IR 05000321/2020001
| ML20132A012 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 05/11/2020 |
| From: | Alan Blamey NRC/RGN-II/DRP/RPB2 |
| To: | Gayheart C Southern Nuclear Operating Co |
| References | |
| IR 2020001 | |
| Download: ML20132A012 (24) | |
Text
May 11, 2020
SUBJECT:
EDWIN I. HATCH NUCLEAR PLANT - INTEGRATED INSPECTION REPORT 05000321/2020001 AND 05000366/2020001
Dear Ms. Gayheart:
On March 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Edwin I. Hatch Nuclear Plant. On April 23, 2020, the NRC inspectors discussed the results of this inspection with Mr. Sonny Dean, Site VP and other members of your staff. The results of this inspection are documented in the enclosed report.
Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations documented in this inspection report, 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; and the NRC Resident Inspector at Edwin I. Hatch Nuclear Plant.
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 U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC Resident Inspector at Edwin I. Hatch Nuclear Plant. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Alan J. Blamey, Chief Reactor Projects Branch 2 Division of Reactor Projects
Docket Nos. 05000321 and 05000366 License Nos. DPR-57 and NPF-5
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000321 and 05000366
License Numbers:
Report Numbers:
05000321/2020001 and 05000366/2020001
Enterprise Identifier: I-2020-001-0062
Licensee:
Southern Nuclear Operating Co. Inc.
Facility:
Edwin I. Hatch Nuclear Plant
Location:
Baxley, GA 31513
Inspection Dates:
January 01, 2020 to March 31, 2020
Inspectors:
J. Diaz-Velez, Senior Health Physicist
J. Hickman, Resident Inspector
C. Jones, Senior Resident Inspector
M. Magyar, Reactor Inspector
W. Pursley, Health Physicist
A. Rosebrook, Senior Reactor Analyst
Approved By:
Alan J. Blamey, Chief
Reactor Projects Branch 2
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Edwin I. Hatch Nuclear Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to perform an adequate Radiological Survey to identify a High Radiation Area.
Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000321,05000366/2020001-01 Open/Closed
[H.14] -
Conservative Bias 71124.01 A self-revealing, Green, Non-Cited violation of 10 CFR 20.1501 and Technical Specifications 5.7.1.b was identified when the licensee failed to perform an adequate survey and subsequently a radiation worker entered a high radiation area (HRA) inside the Unit 1 B moisture separator reheater (MSR) to perform the 10-year internals inspection.
Failure to provide an adequate procedure for operation of a temporary pump installed in the Unit One Drywell Equipment Drain Sump.
Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000321/2020001-02 Open/Closed
[H.5] - Work Management 71124.01 A self-revealing, Green, Non-Cited Violation of Plant Hatch Technical Specifications 5.4.1.a,
Procedures, as recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978, was identified when the licensee installed a temporary pump in the Unit One (U1)
Drywell Equipment Drain Sump (DEDS) and the DEDS was inadvertently pumped down to a level that resulted in dose rates exceeding the technical specification requirements for controlling access as a locked high radiation area (LHRA) without the required controls in place.
Additional Tracking Items
None.
PLANT STATUS
Unit 1 began the inspection period at 92.5 percent rated thermal power (RTP) in the end of cycle coast down for the spring 2020 refueling outage. On February 1, 2020, the operators shut the unit down for a scheduled refueling outage. The unit was restarted on March 15, 2020 and reached approximately 100 percent RTP on March 22, 2020. On March 29, 2020, the unit was down powered to 60 percent RTP due to erratic outboard bearing temperatures on 1B Reactor Feed Pump Turbine. On March 31, 2020, the unit was returned to 100 percent RTP.
Unit 2 began the inspection period at 100 percent RTP. On January 12, 2020, the unit was down powered to 65 percent RTP due to a loss of turbine building chillers and a rise in condenser bay temperatures. On January 15, 2020, the unit was returned to 100 percent RTP and operated there for the remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/readingrm/doc-collections/insp-manual/inspection-procedure/index.html.
Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. From January 1 - March 19, 2020, the inspectors performed plant status activities described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week and during that time conducted plant status activities as described in IMC 2515, Appendix D; and observed risk significant activities when warranted. In addition, resident and regional baseline inspections were evaluated to determine if all or portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In the cases where it was determined the objectives and requirements could not be performed remotely, management elected to postpone and reschedule the inspection to a later date.
REACTOR SAFETY
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)1A Emergency Diesel Generator (EDG) following the Monthly Operability Test on January 31, 2020.
