IR 05000424/2008004: Difference between revisions

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{{Adams|number = ML083040204}}
{{Adams
| number = ML083040204
| issue date = 10/29/2008
| title = IR 05000424-08-004, 05000425-08-004, on 07/01/2008 - 09/30/2008, Vogtle Electric Generating Plant, Units 1 and 2; Event Followup
| author name = Shaeffer S M
| author affiliation = NRC/RGN-II/DRP/RPB2
| addressee name = Tynan T E
| addressee affiliation = Southern Nuclear Operating Co, Inc
| docket = 05000424, 05000425
| license number = NPF-068, NPF-081
| contact person =
| document report number = IR-08-004
| document type = Inspection Report, Letter
| page count = 21
}}


{{IR-Nav| site = 05000424 | year = 2008 | report number = 004 }}
{{IR-Nav| site = 05000424 | year = 2008 | report number = 004 }}


=Text=
=Text=
{{#Wiki_filter:
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II SAM NUNN ATLANTA FEDERAL CENTER 61 FORSYTH STREET, SW, SUITE 23T85 ATLANTA, GEORGIA 30303-8931 October 29, 2008  
[[Issue date::October 29, 2008]]


Mr. TomVice President - Vogtle Southern Nuclear Operating Company, Inc.
Mr. Tom Vice President - Vogtle Southern Nuclear Operating Company, Inc.


Vogtle Electric Generating Plant 7821 River Road Waynesboro, GA 30830
Vogtle Electric Generating Plant 7821 River Road Waynesboro, GA 30830


SUBJECT: VOGTLE ELECTRIC GENERATING PLANT - NRC INTEGRATED INSPECTION REPORT 05000424/2008004 AND 05000425/2008004
SUBJECT: VOGTLE ELECTRIC GENERATING PLANT - NRC INTEGRATED INSPECTION REPORT 05000424/2008004 AND 05000425/2008004


==Dear Mr. Tynan:==
==Dear Mr. Tynan:==
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The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.


Based on the results of this inspection, one finding of very low safety significance was identified which was determined to be a violation of regulatory requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section VI.A.1 of the NRC Enforcement Policy because of the very low safety significance of the violation and because it was entered into your corrective action program. If you contest this 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.
Based on the results of this inspection, one finding of very low safety significance was identified which was determined to be a violation of regulatory requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section VI.A.1 of the NRC Enforcement Policy because of the very low safety significance of the violation and because it was entered into your corrective action program. If you contest this 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  


SNC 2 In accordance with the Code of Federal Regulations 10 CFR 2.390 of the NRC's 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 NRC's 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).
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.


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 
SNC 2 In accordance with the Code of Federal Regulations 10 CFR 2.390 of the NRC's Rules of Practice, a copy of th is letter, its enclosures, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).


===Enclosures:===
Sincerely,/RA/ Scott M. Shaeffer, Chief Reactor Projects Branch 2 Division of Reactor Projects
Inspection Report 05000424/2008004 and 05000425/2008004


===w/Attachment:===
Docket Nos.: 50-424, 50-425 License Nos.: NPF-68 and NPF-81  
Supplemental Information cc w/encl: (See page 3)
SNC 2  In accordance with the Code of Federal Regulations 10 CFR 2.390 of the NRC's 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 NRC's 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:===
===Enclosures:===
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===w/Attachment:===
===w/Attachment:===
Supplemental Information cc w/encl: (See page 3)
Supplemental Information  


X  PUBLICLY AVAILABLE G  NON-PUBLICLY AVAILABLE G  SENSITIVE        X  NON-SENSITIVE ADAMS:  G Yes ACCESSION NUMBER:_________________________ X   SUNSI REVIEW COMPLETE CWR OFFICE RII:DRP RII:DRP RII:DRP RII:DRP RII:DRS RII:DRS SIGNATURE SMS /RA/ via email via telecom via email via email NAME CRapp SShaeffer GMcCoy TChandler RMoore CEven DATE 10/29/2008 10/28/2008 10/28/2008 10/21/2008 10/27/2008 E-MAIL COPY?     YES NO   YES NO   YES NO   YES NO   YES NO   YES NO   YES NO OFFICIAL RECORD COPY DOCUMENT NAME:  I:\RPB2\VOGTLE\REPORTS\08-04\IIR 2008-004.DOC SNC 3   cc w/encl:
cc w/encl: (See page 3)
 
_________________________ X SUNSI REVIEW COMPLETE CWR OFFICE RII:DRP RII:DRP RII:DRP RII:DRP RII:DRS RII:DRS SIGNATURE SMS /RA/ via email via telecom via email via email NAME CRapp SShaeffer GMcCoy TChandler RMoore CEven DATE 10/29/2008 10/28/2008 10/28/2008 10/21/2008 10/27/2008 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO SNC 3 cc w/encl:
N. J. Stringfellow Manager Licensing Southern Nuclear Operating Company, Inc.
N. J. Stringfellow Manager Licensing Southern Nuclear Operating Company, Inc.


Line 57: Line 66:
Michael A. MacFarlane Southern Nuclear Operating Company, Inc.
Michael A. MacFarlane Southern Nuclear Operating Company, Inc.


40 Inverness Center Parkway P.O. Box 1295 Birmingham, AL   35201-1295  
40 Inverness Center Parkway P.O. Box 1295 Birmingham, AL 35201-1295  


David H. Jones Vice President Engineering Southern Nuclear Operating Company, Inc.
David H. Jones Vice President Engineering Southern Nuclear Operating Company, Inc.
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Jim Sommerville (Acting) Chief Environmental Protection Division Department of Natural Resources Electronic Mail Distribution  
Jim Sommerville (Acting) Chief Environmental Protection Division Department of Natural Resources Electronic Mail Distribution  


Mr. Steven M. Jackson Senior Engineer - Power Supply Municipal Electric Authority of Georgia Electronic Mail Distribution  
Mr. Steven M. Jackson Senior Engineer - Power Supply Municipal Electric Authority of Georgia Electronic Mail Distribution  


Mr. Reece McAlister Executive Secretary Georgia Public Service Commission Electronic Mail Distribution  
Mr. Reece McAlister Executive Secretary Georgia Public Service Commission Electronic Mail Distribution  
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Troutman Sanders Electronic Mail Distribution  
Troutman Sanders Electronic Mail Distribution  


SNC 4   Director Consumers' Utility Counsel Division Governor's Office of Consumer Affairs 2 M. L. King, Jr. Drive Plaza Level East; Suite 356 Atlanta, GA   30334-4600  
SNC 4 Director Consumers' Utility Counsel Division Governor's Office of Consumer Affairs 2 M. L. King, Jr. Drive Plaza Level East; Suite 356 Atlanta, GA 30334-4600  


Susan E. Jenkins Director, Division of Waste Management Bureau of Land and Waste Management S.C. Department of Health and Environmental Control Electronic Mail Distribution SNC 5   Letter to Tomfrom Scott M. Shaeffer dated October 29, 2008
Susan E. Jenkins Director, Division of Waste Management Bureau of Land and Waste Management S.C. Department of Health and Environmental Control Electronic Mail Distribution SNC 5 Letter to Tom from Scott M. Shaeffer dated October 29, 2008


SUBJECT: VOGTLE ELECTRIC GENERATING PLANT - NRC INTEGRATED INSPECTION REPORT 05000424/2008004 AND 05000425/2008004 Distribution w/encl: C. Evans, RII L. Slack, RII OE Mail RIDSNRRDIRS PUBLIC R. Martin, NRR Enclosure U. S. NUCLEAR REGULATORY COMMISSION  REGION II 
SUBJECT: VOGTLE ELECTRIC GENERATING PLANT - NRC INTEGRATED INSPECTION REPORT 05000424/2008004 AND 05000425/2008004  


Docket Nos.:  50-424, 50-425 
Distribution w/encl:
C. Evans, RII L. Slack, RII OE Mail RIDSNRRDIRS PUBLIC R. Martin, NRR


License Nos.:    NPF-68, NPF-81 
Enclosure U. S. NUCLEAR REGULATORY COMMISSION REGION II


Report Nos.: 05000424/2008004 and 05000425/2008004 
Docket Nos.: 50-424, 50-425


Licensee: Southern Nuclear Operating Company, Inc.
License Nos.: NPF-68, NPF-81


Facility: Vogtle Electric Generating Plant, Units 1 and
Report Nos.: 05000424/2008004 and 05000425/2008004


Location: Waynesboro, GA 30830 
Licensee: Southern Nuclear Operating Company, Inc.


