IR 05000424/2007003
Download: ML072120312
Text
July 30, 2007
Southern Nuclear Operating Company, Inc.ATTN:Mr. T. E. TynanVice President - VogtleVogtle Electric Generating Plant 7821 River Road Waynesboro, GA 30830
SUBJECT: VOGTLE ELECTRIC GENERATING PLANT- NRC INTEGRATED INSPECTIONREPORT 05000424/2007003 AND 05000425/2007003
Dear Mr. Tynan:
On June 30, 2007, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection atyour Vogtle Electric Generating Plant, Units 1 and 2. The enclosed integrated inspection report documents the inspection findings, which were discussed on July 12, 2007, with you and other members of your staff.The inspection examined activities conducted under your license as they relate to safety andcompliance with the Commission's rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. Based on the results of this inspection, one NRC-identified finding of very low safetysignificance (Green) was identified which was determined to be a violation of NRC regulatory requirements. However, because of the very low safety significance and the finding has been entered into your corrective action program, the NRC is treating this violation as a non-cited (NCV) violation consistent with Section VI.A of the NRC Enforcement Policy. If you contest this non-cited violation, 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.
SNC2In accordance with the Code of Federal Regulations 10 CFR 2.390 of the NRC's "Rules ofPractice," a copy of this letter, its enclosures, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the PublicElectronic Reading Room).
Sincerely,/RA/Scott M. Shaeffer, ChiefReactor Projects Branch 2 Division of Reactor ProjectsDocket Nos.:50-424, 50-425License Nos.:NPF-68 and NPF-81
Enclosure:
Inspection Report 05000424/2007003 and05000425/2007003
w/Attachment:
Supplemental Informationcc w/encl: (See page 3)
SNC2In accordance with the Code of Federal Regulations 10 CFR 2.390 of the NRC's "Rules ofPractice," a copy of this letter, its enclosures, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the PublicElectronic Reading Room).
Sincerely,/RA/Scott M. Shaeffer, ChiefReactor Projects Branch 2 Division of Reactor ProjectsDocket Nos.:50-424, 50-425License Nos.:NPF-68 and NPF-81
Enclosure:
Inspection Report 05000424/2007003 and05000425/2007003
w/Attachment:
Supplemental Informationcc w/encl: (See page 3)X PUBLICLY AVAILABLE G NON-PUBLICLY AVAILABLEG SENSITIVE X NON-SENSITIVEADAMS: X YesACCESSION NUMBER:_________________________OFFICERII:DRPRII:DRPRII:DRPRII:DRPRII:DRSSIGNATURESMSCWR1GJM1BCA1 by emailCAP3 by emailNAMESShaefferCRappGMcCoyBAndersonCPeabodyDATE07/30/200707/25/200707/30/200707/31/200707/24/20078/ /20078/ /2007 E-MAIL COPY? YESNO YESNO YESNO YESNO YESNO YESNO YESNO OFFICIAL RECORD COPY DOCUMENT NAME: C:\FileNet\ML072120312.wpd SNC3cc w/encls:J. T. Gasser Executive Vice President Southern Nuclear Operating Company, Inc.
Electronic Mail DistributionL. M. Stinson, Vice President, FleetOperations Support Southern Nuclear Operating Company, Inc.
Electronic Mail DistributionN. J. StringfellowManager-Licensing Southern Nuclear Operating Company, Inc.
Electronic Mail DistributionMoanica CastonSouthern Nuclear Operating Company, Inc.
