Text

NRC Integrated Inspection Report 05000395/2015004
	ML16029A112
Person / Time
Site:	Summer
Issue date:	01/29/2016
From:	Steven Rose; NRC/RGN-II/DRP/RPB5
To:	Gatlin T; South Carolina Electric & Gas Co
References
	IR 2015004
	Download: ML16029A112 (33)
	v • d • e

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

245 PEACHTREE CENTER AVENUE NE, SUITE 1200

ATLANTA, GEORGIA 30303-1257

January 29, 2016

Mr. Thomas D. Gatlin

Vice President - Nuclear Operations

South Carolina Electric & Gas Company

Virgil C. Summer Nuclear Station

P.O. Box 88

Jenkinsville, SC 29065

SUBJECT: VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1 - NRC INTEGRATED

INSPECTION REPORT 05000395/2015004

Dear Mr. Gatlin:

On December 31, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an

inspection at your Virgil C. Summer Nuclear Station, Unit 1. On January 21, 2016, the NRC

inspectors discussed the results of this inspection with Mr. T. Gatlin and members of your staff.

Inspectors documented the results of this inspection in the enclosed inspection report.

NRC inspectors documented one NRC-identified finding of very low safety significance (Green),

in this report. The finding involved a violation of NRC requirements. The inspectors also

documented two licensee-identified violations, which were determined to be of very low safety

significance, in this report. The NRC is treating the violations as non-cited violations (NCV)

consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violation or significance of these NCVs, you should provide a response within

30 days of the date of this inspection report, with the basis for your denial, to the Nuclear

Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with

copies to the Regional Administrator, Region II; the Director, Office of Enforcement, United

States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident

Inspector at the Virgil C. Summer Nuclear Station, Unit 1.

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 Regional Administrator, Region II, and the NRC Resident Inspector at the

Virgil C. Summer Nuclear Station, Unit 1.

D. Gatlin 2

In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections,

Exemptions, Requests for Withholding, of the NRC's "Agency Rules of Practice," a copy of this

letter, its enclosure, and your response (if any) will be available electronically for public

inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS)

component of the NRC's Agencywide Documents Access and Management System

(ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-

rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Steven D. Rose, Chief

Reactor Projects Branch 5

Division of Reactor Projects

Docket No.: 50-395

License No.: NPF-12

Enclosure:

IR 05000395/2015004

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ML16029A112 SUNSI REVIEW COMPLETE FORM 665 ATTACHED

OFFICE RII:DRP RII:DRP RII:DRP RII:DRP RII:DRS

SIGNATURE JTR via email ETC1 via email BDB3 SON AJB1 via email

NAME J. Reece E. Coffman B. Bishop S. Ninh A. Butcavage

DATE 1/21/2016 1/21/2016 1/20/2016 1/21/2016 1/14/2016

E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO

OFFICE RII:DRS RII:DRS RII:DRP

SIGNATURE SON /RA for BCC2/ DXB2 via email SDR2

NAME B. Collins D. Bacon SRose

DATE 1/22/2016 1/14/ 2016 1/28/2016

E-MAIL COPY? YES NO YES NO YES NO

T. Gatlin 3

Letter to Thomas D. Gatlin from Steven D. Rose dated January 29, 2016.

SUBJECT: VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1 - NRC INTEGRATED

INSPECTION REPORT 05000395/2015004

DISTRIBUTION:

D. Gamberoni, RII

L. Gibson, RII

OE Mail

RIDSNRRDIRS

PUBLIC

RidsNrrPMSummer Resource

U. S. NUCLEAR REGULATORY COMMISSION

REGION II

Docket No. 50-395

License No. NPF-12

Report Nos. 05000395/2015004

Licensee: South Carolina Electric & Gas (SCE&G) Company

Facility: Virgil C. Summer Nuclear Station, Unit 1

Location: P.O. Box 88

Jenkinsville, SC 29065

Dates: October 1, 2015, through December 31, 2015

Inspectors: J. Reece, Senior Resident Inspector

E. Coffman, Resident Inspector

A. Butcavage, Reactor Inspector (Section 1R08)

B. Collins, Reactor Inspector (Section 1R08)

D. Bacon, Senior Operations Engineer (Section 1R11)

Approved by: Steven D. Rose, Chief

Reactor Projects Branch 5

Division of Reactor Projects

Enclosure

SUMMARY

IR 05000395/2015004; 10/01/2015 - 12/31/2015: Virgil C. Summer Nuclear Station, Unit 1;

Problem Identification and Resolution.

The report covered a three-month period of inspection by resident inspectors, regional reactor

inspectors and a senior operations engineer. One NRC-identified violation was identified and

documented in this report. The significance of most findings is indicated by their color (Green,

White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination

Process (SDP), dated April 29, 2015. The cross-cutting aspects were determined using IMC 0310, Aspects Within the Cross Cutting Areas, dated December 4, 2014. All violations of NRC

requirements are dispositioned in accordance with the NRCs Enforcement Policy dated

February 4, 2015. The NRCs program for overseeing the safe operation of commercial nuclear

power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.

Cornerstone: Mitigating Systems

Green. The inspectors identified a non-cited violation of 10 CFR 50, Appendix B,

Criterion V, Instructions, Procedures, and Drawings, which requires in part that

activities affecting quality shall be accomplished in accordance with procedures.

Specifically, the licensee failed to accomplish preventative maintenance diagnostic

testing in accordance with their station administrative program procedure, SAP-160,

Motor Operated Valve Program, Revision 1, to identify degradation of a torque

switch that led to two failures of stroke time testing of A train reactor building spray

(SP) sump isolation valve, XVG03005A-SP. This also resulted in a loss of safety

function involving reactor building spray. The licensee entered the problem into their

corrective action program as condition report, CR-15-00541.

The inspectors identified a performance deficiency (PD) for the failure to accomplish

the requirements of SAP-160 leading to two failures of XVG03005A-SP. The

inspectors reviewed IMC 0612, Appendix B, Issue Screening, dated September 7,

2012, and determined the PD was more than minor because it adversely impacted

the barrier integrity cornerstone objective to provide reasonable assurance that the

reactor building or containment protects the public from radionuclide releases caused

by accidents or events and the related attribute of structures, systems and

components (SSC) performance. Specifically, the licensee failed to perform

preventative maintenance diagnostic testing required by SAP-160 to identify

degradation of a torque switch for XVG03005A-SP. The inspectors used IMC 0609,

Appendix A, Exhibit 3, Barrier Integrity Screening Questions, dated July 1, 2012,

and IMC 0609, Appendix H, Containment Integrity Significance Determination

Process, dated May 6, 2004, and determined the finding was of very low safety

significance or Green, because the finding did not represent a significant impact to

Large Early Release Failure. The inspectors reviewed IMC 0310, Aspects Within

Cross Cutting Areas, dated December 4, 2014, and determined the cause of this

finding involved the cross-cutting area of problem identification and resolution and

the aspect of evaluation, P.2, because the licensee failed to thoroughly evaluate the

failures of XVG03005A-SP to ensure that resolutions address causes and extent of

conditions commensurate with their safety significance. (Section 4OA2.2)

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Two violations of very low safety significance that were identified by the licensee have been

reviewed by the NRC. Corrective actions taken or planned by the licensee have been entered

into the licensees corrective action program. The violations and corrective action tracking

numbers are listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status

Unit 1 began the inspection period at full Rated Thermal Power (RTP) and operated at or near

full RTP until October 2, 2015, when the unit was brought off line to start a refueling outage.