Dates:   July 1, 2008 through September 30, 2008 
Facility: Vogtle Electric Generati ng Plant, Units 1 and 2


Inspectors: G. McCoy, Senior Resident Inspector T. Chandler, Resident Inspector R. Moore, Senior Reactor Inspector (Section 4OA5.2)
Location: Waynesboro, GA 30830
C. Even, Reactor Inspector (Section 4OA5.2) 


Approved by: Scott M. Shaeffer, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure  
Dates: July 1, 2008 through September 30, 2008
 
Inspectors: G. McCoy, Senior Resident Inspector T. Chandler, Resident Inspector R. Moore, Senior Reactor Inspector (Section 4OA5.2)
C. Even, Reactor Inspector (Section 4OA5.2)
 
Approved by: Scott M. Shaeffer, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure  


=SUMMARY OF FINDINGS=
=SUMMARY OF FINDINGS=
IR 05000424/2008-004, 05000425/2008-004; 07/01/2008 - 09/30/2008; Vogtle Electric  
IR 05000424/2008-004, 05000425/2008-004; 07/01/2008 - 09/30/2008; Vogtle Electric  


Generating Plant, Units 1 and 2; Event Followup The report covered a three-month period of inspection by resident inspectors and two reactor inspectors. One Green non-cited violation was identified. The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using Inspection
Generating Plant, Units 1 and 2; Event Followup The report covered a three-month period of inspection by resident inspectors and two reactor inspectors. One Green non-cited violation was identified. The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or 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.
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.


===A. NRC-Identified and Self-Revealing Findings===
===A. NRC-Identified and Self-Revealing Findings===
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Boron Thermal Regeneration System, Rev 57. Failure to properly perform this step resulted in approximately 500 gallons of unborated water being added to the VCT causing an inadvertent positive reactivity addition to the Unit 1 reactor.
Boron Thermal Regeneration System, Rev 57. Failure to properly perform this step resulted in approximately 500 gallons of unborated water being added to the VCT causing an inadvertent positive reactivity addition to the Unit 1 reactor.


The failure to place handswitch 1-HS-7054 in the CLOSED position as required by procedure is a performance deficiency. The minor screening criteria in IMC 0612, Power
The failure to place handswitch 1-HS-7054 in the CLOSED position as required by procedure is a performance deficiency. The minor screening criteria in IMC 0612, Power Reactor Inspection Reports, Appendix B, was not used due to the lack of clear guidance regarding inadvertent reactivity additions. Therefore, in consultation with the NRR program office, regional management determined this finding is more than minor because the licensed operator failed to properly implement procedure 13010-C which resulted an inadvertent positive reactivity addition causing reactor power to briefly increase above 100%. The finding, assessed using the Significance Determination Process, was determined to be of very low safety significance (Green) because the resulting transient did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available. The inspectors determined this finding was related to the Work Practices component of the Human Performance cross-cutting area in that the licensed operator did not have the procedure in-hand during use as required by procedure 00054-C, Rules for Performing Procedures,
Reactor Inspection Reports, Appendix B, was not used due to the lack of clear guidance regarding inadvertent reactivity additions. Therefore, in consultation with the NRR program office, regional management determined this finding is more than minor because the licensed operator failed to properly implement procedure 13010-C which resulted an inadvertent positive reactivity addition causing reactor power to briefly increase above 100%. The finding, assessed using the Significance Determination
Rev. 19.  [H.4(b)] (Section 4OA3)  
Process, was determined to be of very low safety significance (Green) because the resulting transient did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available. The inspectors determined this finding was related to the Work Practices component of the Human
Performance cross-cutting area in that the licensed operator did not have the procedure in-hand during use as required by procedure 00054-C, Rules for Performing Procedures,
Rev. 19.  [H.4(b)] (Section 4OA3)


===B. Licensee-Identified Violations===
===B. Licensee-Identified Violations===
None
None


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===Summary of Plant Status===
===Summary of Plant Status===
Unit 1 operated at full rated thermal power (RTP) for the entire inspection period. Unit 2 started the inspection period at essentially full RTP. The unit was shutdown on September 14 for a planned refueling outage.
 
Unit 1 operated at full rated thermal power (RTP) for the entire inspection period.
 
Unit 2 started the inspection period at essentially full RTP. The unit was shutdown on September 14 for a planned refueling outage.


==REACTOR SAFETY==
==REACTOR SAFETY==
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity  


{{a|1R01}}
{{a|1R01}}
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====b. Findings====
====b. Findings====
No findings of significance were identified.
No findings of significance were identified.
{{a|1R04}}
{{a|1R04}}
==1R04 Equipment Alignment==
==1R04 Equipment Alignment==
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====b. Findings====
====b. Findings====
No findings of significance were identified.
No findings of significance were identified.
{{a|1R05}}
{{a|1R05}}
==1R05 Fire Protection==
==1R05 Fire Protection==
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====b. Findings====
====b. Findings====
No findings of significance were identified.
No findings of significance were identified.
{{a|1R06}}
{{a|1R06}}
==1R06 Flood Protection Measures==
==1R06 Flood Protection Measures==
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====b. Findings====
====b. Findings====
No findings of significance were identified.
No findings of significance were identified.
{{a|1R11}}
{{a|1R11}}
==1R11 Licensed Operator Requalification==
==1R11 Licensed Operator Requalification==
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====a. Inspection Scope====
====a. Inspection Scope====
Resident Quarterly Observation. The inspectors observed operator performance on July 16, during licensed operator simulator training described on simulator exercise guide Dynamic Simulator Scenarios V-RQ-SE-08405. The simulator scenarios covered operator actions resulting from steam generator tube rupture, a pressurizer steam space leak, and an automatic reactor trip failure. Documents reviewed are listed in the  
Resident Quarterly Observation. The inspectors observed operator performance on July 16, during licensed operator simulator training described on simulator exercise guide Dynamic Simulator Scenarios V-RQ-SE-08405. The simulator scenarios covered operator actions resulting from steam generator tube rupture, a pressurizer steam space leak, and an automatic reactor trip failure. Documents reviewed are listed in the  
 
. The inspectors specifically assessed the following areas:
. The inspectors specifically assessed the following areas:   Correct use of the abnormal and emergency operating procedures  Ability to identify and implement appropriate actions in accordance with the requirements of the technical specifications  Clarity and formality of communications in accordance with procedure 1000-C, Conduct of Operations  Proper control board manipulations including critical operator actions  Quality of supervisory command and control  Effectiveness of the post-evaluation critique
Correct use of the abnormal and emergency operating procedures  Ability to identify and impl ement appropriate actions in accordance with the requirements of the technical specifications  Clarity and formality of communications in accordance with procedure 1000-C, Conduct of Operations  Proper control board manipulations including critical operator actions  Quality of supervisory command and control  Effectiveness of the post-evaluation critique


