IR 05000424/2009004

IR 05000424-09-004, 05000425-09-004, on 07/01/2009 - 09/30/2009, Vogtle Electric Generating Plant, Units 1 and 2, Problem Identification and Resolution, Other Activities

ML093030261
Person / Time
Site:	Vogtle
Issue date:	10/30/2009
From:	Scott Shaeffer NRC/RGN-II/DRP/RPB2
To:	Tynan T Southern Nuclear Operating Co
References
IR-09-004
Download: ML093030261 (40)

Text

October 30, 2009

SUBJECT:

VOGTLE ELECTRIC GENERATING PLANT - NRC INTEGRATED INSPECTION REPORT 05000424/2009004 AND 05000425/2009004

Dear Mr. Tynan:

On September 30, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Vogtle Electric Generating Plant, Units 1 and 2. The enclosed integrated inspection report documents the inspection findings, which were discussed on October 23, 2009, with you and other members of your staff.

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

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

This report documents three self-revealing findings of very low safety significance that were identified which were determined to be a violation of regulatory requirements. In addition, two licensee-identified violations, which were determined to be of very low safety significance, are listed in the enclosed inspection report. However, because of the very low safety significance and because they were entered into your corrective action program, the NRC is treating these findings as non-cited violations (NCV) consistent with Section VI.A.1 of the NRCs Enforcement Policy. If you contest any NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.:

Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Vogtle Electric Generating Plant. In addition, if you disagree with the characterization of any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region II, and the NRC Resident Inspector at the Vogtle Electric Generating Plant. The information you provide will be considered in accordance with the Inspection Manual Chapter 0305.

SNC

In accordance with the Code of Federal Regulations 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosures, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Scott M. Shaeffer, Chief Reactor Projects Branch 2 Division of Reactor Projects

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

Enclosures:

1. Inspection Report 05000424/2009004 and 05000425/2009004 w/Attachment: Supplemental Information

REGION II==

Docket Nos.:

50-424, 50-425

License Nos.:

NPF-68, NPF-81

Report Nos.:

05000424/2009004 and 05000425/2009004

Licensee:

Southern Nuclear Operating Company, Inc. (SNC)

Facility:

Vogtle Electric Generating Plant, Units 1 and 2

Location:

Waynesboro, GA 30830

Dates:

July 1, 2009 through September 30, 2009

Inspectors:

M. Cain, Senior Resident Inspector

T. Chandler, Resident Inspector G. Kuzo, Senior Health Physicist (Section 2PS3, 4OA1)

A. Nielsen, Health Physicist (Section 2PS1)

D. Forbes, Health Physicist (Section 2OS3)

G. Laska, Senior Operations Examiner (Section 1R11, 4OA2)

M. Meeks, Operations Engineer (Section 1R11)

L. Mahlahla, Health Physicist Trainee

Approved by:

Scott M. Shaeffer, Chief Reactor Projects Branch 2 Division of Reactor Projects

Enclosure

SUMMARY OF FINDINGS

IR 05000424/2009-004, 05000425/2009-004; 07/01/2009 - 09/30/2009; Vogtle Electric

Generating Plant, Units 1 and 2; Problem Identification and Resolution; Other Activities.

The report covered a three-month period of inspection by a senior resident inspector, a resident inspector, three health physicists and one trainee, one senior operations examiner, and one operations examiner. Three Green, non-cited violations (NCVs) were 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 assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649,

Reactor Oversight Process, Rev 4 dated December 2006.

NRC-Identified and Self-Revealing Findings

Green.

A self-revealing NCV of 10 CFR 50, Appendix B, Criterion V,

Instructions, Procedures, and Drawings, was identified. Specifically, Vogtle Electric Generating Plants (VEGP) MOV preventative maintenance (PM) procedures lacked specific instructions that provided an adequate frequency for performing valve stem lubrication, which resulted in test failures of safety-related MOVs and affected the reliability of the MOVs safety functions. The licensee removed the hardened grease, re-lubricated and successfully tested the MOVs. They have entered the issue into their corrective action program and are in the process of revising existing maintenance procedures to change the PM frequency from 54 months to 36 months for long stem, safety-related MOV stem lubrication.

The finding was more than minor because if left uncorrected other safety related MOVs could be affected by the inadequate stem lubrication PM frequencies. The finding is associated with the configuration control attribute of the Barrier Integrity (BI) Cornerstone and affected the cornerstone objective of providing reasonable assurance that physical design barriers (e.g., containment) protect the public from radionuclide releases caused by accidents or events. Specifically, Containment Spray (CS) pump sump suction isolation MOVs experienced test failures and were declared inoperable, which required operability evaluations, thereby challenging their reliability and capability to perform their safety function. Using the Phase 1 worksheet in Attachment 4 of Manual Chapter 0609,

Significance Determination Process, the finding affected the BI cornerstone and was of very low safety significance (Green) because it did not represent an actual open pathway in the physical integrity of reactor containment. Although the CS sump suction MOVs condition affected the mitigating system cornerstone, the finding analysis was assigned to the BI cornerstone because it best reflected the dominant risk of the finding. This finding has a cross-cutting aspect in the area of PI&R, Corrective Action Program, because VEGP did not thoroughly evaluate problems such that the resolutions addressed the causes and extent of condition P.1(c). Specifically, VEGP failed to thoroughly evaluate previous conditions of degraded and hardened grease on safety-related valves, such that the extent of the condition was considered and the cause was resolved.

Green.

A self-revealing non-cited violation (NCV) was identified for a human performance error associated with inadvertently racking out the 2B emergency diesel generator (EDG) output breaker. The system operator racked out the incorrect breaker while performing lockout 2-DT-09-1217-00289 on the Auxiliary Component Cooling Water (ACCW) system. As a result, the 2B EDG was temporarily rendered inoperable.

Licensee immediately restored the 2B EDG to operable status by returning the output breaker to the connect position. The licensee entered the issue into their corrective action program.

This issue is more than minor because it is associated with a cornerstone attribute and adversely affected the objective of the Mitigating Systems cornerstone. Specifically, the performance deficiency is a human performance error which affected the availability, reliability, and capability of the B train emergency core cooling system to respond to a loss of coolant accident during a loss of off-site power. The finding was determined to be of very low safety significance (Green) because the event did not represent an actual loss of safety function of a single train for greater than its Technical Specification (TS)allowed outage time. The inspectors determined that the cause of this finding was related to the Work Practices component of the Human Performance cross-cutting area due to less-than-adequate human error prevention techniques H.4(a). Specifically, peer checking techniques were less than adequate.

Green.

A self-revealing non-cited violation (NCV) was identified for a human performance error associated with failure of an operator to verify that the discharge valve on the Nuclear Service Cooling Water (NSCW) pump #5 went closed after securing the pump as required by the operating procedure. As a result, NSCW pump #5 was rendered inoperable for several hours. Licensee immediately effected repairs to the discharge valve MOV and returned the NSCW pump #5 to operable status.

