IR 05000237/2014007
| ML14122A273 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 05/02/2014 |
| From: | Cameron J L Reactor Projects Region 3 Branch 4 |
| To: | Pacilio M J Exelon Generation Co, Exelon Nuclear |
| References | |
| IR-14-007 | |
| Download: ML14122A273 (24) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE RD. SUITE 210 LISLE, IL 60532-4352 May 2, 2014
Mr. Michael Senior VP, Exelon Generation Co., LLC President and CNO, Exelon Nuclear 4300 Winfield Road
Warrenville, IL 60555
SUBJECT: DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000237/2014007 AND 05000249/2014007
Dear Mr. Pacilio:
On March 14, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Dresden Nuclear Power Station, Units 2 and 3. On March 27, 2014, the NRC discussed the results of this inspection with Mr. J. Washko and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.
This inspection was an examination of activities conducted under your license as they relate to problem identification and resolution and compliance with the Commission's rules and regulations and the conditions of your license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.
Based on the inspection sample, the inspection team determined that your staff's implementation of the corrective action program supported nuclear safety. In reviewing your corrective action program, the team assessed how well your staff identified problems at a low threshold, your staff's implementation of the station's process for prioritizing and evaluating these problems, and the effectiveness of corrective actions taken by the station to resolve these problems. In each of these areas, the team determined that your staff's performance was adequate to support nuclear safety.
The team also evaluated other processes your staff used to identify issues for resolution. These included your use of audits and self-assessments to identify latent problems and your incorporation of lessons learned from industry operating experience into station programs, processes, and procedures. The team determined that your station's performance in each of these areas supported nuclear safety.
Finally, the team determined that your station's management maintains a safety-conscious work environment adequate to support nuclear safety. Based on the team's observations, your employees are willing to raise concerns related to nuclear safety through at least one of the several means available. NRC inspectors documented one finding of very low safety significance (Green) in this report. This finding involved a violation of NRC requirements. However, because of the very low safety significance, and because the issue was entered into your corrective action program, the NRC is treating the issue as a non-cited violation (NCV) in accordance with Section 2.3.2 of the NRC Enforcement Policy.
If you contest the violations or significance of the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Dresden Nuclear Power Station. If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region III; and the NRC Resident Inspector at the Dresden Nuclear Power Station.
In accordance with Title 10 of the Code of Federal Regulations 2.390, "Public Inspections, Exemptions, Requests for Withholding," of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC's Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Managem ent System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,/RA Bruce Bartlett Acting for/
Jamnes L. Cameron, Chief Branch 4 Division of Reactor Projects
Docket Nos. 50-237; 50-249 License Nos. DPR-19; DPR-25
Enclosure:
IR 05000237/2014007; 05000249/2014007
w/Attachment:
Supplemental Information
cc w/encl: Distribution via LISTSERV
Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION III Docket Nos: 05000237; 05000249 License Nos: DPR-19; DPR-25
Report No: 05000237/2014007; 05000249/2014007
Licensee: Exelon Generation Company, LLC
Facility: Dresden Nuclear Power Station, Units 2 and 3
Location: Morris, IL
Dates: February 24 through March 14, 2014
Inspectors: J. Rutkowski, Project Engineer (Team Lead) D. Szwarc, Senior Reactor Inspector C. Tilton, Senior Reactor Engineer M. Jones, Resident Inspector (Acting)
Approved by: J. Cameron, Chief Branch 4 Division of Reactor Projects 2
SUMMARY OF FINDINGS
Inspection Report (IR) 05000237/2014007, 05000249/2014007; 02/24/2014 - 03/14/2014; Dresden Nuclear Power Station, Units 2 & 3; Problem Identification and Resolution. This inspection was performed by three NRC regional inspectors and the site resident inspector. One Green finding was identified by the inspectors. The finding was considered a Non-Cited Violation (NCV) of NRC regulations. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.
Problem Identification and Resolution On the basis of the sample selected for review, the team concluded that implementation of the corrective action program (CAP) at Dresden Nuclear Power Station, Units 2 and 3, was generally good. The licensee had a low threshold for identifying problems and entering them in the CAP. Items entered into the CAP were screened and prioritized in a timely manner using established criteria; were properly evaluated commensurate with their safety significance; and corrective actions were generally implemented in a timely manner, commensurate with the safety significance. The team noted that the licensee reviewed operating experience for applicability to station activities. Audits and self-assessments were determined to be performed at an appropriate level to identify deficiencies. On the basis of interviews conducted during the inspection, workers at the site expressed freedom to enter safety concerns into the CAP. There was one finding identified by the team during the inspection. The finding involved the failure to adequately evaluate and incorporate a vendor service information letter into the appropriate equipment manuals as required by site procedures. The finding had a cross-cutting aspect in the area of Human Performance.
