Text

Insp Repts 50-424/97-08 & 50-425/97-08 on 970623-27. Deviations Noted.Major Areas Inspected:Qa in Operations, Maint,Engineering & Health Physics
	ML20210N673
Person / Time
Site:	Vogtle
Issue date:	08/14/1997
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	;
Shared Package
ML20210N634	List: ML20210N631; ML20210N652; ML20210N673;
References
	50-424-97-08, 50-424-97-8, 50-425-97-08, 50-425-97-8, NUDOCS 9708260084
	Download: ML20210N673 (26)
	v • d • e

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U. S. NUCLEAR REGULATORY COMMISSION (NRC)

REGION 11

Docket Nos. 50-424 and 50-425

License Nos. NPF-68 and NPF-81

Report No:

50-424/97-08, 50-425/97-08

Licensee:

Southern Nuclear Operating Company, Inc.

Facility:

Vogtle Electric Generating Plant (VEGP) Units 1 and 2

Location:

7821 River Road

Waynesboro, GA 30830

Dates:

June 23 through 27, 1997

Inspectors:

T.Ross, Team Leader

R. Carrion, Project Engineer

N. Merriweather, Reactor Inspector

M. Widmann, Resident inspector

Approved by:

P. Skinner, Chief

Reactor Projects Branch 2

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Division of Reactor Projects

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Enclosure 2

9708260084 970814

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EXECUTIVE SUMMARY

Vogtle Electric Generatin Plant Units 1 and 2

NRCInspectionReport50-4h4/97-08.50-425/97-08

This team inspection evaluated implementation of the licensee's programs for

problem identification, trending and corrective action; quality assurance

audits; operating experience review feedback: self-assessments, safety review

committees; and reverification of the Updated Safety Analysis Report (UFSAR).

Quality Assurance In Ooerations Maintenance. Enaineerina. and Health Physicji

Overall. Deficiency Cards (DCs) and Root Cause and Corrective Actions

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(RCCAs) were sufficiently thorough and complete, with appropriate

disposition /causes and adequate corrective actions identified.

However,

the content and level of detail between DCs/RCCAs differed considerably,

reflecting a variation in skill and experience level of responsible

departmental personnel.

(Section 07.1)

Nuclear Safety and Compliance (NSAC) personnel were knowledgeable,

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conscientious, and added considerable cuality to the DC/RCCA process.

However, management expectations regarcing NSAC timeliness for

processing DCs in a prompt and efficient manner were not clearly

communicated.

(Section 07,1)

Backlogs of DCs or Open items (01s) are not trended to evaluate the

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magnitude and associated trends of outstanding corrective actions or

open DCs.

Although DCs are almost always completed by responsible

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departments in a timely manner, corrective action Ols were routinely

rescheduled.

(Section 07.1)

Licensee's trend identification / reporting and departmental self-

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assessment program continues to evolve.

(Section 07.1)

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Event Review Team (ERT) reports and associated RCCAs were of good

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quality and thorough.

Corrective actions developed as a result of ERTs,

and RCCAs, were appropriate for the root causes identified.

In

addition, operability and reportability determinations were appropriate,

where nocessary. (Section 07.2)

Safety Audit Engineering Review (SAER) Program satisfies the

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requirements of the UFSAR and implementing procedures for conducting

quality assurance (QA) audits. Audits were comprehensive and thorough.

Audit Finding Reports (AFRs) and comments were properly addressed in a

timely manner, and completion of corrective actions were followed up.

Findings were adequate to keep licensee management informed of

significant developing problems in the areas audited.

However, the

practice of allowing an extended duration audit could lead to delays in

implementing corrective actions and the conduct of management reviews.

(Section 07.3)

Enclosure 2

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The Health Physics (HP) self-assessment was a comprehensive evaluation

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of major areas of res)onsibility. This self-assessment identified

numerous aspects of t1e HP program for improvement. for which specific

corrective actions have been develo)ed and were being actively tracked

to completion.

Use of experienced iP personnel from outside the plant

as part of the self-assessment team was considered a significant

strength. (Section 07.4.1)

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A Plant Modification and Maintent ice Support (PMMS) department self-

assessment report was thorough and detailed with :.uostantial find'ngs

and recommendations.

Corrective actions were developed and scheduled to

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address all recommendations.

However, the PMMS department failed to

address numerous compliance and process issues identified in the report,

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(Section 07.4.2)

Quarterly Human Performance Review reports were comprehensive. thorougl

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and insightful.

However. it was difficult for the inspectors to

distinguish whether they represented general observations of fact.

conclusive problems, suggestions or spe:ific recommendations.

Many of

the report statements were repetitive with no apparent system for

tracking or dirrositioning them.

Furthermore, many specific comments

regarding the adequacy of certain DC/RCCAs have not been addressed.

The

reports provided good, detailed information, that was not being

ef'ectively utili.vd by the plant. (Section 07.4.3)

Licensee evaluation and corrective actions for two operating experience

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reports issued in 1996 were reviewed and found to be adequate.

The

backlog of industry operating experience reports and NRC Information

Notices v> being maintained at reasonable levels. (Section 07.5)

Independent Safety Engineering Group (ISEG) review activities were

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consistent with UFSAR and procedural requirements, except for leading

ERTs. Assessments performed by ISEG were effective in identifying areas

for improving plant safety. (Sections 07.2 and 07.6)

Safety Review Board (SRB) meetings appeared to be comprehensive and

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routinely identified s)ecific problem areas requiring site and/or

corporate attention.

or each identified problem an SRB open item was

initiated, tracked and usually resolved in a timely manner.

A deviation

was identified for insufficient implementation of all UFSAR commitments

regarding SRB review.

(Section 07.7.2)

Corrective actions in response to v;o.ations and Licensee Event Reports

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were pro)erly implemented in a timely manner.

(Sections 08.1 and M8.1

through 18.5).

Enclosure 2

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Corrective actions to resolve numerous UFSAR discrepancies we.e found to

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be adequate and timely.

The backlog of UFSAR deficiencies was small.

A

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weakness was identified in the UFSAR Review Program in that issues

identified by offsite groups were not formally evaluated for operability

or reportability.

