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{{IR-Nav| site = 05000424 | year = 2004 | report number = 005 | url = https://www.nrc.gov/reactors/operating/oversight/reports/vog_2004005.pdf }}
{{Adams
| number = ML042960165
| issue date = 10/15/2004
| title = IR 05000424-04-005 and 05000425-04-005, on 06/27/2004 - 09/25/2004; Voglte Electric Generating Plant
| author name = Bonser B
| author affiliation = NRC/RGN-II/DRP
| addressee name = Grissette D
| addressee affiliation = Southern Nuclear Operating Co, Inc
| docket = 05000424, 05000425
| license number = NPF-068, NPF-081
| contact person =
| document report number = IR-04-005
| document type = Inspection Report, Letter
| page count = 20
}}
 
{{IR-Nav| site = 05000424 | year = 2004 | report number = 005 }}
 
=Text=
{{#Wiki_filter:ber 15, 2004
 
==SUBJECT:==
VOGTLE ELECTRIC GENERATING PLANT - NRC INTEGRATED INSPECTION REPORT 05000424/2004005 AND 05000425/2004005
 
==Dear Mr. Grissette:==
On September 25, 2004, 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 results, which were discussed on September 30, 2004, with Mr. William Kitchens and other members of your staff.
 
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
 
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
 
This report documents one NRC-identified finding of very low safety significance (Green) which was determined to involve a violation of NRC requirements. However, because of the very low safety significance and because it has been entered into your corrective action program, the NRC is treating this violation as a non-cited violation (NCV) consistent with Section VI.A of the NRC Enforcement Policy. If you contest the NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the United States 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 Vogtle.
 
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or
 
SNC  2 from the Publicly Available Records (PARS) component of NRCs document system (ADAMS).
 
ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
 
Sincerely,
/RA/
Brian R. Bonser, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket Nos.: 50-424, 50-425 License Nos.: NPF-68, NPF-81
 
===Enclosure:===
Inspection Report 05000424/2004005 and 05000425/2004005 w/Attachment: Supplemental Information
 
REGION II==
Docket Nos.: 50-424, 50-425 License Nos.: NPF-68, NPF-81 Report Nos.: 05000424/2004005 and 05000425/2004005 Licensee: Southern Nuclear Operating Company, Inc. (SNC)
Facility: Vogtle Electric Generating Plant Location: 7821 River Road Waynesboro, GA 30830 Dates: June 27, 2004 - September 25, 2004 Inspectors: G. McCoy, Senior Resident Inspector T. Morrissey, Resident Inspector J. Zeiler, Senior Resident Inspector, V. C. Summer J. Baptist, Project Engineer (Section 1R06)
L. Mellon, Senior Operations Engineer (Section 4OA1)
Approved by: Brian R. Bonser, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure
 
=SUMMARY OF FINDINGS=
IR 05000424/2004-005, 05000425/2004-005; 06/27/2004 - 09/25/2004; Vogtle Electric
 
Generating Plant, Units 1 and 2; Other Activities.
 
The report covered a three-month period of inspection by resident inspectors and announced inspections by a senior operations engineer and a project engineer. One Green non-cited violation (NCV) was identified. The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
 
===NRC-Identified and Self-Revealing Findings===
 
===Cornerstone: Mitigating Systems===
: '''Green.'''
A non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion XVI,
Corrective Action, was identified for failure to implement effective corrective actions to ensure loose debris that could affect the post-accident recirculation function of the residual heat removal system was removed from containment.
 
Since this condition had a potential safety significance greater than Green, a regional Senior Reactor Analyst performed a Phase III significance determination analysis to determine the actual safety significance. The Phase III analysis considered the loss-of-coolant accidents (LOCAs) (small, medium or large) that could dislodge un-jacketed steam generator insulation. This was due to the key assumption that both the loose debris and the steam generator insulation were necessary to lose the RHR recirculation safety function. Considering the three dominant accident sequences and the actual plant condition and exposure time, this finding was determined to be of very low safety significance. The direct cause of this finding involved the cross-cutting area of Identification and Resolution of Problems. (Section 4OA5.1)
 
===Licensee-Identified Violations===
 
None.
 
=REPORT DETAILS=
 
===Summary of Plant Status===
 
Unit 1 operated at essentially full rated thermal power (RTP) throughout the inspection period.
 
Unit 2 operated at essentially full RTP until July 31, 2004, when power was reduced to approximately 87 percent RTP due to a small reactivity anomaly. The licensee concluded that the anomaly was most likely due to one or two neutron absorber rods separating from a rod cluster control assembly (RCCA). On August 6, the unit was shutdown to verify full insertion capability of all control rod assemblies. On August 7, the unit was restarted and operated at essentially full RTP for the remainder of the inspection period.
 
==REACTOR SAFETY==
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
{{a|1R01}}
==1R01 Adverse Weather Protection==
 
====a. Inspection Scope====
Adverse Weather Preparation Review. On August 12 and September 3, the inspectors reviewed licensee procedure 11889-C, Severe Weather Checklist, to verify the licensee had implemented actions to prepare the plant site for predicted severe weather conditions of high winds and heavy rain. The inspectors walked down various site areas to verify the licensees ability to respond to predicted adverse weather conditions.
 
====b. Findings====
No findings of significance were identified. {{a|1R04}}
==1R04 Equipment Alignment==
 
====a. Inspection Scope====
Partial System Walk-downs. The inspectors performed partial walkdowns of the following three systems to verify correct system alignment while redundant or backup equipment was inoperable or following return to service. The inspectors checked for correct valve and electrical power alignments by comparing positions of valves, switches, and breakers to the licensee procedures and drawings listed in the
. Additionally, the inspectors reviewed the condition report (CR) database to verify that equipment alignment problems were being identified and appropriately resolved.
* 2A essential chilled water (ECW) system while 2B ECW system was out of service
* 1B high head safety injection (HHSI) system while 1A HHSI pump was out of service
* 2A auxiliary feedwater pump after the system was returned to service following maintenance
 
====b. Findings====
No findings of significance were identified. {{a|1R05}}
==1R05 Fire Protection==
 
