IR 05000321/2003007

IR 05000321-03-007 & IR 05000366-03-007, Edwin I. Hatch Plant, August 11-29, 2003. Identification and Resolution of Problems

ML032730674
Person / Time
Site:	Hatch
Issue date:	09/26/2003
From:	Brian Bonser NRC/RGN-II/DRP/RPB2
To:	Sumner H Southern Nuclear Operating Co
References
IR-03-007
Download: ML032730674 (26)

Text

ber 26, 2003

SUBJECT:

EDWIN I. HATCH NUCLEAR PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT NO. 05000321/2003007 AND 050000366/2003007

Dear Mr. Sumner:

On August 29, 2003, the U. S. Nuclear Regulatory Commission (NRC) completed a team inspection at the Hatch Nuclear Plant. The enclosed report documents the inspection findings which were discussed on August 29, 2003, with Mr. George Frederick and other members of your staff.

This inspection was an examination of activities conducted under your licenses as they relate to the identification and resolution of problems, and compliance with the Commissions rules and regulations and the conditions of your operating licenses. Within these areas, the inspection involved a selected examination of procedures and representative records, observation of activities, and interviews with personnel.

Based on the sample selected for review, the team concluded that in general problems were properly identified and evaluated. A low threshold for identifying problems was maintained as evidenced by the large number of condition reports entered annually into the corrective action program. The team also noted, however, repetitive equipment related problems that were not resolved in a timely manner. There were two findings of very low safety significance (Green)

identified in the report. The two findings are illustrative of problems associated with the effectiveness of corrective actions. These findings were determined to involve violations of NRC requirements. However, because of their very low safety significance and because they have been entered into your corrective action program, the NRC is treating these findings as non-cited violations, in accordance with Section VI.A.1 of the NRCs Enforcement Policy. If you deny these non-cited violations, you should provide a response with the basis for your denial, within 30 days of the date of this inspection report, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington DC 20555-0001; and the Resident Inspector at the Hatch Nuclear Plant.

In accordance with 10 CFR 2.790 of the NRCs Rules of Practice, a copy of this letter, and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs document

SNC 2 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/

Brian R. Bonser, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket Nos.: 50-321, 50-366 License Nos.: DPR-57, NPF-5

Enclosure:

Inspection Report 05000321/2003007 and 05000366/2003007 w/Attachment: Supplemental Information

REGION II==

Docket Nos.: 50-321, 50-366 License Nos.: DPR-57, NPF-5 Report Nos.: 05000321/2003007 and 05000366/2003007 Licensee: Southern Nuclear Operating Company, Inc. (SNC)

Facility: Edwin I. Hatch Nuclear Plant, Units 1 and 2 Location: P.O. Box 2010 Baxley, Georgia 31515 Dates: August 11, 2003 - August 29, 2003 Inspectors: B. Desai, Senior Project Engineer (Team Leader)

N. Garrett, Resident Inspector F. Jape, Senior Project Manager T. Kolb, Operator License Examiner Approved By: Brian R. Bonser, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000321/2003-007, 05000366/2003-007; 08/11/2003 - 08/29/2003; Edwin I. Hatch Nuclear

Plant, Units 1 and 2; Identification and Resolution of Problems. Two violations were identified that are illustrative of problems with the effectiveness of corrective actions.

The inspection was conducted by a senior project engineer, a senior project manager, a license operator examiner, and a resident inspector. Two Green non-cited violations (NCVs) were identified. The significance of most findings is indicated by their color (Green, White, Yellow,

Red) using IMC 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.

Identification and Resolution of Problems The team identified that the licensee was generally effective at identifying problems and entering them into the corrective action program (CAP) for resolution. The licensee maintained a low threshold for identifying problems as evidenced by the continued large number of condition reports (CR) entered annually into the CAP. The team also determined that the licensee was generally prioritizing and evaluating issues properly. The team concluded however, that deficiencies exist in the implementation of effective corrective actions to prevent recurrence. Numerous repetitive equipment problems had not been resolved in a timely manner. Two NCVs involving 10 CFR 50, Appendix B, Criterion XVI, Corrective Actions, were identified. Audits and self-assessments continued to identify issues related to the corrective action program. On the basis of interviews conducted during the inspection, the team identified that personnel at the site felt free to raise safety concerns to management and to resolve issues via the CAP.

