IR 05000424/2013005
| ML14031A326 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 01/31/2014 |
| From: | Frank Ehrhardt NRC/RGN-II/DRP/RPB2 |
| To: | Tynan T Southern Nuclear Operating Co |
| References | |
| IR-13-005, IR-13-502 | |
| Download: ML14031A326 (27) | |
Text
UNITED STATES January 31, 2014
SUBJECT:
VOGTLE ELECTRIC GENERATING PLANT - NRC INTEGRATED INSPECTION REPORT 05000424/2013005, 05000425/2013005, 05000424/2013502, AND 05000425/2013502
Dear Mr. Tynan:
On December 30, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Vogtle Electric Generating Plant, Units 1 and 2. On January 15, 2014, the NRC inspectors discussed the results of this inspection with you and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.
NRC inspectors documented one finding of very low safety significance (Green) in this report.
This finding involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.
If you contest the violation or significance of the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, U.S.
Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the Vogtle Electric Generating Plant.
If you disagree with a cross-cutting aspect assignment 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.
As a result of the Safety Culture Common Language Initiative, the terminology and coding of cross-cutting aspects were revised beginning in calendar year (CY) 2014. New cross-cutting aspects identified in CY 2014 will be coded under the latest revision to IMC 0310. Cross-cutting aspects identified in the last six months of 2013 using the previous terminology will be converted to the latest revision in accordance with the cross-reference in IMC 0310. The revised cross-cutting aspects will be evaluated for cross-cutting themes and potential substantive cross-cutting issues in accordance with IMC 0305 starting with the CY 2014 mid-cycle assessment review. In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Request for Withholding, 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 NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRCs Agencywide Documents Access and Management 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/
Frank Ehrhardt, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket Nos.: 05000424, 05000425 License Nos.: NPF-68 and NPF-81
Enclosures:
Inspection Report 05000424/2013005, 05000425/2013005, 05000424/2013502, and 05000425/2013502 w/Attachment: Supplemental Information
REGION II==
Docket Nos.: 50-424, 50-425 License Nos.: NPF-68, NPF-81 Report Nos.: 05000424/2013005, 05000425/2013005, 05000424/2013502, and 05000425/2013502 Licensee: Southern Nuclear Operating Company, Inc. (SNC)
Facility: Vogtle Electric Generating Plant, Units 1 and 2 Location: Waynesboro, GA 30830 Dates: October 01, 2013 through December 30, 2013 Inspectors: M. Cain, Senior Resident Inspector T. Chandler, Resident Inspector D. Hardage, Resident Inspector (Hatch)
B. Caballero, Senior Operations Engineer (1R11.3)
J. Laughlin, Emergency Preparedness Inspector (1EP4)
Approved by: Frank Ehrhardt, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000424/2013005, 05000425/2013005, 05000424/2013502, 05000425/2013502; 10/01/2013 - 12/31/2013; Vogtle Electric Generating Plant, Units 1 and 2; Post Maintenance Testing The report covered a three-month period of inspection by three resident inspectors, a senior reactor operations engineer and an emergency preparedness inspector. One self-revealing non-cited violation (NCV) with very low safety significance (Green) was identified. The significance of inspection findings are indicated by their color (i.e., great than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process dated June 19, 2012. Cross-cutting aspects are determined using IMC 0310, Components Within The Cross-Cutting Areas dated October 28, 2011. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated July 9, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process Revision 4.
Cornerstone: Mitigating Systems
Green: A Green, self-revealing non-cited violation (NCV) of plant Technical Specification (TS) 3.8.4, DC Sources - Operating, was identified for failure to meet the conditions of TS limiting condition for operation (LCO) 3.8.4. Specifically, placing the 1AD1CA battery charger out of service during performance of the 18 month load test surveillance, concurrent with the failure of the 1AD1CB battery charger, caused the 1A train chargers to be unable to fulfill their specified safety function. As a result, the 1AD1 safety-related 1E 125 VDC source was inoperable. The 1AD1CB battery charger was repaired, functionally tested, and placed back in service. This violation was entered into the licensees corrective action program as condition report (CR) 735160.
