IR 05000395/2010005
| ML110270055 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 01/27/2011 |
| From: | Gerald Mccoy NRC/RGN-II/DRP/RPB5 |
| To: | Gatlin T South Carolina Electric & Gas Co |
| References | |
| IR-10-005 | |
| Download: ML110270055 (31) | |
Text
UNITED STATES ary 27, 2011
SUBJECT:
VIRGIL C. SUMMER NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT 05000395/2010005
Dear Mr. Gatlin:
On December 31, 2010, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Virgil C. Summer Nuclear Station. The enclosed inspection report documents the inspection results, which were discussed on January 13, 2011, with you and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
This report documents one NRC-identified finding of very low safety significance (Green) which was determined to be a violation of NRC requirements. Additionally, a licensee-identified violation which was determined to be of very low safety significance is listed in this report.
However, because of the very low safety significance and because they were entered into your corrective action program, the NRC is treating these findings as non-cited violations (NCVs)
consistent with Section 2.3.2 of the NRCs Enforcement Policy. If you contest any NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the United States Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001, with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Virgil C. Summer Nuclear Station.
In addition, if you disagree with the cross-cutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, RII, and the NRC Senior Resident Inspector at the Virgil C. Summer Nuclear Station.
SCE&G 2 In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, 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 NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Gerald J. McCoy, Chief Reactor Projects Branch 5 Division of Reactor Projects Docket No.: 50-395 License No.: NPF-12
Enclosure:
NRC Integrated Inspection Report 05000395/2010005 w/Attachment: Supplemental Information
REGION II==
Docket No.: 50-395 License No.: NPF-12 Report No.: 05000395/2010005 Licensee: South Carolina Electric & Gas (SCE&G) Company Facility: Virgil C. Summer Nuclear Station Location: P.O. Box 88 Jenkinsville, SC 29065 Dates: October 1, 2010 through December 31, 2010 Inspectors: J. Zeiler, Senior Resident Inspector E. Coffman, Resident Inspector R. Carrion, Senior Reactor Inspector (Section 4OA5.2)
E. Lea, Senior Operations Inspector (Section 1R11.2)
R. Temps, Senior Safety Inspector (Section 4OA5.2)
R. Williams, Reactor Inspector (Section 4OA5.3)
Approved by: Gerald J. McCoy, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000395/2010005; 10/01/2010 - 12/31/2010: Virgil C. Summer Nuclear Station;
Identification and Resolution of Problems.
The report covered a 3-month period of inspection by resident inspectors and announced inspections by three regional inspectors and an NRC headquarters inspector. One Green finding, which was a non-cited violation (NCV), was identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC)0609, Significance Determination Process (SDP). The cross-cutting aspect was determined using IMC 0310, Components Within the Cross-Cutting Areas. Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review.
The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.
NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
- Green.
The inspectors identified a non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to identify and correct a condition adverse to quality following the February 10, 2010, failure of the A Emergency Diesel Generator (EDG) jacket water pump mechanical seal.
Specifically, the licensee failed to identify and correct inadequacies in their EDG preventive maintenance program for monitoring engine driven pump seal leakage in accordance with vendor recommendations, leading to subsequent A EDG jacket water seal leakage going unidentified from approximately June 1, 2010, until October 20, 2010. The licensee initiated condition report (CR)-10-03861 and implemented requirements and operator training to conduct proper seal leakage monitoring during subsequent EDG operations.
The inspectors determined that the licensees failure to take adequate corrective actions to identify and correct inadequacies in the EDG PM program for monitoring EDG engine driven pump seal leakage in accordance with vendor recommendations was a performance deficiency that was within the licensees ability to foresee and correct. This finding is more than minor because if left uncorrected, the issue would become a more significant safety concern, in that, the potential exists for unidentified engine driven pump seal leakage that could lead to EDG failure. This issue is associated with the equipment performance attribute of the Mitigating System cornerstone and adversely affects the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the failure to take adequate corrective actions to identify inadequacies in the EDG preventive maintenance program for monitoring EDG engine driven pump seal leakage in accordance with vendor recommendations could adversely affect the reliability of the EDGs. This finding was evaluated using Inspection Manual Chapter 0609,
Significance Determination Process, Phase 1 Worksheet for mitigating systems.
The finding was determined to be of very low safety significance (Green) because it did not actually result in the loss of the EDG system safety function or the loss of function of a single EDG. The cause of this finding was directly related to the problem evaluation cross-cutting aspect in the corrective action program component of the Problem Identification and Resolution area because the licensee did not thoroughly evaluate the February 10, 2010, jacket water pump mechanical seal failure event and identify nonconformance with the vendor recommended visual inspections of engine driven pump seals during EDG operations (P.1(c)). (Section 4OA2.3.1)
Licensee-Identified Violations
A violation of very low safety significance that was identified by the licensee has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. This violation and corrective action tracking numbers are listed in Section 4OA7 of this report.
