IR 05000321/2013004

IR 05000321-13-004, 05000366-13-004, on 07/01/2013-09/30/2013, Edwin I. Hatch Nuclear Plant, Units 1 and 2, Follow-up of Events and Notices of Enforcement Discretion

ML13304B429
Person / Time
Site:	Hatch
Issue date:	10/31/2013
From:	Frank Ehrhardt NRC/RGN-II/DRP/RPB2
To:	Madison D Southern Nuclear Operating Co
References
IR-13-004
Download: ML13304B429 (27)

Text

UNITED STATES ctober 31, 2013

SUBJECT:

EDWIN I. HATCH NUCLEAR PLANT - NRC INTEGRATED INSPECTION REPORT 05000321/2013004 AND 05000366/2013004

Dear Mr. Madison:

On September 30, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your E. I. Hatch Units 1 and 2. On October 31, 2013, the NRC inspectors discussed the results of this inspection with Mr. David Vineyard and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.

NRC inspectors documented one finding of very low safety significance (Green) in this report.

This finding involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violation 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 II; the Director, Office of Enforcement, U.S.

Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Hatch.

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 II; and the NRC Resident Inspector at Hatch. In accordance with Title 10 Code of Federal Regulations 2.390, Public Inspections, Exemptions, Request 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 NRCs Public Document Room or from the Publicly Available Records (PARS) component of NRC's Agencywide Document Access and Management 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,

/Jannette Worosilo RA for/

Frank Ehrhardt, Branch Chief Reactor Projects Branch 2 Division of Reactor Projects Docket Nos.: 50-321, 50-366 License Nos.: DPR-57 and NPF-5

Enclosures:

Inspection Report 05000321/2013004, 05000366/2013004 w/Attachment: Supplemental Information

REGION II==

Docket Nos.: 50-321, 50-366,72-036 License Nos.: DPR-57 and NPF-5 Report Nos.: 05000321/2013004 and 05000366/2013004 Licensee: Southern Nuclear Operating Company, Inc.

Facility: Edwin I. Hatch Nuclear Plant Location: Baxley, Georgia 31513 Dates: July 1 - September 30, 2013 Inspectors: E. Morris, Senior Resident Inspector D. Hardage, Resident Inspector Approved by: Frank Ehrhardt, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000321/2013004, 05000366/2013004; 07/01/2013-09/30/2013; Edwin I. Hatch Nuclear

Plant, Units 1 and 2, Follow-up of Events and Notices of Enforcement Discretion The report covered a three-month period of inspection by the Hatch resident inspectors. There was one NRC identified finding identified and documented in this report. The significance of inspection findings are indicated by their color (i.e. greater than Green, or Green, White, Yellow,

Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP) dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310,

Components Within The Cross-Cutting Areas dated October 28, 2011. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated July 9, 2013. The NRCs program for overseeing the safe operations of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process revision 4.

Cornerstone: Mitigating Systems

Green.

The NRC identified a non-cited violation of Unit 1 License Condition 2.C.(3),

Fire Protection, and Unit 2 License Condition 2.C.(3)(a), Fire Protection, which occurred on September 3, 2013, when the licensee failed to establish fire watches and compensatory measures required by Hatchs Fire Hazards Analysis, Appendix B, after a fire header pipe rupture rendered sprinklers and hose stations inoperable. The licensee returned the fire header to operable status September 4, 2013, to restore compliance.

This violation was entered into the licensees corrective action program as condition report (CR) 700402.

Failure to establish fire watches and compensatory actions as required by Hatchs Fire Hazards Analysis, Appendix B, when sprinkler systems and hose stations became inoperable on September 3, 2013, was a performance deficiency. This performance deficiency was more-than-minor because the performance deficiency is associated with the mitigating systems cornerstone protection against external factors (fire) attribute and adversely affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to establish fire watches and alternate compensatory measures resulted in the loss of fixed fire suppression capabilities within each fire area on the plant site for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The inspectors screened this finding using IMC 0609, Appendix F, Attachment 1, dated February 28, 2005. Using Part 1,

