IR 05000424/2023011

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Biennial Problem Identification and Resolution Inspection Report 05000424/2023011 and 05000425/2023011
ML23222A008
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 08/11/2023
From: Alan Blamey
Division Reactor Projects II
To: Brown K
Southern Nuclear Operating Co
References
IR 2023011
Download: ML23222A008 (1)


Text

August 11, 2023

SUBJECT:

VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2-BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000424/2023011 AND 05000425/2023011

Dear Keith Brown:

On June 30, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Vogtle Electric Generating Plant, Units 1 and 2.

On August 4, 2023, the NRC inspectors discussed the results of this inspection with Robert Norris, Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspection team reviewed the stations problem identification and resolution program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for problem identification and resolution programs.

Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.

Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.

Three findings of very low safety significance (Green) are documented in this report. Three of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violations or the significance or severity of the violations 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.

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, Signed by Blamey, Alan on 08/11/23 Alan J. Blamey, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket Nos. 05000424 and 05000425 License Nos. NPF68 and NPF81

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000424 and 05000425 License Numbers: NPF-68 and NPF-81 Report Numbers: 05000424/2023011 and 05000425/2023011 Enterprise Identifier: I2023011-0021 Licensee: Southern Nuclear Operating Company, Inc.

Facility: Vogtle Electric Generating Plant, Units 1 and 2 Location: Waynesboro, GA Inspection Dates: June 12, 2023 to June 30, 2023 Inspectors: A. Alen, Senior Project Engineer J. Parent, Resident Inspector E. Robinson, Resident Inspector C. Scott, Senior Project Engineer 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 a biennial problem identification and resolution 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

Engineered Safety Features Chillers Performance Data Not Considered During § 50.69 Periodic Review Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.4] - Trending 71152B Systems NCV 05000424,05000425/202301102 Open/Closed An NRC-identified Green non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 50.69(e), Feedback and Process Adjustment - Risk-Informed Safety Class 3 (RISC-3), was identified when the licensee failed to identify and consider failures of the engineered safety feature chillers during the periodic review of the essential chilled water system as required by licensee procedure.

Performance Data for RISC3 Structures, Systems, and Components Scoped-Out of the Maintenance Rule (§ 50.65) not considered during § 50.69 Periodic Reviews Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.8] - 71152B Systems NCV 05000424,05000425/202301103 Procedure Open/Closed Adherence An NRC-identified Green NCV of 10 CFR 50.69(e)(3), Feedback and Process Adjustment-RISC3, was identified for the licensees failure to assess performance data for RISC3 structures, systems, and components (SSCs) scoped-out of the maintenance rule (§ 50.65) to determine if adverse SSC performance resulted from the application of alternate treatment (§ 50.69).

Failure to Implement Maintenance Instructions for Component Cooling Water Pump Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.1] - 71152B Systems NCV 05000425/202301101 Resources Open/Closed A self-revealing Green NCV of Technical Specifications 5.4.1.a, Procedures, was identified for the licensees failure to follow procedures for the maintenance and post-maintenance testing of Unit 2 A train (2A) component cooling water (CCW) pump #1. As a result, the 2A CCW pump #1 was rendered inoperable for approximately 26 days.

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.

OTHER ACTIVITIES-BASELINE

71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 03.04)

(1) The inspectors performed a biennial assessment of the effectiveness of the licensees Problem Identification and Resolution program, use of operating experience, self-assessments and audits, and safety-conscious work environment.

Problem Identification and Resolution Effectiveness: The inspectors assessed the effectiveness of the licensees Problem Identification and Resolution program in identifying, prioritizing, evaluating, and correcting problems. Specifically, the team evaluated the licensee's compliance with their Problem Identification and Resolution program, as described in procedure NMP-GM002, "Corrective Action Program," version 16.0 and NRC regulations. The inspectors reviewed a sample of condition reports (CRs),generated since the last problem identification and resolution inspection (April 2021), associated with the auxiliary feedwater system, component cooling water system (CCW), and the chemical and volume control system (CVCS). These reviews included failures; corrective and preventive maintenance issues; surveillances; reliability; maintenance rule (10 CFR 50.65) performance; and alternative treatment (10 CFR 50.69)performance. The inspectors also conducted a five-year review of the CCW and CVCS systems. The corrective actions for the following notice of violation (NOVs), non-cited violations (NCVs), and minor violations (MVs) were evaluated as part of the assessment: NOV 202140101, NCV 202100402, NCV 202200101, NCV 202200201, NCV 202200301, NCV 202200302, NCV 202240301, NCV 202242001, NCV 2023001, and MV 2022002.

Operating Experience: The inspectors assessed the effectiveness of the licensees processes for use of operating experience. Specifically, the team reviewed issues identified through both NRC and industry operating experience that were documented in the licensee's Problem Identification and Resolution program and evaluated the licensee's compliance with their operating experience program, as described in NMP-GM008, "Operating Experience Program," version 24.0, and NMP-AD028, "10 CFR 21 Evaluations and Reporting Requirements," version 7.0.

Self-Assessments and Audits: The inspectors assessed the effectiveness of the licensees identification and correction of problems identified through audits and self-assessments. Specifically, the team reviewed and evaluated condition reports generated as a result of completed self-assessments and/or audits required by the licensee's Quality Assurance Topical Report.

Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.

INSPECTION RESULTS

Assessment 71152B 1) Corrective Action Program Effectiveness Problem Identification: With the exception noted below, the inspectors determined that the licensee was effective in identifying problems and entering them into the problem identification and resolution or corrective action program (CAP) and that there was a low threshold for entering issues into the CAP. This conclusion was based on a review of the requirements for initiating CRs as described in licensee procedure NMP-GM002, "Corrective Action Program," version 16.0, and management's expectation that employees were encouraged to initiate CRs. Additionally, site management was actively involved in the CAP and focused appropriate attention on significant plant issues.

The inspectors reviewed various periodic reviews conducted in accordance with 10 CFR 50.69(e) for SSCs categorized per § 50.69(c). The inspectors noticed that the licensee did not consider (or screened out) failures of risk-informed safety class 3 (RISC3) SSCs on the bases that alternate treatment (i.e., other than maintenance rule - § 50.65) had not been applied to the affected SSCs despite having removed or scope-out the SSCs from the station's maintenance rule program. The inspectors concluded that the licensee was not assessing failures of RISC-3 SSCs, consistent with the § 50.69 Final Rule (FRN 6968008)and their 50.69 program procedure, to determine if adverse SSC performance resulted from the application of a treatment alternate to the maintenance effectiveness treatment requirements of § 50.65. This issue was determined to be a finding with an associated NCV, and it is documented in this report in the inspection results section.

