IR 05000424/2013004
| ML13308C328 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 11/04/2013 |
| From: | Frank Ehrhardt NRC/RGN-II/DRP/RPB2 |
| To: | Tynan T Southern Nuclear Operating Co |
| References | |
| EA-13-162 IR-13-004 | |
| Download: ML13308C328 (31) | |
Text
UNITED STATES mber 4, 2013
SUBJECT:
VOGTLE ELECTRIC GENERATING PLANT - NRC INTEGRATED INSPECTION REPORT 05000424/2013004 AND 05000425/2013004
Dear Mr. Tynan:
On September 30, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Vogtle Electric Generating Plant (VNP), Units 1 and 2. On October 4, 2013, NRC inspectors discussed the results of this inspection with Mr. J. Thomas and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.
No NRC-identified or self-revealing findings were identified during this inspection. However, inspectors documented a licensee-identified violation which was determined to be Severity Level IV in this report. The NRC is treating this violation as a non-cited violation (NCV)
consistent with Section 2.3.2.a of the Enforcement Policy.
Additionally, on October 11, 2012, the NRCs Office of Investigations (OI) initiated an investigation to review the facts and circumstances surrounding a contract employees failure to implement a maintenance procedure involving the independent verification of landing electrical leads during maintenance of a safety-related motor operated valve. Based in part on the investigation, completed on July 2, 2013, the NRC concluded that the actions of the contract employee were willful and caused VNP to be in violation of regulatory requirements. Due to the very low safety significance and VNPs identification of this matter, the NRC concluded that this issue is appropriately characterized at Severity Level IV and documented as a Licensee Identified Violation in Section 4OA7 of the inspection report. This violation was evaluated in accordance with the NRC Enforcement Policy, Section 2.3.2.a. The current Enforcement Policy is included on the NRCs Web site at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRCs Rules of Practice, a copy of this letter, its Enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Frank Ehrhardt, Branch Chief Reactor Projects Branch 2 Division of Reactor Projects Docket Nos.: 05000424, 05000425 License Nos.: NPF-68 and NPF-81
Enclosures:
Inspection Report 05000424/2013004 and 05000425/2013004 w/Attachment: Supplemental Information
REGION II==
Docket Nos.: 50-424, 50-425 License Nos.: NPF-68, NPF-81 Report Nos.: 05000424/2013004 and 05000425/2013004 Licensee: Southern Nuclear Operating Company, Inc. (SNC)
Facility: Vogtle Electric Generating Plant, Units 1 and 2 Location: Waynesboro, GA 30830 Dates: July 1, 2013, through September 30, 2013 Inspectors: M. Cain, Senior Resident Inspector T. Chandler, Resident Inspector R. Baldwin, Senior Operations Examiner (Section 1R11)
M. Donithan, Operations Engineer (Section 1R11)
A. Nielsen, Senior Health Physicist (Section 2RS7)
C. Dykes, Health Physicist (Sections 2RS6, 4OA1)
M. Coursey, Reactor Inspector (Section 4OA5.2)
Approved by: Frank Ehrhardt, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000424/2013-004, 05000425/2013-004; 07/01/2013 - 09/30/2013; Vogtle Electric
Generating Plant, Units 1 and 2; Integrated Inspection Report The report covered a three-month period of inspection by two resident inspectors, two operations examiners and one reactor inspector. No findings were identified during this inspection period. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process revision 4.
Violations of Severity Level IV that were identified by the licensee have been reviewed by the NRC. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. These violations and corrective action tracking numbers are listed in Section 4OA7 of this report.
REPORT DETAILS
Summary of Plant Status
Unit 1 operated at or near full rated thermal power (RTP) for the entire inspection period.