====b. Findings====
====b. Findings====
No findings of significance were identified.
No findings of significance were identified.
{{a|1R12}}
{{a|1R12}}
==1R12 Maintenance Effectiveness==
==1R12 Maintenance Effectiveness==
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====b. Findings====
====b. Findings====
No findings of significance were identified.
No findings of significance were identified.
{{a|1R13}}
{{a|1R13}}
==1R13 Maintenance Risk Assessments and Emergent Work Evaluation==
==1R13 Maintenance Risk Assessments and Emergent Work Evaluation==
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====b. Findings====
====b. Findings====
No findings of significance were identified.
No findings of significance were identified.
{{a|1R15}}
{{a|1R15}}
==1R15 Operability Evaluations==
==1R15 Operability Evaluations==
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====b. Findings====
====b. Findings====
No findings of significance were identified.
No findings of significance were identified.
{{a|1R19}}
{{a|1R19}}
==1R19 Post-Maintenance Testing==
==1R19 Post-Maintenance Testing==


====a. Inspection Scope====
====a. Inspection Scope====
The inspectors either observed post-maintenance testing or reviewed the test results for the following four 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.
The inspectors either observed post-maintenance testing or reviewed the test results for the following four maintenance activities to verify that the testing met the requirements of  


Work order (WO) 10813359, Replacement of failed Unit 1 Train B reactor trip breaker  WOs 20601148, 20802972, and 20802974, Unit 2 train A CS pump Outage  WO 20715268, Clean/inspect/test/lubricate the Unit 2 train B NSCW pump #4 discharge valve (2HV11613)    WO 20810774, Unit 2 train B CS pump mechanical seal replacement
procedure 29401-C, Work Order Functional Tests, for ensur ing equipment operability and functional capability was restored. The inspectors also reviewed the te st procedures to verify the acceptance criteria were sufficient to meet the (TS) operability requi rements.
 
Work order (WO) 10813359, Replacement of failed Unit 1 Train B reactor trip breaker  WOs 20601148, 20802972, and 20802974, Unit 2 train A CS pump Outage  WO 20715268, Clean/ins pect/test/lubricate the Unit 2 train B NSCW pump #4 discharge valve (2HV11613)    WO 20810774, Unit 2 train B CS pump mechanical seal replacement


====b. Findings====
====b. Findings====
No findings of significance were identified.
No findings of significance were identified.
{{a|1R20}}
{{a|1R20}}
==1R20 Refueling and Other Outage Activities==
==1R20 Refueling and Other Outage Activities==
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The inspectors performed the inspection activities described below for the Unit 2 refueling outage that began on September 14. The inspectors confirmed that, when the licensee removed equipment from service, the licensee maintained defense-in-depth commensurate with the outage risk control plan for key safety functions and applicable technical specifications and that configuration changes due to emergent work and unexpected conditions were controlled in accordance with the outage risk control plan.
The inspectors performed the inspection activities described below for the Unit 2 refueling outage that began on September 14. The inspectors confirmed that, when the licensee removed equipment from service, the licensee maintained defense-in-depth commensurate with the outage risk control plan for key safety functions and applicable technical specifications and that configuration changes due 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:   Prior to the outage, the resident inspectors reviewed the licensee's 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. Observed portions of the plant shutdown and cooldown to verify that the technical specification cooldown restrictions were followed. 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  Verified that outage work did not impact the operation of the spent fuel cooling system during and after core load. Reviewed the status and configuration of electrical systems to verify that those systems met technical specification requirements and the licensee's outage risk control plan  Observed decay heat removal parameters to verify that the system was properly functioning and providing cooling to the core Reviewed system alignments to verify that the flow paths, configurations and alternative means for inventory addition were consistent with the outage risk plan  Reviewed selected control room operations to verify that the licensee was controlling reactivity in accordance with the technical specifications  Observed the licensee's control of containment penetrations to verify that the requirements of the technical specifications were met  Reviewed the licensee's 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
Documents reviewed are listed in the Attachment. Inspection activities included:
Prior to the outage, the resident inspectors reviewed the licensee's 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. Observed portions of the plant shutdown and cooldown to verify that the technical specification cooldown restrictions were followed. 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  Verified that outage work did not impact the operation of the spent fuel cooling system during and after core load. Reviewed the status and configuration of electrical systems to verify that those systems met technical specification requirements and the licensee's outage risk control plan  Observed decay heat removal parameters to verify that the system was properly functioning and providing cooling to the core Reviewed system alignments to verify that the flow paths, configurations and alternative means for inventory addition were consistent with the outage risk plan  Reviewed selected control room operations to verify t hat the licensee was controlling reactivity in accordance with the technical specifications  Observed the licensee's control of containment penetrations to verify that the requirements of the technical specifications were met  Reviewed the licensee's 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


====b. Findings====
====b. Findings====
No findings of significance were identified.
No findings of significance were identified.
{{a|1R22}}
{{a|1R22}}
==1R22 Surveillance Testing==
==1R22 Surveillance Testing==


====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed the following four 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.
The inspectors reviewed the following four 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 surveillanc e test problems.


Surveillance Tests 14980A-2, Unit 2 train A EDG monthly operability test In-Service Tests (IST) 14545-2, Unit 2 train A MDAFW pump monthly operability test  14545-2, Unit 2 train B MDAFW pump monthly operability test  14802-1, Unit 1 B train NSCW pump #6 IST and response time test
Surveillance Tests 14980A-2, Unit 2 train A EDG monthly operability test In-Service Tests (IST)14545-2, Unit 2 train A MDAFW pump monthly operability test  14545-2, Unit 2 train B MDAFW pump monthly operability test  14802-1, Unit 1 B train NSCW pump #6 IST and response time test


====b. Findings====
====b. Findings====
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====a. Inspection Scope====
====a. Inspection Scope====
The inspectors sampled licensee submittals for the listed PIs during the period from July 1, 2007 - June 30, 2008, for Unit 1 and Unit 2. The inspectors verified the licensee's basis in reporting each data element using the PI definitions and guidance contained in procedures 00163-C, NRC Performance Indicator and Monthly Operating Report Preparation and Submittal, and Nuclear Energy Institute (NEI) 99-02, Regulatory Assessment Indicator Guideline. Mitigating Systems Cornerstone Mitigating Systems Performance Index, High Pressure Injection System  Mitigating Systems Performance Index, Residual Heat Removal System  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.
The inspectors sampled licensee submittals for the listed PIs during the period from July 1, 2007 - June 30, 2008, for Unit 1 and Unit 2. The inspectors verified the licensee's basis in reporting each data element using the PI definitions and guidance contained in procedures 00163-C, NRC Performance Indicator and Monthly Operating Report Preparation and Submittal, and Nuclear Energy Institute (NEI) 99-02, Regulatory Assessment Indicator Guideline.
 
Mitigating Systems Cornerstone Mitigating Systems Performance Index, High Pressure Injection System  Mitigating Systems Performance Index, Residual Heat Removal System  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====
====b. Findings====
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The inspectors performed a detailed review of the following CR 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 licensee's corrective action program as delineated in licensee procedure NMP-GM-002, Corrective Action Program, and 10 CFR 50, Appendix B.
The inspectors performed a detailed review of the following CR 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 licensee's corrective action program as delineated in licensee procedure NMP-GM-002, Corrective Action Program, and 10 CFR 50, Appendix B.


CR 2008106941, During a surveillance test the inboard seal of the Unit 2 train B CS pump overheated.
CR 2008106941, During a surv eillance test the inboard seal of the Un it 2 train B CS pump overheated.


====b. Findings====
====b. Findings====
No findings of significance were identified.  
No findings of significance were identified.
 
