IR 05000424/2014008
| ML14329A050 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 11/24/2014 |
| From: | Bonser B R NRC/RGN-II/DRS/PSB1 |
| To: | Taber B K Southern Nuclear Operating Co |
| Linda K. Gruhler 404-997-4633 | |
| References | |
| IR 2014008 | |
| Download: ML14329A050 (14) | |
Text
November 24, 2014
Mr. Keith Taber Vice President Southern Nuclear Operating Company, Inc. Vogtle Electric Generating Plant 7821 River Road Waynesboro, GA 30830
SUBJECT: VOGTLE ELECTRIC GENERATING PLANT - U.S. NUCLEAR REGULATORY COMMISSION 95001 SUPPLEMENTAL INSPECTION REPORT 05000424/2014008 AND 05000425/2014008
Dear Mr. Taber:
On October 30, 2014, the U.S. Nuclear Regulatory Commission (NRC) staff completed a supplemental inspection at the Vogtle Electric Generating Plant. The enclosed report documents the results of this inspection, which were discussed with Mr. Glenn Saxon and members of your staff, during an exit meeting on October 30, 2014.
As required by the NRC Reactor Oversight Process (ROP), this supplemental inspection was performed in accordance with Inspection Procedure 95001, "Supplemental Inspection for One or Two White Inputs in a Strategic Performance Area." The purpose of the inspection was to determine causes for, and actions taken, related to a finding of low to moderate safety significance (White) in the Emergency Preparedness cornerstone. This issue was previously documented in NRC Inspection Report (IR) 05000424/2014003 and 05000425/2014003. On August 12, 2014, you informed the NRC that Vogtle Electric Generating Plant was ready for the supplemental inspection.
The NRC performed this supplemental inspection to determine if: (1) the root causes and contributing causes for the identified issues were understood, (2) the extent of condition and extent of cause of risk-significant performance issues were identified, and (3) your completed, or planned, corrective actions were sufficient to address and prevent repetition of the root and contributing causes. The NRC also conducted an independent review of the extent of condition and extent of cause for the White finding, and an assessment of whether any safety culture component caused, or significantly contributed, to the performance issue. The NRC determined that the root and apparent cause evaluations were conducted to a level of detail commensurate with the significance of the problems, and reached reasonable conclusions as to the root and contributing causes of the event. The NRC also concluded that you identified reasonable and appropriate corrective actions for each root, and contributing cause, and that the corrective actions appeared to be prioritized commensurate with the safety significance of the issues.Based on the results of this inspection, no findings were identified. However, inspectors documented a licensee-identified violation, which was determined to be of very low safety-significance, in this report. 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 Vogtle. After reviewing the performance in addressing the White finding documented in this inspection report, the NRC concluded your actions met the inspection objectives. As ROP discretion was exercised in enforcement of this issue and was not to be considered in assessing plant performance, the White finding is closed and Vogtle Electric Generating Plant remains in the Licensee Response Column of the ROP Action Matrix.
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, "Public inspections, exemptions, requests for withholding," of the NRC's "Rules of Practice," a copy of this letter and its enclosure, 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 NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,/RA/ Brian R. Bonser, Chief Plant Support Branch 1 Division of Reactor Safety Docket Nos. 50-424 and 50-425 License Nos. NPF-68 and NPF-81
Enclosure:
IR 05000424/2014008 and 05000425/2014008
w/Attachment:
Supplementary Information
cc: Distribution via Listserv
SUMMARY
Inspection Report (IR) 05000424/2014008; 05000425/2014008; 10/27/2014 - 10/30/2014; Vogtle Electric Generating Plant, Units 1 and 2; Supplemental Inspection - Inspection Procedure (IP) 95001 Two regional emergency preparedness inspectors performed this inspection. No findings were identified. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process."
Cornerstone: Emergency Preparedness
The NRC staff performed the supplemental inspection in accordance with IP 95001,
"Supplemental Inspection for One or Two White Inputs in a Strategic Performance Area," to assess the licensee's evaluation associated with the calculation error used to develop threshold values for Emergency Action Levels (EALs) RG1 and RS1, as required by 10 CFR 50.54(q) and the licensee's emergency plan. This error resulted in the EAL threshold values being approximately 60 times the appropriate values from 2008 until 2013. The NRC staff previously characterized this issue as having low to moderate safety significance (White), as documented in NRC IR 05000424/2014003 and 05000425/2014003. During this inspection, the inspectors determined that your staff performed an adequate evaluation of the cause of the White finding. Your staff's evaluation identified the root cause to be that engineering personnel did not utilize adequate verification practices in developing calculations used to establish threshold values for EALs. The inspectors found the extent of condition and extent of cause reviews were adequate, and the corrective actions implemented were adequate. All immediate and long term corrective actions have been completed, except for completing corrective action effectiveness reviews. Licensee-Identified Violations A violation of very low safety significance was identified by the licensee and has been reviewed by the inspectors. Corrective actions taken, or planned, by the licensee have been entered into the licensee's corrective action program (CAP). This violation and corrective action tracking numbers are listed in Section 4OA7 of this report.
