IR 05000413/2021002
| ML21217A103 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 08/05/2021 |
| From: | Eric Stamm NRC/RGN-II/DRP/RPB1 |
| To: | Simril T Duke Energy Carolinas |
| References | |
| IR 2021002 | |
| Download: ML21217A103 (19) | |
Text
August 5, 2021
SUBJECT:
CATAWBA NUCLEAR STATION - INTEGRATED INSPECTION REPORT 05000413/2021002 AND 05000414/2021002
Dear Mr. Simril:
On June 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Catawba Nuclear Station. On July 28, 2021, 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 Catawba 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 Catawba 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/
Eric J. Stamm, Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Nos. 05000413 and 05000414 License Nos. NPF-35 and NPF-52 Enclosure:
As stated Distribution via LISTSERV
ML21217A103 X Non-Sensitive X Publicly Available X SUNSI Review Sensitive Non-Publicly Available OFFICE RIIDRP RIIDRP RIIDRP RIIDRP NAME J.Austin C.Scott R.Taylor E.Stamm DATE 08/03/2021 08/05/2021 08/02/2021 08/05/2021
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Numbers: 05000413 and 05000414 License Numbers: NPF-35 and NPF-52 Report Numbers: 05000413/2021002 and 05000414/2021002 Enterprise Identifier: I-2021-002-0021 Licensee: Duke Energy Carolinas, LLC Facility: Catawba Nuclear Station Location: York, South Carolina Inspection Dates: April 1, 2021 to June 30, 2021 Inspectors: J. Austin, Senior Resident Inspector C. Scott, Resident Inspector S. Downey, Senior Reactor Inspector M. Magyar, Reactor Inspector A. Nielsen, Senior Health Physicist W. Pursley, Health Physicist D. Rivard, Resident Inspector J. Rivera, Health Physicist 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 Catawba 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 Meet Minimum Dewatering Requirements for Radioactive Waste Sent Directly for Burial Cornerstone Significance Cross-Cutting Report Aspect Section Public Radiation Green [H.1] - 71124.08 Safety NCV 05000413,05000414/2021002-01 Resources Open/Closed A self-revealing, Green, Non-Cited violation of 10 CFR 20 Appendix G.III.A.1 occurred when the licensee transferred solid radioactive waste to the Barnwell Waste Disposal Facility that did not meet the waste characterization requirements in 10 CFR 61.56(a)(3) for free standing liquid.
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 and returned to 99 percent RTP on May 7, 2021. 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 and regional 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, increasing the amount of time on site as local COVID-19 conditions permitted.
As part of their onsite activities, resident inspectors 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 a 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 seasonal hot temperatures for the following systems:
1. Unit 1 and Unit 2 service water pumphouse 2. The Safe Shutdown Facility (SSF)
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) 1A emergency diesel generator (EDG) on April 24, 2021
- (2) Unit 1 and 2 service water room pumphouse on June 30, 2021
- (3) Unit 1 outside Doghouse (penetration room) on June 30, 2021
- (4) Unit 1 and 2 EDG fuel oil transfer station on June 30, 2021
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the SSF on June 30, 2021.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 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 rooms on April 17, 2021
- (2) Unit 2 blackout room on April 17, 2021
- (3) Unit 1 blackout room on April 17, 2021
- (4) Unit 2 6.9 KV rooms on April 17, 2021
- (5) Unit 2 lower containment on April 29, 2021
71111.08P - Inservice Inspection Activities (PWR) PWR Inservice Inspection Activities Sample (IP Section 03.01)
- (1) The inspectors evaluated pressurized water reactor non-destructive testing by reviewing the following examinations from April 12 - 30, 2021:
1. Ultrasonic Testing a. 2RPV-101-104B, Head to Head (meridional), ASME Class 1 (reviewed)b. 2RPV-HEAD-PEN-10, CRDM Nozzle, ASME Class 1 (reviewed)c. 2RPV-HEAD-PEN-60, CRDM Nozzle, ASME Class 1 (reviewed)d. 2RPV-HEAD-PEN-74, CRDM Nozzle, ASME Class 1 (reviewed)2. Magnetic Particle Testing a. 2PZR-SKIRT, Pressurizer Support Skirt to Head, ASME Class 1 (reviewed)3. Penetrant Testing a. 2RPV-HEAD-PEN-67, Base Metal Repair, ASME Class 1 (reviewed)b. 2RPV-HEAD-PEN-74, CRDM Nozzle to RVCH Shell Weld Surface, ASME Class 1 (reviewed)4. Eddy Current Examination a. Steam Generator 2A: ET for tube R44C23 b. Steam Generator 2B: ET for tube R6C45 c. Steam Generator 2C: ET for tubes R44C81 and R49C60 d. Steam Generator 2D: ET for tubes R43C78 and R48C61 The Inspectors evaluated the licensees boric acid corrosion control program 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 Unit 2 reactor start-up following the refueling outage on May 2, 2021.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator simulator requalification training consisting of a steam generator (S/G) tube leak, S/G tube rupture, loss of all AC, and a seismic event on May 25, 2021.
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) 2381270, Unit 2 turbine driven auxiliary feed (TDAFW) pump inoperable, on May 6, 2021
- (2) NCR 2383190, Unit 2 protection power supply failure, on May 20, 2021
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) Unit 2 risk analysis following an auxiliary feed actuation, on May 1, 2021
- (2) Protected equipment plan review while 1A EDG out of service (OOS) for maintenance, on May 11, 2021
- (3) Protected equipment plan review while replacing Unit 2 protective channel power supply, on May 20, 2021
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (3) NCR 2378803, 2 SSPSB failed permissive test, on April 19, 2021
- (4) NCR 2377775, power range (2n44) showing low insulation resistance, on April 20, 2021
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) 415639 install high point vents on EDG 1A and 1B lube oil systems on June 29, 2021
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) Work Order (WO) 20408271-02, functional test following cleaning of the 2A Heat Exchanger, on April 27, 2021
- (2) WO 20259243, breaker refurbishment, on April 28, 2021
- (4) NCR 23883190, Unit 2 SSPS (channel 3) power supply failure, on May 21, 2021
- (5) WO 2030746, perform F instrument air compressor surge test, on May 24, 2021
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated refueling outage C2R24 activities from March 27, 2021 to May 3, 2021.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) PT/2/A/4200/009, Engineering Safety Features Actuation Periodic Test, on
April 19, 2021 RCS Leakage Detection Testing (IP Section 03.01) (1 Sample)
- (1) PT/2/A/4150/001 D reactor coolant system (NC) system leakage calculation, on
May 14, 2021 Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)
- (1) PT/2/A/4200/001 C as left containment isolation valve leak rate test, on April 28, 2021
Ice Condenser Testing (IP Section 03.01) (1 Sample)
- (1) PT/2/A/4200/014 D ice condenser top deck door inspection, on April 30,
RADIATION SAFETY
71124.06 - Radioactive Gaseous and Liquid Effluent Treatment
Walkdowns and Observations (IP Section 03.01) (3 Samples)
The inspectors evaluated the following radioactive effluent systems during walkdowns:
- (1) Unit 1 Plant Vent and associated effluent monitors 1-EMF-35 and 1-EMF-36
- (2) Waste Monitor Tank Building (gaseous pathway) and associated effluent monitor 0-EMF-58
- (3) Waste Monitor Tank Building (liquid pathway) and associated effluent monitor 0-EMF-
Sampling and Analysis (IP Section 03.02) (3 Samples)
Inspectors evaluated effluent samples, sampling processes and compensatory samples, as available.