The unit returned to service on December 2, 2015, and resumed full RTP on December 5, 2015.

The unit operated at or near full RTP for the remainder of the quarter.

1. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

1R01 Adverse Weather Protection

Seasonal Weather Susceptibilities

a. Inspection Scope

The inspectors performed one seasonal extreme weather inspection for readiness

of cold weather for two risk significant components. The inspectors verified the

licensee had implemented applicable sections of operations administrative

procedure, OAP-109.1, Revision (Rev.) 4D, Guidelines for Severe Weather. The

inspectors reviewed preparations for extreme cold weather and walked down the

refueling water storage tank (RWST) and associated outside emergency core

cooling system (ECCS) suction piping and the sodium hydroxide (NaOH) tank and

associated outside piping to assess whether the equipment was adequately

protected from cold weather and would function as expected during an accident

event. Also, the inspectors reviewed the licensees corrective action program

(CAP) database to verify that freeze protection problems were being identified at

the appropriate level, entered into the CAP, and appropriately resolved.

b. Findings

No findings were identified.

1R04 Equipment Alignment

Partial System Walkdowns

a. Inspection Scope

The inspectors conducted three partial equipment alignment walkdowns which are listed

below, to evaluate the operability of selected redundant trains or backup systems with

the other train or system inoperable or out of service (OOS). Correct alignment and

operating conditions were determined from the applicable portions of drawings, system

operating procedures (SOP), and technical specifications (TS). The inspections

included review of outstanding maintenance work orders (WOs) and related condition

reports (CRs) to verify that the licensee had properly identified and resolved equipment

alignment problems that could lead to the initiation of an event or impact mitigating

system availability. Documents reviewed are listed in the attachment.

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Partial walkdown of A emergency diesel generator (EDG) following refueling outage

work activities

Partial walkdown of A safety injection (SI) pump following refueling outage work

activities

Partial walkdown of the A motor driven emergency feedwater (MDEFW)

components following refueling outage work activities

b. Findings

No findings were identified.

1R05 Fire Protection

Quarterly Fire Protection Walkdowns

a. Inspection Scope

The inspectors reviewed recent CRs, WOs, and impairments associated with the fire

protection system. The inspectors reviewed surveillance activities to determine whether

they supported the operability and availability of the fire protection system. The

inspectors assessed the material condition of the active and passive fire protection

systems and features, and observed the control of transient combustibles and ignition

sources. Documents reviewed are listed in the Attachment. The inspectors conducted

routine inspections of the following five areas (respective fire zones also noted):

Auxiliary building 436 elevation (fire zone AB-1.18)

Reactor building (fire zone RB-1.2)

Control room (fire zone CB-17.1)

Control building 482 elevation (fire zones CB-22, CB-23)

Intermediate building (fire zones IB 25.5, 25.6.1, 25.6.2, 25.7)

b. Findings

Introduction: An unresolved item (URI) was identified by the inspectors during the

walkdown of the Intermediate building fire area involving an engineering justification for a

departure from NFPA 80-1973 as required by the Fire Protection Program for

replacement fire doors DRIB/105A and DRIB/105B located in the intermediate building.

Description: The inspectors identified an issue of concern regarding replacement of fire

door DRIB/105 with a single door jamb containing two fire doors DRIB/105A and

DRIB/105B. These replacement doors were installed in a back to back configuration to

provide a pressure barrier function in addition to the fire barrier function but were not

self-closing as required by NFPA 80-1973. The licensee subsequently initiated CR-15-

04027 to evaluate this issue of concern.

Pending completion of additional evaluations needed to determine the existence of any

related performance deficiencies, this is identified as URI 05000395/2015004-01,

Departure from NFPA 80-1973 for Replacement Fire Doors.

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1R06 Flood Protection Measures

.1 Internal Flooding

a. Inspection Scope

The inspectors reviewed and walked down portions of the auxiliary building 374

elevation regarding internal flood protection features and equipment to determine

consistency with design requirements, Updated Final Safety Analysis Report (UFSAR),

and flood analysis documents. Risk significant SSCs in these areas included the A

and B train residual heat removal (RHR) and reactor building (RB) spray pumps.

The inspectors reviewed the licensees CAP database to verify that internal flood

protection problems were being identified at the appropriate level, entered into the

CAP, and appropriately resolved. Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

.2 Annual Review of Electrical Manholes

a. Inspection Scope

The inspectors reviewed a licensees periodic inspection of two risk-significant electrical

manholes (EMH), EMH-001 and EMH-002, containing safety-related cables for

assessment of leaks, cable supports and structures, and general structural integrity. In

addition, the inspectors reviewed several past periodic licensee inspection results for the

above mentioned manholes to ensure that any degraded conditions identified were

appropriately resolved. Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified

1R08 Inservice Inspection Activities

a. Inspection Scope

Non-Destructive Examination Activities and Welding Activities

From October 12-16, 2015, the inspectors conducted an onsite review of the

implementation of the licensees inservice inspection (ISI) program for monitoring

degradation of the reactor coolant system (RCS) boundary, risk-significant piping and

component boundaries, and containment boundaries in Unit 1.

The inspectors either directly observed or reviewed the following non-destructive

examinations (NDEs) mandated by the American Society of Mechanical Engineers

(ASME) Boiler and Pressure Vessel Code (Code of Record: 2007 Edition with 2008

Addenda) to evaluate compliance with the ASME Code,Section XI and Section V

requirements and, if any indications or defects were detected, to evaluate if they were

7

dispositioned in accordance with the ASME Code or an NRC-approved alternative

requirement. The inspectors also reviewed the qualifications of the NDE technicians

performing the examinations, to determine whether they were current and in compliance

with the ASME Code requirements.

Radiographic Inspection Report (IR), 3-inch Piping Weld MW-3, ASME Code Class 2

(Reviewed)

Surface Examination Penetrant Test (PT), Weld MW-1, ECR 51007, RWST Supply

to FLEX Piping Installation, ASME Class 2 (Reviewed)

PT, Weld of Valve XVT-08389-CS, Code Class 2 (Reviewed)

The inspectors reviewed the following in progress welding activities, qualification

records, and associated documents in order to evaluate compliance with procedures and

the ASME Code,Section XI and Section IX requirements. Specifically, the inspectors

reviewed a sample of the work order, repair and replacement plan, weld data sheets,

welding procedures, procedure qualification records, welder performance qualification

records, and NDE reports.

Weld MW-83, Feedwater Piping Replacement, ASME Code Class 2

Weld MW-84, Feedwater Piping Replacement, ASME Code Class 2

Weld MW-87, Feedwater Piping Replacement, ASME Code Class 2

During non-destructive surface and volumetric examinations performed since the

previous refueling outage, the licensee did not identify any relevant indications that were

analytically evaluated and accepted for continued service; therefore, no NRC review was

completed for this inspection procedure attribute.