Unit 2 operated at or near full RTP for the entire inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
1R04 Equipment Alignment
a. Inspection Scope
.1 Partial Walkdown
The inspectors verified that critical portions of selected risk significant systems were correctly aligned. The inspectors selected systems for assessment because they were a redundant or backup system/train, were important for mitigating risk for the current plant conditions, had been recently realigned, or were a single-train system. The inspectors determined the correct system lineup by reviewing plant procedures and drawings. The inspectors verified that critical portions of the selected systems were correctly aligned by performing partial walkdowns. Documents reviewed are listed in the Attachment. The inspectors selected the following four systems/trains to inspect:
- Unit 1 train A nuclear service cooling water (NSCW) system while the train B NSCW system pump #6 was out of service during a planned maintenance outage
- Unit 1 train A & B motor-driven auxiliary feedwater systems while the train C turbine-driven auxiliary feedwater pump was out of service for slave relay testing
- Unit 1 train B diesel fuel oil storage tank while the train A tank was isolated for surveillance testing
- Unit 2 train B control room emergency filtration system (CREFS) while the train A CREFS was out of service during a planned maintenance outage
b. Findings
No findings were identified.
1R05 Fire Protection
a. Inspection Scope
.1 Quarterly Inspection
The inspectors evaluated the adequacy of selected fire plans by comparing the fire plans to the defined hazards and defense-in-depth features specified in the fire protection program. In evaluating the fire plans, the inspectors assessed the following items:
1) control of transient combustibles and ignition sources; 2) fire detection systems; 3) water-based fire suppression systems; 4) gaseous fire suppression systems; 5) manual firefighting equipment and capability; 6) passive fire protection features; 7) compensatory measures and fire watches; and 8) issues related to fire protection contained in the licensees corrective action program. The inspectors toured the following five fire areas to assess material condition and operational status of fire protection equipment. Documents reviewed are listed in the Attachment.
- North and south firewater pumphouses, fire zones 530 and 531
- Unit 1 engineered safety features (ESF) chiller and normal air conditioning rooms, fire zones 125A, 126A, 135, 153, 178, 179, and 180
- Unit 1 A train emergency diesel generator (EDG) building and fuel oil storage tank building, fire zones 161 and 163
- Unit 1 A/B Train component cooling water (CCW) heat exchanger rooms, fire zones 54, 55, 148, 23, 172 and 147
- Unit 1 and 2 A train NSCW pump rooms, fire zones 160A/B
b. Findings
No findings were identified.
1R06 Flood Protection Measures
a. Inspection Scope
.1 Underground Cables
The inspectors reviewed related flood analysis documents and inspected the areas listed below that contain cables whose failure could disable risk significant equipment.
The inspector directly observed the condition of cables and cable support structures and, as applicable, verified that dewatering devices and drainage systems were functioning properly. In addition, the inspectors verified the licensee was identifying and properly addressing issues using their corrective action program. Documents reviewed are listed in the Attachment.
- Cable Pull Boxes: 1NE7ADKEM40, 1NE7ADKEM39, 1NE9GHKEPB01
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program
a. Inspection Scope
.1 Resident Inspector Quarterly Review of Licensed Operator Requalification:
The inspectors observed an evaluated simulator scenario administered to an operating crew conducted in accordance with the licensees accredited requalification training program.
The inspectors assessed licensed operator performance, the ability of the licensee to administer the scenario and evaluate the operators, the quality of any post-scenario critique, any follow-up actions taken by the facility licensee, and the performance of the simulator. Documents reviewed are listed in the Attachment.
.2 Resident Inspector Quarterly Review (Licensed Operator Performance):
The inspectors observed licensed operator performance in the main control room on September 16, while routine surveillances were being performed. Inspectors observed licensed operator performance to assess the following:
- Use of plant procedures
- Control board manipulations
- Communications between crew members
- Use and interpretation of instruments, indications and alarms
- Use of human error prevention techniques
- Documentation of activities
- Management and supervision Documents reviewed are listed in the Attachment.
