IR 05000321/2014003: Difference between revisions

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| issue date = 07/31/2014
| issue date = 07/31/2014
| title = IR 05000321-14-003; and 05000366-14-003, on April 1, 2014, Through June 30, 2014; Edwin I. Hatch, Units 1 and 2, Operability Determinations and Functionality Assessments
| title = IR 05000321-14-003; and 05000366-14-003, on April 1, 2014, Through June 30, 2014; Edwin I. Hatch, Units 1 and 2, Operability Determinations and Functionality Assessments
| author name = Ehrhardt F J
| author name = Ehrhardt F
| author affiliation = NRC/RGN-II/DRP/RPB2
| author affiliation = NRC/RGN-II/DRP/RPB2
| addressee name = Vineyard D R
| addressee name = Vineyard D
| addressee affiliation = Southern Nuclear Operating Co, Inc
| addressee affiliation = Southern Nuclear Operating Co, Inc
| docket = 05000321, 05000366
| docket = 05000321, 05000366
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 July 31, 2014  
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION uly 31, 2014


Mr. David Vice President
==SUBJECT:==
EDWIN I. HATCH NUCLEAR PLANT - NRC INTEGRATED INSPECTION REPORT 05000321/2014003 AND 05000366/2014003


Southern Nuclear Operating Company, Inc. Edwin I. Hatch Nuclear Plant 11028 Hatch Parkway North Baxley, GA 31513
==Dear Mr. Vineyard:==
On June 30, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Edwin I. Hatch Nuclear Plant Units 1 and 2. On July 29, 2014, the NRC inspectors discussed the results of this inspection with Mr. Richard Spring and other members of your staff.


SUBJECT: EDWIN I. HATCH NUCLEAR PLANT - NRC INTEGRATED INSPECTION REPORT 05000321/2014003 AND 05000366/2014003
Inspectors documented the results of this inspection in the enclosed inspection report.


==Dear Mr. Vineyard:==
NRC inspectors documented one finding of very low safety significance (Green) in this report.
On June 30, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Edwin I. Hatch Nuclear Plant Units 1 and 2. On July 29, 2014, the NRC inspectors discussed the results of this inspection with Mr. Richard Spring and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.


NRC inspectors documented one finding of very low safety significance (Green) in this report. This finding involved a violation of NRC requirem ents. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.
This finding 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 significance of the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the Hatch plant.
If you contest the violation or significance of the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the Hatch plant.


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 Regional Administrator, Region II; and the NRC resident inspector at the Hatch plant. In accordance with Title 10 of the Code of Federal Regulations 2.390, "Public Inspections, Exemptions, Requests for Withholding," of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC's Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Managem ent System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
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 Regional Administrator, Region II; and the NRC resident inspector at the Hatch plant. In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
 
Sincerely,/RA/
Frank Ehrhardt, Chief Reactor Projects Branch 2


Division of Reactor Projects Docket Nos.: 50-321, 50-366 License Nos.: DPR-57 and NPF-5  
Sincerely,
/RA/
Frank Ehrhardt, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket Nos.: 50-321, 50-366 License Nos.: DPR-57 and NPF-5


===Enclosures:===
===Enclosures:===
Inspection Report 05000321/2014003, 05000366/2014003  
Inspection Report 05000321/2014003, 05000366/2014003 w/Attachment: Supplemental Information
 
===w/Attachment:===
Supplemental Information  
 
cc via ListServ distribution
 
_________________________ SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DRP RII:DRP RII:DRP RII:DRS RII:DRP RII:DRP SIGNATURE Via email Via email FJE /RA for/ Via email JGW /RA/ FJE /RA/ NAME DHardage EMorris DRetterer MCoursey JWorosilo FEhrhardt DATE 07/09/2014 07/03/2014 07/31/2014 07/08/2014 07/30/2014 07/31/2014 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO Letter to David from Frank Ehrhardt dated July 31, 2014
 
SUBJECT: EDWIN I. HATCH NUCLEAR PLANT - NRC INTEGRATED INSPECTION REPORT 05000321/2014003 AND 05000366/2014003
 
DISTRIBUTION
: D. Gamberoni, RII L. Douglas, RII OE Mail RIDSNRRDIRS
 
PUBLIC RidsNrrPMHatch Resource
 
Enclosure U. S. NUCLEAR REGULATORY COMMISSION
 
REGION II
 
Docket Nos.: 50-321, 50-366, 72-036
 
License Nos.: DPR-57 and NPF-5
 
Report Nos.: 05000321/2014003 and 05000366/2014003
 
Licensee: Southern Nuclear Operating Company, Inc.
 
Facility: Edwin I. Hatch Nuclear Plant
 
Location: Baxley, Georgia 31513
 
Dates: April 1 - June 30, 2014


Inspectors: D. Hardage, Senior Resident Inspector E. Morris, Senior Resident Inspector D. Retterer, Project Engineer (1R15) M. Coursey, Reactor Inspector (4OA5.2)
REGION II==
Docket Nos.: 50-321, 50-366, 72-036 License Nos.: DPR-57 and NPF-5 Report Nos.: 05000321/2014003 and 05000366/2014003 Licensee: Southern Nuclear Operating Company, Inc.


Approved by: Frank Ehrhardt, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure  
Facility: Edwin I. Hatch Nuclear Plant Location: Baxley, Georgia 31513 Dates: April 1 - June 30, 2014 Inspectors: D. Hardage, Senior Resident Inspector E. Morris, Senior Resident Inspector D. Retterer, Project Engineer (1R15)
M. Coursey, Reactor Inspector (4OA5.2)
Approved by: Frank Ehrhardt, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure


=SUMMARY OF FINDINGS=
=SUMMARY OF FINDINGS=
IR 05000321/2014003; and 05000366/2014003, April 1, 2014, through June 30, 2014; Edwin I.
IR 05000321/2014003; and 05000366/2014003, April 1, 2014, through June 30, 2014; Edwin I.


Hatch, Units 1 and 2, Operability Determinations and Functionality Assessments  
Hatch, Units 1 and 2, Operability Determinations and Functionality Assessments The report covered a 3-month period of inspection by resident inspectors and regional inspectors. There was one NRC identified violation identified and documented in this report.
 
The report covered a 3-month period of inspection by resident inspectors and regional inspectors. There was one NRC identified violation identified and documented in this report.
 
The significance of inspection findings are indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SDP) dated June 2, 2011. The cross-cutting aspects are determined using IMC 0310, "Aspects within the Cross-Cutting Areas" dated December 19, 2013. All violations of NRC requirements are dispositioned in accordance with the NRC's


Enforcement Policy dated January 28, 2013. The NRC's program for overseeing the safe operations of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 5.
The significance of inspection findings are indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609,
Significance Determination Process (SDP) dated June 2, 2011. The cross-cutting aspects are determined using IMC 0310, Aspects within the Cross-Cutting Areas dated December 19, 2013. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated January 28, 2013. The NRCs program for overseeing the safe operations of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.


===Cornerstone: Barrier Integrity===
===Cornerstone: Barrier Integrity===
: '''Green.'''
: '''Green.'''
The inspectors identified a Green non-cited violation of 10 CFR 50, Appendix B, Criterion V, "Procedures, Instructions, and Drawings," for the licensee's failure to prove operability following a failure of a surveillance test as required by Hatch procedure 90AC-OAM-001-0, "Test and Surveillance Control," Ver. 1.0, on May 12, 2014. To restore compliance, the licensee isolated the refueling floor dampers and re-performed Surveillance Requirement 3.6.4.1.3 with satisfactory results later that day on May 12, 2014. This violation was entered into the licensee's corrective action program as condition report (CR)  
The inspectors identified a Green non-cited violation of 10 CFR 50, Appendix B,
 
Criterion V, Procedures, Instructions, and Drawings, for the licensees failure to prove operability following a failure of a surveillance test as required by Hatch procedure 90AC-OAM-001-0, Test and Surveillance Control, Ver. 1.0, on May 12, 2014. To restore compliance, the licensee isolated the refueling floor dampers and re-performed Surveillance Requirement 3.6.4.1.3 with satisfactory results later that day on May 12, 2014. This violation was entered into the licensees corrective action program as condition report (CR)819563.
819563. Failure to prove operability following failure of a surveillance test as required by Hatch procedure 90AC-OAM-001-0, "Test and Surveillance Control," Ver. 1.0, on May 12, 2014, was a performance deficiency. The performance deficiency affected the barrier integrity cornerstone and was more-than-minor because, if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, declaring equipment operable following a failed surveillance test would have the potential for the facility to operate outside of technical specification requirements. The inspectors screened this finding using IMC 0609, Appendix A, "The Significant Determination Process (SDP) For Findings At-Power", dated June 19, 2012. The finding screened as Green per Section C of


