IR 05000424/2018003

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Nuclear Regulatory Commission Integrated Inspection Report 05000424/2018003 and 05000425/2018003
ML18317A424
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 11/09/2018
From: Alan Blamey
NRC/RGN-II/DRP/RPB2
To: Myers D
Southern Nuclear Operating Co
References
EA-17-166 IR 2018003
Download: ML18317A424 (23)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION ber 9, 2018

SUBJECT:

VOGTLE ELECTRIC GENERATING PLANT - NUCLEAR REGULATORY COMMISSION INTEGRATED INSPECTION REPORT 05000424/2018003 AND 05000425/2018003

Dear Mr. Myers:

On September 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Vogtle Electric Generating Plant, Units 1 and 2. On October 22, 2018, the NRC inspectors discussed the results of this inspection with Mr. Daniel Komm and other members of your staff. The results of this inspection are documented in the enclosed report.

NRC inspectors documented one licensee identified violation (LIV) in this report that involved a violation of NRC requirements and was determined to be of very low safety significance.

If you contest the violation or significance of the finding, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC resident inspector at the Vogtle Electric Generating Plant, Units 1 and 2. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Alan Blamey, Chief Reactor Projects Branch 2 Division of Reactor Projects Docket Nos.: 50-424, 50-425 License Nos.: NPF-68 and NPF-81

Enclosure:

Inspection Report 5000424/2018003 and 05000425/2018003

Inspection Report

Docket Numbers: 50-424, 50-425 License Numbers: NPF-68, NPF-81 Report Numbers: 05000424/2018003; and 05000425/2018003 Enterprise Identifier: I-2018-003-0039 Licensee: Southern Nuclear Operating Company, Inc.

Facility: Vogtle Electric Generating Plant, Units 1 and 2 Location: Waynesboro, GA 30830 Inspection Dates: July 1, 2018 through September 30, 2018 Inspectors: M. Endress, Senior Resident Inspector A. Alen, Resident Inspector G. Ottenberg, Senior Reactor Inspector N. Lacy, Operations Inspector Approved By: A. Blamey, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure

SUMMARY

The NRC continued monitoring the licensees performance by conducting a quarterly inspection at Vogtle Electric Generating Plant Units 1 and 2 in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to http://www.nrc.gov/NRR/OVERSIGHT/ASSESS/index.html for more information. NRC and self-revealed findings, violations, and additional items are summarized in the table below.

List of Findings and Violations Licensee Identified Non-Cited Violation 71152 This violation of very low safety significant was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a Non-Cited Violation, consistent with Section 2.3.2 of the Enforcement Policy.

10 CFR Part 50.54(q)(2), required, in part, the licensee shall follow and maintain the effectiveness of its emergency plan that meet the standards of 10 CFR 50.47(b). 10 CFR 50.47(b)(4), required, in part, a standard emergency classification and action level scheme, the bases of which include facility and system effluent parameters, is in use by the nuclear facility licensee. Contrary to the above, from January 30, 2018 to July 20, 2018, the licensee failed to maintain the effectiveness of its emergency plan. Specifically, Units 1 and 2 procedure 19200, F-O Critical Safety Function Status Tree, version 1.0, specified over-conservative reactor coolant system (RCS) temperature values for determining a critical safety function RED Path on RCS Integrity used to evaluate emergency classification FA1 (Alert), potential loss of RCS barrier, in response to a rapid RCS cooldown event.

Type Issue number Title Report Status Section Severity 05000424,425/2017012-01 Failure to provide complete 92702 Closed Level III and accurate information Problem, for system operator rounds.

Notice of Enforcement Action Violation (EA)-17-166 Unresolved 05000424, 425/2017009-02 Potential Lack of Thermal 71111.21N Closed Item Aging to End-of-Life (URI) Condition for Outside Containment Limitorque Actuator

PLANT STATUS

Unit 1 began the quarter at or near 100 percent rated thermal power (RTP). On July 3, 2018, Unit 1 tripped due to a rise in steam generator level on loop #2. Unit 1 returned to 100 percent RTP on July 6, 2018 where it remained until September 16, 2018 when it was taken off line for a refueling outage. The unit remained shutdown for the remainder of the quarter.

Unit 2 operated at or near 100 percent RTP for the entire inspection period.

INSPECTION SCOPES

Inspections were conducted using the inspection procedure (IP) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met. The inspectors performed plant status activities described in Inspection Manual Chapter (IMC) 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution.

The inspectors used the Commissions rules and regulations as the criteria for determining compliance along with established licensee standards as the criteria for assessing licensee performance.

REACTOR SAFETY

71111.01 - Adverse Weather Protection Impending Severe Weather

The inspectors evaluated readiness for impending adverse weather conditions for Hurricane Florence on September 6, 2018.

71111.04 - Equipment Alignment Partial Walkdown

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Unit 1 A and B motor-driven (MD) auxiliary feedwater (AFW) trains due to the C train (i.e. turbine-driven (TD) AFW pump) being out-of-service (OOS) for planned maintenance on July 2, 2018
(2) Unit 1 B safety injection train and associated emergency safety feature (ESF) room cooler due to the A train being OOS for planned maintenance on July 31, 2018
(3) Unit 1 A coolant charging pump (CCP) due to the B train CCP system outage on August 14, 2018

71111.05 - Fire Protection Annual/Quarterly Quarterly Inspection

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Unit 2 cable spreading room, fire zones 94, 95, 173, 174, 120, and 121.
(2) Unit 2 Level A east and west penetration areas, fire zones 87, 88, 89, 90, 93, 102, 158, and 159.
(3) Unit 2 residual heat removal (RHR) pump and containment spray (CS) pump rooms, fire zones 4, 5, 9, and 10.
(4) Unit 2 north and south main steam valve house, fire zones 45, 99, and 104.
(5) Unit 1 containment building, fire zones 140 A/B/C/E.

Annual Inspection (1 Sample)

The inspectors evaluated fire brigade performance on July 13, 2018.

71111.06 - Flood Protection Measures Internal Flooding

The inspectors evaluated internal flooding mitigation protections in the auxiliary feedwater pump house for Unit 1 and Unit 2 on August 13 and 14, 2018.