Pressurized Water Reactor Vessel Upper Head Penetration Inspection Activities

The inspectors reviewed portions of the bare metal visual examination of the reactor

vessel upper head penetrations (VUHPs) to determine if the examinations were

performed in accordance with the requirements of ASME Code Case N-729-1 and 10 CFR 50.55a(g)(6)(ii)(D). Additionally, the inspectors reviewed examination records to

determine if the required examination coverage was achieved and if limitations were

recorded in accordance with the licensee procedures.

The inspectors observed the NDE activities for the volumetric examination of reactor

VUHP numbers 23, 27, 33, and 61 to determine if the activities, including the disposition

of indications and defects, were conducted in accordance with the requirements of

ASME Code Case N-729-1, as incorporated by reference in 10 CFR 50.55a(g)(6)(ii)(D).

Additionally, the inspectors review also determined whether essentially 100 percent of

the required examination volumes and surfaces were examined, and whether a

volumetric or surface leakage path examination was completed.

The inspectors reviewed the examinations that identified relevant indications accepted for

continued service. Specifically, the inspectors reviewed a sample of the examination

records and their associated evaluations, to verify that licensees acceptance for

continued service was in accordance with the requirements of 10 CFR 50.55a(g)(6)(ii)(D)

or an NRC-approved alternative.

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Since welding associated with repair of penetration number 22 during the Spring 2014

refueling outage (RF21) occurred after the previous NRC IP 71111.08 inspection, the

inspectors reviewed records of those welded repairs to evaluate if the licensee applied

the pre-service NDEs and acceptance criteria required by the NRC-approved Code relief

request, and the ASME Code Section XI requirements. In addition, the inspectors

reviewed the welding procedure specification and supporting weld procedure

qualification records, to evaluate if the weld procedure(s) used were validated in

accordance with the Construction Code and the ASME Code Section IX requirements.

Boric Acid Corrosion Control Inspection Activities

The inspectors reviewed the licensees boric acid corrosion control program (BACCP)

activities to determine if the activities were implemented in accordance with the

commitments made in response to NRC Generic Letter 88-05, Boric Acid Corrosion of

Carbon Steel Reactor Pressure Boundary Components in PWR Plants, and applicable

industry guidance documents. Specifically, the inspectors performed an onsite records

review of procedures, and the results of the licensees containment walkdown

inspections performed during the current refueling outage. The inspectors also

interviewed the BACCP owner, conducted an independent walkdown of the containment

to evaluate compliance with licensees BACCP requirements, and verified that degraded

or non-conforming conditions, such as boric acid leaks, were properly identified and

corrected in accordance with the licensees BACCP, and CAP. Specifically, the

inspectors identified two areas of concern inside containment; one on the pressurizer

lower head insulation, and one on the primary system shield wall penetration area. Both

areas of concern were entered into the corrective action process. The CRs associated

with these concerns are listed in the document reviewed sections.

The inspectors reviewed the following engineering evaluations, completed for evidence

of boric acid leakage, to determine if the licensee properly applied applicable corrosion

rates to the affected components; and properly assessed the effects of corrosion

induced wastage on structural or pressure boundary integrity in accordance with the

licensee procedures.

CR-15-05183, NRC concern for RCS fluid catchment at primary shield wall

penetration

CR-15-04843, Boric Acid residue C Loop Hot Leg Sandbox Area

The inspectors reviewed the following CRs and associated corrective actions related to

evidence of boric acid leakage, to evaluate if the corrective actions completed were

consistent with the requirements of the ASME Code and 10 CFR Part 50, Appendix B,

Criterion XVI.

CR-15-05081, (NRC-identified) White residue on the bottom of the insulation

package of the pressurizer heater nozzles

CR-15-05024, (NRC-identified) Boric Acid Leak, Test Connection on Safety

Injection Valve XVT08879-SI

CR-15-05025, (NRC-identified) Boric Acid Leak, Test Connection Isolation Valve

Safety Injection Valve XVT08879C-SI

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Steam Generator Tube Inspection Activities

The inspectors verified that for the Unit 1 steam generator tubes, no inspection activities

were required this refueling outage, in accordance with the requirements of the ASME

Code, the licensees Technical Specifications, and Nuclear Energy Institute (NEI) 97-06,

Steam Generator Program Guidelines.

Identification and Resolution of Problems

The inspectors reviewed a sample of ISI-related issues entered into the CAP to

determine if the licensee had appropriately described the scope of the problem and

initiated corrective actions. Specifically the inspectors reviewed the disposition of CR-

15-05177, which was initiated in response to the NRC resident inspectors concern that

portions of the reactor vessel supports were not subjected to the required VT-3

examinations, as required by 10 CFR 50.55a and ASME Table IWF-2500-1, Item F1.40,

supports other than piping supports. This issue surfaced with the resident inspectors

as a result of a previous inspection finding and violation issued May 6, 2013, and

reported in NRC IR 05000395/2013002. The inspectors identified that inspections

performed during 2013, in response to the 2013 inspection finding, did not include all

IWF designed support load path components, based on a code interpretation of ASME

jurisdictional boundaries. This issue was entered into the CAP as CR-15-05177, and the

required VT-3 inspections were completed by Work Order (WO) 1511896-001 during the

current refuel outage in order to comply with the ASME Code requirements for this

interval. This issue was screened in accordance with Inspection Manual Chapter (IMC) 0612, Appendix B, and classified as a minor violation, similar to IMC 0612, Appendix

E, Example m in that the VT-3 inspections performed during this refuel outage did not

identify any conditions that prohibited the reactor supports from performing their

intended function. The inspectors reviewed a sample of the support inspection results to

ensure compliance with the ASME Code inspection requirements and 10 CFR Part 50,

Appendix B, Criterion XVI, Corrective Action, requirements.

Inspectors also reviewed licensee identified CR-15-04864, which was initiated to

address concerns noted during inspection of the containment moisture barrier. The CR

provided direction for areas needing repairs, and concluded that there was a reasonable

expectation of operability.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

.1 Licensed Operator Requalification

a. Inspection Scope

The inspectors observed on December 8, 2015, one sample consisting of two operator

simulator makeup scenarios which involved component failures during Mode 5

conditions leading to entry into abnormal operating procedures in order to combat the

problems. The inspectors observed crew performance in terms of communications;

ability to prioritize failures in order to take timely and proper actions; prioritizing,

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interpreting, and verifying alarms; correct use and implementation of procedures,

including the alarm response procedures; timely control board operation and

manipulation, including high-risk operator actions; and oversight and direction provided

by the shift supervisor, including the ability to identify and implement appropriate TS

actions and emergency action levels. The inspectors reviewed the licensees critique

comments to verify that performance deficiencies were captured for appropriate

corrective action.

b. Findings

No findings were identified.

.2 Resident Quarterly Observation of Control Room Operations

a. Inspection Scope

During the inspection period, the inspectors conducted two observations of licensed

reactor operator activities to ensure consistency with licensee procedures and regulatory

requirements. For the two listed activities, the inspectors observed the following

elements of operator performance: 1) operator compliance and use of plant procedures

including TS; (2) control board component manipulations; 3) use and interpretation of

plant instrumentation and alarms; 4) documentation of activities; 5) management and

supervision of activities; and 6) control room communications.

