IR 05000395/2021011
| ML21152A035 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 06/01/2021 |
| From: | David Dumbacher Division Reactor Projects II |
| To: | Stoddard D Dominion Energy Co |
| References | |
| IR 2021011 | |
| Download: ML21152A035 (15) | |
Text
June 1, 2021
SUBJECT:
VIRGIL C. SUMMER NUCLEAR STATION - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000395/2021011
Dear Mr. Stoddard:
On May 14, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Virgil C. Summer Nuclear Station and discussed the results of this inspection with Mr. George Lippard, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment.
Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
No findings or violations of more than minor significance were identified during this inspection.
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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
David E. Dumbacher, Chief Reactor Projects Branch 3 Division of Reactor Projects Docket No. 05000395 License No. NPF-12
Enclosure:
As stated
Inspection Report
Docket Number: 05000395 License Number: NPF-12 Report Number: 05000395/2021011 Enterprise Identifier: I-2021-011-0021 Licensee: Dominion Energy Facility: Virgil C. Summer Nuclear Station Location: Jenkinsville, SC Inspection Dates: April 26, 2021 to May 14, 2021 Inspectors: E. Hilton, Resident Inspector K. Kolaczyk, Reactor Operations Engineer D. Merzke, Technical Support Team Leader A. Wilson, Project Engineer Approved By: David E. Dumbacher, Chief Reactor Projects Branch 3 Division of Reactor Projects Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution 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.
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
None.
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 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.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)
- (1) The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment.
- Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems.
- Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits, and self-assessments.
- Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Assessment 71152B Corrective Action Program Assessment: Based on the samples reviewed, the team determined that the licensees corrective action program (CAP) complied with regulatory requirements and self-imposed standards. The licensees implementation of the CAP adequately supported nuclear safety.
Effectiveness of Problem Identification: The inspectors determined that the licensee was generally effective in identifying problems and entering them into the CAP at the appropriate threshold. This conclusion was based on a review of the requirements for initiating condition reports (CRs) as described in licensee procedure SAP-0999, Corrective Action Program,"
and the site's management expectation that employees were encouraged to initiate condition reports. Additionally, site management was actively involved in the corrective action program and focused appropriate attention on significant plant issues. The inspectors reviewed CRs and system health trending for the residual heat removal system, reactor protection system, emergency diesel generators, and emergency feedwater system. The inspectors performed walkdowns of accessible portions of the selected systems. Based on the inspectors' reviews and walkdowns, the inspectors determined that deficiencies were being identified and placed in the CAP.
Effectiveness of Problem Prioritization and Evaluation: Based on the review of CRs sampled by the inspection team during the onsite period, the inspectors concluded that problems were generally prioritized and evaluated in accordance with the CR significance determination guidance in CAP procedures. The inspectors determined that adequate consideration was given to system or component operability and associated plant risk. The inspectors determined that plant personnel had generally conducted cause evaluations in compliance with the licensees CAP procedures, including appropriate cause determinations, and performed adequate levels of analysis based on the significance of the issues being evaluated.
Effectiveness of Corrective Actions: Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the inspectors determined that corrective actions were effective, timely, and commensurate with the safety significance of the issues. For significant conditions adverse to quality, the corrective actions directly addressed the cause and effectively prevented recurrence. The inspectors reviewed performance indicators, CRs, and effectiveness reviews, as applicable, to verify that the significant conditions adverse to quality had not recurred. Effectiveness reviews for corrective actions to preclude repetition (CAPRs) were sufficient to ensure corrective actions were properly implemented and were effective.
Operating Experience: The inspectors determined that the station's processes for the use of industry and NRC operating experience information and for the performance of audits and self-assessments were effective and complied with all regulatory requirements and licensee standards. The implementation of these programs adequately supported nuclear safety. The inspectors concluded that operating experience was adequately evaluated for applicability and that appropriate actions were implemented to address lessons learned as needed.
Self-Assessments and Audits: The inspectors determined that the licensee was effective at performing self-assessments and audits to identify issues at a low level, properly evaluated those issues, and resolved them commensurate with their safety significance. Self-assessments were generally detailed and critical. The inspectors verified that CRs were created to document areas for improvement and findings resulting from self-assessments and verified that actions had been completed consistent with those recommendations. Audits of the quality assurance program appropriately assessed performance and identified areas for improvement. Generally, the licensee performed evaluations that were technically accurate.
