ML24313A063
| ML24313A063 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 11/14/2024 |
| From: | Mark Franke NRC/RGN-II/DORS/PB3 |
| To: | Coleman J Southern Nuclear Operating Co |
| References | |
| IR 2024003 | |
| Download: ML24313A063 (17) | |
Text
Jamie Coleman Regulatory Affairs Director Southern Nuclear Operating Company, Inc.
3535 Colonnade Parkway Birmingham, AL 35243
SUBJECT:
VOGTLE ELECTRIC GENERATING PLANT, UNITS 3 AND 4 - INTEGRATED INSPECTION REPORT AND ASSESSMENT FOLLOW-UP LETTER 05200025/2024003 AND 05200026/2024003
Dear Jamie Coleman:
On September 30, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Vogtle Electric Generating Plant, Units 3 and 4. On October 1, 2024, the NRC inspectors discussed the results of this inspection with Patrick Martino, Site Vice President, and other members of your staff. This letter discusses the results of the inspection, which includes one finding of very low safety significance that is documented in the enclosed report. The letter also discusses NRCs quarterly assessment that determined Vogtle Unit 3 transitioned to the Regulatory Response Column (i.e., Column 2) of the Reactor Oversight Program (ROP) Action Matrix due to a Performance Indicator (PI) transitioning from Green to White.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation documented in this inspection report, 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; the Director, Office of Enforcement; and the NRC Resident Inspector at Vogtle Electric Generating Plant, Units 3 and 4.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the 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 Vogtle Electric Generating Plant, Units 3 and 4.
On October 22, 2024, the NRC completed a quarterly review of plant performance information and has determined that Vogtle Unit 3 performance transitioned from the Licensee Response Column (i.e. Column 1) to the Regulatory Response Column (i.e., Column 2) of the ROP Action Matrix beginning in the third quarter of 2024. This letter supplements, but does not supersede, the annual assessment letter issued on February 28, 2024 (ADAMS Accession No. ML24053A356).
November 14, 2024
J. Coleman 2
The NRCs review of Vogtle Electric Generating Plant Unit 3 identified that the Unplanned Scrams with Complications (USwC) PI crossed the Green-to-White threshold. This White PI is the result of having two complicated scrams during the third quarter of 2024. Each scram involved the initiation of a safeguards actuation signal due to conditions that challenged reactor coolant system temperature (July 2024 scram) and inventory (September 2024 scram),
requiring passive safety injection.
Therefore, the NRC plans to conduct a supplemental inspection in accordance with Inspection Procedure 95001, Supplemental Inspection Response to Action Matrix Column 2 (Regulatory Response) Inputs, to ensure that the root and contributing causes of individual and collective White performance issues are understood, to independently assess and ensure that the extent of condition and extent of cause of individual and collective White performance issues are identified, to ensure that completed corrective actions to address and preclude repetition (CAPR) of White performance issues are prompt and effective, and to ensure that pending corrective action plans direct prompt and effective actions to address and preclude repetition of the White performance issue.
On October 31, 2024, you submitted a letter requesting that the NRC consider an Action Matrix Deviation (AMD) to not increase the oversight (i.e., IP 95001) of Vogtle Unit 3 due to its transition to Column 2 of the ROP Action Matrix (ADAMS Accession No. ML24305A249). In summary, you stated that further causal analysis and supplemental inspection is not necessary because the low-risk profile of the AP1000 plant design and the corrective actions already taken and intended to be taken (for each complicated scram) will ensure continued safe plant operation. We acknowledge the low inherent risk in the AP1000 design and that SNC has conducted causal analyses and taken corrective actions; however, we have concluded an AMD is not appropriate in this case.
