IR 05000424/2004008

IR 05000424-04-008, 05000425-04-008, on 11/01/2004 - 11/19/2004; Vogtle Electric Generating Plant, Units 1 and 2; Biennial Baseline Inspection of the Identification and Resolution of Problems

ML043510257
Person / Time
Site:	Vogtle
Issue date:	12/16/2004
From:	Brian Bonser NRC/RGN-II/DRP/RPB2
To:	Grissette D Southern Nuclear Operating Co
References
IR-04-008
Download: ML043510257 (15)

Text

ber 16, 2004

SUBJECT:

VOGTLE ELECTRIC GENERATING PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000424/2004008 AND 05000425/2004008

Dear Mr. Grissette:

On November 19, 2004, the U. S. Nuclear Regulatory Commission (NRC) completed a team inspection at your Vogtle Electric Generating Plant, Units 1 and 2. The enclosed inspection report documents the inspection findings, which were discussed on November 19, 2004 with Mr. Kitchens and other members of your staff.

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

On the basis of the sample selected for review, there were no findings of significance identified during this inspection. The team concluded that problems were properly identified, evaluated, and resolved within the problem identification and resolution programs. A low threshold for entering problems into your corrective action program was observed. However, during the inspection minor examples of problems were found that had not been identified and entered into the corrective action program.

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

Sincerely,

/RA by C. Rapp for/

Brian R. Bonser, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket Nos. 50-424, 50-425 License Nos.: NPF-68, NPF-81

Enclosure:

Inspection Report 05000424/2004008 and 05000425/2004008 w/Attachment: Supplemental Information

REGION II==

Docket Nos.: 50-424, 50-425 License Nos.: NPF-68, NPF-81 Report Nos.: 05000424/2004008 and 05000425/2004008 Licensee: Southern Nuclear Operating Company, Inc. (SNC)

Facility: Vogtle Electric Generating Plant Location: 7821 River Road Waynesboro, GA 30830 Dates: November 1 - 5, 2004, and November 15 - 19, 2004 Inspectors: J. Stewart, Senior Resident Inspector, Crystal River 3 T. Morrissey, Resident Inspector, Vogtle Electric Generating Plant S. Rose, Senior Operations Engineer R. Cortez, Reactor Inspector Approved by: Brian R. Bonser, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000424/2004-008, 05000425/2004-008; 11/01/2004 - 11/19/2004; Vogtle Electric

Generating Plant, Units 1 and 2; Biennial baseline inspection of the Identification and Resolution of Problems.

The inspection was conducted by a senior resident inspector, a resident inspector, a senior operations engineer, and a reactor inspector. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.

Identification and Resolution of Problems The inspection team determined that the licensee was identifying plant deficiencies at an appropriate low level and entering them into the corrective action program. After reviewing condition reports, conducting system walkdowns, and examining equipment tracking databases, the team identified some minor deficiencies. During system walkdowns, the inspectors identified three minor conditions adverse to quality that had not been identified by the licensee.

Also, inspectors identified several minor documentation discrepancies. Quality Assurance audits were effective at identifying issues at a very low level. The licensee adequately prioritized issues and evaluations were technically accurate and of sufficient depth. Formal root cause evaluations using widely accepted methods were adequate in determining the root and contributing causes of problems. Corrective actions to fix problems were appropriate and timely. Because the licensee had identified a number of problems related to human error which were not restricted to any one group, the licensee had implemented a site wide human performance improvement initiative. The inspectors did not identify any reluctance on the part of the employees to document safety concerns in the corrective action program.

A. Inspector Identified Findings None

Licensee Identified Violations

None

REPORT DETAILS

4OA2 Problem Identification and Resolution

a. Effectiveness of Problem Identification

(1) Inspection Scope The inspectors reviewed the licensees corrective action program (CAP) procedures which described the administrative process for initiating problem review and resolution using Condition Reports (CRs). The inspectors walked down selected plant systems, observed control room activities, accompanied plant operators on their daily tours, reviewed selected CRs, and attended meetings where CRs were screened for significance to determine if the licensee was identifying and accurately entering problems into the corrective action program at an appropriate threshold. The CRs reviewed were selected from all CRs issued between December 2002 and November 2004.

