ML20134H160

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Insp Repts 50-424/96-12 & 50-425/96-12 on 961110-1221. Violations Noted.Major Areas Inspected:Operations,Maint, Engineering & Plant Support
ML20134H160
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 01/17/1997
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20134H127 List:
References
50-424-96-12, 50-425-96-12, NUDOCS 9702110180
Download: ML20134H160 (30)


See also: IR 05000424/1996012

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U. S. NUCLEAR REGULATORY COMMISSION (NRC) l

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REGION II

Docket Nos. 50-424 and 50-425

License Nos. NPF-68 and NPF-81

Report No: 50-424/96-12. 50-425/96-12

Licensee: Georgia Power Company (GPC)

Facility: Vogtle Electric Generating Plant (VEGP) Units 1 & 2

-Location: 7821 River Road

Waynesboro. GA 30830

Dates: November 10 - December 21, 1996

Inspectors: M. Widmann. Senior Resident Inspector (Acting)

K. O'Donohue. Resident Inspector (In Training)

B. Bearden. Reactor Inspector (Sections M8.1 thru M8.3)

R. Carrion. Project Engineer (Section R8.1)

W. Kleinsorge. Reactor Inspector (Sections M1.2. M1.4 thru

M1.7)

Approved by: P. Skinner. Chief

Reactor Projects Branch 2

Division of Reactor Projects

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9702110100 970117

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EXECUTIVE SUMMARY

Vogtle Electric Generating Plant Units 1 and 2

NRC Inspection Report 50-424/96-12. 50-425/96-12

This integrated inspection included aspects of licensee operations,

engineering, maintenance, and plant support. The report covers a six-week

period of resident ins)ection: in addition, it includes the results of

announced inspections ]y two reactor inspectors and one regional project

engineer.

Doerations

e In general, the conduct of operations was professional and

safety-conscious (Section 01.1).

e A notification of unusual event was declared on Unit 2 due to a loss of

function of 17 main control annunciator panels. Grounding of an

annunciator light socket caused a blown fuse in a power supply cabinet

that resulted in loss of the control room alarm function. This was a

duplicate event due to similar maintenance work performed on the

annunciator light boxes. (Section 01.2).

e A Unit 1 automatic turbine / reactor trip occurred as a result of a loss

of stator cooling to the turbine generator due to maintenance work on a

pressure switch (Section 01.3).

e A weakness was identified in the implementation of the maintenance

3rogram for the heat trace / freeze protection system. A review of the

lest trace / freeze protection systems were performed with numerous

deficiencies noted. The licensee stated that they were cognizant of most

of the issues and developed a plan to address the status of open

preventive maintenance and maintenance work orders (Section 02.1).

Maintenance l

e Maintenance and surveillance activities were generally completed l

thoroughly and professionally, with satisfactory results (Sections M1.1

and M1.2). ,

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e A non-cited violation was documented concerning missed surveillances on

containment electrical penetration circuit breakers for the personnel

and escape air locks (Section M1.3).

e A violation was identified for inadequate corrective actions to address

improperly secured safety-related motor control center door latches.

The issue was initially documented in Inspection Report (IR)

50-424.47' '96-09 dated September 16. 1996. The inspectors performed a

walkdowr an effort to verify stated corrective actions of IR 96-09

were com, 1ed. (Section M1.6).

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Enclosure 2

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e A review of the Remote Shutdown Panels and associated equipment was

performed. The licensee's program for maintenance and testing for this

equipment was adequate. However, a weakness in the area of housekeeping

inside of the inspected panels was identified (Section M8.1).

Enaineerina

e The inspectors concluded that engineering personnel did an effective job

in determining the underlying root cause for a loss of annunciator

function after the occurrence of two similar events. Engineering

personnel effectively supported operations. maintenance. and

Instrumentation and Control troubleshooting efforts. (Section E7.1).

Plant Sucoort

e A non-cited violation was identified concerning a missed performance of

a technical specification required surveillance for a specific activity

prior to entry into mode 4 and subsequent power ascension activities.

(Section R8.1).

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Enclosure 2

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Report Details

Summary of Plant Status

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Unit 1

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The unit began the period operating at full power, however, on November 27. '

1996, the unit automatically tripped due to a maintenance activity in the main

generator stator cooling / hydrogen seal oil panel. A loss of control power to .

the stator cooling panel actuated a tri) relay giving the turbine / reactor trip  !

signal. All rods fully inserted and tie unit was safely shutdown into mode

3. Following-troubleshooting and corrective action criticality was achieved

on November 28. 1996, with nominal full power attained on November 29. The

unit operated at full power the remainder of the inspection period.

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L Unit 2

The unit operated at full power throughout the inspection period. ,

I. Ooerations i

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01 Conduct of Operations

01.1 General Comments (71707) l

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Using Inspection Procedure (IP) 71707. the inspectors conducted frequent  :

reviews of ongoing plant operations. Operations activities were  ;

generally conducted in a controlled, professional, and safety-conscious '

manner. Minor issues identified were forwarded to operations management l

for resolution. i

01.2 Annunciator Function Lost in Unit 2 Control Room (93702)  !

At 8:12 a.m. on November 15. 1996. personnel were authorized to aerform

maintenance on Unit 2 main control room annunciator ALB06-E01. C9MT VENT .

ISO ACTUATION [ Containment Ventilation Isolation Actuation), due to a t

light socket having fallen behind the alarm panel. During the work  :

activity, maintenance personnel inadvertently grounded the light socket

to the annunciator i

to numerous panels. panel which caused various alarms and a loss of power ,

At 8:42 a.m. the licensee declared a Notification of Unusual Event

(NOUE) on Unit 2 due a loss of function for most of the safety system

main control annunciator Janels. The NRC. state, and local officials '

were promptly notified. Juring the event, compensating non-alarming  ;

indicators were available. Due to the loss of safety related l

annunciator functions the licensee initiated compensatory measures that  ;

included additional monitoring of key plant aarameters. The increased

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monitoring activities were~ continued until tie Event was terminated at  !

j 11:15 a.m.  ;

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On October 25. a similar event occurred as a result of maintenance.

From the October event, the licensee developed and implemented several *

corrective actions including removing the associated annunciator alarm  :

cards to de-energize the affected light socket. The licensee at that -!

time, also initiated a recuest for engineering assistance (REA) 4. )  :

review system electrical crawings and investigate other potential l

contributors to the event. As part of their original troubleshooting j

, efforts, the licensee did not determine that a hard ground was present

i in the system. The ground detection system design at Vogtle is an l

ungrounded system. This design allows the system to handle one fault  ;

l without losing power and permits the licensee time to troubleshoot <

j ground problems. However, the introduction of a second fault may  !

complete a short to ground. resulting in a loss of power to the

annunciators. l

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As a result of troubleshooting efforts stemming from the second event

the licensee determined that a logic card had field contacts wired i

i incorrectly that did not allow the ground detection alarm system to l

recognize a fault. Consecuently, the control room operators were .

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unaware of a system grounc . When maintenance personnel commenced their '

work activity on the annunciator light box, the moment they touched the

control panel, a fuse blew in the power supply cabinet that fed the main

control annunciator panels. This was the same fuse that was replaced in  ;

the October 25 incident. The licensee later determined that a common  !

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ground wire existed from one annunciator light box to the next. Even  !

though the light socket was de-energized, the light box itself remained

part of the ground detection system. Therefore, with the ground fault

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already present, maintenance inadvertently established a short to ground

that caused the loss of the 17 main control room annunciators panels.

The licensee concluded after the second event that if-the drawing review

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requested by the REA had been conducted at the time of the initial

event, then the common ground would have been identified and potentially

i avoided the second event. However, the license recognized during their

onsite review that the REA effort would be manpower intensive due to the

complexity of the electrical system and chose to take corrective action  ;

on the annunciator panel light socket prior to completion of that

review. '

Upon replacement of the fuse, rewiring of the ground detection system ,

logic card contacts, and resolving the hard ground fault, all ,

annunciator functions were restored. j

At the time of the declaration. Unit 2 reactor power was approximately  ;

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100 percent. No transient or challenges to safe operation occurred i

during the time of the NOUE.  !

