IR 05000321/2014005

IR 05000321/2014005 and 05000366/2014005, on October 1, 2014, Through December 31, 2014; Edwin I. Hatch, Units 1 and 2, Fire Protection, Problem Identification and Resolution

ML15026A507
Person / Time
Site:	Hatch
Issue date:	01/26/2015
From:	Mark Franke NRC/RGN-II/DRP/RPB2
To:	Vineyard D Southern Nuclear Operating Co
References
IR-2014005
Download: ML15026A507 (33)

Text

UNITED STATES anuary 26, 2015

SUBJECT:

EDWIN I. HATCH NUCLEAR PLANT - NRC INTEGRATED INSPECTION REPORT 05000321/2014005 AND 05000366/2014005

Dear Mr. Vineyard:

On December 31, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Edwin I. Hatch Nuclear Plant Units 1 and 2. On January 23, 2015, the NRC inspectors discussed the results of this inspection with you and other members of your staff.

Inspectors documented the results of this inspection in the enclosed inspection report.

NRC inspectors documented one finding of very low safety significance (Green) in this report.

This finding involved a violation of NRC requirements. Additionally, the NRC has determined that one Severity Level IV violation of NRC requirements occurred. Further, inspectors documented two licensee-identified violations which were determined to be of very low safety significance in this report. The NRC is treating these violations as non-cited violations (NCVs)

consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violations or significance of the NCVs, 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, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the Hatch plant. In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management 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,

/RA/

Mark Franke, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket Nos.: 50-321, 50-366 License Nos.: DPR-57 and NPF-5

Enclosures:

IR 05000321/2014005, 05000366/2014005 w/Attachment: Supplemental Information

REGION II==

Docket Nos.: 50-321, 50-366 License Nos.: DPR-57 and NPF-5 Report No.: 05000321/2014005; and 05000366/2014005 Licensee: Southern Nuclear Operating Company, Inc.

Facility: Edwin I. Hatch Nuclear Plant Location: Baxley, Georgia Dates: October 1, 2014, through December 31, 2014 Inspectors: D. Hardage, Senior Resident Inspector D. Retterer, Resident Inspector M. Speck, Sr. Emergency Preparedness Inspector (1EP2, 1EP3, 1EP4, 1EP5, 4OA1, 4OA6 )

S. Sanchez, Sr. Emergency Preparedness Inspector (1EP2, 1EP3, 1EP4, 1EP5, 4OA1, 4OA6 )

W. Loo, Sr. Health Physicist (1EP2, 1EP3, 1EP4, 1EP5, 4OA1)

C. Fontana, Emergency Preparedness Inspector (1EP2, 1EP3, 1EP4, 1EP5, 4OA1)

B. Caballero, Sr. Operations Engineer (1R11)

D. Lanyi, Sr. Operations Engineer (1R11)

J. Viera, Operations Engineer (1R11)

Approved by: Mark Franke, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure

REPORT

SUMMARY

IR 05000321/2014005; and 05000366/2014005, October 1, 2014, through December 31, 2014;

Edwin I. Hatch, Units 1 and 2, Fire Protection, Problem Identification and Resolution.

The report covered a three-month period of inspection by resident inspectors, two operations engineers, three emergency preparedness inspectors and a senior health physicist. There were two NRC-identified violations documented in this report. The significance of inspection findings are indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP) dated June 2, 2011. The cross-cutting aspects are determined using IMC 0310, Aspects within the Cross-Cutting Areas dated December 19, 2013. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated January 28, 2013 and revised July 9, 2013. The NRCs program for overseeing the safe operations of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.

Cornerstone: Mitigating Systems

Green.

The NRC identified a Green Non-Cited Violation (NCV) of Unit 1 License Condition 2.C.(3) Fire Protection when a fire penetration that deviated from three-hour rating requirements was not evaluated in accordance with Unit 1 Fire Hazards Analysis (FHA)

Appendix I, Evaluation of non-rated penetration seals in rated fire barriers. The licensee initiated roving fire watches and initiated corrective actions to restore compliance with Appendix I of the Unit 1 FHA. The violation was entered into the licensees corrective action program as CR 865615.

Failure to implement the Unit 1 Fire Hazards Analysis (FHA) Appendix I, Evaluation of non-rated penetration seals in rated fire barriers was a performance deficiency. This performance deficiency was more than minor because it was associated with the Mitigating Systems cornerstone of the Protection Against External Factors (Fire) attribute and adversely affected the cornerstone objective in that the licensee failed to evaluate the as-found configuration of the penetration which resulted in a nonfunctional fire barrier. The inspectors determined the finding was Green because there was a fully functional automatic suppression system on either side of the fire barrier. The inspectors determined that this finding did not have an associated cross-cutting aspect because this finding is not reflective of current licensee performance. (Section 1R05)

• Severity Level IV. The NRC identified a Severity Level IV NCV of 10 CFR Part 50.72(b)(3)(ii)(B), Immediate Notification Requirements for Operating Nuclear Power Reactors, and 10 CFR Part 50.73(a)(2)(ii)(B) Licensee Event Report System for failure to report unanalyzed conditions that significantly degraded plant safety. Specifically, the licensee failed to notify the NRC upon discovery of reportable degraded conditions in the control building that could have resulted in the loss of both Unit 1 safe shutdown paths in the event of a postulated fire. The violation was entered into the licensees corrective action program as CR 870626.