Bin B-022 P. O. Box 1295 Birmingham, AL 35201-1295Director, Consumers' Utility CounselDivision Governor's Office of Consumer Affairs 2 M. L. King, Jr. Drive Plaza Level East; Suite 356 Atlanta, GA 30334-4600Office of the County CommissionerBurke County Commission Waynesboro, GA 30830Director, Department of Natural Resources205 Butler Street, SE, Suite 1252 Atlanta, GA 30334Manager, Radioactive Materials ProgramDepartment of Natural Resources Electronic Mail DistributionAttorney GeneralLaw Department 132 Judicial Building Atlanta, GA 30334Laurence BergenOglethorpe Power Corporation Electronic Mail DistributionResident ManagerOglethorpe Power Corporation Alvin W. Vogtle Nuclear Plant Electronic Mail DistributionArthur H. Domby, Esq.Troutman Sanders Electronic Mail DistributioinSenior Engineer - Power SupplyMunicipal Electric Authority of Georgia Electronic Mail DistributionReece McAlisterExecutive Secretary Georgia Public Service Commission 244 Washington Street, SW Atlanta, GA 30334Distribution w/encl: (See page 4)
SNC4Letter to T.from Scott M. Shaeffer dated July 30, 2007
SUBJECT: VOGTLE ELECTRIC GENERATING PLANT- NRC INTEGRATED INSPECTIONREPORT 05000424/2007003 AND 05000425/2007003Distribution w/encl:B. Singal, NRR C. Evans, RII EICS L. Slack, RII EICS RIDSNRRDIRS OE Mail PUBLIC EnclosureU. S. NUCLEAR REGULATORY COMMISSIONREGION IIDocket Nos.: 50-424, 50-425 License Nos.: NPF-68, NPF-81 Report Nos.:05000424/2007003 and 05000425/2007003 Licensee:Southern Nuclear Operating Company, Inc.
Facility:Vogtle Electric Generating Plant, Units 1 and 2 Location:Waynesboro, GA 30830 Dates:April 1, 2007 through June 30, 2007 Inspectors:G. McCoy, Senior Resident InspectorB. Anderson, Resident Inspector C. Peabody, Reactor Inspector (Section 4OA5)Approved by:Scott M. Shaeffer, ChiefReactor Projects Branch 2 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000424/2007-003, 05000425/2007-003; 04/01/2007 - 06/30/2007; Vogtle ElectricGenerating Plant, Units 1 and 2; Other Activities.The report covered a three-month period of inspection by two resident inspectors andone reactor inspector. One Green finding 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 NRC's program for overseeing the safe operation of commercial nuclear power reactors is described NUREG-1649, "Reactor Oversight
Process."A.NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
- Green.
The inspectors identified a non-cited violation (NCV) of 10 CFR 50, Appendix B,Criterion VII, Control of Purchased Materials, Equipment, and Services, for failure to identify deviations from the procurement specifications regarding the maximum allowable clearances of the replacement Unit 2 containment emergency recirculation sump strainers.The finding is more than minor because it affects the Design Control and EquipmentPerformance attributes of the Mitigating Systems cornerstone objective in that larger perforations could have prevented long-term core decay heat removal. The finding was determined to be of very low safety significance (Green) because the affected components were not placed in service prior to repair. The finding has a cross-cutting aspect in the area of Human Performance involving supervisory and management oversight of work activities, particularly receipt inspection of containment sump screen hardware. This violation has been entered into the licensee corrective action program as CR 2007103895.
B.Licensee-Identified Violations
None.
