IR 05000321/2017009: Difference between revisions
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| number = ML18022A032 | | number = ML18022A032 | ||
| issue date = 01/19/2018 | | issue date = 01/19/2018 | ||
| title = | | title = NRC Problem Identification and Resolution Inspection Report 05000321/2017009 and 05000366/2017009 | ||
| author name = Blamey A | | author name = Blamey A | ||
| author affiliation = NRC/RGN-II/DRP/RPB2 | | author affiliation = NRC/RGN-II/DRP/RPB2 | ||
| addressee name = Vineyard D | | addressee name = Vineyard D | ||
| addressee affiliation = Southern Nuclear Operating Co, Inc | | addressee affiliation = Southern Nuclear Operating Co, Inc | ||
| docket = 05000321, 05000366 | | docket = 05000321, 05000366 | ||
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=Text= | =Text= | ||
{{#Wiki_filter: | {{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION ary 19, 2018 | ||
==SUBJECT:== | |||
EDWIN I. HATCH NUCLEAR PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000321/2017009 AND 05000366/2017009 | |||
==Dear Mr. Vineyard:== | |||
On December 7, 2017, the U. S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution biennial inspection at your Hatch Nuclear Plant Units 1 and 2 and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report. | |||
The NRC inspection team reviewed the plants corrective action program and the plants implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the plant was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety. | |||
The team also evaluated the plants processes for use of industry and NRC operating experience information and the effectiveness of the plants audits and self-assessments. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety. | |||
Finally, the team reviewed the plants programs to establish and maintain a safety-conscious work environment, and interviewed plant personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available. | |||
NRC inspectors documented one finding of very low safety significance (Green) in this report which involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy. If you contest the violation or the significance of the violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Hatch Nuclear Plant. | |||
If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement 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 Regional Administrator, Region II; and the NRC resident inspector at the 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding. | |||
Sincerely, | |||
/RA/ | |||
Alan Blamey, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket No. 50-321, 50-366 License No. DPR-57 and NPF-5 Enclosure: | |||
IR 05000321/2017009 and 05000366/2017009 w/Attachment: Supplemental Information Distribution via ListServ | |||
ML18022A032 OFFICE RII:DRP RII:DRP RII:DRS RII:DRP RII:DCI RII:DRP NAME ARuh NStaples SSanchez GCroon CCheung ABlamey DATE 1/19/2018 1/17/2018 1/19/2018 1/17/2018 1/17/2018 1/19/2018 | |||
U.S. NUCLEAR REGULATORY COMMISSION | |||
== | ==REGION II== | ||
Docket Nos.: 50-321, 50-366 License Nos.: DPR-57 and NPF-5 Report No.: 05000321/2017009 and 05000366/2017009 Licensee: Southern Nuclear Operating Company, Inc. | |||
Facility: Edwin I. Hatch Nuclear Plant Location: Baxley, GA Dates: November 13-17, 2017 December 4-7, 2017 Inspectors: A. Ruh, Senior Resident Inspector, Acting C. Cheung, Construction Inspector G. Croon, Senior Resident Inspector S. Sanchez, Senior Emergency Preparedness Inspector Approved by: Alan Blamey, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure | |||
=SUMMARY= | =SUMMARY= | ||
IR 05000321/2017009 and 05000366/2017009; 11/13/2017 - 12/7/2017; Hatch Nuclear Plant, Units 1 and 2; Biennial Inspection of the Problem Identification and Resolution Program. The inspection was conducted by two senior resident inspectors, one senior emergency preparedness inspector, and a construction inspector. One Green NCV was identified. 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, | IR 05000321/2017009 and 05000366/2017009; 11/13/2017 - 12/7/2017; Hatch Nuclear Plant, | ||
Units 1 and 2; Biennial Inspection of the Problem Identification and Resolution Program. | |||
The inspection was conducted by two senior resident inspectors, one senior emergency preparedness inspector, and a construction inspector. One Green NCV was identified. 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 dated April 29, 2015. Cross-cutting aspects are determined using IMC 0310, Aspects Within Cross-Cutting Areas dated December 4, 2014. | |||
All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated November 1, 2016. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, | |||
Revision 6. Documents reviewed by the inspectors which are not identified in the Report Details are identified in the List of Documents Reviewed section of the Attachment. | |||
Identification and Resolution of Problems The inspectors concluded that, in general, problems were properly identified, evaluated, prioritized, and corrected. The licensee was effective at identifying problems and entering them into the corrective action program (CAP) for resolution, as evidenced by the relatively few number of deficiencies identified by external organizations (including the NRC) that had not been previously identified by the licensee, during the review period. Generally, prioritization and evaluation of issues were adequate, formal root cause evaluations for significant problems were adequate, and corrective actions specified for problems were acceptable. Overall, corrective actions developed and implemented for issues were generally effective and implemented in a timely manner. | |||
The inspectors determined that overall, audits and self-assessments were adequate in identifying deficiencies and areas for improvement in the CAP, and appropriate corrective actions were developed to address the issues identified. Operating experience usage was found to be generally acceptable and integrated into the licensees processes for performing and managing work, and plant operations. | |||
Based on discussions and interviews conducted with plant employees from various departments, the inspectors determined that personnel at the site felt free to raise safety concerns to management and use the CAP to resolve those concerns. | |||
===NRC-Identified and Self-Revealing Findings=== | ===NRC-Identified and Self-Revealing Findings=== | ||
===Cornerstone: Mitigating Systems=== | ===Cornerstone: Mitigating Systems=== | ||
Green: | * Green: A self-revealing non-cited violation (NCV) of 10 CFR Part 50, Appendix B, | ||
Criterion XVI, Corrective Action, was identified for the licensees failure to establish measures to assure that corrective action was taken to preclude repetition of a significant condition adverse to quality (SCAQ). Specifically, the licensee failed to implement corrective actions that would have increased the reliability of the intermediate range monitoring (IRM) system and prevent repetitive reactor scrams for similar reasons. | |||
The licensee entered this issue in the CAP as CR 10356172. | |||
The failure to ensure corrective actions were taken for a SCAQ to preclude repetition of reactor scrams due to IRM spiking caused by external electronic noise was a performance deficiency. This performance deficiency is more-than-minor because it is associated with the equipment performance attribute of the Initiating Events Cornerstone and adversely affected the cornerstone objective because it resulted in a reactor scram, which upsets plant stability and challenges critical safety functions during shutdown as well as power operations. Using Inspection Manual Chapter 0609 Appendix A, the inspectors determined that this finding is of very low safety significance (Green) because it did not involve the loss of mitigation equipment per Exhibit 1.B Transient Initiators. | |||
The inspectors determined that the finding had a cross-cutting aspect of Conservative Bias (H.14) within the cross-cutting area of Human Performance because the licensee failed to use decision making-practices that emphasize prudent choices over those that are simply allowable. | |||
