IR 05000366/2022003
| ML22311A470 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 11/08/2022 |
| From: | Alan Blamey NRC/RGN-II |
| To: | Gayheart C Southern Nuclear Operating Co |
| References | |
| IR 2022003 | |
| Download: ML22311A470 (22) | |
Text
SUBJECT:
EDWIN I. HATCH - INTEGRATED INSPECTION REPORT 05000321/2022003 AND 05000366/2022003
Dear Cheryl A. Gayheart:
On September 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Edwin I. Hatch. On October 19, 2022, the NRC inspectors discussed the results of this inspection with Johnny Weissinger, Site Vice President, and other members of your staff.
The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
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 an 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.
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.
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 November 8, 2022 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. DPR-57 and NPF-5
Enclosure:
As stated,
Inspection Report
Docket Numbers:
05000321 and 05000366
License Numbers:
Report Numbers:
05000321/2022003 and 05000366/2022003
Enterprise Identifier:
I-2022-003-0018
Licensee:
Southern Nuclear Operating Company, Inc.
Facility:
Edwin I. Hatch
Location:
Baxley, GA
Inspection Dates:
July 01, 2022 to September 30, 2022
Inspectors:
A. Alen, Senior Project Engineer
T. Fanelli, Senior Reactor Inspector
J. Hickman, Resident Inspector
M. Magyar, Reactor Inspector
T. Morrissey, Senior Resident Inspector
C. Safouri, Senior Project Engineer
R. Smith, Senior Resident 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 an integrated inspection at Edwin I. Hatch, Units 1 and 2, 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 (NCV) is documented in report section: 71111.0
List of Findings and Violations
Failure to Periodically Test Molded Case Circuit Breakers Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000321,05000366/2022003-01 Open/Closed
[H.14] -
Conservative Bias 71152A An NRC-identified Green NCV, involving two examples of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to implement corrective actions to periodically test molded case circuit breakers (MCCBs) in order to promptly identify and correct performance degradation, including potential age-related degradation, of MCCBs.
Additional Tracking Items
None.
PLANT STATUS
Unit 1 began the inspection period at 100 percent rated thermal power (RTP). On September 3, 2022, the operators reduced power to 65 percent RTP for a rod pattern adjustment and quarterly turbine valve testing. On September 5, 2022, the operators returned the unit to 100 percent RTP. The unit operated there for the remainder of the inspection period.
Unit 2 began the inspection period at 100 percent RTP. On August 20, 2022, the operators reduced power to 75 percent RTP for a rod pattern adjustment and returned the unit to 100 percent RTP the same day. On September 10, 2022, the operators reduced power to 65 percent RTP for a rod pattern adjustment and quarterly turbine valve testing. On September 11, 2022, the operators returned the unit to 100 percent RTP. On September 23, 2022, the operators reduced power to 87 percent RTP for a rod pattern adjustment and returned the unit to 100 percent RTP the same day. The unit 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/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 performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. 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.
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) Unit 2 C emergency diesel generator (EDG) system following testing, using 34SO-R43-001-2, on August 22-24, 2022.
- (2) Unit 1 control rod drive (CRD) hydraulic system following repairs to the 1B CRD pump seal leak, using 34SO-C11-005-1, on August 25-26, 2022.
- (3) Unit 2 B loop residual heat removal service water (RHRSW) system following the replacement of 2D RHRSW pump and motor, using 34SO-E11-010-2, on September 26, 2022.
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the Unit 2 core spray (CS) system from July 12 through 14, 2022.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (6 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) Intake structure on 111-foot elevation on July 18, 2022.
- (2) Unit 2 reactor building 158 and 164-foot elevations on July 20, 2022.
- (3) Unit 1 condensate storage tank, fire pump house, and units 1 and 2 service water valve pits on August 4, 2022.
- (4) Unit 1 reactor building 185-foot elevation on August 12, 2022.
- (5) Control building 147-foot elevation, including units 1 and 2 cable spreading room and plant computer room on August 18, 2022.
- (6) Unit 2 radiological waste building 132-foot elevation on September 16, 2022.
