Text

NRC Triennial Fire Protection Inspection Report 05000395/2016010
	ML16344A014
Person / Time
Site:	Summer
Issue date:	12/05/2016
From:	Scott Shaeffer; NRC/RGN-II/DRS/EB2
To:	Lippard G; South Carolina Electric & Gas Co
References
	IR 2016010
	Download: ML16344A014 (38)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION ber 5, 2016

SUBJECT:

V.C. SUMMER NUCLEAR STATION, UNIT 1 - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000395/2016010

Dear Mr. Lippard:

On October 21, 2016, the U.S. Nuclear Regulatory Commission (USNRC) completed an inspection at your V.C. Summer Nuclear Station, Unit 1 and discussed the results of this inspection with you and other members of your staff. The team continued in-office reviews at the conclusion of the inspection and held a re-exit on December 1, 2016, with members of your staff. The inspection team documented the results of this inspection in the enclosed inspection report.

The NRC team documented three Green findings that were determined to be violations of NRC requirements. The team is also documenting two NRC identified traditional enforcement (TE)

severity level (SL) IV, and one licensee-identified (LIV) violations in applicable sections of this report. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy. If you contest the characterization of a violation or the significance, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN.:

Document Control Desk, Washington DC 20555-001; with copies to the Regional Administrator Region II; the Director, Office of Enforcement, U.S Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the V.C. Summer Nuclear Station.

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, RII, and the NRC Resident Inspector at the V.C. Summer Nuclear Station. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Scott M. Shaeffer, Chief Engineering Branch 2 Division of Reactor Safety Docket Nos.: 50-395 License Nos.: NPF-12

Enclosure:

Inspection Reports 05000395/2016010 w/Attachment: Supplemental Information

REGION II==

Docket Nos: 50-395 License Nos.: NPF-12 Report Nos.: 05000395/2016010 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 3 - October 7, 2016 (Week 1)

October 17 - October 21, 2016 (Week 2)

Inspectors: P. Braaten, Reactor Inspector J. Dymek, Reactor Inspector R. Fanner, Senior Reactor Inspector (Lead Inspector)

M. Singletary, Reactor Inspector D. Terry-Ward, Construction Inspector (Electrical)

H. Barrett, Senior Fire Protection Engineer Other: D. Strickland (Week 1, Training)

W. Satterfield (Week 1, Training)

Approved by: Scott M. Shaeffer, Chief Engineering Branch 2 Division of Reactor Safety Enclosure

SUMMARY

IR 05000395/2016010; 10/03/2016 - 10/07/2016 and 10/17/2016 - 10/21/2016; V.C. Summer

Nuclear Station Unit 1; Fire Protection - NFPA 805 (Triennial)

This report covered an announced two-week triennial fire protection inspection by a team leader, four regional inspectors, and one Office of Nuclear Reactor Regulation (NRR) observer.

Three Green non-cited violations (NCVs), two severity level (SL) IV violations, and one licensee-identified violations (LIV) were identified. 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. Cross-cutting aspects are determined using IMC 0310, Components 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 NRC's program for overseeing the safe operation of commercial nuclear power reactors as described in NUREG-1649, Reactor Oversight Process,

Revision 6, dated July 2016.

Cornerstone: Mitigating Systems

SL IV. The NRC identified a SL IV, non-cited violation (NCV) of the 10 CFR 50.48(c),

National Fire Protection Association Standard (NFPA) 805, requirements. Specifically, the team identified the licensees inability to ensure licensing basis information was maintained consistent with administrative procedures to support the NFPA 805 Section 2.2(j) and NFPA 805, Section 2.7 requirements.

The licensees failure to meet the quality requirements specified by NFPA 805 Section 2.2.

(j) and NFPA 805, Section 2.7, Program Documentation, Configuration Control and Quality was a performance deficiency (PD). This PD was determined to be more than minor because it affected the regulatory process. In this instance, the licensee failed to ensure information to support the NFPA 805 licensing commitments was controlled in the manner specified by the requirement. This information served as the basis for the NRC to perform its regulatory function and had the ability to impact the credited analysis relied upon to reach and maintain safe and stable conditions in case of a fire. As a result, the team evaluated the finding using the traditional enforcement (TE) process based upon the guidance in NRC Enforcement Policy and NRC Enforcement Guidance. The team reviewed the NRC Enforcement Guidance, Part II, Section 2.2, Actions Involving Fire Protection, to aid assessing the significance of the issue and determined the issue to be a SL IV. A cross cutting aspect was not assigned based upon the TE determination. The licensee initiated CR-16-05060, CR-16-05074, CR-16-05160, CR-16-05276, and CR-16-05278 to address the NRC concerns. (Section 1R05.06)

Green.

The NRC identified a Green, non-cited violation (NCV) of the 10 CFR 50.54(hh)(2)requirements. Specifically, the team identified aspects of the implementation strategy that were inconsistent to support the stated commitments.

The licensees failure to ensure that credited components needed to implement the strategy were adequate for circumstances consistent with the stated commitments was a performance deficiency (PD). This PD was determined to be more than minor because of the adverse impact to the Mitigating Systems cornerstone objective. Specifically, the PD had the ability of impacting the availability and reliability of the credited strategy in response to conditions postulated to meet the 10 CFR 50.54hh requirements. The team screened the issue as Green using IMC 0612, Appendix B, Issue Screening, dated September 7, 2012, and determined that further screening was necessary consistent with IMC 0612, Appendix L,

B.5.b Significance Determination Process. Dated December 24, 2009. In this instance, the finding was determined to be of Green significance since no additional strategies were impacted. The licensee initiated CR-16-05266 to address the NRC concerns. (Section 1R05.16)

Green.

The NRC identified a Green, non-cited violation (NCV) for the failure to include potentially high-risk fire scenarios in the current fire protection program. In this instance, the team identified unsealed electrical cabinets credited as being sealed.