REPORT DETAILS
OTHER ACTIVITIES
4OA4 SUPPLEMENTAL INSPECTION
.01 Inspection Scope
The NRC staff performed this supplemental inspection in accordance with Inspection Procedure (IP) 95001 to assess the licensee's evaluation of a White finding that affected the emergency preparedness (EP) cornerstone in the reactor safety strategic performance area. The inspection objectives were to provide assurance that the:
- root causes and contributing causes of risk-significant performance issues were understood
- extent of condition and extent of cause of risk-significant performance issues were identified
- licensee's corrective actions for risk-significant performance issues were sufficient to address the root and contributing causes and prevent recurrence The finding was characterized as having (White) safety significance as discussed in NRC inspection report (IR) 05000424 and 05000425/2014003, and was associated with radiation monitor Emergency Action Levels (EALs) threshold values for radiological release (RS1 and RG1) being approximately 60 times the appropriate value. The NRC exercised discretion in determining that the issue met the criteria specified in Inspection Manual Chapter (IMC) 0305 for treatment as an "old design issue," and would not aggregate in the Reactor Oversight Process (ROP) Action Matrix. The condition existed from 2008 until 2013. The licensee informed the NRC staff on August 12, 2014, that they were ready for the supplemental inspection. In preparation for the inspection, the licensee performed a root cause investigation documented in Root Cause Report 211396, to identify weaknesses that existed in various organizations and processes that resulted in the risk-significant (White) finding. The inspectors reviewed the licensee's Root Cause Evaluation (RCE) and other assessments conducted in support of, and as a result of, the investigation. Corrective actions taken to address the identified root and contributing causes were also reviewed. Additionally, inspectors interviewed licensee personnel to ensure that the root and contributing causes, and the contribution of safety culture components, were understood and corrective actions were appropriate to address the causes and preclude repetition.
.02 Evaluation of Inspection Requirements 02.01 Problem Identification a. Determine that the evaluation identifies who identified the issue, and under what conditions the issue was identified.
The licensee identified the engineering calculation errors during an internal operating experience review. The licensee entered the issue into their corrective action program (CAP), developed immediate compensatory measures to provide appropriate EAL threshold values to appropriate decision-makers, and initiated appropriate apparent and root cause investigations. The inspectors verified that this information was documented in the licensee's evaluation. b. Determine that the evaluation documents how long the issue existed, and prior opportunities for identification. The licensee identified that the RG1 and RS1 EAL radiation monitor threshold values were in error from when they were incorporated into plant procedures in March 2008 until corrected in May 2013. The licensee did not identify any prior opportunities for identification.
The inspectors determined that the licensee's evaluation and assessments were adequate with respect to identifying how long the issue existed, and the prior opportunities for identification. The inspectors did not identify any missed opportunities.
c. Determine that the evaluation documents the plant-specific risk consequences, as applicable, and compliance concerns associated with the issue. The NRC determined this issue was a White finding, as documented in NRC IR 05000424 and 425/2014003 dated August 6, 2014. The licensee's RCE documented the consequences of the issue, including potential adverse impacts on the ability of decision-makers to evaluate the effects of events during an emergency, and the licensee's responsibility to protect the health and safety of the public. Upon discovery, the licensee took action to implement corrective actions to establish appropriate threshold values. The inspectors concluded that the licensee appropriately documented the risk consequences and compliance concerns associated with the finding.
d. Findings
No findings were identified. 02.02 Root Cause and Extent of Condition Evaluation a. Determine that the problem was evaluated using a systematic methodology to identify the root and contributing causes.