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)
The inspectors evaluated internal flooding mitigation protections in the:
- (1) Units 1 and 2 reactor buildings emergency core cooling corner rooms, units 1 and 2 west cable way, and a review of licensee actions to NRC-issued information notices addressing internal flooding at nuclear plants.
71111.07SIX - Heat Exchanger/Sink Performance Ultimate Heat Sink Containment Device and Dam (IP Section 03.05)
The inspectors evaluated the ultimate heat sink performance containment device and dam on the following:
- (1) Service water intake structure and Altamaha River
71111.07T - Heat Exchanger/Sink Performance Heat Exchanger (Service Water Cooled) (IP Section 03.02)
The inspectors evaluated heat exchanger performance on the following:
- (1) Unit 1 A high pressure coolant injection (HPCI) pump room cooler (1T41B005A)
- (2) Unit 2 B residual heat removal (RHR) heat exchanger (2E11B001B)
- (3) Unit 2 B reactor core isolation cooling (RCIC) system room cooler (2T41B004B)
Ultimate Heat Sink (IP Section 03.04) (1 Sample)
The inspectors evaluated the ultimate heat sink performance on the following:
- (1) Service water intake structure and Altamaha River
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 main control room during a unit 2 rod pattern adjustment, on August 20, 2022.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated licensed operators respond to License Operator Requalification Program scenario H-LT-AF-CPE-00112, "Crew Performance Evaluation Design - Electrohydraulic Control, Reactor Feed Pump Turbine Oil Temperature Controller, Condenser Vacuum, Adjustable Speed Drive Cell, Scram Discharge Volume, and Anticipated Transient Without Scram," on July 11, 2022.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components remain capable of performing their intended function:
- (1) Unit 2 hydrogen/oxygen analyzer system, P33-01, due to maintenance rule condition monitoring events being exceeded, on August 2, 2022.
- (2) Review of Hatchs living (i.e., continuous) 10CFR50.65 a(3) documentation package with emphasis on unit 1 A plant service water pump, unit 2 primary containment isolation valves, and containment cooling system being monitored under 10CFR50.65 under a(1) status, on August 1, 2022.
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (5 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 risk due to HPCI system maintenance, on July 14, 2022.
- (2) Units 1 and 2 elevated risk due to performance of fire main system surveillance with existing system failures, on July 22, 2022.
- (3) Unit 2 elevated risk due to the A CS system maintenance outage, on August 30, 2022.
- (4) Unit 1 elevated risk due to emergency lighting relay fire in main control room, on September 14, 2022.
- (5) Units 1 and 2 elevated risk due to Hurricane Ian, the week of September 26, 2022.
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (8 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Condition report (CR) 10897512, loud knocking sound in bay 12 of unit 2 torus potentially caused by leak-by of the E safety relief valve.
- (2) CR 10899243, unit 2 "Diesel Gen B Loading Timer Failure," resulting in potential inoperability of the 1B (swing) EDG for a loss of coolant accident (LOCA) or loss of offsite power (LOSP) or LOCA/LOSP.
- (3) CR 10895096, unit 1 torus to drywell vacuum breaker, 1T48-F323F, would not close during testing.
- (4) CR 10895145, unit 1 RHRSW pump seal water piping detaching; and CRs 10898218 and10898626 for units 1 and 2 RHRSW piping degradation.
- (5) CR 10899388, unit 2 RHRSW pump flow dropped from 4300 gallons per minute (gpm) to 2700 gpm during torus cooling operations.
- (6) CR 10905959, unit 1 B EDG relays exceeded 10-year replacement criteria.
- (7) CR 10905054, unit 1 reactor pressure low analog transmitter trip system (ATTS)instrument failed to the lower end of the scale.
- (8) CR 10910753, unit 2 RHR minimum flow valve, 2E11-F007B, did not operate properly.
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Temporary modification to install a temporary supplemental cooling on the unit 2 CRD piping supplying the seal purge flow to the shaft seal cavity of the 2B reactor recirculation pump.
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (7 Samples)
The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:
(1)57SV-SUV-012-1, ATTS Panel 1H11-P926 Channel FT&C, following the replacement of the HPCI exhaust diaphragm high pressure ATTS card, on July 28, 2022.
