IR 05000395/2019002
| ML19225D219 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 08/12/2019 |
| From: | Randy Musser Division Reactor Projects II |
| To: | Stoddard D Dominion Energy Co |
| Reeder D | |
| References | |
| IR 2019002 | |
| Download: ML19225D219 (16) | |
Text
August 12, 2019
SUBJECT:
VIRGIL C. SUMMER NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT 05000395/2019002
Dear Mr. Stoddard:
On June 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Virgil C. Summer Nuclear Station. On July 29, 2019, the NRC inspectors discussed the results of this inspection with Mr. George Lippard and other members of your staff. The results of this inspection are documented in the enclosed report.
No NRC-identified or self-revealing findings were identified during this inspection.
The inspectors documented a licensee-identified violation which was determined to be of very low safety significance in this report. The NRC is treating this violation as non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.
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/
Randall A. Musser, Chief Reactor Projects Branch 3 Division of Reactor Projects
Docket No. 05000395 License No. NPF-12
Enclosure:
Inspection Report 05000395/2019002
cc w/ encl: Distribution via LISTSERV
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Virgil C. Summer Nuclear Station 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. Licensee-identified non-cited violations are documented in report sections: 71111.1
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000395/2019-001-
LER 2019-001-00 for Virgil C.
Summer, Unit 1, Condition Prohibited by Technical Specification 3.4.6.1.
71153 Closed
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 a tornado watch issued for Fairfield County on April 19, 2019.
Seasonal Extreme Weather Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of hot weather for the following systems: walkdown of emergency diesel generators (EDGs) and service water pumphouse (SWPH) on June 26, 2019.
Summer Readiness Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated summer readiness of offsite and alternate alternating current (AC) power systems on May 31, 2019.
71111.04 - 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)
'A' reactor building (RB) spray pump during scheduled maintenance on 'B' RB spray components on April 17, 2019 (2)
'A' emergency diesel generator (EDG) during major maintenance on 'B' EDG on April 10, 2019 (3)
'B' EDG during major maintenance on 'A' EDG on May 23, 2019 (4)
'B' residual heat removal (RHR) during maintenance on 'A' RHR on June 18, 2019
71111.04S - Equipment Alignment
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the intermediate building (IB) 412' elevation of 'B' train component cooling water (CCW) system on June 24, 2019.
71111.05Q - Fire Protection
Quarterly Inspection (IP Section 03.01) (5 Samples)
The inspectors evaluated fire protection program implementation in the following selected areas:
- (1) Relay room solid state protection system (SSPS) instrumentation and inverter (fire zones CB06, CB10, CB12) on April 10, 2019
- (2) Auxiliary building switchgear room 463' elevation (fire zone AB01.29) on April 17, 2019
- (3) Auxiliary building 374' elevation (fire zones AB01.01.01, 01.01.02, AB01.02, AB01.03) on April 17, 2019
- (4) Battery / charger rooms 'A' and 'B' and cable room (fire zones IB02, 03, 04, 05, 06 and IB27) on June 26, 2019
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 02.02a.) (1 Sample)
The inspectors evaluated internal flooding mitigation protections in the:
- (1) Service water (SW) pumphouse (SW pumps and associated mechanical and electrical components) on June 26, 2019
Inspection Activities - Underground Cables (IP Section 02.02c.) (1 Sample)
The inspectors evaluated cable submergence protection in:
- (1) Safety-related electrical manholes (EMH)-1 and EMH-2; inspection completed on June 17, 2019
71111.07A - Heat Sink Performance
Annual Review (IP Section 02.01) (1 Sample)
The inspectors evaluated readiness and performance of:
- (1) WO 1904815, service water (SW) heat exchanger performance testing following replacement of 'A' EDG heat exchanger tube bundles on June 3, 2019
71111.07T - Heat Sink Performance Triennial Review (IP Section 02.02)
The inspectors evaluated heat exchanger/sink performance on the following from June 24, 2018 to June 28, 2018:
- (1) Component Cooling Water Heat Exchanger A (XHE0002A), Section 02.02b
- (2) Emergency Diesel Generator A Intercooler (XHE0017A-HE3), 02.02b
- (3) Emergency Diesel Generator Lube Oil Coolers (XHE0017A-HE1, XHE0017B-HE1),02.02b
- (4) Service Water Pond, Section 02.02.d. Specifically Sections 02.02.d.1, 02.02.d.6, and 02.02d.7 were completed.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (4 Samples)
- (1) The inspectors observed and evaluated licensed operator performance in the Control Room during reactor coolant system (RCS) dilutions for maintaining temperature; replacement of card for vibration monitoring on 'A' main feedwater pump on June 3, 2019.