This issue is more than minor because it is associated with a cornerstone attribute and adversely affected the objective of the Mitigating Systems cornerstone. Specifically, the performance deficiency is a human performance error which affected the availability, reliability, and capability of the A train emergency core cooling system to respond to a loss of coolant accident. The finding was determined to be of very low safety significance (Green) because the event did not represent an actual loss of safety function of a single train for greater than its TS allowed outage time. The inspectors determined that the cause of this finding was related to the Work Practices component of the Human Performance cross-cutting area due to less-than-adequate human error prevention techniques H.4(a). Specifically, self checking techniques were less than adequate.

Licensee-Identified Violations

Violations of very low safety significance, which were identified by the licensee, have been reviewed by the NRC. Corrective actions taken or planned by the licensee have been entered into the licensees CAP. These violations and corrective action tracking numbers are listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status

Unit 1 started the inspection period at full rated thermal power (RTP). The unit was

shutdown on September 20 for a planned refueling outage.

Unit 2 started the inspection period at full rated thermal power (RTP). The unit reduced power to 94% to complete repairs on the heater drain system and returned to full rated thermal power (RTP) for the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

==1R04 Equipment Alignment

a. Inspection Scope

Partial System Walkdown.==

The inspectors performed partial walkdowns of the following three systems 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 documents listed in the Attachment. Additionally, the inspectors reviewed the condition report database to verify that equipment alignment problems were being identified and appropriately resolved.

C Unit 1 Train B Emergency Diesel Generator (EDG) and fuel oil transfer system while Train A EDG was out of service for six month fast-start surveillance operability test C

Unit 2 Train A&B motor-driven auxiliary feedwater systems while the Train C turbine-driven auxiliary feedwater pump was out of service due to a failed steam supply valve C

Unit 1 Train A&C auxiliary feedwater systems while the Train B motor-driven auxiliary feedwater pump was out of service due to a planned maintenance outage

b. Findings

No findings of significance were identified.

==1R05 Fire Protection

a. Inspection Scope

Fire Area Tours.==

The inspectors walked down the following five plant areas to verify the licensee was controlling 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 licensees fire protection Limiting Condition for Operation log and condition report (CR)database to verify that the corrective actions for degraded equipment were identified and appropriately prioritized. The inspectors also reviewed the licensees fire protection program to verify the requirements of Updated Final Safety Analysis Report Section 9.5.1, Fire Protection Program, and Appendix 9A, Fire Hazards Analysis, were met.

Documents reviewed are listed in the Attachment.

C Unit 2 control building level A 4KV safety related switchgear area C

Unit 2 control building level B east and west penetration areas C

Unit 1 and Unit 2 fuel handling building level A spent fuel pool heat exchanger and piping penetration areas C

Unit 1 and Unit 2 fuel handling building levels B and C piping penetration areas C

North and south firewater pump houses

b. Findings

No findings of significance were identified.

==1R11 Licensed Operator Requalification

==

.1 Resident Quarterly Observation

a. Inspection Scope

The inspectors observed operator performance on August 18, during licensed operator simulator training described on simulator exercise guide Pre-Outage Review V-RQ-SE-09601-1.0. The simulator scenarios covered operator actions resulting from an RCS leak and a loss of all vital AC power with the plant in Mode 5 and solid. The inspectors also observed the operators respond to a loss of shutdown cooling with the plant at hot mid-loop conditions. Documents reviewed are listed in the Attachment. The inspectors specifically assessed the following areas:

C Correct use of the abnormal and emergency operating procedures C

Ability to identify and implement appropriate actions in accordance with the requirements of the Technical Specifications C

Clarity and formality of communications in accordance with procedure 10000-C, Conduct of Operations C

Proper control board manipulations including critical operator actions C

Quality of supervisory command and control C

Effectiveness of the post-evaluation critique

b. Findings

No findings of significance were identified.

.2 Examiner Observation

a. Inspection Scope

During the week of July 13, 2009, the inspectors reviewed documentation, interviewed licensee personnel, and observed the administration of simulator operating tests associated with the licensees operator requalification program. Each of the activities performed by the inspectors was done to assess the effectiveness of the licensee in implementing requalification requirements identified in 10 CFR 55, Operators Licenses.

The evaluations were performed to determine if the licensee effectively implemented operator requalification guidelines established in NUREG-1021, Operator Licensing Examination Standards for Power Reactors, and Inspection Procedure 71111.11, Licensed Operator Requalification Program. The inspectors reviewed and evaluated the licensees simulation facility for adequacy for use in operator licensing examinations.

The inspectors observed three crews during the performance of simulator operating tests. Documentation reviewed included written examinations, Job Performance Measures, simulator scenarios, licensee procedures, on-shift records, licensed operator qualification records, selected watchstanding and medical records, feedback forms, and remediation plans. The inspectors also reviewed a sample of simulator performance test records (transient tests, malfunction tests, steady state test, and procedure tests),simulator modification request records, and the process for ensuring continued assurance of simulator fidelity to ensure compliance with 10 CFR 55.46 Simulation Facilities. Licensee documents reviewed during the inspection are listed in the

.

b. Findings

No findings of significance were identified.

==1R12 Maintenance Effectiveness

a. Inspection Scope

==

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

C Unit 1/2 steam generator atmospheric relief valve maintenance rule a(1) corrective action plan C

CR 2009103132, Unit 2 containment spray valve sump suction isolation failed to fully close

b. Findings

No findings of significance were identified.

==1R13 Maintenance Risk Assessments and Emergent Work Evaluation

a. Inspection Scope

==

The inspectors reviewed the following five work activities to verify plant risk was properly assessed by the licensee prior to conducting the activities. The inspectors reviewed risk assessments and risk management controls implemented for these activities to verify they were completed in accordance with 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.

C WO 2091218501, Unit 2 A train safety injection (SI) pump lube oil cooler concurrent with Unit 2 nuclear safety cooling water (NSCW) pump #3 maintenance outage C

WO 1091349201, Unit 1 T-hot wide range indicator 1TI-413A failing low concurrent with Unit 1 containment spray system Train A planned maintenance outage C

CR 2009107894, maintenance activities following unplanned 2B EDG inoperability caused by a breaker misposition C

Maintenance activities during hot mid-loop conditions (1R15)

C Replacement of Unit 2 loop 2 main feed regulation valve feedback potentiometer while performing routine maintenance on Unit 1/2 motor driven auxiliary feedwater systems during week of August 29 to September 04

b. Findings

No findings of significance were identified.

==1R15 Operability Evaluations

a. Inspection Scope

==

The inspectors reviewed the following five evaluations to verify they met the requirements of 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.