The finding was more than minor because it was associated with the equipment performance attribute of the mitigating systems cornerstone and it adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage).
Specifically, removing the 1AD1CA battery charger from service to conduct a 18 month load test while the 1AD1CB battery charger was not capable of performing its specified safety function resulted in the loss of a single train for greater than its TS allowed outage time. The inspector evaluated the finding in accordance with IMC 0609 Appendix A,
The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012. Since the inspectors answered Yes to the question A.3 of the Mitigating Systems Screening Questions, Does the finding represent an actual loss of function of at least a single Train for greater than its TS allowed outage time, a detailed risk evaluation was required. A detailed risk evaluation was performed by resident inspectors and reviewed by a regional senior reactor analyst in accordance IMC 0609 Appendix A guidance using the NRC Vogtle Standardized Plant Analysis Risk (SPAR)model and the NRC Saphire 8 risk analysis code. An SDP Module Condition Analysis was run with the Unit 1 A train battery chargers, 1AD1CA and 1AD1CB failed with no recovery allowed for a 14 hour1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> exposure period. The dominant sequence was a transient consisting of a reactor trip coincident with the common cause failure of auxiliary feed pumps (AFW) to run and the inability of an operator to restore main feedwater (MFW). The detailed risk evaluation determined that the risk due to the performance deficiency was an increase in core damage frequency (CDF) of <1E-7/year, a GREEN finding of very low safety significance. Because the increase in CDF was <1E-7/year no external events analysis was required. The risk was mitigated by the availability of alternate trains of components and the short exposure period. The detailed risk evaluation was reviewed by a regional senior reactor analyst. The inspectors determined that the cause of this finding was related to the corrective action program (CAP) component of the problem identification and resolution (PI&R) cross-cutting area due to less-than-adequate problem evaluation techniques. Specifically, licensee failed to adequately investigate why the wires were rolled during initial functional testing.
P.1(c) (Section 1R19)
REPORT DETAILS
Summary of Plant Status
Unit 1 operated at or near full rated thermal power (RTP) for the entire inspection period.
Unit 2 began the inspection period at or near full RTP. On October 19, the unit tripped due to a turbine trip. A Unit 2 reactor startup was conducted on October 21, and the unit achieved 25 percent of RTP on October 22 when the unit was manually tripped due to low vacuum in the main condenser. A Unit 2 reactor startup was conducted on October 24, and the unit achieved full RTP on November 4. Unit 2 remained at or near full RTP for the remainder of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
1R01 Adverse Weather Protection
.1 Seasonal Extreme Weather Conditions
a. Inspection Scope
The inspectors conducted a detailed review of the stations adverse weather procedures written for extreme low temperatures. The inspectors verified that weather related equipment deficiencies identified during the previous year had been corrected prior to the onset of seasonal extremes. The inspectors evaluated the licensees implementation of adverse weather preparation procedures and compensatory measures before the onset of seasonal extreme weather conditions. Documents reviewed are listed in the Attachment. The inspectors evaluated the following risk-significant systems:
- Unit 1 refueling water storage tank (RWST) instrumentation
- Unit 2 RWST instrumentation
b. Findings
No findings were identified.
.2 Impending Adverse Weather Conditions
a. Inspection Scope
The inspectors reviewed the licensees preparations to protect risk-significant systems from predicted severe weather conditions of sub-freezing temperatures expected on November 13. The inspectors evaluated the licensees implementation of adverse weather preparation procedures and compensatory measures, including operator staffing, before the onset of and during the adverse weather conditions. The inspectors reviewed the licensees plans to address the ramifications of potentially lasting effects that may result from sub-freezing temperatures. The inspectors verified that operator actions specified in the licensees adverse weather procedure maintain readiness of essential systems. The inspectors verified that required surveillances were current, or were scheduled and completed, if practical, before the onset of anticipated adverse weather conditions. The inspectors also verified the licensee implemented periodic equipment walk-downs or other measures to ensure that the condition of plant equipment met operability requirements. Documents reviewed are listed in the
.
b. Findings
No findings were identified.
