IR 05000424/2023004

Integrated Inspection Report 05000424-2023004 and 05000425-2023004

ML24024A024
Person / Time
Site:
Issue date:	02/05/2024
From:	Alan Blamey Division Reactor Projects II
To:	Coleman J Southern Nuclear Operating Co
References
IR 2023004
Download: ML24024A024 (16)

Text

SUBJECT:

VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 - INTEGRATED INSPECTION REPORT 05000424/2023004 AND 05000425/2023004

Dear Jamie Coleman:

On December 31, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Vogtle Electric Generating Plant, Units 1 and 2. On January 11, 2024, the NRC inspectors discussed the results of this inspection with Robert Norris 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 and 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 and 2.February 5, 2024 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: NPF-68 and NPF-81

Report Numbers: 05000424/2023004 and 05000425/2023004

Licensee: Southern Nuclear Operating Company, Inc.

Facility: Vogtle Electric Generating Plant, Units 1 and 2

Location: Waynesboro, GA

Inspection Dates: October 01, 2023 to December 31, 2023

Inspectors: J. Bell, Senior Health Physicist J. Bundy, Senior Operations Engineer M. Checkle, Senior Allegations Coordinator B. Kellner, Senior Health Physicist T. Morrissey, Senior Resident Inspector B. Truss, Resident Inspector A. Wang, Resident Inspector

Approved By: Alan J. Blamey, Chief Reactor Projects Branch 2 Division of Reactor Projects

Enclosure

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 and 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

Unit 1 Design Control: Inadequate Equivalency Evaluation Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.12] - Avoid 71152A NCV 05000424/2023004-01 Complacency Open/Closed The NRC identified a Green finding and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50 Appendix B, Criterion III, Design Control, for the licensees failure to develop an adequate item equivalency for the replacement of a safety-related valve. Specifically, reactor coolant system (RCS) loop 3 hot leg sample valve (1-1202-U4-045) was replaced with a valve with a carbon steel yoke that was susceptible to boric acid corrosion without providing a basis for its use.

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000424/2023-002-00 LER 2023-002-00 for Vogtle 71153 Closed Electric Generating Plant,

Unit 1, Manual Reactor Trip Due to Failure of a Heater Drain Pump and Standby Condensate Pump

NOV 05000424,05000425/20 Workers Entered Unit 1 92702 Closed 23090-01 Containment on the Wrong Radiation Work Permit (RWP) EA-22-108

PLANT STATUS

Unit 1 began the inspection period at rated thermal power (RTP). On November 27, 2023, power was reduced to approximately 92 percent RTP for several hours to support main turbine valve testing. The unit remained at or near RTP for the remainder of the inspection period.

Unit 2 began the inspection period at approximately 20 percent RTP following a planned refueling outage. The unit was returned to RTP on October 3, 2023. On October 29, 2023, 2A heater drain pump failed due to a motor short. Due to the loss of the heater drain pump, the unit was reduced to approximately 91 percent RTP. On October 31, 2023, power was raised to approximately 95 percent RTP, the upper limit for operation with one heater drain pump. On December 3, 2023, power was lowered to approximately 86 percent RTP to address tube leakage in the 2A main condenser water box. The degraded tubes were plugged, and the 2A condenser water box was returned to service. On December 8, 2023, power was returned to approximately 95 percent RTP. On December 14, 2023, power was lowered to approximately 85 percent RTP to address tube leakage in the 2A condenser water box. The degraded tubes were identified and plugged. On December 20, 2023, power was lowered to approximately 70 percent RTP to limit degradation of the 2A condenser water box tubes from high flow from the 2A heater drain tank through its high level dump valve. The 2A heater drain tank is operating on its high level dump because the 2A heater drain pump is not available due to a faulted motor. The unit remained at or near 70 percent RTP 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.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (2 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Unit 2, train "A" emergency diesel generator (EDG) and associated 4160V engineered safety feature (ESF) bus while train "B" EDG was out of service (OOS) on October 2-6, 2023

(2) Unit 2, train "B" nuclear service cooling water (NSCW) while train "A" NSCW was OOS on November 8-10, 2023

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 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 57A/81A/125B/126B/153/178/180, Unit 2 control building level 3 ESF chiller and normal air conditioner rooms, on October 27, 2023

(2) Fire Zones 99/104/45/39A, Unit 2 north and south main steam and feed valve rooms, on October 30, 2023

(3) Fire Zones 94/95/173/174, Unit 1 lower cable spreading room, on November 15, 2023

