IR 05000369/2022002
| ML22207B630 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 07/26/2022 |
| From: | Eric Stamm NRC/RGN-II/DRP/RPB1 |
| To: | Pigott E Duke Energy Carolinas |
| References | |
| IR 2022002 | |
| Download: ML22207B630 (27) | |
Text
July 26, 2022
SUBJECT:
MCGUIRE NUCLEAR STATION - INTEGRATED INSPECTION REPORT 05000369/2022002 AND 05000370/2022002
Dear Mr. Pigott:
On June 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at McGuire Nuclear Station. On July 19, 2022, 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, Eric J. Stamm, Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Nos. 05000369 and 05000370 License Nos. NPF-9 and NPF-17
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000369 and 05000370
License Numbers:
Report Numbers:
05000369/2022002 and 05000370/2022002
Enterprise Identifier:
I-2022-002-0017
Licensee:
Duke Energy Carolinas, LLC
Facility:
McGuire Nuclear Station
Location:
Huntersville, North Carolina
Inspection Dates:
April 1, 2022, to June 30, 2022
Inspectors:
A. Hutto, Senior Resident Inspector
C. Scott, Resident Inspector
J. Diaz-Velez, Senior Health Physicist
S. Downey, Senior Reactor Inspector
B. Kellner, Senior Health Physicist
N. Lacy, Operations Engineer
M. Meeks, Senior Operations Engineer
M. Schwieg, Senior Reactor Inspector
Approved By:
Eric J. Stamm, 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 (ROP) 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
Failure to Adequately Implement Clearance and Tagout Procedures Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000369/2022002-01 Open/Closed
[H.8] -
Procedure Adherence 71111.20 A self-revealed Green finding and associated non-cited violation (NCV) of Technical Specification (TS) 5.4.1 was identified for the licensees failure to adequately implement their administrative tagout procedure, resulting in the unintended transfer of inventory from the refueling water storage tank (FWST) to the recycle holdup tank (RHT) while in lowered inventory. Specifically, the licensee did not implement the requirements of tagout procedure,
AD-OP-ALL-0200, Clearance and Tagging, and failed to place a component in the required clearance position prior to beginning work on the safety injection (NI) system.
Additional Tracking Items
Type Issue Number Title Report Section Status URI 05000369,05000370/
2022002-02 Technical basis for changes to calibration frequency of radiation monitors EMF-36,
EMF-44, and EMF-49 LOW and HIGH channels and SLC respective update/clarification.
71124.05 Open
PLANT STATUS
Unit 1 began the inspection period shut down for a scheduled refueling outage. The unit was returned to full power operation on May 12, 2022. On May 25, 2022, power was reduced to 84 percent rated thermal power (RTP) to allow for isolation and repair of a steam leak on the 1B1 moisture separator reheater (MSR) drain tank condenser drain line. Power was returned to 100 percent RTP on May 26, 2022. On June 19, 2022, power was reduced to 78 percent RTP to repair an emergent steam leak on a 1/2-inch flow element sensing line associated with the 1B1 MSR. Power was returned to 100 percent RTP on June 23, 2022, and remained at or near 100 percent RTP for the remainder of the inspection period.
Unit 2 operated at or near 100 percent RTP for the entire 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
71111.01 - 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 hot weather for the following systems:
"B" train of control room ventilation and cooling on May 13, 2022
Unit 2 emergency diesel generators (EDGs) on May 13, 2022
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 "B" train of spent fuel pool cooling on April 13, 2022
- (2) Unit 1 "B" EDG on April 20, 2022 (3)
"B" control area chiller on June 24, 2022
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the Unit 1 auxiliary feedwater system on May 5, 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) Unit 1 auxiliary feedwater pump area on April 13, 2022
- (2) Unit 2 auxiliary feedwater pump area on April 13, 2022
- (3) Unit 2 "A" emergency switchgear room on April 21, 2022
- (4) Unit 1 "A" EDG on May 10, 2022
- (5) Unit 1 "B" EDG on May 10, 2022
- (6) Standby shutdown facility (SSF) on May 31, 2022
71111.08P - Inservice Inspection Activities (PWR) PWR Inservice Inspection (ISI) Activities Sample (IP Section 03.01)
- (1) The inspectors reviewed the following ISI activities from April 4 to April 18, 2022:
The inspectors reviewed the following non-destructive examinations (NDEs) activities to verify that the licensee is conducting selected NDEs appropriately and addressing any identified defects appropriately:
o Ultrasonic examination of the 6" Loop 1B hot leg line o
Visual examination of loop 1B reactor vessel outlet nozzle-to-safe-end weld o
Visual examination of reactor pressure vessel upper head penetrations
The inspectors reviewed the boric acid control program to verify that the licensee is managing boric acid appropriately to guard against corrosion mechanisms that could lead to the degradation of safety-significant components
The inspectors reviewed the upper head penetration inspection activities to verify that the licensee is conducting inspections appropriately in accordance with the plant procedures, industry guidelines, and applicable regulatory requirements
The inspectors reviewed steam generator tube inspection activities to verify that they were performed in accordance with the plants technical specifications, industry guidelines, and applicable regulatory requirements o
Steam Generator 1A - eddy testing (ET) for tubes R85C82, R117C72 o
Steam Generator 1B - ET for tubes R57C76, R62C43 o
Steam Generator 2C - ET for tubes R75C60, R82C69, R90C59
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 17, 2022.
