IR 05000424/1993017
| ML20057C200 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 09/07/1993 |
| From: | Balmain P, Brian Bonser, Skinner P, Starkey R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20057C196 | List: |
| References | |
| 50-424-93-17, 50-425-93-17, NUDOCS 9309280065 | |
| Download: ML20057C200 (17) | |
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UMTED STATES f
NUCLEAR REGULATORY COMMISSION y3
REGloN 11 g
S 101 MARtETTA STREET, N.W., SUITE 2900
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ij ATLANTA, GEORGIA 303L 0199
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Report Hos.:
50-424/93-17 and 50-425/93-17 l
Licensee: Georgia Power Company t
P. O. Box 1295 Birmingham, AL 35201 i
Docket Nos.:
50-424 and 50-425 License Nos.: NPF-68 and NPF-81
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Facility Name: Vogtle I and 2 Inspection Conducted: August 1, 1993 - August 21, 1993 Inspector:
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p B. R.'B'o&gnr, Senior Resident Inspector Date Signed Dok /
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<.,L R. D. Stirkey Resident Inspector Date Signed s
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oj.9.q 3 p r. L Resident inspector
~Date Signed
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Approved by:
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- /h!b A.
.A.
P. Skinner, Chief Date Signed
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Reactor Projects Section 3B Division of Reactor Projects SUMMARY Scope:
This routine, inspection entailed inspection in the following areas: plant operations, surveillance, maintenance, evaluation of licensee self-assessment capability, Employee Concerns Program and follow-up of open items.
Results:
One non-cited violation (NCV) was identified.
The NCV was attributable to personnel error due to the failure to properly coordinate the replacement of a' pressurizer pressure transmitter and failure to use procedures. The event placed an unnecessary challenge on the reactor protection system and caused a plant transient (paragraph 7.a.).
An annual review was completed on the functioning of the Plant Review Board and the Safety Audit Engineering Review group.
For those areas examined, both organizations were determined to be effectively performing their appropriate functions (paragraphs 5.a. and 5.b.).
9309280065 930908 PDR ADOCK 05000424 G
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REPORT DETAILS 1.
Persons Contacted Licensee Employees i'
- J. Beasley, General Manager Nuclear Plant
- R. Brown, Supervisor Operations Training
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S. Bradley, Reactor Engineering Supervisor W. Burmeister, Manager Engineering Support
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- S. Chesnut, Manager Engineering Technical Support
- C. Christiansen, SAER Supervisor
- W. Copeland, Supervisor Materials.
C. Coursey, Maintenance Superintendent
- R. Dorman, Manager Training and Emergency Preparedness
- W. Dunn, Operations Unit Superintendent
- G. Frederick, Manager Maintenance
- W. Gabbard, Nuclear Specialist, Technical Support
- M. Griffis, Manager Plant Modifications
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M. Hobbs, I&C Superintendent
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K. Holmes, Manager Operations
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- D. Huyck, Nuclear Security Manager
- W. Kitchens, Assistant General Manager Plant Support
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R. LeGrand, Manager Health Physics and Chemistry
- G. McCarley, ISEG Supervisor
- R. Moye, Plant Engineering Supervisor
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- M. Seepe, Health Physics Radwaste Supervisor
- M. Sheibani, Nuclear Safety and Compliance Supervisor C. Stinespring, Manager Administration
- J. Swartzwelder, Manager Outage and Planning Other licensee employees contacted included technicians, supervisors, engineers, operators, maintenance personnel, quality control inspectors, j
and office personnel.
Oglethorpe Power Company Representative
- T. Mozingo NRC Employees B. Bonser
- D. Starkey P. Balmain
- R. Mc Whorter
- Attended Exit Interview i
An alphabetical list of abbreviations is located in the last paragraph of the inspection report.
2.
Plant Operations - (71707)
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2.
Plant Operations - (71707)
a.
General i
The inspection staff reviewed plant operations throughout the
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reporting period to verify conformance with regulatory requirements, Technical Specifications, and administrative controls. Control logs, shift supervisors' logs, shift relief records, LCO status logs, night orders, standing orders, and clearance logs were routinely reviewed. Discussions were conducted with plant operations, maintenance, chemistry, health physics, engineering support and technical support personnel.
Daily plant status meetings were routinely attended.
