IR 05000424/2022002
| ML22222A205 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 08/11/2022 |
| From: | Alan Blamey NRC/RGN-II/DRP/RPB2 |
| To: | Gayheart C Southern Nuclear Company |
| References | |
| IR 2022002 | |
| Download: ML22222A205 (23) | |
Text
SUBJECT:
VOGTLE ELECTRIC GENERATING PLANT, UNITS 1&2 - INTEGRATED INSPECTION REPORT 05000424/2022002 AND 05000425/2022002
Dear Ms. Gayheart:
On June 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Vogtle Electric Generating Plant, Units 1&2. On July 14, 2022, the NRC inspectors discussed the results of this inspection with Mr. Sonny Dean 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.
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 U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC Resident Inspector at Vogtle Electric Generating Plant, Units 1&2.
August 11, 2022 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, Alan J. Blamey, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket Nos. 05000424 and 05000425 License Nos. NPF-68 and NPF-81
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000424 and 05000425
License Numbers:
Report Numbers:
05000424/2022002 and 05000425/2022002
Enterprise Identifier:
I-2022-002-0021
Licensee:
Southern Nuclear Operating Company, Inc.
Facility:
Vogtle Electric Generating Plant, Units 1&2
Location:
Waynesboro, GA
Inspection Dates:
April 01, 2022 to June 30, 2022
Inspectors:
J. Bell, Resident Inspector
B. Bishop, Senior Project Engineer
J. Eargle, Senior Resident Inspector
C. Fontana, Emergency Preparedness Inspector
J. Hickman, Resident Inspector
Z. Hollcraft, Senior Reactor Operations Engineer
B. Kellner, Senior Health Physicist
A. Nielsen, Senior Health Physicist
W. Pursley, Health Physicist
C. Safouri, Acting Senior Resident Inspector
S. Sanchez, Senior Emergency Preparedness Insp
J. Walker, Emergency Response Inspector
Approved By:
Alan J. Blamey, Chief
Reactor Projects Branch 2
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated 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
Inadequate Surveys for Alpha Contamination Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000424,05000425/2022002-01 Open/Closed
[H.1] -
Resources 71124.04 NRC identified a Green finding and associated non-cited violation (NCV) of Title 10 Code of Federal Regulation (CFR) § 20.1501(a)(1)(2)(iii), which requires in part, that licensee perform surveys to evaluate potential radiological hazards.
Additional Tracking Items
None.
PLANT STATUS
Unit 1 began the inspection period at rated thermal power. On May 3, 2022, the unit was manually tripped due to a loss of the train B main feed pump. The unit was returned to rated thermal power on May 9, 2022. On May 27, 2022, the unit was down powered to 92 percent for quarterly main turbine valves stroke test and returned to rated thermal power. The unit remained at or near rated thermal power for the remainder of the inspection period.
Unit 2 began the inspection period in Mode 5 as part of Cycle 22 refueling outage (2R22) and returned to rated thermal power, on April 9, 2022. On April 10, 2022, the unit was down powered to 65 percent due to a loss of isophase bus duct cooling. The unit was returned to rated thermal power on April 15, 2022. On May 31, 2022, the unit was down powered to 92 percent for quarterly main turbine valves stroke test and returned to rated thermal power. The unit remained at or near rated thermal power for the remainder of the inspection period.
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 performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. 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.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Impending Severe Weather Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe weather associated with a tornado watch, on April 5, 2022.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 2 train B nuclear service cooling water (NSCW) system while pump 6 was out of service, on April 27, 2022.
- (2) Unit 1 auxiliary feedwater (AFW) system following actuation, on May 3, 2022.
- (3) Unit 2 loop 4 main steam isolation valve (MSIV) system following air leak repair, on June 2, 2022.
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the Unit 2 train A engineered safety features (ESF) chiller system following a system outage, on June 14, 2022.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Fire Zones 140A/B/C/E, Unit 2 containment building, on April 2, 2022.
- (2) Unit 1 level 3 control building response to multiple false fire alarms due to charcoal bed replacement, on April 26, 2022.
