IR 05000424/2019003

Integrated Inspection Report 05000424/2019003, 05000425/2019003 and 07201039/2019003 and Apparent Violation

ML19318E978
Person / Time
Site:	Vogtle, 07201039
Issue date:	11/14/2019
From:	Alan Blamey Division Reactor Projects II
To:	Gayheart C Southern Nuclear Operating Co
Reeder D
References
EA-19-112 IR 2019003
Download: ML19318E978 (23)

Text

{{#Wiki_filter:ber 14, 2019

SUBJECT:

VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 & 2 - INTEGRATED INSPECTION REPORT 05000424/2019003, 05000425/2019003 AND 07201039/2019003 AND APPARENT VIOLATION

Dear Ms. Gayheart:

On September 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Vogtle Electric Generating Plant. On October 16, 2019, the NRC inspectors discussed the results of this inspection with Mr. Keith Taber and other members of your staff.

The results of this inspection are documented in the enclosed report.

The enclosed report discusses a finding for which the NRC has not yet reached a preliminary significance determination. This finding involved the failure to accurately calibrate containment high range area radiation monitors 1RE-0005, 1RE-0006, 2RE-0005, and 2RE-0006.

We intend to issue our final safety significance determination, in writing, within 90 days from the date of this inspection report. The NRCs significance determination process is designed to encourage an open dialogue between your staff and the NRC; however, neither the dialogue nor the written information you provide should affect the timeliness of our final determination. We ask that you promptly provide any relevant information that you would like us to consider in making our determination. We are currently evaluating the significance of this finding and will notify you in a separate correspondence once we have completed our preliminary significance review. You will be given an opportunity to provide additional information prior to our final significance determination unless our review concludes that the finding has very low safety significance (i.e., Green).

If you contest the violation or significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at Vogtle. 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.

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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, /RA/ Alan J. Blamey, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket Nos. 05000424, 05000425 and 07201039 License Nos. NPF-68 and NPF-81

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000424 and 05000425 License Numbers: NPF-68 and NPF-81 Report Numbers: 05000424/2019003, 05000425/2019003 and 07201039/2019003 Enterprise Identifier: I-2019-003-0031 and I-2019-003-0079 Licensee: Southern Nuclear Operating Co., Inc.

Facility: Vogtle Electric Generating Plant Location: Waynesboro, GA Inspection Dates: July 1, 2019 to September 30, 2019 Inspectors: M. Donithan, Operations Engineer M. Endress, Senior Resident Inspector D. Lanyi, Senior Operations Engineer A. Nielsen, Senior Health Physicist W. Pursley, Health Physicist C. Safouri, Resident Inspector Approved By: Alan J. Blamey, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Vogtle Electric Generating Plant 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 Failure to Calibrate Containment High-range Area Radiation Monitors Cornerstone Significance Cross-Cutting Report Aspect Section Emergency Pending [H.1] - 71124.05 Preparedness AV 05000424,05000425/2019003-01 Resources Open EA-19-112 The inspectors identified an Apparent Violation (AV) of Technical Specification (TS) 3.3.3, for the failure to correctly calibrate the Vogtle Unit 1 (U1) and Unit 2 (U2) containment high-range area radiation monitors 1RE-0005, 1RE-0006, 2RE-0005, and 2RE-0006. Specifically, the source-to-detector geometry used for isotopic calibrations was not fixed and reproducible which resulted in radiation monitor indications in the main control room that were biased high. These radiation monitors are relied upon during an accident to provide release assessment for use by plant operators in determining the need to invoke site emergency plans.

Additional Tracking Items Type Issue Number Title Report Section Status URI 05000424,05000425/20 Calibration Surveillance 71111.22 Closed 18004-03 Extension of Post Accident Monitoring Instruments URI 05000425,05000424/20 Calibration of Containment 71124.05 Closed 18004-02 High-range Area Radiation Monitors LER 05000424/2018-002-00 LER 2018-002-00 for Vogtle, 71153 Closed Unit 1, Manual Reactor Trip due to Receiving Rod Control Urgent Failure Alarm during Low Power Physics Testing.

PLANT STATUS

Unit 1 began the inspection period at rated thermal power and remained at or near rated thermal power for the entire inspection period.

Unit 2 began the inspection period at rated thermal power. On July 19, 2019, Unit 2 tripped due to the inadvertent closure of the Loop 2 B Train Main Steam Isolation Valve (MSIV). Unit 2 returned to rated thermal power on July 25, 2019 and remained at or near rated thermal power for the rest of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

71111.01 - Adverse Weather Protection Impending Severe Weather Sample (IP Section 03.03)

(1) The inspectors evaluated readiness for impending adverse weather conditions for Hurricane Dorian on September 3-4, 2019.