As in the first event, the inspectors concluded that the licensee's I

conservative response was appropriate. The classification of the event

was timely and all required notifications completed. Operations shift

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i personnel reviewed all annunciator response procedures and took

compensatory actions for alarms affected during the event (reference

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section E7.1 for additional licensee corrective actions and an

assessment of engineering root cause determination).

j 01.3 Unit 1 Automatic Turbine / Reactor Trio (93702)  !

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At 8:46 a.m. on November 27. 1996, a Unit 1 automatic turbine / reactor l

trip signal was received in the control room as a result of maintenance

! activity in the main generator stator cooling / hydrogen seal oil panel.

The automatic trip signal was received witu the unit at 100 percent

l reactor power. Although main steam line code safety valves did not

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lift. the atmospheric reliefs valves (secondary pressure operated relief

valves) were actuated. Based on a review of the sequence of event  !

j report and walkdown of the main control room boards, the inspectors  !

concluded that the post-trip plant response was normal. The unit was

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i stabilized in mode 3. with no significant complications identified.

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On November 27. maintenance personnel were authorized to isolate a

hydrogen pressure switch inside the stator cooling /nydrogen seal oil

panel when the technician inadvertently moved a metal identification tag -

4 and touched an exposed terminal strip on the stator cooling system that )

i shorted out the control panel 120 VAC power. As a result, a high

l temperature relay logic was actuated (failed high on loss of )ower)

which led to the loss of stator cooling and thereby causing tle )
turbine / reactor trip signal.

Shortly after the occurrence of the event the inspectors responded to

the control room and observed plant conditions. The inspectors observed

a portion of-the post-trip maintenance activities including replacement

of the stator cooling 120 VAC power fuse and removal of all metal tags

inside the control panel. In addition, the inspectors witnessed a

portion of licensee management's investigation into the event and

concluded that this activity was appropriately performed. The licensee

determined that the trip occurred as a result of the metal

identification tag coming in contact with an exposed terminal strip.

The contact was a direct result of the technician's movement of the tag

while closing the hydrogen system isolation valve. A review of the

circumstances revealed that the tag was inconspicuously placed in front

of the terminal strip. The inspectors' discussions with the technician

indicated that he was unaware of the terminal strip behind the tag.

Following troubleshooting efforts the reactor was restarted.

Criticality was achieved at 1:27 a.m. on November 28. with nominal full

power achieved on November 29. The licensee issued Licensee Event

Report (LER) 50-424/96-12. Main Generator Turbine / Reactor Trip While

Performing Maintenance In The Stator Cooling / Hydrogen Control Panel.

Enclosure 2

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The inspectors' noted that the licensee management's decision to defer I

the restart of the unit until after. troubleshooting and maintenance '

efforts were completed on the backup power supply that feeds the Unit 1 t

annunciator panels was conservative. A restart could have occurred late

afternoon the day of the trip, however, management made a conscious I

choice to defer the startup until this other problem was addressed.

02 Operational Status of Facilities and Equipment j

02.1 Heat-Tracino and Freeze Protection Panel Status

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a. Insoection Scooe-(71714)

The inspectors walked down the heat tracing and freeze protection system

to determine the effectiveness of the licensee's program to protect )

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against cold weather conditions. This review included examination of j

the Updated Final Safety Analysis Report (UFSAR) system description: the '

licensee's design basis document; the system's physical condition:

preventive maintenance (PM) checklists SCL01749 Freeze Protection:.and

SCL00424. Heat Tracing: outstanding Maintenance Work Orders (MWO)s and

corrective work orders: and Procedure 13901-1/2, Heat Tracing System.

The inspectors' also interviewed the system engineer and maintenance

manager as to the status of the system work. I

b. Observations and Findinas

On December 12 and 13, 1996, the inspectors performed a walk down of the

Unit 1 and 2 heat tracing and freeze protection panels. Based on this

effort, the inspectors identified that the heat trace and freeze

)rotection system had not been maintained in a condition whereby it can

3e relied upon to perform its intended function. However the

inspectors recognized that the system does not provide a safe shutdown

function and is not classified as safety-related.

On December 12 the inspectors performed the walkdown with the system.

engineer. Of the panels inspected, more than half were not working

properly. Numerous maintenance work orders were written, but additional

deficient conditions were identified by the inspectors. Deficiencies

varied from central alarms being illuminated: ground faults being

evident: undertemperature, overtemperture, and undervoltage alarms

visible: and freeze protection systems automatically being energized

when weather conditions did not warrant it. Inside three freeze

protection panels. located in the fire pump house, the inspectors

identified evidence of rodent intrusion. Although there was an j

intrusion of rodents into the panels, there was no obvious damage to i

cables or circuit connections. The system engineer was aware of some of  !

the problems listed above, but captured the additional deficiencies

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identified during the walkdown.

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Enclosure 2

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t- The inspectors' review of the PMs on the system indicated that four of l

the fifteen freeze protection panels had not had a routine PM performed

- in a number of years. The last time the circulating water heat trace '

3 panel PM was performed was in November 1993. The Nuclear Service ,

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Cooling Water (NSCW) A and B train freeze protection panel PMs were last

! performed December 1994, and April 1995, respectively. The high voltage  ;

switchyard heat trace PM was last performed in August 1995. The i

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maintenance manager stated that a plan had been developed prior to this

review that would address the known deficient conditions, in addition to .
subsequent issues identified. The maintenance manager also indicated  !
that the past policy of approving PM due date extensions, was not  ;

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occurring as of November 1996. -As of this review, there were 34 open  :

maintenance and corrective work orders against the heat trace / freeze i

protection systems with the oldest one written in 1992, two written in j

! 1993, and 3 written in 1994. Ten MW0s were written against the system  !

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in 1995 that also remain open.  ;

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The licensee presented their basis as to why portions of the heat trace / I

freeze protection systems were out of service and did not have the  !

scheduled PMs performed. REA 94-VAA628. Review of Heat Tracing Panels. l

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dated September 1. 1995, was initiated to eliminate heat tracing on '

)iping larger than four inches. The licensee' developed Design Change i

l Jackage (DCP) 95-VAN 0067. Elimination of Heat Tracing / Freeze Protection -

& Setpoint Lowering. to implement the recommendations of the REA. Since l

j the due dates for the portion of systems affected by this REA were i

j extended, maintenance personnel postponed the work. However, the  !

licensee presented a cancellation notice dated December 12, 1996,

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indicating that the DCP 95-VAN 0067 would not be implemented. The  ;

! licensee also presented a revised PM schedule that incorporated all heat  ;

trace / freeze protection panels including a scheduled commitment date of

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December 29, 1996 to perform outstanding PMs.  ;

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c. Conclusions
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i The inspectors concluded that although portions of the heat trace / freeze

3 protection systems are not in a condition to perform their function, the

licensee has developed an adequate plan to address the issues. The

i cancellation of the DCP to eliminate heat tracing has removed the

affected portions of the system from a state of non-repair and has  !

prompted the licensee to take action on open items. As a result, the i

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4: inspectors concluded that system problems should be adequately addressed

l if the licensee follows their current maintenance plan.

02.2 Safety-Related Walkdowns i

i. a. Insoection Scooe (71707)

} The inspectors walked down the following engineered safety feature (ESF)

l systems as part of the routine inspection effort to verify availability

and overall condition of the safety-related systems:

Enclosure 2

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Unit 1 Safety Injection System  ;

Unit 2 Fuel Handling Building Post-Accident Exhaust System F

The inspectors also performed a review of UFSAR commitments and  !

technical specifications (TS) requirements for the above listed systems.