(2)1A Residual Heat Removal System following the securing of shutdown cooling on March 16, 2020.
- (3) Unit 1 High Pressure Coolant Injection System following the Monthly Operability Test on March 17, 2020.
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the Torus Spray System on February 27, 2020.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Cable Spreading Room on January 9, 2020.
(2)600V Switchgear Rooms on February 18, 2020.
- (3) Unit 1 and 2 Reactor Protection System Battery Rooms on March 9, 2020.
- (4) Unit 1 and 2 Control Building General Area 112' level on March 19, 2020.
71111.08G - Inservice Inspection Activities (BWR)
BWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding
Activities (IP Section 03.01)
- (1) The inspectors evaluated boiling water reactor non-destructive testing by reviewing the following examinations from February 3 - 7, 2020:
1. Ultrasonic Testing (UT)
a. 1E41-1HPCI-10-D-13, High Pressure Coolant Injection Tee to Pipe weld, ASME Class 1 (observed)b. 1E41-1HPCI-10-D-14, High Pressure Coolant Injection Tee to Pipe weld, ASME Class 1 (observed)c. 1B31-1RC-12AR-J-5, Recirculation System weld, ASME Class 1, Automated UT (observed)d. N-6B, Reactor Vessel Head to nozzle weld, ASME Class 1, Manual UT (observed)e. N-7, Reactor Vessel Head to nozzle weld, ASME Class 1, Manual UT (observed)
2. Penetrant Testing (PT)
a. 1C41F033B, Outlet Check Valve, ASME Class 2 (reviewed)
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the Unit 1 Control Room during final feedwater heater reduction for end of cycle coast down, lowering cavity level to the reactor pressure vessel flange prior to head installation, Control rod scram timing, and Reactor startup on January 8, 2020, March 5, 2020, March 10, 2020, and March 15, 2020, respectively.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the simulator for Just in Time Training to support the Unit 1 startup on March 11, 2020.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (3 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) Unit 1 High Pressure Core Injection Unit Cooler leak on January 17, 2020.
- (2) Unit 2 Primary Containment Maintenance Rule Functional Failure on February 5, 2020.
- (3) Unit 1 "D" Residual Heat Removal Pump breaker Maintenance Rule Functional Failure evaluation on March 9, 2020.
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed;
- (1) Unit 1 elevated shutdown risk during the replacement of the 1C Startup Auxiliary Transformer on February 5, 2020.
- (2) Unit 1 elevated shutdown risk with Power Availability, Decay Heat Removal, and Coolant Inventory all at yellow risk on February 11, 2020.
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) CR10677447, Unit 2 Failure of turbine fast closure trip during control valve testing on January 16, 2020.
- (2) CR10676535, Unit 2 Emergency Diesel Generator fuel pump failed surveillance on January 16, 2020.
- (3) CR10680709, Unit 1 Pant Service Water piping to 1B Emergency Diesel Generator exposed to freezing temperatures on January 28, 2020.
- (4) CR10686188, Unit 1 Jet pump beam 14 loose on February 13, 2020.
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)
The inspectors evaluated the following temporary or permanent modifications:
- (1) SNC1076009, Unit 1 Jet Pump Beam Bolting Assembly Equivalency Evaluation, Revision 0.
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the following post maintenance test activities to verify system operability and functionality:
(1)34SV-P41-P41-001-2, 2B Plant Service Water Pump (PSW) Operability, Version 16.0, Following the replacement of 2B PSW Pump on January 28, 2020.
(2)34SV-R43-021-1, Diesel Generator 1B LOCA/LOSP LSFT, Version 3.0, following 1F DVR installation for degraded grid project on February 9, 2020.
(3)34SV-R43-020-1, Diesel Generator 1A LOCA/LOSP LSFT, Version 2.2, following 1E DVR installation for degraded grid project on February 21, 2020.
(4)41IT-TET-006-1, ISI Pressure Test of the Class 1 System, Version 22.0, following refueling of Unit 1 on March 8, 2020.
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated Unit 1 refueling outage activities from February 1, 2020 to March 15, 2020.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
(1)34SV-R43-001-1, Diesel Generator 1A Monthly Test, Ver. 25.0 on January 3, 2020.
(2)34SV-P41-001-1, Plant Service Water Pump Operability, Version 14.1 on January 29, 2020.
(3)52GM-MME-015, Reactor Vessel Disassembly, Version 22.8, Work Order SNC787374, Drywell Head removal on February 1, 2020.