The licensees failure to identified and assess the applicable electrical cabinet as a fire-scenario in its FSA database was a performance deficiency (PD). This PD was determined to be more than minor because of the adverse impact to the Mitigating Systems cornerstone objective. Specifically, the PD resulted in an incomplete fire risk model. The licensee performed an analysis of the performance deficiency using their fire probabilistic model and the results were that the PD represented a risk increase of <1.0E-6/year in core damage frequency and <1.0E-7/year in large early release fraction. The licensees results were reviewed by a regional senior reactor analyst (SRA). Additionally, a bounding analysis was performed by the regional SRA in accordance with NRC IMC 0609 Appendix F which concluded that the core damage frequency risk increase due to the PD was <1.0 E-6/year, a GREEN finding of very low safety significance.

The team assessed the issue consistent with IMC 0310, Aspects Within Cross Cutting Areas, dated December 4, 2014, and determined the finding to have a cross-cutting aspect of Field Presence (H.2) in the Human Performance area because the licensee did not ensure that senior managers and supervisory staff maintained the proper amount of oversight of contractors and supplemental personnel in the performance work activities relevant to fire protection program implementation. The licensee has fire watches in place as a compensatory measure and has entered this issue into their corrective action program as CR-16-05287. (Section 1R05.15)

SL IV. The NRC identified a SL IV, non-cited violation (NCV) of the 10 CFR 50.48(c),

NFPA 805, requirements. Specifically, a Risk Informed Change was made that was inconsistent with Transition License Condition 2.C.18.(c).1 which stated in part: Before achieving full compliance with 10 CFR 50.48(c), risk-informed changes to the licensee's fire protection program may not be made without prior NRC review and approval. In this instance, the team identified the licensee failed to seek or gain NRC approval for risk-informed changes that had a more than minimal risk impact to the fire protection program during the post-safety evaluation issuance period date of February 11, 2015.

The licensees failure to obtain NRC approval prior to making any changes to the 2.C.18 license requirements was a performance deficiency (PD). This PD was determined to be more than minor because it impacted the regulatory process. Specifically, the team determined that risk-informed changes made to a commitment specified by license condition 2.C.18.(c).1, which was based upon docketed correspondence from the licensee, required NRC approval. The licensee deviated from the stated commitments without NRC approval which formed the basis for the team decision to evaluate the finding using traditional enforcement (TE) based upon the guidance in NRC Enforcement Policy. The team reviewed NRC Enforcement Guidance, Part II, Section 2.2, Actions Involving Fire Protection, to assess the significance of the issue and determined the issue to be a SL IV. The licensee initiated CR-16-01490 and CR-16-05291. (Section 1R17)

Green.

The NRC identified a Green non-cited violation (NCV) of the V.C Summer Nuclear Station, Unit 1, Renewed Facility Operating License (FOL) Condition 2.C.18 requiring the licensee to implement and maintain in effect all provisions of the approved FPP that complied with 10 CFR 50.48 (c), National Fire Protection Association Standard NFPA 805.

The NRC safety evaluation report (SER) dated February 11, 2015, relied upon an adequate corrective action program to implement the NFPA 805 requirements. NFPA 805 Section 2.6.3, Corrective actions. Specifically, the team identified a failure to adequately classify and correct conditions adverse to quality (CAQ) in a timely manner.

The licensees failure to properly assign an action level commensurate to ensure corrective actions were addressed consistent with the NFPA 805, Section 2.6.3 was a PD. The PD was more than minor because, if left uncorrected, it could lead to more significant safety concern. Specifically, the inadequate application of the corrective action program can lead to deficiencies degrading SSCs which can adversely impact the FPP requirements and lead to a more significant safety concern. The finding was screened in accordance with IMC 0612, Appendix B, Issue Screening, dated September 7, 2012, and IMC 0609, Attachment 4, Characterization of Findings dated October 7, 2016. A determination was made using IMC 0609, Significance Determination Process, dated April 29, 2015. Appendix A, The Significance Determination Process for Findings At-Power, dated June 19, 2012 was applicable since the administrative controls in this instance were not associated with transient or hot work activities. Using IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, dated June 19, 2012, the finding was determined to be of very low safety significance (Green) because it did not represent an actual loss of safety function.

The team assessed the finding against the IMC 0310, Cross-cutting Aspects, dated December 4, 2014, requirements and determined that cross-cutting was applicable. In this instance, the cause of this finding was determined by the team to have a cross-cutting aspect of the Resolution component (P.3) of the Problem Identification and Resolution (PI&R) area. This was selected based upon the inability organization to adequately identify and take effective corrective actions to address issues in a timely manner commensurate administrative procedures to meet the NFPA 805, Section 2.6.3 requirements. The licensee initiated CR-16-05306 and CR-16-05160, Action 1 related to this issue. (Section 4OA2)

A. Licensee-identified Findings A violation of very low safety significance that was identified by the licensee has been reviewed by the NRC. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. The violation and corrective action tracking numbers are listed in Section 4OA7 of this report.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

1R05 Fire Protection

This report documents the results of a Triennial Fire Protection Inspection (TFPI) at the V.C. Summer Nuclear Station (VCSNS), Unit 1. The inspection was conducted in accordance with NRC Inspection Procedure (IP) 71111.05XT, Fire Protection - NFPA 805 (Triennial), issued January 31, 2013. Additionally, IP 71111.17T, Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications, issued November 13, 2015, was used to review a sample of engineering change requests (ECRs). These ECRs were associated with committed modifications that served as the foundational basis, along with other attributes, of ensuring the V.C. Summer facility achieved the fire risk reductions as the program transitioned to full compliance with the 10 CFR 50.48(c) requirements and the modified fire protection license condition. The inspection objective was to review a minimum sample of two risk-significant Fire Areas (FAs)/Fire Zones (FZs) and one deterministic (FA) to verify implementation of the VCSNS Fire Protection Program (FPP). An additional objective was to review site specific implementation of one mitigating strategy from Section B.5.b of NRC Order EA-02-026, Order for Interim Safeguards and Security Compensatory Measures (commonly referred to as B.5.b), as well as the storage, maintenance, and testing of B.5.b mitigating equipment associated with compliance requirements.