(2)34SO-R42-001-2, "125 Volts Direct Current (VDC) and 125/250 VDC System,"
following cleaning, calibration, and fan replacement of the unit 2 division II station service battery charger F, on July 29, 2022.
(3)57SV-R43-001-2, "Testing the LOCA/LOSP Timer Card," following replacement of the
==2R43 N782B card, on August 11, 2022.
(4)==
42SP-07-20-22-RS-1-1, "Diesel Fire Pump Engine Replacement Functional Test,"
following the replacement of the 1X43-C002B engine, the weeks of August 15, 22, and 29, 2022.
(5)34SO-E21-001-2, "Core Spray System", section 4.3.1, B loop CS manual startup, following unit 2 A CS system maintenance outage, on August 31, 2022.
(6)57SV-R43-001-2, "Testing The LOCA/LOSP Timer Cards," following the K7 relay replacement on the unit 2 B EDG loading timer, on September 2, 2022.
- (7) Work Order SNC1340018, computer processing unit replacement in the unit 2 B recirculation adjustable speed drive, on September 10, 2022.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:
Surveillance Tests (other) (IP Section 03.01) (2 Samples)
(1)34SV-P41-001-1, "Plant Service Water Pump Operability," Version 15.3 (section 7.2, "PSW 'A' Loop"), on July 12, 2022.
(2)34SV-E11-004-2, "RHR Service Water Pump Operability", Version 19.2, on September 7, 2022.
Inservice Testing (IP Section 03.01) (1 Sample)
(1)34SV-E51-002-1, "RCIC Pump Operability," Version 29.2 (sections 4.2, "Operability Test" and 4.3, "RCIC IST Test"), on July 6, 2022
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)
- (1) Emergency preparedness off-year exercise involving a LOCA, on July 26,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS06: Emergency AC Power Systems (IP Section 02.05)===
- (1) Unit 1 (July 1, 2021-June 30, 2022)
- (2) Unit 2 (July 1, 2021-June 30, 2022)
MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)
- (1) Unit 1 (July 1, 2021-June 30, 2022)
- (2) Unit 2 (July 1, 2021-June 30, 2022)
MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)
- (1) Unit 1 (July 1, 2021-June 30, 2022)
- (2) Unit 2 (July 1, 2021-June 30, 2022)
71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) Testing and replacement schedule for safety related molded case circuit breakers were not being followed in accordance with Institute of Electrical and Electronics Engineers (IEEE) 308-1971 standards (CR 10625944).
INSPECTION RESULTS
Licensee-Identified Non-Cited Violation 71111.05 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program (CAP) and is being treated as a non-cited violation (NCV), consistent with Section 2.3.2 of the Enforcement Policy.
Violation: The licensee identified an NCV of Technical Specification 5.4.1.a which required applicable procedures per Regulatory Guide 1.33 Appendix A section 1.l, shall be established, implemented, and maintained covering Fire Protection Program activities. Contrary to this, prior to identifying the issue on August 19, 2022, the licensee failed to establish and maintain fire protection program procedure 42SV-FPX-021-0, Surveillance Of Swinging Fire Doors, Revision 1.20, for inspecting fire doors. Specifically, the licensees procedure did not ensure the flush bolts for the inactive leaf of a double fire door were properly engaged. As a result, the unit 2 A emergency diesel generator (EDG) room door, 1L48-D135, was identified as non-functional on August 17, 2022. The licensee initiated hourly roving fire watches for this fire door and placed the door in their corrective maintenance process to restore the affected fire door. The issue was placed in the CAP on August 19, 2022.
Significance/Severity: Green. The inspectors assessed the significance of the finding using guidance in IMC 0609, Appendix F, Fire Protection Significance Determination Process, and determined the finding to be of very low safety significance because there was an adequate automatic suppression system inside the EDG room.
Corrective Action References: Condition reports (CRs) 10901837, 10902255 Failure to Periodically Test Molded Case Circuit Breakers Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000321,05000366/2022003-01 Open/Closed
[H.14] -
Conservative Bias 71152A An NRC-identified Green non-cited violation (NCV), involving two examples of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to implement corrective actions to periodically test molded case circuit breakers (MCCBs) in order to promptly identify and correct performance degradation, including potential age-related degradation, of MCCBs.
