IR 05000321/2020002

Integrated Inspection Report 05000321/2020002 and 05000366/2020002

ML20218A205
Person / Time
Site:	Hatch
Issue date:	08/05/2020
From:	Alan Blamey NRC/RGN-II/DRP/RPB2
To:	Gayheart C Southern Nuclear Operating Co
References
IR 2020002
Download: ML20218A205 (19)

Text

August 5, 2020

SUBJECT:

EDWIN I. HATCH NUCLEAR PLANT - INTEGRATED INSPECTION REPORT 05000321/2020002 AND 05000366/2020002

Dear Ms. Gayheart:

On June 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Edwin I. Hatch Nuclear Plant. On July 23, 2020, the NRC inspectors discussed the results of this inspection with Mr. Sonny Dean, Site VP 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.

A licensee-identified violation which was determined to be of very low safety significance is documented in this report. 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 violations or the significance or severity of the violations 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 Edwin I. Hatch Nuclear Plant.

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 Edwin I. Hatch Nuclear Plant. 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/

Alan J. Blamey, Chief Reactor Projects Branch 2 Division of Reactor Projects

Docket Nos. 05000321 and 05000366 License Nos. DPR-57 and NPF-5

Enclosure:

As stated

Inspection Report

Docket Numbers:

05000321 and 05000366

License Numbers:

DPR-57 and NPF-5

Report Numbers:

05000321/2020002 and 05000366/2020002

Licensee:

Southern Nuclear Operating Co. Inc.

Facility:

Edwin I. Hatch Nuclear Plant

Location:

Baxley, GA

Inspection Dates:

April 01, 2020 to June 30, 2020

Inspectors:

J. Hickman, Resident Inspector

M. Schwieg, Senior Resident Inspector

Approved By:

Alan J. Blamey, Chief

Reactor Projects Branch 2

Division of Reactor Projects

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Edwin I. Hatch Nuclear Plant, 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. A licensee-identified non-cited violation is documented in report section: 7115

List of Findings and Violations

Failure to Identify and Correct Water Intrusion into 1A Fuel Oil Storage Tank Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000321/2020002-01 Open/Closed

[P.2] -

Evaluation 71152 The inspectors identified a self-revealing Green NCV of 10 CFR Part 50, Appendix B,

Criterion XVI, Corrective Action, which states, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformance are promptly identified and corrected. Specially, from March 4, 2020 until June 11, 2020 the licensee failed to identify and correct for water intrusion in the 1A fuel oil storage tank (FOST), a condition adverse to quality.

Additional Tracking Items

None.

PLANT STATUS

Unit 1 began the inspection period at or near rated thermal power. On April 16, 2020, the unit was down powered to 54 percent due to indication of high bearing temperature (bearing #5) on the Main Turbine. The unit was returned to rated thermal power on April 18, 2020. On May 31, 2020, the unit was down powered to 71 percent due to a loss of Turbine Building chillers &

indication of high Condenser Bay temperature (175oF). The unit was returned to rated thermal power on June 1, 2020. On June 19, 2020, the unit was shutdown to repair/replace temperature switches and a Drywell cooling fan motor. The unit was restarted on June 26, 2020, and returned to rated thermal power on June 30, 2020. Unit 1 operated at or near rated thermal power for the remainder of the inspection period.

Unit 2 began the inspection period at or near rated thermal power. On April 14, 2020, the unit was shutdown to repair two Primary Containment Isolation Valves. The unit was restarted on April 22, 2020, and returned to rated thermal power on April 28, 2020. On May 31, 2020, the unit was down powered to 68 percent due to increased frequency testing of the Main Turbine valves. The unit was returned to rated thermal power on May 31, 2020. On June 27, 2020, the unit was down powered to 80 percent to remove 2B Condensate Booster pump from service to repair an oil leak. The unit was returned to rated thermal power on June 29, 2020. Unit 2 operated at or near rated thermal power 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 performed plant status activities described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. 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 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 and during that time 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 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.

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 Summer Readiness for the following systems:

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (3 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Alignment of 2C emergency diesel generator (EDG) following 34SV-R43-003-2 Diesel Generator 2C Monthly Test. 34SO-R43-001-2, Diesel Generator Standby AC System, 3 on April 6, 2020.

