IR 05000321/2023011
| ML23320A059 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 11/17/2023 |
| From: | Alan Blamey NRC/RGN-II/DRP/RPB2 |
| To: | Coleman J Southern Nuclear Operating Co |
| References | |
| IR 2023011 | |
| Download: ML23320A059 (23) | |
Text
SUBJECT:
EDWIN I. HATCH NUCLEAR PLANT-BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000321/2023011 AND 05000366/2023011
Dear Jamie Coleman:
On November 8, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Edwin I. Hatch Nuclear Plant and discussed the results of this inspection with Mr. Carl Collins and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations problem identification and resolution program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for problem identification and resolution programs.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. One Severity Level IV violation without an associated finding is documented in this report. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
November 17, 2023 A licensee-identified violation which was determined to be of very low safety significance is documented in this report. We are treating this violation as a non-cited violation (NCV)
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, Alan J. Blamey, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket Nos. 05000321 and 05000366 License Nos. DPR57 and NPF5
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000321 and 05000366 License Numbers:
DPR-57 and NPF-5 Report Numbers:
05000321/2023011 and 05000366/2023011 Enterprise Identifier:
I2023011-0022 Licensee:
Southern Nuclear Operating Company, Inc.
Facility:
Edwin I. Hatch Nuclear Plant Location:
Baxley, Ga Inspection Dates:
September 11, 2023, to November 8, 2023 Inspectors:
A. Alen, Senior Project Engineer D. Hardage, Senior Resident Inspector P. Niebaum, Senior Resident Inspector C. Scott, Senior Project Engineer 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 a biennial problem identification and resolution 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. A licensee-identified non-cited violation is documented in report section: 71152
List of Findings and Violations
Failure to Implement Corrective Actions Results in Inoperability of SBGT Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity Green NCV 05000366/202301101 Open/Closed
[P.3] -
Resolution 71152B The Green self-revealed non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50 Appendix B Criterion XVI, Corrective Actions was identified when the licensee failed to correct a condition adverse to quality (CAQ) associated with the Unit 2 'A' train (2A) standby gas treatment system (SBGT). Specifically, the licensee failed to correct a CAQ following the discovery of a cracked vane lever arm in the 2A SBGT train filter butterfly valve on February 12, 2023. As a result, on June 26, 2023, the valve failed and resulted in entry into a 7-day dual unit Technical Specification (TS) Required Action Statement (RAS).
Failure to Adopt Appropriate Part 21 Procedures Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000321,05000366/202301102 Open/Closed Not Applicable 71152B The inspectors identified a Severity Level (SL) IV non-cited violation (NCV) of 10 CFR 21.21(a) for the licensees failure to adopt appropriate procedures to evaluate deviations.
Specifically, licensee procedures were not appropriate to ensure that 10 CFR Part 21,
Reporting of Defects and Noncompliances, evaluations are completed as required by regulations because it allows the licensee to discontinue 10 CFR Part 21 evaluations if the supplier agrees to perform the evaluation.
Additional Tracking Items
Type Issue Number Title Report Section Status URI 05000366/202301103 Potential Failure to Make a Part 21 Report 71152B Open
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/reading-rm/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. 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.
OTHER ACTIVITIES-BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 03.04)
- (1) The inspectors performed a biennial assessment of the effectiveness of the licensees Problem Identification and Resolution program, use of operating experience, self-assessments and audits, and safety conscious work environment.
- Problem Identification and Resolution Effectiveness: The inspectors assessed the effectiveness of the licensees Problem Identification and Resolution program in identifying, prioritizing, evaluating, and correcting problems.
Specifically, the team evaluated the licensee's compliance with their Problem Identification and Resolution program, as described in procedure NMP-GM002, "Corrective Action Program," version 16.0 and NRC regulations. The inspectors reviewed a sample of condition reports, generated since the last problem identification and resolution inspection (September 2021). These reviews included failures; corrective and preventive maintenance issues, surveillances; reliability; and maintenance rule performance. The condition report reviews were expanded to five years for the containment ventilation, residual heat removal and service air systems. Also, as part of the assessment, the inspectors reviewed corrective actions for the following non-cited violations (NCVs), findings (FIN), and licensee-identified violations (LIVs):
o NCV 202100301, Inoperability of 2D Residual Heat Removal Pump Due to Inadequate Maintenance Procedural Instructions for Recoupling Pump and Motor o
NCV 202200105, Inoperability of 1B Low Pressure Coolant Injection Loop Beyond the Technical Specification Allowed Completion Time Due to Inadequate Maintenance Procedure o
FIN 202200104, Automatic Reactor Shutdown on Low Reactor Water Level Due the Implementation of a Design Change with Single Point Vulnerability Resulting in a Total Loss of Reactor Feed Pumps o
NCV 202200103, Inoperability of Plant Service Water and Residual Heat Removal Service Water Pumps Due to Inadequate Maintenance Procedure o
NCV 202200102, Failure to Implement the NRC-Approved Emergency Action Levels o
NCV 202200101, Incorrect Emergency Action Level Threshold Values for Spent Fuel Pool Level Instrumentation o
NCV 202240301, Security Cornerstone NCV documented in security baseline inspection report 2022404 o
NCV 202200401, Failure to Maintain an Emergency Plan Risk Significant Planning Standard Implementing Procedure o
NCV 202300203, Violation of Primary Containment Technical Specification 3.6.1.1 o
NCV 202300202, Incorrect Adjustable Speed Drive High Speed Setpoints Result in Manual Scram o
NCV 202300201, Inadequate Procedure for Condensate Hotwell Level Control
- Operating Experience: The inspectors assessed the effectiveness of the licensees processes for use of operating experience.
