ML13032A277

IR 05000424-12-005 & 05000425-12-005, 10/01/2012 - 12/31/2012, Vogtle Electric Generating Plant, Units 1 and 2, Post-Maintenance Testing, Identification and Resolution of Problems

ML13032A277
Person / Time
Site:	Vogtle
Issue date:	02/01/2013
From:	Ehrhardt F J NRC/RGN-II/DRP/RPB2
To:	Tynan T E Southern Nuclear Operating Co
References
IR-12-005
Download: ML13032A277 (51)

See also: IR 05000424/2012005

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 February 1, 2013 Mr. Tom E. Tynan

Vice President - Vogtle

Southern Nuclear Operating Company, Inc.

Vogtle Electric Generating Plant

7821 River Road Waynesboro, GA 30830

SUBJECT: VOGTLE ELECTRIC GENERATING PLANT - NRC INTEGRATED INSPECTION REPORT 05000424/2012005 AND 05000425/2012005 Dear Mr. Tynan:

On December 31, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed an

inspection at your Vogtle Electric Generating Plant, Units 1 and 2. The enclosed integrated

inspection report documents the inspection findings, which were discussed on January 11, 2013, with you and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed

personnel. Three self-revealing findings of very low safety significance (Green) were identified during this inspection. These findings were determined to involve violations of NRC requirements. Two licensee-identified violations which were determined to be of very low safety significance are listed in this report. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest these NCVs, you should provide a response within 30 days of the date of this

inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington DC 20555-0001; with copies to the Regional

Administrator, Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Vogtle Electric Generating Plant.

If you disagree with the cross-cutting aspects assigned 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 Regional Administrator, Region II; and the NRC Resident Inspector at the Vogtle Electric Generating Plant.

T. Tynan 2

In accordance with the 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosures, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Document Access and Management 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/ Frank Ehrhardt, Chief Reactor Projects Branch 2

Division of Reactor Projects

Docket Nos.: 05000424, 05000425 License Nos.: NPF-68 and NPF-81

Enclosures: Inspection Report 05000424/2012005 and 05000425/2012005 w/Attachment: Supplemental Information

cc w/encl: (See page 3)

T. Tynan 2

In accordance with the 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosures, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Document Access and Management 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/ Frank Ehrhardt, Chief Reactor Projects Branch 2

Division of Reactor Projects

Docket Nos.: 05000424, 05000425 License Nos.: NPF-68 and NPF-81

Enclosures: Inspection Report 05000424/2012005 and 05000425/2012005 w/Attachment: Supplemental Information

cc w/encl: (See page 3)

X PUBLICLY AVAILABLE G NON-PUBLICLY AVAILABLE G SENSITIVE X NON-SENSITIVE ADAMS: G Yes ACCESSION NUMBER:_________________________ X SUNSI REVIEW COMPLETE G FORM 665 ATTACHED OFFICE RII:DRP RII:DRP RII:DRS RII:DRS RII:DRS RII:DRS RII:DRS SIGNATURE Via email Via email Via email Via email Via email Via email Via email NAME MCain TChandler BCaballero ANielsen CDykes WPursley JLaughlin DATE 01/25/2013 02/31/2013 01/25/2013 01/28/2013 01/28/2013 01/29/2013 01/28/2013 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO OFFICE RII:DRP RII:DRP SIGNATURE MOM /RA/ FJE /RA/ NAME MMiller FEhrhardt DATE 01/20/2013 02/01/2013 2/ /2013 2/ /2013 2/ /2013 2/ /2013 2/ /2013 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO OFFICIAL RECORD COPY DOCUMENT NAME: G:\DRPII\RPB2\VOGTLE\REPORTS\2012\2012-005\VOGTLE 2012005.DOCX

T. Tynan 3

cc w/encl: C. Russ Dedrickson Fleet Support Supervisor

Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution

S. Kuczynski Chairman, President and CEO Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution

Todd L. Youngblood Vice President Fleet Oversight

Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution

W. L. Bargeron Plant Manager

Vogtle Electric Generating Plant

Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution

D. G. Bost Chief Nuclear Officer

Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution

N. J. Stringfellow Licensing Manager

Southern Nuclear Operating Company, Inc.

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Paula Marino Vice President Engineering

Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution

T. A. Lynch Vice President

Joseph M. Farley Nuclear Plant

Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution

Arthur H. Domby, Esq. Troutman Sanders

Electronic Mail Distribution

Dennis R. Madison Vice President Edwin I. Hatch Nuclear Plant

Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution

Leigh Perry SVP & General Counsel-Ops & SNC Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution

T. E. Tynan Site Vice President Vogtle Electric Generating Plant

Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution

M. J. Ajluni Nuclear Licensing Director

Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution

B. D. McKinney, Jr. Regulatory Response Manager Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution

D. W. Daughhetee Licensing Engineer Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution

Bradley J. Adams

Vice President Fleet Operations Support Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution

T. D. Honeycutt Regulatory Response Supervisor Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution

(cc/w enclosure continued next page)

T. Tynan 4

(cc w/encl continued) L. P. Hill

Licensing Supervisor

Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution

L. L. Crumpton Administrative Assistant, Sr.

Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution

Hickox, T. Mark Vogtle Electric Generating Plant

Electronic Mail Distribution

Mark Rauckhorst Site Vice President Vogtle Units 3 and 4

Southern Nuclear Operating Company

Electronic Mail Distribution

S. C. Swanson Site Support Manager Vogtle Electric Generating Plant

Electronic Mail Distribution

Jerry Ranalli Municipal Electric Authority of Georgia Power

Electronic Mail Distribution

Sandra Threatt, Manager

Nuclear Response and Emergency Environmental Surveillance Bureau of Land and Waste Management

Department of Health and Environmental

Control

Electronic Mail Distribution Division of Radiological Health

TN Dept. of Environment & Conservation

401 Church Street

Nashville, TN 37243-1532

Office of the Attorney General 40 Capitol Square, SW

Atlanta, GA 30334

Richard Haynes Director, Division of Waste Management Bureau of Land and Waste Management

S.C. Department of Health and

Environmental Control

2600 Bull Street

Columbia, SC 29201 Lee Foley

Manager of Contracts Generation

Oglethorpe Power Corporation

Electronic Mail Distribution Mark Williams

Commissioner

Georgia Department of Natural Resources

Electronic Mail Distribution Chuck Mueller

Manager

Policy and Radiation Program

Georgia Department of Natural Resources

Electronic Mail Distribution Cynthia A. Sanders

Radioactive Materials Program Manager

Environmental Protection Division

Georgia Department of Natural Resources Electronic Mail Distribution

James C. Hardeman

Environmental Radiation Program Manager

Environmental Protection Division

Georgia Department of Natural Resources Electronic Mail Distribution

Mr. Steven M. Jackson

Senior Engineer - Power Supply

Municipal Electric Authority of Georgia Electronic Mail Distribution

Reece McAlister

Executive Secretary

Georgia Public Service Commission

Electronic Mail Distribution (cc w/encl continued next page)

T. Tynan 5

(cc w/encl continued) Office of the County Commissioner

Burke County Commission

Electronic Mail Distribution

Director Consumers' Utility Counsel Division Governor's Office of Consumer Affairs

2 M. L. King, Jr. Drive

Plaza Level East; Suite 356

Atlanta, GA 30334-4600 Amy Whaley

Resident Manager

Electronic Mail Distribution

T. Tynan 6

Letter to Tom E. Tynan from Frank Ehrhardt dated February 1, 2013 SUBJECT: VOGTLE ELECTRIC GENERATING PLANT - NRC INTEGRATED INSPECTION REPORT 05000424/2012005 AND 05000425/2012005

Distribution w/encl: C. Evans, RII L. Douglas, RII OE Mail

RIDSNRRDIRS

PUBLIC

RidsNrrPMVogtle Resource

Enclosure U. S. NUCLEAR REGULATORY COMMISSION REGION II

Docket Nos.: 50-424, 50-425 License Nos.: NPF-68, NPF-81

Report Nos.: 05000424/2012005 and 05000425/2012005

Licensee: Southern Nuclear Operating Company, Inc. (SNC)

Facility: Vogtle Electric Generating Plant, Units 1 and 2 Location: Waynesboro, GA 30830

Dates: October 1, 2012 through December 31, 2012

Inspectors: M. Cain, Senior Resident Inspector T. Chandler, Resident Inspector B. Caballero, Senior Operations Engineer A. Nielsen Senior Health Physicist C. Dykes Health Physicist W. Pursley Health Physicist J. Laughlin Emergency Preparedness Inspector R. Williams Reactor Inspector

A. Vargas-Mendez Reactor Inspector Approved by: Frank Ehrhardt, Chief Reactor Projects Branch 2 Division of Reactor Projects

Enclosure SUMMARY OF FINDINGS IR 05000424/2012-005, 05000425/2012-005; 10/01/2012 - 12/31/2012; Vogtle Electric Generating Plant, Units 1 and 2; Post-Maintenance Testing, Identification and Resolution

of Problems The report covered a three-month period of inspection by the resident inspectors. Three

non-cited violations (NCVs) with very low safety significance (Green) were identified. The significance of inspection findings are indicated by their color (i.e., great than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" dated June 19, 2012. Cross-cutting aspects

are determined using IMC 0310, "Components Within The Cross-Cutting Areas" dated

October 28, 2011. All violations of NRC requirements are dispositioned in accordance with the NRC's Enforcement Policy dated June 7, 2012. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in

NUREG-1649, "Reactor Oversight Process" revision 3.

Cornerstone: Mitigating Systems Green: A self-revealing non-cited violation (NCV) for failure to meet the requirements of 10 CFR Part 50 Appendix B, Criterion V, "Instructions, Procedures, and Drawings" was

identified for failure to provide adequate work instructions in the maintenance procedure

used to modify 480V EMAX safety-related switchgear breakers. Specifically, when modifying the breaker by adding a higher amperage closing coil, failure to verify the proper placement of the wire bundle on top of the closing coil following replacement resulted in the safety-related 2A NSW cooling tower fan #3 480V EMAX breaker failing

to close when demanded. The licensee replaced the failed breaker and returned the fan

to operable status within 21.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.

The finding was more than minor because it impacted the reactor safety mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences and affected the cornerstone attribute of equipment performance. Since the inspectors

answered "No" to all of the IMC 0609.04 (dated June 19, 2012) Exhibit 2, section A,

questions 1-4, mitigating systems cornerstone screening questions, the inspectors concluded that the finding was of very low safety significance (Green). The cause of this finding was related to the corrective action program component of the problem

identification and resolution cross-cutting area due to less-than-adequate problem

evaluation. P.1(c) Specifically, the licensees' extent of cause evaluations performed on previous 480V EMAX breaker failures (caused by restricted movement of the close lever) did not identify the potential of the closing coil wire bundle to interfere with the proper movement of the close lever. The licensee's corrective action to the 480V EMAX breaker issue was to revise the maintenance procedure used to perform maintenance on

EMAX breakers (procedure 28480-C, 480V EMAX Breaker Maintenance), and then

inspect all 480V EMAX breakers on site that had been modified with the higher

amperage closing coil to verify that the wire bundles were not interfering with the operation of the close coil. The licensee entered this into their corrective action program as CR 549999 and CR 550736. (Section 1R19)

3 Enclosure Cornerstone: Initiating Events Green: A self-revealing non-cited violation (NCV) for failure to meet the requirements of 10 CFR Part 50 Appendix B, Criterion V, "Instructions, Procedures, and Drawings" was

identified for failure to provide adequate work instructions in the operations and

maintenance procedures used to open main steam isolation valves (MSIVs) that were bound in their closed seat. Specifically, the operations and maintenance procedures used to open the loop 2 and loop 3 outboard MSIVs did not provide instructions to limit the magnitude of the force applied to the valve stems while attempting to open the

valves, which ultimately resulted in the brittle failure of the valve stems. The licensee conducted ultrasonic testing of the remaining six Unit 1 MSIVs to verify that the valve

stems were intact. The two failed valve stems were replaced, and the reactor was restarted nine days later.