{{a|4OA3}}
{{a|4OA3}}
==4OA3 Event Followup==
==4OA3 Event Followup==
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=====Introduction.=====
=====Introduction.=====
A Green self-revealing NCV of TS 5.4, Procedures, was identified when the licensed control room operator failed to perform step 4.3.5.10.b of procedure 3010-1, Boron Thermal Regeneration System, Rev 57. Failure to properly perform this step resulted in approximately 500 gallons of unborated water being added to the VCT, causing an inadvertent positive reactivity addition to the Unit 1 reactor.  
A Green self-revealing NCV of TS 5.4, Procedures, was identified when the licensed control room operator failed to perform step 4.3.5.10.b of procedure 3010-1, Boron Thermal Regeneration System, Rev 57. Failure to properly perform this step resulted in approximately 500 gallons of unborated water being added to the VCT, causing an inadvertent positive reactivity addition to the Unit 1 reactor.


=====Description.=====
=====Description.=====
On August 19, the licensee was conducting a flush of the BTRS chilled water piping using procedure 13010-1. This procedure was designated as 'Continuous Use' which required operators to have the procedure in-hand during use. The flush was being directed by a field operator because the majority of the operator actions were performed outside the main control room. However, a few steps were performed in the main control room by the licensed operator who was designated as "Operator at the Controls."  Due to the limited number of steps to be performed, the licensed operator decided that it was not necessary to have the procedure in-hand. Step 4.3.5.10.b
On August 19, the licensee was conducting a flush of the BTRS chilled water piping using procedure 13010-1. This procedure was designated as 'Continuous Use' which required operators to have the procedure in-hand during use. The flush was being directed by a field operator because the majority of the operator actions were performed outside the main control room. However, a few steps were performed in the main control room by the licensed operator who was designated as "Operator at the Controls."  Due to the limited number of steps to be performed, the licensed operator decided that it was not necessary to have the procedure in-hand. Step 4.3.5.10.b directed the CVCS BTRS inlet isolation valve handswitch, 1-HS-7054, be placed in the CLOSED position. When directed by the field operator to perform step 4.3.5.10.b, the licensed operator verified that valve 1-HV-7054 was closed, but did not place handswitch 1-HS-7054 in the CLOSED position as required by procedure 13010-1. Subsequently, when the licensed operator placed the CVCS BTRS selector switch in the DILUTE position, valve 1-HV-7054 automatically opened. As a result, approximately 500 gallons of unborated water from the BTRS was added to the VCT. The addition of unborated water to the VCT resulted in an inadvertent positive reactivity addition to the Unit 1 reactor which caused power to increase above 100% RTP. The operators became aware of the reactivity addition when control rods began to automatically insert. The control room operators responded to the event by manually inserting control rods and reducing main generator load to reduce reactor power below 100%. The maximum 1-minute average power achieved was 100.73%.  
 
directed the CVCS BTRS inlet isolation valve handswitch, 1-HS-7054, be placed in the CLOSED position. When directed by the field operator to perform step 4.3.5.10.b, the licensed operator verified that valve 1-HV-7054 was closed, but did not place handswitch 1-HS-7054 in the CLOSED position as required by procedure 13010-1. Subsequently, when the licensed operator placed the CVCS BTRS selector switch in the DILUTE position, valve 1-HV-7054 automatically opened. As a result, approximately 500 gallons of unborated water from the BTRS was added to the VCT. The addition of unborated water to the VCT resulted in an inadvertent positive reactivity addition to the Unit 1 reactor which caused power to increase above 100% RTP. The operators became aware of the reactivity addition when control rods began to automatically insert. The control room operators responded to the event by manually inserting control rods and reducing main generator load to reduce reactor power below 100%. The maximum 1-minute average power achieved was 100.73%.


=====Analysis.=====
=====Analysis.=====
Line 331: Line 338:


=====Enforcement.=====
=====Enforcement.=====
Technical Specification 5.4.1.a. requires that written procedures as specified in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978, be established, implemented, and maintained. Regulatory Guide 1.33 states that instructions for energizing, filling, venting, draining, startup, shutdown, and changing modes of operation should be prepared for the CVCS, which contains the BTRS.
Technical Specification 5.4.1.a. requires that written procedures as specified in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978, be established, implemented, and maintained. Regulatory Guide 1.33 states that instructions for energizing, filling, venting, draining, st artup, shutdow n, and changing modes of operation should be prepared for the CVCS, which contains the BTRS.


Contrary to the above, on August 19, 2008, a licensed reactor operator failed to implement procedure 13010-1 when he improperly performed step 4.3.5.10.b. Because the finding was of very low safety significance and was entered into the licensee's corrective action program as CR 2008108672, this violation is being treated as an NCV, consistent with section VI.A.1 of the NRC Enforcement Policy:  NCV 05000424/2008004-01, Human Performance Error Results in Unplanned Reactivity Addition.
Contrary to the above, on August 19, 2008, a licensed reactor operator failed to implement procedure 13010-1 when he improperly performed step 4.3.5.10.b. Because the finding was of very low safety significance and was entered into the licensee's corrective action program as CR 2008108672, this violation is being treated as an NCV, consistent with section VI.A.1 of the NRC Enforcement Policy:  NCV 05000424/2008004-01, Human Performance Error Results in Unplanned Reactivity Addition.
Line 352: Line 359:
The objective of this TI was to gather information to assess the adequacy of nuclear power plant EDG endurance and margin testing as prescribed by plant-specific TSs.
The objective of this TI was to gather information to assess the adequacy of nuclear power plant EDG endurance and margin testing as prescribed by plant-specific TSs.


The inspector interfaced with the appropriate station staff to obtain the information specified in Attachment 1 of the TI Worksheet. The TI applies to all operating nuclear power reactor licensees that use EDGs as the onsite standby power supply. The inspector verified the accuracy of the information by review of TS, EDG Design Basis Event (DBE) loading calculations, EDG endurance run test procedures, test data from the last three endurance tests performed on each EDG, EDG ratings, and EDG operating history. The information gathered will be forwarded to Nuclear Reactor Regulation/Division of Engineering/Electrical Engineering Branch (NRR/DE/EEEB) for further review to assess the adequacy and consistency of EDG testing at nuclear stations.
The inspector interfaced with the appropriate station staff to obtain the information specified in Attachment 1 of the TI Worksheet. The TI applies to all operating nuclear power reactor licensees that use EDGs as the onsite standby power supply. The inspector verified the accuracy of the information by review of TS, EDG Design Basis Event (DBE) loading calculations, EDG endurance run test procedures, test data from the last three endurance tests performed on each EDG, EDG ratings, and EDG operating history. The information gathered will be forwar ded to Nuclear Reactor Regulation/Division of Engineering/Electrical Engineering Branch (NRR/DE/EEEB) for further review to assess the adequacy and consistency of EDG testing at nuclear stations.


====b. Findings and Observations====
====b. Findings and Observations====
Line 358: Line 365:


===.3 Review of Institute of Nuclear Power Operations (INPO) Evaluation Report===
===.3 Review of Institute of Nuclear Power Operations (INPO) Evaluation Report===
The inspectors reviewed the results of an INPO evaluation of licensee performance conducted during January and February 2008. The report did not identify any significant licensee performance issues that had not been previously addressed and/or reviewed by the NRC.
The inspectors reviewed the results of an INPO evaluation of licensee performance conducted during January and February 2008. The report did not identify any significant licensee performance issues that had not been previously addressed and/or reviewed by the NRC.


Line 363: Line 371:
==4OA6 Meetings, Including Exit==
==4OA6 Meetings, Including Exit==


Exit Meeting On October 15, the resident inspectors presented the inspection results to Mr. D. R.
Exit Meeting On October 15, the resident inspectors presented the inspection results to Mr. D. R.