- (2) The inspectors observed and evaluated licensed operator performance in the Control Room during nuclear instrumentation calibration on June 21, 2019.
- (3) The inspectors observed and evaluated licensed operator performance in the Control Room during 'A' train safety-related chiller troubleshooting and alarm response on June 26, 2019.
- (4) The inspectors observed and evaluated licensed operator performance in the Control Room during 'A' train solid state protection system (SSPS) testing on June 28, 2019.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated inspection of the simulator requalification examination on May 20, 2019.
71111.12 - Maintenance Effectiveness
Routine Maintenance Effectiveness Inspection (IP Section 02.01) (2 Samples)
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
(1)
'A' service water (SW) pump seismic restraints were found out of tolerance on April 15, 2019
- (2) A maintenance rule (a)(1) evaluation for reactor coolant system (RCS) leak detection function due to reactor building cooling unit (RBCU) drain flow switch failures on June 17, 2019
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
- (1) Yellow risk for 'B' train SSPS surveillance test on May 10, 2019
- (2) Emergent work associated with replacing the master pressurizer controller on June 14, 2019
- (3) Emergent work associated with calibrating nuclear instrumentation (NIs) on June 21, 2019
- (5) Yellow risk condition for 'A' train SSPS surveillance test on June 28, 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) CR-19-00207, Gas found in 'B' train residual heat removal (RHR) on April 1, 2019
- (2) CR-19-01330, 'B' SW pipe tee with pinhole leak on April 18, 2019
- (3) CR-19-00393, Non-conforming condition for 'A' train SW pump due to seismic restraints out of tolerance on April 8, 2019
- (4) CR-19-01499, 'A' EDG air start tanks minimum wall and debris on May 6, 2019
- (5) CR-19-01874, Accept as is disposition for 'A' EDG low lube oil pressure and jacket water pressure switch support bracket non-conformance on May 29, 2019
71111.18 - Plant Modifications
Severe Accident Management Guidelines (SAMG) Update (IP Section 03.03) (1 Sample)
- (1) Review of new Severe Accident Management Guidelines (SAMGs); inspection completed on April 30, 2019
71111.19 - Post-Maintenance Testing
Post Maintenance Test Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the following post maintenance tests:
- (3) EB-04 7.2 kV breaker operational check WO1809270, on May 15, 2019
- (6) Replace master pressurizer controller WO1906239, on June 14, 2019
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Inservice Testing (IP Section 03.01)
- (1) STP-121.002A, "Steam Generator PORV Operability Test," Revision 0D, WO1904919 on May 8, 2019
- (2) STP-220.002, "Turbine Driven Emergency Feedwater Pump and Valve Test,"
Revision 9B, WO1907077 on June 25, 2019
- (3) STP-223.002A, "Service Water Pump Test," Revision 10C, for 'A' train, WO1904489 on June 8, 2019
- (4) STP-205.003, "Charging/Safety Injection Pump and Valve Test," Revision 8B, for 'C' pump, WO1904481 on June 8, 2019
Surveillance Tests (other) (IP Section 03.01) (2 Samples)
- (1) STP-124.004, "Control Room Emergency Unfiltered Air Inleakage Testing," Revision 0D, WO1807357 on May 17, 2019
- (2) STP-111.001, "Seismic Instrumentation Channel Check," Revision 7D, WO1904413 on June 11, 2019
71114.06 - Drill Evaluation
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
The inspectors evaluated:
- (1) On June 4, 2019, the inspectors reviewed and observed the performance of a simulator drill that involved multiple equipment failures which required a Notice of Unusual Event (NOUE), Alert, Site Area Emergency (SAE) and General Emergency to be declared. The inspectors assessed emergency procedure usage, emergency plan classification, notifications, and the licensee's identification and entrance of any problems into their corrective action program. This inspection evaluated the adequacy of the licensee's conduct of the drill and critique performance. Drill issues were captured by the licensee in CR-19-02038.