1R04 Equipment Alignment
a. Inspection Scope
.1 Partial Walkdown
The inspectors verified that critical portions of selected risk-significant systems were correctly aligned. The inspectors selected systems for assessment because they were a redundant or backup system/train, were important for mitigating risk for the current plant conditions, had been recently realigned, or were a single-train system. The inspectors determined the correct system lineup by reviewing plant procedures and drawings. The inspectors verified that critical portions of the selected systems were correctly aligned by performing partial walkdowns. Documents reviewed are listed in the Attachment. The inspectors selected the following three systems/trains to inspect:
- Unit 1 train A spent fuel pool cooling and purification system during the train B spent fuel pool cooling and purification system maintenance outage
- Unit 2 train A nuclear service cooling water (NSCW) system while maintenance was being performed on the train B NSCW cooling tower fans
- Unit 1 train A emergency diesel generator (EDG) during the B train EDG 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> surveillance run
.2 Complete Walkdown
The inspectors verified the alignment of the Unit 1 125V DC 1E electrical distribution system. The inspectors selected this system for assessment because it is a risk-significant mitigating system. The inspectors determined the correct system lineup by reviewing plant procedures, drawings, the updated final safety analysis report, and other documents. In order to identify any deficiencies that could affect the ability of the system to perform its functions, the inspectors reviewed records related to outstanding design issues and maintenance work requests. The inspectors verified that the selected system was correctly aligned by performing a complete walk down of accessible components.
To verify the licensee was identifying and resolving equipment alignment discrepancies, the inspectors reviewed corrective action documents, including condition reports and outstanding work orders, as well as periodic reports containing information on the status of risk-significant systems, including maintenance rule reports and system health reports. Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
1R05 Fire Protection
a. Inspection Scope
.1 Quarterly Inspection
The inspectors evaluated the adequacy of selected fire plans by comparing the fire plans to the defined hazards and defense-in-depth features specified in the fire protection program. In evaluating the fire plans, the inspectors assessed the following items:
1) control of transient combustibles and ignition sources; 2) fire detection systems; 3) water-based fire suppression systems; 4) gaseous fire suppression systems; 5) manual firefighting equipment and capability; 6) passive fire protection features; 7) compensatory measures and fire watches; and 8) issues related to fire protection contained in the licensees corrective action program. The inspectors toured the following five fire areas to assess material condition and operational status of fire protection equipment. Documents reviewed are listed in the Attachment.
- Unit 1 and 2 spent fuel pool area, fire zone 139
- Unit 2 north and south main steam valve house, fire zones 99, 45 and 104
- Unit 1 and 2 main control rooms and the technical support center, fire zones 105, 106, 183A, 601, 602, 603, 604, and 605
- Unit 1 component cooling water (CCW) pump rooms, fire zones 36 and 37
- Unit 2 A train and B train cable spreading rooms, fire zones 94, 95, 173, 174, 107, 108, 120, and 121
b. Findings
No findings were identified.
1R06 Flood Protection Measures
a. Inspection Scope
.1 Internal Flooding
The inspectors reviewed related flood analysis documents and walked down the areas listed below that contain risk significant structures, systems, and components susceptible to flooding. The inspectors verified plant design features and plant procedures for flood mitigation were consistent with design requirements and internal flooding analysis assumptions. The inspectors also assessed the condition of flood protection barriers and drain systems. In addition, the inspectors verified the licensee was identifying and properly addressing issues using their corrective action program.
Documents reviewed are listed in the Attachment
- Unit 1 and 2 auxiliary feedwater (AFW) buildings
b. Findings
No findings were identified.