71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification

The inspectors observed and evaluated two simulator training scenarios and one Drill/Exercise performance (DEP) simulator scenario administered to an operating crew on August 15, 2018 and August 22, 2018. The simulator training scenarios involved placing RHR in service following unit refueling shutdown and RHR evolutions while mitigating various malfunctions (e.g. RCS leakage and loss of offsite power) while operating at reduced inventory (i.e. mid-loop). The DEP scenario V-RQ-SE-09601, consisted of a fuel handling event in the spent fuel pool requiring emergency classification and declaration due to fuel damage and resulting radiation levels. The observation on August 22, 2018, was conducted to observe corrections made as a result of licensee identified deficiencies from the August 15, 2018 evolution.

Operator Performance (2 Samples)

The inspectors observed and evaluated operator performance in the main control room during a Unit 1 A emergency diesel generator (EDG) hot restart test on August 20, 2018, and during a Unit 1 shutdown and cooldown to 400 degrees on September 16, 2018.

71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Unit 1 nuclear service cooling water (NSCW) pump #2 maintenance rule unavailability criteria exceeded (condition report (CR) 10525762)

Quality Control (1 Sample)

The inspectors evaluated maintenance and quality control activities associated with the following equipment performance issues:

(1) Unit 1 B EDG motherboard replacement on September 4, 2018

71111.13 - Maintenance Risk Assessments and Emergent Work Control

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Unit 1, risk assessment for entering Mode 2 from Mode 3 on July 4, 2018 while in Technical Specifications 3.7.9 Condition B for an Inoperable NSCW tower fan, CR

===10511936.

(2) Unit 1, GREEN risk profile for the week of July 30, 2018, due to A SI pump and ESF room cooler, A spent fuel pool cooling pump, and diesel fire pump no. 2 system outages.
(3) Unit 1, YELLOW outage risk assessment monitoring (ORAM) due to reduced power availability, containment, reactivity control and reactor coolant system reduced inventory on September 18 and 20, 2018
(4) Unit 1, B Train RHR system outage on August 6, 2018.
(5) Unit 1, A CCP outage with A train EDG operability run on August 20, 2018.
(6) Unit 1, A Train RHR system outage on August 27, 2018.
(7) Unit 1, YELLOW risk profile for A train outage with A EDG, A train NSCW, and A train sequencer out of service (OOS) on September 25, 2018.

71111.15 - Operability Determinations and Functionality Assessments

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Unit 1, Main control room emergency light fixtures missing seismic restraints, on July 18, 2018, CR 10490617.
(2) Unit 1 and Unit 2, Immediate determination operability (IDO) performed for the auxiliary feedwater system due to an error in the internal flooding calculation analysis, on August 21, 2018,, CR10527587.
(3) Unit 1 and 2, IDO performed for the EDGs due to 24-hr endurance surveillance not conducted as close as practicable to design bases reactive loading, on July 23, 2018, CR10518082
(4) Unit 1, B EDG ESF fans found not lubricated on July 10, 2018, CR10513164.
(5) Unit 1, IDO performed for 1B RHR motor heater circuit low current on August 6, 2018, CR10522530.
(6) Unit 2, IDO performed for gas void being detected on safety injection system at point S-146 on August 28, 2018, CR10529533.

71111.18 - Plant Modifications

The inspectors evaluated the following temporary or permanent modifications:

(1) Unit 1 and Unit 2, Isolation of NSCW corrosion coupon racks, 1-DT-12-1202-00404, Ver. 2.0.

71111.19 - Post Maintenance Testing

The inspectors evaluated the following post maintenance tests:

(1) 14803A-2, Unit 2 component cooling water (CCW) pump no. 3 test (Section 5.2) on July 25, 2018, following corrective maintenance on pump seal water and bearing lube oil leaks.
(2) SNC695991, Unit 1 B train RHR system outage on August 6-7, 2018.
(3) SNC921789, Unit 2 NSCW Pump #6 motor replacement on August 12, 2018.
(4) SNC862561, Unit 1 B train EDG motherboard replacement outage and subsequent retest on September 4, 2018.
(5) SNC625311, Unit 1 A train EDG jacket water heater end cover replacement on September 25, 2018.

71111.20 - Refueling and Other Outage Activities

The inspectors evaluated the following outage activities:

(1) Unit 1: Refueling outage 1R21 activities from September 16-30, 2018.

71111.21N - Design Bases Assurance Inspection (Programs)

The inspectors evaluated environmental qualification program implementation by reviewing an unresolved item associated with the following component sample from July 1, 2018, to September 30, 2018:

Environmental Qualification (EQ) Program Components (URI Follow-up)

(1) HV1806, Limitorque Motor Actuator for Unit 1 A-train Containment Cooler Supply Valve

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Routine

(1) 14668A-2, Unit 2 Diesel Generator 24-hr Operability Test, on July 30-31, 2018.
(2) 14710A-1, Unit 1 Train A remote shutdown panel transfer switch and control circuit 18-month surveillance test, on August 29, 2018.

In-service Test (IST) ===

(1) 14810A-2, Unit 2 TDAFW Pump Operability, Response Time, and Check Valve IST (Sections 5.1 and 5.4), on July 19, 2018.

Containment Isolation Valve (2 Samples)

(1) 14378-1, Containment Penetration No. 78 Containment Sump Pumps Local Leak Rate Test on September 12, 2018.
(2) 14381-1, Containment Penetration No. 81 Containment Instrument Air Supply Line Local Leak Rate Test, on September 21,

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below for the period from July 1, 2017, through June 30, 2018, for both Units 1 and 2.

(1) MS07: High Pressure Injection System (2 Samples).
(2) MS08: Heat Removal System (2 Samples).
(3) MS09: RHR System (2 Samples).

71152 - Problem Identification and Resolution Annual Follow-up of Selected Issues

The inspectors reviewed the licensees implementation of its corrective action program related to the following issue:

(1) CR10517448, Calculation/procedure discrepancy for evaluation of RCS Integrity Critical Safety Function (CSF).