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10)===
- (1) Unit 1 for the period from April 1, 2018, through March 31, 2019.
BI02: RCS Leak Rate Sample (IP Section 02.11) (1 Sample)
The inspectors verified licensee performance indicators submittals listed below:
- (1) Unit 1 for the period from April 1, 2018, through March 31, 2019.
71152 - Problem Identification and Resolution
Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) CR-18-02706, SW pinhole leak in pipe tee downstream of XVB03123B on May 6, 2019
Semiannual Trend Review (IP Section 02.02) (1 Sample)
- (1) The inspectors reviewed the licensees corrective action program for potential adverse trends related to the EDG air start system and noted the licensee initiated CR-17-03653 in response to a negative trend associated with EDG air start system debris issues. The inspectors reviewed CR-17-03653 and the associated common cause evaluation. The inspectors noted in the common cause evaluation identified debris intrusion, which resulted from corrosion in the air start supply lines and tanks.
The inspectors reviewed the licensees current plans to address the EDG air start system issues which includes bridging strategies and aging management documentation.
71153 - Followup of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)
The inspectors evaluated the following licensee event reports (LER): 05000395/2019-001-00, Virgil C. Summer, Unit 1, Condition Prohibited by Technical Specification 3.4.6.1.
ADAMS accession ML19105B284
- (1) From September 16, 2017, to October 6, 2018, the licensee operated in Modes 1 through 4 without an operable reactor building cooling unit (RBCU) condensate flow switch necessary to meet the requirements of TS 3.4.6.1. The inspectors noted that the licensee had determined that debris had rendered both channels, IFS01900A &
B, inoperable, and, consequently, issued a Green, non-cited violation coupled with a Severity Level IV traditional enforcement non-cited violation in NRC Inspection Report
===05000395/2019001. The inspectors review of the LER identified incomplete information relating to the dates in which TS required action requirements were not met. The licensee initiated CR-18-048666 and CR-19-02144 for corrective actions and plan to issue a supplemental LER to correct the discrepancy.
This LER is closed.
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; inspection was completed on April 12,
INSPECTION RESULTS
Licensee-Identified Non-Cited Violation 71111.15 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Violation: TS 6.8.1a states in part that written procedures shall be established covering the activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2, Section 3, Procedures for Startup, Operation, and Shutdown of Safety-Related PWR Systems. Contrary to the above, on January 17, 2019, the licensee failed to adequately establish procedures to ensure gas in B train RHR piping had been removed following the Fall, 2018 refueling outage.
Significance/Severity: Green. The finding was more than minor because it adversely impacted the mitigating systems cornerstone and the respective attribute of equipment reliability. Specifically, the amount of gas that had accumulated was greater than the licensees analyzed limit in SAP-0162, Gas Intrusion Management Program, Revision 0; however, a vendor analysis determined the volume of gas did not exceed a qualitative limit. The finding was evaluated in accordance with IMC 0609, Appendix A, Exhibit 2, and screened as Green, or very low safety significance because it was not a design deficiency and did not result in a loss of function.
Corrective Action References: The licensee has documented this problem in their CAP as CR-19-00207.
Minor Violation 71152 Minor Violation: 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, for failure to promptly identify and correct a condition adverse to quality (CAQ). Specifically, during the Fall, 2018, refueling outage the licensee did not identify a CAQ related to cavitation damage on the downstream pipe tee for the component cooling water heat exchanger service water (SW) discharge butterfly valve, XVB03123B-SW, which was normally throttled for flow control. Specifically, the licensee had performed extent of condition ultrasonic testing including video surveillance for cavitation damage resulting in pinhole leaks from the previous operating cycle in order to perform repairs but failed to identify an area of cavitation damage.
