IR 05000321/2019013
| ML19309C978 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 11/05/2019 |
| From: | Alan Blamey NRC/RGN-II/DRP/RPB2 |
| To: | Gayheart C Southern Nuclear Operating Co |
| Alan Blamey RGN-II/DRP/RPB2 | |
| References | |
| IR 2019013 | |
| Download: ML19309C978 (18) | |
Text
November 5, 2019
SUBJECT:
EDWIN I. HATCH NUCLEAR PLANT - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000321/2019013 AND 05000366/2019013
Dear Ms. Gayheart:
On September 27, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Hatch Nuclear Plant, Units 1 and 2. On September 26, 2019 the NRC inspectors discussed the results of this inspection with Mr. Edwin D. (Sonny) Dean Site Vice President and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the plants corrective action program and the plants implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the plant was complying with NRC regulations and licensee standards for corrective action 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 plants processes for use of industry and NRC operating experience information and the effectiveness of the plants 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 plants programs to establish and maintain a safety-conscious work environment and interviewed plant 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.
The NRC inspectors did not identify any finding or violation of more than minor significance. 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 10 CFR 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:
05000321/2019013 and 05000366/2019013
Enterprise Identifier: I-2019-013-0002
Licensee:
Southern Nuclear Operating Co., Inc.
Facility:
Edwin I. Hatch Nuclear Plant
Location:
Baxley, GA
Inspection Dates:
September 08, 2019 to September 26, 2019
Inspectors:
J. Hickman, Resident Inspector
D. Mas-Penaranda, Project Engineer
C. Stancil, Senior Fuel Facility Inspector
T. Su, Reactor Inspector
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.
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 - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)
- (1) The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment.
- Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems.
- Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the plants processes for use of operating experience, audits and self-assessments.
- Safety Conscious Work Environment: The inspectors assessed the effectiveness of the plants programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Assessment 71152B
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 and there was a low threshold for entering issues into the corrective action program. This conclusion was based on a review of the requirements for initiating condition reports as described in licensee procedure NMP-GM-002, "Corrective Action Program," and managements expectation that employees were encouraged to initiate condition reports. Additionally, site management was actively involved in the corrective action program and focused appropriate attention on significant plant issues.
Problem Prioritization and Evaluation: Based on the review of condition reports, the inspectors concluded that problems were prioritized and evaluated in accordance with the condition report significance determination guidance in procedure NMP-GM-002. The inspectors determined that adequate consideration was given to system or component operability and associated plant risk. The inspectors determined that plant personnel had conducted cause evaluations in compliance with the licensees corrective action program procedures and cause determinations were appropriate, and considered the significance of the issues being evaluated.
Corrective Actions: Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the inspectors determined that corrective actions were timely, commensurate with the safety significance of the issues, and effective, in that conditions adverse to quality were corrected. For significant conditions adverse to quality, the corrective actions directly addressed the cause and effectively prevented recurrence. The inspectors reviewed condition reports and effectiveness reviews to verify that the significant conditions adverse to quality had not recurred. Effectiveness reviews for corrective actions to preclude repetition (CAPRs) were sufficient to ensure corrective actions were properly implemented and were effective.
Based on the samples reviewed, the team determined that the licensees corrective action program complied with regulatory requirements and self-imposed standards. The licensees implementation of the corrective action program adequately supported nuclear safety.
2. Operating Experience
The inspectors determined that the station's processes for the use of industry and NRC operating experience information and for the performance of audits and self-assessments were effective and complied with all regulatory requirements and licensee standards. The implementation of these programs adequately supported nuclear safety. The inspectors concluded that operating experience was adequately evaluated for applicability and that appropriate actions were implemented to address lessons learned as needed. 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.
3. Self-Assessments and Audits
The inspectors determined that the scopes of assessments and audits were adequate. Self-assessments were generally detailed and critical. The inspectors verified that condition reports (CRs) were created to document areas for improvement and findings resulting from self-assessments, and verified that actions had been completed consistent with those recommendations. Audits of the quality assurance program appropriately assessed performance and identified areas for improvement. Generally, the licensee performed evaluations that were technically accurate.
