IR 05000321/2012007

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IR 05000321-12-007; February 27 to March 2, 2012; Edwin I. Hatch Nuclear Plant Unit 1; Post Approval Site Inspection for License Renewal, Phase 1
ML12089A130
Person / Time
Site: Hatch Southern Nuclear icon.png
Issue date: 03/29/2012
From: Vias S
NRC/RGN-II/DRS/EB3
To: Madison D
Southern Nuclear Operating Co
Linda Gruhler 404-997-4614
References
IR-12-007
Download: ML12089A130 (17)
v • d • e


Text

March 29, 2012

SUBJECT:

EDWIN I. HATCH NUCLEAR PLANT - NRC POST-APPROVAL SITE

INSPECTION FOR LICENSE RENEWAL, INSPECTION REPORT

05000321/2012007

Dear Mr. Madison:

On March 2, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed a Post-Approval Site Inspection for License Renewal at your Edwin I. Hatch Nuclear Plant, Unit 1, in accordance with NRC Inspection Procedure (IP) 71003. The enclosed report documents the inspection results, which were discussed on March 2, 2012, with Mr. W. L. Bargeron, Plant Manager, and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations, and with the conditions of your license. The inspectors reviewed selected procedures and records, observed plant activities, and interviewed personnel.

Based on the inspection sample selected for review, no findings were identified. The inspectors identified two observations associated with the implementation of one-time inspections for two Aging Management Programs (AMPs). These observations consisted of issues of concern that, if found during the period of extended operation (PEO), would be characterized as performance deficiencies in the NRC Reactor Oversight Process. These observations are subject to further NRC inspection during the second phase of IP 71003 to provide reasonable assurance that your license renewal commitments are met. However, the inspectors determined that the overall implementation of AMPs activities reviewed during the Unit 1 refueling outage was consistent with the license renewal commitments.

In accordance with 10 CFR 2.390 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

SNC, Inc.

the NRC Public Document Room or from the Publicly Available Records System (PARS)

component of NRC's Agencywide Documents Access and Management System (ADAMS),

accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Steven J. Vias, Chief

Engineering Branch 3

Division of Reactor Safety

Docket Nos. 50-321 License Nos. DPR-57

Enclosure:

NRC Post-Approval Site Inspection For License Renewal, Inspection Report 05000321/2012007 w/Attachment: Supplemental Information

REGION II==

Docket Nos:

50-321

License Nos:

DPR-57

Report No:

05000321/2012007

Licensee:

Southern Nuclear Operating Company, Inc.

Facility:

Edwin I. Hatch Nuclear Plant, Unit 1

Location:

Baxley, Georgia 31513

Dates:

February 27 to March 2, 2012

Inspectors:

J. Rivera-Ortiz, Senior Reactor Inspector (Lead)

B. Collins, Reactor Inspector

Approved by:

Steven J. Vias, Chief

Engineering Branch 3

Division of Reactor Safety

SUMMARY OF FINDINGS

IR 05000321/2012007; February 27 to March 2, 2012; Edwin I. Hatch Nuclear Plant Unit 1; Post

Approval Site Inspection for License Renewal, Phase 1.

The report covers an inspection conducted by two regional inspectors in accordance with NRC Manual Chapter 2515 and NRC Inspection Procedure 71003.

Based on the sample selected for review, the inspectors determined that commitments, license conditions, and regulatory requirements associated with the renewed facility operating license were met. The inspectors also determined that the licensee had administrative controls in place to ensure completion of pending actions scheduled both prior and during the period of extended operation (PEO).

The inspectors identified two observations associated with the implementation of one-time inspections for two Aging Management Programs (AMPs). These observations consisted of issues of concern that, if found during the PEO, would be characterized as performance deficiencies in the NRC Reactor Oversight Process. The licensee entered all observations into the stations Corrective Action Program (CAP) for evaluation and resolution.

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.

NRC-Identified

and Self-Revealed Findings

None

Licensee-Identified Violations

None

REPORT DETAILS

OTHER ACTIVITIES

4OA5 Other Activities

.1 Post-Approval Site Inspection for License Renewal - IP 71003 (Phase 1)

a. Inspection Scope

(1) Implementation of License Conditions and Commitments, including Aging Management Programs

The inspectors reviewed a sample of license renewal activities scheduled for the Unit 1 spring 2012 refueling outage, which was the second-to-last outage prior to the period of extended operation (PEO). The inspectors selected this refueling outage because it would present the best opportunity to observe the majority of the one-time inspections associated with license renewal commitments. The inspections objective was to maximize observations of the actual implementation of license renewal activities before the beginning of the PEO (August 7, 2014), and verify that the licensee completed the necessary actions to:

(a) comply with the conditions stipulated in the renewed facility operating license;
(b) meet the license renewal commitments described in NRC Memorandum dated March 6, 2007, (ADAMS Accession Number ML070640041), and
(c) meet the future inspection activities described in the Updated Final Safety Analysis Report (UFSAR) supplement submitted pursuant to 10 CFR 54.21(d). The license renewal application (LRA) for Edwin I. Hatch Nuclear Plant and the corresponding NRC Safety Evaluation Report (SER) documented in NUREG-1803 are publicly available on ADAMS under accession numbers ML003688151, and ML020020307, respectively.

