IR 05000424/2010002

IR 05000424-10-002 & 05000425-10-002 on 01/01/10 - 03/31/10 for Vogtle, Maintenance Effectiveness

ML101200151
Person / Time
Site:	Vogtle
Issue date:	04/29/2010
From:	Scott Shaeffer NRC/RGN-II/DCI
To:	Tynan T Southern Nuclear Operating Co
References
IR-10-002
Download: ML101200151 (37)

Text

April 29, 2010

SUBJECT:

VOGTLE ELECTRIC GENERATING PLANT - NRC INTEGRATED INSPECTION REPORT 05000424/2010002 AND 05000425/2010002

Dear Mr. Tynan:

On March 31, 2010, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Vogtle Electric Generating Plant, Units 1 and 2. The enclosed integrated inspection report documents the inspection findings, which were discussed on April 19, 2010, with yourself 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 activities, and interviewed personnel.

This report documents one self-revealing finding which was determined to be of very low safety significance and was determined to be a violation of regulatory requirements. In addition, one licensee-identified violation, which was determined to be of very low safety significance, is listed in the enclosed inspection report. However, because of the very low safety significance and because they were entered into your corrective action program, the NRC is treating these findings as non-cited violations (NCV) consistent with Section VI.A.1 of the NRCs Enforcement Policy. If you contest any NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.:

Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Vogtle Electric Generating Plant. In addition, if you disagree with the characterization of any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region II, and the NRC Resident Inspector at the Vogtle Electric Generating Plant. The information you provide will be considered in accordance with the Inspection Manual Chapter 0305.

SNC

In accordance with the Code of Federal Regulations 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosures, and your response (if any) 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 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/

Scott M. Shaeffer, Chief Reactor Projects Branch 2 Division of Reactor Projects

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

Enclosures:

Inspection Report 05000424/2010002 and 05000425/2010002 w/Attachment: Supplemental Information

REGION II==

Docket Nos.: 50-424, 50-425

License Nos.: NPF-68, NPF-81

Report Nos.: 05000424/2010002 and 05000425/2010002

Licensee:

Southern Nuclear Operating Company, Inc. (SNC)

Facility:

Vogtle Electric Generating Plant, Units 1 and 2

Location:

Waynesboro, GA 30830

Dates:

January 1, 2010 through March 31, 2010

Inspectors:

M. Cain, Senior Resident Inspector

T. Chandler, Resident Inspector

A. Nielsen, Health Physicist (Sections 2RS1, 2RS3, and 4OA1)

G. Kuzo, Senior Health Physicist (Sections 2RS2, 2RS4, and 4OA1)

Approved by: Scott M. Shaeffer, Chief Reactor Projects Branch 2 Division of Reactor Projects

Enclosure

SUMMARY OF FINDINGS

IR 05000424/2010-002, 05000425/2010-002; 1/01/2010 - 3/31/2010; Vogtle Electric

Generating Plant, Units 1 and 2; Maintenance Effectiveness

The report covered a three-month period of inspection by two resident inspectors and two health physicists. One self-revealing Green NCV was identified. The significance of most findings is indicated by its color (Green, White, Yellow, Red) using IMC 0609,

ASignificance Determination Process (SDP). Findings for which the SDP does not apply may be Green or assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, AReactor Oversight Process,@ (ROP) Revision 4, dated December, 2006.

NRC-Identified and Self-Revealing Findings

Cornerstones: Mitigating Systems

Green.

A self-revealing non-cited violation (NCV) for failure to meet the requirements of 10 CFR 50, Appendix B, Criterion XVI was identified. Specifically, for ineffective corrective maintenance performed on the Unit 2 Component Cooling Water (CCW)

Pump #4. The corrective maintenance actions performed on CCW pump #4 in October 2009 to repair damage due to contact between the throttle bushing and the shaft sleeve on the inboard mechanical seal were ineffective, and consequently, the same damage to the inboard mechanical seal occurred in January 2010 when the pump was again operated. As a result, the Unit 2 CCW pump #4 was rendered inoperable for the second time in three months due to the same mechanical seal issue.

This issue was greater than minor because it was associated with a cornerstone attribute and adversely affected the objective of the Mitigating Systems cornerstone.

Specifically, the performance deficiency was an equipment performance issue which affected the availability, reliability, and capability of the B train emergency core cooling system (ECCS) to respond to a loss of coolant accident (LOCA). The finding was determined to be of very low safety significance (Green) because the event did not represent in an actual loss of safety function of a single train for greater than its Technical Specification allowed outage time. The inspectors determined that the cause of this finding was related to the Corrective Action Program component of the Problem Identification and Resolution cross-cutting area due to less-than-adequate problem evaluation P.1(c). Specifically, the corrective maintenance actions used to resolve the mechanical seal issue on CCW pump #4 were less than adequate.

(Section 1R12)

Licensee-Identified Violations

A violation of very low safety significance, which was identified by the licensee, was reviewed by the NRC. Corrective actions taken or planned by the licensee have been entered into the licensees CAP. This violation and corrective action tracking numbers are listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status

Unit 1 operated at full rated thermal power (RTP) for the entire inspection period.

Unit 2 started the inspection period at full RTP. The unit was shutdown on March 07 for a planned refueling outage and remained shutdown for the duration of the reporting period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

==1R01 Adverse Weather Protection

a. Inspection Scope

Impending Adverse Weather Condition Review.==

On January 14, the inspectors reviewed licensee procedure 11877-1 and 11877-2, Cold Weather Checklist, to verify the licensee had implemented actions to prepare the plant site for predicted severe weather conditions of extended sub-freezing temperatures during week January 11, 2010. The inspectors walked down various safety-significant areas of the plant to verify the licensees ability to respond to the predicted adverse weather conditions.

b. Findings

No findings of significance were identified.

