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Category:Inspection Report
MONTHYEARML24032A0252024-02-0505 February 2024 NRC Initial Test Program and Operational Programs Integrated Inspection Report 05200026-2023009 ML24031A6102024-01-31031 January 2024 Cyber Security Inspection Report 05200026/2024401 - Public IR 05000424/20244032024-01-26026 January 2024 Information Request for the Cyber-Security Baseline Inspection, Notification to Perform Inspection 05000424/2024403; 05000425/2024403 ML23312A3502023-11-14014 November 2023 Integrated Inspection Report 05200026/2023003 ML23318A4582023-11-14014 November 2023 Integrated Inspection Report 05200025/2023003 IR 05000424/20234022023-11-0606 November 2023 Security Baseline Inspection Report 05000424/2023402 and 05000425/2023402 IR 05000424/20230032023-10-27027 October 2023 Integrated Inspection Report 05000424/2023003 and 05000425/2023003 ML23254A2032023-09-13013 September 2023 Initial Test Program and Operational Programs Inspection Report 05200025/2023013 IR 05000424/20230912023-09-0505 September 2023 Plan Units 1 and 2 - NRC Investigation Report 2-2022-006 and Notice of Violation - NRC Inspection Report 05000424/2023091 and 05000425/2023091 ML23234A3002023-09-0101 September 2023 NRC Integrated Inspection Report 05200026/2023003 IR 05000424/20230052023-08-29029 August 2023 Updated Inspection Plan for Vogtle Electric Generating Plant, Units 1 & 2 - Report 05000424/2023005 and 05000425/2023005 ML23223A0022023-08-14014 August 2023 (Vegp), Unit 3, Integrated Inspection Report 05200025/2023002 IR 05000424/20230112023-08-11011 August 2023 Biennial Problem Identification and Resolution Inspection Report 05000424/2023011 and 05000425/2023011 ML23215A0822023-08-0404 August 2023 (Vego), Unit 3 Initial Test Program and Operational Programs Integrated 05200025/2023011 Inspection Report IR 05000424/20234012023-07-31031 July 2023 Security Baseline Inspection Report 05000424/2023401 and 05000425/2023401 (Cover Letter) ML23212B0612023-07-31031 July 2023 Security Baseline Inspection Report 05200025/2023401 ML23216A0962023-07-26026 July 2023 Document Request for Vogtle 1 & 2 RP Inspection, Report No. 05000424/2023003 and 05000425/2023003 IR 05000424/20230022023-07-24024 July 2023 Integrated Inspection Report 05000424/2023002 and 05000425/2023002 ML23198A3802023-07-19019 July 2023 NRC Integrated Inspection Report 05200026/2023002 ML23199A0892023-07-18018 July 2023 (Vegp), Unit 4 Initial Test Program and Operational Programs Integrated Inspection Report 05200026/2023007 IR 05000424/20233012023-06-30030 June 2023 NRC Operator License Examination Report 05000424/2023301 and 05000425/2023301 ML23128A2932023-05-11011 May 2023 NRC Integrated Inspection Report 05200026/2023001 ML23129A0222023-05-10010 May 2023 (Vegp), Unit 3 - Integrated Report 05200025/2023001 ML23128A3492023-05-0909 May 2023 (Vegp), Unit 4 Initial Test Program and Operational Programs Integrated Inspection Report 05200026/2023006 ML23121A3202023-05-0404 May 2023 NRC Initial Test Program and Operational Programs Integrated Inspection Report 05200025/2023010 IR 05000424/20040252023-04-28028 April 2023 Public Meeting Summary - Vogtle Electric Generating Plant, Units 1, 2, 3, & 4 Docket No. 5000424, 5000425, 5200025, 5200026, Meeting Number 20230375 IR 05000424/20230012023-04-26026 April 2023 Integrated Inspection Report 05000424/2023001 and 05000425/2023001 IR 05000424/20230902023-03-30030 March 2023 NRC Inspection Report 05000424/2023090 and 05000425/2023090, and Investigation Report 2-2022-006; and Apparent Violation ML23083B3702023-03-24024 March 2023 Security Baseline Inspection Report 05200026/2023401 IR 05000424/20220062023-03-0101 March 2023 Annual Assessment Letter for Vogtle Electric Generating Plant Units 1 and 2, NRC Inspection Reports 05000424/2022006 and 05000425/2022006 ML23044A3902023-02-14014 February 2023 Integrated Inspection Report05200025 2022007 ML23040A3612023-02-0909 February 2023 NRC Initial Test Program and Operational Programs Integrated Inspection Report 05200026/2022008 ML23040A0422023-02-0909 February 2023 NRC Initial Test Program and Operational Programs Integrated Inspection