IR 05000424/2021004: Difference between revisions
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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: | 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&2. | 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&2. | ||
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC Resident Inspector at Vogtle Electric Generating Plant, Units 1&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. | If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555 -0001; with copies to the Regional Administrator, Region II; and the NRC Resident Inspector at Vogtle Electric Generating Plant, Units 1&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. | ||
Sincerely, | Sincerely, Alan J. Blamey, Chief Reactor Projects Branch 2 Division of Reactor Projects | ||
Alan J. Blamey, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket Nos. 05000424 and 05000425 License Nos. NPF-68 and NPF-81 | |||
Docket Nos. 05000424 and 05000425 License Nos. NPF -68 and NPF-81 | |||
===Enclosure:=== | ===Enclosure:=== | ||
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==Inspection Report== | ==Inspection Report== | ||
Docket Numbers: 05000424 and 05000425 License Numbers: NPF-68 and NPF-81 Report Numbers: 05000424/2021004 and 05000425/2021004 Enterprise Identifier: I-2021-004-0016 | Docket Numbers: 05000424 and 05000425 | ||
License Numbers: NPF-68 and NPF-81 | |||
Report Numbers: 05000424/2021004 and 05000425/2021004 | |||
Enterprise Identifier: I-2021-004- 0016 | |||
Facility: Vogtle Electric Generating Plant, Units 1&2 Location: Waynesboro, GA Inspection Dates: October 01, 2021 to December 31, 2021 Inspectors: B. Caballero, Senior Operations Engineer D. Mas-Penaranda, Project Engineer T. Morrissey, Senior Construction Inspector C. Safouri, Senior Resident Inspector R. Smith, Senior Resident Inspector M. Toth, Senior Project Engineer Approved By: Alan J. Blamey, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure | Licensee: Southern Nuclear Company, Inc. | ||
Facility: Vogtle Electric Generating Plant, Units 1&2 | |||
Location: Waynesboro, GA | |||
Inspection Dates: October 01, 2021 to December 31, 2021 | |||
Inspectors: B. Caballero, Senior Operations Engineer D. Mas-Penaranda, Project Engineer T. Morrissey, Senior Construction Inspector C. Safouri, Senior Resident Inspector R. Smith, Senior Resident Inspector M. Toth, Senior Project Engineer | |||
Approved By: Alan J. Blamey, Chief Reactor Projects Branch 2 Division of Reactor Projects | |||
Enclosure | |||
=SUMMARY= | =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&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. | The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Vogtle Electric Generating Plant, Units 1&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.htm l for more information. | ||
===List of Findings and Violations=== | ===List of Findings and Violations=== | ||
Failure to Follow Procedures Results in Unit 1 Train A Safety Injection Pump Inoperability Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.3] - Change 71111.12 Systems NCV 05000424,05000425/2021004- 02 Management Open/Closed A self-revealed Green finding and associated Non-cited Violation (NCV) of 10 Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, and Technical Specification (TS) 3.5.2, Condition A, when the licensee failed to perform activities affecting quality in accordance with an approved procedure appropriate for the circumstance and operated in a condition prohibited by TS. Specifically, the licensee performed lubrication sampling of the Unit 1 train A safety injection (1A SI) pump while the pump was running, which did not follow NMP-ES- 074- 006, section 2.1, which states, DO NOT use drop tube method to collect oil sample from a GEARBOX that is in operation/running, and ultimately resulted in the inoperability of the system from September 6, 2021, to September 29, 2021. | |||
Failure to Follow Procedures Results in Unit 1 Train A Safety Injection Pump Inoperability Cornerstone | |||
===Additional Tracking Items=== | ===Additional Tracking Items=== | ||
Type | Type Issue Number Title Report Section Status URI 05000424,05000425/20 SI Pump Room Unsealed 71111.06 Open 21004- 01 Penetrations During Internal Flooding. | ||
LER | LER 05000424/2021001-00 LER 2021-001-00 for Vogtle 71111.12 Closed Electric Generating Plant, | ||
Unit 1, Train A Safety Injection Pump inoperability causes the unit to operate in a Condition Prohibited by Technical Specifications LER | Unit 1, Train A Safety Injection Pump inoperability causes the unit to operate in a Condition Prohibited by Technical Specifications LER 05000425/2020-001-00 LER 2020-001-00 for Vogtle 71153 Closed Electric Generating Plant Unit 2, Transformer failure leads to main generator trip and subsequent reactor trip | ||
=PLANT STATUS= | =PLANT STATUS= | ||
Unit 1 began the inspection period in Mode 5 as part of the refueling outage (1R23) and returned to rated thermal power on October 10, 2021. On December 15, 2021, the unit down powered to 85 percent due to a condenser sodium excursion. The unit was | Unit 1 began the inspection period in Mode 5 as part of the refueling outage (1R23) and returned to rated thermal power on October 10, 2021. On December 15, 2021, the unit down powered to 85 percent due to a condenser sodium excursion. The unit was retur ned to rated thermal power on December 20, 2021, and remained at or near rated thermal power for the remainder of the inspection period. | ||
Unit 2 began the inspection period at rated thermal power. On November 18, 2021, the unit was down powered to 92 percent to perform main turbine valves stroke test. The unit was returned to rated thermal power on November 19, 2021, and remained at or near rated thermal power for the remainder of the inspection period. | Unit 2 began the inspection period at rated thermal power. On November 18, 2021, the unit was down powered to 92 percent to perform main turbine valves stroke test. The unit was returned to rated thermal power on November 19, 2021, and remained at or near rated thermal power for the remainder of the inspection period. | ||
==INSPECTION SCOPES== | ==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, conducted routine | 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, conducted routine review s using IP 71152, Problem Identification and Resolution, 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== | ==REACTOR SAFETY== | ||
==71111.01 - Adverse Weather Protection== | ==71111.01 - Adverse Weather Protection== | ||
===Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)=== | ===Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)=== | ||
: (1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures for the following systems: | : (1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures for the following systems: | ||
auxiliary feedwater system (AFW)nuclear service cooling water (NSCW) system | auxiliary feedwater system (AFW)nuclear service cooling water (NSCW) system | ||
==71111.04 - Equipment Alignment== | ==71111.04 - Equipment Alignment== | ||
===Partial Walkdown Sample (IP Section 03.01) (1 Sample)=== | ===Partial Walkdown Sample (IP Section 03.01) (1 Sample)=== | ||
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains: | The inspectors evaluated system configurations during partial walkdowns of the following systems/trains: | ||
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==71111.05 - Fire Protection== | ==71111.05 - Fire Protection== | ||
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (2 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: | 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) Fire Zones 140A/B/C/E, Unit 1 containment building, on October 4, 2021 | : (1) Fire Zones 140A/B/C/E, Unit 1 containment building, on October 4, 2021 | ||
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==71111.06 - Flood Protection Measures== | ==71111.06 - Flood Protection Measures== | ||
===Inspection Activities - Internal Flooding (IP Section 03.01) (2 Samples)=== | ===Inspection Activities - Internal Flooding (IP Section 03.01) (2 Samples)=== | ||
The inspectors evaluated internal flooding mitigation protections in the: | The inspectors evaluated internal flooding mitigation protections in the: | ||
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==71111.07A - Heat Sink Performance== | ==71111.07A - Heat Sink Performance== | ||
===Annual Review (IP Section 03.01) (1 Sample)=== | ===Annual Review (IP Section 03.01) (1 Sample)=== | ||
The inspectors evaluated readiness and performance of: | The inspectors evaluated readiness and performance of: | ||
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==71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance== | ==71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance== | ||
===Requalification Examination Results (IP Section 03.03) (1 Sample)=== | ===Requalification Examination Results (IP Section 03.03) (1 Sample)=== | ||
: (1) On October 22, 2021, the licensee completed the annual requalification operating tests required to be administered to all licensed operators in accordance with Title 10 of the Code of Federal Regulations 55.59(a)(2), "Requalification Requirements," of the NRC's "Operator's Licenses." During the week of November 29, 2021, the inspector performed an in-office review of the overall pass/fail results of the individual and crew operating tests in accordance with Inspection Procedure (IP) 71111.11, "Licensed Operator Requalification Program." These results were compared to the thresholds established in Section 3.02, "Requalification Examination Results of IP | : (1) On October 22, 2021, the licensee completed the annual requalification operating tests required to be administered to all licensed operators in accordance with Title 10 of the Code of Federal Regulations 55.59(a)(2), "Requalification Requirements," of the NRC's "Operator's Licenses." During the week of November 29, 2021, the inspector performed an in-office review of the overall pass/fail results of the individual and crew operating tests in accordance with Inspection Procedure (IP) 71111.11, "Licensed Operator Requalification Program." These results were compared to the thresholds established in Section 3.02, "Requalification Examination Results of IP | ||