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.
Problem Identification and Resolution The inspectors evaluated the licensees ability to identify and resolve problems associated with licensed operator performance.
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 reactor shutdown and plant cooldown for the Unit 1 refueling outage on April 2, 2022.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated annual simulator exam ASE-03 on May 25, 2022. The scenario involved a nuclear instrument failure followed by a reactor coolant system leak and loss of heat sink.
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) Nuclear condition report (NCR) 2408566, investigate and repair snubber 1VNHGH021/1-MCA-VN-H021, 1B diesel ventilation exhaust duct
- (2) NCR 2428398, previously identified SSF ventilation issues remain
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 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) Action request (AR) 2415989, M1R28 outage independent review risk assessment, on April 11, 2022
- (2) Equipment protection plan for Unit 1 core reload, on April 19, 2022
- (3) Unit 1 yellow risk condition during reduced inventory, on April 21, 2022
- (4) Equipment protection plan for the 1A EDG maintenance outage, on June 22, 2022
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) NCR 2422415, Unit 1 ice basket weights below the safety analysis mean limit
71111.18 - Plant Modifications
Severe Accident Management Guidelines (SAMG) Update (IP Section 03.03) (1 Sample)
- (1) The inspectors verified the site SAMGs were updated in accordance with the pressurized water reactor generic severe accident technical guidelines and validated in accordance with NEI 14-01, Emergency Response Procedures and Guidelines for Beyond Design Basis Events and Severe Accidents, Revision 1.
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:
- (1) PT/1/A/4350/002 A, Diesel Generator 1A Operability Test, following an outage maintenance, on April 18, 2022
- (2) PT/1/A/4209/001 B, 1B NV [chemical and volume control]; Pump Performance Test, following inboard and outboard pump seal replacements, on April 23, 2022
- (3) PT/1/A/4600/105, RCCA [rod cluster control assembly] Drop Timing Using DRPI
[digital rod position indicator] System, following Unit 1 refueling, on May 1, 2022
- (4) PT/1/A/4252/002 B, CA [auxiliary feedwater] Valve Stroke Timing - Quarterly 1B Motor Driven Pump Flowpath, following flow balance adjustments on 1CA-40B and 1CA-44B, on May 10, 2022
- (5) PT/1/A/4350/002 A, Diesel Generator 1A Operability Test, following maintenance, on June 26, 2022
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated refueling outage M1R28 activities from April 2, 2022, to May 9, 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) (3 Samples)
- (1) PT/1/A/4350/026 B, Auxiliary Shutdown Panel Control Verification During Modes 5, 6 or No Mode, on April 22, 2022
- (2) PT/1/A/4150/005, NC [reactor coolant] Valve Stroke Timing Test Using Air, on April 25, 2022
- (3) PT/2/A/4600/003 D, Monthly Surveillance Items, on May 9, 2022
Inservice Testing (IP Section 03.01) (1 Sample)
- (1) PT/1/A/4200/022, ND [residual heat removal] Suction Swapover Timing Test, on April 14, 2022
Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)
- (1) PT/1/A/400/001 C, Isolation Valve Leak Rate Test, on April 7, 2022
Ice Condenser Testing (IP Section 03.01) (1 Sample)
- (1) PT/0/A/4200/018, Ice Bed Analysis (Unit 1), on April 28, 2022
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)
- (1) The inspectors observed the emergency preparedness drill on May 18, 2022. The drill involved a loss of offsite power followed by the sequential loss of both diesel generators for greater than 15 minutes.
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.