The finding was more than minor because it was associated with the procedure quality

attribute of the reactor safety - initiating events cornerstone and it adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the failure to provide adequate work instructions to operations and

maintenance personnel resulted in the failure of both the loop 2 and loop 3 outboard

MSIVs and the subsequent manual reactor trip. Since the inspectors answered "no" to

the Exhibit 1, section B, initiating events screening question, the inspectors concluded

that the finding was of very low safety significance (Green). The cause of the finding was related to the work control component of the human performance cross-cutting area due to less-than-adequate work planning. H.3(a) Specifically, the licensees'

procedures used to open the MSIVs that were stuck on their closed seat did not contain

instructions or precautions to limit the magnitude of the force applied to the valve stems while attempting to open the valves. The licensee entered this issue into their corrective action program as CR 530916. (Section 4OA2)

Cornerstone: Occupational Radiation Safety

Green: The inspectors identified a Green, self-revealing, Non-cited Violation of technical specification 5.7.1, "High Radiation Area", for an unauthorized entry into a High Radiation Area (HRA). A maintenance worker entered a HRA in Unit 1 containment without being briefed on the radiological conditions. The licensee entered this issue into

their corrective action program as CR 523976 and took immediate corrective actions including an outage work crew stand down. This finding was more than minor because it was associated with the occupational radiation safety cornerstone attribute of human performance and adversely affects the cornerstone objective of ensuring adequate protection of worker health and safety from

exposure to radiation from radioactive material during routine civilian nuclear reactor

operation. The finding was evaluated using the occupational radiation safety

significance determination process. The finding was not related to As Low As Reasonably Achievable (ALARA) planning, nor did it involve an overexposure or substantial potential for overexposure, and the ability to assess dose was not

compromised. Therefore, the finding was determined to be of very low safety

4 Enclosure significance (Green). This finding involved the cross-cutting aspect of human performance, work practices H.4.b] because the HRA event was a direct result of poor communications during the pre-job briefing and a lack of procedure adherence on the

part of the maintenance worker. The licensee entered this issue into the Corrective

Action Program (CAP) as CR 523976. (Section 2RS1)

Violations of very low safety significance that were identified by the licensee have been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensee's corrective action program. These violations and the corrective action tracking numbers are listed in Section 4OA7 of this report.

Enclosure REPORT DETAILS Summary of Plant Status Unit 1 started the report period shutdown for a planned refueling outage. The licensee

conducted a reactor startup on October 8; however the licensee shutdown unit 1 later

that day due to issues with two main steam isolation valves (MSIVs). The licensee restarted unit 1 on October 17 and attained full rated thermal power (RTP) power on

October 21. Unit 1 operated at essentially full RTP for the remainder of the inspection period.

Unit 2 operated at essentially full RTP for the entire inspection period.

1. REACTOR SAFETY Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

1R01 Adverse Weather Protection (71111.01) .1 Seasonal Extreme Weather Conditions

a. Inspection Scope

The inspectors conducted a detailed review of the station's adverse weather procedures

written for extreme low temperatures. The inspectors verified that weather related equipment deficiencies identified during the previous year had been corrected prior to the onset of seasonal extremes. The inspectors evaluated the licensee's

implementation of adverse weather preparation procedures and compensatory measures before the onset of seasonal extreme weather conditions. Documents

reviewed are listed in the Attachment. The inspectors evaluated the following risk-significant systems: * Unit 1 emergency diesel generator (EDG) system (both trains) * Unit 2 nuclear service cooling water (NSCW) system (both trains) b. Findings No findings were identified. .2 Impending Adverse Weather Conditions

a. Inspection Scope The inspectors reviewed the licensee's preparations to protect risk-significant systems from predicted severe weather conditions of sub-freezing temperatures expected on December 21, 2012. The inspectors evaluated the licensee's implementation of adverse weather preparation procedures and compensatory measures, including operator

staffing, before the onset of and during the adverse weather conditions. The inspectors

6 Enclosure reviewed the licensee's plans to address the ramifications of potentially lasting effects that may result from sub-freezing temperatures. The inspectors verified that operator actions specified in the licensee's adverse weather procedure maintained readiness of

essential systems. The inspectors verified that required surveillances were current, or

were scheduled and completed, if practical, before the onset of anticipated adverse

weather conditions. The inspectors also verified the licensee implemented periodic

equipment walk-downs or other measures to ensure that the condition of plant equipment met operability requirements. Documents reviewed are listed in the Attachment.

b. Findings No findings were identified. 1R04 Equipment Alignment (71111.04)

.1 Partial Walkdown The inspectors verified that critical portions of selected risk-significant systems were

correctly aligned. The inspectors selected systems for assessment because they were a redundant or backup system/train, were important for mitigating risk for the current plant

conditions, had been recently realigned, or were a single-train system. The inspectors determined the correct system lineup by reviewing plant procedures and drawings. The inspectors verified that critical portions of the selected systems were correctly aligned by performing partial walkdowns. Document reviewed are listed in the Attachment. The

inspectors selected the following three systems/trains to inspect: * Diesel-driven fire water pump #2, the motor-driven firewater pump, and the associated yard piping system while the diesel-driven firewater pump # 1 was out of service for a scheduled maintenance outage * Unit 1 train B containment spray (CS) system while the Unit 1 train A CS system was out of service due to a planned maintenance outage. * Unit 1 train B residual heat removal (RHR) system b. Findings No findings were identified.

.2 Complete Walkdown a. Inspection Scope

The inspectors verified the alignment of the Unit 1 A train residual heat removal (RHR)

system. The inspectors selected this system for assessment because it is a risk-

significant mitigating system. The inspectors determined the correct system lineup by reviewing plant procedures, drawings, the updated final safety analysis report, and other documents. In order to identify any deficiencies that could affect the ability of the system to perform its function(s), the inspectors reviewed records related to outstanding design

7 Enclosure issues and maintenance work requests. The inspectors verified that the selected system was correctly aligned by performing a complete walk down of accessible components.

To verify the licensee was identifying and resolving equipment alignment discrepancies, the inspectors reviewed corrective action documents, including condition reports and

outstanding work orders, as well as periodic reports containing information on the status

of risk-significant systems, including maintenance rule reports and system health reports. Document reviewed are listed in the Attachment.

b. Findings No findings were identified. 1R05 Fire Protection (71111.05AQ)

a. Inspection Scope Quarterly Inspection The inspectors evaluated the adequacy of selected fire plans by comparing the fire plans

to the defined hazards and defense-in-depth features specified in the fire protection

program. In evaluating the fire plans, the inspectors assessed the following items:

(1) control of transient combustibles and ignition sources, (2) fire detection systems, (3) water-based fire suppression systems, (4) gaseous fire suppression systems, (5) manual firefighting equipment and capability (6) passive fire protection features, (7)

compensatory measures and fire watches, and (8) issues related to fire protection

contained in the licensee's corrective action program. The inspectors toured the

following five fire areas to assess material condition and operational status of fire protection equipment. Documents reviewed are listed in the Attachment. * Unit 1 north and south main steam valve room, fire zones 99, 104 and 45 * Unit 2 control building level B east penetration areas (zones 62, 63 and 82) and west penetration areas (zones 60, 61, and 64) * Unit 1A and 1B nuclear service cooling water (NSCW) pump rooms, fire zones 160A and 160B * Unit 1 A, B, C, and D class 1E 125 VDC station batteries and associated switchgear rooms, fire zones 71, 76, 77A, 77B, 78A, 78B, 79A, 79B, 56A, 56B, 83, and 152 * Unit 2 A, B, C, and D class 1E 125 VDC station batteries and associated switchgear rooms, fire zones 71, 76, 77A, 77B, 78A, 78B, 79A, 79B, 56A, 56B, 83, and 152

b. Findings No findings were identified.

8 Enclosure 1R06 Flood Protection Measures (71111.06) .1 Internal Flooding The inspectors reviewed related flood analysis documents and walked down the areas listed below that contain risk significant structures, systems, and components susceptible to flooding. The inspectors verified plant design features and plant procedures for flood mitigation were consistent with design requirements and internal flooding analysis assumptions. The inspectors also assessed the condition of flood

protection barriers and drain systems. In addition, the inspectors verified the licensee

was identifying and properly addressing issues using their corrective action program. Documents reviewed are listed in the Attachment. * Unit 2 residual heat removal (RHR) and containment spray (CS) pump rooms b. Findings No findings were identified. .2 Underground Cables

a. Inspection Scope The inspectors reviewed related flood analysis documents and inspected the areas listed below that contain cables whose failure could disable risk significant equipment. The inspector directly observed the condition of cables and cable support structures and, as

applicable, verified that dewatering devices and drainage systems were functioning

properly. In addition, the inspectors verified the licensee was identifying and properly

addressing issues using their corrective action program. Documents reviewed are listed in the Attachment. * Cable Pull Boxes: 1NE7ADKEM40, 1NE7ADKEM39, 1NE9GHKEPB01 b. Findings No findings were identified.

1R07 Heat Sink Performance (71111.07)

.1 Annual Review a. Inspection Scope The inspectors verified the readiness and availability of the Unit 1 emergency diesel

generator (EDG) jacket water (JW) heat exchanger to perform its design function by observing performance tests or reviewing reports of those tests, verifying the licensee uses the periodic maintenance method outlined in Generic Letter 89-13, "Service Water

9 Enclosure System Problems Affecting Safety Related Equipment," observing the licensee's heat exchanger inspections and verifying critical operating parameters through direct observation or by reviewing operating data. Additionally, the inspectors verified that the licensee had entered any significant heat exchanger performance problems into their corrective action program and that the licensee's corrective actions were appropriate.

Documents reviewed are listed in the Attachment.

b. Findings No findings were identified.

1R11 Licensed Operator Requalification Program (71111.11) .1 Resident Inspector Quarterly Review of Licensed Operator Requalification

a. Inspection Scope The inspectors observed an evaluated simulator scenario administered to an operating crew conducted in accordance with the licensee's accredited requalification training

program. The inspectors assessed licensed operator performance, the ability of the

licensee to administer the scenario and evaluate the operators, the quality of any post-

scenario critique, any follow-up actions taken by the facility licensee, and the

performance of the simulator. Documents reviewed are listed in the Attachment. b. Findings No findings were identified. .2 Resident Inspector Quarterly Review (Licensed Operator Performance): The inspectors observed licensed operator performance in the main control room on

October 8, during the reactor startup following the 1R17 refueling outage. Documents

reviewed are listed in the Attachment. Inspectors observed licensed operator

performance to assess the following: * Use of plant procedures * Control board manipulations * Communications between crew members * Use and interpretation of instruments, indications, and alarms * Use of human error prevention techniques * Documentation of activities * Management and supervision b. Findings No findings were identified.

10 Enclosure .3 Annual Review of Licensee Requalification Examination Results (71111.11A) a. Inspection Scope

On November 29, 2012, the licensee completed administering the annual requalification

operating test and biennial written examination, which is required to be administered to

all licensed operators in accordance with 10 CFR 55.59(a)(2). The inspectors performed an in-office review of the overall pass/fail results of the individual operating tests and the crew simulator operating tests. These results were compared to the thresholds

established in Manual Chapter 609, Appendix I, Operator Requalification Human

Performance Significance Determination Process. b. Findings No findings were identified.

1R12 Maintenance Effectiveness (71111.12) a. Inspection Scope The inspectors assessed the licensee's treatment of the issues listed below in order to

verify the licensee appropriately addressed equipment problems within the scope of the Maintenance Rule (10 CFR 50.65). The inspectors reviewed procedures and records in order to evaluate the licensee's identification, assessment, and characterization of the problems as well as their corrective actions for returning the equipment to a satisfactory

condition. Documents reviewed are listed in the Attachment. The inspectors also

interviewed system engineers and the maintenance rule coordinator to assess the accuracy of performance deficiencies and extent of condition. * Unit 2, 2PV3000 main steam atmospheric relief valve (ARV) exceeded MR performance criteria for maintenance preventable functional failures (MPFFs) * Unit 1, 1HV8702A B train RHR pump hot leg suction valve failed to open when demanded from the control room.

b. Findings No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13) a. Inspection Scope The inspectors reviewed the maintenance activities listed below to verify the licensee

assessed and managed plant risk as required by 10 CFR 50.65(a)(4) and licensee procedures. The inspectors assessed the adequacy of the licensee's risk assessments and implementation of risk management actions. The inspectors also verified that the

licensee was identifying and resolving problems with assessing and managing

maintenance-related risk using the corrective action program. Additionally, for

maintenance resulting from unforeseen situations, the inspectors assessed the

11 Enclosure effectiveness of the licensee's planning and control of emergent work activities. Documents reviewed are listed in the Attachment. * Week of 10/22: Unit 1A EDG 18 month surveillance in conjunction with ongoing work in the high voltage switchyard * Week of 10/29: maintenance outage on the 2A EDG concurrent with maintenance activities on various breakers in the high-voltage switchyard. Week of 11/12: performing testing on the 2B EDG concurrent with maintenance activities in the high-voltage switchyard. Week of 12/3: rendering the Unit 1 B train NSCW cooling tower fans inoperable to perform inspections of the 480V EMAX breakers. Week of 12/17: rendering the Unit 1 A train NSCW cooling tower fans inoperable to perform inspections of the 480V EMAX breakers. b. Findings No findings were identified.

1R15 Operability Evaluations

a. Inspection Scope The inspectors reviewed the following five evaluations to verify they met the

requirements of procedure NMP-GM-002, Corrective Action Program, and NMP-GM-002-001, Corrective Action Program Instructions. The scope of these inspections

included a review of the technical adequacy of the evaluations, the adequacy of

compensatory measures, and the impact on continued plant operation. Inspectors reviewed licensee procedures and conducted walkdowns in accordance with OpESS FY 2012-02 "Technical Specification Interpretation and Operability Determination,"

inspection guidance to ensure that the licensee properly interprets Technical

Specification (TS) Bases, properly develops operability determinations, and adheres to

the NRC's guidance on the temporary use of manual actions to support operability determinations. Documents reviewed are listed in the Attachment. CR 501741, Unit 1A EDG unit available light is not working CR 533822, Unit 1 and 2 main steam isolation valves (MSIVs) CR 550736, Unit 2A NSCW fan #3 failed to close CR 479829, Unit 2B RHR oil sample analysis CR 562504, Gas void discovered at 1-1208-X4-05

b. Findings No findings were identified.

