IR 05000321/2015008
| ML15364A265 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 12/30/2015 |
| From: | Ellis K M Reactor Projects Branch 7 |
| To: | Vineyard D R Southern Nuclear Operating Co |
| References | |
| IR 2015008 | |
| Download: ML15364A265 (14) | |
Text
December 30, 2015
Mr. David Vineyard Vice President Southern Nuclear Operating Company, Inc.
Edwin I. Hatch Nuclear Plant 11028 Hatch Parkway North Baxley, GA 31513
SUBJECT: EDWIN I. HATCH NUCLEAR PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000321/2015008 AND 05000366/2015008
Dear Mr. Vineyard :
On December 10, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution biennial inspection at your Edwin I. Hatch Nuclear Plant Units 1 and 2. The NRC inspection team discussed the results of this inspection with you and the other members of your staff. The inspection team documented the results of this inspection in the enclosed inspection report.
Based on the inspection samples, the inspectors determined that your staff's implementation of the corrective action program supported nuclear safety. In reviewing your corrective action program, the inspectors assessed how well your staff identified problems at a low threshold, your staff's implementation of the station's process for prioritizing and evaluating these problems, and the effectiveness of corrective actions taken by the station to resolve these problems. In each of these areas, the inspectors determined that your staff's performance was adequate to support nuclear safety.
The team also evaluated other processes your staff used to identify issues for resolution. These included your use of audits and self-assessments to identify latent problems and your incorporation of lessons learned from industry operating experience into station programs, processes, and procedures. The inspectors determined that your station's performance in each of these areas supported nuclear safety. Finally, the inspectors determined that your station's management maintains a safety-conscious work environment adequate to support nuclear safety. Based on the inspectors' observations, your employees are willing to raise concerns related to nuclear safety through at least one of the several means available. The NRC inspectors did not identify any findings or violations of more than minor significance.
D. Vineyard 2 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 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/ Kevin M. Ellis, Chief Reactor Projects Branch 7 Division of Reactor Projects
Docket No. 50-321, 50-366 License No. DPR-57 and NPF-5
Enclosure:
IR 05000321/2015008, 05000366/2015008
w/Attachment:
Supplementary Information cc Distribution via Listserv
SUMMARY OF FINDINGS
IR 05000321/2015008 and 05000366/2015008; November 16-20 - December 07-10, 2015; Hatch Power Station, Units 1 and 2; Biennial Inspection of the Problem Identification and
Resolution Program.
The inspection was conducted by one senior project inspector, a construction inspector, a health physicist, and a reactor inspector. No findings were identified. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 5.
Identification and Resolution of Problems The inspectors concluded that, in general, problems were properly identified, evaluated, prioritized, and corrected. The licensee was effective at identifying problems and entering them into the corrective action program (CAP) for resolution, as evidenced by the relatively few number of deficiencies identified by external organizations (including the NRC) that had not been previously identified by the licensee, during the review period. Generally, prioritization and evaluation of issues were adequate, formal root cause evaluations for significant problems were adequate, and corrective actions specified for problems were acceptable. Overall, corrective actions developed and implemented for issues were generally effective and implemented in a timely manner.
The inspectors determined that overall, audits and self-assessments were adequate in identifying deficiencies and areas for improvement in the CAP, and appropriate corrective actions were developed to address the issues identified. Operating experience usage was found to be generally acceptable and integrated into the licensee's processes for performing and managing work, and plant operations.
Based on discussions and interviews conducted with plant employees from various departments, the inspectors determined that personnel at the site felt free to raise safety concerns to management and use the CAP to resolve those concerns.
The NRC inspectors did not identify any findings.