- Self-Assessments and Audits: The inspectors assessed the effectiveness of the licensees identification and correction of problems identified through audits and self-assessments.
- Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Assessment 71152B Assessment 1) Corrective Action Program Effectiveness Problem Identification: The inspectors determined that the licensee was effective in identifying problems and entering them into the corrective action program (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 condition reports as described in licensee procedure NMP-GM002, "Corrective Action Program," version 16.0, and managements expectation that employees were encouraged to initiate condition reports. Additionally, site management was actively involved in the CAP and focused appropriate attention on significant plant issues.
Problem Prioritization and Evaluation: The inspectors reviewed condition reports (CRs),technical evaluations, and completed and/or planned work orders. With the exception noted below, the inspectors concluded that problems were, generally, prioritized and evaluated in accordance with licensee procedure NMP-GM002001, "Corrective Action Program Instructions," version 45.0. The inspectors determined that adequate consideration was given to structures, systems, and/or component's operability and associated plant risk. The inspectors determined that, in general, plant personnel had conducted cause evaluations in accordance with licensees CAP procedures, as described in NMP-GM002GL03, "Cause Analysis and Corrective Actions Guidelines," version 33.0, and cause determinations were appropriate, and considered the significance of the issues being evaluated.
Corrective Actions: The inspectors reviewed corrective action documents, interviewed licensee staff, and verified completion of corrective actions. With the exception noted below, the inspectors determined that, generally, corrective actions were timely, commensurate with the safety significance of the issues, and effective, in that conditions adverse to quality (CAQ)were corrected. The team determined that the licensee was generally effective in developing corrective actions that were appropriately focused. The inspectors reviewed CRs and effectiveness reviews, as applicable, to verify that the significant conditions adverse to quality had not recurred. Effectiveness reviews for corrective actions to preclude repetition were sufficient to ensure corrective actions were properly implemented and were effective. The inspectors reviewed corrective action documents for NRC findings issued since the last problem, identification, and resolution biennial inspection.
Based on the samples reviewed, the team determined that the licensees CAP complied with regulatory requirements and self-imposed standards. The licensees implementation of the CAP adequately supported nuclear safety.
2) Operating Experience The team determined that the licensees processes for the use of industry and NRC operating experience information were effective and complied with regulatory requirements and licensee standards. The implementation of these programs adequately supported nuclear safety. The team concluded that operating experience was adequately evaluated for applicability and that appropriate actions were implemented in accordance with applicable procedures.
3) Self-Assessments and Audits The inspectors reviewed a sample of completed self-assessments and audits conducted by both plant and nuclear oversight personnel. The inspectors determined that the licensee was effective at performing self-assessments and audits to identify issues at a low level, properly evaluated those issues, and resolved them commensurate with their safety significance. The self-assessments and audits were adequately self-critical and performance-related issues were being appropriately identified. The inspectors verified that CRs were created to document areas for improvement and findings and verified that actions had been completed consistent with those recommendations.
4) Safety Conscious Work Environment The inspectors interviewed a sample of plant employees from various departments and with varying roles/responsibilities within the organization. The inspectors determined that employees
- (1) were willing to raise nuclear safety concerns to their supervisor/manager or though the CAP,
- (2) were aware of alternative avenues for raising concerns such as the Employee Concern Program (ECP), and
- (3) had not experienced retaliation for raising safety concerns. Specifically, all individuals interviewed indicated that they would feel comfortable in raising safety concerns. All individuals felt that their management was receptive to receiving safety concerns and generally addressed them promptly and commensurate with the significance of the concern. Most interviewees were aware of the licensee's ECP and stated they would use the program, if necessary. When asked whether there have been any instances where individuals experienced retaliation or other negative reaction for raising safety concerns, all individuals interviewed stated that they had neither experienced nor heard of an instance of retaliation at the site. To supplement these discussions, the team reviewed the ECP case log and interviewed the ECP Coordinator to assess their perception of the site employees' willingness to raise nuclear safety concerns. Also, the team reviewed a sample of the most recent Nuclear Safety Culture Monitoring Panel meeting reports as well as the results from the most recent biennial safety culture survey and self-assessment from August 2022. The team determined that the processes in place to mitigate potential safety culture issues were adequately implemented.
Failure to Implement Corrective Actions Results in Inoperability of SBGT Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity Green NCV 05000366/202301101 Open/Closed
[P.3] -
Resolution 71152B A Green self-revealed non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 50 Appendix B Criterion XVI, Corrective Actions was identified when the licensee failed to correct a condition adverse to quality (CAQ) associated with the Unit 2
'A' train (2A) standby gas treatment system (SBGT). Specifically, the licensee failed to correct a CAQ following the discovery of a cracked vane lever arm in the 2A SBGT train filter butterfly valve on February 12, 2023. As a result, on June 26, 2023, the valve failed and resulted in entry into a 7-day dual unit Technical Specification (TS) Required Action Statement (RAS).