12 Enclosure 1R18 Plant Modifications a. Inspection Scope Temporary Modification: The inspectors reviewed minor design change package SNC439341/1.0 which allowed the temporary installation of clamping device on valve 1-1208-U4-A11, auxiliary pressurizer spray valve, to address body-to-bonnet leakage of the non-isolable valve. Inspectors also reviewed the associated 10 CFR Part 50.59 screening criteria against the system design bases documentation and procedure 00307-C, Temporary Modifications. The inspectors reviewed implementation,

configuration control, post-installation test activities, drawing and procedure updates,

and operator awareness for this temporary modification. b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope The inspectors either observed post-maintenance testing or reviewed the test results for

the following six maintenance activities to verify that the testing met the requirements of procedure 29401-C, Work Order Functional Tests, for ensuring equipment operability and functional capability was restored. The inspectors also reviewed the test

procedures to verify the acceptance criteria were sufficient to meet the Technical

Specification (TS) operability requirements. MWO SNC410412, Unit 1 Train B Safety Injection Accumulator Vent Header Isolation Valve 1HV-0943B MWO SNC439646, 1HV-3016B Disassemble MSIV and MWO SNC439647, 1HV-3026B Disassemble MSIV MWO SNC43990, 1HV-3006A Disconnect Actuator and Perform Ultra-Sonic Testing MWO SNC424222- 2A EDG Replace O-Rings in 2R, 2L, 7R, and 7L Fuel Injectors MWO SNC127251 - Clean, Inspect, and Lubricate Valve Stem MWO SNC447741 - 2A NSCW Fan #3 Not Operating

b. Findings Introduction: A Green self-revealing non-cited violation (NCV) of 10 CFR 50 Appendix B Criterion V, "Instructions, Procedures, and Drawings" was identified for failure to provide

adequate work instructions in the maintenance procedure used to modify 480V EMAX

safety-related switchgear breakers. Specifically, when modifying the breaker by adding a higher amperage closing coil, failure to verify the proper placement of the wire bundle

on top of the closing coil following replacement resulted in the safety-related 480V EMAX breaker failing to close when demanded. Investigation revealed that the wire bundle on top of the closing coil was positioned such that it prevented the close lever

from fully seating, thus preventing the breaker from closing.

13 Enclosure Description: At 0700 on November 19, 2012, the control room operators noted that the 2A NSCW cooling tower fan #3 did not start when the associated tower return valve opened. On Unit 2, NSCW cooling tower fan #3 is interlocked to automatically start

when the associated tower return valve opens and initiates flow to the tower spray lines.

At the direction of the shift supervisor, the operators attempted to start fan #3 manually

from the main control room, but the fan did not start. The green light for the hand switch

indicated that control power was available. The licensee declared the fan inoperable and an incident response team (IRT) was assembled. The 480V EMAX breaker was replaced and the monthly surveillance test was successfully completed. The fan was declared operable at 4:30 a.m. on November 20, 2012. The investigation of the failed

breaker revealed that the wire bundle on top of the closing coil was in physical contact

with the side of the close lever, preventing the close lever from fully seating, thus preventing the breaker from closing. When the wire bundle was properly anchored away from the close lever, the breaker operated normally. The IRT determined that the wire bundle on this breaker had been improperly repositioned following modification of the

breaker. The 480V EMAX breakers that supply specific safety-related loads at Vogtle

must be modified by installing a higher amperage closing coil because with the current plant design, the closing coils are continuously energized. Maintenance procedure 28480-C Rev.26, "480V EMAX Breaker Maintenance," did not provide any guidance on how to anchor the wire bundle following closing coil replacement so that the wire bundle

did not interfere with the operation of the close lever. The licensee entered this issue

into their corrective action program as condition reports (CR) 549999 and CR 550736.

Analysis: The failure of the breaker to close when demanded and start the safety-related NSCW cooling tower fan was a performance deficiency. The inspectors

concluded that the finding was more than minor because it impacted the reactor safety

mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences and affected the cornerstone attribute of equipment performance. Specifically, failure of the 480V EMAX breaker to close when demanded resulted in the

2A NSCW cooling tower fan #3 being inoperable for approximately 21.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.

Using IMC 0609, Attachment 4, "Initial Characterization of Findings" dated

June 19, 2012, the inspectors determined that finding affected the mitigating systems cornerstone. The inspectors evaluated the finding using IMC 0609, Appendix A, "The Significance Determination Process (SDP) for Findings At-Power," dated June 19, 2012.

The inspectors used the Initial Screening and Characterization of Findings (IMC 0609.04

Exhibit 2, dated June 19, 2012) to characterize the finding. Since the inspectors

answered "No" to all of the Exhibit 2, section A, questions 1-4, mitigating systems cornerstone screening questions, the inspectors concluded that the finding was of very low safety significance (Green).

The inspectors determined the primary cause of the performance deficiency was that the maintenance technicians who were modifying the 480V EMAX breakers were unaware that the improper placement of the closing coil wire bundle could interfere with the operation of the close lever. The inspectors determined that the cause of this finding was related to the corrective action program component of the problem identification and

resolution cross-cutting area due to less-than-adequate problem evaluation P.1(c).]

14 Enclosure Specifically, the licensees' extent of cause evaluations performed on previous 480V EMAX breaker failures (caused by restricted movement of the close lever) did not identify the potential of the closing coil wire bundle to interfere with the proper movement

of the close lever.

Enforcement: The inspectors determined that the finding represents a violation of regulatory requirements because it involved inadequate maintenance procedures used to modify safety-related plant equipment. 10 CFR Part 50 Appendix B Criterion V, "Instructions, Procedures, and Drawings," requires, in part, that procedures shall include

appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. Contrary to the above, maintenance procedure 28480-C Rev.26, "480V EMAX Breaker Maintenance," did not provide guidance on how to anchor the wire bundle following closing coil replacement so that the wire bundle did not interfere with the operation of the close lever. As a result of the

violation, the 2A NSCW cooling tower fan #3 was rendered inoperable for a period of

approximately 21.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> on November 19 and 20. Because this violation was of very low safety significance and was entered into the licensee's corrective action program as CR 549999 and CR 550736, this violation is being treated as a NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. (NCV 05000425/2012005-01, Inadequate

Maintenance Procedure Results in Inoperability of NSCW Cooling Tower Fan.)

1R20 Refueling and Other Outage Activities a. Inspection Scope

The inspectors performed the activities described below for the 1R17 refueling outage

that ended on October 18, 2012. The inspectors confirmed that, when the licensee

removed equipment from service, the licensee maintained defense-in-depth commensurate with the outage risk control plan for key safety functions and applicable TS and that configuration changes due to emergent work and unexpected conditions

were controlled in accordance with the outage risk control plan. Inspection activities

included:

Observed refueling activities for compliance with TS, to verify proper tracking of fuel assemblies from the spent fuel pool to the core, and to verify foreign material exclusion was maintained Performed containment closure activities, including a detailed containment walkdown prior to startup, to verify no evidence of leakage and that debris had not been left

which could affect the performance of the containment sump Observed heat up and startup activities to verify that TS, license conditions, and other requirements, commitments, and administrative procedure prerequisites for mode changes were met prior to changing modes or plant conditions. Reactor

coolant system (RCS) integrity was verified by reviewing RCS leakage calculations and containment integrity was verified by reviewing the status of containment

penetrations and containment isolation valves

15 Enclosure b. Findings No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope The inspectors reviewed the following eight surveillance test procedures and either

observed the testing or reviewed test results to verify that testing was conducted in

accordance with the procedures and that the acceptance criteria adequately

demonstrated that the equipment was operable. Additionally, the inspectors reviewed the CR database to verify that the licensee had adequately identified and implemented appropriate corrective actions for surveillance test problems. Surveillance Tests 14666-1 Rev. 34.1, Train A Diesel Generator and ESFAS Test 14670A-1 Rev. 1.2, Diesel Generator 1A Hot Restart Test 14802A-1 Rev. 4.1, Train A NSCW Pump/Check Valve IST and Response Time Test 14804A-1 Rev. 4, Safety Injection Pump A Inservice and Response Time Test

Containment Isolation Valve 14372B-1 Rev. 9, Containment Penetration No. 72B RCS loop 3 Accumulator Sample Line Local Leak Rate Test

In-Service Tests (IST) 14808A-2 Rev. 2.2, Train A Centrifugal Charging Pump and Check Valve IST and Response Time Test RCS Leak Detection 14905-1 Rev. 67.2, RCS Leakage Calculation (Inventory Balance) 14905-2 Rev. 50.1, RCS Leakage Calculation (Inventory Balance)

b. Findings No findings were identified.

Cornerstone: Emergency Preparedness

1EP4 Emergency Action Level and Emergency Plan Changes

a. Inspection Scope The NSIR headquarters staff performed an in-office review of the latest revisions of various Emergency Plan Implementing Procedures (EPIPs) and the Emergency Plan located under ADAMS accession numbers ML12188A352, ML122430598, ML12081A211, ML12093A204, and ML12115A174.

16 Enclosure The licensee determined that in accordance with 10 CFR 50.54(q), the changes made in the revisions resulted in no reduction in the effectiveness of the Plan, and that the revised Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to

10 CFR Part 50. The NRC review was not documented in a safety evaluation report and

did not constitute approval of licensee-generated changes; therefore, these revisions are

subject to future inspection. This inspection activity satisfied one inspection sample for

the emergency action level and emergency plan changes on an annual basis. Documents reviewed are listed in the Attachment.

b. Findings No findings were identified. 2. RADIATION SAFETY [RS]

2RS1 Radiological Hazard Assessment and Exposure Controls a. Inspection Scope

Hazard Assessment and Instructions to Workers: During facility tours, the inspectors directly observed labeling of radioactive material and postings for radiation areas, high

radiation areas (HRA)s, Very High Radiation Areas (VHRA)s and airborne radioactivity

areas established within the radiologically controlled area (RCA) of the auxiliary building, Unit 1 (U1) reactor containment building, and radioactive waste (radwaste) processing and storage locations. The inspectors independently measured radiation dose rates or

directly observed conduct of licensee radiation surveys for selected RCA areas. The

inspectors reviewed survey records for several plant areas including surveys for alpha emitters, discrete radioactive particles, airborne radioactivity, gamma surveys with a range of dose rate gradients, and pre-job surveys for upcoming tasks. The inspectors also discussed changes to plant operations that could contribute to changing radiological

conditions since the last inspection. For selected outage jobs, the inspectors attended

pre-job briefings and reviewed radiation work permit (RWP) details to assess

communication of radiological control requirements and current radiological conditions to

workers. Hazard Control and Work Practices: The inspectors evaluated access barrier effectiveness for selected Locked High Radiation Area (LHRA) locations and discussed

changes to procedural guidance for LHRA and VHRA controls with health physics (HP)

supervisors. The inspectors reviewed implementation of controls for the storage of irradiated material within the spent fuel pool (SFP). Established radiological controls (including airborne controls) were evaluated for selected Unit 1 Refueling Outage 17

(1R-17) tasks including maintenance activities in the transfer canal, removal of

pressurizer code safety valves, and steam generator (S/G) eddy current testing. In addition, the inspectors reviewed licensee controls for areas where dose rates could

change significantly as a result of plant shutdown and refueling operations.

17 Enclosure Through direct observations and interviews with licensee staff, inspectors evaluated occupational workers' adherence to selected RWPs and HP technician (HPT) proficiency in providing job coverage. Electronic dosimeter (ED) alarm set points and worker stay

times were evaluated against area radiation survey results for selected 1R17 job tasks.

As part of Inspection Procedure (IP) 71124.04, inspectors reviewed the use of personnel

dosimetry (ED alarms, extremity dosimetry, multibadging in high dose rate gradients, etc.). The inspectors also evaluated worker responses to dose and dose rate alarms during selected work activities.

Control of Radioactive Material: The inspectors observed surveys of material and personnel being released from the RCA using small article monitor (SAM), personnel contamination monitor (PCM), and portal monitor (PM) instruments. The inspectors reviewed the last two calibration records for selected release point survey instruments and discussed equipment sensitivity, alarm setpoints, and release program guidance

with licensee staff. The inspectors compared recent 10 Code of Federal Regulations

(CFR) Part 61 results for the Dry Active Waste (DAW) radioactive waste stream with

radio nuclides used in calibration sources to evaluate the appropriateness and accuracy of release survey instrumentation. The inspectors also reviewed records of leak tests on selected sealed sources and discussed nationally tracked source transactions with

licensee staff.

Problem Identification and Resolution: The inspectors reviewed and assessed Condition Reports (CR)s associated with radiological hazard assessment and control. The inspectors evaluated the licensee's ability to identify and resolve the issues in accordance with procedure NMP-GM-002, "Corrective Action Program", Ver. 12.1. The inspectors also reviewed recent self-assessment results.

