IR 05000424/2023001
| ML23114A048 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 04/26/2023 |
| From: | Alan Blamey Division Reactor Projects II |
| To: | Brown R Southern Nuclear Operating Co |
| References | |
| IR 2023001 | |
| Download: ML23114A048 (15) | |
Text
SUBJECT:
VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 - INTEGRATED INSPECTION REPORT 05000424/2023001 AND 05000425/2023001
Dear R. Keith Brown:
On March 31, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Vogtle Electric Generating Plant, Units 1 and 2. On April 13, 2023, the NRC inspectors discussed the results of this inspection with Mr. Robert Norris, Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at Vogtle Electric Generating Plant, Units 1 and 2.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
April 26, 2023
Sincerely, Alan J. Blamey, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket Nos. 05000424 and 05000425 License Nos. NPF-68 and NPF-81
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000424 and 05000425
License Numbers:
Report Numbers:
05000424/2023001 and 05000425/2023001
Enterprise Identifier:
I-2023-001-0034
Licensee:
Southern Nuclear Operating Company, Inc.
Facility:
Vogtle Electric Generating Plant, Units 1 and 2
Location:
Waynesboro, GA
Inspection Dates:
January 01, 2023 to March 31, 2023
Inspectors:
S. Downey, Senior Reactor Inspector
T. Morrissey, Senior Resident Inspector
E. Robinson, Resident Inspector
M. Schwieg, Senior Reactor Inspector
W. Truss, Resident Inspector
Approved By:
Alan J. Blamey, Chief
Reactor Projects Branch 2
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated 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
Nuclear Service Cooling Water Pipe Spring Support Found Pinned Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000425/2023001-01 Open/Closed None (NPP)71111.15 The NRC identified a Green finding and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50 Appendix B, Criterion III, Design Control, for the licensees failure to maintain safety-related equipment in a seismically analyzed condition. Specifically, the unit 2 A train of the nuclear service cooling water variable spring support 2-1202-007-H009 was placed in an unanalyzed condition that did not meet the established piping systems seismic dynamic analysis.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000424,05000425/
2023-001-00 LER 2023-001-00 for Vogtle Electric Generating Plant Units 1 and 2, Partial Loss of Offsite Power Results in Emergency Diesel Generator and Auxiliary Feedwater Actuation 71153 Closed
PLANT STATUS
Unit 1 began the inspection period at rated thermal power (RTP). On March 5, 2022, the unit was shut down for planned cycle 24 refueling outage (1R24). The unit was restarted on March 30, 2023, and was at approximately 68 percent RTP power at the end of the inspection period.
Unit 2 began the inspection period at RTP. On March 1, 2023, the unit was down powered to 92 percent RTP for a quarterly main turbine valve stroke test and returned to RTP later the same day. The unit remained at or near RTP for the remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 1 train "A" centrifugal charging pump (CCP) with train "B" CCP out of service for maintenance, on January 5, 2023
- (2) Unit 1 train A safety injection pump (SIP) with train B SIP out of service for maintenance, on January 30, 2023
- (3) Unit 1 train "A" containment spray (CS) pump with train "B" CS pump out of service for maintenance, on February 22, 2023
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Zones 144/162/164, unit 1 train "B" emergency diesel generator (EDG) room and electrical tunnel on January 12, 2023
- (2) Zones 143/161/163, unit 2 train "A" EDG room and electrical tunnel on January 19, 2023
- (3) Zones 87/88/89/90/93/102/158/159, unit 1 level "A" control building east and west penetration areas on February 23, 2023
- (4) Zones 4/5/9/10, unit 1 level "D" auxiliary building CS and residual heat removal (RHR)pump rooms on March 21, 2023
- (5) Zones 140A/B/C/E, Unit 1 containment building on March 21, 2023
Fire Brigade Drill Performance Sample (IP Section 03.02) (2 Samples)
- (1) The inspectors evaluated the onsite fire brigade training and performance during an unannounced fire drill in the following area:
Unit 2 A train CCP room, on January 17, 2023
- (2) The inspectors evaluated the onsite fire brigade training and performance during an unannounced fire drill in the following area:
Unit 1 normal charging pump room, on January 29, 2023