The inspectors reviewed supporting documents; conducted interviews with licensee staff; observed in-process outage activities; and performed visual inspection of structures, systems, and components (SSCs) including those not accessible during power operation. The commitment items and AMPs selected for the inspection sample are summarized below based on their description in Appendix A of the LRA. The specific inspection activities conducted for each AMP are also described below. Specific documents reviewed are listed in the report attachment.

Commitment Item 6 - Galvanic Susceptibility Inspections:

The LRA described the Galvanic Susceptibility Inspections as a new AMP that would provide for condition monitoring via one-time inspections to provide objective evidence that galvanic susceptibility is being managed for specific components within the scope of license renewal. The first one-time inspections would consider the more corrosive raw water environment and include a sample population of carbon-to-stainless-steel weld connections that should exhibit the largest electrochemical potential difference among the existing galvanic couples. The inspection samples would be expanded to other water systems if the examined carbon-to-stainless welds show galvanic corrosion. The inspection of in-scope components would use one or more examination methods, which may include ultrasonic thickness determinations, radiographic testing, depth gauges, and pipe removal and analysis. These one-time inspections would be performed prior to the beginning of the PEO of each Unit.

The inspectors reviewed licensing basis documents, AMP administrative procedures, and implementing inspection and test procedures to verify that the program was developed as described in the LRA and corresponding SER. The inspectors also discussed the process used to select the inspection samples under this AMP and the criteria to be used for scope expansion with licensee personnel. The inspectors reviewed the examination reports listed below to verify that the implementation of the program was in accordance with the established procedures and consistent with the program attributes described in the licensing basis documents.

Dissimilar Metal Welds in Component 1P41N002 (Service Water System)

1E11F103A (Residual Heat Removal(RHR)/Low Pressure Coolant

Injection (LPCI) System)

Commitment Item 7 - Treated Water Systems Piping Inspection Program:

The LRA described the Treated Water Systems Piping Inspections (TWSPI) as a new AMP that would provide for condition monitoring via one-time examinations intended to provide objective evidence that existing chemistry control is managing aging in piping that is not examined under another inspection program. This AMP would examine a sample population of carbon and stainless steel tubing and piping in the treated water systems. The expansion of inspection points and the subsequent examination of in-scope components would depend on the results of the initial inspections. The inspections would be conducted using various techniques including, but not be limited to, volumetric or destructive examination. The specific sample population, examination methods, and acceptance criteria would be defined in the inspection and trending procedures. These one-time inspections would be performed prior to the PEO of each Unit.

The inspectors reviewed licensing basis documents, AMP administrative procedures, implementing inspection and test procedures, and inspection records to verify that the program was developed as described in the LRA, and the corresponding SER. The inspectors also discussed the process used to select the inspection samples under this AMP, and the criteria to be used for scope expansion with licensee personnel.

Additionally, the inspectors directly observed licensee personnel during the execution of the one-time inspections listed below to verify that the implementation of the program was in accordance with the established procedures and consistent with the program attributes described in the licensing basis documents.

Inspection of Minimum Flow Bypass Check Valve 1E51F021 and

Connecting Piping up to MOV 1E51F019 (Reactor Core Isolation Cooling

(RCIC) System)

Modification (RHR/LPCI System)

Restricting Orifice and Piping (Core Spray System)

1E51D003 Steam Supply Steam Trap in RCIC Room (RCIC System)

E51D005 Minimum Flow Bypass Restrictive Orifice (RCIC System)

Inboard Steam Isolation Valve 1E41F003/F002 (High Pressure Coolant

Injection (HPCI) System)

1G11B001 Inlet (Radwaste System)

1 (Reactor Building Closed Cooling Water System)

Commitment Item 8 - Gas Systems Component Inspections:

The LRA described the Gas Systems Component Inspections as a new AMP that would provide for condition monitoring via one-time condition monitoring aging management activities designed to provide objective evidence that the aging effects predicted for systems with gases as internal environments are being adequately managed. The scope of this program would include susceptible locations in several systems within the scope of license renewal. The inspection activities will use examination techniques designed to ascertain whether significant loss of material or cracking has occurred in the sample population. These one-time inspections would be performed prior to the beginning of the PEO of each Unit.