Description:
The updated final safety analysis report (UFSAR) for Hatchs unit 1 (Section 8.3.7) and unit 2 (Section 8.3.1.2.1.C Part 3) states that periodic equipment tests (applicable to MCCBs) are performed at scheduled intervals to detect deterioration of the system toward an unacceptable condition and to demonstrate that standby power equipment and other components that are not exercised during normal operation of the station are operable.
Additionally, the licensee committed to (in the UFSAR for unit 2) testing and surveillances of MCCBs in accordance with the Institute of Electrical and Electronics Engineers (IEEE)standards 308-1971, IEEE Standard Criteria for Class 1E Power Systems for Nuclear Power Generating Stations. Sections 5.2.2 and 5.3.2 for alternating current and direct current distribution systems, respectively, specify in part, that the distribution systems shall be monitored to the extent that it is shown to be ready to perform its intended function. Also, Section 5.4, Vital Instrumentation and Control Power Systems, specifies in part, that dependable power supplies are required for the vital instrumentation and control systems of the unit(s), and Section 6, Surveillance Requirements, specifies in part, that tests shall demonstrate that the equipment operates within design limits and that the system is operational and can meet its performance specifications. Testing can reveal whether degradation has occurred or is occurring that could potentially impact the operability of the load served by the MCCB. Additionally, testing can also identify age-related degradation of the MCCB, such as the potential for hardening of the lubricant used internally to the MCCB as identified by industry operating experience.
Example 1:
In March 2012, during an engineering assessment, the licensee identified that it did not have a test program for the majority (approximately 750 breakers) of its safety-related MCCBs in accordance with the UFSAR and IEEE standards identified above. Many breakers were beyond their 20-year life expectancy, installed in the early 1970s during initial construction, and had not been tested since installation. The licensee identified this issue as a condition adverse to quality (i.e., nonconformance condition) and captured it in the corrective action program (CAP) under condition report (CR) 431380. The licensee initiated a corrective action technical evaluation (TE) 351918 where it documented corrective action plans to replace obsolete breakers and then replace breakers periodically instead of testing. This TE was subsequently closed in May 2012 to a new TE (TE413574) to track and initiate activities to replace the affected breakers. In April 2015, during a second engineering self-assessment, the licensee initiated CR10059075 after identifying that the corrective actions from 2012 (CR431380 and TE413574) were not implemented. The licensee initiated a series of new TEs to establish a testing program, establish PMs to perform the testing, and replace obsolete breakers and distribution panels. TE 930308 tracked actions to ensure all safety related MCCBs located in motor control centers (MCC) were tested within 6 years (complete by 2021), TEs 939734 and 939740 tracked the development of maintenance instructions to test MCCBs in both MCCs and distribution panels, and TE 930309 tracked the replacement of distribution panels planned to begin in 2017. In July 2019, during a third engineering self-assessment, the licensee identified that the corrective actions from 2015 had not been implemented, specifically, no preventive maintenance testing or work orders (WOs) had been created and no replacement distribution panels had been designed or procured. The licensee again entered the failure to take corrective actions in their CAP under CR 10625944. The inspectors determined that between 2012 and 2019 the licensee failed to develop and implement a test program (i.e., corrective actions) for MCCBs. These were corrective actions the licensee acknowledged and documented were needed after identifying the periodic testing nonconformance in 2012 and again in 2015.
Example 2:
The inspectors reviewed the licensees progress towards restoring compliance with the MCCB test requirements since it last identified it in 2019. The inspectors noted that as of September 2022 the licensee had only tested 33 (of approximately 750) in-service MCCBs.
When the licensee began testing in 2019 it deferred testing of in-service MCCBs due to a high number of spare MCCB failures (WOs SNC898390, SNC900113, SNC915932). These failures meant that replacements were not available for in-service MCCB test failures.
Although the licensee determined that the cause of the spare failures may not affect the in-service failure rate, which was not as high as the spares (December 2021 - CR 10845767),the licensee stopped testing in-service MCCBs despite having adverse trend data suggesting MCCBs were in an age degraded state due to being in operation far beyond their design life.