71111.04Q - Equipment Alignment Partial Walkdown Sample (IP Section 03.01)

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

(1) 1A Emergency Diesel Generator (EDG) while 1B EDG was inoperable due to a failed fuel injection pump on August 6, 2019.

(2) 1A Nuclear Service Cooling Water (NSCW) while 1B NSCW Pump #2 was out of service on August 12, 2019.

(3) 1B Component Cooling Water (CCW) system while 1A CCW room cooler was out of service on September 16, 2019.

(4) 2B Centrifugal Charging Pump (CCP) system during 2A CCP testing on September 19, 2019.

71111.05Q - Fire Protection Quarterly Inspection (IP Section 03.01)

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) 2A/2B Auxiliary Component Cooling Water (ACCW) pump rooms, Safety Injection (SI)pump rooms, and Auxiliary Building Level 'B' Penetration Area, Zone 30/33/31/32/26B, on July 26, 2019.

(2) Unit 1 Auxiliary Feedwater (AFW) pump house, Zone 155/156/157A/157B, on August 23, 2019.

(3) 1A/1B ACCW heat exchanger rooms, Zone 49/52, on September 12, 2019.

(4) 1A/1B ACCW pump rooms, SI pump rooms, and Auxiliary Building Level 'B' Penetration Area, Zone 30/31/32/33/26B, on September 12, 2019.

71111.06 - Flood Protection Measures Inspection Activities - Underground Cables (IP Section 02.02c.)

The inspectors evaluated cable submergence protection in:

(1) 1NE96HKEPB01, 1NE7ADKEM39, 1NE7ADKEM40 on July 17, 2019.

71111.07A - Heat Sink Performance Annual Review (IP Section 02.01)

The inspectors evaluated readiness and performance of:

(1) 1A EDG jacket water heat exchanger.

71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance Licensed Operator Requalification Program (IP Section 03.04)

The inspectors completed an inspection to verify the licensees ability to evaluate the performance of their licensed operators during the conduct of examinations, to assess their ability to properly develop and administer requalification annual operating tests and biennial written examinations, to evaluate the performance of the control room simulator and their testing and maintenance of the simulator, to ensure that licensed individuals satisfy the conditions of their licenses, and to assess their effectiveness in ensuring that operator license conditions are satisfied.

(1) Biennial Requalification Written Examinations The inspectors evaluated the quality of the licensed operator biennial requalification written examination administered on November 21, 2018.

Annual Requalification Operating Tests The inspectors evaluated the adequacy of the facility licensees annual requalification operating test.

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

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

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

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

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

Problem Identification and Resolution The inspectors evaluated the licensees ability to identify and resolve problems associated with licensed operator performance.

==71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the Control Room during a Unit 2 Steam Generator Loop 3 Level Control Channel Calibration and 2A EDG operability test on August 5, 2019 and September 23, 2019, respectively.

Licensed Operator Requalification Training/Examinations (IP Section 03.02)==

(1) The inspectors observed and evaluated simulator training of a Loss of Coolant Accident (LOCA) causing a Reactor Trip concurrent with a Pressurizer instrumentation failure on August 13, 2019.

71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness Inspection (IP Section 02.01)

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) 1A NSCW Fan #2 Trip Maintenance Preventable Functional Failure (MPFF), CR

===10546756, October 18, 2018.

(2) Unit 1 and 2, System 1301S Main Steam, MSIV Plant Level Events, CR 10604001, April 23, 2019.

(3) Unit 1 and 2, System 1208 Chemical Volume and Control System (CVCS)maintenance rule re-evaluation, CR 10591187, March 13, 2019.

71111.13 - Maintenance Risk Assessments and Emergent Work Control Risk Assessment and Management Sample (IP Section 03.01)

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) 1B EDG fuel injection pump emergent issue on August 5, 2019.

(2) 1B Engineered Safety Feature (ESF) Chiller preventative maintenance (PM) outage and usage of Risk-Informed Completion Time (RICT) on August 14-15, 2019.

(3) 1A NSCW Pump #5 system outage on August 26, 2019.

(4) 2B NSCW Pump #4 system outage on September 10, 2019.

71111.15 - Operability Determinations and Functionality Assessments Operability Determination or Functionality Assessment (IP Section 02.02)

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Unit 2 CVCS Normal Charging Pump motor inboard bearing oil quality declining trend on July 12, 2019, CR 10628119.