==1R04 Equipment Alignment

a. Inspection Scope

Partial System Walkdown.==

The inspectors performed partial walkdowns of the following three systems to verify correct system alignment. The inspectors checked for correct valve and electrical power alignments by comparing positions of valves, switches, and breakers to the documents listed in the Attachment. Additionally, the inspectors reviewed the condition report database to verify that equipment alignment problems were being identified and appropriately resolved.

• Unit 1 Train A&B motor-driven auxiliary feedwater (MDAFW) systems when the turbine-driven auxiliary feedwater (TDAFW) pump was out of service due to a planned maintenance outage

• Unit 2 Train B residual heat removal (RHR) system when the A train was out of service due to a planned maintenance outage

• Unit 2 Train A&B MDAFW systems when the TDAFW pump was out of service due to a planned maintenance outage Complete System Walkdown. The inspectors performed a complete walkdown of the Unit 1 component cooling water (CCW) system. The inspectors performed a detailed check of valve positions, electrical breaker positions, and operating switch positions to evaluate the operability of the redundant trains or components by comparing the required position in the system operating procedure to the actual position. The inspectors also reviewed control room logs, condition reports, and system health reports to verify that alignment and equipment discrepancies were being identified and appropriately resolved.

The documents reviewed are listed in the Attachment.

b. Findings

No findings of significance were identified.

==1R05 Fire Protection

a. Inspection Scope

Fire Drill Observation.==

On January 27, inspectors observed a fire drill from the control room, the primary fire brigade locker, and the fire scene. The fire was simulated to be in the Unit 1 North Main Steam Valve room. The inspectors assessed the adequacy of the fire drill and fire brigade response using licensee procedures 92000-C, Fire Protection Program; 92005-C, Fire Response Procedure; NMP-TR-425, Fire Drill Program; 92799-1, Zone 99 - Control Building Level A Fire Fighting Preplan; and 17103A-C, Annunciator Response Procedures for the Fire Alarm Computer. The inspectors evaluated the fire brigade performance to verify that they responded to the fire in a timely manner, donned proper protective clothing, used self-contained breathing apparatus, and had the equipment necessary to control and extinguish the fire. The inspectors assessed the adequacy of the fire brigades fire fighting strategy including entry into the fire area, communications, search and rescue, and equipment usage.

Fire Area Tours. The inspectors walked down the following five plant areas to verify the licensee was controlling combustible materials and ignition sources as required by procedures 92015-C, Use, Control, and Storage of Flammable/Combustible Materials, and 92020-C, Control of Ignition Sources. The inspectors assessed the observable condition of fire detection, suppression, and protection systems and reviewed the licensees fire protection Limiting Condition for Operation log and condition report (CR)database to verify that the corrective actions for degraded equipment were identified and appropriately prioritized. The inspectors also reviewed the licensees fire protection program to verify the requirements of Updated Final Safety Analysis Report (UFSAR)

Section 9.5.1, Fire Protection Program, and Appendix 9A, Fire Hazards Analysis, were met. Documents reviewed are listed in the Attachment.

• Unit 1 class 1E 125 vdc station batteries and associated switchgear rooms

• Unit 2 class 1E 125 vdc station batteries and associated switchgear rooms

• Unit 1 north main steam valve room

• Unit 2 emergency diesel generator building

• Unit 2 auxiliary feedwater pumphouse rooms

b. Findings

No findings of significance were identified.

==1R07 Heat Sink Performance

a. Inspection Scope

==

Annual Review. The inspectors reviewed the licensees records of the performance tests conducted on the Unit 2, B Train centrifugal charging pump (CCP) motor cooler heat exchanger. The inspectors reviewed EPRI NP-7552, Heat Exchanger Performance Monitoring Guidelines to ensure that the licensees testing procedures were appropriate.

Additionally, the inspectors reviewed the licensees CAP for heat exchanger performance issues to ensure that discrepancies were being identified and appropriately resolved.

Documents reviewed are listed in the Attachment.

b. Findings

No findings of significance were identified.

==1R11 Licensed Operator Requalification

a. Inspection Scope

Resident Quarterly Observation.==

The inspectors observed operator performance on January 26, during licensed operator simulator training described on simulator exercise guide Pre-Outage Review V-RQ-SE-09601. The simulator scenarios covered operator actions resulting from a Reactor Coolant System (RCS) leak and a loss of all vital AC power with the plant in Mode 5 and solid. The inspectors also observed the operators respond to a loss of shutdown cooling with the plant at hot mid-loop conditions.

Documents reviewed are listed in the Attachment. The inspectors specifically assessed the following areas:

• Use of the abnormal and emergency operating procedures

• Ability to identify and implement appropriate actions in accordance with the requirements of the Technical Specifications

• Clarity and formality of communications in accordance with procedure 10000-C, Conduct of Operations

• Control board manipulations including critical operator actions

• Supervisory command and control

• Post-evaluation critique

b. Findings

No findings of significance were identified.

==1R12 Maintenance Effectiveness

a. Inspection Scope

==

The inspectors reviewed the following two condition reports and applicable safety-significant systems to evaluate the licensees handling of equipment performance problems and to verify the licensees maintenance efforts met the requirements of 10 CFR 50.65 (the Maintenance Rule) and licensee procedure 50028-C, Engineering Maintenance Rule Implementation. The reviews included adequacy of the licensees failure characterization, establishment of performance criteria or 50.65(a)(1) performance goals, and adequacy of corrective actions. Other documents reviewed during this inspection included control room logs, system health reports, the maintenance rule database, and maintenance work orders (WO). Also, the inspectors interviewed system engineers and the maintenance rule coordinator to assess the accuracy of identified performance deficiencies and extent of condition.

