IR 05000321/2018011

Nuclear Regulatory Commission Team Inspection Report 05000321/2018011 and 05000366/2018011

ML18264A038
Person / Time
Site:	Hatch
Issue date:	09/21/2018
From:	Shane Sandal Reactor Projects Region 2 Branch 6
To:	Vehec T Southern Nuclear Operating Co
References
IR 2018011
Download: ML18264A038 (12)

Text

September 21, 2018

SUBJECT:

EDWIN I. HATCH NUCLEAR PLANT - NUCLEAR REGULATORY COMMISSION TEAM INSPECTION REPORT 05000321/2018011

AND 05000366/2018011

Dear Mr. Vehec:

On August 23, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Edwin I. Hatch Nuclear Plant Units 1 and 2. The NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

The inspection examined activities conducted under your license as they relate to the implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders (EA-12-049 and EA-12-051) and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, your compliance with the Commissions rules and regulations, and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and records, observation of activities, and interviews with station personnel.

The NRC inspectors did not identify any finding or violation of more than minor significance.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding. If you have any questions, please contact me at 404-997-4513.

Sincerely,

/RA/

Shane Sandal, Chief Reactor Projects Branch 6 Division of Reactor Projects

Docket Nos.: 50-321, 50-366 License Nos.: DPR-57 and NPF-5

Enclosure:

IR 05000321/2018011, 05000366/2018011

Inspection Report

Docket Numbers:

50-321, 50-366

License Numbers:

DPR-57, NPF-5

Report Numbers:

05000321/2018011 and 05000366/2018011

Licensee:

Southern Nuclear Operating Company, Inc.

Facility:

Edwin I. Hatch Nuclear Plant

Location:

Baxley, Georgia

Inspection Dates:

August 20 - 23, 2018

Inspectors:

R. Rodriguez, Senior Project Engineer (Team Leader)

S. Sanchez, Senior Reactor Inspector

J. Hickman, Resident Inspector

D. Mas-Penaranda, Project Engineer

Approved By:

S. Sandal, Chief

Reactor Projects Branch 6

Division of Reactor Projects

SUMMARY

The NRC continued monitoring licensees performance by conducting Temporary Instruction (TI) 2515/191, Implementation of Mitigation Strategies and Spent Fuel Pool (SFP)

Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, inspection (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18191B074) at Edwin I. Hatch Nuclear Plant Units 1 and 2, 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

No findings or violations of more than minor significance were identified.

Additional Tracking Items

Type Issue number Title Report Section Status TI TI 2515/191 Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans Other Activities Closed

TABLE OF CONTENTS

INSPECTION SCOPE

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

INSPECTION RESULTS

..............................................................................................................

EXIT MEETINGS AND DEBRIEFS

............................................................................................ 6

DOCUMENTS REVIEWED

.......................................................................................................... 7

INSPECTION SCOPE

Inspections were conducted using the appropriate portions of Temporary Instruction (TI)

procedure 2515/191, Implementation of Mitigation Strategies and Spent Fuel Pool (SFP)

Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose

Assessment Plans, (ADAMS Accession No. ML18191B074). Documents reviewed by

inspectors are listed in the documents reviewed section of this report. 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.

OTHER ACTIVITIES - TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

TI 2515/191 - Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool

Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose

Assessment Plans

Inspectors verified plans for complying with NRC Orders EA-12-049, Order Modifying

Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis

External Events, (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML12056A045) and EA-12-051, Order Modifying Licenses with Regard to

Reliable Spent Fuel Pool Instrumentation, (ML12054A679) were in place and were being

implemented by the licensee. Additionally, the inspection verified implementation of staffing and

communications information provided in response to the March 12, 2012, request for

information letter (ML12053A340) and dose assessment information provided per COMSECY-

13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons

Learned, dated March 27, 2013 (ML12339A262).