Enclosure
REPORT DETAILS
Summary of Plant StatusUnit 1 operated at 100% rated thermal power (RTP) for the entire inspection period.Unit 2 started the inspection period in a planned refueling outage. The unit wasrestarted on April 21, 2007. On April 23, the unit tripped at 54% RTP due to a main generator trip. Following repairs, Unit 2 was restarted and reached 100% RTP on May
8. The unit remained at essentially 100% RTP for the remainder of the inspection
period.1.REACTOR SAFETYCornerstones: Initiating Events, Mitigating Systems, Barrier Integrity1R04Equipment Alignmenta.Inspection ScopePartial Walkdowns. The inspectors performed partial walkdowns of the following foursystems to verify correct system alignment. The inspectors checked for correct valve and electrical power alignments by comparing positions of valves, switches, and breakers to the procedures and drawings listed in the Attachment. Additionally, the inspectors reviewed the condition report database to verify that equipment alignment problems were being identified and appropriately resolved.Unit 2 train A component cooling water (CCW) during train B CCW maintenancePlant Wilson Combustion Turbines while work was being performed on a Unit 2reserve station service transformer.Unit 2 train A and B nuclear service cooling water (NSCW) system while NSCW pumpnumber 5 was out of service for maintenance.Unit 2 train A CCW following CCW pump number 1 maintenance.b.FindingsNo findings of significance were identified.1R05Fire Protectiona.Inspection ScopeThe inspectors walked down the following nine plant areas to verify the licensee wascontrolling combustible materials and ignition sources as required by 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 licensee's 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 licensee's fire protection program to verify the requirements of Updated Final Safety Analysis Report (UFSAR) Section 9.5.1, FireProtection Program, and Appendix 9A, Fire Hazards Analysis, were met. Documents reviewed are listed in the Attachment.Unit 1 train A diesel generator (DG) building and associated fuel oil day tank roomNorth firewater pumphouseUnit 2 trains A and B CCW heat exchanger roomsUnit 1 train B cable spreading roomUnit 1 trains A and B safety injection (SI) pump roomsUnit 1 auxiliary feedwater pumphouseUnit 2 remote shutdown roomsUnit 2 train B DG building and associated fuel oil day tank roomUnit 1 DG fuel oil storage tanks and pumphouseb.FindingsNo findings of significance were identified. 1R11Licensed Operator Requalificationa.Inspection ScopeThe inspectors evaluated the following areas of operator performance during licensedoperator simulator training described on simulator exercise guide V-RQ-SE-07205. The simulator scenario covered operator actions resulting from the loss of one class 1-E electrical bus and a reactor trip. Documents reviewed are listed in the Attachment. Correct use of the abnormal and emergency operating proceduresAbility to identify and implement appropriate actions in accordance with therequirements of the Technical SpecificationsClarity and formality of communications in accordance with procedure 10000-C,Conduct of OperationsProper control board manipulations including critical operator actionsQuality of supervisory command and controlEffectiveness of post-evaluation critiqueb.FindingsNo findings of significance were identified.1R12Maintenance Effectivenessa.Inspection Scope
The inspectors reviewed one equipment problem and one system oriented sample toevaluate the effectiveness of the licensee's handling of equipment performance problems and to verify the licensee's maintenance efforts met the requirements of 10 CFR 50.65 (the Maintenance Rule) and licensee procedure 50028-C, Engineering Maintenance Rule Implementation. The reviews included adequacy of the licensee's 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). Also, the inspectors interviewed system engineers and the maintenance rule coordinator to assess the accuracy of identified performance deficiencies and extent of condition. CR 2007104679, Unit 2 turbine-driven auxiliary feedwater (TDAFW) trip-throttle valveinoperabilityUnit 1 NSCW systemb.FindingsNo findings of significance were identified.1R13Maintenance Risk Assessments and Emergent Work Evaluationa.Inspection ScopeThe inspectors reviewed the following five risk significant and emergent MWOs to verifyplant 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 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.Unit 1 train B CCW maintenance outageUnit 1 train A motor-driven auxiliary feedwater (MDAFW) pump maintenanceUnit 2 train B control room emergency filtration system maintenanceUnit 1 AB15 electrical switchgear maintenanceUnit 2 train B number 5 NSCW pump outageb.FindingsNo findings of significance were identified.