Radiation protection activities were evaluated against the requirements of Final Safety Analysis Report (FSAR) Section 12; Technical Specifications (TS) Sections 5.4 and 5.7; 10 CFR Parts 19 and 20; and approved licensee procedures. Licensee programs for

monitoring materials and personnel released from the RCA were evaluated against 10

CFR Part 20 and IE Circular 81-07, "Control of Radioactively Contaminated Material".

Documents reviewed are listed in Sections 2RS1, 2RS2, 2RS3, and 2RS5 of the

Attachment. b. Findings Introduction: The inspectors identified a Green, self-revealing, Non-cited Violation (NCV) of TS 5.7.1, "High Radiation Area", for an unauthorized entry into a HRA. Description: On September 26, 2012, a maintenance worker entered U1 containment to locate and walk down two Nuclear Service Cooling Water check valves in preparation for inspection. Prior to the entry, the worker received a pre-job briefing from HP to allow

access into containment. Neither the worker nor the HPT performing the briefing were

confident of the valve locations, however they determined that Quadrant 1 of the 184' elevation was the most likely area to find the valves. Since the assigned RWP (as well as TS 5.7.1) did not allow entry into any HRAs without first obtaining a briefing on the

radiological conditions, the worker was briefed on conditions in HRAs on the 184'

18 Enclosure elevation. The worker was not briefed on conditions in HRAs in other parts of containment. During the entry, the worker was unable to locate one of the check valves on the 184' elevation and proceeded to exit out a stairwell to the 197' elevation. On the

197' elevation, the worker observed the other check valve inside a posted HRA. Without knowledge of dose rates in the area, the worker proceeded past the HRA swing gate to

verify the valve tag number and subsequently received an ED dose rate alarm of 173

mrem/hr. The worker acknowledged the ED alarm and backed out of the HRA. In addition, HP central control noted the ED alarm via telemetry and sent an HPT to intercept the worker. The worker's ED alarm setpoint was 150 mrem/hr and dose rates

in the area were as high as 445 mrem/hr on contact and 117 mrem/hr at 30 cm. The

licensee entered this issue into the Corrective Action Program (CAP) as CR 523976 and

took immediate corrective actions including an outage work crew stand down. Analysis: The inspectors determined that the unauthorized entry into a HRA was a performance deficiency. This finding is greater than minor because it is associated with

the Occupational Radiation Safety Cornerstone attribute of Human Performance and adversely affects the cornerstone objective of ensuring adequate protection of worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. Workers who enter HRAs without prior knowledge of current radiological conditions could receive unintended occupational exposures. The finding was evaluated using the Occupational Radiation Safety Significance

Determination Process (SDP). The finding was not related to As Low As Reasonably

Achievable (ALARA) planning, nor did it involve an overexposure or substantial potential for overexposure, and the ability to assess dose was not compromised. Therefore, the inspectors determined the finding to be of very low safety significance (Green). The

inspectors noted that the maintenance worker responded properly to the ED dose rate

alarm and was monitored by HP central control via telemetry, thereby limiting his potential for unintended exposure. This finding involved the cross-cutting aspect of Human Performance, Work Practices H.4.b] because the HRA event was a direct result of poor communications during the pre-job briefing and a lack of procedure (RWP)

adherence on the part of the maintenance worker. Enforcement: TS 5.7.1, "High Radiation Area", requires individuals entering HRAs to meet one or more of the following criteria: 1) be provided with a survey meter; 2) wear an ED and be made aware of radiological conditions in the area; or 3) be escorted by a HPT. Contrary to the above, on September 26, 2012, a worker entered a HRA without a

survey meter, without being made aware of radiological conditions in the area, and

without HPT escort. Because this violation was of very low safety significance and it

was entered into the licensee's corrective action program (CR 523976), this violation is being treated as an NCV, consistent with the Enforcement Policy: NCV 05000424/425, 2012005-02, Unauthorized Entry into a High Radiation Area.

19 Enclosure 2RS2 Occupational ALARA Planning and Controls a. Inspection Scope Work Planning and Exposure Tracking: The inspectors reviewed planned work activities and their collective exposure estimates for the current 1R17 outage. The inspectors reviewed ALARA planning packages for the following high collective exposure tasks:

S/G 1-4 job evolutions (nozzle dam removal and installation, eddy current testing, and

sludge lance) and repair of unit 1 transfer canal transfer tube isolation valve work. For

the selected tasks, the inspectors reviewed established dose goals and discussed assumptions regarding the bases for the current estimates with responsible ALARA planners. The inspectors evaluated the incorporation of exposure reduction initiatives and operating experience, including historical post-job reviews, into RWP requirements.

Day-to-day collective dose data for the selected tasks were compared with established

dose estimates and evaluated against procedural criteria (work-in-progress review limits) for additional ALARA review. Where applicable, the inspectors discussed changes to established estimates with ALARA planners and evaluated them against work scope

changes or unanticipated elevated dose rates.

Source Term Reduction and Control: The inspectors reviewed the collective exposure three-year rolling average from 2009 - 2011 and reviewed historical collective exposure trends from 1988 - 2012. The inspectors evaluated historical dose rate trends for reactor coolant system piping and compared them to current 1R17 data. Crud burst

evolution during the first week of the 1R17 outage and source term reduction initiatives

were reviewed and discussed with Chemistry and HP staff.

Radiation Worker Performance: The inspectors observed radiation worker performance for S/G job evolutions such as the diaphragm and manway removal and nozzle dam

removal and installation. The inspectors observed ALARA briefings for multiple steam

generator jobs and emerging jobs such as U1 transfer canal valve work. Radiation

worker performance was also evaluated as part of IP 71124.01. While observing job

tasks, the inspectors evaluated the use of remote technologies to reduce dose including teledosimetry and remote visual monitoring.

Problem Identification and Resolution: The inspectors reviewed and discussed selected CAP documents associated with ALARA program implementation. The inspectors

evaluated the licensee's ability to identify and resolve the issues in accordance with licensee procedure NMP-GM-002, "Corrective Action Program", Ver. 12.1. The inspectors also evaluated the scope and frequency of the licensee's self-assessment

program and reviewed recent assessment results.

ALARA program activities were evaluated against the requirements of FSAR Section 12,

TS Section 5.4, 10 CFR Part 20, and approved licensee procedures. Records reviewed are listed in the Attachment.

20 Enclosure b. Findings No findings were identified.

2RS3 In-Plant Airborne Radioactivity Control and Mitigation a. Inspection Scope Engineering Controls: The inspectors reviewed the use of temporary and permanent engineering controls to mitigate airborne radioactivity during the 1R17 refueling outage. The inspectors observed the use of portable air filtration units for work in contaminated areas of the containment building and reviewed filtration unit testing certificates. The

inspectors evaluated the effectiveness of continuous air monitors and air samplers placed in work area "breathing zones" to provide indication of increasing airborne levels. Respiratory Protection Equipment: The inspectors reviewed the use of respiratory protection devices to limit the intake of radioactive material. This included review of

devices used for routine tasks and devices stored for use in emergency situations. As part

of IP 71124.02, the inspectors reviewed ALARA evaluations for the use of respiratory protection devices during work in the lower cavity near the transfer canal. Selected Self-

Contained Breathing Apparatus (SCBA) units and negative pressure respirators (NPR)s staged for routine and emergency use in the Main Control Room and other locations were inspected for material condition, SCBA bottle air pressure, number of units, and number of

spare masks and air bottles available. The inspectors reviewed maintenance records for

selected SCBA units for the past two years and evaluated SCBA and NPR compliance with

National Institute for Occupational Safety and Health certification requirements. The inspectors also reviewed records of air quality testing for supplied-air devices and SCBA bottles.

The inspectors observed the use of air-supplied suits during S/G maintenance work. The

inspectors discussed training for various types of respiratory protection devices with HP

staff and interviewed radworkers and control room operators on use of the devices including SCBA bottle change-out and use of corrective lens inserts. The inspectors reviewed respirator qualification records (including medical qualifications) for several Main

Control Room operators and emergency responder personnel in the Maintenance and HP

departments. In addition, inspectors evaluated qualifications for individuals responsible for

testing and repairing SCBA vital components. Problem Identification and Resolution: The inspectors reviewed and assessed CRs associated with airborne radioactivity mitigation and respiratory protection. The

inspectors evaluated the licensee's ability to identify and resolve the issues in

accordance with procedure NMP-GM-002, "Corrective Action Program", Ver. 12.1. The inspectors also reviewed recent self-assessment results. Licensee activities associated with the use of engineering controls and respiratory

protection equipment were reviewed against TS Section 5.4; 10 CFR Part 20; Regulatory

Guide 8.15, "Acceptable Programs for Respiratory Protection"; and applicable licensee

procedures. Documents reviewed are listed in the Attachment.

21 Enclosure b. Findings No findings were identified.

2RS4 Occupational Dose Assessment

a. Inspection Scope External Dosimetry: The inspectors reviewed the licensee's National Voluntary Accreditation Program (NVLAP) certification data for accreditation for the current year for

Ionizing Radiation Dosimetry. The inspectors reviewed program procedures for

processing active personnel dosimeters (ED)s and onsite storage of Optically Stimulated Luminescent Dosimeters (OSLD)s. Comparisons between ED and OSLD results, including correction factors, were discussed in detail. The inspectors also reviewed

dosimetry occurrence reports regarding alarming dosimeters.

Internal Dosimetry: Inspectors reviewed and discussed the in vivo bioassay program with the licensee. Inspectors reviewed procedures that addressed methods for determining internal or external contamination, releasing contaminated individuals, the

assignment of dose, and the frequency of measurements depending on the nuclides. Inspectors reviewed and evaluated Whole Body Counter (WBC) records selected from March 2010 to September 2012. The inspectors evaluated the licensee's program for in

vitro monitoring, however there were no dose assessments using this method to review. There were no internal dose assessments for internal exposure greater than 10 millirem committed effective dose equivalent to review.

Special Dosimetric Situations: The inspectors reviewed records for declared pregnant workers (DPW)s from March 2010 through September 2012 and discussed guidance for monitoring and instructing DPWs. Inspectors reviewed and witnessed the licensee's practices for monitoring external dose in areas of expected dose rate gradients,

including the use of multi-badging and extremity dosimetry. The inspectors evaluated the licensee's neutron dosimetry program including instrumentation which was evaluated

under procedure 71124.05. In addition, the inspectors evaluated the adequacy of

shallow dose assessments for selected Personnel Contamination Events occurring between September 2011 and September 2012.

Problem Identification and Resolution: The inspectors reviewed and discussed licensee CAP documents associated with occupational dose assessment. Inspectors evaluated

the licensee's ability to identify and resolve the identified issues in accordance with procedure NPM-GM-002, "Corrective Action Program", Version 12.1. The inspectors also discussed the scope of the licensee's internal audit program and reviewed recent

assessment results.

HP program occupational dose assessment activities were evaluated against the

requirements of FSAR Section 12; TS Section 5.4; 10 CFR Parts 19 and 20; and approved licensee procedures. Records reviewed are listed in the Attachment.

22 Enclosure b. Findings No findings were identified.

2RS5 Radiation Monitoring Instrumentation

a. Inspection Scope Radiation Monitoring Instrumentation: During walk-downs of the auxiliary building and the RCA exit point, the inspectors observed installed and portable radiation detection

equipment. These included area radiation monitors (ARM)s, continuous air samplers, liquid and gaseous effluent monitors, PCMs, SAMs, PMs, a WBC, count room equipment, and portable survey instruments. The inspectors observed the physical location of the components, noted their material condition, observed the currency of

calibration and source check stickers, and discussed performance of equipment with RP

personnel. In addition to equipment walk-downs, the inspectors observed source functional checks of portable detection instruments, including ion chambers and telepoles. For the portable instruments, the inspectors observed the use of a high-range calibrator and

discussed periodic output value testing, calibration, and source check processes with

health physics technicians. The inspectors reviewed calibration records and discussed

with chemistry personnel alarm setpoint values for PCMs, PMs, effluent monitors, WBCs, and an ARM. This included a sampling of instruments used for post-accident monitoring such as a containment high-range radiation monitor and effluent monitors for noble gas and iodine. The inspectors reviewed the most recent 10 CFR Part 61 analysis

for DAW to determine if calibration and check sources are representative of the plant

source term. The inspectors observed computerized performance check calibration efficiency information for count room gamma detectors and a liquid scintillation detector. The inspectors also observed the currency of calibration for selected EDs at the RCA

entry point. Problem Identification and Resolution: The inspectors reviewed selected CAP reports in the area of radiological instrumentation. The inspectors evaluated the licensee's ability to identify and resolve the issues in accordance with procedure NMP-GM-002-001, "Corrective Action Program Instructions", Ver. 29.0. Documents reviewed are listed in the Attachment.

Effectiveness and reliability of selected radiation detection instruments were reviewed against details documented in the following: 10 CFR Part 20; NUREG-0737, Clarification of TMI Action Plan Requirements; FSAR Chapters 11 and 12; and

applicable licensee procedures. Documents reviewed are listed in the Attachment.

b. Findings No findings were identified.