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b. Observations and Findinas

The ins)ectors verified proper system configurations both electrically

and meclanically for the above ESF systems through accessible portions ,

in the plant, walkdowns of main control room boards, and reviews of  !

system drawings. The inspectors also observed overall material  !

condition of system components during the walk downs. Any minor issues l

identified were forwarded to the licensee for resolution.

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c. Conclusions

The inspectors concluded that the systems reviewed were available to ,

perform their intended designed function: systems were properly aligned. .

and UFSAR commitments and TS requirements were met. No items or ,

discrepancies were noted during these inspections.

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03 Operations Procedures and Documentation (71707) l

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. 03.1 During the inspection period, the inspectors walked down the following i

l clearances:  !

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l 19600306 accumulator 1. 2. 3. and 4 isolation per unit i

operating procedure 12006-1

l 19600666 centrifugal charging pump (CCP) A auxiliary lube oil

i pump clearance to troubleshoot pump cycling while CCP

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The inspectors did not identify any problems or concerns during these  !

walkdowns. l

07 Quality Assurance in Operations

07.1 Evaluation of Licensee Self-Assessment Caoability (40500)

During this inspection period the inspector attended two Plant Review

Board (PRB) meetings. The PRB meeting of December 11 was primarily

concerned with a review of the Technical Review Manual for

implementation of the improved technical specifications scheduled to

! commence January 22. 1997. Other subject matters discussed were the

review and ap3roval of deficiency card (DC) dispositions and procedure

revisions. 11e second PRB meeting on December 18 reviewed responses to

, earlier documented NRC violations. The inspectors recognized the

i. licensee's effort in ensuring that the corrective actions developed

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Enclosure 2

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addressed the issues cited. Meetings attended were conducted critically- l

4 and openly with free and uninhibited discussion of issues. Meeting  !

i attendees were knowledgeable of the materials discussed. PRB attendees l

met TS requirements.

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j No issues were identified as a result of this review.

II. Maintenance

! M1 Conduct of Maintenance l

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M1.1 Maintenance Work Order Observations

a. InsDection Scooe (62707) (92902) ,

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,! The inspectors observed portions of maintenance activities involving the  !

following work orders.
19502616 Diesel Generator (DG) 1A day tank low level alarm

L ALB035-D07 troubleshoot i

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19601067 Replace valve 1-1405-U4-011 l

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19601177 NSCW pump 5 discharge isolation motor operated valve l

per DCP 95-V1N0035-1

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j - 19601931 Calibration 1-T0126; verify.UQ1118 below 3562.9 MWt

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j 19601961 DG 1B jacket water leak in coupling under left bank

turbo charge

19602213 Match marking motor coolers for A train pumps

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19602612 Computer point does not show correct indication on

reactor coolant drain tank vent valve 1-HV-7150

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19602831 Repair 1-HV-4486 control loop valve miniflow through

steam jet air ejector to condenser: change out~

. tracking driver card and light indication fuses

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29602921 Troubleshoot and repair train "B" hydrogen recombiner

29602951 Control room emergency filtration system A train

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breaker change out

29603039 Safety injection pump A train motor cooler low flow

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condition;' reverse plenum orientations

29603080 DG train 2A starting air: uncontrolled bleed down l

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i b. Observations and Findinas  !

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The observed maintenance activities were performed satisfactorily except l

as noted below:

During the inspection-period two events occurred as a result of  :

maintenance activities. The declaration of a Notification of Unusual i

Event (Section 01.2) when work on a light socket resulted in the loss of '

power to Unit 2 main control room annunciator panels, and the Unit 1

automatic trip due to loss of stator cooling (Section 01.3). These -

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events were a direct result of maintenance personnel errors.

In both cases, the precursors to the events were difficult to identify.

However, the licensee took appropriate corrective actions for both

events in an effort to preclude repetition.

c. Conclusions

The inspectors concluded that although maintenance personnel caused the

two above events, the work activities did not reflect poor control of

maintenance. The events were a result of unforeseeable circumstances.

No trends or indicators of adverse maintenance performance were

identi fied.

M1.2 Surveillance Observation

a. Insoection Scoce (61726)

The inspectors observed the performance or reviewed the following

surveillances and plant procedures:

14546-2 Turbine driven auxiliary feedwater (TDAFW) pump operability

test

14810-2 TDAFW pum) 1 check valve IST and manual initiating i

handswitc1 trip actuation device operability test j

14970-2 Semiannual, train "B" hydrogen recombiner  !

(2-1513-H7-002-000) functional test ]

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14980-1 DG 1A' operability test  !

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24568-2 Reactor coolant pump 1 train A. reactor trip underfrequency )

(281-A) and undervoltage (227-A) relays trip actuating i

device operational test and channel calibration

83308-2 Monthly NSCW flow test of 2-1203-P4-002-M01 component ,

cooling water (CCW) train B motor cooler per section 8.2. i

data sheet 1 of 83308-C l

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83308-2 Monthly NSCW flow test of 2-1203-P4-004-M01 CCW (train B) l

motor cooler per section 8.2. data sheet 1 of 83308-C

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83308-2 Monthly NSCW flow test of 2-1203-P4-006-M01 CCW (train B) I

q motor cooler per section 8.2. data sheet 1 of 83308-C

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b. Observations and Findinas

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! The observed surveillance activities were performed satisfactorily l

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except as noted below: 1

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i Review of GPC Procedure 83308-C. Revision 10. Flow Testing of Safety l

'Related NSCW System Coolers, does not address the following when using -

i the polysonics instrument: the maximum variation that is considered -

stable: what value to report when a range of flow values is encountered.
' or how to evaluate ranges that bridge the required flow range. The i
licensee indicated that they currently are in the  ;

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this procedure and will make appropriate changes. process of revising  !

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Following the observation of flow testing of the upstream flow orifice i

.. for Unit 2 B Train Component. Cooling Water (CCW) Motor Nos. 2-1203-P4-  !

l 002-M01, 2-1203-P4-004-M01, and 2-1203-P4-006-M01, the inspectors noted  ;

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that the prerequisite steps verifying: instrument calibration: Nuclear  :

Service Cooling Water (NSCW) normal alignment; and authorization to  !

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install Maintenance and Test Equipment (M&TE): were signed off after the  :

completion of the testing. The licensee's procedural compliance- l

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guidance is to: " Follow steps in sequence...". which is documented in i

Procedure 00054-C. Revision 9. Rules for Performing Procedures,

i paragraph 1.1. The inspectors noted that the technicians had in fact l

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completed the prerequisite ste)s prior to conducting the test but )

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completed the sign off for eac1 prerequisite step after completing the '

test. In addition the inspectors noted that the completed data sheets

did not contain required dates for each of the initialed sign offs. The

! preceding indicates a lack of attention to detail on the part of the

Instrumentation and Controls (I&C) technician performing the tests.

This was discussed with licensee management.

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l c. Conclusions

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The observed surveillance activities were performed satisfactorily.

I Some discrepancies were noted in documentation and procedural

compliance.

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M1.3 Missed TS Surveillance on Containment Penetrations

a. Scope of Insoection (92903)

The inspectors reviewed a licensee identified issue concerning the

design of Unit 1 and 2 containment electrical penetrations for the

personnel and escape air locks. The review included system drawings.

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Enclosure 2

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surveillance requirements, and Licensee Event Report (LER) 50-424/96-11,

Inadequate Containment Electrical Penetration and Missed Surveillance.

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b. Observations and Findinas

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On October 23. 1996, during a review of the airlock lighting

requirements, the licensee identified that several personnel and escape

airlocks essential and normal lighting circuits for both Unit 1 and 2  ;

had not been tested per TS requirements. In addition, the circuits did  ;

not meet design requirements to provide dual overcurrent protection.  !

The licensee subsequently install two fuses in series to the affected

circuits to address potential containment integrity issues and comply  !

with design requirements. The airlock lighting circuits were returned ,

to service on November 14, 1996.

