ML22060A006
| ML22060A006 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 02/28/2022 |
| From: | NRC/NRR/VPOB |
| To: | |
| Armstrong G | |
| References | |
| Download: ML22060A006 (13) | |
Text
Vogtle Unit 3 4Q/2021 Performance Summary Construction Action Matrix Column:
Licensee Response Construction Safeguards Operational Reactor Safety Programs Readiness Design/ Procurement/ Construction/ Inspection/ Security Operational Engineering Fabrication Installation Testing Programs Programs Most Significant Inspection Findings No findings No findings No findings No findings 4Q/2021 this quarter G G this quarter this quarter this quarter No findings No findings No findings No findings 3Q/2021 this quarter this quarter this quarter G this quarter G No findings No findings No findings No findings 2Q/2021 this quarter this quarter W this quarter G this quarter No findings No findings No findings No findings No findings 1Q/2021 this quarter this quarter this quarter G this quarter this quarter Additional Inspection and Assessment Information List of Construction Inspection Reports List of Construction Assessment Reports/Inspection Plans Vogtle Unit 3 Findings Archive
Design Engineering Back to Top Procurement/Fabrication Back to Top Construction/Installation Identified By: NRC Identification Date: 10/20/2021 Significance: Green Item Type: Construction Finding Report: Vogtle Electric Generating Plant, Units 3 And 4 - NRC Integrated Inspection Reports 05200025/2021007, 05200026/2021007 Item Number: 05200025/2021007-01 Note: Open in Report (NCV)
Failure to Correct Cable Separation issues in panel SV3-IDSC-DT-1 A construction finding of very low safety significance with an associated NCV of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XVI, Corrective Action, was identified for the licensees failure to identify and correct conditions adverse to quality pertaining to Institute of Electrical and Electronic Engineers 384-1981 cable separation issues inside Class 1E dc and uninterruptible power supply system (IDS) regulating transformer panel SV3-IDSC-DT-1. The licensee failed to maintain the 1-inch separation required for safety and nonsafety-related cables within IDS C regulating transformer panel SV3-IDSC-DT-1 in accordance with electrical installation specification APP-G1-V8-001, Appendix B2, Separation and Segregation Spacing Requirements. Two conditions were identified. The licensee entered this finding into its corrective action program as condition report 50117479. Corrective actions for this issue included rework to restore compliance with the separation requirements and the initiation of a causal analysis.
The performance deficiency was of more than minor safety significance, and thus a finding, because it represented an adverse condition that rendered the quality of the safety function associated with IDS unacceptable or indeterminate and required substantive corrective action. The inspectors determined this finding was a performance deficiency of very low safety significance because if left uncorrected it could reasonably be expected to impair the design function of IDS for only one train of a multi-train system. The inspectors determined the finding was indicative of present licensee performance and was associated with the cross-cutting aspect of Work Management, in the area of Human Performance. The licensee failed to implement a process of planning, controlling, and executing work activities such that nuclear safety was the overriding priority. Specifically, the licensee failed to have a process in place for quality control to verify all cable separation nonconformances were addressed inside the panel.
Identified By: NRC Identification Date: 01/25/2021 Significance: White Item Type: Construction Finding Report: Vogtle Electric Generating Plant, Units 3 And 4 - NRC Initial Test Program and Operational Programs Integrated Inspection Reports 05200025/2021004, 05200026/2021004 Item Number: 05200025/2021010-01 Note: Open in Report (NCV)
Failure to Promptly Identify and Correct IEEE 384 Cable Separation and Seismic/Structural Nonconformances
The inspectors identified a White construction finding and associated apparent violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to promptly identify and correct conditions adverse to quality associated with the installation of Class 1E cables and associated raceways. Specifically, the licensee failed to promptly identify that cable separation was not maintained in accordance with RG 1.75 and IEEE 384-1981, failed to promptly identify widespread deficiencies in installation of seismic supports and structural components, and failed to timely correct these issues.