(2) 2A EDG voltage drop during surveillance testing on August 1, 2019, CR 10632909.

(3) 1B EDG following repairs of issues impacting the fuel injection pump on August 6, 2019, CR 10635016/10634731.

(4) 1A EDG abnormal noise during 24 hour endurance test on August 20, 2019, CR 10639026.

(5) 2A EDG air receiver #2 excess water on September 17, 2019, CR 10646135.

==71111.18 - Plant Modifications Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples) The inspectors evaluated the following temporary or permanent modifications:

(1) 50.59 modification package for the Accident Tolerant Fuel Lead Test Assemblies (LTAs) that were installed in Unit 2 during the 2019 refueling outage; the inspectors reviewed the composition of the limited number of LTAs, placement of LTA in non-limiting core locations and Technical Specification (TS) 5.6.5, Core Operating Limits Reports, including the analytical methods that were previously reviewed and approved by the NRC.

(2) 50.59 evaluation of a procedure revision to 17019-1/2 regarding operator response to Turbine Condenser low vacuum/high rate of change lowering.

71111.19 - Post-Maintenance Testing Post-Maintenance Test Sample (IP Section 03.01)

[[IP sample::=

=IP 71111.18|count=6}}

The inspectors evaluated the following post maintenance tests:

(1) Unit 2 Loop 2 Atmospheric Relief Valve (ARV) following a system outage on July 10, 2019, SNC685621.

(2) 2A NSCW Pump #3 following a system outage on July 29, 2019, SNC998895.

(3) 1A NSCW Fan #1 following a PM outage on July 24, 2019, SNC122439.

(4) 1B EDG following repair of issues associated with the fuel injection pump failure on August 7, 2019, SNC1039987.

(5) 2B NSCW Pump #4 following system outage on September 12, 2019, SNC894661.

(6) 2A EDG jacket water leak repair on September 26, 2019, SNC1051230.

71111.20 - Refueling and Other Outage Activities Refueling/Other Outage Sample (IP Section 03.01)

(1) The inspectors evaluated forced outage activities on Unit 2 after Unit 2 tripped due to a MSIV closure on Loop 2 from July 19, 2019 to July 22, 2019.

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Surveillance Tests (other) (IP Section 03.01)

(1) 14633-1, Unit 1 Solid State Protection System (SSPS) Slave Relay K648 Train 'B' Test Safety Injection, on August 15, 2019.

(2) 14616-1, Unit 1 'A' Train CCW/NSCW SSPS Slave Relay Test, on September 25, 2019.

Inservice Testing (IP Section 03.01) ===

(1) 14805A-1, Unit 1 'A' Train Residual Heat Removal (RHR) Inservice Test (IST) and Response Time Test, on July 24, 2019.

RCS Leakage Detection Testing (IP Section 03.01) (1 Sample)

(1) 14905-1, RCS Leakage Calculation (Inventory Balance), following elevated Unidentified Leakage on August 23,

71124.05 - Radiation Monitoring Instrumentation Calibration and Testing Program (IP Section 02.02)

The inspectors evaluated the calibration and testing program implementation.

(1) The inspectors reviewed the following:

• The licensee's evaluation of URI 2018004-02.

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below: MS07: High Pressure Injection Systems (IP Section 02.06) ===

(1) Unit 1 (July 1, 2018 - June 30, 2019)

(2) Unit 2 (July 1, 2018 - June 30, 2019)

MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)

(1) Unit 1 (July 1, 2018 - June 30,2019)

(2) Unit 2 (July 1, 2018 - June 30, 2019)

MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)

(1) Unit 1 (July 1, 2018 - June 30, 2019)

(2) Unit 2 (July 1, 2018 - June 30, 2019)

71152 - Problem Identification and Resolution Annual Follow-up of Selected Issues (IP Section 02.03)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) 2R20 polar crane movement during vessel flange repair evolution, CR10599538.

(2) Mislocated fuel assembly in cask loading pit, CR 10639050.

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

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 05000424/2018-002-00, Manual Reactor Trip due to receiving Rod Control Urgent Failure Alarm during Low Power Physics Testing (ADAMS accession:

ML18337A188): The inspectors determined that it was not reasonable to foresee or correct the cause discussed in the LER therefore no performance deficiency was identified. The inspectors also concluded that no violation of NRC requirements occurred.

