IR 05000424/2020010
| ML20310A385 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 11/05/2020 |
| From: | James Baptist NRC/RGN-II/DRS/EB1 |
| To: | Gayheart C Southern Nuclear Operating Co |
| References | |
| IR 2020010 | |
| Download: ML20310A385 (14) | |
Text
November 5, 2020
SUBJECT:
VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 & 2 - DESIGN BASIS ASSURANCE INSPECTION (PROGRAMS) INSPECTION REPORT 05000424/2020010 AND 05000425/2020010
Dear Ms. Gayheart:
On October 28, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Vogtle Electric Generating Plant, Units 1 & 2 and discussed the results of this inspection with Drayton Pitts and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation documented in this inspection report, 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; and the NRC Resident Inspector at Vogtle Electric Generating Plant, Units 1 & 2. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
James B. Baptist, Chief Engineering Br 1 Div of Reactor Safety Docket Nos. 05000424 and 05000425 License Nos. NPF-68 and NPF-81
Enclosure:
As stated
Inspection Report
Docket Numbers: 05000424 and 05000425 License Numbers: NPF-68 and NPF-81 Report Numbers: 05000424/2020010 and 05000425/2020010 Enterprise Identifier: I-2020-010-0043 Licensee: Southern Nuclear Operating Co., Inc.
Facility: Vogtle Electric Generating Plant, Units 1 & 2 Location: Waynesboro, GA Inspection Dates: July 27, 2020 to August 14, 2020 Inspectors: T. Fanelli, Sr. Construction Inspector N. Morgan, Reactor Inspector M. Riley, Senior Reactor Inspector Approved By: James B. Baptist, Chief Engineering Br 1 Div of Reactor Safety Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a design basis assurance inspection (programs) inspection at Vogtle Electric Generating Plant, Units 1 & 2, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Use of JOG Threshold Values in Design Bases Calculations Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.21N.
Systems NCV 05000424,05000425/2020010-01 02 Open/Closed The inspectors identified a Green finding and associated Non-Cited Violation (NCV) of 10 CFR Part 50.55a(b)(3)(ii), Motor-Operated Valve Testing, when the licensee failed to verify that Westinghouse 3 and 4 gate valves discussed in calculation X4C1000U07, "Evaluation of Power Operated Safety Related Gate Valves for Susceptibility to Pressure Locking and Thermal Binding (PL/TB) Effects," Version 15, continued to be capable of performing their design basis safety functions. Specifically, the licensee improperly used coefficient of friction (COF) values from industry-wide Joint Owner's Group (JOG) research instead of their own more limiting COF values identified during original plant diagnostic testing and approved by NRC.
Additional Tracking Items
None.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), inspectors were directed to begin telework. In addition, regional baseline inspections were evaluated to determine if all or portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspection documented below met the objectives and requirements for completion of the IP.
REACTOR SAFETY
71111.21N.02 - Design-Basis Capability of Power-Operated Valves Under 10 CFR 50.55a Requirements POV Review (IP Section 03)
The inspectors:
a. Determined whether the sampled POVs are being tested and maintained in accordance with NRC regulations along with the licensees commitments and/or licensing bases.
Specific Guidance b. Determined whether the sampled POVs are capable of performing their design-basis functions.
c. Determined whether testing of the sampled POVs is adequate to demonstrate the capability of the POVs to perform their safety functions under design-basis conditions.
d. Evaluate maintenance activities including a walkdown of the sampled POVs (if accessible).
- (1) 1-HV-8000A, Pressurizer Power-Operated Relief Valve Block Valve
- (2) 2-HV-8821A, Safety Injection Pump Cold Leg Discharge Stop Valve
- (3) 1-HV-15197, Main Feedwater Bypass Isolation Valve
- (4) 1-HV-11600, Nuclear Service Cooling Water - NSCW Pmp Disch Vlv
- (5) 1-HV-5137, Auxiliary Feedwater - AFW Pmp Disch Hdr Iso Vlv
- (6) 2-HV-8804B, Residual Heat Removal - RHR Pmp "B" Disch To SI Pmp "B" Iso Vlv
INSPECTION RESULTS
Use of JOG Threshold Values in Design Bases Calculations Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.21N.0 Systems NCV 05000424,05000425/2020010-01 2 Open/Closed The inspectors identified a Green finding and associated Non-Cited Violation (NCV) of 10 CFR Part 50.55a(b)(3)(ii), Motor-Operated Valve Testing, when the licensee failed to verify that Westinghouse 3 and 4 gate valves discussed in calculation X4C1000U07, "Evaluation of Power Operated Safety Related Gate Valves for Susceptibility to Pressure Locking and Thermal Binding (PL/TB) Effects," Version 15, continued to be capable of performing their design basis safety functions. Specifically, the licensee improperly used coefficient of friction (COF) values from industry-wide Joint Owner's Group (JOG) research instead of their own more limiting COF values identified during original plant diagnostic testing and approved by NRC.