The team selected two performance based FAs and one deterministic FA based on available risk information as analyzed onsite by the team leader and a senior reactor analyst from Region II, data obtained from in-plant walkdowns regarding potential ignition sources, location and characteristics of combustibles, and location of equipment needed to achieve and maintain the reactor in a safe and stable condition. Other considerations for selecting the FAs included, the relative complexity of the post-fire safe shutdown (NSCA) procedures, information contained in FPP documents, and results of prior NRC TFPIs. In selecting the B.5.b mitigating strategy sample, the team reviewed licensee submittal letters, safety evaluation reports (SERs), licensee commitments, B.5.b implementing procedures, and previous NRC inspection reports. This inspection fulfilled the requirements of the procedure by selecting a sample of three FAs and one B.5.b mitigating strategy.

Fire Area CB-15, Upper Cable Spreading Room Based [Performance based]

Fire Area IB-22, 1B 1DB Switchgear Room (7.2kv) [Performance based]

Fire Area TB-03, Turbine Building Switchgear Room [Deterministic]

For each of the selected FAs, the team evaluated the licensees FPP against applicable NRC requirements and licensee design basis documents. Documents reviewed by the team are listed in the Attachment.

.01 Protection of Safe Shutdown Capabilities

a. Inspection Scope

The team assessed the licensees ability to, in the event of a fire, provide a safe shutdown (SSD) success path to meet the established nuclear safety goals, objectives and performance criteria. The team examined the VCSNS fire response Abnormal Operating Procedures (AOPs), DBD-FP NFPA 805, nuclear safety capability assessment (NSCA), Fire Risk Evaluations (FRE), Technical Reports, Calculations, Fire/Circuit Analysis, Fire Modeling, systems flow diagrams, and other documentation that supported the design basis, to determine if equipment required to achieve post-fire safe and stable plant conditions was properly identified and adequately protected from fire damage in accordance with the requirements of 10 CFR 50.48(c) and the VCSNS approved FPP.

The team reviewed cable routing information for a selected sample of NSCA equipment and components to verify that either the associated cables would not be damaged for the selected fire scenarios in respective FAs or the licensees analysis/risk insights determined that the fire damage would not prohibit achieving safe and stable plant conditions.

The team reviewed applicable sections of the respective administrative procedures (APs) based upon the licensing commitments and the selected FAs, to ensure the postulated fire scenarios were identified to ensure the shutdown methodology components and systems necessary to achieve and maintain safe and stable plant conditions remained available.

The team conducted interviews of plant operators to ascertain their knowledge of procedural actions needed to reach a safe and stable condition based upon fire events.

The team also reviewed recovery and defense-in-depth operator actions to verify that the operators could reasonably be expected to perform the specific actions within the time required to maintain plant parameters within specified limits. A list of NSCA components examined for cable routing is included in the Attachment.

b. Findings

a. Inspection Scope

In addition, this report also served as the basis to facilitate management of the future NFPA 805 program and Fire PRA. In essence, this document served as the foundational basis for the development of the Nuclear Safety Capability Assessment (NSCA) and also included, in part, a review and assessment of the VCSNS electrical coordination and protection calculations.

The team reviewed TR08620-312, Nuclear Safety Capability Assessment (NSCA)

Report Fire Shutdown Analysis, Rev. 1, whose purpose was to serve as the framework for the fire analysis. In this instance, the NSCA along with the TR07800-009 technical report provided, in part, the basis for the license amendment request (LAR) submitted on behalf of the V.C. Summer Nuclear Station staff to the NRC. This LAR, upon approval by the NRC, established the licensing basis for the Fire Protection Program at the V.C.

Summer Nuclear Station. As a result, applicable sections of NFPA 805, Section 2 requirements utilized the applicable information referenced within the NSCA and the DBD as the source document for meeting these standard requirements. In further analysis by the team, it was determined that the TR07800-009 was credited by the licensee in meeting the requirements specified by NFPA 805, Section 2.4.2.1, 2.4.2.2, and 2.4.2.3.

The team reviewed the fire protection program administrative procedure, SAP-0131, Fire Protection Program, Rev. 10, Section 5.5.1, which stated that technical reports used to support the FP design basis shall be maintained. At the time of the inspection, the TR07800-009 technical report was not up to date based upon the observed 9/14/11 date. The team performed interviews with applicable licensee staff and ascertained from conversations that the V.C. Summer staff had no intentions of updating technical reports or other documents since these were thought by the licensee staff to be legacy documents. The licensee personnel were under the impression that the PCCKS database was used as the licensing basis.

Based upon NRC questioning, the V.C. Summer management directed their staff to perform an internal assessment in parallel with the NRC inspection activities to ascertain if the TR07800-009 was in fact a commitment in the FP licensing basis. Based upon licensees internal review, they concluded the NRCs position was accurate in that the document was in fact a part of the V.C. Summer FP licensing basis and was required to be maintained consistent with the NFPA 805 Section 2.2.(j) and NFPA 805 Section 2.7.

NFPA 805, Section 2.7, Program Documentation, Configuration Control, and Quality requirements required the licensee to ensure sufficient documentation was available, maintained, and easily retrievable.

Analysis:

The licensees failure to meet the quality requirements specified by NFPA 805 Section 2.2.

(j) and NFPA 805, Section 2.7, Program Documentation, Configuration Control and Quality was a performance deficiency (PD). This PD was determined to be more than minor because it affected the regulatory process. In this instance, the licensee failed to ensure information to support the licensing commitments was controlled in the manner specified by the requirement. This information served as the basis for the NRC to perform its regulatory function and had the ability to impact the credited analysis relied upon to reach and maintain safe and stable conditions in case of a fire. As a result, the team evaluated the finding using traditional enforcement (TE)process based upon the guidance in NRC Enforcement Policy and NRC Enforcement Guidance. The team reviewed the NRC Enforcement Guidance, Part II, Section 2.2, Actions Involving Fire Protection, to aid assessing the significance of the issue and determined the issue to be a SL IV.

