IR 05000395/2022004
| ML23040A386 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 02/10/2023 |
| From: | David Dumbacher NRC/RGN-II/DRP/RPB3 |
| To: | Stoddard D Dominion Energy Co |
| References | |
| IR 2022004 | |
| Download: ML23040A386 (13) | |
Text
February 10, 2023
SUBJECT:
VIRGIL C. SUMMER - INTEGRATED INSPECTION REPORT 05000395/2022004
Dear Daniel G. Stoddard:
On December 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Virgil C. Summer. On January 26, 2023, the NRC inspectors discussed the results of this inspection with Mr. Robert Justice and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at Virgil C. Summer.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC Resident Inspector at Virgil C. Summer. 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, 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:
Report Number:
Enterprise Identifier:
I-2022-004-0024
Licensee:
Dominion Energy
Facility:
Virgil C. Summer
Location:
Jenkinsville, SC
Inspection Dates:
October 01, 2022 to December 31, 2022
Inspectors:
D. Bacon, Senior Operations Engineer
N. Childs, Senior Project Engineer
S. Janicki, Resident Inspector
M. Read, Sr. Resident Inspector
Approved By:
David E. Dumbacher, Chief
Reactor Projects Branch 3
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees
performance by conducting an integrated inspection at Virgil C. Summer, in accordance with the
Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for
overseeing the safe operation of commercial nuclear power reactors. Refer to
https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to establish adequate procedural controls to prevent scaffolding from adversely
affecting the performance of safety-related equipment
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
Open/Closed
[H.12] - Avoid
Complacency
An NRC-identified Green NCV of 10 CFR Part 50, Appendix B, Criterion V, Instructions,
Procedures, and Drawings, was identified for the licensees failure to establish adequate
procedural controls to ensure that scaffolding erected near safety-related equipment would
not adversely affect the performance of that equipment during a design-basis seismic event.
Specifically, NRC inspectors identified that the scaffold program implementing procedure
CMP-100.009, Scaffold Request, Evaluation, and Erection, did not include the spacing
requirements as detailed and evaluated in the scaffold program basis documents.
Additional Tracking Items
Type
Issue Number
Title
Report Section
Status
LER 2022-002-00 for Virgil
C. Summer Nuclear Station
(VCSNS), Unit 1, Potential
Condition Prohibited by
Technical Specification 3.8.1.1
Closed
PLANT STATUS
The unit began the inspection period at rated thermal power (RTP). On September 16, 2022,
the unit was down powered to 91 percent to perform turbine valve stroke testing and returned to
RTP. The unit remained at or near RTP for the remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in
effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with
their attached revision histories are located on the public website at http://www.nrc.gov/reading-
rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared
complete when the IP requirements most appropriate to the inspection activity were met,
consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection
Program - Operations Phase. The inspectors performed activities described in IMC 2515,
Appendix DProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 2515,</br></br>Appendix D" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., Plant Status, observed risk-significant activities, and completed on-site portions of
IPs. 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
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
(1)
The inspectors evaluated readiness for seasonal extreme weather conditions prior to
the onset of freezing weather for the following systems:
Condensate storage tank
Refueling water storage tank
Chilled water system
Circulating water pumps
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1)
1DA1 and 1DA2 emergency buses prior to work on a breaker on bus 1DB1, on
October 12, 2022
(2)
Intermediate building ventilation, on October 17, 2022
(3)
Alternate seal injection pump and controller, on December 4, 2022
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
(1)
Auxiliary feedwater system, on September 9 and October 3, 2022
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a
walkdown and performing a review to verify program compliance, equipment functionality,
material condition, and operational readiness of the following fire areas:
(1)
Auxiliary building elevation 436 feet, on August 10, 2022
(2)
Control building elevation 425 feet, on October 21, 2022
(3)