71111.06 - Flood Protection Measures
Flooding Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated internal flooding mitigation protections in the unit 1 train "A" and "B" component cooling water (CCW) areas on February 22, 2023
71111.07A - Heat Exchanger/Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
- (1) Unit 1, train "B" CCW heat exchanger (83306-C, "CCW and Auxiliary CCW Heat Exchanger Testing"), on March 15, 2023
71111.08P - Inservice Inspection Activities (PWR) PWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding Activities (IP Section 03.01)
The inspectors verified that the following nondestructive examination and welding activities were performed appropriately:
- (1) Ultrasonic Examination Auxiliary feedwater 1 piping welds 13-16 Visual Examination Vessel closure head exterior PWR Inservice Inspection Activities Sample - Vessel Upper Head Penetration Inspection
Activities (IP Section 03.02) (1 Sample)
The inspectors verified that the license conducted the following vessel upper head penetration inspections and addressed any identified defects appropriately:
- (1) Control rod drive mechanism penetrations PWR Inservice Inspection Activities Sample - Boric Acid Corrosion Control Inspection Activities (IP Section 03.03) (1 Sample)
The inspectors verified the licensee is managing the boric acid corrosion control program through a review of the following evaluations:
- (1) Reactor coolant systems pressurizer spray bypass valve PV-0455B, condition report (CR) 10832618
Auxiliary building walkdown PWR Inservice Inspection Activities Sample - Steam Generator Tube Inspection Activities (Section 03.04) (1 Sample)
The inspectors verified that the licensee is monitoring the steam generator tube integrity appropriately through a review of the following examinations:
- (1) Steam generator 1 - Eddy current testing (ECT) for tubes R1C87, R41C100
Steam generator 2 - ECT for tubes R42C97
Steam generator 3 - ECT for tubes R30C111, R47C38
Steam generator 4 - ECT for tubes R25C74, R44C21
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (2 Samples)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during a planned power reduction, shutdown, and cooldown of unit 1 to support refueling outage 1R24 on March 4-5.
- (2) The inspectors observed and evaluated licensed operator performance in the control room during a planned unit 1 startup and power ascension, following refueling outage
==1R24, on March 30-31, 2023.
==
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated a simulator scenario consisting of a rapid down power, a manual reactor trip to address increasing vibrations for a main feedwater pump, and a steam generator tube rupture, on January 25, 2023.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) Units 1 and 2 125-volts direct current (Vdc) system, on January 12, 2023
- (2) Unit 1 "B" reserve auxiliary transformer fault following lightning arrestor failure, on January 3, 2023
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Units 1 and 2, restoration from partial loss of offsite power concurrent with a tornado watch, on January 4, 2023
- (2) Unit 1, elevated risk due to main steam atmospheric relief valve (1PV3020), train "B" nuclear service cooling water (NSCW) cooling tower fan 3, and train "B" engineering safety features (ESF) chiller out of service, on January 24, 2023
- (3) Unit 1, elevated risk due to planned maintenance on train B SIP, train B NSCW pump 4, and train B RHR for the period of January 30, 2023, through February 1, 2023
- (4) Unit 1, elevated risk due to train A RHR out of service for planned maintenance, and train A EDG for emergent maintenance, on February 8-10, 2023
- (5) Unit 1, elevated shutdown risk (Yellow) due to lowered reactor coolant system inventory on March 6-7, 2023
- (6) Unit 1 elevated shutdown risk (Yellow) due to RCS mid-loop operation on March 19, 2023
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) CR 10942093, unit 1 125Vdc battery 1BD1B cracks and corrosion on lids, on February 1, 2023
- (2) CR 10939135, unit 1 train A NSCW fan 4 motor megger test results under acceptance criteria, on February 7, 2023
- (3) CR10944804, unit 1 train A ESF chiller bearing high temperature alarm following troubleshooting and repair, on February 7, 2023
- (4) CR10949591, unit 2 solid state protection system train "A" operability following test lamp staying lit during performance of procedure 14420-2, on February 20, 2023