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)
The inspectors evaluated internal flooding mitigation protections in the:
- (1) 1NE7ADKEM39, 1NE7ADKEM40, and 1NE9GHKEPB01 pull boxes, on April 11, 2022.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (2 Samples)
- (1) The inspectors observed and evaluated licensed operator performance in the main control room during the Unit 2 Mode 4 and Mode 3 transitions following the refueling outage (2R22), on April 2, 2022.
- (2) The inspectors observed and evaluated licensed operator performance in the main control room during the Unit 1 manual reactor trip in response to the loss of the train B main feed pump, on May 3, 2022.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated just-in-time training for Unit 1 startup following a forced outage, on May 4, 2022, as well as a simulator scenario involving an anticipated transient without scram coincident with a main feed line break, on June 6, 2022.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Sample)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) Unit 2 train B NSCW, on April 27, 2022.
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Unit 2 Yellow shut down risk on Alternating Current (AC) Power Availability due to emergent repairs on the incoming breaker cubicle for Unit 2 train A safety-related 4160-volt bus, on April 1, 2022.
- (2) Unit 2 train A ESF chiller system during system outage, on June 14, 2022.
- (3) Units 1 and 2 conservative system operations warning due to elevated temperatures affecting the grid, on June 21, 2022.
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (7 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Units 1 and 2 emergency diesel generator (EDG) inadequate surveillance on intake and recirculation dampers associated with the building HVAC system, on February 11, 2022.
- (2) Unsecured and unlatched storage boxes containing lead blankets in Unit 2 containment building identified during as-found containment walkdown, on March 6, 2022.
- (3) Unit 2 loops 1-4 MSIV stroke times exceeded functional testing acceptance criteria, on April 4, 2022.
- (4) Unit 1 train B component cooling water (CCW) pump 4 inboard bearing oil leak, on May 1, 2022.
- (5) Unit 1 train B CCW pump 6 inboard bearing oil leak, on May 1, 2022.
- (6) Unit 1 AFW ESF actuation following unexpected indications associated with the train B main feed pump, on May 5, 2022.
- (7) Unit 1 train A AFW pump minimum flow motor-operated valve (1FV5155) erratic indications during diagnostic testing, on May 12, 2022.
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:
- (1) Unit 1 train A AFW system outage, on May 11, 2022.
- (2) Unit 1 train B EDG jacket water heater motor control center (1NBO13) starter replacement, on May 24, 2022.
- (3) Unit 1 train B NSCW pump 2 system outage, on May 31, 2022.
- (4) Unit 2 train A ESF chiller system outage, on June 14, 2022.
- (5) Unit 1 train B CCW pump 6 system outage, on June 21, 2022.
- (6) Unit 1 train B NSCW pump 6, on June 27, 2022.
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated Unit 2 Cycle 22 refueling outage (2R22) from April 1, 2022, to April 5, 2022. The inspectors completed inspection procedure Sections 03.01.d through 03.01.e.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:
Inservice Testing (IP Section 03.01) (2 Samples)
(1)
===14803B-1, "Train B CCW Pumps and Check Valve IST and Response Time Tests,"
on April 26, 2022.
(2)14808A-1, "Train A Centrifugal Charging Pump and Check Valve IST and Response Time Test," on May 9, 2022.
71114.01 - Exercise Evaluation
Inspection Review (IP Section 02.01-02.11)===
- (1) The inspectors evaluated the biennial emergency plan exercise during the week of May 16, 2022. The simulated scenario began with a reactor coolant pump trip and subsequent failure of the reactor to automatically trip. This met the conditions for declaration of an Alert. A short time later, a large break loss of coolant accident occurred, along with a safety injection actuation signal. This was followed by a safety injection line break outside of the containment building (radioactive release) and met the conditions for declaration of a Site Area Emergency. As plant main vent stack radiation monitor readings increased, conditions for a General Emergency were met, and the Offsite Response Organizations were able to demonstrate their ability to implement emergency actions.
71114.04 - Emergency Action Level and Emergency Plan Changes
Inspection Review (IP Section 02.01-02.03) (1 Sample)
- (1) The inspectors evaluated submitted Emergency Action Level, Emergency Plan, and Emergency Plan Implementing Procedure changes during the week of May 16, 2022. This evaluation does not constitute NRC approval.