.3 Biennial Review: Licensed Operator Requalification
During the week of September 9, 2013, the inspectors reviewed documentation, interviewed licensee personnel, and observed the administration of simulator operating tests associated with the licensees operator requalification program. Each of the activities performed by the inspectors was done to assess the effectiveness of the licensee in implementing requalification requirements identified in 10 CFR 55, Operators Licenses. The evaluations were performed to determine if the licensee effectively implemented operator requalification guidelines established in NUREG-1021, Operator Licensing Examination Standards for Power Reactors, and Inspection Procedure 71111.11, Licensed Operator Requalification Program. The inspectors reviewed and evaluated the licensees simulation facility for adequacy for use in operator licensing examinations. The inspectors observed three crews during the performance of simulator operating tests. Documentation reviewed included written examinations, Job Performance Measures (JPMs), simulator scenarios, licensee procedures, on-shift records, licensed operator qualification records, selected watch standing and medical records, feedback forms, and remediation plans. The inspectors also reviewed a sample of simulator performance test records (transient tests, malfunction tests, steady state test, and procedure tests), simulator modification request records, and the process for ensuring continued assurance of simulator fidelity to ensure compliance with 10 CFR 55.46 Simulation Facilities. Licensee documents reviewed during the inspection are listed in the attachment.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors assessed the licensees treatment of the two issues listed below in order to verify the licensee appropriately addressed equipment problems within the scope of the Maintenance Rule (MR) (10 CFR 50.65). The inspectors reviewed procedures and records in order to evaluate the licensees identification, assessment, and characterization of the problems as well as their corrective actions for returning the equipment to a satisfactory condition. Documents reviewed are listed in the Attachment.
The inspectors also interviewed system engineers and the maintenance rule coordinator to assess the accuracy of performance deficiencies and extent of condition.
- CR 675427, 1PV-3010, Unit 1, loop 2 atmospheric relief valve fluid leak
- CR 663104, 2PV-3000, Unit 2, loop 1 atmospheric relief valve will not build pressure
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed the five maintenance activities listed below to verify the licensee assessed and managed plant risk as required by 10 CFR 50.65(a)(4) and licensee procedures. The inspectors assessed the adequacy of the licensees risk assessments and implementation of risk management actions. The inspectors also verified that the licensee was identifying and resolving problems with assessing and managing maintenance-related risk using the corrective action program. Additionally, for maintenance resulting from unforeseen situations, the inspectors assessed the effectiveness of the licensees planning and control of emergent work activities.
Documents reviewed are listed in the Attachment.
- Week of 7/22: fuel movements in the Unit 1 spent fuel pool concurrent with construction activities in the cask loading pit
- Week of 7/29: unplanned inoperability of the normal boration flow path on Unit 2
- Week of 8/26: high-risk work being performed in the high-voltage switchyard concurrent with unplanned inoperability of the Unit 2 train C 125 volt battery
- Week of 9/9: monthly surveillance test of the 1B EDG concurrent with NSCW pump #3 being out of service and high-risk work being performed in the high-voltage switchyard
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors selected the six operability determinations or functionality evaluations listed below for review based on the risk-significance of the associated components and systems. The inspectors reviewed the technical adequacy of the determinations to ensure that technical specification operability was properly justified and the components or systems remained capable of performing their design functions. To verify whether components or systems were operable, the inspectors compared the operability and design criteria in the appropriate sections of the technical specification and updated final safety analysis report to the licensees evaluations. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. Additionally, the inspectors reviewed a sample of corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with operability evaluations.
Documents reviewed are listed in the Attachment.
- CR 675692, Void detected at 1-1204-X4-040/041, Unit 1 A train safety injection pump discharge header vent valve
- CR 662375, Engineering systems walkdown CR (Haskell air pump on 1HV3016A cycling continuously)
- CR 687358, EDG 1B governor wax seals cracked
- CR 694831, Found inter-cell and inter-tier cable loose on 2CD1B battery
- CR 655018, Leakage observed at safety injection pump discharge relief valve
b. Findings
No findings were identified.