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

60855.1 - Operation of an Independent Spent Fuel Storage Installation at Operating Plants Operation of an Independent Spent Fuel Storage Installation at Operating Plants

(1) The inspectors evaluated the licensees independent spent fuel storage installation cask loadings September 16 - 27, 2019. Specifically, the inspectors observed the following activities;

• Fuel selection and fuel loading
• Heavy load movement of the multi-purpose canister (MPC)
• Drying and backfill evolutions
• Closure welding and non-destructive weld evaluations
• Transfer and transport evolutions
• Radiological field surveys

INSPECTION RESULTS

Unresolved Item Calibration Surveillance Extension of Post Accident 71111.22 (Closed) Monitoring Instruments URI 05000424,05000425/2018004-03

Description:

Unresolved item (URI) 05000424, 425/2018004-03 was opened in inspection report 05000424, 425/2018004 (Agency wide Documents Access and Management System (ADAMS) Accession No. ML19038A490) to determine if a performance deficiency existed and if that performance deficiency was more than minor for the licensee's potential failure to justify the surveillance frequency extension of Post Accident Monitoring System (PAMS)instruments to include:

(1) containment normal sumps level (narrow range),

(2) containment water level (wide range),

(3) containment radiation level monitors (high range), and

(4) steam line radiation monitor.

The licensee evaluated historical drift for the instruments of concern and demonstrated no adverse trend that would impact extension of electronic calibrations to a staggered 18-month basis. The licensee also determined that credit for completion of a TS required CHANNEL CALIBRATION would be based on the completion of the less frequently performed electronic calibrations (staggered 18-month interval) since the isotopic calibrations are performed every 18-months.

The licensee did determine that the electronic calibration interval for the Containment High Range Radiation monitors should be decreased back to 18 months to match the isotopic interval. The movement of the surveillance frequency was based on the uncertainty that was recently determined to exist with the isotopic calibration process for the Containment High Range Radiation monitors and the inadequate amount of data available with the new calibration process. The inadequate isotopic calibration process is addressed in URI 05000424/425/2018004-02.

The inspectors performed additional inspection and review of licensee-supplied additional documentation, as well as consulted with NRC staff. Based upon information provided to the inspectors as well as results of NRC staff discussions, the inspectors determined that no violation of regulatory requirements exists. The inspectors also determined that there was no performance deficiency. This URI is closed.

Corrective Action Reference(s): The licensee entered the URI in CR 10621152 and documented their evaluation in Technical Evaluation (TE) 1047433.

Failure to Calibrate Containment High-range Area Radiation Monitors Cornerstone Significance Cross-Cutting Report Aspect Section Emergency Pending [H.1] - 71124.05 Preparedness AV 05000424,05000425/2019003-01 Resources Open EA-19-112 The inspectors identified an Apparent Violation (AV) of Technical Specification (TS) 3.3.3, for the failure to correctly calibrate the Vogtle Unit 1 (U1) and Unit 2 (U2) containment high-range area radiation monitors 1RE-0005, 1RE-0006, 2RE-0005, and 2RE-0006. Specifically, the source-to-detector geometry used for isotopic calibrations was not fixed and reproducible which resulted in radiation monitor indications in the main control room that were biased high. These radiation monitors are relied upon during an accident to provide release assessment for use by plant operators in determining the need to invoke site emergency plans.

Description:

In October 2018, the inspectors identified potential errors in the calibration process used to perform in-situ isotopic calibrations on the Vogtle U1 and U2 containment high-range area radiation monitors (CHRMs) 1RE-0005, 1RE-0006, 2RE-0005, and 2RE-0006. Specifically, the methodology used to perform the calibrations failed to create a reproducible source-to-detector geometry from one surveillance to the next. Instead, the licensees calibration procedure involved moving the cesium-137 (Cs-137) point source closer to the detector surface over time in an attempt to maintain, as the source decayed, a target dose rate of 17 R/hr +/- 20%. Prior to each calibration, the distance to achieve 17 R/hr was determined on a benchtop using the calibration source and a small-volume, NIST-traceable ion chamber. As this distance decreased over time, the potential existed for the active detection volume of the CHRMs to be unevenly irradiated during the in-situ isotopic calibration. As a result, it is possible the CHRMs would under respond compared to the much smaller benchtop ion chamber. Therefore, the instrument gain may have been unnecessarily adjusted upward to compensate for low detector response over the course of several calibration surveillances. The inspectors documented an Unresolved Item (URI) in inspection report 2018-004 (05000425,05000424/2018004-02).

