IR 05000369/2022003

Integrated Inspection Report 05000369/2022003 and 05000370/2022003

ML22300A002
Person / Time
Site:	McGuire, Mcguire
Issue date:	10/27/2022
From:	Eric Stamm Division Reactor Projects II
To:	Pigott E Duke Energy Carolinas
References
IR 2022003
Download: ML22300A002 (14)

Text

SUBJECT:

MCGUIRE NUCLEAR STATION - INTEGRATED INSPECTION REPORT 05000369/2022003 AND 05000370/2022003

Dear Edward Pigott:

On September 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at McGuire Nuclear Station. On October 25, 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.October 27, 2022 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: NPF-9 and NPF-17

Report Numbers: 05000369/2022003 and 05000370/2022003

Licensee: Duke Energy Carolinas, LLC

Facility: McGuire Nuclear Station

Location: Huntersville, North Carolina

Inspection Dates: July 1, 2022, to September 30, 2022

Inspectors: A. Hutto, Senior Resident Inspector C. Scott, Resident Inspector F. Young, Resident Inspector, Acting

Approved By: Eric J. Stamm, Chief Reactor Projects Branch 1 Division of Reactor Projects

Enclosure

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

Failure to Implement Equipment Control Procedure Resulted in Loss of Control Room Area Chilled Water System Safety Function Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.12] - Avoid 71153 Systems NCV 05000369,05000370/2022003-01 Complacency Open/Closed A self-revealed Green finding and associated non-cited violation of Technical Specification (TS) 5.4.1 was identified for the licensees failure to implement their administrative tagout procedure. Specifically, the licensee did not implement the requirements of licensee procedure, AD-OP-ALL-0200, Clearance and Tagging, and inadvertently disabled an in-service component on the remaining operable train of control room area chilled water system (CRACWS). This rendered both trains of CRACWS inoperable simultaneously and resulted in a loss of safety function for approximately 35 minutes.

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000370/2022-001-00 LER 2022-01-00 for McGuire 71153 Closed Nuclear Station, Unit 2, Valid Actuation of the Unit 2 Reactor Protection System and Auxiliary Feedwater System LER 05000369,05000370/ LER 2022-001-00 for McGuire 71153 Closed 2022-001-00 Nuclear Station, Units 1 and 2,

Both Control Room Area Chilled Water System Trains Inoperable Due to Human Error

PLANT STATUS

Unit 1 operated at or near 100 percent rated thermal power (RTP) for the entire 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.

71111.01 - Adverse Weather Protection

Impending Severe Weather Sample (IP Section 03.02) (2 Samples)

(1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe weather (extended period of extreme high temperatures) on July 24, 2022.

(2) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe weather due to Hurricane Ian remnants on September 29, 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 2 "A" train of auxiliary feedwater (CA) system on July 15, 2022

(2) Unit 1 "B" train of CA system on July 20, 2022

(3) Unit 2 "B" diesel generator on August 26, 2022

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (3 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) Battery rooms on August 4, 2022

(2) Service building on August 9, 2022

(3) Unit 1 A train switchgear and electrical penetration rooms on September 16, 2022

Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the onsite fire brigade training and performance during an announced fire drill on September 2, 2022. The fire scenario involved a fire in the 1ETA vital switchgear air conditioning equipment room.

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 auxiliary building 695' elevation

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 Unit 1 reactor control rod movement testing on August 1, 2022.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated active simulator exam ASE-102 on August 31, 2022. The scenario involved a failed steam generator power operated relief valve, followed by a loss of letdown and a reactor coolant system leak.

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 (SSCs) remain capable of performing their intended function:

(1) Nuclear condition report (NCR) 2429236, 1NV-849AC failed to open from the control room, on May 28, 2022

(2) NCR 2430759, 1B diesel generator failed to develop voltage and frequency during slow start, on June 22, 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) Equipment protection plan for vital battery EVCD inspections, on July 6, 2022

(2) Equipment protection plan for the Unit 2 Magnastor spent fuel cask loading campaign, on August 1, 2022

(3) Equipment protection plan for Unit 1 B train component cooling water breaker preventive maintenance (PMs), on August 8, 2022

(4) Equipment protection plan for Unit 2 A train residual heat removal pump breaker PMs, on August 22, 2022

(5) Equipment protection plan for the Unit 2 B train lower containment ventilation unit out of service due to cooling coil leaks, on September 28, 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 2433210, 2022 MNS-1 documentation of thermal fatigue analysis/results

(2) NCR 2435677, wear observed on 2B diesel generator fuel oil supply tubing

(3) NCR 2437869, results for ND-62 indicate not water solid

(4) NCR 2440809, 1A diesel generator indication anomaly identified during unavailability monitoring