Identified By: NRC Identification Date: 04/20/2021 Significance: White Item Type: Construction Finding Report: Vogtle Electric Generating Plant, Units 3 And 4 - NRC Initial Test Program and Operational Programs Integrated Inspection Reports 05200025/2021004, 05200026/2021004 Item Number: 05200025/2021010-02 Note: Open in Report (NCV)
Failure to Accomplish Separation for Class 1E System Field Installations in Accordance with Applicable Instructions, Procedures, and Drawings The inspectors identified a White construction finding and associated apparent violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to maintain 1-inch vertical and horizontal separation between Class 1E electrical divisions and non-Class 1E electrical cables inside switchgear cabinets as specified in safety class C (safety related) APP-G1-V8-01, AP1000 Electrical Installation Specification.
Identified By: NRC Identification Date: 06/21/2021 Significance: Green Item Type: Construction Finding Report: Vogtle Electric Generating Plant, Units 3 And 4 - NRC Initial Test Program and Operational Programs Integrated Inspection Reports 05200025/2021004, 05200026/2021004 Item Number: 05200025/2021010-03 Note: Closed in Report (NCV)
Failure to Install Electrical Raceways and Connections in Accordance with Applicable Instructions, Procedures, and Drawings The inspectors identified a Green construction finding and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to install seismic Category I electrical raceways and connections in accordance with applicable instructions, procedures, and drawings.
Identified By: NRC Identification Date: 05/13/2021 Significance: Green Item Type: ITAAC Finding Report: Vogtle Electric Generating Plant, Units 3 And 4 - NRC Initial Test Program and Operational Programs Integrated Inspection Reports 05200025/2021004, 05200026/2021004 Item Number: 05200025/2021004-01 Note: Closed in Report (NCV)
Failure to Prescribe Instructions or Procedures for ITAAC activities that Affect Quality NRC inspectors identified a Green finding and associated NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, and with an associated Severity Level IV violation of
52.99(c)(1), ITAAC Closure Notification, for the licensees failure to demonstrate ITAAC acceptance criteria were satisfied in accordance with procedure ND-RA-001-006, Development and Approval of ITAAC Submittals (ICN, UIN, PCN). The licensee also failed to verify that prescribed inspections, tests, and analyses were performed and that the prescribed acceptance criteria were met for ITAAC C.2.6.09.05a in the ITAAC Closure Notification (ICN). Specifically, the licensee failed to verify the functionality of the active vehicle barriers. The licensee entered this issue into its corrective action program as condition report (CR) 50100179 and tested the functionality of the primary active vehicle barrier.
The performance deficiency was of more than minor safety significance and a finding because it is material to the acceptance criteria of the ITAAC, and the performance deficiency prevented the licensee from meeting the ITAAC Design Commitment. The finding was determined to be of very low safety significance because the finding did not impair a design function and the active vehicle barrier function was not required per 10 CFR 73.55 at that time. The inspectors concluded that this finding affected the cross-cutting area of human performance and crosscutting aspect of Basis for Decisions. Specifically, the licensee failed to verify the entire ITAAC acceptance criteria was met before submitting the ITAAC Closure Notification.
Identified By: NRC Identification Date: 05/22/2021 Significance: Green Item Type: Construction Finding Report: Vogtle Electric Generating Plant, Units 3 And 4 - NRC Initial Test Program and Operational Programs Integrated Inspection Reports 05200025/2021004, 05200026/2021004 Item Number: 05200025/2021004-02 Note: Closed in Report (NCV)
Failure to Follow Procedure 3-GENITPP-517 A self-revealed construction finding of very low safety significance with an associated NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified for the licensees failure to accomplish hot functional testing activities in procedure 3-GEN-ITPP-517, Precore Hot Functional Test Procedure, Version 4.1 in accordance with NMPAP-003, Procedure and Work Instruction Use and Adherence, Version 6.1. The licensee entered this issue into its CAP as CR 50093618, CR 50093597, and CR 50097436.
The performance deficiency was determined to be of more than minor significance because it represents a substantive failure to implement an adequate program, process, procedure, or quality oversight function. Specifically, the licensee failed to perform all steps in sequence, complete each step before moving to the next step, and sign off each step after completing it and before moving to the next step.
This caused the RCS pressure to increase above the low temperature overpressure relief valve setpoints.
The inspectors concluded that this finding affected the cross-cutting area of human performance and cross-cutting aspect of Challenge the Unknown. Specifically, the licensee did not have a complete understanding of how to properly execute a set of steps in procedure 3-GEN-ITPP-517 and did not seek clarification before proceeding.