71114.08 - Exercise Evaluation - Scenario Review
Inspection Review (IP Section 02.01 - 02.04) (1 Sample)
- (1) The inspectors reviewed and evaluated in-office, the proposed scenario for the biennial emergency plan exercise at least 30 days prior to the day of the exercise.
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.
Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)
The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:
- (1) Workers exiting the radiologically controlled area.
- (2) Control of non-fuel material in the spent fuel pool.
Radiological Hazards Control and Work Coverage (IP Section 03.04) (4 Samples)
The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:
- (1) Radiation Work Permit (RWP) 22-2302, Unit 2 steam generator eddy current activities.
- (3) RWP 22-2202, Unit 2 reactor coolant pump replacement.
- (4) RWP 22-2411, Unit 2 guide card inspection.
High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (3 Samples)
The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:
- (1) Unit 2 under-vessel area.
- (2) Resin transfer pipechase cubicles in the auxiliary building.
- (3) Unit 2 steam generator manways and hand holes.
Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)
- (1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Permanent Ventilation Systems (IP Section 03.01) (1 Sample)
The inspectors evaluated the configuration of the following permanently installed ventilation systems:
- (1) Testing and charcoal sampling surveillances for Units 1 and 2 trains A and B (1A, 1B, 2A, and 2B) of control room emergency filtration system (CREFS).
Temporary Ventilation Systems (IP Section 03.02) (1 Sample)
The inspectors evaluated the configuration of the following temporary ventilation systems:
- (1) Portable high efficiency particulate air (HEPA) filter air handling units located in Unit 2 containment during the 2R22 refueling outage.
Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the licensees use of respiratory protection devices.
Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)
- (1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses.
71124.04 - Occupational Dose Assessment
Source Term Characterization (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.
External Dosimetry (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated how the licensee processes, stores, and uses external dosimetry.
Internal Dosimetry (IP Section 03.03) (3 Samples)
The inspectors evaluated the following internal dose assessments:
- (1) Investigation whole body count and internal dose investigation performed for uptake on September 19, 2021.
- (2) Investigation whole body count and Internal dose investigation performed for uptake on September 21, 2021.
- (3) Investigation whole body count and Internal dose investigation performed for uptake on September 30, 2021.
Special Dosimetric Situations (IP Section 03.04) (3 Samples)
The inspectors evaluated the following special dosimetric situations:
- (1) Three records for currently declared pregnant workers who declared on February 15, 2022, June 30, 2021 and July 24, 2021.
- (2) Effective dose equivalent (EDEx) calculations and NRC 5 form calculations for three workers performing nozzle dam installation on the steam generators on November 11, 2021.
- (3) EDEx calculations and NRC 5 forms for composite compartments for three workers performing thermal sleeve replacement under the reactor head on September 23, 2021.
71124.05 - Radiation Monitoring Instrumentation
Walkdowns and Observations (IP Section 03.01) (8 Samples)
The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:
- (1) Area radiation monitors in auxiliary building, spent fuel building and radioactive waste processing facility.
- (2) Personal contamination monitors at the radiological control area (RCA) exit and the Unit 2 dress out area.
- (3) Portal monitors used at the plant security building exit to the restricted area.
- (4) Portable ion chambers stored ready for use at the radiation protection (RP) issue point.
- (5) Liquid scintillation detector and high purity germanium detectors in use for analysis of plant effluent samples.
- (6) Portable neutron survey instruments available for use in the RP instrument laboratory.
- (7) Fixed instruments used for analyzing smears for alpha and beta contamination levels in the plant and screening air samples.
- (8) Continuous air monitors used in the auxiliary building and the reactor containment building during the 2R22 refueling outage.