The licensee determined based on a engineering review that Updated Final  !

Safety Analysis Report (UFSAR) Table 16.3-5. Ccntainment Penetration

Conductor Overcurrent Protection Devices and Isolation Devices for Class  ;

IE to Non-Class 1E Feeds, did not list all reqeired lighting circuit l

breakers for surveillance testing. Since the original design was ,

instalied, the surveillance testing for the penet. ration circuit breakers  ;

had not been performed. The licensee determined that the cause of the

event was a failure to adequately document all airlock lighting circuits

as containment electrical penetration circuits requiring surveillance  :

testing. In addition, the licensee determined that engineering failed

to properly design and install circuits with dual overcurrent protection i

during the original )lant construction. The subsequent installation of l

the fuses in the lig1 ting circuit addressed the dual overcurrent  !

3rotection issues and alleviated the need to incorporate circuit  !

3reakers into the existing surveillance testing since fuses are not j

required to be tested. l

The licensee issued LER 50-424/96-011. on November 22, 1996. Licensee

actions included a commitment to revise the UFSAR Table 16.3-5 to

reflect fuses being used as primary and backup circuit protection and to

review other airlock containment penetration power circuits for similar

design issues. The inspectors verified the licensee's corrective

actions as part of this LER. Actions were taken as stated.

c. Conclusions

The inspectors concluded that the licensee failed to perform required

testing of circuit breakers per TS requirement 4.8.4.1. Electrical

Equipment Protection Devices, at least once per 18 months since initial

startup. However consistent with Section VII of the NRC Enforcement

l Policy this was identified as Non-Cited Violation (NCV) 50-424,

425/96-12-01. Failure to Perform Containment Penetration Circuit Breaker

l Surveillances.

i

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! Enclosure 2

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!

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The inspectors noted that the licensee's electrical engineer did a good

job during the systems design review in identifying circuits not tested

as part of the required surveillance program. This was a good example

of attention to detail. ,

M1.4 Foreion Material Exclusion (FME)

a. Insoection Scooe (62707)

Generic Letter 89-13. Service Water System Problems Affecting Safety-

Related Equipment, was first implemented for the 1990. Unit 2 fall

outage. Heat exchangers and motor / lube oil coolers were tested or

inspected during refueling outages for any adverse fouling, corrosion,

structural damage, and debris. A deficiency card (DC) was written in

September 1994 due to elevated lube oil temperatures for a Unit 2

Centrifugal Charging Pump (CCP) train B lube oil cooler. The

investigation indicated that the flow orifice was blocked by a small

particle of concrete with a piece of aggregate attached. On December

27, 1994, a DC was written to document a piece of aluminum lagging

material (approximately 1 ftz) that had fallen into the Unit 1 NSCW

tower basin. In January 1995, on Unit 2. two other instances occurred

that indicated debris was possibly blocking flow orifices in some of the

motor coolers. During the fourth Unit 2 refueling outage in March 1995,

considerably more debris was discovered during scheduled inspections of

the containment coolers. On August 18. 1995, during the performance of

o)erator rounds, an operator noted that the temperature was 4 F higher

tlan normal on the Unit 1 Train B CCP, On August 26, 1995, maintenance

and engineering personnel measured a low flow condition through the CCP

lube oil cooler. NRC Inspection Report (IR) 50-424.425/95-21. dated

October 13, 1995, identified this issue as an Unresolved Item. NRC IR

50-424.425/95-27 dated December 1. 1995, closed the Unresolved Item for

NSCW debris and opened a Severity Level IV violation. This issue is

further discussed in NRC irs 50-424.425/96-02: 50-424.425/96-09: 50-424,

425/96-10: and 50-424.425/96-11.

To evaluate the FME program at Vogtle in general and the debris in the

NSCW system in particular, the inspectors reviewed procedures, observed

flow testing in progress, interviewed licensee personnel and examined

selected records

b. Observations and Findinas

The licensee established a NSCW debris data base compiled from records

starting September 1992. This data base is composed of 63 records

representing 63 occurrences when debris was identified in the NSCW

l system. The items found in the system include but are not limited to:

l- concrete, sand and aggregate: assorted metal items including expanded

metal, various fasteners, assorted wire, a tapered drift pin: plastic,

including pieces of a beeper, a pipe cap, ball point pen silicon plug.

,

and tie wraps: an AA battery: pieces of Colmonoy wear surfaces of the

'

Enclosure 2

l

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12

l

! NSCW pumps: and other assorted trash. The licensee attributes the

I

debris intrusion into the NSCW system to the following: construction

debris not removed by pre-operational flushes: spalling concrete debris ,

from NSCW cooling tower and basin: debris that was improperly or

inadvertently washed, swept, blown or dropped into unprotected NSCW

cooling tower basins and pump wells; and degrading Colmonoy coating on

sleeves and wear ring surfaces of the NSCW pumps.

To address the existing debris and new debris ingress into the NSCW

system, the licensee has taken the following actions: steel plates have

been installed over the Unit 1 and 2 pump well openings to prevent

l foreign material from entering the basins and pump shaft wells: kick

i plates were installed and screens were installed / repaired on the basins

in both units pump rooms; a diving service was contracted to inspect a

,

representative sam)le of the Unit 1 and 2 tower basin walls to inspect i

the integrity of tie suction screens, and inspect and vacuum debris:

!

flow testing on all Unit 1 and 2 safety-related NSCW small diameter

, motor / lube oil coolers is ongoing and is expected to continue on a

'

monthly basis: the scope was expanded for Generic Letter 89-13 testing

and inspection during the Unit 1 sixth refueling outage; the removal of ,

orifices and flushing of lines and/or visual inspection of lines serving l

l critical components: the Colmonoy coating on NSCW pump sleeves and wear l

rings have been repaired on the Unit 1 Jumps and is expected to be

completed by September 1,1997 for the Jnit 2 pumps: and a design change i

has been proposed but not yet approved to provide strainers for all Unit i

1 and 2 safety-related NSCW small diameter motor / lube oil coolers.  !

c. Conclusions )

l

The licensee's arogram continues to identify and remove debris from the i

NSCW system. T1e licensee's plant modifications and the FME program

l should prevent new ingress of debris into the NSCW system (with the

exception of spalling concrete from the NSCW cooling towers and basins).

At present, the monthly flow testing is identifying debris already in

the NSCW system, when it migrates to the small diameter flow orifices.

Appro)riately sized strainers have the potential of reducing the need

for t1e current level of flow testing.

M1.5 Reolacement of Valve 1-1405-U4-011

a. Insoection Scooe (62703) i

( The inspectors observed work and work activities associated with the

replacement of valve 1-1405-U4-011. These activities included

implementation of a freeze seal, removal of valve 1-1405-U4-011. pipe ,

fitting, welding, and termination of the freeze seal. i

l

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Enclosure 2

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- _ _ . _ . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ . _

l . . $

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b. Observations and Findinas

As reported in NRC.IR 50-424.425/96-09, several examples were noted l;

where procedural personnel safety precautions were not followed during

the a> plication of a freeze seal associated with the repair to valve 2- i

1901- J4-144. In addition, a number of unsu) ported divergences were  ;

noted, between NRC Technical Guidance and t1e implementation of the i

freeze seals. The licensee has revised the freeze seal procedure to  !

appropriately. address the previously identified unsupported divergences  ;

from NRC Technical Guidance for freeze seals. The freeze seal was  :

implemented in compliance with all personnel safety and technical  ;

requirements of the freeze seal procedure consistent with NRC Guidance.  :

Welding was accomplished by a properly qualified welder using properly

certified welding filler material in accordance with a properly

qualified welding procedure specification.

.

c. Conclusien.ji

!