=REPORT DETAILS= | =REPORT DETAILS= | ||
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====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors reviewed the | The inspectors reviewed the licensees Corrective Action Program (CAP) procedures which described the administrative process for initiating and resolving problems primarily through the use of condition reports (CRs). To verify that problems were being properly identified, appropriately characterized, and entered into the CAP, the inspectors reviewed CRs that had been issued between December 2015 and October 2017, including a detailed review of selected CRs associated with the following risk-significant systems: Plant Service Water (PSW), Residual Heat Removal (RHR & RHRSW), and Emergency Diesel Generators (EDGs). Where possible, the inspectors independently verified that the corrective actions were implemented as intended. The inspectors also reviewed selected common causes and generic concerns associated with root cause evaluations (RCE) to determine if they had been appropriately addressed. To help ensure that samples were reviewed across all cornerstones of safety identified in the Reactor Oversight Process (ROP), the inspectors selected a representative number of CRs that were identified and assigned to the major plant departments, including operations, performance improvement, health physics, chemistry, emergency preparedness, and security. These CRs were reviewed to assess each departments threshold for identifying and documenting plant problems, thoroughness of evaluations, and adequacy of corrective actions. The inspectors reviewed selected CRs, verified corrective actions were implemented, and attended meetings where CRs were evaluated for significance to determine whether the licensee was identifying, accurately characterizing, and entering problems into the CAP at an appropriate threshold. | ||
The inspectors conducted plant walkdowns within the selected systems listed above and other plant areas to assess the material condition and to identify any deficiencies that had not been previously entered into the CAP. The inspectors reviewed CRs, maintenance history, CAs, completed work orders (WOs) for the systems, and reviewed associated system health reports. These reviews were performed to verify that problems were being properly identified, appropriately characterized, and entered into the CAP. Items reviewed generally covered a two-year period; however, in accordance with the inspection procedure, a five-year review was performed for selected systems for age-dependent issues. | |||
Control room walkdowns were also performed to assess the main control room (MCR)deficiency list and to ascertain if deficiencies were entered into the CAP and tracked to resolution. Operator workarounds (OWA) and operator burden screenings were reviewed, and the inspectors verified compensatory measures for deficient equipment which were being implemented in the field. | |||
The inspectors conducted a detailed review of selected CRs to assess the adequacy of the root cause and apparent cause evaluations of the problems identified. The inspectors reviewed these evaluations against the descriptions of the problem described in the CRs and the guidance in licensee procedure NMP-GM-002-001, Corrective Action Program Instructions. | |||
The inspectors assessed if the licensee had adequately determined the cause(s) of identified problems, and had adequately addressed operability, reportability, common cause, generic concerns, extent-of-condition, and extent-of-cause. The review also assessed if the licensee had appropriately identified and prioritized corrective actions to prevent recurrence. | |||
The inspectors reviewed selected industry operating experience (OE) items, including NRC generic communications, to verify that they had been appropriately evaluated for applicability and that issues identified through these reviews had been entered into the CAP. | The inspectors reviewed selected industry operating experience (OE) items, including NRC generic communications, to verify that they had been appropriately evaluated for applicability and that issues identified through these reviews had been entered into the CAP. | ||
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The inspectors reviewed site trend reports, to determine if the licensee effectively trended identified issues and initiated appropriate corrective actions when adverse trends were identified. | The inspectors reviewed site trend reports, to determine if the licensee effectively trended identified issues and initiated appropriate corrective actions when adverse trends were identified. | ||
The inspectors reviewed licensee audits and self-assessments, including those which focused on problem identification and resolution programs and processes, to verify that findings were entered into the CAP and to verify that these audits and assessments were consistent with the | The inspectors reviewed licensee audits and self-assessments, including those which focused on problem identification and resolution programs and processes, to verify that findings were entered into the CAP and to verify that these audits and assessments were consistent with the NRCs assessment of the licensees CAP. The inspectors attended various plant meetings to observe management oversight functions of the corrective action process. These included Performance Improvement Review Meetings and Management Review Committee (MRC) meetings. | ||
Documents reviewed are listed in the Attachment. | |||
b. Assessment | b. Assessment Problem Identification The inspectors determined that the licensee was generally effective in identifying problems and entering them into the CAP and there was an appropriately low threshold for entering issues into the CAP. This conclusion was based on a review of the requirements for initiating CRs as described in licensee procedure NMP-GM-002-001, Corrective Action Program Instructions and managements expectation that employees were encouraged to initiate CRs for any reason. Trending was generally effective in monitoring equipment performance. Site management was actively involved in the CAP and focused appropriate attention on significant plant issues. | ||
The inspectors identified one performance deficiency associated with the | The inspectors identified one performance deficiency associated with the licensees problem identification. This issue was screened in accordance with Inspection Manual Chapter 0612, Issue Screening, and was determined to be of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy. | ||
* Aging Management Review Report AMR064M, Carbon Steel, Fuel Oil, Buried stated that galvanic corrosion was not detrimental at Plant Hatch because contact between carbon steel and stainless steel did not exist. Contrary to the report, inspectors identified portions of the vent line for the diesel fuel oil storage tank that contained carbon steel to stainless steel connections. The failure to identify galvanic corrosion as a plausible and detrimental aging effect for the diesel fuel oil storage tank vent lines was a performance deficiency. Once identified by the team, the licensee evaluated the buried connections and determined they had a low susceptibility to galvanic corrosion. Because of the low susceptibility, the inspectors determined the inaccuracy in the report had no safety impact and was therefore of minor significance. The licensee generated CR 10436787 to address this issue. | |||
Problem Prioritization and Evaluation Based on the review of CRs sampled by the inspectors during the onsite period, the inspectors concluded that problems were generally prioritized and evaluated in accordance with the licensees CAP procedures as described in the CR significance determination guidance in NMP-GM-002-GL03, Cause Analysis and Corrective Action Guidelines. Each CR was assigned a priority level at the CR screening meeting, and adequate consideration was given to system or component operability and associated plant risk. | |||