(2) Unit 2 Stand-by Gas Treatment System alignment following replacement of containment vent valves 2T48F319/320. 34SO-T46-001-2, Stand-by Gas Treatment System, on April 22, 2020.

(3) Alignment of 1A EDG following 34SV-R43-001-1 Diesel Generator 1A Monthly Test.

34SO-R43-001-1, Diesel Generator Standby AC System, Attachment 3 on May 18, 2020.

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 High Pressure Coolant Injection (HPCI) Room, Fire Zone 1205, Drawing A43965 Sheet 55 on April 9, 2020.

(2) Unit 1 and 2 Control Room, Fire Zone 0024 Drawing A-43965, Sheet 048 on April 27, 2020.

(3) Unit 1 Working Floor and Adjustable Speed Drive area, Fire Zone 1203, 158' Reactor Building, Drawing 43965 Sheet 060 on May 11, 2020.

(4) Intake Structure, 111' level, Fire Zone 0501, Drawing 43966 Sheet 027 on June 17, 2020.

(5) LPCI Inverter Room, Control Building 147', Fire Zone 0028, Drawing 43965 Sheet 047 on June 18, 2020.

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)

The inspectors evaluated internal flooding mitigation protections in the:

(1) Unit 1 northeast and southeast diagonals on April 10, 2020.

Cable Degradation (IP Section 03.02) (1 Sample)

The inspectors evaluated cable submergence protection in:

(1) Safety related cables in pull boxes PB1-DO and PB1-DP on June 8, 2020.

71111.07A - Heat Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) 1A residual heat removal (RHR) heat exchanger

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 during the Unit 2 Reactor Shutdown, Unit 2 Reactor Startup, Unit 1 Reactor Shutdown, and Unit 1 Reactor Startup on April 14, 2020, April 22, 2020, June 20, 2020, and June 25, 2020.

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

(1) The inspectors observed and evaluated a crew of licensed operators in the plants simulator during licensed operator just in time training in preparation of Unit 1 reactor startup on June 19, 2020.

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)1A RHR service water in-service testing failure due to excessive minimum flow on May 18, 2020.

(2) CR 10711083 2C EDG voltage and frequency swinging while unloaded preventing parallel on May 23, 2020.

Quality Control (IP Section 03.02) (1 Sample)

The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:

(1) CR 10701123 Unit 1 "H" safety relief valve pilot temperature trends abnormal. SNC

===1090081 Replace Unit 1 "H" pilot valve on June 23, 2020.

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01)===

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 1 elevated risk due to "H" safety relief valve pilot leakage, CR10701123 on April 16, 2020.

(2) Unit 2 elevated risk during startup with HPCI and Reactor Core Isolation Cooling (RCIC) not in standby greater than 150 psig, CR 10704520 on April 24, 2020.

(3) Unit 1 elevated risk due to water intrusion into the 1A EDG fuel oil system on May 8, 2020.

(4) Unit 2 elevated risk due to 2C EDG governor failure on May 27, 2020.

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) CR10699921,1C EDG Generator visual inspection, missing and loose stator blocking on April 2, 2020.

(2) CR10704520, During Unit 2 Startup, HPCI and RCIC systems not in standby greater than 150 psig, on April 24, 2020.

(3) CR10705476, 2A Residual Heat Removal Service Water Pump failed operability test, in the required action range, on April 29, 2020.

(4) CR10707858, Water found during sampling of 1A EDG Fuel Oil Day Tank, on May 8, 2020.

(5) CR10709451 1A RHRSW Pump failed Surveillance 34SV-E11-004-1 in the required action range, on May 20, 2020.

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) SNC1099369, Condenser Bay Temperature Switch Bypass Temporary Modification.

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)52SV-R43-001-0, Diesel, Alternator, and Accessories Inspection, Version 31.7, following outage on April 3, 2020.

(2) NMP-ES-014-010, AOV Diagnostic Testing and Signature Evaluation, Version 6.0, following replacement of 2T48F319/320 containment isolation valves on April 17, 2020.

(3)34SV-R43-001-1, Diesel Generator 1A Monthly Test, Version 25.1 following cleaning of the Fuel Oil Storage and Day Tanks on May 18, 2020.

(4)34SV-R43-006-2, Diesel Generator 2C Semi-Annual Test, Version 18.1 following governor replacement on May 30, 2020.