C CR 2009107537, Unit 1 CCW pump #6 oil sample from inboard bearing contains high concentrations of ferrous wear products C

CR 2009107491, Unit 1 NSCW B cooling tower core drill cut additional reinforcing bars during performance of WO# 1081982102 C

CR 2009107988, Cracks found on various cell covers on the 2BD1B Class IE 125 vdc battery during inspection C

CR 2009108134, Unit 2 NSCW pump #4 has an oil leak on the upper bearing RTD C

CR 2009108594, Water and corrosion found inside Limitorque enclosure on Unit 2 NSCW pump #5 discharge valve

b. Findings

No findings of significance were identified.

==1R18 Plant Modifications

a. Inspection Scope

Temporary Modifications.==

Reviewed temporary modification TM 2091306901 and associated 10 CFR 50.59 screening criteria against the system design bases documentation and procedure 00307-C, Temporary Modifications. Also reviewed the associated 10 CFR 50.54(q) evaluation performed by Emergency Preparedness personnel. This temporary modification placed 2RE-12444C at top-of-scale to allow 2RE-12444D and E to be able to monitor gaseous activity released from the plant during an event. Reviewed implementation, configuration control, and operator awareness for this temporary modification.

b. Findings

No findings of significance were identified.

==1R19 Post-Maintenance Testing

a. Inspection Scope

==

The inspectors either observed post-maintenance testing or reviewed the test results for the following six maintenance activities to verify that the testing met the requirements of procedure 29401-C, Work Order Functional Tests, for ensuring equipment operability and functional capability was restored. The inspectors also reviewed the test procedures to verify the acceptance criteria were sufficient to meet the TS operability requirements.

C WO 2080955401, Calibration and replacement of Unit 2 NSCW pump #3 agastat relay 162-1 C

WO 2091274001, Loop 1 steam supply to turbine driven auxiliary feedwater (TDAFW) pump C

Unit 1 containment spray pump 1B outage C

WO 1081521501, Steady increase in motor and pump vibration on NSCW transfer pump #7 C

Unit 1 train B auxiliary feed water system outage C

Unit 1 train A centrifugal charging pump system outage

b. Findings

No findings of significance were identified.

==1R20 Refueling and Other Outage Activities

a. Inspection Scope

==

The inspectors performed the inspection activities described below for the Unit 1 refueling outage that began on September 20. This review also focused on licensee preparations for hot (fuel in vessel) midloop evolutions which had not been performed at Vogtle for numerous refueling cycles. The inspectors confirmed that, when the licensee removed equipment from service, the licensee maintained defense-in-depth commensurate with the outage risk control plan for key safety functions and applicable TS and that configuration changes due to emergent work and unexpected conditions were controlled in accordance with the outage risk control plan. Documents reviewed are listed in the Attachment. Inspection activities included:

C Prior to the outage, the resident inspectors reviewed the licensees integrated risk control plan to verify that activities, systems, and/or components which could cause unexpected reactivity changes were identified in the outage risk plan.

C Observed portions of the plant shutdown and cooldown to verify that the technical specification cooldown restrictions were followed.

C Reviewed reactor coolant system pressure, level and temperature instruments to verify that the instruments provided accurate indication and that allowances were made for instrumentation errors.

C Verified that outage work did not impact the operation of the spent fuel cooling system.

C Reviewed the status and configuration of electrical systems to verify that those systems met technical specification requirements and the licensees outage risk control plan.

C Observed decay heat removal parameters to verify that the system was properly functioning and providing cooling to the core, specifically during hot mid-loop operations.

C Reviewed system alignments to verify that the flow paths, configurations and alternative means for inventory addition were consistent with the outage risk plan.

C Reviewed selected control room operations to verify that the licensee was controlling reactivity in accordance with the technical specifications.

C Observed the licensees control of containment penetrations to verify that the requirements of the technical specifications were met.

C Reviewed the licensees plans for changing plant configuration to verify that technical specifications, license conditions and other requirements, commitments and administrative procedure prerequisites were met prior to changing plant configuration.

C Inspection of containment for as-found degraded conditions.

b. Findings

No findings of significance were identified.

==1R22 Surveillance Testing

a. Inspection Scope

==

The inspectors reviewed the following five surveillance test procedures and either observed the testing or reviewed test results to verify that testing was conducted in accordance with the procedures and that the acceptance criteria adequately demonstrated that the equipment was operable. Additionally, the inspectors reviewed the CR database to verify that the licensee had adequately identified and implemented appropriate corrective actions for surveillance test problems.

Surveillance Tests C

14980A-1, Diesel Generator 1A Operability Test C

14982-2 Rev. 2.3, Diesel Generator Fuel Oil Transfer System 18 Month Test C

28912-C Rev. 51, 92-day Battery and Charger Inspection and Maintenance

In-Service Tests (IST)

C 14810-2 Rev. 38.2, TDAFW Pump and Check Valve IST Response Time Test C

14808A-2 Rev. 1.2, Train A Centrifugal Charging Pump and Check Valve IST Response Time Test

b. Findings

No findings of significance were identified.

1EP6 Drill Evaluation

a. Inspection Scope

The inspectors reviewed the facility activation exercise guide and observed the following emergency 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.

C On July 29, the licensee conducted an emergency preparedness drill. The drill scenario started with a medium loss-of-coolant accident with multiple stuck rods, followed by a fuel element failure then containment failure due to a fire, resulting in an uncontrolled release of activity. The technical support center was activated and the site participated in the exercise.

b. Findings

No findings of significance were identified.

RADIATION SAFETY

Cornerstones: Occupational Radiation Safety (OS) and Public Radiation Safety (PS)2OS3 Radiation Monitoring Instrumentation and Protective Equipment

a. Inspection Scope

Radiation Monitoring Instrumentation. During tours of the Unit 1 and Unit 2 reactor auxiliary building (RAB), Spent Fuel Pool (SFP) and radiologically controlled area (RCA)exit locations, the inspectors observed and evaluated operation of installed radiation detection equipment including area radiation monitor (ARM), continuous air monitor (CAM), personnel contamination monitor (PCM), and portal monitor (PM)instrumentation. The evaluations included component material, condition and compared physical location and sensitivity ranges of the instrumentation with Updated Final Safety Analysis Report (UFSAR) details.

In addition to equipment walk-downs, the inspectors observed functional checks and alarm set-point testing of various fixed and portable detection instruments, including portable ion chambers, teletectors, PCMs, and PMs. The most recent 10 CFR Part 61 analysis for Dry Active Waste (DAW) was reviewed to determine if calibration and check sources were representative of the plant source term. The inspectors reviewed calibration records for selected PCMs, PMs, and Small Article Monitors (SAMs) located at the RCA exit location. Historical calibration records were also reviewed for ARM channels 1RE-0005 and 1RE-0006 (Containment High Range Monitors), 1RE-0011 (In-Core Instrument Room Area Monitor), and ARM 16972 (Radwaste Processing Area Monitor). Calibration timeliness was reviewed by observation of portable survey instrument data during inspection of storage areas for Aready-to-use@ equipment.