The inspectors determined that station personnel had conducted root cause and apparent cause analyses in compliance with the licensees CAP procedures and assigned cause determinations were appropriate, considering the significance of the issues being evaluated. A variety of formal causal-analysis techniques were used depending on the type and complexity of the issue consistent with procedure NMP-GM-002-GL03. | |||
Effectiveness of Corrective Actions | The inspectors identified one performance deficiency associated with the licensees prioritization and evaluation of issues. This issue was screened in accordance with Inspection Manual Chapter 0612, Issue Screening, and was determined to be of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy. | ||
* CR 10330502 was written following receipt of a Severity Level III NRC violation documented in NRC inspection report 05000321/2016011. Licensee procedure NMP-GM-002-001, Attachment 1 required that CRs for Severity Level III violations receive a priority of 1, which would require root cause analysis. Contrary to this requirement, the CR was assigned a lower priority of 3 and closed to actions and lower-tier analyses previously completed. The failure to assign the correct priority per NMP-GM-002-001 was a performance deficiency. Once identified by the team, the licensee obtained MRC approval to downgrade the CR from priority 1 to priority 3. The inspectors determined that this was a failure to implement a procedural requirement that had no safety impact and was therefore of minor significance. The licensee generated CR 10431489 to address this issue. | |||
Effectiveness of Corrective Actions Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the inspectors determined that overall, corrective actions were timely, commensurate with the safety significance of the issues, and effective, in that conditions adverse to quality were corrected and non-recurring. For one of the two significant conditions adverse to quality reviewed by the team, the corrective actions directly addressed the cause and effectively prevented recurrence in that a review of performance indicators, CRs, and effectiveness reviews demonstrated that the significant conditions adverse to quality had not recurred. Effectiveness reviews for corrective actions taken to preclude repetition were sufficient to ensure corrective actions were properly implemented and were effective. However, there was a self-revealed performance deficiency identified with one significant condition adverse to quality reviewed by the team documented below. | |||
====c. Findings==== | ====c. Findings==== | ||
=====Introduction:===== | =====Introduction:===== | ||
A Green self-revealing non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion XVI, | A Green self-revealing non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, was identified for the licensees failure to establish measures to assure that corrective action was taken to preclude repetition of a significant condition adverse to quality (SCAQ). Specifically, the licensee failed to implement corrective actions that would have increased the reliability of the intermediate range monitoring (IRM) system and prevent repetitive reactor scrams for similar reasons. | ||
=====Description:===== | =====Description:===== | ||
On April 20, 2017, with Unit 1 at approximately 1% rated thermal power, an automatic reactor scram occurred due to the | On April 20, 2017, with Unit 1 at approximately 1% rated thermal power, an automatic reactor scram occurred due to the A and B IRMs spiking upscale high simultaneously. The IRM system is capable of generating a trip signal that can be used to prevent fuel damage resulting from anticipated operational occurrences that occur while operating in the intermediate power range. The licensee determined that the cause of the event was due to degradation of the under-vessel connectors within the IRM instrument loop between the detector and the drywell penetration. Degraded cable shielding at jumper connections allowed electronic noise from control rod movement to affect the signal cables for the A and B IRMs. The induced noise caused a false reading which produced a scram signal. | ||
Two other similar events previously occurred. In 2011, Unit 2 was manually scrammed after having all IRMs declared inoperable in the same reactor core quadrant due to erratic signals/electronic noise. In 2009, with Unit 1 at 8% power, an automatic scram occurred because of electronic noise induced in IRM signal cables when the reactor mode switch was taken to RUN. The licensee classified each of the above described events as SCAQs requiring a root cause evaluation and corrective actions to preclude repetition (CAPRs) per Procedure NMP-GM-002-001, Corrective Action Program Instructions. | |||
Per Corrective Action Report 269621, Root Cause Determination Report, dated July 6, 2017, modifications intended to increase the reliability of the IRM system were not implemented in a timely manner. Actions from the two root cause reports associated with the above mentioned reactor scrams of 2009 and 2011, recommended changing the time delay on the upper range IRMs so that spurious spikes caused by electromagnetic interference (EMI) would not result in a spurious IRM instrument trip. | |||
This modification was proposed in 2009, as a CAPR, but was assigned a low risk ranking and subsequently voided. Then in 2012, the same modification proposal was presented to the Plant Health Committee (PHC) as a CAPR due to the EMI noise induced scram that occurred on Unit 2 in 2011. The PHC approved the modification and actions were placed on a short-term list (outside the CAP), however the design was never started or implemented. The inspectors concluded that the licensees processes did not ensure the CAPR was tracked to completion. | |||
Procedure changes were also made to the plant startup procedure following the 2011 scram, but this CAPR was subsequently weakened by other procedure additions and changes. The original CAPR action required performance of Characterization testing during each mid-cycle outage to detect degraded conditions with IRM cables prior to resuming power operations. The procedure and root cause report were later revised, in accordance with approved plant processes, to reduce the frequency of the testing to every second mid-cycle outage. This frequency reduction was based on a trend of satisfactory results. Subsequent procedure changes, however, were made in 2014, 2015, 2016, and 2017, without revising the root cause report or CAPR. These changes allowed an engineering evaluation in place of performing the Characterization testing. | |||
As a result, Unit 1 went through four mid-cycle outages without executing the intended CAPR action. Because the testing was not performed and the engineering evaluations did not recognize the existence of degraded conditions, the plant was restarted with the IRMs in a degraded state. | |||
Inspectors identified that a contributing factor to the event was that an effectiveness review had not been completed. A review was scheduled to be completed in June 2016 to verify the effectiveness of the 2011 root cause actions. This review was deferred from June 2016 to October 2016, and then from October 2016 to October 2018. Licensee procedure NMP-GM-002-002 allowed reviews to be extended when the associated outstanding corrective actions were extended with proper management approval. In this case, the outstanding corrective actions had not received an extension or management approval since they were not being tracked in the CAP with due dates. The effectiveness review extension request process should have identified the lack of corrective action. | |||
=====Analysis:===== | =====Analysis:===== | ||