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==71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance== | ==71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance== | ||
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample) | |||
: (1) The inspectors observed and evaluated licensed operator performance in the control room during Mode 3 heatup and subsequent mode transitions following the refueling outage (1R23), on October 5, 2021 | |||
Licensed Operator Requalification Training/Examinations (IP Section 03.02)=== | |||
{{IP sample|IP=IP 71111.11|count=1}} | {{IP sample|IP=IP 71111.11|count=1}} | ||
: (1) The inspectors observed and evaluated simulator training on the execution of prompt operator actions, loss of instrument air event, and security event, on November 2, 2021 | : (1) The inspectors observed and evaluated simulator training on the execution of prompt operator actions, loss of instrument air event, and security event, on November 2, 2021 | ||
==71111.12 - Maintenance Effectiveness== | ==71111.12 - Maintenance Effectiveness== | ||
===Maintenance Effectiveness (IP Section 03.01) (3 Samples)=== | ===Maintenance Effectiveness (IP Section 03.01) (3 Samples)=== | ||
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function: | The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function: | ||
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==71111.15 - Operability Determinations and Functionality Assessments== | ==71111.15 - Operability Determinations and Functionality Assessments== | ||
===Operability Determination or Functionality Assessment (IP Section 03.01) (1 Sample)=== | ===Operability Determination or Functionality Assessment (IP Section 03.01) (1 Sample)=== | ||
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments: | The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments: | ||
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==71111.19 - Post-Maintenance Testing== | ==71111.19 - Post-Maintenance Testing== | ||
===Post-Maintenance Test Sample (IP Section 03.01) (2 Samples)=== | ===Post-Maintenance Test Sample (IP Section 03.01) (2 Samples)=== | ||
The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality: | The inspectors evaluated the following post -maintenance test activities to verify system operability and functionality: | ||
: (1) Unit 1 train A SI pump repair following lube oil starvation failure, on September 16, 2021 | : (1) Unit 1 train A SI pump repair following lube oil starvation failure, on September 16, 2021 | ||
: (2) Unit 1 train B SI motor cooler NSCW strainer modification, on November 30, 2021 | : (2) Unit 1 train B SI motor cooler NSCW strainer modification, on November 30, 2021 | ||
==71111.20 - Refueling and Other Outage Activities== | ==71111.20 - Refueling and Other Outage Activities== | ||
===Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)=== | ===Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)=== | ||
: (1) The inspectors evaluated refueling outage 1R23 from October 1, 2021, to October 7, 2021. The inspectors completed inspection procedure Sections 03.01.d through 03.01.e. | : (1) The inspectors evaluated refueling outage 1R23 from October 1, 2021, to October 7, 2021. The inspectors completed inspection procedure Sections 03.01.d through 03.01.e. | ||
==71111.22 - Surveillance Testing== | ==71111.22 - Surveillance Testing== | ||
The inspectors evaluated the following surveillance tests: | The inspectors evaluated the following surveillance tests: | ||
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==OTHER ACTIVITIES - BASELINE== | ==OTHER ACTIVITIES - BASELINE== | ||
===71151 - Performance Indicator Verification | |||
The inspectors verified licensee performance indicators submittals listed below: | |||
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) === | |||
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)=== | |||
{{IP sample|IP=IP 71151|count=2}} | {{IP sample|IP=IP 71151|count=2}} | ||
: (1) Unit 1 (October 1, 2020 through September 30, 2021) | : (1) Unit 1 (October 1, 2020 through September 30, 2021) | ||
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==71152 - Problem Identification and Resolution (PI&R)== | ==71152 - Problem Identification and Resolution (PI&R)== | ||
===Semiannual Trend Review (IP Section 02.02) (1 Sample)=== | ===Semiannual Trend Review (IP Section 02.02) (1 Sample)=== | ||
: (1) The inspectors reviewed the licensees corrective action program for potential adverse trends in Unit 1 train B CCW pump #2 oil level that might be indicative of a more significant safety issue. | : (1) The inspectors reviewed the licensees corrective action program for potential adverse trends in Unit 1 train B CCW pump #2 oil level that might be indicative of a more significant safety issue. | ||
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: (2) Unit 1 loop 1 accumulator tank leakage, CR 10801613. | : (2) Unit 1 loop 1 accumulator tank leakage, CR 10801613. | ||
===71153 - Follow Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02) === | ===71153 - Follow Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)=== | ||
{{IP sample|IP=IP 71153|count=2}} | {{IP sample|IP=IP 71153|count=2}} | ||
The inspectors evaluated the following licensee event reports (LERs): | The inspectors evaluated the following licensee event reports (LERs): | ||
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==INSPECTION RESULTS== | ==INSPECTION RESULTS== | ||
Unresolved Item | Unresolved Item SI Pump Room Unsealed Penetrations During Internal 71111.06 (Open) Flooding URI 05000424,05000425/2021004-01 | ||
=====Description:===== | =====Description:===== | ||
NRC inspectors are reviewing flood information related to an issue of concern associated with internal flood analyses for the safety injection (SI) pump rooms. During on-site walkdowns of the Unit 1 train B SI pump room on December 14, 2021, NRC inspectors identified an open wall penetration approximately 3-4" in diameter near the top of the room's watertight door, which was also below the maximum calculated flood height of 135 inches (11.25') per Calculation X6CXC-30. By means of an extent of condition comparison, NRC inspectors and licensee staff identified additional open penetrations in the 1A, 2A, and 2B SI pump room walls. These additional open penetrations varied in both location and number for each pump room and can be summarized by the following: | NRC inspectors are reviewing flood information related to an issue of concern associated with internal flood analyses for the safety injection (SI) pump rooms. During on-site walkdowns of the Unit 1 train B SI pump room on December 14, 2021, NRC inspectors identified an open wall penetration approximately 3-4" in diameter near the top of the room's watertight door, which was also below the maximum calculated flood height of 135 inches (11.25') per Calculation X6CXC-30. By means of an extent of condition comparison, NRC inspectors and licensee staff identified additional open penetrations in the 1A, 2A, and 2B SI pump room walls. These additional open penetrations varied in both location and number for each pump room and can be summarized by the following: | ||
* 1A SI pump room: 2 unsealed or inadequately rated for flood protection o 1-2108-Z1-1392-B and 1-2108-Z1-1572-B | * 1A SI pump room: 2 unsealed or inadequately rated for flood protection o 1-2108-Z1-1392-B and 1-2108-Z1-1572-B | ||
* | * I pumpm:ealed ornadequatyator flotti o 2-2108-Z1-1488-B and 2-2108-Z1-1490-B | ||
* 2B SI pump room: 5 unsealed or inadequately rated for flood protection o 2-2108-Z1-1080-B, 2-2108-Z1-1081-B, 2-2108-Z1-1082-B, 2-2108-Z1-0480-B, and 2-2108-Z1-0481-B 10 CFR Part 50, Appendix B, Criterion III, Design Controls, requires in part, that design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program." Additionally, the Vogtle Electric Design Manual (VEGP) Design Control Number DC-1003, "Flooding-Interdiscipline," | * 2B SI pump room: 5 unsealed or inadequately rated for flood protection o 2-2108-Z1-1080- B, 2-2108-Z1-1081-B, 2-2108-Z1-1082-B, 2-2108-Z1- 0480- B, and 2-2108-Z1- 0481-B | ||
10 CFR Part 50, Appendix B, Criterion III, Design Controls, requires in part, that design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program." Additionally, the Vogtle Electric Design Manual (VEGP) Design Control Number DC-1003, "Flooding-Interdiscipline," | |||
outlines internal flooding requirements including, in part, the following information: | outlines internal flooding requirements including, in part, the following information: | ||
* Watertight doors shall be used to prevent flooding of safety-related equipment if other simpler means are not feasible; e.g., curbed doorways. The flooding hazard shall be assessed by analysis per section 4.0 of this document. (Section 3.1.12) | * Watertight doors shall be used to prevent flooding of safety-related equipment if other simpler means are not feasible; e.g., curbed doorways. The flooding hazard shall be assessed by analysis per section 4.0 of this document. (Section 3.1.12) | ||
* Penetrations through walls of safety-related rooms or areas should be designed to withstand the design flood levels on either side of the walls to prevent leakage through the penetration. Penetrations which do not increase flood levels on either side of walls, by means of communication, need not be sealed against water. (Section 3.1.16) | * Penetrations through walls of safety-related rooms or areas should be designed to withstand the design flood levels on either side of the walls to prevent leakage through the penetration. Penetrations which do not increase flood levels on either side of walls, by means of communication, need not be sealed against water. (Section 3.1.16) | ||
NRC inspectors identified that the original room drawings and approved internal flood calculations for the SI pump rooms did not include the unsealed penetrations or account for their impact during internal flooding scenarios. This unresolved item (URI) is being opened to determine whether the unsealed flood penetrations were the result of a more-than-minor licensee performance deficiency, and whether or not a regulatory requirement was violated. | NRC inspectors identified that the original room drawings and approved internal flood calculations for the SI pump rooms did not include the unsealed penetrations or account for their impact during internal flooding scenarios. This unresolved item (URI) is being opened to determine whether the unsealed flood penetrations were the result of a more-than-minor licensee performance deficiency, and whether or not a regulatory requirement was violated. | ||