Activities within the control room were monitored during shifts and shift changes. Actions observed were conducted as required by
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the licensee's procedures. The complement of licensed personnel on each shift met or exceeded the minimum required by TS. Direct observations were conducted of control room panels, instrumentation and recorder traces important to safety.
i Operating parameters were verified to be within TS limits. The inspectors also reviewed DCs to determine whether the licensee was
appropriately documenting problems and implementing corrective actions.
Plant tours were taken during the reporting period on a routine basis. They included, but were not limited to the turbine building, the auxiliary building, electrical equipment rooms, cable spreading rooms, NSCW towers, DG buildings, AFW buildings, and the low voltage switchyard.
During plant tours, housekeeping, security, equipment status and radiation control practices were observed. The inspector identified approximately 11 areas on the A level of the auxiliary building for both units where housekeeping was poor. These included an unsecured oxygen cylinder (supplies Unit 2B Containment Hydrogen monitor) and several instances where tools, t
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hoses and miscellaneous debris were left adjacent to safety-related equipment and/or in contaminated areas. The inspector informed the Shift Support Supervisor of these items.
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The inspectors verified that the licensee's health physics
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policies / procedures were followed. This included observation of HP practices and review of area surveys, radiation work permits, postings, and instrument calibration.
The inspectors-verified that the security organization was properly manned and security personnel were capable of performing their assigned functions.
Inspectors observed that persons and packages were checked prior to entry into the PA; vehicles were properly authorized, searched, and escorted within the PA; persons
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within the PA displayed photo identification badges; and personnel in vital areas were authorized.
b.
Unit 1 Summary The unit reached 100% power on August 1, following recovery from a reactor trip which occurred on July 28. The unit operated at full i
power throughout the remainder of the inspection period.
c.
Unit 2 Summary The unit began the period operating at full power and operated at full power until August 20 when the unit began to coastdown as i
expected prior to the 2R3 refueling outage scheduled to begin on September 10. The unit ended the period at approximately 96%
i power and was coasting down at approximately 1% power per day.
No violations or deviations were identified.
3.
Surveillance Observation (61726)
Surveillance tests were reviewed by the inspectors to verify procedural and performance adequacy. The completed tests reviewed were examined for necessary test prerequisites, instructions, acceptance criteria, technical content, data collection, independent verification where required, handling of deficiencies noted, and review of completed work.
The tests witnessed, in whole or in part, were inspected to determine
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that approved procedures were available, equipment was calibrated, prerequisites were met, tests were conducted according to procedure, test results were acceptable and systems restoration was completed.
SVRVEILLANCE NO.
TITLE 14410-2 Control Rods Monthly Operability Test No violations or deviations were identified.
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Maintenance Observation (62703)
a.
General
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The inspecters observed maintenance activities, interviewed personnel, and reviewed records to verify that work was conducted
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in accordance with approved procedures, TSs, and applicable
industry codes and standards. The inspectors also verified that
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redundant components were operable, administrative controls were followed, clearances were adequate, personnel were qualified,
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correct replacement parts were used, radiological controls were proper, fire protection was adequate, adequate post-maintenance
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testing was performed, and independent verification requirements were implemented. The inspectors independently verified that selected equipment was properly returned to service.
Outstanding work requests were reviewed to ensure that the licensee gave priority to safety-related maintenance activities.
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The inspectors witnessed or reviewed the following maintenance activities:
MWO NOS.
WORK DESCRIPTION 29302698 Troubleshoot Failure of Shutdown Bank B Group 2 Rods to Move During Monthly Operability Test 29302273 Perform 12 month PM calibration for Heat Trace Cabinet 21817U3001A t
b.
Unit 2 Rod Control System Failure On August 5, during the performance of surveillance procedure 14410-2, Control Rod Operability Test, the licensee identified that all four of the Group 2 rods in SDB B failed to move, as indicated on DRPI and the group demand step counters, when the rod bank was manually inserted. The procedure was being performed in accordance with TS 4.1.3.2, which requires that each rod not fully inserted into the core shall be determined to be operable by movement of at least 10 steps in any one direction on a monthly basis.
Following the failure of SDB B Group 2 rods to move, the licensee entered the LC0 Action Statement for TS 3.1.3.lc, Movable L
Control Assemblies Group Height.