Fire Protection SDP Phase 1 Worksheet, this finding screened as requiring a Phase 2 analysis, because the duration factor was determined to be 0.01 (< 3 Days), the summation of estimated fire frequency for the fire areas was calculated to be 3.78E-01, and the delta core damage frequency (CDF) calculation of 3.78E-03 was greater than a high degradation value of 1E-6 in Table A1.1. The inspectors submitted this finding to the Region II senior reactor analyst for further processing. A detailed SDP risk evaluation was performed by a regional senior reactor analyst. A bounding SDP risk evaluation was completed using a hand calculation and guidance from NRC IMC 0609 Appendix F. The significant analysis assumptions included a five hour exposure time, plant wide ignition frequency of approximately 3E-1/year, severity factor of 1E-1 (only large fires likely to require use of fixed suppression), probability of non-suppression (PNS) of 5E-1 (10 minute fire growth scenario for base case and PNS of 1.0 no suppression due to the PD for the non-conforming case), and a conditional core damage probability of 1E-1 (assumed that large unsuppressed fire would lead to alternate shutdown scenario). The low exposure period mitigated the risk of the performance deficiency. The result of the bounding SDP evaluation was a core damage frequency increase (CDF) of < 1E-6/year, a GREEN finding of very low safety significance. The inspectors determined this performance deficiency had a cross-cutting aspect in the human performance area decision-making attribute because the licensee did not use conservative assumptions in decision making when applying actions for inoperable fire hose stations, yard fire hydrants, and sprinklers. H.1(b) (Section 4OA3.1)

REPORT DETAILS

Summary of Plant Status

Unit 1 began the inspection period at or near 100 percent rated thermal power. On July 3, 2013, operators performed a planned power reduction to 65 percent rated thermal power for fuel bundle flux suppression testing. The unit was returned to rated thermal power on July 9, 2013, and remained at or near 100 percent rated thermal power for the remainder of the inspection period Unit 2 began the inspection period at or near 100 percent rated thermal power. On September 15, 2013, operators shutdown the unit to repair the D outboard main steam line isolation valve. The unit was restarted on September 19, 2013, and returned to 100 percent rated thermal power on September 24, 2013. The unit operated at or near 100 percent rated thermal power for the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

a. Inspection Scope

Readiness to Cope with External Flooding The inspectors evaluated the implementation of flood protection preparation procedures and compensatory measures implemented by the licensee during impending conditions of flooding or heavy rains. The inspectors reviewed the updated final safety analysis report and related flood analysis documents to identify those areas containing safety-related equipment that could be affected by external flooding and their design flood levels. The inspectors walked down flood protection barriers, reviewed procedures for coping with external flooding, and reviewed corrective actions for past flooding events.

The inspectors verified that the procedures for coping with flooding could reasonably be used to achieve the desired results. For those areas where operator actions are credited, the inspectors assessed whether the flooding event could limit or preclude the required actions. Documents reviewed are listed in the Attachment. The inspectors conducted walk-downs of the following plant areas containing risk significant structures, systems, and components which are below flood levels or otherwise susceptible to flooding:

• Unit 1 Intake Area

• Unit 2 Intake Area

b. Findings

No findings were identified.

1R04 Equipment Alignment

a. Inspection Scope

Partial Walkdowns The inspectors verified that critical portions of selected risk-significant systems were correctly aligned. The inspectors selected systems for assessment because they were a redundant or backup system/train, were important for mitigating risk for the current plant conditions, had been recently realigned, or were a single-train system. The inspectors determined the correct system lineup by reviewing plant procedures and drawings. The inspectors verified that critical portions of the selected systems were correctly aligned by performing partial walkdowns. Documents reviewed are listed in the Attachment. The inspectors selected the following three systems/trains to inspect:

• Unit 2 A emergency diesel generator while Unit 2 C emergency diesel generator was out of service for maintenance, July 24

• Unit 2 A train of residual heat removal service water system while B train was out of service for maintenance, August 12

• Unit 1 Division II train of plant service water system while the standby plant service water train was out of service for maintenance, August 14 Complete Walkdown The inspectors verified the alignment of the Unit 2 standby liquid control system. The inspectors selected this system for assessment because it is a risk-significant mitigating system. The inspectors determined the correct system lineup by reviewing plant procedures, drawings, the updated final safety analysis report, and other documents. In order to identify any deficiencies that could affect the ability of the system to perform its function(s), the inspectors reviewed records related to outstanding design issues and maintenance work requests. The inspectors verified that the selected system was correctly aligned by performing a complete walk down of accessible components.