Report 05200025/2022008 ML23033A3972023-02-0707 February 2023 NRC Integrated Inspection Report 05200026/2022007 IR 05000424/20220042023-01-23023 January 2023 Integrated Inspection Report 05000424/2022004 and 05000425/2022004 ML22356A2932022-12-23023 December 2022 Information Request for the Cyber Security Baseline Security Inspection, Notification to Perform Inspection IR 05000424/20220102022-12-0202 December 2022 Design Basis Assurance Inspection (Teams) Inspection Report 05000424/2022010 and 05000425/2022010 ML22327A0532022-11-30030 November 2022 Security Baseline Inspection Report 05200026/2022401 Cover Letter IR 05000424/20224032022-11-28028 November 2022 Security Baseline Inspection Report 05000424/2022403 and 05000425/2022403 (Cover Letter) ML22314A0702022-11-14014 November 2022 NRC Integrated Inspected Reports 05200025/2022005, 05200026/2022005 ML22318A1602022-11-14014 November 2022 Integrated Inspection Report 05200025/2022010 ML22304A1812022-11-0808 November 2022 NRC Initial Test Program and Operational Programs Integrated Inspection Report 05200025/2022011 ML22311A0062022-11-0808 November 2022 NRC Initial Test Program and Operational Programs Integrated Inspection Report 05200026/2022006 IR 05000424/20220032022-10-27027 October 2022 Integrated Inspection Report 05000424/2022003 and 05000425/2022003 IR 05000424/20220052022-08-24024 August 2022 Updated Inspection Plan for Vogtle Electric Generating Plant, Units 1 & 2 - Report 05000424/2022005 and 05000425/2022005 ML22230C6702022-08-22022 August 2022 NRC Initial Test Program and Operational Programs Integrated Inspection Report 05200025/2022006 ND-22-0655, ITAAC Closure Notification on Completion of ITAAC 2.5.01.03a (Index Number 511)2022-08-12012 August 2022 ITAAC Closure Notification on Completion of ITAAC 2.5.01.03a (Index Number 511) IR 05000424/20220022022-08-11011 August 2022 Integrated Inspection Report 05000424/2022002 and 05000425/2022002 ML22220A1342022-08-0909 August 2022 Review of the Refueling Outage 1R23 (Fall 2021) Steam Generator Tube Inspection Report IR 05000424/20224012022-08-0404 August 2022 Cyber Security Inspection Report 05000424/2022401 and 05000425/2022401 2024-02-05
[Table view] Category:Letter
MONTHYEARML24032A0252024-02-0505 February 2024 NRC Initial Test Program and Operational Programs Integrated Inspection Report 05200026-2023009 ML24010A0712024-01-31031 January 2024 Exemption from Select Requirements of 10 CFR Part 73 (Security Notifications, Reports and Recordkeeping and Suspicious Activity Reporting) ML24031A6102024-01-31031 January 2024 Cyber Security Inspection Report 05200026/2024401 - Public ML24029A0592024-01-30030 January 2024 Request for Withholding Information from Public Disclosure Responses to NRC Request for Additional Information for Refueling Outage 1R24 Steam Generator Tube Inspection Report Enclosure 2, GAE-NRCD-RF-LR-000002 P-Attachment, Rev. 0 ML24016A1132024-01-30030 January 2024 Correction of Unit 1 Amendment Nos. 96 and 190 and Unit 2 Amendment Nos. 74 and 173 Adoption of Standard Technical Specifications Westinghouse Plants NL-24-0031, Inservice Inspection Program Owner'S Activity Report (OAR-1) for Outage 2R232024-01-29029 January 2024 Inservice Inspection Program Owner'S Activity Report (OAR-1) for Outage 2R23 IR 05000424/20244032024-01-26026 January 2024 Information Request for the Cyber-Security Baseline Inspection, Notification to Perform Inspection 05000424/2024403; 05000425/2024403 NL-24-0020, Plan, Unit 1 Responses to NRC Request for Additional Information for Refueling Outage 1R24 Steam Generator Tube Inspection Report2024-01-22022 January 2024 Plan, Unit 1 Responses to NRC Request for Additional Information for Refueling Outage 1R24 Steam Generator Tube Inspection Report ML23347A2092024-01-17017 January 2024 Voluntary Requests for Data, Information, And/Or Observation ML23279A0042024-01-17017 January 2024 Amendment No. 194 to Remove Combined License Appendix C NL-23-0926, Correction of Technical Specification Typographical Error2024-01-12012 January 2024 Correction of Technical Specification Typographical Error ML23341A2042024-01-12012 January 2024 Request for Additional