Description:
During the review of calculation X4C1000U07, Evaluation of Power Operated Safety Related Gate Valves for Susceptibility to Pressure Locking and Thermal Binding (PL/TB) Effects, Version 15, dated December 2010, the team identified that several Westinghouse 3 and 4 gate valves inappropriately used industry-wide Joint Owner's Group (JOG) valve factors and threshold coefficient of frictions (COFs) to determine the design capability for these valves. The NRC staff position is that, unlike the EPRI MOV PPM program, the JOG program was not intended to be used in establishing the design-basis capability of MOVs. NRC Information Notice 2012-14, Motor-Operated Valve Inoperable Due to Stem-Disc Separation, dated July 24, 2012, states in part that:
During the implementation of GL 89-10, NRC staff accepted four methods the licensee could use to demonstrate the design-basis capability of safety-related MOVs. In descending order of acceptability, the four methods for demonstrating capability were:
1. Dynamic testing at or near design-basis conditions with diagnostics of each MOV where
practicable
2. Electric Power Research Institute MOV performance prediction methodology (PPM)
3. MOV valve grouping
4. The use of valve test data from other plants or research programs
As a result of improperly using JOG threshold values in determining the margins for the valves, the team determined there was reasonable doubt the affected MOVs could perform their intended safety function. On October 22, 2020, the licensee completed an operability evaluation to verify that the affected valves remained capable of performing their intended safety function. Licensee procedure NMP-ES-017-002, "Motor Operated Valve Design Basis Setpoint Documentation," Version 6.2, detailed how the licensee was to determine the minimum required thrust and design margin for the valves. The licensee determined that the valves maintained acceptable margin when taking into account actual packing friction loads demonstrated by test instead of the assumed loads required by the procedure. The inspectors noted that the licensee had to deviate from the assumptions in the procedural MOV program methodology to obtain a favorable result for five valves, and 76 calculations will need to be revised in total.
Corrective Actions: The licensee entered this issue into their corrective action program and performed an operability evaluation which determined that there was reasonable assurance that the affected Westinghouse gate valves could perform their intended safety function when taking into account actual packing friction loads demonstrated by test.
Corrective Action References: CR 10738957
Performance Assessment:
Performance Deficiency: The failure to verify that Westinghouse 3 and 4 gate valves discussed in calculation X4C1000U07 continued to be capable of performing their design basis safety functions in accordance with 10 CFR Part 50.55a(b)(3)(ii), Motor-Operated Valve Testing, was a PD. Specifically, the licensee improperly used COF values from JOG research instead of their own more limiting COF values identified during original plant diagnostic testing and approved by NRC.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the as-found condition was such that there was reasonable doubt with respect to the capability of MOVs to perform their safety function. In order to verify operability, the licensee had to change the assumptions from their procedural MOV program methodology to obtain a favorable result for five valves.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors assessed the significance of the finding using Inspection Manual Chapter (IMC) 0609, Att. 4, "Initial Characterization of Findings," issued October 7, 2016, for the Mitigating Systems cornerstone, and IMC 0609, App. A, "The Significance Determination Process (SDP) for Findings At-Power," issued June 19, 2012, and determined the findings was of very low safety significance (Green) because the finding was a deficiency affecting the qualification of a mitigating structure, system, or component (SSC) and the SSC maintained its operability.
Cross-Cutting Aspect: Not Present Performance. No cross cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
Enforcement:
Violation: 10 CFR Part 50.55a(b)(3)(ii), Motor-Operated Valve Testing, requires that licensees comply with the provisions for testing MOVs in ASME OM Code, ISTC 4.2, 1995 Edition with the 1996 and 1997 Addenda, or ISTC-3500, 1998 Edition through the latest edition and addenda incorporated by reference in paragraph (a)(1)(iv) of 10 CFR 50.55a, and establish a program to ensure that MOVs continue to be capable of performing their design basis safety functions.
Contrary to the above, since December 2010, the licensee failed to establish a program to ensure that Westinghouse 3" and 4" gate valves continued to be capable of performing their design basis safety functions.
Enforcement Action: This violation is being treated as an non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On October 28, 2020, the inspectors presented the design basis assurance inspection (programs) inspection results to Drayton Pitts and other members of the licensee staff.
- On August 14, 2020, the inspectors presented the Original Exit inspection results to Mr.
Drayton Pitts and other members of the licensee staff.
