IR 05000413/2016007

NRC Problem Identification and Resolution Inspection Report 05000413/2016007 and 05000414/2016007

ML16344A074
Person / Time
Site:	Catawba
Issue date:	12/09/2016
From:	Bradley Davis Reactor Projects Branch 7
To:	Simril T Duke Energy Carolinas
References
IR 2016007
Download: ML16344A074 (17)

Text

December 09, 2016

SUBJECT:

CATAWBA NUCLEAR STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000413/2016007 AND 05000414/2016007

Dear Mr. Simril:

On November 10, 2016, the Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution inspection at your Catawba Nuclear Station, Units 1 and 2 and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.

Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

Finally the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.

The NRC inspectors did not identify any findings or violations of more than minor significance. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Bradley J. Davis, Acting Chief Reactor Projects Branch 7 Division of Reactor Projects

Docket Nos.: 50-413, 50-414 License Nos.: NPF-35, NPF-52

Enclosure:

IR 05000413/2016007 and 05000414/2016007 w/Attachment: Supplemental Information

REGION II==

Docket No.:

50-413, 50-414

License No.:

NPF-35, NPF-52

Report No:

05000413/2016007, 05000414/2016007

Licensee:

Duke Energy Carolinas, LLC

Facility:

Catawba Nuclear Station, Units 1 and 2

Location:

York, SC 29745

Dates:

October 24 - 28, 2016 November 7 - 10, 2016

Inspectors:

J. Worosilo, Senior Project Engineer, Team Leader

M. Toth, Project Engineer N. Pitoniak, Senior Fuel Facility Project Inspector N. Coovert, Senior Construction Inspector

C. Scott, Resident Inspector

Approved by:

Bradley J. Davis, Branch Chief Reactor Projects Branch 7 Division of Reactor Projects

SUMMARY OF FINDINGS

IR 05000413/2016007, 05000414/2016007; 10/24/2016 - 11/10/2016 Catawba Nuclear Station,

Units 1 and 2; Biennial Inspection of the Problem Identification and Resolution Program.

The inspection was conducted by one senior project engineer, one senior fuel facility project inspector, one senior construction inspector, one project engineer, and one resident inspector.

No findings were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,

Revision (Rev.) 6.

Identification and Resolution of Problems

The inspectors concluded that, in general, problems were properly identified, evaluated, prioritized and corrected. The licensee effectively identified problems and entered them into the corrective action program (CAP) for resolution. Generally, prioritization and evaluation of issues were adequate, cause evaluations were adequate, and corrective actions specified for problems were acceptable. Overall, corrective actions developed and implemented for issues were generally effective and implemented in a timely manner.

The inspectors determined that overall audits and self-assessments were adequate in identifying deficiencies and areas for improvement in the CAP, and appropriate corrective actions were developed to address the issues identified. The licensee appropriately evaluated industry operating experience for relevance to the facility and entered applicable items in the CAP. The licensee appropriately incorporated industry and internal operating experience in its cause evaluations.

Based on discussions and interviews conducted with plant employees from various departments, the team determined that personnel at the site felt free to raise safety concerns to management and use the CAP to resolve those concerns.

The NRC inspectors did not identify any findings or violations of more than minor significance.

REPORT DETAILS

4OA2 Problem Identification and Resolution

1. Corrective Action Program Effectiveness

a. Inspection Scope

The team reviewed the licensees corrective action program (CAP) procedures which described the administrative process for initiating and resolving problems primarily through the use of nuclear condition reports (NCRs). To verify that problems were being properly identified, appropriately characterized, and entered into the CAP, the team reviewed a sample of NCRs that had been issued between October 2014 and September 2016, including a detailed review of selected NCRs associated with the following risk-significant systems and components: component cooling water, nuclear service water, and safe shutdown facility. Where possible, the team independently verified that the corrective actions were implemented as intended. The team also reviewed selected common causes and generic concerns associated with root cause evaluations (RCEs) to determine if they had been appropriately addressed. To help ensure that samples were reviewed across all cornerstones of safety identified in the reactor oversight process (ROP), the team selected a representative number of NCRs that were identified and assigned to the major plant departments, including quality assurance, health physics, chemistry, emergency preparedness and security. These NCRs were reviewed to assess each departments threshold for identifying and documenting plant problems, thoroughness of evaluations, and adequacy of corrective actions. The team reviewed selected NCRs, verified corrective actions were implemented, and attended meetings where NCRs were evaluated for significance to determine whether the licensee was identifying, accurately characterizing, and entering problems into the CAP at an appropriate threshold.

