IR 05000321/2009007

IR 05000321-09-007, 05000366-09-007; on 10/19/2009 - 11/05/2009; Hatch Nuclear Plant, Units 1 & 2; Biennial Baseline Identification and Resolution of Problems Inspection

ML093380463
Person / Time
Site:	Hatch
Issue date:	12/04/2009
From:	Daniel Merzke Reactor Projects Branch 7
To:	Madison D Southern Nuclear Operating Co
References
IR-09-007
Download: ML093380463 (19)

Text

December 4, 2009

SUBJECT:

EDWIN I. HATCH NUCLEAR PLANT - NRC IDENTIFICATION AND RESOLUTION OF PROBLEMS INSPECTION REPORT 05000321/2009007 AND 05000366/2009007

Dear Mr. Madison:

On November 5, 2009, the U. S. Nuclear Regulatory Commission (NRC) completed a team inspection at your Edwin I. Hatch Nuclear Plant, Units 1 and 2. The enclosed report documents the inspection findings, which were discussed on November 5, 2009, with yourself and other members of your staff.

The inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, and 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 representative records, observations of plant equipment and activities, and interviews with personnel.

On the basis of the sample selected for review, there were no findings of significance identified during this inspection. The team concluded that in general, problems were properly identified, evaluated, and corrected. However, during the inspection, some examples of minor problems were identified, including conditions adverse to quality that were not being entered into the corrective action program, narrowly focused condition report evaluations, and corrective actions that were ineffectively tracked or had not occurred.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs document

SNC

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/

Daniel J. Merzke, Acting Chief

Reactor Projects Branch 7

Division of Reactor Projects

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

Enclosure:

Inspection Report 05000321/2009007 and 05000366/2009007

w/Attachment: Supplemental Information

REGION II==

Docket Nos:

50-321, 50-366

License Nos:

DPR-57, NPF-5

Report No:

05000321/2009007 and 05000366/2009007

Licensee:

Southern Nuclear Operating Company, Inc.

Facility:

Edwin I. Hatch Nuclear Plant, Units 1 & 2

Location:

11030 Hatch Pkwy N Baxley, Georgia 31513

Dates:

October 19, 2009 through November 5, 2009

Inspectors:

M. King, Senior Project Engineer (Team Leader)

E. Morris, Hatch Senior Resident Inspector G. Kolcum, Brunswick Resident Inspector D. Arnett, Project Engineer

Approved by:

Daniel J. Merzke, Acting Chief Reactor Projects Branch 7 Division of Reactor Projects

Enclosure

SUMMARY OF FINDINGS

IR 05000321/2009-007, 05000366/2009-007; 10/19/2009 - 11/05/2009; Hatch Nuclear Plant,

Units 1 & 2; Biennial Baseline Identification and Resolution of Problems Inspection.

The inspection was conducted by a senior project engineer, a senior resident inspector, a project engineer and a resident inspector. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

Identification and Resolution of Problems

The team concluded that, in general, problems were properly identified, evaluated, prioritized, and corrected. Generally, the threshold for initiating condition reports (CRs) was appropriately low, as evidenced by the types of problems identified and the large number of CRs entered annually into the Corrective Action Program (CAP). Employees were encouraged by management to initiate CRs. However, the team did identify some examples where plant issues were not appropriately entered into the CAP.

Generally, prioritization and evaluation of issues were consistent with the licensees CAP guidance, 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 timely, effective, and commensurate with the safety significance of the issues.

The team 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. The licensees operating experience (OE) usage was found to be generally acceptable and integrated into the licensees processes for performing and managing work, and plant operations. However, the team did identify two examples where the licensee did not evaluate the need to release external OE when defects in vendor supplied qualified components were identified.

Based on discussions and interviews conducted with plant employees from various departments, the inspectors determined that personnel at the site felt free to raise safety concerns to management and use the CAP to resolve those concerns.