(5)52PM-P41-036-2, Unit 2 Plant Service Water Pump and Motor Inspection and Overhaul, Version 9.6 following the replacement of 2D Plant Service Water Pump on June 12, 2020.

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Sample 1 Partial)

(1)

(Partial)

The inspectors evaluated the Unit 2 forced outage for the replacement of two containment isolation valves from April 14 to April 23, 2020. This constituted a partial sample because the drywell walkdown was not completed due to the low drywell work (one Source Range Monitor cable replaced) and limited on-site resident staff.

(2) The inspectors evaluated the Unit 1 forced outage for the replacement of "B" Adjustable Speed Device controller, drywell fan motor, and drywell sump pump from June 20 to June 26, 2020.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1)34SV-R43-010-0, DG Fuel Transfer Pump surveillance on May 5, 2020.

(2)57SV-C32-003-2, Reactor Water level functional test on May 22, 2020.

(3)34SV-E41-002-1, HPCI Pump Operability, Version 32.5 on June 10, 2020.

(4)34SV-R43-003-1, Diesel Generator 1C Monthly Test, Version 20.1 on June 12, 2020.

(5)64CH-SAM-025-0, Reactor Coolant Sampling and Analysis, Version 46.0 on June 30, 2020.

Inservice Testing (IP Section 03.01) (1 Sample)

(1)34SV-E21-002-1, 1A Core Spray Valve Operability IST, Version 12.5 on April 27, 2020.

RCS Leakage Detection Testing (IP Section 03.01) (1 Sample)

(1)34SV-SUV-019-1, Surveillance Checks (Unidentified Leak-rate Calculation), Version 37.29 on June 15, 2019.

Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)

(1)42SV-TET-001-0, LLRT Testing Methodology, version 13.0 of valves 2T48F319/320 on April 20, 2020.

71114.06 - Drill Evaluation

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

The inspectors evaluated:

(1) Licensed reactor operators respond to a HPCI steam line break in the simulator and observed the crew make an emergency declaration and notification. This represented a drill and exercise performance opportunity on April 30,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10)===

(1) Unit 1 from April 1, 2019 to March 31, 2020.

(2) Unit 2 from April 1, 2019 to March 31, 2020.

BI02: RCS Leak Rate Sample (IP Section 02.11) (2 Samples)

(1) Unit 1 from April 1, 2019 to March 31, 2020.

(2) Unit 2 from April 1, 2019 to March 31, 2020

71152 - Problem Identification and Resolution

Semiannual Trend Review (IP Section 02.02) (1 Sample)

(1) The inspectors reviewed the licensees corrective action program for a potential adverse trend in safety-related pull box water intrusion issues.

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) While performing calibration of multiple main steam line leak detector temperature switch's trip setpoint was low out of tolerance. CRs 10717202, 10717204, 10717207, and 10717208.

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

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

(1) LER 05000366/2020-002-00, HPCI and RCIC Inoperable When Required by Technical Specifications (ADAMS Accession No. ML20170A531) on June 18, 2020.

The circumstances surrounding this LER are documented in the results section for IP

INSPECTION RESULTS

Failure to Identify and Correct Water Intrusion into 1A Fuel Oil Storage Tank Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems

Green NCV 05000321/2020002-01 Open/Closed

[P.2] -

Evaluation 71152 The inspectors identified a self-revealing Green NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, which states, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformance are promptly identified and corrected. Specially, from March 4, 2020 until June 11, 2020 the licensee failed to identify and correct for water intrusion in the 1A fuel oil storage tank (FOST), a condition adverse to quality.

Description:

On May 8, 2020, chemistry acquired a sample from the 1A emergency diesel generator (EDG) day tank and reported 14.7 gallons were pure water and 2.5 gallons were a 50/50 mixture of water and fuel. The licensee documented this condition in CR 10707858. On May 12, 2020, the 1A EDG was declared inoperable to drain the 1A FOST to remove all water from the tank and the 1A EDG was returned to service on May 15, 2020. As a result, the 1A EDG was unavailable for a period of 3 days.

The licensee determined the water intrusion in the 1A FOST came from a nearby pull box PB1-DO. The water was able to pass through the pull box conduit into the 1A FOST enclosure. The FOST enclosure flooded due to the enclosure drain holes being clogged. The water entered the FOST tank through the tank manway cover. Additionally, the licensee determined the 1A Day Tank water detection system was not functional due to a calibration error. The detection system was calibrated on May 12, 2020 and returned to service.