Cornerstone: Mitigating Systems

Green.

A Green NCV of 10 CFR 50, Appendix B, Criteria XVI, involving inadequate corrective actions for a previously identified NCV was identified. This resulted in the failure to perform a Technical Specification surveillance requirement within the specified frequency.

This finding is more than minor because if left uncorrected TS required surveillances would not be performed due to procedural inadequacies. Specifically, this finding involved the failure to determine the extent of condition with regard to procedural deficiencies following initial identification of deficiencies in September 2001. In this instance, the individual channel response times could have become greater than the maximum values assumed in the safety analysis associated with the Minimum Critical Power Ratio (MCPR) Safety Limit. This missed surveillance requirement was determined to be of very low safety significance (Green) because the subsequent successful performance of the response time test demonstrated the relays were operable at all times (Section 4OA2).

Green.

A Green NCV of 10 CFR 50, Appendix B, Criteria XVI, was identified for failure to identify that recurring pressure transients during Residual Heat Removal Service Water (RHRSW) pump startup required evaluation.

This finding is is more than minor because on multiple occasions the piping design pressure was exceeded yet the licensee failed to evaluate the effect of the pressure transient on the system. This issue is of very low safety significance (Green) because it did not actually result in the safety related system being inoperable for greater than the time allowed by plant TS (Section 4OA2).

Licensee-Identified Violations

None.

REPORT DETAILS

4OA2 Problem Identification and Resolution

a. Effectiveness of Problem Identification

(1) Inspection Scope The team reviewed a sample of Condition Reports (CRs) for issues across the seven cornerstones of safety to determine if problems were identified, characterized, and entered into the Corrective Action Program (CAP). The majority of the CRs reviewed by the team were for the period from July 2001 to August 2003. The team also reviewed maintenance work orders (MWOs), personnel contamination events, emergency preparedness related deficiencies documented in CRs, employee concerns log, Maintenance Rule status for various systems, selected self-assessments, audits, trend reports, operability evaluations, temporary modification log, operator workaround log, and operator logs. The team also reviewed the system health reports for the following systems: Residual Heat Removal (RHR), High Pressure Coolant Injection (HPCI),

Reactor Core Isolation Cooling (RCIC), Plant Service Water (PSW), Residual Heat Removal Service Water (RHRSW), Instrument Air, Emergency Diesel Generators (EDGs), Station Batteries (vital and non-vital), Main Control Room Environmental Control (MCREC), Control Room Air Conditioning (AC), and Reactor Recirculation systems. All documents reviewed are listed in the Attachment.

The team reviewed the licensees evaluations and, if applicable, corrective actions on a selected sample of NRC generic communications, such as NRC Information Notices, Part 21 notices, NRC Generic Letters and other related information to verify that issues had been properly assessed for impact on the plant. The inspectors also reviewed the licensee's evaluation of selected industry experience items including event reports and NRC generic communications to assess if the issues applicable to Plant Hatch were appropriately addressed.

The team reviewed all CRs written during the inspection and attended several plant status meetings and CAP review meetings to observe the evaluation of CRs, the assignment of a Significance Level (SL), and the assignment of a responsible department to evaluate and close the CR. Additionally, the team interviewed numerous plant staff members and conducted walkdowns of several areas of the plant to assess if component deficiencies were appropriately identified and entered into the CAP.

(2) Assessment The inspectors determined that the licensee was generally effective at identifying problems and entering them into the CAP. The threshold for identifying and initiating CRs was low. Sampled CRs were complete and accurate with some minor exceptions.