Information Exemption Requests for Physical Barriers (EPID L-2023-LLE-0018 & L-2023-LLE-0021) ML23345A1312024-01-0303 January 2024 Withholding Letter - SNC Fleet - Physical Barriers Exemption (L-2023-LLE-0018 and L-2023-LLE-0021) ML23317A2072023-12-22022 December 2023 Issuance of Amendments 223 and 206 Regarding Revision to Technical Specifications to Adopt TSTF-339-A, Relocate Technical Specification Parameters to the COLR Consistent with WCAP-1448 ML23335A1222023-12-19019 December 2023 Safety Evaluation Regarding Implementation of Mitigating Strategies Related to Order EA-12-049 (EPID L-2023-LRQ-0002) - Letter ML23353A1702023-12-19019 December 2023 LAR-22-002, TS 3.8.3 Inverters Operating Completion Time Extension Letter ML23310A2922023-12-0707 December 2023 Issuance of Amendment for Exception to Regulatory Guide 1.163, LAR 23 007 ML23339A1812023-12-0707 December 2023 Correction Letter Regarding License Amendment Request: More Restrictive Action for Technical Specification 3.1.9 ML23338A2182023-12-0606 December 2023 Project Manager Reassignment NL-23-0878, Request for Exemption from Security Event Notification Implementation2023-11-29029 November 2023 Request for Exemption from Security Event Notification Implementation ML23289A1632023-11-28028 November 2023 Letter and Amendment 195 and 192 LAR-23-006R1 TS 3.1.9 More Restrictive Action NL-23-0827, Response to Requests for Additional Information for a License Amendment Request and a Proposed Alternative Related to TS 3.4.142023-11-17017 November 2023 Response to Requests for Additional Information for a License Amendment Request and a Proposed Alternative Related to TS 3.4.14 ML23318A4582023-11-14014 November 2023 Integrated Inspection Report 05200025/2023003 ML23312A3502023-11-14014 November 2023 Integrated Inspection Report 05200026/2023003 ML23306A3552023-11-0808 November 2023 NRC Initial Test Program and Operational Programs Integrated Inspection Report 052000/262023008 ML23268A0572023-11-0707 November 2023 Issuance of Amendments 194 & 191 Request for License Amendment Relocation of Technical Specification 3.7.9, Spent Fuel Pool Makeup Water Sources (LAR-23-003) IR 05000424/20234022023-11-0606 November 2023 Security Baseline Inspection Report 05000424/2023402 and 05000425/2023402 IR 05000424/20230032023-10-27027 October 2023 Integrated Inspection Report 05000424/2023003 and 05000425/2023003 ML23291A1512023-10-18018 October 2023 Information Request for the Cyber Security Baseline Inspection, Notification to Perform Inspection 0520026/2024401 ML23263A9852023-10-12012 October 2023 Issuance of Amendments Nos. 221 and 204, Regarding Technical Specification 5.5.11.C, Acceptance Criteria for Charcoal Filter Testing ML23283A0472023-10-0808 October 2023 Neop Letter Dated October 8, 2023 - Vogtle 3 & 4 - TS 3.7.6 License Amendment Request NL-23-0750, Response to Second Request for Additional Information Regarding License Amendment Request: Technical Specification Revision to Adopt TSTF-339-A, Relocate Technical Specification Parameters to the Colr2023-10-0404 October 2023 Response to Second Request for Additional Information Regarding License Amendment Request: Technical Specification Revision to Adopt TSTF-339-A, Relocate Technical Specification Parameters to the Colr NL-23-0745, Refueling Outage 1R24 Steam Generator Tube Inspection Report2023-09-22022 September 2023 Refueling Outage 1R24 Steam Generator Tube Inspection Report ML23254A2032023-09-13013 September 2023 Initial Test Program and Operational Programs Inspection Report 05200025/2023013 ML23241B0212023-09-12012 September 2023 Review of Quality Assurance Topical Report ML23234A2352023-09-0808 September 2023 Request for Withholding Information from Public Disclosure Notification of Full Compliance of Required Action for NRC Order EA-12-049 Mitigation Strategies for Beyond-Design-Basis External Events IR 05000424/20230912023-09-0505 September 2023 Plan Units 1 and 2 - NRC Investigation Report 2-2022-006 and Notice of Violation - NRC Inspection Report 05000424/2023091 and 05000425/2023091 ML23234A3002023-09-0101 September 2023 NRC Integrated Inspection Report 05200026/2023003 ML23243A0092023-08-31031 