71153 - Follow-up of Events and Notices of Enforcement Discretion Events

(1) The inspectors evaluated plant and licensee response following a manual reactor trip of Unit 1 due to high steam generator water level on July 3,

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL 60855.1 - Operation of an Independent Spent Fuel Storage Installation The inspectors conducted a walkdown of the licensees independent spent fuel storage area and conducted a related log and record review on September 18, 2018.

92702 - Follow up on Traditional Enforcement Actions The inspectors performed this follow up inspection in accordance with Inspection Procedure 92702 to assess the licensees evaluation of the traditional enforcement (TE) Severity Level (SL)-III problem, notice of violation (NOV), associated with two NRC-identified apparent violations (AVs), Enforcement Action (EA)-17-166. The first AV involved the failure to conduct operator rounds, as required by 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings. The second AV involved the inaccurate/incomplete documentation of the data collected during operator rounds, as required by 10 CFR 50.9(a),

Completeness and Accuracy of Information. Additional details of the violations are documented in NRC Inspection Report 05000424/2018090 and 05000425/2018090 (ML18051A053). The inspection objectives were to:

(1) determine that adequate corrective actions have been implemented for the TE violation;
(2) verify that the root causes of these enforcement actions have been identified;
(3) determine if their generic implications have been addressed; and
(4) determine that the licensee's programs and practices have been appropriately enhanced to prevent recurrence.

In preparation for the inspection, the licensee performed a root cause determination (RCD),documented under corrective action report (CAR) 267393, to identify the root and contributing causes, organizational and programmatic weaknesses, extent of condition and extent of cause, that existed and resulted in the SL-III problem. The licensee also evaluated safety culture components and identified immediate corrective actions and corrective actions to prevent recurrence. The inspectors reviewed the licensees root cause, contributing causes, extent of condition, and extent of cause determinations. Inspectors assessed whether the licenses corrective actions to address the root and contributing causes were sufficient to prevent recurrence. The inspectors also held interviews and discussions with various licensee personnel to ensure that the root and contributing causes and the contribution of safety culture components were understood. The highlights of the performance review and NRCs assessment are documented below.

(1) Root Cause Analysis The inspectors concluded that the licensees RCD was generally effective in determining and evaluating the root and contributing causes resulting in the SL-III problem. The licensee used a systematic methodology incorporating various analysis methodologies; barrier analysis, event and causal factor analysis chart, process analysis, organizational and programmatic analysis, human performance fault tree, safety culture analysis, and evaluation of personal integrity significance factors. The following is a synopsis of the significant contributors and/or causes:

Root

Cause:
  • System operators willfully falsified operator rounds Contributing Causes:
  • Less than adequate (LTA) station leadership recognition of integrity issues;
  • LTA supervisory oversight of operator rounds; and
  • LTA recognition and follow-up of internal and external events related to integrity.

The inspectors determined that the licensees RCD included a consideration of prior internal and external occurrences of the problem and available operating experience (OE), addressed the extent of condition and the extent of cause of the issue, and included a proper consideration of whether a weakness in any safety culture component was a root cause or a significant contributing cause of the issue. The inspectors concluded that the RCD was conducted to a level of detail commensurate with the severity of the problem.

(2) Corrective Actions The licensee immediately initiated an investigation after the NRC notified station management, on October 25, 2016, that operators may have been falsifying operator round logs. On October 26, 2016, the licensee confirmed the NRCs concerns and proceeded with its investigation. With the investigation underway, the site Vice President communicated a station-wide message on the Meaning and value of your signature, operation managers conducted face-to-face briefings with each shift crew, involved system operator badges were placed in administrative hold, and shift managers began periodic accountability checks of monitored security door card readers.

The licensee initiated a root cause determination team that identified the following root cause and corresponding corrective actions to prevent recurrence (CAPR):

  • System operators willfully falsified operator rounds: As CAPRs, based on the results of the investigation and the recommendations of a disciplinary review board, the licensee terminated individuals determined to willfully falsify their rounds. Also, the licensee created a fleet procedure, NMP-AD-051, Work Verification, for random verification of records by performing periodic audits of operators, security officers, and fire watch rounds, as well as audits of other functional areas.

For contributing causes, the licensee developed corrective actions including, but not limited to:

  • Revision of corrective action program procedures to screen and evaluate for potential integrity issues.
  • Conduct independent assessments focusing on potential integrity issues.
  • Revision of Operations procedures to improve and clarify the operator rounds process and chain of command for system operators.
  • Revision of external OE evaluation procedures to require screening for potential integrity issues.
  • Annual communication to all current and future badged workers on the Importance of your Signature and Handwritten and Electronic Signatures have Equal Weight
  • Delivered a case study training of this issue/event to all station personnel.

The inspectors determined that corrective actions planned and implemented were appropriate to address the causes and prevent recurrence.

(3) Generic Implications Analysis The licensees RCD considered the extent of condition and extent of cause associated with the willful falsification of plant records. The licensee checked operator round logs versus timestamps on monitored security doors for all system operators for a period of approximately three months (August 1, 2016 to October 27, 2016). A total of 13 system operators were identified to have falsified operator rounds records. The licensee expanded their review to include fire watch and security officer rounds for the same period of time; no discrepancies were identified. For system operators determined to have willfully falsified their rounds the licensee reviewed other potential risk-significant falsifications that could have occurred when these operators were not being monitored or accompanied; no discrepancies were identified.

The licensee also performed an operating experience review. The RCD included an evaluation of internal and external OE, including consideration of prior occurrences and industry OE. As a result of this review, the licensee determined that the station recognition and follow up of internal and external events related to integrity was less than adequate (i.e. identified as a contributing cause). In particular, prior NRC correspondence in Generic Letter 93-03, Verification of Plant Records, was issued to alert the industry of potential for incomplete, inaccurate, and/or falsification of records (including operator rounds logs), and associated lessons learned. The licensee did not establish verification checks to evaluate for willful misconduct or falsification of system operators. Corrective actions were implemented to close this gap.