The inspectors reviewed licensing basis documents, AMP administrative procedures, and implementing inspection and test procedures to verify that the program was developed as described in the LRA and the corresponding SER. The inspectors also discussed with licensee personnel the process used to select the inspection samples under this AMP and the criteria to be used for scope expansion. Additionally, the inspectors directly observed licensee personnel during the execution of the one-time inspections listed below to verify that the implementation of the program was in accordance with the established procedures and consistent with the program attributes described in the licensing basis documents.

Cap/Inspect 1E41F123B Test Valve (HPCI System)

Commitment Item 11 - Residual Heat Removal Heat Exchanger Augmented Inspection and Testing Program:

The LRA described the residual heat removal (RHR) Heat Exchanger Augmented Inspection and Testing Program as a new condition monitoring program that would provide enhanced aging management of both the shell and tube sides of the Unit 1, and Unit 2 RHR heat exchangers. The RHR heat exchangers would be visually inspected, and eddy current testing would be done on a regular basis. This inspection program would be implemented prior to the beginning of the PEO of each Unit.

The inspectors reviewed licensing basis documents, AMP administrative procedures, and implementing inspection and test procedures to verify that the program was developed as described in the LRA and the corresponding SER. Additionally, the inspectors discussed with the license the preliminary eddy current inspection results for the Unit 1 RHR-1A heat exchanger inspection, conducted during the Unit 1 spring 2012 outage, and reviewed the final report for the Unit 1 RHR-1B heat exchanger eddy current inspection, completed in 2006, to verify that the implementation of the program was in accordance with the established procedures and consistent with the program attributes described in the licensing basis documents.

Flow Accelerated Corrosion Aging Management Program:

The LRA described the Flow Accelerated Corrosion (FAC) Program as an enhanced AMP designed to monitor pipe wear in those systems that have been determined to be susceptible to FAC-related loss of material. The susceptibility of piping to FAC would be predicted using a computer model specifically developed for FAC analysis. The FAC model would predict FAC rates in piping, and calculates the time remaining until reaching the defined critical wall thickness. The detection of wall thinning would include various examination methods such as Ultrasonic testing (UT), Radiographic testing (RT),and visual examinations. The enhanced examination methods and frequencies would be based on industry and plant specific operating experience as opposed to computer modeling. Examinations to detect erosion, erosion-corrosion, as well as FAC, would be performed as part of the enhanced program. For both units, the FAC Program would be expanded to include additional piping for certain systems that are already included in the current program. For Unit 2 only, portions of the radioactive decay hold-up volume (main steam and steam line drains, and condensate drains) will also be included. These program enhancements would be implemented prior to the beginning of the PEO of each Unit.

The inspectors reviewed licensing basis documents, AMP administrative procedures, and implementing inspection and test procedures to verify that the program was developed as described in the LRA and the corresponding SER. The inspectors also discussed the criteria for scope expansion for an UT examination of component 1-MSD-10 with licensee staff. The examination of 1-MSD-10 revealed wall thinning indications during the Unit 1 spring 2012 outage requiring scope expansion. Additionally, the inspectors directly observed and reviewed the final examination report for the UT examination of component 1-MSD-14, which was selected as a result of the scope expansion from 1-MSD-10. The inspectors reviewed these activities to verify that the implementation of the program was in accordance with the established procedures and consistent with the program attributes described in the licensing basis documents.

Boiling Water Reactor Vessel And Internals Aging Management Program:

The LRA described the Boiling Water Reactor Vessel and Internals Project (BWRVIP) as an existing AMP resulting from the association of utilities to focus on resolution of BWR vessel and internals issues. The BWRVIP Program inspection and evaluation reports would specifically address the reactor vessel components and reactor internals relative to the requirements of 10 CFR 54. The BWRVIP Program inspection and evaluation documents would provide for reactor pressure vessel (RPV) and reactor internals examination utilizing a combination of ultrasonic, visual, and surface methods, including pressure testing. The specific methods to be used and the frequency of examination would be in accordance with the applicable BWRVIP inspection and evaluation report, unless a specific exception is identified to the NRC. The BWRVIP inspection and evaluation reports applicable to Plant Hatch reactor assembly components would be:

The inspectors reviewed licensing basis documents, AMP administrative procedures, and implementing inspection and test procedures to verify that the program was developed as described in the LRA and the corresponding SER. Additionally, the inspectors reviewed final examination data sheets, and portions of the corresponding digital video disks (DVDs), for the visual examinations of the reactor vessel internal components listed below, to verify that the implementation of the program was in accordance with the established procedures, and consistent with the program attributes described in the in the licensing basis documents.

