IR 05000321/2021003: Difference between revisions
StriderTol (talk | contribs) (StriderTol Bot change) |
StriderTol (talk | contribs) (StriderTol Bot change) |
||
Line 18: | Line 18: | ||
=Text= | =Text= | ||
{{#Wiki_filter: | {{#Wiki_filter:October 19, 2021 | ||
==SUBJECT:== | |||
EDWIN I. HATCH NUCLEAR PLANT - INTEGRATED INSPECTION REPORT 05000321/2021003 AND 05000366/2021003 | |||
==Dear Ms. Gayheart:== | |||
On September 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Edwin I. Hatch Nuclear Plant. On October 19, 2021, the NRC inspectors discussed the results of this inspection with Sonny Dean and other members of your staff. The results of this inspection are documented in the enclosed report. | |||
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy. | |||
If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: | |||
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at Edwin I. Hatch Nuclear Plant. | |||
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding. | |||
Sincerely, | |||
/RA/ | |||
Alan J. Blamey, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket Nos. 05000321 and 05000366 License Nos. DPR-57 and NPF-5 | |||
===Enclosure:=== | |||
As stated | |||
==Inspection Report== | |||
Docket Numbers: 05000321 and 05000366 License Numbers: DPR-57 and NPF-5 Report Numbers: 05000321/2021003 and 05000366/2021003 Enterprise Identifier: I-2021-003-0010 Licensee: Southern Nuclear Operating Company, Inc. | |||
Facility: Edwin I. Hatch Nuclear Plant Location: Baxley, GA Inspection Dates: July 01, 2021 to September 30, 2021 Inspectors: J. Hickman, Resident Inspector R. Smith, Senior Resident Inspector Approved By: Alan J. Blamey, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure | |||
=SUMMARY= | |||
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Edwin I. Hatch Nuclear Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. | |||
===List of Findings and Violations=== | |||
Inoperability of 2D Residual Heat Removal (RHR) Pump Due to Inadequate Maintenance Procedural Instructions for Recoupling Pump and Motor Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71152 Systems NCV 05000366/2021003-01 Open/Closed A self-revealing Green non-cited violation of Unit 2 Technical Specification (TS) 5.4.1(a) was identified for the licensees failure to incorporate adequate maintenance procedural instructions for the recoupling of the residual heat removal (RHR) pump and motor as recommended by Regulatory Guide (RG) 1.33, section 9.a. Specifically, procedure 52PM-E11-003-2, RHR Pump and Motor Maintenance, Version 9.4 did not contain instructions to verify the tightness of the motor coupling nut set screws in 2D RHR pump to prevent the pump shaft downward movement within the pump, thus causing pump failure and pump inoperability. | |||
===Additional Tracking Items=== | |||
None. | |||
=PLANT STATUS= | |||
Unit 1 began the inspection period completing a shutdown that was started on June 30, 2021. The shutdown was performed to repair turbine temperature switches that were erroneously causing half group one signals on the A2 channel due to instrument drift. On July 4, 2021, after repairs to the turbine temperature switches were made, the unit was restarted. The unit returned to 100 percent rated thermal power (RTP) on July 10, 2021. On July 15, 2021, the unit was down powered to 50 percent RTP to perform investigation and repairs due to a condenser tube leaks resulting in an increase in reactor coolant chlorides. After repairs were made by plugging leaking condenser tubes, the unit was returned to 100 percent RTP on July 19, 2021. On August 3, 2021, the unit scrammed on low reactor water level caused by loss of normal feedwater. The loss of feedwater was caused from a loss of power to the electrical bus powering feedwater pump controls. After repairs were made by restoring power to the electrical bus, the unit was restarted and returned to 100 percent RTP on August 9, 2021. On September 19, 2021, the unit was down powered to 70 percent RTP to perform a rod pattern adjustment and turbine valve testing, and the unit returned to 100 percent RTP on September 21, 2021, following completion of those activities. The unit operated there for the remainder of the inspection period. | |||
Unit 2 began the inspection period at 100 percent RTP. On September 11, 2021, the unit was down powered to 70 percent RTP to perform a rod pattern adjustment and turbine valve testing, and the unit was returned to 100 percent RTP the same day. The unit operated there for the remainder of the inspection period. | |||
==INSPECTION SCOPES== | |||
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards. | |||
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident and regional inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time, the resident inspectors performed periodic site visits each week, increasing the amount of time on-site as local COVID-19 conditions permitted. | |||
As part of their on-site activities, resident inspectors conducted plant status activities as described in IMC 2515, Appendix D; conducted routine reviews using IP 71152, Problem Identification and Resolution, observed risk significant activities; and completed on-site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or a portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on-site. The inspections documented below met the objectives and requirements for completion of the IP. | |||
==REACTOR SAFETY== | |||
==71111.04 - Equipment Alignment== | |||
===Partial Walkdown Sample (IP Section 03.01) (4 Samples)=== | |||
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains: | |||
: (1) Alignment of the Unit 2 residual heat removal (RHR) system following a pump operability test the previous day, using 34SO-E11-010-2, on July 21, 2021. | |||
: (2) Alignment of the Unit 1 plant service water (PSW) system following 1B PSW pump motor replacement, using 34SO-P41-001-1, on July 30, 2021. | |||
: (3) Alignment of the Unit 1 core spray (CS) system, 'A' Loop, during CS loop 'B' valve operability test, using 34SO-E21-001-1, on August 17, 2021. | |||
: (4) Alignment of the Unit 1 CS system, 'A' Loop, during loop 'B' pump operability test, using 34SO-E21-001-1, on August 18, 2021. | |||
==71111.05 - Fire Protection== | |||
===Fire Area Walkdown and Inspection Sample (IP Section 03.01) (6 Samples)=== | |||
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas: | |||
: (1) Unit 1 standby gas treatment system room on July 14, 2021. | |||
: (2) Unit 2 reactor core isolation cooling system room on July 15, 2021. | |||
: (3) Unit 2 reactor building 158'/164' elevation on July 20, 2021. | |||
: (4) Unit 1 and 2 intake structure on July 28, 2021. | |||
: (5) Unit 1 and 2 emergency diesel generator (EDG) building on August 19, 2021. | |||
: (6) Unit 1 and 2 control building 112' elevation, on August 20, 2021. | |||
==71111.06 - Flood Protection Measures== | |||
===Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)=== | |||
The inspectors evaluated internal flooding mitigation protections in the: | |||
(1) | |||
* Unit 1 reactor building northwest control rod drive (CRD) compartment | |||
* Unit 1 reactor building northeast residual heat removal (RHR) and core spray (CS) compartment | |||
* Unit 1 reactor building southeast RHR and CS compartment | |||
* Unit 1 reactor core isolation cooling (RCIC) southwest compartment | |||