23 Enclosure 4. OTHER ACTIVITIES 4OA1 Performance Indicator (PI) Verification

a. Inspection Scope The inspectors sampled licensee submittals for the listed mitigating systems cornerstone PIs during the period from October 1, 2011, through September 30, 2012, for Unit 1 and Unit 2. The inspectors verified the licensee's basis in reporting each data element using

the PI definitions and guidance contained in procedures 00163-C, NRC Performance Indicator and Monthly Operating Report Preparation and Submittal, and Nuclear Energy Institute 99-02, Regulatory Assessment Indicator Guideline. Mitigating Systems Cornerstone Emergency AC Power Systems Cooling Water Systems Safety System Functional Failures The inspectors reviewed Unit 1 and Unit 2 operator log entries, the CR data base, the

Vogtle mitigating system performance indicator basis document, the monthly operating reports and monthly PI summary reports to verify that the licensee had accurately submitted the PI data. Occupational Radiation Safety Cornerstone: The inspectors reviewed the Occupational Exposure Control Effectiveness PI results for the Occupational Radiation Safety Cornerstone from June 2011 through September 2012. For the assessment period, the

inspectors reviewed electronic dosimeter alarm logs and CRs related to controls for

exposure significant areas. Documents reviewed are listed in the Attachment. Public Radiation Safety Cornerstone: The inspectors reviewed the Radiological Control Effluent Release Occurrences PI results for the Public Radiation Safety Cornerstone

from June 2011 through September 2012. For the assessment period, the inspectors

reviewed cumulative and projected doses to the public contained in liquid and gaseous

release permits and CRs related to Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual issues. The inspectors also reviewed licensee procedural guidance for collecting and documenting PI data. Documents reviewed are listed in the

Attachment.

The inspectors completed five of the required samples specified in IP 71151. b. Findings No findings were identified.

24 Enclosure 4OA2 Identification and Resolution of Problems .1 Daily Condition Report Review. As required by inspection procedure 71152, Identification and Resolution of Problems, and in order to help identify repetitive

equipment failures or specific human performance issues for follow-up, the inspectors

performed a daily screening of items entered into the licensee's corrective action program. This review was accomplished by either attending daily screening meetings that briefly discussed major CRs, or accessing the licensee's computerized corrective action database and reviewing each CR that was initiated.

.2 Focused Review a. Inspection Scope The inspectors performed a detailed review of the following CR which addressed the

failure of the Unit 1 Loop 2 & 3 outboard MSIVs in the closed position during startup.

The goal of the review was to verify that the full extent of the issue was identified, an appropriate evaluation was performed, and appropriate corrective actions were specified and prioritized. The inspectors evaluated the CR against the licensees corrective action

program as delineated in licensee procedure NMP-GM-002, Corrective Action Program, and 10 CFR 50, Appendix B, Criterion XVI, Corrective Action. Documents reviewed are

listed in the Attachment.

• 530916 - Unit 1 steam generators 2&3 do not indicate steam flow b. Findings and Observations Introduction: A Green self-revealing non-cited violation (NCV) of 10 CFR 50 Appendix B Criterion V, "Instructions, Procedures, and Drawings" was identified for failure to provide

adequate work instructions in the operations and maintenance procedures used to open main steam isolation valves (MSIVs) that were bound in their closed seat. Specifically, the operations and maintenance procedures used to open the loop 2 and loop 3

outboard MSIVs did not provide instructions to limit the magnitude of the force applied to

the valve stems while attempting to open the valves. Investigation revealed that the cause of the stem failures was excessive force applied to the thermally embrittled stems. Description: On October 8, with Unit 1 in Mode 2, the operators had begun preparations for power ascension. At 1616, as the main feed pump was being placed on line, the

control room operators noted a divergence in RCS loop differential temperatures (Ts), steam pressures, and steam flows between loops 1 & 4 and loops 2 & 3. Loops 1 & 4

showed increasing loop Ts, lowering steam pressure, and some minimal steam flow, while loops 2 & 3 showed no loop T, increasing steam pressures (to the point of lifting the loop 2 & 3 atmospheric relief valves), and no steam flow. The Main Control Board hand switches indicated that all MSIVs and associated bypass valves were open. The

operators identified the potential impact to the core neutron flux and stopped power

ascension. Following discussions with plant management and engineering, the operators placed the plant in a safe condition by inserting a manual trip of the reactor at

25 Enclosure 2155. The licensee subsequently assembled an Issue Response Team (IRT) and a root cause team to investigate the cause of the diverging indications and to determine the required corrective actions.

The investigations revealed that the outboard MSIVs on both loops 2 & 3 were failed in

the closed position. Upon disassembly, it was discovered the stems of both the failed

MSIVs had undergone brittle fracture just above the T-head, where the valve stem is connected to the valve disk. Westinghouse representatives were consulted on the MSIV issue. They conveyed to the licensee that the material used for the MSIV stems, ASME SA564 Gr. 630PH T 17-4 PH heat treated to 1100oF, is susceptible to embrittlement when exposed to temperatures above 500oF for a sustained period (after about 10 years). Metallurgical analysis performed on the sheared stems validated that thermal embrittlement was the failure mechanism. The failure analysis concluded that both stem fractures were the result of sudden brittle failures from single tensile stress events.

Further investigation by the IRT revealed that the loop 2 outboard MSIV stem failed

during main steam line warming evolutions conducted on October 6 by operations personnel. The IRT also determined that that the loop 3 outboard MSIV stem failed on the night of October 7 following activities performed by maintenance personnel to lift the valve disk off its closed seat.

The root cause team determined that the root cause of the MSIV stem failures was temperature aging embrittlement of the stem material. The team also determined that the major contributing causes of the event were thermal binding of the valve disks in the closed seat and inadequate procedural guidance, i.e. procedures used to open the MSIVs did not provide instructions or guidance to limit the magnitude of the force applied

to the valve stems while attempting to open the valves, which ultimately resulted in the brittle failure of the valve stems. The inadequate procedures specified by the root cause team were operating procedures 12001-C, "Unit Heat Up to Hot Shutdown (Mode 5 to Mode 4)", and 14850-1/2, "Cold Shutdown Valve In-Service Test", and maintenance procedure 26854-C, "MSIV Actuator Maintenance". The licensee conducted ultrasonic

testing on the remaining six Unit 1 MSIVs to verify that the valve stems were intact. The

two failed valve stems were replaced, and the reactor was restarted on October 17. The

licensee entered this issue into their corrective action program as CR 530916.

Analysis: The failure to provide adequate work instructions in the operations and maintenance procedures used to open main steam isolation valves (MSIVs) that were stuck on their closed seat was a performance deficiency. The inspectors concluded that

the finding was more than minor because it was associated with the procedure quality

attribute of the reactor safety - initiating events cornerstone and it adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations.

Specifically, the failure to provide adequate work instructions to operations and

maintenance personnel resulted in the failure of both the loop 2 and loop 3 outboard

MSIVs and the subsequent manual reactor trip.

Using IMC 0609, Attachment 4, "Initial Characterization of Findings" dated June 19, 2012, the inspectors determined that finding affected the Initiating Events cornerstone.

The inspectors evaluated the finding using IMC 0609, Appendix A, "The Significance

26 Enclosure Determination Process (SDP) for Findings At-Power," dated 06/19/12. The inspectors used the Initial Screening and Characterization of Findings (IMC 0609.04 Exhibit 1, dated June 19, 2012) to characterize the finding. Since the inspectors answered "No" to

the Exhibit 1, section B, Initiating Events screening question, the inspectors concluded

that the finding was of very low safety significance (Green).

The primary cause of the performance deficiency, as determined by the inspectors, was less than adequate work planning and coordination. The inspectors determined that the cause of this finding was related to the work control component of the human

performance cross-cutting area due to less-than-adequate work planning [H.3 (a)].

Specifically, the licensees' procedures used to open the MSIVs that were stuck on their

closed seat did not contain instructions or precautions to limit the magnitude of the force applied to the valve stems while attempting to open the valves. Enforcement: The inspectors determined that the finding represents a violation of regulatory requirements because it involved inadequate operations and maintenance procedures used to operate safety-related plant equipment. 10 CFR 50 Appendix B Criterion V requires, in part, that procedures shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been

satisfactorily accomplished. Contrary to the above, the licensees' procedures used to open the loop 2 and loop 3 outboard MSIVs did not provide instructions to limit the

magnitude of the force applied to the valve stems while attempting to open the valves. As a result of the violation, the loop 2 and loop 3 MSIVs failed in the closed position, and the reactor was manually tripped on October 8, extending the 1R17 refueling outage for an additional nine days. The licensee conducted ultrasonic testing on the remaining six

Unit 1 MSIVs to verify that the valve stems were intact. The stems of the loop 2 and loop 3 outboard MSIVs were replaced, and the Unit 1 reactor was restarted on October

17. Because this violation was of very low safety significance and it was entered into the licensee's corrective action program as CR 530916, this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. (NCV 05000424/2012005-03, Inadequate Operations and Maintenance Procedures Results in

Brittle Failure of the Loop 2 and Loop 3 Outboard MSIV Stems.)

.3 Semi-Annual Trend Review a. Inspection Scope The inspectors performed a review of the licensee's Corrective Action Program and associated documents to identify trends which could indicate the existence of a more significant safety issue. The review was focused on repetitive equipment issues, but also considered the results of inspector daily CR screening and the licensee's trending

efforts. The review nominally considered the six month period of April 2012 through

September 2012 although some examples extended beyond those dates when the scope of the trend warranted. The inspectors also reviewed several CRs associated

with operability determinations which occurred during the period. Corrective actions associated with a sample of the issues identified in the licensee's trend reports were reviewed for adequacy. The inspectors also evaluated the trend reports against the

27 Enclosure requirements of the licensee's corrective action program as specified in licensee procedure NMP-GM-002, Corrective Action Program, and 10 CFR 50, Appendix B.

b. Findings and Observations No findings were identified.

4OA3 Follow-up of Events and Notices of Enforcement Discretion (71153)

.1 (Closed) LER 05000424/2012-003-00 Failure to Comply with Technical Specification LCOs 3.7.14 and 3.0.3 a. Inspection Scope

On August 17, 2012, 1A ESF Chiller condenser vacuum was noted to be 12 inches of

mercury, with a vacuum of 15 inches of mercury specified as the low limit on operating

logs. The shift supervisor mistakenly believed condenser pressure was one of the parameters which engineering had evaluated and was continuing to monitor with a recorder. Condenser pressure was not one of the parameters being monitored and

recorded on a recorder. When the condenser pressure was recorded as out of

specification on the operator rounds log sheet, the shift supervisor failed to initiate

operability and reportability determination processes. This misinformation was carried

forward through subsequent shifts via logs. During the next five days, 1A ESF Chiller condenser vacuum decreased to 4 inches of mercury and stabilized for an additional four days prior to initiation of a CR on August 26, 2012. Subsequent investigation and

consultation with the vendor determined the 1A ESF Chiller was inoperable and the TS

LCO was entered at 1437 on August 26, 2012. As a result of the delay in recognition of

the status of the subject chiller, appropriate actions of LCOs 3.7.14 and 3.0.3 were not taken. The inspectors reviewed the LER, the associated CR and enhanced apparent cause determination, and subsequent action items.

b. Findings One licensee-identified violation was identified, and is documented in section 4OA7 of this report. This LER is closed. 4OA5 Other Activities

.1 Quarterly Resident Inspector Observations of Security Personnel and Activities a. Inspection Scope During the inspection period, the inspectors conducted observations of security force

personnel and activities to ensure that the activities were consistent with licensee

security procedures and regulatory requirements relating to nuclear plant security. These observations took place during both normal and off-normal plant working hours.

28 Enclosure These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors' normal plant status review and inspection activities.

b. Findings and Observations No findings were identified. .2 (Discussed) Temporary Instruction 2515/187 - Inspection of Near-Term Task Force Recommendation 2.3 Flooding Walkdowns

a. Inspection Scope Inspectors conducted independent walkdowns to verify that the licensee completed the

actions associated with the flood protection feature specified in paragraph 03.02.a.2 of

this TI. Inspectors are performing walkdowns at all sites in response to a letter from the

NRC to licensees, entitled "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident," dated

March 12, 2012 (ADAMS Accession No. ML12053A340).

