ML23116A248
| ML23116A248 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 04/26/2023 |
| From: | Coleman J Southern Nuclear Operating Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| ND-23-026=52, EA-22-081, IR 2022011 | |
| Download: ML23116A248 (1) | |
Text
~ Southern Nuclear Jamie M. Coleman 7825 River Road Regulatory Affairs Director Waynesboro, Georgia 30830 Vogtle 3 & 4 706 848 6926 tel April 26, 2023 ND-23-0252 Docket No.: 52-025 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Southern Nuclear Operating Company Vogtle Electric Generating Plant (VEGP) - Unit 3 Response to Apparent Violation in NRC Inspection Report 05200025/2022011: EA-22-081 Ladies and Gentlemen:
By letter dated March 28, 2023, the Nuclear Regulatory Commission (NRC) provided to Southern Nuclear Operating Company (SNC) the results of the recently completed inspection. The NRC letter, dated March 28, 2023, is titled, "NRC Office of Investigations Report 2-2021-020 and Vogtle Electric Generating Plant, Unit 3 - NRC Inspection Report 05200025/2022011 and Apparent Violations." That letter states, "Before the NRC makes its enforcement decision for the two AVs, we are providing you an opportunity to (1) respond in writing to the AVs addressed in this inspection report within 30 days of the date of this letter, or (2) request a Pre-decisional Enforcement Conference (PEC), or (3) request Alternative Dispute Resolution (ADR)." On April 4, 2023, the NRC staff was informed that SNC intended to pursue the first option of providing a written position on these apparent violations. The enclosure to this letter provides the requested information.
The information included in the enclosure is intended to assist the NRC in the determination of final significance for the apparent violations identified in the NRC letter dated March 28, 2023.
This letter contains no regulatory commitments.
Should you have questions regarding the enclosed information , please contact Will Garrett at (706) 848-7154.
Respectfully submitted, Jamie M. Coleman Regulatory Affairs Director Vogtle 3 & 4 Southern Nuclear Operating Company
U.S. Nuclear Regulatory Commission NL-23-0252 Page 2 of 2 JMC/CAC/sfr
Enclosure:
Response to Apparent Violation in NRC Inspection Report 05200025/2022011; EA-22-081 cc: Regional Administrator, Region II Senior Resident Inspector - Vogtle 3 & 4 Director, Environmental Protection Division - State of Georgia
Southern Nuclear Operating Company ND-23-0252 Enclosure Vogtle Electric Generating Plant (VEGP) - Unit 3 Response to Apparent Violation in NRC Inspection Report 05200025/2022011; EA-22-081 (This Enclosure consists of 5 pages, not including this cover page)
U.S. Nuclear Regulatory Commission ND-23-0252 Enclosure Page 1 of 5 SNC has reviewed the information provided in NRC letter dated March 28, 2023. The two apparent violations (A Vs) are summarized below:
AV 05200025/2022011-01 Failure to Follow Procedure for Unit 3 Hot Functional Testing An apparent violation of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," was identified for the failure to follow procedures during hot functional testing (HFT). Specifically, the licensee failed to obtain initial (i.e., ambient temperature) Unit 3 pressurizer upper lateral support shim gap measurements and record the measurements on Attachment 59 of 3-GEN-ITPP-507, "Thermal Expansion, Dynamic Effects, and Vibration (TEDEV) Program," prior to plant heat up during HFT.
AV 05200025/2022011-02 Failure to Maintain Complete and Accurate Test Records for Unit 3 Hot Functional Testing An apparent violation of 10 CFR 52.6(a), "Completeness and Accuracy of Information,"
was identified for the licensee's failure to maintain complete and accurate information in quality assurance records. Specifically, Step 4.1.13 of SNC procedure 3-GEN-ITPP-517 was initialed and dated, confirming that procedure 3-GEN-ITPP-507, Section 4.1, had been performed , when, in fact, required shim gap measurements on the Unit 3 pressurizer upper lateral support were not obtained and recorded as required by Step 4.1.2 and Attachment 59 of procedure 3-GEN-ITPP-507.
The following provides SNC's response to the AVs, as requested in the NRC letter dated March 28, 2023.
(1) The reason for the A Vs or, if contested, the basis for disputing the A Vs:
Both AVs involved the action of an individual, a former test engineer, who failed to follow procedures and provided inaccurate information in the test records.
It is important to note that the non-compliance with the preoperational test requirements and the conditions associated with the incorrect shim gaps were identified by SNC personnel. The identification of these issues by SNC led to timely inspections and corrections, described in (2) below.
Additionally, SNC did recognize and identify the performance issues of the Test Engineer. Based on the observed inconsistencies in the records, SNC investigated the actions of the persons involved, using an independent investigator. This resulted in the conclusion that the Test Engineer had documented inaccurate information in the procedural steps that the shim gaps had been verified, while knowing that this had not been performed in accordance with the procedural requirements. This led to corrective actions, as described in (2) below.