R15 Operability Evaluationsa.Inspection ScopeThe inspectors reviewed the following five evaluations to verify they met therequirements of procedure NMP-GM-002, Corrective Action Program, and NMP-GM-
002-001, Corrective Action Program Instructions. The scope of this inspection included a review of the technical adequacy of the evaluations, the adequacy of compensatory measures, and the impact on continued plant operation.CR 2007104428, Failed oil analysis for 2B MDAFW pumpCR 2007105229, 1B DG jacket cooling water leakCR 2007106432, Problems maintaining Tave and Tref due to slowly decreasing TrefCR 2007105848, Possibility of gas entrapment in Residual Heat Removal (RHR)systemCR 2007107133, Technical Support Center outside air damper failure to fully closeb.FindingsNo findings of significance were identified.1R17 Permanent Plant Modificationsa. Inspection ScopeThe inspectors reviewed Design Change Package (DCP) No. 2051646601, ContainmentEmergency Sump Screens Replacement, Rev. 1, to verify it met the requirements of procedure 58007-C, Design Change Packages, and the modification did not degrade the system design bases, licensing bases, or equipment performance capability. The inspectors conducted a visual walkdown to verify the installed screens were consistent with specifications and drawings provided in the DCP. Additionally, the inspectors reviewed the plant risk assessment to verify that plant risk was not increased unnecessarily during modification implementation.b. FindingsNo findings of significance were identified.1R19Post-Maintenance Testinga.Inspection ScopeThe inspectors either observed post-maintenance testing or reviewed the test results forthe 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 operabilityrequirements.MWO 20622835, Unit 2 train B CCW pump #4 discharge valve maintenanceMWO 20707485, Unit 2 auxiliary feedwater (AFW) discharge to steam generator (SG)#4 throttle handswitch replacementMWO 20701546, Unit 2 TDAFW pump trip and throttle valve maintenanceMWO 20708337, Unit 2 Loop 1 MFRV controller card replacementMWO 20615247, Unit 2 TDAFW pump room outside air intake actuator maintenanceMWO 10707935, Power supply failure on U1 TDAFW governorb.FindingsNo findings of significance were identified.1R20Refueling and Outage ActivitiesRefueling Outage. The inspectors performed the inspection activities described belowfor the Unit 2 refueling outage that began on March 4, 2007. The inspectors confirmed that, when the licensee removed equipment from service, the licensee maintained defense-in-depth commensurate with the outage risk control plan for key safety functions and applicable technical specifications and that configuration changes due toemergent work and unexpected conditions were controlled in accordance with the outage risk control plan. Documents reviewed are listed in the Attachment.*Reviewed reactor coolant system (RCS) pressure, level, and temperature instrumentsto verify that the instruments provided accurate indication and that allowances were made for instrumentation errors.*Reviewed the status and configuration of electrical systems to verify that thosesystems met TS requirements and the licensee's outage risk control plan.*Observed decay heat removal parameters to verify that the system was properlyfunctioning and providing cooling to the core.*Reviewed system alignments to verify that the flow paths, configurations, andalternative means for inventory addition were consistent with the outage risk plan.*Reviewed selected control room operations to verify that the licensee was controllingreactivity in accordance with the technical specifications.*Reviewed the outage risk plan to verify that activities, systems, and/or componentswhich could cause unexpected reactivity changes were identified in the outage risk plan and were controlled.*Observed licensee control of containment penetrations to verify that the requirementsof the technical specifications were met.*Reviewed the licensee's plans for changing plant configurations to verify that technicalspecifications, license conditions, and other requirements, commitments, and administrative procedure prerequisites were met prior to changing plant configurations.
- Reviewed RCS boundary leakage and the setting of containment integrity.*Examined the containment prior to reactor startup to verify that debris had not beenleft which could affect performance of the containment sumps.The inspectors performed a review of Operating Experience Smart Sample (OpESSFY2007-03, Crane and Heavy Lift Inspection, supplemental guidance for inspection procedure 71111.20. The inspectors reviewed the information available for heavy lifts performed during the Unit 2 Spring 2007 refueling outage.