August 2023 Updated Inspection Plan for Vogtle Electric Generating Plant, Units 3 & 4 (Report 05200025 2023005 & 05200026 2023005) NL-23-0695, Response to Round 2 Request for Additional Information Regarding License Amendment Request for Technical Specification 3.8.3, Inverters Operating, Completion Time Extension (LAR-22-002S2)2023-08-31031 August 2023 Response to Round 2 Request for Additional Information Regarding License Amendment Request for Technical Specification 3.8.3, Inverters Operating, Completion Time Extension (LAR-22-002S2) ML23243B0252023-08-30030 August 2023 Exam Corporate Notification Letter (210 Day) IR 05000424/20230052023-08-29029 August 2023 Updated Inspection Plan for Vogtle Electric Generating Plant, Units 1 & 2 - Report 05000424/2023005 and 05000425/2023005 NL-23-0666, License Amendment Request: Remove Combined License Appendix C (LAR 23-008)2023-08-28028 August 2023 License Amendment Request: Remove Combined License Appendix C (LAR 23-008) 2024-02-05
[Table view] Category:OI Investigation Report
MONTHYEARIR 05000424/20230902023-03-30030 March 2023 NRC Inspection Report 05000424/2023090 and 05000425/2023090, and Investigation Report 2-2022-006; and Apparent Violation ML23081A0042023-03-28028 March 2023 NRC Office of Investigations Report 2-2021-020 and Vogtle Electric Generating Plant, Unit 3 - NRC Inspection Report 05200025/2022011 and Apparent Violations IR 05000424/20214012021-09-14014 September 2021 NRC Investigation Report 2-2020-014 and NRC Inspection Report 05000424/2021401 and 05000425/2021401 ML1125705212011-09-13013 September 2011 EA-11-119, Vogtle Electric Generating Plant: Failure to Report an Arrest by a Contract Employee (Office of Investigations Case Number 2-2011-010) 2023-03-30
[Table view] |
Inspection Report - Vogtle - 2023090 |
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Text
March 30, 2023
SUBJECT:
VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 - NRC INSPECTION REPORT 05000424/2023090 AND 05000425/2023090, AND INVESTIGATION REPORT 2-2022-006; AND APPARENT VIOLATION
Dear R. Keith Brown:
This letter refers to the investigation completed on October 31, 2022, by the U.S. Nuclear Regulatory Commissions (NRC) Office of Investigations (OI) regarding the Southern Nuclear Operating Companys (SNC) Vogtle Electric Generating Plant (Vogtle), Units 1 and 2. The purpose of the investigation was to determine whether a former supervisor and two employees of a contractor at Vogtle deliberately logged onto an incorrect radiation work permit (RWP) prior to entering Unit 1 containment during the 1R23 refueling outage. A factual summary of the OI investigation is provided as Enclosure 1.
The incident occurred during the night shift on September 20, 2021, when the three individuals entered Unit 1 containment while logged on an auxiliary building RWP. Based on the results of the NRCs review of the OI investigation report, one apparent violation (AV) was identified and is being considered for escalated enforcement action in accordance with the NRC Enforcement Policy. The current Enforcement Policy is included on the NRCs Web site at http://www.nrc.gov/
about-nrc/regulatory/enforcement/enforce-pol.html. The AV is discussed in the inspection report provided as Enclosure 2.
The AV involves the failure to comply with RWP 21-0010, which was a self-brief RWP with electronic dosimeter alarm setpoints appropriate for certain areas of low radiological risk and did not allow access into containment. Use of this RWP to enter containment effectively bypassed certain administrative controls implemented by the radiation protection department during the refueling outage, such as pre-entry briefings on current radiological conditions and the ability to monitor worker exposures in real-time using transmitting dosimetry. When the three individuals entered containment on RWP 21-0010, contrary to NMP-HP-302, Restricted Area Classification, Postings, and Access Control, they caused SNC to be in violation of Vogtle Units 1 and 2 Technical Specification 5.4.1. In addition, the NRC has concluded that the actions of the supervisor in this incident appears to have been deliberate.