The inspector reviewed this failure to determine if it was similar
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to a recent rod control system failure event at another nuclear plant related to the slave cycler, which is documented in NRC GL 93-04 and IN 93-46. The licensee's troubleshooting isolated the failure to the 2BD slave cycler portion of the rod control system.
The licensee replaced both slave cycler binary counter cards and determined that the failure occurred due to failure of these cards. The event documented in the GL and IN involved the failure of a slave cycler decoder card. The inspector determined that this failure was not associated with recent rod control system failures which are discussed in the GL and IN, since the failures involved different circuit cards.
Following the circuit board replacement the licensee completed the
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rod operability surveillance and exited LC0 2-93-191 at 2:45 a.m.
on August 6.
No violations or deviations were identifie '
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5.
Evaluation of Licensee Self-Assessment Capability (40500)
The objective of this inspection was to evaluate the effectiveness of the licensee's self assessment programs. The inspection of the areas below focused on determining whether the licensee's self assessment programs contributed to the prevention of problems by monitoring and i
evaluating plant performance, and providing assessments and findings, and communicating and following up on corrective action recommendations.
a.
Review of Plant Review Board The inspector observed and reviewed the functioning of the PRB.
The PRB serves as a review and advisory group to the plant general manager on all matters related to nuclear safety. The duties of r
the PRB are described in TS, the FSAR, and a plant administrative c
procedure. As part of this review, the inspector attended several PRB meetings, reviewed minutes from past meetings, reviewed member and alternate member qualifications, and confirmed that open items identified by the PRB were tracked and resolved expeditiously.
The inspector determined that the PRB is meeting the requirements as set forth in TS with respect to composition, duties, meeting frequency, responsibilities.
The inspector concluded that the PRB is performing its function of providing a safety review of appropriate material and advising the plant manager.
b.
Review of Safety Audit and Engineering Review During this inspection period, the inspector reviewed the organization and activities of the onsite Safety Audit and Engineering Review group. The review included verification of
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training and qualification for lead auditors and verification that TS required audits are performed within the required intervals.
There are currently eight qualified lead auditors on the SAER staff.
During the last NRC review of SAER, documented in NRC IR 424,425/92-12, an observation was made that the SAER staff lacked experience in the Health Physics area.
Since that time the SAER organization gained a' member who has an SR0 license and Health Physics manager experience and an additional member with
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maintenance experience.
The inspector reviewed the " Record of Lead Auditor Qualification" documentation and the most recent Annual SAER Training Evaluation and Status review for each of the eight Qualified onsite lead auditors and determined that the lead auditors were qualified in
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accordance with the requirements of Southern Nuclear Vogtle
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Project procedure VSAER-WP-09, Safety Audit and Engineering Review Qualification of Auditors, and ANSI N45.2.23-1978, Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants. During review of procedure VSAER-WP-09, the inspector identified three minor discrepancies where administrative i
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requirements of ANSI N45.2.23-1978 were not incorporated in the procedure. The inspector informed the SAER supervisor of these discrepancies.
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audit reports to verify that audits were conducted in accordance
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with TS 6.4.2.8, Audits. The inspector verified that audits were performed for activities at the required frequencies for areas
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speci fied by TS 6.4.2.8.a., b., c., e., and f.
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No violations or deviations were identified.
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6.
Employee Concerns Program (TI 2500/028)
The inspector, as directed by TI 2500/028, reviewed the licensee's
Employee Concerns Program (the Vogtle program addressed by the TI is
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called the Quality Concerns Program). This program provides employees who wish to raise safety issues an alternate. path (other than their supervisor or normal line management) to express those concerns, and encourages employees to come forward with their concerns without fear of retribution. The inspector discussed the QCP with the site Quality Concerns Coordinator and reviewed procedure VSAER-WP-25, Quality Concerns Program, which describes implementation of the program.
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Specific questions, required by TI 2500/028, and the answers to those questions as they relate to the Vogtle QCP, are provided as Attachment I to this inspection report.
t No violations or deviations were identified.
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Follow-up (90712)-(92700) (92701) (92702)
I The Licensee Event Reports and follow-up items listed below were reviewed to determine if the information provided met NRC requirements.
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The determination included:
adequacy of description, verification of TS compliance and regulatory requirements, corrective action taken, existence of potential generic problems, reporting requirements satisfied, and relative safety significance of. each event.