Documents reviewed are listed in the Attachment.b.FindingsNo findings of significance were identified.1R22Surveillance Testinga.Inspection ScopeThe inspectors reviewed the following five surveillance test procedures and eitherobserved 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 Tests14667-2, Train B Diesel and ESFAS Test14721-2, ECCS Subsystem Flow Balance and Checkvalve Refueling Inservice Test14980A-1, Diesel Generator 1A Operability TestIn-Service Tests (IST)14808-2, Centrifugal Charging Pump and Check Valve IST and Response Time Test14805-1, Residual Heat Removal Pump and Check Valve IST and Response TimeTestsb.FindingsNo findings of significance were identified.1R23Temporary Plant Modificationsa.Inspection ScopeThe inspectors evaluated the following Temporary Modification (TM) and associated 10CFR 50.59 screening against the system design basis documentation and UFSAR to verify that the modification did not adversely affect the safety functions of important safety systems. Additionally, the inspectors reviewed licensee procedure 00307-C,
Temporary Modifications, to verify if the modification was properly developed andimplemented.TM 20620554, Modify containment penetrations for steam generator chemicalcleaning hoses1EP6Drill Evaluationa.Inspection ScopeThe inspectors reviewed the facility activation exercise guide and observed the followingemergency response activity to verify the licensee was properly classifying emergency events, making the required notifications, and making appropriate protective action recommendations in accordance with procedures 91001-C, Emergency Classifications, and 91305-C, Protective Action Guidelines.On April 30, the inspectors observed a simulator-based exercise involving a loss ofsecondary heat sink and the initiation of reactor coolant system feed and bleed.b.FindingsNo findings of significance were identified.4.OTHER ACTIVITIES 4OA1Performance Indicator (PI) Verificationa.Inspection ScopeThe inspectors sampled licensee submittals for the listed PIs during the period fromApril 1, 2006, through March 31, 2007, for Unit 1 and Unit 2. The inspectors verified the licensee's basis in reporting each data element using the PI definitions and guidance contained in procedures 00163-C, NRC Performance Indicator and Monthly Operating Report Preparation and Submittal, and Nuclear Energy Institute (NEI) 99-02, Regulatory Assessment Indicator Guideline.Barrier Integrity CornerstoneReactor Coolant System Specific ActivityReactor Coolant System LeakageThe inspectors reviewed Unit 1 and Unit 2 chemistry and operator log entries, themonthly operating reports and monthly PI summary reports to verify that the licensee had accurately submitted the PI data.
b. Findings
No findings of significance were identified.4OA2Identification and Resolution of Problems.1Daily Condition Report Review. As required by Inspection Procedure 71152,Identification and Resolution of Problems, and in order to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensee's corrective action program. This review was accomplished by either attending daily screening meetings that briefly discussed major CRs, or accessing the licensee's computerized corrective action database and reviewing each CR that was initiated..2Focused Reviews. The inspectors performed a detailed review of the following CR toverify the full extent of the issue was identified, an appropriate evaluation was performed, and appropriate corrective actions were specified and prioritized. The inspectors evaluated the CR against the licensee's corrective action program as delineated in licensee procedure NMP-GM-002, Corrective Action Program, and 10 CFR 50, Appendix B. Documents reviewed are listed in the Attachment.CR 2007101045, 1A EDG was stopped due to a significant fuel oil leak.A cumulative review of operator workaroundsb.Findings and ObservationsNo findings of significance were identified. The CR correctly described the conditionand the corrective actions were appropriate for the causes identified. No increase in operator burden was identified due to cumulative operator workarounds..3Semi-Annual Trend Review. In accordance with IP 71152, Identification and Resolutionof Problems, the inspectors performed a review of the licensee's corrective action program to identify trends that could indicate the existence of a more significant safety issue. The inspectors also focused on the results of daily inspector CR evaluation discussed above. The review also included issues documented outside the normal corrective action program in quality assurance audit /surveillance reports, system health reports, corrective maintenance WOs, self assessment reports, and maintenance rule program reports. The inspectors' review nominally considered the six-month period of January through June 2007, although some examples expanded beyond those dates when appropriate. Corrective actions associated with a sample of the issues identified in the licensee's self assessment report were reviewed for adequacy. The inspectors also evaluated the trend reports against the requirements of the licensee's corrective action program as specified in licensee procedure NMP-GM-002 "Corrective Action Program" and 10 CFR 50, Appendix B.