Control building elevation 448 feet, on October 21, 2022
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance
Requalification Examination Results (IP Section 03.03) (1 Sample)
(1)
During the week of November 07, 2022, the inspector reviewed and evaluated the
licensed operator examination failure rates for the requalification annual operating
exam completed on August 25, 2022. The licensee completed the annual
requalification operating examinations required to be administered to all licensed
operators in accordance with Title 10 of the Code of Federal Regulations 55.59(a)(2),
"Requalification Requirements," of the NRC's "Operator's Licenses." The inspector
performed an in-office review of the overall pass/fail results of the individual operating
examinations and the crew simulator operating examinations in accordance with IP 71111.11, "Licensed Operator Requalification Program." These results were
compared to the thresholds established in Section 3.03, "Requalification Examination
Results," of IP 71111.11.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1
Sample)
(1)
The inspectors observed and evaluated licensed operator performance in the control
room during STP-125.008, "Diesel Generator 'A' 24 Hour Load Test," on November 1
and 2, 2022.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
(1)
The inspectors observed an operator requalification exercise involving a failure of the
reactor to trip, loss of high head safety injection, and rod ejection accident on
December 12, 2022.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following
structures, systems, and components (SSCs) remain capable of performing their intended
function:
(1)
Fire protection program during an extended diesel-driven fire pump outage to replace
the pump motor controller, on November 21, 2022
(2)
Aging management programs and inspections to identify excessive corrosion under
insulation on outdoor carbon-steel piping, review completed on December 15, 2022
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the
following planned and emergent work activities to ensure configuration changes and
appropriate work controls were addressed:
(1)
Elevated risk during scaffold construction around main steam intercept valves, on
September 8, 2022
(2)
Elevated risk during switchyard entry for isophase bus duct work repair job planning,
on October 14, 2022
(3)
Elevated risk during ventilation maintenance activities in the 'A' battery room, on
November 7, 2022
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the
following operability determinations and functionality assessments:
(1)
Condition report (CR) 1206649 'C' charging pump gearbox breather appears to be
installed at an angle, completed review on October 7, 2022
(2)
CR 1210515 installation of grounding wires for ventilation exhaust fan motor,
completed review on October 19, 2022
(3)
CR 1211780 emergency diesel generator 'A' fuel oil header leak, on November 3,
2022
(4)
CR 1205685 main transformer oil temperature below minimum, on December 10,
2022
(5)
CR1212961 steam generator inner nozzle inservice inspection on December 13,
2022
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1
Sample)
The inspectors evaluated the following temporary or permanent modifications:
(1)
VC-22-00030, diesel-driven fire service pump controller replacement, review
completed on November 19, 2022
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the following post-maintenance testing activities to verify system
operability and/or functionality:
(1)
Core flux mapping following replacement of the 'A' incore detector, on October 11,
2022
(2)
Diesel-driven instrument air compressor following preventative maintenance activities,
on October 13, 2022
(3)
'B' chilled water pump following motor replacement, on October 20, 2022
(4)
'B' chiller following routine preventative maintenance, on October 20, 2022
(5)
'A' train high head safety injection isolation valve XVG-8885, following breaker
maintenance, on October 31, 2022
(6)
Relay room supply fan 'B' following planned maintenance, on November 14, 2022
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance testing activities to verify system operability
and/or functionality:
Surveillance Tests (other) (IP Section 03.01) (1 Sample)
(1)
PTP-102.017, alternate seal injection pump functional test, on December 4, 2022
Inservice Testing (IP Section 03.01) (1 Sample)
(1)
STP-223.002, service water pump inservice test, on November 22, 2022.
71114.06 - Drill Evaluation
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
(1)
Inspectors observed an emergency drill on October 25, 2022, involving a seismic
event, loss of offsite power, loss of coolant accident, and containment loss resulting in
multiple emergency declarations including a General Emergency.