(2) The corrective steps that have been taken and the results achieved:
First, the technical shim gap discrepancy was identified and corrected, as documented in Condition Report (CR) 50093275. The initial HFT was halted when SNC discovered that two pressurizer support shims were out of the expected tolerance range. SNC decided to return the plant to ambient conditions to conduct the shim corrections and re-verify the measurements of the other supports. In the process of re-verifying all ambient measurements for the HFT, SNC discovered that no measurements had been taken for the pressurizer upper lateral support shim
U.S. Nuclear Regulatory Commission ND-23-0252 Enclosure Page 2 of 5 gaps despite documentation that indicated such measurements had been taken. At that time, SNC took immediate corrective action to investigate both the shim gap measurements and the inaccurate documentation.
As noted in the NRC inspection report, SNC completed corrective actions to ensure the installation of the Unit 3 pressurizer upper lateral support shims were within design tolerances, and as a result, this issue does not represent an operability concern for VEGP Unit 3. Upon identification of the issues, corrective actions were necessary to rework some of the support shims to be within the design tolerances. Due to the issues surrounding the initial measurements, the test procedures were reperformed. The completed test procedures, after correction of the shim discrepancies, are the quality records documenting successful completion of the preoperational testing and supersede the previous, partially completed procedures that contained the invalid information documented by the Test Engineer.
Second, based on the results of the SNC investigation of the inaccurate test records, the Test Engineer, a supplemental worker, was terminated by SNC. The Test Engineer had been responsible for other measurements during hot functional testing; to address the potential extent-of-condition, those measurements were re-performed prior to recommencing the hot functional testing. No other measurements were found to be incorrect.
Finally, additional actions were taken to reinforce standards to prevent reoccurrence. The primary methods of reinforcing behaviors for accuracy of records, safety culture, and safety conscious work environment (SCWE), include communications and leadership actions. Around the time of and after discovery of the pressurizer shim gap tolerance nonconformance, there were numerous communications and leadership actions that reinforced appropriate personnel behaviors. Several examples of these activities are provided below. This is not intended to be a complete list of all such actions. This is a representative sample intended to show that the Vogtle 3 & 4 project provides frequent reinforcement of expected personnel behaviors.
On May 20, 2021 , the Initial Test Program (ITP) Director released a video communication pertaining to the status of HFT. In this video communication, the ITP Director discussed the pressurizer shim gap tolerance issue and the importance of correcting the identified issue. The importance of completing the testing, while maintaining high standards in safety and quality, was also conveyed.
The following list provides examples of reinforcement communications for accuracy of records, safety culture, and SCWE that occurred after the hot functional testing issues were identified.
This information is typically provided and reinforced by site supervisors:
May 17, 2021 Supervisor Weekly Communication Package (called "Toolbox Talks")
covers, "My signature is my word." Reinforces that the worker signing that the work document is technically complete and accurate in all material respects. The worker's signature is the documented evidence that validates the proper execution and quality of work and will serve as the final acceptance of activities that will safeguard nuclear safety.
May 31, 2021 Toolbox Talks covers, "Follow the rules." Reinforces that everyone understands the scope and responsibilities for executing the work.
U.S. Nuclear Regulatory Commission ND-23-0252 Enclosure Page 3 of 5 June 7, 2021 Toolbox Talks covers, "Stop when unsure." Reinforces that Nuclear safety is the highest priority in completing the new plants and stopping when unsure is a critical part of achieving this goal.
June 21, 2021 Toolbox Talks again covers, "My signature is my word ." Reinforces that hold points are to compare work performed to design and quality requirements.
Hold points are mandatory inspection steps in a work document where the applicable activity must stop to verify quality completion of our work. The signature/initials we provide for the completion of activities is "Our Word" to the regulator and general public that our work in constructing the new plants is valid in all material respect and meets high standards of quality for nuclear safety.
The following items are examples of site leadership communications that promote adherence to processes and reinforcement of individual behaviors:
August 5, 2021 The Executive Vice President for Vogtle 3 & 4 issued a communication to all site personnel discussing the project schedule. This communication also reinforced that nuclear professionals adhere to nuclear quality standards, regardless of the amount of time it takes and that the project personnel must move forward with the understanding that work is to be performed right, the first time.
October 28, 2021 The Executive Vice President for Vogtle 3 & 4 issues a communication to all site personnel reinforcing expectations regarding the fundamental and non-negotiable behaviors. These include the following topics:
Quality of Construction - Reinforces first time quality, following processes, stopping when unsure, identifying issues, and training.
