IR 05000424/2019003
| ML19318E978 | |
| Person / Time | |
|---|---|
| Site: | Vogtle, 07201039  |
| Issue date: | 11/14/2019 |
| From: | Alan Blamey Division Reactor Projects II |
| To: | Gayheart C Southern Nuclear Operating Co |
| Reeder D | |
| References | |
| EA-19-112 IR 2019003 | |
| Download: ML19318E978 (23) | |
Text
November 14, 2019
SUBJECT:
VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 & 2 - INTEGRATED INSPECTION REPORT 05000424/2019003, 05000425/2019003 AND 07201039/2019003 AND APPARENT VIOLATION
Dear Ms. Gayheart:
On September 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Vogtle Electric Generating Plant. On October 16, 2019, the NRC inspectors discussed the results of this inspection with Mr. Keith Taber and other members of your staff.
The results of this inspection are documented in the enclosed report.
The enclosed report discusses a finding for which the NRC has not yet reached a preliminary significance determination. This finding involved the failure to accurately calibrate containment high range area radiation monitors 1RE-0005, 1RE-0006, 2RE-0005, and 2RE-0006.
We intend to issue our final safety significance determination, in writing, within 90 days from the date of this inspection report. The NRCs significance determination process is designed to encourage an open dialogue between your staff and the NRC; however, neither the dialogue nor the written information you provide should affect the timeliness of our final determination. We ask that you promptly provide any relevant information that you would like us to consider in making our determination. We are currently evaluating the significance of this finding and will notify you in a separate correspondence once we have completed our preliminary significance review. You will be given an opportunity to provide additional information prior to our final significance determination unless our review concludes that the finding has very low safety significance (i.e., Green).
If you contest the violation or significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at Vogtle. If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC Resident Inspector at Vogtle.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Alan J. Blamey, Chief Reactor Projects Branch 2 Division of Reactor Projects
Docket Nos. 05000424, 05000425
and 07201039 License Nos. NPF-68 and NPF-81
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000424 and 05000425
License Numbers:
Report Numbers:
05000424/2019003, 05000425/2019003 and 07201039/2019003
Enterprise Identifier:
I-2019-003-0031 and I-2019-003-0079
Licensee:
Southern Nuclear Operating Co., Inc.
Facility:
Vogtle Electric Generating Plant
Location:
Waynesboro, GA
Inspection Dates:
July 1, 2019 to September 30, 2019
Inspectors:
M. Donithan, Operations Engineer
M. Endress, Senior Resident Inspector
D. Lanyi, Senior Operations Engineer
A. Nielsen, Senior Health Physicist
W. Pursley, Health Physicist
C. Safouri, Resident Inspector
Approved By:
Alan J. Blamey, Chief
Reactor Projects Branch 2
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Vogtle Electric Generating Plant in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to Calibrate Containment High-range Area Radiation Monitors Cornerstone Significance Cross-Cutting Aspect Report Section Emergency Preparedness Pending AV 05000424,05000425/2019003-01 Open EA-19-112
[H.1] -
Resources 71124.05 The inspectors identified an Apparent Violation (AV) of Technical Specification (TS) 3.3.3, for the failure to correctly calibrate the Vogtle Unit 1 (U1) and Unit 2 (U2) containment high-range area radiation monitors 1RE-0005, 1RE-0006, 2RE-0005, and 2RE-0006. Specifically, the source-to-detector geometry used for isotopic calibrations was not fixed and reproducible which resulted in radiation monitor indications in the main control room that were biased high. These radiation monitors are relied upon during an accident to provide release assessment for use by plant operators in determining the need to invoke site emergency plans.
Additional Tracking Items
Type Issue Number Title Report Section Status URI 05000424,05000425/20 18004-03 Calibration Surveillance Extension of Post Accident Monitoring Instruments 71111.22 Closed URI 05000425,05000424/20 18004-02 Calibration of Containment High-range Area Radiation Monitors 71124.05 Closed LER 05000424/2018-002-00 LER 2018-002-00 for Vogtle,
Unit 1, Manual Reactor Trip due to Receiving Rod Control Urgent Failure Alarm during Low Power Physics Testing.
71153 Closed
PLANT STATUS
Unit 1 began the inspection period at rated thermal power and remained at or near rated thermal power for the entire inspection period.