(Section E7.1)

ISEG self-assessment of the UFSAR Accuracy Reverification Program

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results provided good insights as to the causes of the UFSAR

discrepancies and provided several recommendations to management on how

to improve performance and reduce the likelihood of new discrepancies

being introduced.

(Section E7.2)

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Enclosure 2

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Reoort Details

Summary of Plant Status

Unit 1 operated at full power throughout the entire inspection period.

Unit 2 eperated at full power throughout the entire inspection period.

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Doerations

07.

Quality Assurance in Operations-(IP 40500)

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07.1 Problem identification. Resolution. Corrective Action. And Trendina

Proarams (4050N

a.

Insoection Scoce

Ins)ectors examined licensee implementation of onsite programs for

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pro)lem identification, resolution, corrective action, and trending as

established in procedure 00150-C " Deficiency Control." Revision

(Rev.) 23: procedure OC058-C. " Root Cause Determination," Rev. 11;

procedure 00409-C "Open Item / Commitment Tracking," Rev. 12: J.rocedure

80014-C " Handling of Deficiency Cards," Rev.11: and procedure 80016-C.

" Trend Identification And-Reporting " Rev. 2.

Selected Deficiency Cards

(DCs) and applicable root cause corrective action (RCCA) re

recent equipment problems and personnel incidents were eval, arts for

uated to

verify licensee effectiveness in c'escribing problems.1dentifying

cause(s), and initiating corrective actions in accordance with

procedural cuidance.

Plant

Safety and Compliance (NSAC) personnel and supervision rnm the Nuclear

group and responsible departments were

interviewed as necessary. The inspectors also reviewed the Open Item

(01) Commitment Tracking System backlog and history of outstanding

corrective actions, and recent trend reports and departmental self-

assessments of equipment failures and personnel errors.

b.

Observations and F.ndinas

The documentation of 18 completed DCs. some with RCCAs. was reviewed in

detail by the inspectors. These DCs/RCCAs were properly completed with

only a few minor administrative errors and omissions. Also,

reportability issues pursuant to 10 CFR 50.73 were properly reviewed by

the licensee. Most of the reviewed DCs and RCCAs were thorough and

detailed, with appropriate disposition /causes and adequate corrective

actions identified. However, three specif . DCs (discussed below) were

inadequately documented or failed to identify the root cause.

Content

-and level of detail between the DCs/RCCAs differed considerably,

reflecting a variation in skill and experience level of responsible

departmental personnel.

Based on interviews with the NSAC staff, there

Enclosure 2

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has been a major increase in the number of DCs/RCCAs being processed

along with a considerable turnover of the individuals tasked with

addressing them for their respective departments.

This turnover

resulted in many of the individuals being inexperienced and have not

received advanced training yet to enhance their problem solving

methodologies or root cause techniques.

The following three DCs and RCCA were considered inadequate for the

reasons discussed below:

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The RCCA for DC 1-97-010 did not identify the appropriate root

cause of a diesel generator control power circuit problem.

Consequently the actions to prevent recurrence were inadequate

and a similar control circuit failure recurred shortly after this

DC/RCCA was completed and implemented.

Following the second

incident another RCCA by the system engineer was developed and

reviewed by an inspector.

This RCCA determined that a

. manufacturing-related design deficiency of a light socket had

caused the control power circuit breaker to trip,

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In the two other cases. DCs 2-97-071 and 2-97-085. concerning a

cracked weld and missing seismic restraining pin on the collar of

a Nuclear Service Cooli1g Water (NSCW) pump, the DCs did not

adequately describe the causes and corrective actions.

These DCs

were not documented well enough for the inspectors to conclude

that the root cause(s) had been determined or the corrective

actions adequate. Also, there was no RCCA performed even tho*:gh

it involved complex problems.

In discussions with the licensee,

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the inspectors concluded that detailed evaluations had been

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conducted by offsite engineering personnel to determine the cause

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of the weld failure and missing pin, and corrective actions

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developed in concert with the onsite system engineer.

However.

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the causes and corrective actions had not been adequately

documented in the DC nor via a RCCA.

Licensee personnel indicated

that they planned to document these DCs more thoroughly to

accurately describe the causes and corrective actions.

While reviewing the selected CCs the inspectors identified 11 other DCs

that were initially dis)ositioned as potential Maintenance Preventable

Functional Failures (MP:Fs) that did not have an RCCA. According to

procedure 50028-C. " Engineering Maintenance Rule Im)1ementation."

Rev. 4. the responsible engineer was to perform an RCCA on "potentit.1"

MPFFs or when performece criteria / goals for a system were not met.

However, procedure 00;.,b3-C. " Maintenance Rule Implementation." Rev. 2.

states that RCCAs O

i be performed for any condition determined to be

an MPFF.

The licensee later aetermined that the 11 DCs initially

characterized as potential MPFFs were not MPFFs. and that no RCCA was

required. A review of the procedural differences has been undertaken by

the licensee.

Enclosure 2

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The threshold for initiating DCs has dropped over time, resulting in an

increase in DCs (approximately 350 in 1995, 900 in 1996. and perhaps

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about 1200 in 1997).

During the inspection, the backlog of outstanding

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DCs was approximately 135. Of these, about 75 were being actively

worked by the responsible departments. )articularly Operations.

Maintenanct and Engineering Suppurt.

T7e other 60 DCs were being

processed by the NSAC group, including newly-initiated DCs and DCs being

reviewed for closure.

Procedure 00150-C. requires responsible departments to resolve DCs/RCCAs

and identify corrective actions within 30 days; whereupon, the NSAC

group conducts a quality review, re-evaluates reportability and enters

proposed corrective actions into the computer database (i.e.. Open item

(01)/ Commitment Tracking System). Although, responsible departments

consistently disposed of their assigned DCs within the 30 days, the NSAC

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group struggled to keep up with the increased volume of DCs required to

be processed. As a consequence, some newly-initiated DCs reviewed by

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the inspectors were taking several days. and up to a week. before the

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NSAC reportability review was accomplished and the DC assigned to a

res)onsible de

The oC form indicates this should be done

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witlin a day. partment.In addition, the closecut reviews of comaleted DCs and

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entry of corrective actions into the OI/ Commitment Tracting System by

NSAC was taking longer than desired. About a fourth of the outstanding

DCs that the NSAC group was responsible for closing had been waiting two

to three months since the responsible department finished identifying

causes and corrective actions.