On June 4, 2020, the 1A EDG fuel oil moisture alarm was received. The adjacent pull boxes to 1A FOST were inspected and additional water intrusion was identified. The licensee determined a nearby pipe leak in the sanitary water line on the north end of the EDG building was the cause of the water intrusion. The leak was repaired on June 11, 2020.

The inspectors reviewed the pull box inspection records and determined the water intrusion into the 1A FOST occurred over a period from March 4, 2020 to June 11, 2020, when the sanitary water pipe was repaired.

Corrective Actions: The licensee drained and removed all water from the 1A FOST, Day Tank, and 1A EDG engine fuel lines. The 1A Day Tank water detection system was calibrated and returned to service. The routine tank sampling frequency was increased on the FOST and Day tanks.

Corrective Action References: CR-10707858 and CR-10707660

Performance Assessment:

Performance Deficiency: The licensee did not promptly identify and correct the water intrusion in the 1A FOST. As a result, the 1A EDG was declared unavailable due to the draining and removing of the fuel and water from the 1A FOST, 1A Day Tank and associated fuel lines.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the 1A EDG was declared unavailable for 3 days due to the draining and removing of water from the 1A FOST, Day Tank and associated fuel lines.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. In accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, Exhibit 2, Mitigating Systems Screening Questions, the issue screened to Exhibit 4, External Events Screening Questions, because it was potentially risk-significant due to seismic, flooding, or severe weather. Per Exhibit 4 this finding screened to a Detailed Risk Evaluation because it would degrade one or more trains of a system that supports a risk-significant system.

A senior reactor analyst (SRA) conducted a detailed risk assessment to bound this condition using NRC IMC 0609 Appendix A, Significance Determination Process at Power. As a conservative bounding approximation, the SRA assumed the 1A EDG would fail to start (since the Water would enter the combustion chamber in the first minute) and that the failure of the 1A EDG was independent since the Performance Deficiency only affected the associated 1A EDG Fuel Oil Storage Tank. The analysis set exposure time to 13 days (time when the 1A EDG was last run and 1A EDG FOST was filled: 10 days plus repair time to drain and refill the FOST and Day tank: 3 days.) This is a conservative assumption since actual operability of the EDG is uncertain. The SRA used SAPHIRE 8 version 8.2.1 and the Hatch Unit 1 & 2 SPAR model version 8.58 dated 2/28/2017. The SRA adjusted the model to set EPS-DGN-FS-DG1A to 1.0 to model the condition as an independent failure of a single EDG. The dominant accident sequence was a Transient with loss of offsite power, stuck open relief valve, failure of high and low pressure injection and containment venting. Since internal events were greater than 1E-7, event assessments were also performed for fire, internal flooding, hurricane, seismic, and tornado external events. Risk for this bounding case was less than 1E-6 which corresponds to a finding of very low safety significance (Green).

The SRA also considered the special case of an intense local precipitation event. Such an event in conjunction with the performance deficiency could cause enough water to leak into the FOST undetected such that the supported EDG may not be able to run for its mission time. The exposure time would be the time between EDG quarterly surveillance tests and fuel oil monitoring samples. The conditional risk would be the probability of an intense rain event (1.55e-2 ) X CCDP for 1A Failure to Run (3.954 E-5) x 3 months x yr/12 months = 1.53 E-7 Core damage event from a rain event /yr. This would also correspond to finding of very low safety significance (Green).

Cross-Cutting Aspect: P.2 - Evaluation: The organization thoroughly evaluates issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance. The organization thoroughly evaluates issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance (PI.2).

Enforcement:

Violation: Title 10 of CFR Part 50, Appendix B, Criterion XVI, Corrective Action, which states, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformance are promptly identified and corrected.

Contrary to the above, from March 4, 2020 until June 11, 2020, the licensee failed to evaluate and correct the source of the water intrusion into the 1A FOST. In response to this issue, the licensee drained the 1A FOST to remove all water and identified the source of water intrusion as an underground pipe leak. The pipe leak was repaired.