Maintenance activities were completed thoroughly and professionally, in  !

accordance with procedures. ,

til.6 Motor Control Center (MCC) Door Latches

a. Insoection Scooe (62707)

i

As identified in NRC IR 50-424.425/96-09, a significant number of MCC

panel door closure " dogs" or latches were not secured. The licensee >

stated that a REA 96-VAA639 had been opened to address this issue.

Completed.REA 96-VAA639. dated August 7. 1996, indicated that no data  :

had been found to support the position that impact loads from unlatched

or partially latched doors would not adversely affect devices that would i

chatter. Further, the seismic report indicated that the MCCs were  :

tested with all latches secured, therefore the cabinets, with some l'

latches not fully secure are not within the envelope of the seismic

qualification.  !

>

REA 96-VAA639 indicated that duct tape was an acceptable temporary l

closure mechanism for broken latches as it was used at the testing i

facility during test to secure wiring, flexible conduits, air lines, and  !

'

other components.

i

After determining that unsecured MCC panel doors were outside of-the i

envelope of the seismic qualification for MCCs. the licensee's .

corrective action, concerning the findings of. REA 96-VAA639. consisted  ;

of a walkdown inspection of all MCCs to assure that all doors on all

MCCs were properly secured. The licensee stated that this walkdown

inspection was performed but undocumented. j

i

Enclosure 2  ;

-. . .- - . .

. _ _ _ - ~ - . - - . . . - - - . . - . . - - - _ - - - - - - . - - . - . . -

.- - .

l . <

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14

!

!

b. Observations and Findinos

To determine the efficacy of the licensee's corrective actions related  !

to MCC latches, the inspectors on December 5. 1996, started to conduct a

walkdown inspection of a re)resentative number of MCCs. examining the

security of the latches. T1e inspectors, accompanied by a licensee

!

representative, examined safety related 1E 480 volt MCCs 2-1805-S3-2BBA i

and 2-1805-S3-2ABA. The inspectors identified seven latches not secured >

on MCC 2-1805-S3-2ABA and 34 latches not secured on MCC 2-1805-S3-2BBA. .

One unsecured latch was identified with a work order tag indicating that

I

the latch was broken. but the door was not secured with duct tape as

recommended by REA 96-VAA639. Both latches on a number of doors were

,

not secured. In view of the number of unsecured latches found on the

l first two MCCs examined, the inspectors discontinued their inspection

and the licensee documented the discrepancies in DC 2-96-310.

t

c. Conclusions

l

The licensee's corrective action to assure that MCC Janel doors were

properly secured, was ineffective. as evidenced by .le unsecured latches

identified by the inspectors on MCC Nos. 2-1805-S3-2BBA and

2-1805-S3-2ABA after the completion of the licensee's walkdown. Failure

to establish effective measures to assure that nonconformances are 1

3romptly identified and corrected is a violation of Title Ten Code of '

ederal Regulations Part 50. Appendix B. Criterion XVI. This is

identified as Violation (VIO) 50-424.425/96-12-02. Failure To Take

Effective Corrective Actions To Assure MCC Door Latches Are Properly

Secured. i

1

M1.7 Maintenance Audits j

a. Insoection Scooe (62707) l

The inspectors reviewed 1996 audits in the maintenance area. The scope

of these audits included: NSCW pump refurbishment procedure control,

maintenance program. Performance Team activities, and maintenance.

b. Observations and Findinas

Audit findings included weaknesses related to: safety related work 3

performed by a contractor not on the safety related approved vendors l

list, bolts over torqued. lockwire not installed, receipt ins)ection not

performed. American Society of Mechanical Engineering (ASME) 3 oiler and

Pressure Vessel Code Section XI repair not implemented, improperly

written purchase order, color coding of grinding wheels for specific

material application, awareness of hold points, training and

l

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l Enclosure 2

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15

s. qualification of maintenance planners, excessive overtime

authorizations, procedure revision process, lifting rigging color

coding, improper / lack of restraint of materials and equipment to prevent

i

damage to operable safety related equipment. Appropriate corrective

, actions were taken or planned.

1

c. Conclusions

!

'

.

The area of maintenance was subjected to independent audits, with

appropriate action taken for identified weaknesses.

s <

M7 Quality Assurance in Maintenance Activities

j M7.1 Hydroaen Recombiner Failed Surveillance

'

a. Insoection Scooe (61726) (40500)

i

'

,

The inspectors reviewed the licensee's investigation and troubleshooting l

efforts regarding a failed surveillance on the Unit 2 train B hydrogen '

4 recombiner The inspectors reviewed the MWO associated with the ,

,

corrective work order, the DC generated, and Procedure 14970-2, Hydrogen l

l Recombiner Functional Test. The inspectors also discussed the root

4

cause determination effort with the system maintenance team leader and

a maintenance manager. 1

i

b, Observations and Findinas

)

j j

i On November 28. 1996, the Unit 2 hydrogen recombiner train B failed to

i successfully pass the surveillance criteria of procedure 14970-2.

-

Maintenance determined that the failure was a result of a transducer

! filter that prevented the recombiner from reaching the required kilowatt

output specified in the surveillance. Maintenance was able to identify
and replace the failed component through effective root cause and

troubleshooting technicues. Maintenance activities observed were

properly documented anc well controlled.

.

After completion of corrective maintenance activities operations

'

performed the surveillance again with satisfactory results.

.

c. Conclusions

,

The inspectors concluded that, for this example of surveillance / ,

maintenance root cause and troubleshooting effort, the licensee

'

]

o effectively identified and resolved issues affecting plant operations.

, i

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Enclosure 2

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M8 Hiscellaneous Maintenance Issues (62700) (61726) (92902)

M8.1 Remote Shutdown Panel

a. Insoection Scooe (62700) (61726)

l

The inspectors reviewed the licensee's maintenance and testing program

for the Remote Shutdown Panels (RSPs) to evaluate the adequacy of the

licensee's program for maintenance and routine testing of this

equipment. Additionally, the inspectors reviewed post-modification

testing following implementation of design changes to components

controlled from the RSPs to determine adequacy of testing.

b. Observation and Findinas

Instrumentation and controls to achieve and maintain hot / cold shutdown

as required by 10 CFR 50 Ap)endix R are provided by separate RSPs for

each unit and supplemented )y manual actions at local component control

stations. The inspectors determined that the RSPs for both units were

installed and functionally tested prior to initial plant o)eration.

Systems and components required to satisfy the alternate slutdown 1

capability are described in the licensee's UFSAR Section 7.4.3. Safe

Shutdown From Outside the Control Room. TS recuirements are described

in Sections 3.3.3.5.1, 3.3.3.5.2. 4.3.3.5.1 anc 4.3.3.5.2.

The inspectors reviewed a listing of plant modifications issued by the i

licensee for systems controlled from the RSPs. Five completed

'

modifications which could have potentially affected operability of RSP

instrumentation or the ability to control components from the RSPs were ,

selected for review. DCP records for those completed modifications were i

reviewed by the inspectors to determine actual scope of modification

activities and adequacy of required post modification testing. The

inspectors determined that for four of the five selected DCPs. post

modification testing of RSP controls was not required since the scope of

modification activities could not have affected the ability to control

components from the RSPs. The remaining DCP appeared to potentially l

affect RSP controls. This modification was DCP 88-V1N0076, which .

deleted the automatic closure interlock associated with Residual Heat  !

Removal (RHR) Hot Leg Isolation Valves 1HV-8701A 1HV-87018, 1HV-8702A.

and 1HV-8702B. The inspectors verified that post modification testing

for this DCP had included functional testing of those RHR valves from

the Unit 1 RSPs. No problems were identified during this review.

The inspectors reviewed GPC Procedures, 14445-1. Rev. 4. Remote Shutdown

Monitoring Instrumentation Channel Check. Unit 1. and 14445-2. Rev. 2.