The failure to ensure corrective actions were taken for a SCAQ to preclude repetition of reactor scrams due to IRM spiking caused by external electronic noise was a performance deficiency. This performance deficiency is more-than-minor because it is associated with the equipment performance attribute of the Initiating Events Cornerstone and adversely affected the cornerstone objective because it resulted in a reactor scram, which upsets plant stability and challenges critical safety functions during shutdown as well as power operations. Using Inspection Manual Chapter 0609 Appendix A, the inspectors determined that this finding is of very low safety significance (Green) because it did not involve the loss of mitigation equipment per Exhibit 1.B | The failure to ensure corrective actions were taken for a SCAQ to preclude repetition of reactor scrams due to IRM spiking caused by external electronic noise was a performance deficiency. This performance deficiency is more-than-minor because it is associated with the equipment performance attribute of the Initiating Events Cornerstone and adversely affected the cornerstone objective because it resulted in a reactor scram, which upsets plant stability and challenges critical safety functions during shutdown as well as power operations. Using Inspection Manual Chapter 0609 Appendix A, the inspectors determined that this finding is of very low safety significance (Green) because it did not involve the loss of mitigation equipment per Exhibit 1.B Transient Initiators. | ||
The inspectors determined that the finding had a cross-cutting aspect of Conservative Bias (H.14) within the cross-cutting area of Human Performance because the licensee failed to use decision-making practices that emphasized prudent choices over those that were simply allowable when the decision was made to proceed with the plant startup rather than conduct IRM system/cable Characterization testing. Additionally, the decision to extend an effectiveness review created a missed opportunity to identify problems with corrective action implementation. | |||
=====Enforcement:===== | =====Enforcement:===== | ||
10 CFR Part 50, Appendix B, Criterion XVI, | 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that for SCAQs, the licensee establish measures to assure that corrective action is taken to preclude repetition. Contrary to the above, from 2009, to April 20, 2017, the licensee failed to establish measures to ensure that corrective action was taken for a SCAQ to preclude repetition. Specifically, the licensee failed to implement corrective actions to address a SCAQ and preclude repetition of plant scrams due to electronic noise affecting IRMs. As an immediate corrective action, the licensee performed Characterization testing and corrected degraded conditions with the IRM system cabling and connections. The licensee entered this issue into their CAP as CR 10356172. | ||
Because the finding is of very low safety significance (Green) and has been entered into the licensees CAP, this violation is being treated as a NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. (NCV 05000321/2017009-01, Failure to Implement Corrective Actions to Preclude Repetition of Reactor Scrams Due to IRM Spiking). | |||
===2. Assessment of the Use of Operating Experience=== | |||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors examined the | The inspectors examined the licensees use of industry OE to assess the effectiveness of how external and internal operating experience data was handled at the plant. In addition, the inspectors selected OE documents (e.g., NRC generic communications, 10 CFR Part 21 reports, licensee event reports, vendor notifications, and plant internal OE items, etc.) which had been issued since August 2015, to verify whether the licensee had appropriately evaluated each notification for applicability to the Hatch Nuclear Plant, and whether issues identified through these reviews were entered into the CAP. | ||
Documents reviewed are listed in the Attachment. | |||
b. Assessment | b. Assessment Based on a review of selected documentation related to OE issues, the inspectors determined that the licensee was generally effective in screening OE for applicability to the plant. Industry OE was evaluated at either the corporate or plant level depending on the source and type of the document. Relevant information was then forwarded to the applicable department for further action or informational purposes. OE issues requiring action were entered into the CAP for tracking and closure. In addition, OE was included in all apparent cause and root cause evaluations in accordance with licensee procedure NMP-GM-008-GL01, Guideline for Searching for Relevant OE. | ||
====c. Findings==== | ====c. Findings==== | ||
No findings were identified. 3. Assessment of Self-Assessments and Audits | No findings were identified. | ||
===3. Assessment of Self-Assessments and Audits=== | |||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
The inspectors reviewed audit reports and self-assessment reports, including those which focused on problem identification and resolution, to assess the thoroughness and self-criticism of the licensee's audits and self-assessments, and to verify that problems identified through those activities were appropriately prioritized and entered into the CAP for resolution in accordance with licensee procedure NMP-GM-003, Self-Assessment and Benchmark Procedure and NOS-104, Audit Planning and Scheduling. | The inspectors reviewed audit reports and self-assessment reports, including those which focused on problem identification and resolution, to assess the thoroughness and self-criticism of the licensee's audits and self-assessments, and to verify that problems identified through those activities were appropriately prioritized and entered into the CAP for resolution in accordance with licensee procedure NMP-GM-003, Self-Assessment and Benchmark Procedure and NOS-104, Audit Planning and Scheduling. | ||
b. Assessment | b. Assessment The inspectors determined that the scopes of assessments and audits were adequate. | ||
Self-assessments and audits were generally detailed and critical, as evidenced by findings consistent with the inspectors independent review. The inspectors verified that CRs were created to document areas for improvement and findings resulting from the self-assessments and audits, and verified that actions had been completed consistent with those recommendations. Generally, the licensee performed evaluations that were technically accurate. | |||
====c. Findings==== | ====c. Findings==== | ||
No findings were identified. 4. Assessment of Safety-Conscious Work Environment | No findings were identified. | ||
===4. Assessment of Safety-Conscious Work Environment=== | |||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
During the course of the inspection, the inspectors assessed the | During the course of the inspection, the inspectors assessed the stations safety-conscious work environment (SCWE) through review of the stations Employee Concerns Program (ECP) and interviews with various departmental personnel. The inspectors reviewed a sample of ECP issues to verify that concerns were being properly reviewed and identified deficiencies were being resolved and entered into the CAP when appropriate. | ||
b. Assessment Based on the interviews conducted and the CRs reviewed, the inspectors determined that licensee management emphasized the need for all employees to identify and report problems using the appropriate methods established within the administrative programs, including the CAP and ECP. These methods were readily accessible to all employees. | |||
Based on discussions conducted with a sample of plant employees from various departments, the inspectors determined that employees felt free to raise issues, and that management encouraged employees to place issues into the CAP for resolution. The inspectors did not identify any reluctance on the part of the licensee staff to report safety concerns. | |||
====c. Findings==== | ====c. Findings==== | ||
No findings were identified. | No findings were identified. {{a|4OA3}} | ||
{{a|4OA3}} | |||
==4OA3 Follow-up of Events and Notices of Enforcement Discretion== | ==4OA3 Follow-up of Events and Notices of Enforcement Discretion== | ||
{{IP sample|IP=IP 71153}} | {{IP sample|IP=IP 71153}} | ||
===.1 (CLOSED) LER 05000321/2017-005-00 Automatic Scram Due to Intermediate Range Monitors Spiking Upscale | ===.1 (CLOSED) LER 05000321/2017-005-00 Automatic Scram Due to Intermediate Range=== | ||