Plant walkdowns of equipment within the selected systems listed above and other plant areas were conducted by inspectors to assess the material condition and to identify deficiencies that had not been previously entered into the CAP. The team reviewed NCRs, maintenance history, completed work orders (WOs) for the systems, and reviewed associated system health reports. These reviews were performed to verify that problems were being properly identified, appropriately characterized, and entered into the CAP. Items reviewed generally covered a two-year period of time; however, a five-year review was performed for selected systems to identify trends and age related issues.

Control room walkdowns were also performed to assess the main control room (MCR)deficiency list and to ascertain if deficiencies were being tracked to resolution. A sample of operator workarounds and operator burden screenings were reviewed and the team verified compensatory measures for deficient equipment were being implemented in the field.

Detailed reviews of selected NCRs were performed by the inspectors to assess the adequacy of root cause and apparent cause evaluations for identified problems. The team reviewed these evaluations against the descriptions of the problems described in the NCRs and the guidance in licensee procedures AD-PI-ALL-0101, Root Cause Evaluation, and AD-PI-ALL-0102, Apparent Cause Evaluation. The team assessed if the licensee had adequately determined the cause(s) of identified problems, and addressed operability, reportability, common cause, generic concerns, extent-of-condition, and extent-of-cause. The review also assessed if the licensee had appropriately identified and prioritized corrective actions to prevent recurrence as applicable.

The team reviewed selected industry operating experience (OE) items, including NRC generic communications and Part 21 reports, to verify that they had been appropriately evaluated for applicability or used in licensee activities and that issues identified through these reviews had been entered into the CAP.

The team reviewed site trend reports to determine if the licensee effectively trended identified issues and initiated appropriate corrective actions when adverse trends were identified.

The inspectors reviewed licensee audits and self-assessments, including those which focused on problem identification and resolution programs and processes, to verify that findings were entered into the CAP and to verify that these audits and assessments were consistent with the NRCs assessment of the licensees CAP. The inspectors attended various plant meetings to observe management oversight functions of the corrective action process.

Documents reviewed are listed in the Attachment.

b.

Assessment

Problem Identification

The team determined that the licensee was generally effective in identifying problems and entering them into the CAP and there was a low threshold for entering issues into the CAP. This conclusion was based on a review of the requirements for initiating NCRs as described in licensee procedure AD-PI-ALL-0100, Corrective Action Program, including managements expectation that employees were encouraged to initiate NCRs for any reason, and the lack of deficiencies identified by the team during plant walkdowns not already entered into the CAP. Trending was generally effective in monitoring equipment performance. Site management was actively involved in the CAP and focused appropriate attention on significant plant issues. Based on reviews and walkdowns of accessible portions of the selected systems, the team determined that system deficiencies were being identified and placed in the CAP.

Problem Prioritization and Evaluation

Based on the review of NCRs sampled by the inspection team during the onsite period, the team concluded that problems were generally prioritized and evaluated in accordance with the licensees CAP procedures as described in AD-PI-ALL-0100, Corrective Action Program. Each NCR was assigned a severity level at the centralized screening team (CST) meeting, and this determination was reviewed at the CAP review meeting. Adequate consideration was given to system or component operability and associated plant risk.

The team determined that station personnel had conducted root cause and apparent cause analyses in compliance with the licensees CAP procedures and the assigned cause determinations were appropriate, considering the significance of the issues being evaluated. A variety of formal causal-analysis techniques were used depending upon the type and complexity of the issue consistent with licensee procedures AD-PI-ALL-0101, Root Cause Evaluation, AD-PI-ALL-0102, Apparent Cause Evaluation, and AD-PI-ALL-0103, Quick Cause Evaluation.

Corrective Actions

Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the team determined that generally, corrective actions were timely, commensurate with the safety significance of the issues, and effective, in that conditions adverse to quality were corrected. For significant conditions adverse to quality, the corrective actions directly addressed the cause and effectively prevented recurrence in that a review of performance indicators, NCRs, and effectiveness reviews demonstrated that the significant conditions adverse to quality had not recurred. Effectiveness reviews for corrective actions to prevent recurrence (CAPRs) were sufficient to ensure corrective actions were properly implemented and effective.