====a. Inspection Scope====
Fire Area Tours. The inspectors walked down the following nine plant areas to verify the licensee was controlling combustible materials and ignition sources as required by licensee procedures 92015-C, Use, Control, and Storage of Flammable/Combustible Materials, and 92020-C, Control of Ignition Sources. The inspectors assessed the observable condition of fire detection, suppression, and protection systems and reviewed the licensees fire protection Limiting Condition for Operation log and CR database to verify that the corrective actions for degraded equipment were identified and appropriately prioritized. The inspectors also reviewed the licensees fire protection program to verify the requirements of Updated Final Safety Analysis Report (UFSAR)
Section 9.5.1, Fire Protection Program, and Appendix 9A, Fire Hazards Analysis, were met. Documents reviewed are listed in the Attachment.
* 2A engineered safety feature (ESF) chiller and filter rooms
* 1A nuclear service cooling water (NSCW) building and tunnels
* Unit 1 train A and B remote shutdown panel rooms and class 1E 4.16 KV switchgear rooms
* 1B motor driven auxiliary feedwater (AFW) pump and 1C turbine driven AFW pump rooms
* 1B HHSI pump and valve rooms
* 1B ESF chiller and filter rooms
* 2A and 2B HHSI pump rooms
* 1A emergency diesel generator (EDG) and associated fuel oil storage tank rooms
* 2A cable spreading room
 
====b. Findings====
No findings of significance were identified. {{a|1R06}}
==1R06 Flood Protection==
 
====a. Inspection Scope====
External Flood Review. The inspectors reviewed the licensees external flooding mitigation procedures and equipment to verify they were consistent with the licensees design requirements and risk analysis assumptions. The inspectors discussed external flooding preparation with engineering personnel to verify preparation and compensatory measures met the licensees design requirements and risk analysis assumptions. The inspectors checked selected external drain systems to verify the drains would function properly. The inspectors reviewed a sampling of CRs to verify the licensee was identifying and correcting problems associated with flood detection and protection of structures, systems and components (SSCs). Documents reviewed are listed in the
.
Internal Flood Review. The inspectors reviewed the UFSAR and Individual Plant Examination and walked down the following four areas which contained risk-significant SSCs below flood level to verify flood barriers were in place. Motor controllers and terminal boxes that could become potentially submerged were inspected to ensure that the sealing gasket material was intact and undamaged. The inspectors reviewed selected licensee alarm response procedures to verify alarm setpoints and setpoints for sump pump operation were consistent with the UFSAR, the setpoint index, and Technical Specifications (TS).
* Unit 1 north main steam valve room
* Unit 1 south main steam valve room
* Unit 2 north main steam valve room
* Unit 2 south main steam valve room
 
====b. Findings====
No findings of significance were identified. {{a|1R11}}
==1R11 Licensed Operator Requalification==
 
====a. Inspection Scope====
Quarterly Resident Review. The inspectors evaluated operator performance on July 28, during licensed operator simulator training associated with Requalification Segment 20044. The simulator scenario began with failure of a pressurizer pressure instrument channel followed by a steam generator tube rupture and faulted steam generator. The inspectors assessed the following areas:
* Correct use of licensee abnormal and emergency operating procedures including 18001-C, Primary Systems Instrumentation Malfunction;18009-C, Steam Generator Tube Leak; 19030-C, E-3 Steam Generator Tube Rupture; and 19020-C, E-2 Faulted Steam Generator Isolation
* Ability to implement appropriate event reporting and emergency plan actions in accordance with licensee procedures 91001-C, Emergency Classification and Implementing Instructions, and 91002-C, Emergency Notifications
* Ability to identify and implement appropriate TS actions
* Clarity and formality of communications in accordance with licensee procedure 10000-C, Conduct of Operations
* Proper control board manipulations including critical operator actions
* Quality of supervisory command and control
* Effectiveness of post-evaluation critique
 
====b. Findings====
No findings of significance were identified. {{a|1R12}}
==1R12 Maintenance Effectiveness==
 
====a. Inspection Scope====
The inspectors reviewed the following two equipment problems and associated licensee CRs to evaluate the effectiveness of the licensees handling of equipment performance problems and to verify the licensees maintenance efforts met the requirements of 10 CFR 50.65 (the Maintenance Rule) and licensee procedure 50028-C, Engineering Maintenance Rule Implementation. The inspectors assessed adequacy of the licensees failure characterization, establishment of performance criteria or 50.65 (a)(1)performance goals, and adequacy of corrective actions. Other documents reviewed during this inspection included control room logs, system health reports, the maintenance rule database, and maintenance work orders (MWOs). The inspectors interviewed system engineers and the maintenance rule coordinator to assess the accuracy of identified performance deficiencies and the extent of condition.
* 1B containment spray motor cooler flow less than acceptable limit (CR 2004000810)
* 2A digital sequencer failure (CR 2004002015)
 
====b. Findings====
No findings of significance were identified. {{a|1R13}}
==1R13 Maintenance Risk Assessments and Emergent Work Evaluation==
 
====a. Inspection Scope====
The inspectors reviewed the following six MWOs to verify plant risk was properly assessed by the licensee prior to conducting the activities. The inspectors reviewed risk assessments and risk management controls implemented for these activities to verify they were completed in accordance with licensee procedure 00354-C, Maintenance Scheduling, and 10 CFR 50.65(a)(4). The inspectors also reviewed the CR database to verify that maintenance risk assessment problems were being identified at the appropriate level, entered into the corrective action program, and appropriately resolved.
* 1A MDAFW pump miniflow valve outage (MWO 10402184)
* 1A HHSI pump outage (MWOs 10402286 and 10302363)
* 1A control room emergency filtration system (CREFS) outage (MWOs 10200290, 10302585 and 10402637)
* 2A CREFS outage (MWOs 20402088, 20302936 and 20301815)
* 1B MDAFW pump miniflow valve outage (MWO 10402739)
* 1B ECW system outage (MWOs 10301826, 10203066, 10402061 and 10400120)
 
====b. Findings====
No findings of significance were identified. {{a|1R14}}
==1R14 Operator Performance During Non-Routine Plant Evolutions==
 