The basis for our decision is that an AMD based on the inherently low risk profile of the AP1000 plant or the low risk of the events, as outlined in your letter, is not consistent with the bases for the associated PI (USwC). As documented in IMC 0308 Attachment 1, Technical Bases for Performance Indicators, (ML20262H116) the Green-to-White threshold for this PI was established to identify outliers from industry norms and is not directly tied to risk. The two complicated scrams for Vogtle Unit 3 were consistent with the recently approved PI guidance in FAQ 21-01 for the AP1000 plants, which did not include changes to relax the PI threshold for AP1000 plants based on risk considerations. Additionally, a supplemental inspection in accordance with IP 95001, as noted above, is appropriate to ensure that the performance issue(s) leading to the White PI have been addressed. The NRC will consider the low-risk significance of the complicated scrams and the AP1000 design when establishing the scope and resources necessary to conduct the supplemental inspection.
The NRC requests that your staff provide notification of your readiness for the NRC to conduct a supplemental inspection to review the actions taken to address this White PI. If SNC has near-term intentions to propose changes to the USwC PI via the ROP PI Feedback process, the NRC would consider not conducting the supplemental inspection until the proposed changes are either approved or rejected. However, note that Vogtle Unit 3 will remain in Column 2 of the action matrix until the proposed PI change is resolved.
J. Coleman 3
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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Mark E. Franke, Director Division of Operating Reactor Safety Docket Nos. 05200025 and 05200026 License Nos. NPF-91 and NPF-92
Enclosure:
As stated cc w/ encl: Distribution via LISTSERV Signed by Franke, Mark on 11/14/24
SUNSI Review X
Non-Sensitive
Sensitive X
Publicly Available
Non-Publicly Available OFFICE RII/DORS RII/DORS RII/DORS RII/DORS NAME B. Truss A. Alen Arias A. Blamey M. Franke DATE 11/12/2024 11/13/2024 11/13/2024 11/14/2024
Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Numbers:
05200025 and 05200026 License Numbers:
NPF-91 and NPF-92 Report Numbers:
05200025/2024003 and 05200026/2024003 Enterprise Identifier:
I-2024-003-0047 Licensee:
Southern Nuclear Operating Company, Inc.
Facility:
Vogtle Electric Generating Plant, Units 3 and 4 Location:
Waynesboro, GA Inspection Dates:
July 1, 2024 to September 30, 2024 Inspectors:
S. Battenfield, Operations Engineer M. Donithan, Senior Operations Engineer K. Kirchbaum, Senior Operations Engineer J. Parent, Resident Inspector S. Seeley, Reg Agreement State Prog Officer B. Truss, Senior Resident Inspector J. Walker, Senior Emergency Preparedness Inspector Approved By:
Alan J. Blamey, Chief Reactor Projects Branch 3 Division of Operating Reactor Safety
2
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Vogtle Electric Generating Plant, Units 3 and 4, 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 https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations Failure to Follow Procedure Results in Unplanned Technical Specification Entry Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05200025/2024003-01 Open/Closed
[H.12] - Avoid Complacency 71152A A self-revealing finding of very low safety significance (Green) and associated non-cited violation (NCV) of Title 10 Code of Federal Regulations, Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified for the licensees failure to follow their equipment clearance and tagging procedure. Specifically, on August 26, 2024, the licensee failed to review and adhere to caution tag instructions to maintain closed the nitrogen vent valve for the unit 3 "A" accumulator of the passive core cooling system. As a result, operators inadvertently opened the valve and caused accumulator pressure to drop below the minimum technical specification limit, which rendered the accumulator inoperable.
Additional Tracking Items None.