- (5) CR 10919978, unit 2 NSCW piping spring support downstream of valve 2HV-11604 found pinned, on March 29, 2023
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Unit 1 train "B" EDG governor permanent modification, design change package (DCP) SNC953976, during 1R24 refueling outage, on March 8th, 2023
- (2) Unit 1, train "B" main steam isolation valve (MSIV) actuator eliminations, DCP SNC965546, during 1R24 refueling outage, on March 29, 2023
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated unit 1 cycle 24 refueling outage (1R24) from March 5, 2023 to March 31, 2023
71111.24 - Testing and Maintenance of Equipment Important to Risk
The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (4 Samples)
- (1) Procedure 14805A-1, Train A Residual Heat Removal Pump and Check Valve Inservice and Response Time Test, (IST portion) and 14825-1, "Quarterly Inservice Valve Test, (1HV-8812A and 1HV8811A only) after train A RHR system outage; work orders (WOs) SNC 999133, SNC1337741 and SNC1186915 (2)
===28816-C, "Class 1E Battery Modified Performance Test," after replacing 1DD1B battery, WO SNC1188836
- (3) WO SNC953976, functional test #2 after permanent modification to the EDG train "B" governor (4)14850-1, "Cold Shutdown Valve Inservice Test," (MSIVs HV-3006A, HV-3016A, HV-3026A, and HV-3036A), after valve replacements under WOs SNC1128968, SNC1128971, SNC1128975 and SNC1128977 Surveillance Testing (IP Section 03.01)===
(1)
87006-1, Movable Incore Detector System Operating Inspections, (unit 1 flux map),on January 19, 2023 (2)24758-1, "Steam Generator Level (Narrow Range) Protection Channel IV 1L-517 Channel Operational Test and Channel Calibration", on January 27, 2023 (3)28210-C, Main Steam Line Code Safety Valve setpoint Verification, (unit 1 loop 3),on March 1, 2023 Inservice Testing (IST) (IP Section 03.01)
(1)
14807B-1 "Train B Motor Driven Auxiliary Feedwater Pump/Check Valve Inservice and Response Time Test" (inservice test only) on January 4, 2023 Containment Isolation Valve (CIV) Testing (IP Section 03.01)
(1)
14342-1, "Containment Penetration No. 42 Accumulator N2 Supply Local Leak Rate Test," on March 14, 2023 Diverse and Flexible Coping Strategies (FLEX) Testing (IP Section 03.02)
71114.06 - Drill Evaluation
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
The inspectors evaluated:
- (1) On January 25, 2023, the inspectors evaluated a licensed operator continuing training dynamic simulator scenario that included a manual reactor trip and steam generator tube rupture resulting in an Alert emergency declaration and notification to the State of Georgia and the surrounding counties.
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01)===
- (1) Unit 1, (January 1, 2022 through December 31, 2022)
- (2) Unit 2, (January 1, 2022 through December 31, 2022)
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (2 Samples)
- (1) Unit 1, (January 1, 2022 through December 31, 2022)
- (2) Unit 2, (January 1, 2022 through December 31, 2022)
IE04: Unplanned Scrams with Complications Sample (IP Section 02.03) (2 Samples)
- (1) Unit 1, (January 1, 2022 through December 31, 2022)
- (2) Unit 2, (January 1, 2022 through December 31, 2022)
71153 - Follow Up of Events and Notices of Enforcement Discretion Event Follow-up (IP section 03.01)
- (1) The inspectors evaluated a partial loss of offsite power and licensees response on January 4, 2023.
Event Report (IP section 03.02) (1 Sample)
The inspectors evaluated the following licensee event reports (LERs):
- (1) LER 2023-001-00, Partial Loss of Offsite Power results in Emergency Diesel Generator and Auxiliary Feedwater Actuation (ADAMS Accession No.
ML23058A432). The inspectors determined that it was not reasonable to foresee or correct the cause discussed in the LER; therefore, no performance deficiency or violation of NRC requirements was identified. This LER is Closed.
INSPECTION RESULTS
Nuclear Service Cooling Water Pipe Spring Support Found Pinned Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000425/2023001-01 Open/Closed None (NPP)71111.15 The NRC identified a Green finding and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50 Appendix B, Criterion III, Design Control, for the licensees failure to maintain safety-related equipment in a seismically analyzed condition. Specifically, the unit 2 A (2A) train of the nuclear service cooling water (NSCW)variable spring support 2-1202-007-H009 was placed in an unanalyzed condition that did not meet the established piping systems seismic dynamic analysis.