Safety Conscious Work Environment: Based on a sample of at least 20 individuals interviewed from a cross-section of plant employees, the inspectors found no evidence of challenges to the safety conscious work environment. Employees interviewed appeared knowledgeable of avenues to raise safety concerns and appeared willing to raise nuclear safety concerns through at least one of the several means available.
Minor Violation 71152B Minor Violation: During the inspectors review of the Structures Monitoring Program, specifically the documentation of roof walkdown reports as required by CMP-700-005, "Roof Inspection," the inspectors identified examples of reports that listed rejectable items, but did not list the way the rejectable items were to be repaired and did not list the work order generated. The inspectors determined this to be a violation of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," which requires that activities affecting quality shall be prescribed by and accomplished in accordance with documented instructions, procedures, or drawings. Specifically, Step 7.1.5 of CMP-700.005, Rev. 5, requires the site to: Initiate the required actions for the repair of all rejectable items in accordance with SAP-300 and record work order number on Attachment I. Contrary to the above, a repair document was not generated and work order numbers were not listed on Attachment I for items listed as rejectable for the Control Building, Intermediate Building, Auxiliary Building, Fuel Handling Building, Turbine Building, Service Building, and Service Water Building roofs in the September 2020 roof walkdown report.
Screening: The inspectors determined the performance deficiency was minor. This performance deficiency was screened in accordance with Inspection Manual Chapter (IMC)0612 Appendix B, "Additional Screening Guidance," dated December 10, 2020, and was determined to be of minor significance because the failure to generate repairs for rejectable items associated with the September 2020 roof walkdown report could not be reasonably viewed as a precursor to a significant event, would not have the potential to lead to a more significant safety concern if left uncorrected, and did not adversely affect a cornerstone objective. No immediate concerns to roof integrity were identified in the list of rejectable items.
Enforcement:
This failure to comply with 10 CFR 50, Appendix B, Criterion V, 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 May 14, 2021, the inspectors presented the biennial problem identification and resolution inspection results to Mr. George Lippard, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71152B Calculations DC 03490-003 Intermediate and Diesel Generator Buildings Flooding Rev. 2
Evaluation
DC 05220-091 Emergency Feedwater Hydraulic Analysis Rev. 3
Corrective Action CR-13-03950,
Documents CR-15-05594,
CR-16-05696,
CR-17-02130,
CR-17-02573,
CR-17-06131,
CR-17-06450,
CR-19-00015,
CR-19-00015,
CR-19-00207,
CR-19-00821,
CR-19-00885,
CR-19-00927,
CR-19-00929,
CR-19-01023,
CR-19-01031,
CR-19-01035,
CR-19-01035,
CR-19-01042,
CR-19-01083,
CR-19-01136,
CR-19-01219,
CR-19-01328,
CR-19-01368,
CR-19-01396,
CR-19-01412,
CR-19-01436,
CR-19-01439,
CR-19-01629,
Inspection Type Designation Description or Title Revision or
Procedure Date
CR-19-01631,
CR-19-01676,
CR-19-01690,
CR-19-01693,
CR-19-01771,
CR-19-01817,
CR-19-01822,
CR-19-01829,
CR-19-01838,
CR-19-01840,
CR-19-01899,
CR-19-01907,
CR-19-01910,
CR-19-01929,
CR-19-01951,
CR-19-01967,
CR-19-02195,
CR-19-02366,
CR-19-02443,
CR-19-02445,
CR-19-02521,
CR-19-02766,
CR-19-02846,
CR-19-02865,
CR-19-02907,