Before the NRC makes its enforcement decision, we are providing you an opportunity to:
(1) respond to the apparent violation addressed in this inspection report within 30 days of the date of this letter, (2) request a Pre-decisional Enforcement Conference (PEC), or (3) request Alternative Dispute Resolution (ADR). If a PEC is held, the NRC will issue a press release to announce the time and date of the conference; however, the PEC will be closed to public
R. observation since information related to an Office of Investigations report will be discussed and the report has not been made public. If you decide to participate in a PEC or pursue ADR, please contact Binoy Desai at 404-997-4519 within 10 days of the date of this letter. A PEC should be held within 30 days and an ADR session within 45 days of the date of this letter.
If you choose to provide a written response, it should be clearly marked as a Response to Apparent Violation in NRC Inspection Report 05000424,425/2023090; EA-22-108 and should include for each apparent violation: (1) the reason for the apparent violation or, if contested, the basis for disputing the apparent violation; (2) the corrective steps that have been taken and the results achieved; (3) the corrective steps that will be taken; and (4) the date when full compliance will be achieved. Your response may reference or include previously docketed correspondence, if the correspondence adequately addresses the required response.
Additionally, your response should be sent to the NRCs Document Control Center, with a copy mailed to Laura Pearson, Director, Division of Reactor Safety, Region II, 245 Peachtree Center Avenue NE, Atlanta, GA 30303, within 30 days of the date of this letter. If a response is not received within the time specified or an extension of time has not been granted by the NRC, the NRC will proceed with its enforcement decision or schedule a PEC.
If you choose to request a PEC, the conference will afford you the opportunity to provide your perspective on these matters and any other information that you believe the NRC should take into consideration before making an enforcement decision. The decision to hold a predecisional enforcement conference does not mean that the NRC has determined that a violation has occurred or that enforcement action will be taken. This conference would be conducted to obtain information to assist the NRC in making an enforcement decision. The topics discussed during the conference may include information to determine whether a violation occurred, information to determine the significance of a violation, information related to the identification of a violation, and information related to any corrective actions taken or planned.
In lieu of a PEC, you may also request ADR with the NRC in an attempt to resolve this issue.
ADR is a general term encompassing various techniques for resolving conflicts using a neutral third party. The technique that the NRC has decided to employ is mediation. Mediation is a voluntary, informal process in which a trained neutral (the mediator) works with parties to help them reach resolution. If the parties agree to use ADR, they select a mutually agreeable neutral mediator who has no stake in the outcome and no power to make decisions. Mediation gives parties an opportunity to discuss issues, clear up misunderstandings, be creative, find areas of agreement, and reach a final resolution of the issues.
Additional information concerning the NRC's program can be obtained at http://www.nrc.gov/
about-nrc/regulatory/enforcement/adr.html. The Institute on Conflict Resolution (ICR) at Cornell University has agreed to facilitate the NRC's program as a neutral third party. Please contact ICR at 877-733-9415 within 10 days of the date of this letter if you are interested in pursuing resolution of this issue through ADR.
In addition, please be advised that the number and characterization of apparent violations described in the enclosed inspection report may change as a result of further NRC review. You will be advised by separate correspondence of the results of our deliberations on this matter.
R. In accordance with 10 CFR 2.390 of the NRCs Rules of Practice and Procedure, a copy of this letter, its enclosures, and your response, if you choose to provide one, will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction.
If you have any questions concerning this matter, please contact Binoy Desai at 404-997-4519.
Sincerely, Signed by Pearson, Laura on 03/30/23 Laura M. Pearson, Acting Director Division of Reactor Safety Docket Nos. 05000424 and 05000425 License Nos. NPF-68 and NPF-81
Enclosures:
1. Factual Summary 2. Inspection Report 05000424/2023090 and 05000425/2023090
Inspection Report
Docket Numbers: 05000424 and 05000425 License Numbers: NPF-68 and NPF-81 Report Numbers: 05000424/2023090 and 05000425/2023090 Enterprise Identifier: I-2023-090-0004 Licensee: Southern Nuclear Operating Company, Inc.