Operability and reliability of selected radiation detection instruments were reviewed against details documented in the following: 10 CFR Part 20; NUREG-0737, Clarification of TMI Action Plan Requirements; Technical Specification Sections 3 and 5; UFSAR Chapter 12; and applicable licensee procedures. Documents reviewed during the inspection are listed in Section 2OS3 of the Attachment.

Self-Contained Breathing Apparatus (SCBA) and Protective Equipment. Selected SCBA units staged for emergency use in the Control Room, Emergency Operations/Training Facility, and the Operations Support Center were inspected for material condition, air pressure and number of units available. The inspectors also reviewed maintenance records for selected SCBA regulators for the past five years and certification records associated with supplied air quality.

Qualifications for individuals responsible for testing and repairing SCBA vital components were evaluated through review of training records. In addition, Control Room operators were interviewed to determine their knowledge of available SCBA equipment locations, including corrective lens inserts, if needed and their training on bottle change-out during a period of extended SCBA use. Respirator qualification records were reviewed for several Control Room operators and emergency responder personnel.

Licensee activities associated with maintenance and use of respiratory protection equipment were reviewed against 10 CFR Part 20; Regulatory Guide (RG) 8.15, Acceptable Programs for Respiratory Protection; and applicable licensee procedures.

Documents reviewed during the inspection are listed in Section 2OS3 of the Attachment.

Problem Identification and Resolution. Selected licensee Nuclear Condition Report documents associated with instrumentation and protective equipment were reviewed and assessed. The inspectors evaluated the licensee=s ability to identify, characterize, prioritize and resolve the identified issues in accordance with procedure NMP-GM-002, Corrective Action Program, Rev. 8. The inspectors also evaluated the scope of the licensees internal audit program and reviewed recent assessment results. Documents reviewed are listed in Section 2OS3 of the Attachment.

The inspectors completed all nine of the required line-item samples detailed in Inspection Procedure (IP) 71121.03.

b. Findings

No findings of significance were identified.

2PS1 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems

a. Inspection Scope

Effluent Monitoring and Radioactive Waste Equipment. During inspector walk-downs, accessible sections of the liquid and gaseous radioactive waste (radwaste) and effluent systems were assessed for material condition and conformance with system design diagrams. The inspection included floor drain tanks, liquid waste system piping, monitor tanks, liquid radwaste monitors, waste gas compressors, plant vent effluent monitors, and associated airborne effluent sample lines. The inspectors interviewed licensee staff regarding radwaste equipment configuration, recent changes to radwaste systems and effluent monitor operation.

The inspectors reviewed performance records and calibration results for selected radiation monitors, flowmeters and air filtration systems. For effluent monitors ARE-16980 (Radwaste Processing Facility), RE12442 (U1 Plant Vent), RE0018 (U1 Waste Liquid Effluent) and RE2565 (U1 Containment Vent), the inspectors reviewed the last two isotopic calibration records. The last two surveillances on the U1 RAB High Efficiency Particulate Air (HEPA) and charcoal air treatment systems were also reviewed. The inspectors evaluated out-of-service effluent monitors and compensatory action data for the period October 2007 - June 2009. In addition, plant vent sample line and vent duct flowrates were reviewed and discussed with chemistry staff to evaluate the adequacy of representative sampling.

Installed configuration, material condition, operability and reliability of selected effluent sampling and monitoring equipment were reviewed against details documented in the following: 10 CFR Part 20; RG 1.21, Measuring, Evaluating and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials In Liquid and Gaseous Effluents from Light-Water Cooled Nuclear Power Plants; American Nuclear Standards Institute (ANSI)-N13.1-1969, Guide to Sampling Airborne Radioactive Materials in Nuclear Facilities; TS Section 5; the Offsite Dose Calculation Manual (ODCM); and UFSAR, Chapter 11. Procedures and records reviewed during the inspection are listed in Section 2PS1 of the report Attachment.

Effluent Release Processing and Quality Control Activities. The inspectors reviewed licensee procedures for sample collection and directly observed collection of weekly airborne effluent samples from the U2 Plant Vent and a batch release sample from a Waste Monitor Tank. Chemistry technician proficiency in collecting, processing, and counting the samples, as well as preparing the applicable release permits, was evaluated. The inspectors reviewed recent liquid and gaseous release permits including pre-release sampling results, effluent monitor setpoints and accuracy of offsite dose calculations. The inspectors also reviewed the 2007 and 2008 annual effluent reports to evaluate reported doses to the public and to review ODCM changes.

Quality Control (QC) activities regarding gamma spectroscopy and beta-emitter detection were discussed with count room technicians and Chemistry supervision. For selected high-purity germanium detectors the inspectors reviewed calibration records, daily QC checks and associated trending graphs. In addition, results of the 2007 and 2008 radiochemistry cross-check program were reviewed.

Observed task evolutions, count room activities and offsite dose results were evaluated against details and guidance documented in the following: 10 CFR Part 20 and Appendix I to 10 CFR Part 50; ODCM; RG 1.21; RG 1.109, Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50 Appendix I; and TS Section 5. Procedures and records reviewed during the inspection are listed in Section 2PS1 of the Attachment.

Problem Identification and Resolution. Selected CRs associated with effluent release activities were reviewed and assessed. The inspectors evaluated the licensees ability to identify, characterize, prioritize, and resolve selected issues in accordance with procedure NMP-GM-002, Corrective Action Program, Rev 8.0. The inspectors also evaluated the scope of the licensees internal audit program and reviewed recent assessment results. Reviewed documents are listed in Section 2PS1 of the Attachment.

The inspectors completed all three specified line-item samples detailed in IP 71122.01.

b. Findings

No findings of significance were identified.

2PS3 Radiological Environmental Monitoring Program (REMP) and Radioactive Material Control Program

a. Inspection Scope

REMP Implementation The inspectors observed selected environmental monitoring program sample collection and monitoring activities as specified in the licensees ODCM.

The inspectors observed material condition and noted operability, including verification of air sampling equipment flowrates, and observed the weekly airborne particulate filter and iodine cartridge change-outs at five sample stations. The inspectors directly observed collection and initial field preparation of milk samples at two dairy farms located within 10 miles of the plant site. Also, the inspectors verified location and material condition of nine environmental thermoluminescent dosimeters. Land use census results, missed samples and changes to the ODCM and sample collection/processing activities including recent changes for milk sampling, were discussed with environmental technicians and knowledgeable licensee staff.