No cross-cutting attributes are applicable for TE issues.

Enforcement:

V.C. Summer Nuclear Station Unit 1, Renewed Facility Operating License Condition 2.C.18 required the licensee to implement and maintain in effect all provisions of the approved FPP that complied with 10 CFR 50.48 (c), National Fire Protection Association Standard NFPA 805, as specified in the NRC safety evaluation report (SER) dated March 22, 2013. SAP-0131.10, Fire Protection Program, required the license to ensure technical reports which were used to establish and implement the NFPA 805 Fire Protection Program requirements constituting the design basis be maintained. NFPA 805 Section 2.2.(j) stated that design requirements shall be ensured by maintaining adequate documentation and quality of analyses to maintain configuration control of the plant consistent with NFPA 805, Section 2.7. NFPA 805, Section 2.7 stated in that analyses performed to demonstrate compliance with this standard shall be documented and maintained for the life of the plant and be organized carefully so that it can be checked for adequacy and accuracy either by an independent reviewer or by the AHJ. NFPA 805, Section 2.7.2.2, Supporting Documentation, stated that detailed supporting information shall be retrievable.

Contrary to the above, since February 11, 2015, the licensee has failed to ensure the requirements specified above. Specifically, the licensees failure to meet the quality requirements specified by NFPA 805 Section 2.2.

(j) and NFPA 805, Section 2.7, Program Documentation, Configuration Control and Quality was a performance deficiency (PD) because information to support the NFPA 805 licensing commitments was not controlled in the manner specified by the requirement. In addition, these technical reports and other information served as the basis for the NRC to perform its regulatory function and had the ability to impact the credited analysis relied upon to reach and maintain safe and stable conditions in case of a fire. The licensee initiated CR-16-05060, CR-16-05074, CR-16-05160, CR-16-05276, and CR-16-05278 to address the NRC concerns. This violation is being treated as an NCV consistent with Section 2.3.2 of the Enforcement Policy. (NCV 05000395/2016010-01, Failure to Meet the Quality Requirements Specified By NFPA 805.)

.07 Communications

a. Inspection Scope

The team reviewed plant communication capabilities to evaluate the availability of systems to support plant personnel in the performance of recovery actions to achieve and maintain NSCA, as credited in the VCSNS UFSAR, Section 9.5.2, Communications. The team performed interviews and plant walkdowns with the licensees operations staff to assess the credited method of communications used to complete operator actions as specified in post-fire procedures for the selected FAs. The team reviewed the adequacy of the communication system to support plant personnel in the performance of the fire brigade duties. The team reviewed and assessed the communication systems at various locations within the plant to ensure that when relied upon, functionality would exist to support fire event notification and fire brigade firefighting activities. The team also reviewed a committed ECR for this functional area as well as the Operability/Return to Service records associated with the NFPA 805 Emergency Communication Upgrade.

Additionally, a walk-down of the Fire Brigade Storage Room was conducted to verify the material condition status of the Fire Brigades and the Operations communication equipment. The inspectors reviewed preventive maintenance and surveillance test records to verify that the communication equipment was being properly maintained and tested. The team also verified that the design and location of communications equipment would not cause a loss of communications during a fire.

b. Findings

No findings were identified.

.08 Emergency Lighting

.15 Control of Combustibles and Ignition Sources

a. Inspection Scope

The team reviewed the applicable design calculation of each fire area to determine the adequacy of ignition source selection. The team verified that VCNS was using the appropriate ignition frequency for selected components based on NUREG/CR 6850, Fire PRA Methodology for Nuclear Power Facilities, task 6. The team also reviewed any applicable frequently asked questions (FAQs) for updated guidance on counting and including ignition sources. The team also reviewed the assumptions and modeling used to determine if each fire area would have developed a hot gas layer as a result of a fire. The list of specifics calculations reviewed is included in the Attachment.

b. Findings

Introduction:

An NRC-identified Green NCV of 10 CRF 50.48(c) and NFPA 805 Section 2.4.3.2 was identified for the licensees failure to address in their fire probabilistic safety analysis (also referred to as fire probabilistic risk assessment (PRA)) the risk contributions associated with all potentially risk-significant fire scenarios for a given FA/FZ.

Description:

During review of calculation DC0780B-099, Fire Modeling: Fire Area CB15, the team noted that the licensee excluded two electrical cabinets as ignition sources. The calculation stated, in part, that these two cabinets were considered to be well-sealed and robustly secured and, per NUREG/CR-6850, could be excluded as ignition sources and therefore had no credible fire scenarios. The team conducted an independent walkdown and assessment of the two cabinets and observed that cabinet XCP6231B appeared to have unsealed penetrations on the top of the cabinet. The inspectors requested the licensee to open the cabinet utilizing their configuration control process to verify if the penetrations were un-sealed. Prior to performing this task with the inspectors, the licensee examined the cabinet and provided photographs to the inspectors of the cabinet which noted that the penetrations were clearly un-sealed. The licensee acknowledged the oversight between the calculation and actual conditions and indicated that the original decision to include cabinet as well-sealed was based on an NRC FAQ that was ultimately not approved.

At the conclusion of the inspection, the licensee further determined that XCP6231A, an additional sealed cabinet, was not accounted for consistent with the requirements.