(1) Based on samples selected for review, the inspectors verified that the licensee

satisfactorily implemented appropriate elements of the Diverse and Flexible Coping

Strategies (FLEX) as described in the plant-specific submittals and the associated safety

evaluation (ML17179A286) and determined that the licensee is in compliance with NRC

Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation

Strategies for Beyond-Design-Basis External Events (ML12056A045). The inspectors

verified the licensee satisfactorily:

a) developed and issued FLEX Support Guidelines (FSGs) to implement the FLEX

strategies for postulated external events;

b) integrated their FSGs into their existing plant procedures such that entry into and

departure from the FSGs were clear when using existing plant procedures;

c) protected FLEX equipment from site-specific hazards;

d) developed and implemented adequate testing and maintenance of FLEX equipment

to ensure their availability and capability;

e) trained their staff to ensure personnel proficiency in the mitigation of

beyond-design basis events; and

f) developed the means to ensure the necessary off-site FLEX equipment would be

available from off-site locations.

(2) Based on samples selected for review, the inspectors verified that the licensee

satisfactorily implemented appropriate elements of the FLEX strategy as described in the

plant specific submittals and the associated safety evaluation (ML17179A286) and

determined that the licensee was in compliance with NRC Order NRC Order EA-12-

051, Order Modifying Licenses With Regard to Reliable Spent Fuel Pool

Instrumentation (ML12054A679). The inspectors verified that the licensee satisfactorily:

a) installed the spent fuel pool (SFP) instrumentation sensors, cabling and power

supplies to provide physical and electrical separation as described in the plant

specific submittals and safety evaluation;

b) installed the SFP instrumentation display in the location, environmental conditions

and accessibility as described in the plant-specific submittals;

c) trained their staff to ensure personnel proficiency with the maintenance, testing, and

use of the SFP instrumentation; and

d) developed and issued procedures for maintenance, testing and use of the reliable

SFP instrumentation.

(3) The inspectors reviewed information provided in the licensees dose submittal and in

response to the NRCs March 12, 2012, request for information letter (ML12053A340),

and verified that the licensee satisfactorily implemented enhancements pertaining to

Near-Term Task Force (NTTF) Recommendation 9.3 response to a large-scale natural

emergency event that results in an extended loss of all alternating current (ac) power

(ELAP) to all site units and impedes access to the site The inspectors verified the

following:

a) the licensee satisfactorily implemented required staffing changes to support a

ELAP scenario;

b) emergency preparedness (EP) communications equipment and facilities are

sufficient for dealing with a ELAP scenario; and

c) the licensee implemented dose assessment capabilities (including releases from

SFPs) using the licensees site-specific dose assessment software and approach.

The inspectors verified that noncompliances with requirements, and standards identified during

the inspection were entered into the licensee's corrective action program as appropriate.

INSPECTION RESULTS

No findings were identified.

EXIT MEETINGS AND DEBRIEFS

No proprietary information was retained by the inspectors or documented in this report.

On August 23, 2018, the inspectors presented the inspection results to Mr.

T. Vehec, Site Vice

President, and other members of the licensees staff.

DOCUMENTS REVIEWED

Condition Reports Initiated as a Result of the Inspection

10527657, FLEX bolt thread PMs

10527679, HNP NRC FLEX Audit Dome Material Conditions

10527695, NRC walkdown material condition West Cable way

10527914, HNP NRC FLEX Audit load shed walkdown comment

10528292, FLEX audit observed inconsistencies in circle slash methods for past PM work orders

10527700, Revise NMP-OS-019-059 to include location of tooling for emergency opening Dome