Calibration and Testing Program (IP Section 03.02) (10 Samples)
The inspectors evaluated the calibration and testing of the following radiation detection instruments:
- (1) Canberra GEM-5 Portal Monitor VEGP-HP-1490, 10/27/2021
- (2) Ludlum Model 9-3 Ion Chamber VEGP-HP-1755, 07/31/2021
- (3) Work Order SNC774750, 2RE-0005 Containment High Range Monitor, 02/18/2019
- (4) Mirion Alpha Beta Particulate Monitor VEGP-HP-1889, 09/01/2021
- (5) Calibration of FASTSCAN Whole Body Counting System, 06/16/2020 and 07/15/2021
- (6) Mirion Telepole 2 VEGP-HP-11962, 03/03/2022
- (7) Ludlum 12-S, VEGP-HP-11687, 03/03/2022
- (8) Canberra ARGOS Personnel Contamination Monitor VEGP-HP-1484, 11/10/2022
- (9) Work Order SNC817713, 2RE-0006 Containment High Range Monitor, 06/22/2020
- (10) Thermo Fisher Scientific SAM-11, VEGP-HP-1223, 05/14/2021 Effluent Monitoring Calibration and Testing Program Sample (IP Sample 03.03) (2 Samples)
The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:
- (1) Work Order SNC988387, Calibration of 2RE12444, C, D & E, Plant Vent Post Accident Gas Detector Low Range, 07/08/2021
- (2) Work Order SNC1015929, Calibration of 1RE0018 - DRMS Waste Liquid Effluent Rad Monitor, 11/16/2021
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10)===
- (1) Unit 1 (April 1, 2021 through March 31, 2022)
- (2) Unit 2 (April 1, 2021 through March 31, 2022)
BI02: RCS Leak Rate Sample (IP Section 02.11) (2 Samples)
- (1) Unit 1 (April 1, 2021 through March 31, 2022)
- (2) Unit 2 (April 1, 2021 through March 31, 2022)
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) August 31, 2021 through March 31, 2022.
PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
- (1) August 21, 2021 through March 31, 2022.
EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)
- (1) July 1, 2021, through March 31, 2022 EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1 Sample)
- (1) July 1, 2021, through March 31, 2022 EP03: Alert And Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)
- (1) July 1, 2021, through March 31, 2022
71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) Missed technical specification (TS) surveillance for Unit 1 train A CREFS not documented in the corrective action program (CAP) during August-September 2021.
(Condition Report (CR) 10871721, CR 10871909, CR 10819906)
71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)
- (1) The inspectors reviewed the licensees CAP for potential adverse trends in emergency planning equipment issues that might be indicative of a more significant safety issue.
71153 - Follow Up of Events and Notices of Enforcement Discretion Personnel Performance (IP Section 03.03)
- (1) The inspectors evaluated the Unit 2 containment air quality concerns and licensees performance, on March 17-18,
INSPECTION RESULTS
Inadequate Surveys for Alpha Contamination Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000424,05000425/2022002-01 Open/Closed
[H.1] -
Resources 71124.04 NRC identified a Green finding and associated non-cited violation (NCV) of Title 10 Code of Federal Regulation (CFR) § 20.1501(a)(1)(2)(iii), which requires in part, that licensee perform surveys to evaluate potential radiological hazards.
Description:
To comply with the regulations in 10 CFR Part 20, Standards for Protection against Radiation, licensees are required to perform surveys to evaluate radiological hazards including assessing levels of alpha contamination to determine potential risks to workers. Due to the restrictive annual intake limits for alpha emitting radionuclides, the nuclear power industry developed and implemented guidance found in the EPRI Technical Report 3002000409, Alpha Monitoring Guidelines for Operating Nuclear Power Stations. This report presents a standardized, risk-informed, and graded approach to monitoring and protecting workers and helps ensure compliance with NRC regulations. This guidance has been implemented industry wide and has been incorporated into Vogtle Electric Generating Plant (VEGP) procedures. Compliance with VEGP procedures ensures that adequate radiological controls are in place to comply with the regulations. Surveys performed in accordance with VEGP procedures, adequate analysis of survey data trends, adequate instrumentation for evaluating high level smears, and supervisory oversight are required to ensure radiological controls in place are adequate.