Exhibit 3, "Barrier Integrity Screening Questions," because the finding only represented a degradation of the radiological barrier function provided by the standby gas treatment system. The inspectors determined the finding had a cross-cutting aspect of "training" in the human performance area, because the licensee did not ensure knowledge transfer of Surveillance Requirement 3.0.1 requirements to maintain a knowledgeable, technically competent workface and instill nuclear safety values. [H.9] (Section 1R15)
Failure to prove operability following failure of a surveillance test as required by Hatch procedure 90AC-OAM-001-0, Test and Surveillance Control, Ver. 1.0, on May 12, 2014, was a performance deficiency. The performance deficiency affected the barrier integrity cornerstone and was more-than-minor because, if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, declaring equipment operable following a failed surveillance test would have the potential for the facility to operate outside of technical specification requirements. The inspectors screened this finding using IMC 0609, Appendix A, The Significant Determination Process (SDP) For Findings At-Power, dated June 19, 2012. The finding screened as Green per Section C of Exhibit 3, Barrier Integrity Screening Questions, because the finding only represented a degradation of the radiological barrier function provided by the standby gas treatment system. The inspectors determined the finding had a cross-cutting aspect of training in the human performance area, because the licensee did not ensure knowledge transfer of Surveillance Requirement 3.0.1 requirements to maintain a knowledgeable, technically competent workface and instill nuclear safety values. [H.9] (Section 1R15)


=REPORT DETAILS=
=REPORT DETAILS=
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==REACTOR SAFETY==
==REACTOR SAFETY==
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity {{a|1R01}}
{{a|1R01}}
==1R01 Adverse Weather Protection==
==1R01 Adverse Weather Protection==
{{IP sample|IP=IP 71111.01}}
{{IP sample|IP=IP 71111.01}}
Line 116: Line 82:


====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified. {{a|1R04}}
{{a|1R04}}
==1R04 Equipment Alignment==
==1R04 Equipment Alignment==
{{IP sample|IP=IP 71111.04}}
{{IP sample|IP=IP 71111.04}}
Line 125: Line 90:


The inspectors selected the following three systems or trains to inspect:
The inspectors selected the following three systems or trains to inspect:
* Unit 2 "B" train of the plant service water system while "A" plant service water pump was out of service for maintenance, April 3
* Unit 2 B train of the plant service water system while A plant service water pump was out of service for maintenance, April 3
* Unit 2 emergency core cooling system room cooler 2T41-B002B while room cooler 2T41-B002A was out of service for maintenance, April 25
* Unit 2 emergency core cooling system room cooler 2T41-B002B while room cooler 2T41-B002A was out of service for maintenance, April 25
* Unit 1 and Unit 2 emergency diesel generators while the "1B" swing emergency diesel generator was out of service for maintenance, April 28
* Unit 1 and Unit 2 emergency diesel generators while the 1B swing emergency diesel generator was out of service for maintenance, April 28


====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified. {{a|1R05}}
{{a|1R05}}
==1R05 Fire Protection==
==1R05 Fire Protection==
{{IP sample|IP=IP 71111.05AQ}}
{{IP sample|IP=IP 71111.05AQ}}
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* passive fire protection features
* passive fire protection features
* compensatory measures and fire watches
* compensatory measures and fire watches
* issues related to fire protection contained in the licensee's corrective action program The inspectors toured the following five fire areas to assess material condition and operational status of fire protection equipment. Documents reviewed are listed in the attachment.
* issues related to fire protection contained in the licensees corrective action program The inspectors toured the following five fire areas to assess material condition and operational status of fire protection equipment. Documents reviewed are listed in the attachment.
* Unit 1 and 2 control room, fire zone 0024C
* Unit 1 and 2 control room, fire zone 0024C
* Unit 1 high pressure coolant injection pump room, fire zone 1205Z
* Unit 1 high pressure coolant injection pump room, fire zone 1205Z
Line 152: Line 116:


====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified. {{a|1R11}}
{{a|1R11}}
==1R11 Licensed Operator Requalification Program and Licensed Operator Performance==
==1R11 Licensed Operator Requalification Program and Licensed Operator Performance==
 
{{IP sample|IP=IP 71111.11}}
(71111.11)


====a. Inspection Scope====
====a. Inspection Scope====
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====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified. {{a|1R12}}
{{a|1R12}}
==1R12 Maintenance Effectiveness==
==1R12 Maintenance Effectiveness==
{{IP sample|IP=IP 71111.12}}
{{IP sample|IP=IP 71111.12}}


====a. Inspection Scope====
====a. Inspection Scope====
The inspectors assessed the licensee's treatment of the three issues listed below to verify the licensee appropriately addressed equipment problems within the scope of the maintenance rule (10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants"). The inspectors reviewed procedures and records to evaluate the licensee's identification, assessment, and characterization of the problems as well as their corrective actions for returning the equipment to a satisfactory condition. The inspectors also interviewed system engineers and the maintenance rule coordinator to assess the accuracy of performance deficiencies and extent of condition.
The inspectors assessed the licensees treatment of the three issues listed below to verify the licensee appropriately addressed equipment problems within the scope of the maintenance rule (10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants). The inspectors reviewed procedures and records to evaluate the licensees identification, assessment, and characterization of the problems as well as their corrective actions for returning the equipment to a satisfactory condition. The inspectors also interviewed system engineers and the maintenance rule coordinator to assess the accuracy of performance deficiencies and extent of condition.


Documents reviewed are listed in the Attachment.
Documents reviewed are listed in the Attachment.
* Unit 1, secondary containment following failure to meet procedural requirements for drawdown test
* Unit 1, secondary containment following failure to meet procedural requirements for drawdown test
* Emergency diesel generator "1B" unavailability when inhibited from aligning to Unit 2 during maintenance on "1C" Unit 1 emergency diesel generator
* Emergency diesel generator 1B unavailability when inhibited from aligning to Unit 2 during maintenance on 1C Unit 1 emergency diesel generator
* Unit 1 and Unit 2 control rod drive systems
* Unit 1 and Unit 2 control rod drive systems


====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified. {{a|1R13}}
{{a|1R13}}
==1R13 Maintenance Risk Assessments and Emergent Work Control==
==1R13 Maintenance Risk Assessments and Emergent Work Control==
{{IP sample|IP=IP 71111.13}}
{{IP sample|IP=IP 71111.13}}


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


Documents reviewed are listed in the Attachment.
Documents reviewed are listed in the Attachment.
* Unit 1 week of April 7 - April 11, including pan assembly replacement 1R24-S025 frame "3A", "1A" emergency diesel generator maintenance, battery charger 1R42-S026 maintenance
* Unit 1 week of April 7 - April 11, including pan assembly replacement 1R24-S025 frame 3A, 1A emergency diesel generator maintenance, battery charger 1R42-S026 maintenance
* Unit 1 and Unit 2 week of April 14 - April 18, including "1C" emergency diesel generator maintenance outage with "1B" emergency diesel generator inhibited from aligning to Unit 2
* Unit 1 and Unit 2 week of April 14 - April 18, including 1C emergency diesel generator maintenance outage with 1B emergency diesel generator inhibited from aligning to Unit 2
* Unit 1 and Unit 2 week of April 28 - April 25, including "1B" emergency diesel generator maintenance outage
* Unit 1 and Unit 2 week of April 28 - April 25, including 1B emergency diesel generator maintenance outage
* Unit 1 and Unit 2 week of May 5 - May 9, including scheduled maintenance for the "1A" residual heat removal pump and "2A" core spray pump
* Unit 1 and Unit 2 week of May 5 - May 9, including scheduled maintenance for the 1A residual heat removal pump and 2A core spray pump
* Unit 1 and Unit 2 week of June 2 - June 6, including scheduled maintenance on the "2A" residual heat removal pump motor and the "1A" turbine building chiller cooling tower
* Unit 1 and Unit 2 week of June 2 - June 6, including scheduled maintenance on the 2A residual heat removal pump motor and the 1A turbine building chiller cooling tower


====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified. {{a|1R15}}
{{a|1R15}}
==1R15 Operability Determinations and Functionality Assessments==
==1R15 Operability Determinations and Functionality Assessments==
{{IP sample|IP=IP 71111.15}}
{{IP sample|IP=IP 71111.15}}


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


Documents reviewed are listed in the Attachment.
Documents reviewed are listed in the Attachment.
* Emergency diesel generator "2C" air intake reinforcement screen missing, CR 798716
* Emergency diesel generator 2C air intake reinforcement screen missing, CR 798716
* Emergency diesel generator "2C" fuel oil leak, CR 802941
* Emergency diesel generator 2C fuel oil leak, CR 802941
* Unit 2 local power range monitor, 36-13A, failed upscale, CR 803902
* Unit 2 local power range monitor, 36-13A, failed upscale, CR 803902
* Secondary containment draw down surveillance test failure, CR 811574
* Secondary containment draw down surveillance test failure, CR 811574
* Unit 1 "C" residual heat removal pump failed to meet surveillance test acceptance criteria, CR 822066
* Unit 1 C residual heat removal pump failed to meet surveillance test acceptance criteria, CR 822066


====b. Findings====
====b. Findings====


=====Introduction:=====
=====Introduction:=====
The inspectors identified a Green non-cited violation of 10 CFR 50, Appendix B, Criterion V, "Procedures, Instructions, and Drawings," when the licensee failed to prove operability following a failure of a surveillance test as required by Hatch procedure 90AC-OAM-001-0, "Test and Surveillance Control," Ver. 1.0, on May 12, 2014.
The inspectors identified a Green non-cited violation of 10 CFR 50, Appendix B, Criterion V, Procedures, Instructions, and Drawings, when the licensee failed to prove operability following a failure of a surveillance test as required by Hatch procedure 90AC-OAM-001-0, Test and Surveillance Control, Ver. 1.0, on May 12, 2014.