Power reduction for start of refueling outage

Core offload activities

b. Findings

No findings were identified.

.3 Annual Review of Licensee Requalification Examination Results

a. Inspection Scope

On September 9, 2015, the licensee completed the comprehensive biennial

requalification written examinations and 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 NRCs Operators Licenses. The inspectors 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 Inspection Procedure (IP) 71111.11,

Licensed Operator Requalification Program. These results were compared to the

thresholds established in Section 3.02, Requalification Examination Results, of IP

71111.11.

b. Findings

No findings were identified.

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1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors evaluated equipment issues described in the four CRs listed below to

verify the licensees effectiveness with the corresponding preventive or corrective

maintenance associated with SSCs. The inspectors reviewed Maintenance Rule (MR)

implementation to verify that component and equipment failures were identified, entered,

and scoped within the MR program. Selected SSCs were reviewed to verify proper

categorization and classification in accordance with 10 CFR 50.65. The inspectors

examined the licensees 10 CFR 50.65(a)(1) corrective action plans to determine if the

licensee was identifying issues related to the MR at an appropriate threshold and that

corrective actions were established and effective. The inspectors review evaluated if

maintenance preventable functional failures or other MR findings existed that the

licensee had not identified. The inspectors reviewed the licensees controlling

procedures consisting of engineering services procedure (ES)-514, Rev. 6,

Maintenance Rule Program Implementation, and SAP-0157, Rev. 1, Maintenance

Rule Program, to verify consistency with the MR program requirements.

CR-15-01043, Failure of relay room B train fan motor, XFN00363

CR-15-03140, B chilled water pump bearing oil bubbler found with dark oil and

elevated bearing housing temperature of 193 degrees Fahrenheit

CR-15-03484, Unexpected start of the alternate seal injection diesel generator

CR-15-04751 and CR-15-06149, Auxiliary building rain water intrusion and potential

impact on RWST level transmitter

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessment and Emergent Work Control

a. Inspection Scope

The inspectors performed risk assessments, as appropriate, for the four scheduled work

activities involving a yellow risk condition for the associated components listed below to

assess, as appropriate: 1) the effectiveness of the risk assessments performed before

maintenance activities were conducted; 2) the management of risk; 3) that, upon

identification of an unforeseen situation, necessary steps were taken to plan and control

the resulting emergent work activities; and 4) that emergent work problems were

adequately identified and resolved. The inspectors evaluated the licensees work

prioritization and risk characterization to determine, as appropriate, whether necessary

steps were properly planned, controlled, and executed for the planned and emergent

work activities.

Lowered RCS inventory in high decay heat conditions for reactor vessel head

removal

Installing temporary power source for the A spent fuel cooling pump

Emergency switchgear 1DA outage with transformer, XTF0031, isolated from 1DB

Lowered RCS inventory in low decay heat conditions for reactor vessel head set

12

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

The inspectors reviewed the two operability evaluations listed below, affecting risk

significant mitigating systems to assess, as appropriate: 1) the technical adequacy of

the evaluations; 2) whether operability was properly justified and the subject component

or system remained available, such that no unrecognized increase in risk occurred;

3) whether other existing degraded conditions were considered; 4) that the licensee

considered other degraded conditions and their impact on compensatory measures for

the condition being evaluated; and 5) the impact on TS limiting conditions for operations

and the risk significance in accordance with the significance determination process. The

inspectors verified that the operability evaluations were performed in accordance with

SAP-209, Rev. 1B, Operability Determination Process, and SAP-999, Rev. 13A,

Corrective Action Program.

CR-15-01043, Evaluate past operability of relay room B fan with A EDG OOS

CR-15-03574, B service water (SW) traveling screen guide degradation allowing

introduction of fish into pump bay

b. Findings

The enforcement aspects regarding CR-15-03574 are discussed in Section 4OA7 of this

report.

1R18 Plant Modifications

a. Inspection Scope

The inspectors reviewed one temporary modification or engineering change request

(ECR) as noted below, to evaluate the change for adverse effects on system availability,

reliability, and functional capability. Documents reviewed included engineering

calculations, WOs, site drawings, applicable sections of the UFSAR, supporting 10 CFR

50.59 evaluations, TS, and design basis information. The inspectors evaluated the

change documents and associated 10 CFR 50.59 reviews against the system design

basis documentation and UFSAR to verify that the changes did not adversely affect the

safety function of safety systems. The inspectors reviewed any related CRs to confirm

that problems were identified at an appropriate threshold, were entered into the CAP,

and appropriate corrective actions had been initiated.

WO1410044, Install temporary power source for the A spent fuel (SF) cooling pump

b. Findings

No findings were identified.

13

1R19 Post Maintenance Testing

a. Inspection Scope

For the three maintenance activities listed below, the inspectors reviewed the associated

post-maintenance testing (PMT) procedures and either witnessed the testing and/or

reviewed test records to assess whether: 1) the effect of testing on the plant had been

adequately addressed by control room and/or engineering personnel; 2) testing was

adequate for the maintenance performed; 3) test acceptance criteria were clear and

adequately demonstrated operational readiness consistent with design and licensing

basis documents; 4) test instrumentation had current calibrations, range, and accuracy

consistent with the application; 5) tests were performed as written with applicable

prerequisites satisfied; 6) jumpers installed or leads lifted were properly controlled;

7) test equipment was removed following testing; and 8) equipment was returned to the

status required to perform its safety function. The inspectors verified that these activities

were performed in accordance with general test procedure, (GTP)-214, Post

Maintenance Testing Guideline, Rev. 5F.

WO1413072, replace pump bearings on B chilled water pump

WO1415985, replace leaking mechanical seal on A RHR pump

WO1509460, repair B EDG lube oil thermostatic control valve

b. Findings

No findings were identified.

1R20 Refueling Outage and Other Outage Activities

a. Inspection Scope

On October 2, 2015, the unit was shut down to commence refueling outage (RF)-22.

The outage was completed on December 2, 2015. The inspectors used IP 71111.20,

Refueling and Outage Activities, to complete the inspections described below.

Documents reviewed are listed in the Attachment.

Prior to and during the outage, the inspectors reviewed the licensees outage risk

assessments and controls for the outage schedule to verify that the licensee had

appropriately considered risk, industry experience and previous site specific problems,

and to confirm that the licensee had mitigation/response strategies for losses of any key

safety functions. In the area of licensee control of outage activities, the inspectors

reviewed equipment removed from service to verify that defense-in-depth was

maintained in accordance with applicable TS and that configuration changes due to

emergent work and unexpected conditions were controlled in accordance with the

outage schedule and risk control plan.

The inspectors reviewed selected components which were removed from service to

verify that tag outs were properly installed and that associated equipment was

appropriately configured to support the function of the clearance.

During the outage, the inspectors reviewed and/or observed the following:

14

RCS pressure, level, and temperature instruments to verify that those instruments

were installed and configured to provide accurate indication prior to RCS draindown

to lowered inventory conditions. The licensee did not drain to reduced inventory or

mid-loop conditions.