Corrective Action Program (CAP) - Reinforces timely documentation of known issues, meeting CAP actions and due dates, and ensuring quality of documentation in CAP.
Teamwork - Reinforces construction, testing, and operation of Vogtle 3 & 4 with quality, ensuring that personnel communicate openly, and hold each other accountable.
The preceding information demonstrates some of the project communications around the time and following the events described in the AVs. These types of communications are typical for the reinforcement of safety culture and SCWE at the Vogtle 3 & 4 project and demonstrate that the Vogtle 3 & 4 project provides frequent reinforcement of appropriate personnel behaviors.
The primary results achieved based on the actions summarized above, was the restoration of compliance for the performance of the TEDEV portions of HFT. Additionally, reinforcement of personnel behaviors has provided increased awareness of the responsibilities of each worker and the overall nuclear safety culture of the organization.
U.S. Nuclear Regulatory Commission ND-23-0252 Enclosure Page 4 of 5 (3) the corrective steps that will be taken:
Based on the actions that resolved the inaccurate test data, addressed the Test Engineer's unacceptable actions, and reinforced expectations regarding the importance of signature and quality, there are no additional actions needed. Site Leadership at the Vogtle 3 & 4 project continues to reinforce positive attributes of a nuclear safety culture and SCWE through site communications.
(4) the date when full compliance will be achieved.
Full compliance was achieved when the shim gaps were verified and corrected, as needed.
Additionally, the completion of the Unit 3 HFT test records required for TEDEV, including 3-GEN-ITPP-507 and 3-GEN-ITPP-517, achieved full compliance that the HFT records are complete and accurate.
Additional Information:
As previously stated, the AVs were caused by an individual 's failure to adhere to procedure during the performance of preoperational testing for Unit 3. The conditions associated with the shim gaps and the resulting inaccurate information in the procedure record were identified and corrected. Further, actions were taken that addressed the individual's conduct. The communications provided by site leadership have reinforced nuclear safety culture principles and SCWE. After the discovery of these ITP implementation issues during HFT, the SCWE of the ITP group was independently assessed. The SCWE of the ITP group was found to be acceptable, with willingness to bring forth safety concerns.
The issues identified in the AVs resulted in no, or relatively inappreciable, potential safety or security consequences.
Based on review of the NRC Enforcement Manual and NRC Enforcement Policy documents, the identified AVs are most similar to Severity Level (SL) IV violations.
The NRC Enforcement Policy, Section 6.5, provides guidance for the severity levels associated with facility construction. Item 2, under SL Ill violations, states, "A failure to confirm the design safety requirements of a structure, system, or component as the result of inadequate preoperational test program implementation." This does not appear to be applicable because the preoperational test program was adequately implemented based on SNC's self-identification and correction of the conditions that could have led to the failure to confirm that the design safety requirements for the shim gaps had been met.
In Section 6.9, the Enforcement Policy provides guidance for the severity levels associated with inaccurate/incomplete information. Item 1, under SL Ill violations provides an example pertaining to incomplete/inaccurate information that would likely cause the NRC to reject the closure of Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC). The ITAAC closure associated with this portion of the preoperational testing had not been submitted and as stated, the information was corrected through SNC's discovery and corrective actions.
U.S. Nuclear Regulatory Commission ND-23-0252 Enclosure Page 5 of 5 The severity levels are defined in the Enforcement Policy, Section 2.2.2. Specifically, SL Ill and SL IV are defined as follows:
SL Ill violations are those that resulted in or could have resulted in moderate safety or security consequences (e.g., violations that created a potential for moderate safety or security consequences or violations that involved systems not being capable, for a relatively short period, of preventing or mitigating a serious safety or security event).
SL IV violations are those that are less serious, but are of more than minor concern, that resulted in no or relatively inappreciable potential safety or security consequences (e.g.,
violations that created the potential of more than minor safety or security consequences).
As noted in AV 2022011-01, the inspectors determined the finding for the technical aspects of the identified conditions was of very low safety significance (Green) because there was reasonable assurance the design function of the RCS was not impaired by the performance deficiency. It is noted that both AVs are associated with the same conditions. This would indicate that both AVs are more closely aligned with the SL IV description than the SL Ill description .
SNC recommends consideration that the two proposed apparent violations be combined into a single finding. Inspection Manual Chapter (IMC) 0613, Section 17.07 states, "Multiple examples of the same performance deficiency that share the same cause and require the same corrective actions shall be documented as a single finding." As stated previously, the conditions described in these AVs were caused by a singular action of the Test Engineer. The failure to follow the procedure as identified in AV 2022011-01 directly led to the failure to have a complete and accurate procedural record as described in AV 2022011-02. Therefore, the single cause was the action of the Test Engineer, and the corrective actions for both AVs are the same.