1R18 Plant Modifications
a. Inspection Scope
The inspectors verified that the plant modification listed below did not affect the safety functions of important safety systems. The inspectors confirmed the modification did not degrade the design bases, licensing bases and performance capability of risk significant structures, systems and components. Additionally, the inspectors evaluated whether system operability and availability, configuration control, post-installation test activities, and changes to documents, such as drawings, procedures, and operator training materials, complied with licensee standards and NRC requirements. In addition, the inspectors reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with modifications.
Documents reviewed are listed in the attachment.
- VTE438151, Licensing Document Change Request for Vogtle Electric Generating Plant Emergency Plan
b. Findings
No findings were identified.
1R19 Post Maintenance Testing
a. Inspection Scope
The inspectors either observed post-maintenance testing or reviewed the test results for the six maintenance activities listed below to verify the work performed was completed correctly and the test activities were adequate to verify system operability and functional capability. The inspectors evaluated these activities for the following: acceptance criteria were clear and demonstrated operational readiness; effects of testing on the plant were adequately addressed; test instrumentation was appropriate; tests were performed in accordance with approved procedures; equipment was returned to its operational status following testing; and test documentation was properly evaluated.
Additionally, the inspectors reviewed a sample of corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with post-maintenance testing. Documents reviewed are listed in the Attachment.
- Maintenance Work Order (MWO) SNC137703 - 2B ESF chilled water -
calibrate/replace DL1, DL2, DL3, DL4 Agastat relays
- MWO SNC134996 - 1B NSCW pump 6 - Calibrate/Replace Agastat Relays
- 1B ESF Chiller outage: MWO SNC123599 - 1-1592-P7-002-M01 ESF CH WTR PMP MTR - Calibrate/replace Agastat relays, MWO SNC409950 - 1-1592-C7-002-000 ESF Chiller - Calibrate/replace Agastat relays, and MWO SNC409948 - 1-1592-C7-002-M01 ESF Chiller compressor motor - Calibrate/replace Agastat relays
- MWO SNC433073 - 18 month test of train B diesel generator fuel oil transfer cross train flowpath
- MWO SNC414680 - Unit 2 diesel fuel oil storage tank transfer pump #1 clean/inspect/lubricate
- MWO SNC517112 - Unit 2 train C 125 volt battery loose connection
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors reviewed the five surveillance tests listed below and either observed the test or reviewed test results to verify testing adequately demonstrated equipment operability and met technical specification and licensee procedural requirements. The inspectors evaluated the test activities to assess for preconditioning of equipment, procedure adherence, and equipment alignment following completion of the surveillance.
Additionally, the inspectors reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with surveillance testing. Documents reviewed are listed in the Attachment.
Routine Surveillance Tests
- 24614-1 Rev. 37, Safety Features Sequencer Train B Channel Operational Test and Channel Calibration
- 14875-1 Rev. 97.2, Quarterly Inservice Valve Test
- 14622-2 Rev. 13, SSPS Slave Relay K615 Train A Test Safety Injection
- 24403-2 Rev. 10.2, Delta T - Auctioneer and Deviation Alarm 2T-411 Channel Calibration In-Service Tests (IST)
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation
a. Inspection Scope
The inspectors observed the emergency preparedness drill conducted on August 6, 2013. The inspectors observed licensee activities in the simulator and/or technical support center to evaluate implementation of the emergency plan, including event classification, notification, and protective action recommendations. The inspectors evaluated the licensees performance against inspection criteria established in the licensees procedures. Additionally, the inspectors attended the post-exercise critique to assess the licensees effectiveness in identifying emergency preparedness weaknesses and verified the identified weaknesses were entered in the corrective action program.
Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
RADIATION SAFETY
(RS)
Cornerstones: Occupational Radiation Safety (OS) and Public Radiation Safety (PS)
2RS6 Radioactive Gaseous and Liquid Effluent Treatment
a. Inspection Scope
Event and Effluent Program Reviews The inspectors reviewed the 2011 and 2012 Annual Radioactive Effluent Release Report documents for consistency with requirements in the Offsite Dose Calculation Manual (ODCM) and technical specifications (TS). Inspectors reviewed the few changes to the ODCM. Routine and abnormal effluent release results and reports, as applicable, were reviewed and discussed with responsible licensee representatives.