Failure to report an unanalyzed condition that significantly degraded plant safety as required by 10 CFR Part 50.72(b)(3)(ii)(B) and 10 CFR Part 50.73(a)(2)(ii)(B) was a performance deficiency (PD). The PD potentially impeded or impacted the regulatory process and was evaluated using traditional enforcement in accordance with Section 6 of the NRC Enforcement Policy. Failure to make a report required by 10 CFR Part 50.72 or 10 CFR Part 50.73 is identified in example 9 of Section 6.9.d as a Severity Level IV violation. Cross-cutting aspects are not assigned to traditional enforcement violations. (Section 4OA2.3)

Violations of very low safety significance that were identified by the licensee have been reviewed by the NRC. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. These violations and corrective action tracking numbers are listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status

Unit 1 began the inspection period at or near 100 percent rated thermal power (RTP). On December 13, 2014, operators performed a unit shutdown to Mode 4 to replace the A recirculation pump seal package. The unit was restarted on December 15, 2014, and returned to RTP on December 18, 2014. On December 26, 2014, operators performed a downpower to 15 percent RTP to replace the stator water cooling filter. The unit was returned to 100 percent RTP on December 29, 2014. The unit operated throughout the remainder of the inspection period at or near 100 percent RTP.

Unit 2 began the inspection period at or near 100 percent RTP. On December 13, 2014, a downpower to 85 percent RTP was performed by operators due to a loss of feedwater heating.

The unit was returned to 100 percent RTP later on December 13, 2014. On December 14, 2014, a downpower to 45 percent RTP was performed by operators in response to a condenser tube leak. The unit was returned to 100 percent RTP on December 18, 2014. On December 20, 2014, the unit entered end-of-cycle coastdown and remained in coastdown throughout the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

a. Inspection Scope

Seasonal Extreme Weather Conditions: The inspectors conducted a detailed review of the stations adverse weather procedures written for extreme low temperatures. The inspectors verified that weather-related equipment deficiencies identified during the previous year had been placed into the work control process and/or corrected before the onset of seasonal extremes. The inspectors evaluated the licensees implementation of adverse weather preparation procedures and compensatory measures before the onset of seasonal extreme weather conditions. The inspectors evaluated the following risk-significant systems. Documents reviewed are listed in the Attachment.

• Plant service water

• Reactor core isolation cooling

b. Findings

No findings were identified.

1R04 Equipment Alignment

a. Inspection Scope

Partial Walkdown: The inspectors verified that critical portions of the selected systems were correctly aligned by performing partial walkdowns. The inspectors selected systems for assessment because they were a redundant or backup system or train, were important for mitigating risk for the current plant conditions, had been recently realigned, or were a single-train system. The inspectors determined the correct system lineup by reviewing plant procedures and drawings. The inspectors selected the following three systems or trains to inspect. Documents reviewed are listed in the Attachment.

• Unit 2 high pressure coolant injection while reactor core isolation cooling system was out of service for maintenance, November 3

• Unit 2 reactor core isolation cooling while high pressure coolant injection system was out of service for maintenance, November 13

• Unit 1 residual heat removal system realignment for maintenance, December 29

b. Findings

No findings were identified.

1R05 Fire Protection

a. Inspection Scope

Quarterly Inspection: The inspectors evaluated the adequacy of selected fire plans by comparing the fire plans to the defined hazards and defense-in-depth features specified in the fire protection program. In evaluating the fire plans, the inspectors assessed the following items:

• control of transient combustibles and ignition sources

• fire detection systems

• water-based fire suppression systems

• gaseous fire suppression systems

• manual firefighting equipment and capability

• passive fire protection features

• compensatory measures and fire watches

• issues related to fire protection contained in the licensees corrective action program The inspectors toured the following four fire areas to assess material condition and operational status of fire protection equipment. Documents reviewed are listed in the

.

• Unit 1, HVAC and stand-by gas filter room, fire zone 1205N/Q

• Unit 2, HVAC and stand-by gas filter room, fire zone 2205Q/T

• Unit 1, diesel generator switchgear rooms 1E/1F/1G, fire zone 1404/1408/1412

• Unit 1, railroad airlock, fire zone 1604

b. Findings

Introduction:

An NRC-identified Green NCV of Unit 1 License Condition 2.C.(3) Fire Protection was identified when the licensee failed to evaluate a fire penetration that deviated from three-hour rating requirements in accordance with Unit 1 Fire Hazards Analysis (FHA) Appendix I, Evaluation of non-rated penetration seals in rated fire barriers.

Description:

The inspectors identified that fire boundary penetration 1T43-H528J was physically degraded. The penetration was a sheet metal plate between the HVAC room and the reactor building that contained six conduits and a ventilation duct running through the larger sheet metal plate. The inspectors also noted the sheet metal had several 1/4-inch diameter holes, a lift in the seam of the metal which resulted in an approximately 3 inches by 1/4-inch gap in the metal, and that the conduits running through the penetration were not sealed. This sheet metal was a non-rated penetration seal in a three-hour rated fire barrier. The as-found configuration of this penetration has existed since at least 1998 when the licensee changed the penetration configuration.