The inspectors reviewed the last two semiannual air flow calibration records for the environmental air sampling stations. The inspectors also reviewed calendar year (CY)2007 and CY 2008 Radiological Environmental Operating Reports, CY 2007 and CY 2008 inter-laboratory cross-check program results and current procedural guidance for environmental sample collection and processing. Selected environmental measurements were reviewed for consistency with licensee effluent data and evaluated for radionuclide concentration trends. The inspectors independently verified detection level sensitivity requirements for iodine monitoring in milk and water samples.

Procedural guidance, program implementation, quantitative analysis sensitivities, and environmental monitoring results were reviewed against 10 CFR Part 20; Appendix I to 10 CFR Part 50; TS Sections 5.4.1, 5.5.1, and 5.6; ODCM; RG 4.15, Quality Assurance for Radiological Monitoring Programs (Normal Operation) - Effluent Streams and the Environment; and the Branch Technical Position, An Acceptable Radiological Environmental Monitoring Program - 1979. Documents reviewed are listed in Section 2PS3 of the Attachment.

Meteorological Monitoring Program During tours of the meteorological tower and local data collection equipment, the inspectors observed the physical condition of the tower and its instruments and discussed equipment operability and maintenance history with the system engineer. The inspectors evaluated transmission of locally generated meteorological data to the main control room operators. For the meteorological measurements of wind speed, wind direction and temperature, the inspectors reviewed the two previous semiannual calibration records for applicable tower instrumentation and evaluated measurement data recovery for calendar years 2008 and 2009. In addition, the inspectors discussed the meteorological tower backup power supply surveillances, and reviewed and discussed control room meteorological tower trouble alarm control room panel activities daily surveillances performed during operator rounds.

Licensee procedures and activities related to meteorological monitoring were evaluated against: ODCM; UFSAR; Regulatory Guide 1.23, Meteorological Monitoring Programs For Nuclear Power Plants, and ANSI/ANS-2.5-1984, Standard for Determining Meteorological Information at Nuclear Power Sites. Documents reviewed are listed in Section 2PS3 of the Attachment.

Unrestricted Release of Materials from the Radiologically Controlled Area (RCA) The inspectors observed surveys of material and personnel being released from the RCA using small article monitor, personnel contamination monitor and portal monitor instruments. The inspectors also observed source check testing of these instruments and discussed equipment sensitivity, alarm set-points and release program guidance with licensee staff. The inspectors compared recent 10 CFR Part 61 results for the DAW waste stream with radionuclides used in calibration and check sources to evaluate the appropriateness and accuracy of release survey instrumentation. The inspectors also reviewed the last two calibration records for selected release point survey instruments.

Licensee programs for monitoring materials and personnel released from the RCA were evaluated against 10 CFR Part 20 and IE Circular 81-07, Control of Radioactively Contaminated Material. Documents reviewed are listed in Sections 2OS3 and 2PS3 of the Attachment.

Problem Identification and Resolution The inspectors reviewed selected CRs in the areas of environmental monitoring, meteorological monitoring, and release of materials.

The inspectors evaluated the licensees ability to identify, characterize, prioritize, and resolve the identified issues in accordance with NMP-GM-002, Corrective Action Program, Rev 8.0. The inspectors also evaluated the scope of the licensees internal audit program and reviewed recent assessment results. Documents reviewed are listed in section 2PS3 in the Attachment.

The inspectors completed all ten specified line-item samples detailed in IP 71122.03.

b. Findings

No findings of significance were identified.

4OA1 Performance Indicator (PI) Verification

.1 Mitigating Systems Cornerstone

a. Inspection Scope

The inspectors sampled licensee submittals for the listed PIs during the period from July 1, 2008 through June 30, 2009, for Unit 1 and Unit 2. The inspectors verified the licensees 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.

C Mitigating Systems Performance Index, High Pressure Injection System C

Mitigating Systems Performance Index, Residual Heat Removal System C

Mitigating Systems Performance Index, Heat Removal System

The inspectors reviewed Unit 1 and Unit 2 operator log entries, the Vogtle MSPI basis document, the monthly 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

.2 Public Radiation Safety Cornerstone

a. Inspection Scope

The inspectors reviewed the Radiological Control Effluent Release Occurrences PI results for the Public Radiation Safety Cornerstone from September 2008 through March 2009. For the assessment period, the inspectors reviewed cumulative and projected doses to the public, out-of-service effluent radiation monitors and compensatory sampling data, and selected CRs related to Radiological Effluent Technical Specifications/ODCM issues. The inspectors also reviewed licensee procedural guidance for collecting and documenting PI data. Documents reviewed are listed in sections 4OA1 and 2PS1 of the Attachment.

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems

.1 Daily Condition Report Review.

As required by Inspection Procedure 71152, Identification and Resolution of Problems, and in order to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensees corrective action program. This review was accomplished by either attending daily screening meetings that briefly discussed major CRs, or accessing the licensees computerized corrective action database and reviewing each CR that was initiated.

.2 Focused Review

a. Inspection Scope

This inspection focused on VEGPs identification, evaluation, and resolution of challenges associated with hardened grease on safety-related MOVs. Specifically, two CS valves failed surveillance testing on March 29 and August 05, 2009. MOV disassembly and inspection identified hardened grease on the stem and inside the stem nut of both valves. Initial extent-of-condition evaluations revealed that one of five MOVs inspected, 2HV9003A CS sump suction isolation valve had marginal closing thrust due to hardened stem grease. The final extent-of-condition scoping determined that 24 safety-related MOVs required additional evaluation appropriate to the circumstances, such as visual inspection, grease evaluation, diagnostic testing, and/or corrective maintenance.

The inspectors reviewed VEGPs associated root cause evaluation, operability evaluations, corrective action reports, and a sample of diagnostic and stroke time test data, and interviewed plant personnel to evaluate the adequacy of VEGPs performance in the areas of problem identification, evaluation, extent-of-condition scoping, and corrective actions. Finally, the inspectors reviewed MOV program procedures to evaluate the quality and effectiveness of the licensees MOV program, as implemented at VEGP.

The inspectors performed a detailed review of the following CRs to verify the full extent of the issue was identified, an appropriate evaluation was performed, and appropriate corrective actions were specified and prioritized. The inspectors evaluated the CR against the licensees corrective action program as delineated in licensee procedure NMP-GM-002, Corrective Action Program, and 10 CFR 50, Appendix B. Documents reviewed are listed in the Attachment.

C CR 2009103132, 2HV9003B containment spray sump suction isolation valve failed to fully close C

CR 2009107542, 1HV9003A failed as-found viper test due to hardened stem lubricant

b. Findings and Observations

Introduction.

A Green self-revealing NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified. Specifically, Vogtle Electric Generating Plants (VEGP) MOV preventative maintenance (PM) procedures lacked specific instructions to prescribe an acceptable frequency for performing valve stem lubrication, which resulted in test failures of safety-related MOVs and affected the reliability of the MOVs safety functions.