Problem Prioritization and Evaluation: The inspectors reviewed CRs, technical evaluations (TEs), and completed and/or planned work orders (WOs). With the exceptions noted below, the inspectors concluded that problems were generally, prioritized and evaluate in accordance with licensee procedure NMP-GM002001, "Corrective Action Program Instructions," version 45.0. The inspectors determined that adequate consideration was given to SSC's operability and associated plant risk. The inspectors determined that, in general, plant personnel had conducted cause evaluations in accordance with licensee's CAP procedures, as described in NMP-GM002GL03, "Cause Analysis and Corrective Action Guideline," version 33.0, and cause determinations were appropriate, and considered the significance of the issues being evaluated.

The inspectors reviewed the § 50.69 periodic review for the essential chilled water (ECW)system for unit 1 and 2 that was completed on December 19, 2022. The inspectors noticed that two failures of the engineered safety feature (ESF) chillers that occurred during the periodic review monitoring period (November 1, 2019, to September 19, 2022) were not included. The inspectors concluded that the omission could potentially prevent the licensee identifying adverse trends in SSC performance resulting from the treatment adjustments allowed by § 50.69. This issue was determined to be a finding with an associated NCV, and it is documented in this report in the inspection results section.

The inspectors noted that NMP-GM002001, "Corrective Action Program Instructions" is not clear regarding all the conditions that the organization needs to take into consideration, such as technical specifications (TS), risk informed completion time (RICT), when determining whether an equipment reliability checklist (ERC) needs to be performed. This observation is document in this report in the inspection results section.

Corrective Actions: The inspectors reviewed corrective action documents, interviewed licensee staff, and verified completion of corrective actions. With the exceptions noted below, the inspectors determined that, generally, corrective actions were timely, commensurate with the safety significance of the issues, and effective, in that conditions adverse to quality were corrected. The team determined that the licensee was generally effective in developing corrective actions that were appropriately focused. No significant conditions adverse to quality (SCAQ) were identified by the licensee over the 2-year assessment period; therefore, the team focused their review on ensuring that issues entered in the CAP were being properly screened and did not satisfy the criteria for being a SCAQ.

The inspectors reviewed corrective action report (CAR) 280456, "Unit 2 CCW Outboard Bearing Trouble." Inspectors noted that a corrective action (i.e., TE 1097976) initiated to correct a CCW pump maintenance procedure deficiency, as identified in CAR 280456, was closed without a resolution supporting that the required action was completed per CAP procedure NMP-GM002001. The issue was determined to be a minor violation and is documented in this report in the inspection results section.

The inspectors noted that operators do not log CCW pumps' oil levels per recommendations from a 'Large Pump Broadness Review' conducted for a degraded trend associated with oil leaks, oil levels, and/or oiler issues. This observation is documented in this report in the inspection results section.

Following a deficiency involving improperly set variable spring can supports on the nuclear service cooling water (NSCW) system piping, which was discovered by the NRC and documented in inspection report 2023001 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML23114A048), the inspectors noted that a § 50.69(e)feedback and process adjustment review has yet to be conducted by the licensee on the alternative treatment plan for the supports with regards to this issue. This observation is documented in this report in the inspection results section.

Based on the samples reviewed, the team determined that the licensee's CAP complied with regulatory requirements and self-imposed standards. The licensee's implementation of the CAP adequately supported nuclear safety.

2) Operating Experience The team determined that the licensee's processes for the use of industry and NRC operating experience information were effective and complied with regulatory requirements and licensee standards. The implementation of these programs adequately supported nuclear safety. The team concluded that operating experience was adequately evaluated for applicability and that appropriate actions were implemented in accordance with applicable procedures.

3) Self-Assessments and Audits The inspectors reviewed a sample of completed self-assessments and audits conducted by both plant and nuclear oversight personnel. The inspectors determined that the licensee was effective at performing self-assessments and audits to identify issues at a low level, properly evaluated those issues, and resolved them commensurate with their safety significance. The self-assessments and audits were adequately self-critical and performance-related issues were being appropriately identified. The inspectors verified that CRs were created to document areas for improvement and verified that actions had been completed consistent with those recommendations.

4) Safety-Conscious Work Environment The inspectors interviewed a sample of plant employees from various departments with varying roles and responsibilities within the organization. The inspectors determined that employees

(1) were willing to raise nuclear safety concerns to their supervisor and manager or through the CAP,
(2) were aware of alternative avenues for raising concerns such as the Employee Concern Program (ECP), and
(3) had not experienced retaliation for raising safety concerns. Specifically, all individuals interviewed indicated that they feel comfortable in raising safety concerns. All individuals felt that their management was receptive to receiving safety concerns and generally addressed them promptly and commensurate with the significance of the concern. Most interviewees were aware of the licensee's ECP and stated they would use the program, if necessary. When asked whether there have been any instances where individuals experienced retaliation or other negative reaction for raising safety concerns, all individuals interviewed stated that they had neither experienced nor heard of an instance of retaliation at the site. To supplement these discussions, the team reviewed the ECP case log and interviewed the ECP Coordinator to assess their perception of the site employees' willingness to raise nuclear safety concerns. Also, the team reviewed a sample of the most recent Nuclear Safety Culture Leadership Team reports as well as the results from the most recent biennial safety culture survey and self-assessment from July 2022. The team determined that the processes in place to mitigate potential safety culture issues were adequately implemented.

Engineered Safety Features Chillers Performance Data Not Considered During § 50.69 Periodic Review Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.4] - Trending 71152B Systems NCV 05000424,05000425/202301102 Open/Closed An NRC-identified Green non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 50.69(e), Feedback and Process Adjustment - Risk-Informed Safety Class 3 (RISC-3), was identified when the licensee failed to identify and consider failures of the engineered safety feature (ESF) chillers during the periodic review of the essential chilled water (ECW) system as required by licensee procedure.

Description:

On December 19, 2022, the licensee completed a 10 CFR 50.69(e) periodic review of the ECW system for unit 1 and 2. This review looked at the system performance from November 1, 2019, to September 19, 2022, and it was conducted in accordance with licensee procedure NMP-ES065006, Requirements for the Immediate Reviews, Periodic Reviews and Performance Monitoring, version 6.0. The licensee uses this procedure to implement the requirement of 10 CFR 50.69(e) Feedback and Process Adjustment and Performance Monitoring - Risk-Informed Safety Class 3 (RISC-3). The purpose of this review is to identify potential adverse trends in system performance and component performance resulting from the treatment adjustments allowed by § 50.69.