• CR 2010101129, Unit 2 component cooling water (CCW) pump inboard bearing/seal fire

• CR 2009105577, Unit 1 Nuclear Service Cooling Water (NSCW) pump #5 discharge valve stroke time failure

b. Findings

Introduction.

A Green self-revealing non-cited violation (NCV) was identified for ineffective corrective maintenance performed on the Unit 2 CCW Pump #4. The corrective maintenance actions performed on CCW pump #4 in October 2009 to repair damage due to contact between the throttle bushing and the shaft sleeve on the inboard mechanical seal were ineffective, and consequently, the same damage to the inboard mechanical seal occurred in January 2010 when the pump was again operated. As a result, the Unit 2 CCW pump #4 was rendered inoperable for the second time in three months due to the same mechanical seal issue.

Description.

On 10/20/09 while performing an in-service test on the Unit 2 B train of CCW, the system operators noticed a burning smell coming from CCW pump #4 after it had been running for approximately 5 minutes. The operators inspected the pump and identified smoke and sparks emanating from the inboard mechanical seal. The pump was immediately stopped and declared inoperable. The operators noticed that the shaft area near the inboard mechanical seal was glowing cherry red. The pump ran for a total of 8 minutes. Inspection of the inboard seal area, external to the pump casing, showed that the source of the heat was physical contact between the throttle bushing (i.e., the stationary disaster bushing mounted on the outer gland) and the shaft sleeve.

Based upon the discovery of abrasive material (corrosion inhibitor/grit deposits) in and around the throttle bushing, the licensee concluded that the buildup of abrasive material alone had eliminated the clearance between the throttle bushing and the shaft sleeve, resulting in physical contact (i.e., touching off) between the stationary and rotating elements. This conclusion was documented in ACD 2009110742. The licensee removed the abrasive material, replaced the shaft sleeve, and rebuilt the inboard mechanical seal using new components on October 24, 2009. The pump alignment

check and the functional test were performed on December 4, 2009. Operations returned the pump to operable status on January 27, 2010.

On January 30, 2010, CCW pump #4 was running when CCW pump #2 was stopped and pump #6 was started in preparation of performing a test of the B train safety injection system. During the pump shift, fire and smoke were observed coming from the inboard seal area of CCW pump #4. The pump was stopped, and subsequent inspection of the inboard seal area revealed that again, the inboard throttle bearing had touched off on the shaft sleeve. An in-depth investigation with the pump casing removed was conducted and the following three issues were identified:

• The inboard mechanical seal housing was not properly centered on the pump shaft (excess clearance exists between the mechanical seal housing and the pump casing, which allowed the mechanical seal to be mounted significantly off-center from the shaft)

• The pump shaft was not centered in the pump casing (inboard bearing was positioned too low)

• The wear rings on the pump casing were worn, which allowed significant flexing of the pump shaft

Due to the limited amount of pump run time between October 2009 and January 2010, it was concluded that these issues most likely existed during the first failure event in October 2009. Had an in-depth investigation with the pump casing removed been conducted after the initial event, these issues would have been identified and corrected.

Analysis.

The corrective maintenance actions performed on the Unit 2 CCW pump #4 to repair damage due to contact between the throttle bushing and the shaft sleeve on the inboard mechanical seal were ineffective. This was a performance deficiency because the personnel performing the corrective maintenance actions failed to verify that the proper physical orientation and alignment existed between the pump casing, pump shaft, and mechanical seal package, as required by the pump and seal manufacturers. This issue is more than minor because it is associated with a cornerstone attribute and adversely affects the objective of the Mitigating Systems cornerstone. Specifically, the performance deficiency is an equipment performance issue which affected the availability, reliability, and capability of the B train emergency core cooling system to respond to a loss of coolant accident. The finding was determined to be of very low safety significance (Green) because the event did not represent an actual loss of safety function of a single train for greater than its Technical Specification allowed outage time.

The inspectors determined that the cause of this finding was related to the Corrective Action Program component of the Problem Identification and Resolution cross-cutting area due to less-than-adequate problem evaluation P.1(c). Specifically, the corrective maintenance actions used to resolve the mechanical seal issue on CCW pump #4 were less than adequate.

Enforcement.

The inspectors determined that the finding represents a violation of regulatory requirements because it involved inadequate corrective actions which failed to promptly identify and correct a condition adverse to quality. 10 CFR 50, Appendix B, Criterion XVI requires the licensee to establish measures to assure that conditions adverse to quality be promptly identified and corrected. Contrary to the above, the corrective maintenance actions performed following the October 2009 mechanical seal overheating event were inadequate, and consequently the inboard mechanical seal overheated again in January 2010. As a result, the Unit 2 CCW pump #4 was rendered inoperable for greater than 2 months. Because this violation was of very low safety significance and it was entered into the licensees corrective action program (ref. CR 2010101129 and CR 2010101155), this violation is being treated as an NCV, consistent with the NRC Enforcement Policy. This finding will be tracked as NCV 05000425/

2010002-01, Ineffective Corrective Action Renders Unit 2 CCW Pump #4 Inoperable.

==1R13 Maintenance Risk Assessments and Emergent Work Evaluation

a. Inspection Scope

==

The inspectors reviewed the following five work activities to verify plant risk was properly assessed by the licensee prior to conducting the activities. The inspectors reviewed risk assessments and risk management controls implemented for these activities to verify they were completed in accordance with procedure 00354-C, Maintenance Scheduling, and 10 CFR 50.65(a)(4). The inspectors also reviewed the CR database to verify that maintenance risk assessment problems were being identified at the appropriate level, entered into the corrective action program, and appropriately resolved.