A. NRC-Identified
and Self-Revealed Findings
Cornerstone: Mitigating Systems
Green: The inspectors identified a finding of very low safety significance and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," for the licensee's failure to ensure that operating experience provided via a vendor Service Information Letter (SIL) was properly evaluated and incorporated into the vendor manual cont rary to the requirements of procedure RS-AA-115, "Operating Experience." The failure to properly assess operating experience for alternating current (AC) Motors resulted in a condition where specific deficiencies could go unrealized under the licensee's conditioned based monitoring program. The licensee initiated action request (AR) 1633528 and 1635766 to document and develop corrective actions for the issue. The finding was determined to be more than minor because it was associated with the Mitigating Systems Cornerstone attribute of design control and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to adequately evaluate and document the basis for the use or rejection of 9 out of 10 experiences presented in General Electric (GE) SIL 484, Supplement 6, could cause a reduction in reliability for safety related systems that use AC motors. The inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, "Significance Determination Process," Appendix A, "The Significance Determination Process (SDP) for Findings At-Power." The finding was screened against the Mitigating Systems Cornerstone, Exhibit 2 of Appendix A, and determined to be of very low safety significance because the answer was "no" to all of the screening questions. This finding has a cross-cutting aspect in the area of Human Performance, Avoid Complacency (H.12), because individuals failed to recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. (4OA2.2)
B. Licensee-Identified Violations
None 4
REPORT DETAILS
OTHER ACTIVITIES
4OA2 Problem Identification and Resolution
(71152B) The activities documented in Sections
.1 through .4 constituted one biennial sample of problem identification and resolution as defined in Inspection Procedure (IP) 71152. .1 Assessment of the Corrective Action Program Effectiveness
a. Inspection Scope
The inspectors reviewed the licensee's CAP implementing procedures and attended CAP meetings to assess the implementation of the CAP program by site personnel. The inspectors reviewed risk and safety significant issues in the licensee's CAP since the last NRC Problem Identification and Resolution (PI&R) inspection in April 2012. The selection of issues ensured an adequate review of issues across NRC cornerstones.
The inspectors used issues identified through NRC generic communications, department self-assessments, licensee audits, operating experience reports, and NRC documented findings as sources to select issues. The inspectors specifically reviewed licensee corrective actions developed to address issues with a flooding finding, that were completed at the conclusion of a NRC IP 95001 as documented in NRC IR 05000237/2013010;05000249/2013010 (ADAMS Accession Number ML14023A004),
dated January 22, 2014. Additionally, the inspectors reviewed issue reports generated as a result of facility personnel's performance in daily plant activities. In addition, the inspectors reviewed issue reports and a select ion of completed investigations from the licensee's various investigation methods, which included root cause, apparent cause, equipment apparent cause, causal factor analysis, latent organizational weakness, and common cause. The inspectors selected the ultimate heat sink with emphasis on containment cooling service water to review in detail. The inspectors' review was to determine whether the licensee staff were properly monitoring and evaluating the performance of the moderate to high risk systems through effective implementation of station monitoring programs. A five year review on the ultimate heat sink and the containment cooling service water system was also undertaken to assess the licensee staff's efforts in monitoring for system degradation due to aging aspects and to determine licensee's efforts to address any identified issues with the system. The inspectors also performed partial system walkdowns of the Unit 2 high pressure coolant injection (HPCI), crib house chemical tank storage area, Units 2 and 3 standby liquid control (SBLC) systems, and the Unit 2 and 3 low pressure coolant injection system. The intent was to verify that the status of systems as reported in plant documents and databases appeared consistent with in-plant observed conditions. During the reviews, the inspectors determined whether the licensee staff's actions were in compliance with the facility's corrective action program and 10 CFR Part 50, Appendix B requirements. Specifically, the inspectors determined if licensee personnel were identifying plant issues at the proper threshold, entering the plant issues into the station's CA program in a timely manner, and assigning the appropriate prioritization for resolution of the issues. The inspectors also determined whether the licensee staff assigned the appropriate investigation method to ensure the proper determination of root, apparent, and contributing causes. The inspectors also evaluated the timeliness and effectiveness of corrective actions for selected issue reports, completed investigations, and NRC findings, including non-cited violations. Specific documents reviewed are listed in the Attachment. b. Assessment (1) Effectiveness of Problem Identification The inspectors concluded that issues were being identified at a low threshold, evaluated appropriately, and recorded correctly in the CAP, and that workers were familiar with the CAP and felt comfortable raising concerns. This was evident by the large number of CAP items generated annually, which were reasonably distributed across the various departments. A shared, computerized database was used for creating individual reports
and for subsequent management of the processes of issue evaluation and response. These processes included determining the issue's significance, addressing such matters as regulatory compliance and reporting, and assigning any actions deemed necessary or appropriate. The inspectors also concluded that the station was generally effective at trending low level issues to prevent larger issues from developing. The inspectors reviewed some specific trend evaluations and did identify some variation in evaluation methods among departments but did not identify any significant concerns.
Observations Inspectors identified notable differences in the methods used during quarterly departmental CAP Coordinator (CAPCO) trending to generate Focus Areas. Inspectors reviewed CAP Documents, trend data and reports, and conducted interviews.
Inspectors determined that while a requirement exists for CAPCOs to identify focus areas on a quarterly basis, the site lacked a process for review or training that ensures effective trending would be performed and appr opriately documented. No formal requirement exists that requires the department CAPCOs to document how focus areas are generated. Although differences existed with some potential areas that could be strengthened in the Maintenance Department, the inspectors did not identify any issue with safety significance. The licensee documents in the CAP approximately 15,000 potential issues each year with most being eventually classified as low or no safety significance. The team determined from interviews that personnel knew that the expectation was to document all issues regardless of safety significance but in several of nine interviewed groups of non-supervisory personnel, personnel stated they passed issues on to supervision and supervision documented the issues. Also, personnel in a few of the interviewed groups said that they felt the CAP was ineffective for less than large or nuclear safety issues and several people mentioned that that they might not use the CAP for non-significant issues. All groups stated that they would not hesitate to bring problems and issues to supervisors. All groups said they would raise perceived nuclear safety issues. The inspectors did not identify any specific issues where plant personnel should have documented issues and did not.