- On October 5, 2020, the inspectors presented the De-brief for Re-exit inspection results to Mr. Mathew Horn and other members of the licensee staff.
- On October 28, 2020, the inspectors presented the RE-exit inspection results to Mr.
Drayton Pitts and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.21N.02 Calculations AX5AC03-05191 Motor Operated Valve Thrust / Torque Allowable Rev. 2
AX5C03-00722-1 Fisher Weak Link Analysis and Calculation Procedure for Rev. B
280 Series Butterfly
AX6AA15-00002 Vogtle Electric Generating Plant - Unit No. 1/2 Pump and Rev. 16
Valve Operability Report
AX6AA15-00002 Pump and Valve Operability Report Rev. 16
VNP-1HV11600 Thrust and Torque Calculation HV11600 (VNPS-1) AC Rev. 3
Motor Operated GL96-05 Butterfly1 Valve
VNP-1HV5137 Thrust and Torque Calculation 1HV5137 (VNPS-1) Rev. 3
VNP-1HV8000A Thrust and Torque Calculation, 1HV8000A (VNPS-1), AC Rev. 3
Motor Operated GL96-05 Gate Valve
VNP-2HV8702B Thrust and Torque Calculation 2HV8702B (VNPS-2) Rev. 1
VNP-2HV8804B Thrust and Torque Calculation 2HV8804B (VNPs-2) Rev. 1
VNP-2HV8821A THRUST AND TORQUE CALCULATION 2HV8821A Rev. 2
(VNPS-2) AC MOTOR OPERATED GL96-05 GATE
VALVE
X3CA18 Unit 1 Load Study Rev. 18
X3CA22 Unit 2 Load Study Rev. 13
X4C1000U01 Differential Pressure Calculations for REA VG-9049 Rev. 18
X4C1000U01 Differential Pressure Calculations for REA VG-9049 Rev. 19
X4C1000U02 Valve Required Thrust/Torque and Operator Capabilities Rev. 23
and Limitations for GL 89-10
Scope Motor Operated Valves
X4C1000U07 Evaluation of Power Operated Safety Related Gate Rev. 15
Valves for Susceptibility to Pressure Locking and Thermal
Binding (PL/TB) Effects
X4C1000U41 AOV Setpoint Review for 1 HV8152
X4C1000U42 AOV Setpoint Review of 1/2HV-15196 to 15199 Rev. 2
X4CPS.0075.402 Stress Analysis, Qualification of Valves for GL 89-10 Rev. 0
X4CPS.0075.520 Qualified Life EXT for Limitorque MTR OPER VLV Rev. 12
Inspection Type Designation Description or Title Revision or
Procedure Date
Actuator
X4CPS.0075.520 Qualified Life Ext for Limitorque Mtr Oper Vlv Actuator Rev. 12
Drawings 1X3D-BD-B02A Elementary Diagram Reactor Coolant System 1HV-8000A Rev. 7
1X4DB114 P&I Diagram Chemical & Volume Control System Rev. 41
1X4DB133-1 P&I Diagram Nuclear Service Cooling Water System No. Rev 56
202
1X4DB168-3 P & I Diagram Condensate & Feedwater System, System Rev. 36
No. 1305
1X5AC01-00210 Certified Dimensional Drawing for Item 6, 7, 8, and 9 05/21/1981
1X5AC03-05138 Valve and Actuator Drawing 18" Butterfly Valves Spare Rev 2
Part List
1X5DN150-4 Control Logic Diagram Main Feedwater System Rev. 2
1X6AA06-00445 Air Operated Control Valve Rev. 11
1X6AA06-10019- Motor Operated Gate Valve Model 03003GM99FNHCOG Rev. 3
3-2035 ASME CL.: GPO ASSY
2X3D-BD-D02M Elementary Diagram Safety Injection System 2HV-8804B Rev. 6
2X3D-BD-DD3D Elementary Diagram Safety Injection System 2HV-8821A Rev. 4
2X3D-BD-E02K Elementary Diagram Residual Heat Removal System Rev. 12
2X4DB121 P&I Diagram Safety Injection System, System No. 1204 Rev. 50
2X4DB122 P & I Diagram Residual Heat Removal System No. 1205 Rev. 54
2X6AA06-00378- Motor OP Operated Valve MOD 04002GM87FHB000 4- Rev. 4
900 ASME CL.I GPO ASSY
2X6AA06-00411 Motor OP Gate Valve MOD 08002GM84FEB010 Rev. 5
2X6AA06-00659 Motor OP Gate Valve MOD 12001GM88SEH000 04/03/1995
AX4AR01-00450 Pneumatic Actuators for Valve Tags 3