The licensee had performed a qualitative analysis in accordance with Appendix I of the Fire Hazards Analysis to allow the area around the ventilation duct to be protected by a sheet metal plate. However, the qualitative analysis did not accurately reflect the as-found condition of the fire barrier. The licensee declared the penetration non-functional and determined that the penetration was degraded such that the associated wall would not meet Appendix R requirements.

Analysis:

Failure to implement the Unit 1 Fire Hazards Analysis (FHA) Appendix I, Evaluation of non-rated penetration seals in rated fire barriers was a performance deficiency. This performance deficiency was more than minor because it was associated with the Mitigating Systems cornerstone of the Protection Against External Factors (Fire) attribute and adversely affected the cornerstone objective in that the licensee failed to evaluate the as-found configuration of the penetration which resulted in a nonfunctional fire barrier. The inspectors assessed this finding using IMC 0609, Appendix F, Attachment 1, dated September 20, 2013, and concluded that this condition affected the Fire Confinement category in section 1.2, potentially affected both paths of safe shutdown for Unit 1, and was assigned a High degradation rating. The finding was determined to be Green because there was a fully functional automatic suppression system on either side of the fire barrier. The inspectors determined that this finding did not have an associated cross-cutting aspect because this finding did not occur within the previous three years and is not reflective of current licensee performance.

Enforcement:

Hatch Unit 1 License Condition 2.C.(3) Fire Protection required in part that the licensee shall implement and maintain in effect all provisions of the fire protection program, which is referenced in the Updated Final Safety Analysis Report for the facility, as contained in the updated Fire Hazards Analysis and Fire Protection Program. Hatchs Fire Hazards Analysis Appendix I Evaluation of non-rated penetration seals in rated fire barriers required evaluation of non-rated penetration seals in rated fire barriers. Section 3.0 of Appendix I states in part, The detailed deviation analyses for all excepted penetrations are located in calculation SMNH 98-023, a dynamic record of evaluation. Any penetration configurations that do not conform to documented testing criteria for the specific barrier rating are included in this calculation. Additionally, Section 5.8.4 of the FHA stated in part, Those penetrations that deviate from rating requirements or standard configurations in any way are evaluated under the criteria discussed in Appendix I of this report. Contrary to the above, the licensee failed to evaluate the as-found configuration of penetration seal 1T43-H528J against the criteria discussed in Appendix I of the FHA and calculation SMNH 98-023. Failure to properly evaluate the penetration seal resulted in the three-hour rated fire barrier not meeting Appendix R requirements from approximately 1998 to September 13, 2014. The licensee initiated roving fire watches and initiated corrective actions to restore compliance with Appendix I of Unit 1 FHA. The violation was entered into the licensees corrective action program as CR 865615. This violation is being treated as a NCV, consistent with Section 2.3.2 of the Enforcement Policy. (NCV 05000321/2014005-001, Failure to evaluate fire penetration 1T43-H528J)

1R06 Flood Protection Measures

a. Inspection Scope

Underground Cables The inspectors reviewed related flood analysis documents and inspected the areas listed below containing cables whose failure could disable risk-significant equipment. The inspector directly observed the condition of cables and cable support structures and, as applicable, verified that dewatering devices and drainage systems were functioning properly. In addition, the inspectors verified the licensee was identifying and properly addressing issues using the corrective action program.

Documents reviewed are listed in the Attachment.

• Unit 1, PB1-V

• Unit 1, PB1-AE

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

a. Inspection Scope

Quarterly Review of Licensed Operator Requalification: The inspectors observed a simulator scenario conducted for training of an operating crew for licensed operator continuing training. The inspectors assessed the following:

• licensed operator performance

• the ability of the licensee to administer the scenario and evaluate the operators

• the quality of the post-scenario critique

• simulator performance Quarterly Review of Licensed Operator Performance: The inspectors observed licensed operator performance in the main control room during a planned Unit 1 shutdown on December 13. The inspectors assessed the following:

• use of plant procedures

• control board manipulations

• communications between crew members

• use and interpretation of instruments, indications, and alarms

• use of human error prevention techniques

• documentation of activities

• management and supervision Biennial Requalification Program Inspection: During the week of August 18 - 21, 2014, and on October 30, 2014, the inspectors reviewed documentation, interviewed licensee personnel, and observed the administration of operating tests associated with the licensees operator requalification program. The inspectors assessed the effectiveness of the facility licensee in implementing requalification requirements identified in 10 CFR Part 55, Operators Licenses. Evaluations were also performed to determine if the licensee effectively implemented operator requalification guidelines established in NUREG-1021, Operator Licensing Examination Standards for Power Reactors, Rev. 9.

The inspectors observed two crews during the performance of the operating tests.

Documentation reviewed included written examinations, Job Performance Measures (JPMs), simulator scenarios, licensee procedures, five on-shift records, simulator modification request records, simulator performance test records, twenty operator feedback records, ten licensed operator qualification records, six remediation plans, ten watchstanding records, and twelve medical records. The records were inspected using the criteria listed in Inspection Procedure 71111.11, dated September 1, 2012. The inspectors also evaluated the licensees simulation facility for adequacy for use in operator licensing examinations using ANSI/ANS-3.5-1985, American National Standard for Nuclear Power Plant Simulators for use in Operator Training and Examination.