- (4) Unit 1A Torus Spray Header Test on February 19, 2020.
(5)52SV-R42-012-1, Unit 1 E.S.S. Battery Combined Service Performance / Modified Performance Test, Version 3.5, March 5, 2020.
(6)42SV-C11-003-0, Control Rod Scram Testing, Version 11.0 on March 8, 2020.
Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)
(1)42SV-TET-001-0, LLRT Testing Methodology, Version 13.0 and 42SV-TET-001-1, Primary Containment Periodic Type B and Type C Leakage Tests for B and C MSIVs, Version 30.0 on February 5,
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels, the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards. Observations were performed in the following areas: Dry Well, Reactor Building, and TC-16 control points; Radwaste Building and Turbine Building.
Instructions to Workers (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated radiological protection-related instructions provided to plant workers, including the use of radiation work permits, radiological surveys, one-to-one briefings, control point briefings, use of "trip" tickets, and area specific control points (e.g., reactor building, turbine building, etc.) radiation levels.
Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)
The inspectors evaluated licensee processes for monitoring and controlling contamination and radioactive material.
- (1) Observed radiation workers performing a Reactor Pressure Vessel Head O-ring cleanup under Radiation Work Permit (RWP) 20-1202. This included observations of site Radiological Protection (RP) staff performing surveys and monitoring staff doses on the refuel floor. This job included the use of respiratory protection.
- (2) Observed radiation workers performing a Hydraulic Control Unit maintenance job under RWP 20-1020. This included observations of site RP staff performing surveys and controlling access to the radiation area. Other work observed included scaffolding installation, insulation removal, fuel movement, etc. The inspectors also observed radiation workers getting in/out of the Radiological Control Area (RCA) and the performance of contamination monitoring as well as radiation surveys conducive to the release of personal items.
Radiological Hazards Control and Work Coverage (IP Section 03.04) (3 Samples)
The inspectors evaluated in-plant radiological conditions during facility walkdowns and observation of radiological work activities.
- (1) Observed licensee Very High Radiation Area (VHRA) access controls of radiation workers under RWP 20-1611, Outage RP Support Activities, including access to upper elevation. Work activities required Health Physicist (HP) remote monitoring via Electronic Alarm Dosimetry (EAD).
- (2) Observed work activities in the refuel floor under RWP 20-1202, Reactor Pressure Vessel Head O-ring cleanup, including fitting of workers with respiratory protection equipment, radiological hazards discussions with workers and air sampling to assess the possibility of changing radiological conditions.
- (3) Observed preparation, cask loading and surveys of resin shipment at the Unit 2 Radwaste Process Pad under RWP 20-0266, Rad Waste Processing Including: Resin Sampling, Alpha Trending and Waste Separation and Temporary Storage Facility Work.
High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (3 Samples)
The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:
- (1) The inspectors evaluated licensee controls of the Unit 1 fuel pool cooling (FPC) heat exchanger (HX) Room, and Unit 2 Steam Chase.
- (2) The inspectors evaluated licensee controls of the Unit 2 tip room and Unit 2 drywell.
- (3) The inspector evaluated licensee controls of the Unit 2 reactor water clean up (RWCU) pump rooms A/B, Unit 2 RWCU HX room, and Unit 1 High Radiation Hallway.
Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)
- (1) The inspectors evaluated radiation workers and RP technician's performance as it pertains to radiation protection requirements. Observed interactions of radiation workers with Licensee's RP staff during control points entry briefings, including the RCA, Unit 1 Drywell, Unit 1 Reactor Building and Refueling Floor. Radiation workers were found knowledgeable of the scope of the work to be performed, the RWP/task to be used, dose rate limits established and dose allowed. In addition, the inspectors observed Licensee's RP staff discussing expectations as to the communication or special instructions provided to workers to ensure adequate Radiation Safety practices. The inspectors observed Licensee RP technicians performing RP practices (e.g., surveys, observations of radiation workers, dose monitoring, etc.) and found RP technicians had adequate proficiency in RP.
71124.08 - Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,
and Transportation
Radioactive Material Storage (IP Section 02.01)
The inspectors evaluated radioactive material storage.
- (1) The inspectors toured the following areas:
Unit 1 Waste Process Pad Unit 2 Waste Process Pad Waste Separation and Temporary Storage Facility Sea-Land Storage Facility Radioactive Waste Building Radioactive Waste Control Room
The inspectors performed container checks (e.g., swelling, leakage and deformation)on multiple containers while walking down areas listed above.