Some DCs had actually been waiting five

to-seven months after the responsible department was done befor : they

were closed by NSAC (e.g.. DC 2-97-22 and 2-96-259). Although there are

no plant procedural guidelines on the length of time NSAC takes to

closecut a completed DC these delays could adversely impact the

accurate and timely tracking of corrective actions and quarterly

trending for management.

NSAC's final reportability review ano quality

checks regarding adequacy and completeness of DC/RCCA documentation,

root causes, and corrective actions are also impacted.

Similar timeliness issues with the processing of DCs by NSAC were

previously identified by the Safety Audit and Engineering Review (SAER)

group during a routine cudit of the licensee's corrective action piogram

conducted in January 1997. The applicable Audit Finding Report

(AFR) 640 was issued January 16, 1997. Corrective actions to address

the AFR were implemented and subsequently reviewed by SAER on April 15,

1997, which determined that the actions were adequate to close out AFR

640. Although the total NSAC backlog of DCs was reduced, the timely

review of new DCs and closure of completeo DCs appeared to remain a

problem. Management expectations regarding NSAC timeliness for

processing DCs in a prompt and efficient manner was not clearly

communicated by procedures.

Enclosure 2

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The inspectors observed and discussed the closecut of DCs with NSAC

personnel. These closeout reviews by NSAC personnel were thorough,

detailed, and added considerable quality to the program.

NSAC personnel

were very knowledgeable and conscientious, although not always timely.

Problems with the completeness and adequacy of DCs dhpositioned by the

responsible departments were promptly brought to the department's

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attention for resolution by NSAC.

In certain cases, this resulted in

revised causes and/or corrective actions. Also the many inconsistencies

observed by the inspectors in the type and number of root cause codes

identified by responsible departments for trending purposes were usually

corrected during the NSAC review.

The total backlog of outstanding items in the 01/ Commitment Tracking

System was about 740 open items (e.g., DC/RCCA corrective actions) and

commitments.

Because the licensee does not trend their backlogs of DCs

or dis, the inspectors were unable to evaluate the magnitude and

associated trends of outstanding corrective actions or open DCs.

However, scheduled due dates for DCs assigned to responsible departments

and Ols/ commitments were aggressively tracked by management on a weekly

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basis. According to the "Open Item and Deficiency Card Status" weekly

reports reviewed by an inspector and interviews with management. DCs and

Ols/ commitments were rarely late.

The inspectors selected ten Ols due

on June 27 to assess the effectiveness of licensee efforts to ensure

that Ols were being closed in a timely manner, consistent with scheduled

due cates.

Of these ten Ols, only three were closed on time.

Of the

remaining seven, two were closed late and five were rescheduled (one of

which was rescheduled after it was overdue).

Due to the fact that these

ten Ols were either rescheduled or closed before June 27. the "Open Item

and Deficiency Card Status" weekly report issued the following Monday

(June 30) would have reported no Ols were late. The inspectors

discussed with plant management that approximately 70% of corrective

action Ols due on June 27 were not completed on time, and half were

rescheduled at the last moment.

The inspectors identified that 01 34432. whose responsible department

was Westinghouse had a scheduled completion date of February 28, 1997.

Because of the way the weekly "Open Item and Deficiency Card Status"

report was formatted, management was unaware that this 0I was long

overdue.

When notified of this finding by the inspectors, NSAC

contacted Westinghouse and revised the due date.

Procedure 00150-C, requires that any responsible department that needs

more than 35 days to resolve a DC must get an Assistant General Manager

(AGM) approval for an extension.

In 1997. of the hundreds of DCs

processed, only three have been extended. The inspectors reviewed the

extension requests and verified that they were approved by an AGM.

However, the administrative controls for rescheduling due dates of

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corrective action Ols was not as-strict.

Procedure 00409-C allows any

corrective action OI to be rescheduled with approval from the NSAC

Originating Coordinator and the responsible department manager,

Enclosure ?

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superintendent, supervisor, or team leader. The inspectors did not

observe that any request to reschedule a corrective action 01 was

denied,

The number and frequency of rescheduled Ols each week were not

being specifically tracked or reported.

The inspectors reviewed several recent "06arterly Trend Reports and

Department Self-assessments." the most recent covering November 1996

through January 1997, issued April 25. 1997. NSAC is responsible for

issuing the quarterly trend reports to each department in addition to

the de)artment's own individual self-assessment. The quarterly report

for Fe)ruary through April 1997 had not been issued by June 27, 1997.

Two to three month delays in issuing the quarterly trend reports seemed

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to be typical, and consistent with DC/RCCA processing delays exhibited

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by NSAC.

Procedure 80016-C does not provide any guidance on the

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expected timeliness of trend identification and reporting. Trend

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reporting and departmental self-assessments have evolved considerably

over the past year and a) pears to be a valuable tool for plant

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-improvement. Although tie most recent quarterly trend report did not

identify any additional corrective actions based on plant-wide trending,

the departmental self-assessments and trending did identify numerous

areas for improvement (e.g., work practices, procedural use, procedure

cuality, management and supervisory involvement).

Each department also

ceveloped corrective measures and provided implementation schedules to

address self-identified problems and adverse trends for improving

performance. The individual departmental self-assessments varied

considerably in format, quality and content. There was no

administrative procedure to ensure uniformity and consistency.

However,

the program was still in its formative stages and management stated that

program guidance is still being developed.

c.

Conclusions

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Overall, the inspectors cor 'Jded that DC/RCCAs were sufficiently

thorough and complete, witi, appropriate disposition /causes and adecuate

corrective actions identified. However, the content and level of cetail

between DCs/RCCAs differed considerably, reflecting a variation in skill

and experience level of responsible departmental personnel.

NSAC

personnel were knowledgeable, conscientious, and added considerable

quality to the DC/RCCA process.

However, management expectations

regarding NSAC timelir.ess for processing DCs in a prompt and efficient

manner were not clearly communicated.