Identified By: Licensee Identification Date: 01/21/2021 Significance: Green Item Type: ITAAC Finding Report: Vogtle Electric Generating Plant, Units 3 And 4 - NRC Integrated Inspection Reports 05200025/2021003, 05200026/2021003 Item Number: 05200025/2021003-02 Note: Open in Report (LIV)
Failure to Promptly Identify and Correct a Condition Adverse to Quality with Unqualified Drilling and Installation of Expansion Anchors into Safety Class C Concrete Structures 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, states, in part, Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. Contrary to this requirement, on or before January 21, 2021, the licensee failed to promptly identify and correct a condition adverse to quality. Specifically, the licensee identified on November 1, 2019 that a subcontractor who was not qualified to drill penetrations and install material into Safety Class C concrete structures under a licensee approved Appendix B Quality Assurance Program had been doing so under two separate contracts. These two contracts were developed to perform non-safety related activities for installation of the fire protection and suppression system. The licensees causal evaluation of the problem identified inadequate management and oversight over its subcontractors with no corrective actions to address the behaviors. The effectiveness review for the causal evaluation was closed on August 20, 2020, although it identified that not all of the contracts were changed as specified by the corrective action to prevent recurrence at the time of the review. Approximately five months later, on January 21, 2021, a subcontractor (one of the five unqualified subcontractors identified by the effectiveness review) who was not qualified to drill penetrations and install material into Safety Class C concrete structures under a licensee approved Appendix B Quality Assurance Program drilled into the Unit 3 auxiliary building rooftop and installed expansion anchors without work instructions approved for the activity. Edge boxes were fabricated and installed by sub-tier sheet metal workers without an approved work package or an approved ASME NQA-1 Standard subcontractor quality program.
This performance deficiency was of more than minor safety significance, and thus a finding, because it represented a substantive failure to establish or implement an adequate program, process, procedure, or quality oversight function. Drilling in reinforced concrete structures can adversely impact the function of the structure if portions of the reinforcing bar or embedded steel are damaged. Cleanliness of the holes being drilled can also adversely impact the function of the structure. This finding was of very low safety significance (Green) because the licensee demonstrated with reasonable assurance the design function of the auxiliary building was not impaired. This LIV is material to the ITAAC 3.3.00.02a.i.c (762) acceptance criteria because the as-built structures in the non-radiologically controlled area of the auxiliary building must conform to the approved design and will withstand the design basis loads specified in the design description without loss of structural integrity or the safety-related functions. This LIV is open pending an NRC review to verify adequate corrective actions have been developed and implemented so the deficiency can no longer prevent the ITAAC from being closed. This issue was documented in the licensees CAP as CR 50099464, CR 50075502, and CAR 80004896.
Identified By: Licensee Identification Date: 02/20/2021 Significance: Green Item Type: ITAAC Finding Report: Vogtle Electric Generating Plant, Units 3 And 4 - NRC Integrated Inspection Reports 05200025/2021003, 05200026/2021003 Item Number: 05200025/2021003-03 Note: Open in Report (LIV)
Unqualified Welding of Fire Extinguisher Brackets on the Unit 3 Containment Vessel 10 CFR 50, Appendix B, Criterion IX, Control of Special Processes, states Measures shall be established to assure that special processes, including welding, heat treating, and nondestructive testing, are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements. Contrary to this requirement, on February 20, 2021, a subcontractor who was not qualified to perform welding on safety related structures under a licensee approved Appendix B Quality Assurance Program welded three sets of fire extinguisher brackets on the Unit 3 containment vessel without a qualified procedure. The subcontractors work package was not qualified for welding to the containment vessel and did not contain
documents, drawings, or details that allowed welding to the containment vessel. The brackets were installed per a drawing detail that did not specify welding to the containment vessel. The drawing allowed for mounting to steel columns, permanent formwork plate, embedment plates, and modules.
This performance deficiency was of more than minor safety significance, and thus a finding, because it rendered the quality of the containment vessel unacceptable or indeterminate and required substantive corrective action. This finding was of very low safety significance (Green) because the licensee demonstrated with reasonable assurance the design function of the containment vessel was not impaired.