During the inspection, the inspectors reviewed in detail the licensees evaluations, inspections and corrective actions associated with cavitation damage on both A and B SW piping tees downstream of throttled butterfly valves. The inspectors also reviewed CR-18-02706: pinhole leak below field weld (FW-1), downstream of XVB03123B. Reference CR-18-02364 for previous pinhole leak from FW-1 as part of the annual inspection sample. Additional related information documented in NRC integrated inspection reports 05000395/2018001 and 05000395/2018004.
The inspectors noted that the licensee determined the cause as cavitation, and the inspectors also noted the licensee initiated CR-19-01436 to document their failure to identify the existing cavitation damage during inspections conducted in the previous refueling outage when existing damage was identified and remediated.
As a result of these failures to identify a condition adverse to quality related to cavitation damage, the piping tee sustained another pinhole leak during the current operating cycle on April 9, 2019, requiring the licensee to seek NRC approval for a relief request.
The inspectors concluded that the licensees failure to promptly identify and correct a CAQ for ongoing cavitation damage of the piping tee downstream of XVB03123B-SW was a minor violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action.
Screening: The inspectors determined the performance deficiency was minor. Because the component was evaluated as operable but degraded, the inspectors identified this as a minor violation of Criterion XVI.
Enforcement:
This failure to comply with 10 CFR 50, Appendix B, Criterion XVI constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On July 29, 2019, the inspectors presented the integrated inspection results to Mr.
George Lippard III and other members of the licensee staff.
- On June 27, 2019, the inspectors presented the Exit Meeting for Triennial Heat Sink Inspection to Kirk Weir, Plant Support Engineering Manager and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
Transmission Agreement
11/1978
Procedures
Response to Electrical Grid Issues
EE-01
Design Interface With Transmission Planning, Power
Delivery, and Relay Applications
0F
OAP-100.4
Communication
OAP-102.1
Conduct of Operations Scheduling Unit
8E
Control of Switchyard-Transformer Yard Activities
SOP-301
Main Generator System
16B
SOP-304
115KV/7.2KV Operations
14A
STP-125.021
Periodic Testing of the Alternate AC Power Supply
Drawings
2-351
Diesel Generator Fuel Oil
2-353
Diesel Generator Miscellaneous Services
2-661
Reactor Building Spray System
Procedures
SOP-116
Reactor Building Spray System
16F
SOP-306
19F
71111.04S Miscellaneous
List of Component Cooling Water System Work Orders
List of Component Cooling Water System Condition Reports
PI&R Briefing Sheet for Engineering/NRC CCW system
walkdown
CCW System Parameter Trend Report
Procedures
STP-728.037
Auxiliary building Fire Barrier Inspection Elevations 502'6",
485', 475', 474' and 463'
4I
STP-728.040
Auxiliary Building Fire Barrier Inspection Elevations 400',
397', 388', and 374'
4C
STP-728.044
Control Building Elevation 436' Fire Barrier Inspection
7J
STP-728.050
Intermediate Building Elevation 412' Fire Barrier Inspection
4G
71111.07A Work Orders
1904824-001
EDG Intercooler Heat Exchanger Performance Data
Collection
05/23/19
71111.07T Calculations
DC04310-045
CCWHX Design Basis Limiting Conditions (GL 89-13)
Revision 0
DC05600-098
Evaluation of Acceptance Criteria Based on Waterhammer
Revision 2
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Phenomena in CCW, EFW, and SW Piping in for VC
Summer
DC06610-99
DG Heat Exchangers Model
Revision 1
Corrective Action
Documents
CR 16-02818
Results of Self-Assessment SA16-PE-03S - Ultimate Heat
Sink/89-13.