Analysis:

The licensees failure to include potentially high risk fire scenarios by incorrectly screening out electrical cabinets that were considered as well-sealed and/or excluded without adequate technical basis was a performance deficiency (PD). This PD was more than minor because it impacted the Mitigating Systems cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to external events (i.e. fire) to prevent undesirable consequences. The finding was screened in accordance with NRC IMC 0609, Significance Determination Process, dated April 29, 2015, Attachment 4, Initial Characterization of Findings, dated October 7, 2016, which determined that, an IMC 0609, Appendix F, Fire Protection Significance Determination Process, dated September 20, 2013, review was required because it affected the ability to reach and maintain safe and stable conditions in case of a fire. However, because the finding preliminarily had a delta core damage frequency >1E-6, a detailed risk analysis was required. The licensee performed an analysis of the performance deficiency using their fire probabilistic model and the results were that the performance deficiency (PD) represented a risk increase of <1.0E-6/year in core damage frequency and <1.0E-7/year in large early release fraction. The licensees results were reviewed by a regional senior reactor analyst (SRA). Additionally, a bounding analysis was performed by the regional SRA in accordance with NRC IMC 0609 Appendix F which concluded that the core damage frequency risk increase due to the PD was <1.0 E-6/year, a GREEN finding of very low safety significance.

The team assessed the issue consistent with IMC 0310, Aspects Within Cross Cutting Areas, dated December 4, 2014, and determined the finding to have a cross-cutting aspect of Field Presence (H.2) in the Human Performance area because the licensee did not ensure that senior managers and supervisory staff maintained the proper amount of oversight of contractors and supplemental personnel in the performance work activities relevant to fire protection program implementation.

Enforcement:

V.C. Summer Nuclear Station Unit 1, Renewed Facility Operating License Condition 2.C.18 required the licensee to implement and maintain in effect all provisions of the approved FPP that complied with 10 CFR 50.48 (c), National Fire Protection Association Standard NFPA 805, as specified in the NRC safety evaluation report (SER) dated March 22, 2013. NFPA 805 Section 2.4.3.2 stated that the probabilistic safety assessment (Fire PRA) evaluation shall address the risk contribution associated with all potentially risk-significant fire scenarios.

Contrary to the above, since February 11, 2015, the licensee failed to address the risk contribution of all ignition sources associated with potentially risk significant fire scenarios during the initial fire scenario development resulting in potentially underestimating post-fire safe shutdown risk. Specifically, the licensee did not include cabinet XCP6231B or cabinet XCP6231A as an ignition source leading to a credible fire scenario in FA CB15. As a result, the impact to the applicable target cables was not postulated nor analyzed per the program requirements. The licensee has entered this into their corrective action program as CR-16-05287 and CR-16-05591. As a result, this violation is being treated as an NCV consistent with Section 2.3.2 of the Enforcement Policy. (NCV 05000395/2016010-02, Failure to Identify Ignition Sources During Initial Fire Scenario Development.)

.16 B.5.b Mitigating Strategy

a. Inspection Scope

The team reviewed on a sample basis, the licensees preparedness to handle large fires or explosions by reviewing an applicable strategy which credited a portable supply mechanism (PDFP). The team verified the licensees ability to meet the requirements of 10 CFR 50.54 (hh)(2) and their B.5.b related license conditions by reviewing procedures to ensure that they were being maintained and were adequate. The team performed walkdowns with licensee staff to ensure that credited actions, if any, the actions were feasible. The team assessed if required equipment was properly staged. The team reviewed applicable records to determine if staff were properly trained.

The team also reviewed maintenance and testing records of equipment to ensure that the equipment was being maintained consistent with vendor recommendations and licensee requirements.

b. Findings

Introduction:

The team identified a performance deficiency based upon the licensees inability to meet the 50.54(hh) requirements. Specifically, the team identified inconsistencies between licensee calculations and actual equipment used to implement the mitigating strategy.

Description:

The team conducted a walk down of the selected mitigating strategy used to meet the 10 CFR 50.54(hh) requirements. During the walk down, the team observed the licensee testing a component that was used for the selected strategy. It was noted that hardware for an applicable component needed for the strategy did not meet the design specifications required to successfully implement the credited strategy being assessed by the team. Specifically, the licensee did not install the correct hardware in accordance with their calculation assumptions credited for the mitigating strategy. When the team questioned the licensee about the discrepancy, they agreed that the hardware should meet the design specifications determined by the calculations. The licensee took immediate corrective actions and replaced the component to address the issue.

Analysis:

The licensees failure to ensure the operability of credited components needed to implement the mitigating strategy consistent with the stated commitments was a performance deficiency (PD). This PD was determined to be more than minor because of the adverse impact to the Mitigating Systems cornerstone objective. Specifically, the PD had the ability of impacting the availability and reliability of the credited strategy in response to conditions postulated to meet the 10 CFR 50.54(hh) requirements. The team screened the issue as Green using IMC 0612, Appendix B, Issue Screening, and determined that further screening was necessary consistent with IMC 0612, Appendix L, B.5.b Significance Determination Process, dated December 24, 2009. In this instance, the finding was determined to be of Green significance since no additional strategies were impacted.

No cross-cutting was assigned since this was not indicative of current performance. The licensee took immediate corrective actions to correct the issue.

Enforcement:

V.C. Summer Nuclear Station Unit 1, Renewed Facility Operating License required the licensee to implement and maintain in effect all provisions of the 10 CFR 50.54hh requirements based upon submittals to NRC.

Contrary to the above, since at least December 2014, the applicable component identified by the team failed to meet the licensing basis commitments specified by 10 CFR 50.54(hh)(2) requirements. Specifically, since the licensee has failed to ensure the requirements specified above were adequately implemented there was reasonable assurance that the strategy would not have been successful had and actual event occurred. As a result, the licensee initiated CR-16-05266 to address this deficiency.

This violation is being treated as an NCV consistent with Section 2.3.2 of the Enforcement Policy. (NCV 05000395/2016010-03, Failure to Meet the 50.54hh requirements.)

1R17 Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications

a. Inspection Scope

The team reviewed various engineering change requests (ECRs) credited with being completed to ensure the NFPA 805 program commitments were satisfied. The team conducted interviews of licensee personnel with responsibility of development or implementation of applicable ECRs to gain insights on package development and screening against the FPP requirements. The team performed walk downs of applicable areas of the plant based upon the completed modifications, to sample the implementation aspects. The team reviewed applicable drawings and procedures relevant to the facility changes to ascertain if changes were translated to applicable documentation and to assess the implementation after completion.

b. Findings

Introduction:

An NRC identified SL IV, NCV of the 10 CFR 50.48(c), NFPA 805, requirements was identified. Specifically, the team identified that the licensee made risk-informed changes but failed to seek or gain NRC approval for the changes made to the fire protection program during the post-safety evaluation issuance period date of February 11, 2015.

