IR 05000424/1999004

Insp Repts 50-424/99-04 & 50-425/99-04 on 990502-0619. Non-cited Violations Noted.Major Areas Inspected:Operations, Engineering,Maintenance & Plant Support

ML20210E060
Person / Time
Site:	Vogtle
Issue date:	07/15/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20210E049	List: IR 05000424/1999004 ML20210E043
References
50-424-99-04, 50-425-99-04, NUDOCS 9907280112
Download: ML20210E060 (11)

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l U. S. NUCLEAR REGULATORY COMMISSION (NRC)

REGION 11

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Docket Nos. 50-424 and 50-425 License Nos. NPF-68 and NPF-81

Report No:

50-424/99-04 and 50-425/99-04 Licensee:

Southern Nuclear Operating Cornpany, Inc.

Facility:

Vogtle Electric Generating Plant Units 1 and 2 i

l Location:

7821 River Road

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Waynesboro, GA 30830 Dates:

May 2 through June 19,1999 Inspectors:

J. Zeiler, Senior Resident inspector K. O'Donohue, Resident inspector W. Kleinsorge, Reacbr Inspector (Section M3.1)

l C. Rapp, Senior Project Engineer (Section E3.1)

l W. Rodgers, Senior Reactor Analyst (Section E8.1)

Approved by: P. Skinner, Chief i

Reactor Projects Branch 2 Division of Reactor Projects

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9907290112 990715 PDR ADOCK 05000424 O

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EXECUTIVE SUMMARY Vogtle Electric Generating Plant Units 1 and 2 NRC Inspection Report 50-424/99-04 and 50-425/99-04 This integrated inspection included aspects of licensee operations, engineering, maintenance, and plant support. The report covers a seven-week period of resident inspection. It also includes the results of announced inspections by region-base inspectors.

Operations Management demonstrr'ed conservative decision making to replace the generator e

stator cooling water strainer. Management resolve in addressing repetitive strainer plugging issues was evident by the decision to initiate an Event Review Team to study the problem (Section O2.2).

A Non-Cited Violation was identified for failure to comply with TS overtime limits (Section

06.1).

Maintenance A Non-Cited Violation was identified for failures to provide adequate procedures for e

conducting maintenance on safety-related breakers resulting in seismic restraint configuration deficiencies (Sections M3.1 and M8.1).

Plant Support Security activities associated with temporary removal of Protected Area fencing and e

vehicle barrier system was well planned and coordinated. Conservative security compensatory measures were implemented (Section S1.2).

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Report Details Summarv of Plant Status Unit 1 operated at 100% Rated Thermal Power (RTP) throughout the entire inspection period.

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Unit 2 operated at 100% RTP until June 4,1999, when the licensee reduced power to 30% in order to replace a generator stator cooling water system strainer. The unit was returned to 100% RTP on June 7.

l. Operations

Conduct of Operations 01.1 Gen 3ral Comments (71707)

The inspectors conducted routine control room tours and attended operations shift turnovers and daily management plant status meetings. Operator logs were reviewed to verify compliance with Technical Specifications (TS). Instrumentation, computer indications, and safety system lineups were periodically reviewed to assess system availability. No problems were identified in the above areas.

O2 Operational Status of Facilities and Equipment O2.1 General Plant Tours (71707)

The inspectors performed general tours of safety-related areas. These general tours included accessible portions of safety-related structures, systems, and components. No equipment material condition or housekeeping problems were observed.

O2.2 Unit 2 Power Reduction (71707)(62707)

On June 4, the licensee reduced power to approximately 30% and removed the Unit 2 generator from service because of low generator stator cooling water flow. The licensee identified a buildup of copper oxide in the generator stator cooling water strainer. The inspectors noted that a similar buildup of copper oxide had also occurred in February 1999. As a result of the continued buildup of copper oxide, and similar stator cooling water problems that recently occurred at other facilities, the licensee initiated an Event Review Team.