Description.

During quarterly surveillance testing performed by VEGP on March 29, 2009, the Unit 2 CS sump suction isolation valve MOV (2HV9003B) failed to stroke full closed during its quarterly surveillance test and was subsequently declared inoperable.

Investigation by VEGP identified both a defective torque switch and dried and hardened grease on the valve stem and stem nut, and a root cause investigation was assigned to VEGP engineering staff. Extent-of-condition inspections were performed by VEGP on select safety-related MOVs over the next several days. Degraded grease was identified on one other Unit 2 CS sump suction isolation MOV (2HV9003A), but the condition was determined not to impact valve operability. VEGPs root cause evaluation determined the initial event to be an isolated case most likely caused by grease cross-contamination (Felpro N-5000 mixed with Nebula EP-0). VEGP utilizes Felpro N-5000 Neverseez grease for valve stem lubrication which has a five year shelf life. Subsequently, on August 5, 2009, the Unit 1 CS sump suction isolation valve MOV (1HV9003A) failed as-found viper test for minimum required thrust and was declared inoperable. Investigation by VEGP identified hardened grease on the stem and inside the stem nut. As a result of the failure, VEGP expanded the extent-of-condition scope to include diagnostic testing of long stem, i.e. > 2 inches stroke length that had reached at least 36 months of their original 54 month PM frequency. The NRC inspectors reviewed the final extent-of-condition scoping, and found that it was appropriate to the circumstances.

VEGP performed immediate corrective actions after each of the MOV failures, which included cleaning and removing the old grease from the stem and stem nut area, applying new grease, and performing diagnostic testing to ensure successful valve performance. VEGP performed operability evaluations for each of the MOV failures, and concluded the MOVs would have been capable of performing their intended safety function for all design basis events. The inspectors reviewed the operability evaluations and agreed that licensees conclusions regarding past operability were reasonable.

However, the capability of the MOVs to perform their mitigating safety functions was challenged, thereby impacting their reliability.

The apparent cause determination for the initial failure was updated in response to the additional failure. The updated apparent cause evaluation determined that VEGP MOV PM frequencies and actions had not appropriately included stem lubricant performance feedback and that a previous PM frequency revision from 36 months to 54 months was not adequately evaluated. The NRC inspectors reviewed the apparent cause evaluation and agreed that an adequate MOV program would schedule and adjust PM activities as necessary to assure that safety-related MOVs can perform their functions as required.

Analysis.

The inspectors determined that VEGPs failure to properly implement MOV preventive maintenance activities, specifically with respect to stem lubrication necessary to assure that MOVs would function when required, constituted a performance deficiency. Specifically, degraded stem lubrication was identified as a common factor in two safety-related MOV test failures between March 29, 2009 and August 5, 2009. The finding was more than minor because if left uncorrected other safety related MOVs could be affected by the inadequate stem lubrication PM frequencies. The finding is associated with the configuration control attribute of the Barrier Integrity (BI) Cornerstone and affected the cornerstone objective of providing reasonable assurance that physical design barriers (e.g., containment) protect the public from radionuclide releases caused by accidents or events. Specifically, Containment Spray (CS) pump sump suction isolation MOVs experienced test failures, were declared inoperable, and required operability evaluations, thereby challenging their reliability and capability to perform their safety function. Using the Phase 1 worksheet in Attachment 4 of Manual Chapter 0609, Significance Determination Process, the finding affected the BI cornerstone and was of very low safety significance (Green) because it did not represent an actual open pathway in the physical integrity of reactor containment. Although the CS sump suction MOVs condition affected the mitigating system cornerstone, the finding analysis was assigned to the BI cornerstone because it best reflected the dominant risk of the finding.

This finding has a cross-cutting aspect in the area of PI&R, Corrective Action Program, because VEGP did not thoroughly evaluate problems such that the resolutions addressed the causes and extent of condition P.1(c). Specifically, VEGP failed to thoroughly evaluate previous conditions of degraded and hardened grease on safety-related valves, such that the extent of the condition was considered and the cause was resolved. This cross-cutting aspect is applied to both Units 1 and 2.

Enforcement.

10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Contrary to the above, the VEGP MOV program preventative maintenance procedure (SCL0021) was not appropriate to the circumstances, in that, it lacked specific instructions to prescribe an acceptable frequency for performing valve stem lubrication, given the limited shelf life of the MOV lubrication grease used by the station as described in the above section. As a consequence of this, two safety-related MOVs experienced test failures between March 29, 2009 and August 5, 2009, attributed to degraded and hardened lubricating grease. Because this finding is of very low safety significance and has been entered into VEGPs CAP (CRs 2009103132, 2009107542 and 2009108077), this violation is being treated as a Green NCV consistent with section VI.A.1 of the NRC Enforcement Policy: NCV 05000424/2009004-01, and NCV 05000425/2009004-01, MOV Program Procedures were Inadequate with Regard to Periodicity of Preventive Maintenance Activities for Stem Lubrication.

.3 Annual Sample Review

a. Inspection Scope

The inspectors selected Condition Report (CR) 2009100594 for a detailed review. The CR was initiated due to an internal audit determining that the week 4 biennial requalification examination contained more repeat questions from the first three weeks than allowed by procedure 60007-C Licensed Operator Requalification Examination Guidelines, Revision 17.1. The inspectors verified that the number of repeat questions did exceed the number allowed by procedure 60007-C Licensed Operator Requalification Examination Guidelines, Revision 17.1. Inspectors reviewed Inspection Procedure 71111.11B Licensed Operator Requalification Program, Appendix D evaluation that determined that the repeat questions did not lead to an examination compromise and, therefore, the issue was dispositioned as having minor safety significance. Inspectors also determined that this issue had been completely and accurately identified in the licensees Corrective Action Program (CAP) and that any challenges to the biennial requalification examination integrity were properly analyzed and prioritized for resolution, and apparent cause determinations were sufficiently thorough. Appropriate corrective actions were implemented in a manner consistent with the corrective action program.

b. Findings

No findings of significance were identified.

.4 Semi-Annual Trend Review

a. Inspection Scope

The inspectors performed a review of the licensees Corrective Action Program and associated documents to identify trends which could indicate the existence of a more significant safety issue. The review was focused on repetitive equipment issues, but also considered the results of inspector daily CR screening and the licensees trending efforts.