* Unit 1 high pressure core cooling (HPCI) compartment | |||
==71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance== | |||
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample) | |||
: (1) The inspectors observed and evaluated licensed operator performance in the control room during a plant startup, following the forced maintenance outage on July 6, 2021. The inspectors observed non-critical heat-up due to a positive moderator coefficient, rod pull to criticality and to the point of adding heat, and observed the operating crew establish a controlled heat-up rate within technical specification limits. | |||
===Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)=== | |||
: (1) The inspectors observed and evaluated "License Operator Just in Time Training" (JITT) H-LOCT 21-026 "U1 MOC Startup," for one team during simulator training on July 1, 2021. | |||
==71111.12 - Maintenance Effectiveness== | |||
===Maintenance Effectiveness (IP Section 03.01) (1 Sample)=== | |||
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function: | |||
: (1) Review of the Unit 1 high pressure coolant injection (HPCI) system following failures of various HPCI components, on September 24, 2021. | |||
==71111.13 - Maintenance Risk Assessments and Emergent Work Control== | |||
===Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)=== | |||
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed: | |||
: (1) Unit 1 elevated risk due to the trip of the 1B PSW pump, from July 19 to July 30, 2021. | |||
: (2) Unit 1 elevated risk following reactor trip and being in shutdown cooling, 31GO-OPS-024-0, Outage Safety Assessment dated August 4, 2021. | |||
: (3) Unit 1 elevated risk due to unplanned inoperability of the 1C PSW pump, from August 26 to September 16, 2021. | |||
: (4) Unit 1 elevated risk due to unplanned inoperability of the HPCI system due to HPCI discharge valve failing to open, from September 8 to September 10, 2021. | |||
: (5) Unit 1 elevated risk due to limited condition of operation (LCO) extension for the 1C PSW pump, from 30 days to 45 days, September 21 to September 28, 2021. | |||
==71111.15 - Operability Determinations and Functionality Assessments== | |||
===Operability Determination or Functionality Assessment (IP Section 03.01) (7 Samples)=== | |||
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments: | |||
: (1) Condition Report (CR) 10810391, Unit 1 "B" Recirculation Discharge Valve did not close on demand on July 3, 2021. | |||
: (2) CR 10812018, Unit 2 "A" Emergency Diesel Generator (EDG) Fuel Oil Transfer Pump seal leak of 0.5 to 1.0 GPM on July 12, 2021. | |||
: (3) CR 10813948, Unit 1 "B" plant service water (PSW) pump trip on July 19, 2021. | |||
: (4) CR 10817764, Unit 1 high pressure coolant injection (HPCI) main pump mechanical seal leak, inboard seal on August 3, 2021. | |||
: (5) CR 10822020, Unit 1 "B" HPCI pump room cooler leak on August 25, 2021. | |||
: (6) CR 10823851, Unit 1 "C" PSW pump foreign material analysis, effects on 1A and 1B PSW pumps on September 2, 2021. | |||
: (7) CR 10827289, Unit 2 "A" EDG battery with cell 27 jar cracked through the side wall on September 15, 2021. | |||
==71111.18 - Plant Modifications== | |||
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples) | |||
The inspectors evaluated the following temporary or permanent modifications: | |||
: (1) Temporary modification to bypass air around solenoid valves 1N11-F036A and 1N11-F036B, as their failure would result in the loss of the steam jet air ejector on Unit 1 and result in a subsequent greater than 20 percent down power. | |||
: (2) Permanent modification to the upper and lower seismic restraints on 1C PSW pump due to excessive contact with the pump column preventing proper alignment of the pump. | |||
==71111.19 - Post-Maintenance Testing== | |||
===Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)=== | |||
The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality: | |||
: (1) NMP-ES-017-020, "MOV Electrical Checkout and Adjustments for SMB/SB Actuators," Version 6.5, and 34SV-B31-001-1, "Recirculation System Valve Operability," Version 7.10, following motor replacement of the 1B recirculation discharge motor operated valve on July 4, 2021. | |||
: (2) 34SV-R43-002-1, "Diesel Generator 1B Monthly Test," Version 24.6, following the troubleshooting and replacement of the fuel oil filter differential pressure gage on July 14, 2021. | |||
: (3) 34SV-P41-001-1, "Plant Service Water Pump Operability," Version 15.2, following the replacement of 1B plant service water pump motor on July 30, 2021. | |||
: (4) 34SV-B31-001-1, "Recirculation System Valve Operability," Version 7.11, after replacement of fuse clips in the valve breaker for 1B31-F031B discharge valve for 'B' recirculation loop, on August 5, 2021. | |||
: (5) SNC1171149, Functional test of auto transfer time delay relay for turbine building switchgear 1R23S021, following relay replacement on August 6, 2021. | |||
: (6) 34SV-P41-001-1, "Plant Service Water (PSW) Pump Operability," Version 15.2, following the replacement of 1C PSW pump on September 28, 2021. | |||
==71111.20 - Refueling and Other Outage Activities== | |||
===Refueling/Other Outage Sample (IP Section 03.01) (2 Samples)=== | |||
: (1) The inspectors evaluated forced outage activities on Unit 1, due to turbine building temperatures switches causing half group I signals on the A2 channel, from June 30, 2021 to July 6, 2021. | |||
: (2) The inspectors evaluated forced outage activities on Unit 1, caused by a reactor scram resulting from a loss of normal feed water, from August 3 to August 8, 2021. | |||
==71111.22 - Surveillance Testing== | |||
The inspectors evaluated the following surveillance tests: | |||
===Surveillance Tests (other) (IP Section 03.01)=== | |||
{{IP sample|IP=IP 71111.22|count=1}} | |||
: (1) 34SV-R43-012-2, "Diesel Generator 1B 24 Month Operability Test," Version 8.1, on | |||
===August 11, 2021. | |||
Inservice Testing (IP Section 03.01) (1 Sample)=== | |||
: (1) 34SV-E11-001-1, "Residual Heat Removal Pump Operability IST," Version 30.1, on July 15, 2021. | |||
==71114.06 - Drill Evaluation== | |||
===Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)=== | |||
The inspectors evaluated: | |||
: (1) Licensed reactor operators respond to a Reactor Scram with Anticipated Transient Without a Scram (ATWS) in the simulator and observed the crew make an emergency declaration and notification. This represented a drill and exercise performance opportunity on July 6, | |||
==OTHER ACTIVITIES - BASELINE== | |||
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below: | |||
MS06: Emergency AC Power Systems (IP Section 02.05) === | |||
{{IP sample|IP=IP 71151|count=2}} | |||
: (1) Unit 1 (July 1, 2020-June 30, 2021) | |||
: (2) Unit 2 (July 1, 2020-June 30, 2021) | |||
===MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)=== | |||
: (1) Unit 1 (July 1, 2020-June 30, 2021) | |||
: (2) Unit 2 (July 1, 2020-June 30, 2021) | |||
===MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)=== | |||
: (1) Unit 1 (July 1, 2020-June 30, 2021) | |||
: (2) Unit 2 (July 1, 2020-June 30, 2021) | |||
==71152 - Problem Identification and Resolution== | |||
===Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)=== | |||
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues: | |||