Description:
The updated final safety analysis report (USFAR) section 3.9 Mechanical Systems and Components, states, in part, that the codes applicable to the NSCW system and its variable spring supports and settings are the 1974 addition and 1975 addenda of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (BPVC), Section III-Division 1, Subsections ND Class 3 Components and NF Component Supports, respectively. The UFSAR, Section 3.9.B.2.1, Piping Vibration, Thermal Expansion, and Dynamic Effects, specified, in part, that pipe and equipment supports are checked for correct assembly and setting. In addition, licensee procedure, 25024-C, Pipe/Component Support Installation, version 13.0, Section 4.6.1, states, in part, restraint, variable, and constant supports should be installed in accordance with the design drawing (pipe support drawing number 2-1202-007-H009). On November 1, 2022, the inspectors found the 2A NSCW spray header pipe variable spring support, 2-1202-007-H009, was pinned preventing the required freedom of movement under seismic dynamic loading, which was an unanalyzed configuration. The licensee removed the pin and documented this issue in the corrective action program as condition report (CR) 10919978. On November 3, 2022, during the past operability evaluation of the pinned support, the licensee determined that nine out of eleven supports for the 2A NSCW spray header were not set in accordance with the load balance calculations, including variable spring support 2-1202-007-H009. This was documented in CR 10920743 and was previously evaluated by the inspectors in Section 71111.15 of NRC Integrated Inspection Report 05000424/2022004 AND 05000425/2022004 (ADAMS Accession No. ML23018A287). The licensee was unable to determine how long the unanalyzed configuration existed.
Corrective Action References: CR 10919978
Performance Assessment:
Performance Deficiency: The failure to maintain safety-related equipment in a seismically analyzed configuration was a performance deficiency. Specifically, the unit 2 A train NSCW variable spring support 2-1202-007-H009 was placed in an unanalyzed configuration that did not meet the established piping systems seismic dynamic analysis.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the inspectors determined that the as-found unanalyzed configuration resulted in reasonable doubt about the unit 2A NSCW equipments seismic qualifications, which reduced assurance in the equipments availability and reliability and required the licensee to revise the calculation.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined the finding was of very low safety significance (Green) because the finding was a design or qualification deficiency of a mitigating structure, system, and component (SSC) and the SSC maintained its functionality. Specifically, following re-evaluation of the system with pinned support the licensee determined that the 2A NSCW remained operable.
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
Enforcement:
Violation: 10 CFR 50, Appendix B, Criterion III, Design Control, requires in part, that design changes, including field changes, shall be subject to design control measures commensurate with the original design and approved by the responsible organization.
To meet 10 CFR 50, Appendix B, Criterion III, the licensee commits to implement Basic Requirement 3, Design Control described in their Quality Assurance Topical Report (SNC-1, Version 25.0. Section 3.2, Design Records, of Basic Requirement 3 states, in part, that (1)the licensee maintains records sufficient to provide evidence that the design was properly accomplished. Records include the final design output (i.e., drawings) and any revisions thereto, as well as record of the important design steps (e.g., calculations, analyses, and computer programs) that support the final output; and
- (2) plant design drawings reflect the properly reviewed and approved configuration of the plant.
Contrary to the above, prior to November 1, 2022, the licensee did not maintain records to provide evidence that a field change to the 2A NSCW variable spring support, 2-1202-007-H009, was properly accomplished. Specifically, the support was in a pinned configuration that prevented the required freedom of pipe movement under seismic dynamic loading. That configuration was not reflected in the design drawing and was not supported by important design steps such as calculations and/or analyses.
Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On April 13, 2023, the inspectors presented the integrated inspection results to Mr. Robert Norris, Plant Manager, and other members of the licensee staff.
On March 22, 2023, the inspectors presented the unit 1 inservice inspection (IP71111.08P) results to Kevin Lowe, Operations Director, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Calculations
X6CXC28
Flooding Analysis - Auxiliary Building, Level A
Version 13
Corrective
Action
Documents
Resulting from
Inspection
CR10956195
Gouge in piping on line 11302-107 weld 15
3/16/2023
Miscellaneous
SG-CDMP-23-1
Vogtle 1R24 Steam Generator Degradation Assessment
Revision 0
NMP-AP-002
SNC Fleet Procedures Writers' Guide
Procedures
NMP-ES-024-208
Visual Examination of Reactor Vessel Head Penetrations and
Base Material (Remote and Direct)
10936652
1B RAT faulted, resulted in offsite power loss to ES buses
1BA03 and 2AA02
10941396
Significant Corrosion Unit 2 B Train Battery
Corrective
Action
Documents
10942093
1BD1B Battery Heavy Corrosion Causing Lid Cracking
Drawings
2-1202-007-H009
Pipe Support Drawing for 2-1202-007-H009
Rev. 2