Planned Closure Actions: NRC inspectors will review all applicable information related to the flood analyses associated with the on-site SI pump rooms to determine whether a performance deficiency exists. Additionally, NRC inspectors will coordinate these results with a Region II Senior Reactor Analyst to determine overall significance of the issue through the NRC's ROP. | Planned Closure Actions: NRC inspectors will review all applicable information related to the flood analyses associated with the on-site SI pump rooms to determine whether a performance deficiency exists. Additionally, NRC inspectors will coordinate these results with a Region II Senior Reactor Analyst to determine overall significance of the issue through the NRC's ROP. | ||
Licensee Actions: Licensee staff have completed an initial assessment of the internal flood analyses for the SI pump rooms and determined the SI pumps remained operable with the identified open penetrations | Licensee Actions: Licensee staff have completed an initial assessment of the internal flood analyses for the SI pump rooms and determined the SI pumps remained operable with the identified open penetrations. | ||
Corrective Action References: Condition Report (CR) 10847097 Failure to Follow Procedures Results in Unit 1 Train A Safety Injection Pump Inoperability Cornerstone | Additionally, a work authorization was created and implemented to formally seal the penetration at the 17" level for the 2B SI pump room. The licensee is still evaluating the impact of the penetrations in the additional rooms. | ||
Corrective Action References: Condition Report (CR) 10847097 | |||
Failure to Follow Procedures Results in Unit 1 Train A Safety Injection Pump Inoperability Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.3] - Change 71111.12 Systems NCV 05000424,05000425/2021004- 02 Management Open/Closed A self-revealed Green finding and associated Non-cited Violation (NCV) of 10 Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, and Technical Specification (TS) 3.5.2, Condition A, when the licensee failed to perform activities affecting quality in accordance with an approved procedure appropriate for the circumstance and operated in a condition prohibited by TS. Specifically, the licensee performed lubrication sampling of the Unit 1 train A safety injection (1A SI) pump while the pump was running, which did not follow NMP-ES- 074- 006, section 2.1, which states, DO NOT use drop tube method to collect oil sample from a GEARBOX that is in operation/running, and ultimately resulted in the inoperability of the system from September 6, 2021, to September 29, 2021. | |||
=====Description:===== | =====Description:===== | ||
On September 16, 2021, while Unit 1 was in Mode 6, the 1A SI pump was started while performing a surveillance 14721D-1, ECCS Subsystem Flow Balance and Checkvalve Refueling Inservice Test. Shortly after the 1A SI pump start, the system operator saw smoke emit from the pump outboard bearing and local temperature indicator for the bearing rise, and promptly secured the pump and the licensee subsequently declared it inoperable. Upon investigation and disassembly, the licensee discovered the worm gear, which drives the gear-driven lube oil pump, catastrophically damaged. The preliminary cause was attributed to a piece of foreign material (FM), a small piece of plastic, lodged between two gears which was assumed to have prevented or inhibited gear rotation, and subsequent failure of the worm gear which resulted in lube oil starvation (Condition Report (CR)10828893). The licensee replaced several damaged parts (i.e., the wiped bearings) and performed a flush of the lube oil system. | On September 16, 2021, while Unit 1 was in Mode 6, the 1A SI pump was started while performing a surveillance 14721D-1, ECCS Subsystem Flow Balance and Checkvalve Refueling Inservice Test. Shortly after the 1A SI pump start, the system operator saw smoke emit from the pump outboard bearing and local temperature indicator for the bearing rise, and promptly secured the pump and the licensee subsequently declared it inoperable. Upon investigation and disassembly, the licensee discovered the worm gear, which drives the gear -driven lube oil pump, catastrophically damaged. The preliminary cause was attributed to a piece of foreign material (FM), a small piece of plastic, lodged between two gears which was assumed to have prevented or inhibited gear rotation, and subsequent failure of the worm gear which resulted in lube oil starvation (Condition Report (CR)10828893). The licensee replaced several damaged parts (i.e., the wiped bearings) and performed a flush of the lube oil system. | ||
On September 25, 2021, during post maintenance testing following repairs, a similar event occurred with bearing temperatures quickly increasing upon pump start followed by prompt securing of the pump. The worm gear was discovered to be catastrophically failed and the bearings were wiped. The licensee began troubleshooting a second time and discovered a small check valve within the lube oil system that the licensee was unaware of and was not on the piping and instrumentation diagrams (P&IDs), however was contained in the vendor manual. Upon disassembly of the check valve, which is located within a union in the lube oil piping, small pieces of FM (plastic), were discovered within the check valve (CR 10830377). This was believed to have resulted in lube oil starvation for the second 1A SI pump failure. Following repairs, the 1A SI pump was successfully restored back to operable on September 29, 2021. | On September 25, 2021, during post maintenance testing following repairs, a similar event occurred with bearing temperatures quickly increasing upon pump start followed by prompt securing of the pump. The worm gear was discovered to be catastrophically failed and the bearings were wiped. | ||
The licensee began troubleshooting a second time and discovered a small check valve within the lube oil system that the licensee was unaware of and was not on the piping and instrumentation diagrams (P&IDs), however was contained in the vendor manual. | |||
Upon disassembly of the check valve, which is located within a union in the lube oil piping, small pieces of FM (plastic), were discovered within the check valve (CR 10830377). This was believed to have resulted in lube oil starvation for the second 1A SI pump failure. Following repairs, the 1A SI pump was successfully restored back to operable on September 29, 2021. | |||
The licensee performed an extent of condition investigation of the SI pumps for both units. On October 3, 2021, the 1B SI pump was tagged out and a few pieces of FM were found within the check valve (CR 10831851). On October 5, 2021, the 2B SI pump was tagged out and contained several pieces of small plastic FM, most of which were found in the oil recirculation piping leg just upstream of the lube oil pressure relief valve, with the remainder found upstream of the oil filter (CR 10733667). On October 7, 2021, the 2A SI pump was tagged out which contained a few pieces of plastic FM, all of which were found in the oil recirculation piping leg just upstream of the lube oil pressure relief valve (CR 10833295). The extent of condition investigation of all SI pumps was completed on October 8, 2021. Overall, the amount of FM found in 1B, 2A, and 2B SI lube oil system was less compared to 1A SI lube oil system. | The licensee performed an extent of condition investigation of the SI pumps for both units. On October 3, 2021, the 1B SI pump was tagged out and a few pieces of FM were found within the check valve (CR 10831851). On October 5, 2021, the 2B SI pump was tagged out and contained several pieces of small plastic FM, most of which were found in the oil recirculation piping leg just upstream of the lube oil pressure relief valve, with the remainder found upstream of the oil filter (CR 10733667). On October 7, 2021, the 2A SI pump was tagged out which contained a few pieces of plastic FM, all of which were found in the oil recirculation piping leg just upstream of the lube oil pressure relief valve (CR 10833295). The extent of condition investigation of all SI pumps was completed on October 8, 2021. Overall, the amount of FM found in 1B, 2A, and 2B SI lube oil system was less compared to 1A SI lube oil system. | ||
Line 221: | Line 247: | ||
The 1A SI pump was last run during an inservice test (IST) on September 6, 2021, for approximately 1 hour. An oil sample was taken during this run and analyzed to be acceptable. The 1B SI pump was last run during an IST on August 30, 2021, for approximately 50 minutes. An oil sample was taken during this run and analyzed to be acceptable. Additionally, due to an unrelated issue surrounding accumulator leakage, the 1A and 1B SI pumps were run frequently (in an alternating manner) for a total of 7 hours during the months of June through July for periods of approximately 5-10 minutes. Moreover, during the Unit 1 refueling outage, the 1B SI pump was ran 6 times for a total of 2.65 hours. Lastly, the licensee entered a refueling outage and exited the mode of applicability for SI pump operability on September 12, 2021. | The 1A SI pump was last run during an inservice test (IST) on September 6, 2021, for approximately 1 hour. An oil sample was taken during this run and analyzed to be acceptable. The 1B SI pump was last run during an IST on August 30, 2021, for approximately 50 minutes. An oil sample was taken during this run and analyzed to be acceptable. Additionally, due to an unrelated issue surrounding accumulator leakage, the 1A and 1B SI pumps were run frequently (in an alternating manner) for a total of 7 hours during the months of June through July for periods of approximately 5-10 minutes. Moreover, during the Unit 1 refueling outage, the 1B SI pump was ran 6 times for a total of 2.65 hours. Lastly, the licensee entered a refueling outage and exited the mode of applicability for SI pump operability on September 12, 2021. | ||