The inspectors reviewed selected CRs covering all the cornerstones of safety identified in the NRCs Reactor Oversight Process (ROP), the licensees CAP severity levels, and site departments. CRs associated with violations documented in NRC inspection reports were specifically selected for review. Additionally, the inspectors reviewed CRs associated with Maintenance Rule (MR) evaluations. These reviews were performed to verify that problems were being properly identified and accurately entered into the CAP.

The inspectors also held discussions with various personnel to evaluate their threshold for identifying and documenting issues. The inspectors also conducted Main Control Room (MCR) board walkdowns to verify that deficiencies were entered into the CAP.

The inspectors conducted a detailed review of CRs for the Auxiliary Feedwater (AFW),

Nuclear Service Cooling Water (NSCW), Residual Heat Removal (RHR), and Safety Injection (SI) systems. These systems were selected based on risk insights from the licensees probabilistic risk assessment. The inspectors reviewed the maintenance history and completed Work Orders (WOs) for the systems, reviewed system health reports, and conducted system walkdowns to check for any deficiencies that had not been entered into the CAP. The inspectors reviewed selected industry operating experience items associated with the systems, including NRC generic communications, to verify that these were appropriately evaluated for applicability and, if necessary, were entered into the CAP. In addition, an extended five year review was performed for the AFW and SI systems.

The inspectors reviewed licensee Quality Assurance audits and self-assessments, including those which focused on problem identification and resolution, to verify that findings were processed in the CAP and to verify that these findings were consistent with the NRCs assessment of the licensees programs.

Documents reviewed are listed in the Attachment.

(2) Assessment The inspectors determined that the licensee was generally effective in identifying problems, including personnel errors and equipment issues, and entering them into the CAP. The inspectors observed that employees were encouraged to initiate CRs at an appropriate level when problems were identified. To minimize radiation exposure, the licensee specified that system engineers and operators only infrequently walkdown and assess material condition of systems in areas with higher localized radiation levels.

Subsequently, during the RHR system walkdown, the inspectors identified three minor deficiencies (two motor bearing oil leaks and one boric acid leak from a compression fitting) that had not been identified by the licensee. The licensee entered these deficiencies into the CAP. Walkdowns of the other systems did not identify similar issues. The inspectors found the MCR to be well maintained and MCR deficiencies had been identified in the CAP or maintenance work order system for resolution.

The licensee was effective in evaluating internal and external industry operating experience items for applicability and entering issues into the CAP. Operating experience items of significance were immediately reviewed, assessed for applicability, and provided to management for priority attention. Quality Assurance audits were effective at identifying issues at a very low level which were then entered into the CAP where appropriate and corrected.

(3) Findings No findings of significance were identified.

b. Prioritization and Evaluation of Issues

(1) Inspection Scope The inspectors reviewed CRs processed since December 2002 to determine adequacy of prioritization and evaluation of problems to verify that the licensee adequately assessed issues for priority commensurate with their risk significance; determined the cause of significant problems including root cause where appropriate; and adequately addressed operability, reportability, common cause, generic concerns, and extent of condition. The review included the appropriateness of the assigned significance, the timeliness of resolution, and the scope and depth of the causal analysis, and the assignment of corrective actions to address the cause of problems. To streamline efforts, the licensee recently implemented a corporate corrective actions management process. The inspectors checked that issues continued to be identified in the new program at an appropriate threshold and received an appropriate level of evaluation. In reviewing the new process, the inspectors reviewed the activities of the recently established Corrective Actions Review Board (CARB) which involved senior site management in the review of root cause reports and corrective actions for issues of higher risk significance.

The inspectors attended various plant meetings to observe management oversight functions of the corrective action process. These included morning management meetings and Corrective Action Program Coordinator (CAPCO) meetings, where newly identified issues were screened for significance. The inspectors interviewed individuals involved in processing of corrective action reports to verify an appropriate level of technical skill to ensure that the program was completed consistently and as intended by the licensees procedures.

Documents reviewed are listed in the Attachment.

(2) Assessment The inspectors determined that the licensee adequately prioritized issues entered into the CAP. For issues of risk significance, the licensee performed evaluations that were technically accurate and of sufficient depth. Formal root cause evaluations using widely accepted methods were adequate in determining the root and contributing causes of more significant problems.