Contamination and Radioactive Material Control (IP Section 03.03) (3 Samples)
The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:
- (1) Licensee surveys of potentially contaminated material leaving the radiologically controlled area (RCA)
- (2) Workers exiting the RCA Unit 1 during a refueling outage
- (3) Hot particle surveys of workers exiting the area under the reactor head
Radiological Hazards Control and Work Coverage (IP Section 03.04) (5 Samples)
The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:
- (1) McGuire Nuclear Station M2R27 Refueling Outage Report, 01/18/2022 [Fall 2021 outage]
- (2) ALARA [as low as reasonably achievable] Plan 22-04 Revision 0, M1R28 Fleet Reactor Services Routine Outage Work [Reactor head and upper internals removal/install, and fuel movement in the reactor cavity & spent fuel pool]
- (3) ALARA Plan 22-03 Revision 0, Steam Generator (Primary and Secondary) [Eddy current, sludge lance, and foreign object search and retrieval]
- (4) ALARA Plan 22-05 Revision 0, Under head Mod., including 50 percent in-progress review [Cutting funnels and prep work for future modification under the reactor head]
- (5) ALARA Plan 22-07 Revision 0, U1 NV gasket replacement High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (5 Samples)
The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:
- (1) Unit 1 fuel transfer canal locked high radiation area (LHRA) temporary boundary
- (2) Unit 1 access under the reactor head LHRA
- (3) Unit 1 incore tip room door Very High Radiation Area
- (4) Unit 1 reactor cavity - upper internals lift
- (5) Unit 1 reactor cavity - reactor head lift Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)
- (1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Permanent Ventilation Systems (IP Section 03.01) (2 Samples)
The inspectors evaluated the configuration of the following permanently installed ventilation systems:
- (1) Unit 1/Unit 2 auxiliary building ventilation system
- (2) Unit 1/Unit 2 containment purge ventilation system
Temporary Ventilation Systems (IP Section 03.02) (1 Sample)
The inspectors evaluated the configuration of the following temporary ventilation system:
- (1) HEPA #U010997, room 809 letdown heat exchanger
Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the licensees use of respiratory protection devices.
Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)
- (1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses.
71124.04 - Occupational Dose Assessment
Source Term Characterization (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.
External Dosimetry (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated how the licensee processes, stores, and uses external dosimetry.
Internal Dosimetry (IP Section 03.03) (1 Sample)
The inspectors evaluated the following internal dose assessment:
- (1) AD-RP-All-4010, Attachment 1, Internal Dose Assessment. Radiation protection (RP)
Badge Number 501077. 10/29/2020
Special Dosimetric Situations (IP Section 03.04) (2 Samples)
The inspectors evaluated the following special dosimetric situations:
- (1) Reviewed documentation of monitoring of three declared pregnant workers during the period 7/1/2020 through 4/1/2022
- (2) Reviewed multi-badging documentation for 23 individuals performing work under the Unit 1 reactor head from 4/7/2022 to 4/18/2022
71124.05 - Radiation Monitoring Instrumentation
Walkdowns and Observations (IP Section 03.01) (10 Samples)
The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:
- (1) Canberra iCAM, Sn:5735 (EnRad 13202), Unit 1 spent fuel pool
- (2) Ludlum 3030P Smear Counter, Sn: 317124 (EnRad 12780) Unit 1 spent fuel pool
- (3) Ludlum LUD-177 Rate Meter w/frisker, Sn: 309471 (EnRad 07531), Unit 1 spent fuel pool
- (4) Ludlum LUD-177 Rate Meter w/frisker, Sn: 279135 (EnRad 10161), auxiliary building, room 1009A
- (5) Rotem Telepole, Sn:6613-109 (EnRad 12232), Unit 2 upper containment RP desk
- (6) Canberra Cronos -1, Sn: 1411-241-CR0100G (EnRad 12749), admin building, room 157 (Dosimetry)
- (7) Canberra GEM-5, Sn: 0511-024 (EnRad 12354), admin building, room 157 (Dosimetry)
- (8) Radeco "Goose Neck" Air Sampler, Sn: 5956 (EnRad 02929), equipment hatch area
- (9) Rotem Telepole, Sn:0914-113 (EnRad 07595), RP count room
- (10) Thermo RadEye G, Sn:30760 (EnRad 16013), auxiliary building, room 1009A
Calibration and Testing Program (IP Section 03.02) (13 Samples)
The inspectors evaluated the calibration and testing of the following radiation detection instruments:
(1)1-EMF-51A, Unit 1 Containment High Range Radiation Monitor, calibrated 04/05/2019 (2)1-EMF-51A, Unit 1 Containment High Range Radiation Monitor, calibrated 10/03/2020 (3)2-EMF-51A, Unit 2 Containment High Range Radiation Monitor, calibrated 03/23/2020 (4)2-EMF-51A, Unit 2 Containment High Range Radiation Monitor, calibrated 09/26/2021 (5)2-EMF-51B, Unit 2 Containment High Range Radiation Monitor, calibrated 04/14/2020 (6)2-EMF-51B, Unit 2 Containment High Range Radiation Monitor, calibrated 03/23/2020 (7)1-EMF-12, Unit 1 Control Room Area Radiation Monitor, calibrated 09/03/2019 (8)1-EMF-17, Unit 1 Bridge Spent Fuel Pool Area Radiation Monitor, calibrated 12/23/2021 (9)1-EMF-17, Unit 1 Bridge Spent Fuel Pool Area Radiation Monitor, calibrated 04/14/2020 (10)2-EMF-36HH, Unit 2 Plant Vent HH Range Radiation Monitor, calibrated 10/03/2021 (11)1-EMF-36HH Unit 1 Plant Vent HH Range Radiation Monitor, calibrated 09/13/2021 (12)2-EMF-4, Spent Fuel Pool Area Rad Monitor, calibrated 06/18/2020 (13)2-EMF-4, Spent Fuel Pool Area Rad Monitor, calibrated 10/17/2018 Effluent Monitoring Calibration and Testing Program Sample (IP Sample 03.03) (2 Samples)
