IR 05000369/2020002
| ML20211L704 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 07/29/2020 |
| From: | Frank Ehrhardt NRC/RGN-II/DRP/RPB1 |
| To: | Teresa Ray Duke Energy Carolinas |
| References | |
| IR 2020002 | |
| Download: ML20211L704 (15) | |
Text
July 29, 2020
SUBJECT:
MCGUIRE NUCLEAR STATION - INTEGRATED INSPECTION REPORT 05000369/2020002 AND 05000370/2020002
Dear Mr. Ray:
On June 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at McGuire Nuclear Station. On July 22, 2020, the NRC inspectors discussed the results of this inspection with you 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.
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 McGuire Nuclear Station.
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 McGuire Nuclear Station. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Frank J. Ehrhardt, Chief Reactor Projects Branch 1 Division of Reactor Projects
Docket Nos. 05000369 and 05000370 License Nos. NPF-17 and NPF-9
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000369 and 05000370
License Numbers:
Report Numbers:
05000369/2020002 and 05000370/2020002
Enterprise Identifier: I-2020-002-0058
Licensee:
Duke Energy Carolinas, LLC
Facility:
McGuire Nuclear Station
Location:
Huntersville, North Carolina
Inspection Dates:
April 01, 2020 to June 30, 2020
Inspectors:
M. Bates, Senior Operations Engineer
B. Griman, Resident Inspector
G. Hutto, Senior Resident Inspector
K. Kirchbaum, Operations Engineer
N. Lacy, Operations Engineer
Approved By:
Frank J. Ehrhardt, Chief
Reactor Projects Branch 1
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at McGuire Nuclear Station, 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
McGuire Loss of Component Cooling Water (KC) Inventory in Mode 6 Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000370/2020002-01 Open/Closed
[H.11] -
Challenge the Unknown 71111.20 A self-revealed Green finding and associated NCV of Technical Specification (TS) 5.4.1,
Procedures, was identified when the licensee failed to adequately implement the procedure requirements for tagged components used for test configuration control. Specifically, the licensee opened a KC non-essential header valve that was tagged as a test boundary. This resulted in the loss of approximately 300 gallons of KC inventory through an open drain valve within the test boundary.
Additional Tracking Items
None.
PLANT STATUS
Unit 1 operated at or near 100 percent rated thermal power (RTP) for the entire inspection period.
Unit 2 began the inspection period shutdown for a scheduled refueling outage. The unit was placed on line April 13, 2020 and was returned to 100 percent RTP on April 16, 2020. The unit operated at or near 100 percent RTP 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 reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week and during that time conducted plant status activities as described in IMC 2515, Appendix D; observed risk significant activities; and completed on site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of season hot temperatures for the following systems:
- (1) Unit 2 diesel generators
- (2) Unit 1 containment ventilation units
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 1 1A diesel generator, on April 16, 2020
- (2) Unit 2 component cooling water (KC) "A" train on May 14, 2020
- (3) Unit 1 1B diesel generator, on June 18, 2020
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the Unit 1 safety injection system, on June 30, 2020.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Unit 1 Battery Room area, on April 23, 2020
- (2) Unit 2 Battery Room area, on April 23, 2020
- (3) Unit 1 750 elevation electrical penetration room, on June 29, 2020
- (4) Unit 2 750 elevation electrical penetration room, on June 29, 2020
71111.07A - Heat Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
- (1) 1A containment spray heat exchanger, on June 8, 2020
71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)
The inspectors completed an inspection to verify the licensees ability to evaluate the performance of their licensed operators during the conduct of examinations, to assess their ability to properly develop and administer requalification annual operating tests and biennial written examinations, to evaluate the performance of the control room simulator and their testing and maintenance of the simulator, to ensure that licensed individuals satisfy the conditions of their licenses, and to assess their effectiveness in ensuring that operator license conditions are satisfied.
- (1) Biennial Requalification Written Examinations
The inspectors evaluated the quality of the licensed operator biennial requalification written examination administered on June 12, 2020.
Annual Requalification Operating Tests
The inspectors evaluated the adequacy of the facility licensees annual requalification operating test.