(4) Fire Zones 30/31/32/33/26B, Unit 1 auxiliary component cooling water pump rooms, 1A and 1B safety injection pump rooms, and auxiliary building "B" level penetration area, on November 30, 2023

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance

Requalification Examination Results (IP Section 03.03) (1 Sample)

The licensee completed the annual requalification operating tests required to be administered to all licensed operators in accordance with Title 10 of the Code of Federal Regulations 55.59(a)(2), "Requalification Requirements," of the NRC's "Operator's Licenses." The inspector performed an in-office review of the overall pass/fail results of the individual operating tests, and the crew simulator operating tests in accordance with IP 71111.11, "Licensed Operator Requalification Program and Licensed Operator Performance." These results were compared to the thresholds established in section 3.03, "Requalification Examination Results," of IP

===71111.11.

(1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating tests, which the facility licensee completed administering on October 30,2023.

71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Requalification Program (IP Section 03.04)===

(1) Biennial Requalification Written Examinations

The inspectors evaluated the quality of the licensed operator biennial requalification written examination administered on November 3, 2022.

Annual Requalification Operating Tests

The inspectors evaluated the adequacy of the facility licensees annual requalification operating test.

Administration of an Annual Requalification Operating Test

The inspectors evaluated the effectiveness of the facility licensee in administering requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives.

Requalification Examination Security

The inspectors evaluated the ability of the facility licensee to safeguard examination material, such that the examination is not compromised.

Remedial Training and Re-examinations

The inspectors evaluated the effectiveness of remedial training conducted by the licensee, and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.

Operator License Conditions

The inspectors evaluated the licensees program for ensuring that licensed operators meet the conditions of their licenses.

Control Room Simulator

The inspectors evaluated the adequacy of the facility licensees control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46.

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 control room during a down power of Unit 2 from 95 percent to 84 percent RTP to address sodium in-leakage to the condenser hot well on December 12, 2023.

(2) The inspectors observed and evaluated licensed operator performance in the control room during a down power of Unit 2 from 85 percent to 70 percent RTP to mitigate condenser tube damage due to 2A heater drain pump being out of service on December 20, 2023.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated a simulator scenario consisting of a loss of one 4160 volt ESF bus, a forecast of hurricane force winds on-site, a loss of a circulating water pump, a manual reactor trip and a faulted steam generator inside containment on October 23, 2023.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (3 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components remain capable of performing their intended function:

(1) Unit 1 component cooling water system, on October 9, 2023.

(2) Unit 2 auxiliary feedwater (AFW) system, on October 12, 2023

(3) Unit 1 turbine driven AFW pump experienced two failures June 20, 2023 and August 29, 2023 (condition reports (CRs) 10981359 and 11001851)

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (2 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, elevated risk due to train "B" EDG OOS for planned maintenance, on October 2 - 9, 2023.

(2) Unit 2, elevated risk due to train "A" NSCW OOS for planned maintenance, on November 8-10, 2023

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) CR 11012191, Unit 2, train "A" EDG missing shroud cover plates and bolts, on October 11, 2023

(2) CR 11004793, Unexpected Unit 2, train "A" EDG voltage drop during 14980A-2 "Diesel Generator 2A Operability Test," on October 12, 2023

(3) CR 11020598, Unit 2, train "B" EDG 24-hour run with generator control panel doors not secured due to installed recorder, on November 2, 2023

(4) CR 11029812, Unit 1, train "A" ESF chiller max pump out rate exceeded due to air in-leakage, on December 12, 2023

71111.24 - Testing and Maintenance of Equipment Important to Risk

The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:

Post-Maintenance Testing (PMT) (IP Section 03.01) (1 Sample)

(1) Unit 2, Functional Test No. 3, "DG2B Final Acceptance Testing Woodward 2301A Speed Control System for Unit 2 Emergency Diesel Generator 701 Governor Vogtle Unit 2 DCP SNC953980, Work Order SNC1214355, and 14980B-2, "Diesel Generator 2B Operability Test," following governor replacement, WOs SNC1214356, SNC1214357, SNC1214360, and SNC1214369, on October 10, 2023

Surveillance Testing (IP Section 03.01) (1 Sample)

(1) Unit 2, 14668B-2, "Train B Diesel Generator Operability Test," on November 2,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)===

(1) Unit 1 (October 1st, 2022, through September 30th, 2023)

(2) Unit 2 (October 1st, 2022, through September 30th, 2023)

MS06: Emergency AC Power Systems (IP Section 02.05) (2 Samples)

(1) Unit 1 (October 1st, 2022, through September 30th, 2023)

(2) Unit 2 (October 1st, 2022, through September 30th, 2023)

MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)

(1) Unit 1 (October 1st, 2022, through September 30th, 2023)

(2) Unit 2 (October 1st, 2022, through September 30th, 2023)

===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) CR 1098266, Unit 1 reactor coolant system hot leg #3 sample valve packing leakage and valve yoke corrosion, on June 24, 2023.

