ML093521655
| ML093521655 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 12/18/2009 |
| From: | Wert L Division Reactor Projects II |
| To: | Madison D Southern Nuclear Operating Co |
| References | |
| IR-09-009 | |
| Download: ML093521655 (14) | |
See also: IR 05000321/2009009
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
SAM NUNN ATLANTA FEDERAL CENTER
61 FORSYTH STREET, SW, SUITE 23T85
ATLANTA, GEORGIA 30303-8931
December 18, 2009
Mr. Dennis R. Madison
Vice President
Southern Nuclear Operating Company, Inc.
Edwin I. Hatch Nuclear Plant
11028 Hatch Parkway North
Baxley, GA 31513
SUBJECT: EDWIN I. HATCH NUCLEAR PLANT - NRC SUPPLEMENTAL INSPECTION
REPORT 05000321/2009009, 05000366/2009009
Dear Mr. Madison:
On November 18, 2009, the U.S. Nuclear Regulatory Commission (NRC) staff completed a
supplemental inspection pursuant to Inspection Procedure 95001, (Inspection for One or Two
White Inputs in a Strategic Performance Area), at your Edwin I. Hatch Nuclear Plant, Units 1
and 2. The purpose of the inspection was to examine the causes and actions taken related to a
White inspection finding issued in the first quarter of 2009 for failure to promptly identify and
correct a condition adverse to quality. This finding resulted in a Violation (VIO) 05000321,
366/2008009-01, 1B EDG Coupling Failure. The enclosed inspection report documents the
inspection results, which were discussed at the exit meeting on November 18, 2009, with you
and other members of your staff.
The objectives of this supplemental inspection were to provide assurance that: (1) the root
causes and the contributing causes for the risk-significant issues were understood; (2) the
extent of condition and extent of cause of the issues were identified; and (3) corrective actions
were or will be sufficient to address and preclude repetition of the root and contributing causes.
The inspection examined activities conducted under your license as they relate to safety and
compliance with the Commissions rules and regulations and with the conditions of your license.
The inspector reviewed the root cause determination report, selected procedures and records,
and interviewed personnel.
Based on the results of this supplemental inspection, no findings of significance were identified.
The inspector determined that, in general, the problem identification, root cause, and corrective
actions taken by your staff were adequate. However, the inspector noted several areas in the
root cause determination report that could have been improved. In addition, weaknesses were
identified in the recently revised maintenance procedure used to inspect the engine/generator
SNC 2
In accordance with the Code of Federal Regulations 10 CFR 2.390 of the NRCs Rules of
Practice, a copy of this letter, its enclosure, and your response (if any) will be available
electronically for public inspection in the NRC Public Document Room or from the Publicly
Available Records (PARS) component of the NRCs document system (ADAMS). ADAMS is
accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public
Electronic Reading Room).
Sincerely,
/Joel Munday RA for/
Leonard D. Wert, Jr., Director
Division of Reactor Projects
Docket Nos.: 50-321, 50-366
Enclosure: Inspection Report 05000321/2009009, 05000366/2009009
w/Attachment: Supplemental Information
cc w/encl: (See page 3)
_________________________ X SUNSI REVIEW COMPLETE
OFFICE RII:DRP RII:DRP RII:DRP
SIGNATURE TXL /RA for/ SMS /RA/ Via email
NAME SRose SShaeffer TChandler
DATE 12/16/2009 12/15/2009 12/15/2009
E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO
SNC 3
cc w/encl: Arthur H. Domby, Esq.
Angela Thornhill Troutman Sanders
Managing Attorney and Compliance Officer Electronic Mail Distribution
Southern Nuclear Operating Company, Inc.
Electronic Mail Distribution Dr. Carol Couch
Director
Jeffrey T. Gasser Environmental Protection
Executive Vice President Department of Natural Resources
Southern Nuclear Operating Company, Inc. Electronic Mail Distribution
Electronic Mail Distribution
Cynthia Sanders
Raymond D. Baker Program Manager
Licensing Manager Radioactive Materials Program
Licensing - Hatch Department of Natural Resources
Southern Nuclear Operating Company, Inc. Electronic Mail Distribution
Electronic Mail Distribution
Jim Sommerville
L. Mike Stinson (Acting) Chief
Vice President Environmental Protection Division
Fleet Operations Support Department of Natural Resources
Southern Nuclear Operating Company, Inc. Electronic Mail Distribution
Electronic Mail Distribution
Mr. Steven M. Jackson
Paula Marino Senior Engineer - Power Supply
Vice President Municipal Electric Authority of Georgia
Engineering Electronic Mail Distribution
Southern Nuclear Operating Company, Inc.