The inspectors concluded that management demonstrated conservative decision making by replacing the generator stator cooling water strainer. Management decision to initiate a more thorough investigation of the strainer plugging problems was proper.

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OS Plant Organization and Administration i

06.1 Excess Plant Overtime Review a.

Insoection Scope (71707)(40500)

q The inspectors reviewed licensee procedures for controlling plant personnel overtime. A sample of plant personnel time records and completed Excess Overtime Authorizaticn forms were examined and compared with personnel on-site time as determined by

security logs.

b.

Observations and Findinas TS 5.2.2, Unit Staff, section e, provides overtime guidelines for personnel that perform safety related functions. The TS required that any deviation from these overtime j

guidelines be authorized by the applicable department superintendent or higher management. The inspectors reviewed administrative procedure 00005-C," Overtime Authorization," Revision (Rev.) 8. The procedure required that any deviations from these overtime guidelines be authorized prior to the hours being worked and that this approval may be obtained verbally. The authorization and justification of these deviations were required to be documented on Excess Overtime Authorization forms.

The inspectors reviewed the 1998 cumulative overtime worked by six operations personnel. The inspectors discussed the usage of operator overtime with licensee management. Management attributed the overtime to changes in shift staffing, unexpected operator attrition, and necessary staffing for sickness and vacation. The inspectors noted that the licensee had started two additional operator training classes to address operator attrition. In addition, the plant manager directed the independent Safety Engineering Group (ISEG) to conduct an independent assessment of plant overtime.

The inspectors reviewed approximately 45 maintenance personnel time records. The l

inspectors noted that the majority of overtime occurred during refueling outages.

However, during refueling outage 1R8 (February 28 - March 26,1999), time records indicated that maintenance personnel worked long periods of consecutive days. For example, several individuals worked 13 consecutive days, followed by one day off, tnen

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worked 6,7, or 8 consecutive days with'inother day off. Licensee management stated that all maintenance personnel were scheduled to work 13 consecutive days at the beginning of the outage because the outage was scheduled for 21 days. A single

Excess Overtime Authorization form was completed for all maintenance personnel expected to work the 13 consecutive days. Licensee management also stated that

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there was an expectation that the personnel who felt they should not work because of

fatigue would be allowed a day off if requested. The inspectors interviewed l

maintenance personnel and determined that although maintenance personnel I

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understood that a day off could be requested, none had requested a day off although

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some indicated they felt fatigued. Based on review of Condition Reports (CRs)

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generated during the outage, the inspectors did not identify any adverse plant performance issue due to fatigue. The licensee acknowledged the impact of the

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schedule oc maintenance personnel and that future outage schedules would not include similar consecutive days.

While reviewing completed Excess Overtime Authorization forms for the period January 1998 to April 1999, the inspectors identified nine cases where individuals performing safety-related activities had deviated from the TS overtime guidelines without completing the necessary authorization forms. All of these cases involved overtime in excess of the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7-day peri 6d guideline. Licensee management stated that verbal approval was granted for several of these cases although the authorization forms were not completed. However, after further discussions with personnel who authorized overtime, the inspectors determined that this guideline was being applied to overtime in excess of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> per 7-day work oeriod. As a result, personnel had not recognized that the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7-day period guideline had been exceeded. The inspectors reviewed control room logs and condition reports for each of the time periods that were exceeded and did not identify any issues attributed to adverse individual plant performance.

j Technical Specification 5.2.2, section e.2, states, in part, "An individual should not be permitted to work... more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7 day period..." TS 5.2.2, section e, further states "Any deviation from the above guidelines shall be authorized.. with

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documentation of the basis for granting the deviation." Contrary to the above, in nine cases, this overtime guideline was exceeded without either prior approval or documenting the basis for the deviation. This is a Severity Level IV violation.

Consistent with Appendix C of the NRC Enforcement Policy, this violation is being treated as a Non-Cited Violation (NCV) and is identified as NCV 50-424,425/99-04-01,

" Technical Specification Overtime Limits Exceeded." This violation is in the licensee's Corrective Action Program as CRs 119990576 and 119990577.