The status and configuration of electrical systems to verify that those systems met

TS requirements and the licensees outage risk control plan. The inspectors also

evaluated if switchyard activities were controlled commensurate with their risk

significance and if they were consistent with the licensees outage risk control

assessment assumptions

SF cooling operations to verify that outage work was not impacting the ability of the

operations staff to operate the SF cooling system during and after core offload. The

inspectors also reviewed the licensees calculation results of SF and reactor vessel

heat up rates in case of a potential loss of cooling event

Heavy load lifts for the reactor vessel head removal and reinstallation to ensure the

activities were conducted in a controlled and safe manner. Heavy load lift

procedures were reviewed to determine whether past and current practices were

within the licensing basis and consistent with guidance in NUREG-0612, Control of

Heavy loads at Nuclear Power Plants

The control of containment penetrations and containment entries to verify that the

licensee controlled those penetrations and activities in accordance with the

appropriate TS and could achieve/maintain containment closure for required

conditions

All accessible areas inside the reactor building prior to reactor startup to verify that

debris had not been left which could affect the performance of the containment

emergency core cooling system recirculation sumps

The inspectors reviewed the following activities for conformance to applicable TS and

licensee procedural requirements:

Plant shutdown activities

Decay heat removal system operations

Inventory controls and measures to provide alternate means for inventory addition

Electrical power availability controls

Fitness for Duty area of fatigue management

Reactivity controls

Reactor vessel defueling and refueling operations

Reactor heat up, mode changes, initial criticality, startup and power ascension

activities

The inspectors reviewed various problems that occurred during the outage to verify that

the licensee was identifying problems related to outage activities at an appropriate

threshold and was entering them in the CAP.

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

15

The inspectors observed and/or reviewed the six surveillance test procedures (STPs)

listed below to verify that TS or risk significant surveillance requirements were followed

and that test acceptance criteria were properly specified to ensure that the equipment

could perform its intended safety function. The inspectors verified that proper test

conditions were established as specified in the procedures, that no equipment

preconditioning activities occurred, and that acceptance criteria were met.

Containment Isolation Valve

STP-215.003A, Containment Isolation Valve Leakage Test for the CVCS, ND, RC,

SF, SI, SP, and WL Systems, Rev. 7A, for penetration XRP0303

In-Service Tests

STP-160.001, Containment Tendon Test, Rev. 4G

Reactor Coolant System

STP-114.002, Operational Leakage Calculation, Rev. 12G

Other

STP-102.001, Source Range Analog Channel Operational Test N-33, Rev. 7

STP-125.001, Electric Power Systems Weekly Test, Rev. 15I

STP-501.001A, Battery XBA1A Weekly Test, Rev. 2C

b. Findings

No findings were identified.

1EP6 Drill Evaluation

a. Inspection Scope

The inspectors reviewed and observed the performance of an operator requalification

exam that involved multiple failures leading to entry into abnormal operating procedures

followed by emergency operating procedures, which required entry into emergency

action levels. The inspectors assessed as applicable abnormal and emergency

procedure usage, emergency plan classifications, protective action recommendations,

respective notifications and the adequacy of the licensees drill critique. The inspectors

verified that drill deficiencies were captured into the licensees corrective action program.

b. Findings

No findings were identified.

16

4. OTHER ACTIVITIES

4OA1 Performance Indicator (PI) Verification

Mitigating Systems Cornerstone

a. Inspection Scope

The inspectors verified the accuracy of the licensees PI submittals listed below for the

period October 1, 2014 through September 30, 2015. The inspectors used the

performance indicator definitions and guidance contained in NEI 99-02, Rev. 7,

Regulatory Assessment Performance Indicator Guideline, and licensee procedure

SAP-1360, Rev. 2, NRC and INPO/WANO Performance Indicators, to check the

reporting of each data element. The inspectors sampled licensee event reports (LERs),

operator logs, plant status reports, CRs, and performance indicator data sheets to verify

that the licensee had properly reported the PI data.

Mitigating System Performance Index (MSPI) - Heat Removal System

MSPI - Cooling Water Systems

Safety System Functional Failures

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Review of Items Entered into the Corrective Action Program

a. Inspection Scope

As required by inspection procedure IP 71152, Identification and Resolution of

Problems, and in order to help identify repetitive equipment failures or specific human

performance issues for follow-up, the inspectors performed a daily screening of items

entered into the licensees CAP. This review was accomplished by either attending daily

screening meetings that briefly discussed major CRs, or accessing the licensees

computerized corrective action database and reviewing each CR that was initiated.

b. Findings

No findings were identified.

.2 Annual Sample Review of CR-15-00541

a. Inspection Scope

The inspectors reviewed CR-15-00541, XVG03005A-SP (A train reactor building

spray (SP) sump isolation) did not fully stroke open, in detail to evaluate the

effectiveness of the licensees corrective actions for important safety issues. The

inspectors assessed whether the issue was properly identified, documented accurately

and completely, properly classified and prioritized, adequately considered extent of

17

condition, generic implications, common cause, and previous occurrences, adequately

identified root causes/apparent causes, and identified appropriate and timely corrective

actions. Also, the inspectors verified the issues were processed in accordance with

procedure, SAP-999, Corrective Action Program, Rev. 12A.

b. Findings

Introduction: The inspectors identified a Green, non-cited violation (NCV) of 10 CFR 50,

Appendix B, Criterion V, Instructions, Procedures, and Drawings, which requires in part

that activities affecting quality shall be accomplished in accordance with procedures.

Specifically, the licensee failed to accomplish preventative maintenance diagnostic

testing in accordance with procedure, SAP-160, Motor Operated Valve Program, Rev.

1, to identify degradation of a torque switch that led to two failures of stroke time testing

of A train reactor building spray sump isolation valve, XVG03005A-SP. This also

resulted in a loss of safety function involving the SP system.

Description: On December 11, 2014, during a surveillance test of XVG03005A-SP, the

valve failed to fully open and therefore failed its respective stroke time test. The licensee

initiated condition report, CR-14-06439, to document the failure and develop corrective

actions. The inspectors reviewed the licensees subsequent investigation which

determined the torque switch for the Limitorque motor operator actuated at the 90

percent open limit switch setting. The inspectors noted that per design, the torque

switch is bypassed for the first 90 percent when the valve is opening, and then reinstated

to provide a backup to the 100 percent limit switch setting and preclude structural failure

of the valve if the limit switch fails. The licensee performed motor operator valve

actuator testing (MOVAT) and did not identify any problems. A subsequent operability

determination was completed on January 12, 2015, and concluded the valve was

operable.