The review nominally considered the six month period of April 2009 through September 2009 although some examples extended beyond those dates when the scope of the trend warranted. The inspectors also reviewed several CRs associated with operability determinations which occurred during the period. The inspectors compared and contrasted their results with the results contained in the licensees two latest Integrated Performance Assessments (IPAs). Corrective actions associated with a sample of the issues identified in the licensees trend reports were reviewed for adequacy. The inspectors also evaluated the trend reports against the requirements of the licensees corrective action program as specified in licensee procedure NMP-GM-002, Corrective Action Program, and 10 CFR 50, Appendix B. Documents reviewed are listed in the

.

b. Findings and Observations

No findings of significance were identified. However, the relatively high number of issues associated with procedural compliance identified during this review period could possibly indicate a negative trend. The following are examples of issues where procedure compliance and/or adherence was either the root cause or contributing cause of the issues noted:

C CR 2009106565 Changes made to Emergency Response Data System (ERDS)

were not reported to NRC within 30 days C

CR 2009107062 Operator inadvertently loads crane while attempting to remove

slack from cable during new fuel receipt C

CR 2009107569 Firing Range Masters Calling Card not in accordance with

approved procedure C

CR 2009107586 Procedural rigor and compliance inadequate during surveillance

on 1A emergency diesel generator C

CR 2009108517 Procedure compliance issues identified while maintenance

personnel were replacing a main feed regulation valve feedback potentiometer C

CR 2009109285 Personnel attempted to raise the containment equipment hatch

with two hold down bolts secured in position

No findings of significance were identified. All of the procedure compliance issues reviewed were determined to be minor performance deficiencies.

4OA5 Other Activities

.1 Human Performance Error Renders 2B EDG Inoperable

a. Inspection Scope

Resident inspectors reviewed the circumstances surrounding a human performance error that rendered the 2B EDG inoperable, as described in condition report CR 2009107894.

The inspectors interviewed the operators on-shift at the time of the event, reviewed the condition report and subsequent disposition, evaluated the results of the associated human performance board, and reviewed the applicable procedures.

b. Findings

Introduction.

A Green self-revealing non-cited violation (NCV) was identified for a human performance error associated with inadvertently racking out the 2B emergency diesel generator (EDG) output breaker. The system operator racked out the incorrect breaker while performing lockout 2-DT-09-1217-00289 on the Auxiliary Component Cooling Water (ACCW) system. As a result, the 2B EDG was temporarily rendered inoperable.

Description.

On August 17 while performing lockout 2-DT-09-1217-00289 on the ACCW system, the system operator inadvertently racked out 2B EDG output breaker (2BA03 bkr 19) instead of the breaker for the ACCW pump (2BA03 bkr 20). The control room operators immediately identified the error due to numerous control room alarms indicating improper lineup of the 2B EDG. The control room operators directed the system operators to stop work. Within 15 minutes, the 2B EDG output breaker was racked back in to the connect position and the diesel was declared available.

Operations personnel then performed a surveillance to verify operability of the 2B EDG.

Analysis.

While performing a lockout on the ACCW system, the system operator inadvertently racked out 2B emergency diesel generator (EDG) output breaker. This is a performance deficiency because the operator did not follow the written instructions in the procedure. This issue is more than minor because it is associated with a cornerstone attribute and adversely affected the objective of the Mitigating Systems cornerstone.

Specifically, the performance deficiency is a human performance error which affected the availability, reliability, and capability of the B train emergency core cooling system to respond to a loss of coolant accident during a loss of off-site power. The finding was determined to be of very low safety significance (Green) because the event did not represent an actual loss of safety function of a single train for greater than its Technical Specification allowed outage time. The inspectors determined that the cause of this finding was related to the Work Practices component of the Human Performance cross-cutting area due to less-than-adequate human error prevention techniques H.4(a).

Specifically, peer checking techniques were less than adequate.

Enforcement.

The inspectors determined that the finding represents a violation of regulatory requirements because it involved improper implementation of procedures associated with safety-related plant equipment. Technical Specification 5.4 requires that written procedures, specified in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978, shall be established, implemented, and maintained. Regulatory Guide 1.33 states that procedures are required for certain administrative actions, which include the locking and tagging actions. Contrary to the above, on 8/17/09, operations personnel racked out the incorrect breaker while performing lockout 2-DT-09-1217-00289 on the ACCW system. As a result of the violation, the 2B EDG was rendered inoperable for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 21 minutes. Because this violation was of very low safety significance and it was entered into the licensees corrective action program (ref. CR 2009107894), this violation is being treated as an NCV, consistent with the NRC Enforcement Policy. This finding will be tracked as NCV 05000425/2009004-02, Human Performance Error Renders 2B EDG Inoperable.

.2 Human Performance Error Renders NSCW Pump #5 Inoperable

a. Inspection Scope

Resident inspectors reviewed the circumstances surrounding a human performance error that unknowingly rendered the NSCW pump #5 inoperable, as described in condition reports CR 2009108577, CR 2009108594, and CR 2009108670. The inspectors interviewed the operators on-shift at the time of the event, reviewed the Condition Reports and subsequent dispositions, evaluated the results of the associated human performance board, and reviewed the applicable procedures.

b. Findings

Introduction.

A Green self-revealing non-cited violation (NCV) was identified for a human performance error associated with failure of an operator to verify that the discharge valve on the Nuclear Service Cooling Water (NSCW) pump #5 went closed after securing the pump as required by the operating procedure. As a result, NSCW pump #5 was rendered inoperable for several hours.

Description.

On September 4 at 2200, preparations were being made to facilitate performance of surveillance 14616-2, SSPS Slave Relay K 609 Train A Test Safety Injection. The preparations included realigning the NSCW pumps in Train A so that pumps #1 and #3 were operating and that pump #5 was stopped and in standby. The Unit 2 NSCW pump #1 was started at 2204 and pump #5 was stopped at 2207 per system operating procedure 13150A-2, Train A Nuclear Service Cooling Water System.

Step 4.2.1.1.c of procedure 13150A-2 requires the operator to stop the NSCW pump to be placed in standby and check that the pumps discharge valve closes completely after the pump stops. The operator that was performing the step to stop the pump and check the discharge valve position was distracted by an alarm on an adjacent control room panel. The operator stepped away from the control panel briefly to acknowledge the alarm. When the operator returned to verify that the discharge valve on the #5 NSCW pump had gone closed, he mistakenly looked at the discharge valve indicator for NSCW pump #6, which was correctly closed. This resulted in the operator not identifying the fact that the discharge valve on NSCW pump #5 had failed to close after the pump was stopped. On 9/05/09 at 0110 hours0.00127 days <br />0.0306 hours <br />1.818783e-4 weeks <br />4.1855e-5 months <br />, while surveillance procedure 14616-2 was in progress, NSCW pump #5 failed to start when demanded by the SI signal. The pump would not start because the discharge valve was not fully closed, which is required in the start permissive circuit for the pump. NSCW pump #5 was immediately declared inoperable and the surveillance was declared unsatisfactory.

Analysis.

While shifting the operating pumps in the Train A NSCW system, the operator failed to verify that the discharge valve of the NSCW pump he had just secured closed as designed. This is a performance deficiency because the operator did not follow the written instructions in procedure 13150A-2, Train A Nuclear Service Cooling Water System. This issue is more than minor because it is associated with a cornerstone attribute and adversely affected the objective of the Mitigating Systems cornerstone.