3 PLANT STATUS Unit 3 started the quarter at rated thermal power (RTP). On July 8, 2024, the unit was manually tripped, and an automatic safeguards actuation was initiated after the "A" main feed pump (MFP) mini-flow valve V005A failed open. The failure of V005A caused main feed water to be diverted from the steam generators (SGs), which lowered water level in the SGs, and prompted the operators to initiate a manual reactor trip. The reactor trip caused the water level in the SGs to lower further (due to shrink) resulting in the automatic actuation of the standby passive residual heat removal (PRHR) heat exchanger (HX). The PRHR HX rapidly reduced reactor coolant system (RCS) temperature resulting in an automatic safeguards actuation signal (NRC Event Notification 57215). The unit was restarted on July 16, 2024, following repairs to V005, and was returned to RTP on July 20, 2024. On September 17, 2024, with the unit at RTP, the reactor was automatically tripped and a manual safeguards actuation initiated due to PRHR HX outlet valve V108A failing open. Following the reactor trip, RCS pressurizer level began to lower, due to the rapid RCS cooldown from the PRHR HX, resulting in the operators manually initiating a safeguards actuation signal (NRC Event Notification 57326). The unit was restarted on September 26, 2024, following repairs to V108A, and was at approximately 40 percent of RTP at the end of the inspection period.
Unit 4 began the quarter at RTP. On September 5, unit operators conducted a planned power reduction to approximately 60 percent RTP to implement a main feedwater pump relay modification. The unit returned to RTP on September 6, 2024. The unit remained at or near RTP for the remainder of the inspection period.
INSPECTION SCOPES Inspections were conducted using the appropriate portions of the inspection procedures (IPs) 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 consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, observed risk-significant activities, and completed on-site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY 71111.01 - Adverse Weather Protection Impending Severe Weather Sample (IP Section 03.02) (2 Samples)
(1)
The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe weather during Tropical Storm Debby from August 5, 2024, through August 7, 2024.
(2)
The inspectors evaluated licensee readiness for impending adverse weather conditions due to Hurricane Helene approaching the site on September 24-28, 2024. The site was under a tropical storm warning. Tropical storm winds were experienced on site however, they did not impact plant operation.
4 71111.05 - Fire Protection Fire Area Walkdown and Inspection Sample [AP1000] (IP Section 03.01) (2 Samples)
(1)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following unit 4 fire areas on August 8, 2024:
Fire Area 1200 AF 12562 (room 12463): Cask loading pit Fire Area 1200 AF 12562 (room 12562): Fuel handling area Fire Area 1200 AF 12562 (room 12563): Spent fuel storage pool Fire Area 1200 AF 12562 (room 12564): Fuel transfer canal (2)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following unit 3 fire areas on July 11, 2024:
Fire Area 1100 AF 11204: Vertical access / reactor coolant drain tank room Fire Area 1100 AF 11300A: Maintenance floor southeast Fire Area 1100 AF 11300B: Maintenance floor north Fire Area 1100 AF 11301: SG compartment 1 Fire Area 1100 AF 11302: SG compartment 2 Fire Area 1100 AF 11303: Pressurizer compartment Fire Area 1100 AF 11303A: Lower automatic depressurization system (ADS) valve area Fire Area 1100 AF 11303B: Upper ADS valve area Fire Area 1100 AF 11500: Operating deck Fire Brigade Drill Performance Sample [AP1000] (IP Section 03.02) (1 Sample)
(1)
The inspectors evaluated the onsite fire brigade training and performance during an unannounced fire drill in the following area:
Unit 3 outside switchgear, on July 29, 2024.
71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)
The inspectors assessed the effectiveness of the facility licensee in implementing requalification requirements identified in 10 CFR Part 55, Operators Licenses. Each of the following inspection activities was conducted in accordance with IP 71111.11, Licensed Operator Requalification Program and Licensed Operator Performance.
(1)
Biennial Requalification Written Examinations The inspectors evaluated the quality of the licensed operator biennial requalification written examination administered for the 2023 Biennial Written Exam.
5 Annual Requalification Operating Tests The inspectors evaluated the adequacy of the licensees annual requalification operating test.
Administration of an Annual Requalification Operating Test The inspectors evaluated the effectiveness of the licensee in administering requalification operating tests required by 10 CFR 55.59(a)(2) and that the licensee is effectively evaluating their licensed operators for mastery of training objectives.
