IR 05000321/2011008
| ML113040311 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 10/31/2011 |
| From: | Hopper G Reactor Projects Branch 7 |
| To: | Madison D Southern Nuclear Operating Co |
| References | |
| IR-11-008 | |
| Download: ML113040311 (19) | |
Text
October 31, 2011
SUBJECT:
EDWIN I. HATCH NUCLEAR PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000321/2011008 AND 05000366/2011008
Dear Mr. Madison:
On September 29, 2011, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Edwin I. Hatch Nuclear Plant, Units 1 and 2. The enclosed report documents the inspection findings, which were discussed with you and other members of your staff.
The inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commissions rules and regulations and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of plant equipment and activities, and interviews with personnel.
On the basis of the samples selected for review, there were no findings identified during this inspection. The inspectors concluded that problems were properly identified, evaluated, and resolved within the corrective action program. However, during the inspection, some minor performance deficiencies were identified related to your adherence to corrective action program procedures with respect to prioritization and evaluation of identified problems, the effectiveness of corrective actions, and operating experience.
In accordance with 10 CFR 2.390 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
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/
George T. Hopper, Chief Reactor Projects Branch 7 Division of Reactor Projects
Docket Nos.: 50-321, 50-366 License Nos.: DPR-57 and NPF-5
Enclosure:
Inspection Report 05000321/2011008 and 05000366/2011008 w/Attachment: Supplemental Information
REGION II==
Docket Nos.:
50-321 and 50-366
License Nos.:
Report Nos.:
05000321/2011008 and 05000366/2011008
Licensee:
Southern Nuclear Operating Company, Inc.
Facility:
Edwin I. Hatch Nuclear Plant, Units 1 and 2
Location:
Baxley, GA
Dates:
September 12 - 16, 2011 September 26 - 29, 2011
Inspectors:
B. Collins, Reactor Inspector J. Pelchat, Senior Fuel Facilities Inspector E. Stamm, Project Engineer (Team Leader)
N. Staples, Senior Project Engineer R. Taylor, Senior Project Engineer
Approved by:
G. Hopper, Chief Reactor Projects Branch 7 Division of Reactor Projects
Enclosure
SUMMARY OF FINDINGS
IR 05000321/2011008, 05000366/2011008; September 12 - 29, 2011; Edwin I. Hatch Nuclear
Plant, Units 1 and 2; Biennial Inspection of the Problem Identification and Resolution Program.
The inspection was conducted by two senior project engineers, one senior fuel facility inspector, one project engineer, and a reactor engineer. 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.
Problem Identification and Resolution
The inspectors concluded that, in general, problems were properly identified, evaluated, prioritized, and corrected. The licensee was effective at identifying problems and entering them into the corrective action program (CAP) for resolution, as evidenced by the relatively few number of deficiencies identified by external organizations (including the NRC) that had not been previously identified by the licensee, during the review period. Generally, prioritization and evaluation of issues were adequate, formal root cause evaluations for significant problems 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. However, the inspectors did identify some minor performance deficiencies related to your adherence to corrective action program procedures with respect to prioritization and evaluation of identified problems, the effectiveness of corrective actions, and operating experience.
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. Operating experience usage was found to be generally acceptable and integrated into the licensees processes for performing and managing work, and plant operations.
Based on discussions and interviews conducted with plant employees from various departments, the inspectors determined that personnel at the site felt free to raise safety concerns to management and use the CAP to resolve those concerns.
REPORT DETAILS
OTHER ACTIVITIES
4OA2 Problem Identification and Resolution
a.
Assessment of the Corrective Action Program
- (1) Inspection Scope
The inspectors reviewed the licensees CAP procedures which described the administrative process for initiating and resolving problems primarily through the use of condition reports (CRs). To verify that problems were being properly identified, appropriately characterized, and entered into the CAP, the inspectors reviewed CRs that had been issued between November 2009 and September 2011, including a detailed review of selected CRs associated with the following risk-significant systems: RHR Service Water, Reactor Core Isolation Cooling, 4160V Emergency Busses, and the Emergency Diesel Generators (EDGs). Where possible, the inspectors independently verified that the corrective actions were implemented as intended. The inspectors also reviewed selected common causes and generic concerns associated with root cause evaluations to determine if they had been appropriately addressed. To help ensure that samples were reviewed across all cornerstones of safety identified in the NRCs Reactor Oversight Process, the inspectors selected a representative number of CRs that were identified and assigned to the major plant departments, including operations, maintenance, engineering, health physics, emergency preparedness, fire protection, and security. These CRs were reviewed to assess each departments threshold for identifying and documenting plant problems, thoroughness of evaluations, and adequacy of corrective actions. The inspectors reviewed selected CRs, verified corrective actions were implemented, and attended meetings where CRs were screened for significance to determine whether the licensee was identifying, accurately characterizing, and entering problems into the CAP at an appropriate threshold.