REPORT DETAILS
Summary of Plant Status
The unit began the inspection period at full Rated Thermal Power (RTP). The unit operated at essentially full RTP for the entire inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
1R01 Adverse Weather Protection
.1 Seasonal Weather Susceptibilities
a. Inspection Scope
The inspectors performed one adverse weather inspection for readiness of cold weather. The inspectors verified the licensee had implemented applicable sections of operations administrative procedure (OAP)-109.1, Revision (Rev.) 3A, Guidelines for Severe Weather. The inspectors reviewed preparations for extreme cold weather and walked down the condensate storage tank (CST), refueling water storage tank (RWST),and auxiliary building and waste building heat trace and freeze protection panels to assess whether the equipment was adequately protected from cold weather and was functioning as expected. Also, the inspectors reviewed the licensees corrective action program (CAP) database to verify that freeze protection problems were being identified at the appropriate level, entered into the CAP, and appropriately resolved.
b. Findings
No findings were identified.
.2 External Flooding
a. Inspection Scope
The inspectors reviewed the licensees external flood design mitigation plans to determine consistency with design requirements, updated final safety analysis report (UFSAR) Sections 2.4.2 through 2.4.10, flood analysis documents, emergency plan procedure (EPP)-015, Rev. 17, Natural Emergency, and OAP-109.1, Rev. 3A, Guidelines for Severe Weather. The inspectors performed walkdowns of the station to verify flood protection features remained as described in the UFSAR. Specifically, the inspectors performed visual examinations of the storm drain system inside the protected area to verify that drains were not blocked and the ground was properly graded to channel water into the system. In addition, the inspectors conducted rooftop walkdowns of the auxiliary building, turbine building, control building, fuel handling building, and service water pumphouse to examine the condition of the rooftop drainage system and verify proper drainage capability.
b. Findings
No findings were identified.
1R04 Equipment Alignment
.1 Partial System Walkdowns
a. Inspection Scope
The inspectors conducted three partial equipment alignment walkdowns which are listed below, to evaluate the operability of selected redundant trains or backup systems with the other train or system inoperable or out of service (OOS). Correct alignment and operating conditions were determined from the applicable portions of drawings, system operating procedures (SOPs), and technical specifications (TS). The inspections included review of outstanding maintenance work orders (WOs) and related condition reports (CRs) to verify that the licensee had properly identified and resolved equipment alignment problems that could lead to the initiation of an event or impact mitigating system availability. Documents reviewed are listed in the Attachment.
- A and B motor driven emergency feedwater (MDEFW) pumps, while the turbine driven emergency feedwater (TDEFW) pump was OOS for scheduled preventive maintenance (PM)
- B residual heat removal (RHR) pump while the A RHR pump was OOS for scheduled preventive maintenance
- A and C centrifugal charging pumps (CCPs) while the B CCP was OOS for scheduled preventive maintenance
b. Findings
No findings were identified.
.2 Complete System Walkdown
a. Inspection Scope
The inspectors performed a detailed review and walkdown of the service water (SW)system to identify any discrepancies between the current operating system equipment lineup and the designed lineup. This walkdown included accessible areas of the buildings and the equipment alignment configuration as indicated from valves, pumps, and control room equipment status lights. In addition, the inspectors reviewed completed surveillance procedures, outstanding WOs, system health reports, and related CRs to verify that the licensee had properly identified and resolved equipment problems that could affect the availability and operability of the system. Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
1R05 Fire Protection
.1 Fire Protection Tours
a. Inspection Scope
The inspectors reviewed recent CRs, WOs, and impairments associated with the fire protection system. The inspectors reviewed surveillance activities to determine whether they supported the operability and availability of the fire protection system. The inspectors assessed the material condition of the active and passive fire protection systems and features and observed the control of transient combustibles and ignition sources. The inspectors conducted routine inspections of the following five areas (respective fire zones also noted):
- TDEFW pump room (fire zone 25.2)
- Auxiliary building (AB) 397 foot elevation (fire zone AB-1.4)
- Control building (CB) relay room (fire zones CB-6, CB-10, and CB-12)
- A, B, and C CCP rooms (fire zones AB-1.5, AB-1.6 and AB-1.7)
- Cable spreading rooms (fire zones CB-4 and CB-15)
b. Findings
No findings were identified.
.2 Annual Fire Brigade Drill Observation
a. Inspection Scope
The inspectors observed the performance of the licensees fire drill on October 6, 2010.