Electronic Mail Distribution Mr. Reece McAlister
Executive Secretary
Moanica Caston Georgia Public Service Commission
Vice President and General Counsel Electronic Mail Distribution
Southern Nuclear Operating Company, Inc.
Electronic Mail Distribution Chairman
Appling County Commissioners
Steven B. Tipps County Courthouse
Hatch Principal Engineer - Licensing 69 Tippins Street, Suite 201
Edwin I. Hatch Nuclear Plant Baxley, GA 31513
Electronic Mail Distribution
Mr. Ken Rosanski
Resident Manager
Edwin I. Hatch
Oglethorpe Power Corporation
Electronic Mail Distribution
Lee Foley
Manager of Contracts Generation
Oglethorpe Power Corporation
Electronic Mail Distribution
SNC 4
Letter to Dennis R. Madison from Leonard D. Wert dated December 18, 2009
SUBJECT: EDWIN I. HATCH NUCLEAR PLANT - NRC SUPPLEMENTAL INSPECTION
REPORT 05000321/2009009, 05000366/2009009
Distribution w/encl:
C. Evans, RII
L. Slack, RII
OE Mail
RIDSNRRDIRS
PUBLIC
RidsNrrPMHatch Resource
U.S. NUCLEAR REGULATORY COMMISSION
REGION II
Docket No.: 50-321, 50-366
Report No.: 05000321/2009009, 05000366/2009009
Licensee: Southern Nuclear Operating Company Inc.
Facility : Edwin I. Hatch Nuclear Plant
Location: Baxley, Georgia 31513
Dates: November 16, 2009 - November 18, 2009
Inspector: T. Chandler, Resident Inspector, Region II
Approved by: Scott M. Shaeffer, Chief
Reactor Projects Branch 2
Division of Reactor Projects
Enclosure
SUMMARY OF FINDINGS
IR 05000321/2009009, 05000366/2009009; 11/16/2009 - 11/18/2009; Edwin I. Hatch Nuclear
Plant, Units 1 and 2; Supplemental Inspection IP 95001 in response to a White inspection
finding for failure to promptly identify and correct a condition adverse to quality.
This inspection was conducted by a resident inspector. No findings of significance were
identified. The NRCs program for overseeing the safe operation of commercial nuclear power
reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated
December 2006.
Cornerstone: Mitigating Systems
The NRC staff performed this supplemental inspection in accordance with Inspection Procedure 95001, Inspection for One or Two White Inputs in a Strategic Performance Area, to assess the
licensees evaluation associated with the inoperability of the 1B emergency diesel generator in
June 2008. The NRC staff previously characterized this issue as having low to moderate safety
significance (White) as documented in NRC IR 05000321/2008009, 05000366/2008009. During
this supplemental inspection, the inspector determined that the licensee performed a
comprehensive evaluation of the self-revealing EDG failure, which occurred during a routine
technical specification surveillance requirement test. The licensee identified the primary root
causes of the issue to be (1) less-than-adequate EDG coupling inspection procedures and (2)
less-than-adequate risk perception for degrading components. These two primary root causes,
along with six other root causes and three contributing causes, led the maintenance and
engineering personnel to believe that cracking and separation in the engine-generator coupling
gland was acceptable. The NRC inspector also determined that the licensees extent of
condition and extent of cause evaluations were adequate, and that the corrective actions were
comprehensive and properly prioritized, and sufficient to prevent recurrence of the event.
The inspector did note several areas in the root cause determination report that could have
been more timely. Specifically, because the readiness assessment was not conducted until just
a few weeks before the 95001 inspection was scheduled to begin; time available to incorporate
needed improvements into the final root cause determination reviewed by the inspector was
limited. Also, the MORT analysis was not fully utilized to evaluate the role of supervision in the
event. In addition, weaknesses were identified in the revised maintenance procedure used to
inspect the engine/generator coupling. For example, no specific criteria was provided on how to
determine when inspection of the engine side of the coupling would be needed.
Given the licensees acceptable performance in addressing the inoperable EDG, the White
finding associated with this issue will only be considered in assessing plant performance for a
total of four quarters in accordance with the guidance in IMC 0305, Operating Reactor
Assessment Program. The implementation and effectiveness of the licensees corrective
actions will be reviewed during future inspections.