The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:
(1)0-EMF-50L, 0-EMF-50H Waste Gas Radiation Monitor, calibrated 09/25/2021 and 07/21/2016 (respectively)
(2)0-EMF-49L, 0-EMF-49H Liquid Waste Radiation Monitor, calibrated 11/16/2021 and 12/21/2021 (respectively)
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, 2021, through March 31, 2022)
- (2) Unit 2 (April 1, 2021, through March 31, 2022)
MS06: Emergency AC Power Systems (IP Section 02.05) (2 Samples)
- (1) Unit 1 (April 1, 2021, through March 31, 2022)
- (2) Unit 2 (April 1, 2021, through March 31, 2022)
MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)
- (1) Unit 1 (April 1, 2021, through March 31, 2022)
- (2) Unit 2 (April 1, 2021, through March 31, 2022)
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) August 1, 2021, through January 31, 2022 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
- (1) August 1, 2021, through January 31, 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:
- (2) NCR 2408408, pressurizer power operated relief valve block safety function
71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)
- (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.
INSPECTION RESULTS
Failure to Adequately Implement Clearance and Tagout Procedure Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000369/2022002-01 Open/Closed
[H.8] -
Procedure Adherence 71111.20 A self-revealed Green finding and associated non-cited violation (NCV) of Technical Specification (TS) 5.4.1 was identified for the licensees failure to adequately implement their administrative tagout procedure, resulting in the unintended transfer of inventory from the refueling water storage tank (FWST) to the recycle holdup tank (RHT) while in lowered inventory. Specifically, the licensee did not implement the requirements of their tagout procedure, AD-OP-ALL-0200, Clearance and Tagging, and failed to place a component in the required clearance position prior to beginning work on the safety injection (NI) system.
Description:
On April 5, 2022, at 6:56 a.m., the licensee implemented clearance OPS-1-22-NI-1NI332-0104 to isolate a portion of the NI system to perform maintenance on valve 1NI-332A. Unit 1 was in a refueling outage at the time, in Mode 5 with preparations to enter Mode 6 underway. The clearance required valve 1NI-334B to be placed in the closed position. The operator implementing the clearance in the control room placed the clearance information tag on the control switch for 1NI-334B and signed for placement verification as the tag hanger, but did not verify if the valve was in the required closed position, as the operator assumed the valve did not need to be manipulated. The valve was in fact open.
At 8:00 p.m., the following shift, work began on valve 1NI-332A. At this time, reactor coolant system level had been reduced to lowered inventory below the vessel flange (77 inches) in preparation for Mode 6 entry. With 1NI-334B open, when 1NI-332A was opened as part of the maintenance, an inadvertent flow path was created from the FWST to the reactor coolant system. As a result, the volume control tank level increased to 66 percent at which point the letdown diversion control valve automatically opened as designed to divert inventory from the reactor coolant system to the RHT. At 11:55 p.m., the operators noticed a mismatch in charging and letdown flows, and after a review of the operator aid computer graphics, determined that 1NI-334B was open and subsequently closed the valve. Actual level in the reactor coolant system did not change during the event.
The licensees administrative procedure for implementing tagouts, AD-OP-ALL-0200, Clearance and Tagging, Section 4.11, specifies that the tag hanger, positions the components in accordance with the clearance and plant procedures and verifies the effects of the component manipulations as expected. Contrary to AD-OP-ALL-0200, the tag hanger did not place valve 1NI-334B in the position specified by the clearance.
Corrective Actions: The operators closed 1NI-334B and immediately halted the work on 1NI-332A upon the discovery of the deficient condition. Additionally, the licensee conducted stand-downs with operations personnel to communicate issue lessons-learned relative to procedure use and adherence and clearance briefs.
Corrective Action References: NCR 2422881
Performance Assessment:
Performance Deficiency: The inspectors determined that the licensees failure to implement the requirements of licensee procedure AD-OP-ALL-0200 for clearance OPS-1-22-NI-1NI332-0104 was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Configuration Control 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, if uncorrected, uncontrolled flow paths into and out of the reactor coolant system while in lowered inventory could increase the likelihood of a loss of inventory event.