4. Safety Conscious Work Environment
Based on interviews with plant staff and reviews of the latest safety culture survey results to assess the safety conscious work environment on site, the inspectors found no evidence of challenges to the safety conscious work environment. Employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
Minor Violation 71152B Minor Violation: The team identified one minor violation of 10 CFR 54.29 (a)(1), Standards for issuance of a renewed license, which states that managing the effects of aging during the period of extended operation on the functionality of structures and components that have been identified to require review under § 54.21(a)(1) is a requirement. Updated Final Safety Analysis Report (FSAR) chapter 18 discusses how the licensee will meet this requirement. Specifically, section 18.2.16(B), Wetted Cable Activities, discusses the commitment to maintain the water level below the routed cable. The licensees failure to maintain water level below the routed cables as described in FSAR was a performance deficiency (PD).
Contrary to this requirement, multiple condition reports (CR) have identified pull boxes, with safety related cables that were submerged. Pull-boxes PB1-AA, PB1-W, PB1-AE, PB1-AM, PB1-AB and PB1-AJ had high water levels that submerged the cables several times during the time frame from 2012 to 2019. Specially, Plant Service Water cable 1P41C001A and 1P41C001C, which routed through pull box PB1-AA, exhibited cable degradation as indicated by the licensees tan delta (TD) test results.
Screening: The inspectors determined the performance deficiency was minor. The PD was determined to be minor because although the cables were known to be repeatedly submerged, the licensee has implemented a PM program that performs TD test on the cables, to monitor degradation and replace the cable to ensure continued operability and functionality of the cable. Also, the team determine that the performance deficiency would not reasonably be viewed as a precursor to a significant event, if left uncorrected, the performance deficiency would not have the potential to lead to a more significant safety concern, the performance deficiency does not relate to a performance indicator that would not have caused the performance indicator to exceed a threshold, and the performance deficiency would not adversely affect the associated cornerstone objective.
Enforcement:
This failure to comply with 10 CFR 54.29 (a)(1) constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
The licensee initiated CR 10649708 to document the condition.
Observation: Corrective Action Program Effectiveness 71152B Operator Burdens, Workarounds, and Control Room Deficiencies
The inspectors performed a review of Operator Burdens, Workarounds, and Control Room Deficiencies. The inspectors observed that the Operations Performance Indicators for Control Room deficiencies were not meeting the goal of less than or equal to eight deficiencies 97% of the time over the past year. The inspectors observed that there continued to be material problems resulting in compensatory actions affecting Operators, as documented in CRs during this period. Although there were no defined workarounds, there were numerous compensatory action requirements due to plant and control room deficiencies (Unit 1 with 15 and Unit 2 with 16) which created a cumulative impact to the operators. In October of 2018 the Corporate Functional Area Manager identified that Hatch did not perform the quarterly Aggregate Operator Impact review (CR 10546353), which would assess these cumulative impacts. The inspectors reviewed the 2018 fourth quarter Aggregate Operator Impact review and found the assessment conclusions did not detail the nature of the impact, the expected actions that would reduce the impact, or whether the work order priority was raised for four assessment areas rated as Yellow, as required by NMP-OS-006-002, Aggregate Operator Impact Review Instruction Version 2.2. The inspectors review of the 2019 second quarter Aggregate Operator Impact Review identified the licensees review, again did not detail the nature of the impact and actions to reduce the impact for five Yellow and one Red rated assessment areas (CR 10649106). Additionally, a Red rated assessment area also requires a condition report, which was not generated (CR 10647593).
These issues were captured in the licensees corrective action program under the condition reports (CR) listed above.
