IR 05000424/2009006

IR 05000424-09-006, 05000425-09-006, on 02/09/2009 - 02/27/2009, Vogtle Electric Generating Plant, Units 1 & 2, Biennial Inspection of the Identification and Resolution of Problems

ML090860653
Person / Time
Site:	Vogtle
Issue date:	03/27/2009
From:	Vias S Reactor Projects Branch 7
To:	Tynan T Southern Nuclear Operating Co
References
IR-09-006
Download: ML090860653 (18)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION rch 27, 2009

SUBJECT:

VOGTLE ELECTRIC GENERATING PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000424/2009006 AND 05000425/2009006

Dear Mr. Tynan:

On February 27, 2009, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Vogtle Electric Generating Plant Units 1 and 2. The enclosed report documents the inspection findings, which were discussed on February 27, 2009, with you and members of your staff.

The inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commissions rules and regulations and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of plant equipment and activities, and interviews with personnel.

On the basis of the samples selected for review, there were no findings of significance identified during this inspection. The team concluded that problems were properly identified, evaluated, and resolved within the problem identification and resolution (PI&R) program. However, the team identified examples of minor problems, including closing of a corrective action prior to completion and closing of a corrective action without clear documentation of what was performed.

SNC, Inc. 2 In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response, if any, will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Steven J. Vias, Chief Reactor Projects Branch 7 Division of Reactor Projects Docket Nos.: 50-424, 50-425 License Nos.: NPF-68, NPF-81

Enclosure:

Inspection Report 05000424/2009006 and 05000425/2009006 w/Attachment: Supplemental Information

REGION II==

Docket Nos.: 50-424, 50-425 License Nos.: NPF-68, NPF-81 Report Nos.: 05000424/2009006 and 05000425/2009006 Licensee: Southern Nuclear Operating Company, Inc.

Facility: Vogtle Electric Generating Plant, Units 1 and 2 Location: Waynesboro, GA 30830 Dates: February 09 - 13, 2009 February 23 - 27, 2009 Inspectors: S. Atwater, Senior Project Inspector, Team Leader R. Taylor, Senior Project Inspector T. Chandler, Resident Inspector, Vogtle T. Lighty, Project Engineer Accompanied By: C. Smith-Standberry, Construction Inspector Trainee Approved by: Steven J. Vias, Chief Reactor Projects Branch 7 Division of Reactor Projects Enclosure

SUMMARY

OF ISSUES

IR 05000424/2009006, 05000425/2009006; 02/09/2009 - 02/27/2009; Vogtle Electric Generating Plant, Units 1 and 2; biennial inspection of the identification and resolution of problems.

The inspection was conducted by two senior project inspectors, a resident inspector, a project engineer, and a construction inspector trainee. No findings of significance were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

Identification and Resolution of Problems The team concluded that, in general, problems were identified, evaluated, prioritized, and corrected. The licensee was effective at identifying problems and entering them into the corrective action program (CAP) for resolution, as evidenced by the relatively few deficiencies identified by external organizations (including the NRC) that had not been previously identified by the licensee, during the review period. Generally, prioritization and evaluation of issues were adequate, formal root cause evaluations for significant problems were adequate, and corrective actions specified for problems were acceptable. Overall, corrective actions developed and implemented for issues were generally effective and implemented in a timely manner. However, the team identified examples of minor problems, including closing of a corrective action prior to completion and closing of a corrective action without clear documentation of what was performed.

The team determined that overall audits and self-assessments were adequate in identifying deficiencies and areas for improvement in the CAP, and appropriate corrective actions were developed to address the issues identified. Operating experience usage was found to be generally acceptable and integrated into the licensees processes for performing and managing work, and plant operations.

Based on discussions and interviews conducted with plant employees from various departments, the inspectors determined that personnel at the site felt free to raise safety concerns to management and use the CAP to resolve those concerns.