Requalification Examination Security The inspectors evaluated the ability of the licensee to safeguard examination material, such that the examination is not compromised.
Remedial Training and Re-examinations The inspectors evaluated the effectiveness of remedial training conducted by the licensee, and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.
Operator License Conditions The inspectors evaluated the licensees program for ensuring that licensed operators meet the conditions of their licenses.
Control Room Simulator The inspectors evaluated the adequacy of the licensees control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46, "Simulation facilities."
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
(1)
The inspectors observed and evaluated licensed operator performance in the control room during a planned unit 3 startup and power ascension, following forced outage V32024B (i.e., "A" MFP mini-flow valve failure), on July 16, 2024.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (2 Samples)
(1)
The inspectors observed and evaluated a simulator scenario consisting of a SG tube leak, passive core cooling system (PXS) instrument failure, inadvertent feedwater isolation, automatic turbine trip failure, and PRHR actuation failure. The scenario resulted in a "Site Area Emergency" declaration, on July 29, 2024.
(2)
The inspectors observed and evaluated a simulator scenario consisting of degraded flow on the A component cooling water system pump, an RCS leak of 40 gallon-per-
6 minute, vibrations on the main turbine that exceeded the trip setpoint, main turbine failure to trip, and failure of the containment sump valves to open, on August 6, 2024.
71111.12 - Maintenance Effectiveness Maintenance Effectiveness [AP1000] (IP Section 03.01) (2 Samples)
(1)
Maintenance Rule periodic evaluation (i.e., 10 CFR 50.65(a)(3)) for the period of May 1, 2022, through May 1, 2024.
(2)
Maintenance Rule performance goal establishment and monitoring (i.e., 10 CFR 50.65(a)(1)) for breakers 3-ECS-EK-12 and 3-ECS-EK-22 after failure impacted class 1E batteries (IDS) on August 20, 2024.
Quality Control [AP1000] (IP Section 03.02) (1 Sample)
(1)
Unit 4, core makeup tank (CMT) outlet valve maintenance. Work order (WO)
SNC1558696 on July 19, 2024.
71111.13 - Maintenance Risk Assessments and Emergent Work Control Risk Assessment and Management Sample [AP1000] (IP Section 03.01) (1 Sample)
(1)
Unit 3, elevated risk (Yellow) due to a manual reactor trip, PRHR actuation, and safeguards actuation with an unavailable chemical volume and control system (CVS) pump on July 8, 2024.
71111.15 - Operability Determinations and Functionality Assessments Operability Determination or Functionality Assessment [AP1000] (IP Section 03.01) (3 Samples)
(1)
Condition Report (CR) 11095641, lowering water level in the unit 3 in-containment refueling water storage tank (IRWST) on July 21, 2024.
(2)
CR 11091687, unit 3 evaluation of RCS piping, SG tubes, reactor vessel internals, and reactor vessel, following rapid cooldown event on July 8, 2024.
(3)
CR 11092182, unit 3 trisodium phosphate banks wetted, on July 8, 2024.
71111.18 - Plant Modifications Temporary Modifications and/or Permanent Modifications [AP1000] (IP Section 03.01 and/or 03.02) (1 Sample)
(1)
SNC1401719, plant control system (PLS) logic changes for loss of main feedwater pump and mini-flow valve V005A failure on July 26, 2024.
71111.20 - Refueling and Other Outage Activities Refueling/Other Outage Sample (IP Section 03.01) (2 Samples)
(1)
The inspectors evaluated unit 3 forced outage (V32024B) following manual reactor trip, PRHR actuation, and automatic safeguards actuation recovery activities from July 8 to July 16, 2024.
7 (2)
The inspectors evaluated unit 3 forced outage (V32024C) following automatic reactor trip and manual safeguards actuation recovery activities from September 17 to September 26, 2024.