Based on surveys and trends, VEGP radiation protection staff determined all areas in the radiological controlled area of VEGP were "Alpha Level I." An Alpha Level I area is where the ratio of beta/gamma to alpha contamination levels are greater than or equal to 30,000. Alpha areas can be Level I, II or III with Level I being the least restrictive and Level III the most restrictive. Alpha Level II areas are where the ratio is less than 30,000 but greater than or equal to 3,000. The "Alpha Level" designation determines requirements for surveys. During the period from March 8 through March 16, 2022, while Vogtle Unit 2 was in a refueling outage, the inspectors observed multiple examples in areas designated as Alpha Level I where either the minimum number of smears were not taken and/or the smears with the higher contamination levels were not evaluated for alpha in accordance with licensee procedure NMP-HP-300, Radiation and Contamination Surveys, Version 5.7. The requirement to count higher level smears is to confirm the ratio of beta/gamma to alpha contamination remained at or above 30,000. The inspectors also noted that smear counting equipment better suited for analyzing the higher-level smears was not available for use in the field but was stored in the laboratory. In addition, the contamination levels on smears used for the Vogtle Alpha Plant Characterization Study, Update for Fuel Cycle 2R21 Fall 2020, dated November 21, 2020, and performed in accordance with NMP-HP-305, Alpha Radiation Monitoring, were not high enough to support the conclusion that the ratio of beta/gamma to alpha activity was greater than 30,000. In fact, two samples sent to an offsite laboratory for detailed analysis determined that Alpha Level II conditions were present inside the chemical volume and control system and in areas inside the radwaste facility. The licensee failed to incorporate this information into the RP program so that more restrictive Level II controls could be implemented.
Corrective Actions: The licensee re-surveyed the areas in question that were still accessible to restore procedural compliance and entered the issue into the station corrective action program.
Corrective Action References: Condition Report 10870658
Performance Assessment:
Performance Deficiency: The licensee's failure to perform adequate surveys for the presence of alpha contamination.
Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Performing surveys that do not accurately assess alpha contamination could result in potential unmonitored internal exposure.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix C, Occupational Radiation Safety SDP. The inspectors determined the finding had a very low safety significance (Green) because:
- (1) it was not associated with ALARA planning and work controls,
- (2) it was not an overexposure,
- (3) there was no potential for an overexposure; and
- (4) the ability to assess dose was not compromised.
Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety.
Licensee management did not ensure that personnel, equipment, procedures, and other resources were available and adequate to assess the alpha hazard in the plant.
Enforcement:
Violation: Title 10 CFR 20.1501(a)(1)(2)(iii) requires in part, that licensees perform surveys to evaluate potential radiological hazards. Contrary to this, from November 21, 2020 to March 16, 2022, RP failed to perform surveys that were adequate to assess potential alpha hazards in the plant. Specifically, the licensee failed to comply with survey requirements for taking and counting smears as required by procedure NMP-HP-300, Radiation and Contamination Surveys, Version 5.7. In addition, the licensee failed to implement more restrictive survey requirements for areas indicating that Alpha Level II conditions existed in the plant as identified in the 2021 Vogtle Alpha Plant Characterization Study performed in accordance with NMP-HP-305, Alpha Radiation Monitoring, Version 5.11.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Minor Violation 71152A Minor Violation: The inspectors identified two instances where the licensee failed to identify a Condition Adverse to Quality (CAQ). First, in August 2021, the licensee discovered that it would be unable to meet the 31-day offsite analysis requirement for charcoal samples taken from the 2A train (i.e., Unit 2 train A) of the control room emergency filtration system (CREFS), as specified in procedure 28620-C, "Safety Related Filter System Carbon Absorber Sampling," Version 6.0, and initiated Condition Report (CR) 10819906. However, the licensee failed to identify that the charcoal samples from the other three trains of CREFS, that were collected in the months preceding the 2A sample, had not yet been shipped off for analysis either. As a result, CR 10819906 failed to alert the licensee that the 1A, 1B, and 2B trains had exceeded the 31-day analysis requirements and may be at risk of exceeding the Technical Specification (TS) 5.5.11, "Ventilation Filter Testing Program (VFTP)" 18-month surveillance frequency requirement, and, in fact, CREFS train 1A did exceed the 18-month limit and the 25 percent grace period. Second, when the charcoal analysis results from the vendor lab were received in the August - September 2021 timeframe, it was not recognized that train 1A had exceeded the TS 5.5.11 surveillance frequency and no CR was written. Therefore, no review of the event was performed by Operations and Surveillance Requirement (SR) 3.0.3 was never entered. The inspectors determined that these failures were contrary to the requirements of procedure NMP-GM-002-001, "Corrective Action Program Instructions,"
Version 42.0, in that CAQs were not identified and entered in the corrective action program (CAP) when surveillance requirements required by procedure 28620-C and TS 5.5.11 were exceeded. The inspectors noted that all CREFS charcoal sample results satisfactorily met the acceptance criteria of procedure 28620-C and that all four trains remained operable during this period.