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(Closed) URI 424/93-16-01, Review Causes of Pressurizer Low
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Pressure Reactor Trip.
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The URI was opened to allow completion of a review of the causes of the Unit I reactor trip on July 28, 1993. The automatic trip occurred when pressure dropped in a pressurizer instrument sensing l
line while I&C technicians were returning a pressure transmitter
to service. The pressure in the sensing line, which is also
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shared with another pressurizer pressure transmitter, dropped low
enough to fulfill the 2 of 4 logic for a reactor trip.
The inspectors concluded after review of the event and the
licensee's investigation into this event that the trip was caused
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by a failure of the I&C technicians to perform the necessary
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procedural steps to pressurize the sensing line and transmitter before opening the isolation valve to return IPT-457 to service.
Had the procedure been performed as written the pressure drop in the sensing line should not have occurred.
The technicians performing the work in the Unit I containment were not prepared for this task and were unaware of all the steps contained in the procedure. The licensee determined through their investigation that there were several contributing factors:
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job preparation did not include a review of the procedure by all the technicians; a briefing to discuss the risks associated with this work was not performed; the pre-job preparation did not ensure proper coordination of the technicians; the technicians were not in continuous communication; and the technicians in containment did not have a copy the procedure with them. As a i
result, the pressure transmitter isolation valve was opened without using the required steps in the procedure.
This event was significant because it placed an unnecessary challenge on the reactor protection system and caused a plant transient.
The inspector concluded that this event was attributable to personnel error due to the failure to properly coordinate the job and failure to use procedures in containment.
The licensee took prompt corrective action to address the personnel errors and work controls associated with this event.
This violation will not be subject to enforcement action because the licensee's efforts in identifying and correcting the violation meet the criteria specified in Section VII.B of the Enforcement Policy. This is identified as NCV 50-424/93-17-01, Pressurizer
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low Pressure Reactor Trip Due To Personnel Error.
Based on this review, the URI is closed, b.
(Closed) VIO 50-424/90-16-02, Failure To Develop Appropriate Procedures for Timely Closing of the Unit 1 Containment Equipment
Hatch.
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During subsequent refueling outages following the March 20, 1990, Site Area Emergency, maintenance personnel were trained on
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emergency hatch closure procedures and were stationed at the equipment hatch while it was open during RCS mid-loop operations.
Permanent design changes were implemented which enable the closure of the equipment hatch with or without electrical power.
Procedure 12008-C, Mid-Loop Operations, was written to integrate all mid-loop operating guidelines into one procedure and to state the conditions which must be met before the equipment hatch is permitted to remain open during periods of reduced RCS nventory.
Maintenance procedure 27505-C, Opening and Closing of the j
Containment Equipment Hatch, provides maintenance personnel i
specific instructions for the actual opening and closing of the o
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changes are now in place to e:;sure the timely closing of the equipment hatch following a loss of electrical power. This item is closed.
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(Closed) VIO 50-425/89-37-01, Failure to Perform Out of Calibra-tion Evaluations as Required by ANSI N45.2.4-1972.
i The licensee responded.to the violation in correspondence dated December 21, 1989. The violation involved a failure by the licensee to perform timely evaluations of the effects that out of calibration M&TE have on equipment that were calibrated using the -
out of calibration M&TE. Approximately 150 evaluations of out of calibration, lost or stolen M&TE were backlogged by the I&C
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department. Many of these were between one or two years old. The licensee's procedure in effect at the time did not have a timeliness requirement for completion of the evaluations. Also,
the status of the evaluations was not being tracked.
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The licensee has changed Procedure No. 00208-C, Control of
Measuring and Test Equipment, to include a timeliness requirement i
for performing evaluations of out of calibration, lost, or stolen
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M&TE.
The latest revision of the procedure required that evalua-
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tions be completed within 90 days. The status of all evaluations was tracked.
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The inspector reviewed the process for closeout of evaluations
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that were not completed within the 90 day time period. The pro-
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cess was effective in tracking and ensuring the timely resolution of evaluations.
-i Based on this review of the licensee's corrective actions, this
ite,n is closed.
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d.
(Closed) IFI 50-425/89-37-02, Incorporation of Unit 2 Installed Technical Specification Verification Instrumentation into a
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Calibration Program
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Prior to the Unit 2 initial startup, the licensee had not included into a calibration program all installed instrumentation that was used to verify TS requirements.