To verify the licensee was identifying and resolving equipment alignment discrepancies, the inspectors reviewed corrective action documents, including condition reports and outstanding work orders, as well as periodic reports containing information on the status of risk-significant systems, including maintenance rule reports and system health reports. Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

1R05 Fire Protection

a. Inspection Scope

Quarterly Inspection The inspectors evaluated the adequacy of selected fire plans by comparing the fire plans to the defined hazards and defense-in-depth features specified in the fire protection program. In evaluating the fire plans, the inspectors assessed the following items:

1) control of transient combustibles and ignition sources; 2) fire detection systems; 3) water-based fire suppression systems; 4) gaseous fire suppression systems; 5) manual firefighting equipment and capability; 6) passive fire protection features; 7) compensatory measures and fire watches; and 8) issues related to fire protection contained in the licensees corrective action program. The inspectors toured the following five fire areas to assess material condition and operational status of fire protection equipment. Documents reviewed are listed in the Attachment.

• Unit 2 southeast residual heat removal and core spray room reactor building below 130, fire zone 2205B

• Unit 2 north and south control rod drive area reactor building elevation 130, fire zones 2203F and 2205F

• Unit 2, adjustable speed drive units reactor building elevation 158, fire zones 2210 and 2211

• Unit 2, working floor north reactor building 158, fire zone 2203K

• Unit 2, chiller room reactor building 164, fire zone 2205N Annual Inspection The inspectors evaluated the licensees fire brigade performance during a drill and assessed the brigades capability to meet fire hazards analysis requirements. The inspectors observed the following aspects of fire brigade performance: 1) capability of fire brigade members; 2) leadership ability of the brigade leader; 3) use of turnout gear and fire-fighting equipment; and 4) team effectiveness; and 5) compliance with site procedures. The inspectors also assessed the ability of control room operators to combat potential fires, including identifying the location of the fire, dispatching the fire brigade, and sounding alarms. The inspectors evaluated the licensees ability to declare the appropriate emergency action level and make required notifications in accordance with NUREG 0654 and 10 CFR 50. Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

.1 Resident Inspector Quarterly Review of Licensed Operator Requalification

The inspectors observed an evaluated simulator scenario administered to an operating crew as part of the annual requalification operating test required by 10 CFR 55.59. The inspectors assessed licensed operator performance, the ability of the licensee to administer the scenario and evaluate the operators, the quality of any post-scenario critique, any follow-up actions taken by the facility licensee, and the performance of the simulator. Documents reviewed are listed in the Attachment.

.2 Resident Inspector Quarterly Review of Licensed Operator Performance

The inspectors observed licensed operator performance in the main control room during Unit 1 flux suppression testing on July 3. Inspectors observed licensed operator performance to assess the following:

• Use of plant procedures

• Control board manipulations

• Communications between crew members

• Use and interpretation of instruments, indications, and alarms

• Use of human error prevention techniques

• Documentation of activities

• Management and supervision Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors assessed the licensees treatment of the two issues listed below in order to verify the licensee appropriately addressed equipment problems within the scope of the Maintenance Rule (10 CFR 50.65). The inspectors reviewed procedures and records in order to evaluate the licensees identification, assessment, and characterization of the problems as well as their corrective actions for returning the equipment to a satisfactory condition. Documents reviewed are listed in the Attachment.

The inspectors also interviewed system engineers and the maintenance rule coordinator to assess the accuracy of performance deficiencies and extent of condition.

• Unit 1 and 2, battery system, R42

• Unit 2, 2R20 1E alternating current electrical supply 600 volt alternating current bus 2C normal supply breaker closed in after tripping with no operator action

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed the five maintenance activities listed below to verify the licensee assessed and managed plant risk as required by 10 CFR 50.65(a)(4) and licensee procedures. The inspectors assessed the adequacy of the licensees risk assessments and implementation of risk management actions. The inspectors also verified that the licensee was identifying and resolving problems with assessing and managing maintenance-related risk using the corrective action program. Additionally, for maintenance resulting from unforeseen situations, the inspectors assessed the effectiveness of the licensees planning and control of emergent work activities.

Documents reviewed are listed in the Attachment.