Radioactive Waste Treatment Systems The inspectors walked-down the gaseous and liquid radioactive waste (radwaste) processing and discharge systems for material condition and configuration. To the extent practical, the inspectors observed and evaluated the material condition of in-place waste processing equipment for indications of degradation or leakage that could constitute a possible release pathway to the environment. Inspected components included ventilation filtration systems, steam generator blowdown skid, laundry tank, waste evaporator condensate tanks, and associated piping and valves. The inspectors interviewed licensee staff regarding radwaste equipment configuration and effluent monitor operation. The inspectors also reviewed surveillance testing records for containment building ventilation filtration systems.
Effluent Processing There were no collection samples available for the inspectors to observe. The inspectors observed the steps a technician would perform in collecting and analyzing liquid and gaseous samples. The inspectors discussed liquid and gaseous effluent discharge pathways and operability of the effluent radiation monitors with plant personnel. The inspectors reviewed gaseous and liquid release permits, effluent monitor setpoints, and public dose calculations. The reviews included evaluation and discussion of selected dose calculation summaries. Release quantities and dose impacts were reviewed and discussed. Inspectors reviewed 10 CFR 61 analysis data. The inspectors reviewed the calculated public dose results for any indications of higher than anticipated or abnormal releases. The inspectors also reviewed compensatory sampling data for time periods when selected radiation monitors were out of service. The inspectors reviewed the results of the radiochemistry cross-check program for 2011 and 2012 to evaluate the quality of the radioactive effluent sample analyses. Recent land use census results and meteorological data used to calculate doses to the public were evaluated as part of inspection procedure 71124.07.
Ground Water Protection The inspectors discussed groundwater monitoring program implementation and recent program changes with licensee staff. The inspectors reviewed the current groundwater sample results and contents of the 50.75(g)decommissioning file. The inspectors reviewed and discussed the licensees program for monitoring of structures, systems, and components with the potential to release radioactive material to the environment, including selected portions of the liquid radwaste system. Potential effluent release points due to onsite surface water bodies were also evaluated.
Problem Identification and Resolution The inspectors reviewed selected corrective action program (CAP) documents in the areas of gaseous and liquid effluent processing and release activities. The inspectors evaluated the licensees ability to identify, characterize, prioritize, and resolve the identified issues in accordance with licensee procedures. The inspectors also discussed the scope of the licensees internal audit program and reviewed recent assessment results.
Effluent process and monitoring activities were evaluated against details and requirements documented in final safety analysis report (FSAR) Section 11; ODCM; TS 5.6.3 (Annual Radioactive Release Report),10 CFR Part 20; Appendix I to 10 CFR Part 50; and approved licensee procedures. In addition, ODCM and FSAR changes since the last onsite inspection were reviewed against the guidance in NUREG-1301 and Regulatory Guides (RG)s 1.109, RG 1.21, and RG 4.1. Records reviewed are listed in the attachment to this report.
b. Findings
No findings were identified.
2RS7 Radiological Environmental Monitoring Program (REMP)
a. Inspection Scope
REMP Implementation The inspectors observed routine sample collection and surveillance activities as required by the licensees environmental monitoring program.
The inspectors noted the material condition and operability of airborne particulate filter and iodine cartridge sample stations and observed collection of weekly air samples at selected monitoring locations. The inspectors checked environmental dosimeters for material condition at selected sites. The inspectors also observed the collection of milk samples at two locations. In addition, the inspectors reviewed and evaluated land use census results, changes to the ODCM, monitoring for hard-to-detect radionuclides, and sample collection/processing activities.