Calibration dates of instruments used to verify compliance with TS i
requirements were tracked using the Nuclear Plant Management
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Information System. This was a computerized data base that provided the information necessary to schedule and track the calibration of instrumentation.
The inspector was able l
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to use this data base to determine the schedule and completion dites for various Unit 2 instruments used to perform TS required surveillances.
Based on this review, this item is closed.
One non-cited violation was identified.
8.
Exit Meeting The inspection scope and findings were summarized on August 20, 1993, with those persons indicated in paragraph 1.
The inspector described the areas inspected and discussed in detail the. inspection
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findings listed below.
No dissenting comments were received from the
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licensee. The licensee did-not identify as proprietary any of the material provided to or reviewed by the inspectors during the inspection.
Item No.
Description and Reference NCV 424/93-17-01 Pressurizer Low Pressure Reactor Trip Due To Personnel Error (paragraph 7a)
9.
Abbreviations AFW
- Auxiliary Feedwater System ANSI
- American National Standards Institute CFR
- Code of Federal Regulations
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- Deficiency Card
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- Diesel Generator
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DRPI
- Digital Rod Position Indication System
- Final Safety Analysis Report GL
- Generic Letter I&C
- Instrumentation and Controls IFI
- Inspector Followup Item IR
- Inspection Report i
ISEG
- Independent Safety Engineering Group LCO
- Limiting Condition for Operation LER
- Licensee Event Report M&TE
- Measurement and Test Equipment
MWO
- Maintenance Work Order
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- Non-Cited Violation
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NPF
- Nuclear Power Facility NRC
- Nuclear Regulatory Commission
- Nuclear Service Cooling Water System t
- Protected Area PM
- Preventive Maintenance
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- Plant Review Board
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QCP
- Quality Concerns Program RCS
- Reactor Coolant System SAER
- Safety Audit And Engineering Review SDB
- Shutdown Bank i
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SR0
- Senior Reactor Operator TI
- Temporary Instruction i
TS
- Technical Specifications URI
- Unresolved Item
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- Violation 2R3
- Unit 2, Third Refueling Outage
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Attachment 1
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EMPLOYEE CONCERNS PROGRAMS PLANT NAME: Vogtle 1 & 2 LICENSEE: Georgia Power Co. DOCKET #: 50-424,425 NOTE:
Please circle yes or no if applicable and add comments in the space provided.
A.
PROGRAM:
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1.
Does the licensee have an employee concerns program?
(Yes). The Vogtle program is called the Quality Concerns Program (QCP)
2.
Has NRC inspected the program?
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(Yes/ Comments). Report #50-424,425/90-02.
The report noted that a specific Quality Concerns Program investigation was thorough and professionally done. The QCP was noted as a strength.
B.
SCOPE:
(Circle all that apply)
1.
Is it for:
a.
Technical? (Yes)
b.
Administrative? (Yes)
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c.
Personnel issues? (Yes)
2.
Does it cover safety as well as non-safety issues?
(Yes)
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Is it designed for:
a.
Nuclear safety? (Yes)
b.
Personal safety? (Yes)
c.
Personnel issues - including union grievances?
l (Yes/ Comments). However, any union grievance should first be taken to the union.
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Employee Concerns Programs (continued)
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4.
Does the program apply to all licensee employees?
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(Yes)
5.
Contractors?
(Yes/ Comments). Every contractor who will enter the
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protected area of the plant will be briefed on the QCP, but
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all _ contractors whether working inside or outside of the
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protected area can use-the services of the QCP.
6.
Does the licensee require its contractors and their subs to
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have a similar program?
I (No)
7.
Does the licensee conduct an exit interview upon terminating
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employees asking if they have any safety concerns?
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(Yes/ Comments). Exiting employees are given the opportunity to state concerns in writing. When possible_ exiting employees are given the exit interview prior to departure from the site. Should an employee exit the site without an
exit interview, the Quality Concerns Coordinator (QCC) will
forward a copy of the exit interview forms along with a
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letter of explanation to the employee's last known address.
C.
INDEPENDENCE:
1.
What is the title of the person in charge?
Quality Concerns Coordinator (QCC)
2.
Who do they repo"t to?