Facility: Vogtle Electric Generating Plant, Units 1 and 2 Location: Waynesboro, GA Approved By: Binoy Desai, Chief Engineering Branch 3 Division of Reactor Safety Enclosure 2
SUMMARY The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a NRC inspection at Vogtle Electric Generating Plant, Units 1 and 2, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations Workers Entered Unit 1 Containment on the Wrong Radiation Work Permit Cornerstone Severity Cross-Cutting Report Aspect Section Not Applicable Apparent Violation Not Applicable 71152A AV 05000424,05000425/2023090-01 Open EA-22-108 An apparent violation (AV) of Technical Specification (TS) 5.4.1 was identified when two contract employees, along with and under the direction of a contract supervisor, entered Unit 1 containment on a radiation work permit (RWP) that did not allow containment access.
Enclosure 2
INSPECTION RESULTS Workers Entered Unit 1 Containment on the Wrong Radiation Work Permit Cornerstone Severity Cross-Cutting Report Aspect Section Not Apparent Violation Not 71152A Applicable AV 05000424,05000425/2023090-01 Applicable Open EA-22-108 An AV of Technical Specification (TS) 5.4.1 was identified when two contract employees, along with and under the direction of a contract supervisor, entered Unit 1 containment on a radiation work permit (RWP) that did not allow containment access.
Description: During the night shift of September 20, 2021, a contract supervisor and two contract employees were performing various tasks inside Unit 1 containment and the auxiliary building in support of the 1R23 refueling outage. The supervisor and crew received a briefing from radiation protection (RP) on radiological conditions inside containment and were instructed to use RWP 21-1003, with electronic dosimeter (ED) alarm setpoints appropriate for work in that area. Early in the shift, they had entered containment twice using the correct RWP. Later in the shift, they planned to perform another entry into containment; however, at the direction of the supervisor, they bypassed the radiation protection (RP) trailer where containment briefings were performed and logged onto a different RWP (RWP 21-0010) at a separate auxiliary building login terminal. RWP 21-0010 was a self-brief RWP with ED alarm setpoints appropriate for low-risk auxiliary building areas which did not allow access into Unit 1 containment. The workers also failed to use the correct (transmitting) electronic dosimeters (EDs) for containment entry during login, meaning that their dose and dose rate were not monitored by RP personnel in real-time. At multiple points during the login process the two subordinate workers questioned whether RWP 21-0010 was correct. The supervisor repeatedly told them that it was the correct RWP and instructed them to enter the number as directed and the workers ultimately complied. The group then entered the radiologically controlled area (RCA), dressed out in protective clothing, and entered Unit 1 containment. At some point, the two workers were told to wait just inside the containment entrance while the supervisor proceeded down to the 197 elevation to inspect a work area near a high radiation area. Shortly after emerging from the elevator on the 197 elevation, the supervisor received an ED dose rate alarm of 48 mrem/hr on a set point of 25 mrem/hr. The entire group immediately left containment and reported to RP.
Corrective Actions: The licensee temporarily revoked RCA access for the three involved individuals, performed supplemental surveys of the area where the ED alarm was received, and performed an investigation of the events. The supervisor was subsequently terminated by his employer, Day and Zimmerman.
Corrective Action References: Condition Reports 10828724 and 10828726 Performance Assessment: The inspectors determined this violation was associated with a minor performance deficiency.
Enforcement: The ROPs significance determination process does not specifically consider willfulness in its assessment of licensee performance. Therefore, it is necessary to address this violation, which involves apparent willfulness, using traditional enforcement to adequately deter non-compliance.
Enclosure 2
Violation: Vogtle Units 1 and 2 Technical Specification (TS) 5.4.1 requires that the procedures recommended in Regulatory Guide 1.33, Quality Assurance Program Requirements, Revision 2, Appendix A, be established, implemented, and maintained, for access control to radiation areas, including a Radiation Work Permit (RWP) system.
Southern Nuclear Operating Company (SNC) Procedure NMP-HP-302, Restricted Area Classification, Postings, and Access Control, Version 12.8, Section 4.1 Step 15 states, Entry requirements into any RCA will be defined by a Radiation Work Permit.
SNC RWP 21-0010 allowed radiological work to be performed in certain low-risk areas, including the auxiliary building, fuel handling building, control building, turbine building, and outside areas, but did not allow access into Unit 1 or Unit 2 containment.
Contrary to the above, during the night shift on September 20, 2021, during the 1R23 refueling outage, the licensee failed to follow RWP 21-0010, as required by TS 5.4.1.
Specifically, three contract employees entered Unit 1 containment on RWP 21-0010, which did not allow containment access.
Enforcement Action: This violation is being treated as an apparent violation pending a final significance (enforcement) determination.
Enclosure 2