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) (1 Sample)
(1)
MS10: October 1, 2021 to September 30, 2022
MS08: Heat Removal Systems (IP Section 02.07) (1 Sample)
(1)
MS08: October 1, 2021 to September 30, 2022
MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)
(1)
MS10: October 1, 2021 to September 30, 2022
71152S - Semiannual Trend Problem Identification and Resolution
Semiannual Trend Review (Section 03.02) (2 Samples)
(1)
The inspectors reviewed the licensees corrective action program for potential
adverse trends in the scaffolding program that might be indicative of a more
significant safety issue. Inspectors reviewed the licensee's scaffolding program
following identification of scaffolding in close contact with plant equipment and recent
risk assessment procedure changes which affected risk screenings of scaffolding
activities. Inspectors observed and interviewed scaffolding planners, crews, and
competent persons, interviewed engineering and management, and walked down
erected scaffolds in the plant. Inspectors identified that risk assessments were
typically screened "low-risk" and in some cases may have warranted a higher risk
screening per the recently adopted WM-AA-301, "Operational Risk Assessment,"
Revision 21, but inspectors did not identify any instances where additional risk
mitigating actions beyond what the licensee was providing would have been required
by procedure. Inspectors reviewed design documentation forming the basis for the
scaffolding program to identify the basis for procedural requirements. Inspectors
identified that procedure CMP-100.009, "Scaffold Request, Evaluation, and Erection,"
Revision 10, did not align to basis documents and did not provide adequate
requirements to ensure the design basis of the facility was preserved when temporary
scaffolding was erected near seismically qualified equipment. The inspection
conclusions associated with this semiannual trend review are documented in this
report under Inspection Results Section 71152S.
(2)
The inspectors reviewed the licensees corrective action program for potential
adverse trends in radiation monitors that might be indicative of a more significant
safety issue. Inspectors reviewed a trend of failures resulting in Special Reports to
the NRC, obsolescence and procurement challenges, and planned modifications.
Inspectors also reviewed compensatory actions for each failure. Inspectors did not
identify any violations of regulatory requirements from the scope of inspection, but
this does not preclude further inspections on individual failures of radiation monitors.
71153 - Follow Up of Events and Notices of Enforcement Discretion
Event Report (IP Section 03.02) (1 Sample)
The inspectors evaluated the following licensee event reports (LERs):
(1)
LER 050000395/2022-002-01, Condition Prohibited by Technical Specification 3.8.1.1
(ADAMS Accession No. ML22101A284). The inspection conclusions associated with
this LER are documented in Inspection Report 2022-091 (ML22287A184).
INSPECTION RESULTS
Failure to establish adequate procedural controls to prevent scaffolding from adversely
affecting the performance of safety-related equipment
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
Open/Closed
[H.12] - Avoid
Complacency
An NRC-identified Green NCV of 10 CFR Part 50, Appendix B, Criterion V, Instructions,
Procedures, and Drawings, was identified for the licensees failure to establish adequate
procedural controls to ensure that scaffolding erected near safety-related equipment would
not adversely affect the performance of that equipment during a design-basis seismic event.
Specifically, NRC inspectors identified that the scaffold program implementing procedure
CMP-100.009, Scaffold Request, Evaluation, and Erection, did not include the spacing
requirements as detailed and evaluated in the scaffold program basis documents.
Description: On August 1, 2022, NRC inspectors identified that a scaffold constructed around
the B main steamline power operated relief valve was not adequately braced from
movement and there was inadequate clearance such that the end of one scaffold pole could
have contacted the valve controller if a seismic event were to occur. Inspectors reviewed
implementing procedures and design calculations for approved seismic-resistant scaffold
designs.
Licensee design calculation DC0121A-002, Dynamic Motion of Scaffolding Subjected to
Earthquake Accelerations, and engineering work record EIR-82173A, Criteria for
Scaffolding in the Vicinity of Essential Equipment, are two of several basis documents for the
licensees scaffolding program. DC0121A-002 evaluated and bounded various configurations
of scaffolding to not overturn, move no more than nine inches from their original position
horizontally, or move no more than two inches vertically during a design basis seismic event.