doors

10528430 FLEX Staffing Study did not document resources to obtain CST Level

10527184 NMP-OS-019-293 Procedure Enhancement

10527703 NRC Resident Walkdown material condition - FLEX Walkdown

10528253 HNP NRC FLEX Inspection walkdown comments - RB Roof Conditions

10528469 HNP Maintaining a Priority on FLEX

Procedures

31EO-FSG-003-2, FSG - ELAP (Extended Loss of AC Power), Ver. 3.1

NMP-EP-147, Offsite Dose Assessment, Ver. 2.1

NMP-OS-019-003, Security Support for Beyond Design Basis Events, Ver. 1.1

NMP-OS-019-013, Beyond Design Basis Equipment Unavailability Tracking, Ver. 3.0

NMP-OS-019-253, Hatch Unit C SIG-12, Mode 5 RPV Inventory Control, Ver. 2.2

NMP-OS-019-254, Hatch Unit C SIG-11, Critical Instrumentation, Ver. 3.0

NMP-OS-019-256, Hatch Unit C Initial Site Damage Assessment, Ver. 4.0

NMP-OS-019-257, Hatch Unit C Diesel Fuel Oil Transfer, Ver. 1.1

NMP-OS-019-258, Miscellaneous FLEX Equipment, Ver. 1

NMP-OS-019-259, Hatch Unit C SIG-9, Communications, Ver. 1.2

NMP-OS-019-261, Hatch Unit 1 SIG-1, 4160V Alternate Power, Ver. 2

NMP-OS-019-262, Hatch Unit C SIG -2, 600V Alternate Power Division 1, Ver. 6.2

NMP-OS-019-264, Hatch Unit 1 SIG-4, Reactor Pressure Vessel Makeup, Ver. 2.0

NMP-OS-019-266, Hatch Unit 1 SIG-6, Containment Integrity, Ver. 2.1

NMP-OS-019-268, Hatch Unit 1 SIG-8, Spent Fuel Makeup, Ver. 3.1

NMP-OS-019-270, Hatch Unit 1 SIG-10, Ventilation, Ver. 1.1

NMP-OS-019-281, Hatch Unit 2 SIG-1, 4160V Alternate Power, Ver. 2

NMP-OS-019-282, Hatch Unit C SIG -2, 600V Alternate Power Division 2, Ver. 6.2

NMP-OS-019-293, FLEX 600V Diesel Generator Operating Instruction, Ver. 1

NMP-OS-019-296, FLEX RapidCom Generator Operating Instructions, Ver. 1

NMP-OS-019-299, FLEX Light Tower Operating Instruction, ver. 1

NMP-ES-005, Scoping and Importance Determination for Equipment Reliability, Ver. 17.0