In response to this URI, the licensee performed an evaluation to determine the magnitude of the calibration error and presented the results to NRC inspectors on June 19, 2019. The evaluation consisted of irradiating spare containment high range ion chamber tubes in a gamma box calibrator to determine nominal response characteristics and then performing a transfer calibration using the Cs-137 calibration source in a fixed, direct contact geometry with both the spare detectors and those currently installed on Unit 2. Using this methodology, a gain factor (R/hr/Amp) was calculated for 2RE-0005 and 2RE-0006 and compared to the gain factors currently in use. In this manner, all sources of potential error described in the URI (i.e. inconsistency in measurement distance, uneven irradiation, and failure to decay-correct the source) were addressed in the evaluation.

The results showed that the gain factors currently in use were biased high by 60% for 2RE-0005 and 84% for 2RE-0006. Therefore, indications for these instruments in the main control room (MCR) would be biased high by a similar amount. In addition to the licensees evaluation, the inspectors performed a review of gain factors for both units going back to 2009. This showed that 1RE-0005, 1RE-0006, 2RE-0005, and 2RE-0006 have been operating with a positive bias between 46% and 128% during that time period. This bias exceeds the +/- 20% acceptance criteria in calibration procedures 24989-1, Isotopic Channel Calibration of the Containment High Range Area Radiation Monitors 1RE-0005 and 1RE-0006 and 24989-2, Isotopic Channel Calibration of the Containment High Range Area Radiation Monitors 2RE-0005 and 2RE-0006 and exceeds the accuracy range of +/- 20% of the actual radiation field described in UFSAR Section 12. In addition, as the Cs-137 calibration source continued to decay the source would be moved closer to the detector surface. As a result, the uneven irradiation would become more pronounced and could result in continued changes to the gain factor over time and an even larger positive bias in MCR indication.

The inspectors noted that 1RE-0005, 1RE-0006, 2RE-0005, and 2RE-0006 are used during an accident to assist in making emergency action level (EAL) declarations, as described in the licensees EAL implementing procedure NMP-EP-141-003, Vogtle 1 & 2 Emergency Action Level and Basis. Specifically, the instruments are used in the Fission Product Barrier Degradation matrix (EALs FA1, FG1 and FS1) and Cold Shutdown/refueling System Malfunction Reactor Pressure Vessel Level accident scenario (EALs CG1 and CS1). Since the monitors were biased high compared to actual radiological conditions in containment, these emergency declarations would be made earlier than necessary or when a lower classification was more appropriate. In some cases, this would result in an Offsite Response Organization implementing unnecessary protective actions for the public.

Corrective Actions: The licensee is revising their procedures for performing calibrations on the containment high range area radiation monitors.

Corrective Action References: Condition Reports 10621148 and 10621284

Performance Assessment:

Performance Deficiency: The licensees failure to calibrate containment high range area radiation monitors, as required by TS 3.3.3, 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, the magnitude of the detector overresponse would have increased over time as the Cs-137 source decayed.

Significance: The significance determination is pending an initial significance characterization and is not yet finalized.

Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety.

The event was a direct result of the licensees failure to provide adequate calibration procedures.

Enforcement:

Violation: Technical Specification 3.3.3 requires the licensee to perform periodic channel calibrations for post-accident monitoring equipment, including radiation monitors 1RE-0005, 1RE-0006, 2RE-0005, and 2RE-0006. Section 1.1 of the TS states that A channel calibration shall be the adjustment, as necessary, of the channel so that it responds within the required range and accuracy to known inputs. Contrary to this, since plant startup, the licensee has failed to periodically calibrate containment high-range area monitors 1RE-0005, 1RE-0006, 2RE-0005, and 2RE-0006 so that they responded within the required accuracy to known inputs. Upon identification, the licensee took action to revise their calibration procedures.

Enforcement Action: This violation is being treated as an apparent violation pending a final significance (enforcement) determination.

The disposition of this finding and associated violation closes URI: 05000425,05000424/2018004-02.

EXIT MEETINGS AND DEBRIEFS

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

• On October 16, 2019, the inspectors presented the integrated inspection results to Mr.

Keith Taber and other members of the licensee staff.