CR-19-03026,
CR-19-03166,
CR-19-03417,
CR-19-03437,
CR-19-03444,
CR-19-03444,
CR-19-03481,
CR-19-03528,
CR-19-03732,
Inspection Type Designation Description or Title Revision or
Procedure Date
CR-19-03760,
CR-19-03849,
CR-19-03882,
CR-19-03892,
CR-19-03945,
CR-19-03977,
CR-19-03979,
CR-19-04154,
CR-19-04191,
CR-19-04201,
CR-19-04222,
CR-19-04309,
CR-19-04321,
CR-19-04499,
CR-19-04528,
CR-19-04529,
CR-19-04530,
CR-20-00075,
CR-20-00075,
CR-20-00118,
CR-20-00265,
CR-20-00380,
CR-20-00470,
CR-20-00679,
CR-20-00764,
CR-20-00802,
CR-20-00830,
CR-20-01120,
CR-20-01146,
CR-20-01146,
CR-20-01152,
CR-20-01187,
CR-20-01190,
CR-20-01266,
Inspection Type Designation Description or Title Revision or
Procedure Date
CR-20-01268,
CR-20-01284,
CR-20-01317,
CR-20-01443,
CR-20-01494,
CR-20-01495,
CR-20-01559,
CR-20-01562,
CR-20-01583,
CR-20-01603,
CR-20-01621,
CR-20-01623,
CR-20-01658,
CR-20-01681,
CR-20-01734,
CR-20-01757,
CR-20-02016,
CR-20-02210,
CR-20-02283,
CR-20-02444,
CR-20-02513,
CR-20-02531,
CR-20-02626,
CR-20-02673,
CR-20-02714,
CR-20-02733,
CR-20-02827,
CR-20-03023,
CR-20-03027,
CR-20-03062,
CR-20-03108,
CR-20-03238,
CR-20-03251,
CR-20-03347,
Inspection Type Designation Description or Title Revision or
Procedure Date
CR-20-03498,
CR-20-03622,
CR-20-03647,
CR-20-03803,
CR-20-03935,
CR-20-04004,
CR-20-04191,
CR-21-00010,
CR-21-00137,
CR-21-00162,
CR-21-00190,
CR-21-00229,
CR-21-00285,
CR-21-00500,
CR-21-00750,
CR-21-00778,
CR-21-01214,
CR-21-01286
Drawings D-302-085
Engineering ECR 50695E EFW Flow Margin Improvement
Changes ECR 50938 RBCU Condensate Leak Detection Switches
Miscellaneous VCS Excellence Plan - Nuclear Operations 03/08/2021
DBD-RP Reactor Protection System (RPS) Engineered Safety Features Rev. 4
Loading Sequencer (ESFLS)
EIR 82390
VC-20-00006 EF Check Valve Replacement
Procedures Maintenance Support For Refueling Rev. 21,
Change B
Maintenance Support For Refueling Rev. 21,
Change A
CM-AA-PGM- Program Health Report Rev. 9
1001
Inspection Type Designation Description or Title Revision or
Procedure Date
CMP-700.005 Roof Inspection Rev. 5
EC-AA-110 Identifying and Addressing Nuclear Safety and Quality Rev. 1
Concerns
ER-AA-101 System Engineering Walkdowns Rev. 4
ES-0437 Inspections For Maintenance Rule - Structures Rev. 3
LI-AA-1002 Safety Culture Review Rev. 7
OAP-100.6 Control Room Conduct and Control of Shift Activities Rev. 6
PSEG-46 Service Water Piping Degradation Guidance Rev. 0
RP-AA-5001 RP Department Survey and Surveillance Verification Rev. 1
SAG-01 Self-Assessment Guidelines Rev. 4
SAP-0999 Corrective Action Program Rev. 19
SAP-0999B CR Review Team (CRRT) Rev. 1
SAP-0999C Management Review Team (MRT) Rev. 1
SAP-1350 Self-Assessment and Benchmarking Rev. 11
SAP-1356 Cause Determination Guidelines CDG-01 Rev. 20
SOP-211 Emergency Feedwater System Rev. 14
STP-130.003C Pressurizer PORV Operability Testing Rev. 2
TR00010-010 Maintenance Rule Inspections - 2020 Assessment Of In- Rev. 0
Service Conditions Of Important To Maintenance Rule (ITMR)
Structures
Self-Assessments 2019 QC Inspection Program
20 Chemistry Human Performance and Fundamentals
20 Operations Training Accreditation Visit Follow Up Self-
Assessment
20 Pre-PI&R Self-Assessment
21 Mid-Cycle and Nuclear Safety Culture Report
QA-AUD-201912; Corrective Action Program
QA-AUD-202006; Station Radiation Protection
QA-AUD-202007; Design Control & Engineering Programs
QA-AUD-202010; Station Operations
QA-AUD-202012; Station Maintenance
Inspection Type Designation Description or Title Revision or
Procedure Date
2019 Mid-Cycle and Nuclear Safety Culture Report
Work Orders 1917892
2005542
2006371
2012459
2100006
2