REPORT DETAILS
4OA2 Problem Identification and Resolution
1. Corrective Action Program Effectiveness
a. Inspection Scope
The team reviewed the licensee's Corrective Action Program (CAP) procedures which described the administrative process for initiating and resolving problems primarily through the use of condition reports (CRs). To verify that problems were being properly identified, appropriately characterized, and entered into the CAP, the inspectors reviewed CRs that had been issued between October 2013 and October 2015, including a detailed review of selected CRs associated with the following risk-significant systems: Fire Protection, Primary Containment, 1E A/C Electrical. Where possible, the team independently verified that the corrective actions were implemented as intended. The team also reviewed selected common causes and generic concerns associated with root cause evaluations (RCE) to determine if they had been appropriately addressed. To help ensure that samples were reviewed across all cornerstones of safety identified in the Reactor Oversight Process (ROP), the team selected a representative number of CRs that were identified and assigned to the major plant departments, including quality assurance, health physics, chemistry, emergency preparedness and security. These CRs were reviewed to assess each department's threshold for identifying and documenting plant problems, thoroughness of evaluations, and adequacy of corrective actions. The team reviewed selected CRs, verified corrective actions were implemented, and attended meetings where CRs were evaluated for significance to determine whether the licensee was identifying, accurately characterizing, and entering problems into the CAP at an appropriate threshold. Plant walkdowns of equipment within the selected systems listed above and other plant areas were conducted by inspectors to assess the material condition and to identify deficiencies that had not been previously entered into the CAP. The inspectors reviewed CRs, maintenance history, corrective actions (CAs), completed work orders (WOs) for the systems, and reviewed associated system health reports. These reviews were performed to verify that problems were being properly identified, appropriately characterized, and entered into the CAP. Items reviewed generally covered a two-year period of time; however, in accordance with the inspection procedure, a five-year review was performed for selected systems for age-related issues. Control Room walk-downs were also performed to assess the main control room (MCR) deficiency list and to ascertain if deficiencies were entered into the CAP and tracked to resolution. Operator workarounds (OWA) and operator burden screenings were reviewed, and the inspectors verified compensatory measures for deficient equipment which were being implemented in the field. The inspectors conducted a detailed review of selected CRs to assess the adequacy of the root cause and apparent cause evaluations of the problems identified. The inspectors reviewed these evaluations against the descriptions of the problem described in the CRs and the guidance in licensee procedure NMP-GM-002-GL03, Cause Analysis Techniques Guideline.
The inspectors assessed if the licensee had adequately determined the cause(s) of identified problems, and had adequately addressed operability, reportability, common cause, generic concerns, extent-of-condition, and extent-of-cause. The review also assessed if the licensee had appropriately identified and prioritized corrective actions to prevent recurrence.
The inspectors reviewed selected industry operating experience (OE) items, including NRC generic communications, to verify that they had been appropriately evaluated for applicability and that issues identified through these reviews had been entered into the CAP.
The inspectors reviewed site trend reports, to determine if the licensee effectively trended identified issues and initiated appropriate corrective actions when adverse trends were identified.
The inspectors reviewed licensee audits and self-assessments, including those which focused on problem identification and resolution programs and processes, to verify that findings were entered into the CAP and to verify that these audits and assessments were consistent with the NRC's assessment of the licensee's CAP. The inspectors attended CR screening meetings and Management Review Committee (MRC) meetings to observe management oversight functions of the corrective action process.
Documents reviewed are listed in the Attachment.
b. Assessment Problem Identification The inspectors determined that the licensee was generally effective in identifying problems and entering them into the CAP and there was an appropriately low threshold for entering issues into the CAP. This conclusion was based on a review of the requirements for initiating CRs as described in licensee procedure NMP-GM-002, "Corrective Action," management's expectation that employees were encouraged to initiate CRs for any reason. Trending was generally effective in monitoring equipment performance. Site management was actively involved in the CAP and focused appropriate attention on significant plant issues. Based on reviews and walkdowns of accessible portions of the selected systems, the inspectors determined that system deficiencies were being identified and placed in the CAP.