Annual Review of Licensee Requalification Examination Results: On November 7, 2014, the licensee completed the annual requalification operating examinations required to be administered to all licensed operators in accordance with 10 CFR Part 55.59(a)(2),

Requalification Requirements, of the NRCs Operators Licenses. The inspectors performed an in-office review of the overall pass/fail results of the individual operating examinations and the crew simulator operating examinations in accordance with Inspection Procedure (IP) 71111.11, Licensed Operator Requalification Program.

These results were compared to the thresholds established in Section 3.02, Requalification Examination Results, of IP 71111.11.

Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors assessed the licensees treatment of the two issues listed below to verify the licensee appropriately addressed equipment problems within the scope of the maintenance rule (10 CFR Part 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants). The inspectors reviewed procedures and records to evaluate the licensees identification, assessment, and characterization of the problems as well as their corrective actions for returning the equipment to a satisfactory condition. Documents reviewed are listed in the Attachment.

• Unit 1, 1W33 Traveling Water Screen, Improperly sized thermal overloads trip water screen motors.

• Unit 1, 1Z41 Main Control Room Condensing Unit A, High discharge pressure trip.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed the three maintenance activities listed below to verify that the licensee assessed and managed plant risk as required by 10 CFR Part 50.65(a)(4) and licensee procedures. The inspectors assessed the adequacy of the licensees risk assessments and implementation of risk management actions. The inspectors also verified that the licensee was identifying and resolving problems with assessing and managing maintenance-related risk using the corrective action program. Additionally, for maintenance resulting from unforeseen situations, the inspectors assessed the effectiveness of the licensees planning and control of emergent work activities.

Documents reviewed are listed in the Attachment.

• Unit 1 and Unit 2, week of October 25 - October 31, including scheduled maintenance for the 2A residual heat removal train, 1A plant service water pump and 1A emergency diesel generator

• Unit 1 and Unit 2, week of November 1 - November 7, including scheduled maintenance for the Unit 2 reactor core isolation cooling system and removal of the communication tower in the high voltage switchyard

• Unit 2, emergent maintenance due to core drill cutting embedded conduit, December 5 - December 8, including 2P41F316A, 2P41F316D, and the 2A emergency diesel generator

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

The inspectors selected the five operability determinations or functionality evaluations listed below for review based on the risk-significance of the associated components and systems. The inspectors reviewed the technical adequacy of the determinations to ensure that technical specification operability was properly justified and the components or systems remained capable of performing their design functions. To verify whether components or systems were operable, the inspectors compared the operability and design criteria in the appropriate sections of the technical specification and updated final safety analysis report to the licensees evaluations. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. Additionally, the inspectors reviewed a sample of corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with operability evaluations.

Documents reviewed are listed in the Attachment.

• Unit 2, diesel generator 2C exhaust manifold leak, CR 884727

• Unit 1, diesel generator 1A loading frequency droop, CR 880596

• Unit 2, 2P41F316D, PSW turbine building isolation valve, CR 903118

• Unit 1, station service battery 1A calculation update affects load profile, CR 892720

• Unit 1, reactor core isolation cooling water protection of electrical circuits, CR10002540/10002558

b. Findings

No findings were identified.

1R18 Plant Modifications

a. Inspection Scope

The inspectors verified that the plant modification listed below did not affect the safety functions of important safety systems. The inspectors confirmed the modifications did not degrade the design bases, licensing bases, and performance capability of risk significant structures, systems and components. The inspectors also verified modifications performed during plant configurations involving increased risk did not place the plant in an unsafe condition. Additionally, the inspectors evaluated whether system operability and availability, configuration control, post-installation test activities, and changes to documents, such as drawings, procedures, and operator training materials, complied with licensee standards and NRC requirements. In addition, the inspectors reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with modifications. Documents reviewed are listed in the Attachment.

• SNC 578233, Install vent plugs on 1N22F070A/B

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors either observed post-maintenance testing or reviewed the test results for the five maintenance activities listed below to verify the work performed was completed correctly and the test activities were adequate to verify system operability and functional capability.

• SNC337304, Test/Repair/Replace Relief Valve 1R43F092A, October 30

• SNC428023, Functional Test and Calibration of RCIC Woodward Turbine Controls, November 6

• SNC 434295, Test/Repair/Replace Relief Valve 2E41F020, November 18

• SNC 621043, 2P41F316A Cable Replacement Functional Test, December 10

• SNC 557155, Investigate Poor Connection Issue with LPRM Cable, December 14 The inspectors evaluated these activities for the following:

• Acceptance criteria were clear and demonstrated operational readiness.

• Effects of testing on the plant were adequately addressed.

• Test instrumentation was appropriate.

• Tests were performed in accordance with approved procedures.

• Equipment was returned to its operational status following testing.

• Test documentation was properly evaluated.