NMP-GM-038, Diverse and Flexible Coping Strategies (FLEX) Program, Ver. 2.0

NMP-GM-038-002, Hatch Nuclear Plant Diverse and Flexible Coping Strategies

(FLEX) Program Document, Ver. 3.0

NMP-MA-050, Work Package Preparation, Ver. 6.1

NMP-OM-002, Shutdown Risk Management, Ver. 5.0

31EO-FSG-003-1, FSG - ELAP (Extended Loss of AC Power, Ver. 2.0

34AB-G41-001-1, Loss of Fuel Pool Cooling, Ver. 6.6

34GO-OPS-007-0, Shutdown/Refueling Mode Preparation for Flex, Ver. 1.2

34GO-OPS-030-1, Daily Inside Rounds, Ver.33.1

57IT-G41-001-0, Flex Pool Level Sensors, Ver. 3.0

RapidRack 1X86E018 Functional Test and PM, Ver. 3.0

34IT-FLE-002-0, FLEX Storage Building Equipment Checks, Ver. 2

31EO-FSG-003-1, FSG - ELAP (Extended Loss of AC Power), Ver. 2.1

31EO-FSG-003-2, FSG - ELAP (Extended Loss of AC Power), Ver. 3.1

Drawings

D-11004, Edwin

I. Hatch Nuclear Plant Unit 1 P&ID - R.H.R Service Water Outside Building,

Ver. 43

H-21039, Edwin

I. Hatch Nuclear Plant Unit 2 P&ID - R.H.R Service Water, Ver. 48

Design Changes

DCP SNC467474, Unit 2 FLEX Alternate Power

DCP SNC467488, Unit 2 Flex Core Cooling

DCP SNC467489, Unit 2 FLEX Condensate Storage Tank

Condition Reports

10313397

10317995

10336555

10345427

10345429

10376424

10388441

10388459

10396083

10399336

10436501

10437237

10503233

10505569

10505570

10513860

274476

294000

10364690

10442844

10477543

10482391

10503233

10514374

10505569

10505570

10513860

256152

279510

10350442

10367864

10437236

10303704

10481351

10311058

10379670

10472446

10514717

10314760

10436989

10323081

10329317

Work Orders

SNC808521, 57IT-G41-001-0 Flex Pool Level Sensors, dated 12/2/16

SNC829784, 57IT-G41-001-0 Flex Pool Level Sensors, dated 1/23/18

SNC829789, 57IT-G41-001-0 Flex Pool Level Sensors, dated 12/7/17

SNC847511, FLEX Booster Pump Operational Inspection, dated 12/5/17

SNC889967, Flex Diesel Powered Lights, dated 6/11/18

SNC911773, Flex Booster Pump Inoperable, dated 1/5/18

SNC756506, FLEX PM : 600V FLEX Generator Operational Inspection, dated 12/6/2016

SNC846059, FLEX Support PM: 600V FLEX D/G Cable Trailer Functional Test & Inspection,

dated 12/4/2017

SNC846063, FLEX PM: 600V FLEX Diesel Generator Functional Test & Inspection, dated

2/8/2017

SNC847524, FLEX PM: 600V FLEX Generator Operational Inspection, dated 12/6/2017

SNC889973, FLEX Support PM: 600V FLEX D/G Cable Trailer Functional Test & Inspection,

dated 6/19/2018

SNC889977, FLEX PM: 600V FLEX Diesel Generator Functional Test & Inspection, dated

6/26/2018

SNC915082, 1 Year PM FLEX Mode 5 Core Cooling Pump Operational Inspection,

dated June 13, 2018

SNC821126, FLEX Support PM: RapidCase Communications Functional Test & Inspection,

dated 8/17/7

SNC822483, FLEX Support PM: RapidCom Communications Functional Test & Inspection,

dated 10/26/17

SNC84287, FLEX Support PM: RapidCase Communications Functional Test & Inspection,

dated 1/25/18

SNC857772, FLEX Support PM: RapidCom Communications Functional Test & Inspection,

dated 4/3/18

SNC887274, FLEX Support PM: RapidCase Communications Functional Test & Inspection,

dated 8/8/18

Other

NMP-GM-038-002, Hatch Nuclear Plant Diverse and Flexible Coping Strategies (FLEX)

Program Document, Ver. 3

NMP-GM-038, Diverse and Flexible Coping Strategies (FLEX) Program, Ver. 2

HNP-FLEX-2016-19, Hatch Nuclear Plant FLEX Verification and Validation Report, dated

2/27/2016

S76305, Report of Liquefaction Potential Assessment FLEX Dome Storage Building and Travel

Paths Hatch Nuclear Plant (HNP), date 10/3/2014

FHC-S-13-001/X1AR50, Procurement Specification for FLEX equipment Storage Building,

Ver. 1

SNC600781, Hatch FLEX dome infrastructure, Ver. 2

August 2018 NRC TI-191 Inspection Plant Hatch FLEX Overview Slides

DOEJ-HRSNC600781-C001, Evaluation of Tie-Downs for Equipment in the FLEX Storage

Building, Ver. 1.0

Diesel Fuel Supply Assurance Letter from Diversified Energy Supply, dated June 27, 2018

Edwin

I. Hatch Nuclear Plant, Units 1 and 2-Safety Evaluation Regarding Implementation of

Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders

EA-12-049 and EA-12-051, dated 8/4/17

Edwin

I. Hatch Nuclear Plant, Units 1 and 2-Notification of Full Compliance of Required Action

for NRC Order EA-12-051 Reliable Spent Fuel Pool Instrumentation, dated 2/13/17

Hatch Nuclear Plant FLEX Verification & Validation Report, dated 2/28/16

Safer Response Plan for Edwin

I. Hatch Nuclear Plant, dated 8/11/15

S-76305, Report of Liquefaction Potential Assessment for Flex Dome Storage Building and

Travel Paths Hatch Nuclear Plant, dated 10/3/14

SNC600781-05, Hatch Dome Infrastructure, dated 3/2/16