The 2A SI pump was last run during an IST on August 12, 2021, for approximately 20 minutes. An oil sample was taken during this run and analyzed to be acceptable. The 2B SI pump was last run during an IST on August 25, 2021, for approximately 15 minutes. An oil sample was taken during this run and analyzed to be acceptable. | The 2A SI pump was last run during an IST on August 12, 2021, for approximately 20 minutes. An oil sample was taken during this run and analyzed to be acceptable. | ||
The 2B SI pump was last run during an IST on August 25, 2021, for approximately 15 minutes. An oil sample was taken during this run and analyzed to be acceptable. | |||
Corrective Actions: The 1A SI pump was repaired, lube oil system was flushed, and returned to service; an extent of condition investigation was performed on all SI pumps on both units; and an interim standing order was put in place to not sample pumps while running until industry benchmarking and subsequent specific guidance has been provided. | Corrective Actions: The 1A SI pump was repaired, lube oil system was flushed, and returned to service; an extent of condition investigation was performed on all SI pumps on both units; and an interim standing order was put in place to not sample pumps while running until industry benchmarking and subsequent specific guidance has been provided. | ||
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=====Performance Assessment:===== | =====Performance Assessment:===== | ||
Performance Deficiency: Fleet Procedure NMP-ES-074-006, Fleet Lubrication Instruction, Version 4.0, states under Section 2.1, Precautions, the following: DO NOT use drop tube method to collect oil sample from a GEARBOX that is in operation/running. Doing so could cause drop tube to be pulled into the GEARBOX from the vampire pump. During oil sampling, the licensee inserted a sampling tube into the lube oil gearbox associated with the SI pumps while the pumps were running, which resulted in FM being introduced to the lube oil system and ultimately, the lube oil starvation of the pump outboard bearing resulted in pump failure. | Performance Deficiency: Fleet Procedure NMP-ES- 074- 006, Fleet Lubrication Instruction, Version 4.0, states under Section 2.1, Precautions, the following: DO NOT use drop tube method to collect oil sample from a GEARBOX that is in operation/running. Doing so could cause drop tube to be pulled into the GEARBOX from the vampire pump. During oil sampling, the licensee inserted a sampling tube into the lube oil gearbox associated with the SI pumps while the pumps were running, which resulted in FM being introduced to the lube oil system and ultimately, the lube oil starvation of the pump outboard bearing resulted in pump failure. | ||
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance 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. | Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance 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. | ||
Line 234: | Line 262: | ||
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The performance deficiency did require a detailed risk evaluation because the degraded condition represented a loss of the probabilistic risk assessment function of one train of a multi-train TS system for greater than its TS allowed outage time. The total time the 1A SI pump was determined to be inoperable under applicable modes was 137 hours, which is beyond the TS 3.5.2, Condition A, completion time of 72 hours; TS 3.5.2, Condition B, states if the required action and associated completion time was not met, the unit is required to be in Mode 3 within 6 hours and Mode 4 within 12 hours. | Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The performance deficiency did require a detailed risk evaluation because the degraded condition represented a loss of the probabilistic risk assessment function of one train of a multi-train TS system for greater than its TS allowed outage time. The total time the 1A SI pump was determined to be inoperable under applicable modes was 137 hours, which is beyond the TS 3.5.2, Condition A, completion time of 72 hours; TS 3.5.2, Condition B, states if the required action and associated completion time was not met, the unit is required to be in Mode 3 within 6 hours and Mode 4 within 12 hours. | ||
A detailed risk evaluation was performed by a regional senior reactor analyst using SAPHIRE Version 8.2.5 and NRC Vogtle SPAR model Version 8.60. The conditional analysis included a Bayesian update to the failure likelihood of the SI pumps for both Units 1 and 2 with a one-year exposure time. In addition, the conditional risk associated with the failure of the 1A SI pump was also included. No credit was provided in the analysis for recovery of a failed SI pump. The dominant sequence was a Medium Loss of Coolant Accident initiating event accompanied by a failure of the high-pressure injection and cooldown mitigating functions accompanied by the maintenance unavailability of the B-train of safety-related cooling water. The analysis determined that the estimated increase in Core Damage Frequency (CDF) and Large Early Release Frequency (LERF) was less than 1E-06/year for delta-CDF and less than 1E-07/year for delta-LERF, representing a finding of very low safety significance (Green) for both Units 1 and 2. | A detailed risk evaluation was performed by a regional senior reactor analyst using SAPHIRE Version 8.2.5 and NRC Vogtle SPAR model Version 8.60. | ||
The conditional analysis included a Bayesian update to the failure likelihood of the SI pumps for both Units 1 and 2 with a one-year exposure time. In addition, the conditional risk associated with the failure of the 1A SI pump was also included. No credit was provided in the analysis for recovery of a failed SI pump. The dominant sequence was a Medium Loss of Coolant Accident initiating event accompanied by a failure of the high-pressure injection and cooldown mitigating functions accompanied by the maintenance unavailability of the B -train of safety-related cooling water. The analysis determined that the estimated increase in Core Damage Frequency (CDF) and Large Early Release Frequency (LERF) was less than 1E-06/year for delta-CDF and less than 1E-07/year for delta-LERF, representing a finding of very low safety significance (Green) for both Units 1 and 2. | |||
Cross-Cutting Aspect: H.3 - Change Management: Leaders use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority. | Cross-Cutting Aspect: H.3 - Change Management: Leaders use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority. | ||
Line 249: | Line 279: | ||
==EXIT MEETINGS AND DEBRIEFS== | ==EXIT MEETINGS AND DEBRIEFS== | ||
The inspectors verified no proprietary information was retained or documented in this report. | The inspectors verified no proprietary information was retained or documented in this report. | ||
* On January 19, 2022, the | * On January 19, 2022, the inspector s presented the integrated inspection results to Mr. | ||
Drayton Pitts and other members of the licensee staff. | Drayton Pitts and other members of the licensee staff. | ||
Line 255: | Line 285: | ||
=DOCUMENTS REVIEWED= | =DOCUMENTS REVIEWED= | ||
Inspection Type | Inspection Type Designation Description or Title Revision or | ||
Procedure | Procedure Date | ||
71111.01 | 71111.01 Corrective Action Condition Reports 10836230, 10837239 | ||
Documents | Documents | ||
Corrective Action Condition Reports 10848171 | Corrective Action Condition Reports 10848171 | ||
Line 263: | Line 293: | ||
Resulting from | Resulting from | ||
Inspection | Inspection | ||
Miscellaneous | Miscellaneous NMP-GM-025 Site Certification for Winter Readiness 11/15/2021 | ||
Procedures | Procedures 11901-1 Heat Tracing System Alignment 10/18/2021 | ||
11901-2 | 11901-2 Heat Tracing System Alignment 10/17/2021 | ||
17104-1 | 17104-1 ARP for Heat Tracing Panel 1NCQARHT 18.1 | ||
17104-2 | 17104-2 ARP for Heat Tracing Panel 2NCQARHT 18.0 | ||
NMP-GM-025 | NMP-GM-025 Seasonal Readiness Process 8.0 | ||
71111.04 | 71111.04 Corrective Action Condition Reports 10839617, 10839691, 10839744, 10839750, 10839751, | ||
Documents | Documents 10839785 | ||
Resulting from | Resulting from | ||
Inspection | Inspection | ||
Drawings | Drawings 2X4DB135-2 P & I Diagram Nuclear Service Water System, System 29.0 | ||
Number 1202 | Number 1202 | ||
2X4DB136 | 2X4DB136 P&I Diagram - Component Cooling Water System - System 24.0 | ||
No. 1203 | No. 1203 | ||
2X4DB137 | 2X4DB137 P&I Diagram - Component Cooling Water System - System 21.0 | ||
No. 1203 | No. 1203 | ||
2X4DB149-1 | 2X4DB149-1 Flow Diagram - Cooling Water System - Systems 1202, 5.0 | ||
203, 1217 | 203, 1217 | ||
2X4DB149-2 | 2X4DB149-2 Flow Diagram - Cooling Water System - Systems 1202, 4.0 | ||
203, and 1217 | 203, and 1217 | ||
Miscellaneous | Miscellaneous 1X4AF01-00136 Instruction Manual Component Cooling Water and Auxiliary 35.0 | ||
Component Cooling Water | Component Cooling Water | ||
Procedures | Procedures 11715-2 Component Cooling Water System Alignment 12.1 | ||
13150B-2 | 13150B-2 Train B Nuclear Service Cooling Water System 16 | ||
71111.05 | 71111.05 Corrective Action Condition Reports 10842398 | ||
Documents | Documents | ||
Inspection Type | Inspection Type Designation Description or Title Revision or | ||
Procedure | Procedure Date | ||
Resulting from | Resulting from | ||
Inspection | Inspection | ||
Procedures | Procedures 92704-2 Zone 4 - Auxiliary Building - Level D, Containment Spray 2.0 | ||
Pump "A" Fire Fighting Preplan | Pump "A" Fire Fighting Preplan | ||
2705-2 | 2705-2 Zone 5 - Auxiliary Building - Level D, Containment Spray 3.0 | ||
Pump "B" Fire Fighting Preplan | Pump "B" Fire Fighting Preplan | ||
2709-2 | 2709-2 Zone 9 - Auxiliary Building - Level D Fire Fighting Preplan 2.2 | ||
2710-2 | 2710-2 Zone 10 - Auxiliary Building Level D Fire Fighting Preplan 2.2 | ||
2840A-1 | 2840A-1 Zone 140A - Containment Building - Levels A, B, 1, and 3 4.1 | ||
East Fire Fighting Preplan | East Fire Fighting Preplan | ||
2840B-1 | 2840B-1 Zone 140B - Containment Building - Levels A, B, 1, 2, and 3 5.1 | ||