This LIV is material to the ITAAC 2.2.01.02a (91), 2.2.01.04a.ii (96), and 2.2.01.07.i (107) acceptance criteria because it affects the ASME Section III requirements for the as-built containment vessel and associated testing requirements. This LIV remains open pending restoration of the Unit 3 containment vessel to compliance with the ASME Section III Code requirements and an NRC review to verify adequate corrective actions have been developed and implemented such that the initial ITAAC conclusions remain valid and the deficiency can no longer prevent remaining ITAAC from being closed.
This issue was documented in the licensees CAP as CR 50099460, CR 50082701, and CAR 80004934.
Back to Top Inspection/Testing Identified By: NRC Identification Date: 10/15/2021 Significance: Green Item Type: ITAAC Finding Report: Vogtle Electric Generating Plant, Units 3 And 4 - NRC Initial Test Program and Operational Programs Integrated Inspection Reports 05200025/2021008, 05200026/2021008 Item Number: 05200025/2021008-01 Note: Open in Report (NCV)
Failure to Prescribe Instructions or Procedures for ITAAC Activities that Affect Quality NRC inspectors identified a Green ITAAC finding and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR 50), Appendix B, Criterion V, Instructions, Procedures, and Drawings, and with an associated Severity Level (SL) IV violation of 52.99(c)(1), ITAAC Closure Notification, for the licensees failure to coordinate and collaborate with the ITAAC Project Team (IPT) to identify and collect ITAAC determination basis input documents for ITAAC C.2.6.09.06 (Index Number 647) to demonstrate the vehicle barrier system could protect against the design basis threat vehicle bombs prior to submitting the ITAAC Closure Notification in accordance with procedure ND-RA-001-006, Development and Approval of ITAAC Submittals (ICN, UIN, PCN). The licensee entered this issue into its corrective action program (CAP) as condition report (CR) 50118429.
The performance deficiency was determined to be more than minor because it represented a substantive failure to establish or implement an adequate program, process, procedure, or quality oversight function.
The inspectors determined this finding was of very low safety significance (Green) because the vehicle barrier function was not required per 10 CFR 73.55 at that time. The inspectors determined the finding had a cross-cutting aspect of Conservative Bias in the area of Human Performance. Specifically, the licensee failed to use conservative decision making when submitting the ITAAC Closure Notice (ICN) without all the determination basis input documents finalized.
Identified By: NRC Identification Date: 3/17/2021 Significance: Green Item Type: ITAAC Finding Report: Vogtle Electric Generating Plant, Units 3 And 4 - NRC Integrated Inspection Reports 05200025/2021006, 05200026/2021006
Item Number: 05200025/2021006-01 Note: Closed in Report (NCV)
Failure to Follow Procedure B-GEN-ITPA-004 An ITAAC finding of very low safety significance with an associated NCV of Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was self-revealed for the licensees failure to follow its procedural guidance for troubleshooting external leakage from the Unit 3 spent fuel pool (SFP) and fuel transfer canal (FTC), which resulted in over-pressurization of the leak chase area between the SFP and FTC stainless steel liner and the surrounding Seismic Category I structural module. The licensee failed to adhere to procedure B-GEN-ITPA-004, Conduct of Test, Revision 24. Additionally, the procedure was not appropriate to the circumstances because it did not contain adequate guidance on when formal troubleshooting was required. The licensee entered this finding into its corrective action program as condition report 50083423. Corrective actions for this issue included repairs to the SFP and FTC liner, the leak chase, and the surrounding structural module to return them into conformance with the design.
The performance deficiency was of more than minor safety significance, and thus a finding, because it represented an adverse condition that rendered the quality of a structure (i.e., the SFP, FTC, and surrounding structural module) unacceptable and required substantive corrective action. The performance deficiency was also material to the acceptance criteria of ITAAC 3.3.00.02a.i.d (763) and prevented the licensee from meeting an ITAAC Design Commitment. The inspectors determined this finding was a performance deficiency of very low safety significance (Green) because there was reasonable assurance the structure or the applicable portions of the structure would have been able to meet its design function.
The inspectors determined the finding was indicative of present licensee performance and was associated with the cross-cutting aspect Challenge the Unknown, in the area of Human Performance. The licensee did not have a complete understanding of how to properly execute the set of steps in the procedure and clarification was not sought before proceeding.
