IR 05000395/2023010

Biennial Problem Identification and Resolution Inspection Report 05000395/2023010

ML23223A231
Person / Time
Site:	Summer
Issue date:	08/12/2023
From:	David Dumbacher Division Reactor Projects II
To:	Carr E Southern Nuclear Operating Co
References
IR 2023010
Download: ML23223A231 (14)

Text

SUBJECT:

VIRGIL C. SUMMER NUCLEAR STATION - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000395/2023010

Dear Mr. Eric Carr:

On June 29, 2023, 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. Robert Justice, 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 problem identification and resolution 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 problem identification and resolution 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.August 12, 2023 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: NPF-12

Report Number: 05000395/2023010

Licensee: Dominion Energy

Facility: Virgil C. Summer Nuclear Station

Location: Jenkinsville, SC

Inspection Dates: June 12, 2023 to June 29, 2023

Inspectors: P. Braxton, Reactor Inspector N. Childs, Senior Project Engineer (Team Lead)

M. Ruffin, Reactor Inspector C. Speer, Project Manager T. Su, Reactor Inspector

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 03.04)

(1) The inspectors performed a biennial assessment of the effectiveness of the licensees problem identification and resolution program, use of operating experience, self-assessments and audits, and safety conscious work environment.

Problem Identification and Resolution Effectiveness: The inspectors assessed the effectiveness of the licensees problem identification and resolution program in identifying, prioritizing, evaluating, and correcting problems, including an in-depth corrective action program review of the following systems or portions thereof: component cooling water (CCW), service water (SW), and the electrical system (ES). The inspectors also conducted a five-year review of equipment aging issues. The corrective actions for the following non-cited violations (NCV), licensee identified violations (LIV), and findings (FIN) were evaluated as part of the assessment: FIN 2021002-01; NCV 2021004-01; NCV 2021010-01; NCV/SL-IV 2022002-01 (EA-22-037); NCV 2022004-01; LIV 2022401-01; NCV 2022401-01; NCV 2022401-02; and NCV 2022401-03.

Operating Experience: The inspectors assessed the effectiveness of the licensees processes for use of operating experience.

Self-Assessments and Audits: The inspectors assessed the effectiveness of the licensees identification and correction of problems identified through 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.

The inspectors reviewed the corrective actions to prevent recurrence that were in progress during an IP 95001 Supplemental Inspection (ML23114A094), dated May 1, 2023, associated with a notice of violation (NOV) 2022001-01 (EA-22-039) in the Mitigating Systems Cornerstone. The inspectors verified that the corrective actions had been either completed or had a corrective action plan in place.

INSPECTION RESULTS

Assessment 71152B 1) Corrective Action Program Effectiveness

Problem Identification: The team determined that the licensee was generally effective in identifying problems and entering them into the corrective action program (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 PI-AA-200, Corrective Action. Additionally, site management was actively involved in the corrective action program and focused appropriate attention on significant plant issues. The inspectors documented one minor violation in the Results section of this report, regarding incomplete documentation of information in a CR as directed by the site procedure. The licensee initiated CR 1232098 to address this issue.

Problem Prioritization and Evaluation: Based on the review of condition reports and work orders, the inspectors concluded that problems were generally prioritized and evaluated in accordance with licensee guidance. 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, and cause determinations were appropriate and considered the significance of the issues being evaluated. The inspectors documented an observation in the Results section of this report, regarding the licensees categorization and subsequent prioritization of issues related to programs required by NRC regulations, such as 10 CFR Part 21, as non-condition adverse to quality (NCAQ) CRs. The inspectors also documented an observation in the Results section of this report, related to the licensees failure to recognize that a software change resulted in the mis-categorization of multiple CRs as NCAQs, even though the affected components were quality related. The licensee initiated CR 1231870 and CR 1232224 to address these issues.