Description:

The NRC issued to the VCSNS an amendment to its fire protection operating license on February 11, 2015. This change to the 2.C.18 license condition required that the licensee meet all attributes of the license based upon the stated commitments and included Transition License Condition 2.C.18.(c).1 which stated:

Before achieving full compliance with 10 CFR 50.48(c), risk-informed changes to the licensee's fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact. Per the commitments specified by Section 2.7.3 the licensee had requirements that were to be implemented by three specific periods. These times were 180 days after the February 11, 2015 date; December 31, 2015; and March 31, 2016.

In this example, the licensee failed to meet the commitments to support the December 31, 2015 date. Though the licensee provided a condition report the stating that modifications were not implemented consistent with commitments, the team determined after discussions that the basis for reaching this conclusion was based the use fire risk evaluations and other PRA tools. In some instances during the transition period, the licensee made a determination that committed modifications specified in correspondence to the NRC were not needed after the initial commitment date. This process was called into question by the team since the FREs were being updated at the time of the inspection. In addition, the licensee identified to inspectors that the PRA commitment was also not met, as documented in section 4OA7 of this report. Though the licensee documented the failure to meet the requirements, the result of missing the stated the modification commitments and making changes in the manner specified above constituted a de-facto change to the license. At the time of the inspection, the licensee had not recognized in SER Section 2.4.2, License Conditions, that changes such as these constituted a risk-informed self-approval methodology.

In addition to the above items, on October 20, 2016 the licensee provided to the NRC team a condition report stating that additional modifications that were committed to in RC-11-0149 were also not implemented. The team viewed this as an additional instance of a change to the licensing basis and inconsistent with license condition. The licensee concluded that a license amendment request would be needed since the medications have a more than minimal increase to plant risk. In these instances, the plant licensing basis and the as built plant condition needed to be same and wasnt. As a result, these changes were deemed as one that had the potential to impede the regulatory process.

Analysis:

The failure to seek or obtain approval to deviate from the stated requirements was a performance deficiency (PD). This PD was determined to be more than minor because it impacted the regulatory process. Specifically, the team determined that the licensee made changes which were inconsistent to commitments specified by the 2.C.18(c).1 license condition. This license condition was based upon docketed correspondence from the licensee to the NRC which established the basis for fire protection program implementation. As a result of the deviations, the licensee made a self-approved risk-informed change prior to full-implementation inconsistent from the requirements of the license. This formed the basis for the team to evaluate the finding using traditional enforcement (TE) based upon the guidance in NRC Enforcement Policy. The team reviewed NRC Enforcement Guidance, Part II, Section 2.2, Actions Involving Fire Protection, to assess the significance of the issue and determined the issue to be a SL IV.

No cross-cutting aspects are applicable to TE violations.

Enforcement:

V.C. Summer Nuclear Station Unit 1, Renewed Facility Operating License Condition 2.C.18 required the licensee to implement and maintain in effect all provisions of the approved FPP that complied with 10 CFR 50.48 (c), National Fire Protection Association Standard NFPA 805, as specified in the NRC safety evaluation report (SER) dated February 11, 2015. RG 1.189, Fire Protection for Nuclear Power Plants, Rev. 2 defines the licensing basis as the set of NRC requirements applicable to a specific plant based on the commitments made via a docketed process. SAP-0131.10, Fire Protection Program, required the license to ensure the design basis be maintained for effective fire protection program implementation.

Contrary to the above, since December 31, 2015 the licensee has failed to ensure the requirements specified above. The licensees failure to obtain NRC approval prior to making any changes that had a more than minimal increase to the 2.C.18 license requirements was a performance deficiency (PD). This PD was determined to be more than minor because the team determined that risk-informed changes made to a commitment specified by license condition 2.C.18.(c).1, which was based upon docketed correspondence from the licensee, required NRC approval. This lack of recognition was from weaknesses in a translation of licensee commitments specified by the NRC to a validated process. In addition, changes to the FREs and PRA model were ongoing and relevant to this issue since this formed the basis for the decision-making. The licensee initiated CR-16-01490 and CR-16-05291 to address the issue. This violation is being treated as an NCV consistent with Section 2.3.2 of the Enforcement Policy. (NCV 05000395/2016010-04, Failure to seek or gain approval for risk-informed changes constituted a self-approved change which is inconsistent with the NFPA 805 requirements.)

OTHER ACTIVITIES

4OA2 Problem Identification and Resolution

a. Inspection Scope

The team reviewed recent independent licensee audits for thoroughness, completeness and conformance to FPP requirements. Guidance for the independent audits are contained in Regulatory Guide 1.189, Fire Protection for Operating Nuclear Power Plants, and Generic Letter 82-21, Technical Specifications for Fire Protection Audits.

The team also reviewed other CAP documents, including completed elective actions and corrective actions documented in selected CRs and operating experience program documents, to ascertain whether industry identified fire protection issues (actual or potential) affecting V.C. Summer Unit 1 were appropriately entered into the CAP for resolution. Items included in the operating experience program effectiveness review were NRC information notices, regulatory guides, regulatory issues summary, industry or vendor generated reports of defects and non-compliances submitted pursuant to 10 CFR Part 21, and vendor information letters. The team assessed the licensees ability to identify issues related to the FPP and FAs selected at an appropriate threshold, appropriately classifying these issues per their site administrative procedures and entering these issues into the corrective action program consistent with as required by NFPA 805 section 2.6. The team reviewed licensing basis documentation such as 10 CFR 50.48(a), 10 CFR 50.48(c), NFPA 805, 2001Edition, licensing submittals, LAR, and the NRC NFPA 805 Safety Evaluation Report (SER) to verify that corrective actions met the licensing commitments. The team reviewed Safety Evaluation (SE) report section 3.7 (NFPA 805 Monitoring),which states if the established levels of availability, reliability or performance are not met, appropriate corrective actions to return to the established levels shall be implemented. Monitoring shall be continued to ensure that the corrective actions are effective.

b. Findings

Introduction:

An NRC-identified Green NCV of V.C. Summer Nuclear Station Unit 1 Renewed Facility Operating License Condition 2.C.18 and NFPA 805 was identified for the licensees failure to adequately classify and correct conditions adverse to quality in a timely manner. Specifically, NFPA 805 Section 2.6.3, Corrective actions, stated that if the established levels of availability, reliability, or performance are not met, appropriate corrective actions to return to the established levels shall be implemented.