b.Assessment and ObservationsThe inspectors compared the licensee trending analysis with the results of theinspectors' daily CR screening and did not identify any discrepancies or potential trends that the licensee had failed to identify.4OA3Event Followup.1Unit 2 Main Generator and Reactor Tripa.Inspection ScopeThe inspectors reviewed the circumstances of the Unit 2 automatic reactor trip on April23. The inspectors discussed the trip with operations, engineering, and licensee management personnel to understand the event and assess followup actions. The inspectors reviewed operator actions taken in accordance with licensee procedures and reviewed unit and system indications to verify that actions and system responses were as expected. The inspectors discussed the trip with the licensee's event investigation team and assessed the team's actions to gather, review, and assess information leading up to and following the event. The inspectors also reviewed the initial licensee notification to verify that it met the requirements specified in NUREG-1022, Event Reporting Guidelines. The inspectors later reviewed the initial investigation report and root cause determination to assess the detail of review and adequacy of the root cause and proposed corrective actions prior to unit restart.b.FindingsNo findings of significance were identified.4OA5Other Activities.1(Discussed) Temporary Instruction (TI) 2515/166, Pressurized Water ReactorContainment Sump Blockage (NRC Generic Letter 2004-02) - Unit 2a.Inspection ScopeThe inspectors reviewed Unit 2 implementation of the licensee's commitmentsdocumented in their September 1, 2005, response to Generic Letter (GL) 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized Water Reactors. These commitments included permanent modification of the sump strainer assembly, modifications of high-head safety injection (HHSI) and intermediate-head safety injection (IHSI) branch lines and throttle valves, and replacement of particulate insulation in containment. The inspectors reviewed the Design Change Packages (DCPs) for the sump strainer assembly and the HHSI branch line and the 10 CFR 50.59 evaluations for these DCPs. The inspectors conducted a visual walkdown to verify the installed strainer assembly configuration was consistent with drawings and specifications provided in the DCPs and associated drawings. The
inspectors also conducted visual walkdowns of accessible insulation replacements andthe HHSI branch line modifications. The inspectors also reviewed ECCS flow balance test results following the HHSI modifications as well as reviewed associated QA documentation from the licensee, vendor, and subcontractor. Documents reviewed are listed in the Attachment.The inspectors determined the following answers to the Reporting Requirementsdetailed in the TI for Unit 2:*The licensee implemented plant modifications and procedure changes committed to intheir GL 2004-02.*The licensee updated its licensing bases to reflect the corrective actions taken inresponse to GL 2004-02.This TI will remain open on Unit 2 until the TI expiration date of December 31, 2007, ornotification from the licensee that all associated ongoing analyses have been completed and no further modifications to Unit 2 are required by GL 2004-02.b.FindingsIntroduction. The inspectors identified a Green NCV of 10CFR50, Appendix B, CriterionVII, "Control of Purchased Material, Equipment, and Services" for a failure to identify manufacturing defects which lead to a non-conformance with the replacement Containment Emergency Sump Strainers' procurement specifications. During a walkdown of the Containment Emergency Sump Screens Replacement, the inspectors found numerous screen penetrations greater than the specified 3/32" diameter.Description. The replacement strainers were the General Electric (GE) stacked discdesign and were manufactured by Fabrico Inc. The procurement specifications require a 3/32" diameter perforation, and no gaps or openings at other locations shall exceed a 3/32" dimension. GE Nuclear drawing number 234C7889 Rev. 2 instructs the welders to
"weld assembly flush side to perforated plate" and "inspect for gaps of greater than 3/32." Because of the way the perforated plate was cut, there was no flush side on the inner cylinder seam and perforated plate was welded to perforated plate, resulting in numerous perforations becoming conjoined and allowing clearances up to 3/16". On December 22, 2006, the licensee conducted a receipt inspection of Unit 2 ECCS replacement strainers and did not verify the perforation diameter was in accordance with the design specification of 3/32".The inspectors inspected the strainers installed in the Unit 2 containment emergencysump and found there were numerous conjoined perforation in the seams where the perforated strainer plate was wrapped around and joined to form the inner cylinder of each stack. These conjoined perforations resulted in up to twice the design clearance of 3/32" which could result in clogging clearances in the HHSI and IHSI that are less than 3/16".