Backlogs of DCs or 0Is are not-

trended to evaluate the magnitude and associated trends of outstanding

corrective actions or open DCs. Although DCs are almost always

completed by responsible departments in a timely manner. corrective

action 0Is were routinely rescheduled. The licensee's trend

identification / reporting and departmental self-assessment program

continues to evolve.

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Enclosure 2

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07.2 Event Review Team Reports (40500)

a.

Insoection Scoce

Procedure 00057-C, " Event Investigation," Rev. 10, and

C. " Root Cause Determination," Rev. 11, described the ' procedure 00058-

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icensee's methods

for determining the root causes of events.

The inspectors reviewed

selected Event Review Team (ERT) and RCCA re) orts.

The review included

a cursory examination of 11 ERT reports, wf t1 a detailed review of three

ERT reports listed below:

ERT report 1-96-06, " Inadequate Cooling for Safety Injection Pump

IB Motor." dated October 15, 1996:

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ERT report 2-96-003, " Manual Reactor Trip Due to Main Feed

Regulating Valve Sticking," dated October 14, 1996: and

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ERT report 2-96-004, " Low Vacuum - Turbine Trip / Reactor Trip after

SGFPT (Steam Generator Feed Pump Turbine) Rupture Disk Failure,"

dated October 23, 1996.

The inspectors reviewed the above ERT reports for effectiveness of

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identifying root causes, making appro)riate recommendations to solve the

problem and prevent recurrence, and t1e implementation of developed

corrective actions.

In addition, the inspectors reviewed operability

determinations made by the licensee as a result of events and associated

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reportability issues.

b.

Observations and Findinos

The licensee performs ERTs and RCCAs for significant events such as:

unplanned reactor trips: reoortable Engineered Safety features (ESF)

actuations; significant radiological events: and events identified by

site management.

Based on the review of the selected ERTs. the inspector noted that the

licensee frequently uses the Cause Identification Worksheet analysis

technique or the Paper and Pencil Narrative method to investigate an

event. Application of those te< hniques resulted in thorough root cause

analysis. However, the inspectars identified several . non-repetitive,

minor administrative procedural non-compliances.

None of the identified

items resulted in impacting the problem resolution process or the

effectiveness of the corrective actions developed.

These items were

forwarded to the licensee for resolution.

An issue raised by the inspectors during the review of event reports

concerned ERT team leaders. A review of the team members for each of

the 11 ERTs indicated that an Independent Safety Engineering Group

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(ISEG) re)resentative led five of the 11 teams.

Updated Final Safety

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Analysis Report (UFSAR) Section 17.2.1.3.4, states that ISEG shall not

Enclosure 2

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Mcome responsible for signoff functions such that it becomes involved

in the operating organization.

By signing and recommending corrective

actions as part of the ERT report the ISEG representative performed

duties in accordance with procedure 00057-C.

SAER had identified a

somewhat related issue during an audit of the ISEG.

The audit comment

pointed out that ISEG internal procedures only allowed ISEG personnel to

assist and not lead ERTs.

Corrective action taken in response to the

audit comment was to prohibit ISEG members from leading future ERTs in

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accordance with procedure VSAER-WP-20. The inspectors discussed their

observation with licensee management.

The ins)ectors were later

informed that corporate management had (as of iay 9.1997) directed ISEG

members to no longer lead ERTs until further notice.

The licensee documented events as required by 10 CFR 50.73. Licensee

Event Report (LER) system. No issues or discrepancies concerning

reportability were identified.

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c.

Conclusions

The inspectois concluded that the ERT reports and RCCAs reviewed were of

good quality and thorough. Corrective actions developed as a result of

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ERTs. and associated RCCAs, were appropriate for the root causes

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identified.

In addition, operability and reportability determinations

were appropriate, where necessary.

07.3 Safety Audit and Enaineerina Review Proaram (40500)

a.

Insoection Scone

The inspectors evaluated implementation of the SAER Program with regard

to scope and responsibilities, position in the plant organization

according to UFSAR Chapter 17.2. Operational Quality Assurance Program,

and licensee procedures. Selected SAER audits were specifically

reviewed.

b.

Observations and Findinas

The ins)ectors discussed the structure and specific responsibilities of

the SAER group with its su3ervisor to determine that the program's

implementation satisfied t1e requirements of the UFSAR. including

independence from operational considerations.

The inspectors reviewed

the audit schedule for the current year for compliance with required

subject audit areas and frequency.

The inspectors selected the following audits for review:

OP02. " Health Physics and Radiation Protection." for the previous

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three audits (specifically. OP02-95/06. OP02-96/05, and

OP02-96/33):

Enclosure 2

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OP06. " Reactor and Plant Operations." for the previous three

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audits (specifically. OP06-96/09. OP06-96/29, and OP06-97/05):

OP09, " Surveillance Program / Technical Specification Compliance,"

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for the previous three audits (specifically. OP09-96/15,

OP09-96/31, and OP09-97/11): and,

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OP21, "Corre:tive Action Program." last audit and portions of next

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to last audit (specifically, OP21-97/08 and OP21-96-39)

The inspectors noted that the audits were comprehensive and thorough.

These audits included audit findings, comments, and/or recommendations

for the audited group. Audit finding reports (AFRs) required an

immediate response and were tracked by plant management until

appropriate approved action was taken to resolve the finding.

Comments

recuired action to be taken and were followed up during a successive

aucit to review the appropriateness of the action taken.

Recommendations were treated as suggestions and had to be acknowledged,

but no formal problem resolution was required.

The inspectors reviewed

the handling of these different items, from original presentation in an

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audit to final resolution and disposition, and determined that they were

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appropriately resolved in a timely manner.

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The inspectors noted that all of the audits were conducted within the

required frequency, based on start dates.

However, the inspectors found

that the SAER group could continue auditing for long periods of time or

even suspend the audit (e.g.

auditor reassigned to begin another more

important audit). The typical SAER audit completed in 1997 took from

three weeks to three months to perform, with most being accomplished in

about a month.

A few audits were actually suspended, some covered plant

activities that did encompass considerable lengths of time; but the

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normal. routine audit was several weeks long.