Unit 2 began the inspection period at rated thermal power. On July 19, 2019, Unit 2 tripped due to the inadvertent closure of the Loop 2 B Train Main Steam Isolation Valve (MSIV). Unit 2 returned to rated thermal power on July 25, 2019 and remained at or near rated thermal power for the rest of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Impending Severe Weather Sample (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated readiness for impending adverse weather conditions for Hurricane Dorian on September 3-4, 2019.
71111.04Q - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)1A Emergency Diesel Generator (EDG) while 1B EDG was inoperable due to a failed fuel injection pump on August 6, 2019.
(2)1A Nuclear Service Cooling Water (NSCW) while 1B NSCW Pump #2 was out of service on August 12, 2019.
(3)1B Component Cooling Water (CCW) system while 1A CCW room cooler was out of service on September 16, 2019.
(4)2B Centrifugal Charging Pump (CCP) system during 2A CCP testing on September 19, 2019.
71111.05Q - Fire Protection
Quarterly Inspection (IP Section 03.01) (4 Samples)
The inspectors evaluated fire protection program implementation in the following selected areas:
(1)2A/2B Auxiliary Component Cooling Water (ACCW) pump rooms, Safety Injection (SI)pump rooms, and Auxiliary Building Level 'B' Penetration Area, Zone 30/33/31/32/26B, on July 26, 2019.
- (2) Unit 1 Auxiliary Feedwater (AFW) pump house, Zone 155/156/157A/157B, on August 23, 2019.
(3)1A/1B ACCW heat exchanger rooms, Zone 49/52, on September 12, 2019.
(4)1A/1B ACCW pump rooms, SI pump rooms, and Auxiliary Building Level 'B' Penetration Area, Zone 30/31/32/33/26B, on September 12, 2019.
71111.06 - Flood Protection Measures
Inspection Activities - Underground Cables (IP Section 02.02c.) (1 Sample)
The inspectors evaluated cable submergence protection in:
- (1) 1NE96HKEPB01, 1NE7ADKEM39, 1NE7ADKEM40 on July 17, 2019.
71111.07A - Heat Sink Performance
Annual Review (IP Section 02.01) (1 Sample)
The inspectors evaluated readiness and performance of:
- (1) 1A EDG jacket water heat exchanger.
71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)
The inspectors completed an inspection to verify the licensees ability to evaluate the performance of their licensed operators during the conduct of examinations, to assess their ability to properly develop and administer requalification annual operating tests and biennial written examinations, to evaluate the performance of the control room simulator and their testing and maintenance of the simulator, to ensure that licensed individuals satisfy the conditions of their licenses, and to assess their effectiveness in ensuring that operator license conditions are satisfied.
- (1) Biennial Requalification Written Examinations
The inspectors evaluated the quality of the licensed operator biennial requalification written examination administered on November 21, 2018.
Annual Requalification Operating Tests The inspectors evaluated the adequacy of the facility licensees annual requalification operating test.
Administration of an Annual Requalification Operating Test
The inspectors evaluated the effectiveness of the facility licensee in administering requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives.
Requalification Examination Security
The inspectors evaluated the ability of the facility licensee to safeguard examination material, such that the examination is not compromised.
Remedial Training and Re-examinations
The inspectors evaluated the effectiveness of remedial training conducted by the licensee, and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.
Operator License Conditions
The inspectors evaluated the licensees program for ensuring that licensed operators meet the conditions of their licenses.
Control Room Simulator
The inspectors evaluated the adequacy of the facility licensees control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46.
Problem Identification and Resolution
The inspectors evaluated the licensees ability to identify and resolve problems associated with licensed operator performance.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the Control Room during a Unit 2 Steam Generator Loop 3 Level Control Channel Calibration and 2A EDG operability test on August 5, 2019 and September 23, 2019, respectively.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated simulator training of a Loss of Coolant Accident (LOCA) causing a Reactor Trip concurrent with a Pressurizer instrumentation failure on August 13, 2019.
71111.12 - Maintenance Effectiveness
Routine Maintenance Effectiveness Inspection (IP Section 02.01) (3 Samples)
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
(1)1A NSCW Fan #2 Trip Maintenance Preventable Functional Failure (MPFF), CR
===10546756, October 18, 2018.
- (2) Unit 1 and 2, System 1301S Main Steam, MSIV Plant Level Events, CR 10604001, April 23, 2019.
- (3) Unit 1 and 2, System 1208 Chemical Volume and Control System (CVCS)maintenance rule re-evaluation, CR 10591187, March 13, 2019.
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01)===
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
(1)1B EDG fuel injection pump emergent issue on August 5, 2019.