====a. Inspection Scope====
For the two non-routine plant evolutions described below, the inspectors reviewed the operating crews performance, reviewed operator logs, control board indications, and plant computer data to verify that operator response was in accordance with the associated plant procedures.
* July 31, Unit 2 reactivity anomaly
* August 6, Unit 2 shutdown and subsequent startup in accordance with licensee procedures 12004-C, Power Operation (Mode 1), 12005-C, Reactor Shutdown to Hot Standby (Mode 2 to Mode 3) and 12003-C, Reactor Startup (Mode 3 to Mode 2)
 
====b. Findings====
No findings of significance were identified. {{a|1R15}}
==1R15 Operability Evaluations==
 
====a. Inspection Scope====
The inspectors reviewed the following five evaluations to verify they met the requirements of licensee Nuclear Management Procedure (NMP)-GM-002, Corrective Action Program, and NMP-002-GL02, Corrective Action Program Details and Expectations Guideline. This scope included an assessment of the technical adequacy of the evaluations, the adequacy of compensatory measures, and the impact on continued plant operation.
* 2A ECW system relief valve 2PSV22404 leakage (CR 2004002711)
* Unit 2 reactivity anomaly (CR 2004003225)
* Unit 1 electrical penetration loss of gas pressure (CR 2004003514)
* Unit 2 replacement of the thermocouple selector switch on the 2B EDG (WO 20400540)
* Unit 2 auxiliary relay room ESF cooler flowrate higher than recommended (CR 2004003822)
 
====b. Findings====
No findings of significance were identified. {{a|1R16}}
==1R16 Operator Workarounds==
 
====a. Inspection Scope====
The inspectors reviewed the licensees list of identified operator workarounds and burdens to determine whether any items would adversely affect the operators ability to implement abnormal or emergency operating procedures. Additionally, the inspectors reviewed Unit 1 and Unit 2 control room logs, caution tag logs, abnormal configuration logs, MWOs, and the clearance and tagging database, to identify any abnormal plant equipment configurations that might be considered operator workarounds, and to verify the licensee was identifying and documenting operator workarounds in accordance with licensee procedure 10025-C, Work Around Program. The inspectors also assessed the cumulative effects of any potential operator workarounds on the operators ability to effect a correct and timely response to plant transients and events.
 
====b. Findings====
No findings of significance were identified. {{a|1R19}}
==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 was sufficient to meet the TS operability requirements.
* 1A MDAFW pump miniflow valve outage (MWO 10402184)
* 1A HHSI pump outage (MWOs 10402286 and 10302363)
* 1A CREFS outage (MWOs 10200290, 10302585 and 10402637)
* 2A CREFS outage (MWOs 20402088, 20302936 and 20301815)
* 2A Group 1 room coolers (containment spray (CS) and component cooling water)outage (MWOs 20401772, 20401778, 20301863 and 20301865)
* 1B ECW system outage (MWOs 10301826, 10203066, 10402061 and 10400120)
 
====b. Findings====
No findings of significance were identified. {{a|1R20}}
==1R20 Refueling and Other Outage Activities==
 
====a. Inspection Scope====
On August 6, the licensee initiated a shutdown to Mode 3 to verify control rod operability. The inspectors reviewed the outage plans to confirm that the licensee had appropriately considered risk in developing and implementing the plans. During the outage, the inspectors observed or reviewed portions of the outage activities and preparations for unit restart to verify these activities were conducted in accordance with TS and licensee procedures.
 
====b. Findings====
No findings of significance were identified. {{a|1R22}}
==1R22 Surveillance Testing==
 
====a. Inspection Scope====
The inspectors reviewed the following six licensee 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
* 14420-2, Solid State Protection System and Reactor Trip Breaker Train A Operability Test
* 14980A-1, Diesel Generator Operability Test (1A, Fast start)
* 14546-2, Unit 2 Turbine Driven Auxiliary Feedwater Pump Operability Test
* 28820-C, 2CD1CB Battery Charger Load Test In-Service Tests
* 14808-1, Centrifugal Charging Pump and Check Valve IST and Response Time Test (1A, IST portion only).
 
RCS Leak Detection Systems
* 14905-2, RCS Leakage Calculation (Inventory Balance)
 
====b. Findings====
No findings of significance were identified. {{a|1R23}}
==1R23 Temporary Plant Modifications==
 
====a. Inspection Scope====
The inspectors evaluated the following Temporary Modification (TM) and associated 10 CFR 50.59 screening against the system design basis documentation and UFSAR to verify that the modifications did not adversely affect the safety functions of important safety systems. Additionally, the inspectors assessed if the modification was developed and implemented in accordance with licensee procedure 00307-C, Temporary Modifications.
* TM 2003-V1T061, Temporarily lift lead from safety injection system valve 1HV8806B to the system status monitoring panel.
 
====b. Findings====
No findings of significance were identified.
 
===Cornerstone: Emergency Preparedness===
 
1EP6 Drill Evaluation
 
====a. Inspection Scope====
On August 26, the licensee conducted an emergency drill involving a seismic event followed by a loss of coolant accident with an unmonitored reactivity release pathway to the environment through a failed purge supply isolation damper. The inspectors observed the drill to verify the licensee was properly classifying emergency events, making the required notifications, and making appropriate protective action recommendations in accordance with licensee procedures 91001-C, Emergency Classification and Implementing Instructions; 91002-C, Emergency Notifications; and 91305-C, Protective Action Guidelines.
 
====b. Findings====
No findings of significance were identified.
 
==OTHER ACTIVITIES==
{{a|4OA1}}
==4OA1 Performance Indicator (PI) Verification==
 
====a. Inspection Scope====
The inspectors sampled licensee submittals for the PIs listed below to verify the accuracy of the PI data reported during the indicated period. The PI definitions and guidance contained in licensee procedures 00163-C, NRC Performance Indicator Preparation and Submittal, and 50025-C, Reporting of Mitigating System Performance Indicator Unavailability, and NEI 99-02, Regulatory Assessment Indicator Guideline, Rev. 2, were used to verify the basis in reporting for each data element.
 
Mitigating Systems Cornerstone
* Safety System Unavailability - Auxiliary Feedwater System
* Safety System Unavailability - Emergency AC Power The inspectors reviewed operator log entries, maintenance rule database, monthly operating reports, monthly PI Summary reports, and NRC inspection reports for the PI data submitted by the licensee for both Unit 1 and Unit 2 during the period from July 2003 through June 2004.
 