Licensee procedure CMP-100.009, Scaffold Request, Evaluation, and Erection, Revision
10, was the implementing procedure for the scaffolding program and was used to maintain
the design basis of the facility. Per the basis documents, scaffolds do not impact the
functionality of essential equipment if constructed in accordance with CMP-100.009. CMP-
100.009 step 5.5.24 required that Scaffolding shall be constructed as to minimize the
possibility of affecting seismically qualified components. Step 7.5.6 stated, Ensure scaffold
will not contact safety-related or safe shutdown components that may be damaged by
scaffold movement. Step 7.5.6.E stated, If it is determined that contact may occur then
prevention of horizontal movement toward safety-related or safe shutdown components may
require scaffold bracing tie off to structure.
Inspectors identified that the scaffolding crews, foremen, and competent persons did not
understand the spacing requirements as detailed in the scaffold program basis documents
including the potential movement distance during a seismic event. As such, it was accepted
practice to construct scaffolds that were not touching but were less than nine inches from
essential equipment. The inspectors provided multiple examples of these scaffold
installations to the licensee.
The inspectors concluded that the procedural requirements in CMP-100.009 were inadequate
to prevent scaffolding from impacting safety-related equipment during a design-basis seismic
event.
Corrective Actions: The licensee entered the inspectors concerns into the corrective action
program, evaluated program and procedure requirements, and revised procedure CMP-
100.009 to provide adequate requirements to ensure adequate bracing to structures when
spacing requirements could not be met near essential equipment.
Corrective Action References: CR 1210253
Performance Assessment:
Performance Deficiency: The inspectors determined the licensees failure to establish and
implement procedural controls, so scaffolding does not adversely affect the performance of
safety-related equipment was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor
because if left uncorrected, it would have the potential to lead to a more significant safety
concern. Specifically, the licensee did not have adequate procedural controls to prevent
scaffolding from impacting essential equipment during a seismic event.
Significance: The inspectors assessed the significance of the finding using IMC 0609
Appendix AProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 0609</br></br>Appendix A" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., The Significance Determination Process (SDP) for Findings At-Power. The
finding was determined to be of very low safety significance (Green) since inspectors did not
identify any components that were rendered inoperable as a result of the performance
deficiency. Although erecting scaffolds near essential equipment could have affected the
seismic qualification of the equipment, inspectors did not identify an example where the
potential contact points would have rendered the equipment inoperable. Therefore, in the
examples found, all SSCs maintained operability or probabilistic risk assessment (PRA)
functionality.
Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the
possibility of mistakes, latent issues, and inherent risk, even while expecting successful
outcomes. Individuals implement appropriate error reduction tools. Specifically, scaffolding
activities were mostly assessed as low-risk activities and relied on procedural guidance,
planning, and training to ensure compliance. By not providing adequate procedural guidance
to workers and competent persons and by treating scaffolding activities as mostly low-risk
activities, the inherent risks of scaffolding activities (i.e., potential impacts on nearby essential
equipment) were not adequately managed.
Enforcement:
Violation: The scaffold program could affect the safety-related functions of those SSCs
necessary to ensure safe operations, therefore, the requirements of Title 10 CFR 50,
Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing
Plants, are applicable. Title 10 CFR Part 50, Appendix B, Criterion V, Instructions,
Procedures, and Drawings, requires, in part, that activities affecting quality shall be
prescribed by documented procedures appropriate to the circumstances and shall be
accomplished in accordance with those procedures.
Contrary to the above, the licensee failed to provide adequate procedures appropriate to the
circumstances. Specifically, licensee design calculation DC0121A-002 concluded that
scaffolds would move up to nine inches from their original position horizontally or up to two
inches vertically during a design-basis seismic event; however, NRC inspectors identified that
the scaffold implementing procedure, CMP-100.009, did not incorporate the requirements
detailed and evaluated in calculation DC0121A-002 such that scaffold erected in the vicinity
of essential equipment would be adequately spaced or braced to suitable structural
components to minimize movement during a design-basis seismic event.
Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2
of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On January 26, 2023, the inspectors presented the integrated inspection results to Mr.
Robert Justice and other members of the licensee staff.