This unannounced fire drill was conducted during backshift for the B operating shift crew and involved an electrical breaker fire in the XSW1DB1 switchgear room located in the AB. The inspectors evaluated the readiness of licensee personnel to prevent and fight fires including the following aspects:
- Observe whether turnout clothing and self-contained breathing apparatus (SCBA)equipment were properly worn
- Determine whether fire hose lines were properly laid out and nozzle pattern simulated being tested prior to entering the fire area of concern
- Verify that the fire area was entered in a controlled manner
- Review if sufficient firefighting equipment was brought to the scene by the fire brigade to properly perform their firefighting duties
- Verify that the fire brigade leaders fire fighting directions were thorough, clear and effective, and that, if necessary, offsite fire team assistance was requested
- Verify that radio communications with plant operators and between fire brigade members were efficient and effective
- Confirm that fire brigade members checked for fire victims and fire propagation into applicable plant areas
- Observe if effective smoke removal operations were simulated
- Verify that the fire fighting pre-plans were properly utilized and were effective
- Verify that the licensee pre-planned drill scenario was followed, drill objectives met the acceptance criteria, and deficiencies were captured in post drill critiques
b. Findings
No findings were identified.
1R06 Flood Protection Measures
a. Inspection Scope
The inspectors walked down and reviewed the turbine building flood protection features, including penetrations required to be sealed, level instrumentation for tripping the circulating water (CW) pumps during a system pipe break, and plant maintenance and test records of flood protection level instrumentation. The inspectors evaluated the flood protection features and equipment to determine consistency with design requirements, UFSAR, and flood analysis documents. The inspectors reviewed the licensees CAP database to verify that internal flood protection problems were being identified at the appropriate level, entered into the CAP, and appropriately resolved.
b. Findings
No findings were identified.
1R07 Heat Sink Performance
a. Inspection Scope
The inspectors conducted one heat sink performance sample. The inspectors reviewed the last two performance test results conducted by the licensee on the A and B component cooling water (CCW) heat exchangers and discussed the results with the system engineer. The inspectors also reviewed SW and CCW system health reports, verified CCW heat exchanger backflush compensatory measures were being conducted at the recommended frequency, and reviewed CRs on CCW heat exchanger performance issues.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program
.1 Quarterly Resident Inspector Observations
a. Inspection Scope
On November 15, 2010, the inspectors observed the performance of senior reactor operators and reactor operators on the plant simulator during licensed operator requalification annual examinations. The scenario involved a feedwater pump trip, a steam generator level transmitter failure, a main feedwater pump master controller failure, a failure of the turbine generator to trip on reactor trip, and subsequent loss of all emergency feedwater. The inspectors assessed overall crew performance, communications, oversight of supervision, and the evaluators' critique. The inspectors verified that any significant training issues were appropriately captured in the licensees CAP.
b. Findings
No findings were identified.
.2 Annual Review of Licensee Requalification Examination Results
a. Inspection Scope
On August 27, 2010, the licensee completed the annual requalification operating test required to be administered to all licensed operators in accordance with 10 CFR 55.59(a)(2). The inspectors performed an in-office review of the overall pass/fail results of individual operating tests and the crew simulator operating tests. These results were compared to the thresholds established in Inspection Manual Chapter 0609, Appendix I, Operator Requalification Human Performance Significance Determination Process.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors evaluated two equipment issues described in the CRs listed below to verify the licensees effectiveness with the corresponding preventive or corrective maintenance associated with structures, systems, and components (SSCs). The inspectors reviewed Maintenance Rule (MR) implementation to verify that component and equipment failures were identified, entered, and scoped within the MR program.
Selected SSCs were reviewed to verify proper categorization and classification in accordance with 10 CFR 50.65. The inspectors examined the licensees 10 CFR 50.65(a)(1) corrective action plans to determine if the licensee was identifying issues related to the MR at an appropriate threshold and that corrective actions were established and effective. The inspectors review also evaluated if maintenance preventable functional failures (MPFFs) or other MR findings existed that the licensee had not identified.
The inspectors reviewed the licensees controlling procedures, i.e., engineering services procedure (ES)-514, Rev. 4, Maintenance Rule Implementation, and station administrative procedure (SAP)-0157, Rev. 0A, Maintenance Rule Program, to verify consistency with the MR requirements.
- CR-10-02169, C safety-related chiller trip on low refrigerant pressure due to faulty load control circuit problem
- CR-10-04168, A RHR pump circuit breaker failure to close due to failure of the secondary trip latch
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors evaluated, as appropriate, for the five selected work activities listed below:
- (1) the effectiveness of the risk assessments performed before maintenance activities were conducted;
- (2) the management of risk;
- (3) that, upon identification of an unforeseen situation, necessary steps were taken to plan and control the resulting emergent work activities; and,
- (4) that emergent work problems were adequately identified and resolved. The inspectors evaluated the licensees work prioritization and risk characterization to determine, as appropriate, whether necessary steps were properly planned, controlled, and executed for the planned and emergent work activities.