Emergency Preparedness Cornerstone
* Emergency Response Organization (ERO) Drill/Exercise Performance
* ERO Drill Participation
* Alert and Notification System Reliability The inspectors assessed the accuracy of the PI for ERO drill and exercise performance (DEP) over the past eight quarters through review of a sample of drill and exercise records. The inspector assessed the accuracy of the PI for ERO drill participation during the previous eight quarters for personnel assigned to key positions in the ERO.
 
The inspector assessed the accuracy of the PI for the alert and notification system reliability through review of a sample of the licensees records of the complete cycle tests.
 
====b. Findings====
No findings of significance were identified.
{{a|4OA2}}
==4OA2 Identification and Resolution of Problems==
 
===1. Daily Screening of Corrective Action Items===
 
====a. Inspection Scope====
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 licensees corrective action program. This review was accomplished by either attending daily screening meetings that briefly discussed major CRs or accessing the licensees computerized corrective action database and reviewing each CR that was initiated.
 
====b. Findings and Observations====
No findings of significance were identified.
 
===2. Annual Sample Review.===
 
====a. Inspection Scope====
The inspectors reviewed two issues to evaluate the effectiveness of the licensees corrective actions for important safety issues documented in CRs 2004000682 and 2004000810. The condition reports were associated with a failure of inverter 1BD1I12 and 1B CS pump motor cooler flow less than the acceptable flow range. The inspectors assessed whether the issue was identified in a timely manner; documented accurately and completely; properly classified and prioritized; adequately considered extent of condition, generic implications, common cause, and previous occurrences; adequately identified root causes/apparent causes; and, identified appropriate corrective actions.
 
Also the inspectors verified the issue was processed in accordance with licensee procedure NMP-GM-002-GL02, Corrective Action Program Details and Expectation Guideline.
 
====b. Findings and Observations====
No findings of significance were identified.
 
CR 200400682 - The inspectors noted that the licensees review was thorough and the corrective actions were appropriate.
 
CR 200400810 - The inspectors identified that the functional failure was maintenance preventable. The issue was re-reviewed by the licensee who agreed that it should have been classified as a maintenance preventable functional failure (MPFF) and CR 2004003160 was initiated. Since the issue was a MPFF, CR 2004003160 was assigned a severity level 2 which requires more senior management review than the original severity level 3 CR. When this MPFF for the Unit 1 NSCW system was considered, the Maintenance Rule a(2) conclusion remained valid.
 
===3. Cross-Reference to PI&R Findings Documented Elsewhere===
 
Section 4OA5.1 describes a violation for failure to implement effective corrective actions for in an inadequate containment closeout inspections which could have affected the post-accident recirculation function of the residual heat removal (RHR) system.
 
{{a|4OA3}}
==4OA3 Event Follow-up==
 
===1. (Closed) Licensee Event Report (LER) 05000425/2003001-01: Technical Specification===
 
Required Shutdown Not Performed Following Issuance of Notice of Enforcement Discretion (NOED)(Rev. 1)
This condition was previously discussed in NRC Integrated Inspection Report 05000424,425/2004003. This LER revision provided additional information related to the root cause. The cause of the event was found to be a failure of a reset pushbutton in the test circuitry and not a failure of the memories logic test switch as was originally presumed. No new findings of significance were identified. This issue was documented in the licensees corrective action program as CR 2003003186.
 
===2. (Closed) LER 05000425/2004002-00: Containment Debris Could Have Resulted in Loss===
 
of Safety System Function The inspectors reviewed the LER and CR 2004002140 to verify the accuracy of the LER and the appropriateness of the corrective actions. No new findings of significance were identified. This issue was previously documented in Integrated Inspection Report 05000424, 425/2004004. The regulatory significance of this issue is discussed in Section 4OA5.1.
 
{{a|4OA5}}
==4OA5 Other Activities==
 
===1. (Closed) Apparent Violation (AV) 05000425/2004004-02, Failure to Adequately Perform===
 
Containment Closeout Inspection   
 
=====Introduction.=====
A Green non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, was identified for failure to implement effective corrective actions to ensure loose debris that could affect the post-accident recirculation function of the RHR system was removed from containment.
 
=====Description.=====
This apparent violation was initially documented in NRC Integrated Inspection Report 05000424, 425/2004004 as a failure to follow procedure with a potential safety significance greater than Green. Upon further review, the inspectors determined that the failure to remove loose debris from the Unit 2 containment was a result of not implementing effective corrective actions for a similar Unit 1 condition documented in LER 05000424/2003001-00 and dispositioned as NCV 05000424/2003005-02.
 
=====Analysis.=====
Since this condition had a potential safety significance greater than Green, a regional Senior Reactor Analyst performed a Phase III significance determination analysis to determine the actual safety significance. The Phase III analysis considered the loss-of-coolant accidents (LOCAs) (small, medium or large) that could dislodge un-jacketed steam generator insulation. This was due to the key assumption that both the loose debris and the steam generator insulation were necessary to lose the RHR recirculation safety function. Considering the three dominant accident sequences and the actual plant condition and exposure time, this finding was determined to be of very low safety significance. The direct cause of this finding involved the cross-cutting area of Identification and Resolution of Problems.
 
=====Enforcement.=====
10 CFR Part 50, Appendix B, Criterion XVI (Corrective Action), requires, in part, that significant conditions adverse to quality are corrected to prevent recurrence.
 
Contrary to the above, on May 11, 2004, the licensee failed to implement effective corrective actions for an inadequate Unit 1 containment closeout inspection which resulted in leaving loose debris in Unit 2 containment. Because the violation is of very low safety significance and has been entered into the licensees corrective action program as CR 2004002140, this violation is being treated as an NCV in accordance with Section VI.A of the NRC Enforcement Policy: NCV 05000425/2004005-01, Failure to Implement Effective Corrective Actions For Containment Closeout Inspections.
 
===2. World Association of Nuclear Operators (WANO) Assessment Report Review===
 
====a. Inspection Scope====
The inspectors reviewed the final report of the WANO assessment of site activities conducted in March 2004. The inspectors reviewed the report to ensure that issues identified were consistent with the NRC perspectives of licensee performance and if any significant safety issues were identified that needed further NRC followup.
 