The licensee resumed testing in 2022 after determining the cause of the high failure rate of the spare MCCBs. However, the inspectors noted that in subsequent testing, documented in WOs: SNC900103, SNC900100, and SNC900095, the licensee continued to defer testing of in-service MCCBs. Specifically, 9 out of 35 MCCBs scheduled to be tested in the referenced WOs were not tested due to not having a replacement available.
The licensees Quality Assurance Program is described in topical report SNC-1, Quality Assurance Topical Report (QATR). The QATR describes the quality assurance program and administrative control requirements established to meet 10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants. In establishing provisions for corrective action, and compliance with Criterion XVI of 10 CFR Appendix B, SNC commits to comply with Basic Requirement 16, Corrective Action, of ASME NQA-1-1994, Quality Assurance Requirements for Nuclear Facility Applications. Basic Requirement 16 requires, in part, that conditions adverse to quality shall be identified promptly and corrected as soon as practical. The inspectors determined that deferring MCCB testing due to parts availability (particularly considering the long-standing nature and awareness of this issue) was inadequate and inconsistent with correcting a CAQ (lack of testing) as soon as practical.
Corrective Actions: The licensee entered the issue into their CAP as CR 10915674 to ensure testing is conducted regardless of breaker replacement availability. Also, CR10915161 was initiated to create WOs to test MCCBs for which testing has been deferred. Lastly, TE 1112637 will develop and support a test plan to ensure MCCBs are tested at the next available opportunity.
Corrective Action References: CRs 10915674, 10915161, 10916115, and TE 1112637
Performance Assessment:
Performance Deficiency: The failure to implement corrective actions to test MCCBs in accordance with IEEE 308 standards in order to promptly identify and correct degradation, including aging degradation, of MCCBs was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The failure to establish a test program and use it to detect and correct degradation in safety related MCCBs adversely affects the reliability and availability of mitigating systems and could cause undesirable consequences.
Significance: Although the MCCBs associated with this performance deficiency affected systems and components in both the Mitigating Systems and the Containment Barrier Cornerstones, the number of mitigating systems affected was significantly higher than the systems associated with the Containment Barrier; therefore, the Mitigating Systems Cornerstone was used to evaluate the significance of the finding. In accordance with NRC Inspection Manual Chapter (IMC) 0609, Attachment 4, Initial Characterization of Findings, the inspectors assessed the significance of the finding using the mitigating systems screening questions from Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power. The finding screened as very low safety significance (Green) because the finding was a qualification deficiency that did not result in loss of operability or functionality. Specifically, the licensee determined it had reasonable assurance of operability (CR10852218) regarding untested MCCBs based on results of MCCB tested to-date, operating experience, and the determination that the cause for the high failure rate of spare breakers did not impact in-service breakers.
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. The licensees decision making did not act prudently to ensure MCCBs were tested to be safe to use in order to proceed, rather they allowed the use of untested MCCBs, which were beyond their design life, simply because spares were unavailable and work instructions allowed it.
Enforcement:
Violation: 10 CFR 50, Appendix B, Criterion XVI, Corrective Actions, requires in part, that measures shall be established to assure that conditions adverse to quality, such as a nonconformances, are promptly identified and corrected.
In SNC-1, Quality Assurance Topical Report (QATR), Version 25.0, the licensee committed to implement Basic Requirement 16, Corrective Action, of the American Society of Mechanical Engineers (ASME) NQA-1-1994, Quality Assurance Requirements for Nuclear Facility Applications, to comply with 10 CFR 50, Appendix B, Criterion XVI. Basic Requirement 16, Corrective Action, of ASME NQA-1-1994 requires in part, that conditions adverse to quality shall be identified promptly and corrected as soon as practical.
Contrary to the above, since March 2012, the licensee identified a condition adverse to quality associated with the lack of MCCB testing, a nonconforming condition, but failed to implement measures to assure the condition was promptly identified and corrected.