=====Description:=====
=====Description:=====
On May 12, 2014, SNC performed Technical Specification 3.6.4.1 Surveillance Requirement 3.6.4.1.3 per SNC procedure 34SV-T22-001-0, "Secondary Containment Test," Ver. 15.1. This test verifies required standby gas treatment subsystems will draw down secondary containment to greater than or equal to 0.20 inch of vacuum water gauge in less than or equal to 120 seconds. The licensee was performing this test as a post maintenance test following maintenance on the Unit 2 refueling floor vent exhaust fans inboard isolation damper, 2T41-F003A. At 04:05 the control room logs documented that the secondary containment drawdown test did not meet acceptance criteria and Technical Specification Required Action Statement 3.6.4.1. Condition A was entered. The control room logs also documented that Required Action Statement 3.6.4.1 Condition A was exited at 05:57 because 2T41-F003A and 2T41-F023A, refueling floor vent exhaust fans discharge isolation dampers, had been deactivated/tagged out. SNC procedure NMP-AD-012, "Operability Determination and Functionality Assessments," Ver. 12.3, is the procedure for determining and documenting the operability of systems, structures, or components when a degraded or non-conforming condition is found or suspected to exist. NMP-AD-012, Section 2.0.13, states, "Technical specification operability considerations require that a system, structure, or component meet all surveillance requirements (as specified in Surveillance Requirement (SR) Applicability SR 3.0.1). A system, structure, or component that does not meet a surveillance requirement must be declared inoperable.Technical Specification Surveillance Requirement 3.0.1 states, "Failure to meet a surveillance, whether such failure is experienced during the performance of the surveillance or between performance of the surveillances, shall be failure to meet the limiting condition for operability.With secondary containment failing to meet Surveillance Requirement 3.6.4.1.3 as documented in the most recent surveillance test, 34SV-T22-001-0, NMP-AD-012 required that secondary containment be declared inoperable. Hatch procedure 90AC-OAM-001-0, "Test and Surveillance Control," Ver. 1.0, Section 5.2.10.4, contains actions following unsatisfactory surveillance testing results and states in part, "To prove operability, a surveillance test shall be run on the equipment, system, or component as required by the surveillance requirement. Upon satisfactory completion of the surveillance test, operability will be declared.However, SNC senior reactor operators declared secondary containment operable without obtaining satisfactory surveillance test results for secondary containment following a failed secondary containment surveillance test.
On May 12, 2014, SNC performed Technical Specification 3.6.4.1 Surveillance Requirement 3.6.4.1.3 per SNC procedure 34SV-T22-001-0, Secondary Containment Test, Ver. 15.1. This test verifies required standby gas treatment subsystems will draw down secondary containment to greater than or equal to 0.20 inch of vacuum water gauge in less than or equal to 120 seconds. The licensee was performing this test as a post maintenance test following maintenance on the Unit 2 refueling floor vent exhaust fans inboard isolation damper, 2T41-F003A. At 04:05 the control room logs documented that the secondary containment drawdown test did not meet acceptance criteria and Technical Specification Required Action Statement 3.6.4.1.
 
Condition A was entered. The control room logs also documented that Required Action Statement 3.6.4.1 Condition A was exited at 05:57 because 2T41-F003A and 2T41-F023A, refueling floor vent exhaust fans discharge isolation dampers, had been deactivated/tagged out. SNC procedure NMP-AD-012, Operability Determination and Functionality Assessments, Ver. 12.3, is the procedure for determining and documenting the operability of systems, structures, or components when a degraded or non-conforming condition is found or suspected to exist. NMP-AD-012, Section 2.0.13, states, Technical specification operability considerations require that a system, structure, or component meet all surveillance requirements (as specified in Surveillance Requirement (SR) Applicability SR 3.0.1). A system, structure, or component that does not meet a surveillance requirement must be declared inoperable. Technical Specification Surveillance Requirement 3.0.1 states, Failure to meet a surveillance, whether such failure is experienced during the performance of the surveillance or between performance of the surveillances, shall be failure to meet the limiting condition for operability. With secondary containment failing to meet Surveillance Requirement 3.6.4.1.3 as documented in the most recent surveillance test, 34SV-T22-001-0, NMP-AD-012 required that secondary containment be declared inoperable. Hatch procedure 90AC-OAM-001-0, Test and Surveillance Control, Ver. 1.0, Section 5.2.10.4, contains actions following unsatisfactory surveillance testing results and states in part, To prove operability, a surveillance test shall be run on the equipment, system, or component as required by the surveillance requirement. Upon satisfactory completion of the surveillance test, operability will be declared. However, SNC senior reactor operators declared secondary containment operable without obtaining satisfactory surveillance test results for secondary containment following a failed secondary containment surveillance test.


=====Analysis:=====
=====Analysis:=====
Failure to prove operability following failure of a surveillance test as required by Hatch procedure 90AC-OAM-001-0, "Test and Surveillance Control," Ver. 1.0, on May 12, 2014, was a performance deficiency. The performance deficiency affected the barrier integrity cornerstone and was more-than-minor because, if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, declaring equipment operable following a failed surveillance test would have the potential for the facility to operate outside of technical specification requirements. The inspectors screened this finding using IMC 0609, Appendix A, "The Significant Determination Process (SDP) For Findings At-Power", dated June 19, 2012. The finding  
Failure to prove operability following failure of a surveillance test as required by Hatch procedure 90AC-OAM-001-0, Test and Surveillance Control, Ver. 1.0, on May 12, 2014, was a performance deficiency. The performance deficiency affected the barrier integrity cornerstone and was more-than-minor because, if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, declaring equipment operable following a failed surveillance test would have the potential for the facility to operate outside of technical specification requirements. The inspectors screened this finding using IMC 0609, Appendix A, The Significant Determination Process (SDP) For Findings At-Power, dated June 19, 2012. The finding screened as Green per Section C of Exhibit 3, Barrier Integrity Screening Questions, because the finding only represented a degradation of the radiological barrier function provided by the standby gas treatment system. The inspectors determined the finding had a cross-cutting aspect of training in the human performance area, because the licensee did not ensure knowledge transfer of Surveillance Requirement 3.0.1 requirements to maintain a knowledgeable, technically competent workface and instill nuclear safety values. [H.9]