• Unit 1 turbine-driven auxiliary feedwater pump outage while performing several maintenance items on the SSPS

• Performance of the preventive maintenance on the Unit 1 turbine-driven auxiliary feedwater pump steam inlet valve concurrent with performing in-service tests on three NSCW pumps

• Performance of numerous pre-outage activities on Unit 2 safety systems

• Performance of the preventive maintenance on the Unit 2 turbine-driven auxiliary feedwater pump concurrent with component cooling water (CCW) pump #4 OOS

• Maintenance activities during hot mid-loop conditions (2R14)

b. Findings

No findings of significance were identified.

==1R15 Operability Evaluations

a. Inspection Scope

==

The inspectors reviewed the following five evaluations to verify they met the requirements of procedure NMP-GM-002, Corrective Action Program, and NMP-GM-002-001, Corrective Action Program Instructions. The scope of this inspection included a review of the technical adequacy of the evaluations, the adequacy of compensatory measures, and the impact on continued plant operation.

• CR 2010100884, Jacket water leaks found on #6 right bank jacket water jumper and under left bank turbo charger of 2A EDG

• CR 2010101674, EMAX breaker closing coil Part 21

• CR 2010101634, Hydraulic leak at atmospheric relief valve 1PV-3000 identified during performance of quarterly valve testing

• CR 2010102781, 2A EDG jacket water keep warm pump seal leak

• CR 2010101129, Unit 2 CCW pump #4 inboard mechanical seal caught on fire

b. Findings

No findings of significance were identified.

==1R18 Plant Modifications

a. Inspection Scope

Temporary Modifications.==

The inspectors reviewed temporary modification TM 1091727101 (U1) and associated 10CFR50.59 screening criteria against the system design bases documentation and procedure 00307-C, Temporary Modifications. This temporary modification replaced circuit breaker 1ABA11, feeder supply breaker to the Class 1E battery charger 1CD1CB, with an equivalent breaker that did not have 52b auxiliary contacts. The 52b auxiliary contacts are used to provide input to the MCC 1ABA trouble alarm. Use of the temporary modification allowed continued operation of the safety-related battery charger until a breaker with 52b auxiliary contacts could be procured, tested, and installed. The inspectors reviewed implementation, configuration control, post-installation test activities, drawing and procedure updates, and operator awareness for this temporary modification.

b. Findings

No findings of significance were identified.

==1R19 Post-Maintenance Testing

a. Inspection Scope

==

The inspectors either observed post-maintenance testing or reviewed the test results for the following six maintenance activities to verify that the testing met the requirements of procedure 29401-C, Work Order Functional Tests, for ensuring equipment operability and functional capability was restored. The inspectors also reviewed the test procedures to verify the acceptance criteria were sufficient to meet the Technical Specifications operability requirements.

• Unit 2 train A centrifugal charging pump system outage

• Unit 2 train B motor-driven auxiliary feedwater system outage

• Unit 1 S/G #4 main feed isolation valve pressure loop calibration

• Unit 2 train A residual heat removal pump system outage

• Unit 2 train A containment spray pump system outage

• Unit 2 turbine driven auxiliary feedwater pump system outage

b. Findings

No findings of significance were identified.

==1R20 Refueling and Other Outage Activities

a. Inspection Scope

==

The inspectors performed the inspection activities described below for the Unit 2 refueling outage that began on March 07, 2010. The inspectors confirmed that, when the licensee removed equipment from service, the licensee maintained defense-in-depth commensurate with the outage risk control plan for key safety functions and applicable technical specifications and that configuration changes due to emergent work and unexpected conditions were controlled in accordance with the outage risk control plan.

Documents reviewed are listed in the Attachment. Inspection activities included:

• Prior to the outage, the resident inspectors reviewed the licensees integrated risk control plan to verify that activities, systems, and/or components which could cause unexpected reactivity changes were identified in the outage risk plan.

• Observed portions of the plant shutdown and cooldown to verify that the technical specification cooldown restrictions were followed.

• Reviewed reactor coolant system pressure, level, and temperature instruments to verify that the instruments provided accurate indication and that allowances were made for instrumentation errors.

• Verified that outage work did not impact the operation of the spent fuel cooling system.

• Reviewed the status and configuration of electrical systems to verify that those systems met technical specification requirements and the licensees outage risk control plan.

• Observed decay heat removal parameters to verify that the system was properly functioning and providing cooling to the core, specifically during hot mid-loop operations.

• Reviewed system alignments to verify that the flow paths, configurations and alternative means for inventory addition were consistent with the outage risk plan.

• Reviewed selected control room operations to verify that the licensee was controlling reactivity in accordance with the technical specifications.

• Observed the licensees control of containment penetrations to verify that the requirements of the technical specifications were met.

• Reviewed the licensees plans for changing plant configuration to verify that technical specifications, license conditions, and other requirements, commitments, and administrative procedure prerequisites were met prior to changing plant configuration.

• Observed refueling activities for compliance with Technical Specifications, to verify proper tracking of fuel assemblies from the spent fuel pool to the core, and to verify foreign material exclusion was maintained.

b. Findings

No findings of significance were identified.

==1R22 Surveillance Testing

a. Inspection Scope

==

The inspectors reviewed the following seven surveillance test procedures and either observed the testing or reviewed test results to verify that testing was conducted in accordance with the procedures and the acceptance criteria adequately demonstrated that the equipment was operable. Additionally, the inspectors reviewed the CR database to verify the licensee had adequately identified and implemented appropriate corrective actions for surveillance test problems.