Remote Shutdown Monitoring Instrumentation Channel Check, Unit 2, which

are performed by the licensee on a monthly basis. The inspectors also

reviewed GPC Procedures. 14710-1 Rev.18. Remote Shutdown Panel

Transfer Switch and Control Circuit 18 Month Surveillance Test. Unit 1.

and 14710-2 Rev. 17. Remote Shutdown Panel Transfer Switch and Control

Enclosure 2

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17

-Circuit 18 Month Surveillance Test. Unit 2. which are used by the

licensee to periodically verify operability of the transfer switches and

functional controls located on the RSPs and at local control stations.

These two test procedures are performed every refueling outage. The

inspectors reviewed each of these surveillance procedures and verified

that all instrumentation and controls surveillance requirements from

TS 4.3.3.5.1 and 4.3.3.5.2 were satisfied. The inspectors also reviewed

the data package associated with the most recent performance of each

procedure. Additionally. the inspectors verified that instrumentation

located on the RSP was included in the licensee's instrumentation

calibration program. During this review the inspectors determined that

all necessary instrumentation located on the RSP or locally is routinely

checked and all required functional controls are adequately tested.

During this review, the inspectors noted that the licensee had

previously identified various control switches located on the.RSPs or

locally that had not been included under the scope of GPC Procedures

14710-1 and 14710-2. The inspectors reviewed DC 1-95-129 which

documented the licensee's disposition of this 3roblem. DC 1-95-129 '

'

included a list of s)ecific control switches w11ch should have been

routinely tested. T1e licensee evaluated this problem as not affecting

the operability of required safe shutdown equipment. This determination

was based on the fact that none of the listed control switches were ,

associated with equipment required by TS 3.3.3.5.2. The inspectors

noted that the licensee subsequently revised both procedures to require

functional testing of those control switches as the result of this -

issue. The inspectors review of the licensee's resolution of this issue

identified no concerns.

The inspectors performed a walkdown on the Unit 1 Train A and Train B

RSPs. Unit 1 TDAFW Control Panel. Unit 2 Train A and Train B RSPs, along

with selected local controls for the diesel generators and other

components located on the safety related electrical switchgear. The

RSPs are located in separate locked rooms with access restricted. No

loose wires, damaged components, or evidence of corrosion were observed

' during this walkdown. Material condition inside and outside of the

panels was acceptable. However, several housekeeping deficiencies were

identified during the walkdown. A section of loose metal deck ) late,

sound powered phone headset and cable, a used 100 VAC light bul) with

bulb cage, and several spare 110 VAC light bulbs were noted inside the

RSPs. The section of deck plate was approximately 8 inches by 15 inches

in size and had all four bolts missing. The inspectors identified these  ;

deficiencies to licensee management and the deficiencies were  !

immediately corrected. The licensee also requested that corporate  !

engineering evaluate any seismic effects of the loose material on l

operability of the RSPs. The licensee's evaluation was documented under l

REA VE-3100. The inspectors reviewed the licensee's evaluation and i

determined that the operability of the RSPs was not effected by the  ;

i

Enclosure 2  ;

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presence of the loose material. However, better housekeeping practices I

following maintenance could have prevented these deficiencies. The

presence of this material within infrequently inspected panels  ;

represents a weakness. j

c. Conclusions

The inspectors concluded that the licensee has maintained the alternate  :

safe shutdown equipment in a satisfactory manner, and that the

licensee's program for routine testing of RSP instrumentation and

controls is adequate. The inspectors did not identify any examples of

inadequate post modification testing following licensee modification

activities that could have had a negative impact on any control

functions of equipment operated from the RSP. A weakness was identified i

associated with poor housekeeping practices following maintenance within l

infrequently inspected panels.

M8.2 Balance of Plant '(BOP) Eauioment Reliability I

a. Insoection Scone (62700)

l

The inspectors reviewed a listing of unplanned capability loss data for  !

both units along with other plant operating history provided by the

licensee to identify potential equipment reliability problems that might

exist. This listing was evaluated to identify unplanned )ower  ;

reductions and trips associated with equipment failures tlat might be

associated with maintenance activities for Balance of Plant (BOP)

equipment that was not being conducted in a manner that results in the

reliable and safe operation of the plant. The purpose for this review

was to identify equipment that has a history of recurring problems or

whose failure resulted in a safety system actuation or plant shutdown or

resulted in reduced system capability and determine if the problem might

have been caused by inadequate maintenance.

i

b. Observation and Findinas

The inspectors reviewed plant operating history for 1994. 1995. and 1996

and noted that the licensee had experienced some plant trias and

unplanned )ower reductions due to degraded performance of 30P equi) ment.

However.. t1e ins)ectors did not identify any trends associated wit 1

these failures w11ch might indicate that tha equipment reliability

problems resulted from inadequate maintena ce.

c. Conclusions

The licensee has experienced some trips or unplanned power reductions

due to degraded performance of B0P equipment. The ins)ectors did not

identify any adverse trends that might indicate that t1e equipment

reliability problems resulted from inadequate maintenance.

Enclosure 2

)

a

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!

M8.3 Reactor Trio Breakers

a. Insoection Scooe (62700) {

f

The inspectors reviewed the status of licensee action to address NRC l

Information Notice (IN) 96-44. IN 96-44 was issued to alert licensees  !

to the possible failure of reactor trip breakers (RTBs) to properly  !

function because of cracking or breakage of the secondary disconnecting i

contact assemblies. During RTB testing at another nuclear facility. a  !

licensee found that one of the bypass breakers failed to open l

electrically when the local shunt trip push button was depressed.  !'

During subsequent inspection of the breaker, a small piece of the

assembly was found lodged in the secondary disconnecting contact

assembly which may have prevented reliable electrical continuity for

the local shunt trip push button circuitry for the manual trip function. j

i

The disconnect assemblies provide circuit connections between the i

control and monitoring devices on the breaker and external control  !

circuits. The housing of the electrical contacts in the disconnect  !

assemblies consists of a phenolic material. The assemblies are made of l'

a molded, cellulose-filled, phenolic material which has low impact

strength and may be highly susceptible to chipping or cracking.

Breakage or partial cracking of these assemblies may prevent the breaker

from performing its design function or other secondary functions l

provided by the status of the breaker position,

b. Observation and Findinas

i

The inspectors reviewed Operating Experience Program Evaluation. OER-ID:  ;

IN 96-44, which documented the licensee's disposition of this issue,  !

The RTBs installed are Westinghouse DS-416 type breakers which are the  !

same type which were in use at the other nuclear facility which had been j

the subject of IN 96-44. As the result of the licensee's review of this  !

issue the licensee determined that the PM procedure used for routine RTB l

inspection and maintenance required revision. The licensee determined  !

that maximum torque values specified in the vendor manual might prevent i

overtorquing and resultant cracking of the disconnect assemblies.  ;

Required procedure changes included specific ins)ection of the secondary j

disconnecting contact assembly for cracking of t1e phenolic material and j

incorporation of the torque values specified in the vendor manual into  ;

the licensee's procedure. l

The inspectors reviewed PM Procedure. 27765-C Westinghouse Type DS-416

Circuit Breaker Maintenance, and verified that Step 4.9 includes a i

requirement to verify that the secondary contact assembly is free of l

cracks during this periodic inspection. Additionally, Step 4.9 requires ,

that whenever those assemblies are replaced torquing requirements from i

Westinghouse Vendor Manual AX6AT01-10005 would be followed. The  !

'

inspectors were informed that the breaker insSection under the new

revised procedure had been performed during tie recent Unit 2 refueling

Enclosure 2

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outage and that no abnormalities were identified during those j

inspections. The breaker inspections for the Unit 1 breakers are i

scheduled for the upcoming refueling outage during September 1997.

l

c. Conclusions

!

The licensee has adequately addressed IN 96-44.

M8.4 (Closed) EEI 50-424/96-11-03: Unit 1 SIP Train B Loss of Function

An Enforcement Conference (EA 96-479) was held in the Region II office

on December 19, 1996 to discuss the issues identified in Escalated  !