The inspectors read the periodic review for the ECW system and noticed that two failures of the ESF chillers that occurred during the monitoring period were not included. The ESF chillers are RISC3 components and part of the ECW system. Condition report (CR)10691547 documented a failure of the Unit 1 'A' train ESF chiller and unplanned entry into Technical Specifications (TS) 3.7.14, Engineered Safety Features Room Cooler and Safety Related Chiller System, on February 28, 2020. Condition report 10699078 documented another failure of the Unit 1 'B' train ESF chiller and unplanned entry in TS 3.7.14 on March 27, 2020. Section 4.3 Periodic Review of Categorized Systems, Step 5

(b) of NMP-ES065006, requires the licensee to identify failures of RISC-3 systems structures and components (SSC) in the corrective action program as a means to monitor equipment performance change.

Condition report 10983834 was written to address the inspectors observation. The licensee discovered that the search criteria used to identify failures of RISC3 SSCs in the corrective action program (CAP) did not identify the equipment failures of the ESF chillers. These CRs were not found because the CR TYPE field in the CAP database was not populated with EQUIP, which the query utilized to discriminate between equipment related and non-equipment related CRs. The licensee ran the search query again, but this time the CR TYPE was null. The licensee found 31 additional CRs for the ECW system that should have been identified and reviewed during the periodic review. The licensee reviewed the 31 additional CRs and determined that they did not impact the periodic review performed in December 2022. As a result of the inspectors questions, the licensee took corrective actions to revise the search criteria used to identify failures of RISC3 SSCs in the CAP during future § 50.69 periodic reviews. The inspectors concluded that the error in the search criteria could prevent the licensee from identifying adverse trends in system and component performance resulting from the treatment adjustments allowed by § 50.69.

Corrective Actions: The licensee initiated technical evaluation (TE) 1131665 to revise the periodic review template search criteria. The licensee also initiated actions to perform another search of the CAP to identify equipment failures that were not identified during recently completed periodic reviews.

Corrective Action References: CR 10983834, CRs not found during § 50.69 Periodic Review TE 1131665

Performance Assessment:

Performance Deficiency: The failure to identify equipment failures of the ESF chillers during the 10 CFR 50.69 periodic review of the ECW system as required by licensee procedure was a performance deficiency.

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. Specifically, equipment failures documented in the CAP may not be identified and considered during the periodic reviews to determine if there is an adverse impact to the performance of RISC3 SSCs due to the alternative treatment.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding screened to be of very low safety significance (i.e., Green) because the degraded condition did not represent a loss of the PRA function of one or more non-TS trains of equipment designated as risk-significant in accordance with the licensees maintenance rule program for greater than 3 days.

Cross-Cutting Aspect: P.4 - Trending: The organization periodically analyzes information from the CAP and other assessments in the aggregate to identify programmatic and common cause issues. In this case the licensee failed to effectively identify CRs that detailed equipment failures of RISC3 SSCs in the CAP during periodic reviews.

Enforcement:

Violation: 10 CFR 50.69(e)(3) Feedback and Process Adjustment- Risk-Informed Safety Class 3 (RISC3), states the licensee shall consider data collected in § 50.69(d)(2)(i) for RISC-3 SSCs to determine if there are any adverse changes in performance such that the SSC unreliability values approach or exceed the values used in the evaluations conducted to satisfy § 50.69(c)(1)(iv). The licensee shall make adjustments as necessary to the categorization or treatment processes so that the categorization process and results are maintained valid.

The licensee established procedure NMP-ES065006, Requirements for Immediate Reviews, Periodic Reviews, and Performance Monitoring, to provide direction for implementing the requirements of 10 CFR 50.69(e)(3).

Section 4.3 requires identification of failures of RISC3 SSCs in the CAP as a means to monitor equipment performance change.

Contrary to the above, on December 19, 2022, the licensee failed to identify and consider two failures of the ESF chillers documented in the CAP during the periodic review of the ECW system.

Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.

Performance Data for RISC3 Structures, Systems, and Components Scoped-Out of the Maintenance Rule (§ 50.65) not considered during § 50.69 Periodic Reviews Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.8] - 71152B Systems NCV 05000424,05000425/202301103 Procedure Open/Closed Adherence An NRC-identified Green NCV of 10 CFR 50.69(e)(3), Feedback and Process Adjustment-Risk-Informed Safety Class 3 (RISC3), was identified for the licensees failure to assess performance data for RISC3 structures, systems, and components (SSCs) scoped-out of the maintenance rule (§ 50.65) to determine if adverse SSC performance resulted from the application of alternate treatment.

Description:

On December 15, 2022, the licensee completed a § 50.69 periodic review of the radiation monitoring system (RMS) for units 1 and 2 (documented in V2201-PR). The review looked at system performance from February 1, 2021, to September 19, 2022, and it was conducted in accordance with licensee procedure NMP-ES065006, Requirements for the Immediate Reviews, Periodic Reviews and Performance Monitoring, version 6.0. The licensee uses this procedure to implement the requirement of § 50.69(e) Feedback and Process Adjustment - Risk-Informed Safety Class 3 (RISC-3). Step 4.3.5 of the procedure directs performance monitoring of RISC3 SSCs, as required by 10 CFR 50.69(e)(3), to identify adverse trends of RISC3 SSC performance resulting from implementation of alternate treatment as allowed by 10 CFR 50.69. The procedure first requires the licensee to identify failures of RISC3 SSCs, as captured in the CAP. It then requires that the failures be assessed to determine if reduced performance is related to the application of alternate treatment. The inspectors read the periodic review for the RMS and noticed that there were eleven

(11) condition reports associated with failures of RISC3 components. Failures included, in part, radiation monitor isolation valves and main control room air intake radiation gas monitors. The inspectors noted that the licensee did not assess if the failures resulted from the application of alternate treatment on the bases that alternate treatment (i.e., other than maintenance rule - § 50.65) had not been applied to the associated components. The inspectors questioned this conclusion because the RMS system had been removed or scoped-out of maintenance rule in its entirety since September 2017, and therefore the system was under alternate treatment status (i.e., maintenance effectiveness no longer being monitored under § 50.65) and SSC performance monitoring was now driven by the periodic review requirements in § 50.69(e).

Section III.4.4, Section 50.65 Monitoring the Effectiveness of Maintenance, of the § 50.69 Final Rule (FRN 6968008) states that the maintenance rule monitoring, goal setting, corrective action, and periodic evaluation treatments required by § 50.65(a)(1), (a)(2), and (a)(3) are special treatment requirements. It further states that upon implementation of

§ 50.69, the licensee is not required to apply the treatments required by § 50.65(a)(1), (a)(2),and (a)(3) to RISC-3 SSCs. Instead, § 50.69 rule requires the licensee to use SSC performance information to feed back into its processes to adjust treatment when results (i.e.,

unacceptable performance) so indicate during the periodic review of RISC3 performance as required by § 50.69(e)(3). Because RMS system failures identified in the periodic review were incorrectly screened-out or not attributed to alternate treatment, despite the system no longer being monitored under § 50.65, the licensee was not using the available performance data to determine if alternate treatment adjustments were needed. The inspector noted that instructions in the licensees periodic review procedure NMP-ES065006 were consistent with the inspectors interpretation and the FRN. Specifically, step 4.3.5.b.(2)(c) provided a list of questions to consider when determining if alternate treatment had been applied to a component. The third question from the list asked if the component had been scoped-out of the maintenance rule. The licensee did not reach this step in the procedure during the review process because it incorrectly screened-out the failures as not related to alternate treatment in an earlier step in the procedure.