- (1) Unit 2 containment air for VQ system releases, particulate, iodine, noble gas
- (2) Compensatory sampling records for 1-EMF-36, plant vent monitor, out of service. August 24, 2020 and April 9, 2021
- (3) Waste Monitor Tank Building liquid discharge
Dose Calculations (IP Section 03.03) (2 Samples)
The inspectors evaluated the following dose calculations:
- (1) Projected Offsite Dose from Radioactive Effluents, March 2021
- (2) Projected Offsite Dose from Radioactive Effluents, April 2021
Abnormal Discharges (IP Section 03.04) (2 Samples)
The inspectors evaluated the following abnormal discharges:
- (1) Waste Gas Shutdown Decay Tank A pressure drop, July 30, 2020
- (2) Waste Gas Decay Tank D downward pressure trend, February 25, 2021 -
March 2, 2021
71124.07 - Radiological Environmental Monitoring Program
Environmental Monitoring Equipment and Sampling (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated environmental monitoring equipment and observed collection of environmental samples.
Radiological Environmental Monitoring Program (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the implementation of the licensees radiological environmental monitoring program.
GPI Implementation (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the licensees implementation of the Groundwater Protection Initiative program to identify incomplete or discontinued program elements.
71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &
Transportation
Radioactive Material Storage (IP Section 03.01)
- (1) Inspectors evaluated the licensees performance in controlling, labeling, and securing radioactive materials in the unit one auxiliary building Waste Solidification Facility.
- (2) Inspectors evaluated the licensees performance in controlling, labeling, and securing radioactive materials in the Radioactive Material Storage Building.
- (3) Inspectors evaluated the licensees performance in controlling, labeling, and securing radioactive materials at the independent spent fuel storage facility radioactive storage area.
Radioactive Waste System Walkdown (IP Section 03.02) (3 Samples)
- (1) Inspectors walked down accessible portions of the solid radioactive waste systems and evaluated system configuration and functionality in the Waste Solidification Building.
- (2) Inspectors walked down accessible portions of the high flow demineralization skid in the waste monitor tank building.
- (3) Inspectors walked down accessible portions of the low flow demineralization skid in the waste monitor tank building.
Waste Characterization and Classification (IP Section 03.03) (3 Samples)
- (1) The inspectors evaluated the licensees characterization and classification of Powdex Storage Tank resin performed on September 20, 2020.
- (2) The inspectors evaluated the licensees characterization and classification of Resin Batch Tank resin performed on April 26, 2021.
- (3) The inspectors evaluated the licensees characterization and classification of Dry Active Waste Composite Solid performed on October 8, 2019.
Shipping Records (IP Section 03.05) (3 Samples)
The inspectors evaluated the following non-excepted radioactive material shipments through a record review:
- (1) Radioactive Shipment Number RSR-20-02, UN3321, LSA II, Demineralizer Resin
- (2) Radioactive Shipment Number RSR-21-07, UN3321, LSA II, Demineralizer Resin
- (3) Radioactive Shipment Number RSR-20-16, UN2916, Radioactive Material Type B(U),
Primary Demineralizer Resin
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS06: Emergency AC Power Systems (IP Section 02.05) ===
- (1) Unit 1 (April 1, 2020 - March 31, 2021)
- (2) Unit 2 (April 1, 2020 - March 31, 2021)
MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)
- (1) Unit 1 (April 1, 2020 - March 31, 2021)
- (2) Unit 2 (April 1, 2020 - March 31, 2021)
MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)
- (1) Unit 1 (April 1, 2020 - March 31, 2021)