The inspectors conducted plant walkdowns of equipment associated with the selected systems and other plant areas to assess the material condition and to look for any deficiencies that had not been previously entered into the CAP. The inspectors reviewed CRs, 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, in accordance with the inspection procedure, a five-year review was performed for selected systems for age-dependent issues.
Control Room walkdowns were also performed to assess the main control room deficiency list and to ascertain if deficiencies were entered into the CAP. Operator Workarounds and Operator Burden screenings were reviewed, and the inspectors verified compensatory measures for deficient equipment which were being implemented in the field. The inspectors conducted a detailed review of selected CRs to assess the adequacy of the root-cause and apparent-cause evaluations of the problems identified.
The inspectors reviewed these evaluations against the descriptions of the problem described in the CRs and the guidance in licensee procedure NMP-GM-002-006, Root Cause Analysis Instruction, and NMP-GM-002-007, Apparent Cause Determination Instruction. The inspectors assessed if the licensee had adequately determined the causes of identified problems, and had adequately 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.
The inspectors reviewed selected industry operating experience items, including NRC generic communications to verify that they had been appropriately evaluated for applicability and that issues identified through these reviews had been entered into the CAP.
The inspectors 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 attended various plant meetings to observe management oversight functions of the corrective action process. These included CAP coordinator (CAPCo)screening meetings and Management Review Committee meetings.
Documents reviewed are listed in the Attachment.
- (2) Assessment
Identification of Issues
The inspectors determined that the licensee was generally effective in identifying problems and entering them into the CAP and that there was a low threshold for entering issues into the CAP. This conclusion was based on a review of the requirements for initiating CRs as described in licensee procedure NMP-GM-002-001, Corrective Action Program Instructions, managements expectation that employees were encouraged to initiate CRs for any reason, and the relatively few number of deficiencies identified by inspectors 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 inspectors determined that system deficiencies were being identified and placed in the CAP.
Prioritization and Evaluation of Issues
Based on the review of CRs sampled by the inspection team during the onsite period, the inspectors concluded that problems were generally prioritized and evaluated in accordance with the licensees CAP procedures as described in the severity level determination guidance in NMP-GM-002-001. Each CR was evaluated and their associated corrective action reports (CARs) or technical evaluations (TEs) were assigned a severity level at the CAPCo meeting, and adequate consideration was given to system or component operability and associated plant risk.
The inspectors determined that station personnel had conducted root cause and apparent cause analyses in compliance with the licensees CAP procedures and assigned cause determinations were appropriate, considering the significance of the issues being evaluated. A variety of formal causal-analysis techniques were used, depending on the type and complexity of the issue, consistent with NMP-GM-002-006 and NMP-GM-002-007.
The inspectors identified one performance deficiency associated with the licensees prioritization and evaluation of issues. This issue was screened in accordance with Manual Chapter 0612, Issue Screening, and was determined to be of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy.
- The inspectors identified one example of a CAR (191253) which had not been prepared in accordance with licensee procedure NMP-GM-002-001, Step 6.4.7.3, Version 24.0, dated June 8, 2011. Specifically, the basic cause determination was not included in the solutions tab or attached to the CAR. The inspectors confirmed that the basic cause determination had been conducted at the time. The licensee initiated CR 355302 to address the issue.
The inspectors also observed a discrepancy between information contained in the CAP program and the licensees technical position related to EDG fuel oil leakage. Multiple historical CRs and EDG System Health Reports described a long-standing fuel oil leakage issue on the EDGs which had not been corrected and which were documented as a potential fire hazard in the EDG room. After a visual inspection of the condition and a review of additional information, not contained in the historical CRs, the inspectors agreed with the licensees assessment that the small volume of fuel oil leakage did not affect the operability of the diesel and did not represent a significant fire hazard. The licensee initiated CR 351608 and CR 355721 to address the issue.
Effectiveness of Corrective Actions
Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the inspectors determined that overall, corrective actions were timely, commensurate with the safety significance of the issues, and effective, in that conditions adverse to quality were corrected and non-recurring, notwithstanding the EDG issue discussed above. For significant conditions adverse to quality, the corrective actions directly addressed the cause and effectively prevented recurrence in that a review of performance indicators, CRs, and effectiveness reviews demonstrated that the significant conditions adverse to quality had not recurred.
Effectiveness reviews for corrective actions to prevent recurrence were sufficient to ensure corrective actions were properly implemented and were effective. The inspectors identified two performance deficiencies associated with the licensees effectiveness of corrective actions. These issues were screened in accordance with Manual Chapter 0612, Issue Screening, and were determined to be of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy.
- The inspectors identified one instance (CR 2010109818) where an effectiveness review was not conducted for an NRC non-cited violation (NCV 2010003-03, Failure to follow procedure while in shutdown cooling to record corrected reactor water level)as required by NMP-GM-002-007, Step 6.3, Version 4.0, dated June 1, 2011. The licensee initiated CR 353966 to address the issue.