Radioactive Waste System Walkdown (IP Section 02.02) (1 Sample)
The inspectors evaluated the following radioactive waste processing systems [and processes] during plant walkdowns:
- (1) Liquid or Solid Radioactive Waste Processing Systems
- Unit 1/Unit 2 Waste Collector System
- Unit 1/Unit 2 Condensate Phase Separators
Radioactive Waste Resin and/or Sludge Discharges Processes
- Resin Dewatering/Drying System
Waste Characterization and Classification (IP Section 02.03) (1 Sample)
The inspectors evaluated the radioactive waste characterization and classification for the following waste streams:
- (1) Dry Active Waste (DAW) Distribution Scaling Factor Determination, March 15, 2019.
Unit 2 Cleanup Phase Separators Distribution Scaling Factor Determination, July 11, 2019.
Unit 2 Spent Resin Distribution Scaling Factor Determination, March 15, 2019.
Shipment Preparation (IP Section 02.04) (1 Sample)
The inspectors evaluated [and observed] the following radioactive material shipment preparation processes:
(1)20-RW-007 20-RW-008
Shipping Records (IP Section 02.05) (1 Sample)
The inspectors evaluated the following non-excepted package shipment records:
(1)19-RW-036 19-RW-047 19-RW-040 19-RW-041 18-RM-038
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01)===
- (1) Unit 1 from January 1, 2019 to December 31, 2019.
- (2) Unit 2 from January 1, 2019 to December 31, 2019.
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (2 Samples)
- (1) Unit 1 from January 1, 2019 to December 31, 2019.
- (2) Unit 2 from January 1, 2019 to December 31, 2019.
IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (2 Samples)
- (1) Unit 1 from January 1, 2019 to December 31, 2019.
- (2) Unit 2 from January 1, 2019 to December 31, 2019.
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) January 1, 2019 to December 31, 2019.
71152 - Problem Identification and Resolution
Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) Through wall water leak from the 1A EDG Fuel Oil Transfer Pump electrical conduit, filling the Fuel Oil Storage Tank Enclosure 21 inches above Fuel Oil Storage Tank, CRs 10695910, 10696062, and 10696214. Work Order SNC1084849 Water Present in 1A EDG Fuel Oil Storage Tank.
INSPECTION RESULTS
Failure to perform an adequate Radiological Survey to identify a High Radiation Area.
Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety
Green NCV 05000321,05000366/2020001-01 Open/Closed
[H.14] -
Conservative Bias 71124.01 A self-revealing, Green, Non-Cited violation of 10 CFR 20.1501 and Technical Specifications 5.7.1.b was identified when the licensee failed to perform an adequate survey and subsequently a radiation worker entered a high radiation area (HRA) inside the Unit 1 B moisture separator reheater (MSR) to perform the 10-year internals inspection.
Description:
On February 9, 2020, a radiation worker received an electronic alarming dosimeter (EAD) dose rate alarm in excess of 250 millirem per hour (mrem/hr) while performing a 10-year inspection of the Unit 1 B MSR internals. The licensee had performed a survey (#176936) prior to the worker accessing the MSR which identified the highest dose rate at 43 millirem per hour (mrem/hr) at 30 centimeters (general area) but was performed by a radiation protection technician who performed the survey by reaching in through the entry port. The radiation worker had to actually enter the MSR which was forty feet long to do the inspection. A followup survey found general area dose rates as high as 360 mrem/hr inside the MSR in an area that was not surveyed prior to the radiation worker entering.
The licensees inadequate survey failed to identify general area dose rates greater than 100 mrem/hr inside the MSR and resulted in the area not being posted as a High Radiation Area (HRA) in accordance with 10 CFR 20.1902 and site procedures. In addition, the area was not controlled for access in accordance with site procedures. The radiation work permit the worker was using did not authorize entry to an HRA and as required by Plant Hatch Technical Specifications, the worker was not made knowledgeable of the dose rates prior to entry. The worker received less than two mrem for the entry which the inspectors concluded was in part due to the worker's appropriate response to the EAD alarm and the general area dose rates were so much higher than the EAD rate alarm setpoint.
Corrective Actions: The licensee took immediate corrective action including removing radiation protection technician qualifications of the individual who had performed the inadequate surveys of the area. In addition, the licensee initiated an event investigation to determine if additional actions were necessary.