Identified By: NRC Identification Date: 1/29/2021 Significance: Green Item Type: Construction Finding Report: Vogtle Electric Generating Plant, Units 3 And 4 - NRC Initial Test Program and Operational Programs Integrated Inspection Reports 05200025/2021002, 05200026/2021002 Item Number: 05200025/2021002-01 Note: Closed in Report (NCV)
Failure to Correct NRC Identified Violation The NRC inspectors identified a construction finding of very low safety significance and a non-cited violation (NCV) of Title 10 of the Code of Federal Regulations, Part 50 (10 CFR 50), Appendix B, Criterion XVI, "Corrective Action," for the licensee's failure to correct a deficiency in their Class 1E Direct Current (DC) and Uninterruptible Power Supply (UPS) (IDS) preoperational test procedure, 3-IDS-ITPP-501. The licensee entered this finding into their corrective action program as condition reports (CR) 50076165 and 50078235, and corrective action report (CAR) 80004604, to correct the preoperational test procedure.
The performance deficiency was of more than minor safety significance and a finding because it represented a substantive failure to establish or implement an adequate program, process, procedure, or quality oversight function. The finding was determined to be of very low safety significance (Green) because the finding did not impair a design function. The inspectors concluded that this finding affected the cross-cutting area of human performance and the crosscutting aspect of avoiding complacency. The proximate cause was attributed to a failure to use proper human error reduction techniques, namely inadequate verification by personnel. [H.12]
Identified By: NRC
Identification Date: 2/1/2021 Significance: Green Item Type: Construction Finding Report: Vogtle Electric Generating Plant, Units 3 And 4 - NRC Initial Test Program and Operational Programs Integrated Inspection Reports 05200025/2021002, 05200026/2021002 Item Number: 05200025/2021002-02 Note: NCV Failure to Use Worst Case Load Profile for IDS Battery Service Test The NRC inspectors identified a performance deficiency and ITAAC finding of very low safety significance (Green), and a NCV of 10 CFR 50, Appendix B, Criterion III, Design Control for the licensees failure to translate the most limiting accident load profiles and load currents that envelope the battery bank design duty cycle into the battery service tests specified by procedure 3-IDS-ITPP-501, Class 1E DC and UPS Preoperational Test. The licensee entered this finding into their corrective action program as CR 50078637 and changed their procedure to test the worst-case load profile with the worst-case load currents for battery divisions IDSA, IDSB, IDSC, and IDSS service tests.
The performance deficiency was of more than minor safety significance and a finding because it represented a substantive failure to establish or implement an adequate program, process, procedure, or quality oversight function. The finding was determined to be of very low safety significance (Green) because the finding did not impair a design function. The inspectors concluded that this finding affected the cross-cutting area of human performance and crosscutting aspect of challenge the unknown.
Specifically, the licensee failed to adequately investigate which profiles were the most limiting for each division and the spare battery to ensure the test procedure encompassed the requirements. [H.11]
Identified By: NRC Identification Date: 2/1/2021 Significance: Green Item Type: Construction Finding Report: Vogtle Electric Generating Plant, Units 3 And 4 - NRC Initial Test Program and Operational Programs Integrated Inspection Reports 05200025/2021002, 05200026/2021002 Item Number: 05200025/2021002-03 Note: NCV Failure to Place IDSB Battery on Float for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> After Being on Equalize Voltage The NRC inspectors identified a construction finding of very low safety significance and a NCV of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," for the licensees failure to place the IDSB 24-hour battery on float voltage for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> subsequent to it being on equalize voltage. The licensee entered this finding into their corrective action program as CR 50085270 to reperform the IDSB service test with the appropriate requisite float voltage.
The performance deficiency was of more than minor safety significance and a finding because it represented a substantive failure to establish or implement an adequate program, process, procedure, or quality oversight function. The finding was determined to be of very low safety significance (Green) because the finding did not impair a design function. The inspectors concluded that this finding affected the cross-cutting area of human performance and crosscutting aspect of conservative bias. Specifically, the licensee proceeded with testing without questioning whether a 72-hour float was required. [H.14]
Identified By: NRC Identification Date: 2/2/2021 Significance: Green Item Type: Construction Finding Report: Vogtle Electric Generating Plant, Units 3 And 4 - NRC Initial Test Program and Operational Programs Integrated Inspection Reports 05200025/2021002, 05200026/2021002
Item Number: 05200025/2021002-04 Note: NCV Failure to Translate Design Requirements into IDS Test Procedure The NRC inspectors identified a construction finding with three examples of very low safety significance and a NCV of 10 CFR 50, Appendix B, Criterion III, "Design Control," for the licensees failure to translate the design requirements and acceptance limits in applicable design documents into preoperational test procedure 3-IDS-ITPP-501, Class 1E DC and UPS Preoperational Test. Specifically, the licensee failed to translate design requirements from NEMA PE 5-1985, Utility Type Battery Chargers, SV3-IDS-T1-503, Class 1E DC and Uninterruptible Power Supply System Preoperational Test Specification, and the UFSAR Section 14.2.9.1.14. The licensee entered this finding into their corrective action program as CRs 50080097, 50079776, and 50089774, respectively, to restore compliance. The performance deficiency was of more than minor safety significance and a finding because it represented a substantive failure to establish or implement an adequate program, process, procedure, or quality oversight function.