: (1) The 1D residual heat removal service water pump (RHRSW) failure caused by the pump shaft seizing to the mechanical seal box in the discharge head. | |||
: (2) Inoperability of 2D residual heat removal (RHR) pump due to inadequate maintenance procedural instructions for recoupling pump and motor. | |||
===71153 - Follow Up of Events and Notices of Enforcement Discretion Event Followup (IP Section 03.01) === | |||
{{IP sample|IP=IP 71153|count=2}} | |||
: (1) The inspectors evaluated the Unit 1 reactor scram caused by loss of normal reactor feed water and licensees response on August 3, 2021. | |||
: (2) The inspectors evaluated the unplanned inoperability of the 1C PSW pump caused by the shaft shearing, on August 26, | |||
==INSPECTION RESULTS== | |||
Inoperability of 2D Residual Heat Removal (RHR) Pump Due to Inadequate Maintenance Procedural Instructions for Recoupling Pump and Motor Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71152 Systems NCV 05000366/2021003-01 Open/Closed A self-revealing Green non-cited violation of Unit 2 Technical Specification (TS) 5.4.1(a) was identified for the licensees failure to incorporate adequate maintenance procedural instructions for the recoupling of the residual heat removal (RHR) pump and motor as recommended by Regulatory Guide (RG) 1.33, section 9.a. Specifically, procedure 52PM-E11-003-2, RHR Pump and Motor Maintenance, Version 9.4 did not contain instructions to verify the tightness of the motor coupling nut set screws in 2D RHR pump to prevent the pump shaft downward movement within the pump, thus causing pump failure and pump inoperability. | |||
=====Description:===== | |||
On April 16, 2021, the 2D RHR Pump was operating in torus cooling mode and after approximately 10 minutes of pump operation, an overcurrent annunciator OVLD/Lockout Relay trip was received. The annunciator response procedure was entered, the 2D RHR pump was manually secured, and TS LCO 3.5.1 A(1) was subsequently entered. After initial troubleshooting, another pump run was attempted that resulted in an automatic pump trip. | |||
Following the second attempted pump run, the 2D RHR pump was disassembled, and the first stage impeller was found bound to the suction head wear ring. During the pump repair, the mechanics working on the mechanical seal observed that the motor coupling nut set screws were loose. The design/intent of the set screws is to hold the motor coupling nut stationary. Due to these set screws being loose during each pump start, the combination of shaft loading/unloading on the nut caused significant torque leading to the coupling nut loosening. During the nut loosening process from each start, the pump shaft moved downward within the pump. This caused the first stage impeller to come in contact (rub) with the suction head wear ring and resulted in it grinding/cutting into the wear ring. The binding together of the impeller and wear ring caused the overcurrent in the motor that resulted in the overcurrent annunciator OVLD/Lockout Relay trip seen in the control room. | |||
The motor for 2D RHR pump was replaced on March 4, 2019. At the time, the motor coupling was disconnected, and the licensee failed to ensure the set screws were tightened down as required. The cause of the improper maintenance was inadequate procedural guidance for the process of tightening the motor half coupling nut set screws. During the creation of the maintenance procedure 52PM-E11-003-2 in 1991, information from the vendor manual pertaining to a referenced General Electric (GE) Service Information Letter (SIL) #417, was not transferred from the RHR Pump maintenance vendor manual to the new pump maintenance procedure. GE SIL #417 was provided to Plant Hatch on January 14, 1985. The SIL was a warning to affected utilities that the motor half coupling nut could loosen and lead to pump failure if the set screws were not installed and tightened properly. The licensee responded to GE SIL #417 by revising the vendor manual SX27070 with an As Built Notice (ABN), however failed to transfer this information over to their revised procedure in 1991. | |||
Corrective Actions: The licensee entered this pump failure event into their corrective action program. The licensee repaired 2D RHR pump by properly reinstalling/tightening the motor coupling set screws and by replacing the pump rotating assembly/suction head. Additionally, the licensee verified the clearance between the mechanical seal gland plate and collar on all remaining Ingersoll Rand Pumps met requirements and no movement of the coupling nuts had occurred to other similar pumps. The licensee also revised their procedure 52PM-E11-003-2, incorporating instructions to apply thread-locker to coupling nut set screws and to ensure they were properly tightened to reduce the likelihood of this type of event occurring again. | |||
Corrective Action References: Condition reports (CRs) 10791097 and 10801317; technical evaluations (TE) 1090830, 1090831, 1090832, 1090833, 1090834 and 1090835 corrective action report (CAR) 279192. | |||
=====Performance Assessment:===== | |||
Performance Deficiency: The failure to provide appropriate procedures, instructions, or drawings for maintenance that could affect the performance of safety-related equipment per TS 5.4.1 and Regulatory Guide 1.33 was a performance deficiency. Specifically, there were no instructions or drawings to verify the tightness of the motor coupling nut set screws to prevent shaft downward movement within the pump. | |||
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the 2D RHR pump failed due to incorrect maintenance by the licensee when they failed to tighten the motor half coupling nut with set screws, resulting in an out of service time for the pump greater than its normal TS outage limit. | |||
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The affected cornerstone was Mitigating Systems, as determined by Inspection Manual Chapter (IMC) 0609, 4, Initial Characterization of Findings. Utilizing IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, the performance deficiency required a detailed risk evaluation because the degraded condition represented a loss of the PRA function of one train of a multi-train TS system for greater than its TS allowed outage time. | |||
A regional Senior Reactor Analyst (SRA) conducted a detailed risk evaluation using the guidance in IMC 0609 Appendix A and the Risk Assessment Standardization Project (RASP) | |||
Handbook. The SRA modelled the condition using the Hatch Unit 1&2 SPAR model version 8.58 dated February 28, 2017, and SAPHIRE 8 Version 8.2.3. The exposure period was divided into two periods. First, the 10-day period from the last run of the 2D RHR pump on April 13, 2021 until April 22, 2021, when the one-time emergency TS amendment was approved and the second from April 22, 2021, until the 2D RHR pump was declared operable on April 29, 2021. During the second period, the compensatory actions required by the emergency TS were credited. The issue was modelled as a failure to start of the 2D RHR pump, due to the failure mechanism failure to run was not considered. The dominant accident sequences included several fire scenarios and a loss of condenser heat sink event with a failure of RHR, late injection and containment venting functions. For the first 10-day period, risk was determined to be 5.042E-7 core damage events per year. For the final seven-day period, the risk was 4.482E-8 core damage events per year. Thus, total risk for the exposure period was 5.49E-7 core damage events per year, which makes this a finding of very low safety significance (Green). | |||