The inspectors observed the calibration of environmental air samplers in the field and reviewed the last two calibration records for selected air samplers. The inspectors also reviewed the 2011 and 2012 Radiological Environmental Operating Reports, the 2012 Annual Radioactive Effluent Report, results of the 2011 and 2012 interlaboratory cross-check program for the Georgia Power Environmental Laboratory, and procedural guidance for environmental sample collection and processing. Selected environmental measurements were reviewed for consistency with licensee effluent data, evaluated for radionuclide concentration trends, and compared with detection level sensitivity requirements. The inspectors reviewed the licensees groundwater monitoring program as part of Inspection Procedure 71124.06.
Meteorological Monitoring Program The inspectors observed the physical condition of the primary meteorological tower and its instrumentation and discussed equipment operability and maintenance history with licensee staff. The inspectors evaluated transmission of locally generated meteorological data to other licensee groups such as main control room operators. For the meteorological measurements of wind speed, wind direction, and temperature, the inspectors reviewed the last two calibration records for applicable tower instrumentation. The inspectors also evaluated measurement data recovery for 2011 - 2012 and 2013 to date.
Problem Identification and Resolution The inspectors reviewed CAP documents in the areas of radiological environmental monitoring and meteorological tower maintenance.
The inspectors evaluated the licensees ability to identify and resolve the issues in accordance with licensee procedures. The inspectors also reviewed recent self-assessment results.
REMP implementation and meteorological monitoring activities were reviewed against the guidance and requirements of 10 CFR Part 20; Appendices E and I to 10 CFR Part 50; TS Section 5; FSAR Chapter 2; ODCM; NUREG-1301, Offsite Dose Calculation Manual Guidance: Standard Radiological Effluent Controls for Pressurized Water Reactors; RG 4.15, Quality Assurance for Radiological Monitoring Programs (Normal Operation) - Effluent Streams and the Environment; Safety Guide 23, Onsite Meterological Programs; Branch Technical Position, An Acceptable Radiological Environmental Monitoring Program - 1979; and approved licensee procedures.
Documents reviewed are listed in the report Attachment.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
a. Inspection Scope
The inspectors reviewed a sample of the performance indicator (PI) data, submitted by the licensee, for the PIs listed below. To verify the accuracy and completeness of the data reported for the station, the inspectors reviewed plant records compiled between July 1, 2012, and June 30, 2013, for both Unit 1 and Unit 2. The inspections verified that the PI data complied with guidance contained in NEI 99-02, Regulatory Assessment Indicator Guideline, and licensee procedures. The inspectors also confirmed the PIs were calculated correctly. In addition, the inspectors reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with PI data. Documents reviewed are listed in the Attachment.
Cornerstone: Mitigating Systems
- Heat Removal System
- High Pressure Injection System
- Residual Heat Removal System
Cornerstone: Public Radiation Safety
The inspectors reviewed the Radiological Control Effluent Release Occurrences PI results for the Public Radiation Safety Cornerstone from October 2012 through August 2013. For the assessment period, the inspectors reviewed cumulative and projected doses to the public contained in liquid and gaseous release permits and condition reports related to Radiological Effluent Technical Specifications/ODCM issues. The inspectors also reviewed licensee procedural guidance for collecting and documenting PI data. Documents reviewed are listed in the report Attachment.
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
a. Inspection Scope
.1 Routine Review
The inspectors performed a daily screening of items entered into the licensees corrective action program in order to identify repetitive equipment failures or specific human performance issues for follow-up. The inspectors reviewed daily condition reports, attended screening meetings, or accessed the licensees computerized corrective action database.