1R07 Heat Sink Performance
a. Inspection Scope
.1 Annual Review
The inspectors verified the readiness and availability of the Unit 2B auxiliary component cooling water (ACCW) heat exchanger to perform its design function by observing performance tests or reviewing reports of those tests, verifying the licensee uses the periodic maintenance method outlined in Generic Letter 89-13, Service Water System Problems Affecting Safety Related Equipment, observing the licensees heat exchanger inspections and verifying critical operating parameters through direct observation or by reviewing operating data. Additionally, the inspectors verified that the licensee had entered any significant heat exchanger performance problems into their corrective action program and that the licensees corrective actions were appropriate.
Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program
a. Inspection Scope
.1 Resident Inspector Quarterly Review of Licensed Operator Requalification:
The inspectors observed an evaluated simulator scenario administered to an operating crew conducted in accordance with the licensees accredited requalification training program.
The inspectors assessed licensed operator performance, the ability of the licensee to administer the scenario and evaluate the operators, the quality of any post-scenario critique, any follow-up actions taken by the facility licensee, and the performance of the simulator. Documents reviewed are listed in the Attachment.
.2 Resident Inspector Quarterly Review (Licensed Operator Performance):
The inspectors observed operator performance in the main control room on October 21, while a reactor startup was being performed. Inspectors observed licensed operator performance to assess the following:
- Use of plant procedures
- Control board manipulations
- Communications between crew members
- Use and interpretation of plant instruments, indications and alarms
- Use of human error prevention techniques, such as pre-job briefs and peer checking
- Documentation of activities
- Management and supervision of activities Documents reviewed are listed in the Attachment.
.3 Licensed Operator Requalification: Annual Review of Licensee Requalification
Examination Results On September 13, 2013, the licensee completed the annual requalification operating examinations required to be administered to all licensed operators in accordance with 10 CFR 55.59(a)(2). The inspectors performed an in-office review of the overall pass/fail results of the individual operating examinations and the crew simulator operating examinations in accordance with Inspection Procedure (IP) 71111.11, Licensed Operator Requalification Program. These results were compared to the thresholds established in Inspection Manual Chapter (IMC) 0609, Significance Determination Process, Appendix I, Operator Requalification Human Performance Significance Determination Process.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors assessed the licensees treatment of the two issues listed below in order to verify the licensee appropriately addressed equipment problems within the scope of the Maintenance Rule (10 CFR 50.65). The inspectors reviewed procedures and records in order to evaluate the licensees identification, assessment, and characterization of the problems as well as their corrective actions for returning the equipment to a satisfactory condition. Documents reviewed are listed in the Attachment.
The inspectors also interviewed system engineers and the maintenance rule coordinator to assess the accuracy of performance deficiencies and extent of condition.
- CR 711400 - Functional Failures for System 1817 (AFW heat tracing/freeze protection)
- CR 745522 - Unit 1 125 VDC System 1806 exceeded 75 percent of the maintenance rule criteria
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed the five maintenance activities listed below to verify the licensee assessed and managed plant risk as required by 10 CFR 50.65(a)(4) and licensee procedures. The inspectors assessed the adequacy of the licensees risk assessments and implementation of risk management actions. The inspectors also verified that the licensee was identifying and resolving problems with assessing and managing maintenance-related risk using the corrective action program. Additionally, for maintenance resulting from unforeseen situations, the inspectors assessed the effectiveness of the licensees planning and control of emergent work activities.
Documents reviewed are listed in the Attachment.
- Week of October 21: monthly surveillance run of the 1A EDG concurrent with the unplanned inoperability of the 1B ACCW pump
- Week of October 28: Unit 2 A train NSCW tower fan #2 out of service to replace the gearbox
- Week of November 11: Unit 2 B train NSCW fan #1 maintenance outage
- Week of December 2: Unit 2 B train NSCW tower fan #3 out of service for maintenance concurrent with the monthly surveillance on the 1B EDG
- Week of December 9: Unit 2 B train NSCW tower fan #3 out of service for maintenance concurrent with the monthly surveillance on the 2B EDG
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors selected the five operability determinations or functionality evaluations listed below for review based on the risk-significance of the associated components and systems. The inspectors reviewed the technical adequacy of the determinations to ensure that technical specification operability was properly justified and the components or systems remained capable of performing their design functions. To verify whether components or systems were operable, the inspectors compared the operability and design criteria in the appropriate sections of the technical specification and updated final safety analysis report to the licensees evaluations. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. Additionally, the inspectors reviewed a sample of corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with operability evaluations.