Problem Prioritization and Evaluation Based on the review of CRs sampled by the inspection team during the onsite period, the inspectors concluded that problems were generally prioritized and evaluated in accordance with the licensee's CAP procedures as described in the CR significance determination guidance in NMP-GM-002-001, Corrective Action Program Instructions. Each CR was assigned a priority level at the CR screening meeting and adequate consideration was given to system or component operability and associated plant risk.
The inspectors determined that station personnel had conducted root cause and apparent cause analyses in compliance with the licensee's CAP procedures and assigned cause determinations were appropriate, considering the significance of the issues being evaluated. A variety of formal causal-analysis techniques were used depending on the type and complexity of the issue consistent with NMP-GM-002-GL03, Cause Analysis Techniques Guideline.
Corrective Actions Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the inspectors determined that overall, corrective actions were timely, commensurate with the safety significance of the issues, and effective, in that conditions adverse to quality were corrected and non-recurring. For significant conditions adverse to quality, the corrective actions directly addressed the cause and effectively prevented recurrence in that a review of performance indicators, CRs, and effectiveness reviews demonstrated that the significant conditions adverse to quality had not recurred. Effectiveness reviews for corrective actions to prevent recurrence (CAPRs) were sufficient to ensure corrective actions were properly implemented and were effective.
c. Findings
No findings were identified.
2. Use of Operating Experience
a. Inspection Scope
The team examined the licensee's use of industry OE to assess the effectiveness of how external and internal operating experience information was used to prevent similar or recurring problems at the plant. In addition, the team selected operating experience documents (e.g., NRC generic communications, 10 CFR Part 21 reports, licensee event reports, vendor notifications, and plant internal operating experience items, etc.), which had been issued since October 2013, to verify whether the licensee had appropriately evaluated each notification for applicability to the Hatch Nuclear Plant, and whether issues identified through these reviews were entered into the CAP.
b. Assessment Based on a review of selected documentation related to operating experience issues, the inspectors determined that the licensee was generally effective in screening operating experience for applicability to the plant. Industry OE was evaluated at either the corporate or plant level depending on the source and type of the document. Relevant information was then forwarded to the applicable department for further action or informational purposes. OE issues requiring action were entered into the CAP for tracking and closure. In addition, operating experience was included in all apparent cause and root cause evaluations in accordance with licensee procedure NMP-GM-002-GL03, Cause Analysis Techniques Guideline.
c. Findings
No findings were identified. 3. Self-Assessments and Audits
a. Inspection Scope
The team reviewed audit reports and self-assessment reports, including those which focused on problem identification and resolution, to assess the thoroughness and self-criticism of the licensee's audits and self-assessments, and to verify that problems identified through those activities were appropriately prioritized and entered into the CAP for resolution in accordance with licensee procedure NMP-GM-003, "Self-Assessments." b. Assessment The team determined that the scopes of assessments and audits were adequate. Self-assessments were generally detailed and critical, as evidenced by findings consistent with the inspector's independent review. The team verified that CRs were created to document areas for improvement and findings resulting from the self-assessments, and verified that actions had been completed consistent with those recommendations.
Generally, the licensee performed evaluations that were technically accurate.
c. Findings
No findings were identified.
4. Safety-Conscious Work Environment
a. Inspection Scope
During the course of the inspection, the team assessed the station's safety-conscious work environment (SCWE) through review of the stations Employee Concerns Program (ECP) and interviews with various departmental personnel. The team reviewed a sample of ECP issues to verify that concerns were being properly reviewed and identified deficiencies were being resolved and entered into the CAP when appropriate.
b. Assessment Based on the interviews conducted and the CRs reviewed, the inspectors determined that licensee management emphasized the need for all employees to identify and report problems using the appropriate methods established within the administrative programs, including the CAP and ECP. These methods were readily accessible to all employees.
Based on discussions conducted with a sample of plant employees from various departments, the inspectors determined that employees felt free to raise issues, and that management encouraged employees to place issues into the CAP for resolution. The inspectors did not identify any reluctance on the part of the licensee staff to report safety concerns.
c. Findings
No findings were identified.