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Conclusions An NCV was identified for failure to comply with TS 5.2.2 overtime limits.

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Miscellaneous Operations issues (92700)(92901)

08.1 (Closed) Licensee Event Report (LER) 50-424/98-008-00: Loss of Feedwater Heatina Results in Reactor Overoower Event Details associated with this event and the licensee's corrective actions were previously reviewed and documented in NRC Integrated Inspection Reports 50-424,425/99-02 and 98-10. No additional information was identifie ff

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4 11. Maintenance.

M1 Conduct of Maintenance M1.1 General Maintenance Work Order and Surveillance Observations (61726) (62707)

The inspectors observed or reviewed portions of selected maintenance and surveillance activities. The observed maintenance and surveillance activities were completed by qualified personnel knowledgeable of their assigned tasks. Procedures were present at the work location and provided sufficient guidance for the intended activities. Problems encountered during the performance of activities were properly resolved.

M3 Maintenance Procedures and Documentation M3.1 Unsecured Motor Control Center (MCC) Door Latches a.

Inspection Scope (62700)

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The inspectors reviewed licensee actions to correct unsecured MCC door latches.

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Observations and Findinas On February 13,1997, the licensee determined that MCC's with unsecured door latches could trip or cause mis-operation of equipment such as starters, auxiliary contacts or I

relays during a seismic event. The licensee determined that the unsecured MCC door latches represented a condition that alone could have prevented the associated safety-related equipment from preforming its intended function and reported the condition in LER 50-424/97-003. The licensee's corrective actions were to inspect and secure all MCC door latches and provide training to maintenance and operations personnel.

On March 15,1999, while observing 125-volt class 1E battery maintenance, the inspectors identified a number of unsecured MCC door latches. Subsequently, the licensee conducted an inspection of all Class 1E safety-related MCCs and found 51 unsecured MCC door latches in Unit 1 and 25 unsecured MCC door latches in Unit 2.

The licensee documented these conditions in their Corrective Action program as CRs 119990304-8,119990327-8,119990335-6, and 219990066-76. The licensee conducted additional seismic evaluations and determined that unlatched MCC door would not prevent the MCCs from performing their intended function.

I 10 CFR 50, Appendix B, Criterion V, instructions, Procedures, and Drawings, requires, in part, that activities affecting quality be prescribed and accomplished in accordance with procedures appropriate to the circumstances. Contrary to the above, procedure 25506-C, Rev.12, Motor Control Center Preventative Maintenance, was not appropriate to the circumstances in that it did not contain sufficiently detailed instructions to assure that MCCs were returned to proper seismic configurations following maintenance. This is identified as an example of NCV 50-424,425/99-04-02, " inadequate Procedures for Conducting Maintenance on Safety-Related Circuit Breakers."

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Conclusion An example o' NCV 50-424,425/99-04-02 was identified for an inadequate procedure for proper securing of MCC door latches which resulted in MCCs not being returned to required seismic configurations after maintenance.

M8 Miscellaneous Maintenance lasues (92700) (92902)

M8.1 (Closed) URI 50-424. 425/98-09-01: Review of Breaker Seismic Oualification inadeauacies The licensee conducted additional seismic testing for the as-found breaker configuratior s and determined that only one seismic clip or only one breaker latch was required. Based on these test results, the licensee concluded that the associated equipment was operable.

The inspectors reviewed preventive maintenance procedures 25506-C, Motor Control Center Preventative Maintenance, Rev. 11,27740-C, Molded Case Circuit Breakers Maintenance, Rev.18, and 28908-C, Molded Case Circuit Breaker Testing, Rev. 26.

These procedures stated that the seismic clips should be installed; however, there was no guidance on the number of seismic clips required. Further, there was no guidance to close breaker latches. Licensee correc;ive actions included revising the procedures to strengthen the squirement for securing breaker latches and seismic clips. The inspectors considered the corrective actions adequate, in addition, the importance of securing breaker latchas and Faismic clips was addressed in continuing maintenance and operator training.