2. Use of Operating Experience

a. Inspection Scope

The team examined the licensees use of industry OE to assess the effectiveness of how external and internal operating experience information was used to prevent similar or recurring problems at the plant. In addition, the team selected operating experience documents (e.g., NRC generic communications, 10 CFR Part 21 reports, licensee event reports, vendor notifications, and plant internal operating experience items, etc.), which had been issued since October 2014 to verify whether the licensee had appropriately evaluated each notification for applicability to the Catawba Nuclear Station, and whether issues identified through these reviews were entered into the CAP.

b.

Assessment

Based on a review of documentation related to OE issues, the team determined that the licensee was generally effective in screening operating experience for applicability to the plant. Industry OE was screened by the corporate OE coordinator and relevant information was then forwarded to the sites OE coordinator. Operating experience issues requiring action were entered into the CAP for tracking and closure. In addition, operating experience was included in root cause evaluations and apparent cause evaluations in accordance with licensee procedures AD-PI-ALL-0101, Root Cause Evaluation, and AD-PI-ALL-0102, Apparent Cause Evaluation.

3. Self-Assessments and Audits

a. Inspection Scope

The team reviewed audit reports and self-assessment reports, including those which focused on problem identification and resolution, to assess the thoroughness and self-criticism of the licensee's audits and self-assessments, and to verify that problems identified through those activities were appropriately prioritized and entered into the CAP for resolution in accordance with licensee procedure AD-PI-ALL-0300, Self-Assessment and Benchmark Programs.

b.

Assessment

The team determined that the scopes of assessments and audits were adequate. Self-assessments were generally detailed and critical, as evidenced by findings consistent with the inspectors independent review. The team verified that NCRs were created to document areas for improvement and findings resulting from the self-assessments, and verified that actions had been completed consistent with those recommendations.

Generally, the licensee performed evaluations that were technically accurate.

4. Safety-Conscious Work Environment

a. Inspection Scope

During the course of the inspection, the team assessed the stations safety-conscious work environment (SCWE) through review of the stations employee concerns program (ECP) and interviews with various departmental personnel. The team reviewed a sample of ECP issues to verify that concerns were being properly reviewed and identified deficiencies were being resolved and entered into the CAP when appropriate.

b.

Assessment

Based on the interviews conducted and the NCRs reviewed, the team determined that licensee management emphasized the need for all employees to identify and report problems using the appropriate methods established within the administrative programs, including the CAP and ECP. These methods were readily accessible to all employees.

Based upon interviews conducted with a sample of plant employees from various departments, the team determined that employees felt free to raise issues, and that management encouraged employees to place issues into the CAP for resolution. The team did not identify any reluctance on the part of the licensee staff to report safety concerns.

4OA6 Meetings, Including Exit

On November 10, 2016, the inspectors presented the inspection results to you and other members of the site staff. The inspectors confirmed that all proprietary information examined during the inspection had been returned to the licensee.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

S. Andrews, Regulatory Affairs Senior Engineer

C. Bigham, Organizational Effectiveness Director

M. Brigman, Primary System Engineering Manager

T. Byrne, Fleet Regulatory Affairs

M. Carroll, Safety Analysis

B. Cauthen, System Engineer

C. Curry, Plant Manager

C. Fletcher, Regulatory Affairs Manager

B. Foster, Operations Manager

L. Fredrich, Fleet Equipment Reliability CFAM

T. Garrison, Operations Procedures Supervisor

K. Hear, Battery System Engineer

R. Herring, System Engineer

T. Hinkle, System Engineer

L. Keller, General Manager Nuclear Engineering

K. Lyall, Engineering

J. Marcum, Electrical System Engineer

A. Michalski, Operator Workaround Coordinator

S. Milton, Shift Manager

S. Myers, Engineering Design Director

T. Poetzsch, System Engineering Director

D. Powell, Performance Improvement Manager

T. Robinson, Electrical EDG System Engineer

P. Simpson, Design Manager

W. Snyder, Senior Nuclear Engineer

M. Swim, Diesel System Engineer

L. Vukelja, Performance Improvement

B. Woolweber, I&C Design Engineering

D. Yang, Regulatory Affairs - Engineer

M. Young, Equipment Reliability Lead

NRC personnel

J. Austin, Senior Resident Inspector

LIST OF REPORT ITEMS

Opened and Closed

None