Vineyard and other members of his staff, who acknowledged the findings. The inspectors confirmed that proprietary information was not provided or examined during the inspection.
Vineyard and other members of his staff, who acknowledged the findings. The inspectors confirmed that proprietary information was not provided or examined during the inspection.
Line 388: Line 396:


===NRC personnel===
===NRC personnel===
:  
:
: [[contact::S. Shaeffer]], Chief, Region II Reactor Projects Branch 2  
: [[contact::S. Shaeffer]], Chief, Region II Reactor Projects Branch 2  


==LIST OF ITEMS==
==LIST OF ITEMS==
OPENED AND CLOSED
OPENED AND CLOSED  


===Opened and Closed===
===Opened and Closed===
Line 399: Line 407:
===Discussed===
===Discussed===
2515/176 TI Emergency Diesel Generator Technical Specification Surveillance Requirements Regarding Endurance and
2515/176 TI Emergency Diesel Generator Technical Specification Surveillance Requirements Regarding Endurance and
Margin Testing  
Margin Testing  
 
==LIST OF DOCUMENTS REVIEWED==
==LIST OF DOCUMENTS REVIEWED==
==Section 1R04: Equipment Alignment Procedures 11610-2, Auxiliary Feedwater System Alignment 11105-2, Safety Injection System Alignment==
==Section 1R04: Equipment Alignment==


===Procedures===
: 11610-2, Auxiliary Feedwater System Alignment 11105-2, Safety Injection System Alignment 
===Drawings===
===Drawings===
: 2X4DB161-1, 2, 3, Auxiliary Feedwater System 2X4DB168-3, Condensate and Feedwater System  
: 2X4DB161-1, 2, 3, Auxiliary Feedwater System 2X4DB168-3, Condensate and Feedwater System  
Line 411: Line 422:
: Attachment
: Attachment


==Section 1R05: Fire Protection Procedures 92805-1, Zone 105 Unit 1 Control Bldg. Level 1 Fire Fighting Preplan==
==Section 1R05: Fire Protection==
 
===Procedures===
: 2805-1, Zone 105 Unit 1 Control Bldg. Level 1 Fire Fighting Preplan  
: 2805-2, Zone 105 Unit 2 Control Bldg. Level 1 Fire Fighting Preplan  
: 2805-2, Zone 105 Unit 2 Control Bldg. Level 1 Fire Fighting Preplan  
: 2806-1, Zone 106 Unit 1 Control Bldg. Level 1 Fire Fighting Preplan  
: 2806-1, Zone 106 Unit 1 Control Bldg. Level 1 Fire Fighting Preplan  
Line 423: Line 437:
: 2726B-2, Zone 26B Unit 2 Aux. Bldg. Levels A&B Fire Fighting Preplan
: 2726B-2, Zone 26B Unit 2 Aux. Bldg. Levels A&B Fire Fighting Preplan


==Section 1R20: Refueling and Other Outage Activities Procedures 12005-C, Reactor Shutdown to Hot Standby (Mode 2 to Mode 3)==
==Section 1R20: Refueling and Other Outage Activities==
 
===Procedures===
: 2005-C, Reactor Shutdown to Hot Standby (Mode 2 to Mode 3)  
: 2006-C, Unit Cooldown to Cold Shutdown  
: 2006-C, Unit Cooldown to Cold Shutdown  
: 2007-C, Refueling Operations (Entry into Mode 6)   
: 2007-C, Refueling Operations (Entry into Mode 6)   
Line 429: Line 446:
: 2R13 Outage Risk Control Plan
: 2R13 Outage Risk Control Plan


==Section 4OA5: Other Technical Specifications, Unit 1, Amendment 151==
==Section 4OA5: Other==
: Technical Specifications, Unit 1, Amendment 151  
: Technical Specifications, Unit 2, Amendment 132   
: Technical Specifications, Unit 2, Amendment 132   
===Procedures===
===Procedures===
: 14668A-1, Train A Diesel Generator 24 Month Operability Test, Rev. 4.2 14668A-2, Train A Diesel Generator 24 Month Operability Test, Rev. 3.2 14668B-1, Train B Diesel Generator 24 Month Operability Test, Rev. 3.3 14668B-2, Train B Diesel Generator 24 Month Operability Test, Rev. 3.3  
: 14668A-1, Train A Diesel Generator 24 Month Operability Test, Rev. 4.2 14668A-2, Train A Diesel Generator 24 Month Operability Test, Rev. 3.2 14668B-1, Train B Diesel Generator 24 Month Operability Test, Rev. 3.3 14668B-2, Train B Diesel Generator 24 Month Operability Test, Rev. 3.3
===Calculations===
===Calculations===
: X3CE01, Diesel Generator Steady State Load Study, Rev. 9  
: X3CE01, Diesel Generator Steady State Load Study, Rev. 9  
: Other 14666-103X-134068, Train A Diesel Generator and ESFAS Test, 2/03  
: Other 14666-103X-134068, Train A Diesel Generator and ESFAS Test, 2/03  
: 14668-101-146021, Train A Diesel Generator 24 Month Operability Test, 1/05 14668-101-1061126701, Train A Diesel Generator 24 Month Operability Test, 2/07 14667-103X-133802, Train B Diesel Generator and ESFAS Test, 2/03  
: 14668-101-146021, Trai
: 14668-102-146022, Train B Diesel Generator 24 Month Operability Test, 1/05 14668-102-1061126801, Train B Diesel Generator 24 Month Operability Test, 1/07 14668-201-2071185301, Train A Diesel Generator 24 Month Operability Test, 5/08 14668-201-2052772901, Train A Diesel Generator 24 Month Operability Test, 1/06 14668-201-14065, Train A Diesel Generator 24 Month Operability Test, 2/04 14668-202-2071185401, Train B Diesel Generator 24 Month Operability Test, 6/08 14668-202-2052773001, Train B Diesel Generator 24 Month Operability Test, 1/06 14668-202-142254, Train B Diesel Generator 24 Month Operability Test, 1/04
n A Diesel Generator 24 Month Operability Test, 1/05 14668-101-1061126701, Trai
n A Diesel Generator 24 Month Operability Test, 2/07 14667-103X-133802, Train B Diesel Generator and ESFAS Test, 2/03  
: 14668-102-146022, Trai
n B Diesel Generator 24 Month Operability Test, 1/05 14668-102-1061126801, Trai
n B Diesel Generator 24 Month Operability Test, 1/07 14668-201-2071185301, Trai
n A Diesel Generator 24 Month Operability Test, 5/08 14668-201-2052772901, Trai
n A Diesel Generator 24 Month Operability Test, 1/06 14668-201-14065, Trai
n A Diesel Generator 24 Month Operability Test, 2/04 14668-202-2071185401, Trai
n B Diesel Generator 24 Month Operability Test, 6/08 14668-202-2052773001, Trai
n B Diesel Generator 24 Month Operability Test, 1/06 14668-202-142254, Trai
n B Diesel Generator 24 Month Operability Test, 1/04
}}
}}

Revision as of 08:21, 28 August 2018

IR 05000424-08-004, 05000425-08-004, on 07/01/2008 - 09/30/2008, Vogtle Electric Generating Plant, Units 1 and 2; Event Followup
ML083040204
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 10/29/2008
From: Shaeffer S M
NRC/RGN-II/DRP/RPB2
To: Tynan T E
Southern Nuclear Operating Co
References
IR-08-004
Download: ML083040204 (21)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II SAM NUNN ATLANTA FEDERAL CENTER 61 FORSYTH STREET, SW, SUITE 23T85 ATLANTA, GEORGIA 30303-8931 October 29, 2008

Mr. Tom Vice President - Vogtle Southern Nuclear Operating Company, Inc.