The finding was determined to be of very low safety significance (Green) because the finding did not impair a design function. The inspectors concluded that this finding affected the cross-cutting area of human performance and crosscutting aspect of consistent process. Specifically, the licensee used an inconsistent approach to ensure that all requirements were translated into the procedure. [H.13]
Identified By: NRC Identification Date: 2/24/2021 Significance: Green Item Type: Construction Finding Report: Vogtle Electric Generating Plant, Units 3 And 4 - NRC Initial Test Program and Operational Programs Integrated Inspection Reports 05200025/2021002, 05200026/2021002 Item Number: 05200025/2021002-05 Note: NCV Failure to Control Design Calculation for Three Battery Cells Bypassed The NRC inspectors identified a construction finding of very low safety significance and a NCV of 10 CFR 50, Appendix B, Criterion VII, "Control of Purchased Material, Equipment, and Services," for the licensees failure to control the quality of design requirements and acceptance criteria in calculations used to determine voltage margins after battery discharge. The licensee entered this into their corrective action program as CR 50080010 and CAP IR 2021-2177. Corrective actions included using a different battery profile that used a higher final cell voltage which ensured at least 210VDC after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of discharge following a design basis accident with three cells bypassed.
The performance deficiency was of more than minor safety significance and a finding because it represented a substantive failure to establish or implement an adequate program, process, procedure, or quality oversight function. The finding was determined to be of very low safety significance (Green) because the finding did not impair a design function. The inspector concluded that this finding affected the cross-cutting area of human performance and crosscutting aspect of documentation. Specifically, the licensee failed to consider all potential scenarios for the battery calculation. [H.7]
Identified By: NRC Identification Date: 1/20/2021 Significance: Green Item Type: Construction Finding Report: Vogtle Electric Generating Plant, Units 3 And 4 - NRC Initial Test Program and Operational Programs Integrated Inspection Reports 05200025/2021002, 05200026/2021002 Item Number: 05200025/2021002-06 Note: NCV Inadequate Startup Testing Procedures for Establishing Initial Criticality
The NRC inspectors identified a construction finding of very low safety significance (Green) and a NCV of 10 CFR 50, Appendix B, Criterion III, Design Control, for the licensees failure to correctly translate applicable regulatory requirements and the design basis into specifications and procedures for performing the Unit 3 initial plant startup testing activities of achieving initial criticality in a controlled manner, measuring the isothermal temperature coefficient (ITC), and calculating the moderator temperature coefficient (MTC) of reactivity. The licensee entered this finding into its corrective action program as CR 50086434 for evaluation and identification of appropriate corrective actions.
The performance deficiency was of more than minor safety significance, and thus a finding, because it represented a substantive failure to establish or implement an adequate program, process, procedure, or quality oversight function. This finding was associated with an SSC (i.e. reactor system) and was a licensee performance deficiency of very low safety significance (Green) because the procedure was not implemented. The inspectors concluded this finding affected the cross-cutting area of human performance and the cross-cutting aspect of teamwork. Consistency between the procedures and test specification required a coordinated effort between three organizations. This was not effectively done during initial drafting of the procedures. [H.4]
Identified By: NRC Identification Date: 2/12/2021 Significance: Green Item Type: Construction Finding Report: Vogtle Electric Generating Plant, Units 3 And 4 - NRC Initial Test Program and Operational Programs Integrated Inspection Reports 05200025/2021002, 05200026/2021002 Item Number: 05200025/2021002-07 Note: NCV Inadequate Startup Testing Procedures for Initial Fuel Loading The NRC inspectors identified a construction finding of very low safety significance (Green) and a NCV of 10 CFR 50, Appendix B, Criterion III, Design Control, for the licensees failure to correctly translate applicable regulatory requirements and the design basis into specifications and procedures for performing the Unit 3 initial plant startup testing activity of initial fuel loading. The licensee entered this finding into its corrective action program as CR 50086035 for evaluation and identification of appropriate corrective actions.