A. NRC-Identified and Self-Revealing Findings
No findings of significance were identified.
B. Licensee-Identified Violations
No findings of significance were identified.
Enclosure
REPORT DETAILS
4. OTHER ACTIVITIES
4OA4 Supplemental Inspection (95001)
.01 Inspection Scope
The NRC staff performed this supplemental inspection in accordance with IP 95001 to
assess the licensees evaluation of a White finding, which affected the mitigating
systems cornerstone in the reactor safety strategic performance area. The inspection
objectives were to:
- Verify that the licensee understands the root causes and contributing causes of the 1B
EDG failure.
- Verify that the licensee has determined the extent of condition and extent of cause of
the identified root and contributing causes.
- Verify that the corrective actions for these issues are sufficient to address the root and
contributing causes and to prevent recurrence.
- Verify that the procedures have been revised to perform visual inspections of both
sides of the coupling (generator/motor).
The licensee entered the Regulatory Response Column of the NRCs Action Matrix in
the first quarter of 2008 as a result of one inspection finding of low to moderate safety
(White) significance. The finding was associated with the inoperability of the 1B EDG in
July 2008. On July 12, 2008, the 1B EDG was manually shutdown due to excessive
vibration and declared inoperable. The finding was characterized as having White safety
significance based on the results of a Phase 3 risk analysis performed by a region-based
senior reactor analyst (SRA), as discussed in NRC IR 05000321/2008009,
05000366/2008009. The excessive vibration was attributed to age-related cracks in the
rubber gland on both the diesel engine side and generator side of the generator/motor
coupling. On July 16, 2008, the generator/motor coupling was replaced and the 1B EDG
was returned to service.
The licensee had performed its initial root cause determination (CR 2008107432 RCCA
version 1.0, dated 09/04/08) to identify weaknesses that existed in various organizations,
which allowed for a risk-significant finding and to determine the organizational attributes
that resulted in the White finding. As part of the root cause determination, the licensee
also completed a safety culture assessment. The licensee staff informed the NRC staff
on September 23, 2009, that they were ready for the supplemental inspection. In
October 2009, in preparation for the 95001 inspection, the licensee conducted an in-
depth readiness assessment of the original root cause determination report. As a result
of that self-critical readiness assessment, the licensee made numerous significant
improvements to the original report. As a result, the revised root cause determination
Enclosure
4
report (CR 2008107432 RCCA version 2.0, dated 11/12/09) was issued just prior to the
inspection.
The inspector reviewed the licensees root cause determination report, along with
several evaluations that were conducted in support of the root cause determination. The
inspector reviewed the licensees extent of condition and extent of cause evaluations to
ensure they were sufficient in breadth. The inspector reviewed the corrective actions
that were taken or planned to address the identified causes. The inspector also held
discussions with licensee personnel to ensure that the root and contributing causes, as
well as the contribution of safety culture components, were understood and that
corrective actions taken or planned were appropriate to address the causes and
preclude repetition.
.02 Evaluation of the Inspection Requirements
02.01 Problem Identification
a. IP 95001 requires that the inspection staff determine that the licensees evaluation of the
issue documents who identified the issue (i.e., licensee-identified, self-revealing, or
NRC-identified) and the conditions under which the issue was identified.
The self-revealing issue occurred during a Technical Specification surveillance
requirement. The initial indications of the issue were high engine vibrations
approximately four hours into the 24-hour test run of the 1B EDG.
b. IP 95001 requires that the inspection staff determine that the licensees evaluation of the
issue documents how long the issue existed and prior opportunities for identification.
The licensees RCCA documented that the cracks in the coupling gland were first
identified back in 1988. However, it was determined at that time that the cracks did not
impact EDG operability due to the coupling gland passing a vendor recommended air
test and the EDGs ability to pass the Technical Specification surveillance requirement.
c. IP 95001 requires that the inspection staff determine that the licensees evaluation of the
issue documents the plant-specific risk consequence, as applicable, and compliance
concerns associated with the issue.