Surveillance Tests

• 14980A-1 Rev 23, Diesel Generator 1A Operability Test (fast start)

• 14701B-2 Rev.6, Reactor Trip Breaker Train B UV and Shunt Trip Test

• 21391-C, Rev. 3, Main Feed Isolation Valve Accumulator Gas Pressure Channel Calibration

• 14617-2 Rev. 14, SSPS Slave Relay K 609 Train B Test Safety Injection

In-Service Tests (IST)

• 14804A-2 Rev. 4.0, Safety Injection Pump A Inservice and Response Time Test

Containment Isolation Valve (CIV)

• 84400-2 Rev. 5, Containment Integrated Leak Rate Test

• 14341-2 Rev. 7, Containment Penetration No. 41 Safety Injection Test Line Local Leak Rate Test

b. Findings

No findings of significance were identified.

1EP6 Drill Evaluation

a. Inspection Scope

The inspectors reviewed the facility activation exercise guide and observed the following emergency response activity to verify the licensee was properly classifying emergency events, making the required notifications, and making appropriate protective action recommendations in accordance with procedures 91001-C, Emergency Classifications, and 91305-C, Protective Action Guidelines.

• On February 17, the licensee conducted an emergency preparedness drill involving a turbine load reject concurrent with a loss of all annunciators, followed by a loss of coolant accident concurrent with a loss of all feedwater, which eventually lead to a tube rupture in S/G #4 and an uncontrolled release of activity due to a stuck open atmospheric relief valve. The technical support center, emergency operations facility and operations support center were activated and the site participated in the exercise.

b. Findings

No findings of significance were identified.

2RS1 Radiological Hazard Assessment and Exposure Controls

a. Inspection Scope

Hazard Assessment and Instructions to workers During facility tours, the inspectors directly observed labeling of radioactive material and postings for radiation areas, high radiation areas (HRAs), and airborne radioactivity areas established within the radiologically controlled area (RCA) of the Unit 2 (U2) containment, Unit 1 (U1) and U2 auxiliary buildings, and radioactive waste (radwaste) processing and storage locations.

The inspectors independently measured radiation dose rates or directly observed conduct of licensee radiation surveys for selected RCA areas. The inspectors reviewed survey records for several plant areas including surveys for alpha emitters, hot particles, airborne radioactivity, gamma surveys with a range of dose rate gradients, and pre-job surveys for upcoming tasks. The inspectors also discussed changes to plant operations that could contribute to changing radiological conditions since the last inspection. For selected outage jobs, the inspectors attended pre-job briefings and reviewed radiation work permit (RWP) details to assess communication of radiological control requirements and current radiological conditions to workers.

Hazard Control and Work Practices The inspectors evaluated access barrier effectiveness for selected U1 and U2 Locked High Radiation Area (LHRA) and Very High Radiation Area (VHRA) locations. Changes to procedural guidance for LHRA and VHRA controls were discussed with health physics (HP) supervisors. Controls and their implementation for storage of irradiated material within the spent fuel pool (SFP) were reviewed and discussed in detail. Established radiological controls (including airborne controls) were evaluated for selected U2 Refueling Outage 14 (2R14) tasks including pressurizer code safety removal, steam generator (S/G) eddy current testing, work in auxiliary building HRAs, and radwaste processing and storage. In addition, licensee controls for areas where dose rates could change significantly as a result of plant shutdown and refueling operations were reviewed and discussed.

Occupational workers adherence to selected RWPs and HP technician (HPT)proficiency in providing job coverage were evaluated through direct observations and interviews with licensee staff. Electronic dosimeter (ED) alarm set points and worker stay times were evaluated against area radiation survey results for pressurizer code safety removal and S/G eddy current testing. ED alarm logs were reviewed and worker response to dose and dose rate alarms during selected work activities was evaluated.

For HRA tasks involving significant dose rate gradients, e.g. S/G maintenance activities, the inspectors evaluated the use and placement of whole body and extremity dosimetry to monitor worker exposure.

Control of Radioactive Material The inspectors observed surveys of material and personnel being released from the RCA using small article monitor, personnel contamination monitor, and portal monitor instruments. The inspectors reviewed the last two calibration records for selected release point survey instruments and discussed equipment sensitivity, alarm setpoints, and release program guidance with licensee staff.

The inspectors compared recent 10 Code of Federal Regulations (CFR) Part 61 results for the Dry Active Waste radioactive waste stream with radionuclides used in calibration sources to evaluate the appropriateness and accuracy of release survey instrumentation.

The inspectors also reviewed records of leak tests on selected sealed sources and discussed nationally tracked source transactions with licensee staff.

Problem Identification and Resolution Condition Reports (CR)s associated with radiological hazard assessment and control were reviewed and assessed. The inspectors evaluated the licensees ability to identify and resolve the issues in accordance with procedure NMP-GM-002, Corrective Action Program, Ver. 9. The inspectors also evaluated the scope of the licensees internal audit program and reviewed recent assessment results.

Radiation protection activities were evaluated against the requirements of Updated Final Safety Analysis Report (UFSAR) Section 12; Technical Specifications (TS) Sections 5.4 and 5.7; 10 CFR Parts 19 and 20; and approved licensee procedures. Licensee programs for monitoring materials and personnel released from the RCA were evaluated against 10 CFR Part 20 and IE Circular 81-07, Control of Radioactively Contaminated Material. Documents reviewed are listed in Section 2RS1 of the Attachment.

The inspectors completed all specified line-items detailed in Inspection Procedure (IP)71124.01 (sample size of 1).

b. Findings

No findings of significance were identified.