10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality be prescribed and accomplished in accordance with procedures appropriate to the circumstances. Contrary to the above, Procedures 25506-C,26869-C,27740-C, and 28908-C, were not appropriate to the circumstances, in that, they failed to contain adequate controls for ensuring that required seismic restraints were properly secured. As a result, numerous 480 volt safety-related circuit breakers were not returned to proper seismic configurations after maintenance. This is a Severity Lever IV violation. Consistent with Appendix C of the NRC Enforcement Policy, this violation is being treated as an NCV and is identified as NCV 50-424, 425/99-04-02, " inadequate Procedures for Conducting Maintenance on Safety-Related Circuit Breakers." This violation is in the licensee's Corrective Actions program as LER 50-424/98-006.

M8.2 -(Closcd) LER 50-424/98-006-02: Motor Control Center Breaker Buckets Not Seismically Oualified Revision 2 to this LER vms submitted to document an additional motor-control center breaker associated with the Unit 1 Power Operated Relief Valve block valve,1HV8000A, which was not seismically qualified resulting in a condition prohibited by TS.

Subsequent evaluations by the licensee determined that the valve was operable. No additional information was identified.. _ _ _ - _ _ _ _ _

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M8.3 (Closed) LER 50-424/98-006-03: Motor Control Center Breaker Buckets Not Seismically Qualified Revision 3 to this LER was submitted to document the results of additional seismic testing that demonstrated that the affected breakers would have continued to perform their intended safety functions during a seismic event.

Ill. Enaineerina E3 Engineering Procedures and Documentation E3.1 Year 2000 (Y2K) Readiness Proaram Review (Tl 2515/141)

The staff conducted an abbreviated review of Y2K activities and documentation using Temporary Instruction (TI) 2515/141, " Review of Year 2000 (Y2K) Readiness of Computer Systems at Nuclear Power Plants." The review addressed aspects of Y2K management planning, documentation, implementation planning, initial assessment, detailed assessment, remediation activities, Y2K testing and validation, notification activities, and contingency planning. The reviewcrs used NEl/NUSMG 97-07," Nuclear Utility Year 2000 Readiness," and NEl/NUSMG 98-07, " Nuclear Utility Year 2000 Readiness Contingency Planning," as the primary references for this review. Based on this abbreviated review, the inspectors did not identify any issues that could affect Y2K readiness.

Specific conclusions regarding the Y2K readiness of the facility are not included in this report. The results of this review will be combined with the results of reviews of other licensees in a summary report scheduled to be issued by July 31,1999.

E8 Miscellaneous Engineering issues (92903)

E8.1 (Closed) Inspector Followuo item (IFI) 50-424. 425/98-01-01: Review of Maintenance Rule Reliability Assumotions Originally, the licensee established system reliability performance criteria for the

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Maintenance Rule different from the values specifically stated in the probabilistic risk analysis (PRA) without performing a sensitivity analysis demonstrating that the assumptions of the PRA were still conserved. This inspector followup item was

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established to confirm that such a sensitivity analysis was completed, submitted to an I

expert panel for review and that the subsequent reliability performance criteria continued to conserve the PRA assumptions. On 6/i-the licensee's expert panel reviewed the

results of the sensitivity analysis. The e-ased one additional failure, in most i

cases, integrated into a PRA system's fc t

.oability via a Bayesian update. Using the baseline core damage frequency (CDt.

d.7E-5, CDF increased by 20%. When simultaneously combined with the Maintenance Rule availability performance criteria, CDF increased by 57% The expert panel accepted the sensitivity analysis results. In the Region 11 office, the inspector reviewed documentation of the 6/19/98 6xpert panel meeting and the results of the sensitivity analysis. The information supported that the reliability performance criteria conserved the PRA assumptions. This IFl is closed.