• Week of July 1 - July 5, including Unit 1 planned maintenance on the A control rod drive pump, and Unit 2 planned maintenance on the reactor high water level instrumentation and scram discharge volume level instrumentation

• Week of July 20 - July 26, including Unit 1 division 2 plant service water pipe replacement activities, planned maintenance on the reactor water cleanup system, repair of Intake structure supports and Unit 2 planned maintenance on 2C emergency diesel generator

• Week of August 5 - August 9, including planned plant service water pipe replacement excavations, planned replacement of the intake dampers, unplanned leak in external building instrument air piping, and planned maintenance for the electric fire pump

• Week of August 12 - August 16, including emergent replacement of Unit 2 B loop residual heat removal service water system relief valve, planned maintenance on the standby service water pump, and planned replacement of the intake dampers

• Week of August 25 - August 30, including planned maintenance on the Unit 1 A residual heat removal service water loop, standby service water pump, and Unit 2 A emergency diesel generator fans

b. Findings

No findings were identified.

1R15 Operability Evaluations and Functionality Assessments

a. Inspection Scope

The inspectors selected the six operability determinations or functionality evaluations listed below for review based on the risk-significance of the associated components and systems. The inspectors reviewed the technical adequacy of the determinations to ensure that technical specification operability was properly justified and the components or systems remained capable of performing their design functions. To verify whether components or systems were operable, the inspectors compared the operability and design criteria in the appropriate sections of the technical specification and updated final safety analysis report to the licensees evaluations. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. Additionally, the inspectors reviewed a sample of corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with operability evaluations.

Documents reviewed are listed in the Attachment.

• Unit 2 turbine and reactor buildings fire water suppression system flow test unable to establish minimum flow, CR 668665

• C main control room air conditioner tripped approximately one minute after start, CR 663771

• Thru wall in Unit 1 service water piping to A residual heat removal, CR 679704

• Foreign material (argon) added to dry canister (MPC) SN 424 , CR 676775

• Service water flow requirements through 1B emergency diesel generator, CR 694034

• Unit 1 turbine building fire main header isolated, CR 697451

b. Findings

No findings were identified.

1R18 Plant Modifications

a. Inspection Scope

The inspectors verified that the plant modification listed below did not affect the safety functions of important safety systems. The inspectors confirmed the modification did not degrade the design bases, licensing bases and performance capability of risk significant structures, systems and components. Additionally, the inspectors evaluated whether system operability and availability, configuration control, post-installation test activities, and changes to documents, such as drawings, procedures, and operator training materials, complied with licensee standards and NRC requirements. In addition, the inspectors reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with modifications.

Documents reviewed are listed in the Attachment.

Modification:

• SNC497179, Install pipe cap on suction of Unit 1 B reactor water cleanup pump piping

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors either observed post-maintenance testing or reviewed the test results for the six maintenance activities listed below to verify the work performed was completed correctly and the test activities were adequate to verify system operability and functional capability. The inspectors evaluated these activities for the following: acceptance criteria were clear and demonstrated operational readiness; effects of testing on the plant were adequately addressed; test instrumentation was appropriate; tests were performed in accordance with approved procedures; equipment was returned to its operational status following testing; and test documentation was properly evaluated. Additionally, the inspectors reviewed a sample of corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with post-maintenance testing.

Documents reviewed are listed in the Attachment.

• Work order (WO) SNC352188, Repair oil leaks on 2C emergency diesel generator, July 25

• WO SNC308971, Repair relief valve 1E21-F024A, July 30

• WO SNC339125, Perform preventive maintenance on frame 1 of 1R22-S005 for the 1A core spray pump, August 1

• WO SNC513135, Replace failed residual heat removal service water relief valve, 1E11-F3079B, August 12

• WO SNC518239, Replace reactor core isolation cooling pump trip throttle valve electrical link, BB-86, September 3

• WO SNC518416, Replace fire header piping, September 11

b. Findings

No findings were identified.

1R20 Refueling and Other Outage Activities

a. Inspection Scope

The inspectors evaluated the outage activities listed below for the Unit 2 maintenance outage from September 15, 2013 through September 19, 2013. The inspectors verified that the licensee: 1) considered risk in developing the outage schedule; 2) controlled plant configuration in accordance with administrative risk reduction methodologies; 3)developed work schedules to manage fatigue; 4) developed mitigation strategies for loss of key safety functions; and 5) adhered to operating license and technical specification requirements. Additionally, inspectors verified that safety-related and risk significant structures, systems, and components not accessible during power operations were maintained in an operable condition.