====b. Findings====
No findings of significance were identified.
{{a|4OA6}}
==4OA6 Meetings, Including Exit==
 
On September 30, 2004, the resident inspectors presented the inspection results to Mr.
 
W. Kitchens and other members of his staff who acknowledged the findings. The inspectors confirmed that proprietary information was not provided or examined during the inspection.
 
ATTACHMENT:
 
=SUPPLEMENTAL INFORMATION=
 
==KEY POINTS OF CONTACT==
 
===Licensee personnel===
:
: [[contact::W. Bargeron]], Plant Support Assistant General Manager
: [[contact::R. Brown]], Training and Emergency Preparedness Manager
: [[contact::C. Buck]], Chemistry Manager
: [[contact::W. Burmeister]], Manager Engineering Support
: [[contact::S. Douglas]], Manager Operations
: [[contact::K. Dyar]], Security Manager
: [[contact::K. Holmes]], Performance Analysis Supervisor
: [[contact::W. Kitchens]], Nuclear Plant General Manager
: [[contact::I. Kochery]], Health Physics Manager
: [[contact::T. Tynan]], Assistant General Manager Operations
: [[contact::D. Vineyard]], Work Control Superintendent
===NRC personnel===
:
: [[contact::B. Bonser]], Chief, Region II Reactor Project Branch 2
: [[contact::W. Rodgers]], Senior Risk Analyst, Region II
 
==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==
 
===Opened and Closed===
: 05000425/2004005-01          NCV    Failure to Implement Effective Corrective Actions For Containment Closeout Inspections (Section 4OA5.1)
 
===Closed===
: 05000425/2003001-01          LER    Technical Specification Required Shutdown Not Performed Following Issuance of NOED (Section 4OA3.1)
: 05000425/2004002-00          LER    Containment Debris Could Have Resulted in Loss of Safety System Function (Section 4OA3.2)
: 05000425/2004004-02          AV    Failure to Adequately Perform Containment Closeout Inspection (Section 4OA5.1)
 
==LIST OF DOCUMENTS REVIEWED==
 
}}

Latest revision as of 01:09, 16 March 2020

IR 05000424-04-005 and 05000425-04-005, on 06/27/2004 - 09/25/2004; Voglte Electric Generating Plant
ML042960165
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 10/15/2004
From: Brian Bonser
Division Reactor Projects II
To: Grissette D
Southern Nuclear Operating Co
References
IR-04-005
Download: ML042960165 (20)


Text

ber 15, 2004

SUBJECT:

VOGTLE ELECTRIC GENERATING PLANT - NRC INTEGRATED INSPECTION REPORT 05000424/2004005 AND 05000425/2004005

Dear Mr. Grissette:

On September 25, 2004, 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 results, which were discussed on September 30, 2004, with Mr. William Kitchens and other members of your staff.

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

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

This report documents one NRC-identified finding of very low safety significance (Green) which was determined to involve a violation of NRC requirements. However, because of the very low safety significance and because it has been entered into your corrective action program, the NRC is treating this violation as a non-cited violation (NCV) consistent with Section VI.A of the NRC Enforcement Policy. If you contest the NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the United States 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 Vogtle.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or

SNC 2 from the Publicly Available Records (PARS) component of NRCs document system (ADAMS).

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

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

Enclosure:

Inspection Report 05000424/2004005 and 05000425/2004005 w/Attachment: Supplemental Information

REGION II==

Docket Nos.: 50-424, 50-425 License Nos.: NPF-68, NPF-81 Report Nos.: 05000424/2004005 and 05000425/2004005 Licensee: Southern Nuclear Operating Company, Inc. (SNC)

Facility: Vogtle Electric Generating Plant Location: 7821 River Road Waynesboro, GA 30830 Dates: June 27, 2004 - September 25, 2004 Inspectors: G. McCoy, Senior Resident Inspector T. Morrissey, Resident Inspector J. Zeiler, Senior Resident Inspector, V. C. Summer J. Baptist, Project Engineer (Section 1R06)

L. Mellon, Senior Operations Engineer (Section 4OA1)

Approved by: Brian R. Bonser, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000424/2004-005, 05000425/2004-005; 06/27/2004 - 09/25/2004; Vogtle Electric

Generating Plant, Units 1 and 2; Other Activities.

The report covered a three-month period of inspection by resident inspectors and announced inspections by a senior operations engineer and a project engineer. One Green non-cited violation (NCV) was identified. The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.

NRC-Identified and Self-Revealing Findings

Cornerstone: Mitigating Systems

Green.

A non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion XVI,

Corrective Action, was identified for failure to implement effective corrective actions to ensure loose debris that could affect the post-accident recirculation function of the residual heat removal system was removed from containment.

Since this condition had a potential safety significance greater than Green, a regional Senior Reactor Analyst performed a Phase III significance determination analysis to determine the actual safety significance. The Phase III analysis considered the loss-of-coolant accidents (LOCAs) (small, medium or large) that could dislodge un-jacketed steam generator insulation. This was due to the key assumption that both the loose debris and the steam generator insulation were necessary to lose the RHR recirculation safety function. Considering the three dominant accident sequences and the actual plant condition and exposure time, this finding was determined to be of very low safety significance. The direct cause of this finding involved the cross-cutting area of Identification and Resolution of Problems. (Section 4OA5.1)

Licensee-Identified Violations

None.

REPORT DETAILS

Summary of Plant Status

Unit 1 operated at essentially full rated thermal power (RTP) throughout the inspection period.

Unit 2 operated at essentially full RTP until July 31, 2004, when power was reduced to approximately 87 percent RTP due to a small reactivity anomaly. The licensee concluded that the anomaly was most likely due to one or two neutron absorber rods separating from a rod cluster control assembly (RCCA). On August 6, the unit was shutdown to verify full insertion capability of all control rod assemblies. On August 7, the unit was restarted and operated at essentially full RTP for the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

1R01 Adverse Weather Protection

a. Inspection Scope

Adverse Weather Preparation Review. On August 12 and September 3, the inspectors reviewed licensee procedure 11889-C, Severe Weather Checklist, to verify the licensee had implemented actions to prepare the plant site for predicted severe weather conditions of high winds and heavy rain. The inspectors walked down various site areas to verify the licensees ability to respond to predicted adverse weather conditions.

b. Findings

No findings of significance were identified.