Corrective Action References: Condition Report 10685808
Performance Assessment:
Performance Deficiency: Failure to perform an adequate survey to identify a High Radiation Area in the Unit 1 B moisture separator reheater (MSR) as required by 10 CFR 20.1501, was identified as a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, as a direct result of an inadequate survey, an uninformed worker entered an unposted HRA with an EAD with a rate alarm setpoint that was too high to allow the worker to take appropriate action before encountering dose rates exceeding 100 mrem/hr challenging the licensee's ability to prevent unplanned dose.
Significance: The inspectors assessed the significance of the finding using Appendix C, Occupational Radiation Safety SDP. The finding was of very low safety significance (Green)because it was not an As Low As Reasonably Achievable (ALARA) planning issue, there was no overexposure nor potential for an overexposure (due to availability of alarming dosimetry being worn), and the licensees ability to assess dose was not compromised.
Cross-Cutting Aspect: H.14 - Conservative Bias: Individuals use decision making-practices that emphasize prudent choices over those that are simply allowable. A proposed action is determined to be safe in order to proceed, rather than unsafe in order to stop. RP decision making practices allowed a worker to enter the MSR without an adequate radiological survey of the area. In addition, the worker was using an RWP that did not allow access to areas where radiation levels were greater than 100 mrem/hr with an EAD setpoint of 250 mrem/hr. This is not reflective of an organization with a bias for conservative decision making.
Enforcement:
Violation: 10 CFR 20.1003, defines a survey as an evaluation of the radiological conditions and potential hazards incident to the production, use, transfer, release, disposal, or presence of radioactive material or other sources of radiation.
10 CFR 20.1501 requires that each licensee make or cause to be made surveys that may be necessary for the licensee to comply with the regulations in Part 20 and that surveys are reasonable under the circumstances to evaluate the extent of radiation levels, concentrations or quantities of radioactive materials, and the potential radiological hazards that could be present.
10 CFR 20.1902 requires, in part, that the licensee post each High Radiation Area with a conspicuous sign or signs bearing the radiation symbol and the words "CAUTION, HIGH RADIATION AREA" or "DANGER, HIGH RADIATION AREA."
Technical Specification 5.7.1.b requires, in part, that entry into a High Radiation Area with a radiation monitoring device be made after dose rate levels in the area have been established and personnel are made aware of them.
Contrary to the above, as of February 9, 2020, the licensee failed to make surveys to ensure compliance with 10 CFR 20.1902 and Technical Specification 5.7.1.b requirements. Specifically, 1) the survey performed failed to identify an HRA in the MSR and the area was not properly posted, and 2) a worker entered the HRA in the 1B MSR without being made aware of the dose rates in the area.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to provide an adequate procedure for operation of a temporary pump installed in the Unit One Drywell Equipment Drain Sump.
Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety
Green NCV 05000321/2020001-02 Open/Closed
[H.5] - Work Management 71124.01 A self-revealing, Green, Non-Cited Violation of Plant Hatch Technical Specifications 5.4.1.a, Procedures, as recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978, was identified when the licensee installed a temporary pump in the Unit 1 (U1) Drywell Equipment Drain Sump (DEDS) and the DEDS was inadvertently pumped down to a level that resulted in dose rates exceeding the technical specification requirements for controlling access as a locked high radiation area (LHRA) without the required controls in place.
Description:
On February 15, 2020 a temporary sump pump installed in the U1 DEDS was turned on by the Reactor Building Coordinator at the request of Operations (OPS) to support draining the Reactor Building Closed Cooling Water system. The pump remained in service for approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 45 minutes. On February 26, 2020, at approximately 0100, two Instrumentation and Control Technicians (ICTs) were briefed by radiation protection (RP) to perform work on the carousel at the 127-foot elevation of the drywell and that expected dose rates were 40-75 millirem per hour (mrem/hr) at 30 centimeters (general area). The survey was performed on February 13, 2020, and RP did not anticipate radiation levels in the area changing based on prior operating experience. Also, there had been no entries into the area since February 15, 2020. After the ICTs entered the area, RP technicians in the RP Central Control Center observed, via telemetry, that the workers were exceeding 80% of their 150 mrem/hr electronic dosimeter (ED) dose rate alarm setpoint. The maximum ED dose rate observed was 126 mrem/hr. An RP technician covering the job removed the workers from the area and performed a survey. The survey found general area dose rates of 80-100 mrem/hr on the carousel and 286 mrem/hr at one foot below the grating. The workers returned to work after being briefed on the new dose rates and being briefed to anticipate a dose rate alarm. One of the ICTs received three dose rate alarms and per procedural requirements, both ICTs exited the area. The maximum dose rates observed on their ED was 166 mrem/hr. RP stopped the job. While performing follow-up surveys to determine the source, RP found general area dose rates as high as 1510 mrem/hr at DEDS room on the 114-foot elevation of the drywell.