Significance: The inspectors assessed the significance of the finding using Inspector Manual Chapter 0609 Appendix G, Shutdown Safety SDP. The finding was determined to be of very low safety significance (green) because the finding did not result in an actual loss of inventory.
Cross-Cutting Aspect: H.8 - Procedure Adherence: Individuals follow processes, procedures, and work instructions. Specifically, the operator did not follow the licensees procedure for implementing clearance OPS-1-22-NI-1NI332-0104.
Enforcement:
Violation: TS 5.4.1 required that procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide (RG)1.33. RG 1.33, Appendix A, Section 1, Administrative Procedures, recommended procedures for equipment control (e.g., locking and tagging). The licensees administrative procedure for locking and tagging, AD-OP-ALL-0200, Clearance and Tagging, required that the tag hanger, positions the components in accordance with the clearance and plant procedures and verifies the effects of the component manipulations as expected.
Contrary to the above, on April 5, 2022, the licensee failed to adequately implement licensee procedure AD-OP-ALL-0200. Specifically, the tag hanger for clearance OPS-1-22-NI-1NI332-0104 failed to position 1NI-334B in the closed position, resulting in an inadvertent transfer of reactor coolant system inventory while in lowered inventory.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Unresolved Item (Open)
Technical basis for changes to calibration frequency of radiation monitors EMF-36, EMF-44, and EMF-49 LOW and HIGH channels and SLC respective update/clarification.
URI 05000369,05000370/2022002-02 71124.05
Description:
Site Technical Specification 5.5, Programs and Manuals, Section 5.5.5, Radioactive Effluent Controls Program, states in part that, this program conforms to 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to members of the public from radioactive effluents as low as reasonably achievable. The program shall be contained in Chapter 16 of the UFSAR [updated final safety analysis report], shall be implemented by procedures, and shall include remedial actions to be taken whenever the program limits are exceeded. The program shall include the following elements:
1. Limitations on the functional capability of radioactive liquid and gaseous monitoring
instrumentation including surveillance tests and setpoint determination in accordance with the methodology in the offsite dose calculation manual
Additionally, Section 5.5.5 b, states in part that, licensee-initiated changes to the Radiological Effluent Controls of the UFSAR:
1. Shall be documented and records of reviews performed shall be retained. This
documentation shall contain:
i.
Sufficient information to support the change(s) together with the appropriate analyses or evaluations justifying the change(s), and ii.
A determination that the change(s) maintain the overall conformance of the solidified waste product to existing requirements of Federal, State, or other applicable regulations or a determination that the change will maintain the level of radioactive effluent control required by 10 CFR 20.1302, 40 CFR Part 190, 10 CFR 50.36a, and Appendix I to 10 CFR Part 50 and not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations
Chapter 16 of the UFSAR, Selected Licensee Commitments, (SLCs) states that, Changes to these Selected Licensee Commitments shall be considered a change in an NRC commitment and shall be made only in accordance with the approved Nuclear Operating Fleet Administrative Procedure for the Control of Selected Licensee Commitments and by use of the 10 CFR 50.59 Process. SLC Section 16.11.2, Radioactive Liquid Effluent Monitoring Instrumentation, identifies the surveillance frequency requirements and compensatory actions which include channel calibration testing requirement (TR) 16.11.2.7 on a 24-month periodicity. SLC Section 16.11.7, Radioactive Gaseous Effluent Monitoring Instrumentation, identifies the surveillance frequency requirements and compensatory actions which include channel calibration TR 16.11.7.7 on an 18-month periodicity.
The inspectors noted that calibration intervals of site effluent radiation monitors used for making decisions related to emergency action level declarations in case of an event were changed from the expected frequencies described in Chapter 16 of the UFSAR. Specifically, effluent monitors EMF-36, EMF-44, and EMF-49 HIGH channels were found calibrated at six-year intervals. The inspectors were unable to review a technical basis study/report or paper justifying the change in calibration frequency nor has the licensee updated Chapter 16 of the UFSAR to reflect the change in calibration frequency, separating the specific channel calibrations that deviated from the descriptions stated in Chapter 16 of the UFSAR. The issue is unresolved because inspectors were unable to determine the significance of the radiation monitors calibration frequency changes.
Planned Closure Actions:
===1. Review closing/completion of actions related to NCR 02427036, including
- (1) review===
of the licensee's technical basis supporting changes in calibration frequencies for radiation monitors EMF-36, EMF-44, and EMF-49 regarding established calibration frequencies for LOW and HIGH range channels and,
- (2) review of revised SLC tables referring to radiation monitors EMF-36, EMF-44, and EMF-49 calibration of LOW and HIGH channels to ensure commitments are clearly defined.