Specifically, as identified in 2015 and 2019, the licensee repeatedly failed to establish a test program for MCCBs. Furthermore, since the licensee began testing in 2019, the deferral to test MCCBs, which were beyond their service life, due to parts availability was inadequate and inconsistent with correcting the nonconformance as soon as practical. Approximately 10 years after the licensee identified (March 2012) the nonconforming condition only a small population of MCCBs have been tested.
Enforcement Action: This violation is being treated as an NCV, 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 July 27, 2022, the inspectors presented the heat sink performance inspection results to Johnny Weissingner, Site Vice President (SVP) and other members of the licensee staff.
On October 19, 2022, the inspectors presented the integrated inspection results to Johnny Weissinger, SVP, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
Condition Reports (CR)
10628284, 10632635, 10635610, 10644674,
10661058, 10694204, 10695300, 10705032,
10706311, 10706501, 10709640, 10713284,
10713434, 10713709, 10714302, 10729116,
10733813, 10734322, 10739735, 10755977,
10756457, 10767210, 10771203, 10772070,
10773140, 10773366, 10774313, 10774993,
10776756, 10776800, 10776816, 10777640,
10778063, 10778614, 10778614, 10778635,
10778819, 10778940, 10778979, 10779210,
10780003, 10782516, 10782790, 10785605,
10786941, 10786942, 10789793, 10801026,
10803252, 10807247, 10808377, 10826311,
10829392, 10831704, 10839522, 10846527,
10847035, 10861205, 10871869, 10877955,
10885863, 10887149, 10889038, 10889039
Corrective Action
Documents
Condition Reports (CR)
10823143, 10835132, 10835365, 10838266,
10840019, 10847448, 10847489, 10847705,
10848122, 10855525, 10866214, 10868463,
10868678, 10868924, 10869381, 10869482,
10869566, 10869866, 10870090, 10870117,
10870147, 10870156, 10870165, 10876258,
10876581, 10879799, 10884793, 10892133,
10896398
Drawings
H-24739
Unit 2 Core Spray System Logic Diagrams Sheet 1 of
6.0
Drawings
H-24740
Unit 2 Core Spray System Logic Diagrams Sheet 2 of
Drawings
H-26018
Unit 2 Core Spray System P&ID
40.0
Drawings
H-26046
Reactor & Radwaste Buildings - Condensate Storage
& Transfer System Diagram
50.0
Drawings
H16065
Control Rod Drive Hydraulic System P&ID Sheet 2
50.0
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
Control Rod Drive Hydraulic System
34.0
Procedures
Residual Heat Removal System
45.0
Procedures
Core Spray System
26.6
Procedures
Diesel Generator Standby AC System
30.8
Procedures
NMP-ES-012-001
Inspection of Heat Exchangers (2R43-B002C - 2C
2.1
Work Orders
Work Orders (SNC)
1145215, 1145516, 1078706
Corrective Action
Documents
Resulting from
Inspection
Condition Report (CR)
10895572
Fire Plans
NMP-ES-035-019-GL02-
F03
Control Building 147-foot Elevation
1.0
Fire Plans
NMP-ES-035-019-GL02-
F15
Unit 1 Reactor Building 185' Elevation
1.0
Fire Plans
NMP-ES-035-019-GL02-
F31
U2 Reactor Building El. 158/164
1.0
Fire Plans
NMP-ES-035-019-GL02-
F35
Unit 2 Rad Waste Building 132' elevation
1.0
Fire Plans
NMP-ES-035-019-Gl02-
F52
U1 Condensate Storage Tank
1.0
Fire Plans
NMP-ES-035-019-GL02-
F70
Fire Pump House
1.0
Fire Plans
NMP-ES-035-019-GL02-
F84
Service Water Valve Pits
1.0
Procedures
NMP-ES-035-017
Fleet Fire Doors Functional Inspection Governance
and Acceptance Criteria
1.1
Calculations
SMNH 99-014 (REV 1)
Water Hammer Evaluation for Fire Protection Piping