The CAP is used to identify equipment deficiencies and produce MWOs for equipment repair. For the MWOs reviewed that resulted from equipment deficiencies, the team determined that all had been identified and included in the CAP program.

For the audits and self-assessments reviewed, the inspectors verified that the issues raised were entered into the CAP for resolution.

During a system health report review, the team noted that the cooling tower batteries as well as the 120 -240V uninterruptible ac power system batteries had degraded to approximately 50 percent of design capacity for at least one year. While these two batteries are non class 1E and not required by plant Technical Specifications (TS), they are described in the Updated Final Safety Analysis Report (UFSAR), Chapter 8.

According to the UFSAR, the cooling tower batteries provide control power to the cooling tower fan circuit breakers and the uninterruptible ac power system batteries provide power to some non safety related secondary loads. The team determined that the licensee had not performed and documented any reviews such as operator workaround, procedure impact, or 10 CFR 50.59 screening for this extended degraded condition. The inspectors concern was that letting a system degrade to below its design capacity was a defacto design change. Documents reviewed are listed in the

.

Plant walkdowns were performed in the following areas: Unit 1 and Unit 2 Emergency Diesel Generator Rooms (EDG), MCR, Unit 1 HPCI, Unit 1 RCIC rooms and the servcie water intake structure. Deficiencies identified by the team during these walkdowns resulted in the following four CRs.

• CR 2003008955 Valve handle for jacket cooling water isolation valve on 1A EDG broken.

• CR 2003008956 Oil leak on tubing going to turbo charger for 1A EDG.

• CR 2003009011 Pinstripe tape on Unit 1 Control Board falling off.

• CR 2003009423 Instrument Rack isolation valve has broken lockwire in RCIC Room.

None of the above CRs generated as a result of the team walkdown were indicative of a negative trend in problem identification.

b. Prioritization and Evaluation of Issues

(1) Inspection Scope The team reviewed procedure 10AC-MGR-004-0, Corrective Action Program, to determine the licensees requirements for prioritizing and evaluating issues. The corrective action program coordinators (CAPCOs) assign each CR a significance level (SL) from SL1 (highest significance) to SL5 (lowest significance) and assign the CR to a responsible department for processing. The inspectors reviewed the daily CRs, attended various CAPCO meetings, and compared the assignment of SL to each CR.

The team then reviewed selected CRs to ensure that CR significance level classifications, operability determinations, reportability determinations, degraded and non-conforming condition determinations, cause determinations, and selection of corrective actions were consistent with the significance of the problems described. The team also reviewed the licensees follow-up of previously identified NCVs to assess prioritization and completion of corrective actions. Documents reviewed are listed in the

.

(2) Assessment The team determined that the CAPCOs correctly assigned SLs to the CRs sampled by the inspectors. The root cause evaluations for the CRs reviewed were adequate. The licensee was generally effective in prioritizing and processing CRs. Apparent Cause Evaluations reviewed were found to be thorough and well-documented. All of the evaluations were verified to be completed by qualified individuals Several corporate and mid-cycle audit reports were reviewed by the team. The licensee had initiated numerous CRs as a result of the audit findings and corporate observations.

The CRs primarily involved equipment reliability and aging issues. These CRs were designated as SL5 (least significant). However, the licensees Top Thirty issues list had equipment reliability as the highest priority item at Plant Hatch. The top thirty list identifies and highlights plant issues in order of importance, and is used as a management tool to track status of resolution. The lowest priority given to these CRs contrasted with the highest priority assigned to the equipment reliability issues in the top thirty plant issues list. Based on inspector comments, the licensee raised the CRs significance level to SL4.

c. Effectiveness of Corrective Actions

(1) Inspection Scope The inspectors reviewed selected CRs to verify that specified corrective actions were timely and effective in resolving the problems described. This sample was based on risk as well as SL. The CRs reviewed also included those resulting from previous NRC violations as well as licensee audits and self assessments, and covered all safety cornerstones. The team also discussed the CAP with plant staff to determine their impression of the CAPs effectiveness in resolving issues. Licensee trend reports, the Top Thirty plant issues list, action items resulting from CRs, system health reports previously mentioned, and CR backlog were also reviewed. The review was predominantly for the year 2002 and 2003, however, some older CRs were also reviewed for long standing issues. The team also reviewed the temporary modification log to determine the reason and licensee plans relating to the temporary modifications.