  • RPV Interior Surfaces - Component ID: RPV Int 045-090 deg (DVD 31)
  • Jet Pump Riser Welds - Component ID: JP 16 RS-2 (DVD 17)
  • Steam Dryer Vertical Partition Welds - Component ID: Bank 3 to 2

Vertical Partition Weld 3 (DVD 4)

  • Steam Dryer Horizontal Welds - Component ID: Upper Horizontal Hood 5

Weld (DVD 01)

(2) Review of License Renewal Commitment Changes

The inspectors identified that no changes were made to the commitment items selected for review. The review of remaining license renewal commitment changes would be completed during the second implementation phase of inspection procedure 71003.

(3) Review of Newly-Identified SSCs

This inspection requirement would be completed during the second implementation phase of inspection procedure 71003.

(4) Review of the Description of AMPs and Time-Limited Aging Analysis (TLAA) in

the UFSAR Supplement

The review of the description of AMPs and TLAAs in the UFSAR supplement submitted pursuant 10 CFR 54.21(d) would be completed during the second implementation phase of inspection procedure 71003.

b. Findings and Observations

No findings were identified. The inspectors determined that the licensee met the license renewal commitments, license conditions, and applicable regulatory requirements for the inspection samples selected for review. The inspectors determined that the overall implementation of Aging Management Program activities reviewed during the Unit 1 spring 2012 refueling outage was consistent with the license renewal commitments. The inspectors also determined that the licensee had administrative controls in place to ensure completion of pending actions scheduled both prior and during the period of extended operation.

The inspectors identified the two observations described below, which if identified during the PEO, would be characterized as performance deficiencies, and processed in accordance with NRC Inspection Manual Chapter 0612, Power Reactor Inspection Reports. These observations are subject to follow-up inspection during the second implementation phase of inspection procedure 71003 to provide reasonable assurance that the license renewal commitments are met.

(1) Observation for Commitment Item 6, Galvanic Susceptibility Inspections

The inspectors identified that the licensee did not conduct a non-destructive examination (NDE) activity for WO SNC105364 in accordance with the administrative controls described in the UFSAR supplement for license renewal. The team identified that a radiographic examination performed under this WO was not fully prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances, in accordance with the applicable quality assurance controls described in the UFSAR supplement. Specifically, the licensee selected a radiographic examination method (i.e., digital radiography) which was not discussed in any of the implementing procedures for the Aging Management Program. While the selected method provided effective results to identify the aging effects of concern under this program, the activity was not performed following the quality assurance standards described in the UFSAR for license renewal activities. This issue had no impact on plant safety and the selected examination method was demonstrated to be effective in identifying the aging effects of concern.

The licensee entered this issue into the sites CAP as Condition Report (CR) 417114.

(2) Observation for Commitment Item 7, Treated Water Systems Piping Inspection

Program

The inspectors noted that one of the criteria for unacceptable relevant indications in implementing visual inspection procedure 42IT-QCX-006-0 of this AMP was, any corrosion or erosion that is judged to reduce the pressure retaining wall thickness by more than 10% before the end of the period of extended operation. Based on discussions with the licenses NDE examiners during field observations, the inspectors identified that the examiners were looking for actual indications of 10% or more in wall thickness reduction rather than indications that could reach the 10% wall reduction during the PEO. The inspectors determined that the examiners understanding of the inspection criterion for percentage of wall reduction was inconsistent with the criteria established in the implementing procedures for this AMP. Additionally, the implementing visual inspection procedure did not provide specific guidance for the examiners to identify what indications could reduce the pressure retaining wall thickness by more than 10% before the end of the PEO. This issue had no impact on plant safety and the selected examinations observed by the inspectors did not identify unacceptable relevant indications that would be affected by the misapplication of the 10% wall thickness criterion.

The licensee entered this issue into the sites CAP as CR 417115.

4OA6 Management Meetings

.1

Exit Meeting Summary

On March 02, 2012, the inspectors presented the inspection results to Mr. W. L.

Bargeron, Plant Manager, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

D. So, License Renewal Engineer
J. Hornbuckle, Materials Programs-Corporate
S. Tipps, Principal Licensing Engineer
W.L. Bargeron, Plant Manager

LIST OF REPORT ITEMS

Opened

None

Opened and Closed

None

Closed

None

DOCUMENTS REVIEWED

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