2RS2 As Low As Reasonably Achievable (ALARA)

a. Inspection Scope

ALARA Program Status The inspectors reviewed and discussed plant exposure history and current trends including the sites three-year rolling average (TYRA) collective exposure history for calendar year (CY) 2007 through CY 2009. Current and proposed activities to manage site collective exposure and trends regarding collective exposure were evaluated through review of previous TYRA collective exposure data and review of the licensees 5-year ALARA program implementing plan. Current ALARA program guidance and recent changes, as applicable, regarding estimating and tracking exposure were discussed and evaluated.

Radiological Work Planning The inspectors reviewed planned work activities and their collective exposure estimates for the current 2R14 outage. Work activities, exposure estimates and mitigation activities were reviewed for the following high collective exposure tasks: U2 S/G eddy current test activities; reactor head disassembly and re-assembly; U2 containment scaffold installation and removal; and coatings, painting and all associated work in U2 containment. For the selected tasks, the inspectors reviewed dose mitigation actions and established dose goals. During the inspection, use of remote technologies including teledosimetry and remote visual monitoring were verified as specified in RWP or procedural guidance. Current collective dose data for selected tasks were compared with established estimates and, where applicable, changes to established estimates were discussed with responsible licensee ALARA planning representatives. The inspectors reviewed previous post-job reviews conducted for the U1 Refueling Outage 15 (1R15) outage and verified that the items were entered into the licensees corrective action program for evaluation.

Verification of Dose Estimates and Exposure Tracking Systems The inspectors reviewed select ALARA work packages and discussed assumptions with responsible planning personal regarding the bases for the current estimates. The licensees on-line RWP cumulative dose data bases used to track and trend current personal and cumulative exposure data and/or to trigger additional ALARA planning activities in accordance with current procedures were reviewed and discussed. Selected work-in-progress reviews for S/G secondary side activities and adjustments to cumulative exposure estimate data were evaluated against work scope changes or unanticipated elevated dose rates.

Source Term Reduction and Control The inspectors reviewed historical dose rate trends for shutdown chemistry, cleanup, and resultant chemistry and radiation protection trend-point data against the current 2R14 data. Licensee actions to mitigate noble gas and iodine exposures resulting from fuel leaks were discussed in detail.

Corrective Action Program (CAP) Review The inspectors reviewed and discussed selected CAP documents associated with ALARA program implementation. The reviewed items included CRs, self-assessments, and quality assurance audit documents.

The inspectors evaluated the licensees ability to identify, characterize, prioritize, and resolve the identified issues in accordance with licensee procedure NMP-GM-002-001, Corrective Action Program Instructions, Rev. 15.

The licensees ALARA program activities and results were evaluated against the requirements of UFSAR Section 12; TS Sections 5.4 and 5.7; 10 CFR Parts 19 and 20; and approved licensee procedures. Records reviewed are listed in Sections 2RS1 and 2RS2 of the report Attachment.

Radiation worker performance was reviewed as part of observations conducted for IP 71124.01 and is documented in section 2RS1. The inspectors completed all specified line-items detailed in IP 71124.02 (sample size of 1).

b. Findings

No findings of significance were identified.

2RS3 In-Plant Airborne Radioactivity Control and Mitigation

a. Inspection Scope

Engineering Controls The inspectors reviewed the use of temporary and permanent engineering controls to mitigate airborne radioactivity inside U2 containment during the

2R14 refueling outage. The inspectors observed the use of negative pressure units

(NPU)s and vacuums to control contamination during S/G eddy current testing and reviewed NPU testing records. The inspectors also observed cavity covers (tenting)used to reduce airborne radioactivity emanating from the refuel cavity. Use of containment purge to reduce airborne levels in general areas was reviewed. The inspectors evaluated the effectiveness of continuous air monitors and air samplers placed in work area breathing zones to provide indication of increasing airborne levels.

Respiratory Protection Equipment The inspectors reviewed the use of respiratory protection devices to limit the intake of radioactive material. This included review of devices used for routine tasks and devices stored for use in emergency situations. The inspectors reviewed ALARA evaluations for the use of respiratory protection devices during nozzle dam installation and removal inside U2 S/Gs 1 and 3. Selected Self-Contained Breathing Apparatus (SCBA) units and negative pressure respirators (NPR)s staged for routine and emergency use in the Main Control Room and other locations were inspected for material condition, SCBA bottle air pressure, number of units, and number of spare masks and air bottles available. The inspectors reviewed maintenance records for selected SCBA units for the past two years and evaluated SCBA and NPR compliance with National Institute for Occupational Safety and Health certification requirements. The inspectors also reviewed records of air quality testing for supplied-air devices and SCBA bottles.

Due to limited respirator use during the period of inspection, the inspectors reviewed training curricula for various types of respiratory protection devices and interviewed radworkers and control room operators on use of the devices including SCBA bottle change-out and use of corrective lens inserts. Respirator qualification records and medical fitness cards were reviewed for several Main Control Room operators and emergency responder personnel in the Maintenance and HP departments. In addition, qualifications for individuals responsible for testing and repairing SCBA vital components were evaluated through review of training records.

Problem Identification and Resolution CRs associated with airborne radioactivity mitigation and respiratory protection were reviewed and assessed. The inspectors evaluated the licensees ability to identify and resolve the issues in accordance with procedure NMP-GM-002, Corrective Action Program, Ver. 9. Documents reviewed are listed in section 2RS3 of the Attachment.

Licensee activities associated with the use of engineering controls and respiratory protection equipment were reviewed against 10 CFR Part 20; UFSAR Chapter 12; RG 8.15, Acceptable Programs for Respiratory Protection; NL-09-1048, Safety Evaluation Related to Use of Respiratory Protection Equipment With a Protection Factor of 5000; and applicable licensee procedures. Documents reviewed during the inspection are listed in Section 2RS3 of the Attachment.