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Independent Sa'iety Engineering Group (ISEG) Supervisor on site
3.
Are they independent of line management?
(Yes)
u 4.
Does the ECP use tFird party consultants?
i (Yes/ Comments). They have occasionally requested assistance
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from the human resources department at the company corporate office.
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Employee Cor.cerns Programs (continued)
5.
How is a concern about a manager or vice president followed up?
The QCC has direct access to top corporate management to resolve such concerns.
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D.
RESOURCES:
1.
What is the size of staff devoted to this progran'
One full-time Vogtle employee devotes one-half of his time to overseeing the QCP program on site. The remainder of the time he is a QA inspector.
2.
What are ECP staff qualifications (technical training, interviewing training, investigator training, other)?
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There are no procedurally required qualifications for the
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position of QCC. The present QCC has been a QA inspector for 15 years and has a B.S. degree in Industrial Management.
E.
REFERRALS:
1.
Who has followup on concerns (ECP staff, line management, other)?
The QCC ensures that the actions are entered in a closed loop program to assure their implementation:
e.g., Action Item Tracking System, Safety Audit and Engineering Review Audit Finding Report tracking system, Deficiency Control
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System, etc.
F.
CONFIDENTIALITY:
1.
Are the reports confidential?
i (Yes/ Comments). Every effort is made within the law to protect the confidentiality of the submitter unless the submitter waives confidentiality or otherwise by his own action makes known his identity with relation to the Concern.
2.
Who is the identity of the alleger made known to (senior management, ECP staff, line management, other)?
The QCC and his supervisor.
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Employee Concerns Programs (continued)
3.
Can employees be:
a.
Anonymous? (Yes)
b.
Report by phone? (Yes/ Comments). Onsite phones numbers and an offsite toll-free number are available.
G.
FEEDBACK:
1.
Is feedback given to the alleger upon completion of the followup?
(Yes/Coments). The results of any investigation are sumarized in a certified letter addressed to the submitter.
Included with the letter is a form with provisions for the submitter to acknowledge receipt, indicate his satisfaction with the investigation, and provide his opinion of the results.
If the submitter is not satisfied, the QCC may initiate further investigation.
Prior to closing the concern, efforts will be made to advise the submitter of the ultimate disposition.
2.
Does program reward good ideas?
(No/Coments). The QCP is not an employee suggestion program.
3.
Who, or at what level, makes the final decision of i
resolution?
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The Manager Safety Audit and Engineering Review at the Corporate Office.
4.
Are the resolutions of anonymous concerns disseminated?
(No)
5.
Are resolutions of valid concerns publicized (newsletter, bulletin board, all hands meeting, other)?
(No)
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O Employee Concerns Programs (continued)
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H.
EFFECTIVENESS:
r 1.
How does the licensee measure the e#fectiveness of the program?
l Annual program audit by corporate Safety Audit and Engineering Review (SAER)
2.
Are concerns:
a.
Trended? (No)
b.
Used? (Yes/Coments). Informally.
If the QCC notices
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a recurring concern in a specific area he would notify the manager of that area.
3.
In the last three years how many concerns were raised? 172 Closed? 162 What percentage were substantiated? Approx.
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22%
4.
How are followup techniques used to measure effectiveness (random survey, interviews, other)?
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In 1991 random informal interviews were conducted to access i
employee knowledge of the QCP.
As stated previously, the SAER conducts an annual audit to assure program procedural compliance.
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5.
How frequently are internal audits of the ECP conducted and
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by whom?
Annually by corporate SAER.
I I.
ADMINISTRATION / TRAINING:
1.
Is ECP prescribed by a procedure?
(Yes/Coments). Corporate procedure VSAER-WP-25, " Quality Concerns Program" and Vogtle procedure 00015-C, " Quality
Concerns Program",
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How are employees, as well as contractors, made aware of this program (training, newsletter, bulletin board, other)?
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Orientation training, QCP bulletin boards on site, and site newsletter.
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Employee Concerns Programs (continued)
ADDITIONAL COMMENTS:
(Including characteristics which make the program especially effective or ineffective.)
The QCP is available to all Vogtle employees and contractors. Submitters of concerns are not asked to distinguish between quality and non-quality related concerns. All concerns are reviewed by the QCC whether or not there is a safety significance associated with the concern.
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