1R04 Equipment Alignment

a. Inspection Scope

Partial System Walk-downs. The inspectors performed partial walkdowns of the following three systems to verify correct system alignment while redundant or backup equipment was inoperable or following return to service. The inspectors checked for correct valve and electrical power alignments by comparing positions of valves, switches, and breakers to the licensee procedures and drawings listed in the

. Additionally, the inspectors reviewed the condition report (CR) database to verify that equipment alignment problems were being identified and appropriately resolved.

  • 2A essential chilled water (ECW) system while 2B ECW system was out of service
  • 1B high head safety injection (HHSI) system while 1A HHSI pump was out of service

b. Findings

No findings of significance were identified.

1R05 Fire Protection

a. Inspection Scope

Fire Area Tours. The inspectors walked down the following nine plant areas to verify the licensee was controlling combustible materials and ignition sources as required by licensee procedures 92015-C, Use, Control, and Storage of Flammable/Combustible Materials, and 92020-C, Control of Ignition Sources. The inspectors assessed the observable condition of fire detection, suppression, and protection systems and reviewed the licensees fire protection Limiting Condition for Operation log and CR database to verify that the corrective actions for degraded equipment were identified and appropriately prioritized. The inspectors also reviewed the licensees fire protection program to verify the requirements of Updated Final Safety Analysis Report (UFSAR) Section 9.5.1, Fire Protection Program, and Appendix 9A, Fire Hazards Analysis, were met. Documents reviewed are listed in the Attachment.

  • 2A engineered safety feature (ESF) chiller and filter rooms
  • 1A nuclear service cooling water (NSCW) building and tunnels
  • 1B HHSI pump and valve rooms
  • 1B ESF chiller and filter rooms
  • 2A and 2B HHSI pump rooms
  • 2A cable spreading room

b. Findings

No findings of significance were identified.

1R06 Flood Protection

a. Inspection Scope

External Flood Review. The inspectors reviewed the licensees external flooding mitigation procedures and equipment to verify they were consistent with the licensees design requirements and risk analysis assumptions. The inspectors discussed external flooding preparation with engineering personnel to verify preparation and compensatory measures met the licensees design requirements and risk analysis assumptions. The inspectors checked selected external drain systems to verify the drains would function properly. The inspectors reviewed a sampling of CRs to verify the licensee was identifying and correcting problems associated with flood detection and protection of structures, systems and components (SSCs). Documents reviewed are listed in the

.

Internal Flood Review. The inspectors reviewed the UFSAR and Individual Plant Examination and walked down the following four areas which contained risk-significant SSCs below flood level to verify flood barriers were in place. Motor controllers and terminal boxes that could become potentially submerged were inspected to ensure that the sealing gasket material was intact and undamaged. The inspectors reviewed selected licensee alarm response procedures to verify alarm setpoints and setpoints for sump pump operation were consistent with the UFSAR, the setpoint index, and Technical Specifications (TS).

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification

a. Inspection Scope

Quarterly Resident Review. The inspectors evaluated operator performance on July 28, during licensed operator simulator training associated with Requalification Segment 20044. The simulator scenario began with failure of a pressurizer pressure instrument channel followed by a steam generator tube rupture and faulted steam generator. The inspectors assessed the following areas:

  • Correct use of licensee abnormal and emergency operating procedures including 18001-C, Primary Systems Instrumentation Malfunction;18009-C, Steam Generator Tube Leak; 19030-C, E-3 Steam Generator Tube Rupture; and 19020-C, E-2 Faulted Steam Generator Isolation
  • Ability to implement appropriate event reporting and emergency plan actions in accordance with licensee procedures 91001-C, Emergency Classification and Implementing Instructions, and 91002-C, Emergency Notifications
  • Ability to identify and implement appropriate TS actions
  • Clarity and formality of communications in accordance with licensee procedure 10000-C, Conduct of Operations
  • Proper control board manipulations including critical operator actions
  • Quality of supervisory command and control
  • Effectiveness of post-evaluation critique

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed the following two equipment problems and associated licensee CRs to evaluate the effectiveness of the licensees handling of equipment performance problems and to verify the licensees maintenance efforts met the requirements of 10 CFR 50.65 (the Maintenance Rule) and licensee procedure 50028-C, Engineering Maintenance Rule Implementation. The inspectors assessed adequacy of the licensees failure characterization, establishment of performance criteria or 50.65 (a)(1)performance goals, and adequacy of corrective actions. Other documents reviewed during this inspection included control room logs, system health reports, the maintenance rule database, and maintenance work orders (MWOs). The inspectors interviewed system engineers and the maintenance rule coordinator to assess the accuracy of identified performance deficiencies and the extent of condition.

  • 2A digital sequencer failure (CR 2004002015)

b. Findings

No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Evaluation

a. Inspection Scope

The inspectors reviewed the following six MWOs to verify plant risk was properly assessed by the licensee prior to conducting the activities. The inspectors reviewed risk assessments and risk management controls implemented for these activities to verify they were completed in accordance with licensee procedure 00354-C, Maintenance Scheduling, and 10 CFR 50.65(a)(4). The inspectors also reviewed the CR database to verify that maintenance risk assessment problems were being identified at the appropriate level, entered into the corrective action program, and appropriately resolved.

  • 1A MDAFW pump miniflow valve outage (MWO 10402184)
  • 1A HHSI pump outage (MWOs 10402286 and 10302363)
  • 2A CREFS outage (MWOs 20402088, 20302936 and 20301815)
  • 1B MDAFW pump miniflow valve outage (MWO 10402739)
  • 1B ECW system outage (MWOs 10301826, 10203066, 10402061 and 10400120)

b. Findings

No findings of significance were identified.

1R14 Operator Performance During Non-Routine Plant Evolutions

a. Inspection Scope

For the two non-routine plant evolutions described below, the inspectors reviewed the operating crews performance, reviewed operator logs, control board indications, and plant computer data to verify that operator response was in accordance with the associated plant procedures.