NRC Identified and Self-Revealing Findings

None

Licensee Identified Violations

None

REPORT DETAILS

4OA2 Problem Identification and Resolution

a.

Assessment of the Corrective Action Program

(1) Inspection Scope

The inspectors reviewed the licensees CAP procedures which described the administrative process for initiating and resolving problems primarily through the use of 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 August 2007 and October 2009, including a detailed review of selected CRs associated with the following risk-significant systems: residual heat removal (RHR), RHR service water, station auxiliary DC power system, and reactor building heating, ventilation, air conditioning (HVAC). Where possible, the inspectors independently verified that the corrective actions were implemented as intended. The inspectors also reviewed selected common causes and generic concerns associated with root cause evaluations to determine if they had been appropriately addressed. To help ensure that samples were reviewed across all cornerstones of safety identified in the NRCs Reactor Oversight Process (ROP), the team selected a representative number of CRs that were identified and assigned to the major plant departments, including Operations, Maintenance, Engineering, Emergency Preparedness, Health Physics, Chemistry, and Security. These CRs were reviewed to assess each departments threshold for identifying and documenting plant problems, thoroughness of evaluations, and adequacy of corrective actions. The inspectors reviewed selected CRs, verified corrective actions were implemented, and attended meetings where CRs were screened for significance to determine whether the licensee was identifying, accurately characterizing, and entering problems into the CAP at an appropriate threshold.

The inspectors conducted plant walkdowns of equipment associated with the selected systems and other plant areas to assess the material condition and to look for any deficiencies that had not been previously entered into the CAP. The inspectors reviewed CRs, maintenance history, 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 26-month period of time; however, in accordance with the inspection procedure, a 5-year review was performed for selected systems for age-dependent issues.

Control room walkdowns were also performed to assess the main control room (MCR)deficiency list and to ascertain if deficiencies were entered into the CAP. Operator Workarounds and Operator Burden screenings were reviewed, and the inspectors verified compensatory measures for deficient equipment which were being implemented in the field.

The team 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 the licensees procedure, NMP-GM-002-GL03, Cause Determination 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 team 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 attended various plant meetings to observe management oversight functions of the corrective action process. These included corrective action program coordinators (CAPCO) meetings and the Management Review Meeting (MRM).

Documents reviewed are listed in the Attachment.

(2) Assessment

Identification of Issues

The team determined that the licensee was generally effective in identifying problems and entering them into the CAP and there was a 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 Program, management expectation that employees were encouraged to initiate CRs for any reason, a review of system health reports, the types of problems identified, and the large number of CRs entered annually into the CAP. Trending was generally effective in monitoring equipment performance. Site management was actively involved in the CAP and focused appropriate attention on significant plant issues. However, the team did identify the following examples of minor performance deficiencies where conditions adverse to quality were not entered into the CAP, contrary to procedure NMP-GM-002, Corrective Action Program. However, the inspectors determined these performance deficiencies were not findings of significance and not subject to enforcement action in accordance with the NRC's Enforcement Policy:

• The inspectors review of control room logs identified that on November 4, 2007, a Unit 1 RHR pump discharge check valve, 1E11-F031C, failed to reseat following a surveillance of the Unit 1 'C' RHR pump. The licensee failed to initiate a CR to document this failure. The operability of the RHR system was maintained when the operators briefly started the Unit 1 A RHR pump which successfully seated the 1E11-F031C check valve. Inspectors noted that the failure of this check valve to seat had been identified and documented in a previous CR and the repair was scheduled to occur the next day. The licensee initiated CR 2009110928 to address this issue.

• Inspectors identified that work to inspect and repair a Unit 1 RHR pump discharge check valve, 1E11-FO31A, which occurred on September 13, 2008, documented a condition where the disc size was different than expected and required vendor support to resolve. The licensee failed to initiate a CR to document the parts discrepancy. The licensee initiated CR 2009110561 to address this issue. This issue had no impact on the operability of the RHR system.