• On October 17, 2019, the inspectors discussed the closure of URI 05000425,05000424/2018004-02, resulting in AV 2019003-01, with Mr. Keith Taber and other members of the licensee staff.
• On August 22, 2019, the inspectors presented the Biennial Requalification Inspection results to Matthew Norris, Operations Director and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or Procedure Date 60855.1 Corrective Action 10646689 Documents Procedures 93230-C Spent Fuel Cask Bridge Crane Operating Instructions 20 Work Orders SNC508771 71111.04Q Drawings 1X4DB116-2 P&I Diagram - Chemical & Volume Control System - System 37.0 No. 1208 71111.05Q Fire Plans 92726B-1 Zone 26B - Auxiliary Building - Levels A&B Fire Fighting 3.2 Preplans 2726B-2 Zone 26B - Auxiliary Building - Levels A&B Fire Fighting 3.0 Preplan 2730-1 Zone 30 - Auxiliary Building - Level B Fire Fighting Preplan 1.2 2730-2 Zone 30 - Auxiliary Building - Level B, ACCW Pump, Train A 1.0 Fire Fighting Preplan 2731-1 Zone 31 - Auxiliary Building - Level B Fire Fighting Preplan 3.1 2731-2 Zone 31 - Auxiliary Building - Level B Fire Fighting Preplan 1.0 2732-1 Zone 32 - Auxiliary Building - Level B Fire Fighting Preplan 2.0 2732-2 Zone 32 - Auxiliary Building - Level B, SI Pump, Train A Fire 1.0 Fighting Preplan 2733-1 Zone 33 - Auxiliary Building - Level B Fire Fighting Preplan 4.0 2733-2 Zone 33 - Auxiliary Building - Level B Fire Fighting Preplan 1.0 2749-1 Zone 49 - Auxiliary Building Level 1 Fire Fighting Preplan 3.0 2752-1 Zone 52 - Auxiliary Building Level 1 Fire Fighting Preplan 2.0 2855-1 Zone 155 - Auxiliary Feedwater Pumphouse - Train B Fire 2.2 Fighting Preplan 2856-1 Zone 156 - Auxiliary Feedwater Pumphouse Fire Fighting 3.1 Preplan 2857A-1 Zone 157A - Auxiliary Pumphouse - Train C Fire Fighting 2.3 Preplan 2857B-1 Zone 157B - Auxiliary Feedwater Pumphouse Fire Fighting 1.2 Preplan 71111.11B Miscellaneous Eight (8) Licensed Operator Medical Inspection Type Designation Description or Title Revision or Procedure Date Records JPM V-RQ-JP- Implement Tech Spec LCO Requirements for a Failed NR Revision 8.2, 10008-001 Temperature Instrument (SRO Only) 07/09/2019 JPM V-RQ-JP- Raise Accumulator Level While at Low RCS Pressure Revision 1.0, 13105-001 07/01/2019 JPM V-RQ-JP- Place Containment Hydrogen Monitors in Service Revision 13130-002 10.3, 06/19/2019 JPM V-RQ-JP- Manually Actuate Control Room Isolation Due to Smoke in Revision 13301-002 the Outside Air Intake (Alternate Path) 15.4, 06/24/2019 JPM V-RQ-JP- Respond to a Radiation Alarm During a Liquid Radwaste Revision 2.1, 213-002 Release (Alternate Path) 06/19/19 JPM V-RQ-JP- Locally Throttle RHR Flow Following Control Room Revision 3.0, 18038-008 Evacuation 07/01/2019 JPM V-RQ-JP- Manually align ECCS for Hot Leg Recirculation Phase Revision 9.3, 19014-002 (Alternate Path) 06/19/2019 JPM V-RQ-JP- Locally Operate a Bypass Feed Isolation Valve Revision 3.1, 231-007 06/19/2019 JPM V-RQ-JP- Establish Main Feedwater Flow to SGs Following Loss of Revision 2.0, 231-009 Heat Sink 06/19/2019 JPM V-RQ-JP- Classify an Emergency Event (SRO Only) Revision 2.0, NMP-EP-141-003 06/19/2019 License Activation Documentation

               (NMP-TR-406) for

licensed operators Remedial Training Plans for two (2) Licensed Operators from current Requalification Inspection Type Designation Description or Title Revision or Procedure Date Cycle SBT for Scenario-Based Testing records associated with Rev 23.1, Requalification Requalification Scenario DS-06: 75% Power, SGTR 03/13/2019 Scenario DS-06 SBT Records for SBT Records Associated with Initial Scenario #1, June 2019 Revision 0, Initial Scenario Exam: 50% Power, Uncontrolled Rod Withdrawal, LOCA 12/19/2018