Screening: The inspectors determined the performance deficiency was minor. No cornerstone objectives were adversely impacted. Specifically, all CREFS test results met the established acceptance criteria and there was no indication of system inoperability.
Enforcement:
Title 10 CFR 50 Appendix B, Criterion XVI, "Corrective Actions," states that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are to be promptly identified. The licensee uses procedure NMP-GM-002-001 to meet this requirement. Contrary to this, on two instances in August - September 2021, the licensee failed to promptly identify safety-related equipment surveillance deficiencies as CAQs. The licensee initiated Corrective Action Report (CAR) 308603 to address concerns regarding CREFS surveillance completion and tracking. This failure to comply with 10 CFR 50, Appendix B, Criterion XVI constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On April 1, 2022, the inspectors presented the RP baseline occupational inspection results to Mr. Drayton Pitts, Site Vice President (SVP), and other members of the licensee staff.
On June 22, 2022, the inspectors presented the emergency preparedness exercise inspection results to Mr. Ho Nieh, acting SVP, and other members of the licensee staff.
On July 14, 2022, the inspectors presented the integrated inspection results to Mr. Sonny Dean, SVP, and other members of the licensee staff.
On July 20, 2022, the inspectors re-exited the RP baseline occupational inspection results to Mr. Robert Norris, Plant Manager, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
Resulting from
Inspection
Condition
Report(s)
10871705, 10871706
Procedures
18036-C
Seismic or Severe Weather Event
14.0
Corrective Action
Documents
Condition
Report(s)
10884171
Corrective Action
Documents
Resulting from
Inspection
Condition
Report(s)
10876789, 10885122
1X4DB159-2
P&I Diagram - Main Steam System - System No. 1301
34.0
2X4DB133-2
P&I Diagram - Nuclear Service Cooling Water - System No.
202
2X4DB221
P&I Diagram - Safety Related (Essential) Chillers Unit 2
Trains A & B - System No. 1592
26.0
2X4DB233
P&I Diagram - Essential Chilled Water Cooling Coils Unit 2,
Train A - System No. 1592
24.0
Drawings
2X4DB234
P&I Diagram - Essential Chilled Water Cooling Coils Unit 2,
Train B - System No. 1592
25.0
Miscellaneous
2-CA-22-1301-
00064(1)
Tagout for Unit 2 Loop 4 MSIV air leak
13601-2
Steam Generator and Main Steam System Operation
2.0
13744A-2
Train A Essential Chilled Water System
15.1
13744B-2
Train B Essential Chilled Water System
15.0
14552-2
NSWC Flow Path Verification
Procedures
14553-2
ESF Room Cooler and Safety Related Chiller Flow Path
Verification
Corrective Action
Documents
Condition
Report(s)
10877722
Procedures
2840A-2
Zone 140A - Containment Building - Levels A, B, 1, 2, and 3
Fire Fighting Preplan
3.1
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2840B-2
Zone 140B - Containment Building - Levels A, B, 1, 2, and 3
Fire Fighting Preplan
4.1
2840C-2
Zone 140C - Containment Building - Levels A, B, 1, 2, and 3
Fire Fighting Preplan
2.1
2840E-2
Zone 140E - Containment Building - Levels A, 1, 2, and 3
Fire Fighting Preplan
1.1
Corrective Action
Documents
Condition
Report(s)
10873162, 10873448, 10874755, 10797717, 10797724