Findings No findings were identified. (2) Effectiveness of Prioritization and Evaluation of Issues The inspectors concluded that the licensee's overall performance in the prioritization and evaluation of issues was appropriate. In particular, the inspectors observed that while the majority of issues identified were at a low level of significance, those issues and issues of more significance were assigned a review and action level appropriate for the identified condition evaluation and in accordance with governing procedures. Issues were being appropriately screened by the Ownership Committee and Operations shift management for items potentially impacting equipment operability, and when requested, by the originator's supervisor. Evaluations in apparent cause and root cause reports reviewed by the inspectors were adequate. There were no items identified by the inspectors in the operations, engineering, training, or maintenance backlogs that were risk significant, either individually or collectively. The inspectors reviewed the licensee's work order backlog and associated performance metric data and concluded that equipment issues were generally being addressed appropriately.
Observations The inspectors reviewed root cause 1305358, "An Unplanned Technical Specification Entry Occurred During Electrical Testing of the Unit 2 Reactor Building Interlock Door."
The root cause evaluated an unplanned technical specification entry that occurred as a result of preventative maintenance that was performed on the Unit 2 reactor building interlock door. The licensee determined the root cause to be an inaccurate work package that was prepared due to a lack of vigor by a work planner. The licensee's corrective action to prevent recurrence (CAPR) was to remove the qualification of the work planner. Since the inspectors were aware that the licensee had experienced several issues with unplanned Technical Specification entries associated with door interlocks, the inspectors considered this root cause evaluation to be narrowly focused and one in which a wider view might have determined other options to prevent additional door interlock failures. The licensee has taken additional action to address the underlying issues with the door interlock systems including an interim action to post a dedicated individual to operate a frequently used door system. The inspectors also identified two evaluations where the inspectors experienced difficultly understanding the "root cause statement" and how it was derived for the evaluations documented in the reports. In both evaluations, the inspectors noted that
the evaluations were extensive and the developed corrective actions were appropriate for the identified issues. The inspectors observed that templates/standard forms were extensively used in evaluation reports. The use of such templates appeared to ensure coverage of all relevant items required by licensee procedures; however, for some of the products reviewed, the use of templates in which many items were not relevant, complicated the review of the evaluations.
Findings No findings were identified. (3) Effectiveness of Corrective Actions On the basis of the corrective action documents reviewed, the inspectors concluded that the corrective actions were appropriate for the identified issues. Those corrective actions addressing selected NRC documented violations were also determined to be effective and timely. The inspectors' review of the previous five years of the licensee's efforts to address issues with the ultimate heat sink did not identify any negative trends or inability by the licensee to address long-term issues.
Observations The inspectors observed that some quarterly trend reports, specifically, in the maintenance department over the last two years, were lacking in detail. Specifically, those reports listed ARs and their trend codes but did not provide an analysis of those trends. However, after discussions with the licensee the inspectors concluded the licensee was using trending data in an appropriate manner to identify adverse trends
that could impact the performance of st ructures, systems, and components. The maintenance department was evaluating the trending data on a monthly basis even though that was not discussed in the quarterly trend reports. The licensee planned to develop more robust quarterly maintenance trend reports. The inspectors reviewed corrective actions from licensee root cause evaluation (RCE) developed as "AR 1513453. NRC: Preliminary White Finding - Flood Mitigation Procedure," and considered the below corrective actions appropriately closed:
- describe and document the training program to be implemented and the periodicity the training will be offered - scheduled completion 2/7/2014 - RCE assignment number 40;
- revise DOA 0010-03, "Earthquakes," to include a method to reduce releases from the spent fuel pool in the event of fuel damage - scheduled completion 2/28/2014 - RCE assignment number 34; and
- revise DOA 0010-02, "Tornado Warning-Severe Winds," to include a method to reduce releases from the spent fuel pool in the event of fuel damage - scheduled completion 2/28/2014 - RCE assignment number 33.
The following corrective actions remain to be reviewed during future inspections:
- put into existing or to be developed case studies the flooding licensing knowledge gap that contributed to the finding - scheduled completion 3/22/2014 - RCE assignment number 18;
- Develop and present a case study for applicable Dresden personnel showing the impact of a minimal compliance culture - scheduled completion 6/22/2014 - RCE assignment number 16; and
- Perform effectiveness review of corrective actions taken - scheduled completion 8/13/2014 - RCE assignment number 20.
The above are scheduled dates that were assigned as of the NRC inspection that was
completed in December 2013.
Findings No findings were identified.