Documents reviewed are listed in the Attachment.

(2) Assessment

(i) General Based on a review of numerous completed as well as open CRs, discussions with plant personnel, and review of existing plant problems, the team noted that numerous repetitive equipment related problems were not resolved in a timely manner. This concern was also noted by the licensees own staff during interviews as well as licensee self-assessments and audits. The team noted that the licensee had made progress in corrective action program management from the previous problem identification and resolution inspection conducted in November 2001 (Inspection Report Number 50-321/01-09 and 50-366/01-09). A dedicated CAPCO staff demonstrated ownership in the administration of the corrective action program.

A review of approximately 30 CRs revealed that approximately 70 percent of the repeat events occurred before the corrective actions for the initial SL3 event was corrected. In most of these events, the corrective action could not have been completed due to scheduling conflicts. For the remaining 30 percent, the investigation into the causal factors was complete and a search for common cause was made as part of the root or apparent cause. In most cases the events are well known to the licensee and the planned corrective actions have not been completed for various reasons. The licensee has designated this as an area for improvement.

The temporary modification log was reviewed to determine timeliness in restoring the system/component to original design or plans to convert the temporary modification to a permanent status. Numerous temporary modifications were noted to be beyond the original schedule to be returned to original design status. One temporary modification (1-97-30) on the PSW system was noted to exist since 1997, significantly beyond the original schedule.

The Operations department has developed a Needs and Significant Work Around list which is used to help prioritize scheduling of maintenance and/or system upgrades.

Although this list allows the Operations manager to perform an aggregate review for impact on the plant, the team concluded that it loses its effectiveness if items remain on the list for an extended period of time. Five out of the twelve items have been on the list since 2000.

The team noted that CR 2003003966, involved an issue where PSW Valve 2P41-F063, Reactor Building Outlet Isolation valve, indicated open but was actually closed. This SL3 CR documented the failure of the valve operator to stem spline clamp resulting in the valve indicating open when it was closed. The corrective actions included revising the valve maintenance procedure to add a torque specification and verification of valve torque for the stem spline clamp bolts. The inspectors reviewed the completed action items and determined that the revision to the maintenance procedure did not include torque specifications or the requirement to document the final torque. The licensee initiated CR 2003009338 to correct this problem based on the teams observation.

The team reviewed the system health report for the RHRSW system. The system health report detailed a chronic and recurring problem causing degraded PSW flow and pressure to the RHRSW motor upper thrust bearing and upper guide bearing cooling coils. The degraded PSW flow, which has the potential for impacting operability, was caused by corrosion products and decayed organic matter collecting in the cooling water lines and restricting flow through the oil cooler. The cooling water lines required a periodic manual backflush. This condition was identified by the licensee as an operator workaround. Further, the RHRSW system has been a maintenance rule a(1) system since approximately November 1999, due partly to this problem. Despite these problems, the team noted that the licensee had only implemented corrective actions to partially modify the system. The licensee installed a four way valve which allows flushing the cooling lines during pump operation on four of the eight pumps, one pump in each division for each plant.

The team reviewed the maintenance rule report for the control room AC system. The maintenance rule report identified that the system exceeded the allowable maintenance preventable functional failures. One cause for the repetitive failures of the main control room air conditioners was debris clogging the in-line strainers on the pilot valves for the PSW supply valves, 1P41-F1246, 1247, and 1248. These valves supply PSW to the air conditioner condenser/evaporator. The root cause of the clogging was documented in CR 1999006444 and CR 2001001973. The recommended corrective action to prevent recurrence was determined to be the replacement of valves 1P41-F1246, 1247, and 1248 with a modified valve. Further, the system had been a maintenance rule a(1)system since approximately March 2001. Despite these problems, and the recurrence of maintenance preventable functional failures, the licensee had not implemented the recommended corrective actions to prevent the recurring failure of the main control room heating and ventilation system. The licensee initiated CR 2003009539 to document the teams concerns.