Analysis.
The finding is more than minor because it affects the Design Control andEquipment Performance attributes of the Mitigating Systems cornerstone objective in that larger perforations could have prevented long-term core decay heat removal. The finding was determined to be of very low safety significance (Green) because the affected components were not placed in service prior to repair. The finding also had a cross-cutting aspect in the area of human performance involving supervisory and management oversight of work activities, specifically receipt inspection of containment screen hardware. A receipt inspection did not verify the hardware was constructed in accordance with the specified design.Enforcement. 10 CFR 50 Appendix B Criterion VII requires in part that Measures shallbe established to assure that purchased material, equipment, and services, whether purchased directly or through contractors and subcontractors, conform to the procurement documents. Contrary to the above, a receipt inspection of the Unit 2 ECCS Sump replacement strainers did not verify the specified perforation diameter was 3/32" when if fact manufacturing errors had caused this clearance to be exceeded in numerous instances. Because the finding is of very low safety significance and has been entered into the licensee's corrective action program as CR 2007103895, this violation is being treated as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy: NCV 05000425/2007003-01, Failure to Identify Replacement Strainer Clearances Greater than Design Procurement Specifications. 4OA6Meetings, Including ExitOn July 12, 2007, the resident inspectors presented the inspection results to Mr. T.Tynan and other members of his staff, who acknowledged the findings. The inspectors confirmed that proprietary information was not provided or examined during the inspection.ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- R. Brown, Training and Emergency Preparedness Manager
- C. Buck, Chemistry Manager
- J. Cash, Project Engineer (Southern Nuclear)
- W. Copeland, Performance Analysis Supervisor
- R. Dedrickson, Plant Manager
- K. Dyar, Security Manager
- I. Kochery, Health Physics Manager
- J. Robinson, Operations Manager
- S. Swanson, Engineering Support Manager
- T. Tidwell, Plant Modifications Supervisor
- T. Tynan, Site Vice-President
- J. Williams, Site Support Manager
NRC personnel
- S. Shaeffer, Chief, Region II Reactor Projects Branch 2
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and
Closed
- 05000425/FIN-2007003-01 NCVFailure to Identify Replacement Strainer ClearancesGreater than Design Procurement Specifications (Section
- 4OA5.1)Discussed2515/166TI Pressurized Water Reactor Containment Sump Blockage(NRC Generic Letter 2004-02) - Unit 2 (Section 4OA5.1)
LIST OF DOCUMENTS REVIEWED
Section 1R04:
- Equipment AlignmentProcedures13715A-2, Component Cooling Water System Train A11715-2, Component Cooling Water System Alignment
- 13150, Nuclear Service Cooling Water System
- 11150, Nuclear Service Cooling Water System AlignmentDrawings2X3D-BD-L01A, Component Cooling Water System
- 2-1203-P4-0012X3D-BD-L01B, Component Cooling Water System