2. Determine whether a performance deficiency occurred and if so, the ROP significance
for proper disposition.
Corrective Action References: NCR
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On April 18, 2022, the inspectors presented the Unit 1 ISI inspection results to Ed Pigott, Site Vice President, and other members of the licensee staff.
On April 27, 2022, the inspectors presented the RP Occupational Radiation Safety Baseline inspection results to Ed Pigott, Site Vice President, and other members of the licensee staff.
On June 16, 2022, the inspectors presented the Licensed Operator Requalification inspection results to Ed Pigott, Site Vice President, and other members of the licensee staff.
On July 19, 2022, the inspectors presented the integrated inspection results to Ed Pigott, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
AD-WC-ALL-0230
Seasonal Readiness
Procedures
PT/0/B/470/039
Warm Weather Equipment Checkout
Corrective Action
Documents
2417173
Generate PRRs for 1B diesel governor droop setting
MCFD-1570-
01.00/01
Flow Diagram of Unit 1 Spent Fuel Cooling System
Drawings
MCFD-1618-
01.00
Flow Diagram of Control Area Chilled Water System
AD-EG-ALL-1206
Equipment Reliability Classification
Procedures
OP/1/A/6350/002
A
Diesel Generator
Work Orders
01991959-01, 2CARL2AFTPBD: Replace Relay
AD-EG-ALL-1520
Transient Combustible Control
CSD-MNS-PFP-
DG1-0736-001
Diesel Generator Building Elevation 736 Pre-Fire Plan
Procedures
CSD-MNS-PFP-
DG2-0736-001
U2 Diesel Generator Building Elevation 736 Pre-Fire Plan
Corrective Action
Documents
22593
Boric Acid residue on Loop B Outlet Nozzle
04/05/2022
McGuire Unit 1 M1R28 Steam Generator Degradation
Assessment
CFR80 Steam Generator Site Technique Validation for
Catawba Nuclear Station, Unit 1, and McGuire Nuclear
Station Units 1 and 2
Miscellaneous
24-AST-
101483
Condition Monitoring and Operational Assessment for
McGuire Unit 1 M1R25
UT-22-005
UT examination of 6" 1B Loop Hot Leg Injection
04/07/2022
VT-22-074
Visual examination of Reactor Pressure Vessel Upper Head
04/13/2022
NDE Reports
VT-22-49
Visual Examination of Loop B - Outlet (Hot Leg) Nozzle-to-
04/10/2022
Procedures
NDE-NE-ALL-
Visual examination of PWR Reactor Pressure Vessel Upper
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
202
Head Penetrations
Biennial Written Exam LOCT B-Shift, SRO and RO
Simulator scenarios and job performance measures
administered to LOCT B-Shift, SRO and RO
Medical records for 10 licensed operators, C-Shift
Training attendance records, 2020-2022, since last
71111.11B inspection
Remediation records, 2020-2022, since last 71111.11B
inspection
License maintenance hours documentation
Miscellaneous
Simulator fidelity testing records, 2020-2022
AD-TQ-ALL-0068
Licensed Operator Continuing Training Program
AD-TQ-ALL-0101
Conduct of the Systematic Approach to Training
AD-TQ-ALL-0230
Licensed Operator Requalification Annual and Biennial
Exam Development
AD-TQ-ALL-0320
Development of Simulator Training and Evaluation Guides
AD-TQ-ALL-0420
Conduct of Simulator Training and Evaluation
AD-TQ-ALL-0425
Simulator Scenario Based Testing
AD-TQ-ALL-0700
Nuclear Station Unit Specific Training Simulators
Procedures
CSD-TQ-ALL-
0101-01
Systematic Approach to Training Process
Procedures
AD-OP-ALL-1000
Conduct of Operations
AD-EG-ALL-1204
Single Point Vulnerability Identification, Elimination and
Mitigation
AD-EG-ALL-1206
Equipment Reliability Classification
AD-EG-ALL-1209
System, Component, and Program Health Reports and
Notebooks
AD-EG-ALL-1210
Procedures
AD-EG-ALL-1211
System Performance Monitoring and Trending
Procedures
AD-OP-ALL-0201
Protected Equipment
Engineering
Changes
20980
Evaluation of 1NC-2 As Found Left Setpoint Test Results -
M1R28
Procedures