(2)1B Engineered Safety Feature (ESF) Chiller preventative maintenance (PM) outage and usage of Risk-Informed Completion Time (RICT) on August 14-15, 2019.
(3)1A NSCW Pump #5 system outage on August 26, 2019.
(4)2B NSCW Pump #4 system outage on September 10, 2019.
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 02.02) (5 Samples)
The inspectors evaluated the following operability determinations and functionality assessments:
- (1) Unit 2 CVCS Normal Charging Pump motor inboard bearing oil quality declining trend on July 12, 2019, CR 10628119.
(2)2A EDG voltage drop during surveillance testing on August 1, 2019, CR 10632909.
(3)1B EDG following repairs of issues impacting the fuel injection pump on August 6, 2019, CR 10635016/10634731.
(4)1A EDG abnormal noise during 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> endurance test on August 20, 2019, CR
===10639026.
- (5) 2A EDG air receiver #2 excess water on September 17, 2019, CR 10646135.
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)
The inspectors evaluated the following temporary or permanent modifications:
(1)50.59 modification package for the Accident Tolerant Fuel Lead Test Assemblies (LTAs) that were installed in Unit 2 during the 2019 refueling outage; the inspectors reviewed the composition of the limited number of LTAs, placement of LTA in non-limiting core locations and Technical Specification (TS) 5.6.5, Core Operating Limits Reports, including the analytical methods that were previously reviewed and approved by the NRC.
(2)50.59 evaluation of a procedure revision to 17019-1/2 regarding operator response to Turbine Condenser low vacuum/high rate of change lowering.
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01)===
The inspectors evaluated the following post maintenance tests:
- (1) Unit 2 Loop 2 Atmospheric Relief Valve (ARV) following a system outage on July 10, 2019, SNC685621.
(2)2A NSCW Pump #3 following a system outage on July 29, 2019, SNC998895.
(3)1A NSCW Fan #1 following a PM outage on July 24, 2019, SNC122439.
(4)1B EDG following repair of issues associated with the fuel injection pump failure on August 7, 2019, SNC1039987.
(5)2B NSCW Pump #4 following system outage on September 12, 2019, SNC894661.
(6)2A EDG jacket water leak repair on September 26, 2019, SNC1051230.
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated forced outage activities on Unit 2 after Unit 2 tripped due to a MSIV closure on Loop 2 from July 19, 2019 to July 22, 2019.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
(1)
===14633-1, Unit 1 Solid State Protection System (SSPS) Slave Relay K648 Train 'B' Test Safety Injection, on August 15, 2019.
(2)14616-1, Unit 1 'A' Train CCW/NSCW SSPS Slave Relay Test, on September 25, 2019.
Inservice Testing (IP Section 03.01)===
(1)
===14805A-1, Unit 1 'A' Train Residual Heat Removal (RHR) Inservice Test (IST) and Response Time Test, on July 24, 2019.
RCS Leakage Detection Testing (IP Section 03.01)===
(1)
===14905-1, RCS Leakage Calculation (Inventory Balance), following elevated Unidentified Leakage on August 23,
RADIATION SAFETY
71124.05 - Radiation Monitoring Instrumentation
Calibration and Testing Program (IP Section 02.02)===
The inspectors evaluated the calibration and testing program implementation.
- (1) The inspectors reviewed the following:
- The licensee's evaluation of URI 2018004-02.
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS07: High Pressure Injection Systems (IP Section 02.06)===
- (1) Unit 1 (July 1, 2018 - June 30, 2019)
- (2) Unit 2 (July 1, 2018 - June 30, 2019)
MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)
- (1) Unit 1 (July 1, 2018 - June 30,2019)
- (2) Unit 2 (July 1, 2018 - June 30, 2019)
MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)
- (1) Unit 1 (July 1, 2018 - June 30, 2019)
- (2) Unit 2 (July 1, 2018 - June 30, 2019)
71152 - Problem Identification and Resolution
Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
(1)
==2R20 polar crane movement during vessel flange repair evolution, CR10599538.
(2)==
Mislocated fuel assembly in cask loading pit, CR 10639050.
71153 - Followup of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)
The inspectors evaluated the following licensee event reports (LERs):
- (1) LER 05000424/2018-002-00, Manual Reactor Trip due to receiving Rod Control Urgent Failure Alarm during Low Power Physics Testing (ADAMS accession:
ML18337A188): The inspectors determined that it was not reasonable to foresee or correct the cause discussed in the LER therefore no performance deficiency was identified. The inspectors also concluded that no violation of NRC requirements occurred.