Description:
During the 2023 Unit 2 refueling outage, while finishing work on the 2T46-F002A filter train butterfly valve for the 2A SBGT, the licensee identified that the vane lever arm in the valve was cracked. Condition report (CR) 10947708 was written on February 12, 2023, to document the deficient condition.
On June 26, 2023, during routine operation of the 2A SBGT train for drywell venting, the system failed to indicate flow during startup of the system fan and the "2A SBGT FLOW LOW" annunciator was received in the main control room. Troubleshooting identified that the 2T46F002A vane lever arm had failed, preventing the valve from opening properly. This resulted in the licensee entering a 7-day dual unit RAS. The licensee took immediate corrective actions to repair the valve and restored the equipment to service.
The licensees cause evaluation CAR 4555398 determined that the butterfly valve failed in June because the deficient condition was not properly evaluated during the unit 2 refueling outage and resolved in timely manner. Inspectors reviewed the licensees evaluation and noted that there were several factors that contributed to the licensees failure to correct the CAQ during the outage. The CR written for the cracked vane lever arm identified during the outage was assigned a Mode Code for Mode 3 per processes described in procedures 31GO-OPS0060, Conditions Required Actions, and Completion Times and OPS1982, Reactor Mode Code." Licensee procedure OPS1982 states that "Mode Codes are used to ensure Technical Specification equipment is returned to service prior to entering a mode of applicability, and to ensure that other plant equipment is operational prior to being needed for system operation." The licensee assigned a Mode Code to the CR because it was recognized that the deficient condition needed to be resolved during the refueling outage. However, the corrective action work order SNC1442128 created to correct the deficient condition did not have a Mode Code and was not completed during the outage. The work order was given a target start date of December 19, 2023, after the licensee made the decision to accept the CAQ and complete repairs after the outage, without a formal evaluation of the deficient condition to determine the need for immediate repairs or determine the acceptability to defer repairs to a later time.
The inspectors concluded that the licensees failure to correct the CAQ associated with the cracked vane lever arm in 2T46-F002A during the outage led to the failure of the valve on June 26, 2023.
Corrective Actions: The licensee took immediate corrective actions to repair the valve. The licensee initiated corrective actions to revise 31GO-OPS0060 and OPS1982 to ensure that all CRs that are assigned a reactor Mode Code are evaluated and addressed in a timely manner.
Corrective Action References: CAR 4555398
Performance Assessment:
Performance Deficiency: The failure to correct a CAQ following the discovery of a cracked vane lever arm in the 2A SBGT train filter butterfly valve, 2T46-F002A, was a performance deficiency and a violation of 10 CFR Part 50, Appendix B, Criterion XVI.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the SSC and Barrier Performance attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, failure to correct the cracked vane lever arm in the 2T46-F002A filter train butterfly valve during the outage in February 2023 led to the failure of the valve and unplanned entry into TS for both Units on June 26, 2023.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding screened to be of very low safety significance (i.e., Green) because the finding only represented a degradation of the radiological barrier function provided by the SBGT system.
Cross-Cutting Aspect: P.3 - Resolution: The organization takes effective corrective actions to address issues in a timely manner commensurate with their safety significance. Specifically, the organization failed to implement effective corrective actions in a timely manner to address the cracked vane lever arm identified during the unit 2 February 2023 refueling outage. This resulted in the failure of the valve and unplanned entry into TS for both Units on June 26, 2023.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, states that measures shall be established to ensure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
Contrary to the above, the licensee failed to correct a condition adverse to quality following the discovery of a cracked vane lever arm in the 2A SBGT train filter butterfly valve, 2T46-F002A, on February 12, 2023. Consequently, the 2A SBGT train was rendered inoperable when the cracked vane lever arm failed on June 26, 2023, preventing the valve from opening properly. The licensee took immediate corrective actions to replace the vane lever arm and return the 2A SBGT to service.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Adopt Appropriate Part 21 Procedures Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000321,05000366/202301102 Open/Closed Not Applicable 71152B The inspectors identified a Severity Level (SL) IV non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR 21.21(a) for the licensees failure to adopt appropriate procedures to evaluate deviations. Specifically, licensee procedures were not appropriate to ensure that 10 CFR Part 21, Reporting of Defects and Noncompliances, evaluations are completed as required by regulations because it allows the licensee to discontinue 10 CFR Part 21 evaluations if the supplier agrees to perform the evaluation.
Description:
Condition report (CR) 10958783, initiated on March 22, 2023, documented that a local leak rate test failure of two primary containment isolation valves on unit 2 (F319 and F320) that occurred on February 7, 2023, was most likely due to a manufacturing or a design flaw in the new style T-Ring used in these valves. This CR documented that Fisher Controls (the supplier) agreed to further investigate the failure of the T-Rings on the licensees behalf and perform an evaluation for reportability under 10 CFR Part 21 as appropriate. On April 5, 2023, the licensee submitted licensee event report (LER) 05000366/2023001-00, "Primary Containment Penetration Exceeded Maximum Allowable Primary Containment Leakage Rate (La)" (ADAMS Accession No. ML23095A088) for this event and stated that the cause was due to a manufacturing defect.