Monitors Spiking Upscale | |||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
This Licensee Event Report (LER) was associated with the automatic reactor scram that occurred with Unit 1 at approximately 1% rated thermal power on April 20, 2017. The inspectors reviewed the root cause report and discussed the issue with members of the plant staff. The cause of the scram was attributed to IRM signal cable connectors being in a degraded condition and susceptible to external electronic noise. This condition was documented in the | This Licensee Event Report (LER) was associated with the automatic reactor scram that occurred with Unit 1 at approximately 1% rated thermal power on April 20, 2017. The inspectors reviewed the root cause report and discussed the issue with members of the plant staff. The cause of the scram was attributed to IRM signal cable connectors being in a degraded condition and susceptible to external electronic noise. This condition was documented in the licensees CAP as CR 10356172. The inspectors reviewed the CR, other associated CAP documents, and the licensees corrective actions. | ||
====b. Findings==== | ====b. Findings==== | ||
One finding was identified. The enforcement aspects of this issue are discussed in Section 4OA2.1 of this report. | One finding was identified. The enforcement aspects of this issue are discussed in Section 4OA2.1 of this report. | ||
{{a|4OA6}} | {{a|4OA6}} | ||
==4OA6 Exit== | ==4OA6 Exit== | ||
===Exit Meeting Summary=== | |||
On December 7, 2017, the inspectors presented the inspection results to | |||
On December 7, 2017, the inspectors presented the inspection results to Mr. David Vineyard, Vice President and other members of the site staff. The inspectors confirmed that proprietary information was not provided or examined during the inspection. | |||
ATTACHMENT: | |||
=SUPPLEMENTAL INFORMATION= | =SUPPLEMENTAL INFORMATION= | ||
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===Licensee personnel=== | ===Licensee personnel=== | ||
: [[contact::L. Capeles]], Maintenance Engineer | : [[contact::L. Capeles]], Maintenance Engineer | ||
: [[contact::J. Crumpton]], Radiation Protection Supervisor | : [[contact::J. Crumpton]], Radiation Protection Supervisor | ||
: [[contact::B. Edkin]], System Engineer | : [[contact::B. Edkin]], System Engineer | ||
: [[contact::A. Elliott]], System Engineer | : [[contact::A. Elliott]], System Engineer | ||
: [[contact::D. Negron]], System & Program Engineer | : [[contact::D. Negron]], System & Program Engineer | ||
: [[contact::D. Gilbert]], Chemistry Supervisor | : [[contact::D. Gilbert]], Chemistry Supervisor | ||
: [[contact::J. Harley]], Senior Radiation Protection Technician | : [[contact::J. Harley]], Senior Radiation Protection Technician | ||
: [[contact::K. Johnson]], Senior Chemistry Technician | : [[contact::K. Johnson]], Senior Chemistry Technician | ||
: [[contact::D. Moore]], Emergency Preparedness Specialist | : [[contact::D. Moore]], Emergency Preparedness Specialist | ||
: [[contact::N. Ramos]], Engineer | : [[contact::N. Ramos]], Engineer | ||
: [[contact::R. Reddick]], Emergency Preparedness Supervisor | : [[contact::R. Reddick]], Emergency Preparedness Supervisor | ||
: [[contact::J. Reddy]], Mechanical Systems Supervisor | : [[contact::J. Reddy]], Mechanical Systems Supervisor | ||
: [[contact::J. Bailey]], Licensing Engineer | : [[contact::J. Bailey]], Licensing Engineer | ||
: [[contact::R. Outler]], PI Manager | : [[contact::R. Outler]], PI Manager | ||
: [[contact::J. Collins]], Regulatory Affairs Manager | : [[contact::J. Collins]], Regulatory Affairs Manager | ||
: [[contact::B. Coleman]], Causal Analyst | : [[contact::B. Coleman]], Causal Analyst | ||
===NRC personnel=== | ===NRC personnel=== | ||
: [[contact::D. Retterer]], Resident Inspector | : [[contact::D. Retterer]], Resident Inspector | ||
==LIST OF REPORT ITEMS== | ==LIST OF REPORT ITEMS== | ||
===Opened and Closed=== | ===Opened and Closed=== | ||
: 05000321/2017009-01 NCV Failure to Implement Corrective Actions to Preclude Repetition of Reactor Scrams Due to IRM Spiking (Section 4OA2.1) | : 05000321/2017009-01 NCV Failure to Implement Corrective Actions to Preclude Repetition of Reactor Scrams Due to IRM Spiking (Section 4OA2.1) | ||
===Closed=== | ===Closed=== | ||
: 05000321/2017-005-00 LER Automatic Scram Due to Intermediate Range Monitors Spiking Upscale (Section 4OA3.1) | |||
==LIST OF DOCUMENTS REVIEWED== | ==LIST OF DOCUMENTS REVIEWED== | ||
}} | }} |
Latest revision as of 05:25, 19 December 2019
ML18022A032 | |
Person / Time | |
---|---|
Site: | Hatch ![]() |
Issue date: | 01/19/2018 |
From: | Alan Blamey NRC/RGN-II/DRP/RPB2 |
To: | Vineyard D Southern Nuclear Operating Co |
References | |
IR 2017009 | |
Download: ML18022A032 (18) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION ary 19, 2018
SUBJECT:
EDWIN I. HATCH NUCLEAR PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000321/2017009 AND 05000366/2017009
Dear Mr. Vineyard:
On December 7, 2017, the U. S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution biennial inspection at your Hatch Nuclear Plant Units 1 and 2 and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the plants corrective action program and the plants implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the plant was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the plants processes for use of industry and NRC operating experience information and the effectiveness of the plants audits and self-assessments. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the plants programs to establish and maintain a safety-conscious work environment, and interviewed plant personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
NRC inspectors documented one finding of very low safety significance (Green) in this report which involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy. If you contest the violation or the significance of the violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Hatch Nuclear Plant.
If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement 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 Regional Administrator, Region II; and the NRC resident inspector at the 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Alan Blamey, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket No. 50-321, 50-366 License No. DPR-57 and NPF-5 Enclosure:
IR 05000321/2017009 and 05000366/2017009 w/Attachment: Supplemental Information Distribution via ListServ
ML18022A032 OFFICE RII:DRP RII:DRP RII:DRS RII:DRP RII:DCI RII:DRP NAME ARuh NStaples SSanchez GCroon CCheung ABlamey DATE 1/19/2018 1/17/2018 1/19/2018 1/17/2018 1/17/2018 1/19/2018
U.S. NUCLEAR REGULATORY COMMISSION
REGION II
Docket Nos.: 50-321, 50-366 License Nos.: DPR-57 and NPF-5 Report No.: 05000321/2017009 and 05000366/2017009 Licensee: Southern Nuclear Operating Company, Inc.
Facility: Edwin I. Hatch Nuclear Plant Location: Baxley, GA Dates: November 13-17, 2017 December 4-7, 2017 Inspectors: A. Ruh, Senior Resident Inspector, Acting C. Cheung, Construction Inspector G. Croon, Senior Resident Inspector S. Sanchez, Senior Emergency Preparedness Inspector Approved by: Alan Blamey, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure
SUMMARY
IR 05000321/2017009 and 05000366/2017009; 11/13/2017 - 12/7/2017; Hatch Nuclear Plant,
Units 1 and 2; Biennial Inspection of the Problem Identification and Resolution Program.
The inspection was conducted by two senior resident inspectors, one senior emergency preparedness inspector, and a construction inspector. One Green NCV was identified. 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 dated April 29, 2015. Cross-cutting aspects are determined using IMC 0310, Aspects Within Cross-Cutting Areas dated December 4, 2014.
All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated November 1, 2016. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,
Revision 6. Documents reviewed by the inspectors which are not identified in the Report Details are identified in the List of Documents Reviewed section of the Attachment.