The NRC determined this issue was a White finding, as documented in NRC IR 05000321/2009008 and 05000366/2009008. The inspector determined that the licensee
conducted a plant specific risk consequence analysis and provided its results in the final
root cause determination report. Using the Hatch PRA model with a 93 day exposure
time yields a probable core damage frequency (CDF) of 9.16 E-7. The large early
release frequency (LERF) is 3.89 E-9 and is considered negligible. Due to the small
amount of risk increase (less than 1.0 E-6) the licensee determined this to be a Green
finding. It is also noted that Plant Hatch requires only one EDG per unit for performance
of LOSP functions.
Enclosure
5
d. Findings
No findings of significance were identified.
02.02 Root Cause and Extent-of-Condition Evaluation
a. IP 95001 requires that the inspection staff determine that the licensee evaluated the
issue using a systematic methodology to identify the root and contributing causes.
The licensee used the following systematic methods to complete their RCCA:
- Fault tree analysis
- Barrier analysis
- MORT analysis
- Event and causal factors chart
- Event timeline
The inspector determined that the licensee evaluated the issue using a systematic
methodology to identify the root and contributing causes.
b. IP 95001 requires that the inspection staff determine that the licensees RCCA was
conducted to a level of detail commensurate with the significance of the problem.
The licensees RCCA included an extensive timeline of events, as well as an event and
causal factors chart as discussed in the previous section. Using a multidisciplinary
team, the licensee identified eight root causes and three contributing causes. Based on
the extensive work performed for this root cause evaluation, the inspector concluded that
the root cause evaluation was conducted to a level of detail commensurate with the
significance of the problem.
c. IP 95001 requires that the inspection staff determine that the licensees RCCA include a
consideration of prior occurrences of the problem and knowledge of prior operating
experience.
The licensees RCCA included a review of both internal and external OE. A search of
the Plant Hatch condition report data base for previous reports of the same or similar
problems found no reports of previous problems with the EDG couplings. However, the
event and causal factors chart reviewed the history of the event and looked for previous
opportunities to correct the problem. As a result of this review, the licensee identified
that their use of vendor information was poor, and as a result, several of the root causes
are tied to inadequate dissemination of vendor information. Based on the licensees
detailed evaluation and conclusions, the inspector determined that the licensees RCCA
considered prior occurrences and operating experience.
d. IP 95001 requires that the inspection staff determine that the licensees RCCA
addresses the extent of condition and the extent of cause of the issue.
Enclosure
6
To address the extent of condition issue, the licensees RCCA contained a review of
several components that contain similar elastomer-coupled elements and the preventive
maintenance items associated with them. As a result of this review, the couplings were
replaced on the other four EDGs at Plant Hatch, and the inspection and replacement
requirements on several other major components that contain similar elastomer-coupled
elements were greatly improved. Also, a review of the actions taken in relationship to
the causes was documented in the RCCA to provide assurance that the actions were
sufficiently broad to address the extent of causes. The inspector determined that the
licensees RCCA addressed the extent of condition and the extent of cause of the issue.
e. IP 95001 requires that the inspection staff determine that the licensees root cause
evaluation, extent of condition, and extent of cause appropriately considered the safety
culture components as described in IMC 0305.
As part of the RCCA, the licensee performed a Safety Culture Assessment. This
assessment identified three areas needing improvement: Decision Making, Corrective
Action Program, and Operating Experience. In addition, a MORT analysis was
performed to provide additional focus on why condition reports were not initiated. Based
upon the corrective actions listed in the Safety Culture Assessment, the inspector
determined that the licensees root cause evaluation, extent of condition, and extent of
cause appropriately considered the safety culture components as described in IMC 0305.
f. Findings
No findings of significance were identified. However, the inspector did note several
areas in the root cause determination report that could have been more timely.
Specifically, because the readiness assessment was not conducted until just a few
weeks before the 95001 inspection was scheduled to begin; time available to incorporate
needed improvements into the final root cause determination reviewed by the inspector
was limited. Also, the MORT analysis was not fully utilized to evaluate the role of
supervision in the event.
02.03 Corrective Actions
a. IP 95001 requires that the inspection staff determine that: (1) the licensee specified
appropriate corrective action(s) for each root and/or contributing cause; or (2) an
evaluation that states no actions are necessary is adequate.
The licensee took immediate corrective actions to restore operability of the 1B EDG by
replacing the cracked coupling. All root and contributing causes listed in the RCCA were
linked to an appropriate corrective action. The inspector determined that the proposed
corrective actions are appropriate and addressed each root and contributing cause.
b. IP 95001 requires that the inspection staff determine that the licensee prioritized
corrective actions with consideration of risk significance and regulatory compliance.