4OA6 Meetings, Including Exit
On December 10, 2015, the inspectors presented the inspection results to you and other members of the site staff. The inspectors confirmed that proprietary information was not provided or examined during the inspection.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- B. Anderson, Health Physics Manager
- G. Brinson, Maintenance Director
- T. Beckworth, ECP Coordinator
- B. Bowers, Engineering
- T. Canady, Fleet Procedures
- L. Capeles, System Engineer AC
- B. Coleman, back-up Site CAP Coordinator
- J. Collins, Regulatory Affairs Supervisor
- M. Dowd, Performance Improvement
- D. Hodge, QA/Lead Auditor
- S. Hodgins, Chemistry (CAPCO)
- G. Johnson, Regulatory Affairs Manager
- M. Keating, Primary Containment Engineer
- P. Linebarger, Planning Supervisor
- K. Long, Operations Director
- J. Major, Regulatory Affairs Engineer
- R. May, Radiation Protection (CAPCO)
- L. Mikulecky, Site CAP Coordinator
- C. Outler, Training Support Manager
- B. Osterbuhr, License Renewal Engineer
- C. Prandini, Regulatory Affairs Engineer
- L. Sweeney, Nuclear Security Coordinator
- J. Stevenson, System Engineer AC
- K. Underwood, CAP Manager
- C. Varaadop, Engineering CAPCO
- D. Vineyard, Hatch Vice President
- A. Wheeler, Site Projects Manager
NRC personnel
- S. Sandal, Chief, Branch 2, Division of Reactor Projects
- K. Ellis, Chief, Branch 7, Division of Reactor Projects
- D. Hardage, Senior Resident Inspector
LIST OF REPORT ITEMS
Opened and Closed
None
Closed
- None
Discussed
None
LIST OF DOCUMENTS REVIEWED
Procedures:
- 50AC-MNT-001-0, Maintenance Program, Version 34
- 2CM-MME-067-0, Corrective Maintenance Procedure, Version 3.8
- 2GM-B21-005-0, Main Steam Safety Relief Valve Maintenance, Version 24 52PM-P41-036-1, unit 1 Plant Service Water Pump and Motor Major Inspection Overhaul, Version 7.0 62RP-RAD-016-0, Control of High Radiation Areas, Ver. 34.1
- 2RP-RAD-019-0, Radiation Protection Start-Up Surveillance, Ver. 10.0
- 2RP-RAD-060-0, Posting of High Radiation Areas for Backwash, Resin Transfers, and Deccants, Ver. 5.0
- NMP-AD-025, Quality Assurance and Non-Quality Assurance Records Administration, Version 4.0
- NMP-CH-016, Chemistry Instrument and Equipment Program, Ver. 6.0
- NMP-EP-303, Drill and Exercise Standards, Version 16.1
- NMP-HP-301, Airborne Radioactivity Sampling and Evaluation, Ver. 3.3
- NMP-MA-012-003, Maintenance Standards and Expectations, Version 3.2
- NMP-GM-002, Corrective Action Program, Versions 12.1 - 13.2
- NMP-GM-002-001, Corrective Action Program Instructions, Versions 31.1 - 34.0
- NMP-GM-002-006, Root Cause Analysis Instruction, Version 9.1
- NMP-GM-002-GL03, Cause Analysis Techniques Guideline, Versions 1.0 - 5.0
- NMP-GM-003, Self-Assessment and Benchmark Procedure, Version 21
- NMP-GM-003-001, Self-Assessment Instructions for Focused Area Self-Assessment (FASA), Version 4.1
- NMP-GM-006, Work Management, Version 13.3
- NMP-GM-006-GL01, Work Planning, Packaging, and Closure, Version 29.1
- NMP-GM-008, Operating Experience Program, Version 15.1
- NMP-GM-016-F01, Management Review Committee (MRC) Charter, Version 3.0
- NMP-GM-024, Nuclear Safety Culture Program, Version 5.0
- NMP-GM-024-001, Nuclear Safety Culture Monitoring and Review Process, Version 6.0
- NMP-MA-012-003, Maintenance Standards and Expectations, Version 3.2
- NOS-105, Internal Nuclear Oversight Audit, Version 5.2
- OPS-1820, Outside Rounds Inside Fence, Version 67.5