The licensee investigation was performed by a diverse, qualified team of three members using licensee procedure NMP-GM-002-GL03, Cause Analysis and Corrective Action Guidelines. The following systematic methods and tools were used to perform the RCE:
- Event and Causal Factor Chart Analysis
- Barrier Analysis
- Interviews
- Extent of Condition and Extent of Cause Evaluations
- Human Performance Checklist
- Change Summary Chart
- Safety Culture Attributes Assessment
- Organization and Programmatic Review The licensee used an independent team to perform a mock inspection to determine their readiness for inspection and the need for additional corrective actions. The inspectors determined that the licensee adequately evaluated the issue using systematic methodologies to identify root and contributing causes. b. Determine that the root cause evaluation was conducted to a level of detail commensurate with the significance of the problem. The RCE was detailed in the scope of investigation and performed the following activities in support of the evaluation:
- conducted interviews with key personnel involved with the issue
- performed searches and reviews of the corrective action database for all Southern Nuclear Company sites using 'calculation error' as a keyword search
- performed reviews of industry and internal operating experience associated with EAL setpoints and implementation of NEI-99-01, rev. 4 guidance The following represent a synopsis of the root cause and contributing causes: (1) The root cause of this issue was determined to be inadequate independent verification practices. Proper verification practices were not demonstrated by the preparer or the reviewer of the calculation in 2005, nor were these practices enforced by the Safety Analysis Group's (SAG) supervisory personnel. (2) A mathematical error associated with the conversion factor was determined to be a direct cause of this issue. Due to over-confidence, the preparer did not include the derivation of the conversion factor in the body of the calculation, and the error was not identified by the reviewer. The reviewer placed too much reliance on the preparer's ability and did not perform a complete and independent review. (3) Organizational structure and lack of cross functional communication were determined to be causal factors. Although procedural guidance was in place to ensure adequate detail when performing key calculations, supervision was insufficiently engaged with the SAG to enforce this guidance. In addition, communications between the SAG and the receiving organization were not implemented, to ensure the intent and results of the calculation were adequate.
Based on a review of the RCE and supporting documentation, the inspectors concluded that the evaluation was conducted to a level of detail commensurate with the significance of the problem. c. Determine that the root cause evaluation included a consideration of prior occurrences of the problem and knowledge of prior operating experience.
The RCE included a review of plant corrective action databases and industry databases. The licensee identified several CAP items related to errors in calculations originated after 2008, but determined the errors were found and corrected prior to final approval. Additionally, the licensee determined that the implementation of calculation training since 2007 demonstrated the effectiveness of that training in limiting the severity of identified errors. The licensee identified several industry issues associated with EAL setpoints and Nuclear Energy Institute (NEI) 99-01 Rev. 4 implementation; however, the timeframe and specific issues identified in these issues, showed that use of this operating experience would not have prevented the calculation error. Based on the licensee's detailed evaluation and conclusions, the inspectors determined that the licensee's root cause investigation included adequate consideration of prior occurrences of the problem, and knowledge of prior operational experience. d. Determine that the root cause evaluation addressed the extent of condition and the extent of cause of the problem. The licensee's evaluation limited the extent of condition review to EAL calculations, as these calculations were similar in content and also performed by the SAG. Search results were restricted to core business calculations with "dose" as a keyword in the title.
This produced a result of 202 calculations, which were further reduced to 47 calculations based on additional analysis by the licensee. Two calculations were identified to be performed by the same preparer as in 2005, but a review of these calculations did not identify any other unit conversion errors. Additional licensee review of underlying assumptions supporting EAL threshold value determinations did identify several other values, which required minor revisions. These were placed in the licensee's CAP and actions have been completed.
The extent of cause was limited to the verification practices of the SAG. Procedure NMP-ES-039-001, Calculations - Preparation and Revision, sets the standard for ensuring rigor, the level of detail, and accuracy when performing key calculations. Also, procedures are in place to ensure individuals are qualified to perform calculations, and products are reviewed and verified.
The inspectors concluded that the licensee's root cause investigation adequately addressed the extent of condition and the extent of cause of the issue. A review of the subsequently identified EAL issues did not reveal any new performance deficiencies (PDs).
Inspectors reviewed additional information regarding one unresolved item (URI)previously documented in IR 2013003 (URI 05000424 and 05000425/2013003-01,
"Ability of Main Steam Line Radiation Monitors to Provide Threshold Values for EAL RG1"). The licensee's analysis determined that the usable ranges of the main steam line radiation monitors was insufficient to encompass declaration thresholds for Site Area Emergency, and General Emergency classifications, under the Abnormal Radiation Levels/Radiological Effluent initiating condition, and that their inclusion into the EAL scheme was inappropriate. The licensee submitted a License Amendment Request (LAR) to remove these thresholds. The NRC evaluated the request and issued a Safety Evaluation Report (SER) and license amendment removing the thresholds.
e. Determine that the root cause, extent of condition, and extent of cause evaluations appropriately considered the safety culture components, as described in IMC 0305.