An audit was not

considered completed until the audit exit meeting was neld by which time

the audit report was finalized and audit checklists typically f'.lled

out. Consequently, a significant amount of the audit duration was not

necessarily active auditing but documenting. UFSAR Section

17.2.1.1.1.9.C states that audit reports will be forwarded to the Vice

President - Nuclear (VPN) and responsible management within 30 days

after the audit is completed. Although allowed by internal SAER

procedures for flexibility, the inspectors considered that the extended

duration of an audit could permit findings and comments to not be

communicated to responsible managers. VPN, and/or Safety Review Board

(SRB) in a timely manner.

In addition, suspending audits or extending

audits to accommodate documentation can lead to delays in corrective

actions and management review activities.

Enclosure 2

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c.

Conclusions

The inspectors concluded that the SAER Program satisfies the

requirements of the UFSAR and implementing procedures for conducting

quality assurance (0A) audits. Audits were comprehensive and thorough.

AFRs and comments were properly addressed in a timely manner, and

com)letion of corrective actions were verified.

Findings were adequate

to (eep licensee management informed of significant developing problems

in the areas audited.

However, the practice of allowing an extended

duration audit could lead to delays in implementing corrective actions

and the conduct of management reviews.

07.4 Self- Assessments (40500)

07.4.1

Health Physics Self-Assessment

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a.

Insoection Scoce

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The inspectors reviewed the licensee's comprehensive self-

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assessment of Health Physics (HP) areas of responsibility,

b.

Observations and Findinas

The inspectors reviewed a self-assessment conducted by the HP

Department from February 3-7. 1997. The inspectors noted that the

self-assessment was conducted by a team of people not only from

within the plant staff, but from other nuclear plants within the

Southern Nuclear Operating Company. Inc. (SNC) organization, and

even from nuclear plants outside the SNC organization. The

inspectors determined this aspect of the program to be a strength.

The assessment addressed the following seven areas: As Low As

Reasonably Achievable (ALARA): contamination control: external

radiation: personnel dosimetry: RWPs/ posting and labeling: solid

radwaste; and surveys and documentation. A generally consistent

format was used to report on each area with specific observations,

both as strengths and areas for improvement. Overall each area

3rovided numerous insightful and meaningful observations.

iowever, the final document appeared as a disparate collection of

work from several individuals with varying quality

The root

cause analysis, addressed as pie charts at the end of the

assessment, was not always well-defined. The inspectors also

reviewed data collection sheets from the individual team members.

These sheets were of a standard format and provided more detailed

information regarding each observation. These sheets also

provided trending codes, defined corrective actions, and tracked

status.

~

Enclosure 2

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c.

Conclusions

The HP self-assessment, was a comprehensive evaluation of major

areas of res)onsibility.

This self-assessment identified numerous

aspects of tie HP program for improvement for which specific

corrective actions have been developed and were being actively

tracked to completion. The use of experienced HP personnel from

outside the plant as part of the self-assessment team was

considered a significant strength.

1

,

07.4.2

Plant Modifications and Maintenance Sucoort (PMMS) Self-Assessment

a.

Insoection Scooe

The inspectors reviewed the report from a self-assessment of the

PMMS department conducted in December 1996.

The inspectors also

reviewed the PMMS corrective action plan,

b.

Observations and Findinas

The PMMS self-assessment team performed a detailed assessment of

the design change process, modelling and analy7.ing twenty-two

discrete, significant activities of the process.

Four specific

process areas were identified for assessment: Design Change

Control. Design Generation. Design Implementation, and Design

Close Out.

During the assessment substantial findings were

identified and explicit recommendations were made. A

comprehensive corrective action plan was developed, with scheduled

due dates, which addressed each of the specific recommendations.

The inspectors' review indicated that the PMMS department did not

address numerous " compliance" and " process" issues in the Design

Generation area identified by the assessment team, for which

s)ecific recommendations were not made. After discussions with

tie inspector. PMMS management indicated it planned to go back and

address each of the issues.

This issue is identified as an

example of Inspector Followup Item (IFI) 50-424. 425/97-08-01.

Resolution of Self-Assessment Findings.

c.

Conclusions

The PMMS self-assessment was thorough and detailed, with

substantial findings and recommendations.

Corrective actions were

)lanned and scheduled to address all of the recommendations.

lowever, the PMMS department did not address numerous compliance

and process issues identified in the report.

Enclosure 2

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11

07.4.3

Ouarterly Human Performance Self-Assessments

a.

Insoection Scone

The inspectors reviewed several of the most recent Quarterly RCCA

Human Performance Review reports. and discussed these reports with

site management and the Independent Safety Engineering Group

(ISEG) supervisor.

b.

Observations and Findinas

In February 1996, the ISEG was requested to conduct quarterly

reviews of DC/RCCAs involving human performance errors. The ISEG

has conducted five quarterly reviews since February 1996, usually

issuing their reports within four to six weeks after the quarter.

These reports were comprehensive, thorough and insightful, with

detailed observations and some statistical analysis.

However, it

was difficult for the inspectors to distinguish whether some ISEG

-

report statements were mea #, to be a general observation of fact,

conclusive problem, suggestion, or specific recommendation. There

was no formal process in place to disposition these ISEG

statements. some of which have been repeated in several quarterly

reports with no apparent licensee response.

Examples of

repetitive ISEG issues were:

1) there is a continued increasing

trend of DCs with human performance errors. 2) efforts to ensure

individuals with advanced root cause training perform the RCCAs

involving human performance issues have been inconsistent: 3) cnce

potential trends are identified RCCAs should be completed on each

recurring incident: and 4) a review group to evaluate quality and

consistency of DC dispositions

' analyze adverse trends would be

beneficial.

Also, attached to each ISEG quarterly report was Attachment A.

" Example Human Performance Review Summaries / Assessment Comments."

In this attachment were detailed discussions, specific comments.

and recommendations regarding selected DC/RCCAs.

Many of the ISEG

comments clearly ques:,ioned whether the disposition. causes,

and/or corrective actions of particular DC/RCCAs were a)propriate

or adequate. These Attachment A comments and findings lad not

been routed to the responsible departments for resolution. These

findings represent potentially inadequate corrective actions

and/or incomplete documentation of DC/RCCAs. This issue is

identified as an example of IFI 50-424, 425/97-08-01. Resolution

of Self-Assessment Findings.

c.