The performance deficiency was of more than minor safety significance, and thus a finding, because it represented a substantive failure to establish or implement an adequate program, process, procedure, or quality oversight function. This finding was associated with an SSC (i.e. reactor system) and was a licensee performance deficiency of very low safety significance (Green) because the procedure was not implemented. The inspectors concluded this finding affected the cross-cutting area of human performance and the cross-cutting aspect of documentation. The proximate cause of the performance deficiency was primarily attributed to the failure to create accurate documentation. Revision 1 of the test procedure was archived without sufficient development and it was not adequately reviewed prior to approval. [H.7]
Back to Top Security Programs Back to Top Operational Programs Identified By: SNC
Identification Date: 08/12/2021 Significance: Green Item Type: Construction Finding Report: Vogtle Electric Generating Plant, Units 3 And 4 - NRC Initial Test Program and Operational Programs Integrated Inspection Reports 05200025/2021005, 05200026/2021005 Item Number: 05200025/2021005-01 Note: Closed in Report (NCV)
Failure to Follow Procedure 3-IDSC-SOP-002 A self-revealed construction finding of very low safety significance with an associated noncited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified for the licensees failure to accomplish activities in procedure 3-IDSC-SOP-002, Class 1E AC System - Division C, Version 0 in accordance with procedure NMP-AP-003, Procedure and Work Instruction Use and Adherence, Version 6.1. The licensee entered this issue into its corrective action program (CAP) as condition report (CR) 50103788, CR 50103789, and CR 50103907.
The performance deficiency was determined to be of more than minor significance and thus a finding because it represented a substantive failure to implement an adequate program, process, procedure, or quality oversight function. The inspectors determined the finding was of very low safety significance (Green) because the event impaired only one train of the IDS. The inspectors determined the finding had a cross-cutting aspect of H.2, Field Presence, in the area of Human Performance. Specifically, senior managers did not ensure that operators performing 3-IDS-SOP-002 had adequate supervisory and management oversight of work activities which led to plant equipment being damaged.
Identified By: NRC Identification Date: 09/30/2021 Significance: Green Item Type: Construction Finding Report: Vogtle Electric Generating Plant, Units 3 And 4 - NRC Initial Test Program and Operational Programs Integrated Inspection Reports 05200025/2021005, 05200026/2021005 Item Number: 05200025/2021005-02 Note: Closed in Report (NCV)
Failure to Obtain a License Amendment Prior to Altering Dynamic Restraint Qualification Requirements The NRC inspectors identified a performance deficiency and construction finding of very low safety significance and an associated Severity Level (SL) IV non-cited violation (NCV) of 10 CFR 50.59, Changes, tests, and experiments, for the licensees failure to perform a written safety evaluation prior to implementing a change to remove ASME QME-1-2007 commitments from the UFSAR in accordance with procedure ND-LI-VNP-002. The licensee entered this issue into its corrective action program as CR 50098695.
The inspectors determined that the failure to follow procedure ND-LI-VNP-002 to perform a 10 CFR 50.59 evaluation for the removal of ASME QME-1-2007 commitments from the design bases was a violation of 10 CFR 50.59(d)(1), and a performance deficiency. Per the guidance in IMC 0613, Appendix E, Examples of Minor Construction Issues, the performance deficiency was determined to be more than minor, and thus a finding, because it represented a substantive failure to establish or implement an adequate program, process, procedure, or quality oversight function. Specifically, the removal of QME 2007 for dynamic restraints constituted a more than minimal increase in the likelihood of a malfunction of a structure, system, or component important to safety and there was a reasonable likelihood that the change would have required Commission review and approval prior to implementation in accordance with 10 CFR 50.59(c)(2)(ii). The inspectors determined the finding had a cross-cutting aspect of H.3, Change Management in the area of Human Performance. Specifically, the licensee failed to ensure the process
for reviewing the change to remove QME-1-2007 for dynamic restraints was systematic in that all aspects of QME-1-2007 were evaluated for their impact on dynamic restraints.