Description:

The team selected a sample of NFPA 805 items specified as being open as documented in the licensees corrective action program. The goal was to verify that the appropriate corrective actions to return deficiencies to the established levels were implemented, to verify that the corrective actions were commensurate with the significance of the issue and to verify if the corrective actions were implemented by the licensee. The team reviewed USNRC letter to SCE&G (docket No. 50-395, dated July 26, 2012) which requested the licensee provide additional information (RAI) as described in NSCA RAI 14. The request stated, in part, Describe whether the 13 open items in Appendix C, Circuit Analysis Opens Table of NFPA 805 and Fire PRA Circuit Analysis, Task 4.4 TR07800-009, have been entered into the CAP and whether they have been completed. The SCE&G response, contained in (RC-12-0142, dated October 10, 2012) stated that the 13 open items in Appendix C, Circuit Analysis Open Table have been addressed acceptably and are considered closed. Within proximity to this statement, a reference to CR-12-02306 was specified by the licensee.

The team reviewed site administrative procedure SAP-0131, Fire Protection Program, Rev. 10, section 1.1 which stated the purpose of this procedure is to define the V. C Summer Nuclear Station (VCSNS) Unit 1 Nuclear Exclusion area fire protection program (FPP) identified in section 3.16.E the administrative procedure SAP-0999 Corrective Action Program.

The team reviewed procedure SAP-0999, section 4.1.1.A which stated Corrective actions are actions that have or will be taken to correct a deficient or degraded condition.

Within the context of the SAP-0999 procedure, the licensee specified several action levels which are used to ensure timely and adequate corrective action of the respective issue. In this instance, the 2012 CR initiated by the licensee per the licensee was designated with an Action level 3, which is considered and elective action. According to SAP-0999, Section 4.1.1.B of the procedure, elective actions are actions that correct minor degradation to SSCs or related processes. This action level is not identified as one associated with CAQs. In this instance, by defining the corrective action to address the open items, which was questioned as a result of the transition to NFPA 805, as an Action level of 3 the team concluded the licensee did not consider this to be a condition adverse to quality or a degraded condition that could impact the FPP commitments.

This was based upon further review by the team of procedure SAP-0999, Enclosure B.

The following annotates the basis of applicable action levels:

Action level 3 - routine actions (RA), also considered elective actions, are actions that do not directly address the correction of a CAQ or the identified cause;

Action level 4 - tracking actions are Actions that are used to track items such as Actions items from meetingsThey may or may not get implemented; and

Action Level 5 - Long-Term Corrective Actions (LTCA), these items are long term actions (equal to or greater than 365 days that are considered Corrective actions. These require implementation through plant change process.

The team reviewed SAP-0999, Enclosure A, which stated that Category 3 CRs are categorized as a non-Condition Adverse to quality. As a result of identifying this as an elective action, the team determined that the underlying was not recognized as a condition adverse to quality (CAQ) or meet the intent of timeliness consistent with NFPA 805, Section 2.6.3.

To support the timeliness assertions, the team observed that licensee documentation stated that the actions to address open items specified in TR07800-009 were entered into the corrective action program as CR-12-02306, with an anticipated completion date for Action 1 and 2 the first quarter of 2013. The team observed that CR-12-02306 had a creation date of 06/05/12 and was given Category 3 assignment. In addition, action items 001 and 002, which were focused on correcting the Open items, were categorized as a Level 4. Both of the Action levels were changed from 4 to 3 per the Corrective Report Review team (CRRT) on 10/9/14. At the time of the inspection, the team noted the last updates for Actions 001 and 002 were entered on 10/04/16 which stated, This item is or mostly complete - separate items being reviewed and most if not all of these items may be complete, reviewing several separate documents. Based upon these observations this is an additional instance where the licensee failed to identify the issue adequately.

Analysis:

The licensees failure to ensure the implementation of corrective actions were implemented consistent with the NFPA 805, Section 2.6.3 was a PD. The PD was more than minor because, if left uncorrected, it could lead to more significant safety concern.

Specifically, the inadequate application of the corrective action program can lead to deficiencies degrading SSCs which can adversely impact the FPP requirements. The finding was screened in accordance with IMC 0612, Appendix B and IMC 0609, 4, Phase 1 - Initial Screening and Characterization of Findings worksheet.

A determination was made using IMC 0609, Significance Determination Process, dated June 2, 2011. Appendix A, The Significance Determination Process for Findings At-Power, dated June 19, 2012 was applicable since the administrative controls in this instance were not associated with transient or hot work activities. Using IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the finding was determined to be of very low safety significance (Green) because it did not represent an actual loss of safety function.

The team assessed the finding against the IMC 0310, Cross-cutting Aspects, requirements and determined that cross-cutting was applicable. In this instance, the cause of this finding was determined by the team to have a cross-cutting aspect of the Resolution component (P.3) of the Problem Identification and Resolution (PI&R) area.

This was selected based upon the inability organization to adequately identify and take effective corrective actions to address issues in a timely manner commensurate administrative procedures to meet the NFPA 805, Section 2.6.3 requirements.