The inspectors extended their review to additional periodic review packages for other systems that were either completely or partially scoped-out of the maintenance rule program.

Specifically, the inspectors reviewed the containment spray system (V2302-PR, 02/28/2023), nuclear service cooling water and component cooling water systems (V2301-PR, 01/25/2023), chemical and volume control system (CVCS) (V2201-PR, 12/15/2022),and the essential chilled water and nuclear instrumentation systems (V2202-PR, 12/19/2022). The inspectors noted that, similarly to the RMS periodic review, the licensee did not consider failures of RISC3 components for the CVCS system from a maintenance rule alternate treatment standpoint (i.e., scoped-out). For the ESF chiller system, the periodic review did not identify any failures of RISC3 components; however, in response to the failures that were not considered, as documented in NCV 202301102 of this report, the licensee indicated, via interviews, that the outcome of the periodic review would not have been affected had the failures been considered because no alternate treatment had been applied to the components in question. For the remaining systems no RISC3 failures were identified and therefore an assessment of alternate treatment effects was not needed.

The inspectors concluded that the licensee was not assessing, consistent with the FRN and program procedure, failures of RISC3 SSCs to determine if adverse SSC performance resulted from the application of a treatment alternate to the maintenance effectiveness treatment requirements of § 50.65.

Corrective Actions: The licensee entered this violation in their corrective action program.

Corrective actions had not been developed by the end of the inspection.

Corrective Action References: CR 10992390

Performance Assessment:

Performance Deficiency: The failure to assess performance data for RISC3 SSCs scoped-out of the maintenance rule (§ 50.65) to determine if adverse SSC performance was a result of the application of an alternate treatment, per § 50.69 (e)(3), was a performance deficiency.

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. Specifically, unreliability of RISC3 SSCs resulting from treatment alternate to the maintenance effectiveness monitoring requirements of § 50.65 (i.e., maintenance rule) could go undetected and invalidate the performance values assumed in the categorization process.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding screened to be of very low safety significance (i.e., Green) because the performance deficiency did not represent a loss of the PRA function of one or more non-TS trains of equipment designated as risk-significant in accordance with the licensees maintenance rule program for greater than 3 days.

Cross-Cutting Aspect: H.8 - Procedure Adherence: Individuals follow processes, procedures, and work instructions. Specifically, the licensee did not use procedure guidance when determining whether alternate treatment had been applied to RISC3 SSCs.

Enforcement:

Violation: 10 CFR 50.69(e)(3) Feedback and Process Adjustment - Risk-Informed Safety Class 3 (RISC3), states that the licensee shall consider data collected in § 50.69(d)(2)(i) for RISC-3 SSCs to determine if there are any adverse changes in performance such that the SSC unreliability values approach or exceed the values used in the evaluations conducted to satisfy § 50.69(c)(1)(iv). The licensee shall make adjustments as necessary to the categorization or treatment processes so that the categorization process and results are maintained valid.

Contrary to the above, in December 2022, the licensee failed to consider data collected in

§ 50.69(d)(2)(i) for RISC3 SSCs during periodic reviews of the RMS, CVCS, and ESF systems to determine if adverse changes in performance necessitated adjustments to the categorization or treatment processes. Specifically, failures of RISC3 SSCs were not assessed to determine if adverse SSC performance resulted from the application of a treatment alternate to the treatment requirements of § 50.65.

Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.

Failure to Implement Maintenance Instructions for Component Cooling Water Pump Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.1] - 71152B Systems NCV 05000425/202301101 Resources Open/Closed A self-revealing Green Finding and associated NCV of Technical Specifications (TS) 5.4.1.a, Procedures, was identified for the licensees failure to follow procedures for the maintenance and post-maintenance testing (PMT) of Unit 2 A train (2A) component cooling water (CCW) pump #1. As a result, the 2A CCW pump #1 was rendered inoperable for approximately 26 days.

Description:

On September 15, 2021, with Unit 2 in Mode 1, main control room operators received a high temperature alarm for the outboard bearing of the 2A CCW pump #1. The pump was stopped and declared inoperable. The pump had been placed inservice approximately 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> before receiving the high temperature alarm as part of a routine pump swap operation. Prior to being placed in service the pump had been in standby since a 2-hour PMT conducted on August 20, 2021, following a replacement of the pumps outboard bearing per work order (WO) SNC1172499. The licensee entered this issue in their corrective action program (CAP) as condition report (CR) 10827428 and investigated the cause of the high bearing temperature.

Inspection of the pump identified that the outboard bearing had failed due to operation below the minimum oil level requirement. The lack of lubrication resulted from the failure to follow CCW maintenance procedure (27080C, Ingresoll Rand Model 10 x18 SE CCW Pump Maintenance, version 27.1) instructions for

(1) assembling the automatic oil bubbler and for
(2) filling the bearing oil reservoir during the August 2021 bearing replacement. In addition, the licensee had an opportunity to identify the insufficient oil condition during the PMT; however, the licensee did not follow the PMT instructions in the maintenance procedure. The following describes, in more detail, the procedural steps the licensee failed to follow with the August 2021 maintenance and restoration activities for the 2A CCW pump #1.

The procedures instructions (Figure 7, Trico Oiler Settings, of 27080C) for installation of the automatic oil bubbler included a note that cautioned not to install or extend the oil feed pipe into the bottom of the oil bubbler housing such that it contacts the level adjuster (flat disc) mechanism. Contact between the oil feed pipe and the disc can block oil flow from the bubbler to the bearing oil reservoir (refer to NRC Information Notice 200119 for additional operating experience information on this failure mechanism). As-found inspection of the oil bubbler determined that this caution was not followed because the feed pipe was found extended too far inside the housing, contacting the level adjuster disc. It is important to note that the CCW pumps are not equipped with independent oil sight glasses; therefore, proper oil level can only be established and verified by proper installation of the automatic oil bubbler.