06/25/2012
Corrective Action
Documents
Resulting from
Inspection
Condition Reports (CR)
10904792, 10904824
Drawings
H-16039
Leak Detection System-Instrument & Drainage Sump
8.0
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Drawings
H-16110
Types of Penetration Seals For Non Fire Rated Wall
Pipe & Duct
2.0
Drawings
H-16176
Radwaste System P&ID
2.0
Engineering
Evaluations
LR-REG-001-1098
SER 3-98 Recurring Events Flooding of ECCS
Rooms Caused by Fire Protection System Water
Hammer
10/05/1998
Engineering
Evaluations
REA HT98703
Hatch Nuclear Plant - Units 1 & 2-Water Hammer
Analysis for Fire Protection
2/17/2000
Engineering
Evaluations
Technical Evaluations (TE)
390614, 78139
Miscellaneous
Response to NRC IN 2007-001
Recent Operating Experience Concerning Hydrostatic
Barriers
04/18/2007
Miscellaneous
Response to NRC IN-
2003-008
Potential Flooding through Unsealed Concrete Floor
Cracks
09/16/2003
Miscellaneous
Response to NRC IN-
2005-011 and IN-2005-30
Internal Flooding/Spraying-Down of Safety-Related
Equipment Due to Unsealed Equipment Hatch Floor
Plugs and/or Blocked Floor Drains
Safe Shutdown Potentially Challenged by Unanalyzed
Internal Flooding Events and Inadequate Design
06/29/2005
Procedures
Secondary Containment Control
5.18/4.5
Procedures
Torus Water Level
1.2/1.4
Procedures
ARP's For Control Panel 1H11-P657 (2H11-P657)
25.18/23.10
Miscellaneous
Emergency Preparedness Observation Form
07/11/2022
Miscellaneous
H-LT-AF-CPE-00112
CPE Design - EHC, RFPT Oil Temperature
Controller, Condenser Vacuum, ASD Cell, SDV,
1.0
Procedures
NMP-RE-008-F02
Simplified Reactivity Management Plan (Hatch - Unit
Cycle 27, H2C27-082022-040
2.1
Corrective Action
Documents
Condition Reports (CR)
10895237, 10889783, 10627699, 10636561,
10644291, 10648471, 10649056, 10644291,
10649128, 10653060, 10661059, 10665465,
10671968, 10683877, 10698757, 10700915,
10702813, 10702936, 10707324, 10709100,
10709104, 10709119, 10716168, 10717046,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
10723279, 10723451, 10726191, 10727321,
10729088, 10730446, 10730448, 10730527,
10733168, 10733904, 10734223, 10735427,
10737276, 10741057, 10742768, 10743777,
10743835, 10750160, 10753242, 10764198,
10767536, 10771598, 10774779, 10776884,
10779262, 10779523, 10780594, 10781036,
10781693, 10782597, 10782937, 10783554,
10786049, 10786052, 10790129, 10791368,
10791498, 10793147, 10794840, 10800016,
10803039, 10803106, 10803107, 10807477,
10814592, 10814961, 10814961, 10815628
Engineering
Evaluations
Technical Evaluations (TE)
1107681, 1075210
Miscellaneous
H-1(2) - P33 - Sampling
Primary Containment Hydrogen and Oxygen
Analyzers
Miscellaneous
P33-01 Sampling
Hydrogen and Oxygen Analyzers (Maintenance Rule
Function Scoping Sheet)
Calibration
Records
Condition Report (CR)
10910325
Corrective Action
Documents
Resulting from
Inspection
Condition Reports (CR)
10910484,10910972, 10910974
Miscellaneous
Hatch Unit 2 R8 On-Line Configuration Risk Monitor
Current
Risk Summary Report
08/30/2022
Miscellaneous
Hatch U1 R8 On-Line Configuration Risk Monitor -
Current Risk Summary Report
07/14/2022
Procedures
NMP-GM-031-001
Online Maintenance Rule (a)(4) Risk Calculations
8.0
Procedures
NMP-OS-010-002
Hatch Protective Equipment Logs
2.2
Procedures
NMP-OS-010-002
Hatch Protected Equipment Logs
11.1
Procedures
NMP-OS-017
Severe Weather
3.0
Procedures
NMP-OS-017