On February 4, 2015, another surveillance test was conducted on XVG03005A-SP and

the valve failed to fully open as described above. The licensee initiated CR-15-00541

and subsequently completed work order, WO1501650, to increase the torque switch

setting from 1.0 to 1.5. The inspectors reviewed the licensees second operability

determination completed on February 5, 2015, and noted that the licensee determined

that since the valve failed prior to reaching the 100 percent open limit switch setting, the

required interlock logic was not met. This was not recognized during the operability

evaluation for the first failure, and a past operability evaluation would be required. The

licensee concluded that the valve would be operable but degraded with the new torque

switch setting and that increased testing would be performed to validate the new MOV

configuration. The licensee also formed a failure mode analysis (FMA) team to evaluate

both failures. The FMA teams investigation and causal evaluation concluded the

failures were due to spring pack relaxation and torque switch tolerance. The past

operability evaluation completed on March 17, 2015, concluded the valve was past

inoperable.

The licensee initiated licensee event report, LER 2015-001-00, due to their discovery of

the inoperability of the B train reactor building spray system for approximately one hour

in parallel with the aforementioned past inoperability of the A train. The inspectors

reviewed the licensees corrective action documents, LER, and respective program

documents relating to Generic Letter (GL) 89-10, Safety-Related Motor-Operated Valve

Testing and Surveillance, and the related subsequent GL 96-05, Periodic Verification of

18

Design-Basis Capability of Safety-Related Motor-Operated Valves. The inspectors

noted that SAP-160, Step 6.3.3, states, Preventive maintenance diagnostic testing shall

be performed to identify degradations. Additionally, Step 6.4.1A states, Following the

initial baseline testing, periodic preventive maintenance diagnostic testing and trending

will be used to identify degradations as part of the stations Periodic Verification

Program. The inspectors interviewed licensee staff and determined that the torque

switch setting for XVG03005A-SP in the open direction was not included within

diagnostic testing. Consequently, the inspectors concluded that the licensee had failed

to accomplish this procedure requirement which was a significant contributor to the

failures of XVG03005A-SP.

Analysis: The inspectors identified a performance deficiency (PD) for the failure to

accomplish the requirements of SAP-160 leading to two failures of XVG03005A-SP.

The inspectors reviewed IMC0612, Appendix B, Issue Screening, dated September 7,

2012, and determined the PD was more than minor because it adversely impacted the

barrier integrity cornerstone objective to provide reasonable assurance that the reactor

building or containment protects the public from radionuclide releases caused by

accidents or events and the related attribute of SSC performance. Specifically, the

licensee failed to perform preventative maintenance diagnostic testing required by SAP-

160 to identify degradation of a torque switch for XVG03005A-SP. The inspectors used

IMC 0609, Appendix A, Exhibit 3, Barrier Integrity Screening Questions, dated July 1,

2012, and IMC 0609, Appendix H, Containment Integrity Significance Determination

Process, dated May 6, 2004, and determined the finding was of very low safety

significance or Green, because the finding did not represent a significant impact to Large

Early Release Failure. The inspectors reviewed IMC 0310, Aspects Within Cross

Cutting Areas, dated December 4, 2014, and determined the cause of this finding

involved the cross-cutting area of problem identification and resolution and the aspect of

evaluation, P.2, because the licensee failed to thoroughly evaluate the failures of

XVG03005A-SP to ensure that resolutions address causes and extent of conditions

commensurate with their safety significance.

Enforcement: 10 CFR 50, Appendix B, Criterion V, requires in part that activities

affecting quality shall be accomplished in accordance with procedures. Contrary to this,

on December 11, 2014, and February 4, 2015, the licensee failed to accomplish SAP-

160 to identify degradation of a torque switch that led to two failures of XVG03005A-SP

and a resultant loss of safety function. Because the finding is of very low safety

significance and because it has been entered into the licensees CAP as CR-15-00541,

this violation is being treated as a Green NCV, consistent with Section 2.3.2 of the NRC

Enforcement Policy: NCV 05000395/2015003-02, Failure to Accomplish Procedure for

Diagnostic Testing Resulting in Valve Failures.

.3 Annual Sample Review of CR-15-03574

a. Inspection Scope

A sample for CR-14-06439 and CR-15-00541, MVG-3005A (A train reactor building

spray (SP) sump isolation valve) did not fully stroke open, was completed in the third

quarter as documented in Section 1R15 of IR 05000395/2015003. A detailed review of

this issue was performed as part of this annual sample. The inspectors reviewed CR-

15-03574, B SW traveling screen guide degradation allowing introduction of fish into

pump bay, in detail to evaluate the effectiveness of the licensees corrective actions for

19

important safety issues. The inspectors assessed whether the issue was properly

identified, documented accurately and completely, properly classified and prioritized,

adequately considered extent of condition, generic implications, common cause, and

previous occurrences, adequately identified root causes/apparent causes, and

identified appropriate and timely corrective actions. Also, the inspectors verified the

issues were processed in accordance with procedure, SAP-999, Corrective Action

Program, Rev. 12A.

b. Findings

One licensee identified violation was identified as discussed in Section 4OA7 of this

report. On March 2, 2015, the licensee found parts of a fish on the intake tubesheet of

the A EDG intercooler heat exchanger. The cause was later determined to be a

partially blocked spray nozzle associated with the screen wash system. Consequently,

the licensee began focused observations on possible causes and regular inspections for

fish within the SW pump bays. On August 4, 2015, the licensee discovered that

degradation of the B SW intake screen resulted in the introduction of fish into the B

SW pump bay and initiated CR-15-03574. Inspections by divers found corroded holes

within the SW traveling screen guides allowing the passage of fish.

The inspectors performed a historical review of the licensees CAP and other related

documentation and noted the following:

In 2003 the licensee began plans for SW traveling screen replacement projects and

obtained a proposal for screen rebuild from a vendor.

In 2004 the licensee performed a rebuild of the A SW traveling screen documented

in WO0410528. CR-04-01868 was initiated to document items found during

disassembly. The detailed description included in part that the bolting material used

for the structure of the screen had degraded to approximately 50 percent material

remaining and that the screen structure and chain guides were found with major

corrosion and wear. The licensee replaced the traveling screen structure as

documented in engineering information request, EIR80932A, dated June 18, 2004,

which stated that during the refurbishment effort, it was decided that replacement of

the travel screens was prudent.

In 2005 the licensee created a traveling screens program to implement appropriate

Preventative Maintenance (PMs) and inspections for condition monitoring as part of

the overall station equipment reliability improvement program as documented in CR-

05-04208.

In 2006 the licensee replaced the C SW traveling screen documented in

WO0601586. Documents indicating any corrosion damage were not found. The

licensee initiated WO0601588 to replace the B SW traveling screen.

In 2008 the licensee initiated CR-08-00069 to document a review of intake cooling

water blockage operational experience as a response to an industry report. An

engineering technical work record, TWRGC10203 provided an station evaluation for

the CR and noted in section 3.5 that all traveling screens are being replaced as

necessary and that WO0601588 for the B SW screen was in planning.

In 2012 the licensee initiated CR-12-03887 to document that WO0601588 was

inadvertently closed due to an incorrect routine run within the WO computer planning

program. Consequently, WO1210303 was initiated to replace WO0601588.

20

In 2014 the licensee closed out WO1210303 due to corresponding pump work taking

longer than normal. An inspection was performed by divers who did not identify any

problems. A new WO was not initiated for rebuild of the B SW traveling screen.

In 2015 following the identification of corroded holes in the B screen guides, the

licensee completed a temporary repair and initiated WO1508250 for future

rebuild/replacement.