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
60855.1 - Operation of an Independent Spent Fuel Storage Installation at Operating Plants Operation of an Independent Spent Fuel Storage Installation at Operating Plants
- (1) The inspectors evaluated the licensees independent spent fuel storage installation cask loadings September 16 - 27, 2019. Specifically, the inspectors observed the following activities;
- Fuel selection and fuel loading
- Heavy load movement of the multi-purpose canister (MPC)
- Drying and backfill evolutions
- Closure welding and non-destructive weld evaluations
- Transfer and transport evolutions
- Radiological field surveys
INSPECTION RESULTS
Unresolved Item (Closed)
Calibration Surveillance Extension of Post Accident Monitoring Instruments URI 05000424,05000425/2018004-03 71111.22
Description:
Unresolved item (URI) 05000424, 425/2018004-03 was opened in inspection report 05000424, 425/2018004 (Agency wide Documents Access and Management System (ADAMS) Accession No. ML19038A490) to determine if a performance deficiency existed and if that performance deficiency was more than minor for the licensee's potential failure to justify the surveillance frequency extension of Post Accident Monitoring System (PAMS)instruments to include:
- (1) containment normal sumps level (narrow range),
- (2) containment water level (wide range),
- (3) containment radiation level monitors (high range), and
- (4) steam line radiation monitor.
The licensee evaluated historical drift for the instruments of concern and demonstrated no adverse trend that would impact extension of electronic calibrations to a staggered 18-month basis. The licensee also determined that credit for completion of a TS required CHANNEL CALIBRATION would be based on the completion of the less frequently performed electronic calibrations (staggered 18-month interval) since the isotopic calibrations are performed every 18-months.
The licensee did determine that the electronic calibration interval for the Containment High Range Radiation monitors should be decreased back to 18 months to match the isotopic interval. The movement of the surveillance frequency was based on the uncertainty that was recently determined to exist with the isotopic calibration process for the Containment High Range Radiation monitors and the inadequate amount of data available with the new calibration process. The inadequate isotopic calibration process is addressed in URI 05000424/425/2018004-02.
The inspectors performed additional inspection and review of licensee-supplied additional documentation, as well as consulted with NRC staff. Based upon information provided to the inspectors as well as results of NRC staff discussions, the inspectors determined that no violation of regulatory requirements exists. The inspectors also determined that there was no performance deficiency. This URI is closed.
Corrective Action Reference(s): The licensee entered the URI in CR 10621152 and documented their evaluation in Technical Evaluation (TE) 1047433.
Failure to Calibrate Containment High-range Area Radiation Monitors Cornerstone Significance Cross-Cutting Aspect Report Section Emergency Preparedness
Pending AV 05000424,05000425/2019003-01 Open EA-19-112
[H.1] -
Resources 71124.05 The inspectors identified an Apparent Violation (AV) of Technical Specification (TS) 3.3.3, for the failure to correctly calibrate the Vogtle Unit 1 (U1) and Unit 2 (U2) containment high-range area radiation monitors 1RE-0005, 1RE-0006, 2RE-0005, and 2RE-0006. Specifically, the source-to-detector geometry used for isotopic calibrations was not fixed and reproducible which resulted in radiation monitor indications in the main control room that were biased high. These radiation monitors are relied upon during an accident to provide release assessment for use by plant operators in determining the need to invoke site emergency plans.
Description:
In October 2018, the inspectors identified potential errors in the calibration process used to perform in-situ isotopic calibrations on the Vogtle U1 and U2 containment high-range area radiation monitors (CHRMs) 1RE-0005, 1RE-0006, 2RE-0005, and 2RE-0006. Specifically, the methodology used to perform the calibrations failed to create a reproducible source-to-detector geometry from one surveillance to the next. Instead, the licensees calibration procedure involved moving the cesium-137 (Cs-137) point source closer to the detector surface over time in an attempt to maintain, as the source decayed, a target dose rate of 17 R/hr +/- 20%. Prior to each calibration, the distance to achieve 17 R/hr was determined on a benchtop using the calibration source and a small-volume, NIST-traceable ion chamber. As this distance decreased over time, the potential existed for the active detection volume of the CHRMs to be unevenly irradiated during the in-situ isotopic calibration. As a result, it is possible the CHRMs would under respond compared to the much smaller benchtop ion chamber. Therefore, the instrument gain may have been unnecessarily adjusted upward to compensate for low detector response over the course of several calibration surveillances. The inspectors documented an Unresolved Item (URI) in inspection report 2018-004 (05000425,05000424/2018004-02).