The Unit 1 DEDS collects all liquid waste from equipment drains in the primary containment. Permanently installed pumps transfer these wastes to the radwaste system using OPS procedure, 34SO-G11-013-1, Drywell and Reactor Building Sumps System. The permanent pumps were removed from service during the current outage for maintenance, and the licensee installed and operated a temporary pump using work order (WO)
SNC787857 to preclude overflow of the DEDS. Procedure 34SO-G11-013-1 contained no provisions for the installation and operation of temporary pumps in the DEDS and there were no notes or precautions in this procedure or the WO warning users of the importance of maintaining a minimum DEDS sump level. The licensees causal analysis concluded that the failure to recognize the risk and fully understand the consequences of operating the temporary equipment without procedural controls and the failure to implement appropriate radiological survey methods was the cause of the event. The licensees operational risk assessment (ORA) for WO SNC787857 per NMP-DP-001, Operational Risk Awareness, had not appropriately considered the radiological risk associated with changing radiation levels due to DEDS water level changes that could result from the operation of the temporary pump.
Corrective Actions: The licensee took immediate corrective action including posting and controlling access to the Unit 1 Drywell basement as an LHRA. The equipment drain sump level was returned to normal as were the radiation levels. In addition, the licensee established an event investigation team to perform a causal analysis and determine if additional actions are necessary.
Corrective Action References: This event has been documented in the licensees corrective action program (Action Request # 02318788).
Performance Assessment:
Performance Deficiency: The inspector determined the performance deficiency was the licensees failure to implement an adequate procedure for controlling the operation of a temporary pump installed in the DEDS which resulted in plant workers gaining access to an LHRA that was not controlled in accordance with plant technical specifications.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Program & Process attribute of the Occupational Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. The licensees failure to provide adequate procedures for the operation of a temporary pump in the DEDS that resulted in workers accessing an LHRA that was not controlled in accordance with plant technical specifications challenged the licensees ability to prevent unintended dose to workers.
Significance: The inspectors assessed the significance of the finding using Appendix C, Occupational Radiation Safety SDP. The finding was of very low safety significance (Green)because it was not an ALARA planning issue, there was no overexposure nor potential for an overexposure (due to availability of alarming dosimetry being worn), and the licensees ability to assess dose was not compromised.
Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. The licensees process for planning, controlling, implementing and operating the temporary sump pump did not adequately assess potential radiological risk because of insufficient coordination and communication between Work Control, Operations, and RP prior to installing and operating of the temporary pump.
Enforcement:
Violation: Plant Hatch Technical Specifications 5.4.1.a, states in part, written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, Section 7.a., Procedures for Control of Radioactivity, recommends in part, adequate procedures for (limiting personnel exposure) the collection of liquid radioactive waste. In addition, Section 9.e. recommends in part, General procedures for the control of maintenanceinclude information on the necessity for minimizing radiation exposure to workers. Plant Hatch Technical Specification 5.7.2, High Radiation Area requires areas with radiation levels greater than 1000 mrem/hr, measured at 30 cm from the radiation source shall be provided with locked or continuously guarded doors to prevent unauthorized entry. In addition, the requirements of Specification 5.7.1.b, which allow for personnel entry into such areas only after the dose rate levels in the area have been established and personnel are aware of them. Contrary to these requirements, on February 15, 2020, utilizing a WO that did not contain instructions for limiting potential personnel exposures, plant workers pumped the DEDS to a level such that dose rates exceeded 1000 mrem/hr at 30 cm from the source in an area that was not locked or continuously guarded. On February 26, 2020, personnel entered the area prior to the dose rates being established and their being made aware of them.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On April 23, 2020, the inspectors presented the integrated inspection results to Mr.
Sonny Dean, Site VP and other members of the licensee staff.
- On February 14, 2020, the inspectors presented the Occupational Radiation Safety Radiation Hazards & Transportation Baseline Inspection results to Mr. Sonny Dean, Site VP and other members of the licensee staff.
- On February 6, 2020, the inspectors presented the Unit 1 ISI inspection results to Mr.