Procedures
NMP-ES-051-004
Pull Box Inspection
7.0
Work Orders
SNC1165731
Miscellaneous
V-RQ-SG-U1 Trip
5/2022
U1 Trip Recovery
05/03/2022
Miscellaneous
RBD-V12-5069-
202
10CFR50.59 Categorization Nuclear Service Cooling Water
System Vogtle Electric Generating Plant
08/10/2018
2R22 2AA02 & B RAT Work Window during Mode 5 DID
Contingency Plan
eSOMS Logs - April 1, 2022
04/01/2022
Unit 2 Phoenix A4 Risk - June 14, 2022
06/14/2022
Miscellaneous
2-ER-22-1213-
00038(2)
Protected Equipment Tags for 2B SFPC and Supporting
Equipment
04/01/2022
10032-C
Outage Risk Assessment Monitoring - 2AA02 and 2B RAT
04/01/2022
NMP-DP-001
Operational Risk Awareness
23.0
NMP-OS-010-003
Vogtle Protected Equipment Logs
11.2
NMP-OS-020
Station Response to Southern Company System Alert
Conditions
2.0
Procedures
RBD-V12-5069-
1592
Vogtle Electric Generating Plant Units 1&2 - 10 CFR 50.69
System Categorization - Essential Chilled Water
03/01/2019
Corrective Action
Documents
Condition
Report(s)
10834358, 10871020, 10871174, 10878357, 10842403,
10846607, 10848629, 10858962, 10871726, 10876618,
10880126, 10880220
Corrective Action
Documents
Resulting from
Condition
Report(s)
10881876, 10864186, 10864198, 10869812, 10894638
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Inspection
One Line Diagram - 480V Motor Control Center 1ABF 1-
1805-S3-ABF
16.0
Elementary Diagram - Main Steam System Safety Actuation
Signals
Elementary Diagram - Main Steam System Safety Actuation
Signals
10.0
Elementary Diagram - Aux. Feedwater System 1FV-5155
1X3D-CE-H02E
Wiring Diagram - Aux Relay Panel PAR2 Sh. 1 1-1816-U3-
2
Wiring Diagram - Aux Relay Panel PAR4 Sh. 3 1-1816-U3-
004
10.0
Drawings
1X4DB161-2
P&I Diagram - Auxiliary Feedwater System - System No.
1302
29.0
Miscellaneous
RBA-22-001-V
Risk-Based Analysis for missed EDG HVAC surveillance
2/11/2022
00309-C
Control of Unattended Temporary Material in Containment in
Modes 1-4
4.1
14900-C
Containment Exit Inspection
24.1
NMP-AD-012
15.0
Procedures
NMP-AD-012-
GL04
1.1
Work Orders
SNC1198393, SNC687323, SNC692064, SNC589650,
SNC594038
Corrective Action
Documents
Condition
Report(s)
10838630
Corrective Action
Documents
Condition
Report(s)
10887791
Miscellaneous
1X4AF01-00136
Instruction Manual for Ingersoll Rand Centrifugal Pumps
290-C
Agastat Series 2100 and 7000 Timing Relay Calibration
39.0
23830-C
Process Instrument Loop Channel Calibration
23.2
27080-C
Ingersoll Rand Model 10 x 18 SE CCW Pump Maintenance
27.3
NMP-ES-017-008
MOV Mechanical and Electrical Inspections
11.4
NMP-ES-017-021
MOV Diagnostic Procedure for VOTES Infinity
2.4
Procedures
NMP-MA-014
Post Maintenance Testing/Post Modification Testing
2.4
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
NMP-MA-014-
001
Post Maintenance Testing Guidance
5.9
Work Orders
SNC1149757, SNC894586, SNC1001652, SNC1005811,
SNC1143929, SNC1325415, SNC1120883, SNC928719,
SNC1092408, SNC1191043, SNC756250, SNC1071963
Corrective Action
Documents
Condition
Report(s)
10869754, 10869338, 10869420, 10869460
Corrective Action
Documents
Resulting from
Inspection
Condition
Report(s)
10870909, 10869667
Schedule Report for Security 02/2022 - 04/2022
Schedule Report for Maintenance - March 2022
Schedule Report for Operations 02/2022 - 04/2022