.2 Annual Follow-up of Selected Issues
The inspectors selected condition reports 684914 - Failed Drill Exercise Performance Opportunity and corrective action report (CAR) 207025 - Long standing performance issues of the RCP number 1 seals, for detailed review. The inspectors evaluated the following attributes of the licensees actions:
- complete and accurate identification of the problem in a timely manner
- evaluation and disposition of operability/reportability issues
- consideration of extent of condition, generic implications, common cause, and previous occurrences
- classification and prioritization of the problem
- identification of root and contributing causes of the problem
- identification of any additional condition reports
- completion of corrective actions in a timely manner Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
4OA3 Follow-up of Events and Notices of Enforcement Discretion
a. Inspection Scope
.1 (Closed) Licensee Event Report 05000425/2013-001: Manual Reactor Trip due to High
Reactor Coolant Pump Seal Leakoff Flow On February 26, 2013, at approximately 2302 Eastern Daylight Time (EDT) time, with Unit 2 operating in Mode 1 at 94 percent rated thermal power and end of life (EOL)coastdown in progress, Unit 2 operators initiated a manual reactor trip due to reactor coolant pump (RCP) #4 number one seal leakoff flow exceeding the operating limits.
The reactor trip system, the engineered safety feature actuation system, and other responding equipment performed as expected. The plant was stabilized in Mode 3. The cause of the event was the addition of air into the chemical volume control system (CVCS) charging system as a result of less than adequate filling and venting of the reactor coolant system filter. The inspectors reviewed the LER, the associated condition report and root cause determination, and subsequent action items. The enforcement aspects associated with this event were documented in NRC integrated inspection report 05000424,425/2013002 (Section 1R11). No other findings were identified. This LER is closed.
b. Findings
No findings were identified.
4OA5 Other Activities
.1 Quarterly Resident Inspector Observations of Security Personnel and Activities
a. Inspection Scope
During the inspection period, the inspectors conducted observations of security force personnel and activities to ensure that the activities were consistent with licensee security procedures and regulatory requirements relating to nuclear plant security.
These observations took place during both normal and off-normal plant working hours.
These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors normal plant status review and inspection activities.
b. Findings
No findings were identified.
.2 Temporary Instruction (TI)-2515/182 - Review of the Industry Initiative to Control
Degradation of Underground Piping and Tanks
a. Inspection Scope
Leakage from buried and underground pipes has resulted in ground water contamination incidents with associated heightened NRC and public interest. The industry issued a guidance document, Nuclear Energy Institute (NEI) 09-14, Guideline for the Management of Buried Piping Integrity (ADAMS Accession No. ML1030901420) to describe the goals and required actions (commitments made by the licensee) resulting from this underground piping and tank initiative. On December 31, 2010, NEI issued Revision 1 to NEI 09-14, Guidance for the Management of Underground Piping and Tank Integrity, (ADAMS Accession No. ML110700122), with an expanded scope of components which included underground piping that was not in direct contact with the soil and underground tanks. On November 17, 2011, the NRC issued TI-2515/182 Review of the Industry Initiative to Control Degradation of Underground Piping and Tanks to gather information related to the industrys implementation of this initiative.
From September 09 - 11, 2013, the inspectors conducted a review of records and procedures related to the licensees program for buried pipe, underground pipe and tanks in accordance with Phase II of TI-2515/182. This review was done to confirm that the licensees program contained attributes consistent with Sections 3.3.A and 3.3.B of NEI 09-14 and to confirm that these attributes were scheduled and/or completed by the NEI 09-14 Revision 3 deadlines. To determine if the program attribute was accomplished in a manner which reflected good or poor practices in program management, the inspectors interviewed licensee staff responsible for the buried pipe program and reviewed buried pipe program related activities.
The licensees buried piping and underground piping and tanks program was inspected in accordance with Paragraph 03.02.a of the TI and to confirm that activities which correspond to completion dates specified in the program which have passed since the Phase I inspections were conducted and are complete. Additionally, the licensees Buried Piping and Underground Piping and Tanks Program was inspected in accordance with Paragraph 03.02.b of the TI and responses to specific questions found in http://www.nrc.gov/reactors/operating/ops-experience/buried-pipe-ti-phase-2-insp-req-2011-11-16.pdf, were submitted to the NRC Headquarters staff.
Based upon the scope of the review described above, Phase II of TI-2515/182 was completed.
b. Findings
No findings were identified.