Additionally, the inspectors reviewed a sample of corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with post-maintenance testing. Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

1R20 Refueling and Other Outage Activities

a. Inspection Scope

The inspectors evaluated the following outage activities during the Unit 1 maintenance outage:

• outage planning

• shutdown, cooldown, heatup, and startup

• reactor coolant system instrumentation and electrical power configuration

• containment closure The inspectors verified that the licensee:

• considered risk in developing the outage schedule

• controlled plant configuration in accordance with administrative risk reduction methodologies

• developed work schedules to manage fatigue

• developed mitigation strategies for loss of key safety functions

• adhered to operating license and technical specification requirements Inspectors verified that safety-related and risk-significant structures, systems, and components not accessible during power operations were maintained in an operable condition. The inspectors also reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with outage activities. Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors reviewed the three surveillance tests listed below and either observed the test or reviewed test results to verify testing adequately demonstrated equipment operability and met technical specification and licensee procedural requirements. The inspectors evaluated the test activities to assess for preconditioning of equipment, procedure adherence, and equipment alignment following completion of the surveillance.

Additionally, the inspectors reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with surveillance testing. Documents reviewed are listed in the Attachment.

Routine Surveillance Tests

• 34SV-R43-003-2, Diesel Generator 2C Monthly Test

• 34SV-B31-001-1, Recirculation System Valve Operability In-Service Tests (IST)

• 34SV-R43-003-2, Diesel Generator 2C Monthly Test, 2P41-F339B IST

b. Findings

No findings were identified.

1EP2 Alert and Notification System Evaluation

a. Inspection Scope

The inspectors evaluated the adequacy of the licensees methods for testing the alert and notification system in accordance with NRC Inspection Procedure 71114, 02, Alert and Notification System (ANS) Testing. The applicable planning standard, 10 CFR Part 50.47(b)(5) and its related 10 CFR Part 50, Appendix E, Section IV.D requirements were used as reference criteria. The criteria contained in NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1, were also used as a reference. The inspectors also interviewed personnel involved with siren system maintenance and observed the condition of a sample of siren installations.

Documents reviewed are listed in the Attachment. This inspection activity satisfied one inspection sample for the alert and notification system.

b. Findings

No findings were identified.

1EP3 Emergency Preparedness Organization Staffing and Augmentation System

a. Inspection Scope

The inspectors reviewed the licensees Emergency Response Organization (ERO)augmentation staffing requirements and process for notifying the ERO to ensure the readiness of key staff for responding to an event and timely facility activation. The qualification records of key position ERO personnel were reviewed to ensure all ERO qualifications were current. A sample of problems identified from augmentation drills or system tests performed since the last inspection was reviewed to assess the effectiveness of corrective actions.

The inspection was conducted in accordance with NRC Inspection Procedure 71114, 03, Emergency Preparedness Organization Staffing and Augmentation System. The applicable planning standard, 10 CFR Part 50.47(b)(2), and its related 10 CFR Part 50, Appendix E requirements were used as reference criteria.

Documents reviewed are listed in the Attachment. This inspection activity satisfied one inspection sample for the ERO staffing and augmentation system.

b. Findings

No findings were identified.

1EP4 Emergency Action Level and Emergency Plan Changes

a. Inspection Scope

Since the last NRC inspection of this program area, Revisions 102 and 103 were made to the Radiological Emergency Plan. The licensee determined that, in accordance with 10 CFR Part 50.54(q), the Plan continued to meet the requirements of 10 CFR Part 50.47(b) and Appendix E to 10 CFR Part 50. The inspectors reviewed the changes and sampled implementing procedure changes made between October 2013 and September 2014, to evaluate for potential reductions in the effectiveness of the Plan. As this review was not documented in a Safety Evaluation Report and does not constitute formal NRC approval of the changes, these changes remain subject to future NRC inspection in their entirety.

The inspection was conducted in accordance with NRC Inspection Procedure 71114, 04, Emergency Action Level and Emergency Plan Changes. The applicable planning standards of 10 CFR Part 50.47(b), and its related requirements in 10 CFR Part 50, Appendix E, were used as reference criteria.

Documents reviewed are listed in the Attachment. This inspection activity satisfied one inspection sample for the emergency action level and emergency plan changes.

b. Findings

No findings were identified.

1EP5 Maintenance of Emergency Preparedness

a. Inspection Scope

The inspectors reviewed the corrective actions identified through the Emergency Preparedness program to determine the significance of the issues, the completeness and effectiveness of corrective actions, and to determine if issues were recurring. The licensees post-event action reports, self-assessments, and audits were reviewed to assess the licensees ability to be self-critical, thus avoiding complacency and degradation of their emergency preparedness program. Inspectors reviewed the licensees 10 CFR Part 50.54(q) change process, personnel training, and selected screenings and evaluations to assess adequacy. The inspectors toured facilities and reviewed equipment and facility maintenance records to assess licensees adequacy in maintaining them. The inspectors evaluated the capabilities of selected radiation monitoring instrumentation to adequately support Emergency Action Level (EAL)declarations.

The inspection was conducted in accordance with NRC Inspection Procedure 71114.05, Maintenance of Emergency Preparedness. The applicable planning standards, related 10 CFR Part 50, Appendix E requirements, and 10 CFR Part 50.54(q) and

(t) were used as reference criteria. Documents reviewed are listed in the Attachment. This inspection activity satisfied one inspection sample for the maintenance of emergency preparedness.

b. Findings

No findings were identified.