In addition to the above observations, the team identified two findings involving effectiveness of corrective actions at Plant Hatch.

(ii) Findings

1.

Introduction:

A Green NCV involving inadequate corrective actions for a previously identified NCV was identified. This resulted in the failure to perform a TS surveillance requirement within the specified frequency.

Description:

The team reviewed completed corrective actions resulting from previous NCV 50-366/01-05-03, Failure to Prevent Recurrence of Emergency Bus Under-voltage Relay Setpoint Drift. This NCV was identified in September 2001 when the licensee had failed to perform system response time testing for the turbine stop valves (TSV) to the Reactor Protection System (RPS) Channel D relay on Unit 2 as required by TS.

Licensee corrective actions for this NCV included revision of associated surveillance procedures, including, procedure 57SV-MNT-023-2S, Response Time Testing of Channel D Relay Logic in Mode 1, to ensure that all required relays associated with the response time testing surveillance (TS SR 3.3.4.1.5) would be tested.

During this review to assess completion of the licensees corrective actions, the team identified additional examples where TS required surveillances for response time testing were not being performed. Specifically, the team identified that TS 3.3.4.1.5 required surveillance associated with the Turbine Control Valve End of Cycle Recirculation Pump Trip (TCV EOC- RPT) response time testing had not been performed for the period between February 24, 2000, and February 27, 2003. TS 3.3.4.1.5 requires the TCV EOC-RPT system response time test to be conducted on a 24 month staggered test basis frequency. However, the team determined that the licensee failed to identify that the TCV EOC-RPT system response time testing was not being performed.

Consequently, the TS 3.3.4.1.5 required response time testing associated with the TCV to the EOC-RPT logic system was exceeded by approximately 6 months. Additionally, the team identified that procedure 57SV-MNT-021-2S, Response Time Testing of Channel B Relay Logic in Mode 1 was also found to be inadequate to meet the TS testing requirements. Further, the team noted that the current revision of the next scheduled surveillance in 2005 did not contain the steps necessary to correctly test the TCV EOC-RPT relays. The failure to identify additional missed TS surveillances following initial identification in September 2001 illustrates a weakness the in licensees corrective action program as the extent of condition was not adequately assessed.

Analysis:

This finding is related to the mitigating system cornerstone and is more than minor because if left uncorrected, TS required surveillances would not be performed due to procedural inadequacies. Specifically, the failure to determine the extent of condition with regard to procedural deficiencies following initial identification in September 2001.

In this instance, the individual channel response times could have become greater than the maximum values assumed in the safety analysis associated with the MCPR Safety Limit. This missed surveillance requirement was determined to be of very low safety significance (Green) because the subsequent successful performance of the response time test demonstrated the relays were operable at all times.

Enforcement:

10 CFR 50, Appendix B, Criteria XVI, Corrective Actions, requires in part, that measures be established for significant conditions adverse to quality that the cause of the condition is determined and corrective action taken to preclude repetition.

Contrary to this requirement, in September 2001, licensee corrective actions were inadequate in that TS required surveillance procedures involving the TCV EOC-RPT system response time test were not revised to prevent future violations of TS surveillance requirements as the licensee failed to determine extent of condition. This resulted in the TCV EOC-RPT System Response test not being conducted for the B and D channels from February 2000 to February 2003. Since this violation is of very low safety significance and the licensee has entered it into the corrective action program as CR 2003009445, this violation is being treated as an NCV in accordance with Section VI.A.1 of the NRC Enforcement Policy and is identified as NCV 50-321/03-07-01 and 50-366/03-07-01, Inadequate Corrective Actions For A Previous Violation.

2.

Introduction:

A Green NCV was identified for failure to identify that recurring pressure transients during RHRSW pump startup required evaluation.