• Outage planning

• Shutdown, cooldown, heatup, and startup

• Reactor coolant system instrumentation and electrical power configuration

• Reactivity and inventory control

• Decay heat removal cooling system operation

• Containment closure Additionally, the inspectors reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with outage activities. Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors reviewed the three surveillance tests listed below and either observed the test or reviewed test results to verify testing adequately demonstrated equipment operability and met technical specification and licensee procedural requirements. The inspectors evaluated the test activities to assess for preconditioning of equipment, procedure adherence, and equipment alignment following completion of the surveillance.

Additionally, the inspectors reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with surveillance testing. Documents reviewed are listed in the Attachment.

Routine Surveillance Tests

• 34SV-C41-002-2, Standby Liquid Control Pump Operability Test Reactor Coolant System Leak Detection

• 34SV-SUV-019-1, Surveillance Checks In-Service Tests

• 34SV-E41-002-1, High Pressure Coolant Injection Pump Operability

b. Findings

No findings were identified.

1EP6 Drill Evaluation

a. Inspection Scope

The inspectors observed the emergency preparedness drill conducted on July 10, 2013.

The inspectors observed licensee activities in the simulator and technical support center to evaluate implementation of the emergency plan, including event classification, notification, and protective action recommendations. The inspectors evaluated the licensees performance against inspection criteria established in the licensees procedures. Additionally, the inspectors attended the post-exercise critique to assess the licensees effectiveness in identifying emergency preparedness weaknesses and verified the identified weaknesses were entered in the corrective action program.

Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

4OA1 Performance Indicator Verification

a. Inspection Scope

The inspectors reviewed a sample of the performance indicator data, submitted by the licensee, for the Unit 1 and Unit 2 performance indicators listed below. To verify the accuracy and completeness of the data reported for the station, the inspectors reviewed plant records compiled between August 2012 and July 2013. The inspections verified that the performance indicator data complied with guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, and licensee procedures.

The inspectors also confirmed the performance indicators were calculated correctly. In addition, the inspectors reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with performance indicator data. Documents reviewed are listed in the Attachment.

Cornerstone: Mitigating Systems

• Residual Heat Removal System

• High Pressure Injection System

• Emergency AC Power System

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review

The inspectors performed a daily screening of items entered into the licensees corrective action program in order to identify repetitive equipment failures or specific human performance issues for follow-up. The inspectors reviewed daily condition reports, attended screening meetings, or accessed the licensees computerized corrective action database.

.2 Annual Follow-up of Selected Issues

a. Inspection Scope

The inspectors selected condition report 485558, Control Room Air Conditioner Trip, for detailed review. The inspectors evaluated the following attributes of the licensees actions:

• complete and accurate identification of the problem in a timely manner

• evaluation and disposition of operability/reportability issues

• consideration of extent of condition, generic implications, common cause, and previous occurrences

• classification and prioritization of the problem

• identification of root and contributing causes of the problem

• identification of any additional condition reports

• completion of corrective actions in a timely manner Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

.3 Operator Work-Around Annual Review

a. Inspection Scope

The inspectors performed a detailed review of the licensees operator work-around, operator burden, and control room deficiency lists for the station in effect on August 30, 2013, to verify that the licensee identified operator workarounds at an appropriate threshold and entered them in the corrective action program. The inspectors verified that the licensee identified the full extent of issues, performed appropriate evaluations, and planned appropriate corrective actions. The inspectors also reviewed compensatory actions and their cumulative effects on plant operation. Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

4OA3 Follow-up of Events and Notices of Enforcement Discretion

.1 Fire Main Rupture

a. Inspection Scope

The inspectors responded to the control room on September 3, 2013, following an underground fire main pipe rupture in the yard outside the fire pump building. The inspectors reviewed site procedures and Hatchs Fire Hazards

Analysis.

The inspectors also reviewed operating logs, and attended event response meetings.

b. Findings

Introduction:

The NRC identified a Green non-cited violation of Unit 1 License Condition 2.C.(3), Fire Protection, and Unit 2 License Condition 2.C.(3)(a), Fire Protection, when on September 3, 2013, the licensee failed to establish fire watches and compensatory measures required by Hatchs Fire Hazards Analysis, Appendix B, after a fire header pipe rupture rendered sprinklers and hose stations inoperable.