71111.24 - Testing and Maintenance of Equipment Important to Risk Post-Maintenance Testing (PMT) [AP1000] (IP Section 03.01) (1 Sample)
(1) 3-PXS-OTS-10-003, "Passive Core Cooling System PRHR Valves Stroke Test," on 3-PXS-V108A following replacement of the solenoid valve on September 22, 2024.
71114.01 - Exercise Evaluation Inspection Review (IP Section 02.01-02.11) (1 Sample)
(1)
In accordance with 10 CFR 50, Appendix E.IV.F.2.b, the inspectors evaluated the onsite emergency plan exercise during the week of August 26, 2024. The simulated scenario began when Chemistry reported reactor coolant sample results that were greater than the Alert emergency action level threshold and resulted in the declaration of an Alert. Following the Alert declaration, a pressurizer safety valve failed open lowering pressurizer pressure and increased containment radiation levels that resulted in a Site Area Emergency declaration. Finally, the containment hatch experiences a blown seal, that rapidly lowered containment pressure and raised area radiation monitors/alarms that indicated a loss of containment, and a General Emergency was declared. This scenario also allowed the offsite response organizations to partially participate in the drill. In accordance with 10 CFR 50, Appendix E.IV.F.2.c, the Vogtle units 3 & 4 offsite response organizations ability to implement the emergency plan was previously evaluated the week of May 20, 2024.
The results of that inspection are documented in inspection report ML24212A144.
71114.08 - Exercise Evaluation - Scenario Review Inspection Review (IP Section 02.01 - 02.04) (1 Sample)
(1)
The inspectors reviewed and evaluated in-office, the proposed scenario for the biennial emergency plan exercise at least 30 days prior to the day of the exercise.
OTHER ACTIVITIES - BASELINE 71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03) (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
(1)
CR 11105321, unit 3 "A" accumulator nitrogen pressure less than technical specification limit.
8 71153 - Follow Up of Events and Notices of Enforcement Discretion Event Follow Up [AP1000] (IP Section 03.01) (2 Samples)
The inspectors evaluated the following events and/or degraded conditions for plant status and mitigating actions; and provided input to NRC management to determine whether an incident investigation, augmented inspection, or special inspection team (IIT, AIT, or SIT) was warranted.
(1)
The inspectors evaluated the licensee's response to the unit 3 manual reactor trip and automatic safeguards actuation resulting from a failure of the "A" MFP mini-flow valve on July 8, 2024. This event resulted in a 4-hour notification to the NRC Headquarters Operation Officer (HOO) in accordance with 10 CFR 50.72(b)(2)(iv)(A) and (b)(2)(iv)(B) due to the actuation and discharge of the CMTs into the RCS and the actuation of the reactor protection system while critical, respectively (see NRC Event Notification 57215). The inspectors evaluated this event in accordance with NRC Management Directive (MD) 8.3 and determined that no follow-up inspection was necessary.
(2)
The inspectors evaluated the licensee's response to the unit 3 automatic reactor trip and manual safeguards actuation resulting from a PRHR heat exchanger outlet valve failing open on September 17, 2024. This event resulted in a 4-hour notification to the NRC HOO in accordance with 10 CFR 50.72(b)(2)(iv)(A) and (b)(2)(iv)(B) due to the actuation and discharge of the CMTs into the RCS and the actuation of the reactor protection system while critical, respectively (see NRC Event Notification 57326). The inspectors determined that an MD 8.3 evaluation and follow-up inspection was not necessary for this event.
INSPECTION RESULTS Failure to Follow Procedure Results in Unplanned Technical Specification Entry Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05200025/2024003-01 Open/Closed
[H.12] - Avoid Complacency 71152A A self-revealing finding of very low safety significance (Green) and associated non-cited violation (NCV) of Title 10 Code of Federal Regulations (10CFR), Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified for the licensees failure to follow their equipment clearance and tagging procedure. Specifically, on August 26, 2024, the licensee failed to review and adhere to caution tag instructions to maintain closed the nitrogen vent valve for the unit 3 "A" accumulator of the passive core cooling system. As a result, operators inadvertently opened the valve and caused accumulator pressure to drop below the minimum technical specification (TS) limit, which rendered the accumulator inoperable.