Enforcement Action: This violation is being treated as an non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Licensee-Identified Non-Cited Violation 71153 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Violation: Title 10 of the Code of Federal Regulations Part 50 (10 CFR 50), Appendix B, Criterion V, "Instructions, Procedures and Drawings," requires in part that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

Contrary to the above, on April 22, 2020, the licensee failed to follow Hatch procedure, 34GO-OPS-001-2, Plant Startup, Version 51.6, steps 4.3.16 and 4.3.19.a, by not placing Reactor Core Isolation Cooling (RCIC) and High Pressure Coolant Injection (HPCI) Systems in standby prior to allowing Unit 2 reactor pressure to exceed 150 psig when Unit 2 was in Startup (Mode 2) as required by Technical Specifications 3.5.1 and 3.5.3. The established heat-up rate impacted the ability of the shift crew to meet reactor pressure limits outlined within the procedure. When recognized by the shift crew that RCIC and HPCI were not in standby, the pressure was at approximately~146 psig and rising 5 psig every 3 minutes.

When reactor pressure reached 150 psig the mode of applicability for HPCI and RCIC systems was entered, but the systems were not in standby as required. The shift crew restored RCIC and HPCI to operability within 28 and 56 minutes respectively of exceeding 150 psig.

Significance/Severity: Green. The inspectors assessed the significance of the violation using Exhibit 2, Mitigating Systems Screening Questions, of Inspection Manual Chapter (IMC)0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, issued December 13, 2019. The inspectors concluded this violation is of very low safety significance (Green). Specifically, during the short time period that Unit 2 HPCI and RCIC were inoperable, the Automatic Depressurization System (ADS) and Low Pressure Emergency Core Cooling Systems were operable.

Corrective Action References: Condition Report 10704520 and CAR

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On July 23, 2020, the inspectors presented the integrated inspection results to Mr.

Sonny Dean, Site VP and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.01

Procedures

34AB-S11-001-0

Operation with Degraded System Voltage

Version 6.0

NMP-OS-020

Station Response to Southern Company Alert Conditions

Version 1.2

71111.04

Procedures

34SO-R43-001-1

Diesel Generator Standby AC System, Attachment 3

Version 29.3

34SO-R43-001-2

Diesel Generator Standby AC System, Attachment 3

Version 30.6

34SO-T46-001-2

Stand-by Gas Treatment System

Version 15.3

34SV-R43-001-1

Diesel Generator 1A Monthly Test

Revision

25.0

34SV-R43-003-2

Diesel Generator 2C Monthly Test

Version 25.2

71111.05

Fire Plans

A43965, Sheet 47 LPCI Inverter Room

Version 3.0

A43965, Sheet 48 Unit 1 and 2 Control Room

Version 4.0

A43965, Sheet 55 HPCI Pump Room

Revision 2

A43965, Sheet 60 Working Floor South Reactor Building Elevation 158'

Version 5.0

A43966, Sheet 27 Intake Structure

Version 4.0

71111.06

Calculations

BH2-M-387

Mechanical Calculations

July 14,

1983

Miscellaneous

E. I. Hatch Individual Plant Examination

December

1992

Hatch Final Safety Analysis Report, Sections 2.4 and 9.3

Revision

35.0

Procedures

2PM-Y46-001-0

Inground Pullbox Debris Removal/Inspection

Version 10.0

71111.07A

Procedures

NMP-ES-012-001

Inspection of Heat Exchangers

Ver. 2.0

Work Orders

SNC786730

Clean and Inspect 1A RHR HX

2/16/2020

71111.11Q Miscellaneous

H-LOCT 20-005-

R2

Just In Time Training - Plant Startup

03/10/2020

Procedures

34GO-OPS-001-1 Plant Startup

Version 46.0

34GO-OPS-001-2 Plant Startup

Version 51.7

34GO-OPS-013-1 Normal Plant Shutdown

Version 32.3

34GO-OPS-013-2 Normal Plant Shutdown

Version 33.3

71111.12

Corrective Action

Documents

CR 10701123

Unit 1 "H" Safety Relief Valve pilot temperature trends

abnormal.

04/06/2020

CR 10711083

2C EDG Voltage and Frequency Swinging while Unloaded

05/24/2020

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

preventing parallel.