(2) The inspectors conducted interviews and reviewed corrective actions associated with the environment for reporting fatigue and safety concerns in a department. The inspectors conducted interviews of 17 personnel in the department from three different teams, reviewed corrective actions associated with the Employee Concerns Program (ECP), safety conscious work environment and technical evaluations, and reviewed notes from recent safety culture monitoring panels. The inspectors determined that, in the area of environment for raising concerns, the majority of the personnel interviewed stated that they would raise nuclear safety and security concerns through multiple avenues.

The inspectors also verified that corrective actions previously implemented to address the environment for reporting fatigue were completed. When it comes to reporting fatigue, most personnel reported that, although they do not fear retaliation when reporting fatigue, they were hesitant to report fatigue and view reporting fatigue negatively. Personnel felt that when they report fatigue they were not viewed as an individual contributor or team member. In addition, most of the personnel interviewed believed other employees within the department may be hesitant to report fatigue. In the area of problem identification and resolution, there was also a perception that, although corrective actions have been implemented, there is a lack of improvement in the overall working conditions. The majority of personnel interviewed stated that the amount of overtime, staffing numbers, work schedules, and turnover rate represent challenges to the work environment and may further impact the persons willingness to report fatigue. If these perceptions are not addressed, it may affect the persons willingness to report fatigue in the future. The ECP had identified similar observations during their corrective action effectiveness review. Additionally, the NRC previously established minimum staffing levels and fitness for duty requirements, that ensure sufficient staffing levels and rest periods to prevent fatigue. The licensee continues to meet these requirements and the NRC will continue to independently inspect this area to confirm the required minimum staffing and fitness for duty requirements are met. The inspectors observations were shared with the stations management who will continue to work with ECP to identify additional corrective actions, as necessary, to address these perceptions.

71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)

(1) The inspectors reviewed the licensees corrective action program for potential adverse trends in resident inspector identified issues that might be indicative of a more significant safety issue. The inspectors observed foreign material in the NSCW pump rooms and water basins, degraded fire doors, missing protected equipment signs, and boric acid leaks which indicates a need for increased sensitivity to low level issues. The number of items identified by the resident inspectors increased each quarter of 2023.

71153 - Follow Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)

The inspectors evaluated the following licensee event report (LER):

(1) LER 2023-002-00, Manual (unit 1) Reactor Trip Due to Failure of a Heater Drain Pump and Standby Condensate Pump (ADAMS Accession No. ML23284A427).

The inspectors determined that it was not reasonable to foresee or correct the cause discussed in the LER; therefore, no performance deficiency or violation of NRC requirements was identified. This LER is Closed.

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

===92702 - Follow-Up on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory Action Letters, and Orders

The inspectors conducted a follow-up inspection of Southern Nuclear Operating Companys (SNC) corrective actions in response to notice of violation (NOV) EA-22-108 issued on September 5, 2023.

Follow-Up on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory Action Letters, and Orders===

(1) The inspectors evaluated the corrective actions that were implemented by SNC to determine whether they were adequate to address the identified deficiencies and to prevent recurrence. As part of the corrective actions review the inspectors noted installation, and observed operation, of the 'smart turnstiles' identified as a corrective action during baseline radiation safety inspection activities completed during the Unit 2 fall outage in September 2023 (inspection documented in NRC integrated inspection report dated October 27, 2023; ML23291A304). The inspectors concluded that SNC's corrective actions were both timely and appropriate. Based on the results of this review, no additional NRC actions are necessary.

For administrative purposes. The original apparent violation (AV) and the circumstances surrounding it were previously described in detail in the NRCs letter to SNC Vogtle on March 30, 2023 (ADAMS Accession No. ML23047A033) and was assigned violation tracking number AV 05000424,05000425/2023090-01. This AV tracking number was re-designated as Notice of Violation (NOV) 05000424,05000425/2023090-01 in an NRC inspection report dated September 5, 2023 (ML23223A233), when the NOV was issued. The NOV 05000424,05000425/2023090-01, is now closed.