==
Description:==
On April 15, 2024, the licensee identified a nitrogen leak in containment. The containment nitrogen supply isolation valve, 3-PXS-V042, was closed to stop the leak.
Operations placed caution tag (3-CA-PXS-00004(2)) on 3-PXS-V042 and the passive core cooling system accumulator "A" nitrogen solenoid valve, 3-PXS-V021A, on April 22, 2024.
The caution tag contained instructions to "maintain 3-PXS-V021A/B closed at all times until the nitrogen header leak is identified and isolated."
9 On August 26, 2024, the licensee lowered reactor coolant drain tank (RCDT) level. The evolution required restoring nitrogen to the RCDT to prevent air intrusion when the tank is pumped down. While working through procedure 3-WLS-SOP-001, "Liquid Radwaste System," Rev. 14.0, to manually pump down the tank, the operator intended to open 3-PXS-V042, however; the operator inadvertently selected and opened caution tagged valve 3-PXS-V021A without reviewing the caution tag instructions. This created a nitrogen leak from accumulator "A" through the previously identified leak path into containment. Accumulator "A" pressure lowered below the minimum allowed pressure specified in Surveillance Requirement (SR) 3.5.1.3 for TS 3.5.1, "Accumulators." The licensee entered the applicable TS action, Condition B, for an inoperable accumulator that required restoration of nitrogen pressure in 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and if not, 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to place the unit in Mode 3.
The inspector determined that the operator did not review and adhere to the caution tag placed on 3-PXS-V021A in accordance with NMP-AD-003, "Equipment Clearance and Tagging," Rev. 33.1, prior to manipulating the valve. Per NMP-AD-003, section 4.1.5 (2),
states that caution tagged equipment may be operated only after reviewing and satisfying the conditions specified on the caution tag.
Corrective Actions: Operators took immediate corrective actions and closed 3-PXS-V021A to stop any further pressure reduction. Operators then restored, within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, accumulator pressure above the SR limit by raising level in the accumulator and compressing nitrogen cover gas, in accordance with the system operation procedure. The licensee entered this performance issue into its corrective action program.
Corrective Action
References:
CR 11067703 and CR 11105321 Performance Assessment:
Performance Deficiency: The failure to review and adhere to caution tag 3-CA-PXS-00004(2) in accordance with procedure NMP-AD-003, was contrary to 10 CFR 50 Appendix B, Criterion V, Instructions, Procedures, and Drawings, and was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Configuration Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the performance deficiency resulted in the inoperability of the "A" accumulator.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspector determined that this finding is of very low safety significance (Green) because all Exhibit 2, Section A, Mitigating SSCs and PRA Functionality screening questions were answered "No".
Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. Specifically, the licensee failed to use proper error reduction tools, prior to manipulating valve 3-PXS-V021A.
10 Enforcement:
Violation: Title 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that, activities affecting quality shall be accomplished in accordance with documented instructions, procedures or drawings, of a type appropriate to the circumstances.
Contrary to the above, on August 26, 2024, activities affecting quality were not accomplished in accordance with documented procedures appropriate to the circumstance. Specifically, the licensee failed to review and adhere to caution tag 3-CA-PXS-00004(2) prior to manipulating accumulator "A" nitrogen solenoid valve, 3-PXS-V021A, in accordance with procedure NMP-AD-003 section 4.1.5 (2), while lowering RCDT level. This resulted in an unplanned TS entry for an inoperable accumulator.
Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.
On October 1, 2024, the inspectors presented the integrated inspection results to Patrick Martino, Site Vice President, and other members of the licensee staff.
On July 25, 2024, the inspectors presented the inspection results for the licensed operator biennial requalification inspection to Rob Stough, Acting Plant Manager, and other members of the licensee staff.