The team identified that the licensee did not perform a substantial safety hazards evaluation associated with the manufacturing defect mentioned in LER 05000366/2023001-00 and described in CR 10958783. The licensees decision to not perform the evaluation was based on the guidance in the licensee fleet procedure NMP-AD028, 10 CFR 21 Evaluations and Reporting Requirements, Ver. 7.0. Section 4.2.b(1), which states, IF the supplier agrees to perform the Substantial Safety Hazard Evaluation and notification to the NRC, document the basis AND terminate any further Part 21 review until the Suppliers notification is complete.
This provision to transfer the 10 CFR Part 21 evaluation to the supplier was added to the procedure on January 31, 2017 (Version 4).
Regulatory Guide 1.234 "Evaluating Deviations and Reporting Defects and Noncompliance."
endorses, with clarifications, Nuclear Energy Institute (NEI) 1409, "Guidelines for Implementation of 10 CFR Part 21, Reporting of Defects and Noncompliance, Revision 1 (dated February 2016). NEI 1409 states, in part, that the entity that discovered the deviation or failure to comply has the responsibility to complete the evaluation within 60 days from discovery or submit an interim report if the evaluation cannot be completed within 60 days. In the case concerning the primary containment isolation valves, CR10956992 documented the point of discovery, and started the 60-day clock (which ended on May 15, 2023) to complete the evaluation to make the required 60-day report under 10 CFR 21.21(a)(1) or interim report under 10 CFR 21.21(a)(2). On March 22, 2023, the licensee terminated their 10 CFR Part 21 review following documentation of CR 10958783 that transferred that responsibility to the supplier. As of the completion of this inspection, neither the licensee or the supplier had completed the evaluation.
The inspectors determined that the fleet procedure allowance to terminate any further 10 CFR Part 21 review if the supplier agrees to perform the evaluation was not in accordance with the regulatory requirements, as clarified in the NRC-endorsed NEI guideline. This could, result in the failure of any Southern Nuclear Operating Company, Inc. (SNC) nuclear plant to make reports required by 10 CFR 21.21(a)(1) and/or 10 CFR 21.21(a)(2).
Unresolved Item (URI) 202301103 was opened to determine if the licensee met the requirements of 10 CFR 21.21(a) when LER 05000366/2023001-00 was submitted on April 5, 2023.
Corrective Actions: The licensee entered this issue into the corrective action program.
Corrective Action References: CR 110110968
Performance Assessment:
None
Enforcement:
The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter non-compliance.
Severity: In accordance with Section 2.2.2 of the NRC Enforcement Policy, violations that are less serious but are of more than minor concern and result in no or relatively inappreciable potential safety consequences are characterized as SL IV violations. Furthermore, this violation aligns with NRC Enforcement Policy SL IV Violation Example 6.9.d.13, Failures to implement adequate 10 CFR Part 21 or 10 CFR 50.55(e) processes or procedures that has more-than-minor safety or security significance. Specifically, this inadequate procedure issue has more than minor safety significance because some reportable Part 21 issues may not be evaluated and reported, resulting in substantial safety hazards not being communicated to other affected entities.
Violation: Title 10 CFR 21.21(a) requires, in part, each entity subject to the regulations in this part shall adopt appropriate procedures to evaluate deviations and failures to comply to identify defects and failures to comply associated with substantial safety hazards as soon as practicable in order to identify a reportable defect or failure to comply that could create a substantial safety hazard, were it to remain uncorrected.
Contrary to the above, since January 31, 2017, the licensee, an entity subject to the regulations in this part, did not adopt appropriate procedures to evaluate deviations and failures to comply to identify defects and failures to comply associated with substantial safety hazards as soon as practicable in order to identify a reportable defect or failure to comply that could create a substantial safety hazard, were it to remain uncorrected. Specifically, the licensee adopted procedure NMP-AD028, 10 CFR 21 Evaluations and Reporting Requirements, Ver. 4.0 to evaluate deviations and failures to comply to identify defects and failures to comply associated with substantial safety hazards, and the procedure was inappropriate because it permits the licensee to discontinue 10 CFR Part 21 evaluations if a supplier agrees to perform the evaluation.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Unresolved Item (Open)
Potential Failure to Make a Part 21 Report URI 05000366/202301103 71152B
Description:
In licensee event report (LER) 05000366/2023001-00 the licensee documented that the reason the unit 2 primary containment isolation valves, 2T48F319 and 2T48F320 (F319 and F320) exceeded the maximum allowable leakage (La) was due to incorrectly manufactured T-Rings provided by the original equipment manufacturer. While the LER was submitted timely, it is not clear to the inspectors that the requirements of 10 CFR 21.21(a)have been met. Specifically, 10 CFR 21.21(a) requires, in part, evaluation of deviations to identify defects associated with substantial safety hazards as soon as practicable, and in all cases within 60 days of discovery, to identify a reportable defect that could create a substantial safety hazard, were it to remain uncorrected. In this case, condition report (CR)10956992 documented the point of discovery, and started the 60-day clock (which ended on May 15, 2023) to complete the evaluation to make the required 60-day report under 10 CFR 21.21(a)(1) or interim report under 10 CFR 21.21(a)(2). On March 22, 2023, the licensee terminated their 10 CFR Part 21 review, in accordance with their 10 CFR Part 21 fleet procedure (NMP-AD028), following documentation in CR 10958783 that transferred that responsibility to the supplier. As documented in NCV 202301102 above, the inspectors determined this procedure allowance was inadequate and contrary to the requirements in 10 CFR 21.21(a).