  • July 31, Unit 2 reactivity anomaly
  • August 6, Unit 2 shutdown and subsequent startup in accordance with licensee procedures 12004-C, Power Operation (Mode 1), 12005-C, Reactor Shutdown to Hot Standby (Mode 2 to Mode 3) and 12003-C, Reactor Startup (Mode 3 to Mode 2)

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the following five evaluations to verify they met the requirements of licensee Nuclear Management Procedure (NMP)-GM-002, Corrective Action Program, and NMP-002-GL02, Corrective Action Program Details and Expectations Guideline. This scope included an assessment of the technical adequacy of the evaluations, the adequacy of compensatory measures, and the impact on continued plant operation.

  • 2A ECW system relief valve 2PSV22404 leakage (CR 2004002711)
  • Unit 2 reactivity anomaly (CR 2004003225)
  • Unit 1 electrical penetration loss of gas pressure (CR 2004003514)
  • Unit 2 replacement of the thermocouple selector switch on the 2B EDG (WO 20400540)
  • Unit 2 auxiliary relay room ESF cooler flowrate higher than recommended (CR 2004003822)

b. Findings

No findings of significance were identified.

1R16 Operator Workarounds

a. Inspection Scope

The inspectors reviewed the licensees list of identified operator workarounds and burdens to determine whether any items would adversely affect the operators ability to implement abnormal or emergency operating procedures. Additionally, the inspectors reviewed Unit 1 and Unit 2 control room logs, caution tag logs, abnormal configuration logs, MWOs, and the clearance and tagging database, to identify any abnormal plant equipment configurations that might be considered operator workarounds, and to verify the licensee was identifying and documenting operator workarounds in accordance with licensee procedure 10025-C, Work Around Program. The inspectors also assessed the cumulative effects of any potential operator workarounds on the operators ability to effect a correct and timely response to plant transients and events.

b. Findings

No findings of significance 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 was sufficient to meet the TS operability requirements.

  • 1A MDAFW pump miniflow valve outage (MWO 10402184)
  • 1A HHSI pump outage (MWOs 10402286 and 10302363)
  • 1A CREFS outage (MWOs 10200290, 10302585 and 10402637)
  • 2A CREFS outage (MWOs 20402088, 20302936 and 20301815)
  • 2A Group 1 room coolers (containment spray (CS) and component cooling water)outage (MWOs 20401772, 20401778, 20301863 and 20301865)
  • 1B ECW system outage (MWOs 10301826, 10203066, 10402061 and 10400120)

b. Findings

No findings of significance were identified.

1R20 Refueling and Other Outage Activities

a. Inspection Scope

On August 6, the licensee initiated a shutdown to Mode 3 to verify control rod operability. The inspectors reviewed the outage plans to confirm that the licensee had appropriately considered risk in developing and implementing the plans. During the outage, the inspectors observed or reviewed portions of the outage activities and preparations for unit restart to verify these activities were conducted in accordance with TS and licensee procedures.

b. Findings

No findings of significance were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors reviewed the following six licensee 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

  • 14420-2, Solid State Protection System and Reactor Trip Breaker Train A Operability Test
  • 14980A-1, Diesel Generator Operability Test (1A, Fast start)
  • 28820-C, 2CD1CB Battery Charger Load Test In-Service Tests
  • 14808-1, Centrifugal Charging Pump and Check Valve IST and Response Time Test (1A, IST portion only).

RCS Leak Detection Systems

  • 14905-2, RCS Leakage Calculation (Inventory Balance)

b. Findings

No findings of significance were identified.

1R23 Temporary Plant Modifications

a. Inspection Scope

The inspectors evaluated the following Temporary Modification (TM) and associated 10 CFR 50.59 screening against the system design basis documentation and UFSAR to verify that the modifications did not adversely affect the safety functions of important safety systems. Additionally, the inspectors assessed if the modification was developed and implemented in accordance with licensee procedure 00307-C, Temporary Modifications.

  • TM 2003-V1T061, Temporarily lift lead from safety injection system valve 1HV8806B to the system status monitoring panel.

b. Findings

No findings of significance were identified.

Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation

a. Inspection Scope

On August 26, the licensee conducted an emergency drill involving a seismic event followed by a loss of coolant accident with an unmonitored reactivity release pathway to the environment through a failed purge supply isolation damper. The inspectors observed the drill to verify the licensee was properly classifying emergency events, making the required notifications, and making appropriate protective action recommendations in accordance with licensee procedures 91001-C, Emergency Classification and Implementing Instructions; 91002-C, Emergency Notifications; and 91305-C, Protective Action Guidelines.

b. Findings

No findings of significance were identified.

OTHER ACTIVITIES

4OA1 Performance Indicator (PI) Verification

a. Inspection Scope

The inspectors sampled licensee submittals for the PIs listed below to verify the accuracy of the PI data reported during the indicated period. The PI definitions and guidance contained in licensee procedures 00163-C, NRC Performance Indicator Preparation and Submittal, and 50025-C, Reporting of Mitigating System Performance Indicator Unavailability, and NEI 99-02, Regulatory Assessment Indicator Guideline, Rev. 2, were used to verify the basis in reporting for each data element.

Mitigating Systems Cornerstone

  • Safety System Unavailability - Emergency AC Power The inspectors reviewed operator log entries, maintenance rule database, monthly operating reports, monthly PI Summary reports, and NRC inspection reports for the PI data submitted by the licensee for both Unit 1 and Unit 2 during the period from July 2003 through June 2004.

Emergency Preparedness Cornerstone

  • Emergency Response Organization (ERO) Drill/Exercise Performance
  • ERO Drill Participation
  • Alert and Notification System Reliability The inspectors assessed the accuracy of the PI for ERO drill and exercise performance (DEP) over the past eight quarters through review of a sample of drill and exercise records. The inspector assessed the accuracy of the PI for ERO drill participation during the previous eight quarters for personnel assigned to key positions in the ERO.

The inspector assessed the accuracy of the PI for the alert and notification system reliability through review of a sample of the licensees records of the complete cycle tests.

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems

1. Daily Screening of Corrective Action Items

a. Inspection Scope

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 licensees corrective action program. This review was accomplished by either attending daily screening meetings that briefly discussed major CRs or accessing the licensees computerized corrective action database and reviewing each CR that was initiated.

b. Findings and Observations

No findings of significance were identified.