NRC Identified and Self-Revealing Findings

None

Licensee Identified Violations

None

REPORT DETAILS

4OA2 Problem Identification and Resolution

a. Assessment of the Corrective Action Program

(1) Inspection Scope The inspectors reviewed the licensees CAP procedures which described the administrative process for initiating and resolving problems primarily through the use of condition reports (CRs). To verify that problems were being properly identified, appropriately characterized, and entered into the CAP, the inspectors reviewed CRs that had been issued between January 2007 and December 2008, including a detailed review of selected CRs associated with the Main Steam System, Standby Power System, Reactor Coolant System, 125 VDC System, and 480 VAC System.

Where possible, the inspectors independently verified that the corrective actions were implemented as intended. The inspectors also reviewed selected common causes and generic concerns associated with root cause evaluations to determine if they had been appropriately addressed. To help ensure that samples were reviewed across all cornerstones of safety identified in the NRCs Reactor Oversight Process (ROP), the team selected a representative number of CRs that were identified and assigned to the major plant departments, including operations, maintenance, engineering, health physics, chemistry, and security. These CRs were reviewed to assess each departments threshold for identifying and documenting plant problems, thoroughness of evaluations, and adequacy of corrective actions. The inspectors reviewed selected CRs, verified corrective actions were implemented, and attended meetings where CRs were screened for significance to determine whether the licensee was identifying, accurately characterizing, and entering problems into the CAP at an appropriate threshold.

The inspectors reviewed CRs, Action Items (AI), work orders, and health reports for the systems selected. These reviews were performed to verify that problems were being properly identified, appropriately characterized, and entered into the CAP.

Items reviewed generally covered a two-year period of time; however, in accordance with the inspection procedure, a five-year review was performed for selected systems for age-dependent issues.

The team conducted a detailed review of selected CRs to assess the adequacy of the root cause and apparent cause evaluations of the problems identified. The inspectors assessed if the licensee had adequately determined the cause(s) of identified problems, and had adequately addressed operability, reportability, common cause, generic concerns, extent-of-condition, and extent-of-cause. The review also assessed if the licensee had appropriately identified and prioritized corrective actions to prevent recurrence.

The team reviewed selected industry operating experience items, including NRC generic communications, to verify that they had been appropriately evaluated for applicability and that issues identified through these reviews had been entered into the CAP.

The team reviewed site trend reports, to determine if the licensee effectively trended identified issues and initiated appropriate corrective actions when adverse trends were identified.

The inspectors attended various plant meetings to observe management oversight functions of the corrective action process. These included the Corrective Action Program Coordinator (CAPCO) meetings, Management Review Meetings (MRM),

Corrective Action Review Board (CARB) meetings and Plant Review Board (PRB)meetings.

The documents reviewed are listed in the Attachment.

(2) Assessment Identification of Issues The team determined that the licensee was generally effective in identifying problems and entering them into the CAP. There was a low threshold for entering issues into the CAP as evidenced by a CR generation rate of approximately 1,000 per month.

The management expectation was for employees to initiate CRs for all deficiencies.

Trending was generally effective in monitoring equipment performance and the team did not identify any deficiencies not previously entered into the CAP. Site management was actively involved in the CAP and focused appropriate attention on significant plant issues.

Prioritization and Evaluation of Issues Based on the review of CRs, work orders, and health reports for the systems selected and audits conducted by the licensee, the team concluded that problems were generally prioritized and evaluated in accordance with the licensees CAP procedures. Each CR was assigned a severity level, the type of cause determination, and a responsible department by the Corrective Action Program Coordinators (CAPCOs). Management reviewed the CAPCO decisions at the Management Review Meeting (MRM). Management reviews were thorough, and adequate consideration was given to system or component operability and associated plant risk.

The team determined that the station had conducted root cause and apparent cause analyses in compliance with the licensees CAP procedures, and the assigned cause determinations were appropriate considering the significance of the issues being evaluated. The following causal-analysis techniques were used depending on the type and complexity of the issue:

• Event and Causal Factors Chart

• Why Staircase Analysis

• Management Oversight and Risk Tree (MORT Analysis)

• Kepner Tregoe The team determined that generally, the licensee had performed evaluations that were technically accurate and of sufficient depth. The licensee has substantially improved the quality of their root cause analyses since the last PI&R inspection.

The team further determined that operability, reportability, and degraded or non-conforming condition determinations had been completed consistent with the CAP program procedures.