Fire Fighting Preplan | Fire Fighting Preplan | ||
2840C-1 | 2840C-1 Zone 140C - Containment Building - Levels A, B, 1 and 3 4.1 | ||
Steam Generator Compartment Fire Fighting Preplan | Steam Generator Compartment Fire Fighting Preplan | ||
2840E-1 | 2840E-1 Zone 140E - Containment Building - Levels A, 1 and 2 Fire 1.1 | ||
Fighting Preplan | Fighting Preplan | ||
71111.06 | 71111.06 Calculations X6CXC-30 Flooding Analysis Auxiliary Building 07/19/1993 | ||
Corrective Action Condition Reports 10846893, 10849573, 10852053 | Corrective Action Condition Reports 10846893, 10849573, 10852053 | ||
Documents | Documents | ||
Resulting from | Resulting from | ||
Inspection | Inspection | ||
Miscellaneous | Miscellaneous REA 97-VAA632 Door Database 06/30/1998 | ||
REA 99-VAA650 | REA 99-VAA650 Door Database Update 09/03/1999 | ||
VEGP Design | VEGP Design Flooding - Interdiscipline 11.0 | ||
Manual, Design | Manual, Design | ||
Control Number | Control Number | ||
DC-1003 | DC-1003 | ||
X6CXC-26 | X6CXC-26 Flooding Analysis Auxiliary Building Level C 9 | ||
71111.07A | 71111.07A Corrective Action Condition Reports 10423905, 10836215, 10837460 | ||
Documents | Documents | ||
Corrective Action Condition Reports 10845900 | Corrective Action Condition Reports 10845900 | ||
Line 325: | Line 355: | ||
Resulting from | Resulting from | ||
Inspection | Inspection | ||
Inspection Type | |||
Procedure | Inspection Type Designation Description or Title Revision or | ||
Miscellaneous | Procedure Date | ||
AX4AE01-00109 | Miscellaneous 2A CCW HX Fluid Temperatures, 11/7-11/12/2021 | ||
ELV-1212 | AX4AE01-00109 Instruction Manual for CCW and ACCW Heat Exchangers 7.0 | ||
ELV-1212 VEGP Response to Generic Letter 89-13 Service Water 01/25/1990 | |||
System Problems Affecting Safety-Related Equipment | System Problems Affecting Safety-Related Equipment | ||
EPRI 1022980 | EPRI 1022980 Guidance for an Effective Heat Exchanger Program 09/2011 | ||
NDE Reports | NDE Reports 2A CCW HX Post-Plugging Map 11-2021 from ECT Report | ||
2A CCW Heat Exchanger ECT Report | 2A CCW Heat Exchanger ECT Report 10/19/2021 | ||
2X4DR024-019 | 2X4DR024-019 2A CCW HX Pre-Plugging Map 2021 1 | ||
Procedures | Procedures 30025-C Periodic Analysis Scheduling Program 100 | ||
35363-C | 35363-C Chemistry Control of the NSCW System 9.3 | ||
38363-2 | 38363-2 Chemical Addition to the Unit Two NSCW 12.0 | ||
83305-C | 83305-C Heat Exchanger Testing/Maintenance Program 7.11 | ||
83306-C | 83306-C CCW and ACCW Heat Exchanger Testing 8 | ||
83306-C | 83306-C CCW and ACCW Heat Exchanger Testing 11.1 | ||
NMP-ES-012- | NMP-ES-012-Heat Exchanger Program Eddy Current Testing (ECT) 1.0 | ||
GL05 | GL05 Strategic Plan for Plant Vogtle | ||
NMP-ES-024-701 | NMP-ES-024-701 Eddy Current Testing of Heat Exchanger Tubing 5.0 | ||
Work Orders | Work Orders SNC814889, SNC336301, SNC910488 | ||
71111.11Q Miscellaneous | 71111.11Q Miscellaneous V-RQ-SG-21602 Lesson Plan Form 10/14/2021 | ||
18028 18037 | 18028 18037 | ||
Procedures | Procedures 12003-1 Reactor Startup (Mode 3 to Mode 2) 5 | ||
2004-1 | 2004-1 Power Operation (Mode 1) 8.0 | ||
71111.12 | 71111.12 Corrective Action Condition Reports 10828893, 10829924, 10829977, 10829979, 10830062, | ||
Documents | Documents 10830377, 10830403, 10830550, 10831851, 10832538, | ||
10832610, 10833213, 10833295, 10833439, 10798047, | 10832610, 10833213, 10833295, 10833439, 10798047, | ||
10819690, 10827428, 10832569 | 10819690, 10827428, 10832569 | ||
Corrective Action 282464 | Corrective Action 282464 | ||
Reports | Reports | ||
Technical | Technical 1088188 | ||
Evaluations | Evaluations | ||
Corrective Action Condition Reports 10834273 | Corrective Action Condition Reports 10834273 | ||
Line 361: | Line 392: | ||
Resulting from | Resulting from | ||
Inspection | Inspection | ||
Inspection Type | |||
Procedure | Inspection Type Designation Description or Title Revision or | ||
Miscellaneous | Procedure Date | ||
Temperature Trace for 2A CCW Pumps 1 and 3, Inboard | Miscellaneous Oil Analysis - Unit 2 CCW #1 08/11/2021 | ||
Temperature Trace for 2A CCW Pumps 1 and 3, Inboard 09/15/2021 | |||
and Outboard Bearings | and Outboard Bearings | ||
1X6AG02-00016 | 1X6AG02-00016 Instruction Manual for Pacific Pumps Safety Injection Pumps 13.0 | ||
2- LCO-21-00050 | 2-LCO-21-00050 2A CCW Pump 1 INOP Due to Damaged Outboard Bearing | ||
2-LCO-21-00056 | 2-LCO-21-00056 2A CCW Pump 1 INOP Due to Damaged Outboard Bearing | ||
MREP20210713 | MREP20210713 Maintenance Rule Expert Panel Meeting #2021-0713 | ||
PO# | PO# Warehouse Receipt / Stock Process Sheet 12/11/2014 | ||
SNG10091953 | SNG10091953 | ||
SCM-CGDP-042 | SCM-CGDP-042 Farley, Hatch and Vogtle Nuclear Plants Commercial Grade 27.0 | ||
Dedication Plan (Bearing) | Dedication Plan (Bearing) | ||
Procedures | Procedures 14803A-2 Train A CCW Pumps and Check Valve IST and Response 08/20/2021 | ||
14803A-2 | 14803A-2 Train A CCW Pumps and Check Valve IST and Response 10/09/2021 | ||
27112-C | 27112-C Safety Injection Pump Maintenance 10 | ||
NMP-DP-001 | NMP-DP-001 Operational Risk Awareness 20.0 | ||
NMP-ES-027 | NMP-ES-027 Maintenance Rule Program 10.4 | ||
NMP-ES-074-006 | NMP-ES-074-006 Fleet Lubrication Instruction 4.0 | ||
NMP-MA-009 | NMP-MA-009 Foreign Material Exclusion Program 16.2 | ||
NMP-MA-009-001 | NMP-MA-009-001 Foreign Material Exclusion Program Requirements 11.1 | ||
SCM-ENG-006 | SCM-ENG-006 Accepting Commercial Grade Items for Use as Basic 8.2 | ||
Components | Components | ||
Work Orders | Work Orders SNC1178604, SNC1180555, SNC1172499 | ||
71111.15 | 71111.15 Corrective Action Condition Reports 10828893, 10829924, 10829977, 10829979, 10830062, | ||
Documents | Documents 10830377, 10830403, 10830550, 10831451, 10831851, | ||
10832538, 10832610, 10833213, 10833295, 10833439, | 10832538, 10832610, 10833213, 10833295, 10833439, | ||
10834273 | 10834273 | ||
Corrective Action 282464 | Corrective Action 282464 | ||
Reports | Reports | ||
Technical | Technical 1093808, 1094635, 1094975, 1094811 | ||
Evaluations | Evaluations | ||
Corrective Action Condition Reports 10831451, 10834273 | Corrective Action Condition Reports 10831451, 10834273 | ||
Documents | Documents Technical 1098071 | ||
Resulting from | Resulting from Evaluations | ||
Inspection | Inspection | ||
Inspection Type | |||
Procedure | Inspection Type Designation Description or Title Revision or | ||
Miscellaneous | Procedure Date | ||
001 | Miscellaneous 1380-0046-RPT-Past Operability Review of Vogtle Unit 1 Safety Injection 0 | ||
1380-0046-RPT- | 001 Pumps | ||
2 | 1380-0046-RPT-Past Operability Review of Vogtle Unit 2 Safety Injection 0 | ||
1X6AG02-00016 | 2 Pumps | ||
Procedures | 1X6AG02-00016 Instruction Manual for Pacific Pumps Safety Injection Pumps 13.0 | ||
NMP-ES-074-006 | Procedures 20412-C General Oil Sample Collection 5.2 | ||
71111.19 | NMP-ES-074-006 Fleet Lubrication Instruction 4.0 | ||
71111.19 Corrective Action Condition Reports 10847606 | |||
Documents | Documents | ||
Resulting from | Resulting from | ||
Inspection | Inspection | ||
Miscellaneous | Miscellaneous 1X6AG02-00016 Instruction Manual for Pacific Pumps Safety Injection Pumps 13.0 | ||
Procedures | Procedures 27112-C Safety Injection Pump Maintenance 10 | ||
83308-C | 83308-C Testing of Safety-Related NSCW System Coolers 33.3 | ||
Work Orders | Work Orders SNC1178604, SNC1180555, SNC1149001, SNC1148998 | ||
71111.20 | 71111.20 Corrective Action Condition Reports 10830844 | ||
Documents | Documents | ||
Miscellaneous | Miscellaneous PQS Schedule Report for Maintenance and Operations for | ||
9/21 - 10/21 | 9/21 - 10/21 | ||
NMP-AD-016- | NMP-AD-016-Fatigue Rule Waiver 09/28/2021 | ||
001-F02 | 001-F02 | ||
71111.22 | 71111.22 Procedures 14666-1 Train A Diesel Generator and ESFAS Test 41.3 | ||
14721D-1 | 14721D-1 ECCS Subsystem Flow Balance and Checkvalve Refueling 2 | ||
Inservice Test | Inservice Test | ||
71152 | 71152 Corrective Action Condition Reports 10824781, 10819677, 10772686, 10789625, 10804971, | ||
Documents | Documents 10805260, 10817917, 10826474, 10801613 | ||
Corrective Action 279673, 279719 | Corrective Action 279673, 279719 | ||
Reports | Reports | ||
Work Orders | Work Orders SNC1165581, SNC1171219, SNC859606 | ||
71153 | 71153 Corrective Action Condition Reports 10753578, 10753583, 10753588, 10753592, 10753938, | ||
Documents | Documents 10754009, 10754020, 10754032, 10754037, 10754061, | ||
10754064, 10754065, 10754320, 10754321, 10754600, | 10754064, 10754065, 10754320, 10754321, 10754600, | ||
10754640, 10754658 | 10754640, 10754658 | ||
Corrective Action 278594 | Corrective Action 278594 | ||
Inspection Type | |||
Procedure | Inspection Type Designation Description or Title Revision or | ||
Procedure Date | |||
Reports | Reports | ||
Corrective Action Condition Reports 10846606 | Corrective Action Condition Reports 10846606 | ||
Line 440: | Line 474: | ||
Resulting from | Resulting from | ||
Inspection | Inspection | ||
Miscellaneous | Miscellaneous 2A/2B/2C Generator Step-Up Transformer Dissolved Gas | ||
Analysis Data | Analysis Data | ||
2-20-001 | 2-20-001 Event Recovery Report: Unit 2 Reactor Trip due to 11/12/2020 | ||
Generator Step-Up (GSU) transformer 'B' Failure | Generator Step-Up (GSU) transformer 'B' Failure | ||
Work Orders | Work Orders SNC1129023 | ||
18 | 18 | ||
}} | }} |
Latest revision as of 19:08, 18 November 2024
ML22027A851 | |
Person / Time | |
---|---|
Site: | Vogtle |
Issue date: | 02/07/2022 |
From: | Alan Blamey NRC/RGN-II/DRP/RPB2 |
To: | Gayheart C Southern Nuclear Operating Co |
References | |
IR 2021004 | |
Download: ML22027A851 (21) | |
Text
February 7, 2022
SUBJECT:
VOGTLE ELECTRIC GENERATING PLANT, UNITS 1&2 - INTEGRATED INSPECTION REPORT 05000424/2021004 AND 05000425/2021004
Dear Ms. Gayheart:
On November 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Vogtle Electric Generating Plant, Units 1&2. On January 19, 2022, the NRC inspectors discussed the results of this inspection with Mr. Drayton Pitts 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&2.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555 -0001; with copies to the Regional Administrator, Region II; and the NRC Resident Inspector at Vogtle Electric Generating Plant, Units 1&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.