On August 29, 2024, the inspectors presented the emergency preparedness inspection results to Keith Brown, Fleet Emergency Preparedness Director, and other members of the licensee staff.
11 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision or Date 3-AOP-901 Acts of Nature 2.0 4-AOP-901 Acts of Nature 2.0 71111.01 Procedures NMP-OS-017 Severe Weather 4.0 B-PFP-ENG-001-F3003 Pre-Fire Plan - Yard Area - South 2.0 B-PFP-ENG-001-F3101 Pre-Fire Plan - Containment Building El 82'-6" 2.0 B-PFP-ENG-001-F3102 Pre-Fire Plan - Containment Building El 92'-6" 2.0 B-PFP-ENG-001-F3103 Pre-Fire Plan - Containment Building El 107'-2" 3.0 B-PFP-ENG-001-F3104 Pre-Fire Plan - Containment Building El 118'-6" 2.0 B-PFP-ENG-001-F3105 Pre-Fire Plan - Containment Building El 135'-3" 2.0 B-PFP-ENG-001-F3106 Pre-Fire Plan - Containment Building El 145'-9" 2.0 B-PFP-ENG-001-F3107 Pre-Fire Plan - Containment Building El 166'-1" 2.0 B-PFP-ENG-001-F3108 Pre-Fire Plan - Containment Building El 250'-0" 1.0 Fire Plans B-PFP-ENG-001-F4125 Pre-Fire Plan - Auxiliary Building RCA El 135'-3" 2.0 B-FPS-MMM-004 Portable Fire Extinguishers and Fire Hose Stations Visual Inspection 9.0 B-GEN-ENG-008 Fire Equipment Functionality and Fire Protection Impairments (FPI) Requirements 10.0 NMP-ES-035-017 Fleet Fire Doors Functional Inspection Governance and Acceptance Criteria 2.0 NMP-TR-425-F01 Fire Drill Scenario Development and Approval Sheet - Drill #
B-026 6.0 71111.05 Miscellaneous NMP-TR-425-F14 Fire Drill Package 5.0
12 Inspection Procedure Type Designation Description or Title Revision or Date AP-LT-C-SIM-ES-078 AOT Scenario ES-078 1.0 AP-LT-C-SIM-ES-082 AOT Scenario ES-082 1.0 BEACON file:
ecc_071524_500 Critical Condition Summary 07/15/2024 Miscellaneous NMP-RE-019-F01 RCS B-10 Ratio Estimation Worksheet 07/15/2024 3-AOP-101 Rapid Power Reduction 1.0 3-AOP-112 Reactor Coolant Leak 1.0 3-AOP-208 Main Turbine Malfunction 4.0 3-EOP-E-0 Reactor Trip or Safeguards Actuation 1.1 3-EOP-E-1 Loss of Reactor or Secondary Coolant 2.0 3-GOP-302 Reactor Startup Mode 3 to Mode 2 2.0 71111.11Q Procedures 3-GOP-306 Plant Startup Mode 2 to 25% Power 4.0 Engineering Changes DECP -
SNC1895801 VCS Fan Relay Coordination with EPA Protection 0
71111.12 Procedures NMP-AD-041-002 Valve Maintenance for Cobalt Reduction 2.0 71111.13 Procedures B-ADM-OPS-011 Outage Risk Assessment Monitoring 2.0 Calculations SV3-MY07-VQQ-001 Data Package & Quality Release 1.0 CAR718091 U3 Manual reactor trip 07/08/2024 CR11091687 U3 LCO 3.4.3 Entry 07/09/2024 CR11092182 U3 Containment TSP Banks Wetted 07/10/2024 Corrective Action Documents CR11093816 ERT 3-24-001-11091552 Follow Up Action 5 07/16/2024 SVP_SV0_240432 Response to TE 1157877 - Technical Evaluations related to Vogtle Unit 3 Reactor Trip July 8, 2024 07/11/2024 TE1145873 While initial filling of pH Adjustment Baskets the min/max lines could not be seen 01/24/2024 TE1157877 WEC support of design transient analysis for U3 Rx trip 07/09/2024 TE1158072 U3 Containment TSP Banks Wetted 07/11/2024 Engineering Evaluations TE1159087 Lowering U3 IRWST Level Trend 07/25/2024 71111.15 Miscellaneous APP-PXS-M3-001 Passive Core Cooling System, System Specification Document 12.0