               #1, June 2019

Exam SBT Records for Scenario-Based Testing records associated with Revision 7.2, Requalification Requalification Scenario DS-21: 100% Power, Rod Ejection 03/19/2019 Scenario DS-21 LOCA Shift 4 Licensed Operator 2019 LOCT Segment 2 Training Attendance Records Shift 4 Licensed Personnel Quarterly Proficiency Time Records (NMP- TR-406-F01, NMP-OS-026-F- 01) Simulator Cycle 12/17/2018 Core Test Certification Simulator 75% Power, BOL, Loss of Power, LOCA Revision Scenario DS #10 18.1 Simulator 100 % Power, MOL, Steam Leak, LOCA Revision Scenario DS #14 19.1 Simulator 100% Power, EOL, Ejected Control Rod LOCA Revision 8.0 Scenario DS #21 Inspection Type Designation Description or Title Revision or Procedure Date Simulator 75% Power, BOL, SGTL to SGTR Revision Scenario DS #6 24.0 Simulator Test LOCA Outside Containment 09/19/2017 05-03 Simulator Test Control Rod Failures 09/29/2017 05-19b Simulator Test Generator and Grid Malfunctions 10/10/2017 05-47d Simulator Test RCP #1 and 2 Seal Failures with Accidental Release from 10/02/2017 05-67a the Waste Monitor Tank Simulator Test Plant Shutdown from Rated Power to Hot Standby 12/19/2018 06-04 Simulator Test Surveillance Testing on Safety Equipment Systems (DG 12/10/2018 06-08 Operability Test) Simulator Test Surveillance Testing on Safety Equipment Systems 12/10/2018 06-08 (14510A-1 Train A Control Room Emergency Filtration System Operability Test) Simulator Test Steady State Performance Test at 50% Power 02/18/2018 06-09 Simulator Test Simultaneous Trip of all Feedwater Pumps 11/20/2018 07-02 Simulator Test Main Turbine Trip without a Reactor Trip 11/20/2018 07-06 Simulator Test Maximum Size Unisolable Rupture 11/20/2018 07-09 Procedures NMP-OS-026 License Administration Version 1.0 NMP-TR-208 Examination and Examination Security Version 10.0 NMP-TR-416 Licensed Operator Continuing Training Program Version 10.0 Administration NMP-TR-422 Simulator Configuration Control Version 7.0 NMP-TR-424 Licensed Operator Continuing Training Exam Development Version 6.0 71111.11Q Procedures 13506-C Digital Feedwater Control System 9.0 24484-2 Steam Generator #3 Level Control 2F-531 Channel 15 Calibration Inspection Type Designation Description or Title Revision or Procedure Date 71111.12 Corrective Action 10623372, Documents 10604001, 10638064, 10620795, 10591187, 10354066 Miscellaneous MREP Meeting Agenda Minutes on August 9, 2019 and June 5