In response to this URI, the licensee performed an evaluation to determine the magnitude of the calibration error and presented the results to NRC inspectors on June 19, 2019. The evaluation consisted of irradiating spare containment high range ion chamber tubes in a gamma box calibrator to determine nominal response characteristics and then performing a transfer calibration using the Cs-137 calibration source in a fixed, direct contact geometry with both the spare detectors and those currently installed on Unit 2. Using this methodology, a gain factor (R/hr/Amp) was calculated for 2RE-0005 and 2RE-0006 and compared to the gain factors currently in use. In this manner, all sources of potential error described in the URI (i.e. inconsistency in measurement distance, uneven irradiation, and failure to decay-correct the source) were addressed in the evaluation.
The results showed that the gain factors currently in use were biased high by 60% for 2RE-0005 and 84% for 2RE-0006. Therefore, indications for these instruments in the main control room (MCR) would be biased high by a similar amount. In addition to the licensees evaluation, the inspectors performed a review of gain factors for both units going back to 2009. This showed that 1RE-0005, 1RE-0006, 2RE-0005, and 2RE-0006 have been operating with a positive bias between 46% and 128% during that time period. This bias exceeds the +/- 20% acceptance criteria in calibration procedures 24989-1, Isotopic Channel Calibration of the Containment High Range Area Radiation Monitors 1RE-0005 and 1RE-0006 and 24989-2, Isotopic Channel Calibration of the Containment High Range Area Radiation Monitors 2RE-0005 and 2RE-0006 and exceeds the accuracy range of +/- 20% of the actual radiation field described in UFSAR Section 12. In addition, as the Cs-137 calibration source continued to decay the source would be moved closer to the detector surface. As a result, the uneven irradiation would become more pronounced and could result in continued changes to the gain factor over time and an even larger positive bias in MCR indication.
The inspectors noted that 1RE-0005, 1RE-0006, 2RE-0005, and 2RE-0006 are used during an accident to assist in making emergency action level (EAL) declarations, as described in the licensees EAL implementing procedure NMP-EP-141-003, Vogtle 1 & 2 Emergency Action Level and Basis. Specifically, the instruments are used in the Fission Product Barrier Degradation matrix (EALs FA1, FG1 and FS1) and Cold Shutdown/refueling System Malfunction Reactor Pressure Vessel Level accident scenario (EALs CG1 and CS1). Since the monitors were biased high compared to actual radiological conditions in containment, these emergency declarations would be made earlier than necessary or when a lower classification was more appropriate. In some cases, this would result in an Offsite Response Organization implementing unnecessary protective actions for the public.
Corrective Actions: The licensee is revising their procedures for performing calibrations on the containment high range area radiation monitors.
Corrective Action References: Condition Reports 10621148 and 10621284
Performance Assessment:
Performance Deficiency: The licensees failure to calibrate containment high range area radiation monitors, as required by TS 3.3.3, was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern.
Specifically, the magnitude of the detector overresponse would have increased over time as the Cs-137 source decayed.
Significance: The significance determination is pending an initial significance characterization and is not yet finalized.
Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety.
The event was a direct result of the licensees failure to provide adequate calibration procedures.
Enforcement:
Violation: Technical Specification 3.3.3 requires the licensee to perform periodic channel calibrations for post-accident monitoring equipment, including radiation monitors 1RE-0005, 1RE-0006, 2RE-0005, and 2RE-0006. Section 1.1 of the TS states that A channel calibration shall be the adjustment, as necessary, of the channel so that it responds within the required range and accuracy to known inputs. Contrary to this, since plant startup, the licensee has failed to periodically calibrate containment high-range area monitors 1RE-0005, 1RE-0006, 2RE-0005, and 2RE-0006 so that they responded within the required accuracy to known inputs. Upon identification, the licensee took action to revise their calibration procedures.
Enforcement Action: This violation is being treated as an apparent violation pending a final significance (enforcement) determination.
The disposition of this finding and associated violation closes URI:
05000425,05000424/2018004-02.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On October 16, 2019, the inspectors presented the integrated inspection results to Mr.
Keith Taber and other members of the licensee staff.
- On October 17, 2019, the inspectors discussed the closure of URI 05000425,05000424/2018004-02, resulting in AV 2019003-01, with Mr. Keith Taber and other members of the licensee staff.