.2 Assessment of the Use of Operating Experience
a. Inspection Scope
The inspectors reviewed the licensee's implementation of the facility's Operating Experience (OE) program. Specifically, the inspectors reviewed implementing OE program procedures, attended CAP meetings to observe the use of OE information, completed evaluations of OE issues and events, and selected monthly assessments of the OE composite performance indicators. The inspectors' review was to determine whether the licensee was effectively integrating OE experience into the performance of daily activities, whether evaluations of issues were proper and conducted by qualified personnel, whether the licensee's program was sufficient to prevent future occurrences of previous industry events, and whether the licensee effectively used the information in developing departmental assessments and facility audits. The inspectors also assessed if corrective actions, as a result of OE experience, were identified and effectively and timely implemented. In addition, the inspectors review included a sample portion of OE driven corrective actions resulting from 10 CFR Part 21 reports. The inspectors verified the licensee adequately evaluated the vendor's issues for applicability to the station. The inspectors also confirmed the licensee correctly justified whether or not programmatic controls were in place that would prevent similar issues at the site. In addition, the inspectors verified the licensee initiated actions to detect, prevent, monitor and correct conditions to prevent future occurrences related to the vendor's report. Specific documents reviewed are listed in the Attachment. b. Assessment In general, OE was effectively used at the station although the inspectors identified an instance associated with OE not being appropriately incorporated into a vendor manual. The inspectors observed that OE was discussed as part of the daily station and pre-job briefings. Industry OE was effectively disseminated across the various plant departments and no issues were identified during the inspectors' review of licensee OE evaluations. During interviews, several licensee personnel commented favorably on the use of OE in their daily activities.
The team noted that root and apparent cause evaluations were required to evaluate whether internal or external operating experience was available associated with the event or failure being examined, and whether the evaluation and actions to address those items had been effective. Additionally, all root cause evaluations reviewed included an assessment as to whether the issue being evaluated had potential application to other similar component or plants.
Findings
Introduction:
The inspectors identified a finding of very low safety significance (Green) and associated NCV of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," for the licensee's failure to ensure that operating experience provided via a vendor SIL was properly evaluated and incorporated into a vendor manual. The failure to properly assess operating experience for AC motors resulted in a condition where specific deficiencies could go unrealized under the licensee's conditioned-based monitoring program.
Description:
The inspectors reviewed open and closed ARs, operating experience, and preventive maintenance records for the low-pressure coolant injection system. As a part of this review inspectors selected AR 1359698, "Cancelling 3A low-pressure coolant injection (LPCI) Pump Rebuild and Motor Replace in D3R22", dated April 27, 2012, for review during this inspection. This AR cancelled previously scheduled 3A LPCI pump rebuild and motor refurbishment. Per the Exelon performance centered maintenance (PCM) pump template the recommended interval for internal inspection of the LPCI pumps should not exceed 16 years. The PCM template for certain critical high and medium voltage electric motors recommended motor refurbishment on a 15-year frequency. The licensee reviewed the Vendor Manual VETIP 1122, 'LPCI Vendor Manual," and did not identify recommendations on either the frequency of pump internal inspections, motor rebuilds, or motor replacements. The licensee contacted the vendor for the LPCI pumps and motors, and documented that each vendor stated that major work such as internal inspections and motor refurbishment is based on the site's condition monitoring program of the components.
The licensee stated that, "as long as the equipment is performing as required and there are not adverse trends, then a rebuild or replacement is not required." However, inspectors reviewed the vendor manual, and associated SILs associated with the LPCI pumps and motors and noted that in GE SIL 484, Supplement 6, General Electric recommended periodic partial disassembly of the pump and motors on a periodic basis, in concert with scheduled testing programs, due to several issues identified that have the potential to go undetected under typical condition based monitoring programs that include vibration, temperature monitoring, winding electrical tests, thermography, and oil analysis. Additionally, inspectors noted that GE SIL 484 Supplement 6 was not contained in the vendor manual. The licensee initiated AR 1633528, "LPCI Motor VTIP Binder Missing SIL." Inspectors reviewed the licensee's assessment AR 70211, "GE SIL 484 Supplement 6, Experience with AC Motors, dated November 2001," and determined that the licensee failed to adequately evaluate the operating experience presented in Supplement 6 of the SIL and failed to document the use or rejection of the recommendations made in the Letter, as required by RS-AA-115, "Operating Experience," Revision 2. The licensee only assessed 1 of the 10 potentially applicable experiences, and failed to document why the remaining nine were rejected. The inspectors performed a historical review of the installed LPCI and core spray (CS) motors and pumps and determined that six of eight LPCI motors have been installed for greater than 19 years and four of four CS motors have been installed greater than 17 years without periodic partial disassembly inspections as recommended in the GE SIL 484 Supplement 6. Additionally, when the inspectors requested program change documents and deferral justifications for changing and exceeding the PCM template recommendations, the licensee was not able to locate and provide the justifications. Specifically, the PCM template provides a motor refurbishment frequency of 15 years and SIL 484 Supplement 6 recommends an integrated periodic partial disassembly and condition based monitoring program. The notes that accompany this time directed tasks of the PCM template state: Note 1: "-at a minimum, in-situ periodic partial disassembly shall be performed at a frequency directed by the motor OEM or other industry document if the recommended frequency from the motor OEM is not available." Note 4: "A partial disassembly and inspection might also be performed on a motor that gets tested under the requirements of the Electrical Maintenance Logic Tree to perform dimensional checks of bearings, and shaft fits and to also determine the conditions of stator winding/bracing/wedging/ and rotor which typically cannot be determined by other diagnostic testing, to determine if comprehensive refurbishment or rewind will be required. At the time of a scheduled partial disassembly and inspection, it may be prudent to proactively schedule a motor refurbishment and or rewind in lieu of performing the partial disassembly at risk." Additionally, the inspectors noted one instance where the licensee identified a failure to incorporate Supplement 5 of GE SIL 484, dated May 16, 2012. To address the issue of unevaluated and unincorporated Vendor, the licensee initiated AR1350052 and 1350055 in 2012 and created an action item for Engineering to review a list from GE correspondence and create, as necessary, additional actions to address GE recommendations. Inspectors noted that systems engineering completed this action item with no additional action identified. Inspectors concluded that the licensee failed to identify that Supplement 6 to GE SIL 484 was not properly incorporated per site procedures. Inspectors determined the failure to integrate motor partial disassembly into licensee condition based monitoring program for the LPCI and CS pump motors also potentially affects the remaining plant population of high and medium voltage AC motors. The licensee created AR 1635766, "Review of GE SIL 484 on 4KV motors Implementation,"
to evaluate all large GE motors to compare the Dresden preventive maintenance (PM) program strategy with that of the PM strategy and the recommended guidance within GE SIL 484 Supplement 6.