- (2) Unit 2 (April 1, 2020 - March 31, 2021)
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) May 23, 2020 through April 30, 2021
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 resolution of adverse conditions 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 2372969, operability concerns with residual heat removal system on June 21,
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
71003 - Post-Approval Site Inspection for License Renewal Post-Approval Site Inspection for License Renewal
- (1) The inspectors observed the implementation of the following license renewal activities (listed by aging management program, as identified by Updated Final Safety Analysis Report, Technical Specification Chapter or Surveillance Requirement) from April 26 -
May 14, 2021:
1. Borated Water Stainless Steel Inspection, UFSAR 18.2.2 a. WO 20286000 02, 2NS PP SYS: UT Weld Number 2NS27-8 and Heat-Affected Zone 2. Containment Inservice Inspection Plan - IWE, UFSAR 18.2.5 a. WO 20289917 01, PT/2/A/4200/78, Containment Structural Integrity Insp. (General Visual Insp. Preoutage)3. Containment Leak Rate Testing Program Aging Management Program, ITS 3.6.1 & ITS 5.5.2 a. WO 20408075 01, PT/2/A/4200/01J SF6 Gas LRT 4. Divider Barrier Seals Inspection and Testing Program, ITS SR 3.6.14.2 &
.4 &
.5 a. WO 20408957 01, 2NF DR LAD: Insp I/C Access Dr Seal, dated April
30, 2021 5. Flow-Accelerated Corrosion Program, UFSAR 18.2.9 a. WO 20379481 01, 2HS EC E2HS116: Perform FAC Inspection on 32HS116 in C2R24 6. Fluid Leak Management Program, UFSAR 18.2.10 a. WO 20407989 02, PT/2/A/4150/01H (OPS) Inside Cont. Boric Acid Check 7. Heat Exchanger Activities: Component Cooling Heat Exchangers, UFSAR 18.2.12.1 a. WO 20408271 01, 2KC HX A: Test/Clean Heat Exchanger 8. Heat Exchanger Activities: Diesel Generator Engine Cooling Water Heat Exchangers, UFSAR 18.2.12.3 a. WO 20362713 01, 2KC HX B; Perform Eddy Current Testing of Tubes
9. High-Range Radiation and Neutron Flux Instrumentation Circuits, ITS 3.3.1 &
ITS 3.3.3 a. WO 20397475 01, 2EMF: Perform Channel Cal on 2EMF53B 10. Ice Condenser Engineering Inspection Program, UFSAR 18.2.13 a. WO 20407519 02, 2NF Ice Basket: Unload/Reload Ice Baskets 11. Inaccessible Non-EQ Medium Voltage Cables Aging Management Program, UFSAR 18.2.14 a. WO 20407565 01, U2 Offline Inspection of Cable in License Renewal Structures 12. Inservice Inspection Plan, UFSAR 18.2.15 a. WO 20347400 03, 2NI PP SYS: Perform ISI (R1.16 UT) on 2NI185-18 Pipe to Elbow 13. Liquid Waste System Inspection, UFSAR 18.2.17 a. WO 20368990 06, 2WL-321: Engineering to Review License Inspection Results 14. Reactor Vessel Internals Inspection Program, UFSAR 18.2.21 a. WO 20408099 01, 2ENA-Eddy Current Incore Flux Thimbles 15. Steam Generator Surveillance, ITS 5.5.9 a. WO 20415441 03, Perform E/C Test on S/G-2A
INSPECTION RESULTS
Observation: Implementation of Acceptance Criteria 71003 Regarding two aging management programs (Borated Water Stainless Steel Inspection and Liquid Waste Inspection), the inspectors noted two instances involving the following circumstances:
- In the License Renewal Application (Application to Renew the Operating Licenses of McGuire Nuclear Station, Units 1 & 2 and Catawba Nuclear Station, Units 1 & 2 -
Technical Information, ADAMS Accession No. ML011660145), the licensee provided generic acceptance criteria for inspections that would be performed as part of the aging management process.
- By letter dated January 28, 2002 (Letter from Rani L. Franovich to Mr. M. S. Tuckman, Request for Additional Information for the Review of the McGuire Nuclear Station, Units 1 and 2, and Catawba Nuclear Station, Units 1 and 2, License Renewal Application (LRA), ADAMS Accession No. ML020310200), in Request for Additional Information (RAI) 3.4-2, the staff asked the licensee to provide more specific acceptance criteria.