Enforcement Item (EEI) 50-424/96-11-03. Unit 1 SIP Train B Loss of  ;

Function. (Refer to Section M3.1 of irs 50-424.425/96-11.) As a result  !

of the conference, the EEI was closed and two violations were  !

identified: VIO 50-424/96-479-01013. Inoperable IB Safety Injection Pump j

(SIP) for Period of at least 09/30/91 through 10/23/96 due to Inadequate  ;

Cooling Flow to Its Motor Coolers, and VIO 50-424.425/96-479-01023. *

Inadequate Procedural Guidance to Assure Correct Installation of Motor ,

Cooler Gaskets and Plenums for Safety-Related Equipment. The Notices of  !

Violation were issued as Enclosure 1 to the NRC letter of December 31. I

1996 summarizing the proceedings of the meeting.

III. Enaineerina

E7 Quality Assurance in Engineering Activities

t

E7.1 NOUE Problem Identification and Corrective Actions )

!

a, Insoection Scone (37551) l

As a result of a Notification of unusual Event (NOUE) that occurred on

November 15. the inspectors reviewed the licensee's engineering root  !

cause/ problem identification and corrective action effort. This review

included assessment of the engineering process into the root cause of

the event and an evaluation of the adequacy of engineering support

personnel activities.

b. Observations and Findinas

As a result of a NOUE declared on October 25. (reference IR 50-424,

425/96-11. section 01.7) engineering personnel were requested to support

annunciator troubleshooting efforts. Engineering. I&C. and maintenance

personnel determined that a blown fuse in a power su) ply cabinet caused

the loss of annunciator function. However, on Novem)er 15. a second

i similar event took place (reference section 01.2) as a result of the

l

same maintenance activity (i.e. ~ fixing a light socket. but on a

different annunciator pgnel). Investigation into this event also

determined that the same fuse blew. but that an undetected system ground

,

was present. Engineering personnel were able to identify a system

! Enclosure 2

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.- .-..-.. - . . . . . - .- - - - - - - . - . - - --.

,

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l

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21

f

ground even though the complexity of the annunciator panel electrical  !

system made it difficult to troubleshoot. During the process of the l

root cause investigation engineering personnel made manogement aware of  !

potential issues and contributors to the event as they were determined.  ;

As a result of the second event, the licensee developed additional

I corrective actions that included de-energizing the affected annunciator-

I

light box for future maintenance activities on light sockets. In  ;

addition, the licensee plans.to com)lete a review of- system electrical i

drawings for other potential contri)utors to the event. j

c. Conclusions l

1

l The inspectors concluded that engineering personnel did an effective job' l

in determining the underlying root cause as a result of the second (

event. Engineering personnel effectively-supported operations, i

maintenance, and I&C troubleshooting efforts. Engineering )ersonnel  :

involved the proper level of management commensurate with tie event. l

The inspectors also concluded that the licensee's planned corrective

actions as a result of the second event, to address future maintenance i

activities on annunciator light boxes was appropriate.  ;

1

E8 Miscellaneous Engineering Issues (92903) j

i

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E8.1 (Closed) VIO 50-424.425/95-27-04: Partially Obstructed NSCW System Flow l

Orifice Corrective Actions inadequate To Preclude Repetition  !

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Violation 50-424, 425/95-27-04 documents the inadequate corrective

actions taken to prevent repetition of NSCW flow reduction events. The

re)ly to the violation itemizes additional corrective actions to be

tacen. The inspectors * review of this issue and the associated

corrective actions is documented in section M1.4 of this report. The

. inspectors determined that the corrective actions identified were

completed. therefore VIO 50-424.425/95-27-04 is closed.

E8.2 (Closed) LER 50-424/96-011: Inadequate Containment. Electrical

Penetration and Missed Surveillance.

This issue was discussed in this re) ort as part of Section M1.3. No new

issues were revealed by the LER. T11s LER is closed.

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Enclosure 2

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IV. Plant Support

R8 Miscellaneous Radiological Protection and Chemistry (RP&C) Issues  !

(92700)

R8.1 (Closed) LER 50-424/96-008: Secondary Water Chemistry Tests not

Performed Prior to Power Ascension. .

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The inspectors reviewed the circumstances associated with not performing

secondary water chemistry tests for dose equivalent iodine-131 prior to ,

power ascension as required by TS 4.7.1.4. as well as the following l

Chemistry procedures: )

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30025-C. Rev. 24. Periodic Analysis Scheduling Program

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30090-C. Rev.17. Chemistry Technical Specification '

Surveillance Performance Coordination  ;

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35110-C. Rev. 22. Chemistry Control of the Reactor Coolant i

System

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35210-C. Rev. 14 Chemistry Control of the Steam Generators

On June 14. 1996, the licensee identified a procedural weakness when it l

discovered that specific chemistry surveillance tasks were not being ,

performed prior to mode 4 entry following a refueling outage. l

Specifically, the licensee identified that TS required surveillances for

specific activities were not done prior to power ascension upon the

completion of the 2R4 refueling outage in March 1995 and the IR6

refueling outage in April 1996. The licensee feels that it is likely

that this condition occurred following outages previous to these two

referenced outages. TS 3.7.1.4 requires the specific activity of the

secondary coolant system to be less than or equal to 0.1 microcurie per i

gram dose equivalent iodine-131 whenever the unit is in modes 1, 2. 3. i

or 4. The failure to complete the TS required surveillances prior to

entry into mode 4 is a violation of TS 3.7.1.4. The cause of the

failure was identified by the licensee as procedural inadequacy in that

the procedures did not specifically state that the surveillances were

required to be performed prior to entry into mode 4.

The required surveillances were made shortly after entering mode 4 in I

both cases and confirmed that the specific activity in the secondary

system was within the required TS limits. Therefore, there was no

adverse effect on plant safety nor on the health and safety of the

public as a result of these events.  ;

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The inspectors verified that the licensee revised the above-referenced

procedures to specify that the required sampling be completed prior to

entry into the applicable mode. l

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The inspectors concluded that the failure to complete the secondary

system sampling prior to entry into mode 4 violated the requirements of

TS 3/4.7.1.4. However, consistent with Section VII of the NRC

Enforcement Policy, this is identified as NCV 50-424.425/96-12-03.

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Failure to Complete Required Sampling Prior to Entering Mode 4. Based

upon the inspector's review, this LER is closed.

P1 Conduct of EP Activities

Pl.1 Conduct of 1996 Full Scale Emeroency Preparedness (EP) Exercise (71750)

On November 20. 1996 the licensee conducted a full scale EP exercise.

Participants in the emergency exercise included state and county

representatives from Georgia and South Carolina, and the resident

inspectors. The inspectors observed and Jartici)ated in the exercise

from the Emergency Operating Facility (E02). Tec1nical Su) port Center

(TSC). Operations Support Center (OSC), and simulator. T1e results of

the EP exercise are documented in a separate report. IR

50-424.425/96-13.

The resident inspectors did not identify any specific concerns.

F5 Fire Protection Staff Training and Qualification

F5.1 Announced Fire Drill (71750)

On December 10 and 11. '396, the inspectors observed an announced fire

drill. The scenario was a truck fire located at the A 1 pumps near the

receiving warehouse. This location is outside of the mtected area.

The fire team response was timely. Equipment was readily available and

in adequate condition. The self-contained air breathing ap)aratuses

were suffit.iantly charged and in good working condition. T1e fire team

established good communications with the control room and security.

Minor issues identified by the inspectors were forwarded to the licensee

and adequately addressed.

Overall, the inspectors concluded that the drill was well controlled and

met the performance criteria established by the licensee.

V. Manaaement Meetinas and Other Areas

X1 Exit Meeting Summary

The inspectors ) resented the inspection results to members of licensee

management at t1e conclusion of the inspection on December 23, 1996.