Identification and Resolution of Problems The inspectors concluded that, in general, problems were properly identified, evaluated, prioritized, and corrected. The licensee was effective at identifying problems and entering them into the corrective action program (CAP) for resolution, as evidenced by the relatively few number of deficiencies identified by external organizations (including the NRC) that had not been previously identified by the licensee, during the review period. Generally, prioritization and evaluation of issues were adequate, formal root cause evaluations for significant problems were adequate, and corrective actions specified for problems were acceptable. Overall, corrective actions developed and implemented for issues were generally effective and implemented in a timely manner.
The inspectors determined that overall, audits and self-assessments were adequate in identifying deficiencies and areas for improvement in the CAP, and appropriate corrective actions were developed to address the issues identified. Operating experience usage was found to be generally acceptable and integrated into the licensees processes for performing and managing work, and plant operations.
Based on discussions and interviews conducted with plant employees from various departments, the inspectors determined that personnel at the site felt free to raise safety concerns to management and use the CAP to resolve those concerns.
NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
- Green: A self-revealing non-cited violation (NCV) of 10 CFR Part 50, Appendix B,
Criterion XVI, Corrective Action, was identified for the licensees failure to establish measures to assure that corrective action was taken to preclude repetition of a significant condition adverse to quality (SCAQ). Specifically, the licensee failed to implement corrective actions that would have increased the reliability of the intermediate range monitoring (IRM) system and prevent repetitive reactor scrams for similar reasons.
The licensee entered this issue in the CAP as CR 10356172.
The failure to ensure corrective actions were taken for a SCAQ to preclude repetition of reactor scrams due to IRM spiking caused by external electronic noise was a performance deficiency. This performance deficiency is more-than-minor because it is associated with the equipment performance attribute of the Initiating Events Cornerstone and adversely affected the cornerstone objective because it resulted in a reactor scram, which upsets plant stability and challenges critical safety functions during shutdown as well as power operations. Using Inspection Manual Chapter 0609 Appendix A, the inspectors determined that this finding is of very low safety significance (Green) because it did not involve the loss of mitigation equipment per Exhibit 1.B Transient Initiators.
The inspectors determined that the finding had a cross-cutting aspect of Conservative Bias (H.14) within the cross-cutting area of Human Performance because the licensee failed to use decision making-practices that emphasize prudent choices over those that are simply allowable.
REPORT DETAILS
OTHER ACTIVITIES
4OA2 Problem Identification and Resolution
.1 Assessment of the Corrective Action Program
a. Inspection Scope
The inspectors reviewed the licensees Corrective Action Program (CAP) procedures which described the administrative process for initiating and resolving problems primarily through the use of condition reports (CRs). To verify that problems were being properly identified, appropriately characterized, and entered into the CAP, the inspectors reviewed CRs that had been issued between December 2015 and October 2017, including a detailed review of selected CRs associated with the following risk-significant systems: Plant Service Water (PSW), Residual Heat Removal (RHR & RHRSW), and Emergency Diesel Generators (EDGs). Where possible, the inspectors independently verified that the corrective actions were implemented as intended. The inspectors also reviewed selected common causes and generic concerns associated with root cause evaluations (RCE) to determine if they had been appropriately addressed. To help ensure that samples were reviewed across all cornerstones of safety identified in the Reactor Oversight Process (ROP), the inspectors selected a representative number of CRs that were identified and assigned to the major plant departments, including operations, performance improvement, health physics, chemistry, emergency preparedness, and security. These CRs were reviewed to assess each departments threshold for identifying and documenting plant problems, thoroughness of evaluations, and adequacy of corrective actions. The inspectors reviewed selected CRs, verified corrective actions were implemented, and attended meetings where CRs were evaluated for significance to determine whether the licensee was identifying, accurately characterizing, and entering problems into the CAP at an appropriate threshold.
The inspectors conducted plant walkdowns within the selected systems listed above and other plant areas to assess the material condition and to identify any deficiencies that had not been previously entered into the CAP. The inspectors reviewed CRs, maintenance history, CAs, completed work orders (WOs) for the systems, and reviewed associated system health reports. These reviews were performed to verify that problems were being properly identified, appropriately characterized, and entered into the CAP. Items reviewed generally covered a two-year period; however, in accordance with the inspection procedure, a five-year review was performed for selected systems for age-dependent issues.
Control room walkdowns were also performed to assess the main control room (MCR)deficiency list and to ascertain if deficiencies were entered into the CAP and tracked to resolution. Operator workarounds (OWA) and operator burden screenings were reviewed, and the inspectors verified compensatory measures for deficient equipment which were being implemented in the field.
The inspectors conducted a detailed review of selected CRs to assess the adequacy of the root cause and apparent cause evaluations of the problems identified. The inspectors reviewed these evaluations against the descriptions of the problem described in the CRs and the guidance in licensee procedure NMP-GM-002-001, Corrective Action Program Instructions.
The inspectors assessed if the licensee had adequately determined the cause(s) of identified problems, and had adequately addressed operability, reportability, common cause, generic concerns, extent-of-condition, and extent-of-cause. The review also assessed if the licensee had appropriately identified and prioritized corrective actions to prevent recurrence.
The inspectors reviewed selected industry operating experience (OE) items, including NRC generic communications, to verify that they had been appropriately evaluated for applicability and that issues identified through these reviews had been entered into the CAP.
The inspectors reviewed site trend reports, to determine if the licensee effectively trended identified issues and initiated appropriate corrective actions when adverse trends were identified.
The inspectors reviewed licensee audits and self-assessments, including those which focused on problem identification and resolution programs and processes, to verify that findings were entered into the CAP and to verify that these audits and assessments were consistent with the NRCs assessment of the licensees CAP. The inspectors attended various plant meetings to observe management oversight functions of the corrective action process. These included Performance Improvement Review Meetings and Management Review Committee (MRC) meetings.
Documents reviewed are listed in the Attachment.
b. Assessment Problem Identification The inspectors determined that the licensee was generally effective in identifying problems and entering them into the CAP and there was an appropriately low threshold for entering issues into the CAP. This conclusion was based on a review of the requirements for initiating CRs as described in licensee procedure NMP-GM-002-001, Corrective Action Program Instructions and managements expectation that employees were encouraged to initiate CRs for any reason. Trending was generally effective in monitoring equipment performance. Site management was actively involved in the CAP and focused appropriate attention on significant plant issues.
The inspectors identified one performance deficiency associated with the licensees problem identification. This issue was screened in accordance with Inspection Manual Chapter 0612, Issue Screening, and was determined to be of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy.