While acknowledging the inappropriate termination of the 10 CFR Part 21 review, the licensee contends that it satisfied the 10 CFR Part 21 evaluation and reporting requirements when it reported the event under LER 05000366/2023001-00, as required by 10 CFR 50.73, Licensee event report system. Specifically, the licensees position is that the LER is consistent with the provisions in 10 CFR 21.2(c) which states that the evaluation of deviations and appropriate reporting of defects under 10 CFR 50.72, and 10 CFR 50.73 satisfies each person's evaluation, notification, and reporting obligation to report defects under 10 CFR Part
21.
The team noted that the statements of consideration for the 1991 rulemaking to revise 10 CFR Part 21 (56FR36081) clarifies that the evaluation and reporting criteria in 10 CFR Part 21 and in 10 CFR 50.72/73 are similar, and duplicate evaluation and reporting is not necessary. It further clarifies that the licensee's evaluation and reporting responsibilities under 10 CFR Part 21 are satisfied by evaluating deviations of basic components, and reporting, if necessary, under 10 CFR 50.72, and 10 CFR 50.73. Although the licensee reported most of the information required for reporting a defect under LER 05000366/2023-001-00, the licensee never conducted a 10 CFR 21 evaluation to determine if the T-Ring manufacturing deviation represented a Defect (i.e., created a substantial safety hazard) to report it completely and appropriately in their 10 CFR 50.73 report. Therefore, the inspectors determined that an Unresolved Item (URI) was necessary to determine if a violation of 10 CFR Part 21 exists. Specifically, to determine if the licensee satisfied the 10 CFR Part 21 reporting requirement with the information provided in LER 05000366/2023001-00 despite never conducting a substantial safety hazard evaluation of the deviation associated with the primary containment isolation valves T-Rings.
Planned Closure Actions: The inspectors do not anticipate the licensee will perform an additional evaluation to determine whether the defect or failure to comply could create a substantial safety hazard were it to remain uncorrected. The NRC needs to review the information the licensee provided in the LER and determine if the licensee met the Part 21 reporting requirements since an evaluation has not been completed by the licensee or supplier.
Licensee Actions: The licensee entered the 10 CFR Part 21 evaluation and reporting concern into the corrective action program.
Corrective Action References: CR 11010974 Licensee-Identified Non-Cited Violation 71152B This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Violation: Units 1 and 2 Technical Specifications 5.4, Procedures, requires, in part, that written procedures shall be implemented for the applicable procedures recommended in Regulatory Guide (RG) 1.33, Appendix A, Revision 2 (February 1978). Section 9.b of Appendix A required in part, preventive maintenance (PM) schedules be developed to specify inspections of equipment. Procedure 42IT-TET-0121/2 (unit 1/unit 2), Plant Service Water and RHR Service Water Piping Inspection Procedure, Rev. 2.14/3.9, required ultrasonic testing (UT) inspections of the residual heat removal service water (RHRSW) system piping to detect loss of material in order to manage the effects of aging during the period of extended operation on the functionality of the system.
Contrary to the above, prior to May 16, 2023 (when a recurring PM task (PMCR 104906) was established to conduct UTs), the licensee failed to establish PM schedules to implement procedure 42IT-TET0121/2 to conduct UT inspections of the RHRSW system piping. The lack of inspections contributed to a loss of material (corrosion), on the RHRSW strainers inlet/outlet piping (on both units), to go undetected. In one instance for unit 1, the loss of material exceeded the minimum wall thickness required by the Code of Record. The licensee identified the lack of UT inspections during the conduct of a causal analysis, CAR 317738, initiated after the loss of material condition was identified on August 3, 2022 (CR10898626).
Significance/Severity: Green. The inspectors assessed the significance of the violation using Exhibit 2, Mitigating Systems Screening Questions, of Inspection Manual Chapter (IMC)0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, issued December 13, 2019. The inspectors concluded this violation is of very low safety significance (i.e., Green) because the finding was related to a deficiency affecting the design or qualification of a mitigating structure, system, or component (SSC); however, the SSC maintained its operability or Probabilistic Risk assessment functionality. Specifically, the licensee performed a structural analysis of the affected pipe and determined that the as-found condition did not affect operability of the system.
Corrective Action References: CRs 10898626, 10901485, and 11010936. CAR 317738.
TE1111665 Minor Violation 71152B SBM Switches Installed Beyond Vendor Recommended Service Life without PM or Evaluation Minor Violation: Units 1 and 2 Technical Specifications 5.4, Procedures, requires, in part, that written procedures shall be implemented for the applicable procedures recommended in Regulatory Guide 1.33, Appendix A, Revision 2 (February 1978). Section 9.b of Appendix A required, in part, preventive maintenance (PM) schedules be developed to specify lubrication schedules, inspections of equipment, replacement of such items as filters and strainers, and inspection or replacement of parts. Contrary to the above, the licensee failed to develop PM schedules or evaluate the lack of PM for single block module (SBM) electrical control switches installed beyond the vendor recommended service life of 29 years.