Analysis:
The inspectors determined the failure to adequately evaluate and incorporate GE SIL 484, Supplement 6, "Experience with AC Motors," into the Vendor Manual as required by step 4.4.3 of Procedure RS-AA-115, which required the licensee to "document all reviews with specific information related to the use or rejection of the information contained in the document," was a performance deficiency warranting review. The finding was determined to be more than minor because it was associated with the Mitigating Systems Cornerstone attribute of design control and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to adequately evaluate and document the basis for the use or rejection of 9 out of 10 experiences presented in GE SIL 484, Supplement 6, could cause a reduction in reliability for systems that use AC motors. Six LPCI motors have been installed for greater than 19 years and four CS motors have been installed greater than 17 years without periodic partial disassembly inspections in accordance with the vendor recommendations in SIL 484 Supplement 6 or in accordance with the PCM template. At the conclusion of the inspection the licensee failed to provide a documented basis or evaluation that justified the current specified preventive maintenance and associated intervals for AC motor rewind and refurbishment. The inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, "Significance Determination Process," Appendix A, "The Significance Determination Process (SDP) for Findings At-Power." The finding was screened against the Mitigating Systems Cornerstone and determined to be of very low safety significance (Green) because the finding: 1) was not a deficiency affecting the design or qualification of a mitigating structure, system or component, 2) did not represent a loss of system and/or function, 3) did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time, 4) did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and 5) did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding or severe weather event. This finding has a cross-cutting aspect in the area of Human Performance, Avoid Complacency, because individuals failed to recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes.
Specifically, the licensee failed to adequately evaluate and incorporate General Electric SIL 484, Supplement 6, "Experience with AC Motors,' into the LPCI Vendor Manual as required by Site Specific Operating Experience Procedure in the original evaluation performed under AR 70211 in November 2001 and di d not identify in actions associated with AR1350052 and AR1350055, written in 2012, the failure to properly review and disposition the recommendations of SIL 484 Supplement 6. [H.12]
Enforcement:
10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," requires, in part, that activities affecting quality be prescribed by documented procedures of a type appropriate to the circumstances and be accomplished in accordance with these procedures. The licensee established RS-AA-115, "Operating Experience (OPEX)," as the implementing procedure for evaluating and initiating action for operating experience and CC-AA-204, "Control of Vendor Equipment Manuals," to provide a method to maintain the adequacy of vendor manuals. RS-AA-115, Step 4.3.3 stated, "Document all reviews with specific information related to the use or rejection of the information contained in the document."
Contrary to the above, in November 2001, the subject matter expert failed to follow step 4.3.3 of procedure RS-AA-115, Operating Experience (OPEX). Specifically, the subject matter expert failed to provide technical justification for deviating from the vendor recommendations provided for specific failure mechanisms not identifiable through the licensee's condition-based preventive maint enance program. Additionally, the licensee has not provided adequate basis for deviating from the vendor recommended periodic disassembly, or the PCM template interval of 15 years for AC motor rewind. Because this violation was of very low safety significance and it was entered into the licensee's CAP as AR 1633528 and 1635766 this violation is being treated as an NCV consistent with section 2.3.2 of the NRC enforcement policy. The Licensee is performing an evaluation on all large GE motors and comparing the preventive maintenance strategy with that of the recommended guidance within GE SIL 484
Supplement 6. (NCV 05000237/2014007-01; 05000249/2014007-01, Failure to Adequately Incorporate GE Operating Experience into Vendor Manual)
.3 Assessment of Self-Assessments and Audits
a. Inspection Scope
The inspectors assessed the licensee staff's ability to identify and enter issues into the CAP program, prioritize and evaluate issues, and implement effective corrective actions through efforts from departmental assessments and audits. The inspectors reviewed Nuclear Oversight audits, departmental self-assessments, and departmental performance assessment reports. Additionally, the inspectors reviewed any assessments associated with assessment of the self-assessment program. Specific documents reviewed are listed in the Attachment. b. Assessment The inspectors concluded that self-assessments and audits were typically accurate, thorough, and effective at identifying most issues and enhancement opportunities at an appropriate threshold. The inspectors concluded that personnel involved in audits and self-assessments were knowledgeable in the subject area they audited or assessed. In
many cases, self-assessments and audits identified issues that were not previously recognized by the licensee.