- Aging Management Review Report AMR064M, Carbon Steel, Fuel Oil, Buried stated that galvanic corrosion was not detrimental at Plant Hatch because contact between carbon steel and stainless steel did not exist. Contrary to the report, inspectors identified portions of the vent line for the diesel fuel oil storage tank that contained carbon steel to stainless steel connections. The failure to identify galvanic corrosion as a plausible and detrimental aging effect for the diesel fuel oil storage tank vent lines was a performance deficiency. Once identified by the team, the licensee evaluated the buried connections and determined they had a low susceptibility to galvanic corrosion. Because of the low susceptibility, the inspectors determined the inaccuracy in the report had no safety impact and was therefore of minor significance. The licensee generated CR 10436787 to address this issue.
Problem Prioritization and Evaluation Based on the review of CRs sampled by the inspectors during the onsite period, the inspectors concluded that problems were generally prioritized and evaluated in accordance with the licensees CAP procedures as described in the CR significance determination guidance in NMP-GM-002-GL03, Cause Analysis and Corrective Action Guidelines. Each CR was assigned a priority level at the CR screening meeting, and adequate consideration was given to system or component operability and associated plant risk.
The inspectors determined that station personnel had conducted root cause and apparent cause analyses in compliance with the licensees CAP procedures and assigned cause determinations were appropriate, considering the significance of the issues being evaluated. A variety of formal causal-analysis techniques were used depending on the type and complexity of the issue consistent with procedure NMP-GM-002-GL03.
The inspectors identified one performance deficiency associated with the licensees prioritization and evaluation of issues. This issue was screened in accordance with Inspection Manual Chapter 0612, Issue Screening, and was determined to be of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy.
- CR 10330502 was written following receipt of a Severity Level III NRC violation documented in NRC inspection report 05000321/2016011. Licensee procedure NMP-GM-002-001, Attachment 1 required that CRs for Severity Level III violations receive a priority of 1, which would require root cause analysis. Contrary to this requirement, the CR was assigned a lower priority of 3 and closed to actions and lower-tier analyses previously completed. The failure to assign the correct priority per NMP-GM-002-001 was a performance deficiency. Once identified by the team, the licensee obtained MRC approval to downgrade the CR from priority 1 to priority 3. The inspectors determined that this was a failure to implement a procedural requirement that had no safety impact and was therefore of minor significance. The licensee generated CR 10431489 to address this issue.
Effectiveness of Corrective Actions Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the inspectors determined that overall, corrective actions were timely, commensurate with the safety significance of the issues, and effective, in that conditions adverse to quality were corrected and non-recurring. For one of the two significant conditions adverse to quality reviewed by the team, the corrective actions directly addressed the cause and effectively prevented recurrence in that a review of performance indicators, CRs, and effectiveness reviews demonstrated that the significant conditions adverse to quality had not recurred. Effectiveness reviews for corrective actions taken to preclude repetition were sufficient to ensure corrective actions were properly implemented and were effective. However, there was a self-revealed performance deficiency identified with one significant condition adverse to quality reviewed by the team documented below.
c. Findings
Introduction:
A Green self-revealing non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, was identified for the licensees failure to establish measures to assure that corrective action was taken to preclude repetition of a significant condition adverse to quality (SCAQ). Specifically, the licensee failed to implement corrective actions that would have increased the reliability of the intermediate range monitoring (IRM) system and prevent repetitive reactor scrams for similar reasons.
Description:
On April 20, 2017, with Unit 1 at approximately 1% rated thermal power, an automatic reactor scram occurred due to the A and B IRMs spiking upscale high simultaneously. The IRM system is capable of generating a trip signal that can be used to prevent fuel damage resulting from anticipated operational occurrences that occur while operating in the intermediate power range. The licensee determined that the cause of the event was due to degradation of the under-vessel connectors within the IRM instrument loop between the detector and the drywell penetration. Degraded cable shielding at jumper connections allowed electronic noise from control rod movement to affect the signal cables for the A and B IRMs. The induced noise caused a false reading which produced a scram signal.
Two other similar events previously occurred. In 2011, Unit 2 was manually scrammed after having all IRMs declared inoperable in the same reactor core quadrant due to erratic signals/electronic noise. In 2009, with Unit 1 at 8% power, an automatic scram occurred because of electronic noise induced in IRM signal cables when the reactor mode switch was taken to RUN. The licensee classified each of the above described events as SCAQs requiring a root cause evaluation and corrective actions to preclude repetition (CAPRs) per Procedure NMP-GM-002-001, Corrective Action Program Instructions.
Per Corrective Action Report 269621, Root Cause Determination Report, dated July 6, 2017, modifications intended to increase the reliability of the IRM system were not implemented in a timely manner. Actions from the two root cause reports associated with the above mentioned reactor scrams of 2009 and 2011, recommended changing the time delay on the upper range IRMs so that spurious spikes caused by electromagnetic interference (EMI) would not result in a spurious IRM instrument trip.
This modification was proposed in 2009, as a CAPR, but was assigned a low risk ranking and subsequently voided. Then in 2012, the same modification proposal was presented to the Plant Health Committee (PHC) as a CAPR due to the EMI noise induced scram that occurred on Unit 2 in 2011. The PHC approved the modification and actions were placed on a short-term list (outside the CAP), however the design was never started or implemented. The inspectors concluded that the licensees processes did not ensure the CAPR was tracked to completion.
Procedure changes were also made to the plant startup procedure following the 2011 scram, but this CAPR was subsequently weakened by other procedure additions and changes. The original CAPR action required performance of Characterization testing during each mid-cycle outage to detect degraded conditions with IRM cables prior to resuming power operations. The procedure and root cause report were later revised, in accordance with approved plant processes, to reduce the frequency of the testing to every second mid-cycle outage. This frequency reduction was based on a trend of satisfactory results. Subsequent procedure changes, however, were made in 2014, 2015, 2016, and 2017, without revising the root cause report or CAPR. These changes allowed an engineering evaluation in place of performing the Characterization testing.
As a result, Unit 1 went through four mid-cycle outages without executing the intended CAPR action. Because the testing was not performed and the engineering evaluations did not recognize the existence of degraded conditions, the plant was restarted with the IRMs in a degraded state.
Inspectors identified that a contributing factor to the event was that an effectiveness review had not been completed. A review was scheduled to be completed in June 2016 to verify the effectiveness of the 2011 root cause actions. This review was deferred from June 2016 to October 2016, and then from October 2016 to October 2018. Licensee procedure NMP-GM-002-002 allowed reviews to be extended when the associated outstanding corrective actions were extended with proper management approval. In this case, the outstanding corrective actions had not received an extension or management approval since they were not being tracked in the CAP with due dates. The effectiveness review extension request process should have identified the lack of corrective action.