The inspectors concluded that the licensees RCD adequately addressed the generic implications of the issue in the extent of condition analysis, extent of cause analysis, and in their review of operating experience.

(4) Conclusion No findings were identified. Based on the above, the inspectors determined that corrective actions taken by the licensee addressed the SL-III problem NOV that was the basis for the follow up inspection. This violation is closed. (05000424, 425/2017012-01, Failure to provide complete and accurate information for system operator rounds.

(EA-17-166))

INSPECTION RESULTS

Licensee Identified Non-Cited Violation 71152 This violation of very low safety significant was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a Non-Cited Violation, consistent with Section 2.3.2 of the Enforcement Policy.

Violation: Title 10 CFR Part 50.54(q)(2), required, in part, the licensee shall follow and maintain the effectiveness of its emergency plan that meet the standards of 10 CFR 50.47(b).

10 CFR 50.47(b)(4), required, in part, a standard emergency classification and action level scheme, the bases of which include facility and system effluent parameters, is in use by the nuclear facility licensee. Contrary to the above, from January 30, 2018 to July 20, 2018, the licensee failed to maintain the effectiveness of its emergency plan. Specifically, Units 1 and 2 procedure 19200, F-O Critical Safety Function Status Tree, version 1.0, specified over-conservative reactor coolant system (RCS) temperature values for determining a critical safety function RED Path on RCS Integrity used to evaluate emergency classification FA1 (Alert), potential loss of RCS barrier, in response to a rapid RCS cooldown event.

Significance: The inspectors assessed the significance of this violation in accordance with NRC Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, dated September 22, 2015, and determined it was of very low safety significance (Green) because the deficient emergency classification process would result in an Alert over classification emergency, but would not result in unnecessary public protective measures.

Corrective Action References: The licensee entered this violation into the corrective action program as CR 10517448 and CAR 274471.

Unresolved Potential Lack of Thermal Aging to End-of-Life 71111.21N Item Condition for Outside Containment Limitorque (Closed) Actuator 05000424, 425/2017009-02

Description:

Vogtle Inspection Report 2017009 [ADAMS ML18024A566] identified an unresolved item (URI) related to a potential lack of thermal aging of the Limitorque actuators qualified under the environmental qualification (EQ) test programs described in Limitorque Test Reports B0003 and B0058. Since the URI was opened, the inspectors performed additional research into the site-specific EQ licensing basis documentation that pertains to this item. During their follow-up review, inspectors noted the following description regarding aging (section 3.11.3.3.5) in the Vogtle Unit 1 Supplement No. 5 to the Vogtle Safety Evaluation Report (NUREG-1137, SSER-5), dated January 1987:

The aging program requirements for Vogtle electrical equipment are defined in Category I of NUREG-0588. All degrading influences must be considered and included in the aging program. Justification for excluding preaging of equipment in type testing must be established on the basis of equipment design and application, or on state-of-the-art aging techniques. A qualified life is to be established for each equipment item.

As per SSER-5, section 3.11.2, the following constituted the NRCs review of the Vogtle EQ program:

To document the degree to which the environmental qualification program complies with the NRC environmental qualification requirements and criteria, the applicant provided equipment qualification information by letters dated September 13, 1985; May 30, July 31, August 22, September 19, October 31 (2 submittals), November 13, 14, and 26, December 4 (2 submittals) and 5 (3 submittals), 1986; and January 2, 1987, to supplement the information in FSAR Section 3.11.

The inspectors noted that the NRC staff evaluation of Vogtles EQ program and equipment included an onsite examination of some equipment, an audit of qualification documentation, and a review of the Vogtle submittals for completeness and acceptability of systems and components, qualification methods, and accident environments.

The Limitorque qualification described in test reports B0058 and B0003 relied on the provision described in Supplement No. 5 to the Vogtle Safety Evaluation Report for excluding pre-aging of the equipment during type testing. The inspectors determined that this provision had not been specifically reviewed by the NRC for the Limitorque actuator in question during original licensing review of the Vogtle EQ program. Specifically, the NRCs contractor, EG&G Idaho, Inc., transmitted the results of their audit to the NRC in a report, EGG-NTA-7403, dated October 31, 1986 (ADAMS accession number 8704300015) , which identified that their review was based on revision 2 of Vogtles Environmental Qualification Report, provided to the NRC in a submittal dated August 22, 1986. The EGG-NTA-7403 report, Appendix A, Table A-2, presented qualification deficiencies from the audit review, and identified that Vogtle stated in their submittal that qualifications based on Limitorque Test Report B0003 were incomplete, and the report further indicated that the EG&G Idaho reviewer did not specifically review the B0003 test report. Review of subsequent revisions to the Vogtle EQ report that were provided to the NRC in later submittals, determined that the qualification associated with the Limitorque B0003 test report was also supported by Limitorque test report B0058 and Bechtel calculation LAEQ-ES-002, which was identified as the source of the determination of the qualified life. The Bechtel calculation did not appear to have been reviewed specifically by the NRC or its contractor.

To inform closure of this URI, the inspector researched other similarly licensed facilities for any applicable determinations or deficiencies regarding the environmental qualification of the outside containment Limitorque alternating current motor actuator with class B insulation.

Based on the results of this review, the issue discussed in URI 05000424, 425/2017009-02

[ADAMS ML18024A566] is considered by the inspector to not represent a licensee performance deficiency or a violation of applicable regulatory requirements. The URI is closed.

Corrective Action Reference: CR

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

  • On September 7, 2018, the inspector presented the IP 92702 TE follow up inspection results the site Plant Manager, Mr. Daniel Komm, and other members of the licensee staff.
  • On October 22, 2018, the inspectors presented the quarterly resident inspector inspection results to Mr. Daniel Komm, and other members of the licensee staff.