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: NPF-68 and NPF-81
Report Numbers: 05000424/2021004 and 05000425/2021004
Enterprise Identifier: I-2021-004- 0016
Licensee: Southern Nuclear Company, Inc.
Facility: Vogtle Electric Generating Plant, Units 1&2
Location: Waynesboro, GA
Inspection Dates: October 01, 2021 to December 31, 2021
Inspectors: B. Caballero, Senior Operations Engineer D. Mas-Penaranda, Project Engineer T. Morrissey, Senior Construction Inspector C. Safouri, Senior Resident Inspector R. Smith, Senior Resident Inspector M. Toth, Senior Project Engineer
Approved By: Alan J. Blamey, Chief Reactor Projects Branch 2 Division of Reactor Projects
Enclosure
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&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.htm l for more information.
List of Findings and Violations
Failure to Follow Procedures Results in Unit 1 Train A Safety Injection Pump Inoperability Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.3] - Change 71111.12 Systems NCV 05000424,05000425/2021004- 02 Management Open/Closed A self-revealed Green finding and associated Non-cited Violation (NCV) of 10 Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, and Technical Specification (TS) 3.5.2, Condition A, when the licensee failed to perform activities affecting quality in accordance with an approved procedure appropriate for the circumstance and operated in a condition prohibited by TS. Specifically, the licensee performed lubrication sampling of the Unit 1 train A safety injection (1A SI) pump while the pump was running, which did not follow NMP-ES- 074- 006, section 2.1, which states, DO NOT use drop tube method to collect oil sample from a GEARBOX that is in operation/running, and ultimately resulted in the inoperability of the system from September 6, 2021, to September 29, 2021.
Additional Tracking Items
Type Issue Number Title Report Section Status URI 05000424,05000425/20 SI Pump Room Unsealed 71111.06 Open 21004- 01 Penetrations During Internal Flooding.
LER 05000424/2021001-00 LER 2021-001-00 for Vogtle 71111.12 Closed Electric Generating Plant,
Unit 1, Train A Safety Injection Pump inoperability causes the unit to operate in a Condition Prohibited by Technical Specifications LER 05000425/2020-001-00 LER 2020-001-00 for Vogtle 71153 Closed Electric Generating Plant Unit 2, Transformer failure leads to main generator trip and subsequent reactor trip
PLANT STATUS
Unit 1 began the inspection period in Mode 5 as part of the refueling outage (1R23) and returned to rated thermal power on October 10, 2021. On December 15, 2021, the unit down powered to 85 percent due to a condenser sodium excursion. The unit was retur ned to rated thermal power on December 20, 2021, and remained at or near rated thermal power for the remainder of the inspection period.
Unit 2 began the inspection period at rated thermal power. On November 18, 2021, the unit was down powered to 92 percent to perform main turbine valves stroke test. The unit was returned to rated thermal power on November 19, 2021, and remained at or near rated thermal power 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, conducted routine review s using IP 71152, Problem Identification and Resolution, 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
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures for the following systems:
auxiliary feedwater system (AFW)nuclear service cooling water (NSCW) system
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (1 Sample)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 2 train B NSCW system due to train B NSCW pump 6 out of service for planned maintenance, on November 2, 2021
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the Unit 2 train A and train B component cooling water (CCW) system, on November 6, 2021
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (2 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) Fire Zones 140A/B/C/E, Unit 1 containment building, on October 4, 2021
- (2) Fire Zones 4/5/9/10, Unit 2 containment spray and residual heat removal pump rooms, on November 7, 2021
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 03.01) (2 Samples)
The inspectors evaluated internal flooding mitigation protections in the:
- (1) Unit 1 train B safety injection (SI) pump room, on December 14, 2021
- (2) Unit 1 train A and train B centrifugal charging pump rooms, on December 20, 2021
71111.07A - Heat Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
- (1) Unit 2 train A CCW heat exchanger, on October 19, 2021
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance
Requalification Examination Results (IP Section 03.03) (1 Sample)
- (1) On October 22, 2021, the licensee completed the annual requalification operating tests required to be administered to all licensed operators in accordance with Title 10 of the Code of Federal Regulations 55.59(a)(2), "Requalification Requirements," of the NRC's "Operator's Licenses." During the week of November 29, 2021, the inspector performed an in-office review of the overall pass/fail results of the individual and crew operating tests in accordance with Inspection Procedure (IP) 71111.11, "Licensed Operator Requalification Program." These results were compared to the thresholds established in Section 3.02, "Requalification Examination Results of IP
===71111.11.
The inspectors reviewed and evaluated the licensed operator failure rates for the requalification annual tests, which the licensee completed administering on October 22, 2021.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during Mode 3 heatup and subsequent mode transitions following the refueling outage (1R23), on October 5, 2021
Licensed Operator Requalification Training/Examinations (IP Section 03.02)===
- (1) The inspectors observed and evaluated simulator training on the execution of prompt operator actions, loss of instrument air event, and security event, on November 2, 2021
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (3 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) Lubrication sampling practices of SI pumps following Unit 1 train A SI pump failure, on September 16, 2021
- (2) Unit 1 train B emergency diesel generator unavailability performance criterion exceeded, on October 18, 2021
- (3) Unit 2 turbine plant sampling valve, 2-HV-9453, a(1) retraction evaluation, on October 27, 2021
Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:
- (1) Unit 2 train A CCW pump #1 following outboard bearing replacement with commercial grade dedication parts, on August 24, 2021
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (1 Sample)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Unit 1 train A SI pump lube oil starvation failure and extent of condition investigation, on September 16, 2021
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated the following post -maintenance test activities to verify system operability and functionality:
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated refueling outage 1R23 from October 1, 2021, to October 7, 2021. The inspectors completed inspection procedure Sections 03.01.d through 03.01.e.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) 14721D-1, emergency core cooling system (ECCS) subsystem flow balance and checkvalve refueling inservice test, on August 15, 2021
- (2) 14666-1, Train A diesel generator and engineered safety features actuation system (ESFAS) test, on September 25,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)===
- (1) Unit 1 (October 1, 2020 through September 30, 2021)
- (2) Unit 2 (October 1, 2020 through September 30, 2021)
MS06: Emergency AC Power Systems (IP Section 02.05) (2 Samples)
- (1) Unit 1 (October 1, 2020 through September 30, 2021)
- (2) Unit 2 (October 1, 2020 through September 30, 2021)
MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)
- (1) Unit 1 (October 1, 2020 through September 30, 2021)
- (2) Unit 2 (October 1, 2020 through September 30, 2021)
71152 - Problem Identification and Resolution (PI&R)
Semiannual Trend Review (IP Section 02.02) (1 Sample)
- (1) The inspectors reviewed the licensees corrective action program for potential adverse trends in Unit 1 train B CCW pump #2 oil level that might be indicative of a more significant safety issue.
Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) Part 21 associated with Barton differential pressure transmitters hydrostatic pressure testing, condition report (CR) 10824781.
- (2) Unit 1 loop 1 accumulator tank leakage, CR 10801613.
71153 - Follow Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)
The inspectors evaluated the following licensee event reports (LERs):
- (1) LER 05000425/2020-001-00, Transformer failure leads to main generator trip and subsequent reactor trip (ADAMS Accession No. ML21008A571): The inspectors determined that it was not reasonable to foresee or correct the cause discussed in the LER therefore no performance deficiency was identified. The inspectors did not identify a violation of NRC requirements.
- (2) LER 05000424/2021-001-00, Unit 1 Train A Safety Injection Pump inoperability causes the unit to operate in a Condition Prohibited by Technical Specifications (ADAMS Accession No. ML21319A348): The inspection conclusions associated with this LER are documented in this report under Inspection Results Section
INSPECTION RESULTS
Unresolved Item SI Pump Room Unsealed Penetrations During Internal 71111.06 (Open) Flooding URI 05000424,05000425/2021004-01
Description:
NRC inspectors are reviewing flood information related to an issue of concern associated with internal flood analyses for the safety injection (SI) pump rooms. During on-site walkdowns of the Unit 1 train B SI pump room on December 14, 2021, NRC inspectors identified an open wall penetration approximately 3-4" in diameter near the top of the room's watertight door, which was also below the maximum calculated flood height of 135 inches (11.25') per Calculation X6CXC-30. By means of an extent of condition comparison, NRC inspectors and licensee staff identified additional open penetrations in the 1A, 2A, and 2B SI pump room walls. These additional open penetrations varied in both location and number for each pump room and can be summarized by the following:
- 1A SI pump room: 2 unsealed or inadequately rated for flood protection o 1-2108-Z1-1392-B and 1-2108-Z1-1572-B
- I pumpm:ealed ornadequatyator flotti o 2-2108-Z1-1488-B and 2-2108-Z1-1490-B
- 2B SI pump room: 5 unsealed or inadequately rated for flood protection o 2-2108-Z1-1080- B, 2-2108-Z1-1081-B, 2-2108-Z1-1082-B, 2-2108-Z1- 0480- B, and 2-2108-Z1- 0481-B
10 CFR Part 50, Appendix B, Criterion III, Design Controls, requires in part, that design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program." Additionally, the Vogtle Electric Design Manual (VEGP) Design Control Number DC-1003, "Flooding-Interdiscipline,"
outlines internal flooding requirements including, in part, the following information:
- Watertight doors shall be used to prevent flooding of safety-related equipment if other simpler means are not feasible; e.g., curbed doorways. The flooding hazard shall be assessed by analysis per section 4.0 of this document. (Section 3.1.12)
- Penetrations through walls of safety-related rooms or areas should be designed to withstand the design flood levels on either side of the walls to prevent leakage through the penetration. Penetrations which do not increase flood levels on either side of walls, by means of communication, need not be sealed against water. (Section 3.1.16)
NRC inspectors identified that the original room drawings and approved internal flood calculations for the SI pump rooms did not include the unsealed penetrations or account for their impact during internal flooding scenarios. This unresolved item (URI) is being opened to determine whether the unsealed flood penetrations were the result of a more-than-minor licensee performance deficiency, and whether or not a regulatory requirement was violated.