Procedure step 4.3.12.1, in the main body of the procedure, instructed technicians to fill the bearing oil reservoir per the oil bubbler assembly instructions in Figure 7 at the back of the procedure. Step 4.3.12.1 also referred to the VEGP Lubrication Manual for specifications on the required oil. The lubrication manual specifies the type and amount of oil that is needed for the pump. Figure 7 instructed to repeatedly fill and pour the bubbler into its housing to fill the bearing oil reservoir until no air bubbles appeared in the bubbler (indication that reservoir is full). Asfound inspection noted that the bearing oil reservoir was approximately 4 ounces below the minimum required oil amount. Technicians failed to account or track the amount of oil added to ensure the required amount was supplied. Instead, technicians followed the fill and pour bubbler instructions until no air bubbles were observed. Due to the improper installation of the bubbler, at some point toward the end of the oil filling step, oil stopped flowing from the bubbler to the bearing reservoir giving technicians false indication that the reservoir was full.

Lastly, step 4.6.5 required the PMT to check for bearing excessive heat. The step included a note which stated, to run the pump at equilibrium temperatures for a minimum of four (4)hours. Review of plant computer equipment operating data shows that the 2A CCW pump #1 was ran on August 20, 2021, up until bearing temperatures began to stabilize at the 2-hour mark. It was at this point that the pump should have been ran for another 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> at normal operating temperatures for a total run time of approximately 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Because the high temperature alarm came-in at approximately 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after the pump was started on September 15, 2021, it is likely that the inadequate oil level condition would have been identified if the pump had been tested in accordance with the procedures PMT requirements.

Corrective Actions: The licensee

(1) replaced the failed outboard bearing (WO SNC1178526),
(2) included a discussion of the event and learnings in their technicians continuing training segment,
(3) revised the maintenance procedure to include the required oil amount needed for the bearing reservoir,
(4) developed a new fleet procedure (MNP-MA060, Operation and Installation of Trico Oil Bubbler Systems,) with more explicit guidance on the installation and maintenance of Trico automatic oilers,
(5) added operations support task to CCW pump WOs with directions to perform operability runs per procedure 27080C, and
(6) conducted an extent of condition to verify the condition was not present in the other Units 1 and 2 CCW pump.

Corrective Action References: CR 10827428 and corrective action report (CAR) 280456

Performance Assessment:

Performance Deficiency: The failure to implement maintenance and PMT instructions in accordance with procedure 27080C, Ingresoll Rand Model 10 x18 SE CCW Pump Maintenance, version 27.1, for 2A CCW pump #1 maintenance conducted in August 2021 was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance 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 performance deficiency resulted in inoperability of the 2A CCW pump #1 for approximately 26 days.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Utilizing Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined the finding was of very low safety significance (i.e., Green) because all of the questions in Section A, Mitigating SSCs and PRA Functionality (except Reactivity Control Systems), were answered no. Specifically, operability of the 'A' train of the CCW system was not affected.

Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety. In this case, while maintenance personnel did not follow maintenance procedure, given industry operating experience with the Trico oilers the procedure could have contained clearer guidance to ensure lubrication to the bearings was properly configured.

Enforcement:

Violation: Technical Specifications 5.4.1.a, Procedures requires, in part, that written procedures be implemented covering the applicable procedures recommended in Regulatory Guide (RG) 1.33, Appendix A, February 1978. Section 9.a of Appendix A of RG 1.33 requires, in part, that maintenance which can affect the performance of safety-related equipment should be performed in accordance with written procedures. Procedure 27080C, CCW Pump Maintenance, is a maintenance procedure which can affect the performance the CCW pumps.

Contrary to this, on August 20, 2021, the station failed to implement CCW maintenance procedure 27080C, which affected the performance of the 2A CCW pump #1. Specifically, the licensee failed to

(1) install the pump's outboard bearing oiler,
(2) fill the bearing housing, and
(3) conduct the PMT as required by the maintenance procedure. As a result, the pump was rendered inoperable until the condition was discovered on September 15, 2021.

Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.

Minor Violation 71152B Minor Violation: NRC-identified a Minor Violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action. The minor violation is for the licensee's failure to incorporate a corrective action into the component cooling water (CCW) pumps maintenance procedure, 27080C, "Ingresoll Rand Model 10 x 18 SE CCW Pump Maintenance." Specifically, the licensee's failure to implement a corrective action, technical evaluation (TE) 1097976, to update the CCW maintenance procedure to include the amount of oil required to fill the bearing reservoirs, with a supervision stoppage point if required amount is not added. The corrective action TE was identified as a result of the causal analysis performed for the Unit 2 CCW pump #1 failure due to low oil level on September 15, 2021. Corrective action program (CAP)procedure NMP-GM002001, step 4.7.1 states that CAP TE resolutions must provide adequate detail to support that the assigned action was completed as written. Also, if the action will not be completed as originally written, Attachment 4 was to be followed. TE 1097976 was closed without a resolution supporting that the required action was completed as written and was not revised per CAP procedure instructions. This issue was captured in CR 10981490.

Screening: The inspectors determined that the licensee failed to incorporate a corrective action into the CCW pumps' maintenance procedure was a minor performance deficiency. Specifically, the inspectors determined that the licensee would have identified any issues with the maintenance of the pump during the post maintenance test, in which the pump would have been considered inoperable already due to the maintenance. Therefore, the performance deficiency did not adversely affect a cornerstone objective, would not lead to a more significant safety concern if left uncorrected, and could not reasonably be viewed as a precursor to a significant event.

Enforcement:

This failure to comply with 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.

Observation: NSCW Spring Can / Alternate Treatment Observation 71152B The licensee has adjusted the treatment plan for risk-informed safety class 3 (RISC3) low safety significance seismic supports to an alternative treatment plan in accordance with 10 CFR 50.69. This alternate treatment plan replaces a special treatment plan based on performing in service inspection (ISI) samples on a selection of supports, with a more general area inspection requirement on all supports. A deficiency was discovered by the NRC in November of 2022 with regards to improperly set spring cans on the seismic supports of the nuclear service cooling water (NSCW) system. A feedback and process adjustment review has not yet been conducted by the licensee on the alternative treatment plan for the seismic supports with regards to this issue. This review could impact the alternative treatment plan as the treatment plan may need to be adjusted to address potential loss in detection abilities. The possibility of future failures of a similar nature going undetected should also be considered.

Observation: System operator rounds implementation of a recommendation from 71152B a 2021 broadness review on large pumps related to lubrication issues.

The station implemented a recommendation from a 'Large Pump Broadness Review' (corrective action report (CAR) 279673) conducted for a degraded trend associated with oil leaks, oil levels, and/or oiler issues on large pumps. The review recommended to update the auxiliary building operator rounds procedure (118811/2) to remove subjectivity in which oil levels are logged or recorded (i.e., high, mid, low, etc.) for mitigating system performance index (MSPI) components. It recommended to incorporate, as feasible, a more qualitative means of logging oil levels in order to better trend oil levels. The inspectors noted that the recommendation, as tracked and implemented via technical evaluation (TE) 1093853, was incorporated into a note in the rounds procedure; however, operators continue to log oil levels in the former subjective manner. Implementing this recommendation would aid the station in better trending and combating additional failures related to lack of lubrication.