Procedures

50AC-MNT-001-0

Maintenance Program

Version 35.0

NEI 99-02

Regulatory Assessment Performance Indicator Guideline

Revision 7

NMP-ES-027

Maintenance Rule Program

Version 9.0

NUMARC 93-01

Industry Guideline for Monitoring the Effectiveness of

Maintenance at Nuclear Power Plants

Revision 4A

71111.13

Calculations

Equipment Out of Service Calculations

April 16,

20

Equipment Out of Service Calculations

April 24,

20

Equipment Out of Service Calculations

May 8, 2020

Equipment Out of Service Calculations

May 27,

20

Corrective Action

Documents

CR10704520

HPCI not placed in standby for Unit 2 Startup

April 22,

20

Procedures

NMP-DP-001

Operational Risk Awareness

Ver. 16.0

NMP-OS-010-002 Hatch Protected Equipment Logs

Version 11.0

71111.15

Corrective Action

Documents

10699921

1C EDG Generator visual inspection, missing and loose

stator blocking

04/02/2020

10704520

During Unit 2 Startup, Reactor Pressure rose to 150 psig

prior to HPCI and RCIC being in standby

04/22/2020

10707858

Water found during sampling of 1A Emergency Diesel

Generator Fuel Oil Day Tank

05/08/2020

10709451

1A RHRSW Pump failed Surveillance 34SV-E11-004-1 in

the required action range

05/20/2020

Procedures

NMP-AD-012

Operability Determinations and Functional Assessments

Ver. 13.3

71111.19

Procedures

NMP-MA-014

Post Maintenance Testing/Post Modification Testing

Version 2.2

NMP-MA-014-

001

Post Maintenance Testing Guidance

Version 5.2

71111.20

Procedures

34GO-OPS-001-1 Plant Startup

Version 46.0

34GO-OPS-001-2 Plant Startup

Version 51.7

34GO-OPS-013-1 Normal Plant Shutdown

Version 32.3

34GO-OPS-013-2 Normal Plant Shutdown

Version 33.3

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.22

Corrective Action

Documents

10705879

PDO 2A Fuel Transfer Pump Surveillance

Rev. 0

Procedures

34SV-E21-002-1

Core Spray Valve Operability

Ver. 12.5

34SV-R43-010-0

DG Fuel Oil Transfer Pump Surveillance Test

Rev. 43

71114.06

Miscellaneous

LORP Scenario

H-LT-AF-00113

Loss of Control Rod Drive flow, 2C Plant Service Water

pump trip, Loss of Service Air, HPCI Steam Line Break,

HPCI Failed to Isolate, and Emergency Depress

04/30/2020

71151

Miscellaneous

Hatch Key Performance Indicators

April 2019

through

March 2020

NEI 99-02

Regulatory Assessment Performance Indicator Guideline

Revision 7

Procedures

NMP-AD-029

Preparation and Reporting of Regulatory Assessment

Performance Indicator Data and the Monthly Operating

Report

Version 1.1

71152

Corrective Action

Documents

10717202

Turbine area temperature switches out of calibration

06/22/2020

10717208

Turbine area temperature switched out of calibration

06/22/2020

Drawings

H11037

Unit 1 P&ID Fuel Oil Diesel Oil System

Ver. 29

H11185

Unit 1 Instrument Diesel Day Tanks and Main Tanks Level

Transmitters

Ver. 3.0

S13699

1000 Gal Fuel Oil Day Tank

04/05/1971

Engineering

Evaluations

Joint User Group

Conference

Review of Test Program Regarding the Through-Wall

Corrosion of Day Tank Vent Lines for Emergency Diesel

Generator A and B

07/15/2020

MPR-4187

Waterford Unit 3 Emergency Diesel Generator Feed Tank

Water Intrusion Test Report

April 2015

Miscellaneous

White paper

1A EDG Fuel Oil Storage Tank (Water Intrusion) Summary

Rev. 0

Procedures

NMP-AD-029

Preparation and Reporting of Regulatory Assessment

Performance Indicator Data and the Monthly Operating

Report

Version 2.0

NMP-ES-051-004

Pull Box Inspection

Ver. 6.0

NMP-GM-002

Corrective Action Program

Version 15.2

NMP-GM-002-

001

Corrective Action Program Instructions

Ver. 39.0

NMP-GM-002-

Effectiveness Review Instructions

Version 5.2

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

2