- Work Week 2010-41: risk assessment for scheduled maintenance and testing on the switchyard relay house replacement (Yellow risk), A safety-related chiller replacement, TDEFW pump/turbine (Yellow risk), east/west penetration room exhaust fans, and A CCW heat exchanger performance testing
- Work Week 2010-42: risk assessment for scheduled maintenance and testing on the switchyard relay house replacement (Yellow risk), A safety-related chiller replacement, C CCP and associated components, B MDEFW pump, and B containment spray pump
- Work Week 2010-43: risk assessment for scheduled maintenance and testing on the switchyard relay house replacement (Yellow risk), A safety-related chiller replacement, A and B main steam header power relief valves, emergent repairs to the B CW pump, and A RHR pump and associated components (Yellow risk)
- Work Week 2010-44: risk assessment for scheduled maintenance and testing on the switchyard relay house replacement (Yellow risk), A safety-related chiller replacement, Pineland 230 kilovolt transmission line rebuild, spent fuel pool fuel rod transfer activities, C SW pump and associated components (Yellow risk), A MDEFW pump, A battery charger, and A CCP and associated components
- Work Week 2010-49: risk assessment for scheduled maintenance and testing on the switchyard relay house replacement (Yellow risk), A safety-related chiller replacement, TDEFW pump testing, B emergency diesel generator (EDG) minor lubrication/fuel oil repairs (Yellow risk), and B CCP
b. Findings
No findings were identified.
1R15 Operability Evaluations
a. Inspection Scope
The inspectors reviewed five operability evaluations listed below, affecting risk significant mitigating systems to assess, as appropriate:
- (1) the technical adequacy of the evaluations;
- (2) whether operability was properly justified and the subject component or system remained available, such that no unrecognized increase in risk occurred;
- (3) whether other existing degraded conditions were considered;
- (4) that the licensee considered other degraded conditions and their impact on compensatory measures for the condition being evaluated; and,
- (5) the impact on TS limiting conditions for operations and the risk significance in accordance with the significance determination process. Also, the inspectors verified that the operability evaluations were performed in accordance with SAP-209, Rev. 0E, Operability Determination Process, and SAP-999, Rev. 5, Corrective Action Program.
- CR-10-03862, A SW pump motor boroscope revealed oil and dirt coating windings
- CR-10-03912, operability of RWST during purification and sampling operations
- CR-10-04091, instrument air supply pressure regulator for valve 1FV03551-EF drifted high
- CR-10-04172, RHR vent indicator found low out-of-specification
b. Findings
No findings were identified.
1R18 Plant Modifications
a. Inspection Scope
For the two equipment changes listed below that were considered temporary modifications, the inspectors evaluated the changes for adverse effects on system availability, reliability, and functional capability. Documents reviewed, as applicable, included associated 10 CFR 50.59 reviews, engineering calculations, WOs and implementation packages, plant electrical and mechanical drawings, corrective action documents, applicable sections of the UFSAR, supporting analyses, TS, and design basis information.
- Bypass Authorization Request (BAR) 10-03, install electrical jumper to allow opening of liquid waste discharge valve XVD06910
- BAR 10-04, install electrical jumper to enable re-flash alarms on heat trace panels for circuits associated with atmospheric radiation monitors RM-A2 and RM-A3
b. Findings
No findings were identified.
1R19 Post Maintenance Testing
a. Inspection Scope
For the six maintenance activities listed below, the inspectors reviewed the associated post-maintenance testing (PMT) procedures and either witnessed the testing and/or reviewed test records to assess whether:
- (1) the effect of testing on the plant had been adequately addressed by control room and/or engineering personnel;
- (2) testing was adequate for the maintenance performed;
- (3) test acceptance criteria were clear and adequately demonstrated operational readiness consistent with design and licensing basis documents;
- (4) test instrumentation had current calibrations, range, and accuracy consistent with the application;
- (5) tests were performed as written with applicable prerequisites satisfied;
- (6) jumpers installed or leads lifted were properly controlled;
- (7) test equipment was removed following testing; and,
- (8) equipment was returned to the status required to perform its safety function. The inspectors verified that these activities were performed in accordance with general test procedure (GTP)-214, Rev.
5A, Post Maintenance Testing Guideline.
- WOs 1010934, 1010935, 1003416, and 1004912: PMT following PM on A RHR pump and associated support components
- WO 1015093: PMT following repair of volume control tank boric acid inlet flow control valve
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors observed and/or reviewed the five surveillance test procedures (STPs) or Preventive Test Procedures (PTP) listed below to verify that TS or risk significant surveillance requirements were followed and that test acceptance criteria were properly specified to ensure that the equipment could perform its intended safety function. The inspectors verified that proper test conditions were established as specified in the procedures, that no equipment preconditioning activities occurred, and that acceptance criteria were met.