DOCUMENTS REVIEWED

Section 71111.01: Adverse Weather Protection

Procedures

11889-C, Severe Weather Checklist, Ver. 26

NMP-OS-017, Severe Weather, Ver. 1.1

NMP-GM-021, Switchyard Access and Maintenance Controls

Corrective Action Program Records

Condition Reports (CRs)

10535326, Unit 2 LVSY Pullbox cover not secured

Section 71111.04: Equipment Alignment

Drawings

1X4DB121, Ver. 42.0, Unit 1 P&I Diagram - Safety Injection System - System No. 1204

1X4DB134, Ver. 31.0, Unit 1 P&I Diagram - Nuclear Service Water System - System No. 1202

1X4DB161-1, Ver. 46.0, Unit 1 P&I Diagram - Auxiliary Feedwater System Condensate Storage

& Degasifier System No. 1302

1X4DB161-2, Ver. 29.0, Unit 1 P&I Diagram - Auxiliary Feedwater System - System No. 1302

Other

Tagout 1-DT-18-1204-00233, Unit 1 B train safety injection pump/motor maintenance

Tagout 1-DT-18-1204-00233(001), Unit 1 B train safety injection motor cooler maintenance

Tagout 1-DT-18-1302-00194, Unit 1 TDAFW pump and steam supply isolation for maintenance

Section 71111.05: Fire Protection Annual/Quarterly

Procedures

29100-C, Portable Fire Extinguishers and Fire Hose Stations Visual Inspection, Version 62.11

2040-C, Fire Protection Operability and LCO Requirements, Rev. 46.0

2704-2, Zone 4, Auxiliary Building - Level D, Containment Spray Pump A Fire Fighting

Preplan, Rev. 2.0

2705-2, Zone 5, Auxiliary Building - Level D, Containment Spray Pump B Fire Fighting

Preplan, Rev. 3.0

2709-2, Zone 9, Auxiliary Building - Level D Fire Fighting Preplan, Rev. 2.2

2710-2, Zone 10, Auxiliary Building - Level D Fire Fighting Preplan, Rev. 2.2

2840A-1, Zone 140A, Containment Building - Levels A, B, 1, and 3 East Fire Fighting Preplan,

Rev. 4.0

2804-2, Zone 104, MSIV Room North Level 1 Fire Fighting Preplan, Rev. 4.1

2745-2, Zone 45, Auxiliary Building - Level 1 & 2 Fire Fighting Preplan, Rev. 1.2

2799-2, Zone 99, Control Building - Level A Fire Fighting Preplan, Rev 4.1

2794-2, Zone 94, Control Building - Level A Fire Fighting Preplan, Rev. 4.0

2795-2, Zone 95, Control Building - Level A, Train A Spreading Room Fire Fighting Preplan,

Rev. 5.0

2783-2, Zone 173, Control Building - Level A Fire Fighting Preplan, Rev. 1.2

2874-2, Zone 174, Control Building - Level A Fire Fighting Preplan, Rev. 1.2

2820-2, Zone 120, Control Building - Level 2 Fire Fighting Preplan, Rev. 6.0

2821-2, Zone 121, Control Building - Level 2 Fire Fighting Preplan, Rev. 6.0

2789-2, Zone 89, Control Building - Level A Fire Fighting Preplan, Rev. 3.1

2790-2, Zone 90, Control Building - Level A Fire Fighting Preplan, Rev. 2.2

2859-2, Zone 159, Control Building - Level A Fire Fighting Preplan, Rev. 1.2

2787-2, Zone 87, Control Building - Level A Fire Fighting Preplan, Rev. 2.2

2788-2, Zone 88, Control Building - Level A Fire Fighting Preplan, Rev. 2.2

2793-2, Zone 93, Control Building - Level A Fire Fighting Preplan, Rev. 3.2

2802-2, Zone 102, Control Building - Level A Fire Fighting Preplan, Rev. 2.2

2858-2, Zone 158, Control Building Level A Fire Fighting Preplan, Rev. 1.2

Section 71111.06: Flooding Protection Measures

Procedures

17016-1, Ver. 30, Annunciator Response Procedures for ALB 16 on Panel 2B1 on MCB

17016-2, Ver. 35.1, Annunciator Response Procedures for ALB 16 on Panel 2B1 on MCB

83304-C, Rev. 16.1, Check Valve Monitoring Program

Drawings

1X4DB161-2, Ver. 29.0, Unit 1 P&I Diagram - Auxiliary Feedwater System - System No. 1302

1X4DB146-3, Ver. 30.0, P&I Diagram, Auxiliary Building & Misc. Drains - System No. 1215

2X4DB146-3, Ver. 25.0, P&I Diagram, Auxiliary Building & Misc. Drains - System No. 1215

1X4DE316, Rev. 11 AFW Pump House and CST Equipment Location Layout

Calculations

X6CXC36, Ver. 7, Flooding Analysis - VNP Auxiliary Feedwater Pump house - Unit 1 and Unit 2

X6CXC17, Ver. 5, Flooding - Outside Areas, Auxiliary Feedwater Pump house

Work Orders

SNC10301089, Disassemble and inspect Unit1 AFW pump rooms drain check valves, 9/12/03

Miscellaneous

SCL00228, Auxiliary Feedwater Drain System Check Valve Inspection, Rev. 3

PMCR86549, Inactivate PM21215N5017 (Unit 2 TDAFW room drain line check valve PM)

Section 71111.11: Licensed Operator Requalification Program and Licensed Operator

Performance

Completed Procedures

14670A-1, Diesel Generator 1A Hot Restart Test, Ver. 1.4

Procedures

18004-C, Reactor Coolant System Leakage, Ver. 30.2

18006-C, Fuel Handling Event, Ver. 11

18019-C, Loss of Residual Heal Removal, Ver. 31.2

18031-1, Loss of Class 1E Electrical Systems, Ver. 1.2

NMP-EP-141-003-F01, Vogtle Unit 1 and Unit 2 -Initiating Condition Matrix COLD Conditions

(RCS 200 F), Ver. 1.0

NMP-EP-141-003, Vogtle Unit 1 and Unit 2 Emergency Action Levels and Basis, Ver. 3.0

NMP-EP-142-F01, Emergency Notification Form (ENF), Ver. 1.0

Other

V-RQ-SE-09601, Pre-Outage Review with DEP Opportunity, Ver. 2.5

Section 71111.12: Maintenance Effectiveness

Procedures:

NMP-ES-027, Maintenance Rule Program, Ver. 7

Diesel Generator Surveillance Manual - Gen-95, Instrument Calibrations/Inspections and

Generator/Engine Functional Test, Chapter 46, Ver. 19

NMP-AD-002, Problem Solving and Troubleshooting Guidelines, Ver. 12.0

NMP-GM-002-001, Corrective Action Program Instructions, Ver. 34.0

Work Orders

SNC862561, 1B EDG Motherboard Replacement, 9/4/18

Drawings

1X4AK01-20031, 1B EDG

Other

NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear

Power Plants, Rev. 4A

Section 71111.13: Maintenance Risk Assessments and Emergent Work Control

Procedures

NMP-GM-031-001, Online Maintenance Rule (a)(4) Risk Calculations, Ver. 3.0

Condition Reports

10511936, Trip of Unit 1 A train NSCW fan no. 1

Other

Unit 1 Phoenix Integrated Risk Reports for July 30 - August 21, 2018

Unit 1 Narrative Control Room Logs for July 30 - August 21, 2018

Unit 1 Daily Work Schedule for July 30 - August 21, 2018

Unit 1 Narrative Control Room Logs for July 30 - August 21, 2018

Unit 1 Daily Work Schedule for September 25, 2018

Unit 1 Narrative Control Room Logs for September 25, 2018

Unit 1 Outage Control Center Logs for September 25, 2018

10032-C, Outage Risk Assessment Monitoring, completed on 9/18/28 and 9/20/28 for

Unit 1 1R21

Section 71111.15: Operability Determinations and Functionality Assessments

Procedures

NMP-AD-012, Operability Determinations and Functionality Assessments, Ver. 13.1

Work Orders

1A EDG 18-month 24hr Surveillance 1B EDG 18-month 24hr Surveillance

SNC839165 (February 2018) SNC888629 (February 2016)

SNC687096 (July 2016) SNC693187 (August 2016)

SNC546950 (March/2015) SNC550751 (June 2015)

SNC420626 (October 2013) SNC425801 (October 2013)

2A EDG 18-month 24hr Surveillance 2B EDG 18-month 24hr Surveillance

SNC751976 (May 2017) SNC794504 (December 2017)

SNC590049 (November 2015) SNC620947 (December 2015)

SNC459933 (May 2014) SNC462382 (July 2014)

SNC361771 (October 2012) SNC364448 (December 2012)

Calculations

X6CXC36, Ver. 7, Flooding Analysis - VNP Auxiliary Feedwater Pump house - Unit 1 and Unit 2

X6CYC36, Ver. 7, Flooding Analysis - VNP Auxiliary Feedwater Pump house - Unit 2

Drawings

1X2D59A001, Ver. 9.0, Aux Feedwater Pump House Forming Plans Elev & Details

2X2D59A001, Ver. 7.0, Aux Feedwater Pump House Forming Plans Sections and Details

Condition Reports

10490617, 10527587, 10518082

Other

1X1AN03-00014, Control Room Ceiling Pyramid Pyramid Module, 4/11/83

AX1AN03-00027, Seismic Qualification Test Report for Control Room Suspended Ceiling,

August 25, 1980

PMCR86549, Inactivate PM21215N5017 (Unit 2 TDAFW room drain line check valve PM)

RER SNC964580, RER to Support AFW Pump house Flooding Calculation Error PDO, 8/27/18

DC-1018, Ver. 7.0, Pipe-Break Criteria - Interdisciplinary (Mechanical)

Section 71111.18: Plant Modifications

10CFR50.59 Evaluations

1-DT-12-1202-00404, Unit 1 and Unit 2, Isolation of NSCW corrosion coupon racks, Ver. 1.0

1-DT-12-1202-00404, Unit 1 and Unit 2, Isolation of NSCW corrosion coupon racks, Ver. 2.0

Modification Packages

DCR 91-V1N0045, Provide Corrosion and Deposition Monitoring for the NSCW System.

Procedures

35363-C, Chemistry Control of the NSCW System, Ver. 9.0

NMP-ES-063-GL03, Plant Vogtle License Renewal Program Manual, Ver. 1.1

Calculations

X4C1202V71, NSCW Flowrate for Break in Line to the NSCW Corrosion Monitors, Ver. 1.0

Drawings

1X4DB133-1, Ver. 55.0, Unit 1 P&I Diagram - Nuclear Service Cooling Water System - System

No. 1202

1X4DB192-1, Ver. 21.0, Unit 1 P&I Diagram - Nuclear Service Cooling Water Chem Injection

System and Chlorine Analysis System - System No. 1413

2X4DB192-1, Ver. 21.0, Unit 2 P&I Diagram - Nuclear Service Cooling Water Chem Injection

System and Chlorine Analysis System - System No. 1413

1X4DB192-2, Ver. 22.0, Unit 1 P&I Diagram - Nuclear Service Cooling Water Chem Injection

System and Chlorine Analysis System - System No. 1413

2X4DB192-2, Ver. 22.0, Unit 2 P&I Diagram - Nuclear Service Cooling Water Chem Injection

System and Chlorine Analysis System - System No. 1413

Other

NRC Information Notice 2012-01, Seismic Considerations - Principally Issues Involving Tanks,

January 26, 2012

NUREG-1137, Safety Evaluation Report Related to the Operation of Vogtle Electric Generating

Plant, Units 1 and 2, June 1985

NUREG-1801. Generic Aging Lessons Learned (GALL) Report - Tabulation of Results (Vol. 2)

September 2005

NUREG-1920, Safety Evaluation Report Related to the License Renewal of Vogtle Electric