Findings No findings were identified.
.4 Assessment of Safety Conscious Work Environment
a. Inspection Scope
The inspectors assessed the licensee's sa fety conscious work environment (SCWE) through the reviews of the facility's employee concern program implementing procedures, discussions with coordinators of the employee concern program, interviews with personnel from various departments, and reviews of issue reports. The inspectors
also reviewed the results from two safety culture surveys that collected survey results in 2011 and also minutes from several meetings of the Dresden Safety Culture Monitoring Panel. As part of the overall inspection effort, inspectors discussed department and station programs with a variety of people. In addition, the inspectors interviewed 38 individuals, in groups of three to five people, from various departments to assess their willingness to raise nuclear safety issues. The individuals were non-supervisory personnel and were selected to provide a distribution across the various departments at the site. In addition, to assessing individuals' willingness to raise nuclear safety issues, the interviews also addressed changes in the plant environment over the past two years. Other items discussed included:
- knowledge and understanding of the CAP;
- effectiveness and efficiency of the CAP;
- willingness to use the CAP; and
- knowledge and understanding of Employee Concerns Program (ECP).
b. Assessment The inspectors did not identify any issues of concern regarding the licensee's safety conscious work environment. Information obtained during the interviews indicated that an environment was established where licensee and contract employees felt free to raise nuclear safety issues without fear of retaliation; licensee personnel were aware of and generally familiar with the CAP and other processes, including the ECP and the NRC, through which concerns could be raised, and safety significant issues could be freely communicated to supervision. Documents provided to the inspectors regarding safety culture surveys and monitoring of the safety culture and SCWE generally supported the conclusions from the interviews.
Observations While all interviewees stated that they would discuss issues with their supervisors and would bring up any and all nuclear safety issues, interviewees in five of the nine groups stated that while the CAP worked for important items, they believed it did not work well for lesser items. In two of the interviewed groups, several interviewees mentioned that they might not document in CAP low-significance issues. Interviewees in four of the nine groups mentioned at least one plant system that in their opinion was not getting the attention that it should. All of the systems mentioned were non-safety and were not directly involved in making electricity.
Interviewees in four of the groups mentioned that they were concerned with the declining level of employee experience and believed the experience level would continue to decline with the number of experienced people approaching retirement. Interviewees specifically mentioned the engineering groups and first line supervisors. No interviewees described a condition where the decreasing level of experience presently created a nuclear safety issue. The ECP program at the site only was required to conduct one formal investigation in 2013. Interviewed personnel stated that they were aware of the program but did not use the program because they could bring up issues with their supervisors.
Findings No findings were identified.
4OA6 Management Meetings
.1 Exit Meeting Summary
On March 27, 2014, the inspectors presented the inspection results to Mr. J. Washko, Plant Manager, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary. ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- S. Marik, Site Vice President
- J. Washko, Plant Manager
- G. Morrow, Regulatory Assurance Manager
- P. O'Brien, CAP Manager DJ Walker, NRC Coordinator
- T. Griffith, Thomas, Regulatory Engineer
Nuclear Regulatory Commission
- G. Roach, Senior Resident Inspector
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
Opened
- 05000249/2014007-01 NCV Failure to Adequately Incorporate GE Operating Experience
into Vendor Manual (4OA2.2)
Closed
- 05000249/FIN-2014007-01 NCV Failure to Adequately Incorporate GE Operating Experience
into Vendor Manual (4OA2.2)
LIST OF DOCUMENTS REVIEWED
The following is a list of documents reviewed during the inspection.
- Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that selected sections of portions of the documents were evaluated as part of the
overall inspection effort.
- Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report.
- PLANT PROCEDURES
- Number Description or TitleDate or Revision
- Control of Vendor Equipment Manuals