Sonny Dean, Site VP and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Drawings
H-13412
Elementary Diagram Diesel Generator 1A
Version 53.0
H-16329
Unit 1 RHR System P&ID Sheet 1
Version 83.0
H-16332
Unit 1 HPCI System P&ID Sheet 1
Version 68.0
Procedures
Residual Heat Removal System
Version 45.1
High Pressure Coolant Injection (HPCI) System
Version 30.0
Diesel Generator Standby AC System, Attachments 3 and 4
Version 29.2
Air Test on Torus Headers and Nozzles
Version 5.0
Drawings
A-43965, Sheet
044
Cable Spreading Room
Version 2.0
A-43965, Sheets
014, 015, 021,
and 022
Reactor Protection System Battery Rooms
Revision 4.0
A-43965, Sheets
23, 024, 025,
and 035
Control Building General Area 130'
Revision 4.0
A-43965, Sheets
28, 029, 037,
and 038
600 volt Switchgear Rooms
Version 5.0
Fire Plans
Fire Protection Hazards Analysis (FHA)
Revision
36.0
71111.11Q Miscellaneous
LT-SG-50716
Just In Time Simulator for Plant Startup
Revision 3.0
Procedures
34GO-OPS-001-1 Plant Startup
Version 45.6
34GO-OPS-042-1 Moisture Separator Re-heater Extraction Steam and Heater
Shell Drain System
Version 17.3
Fuel Pool Cooling and Cleanup System
Version 22.2
Control Rod Scram Testing
Version 11.0
Procedures
Maintenance Program
Version 35.0
Regulatory Assessment Performance Indicator Guideline
Revision 7
NMP-ES-027
Version 10.2
NMP-OS-010-002 Hatch Protected Equipment Logs
Version 11.1
Industry Guideline for Monitoring the Effectiveness of
Maintenance at Nuclear
Revision 4A
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Power Plants
Miscellaneous
Equipment Out of Service Calculations
February 5,
20
Equipment Out of Service Calculations
February 11,
20
Procedures
NMP-DP-001
Operational Risk Awareness
Version 16.0
Calculations
Equipment Out of Service Calculations
01/12/2020
Procedures
NMP-AD-012
Operability Determinations and Functional Assessments
Version 13.3
Procedures
NMP-AD-008
Applicability Determinations
Version 21.1
NMP-AD-009
Licensing Document Change Requests
Version 16.3
NMP-AD-010
CFR 50.59 Screenings and Evaluations
Version 16.0
NMP-MA-014
Post Maintenance Testing/Post Modification Testing
Version 2.2
Procedures
NMP-MA-014
Post Maintenance Testing/Post Modification Testing
Version 2.2
NMP-MA-014-
001
Maintenance Testing Guidance
Version 5.2
Procedures
31GO-OPS-024-0 Outage Safety Assessment
Version 5.4
34GO-OPS-001-1 Plant Startup
Version 45.6
Corrective Action
Documents
10651366,
10684160,
10686216,
10685808,
10580237,
10596223,
10607281,
10613382,
10571787,
10577386,
10579232,
10582595,
10578680,
2964, 2318788
and 10578499
Condition Reports # 10651366, 10684160, 10686216,
10685808, 10580237, 10596223, 10607281, 10613382,
10571787, 10577386, 10579232, 10582595, 10578680, and
10578499
CAR# 277352
NMP-GM-002-F02 - Cause Determination Report Summary
04/08/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
for U1 Drywell Unposted LHRA
Rev 1
Miscellaneous
N/A
Locked High Radiation Areas and Very High Radiation Areas
List
Undated
NMP-GM-020-
F03
Event Recovery Report: Unanticipated Dose Rate Alarm
received in Unit 1 "B" MSR during inspection
2/09/2020
PARC Meeting,
Outage PARC #1,
RWP Dose
Estimate Updates
Report
PARC Meeting, Outage PARC #1, RWP Dose Estimate
Updates
2/13/2020
Procedures
AMS-4 Operation and Calibration
2/09/2018
Control of High Radiation Areas
06/22/2018
NMP-DP-001
Operational Risk Awareness
Version 16.0
NMP-DP-001-
GL01
Risk Assessment Worksheets
VERSION
2.0
NMP-FLS-016
Safe Conduct of Diving
09/05/2019
NMP-HP-206
Issuance, Use, and Control of Radiation Work Permits
01/16/2019
NMP-HP-300
Radiation and Contamination Surveys
10/29/2019
NMP-HP-301