- On August 22, 2019, the inspectors presented the Biennial Requalification Inspection results to Matthew Norris, Operations Director and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
60855.1
Corrective Action
Documents
10646689
Procedures
230-C
Spent Fuel Cask Bridge Crane Operating Instructions
Work Orders
SNC508771
71111.04Q Drawings
1X4DB116-2
P&I Diagram - Chemical & Volume Control System - System
No. 1208
37.0
71111.05Q Fire Plans
2726B-1
Zone 26B - Auxiliary Building - Levels A&B Fire Fighting
Preplans
3.2
2726B-2
Zone 26B - Auxiliary Building - Levels A&B Fire Fighting
Preplan
3.0
2730-1
Zone 30 - Auxiliary Building - Level B Fire Fighting Preplan
1.2
2730-2
Zone 30 - Auxiliary Building - Level B, ACCW Pump, Train A
Fire Fighting Preplan
1.0
2731-1
Zone 31 - Auxiliary Building - Level B Fire Fighting Preplan
3.1
2731-2
Zone 31 - Auxiliary Building - Level B Fire Fighting Preplan
1.0
2732-1
Zone 32 - Auxiliary Building - Level B Fire Fighting Preplan
2.0
2732-2
Zone 32 - Auxiliary Building - Level B, SI Pump, Train A Fire
Fighting Preplan
1.0
2733-1
Zone 33 - Auxiliary Building - Level B Fire Fighting Preplan
4.0
2733-2
Zone 33 - Auxiliary Building - Level B Fire Fighting Preplan
1.0
2749-1
Zone 49 - Auxiliary Building Level 1 Fire Fighting Preplan
3.0
2752-1
Zone 52 - Auxiliary Building Level 1 Fire Fighting Preplan
2.0
2855-1
Zone 155 - Auxiliary Feedwater Pumphouse - Train B Fire
Fighting Preplan
2.2
2856-1
Zone 156 - Auxiliary Feedwater Pumphouse Fire Fighting
Preplan
3.1
2857A-1
Zone 157A - Auxiliary Pumphouse - Train C Fire Fighting
Preplan
2.3
2857B-1
Zone 157B - Auxiliary Feedwater Pumphouse Fire Fighting
Preplan
1.2
Miscellaneous
Eight (8) Licensed
Operator Medical
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Records
JPM V-RQ-JP-
10008-001
Implement Tech Spec LCO Requirements for a Failed NR
Temperature Instrument (SRO Only)
Revision 8.2,
07/09/2019
JPM V-RQ-JP-
13105-001
Raise Accumulator Level While at Low RCS Pressure
Revision 1.0,
07/01/2019
JPM V-RQ-JP-
13130-002
Place Containment Hydrogen Monitors in Service
Revision
10.3,
06/19/2019
JPM V-RQ-JP-
13301-002
Manually Actuate Control Room Isolation Due to Smoke in
the Outside Air Intake (Alternate Path)
Revision
15.4,
06/24/2019
JPM V-RQ-JP-
213-002
Respond to a Radiation Alarm During a Liquid Radwaste
Release (Alternate Path)
Revision 2.1,
06/19/19
JPM V-RQ-JP-
18038-008
Locally Throttle RHR Flow Following Control Room
Evacuation
Revision 3.0,
07/01/2019
JPM V-RQ-JP-
19014-002
Manually align ECCS for Hot Leg Recirculation Phase
(Alternate Path)
Revision 9.3,
06/19/2019
JPM V-RQ-JP-
231-007
Locally Operate a Bypass Feed Isolation Valve
Revision 3.1,
06/19/2019
JPM V-RQ-JP-
231-009
Establish Main Feedwater Flow to SGs Following Loss of
Heat Sink
Revision 2.0,
06/19/2019
JPM V-RQ-JP-
NMP-EP-141-003
Classify an Emergency Event (SRO Only)
Revision 2.0,
06/19/2019
License Activation
Documentation
(NMP-TR-406) for
licensed
operators
Remedial
Training Plans for
two (2) Licensed
Operators from
current
Requalification
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Cycle
SBT for
Requalification
Scenario DS-06
Scenario-Based Testing records associated with
Requalification Scenario DS-06: 75% Power, SGTR
Rev 23.1,
03/13/2019
SBT Records for
Initial Scenario
- 1, June 2019
Exam
SBT Records Associated with Initial Scenario #1, June 2019
Exam: 50% Power, Uncontrolled Rod Withdrawal, LOCA
Revision 0,
2/19/2018
SBT Records for
Requalification
Scenario DS-21
Scenario-Based Testing records associated with