Vogtle Electric Generating Plant 7821 River Road Waynesboro, GA 30830

SUBJECT: VOGTLE ELECTRIC GENERATING PLANT - NRC INTEGRATED INSPECTION REPORT 05000424/2008004 AND 05000425/2008004

Dear Mr. Tynan:

On September 30, 2008, 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 15, with Mr. D. R. Vineyard and other members of your staff.

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

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

Based on the results of this inspection, one finding of very low safety significance was identified which was determined to be a violation of regulatory requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section VI.A.1 of the NRC Enforcement Policy because of the very low safety significance of the violation and because it was entered into your corrective action program. If you contest this 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.

SNC 2 In accordance with the Code of Federal Regulations 10 CFR 2.390 of the NRC's Rules of Practice, a copy of th is letter, its enclosures, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the 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:

Inspection Report 05000424/2008004 and 05000425/2008004

w/Attachment:

Supplemental Information

cc w/encl: (See page 3)

_________________________ X SUNSI REVIEW COMPLETE CWR OFFICE RII:DRP RII:DRP RII:DRP RII:DRP RII:DRS RII:DRS SIGNATURE SMS /RA/ via email via telecom via email via email NAME CRapp SShaeffer GMcCoy TChandler RMoore CEven DATE 10/29/2008 10/28/2008 10/28/2008 10/21/2008 10/27/2008 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO SNC 3 cc w/encl:

N. J. Stringfellow Manager Licensing Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution

Jeffrey T. Gasser Executive Vice President Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution

L. Mike Stinson Vice President Fleet Operations Support Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution

Michael A. MacFarlane Southern Nuclear Operating Company, Inc.

40 Inverness Center Parkway P.O. Box 1295 Birmingham, AL 35201-1295

David H. Jones Vice President Engineering Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution

Bob Masse Resident Manager Vogtle Electric Generating Plant Oglethorpe Power Corporation Electronic Mail Distribution

Moanica Caston Vice President and General Counsel Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution

Laurence Bergen Oglethorpe Power Corporation Electronic Mail Distribution

Mr. N. Holcomb Commissioner Department of Natural Resources Electronic Mail Distribution

Dr. Carol Couch Director Environmental Protection Department of Natural Resources Electronic Mail Distribution

Cynthia Sanders Program Manager Radioactive Materials Program Department of Natural Resources Electronic Mail Distribution

Jim Sommerville (Acting) Chief Environmental Protection Division Department of Natural Resources Electronic Mail Distribution

Mr. Steven M. Jackson Senior Engineer - Power Supply Municipal Electric Authority of Georgia Electronic Mail Distribution

Mr. Reece McAlister Executive Secretary Georgia Public Service Commission Electronic Mail Distribution

Office of the Attorney General Electronic Mail Distribution

M. Stanford Blanton, Esq.

Balch and Bingham Law Firm Electronic Mail Distribution

Office of the County Commissioner Burke County Commission Electronic Mail Distribution

Arthur H. Domby, Esq.

Troutman Sanders Electronic Mail Distribution

SNC 4 Director Consumers' Utility Counsel Division Governor's Office of Consumer Affairs 2 M. L. King, Jr. Drive Plaza Level East; Suite 356 Atlanta, GA 30334-4600

Susan E. Jenkins Director, Division of Waste Management Bureau of Land and Waste Management S.C. Department of Health and Environmental Control Electronic Mail Distribution SNC 5 Letter to Tom from Scott M. Shaeffer dated October 29, 2008

SUBJECT: VOGTLE ELECTRIC GENERATING PLANT - NRC INTEGRATED INSPECTION REPORT 05000424/2008004 AND 05000425/2008004

Distribution w/encl:

C. Evans, RII L. Slack, RII OE Mail RIDSNRRDIRS PUBLIC R. Martin, NRR

Enclosure U. S. NUCLEAR REGULATORY COMMISSION REGION II

Docket Nos.: 50-424, 50-425

License Nos.: NPF-68, NPF-81

Report Nos.: 05000424/2008004 and 05000425/2008004

Licensee: Southern Nuclear Operating Company, Inc.

Facility: Vogtle Electric Generati ng Plant, Units 1 and 2

Location: Waynesboro, GA 30830

Dates: July 1, 2008 through September 30, 2008

Inspectors: G. McCoy, Senior Resident Inspector T. Chandler, Resident Inspector R. Moore, Senior Reactor Inspector (Section 4OA5.2)

C. Even, Reactor Inspector (Section 4OA5.2)

Approved by: Scott M. Shaeffer, Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000424/2008-004, 05000425/2008-004; 07/01/2008 - 09/30/2008; Vogtle Electric

Generating Plant, Units 1 and 2; Event Followup The report covered a three-month period of inspection by resident inspectors and two reactor inspectors. One Green non-cited violation was identified. The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or 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.

A. NRC-Identified and Self-Revealing Findings

Green.

A self-revealing non-cited violation of TS 5.4, Procedures, was identified when the licensed control room operator failed to perform step 4.3.5.10.b of procedure 3010-1,

Boron Thermal Regeneration System, Rev 57. Failure to properly perform this step resulted in approximately 500 gallons of unborated water being added to the VCT causing an inadvertent positive reactivity addition to the Unit 1 reactor.

The failure to place handswitch 1-HS-7054 in the CLOSED position as required by procedure is a performance deficiency. The minor screening criteria in IMC 0612, Power Reactor Inspection Reports, Appendix B, was not used due to the lack of clear guidance regarding inadvertent reactivity additions. Therefore, in consultation with the NRR program office, regional management determined this finding is more than minor because the licensed operator failed to properly implement procedure 13010-C which resulted an inadvertent positive reactivity addition causing reactor power to briefly increase above 100%. The finding, assessed using the Significance Determination Process, was determined to be of very low safety significance (Green) because the resulting transient did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available. The inspectors determined this finding was related to the Work Practices component of the Human Performance cross-cutting area in that the licensed operator did not have the procedure in-hand during use as required by procedure 00054-C, Rules for Performing Procedures,

Rev. 19. H.4(b) (Section 4OA3)

B. Licensee-Identified Violations

None

REPORT DETAILS

Summary of Plant Status

Unit 1 operated at full rated thermal power (RTP) for the entire inspection period.

Unit 2 started the inspection period at essentially full RTP. The unit was shutdown on September 14 for a planned refueling outage.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

1R01 Adverse Weather Protection

a. Inspection Scope

Impending Adverse Weather Condition. On September 4, inspectors reviewed procedures 11889-C, Severe Weather Checklist, and 20054-C, Maintenance Support for the Severe Weather Checklist to verify that the licensee was prepared to implement actions when hurricane Hanna was predicted to affect the Burke County area. The inspectors walked down the outside areas of the plant to identify the presence of loose materials which could affect the operation of plant equipment.

b. Findings

No findings of significance were identified.

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.

Unit 2 auxiliary feedwater (AFW) system prior to testing of the turbine driven AFW pump Unit 2 train A high head safety injection pump when the B train was out of service for maintenance Unit 2 train A safety injection (SI) pump during a refueling 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 licensee's 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 licensee's 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.

Unit 1 and Unit 2 main control room Technical support center Unit 1 auxiliary building pipe penetration area on level C Unit 2 auxiliary building pipe penetration on level B Unit 2 auxiliary component cooling water pump room

b. Findings

No findings of significance were identified.