- The inspectors identified appropriate management review of multiple Priority 1 & 2 TEs had not been completed prior to closing the TEs as required by NMP-GM-002-001, Step 6.16.2.1, Version 24.0, dated June 8, 2011. The licensee initiated CR 355315 to address the issue.
- (3) Findings
No findings were identified.
b.
Assessment of the Use of Operating Experience (OE)
- (1) Inspection Scope
The inspectors examined licensee programs for reviewing industry operating experience, reviewed licensee procedure NMP-GM-008, Operating Experience Program, and reviewed the licensees operating experience database to assess the effectiveness of how external and internal operating experience data was handled at the plant. In addition, the inspectors 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 November 2009, to verify whether the licensee had appropriately evaluated each notification for applicability to the Hatch plant, and whether issues identified through these reviews were entered into the CAP. Procedure NMP-GM-008 was reviewed to verify that the requirements delineated in the program were being implemented at the station. Documents reviewed are listed in the Attachment.
- (2) Assessment
Based on a review of documentation related to the review of operating experience issues, the inspectors determined that the licensee was generally effective in screening operating experience for applicability to the plant. Industry OE was evaluated by plant OE Coordinators and relevant information was then forwarded to the applicable department for further action or informational purposes. OE issues requiring action were entered into the CAP for tracking and closure. In addition, operating experience was included in all root cause evaluations in accordance with licensee procedure NMP-GM-002-006.
The inspectors identified one performance deficiency associated with the licensees use of operating experience. This issue was screened in accordance with Manual Chapter 0612, Issue Screening, and was determined to be of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy.
- The inspectors identified multiple examples of NRC Information Notices issued since November 2009 in which the licensee had not documented their evaluation in a CR as required by procedure NMP-GM-008, Attachment 1, Version 12.0, dated March 23, 2011. The licensee provided information which showed that those NRC Information Notices were evaluated by the OE Screening Board and determined to be not-applicable to Plant Hatch. The licensee initiated CR 355300 to address the issue.
- (3) Findings
No findings were identified.
c.
Assessment of Self-Assessments and Audits
- (1) Inspection Scope
The inspectors 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 NMP-GM-003-001, Self Assessment Instructions. The inspectors also conducted a review of the licensees 2010 Safety Culture self-assessment associated with the NRCs IP 95002 inspection performed in August 2010.
- (2) Assessment
The inspectors 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 inspectors verified that CRs were created to document all areas for improvement and deficiencies 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. Site trend reports were thorough and a low threshold was established for evaluation of potential trends, as evidenced by the CRs reviewed that were initiated as a result of adverse trends.
- (3) Findings
No findings were identified.
d.
Assessment of Safety-Conscious Work Environment
- (1) Inspection Scope
The inspectors randomly interviewed 16 on-site workers regarding their knowledge of the corrective action program at Hatch and their willingness to write CRs or raise safety concerns. During technical discussions with members of the plant staff, the inspectors conducted interviews to develop a general perspective of the safety-conscious work environment at the site. The interviews were also conducted to determine if any conditions existed that would cause employees to be reluctant to raise safety concerns.
The inspectors reviewed the licensees Quality Concerns Program (QCP) and interviewed the Concerns Coordinator. Additionally, the inspectors reviewed a sample of QCP issues to verify that concerns were being properly reviewed and identified deficiencies were being resolved and entered into the CAP when appropriate.
- (2) Assessment
Based on the interviews conducted and the CRs reviewed, the inspectors 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 QCP. These methods were readily accessible to all employees.
Based on discussions conducted with a sample of plant employees from various departments, the inspectors determined that employees felt free to raise issues, and that management encouraged employees to place issues into the CAP for resolution. The inspectors did not identify any reluctance on the part of the licensee staff to report safety concerns.
- (3) Findings
No findings were identified.
4OA6 Meetings, Including Exit
On September 29, 2011, the inspectors presented the inspection results to Mr. Dennis Madison 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
- T. Beckworth, Concerns Coordinator
- B. Bowers, Engineer I - Systems
- C. Clark, Engineer II
- F. Goreley, Shift Manager
- B. Hulett, Site Design Manager
- D. Madison, Vice President
- L. Mikulecky, Corrective Action Program Supervisor
- C. Morrison, Maintenance I&C Supervisor
- R. Outler, Cause Analyst
- A. Owens, Senior Engineer - Systems
- K. Pownall, Senior Engineer - Programs
- C. Sexton, RHR/CS System Engineer
- S. Tipps, Principal Licensing Engineer
- K. Underwood, Process Improvement Supervisor
- A. Vora, Senior Engineer - Maintenance Engineering
NRC personnel
- E. Morris, Senior Resident Inspector
- D. Hardage, Resident Inspector
- G. Hopper, Chief, Branch 7, Division of Reactor Projects
LIST OF REPORT ITEMS
Opened and Closed
None
Closed
None
Discussed
None