Analysis:
The failure to ensure corrective actions were taken for a SCAQ to preclude repetition of reactor scrams due to IRM spiking caused by external electronic noise was a performance deficiency. This performance deficiency is more-than-minor because it is associated with the equipment performance attribute of the Initiating Events Cornerstone and adversely affected the cornerstone objective because it resulted in a reactor scram, which upsets plant stability and challenges critical safety functions during shutdown as well as power operations. Using Inspection Manual Chapter 0609 Appendix A, the inspectors determined that this finding is of very low safety significance (Green) because it did not involve the loss of mitigation equipment per Exhibit 1.B Transient Initiators.
The inspectors determined that the finding had a cross-cutting aspect of Conservative Bias (H.14) within the cross-cutting area of Human Performance because the licensee failed to use decision-making practices that emphasized prudent choices over those that were simply allowable when the decision was made to proceed with the plant startup rather than conduct IRM system/cable Characterization testing. Additionally, the decision to extend an effectiveness review created a missed opportunity to identify problems with corrective action implementation.
Enforcement:
10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that for SCAQs, the licensee establish measures to assure that corrective action is taken to preclude repetition. Contrary to the above, from 2009, to April 20, 2017, the licensee failed to establish measures to ensure that corrective action was taken for a SCAQ to preclude repetition. Specifically, the licensee failed to implement corrective actions to address a SCAQ and preclude repetition of plant scrams due to electronic noise affecting IRMs. As an immediate corrective action, the licensee performed Characterization testing and corrected degraded conditions with the IRM system cabling and connections. The licensee entered this issue into their CAP as CR 10356172.
Because the finding is of very low safety significance (Green) and has been entered into the licensees CAP, this violation is being treated as a NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. (NCV 05000321/2017009-01, Failure to Implement Corrective Actions to Preclude Repetition of Reactor Scrams Due to IRM Spiking).
2. Assessment of the Use of Operating Experience
a. Inspection Scope
The inspectors examined the licensees use of industry OE to assess the effectiveness of how external and internal operating experience data was handled at the plant. In addition, the inspectors selected OE documents (e.g., NRC generic communications, 10 CFR Part 21 reports, licensee event reports, vendor notifications, and plant internal OE items, etc.) which had been issued since August 2015, to verify whether the licensee had appropriately evaluated each notification for applicability to the Hatch Nuclear Plant, and whether issues identified through these reviews were entered into the CAP.
Documents reviewed are listed in the Attachment.
b. Assessment Based on a review of selected documentation related to OE issues, the inspectors determined that the licensee was generally effective in screening OE for applicability to the plant. Industry OE was evaluated at either the corporate or plant level depending on the source and type of the document. Relevant information was then forwarded to the applicable department for further action or informational purposes. OE issues requiring action were entered into the CAP for tracking and closure. In addition, OE was included in all apparent cause and root cause evaluations in accordance with licensee procedure NMP-GM-008-GL01, Guideline for Searching for Relevant OE.
c. Findings
No findings were identified.
3. Assessment of Self-Assessments and Audits
a. Inspection Scope
The inspectors reviewed audit reports and self-assessment reports, including those which focused on problem identification and resolution, to assess the thoroughness and self-criticism of the licensee's audits and self-assessments, and to verify that problems identified through those activities were appropriately prioritized and entered into the CAP for resolution in accordance with licensee procedure NMP-GM-003, Self-Assessment and Benchmark Procedure and NOS-104, Audit Planning and Scheduling.
b. Assessment The inspectors determined that the scopes of assessments and audits were adequate.
Self-assessments and audits were generally detailed and critical, as evidenced by findings consistent with the inspectors independent review. The inspectors verified that CRs were created to document areas for improvement and findings resulting from the self-assessments and audits, and verified that actions had been completed consistent with those recommendations. Generally, the licensee performed evaluations that were technically accurate.
c. Findings
No findings were identified.
4. Assessment of Safety-Conscious Work Environment
a. Inspection Scope
During the course of the inspection, the inspectors assessed the stations safety-conscious work environment (SCWE) through review of the stations Employee Concerns Program (ECP) and interviews with various departmental personnel. The inspectors reviewed a sample of ECP issues to verify that concerns were being properly reviewed and identified deficiencies were being resolved and entered into the CAP when appropriate.
b. Assessment Based on the interviews conducted and the CRs reviewed, the inspectors determined that licensee management emphasized the need for all employees to identify and report problems using the appropriate methods established within the administrative programs, including the CAP and ECP. These methods were readily accessible to all employees.
Based on discussions conducted with a sample of plant employees from various departments, the inspectors determined that employees felt free to raise issues, and that management encouraged employees to place issues into the CAP for resolution. The inspectors did not identify any reluctance on the part of the licensee staff to report safety concerns.
c. Findings
No findings were identified.
4OA3 Follow-up of Events and Notices of Enforcement Discretion
.1 (CLOSED) LER 05000321/2017-005-00 Automatic Scram Due to Intermediate Range
Monitors Spiking Upscale
a. Inspection Scope
This Licensee Event Report (LER) was associated with the automatic reactor scram that occurred with Unit 1 at approximately 1% rated thermal power on April 20, 2017. The inspectors reviewed the root cause report and discussed the issue with members of the plant staff. The cause of the scram was attributed to IRM signal cable connectors being in a degraded condition and susceptible to external electronic noise. This condition was documented in the licensees CAP as CR 10356172. The inspectors reviewed the CR, other associated CAP documents, and the licensees corrective actions.
b. Findings
One finding was identified. The enforcement aspects of this issue are discussed in Section 4OA2.1 of this report.
4OA6 Exit
Exit Meeting Summary
On December 7, 2017, the inspectors presented the inspection results to Mr. David Vineyard, Vice President and other members of the site staff. The inspectors confirmed that proprietary information was not provided or examined during the inspection.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- L. Capeles, Maintenance Engineer
- J. Crumpton, Radiation Protection Supervisor
- B. Edkin, System Engineer
- A. Elliott, System Engineer
- D. Negron, System & Program Engineer
- D. Gilbert, Chemistry Supervisor
- J. Harley, Senior Radiation Protection Technician
- K. Johnson, Senior Chemistry Technician
- D. Moore, Emergency Preparedness Specialist
- N. Ramos, Engineer
- R. Reddick, Emergency Preparedness Supervisor
- J. Reddy, Mechanical Systems Supervisor
- J. Bailey, Licensing Engineer
- J. Collins, Regulatory Affairs Manager
- B. Coleman, Causal Analyst
NRC personnel
- D. Retterer, Resident Inspector
LIST OF REPORT ITEMS
Opened and Closed
- 05000321/2017009-01 NCV Failure to Implement Corrective Actions to Preclude Repetition of Reactor Scrams Due to IRM Spiking (Section 4OA2.1)
Closed
- 05000321/2017-005-00 LER Automatic Scram Due to Intermediate Range Monitors Spiking Upscale (Section 4OA3.1)