13 Inspection Procedure Type Designation Description or Title Revision or Date 3-PXS-OTS 003 Emergency Containment Sump Sampling and Analysis 1.0 NMP-AD-012 Operability Determinations 16.1 Procedures NMP-AD-012-F01 Operability Determination Support Basis 4.1 CR10025539 Loss of a main feedwater pump may unacceptably result in a reactor trip or turbine trip 02/12/2015 71111.18 Corrective Action Documents CR11091552 U3 Manual reactor trip 07/08/2024 CR 11092182 U3 Containment TSP Banks Wetted 07/10/2024 CR 11111053 Unit 3 reactor trip and safeguards 9/17/24 09/17/2024 Corrective Action Documents TE1157862 Perform MREVAL for the Plant Level Event of CR 11091552 07/09/2024 Corrective Action Documents Resulting from Inspection CR 11092749 Nylon Beam Strap Found in U3 Containment 07/12/2024 B-ADM-OPS-020 Reactor Trip Review 4.0 NMP-GM-009-F01 Restart PRB Review Checklist 8.0 Miscellaneous NMP-GM-020-F03 Event Recovery Report 2.0 Procedures 3-CNS-SOP-001 Containment System 4.0 SNC1401719 PLS logic changes for loss of main feedwater pump and valve failure Rev. 0 SNC1575787 DCP SNC1401719 Digital Implementation Rev. 0 71111.20 Work Orders SNC1895741 3-FWS-V005A replace positioner and perform diagnostic test of valve operator Rev. 0 SNC2043986 Troubleshoot Solenoid coil from 3-PXS-V108A on the bench 09/20/2024 71111.24 Work Orders SNC2046202 3-PXS-V108A Replace Solenoid coil 09/20/2024 NMP-EP-141-004-F01 VEGP Units 3 & 4, EAL Matrix HOT Conditions Rev. 3 71114.01 Procedures NMP-EP-141-004-F02 VEGP Units 3 & 4, EAL Matrix COLD Conditions Rev. 2.1 71114.08 Miscellaneous Vogtle 3&4 NRC Graded Exercise Scenario Package 08/27/2024 3-PXS-SOP-001 Passive Core Cooling System 13.0 3-WLS-SOP-001 Liquid Radwaste System 14.0 71152A Procedures NMP-AD-003 Equipment Clearance and Tagging 33.1
14 Inspection Procedure Type Designation Description or Title Revision or Date CAR 718091 U3 Manual Reactor Trip 07/08/2024 CR11091552 Vogtle 3 Reactor Trip and Safeguards Due to Failed Open Main Feed Pump Mini-Flow Valve 07/08/2024 CR11091565 3-FWS-V005A failed to full open position 07/09/2024 CR11091567 Unit 3 Safeguards Actuation 07/09/2024 Corrective Action Documents CR11091582 MSL actuation failure alarm 07/09/2024 B-ADM-OPS-020 Reactor Trip Review 4.0 EN 57215 Reactor Plant Event Notification Worksheet 07/08/2024 NMP-GM-009-F01 Restart PRB Review Checklist 8.0 Miscellaneous NMP-GM-020-F03 Event Recovery Report 2.0 71153 Procedures NMP-GM-020-F03 Event Recovery Report; Vogtle 3 Reactor Trip and Safeguards Due to Failed Open Main Feed Pump Recirc Valve 2.0