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance. | |||
=====Enforcement:===== | |||
Violation: Hatch Unit 2 Technical Specification 5.4.1.(a) Procedures, states, in part, that written procedures shall be implemented covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, February 1978. Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), Appendix A, Paragraph 9.a, Procedures for Performing Maintenance, requires that maintenance that can affect the performance of safety-related equipment should be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. | |||
Contrary to the above, on March 4, 2019, maintenance procedure 52PM-E11-003-2 did not provide procedures, instructions, or drawings regarding 2D RHR pump motor replacement that were appropriate to the circumstances. Specifically, there were no instructions or drawings to verify the tightness of the motor coupling nut set screws to prevent shaft downward movement within the pump. | |||
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy. | |||
==EXIT MEETINGS AND DEBRIEFS== | |||
The inspectors verified no proprietary information was retained or documented in this report. | |||
* On October 19, 2021, the inspectors presented the integrated inspection results to Sonny Dean and other members of the licensee staff. | |||
=DOCUMENTS REVIEWED= | |||
Inspection Type Designation Description or Title Revision or | |||
Procedure Date | |||
71111.04 Corrective Action 10750927, | |||
Documents 10805421 | |||
Drawings H-16331 Unit 1 Core Spray P&ID 38.0 | |||
H-26014 RHR System P&ID Sheet 1 65.0 | |||
H-26015 RHR System P&ID Sheet 2 60.0 | |||
Procedures 34SO-E11-010-2 Residual Heat Removal System 44.5 | |||
34SO-E21-001-01 Core Spray System 24.8 | |||
34SO-P41-001-1 Plant Service Water System 36.19 | |||
34SV-E21-001-01 1E21C001B ISI Core Spray Pump Operability 24.1 | |||
34SV-E21-002-1 1E21 B Loop Core Spray Valve Operability 12.5 | |||
Work Orders SNC1112235 | |||
SNC1112410 | |||
71111.05 Corrective Action CR10814348 07/20/2021 | |||
Documents | |||
Resulting from | |||
Inspection | |||
Fire Plans Drawing A-34965, Unit 2 Reactor Core Isolation Cooling Pump and Turbine 3.0 | |||
Sheet 100 Room | |||
Drawing A-43965, Unit 1 Standby Gas Treatment Room 4.0 | |||
Sheet 66 | |||
NMP-ES-035-019- U2 Reactor Building EL 158/164 1.0 | |||
GL01-F31 | |||
NMP-ES-035-019- Diesel Generator Building El. 130 Fire Plan 1.0 | |||
GL02-F06 | |||
NMP-ES-035-019- Intake Structure 1.0 | |||
GL02-F07 | |||
NMP-ES-035-019- Pre-Fire Plan for Control Building 112 elevation 1.0 | |||
GL2-F01 | |||
71111.06 Miscellaneous HNP-1-FSAR Sections 5.2.1, 5.6.1, 5.6.3, 6.4.1 and Figure 4.10-5 24/35/19 | |||
Procedures 34AB-T22-003-1 Secondary Containment Control 5.18 | |||
34AB-T23-001-1 Loss Of Primary Containment Control 1.3 | |||
34AB-T23-004-1 Torus Water Level 1.2 | |||
Inspection Type Designation Description or Title Revision or | |||
Procedure Date | |||
71111.12 Corrective Action CAR278906 | |||
Documents Condition Reports 10729060, 10729502, 10733510, 10733807, 10749660, | |||
10751450, 10760865, 10760867, 10761652, 10761654, | |||
10761877, 10766527, 10766528, 10766900, 10771285, | |||
10786252, 10786424, 10788442, 10797061, 10804276, | |||
10804392, 10805177, 10805246, 10805833, 10805897, | |||
10705977, 10805981, 10806069, 10806554, 10817164, | |||
10817776, 10818273, 10818320, 10818432, 10822785, | |||
10823876, 10825511, 10825758, 10825818, 10826236, | |||
10826251, 10826278 | |||
Miscellaneous E41- 01- High Provide Adequate Core Coolant for Small Pipe Breaks that | |||
Pressure Coolant do Not Rapidly Depressurize the Reactor During a Design | |||
Injection Basis Accident | |||
E41- 02- High Provide Alternate RPV Control Functions During EOP | |||
Pressure Coolant Implementation | |||
Injection | |||
Procedures 34SO-E41-001-1 High Pressure Coolant Injection (HPCI) System 30.4 | |||
Work Orders SNC1171081 | |||
71111.13 Miscellaneous NL-21-0852 Evaluation of Risk Impact and Compensatory Measures 09/21/2021 | |||
S-2021-06 Implementation of Compensatory and Risk Management 09/21/2021 | |||
Controls for Technical Specification 3.7.2, Regarding One- | |||
Time Extension of Completion Time for 1C PSW Pump | |||
Procedures 31GO-OPS-024-0 Outage Safety Assessment 4.1 | |||
NMP-OS-010-002 Hatch Protected Equipment Logs 11.1 | |||
71111.15 Corrective Action 10817764 08/03/2021 | |||
Documents 10818432 08/05/2021 | |||
10822020 08/22/2021 | |||
Corrective Action 10822886 08/25/2021 | |||
Documents | |||
Resulting from | |||
Inspection | |||
Engineering #308164 Station battery Cell Cracked - Indian Point Unit 3 10/09/2013 | |||
Evaluations #318147 Black Start Peaker Battery Cell Case Cracked - Fermi 08/01/2015 | |||
Inspection Type Designation Description or Title Revision or | |||
Procedure Date | |||
#324296 Battery Failure Due to Crack Cell - Indian Point Unit 2 08/24/2016 | |||
#413848 Maintenance Discovers Crack in Safety Related Battery - 09/12/2017 | |||
Grand Gulf | |||
Miscellaneous Email from 2A EDG Battery Jumper 09/22/2021 | |||
Electrical | |||
Maintenance | |||
Supervisor | |||
Email from 2A EDG Battery 2R42-S002A Cell Operability 09/22/2021 | |||
Engineering | |||
Supervisor | |||
Operability 2-08-02 Unit 1 and Unit 2 HPCI Mechanical Seal Leak | |||
Evaluations NMP-AD-012-F01 Operability Determination Support Basis - 1B HPCI Room 08/25/2021 | |||
Cooler | |||
Procedures 34SV-E41-002-1 HPCI Pump Operability 33.2 | |||
Work Orders SNC372604 | |||
71111.18 Drawings A11015, Sheet 1 Edwin I. Hatch Nuclear Plant Unit 1 Seismic Restraints 5.0 | |||
Plant Service Water | |||
SNC1163136TCC1 2.0 | |||
SNC1163136TCC2 2.0 | |||
SNC1163136TCC3 2.0 | |||
SNC1163136TCC4 2.0 | |||
SNC1163136TCC5 2.0 | |||
Engineering Design Equivalent 1P41C Upper Seismic Restraint Alignment 09/06/2021 | |||
Changes Change Package | |||
SNC1176825 | |||
SNC11631136 TCC to Bypass Air Around Solenoid Valves on 1N11-F036A 06/15/2021 | |||
and 1N11-F036B | |||
SNC1163136 TCC to Bypass Air Around Solenoid Valves on 1N11-F036A 01 | |||
and 1N11-F036B | |||
Miscellaneous IP-ENG-001 Nuclear Industry Standard Process Engineering - Standard 2 | |||
Design Process (EB-17-06) | |||
NDE Reports 51GM-MNT-065-0 Weld Process Control Sheet-ASME Safety Class Welds 09/08/2021 | |||
Procedures 52PM-P41-036-1 Unit 1 Plant Service Water Pump & Motor Major 9.6 | |||
Inspection/Overhaul | |||
Inspection Type Designation Description or Title Revision or | |||
Procedure Date | |||
NMP-AD-008-F01 Applicability Determination 07/01/2021 | |||
NMP-AD-008-F01 Applicability Determination 06/15/2021 | |||
NMP-AD-010-F01 10 CFR 50.59 Screening 06/15/2021 | |||
NMP-AD-010-F01 10 CFR 50.59 Screening 07/01/2021 | |||
NMP-ES-025-002 Quality Control Inspection Planning 2.0 | |||
NMP-ES-035-006- Fire Protection Program Impact Screen for SNC1163136 7.0 | |||
F05 | |||
NMP-OS-003-F01 Operational Decision-Making Issue Worksheet 07/09/2021 | |||
Work Orders SNC1177052 Perform Modification of 1P41C001C -Upper Pump seismic 09/08/2021 | |||
restraint | |||