4OA1 Performance Indicator Verification

a. Inspection Scope

The inspectors sampled licensee data to confirm the accuracy of reported PI data for the performance indicators (PIs) during periods listed below. To determine the accuracy of the reported PI elements, the reviewed data was assessed against PI definitions and guidance contained in Nuclear Energy Institute 99-02, Regulatory Assessment Indicator Guideline, Rev. 7. Documents reviewed are listed in the Attachment.

Cornerstone: Mitigating Systems

• safety system functional failures

• heat removal system

• cooling water system The inspectors reviewed plant records compiled between October 2013 and October 2014 to verify the accuracy and completeness of the data reported for the station. The inspectors verified that the PI data complied with guidance contained in Nuclear Energy Institute 99-02 and licensee procedures. The inspectors verified the accuracy of reported data that were used to calculate the value of each PI. In addition, the inspectors reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with PI data.

Emergency Preparedness Cornerstone

• Emergency Response Organization (ERO) Drill/Exercise Performance

• ERO Drill Participation

• Alert and Notification System Reliability For the period July 1, 2013, through September 30, 2014, the inspectors examined data reported to the NRC, procedural guidance for reporting PI information, and records used by the licensee to identify potential PI occurrences. The inspectors verified the accuracy of the PI for ERO drill and exercise performance through review of a sample of drill and event records. The inspectors reviewed selected training records to verify the accuracy of the PI for ERO drill participation for personnel assigned to key positions in the ERO.

The inspectors verified the accuracy of the PI for alert and notification system reliability through review of a sample of the licensees records of periodic system tests. The inspectors also interviewed the licensee personnel who were responsible for collecting and evaluating the PI data.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review

The inspectors screened items entered into the licensees corrective action program in order to identify repetitive equipment failures or specific human performance issues for followup. The inspectors reviewed condition reports, attended screening meetings, or accessed the licensees computerized corrective action database.

.2 Semi-Annual Trend Review

a. Inspection Scope

The inspectors reviewed issues entered in the licensees corrective action program and associated documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors focused their review on repetitive equipment issues, but also considered the results of inspector daily condition report screenings, licensee trending efforts, and licensee human performance results. The review nominally considered the 6-month period of July 2014 thru December 2014 although some examples extended beyond those dates when the scope of the trend warranted.

The inspectors compared their results with the licensees analysis of trends.

Additionally, the inspectors reviewed the adequacy of corrective actions associated with a sample of the issues identified in the licensees trend reports. The inspectors also reviewed corrective action documents that were processed by the licensee to identify potential adverse trends in the condition of structures, systems, and/or components as evidenced by acceptance of long-standing non-conforming or degraded conditions.

Documents reviewed are listed in the Attachment.

b. Findings and Observations

No findings were identified.

.3 Annual Followup of Selected Issues

a. Inspection Scope

The inspectors conducted a detailed review of the following condition report:

• CR 870626, Fire Penetration Seal 1Z43H811D has void in seal The inspectors evaluated the following attributes of the licensees actions:

• complete and accurate identification of the problem in a timely manner

• evaluation and disposition of operability and reportability issues

• consideration of extent of condition, generic implications, common cause, and previous occurrences

• classification and prioritization of the problem

• identification of root and contributing causes of the problem

• identification of any additional condition reports

• completion of corrective actions in a timely manner Documents reviewed are listed in the Attachment.

b. Findings

Introduction:

The NRC identified a Severity Level IV Non-Cited Violation (NCV) of 10 CFR Part 50.72(b)(3)(ii)(B), Immediate Notification Requirements for Operating Nuclear Power Reactors, and 10 CFR Part 50.73(a)(2)(ii)(B) Licensee Event Report System for failure to report unanalyzed conditions that significantly degraded plant safety.

Specifically, the licensee failed to notify the NRC upon discovery of reportable degraded conditions in the control building that could have resulted in the loss of both Unit 1 safe shutdown paths in the event of a postulated fire.

Description:

On May 29, 2014, the licensee identified several fire boundary penetration seals in hollow block walls had 1.5 inches or less of grout which did not meet 10 CFR Part 50 Appendix R requirements and potentially compromised both paths of safe shutdown for Unit 1 on all levels of the control building. The licensee reported this condition under 10 CFR Part 50.72(b)(3)(ii)(B) as an unanalyzed condition which could potentially affect both paths of safe shutdown for Unit 1 and as a licensee event report (LER) on July 25, 2014.

The licensee conducted additional inspections on fire boundary penetration seals in hollow block walls as part of an extent of condition review. On August 4, 2014, the licensee identified a gap around the entire annulus of fire penetration 1Z43H520C that potentially compromised both paths of safe shutdown for Unit 1 on the 112-foot elevation of the control building. On September 24, 2014, the licensee discovered fire penetration seal 1Z43H811D contained a void with no fire sealant material installed behind a pull box which could compromise both paths of safe shutdown for Unit 1 on the 130 foot elevation of the control building. Both of these conditions were unanalyzed and degraded plant safety. Therefore, they were reportable under 10 CFR Part 50.72 (8-hour reportability) and 10 CFR Part 50.73 (60 day LER).