Conclusions

ISEG Ouarterly Human Perfcrmance Reviews were comprehensive,

thorough and insightful.

However, many of the ISEG report

statements were unclear whether they represented general

Enclosure 2

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12

observations of fact, conclusive problems. suggestions or specific

recommendations. Also, the inspectors were unable to ascertain

how the licensee was addressing these ISEG statements. especially

those that were repeated in several reports. Specific comments

regarding the adequacy of particular DC/RCCAs have not been

addressed by licensee management.

07.5 Ooeratina Exoerience Feedback Proaram (40500)

a.

Insoection Scooe

The inspectors reviewed the licensee's handling of two Opeuting

Experience Reports (GERs) and the backlog of open OERs, including NRC

Information Notices (ins) awaiting disposition.

b.

Observations and Findinas

Procedure 00414-C, " Operating Experience Program," required ISEG to

coordinate the onsite evaluation of certain industry event reports and

NRC ins.

NSAC was assigned responsibility for onsite coordination of

generic letters and other NPC issues requiring a response. The

inspectors selected two recently dispositioned OERs from a list of

industry event reports that nad been received since January 1996 to

present. The inspectors reviewed the licensee's evaluations and

corrective actions for the OERs selected and found both to be adequate.

For the examples reviewed, appropriate de]artments had been involved in

the evaluation and required training on tie events had been provided for

both licensed and non-licensed personnel.

The inspectors found that the

ISEG had a goal to have all ins closed within a six-month period. The

-

licensee indicated that all but one 1996 IN had been closed.

It was

expected to be closed by the end of June, which was consistent with the

department goals. The ISEG's total backlog of open OERs was

approximately 54 items, somewhat higher than the 1996 year end total of

44 items.

c.

Conclusions

<

The licensee's evaluation and corrective actions for two OERs issued in

1996 were reviewed and found to be adequate. The backlog of industry

OERs and ins was being maintained within reasonable levels.

07.6 Indeoendent Safety Enqineerino Grouc (40500)

a.

Insoection Scoce

The inspectors reviewed the ISEG activities to determine if they were

consistent with those described in UFSAR Section 17.2.1.3.4 and

Procedure VSAER-WP-20. Independent Safety Engineering Group

Organization.

Enclosure 2

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b.

Observations and Findinas

The ins)ectors found that the ISEG was meeting the activities described

in the JFSAR and internal procedures for reviewing and providing

recommendations to management on methods to improve plant safety and

reliability and reporting to management on the activities reviewed by

the ISEG.

However, the inspectors found that the ISEG was involved in

both assisting and leading event review teams.

The practice of ISEG

1eading event review teams was found to be in conflict with the UFSAR

with respect to maintaining independence from the operating organization

-(see report Section 07.2).

The inspectors found that the ISEG had

performed several assessments over the last 12 to 18 months.

Exam)1es

of routine assessments Jerformed by ISEG were Pre-Outage Schedule Review

and Risk Assessments, Slutdown Risk Assessments. Post-Outage Review and

Risk Assessments and Quarterly RCCA Human Performance Reviews (see

report Section 07.4.3).

Examples of special assessments that were

)erformed by the ISEG included the assessment of the UFSAR Review

l

3rogram and the Configuration Control Assessment. A detailed review of

the UFSAR Review Assessment is described in report Section E7.2.

c.

Conclusions

The inspectors concluded that the ISEG acti"ities were consistent with

UFSAR and procedural requirements, except f ' leading the ERTs.

The

assessments performed by the ISEG were efft

ive in identifying areas

for improving plant safety.

07.7 Onsite and Offsite Review Committee Activi; 140500)

07.7.1

Plant Review Board

The inspectors attended one meeting of the Plant Review Board

(PRB) on June 24.

Plant management was well represented at the

meeting and attendance met UFSAR membership and quorum

requirements.

The PRB agenda for meeting 97-47 was com)osed

primarily of procedure changes and DCs.

Of these, the )RB anly

actually discussed those procedure changes and DCs that one ir

more of the members indicated they had comments on.

Discussuns

were detailed and explored relevant aspects of associated

procedure changes.

07.7.2

Safety Review Board

a.

Insoection Scooe

The inspectors reviewed UFSAR and corporate procedural

requirements for conducting Safety Review Board (SRB) activities.

The inspector also reviewed the last two SRB meeting minutes

(i.e. . iajor Meetings 96-20 and 97-02). including associated SRB

open items, and interviewed several SRB members.

Enclosure 2

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b.

Observations and Findinas

UFSAR Section 17.2.1.1.1 prescribed SRB functions, organization

and review res)onsibilities.

Corporate procedure VSRB-05. Safety

Review Board. Rev. O, provided the procedural guidance for

defining how the SRB fulfills its regulatory responsibilities.

The inspector verified that SRB activities were conducted in

accordance with UFSAR Section 17.2.1.1.1 and procedure VSRB-05,

except as discussed below.

In general. SRB meetings were

comprehensive and routinely identified specific problem areas

requiring site and/or corporate attention.

For each identified

problem an SRB open item was initiated, tracked and usually

resolved in a timely manner prior to the next SRB meeting

whereupon it would be reviewed and closed out. Of the eleven SRB

open items from the SRB meeting (Major Meeting 96-20) on December

18, 1996, only one item remained open following the meeting on

April 30,1997. The SRB meeting on April 30 also identified an

additional 19 open items.

Responses to 14 of these new SRB open

items had already been received within about 45 days following the

SRB meeting. The inspector noted that, except for some SRB open

items assigned to the VEGP General Manager (GM). most open items

were not entered into the site corrective action program for

trending or RCCA.

The inspectors identified the following deficiencies in procedural

guidance and implementation of SRB responsibilities:

e

UFSAR Rev. 6. Section 17.2.1.1.1.7.F. states that the SRB

shall be responsible for reviewing significant operating

abnormalities or deviations from normal and expected

performance of plant equipment that affect nuclear safety.

Section 17.2.1.1.1.7.H states that the SRB shall review all

recognized indications of an unanticipated deficiency in

some aspect of design or operation of structures, systems,

or components that could affect nuclear safety. These areas

of review were in addition to SRB responsibilities to review

violations. AFRs. and LERs.