Miscellaneous
Unit 2 Cycle 23 Initial Cycle Startup and Power Ascension
04/04/2022
Procedures
NMP-RE-011-F01
2R22 Reload
1.0
Corrective Action
Documents
Resulting from
Inspection
Condition
Report(s)
10879904, 10891645, 10894648
Procedures
14808A-1
Train A Centrifugal Charging Pump and Check Valve IST
and Response Time Test
Work Orders
SNC1182716
ALARA Plans
RWP 22-2401
Fuel Offload/Reload, Work In Progress Review, 50%
Exposure
03/12/22
Corrective Action
Documents
CR 10865968
CR 10867476
CR 10868115
CR 10868139
Corrective Action
Documents
Resulting from
Inspection
CR 10868155
Procedures
NMP-HP-302
Restricted Area Classification, Postings, and Access Control
Version 12.7
10867978
Incomplete PAPR Qualification
3/21/2022
Corrective Action
Documents
CR 10866532
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
10895548
07/20/2022
Corrective Action
Documents
Resulting from
Inspection
10895553
07/20/2022
91702-C
Emergency Equipment and Supplies
Version 37
NMP-AD-025
Quality Assurance and Non-Quality Assurance Records
Administration
Version 13
NMP-HP-004
Inspection, Repair, and Storage of Self-Contained Breathing
Apparatus
Version 1.6
NMP-HP-501-002
Control, Issuance, and Return of Radiological Respiratory
Protection Equipment
Version 2.2
Procedures
NMP-HP-515
3M Versaflo Powered Air Purifying Respirator (PAPR) Use
and Control
1.4
SNC1077306
U2 Train B Control Emergency Filtration System HEPA Filter
and Carbon Adsorber Test
09/02/2021
SNC1083728
U1 Train B Control Emergency Filtration System HEPA Filter
and Carbon Adsorber Test
09/02/2021
SNC1090827
U2 Train A Control Emergency Filtration System HEPA Filter
and Carbon Adsorber Test
Work Orders
SNC963459
U1 Train A Control Emergency Filtration System HEPA Filter
and Carbon Adsorber Test
09/02/2021
Procedures
NMP-HP-300
Radiation and Contamination Surveys
Version 5.7
Vogtle Alpha Characterization Study - Update for Fuel Cycle
2R21 Fall 2020
11/21/2020
Survey #252374
Upper Cavity
03/08/2022
Survey #252600
RCP #3 Shroud
03/11/2022
Survey #252769
Steam Generator Channel Head Hot Leg
03/14/2022
Survey #252895
Steam Generator Manway Platt #3
03/16/2022
Radiation
Surveys
Survey #252898
Steam Generator Manway Platt #2
03/16/2022
Corrective Action
Documents
Resulting from
Inspection
CR 10868179
Corrective Action
10870726
04/01/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
10871721
04/05/2022
10871909
04/06/2022
Documents
Resulting from
Inspection
10895563
07/20/2022
Procedures
NMP-GM-002-
001
Corrective Action Program Instructions
Version 42.0
Condition
Report(s)
10837404, 10819321, 10798605, 10817967, 10806717,
10809130, 10809653, 10817967, 10837642, 10883188,
10891642, 10827599, 10829454, 10837094, 10844262,
10837404, 10837445, 10835036, 10840384, 10805972,
10836944, 10849075, 1097359
Corrective Action
Documents
Corrective Action
Report(s)
279762
Corrective Action
Documents
Condition
Report(s)
10867221, 18067224, 10869937
Miscellaneous
NMP-EP-141-
003-F02
EAL Classification Matrix COLD CONDITIONS
3.0
10000-C
Operations Administrative Controls
100.1
18035-C
Toxic/Asphyxiant/Flammable Gas Release
NMP-AP-003
Procedure and Work Instruction Use and Adherence
6.2
NMP-AP-005
Transient Response Guidelines
3.0
Procedures
NMP-OS-007
Conduct of Operations
18.0