- By letter dated March 15, 2002 (Letter from Ken S. Canady to U.S. Nuclear Regulatory Commission Response to Requests for Additional Information in Support of the Staff Review of the Application to Renew the Facility Operating Licenses of McGuire Nuclear Station, Units 1 & 2 and Catawba Nuclear Station, Units 1 & 2, ADAMS Accession No. ML020810451), the licensee stated that the specific acceptance criteria would be developed at the time of the inspections.
- In Section 3.0.3.1.2 of the Safety Evaluation Report (SER; NUREG-1772, Safety Evaluation Report Related to the License Renewal of McGuire Nuclear Station, Units 1 and 2, and Catawba Nuclear Station, Units 1 and 2, ADAMS Accession No.
ML030850164), the staff accepted this response and closed out RAI 3.4-2.
- Upon review of these inspection activities during this Phase 1 inspection, the inspectors noted that the procedures used by field personnel still contained the generic criteria, indicating that the licensee had not developed specific acceptance criteria for each activity.
The inspectors interviewed licensee personnel and reviewed associated documentation and determined that the activities had been conducted in a quality manner, and - given the skill of the craft of the field personnel performing the activities - any degradation that would have warranted corrective action would have been identified. No such degradation was evident in either inspection.
Based on this information, the inspectors determined that no finding existed for this issue. The licensee acknowledged the issue and entered it into their Corrective Action Program (NCR 02383078) and will evaluate whether the associated documentation needs to be revised to clarify the manner in which the acceptance criteria were applied.
Failure to Meet Minimum Dewatering Requirements for Radioactive Waste Sent Directly for Burial Cornerstone Significance Cross-Cutting Report Aspect Section Public Radiation Green [H.1] - 71124.08 Safety NCV 05000413,05000414/2021002-01 Resources Open/Closed A self-revealing, Green, Non-Cited violation of 10 CFR 20 Appendix G.III.A.1 occurred when the licensee transferred solid radioactive waste to the Barnwell Waste Disposal Facility that did not meet the waste characterization requirements in 10 CFR 61.56(a)(3) for free standing liquid.
Description:
On January 29, 2020, a shipment of spent resin media was sent directly for burial at the Barnwell Waste Disposal Facility. On February 4, 2020, the licensee was notified that the High Integrity Container (HIC) associated with this shipment, which contained a mixture of dewatered bead resin, zeolite, and carbon, failed to meet the regulatory limit of one percent for Free Standing Liquid (FSL). The HIC had been randomly selected and tested for FSL by the South Carolina Department of Health and Environmental Control (SCDHEC) and, when punctured, 13.75 gallons of FSL were collected. The limit for FSL for this shipment was calculated to be 11.4 gallons.
The licensee performed a causal analysis and determined the most probable cause of the cask shipment exceeding the FSL limit was due to a variation in the Powdex Storage Tank (PST) resin media which contained a mixture of dewatered bead resin, zeolite, and carbon which when aggregated can trap water in this mixture and result in unsuccessful dewatering. This trapped water remains in the HIC even when the dewatering process is performed in accordance with current licensee procedures. During transport, the motion of the cask and vehicle may have caused the trapped FSL in the resin matrix to migrate to the bottom of the HIC.
Corrective Actions: Shipments of resin to the Barnwell Waste Disposal Facility for direct burial were suspended. Licensee staff met with the Barnwell Waste Disposal Facility staff and the SCDHEC to discuss the event. Licensee evaluated possible changes to site and corporate procedures and published an industry "Operating Experience" summary of the event.
Corrective Action References: NCR 02314994.