Corrective Actions: Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the inspectors determined that, generally, corrective actions were effective, timely, commensurate with the safety significance of the issues, and effective, in that conditions adverse to quality were corrected.

The team determined that the licensee was generally effective in developing corrective actions that were appropriately focused. The inspectors documented an observation in the Results section of this report, regarding a missed opportunity to implement a preventive maintenance activity for the component cooling water pump motors, identified during a large motor program review in 2012, prior to the CCW pump B motor failure in 2021.

Based on the samples reviewed, the team determined that the licensees corrective action program complied with regulatory requirements and self-imposed standards. The licensees implementation of the corrective action program adequately supported nuclear safety.

2) Operating Experience The team determined that the stations processes for the use of industry and NRC operating experience information were effective and complied with regulatory requirements and licensee standards. The implementation of these programs adequately supported nuclear safety. The team concluded that operating experience was adequately evaluated for applicability and that appropriate actions were implemented in accordance with applicable procedures.

3) 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. The self-assessments and audits were adequately self-critical and performance-related issues were being appropriately identified. The inspectors verified that action requests were created to document areas for improvement and findings and verified that actions generally had been completed consistent with those recommendations.

4) Safety Conscious Work Environment

Employees interviewed appeared willing to raise nuclear safety concerns through at least one of the several means available. Based on interviews with plant staff and reviews of the latest safety culture survey results, the team found no evidence of challenges to a safety conscious work environment. However, the inspectors documented an observation in the Results section of this report, regarding a potential vulnerability in employee knowledge of initiating and submitting anonymous CRs, which is one of the means to raise nuclear safety concerns onsite. The licensee initiated CR 1232223 to address this issue.

Minor Violation 71152B Minor Violation: The inspectors identified one minor violation regarding incomplete documentation of information in a CR as directed by a site procedure. CR 21-02742 and CR 1214518 requested an environmental qualification (EQ) evaluation for the areas served by penetration area exhaust fans A and B (XFN 147A / B), due to the fans being out of service for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. System Operating Procedure (SOP)-502, Auxiliary and Fuel Handling Building Ventilation System, step 4.c required that a CR be initiated when these fans were out of service for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Additionally, step 4.c of SOP-502 required that the building temperature, the length of time the fan(s) were out of service, and any temperature alarms received were documented in the CR. In this case, the CRs were initiated but the building temperatures were not recorded in the CRs as required by SOP-502, steps 4.c and 4.e. The licensee initiated CR 1232098 to address this issue.

Screening: The inspectors determined the performance deficiency was minor. The licensee's failure to properly implement a procedure affecting quality, SOP-502, when penetration area exhaust fans A and B (XFN 147A/B) were out of service for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> was a performance deficiency (PD). The issue is consistent with minor example 1.a of IMC 612 Appendix E. The PD did not adversely affect the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. There were no noted adverse impacts to EQ components located in the affected area due to the PD.

Enforcement:

Title 10 CFR Part 50 Appendix B, Criterion V, Instructions, Procedures, and Drawings, states, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Contrary to the above, on October 13, 2021 (CR-21-02742) and December 5, 2022 (CR1214518), the licensee failed to properly implement SOP-502, a procedure affecting quality. Specifically, the licensee failed to document building temperatures in the associated CRs as required by procedure SOP-502 steps 4.c and 4.e. This failure to comply with 10 CFR Part 50, Appendix B, Criterion V, constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.

Observation: Software Change Resulted in Misclassification of Multiple CRs 71152B In the area of problem prioritization, the team identified that CR 21-02742 (EQ evaluation for areas served by penetration area exhaust fans) was improperly categorized as an NCAQ, even though the affected components were quality related. Further investigation revealed that the CR misclassification was introduced during the licensee's transition from the Computer Maintenance Management System (CMMS) to the Plant Asset Management System (PAMS)which occurred in January 2022. The inspectors also identified that CR 21-01492, CR 21-00960, and CR 20-02070 had the same issue. The licensee determined that these CRs should have been listed in PAMS as CAQs because each CR had an associated operability evaluation and any CRs in CMMS with operability evaluations should have been transferred to PAMS as CAQs. The licensee initiated CR 1231870 to address this issue.