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IV. Plant Support R1 Radiologicai Protection and Chemistry Controls R I.1 General Observations (71750)

The inspectors routinely observed radiologically controlled areas and reviewed chemistry results. Personnel were attentive to radiological conditions and followed posted requirements. Area surveys were properly performed. Radiation pre-job briefings were detailed and performed when necessary. The licensee provided good management oversight of radiation and chemistry activities.

P5 Staff Training and Qualification in Emergency Preparedriess (EP)

PS.1 - Observation of Emeraency Drills (71750)

On June 2, the licensee conducted a quarterly EP drill. The drill involved full response by personnel on-site and activation of all emergency response facilities. The inspectors observed the activation, staffing, and operation of the emergency organization in the Technical Support Center (TSC) and simulator control room. The inspectors determined that the drill and subsequent critique were effective in identifyirig areas for improvement.

S1 Conduct of Security and Safeguards Activities S1.1 Routine Observation of Security and Safeauards Activities (71750)

The inspectors periodically toured the protected area for adequate lighting and security control functions, observed visitor escorting, and the use of special purpose detectors at the protected area entrance, and observed personnel, packages, and vehicles entering the protected area. The inspectors determined that the security fence was intact and the isolation zcnes were being adequately maintained free of objects. Lighting of the perimeter and protected area was acceptable. Visitor escorting and special purpose detectors were used as applicable before personnel or package entry.

S1.2 Temoorary Protected Area Fence Removal (71750)

The inspectors observed licensee activities to temporarily remove a section of the Protected Area (PA) fence and vehicle barrier system. The inspectors observed the implementation of compensatory measures when the section of the PA fence and vehicle barrier system were removed. Following the fence and vehicle barrier restoration, the inspectors performed a walkdown of the area. No discrepancies were identified.

The inspectors concluded that the security activity was well planned and coordinated.

Conservative security compensatory measures were implemented during the period that the PA fence and vehicle barrier system was degraded.

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8 V. Manaaement Meetinas and Other Areas X1 Exit Meeting Summary The inspectors presented the inspections results to members of licensee management at the conclusion of the inspection on June 23,1999. The licensee acknowledged the findings presented. No proprietary information was identified.

PARTIAL LIST OF PERSONS CONTACTED Licensee R. Brown, Manager, Training and Emergency Preparedness -

W. Burmeister, Manager Engineering Support S. Chesnut, Plant Operations Assistant General Manager G. Frederick, Manager Operations J. Gasser, Nuclear Plant General Manager K. Holmes, Manager Maintenance P. Rushton, Plant Support Assistant General Manager M. Sheibani, Nuclear Safety and Compliance Supervisor C. Tippins, Jr., Nuclear Specialist i INSPECTION PROCEDURES USED IP 37551:

Onsite Engineering IP 61726:

Surveillance Observation IP 62707:

Maintenance Observation IP 71707:

Plant Operations IP 71750:

Plant Support i

IP 92700:

Onsite Followup of Written Reports of Nonroutine Events at Power Reactor Facilities IP 92901:

Followup - Operations IP 92902:

Followup - Maintenance / Surveillance IP 92903 Followup - Engineering Tl 2515/141: Year 2000 (Y2K) Readiness Program Review ITEMS OPENED AND CLOSED ITEM NUMBER TYPE DESCRIPTION Closed 50-424,425/99-04-01 NCV Technical Specification Overtime Limits Exceeded (Section 06.1)

50-424/98-008-00 LER Loss of Feedwater Heating Results in Reactor Overpower Event (Section 08.1)

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50-424,425/99-04-02 NCV inadequate Procedures for Conducting Maintenance on Safety-Related Circuit Breakers (Sections M3.1 and M8.1)

50-424,425/98-09-01 URI Review of Breaker Seismic Qualification inadequacies (Section M8.1)

50-424/98-006-02 LER Motor Control Center Breaker Buckets Not

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Seismically Qualified (Section M8.2)

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50-424/98-006-03 LER Motor Control Center Breaker Buckets Not Seismically Qualified (Section M8.3)

50-424,425/98-01-01 IFl Review of Maintenance Rule Reliability

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Assumptions (Section E8.1)

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