1R06 Flood Protection Measures

a. Inspection Scope

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

Unit 2 AFW building

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification

a. Inspection Scope

Resident Quarterly Observation. The inspectors observed operator performance on July 16, during licensed operator simulator training described on simulator exercise guide Dynamic Simulator Scenarios V-RQ-SE-08405. The simulator scenarios covered operator actions resulting from steam generator tube rupture, a pressurizer steam space leak, and an automatic reactor trip failure. Documents reviewed are listed in the

. The inspectors specifically assessed the following areas:

Correct use of the abnormal and emergency operating procedures Ability to identify and impl ement appropriate actions in accordance with the requirements of the technical specifications Clarity and formality of communications in accordance with procedure 1000-C, Conduct of Operations Proper control board manipulations including critical operator actions Quality of supervisory command and control Effectiveness of the post-evaluation critique

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed the following two condition reports to evaluate the effectiveness of the licensee's handling of equipment performance problems and to verify the licensee's maintenance efforts met the requirements of 10 CFR 50.65 (the Maintenance Rule) and licensee procedure 50028-C, Engineering Maintenance Rule Implementation.

The inspector also reviewed one safety-significant system to verify that the licensee's maintenance efforts met the requirements of 10 CFR 50.65 (the Maintenance Rule) and licensee procedure 50028-C, Engineering Maintenance Rule Implementation. The reviews included adequacy of the licensee's failure characterization, establishment of performance criteria or 50.65(a)(1) performance goals, and adequacy of corrective actions. Other documents reviewed during this inspection included control room logs, system health reports, the maintenance rule database, and maintenance work orders.

Also, the inspectors interviewed system engineers and the maintenance rule coordinator to assess the accuracy of identified performance deficiencies and extent of condition.

CR 2008105578, Containment cooling fan number 1 failed to start in slow speed. CR 2008106489, Unit 2 train B NSCW fan number 4 tripped.

b. Findings

No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Evaluation

a. Inspection Scope

The inspectors reviewed the following four 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.

July 25, planned maintenance outages for the Unit 2 train A containment spray (CS) pump and the Unit 2 Train A SI pump July 28, Unit 2 train B coolant charging pump was out of service for planned maintenance August 4, Unit 2 train A CS pump was out of service for corrective maintenance September 6, performance of multiple surveillances in preparation for Unit 2 refueling outage

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.

CR 2008107647, Unit 2 train A sequencer power supply failure. CR 2008107492, Fuel assembly in the spent fuel pool lifted by the hold down spring CR 2008109254, Defective security diesel generator breaker CR 2008109286, Breaches in the Unit 2 piping penetration negative pressure boundary CR 2008109859, ultra-low sulfur diesel fuel was added to the 2B EDG fuel oil storage tank.

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 four maintenance activities to verify that the testing met the requirements of

procedure 29401-C, Work Order Functional Tests, for ensur ing equipment operability and functional capability was restored. The inspectors also reviewed the te st procedures to verify the acceptance criteria were sufficient to meet the (TS) operability requi rements.

Work order (WO) 10813359, Replacement of failed Unit 1 Train B reactor trip breaker WOs 20601148, 20802972, and 20802974, Unit 2 train A CS pump Outage WO 20715268, Clean/ins pect/test/lubricate the Unit 2 train B NSCW pump #4 discharge valve (2HV11613) WO 20810774, Unit 2 train B CS pump mechanical seal replacement

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 2 refueling outage that began on September 14. The inspectors confirmed that, when the licensee removed equipment from service, the licensee maintained defense-in-depth commensurate with the outage risk control plan for key safety functions and applicable technical specifications and that configuration changes due 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:

Prior to the outage, the resident inspectors reviewed the licensee's 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. Observed portions of the plant shutdown and cooldown to verify that the technical specification cooldown restrictions were followed. 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 Verified that outage work did not impact the operation of the spent fuel cooling system during and after core load. Reviewed the status and configuration of electrical systems to verify that those systems met technical specification requirements and the licensee's outage risk control plan Observed decay heat removal parameters to verify that the system was properly functioning and providing cooling to the core Reviewed system alignments to verify that the flow paths, configurations and alternative means for inventory addition were consistent with the outage risk plan Reviewed selected control room operations to verify t hat the licensee was controlling reactivity in accordance with the technical specifications Observed the licensee's control of containment penetrations to verify that the requirements of the technical specifications were met Reviewed the licensee's 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

b. Findings

No findings of significance were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors reviewed the following four 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 surveillanc e test problems.

Surveillance Tests 14980A-2, Unit 2 train A EDG monthly operability test In-Service Tests (IST)14545-2, Unit 2 train A MDAFW pump monthly operability test 14545-2, Unit 2 train B MDAFW pump monthly operability test 14802-1, Unit 1 B train NSCW pump #6 IST and 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.

On August 6 the licensee conducted an emergency preparedness drill involving an uncontrolled release of activity from a waste decay tank, followed by a loss of all offsite power and a loss of all onsite AC power. The technical support center was activated and the site participated in the exercise.

b. Findings

No findings of significance were identified.

OTHER ACTIVITIES

4OA1 Performance Indicator (PI) Verification

a. Inspection Scope

The inspectors sampled licensee submittals for the listed PIs during the period from July 1, 2007 - June 30, 2008, for Unit 1 and Unit 2. The inspectors verified the licensee's basis in reporting each data element using the PI definitions and guidance contained in procedures 00163-C, NRC Performance Indicator and Monthly Operating Report Preparation and Submittal, and Nuclear Energy Institute (NEI) 99-02, Regulatory Assessment Indicator Guideline.

Mitigating Systems Cornerstone Mitigating Systems Performance Index, High Pressure Injection System Mitigating Systems Performance Index, Residual Heat Removal System 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.

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

.2 Focused Review

a. Inspection Scope

The inspectors performed a detailed review of the following CR 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 licensee's corrective action program as delineated in licensee procedure NMP-GM-002, Corrective Action Program, and 10 CFR 50, Appendix B.

CR 2008106941, During a surv eillance test the inboard seal of the Un it 2 train B CS pump overheated.

b. Findings

No findings of significance were identified.

4OA3 Event Followup

.1 Inadvertent Positive Reactivity Addition

a. Inspection Scope

Resident inspectors reviewed the circumstances surrounding an unintended dilution of the reactor coolant system as described in condition report 2008108672, Inadvertent dilution while performing procedure for chemistry control of the Boron Thermal Regeneration System (BTRS) chilled water system. The inspectors interviewed operators on-shift at the time of the event, reviewed the condition report and subsequent disposition, attended the associated human performance board, reviewed the applicable procedures, and evaluated the plant response using plots of reactor power and Tave during the event.

b. Findings

Introduction.

A Green self-revealing NCV of TS 5.4, Procedures, was identified when the licensed control room operator failed to perform step 4.3.5.10.b of procedure 3010-1, Boron Thermal Regeneration System, Rev 57. Failure to properly perform this step resulted in approximately 500 gallons of unborated water being added to the VCT, causing an inadvertent positive reactivity addition to the Unit 1 reactor.

Description.

On August 19, the licensee was conducting a flush of the BTRS chilled water piping using procedure 13010-1. This procedure was designated as 'Continuous Use' which required operators to have the procedure in-hand during use. The flush was being directed by a field operator because the majority of the operator actions were performed outside the main control room. However, a few steps were performed in the main control room by the licensed operator who was designated as "Operator at the Controls." Due to the limited number of steps to be performed, the licensed operator decided that it was not necessary to have the procedure in-hand. Step 4.3.5.10.b directed the CVCS BTRS inlet isolation valve handswitch, 1-HS-7054, be placed in the CLOSED position. When directed by the field operator to perform step 4.3.5.10.b, the licensed operator verified that valve 1-HV-7054 was closed, but did not place handswitch 1-HS-7054 in the CLOSED position as required by procedure 13010-1. Subsequently, when the licensed operator placed the CVCS BTRS selector switch in the DILUTE position, valve 1-HV-7054 automatically opened. As a result, approximately 500 gallons of unborated water from the BTRS was added to the VCT. The addition of unborated water to the VCT resulted in an inadvertent positive reactivity addition to the Unit 1 reactor which caused power to increase above 100% RTP. The operators became aware of the reactivity addition when control rods began to automatically insert. The control room operators responded to the event by manually inserting control rods and reducing main generator load to reduce reactor power below 100%. The maximum 1-minute average power achieved was 100.73%.