Generating Plant, Units 1 and 2 (Vol 1), April 2009

Condition Reports

10440933, Failure to conduct a 50.59 evaluation for isolation of NSCW corrosion monitoring

system 520212

Section 71111.19: Post Maintenance Testing

Completed Procedures

14803A-2, Train A CCW Pumps and Check Valve IST and Response Time Tests (Section 5.2),

completed on 7/25/18

CR10518612, Unit 2 CCW #3 suction valve HV11801 hand wheel spins freely

Work Orders

SNC893644, Unit 2 CCW pump #3 seal water leak, 7/25/18

SNC942135, Unit 2 CCW pump #3 oil leak repairs, 7/25/18

SNC625003, Unit 2 CCW pump #3 inboard bearing oil replacement due to elevated particle

count, 7/25/18

SNC625002, Unit 2 CCW pump #3 outboard bearing oil replacement due to elevated particle

count, 7/25/18

SNC959049, 2HV11801 gearbox repairs, 7/25/18

Other

LCO/TR Number 2-2018-065i, CCW Pump #3 (21203P4003) Tagout/System Outage for

planned maintenance

Tagout 2-DT-18-1203-00146, Unit 2 CCW pump no. 3 seal pipe leak tagout

Tagout 2-DT-18-1203-00146, Unit 2 CCW pump no. 3 bearing lube oil leaks tagout

Section 71111.20: Refueling and Other Outage Activities

Procedures

271-1, AP1000 Refueling Machine Initialization Instructions, Ver.3.2

Section 71111.21N: Design Bases Assurance Inspection (Programs)

Licensing Basis Documents

ADAMS Acc. No. 8509170185, File X3BL01, Log GN-701, NRC Docket Numbers 50-424 and

50-425 Construction Permit Numbers CPPR-108 and CPPR-109 Vogtle Electric Generating

Plant - Units 1 and 2 SER Open Item 1: Equipment Qualification, dated 9/13/85

ADAMS Acc. No. 5906110145, File X7BC35, Log GN-926, NRC Docket Numbers 50-424 and

50-425 Construction Permit Numbers CPPR-108 and CPPR-109 Vogtle Electric Generating

Plant - Units 1 and 2 SER Open Item 1: Equipment Qualification, dated 5/30/86

File X7N00-25, Log GN-1071, NRC Docket Numbers 50-424 and 50-425 Construction Permit

Numbers CPPR-108 and CPPR-109 Vogtle Electric Generating Plant - Units 1 and 2 FSAR

Amendment Number 25, dated 9/19/86

ADAMS Acc. No. 8610100179, File X7BC35, Log GN-1094, NRC Docket Numbers 50-424 and

50-425 Construction Permit Numbers CPPR-108 and CPPR-109 Vogtle Electric Generating

Plant - Units 1 and 2 SER Open Item 1: Equipment Qualification, dated 9/30/86

ADAMS Acc. No. 8611140238, File X7BC35, Log GN-1151, NRC Docket Numbers 50-424 and

50-425 Construction Permit Numbers CPPR-108 and CPPR-109 Vogtle Electric Generating

Plant - Units 1 and 2 SER Open Item 1: Equipment Qualification, dated 10/31/86

ADAMS Acc. No. 87043000015, Transmittal of Final Version of Report EGG-NTA-7403 -

Oben-128-86, dated 10/31/86

Letter,

M. A. Miller (NRC) to R. Conway (Georgia Power Company), Vogtle Environmental

Qualification Audit of the Equipment Qualification Files and Request for Additional Information,

dated 11/18/86

ADAMS Acc. No. 8612100362, File X3BL01, Log GN-1194, NRC Docket Numbers 50-424 and

50-425 Construction Permit Numbers CPPR-108 and CPPR-109 Vogtle Electric Generating

Plant - Units 1 and 2 SER Open Item 1: Equipment Qualification, dated 11/26/86

ADAMS Acc. No. 8612110015, File X3BL01, Log GN-1204, NRC Docket Numbers 50-424 and

50-425 Construction Permit Numbers CPPR-108 and CPPR-109 Vogtle Electric Generating

Plant - Units 1 and 2 SER Open Item 1: Equipment Qualification, dated 12/4/86

ADAMS Acc. No. 8701070358, File X3BL01, Log GN-1263, NRC Docket Numbers 50-424 and

50-425 Construction Permit Numbers CPPR-108 and CPPR-109 Vogtle Electric Generating

Plant - Units 1 and 2 SER Open Item 1: Equipment Qualification, dated 1/2/87

NUREG-1137, Supplement No. 5, Safety Evaluation Report related to the operation of Vogtle

Electric Generating Plant, Units 1 and 2 Docket Nos. 50-424 and 50-425, dated January 1987

NUREG-0896, Supplement No. 5, Safety Evaluation Report related to the operation of

Seabrook Station, Units 1 and 2 Docket Nos.50-443 and 50-444, dated July 1986

Letter,

J. DeVincentis (PSNH) to G. W. Knighton (NRC), Environmental Qualification of

Electrical Equipment, SER Outstanding Issue #6, dated 10/31/85

Memorandum for V. Nerses (NRC) from F. Rosa (NRC) Environmental Qualification Audit of the

Equipment Qualification Files for Seabrook Station, Unit 1, dated 3/20/86

Letter,

N. Petrick (SNUPPS) to H. Denton (NRC), Environmental Qualification of Safety-Related

Electrical Equipment, dated 5/27/83

EGG-EA-6339, Audit of the Environmental Qualification of Safety-Related Electrical Equipment

for the Standardized Nuclear Unit Power Plant System, dated July 1983

NUREG-0881, Supplement No. 4, Safety Evaluation Report related to the operation of Wolf

Creek Nuclear Generating Station, Unit No. 1, Docket No. STN 50-482, dated December 1983

Letter,

N. Petrick (SNUPPS) to H. Denton (NRC), Environmental Qualification Justifications for

Interim Operation, dated 1/27/84

Section 71111.22: Surveillance Testing

Completed Procedures

14810A-2, Unit 2 TDAFW Pump Operability, Response Time, and Check Valve IST (Sections

5.1 and 5.4), Completed on July 19, 2018

14378-1, Containment Penetration No. 78 Containment Sump Pumps is charge Local Leak Rate

Test, Completed on September 12, 2018

14381-1, Containment Penetration No. 81 Containment Instrument Air Supply Line Local Leak

Rate Test, Completed on September 21, 2018

14668A-2, Unit 2 Diesel Generator 24-hr Operability Test, completed on July 30-31, 2018