In-Service Tests:
- STP-105.003, Rev. 15B, Safety Injection Valve Operability Test (A Train)
Other Surveillance Tests:
- STP-123.003B, Rev. 6, Train B Service Water System Valve Operability Test
- STP-125.001, Rev. 14G, Electric Power Systems Weekly Test
- STP-120.003, Rev. 8H, Emergency Feedwater Valve Verification
- PTP-102.014, Rev. 0C, Main Generator Gross and Net Reactive Power Capability
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation
a. Inspection Scope
On October 27, 2010, the inspectors reviewed and observed the performance of an emergency preparedness training drill that involved reactor fuel cladding degradation followed by a large break loss-of-coolant accident (LOCA) and subsequent loss of containment integrity with the release of radioactivity to the environment (scenario EPP-10-02A, V. C. Summer Nuclear Station B ERO Training Drill). The inspectors assessed the emergency procedure usage, emergency plan classifications, notifications, and protective action recommendation development. The inspectors evaluated the adequacy of the licensees conduct of the drill and critique performance. The inspectors verified that the drill critique identified drill performance weaknesses and entered these items into the licensees CAP.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator (PI) Verification
Cornerstone: Mitigating Systems
a. Inspection Scope
The inspectors verified the accuracy of the licensees PI submittals listed below for the period October 1, 2009, through September 30, 2010. The inspectors used the performance indicator definitions and guidance contained in NEI 99-02, Rev. 6, Regulatory Assessment Performance Indicator Guideline, and licensee procedure SAP-1360, Rev. 2, NRC and INPO/WANO Performance Indicators, to check the reporting of each data element. The inspectors sampled licensee event reports (LERs),operator logs, tagout records, plant risk records, plant status reports, CRs, and performance indicator data sheets to verify that the licensee had properly reported the PI data. Also, the inspectors discussed the PI data with the licensee personnel associated with the performance indicator data collection and evaluation.
- Mitigating System Performance Index (MSPI) - Heat Removal System
- MSPI - Cooling Water Systems
- Safety System Functional Failures
b. Findings
No findings were identified.
4OA2 Identification and Resolution of Problems
.1 Review of Items Entered into the Corrective Action Program
a. Inspection Scope
As required by Inspection Procedure 71152, Identification and Resolution of Problems, and in order to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensees CAP. This review was accomplished by either attending daily screening meetings that briefly discussed major CRs, or accessing the licensees computerized corrective action database and reviewing each CR that was initiated.
b. Findings
No findings were identified.
.2 Semi-Annual Review to Identify Trends
a. Inspection Scope
The inspectors performed a review of the licensees CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue. The review was focused on repetitive equipment issues, but also considered trends in human performance errors, the results of daily inspector corrective action item screening discussed in Section 4OA2.1 above, licensee trending efforts, and licensee human performance results. The review nominally considered the six-month period of July 2010 through December 2010.
Documents reviewed included licensee monthly and quarterly corrective action trend reports, engineering system health reports, maintenance rule documents, department self-assessment activities, and quality assurance audit reports.
b. Findings
No new adverse trends were identified this period that had not already been identified by the licensee.
.3 Annual Sample Review
1) Quarterly Sample Review
a. Inspection Scope
The inspectors reviewed the issue listed below in detail to evaluate the effectiveness of the licensees corrective actions for important safety issues.
- CR-10-00632, excessive A EDG cooling water leakage from jacket water pump seal The inspectors assessed whether the issue was properly identified; documented accurately and completely; properly classified and prioritized; adequately considered extent of condition, generic implications, common cause, and previous occurrences; adequately identified root causes/apparent causes; and identified appropriate and timely corrective actions. Also, the inspectors verified the issues were processed in accordance with procedure SAP-999, Rev. 5, Corrective Action Program.
b. Findings
Introduction:
The inspectors identified a Green non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to identify and correct a condition adverse to quality following the February 10, 2010, failure of the A EDG jacket water pump mechanical seal. Specifically, the licensee failed to identify and correct inadequacies in their EDG PM program for monitoring engine driven pump seal leakage in accordance with vendor recommendations, leading to subsequent A EDG jacket water seal leakage going unidentified from approximately June 1, 2010, until October 20, 2010.
Description:
CR-10-00632 documented the licensees investigation into the February 10, 2010, A EDG excessive jacket water cooling pump seal leakage that rendered the EDG inoperable. When the seal failure occurred, the EDG was in operation and had just completed a routine monthly TS surveillance one-hour operational run. The licensee later determined that the magnitude of the seal leakage was approximately 3 gpm. This leakage rate would not have allowed time for the operators to have manually made up to the jacket water expansion tank prior to losing adequate engine cooling capability during a design basis accident event. Therefore, the failure was classified as a MSPI Emergency AC Power failure to run event. The licensee determined the cause of the event was the sudden catastrophic failure of the mechanical seal due to age related degradation of the elastomeric material in the seal. The seal had never been replaced and degraded over the years of service.
The licensees apparent cause investigation reviewed the adequacy of their existing engine driven pump seal preventive maintenance program. This vendor recommended PM strategy relied on periodic operator visual checks for leakage during EDG operations and a six-month mechanical maintenance PM whereby mechanical maintenance personnel visually checked for leakage. These visual checks were established in accordance with the Fairbank Morse Owners Group (FMOG) maintenance recommendations in lieu of a PM for periodic pump seal replacements. The CR investigation concluded that they were properly implementing the FMOG Engine Recommendation #17, Check All Engine Driven Pump Seals for Excessive Leakage, which included the following details:
- A visual leakage check of the engine driven jacket water, air cooler, and fuel oil pumps during EDG operation to ensure seal and gasket integrity,
- Observe jacket water and air cooler engine driven pumps for water leakage on the engine side of the pump casing during EDG operation. On these pumps, there is a tell tale (a small hole below the shaft) where leakage can be observed, and,
- If leakage of pump seals is observed, a judgment must be made whether the leakage rate is excessive such that the EDG will not be able to meet its licensing requirements for the duration of post accident operation.