Description:

The team reviewed the 2nd quarter 2003 system health report for the RHRSW system. The system health report described a performance problem on the RHRSW system involving pressure transients that occur during RHRSW system startup.

When a RHRSW pump was started, the pressure increase resulted in damage to the air release floats and local pressure gages. This pressure transient was magnified if one RHRSW pump was already running. The team noted that since 1999 nine such pressure transients had caused damage to the air release floats resulting in their replacement. Further, upon discussion with the system engineer, the team noted that the pressure gage, which is rated to 600 psig, had been over-ranged on numerous occasions. Upon further inspection, the team determined that the pressure rating of that portion of the pipe was 525 psig. The team determined that the licensee failed to evaluate the affect on portions of the RHRSW system piping exceeding the design pressure rating each time that the design pressure was exceeded.

Analysis:

This finding is related to the mitigating system cornerstone and is more than minor because on multiple occasions the piping design pressure was exceeded, yet the licensee failed to evaluate the implication of the pressure transient on the system. This issue is of very low safety significance (Green) because it did not actually result in the safety related system being inoperable for greater than the time allowed by plant TS.

Enforcement:

10 CFR 50, Appendix B, Criteria XVI, Corrective Actions, requires in part, that measures be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected. Contrary to the above, the licensee failed to identify that pressure transients resulting in the design pressure being exceeded on portions of the RHRSW system required evaluation. Since this violation is of very low safety significance and the licensee has entered it into the corrective action program as CR 2003009527, this violation is being treated as an NCV in accordance with Section VI.A.1 of the NRC Enforcement Policy: NCV 50-321/03-07-023 and 50-366/03-07-02, Failure to Evaluate Pressure Transients on Safety Related System.

d.

Assessment of Safety-Conscious Work Environment

(1) Inspection Scope The team reviewed numerous audits, self assessments, CRs, MWOs, as well as the Employee Concerns Program files to determine if issues affecting safety were being appropriately addressed. Discussions were held with numerous personnel at various levels in the organization to determine if a work environment and a process existed that was conducive to the identification of safety issues.

(2) Assessment The team determined that personnel at the site felt free to raise safety concerns. All personnel stated that they would not hesitate to raise safety concerns to their management or through the CR process. They also understood and believed that they could raise issues without fear of retaliation by management. Concerns resolution files for 2002 and 2003 were sampled and the team determined that safety concerns resulted in the initiation of a CR for resolution. The team concluded that a safety conscious work environment existed at the Hatch Nuclear Plant.

4OA6 Meetings, Including Exit

On August 29, 2003, the team presented the inspection results to G. Frederick and other members of his staff who acknowledged the findings. The inspectors confirmed that proprietary information was not provided or examined during this inspection.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

J. Betsill, Engineering Support Manager

V. Coleman, Safety Audit and Engineering Review Supervisor

D. Davis, Plant Administration Manager

R. Dedrickson, Assistant General Manager - Plant Support

G. Frederick, General Manager - Nuclear Plant

M. Googe, Performance Team Manager

J. Hammonds, Operations Manager

W. Kirkley, Health Physics and Chemistry Manager

J. Lewis, Training and Emergency Preparedness Manager

D. Madison, Assistant General Manager - Plant Operations

R. Reddick, Site Emergency Preparedness Coordinator

R. Varnadore, Outage and Planning Manager

J. Thompson, Nuclear Security Manager

S. Tipps, Nuclear Safety and Compliance Manager

NRC Personnel

L. Plisco, Acting Deputy Regional Administrator (DRA) Region II (RII)

K. Landis, Branch Chief, Division of Reactor Projects (DRP) R II

D. Simpkins, Senior Resident Inspector, RII

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

NONE

Opened and Closed

50-321, 366/03-07-01 NCV Inadequate Corrective Actions from a previous NCV.

50-321, 366/03-07-02 NCV Inadequate Corrective Actions for Recurring Issues.

Closed

NONE

Discussed

NONE