Screening: The inspectors determined the issue was not more than minor because the licensee was able to demonstrate that the SBM switches maintained their operability.
Enforcement:
This failure to comply with TS 5.4 constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy. The licensee entered the issue into the corrective action program as CR 11010975 and will evaluate the need for a PM on the SBM switches.
Minor Violation 71152B Inadequate Condition Report Description and Inadequate Operability Evaluation Minor Violation: Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XVI, Corrective Action, which requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. NMP-GM002001, Corrective Action Program Instructions, Section 4.1.1.b, requires personnel to initiate a condition report (CR) to identify a condition that needs correcting and to provide sufficient information into the condition details so that the CR may be properly evaluated for operability, reportability, significance, etc. Contrary to the above, CR 10907360 did not adequately identify a potential deficiency associated with single block module (SBM) electrical control switches installed beyond their service life of 29 years because the CR did not contain sufficient information so that the deficiency could be properly evaluated for operability. As a result, an operability evaluation was not completed in accordance with NMP-AD012, Operability Determinations and Functionality Assessments, Ver. 15.0.
Screening: The inspectors determined the issue was not more than minor because the licensee was able to demonstrate that the SBM switches maintained their operability.
Enforcement:
This failure to comply with 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy. The licensee entered the issue into the corrective action program as CR 11010969 and developed an operability evaluation that demonstrated operability of the SBM switches was maintained.
Minor Violation 71152B Failure to Evaluate Supplier Notice in accordance with Procedure Minor Violation: Title 10 of the Code of Federal Regulations (10 CFR) Part 21, Reporting of Defects and Noncompliances, requires, in part, that each entity subject to the regulations in this part shall adopt appropriate procedures to evaluate deviations and failures to comply to identify defects associated with substantial safety hazards as soon as practicable except as provided in paragraph (a)(2) of this section, and in all cases within 60 days of discovery, in order to identify a reportable defect that could create a substantial safety hazard were it to remain uncorrected. Licensee procedure, NMP-AD028, 10 CFR 21 Evaluations and Reporting Requirements, Ver. 7.0, Section 4.3 states that affected licensees that receive a Supplier notice citing 10 CFR21.21(b) MUST perform their own Substantial Safety Hazard Evaluation to determine if the deviation is reportable under 10 CFR21.21(d)." Contrary to the above the licensee failed to implement steps in NMP-AD028 to determine if a deviation was reportable when a supplier notice was received on February 24, 2023, for a pipe elbow Hatch purchased that may have a pipe wall thickness below minimum allowable.
Screening: The inspectors determined the issue was not more than minor because the component described in the suppler notice is installed in a non-safety system and would likely not result in a defect.
Enforcement:
This failure to comply with 10 CFR Part 21 constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy. The licensee entered the issue into the corrective action program as CR 11008563 and initiated actions to determine if a deviation exists associated with the basic component described in the supplier notice.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On September 28, 2023, the inspectors presented the biennial problem identification and resolution inspection results to Mr. Matthew Busch and other members of the licensee staff.
- On November 8, 2023, the inspectors presented the biennial problem identification and resolution inspection results to Mr. Carl Collins and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Condition Reports
(CRs)
10471234, 10709451, 10718722, 10727466, 10730343,
10739420, 10739657, 10759187, 10780090, 10785024,
10791097, 10798797, 10815220, 10819171, 10819217,
10821660, 10821968, 10822988, 10833367, 10834728,
10839282, 10843381, 10844609, 10844615, 10844819,
10844845, 10846128, 10847015, 10847854, 10848260,
10848348, 10858911, 10859147, 10859661, 10866255,
10872024, 10873304, 10874670, 10878308, 10878315,
10881430, 10881767, 10885338, 10885477, 10885764,
10887272, 10888368, 10898626, 10909431, 10910615,