The licensee found a weakness in the following crosscutting aspect:
- Human Performance component of Field Presence (H.2): This related to the ineffective oversight to ensure adequate verification practices were used by engineers involved in calculations supporting Emergency Action Level threshold development.
The inspectors determined that the licensee's root cause investigation included a proper consideration of whether weaknesses in any safety culture component were root or significant contributing causes of the issue.
f. Findings
A licensee-identified violation (LIV) is documented in Section 4OA7. 02.03 Corrective Actions a.
Determine that appropriate corrective actions are specified for each root and contributing cause, or that the licensee has an adequate evaluation for why no corrective actions are necessary. The licensee identified the following root cause and implemented the corresponding corrective action:
- Poor independent verification practices compounded by causal factors of inadequate organizational structure and lack of cross functional communication. For a corrective action to prevent recurrence (CAPR), the SAG was transferred from Fleet Licensing to Fleet Design in December of 2007. This was done to ensure proper technical oversight of engineering calculations existed, and that procedural standards were adequately enforced. An additional CAPR was the development and implementation of an engineering training course in 2007, which established the foundation for correct verification practices when performing design bases calculations. The corrective action to address the lack of cross-functional communication was addressed by revising procedure, NMP-ES-050, Request for Engineering Review, to require communications between responsible organizations throughout the calculation revision process. The licensee developed corrective actions to address contributing causes as summarized below:
- The technical inaccuracies in the EAL calculations were addressed by the licensee performing a reconstitution of the NEI 99-01 Rev. 4, EAL Calculations for the Vogtle Electric Generating Plant, which was completed in September 2014.
- Communications with corporate design engineers, site design engineers, and external engineering firms to discuss the issue, reinforce procedural standards, and emphasize the importance of calculation accuracy and review was completed in October 2014.
The inspectors determined that the corrective actions were appropriate and addressed the root and contributing causes in the licensee's detailed evaluation and conclusions. b. Determine that corrective actions have been prioritized with consideration of risk significance and regulatory compliance. The licensee determined the correct EAL threshold values, and provided these to appropriate decision-makers in the operations and emergency response organizations (EROs). The licensee completed apparent cause and RCEs, and a subsequent independent assessment to determine root/contributing causes, and developed appropriate corrective actions with consideration of risk significance. The inspectors determined that the immediate and follow-on corrective actions were adequately prioritized with consideration of the risk significance and regulatory compliance.
c. Determine that a schedule has been established for implementing and completing the corrective actions. The licensee established due dates for the corrective actions in accordance with their CAP. The inspectors reviewed the status of each corrective action assignment and determined that an appropriate schedule had been established for implementing the corrective actions. The only remaining action is to complete corrective action effectiveness reviews. d. Determine that quantitative or qualitative measures of success have been developed for determining the effectiveness of the corrective actions to prevent recurrence. The licensee established an effectiveness review plan. Final effectiveness reviews are currently scheduled to be completed by January 15, 2015.
The inspectors determined that the effectiveness review plan actions would adequately test and/or measure corrective actions to ensure minimal impact from future calculation errors.
e. Determine that the corrective actions planned, or taken, adequately address a Notice of Violation that was the basis for the supplemental inspection, if applicable. As ROP discretion was exercised, no written response to the notice of violation (NOV)was required. The licensee's evaluation described: (1) corrective actions taken and the results achieved; (2) actions which will be taken; (3) the date when full compliance was achieved; and (4) the reasons for the violation. During this inspection, the inspectors confirmed that the licensee's root cause investigation and actions completed, or planned, adequately addressed the NOV. The licensee restored compliance in May 2013 when interim compensatory actions were implemented. Final EAL thresholds were incorporated in appropriate EP procedures in November 2014.
f. Findings
No findings were identified.
02.04 Evaluation of Inspection Manual Chapter 0305 Criteria for Treatment of Old Design Issues This issue was previously evaluated against IMC 0305 criteria and was determined to be an old design issue, as documented in NRC IR 05000424/2014003 and 05000425/2014003.
4OA6 Exit Meeting On October 30, 2014, the inspectors presented the inspection results to Mr. G. Saxon and other members of the staff, who acknowledged the results.
The inspectors asked the licensee if any of the material examined during the inspection should be considered proprietary. The licensee did not identify any proprietary information.