Observation: Potential Lack of Employee Knowledge in Reporting Anonymous 71152B Concerns In the area of safety conscious work environment, the team noted that there had been one anonymous CR initiated at V.C. Summer over the prior two-year period (since April 2021) and that CR was initiated in 2023. Anonymous CR reporting is included in the licensee's corrective action procedure as one of the means to report an issue. During safety conscious work environment interviews with randomly selected licensee staff (~ 15), the inspectors identified that only one individual knew how to submit an anonymous concern. However, all of those interviewed stated that they felt free to raise concerns. The inspectors noted that there also appeared to be a lack of anonymity in how an employee would submit the anonymous CR form, which was to mail the form to the corrective action group or deliver the form to someone in the corrective action group (e.g., could leave in envelope at desk). The inspectors noted that the employees' lack awareness on how to submit an anonymous CR, could create missed opportunities to capture issues that might otherwise be identified by those individuals that do not feel comfortable using the site's preferred means of reporting (i.e., management chain, CAP, or employee concerns program). The licensee initiated CR 1232223 to address this issue.

Observation: Missed Opportunity to Implement PM Prior to Component Failure 71152B In the area of corrective action, the inspectors identified that the licensee missed an opportunity to implement a preventive maintenance activity to refurbish and rewind the CCW pump B motor prior to its failure in 2021. The inspectors determined that, in June 2012, during a large motor program review, the licensee identified that a preventive maintenance (PM) task did not exist to refurbish or rewind the CCW pump motors. The Electric Power Research Institute (EPRI) PM templates, which the licensee utilized to inform their PM strategies, recommended a PM task to refurbish or rewind the motors every 15 years. The licensee did not enter this into their corrective action program; however, they established a schedule to implement the PM task for the CCW pump motors as well as other similar large motors onsite. In 2016, the licensee opted to obtain a spare pump motor in lieu of implementing the PM task. That action was put on hold in 2017 as documented in the December 2020 revision of the licensee's Large Motor Program Long Range Plan.

On June 14, 2021, the CCW pump B motor failed while in service due to an electrical fault caused by degradation in the motor windings. The CCW pump B motor was placed in service in 1982 without a motor refurbishment or rewind prior to the failure in 2021. The inspectors concluded that the motor failure may have been prevented if the licensee had entered this issue into their corrective action program and implemented the PM task to periodically refurbish and rewind the motor when the issue was identified in 2012. However, the inspectors determined that this issue was not a performance deficiency. This was the first CCW pump motor failure due to degradation of the motor windings at V.C. Summer. The licensee was aware of the EPRI recommended PM task for refurbishment and rewind, but they were following their in-service testing program requirements and there werent any declining trends identified before the motor failure in 2021. The licensee refurbished the CCW pump B motor following the failure in 2021 and placed it back into service in October 2021. In discussions with engineers and managers familiar with the licensee's deferral of the actions related to the refurbish and rewind PM activity and the action to acquire a spare pump motor, dating back to 2012 and following the June 2021 failure, the inspectors determined that the licensee was actively establishing work plans and procuring replacement motors for all similar large motors on site that did not have PMs for refurbishment or rewind (Reference CR 21-01621).