71111.19 Corrective Action 10818216 08/05/2021 | |||
Documents 10878391 08/05/2021 | |||
Corrective Action CR10830501 | |||
Documents CR10830511 | |||
Resulting from CR10830519 | |||
Inspection CR10830530 | |||
Procedures 34SV-B31-001-1 Recirculation System Valve Operability (8/5/2021) 7.11 | |||
2PM-P41-036-1 Unit 1 Plant Service Water Pump and Motor Major 9.5 | |||
Inspection/Overhaul | |||
NMP-MA-014 Post Maintenance Testing/Post Modification Testing 2.3 | |||
NMP-MA-014-001 Post Maintenance Testing Guidance 5.7 | |||
NMP-MA-019 Bolting and Torque Guidelines 5.1 | |||
Work Orders SNC1166472 | |||
SNC844572 1B Plant Service Water Motor replacement 07/29/2021 | |||
71111.20 Miscellaneous Unit 1 Forced Outage List 08/06/2021 | |||
SRO Event Report Unit 1 Low Reactor Water Level Automatic Scram Due to | |||
21-01 Dual Reactor Feed Pump Trip (8/3/2021) | |||
Procedures 31-GO-OPS-010-0 Scram / Transient Analysis (8/3/2021 Scram) 7.6 | |||
2PM-MEL-026-0 MICROVERSA Trip Plus (MVT+) Overcurrent Trip Units 9.4 | |||
NMP-RE-008-F01 Detailed Reactivity Management Plan 08/04/2021 | |||
71114.06 Miscellaneous LORP Scenario H- Loss of Control Rod Drive flow, 2C Plant Service Water 06/21/2021 | |||
LT-AF-00116 pump trip, Reactor Feed Pump High Vibrations, ATWS, and | |||
Recirculation Pump Seal Failure. | |||
Inspection Type Designation Description or Title Revision or | |||
Procedure Date | |||
71152 Corrective Action 10741430 | |||
Documents 10791097 04/16/2021 | |||
CAR277097 | |||
CAR279192 07/15/2021 | |||
CAR279412 | |||
Engineering TE 1090830 | |||
Evaluations TE 1090831 | |||
TE 1090832 | |||
TE 1090833 | |||
TE1057091 | |||
TE1090049 | |||
TE1090900 | |||
TE1091056 | |||
71153 Corrective Action 10817773, | |||
Documents 10818433, | |||
10818435 | |||
Drawings H-13367 Single Line Diagram 120/208V, Station Switchgear 1A 32 | |||
Sheet 1 of 2 | |||
H-13367 Single Line Diagram 120/208V, Station Switchgear 1A 20 | |||
Sheet 2 of 2 | |||
H-13384 Elementary Diagram 600V and 208V Station Service 24 | |||
16 | |||
}} | }} |
Revision as of 13:15, 18 January 2022
ML21292A342 | |
Person / Time | |
---|---|
Site: | Hatch |
Issue date: | 10/19/2021 |
From: | Alan Blamey Division Reactor Projects II |
To: | Gayheart C Southern Nuclear Operating Co |
References | |
IR 2021003 | |
Download: ML21292A342 (19) | |
Text
October 19, 2021
SUBJECT:
EDWIN I. HATCH NUCLEAR PLANT - INTEGRATED INSPECTION REPORT 05000321/2021003 AND 05000366/2021003
Dear Ms. Gayheart:
On September 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Edwin I. Hatch Nuclear Plant. On October 19, 2021, the NRC inspectors discussed the results of this inspection with Sonny Dean and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at Edwin I. Hatch Nuclear Plant.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Alan J. Blamey, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket Nos. 05000321 and 05000366 License Nos. DPR-57 and NPF-5
Enclosure:
As stated
Inspection Report
Docket Numbers: 05000321 and 05000366 License Numbers: DPR-57 and NPF-5 Report Numbers: 05000321/2021003 and 05000366/2021003 Enterprise Identifier: I-2021-003-0010 Licensee: Southern Nuclear Operating Company, Inc.
Facility: Edwin I. Hatch Nuclear Plant Location: Baxley, GA Inspection Dates: July 01, 2021 to September 30, 2021 Inspectors: J. Hickman, Resident Inspector R. Smith, Senior Resident Inspector Approved By: Alan J. Blamey, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Edwin I. Hatch Nuclear Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Inoperability of 2D Residual Heat Removal (RHR) Pump Due to Inadequate Maintenance Procedural Instructions for Recoupling Pump and Motor Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71152 Systems NCV 05000366/2021003-01 Open/Closed A self-revealing Green non-cited violation of Unit 2 Technical Specification (TS) 5.4.1(a) was identified for the licensees failure to incorporate adequate maintenance procedural instructions for the recoupling of the residual heat removal (RHR) pump and motor as recommended by Regulatory Guide (RG) 1.33, section 9.a. Specifically, procedure 52PM-E11-003-2, RHR Pump and Motor Maintenance, Version 9.4 did not contain instructions to verify the tightness of the motor coupling nut set screws in 2D RHR pump to prevent the pump shaft downward movement within the pump, thus causing pump failure and pump inoperability.
Additional Tracking Items
None.
PLANT STATUS
Unit 1 began the inspection period completing a shutdown that was started on June 30, 2021. The shutdown was performed to repair turbine temperature switches that were erroneously causing half group one signals on the A2 channel due to instrument drift. On July 4, 2021, after repairs to the turbine temperature switches were made, the unit was restarted. The unit returned to 100 percent rated thermal power (RTP) on July 10, 2021. On July 15, 2021, the unit was down powered to 50 percent RTP to perform investigation and repairs due to a condenser tube leaks resulting in an increase in reactor coolant chlorides. After repairs were made by plugging leaking condenser tubes, the unit was returned to 100 percent RTP on July 19, 2021. On August 3, 2021, the unit scrammed on low reactor water level caused by loss of normal feedwater. The loss of feedwater was caused from a loss of power to the electrical bus powering feedwater pump controls. After repairs were made by restoring power to the electrical bus, the unit was restarted and returned to 100 percent RTP on August 9, 2021. On September 19, 2021, the unit was down powered to 70 percent RTP to perform a rod pattern adjustment and turbine valve testing, and the unit returned to 100 percent RTP on September 21, 2021, following completion of those activities. The unit operated there for the remainder of the inspection period.
Unit 2 began the inspection period at 100 percent RTP. On September 11, 2021, the unit was down powered to 70 percent RTP to perform a rod pattern adjustment and turbine valve testing, and the unit was returned to 100 percent RTP the same day. The unit operated there for the remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident and regional inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time, the resident inspectors performed periodic site visits each week, increasing the amount of time on-site as local COVID-19 conditions permitted.
As part of their on-site activities, resident inspectors conducted plant status activities as described in IMC 2515, Appendix D; conducted routine reviews using IP 71152, Problem Identification and Resolution, observed risk significant activities; and completed on-site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or a portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on-site. The inspections documented below met the objectives and requirements for completion of the IP.
REACTOR SAFETY
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Alignment of the Unit 2 residual heat removal (RHR) system following a pump operability test the previous day, using 34SO-E11-010-2, on July 21, 2021.
- (2) Alignment of the Unit 1 plant service water (PSW) system following 1B PSW pump motor replacement, using 34SO-P41-001-1, on July 30, 2021.
- (3) Alignment of the Unit 1 core spray (CS) system, 'A' Loop, during CS loop 'B' valve operability test, using 34SO-E21-001-1, on August 17, 2021.