Enclosure 4 of the letter requested licensees to perform external flooding walkdowns

using an NRC-endorsed walkdown methodology (ADAMS Accession No. ML12056A050). Nuclear Energy Industry (NEI) document 12-07 titled, "Guidelines for Performing Verification Walkdowns of Plant Protection Features," (ADAMS Accession

No. ML12173A215) provided the NRC-endorsed methodology for assessing external flood protection and mitigation capabilities to verify that plant features, credited in the

CLB for protection and mitigation from external flood events, and are available, functional, and properly maintained. b. Findings and Observations Findings or violations associated with the flooding, if any, will be documented in the 1st quarter integrated inspection report of 2013. .3 Temporary Instruction 2515/188 - Inspection of Near-Term Task Force Recommendation 2.3 Seismic Walkdowns

a. Inspection Scope The inspectors accompanied the licensee on their seismic walkdowns of the following

SWEL 1 and SWEL 2 components:

• Unit 1 Diesel Fuel Oil Transfer Pump A, SWEL 1 item #60, on August 15 in the Diesel Fuel Oil Storage Tank Building * Unit 1B Diesel Generator Control Panel, SWEL 1 item #61, on August 15 in the Diesel Generator Building

29 Enclosure * Unit 1 Turbine-Driven AFW Pump and Turbine Driver, SWEL 1 item #13, on August 16 in the AFW Pump House * Unit 2 Spent Fuel Pool Heat Exchanger B, SWEL 2 item #1, on August 21 in the Auxiliary Building The inspectors verified that the licensee confirmed that the following seismic features associated with the above listed components were free of potential adverse seismic

conditions:

• Anchorage was free of bent, broken, missing or loose hardware * Anchorage was free of corrosion that is more than mild surface corrosion * Anchorage is free of visible cracks in the concrete near the anchors * Anchorage configuration was consistent with plant documentation * SSCs will not be damaged from impact by nearby equipment or structures * Overhead equipment, distribution systems, ceiling tiles and lighting, and masonry block walls are secure and not likely to collapse onto the equipment * Attached lines have adequate flexibility to avoid damage * The area appears to be free of potentially adverse seismic interactions that could cause flooding or spray in the area * The area appears to be free of potentially adverse seismic interactions that could cause a fire in the area * The area appears to be free of potentially adverse seismic interactions associated with housekeeping practices, storage of portable equipment, and temporary installations (e.g., scaffolding, lead shielding) The inspectors independently performed their walkdowns and verified that the following

components were free of the potential adverse seismic conditions listed above:

• Unit 2A Diesel Generator Air Start Receiver #1, SWEL 1 item #55, on December 17 in the Diesel Generator Building * Unit 1 Spent Fuel Pool Pump B, SWEL item #2, on December 17 in the Auxiliary Building Observations made during the walkdowns that could not be determined to be acceptable were entered into the licensee's corrective action program for evaluation.

Additionally, inspectors verified that items that could allow the spent fuel pool to drain

down rapidly were added to the SWEL and these items were walked down by the

licensee. b. Findings and Observations No findings were identified.

30 Enclosure 4OA6 Meetings, Including Exit .1 Exit Meeting On January 11, the resident inspectors presented the inspection results to Mr. Tom

Tynan and other members of his staff, who acknowledged the findings. The inspectors

confirmed that proprietary information was not provided or examined during the inspection. 4OA7 Licensee-Identified Violations The following violations of very low significance (Green) or Severity Level IV were identified by the licensee and are violations of NRC requirements which meet the criteria of the NRC Enforcement Policy for being dispositioned as Non-cited Violations. .1 Failure to Comply with Technical Specification LCOs 3.7.14 and 3.0.3 TS 3.0.3 requires, in part, that when a limiting condition of operation (LCO) is not met and the associated actions are not met, an associated action is not provided, or if

directed by the associated actions, the unit shall be placed in a mode or other specified

condition in which the LCO is not applicable. TS 3.7.14 require that two engineered

safety feature (ESF) room cooler and safety-related chiller trains shall be operable.

Contrary to the above, on August 17, 2012, at approximately midnight, the unit 1 shift supervisor failed to enter the required action statement for TS LCO 3.7.14, Condition 'A' when the unit 1A ESF chiller condenser purge pressure was noted to be out of

specification high. Inoperability of the chiller was not recognized until August 26, 2012,

and the LCO entered at 1437. Further, during the extended period during which the 1A

ESF chiller was inoperable (albeit unrecognized as inoperable), opposite train supported components as well as redundant room coolers on the train B ESF Chiller and room cooler train were removed from service for unrelated activities which resulted in two

occasions during which TS 3.0.3 should have been applied. The licensee documented

this event in their corrective action program as CR 507143. Using IMC 0609, dated

June 19, 2012, Attachment 4, Table 2, the inspectors verified that the finding affected

the mitigation systems cornerstone. IMC 0609 Attachment 4 Table 3 directed the inspectors to use IMC 0609 Appendix A to characterize the finding. Because the finding represented an actual loss of function of one train of ECCS for greater than its TS

Allowed Outage Time, a detailed risk evaluation was required. A detailed risk evaluation

was performed by a regional senior reactor analyst in accordance with IMC 0609

Appendix A guidance using the NRC Vogtle SPAR model and the Saphire 8 risk analysis code. An Event/Condition Analysis module in Saphire was run with the unit 1A train ESF chiller failed with no recovery allowed for a 9 day exposure period. The dominant

sequence was a loss of offsite power with success of reactor trip and emergency power

with late failure of feedwater and failure to implement feed and bleed cooling due to

failure of the Unit 1B train chiller and loss of the safety related switchgear. The detailed

risk evaluation determined that the risk due to the performance deficiency was an increase in core damage frequency of <1E-6/year, a GREEN finding of very low safety significance. The risk was mitigated by the availability of alternate train components and

the short exposure period.

31 Enclosure .2 Failure to Conduct Required ASME Code Section XI Inspections On April 12, 2012, Vogtle staff identified that in-service inspections for the second 10-

year ISI period were missed for eight ASME Code Class 1 valves. Valves 1/2 1208U6035, 1/2 1208U6036, 1/2 1208U6037 and 1/2 1208U6038 are chemical and

volume control system normal and alternate charging check valves to the reactor coolant system. Leakage control devices (seal encapsulation devices) were installed on the Unit 1 valves in 1987 to address recurring body-to-bonnet leakage per an industry approved Westinghouse design change. The seal caps were subsequently installed on the unit 2

valves in 1989. Title 10 CFR 50.55a(g)(4) requires, in part, that licensees follow the

pressure test requirements of ASME Code Section XI. ASME Code,Section XI, IWA-

5240, requires visual examinations as part of system pressure tests. ASME Code Section XI, IWA-5242, 1998 Edition through 2000 addenda, requires VT-2 visual examinations for pressure retaining bolted connections in borated water systems.

Contrary to the above, from October, 1987, to the present, Vogtle did not perform a visual inspection of the valve body-to-bonnet studs. This finding was more than minor because it impacted the initiating events cornerstone and its attribute of equipment performance. Specifically, it affected the objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well

as power operations. Using Inspection manual chapter 0609, dated June 19, 2012,

Appendix A, "The Significance Determination Process (SDP) for Findings At-Power," this

finding was determined to be of very low safety significance because the licensee's

evaluation was able to demonstrate structural integrity. Specifically, stud stress was not sufficiently close to the yield stress to cause a loss of integrity. Therefore, the finding does not contribute to both the likelihood of a reactor trip and the likelihood that

mitigation equipment will not be available. The licensee has entered this issue into their

corrective action program as CRs 438268, 458567, 505111 and 547078. To address

the issue for the short term, the licensee plans to follow the 'needed' and 'good practice' recommendations detailed by the PWROG in letter OG-12-330 which was issued on August 16, 2012. The long term corrective actions will be to remove all of the existing

seal caps and install a bonnet with a canopy seal weld to remove the need for a seal cap

as a way to mitigate the effects of leakage and to allow visual examination of the bolted

connections. .3 Failure to Post High Radiation Area 10 CFR 20.1902(b) requires licensees to post each HRA with a conspicuous sign or

signs bearing the radiation symbol and the words "CAUTION, HIGH RADIATION AREA" or "DANGER, HIGH RADIATION AREA". Contrary to this, on September 18, 2012, the entryway into the Unit 1 spent fuel pool cooling system demineralizer valve gallery was discovered to be missing a conspicuous sign bearing the radiation symbol and the words

"CAUTION, HIGH RADIATION AREA" or "DANGER, HIGH RADIATION AREA."

Accessible areas inside the Valve Gallery room contained dose rates up to 327 mrem/hr

at 30 cm. A HP foreman discovered this violation while performing a walkdown of HRA

postings in the auxiliary building. The licensee took immediate corrective actions upon discovery including restoration of the HRA posting (CR 519818). There was no evidence of unauthorized worker entry into the affected area. Although this event

involved the failure to maintain proper control for a HRA, this finding is of very low safety

32 Enclosure significance because it was not related to ALARA planning, nor did it involve an overexposure or substantial potential for overexposure, and the ability to assess dose was not compromised.

ATTACHMENT: SUPPLEMENTAL INFORMATION

Attachment SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT Licensee personnel: S. Bargeron, Plant Manager

B. Brown, Training Manager

R. Collins, Chemistry Manager

K. Dyar, Security Manager G. Gunn, Licensing I. Kochery, Health Physics Manager

D. McCary, Maintenance Manager

K. Molina, Heat Exchanger Engineer

D. Puckett, Performance Analysis Supervisor J. Robinson, Engineering Programs Manager S. Swanson, Site Support Manager

T. Tynan, Site Vice-President

NRC personnel: M. Cain, Senior Resident Inspector T. Chandler, Resident Inspector

F. Ehrhardt, Chief, Region II Reactor Projects Branch 2

T. Lighty, Project Engineer

LIST OF ITEMS OPENED AND CLOSED Opened and Closed

050000425/2012005-01 NCV Inadequate Maintenance Procedure Results in Inoperability of NSCW Cooling Tower Fan (Section 1R19) 05000424, 425/2012005-02 NCV Unauthorized Entry into a High Radiation Area. (Section 2RS1)05000424/2012005-03 NCV Inadequate Operations and Maintenance Procedures Results in Brittle Failure of the Loop

2 and Loop 3 Outboard MSIV Stems (Section 4OA2) Closed

05000424/2012-003-00 LER Failure to Comply with Technical Specification LCOs 3.7.14 and 3.0.3 05000424/425/2515/188 TI Inspection of Near-Term Task Force Recommendation 2.3 Seismic Walkdowns

(Section 4OA5.3)

2 Attachment Discussed LIST OF DOCUMENTS REVIEWED

Section 1R01: Adverse Weather Protection Procedures 11877-1 Rev. 23, Cold Weather Checklist 11877-2 Rev. 21, Cold Weather Checklist 11901-1 Rev. 17.2, Heat Tracing System Alignment

11901-2 Rev. 12.3, Heat Tracing System Alignment

Section 1R04: Equipment Alignment Procedures 11903-C Rev. 30.4, Fire Protection System Alignment, Section A

11011-1 Rev. 14.2, Residual Heat Removal System Alignment

13011-1 Rev. 70.3, Residual Heat Removal System

11115-1 Rev. 10.2, Containment Spray System Alignment

Drawings CX4DB173-1 Rev. 41.0, P&I Diagram Fire Protection - Pump House No. 1 & 2, System 2301 CX4DB173-2 Rev. 29.0, P&I Diagram Fire Protection - Yard Piping System, System 2301 1X4DB122 Rev. 51.0, P&I Diagram Residual Heat Removal System 1205

1X4DB131 Rev. 35.0, P&I Diagram Containment Spray System - System No. 1206 Section 1R05: Fire Protection Procedures 92799-1 Rev. 3.2, Zone 99 - Control Building Level A Fire Fighting Preplan

92804-1 Rev. 4.2, Zone 104 - MSIV Room Level 1 Fire Fighting Preplan

92745-1 Rev. 2.2, Zone 45 - Auxiliary Building Level 1 Fire Fighting Preplan 92760-2 Rev. 1.0, Zone 60 - Control Building - Level B Fire Fighting Preplan 92761-2 Rev. 1.1, Zone 61 - Control Building - Level B Fire Fighting Preplan

92764-2 Rev. 1.1, Zone 64 - Control Building - Level B Fire Fighting Preplan

92762-2 Rev. 2.0, Zone 62 - Control Building - Level B Fire Fighting Preplan

92763-2 Rev. 0.2, Zone 63 - Control Building - Level B Fire Fighting Preplan 92782-2 Rev. 1.2, Zone 82 - Control Building - Level B Fire Fighting Preplan 92860A-1 Rev. .2, Zone 160A - NSCW Pumphouse - Train A Fire Fighting Preplan

92860B-1 Rev. .2, Zone 160B - NSCW Pumphouse - Train B Fire Fighting Preplan

92771-1, Rev. 4.1, Zone 71 - Control Building - Level B Fire Fighting Preplan

92776-1, Rev. 2.1, Zone 76 - Control Building - Level B Fire Fighting Preplan

92777A-1, Rev. 1.1, Zone 77A - Control Building - Level B Fire Fighting Preplan 92777B-1, Rev. 1.2, Zone 77B - Control Building - Level B Fire Fighting Preplan 92778A-1, Rev. 2.1, Zone 78A - Control Building - Level B Fire Fighting Preplan

92778B-1, Rev. 1.2, Zone 78B - Control Building - Level B Fire Fighting Preplan 05000424/425/2515/187 TI Inspection of Near-Term Task Force Recommendation 2.3 Flooding Walkdowns

(Section 4OA5.2)

3 Attachment 92779A-1, Rev. 0.2, Zone 79A - Control Building - Level B Fire Fighting Preplan 92779B-1, Rev. 1.2, Zone 79B - Control Building - Level B Fire Fighting Preplan 92756A-1, Rev. 0.2, Zone 56A - Control Building - Level B Fire Fighting Preplan