Observation: Weakness in Categorizing and Prioritizing Programmatic Issues 71152B In the area of problem prioritization, the inspectors identified a weakness with the licensees categorization and subsequent prioritization of issues related to process issues or procedural enhancements. Specifically, the inspectors reviewed CR 1195800, initiated on April 6, 2022, which was written to improve the licensees 10 CFR Part 21 program in response to a violation documented in integrated inspection report 05000395/2022002. The inspectors noted that the due dates associated with the CR 1195800 actions to develop 10 CFR Part 21 process improvements had been extended for over a year and had not been completed at the time of the PI&R inspection. The licensees procedure for categorizing and prioritizing condition reports, PI-AA-200, Corrective Action, Revisions 38 through 40, allowed for categorizing condition reports dealing with procedural enhancements and process improvements, such as CR 1195800, as an NCAQ. NCAQ condition reports are not subject to the same timeliness or other prioritization requirements as those categorized as conditions adverse to quality (CAQ). The inspectors challenged the licensees approach to characterize identified shortcomings or needed enhancements in programs required by NRC regulations as NCAQ condition reports. Doing so, rather than categorizing such issues as CAQ condition reports, could put the licensee at an increased risk of future, similar regulatory violations. The licensee initiated CR1232224 to address this issue.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On June 29, 2023, the inspectors presented the biennial problem identification and resolution inspection results to Mr. Robert Justice, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71152B Calculations DC0011A-132 Component Cooling Water Pump Motor Life Extension Revision 2

DC0011A-132 Component Cooling Water Pump Motor Life Extension Revision 3

Corrective Action Condition Reports 1190134, 1190777, 1191016, 1191016, 1191563, 1192303,

Documents (CRs) 1192816, 1195800, 1196122, 1197425, 1199300, 1199548,

1199715, 1200345, 1201683, 1201850, 1202676, 1203030,

207524, 1207741, 1207741, 1208069, 1208482, 1210043,

210687, 1211226, 1211780, 1212050, 1212088, 1214518,

215400, 1217049, 1217074, 1219603, 1221641, 1221787,

22768, 1223268, 1224086, 1224267, 1224566, 1224568,

24929, 1225119, 1225197, 1226356, 1226678, 1226790,

26803, 1227195, 1227733, 1227975, 1228425, 1228459,

28631, 16-01337, 20-03474, 20-03494, 21-00794, 21-

00842, 21-00920, 21-00922, 21-00938, 21-00940, 21-00942,

21-00948, 21-00960, 21-00963, 21-00984, 21-00984, 21-

01053, 21-01063, 21-01121, 21-01157, 21-01164, 21-01190,

21-01261, 21-01263, 21-01326, 21-01362, 21-01455, 21-

01469, 21-01492, 21-01501, 21-01536, 21-01587, 21-01620,

21-01621, 21-01699, 21-01732, 21-01754, 21-01787, 21-

01810, 21-01828, 21-01831, 21-01832, 21-01844, 21-01872,

21-01951, 21-01959, 21-01969, 21-02004, 21-02022, 21-

2094, 21-02149, 21-02178, 21-02282, 21-02438, 21-02444,

21-02455, 21-02513, 21-02584, 21-02594, 21-02663, 21-

2687, 21-02699, 21-02699, 21-02741, 21-02742, 21-02818,

21-02818, 21-02820, 21-02846, 21-02857, 21-02871, 21-

2875, 21-02876, 21-02876, 21-02944, 21-03020, 21-03023,

21-03039, 21-03055, 21-03105, 21-03266, 21-03276, 21-

03454, 21-03799, 21-03805, 22-00115, 22-00220, 22-00258

Corrective 9350778, 11062192, 11075560, 11075561, 11112112,

Actions (CAs) 11198372, 11198373, 11221941, 11221942, 11233250,

286680, 11302860, 11302861, 11310546, 11316973,

11371459, 11490657, 11490671, 11490672, 11490701,

11490704, 11490712, 11490714, 11490715, 11490716,

Inspection Type Designation Description or Title Revision or

Procedure Date

11490721, 11490822, 11502745, 11788373, 11789931

CR-21-01455 MR XFN0045A DG Area B Ventilation Air Supply Fan A 05/27/2021

Eval

Corrective Action Condition Reports 1231870, 1232098, 1232164, 1232223, 1232224

Documents (CRs)