Enclosure
7
The licensees immediate corrective actions restored the 1B EDG to operable status
within 86 hours9.953704e-4 days <br />0.0239 hours <br />1.421958e-4 weeks <br />3.2723e-5 months <br />. While the 1B EDG was inoperable, the licensee performed monthly TS
surveillance procedures to verify operability of the 1A, 1C, 2A, and 2B EDGs. Over the
next few weeks, the licensee conservatively replaced the couplings in the 1A, 1C, 2A,
and 2B EDGs, greatly reducing the risk of an additional coupling failure. Based upon
these corrective actions, as well as the other corrective actions identified in the RCCA,
the inspector determined that the licensee prioritized corrective actions with
consideration of risk significance and regulatory compliance.
c. IP 95001 requires that the inspection staff determine that the licensee established a
schedule for implementing and completing the corrective actions.
The inspector determined that all of the corrective actions listed in the RCCA have been
either scheduled or completed.
d. IP 95001 requires that the inspection staff determine that the licensee developed
quantitative and qualitative measures of success for determining the effectiveness of the
corrective actions to preclude repetition.
The inspector determined that an interim effectiveness review for the corrective actions
listed in the RCCA is scheduled for December 2009 (ref. AI 2009203209) Because the
RCCA was revised on November 12, 2009, the final effectiveness review will be delayed
until June 2010 to allow additional time to completed newly added corrective actions.
The inspector determined that the licensee has developed quantitative and qualitative
measures of success for determining the effectiveness of the corrective actions to
preclude repetition of this event.
e. IP 95001 requires that the inspection staff determine that the licensees planned or taken
corrective actions adequately address a Notice of Violation (NOV) that was the basis for
the supplemental inspection, if applicable.
The NRC issued an NOV to the licensee on June 4, 2009. The licensee provided the
NRC a written response to the NOV on July 2, 2009. The licensees response
described: (1) corrective steps which have been taken and the results achieved; (2)
corrective steps which will be taken; (3) the date when full compliance will be achieved;
and (4) the reasons for the violation. During this inspection, the inspector confirmed that
the licensees RCCA and planned and taken corrective actions addressed the NOV.
The licensee restored the 1B EDG to full compliance on July 16, 2008.
f. Findings
No findings of significance were identified. Inspectors did note weaknesses in the
revised maintenance procedure used to inspect the engine/generator coupling. For
example, no specific criteria was provided on how to determine when inspection of the
engine side of the coupling would be needed. Based on observations provided by the
inspector the licensee initiated actions to add criteria to address this issue.
Enclosure
8
4OA6 Exit Meeting
On November 18, 2009, the inspector presented the results of the supplemental
inspection to Mr. Dennis R. Madison and other members of licensee management and
staff, who acknowledged the findings. The inspector confirmed that no proprietary
information was provided or examined during the inspection.
ATTACHMENT: SUPPLEMENTAL INFORMATION
Enclosure
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
G. Johnson - Engineering Director
D. Madison - Site Vice President
L. Mikulecky - Root Cause Analyst
S. Tipps - Principle Licensing Engineer
NRC personnel:
E. Morris, Senior Resident Inspector - Hatch
P. Niebaum, Resident Inspector - Hatch
S. Shaeffer, Chief, Reactor Projects Branch 2
ITEMS OPENED, CLOSED AND DISCUSSED
None
LIST OF DOCUMENTS REVIEWED
Action Items
2001202296 2008203824 2004202167 2008203692 2008204097 2008204098
2008204099 2009204100 2008204101 2008204102 2008204103 2008204104
2008204105 2008204106 2008204107 2008204108 2008204109 2008204110
2008204111 2008204112 2008204113 2008204114 2008204115 2008203209
2008204651 2008205554
Procedures
52SV-R43-001, Diesel, Alternator, and accessories inspection, various revisions
Maintenance Work Orders
10100390, Replace inboard and outboard alternator bearings on 1B EDG
28603340, 2C EDG bearing seizure
28603681, Inspect 2C EDG inboard bearing
Condition Reports
1996001491 1998002701 2001004250 2000011063 2001000624 2004104711
1996001491 2007108168 2008107432
Miscellaneous
Fermi Event Card 02-14329
Sure-Flex Elastomeric Couplings Manual
Test Report 08-0372-TR-001, Altran Technical Report on Hatch EDG Coupling Assessments
Vendor document SX28733
Vendor document SX13147
Attachment