However, the inspector was

unable to discover any examples within the scope of UFSAR

Sections 17.2.1.1.1.7.F and H that had been reviewed by the

SRB unless it also involved a violation. AFR or LER.

Although these UFSAR review requirements were replicated in

VSRB-005, the procedure did not provide any defining

guidance.

As documented in inspection report Section 07.2 the

inspectors examined 11 ERT reports of significant plant

events according to procedure 00057-C.

Of these events

(that occurred within the past year), eight were reviewed by

the WRB primarily because they resulted in an LER, special

report. and/or violation.

However, three events were not

Enclosure 2

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reviewed.

In general. ERT reports that don't result in

violations. LERs. AFRs. etc. are considered to be examples

of the aforementioned UFSAR sections that require SRB

review.

The inspectors were provided little or no documentation to

e

demonstrate how several SRB responsibilities described in

Section 5.2 of VSRB-005 were being accomplished, such as:

a) " Verifying that certain aspects of plant operations in

accordance with license provisions:" b) " Making

recommendations for improvements in plant operations and in

effectiveness of operations quality assurance;" and c)

,

"Re-audit of deficient areas where indicated, shall be

initiated by the SRB."

Implementation of UFSAR Sections 17.2.1.1.1.7.F and H. as

l

described above, constitute a deviation from UFSAR commitments and

'

is identified as DEV 50-424, 425/97-08-02. Failure to Fulfill All

SRB Review Commitments,

i

!

The most recent annual SAER assessment of the VEGP SAER grou) and

SRB was issued in an audit report dated December 6, 1996. T11s

audit report did not identify any " Findings" or make any

" Comments" regarding conduct of SRB functions.

SRB members

themselves did not provide any comments regarding the conduct or

suggestions for improvement of the last two SRB meetings using the

provided feedback forms,

c.

Conclusions

In general. SRB meetings appeared to be comprehensive and

routinely identified specific problem areas requiring site and/or

corporate attention.

For each ideitified problem, an SRB open

item was initiated, tracked, and wholly resolved in a timely

manner.

SRB activities were conducted in accordance with FSAR

Section 17.2.1.1.1 and procedure VSRB-05, except as identified

above.

DEV 50-424, 425/97-08-02 was identified for insufficient

implementation of UFSAR commitments regarding SRB review.

08

Miscellaneous Operations Issues (92901)

f

08.1 (Closed) Violation (VIO) 50-425/96-11-01: Improperly Positioned

Clearance Holci Points on Unit 2 Main Control Room Boards - Two Examples.

This item was addressed in Sections 02.1 and 02.2 of Inspection Report

(IR) 50-424, 425/96-11. The licensee submitted its reply to the VIO by

letter dated December 30, 1996.

The inspectors reviewed the root cause

determination and corrective actions completed by the licensee to avoid

recurrence. The inspectors verified completion of the corrective

actions, which included the counseling of the operations supervisors

Enclosure 2

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16

regarding clearance and tagging restrictions using solenoid valves as

clearance points. Also, tha counseling of the individual operator

directly involved regarding tagging requirements and the importance of

ensuring that component position is in accordance with the clearance

requirements. The topic was included in the operation department's

continuing training for licensed and non-licensed operators, scheduled

,

for completion in March 1997.

The ins)ectors also reviewed the training

lesson plan and personnel attendance sleets for the training.

The

lesson plan was determined to be adequate and the training was completed

as scheduled.

This VIO is closed.

II. Maintenance

1

M8

Miscellaneous Maintenance Issues (92902)

!

M8.1

(Closed) VIO 50-424/96-479-01013: Inoperable IB SIP Due To Inadequate

Cooling Flow To Its Motor Coolers.

This issue was documented in IR 50-424. 425/96-12 (Section M8.4).

50-424, 425/96-11 (Section M3.1). LER 50 -424/96-10. Rev. 0, and

LER 50-424/96-10. Rev. 1.

The inspectors reviewed the licensee's corrective actions identified in

the LER and ERT report 1-96-06. " Inadequate Cooling for Safety Injection

Pump 1B Motor". dated October 15, 1996.

Based on this review the

licensee's corrective actions should preclude repetition.

This VIO is

closed.

M8.2 (Closed) VIO 50-424. 425/96-479-01023: Inadequate Procedural Guidance To

Assure Correct Installation Of Motor Cooler Gaskets And Plenums For

Safety-Related Equipment.

This violation was documented in IR 50-424, 425/96-12 and addressed the

lack of adequate procedural guidance.

As part of the licensee's corrective action, maintenance procedure

27118-C. " Westinghouse large Frame Motor Heat Exchanger Maintenance."

Revision 2. was developed.

Based on the review of the maintenance procedure performed by the

inspectors and the review documented in report Section M8.1. the

licensee's corrective actions should preclude repetition.

This VIO is

closed.

Enclosure 2

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M8.3 (Closed) LER 50-424/96 010; SIP Rendered Inoperable Due to Lack of Motor

Cooling.

This LER documented issues discussed in report Sections M8.1 and M8.2.

Based on that review this LER is closed.

M8.4 (Closed) LER 50-424/96-010. Rev. 1: SIP Rendered Inoperable Due to Lack

of Motor Cooling.

This LER documented further analys1s performed by the licensee of the

impact that the inoperable SI pump had on the small break loss-of-

coolant-accident.

In addition. further corrective actions were

developed as a result of the licensee's continued review of the issue.

Based on this review and that documented in report Sections M8.1 and

!

M8.2. this LER is closed.

M8.5 (Closed) LER 50-424/97-001: Thermal Overload Bypass Jumper Connection

Renders ECCS Valve Inoperable

This LER documented the identification of a thermal overload bypass

jumper for valve 1HV-8802A. SI Pump A to Hot Leg 1 and 4 Isolation

Valve %ing improperly connected.

Prevt. inspection of this issue was documented in IR 50-424. 424/96-14

(Section 02.4) and 50-424, 425/97-04 (Section 08.1).

The inspectors reviewed the licensee's corrective actions identified in

the LER and the event report developed as a result of this event.

As a result of the event. the licensee verified that other ECCS valves'

thermal overload jumpers in both Units 1 and 2 were properly installed.