The inspectors completed all specified line-items detailed in IP 71124.03 (sample size of 1).

b. Findings

No findings of significance were identified.

2RS4 Occupational Dose Assessment

a. Inspection Scope

Occupational Dose Assessment Status The inspectors evaluated current HP program activities related to internal and external dose monitoring and exposure results for occupational workers. The review included changes to the program guidance and equipment, as applicable; quality assurance activities and response to identified issues and individual dose results for workers.

External Dosimetry The inspectors reviewed and discussed recent implementation of the use of optically stimulated luminescent (OSL) dosimeters for monitoring and assigning worker doses, and verified National Voluntary Laboratory Accreditation Program certification data for the subject equipment. Calibration requirements for ED use, and results of OSL and ED dose result comparisons were discussed in detail. Program guidance for storage and processing of dosimeters, and results for the personnel monitoring were discussed.

Internal Dosimetry Program guidance, detection capabilities, and select whole whole-body counter (WBC) analysis results for routine (termination), follow-up, or for special bioassays were evaluated. The evaluation included review and discussion of whole body analysis and internal dose assessments for approximately 18 worker intakes of radioactive material identified during the CY 2009 1R15 outage.

Special Dosimetric Situations The inspectors reviewed monitoring conducted and results for non-routine dosimetric situations. The methodology and results of monitoring occupational workers within non-uniform external dose fields for steam generator maintenance workers were evaluated. In addition, the adequacy of dosimetry program guidance and its implementation were reviewed for the following program areas:

declared pregnant workers documented in licensee records since January 1, 2008; monitoring conducted and results for shallow dose evaluations in response to noble gas exposure, dispersed contamination, and/or discrete radioactive particles during the previous 1R15 and current 2R14 outages; and neutron monitoring conducted during two recent at-power entries. Proficiency of HP staff involved in skin dose assessments, neutron monitoring, and WBC operations were evaluated through direct interviews, onsite observations, and review and discussions of data for completed records.

Capabilities for in-vitro bioassays for alpha monitoring were reviewed and discussed with licensee representatives.

CAP Review The inspectors reviewed and discussed selected CAP documents associated with implementation of the licensees occupational dose assessment program implementation. The reviewed items included CR, self-assessment, and quality assurance audit documents. The inspectors evaluated the licensees ability to identify, characterize, prioritize, and resolve the identified issues in accordance with licensee procedure NMP-GM-002-001, Corrective Action Program Instructions, Rev. 15.

HP program occupational dose assessment activities were evaluated against the requirements of the UFSAR Section 12; TS Sections 5.4 and 5.7; 10 CFR Parts 19 and 20; and approved licensee procedures. Records reviewed are listed in Sections 2RS4 of the Attachment.

Radiation worker performance was reviewed as part of observations conducted for IP 71124.01 and is documented in section 2RS1. The inspectors completed all specified line-items detailed in IP 71124.04 (sample size of 1).

b. Findings

No findings of significance were identified.

4OA1 Performance Indicator (PI) Verification

.1 Mitigating Systems Cornerstone

a. Inspection Scope

The inspectors sampled licensee submittals for the listed PIs during the period from January 1, 2009, through December 31, 2009, for Unit 1 and Unit 2. The inspectors verified the licensees basis in reporting each data element using the PI definitions and guidance contained in procedure 00163-C, NRC Performance Indicator and Monthly Operating Report Preparation and Submittal, and Nuclear Energy Institute document NEI 99-02, Regulatory Assessment Indicator Guideline.

• Unplanned Scrams per 7,000 Critical Hours

• Unplanned Scrams with Complications

• Unplanned Power Changes per 7,000 Critical Hours

The inspectors reviewed Unit 1 and Unit 2 operator log entries, the Vogtle Electric Generating Plant Unit 1 and Unit 2 NRC Mitigating System Performance Index Basis Document, the monthly operating reports and monthly PI summary reports to verify that the licensee had accurately submitted the PI data.

b. Findings

No findings of significance were identified.

.2 Radiation Safety Cornerstone

a. Inspection Scope

Occupational Radiation Safety Cornerstone The inspectors reviewed the Occupational Exposure Control Effectiveness PI results for the Occupational Radiation Safety Cornerstone from July 2009 to December 2009. For the assessment period, the inspectors reviewed ED alarm logs and selected CRs related to controls for exposure significant areas. The inspectors also reviewed licensee procedural guidance for collecting and documenting PI data. Documents reviewed are listed in sections 2RS1 and 4OA1 of the Attachment.

Public Radiation Safety Cornerstone The inspectors reviewed the Radiological Effluent Technical Specification/Offsite Dose Calculation Manual Radiological Effluent Occurrences PI results from January through December 2009. The inspectors reviewed CAP documents, effluent dose data, and licensee procedural guidance for classifying and reporting PI events. The inspectors also interviewed licensee personnel responsible for collecting and reporting the PI data. Reviewed documents are listed in Section 4OA1 of the Attachment.

The inspectors completed two of the required samples specified in IP 71151.

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems

.1 Daily Condition Report Review.

As required by Inspection Procedure 71152, Identification and Resolution of Problems, and in order to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensees corrective action program. This review was accomplished by either attending daily screening meetings that briefly discussed major CRs, or accessing the licensees computerized corrective action database and reviewing each CR that was initiated.

.2 Focused Review

a. Inspection Scope

The inspectors performed a detailed review of the following CRs which both address the licensees capability to close the equipment hatch prior to boiling following a loss of RHR at reduced inventory conditions. The goal of the review was to verify that the full extent of the issue was identified, an appropriate evaluation was performed, and appropriate corrective actions were specified and prioritized. The inspectors evaluated the CRs against the licensee?s corrective action program as delineated in licensee procedure NMP-GM-002, Corrective Action Program, and 10 CFR 50, Appendix B. Documents reviewed are listed in the Attachment.