During review of this CR, the inspectors independently validated that the above mentioned PMs were being conducted as stated in the CR. The inspectors subsequently identified that the six-month mechanical maintenance PMs were being conducted; however, there was no evidence that operator visual checks were being performed during EDG operational runs. Specifically, the inspectors found neither procedural requirements for conducting these visual checks, nor any operator training on the expectations for performing the checks. The inspectors interviewed several qualified operators on EDG operations and none were familiar with the location of either the jacket water or intercooler pump tell tale drains, or the existence of the drains. The inspectors determined that since these tell tale drains are underneath the pumps and behind the fuel oil filters and pump suction/discharge piping, they were not readily accessible to being observed unless personnel are specifically looking for leakage from these areas. Any leakage from these drains would fall between the engine and the frame rail and not onto the floor where it would be more noticeable or obvious where it came from. Additionally, based on visual observation of the jacket water and intercooler tell tale drains by the inspectors on September 30, 2010, a noticeable wetted condition was present, albeit there was no active leakage identified since the engine was not in operation. Based on concerns raised by the inspectors regarding the lack of evidence that visual checks were being conducted, the licensee provided operator instructions and training on the conduct of these checks, which were to be implemented during the next scheduled TS surveillance operational run. On October 20, 2010, when the A EDG was tested, the operators found the jacket water pump seal was leaking approximately 20-30 drops per minute. The inspectors determined that, based on the wetted conditions previously observed, most likely this leakage was present when the engine was last operated. Further, in lieu of the lack of visual checks when the EDG was operated, the leakage could have existed since June 1, 2010, when the first monthly TS surveillance test was conducted on the A EDG following the previous jacket water pump seal replacement on May 6, 2010.
Analysis:
The inspectors determined that the licensees failure to take adequate corrective actions to identify and correct inadequacies in the EDG PM program for monitoring EDG engine driven pump seal leakage in accordance with vendor recommendations was a performance deficiency that was within the licensees ability to foresee and correct. The inspectors determined that the finding is more than minor because if left uncorrected, the issue would become a more significant safety concern, in that, the potential exists for unidentified engine driven pump seal leakage that could lead to EDG failure. This issue is associated with the equipment performance attribute of the Mitigating System cornerstone and adversely affects the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the failure to take adequate corrective actions to identify inadequacies in the EDG PM program for monitoring EDG engine driven pump seal leakage in accordance with vendor recommendations could adversely affect the reliability of the EDGs. This finding was evaluated using Inspection Manual Chapter 0609, Significance Determination Process, Phase 1 Worksheet for mitigating systems. The finding was determined to be of very low safety significance (Green) because it did not actually result in the loss of the EDG system safety function or the loss of function of a single EDG. The cause of this finding was directly related to the problem evaluation cross-cutting aspect in the corrective action program component of the Problem Identification and Resolution area because the licensee did not thoroughly evaluate the February 10, 2010, jacket water pump mechanical seal failure event and identify nonconformance with the vendor recommended visual inspections of engine driven pump seals during EDG operations (P.1(c)).
Enforcement:
10 CFR 50, Appendix B, Criterion XVI, Corrective Action, required in part, that conditions adverse to quality be promptly identified and corrected. Contrary to the above, following the February 10, 2010, A EDG jacket water pump mechanical seal failure, the licensee failed to properly evaluate the incident and did not identify and correct that EDG vendor recommended engine driven pump seal leakage preventive maintenance designed to detect minor leakage from the seal tell tale drains during routine EDG operations, had not been implemented. As a result, the licensee failed to identify subsequent jacket water pump seal leakage following replacement of the seal in May 2010 until the preventive maintenance was properly implemented on October 20, 2010. Because this finding is of very low safety significance and has been entered into the licensees corrective action program as CR-10-03861, this violation is being treated as a NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy and is identified as: NCV 05000395/2010005-01, Failure to Correct Condition Adverse to Quality Involving Inadequate EDG Engine Driven Pump Preventive Maintenance.
2) Annual Operator Work Around Review
a. Inspection Scope
The inspectors reviewed the licensees list of identified operator workarounds, burdens, and challenges associated with mitigating system equipment to determine whether any new items since the previous review conducted in 2009 would adversely affect any mitigating system function or affect the operators ability to implement abnormal or emergency operating procedures. In addition, the inspectors performed an independent review of outstanding control board WOs and known problems with mitigating system equipment to identify any potential workarounds that had not been formally identified and evaluated by the licensee.
b. Findings
No findings were identified.