Enforcement:

V.C. Summer Nuclear Station, Unit 1 Renewed Facility Operating License Condition 2.C.18 required the licensee to implement and maintain in effect all provisions of the approved FPP that complied with 10 CFR 50.48 (c), National Fire Protection Association Standard NFPA 805. The NRC safety evaluation report (SER) dated February 11, 2015 relied upon an adequate corrective action program to implement the NFPA 805 requirements. SAP-0999, Corrective Action Program, stated in pat that the licensee would adequately identify, evaluate, and verify resolution of conditions that are adverse or potentially adverse to quality. SAP-0131, Fire Protection Program, Rev 10 references the SAP-0999 procedure as being applicable for implementation of the FPP requirements adequately. NFPA 805 Section 2.6.3, Corrective actions, stated that if the established levels of availability, reliability, or performance are not met, appropriate corrective actions to return to the established levels shall be implemented.

Contrary to the above, since February 11, 2015 the licensee failed to adequately meet the corrective action program requirements by failing to properly assign an action level commensurate to issue could lead to more significant safety concern. Specifically, the failure to ensure that actions are annotated accurately and appropriate corrective actions are implemented is the fundamental basis for meeting the established standards by the NRC as recognized by NSCA RAI 14. The lack of an adequate designation also calls into question the effectiveness of the program to correct issues and if they were actually corrected per NFPA 805, Section 2.6.3 and closed as stated in a timely manner.

Because the finding was of very low safety significance (Green) and was entered into the licensees CAP as CR-16-05306 and CR-16-05160, Action 1, this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. This violation is identified as05000395/2016010-05, (Failure to meet corrective action requirements consistent with NFPA 805 Section 2.6.3.) Specific documents reviewed by the team are listed in the Attachment.

4OA6 Meetings, Including Exit

On October 21, 2016, the inspection team leader presented the preliminary inspection results to Mr. G. Lippard and other members of the licensees staff. The licensee acknowledged the results. The team had further communications with the licensee and headquarters personnel after the exit date which resulted in a re-exit on December 1, 2016. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

4OA7 Licensee-Identified Violations

The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as a non-cited violation.

.1 The licensee identified an example of a failure to meet the 2.C.18 commitments. The

licensee was required to implement applicable aspects of the NFPA 805 requirements in order to achieve the risk reductions specified in RG 1.174, An Approach for Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis. To accomplish this, the licensee committed to various changes to the facility. In this instance, the licensee committed to ensure the PRA developed to meet the 2.C.18 requirements was completed consistent with Table S-2, Implementation Item 22 and SER Section 2.7.2.

Contrary to the above, the licensee failed to implement the stated requirement specified by license condition 2.C.18 and docketed correspondence from the licensee to the NRC.

Specifically, the licensee deviated from the stated commitment without NRC approval by which formed the basis for the team to evaluate the finding using traditional enforcement (TE) based upon the guidance in NRC Enforcement Policy. The team reviewed the NRC Enforcement Guidance, Part II, Section 2.2, Actions Involving Fire Protection, to aid assessing the significance of the issue and determined the issue to be a SL IV.

A cross cutting aspect was not assigned based upon the TE determination.

Based upon the identification by the licensee, the issues have been entered into the licensees corrective action program as CR-16-00321, CR-16-01132, CR-16-01602, CR-16-04828, and CR-16-04829.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

B. Bennett, Licensing Engineer, Nuclear Licensing

C. Calvert, Manager, Design Engineering

G. Douglass, Manager, Nuclear Protection Services

D. Edwards, Supervisor, Operations

J. Garza, Supervisor, Nuclear Licensing

T. Gatlin, Vice President, Nuclear Support Services

J. Gathers, Design Engineering

B. Gerwe, Contractor, Jensen-Hughes

L. Harris, Manager, Quality Systems

R. Haselden, General Manager, Organizational / Development Effectiveness

R. Justice, General Manager, Nuclear Plant Operations

L. Kachnik, Probability & Risk Assessment

M. Kammer, Manager, Emergency Response

G. Lippard, Vice President, Nuclear Plant Operations

G. Loignon, Supervisor, Probability and Risk Assessment

T. Lontz, Contractor, Jensen-Hughes

D. Mauldin, Design Engineering

M. Moore, Supervisor, Nuclear Licensing

R. Ray, Manager, Maintenance

R. Perry, Licensing Engineer, Nuclear Licensing

D. Shue, Manager, Nuclear Operations

W. Stuart, General Manager, Engineering Services

W. Taylor, Nuclear Licensing Engineer

B. Thompson, Manager, Nuclear Licensing

M. Torres, Operations

D. Weir, Manager, Plant Support Engineering

R. Williamson, Manager, Emergency Services

S. Zarandi, General Manager, Nuclear Support Services

NRC Personnel

J. Reece, Senior Resident Inspector, V.C. Summer Resident Office

E. Coffman, Resident Inspector, V.C. Summer Resident Office

H. Barrett, Senior Fire Protection NRR

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000395/2016010-01 SL IV Failure to Meet the Quality Requirements Specified By NFPA 805 (Section 1RO5.06)

05000395/2016010-02 NCV Failure to identify unsealed cabinet Specified by NFPA 805 Section 3.3.1.2(1) (Section 1RO5.15)

05000395/2016010-03 NCV Failure to ensure credited equipment to support the 50 54hh requirements were adequate (Section 1RO5.16)

05000395/2016010-04 SL IV Failure to seek or gain approval for risk-informed changes constituted a self-approved change which is inconsistent with the NFPA 805 requirements (Section 1R17)

05000395/2016010-05 NCV Failure to meet corrective action requirements consistent with NFPA 805 Section 2.6.3) (Section 4OA2)

SUPPLEMENTAL INFORMATION Section 1R05.06: List of NSCA Components Inspected Component Identification Description INI00033 Source Range Instrumentation MVG-8000B Relief PORV CP - A Charging Pump A IFV-3556-EF TDEFP Valve XFER FCV-122 Charging Flow Control Valve XFER LCV-459 Steam Valve to TDEFP Circuit RCC42A Cable Circuit RCC44A Cable

LIST OF DOCUMENTS REVIEWED