Requalification Scenario DS-21: 100% Power, Rod Ejection
Revision 7.2,
03/19/2019
Shift 4 Licensed
Operator 2019
LOCT Segment 2
Training
Attendance
Records
Shift 4 Licensed
Personnel
Quarterly
Proficiency Time
Records (NMP-
TR-406-F01,
NMP-OS-026-F-
01)
Simulator Cycle
Core Test
Certification
2/17/2018
Simulator
Scenario DS #10
75% Power, BOL, Loss of Power, LOCA
Revision
18.1
Simulator
Scenario DS #14
100 % Power, MOL, Steam Leak, LOCA
Revision
19.1
Simulator
Scenario DS #21
100% Power, EOL, Ejected Control Rod LOCA
Revision 8.0
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Simulator
Scenario DS #6
75% Power, BOL, SGTL to SGTR
Revision
24.0
Simulator Test
05-03
LOCA Outside Containment
09/19/2017
Simulator Test
05-19b
Control Rod Failures
09/29/2017
Simulator Test
05-47d
Generator and Grid Malfunctions
10/10/2017
Simulator Test
05-67a
RCP #1 and 2 Seal Failures with Accidental Release from
the Waste Monitor Tank
10/02/2017
Simulator Test
06-04
Plant Shutdown from Rated Power to Hot Standby
2/19/2018
Simulator Test
06-08
Surveillance Testing on Safety Equipment Systems (DG
Operability Test)
2/10/2018
Simulator Test
06-08
Surveillance Testing on Safety Equipment Systems
(14510A-1 Train A Control Room Emergency Filtration
System Operability Test)
2/10/2018
Simulator Test
06-09
Steady State Performance Test at 50% Power
2/18/2018
Simulator Test
07-02
Simultaneous Trip of all Feedwater Pumps
11/20/2018
Simulator Test
07-06
Main Turbine Trip without a Reactor Trip
11/20/2018
Simulator Test
07-09
Maximum Size Unisolable Rupture
11/20/2018
Procedures
NMP-OS-026
License Administration
Version 1.0
NMP-TR-208
Examination and Examination Security
Version 10.0
NMP-TR-416
Licensed Operator Continuing Training Program
Administration
Version 10.0
NMP-TR-422
Simulator Configuration Control
Version 7.0
NMP-TR-424
Licensed Operator Continuing Training Exam Development
Version 6.0
71111.11Q Procedures
13506-C
Digital Feedwater Control System
9.0
24484-2
Steam Generator #3 Level Control 2F-531 Channel
Calibration
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
10623372,
10604001,
10638064,
10620795,
10591187,
10354066
Miscellaneous
MREP Meeting
Agenda Minutes
on August 9,
2019 and June 5
& 6 & 11, 2019
Procedures
NMP-ES-027
10.0
NMP-ES-027
9.0
Corrective Action
Documents
10634731
Miscellaneous
Plan of the Day for August 5, 2019
Unit 1 Phoenix Integrated Risk Reports for August 5, 2019
Unit 1 Narrative Control Room Logs for August 5, 2019
1-ET-18-2403-
00156
Protected Equipment Tagout
Procedures
NMP-OS-010
Protected Train/Division and Protected Equipment Program
8.0
NMP-OS-010-003
Vogtle Protected Equipment Logs
10.0
Corrective Action
Documents
10638697,
10634731,
10635016,
10632909,
2737
Drawings
2X3D-BH-G03H-2 Diesel Engine Control Diesel Engine - Generator DG2A
Sheet 2
10.0
Diesel Engine Control Diesel Engine - Generator DG2B
Sheet 1
10.0
2X3D-BH-G03R-1 Diesel Engine Control Diesel Engine - Generator DG2B
Sheet 1 of 2
9.0
Diesel Engine Control Diesel Engine - Generator DG2B
11.0
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Sheet 1
Diesel Engine Control Diesel Engine - Generator DG2B
Sheet 2
11.0
AX4AK01-00748
Schematic Power Driven Potentiometer
Miscellaneous
CE IB 02-18
Cooper-Enterprise Owners Group Information Bulletin -
R4/RV4 Fuel Pump Base Bolts
06/07/2002
Procedures
14668B-1
Train B Diesel Generator Operability Test
8.2
14980A-2
Diesel Generator 2A Operability Test
30.1
14980B-1
Diesel Generator 1B Operability Test
30.2