Planned Closure Actions: NRC inspectors will review all applicable information related to the flood analyses associated with the on-site SI pump rooms to determine whether a performance deficiency exists. Additionally, NRC inspectors will coordinate these results with a Region II Senior Reactor Analyst to determine overall significance of the issue through the NRC's ROP.
Licensee Actions: Licensee staff have completed an initial assessment of the internal flood analyses for the SI pump rooms and determined the SI pumps remained operable with the identified open penetrations.
Additionally, a work authorization was created and implemented to formally seal the penetration at the 17" level for the 2B SI pump room. The licensee is still evaluating the impact of the penetrations in the additional rooms.
Corrective Action References: Condition Report (CR) 10847097
Failure to Follow Procedures Results in Unit 1 Train A Safety Injection Pump Inoperability Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.3] - Change 71111.12 Systems NCV 05000424,05000425/2021004- 02 Management Open/Closed A self-revealed Green finding and associated Non-cited Violation (NCV) of 10 Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, and Technical Specification (TS) 3.5.2, Condition A, when the licensee failed to perform activities affecting quality in accordance with an approved procedure appropriate for the circumstance and operated in a condition prohibited by TS. Specifically, the licensee performed lubrication sampling of the Unit 1 train A safety injection (1A SI) pump while the pump was running, which did not follow NMP-ES- 074- 006, section 2.1, which states, DO NOT use drop tube method to collect oil sample from a GEARBOX that is in operation/running, and ultimately resulted in the inoperability of the system from September 6, 2021, to September 29, 2021.
Description:
On September 16, 2021, while Unit 1 was in Mode 6, the 1A SI pump was started while performing a surveillance 14721D-1, ECCS Subsystem Flow Balance and Checkvalve Refueling Inservice Test. Shortly after the 1A SI pump start, the system operator saw smoke emit from the pump outboard bearing and local temperature indicator for the bearing rise, and promptly secured the pump and the licensee subsequently declared it inoperable. Upon investigation and disassembly, the licensee discovered the worm gear, which drives the gear -driven lube oil pump, catastrophically damaged. The preliminary cause was attributed to a piece of foreign material (FM), a small piece of plastic, lodged between two gears which was assumed to have prevented or inhibited gear rotation, and subsequent failure of the worm gear which resulted in lube oil starvation (Condition Report (CR)10828893). The licensee replaced several damaged parts (i.e., the wiped bearings) and performed a flush of the lube oil system.
On September 25, 2021, during post maintenance testing following repairs, a similar event occurred with bearing temperatures quickly increasing upon pump start followed by prompt securing of the pump. The worm gear was discovered to be catastrophically failed and the bearings were wiped.
The licensee began troubleshooting a second time and discovered a small check valve within the lube oil system that the licensee was unaware of and was not on the piping and instrumentation diagrams (P&IDs), however was contained in the vendor manual.
Upon disassembly of the check valve, which is located within a union in the lube oil piping, small pieces of FM (plastic), were discovered within the check valve (CR 10830377). This was believed to have resulted in lube oil starvation for the second 1A SI pump failure. Following repairs, the 1A SI pump was successfully restored back to operable on September 29, 2021.
The licensee performed an extent of condition investigation of the SI pumps for both units. On October 3, 2021, the 1B SI pump was tagged out and a few pieces of FM were found within the check valve (CR 10831851). On October 5, 2021, the 2B SI pump was tagged out and contained several pieces of small plastic FM, most of which were found in the oil recirculation piping leg just upstream of the lube oil pressure relief valve, with the remainder found upstream of the oil filter (CR 10733667). On October 7, 2021, the 2A SI pump was tagged out which contained a few pieces of plastic FM, all of which were found in the oil recirculation piping leg just upstream of the lube oil pressure relief valve (CR 10833295). The extent of condition investigation of all SI pumps was completed on October 8, 2021. Overall, the amount of FM found in 1B, 2A, and 2B SI lube oil system was less compared to 1A SI lube oil system.
The plastic FM is believed to have been introduced to the lube oil system during oil sampling. There is a nine-month preventative maintenance task to perform lube oil sampling on the SI pumps, where it is performed while the pump is running. The causal analysis conducted under corrective action report (CAR) 282464 concluded that the FM likely originated from the plastic sampling tube, used during oil sampling, inappropriately being sampled from the gearbox while the pumps were running. The duration of FM existing within the SI pump lube system is unknown.
Additionally, during the extent of condition, the licensee discovered that the 2A and 2B SI pumps both did not contain any check valve (CR 10833295 and CR 10832538). The licensee conducted a detailed search of the corrective action program, work orders, and other documentation to determine when or if the check valve was removed. No documented history was found, and it is unknown when the check valve was removed or for how long the 2A and 2B SI pumps have been operated with no check valve installed in the lube oil pump discharge piping. Vogtle engineering, with support of the vendor, determined that the function of the check valve was to maintain the oil supply piping filled with oil so that when an SI pump is started, the delay in providing adequate lubrication to the bearings is reduced. The issue was characterized as a long-term degradation issue where a slight amount of wear is incurred during each pump start, and the licensee returned the 2A and 2B SI pumps back to operable upon completion of lube oil flush.
The 1A SI pump was last run during an inservice test (IST) on September 6, 2021, for approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. An oil sample was taken during this run and analyzed to be acceptable. The 1B SI pump was last run during an IST on August 30, 2021, for approximately 50 minutes. An oil sample was taken during this run and analyzed to be acceptable. Additionally, due to an unrelated issue surrounding accumulator leakage, the 1A and 1B SI pumps were run frequently (in an alternating manner) for a total of 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> during the months of June through July for periods of approximately 5-10 minutes. Moreover, during the Unit 1 refueling outage, the 1B SI pump was ran 6 times for a total of 2.65 hours7.523148e-4 days <br />0.0181 hours <br />1.074735e-4 weeks <br />2.47325e-5 months <br />. Lastly, the licensee entered a refueling outage and exited the mode of applicability for SI pump operability on September 12, 2021.
The 2A SI pump was last run during an IST on August 12, 2021, for approximately 20 minutes. An oil sample was taken during this run and analyzed to be acceptable.
The 2B SI pump was last run during an IST on August 25, 2021, for approximately 15 minutes. An oil sample was taken during this run and analyzed to be acceptable.
Corrective Actions: The 1A SI pump was repaired, lube oil system was flushed, and returned to service; an extent of condition investigation was performed on all SI pumps on both units; and an interim standing order was put in place to not sample pumps while running until industry benchmarking and subsequent specific guidance has been provided.
Corrective Action References: CAR 282464
Performance Assessment:
Performance Deficiency: Fleet Procedure NMP-ES- 074- 006, Fleet Lubrication Instruction, Version 4.0, states under Section 2.1, Precautions, the following: DO NOT use drop tube method to collect oil sample from a GEARBOX that is in operation/running. Doing so could cause drop tube to be pulled into the GEARBOX from the vampire pump. During oil sampling, the licensee inserted a sampling tube into the lube oil gearbox associated with the SI pumps while the pumps were running, which resulted in FM being introduced to the lube oil system and ultimately, the lube oil starvation of the pump outboard bearing resulted in pump failure.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance 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.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The performance deficiency did require a detailed risk evaluation because the degraded condition represented a loss of the probabilistic risk assessment function of one train of a multi-train TS system for greater than its TS allowed outage time. The total time the 1A SI pump was determined to be inoperable under applicable modes was 137 hours0.00159 days <br />0.0381 hours <br />2.265212e-4 weeks <br />5.21285e-5 months <br />, which is beyond the TS 3.5.2, Condition A, completion time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; TS 3.5.2, Condition B, states if the required action and associated completion time was not met, the unit is required to be in Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Mode 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
A detailed risk evaluation was performed by a regional senior reactor analyst using SAPHIRE Version 8.2.5 and NRC Vogtle SPAR model Version 8.60.
The conditional analysis included a Bayesian update to the failure likelihood of the SI pumps for both Units 1 and 2 with a one-year exposure time. In addition, the conditional risk associated with the failure of the 1A SI pump was also included. No credit was provided in the analysis for recovery of a failed SI pump. The dominant sequence was a Medium Loss of Coolant Accident initiating event accompanied by a failure of the high-pressure injection and cooldown mitigating functions accompanied by the maintenance unavailability of the B -train of safety-related cooling water. The analysis determined that the estimated increase in Core Damage Frequency (CDF) and Large Early Release Frequency (LERF) was less than 1E-06/year for delta-CDF and less than 1E-07/year for delta-LERF, representing a finding of very low safety significance (Green) for both Units 1 and 2.
Cross-Cutting Aspect: H.3 - Change Management: Leaders use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority.
Enforcement:
Violation: 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, states in part that Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Vogtle, Units 1 and 2, Technical Specification (TS) 3.5.2, Emergency Core Cooling Systems (ECCS), requires two ECCS trains shall be operable in Modes 1 through 3; if a train is inoperable, it shall be returned to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or in accordance with the Risk Informed Completion Time Program, otherwise the unit shall be shut down and in Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Mode 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Contrary to the above, sometime between August 22, 2013 (estimated) and September 6, 2021, the licensee failed to accomplish activities affecting quality in accordance with procedures for lubrication sampling of the SI pumps, which rendered the 1A SI pump inoperable under applicable modes for 137 hours0.00159 days <br />0.0381 hours <br />2.265212e-4 weeks <br />5.21285e-5 months <br />, which is greater than the TS allowed outage time, and the unit had not been placed in Mode 3 and Mode 4 within the required times.
Enforcement Action: This violation is being treated as a non-cited violation, 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 January 19, 2022, the inspector s presented the integrated inspection results to Mr.