• Inspectors identified that several CRs had been written which documented electrolyte leakage from battery cells, 1A and 2B station service batteries and the 1A, 1B, 1C, and 2C diesel generator batteries, manufactured by C&D Technologies. The licensee recognized the extent of the condition in the system health report; however, the licensee failed to initiate a CR to document the widespread condition as an adverse trend in the CAP. The licensee initiated CR 209110573 to address this issue. This issue had no impact on the operability of the station service batteries or the diesel generator batteries.

Prioritization and Evaluation of Issues

Based on the review of audits conducted by the licensee and the assessment conducted by the inspection team during the onsite period, the team concluded that the licensee was generally effective in the prioritization and evaluation of identified problems.

Problems were generally prioritized and evaluated in accordance with the licensees CAP procedures as described in the CR severity level determination guidance in NMP-GM-002, Corrective Action Program. Each CR written was assigned a severity level at the CAPCO meeting, and adequate consideration was given to system or component operability and associated plant risk.

The team determined that the licensee had conducted root cause and apparent cause analyses in compliance with the site CAP procedures, and assigned cause determinations were appropriate considering the significance of the issues being evaluated. A variety of causal-analysis techniques were used depending on the type and complexity of the issue consistent with licensee procedure NMP-GM-002-GL03, Cause Determination Guideline. The licensee had performed evaluations that were technically accurate and of sufficient depth. The team further determined that operability, reportability, and degraded or non-conforming condition determinations had been completed consistent with the guidance contained in NMP-AD-012, Operability Determinations and Functionality Assessments for Resolution of Degraded and Nonconforming Conditions. However, the team did make the following observation in the area of prioritization and evaluation of issues:

• CR 2007107101 was initiated on July 24, 2007, for failure of the Unit 1 C RHR pump discharge check valve, 1E11-FO31C, to seat. The operability information documented in the CR concluded the valve was operable after corrective action was taken to reseat the valve and vent the system; however, the CR did not document that the system had become inoperable before the operators performed those corrective actions. By site CAP procedures, a determination of inoperability and entry into the associated technical specification action statement is a key factor in determining the appropriate severity level (SL) for CRs. In this case, the inspectors determined that, although the inoperability aspect was not considered in assigning a SL to this CR, the SL of the CR would not have changed and the licensee conducted the appropriate evaluation of the degraded condition. Inspectors also noted that compensatory actions which were put into place by Operations as a result of this degraded condition were performed outside of the CAP process (i.e., were not documented and tracked by the CR). The licensee initiated CR 2009110566 to address this issue.

Effectiveness of Corrective Actions

Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the team 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, all CRs, and effectiveness reviews demonstrated that the significant conditions adverse to quality had not recurred. Effectiveness reviews for corrective actions to prevent recurrence were sufficient to ensure corrective actions were properly implemented and were effective. However, the team did make the following observations in the area of effectiveness of corrective actions:

• Inspectors identified that CR 2008102274 contained three action items which established specific effectiveness review criteria as documented in the effectiveness review plan section of the root cause analysis. The three action items were subsequently consolidated into a single action item; however, one of the planned effectiveness review criteria of no event recurrence" was not retained or conducted.

This omission of recommended effectiveness review criteria represented a missed opportunity to ensure the intent of the root cause corrective action plan was met.

The licensee initiated CR 2009110171 to address this issue.

• A review of tagout records revealed that a corrective action for CR 2008102274 requiring tagout preparers to explicitly document assumptions on tagout cover sheets was not being implemented in practice. Inspectors did not identify any examples where the ineffective implementation of tagout preparation guidance significantly impacted operations or maintenance activities; however, this issue represented a missed opportunity for the licensee to identify an ineffective corrective action. The licensee initiated CR 2009111080 to address this issue.

(3) Findings

No findings of significance were identified.

b.