Severe Weather (Attachments 1 through 9 for Site
09/27/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Preps for Hurricane Ian)
Corrective Action
Documents
Condition Report (CR)
10895096
Corrective Action
Documents
Condition Reports (CR)
10899243, 10627205
Corrective Action
Documents
Condition Reports (CR)
10895145, 10898218, 10898626, 10901485
Drawings
H-26833
RHR Service Water at River Intake Structure -
Isometric
4.0
Drawings
S-00768, 00769, 00770
RHR Service Water system E-11-HGR-1, E-11-HGR-
2, E-11-HGR-3
2.0/1.0/3.0
Engineering
Evaluations
DOEJ-HRSNC1358910-
S001
Minimum Pipe Wall Thickness for 18 Inch RHRSW
Piping Structures at the Intake
08/08/2022
Engineering
Evaluations
NMP-AD-012-F01
Operability Determination Support Bases (CRs
10898218, 10898626, 10895145)
08/18/2022
Engineering
Evaluations
Prompt Determination of
Operability (CR 10730343)
Unit 2 RHRSW Division 2 Pumps
08/17/2020
Miscellaneous
1-LCO-22-00152
1T48-F323F Vacuum Breaker Failure to Close
Procedures
Loss of Plant Service Water
13.13
Procedures
Diesel Gen B Loading Timer Failure Alarm
3.3
Procedures
Containment Atmosphere Control and Dilution
System
26.4
Work Orders
Work Orders (WO)
1358911, 1358154
Engineering
Changes
SNC1334334
Design Equivalent Change Package for the 2B
Recirculation Pump Seal Purge Supplemental
Cooling
06/06/2022
Miscellaneous
NMP-OS-028
Adverse Condition Monitoring and Contingency Plan
for the 2B Recirculation Seal Monitoring
07/06/2022
Corrective Action
Documents
Condition Report (CR)
10897221
Corrective Action
Documents
Condition Report (CR)
10897312
Drawings
DECP SNC1225505J001
Fire Protection P&ID
1.0
Drawings
DECP
Program Fire Protection House Equipment
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
SNC125505E100_FCR004
Drawings
H-58109
Fire Pump Diesel Engine Mounting Details (1X43-
C002A and 1X43-C002B)
1.0
Miscellaneous
S-78101
Installation and Maintenance Manual for Diesel
Engine Fire Pump Controllers Model GPD
2.0
Procedures
25 VDC and 125/250 VDC System
20.3
Procedures
2SP-07-20-22-RS-1-1
Diesel Fire Pump Engine Replacement Functional
Test
1.0
Work Orders
Work Order (SNC)
1359845
08/11/2022
Work Orders
Work Order (SNC)
1356086
07/28/2022
Work Orders
Work Orders (SNC)
1012444, 1012446, 1356128, 1295880, 1296244,
1342764, 1368174, 1366668, 1321585, 1323434,
23466, 1297079, 1302202, 1297079, 1302202,
1303107, 1304289, 1305582, 1325361, 1325378,
25378, 1325787, 1326726, 1328511, 1329001,
1337341, 1345820, 1352434
07/29/2022
Corrective Action
Documents
Condition Reports
10892714, 10892718
Drawings
H-16334
RCIC System P&ID (Sheet No. 1)
51.0
Drawings
H-16335
RCIC System P&ID (Sheet No. 2)
36.0
Miscellaneous
1E51-C001 Existing Reference Data Page
3.0
Procedures
RCIC Pump Operability, completed on
7/6/2022
Procedures
Plant Service Water Pump Operability
15.3
Corrective Action
Documents
Condition Reports (CR)
10897008, 10897010, 10897011
Miscellaneous
Classification Evaluation for Hatch Off Year Exercise
22
Miscellaneous
Hatch Off Year Exercise 2022
07/26/2022
Miscellaneous
Emergency Preparedness Observation Form
07/26/2022
Procedures
NMP-EP-142-F10
Alert/Site Area/General Area Emergency Public
Address Announcement Scripts (July 26, 2022)
2.0
Procedures
NMP-EP-303-F05
Drill and Exercise Objectives (Section E.1 - Off-Site
Notification)
7.0
71152A
Corrective Action
Corrective Action Report
2959
03/20/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
Determination