- 4131 Raw Water Chemical Feed Equipment Repair and Preventative Maintenance Program 4CY-DR-120-500
- Fuel Oil Chemistry Aging Management
- Program 0CY-DR-120-900
- Diesel Fuel Oil Testing
- 1DEOP 200-1
- Primary Containment Control
- 10DGA 12 Partial or Complete Loss of AC Power
- 2DOA 0010-01
- Dresden Lock and Dam Failure
- 31DOA 0010-02
- Tornado Warning/Severe Winds
- 19DOA 0010-03
- 21DOS 0010-01
- Dresden Dam Failure Equipment Test
- 2DOS 0040-02
- Operator Oil Sampling for Offsite Laboratory Analysis
- 137 DTS 3900-07
- Crib House/Intake Structure Inspections
- Employee Concerns Program
- Employee Concerns Program Process
- Preventive Maintenance Program
- 1004 Maintenance Rule - Performance
- Monitoring
- 1005 Standard Approach on How to Evaluate and Inspect Outside Diameter Corrosion on Piping and Components
- Structures Monitoring
Operating Experience
- Program
- 1001 Processing of Level 1 Opex Evaluations
- 1002 Processing of Level 2 Opex Evaluations
- 1003 Processing of Level 5 Opex Evaluations
- LS-AA-115-
- Issue Identification And Screening Process 15LS-AA-125
- Corrective Action Program (Cap)
Procedure
- 1001 Root Cause Analysis Manual
- 1003 Apparent Cause Evaluation Manual
- 1004 Effectiveness Review Manual
- 1005 Coding and Analysis Manual
- Self-Assessment and Benchmark (SAB)
- Program 7LS-AA-126-
- 1001 Focused Area Self-Assessments
- 1005 Check-In Self-Assessments
- Safety Culture Monitoring
- Conduct of Radiation Protection Operations
Operating Experience
(OPEX)
- TSG-3 Operational Contingency Action
- Guidelines
- Work Screening and Processing
- CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED
- Number Description or TitleDate or Revision
- AC Motors
- 07/27/2001
- System 08/15/2003
- 05/10/2007
- 876437 Fire Panels Potentially Mislabeled
- 2/5/2009
- 2641 IST Requirements for DG Starting Air Check Valves
- 07/16/2009
- 1094745 NRC Question Regarding Implementation of TS 5.5.9
- 07/27/2010
- 1144302 Pressure Switch Conduit Damaged for
- LPCI Pressure Switch
- 11/23/2010
- 1173579 NRC Heat Sink Inspection - Bay 13 Inspection Corrosion
- 2/10/2011
- 1202741 Enhancement to DGA 12
- 04/14/2014
- 21386 NRC Identifies Issues With Procedure for Dam Failure
- 05/27/2014
- 21390 NRC Ids Issues With Surveillance
Procedure
for Dam Failure
- 05/27/2011
- 21421 2/3 Screen Refuse Pumps Not in the Maintenance Rule
- 05/27/2011
- 242735 Increasing Trend in HU Cross-Cutting
- Violations
- 07/22/2011
- 273762 NRC - Information on the EP Alert Classification
- 10/7/2011
- 277368 D2R22LL: IRM Half Scram Occurred During Reactor Shutdown
- 10/17/2011
- 1302573 NRC SRI Question on Chemical Tanks
and CREVS
- 2/14/2011
- 1305358 Unplanned Tech Spec Entry
- 2/21/2011
- 21542 Permanent Scaffold Rack Blocking Access to Operations Equipment
- 2/1/2012
- 1333925 Ops to Perform RCA For CPO
- Observations
- 2/29/2012
- 1350052 Motor VTIP Not Updated
- 04/4/2012
- 1350055 General Electric SIL Not Incorporated Into the VTIP Manual
- 04/4/2012
- 1359669 MRule: Declining Engineering Expert Panel Attendance Trend
- 04/27/2012
- 1359698 Cancelling 3A LPCI Pump Rebuild and Motor Replace in D3R22
- 04/27/2012
- 1360547 MRule: Z60 Generator Qtr Eval Documentation Questioned
- 04/30/2012
- 1365413 MRFF IR Determination Not Completed
- Within 30 Days
- 05/11/2012
- 1381696 RP Document Review Generates Root Cause Request
- 06/25/2012
- 21473 Radioactive Source Not Properly Controlled
- 10/2/2012
- 1441571 Calcs DRE98-0031, DRE02-0055, &
- 20-58-19-1 Need Revision
- 11/17/2012
- 1450288 Procedure Revision Causes Core Flow Unexpected Results (ACE)
- 2/10/2012
- 1467756 Annual Review of Confined Space Permits 01/25/2013
- 27619 Continuous Fire Watch TRM Requirement
- 06/21/2013
- 07/23/2013
- 1540092 Standards Issue Identified in FASA
- 07/26/2013
- 1540566 Transformer 28 Nitrogen Pressure Found to be Negative
- 07/29/2013
- 1541190 NRC Question:
- Modification (SLIV 2013004-01)
- 07/30/2013
- 1567188 FME:
- NOS ID Operator Rounds Observation Issue
- 10/3/2013
- 1590970 U2 X-Area Secondary Containment Doors Open at the Same Time
- 11/28/2013
- 1591931 Root Cause Investigation Initiated
- 2/2/2013
- 1631228 PMC Unit 2 SBLC Heat Trace Incorrectly Installed
- 03/6/2014
- 03/14/2014
- 1635766 Review of GE
- 03/19/2014
- OPERATING EXPERIENCE
- Number Description or TitleDate or Revision
- 01564532-69
- Dresden Review of ICES 309328
- 2/13/2014
- 01564532-55
- Dresden Review of ICES 308960
- 01/28/2014
- 1630103
- PT 21 - 2014-01-00 Loose Battery Vent Assemblies
- 03/3/2014
- 1630121
- PT 21-2014-02-00 Non-Conformance of Electrical Water Heaters
- 01/16/2014
- AUDITS, ASSESSMENTS AND SELF-ASSESSMENTS
- Number Description or TitleDate or Revision
- 1312813 Work Package Quality Check-In
- 2/24/2012
- 1318828 Check-In:
- 3rd Qtr 2012
- Self Assessment/Benchmark Review
- 22489 Dresden Maintenance Rule Program
- 10/15/2012
- 22489 Dresden Maintenance Rule Program