Documents reviewed are listed in the Attachment.
- CR 714240, Void found at 1-1204-X4-040/041
- CR 725597, Void detected near valve 1-1204-U4-143
- CR 720854, Unit 2 B train motor driven auxiliary feedwater (MDAFW) leaking 60 drops per minute at the outboard seal
- CR 720600, 1HV5230 is leaking hydraulic fluid
b. Findings
No findings were identified.
1R18 Plant Modifications
a. Inspection Scope
The inspectors verified that the plant modification listed below did not affect the safety functions of important safety systems. The inspectors confirmed the modifications did not degrade the design bases, licensing bases and performance capability of risk significant structures, systems and components. The inspectors also verified modifications performed during plant configurations involving increased risk did not place the plant in an unsafe condition. Additionally, the inspectors evaluated whether system operability and availability, configuration control, post-installation test activities, and changes to documents, such as drawings, procedures, and operator training materials, complied with licensee standards and NRC requirements. In addition, the inspectors reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with modifications. Documents reviewed are listed in the Attachment.
- Temporary Modification SNC536385 - Unit 2 CET Remote Shutdown Indication Restoration
b. Findings
No findings were identified.
1R19 Post Maintenance Testing
a. Inspection Scope
The inspectors either observed post-maintenance testing or reviewed the test results for the six maintenance activities listed below to verify the work performed was completed correctly and the test activities were adequate to verify system operability and functional capability. The inspectors evaluated these activities for the following: acceptance criteria were clear and demonstrated operational readiness; effects of testing on the plant were adequately addressed; test instrumentation was appropriate; tests were performed in accordance with approved procedures; equipment was returned to its operational status following testing; and test documentation was properly evaluated. Additionally, the inspectors reviewed a sample of corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with post-maintenance testing.
Documents reviewed are listed in the Attachment.
- Maintenance Work Order (MWO) SNC408289 - 1B SFPC pump - replace packing and o-rings
- MWO SNC383537-Z08 - (2A NSCW F2) - Rig and install new gearbox, and SNC383537-Z11 - (2A NSCW F2) - Align and couple fan
- MWO SNC534699 - Both 1AD1CA and 1AD1CB out of service at same time
- MWO SNC537331 - Unit 1B EDG would not auto synch
- MWO SNC489319 - B5B pump preventive maintenance
b. Findings
Introduction.
A Green, self-revealing non-cited violation (NCV) of plant Technical Specification (TS) 3.8.4, DC Sources - Operating was identified for failure to meet the conditions of TS limiting condition for operation (LCO) 3.8.4. Specifically, with the 1AD1CA battery charger out of service during performance of the 18 month load test surveillance, concurrent with the failure of the 1AD1CB battery charger, the 1A train chargers were unable to fulfill their specified safety function. As a result, the 1AD1, safety-related, 1E 125 VDC source was inoperable. The unit continued to operate in Mode 1 in excess of eight hours without performing the necessary actions within the applicable completion times.
Description.
In April of 2012, the Class 1E battery charger 1AD1CB was replaced with a newer Amertek Model: 85-CC4000-96, 400 amp battery charger. Condition report 441822 documented the discovery of rolled wires on the secondary rectifier bridge during the functional testing of 1AD1CB. The system engineer was consulted and work instructions were revised to de-terminate and re-terminate the wires in accordance with drawing AX3AD01B-00011. This work was performed on April 19, functional testing completed, and the charger declared operable on April 20, 2012.