In addition, the licensee developed supplemental training for

maintenance personnel on proper install? tion of lifted leads with an

emphasis on independent verification.

' ne licensee also counseled the

i

involved maintenance personnel.

The licensee's corrective actions should preclude repetition.

Based on

this review this LER is closed.

Enclosure 2

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x

III.

Enaineerina

-E7

Quality Assurance in Engineering Activities-

1

E7.1 UFSAR Accuracy Reverification Proaram (40500)

a.

Insoection Scoce

<

The inspectors reviewed the. licensee's activities associated with the

resolution of numerous discrepancies identified by the UFSAR Accuracy

1

Reverification Program to determine if these actions were comistent-

with the requirements of title 10 of the Code of Federal Regulations

Parts 50.-59, 50.72. 50.73. ar.d Part 50 Appendix B. Criterion XVI.

-b.

-Observations and Findinas

The licensee in res]onse to IN 96-17. " Reactor Operation Inconsistent

with the Updated FSA1." conducted a review of over 600 sections of the

VEGP UFSAR to verify that it accurately reflected the plant design,

as-built condition, and/or operating practices.

This review, performed

by individuals from the operating plant staff. SNC corporate. Southern

Company Services (SCS), and Westinghouse, took ) lace over approximately

a six-month period from July 1996 through Decem)er 1996, and resulted in

the identification and documentation of over 700 discreaancies.between -

the UFSAR and as-built plant and operating practices. Of those the

licensee-considered that approximately 500 were associated-with original

errors in the UFSAR.

-The deficiencies were documented on ap3roximately 100 DCs, and

approximately 125 Licensing Document C1ange Requests (LDCRs) were

-generated to revise the-UFSAR. The licensee indicated that -

discre)ancies identified by site reviewers were documented on DCs and

that tiose identified by offsite reviewers (i.e. SNC cor) orate. SC1.'and

Westinghouse personnel) were primarily documented on LDCRs.

Site

procedures required DCs to be evaluated-for operability and

r

reportability: however, a similar -requirement did not exist for LDCRs~.

'

In the latter case, the licensee relied on the knowledge of the

personnel doing the review to identify any operability or reportability

concerns, . This was considered to be a weakness in the UFSAR Review

Program,-although no operability or reportability issues were

identified.

The inspectors reviewed the adequacy of the licensee's corrective

actions for the UFSAR discrepancies documented in-DCs-1-96-412.

1-96-449,1-96-431.1-96-499 and'l-96-375 involving various

discrepancies with UFSAR Sections 15.0.13. 15.6.3. 3.1.2. 3.1.4. 6.5.2.

15.6.5 and 9.3.4.

The inspector found that the DCs had been_ adequately

dispositioned, but not all of the required corrective ections had been--

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Enclosure 2

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19

completed. The inspector did not identify any concerns documented on

the above DCs that required reporting in accordance with 10 CFR 50.72 or

10 CFR 50.73.

With one exception, DC 1-96-499, a root cause evaluation

was not )erformed for each discre)ancy, rather, an assessment was made

of the U:SAR review results and tie most likely causes were determined,

for which recommendations made and corrective actions were identified to

reduce the likelihood of new discrepancies being introduced.

The

inspector found this to be acceptable.

DC 1-96-375, identified a discrepancy between plant operating practices

in the use of the Centrifugal Charging Pumps (CCPs) for normal charging.

The UFSAR that stated normal charging flow was provided by the )ositive

displacement charging pump (PDP).

The corrective action taken )y the

i.

licensee was to revise the UFSAR to allow the PDP or CCP to provide

'

normal charging to the reactor coolant system. The licensee's 10 CFR

l

50.59 Safety Evaluation stated, in part, that " utilization of

centrifugr' "harging pumps to provide normal charging fhv does not

raise the

ability of occurrence of a malfunction of centrifugal

charging pumps. This is assured by routine preventive and predictive

maintenance."

l

Considering the above evaluation, the inspectors requested and reviewed

information on the environmental qualification (EO) of the CCP motors.

A one-page document identified as Attachment 11, Sheet 2 of 2. of

Calculation X4 CPS.0075.335. Rev. 8, was )rovided to demonstrate the

EO-qualified life for the CCP Motors. T11s document indicated that the

I

,

motors had a qualified life of greater than 60 years operating

continuously for 60.1 percent of the time at a normal service

temperature of 100,88 degrees Centigrade (C). A single page from a

draft calculation was also provided to the ins)ectors in which the motor

J

qualified life had been re-analyzed based on tie motor o)erating 100

<

percent of the time. This draft calculation indicated tie motor had a

qualified life under these conditions of greater than 40 years at a

normal service temperature of 100.88 degrees C.

The one page document

from the draft calculation indicated that the motor service temperature

s

of 100.88 degrees C consisted of 30 degrees C ambient temperature. plus

60.88 degrees C heat 'ise at 640 HP plus 10 degrees C hot spot.

EQ Documentation Package No. X6AA15 indicated that the CCPs were located

in the Auxiliary Building in areas 8RC115. 8RC118, 8RC16. and 8RC17.

The normal ambient temperature for these areas was shown in FSAR Table

3.11.B.1 as 100 degrees Fahrenheit (F) which is approximately 37.78

degrees C.

The inspectors noted that the 30 degrees'C did not appear to

be consistent with the UFSAR. Discussions with SNC corporate personnel

indicated that temperature surveys had previously been done at the site

and these results were used in the analysis to establish a qualified

life for the CCP etors.

This issue is unresolved, pending further

review by the inspector to determine the design basis for the

30 degree C ambient temperature used in the evaluation of the CCP motor

qualified life. This issue will be identified as Unresolved Item (URI)

Enclosure 2

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20

50-424, 425/97-08-03. Determine Design Basis for Ambient Temperatures

Used in Qualified Life Evaluations of CCP Motors.

The inspectors found that the backlog of incomplete corrective actions

for the UFSAR discrepancies was small, consisting of approximately six

LDCRs that required processing: approxinatel

engineering assistance that were still open:y three requests for

approximately 11

miscellaneous corrective action items: and those corrective actions to

address recommendations made by the ISEG on actions to help preclude

ML20210N673

Text

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