- 2-1203-P4-002
- 2Attachment
Section 1R05: Fire ProtectionProcedures92861-1, Zone 161 Diesel Generator Building Fire Fighting Preplan92863-1, Zone 163 Diesel Generator Building Train A
- DFO Day Tank Fire Fighting Preplan
- 2930F-1, Zone 530 North Firewater Pumphouse Fire Fighting Preplan
- 2807-1, Zone 107 Control Building Levels 1 and 2 Fire Fighting Preplan
- 2808-1, Zone 108 Control Building Levels 1 and 2 Fire Fighting Preplan
- 2820-1, Zone 120 Control Building Level 2 Fire Fighting Preplan
- 2821-1, Zone 121 Control Building Level 2 Fire Fighting Preplan
- 2731-1, Zone 31 Auxiliary Building Level B Fire Fighting Preplan
- 2732-1, Zone 32 Auxiliary Building Level B, SI Pump, Train A Fire Fighting Preplan
- 2862-2, Zone 162 Diesel Generator Building Fire Fighting Preplan
- 2864-2, Zone 164 Diesel Generator Building Train B DFO Day Tank Fire Fighting Preplan
- 2865-1, Zone 165 Diesel Generator Tanks and Pumphouse Fire Fighting Preplan
- 2866-1, Zone 166 Diesel Generator Tanks and Pumphouse Fire Fighting Preplan
Section 1R11: Licensed Operator RequalificationProcedures18031-C, Loss of Class 1E Electrical Systems19000-C,
- E-0 Reactor Trip or Safety Injection
- 19001-C,
- ES-0.1 Reactor Trip Response
- 18002-C, Nuclear Instrumentation System Malfunction
Section 1R20:
- Refueling and Outage ActivitiesProcedures 93246-C, Reactor Polar Crane Service Check
- 93663-C, Verification of Core Loading Pattern
- 93300-C, Conduct of Refueling Operations
- 2005-C, Reactor Shutdown to Hot Standby (Mode 2 to Mode 3)
- 2006-C, Unit Cooldown to Cold Shutdown
- 2007-C, Refueling Operations (Entry into Mode 6)
- 2008-C, Midloop Operations
- 14900-C, Containment Exit InspectionOther DocumentsWork Order 20602183Condition Report 2007105862
- Drawing 1X4DE601
Section 1R22: Surveillance TestingProcedures14808-2, Centrifugal Charging Pump and Check Valve
- IST and Response Time Test14721-2, ECCS Subsystem Flow Balance and Check Valve Refueling Inservice Test
- 14805-1, Residual Heat Removal Pump and Check Valve IST and Response Time Tests
- 14980A-1, Diesel Generator 1A Operability Test
- 3Attachment
Section 4OA5: Other Activities14721-2 Rev. 21,
- ECCS Subsystem Flow Balance and Check Valve Refueling Inservice Test,Surveillance performed 10/7/2005.
- 14721-2 Rev. 25, ECCS Subsystem Flow Balance and Check Valve Refueling Inservice Test, Surveillance performed 4/11/2007.
- CR 2007103895, During Vogtle Unit 2 NRC
- TI 2515/166 Inspection, a number of defects were found in the strainer surface.
- DOEJ-SM-2051646601-003m, Unit 2 Containment Heat Load Impact due to removal of Min K
- Insulation and replacement with Compressed NUKON Insulation Out-of-Spec Condition for PWR Suction Strainers (Vogtle 2, Farley 2), 10 CFR 21
- QA Job Traveler N00062, Fabrico Inc., 12/5/06
- QA Job Traveler N00063, Fabrico Inc., 12/6/06
- QA Job Traveler N00065, Fabrico Inc., 11/22/06
- QA Job Traveler N00066, Fabrico Inc., 11/28/06
- QA Job Traveler N00078, Fabrico Inc., 10/30/06
- QA Job Traveler N00080, Fabrico Inc., 12/5/06
- September 2005 Response to NRC
- GL 2004-02, 8/31/2005
- SYNCPOWER Receipt Inspection#
- 06071399, 12/22/2006