On August 5, 2014, the licensee issued a Reportability Analysis to address the reporting of multiple events such as those being experienced with fire penetrations. The licensee reviewed NUREG-1022, Event Reporting Guidelines 10 CFR Part 50.72 and 50.73, Rev. 3, and quoted section 2.3 which stated in part More than one failure or event may be reported in a single ENS notification or LER if

(1) the failures or events are related (i.e., they have the same general cause or consequences) and

(2) they occurred during a single activity (e.g., a test program) over a reasonably short time (e.g., within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for ENS notifications, or within 60 days for LER reporting). To the extent feasible, report failures that occurred within the first 60 days of discovery of the first failure in one LER. If appropriate, state in the LER text that a supplement to the LER will be submitted when the test program is completed. In the revised LER, include all of the failures, including those reported in the original LER (i.e., the revised LER should stand alone). The licensees reportability analysis concluded that new occurrences, of related degraded conditions, identified during extent of condition that had the same consequences were not reportable under 50.72(b)(3)(ii)(B) because the original ENS covered each additional example. The reportability analysis also discussed submitting a supplement to the previously submitted LER that would include additional examples found during the inspection activity. Consequently, the licensee did not make an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> report nor submit a LER within 60 days for these two additional degraded penetrations.

The inspectors reviewed the licensees reportability analysis and NUREG-1022.

Although they had the same safe shutdown consequences, the two additional instances of degraded penetrations had later discovery dates from the May 29, 2014, degraded penetration which exceeded the limit specified in NUREG-1022. Therefore, the inspectors determined that the licensee could not take credit for the 8-hour report and LER submittal for the May 29, 2014, degraded penetration and that these two additional degraded penetrations were separately subject to the reporting requirements of 10 CFR Part 50.72 (8-hour reportability) and 10 CFR Part 50.73 (60-day LER).

Analysis:

Failure to report an unanalyzed condition that significantly degraded plant safety as required by 10 CFR Part 50.72(b)(3)(ii)(B) and 10 CFR Part 50.73(a)(2)(ii)(B)was a performance deficiency (PD). The PD potentially impeded or impacted the regulatory process and was evaluated using traditional enforcement in accordance with Section 6 of the NRC Enforcement Policy. Failure to make a report required by 10 CFR Part 50.72 or 10 CFR Part 50.73 is identified in example 9 of Section 6.9.d as a Severity Level IV violation. Cross-cutting aspects are not assigned to traditional enforcement violations.

Enforcement:

10 CFR Part 50.72(b)(3)(ii)(B), Immediate Notification Requirements for Operating Nuclear Reactors, requires, in part, the licensee shall notify the NRC as soon as practical and in all cases within eight hours of the occurrence of the nuclear power plant being in an unanalyzed condition that significantly degrades plant safety. 10 CFR Part 50.73(a)(2)(ii)(B), Licensee Event Report System, requires in part, the licensee shall report any event or condition that resulted in the nuclear power plant being in an unanalyzed condition that significantly degraded plant safety within 60 days after discovery of the event. Contrary to the above, the licensee did not notify the NRC within eight hours and submit a LER within 60 days from the time of discovery of degraded fire penetration seals that resulted in an unanalyzed condition that significantly degraded plant safety. Specifically, the licensee discovered gaps in fire penetration seals on August 4, 2014 as well as missing fire penetration sealant on September 24, 2014 and failed to notify the NRC that these degradations of fire penetration seals caused an unanalyzed condition. The violation of regulatory requirement began on August 4 and does not represent a current safety concern because the failure to report resulted in no substantial change in NRC regulatory stance. This violation is being treated as a NCV, consistent with Section 2.3.2 of the Enforcement Policy. The violation was entered into the licensees corrective action program as CR 870626. (NCV 05000321/2014005-002, Failure to report degraded fire penetration seals per 50.72 and 50.73)

4OA3 Followup of Events and Notices of Enforcement Discretion

.1 (Closed) LER 05000366/2014-001, Revision 1, Incorrectly Sized Thermal Overloads

Result in a Condition Prohibited by Plant Technical Specifications

a. Inspection Scope

The inspectors reviewed this LER for potential performance deficiencies and/or violations of regulatory requirements. This LER is a supplement to LER 2014-001-00. This condition was documented in the licensees corrective action program as CR 822819.

b. Findings

No new findings were identified.

.2 (Closed) LER 05000321/2014-007 and LER 05000321/2014-007, Revision 1,

Unanalyzed Condition Due to a Non-functional Penetration Affecting Both Safe Shutdown Paths During a Postulated Fire

a. Inspection Scope

The inspectors reviewed this LER for potential performance deficiencies and/or violations of regulatory requirements. Additionally, discussions were held with operations, engineering, and licensing staff members to understand the details surrounding this issue. This condition was documented in the licensees corrective action program as CR 865613.

b. Findings

The enforcement aspects of this finding are discussed in Section 1R05.

4OA5 Other Activities

.1 (Closed) Temporary Instruction 2515/190 - Inspection of the Proposed Interim Actions

Associated with Near-Term Task Force Recommendation 2.1 Flooding Hazard Evaluations.

a. Inspection Scope

Inspectors verified that licensees interim actions will perform their intended function for flood mitigation. The inspectors independently verified that the licensees proposed interim actions would perform their intended function for flooding mitigation.

• Visual inspection of the flood protection feature was performed if the flood protection feature was relevant. External visual inspection for indications of degradation that would prevent its credited function from being performed was performed.