Analysis.

The failure to place handswitch 1-HS-7054 in the CLOSED position as required by procedure is a performance deficiency. The minor screening criteria in IMC 0612, Power Reactor Inspection Reports, Appendix B, was not used due to the lack of clear guidance regarding inadvertent reactivity additions. Therefore, in consultation with the NRR program office, regional management determined this finding is more than minor because the licensed operator failed to properly implement procedure 13010-C which resulted in an inadvertent positive reactivity addition causing reactor power to briefly increase above 100%. This finding, assessed using the SDP, was determined to be of very low safety significance (Green) because the resulting transient did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available. The inspectors determined this finding was related to the Work Practices component of the Human Performance cross-cutting area in that the licensed operator did not have the procedure in-hand during use as required by procedure 00054-C, Rules for Performing Procedures, Rev. 19. H.4(b)

Enforcement.

Technical Specification 5.4.1.a. requires that written procedures as specified in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978, be established, implemented, and maintained. Regulatory Guide 1.33 states that instructions for energizing, filling, venting, draining, st artup, shutdow n, and changing modes of operation should be prepared for the CVCS, which contains the BTRS.

Contrary to the above, on August 19, 2008, a licensed reactor operator failed to implement procedure 13010-1 when he improperly performed step 4.3.5.10.b. Because the finding was of very low safety significance and was entered into the licensee's corrective action program as CR 2008108672, this violation is being treated as an NCV, consistent with section VI.A.1 of the NRC Enforcement Policy: NCV 05000424/2008004-01, Human Performance Error Results in Unplanned Reactivity Addition.

4OA5 Other Activities

.1 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.

b. Findings

No findings of significance were identified.

.2 (Discussed)

Temporary Instruction (TI) 2515/176, Emergency Diesel Generator Technical Specification Surveillance Requirements Regarding Endurance and Margin Testing

a. Inspection Scope

The objective of this TI was to gather information to assess the adequacy of nuclear power plant EDG endurance and margin testing as prescribed by plant-specific TSs.

The inspector interfaced with the appropriate station staff to obtain the information specified in Attachment 1 of the TI Worksheet. The TI applies to all operating nuclear power reactor licensees that use EDGs as the onsite standby power supply. The inspector verified the accuracy of the information by review of TS, EDG Design Basis Event (DBE) loading calculations, EDG endurance run test procedures, test data from the last three endurance tests performed on each EDG, EDG ratings, and EDG operating history. The information gathered will be forwar ded to Nuclear Reactor Regulation/Division of Engineering/Electrical Engineering Branch (NRR/DE/EEEB) for further review to assess the adequacy and consistency of EDG testing at nuclear stations.

b. Findings and Observations

The TI is presently scheduled to be open until completion of the NRR/DE/EEEB review.

.3 Review of Institute of Nuclear Power Operations (INPO) Evaluation Report

The inspectors reviewed the results of an INPO evaluation of licensee performance conducted during January and February 2008. The report did not identify any significant licensee performance issues that had not been previously addressed and/or reviewed by the NRC.

4OA6 Meetings, Including Exit

Exit Meeting On October 15, the resident inspectors presented the inspection results to Mr. D. R.

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

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

R. Brown, Training and Emergency Preparedness Manager
C. Buck, Chemistry Manager
W. Copeland, Performance Analysis Supervisor
R. Dedrickson, Plant Manager
K. Dyar, Security Manager
I. Kochery, Health Physics Manager
J. Robinson, Work Control Superintendent
T. Tynan, Site Vice-President
D. Vineyard, Operations Manager
J. Williams, Site Support Manager
T. Youngblood, Site Engineering Manager

NRC personnel

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

LIST OF ITEMS

OPENED AND CLOSED

Opened and Closed

05000424/2008004-01 NCV Human Performance Error Results in Unplanned Reactivity Addition

Discussed

2515/176 TI Emergency Diesel Generator Technical Specification Surveillance Requirements Regarding Endurance and

Margin Testing

LIST OF DOCUMENTS REVIEWED

Section 1R04: Equipment Alignment

Procedures

11610-2, Auxiliary Feedwater System Alignment 11105-2, Safety Injection System Alignment

Drawings

2X4DB161-1, 2, 3, Auxiliary Feedwater System 2X4DB168-3, Condensate and Feedwater System
2X4DB116-1, 2 Chemical and Volume Control System
System Health Reports Auxiliary Feedwater System 1302A, Second Quarter 2008
Safety Injection System 1204, Second Quarter 2008
Chemical and Volume Control System 1208, Second Quarter 2008
Attachment

Section 1R05: Fire Protection

Procedures

2805-1, Zone 105 Unit 1 Control Bldg. Level 1 Fire Fighting Preplan
2805-2, Zone 105 Unit 2 Control Bldg. Level 1 Fire Fighting Preplan
2806-1, Zone 106 Unit 1 Control Bldg. Level 1 Fire Fighting Preplan
2883A-1, Zone 183A Unit 1 Control Bldg. Level 1 Fire Fighting Preplan
2921-1, Zone 601 TSC Fire Fighting Preplan
2922-1, Zone 602 TSC Fire Fighting Preplan
2923-1, Zone 603 TSC Electrical Equipment Room Fire Fighting Preplan
2924-1, Zone 604 TSC Battery Room Fire Fighting Preplan
2925-1, Zone 605 TSC Fire Fighting Preplan
2714B-1, Zone 14B Unit 1 Aux. Bldg. Level C Fire Fighting Preplan
2726B-2, Zone 26B Unit 2 Aux. Bldg. Levels A&B Fire Fighting Preplan

Section 1R20: Refueling and Other Outage Activities

Procedures

2005-C, Reactor Shutdown to Hot Standby (Mode 2 to Mode 3)
2006-C, Unit Cooldown to Cold Shutdown
2007-C, Refueling Operations (Entry into Mode 6)

Other Documents

2R13 Outage Risk Control Plan

Section 4OA5: Other

Technical Specifications, Unit 1, Amendment 151
Technical Specifications, Unit 2, Amendment 132

Procedures

14668A-1, Train A Diesel Generator 24 Month Operability Test, Rev. 4.2 14668A-2, Train A Diesel Generator 24 Month Operability Test, Rev. 3.2 14668B-1, Train B Diesel Generator 24 Month Operability Test, Rev. 3.3 14668B-2, Train B Diesel Generator 24 Month Operability Test, Rev. 3.3

Calculations

X3CE01, Diesel Generator Steady State Load Study, Rev. 9
Other 14666-103X-134068, Train A Diesel Generator and ESFAS Test, 2/03
14668-101-146021, Trai

n A Diesel Generator 24 Month Operability Test, 1/05 14668-101-1061126701, Trai

n A Diesel Generator 24 Month Operability Test, 2/07 14667-103X-133802, Train B Diesel Generator and ESFAS Test, 2/03

14668-102-146022, Trai

n B Diesel Generator 24 Month Operability Test, 1/05 14668-102-1061126801, Trai

n B Diesel Generator 24 Month Operability Test, 1/07 14668-201-2071185301, Trai

n A Diesel Generator 24 Month Operability Test, 5/08 14668-201-2052772901, Trai

n A Diesel Generator 24 Month Operability Test, 1/06 14668-201-14065, Trai

n A Diesel Generator 24 Month Operability Test, 2/04 14668-202-2071185401, Trai

n B Diesel Generator 24 Month Operability Test, 6/08 14668-202-2052773001, Trai

n B Diesel Generator 24 Month Operability Test, 1/06 14668-202-142254, Trai

n B Diesel Generator 24 Month Operability Test, 1/04