10922514, 10931814, 10933094, 10943376, 10943572,
10945741, 10946189, 10946502, 10946508, 10948362,
10949319, 10951470, 10952899, 10954024, 10955883,
10956481, 10956992, 10957414, 10957536, 10958113,
10958712, 10958783, 10959514, 10959516, 10960409,
10961997, 10964251, 10964880, 10966211, 10966494,
10972211, 10976139, 10976832, 10977386, 10977734,
10977791, 10978188, 10978738, 10978767, 10978890,
10980353, 10980765, 10981654, 10982312, 10982316,
10982775, 10984031, 10984427, 10984777, 10985166,
10986082, 10988086, 1099491, 10947708, 10753270,
10730343, 10709451, 10718722, 10727466, 10739420,
10918171
Corrective Action
Reports (CARs)
278832, 279192, 279706, 285272, 286047, 286507,
297676, 302948, 312130, 317738, 321424, 332462,
359966, 380222, 390477, 398875, 412300, 415463,
2764, 451931,297676, 323625, 310564, 290990,
2664, 282234, 380222, 279720, 304318, 440510,
455398, 412003
71152B
Corrective Action
Documents
Technical Evaluations
(TEs)
1037053, 1072149, 1074089, 1074119, 1074262,
1081994, 1082847, 1088228, 1093501, 1094645,
1094997, 1097182, 1097211, 1097346, 1098677,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
1101404, 1104521, 1105855, 1105901, 1105952,
1106700, 1111665, 1113163, 1114464, 1115379,
1115383, 1115883, 1116116, 1119161, 1119163,
22697, 1124496, 1124599, 1124900, 1124908,
24960, 1125379, 1125949, 1131683, 1020833,
20833, 1099491
Condition Reports
(CR)
11010969, 11005890, 11010975, 11008563
CR 11006417
Small RHRSW pipe section not coated (external)
09/13/2023
CR 11006865
No documentation of resolution of 2A SSAC failure
09/14/2023
CR 11007742
Cause of 2A Station Service Air Compressor not properly
captured on Maintenance Rule database
09/18/2023
CR 11008111
Item Master No. 1375704 (defective T-Ring) not in
Discontinued status
09/19/2023
Corrective Action
Documents
Resulting from
Inspection
CR 11010936
RHRSW Past Operability Review
09/28/2023
D11004
Unit 1 RHR Service Water Outside Building P&ID
Ver. 43.0
H11039
Unit 1 Service Air at High Pressure Air Compressors
Ver. 49.0
H11641
Unit 1 Instrument Air at High Pressure Air Compressors
Ver. 12.0
H11642
Unit 1 Service Air Compressors Closed Loop Cooling
Water System P&ID
Ver. 7.0
H16329
Ver. 84
H16332
HPCI System P&ID-Sheet No. 1
Ver. 68.0
H21028
Unit 2 Control Building Service Air System P&ID-Sheet 1
Ver. 35.0
H21077
Unit 2 Turbine Building Instrument Air System P&ID-
Sheet 1
Ver. 23.0
H26084
Unit 2 Primary Containment Purge and Inerting System
Ver. 42.0
H51161
Unit 2 Station Service Air Compressors Closed Loop
Cooling System P&ID
Ver. 10.0
Drawings
S64989
Fisher 9200 18 Butterfly Valve
Ver. 2.0
Engineering
Changes
SIEE SNC1145270ED
Standard Item Equivalency Process. Replacement of
Unit 2 Fisher 9220 with 9200 Butterfly Valve
Rev. 0
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
SNC497427
Design Change Package (DCP)
8003933FA
Failure Analysis for Woodward UG8D Governor with
Booster Serco Motor
6/5/2023
DOEJ-
HRSNC1358910S001
Minimum Pipe Wall Thickness for 18-inch RHRSW
Piping at the Intake Structure
08/8/2022
RER SNC1358910
Request for Engineering Review (RER). RHRSW Piping
Degradation
08/5/2022
Engineering
Evaluations
SNG10321992
Past Operability Evaluation of a Thinned Section of RHR
Service Water Piping
10/19/2023
Hatch Emergency Preparedness (EP) Alert and
Notification System Excellence Plan
2/02/2021
Emergency Preparedness gaps-drivers-analysis-results
(GDAR) report
November
22
Fairbanks Morse Owners Group Opposed Piston Engine
Maintenance Guidelines-Governor Maintenance and
Recommendations and Good Practices (July 2019)
Rev. 5
ASME Code
ASME Boiler and Pressure Vessel Code,Section III,
Rules for Construction of Nuclear Facility Components,
1967 edition with addenda through 1971
1967
Correspondence
Hagen, M., Emerson Director for Applications
Engineering, letter to Edwin I. Hatch Nuclear Plant. 9200
T-ring Interchangeability,
2/25/2021
IN 202002
NRC Information Notice. Flex Diesel Generator
Operational Challenges
9/15/2020
IN 202101
NRC Information Notice. Lessons Learned from NRC
Inspections of Design-Basis Capability of Power-
Operated Valves at Nuclear Power Plants
05/06/2021
IN 202302
NRC Information Notice. Reporting When a Fixed Gauge
Shutter is Stuck in the Closed Position
3/17/2023
Long Term Action
Management (LTAM)
Items
H170069, H190008, H190053, H230011
Miscellaneous
MRule Basis
Document
Units 1/2, System P51, Station Service Air - Maintenance
Rule SSC Function Consolidation and Performance
10/15/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Criteria Selection
MRule CME
EVT-P512023-20669, 1A Air Compressor Tripped
MRule CME
EVT-P512022-20657, 1A Air Compressor Tripped
MRule CME
EVT-P512022-20650 - 2C Air Compressor on High Oil