Performance Assessment:
Performance Deficiency: The licensee's failure to meet the 10 CFR 61.56(a)(3) waste characterization requirement for FSL in solid radioactive waste prior to transferring it to the Barnwell Waste Disposal for direct burial was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Program & Process attribute of the Public Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain as a result of routine civilian nuclear reactor operation. Failure to meet the radioactive waste characterization requirements in 10 CFR 61.56(a)(3) for shallow land burial potentially challenges the facility's long-term confinement of the radioactive material in accordance with its design criteria.
Significance: The inspectors assessed the significance of the finding using Appendix D, Public Radiation Safety SDP. The finding was determined to be of very low safety significance (Green) because the waste was not improperly classified per 10 CFR 61.55 and did not result in the improper disposal of the waste.
Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety. The licensee's Process Control Program requires adequate evaluations be performed to ensure waste characterization requirements are met prior to processing each waste stream. Based on the licensee's root cause evaluation, compliance with the procedures and processes for dewatering mixed resin from the PST could not consistently ensure that the FSL was less than one percent of the waste volume.
Enforcement:
Violation: Green, Non-Cited violation of 10 CFR 20 Appendix G.III.A.1. which requires any licensee who transfers radioactive waste to a land disposal facility to prepare all wastes such that it meets waste characteristic requirements in 10 CFR 61.56. 10 CFR 61.56(a)(3) states that FSL must in no case exceed one percent of the volume of the waste. Contrary to these requirements, on January 29, 2020, radioactive waste shipment RSR-20-02 was shipped to the Barnwell Waste Disposal Facility for direct burial with FSL that exceeded one percent of the volume of the waste.
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 July 28, 2021, the inspectors presented the integrated inspection results to Tom Simril and other members of the licensee staff.
- On May 28, 2021, the inspectors presented the Radiation Protection inspection results to Tom Simril and other members of the licensee staff.
- On May 19, 2021, the inspectors presented the Catawba Unit 1 License Renewal Phase 1 inspection results to Mr. Tom Simril and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71003 Corrective Action NCR02376015 2-NV-VA-0124B Excessive White Dry Boron from Unknown 03/28/2021
Documents Source
NCR02376335 2-NM-VA-0969 Brown/Rust-Colored Boron at Downstream 03/30/2021
Pipe Cap
NCR02376575 2-ND-VA-0110 Excessive Boron Deposit & Active Seat 03/31/2021
Leakage
NCR02376594 2-WL-PU-ANC Pressure Boundary Leakage below Suction 03/31/2021
NCR02376792 2-NV-VA-0493 Body-Bonnet Rust-Colored Boron/Active 04/02/2021
Leakage
NCR02376871 2-WL-VA-B043 Dry Rust-Colored Boron and Residue on 04/03/2021
Packing
Corrective Action NCR02383078 NRC Phase 1 Inspection Comment on Acceptance Criteria 05/19/2021
Documents
Resulting from
Inspection
Procedures AD-EG-PWR-1611 Boric Acid Corrosion Control Program - Implementation 4
AD-EG-PWR-1814 Steam Generator Condition Monitoring 2
AD-EG-PWR-1815 Steam Generator Operational Assessments 2
AD-MN-ALL-0006 Fluid Leak Management 3
IP/0/A/3314/053 T Char Testing of Containment High Range Radiation Monitor 001