Effectiveness of Corrective Actions Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the team determined that overall, corrective actions were timely, commensurate with the safety significance of the issues, and effective, in that conditions adverse to quality were corrected and non-recurring. A review of performance indicators, all CRs, and effectiveness reviews demonstrated that the significant conditions adverse to quality had not recurred.

Effectiveness reviews for corrective actions to prevent recurrence (CAPRs) were sufficient to ensure corrective actions were properly implemented and were effective.

However, the team identified the following two examples in which corrective actions had been closed improperly. The first corrective action had been closed prior to completion and the second corrective action had been closed without proper documentation.

• CR 2008102153, "Clearance & Tagging Errors" The root cause evaluation identified ineffective management oversight and inadequate use of Human Error Tools as root causes for this event. AI 2008205802 was generated to enhance management oversight through bi-monthly observations in the area of clearance development and review.

As of the first week of inspection, the team determined that the management observations had not yet been established and AI 2008205802 had been closed. When notified of this condition, the licensee immediately generated CR 2009101479 to investigate. The licensee revised procedure 10000-C to formally establish a management observation policy and generated an action item to establish a recurring task. At the close of the inspection, management had conducted their first observation.

Previous clearance and tagging CRs along with misposition CRs were reviewed to determine if a common caused existed. The team determined that an adverse trend existed in which similar root causes were identified in previous analysis reports associated with clearance and tagging deficiencies.

The licensee has not yet completed all of the programmatic corrective actions to address the clearance and tagging issues.

• CR 2007101757, "Engineering Qualifications Not Valid" AI 2007201138 was an effectiveness review that found the actions taken to address the root causes to be ineffective. AI 2007201138 had been closed with no follow-up action identified. Investigation under CR 2009101505 found the questionable qualifications were based on an incorrect qualification standard. Once the correct standard was referenced, the qualifications were valid. This was an error in documentation only, in that the original effectiveness review was not corrected prior to closure.

(3) Findings No findings of significance were identified.

b.

Assessment of the Use of Operating Experience (OE)

(1) Inspection Scope The team examined licensee programs for reviewing industry operating experience, reviewed the licensees operating experience database, and interviewed the OE Coordinator, to assess the effectiveness of how external and internal operating experience data was handled at the plant. In addition, the team selected operating experience documents (e.g., INPO OE, NRC Regulatory Information Summaries (RIS), Information Notices (IN), Generic Letters, Part 21 vendor notifications, licensee event reports, and plant internal operating experience items, etc.), which had been issued since January 1, 2007, to verify whether the licensee had appropriately evaluated each notification for applicability to the Vogtle plant, and whether issues identified through these reviews were entered into the CAP. Procedure NMP-GM-008, "Operating Experience Program," was reviewed to verify that the requirements delineated in the program were being implemented at the station.

(2) Assessment Based on interviews with the OE coordinator, a sample of relevant OE, and a review of documentation related to the review of operating experience issues, the team determined that the licensee was generally effective in screening operating experience for applicability to the plant. Industry OE was evaluated at either the corporate or plant level depending on the source and type of document. Relevant information was then forwarded to the applicable department for further action or informational purposes. OE issues requiring action were entered into the CAP for tracking and closure.

The inspectors determined that significant operating experience such as INPO Significant Event Notifications (SEN) and Significant Operating Experience Reports (SOER), NRC Generic letters (GL), Regulatory Information Summaries (RIS), and Information Notices (IN), and Part 21 vendor notifications was regularly used to prevent events from occurring and to address events or near-misses. OE was regularly included in System Health Reports and in CRs associated with station events as part of the causal investigations and corrective action development.

However, the team identified one significant OE that had not been entered into the CAP, as required by procedure. RIS 2008-22 contained safeguards information and was therefore correctly processed through security protocols, rather than through the corrective action process. This was a minor issue in that the OE procedure did not address handling of safeguards information. The licensee generated CR 2009101910 to address the procedure gap.

c. Assessment of Self-Assessments and Audits

(1) Inspection Scope The team reviewed audit reports and self-assessment reports, including those which focused on problem identification and resolution, to assess the thoroughness and self-criticism of the licensee's audits and self assessments, and to verify that problems identified through those activities were appropriately prioritized and entered into the CAP for resolution.