- (4) Alignment of the Unit 1 CS system, 'A' Loop, during loop 'B' pump operability test, using 34SO-E21-001-1, on August 18, 2021.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Unit 1 standby gas treatment system room on July 14, 2021.
- (2) Unit 2 reactor core isolation cooling system room on July 15, 2021.
- (3) Unit 2 reactor building 158'/164' elevation on July 20, 2021.
- (4) Unit 1 and 2 intake structure on July 28, 2021.
- (5) Unit 1 and 2 emergency diesel generator (EDG) building on August 19, 2021.
- (6) Unit 1 and 2 control building 112' elevation, on August 20, 2021.
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)
The inspectors evaluated internal flooding mitigation protections in the:
(1)
- Unit 1 reactor building northwest control rod drive (CRD) compartment
- Unit 1 reactor building northeast residual heat removal (RHR) and core spray (CS) compartment
- Unit 1 reactor core isolation cooling (RCIC) southwest compartment
- Unit 1 high pressure core cooling (HPCI) compartment
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during a plant startup, following the forced maintenance outage on July 6, 2021. The inspectors observed non-critical heat-up due to a positive moderator coefficient, rod pull to criticality and to the point of adding heat, and observed the operating crew establish a controlled heat-up rate within technical specification limits.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated "License Operator Just in Time Training" (JITT) H-LOCT 21-026 "U1 MOC Startup," for one team during simulator training on July 1, 2021.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Sample)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) Review of the Unit 1 high pressure coolant injection (HPCI) system following failures of various HPCI components, on September 24, 2021.
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Unit 1 elevated risk due to the trip of the 1B PSW pump, from July 19 to July 30, 2021.
- (2) Unit 1 elevated risk following reactor trip and being in shutdown cooling, 31GO-OPS-024-0, Outage Safety Assessment dated August 4, 2021.
- (3) Unit 1 elevated risk due to unplanned inoperability of the 1C PSW pump, from August 26 to September 16, 2021.
- (4) Unit 1 elevated risk due to unplanned inoperability of the HPCI system due to HPCI discharge valve failing to open, from September 8 to September 10, 2021.
- (5) Unit 1 elevated risk due to limited condition of operation (LCO) extension for the 1C PSW pump, from 30 days to 45 days, September 21 to September 28, 2021.
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (7 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Condition Report (CR) 10810391, Unit 1 "B" Recirculation Discharge Valve did not close on demand on July 3, 2021.
- (2) CR 10812018, Unit 2 "A" Emergency Diesel Generator (EDG) Fuel Oil Transfer Pump seal leak of 0.5 to 1.0 GPM on July 12, 2021.
- (3) CR 10813948, Unit 1 "B" plant service water (PSW) pump trip on July 19, 2021.
- (4) CR 10817764, Unit 1 high pressure coolant injection (HPCI) main pump mechanical seal leak, inboard seal on August 3, 2021.
- (5) CR 10822020, Unit 1 "B" HPCI pump room cooler leak on August 25, 2021.
- (6) CR 10823851, Unit 1 "C" PSW pump foreign material analysis, effects on 1A and 1B PSW pumps on September 2, 2021.
- (7) CR 10827289, Unit 2 "A" EDG battery with cell 27 jar cracked through the side wall on September 15, 2021.
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Temporary modification to bypass air around solenoid valves 1N11-F036A and 1N11-F036B, as their failure would result in the loss of the steam jet air ejector on Unit 1 and result in a subsequent greater than 20 percent down power.
- (2) Permanent modification to the upper and lower seismic restraints on 1C PSW pump due to excessive contact with the pump column preventing proper alignment of the pump.
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:
- (1) NMP-ES-017-020, "MOV Electrical Checkout and Adjustments for SMB/SB Actuators," Version 6.5, and 34SV-B31-001-1, "Recirculation System Valve Operability," Version 7.10, following motor replacement of the 1B recirculation discharge motor operated valve on July 4, 2021.
- (2) 34SV-R43-002-1, "Diesel Generator 1B Monthly Test," Version 24.6, following the troubleshooting and replacement of the fuel oil filter differential pressure gage on July 14, 2021.
- (3) 34SV-P41-001-1, "Plant Service Water Pump Operability," Version 15.2, following the replacement of 1B plant service water pump motor on July 30, 2021.
- (4) 34SV-B31-001-1, "Recirculation System Valve Operability," Version 7.11, after replacement of fuse clips in the valve breaker for 1B31-F031B discharge valve for 'B' recirculation loop, on August 5, 2021.
- (5) SNC1171149, Functional test of auto transfer time delay relay for turbine building switchgear 1R23S021, following relay replacement on August 6, 2021.
- (6) 34SV-P41-001-1, "Plant Service Water (PSW) Pump Operability," Version 15.2, following the replacement of 1C PSW pump on September 28, 2021.
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (2 Samples)
- (1) The inspectors evaluated forced outage activities on Unit 1, due to turbine building temperatures switches causing half group I signals on the A2 channel, from June 30, 2021 to July 6, 2021.
- (2) The inspectors evaluated forced outage activities on Unit 1, caused by a reactor scram resulting from a loss of normal feed water, from August 3 to August 8, 2021.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) 34SV-R43-012-2, "Diesel Generator 1B 24 Month Operability Test," Version 8.1, on
===August 11, 2021.
Inservice Testing (IP Section 03.01) (1 Sample)===
- (1) 34SV-E11-001-1, "Residual Heat Removal Pump Operability IST," Version 30.1, on July 15, 2021.
71114.06 - Drill Evaluation
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
The inspectors evaluated:
- (1) Licensed reactor operators respond to a Reactor Scram with Anticipated Transient Without a Scram (ATWS) in the simulator and observed the crew make an emergency declaration and notification. This represented a drill and exercise performance opportunity on July 6,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS06: Emergency AC Power Systems (IP Section 02.05) ===
- (1) Unit 1 (July 1, 2020-June 30, 2021)
- (2) Unit 2 (July 1, 2020-June 30, 2021)
MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)
- (1) Unit 1 (July 1, 2020-June 30, 2021)
- (2) Unit 2 (July 1, 2020-June 30, 2021)
MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)
- (1) Unit 1 (July 1, 2020-June 30, 2021)
- (2) Unit 2 (July 1, 2020-June 30, 2021)
71152 - Problem Identification and Resolution
Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) The 1D residual heat removal service water pump (RHRSW) failure caused by the pump shaft seizing to the mechanical seal box in the discharge head.
- (2) Inoperability of 2D residual heat removal (RHR) pump due to inadequate maintenance procedural instructions for recoupling pump and motor.
71153 - Follow Up of Events and Notices of Enforcement Discretion Event Followup (IP Section 03.01)
- (1) The inspectors evaluated the Unit 1 reactor scram caused by loss of normal reactor feed water and licensees response on August 3, 2021.
- (2) The inspectors evaluated the unplanned inoperability of the 1C PSW pump caused by the shaft shearing, on August 26,
INSPECTION RESULTS
Inoperability of 2D Residual Heat Removal (RHR) Pump Due to Inadequate Maintenance Procedural Instructions for Recoupling Pump and Motor Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71152 Systems NCV 05000366/2021003-01 Open/Closed A self-revealing Green non-cited violation of Unit 2 Technical Specification (TS) 5.4.1(a) was identified for the licensees failure to incorporate adequate maintenance procedural instructions for the recoupling of the residual heat removal (RHR) pump and motor as recommended by Regulatory Guide (RG) 1.33, section 9.a. Specifically, procedure 52PM-E11-003-2, RHR Pump and Motor Maintenance, Version 9.4 did not contain instructions to verify the tightness of the motor coupling nut set screws in 2D RHR pump to prevent the pump shaft downward movement within the pump, thus causing pump failure and pump inoperability.