The inspectors reviewed a cause determination report summary for a Nuclear Safety Review Board area for improvement that created a corrective action to review the Aggregate Operator Impact assessment with the operators monthly (CAR 276602), which should assist in establishing a detailed impact to operators and work order priorities.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On September 26, 2019, the inspectors presented the biennial problem identification and resolution inspection results to Mr. Edwin D. (Sonny) Dean Site Vice President and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective
Action
Documents
Condition Report
(CR) 10322670,
1035672,
10376061,
10382838,
10382949,
10384058,
10394854,
10398751,
10423345,
10436191,
10439652,
10439685,
10440145,
10441129,
10443004,
10445377,
10446627,
10452310,
10455235,
10458608,
10458693,
10460506,
10460865,
10461039,
10462099,
10463114,
10463685,
10471189,
10482986,
10483331,
10490316,
10490318,
10491460,
10494315,
10497330,
10503641,
10504996,
10506730,
10508514,
10509191,
10509236,
10509253,
10509935,
10512351,
10524244,
10525213,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
10525233,
10525236,
10525887,
10526197,
10539657,
10540144,
10546353,
10548933,
10574618,
10574782,
10577264,
10579200,
10579232,
10579960,
10580065,
10582456,
10583074,
10585063,
10585867,
10585783,
10585867,
10586270,
10588709,
10591143,
10591504,
10592769,
10594302,
10594633,
10594635,
10599418,
10594968,
10601829,
10603492,
10603955,
10604132,
10607734,
10610185,
10610186,
10610196,
10611235,
10612038,
10616583,
10617753,
10619230,
10619830,
10620210,
10620226,
10620227,
10625975,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
10627164,
10627536,
10628350,
10634922,
10635643,
10635649,
10635842,
10638972,
10639059,
10641139,
10645239,
10848082
Corrective Action
Reports (CAR)
268718, 272275,
273910, 275619,
275824, 275864,
275939, 275982,
276602
CR 10582457,
10556842
TE 1030941
Licensee Identified Violation
(LIV) from 4Q18 Integrated
Inspection
CRs: 10443379,
896726
Tan Delta Plots:
NMP-ES-051-002,
1C PSW Pump -
1P41C001C New,
1D PSW Pump -
1P41C001D new,
1E11C001A - R22-
S005-ES1-M01,
1E11C001A 2017-
-08-30,
1E11C001B,
1E11C001B - R22-
S0007-ES2-M01,
1E11C001C,
1E11C001C 2019-
05-09,
1E11C001D,
1E11C001D
Withstand,
1E11C002A - R22-
S005-ES1-M05,
1E11C002A 2018-
Pull boxes discovered with
higher than acceptable
water levels during weekly
inspection
2/28/2017
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
01-31,
1E11C002B - R22-
S007-ES2-M05,
1E11C002B 2018-
2-14,
1E11C002C -
R22-S006-ES2-
M07, 1E11C002C
2018-02-01,
1E11C002D -
R22-S006-ES1-
M05, 1E11C002D
2018-02-14,
1E21C001A - R22-
S005-ES1-M07,
1E21C001A 2018-
01-28,
1E21C001B - R22-
S007-ES-M006,
1P41C001A - R22-
S005-ES1-M02,
1P41C001A 2018-
04-10,
1P41C001A 2018-
04-10 Tan Delta,
1P41C001A
Withstand Test,
1P41C001B - R22-
S007-ES2-M03,
1P41C001B - R22-
S007-ES2-M03,
1P41C001C,
1P41C001D,
1E11C001D
Phase B 2018-08-
17, 2E11C001A,
2E11C001C,
2E11C002A -
EAE187M01,
2E11C002A 2019-
01-28,
2E11C002B,
2E11C002BC002B
2019-02-01,
2E11C002C,
2E11C002C 2019-
01-30,
2E11C002D,
2E11C002D 2019-
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2-17,
2E21C001A,
2E21C001A 2019-
01-31,
2E21C001B,
2E21C001B 2019-
2-19,
2P41C001A 2010-
11-29,
2P41C001A 2018-
03-25,
2P41C001C -
PUE137M02,
2P41C001C short,
R22-S007-ES-M02
Phase B,
Corrective
Action
Documents
Resulting from
Inspection
10649708
Cables Submergence in
Various Pull Box
09/26/2019
Condition Report
(CR) 10645352,
10645692,
10647593,
10649106,
10649651
Drawings
B-28015
Unit 1 and 2 Isometric Drain
Lines for Att 5 Racks
Revision 0
B-45555
Seismic Configuration
Control Requirements
Version 3.0
H-16062
Nuclear Boiler System
Version
57.0
H-16332
Unit No. 1 HPCI System
Version
67.0
H-23352
Single Line Drawing
Emergency Station Service
Ver. 24.0
H-23358
Single Line Diagram 4160 V
Bus 2 G
Revision
21.0
H-23362
Single Line Diagram 600 V
Bus 2C & 2D
Version
39.0
H-26020
Unit No. 2 HPCI System
Version
2.0
H26015
Version
60.0
Engineering