The licensee acknowledged the findings presented.

The inspectors asked the licensee whether any materials examined during

the inspection should be considered proprietary. No proprietary

information was identified.

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After the conclusion of one of the regional reactor inspector's exit

performed on December 6. the licensee was notified by telephone at

approximately 2:30 p.m. December 9.1996, that the issue relating to -i

unsecured MCC door latches, would be the subject of a violation. i

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X2 Pre Decisional Enforcement Conference Summary l

On December 19. 1996, a pre-decisional enforcement conference was held  ;

at the NRC Region II office to discuss potential enforcement issues l

' identified in IR 50-424.425/96-11. Issues discussed primarily focused j

on emergency core cooling system pump motor cooler maintenance  :

activities and the operability of the Unit 1 safety injection pump train. i

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B since September 30, 1991.

X3 Review of Final Safety Analysis Report  !

A recent discovery of a licensee operating its facility in a manner l

contrary to the Updated Final Safety Analysis Report (UFSAR) description

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highlighted the need for a special focused review that compares plant l

practices, procedures and/or parameters to the UFSAR descriptions.

While )erforming the inspections discussed in this report, it was noted

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that tie licensee had determined that the UFSAR Table 16.3-5.

Containment Penetration Conductor Overcurrent Protection Devices and

Isolation Devices for Class 1E to Non-Class 1E Feeds, did not list all

required lighting circuit breakers for surveillance testing. This is

discussed in section M1.3 of this report. The ins)ectors reviewed the ,

applicable portions of the UFSAR that related to t7e areas inspected.

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X4 Hanagement Meeting Summary

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PARTIAL LIST OF PERSONS CONTACTED j

Licensee

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J. Beasley. Nuclear Plant General Manager

J. Gasser. Plant Operations Assistant General Manager

S. Chesnut. Manager Operations

P. Rushton. Plant Support Assistant General Manager  ;

K. Holmes. Manager Maintenance  !

W. Burmeister. Manger Engineering Support

B. Brown. Manager Emergency Preparedness and Training

M. Sheibani. Nuclear Safety and Compliance Supervisor

C. Stinespring. Manager Plant Administration

C. Tippins. Jr.. Nuclear Specialist I l

Enclosure 2 i

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INSPFCTION PROCEDURES USED

l IP 37551: Onsite Engineering

l IP 40500: Effectiveness of Licensee Controls In Identifying. Resolving, and

l Preventing Problems i

IP 61726: Surveillance Observations

IP 62700: Maintenance Implementation

, IP 62703: Maintenance Observations

IP 62707: Maintenance Observations

IP 71707: Plant Operations

IP 71714: Cold Weather Preparations

l IP 71750: Plant Support Activities '

IP 92700.: Onsite Notification of Written Reports of Non-routine Events At

Power Reactor Facilities

IP 92902: Followup - Maintenance

IP 92903: Followup - Engineering

IP 93702: Prompt Onsite Response To Events At Operating Power Reactors

REFERENCED PROCEDURES AND DRAWINGS

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GPC PM Procedure 27765-C. Westinghouse Type DS-416 Circuit Breaker

Maintenance

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GPC Procedure 14445-1. Rev. 4. Remote Shutdown Monitoring

Instrumentation Channel Check Unit 1

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GPC Procedure 14445-2. Rev. 2. Remote Shutdown Monitoring

Instrumentation Channel Check. Unit 2 l

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GPC Procedure 14710-1 Rev. 19. Remote Shutdown Panel Transfer Switch  !

and Control Circuit 18 Month Surveillance Test. Unit 1

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GPC Procedure 14710-2. Rev. 17. Remote Shutdown Panel Transfer Switch  !

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and Control Circuit 18 Month Surveillance Test. Unit 2

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DCP 88-V1N0076. Deletion of Automatic Closure Interlock for RHR Hot Leg

Isolation Valves

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DCP 90-V2N0029. AFW to S/G 3 Testing Provision DCP 87-V1E0242. RHR Hot

Leg Isolation Valves RCS Pressure Open Permissive Interlock Setpoint

Change

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DCP 91-V2N0142. Change Handswitch Logic on Power Lockout Handswitch on

Main Control Board

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DCP 92-VIN 0058. NSCW Reliability Upgrade  ;

ITEMS OPENED. CLOSED, AND DISCUSSED

Opened l

50-424. 425/96-12-01 NCV Failure to Perform Containment Penetration

Circuit Breaker Surveillances (Section M1.3)

50-424. 425/96-12-02 VIO Failure to Take Effective Corrective Actions to

Assure MCC Door Latches Are Properly Secured

(Section M1.6)

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50-424, 425/96-12-03 NCV Failure to Complete Required Sampling Prior to

Entering Mode 4 (Section R8.1)

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50-424/96-479-01013 VIO Inoperable IB Safety Injection Pum) (SIP) for

! Period of at least 09/30/91 througl 10/23/96 due

l to Inadequate Cooling Flow to Its Motor Coolers

l (Section M8.4)

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50-424,425/96-479-01023 VIO Inadequate Procedural Guidance to Assure Correct

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Installation of Motor Cooler Gaskets and Plenums j

for Safety-Related Equipment (Section M8.4) l

50-424, 425/96-12-01 NCV Failure to Perform Containment Penetration

Circuit Breaker Surveillances (Section M1.3)

50-424, 425/95-27-04 VIO Partially Obstructed NSCW System Flow Orifice

Corrective Actions Inadequate to Preclude

Repetition (Section E8.1)

50-424/96-011 LER Inadequate Containment Electrical Penetration

and Missed Surveillance (Section E8.2).

50-424/96-008 LER Secondary Water Chemistry Tests Not Performed

Prior to Power Ascension (Section R8.1)

50-424. 425/96-12-03 NCV Failure to Complete Required Sampling Prior to

Entering Mode 4 (Section R8.1)

50-424/96-11-03 EEI Unit 1 Safety Injection Pump Train B Loss of

Function (Sectin M8.4)

LIST OF ACRONYMS USED

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AFW - Auxiliary Feedwater

ASME - American Society of Mechanical Engineering

l BOP - Balance of Plant

CCP - Centrifugal Charging Pump

CCW - Component Cooling Water

CFR - Code of Federal Regulations

DC - Deficiency Card

DCP - Design Change Package

DG - Diesel Generator

EOF - Emergency Operating Facility

EP - Emergency Preparedness

FME - Foreign Material Exclusion

ESF - Engineered Safety Feature 4

2

ft - square feet

GPC - Georgia Power Company

I&C - Instrumentation and Controls ,

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IN - Information Notice

IR - Inspection Report

IP - Inspection Procedure

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LER - Licensee Event Report

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M&TE - Maintenance and Test Equipment

MCC - Motor Control Center

MWO - Maintenance Work Order '

MWt - Megawatt Thermal

NCV - Non-Cited Violation

NOUE - Notification of Unusual Event

NPF - Nuclear Power Facility

NRC - Nuclear Regulatory Commission

NSAC - Nuclear Safety and Compliance

NSCW - Nuclear Service Cooling Water  ;

NUREG - Nuclear Regulations

OSC - Operations Support Center

PDR - Public Document Room

PM - Preventive Maintenance

PRB - Plant Review Board

RCS - Reactor Coolant System

REA - Request for Engineering Assistance

RHR - Residual Heat Removal

RP&C - Radiological Protection and Chemistry

RSP - Remote Shutdown Panel

RTB - Reactor Trip Breaker

S/G - Steam Generator

TDAFW - Turbine Driven Auxiliary Feedwater

TS - Technical Specifications

TSC - Technical Support Center ,

UFSAR - Updated Final Safety Analysis Report

VAC - Volts Alternating Current

VEGP - Vogtle Electric Generating Plant

VIO - Violation

1R6 - Unit 1 Sixth Refueling Outage

2R4 - Unit 2 Fourth Refueling Outage

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Enclosure 2

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