• Reasonable simulation.

• Flood protection feature functionality was determined using either visual observation or by review of other documents.

The inspectors verified that issues identified were entered into the licensees corrective action program.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

On January 23, 2015, the resident inspectors presented the inspection results to Mr.

David Vineyard and other members of the licensees staff. The inspectors confirmed that proprietary information was not provided or examined during the inspection period.

4OA7 Licensee-Identified Violations

The following LIVs of very low safety significance (Green) were identified and determined to be violations of NRC requirements which meet the criteria of Section VI of the NRC Enforcement Policy, NUREG-1600, for being dispositioned as Non-Cited Violations (NCVs).

• Title 10 of the Code of Federal Regulations (10 CFR Part 50.54(q)(2)) requires, in part, that a holder of a license under this part shall follow and maintain the effectiveness of an emergency plan that meets the requirements in 10 CFR Part 50, Appendix E and the planning standards of 10 CFR Part 50.47(b). 10 CFR Part 50, Appendix E, Section IV.A.9 states, By December 24, 2012, for nuclear power reactor licensees, a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan, shall be included.

Contrary to the above, on December 24, 2012, the licensees detailed analysis of on-shift staffing was deficient in that the specific scenario involving a fire in the Main Control Room with dual unit remote shutdown panel operations was evaluated assuming a typical complement of 17 operations personnel vice the 14 specified in the licensees Emergency Plan and fire response plan. The licensee subsequently performed a detailed time-motion study and determined that all required functions could have been performed, but individual workload capacity would have been challenged. The NRC determined that with no identified loss or degradation of a planning standard function, the failure to complete the detailed analysis in accordance with 10 CFR Part 50, Appendix E, Section IV.A.9, was a very low safety significance issue (Green) as indicated in Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, Revision dated September 26, 2014. This violation was documented in CAR 11209.

Immediate corrective actions included interim augmentation for on-shift positions and the on-shift staffing analysis was re-performed. Final incorporation into the licensees emergency plan is in progress.

• Title 10 CFR Part 50.54(q)(2) requires, in part, that a licensee shall follow and maintain the effectiveness of an emergency plan which meets the planning standards of 10 CFR Part 50.47(b). 10 CFR Part 50.47(b)(4) requires that a standard emergency action level (EAL) scheme, the bases of which include facility system and effluent parameters, is in use by nuclear facility licensee, and state and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.

Contrary to the above, from May 2011 to November 2013, the licensee failed to maintain the effectiveness of its emergency plan. The System Malfunction EAL for Fuel Clad Degradation (SU4) listed incorrect reactor coolant sample activity threshold values and the Fission Product Barrier EAL contained an incorrect drywell radiation monitor threshold value for reactor coolant system leakage (FA1). These incorrect EAL values were associated with changes to the license technical specifications when incorporating an alternate source term. The licensee implemented immediate compensatory actions by issuing a standing order to include the correct threshold values and informed appropriate operators and decision-makers. These corrected values were then incorporated into Revision 3 of procedure NMP-EP-110-GL02, HNP EALs - ICs, Threshold Values and Basis. The issue was placed in their corrective action program as CR732879. This violation was determined not to be greater than Green as these incorrect EAL threshold values only affected Unusual Event and Alert declarations using Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, Revision dated September 26, 2014.

Supplemental Information

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

B. Anderson, Health Physics Manager

G, Brumbelow, Emergency Preparedness (EP) Supervisor

C. Burke, Project Manager

G. Brinson, Maintenance Director

B. Duval, Chemistry Manager

A. Giancatarino, Engineering Director

S. Grantham, Training Director

R. Henszey, EP Specialist

G. Johnson, Site Regulatory Affair Manager

D. Komm, Operations Director

K. Long, Work Management Director

J. Major, Licensing Engineer

D. Moore, EP Specialist

G. Ohmstede, Fleet Examination Manager

R. Outler, Senior Cause Analyst

J. Smallwood, Contractor - Field Service Technician

R. Spring, Plant Manager

S. Tipps, Principal Licensing Engineer

M. Torrance, Nuclear Oversight Manager

P. Underwood, Operations Shift Manger

R. Varnadore, Training Manager

D. Vineyard, Hatch Vice President

C. Vonier, Shift Operations Manager

K. Wainwright, Operations Training Manager

A. Wheeler, Site Projects Manager

LIST OF REPORT ITEMS

Closed

Incorrectly Sized Thermal Overloads Result in a LER

05000366/2014-001 Rev. 1 Condition Prohibited by Plant Technical Specifications (Section 4OA3.1)

Unanalyzed Condition Due to a Non-Functional LER

05000321/2014-007-00, -01 Penetration Affecting Both Safe Shutdown Paths During a Postulated Fire (Section 4OA3.2)

TI

05000321, 366/2515/190 Inspection of the Proposed Interim Actions Associated with Near-Term Task Force Recommendation 2.1 Flooding Hazard Evaluations (Section 4OA5.1)

Opened &

Closed

NCV

05000321/2014005-001 Failure to evaluate fire penetration 1T43-H528J (Section 1R05)

NCV

05000321/2014005-002 Failure to report degraded fire penetration seals per 50.72 and 50.73 (Section 4OA2.3)