AD-EG-ALL-1211
System Performance Monitoring and Trending
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
AD-EG-ALL-1451
Relief Valve Component Program
AD-OP-ALL-0102
Operability Decision Making
AD-OP-ALL-0105
Operability Determinations and Functionality Assessment
AD-EG-ALL-1155
Post Modification Testing
Procedures
PT/1/A/4350/019
A
1A D/G Governor and Voltage Regulator Benchmark
Comparison Test
AD-EG-ALL-1202
Preventive Maintenance and Surveillance Testing
Administration
AD-EG-ALL-1720
Inservice Testing (IST) Program Implementation
Procedures
AD-WC-ALL-0250
Work Implementation and Completion
21-02
M2R27 21-02 Fleet Reactor Services (Rx Head Team)
ALARA Plan, Revision 0 [Including in-progress reviews and
ALARA Critique]
11/11/2021
ALARA Plans
21-08
M2R27 21-08 Steam Generator Work ALARA Plan,
Revision 0 and Revision 2 [Including in-progress reviews
and ALARA Critique]
11/11/2021
Unanticipated SRD dose rate alarm
09/25/2020
Corrective Action
Documents
AR02400516, and
Various
McGuire Nuclear Station Radiological Key Roster [High
Radiation, Locked High Radiation, and Very High Radiation
Area key control Log]
03/31/2022
Spent Fuel Pool Non-SNM Item Inventory
11/2021
M1R28 Dose Reports [Summary report issue twice daily
including outage exposure tracking totals vs. goal and
breakdown by Radiation Work Permit (RWP) number]
04/04/2022 thru 04/22/2022
Various
Site ALARA
Committee
Meeting Minutes
10/16/2021, 12/13/2021, and 03/01/2022
Various
Miscellaneous
TSR 22-108
Temporary Shielding Request (TSR) - U-1 Lower
08/25/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Containment around Pressurizer Relief Tank
TSR 22-125
Temporary Shielding Request - Unit 1 Lower Containment 3"
NV piping B/C pipe chase
2/17/2022
Procedures
HP/0/B/1003/063
Routine Surveillance [Radiological]
MNS-M-
220406-15
Initial Under Head Survey
04/07/2022
MNS-M-
220408-19
Mark and Cut Drive Nozzle F12 & K12
04/08/2022
MNS-O-
220406-5
Aux Bldg - Misc - Spent Fuel Pool
04/07/2022
Radiation
Surveys
Survey # MNS-M-
220402-1 thru
MNS-M-
220402-13,
MNS-M-
220402-15,
MNS-M-
220402-19, and
MNS-M-
220402-20
Unit 1 (U-1) initial entry radiation and contamination surveys
after shutdown
04/02/2022
RWP # 11
Spent Fuel Pool Activities (Excluding Refueling)
RWP # 1332
U-1 Outage: Under Head Inspections and cutting of PLDR's,
Preps for Peening
Radiation Work
Permits (RWPs)
RWP# 1332
U-1 Outage: Under Head Inspections and cutting of PLDR's,
Preps for Peening
Self-Assessments AR02363388
21 Field Operations Self Assessment
2/28/2021
Corrective Action
Documents
2361270,
AR02363386, and
Various
Air Sample ID:
254
Air Quality Analysis Report
03/10/2022
Miscellaneous
Air Sample ID:
256
Air Quality Analysis Report
10/25/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Air Sample ID:
250
Air Quality Analysis Report
10/11/2021
Air Sample ID:
255
Air Quality Analysis Report
2/03/2022
RWP 1332
TEDE ALARA Screening evaluation
RWP 1701
TEDE ALARA Screening evaluation
RWP 1702
TEDE ALARA Screening evaluation
RWP-1700
TEDE ALARA Screening evaluation
Various
Respirator Fit Test Records
Various
Various
SCBA Use Training Records
Various
AD-RP-ALL-0003
RADIOLOGICAL AIR SAMPLING
AD-RP-ALL-0008
USE AND CONTROL OF HEPA FILTRATION AND
VACUUM EQUIPMENT
AD-RP-ALL-0010
RADIOLOGICAL JOB COVERAGE
AD-RP-ALL-2014
WORK IN ALPHA ENVIRONMENTS
AD-RP-ALL-6001
QUANTITATIVE FIT TESTING
AD-RP-ALL-6002
INSPECTIONS OF SELF-CONTAINED BREATHING
APPARATUS (SCBA) AND ASSOCIATED EQUIPMENT
AD-RP-ALL-6005
POWERED AIR-PURIFYING RESPIRATORS
AD-RP-ALL-7004
OPERATION OF AIR SAMPLING EQUIPMENT
Procedures
AD-TQ-ALL-0081
BASIC RESPIRATORY PROTECTION TRAINING
Self-Assessments 02363386-05,
2361270-01
Respiratory Protection
258001-01
PT/1/A/4450/001E 1VP FILTER TEST
299507-01