Specifically, the performance deficiency is a human performance error which affected the availability, reliability, and capability of the A train emergency core cooling system to respond to a loss of coolant accident. The finding was determined to be of very low safety significance (Green) because the event did not represent an actual loss of safety function of a single train for greater than its Technical Specification allowed outage time.

The inspectors determined that the cause of this finding was related to the Work Practices component of the Human Performance cross-cutting area due to less-than-adequate human error prevention techniques H.4(a). Specifically, self checking techniques were less than adequate.

Enforcement.

The inspectors determined that the finding represents a violation of regulatory requirements because it involved improper implementation of procedures associated with safety-related plant equipment. Technical Specification 5.4 requires that written procedures, specified in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978, shall be established, implemented, and maintained. Regulatory Guide 1.33 states that procedures are required for certain safety-related systems, which include the safety-related service cooling water system. Contrary to the above, on 9/04/09, the operator did not identify the fact that the discharge valve on NSCW pump #5 had failed to close after the pump was stopped. As a result of the violation, the Unit 2 NSCW pump #5 was unknowingly rendered inoperable for 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and 3 minutes. Because this violation was of very low safety significance and it was entered into the licensees corrective action program (ref. CR 2009108577, CR 2009108594, CR 2009108670), this violation is being treated as an NCV, consistent with the NRC Enforcement Policy. This finding will be tracked as NCV 05000425/2009004-03, Human Performance Error Renders NSCW Pump #5 Inoperable.

.3 Quarterly Resident Inspector Observations of Security Personnel and Activities

a. Inspection Scope

During the inspection period, the inspectors conducted observations of security force personnel and activities to ensure that the activities were consistent with licensee security procedures and regulatory requirements relating to nuclear plant security. These observations took place during both normal and off-normal plant working hours.

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

b. Findings and Observations

No findings of significance were identified.

4OA6 Meetings, Including Exit

.1 Exit Meeting

On October 23, 2009, the resident inspectors presented the inspection results to you and other members of his staff, who acknowledged the findings. The inspectors confirmed that proprietary information was not provided or examined during the inspection.

On July 17, 2009, the inspectors discussed results of the onsite radiation protection inspection with you and other responsible staff. The inspectors noted that proprietary information was reviewed during the course of the inspection but would not be included in the documented report. During a August 3, 2009, teleconference with Mr. S. Varnum, Acting Chemistry Manager, the inspectors discussed their resolution of previous concerns associated with the collection of grab sampling at the U2 main plant stack low range gas monitor (2RE-12442c) and the adequacy of the U2 main plant vent gas monitoring system (2RE-12444c), to appropriately monitor gaseous releases under routine and off-normal effluent release conditions. Based on review of monitors use, applicable procedural guidance and implementation, the inspectors noted that no radiation monitoring performance deficiencies were identified for either monitor and the issue was considered closed.

An exit meeting was also conducted on July 17, 2009, to discuss the findings of onsite licensed operator requalification program inspection. One issue involving simulator testing was discussed at the exit and required the licensee to provide additional information. Inspectors reviewed this information and re-exited with Mr. R. Brigdon on August 11, 2009, to discuss this issue. The inspectors confirmed that no proprietary information was retained during this inspection.

4OA7 Licensee Identified Violations

The following violations of very low safety significance (Green) were identified by the licensee and are a violation of NRC requirements which meet the criteria of the NRC Enforcement Policy, for being dispositioned as a Non-Cited Violations.

C TS 3.7.9 Condition A requires that one or more Nuclear Service Cooling Water (NSCW) basins be within water temperature and level limits. Contrary to this on September 16, 2009, when the plant was in mode 1, licensee personnel rendered the B train Ultimate Heat Sink (UHS) incapable of fulfilling its 30 day mission time based on NSCW system back leakage caused during the performance of section 4.4.6, Chilled Water Alignment to the B Train Containment Auxiliary Cooler and Reactor Cavity Cooler, of procedure 13743-C, Normal Chilled System. Subsequent engineering operability determination of the leak rate confirmed that the required mission time of 30 days could not be met and that the system was inoperable. This finding is of very low safety significance due to the fact that unit was in the process of conducting a normal shutdown in preparation for a refueling outage when the issue was recognized. The leaking NSCW isolation valves were identified and repaired.

The licensee has documented this condition in condition report 2009108930.

C 10 CFR 50.65 (a)(4) requires that before performing maintenance activities (including but not limited to surveillance, post-maintenance testing, and corrective and preventative maintenance), the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activity. Contrary to this on September 26, 2009, with the unit in mode six the licensee inadvertently isolated the only boration flowpath by danger tagging and isolating power to 1HV8835, safety injection to the RCS cold legs. This resulted in an unplanned Outage Risk Assessment Monitoring (ORAM) RED condition for reactivity control. This condition lasted for approximately 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> before being discovered by operators performing an outage risk assessment. Licensee immediately suspended all core alterations and restored the boration flowpath by manually opening 1HV8835. This finding is of very low safety significance due to the fact that the reactor cavity was completely flooded with 2600 ppm borated water from the refueling water storage tank when the issue was recognized. Licensee has documented this event in condition report 2009109416.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

R. Brown, Training and Emergency Preparedness Manager

R. Brigdon, Nuclear Operations Training Supervisor

C. Buck, Chemistry Manager

W. Copeland, Performance Analysis Supervisor

R. Dedrickson, Plant Manager

K. Dyar, Security Manager

C. Dykes, Medical Services Staff

M. Gibson, Simulator Coordinator

G. Gunn, Lead Instructor

I. Kochery, Health Physics Manager

T. Parton, Operations Support Superintendent

J. Robinson, Work Control Superintendent

M. Sharma, Nuclear Specialist

T. Tynan, Site Vice-President

D. Vineyard, Operations Manager

K. Waters, Medical Services Coordinator

J. Williams, Site Support Manager

T. Youngblood, Site Engineering Manager

Southern Nuclear Company

Mary Beth Lloyd,

NRC personnel

S. Shaeffer, Chief, Region II Reactor Projects Branch 2

M. Cain, Senior Resident Inspector

T. Chandler, Resident Inspector

LIST OF ITEMS

OPENED AND CLOSED

Opened and Closed

05000424,425/2009004-01 NCV MOV Program Procedures were Inadequate with Regard to Periodicity of Preventive Maintenance Activities for Stem Lubrication (Section 4OA2.2)

05000425/2009004-02, NCV Human Performance Error Renders 2B EDG Inoperable (Section 4OA5.1)

05000425/2009004-03 NCV Human Performance Error Renders NSCW Pump

1. 5 Inoperable (Section 4OA5.2)