Observation: NMP-GM002001, "Corrective Action Program Instructions" - 71152B clarification of when an Equipment Reliability Checklist is to be performed.

The inspectors noted that the licensee has had four failures of the unit 1 emergency safety features chillers, since 2020 that have resulted in unplanned entry into technical specification (TS) 3.7.14 Engineered Safety Features Room Cooler and Safety Related Chiller System, Condition A. The required action statement completion time is 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. NMP-GM002001, "Corrective Action Program Instructions" says that an Equipment Reliability Checklist (ERC)is required for equipment failures which result in unplanned entry into a TS shutdown required action statement (RAS) less than or equal to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The licensee indicated that since a risk-informed completion time (RICT) greater than 72-hours was available, an ERC evaluation did not need to be performed. Clarification of NMP-GM002001 of when an ERC is required, based on traditional TS shutdown RAS and/or RICT, would aid the station in properly identifying when to perform an ERC.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On August 4, 2023, the inspectors presented the biennial problem identification and resolution inspection results to Robert Norris, Plant Manager, and other members of the licensee staff.

On June 29, 2023, the inspectors presented the Exit Meeting inspection results to Mr.

Robert Norris, Site Plant Manager, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71152B ALARA Plans NMP-HP204F12 1R24 Vogtle 23-1302 Eddy Current Inspections on Steam Ver. 1.2

Generators 1, 2, 3, and 4

71152B Calibration 43697C Calibration Record for Instrument: VEGP-HP2009 (Ludlum 02/15/2023

Records Model 2000)

71152B Calibration 43697C Calibration Record for Instrument: VEGP-HP2011 (Ludlum 02/21/2023

Records Model 2000)

71152B Calibration 43697C Calibration Record for Instrument: VEGP-HP2010 (Ludlum 02/21/2023

Records Model 2000)

71152B Corrective Action 10878333 Unit 1 Manual Reactor Trip due to loss of 1B MFP 5/3/2022

Documents

71152B Corrective Action 279643 ERC: Component Cooling Water Outboard Bearing Failure 11/04/2021

Documents

71152B Corrective Action 282464 Perform LOE on 1A Safety Injection Pump (SIP) Inoperable 10/4/2021

Documents

71152B Corrective Action 283482 NRC Apparent Violation which is being evaluated for 10/01/2021

Documents escalated enforcement

71152B Corrective Action 303729 O&P Checklist: Unit 2 Btrain NSCW Missed Surveillance 06/06/2022

Documents

71152B Corrective Action 307081 NMP-AD025 Monthly Audit - Training Records Processed 04/29/2022

Documents Beyond 120 days of Final Record Approval.

71152B Corrective Action 327448 Complete a Human Performance Checklist - for the NRC 11/02/2022

Documents Violation: "Failure to Comply with Procedures for Entry into a

High Radiation Area".

71152B Corrective Action CAR 279333 Perform OPC on 50.59 CISA identified - Procedure revision 05/11/2021

Documents do not have procedurally required ADs.

71152B Corrective Action CAR 279672 OPC - Determine Organizational Behaviors around oil leaks 08/24/2021

Documents on Large Pumps.

71152B Corrective Action CAR 280456 ERC and O&P: Unit 2 CCW Outboard Bearing Trouble 12/13/2021

Documents

71152B Corrective Action CAR 284282 Failed to maintain complete and accurate medical

Documents qualification data for SRO.

71152B Corrective Action CAR 284282 Level Evaluation Checklist 01/20/2022

Inspection Type Designation Description or Title Revision or

Procedure Date

Documents

71152B Corrective Action CAR 303476 O&P Checklist: NRC Green NCV for Failure to Perform RP 05/12/2022

Documents Surveys to Evaluate for Alpha Contamination

71152B Corrective Action CAR 308603 O&P Checklist: Control Room Emergency Filtration System 06/30/2022

Documents (CREFS) Carbon Samples not Tracked to Completion

71152B Corrective Action CAR 327409 O&P Checklist: Failure to Comply with Procedures for Entry 01/05/2023

Documents into a High Radiation Area

71152B Corrective Action CAR 360838 Equipment Reliability Checklist (ERC): Failure of Unit 1 02/02/2023

Documents Btrain Reserve Auxiliary Transformer Lightning Arrester

71152B Corrective Action CAR 360838 O&P Checklist (O&P): Failure of Unit 1 Btrain Reserve 02/02/2023

Documents Auxiliary Transformer Lightning Arrester

71152B Corrective Action CAR 420818 NOS Identified: Temporary Procedure Changes not 04/18/2023

Documents processed per NMP-AP001003

71152B Corrective Action Condition Reports 10812516, 10889884, 10902701, 10920952, 10927394,

Documents 10940134, 10943889, 10945074, 10946071,

10960536,10797791, 10813421, 10818886, 10819895,

10839392, 10845917, 10872388,10891645, 10946609,

10959104, 10968891, 10970557, 10803857,10809351,

10832272, 10837239, 10844203, 10863378, 10885555,

10913297, 10938059, 10973327

71152B Corrective Action Condition Reports 865511, 10002377, 10357654, 10668074, 10789942,

Documents (CR) 10790781, 10794193, 10801314, 10804585, 10809759,

10817209, 10818495, 10818886, 10826299, 10826329,

10826666, 10828083, 10833225, 10833653, 10834081,

10834111, 10835036, 10835980, 10836854, 10837094,

10844699, 10846802, 10848695, 10854505, 10864254,

10867100, 10868188, 10868209, 10870082, 10870283,

10871015, 10871387, 10871696, 10872050, 10873544,

10877198, 10883774, 10894283, 10913163, 10914526,

10920230, 10932397, 10944626, 10950967, 10951644,

10955834, 10968096, 10969196, 10983834, 10981490,

10979995, 10979958, 10959527, 10959525, 10959524,

10820887, 10820883,10928266, 10919978, 10957529,

10976303, 10975881, 10806448, 10908305, 10806448,

Inspection Type Designation Description or Title Revision or

Procedure Date

10831842, 10880220, 10956195, 10878333, 10928266,

10919978, 10890881, 50144593, 10868188

71152B Corrective Action Corrective Action 279727, 302968, 304778,314862, 317230, 318566,

Documents Reports (CARs) 360838, 363741

71152B Corrective Action Corrective Action 196054, 278436, 279673, 279727, 302626, 303502,

Documents Reports (CARs) 327004, 322420, 319464, 308151, 302473, 302395,

2395_0, 283943, 308151_0, 319464, 313587, 282464,

279727, 308151, 317729, 319464, 322420, 313587

71152B Corrective Action CR 10847097 Unsealed penetrations in SI pump Rooms

Documents

71152B Corrective Action CR 10848644 System 1561 and 2108 / Door 12108L1B04. Degradation of

Documents the gaskets around door 12108L1B04 which would effect the

doors ability to serve its' function as a barrier for the ESF

equipment room.