Administration of an Annual Requalification Operating Test
The inspectors evaluated the effectiveness of the facility licensee in administering requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives.
Requalification Examination Security
The inspectors evaluated the ability of the facility licensee to safeguard examination material, such that the examination is not compromised.
Remedial Training and Re-examinations
The inspectors evaluated the effectiveness of remedial training conducted by the licensee, and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.
Operator License Conditions
The inspectors evaluated the licensees program for ensuring that licensed operators meet the conditions of their licenses.
Control Room Simulator
The inspectors evaluated the adequacy of the facility licensees control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46.
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 Control Room during reactivity manipulations on June 18, 2020 and June 25, 2020.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated active simulator exam ASE-16, which involved a loss of heat sink scenario, on June 22, 2020
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Sample)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:
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) Equipment protection plan for Unit 2 spent fuel cooling following core off-load, on April 13, 2020
- (2) Equipment protection plan for the vital battery charger C (EVCC) modified performance test, on April 28, 2020.
- (3) Equipment protection plan for the 2A diesel generator maintenance outage, on June 15, 2020
- (4) Equipment protection plan for the 2B VL Air Handling Unit out of service, on June 11, 2020
- (5) Equipment protection plan for the 1A diesel generator maintenance outage, on June 25, 2020
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) NCR 2324850, Invalid Unit 2 rod drop time reported by "A" train of digital rod position indication, on April 16, 2020
- (3) NCR 2328812, 1A auxiliary feedwater pump vibration - misalignment, on May 6, 2020
- (4) NCR 2331189, Rosemount transmitter heat rise part 21 impacting qualified life, on May 19, 2020
- (5) NCR 2333767, 2EDGA battery inoperable for low electrolyte level, on June 10, 2020
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the following post maintenance test activities to verify system operability and functionality:
- (1) PT/0/A/4150/028, Initial Criticality and Zero Power Physics Testing, following Unit 2 core reload, on April 24, 2020
- (2) PT/1/A/4350/002 A, 1A Diesel Generator Operability Test, following fluid checks, on April 28, 2020
- (3) OP/0/A/6100/029, General Procedure for Stroking Valves for Maintenance Activities, following electrical/mechanical PMs on 1CA-54AC, on May 26, 2020
- (4) PT/0/A/4200/002, SSF Operability Test, following SSF diesel PMs, on May 28, 2020
- (5) PT/2/A/4350/002 A, Revision 114, 2A Diesel Generator Operability Test, following maintenance outage, on June 23, 2020
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Partial)
- (1) The inspectors evaluated M2R26 activities from April 1, 2020 to April 10, 2020.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) PT/2/A/4600/105, RCCA Drop Timing Using DRPI System, on April 21, 2020
- (2) PT/1/A/4200/020 A, Airlock Operability Test, on June 30, 2020
Inservice Testing (IP Section 03.01) (1 Sample)
- (1) PT/1/A/4252/001 B, 1B CA Pump Performance Test, on May 15, 2020
Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)
- (1) PT/2/A/4200/001 C, Isolation Valve Leak Rate Test, for penetration 2M-342, on April 3, 2020
Ice Condenser Testing (IP Section 03.01) (1 Sample)
- (1) PT/0/A/4200/018, Ice Bed Analysis, on April 15,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)===
- (1) Unit 1 (April 1, 2019 - March 31, 2020)
- (2) Unit 2 (April 1, 2019 - March 31, 2020)
MS06: Emergency AC Power Systems (IP Section 02.05) (2 Samples)
- (1) Unit 1 (April 1, 2019 - March 31, 2020)
- (2) Unit 2 (April 1, 2019 - March 31, 2020)
MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)
- (1) Unit 1 (April 1, 2019 - March 31, 2020)
- (2) Unit 2 (April 1, 2019 - March 31, 2020)
71152 - Problem Identification and Resolution
Semiannual Trend Review (IP Section 02.02) (1 Sample)
- (1) The inspectors reviewed the licensees corrective action program for potential adverse trends in equipment reliability that might be indicative of a more significant safety issue.
Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) NCR 2320541, Site trend - checklist quality, on June 29,
INSPECTION RESULTS
McGuire Loss of Component Cooling Water (KC) Inventory in Mode 6 Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events
Green NCV 05000370/2020002-01 Open/Closed
[H.11] -
Challenge the Unknown 71111.20 A self-revealed Green finding and associated NCV of Technical Specification (TS) 5.4.1, Procedures, was identified when the licensee failed to adequately implement the procedure requirements for tagged components used for test configuration control. Specifically, the licensee opened a KC non-essential header valve that was tagged as a test boundary. This resulted in the loss of approximately 300 gallons of KC inventory through an open drain valve within the test boundary.
Description:
On March 29, 2020, the Unit 2 B train of component cooling water was the protected train of cooling water to the decay heat removal system while in Mode 6. The A train of service water was not protected but available. Valve 2KC -335 was danger tagged for a maintenance boundary and the valve also had a test tag to maintain configuration control for unrelated penetration valve testing. 2KC-335 is an isolation valve in the KC non-essential header return from containment. Non-licensed operators (NLOs) were restoring the maintenance clearance and removed the danger tag which had an open restoration position. The NLOs erroneously assumed they could also remove the test tag and position the valve open. The test boundary maintained a drain valve in the KC header open, so when KC-335 was opened, which un-isolated the non-essential header from the operating portion of the system, approximately 300 gallons of KC inventory leaked into the auxiliary building before the leak was discovered and isolated. The leak resulted in a nearby fire sensor to alarm which expedited the discovery of the leak location and allowed the operators to terminate the leak within approximately 10 minutes.
AD-OP-ALL-0204, Plant Status Control, required that test tags used for system configuration control during testing must be removed either by the test procedure or once the test procedure is completed, and components having test tags can only be manipulated within the instructions of the test procedure. The NLOs removed the test tag independent of the test procedure and did not appropriately verify the status of the penetration testing prior to removing the tag and positioning valve KC-335. As a result, once KC-335 was positioned open, water from the operating portion of the KC system leaked through an open drain valve in the test boundary.
Corrective Actions: Operations personnel identified and isolated the source of the leak. Coaching was provided to all individuals involved based on human performance behaviors exhibited. Lessons learned were communicated to all operations shifts. A training request form was generated to develop and deliver training on the use of AD-OP-ALL-0204 tagging processes.
Corrective Action References: NCR 2322876, 2KC-335 opened while under test tag control.
Performance Assessment:
Performance Deficiency: The licensees failure to adequately implement procedure AD-OP-ALL-0204 was a violation of TS 5.4.1 and a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human Performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the failure to implement procedure AD-OP-ALL-0204, resulted in a challenge to the decay heat removal function support system of KC, due to a loss of system inventory during Mode 6.
Significance: The inspectors assessed the significance of the finding using Appendix G, Shutdown Safety SDP. The finding was determined to require a Phase 2 risk assessment based on the screening criteria in Attachment 1, Exhibit 2, Shutdown Initiators, Question
1. Specifically, the finding resulted in the increased likelihood of a shutdown initiating event
(loss of shutdown cooling). A regional senior reactor analyst conducted a Phase 2 risk analysis in accordance with IMC 0609, Appendix G, Attachment 2, Phase 2 Significance Determination Process Template for PWR During Shutdown, dated January 8, 2020, and concluded the component cooling water leak represented a loss of residual heat removal (LORHR) precursor condition that occurred in Plant Operational State (POS) III. The analyst noted that with the upper internals installed, the estimated time to core uncovery was approximately 44 hours5.092593e-4 days <br />0.0122 hours <br />7.275132e-5 weeks <br />1.6742e-5 months <br /> following a complete loss of decay heat removal. The analyst concluded that the presence of the upper internals did not significantly reduce the time for operators to take manual actions to mitigate a potential loss of decay heat removal condition and that the finding would screen to Green in Phase 2 (reference Section 4.0, IMC 0308, 3, Appendix G, Technical Basis for Shutdown Operations Significance Determination Process, dated February 8, 2005).