The inspectors reviewed a sampling of videos associated with the diver inspections of

SW traveling screens and noted that the divers did not perform a complete survey of

each screen guide by removing all of the corrosion buildup along the length of the

guides.

The inspectors review of the above documents determined that the licensee was prompt

in initiating corrective action via WO0601588 to rebuild/replace the B SW traveling

screen following their observations of the corrosion damage on the A and C SW

traveling screens. However, the inspectors concluded their corrective actions for and

monitoring of B SW traveling screen were ineffective to maintain adequate functionality.

The enforcement aspects involving CR-15-03574 are discussed in Section 4OA7 of this

report.

.4 Semi-Annual Review to Identify Trends

a. Inspection Scope

The inspectors performed a review of the licensees CAP and associated documents to

identify trends that could indicate the existence of a more significant safety issue. The

review was focused on repetitive equipment issues, but also considered trends in human

performance errors, the results of daily inspector corrective action item screening

discussed in Section 4OA2.1 above, licensee trending efforts, and licensee human

performance results. This review considered the twelve-month period from January

2015 through December, 2015. Documents reviewed included licensee monthly and

quarterly corrective action trend reports, engineering system health reports,

maintenance rule documents, department self-assessment activities, and quality

assurance audit reports.

b. Findings

One licensee identified violation was identified as discussed in Section 4OA7 of this

report. In general, the licensee has identified trends and has addressed the trends

within their CAP. However, inspectors noted that Appendix R fire doors (FRA), including

some doors functioning as steam propagation barriers (SPB), control room pressure

boundaries (CRP) or CO2 boundaries (CO2), continue to have issues.

Specifically from January 2015 to December 2015, the inspectors identified the following

CRs grouped into two categories: instances where the associated door was found open

and instances where a door was declared non-functional/inoperable. Note that for the

condition reports below, no roving fire watch or compensatory measure was in place

prior to discovering a door inoperable. In some instances, the doors were repaired

immediately in lieu of a roving fire watch.

21

A similar trend was previously discussed in inspection reports 05000395/2013004,

05000395/2012005 and 05000395/2011005. The licensee previously initiated CR-13-

04356 to monitor this trend; however the inspectors note that CR-13-04356 is now

closed. The table below includes DRAB/319 which was found open by the resident

inspsectors; this issue has already been dispositioned as a Green NCV,05000395/2015002-01, Failure to Maintain Fire door/Steam Propagation Barrier in

Accordance with the Fire Protection Program Procedure.

Doors found open with no fire permit (doors not needing repairs):

Condition Description Door Inoperable

Report Function(s)

CR-15-00662 Door found unsecured by resident inspectors DRAB/319 SPB,FRA

CR-15-01015 Door held open by trash can DRSW/302 FRA

CR-15-01546 Door held open by multiple cords DRSW/203 FRA

CR-15-02078 Door alarmed and was found unsecure DRAB/514 SPB,FRA

CR-15-04950 Door found open with no fire permit DRIB/314 FRA

Doors declared non-functional/inoperable needing repairs:

Condition Description Door Inoperable

Report Function(s)

CR-15-00436 Door will not latch under its own power DRIB/409 FRA

CR-15-02198 Door latching intermittently DRIB/408 FRA

CR-15-02207 Door has broken closure arm DRAB/304A FRA

CR-15-04320 Door will not latch under its own power DRIB/318 FRA

CR-15-04529 Door will not latch under its own power DRIB/313 FRA

CR-15-04853 Door leaf very hard to close or open DRCB/302 SPB, FRA

CR-15-05068 Door not latching properly DRCB/517 CRP, FRA

CR-15-05132 Door latch broken DRAB/319 SPB, FRA

CR-15-05389 Door handle pulling away from door skin DRAB/303A SPB

CR-15-05994 Door not closing under its own power DRIB/313 FRA

CR-15-06046 Door not closing under its own power DRIB/318 FRA

CR-15-06166 Door sticking DRCB/501 SPB, FRA

CR-15-06312 Door not closing under its own power DRIB/313 FRA

CR-15-06357 Door not properly latching DRCB/304 CO2

CR-15-06565 Door latch sticking DRCB/517 CRP, FRA

4OA3 Event Followup

(Closed) LER 05000395/2015-001-00: Reactor Building Spray Isolation Valve Failure

Renders Train of Reactor Building Spray Inoperable

On March 17, 2015, a past operability evaluation conducted by the licensee concluded

that XVG3005A-SP, A train reactor building spray pump containment sump suction

isolation valve, was inoperable due to failure to fully stroke open during a surveillance

test. The licensee entered the problem into their CAP as CR-15-00541. The inspectors

conducted a review of this CR including a previous, related CR-14-06439. The

enforcement aspects are documented in Section 4OA2.2 of this report. This LER is

closed.

22

4OA6 Meetings, Including Exit

On January 21, 2016, the resident inspectors presented the integrated inspection report

results to Mr. T. Gatlin and other members of the licensee staff. The licensee

acknowledged the results of these inspections. The inspectors confirmed that inspection

activities discussed in this report did not contain proprietary material.

4OA7 Licensee-Identified Violations

The following violations of very low safety significance (Green) were identified by the

licensee and are violations of NRC requirements which meet the criteria of Section 2.3.2

of the NRC Enforcement Policy for characterization as an NCV:

10 CFR 50, Appendix B, Criterion XVI states in part that conditions adverse to quality

shall be promptly identified and corrected. Contrary to this, on August 4, 2015, the

licensee discovered degradation of the B SW intake screen allowing the introduction

of fish into the B SW pump bay. The licensee had initiated WO0601588 in 2006 to

repair/rebuild the screen but failed to correct. A review of IMC0609, Appendix A,

determined the finding was of very low safety significance (Green) because the

finding was not a design deficiency and it did not result in a loss of function. The

licensee has documented this problem in their CAP as CR-15-03574.

V.C. Summer Nuclear Station TS 6.8.1 states in part that procedures shall be

implemented for the Fire Protection Program. Contrary to the above, on March 3,

2015, April 7, 2015, October 10, 2015, and October 11, 2015, the licensee failed to

implement Fire Protection Program (FPP) procedure, FPP-25, Fire Containment,

Revision 4H, in that required fire protection permits were not obtained while

Appendix R fire doors were left open without being manned. Specifically, Appendix

R fire door DRSW/302 was found blocked open by a trash can on March 3, 2015,

Appendix R fire door DRSW/203 was found blocked open by multiple cords on

April 7, 2015, and Appendix R fire door DRIB/314 was found open on October 10,

2015 and again on October 11, 2015. The inspectors used IMC 0609, Appendix F,

Attachment 1, to determine that the finding was of very low safety significance

(Green) because smoke or heat detection was present in all adjacent fire areas.

Further, since plant personnel would be alerted in the event of a fire and the doors

could then be closed, equipment required for safe shutdown would not be impacted.

Fire door DRSW/302 was closed upon discovery, while fire permits and fire watches

were required for DRSW/203 and DRIB/314 to support ongoing plant maintenance.