Description:
On April 16, 2021, the 2D RHR Pump was operating in torus cooling mode and after approximately 10 minutes of pump operation, an overcurrent annunciator OVLD/Lockout Relay trip was received. The annunciator response procedure was entered, the 2D RHR pump was manually secured, and TS LCO 3.5.1 A(1) was subsequently entered. After initial troubleshooting, another pump run was attempted that resulted in an automatic pump trip.
Following the second attempted pump run, the 2D RHR pump was disassembled, and the first stage impeller was found bound to the suction head wear ring. During the pump repair, the mechanics working on the mechanical seal observed that the motor coupling nut set screws were loose. The design/intent of the set screws is to hold the motor coupling nut stationary. Due to these set screws being loose during each pump start, the combination of shaft loading/unloading on the nut caused significant torque leading to the coupling nut loosening. During the nut loosening process from each start, the pump shaft moved downward within the pump. This caused the first stage impeller to come in contact (rub) with the suction head wear ring and resulted in it grinding/cutting into the wear ring. The binding together of the impeller and wear ring caused the overcurrent in the motor that resulted in the overcurrent annunciator OVLD/Lockout Relay trip seen in the control room.
The motor for 2D RHR pump was replaced on March 4, 2019. At the time, the motor coupling was disconnected, and the licensee failed to ensure the set screws were tightened down as required. The cause of the improper maintenance was inadequate procedural guidance for the process of tightening the motor half coupling nut set screws. During the creation of the maintenance procedure 52PM-E11-003-2 in 1991, information from the vendor manual pertaining to a referenced General Electric (GE) Service Information Letter (SIL) #417, was not transferred from the RHR Pump maintenance vendor manual to the new pump maintenance procedure. GE SIL #417 was provided to Plant Hatch on January 14, 1985. The SIL was a warning to affected utilities that the motor half coupling nut could loosen and lead to pump failure if the set screws were not installed and tightened properly. The licensee responded to GE SIL #417 by revising the vendor manual SX27070 with an As Built Notice (ABN), however failed to transfer this information over to their revised procedure in 1991.
Corrective Actions: The licensee entered this pump failure event into their corrective action program. The licensee repaired 2D RHR pump by properly reinstalling/tightening the motor coupling set screws and by replacing the pump rotating assembly/suction head. Additionally, the licensee verified the clearance between the mechanical seal gland plate and collar on all remaining Ingersoll Rand Pumps met requirements and no movement of the coupling nuts had occurred to other similar pumps. The licensee also revised their procedure 52PM-E11-003-2, incorporating instructions to apply thread-locker to coupling nut set screws and to ensure they were properly tightened to reduce the likelihood of this type of event occurring again.
Corrective Action References: Condition reports (CRs) 10791097 and 10801317; technical evaluations (TE) 1090830, 1090831, 1090832, 1090833, 1090834 and 1090835 corrective action report (CAR) 279192.
Performance Assessment:
Performance Deficiency: The failure to provide appropriate procedures, instructions, or drawings for maintenance that could affect the performance of safety-related equipment per TS 5.4.1 and Regulatory Guide 1.33 was a performance deficiency. Specifically, there were no instructions or drawings to verify the tightness of the motor coupling nut set screws to prevent shaft downward movement within the pump.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the 2D RHR pump failed due to incorrect maintenance by the licensee when they failed to tighten the motor half coupling nut with set screws, resulting in an out of service time for the pump greater than its normal TS outage limit.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The affected cornerstone was Mitigating Systems, as determined by Inspection Manual Chapter (IMC) 0609, 4, Initial Characterization of Findings. Utilizing IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, the performance deficiency required a detailed risk evaluation because the degraded condition represented a loss of the PRA function of one train of a multi-train TS system for greater than its TS allowed outage time.
A regional Senior Reactor Analyst (SRA) conducted a detailed risk evaluation using the guidance in IMC 0609 Appendix A and the Risk Assessment Standardization Project (RASP)
Handbook. The SRA modelled the condition using the Hatch Unit 1&2 SPAR model version 8.58 dated February 28, 2017, and SAPHIRE 8 Version 8.2.3. The exposure period was divided into two periods. First, the 10-day period from the last run of the 2D RHR pump on April 13, 2021 until April 22, 2021, when the one-time emergency TS amendment was approved and the second from April 22, 2021, until the 2D RHR pump was declared operable on April 29, 2021. During the second period, the compensatory actions required by the emergency TS were credited. The issue was modelled as a failure to start of the 2D RHR pump, due to the failure mechanism failure to run was not considered. The dominant accident sequences included several fire scenarios and a loss of condenser heat sink event with a failure of RHR, late injection and containment venting functions. For the first 10-day period, risk was determined to be 5.042E-7 core damage events per year. For the final seven-day period, the risk was 4.482E-8 core damage events per year. Thus, total risk for the exposure period was 5.49E-7 core damage events per year, which makes this a finding of very low safety significance (Green).
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
Enforcement:
Violation: Hatch Unit 2 Technical Specification 5.4.1.(a) Procedures, states, in part, that written procedures shall be implemented covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, February 1978. Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), Appendix A, Paragraph 9.a, Procedures for Performing Maintenance, requires that maintenance that can affect the performance of safety-related equipment should be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.