4OA7 Licensee-Identified Violations
Title 10 CFR 50.54(q)(2) required, in part, that a licensee shall follow and maintain the effectiveness of an emergency plan which meets the planning standards of 10 CFR 50.47(b). Title 10 CFR 50.47(b)(4) required that a standard emergency action level (EAL) scheme, the basis of which include facility system and effluent parameters, is in use by nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures. Contrary to the above, from March 2008 to May 2013, the licensee failed to maintain the effectiveness of its emergency plan. Specifically, Abnormal Radiation Release/Rad Effluent EALs RU1, RA1, RS1, and RG1, inappropriately included Main Steam Line radiation monitors (RE-13119 through RE-13122) threshold values. The licensee implemented immediate compensatory actions by issuing a Standing Order to disregard these radiation monitor EAL thresholds, and informed appropriate operators and decision-makers. The licensee requested a license amendment to remove the radiation monitors from the EAL scheme. The NRC issued a license amendment and SER on September 30, 2014. The licensee implemented the amendment and revised the emergency plan and implementing procedures in November 2014. The issue was placed in the licensee's CAP as condition report (CR) 564168. The inspectors evaluated this issue as an ineffective EAL per IMC 0609, Appendix B.
Since unaffected redundant or diverse EAL thresholds existed, an appropriate declaration would be made in an accurate and timely manner, and therefore this issue screened as a Green NCV. URI 05000424,05000425/2013003-01 is closed.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee
- M. Carstensen, CAP Supervisor
- L. Dencker, Electrical Design Supervisor
- C. Grant, Operations Shift Supervisor
- G. Gunn, Regulatory Affairs Manager
- M. Henry, Operations Shift Manager
- M. Johnson, Radiation Protection Manager
- J. Klecha, Operations Director
- T. Littlejohn, Mechanical/Civil Engineering Technical Lead
- L. Mansfield, Fleet EP Director
- T. Mattson, Root Cause Team Leader
- K. Morrow, Senior Licensing Engineer
- S. Odom, Corporate Functional Area Manager
- G. Saxon, Plant Manager
- J. Wade, Site Design Engineering Manager
- K. Walden, Licensing Engineer
- J. Williams, Site Integration Director
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened None
Closed VIO
- 05000424, 425/2014003-03; Calculation Error Results in Significantly non-Conservative EAL Threshold Values
URI
- 05000424, 425/2013003-01, "Ability of Main
Steam Line Radiation Monitors to Provide Threshold Values for EAL RG1"
DOCUMENTS REVIEWED
Plans and Procedures 91304-C, Estimating Offsite Dose, Rev. 27.4
- ENG-002, Calculations - Preparation and Revision, V. 1
- NMP-ES-039-001, Calculations - Preparation and Revision, V. 5.1
- NMP-ES-050, Requests for Engineering Review, Ver. 1.0 and Ver. 5.0
- NMP-GM-002, Corrective Action Program, Ver. 13.1
- NMP-GM-002-GL03, Cause Analysis and Corrective Actions Guideline, Ver. 25.0
- NMP-GM-002-002, Effectiveness Review Instructions, Ver. 4.2
- NMP-GM-002-004, CAP Training and Qualification Instruction, Ver. 4.0
- NMP-GM-024-001, Nuclear Safety Culture Monitoring and Review Process, Ver. 5.0
- Corrective Action Documents
- CAR 207092, Enhanced Apparent Cause Report dated 7/22/2013
- CAR 211396, Root Cause Report
- CR 853606, Fleet Alert content inconsistent with RCE results
- CR 862001, NRC Feedback on Green FEA
- CR 887168,
- NRC 95001 observations
Miscellaneous Documents
- Calculation X6CNA14,
- NEI 99-01, Ver. 5, 6, and 7
- License Operator Requalification, V-RQ-PP-63280, Current Events, Ver. 1.0 Management Review Committee minutes August 6, 2014
- Emergency Action Level Mock Inspection Team Report completed October 16, 2014
- SoCo ltr
- NL-13-1780, VEGP LAR to Revise E-Plan Licensing Document Change Request
- NPF-68/81 dated 9/30/2014 FEA C-14-01, Radiation Monitor Setpoints for EAL Entry Inconsistent With Current Guidelines Plant Standing Order
- C-2014-9, Ver. 1.0
- DOEJ-VXSNC648248-M001, Corrected EAL Set Points for RS1 and RG1 for Plant Vogtle, V. 1 LOR Segment 20146 Current Events, dated 10/16/14
- 10CFR50.54(q) Screening/Evaluation
- VEGP-13-033-01, dated 8/2/13 EAL Vogtle Mock Inspection Report, dated 10/16/14
LIST OF ACRONYMS
CAPR Corrective Actions to Prevent Recurrence CR Condition Report
EAL Emergency Action Level
IP Inspection Procedures IR Inspection Report
LAR License Amendment Request
NCV Non-Cited Violation NOV Notice of Violation
PD Performance Deficiency
RCE Root Cause Evaluation