screened as Green per Section C of Exhibit 3, "Barrier Integrity Screening Questions," because the finding only represented a degradation of the radiological barrier function provided by the standby gas treatment system. The inspectors determined the finding had a cross-cutting aspect of "training" in the human performance area, because the licensee did not ensure knowledge transfer of Surveillance Requirement 3.0.1 requirements to maintain a knowledgeable, technically competent workface and instill nuclear safety values.  [H.9]
=====Enforcement:=====
Enforcement
10 CFR 50, Appendix B, Criterion V, Procedure, Drawings, and Instructions, requires in part that activities affecting quality shall be accomplished in accordance with documented instructions, procedures, or drawings, of a type appropriate to the circumstances. Hatch procedure NMP-AD-012, Operability Determination and Functionality Assessments, Ver. 12.3, Section 2.0.13 states in part, Technical specification operability considerations require that a system, structure, or component meet all surveillance requirements (as specified in Surveillance Requirement (SR) Applicability SR 3.0.1). A system, structure, or component that does not meet a surveillance requirement must be declared inoperable. In addition, Hatch procedure 90AC-OAM-001-0, Test and Surveillance Control, Ver. 1.0, Section 5.2.10.4, contains actions following unsatisfactory surveillance testing results and states in part, To prove operability, a surveillance test shall be run on the equipment, system, or component as required by the surveillance requirement. Upon satisfactory completion of the surveillance test, operability will be declared. Contrary to this requirement, on May 12, 2014, the licensee failed to accomplish an operability determination and failed to prove operability of secondary containment prior to declaring it operable. Specifically, senior reactor operators declared secondary containment operable after failing Surveillance Requirement 3.6.4.1.3 and did not prove operability by satisfactorily performing the surveillance test prior to declaring the secondary containment operable on May 12, 2014. To restore compliance, the licensee isolated the refueling floor dampers and re-performed Surveillance Requirement 3.6.4.1.3 with satisfactory results later that day on May 12, 2014. This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy. The violation was entered into the licensees corrective action program as CR 819563. (NCV 05000321, 366/2014003-01, Failure to Prove Operability Following the Failure of the Secondary Containment Surveillance Test)
10 CFR 50, Appendix B, Criterion V, "Procedure, Drawings, and Instructions," requires in part that activities affecting quality shall be accomplished in accordance with documented instructions, procedures, or drawings, of a type appropriate to the circumstances. Hatch procedure NMP-AD-012, "Operability Determination and Functionality Assessments," Ver. 12.3, Section 2.0.13 states in part, "Technical specification operability considerations require that a system, structure, or component meet all surveillance requirements (as specified in Surveillance Requirement (SR) Applicability SR 3.0.1). A system, structure, or component that does not meet a surveillance requirement must be declared inoperable.In addition, Hatch procedure 90AC-OAM-001-0, "Test and Surveillance Control," Ver. 1.0, Section 5.2.10.4, contains actions following unsatisfactory surveillance testing results and states in part, "To prove operability, a surveillance test shall be run on the equipment, system, or component as required by the surveillance requirement. Upon satisfactory completion of the surveillance test, operability will be declared.Contrary to this requirement, on May 12, 2014, the licensee failed to accomplish an operability determination and failed to prove operability of secondary containment prior to declaring it operable. Specifically, senior reactor operators declared secondary containment operable after failing Surveillance Requirement 3.6.4.1.3 and did not prove operability by satisfactorily performing the surveillance test prior to declaring the secondary containment operable on May 12, 2014. To restore compliance, the licensee isolated the refueling floor dampers and re-performed Surveillance Requirement 3.6.4.1.3 with satisfactory results later that day on May 12, 2014. This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy. The violation was entered into the licensee's corrective action program as CR 819563. (NCV 05000321, 366/2014003-01, "Failure to Prove Operability Following the Failure of the Secondary Containment Surveillance Test")
{{a|1R18}}
{{a|1R18}}
==1R18 Plant Modifications==
==1R18 Plant Modifications==
Line 246: Line 206:
====a. Inspection Scope====
====a. Inspection Scope====
The inspectors verified that the plant modification listed below did not affect the safety functions of important safety systems. The inspectors confirmed the modification did not degrade the design bases, licensing bases, and performance capability of risk significant structures, systems and components. The inspectors also verified modifications performed during plant configurations involving increased risk did not place the plant in an unsafe condition. Additionally, the inspectors evaluated whether system operability and availability, configuration control, post-installation test activities, and changes to documents, such as drawings, procedures, and operator training materials, complied with licensee standards and NRC requirements. In addition, the inspectors reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with modifications. Documents reviewed are listed in the Attachment.
The inspectors verified that the plant modification listed below did not affect the safety functions of important safety systems. The inspectors confirmed the modification did not degrade the design bases, licensing bases, and performance capability of risk significant structures, systems and components. The inspectors also verified modifications performed during plant configurations involving increased risk did not place the plant in an unsafe condition. Additionally, the inspectors evaluated whether system operability and availability, configuration control, post-installation test activities, and changes to documents, such as drawings, procedures, and operator training materials, complied with licensee standards and NRC requirements. In addition, the inspectors reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with modifications. Documents reviewed are listed in the Attachment.
* 34SO-R43-001-1, "Alignment of "1B" emergency diesel generator during "1A" or "1C" emergency diesel generator maintenance."
* 34SO-R43-001-1, Alignment of 1B emergency diesel generator during 1A or 1C emergency diesel generator maintenance.


====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified. {{a|1R19}}
{{a|1R19}}
==1R19 Post-Maintenance Testing==
==1R19 Post-Maintenance Testing==
{{IP sample|IP=IP 71111.19}}
{{IP sample|IP=IP 71111.19}}
Line 256: Line 215:
====a. Inspection Scope====
====a. Inspection Scope====
The inspectors either observed post-maintenance testing or reviewed the test results for the five maintenance activities listed below to verify the work performed was completed correctly and the test activities were adequate to verify system operability and functional capability.
The inspectors either observed post-maintenance testing or reviewed the test results for the five maintenance activities listed below to verify the work performed was completed correctly and the test activities were adequate to verify system operability and functional capability.
* Work order SNC556530, replace oil line on "1A" emergency diesel generator, April 9
* Work order SNC556530, replace oil line on 1A emergency diesel generator, April 9
* Work order SNC397626, post maintenance testing following "1C" emergency diesel generator maintenance outage, April 18
* Work order SNC397626, post maintenance testing following 1C emergency diesel generator maintenance outage, April 18
* Work order SNC375887, Unit 2 "A" residual heat removal pump seal cooler clean and inspect, May 5
* Work order SNC375887, Unit 2 A residual heat removal pump seal cooler clean and inspect, May 5
* Work order SNC375841, Unit 2 "A" core spray pump check valve 2E21-F003A inspection, May 9
* Work order SNC375841, Unit 2 A core spray pump check valve 2E21-F003A inspection, May 9
* Work order SNC574763, repair Unit 2 drywell "2B" hydrogen-oxygen analyzer,     May 21 The inspectors evaluated these activities for the following:
* Work order SNC574763, repair Unit 2 drywell 2B hydrogen-oxygen analyzer, May 21 The inspectors evaluated these activities for the following:
* Acceptance criteria were clear and demonstrated operational readiness.
* Acceptance criteria were clear and demonstrated operational readiness.
* Effects of testing on the plant were adequately addressed.
* Effects of testing on the plant were adequately addressed.
Line 271: Line 230:


====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified. {{a|1R22}}
{{a|1R22}}
==1R22 Surveillance Testing==
==1R22 Surveillance Testing==
{{IP sample|IP=IP 71111.22}}
{{IP sample|IP=IP 71111.22}}


====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed the six surveillance tests listed below and either observed the test or reviewed test results to verify testing adequately demonstrated equipment operability and met technical specification and licensee procedural requirements. The inspectors evaluated the test activities to assess for preconditioning of equipment, procedure adherence, and equipment alignment following completion of the surveillance. Additionally, the inspectors reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with surveillance testing. Documents reviewed are listed in the Attachment.
The inspectors reviewed the six surveillance tests listed below and either observed the test or reviewed test results to verify testing adequately demonstrated equipment operability and met technical specification and licensee procedural requirements. The inspectors evaluated the test activities to assess for preconditioning of equipment, procedure adherence, and equipment alignment following completion of the surveillance.
 
Additionally, the inspectors reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with surveillance testing. Documents reviewed are listed in the Attachment.


Routine Surveillance Tests
Routine Surveillance Tests
* 34SV-R43-001-1, "Diesel Generator 1A Monthly Test"
* 34SV-R43-001-1, Diesel Generator 1A Monthly Test
* 34SV-T48-002-2, "Suppression Chamber to Drywell Vacuum Breaker Operability and Containment Purge/Vent Valve Position Check"
* 34SV-T48-002-2, Suppression Chamber to Drywell Vacuum Breaker Operability and Containment Purge/Vent Valve Position Check
* 34SV-T22-001-0, "Secondary Containment Test"
* 34SV-T22-001-0, Secondary Containment Test
* 64CH-SAM-025-0, "Reactor Coolant Sampling and Analysis" In-Service Tests
* 64CH-SAM-025-0, Reactor Coolant Sampling and Analysis In-Service Tests
* 34SV-E21-001-2, "Core Spra y Pump Operability" ("2A")
* 34SV-E21-001-2, Core Spray Pump Operability (2A)
Reactor Coolant System Leak Detection
Reactor Coolant System Leak Detection
* 34SV-SUV-019-1, "Surveillance Checks"
* 34SV-SUV-019-1, Surveillance Checks


====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified.


===Cornerstone:===
===Cornerstone: Emergency Preparedness===
Emergency Preparedness
{{a|1EP6}}
{{a|1EP6}}
==1EP6 Drill Evaluation==
==1EP6 Drill Evaluation==
Line 300: Line 259:
The inspectors observed the emergency preparedness drill conducted on June 18, 2014.
The inspectors observed the emergency preparedness drill conducted on June 18, 2014.