(5) NCR 2442167, 1A auxiliary feedwater pump abnormal decrease in differential pressure during in-service test

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) Engineering change (EC) 419655, Replace Dresser Relief Valve 1ND-0061 Equivalent

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:

(1) PT/2/A/4350/002 B, "Diesel Generator 2B Operability Test," following fluid checks, on August 1, 2022

(2) OP/2/A/6400/005, "Component Cooling Water (KC) System," Attachment 5, "KC Pump Functional Verification," following 2A1 and 2A2 KC pump motor breaker PMs, on August 8, 2022

(3) PT/1/A/4350/002 A, "Diesel Generator 1A Operability Test," following relay replacements, on September 25, 2022

(4) PT/2/A/4350/002 B, "Diesel Generator 2B Operability Test," following verification of integrity for remote circuit breaker indicator circuits, on September 27, 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) (4 Samples)

(1) PT/0/A/4350/028 B, "125 Volt Vital Battery Quarterly Inspection," on August 8, 2022

(2) PT/2/A/4350/002 A, "2A Diesel Generator Operability Test," on August 16, 2022

(3) PT/2/A/4350/046 D, "Auxiliary Shutdown Panel Controls Verification for A Train Components," on August 29, 2022

(4) PT/1/A/4206/001/B, "1B NI Pump Performance Test," on September 5, 2022

Inservice Testing (IP Section 03.01) (1 Sample)

(1) PT/2/A/4252/001, "#2 TD CA Pump Performance Test," on July 24, 2022

71114.06 - Drill Evaluation

Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)

The inspectors evaluated:

(1) McGuire Emergency Preparedness Drill 22-02 involving the reactor failing to trip following a turbine trip and a small break loss of coolant accident, on August 17,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

MS08: Heat Removal Systems (IP Section 02.07)===

(1) Unit 1 (July 1, 2021 - June 30, 2022)

(2) Unit 2 (July 1, 2021 - June 30, 2022)

MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)

(1) Unit 1 (July 1, 2021 - June 30, 2022)

(2) Unit 2 (July 1, 2021 - June 30, 2022)

MS10: Cooling Water Support Systems (IP Section 02.09) (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) NCR 2438984, 2VX-1A actuator grease degraded to unsatisfactory condition

71153 - Follow Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 05000370/2022-001-00, Valid Actuation of the Unit 2 Reactor Protection System and Auxiliary Feedwater System (ADAMS Accession No. ML22109A027). The cause of the actions described in the LER were the result of a manual reactor trip performed by the operators in response to erratic turbine control valve movements as a result of a random failure in a nonsafety-related turbine controls power supply. The inspectors determined that it was not reasonable to foresee or correct the cause discussed in the LER therefore no performance deficiency was identified. The inspectors did not identify a violation of NRC requirements.

(2) LER 05000369, 05000370/2022-001-00, Both Control Room Area Chilled Water System Trains Inoperable Due to Human Error (ADAMS Accession No. ML22230C557). The inspection conclusions associated with this LER are documented in this report under Inspection Results Section

INSPECTION RESULTS

Failure to Implement Equipment Control Procedure Resulted in Loss of Control Room Area Chilled Water System Safety Function Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.12] - Avoid 71153 Systems NCV 05000369,05000370/2022003-01 Complacency Open/Closed A self-revealed Green finding and associated non-cited violation of Technical Specification (TS) 5.4.1 was identified for the licensees failure to implement their administrative tagout procedure. Specifically, the licensee did not implement the requirements of licensee procedure, AD-OP-ALL-0200, Clearance and Tagging, and inadvertently disabled an in-service component on the remaining operable train of control room area chilled water system (CRACWS). This rendered both trains of CRACWS inoperable simultaneously and resulted in a loss of safety function for approximately 35 minutes.

Description:

On June 21, 2022, the licensee approved the hanging of a clearance (OPS-0-22-YC-CH0005-0814) in support of maintenance on the A CRACWS chiller and subsequently declared the A train of CRACWS inoperable. The B train CRACWS chiller was in operation. While hanging the A train CRACWS clearance, a non-licensed operator incorrectly identified and opened the B train CRACWS oil pump breaker. This action was contrary to the licensees administrative procedure for implementing tagouts, AD-OP-ALL-0200, section 4.11, which specifies that the tag hanger shall, Identify the component to be manipulated by matching the component label with the equipment ID provided on the tag list.