14300-1, Containment Type B & C Leakage Totalization, completed on 10/1/2018

Condition Reports

10517236, Unit 2 TDAFW pump possible turbine seal leak

CR10534763, LLRT on Pen 78 for 1HV0781, As-Found exceeded Admin Limit SCCM

Drawings

1X4DB161-2, Ver. 29.0, Unit 1 P&I Diagram - Auxiliary Feedwater System - System No. 1302

1X4DB186-4, Ver. 14.0, Unit 1 P&I Diagram - Instrument Air System - Containment Building -

System 2420

Work Orders

SNC437981, Containment Type B and C Leakage Totalization, 10/19/15

SNC437982, Containment Type B and C Leakage Totalization, 4/3/17

SNC675545, 1214 HV0780 Containment Drains Rx Cavity/Containment Sump, PLANNED

Other

ASME OM Code, Subsection ISTB, Inservice Testing of Pumps in Light-Water Reactor Nuclear

Power Plants, 2004 Edition with Addenda through OMb-2006

Unit 2 TDAFW Inservice Testing Quarterly trends for Flow and Pressure (data range: 01/2013 -

07/2018)

Section 71151: Performance Indicator (PI) Verification

Procedures, Guidance Documents, and Manuals

00163-C, NRC Performance Indicator & Monthly Operating Report Preparation & Submittal,

Rev. 14.6

Section 71152: Problem Identification and Resolution

Procedures

NMP-EP-141-003-F01, Vogtle Unit 1 and Unit 2 -Initiating Condition Matrix COLD Conditions

(RCS 200 F), Ver. 1.0

NMP-EP-141-003, Vogtle Unit 1 and Unit 2 Emergency Action Levels and Basis, Ver. 3.0

19000-1, F-O Critical Safety Function Status Tree, Versions 1.0 and 1.1

Section 71153: Follow-up of Events and Notices of Enforcement Discretion Events

Other

NMP-GM-020-F03, Event Recovery Report: Unit 1 SG no. 2 High Level Manual Reactor Trip,

7/3/18

Section 60855.1: Operation of an Independent Spent Fuel Storage Installation

Procedures

11882-1, Outside Area Rounds Sheets, Ver. 98.2

Section 92702: Follow up on Traditional Enforcement Actions

Procedures

NMP-GM-002-GL03, Causal Analysis and Corrective Actions Guidelines, Ver. 29.0

NMP-GM-002-001, Corrective Action Program Instructions, Ver. 37.0

11882-1 Outside Area Rounds Sheets Unit 1, Ver. 99.0

11882-2 Outside Area Rounds Sheets Unit 2, Ver. 85.0

NMP-AD-051, Work Verification, Ver. 1.0, 2.0, and 3.0

NMPOS-007-007, Rounds, Ver. 4.0

NOS-112-001, Comprehensive Performance Assessments, Ver. 6.1

NMP-OS-007, Conduct of Operations, Ver. 13.0

NMP-GM-008, Operating Experience Program, Ver.19.0

NRC/SNC Correspondence

ML13127A136, Southern Nuclear Operating Company, Inc. - Confirmatory Order (NRC Office

of Investigations Report No. 2-2011-018), May 6, 2013

ML17355A481, Vogtle Electric Generating Plant - Inspection Report 05000424/2017012 and

05000425/2017012: Investigation Report No. 2-2017-005; and Apparent Violation, December

21, 2017

ML18051A053, Vogtle Electric Generating Plant - Notice of Violation and Proposed Imposition

of Civil Penalty - $145,000, NRC Inspection Report 05000424/2018090 and 05000425/

2018090; Investigation Report No. 2-2017-005, February 20, 2018

ML18051A599, Vogtle Electric Generating Plant, Units 1 and 2 - Pre-decisional Enforcement

Conference Summary, February 20, 2018

Completed Work Verifications

Operator Rounds

2017: 2/23/17 thru 3/3/17 // 4/30/17 thru 5/7/17 // 8/21/17 thru 8/28/17 // 11/18/17 thru 11/25/17 //

6/5/17 thru 6/13/17 //2/10/17 thru 2/18/17

2018: 3/20/18 thru 3/27/18 // 5/8/18 thru 5/18/18

Condition Reports

10532643, First and second quarters of 2017 operator rounds verification did not include aux.

bldg. operators

10533987, Missing data on June 2018 Operator Rounds Verification Audit

10497160, 10444685, 10510189, 10510339,10314673, 10319927, 10319943, 10330914,

10339708, 10349464, 10350342

Technical Evaluations:

21058, 1016007, 976449, 976394, 976541, 976544, 976545, 976548, 976553, 976557,

976560, 975661, 976640, 976575, 977758, 977760, 977761, 977763, 977791, 976771, 976648,

Corrective Action Reports:

267393, Version 1.0

Other

All Hands Meeting - Trust and Integrity, Presentation Slides, Monday, February 20, 2017

Badge Access Transaction Repot: Card Reader 2F102: 6/10/17 0:01:00 to 6/10/17 23:59:00

ESDDB-2095-1207-00, eSOMS Suite Mobile Operator Rounds User Guide

Generic Letter 93-03: Verification of Plant Records, October 20, 1995

Information Notice 2013-15: Willful Misconduct/Record Falsification and Nuclear Safety Culture,

August 23, 2013

Information Notice 92-30: Falsification of Plant Records, April 23, 1992

Komm, Daniel A. Re: Integrity training follow-up discussion. OE Example 2. Message to VNP

Plant Supervision. July 17, 2018. E-mail.

Meier, Michael. Re: The Value of Trust and Integrity. Message to SNC - All Employees and

Contractors at All Locations. November 18, 2016. E-mail.

NRC Confirmatory Order 2013-0093

Southern Nuclear Company Lesson Plan. Media No. V-LO-LP-63501, Ver. 11.1

Southern Nuclear Company Lesson Plan. Media No. V-NL-LP-51170, Ver. 9.1

Taber, Brian K. Re: The Meaning and Value of Your Signature. Message to SNC - All

Employees at Plant Vogtle 1-2. November 4, 2016. E-mail

20