71152B Corrective Action Technical 1075098, 1075100, 1075101, 1103343, 1105121, 1105679,

Documents Evaluations 1107999, 1115437, 1116482, 1120600,

71152B Corrective Action Technical 1029197, 1101345, 1124819, 1106312, 945466, 1107999,

Documents Evaluations 1067430

71152B Corrective Action Technical 1131540, 1115171, 1123354, 1123350, 1115171, 1120003,

Documents Evaluations 1128712, 1115684

71152B Corrective Action CR 10979958 NRC Identified Issue - Camera Wire running through a Sub 06/14/2023

Documents Door

Resulting from

Inspection

71152B Corrective Action CR 10979995 Extent of Condition - Camera wire found passing through 06/15/2023

Documents watertight doorway

Resulting from

Inspection

71152B Corrective Action CR 10981490 Procedure 27080C Correction 06/20/2023

Documents

Resulting from

Inspection

71152B Corrective Action CR 10983834 CRs not found during 50.69 Periodic Review 06/28/2023

Documents

Inspection Type Designation Description or Title Revision or

Procedure Date

Resulting from

Inspection

71152B Corrective Action CR 10984204 NRC PI&R inspection observation: TRICO oilers are filled 06/16/2023

Documents >2/3 full

Resulting from

Inspection

71152B Corrective Action CR 10984275 NRC PI&R observation: Operator Rounds - Oil levels not 06/29/2023

Documents recorded with quantitative values

Resulting from

Inspection

71152B Corrective Action CR 10984389 NRC PI&R inspection observation on CEF's and ERC's 06/30/2023

Documents

Resulting from

Inspection

71152B Corrective Action CR 10992390 NRC PI&R 50.69 issue 07/31/2023

Documents

Resulting from

Inspection

71152B Corrective Action TE 1131540 Extent of condition review of ESF Chillers 06/27/2023

Documents

Resulting from

Inspection

71152B Drawings 1X4DB136 Component Cooling Water System No. 1203 Ver. 24.0

71152B Drawings 1X4DB137 Component Cooling Water System No. 1203 Ver. 19.0

71152B Drawings 2X4DB136 Component Cooling Water System No. 1203 Ver. 33.0

71152B Drawings 2X4DB137 Component Cooling Water System No. 1203 Ver. 21.0

71152B Engineering SNC1174713ED Short Form Item Equivalency Evaluation (SIEE): Oiler, 09/09/2021

Changes TRICO - Evaluate replacement for TRICO oiler with wire

guard, with flat base level adjuster, opto-matic #2; capacity:

21/2 oz. (Mfg. part no. 40391)

71152B Engineering Maintenance Rule 1119547

Evaluations Evaluation TEs

71152B Engineering RER Evaluation of Obstructions in Doors 22108L1A78 and 06/20/2023

Evaluations SNC1495628 22108L1D18

Inspection Type Designation Description or Title Revision or

Procedure Date

71152B Engineering SNC1398938 Documentation of Engineering Judgement: Variable Spring 11/4/2022

Evaluations Support Settings

71152B Engineering TE 1057413 MSPI Failure Evaluation for unit 1 CCW pump #2 failing to 01/15/2020

Evaluations auto-start during test

71152B Miscellaneous CNOS-22-208 Fleet-Ops-2022 Audit Package

71152B Miscellaneous CNOS-22-288 Fleet-EA-CHEM-2022 Audit Package

71152B Miscellaneous OR Management Review Committee (MRC) Agenda 06/13/2023

71152B Miscellaneous Management Review Committee (MRC0 Agenda HU MRC 06/13/2023

71152B Miscellaneous MRC Agenda 06/14/2023

71152B Miscellaneous 2X4AF0100137 Instruction Manual Auxiliary Component Cooling Water Ver. 27

Pump

71152B Miscellaneous 701 Employee Concerns Program 11/20/2019

71152B Miscellaneous 730002 Employee Concerns Guideline November

2019

71152B Miscellaneous AX1D94A54 Auxiliary Building Units 1 & 2 Door Schedule Level B Version 1.0

71152B Miscellaneous Crew Learning Internal Operating Experience Crew Learning related to 11/08/2022

Condition Report 10868188: Unanticipated Dose Rate Alarm

71152B Miscellaneous DC1215 Design Basis: Auxiliary Building Drain System- Rev 8

Nonradioactive

71152B Miscellaneous DC1302 Design Basis Document: Auxiliary Feedwater System Rev. 18

71152B Miscellaneous ELV01212 Vogtle Electric Generating Plant Response to Generic Letter 01/25/1990

8913

71152B Miscellaneous MPR Report No. SNC Large Pump and Motor Reliability Improvement Project Rev. 0

220009-

RPT001

71152B Miscellaneous NMD-AD028 10 CFR 21 Evaluations and Reporting Requirements Ver. 7.0

71152B Miscellaneous NMP-AD010F01 10 CFR 50.59 Screening Ver. 10.4

71152B Miscellaneous NMP-AD012 Operability Determinations Version 16.0

71152B Miscellaneous NMP-AD012F01 Operability Determination Support Basis Version 4.1

71152B Miscellaneous NMP-AD025 Quality Assurance and Non-Quality Assurance Records Ver. 14.3

Administration

71152B Miscellaneous NMP-AP001 Development and Control of Southern Nuclear Procedures Ver. 21.2

71152B Miscellaneous NMP-AP001003 Review and Approval of Site Procedures Ver. 16.0

Inspection Type Designation Description or Title Revision or

Procedure Date

71152B Miscellaneous NMP-AP001F09 SNC Temporary Procedure Change Form Ver. 2.0

71152B Miscellaneous NMP- Organizational and Programmatic (O&P) Screening Tool Ver. 8.2

GM002F08

71152B Miscellaneous NMP- Human Performance Checklist Ver. 11.0

GM002F31

71152B Miscellaneous NMP- Work Prioritization Screening Version 4.4

GM006GL11

71152B Miscellaneous NMP-GM008 Operating Experience Program Ver. 24.0

71152B Miscellaneous NMP- Management Review Committee (MRC) Charter Version 15.0

GM016F01

71152B Miscellaneous NOS101 Nuclear Oversight Organization and Responsibilities Version 10.0

71152B Miscellaneous NOS101GL01 Nuclear Oversight Performance Indicator Guideline Version 4.0

71152B Miscellaneous PMCR 91384 Class 2 and 3 Piping and Supports Categorized as RISC3

(LSS) per 10 CFR 50.69

71152B Miscellaneous VMEPP11604 Lesson Plan: Trico Oilers Version 1.0

71152B Miscellaneous VRPJIT2023101 Just-InTime Training DBIG - Alpha Radiation Monitoring/RP Rev. 1.0