The CRs for doors DRSW/302, DRSW/203 and DRIB/314 being found open are CR-

15-01015, CR-15-01546 and CR-15-04950 respectively.

ATTACHMENT: SUPPLEMENTARY INFORMATION

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

A. Barbee, Director, Nuclear Training

C. Calvert, Manager, Design Engineering

M. Coleman, Manager, Health Physics and Safety Services

N. Constance, Manager, Nuclear Training

G. Douglass, Manager, Nuclear Protection Services

D. Edwards, Supervisor, Operations

J. Garza, Supervisor, Nuclear Licensing

T. Gatlin, Vice President, Nuclear Operations

L. Harris, Manager, Quality Systems

R. Haselden, General Manager, Organizational / Development Effectiveness

R. Justice, Manager, Nuclear Operations

G. Lippard, General Manager, Nuclear Plant Operations

R. Mike, Manager, Chemistry Services

M. Moore, Supervisor, Nuclear Licensing

S. Reese, Licensing Specialist

D. Shue, Manager, Maintenance Services

W. Stuart, General Manager, Engineering Services

W. Taylor, Nuclear Licensing Engineer

B. Thompson, Manager, Nuclear Licensing

J. Wasieczko, Manager, Organization Development and Performance

D. Weir, Manager, Plant Support Engineering

R. Williamson, Manager, Emergency Services

S. Zarandi, General Manager, Nuclear Support Services

Attachment

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000395/2015004-01 URI Departure from NFPA 80-1973 for Replacement Fire

Doors.

Closed

05000395/2015001-00 LER Reactor Building Spray Isolation Valve Renders Train of

Reactor Building Spray Inoperable (Section 4OA3)

Opened and Closed

05000395/2015004-02 NCV Failure to Accomplish Procedure for Diagnostic Testing

Resulting in Valve Failures (Section 4OA2.2)

LIST OF DOCUMENTS REVIEWED

Section 1R04: Equipment Alignment

Procedures

SOP-306, Emergency Diesel Generator, Rev. 19D

SOP-112, Safety Injection System, Rev. 18G

SOP-211, Emergency Feedwater System, Rev 14E

Section 1R05: Fire Protection

Procedures

STP-128.022, FPER Related Fire System Visual Inspection, Rev 8B

STP-128.325, Heat Detector Functional Test, Rev 1

STP-728.015, Fire Hose Stations Valve Flow Check, Hose Hydrostatic Pressure Test and

Visual Inspection, Rev 5

STP-728.020, Reactor Building Fire Barrier Inspection, Rev 5B

Work Orders

WO1412322-001, RB Fire Hose Inspections

WO1412323-001, Perform RB fire penetration inspection

WO1500832-001-5, RB fire hose hydrostatic testing

WO1510467-001, Replace hose reel in RB

Section 1R06: Flood Protection Measures

Work Orders for RHR Pump area sump level switch calibrations/repairs

WO1104871

WO1108490

WO1404036

WO1406956

WO1503318

Work Orders for Safety-Related Manhole 1&2 Inspections

WO1507624, EMH-1WO1507625, EMH-2

3

Section 1R08: Inservice Inspection Activities

Procedures:

GQP-9.6, PCI Energy Services Visual Examination of Welds, Rev. 14

GQP-9.7, PCI Energy Services: Solvent Removable Liquid Penetrant Examination and

Acceptance Standards for Welds, Base Materials, and Cladding (50° - 125° F), Rev. 16

MRS-SSP-2913, Westinghouse: Reactor Vessel Head Thermocouple/Spare/CRDM Penetration

Repair at V.C. Summer Unit 1, Rev. 1

WDI-STD-1041, Wesdyne: Reactor Vessel Head Penetration Ultrasonic Examination Analysis,

Rev. 10

SAP-1100, V.C. Summer Nuclear Station, Nuclear Operations, Station Administrative

Procedure, Boric Acid Corrosion Control Program, Rev. 2

PSEG-19, V.C. Summer Nuclear Station, Plant Support Engineering, Plant Support Engineering

Guide, Boric Acid Corrosion Evaluation, Rev. 1

Drawings:

1099E34, Reactor Vessel Support Hardware, Rev. 4

E-511-219, VC Summer Reactor Building, Pipe Sleeve and Liner Plate, Rev. 9

IMS-07-057 Sht. 1, Reactor Vessel Supports, Rev. 13

IMS-07-057 Sht. 2, Reactor Vessel Supports, Rev. 1

Self-Assessments:

SA14-PE-04, Boric Acid Program, 9/15/2014

Work Orders/Work Requests:

WO 1502268-033, Install 3 Inch FLEX Piping and valve XVA09750-SF to exiting 3-inch Piping

System, 10/12/2015

WO 1404556-001, Seal Injection Header Flow Bypass Valve XVT08389-CS Shop Welds,

10/13/2015

WO 1511896-001, Reactor Vessel Support VT-3, A Hot Leg, 11/6/2015

WO 1511895-001, Reactor Vessel Support VT-3, B Hot Leg, 11/6/2015

WO 1511897-001, Reactor Vessel Support VT-3, C Cold Leg, 11/6/2015

WO 1511897-001, Reactor Vessel Support VT-3, C Hot Leg, 11/6/2015

Calculations:

DC0311E-013, Primary Shield Wall - Anchor Assembly Reactor Vessel Support (GC),

11/19/1993

Corrective Action Documents:

CR-14-01930, Special Interest Flaws Identified in CRDM Penetration Welds, dated 4/14/2014

CR-15-04864, Reactor Building Moisture Barrier, Augmented Inspection, 10/7/2015

CR-15-04843, QC Identified White Residue, C Hot Leg Sand Box Area, 10/7/2015

CR-15-0509, XVT08389-CS Seal Injection Header Flow Bypass Valve weld indication,

10/15/2015

CR-15-05024, (NRC Identified) Boric Acid Leak, Test Connection on Safety Injection Valve

XVT08879-SI, 10/14/2015

CR-15-05025, (NRC Identified) Boric Acid Leak, Test Connection Isolation Valve Safety

Injection Valve XVT08879C-SI, 10/14/2015

CR-15-05081, NRC Identified concern for white residue on the bottom of the insulation package

of the pressurizer heater nozzles, 10/16/2015

CR-15-05183, NRC Identified concern on the source of the water being directed by drip catch in

C Loop Hot Leg Nozzle area, 10/15/2015

4

NDE Examiner Qualifications:

Acuren Certification of NDT Qualification: PT (Bradford), dated 4/17/2014

Acuren Certification of NDT Qualification: PT (Sipe), dated 4/2/2014

Acuren Vision Acuity Examination Record (Bradford), dated 4/3/2014

Acuren Vision Acuity Examination Record (Sipe), dated 3/10/2014

Curtiss Wright Flow Control Company Personnel Certification: PT (Block), dated 1/2/2015

Wesdyne Certificate of Qualification: UT (Atcheson), dated 7/30/2015

Wesdyne Certificate of Qualification: UT (Svensson), dated 9/9/2015

Westinghouse Vision Acuity Examination Record (Atcheson), dated 6/19/2015

Westinghouse Vision Acuity Examination Record (Svensson), dated 9/3/2015

ML16029A112

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