- OPS-1820-PAF57.0, Procedure Approval Form for Version 57.0 for Unit One Outside Rounds Inside Fence Corrective Action Records (CAR):
- 174876,
- 193574,
- 194208,
- 191694,
- 193381,
- 193406,
- 196541,
- 206404,
- 254954,
- 257799,
- 256367,
- 208379,
- 255917,
- 213201,
- 256305,
- 256298,
- 212691,
- 207762,
- 211274,
- 207396,
- 208030,
- 208293,
- 208324,
- 208892,
- 208968,
- 209134,
- 209139,
- 209179,
- 209962,
- 209699,
- 209067,
- 201591,
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- 215120,
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- 210031,
- 208216,
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- 210675,
- 210278,
- 208639,
- 213201,
- 256852,
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- 255701,
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- 210675,
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- 249078,
- 249581,
- 254874,
- 255395,
- 255610,
- 257282,
- 257283,
- 257284,
- 764385
Condition Reports
(CR):
- 105972,
- 110191,
- 110497,
- 207762,
- 209132,
- 344291,
- 356926,
- 396706,
- 458817,
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- 10039688,
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- 10036361,
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- 2000009263
- Technical Evaluations (TE): 71212,
- 253357,
- 253616,
- 289675,
- 314258,
- 361463,
- 564135,
- 671512,
- 665021,
- 694492,
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Work Orders
(WO): 99870,
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- 111108,
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- 10106145,
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- 10017677,
- 10000636,
- 1000341301,
- 2100176301,
- 2070423601
- Other Documents: 2013 Excellence Assessment report
- AFR882668/213201, Closure Review for Fleet Licensing Audit 2015 BOS Training Sheet 13-18
- Calculation
- SMNH-05-009,
- Calculation
- SCNH-99-415, Evaluate the Seismic Qualification of Switchgear 1R23-S004, Version 1
- Calculation
- SCNH-13-095, Seismic Licensing Basis Evaluation of Switchgear for Fukushima NTTF Recommendation 2.3:Seismic Walkdown Inspection, Version 1 Check-in Self-Assessment Plan and Report, 2013
- Commitment SNC2008 Emergency Preparedness Commitment SNC19274 Emergency Preparedness Commitment SNC23597 Emergency Preparedness Commitment SNC23627 Emergency Preparedness Commitment SNC23630 Emergency Preparedness
- DCP 109109770, Discipline 001 Worksheet (for perimeter)
- DCP 109109860, Discipline 001 Worksheet (for multiplexer)
- Daily Status Meeting Hatch Security 4-20-15
- DOEJ-HX-750731-C001v4 Engineering Evaluations
- DOEJ-HX-750731-C001v3 Engineering Evaluations
- DOEJ-HX-35281-C001 Engineering Evaluations Edwin I. Hatch Nuclear Plant Appendix J Program Health Report - 3rd Quarter 2015
- Fleet-EP-2015, Final Audit Report Fleet-CAP-2014, Nuclear Oversight Audit for Corrective Action Program Fleet-DC-2013, Nuclear Oversight Audit for Document Control Fleet-DCM-2015, Nuclear Oversight Audit of Engineering Design Fleet-EP-2015, Nuclear Oversight Audit for Emergency Preparedness Fleet-LIC-2015, Nuclear Oversight Audit for Licensing Fleet-MRO-2015, Nuclear Oversight Audit for Medical Review Officers Focused Area Self Assessment Plan and Report 2014-02-24 Focused Area Self Assessment Plan and Report 2014-06-30 Job Aid, S-5 Camera Right Monitor, 5/6/15
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