- FASA 10/15/2012
- 1342784 Maintenance Rule Program Check-In
- 06/21/2012
- 1355518 Electronic Critical Component Preventative Maintenance
- 09/28/2012
- 1383346 Safety Committee Alignment with SA
Procedures
- 06/29/2012
- 1396445
- NOSCPA-DR-12-3T-Learnings Prog CAP #20/Report/OE
- 08/2/2012
- 10/11/2012
- 1432697 Work Management FASA
- 03/18/2013
- 1436699 Pre-NRC Radiation Protection Baseline Assessment FASA
- 3/20/2013
- 1442930 Corrective Action Program Audit Report
- NOSA-DRE-13-04
- 05/1/2013
- 1442932 Radiation Protection Audit Report
- NOSA-DRE-13-06
- 07/9/2013
- 1442937 Operations Audit Report NOSA-DRE-13-
- 10/10/2013
- 1449521 Check-In:
- Annual Aggregate Burden
- 1461088 Assessing Operator Fundamentals
- FASA 07/31/2013
- 1462607 Adverse Trend in Self-Assessment Program Implementation
- 01/15/2013
- 1478244 2013 Employee Concerns Program
- 2/20/2013
- 1483709 Dresden 2013 Biennial Self-Assessment
& Benchmark Programs
- 04/11/2013
- 1550966 Check-In:
- 2013 Training Dept Qualifications
- 242095-03
- General Electric HFA Relay Failure Results in the Inability to Start the 3A
- Reactor Feed Pump
- 10/5/2011
- 1353494-04
- Failure of MOV 3-1501-11A to Stroke Closed 10/31/2013
- 1441587-04
- Engineering Dept. OPS Focus
- 4/26/2013
- CPA 13-20
- Learning Programs Focused Assessment Plan
- 2/20/2013
- Safety Culture Survey Results From Early and Late 2012
- OTHER DOCUMENTS
- Number Description or TitleDate or Revision
- TSP 2011-055
- Temporary Contact Shielding Permit for
- Shielding Line
- 2-1913-10" Elevated Dose Area 10/12/2011
and IST Surv
- 2/21/2013
- Meeting Minutes - Safety Culture Monitoring Panel
- 2/7/2013
- Semi-Annual Safety Culture Review Template 10/1/2013
- Simulator Work Requests; 2/27/2013 to
- 2/27/2014
- 2/27/2014
- Radiation Protection Department Trending Summary Report
- 4th Quarter 2012
- Radiation Protection Department Trending Summary Report
- 3rd Quarter 2013
- Radiation Protection Department Trending Summary Report
- 4th Quarter 2013
- Operations Department 2012 Fourth Quarter Trending Data
- 4th Quarter 2012
- Operations Department 2013 Fourth Quarter Trending Data
- 4th Quarter 2013
- CONDITION REPORTS GENERATED DURING INSPECTION
- Number Description or TitleDate or Revision
- 23497 NRC Questioned a Noise Coming from 2B
- EHC Pump 02/19/2014
- 03/14/2014
- DRAWINGS Number Description or TitleDate or Revision
- M-29 Diagram of LP Coolant Injection Piping
- BG M-193 Outdoor Piping
- L M-4278 CCSW Pump 2A-1501-44 Seal Tubing Replacement
- A
- WORK ORDERS/SURVEILLANCES
- Number Description or TitleDate Completed
- 1302-4 Group 2
- 01/18/2007
- 764456
- 1301-1 Group 2
- 2/25/2008
- 1668190 D2/3 Qtr Com Insp Fire Pump Bay/DwnStrm Screen With Diver
- 09/9/2013
- Surv 09/21/2013
- 1551503 06
- EM Remove / Reinstall Heat Trace from 2A SBLC Squib Valve
- 11/24/2013
- 01/14/2014
- 1699853 D2/3 Qtr Com Insp Fire Pump Bay/DwnStrm Screen With Diver
- 01/15/2014
LIST OF ACRONYMS
- USED [[]]
- CAPCO [[]]
NRC inspectors documented
one finding of very low safety significance (Green) in this report. This finding involved a violation of NRC requirements. However, because of the very low safety
significance, and because the issue was entered
into your corrective action program, the
NCV) in accordance with Section 2.3.2 of the NRC
If you contest the violations or significance of the NCV,
you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the
ATTN: Document Control Desk, Washington DC 20555-0001; with
copies to the Regional Administrator, Region
DC 20555-0001; and the NRC Resident
Inspector at the Dresden Nuclear Power Station. If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region
III; and the NRC Resident Inspector at the Dresden Nuclear Power Station.
In accordance with Title 10 of the Code of Federal Regulations 2.390, "Public Inspections, Exemptions, Requests for Withholding," of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the
NRC's Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Managem
ent System (ADAMS).
NRC Web site at http://www.nrc.gov/reading-rm/adams.html
(the Public Electronic Reading Room).
Sincerely,
/RA Bruce Bartlett Acting for/
Jamnes L. Cameron, Chief Branch 4 Division of Reactor Projects Docket Nos. 50-237; 50-249
Enclosure:
IR 05000237/2014007; 05000249/2014007
w/Attachment: Supplemental Information
cc w/encl: Distribution via LISTSERV
- See next page
- DOCUME NT NAME: Dresden 2014007 Publicly Available Non-Publicly Available Sensitive Non-Sensitive To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy
- OFFICE [[]]
- RIII [[]]
- NAME [[]]
- RECORD [[]]
COPY
Letter to Michael Pacilio from Jamnes Cameron dated May 2, 2014
- POWER [[]]
- AND [[]]
AND 05000249/2014007
RidsNrrDorlLpl3-2 Resource RidsNrrPMDresden Resource
RidsNrrDirsIrib Resource
Cynthia Pederson
- DRPIII [[]]
DRSIII Patricia Buckley