AX4AR01-00451 Pneumatic Actuators for Valve Tags 2
Engineering AX5AC03-05169 Qualification Report for Group XI Control Valves 9/4/1992
Evaluations
Miscellaneous 1X6AA06-00639 Valve Specification Sheets Rev. 7
207-D- Air Operated Valve Program Package Rev. 2.1
1HV8152
AQR-67368 ASCO Solenoid Valve Qualification Test Report Rev. 2
Inspection Type Designation Description or Title Revision or
Procedure Date
AX4AR01-567 Seismic Analysis Report - Generic Valve Rev. 5
AX5AC01-365 Weak Link Analysis for 1HV-5137 09/03/1987
AX6AA15-00002 Pump and Valve Operability Report Rev. 16
AX6AA15-00002 Vogtle Electric Generating Plant - Unit No. 1 / 2 Pump Rev. 16
and Valve Operability Report
DC-1201 Reactor Coolant System Rev. 5
DC-1202 VEGP Design Criteria Nuclear Service Cooling Water Rev 13
(NSCW) System
DC-1204 Safety Injection System Rev. 6
DC-1208 Chemical and Volume Control System (CVCS) and Boron Rev 11
Recycle System (BRS)
DC-1305 Condensate and Feedwater System Rev. 10
GP-17105 Weak Link Analysis for Valves 8804 A & B 05/11/2000
GP-18568 Summary of Seismic and Weak Link Evaluation of the 10/8/2009
Westinghouse 3GM88FHN (Vogtle Locations 1/2 HV
8000A, B) and the Westinghouse 4GM77FH (Vogtle
Locations 1/2 HV 8821A, B) at Vogtle Units 1 and 2
Valve-1HV11600 Full Test Curves SNC576875 7/31/2017
VNP-1HV11600 JOG MOV Evaluation Report Rev. 3
VNP-1HV5137 JOG MOV Evaluation Report 1HV5137 (VNPS-1) Rev. 3
VNP-1HV8000A JOG MOV Evaluation Report 1HV8000A (VNPS-1) AC Rev. 3
Motor Operated GL96-05 Gate Valve
VNP-2HV8702B JOG MOV evaluation Report 2HV8702B (VNPS-2) Rev. 1
VNP-2HV8821A JOG MOV Evaluation Report 2HV8821A (VNPS-2) AC Rev. 2
Motor Operated GL96-05 Gate Valve
WCAP-8687 Equipment Qualification Test Report Rev. 59
X5AC01 Electric Motor Operator Equipment Qualification Data Rev. 1
Package
X5AC03 Specification for Small Butterfly Valves for the GIORGIA Rev 15
Power Company, Vogtle Electric Generating Plant, Burke
County
X6AA15 Motor Operator-Group A Equipment Qualification Data Rev. 1
Package
X6AA15 Environmental Qualification Data Package Rev. 1.0
Inspection Type Designation Description or Title Revision or
Procedure Date
Procedures 14825-1 Quarterly lnservice Valve Test Rev. 106
14850-1 Cold Shutdown Valve Inservice Test Rev. 59
207-D- Air Operated Valve Program Package Rev. 2
1HV15197
NMP-ES-014-001 Air Operated Valve (AOV) Scoping and Categorization Rev. 3.2
NMP-ES-014-002 Air Operated Valve (AOV) Design Basis Review and Rev. 4.2
Setpoint Control
NMP-ES-014-003 Air Operated Valve (AOV) Datasheet Preparation and Rev. 4.1
Testing
NMP-ES-014-004 Air Operated Valve (AOV) Tracking and Trending Rev. 4.1
NMP-ES-014-010 AOV Diagnostic Testing and Signature Evaluation Rev. 6
NMP-ES-017-001 Motor Operated Valve (MOV) Regulatory Scoping Rev. 6.2
Process
NMP-ES-017-002 Motor Operated Valve Design Basis Setpoint Rev. 6.2
Determination
NMP-ES-017-003 Motor Operated Valve Performance Trending and Margin Rev. 5.2
Management
NMP-ES-017-004 MOV Diagnostic Procedure for Gate & Globe Valves Rev. 7.0
NMP-ES-017-005 MOV Diagnostic Procedure for Butterfly Valves Rev. 6.0
NMP-ES-017-008 MOV Mechanical and Electrical Inspections Rev. 11.2
Work Orders SNC1056611
SNC1060711
SNC358552
SNC392558
SNC407132
SNC513205-22
SNC532510-30
SNC576875
SNC635430
SNC672979
SNC832046
SNC891268
SNC898207
Inspection Type Designation Description or Title Revision or
Procedure Date
SNC972592
11