Changes
C102092301E001
Airlock R311A Door Strike
Minor Modification
Version 1.0
NMP-ES-084-001-
F20
Configuration Change
Evaluation: LED Lighting
Project RX Bldg U1
Version 2.0
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Diagonals, 130', 228'
1042136, TE
1042137, TE
1042138, TE
1042139, TE
1042141, TE
1045856, TE
1048493
(CAR) 275842
Work Orders, SNC
1000764, SNC
1000804, SNC
1000857, SNC
1000858, SBC
1000859, SNC
1000860, SNC
1000861, SNC
1000862, SNC 1---
880, SNC
1001043, SNC
1001132, SNC
1001133
associated with 2R23-S004
'2D' Bus Tripped
Engineering
Evaluations
1040661, TE
1039100, TE
1043387, TE
1042852, TE
1044112, TE
1044113, TE
1044114, TE
1044115, TE
1044116, TE
1044118, TE
1044119, TE
1044129, TE
1044131, TE
1044131,
Miscellaneous
Lighting Plan Maintenance
Update
08/20/2019
Maintenance Rule Expert
Panel Meeting Agenda
09/17/2019
CRD Daily Counts
09/24/2019
HPCI System Health Report Current
LER 2018-03
SRV As Found Testing
Results Out of Tolerance
Revision 00
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Application to Revise
Technical Specifications to
Adopt TSTIF-542, Reactor
Pressure Vessel Water
Inventory Control
04/20/2017
PMCR 88060
Create storage PM for item
2239
05/25/2017
TE 1042135
Fatigue Management
Program Review
5/6/2019
Operability
Evaluations
PDO 1-10-02
Wetted Cables
Revision 3
PDO 1-17-003/2-
17-004
Prompt Determination of
Operability for 23 Safety
Related Breakers failed to
close on demand
10/24/2018
PDO 1-18-006
Prompt Determination of
Operability for Steam Leak
Supply Outboard PCIV
Rev. 0
PDO 2-18-002
Prompt Determination of
Operability of Unit 2 RHR.
while performing 34SV-
E11-001-2, when RHR
pump was started the min
flow valve went closed an
then back open.
2/01/2018
Procedures
Version 3.3
ARP's For Control Panel
Version No:
20.1
Automatic Depressurization
System (ADS)
Version
2.12
BETTIS 522C-SR Actuator
Corrective Maintenance
Version 4.3
Unit 1 Secondary
Containment Doors
Preventive Maintenance
Version 9.2
Pan Assembly Cleaning
and Inspection
Version 8.5
SRM Detector Testing
Version 5.0
SRM Detector Testing
Version
%.0
IRM Detectpr Testing
Version 3.3
IRM Detector Testing
Version 3.3
AG-MGR-01-0783
Processing Administrative
Guidelines and
Departmental Instructions
Version 6.2
AG-MGR-68-
200N
Climbing On Plant
Equipment
Revision 2
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Regulatory Assessment
Performance Indicator
Guideline
Revision 7
NMP -AD-006
Infrequently Performed
Tests and Evolutions
Version
2.8
NMP-ES-006
Preventive Maintenance
Implementation and
Continuing Equipment
Reliability Improvement
Version
10.1
NMP-ES-027
Version
10.0
NMP-ES-051
Cable Monitoring Program
Version 9.1
NMP-ES-051-004
Pull Box Inspection
Procedure
Version 5.2
NMP-GM-002
Corrective Action Program
Version
15.1
NMP-GM-002-001
Corrective Action Program
Instructions
Version
38.1
NMP-GM-002-002
Effectiveness Review
Instructions
Version 5.2
NMP-GM-002-
GL03
Cause Analysis and
Corrective Actions
Guideline
Version
30.0
NMP-OS-006-002
Aggregate Operator Impact
Review Instruction
Version 2.2
Industry Guideline for
Monitoring the
Effectiveness of
Maintenance at Nuclear
Power Plants
Revision
4A
OS-BP-001
Operations Performance
Indicators
Version 4.6
Self-
Assessments
HNP Aggregate Impact
Review for 4th Quarter
2018
Version 0
HNP Aggregate Impact
Review for 2nd Quarter
2019
Version 0
Work Orders
SNC1024503
Repair leak on HPCI Room
cooler
06/03/2019
SNC440323
Airlock R311A Door Strike
Modification
10/28/2019
SNC841609
Airlock R311A Horn and
MCR Alarm
08/03/2017
SNC880463
Airlock R311A Lights
01/25/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Malfunctioning
SNC891848
Tech Spec 3.3.5.1-1(3d)
has been identified as non-
conservative, CST Level
Switch (Swapover)
08/28/2017
SNC922120
Investigate Unit 2 "A" RHR
Minimum Flow Valve
09/27/2018
SNC926414
Airlock R311A Door Won't
Stay Closed, Failed
Interlock
07/21/2018
SNC947221
Repair Concrete Removed
for UT Inspection around
U1 Core Spray Suction Line
at CST
5/22/2018
SNC955966
Repair of Insulation near
1E41F3025