4OA3 Event Followup
.1 (Closed) LER 05000395/2010003-00: Inadequate Procedural Guidance Results in
Violation of Technical Specification 3.0.4 During Plant Startup The inspectors reviewed the subject LER and condition report (CR-10-03766)associated with the issue to verify the LER accuracy and appropriateness of the specified corrective actions. The issue involved a violation of TS 3.0.4 and 3.7.1.6 due to entering Mode 1 without ensuring the operability of all three feedwater isolation valves (FWIVs). Specifically, the accumulator pressure for one of three FWIVs was determined to be at 471.3 psig when Mode 1 was entered versus the minimum 500 psig for TS operability. The condition lasted only seven minutes at which point, the accumulator pressure had increased above 500 psig. The cause of this event was the failure to provide adequate procedural instructions to ensure the FWIV air accumulator operating pressures were greater than the minimal pressure for operability prior to entering Mode 1 from Mode 2. The licensee conducted subsequent valve stroke time testing via the valve manufacturer and determined that the one FWIV that was at 471.3 psig was still capable of closing within the necessary response time to fulfill its design basis accident function. Therefore, there were no actual safety consequences associated with this event. The licensee planned to revise general operating procedure (GOP)-4A, Power Operation Mode 1 Ascending, to ensure verification that all FWIV actuator pressures are above the minimum pressure for operability prior to allowing entry into Mode 1. The enforcement aspects of this finding are discussed in Section 4OA7. No other findings were identified. This LER is closed.
.2 (Closed) LER 05000395/2009002-01: Automatic Reactor Trip Due to Main Generator
Output Breaker Fault The inspectors reviewed the subject LER and condition report (CR-09-03811)associated with the issue to verify the LER accuracy and appropriateness of the specified corrective actions. The supplement to this LER provided additional details of the licensees investigation into the cause of the breaker fault and associated corrective actions. Due to extent of damage experienced, the root cause could not be determined.
The licensee postulated that a cracked finger carrier assembly (the mating connection to the main contact) allowed loosening of the fingers at the heavy current isolator connection. This looseness resulted in increased contact surface resistance and led to a thermal runaway condition. Due to obsolescence of the main generator breakers and difficulty in procuring replacement parts, the licensee planned to replace all three output breakers during the next refueling outage scheduled in the spring of 2011. No new findings were identified. This LER is closed.
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.
These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors normal plant status review and inspection activities.
b. Findings
No findings were identified.
.2 International Shipment of Spent Fuel
a. Inspection Scope
An inspection was conducted by regional and headquarters inspectors to review the licensees preparations and plans for an export shipment of ten irradiated fuel pins to a research facility in Sweden. The inspectors determined that the shipment was being made on behalf of Westinghouse Electric Companys Nuclear Fuel Division as part of a research effort involving high burnup Pressurized Water Reactor fuel rods with zirconium alloy type cladding. The inspectors determined that the licensee had contracted with Westinghouse for the overall management of the effort and that Westinghouse, in turn, had contracted with NAC International Inc. (NAC) for use of the NAC-LWT shipping cask, including loading and handling operations. Through review of documents, interviews with licensee personnel, and direct observation of work in progress in the fuel handling building, the inspectors determined that:
- Overall directions for the handling of the fuel pins and cask loading operations were contained in the licensee-approved Westinghouse procedure MRS-SSP-2651-CGE-LTA, VC Summer Cask Loading Procedure. The procedure invoked portions of subsidiary NAC operating procedures involving cask handling activities. The inspectors noted that the subsidiary procedures were also reviewed and approved for use by the licensee.
- The latest revision of the Certificate of Compliance for the NAC-LWT cask was in the licensees possession and in use for the activity, as required by 10 CFR Part 71.17.
- As required by NRC regulations, the licensee registered with the U.S. Department of Transportation as a user of the NAC-LWT cask for export purposes. (49 CFR Part 173.472)
- Personnel involved with the activity had received appropriate training. Qualifications of personnel performing non-destructive examination activities, in particular helium leak testing, were verified by Westinghouse and the procedures received review and approval by a qualified Level III examiner.
- Export license XSNM3649 was obtained by Transport Logistics International for the export shipment and the licensee was listed as a party to the export on the license.
Authorization from Sweden to import the irradiated fuel rods was also verified to have been granted.
- Required notifications per 10 CFR Part 110(b)(4)(i) were made to the NRC along with required radioactive material quantities of concern notifications.
- Personnel involved with the loading, shipping, and delivery to a carrier of radioactive material were experienced and had received appropriate training, as required by 49 CFR Part 172.700.
b. Findings
No findings were identified.
.3 (Closed) Temporary Instruction (TI) 2515/172, Rev. 1, Reactor Coolant System
Dissimilar Metal Butt Welds
a. Inspection Scope
The inspectors conducted a review of the licensees activities regarding licensee dissimilar metal butt weld (DMBW) mitigation and inspection implemented in accordance with the industry self imposed mandatory requirements of Materials Reliability Program (MRP)-139, Primary System Piping Butt Weld Inspection and Evaluation Guidelines.