Contrary to the above, on March 4, 2019, maintenance procedure 52PM-E11-003-2 did not provide procedures, instructions, or drawings regarding 2D RHR pump motor replacement that were appropriate to the circumstances. Specifically, there were no instructions or drawings to verify the tightness of the motor coupling nut set screws to prevent shaft downward movement within the pump.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On October 19, 2021, the inspectors presented the integrated inspection results to Sonny Dean and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.04 Corrective Action 10750927,
Documents 10805421
Drawings H-16331 Unit 1 Core Spray P&ID 38.0
H-26014 RHR System P&ID Sheet 1 65.0
H-26015 RHR System P&ID Sheet 2 60.0
Procedures 34SO-E11-010-2 Residual Heat Removal System 44.5
34SO-E21-001-01 Core Spray System 24.8
34SO-P41-001-1 Plant Service Water System 36.19
34SV-E21-001-01 1E21C001B ISI Core Spray Pump Operability 24.1
34SV-E21-002-1 1E21 B Loop Core Spray Valve Operability 12.5
Work Orders SNC1112235
SNC1112410
71111.05 Corrective Action CR10814348 07/20/2021
Documents
Resulting from
Inspection
Fire Plans Drawing A-34965, Unit 2 Reactor Core Isolation Cooling Pump and Turbine 3.0
Sheet 100 Room
Drawing A-43965, Unit 1 Standby Gas Treatment Room 4.0
Sheet 66
NMP-ES-035-019- U2 Reactor Building EL 158/164 1.0
GL01-F31
NMP-ES-035-019- Diesel Generator Building El. 130 Fire Plan 1.0
GL02-F06
NMP-ES-035-019- Intake Structure 1.0
GL02-F07
NMP-ES-035-019- Pre-Fire Plan for Control Building 112 elevation 1.0
GL2-F01
71111.06 Miscellaneous HNP-1-FSAR Sections 5.2.1, 5.6.1, 5.6.3, 6.4.1 and Figure 4.10-5 24/35/19
Procedures 34AB-T22-003-1 Secondary Containment Control 5.18
34AB-T23-001-1 Loss Of Primary Containment Control 1.3
34AB-T23-004-1 Torus Water Level 1.2
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.12 Corrective Action CAR278906
Documents Condition Reports 10729060, 10729502, 10733510, 10733807, 10749660,
10751450, 10760865, 10760867, 10761652, 10761654,
10761877, 10766527, 10766528, 10766900, 10771285,
10786252, 10786424, 10788442, 10797061, 10804276,
10804392, 10805177, 10805246, 10805833, 10805897,
10705977, 10805981, 10806069, 10806554, 10817164,
10817776, 10818273, 10818320, 10818432, 10822785,
10823876, 10825511, 10825758, 10825818, 10826236,
10826251, 10826278
Miscellaneous E41- 01- High Provide Adequate Core Coolant for Small Pipe Breaks that
Pressure Coolant do Not Rapidly Depressurize the Reactor During a Design
Injection Basis Accident
E41- 02- High Provide Alternate RPV Control Functions During EOP
Pressure Coolant Implementation
Injection
Procedures 34SO-E41-001-1 High Pressure Coolant Injection (HPCI) System 30.4
Work Orders SNC1171081
71111.13 Miscellaneous NL-21-0852 Evaluation of Risk Impact and Compensatory Measures 09/21/2021
S-2021-06 Implementation of Compensatory and Risk Management 09/21/2021
Controls for Technical Specification 3.7.2, Regarding One-
Time Extension of Completion Time for 1C PSW Pump
Procedures 31GO-OPS-024-0 Outage Safety Assessment 4.1
NMP-OS-010-002 Hatch Protected Equipment Logs 11.1
71111.15 Corrective Action 10817764 08/03/2021
Documents 10818432 08/05/2021
10822020 08/22/2021
Corrective Action 10822886 08/25/2021
Documents
Resulting from
Inspection
Engineering #308164 Station battery Cell Cracked - Indian Point Unit 3 10/09/2013
Evaluations #318147 Black Start Peaker Battery Cell Case Cracked - Fermi 08/01/2015
Inspection Type Designation Description or Title Revision or
Procedure Date
- 324296 Battery Failure Due to Crack Cell - Indian Point Unit 2 08/24/2016
- 413848 Maintenance Discovers Crack in Safety Related Battery - 09/12/2017
Grand Gulf
Miscellaneous Email from 2A EDG Battery Jumper 09/22/2021
Electrical
Maintenance
Supervisor
Email from 2A EDG Battery 2R42-S002A Cell Operability 09/22/2021
Engineering
Supervisor
Operability 2-08-02 Unit 1 and Unit 2 HPCI Mechanical Seal Leak
Evaluations NMP-AD-012-F01 Operability Determination Support Basis - 1B HPCI Room 08/25/2021
Cooler
Procedures 34SV-E41-002-1 HPCI Pump Operability 33.2
Work Orders SNC372604
71111.18 Drawings A11015, Sheet 1 Edwin I. Hatch Nuclear Plant Unit 1 Seismic Restraints 5.0
Plant Service Water
SNC1163136TCC1 2.0
SNC1163136TCC2 2.0
SNC1163136TCC3 2.0
SNC1163136TCC4 2.0
SNC1163136TCC5 2.0
Engineering Design Equivalent 1P41C Upper Seismic Restraint Alignment 09/06/2021
Changes Change Package
SNC1176825
SNC11631136 TCC to Bypass Air Around Solenoid Valves on 1N11-F036A 06/15/2021
and 1N11-F036B
SNC1163136 TCC to Bypass Air Around Solenoid Valves on 1N11-F036A 01
and 1N11-F036B
Miscellaneous IP-ENG-001 Nuclear Industry Standard Process Engineering - Standard 2
Design Process (EB-17-06)
NDE Reports 51GM-MNT-065-0 Weld Process Control Sheet-ASME Safety Class Welds 09/08/2021
Procedures 52PM-P41-036-1 Unit 1 Plant Service Water Pump & Motor Major 9.6
Inspection/Overhaul
Inspection Type Designation Description or Title Revision or
Procedure Date
NMP-AD-008-F01 Applicability Determination 07/01/2021
NMP-AD-008-F01 Applicability Determination 06/15/2021
NMP-AD-010-F01 10 CFR 50.59 Screening 06/15/2021
NMP-AD-010-F01 10 CFR 50.59 Screening 07/01/2021
NMP-ES-025-002 Quality Control Inspection Planning 2.0
NMP-ES-035-006- Fire Protection Program Impact Screen for SNC1163136 7.0
F05
NMP-OS-003-F01 Operational Decision-Making Issue Worksheet 07/09/2021
Work Orders SNC1177052 Perform Modification of 1P41C001C -Upper Pump seismic 09/08/2021
restraint
71111.19 Corrective Action 10818216 08/05/2021
Documents 10878391 08/05/2021
Corrective Action CR10830501
Documents CR10830511
Resulting from CR10830519
Inspection CR10830530
Procedures 34SV-B31-001-1 Recirculation System Valve Operability (8/5/2021) 7.11
2PM-P41-036-1 Unit 1 Plant Service Water Pump and Motor Major 9.5
Inspection/Overhaul
NMP-MA-014 Post Maintenance Testing/Post Modification Testing 2.3
NMP-MA-014-001 Post Maintenance Testing Guidance 5.7
NMP-MA-019 Bolting and Torque Guidelines 5.1
Work Orders SNC1166472
SNC844572 1B Plant Service Water Motor replacement 07/29/2021
71111.20 Miscellaneous Unit 1 Forced Outage List 08/06/2021
SRO Event Report Unit 1 Low Reactor Water Level Automatic Scram Due to
21-01 Dual Reactor Feed Pump Trip (8/3/2021)
Procedures 31-GO-OPS-010-0 Scram / Transient Analysis (8/3/2021 Scram) 7.6
2PM-MEL-026-0 MICROVERSA Trip Plus (MVT+) Overcurrent Trip Units 9.4
NMP-RE-008-F01 Detailed Reactivity Management Plan 08/04/2021
71114.06 Miscellaneous LORP Scenario H- Loss of Control Rod Drive flow, 2C Plant Service Water 06/21/2021
LT-AF-00116 pump trip, Reactor Feed Pump High Vibrations, ATWS, and
Recirculation Pump Seal Failure.
Inspection Type Designation Description or Title Revision or
Procedure Date
71152 Corrective Action 10741430
Documents 10791097 04/16/2021
CAR279192 07/15/2021
Engineering TE 1090830
Evaluations TE 1090831
TE 1090832
TE 1090833
TE1057091
TE1090049
TE1090900
TE1091056
71153 Corrective Action 10817773,
Documents 10818433,
10818435
Drawings H-13367 Single Line Diagram 120/208V, Station Switchgear 1A 32
Sheet 1 of 2
H-13367 Single Line Diagram 120/208V, Station Switchgear 1A 20
Sheet 2 of 2
H-13384 Elementary Diagram 600V and 208V Station Service 24
16