PT/2/A/4450/001B 2VA FILTER TEST
20330860-01
PT/2/A/4450/001E 2VP FILTER TEST
20366719-01
PT/1/A/4450/001E 1VP FILTER TEST
20418590-01
PT/1/A/4450/001B 1VA FILTER TEST
Work Orders
20440688-01
PT/2/A/4450/001E 2VP FILTER TEST
21 (M2R27) Alpha Characterization [per AD-RP-ALL-
2015, Alpha Radiation Characterization]
2/07/2021
Calculations
Dosimetry
Technical Report:
MNS (McGuire Nuclear Station) MAGNASTOR ISFSI
(Independent Spent Fuel Storage Installation) Neutron
04/23/2015
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
15-01
Energy Evaluation
AR02352602, and
Various
Corrective Action
Documents
AR02397852, and
Various
NVLAP Certificate of Accreditation to ISO/IEC 17025:2005,
NVLAP LAB CODE: 100505-0 Effective Dates: 2020-04-01
through 2021-03-31
NVLAP Certificate of Accreditation to ISO/IEC 17025:2017,
NVLAP LAB CODE: 100505-0 Effective Dates: 2021-10-01
through 2022-03-31
NVLAP Certificate of Accreditation to ISO/IEC 17025:2017,
NVLAP LAB CODE: 100505-0 Effective Dates: 2022-04-01
through 2023-03-31
Miscellaneous
AD-RP-ALL-2015
Alpha Radiation Characterization - 2021 (M2R27) Alpha
Characterization
2/7/2021
AD-RP-ALL-4005
Dose Management
AD-RP-ALL-4010
Internal Dose Assessment
AD-RP-ALL-4015
Dosimetry in Gradient Radiation Fields
AD-RP-ALL-4016
Declared Pregnant Worker
AD-RP-ALL-7008
Apex InVivo Whole Body Counter Operation, Quality Checks
and Data Review
Procedures
CDS-RP-ALL-
0416
Prospective Determination for Occupational Exposure
Radiation
Surveys
Area DLR Monitoring Report, 3rd Trimester 2021
2/23/2022
2305430-05
MNS External Dosimetry Self Assessment
11/05/2020
Self-Assessments
2357028
21 Duke Energy Dosimetry Lab Internal Audit [Simulated
NVLAP (National Voluntary Laboratory Accreditation
07/09/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Program) on-site assessment]
2363386-05 and
2361270-01
MNS Internal Dosimetry Self Assessment
01/05/2022
AD-RP-ALL-7007
Apex InVivo Whole Body Counter Calibration
10-08-2021
HP/0/B/1001/045
Calibration of Packard Tri-Carb 2900 TR and 3110 TR Liquid
Scintillation Counters
07/27/2021
HP/0/B1001/048
Calibration of Apex Gamma Spectroscopy System-Source
Certificates Creation 2021 Q3
10/08/2021
Calibration
Records
HP/0/B1001/048
Calibration of Apex Gamma Spectroscopy System-Efficiency
Verifications 2021 Q3
10/10/2021
Corrective Action
Documents
AR02407688, and
Various
AD-RP-ALL-7006
GEM-5 - Weekly Response Checklist for Month April 2022
April 2022
Miscellaneous
AD-RP-ALL-7006
TEM - Weekly Response Checklist for Month April 2022
April 2022
HP/0/B/1001/045
Calibration of Packard Tri-Carb 2900 TR and 3110 TR Liquid
Scintillation Counters
HP/0/B/1001/048
Calibration of Apex Gamma Spectroscopy System
Procedures
HP/0/B/1009/006
Procedure for Quantifying High Level Radioactivity Releases
During Accident Conditions
20351152-03,
20456922-01,
20039840-01,
2037877-01
0-EMF-50L and 0-EMF-50H Calibrations
Various
Work Orders
20448831-01,
20309402-01,
2134173-01, and
20426943-01
0-EMF-49L and 0-EMF-49H Calibrations
Various
71151
Corrective Action
Documents
09/25/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
McGuire Electronic Dosimeter Dose Rate Alarm Logs for the
period 8/1/2021 to 3/1/2022
03/01/2022
McGuire Electronic Dosimeter Dose Alarm Logs for the
period 8/1/2021 to 3/1/2022
03/01/2022
AD-CP-DEC-0021
Projected Offsite Dose from Radioactive Effluents
2/09/2022
OpenEMS Permit
- G2021379
OpenEMS Permit #G2021379
2/28/2022
Miscellaneous
OpenEMS Permit
- L2021926
OpenEMS Permit #L2021926
2/28/2022
AD-LS-ALL-0004
NRC Performance Indicators and Monthly Operating Report
Procedures
AD-PI-ALL-0100
Corrective Action Program
AD-LS-ALL-0006
Notification/Reportability Evaluation
AD-PI-ALL-0100
Corrective Action Program
Procedures
AD-PI-ALL-0105
Effectiveness Reviews