Work Orders
SNC1039987
Calculations
NMP-ES-050-F01 Vogtle Unit 2 Cycle 21 Reload Analysis
06/26/2018
Engineering
Evaluations
NF-GP-18-64
Vogtle Electric Generating Plant Unit 2 Cycle 21 Reload 10 CFR 50.59 Evaluation and Supplemental Technical
Evaluation for Exclusion Zone Change
Version 1,
2/19/2018
NMP-AD-008-F01
50.59 Applicability Determination for Vogtle 2 Cycle 21
Reload Core and Associated COLR with FRAMATOME
GAIA Lead Test Assemblies with EATF Features
2/12/2019
NMP-AD-010-F03
CFR 50.59 Evaluation for Vogtle Unit 2 Cycle 21 Reload
Core and Associated COLR with FRAMATOME GAIA Lead
Test Assemblies with EATF Features
03/15/2019
NMP-AD-010-F03
CFR 50.59 Evaluation of Major Procedure Revision to
17019-1/2 regarding operator response to ALB19-04 Turbine
Condenser Low Vacuum/High Rate of Change Lowering
08/27/2019
Miscellaneous
ANP-3735P
Mechanical Design Report for GAIA/EATF Lead Assemblies
at Vogtle
November
2018
FS1-0041257-1.0
Description of EATF Features and Clarifications to Support
SNC Responses to FDC and 10 CFR 50.59
2/07/2019
Corrective Action
Documents
10633110,
10632907,
10632977,
10632590,
10634731,
10635016,
10632977,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
10632590,
10627543
Corrective Action
Documents
Resulting from
Inspection
10638924
Drawings
Elementary Diagram Nuclear Service Cooling Water System
2-1202-P4-004-M01
24.0
Procedures
14430-1
NSCW Cooling Tower Fans Monthly Test
14668B-1
Train B Diesel Generator Operability Test
8.2
14802B-2
Train B NSCW Pump / Check Valve IST and Response
Time Test
11.2
14825-2
Quarterly Inservice Valve Test
98.1
14825-2
Quarterly Inservice Valve Test
98.1
14980B-1
Diesel Generator 1B Operability Test
30.2
277-C
NTS Timing Relay Maintenance
3.0
Work Orders
SNC122439,
SNC841815,
SNC985435,
SNC880472,
SNC998895,
SNC987801,
SNC1039987,
SNC841815,
SNC894661,
SNC989050,
SNC547667
Corrective Action
Documents
10640132
Procedures
13744B-1
Train B Essential Chilled Water System
14633-1
SSPS Slave Relay K648 Train B Test Safety Injection
14805A-1
Train A Residual Heat Removal Pump and Check Valve IST
and Response Time Tests 7.0
14905-1
RCS Leakage Calculation (Inventory Balance)
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
NMP-OS-009
RCS Unidentified Leakage Monitoring Program
3.0
Engineering
Evaluations
Plant Vogtle Response to Containment High Range Area
Radiation Monitor Issues
December
2018
Plant Vogtle Response to URI
June 2019
Procedures
24989-1
Isotopic Channel Calibration of the Containment High Range
Area Monitors 1RE-0005 and 1RE-0006
Rev. 1
24989-1
Isotopic Channel Calibration of the Containment High Range
Area Monitors 1RE-0005 and 1RE-0006
Ver. 7.1
24989-2
Isotopic Channel Calibration of the Containment High Range
Area Monitors 2RE-0005 and 2RE-0006
Rev. 1
24989-2
Isotopic Channel Calibration of the Containment High Range
Area Monitors 2RE-0005 and 2RE-0006
Ver. 4
43802-C
Calibration of Gamma Standards
Ver. 17
NMP-EP-141-003
Vogtle 1 & 2 Emergency Action Levels and Basis (NEI 99-01
revision 6)
Ver. 4.0
Corrective Action
Documents
10639050,
10599538
Miscellaneous
NMP-RE-011-F01
UFLO #5 MPC-490 Loading Plan
2.0
Procedures
93120-C
Spent Fuel Assembly Handling Tool Operating Instructions
14.1
93120-C
Spent Fuel Assembly Handling Tool Operating Instructions
247-C
Containment Polar Crane Operating Instructions
28.1
93713-C
MPC Fuel Loading Operations
2.0
NMP-RE-006
Dry Cask Loading Verification
1.3
Miscellaneous
NMP-GM-002-
F02
Cause Determination Report Summary for CR10542344
08/14/2019