Temporary Instruction (TI) 2515/172, Rev. 1, Reactor Coolant System Dissimilar Metal Butt Welds, was issued May 27, 2010, to support the evaluation of the licensees implementation of MRP-139.
On December 8, 2010, the inspectors performed a review in accordance with TI 2515/172, Rev. 1, as described in the Observation Section below:
b. Observations The licensee has met the MRP-139 deadlines for baseline examinations of all welds scoped into the MRP-139 program. TI 2515/172, Rev. 1, is considered closed. In accordance with requirements of TI 2515/172, Rev. 1, the inspectors evaluated the following areas:
- Implementation of the MRP-139 Baseline Inspections This portion of the TI was not inspected during the period of this inspection report, but was previously covered in NRC Inspection Report 05000395/2008004.
- Weld Overlays This portion of the TI was not inspected during the period of this inspection report, but was previously covered in NRC Inspection Report 05000395/2008003.
- Mechanical Stress Improvement This portion of the TI was not inspected during the period of this inspection report, but was previously covered in NRC Inspection Report 05000395/2008004.
- Application of Weld Cladding and Inlays There were no weld cladding nor inlay activities performed or planned by this licensee to comply with their MRP-139 commitments.
- Inservice Inspection Program This portion of the TI was not inspected during the period of this inspection report, but was previously covered in NRC Inspection Report 05000395/2008004.
c. Findings
No findings were identified.
4OA6 Meetings, Including Exit
.1 Quarterly Resident Inspector Exit Meeting
On January 13, 2011, the resident inspectors presented the integrated inspection results to Mr. Thomas Gatlin and other members of the licensee staff. The licensee acknowledged the results of these inspections. The inspectors confirmed that inspection activities discussed in this report did not contain proprietary material.
.2 International Shipment of Spent Fuel Exit Meeting
On November 8, 2010, an exit meeting was conducted to discuss the results of the inspection. The inspectors confirmed that inspection activities discussed in this report did not contain proprietary material.
4OA7 Licensee-Identified Violations
The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of Section 2.3.2 of the NRC Enforcement Policy, NUREG-1600, for being dispositioned as an NCV.
- TS 3.0.4 requires, in part, that when a Limiting Condition for Operation is not met, entry into a mode or other specified condition shall only be made when the associated actions to be entered permit continued operation in the mode for an unlimited period of time. TS 3.7.1.6 requires that each FWIV be operable in Modes 1-3 and the associated ACTIONS for Mode 1 operation do not allow operation for an unlimited period of time. Contrary to the above, on September 25, 2010, due to inadequate procedural guidance, operators did not ensure that one of the three FWIVs air accumulator pressure was above the minimum for operability when Mode 1 was entered from Mode 2. This condition existed for seven minutes until the minimum pressure for operability was attained in the FWIV air accumulator. The violation was determined to be of very low safety significance because of the short duration that pressure was below the minimum for operability and subsequent FWIV testing determined that the FWIV remained capable of performing its design function at the reduced air accumulator pressure. The licensee planned to revise GOP-4A, Power Operation Mode 1 Ascending, to ensure verification that all FWIV actuator pressures are above the minimum pressure for operability prior to allowing entry into Mode 1. The licensee identified and addressed this issue in their corrective action program as CR-10-03766.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- J. Archie, Senior Vice President, Nuclear Operations
- A. Barbee, Director, Nuclear Training
- L. Bennett, Manager, Plant Support Engineering
- L. Blue, Manager, Nuclear Training
- M. Browne, Manager, Quality Systems
- M. Coleman, Manager, Health Physics and Safety Services
- G. Douglass, Manager, Nuclear Protection Services
- M. Fowlkes, General Manager, Engineering Services
- D. Gatlin, Vice President, Nuclear Operations
- R. Haselden, General Manager, Organizational / Development Effectiveness
- R. Justice, Manager, Nuclear Operations
- G. Lippard, General Manager, Nuclear Plant Operations
- M. Mosley, Manager, Chemistry Services
- D. Shue, Manager, Maintenance Services
- W. Stuart, Manager, Design Engineering
- B. Thompson, Manager, Nuclear Licensing
- R. Williamson, Manager, Emergency Planning
- S. Zarandi, General Manager, Nuclear Support Services
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
- 05000395/2010005-01 NCV Failure to Correct Condition Adverse to Quality Involving Inadequate EDG Engine Driven Pump Preventive Maintenance (Section 4OA2.3.1)
Closed
- 05000395/2010003-00 LER Inadequate Procedural Guidance Results in Violation of Technical Specification 3.0.4 During Plant Startup (Section 4OA3.1)
- 05000395/2009002-01 LER Automatic Reactor Trip Due to a Main Generator Output Breaker Fault (4OA3.2)
- 05000395/2515/172 TI Reactor Coolant System Dissimilar Metal Butt Welds, Rev.
(Section 4OA5.3)