• CR 2008108006, Compliance with NEI 91-06 with respect to equipment hatch closure times; and CR 2009108487, Request engineering develop RCS time-to-boil data for incorporation into unit operating procedures

b. Findings and Observations

No findings of significance were identified.

4OA3 Event Follow-up

.1 (Closed) Licensee Event Report 05000425/2006-004:

Engineered Safety Feature (ESF)

Room Cooler Determined to be in a Condition Prohibited by Technical Specifications

On October 01, 2006, ESF room cooler 2-1555-A7-003 was found running with no discernable air flow to the ESF equipment room. An investigation by the licensee determined that the failure was due to reversed motor leads causing the fan to rotate backwards. The inspectors reviewed the LER, the associated condition report, and subsequent action items. The enforcement aspects of this finding are discussed in Section 4OA7.

.2 (Closed) Licensee Event Report 05000425/2007-001:

Reactor Water Storage Tank (RWST) Sludge Mixing System Valves in a Condition Prohibited by Technical Specifications

On January 01, 2007, RWST sludge mixing valves 2HV-10957 and 2HV-10958 were discovered to be inoperable for 24 days due to inadvertently being left on the jack in an open condition during a clearance tag restoration evolution. An investigation by the licensee determined that operators made incorrect assumptions on how the valves jacking system worked which resulted in the inoperability of the valves. The inspectors reviewed the LER, the associated condition report, and subsequent action items. No findings of significance were identified.

.3 (Closed) Licensee Event Report 05000425/2007-002:

Unit 2 Main Generator tripped resulting in an Automatic Reactor Trip

On April 23, 2007, Unit 2 experienced an automatic reactor trip from approximately 54%

power during power ascension following completion of refueling outage 2R12. The reactor trip was caused by a main generator trip resulting from a generator neutral over current condition caused by a ground fault on the A phase bushing. An investigation by the licensee determined that the ground fault was due to a design deficiency in the main generator bushing tang assembly. The inspectors reviewed the LER, the associated condition report, and subsequent action items. No findings of significance were identified.

4OA5 Other Activities

.1 (Closed) URI 05000424,425/2008009-01 Technical Specification Operability of the

NSCW System with the Cooling Tower Return Valves in Manual Control

a. Inspection Scope

The inspectors performed a review of Task Interface Agreement (TIA) 2009-008, Operability of the Nuclear Service Cooling Water system - Vogtle Electric Generating Plant.

b. Findings and Observations

Findings were documented in NRC integrated inspection report 05000424/2009005 and 05000425/2009005. This URI is being closed for administrative purposes only.

.2 Quarterly Resident Inspector Observations of Security Personnel and Activities

a. Inspection Scope

During the inspection period, the inspectors conducted observations of security force personnel and activities to ensure that the activities were consistent with licensee security procedures and regulatory requirements relating to nuclear plant security. These observations took place during both normal and off-normal plant working hours.

b. Findings and Observations

No findings of significance were identified.

4OA6 Meetings, Including Exit

.1 Exit Meeting

On April 19, 2010, the resident inspectors presented the inspection results to you and other members of your staff, who acknowledged the findings. The inspectors confirmed that proprietary information was not provided or examined during the inspection.

4OA7 Licensee Identified Violations

The following violation of very low safety significance (Green) was identified by the licensee and determined to be a violation of NRC requirements which meet the criteria of the NRC Enforcement Policy, for being dispositioned as a Non-Cited Violation.

• 10CFR50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Contrary to the above, the VEGP Work Order Functional Test procedure (29401-C) was not adequate in that it lacked specific guidance to conduct a fan rotational check following any maintenance resulting in the determination of ESF fan motor electrical cables. This finding is of very low safety significance (Green) due to the fact that subsequent analysis performed to evaluate the impact to electrical equipment concluded all associated safety-related equipment would have continued to perform its intended function and did not result in the loss of safety system function. The licensee has documented this condition in CR 2006110981.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

R. Brigdon, Training and Emergency Preparedness Manager

C. Buck, Chemistry Manager

W. Copeland, Performance Analysis Supervisor

R. Dedrickson, Plant Manager

K. Dyar, Security Manager

M. Hickox, Licensing Engineer

I. Kochery, Health Physics Manager

L. Mansfield, Site Engineering Director

D. McCary, Operations Manager

S. Swanson, Site Support Manager

T. Tynan, Site Vice-President

NRC personnel

S. Shaeffer, Chief, Region II Reactor Projects Branch 2

M. Cain, Senior Resident Inspector

T. Chandler, Resident Inspector

LIST OF ITEMS

OPENED AND CLOSED

OPEN AND CLOSED

05000425/2010002-01 NCV Ineffective Corrective Action Renders Unit 2 CCW Pump

1. 4 Inoperable (Section 1R12)

CLOSED

05000425/2006-004 LER Engineered Safety Feature (ESF) Room Cooler Determined to be in a Condition Prohibited by Technical Specifications (Section 4OA3.1)

05000425/2007-001 LER Reactor Water Storage Tank (RWST) Sludge Mixing System Valves in a Condition Prohibited by Technical Specifications (Section 4OA3.2)

05000427/2007-002 LER Unit 2 Main Generator tripped resulting in an Automatic Reactor Trip (Section 4OA3.3)

05000424,425/2008009-01 URI Technical Specification Operability of the NSCW System with the Cooling Tower Return Valves In Manual Control (Section 4OA5.1)