Description:

On September 3, 2013, at 1445 a rupture of the Hatch fire main header occurred. This resulted in a complete loss of all fire protection spray and/or sprinklers and hose stations in every fire area at the plant site. Hatchs Fire Hazards Analysis Appendix B, Section 1.4.1 requires that the spray and/or sprinkler systems shall be operable, and with one or more of the required spray and/or sprinkler system inoperable that a continuous fire watch with backup fire suppression equipment be established within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at each affected Category I fire area. Fire Hazards Analysis Appendix B, Section 1.6.1 requires that hose stations shall be operable, and with all fire hose stations inoperable that alternate compensatory measures must be established per NMP-ES-035-005. Fire Hazards Analysis, Appendix B, section 1.7.1 requires that each yard fire hydrant shall be operable, and with one or more yard hydrants inoperable that alternate compensatory measures be established per NMP-ES-035-005. Fire Hazards Analysis, Appendix B, Section 1.10.1 requires that the waste separation and temporary storage facility sprinkler system shall be operable, and with the sprinkler system inoperable that a continuous fire watch with backup fire suppression equipment shall be established within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

When the rupture in the fire main header occurred the licensee entered Fire Hazards Analysis, Appendix B, Section 1.3.1 fire action, and the decision to implement the other relevant Appendix B actions was not recognized as required at that time. After questioning by the site NRC resident inspectors, Operations determined that Section 1.4.1, 1.6.1, 1.7.1, and 1.10.1 actions were required and initiated compliance with those requirements at 1800. Continuous fire watches with backup fire suppression equipment were established in all Category I fire areas and the waste separation and temporary storage facility at 2105. The rupture was isolated and the fire header was restored to operable on September 4, 2013, at 1238. The NMP-ES-035-005 evaluations were not complete until September 4, 2013, at 2330. Therefore, during the 21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> the hose stations and yard fire hydrants were inoperable the required actions of section 1.4.1, 1.6.1, 1.7.1, and 1.10.1 for inoperable fire hose stations and yard fire hydrants were not performed.

Analysis:

Failure to establish fire watches and compensatory actions as required by Hatchs Fire Hazards Analysis, Appendix B, when sprinkler systems and hose stations became inoperable on September 3, 2013, was a performance deficiency. This performance deficiency was more-than-minor because the performance deficiency is associated with the mitigating systems cornerstone protection against external factors (fire) attribute and adversely affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to establish fire watches and alternate compensatory measures resulted in the total loss of fixed fire suppression capabilities within each fire area on the plant site for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The inspectors screened this finding using IMC 0609, Appendix F, Attachment 1, dated February 28, 2005. Using Part 1, Fire Protection SDP Phase 1 Worksheet, this finding screened as requiring a Phase 2 analysis, because the duration factor was determined to be 0.01 (<

3 Days), the summation of estimated fire frequency for the fire areas was calculated to be 3.78E-01, and the delta CDF calculation of 3.78E-03 was greater than a high degradation value of 1E-6 in Table A1.1. The inspectors submitted this finding to the Region II senior reactor analyst for further processing. A detailed SDP risk evaluation was performed by a regional senior reactor analyst. A bounding SDP risk evaluation was completed using a hand calculation and guidance from NRC IMC 0609 Appendix F.

The significant analysis assumptions included a five hour exposure time, plant wide ignition frequency of approximately 3E-1/year, severity factor of 1E-1 (only large fires likely to require use of fixed suppression), probability of non-suppression (PNS) of 5E-1 (10 minute fire growth scenario for base case and PNS of 1.0 no suppression due to the PD for the non-conforming case), and a conditional core damage probability of 1E-1 (assumed that large unsuppressed fire would lead to alternate shutdown scenario). The low exposure period mitigated the risk of the PD. The result of the bounding SDP evaluation was a core damage frequency increase (CDF) of < 1E-6/year, a GREEN finding of very low safety significance.

The inspectors determined this performance deficiency had a cross-cutting aspect in the human performance area decision-making attribute because the licensee did not use conservative assumptions in decision making when applying actions for inoperable fire hose stations, yard fire hydrants, and sprinklers. H.1(b)

Enforcement:

Hatchs Unit 1 License Condition 2.C.(3), Fire Protection and Unit 2 License Condition 2.C.(3)(a), Fire Protection, require in part that the licensee shall implement and maintain in effect all provisions of the fire protection program, which is referenced in the Updated Final Safety Analysis Report for the facility, as contained in the updated Fire Hazards Analysis and Fire Protection Program. Hatchs Fire Hazards Analysis Appendix B, Section 1.4.1 requires that the spray and/or sprinkler systems shall be operable, and with one or more of the required spray and/or sprinkler system inoperable that a continuous fire watch with backup fire suppression equipment be established within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at each affected Category I fire area. Fire Hazards Analysis Appendix B, Section 1.6.1 requires that hose stations shall be operable, and with all fire hose stations inoperable that alternate compensatory measures must be established per NMP-ES-035-005. Fire Hazards Analysis, Appendix B, Section 1.7.1 requires that each yard fire hydrant shall be operable, and with one or more yard hydrants inoperable that alternate compensatory measures be established per NMP-ES-035-005. Fire Hazards Analysis, Appendix B, Section 1.10.1 requires that the waste separation and temporary storage facility sprinkler system shall be operable, and with the sprinkler system inoperable that a continuous fire watch with backup fire suppression equipment shall be established within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

Contrary to the above on September 3, 2013, when a fire header rupture resulted in the inoperability of all fire protection spray and/or sprinklers and hose stations, the licensee failed to implement the provision in the fire protection program contained in the Fire Hazards Analysis, Appendix B, which required the licensee to establish continuous fire watches with backup fire suppression within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for each affected Category I fire area, establish continuous fire watches with backup fire suppression within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for the waste separation and temporary storage facility, and to establish alternate compensatory measures per NMP-ES-035-005. The licensee established continuous fire watches in each Category I fire area and waste separation and temporary storage facility by 2105 on September 3, 2013. The licensee restored the fire header to operable status September 4, 2013, to restore compliance. This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy. The violation was entered into the licensees corrective action program as CR 700402. (NCV 05000321, 366/2013004-01, Failure to Take Required Actions for Inoperable Equipment in Accordance with Hatchs Fire Hazards Analysis, Appendix B)

4OA5 Other Activities

.1 Quarterly Resident Inspector Observations of Security Personnel and Activities

a. Inspection Scope

During the inspection period, the inspectors conducted observations of security force personnel and activities to ensure that the activities were consistent with licensee security procedures and regulatory requirements relating to nuclear plant security.

These observations took place during both normal and off-normal plant working hours.

These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors normal plant status review and inspection activities.

b. Findings

No findings were identified.

.2 Operation of an Independent Spent Fuel Storage Installation (IP 60855.1)

a. Inspection Scope

The inspectors performed a walkdown of the independent spent fuel storage installation on site (reference docket 72-036) and monitored the activities associated with the dry fuel storage campaigns which were completed July 12, August 2, and August 23. The inspectors reviewed changes made to the spent fuel storage installation programs and procedures including associated 10 CFR 72.48 screens and evaluations to verify that changes made were consistent with the license or Certificate of Compliance. The inspectors reviewed records to verify that the licensee has recorded and maintained the location of each fuel assembly placed in the spent fuel storage installation. The inspectors also reviewed surveillance records to verify that daily surveillance requirements were performed as required by technical specifications. Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

.3 Institute of Nuclear Power Operations Report Review

In accordance with Executive Director of Operations Procedure 0220, the Hatch resident inspectors reviewed the most recent Institute of Nuclear Power Operations training accreditation report to determine if the report identified safety or training issues not previously identified by NRC evaluations.

4OA6 Meetings, Including Exit

On October 31, 2013, the resident inspectors presented the inspection results to Mr.

David Vineyard and other members of the licensees staff. The inspectors confirmed that proprietary information was not provided or examined during the inspection.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

B. Anderson, Health Physics Manager

G. Brinson, Maintenance Director

L. Carter, Residual Heat Removal System Engineer

C. Clark, High Pressure Coolant Injection System Engineer

V. Coleman, Chemistry Manager

C. Lane, Engineering Director

K. Long, Operations Director

M. Madigan, Work Management Director

D. Madison, Hatch Vice President

S. Tipps, Principal Licensing Engineer

M. Torrance, Nuclear Oversight Manager

D. Vineyard, Plant Manager

B. Waltman, Emergency Diesel Generator System Engineer

A. Wheeler, Site Projects Manager

NRC personnel

G. MacDonald, Senior Reactor Analyst, RII

LIST OF ITEMS

OPENED AND CLOSED Opened &

Closed

05000321, 366/2013004-01 NCV Failure to Take Required Actions for Inoperable Equipment in Accordance with Hatchs Fire Hazards Analysis, Appendix B (Section 4OA3.1)