Temp
MRule CME
EVT-P512022-20649, 2A Air Compressor Failed
Breaker
MRule CME
EVT-P512022-20649, 2B Air Compressor Fails to Build
Pressure
MRule CME
EVT-P512022-20670, 2A Air Compressor Stuck
Solenoid
MRule Status - P51
System
Maintenance Rule Scoping and Performance Criteria
a(2) Status for Units 1 and 2 Station Service Air (System
P51)
9/13/2023
PMCR 103175
Preventive Maintenance Change Request
PMCR 104906
RHRSW UT Inspection-Service Water Program
05/16/2023
PO SNG10213514
Purchase Order. Fisher 9200 Butterfly Valve
08/03/2021
PO SNG10252022
Purchase Order. Compression Ring and T-Rings
08/03/2021
RER 1496175
Request for Engineering Review
S28566
Vendor Technical Manual. Instruction Manual and Parts
List for Type 9200 T-Ring Butterfly Valve
Ver. 1.0
S77674
Vendor Technical Manual. 9200 Series Adjustable
Elastomer T-Ring Control Valve
Ver. 1.0
S77678
Vendor Technical Manual. Obs Type 9200 T-Ring
Butterfly Valve Bodies
Ver. 1.0
SS2102107
Specification for Primary Containment Isolation Butterfly
Valves for Edwin
- I. Hatch Nuclear Plant, Unit 2
Rev. 1
SX27070
Vendor Technical Manual. RHR Pumps-Maintenance
Instruction and Operating Manual
Rev. A
TR 1015157
EPRI Technical Report. Nuclear Maintenance
Applications Center: Emergency Diesel Generator
Governing System Maintenance Guide for Nuclear
Applications. EPRI, Palo Alto, CA
2007
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
20-001
1A RHRSW pump degraded IST performance
2/23/2022
20-005
1A RHRSW pump degraded IST performance
2/23/2022
Operability
Evaluations20-006
2D RHRSW pump degraded IST performance
08/17/2020
Conditions, Required Actions, and Completion Times
Daily Outside Rounds
Ver. 21.40
HPCI Valve Operability
Ver. 20.1
Plant Service Water and RHR Service Water Piping
Inspection Procedure
Ver. 2.14
Limitorque Valve Operator Electrical Maintenance
Ver. 25.1
RHR Pump and Motor Maintenance
Ver. 9.10
Molded Case Circuit Breaker Testing
Ver. 42.20
Cutler Hammer Low Voltage MCC Inspection (DC)
Ver. 8.2
General Electric Low Voltage MCC Inspection
Ver. 9.2
Purge and Vent Valve T-Ring Replacement
Ver. 12.15
MCCB(s) Protecting Primary Containment Penetration
Conductors
Ver. 8.31
701
EMPLOYEE CONCERNS PROGRAM
NMP-AD012
Operability Determinations. CR 11008563 - potential
deviation in CPS elbow
Version 16.1
NMP-AD012
Ver. 15
NMP-AD028
CFR 21 Evaluations and Reporting Requirements
Ver. 7.0
NMP-AD028F01
CFR 21 Screening/Evaluation
Ver. 5.0
NMP-AD028F02
NRC Notification of a Defect or Deviation in Accordance
with 10 CFR 21.21(D)
Ver. 2.0
NMP-AD028GL01
Guidelines for the Part 21 Applicability Assessment of
Equipment Failures and Nonconforming Conditions
Ver. 4.0
NMP-AD030
Licensee Event Report
NMP-AD031GL02
Reportability Guidelines
Ver. 2.0
NMP-EP310
Maintaining the Emergency Plan
Ver. 11.0
NMP-ES007
Conduct of Engineering
Version 17.3
Procedures
NMP-ES007005
Technical Task Pre-Job Brief, Critical Thinking, and Post
Job Critique
Version 3
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
NMP-ES017020
MOV Electrical Checkout and Adjustment for SMB/SB
Ver. 6.9
NMP-ES069001
Fleet Service Water Program Instructions
Ver. 4.0
NMP-GM002002
Effectiveness Review Instructions
Version 6
NMP-GM006
Work Management
Version 2
NMP-GM008
Operating Experience Program
VERSION
24.0
NMP-HP302003
Hatch Radiation Protection Start-Up Surveillance
Ver. 1.7
NMP-MA014001
Post Maintenance Testing Guidance
Ver. 5.10
NMP-MA053
SNC Maintenance Department Measuring and Test
Equipment Program (M&TE)
Ver. 6.1
NMP-SE006
Security Drill and Exercise Program
Ver. 9.0
NO5111 V10.0
Nuclear Oversight Missed Opportunity Review &
Lessons Learned Evaluation
NOS101
Nuclear Oversight Organization and Responsibilities
Version 10
NOS103
Training and Qualification of Personnel
Version 7
NOS106
Nuclear Oversight Surveillances
Version 7
NOS107
Independent Evaluations of Nuclear Oversight QA
Program and Coordination of Technical Specialists
Version 8
OPS1982
OPS1982, REACTOR MODE CODE TRACKING
SNC Corporate
Guidelines 730002
EMPLOYEE CONCERNS GUIDELINE
Fleet-MNT2021
21 Fleet Maintenance Audit
2/15/2021
Self-
Assessments
Fleet-SEC2022
22 Fleet Security Audit
06/07/2022
SNC No.
(Planned) 1096879, 1336467
Work Orders
SNC No.
(Completed) 0117249, 0144232, 0470174, 0942929,
20432, 1020432, 1083553, 1124759, 1129167,
1153001, 1161853, 1177152, 1191056, 1191056,
1191057, 1191057, 1202158, 1229010, 1230937,
236464, 1281554, 1281554, 1304626, 1329374,
1335474, 1337310, 1337379, 1368285, 1410621,
1419270, 1444073, 1448986, 1450216, 1451860,
1455927, 1455954, 1456692, 1456692, 1476967,
1490842, 1496720, 1499190, 1506813, 1218371TM,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
23546