                            & 6 & 11, 2019

Procedures NMP-ES-027 Maintenance Rule Program 10.0 NMP-ES-027 Maintenance Rule Program 9.0 71111.13 Corrective Action 10634731 Documents Miscellaneous Plan of the Day for August 5, 2019 Unit 1 Phoenix Integrated Risk Reports for August 5, 2019 Unit 1 Narrative Control Room Logs for August 5, 2019 1-ET-18-2403- Protected Equipment Tagout 00156 Procedures NMP-OS-010 Protected Train/Division and Protected Equipment Program 8.0 NMP-OS-010-003 Vogtle Protected Equipment Logs 10.0 71111.15 Corrective Action 10638697, Documents 10634731, 10635016, 10632909, 2737 Drawings 2X3D-BH-G03H-2 Diesel Engine Control Diesel Engine - Generator DG2A 10.0 Sheet 2 2X3D-BH-G03N Diesel Engine Control Diesel Engine - Generator DG2B 10.0 Sheet 1 2X3D-BH-G03R-1 Diesel Engine Control Diesel Engine - Generator DG2B 9.0 Sheet 1 of 2 2X3D-BH-G03S-1 Diesel Engine Control Diesel Engine - Generator DG2B 11.0 Inspection Type Designation Description or Title Revision or Procedure Date Sheet 1 2X3D-BH-G03S-2 Diesel Engine Control Diesel Engine - Generator DG2B 11.0 Sheet 2 AX4AK01-00748 Schematic Power Driven Potentiometer 0 Miscellaneous CE IB 02-18 Cooper-Enterprise Owners Group Information Bulletin - 06/07/2002 R4/RV4 Fuel Pump Base Bolts Procedures 14668B-1 Train B Diesel Generator Operability Test 8.2 14980A-2 Diesel Generator 2A Operability Test 30.1 14980B-1 Diesel Generator 1B Operability Test 30.2 Work Orders SNC1039987 71111.18 Calculations NMP-ES-050-F01 Vogtle Unit 2 Cycle 21 Reload Analysis 06/26/2018 Engineering NF-GP-18-64 Vogtle Electric Generating Plant Unit 2 Cycle 21 Reload 10 Version 1, Evaluations CFR 50.59 Evaluation and Supplemental Technical 12/19/2018 Evaluation for Exclusion Zone Change NMP-AD-008-F01 50.59 Applicability Determination for Vogtle 2 Cycle 21 02/12/2019 Reload Core and Associated COLR with FRAMATOME GAIA Lead Test Assemblies with EATF Features NMP-AD-010-F03 10 CFR 50.59 Evaluation for Vogtle Unit 2 Cycle 21 Reload 03/15/2019 Core and Associated COLR with FRAMATOME GAIA Lead Test Assemblies with EATF Features NMP-AD-010-F03 10 CFR 50.59 Evaluation of Major Procedure Revision to 08/27/2019 17019-1/2 regarding operator response to ALB19-04 Turbine Condenser Low Vacuum/High Rate of Change Lowering Miscellaneous ANP-3735P Mechanical Design Report for GAIA/EATF Lead Assemblies November at Vogtle 2018 FS1-0041257-1.0 Description of EATF Features and Clarifications to Support 12/07/2019 SNC Responses to FDC and 10 CFR 50.59 71111.19 Corrective Action 10633110, Documents 10632907, 10632977, 10632590, 10634731, 10635016, 10632977, Inspection Type Designation Description or Title Revision or Procedure Date 10632590, 10627543 Corrective Action 10638924 Documents Resulting from Inspection Drawings 2X3D-BD-K04D Elementary Diagram Nuclear Service Cooling Water System 24.0 2-1202-P4-004-M01 Procedures 14430-1 NSCW Cooling Tower Fans Monthly Test 12 14668B-1 Train B Diesel Generator Operability Test 8.2 14802B-2 Train B NSCW Pump / Check Valve IST and Response 11.2 Time Test 14825-2 Quarterly Inservice Valve Test 98.1 14825-2 Quarterly Inservice Valve Test 98.1 14980B-1 Diesel Generator 1B Operability Test 30.2 277-C NTS Timing Relay Maintenance 3.0 Work Orders SNC122439, SNC841815, SNC985435, SNC880472, SNC998895, SNC987801, SNC1039987, SNC841815, SNC894661, SNC989050, SNC547667 71111.22 Corrective Action 10640132 Documents Procedures 13744B-1 Train B Essential Chilled Water System 14 14633-1 SSPS Slave Relay K648 Train B Test Safety Injection 10 14805A-1 Train A Residual Heat Removal Pump and Check Valve IST 7.0 and Response Time Tests 14905-1 RCS Leakage Calculation (Inventory Balance) 74 Inspection Type Designation Description or Title Revision or Procedure Date NMP-OS-009 RCS Unidentified Leakage Monitoring Program 3.0 71124.05 Engineering Plant Vogtle Response to Containment High Range Area December Evaluations Radiation Monitor Issues 2018 Plant Vogtle Response to URI June 2019 Procedures 24989-1 Isotopic Channel Calibration of the Containment High Range Rev. 1 Area Monitors 1RE-0005 and 1RE-0006 24989-1 Isotopic Channel Calibration of the Containment High Range Ver. 7.1 Area Monitors 1RE-0005 and 1RE-0006 24989-2 Isotopic Channel Calibration of the Containment High Range Rev. 1 Area Monitors 2RE-0005 and 2RE-0006 24989-2 Isotopic Channel Calibration of the Containment High Range Ver. 4 Area Monitors 2RE-0005 and 2RE-0006 43802-C Calibration of Gamma Standards Ver. 17 NMP-EP-141-003 Vogtle 1 & 2 Emergency Action Levels and Basis (NEI 99-01 Ver. 4.0 revision 6) 71152 Corrective Action 10639050, Documents 10599538 Miscellaneous NMP-RE-011-F01 UFLO #5 MPC-490 Loading Plan 2.0 Procedures 93120-C Spent Fuel Assembly Handling Tool Operating Instructions 14.1 93120-C Spent Fuel Assembly Handling Tool Operating Instructions 13 247-C Containment Polar Crane Operating Instructions 28.1 93713-C MPC Fuel Loading Operations 12.0 NMP-RE-006 Dry Cask Loading Verification 1.3 71153 Miscellaneous NMP-GM-002- Cause Determination Report Summary for CR10542344 08/14/2019 F02 20| ]]