Text

NRC Inspection Report 05000321/2024010 and 05000366/2024010
	ML24310A171
Person / Time
Site:	Hatch
Issue date:	11/06/2024
From:	Daniel Bacon; NRC/RGN-II/DORS/EB2
To:	Coleman J; Southern Nuclear Operating Co
References
	IR 2024010
	Download: ML24310A171 (10)
	v • d • e

SUBJECT:

EDWIN I. HATCH - NRC INSPECTION REPORT 05000321/2024010 AND 05000366/2024010

Dear Jamie Coleman:

On September 25, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Edwin I. Hatch and discussed the results of this inspection with Matthew Busch and other members of your staff. The results of this inspection are documented in the enclosed report.

No NRC-identified or self-revealing findings were identified during this inspection.

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 violation or the significance or severity of the violation 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.

November 6, 2024 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, Daniel M. Bacon, Chief Engineering Branch 2 Division of Operating Reactor Safety Docket Nos. 05000321 and 05000366 License Nos. DPR-57 and NPF-5

Enclosure:

As stated

Inspection Report

Docket Numbers:

05000321 and 05000366

License Numbers:

DPR-57 and NPF-5

Report Numbers:

05000321/2024010 and 05000366/2024010

Enterprise Identifier:

I-2024-010-0042

Licensee:

Southern Nuclear Operating Co., Inc.

Facility:

Edwin I. Hatch

Location:

Baxley, GA

Inspection Dates:

September 09, 2024 to September 25, 2024

Inspectors:

P. Braaten, Senior Reactor Inspector

R. Easter, Resident Inspector

M. Hagen, Reactor Inspector

S. Sandal, Senior Reactor Analyst

Approved By:

Daniel M. Bacon, Chief

Engineering Branch 2

Division of Operating Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a NRC inspection at Edwin I. Hatch, 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: 3706

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

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

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL 37060 - 10 CFR 50.69 Risk-Informed Categorization and Treatment of Structures, Systems, and Components Inspection The inspectors reviewed the licensees program and implementation of 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors, in accordance with the following procedure sections. Section 02.04 was not completed during this inspection because the feedback and process adjustment required by 10 CFR 50.69(e) was not implemented by the licensee. As of the date of this inspection, two refueling outages have not occurred since system categorization was completed on at least three systems.

Review of the Licensees Programs and Procedures (IP Section 02.01) (1 Partial)

(1)

(Partial)

The team reviewed the licensees programs and procedures to ensure that the procedures fully described the categorization and treatment process for SSCs as described in its UFSAR and as required by 10 CFR 50.69.

Review of the Licensees 10 CFR 50.69 Program Implementation (IP Section 02.02) (1 Partial)

(1)

(Partial)

The team reviewed the licensee's 10 CFR 50.69 categorization process and alternate treatment requirements completed on the following systems:

1. Residual Heat Removal

2. Emergency Diesel Generators

3. Plant Service Water

4. Unit 2 Drywell Cooling Chilled Water

5. Control Rod Drive

6. OpE Smart sample 2023-02 "PRA Configuration Management"

Problem Identification and Resolution (IP Section 02.03) (1 Partial)

(1)

(Partial)

For the systems listed above, the inspectors reviewed the licensees corrective action program to verify that conditions that would prevent RISC-3 SSCs from performing their safety-related function have been corrected. Additionally, the inspector verified that, as appropriate, the licensee performed common cause reviews for RISC-3 SSC deficiencies to ensure that the licensees SSC categorization process remains valid.

INSPECTION RESULTS

Licensee-Identified Non-Cited Violation 37060 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: Edwin I. Hatch license condition 2.C.11 and 2.C.3.i for units 1 and 2 respectively states, in part, " Southern Nuclear Operating Company is approved to implement 10 CFR 50.69 using the processes for categorization of Risk-Informed Safety Class (RISC)-1, RISC-2, RISC-3, and RISC-4 structures, systems, and components (SSCs) specified in the Renewed License Amendment"

10 CFR 50.69 (c)(1) states, in part, "SSCs must be categorized as RISC-1, RISC-2, RISC-3, or RISC-4 SSCs using a categorization process that determines if an SSC performs one or more safety significant functions and identifies those functions. The process must:...(iii)Maintain defense-in-depth."

Procedure NMP-ES-065-003, "10 CFR 50.69 Risk Informed Categorization for Structures, Systems, and Components," version 10, step 4.8, "Defense in Depth Assessment," states, in part, " Assess the role of the components in preserving defense-in-depth related to core damage, large early release, and long term containment integrity, in accordance with the methodology provided in Attachment 1."

1 of procedure NMP-ES-065-003 section 1, "Core Damage Defense in Depth,"

states, in part, "For each design basis event, identify the region of Figure 1 in which the plant mitigation capability lies WITHOUT credit for the function/SSC that has been proposed as low safety-significant, and WITHOUT credit for any identical, redundant SSCs within the system that are also classified as LSS."

Contrary to, since May 17, 2023, the licensee did not adequately demonstrate that defense in depth was maintained without credit for the SSC that was proposed as low safety-significance and without credit for any identical, redundant SSC within the system that are also classified as LSS. Specifically, the site credited manual action of the SSC in question and manual action of an identical and redundant SSC that was also classified as LSS.

Significance/Severity: Green. The issue was screened using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power." The inspectors determined the finding was of very low safety significance (Green) because it was not a deficiency affecting the system design or qualification and it did not represent a loss of system function.

Corrective Action References: CR

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On September 25, 2024, the inspectors presented the NRC inspection results to Matthew Busch and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

CR 11109820

NRC Identified during Hatch 50.69 Inspection: PSW/RHR

RBD Enhancement for Limit Switch Categorization

09/12/2024

CR 11113031

Potential EDG RBD Critical Change

09/23/2024

Corrective Action

Documents

Resulting from

Inspection

CR 11113041

Procedure Enhancement - NMP-ES-065-003, 50.69

Defense-in-Depth Analyses

09/23/2024

H16064 Unit 1

CRD P&ID SH 1

Control Rod Drive System

H16065 Unit 1

CRD P&ID SH 2

Control Rod Drive System

H26006 Unit 2

CRD P&ID SH 1

Control Rod Drive System

Drawings

H26007 Unit 2

CRD P&ID SH 2

Control Rod Drive System

H-RIE-IEIF-U00-

005-005 - CRD

Probabilistic Risk Assessment System Notebook H-RIE-IEIF-

U00-005-005 Control Rod Drive System

HNP C11 RBD