Assessment of the Use of Operating Experience (OE)

(1) Inspection Scope

The team examined licensee programs for reviewing industry operating experience and reviewed licensee procedure NMP-GM-008, Operating Experience Program, to assess the effectiveness of how external and internal operating experience data was handled 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 August 2007 to verify whether the licensee had appropriately evaluated each notification for applicability to the Hatch plant, and whether issues identified through these reviews were entered into the CAP. Documents reviewed are listed in the

.

(2) Assessment

Based on a review of documentation related to the review of OE issues, the team determined that the licensee was generally effective in screening OE for applicability to the plant. The inspectors verified for selected issues that industry OE was evaluated at either the corporate or plant level depending on the source and type of 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 each root cause evaluation reviewed by the inspectors in accordance with licensee procedure NMP-GM-002-GL03, Cause Determination Guideline. However, the team did make the following observation regarding the licensees use of OE:

• The inspectors identified two examples where the licensee missed an opportunity to evaluate the need to generate external OE when vendor supplied qualified components were determined to be deficient. The first example was a manufacturing defect associated with the lid-to-jar seal for the 1A and 2B station service batteries and the 1A, 1B, 1C, and 2C diesel generator batteries. The second example was a manufacturing defect affecting RHR pump discharge check valve seat tolerances. The licensee initiated CR 209110573 and CR 2009110603 to address this issue. Subsequent screening by the licensee concluded that neither of the issues above could have created a substantial safety hazard.

(3) Findings

No findings of significance were identified.

c.

Assessment of Self-Assessments and Audits

(1) 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 Assessment.

(2) 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 teams independent review. The team verified that CRs were created to document all 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. Site trend reports were thorough and a low threshold was established for evaluation of potential trends, as evidenced by the CRs reviewed that were initiated as a result of adverse trends.

(3) Findings

No findings of significance were identified.

d.

Assessment of Safety-Conscious Work Environment

(1) Inspection Scope

During normal interactions with plant employees during the course of this inspection, the inspectors informally interviewed plant personnel regarding their knowledge of the CAP at Hatch and their willingness to write CRs or raise safety concerns. The inspectors conducted interviews to develop a general perspective of the safety-conscious work environment at the site to determine if any conditions existed that would cause employees to be reluctant to raise safety concerns. The inspectors reviewed the licensees Concerns Program Procedure and interviewed the Concerns Coordinator.

Additionally, the inspectors reviewed a sample of employee concern issues which had been entered into the CAP to verify concerns were being properly reviewed and deficiencies were being resolved.

(2) Assessment

Based on the interviews conducted and the CRs reviewed, the team 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 concerns program. These methods were readily accessible to all employees. Based on discussions conducted with a sample of plant employees from various departments, the inspectors concluded 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.

(3) Findings

No findings of significance were identified.

4OA6 Meetings, Including Exit

On November 5, 2009, the inspectors presented the inspection results to Mr. Madison and other members of the site staff. The inspectors confirmed that proprietary information was not provided or examined during the inspection.

ATTACHMENT: SUPPPLEMENTAL INFORMATION

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

S. Bargeron - Plant Manager

T. Beckworth - Employee Concerns Program Coordinator

B. Bowers - System Engineer

S. Brunson - NSSS System Supervisor

C. Clark - Systems Engineer

C. Dixon - Corrective Action Supervisor

J. Dixon - Health Physics Manager

W. Holt - Outage & Scheduling Manager

B. Hulett - Site Design Engineering Manager

G. Johnson - Hatch Engineering Director

D. Madison - Hatch Site Vice President

R. Miller - Outage Scheduling Coordinator

J. Payne - Senior Plant Engineer

S. Soper - Engineering Support Manager

T. Spring - Acting Operations Manager

S. Tipps - Principal Licensing Engineer

K. Underwood - Performance Improvement Supervisor

R. Varnadore - Maintenance Manager

A. Wilcher - Systems Engineer

A. Wolf - Operations Superintendant

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Closed

None

Discussed

None