06/03/2016
CR 19-01872
Diesel Generator "A" Intercooler Tube Bundle damaged
during installation
05/21/2019
CR-16-03923
CCWHX A Heat Transfer below Admin Limit
08/02/2016
CR-19-00292
SWS Chem. Injection
01/24/2019
Miscellaneous
Virgil C. Summer Nuclear Station Design Basis Document:
Service Water System
Revision 15
NDE Reports
SCA2-VCS-01
Eddy Current Inspection Report for EDG-B Lube Oil Cooler
06/13/16
Procedures
Service Water System Corrosion Monitoring and Control
Program
Revision 6
Service Water System Heat Exchanger Performance
Revision 13
MMP-150.006
Diving Support for Service Water System Equipment
Revision 1
PTP-213.002
Service Water System Heat Exchanger Data Collection
Revision 5
Service Water System Reliability Optimization Program
Revision 2
Heat Exchanger Program
Revision 2
Underground Piping and Tank Integrity Program
Revision 1
Work Orders
CCWHX A ES-505 Att.02
04/30/2017
Service Water Intake Structure and Pump Bay A, B, and C
Inspection and Cleaning
05/13/2017
WO 1613631-001
Eddy Current Inspection of Emergency Diesel Generator A
Heat Exchangers
03/01/2017
WO 1802272-001
Service Water Heat Exchanger Performance for Emergency
Diesel Generator B Intercooler
05/10/2018
WO 1807155-001
Service Water HX Exchanger Performance Collect Data on
XHE0002A
2/22/2019
Service Water 'A' Pump and Valve Test
10/16/2018
WO 1904824-001
Service Water Heat Exchanger Performance for Emergency
Diesel Generator A Intercooler
05/23/2019
WO 1905988-001
Service Water HX Performance Collect Data on XHE0002A
06/12/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Calculations
DC04410-030
Parametric Evaluation of Void Volumes to Address Generic Letter 2008-01
and 4
DC05600-084
Potential Gas Accumulation Locations in SI, RH and SP
Piping
0, 1, and 2
DC05600-085
Review of Water Hammer Forces on SI, RH, and SP pump
Discharge Piping Due to Gas Voids
DC05600-086
Review of Water Hammer Forces on SI, RH and SP Pump
Section Piping Due to Gas Voids
DC05600-087
Disposition of Possible Gas Void Locations to Mitigate
Effects of Gas Intrusion in the SI, RH, and SP Systems
0, 1, 2 and 3
Corrective Action
Documents
CR-08-00162
Review NRC GL 2008-01 for applicability to the site
01/15/2008
CR-09-01592
Review Industry Document 2-05 for applicability to the site
04/21/2009
CR-14-03500
During venting of RHR gas was detected at two points in the
system
06/22/2014
CR-14-03584
During follow-up venting of RHR additional gas was detected
at two points
06/26/2014
CR-14-03624
During follow-up venting of RHR additional gas was detected
at one point in the system
06/29/2014
Operability
Evaluations
ES-120 for CR-
19-00207
Operability evaluation for gas found in the RHR system
documented in CR-19-00207
03/12/2019
Corrective Action
Documents
CR-08-01218
'B' EDG main air start valve leak
3/30/2008
CR-09-02852
'B' EDG main air start valve leak
7/22/2009
CR-10-01262
'B' EDG main air start valve leak
03/24/2010
CR-10-02113
'B' EDG main air start valve leak
05/25/2010
CR-12-04237
'B' EDG main air start system solenoid valve leak
10/03/2012
CR-14-01338
'B' EDG main air start system solenoid valve leak
03/22/2014
CR-14-02111
'B' EDG main air start system solenoid valve leak
04/20/2014
CR-16-03934
'B' EDG main air start valve leak
08/03/2016
CR-16-04931
'B' EDG main air start valve leak
09/27/2016
CR-16-05907
'B' EDG main air start valve leak
11/23/2016
CR-16-05948
'B' EDG main air start system solenoid valve leak
11/27/2016
CR-17-03299
'B' EDG main air start valve leak
06/07/2017
CR-17-03653
Tread identified on 'B' EDG main air start system
06/28/2017
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
Corrective Action Program
18A