2. Annual Sample Review.

a. Inspection Scope

The inspectors reviewed two issues to evaluate the effectiveness of the licensees corrective actions for important safety issues documented in CRs 2004000682 and 2004000810. The condition reports were associated with a failure of inverter 1BD1I12 and 1B CS pump motor cooler flow less than the acceptable flow range. The inspectors assessed whether the issue was identified in a timely manner; documented accurately and completely; properly classified and prioritized; adequately considered extent of condition, generic implications, common cause, and previous occurrences; adequately identified root causes/apparent causes; and, identified appropriate corrective actions.

Also the inspectors verified the issue was processed in accordance with licensee procedure NMP-GM-002-GL02, Corrective Action Program Details and Expectation Guideline.

b. Findings and Observations

No findings of significance were identified.

CR 200400682 - The inspectors noted that the licensees review was thorough and the corrective actions were appropriate.

CR 200400810 - The inspectors identified that the functional failure was maintenance preventable. The issue was re-reviewed by the licensee who agreed that it should have been classified as a maintenance preventable functional failure (MPFF) and CR 2004003160 was initiated. Since the issue was a MPFF, CR 2004003160 was assigned a severity level 2 which requires more senior management review than the original severity level 3 CR. When this MPFF for the Unit 1 NSCW system was considered, the Maintenance Rule a(2) conclusion remained valid.

3. Cross-Reference to PI&R Findings Documented Elsewhere

Section 4OA5.1 describes a violation for failure to implement effective corrective actions for in an inadequate containment closeout inspections which could have affected the post-accident recirculation function of the residual heat removal (RHR) system.

4OA3 Event Follow-up

1. (Closed) Licensee Event Report (LER) 05000425/2003001-01: Technical Specification

Required Shutdown Not Performed Following Issuance of Notice of Enforcement Discretion (NOED)(Rev. 1)

This condition was previously discussed in NRC Integrated Inspection Report 05000424,425/2004003. This LER revision provided additional information related to the root cause. The cause of the event was found to be a failure of a reset pushbutton in the test circuitry and not a failure of the memories logic test switch as was originally presumed. No new findings of significance were identified. This issue was documented in the licensees corrective action program as CR 2003003186.

2. (Closed) LER 05000425/2004002-00: Containment Debris Could Have Resulted in Loss

of Safety System Function The inspectors reviewed the LER and CR 2004002140 to verify the accuracy of the LER and the appropriateness of the corrective actions. No new findings of significance were identified. This issue was previously documented in Integrated Inspection Report 05000424, 425/2004004. The regulatory significance of this issue is discussed in Section 4OA5.1.

4OA5 Other Activities

1. (Closed) Apparent Violation (AV)05000425/2004004-02, Failure to Adequately Perform

Containment Closeout Inspection

Introduction.

A Green non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, was identified for failure to implement effective corrective actions to ensure loose debris that could affect the post-accident recirculation function of the RHR system was removed from containment.

Description.

This apparent violation was initially documented in NRC Integrated Inspection Report 05000424, 425/2004004 as a failure to follow procedure with a potential safety significance greater than Green. Upon further review, the inspectors determined that the failure to remove loose debris from the Unit 2 containment was a result of not implementing effective corrective actions for a similar Unit 1 condition documented in LER 05000424/2003001-00 and dispositioned as NCV 05000424/2003005-02.

Analysis.

Since this condition had a potential safety significance greater than Green, a regional Senior Reactor Analyst performed a Phase III significance determination analysis to determine the actual safety significance. The Phase III analysis considered the loss-of-coolant accidents (LOCAs) (small, medium or large) that could dislodge un-jacketed steam generator insulation. This was due to the key assumption that both the loose debris and the steam generator insulation were necessary to lose the RHR recirculation safety function. Considering the three dominant accident sequences and the actual plant condition and exposure time, this finding was determined to be of very low safety significance. The direct cause of this finding involved the cross-cutting area of Identification and Resolution of Problems.

Enforcement.

10 CFR Part 50, Appendix B, Criterion XVI (Corrective Action), requires, in part, that significant conditions adverse to quality are corrected to prevent recurrence.

Contrary to the above, on May 11, 2004, the licensee failed to implement effective corrective actions for an inadequate Unit 1 containment closeout inspection which resulted in leaving loose debris in Unit 2 containment. Because the violation is of very low safety significance and has been entered into the licensees corrective action program as CR 2004002140, this violation is being treated as an NCV in accordance with Section VI.A of the NRC Enforcement Policy: NCV 05000425/2004005-01, Failure to Implement Effective Corrective Actions For Containment Closeout Inspections.

2. World Association of Nuclear Operators (WANO) Assessment Report Review

a. Inspection Scope

The inspectors reviewed the final report of the WANO assessment of site activities conducted in March 2004. The inspectors reviewed the report to ensure that issues identified were consistent with the NRC perspectives of licensee performance and if any significant safety issues were identified that needed further NRC followup.

b. Findings

No findings of significance were identified.

4OA6 Meetings, Including Exit

On September 30, 2004, the resident inspectors presented the inspection results to Mr.

W. Kitchens and other members of his staff who acknowledged the findings. The inspectors confirmed that proprietary information was not provided or examined during the inspection.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

W. Bargeron, Plant Support Assistant General Manager
R. Brown, Training and Emergency Preparedness Manager
C. Buck, Chemistry Manager
W. Burmeister, Manager Engineering Support
S. Douglas, Manager Operations
K. Dyar, Security Manager
K. Holmes, Performance Analysis Supervisor
W. Kitchens, Nuclear Plant General Manager
I. Kochery, Health Physics Manager
T. Tynan, Assistant General Manager Operations
D. Vineyard, Work Control Superintendent

NRC personnel

B. Bonser, Chief, Region II Reactor Project Branch 2
W. Rodgers, Senior Risk Analyst, Region II

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000425/2004005-01 NCV Failure to Implement Effective Corrective Actions For Containment Closeout Inspections (Section 4OA5.1)

Closed

05000425/2003001-01 LER Technical Specification Required Shutdown Not Performed Following Issuance of NOED (Section 4OA3.1)
05000425/2004002-00 LER Containment Debris Could Have Resulted in Loss of Safety System Function (Section 4OA3.2)
05000425/2004004-02 AV Failure to Adequately Perform Containment Closeout Inspection (Section 4OA5.1)

LIST OF DOCUMENTS REVIEWED