Cables
MPP/0/A/7650/199 Maintenance Procedure for Eddy Current Testing 003
NDE-NE-ALL- Utilization of PDI-UT-2 Generic Procedure for the Ultrasonic 003
6102 Examination of Austenitic Pipe Welds
NDE-NE-ALL- Ultrasonic Thickness Measurement 002
6401
NE-20-08-01 Iepson Consulting Enterprises: Non-EQ Insulated Cables 0
and Connections Program
PDI-UT-2 Generic Procedure for the Ultrasonic Examination of 1
Austenitic Pipe Welds
PT/0/A/4600/010 Incore Detector Thimble Eddy Current Testing 004
Inspection Type Designation Description or Title Revision or
Procedure Date
A
PT/2/A/4150/001 Inside Containment Boric Acid Check 018
H
PT/2/A/4200/001J Electrical Penetration SF6 Gas Leak Rate Test 023
PT/2/A/4200/78 Containment Structural Integrity Inspection 006
SM/0/A/8510/007 Ice Basket Corrective Maintenance and Tracking 025
SM/0/B/8630/001 Flow Accelerated Corrosion Component Inspection 005
TE-MN-PWR-0006 Inspection, Assessment, and Cleanup of Boric Acid on Plant 1
Materials
Work Orders WO20286000 01 2NS PP SYS: UT Weld Number 2NS27-8 and Heat-Affected 04/07/21
Zone
WO20289917 01 PT/2/A/4200/78, Containment Structural Integrity Inspection 10/24/18
WO20362713 01 2KC HX B: Perform Eddy Current Testing of Tubes 04/06/21
WO20368990 06 2WL-321: Engineering to Review License Inspection 12/05/19
Results
WO20379481 01 2HS EC E2HS116: Perform FAC Inspection on E2HS116 in 08/21/20
C2R24
WO20407519 02 2NF Ice Basket: Unload/Reload Ice Baskets 04/01/21
WO20407565 01 U2 Offline Inspection of Cable in License Renewal 08/07/20
Structures
WO20408075 01 PT/2/A/4200/01J, SF6 Gas LRT 06/29/20
WO20408099 01 2ENA-Eddy Current Incore Flux Thimbles 03/24/21
WO20408889 01 2NF DR LAD: PM I/C Lower Personnel Door 12/30/20
WO20408954 01 2EMF RT 53B: Perform Char Testing on Cables 04/21/21
WO20408957 01 2NF DR LAD: Insp I/C Access Dr Seal 04/30/21
WO20415441 03 Perform E/C Test on 2SG-A 07/30/20
71111.08P Miscellaneous Catawba 2EOC24 SG Degradation Assessment 0
274-TECR- Steam Generator Operational Assessment for Foreign 000
103895 Object Wear at Catawba Unit 2 C2R23 Outage
51-9323917-000 Catawba Unit 2 C2R24 Steam Generator ECT Inspection 000
Plan
C-ISISG- Fourth Interval Steam Generator Tube Inservice Inspection 0
0169.030.0040 Plan
Inspection Type Designation Description or Title Revision or
Procedure Date
NDE-NE-CNS- Catawba 2 Site Validated Techniques 4
22
PD-EG-PWR-1801 Steam Generator Management Program 7
SG-CDMP-19-13 Catawba Unit 2 EOC23 Condition Monitoring and Final 1
Operational Assessment
71124.06 Miscellaneous G2021154 Gaseous Effluent Release Permit 5/4/21
L2021136 Liquid Effluent Release Permit 5/4/21
71124.07 Calibration WO 2039322501 Calibration of Meteorological Tower Instrumentation 07/16/2020
Records WO 2041673801 Calibration of Meteorological Tower Instrumentation 01/14/2021
Procedures IP/0/B/3343/013 Meteorological Monitoring System (EEB) Calibration and 048
Maintenance Procedure
71124.08 Corrective Action NCR 02314994 Shipment Discrepancy Identified Associated with RSR-20- 02/07/2020
Documents 02
Procedures AD-RP-ALL-5002 10 CFR 61 RADIOACTIVE WASTE CLASSIFICATION 2
CNS PCP Catawba Nuclear Station Process Control Program 14
CS-OP-PR-009 Ecodex Precoat/Powdex/Solka-Floc/Diatomaceous 2
Earth/Zeolite Dewatering Procedure for Energy Solutions14-215 or Smaller Liners Utilizing Energy Solutions Self-
Engaging Dewatering System (S.E.D.S)
DEC Corporate Radioactive Waste Process Control Program Duke Energy 16
PCP Carolinas (DEC) Corporate PCP
16