The inspectors observed licensee activities in the simulator and/or technical support center to evaluate implementation of the emergency plan, including event classification, notification, and protective action recommendations. The inspectors evaluated the licensee's performance against criteria established in the licensee's procedures.
The inspectors observed licensee activities in the simulator and/or technical support center to evaluate implementation of the emergency plan, including event classification, notification, and protective action recommendations. The inspectors evaluated the licensees performance against criteria established in the licensees procedures.


Additionally, the inspectors attended the post-exercise critique to assess the licensee's effectiveness in identifying emergency preparedness weaknesses and verified the identified weaknesses were entered in the corrective action program. Documents reviewed are listed in the Attachment.
Additionally, the inspectors attended the post-exercise critique to assess the licensees effectiveness in identifying emergency preparedness weaknesses and verified the identified weaknesses were entered in the corrective action program. Documents reviewed are listed in the Attachment.


====b. Findings====
====b. Findings====
Line 313: Line 272:


====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed a sample of the performance indicator (PI) data, submitted by the licensee, for the Unit 1 and Unit 2 PIs listed below. The inspectors reviewed plant records compiled between April 2013 and March 2014 to verify the accuracy and completeness of the data reported for the station. The inspectors verified that the PI data complied with guidance contained in Nuclear Energy Institute 99-02, "Regulatory Assessment Performance Indicator Guideline," and licensee procedures. The inspectors verified the accuracy of reported data that were used to calculate the value of each PI. In addition, the inspectors reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with PI data. Documents reviewed are listed in the Attachment.
The inspectors reviewed a sample of the performance indicator (PI) data, submitted by the licensee, for the Unit 1 and Unit 2 PIs listed below. The inspectors reviewed plant records compiled between April 2013 and March 2014 to verify the accuracy and completeness of the data reported for the station. The inspectors verified that the PI data complied with guidance contained in Nuclear Energy Institute 99-02, Regulatory Assessment Performance Indicator Guideline, and licensee procedures. The inspectors verified the accuracy of reported data that were used to calculate the value of each PI.


===Cornerstone:===
In addition, the inspectors reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with PI data. Documents reviewed are listed in the Attachment.
Barrier Integrity
 
===Cornerstone: Barrier Integrity===
* reactor coolant system leak rate
* reactor coolant system leak rate
* reactor coolant system specific activity
* reactor coolant system specific activity


====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified. {{a|4OA2}}
{{a|4OA2}}
==4OA2 Problem Identification and Resolution==
==4OA2 Problem Identification and Resolution==
{{IP sample|IP=IP 71152}}
{{IP sample|IP=IP 71152}}
===.1 Routine Review===
===.1 Routine Review===


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


===.2 Semi-Annual Trend Review===
===.2 Semi-Annual Trend Review===


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


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


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


====b. Findings and Observations====
====b. Findings and Observations====
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}}
Line 350: Line 310:
====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified.
 
{{a|4OA5}}
{{a|4OA5}}
==4OA5 Other Activities==
==4OA5 Other Activities==


Line 357: Line 316:


====a. Inspection Scope====
====a. Inspection Scope====
The inspectors performed a walkdown of the onsite independent spent fuel storage installation (ISFSI) and monitored the activities associated with the dry fuel storage campaign completed on June 17. The inspectors reviewed changes made to the ISFSI programs and procedures, including associated 10 CFR 72.48, "Changes, Tests, and Experiments," screens and evaluations to verify that changes made were consistent with the license or certificate of compliance. The inspectors reviewed records to verify that the licensee recorded and maintained the location of each fuel assembly placed in the ISFSI. The inspectors also reviewed surveillance records to verify that daily surveillance requirements were performed as required by technical specifications. Documents reviewed are listed in the Attachment.
The inspectors performed a walkdown of the onsite independent spent fuel storage installation (ISFSI) and monitored the activities associated with the dry fuel storage campaign completed on June 17. The inspectors reviewed changes made to the ISFSI programs and procedures, including associated 10 CFR 72.48, Changes, Tests, and Experiments, screens and evaluations to verify that changes made were consistent with the license or certificate of compliance. The inspectors reviewed records to verify that the licensee recorded and maintained the location of each fuel assembly placed in the ISFSI. The inspectors also reviewed surveillance records to verify that daily surveillance requirements were performed as required by technical specifications. Documents reviewed are listed in the Attachment.


====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified.


===.2 (Closed) Temporary Instruction -2515/182 - Review of the Industry Initiative to Control Degradation of Underground Piping and Tanks===
===.2 (Closed) Temporary Instruction -2515/182 - Review of the Industry Initiative to Control===
 
Degradation of Underground Piping and Tanks


====a. Inspection Scope====
====a. Inspection Scope====
From April 14 - April 16, 2014, the inspectors conducted a review of records and procedures related to the licensee's program for buried pipe, underground pipe and tanks in accordance with Phase II of TI-2515/182. This review was done to confirm that the licensee's program contained attributes consistent with Sections 3.3.A and 3.3.B of NEI 09-14 and to confirm that these attributes were scheduled and/or completed by the NEI 09-14 Revision 3 deadlines. To determine if the program attribute was accomplished in a manner which reflected good or poor practices in program management, the inspectors interviewed licensee staff responsible for the buried pipe program and reviewed buried pipe program related activities.
From April 14 - April 16, 2014, the inspectors conducted a review of records and procedures related to the licensees program for buried pipe, underground pipe and tanks in accordance with Phase II of TI-2515/182. This review was done to confirm that the licensees program contained attributes consistent with Sections 3.3.A and 3.3.B of NEI 09-14 and to confirm that these attributes were scheduled and/or completed by the NEI 09-14 Revision 3 deadlines. To determine if the program attribute was accomplished in a manner which reflected good or poor practices in program management, the inspectors interviewed licensee staff responsible for the buried pipe program and reviewed buried pipe program related activities.
 
The licensee's buried piping and underground piping and tanks program was inspected in accordance with paragraph 03.02.a of the temporary instruction (TI) and it was confirmed that activities, which correspond to completion dates specified in the program which have passed since the Phase 1 inspection was conducted, have been completed.


Additionally, the licensee's buried piping and underground piping and tanks program was inspected in accordance with paragraph 03.02.b of the TI and responses to specific questions found in http://www.nrc.gov/reactors/operating/ops-experience/buried-pipe-ti-phase-2-insp-req-2011-11-16.pdf were submitted to the NRC headquarters staff.
The licensees buried piping and underground piping and tanks program was inspected in accordance with paragraph 03.02.a of the temporary instruction (TI) and it was confirmed that activities, which correspond to completion dates specified in the program which have passed since the Phase 1 inspection was conducted, have been completed.


Based upon the scope of the review described above, Phase II of TI-2515/182 was
Additionally, the licensees buried piping and underground piping and tanks program was inspected in accordance with paragraph 03.02.b of the TI and responses to specific questions found in http://www.nrc.gov/reactors/operating/ops-experience/buried-pipe-ti-phase-2-insp-req-2011-11-16.pdf were submitted to the NRC headquarters staff.


completed.
Based upon the scope of the review described above, Phase II of TI-2515/182 was completed.


====b. Findings====
====b. Findings====
No findings were identified  
No findings were identified {{a|4OA6}}
 
{{a|4OA6}}
==4OA6 Meetings, Including Exit==
==4OA6 Meetings, Including Exit==


On July 29, 2014, the resident inspectors presented the inspection results to Mr. Richard Spring and other members of the licensee's staff. The inspectors confirmed that proprietary information provided or examined during the inspection period was properly controlled.
On July 29, 2014, the resident inspectors presented the inspection results to Mr. Richard Spring and other members of the licensees staff. The inspectors confirmed that proprietary information provided or examined during the inspection period was properly controlled.