(2) Assessment The team determined that the scope of assessments and audits was adequate. Self-assessments were generally detailed and critical, as evidenced by observations consistent with the teams independent review. CRs were created to document a summary of the results and associated recommendations from the final reports. The team verified that all recommendations from self-assessments reviewed had been entered into the CAP, and verified that actions had been completed consistent with those recommendations. Generally, the licensee performed evaluations that were technically accurate. The team concluded that the self-assessments and audits were an effective tool to identify adverse trends.

(3) Findings No findings of significance were identified.

d. Assessment of Safety-Conscious Work Environment

(1) Inspection Scope The team randomly interviewed 20 on-site workers regarding their knowledge of the corrective action program at Vogtle and their willingness to write CRs or to raise safety concerns. During technical discussions with members of the plant staff, the inspectors conducted interviews to develop a general perspective of the safety-conscious work environment at the site. The interviews were also conducted to determine if any conditions existed that would cause employees to be reluctant to raise safety concerns. The inspectors reviewed the licensees Employee Concerns Program (ECP) and interviewed the Concerns Coordinator. Additionally, the inspectors reviewed a sample of completed ECP reports to verify that concerns were being properly reviewed, and identified deficiencies were being resolved and entered into the CAP when appropriate.

(2) Assessment Based on the interviews conducted and the CRs reviewed, the team determined that licensee management emphasized the need for all employees to identify and report problems using the appropriate methods established within the administrative programs, including the CAP and ECP. These methods were readily accessible to all employees. Based on discussions conducted with a sample of plant employees from various departments, the inspectors determined that employees felt free to raise issues, and that management encouraged employees to place issues into the CAP for resolution. The inspectors did not identify any reluctance on the part of the licensee staff to report safety concerns.

The investigations conducted by the ECP were thorough and complete, and recommended corrective actions were appropriately focused to address actions needed to resolve individual concerns. The team noted one exception in which the licensee failed to formally enter a concern into the concerns resolution process due to lapses in ECP staffing caused by illness and turnover. However, the licensee had taken actions to acknowledge and address the employee concern.

(3) Findings No findings of significance were identified.

4OA6 Meetings, Including Exit

On February 27, 2009, the inspectors presented the inspection results to Mr. Tom Tynan and members of the site staff. The inspectors confirmed that proprietary information was not provided or examined during the inspection.

ATTACHMENT: SUPPPLEMENTAL INFORMATION

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

J. Agcaoilli, Engineering

M. Agcaoilli, 125 VDC System Engineer

R. Brigdon, Nuclear Operation Training Supervisor

C. Buck, Chemistry Manager

W. Copeland, Performance Improvement Supervisor

R. Dedrickson, Plant Manager

K. Dyer, Security Manager

J. Ealick, Fleet Oversight Supervisor

M. Hickox, Principal Licensing Engineer

D. Hill, Root Cause Analyst

D. Holt, Performance Improvement Engineer

P. Hurst, Concerns Program Manager

M. Johnson, Health Physics Support Supervisor

N. Johnson, Standby Power System Engineer

I. Kochney, Health Physics

D. Lambert, Site Design Manager

L. Mansfield, Engineering Support Manager

J. Martin, 480 VAC System Engineer

D. McCary, Maintenance Manager

T. Morgan, Human Resources Business Consultant

T. Parton, Operations Support Superintendent

S. Phillips, Maintenance Superintendent

T. Reeves III, Health Physics Specialist

A. Rivera, Main Steam System Engineer

J. Robinson, Technical Services Manager

M. Sharma, Nuclear Specialist

R. Shepherd, Performance Improvement Nuclear Specialist

E. Sweat, RCS System Engineer

T. Tynan, Site Vice President

R. Vaught, Outage and Scheduling Manager

D. Vineyard, Operations Manager

A. Whaley, Corrective Action Program Supervisor

J. Williams, Site Support Manager

D. Wilson, Human Resource Business Partner

M. Wilson, Fleet Oversight

T. Youngblood, Engineering Director

NRC

S. Vias, Branch Chief, Reactor Projects Branch 7

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

None

Closed

None

Discussed

None.