INSPECTION RESULTS

Unit 1 Design Control: Inadequate Equivalency Evaluation Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.12] - Avoid 71152A NCV 05000424/2023004-01 Complacency Open/Closed The NRC identified a Green finding and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50 Appendix B, Criterion III, Design Control, for the licensees failure to develop an adequate item equivalency for the replacement of a safety-related valve. Specifically, reactor coolant system (RCS) loop 3 hot leg sample valve (1-1202-U4-045) was replaced with a valve with a carbon steel yoke that was susceptible to boric acid corrosion without providing a basis for its use.

Description:

On June 24, 2023, the inspector completed a containment inspection of unit 1 that was shut down in Mode 4 (<350F) in preparation for replacement of two pressurizer code safety valves. The inspector identified a significant area of wet boric acid buildup on the floor and on the overhead piping in the vicinity of the reactor coolant system (RCS) loop 3 hot leg. The source of the leakage was packing leakage from manual valve 1-1202-U4-045, RCS hot leg #3 sample line isolation. The issue was placed in the licensees corrective action program as CR 10982666. The leakage was located inside the locked bioshield. The inspector had been informed that boric acid inspections inside the bioshield would not be completed since they had been completed within the last 90 days when the unit was shut down for a refueling outage. Valve 1-1202-U4-045s carbon steel yoke showed signs of moderate to severe boric acid corrosion.

Valve 1-1202-U4-045 was replaced during the Spring 2023 refueling outage (March 2023, WO SNC1452807) when it was suspected to be leaking at power and was found to have a moderate amount of discolored boric acid in the vicinity of the valve body/packing area. The valve yoke was not degraded since it was stainless-steel. Since a replacement valve of the same model was not available, an Item equivalency evaluation would be needed to evaluate a suitable replacement. The licensee approved item equivalency (IE) SNC1453163 for the valve replacement. IE SNC1453163 updated equivalency determination (ED) A060965701 to include valve 1-1202-U4-045. ED A060965701 approved the use of Flowserve-Edwards, V-pattern globe stop univalve (F316) as an acceptable replacement for Dresser globe valve, model no. 3/4 7150W-1-XMB1-NC055 for a valve located downstream of safety injection pump 1-1204-P6-003. The major difference between the two valves was the Flowserve valve had a carbon steel yoke while the original Dresser valve yoke was stainless-steel. IE SNC1453163 and ED A060965701 did not address boric acid corrosion of the carbon steel yoke in the event of a packing leak.

IE SNC1453163 as issued under procedure NMP-ES-098, Interface Procedure for NISP-EN-02, Standard Item Equivalency Process," Version 2.4 and Nuclear Industry Standard Process Engineering procedure NISP-EN-02, Standard Item equivalency Process (SIEP),

Revision 01. NISP-EN-02, Attachment 3 step 1.6.9, Evaluate design characteristics and document, requires, in part, the responsible engineer to consider materials of construction and to provide a basis for acceptability of differences. The material of construction for the replacement valve included a carbon steel yoke while the original valve had a stainless-steel yoke. The basis for the IE did not include a justification for using a valve with a carbon steel yoke in a system containing boric acid.

Corrective Actions: CR 10985255 was initiated requesting an engineering evaluation of the valve condition and to find a suitable replacement valve. CR 10985255 documented that it was not advisable to have a valve with susceptible materials in an area not accessible at power and that unchecked boric acid corrosion of the yoke could possibly impact RCS integrity. The licensee replaced the valve packing and shut the valve isolating the packing to preclude any further leakage. The valve will remain shut during the operating cycle to prevent any packing leakage that would result in further degradation of the valve yoke. Proposed corrective actions include replacing the valve during the next refueling outage (fall 2024) with a valve with a stainless-steel yoke that is not susceptible to boric acid corrosion.

Corrective Action References: CR 10985255

Performance Assessment:

Performance Deficiency: The inspectors determined that the failure to develop an adequate IE for the replacement of valve 1-1202-U4-045 was a performance deficiency that was within the licensees ability to foresee and correct and should have been prevented.

Screening: The inspectors determined the PD was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern.

Specifically, continued boric acid corrosion of the hot leg sample valve yoke during the operating cycle would have resulted in failure of the valves packing and increased RCS unidentified leakage. If left as found with the packing leakage, it would be likely that sometime during the operating cycle, the unidentified RCS leakage from the degraded valve would have exceeded the Technical Specification (TS) 3.4.13.b limit of 1 gallon per minute (gpm) which would have been an upset to plant stability resulting in a TS required shutdown of the unit.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined that the finding was of very low safety significance (Green), because the finding would not have resulted in exceeding the RCS leak rate for a small loss of coolant accident (LOCA) (leakage in excess of normal makeup) and would not have affected other systems used to mitigate a LOCA.

Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. Specifically, IE SNC1453163 did not consider valve packing leakage and its impact on valve integrity when installing a valve with a carbon steel yoke in a system containing boric acid.

Enforcement:

Violation: 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires that measures be established for the selection and review of parts for suitability of application. NMP-ES-098, Interface Procedure for NISP-EN-02 Standard Item Equivalency Process, Version 2.4, endorses industry standard procedure NISP-EN-02, Standard Item Equivalency Process (SIEP), Revision1. NISP-EN-02, Attachment 3 step 1.6.9, Evaluate design characteristics and document, requires, in part, that the responsible engineer consider materials of construction and provide a basis for acceptability of differences.

Contrary to this, since March 11, 2023, IE SNC1453163 allowed replacement of RCS hot leg sample isolation valve 1-1202-U4-045 originally with a stainless-steel yoke with one with a carbon steel yoke susceptible to boric acid corrosion without providing a basis for its use.

Enforcement Action: This violation is being treated as a 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 January 11, 2024, the inspectors presented the integrated inspection results to Robert Norris, Plant Manager, and other members of the licensee staff.

• On November 28, 2023, the inspectors presented the 92702 Follow-Up Inspection Debrief inspection results to Robert Norris, Plant Manager, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.11Q Procedures 12004-2 Power Operation (Mode 1) Version 5.0

71111.15 Procedures 13744A-1 Train A Essential Chilled Water System Version 17.2

71111.15 Procedures 14980A-2 Diesel Generator 2A Operability Test Version 33.0

2702 Corrective Action List of Condition Reports related to workers entering the 11/15/2023

Documents RCA on the wrong RWP from 10/01/2021 to 11/15/2023

2702 Corrective Action 10828724 Workers entered containment on wrong RWP 09/21/2021

Documents

2702 Corrective Action 10828726 Worker received a dose rate alarm 09/21/2021

Documents

2702 Corrective Action CAR 423081 Apparent NRC Violation: "Workers Entered Unit 1 04/24/2023

Documents Containment on the Wrong Radiation Work

Permit"

2702 Corrective Action TE 1129089 Plant Manager and a Manager (Suggest REG Affairs 09/11/2023

Documents Manager) do a video discussing the issue and re-enforce the

importance of following

procedures and the personal repercussions of deliberate

misconduct.

2702 Corrective Action TE 140756 V2R23 RP OLL Action - U2 RWPs (CTMT/AUX) 11/8/2023

Documents

2702 Corrective Action Technical V2R23 RP OLL Action - U1 RWPs (CTMT/AUX) 11/8/2023

Documents Evaluation (TE)

140754

2702 Miscellaneous Memo regarding operation and control of the 'smart 11/02/2023

turnstiles' used to control containment entry

2702 Miscellaneous Vogtle Electric Generating Plant - Units 1 and 2 Response 05/01/2023

to Apparent Violation in NRC Inspection Report 05000424,

25/2023090; EA-22-108

2702 Miscellaneous Electronic Dosimeter Dose and Dose Rate Alarm Logs for 11/07/2023

the period 09/01/2021 through 09/30/2023

2702 Miscellaneous PowerPoint 2R23 Outage Supervisor Kick-off 8/24/2023

Presentation

2702 Miscellaneous PowerPoint Achieving Regulatory Excellence 01/22/2022

Inspection Type Designation Description or Title Revision or

Procedure Date

Presentation

2702 Procedures NMP-GM-002 Corrective Action Program Version 16.0

2702 Procedures NMP-GM-002- Corrective Action Program Instructions Version 47.0

001

2702 Radiation Work Vogtle Radiation Work Permits Used During CY 2022 Various

Permits (RWPs)

2702 Radiation Work Vogtle Radiation Work Permits Used During CY 2023 Various

Permits (RWPs)

2702 Radiation Work List of Vogtle CY 2023 RWPs 11/01/2023

Permits (RWPs)

2702 Radiation Work List of Vogtle CY 2022 RWPs 11/01/2023

Permits (RWPs)

2702 Self-Assessments TE 1116779 Radiological Protection Fundamental Behaviors 02/08/2023

2702 Self-Assessments TE 1129848 Perform a Check-in-Self Assessment prior to the follow-up 11/27/2023

Inspection. Per MRC, this CISA will serve as the

effectiveness review for the LOE

13