Cross-Cutting Aspect: H.11 - Challenge the Unknown: Individuals stop when faced with uncertain conditions. Risks are evaluated and managed before proceeding. The inspectors determined the finding had a cross cutting aspect of challenge the unknown, in the human performance area, because the NLOs did not stop work in the field to validate assumptions when unexpected conditions were encountered (the presence of test tags).
Enforcement:
Violation: TS 5.4.1, Procedures, required that procedures shall be established, implemented and maintained covering the applicable procedures recommended in Regulatory Guide 1.33. Regulatory Guide 1.33, Appendix A, Section 1, Administrative Procedures, included procedures for equipment control (e.g. locking and tagging). The licensees administrative procedure AD-OP-ALL-0204, Plant Status Control, required that test tags used for system configuration control during testing must be removed either by the test procedure or once the test procedure is completed, and components having test tags can only be manipulated within the instructions of the test procedure.
Contrary to the above, on March 29, 2020, the licensee failed to adequately implement administrative procedure AD-OP-ALL-0204. Specifically, NLOs removed the test tag on KC-335A independent of the test procedure and before the test was completed. This resulted in a loss of 300 gallons of inventory from the operating train of KC through an open drain valve in the test boundary.
Enforcement Action: This violation is being treated as an non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On July 22, 2020, the inspectors presented the integrated inspection results to Tom Ray and other members of the licensee staff.
- On June 29, 2020, the inspectors presented the Licensed Operator Requalification Program inspection results to Thomas Ray, 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
NCR 2330638
Potential impacts to Unit 2 intake summer readiness
Miscellaneous
Action Register report for summer readiness between April -
June 2020
Procedures
AD-WC-ALL-0230
Seasonal Readiness
PT/0/B/4700/039
Warm Weather Equipment Checkout
Drawings
MCFD-1562-
01.00
Flow Diagram of Safety Injection System (NI)
MCFD-2573-
01.00
Flow Diagram of Component Cooling Water System (KC)
MCFD-2573-
01.01
Flow Diagram of Component Cooling Water System (KC)
Procedures
OP/1/A/6350/002
Diesel Generator
Drawings
MFSD-013
Vital Battery Room
MSFD-017
Unit 1 750 Electrical Pen Room
MSFD-018
Unit 2 750 Electrical Pen Room
Fire Plans
CSD-MNS-PFP-
AB-0733-001
Units 1 & 2 Auxiliary Builidng El' 733
Procedures
AD-EG-ALL-1520
Transient Combustible Control
71111.07A Procedures
PT/1/A/4208/010
A
NS 1A Heat Exchanger Heat Balance Test
Procedures
AD-OP-ALL-0201
Protected Equipment
Engineering
Evaluations
MCC-1553.05-00-
0662
McGuire 2 Cycle 26 Startup and Operational Report
Procedures
AD-EG-ALL-1211 System Performance Monitoring and Trending
AD-OP-ALL-0102
Operability Decision Making
AD-OP-ALL-0105
Operability Determinations and Functionality Assessment
Procedures
AD-EG-ALL-1155 Post Modification Testing
OP/0/A/6100/029
Generic Procedure for Stroking Valves for Maintenance
Activities
PT/2/A/4350/002
A, Revision 114
Diesel Generator 2A Operability Test
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Work Orders
PT 1CA-54AC Elec/Mech Inspection of Rotork Actuator and
Stem Lube
Procedures
OP/1/A/6100/003
Controlling Procedure for Unit Operation
PT/0/A/4150/028
Initial Criticality and Zero Power Physics Testing
PT/0/A/4150/047
1/M Monitoring During Startup
PT/2/A/4600/003F Containment Cleanliness and ECCS Operability Inspection
Procedures
PT/1/A/4200/020
A, Revision 25
Airlock Operability Test
71151
Procedures
AD-LS-ALL-0004
NRC Performance Indicators and Monthly Operating Report
AD-PI-ALL-0100
Corrective Action Program
Procedures
AD-LS-ALL-0006
Notification/Reportability Evaluation
AD-PI-ALL-0100
Corrective Action Program
AD-PI-ALL-0104
Prompt Investigation Response Team
AD-PI-ALL-0105
Effectiveness Reviews