ATTACHMENT:
ATTACHMENT:  


=SUPPLEMENTAL INFORMATION=
=SUPPLEMENTAL INFORMATION=
Line 390: Line 347:


===Licensee personnel===
===Licensee personnel===
: [[contact::B. Anderson]], Health Physics Manager  
: [[contact::B. Anderson]], Health Physics Manager
: [[contact::G. Brinson]], Maintenance Director  
: [[contact::G. Brinson]], Maintenance Director
: [[contact::V. Coleman]], Chemistry Manager  
: [[contact::V. Coleman]], Chemistry Manager
: [[contact::A. Giancatarino]], Engineering Director  
: [[contact::A. Giancatarino]], Engineering Director
: [[contact::G. Johnson]], Site Regulatory Affair Manager  
: [[contact::G. Johnson]], Site Regulatory Affair Manager
: [[contact::D. Komm]], Operations Director  
: [[contact::D. Komm]], Operations Director
: [[contact::K. Long]], Work Management Director  
: [[contact::K. Long]], Work Management Director
: [[contact::R. Spring]], Plant Manager  
: [[contact::R. Spring]], Plant Manager
: [[contact::S. Tipps]], Principal Licensing Engineer  
: [[contact::S. Tipps]], Principal Licensing Engineer
: [[contact::M. Torrance]], Nuclear Oversight Manager  
: [[contact::M. Torrance]], Nuclear Oversight Manager
: [[contact::D. Vineyard]], Hatch Vice President  
: [[contact::D. Vineyard]], Hatch Vice President
: [[contact::A. Wheeler]], Site Projects Manager  
: [[contact::A. Wheeler]], Site Projects Manager


==LIST OF ITEMS==
==LIST OF ITEMS==
OPENED AND CLOSED
OPENED AND CLOSED


Closed 2515/182 TI Phase II - Review of the Industry Initiative to Control Degradation of Underground Piping and Tanks
===Closed===


(Section 4OA5.2)
2515/182                        TI  Phase II - Review of the Industry Initiative to Control Degradation of Underground Piping and Tanks (Section 4OA5.2)
Opened &  
Opened &  
===Closed===
===Closed===
: 05000321,366/2014003-01 NCV Failure to Prove Operability Following the Failure of the Secondary Containment Surveillance Test (Section  
: 05000321,366/2014003-01       NCV   Failure to Prove Operability Following the Failure of the Secondary Containment Surveillance Test (Section 1R15)
: 1R15)    


==LIST OF DOCUMENTS REVIEWED==
==LIST OF DOCUMENTS REVIEWED==
==Section 1R01: Adverse Weather==
===Procedures===
: 34AB-S11-001-0, "Operation with Degraded System Voltage," Ver. 4.0
: DI-OPS-87-0408, "Actions for GENCOMM Alerts," Ver. 1.1
: 34SO-N40-001-1, "Main Generator Operation," Ver. 17.1 
===Condition Reports===
: 478154,
: 677724,
: 694949,
: 694992, 696146
==Section 1R04: Equipment Alignment==
===Procedures===
: 34SO-P41-001-2, "Plant Service Water System," Ver. 26.4 
===Drawings===
: D11001, P. & I. D. for Service Water Piping at Intake Structure, Ver. 88.0 
===Condition Reports===
: 804907 
: Other Hatch Technical Requirements Manual
==Section 1R05: Fire Protection==
===Procedures===
: E.I. Hatch Fire Protection Fire Hazards Analysis 42FP-FPX-018-0, "Use, Control and Storage of Flammable/Combustible Ma terials," Ver. 1.2 34AB-X43-001-1, "Fire Procedure," Ver. 10.25
: 2SV-FPX-024-0, "Fire Hose Stations - Appendix B Areas," Ver. 3.2 
===Drawings===
: A-43965 sheet 48A/B, Unit 1 & 2 Pre-Fire Plan Control Room Control Bldg. Elevation 164'-0" A-43965 sheet 53A/B, Unit 1 Pre-Fire NE RHR & Core Spray Room Reactor Bldg. El. Below 130'-0" A-43965 sheet 55A/B, Unit 1 Pre-Fire Plan HPCI Pump Room Reactor Bldg. El. Below 130'-0" A-43965 sheet 58A/B, Unit 1 Pre-Fire Plan South CRD Area Reactor Bldg. Elevation 130'-0" A-43965 sheet 59A/B, Unit 1 Pre-Fire Plan North CRD Area Reactor Bldg. Elevation 130'-0" A-43965 sheet 47A/B, Unit 1& 2 Pre-Fire Plan LPSI Inverter Room, Control Bldg. Elevation 147'-0"
==Section 1R11: Licensed Operator Requalification==
: Drill Scenario:
: LR-SE-50413-22.2
: LT-SG-50406-17.1 
===Procedures===
: 34GO-OPS-005-1, "Power Changes," Ver. 27.1
: 34GO-OPS-065-1, "Control Rod Movement," Ver.14.0
: NMP-OS-007, "Conduct of Operations," Ver.10.0
: Attachment
==Section 1R12: Maintenance Effectiveness==
: Other System Health Report -T41 System - 1
st quarter 2014
: T41 Maintenance Rule Scoping Manual Documents
: T41 Maintenance Rule Performance Criteria System Health Report - R43 System
: R43 Maintenance Rule Scoping Manual Documents
: NMP-ES-002, "System Monitoring and Health Reporting," Ver. 17.0
: CAR 209179
: C11 Maintenance Rule Scoping Manual Documents
: C11 Maintenance Rule Performance Criteria System Health Report - C11 System
==Section 1R13: Maintenance Risk Assessments and Emergent Work Evaluation==
===Condition Reports===
: 638728,
: 685804,
: 700709,
: 766743,
: 772241,
: 801354
: Other Equipment Out of Service calculations 4/6/14 - 4/11/14
: Equipment Out of Service calculations 4/14/14 - 4/18/14
: Equipment Out of Service calculations 4/28/14 - 5/2/14 Equipment Out of Service calculations 5/5/14 - 5/9/14 Equipment Out of Service calculations 6/2/14 - 6/6/14
: Control room logs
==Section 1R15: Operability Evaluations==
===Procedures===
: NMP-AD-012, "Operability Determinations and Functional Assessments," Ver. 12.3 
===Work Orders===
: SNC566387, SNC568387
: Other Control room logs Updated final safety analysis report Unit 1 and Unit 2 
===Condition Report===
: 811577,
: 811574
: Corrective Action Report
: 210006, 210087,
==Section 1R18: Plant Modifications==
===Procedures===
: NMP-ES-054, "Temporary Modifications," Ver. 2.0 34SO-R43-001-1, "Diesel Generator Standby AC System," Ver. 26.0 
===Condition Reports===
: 2304 
: Attachment
==Section 1R19: Post Maintenance Testing==
===Work Orders===
: SNC556530, SNC564016, SNC375887 
===Procedures===
: 34SV-R43-001-1, "Diesel Generator 1A Monthly Test," Ver. 24.1
: 34SO-E11-010-1, "Residual Heat Removal System," Ver. 44.0 95IT-OTM-001-0, "Maintenance Work Order Functional Test Guideline," Rev. 5.4
: NMP-MA-014-001, "Post Maintenance Testing," Ver. 3.0
: 57SV-P33-001-2, "Containment Hydrogen and Oxygen Analyzers Functional Test &
: Calibration", Ver. 12.0 
===Condition Reports===
: 777689,
: 777630,
: 776849, 769576
==Section 1R22: Surveillance Testing==
===Procedures===
: 34SV-T48-002-2, "Suppression Chamber to Drywell Vacuum Breaker Operability and Containment Purge/Vent Valve Position Check," Ver. 5.7
: 34SV-SUV-019-1, "Surveillance Checks," Ver. 37.3
: 34SV-T22-001-0, "Secondary Containment Test," Ver. 15.1
: 64CH-SAM-025-0, "Reactor Coolant Sampling and Analysis," Ver. 35.1 
===Work Orders===
: SNC522190
==Section 1EP6: Drill Evaluation==
: EP Exercise Narrative and Timeline for drill conducted June 18, 2014
: Drill event notification forms from drill conducted June 18, 2014
==Section 4OA1: Performance Indicator Verification==
: 00AC-REG-005-0, "Preparation and Reporting of NRC PI Data," Ver. 6.2
==Section 4OA2: Identification and Resolution of Problems==
: CAP Trend Report dated March 31, 2104


==Section 4OA5: Other Activities==
: Docket 72-36 10
: CFR 72.212 Report - Revision 15 MPC Loading Verification Datasheet
: MPC-68 Serial Number 426 42FH-ERP-014-O, "Fuel Movement," Ver. 20.0 Fuel Movement Sheets 2014 Dry Cask Storage - Cask 2014-1,
: MPC-426 Loading
}}
}}

Latest revision as of 08:59, 20 December 2019

IR 05000321-14-003; and 05000366-14-003, on April 1, 2014, Through June 30, 2014; Edwin I. Hatch, Units 1 and 2, Operability Determinations and Functionality Assessments
ML14216A382
Person / Time
Site: Hatch  Southern Nuclear icon.png
Issue date: 07/31/2014
From: Frank Ehrhardt
NRC/RGN-II/DRP/RPB2
To: Vineyard D
Southern Nuclear Operating Co
References
IR-14-003
Download: ML14216A382 (22)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION uly 31, 2014

SUBJECT:

EDWIN I. HATCH NUCLEAR PLANT - NRC INTEGRATED INSPECTION REPORT 05000321/2014003 AND 05000366/2014003

Dear Mr. Vineyard:

On June 30, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Edwin I. Hatch Nuclear Plant Units 1 and 2. On July 29, 2014, the NRC inspectors discussed the results of this inspection with Mr. Richard Spring and other members of your staff.