4OA6 Meetings, Including Exit
a. Exit Meeting On October 4th, the resident inspectors presented the inspection results to Mr. J.
Thomas and other members of plant staff. The inspectors confirmed that proprietary information was not provided or examined during the inspection.
4OA7 Licensee-Identified Violation
The following violations of Severity Level IV were identified by the licensee and are violations of NRC requirements, which met the criteria of the NRC Enforcement Policy, for being dispositioned as non-cited violations.
- On October 11, 2012, the NRCs Office of Investigations (OI) initiated an investigation to review whether a contract employee willfully failed to implement a maintenance procedure involving the independent verification of landing electrical leads during maintenance of a safety-related Motor Operated Valve. Based in part on the investigation, completed on July 2, 2013, the NRC concluded that the actions of the contract employee were willful, and his actions caused VNP to be in violation of regulatory requirements. This issue was identified by the licensee.
Technical Specification 5.4, Procedures, requires that written procedures, specified in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978, shall be established, implemented, and maintained. Section 9.a of Regulatory Guide 1.33, Appendix A, requires that maintenance that can affect the performance of safety-related equipment should be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. Licensee procedure NMP-ES-017-004, MOV Diagnostic Procedure for Gate and Globe Valves, provides instructions for maintenance of safety-related motor operated valve 1HV8105. Step 6.10.3 of the procedure provides instructions to re-connect control wiring per the Data Sheet. Per the Data Sheet the lead (LS-16) from point 39 needed to be re-landed and independently verified.
Contrary to the above, on September 26, 2012, a contract laborer from Crane Nuclear willfully failed to independently verify that lead LS-16 was correctly landed per procedure NMP-ES-017-004. Specifically, the contract laborer failed to conduct an independent verification but signed-off the data sheet stating that he had verified the landing of leads for MOV 1HV8105.
The inspectors determined that the underlying technical significance of the failure to perform an independent verification on landing a wire from a control switch of a safety-related MOV was a minor violation. However, based on an assessment of the factors described in Section 2.2.1.d of the Enforcement Policy, this violation is disposition as a non-cited violation. The licensee entered this issue into its corrective action program as CR 524641.
- The licensee identified a violation of Title 10 CFR 50.74, Notification of change in operator or senior operator duties, for the failure of the facility licensee to notify the Commission of changes in the medical status of numerous licensed operators within 30 days of learning of the medical change, as required. Contrary to the above, from November 2012 to July 2013, the licensee failed to provide the Commission the necessary medical information to insure licensed operators met the requirements of 10 CFR 55.33, Disposition of Initial Application. The licensee entered this violation into their corrective action program as CR 207318. The finding was determined to be of very low safety significance because the individual operators were found to have been physically capable of meeting the requirements as required, as well as, being in the presence of other medically qualified operators. This violation was characterized as a Severity Level IV non-cited violation, consistent with Example 6.4.d.1(c) of the Enforcement Policy.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- R. Barringer, Security Manager
- R. Brown, Training Manager
- N. Carter, Buried Piping Program Owner
- R. Collins, Chemistry Manager
- G. Gunn, Licensing
- M. Johnson, Health Physics Manager
- F. Pournia, Engineering Director
- J. Robinson, Engineering Programs Manager
- G. Saxon, Plant Manager
- J. Thomas, Operations Director
- T. Thompson, Systems Engineering Manager
- T. Tynan, Site Vice-President
- K. Walden, Licensing Engineer
NRC personnel
- M. Cain, Senior Resident Inspector
- T. Chandler, Resident Inspector
- F. Ehrhardt, Chief, Region II Reactor Projects Branch 2
LIST OF ITEMS
OPENED AND CLOSED OPEN AND CLOSED None OPENED None CLOSED
- 05000425/2013-001 LER Manual Reactor Trip due to High RCP Seal Leakoff Flow (Section 4OA3.1)
2515/182 TI Review of the Industry Initiative to Control Degradation of Underground Piping and Tanks (Phase II) (Section 4OA5.2)