On September 22, 2013, at 22:14, a charger failure alarm was received on 1AD1CB (CR 706647). The condition cleared the following morning at approximately 05:00. Later on September 23, 2013, charger 1AD1CB was removed from service for performance of a load test. The load test was completed satisfactorily and 1AD1CB was returned to service. Shortly after restoring 1AD1CB back to service, the Unit 1 control room received ALB34-E01, "BAT CHARGERS 1AD1CA 1AD1CB TROUBLE" alarm and dispatched operations and maintenance personnel to investigate. Field personnel discovered that charger 1AD1CB had the "Charger Failure" light lit; however, the condition cleared. These symptoms had been noted previously and diagnosed as the chargers not load sharing (CR 706647).
On September 30, 2013, at 06:09, battery charger 1AD1CA was removed from service for 18 month load testing and returned to service at 20:45 the same day.
On November 19, 2013, battery charger 1AD1CB tripped during troubleshooting activities (CR 735160). The licensee found that the 1AD1CB internal wiring was incorrect. The licensee performed a review of 1AD1CB history and determined that the initial wiring discrepancy occurred prior to receiving the battery charger from the vendor.
The vendor had altered the secondary rectifier wiring in order to make the charger fully functional; however, this was not identified to site personnel. Upon discovery of the discrepancy between the as-built condition and the approved plant drawings during the original functional test, SNC personnel rolled the wires in question back to the configuration documented on AX3AD01B-00011 and replaced the fuses. No additional action was taken at that time to determine why the discrepancy existed. The battery charger was functionally tested and placed back in-service on November 29.
Although degraded, adequate voltage capacity from the unaffected primary rectifier bridge and the degraded secondary rectifier bridge met all TS surveillance requirements.
As a result, 1AD1CB was placed in service in a degraded condition. Engineering review, verified by the resident inspectors, determined that the most probable cause of the original issue identified on September 22 was the failure of one additional fuse in the three-phase secondary rectifier bridge resulting in single-phasing of the bridge. This condition did not become evident until the investigation of the over-voltage shutdown of 1AD1CB on November 19, 2013. The licensee reviewed battery charger parameters and subsequently determined that when AC input power was cycled to 1AD1CB on September 23, a second fuse in the secondary rectifier bridge blew resulting in a single-phase condition of the secondary bridge. With a single-phase condition of the secondary bridge the 1AD1CB battery charger could not perform its specified safety function.
A past operability evaluation concluded that on September 30, 2013, from 06:09 to 20:45 when redundant charger 1AD1CA was removed from service, TS 3.8.4 was not met for an operable DC source (no operable battery charger) for approximately 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />. TS 3.8.4 requires restoration of the affected DC source within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, or the unit to be in mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
Analysis.
The failure to meet the conditions of TS LCO 3.8.4 was a performance deficiency. The finding was more than minor because it was associated with the equipment performance attribute of the mitigating systems cornerstone and it adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, removing the 1AD1CA battery charger from service to conduct a 18 month load test while the 1AD1CB battery charger was incapable of performing its specified safety function resulted in the loss of a single train of one DC electrical power source for greater than its TS allowed outage time.
Using IMC 0609, Attachment 4, Initial Characterization of Findings dated June 19, 2012, the inspectors determined that the finding affected the mitigating systems cornerstone. The inspectors evaluated the finding using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012.
The inspectors used the Initial Screening and Characterization of Findings (IMC 0609.04 dated June 19, 2012) Exhibit 2, Mitigating Systems Screening Questions, to characterize the finding. Since the inspectors answered Yes to the question A.3, Does the finding represent an actual loss of function of at least a single Train for greater than its TS allowed outage time, a detailed risk evaluation was required. A detailed risk evaluation was performed by resident inspectors in accordance IMC 0609 Appendix A guidance using the NRC Vogtle Standardized Plant Analysis Risk (SPAR) model and the NRC Saphire 8 risk analysis code. An SDP Module Condition Analysis was run with the Unit 1 A train battery chargers, 1AD1CA and 1AD1CB failed with no recovery allowed for a 14 hour1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> exposure period. The dominant sequence was a transient consisting of a reactor trip coincident with the common cause failure of auxiliary feed pumps (AFW) to run and the inability of an operator to restore main feedwater (MFW). The detailed risk evaluation determined that the risk due to the performance deficiency was an increase in core damage frequency (CDF) of <1E-7/year, a Green finding of very low safety significance. Because the increase in CDF was <1E-7/year no external events analysis was required. The risk was mitigated by the availability of alternate trains of components and the short exposure period. The detailed risk evaluation was reviewed by a regional senior reactor analyst. The inspectors determined that the cause of this finding was related to the corrective action program (CAP) component of the problem identification and resolution (PI&R) cross-cutting area due to less-than-adequate problem evaluation techniques. Specifically, the licensee failed to adequately investigate why the wires were rolled during initial functional testing. P.1(c)
Enforcement.