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

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

This finding involved a violation of NRC requirements. 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 significance of the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the Hatch plant.

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 Regional Administrator, Region II; and the NRC resident inspector at the Hatch plant. In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

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

Enclosures:

Inspection Report 05000321/2014003, 05000366/2014003 w/Attachment: Supplemental Information

REGION II==

Docket Nos.: 50-321, 50-366,72-036 License Nos.: DPR-57 and NPF-5 Report Nos.: 05000321/2014003 and 05000366/2014003 Licensee: Southern Nuclear Operating Company, Inc.

Facility: Edwin I. Hatch Nuclear Plant Location: Baxley, Georgia 31513 Dates: April 1 - June 30, 2014 Inspectors: D. Hardage, Senior Resident Inspector E. Morris, Senior Resident Inspector D. Retterer, Project Engineer (1R15)

M. Coursey, Reactor Inspector (4OA5.2)

Approved by: Frank Ehrhardt, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000321/2014003; and 05000366/2014003, April 1, 2014, through June 30, 2014; Edwin I.

Hatch, Units 1 and 2, Operability Determinations and Functionality Assessments The report covered a 3-month period of inspection by resident inspectors and regional inspectors. There was one NRC identified violation identified and documented in this report.

The significance of inspection findings are indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609,

Significance Determination Process (SDP) dated June 2, 2011. The cross-cutting aspects are determined using IMC 0310, Aspects within the Cross-Cutting Areas dated December 19, 2013. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated January 28, 2013. The NRCs program for overseeing the safe operations of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.

Cornerstone: Barrier Integrity

Green.

The inspectors identified a Green non-cited violation of 10 CFR 50, Appendix B,

Criterion V, Procedures, Instructions, and Drawings, for the licensees failure to prove operability following a failure of a surveillance test as required by Hatch procedure 90AC-OAM-001-0, Test and Surveillance Control, Ver. 1.0, on May 12, 2014. To restore compliance, the licensee isolated the refueling floor dampers and re-performed Surveillance Requirement 3.6.4.1.3 with satisfactory results later that day on May 12, 2014. This violation was entered into the licensees corrective action program as condition report (CR)819563.

Failure to prove operability following failure of a surveillance test as required by Hatch procedure 90AC-OAM-001-0, Test and Surveillance Control, Ver. 1.0, on May 12, 2014, was a performance deficiency. The performance deficiency affected the barrier integrity cornerstone and was more-than-minor because, if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, declaring equipment operable following a failed surveillance test would have the potential for the facility to operate outside of technical specification requirements. The inspectors screened this finding using IMC 0609, Appendix A, The Significant Determination Process (SDP) For Findings At-Power, dated June 19, 2012. The finding screened as Green per Section C of Exhibit 3, Barrier Integrity Screening Questions, because the finding only represented a degradation of the radiological barrier function provided by the standby gas treatment system. The inspectors determined the finding had a cross-cutting aspect of training in the human performance area, because the licensee did not ensure knowledge transfer of Surveillance Requirement 3.0.1 requirements to maintain a knowledgeable, technically competent workface and instill nuclear safety values. [H.9] (Section 1R15)

REPORT DETAILS

Summary of Plant Status

Unit 1 began the inspection period at 100 percent rated thermal power (RTP). On May 31, 2014, operators reduced unit power to 25 percent RTP in response to a loss of feedwater heating transient. Operators returned the unit to 100 percent RTP on June 4, 2014. The unit remained at or near 100 percent RTP for the remainder of the inspection period.

Unit 2 operated at or near 100 percent RTP for the duration of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

a. Inspection Scope

Summer Readiness of Offsite and Alternate AC Power System The inspectors reviewed the material condition of offsite and onsite alternate AC power systems (including switchyard and transformers) by performing a walkdown of the switchyard. The inspectors reviewed outstanding work orders and assessed corrective actions for degraded conditions that impacted plant risk or required compensatory actions. Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

1R04 Equipment Alignment

a. Inspection Scope

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

The inspectors selected the following three systems or trains to inspect:

b. Findings

No findings were identified.

1R05 Fire Protection

a. Inspection Scope

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

  • control of transient combustibles and ignition sources
  • fire detection systems
  • water-based fire suppression systems
  • gaseous fire suppression systems
  • manual firefighting equipment and capability
  • passive fire protection features
  • compensatory measures and fire watches
  • issues related to fire protection contained in the licensees corrective action program The inspectors toured the following five fire areas to assess material condition and operational status of fire protection equipment. Documents reviewed are listed in the attachment.
  • Unit 1 and 2 control room, fire zone 0024C
  • Unit 1 reactor building control rod drive areas, fire zones 1203F and 1205F
  • Low pressure safety injection inverter room, fire zone 0028

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

a. Inspection Scope

.1 Resident Inspector Quarterly Review of Licensed Operator Requalification

The inspectors observed a simulator scenario conducted for training of an operating crew for requalification. The inspectors assessed the following:

  • licensed operator performance
  • the ability of the licensee to administer the scenario and evaluate the operators
  • the quality of the post-scenario critique
  • simulator performance Documents reviewed are listed in the Attachment.

.2 Resident Inspector Quarterly Review of Licensed Operator Performance

The inspectors observed licensed operator performance in the main control room during Unit 1 increase in power following a loss of feedwater heating on June 2.

The inspectors assessed the following:

  • use of plant procedures
  • control board manipulations
  • communications between crew members
  • use and interpretation of instruments, indications, and alarms
  • use of human error prevention techniques
  • documentation of activities
  • management and supervision Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors assessed the licensees treatment of the three issues listed below to verify the licensee appropriately addressed equipment problems within the scope of the maintenance rule (10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants). The inspectors reviewed procedures and records to evaluate the licensees identification, assessment, and characterization of the problems as well as their corrective actions for returning the equipment to a satisfactory condition. The inspectors also interviewed system engineers and the maintenance rule coordinator to assess the accuracy of performance deficiencies and extent of condition.

Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

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

Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

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

Documents reviewed are listed in the Attachment.

  • Unit 2 local power range monitor,36-13A, failed upscale, CR 803902

b. Findings

Introduction:

The inspectors identified a Green non-cited violation of 10 CFR 50, Appendix B, Criterion V, Procedures, Instructions, and Drawings, when the licensee failed to prove operability following a failure of a surveillance test as required by Hatch procedure 90AC-OAM-001-0, Test and Surveillance Control, Ver. 1.0, on May 12, 2014.

Description:

On May 12, 2014, SNC performed Technical Specification 3.6.4.1 Surveillance Requirement 3.6.4.1.3 per SNC procedure 34SV-T22-001-0, Secondary Containment Test, Ver. 15.1. This test verifies required standby gas treatment subsystems will draw down secondary containment to greater than or equal to 0.20 inch of vacuum water gauge in less than or equal to 120 seconds. The licensee was performing this test as a post maintenance test following maintenance on the Unit 2 refueling floor vent exhaust fans inboard isolation damper, 2T41-F003A. At 04:05 the control room logs documented that the secondary containment drawdown test did not meet acceptance criteria and Technical Specification Required Action Statement 3.6.4.1.

Condition A was entered. The control room logs also documented that Required Action Statement 3.6.4.1 Condition A was exited at 05:57 because 2T41-F003A and 2T41-F023A, refueling floor vent exhaust fans discharge isolation dampers, had been deactivated/tagged out. SNC procedure NMP-AD-012, Operability Determination and Functionality Assessments, Ver. 12.3, is the procedure for determining and documenting the operability of systems, structures, or components when a degraded or non-conforming condition is found or suspected to exist. NMP-AD-012, Section 2.0.13, states, Technical specification operability considerations require that a system, structure, or component meet all surveillance requirements (as specified in Surveillance Requirement (SR) Applicability SR 3.0.1). A system, structure, or component that does not meet a surveillance requirement must be declared inoperable. Technical Specification Surveillance Requirement 3.0.1 states, Failure to meet a surveillance, whether such failure is experienced during the performance of the surveillance or between performance of the surveillances, shall be failure to meet the limiting condition for operability. With secondary containment failing to meet Surveillance Requirement 3.6.4.1.3 as documented in the most recent surveillance test, 34SV-T22-001-0, NMP-AD-012 required that secondary containment be declared inoperable. Hatch procedure 90AC-OAM-001-0, Test and Surveillance Control, Ver. 1.0, Section 5.2.10.4, contains actions following unsatisfactory surveillance testing results and states in part, To prove operability, a surveillance test shall be run on the equipment, system, or component as required by the surveillance requirement. Upon satisfactory completion of the surveillance test, operability will be declared. However, SNC senior reactor operators declared secondary containment operable without obtaining satisfactory surveillance test results for secondary containment following a failed secondary containment surveillance test.