Airborne Radioactivity Sampling and Evaluation
04/10/2019
NMP-HP-302-001 Radiological Key Control
06/29/2018
NMP-HP-400
Radioactive Source Inventory
10/14/2019
NMP-HP-404
Release of Materials from the RCA and Protected Areas
07/19/2018
Radiation
Surveys
176574
Plant Hatch U1 RPV Head
2/04/2020
NMP-HP-301
(RWP 20-1202)
Airborne Radioactivity Sample and Evaluation
2/13/2020
RP Survey #
178187
U1 Carousel (1DW114 Subpile) LHRA Posting Survey
2/26/2020
RP Survey
- 176764
U1 Subpile Room (1DW114 Subpile) After Shield Plate
Removal
2/06/2020
RP Survey
- 177291
U1 Carousel (1DW114 Subpile)
2/13/2020
RP Survey
- 178170
U1 Carousel (1DW114 Subpile)
2/26/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
RP Survey
- 178186
U1 Carousel (1DW114 Subpile) LHRA Down Posting Survey
2/26/2020
RP Survey#
178179
DW Subpile Room (1DW114Subpile) LHRA Downposting
Survey
2/26/2020
Radiation Work
Permits (RWPs)
20-1202
Refuel Floor - Bridge, Hoist, Grapple and Upper Platform
Maint./ Repairs, Underwater Camera/Repairs, Tru-Nikes,
Blade Guides, Lighting, and Non-Irradiated Tool Handling
Rev. 0
Work Orders
Work Order #
SNC787857
2/07/2019
Miscellaneous
Radioactive
Material
Shipment Log
Reports
(2018/2019)
Radioactive Material Shipment Log Reports (2018/2019)
N/A
Radioactive
Waste Shipment
Log Reports
(2018/2019)
Radioactive Waste Shipment Log Reports (2018/2019)
N/A
Procedures
Resin Dewatering/Drying System
Version 8.4
Cask Handling for NRC Approved Type A 14-190 and/or 14-
210 Casks
Version 4.0
Waste Separation and Temporary Storage Facility and
Sealand Storage Facility
Version 4.0
SOLID RADIOACTIVE WASTE PROCESS CONTROL
PROGRAM
FOR
EDWIN I. HATCH NUCLEAR PLANT
Revision 6
NMP-HP-403
Control and Monitoring of Materials in Radiation
Controlled Areas
Version 3.9
NMP-HP-405
Shipment of Radioactive Waste and Radioactive
Material
Version 3.7
NMP-HP-405-001 Use of the Radman Program for Shipment of Radioactive
Waste and Radioactive Material
Version 1.0
NMP-HP-408
Solid Radioactive Waste Scaling Factor Determination and
Version 2.0
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Implementation and Waste Classification
Radiation
Surveys
DS-0001
U1 CPS distribution scaling factor determination
03/05/2019
DS-0001
U1 CPS Distribution scaling factor determination
2/05/2018
DS-0001
U1 CUPS Scaling Factor Determination
06/02/2018
DS-0001
U1 SR Distribution scaling factor determination
2/01/2018
DS-0001
U1 Torus Filters scaling factor determination
05/15/2018
DS-0001
U2 CPS Distribution scaling factor determination
2/02/2018
DS-0001
U2 SR Distribution scaling factor determination
2/02/2018
DS-0002
DAW Distribution Scaling Factor Determination
2/11/2019
DS-0002
DAW fractional abundance distribution
2/01/2018
RP Survey
- 178187
2/26/2020
71151
Corrective Action
Documents
10758680,
10579232,
10580237,
10592272,
10596223,
10607281,
10613650,
10641846
Condition Reports 10758680, 10579232, 10580237,
10592272, 10596223, 10607281, 10613650, 10641846
CARs 275950,
276184
Corrective Action Reports
Miscellaneous
Monthly PI Report
Unit 1/2 (January
2019-December
2019)
Monthly PI Report Unit 1/2 (January 2019-December 2019;
non-dated)
Regulatory Assessment Performance Indicator Guideline.
Revision 7
Procedures
NMP-AD-029
Preparation and Reporting of Regulatory Assessment
Performance Indicator
Data and the Monthly Operating Report
Version 1.1
Procedures
NMP-AD-029
Preparation and Reporting of Regulatory Assessment
Performance Indicator Data and the Monthly Operating
Report
Version 1.1
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
NMP-GM-002
Corrective Action Program
Version 15.2
NMP-GM-002-
2
Effectiveness Review Instructions
Version 5.2