Site management was actively involved in the CAP process and focused appropriate attention on significant plant issues during their review and discussion of CRs. The CAPCO meetings provided timely initial assessments and assignment of initial responsibility for issues entered into the CAP. The recent use of the CARB to review root cause reports and corrective actions provided management oversight of the formal root cause process assigned to significant issues and was considered a positive addition to the program.

The CAP procedure allowed for management judgement to be applied for CR severity level classification. The inspectors recognized the need for management flexibility to effectively implement the CAP. The inspectors observed that several CRs were assigned higher levels of review than specified by their apparent risk significance. As a result, some issues of apparently low risk significance were receiving an elevated level of management attention to prevent more serious problems from developing. Similarly, because a number of problems related to human error had been identified which were not restricted to any one group, the licensee had implemented a site wide human performance improvement initiative.

(3) Findings No findings of significance were identified.

c. Effectiveness of Corrective Actions

(1) Inspection Scope The inspectors reviewed CRs and the licensees Major Issues List to verify that the licensee had identified and implemented timely and appropriate corrective actions to address problems and that the corrective actions were properly documented, assigned, and tracked to ensure completion. The review was also to verify the adequacy of corrective actions to address equipment deficiencies and MR functional failures in risk significant plant systems. For more significant problems, the inspectors reviewed the corrective actions to verify they would prevent recurrence and had received appropriate priority. Effectiveness reviews of corrective actions that had been completed for problems of higher significance were checked and compared with NRC assessments of performance to verify that issues were being properly addressed.

Documents reviewed are listed in the Attachment.

(2) Assessment In general, corrective actions developed and implemented for problems were timely and effective. During the two year period that was reviewed, plant performance was such that no issues were assigned the highest significance (Severity Level 1). As specified by licensee procedures, Severity Level 2 was assigned to issues such as MR functional failures and uncomplicated plant transients. For these issues, corrective actions addressed the root cause and effectively prevented recurrence.

The inspectors identified an isolated issue where completed corrective actions did not prevent repeated Foreign Materials Control Log documentation problems for the spent fuel pool area. The licensee took immediate corrective action and documented the issue in the CAP. No examples involving actual loss of materials in the spent fuel pool area were identified.

The inspectors did not identify any examples of problem recurrence that resulted from not performing a root cause investigation or an example of a significant issue where it could be concluded that the actual root cause had not been determined. The inspectors noted a few documentation discrepancies where CAP files did not reflect all of the corrective actions taken in resolving problems. The inspectors also identified an isolated example where a procedure revision did not match the specified corrective actions. The licensee documented these issues in the CAP.

(3) Findings No findings of significance were identified.

d. Assessment of Safety-Conscious Work Environment

(1) Inspection Scope The inspectors questioned members of the plant staff to assess if any conditions existed that would cause employees to be reluctant to raise safety concerns. The inspectors also reviewed the licensees employee concerns program (ECP) which provided a method for employees to anonymously raise safety concerns. The inspectors interviewed the ECP Manager and reviewed selected ECP reports completed in 2003 and 2004 to verify that concerns were being properly reviewed and identified deficiencies were being resolved.

Documents reviewed are listed in the Attachment.

(2) Assessment The inspectors did not identify any reluctance to report safety concerns. Licensee management emphasized the need for all employees to promptly identify and report problems using the appropriate methods established within the administrative programs.

(3) Findings No findings of significance were identified.

4OA6 Management Meetings

On November 19, 2004, the inspectors presented the inspection results to Mr. Kitchens and other members of the Vogtle staff. The inspectors confirmed that proprietary information was not provided or examined during the inspection.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

W. Bargeron, Plant Support Assistant General Manager

C. Buck, Chemistry Manager

W. Burmeister, Manager Engineering Support

B. Diehl, Supervisor, Outage and Scheduling

S. Douglas, Manager Operations

W. Kitchens, Nuclear Plant General Manager

C. Miller, Acting Manager, Performance Assessment

D. Monahon, Quality Assurance Engineer

S. Rucker, Quality Assurance Specialist

T. Tynan, Assistant General Manager Nuclear Operations

NRC personnel

L. Wert, Deputy Director, DRP