Analysis:

Failure to prove operability following failure of a surveillance test as required by Hatch procedure 90AC-OAM-001-0, Test and Surveillance Control, Ver. 1.0, on May 12, 2014, was a performance deficiency. The performance deficiency affected the barrier integrity cornerstone and was more-than-minor because, if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, declaring equipment operable following a failed surveillance test would have the potential for the facility to operate outside of technical specification requirements. The inspectors screened this finding using IMC 0609, Appendix A, The Significant Determination Process (SDP) For Findings At-Power, dated June 19, 2012. The finding screened as Green per Section C of Exhibit 3, Barrier Integrity Screening Questions, because the finding only represented a degradation of the radiological barrier function provided by the standby gas treatment system. The inspectors determined the finding had a cross-cutting aspect of training in the human performance area, because the licensee did not ensure knowledge transfer of Surveillance Requirement 3.0.1 requirements to maintain a knowledgeable, technically competent workface and instill nuclear safety values. [H.9]

Enforcement:

10 CFR 50, Appendix B, Criterion V, Procedure, Drawings, and Instructions, requires in part that activities affecting quality shall be accomplished in accordance with documented instructions, procedures, or drawings, of a type appropriate to the circumstances. Hatch procedure NMP-AD-012, Operability Determination and Functionality Assessments, Ver. 12.3, Section 2.0.13 states in part, Technical specification operability considerations require that a system, structure, or component meet all surveillance requirements (as specified in Surveillance Requirement (SR) Applicability SR 3.0.1). A system, structure, or component that does not meet a surveillance requirement must be declared inoperable. In addition, Hatch procedure 90AC-OAM-001-0, Test and Surveillance Control, Ver. 1.0, Section 5.2.10.4, contains actions following unsatisfactory surveillance testing results and states in part, To prove operability, a surveillance test shall be run on the equipment, system, or component as required by the surveillance requirement. Upon satisfactory completion of the surveillance test, operability will be declared. Contrary to this requirement, on May 12, 2014, the licensee failed to accomplish an operability determination and failed to prove operability of secondary containment prior to declaring it operable. Specifically, senior reactor operators declared secondary containment operable after failing Surveillance Requirement 3.6.4.1.3 and did not prove operability by satisfactorily performing the surveillance test prior to declaring the secondary containment operable on May 12, 2014. To restore compliance, the licensee isolated the refueling floor dampers and re-performed Surveillance Requirement 3.6.4.1.3 with satisfactory results later that day on May 12, 2014. This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy. The violation was entered into the licensees corrective action program as CR 819563. (NCV 05000321, 366/2014003-01, Failure to Prove Operability Following the Failure of the Secondary Containment Surveillance Test)

1R18 Plant Modifications

a. Inspection Scope

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

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

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

  • Work order SNC574763, repair Unit 2 drywell 2B hydrogen-oxygen analyzer, May 21 The inspectors evaluated these activities for the following:
  • Acceptance criteria were clear and demonstrated operational readiness.
  • Effects of testing on the plant were adequately addressed.
  • Test instrumentation was appropriate.
  • Tests were performed in accordance with approved procedures.
  • Equipment was returned to its operational status following testing.
  • Test documentation was properly evaluated.

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

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

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

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

Routine Surveillance Tests

  • 34SV-T48-002-2, Suppression Chamber to Drywell Vacuum Breaker Operability and Containment Purge/Vent Valve Position Check

Reactor Coolant System Leak Detection

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation

a. Inspection Scope

The inspectors observed the emergency preparedness drill conducted on June 18, 2014.

The inspectors observed licensee activities in the simulator and/or technical support center to evaluate implementation of the emergency plan, including event classification, notification, and protective action recommendations. The inspectors evaluated the licensees performance against criteria established in the licensees procedures.

Additionally, the inspectors attended the post-exercise critique to assess the licensees effectiveness in identifying emergency preparedness weaknesses and verified the identified weaknesses were entered in the corrective action program. Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

OTHER ACTIVITIES

4OA1 Performance Indicator Verification

a. Inspection Scope

The inspectors reviewed a sample of the performance indicator (PI) data, submitted by the licensee, for the Unit 1 and Unit 2 PIs listed below. The inspectors reviewed plant records compiled between April 2013 and March 2014 to verify the accuracy and completeness of the data reported for the station. The inspectors verified that the PI data complied with guidance contained in Nuclear Energy Institute 99-02, Regulatory Assessment Performance Indicator Guideline, and licensee procedures. The inspectors verified the accuracy of reported data that were used to calculate the value of each PI.

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

Cornerstone: Barrier Integrity

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review

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

.2 Semi-Annual Trend Review

a. Inspection Scope

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

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

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

Documents reviewed are listed in the Attachment.

b. Findings and Observations

No findings were identified.

4OA3 Follow-up of Events and Notices of Enforcement Discretion

.1 Unit 1 Feedwater Heating Transient

a. Inspection Scope

On May 31, 2014, a Unit 1 feedwater heating transient occurred requiring operators to reduce Unit 1 from 100 percent RTP to 25 percent RTP. The inspectors reviewed operator response, control room logs, operating procedures, plant computer data, and operator statements.

b. Findings

No findings were identified.

4OA5 Other Activities

.1 Operation of an Independent Spent Fuel Storage Installation (60855.1)

a. Inspection Scope

The inspectors performed a walkdown of the onsite independent spent fuel storage installation (ISFSI) and monitored the activities associated with the dry fuel storage campaign completed on June 17. The inspectors reviewed changes made to the ISFSI programs and procedures, including associated 10 CFR 72.48, Changes, Tests, and Experiments, screens and evaluations to verify that changes made were consistent with the license or certificate of compliance. The inspectors reviewed records to verify that the licensee recorded and maintained the location of each fuel assembly placed in the ISFSI. The inspectors also reviewed surveillance records to verify that daily surveillance requirements were performed as required by technical specifications. Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

.2 (Closed) Temporary Instruction -2515/182 - Review of the Industry Initiative to Control

Degradation of Underground Piping and Tanks

a. Inspection Scope

From April 14 - April 16, 2014, the inspectors conducted a review of records and procedures related to the licensees program for buried pipe, underground pipe and tanks in accordance with Phase II of TI-2515/182. This review was done to confirm that the licensees program contained attributes consistent with Sections 3.3.A and 3.3.B of NEI 09-14 and to confirm that these attributes were scheduled and/or completed by the NEI 09-14 Revision 3 deadlines. To determine if the program attribute was accomplished in a manner which reflected good or poor practices in program management, the inspectors interviewed licensee staff responsible for the buried pipe program and reviewed buried pipe program related activities.

The licensees buried piping and underground piping and tanks program was inspected in accordance with paragraph 03.02.a of the temporary instruction (TI) and it was confirmed that activities, which correspond to completion dates specified in the program which have passed since the Phase 1 inspection was conducted, have been completed.

Additionally, the licensees buried piping and underground piping and tanks program was inspected in accordance with paragraph 03.02.b of the TI and responses to specific questions found in http://www.nrc.gov/reactors/operating/ops-experience/buried-pipe-ti-phase-2-insp-req-2011-11-16.pdf were submitted to the NRC headquarters staff.

Based upon the scope of the review described above, Phase II of TI-2515/182 was completed.

b. Findings

No findings were identified

4OA6 Meetings, Including Exit

On July 29, 2014, the resident inspectors presented the inspection results to Mr. Richard Spring and other members of the licensees staff. The inspectors confirmed that proprietary information provided or examined during the inspection period was properly controlled.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

B. Anderson, Health Physics Manager
G. Brinson, Maintenance Director
V. Coleman, Chemistry Manager
A. Giancatarino, Engineering Director
G. Johnson, Site Regulatory Affair Manager
D. Komm, Operations Director
K. Long, Work Management Director
R. Spring, Plant Manager
S. Tipps, Principal Licensing Engineer
M. Torrance, Nuclear Oversight Manager
D. Vineyard, Hatch Vice President
A. Wheeler, Site Projects Manager

LIST OF ITEMS

OPENED AND CLOSED

Closed

2515/182 TI Phase II - Review of the Industry Initiative to Control Degradation of Underground Piping and Tanks (Section 4OA5.2)

Opened &

Closed

05000321,366/2014003-01 NCV Failure to Prove Operability Following the Failure of the Secondary Containment Surveillance Test (Section 1R15)

LIST OF DOCUMENTS REVIEWED