Technical Specification 3.8.4, DC Sources - Operating requires that four class 1E 125 VDC electrical power sources shall be operable during Modes 1-4.
Contrary to the above, on September 30, 2013, maintenance technicians removed safety-related battery charger 1AD1CA from service to conduct an 18 month load test surveillance while the 1AD1CB battery charger was inoperable. As a result of the error, the 1AD1 class 1E 125VDC battery source was rendered inoperable for approximately 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />. Technical specification LCO required actions were not completed within the applicable completion times. This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy. The violation was entered into the licensees corrective action program as CR 735160. (NCV 05000424/2013005-01, Failure to Meet the Conditions of TS LCO 3.8.4.)
1R22 Surveillance Testing
a. Inspection Scope
The inspectors reviewed the seven surveillance tests listed below and either observed the test or reviewed test results to verify testing adequately demonstrated equipment operability and met Technical Specification and licensee procedural requirements. The inspectors evaluated the test activities to assess for preconditioning of equipment, procedure adherence, and equipment alignment following completion of the surveillance.
Additionally, the inspectors reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with surveillance testing. Documents reviewed are listed in the Attachment.
Routine Surveillance Tests
- 24714-2 Rev. 38, Nuclear Instrumentation System Power Range Channel 2N44 Channel Calibration
- 14400A-2 Rev. 5.3, Train A Control Room Emergency Filtration Actuation Logic Test
- 14668B-1 Rev. 7.1, Train B Diesel Generator Operability Test
- 24813-2 Rev. 35.2, Delta T/T AVG Loop 4 Protection Channel IV 2T-441 Channel Operational Test and Channel Calibration In-Service Tests (IST)
- 14807B-2 Rev. 1.5, Train B Motor Driven Auxiliary Feedwater Pump/Check Valve Inservice and Response Time Test Reactor Coolant System Leak Detection
- 14905-1 Rev. 67.7, RCS Leakage Calculation (Inventory Balance)
- 14905-2 Rev. 51.6, RCS Leakage Calculation (Inventory Balance)
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP4 Emergency Action Level and Emergency Plan Changes
a. Inspection Scope
The NSIR headquarters staff performed an in-office review of the latest revisions of various Emergency Plan Implementing Procedures (EPIPs) and the Emergency Plan located under ADAMS accession numbers ML12346A413, ML13165A369, ML13088A044, and ML13283A175, as listed in the Attachment.
The licensee determined that in accordance with 10 CFR 50.54(q), the changes made in the revisions resulted in no reduction in the effectiveness of the Plan, and that the revised Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. The NRC review was not documented in a safety evaluation report and did not constitute approval of licensee-generated changes; therefore, these revisions are subject to future inspection. Documents reviewed are listed in the Attachment. This inspection activity satisfied one inspection sample for the emergency action level and emergency plan changes on an annual basis.
b. Findings
No findings were identified
1EP6 Drill Evaluation
a. Inspection Scope
The inspectors observed the emergency preparedness drill conducted on November 20, 2013. The inspectors observed licensee activities in the simulator and/or technical support center to evaluate implementation of the emergency plan, including event classification, notification, and protective action recommendations. The inspectors evaluated the licensees performance against inspection criteria established in the licensees procedures. Additionally, the inspectors attended the post-exercise critique to assess the licensees effectiveness in identifying emergency preparedness weaknesses and verified the identified weaknesses were entered in the corrective action program.
Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
a. Inspection Scope
.1 Barrier Integrity Cornerstone
The inspectors reviewed a sample of the performance indicator (PI) data, submitted by the licensee, for the PIs listed below. To verify the accuracy and completeness of the data reported for the station, the inspectors reviewed plant records compiled between October 1, 2012, and September 30, 2013, for both Unit 1 and Unit 2. The inspections verified that the PI data complied with guidance contained in NEI 99-02, Regulatory Assessment Indicator Guideline, and licensee procedures. The inspectors also confirmed the PIs were calculated correctly. In addition, the inspectors reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with PI data. Documents reviewed are listed in the Attachment.
Cornerstone: Mitigating Systems
- Safety System Functional Failures
- Emergency AC Power System
- Cooling Water System
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
a. Inspection Scope
.1 Routine Review
The inspectors performed a daily screening of items entered into the licensees corrective action program in order to identify repetitive equipment failures or specific human performance issues for follow-up. The inspectors reviewed daily condition reports, attended screening meetings, or accessed the licensees computerized corrective action database.
.2 Annual Follow-up of Selected Issues
The inspectors selected CR 721963 - Unit 2 Reactor Trip on October 22, 2013, at 1144, for detailed review. The inspectors evaluated the following attributes of the licensees actions:
- complete and accurate identification of the problem in a timely manner
- evaluation and disposition of operability/reportability issues
- consideration of extent of condition, generic implications, common cause, and previous occurrences
- classification and prioritization of the problem
- identification of root and contributing causes of the problem
- identification of any additional condition reports
- completion of corrective actions in a timely manner Documents reviewed are listed in the Attachment.
.3 Semi-Annual Trend Review
The inspectors reviewed the licensees corrective action program and associated documents to identify trends which could indicate the existence of a more significant safety issue. The inspectors focused their review on repetitive equipment issues, but also considered the results of inspector daily condition report screenings, licensee trending efforts, and licensee human performance results. The review nominally considered the six month period of March 2013 to October 2013 although some examples extended beyond those dates when the scope of the trend warranted. The inspectors compared their results with the results contained in the licensees trend documents. Additionally, the inspectors reviewed the adequacy of corrective actions associated with a sample of the issues identified in the licensees trend reports. The inspectors also reviewed corrective action documents which have been processed by the licensee to identify potential adverse trends in structures, systems, and/or components as evidenced by acceptance of long-standing non-conforming or degraded conditions. Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
4OA5 Other Activities
a. Inspection Scope
.1 Quarterly Resident Inspector Observations of Security Personnel and Activities
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
No findings were identified
4OA6 Meetings, Including Exit
a. Exit Meeting On January 15th the resident inspectors presented the inspection results to the Site Vice president, Mr. Tom Tynan and other members of the licensees staff. The inspectors confirmed that proprietary information was destroyed or returned following the completion of the inspection period.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- R. Barringer, Security Manager
- R. Collins, Chemistry Manager
- G. Gunn, Licensing Supervisor
- R. Hons, Training Manager
- M. Johnson, Health Physics Manager
- F. Pournia, Engineering Director
- J. Robinson, Engineering Programs Manager
- G. Saxon, Plant Manager
- J. Thomas, Operations Director
- T. Thompson, Systems Engineering Manager
- T. Tynan, Site Vice-President
- K. Walden, Licensing Engineer
- S. Waldrup, Licensing Director
NRC personnel
- M. Cain, Senior Resident Inspector
- T. Chandler, Resident Inspector
- D. Hardage, Resident Inspector (Hatch)
- F. Ehrhardt, Chief, Region II Reactor Projects Branch 2
LIST OF ITEMS
OPENED AND CLOSED Open And
Closed
- 05000424/2013005-01 NCV Failure to Meet the Conditions of TS LCO 3.8.4 (Section 1R19)
Opened
None
Closed
None