Drayton Pitts and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.01 Corrective Action Condition Reports 10836230, 10837239
Documents
Corrective Action Condition Reports 10848171
Documents
Resulting from
Inspection
Miscellaneous NMP-GM-025 Site Certification for Winter Readiness 11/15/2021
Procedures 11901-1 Heat Tracing System Alignment 10/18/2021
11901-2 Heat Tracing System Alignment 10/17/2021
17104-1 ARP for Heat Tracing Panel 1NCQARHT 18.1
17104-2 ARP for Heat Tracing Panel 2NCQARHT 18.0
NMP-GM-025 Seasonal Readiness Process 8.0
71111.04 Corrective Action Condition Reports 10839617, 10839691, 10839744, 10839750, 10839751,
Documents 10839785
Resulting from
Inspection
Drawings 2X4DB135-2 P & I Diagram Nuclear Service Water System, System 29.0
Number 1202
2X4DB136 P&I Diagram - Component Cooling Water System - System 24.0
No. 1203
2X4DB137 P&I Diagram - Component Cooling Water System - System 21.0
No. 1203
2X4DB149-1 Flow Diagram - Cooling Water System - Systems 1202, 5.0
203, 1217
2X4DB149-2 Flow Diagram - Cooling Water System - Systems 1202, 4.0
203, and 1217
Miscellaneous 1X4AF01-00136 Instruction Manual Component Cooling Water and Auxiliary 35.0
Component Cooling Water
Procedures 11715-2 Component Cooling Water System Alignment 12.1
13150B-2 Train B Nuclear Service Cooling Water System 16
71111.05 Corrective Action Condition Reports 10842398
Documents
Inspection Type Designation Description or Title Revision or
Procedure Date
Resulting from
Inspection
Procedures 92704-2 Zone 4 - Auxiliary Building - Level D, Containment Spray 2.0
Pump "A" Fire Fighting Preplan
2705-2 Zone 5 - Auxiliary Building - Level D, Containment Spray 3.0
Pump "B" Fire Fighting Preplan
2709-2 Zone 9 - Auxiliary Building - Level D Fire Fighting Preplan 2.2
2710-2 Zone 10 - Auxiliary Building Level D Fire Fighting Preplan 2.2
2840A-1 Zone 140A - Containment Building - Levels A, B, 1, and 3 4.1
East Fire Fighting Preplan
2840B-1 Zone 140B - Containment Building - Levels A, B, 1, 2, and 3 5.1
Fire Fighting Preplan
2840C-1 Zone 140C - Containment Building - Levels A, B, 1 and 3 4.1
Steam Generator Compartment Fire Fighting Preplan
2840E-1 Zone 140E - Containment Building - Levels A, 1 and 2 Fire 1.1
Fighting Preplan
71111.06 Calculations X6CXC-30 Flooding Analysis Auxiliary Building 07/19/1993
Corrective Action Condition Reports 10846893, 10849573, 10852053
Documents
Resulting from
Inspection
Miscellaneous REA 97-VAA632 Door Database 06/30/1998
REA 99-VAA650 Door Database Update 09/03/1999
VEGP Design Flooding - Interdiscipline 11.0
Manual, Design
Control Number
DC-1003
X6CXC-26 Flooding Analysis Auxiliary Building Level C 9
71111.07A Corrective Action Condition Reports 10423905, 10836215, 10837460
Documents
Corrective Action Condition Reports 10845900
Documents
Resulting from
Inspection
Inspection Type Designation Description or Title Revision or
Procedure Date
Miscellaneous 2A CCW HX Fluid Temperatures, 11/7-11/12/2021
AX4AE01-00109 Instruction Manual for CCW and ACCW Heat Exchangers 7.0
ELV-1212 VEGP Response to Generic Letter 89-13 Service Water 01/25/1990
System Problems Affecting Safety-Related Equipment
EPRI 1022980 Guidance for an Effective Heat Exchanger Program 09/2011
NDE Reports 2A CCW HX Post-Plugging Map 11-2021 from ECT Report
2A CCW Heat Exchanger ECT Report 10/19/2021
2X4DR024-019 2A CCW HX Pre-Plugging Map 2021 1
Procedures 30025-C Periodic Analysis Scheduling Program 100
35363-C Chemistry Control of the NSCW System 9.3
38363-2 Chemical Addition to the Unit Two NSCW 12.0
83305-C Heat Exchanger Testing/Maintenance Program 7.11
83306-C CCW and ACCW Heat Exchanger Testing 8
83306-C CCW and ACCW Heat Exchanger Testing 11.1
NMP-ES-012-Heat Exchanger Program Eddy Current Testing (ECT) 1.0
GL05 Strategic Plan for Plant Vogtle
NMP-ES-024-701 Eddy Current Testing of Heat Exchanger Tubing 5.0
Work Orders SNC814889, SNC336301, SNC910488
71111.11Q Miscellaneous V-RQ-SG-21602 Lesson Plan Form 10/14/2021
18028 18037
Procedures 12003-1 Reactor Startup (Mode 3 to Mode 2) 5
2004-1 Power Operation (Mode 1) 8.0
71111.12 Corrective Action Condition Reports 10828893, 10829924, 10829977, 10829979, 10830062,
Documents 10830377, 10830403, 10830550, 10831851, 10832538,
10832610, 10833213, 10833295, 10833439, 10798047,
10819690, 10827428, 10832569
Corrective Action 282464
Reports
Technical 1088188
Evaluations
Corrective Action Condition Reports 10834273
Documents
Resulting from
Inspection
Inspection Type Designation Description or Title Revision or
Procedure Date
Miscellaneous Oil Analysis - Unit 2 CCW #1 08/11/2021
Temperature Trace for 2A CCW Pumps 1 and 3, Inboard 09/15/2021
and Outboard Bearings
1X6AG02-00016 Instruction Manual for Pacific Pumps Safety Injection Pumps 13.0
2-LCO-21-00050 2A CCW Pump 1 INOP Due to Damaged Outboard Bearing
2-LCO-21-00056 2A CCW Pump 1 INOP Due to Damaged Outboard Bearing
MREP20210713 Maintenance Rule Expert Panel Meeting #2021-0713
PO# Warehouse Receipt / Stock Process Sheet 12/11/2014
SNG10091953
SCM-CGDP-042 Farley, Hatch and Vogtle Nuclear Plants Commercial Grade 27.0
Dedication Plan (Bearing)
Procedures 14803A-2 Train A CCW Pumps and Check Valve IST and Response 08/20/2021
14803A-2 Train A CCW Pumps and Check Valve IST and Response 10/09/2021
27112-C Safety Injection Pump Maintenance 10
NMP-DP-001 Operational Risk Awareness 20.0
NMP-ES-027 Maintenance Rule Program 10.4
NMP-ES-074-006 Fleet Lubrication Instruction 4.0
NMP-MA-009 Foreign Material Exclusion Program 16.2
NMP-MA-009-001 Foreign Material Exclusion Program Requirements 11.1
SCM-ENG-006 Accepting Commercial Grade Items for Use as Basic 8.2
Components
Work Orders SNC1178604, SNC1180555, SNC1172499
71111.15 Corrective Action Condition Reports 10828893, 10829924, 10829977, 10829979, 10830062,
Documents 10830377, 10830403, 10830550, 10831451, 10831851,
10832538, 10832610, 10833213, 10833295, 10833439,
10834273
Corrective Action 282464
Reports
Technical 1093808, 1094635, 1094975, 1094811
Evaluations
Corrective Action Condition Reports 10831451, 10834273
Documents Technical 1098071
Resulting from Evaluations
Inspection
Inspection Type Designation Description or Title Revision or
Procedure Date
Miscellaneous 1380-0046-RPT-Past Operability Review of Vogtle Unit 1 Safety Injection 0
001 Pumps
1380-0046-RPT-Past Operability Review of Vogtle Unit 2 Safety Injection 0
2 Pumps
1X6AG02-00016 Instruction Manual for Pacific Pumps Safety Injection Pumps 13.0
Procedures 20412-C General Oil Sample Collection 5.2
NMP-ES-074-006 Fleet Lubrication Instruction 4.0
71111.19 Corrective Action Condition Reports 10847606
Documents
Resulting from
Inspection
Miscellaneous 1X6AG02-00016 Instruction Manual for Pacific Pumps Safety Injection Pumps 13.0
Procedures 27112-C Safety Injection Pump Maintenance 10
83308-C Testing of Safety-Related NSCW System Coolers 33.3
Work Orders SNC1178604, SNC1180555, SNC1149001, SNC1148998
71111.20 Corrective Action Condition Reports 10830844
Documents
Miscellaneous PQS Schedule Report for Maintenance and Operations for
9/21 - 10/21
NMP-AD-016-Fatigue Rule Waiver 09/28/2021
001-F02
71111.22 Procedures 14666-1 Train A Diesel Generator and ESFAS Test 41.3
14721D-1 ECCS Subsystem Flow Balance and Checkvalve Refueling 2
Inservice Test
71152 Corrective Action Condition Reports 10824781, 10819677, 10772686, 10789625, 10804971,
Documents 10805260, 10817917, 10826474, 10801613
Corrective Action 279673, 279719
Reports
Work Orders SNC1165581, SNC1171219, SNC859606
71153 Corrective Action Condition Reports 10753578, 10753583, 10753588, 10753592, 10753938,
Documents 10754009, 10754020, 10754032, 10754037, 10754061,
10754064, 10754065, 10754320, 10754321, 10754600,
10754640, 10754658
Corrective Action 278594
Inspection Type Designation Description or Title Revision or
Procedure Date
Reports
Corrective Action Condition Reports 10846606
Documents
Resulting from
Inspection
Miscellaneous 2A/2B/2C Generator Step-Up Transformer Dissolved Gas
Analysis Data
2-20-001 Event Recovery Report: Unit 2 Reactor Trip due to 11/12/2020
Generator Step-Up (GSU) transformer 'B' Failure
Work Orders SNC1129023
18