Identified By: NRC Identification Date: 09/30/2021 Significance: Green Item Type: ITAAC Finding Report: Vogtle Electric Generating Plant, Units 3 And 4 - NRC Initial Test Program and Operational Programs Integrated Inspection Reports 05200025/2021005, 05200026/2021005 Item Number: 05200025/2021005-03 Note: Closed in Report (NCV)
Failure to Demonstrate Qualification of Valve Nonmetallic Parts NRC inspectors identified a performance deficiency and ITAAC finding of very low safety significance and an NCV of 10 CFR 50.49(e)(5), Environmental qualification of electric equipment important to safety for nuclear power plants, for the licensees failure to establish the qualified lives of all nonmetallic components necessary for the completion of the safety function of the squib and main steam isolation (MSI) valves in accordance with procedure APP-GW-G1-002, "AP1000 Equipment Qualification Methodology." The licensee entered this issue into its CAP as CR 50096894.
The performance deficiency was determined to be more than minor, and thus a finding, because it is material to the acceptance criteria of the ITAAC, and the performance deficiency prevented the licensee from meeting the ITAAC Design Commitment. The inspectors determined this finding was of very low safety significance because the finding did not impair a design function of the valves. The inspectors determined no cross-cutting aspect applied because the performance deficiency did not reflect current licensee performance.
Identified By: NRC Identification Date: 07/19/2021 Significance: Green Item Type: ITAAC Finding Report: Vogtle Electric Generating Plant, Units 3 And 4 - NRC Initial Test Program and Operational Programs Integrated Inspection Reports 05200025/2021005, 05200026/2021005 Item Number: 05200025/2021005-04 Note: Closed in Report (NCV)
Failure to Demonstrate Qualification of Containment High Radiation Monitor Door Gasket NRC inspectors identified an ITAAC finding and associated NCV of 10 CFR 50.49.e(5) for the failure to establish the qualified life of the Containment High Range Monitor (CHRM) door gasket in accordance with Institute of Electrical and Electronics Engineers Standard (IEEE) 323-1974. The licensee entered this issue into its CAP as CR 50096896 and CAP-IR-2021-6870 and is working on corrective actions to address the issue.
The performance deficiency was determined to be more than minor, and thus a finding, because it represented an adverse condition that rendered the quality of a system, structure, or component (SSC),
unacceptable or indeterminate, and required substantive corrective action. The inspectors determined that the finding was of very low safety significance because the finding was not associated with a system or structure in risk importance table. The inspectors determined the finding was associated with the cross-cutting aspect of Consistent Process in the area of Human Performance. Specifically, the licensee failed to use a consistent, systematic approach to make decisions whether the AP1000 harsh environment included wetted environments.
Identified By: NRC Identification Date: 07/9/2021
Significance: Green Item Type: ITAAC Finding Report: Vogtle Electric Generating Plant, Units 3 And 4 - NRC Initial Test Program and Operational Programs Integrated Inspection Reports 05200025/2021005, 05200026/2021005 Item Number: 05200025/2021005-05 Note: Closed in Report (NCV)
Failure to Qualify EPAs in Accordance with IEEE 317 NRC identified an ITAAC finding and associated violation of 10 CFR 50, Appendix B, Criterion III, for the failure to seismically or environmentally qualify the Electrical Penetration Assemblies (EPAs) in accordance with IEEE 317, Section 6.2.10. Specifically, the licensee failed to test or analyze the as installed assembly including cable configurations, terminations, termination box, raceways, and their respective interactions. The licensee entered this issue into its CAP as CR 50104476 and is working on corrective actions to address the issue.
The performance deficiency was determined to be more than minor, and thus a finding, because it represented an adverse condition that rendered the quality of an SSC unacceptable or indeterminate and required substantive corrective action. The inspectors determined the finding was of very low safety significance because the licensee was able to show through additional analysis that the finding did not impact a design function of the EPAs. The inspectors determined the finding was associated with the cross-cutting aspect of Change Management in the area of Human Performance. Specifically, the licensee leadership failed to use a systematic process for evaluating and implementing changes to as installed SSCs compared to configurations that were environmentally qualified so that nuclear safety remained the overriding priority.
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