Opening the B train oil pump breaker inadvertently tripped the B train of CRACWS, rendering it inoperable. As a result, control room operators entered Abnormal Procedure AP-39, Control Room High Temperature. Operators were successful in closing the incorrect breaker and restarting the B CRACWS chiller. The B train of CRACWS was inoperable for approximately 35 minutes. The maximum temperature measured in the control room was 81.4°F with a TS surveillance upper limit of 90°F. Additionally, the licensee made a notification to the NRC per 10 CFR 50.72(b)(3)(v)(D) for the loss of safety function.

Corrective Actions: The licensee performed a cause investigation which resulted in additional corrective actions including stand-downs with plant personnel to communicate issue lessons-learned relative to procedure use and adherence and clearance briefs, temporarily implemented peer-check controls for plant operations, identified gaps in equipment protection and risk mitigation implementation, and assessed performance trends in procedural compliance.

Corrective Action References: NCR 2432084, B Control Area Chiller Trip

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-0-22-YC-CH0005-0814 was 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 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. Specifically, failure to avoid complacency and properly identify the proper component per procedure resulted in the unplanned inoperability of a TS-required nuclear safety-related system.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding was determined to be of very low safety significance (green) as all Exhibit 2 questions were answered no.

Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. Specifically, the non-licensed operator did not implement the licensees risk reduction tools, namely self-checking, while implementing clearance OPS-0-22-YC-CH0005-0814.

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, Identify the component to be manipulated by matching the component label with the equipment ID provided on the tag list.

Contrary to the above, on June 21, 2022, the licensee failed to implement licensee procedure AD-OP-ALL-0200. Specifically, the tag hanger incorrectly identified and positioned the B train CRACWS oil pump breaker instead of the corresponding component on the A train as indicated on the issued tag list for clearance OPS-0-22-YC-CH0005-0814.

Enforcement Action: This violation is being treated as a 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 October 25, 2022, the inspectors presented the integrated inspection results to Ed Pigott and other members of the licensee staff.

THIRD PARTY REVIEWS

Inspectors reviewed Institute on Nuclear Power Operations reports that were issued during the inspection period.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title

Procedure

71111.01 Procedures RP/0/B/5700/027 Severe Weather Preparations

71111.04 Procedures OP/1/A/6250/002 Licensee Operating Procedure for aux feedwater (CA)

system

71111.04 Procedures OP/2/A/6250/002 Auxiliary Feedwater System

71111.05 Drawings MFSD-013 Vital Battery Room

71111.05 Drawings MFSD-015.017 1ETA/750 Electrical Penetration Room

71111.05 Procedures AD-EG-ALL-1520 Transient Combustible Control

71111.06 Procedures AP/0/A/5500/044 Plant Flooding

71111.11Q Procedures AD-OP-ALL-1000 Conduct of Operations

71111.12 Procedures AD-EG-ALL-1204 Single Point Vulnerability Identification, Elimination and

Mitigation

71111.12 Procedures AD-EG-ALL-1206 Equipment Reliability Classification

71111.12 Procedures AD-EG-ALL-1209 System, Component and Program Health Reports and

Programs

71111.12 Procedures AD-EG-ALL-1210 Maintenance Rule Program

71111.12 Procedures AD-EG-ALL-1211 System Performance Monitoring and Trending

71111.13 Procedures AD-OP-ALL-0201 Protected Equipment

71111.13 Procedures AD-OP-ALL-0204 Plant Status Control

71111.13 Procedures AD-WC-ALL-0204 On-line Risk Management Process

71111.15 Procedures AD-EG-ALL-1211 System Performance Monitoring and Trending

71111.15 Procedures AD-OP-ALL-0102 Operability Decision Making

71111.15 Procedures AD-OP-ALL-0105 Operability Determinations and Functionality Assessment

71111.18 Engineering EC 419655 Replace Dresser Relief Valve 1ND-0061 Equivalent

Changes

71111.19 Procedures AD-EG-ALL-1155 Post Modification Testing

71111.22 Procedures AD-EG-ALL-1202 Preventive Maintenance and Surveillance Testing

Administration

71111.22 Procedures AD-EG-ALL-1720 In-service Testing (IST) Program Implementation

71111.22 Procedures AD-WC-ALL-0250 Work Implementation and Completion

71151 Procedures AD-LS-ALL-0004 NRC Performance Indicators and Monthly Operating Report

71151 Procedures AD-PI-ALL-0100 Corrective Action Program

Inspection Type Designation Description or Title

Procedure

71153 Corrective Action AD-PI-All-0106 Cause Investigation Checklist PIRT 2432084-03

Documents

71153 Engineering AD-EG-ALL-1311 Failure Investigation Process for NCR 2416694, Unit 2

Evaluations Turbine Runback/Manual Trip

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