71152B Miscellaneous VRPJIT2023101 Alpha Radiation Monitoring / RP - completed for 1R24 on 02/27/2023

71152B Miscellaneous VRPPP2022102 Alpha Radiation Monitoring (Radiation Protection Continuing Ver. 1.0

Training)

71152B Miscellaneous VRPPP2022103 Alpha Radiation Monitoring (Radiation Protection Continuing Ver. 2.0

Training)

71152B NDE Reports S04V2V006 Visual Examination (VT3) of Pipe Variable Spring Support: 04/19/2004

V2 21202006-H028

71152B NDE Reports S05V2V0049 Visual Examination (VT3) of Pipe Variable Spring Support: 09/23/2005

V2 21202006-H054

71152B NDE Reports S13V2V054 Visual Examination (VT3) of Pipe Variable Spring Support: 03/23/2013

V2 21202006-H028

71152B NDE Reports S16V2V069 Visual Examination (VT3) of Pipe Variable Spring Support: 03/32/2016

V2 21202006-H054

71152B NDE Reports S95V2V027 Visual Examination (VT3) of Pipe Variable Spring Support: 02/27/1995

V2 21202006-H028

71152B NDE Reports S96V2V680 Visual Examination (VT3) of Pipe Variable Spring Support: 10/10/1996

V2 21202006-H054

Inspection Type Designation Description or Title Revision or

Procedure Date

71152B Operability Standing Order Unit 1 A/B Train Hydrogen Monitors Non-Functional 05/13/2023

Evaluations 12023-001

71152B Operability Standing Order Unit 2 MSIV A Post Design Change Monitoring 05/05/2022

Evaluations 22022-003

71152B Operability Standing Order EDG Frequency Limit for Safety-Related Equipment 12/21/2021

Evaluations S2016007 Operability

71152B Operability Standing Order Diesel Fire Pump #1 M&TE 10/05/2022

Evaluations S2022017

71152B Procedures 118811 Unit 1 Auxiliary Building Rounds 4/21/2022

71152B Procedures 13744A1 Train A Essential Chilled Water System

71152B Procedures 170141 Annunciator Response Procedures for ALB 14 on Panel 1B! Ver. 18.1

on the MCB

71152B Procedures 170151 Annunciator Response Procedures for ALB 15 on Panel 1B1 Ver. 53.0

on MCB

71152B Procedures 170202 Annunciator Response Procedures for ALB 20 on Panel 2B2 Ver. 53.2

on MCB

71152B Procedures 1705301 Annunciator Response Procedures for ALB 53 on QHVC

Panel

71152B Procedures 27080C Ingersoll Rand Model 10x18 SE CCW Pump Maintenance Versions

27.1, 27.4,

and 27.5

71152B Procedures NMP-ES065 10 CFR 50.69 Program Ver. 5.0

71152B Procedures NMP-ES065004 10 CFR 50.69 Alternative Treatment Requirements Ver. 6.0

71152B Procedures NMP-ES065006 Requirements for Immediate Reviews, Periodic Reviews, Ver. 6.0

and Performance Monitoring

71152B Procedures NMP-ES074006 Fleet Lubrication Instruction

71152B Procedures NMP-GM002 Corrective Action Program Version 16.0

71152B Procedures NMP- Corrective Action Program Instructions Version 45.0

GM002001

71152B Procedures NMP- Corrective Action Program Instructions Version 45.0

GM002001

71152B Procedures NMP- Effectiveness Review Instructions Version 6.0

GM002002

Inspection Type Designation Description or Title Revision or

Procedure Date

71152B Procedures NMP- CAP Training and Qualification Plan Instruction Version 6.1

GM002004

71152B Procedures NMP- Cause Analysis and Corrective Actions Guideline Ver. 33.0

GM002GL03

71152B Procedures NMP-GM003 Self-Assessment and Benchmark Procedure Version 34.0

71152B Procedures NMP- Surveillance Program Version 4.4

GM006002

71152B Procedures NMP-GM024 Nuclear Safety Culture Program Version 9.1

71152B Procedures NMP- Nuclear Safety Culture Monitoring and Review Process Version 12.0

GM024001

71152B Procedures NMP- Nuclear Safety Culture Leadership Team Report Template Version 4.1

GM024F04

71152B Procedures NMP-HP204 ALARA Planning and Job Review Ver. 10.4

71152B Procedures NMP-HP204F02 Radiological Briefing Record Ver. 2.5

71152B Procedures NMP-HP301001 Facility Alpha Characterization Ver. 1.1

71152B Procedures NMP-HP305 Alpha Radiation Monitoring Ver. 5.13

71152B Procedures NMP-MA014001 Post Maintenance Testing Guidance Version 5.9

71152B Procedures NMP-MA014001 Post Maintenance Testing Guidance Version 5.6

71152B Procedures NMP-MA060 Operation and Installation of Trico Oil Bubbler Systems Version 2.0

71152B Procedures NMP-OS007003 Plant Operating Orders Ver. 3.2

71152B Procedures V - 1 - 1302 Auxiliary Feedwater, MRule Function Scoping 5/11/2023

71152B Radiation 253135 Inside Bioshield (2RXC11) 03/21/2022

Surveys

71152B Radiation 260425 Fuel Upender (rev #2) (RXA22) 03/05/2023

Surveys

71152B Radiation 261021 Inside Bioshield Area (1RXC) 03/15/2023

Surveys

71152B Radiation 261089 Inside Bioshield Area (1RXC) 03/16/2023

Surveys

71152B Radiation 261144 Inside Bioshield Area (1RXC) 03/17/2023

Surveys

71152B Self-Assessments Site KPI Report May 2023

71152B Self-Assessments CNOS21146 FLEET-RGA2021 AUDIT PACKAGE 6/16/2021

Inspection Type Designation Description or Title Revision or

Procedure Date

71152B Self-Assessments NMP- Annual Fatigue Management Report 2022

AD016004-F03

71152B Self-Assessments NMP- Annual Fatigue Management Report 2021

AD016004-F03

71152B Self-Assessments NMP- 2022 Plant Vogtle Nuclear Safety Culture Biennial July 2022

GM003F18 Assessment

71152B Self-Assessments NMP- Vogtle NSCM First Period 20231 06/20/2023

GM024F04

71152B Work Orders SNC No. 543477, 846305, 949281, 1095618, 1183954, 1126518,

(completed WOs) 1172499, 1178526, 1183060, 1197303, 1249310, 1313074,

1332866, 1340034, 1418750, 1448175, 1172499

71152B Work Orders SNC No. (planned 1013995, 1165760, 1273501, 1279666, 1289067, 1390713,

WOs) 1449234, 1454429,

25