92756B-1, Rev. 1.2, Zone 56B - Control Building - Level B Fire Fighting Preplan

92783-1, Rev. 2.2, Zone 83 - Control Building - Level B Fire Fighting Preplan

92852-1, Rev. 2.2, Zone 152 - Control Building - Level B Fire Fighting Preplan

92771-2, Rev. 1.1, Zone 71 - Control Building - Level B Fire Fighting Preplan 92776-2, Rev. 1.1, Zone 76 - Control Building - Level B Fire Fighting Preplan 92777A-2, Rev. 1.1, Zone 77A - Control Building - Level B Fire Fighting Preplan

92777B-2, Rev. 1.2, Zone 77B - Control Building - Level B Fire Fighting Preplan

92778A-2, Rev. 0.2, Zone 78A - Control Building - Level B Fire Fighting Preplan

92778B-2, Rev. 1.2, Zone 78B - Control Building - Level B Fire Fighting Preplan 92779A-2, Rev. 0.2, Zone 79A - Control Building - Level B Fire Fighting Preplan 92779B-2, Rev. 1.2, Zone 79B - Control Building - Level B Fire Fighting Preplan

92756A-2, Rev. 1.1, Zone 56A - Control Building - Level B Fire Fighting Preplan

92756B-2, Rev. 0.2, Zone 56B - Control Building - Level B Fire Fighting Preplan

92783-2, Rev. 0.2, Zone 83 - Control Building - Level B Fire Fighting Preplan 92852-2, Rev. 0.2, Zone 152 - Control Building - Level B Fire Fighting Preplan Section 1R06: Flood Protection Measures Work Orders SNC 395851

Calculations X6CXC-27 Rev.8, Flooding Analysis Auxiliary Building Level D

Procedures 25512-C Rev.1.0, General Inspection Outdoor Electrical Duct Run Pull Boxes/Manholes Drawings 2X4DB147-1 Rev. 18.0, P&I Diagram Aux BLDG. Flood Retaining Rooms Alarms & Drains

System No. 1218

Section 1R07: Heat Sink Performance Work Orders: SNC 121039

Procedures 83309-C Rev. 6.4, Safety-Related Heat Exchanger Inspection 83305-C Rev. 7.6, Heat Exchanger Test/Maintenance Program

Condition Reports: CR 523190

Other Heat Exchanger 'as-found' and 'as-left' photos taken 09/24/2012

4 Attachment Section 1R11: Licensed Operator Requalification Program Other V-RQ-SE-12705, Simulator Exercise Guide: Steam Generator Tube Leak

Procedures 18009-C Rev. 29.2, Steam Generator Tube Leak

18007-C Rev. 23, Chemical and Volume Control System Malfunction

Section 1R12: Maintenance Effectiveness Engineering Documents System 1301-2, Main Steam System 2012 health reports System 1205 RHR System, 4th quarter 2012 system health report Condition Reports: 348759, 2PV3000 has exceeded its MR OOS time

343991, 2PV3000 SG-1 ARV Failure

518228, 1HV8702A will not open

534190, MR evaluation identified FF Procedures 50028-C Rev. 18.1, Engineering Maintenance Rule Implementation

Section 1R15: Operability Evaluations Condition Reports: 501741, U-1 D/G "A" unit available light is not working 533822, Unit 1 and 2 main steam isolation valves (MSIVs) 530916, Unit 1 steam generator loops 2 & 3 do not indicate steam flow

Engineering Documents RER SNC440108, MSIV stem failure evaluation DOEJ-VRSNC440108-M001, Unit 1 MSIVs ((1HV3016B & 1HV3026B) disk separation

Other VNP-12-008 REV. 1.0, ODMI worksheet for degraded MSIV stems

Operating Experience Smart Sample (OpESS) 2012/02, Revision 1, Technical Specification Interpretation and Operability Determination Section 1R18: Plant Modifications Other MDC SNC439341/1.0, 1-1208-U4-A11, Auxiliary Pressurizer Spray Valve Seal Leak Section 1R19: Post Maintenance Testing Procedures 25022-C Rev. 7, General Small Bore Piping Installation

14240-1 Rev. 5.2, Manual SLI TADOT

14850-1 Rev. 52, Cold Shutdown Valve Inservice Test 14980A-2 Rev. 23, Diesel Generator Operability Test 14825-1 Rev. 97, Quarterly Inservice Valve Test

14430-2 Rev. 9.0, NSCW Cooling Tower Fans Monthly Test

5 Attachment Condition Reports 523221 530916

550378

Work Orders SNC410412 SNC439646 SNC439647

SNC439900

SNC424222

SNC387201 SNC127251 SNC447741

Section 1R22: Surveillance Testing Procedures 14666-1 Rev. 34.1, Train A Diesel Generator and ESFAS Test 14372B-1 Rev. 9, Containment Penetration No. 72B RCS Loop #3 Accumulator Sample Line Local Leak Rate Test 14670A-1 Rev. 1.2, Diesel Generator 1A Hot Restart Test

14808A-2 Rev. 2.2, Train A Centrifugal Charging Pump and Check Valve IST and Response Time Test 14804A-1 Rev. 4, Safety Injection Pump A Inservice and Response Time Test 14905-1 Rev. 67.2, RCS Leakage Calculation (Inventory Balance)

14905-2 Rev. 50.1, RCS Leakage Calculation (Inventory Balance)

14802A-1 Rev. 4.1, Train A NSCW Pump/Check Valve IST and Response Time Test

Work Orders SNC356759

SNC335801

SNC371576

SNC385697

SNC380426 SNC392870 Section 1EP4: Emergency Action Level and Emergency Plan Changes Change Packages Emergency Plan, Revision 57 NMP-EP-110, "Emergency Classification Determination and Initial Action," Version 3.0 NMP-EP-110, "Emergency Classification Determination and Initial Action," Version 4.0

NMP-EP-111, "Emergency Notifications," Version 7.0

NMP-EP-112, "Protective Action Recommendations," Version 2.0

91201-C, "Activation and Operation of the Technical Support Center," Revision 17

91202-C, "Activation and Operation of the Operations Support Center," Revision 22

6 Attachment Section 2RS1: Radiological Hazard Assessment and Exposure Controls Procedures, Guidance Documents, and Manuals 43014-C, "Special Radiological Controls", Ver. 46

46024-C, "Release of Materials from the RCA", Ver. 9.3

93240A-C, "Reactor Vessel Disassembly Instructions", Ver. 33

NMP-HP-300, "Radiation and Contamination Surveys", Ver. 2.0

NMP-HP-302, "Restricted Area Classification, Postings, and Access Control", Ver. 2.1 NMP-HP-303, "Personnel Decontamination", Ver. 1.4 NMP-HP-305, "Alpha Radiation Monitoring", Ver. 4.0

NMP-CH-013-001, "Vogtle RCS Chemistry During Scheduled Plant Shutdowns with Fuel Defects Suspected", Ver. 1.0 NMP-GM-002, "Corrective Action Program", Ver. 12.1 Records and Data NMP-HP-109, "Investigation, Evaluation and Management of Damaged, Lost, Malfunctioning or Alarming Dosimetry", Ver. 1.1, Data Sheet 2, Worker's Statement for Dose/Rate Alarm or

Malfunctioning Electronic Dosimeter, 9/26/12 Unit 1 Spent Fuel Pool Inventory Log Non Fuel Radioactive Material Stored in Unit 1 Spent Fuel Pool Contingency Plan for: Health Physics Controls for High Noble Gas Activity During Code Safety Valve Removal During 1R17 ALARA Briefing Notes: Rx Head/ Upper Internals Lift and Set

Alpha Levels, Comparing 100 cm2 Samples RWP 12-1618, Repair of Unit 1 Transfer Canal Transfer Tube ISO Valve 1-1213-U6-086, Rev. 0 RWP 12-1505, Under Rx Vessel Work, Rev. 0

RWP 12-1608, Remove/Install Pzr Code Safety Valves, Rev. 0

RWP 12-1600, CM/PM, VLVS, Motors, Misc Activities in U1 CTMT, Rev. 0

Radiological Survey 124805, U1 SFP Transfer Canal Radiological Survey 124876, U1 SFP Transfer Canal Radiological Survey 152222, Unit 1 Transfer Canal - Top View (1FHBC1)

Radiological Survey 151559, Valve Gallery SFP Cooling Demin (1AXA46)

Radiological Survey 153033, Inside Bioshield Area (1RXC)

Radiological Survey 152915, Inside Bioshield Area (1RXC)

Radiological Survey 152836, Inside Bioshield Area (1RXC) Radiological Survey 152699, Seal Table Rack Pulled Back (1RXA3) Radiological Survey 152711, Seal Table (1RXA3)

Radiological Survey 151834, Auxiliary Building Level D (CAXD)

Radiological Survey 9/18/2012 15:38, Under Vessel

Radiological Survey 152143, Top of PZR - 252' el. (1RX32) Radiological Survey 152054, Top of PZR - 252' el. (1RX32) Radiological Survey 135176, Top of PZR - 252' el. (1RX32)

Radiological Survey 152283, S/G 4 Channel Head Cold Leg (1RXB27)

Radiological Survey 152282, S/G 4 Channel Head Hot Leg (1RXB26)

Radiological Survey 152281, S/G 1 Channel Head Cold Leg (1RXB19)

Radiological Survey 152281, S/G 1 Channel Head Cold Leg (1RXB19) Radiological Survey 151964, U1 Containment Building Level 1 (1RX1) Radiological Survey 152549, U1 Containment Level A Lower Overview (1RXA) Radiological Survey 151986, U1 Containment 184' El. Quadrant 1 (1RXB)

7 Attachment Radiological Survey 152662, U1 Containment 197' El. Quadrant 1 (1RXA) Radiological Survey 151910, U1 Containment 197' El. Quadrant 1 (1RXA) Radioactive Sealed Source Leak Test Certification, Source ID 0413-00-00, 6/22/12, 12/5/11, 6/28/11, 1/19/10 Air Sample Log, 9/18/12 - 9/20/12

CAP Documents V-HP-2011, Fleet Oversight Audit of Health Physics, 8/15/11 CR 382120

CR 335736

CR 519818

CR 527832 CR 523976 CR 434496

CR 434498

CR 481012

Section 2RS2: Occupational ALARA Planning and Controls Procedures, Guidance Documents, and Manuals 16035-1, "Chemistry Operations Interface for RCS Chemistry Control During Scheduled Plant Shutdowns", Ver. 13 43031-C, "Steam Generator Job Coverage", Rev. 5.3

00910-C, "VEGP ALARA Program", Rev. 15.3 41001-C, "ALARA Job Review", Rev. 33.1 NMP-AD-035, "ALARA Program", Ver. 1.0

NMP-HP-204, "ALARA Planning and Job Review", Ver. 2.0

43014-C, "Special Radiological Controls", Ver. 46

Records and Data Audit No. V-HP-2011, Fleet Oversight Audit of Health Physics, 8/15/2011

NMP-GM-003-F04 Self-Assessment Final Report; ALARA Outage Planning, CR#2011100194,

12/17/10

Shutdown Chemistry Review: Vogtle Unit 2 Fuel Cycle 15, Final report October 24, 2011 ALARA Committee Meeting Minutes First Quarter 2012 2011 Annual ALARA Report, March 30, 2012 Pre-1R17 ALARA Sub-Committee Meeting Minutes, August 10, 2012

Vogtle 1R17 EPRI Standard Radiation Monitoring Points

Chemistry Crud Burst chart 9/16/12 22:00-9/20/12 22:00

ALARA Steam Generator Work Package: ALARA Briefing Records RWP 12-1300, R/I Primary Manway Covers & Diaphragms on S/G 1-4; ALARA Briefing

Record RWP 12-1301, Install and Remove Nozzle Dams for SGs 1-4; ALARA Briefing

Record RWP 12-1302, EDDY Current Testing on SG 1-4 & All Associated Work; ALARA

Briefing Record RWP 12-1303, Sludge Lance on S/G 1-4 & all Associated Work; ALARA

Briefing Record RWP 12-1305, Radiological Surveys #152638, 9/25/12 20:58, S/G Manway Platt #1; #152279, 9/20/12 14:59, S/G Channel Head

Hot leg; #152281 9/20/12 15:30, S/G Channel Head Cold Leg; #152688 9/26/12 11:15, S/G

8 Attachment Manway Platt 2; #152244 9/20/12 6:25 S/G Channel Head Hot Leg; #152245 9/20/12 6:35 S/G Channel Head Cold Leg; #152690 9/26/12 11:26 S/G Manyway Platt 3; #152246 9/20/12 6:43 S/G 3 Channel Head Hot Leg; #152282 9/20/12 15:57 S/G 4 Channel Head

Hot Leg; #152639 9/25/12 21:05 S/G Manway Platt 4; #152653 9/26/12 1:29 S/G #3 Hand-

Hole Plat

Work-In-Progress Reviews NMP-HP-104 (or equivalent) RWP 12-1303, 9/27/12 80% Review; RWP 12-1302, 9/23/12 50% Review; RWP 12-1300 9/24/12 50% Review; RWP 12-1301 9/24/12 50% Review; RWP !2-1303 9/25/12 50% Review; RWP 12-1304 9/25/12 50% Review