Resulting from

Inspection

Miscellaneous Self-Assessment Report, Mic-Cycle (Phase 1) and Nuclear Revision 0

Safety Culture

Self-Assessment Report, Test Unit Task Transfer to PSE Approved

Effectiveness March 28,

22

Self-Assessment: 2021 Mid-Cycle (Phase 1) and Nuclear Revision 0

Safety Culture

Electrical System Health Report 03/08/23

Electrical System Walkdown 03/29/22

Electrical System Walkdown 04/30/23

SYSTEM REPORT - Component Cooling 2022 Period 2 03/08/2023

Enhanced Design Basis Document: Component Cooling Revision 13

Large Motor Program Long Term Motor Plan 04/21/2015

Large Motor Program Long Term Motor Plan 12/14/2020

Electrical System Walkdown 01/17/23

Large Motor Program Long Term Motor Plan 09/01/2011

1MS-94B-447-0 Bingham Willamette HS Series Pumps 02/04/1982

1MS-94B-587-0 Westinghouse FA Motors Induction and Synchronous Types 11/08/1984

Plant Health Service Water System 03/08/2023

Report - System

Report

QA-AUD-201912 Corrective Action Program Audit Report 12/10/2019

VCS1SW SW System Basis Document Revision 0

Procedures CMP-100.009 Scaffold Request, Evaluation, and Erection Revision 11

DOM-QA-1 Internal Audits

EC-AA-110 Identifying and Addressing Nuclear Safety and Quality Revision 1

Concerns

Inspection Type Designation Description or Title Revision or

Procedure Date

ER-AA-102 Preventive Maintenance Program Revision 16

ER-AA-MTR-Large Motor Program Revision 4

1001

ER-AA-PRS-1003 Equipment Reliability Component Classifications Revision 10

ER-AA-PRS-1010 Preventative Maintenance Task Basis and Maintenance Revision 16

Strategy

ER-AA-SYS-100 System Health Report Revision13

LI-AA-301 Implementation of 10 CFR 21, Reporting of Defects and Revision 3

Noncompliance

MLP-285.004 Calibration of Dial Indicators Revision 4

OP-AA-100 Conduct of Operations Revision 46

OP-AA-102 Operability Determinations Revision 17

PI-AA-100 Performance Monitoring Revision 12

PI-AA-100-1003 Self Evaluation and Trending

PI-AA-100-1004 Self-Assessments Revision 14

PI-AA-100-1009 Mid-Cycle Review

PI-AA-200 Corrective Action Program Revision 41

PI-AA-200 Corrective Action Revision 40

PI-AA-300-3001 Root Cause Evaluation Revision 14

PI-AA-300-3007 Level of Effort Evaluation Revision 2

PSEG-12 System and Program Health Reports Revision 10

SAP-0999 Corrective Action Program Change E Revision 19

SAP-0999 Corrective Action Program Change D Revision 19

SAP-0999 Corrective Action Program Change C Revision 19

TRP-31 Quality Related HVAC Which Effects Equipment QualificationRevision 1

VCSNS-DBD Service Water System Revision 19

Self-Assessments Dosimetry Self-Assessment 05/31/2022

EP Readiness Self-Assessment for the March 2022 INPO 01/24/2022

EMPE

Operations Self-Assessment 12/28/2022

Motor Program Self Assessment 08/10/2021

22 Operations Training Program Self-Assessment 11/07/2022

22 VCS Access Control PIV PSP Action Auth and FFD 01/24/2022

Inspection Type Designation Description or Title Revision or

Procedure Date

Self Assessment Manuel 01242022

SAG-01 VCSNS Motor Program Self-Assessment 06/14/2021

Service Water Service Water Chemistry Self Assessment 03/22/2022

Chemistry Self

Assessment

Work Orders WOs 88101005525, 88101005545, 88101055258, 88101055262,

201668017

11