NMP-HP-204 Form 8 Respirator Use Evaluation Worksheets for RWP 12-1301 Radiological Surveys: #38622, 1/22/02, Plant Vogtle U1 Transfer Canal- top view #117917, 7/14/09, U1 Transfer Canal- topview #152208, 9/19/12, U1 Transfer Canal- Side view ALARA Briefing Record RWP 12-1004, Install/Remove Scaffold in U1 CTMT

ALARA Briefing Record RWP 12-1104, Waste and Decon Routines in U1 CTMT

ALARA Briefing Record RWP 12-1618, Repair of U1 Transfer Canal ALARA Post-Job Report 11-2509, RPV Cold Leg Nozzle Inspection in U2 Annulus ALARA Post-Job Report 11-2302, Eddy Current Testing on S/G 1&4 CAP Documents CR 167416, The accumulated dose for the U-1 Aux Bldg ECCS Flowpath Verification that was performed CR 339453, HP Self Assessment on High Rad Area Controls CR 346242, Dose goal exceeded for placing old UFC skid into shipping container Section 2RS3: In-Plant Airborne Radioactivity Control and Mitigation Procedures, Guidance Documents, and Manuals 43635-C, "Operation and Calibration of the AMS-4 Continuous Air Monitor", Rev. 18.1 47013-C, "Inspection, Repair, and Storage of Self Contained Breathing Apparatus", Ver. 37

NMP-HP-301, "Airborne Radioactivity Sampling and Evaluation", Ver. 1.2

00970-C, "Respiratory Protection Program", Rev. 11.4

NMP-GM-002, "Corrective Action Program", Ver. 12.1 Records and Data Compressed Air/Gas Quality Testing, SCBA Compressor (Demin Plant), 2/5/10, 5/10/10, 8/11/10, 11/9/10, 2/14/11, 5/11/11, 8/25/11, 11/7/11, 2/9/12, 5/7/12, 8/14/12 00012-C, "Shift Manning Requirements", Rev. 17.1, Data Sheet 1, Minimum Shift Manning (Either Unit in Mode 1-4), Day Shift, 9/21/12 Qualification List, ID V-GE-099H, MSA High Pressure Firehawk MMR SCBA, Maintenance, Health Physics, and Operations Qualification List, ID V-HP-999 MSA C.A.R.E. Tech

Control Room Monthly Emergency SCBA Inspection, 8/7/12

TSC Monthly Emergency SCBA Inspection, 8/10/12

SCBA PosiChek3 Test Results, SCBA Unit HP-82, 11/26/10, 12/30/10, 11/23/11 SCBA Posichek3 Test Results, SCBA Unit HP-61, 12/29/10, 12/28/11 SCBA Posichek3 Test Results, SCBA Unit HP-58, 8/24/10, 8/25/11, 8/27/12

Maintenance Record Report, SCBA Units HP-58, HP-61, HP-82, 8/1/10 - 9/16/12

9 Attachment CAP Documents V-HP-2011, Fleet Oversight Audit of Health Physics, 8/15/11 CR 167804

Section 2RS4: Occupational Dose Assessment Procedures, Guidance Documents, and Manuals NMP-HP-107-001, "Instructions for Retrieving, Printing and Updating Individual Radiation Exposure Records", Version 1.0 NMP-HP-105, "Comparisons of OSLD and ED Dosimetry Results", Ver. 1.0

NMP-HP-106, "Investigating of Exposures Exceeding Fleet Administrative Limits", Ver. 1.0 NMP-HP-103, "Skin Dose Assessment", Ver. 1.1

NMP-HP-100, "Bioassay Program", Ver. 1.0 NMP-HP-101, "In-Vivo Bioassay and Internal Dose Assessment", Ver. 1.0 45013-C, "Issuance, Use and Collection of Personnel Dosimetry", Ver. 26.3

Records and Data Canberra Report of Performance Testing Results for Nuclear Enterprises (NE) Model SPM 904B/906 Personnel Portal Monitor, May 18, 2012 Personnel Contamination Events/Personnel Contamination Reports (PCE/PCR) Logs, 9/2011-9/2012 EDE & NRC Form 5 Calculations for Steam Generator Multibadging Jobs entry made on 9/20/12; Multibadge RCA Authorization/Worksheets NMP-HP-109 Data Sheets, Investigation of Lost, Damaged or Malfunctioning Personnel Dosimetry, for occurrence on 9/26/12 NMP-HP-109 Data Sheet 2, Investigation of Lost, Damaged or Malfunctioning Personnel Dosimetry, for occurrence on 9/28/12 Varskin 3 Calculations 10/5/2011

CAP Documents CR 149580, On 4-16-10 there were (62) EPD's and (1) EPD "Vibe Mesh Transmitter" found at the RPF control room CR 152467, A vendor arrived on site on June 22 at 08:45 am. and asked for a source that was shipped to Plant Vogtle. CR 466572, HP Tier 1 outage readiness Health Physics Tier 1 outage review was performed with the HP Manager. Section 2RS5: Radiation Monitoring Instrumentation Procedures, Guidance Documents, and Manuals 17005-1, "Annunciator Response Procedures for ALB 05 on Panel 1A2 on MCB", Ver. 33 17100-2, "Annunciator Response Procedure for the Process and Effluent Radiation Monitoring System (RMS)", Rev. 20.1 24625-1, "Containment High Range (2RE-0005) Area Monitor 2RX-0005 Channel Calibration", Rev. 29.1 24652-1, "Plant Vent Wide Range Radiogas Monitor 1RX-12444 Channel Operational Test and

Channel Calibration", Rev. 19 34313-C, "Operation of the DRMS Plant Vent Effluent Wide Range Monitor 1(2) RE-12444," Rev 17 43802-C, "Calibration of Gamma Standards", Rev. 12.1

10 Attachment 43500-C, "Health Physics Instrument Calibration and Control Program," Rev. 53.10 43685-C, "Calibration and Operation of the Asp-1", Rev 20.3 43693-C, "Operation and Use of the Jl Shepherd Model 89-400 Shielded Calibrator, Rev. 2.1

NMP-HP-703, "RO-2, RO-2A and RO-20 Operation and Calibration, Ver.1.0

NMP-HP-703, "Daily Instrumentation Source Checks," Ver 1.1

NMP-EP-110-GL03, "VEGP EALs - ICs, Threshold Values and Basis", Ver. 3.0

Vogtle Electric Generating Plant (VEGP), ODCM, Ver. 28 Records and Data 10 CFR Part 61 Analysis, DAW, Dated 12/21/2011

10 CFR Part 61 Analysis, DAW, Dated 12/28/2010

Chemistry Issues Turnover Log, Dated 09/17/2012 In Situ Calibration of High Range Monitors, VEGP Units 1&2, Dated 02/18/1997 LS 6500 SN 7069842 Source Check Response Charts, Dated 02/11/2011 - 03/28/2012

HPGE Detector #1 Control Charts, Dated 12/25/2011 - 04/03/2012

Radiation Monitor RE-005 Monthly Tech Spec Response Surveillance, Dated May 2010 - September 2012 Radiation Monitor System Health Reports for 1st and 2nd Quarters 2012 LCO/TR Status Sheet, 1RE006 Failure, initiated 08/14/2010

Special Report 2011-001-00, Inoperable Radiation Monitor 1RE-006, Dated 03/29/2011

RadCal Electrometer Model 2025, SN4676 Calibration Record, Dated 10/31/2011

RadCal Probe Model 20X5-3, SN14166 Calibration Record, Dated 10/31/2011

RadCal Probe Model 20X5-180, SN16121 Calibration Record, Dated 10/31/2011 RadCal Probe Model 20X5-1800, SN21721 Calibration Record, Dated 10/31/2011 Instruments Missing Operation Checks Report, Dated 09/19/2012

Online Instruments Issued Report, Dated 09/19/2012

IPM-7A/8/9, VEGP-HP 0637, Calibration Records, Dated 06/14/2011 and 06/12/2012

Model 28-5 Calibrator, Source VEGP 0292, Calibration Record, Dated 05/18/12 Model 89-400 Calibrator, Source VEGP 0413, Calibration Record, Dated 08/12/2012 Model 878-10 Calibrator, Source VEGP 1049, Calibration Record, Dated 08/12/2012

SAM-11, VEGP-HP 1151, Calibration Records, Dated 05/26/2011 and 05/23/2012

SPM-904B, VEGP-HP 0754, Calibration Records, Dated 02/8/2011 and 02/10/2012

WO 1090817001, Plant Vent Wide Range Radiogas Flow 1F-12444 Channel Operational Test and Channel Calibration, Dated 03/03/11 WO SNC332418, Plant Vent Wide Range Radiogas Flow 1F-12444 Channel Operational Test and Channel Calibration, Dated 03/28/2012 WO 1090816001, Plant Vent Wide Range Radiogas Radiation Monitor 1RX12444 Channel Operational Test and Channel Calibration, Dated 10/15/10 WO 1100068601, 2RE0005 Containment High Range Monitor Channel Calibration, Dated 08/09/2010 WO 11000408201, 2RE0005 Containment High Range Monitor Channel Calibration,

Dated 03/29/2011

WO 1080853101, 1RE0011 In-Core Instrumentation Room Area Monitor Calibration, Dated 09/26/2009 WO 1100216601, 1RE0011 In-Core Instrumentation Room Area Monitor Calibration, Dated 03/14/2011 WO SNC328096, 1RE0018 Waste Liquid Effluent Channel Operational Test and Calibration, Dated 03/09/2012

11 Attachment WO 1090816201, 1RE0018 Waste Liquid Effluent Channel Operational Test and Calibration, Dated 01/28/2011 WO 1090816201, 1RE0018 Waste Liquid Effluent Isotopic Channel Calibration, Dated 02/23/2012 WBC Calibration Report, "Calibration of the Canberra Fastscan-1 WBC System at the Vogtle Electric Generating Plant", Dated 06/08/2011 and 06/13/2012 WBC Calibration Report, "Calibration of the Canberra Fastscan-2 WBC System at the Vogtle Electric Generating Plant", Dated 06/09/2011 and 06/15/2012

CAP Documents Fleet Oversight Audit of Health Physics, V-HP-2011, Dated 08/15/2011

CR 285751 CR 302822 CR 410359

CR 321427

CR 472385

CR 483434 CR 481949 CR 490231

CR 521213

Section 4OA1: Performance Indicator Verification Procedures, Guidance Documents, and Manuals 00163-C, "NRC Performance Indicator and Monthly Operating Report Preparation and Submittal", Ver. 14.3

Records and Data Liquid Permit Post-Release Data Permit # L-20120725-087-B Gas Permit Post-Release Data Permit # G-20120813-171-C Gas Permit Post-Release Data Permit # G-20120808-165-C

Liquid Permit Post-Release Data Permit # G-20120803-091-B

ED Alarm Log Sept 2011-Sept 2012

CAP Documents CR 349797, Trouble shoot plan for U2 CVCS Demin Results in Resin in Drain Line CR 474221, Dose equivalent Iodine definition in Tech Specs and ODCM does not match

CR 480703, U-1 RMWST degassifier dissolved oxygen anomaly

CR 354479, Increased dose rates in 2AB-A-72

Section 4OA2: Identification and Resolution of Problems Procedures/Calculations/Engineering Documents CAR 196113 - Root Cause and Corrective Actions Evaluation for the Unit 1 Steam Generator Loop T Mismatch 12001-C, Unit Heat Up to Hot Shutdown (Mode 5 to Mode 4)

14850-1/2, Cold Shutdown Valve In-Service Test 26854-C, MSIV Actuator Maintenance

12 Attachment Condition Reports 530916 - Unit 1 steam generators 2&3 do not indicate steam flow Section 4OA7: Licensee Identified Violations Radiological Survey 151559, Valve Gallery SFP Cooling Demin (1AXA46) CR 519818

LIST OF ACRONYMS 1R17 Unit 1 Refueling Outage 17 ALARA As Low As Reasonably Achievable

ARM Area Radiation Monitor CAP Corrective Action Program CFR Code of Federal Regulations

CR Condition Report

DAW Dry Active Waste

DPW Declared Pregnant Worker ED Electronic Dosimeter FSAR Final Safety Analysis Report

HP Health Physics

HPT HP Technician

HRA High Radiation Area

IP Inspection Procedure LHRA Locked High Radiation Area NCV Non-cited Violation

NPR Negative Pressure Respirator

NVLAP National Voluntary Laboratory Accreditation Program

OA Other Activities OSLD Optically Stimulated Luminescent Dosimeter PCM Personnel Contamination Monitor

PI Performance Indicator

PM Portal Monitor

Radwaste Radioactive Waste

RCA Radiologically Controlled Area RS Radiation Safety RWP Radiation Work Permit

S/G Steam Generator

SAM Small Article Monitor

SCBA Self-contained Breathing Apparatus SDP Significance Determination Process SFP Spent Fuel Pool

TS Technical Specification

U1 Unit 1

VHRA Very High Radiation Area

WBC Whole Body Counter