RC-16-0173, Reply to Notice of Violation

Reply to Notice of Violation

ML16355A277
Person / Time
Site:	Summer
Issue date:	12/20/2016
From:	Lippard G South Carolina Electric & Gas Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RC-16-0173
Download: ML16355A277 (6)

Text

George A. Lippar-d . .

Vice President Nuclear Operations 803.345.4810 A SCANA COMPANY December 20, 2016 RC-16-0173 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555-0001

Subject:

VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) UNIT 1 DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 REPLY TO A NOTICE OF VIOLATION

References:

1. Bradley J. Davis, Acting Chief, NRC, to George Lippard, SCE&G, "NRC Problem Identification and Resolution Inspection Report 05000395/2016007 and Notice of Violation," dated November 22, 2016 [ML16327A378]

By letter dated November 22, 2016, titled "NRC Problem Identification and Resolution Inspection Report 05000395/2016007 and Notice of Violation," the Nuclear Regulatory Commission (NRC) notified VCSNS of a Traditional Enforcement Severity Level IV violation (Section 2.2.2.d). This NRC-identified violation states the licensee failed to insure that conditions adverse to fire protection were promptly corrected.

SCE&G has reviewed the description of the subject violation and will not contest the violation. Pursuant to the provisions of 10 CFR 2.201, SCE&G hereby submits a response to the alleged violation provided in Attachment I.

V. C. Summer Nuclear Station

• P. 0. Box 88 *Jenkinsville, SC

• 29065

• F(803) 941-9776

Document Control Desk CR-16-05919 RC-16-0173 Page 2 of 2 A Commitment is required to restore full compliance and is provided in Attachment II. If you have any questions about this submittal, please contact Mr. Bruce L. Thompson at (803) 931-5042.

Very truly yours, RLP/GAL/ts Attachments:

Attachment I- Reply to Notice of Violation 05000395/2016007-01 Attachment II -Commitments cc: Without Attachment unless noted K. B. Marsh NRC Resident Inspector S. A. Byrne L. W. Harris J. B. Archie Paulette Ledbetter N. S. Carns K. M. Sutton J. H. Hamilton NSRC S.M. Shealy RTS (CR-16-05919)

W. M. Cherry File (815.01)

C. Haney PRSF (RC-16-0173) (with Attachment)

S. A. Williams (with Attachment)

Document Control Desk Attachment I CR-16-05919 RC-16-0173 Page 1 of 3 VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) Unit 1 DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 ATTACHMENT I REPLY TO NOTICE OF VIOLATION 05000395/2016007-01

Document Control Desk Attachment I CR-16-05919 RC-16-0173 Page 2 of 3 NOTICE OF VIOLATION During an Inspection conducted between August 29, 2016 and October 13, 2016, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:

Operating Licensee Condition 2.C.(18) states, in part, that the South Carolina Electric &

Gas Company (SCE&G) shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment request (LAR) dated 11/15/11 (and supplements dated 1/26/12, 10/10/12, 2/1/13, 4/1/13, 10/14/13, 11/26/13, 1/9/14, 2/25/14, 5/2/14, 5/11/14, 8/14/14, 10/9/14, and 12/11/14) and as approved in the safety evaluation report dated 02/11/15.

Section 4.7.3 of the LAR states, in part, that Virgil C. Summer Nuclear Station (VCSNS) will implement a revised quality assurance program to ensure compliance with section 2.7.3 of NFPA 805 and the revised fire protection quality assurance program is based on Regulatory Position 1.7, Quality Assurance, in Regulatory Guide (RG) 1.189, Rev.

2, Fire Protection for Operating Nuclear Power Plants.

Section 1.7.8 of RG 1.189 states, in part, that conditions adverse to fire protection, such as failures, malfunctions, deficiencies, deviations, defective components, uncontrolled combustibles materials, and non-conformances are promptly identified, reported, and corrected.

Contrary to the above, as of October 13, 2016, the licensee failed to ensure that conditions adverse to fire protection as noted in a previous NRC-identified SL IV NCV,05000395/2016001-01, Failure to Implement Adequate Administrative Controls Following a Departure from NFPA 80-1973 and Provide NRC Staff Complete and Accurate Information, were promptly corrected. Specifically, the licensee failed to implement corrective actions and restore compliance in a timely manner for (1) the noncompliance with 10 CFR 50.9 to provide staff complete and accurate information and (2) fire doors DRIB/105A&B currently do not meet self-closing requirements in accordance with the current NFPA 805 licensing basis and no actions were specified in licensees corrective action program to restore compliance.

This is a Severity Level IV violation (Section 2.2.2.d)

1. Reason for the violation The station completed an Apparent Cause Evaluation in Condition Report CR-16-05919. The apparent cause was: The station maintained the position, that per GL 86-10, IMPLEMENTATION OF FIRE PROTECTION REQUIREMENTS, these doors were not required to be identified in NFPA 805 License Amendment

Document Control Desk Attachment I CR-16-05919 RC-16-0173 Page 3 of 3 Request (LAR) Appendix A. As a result, the station did not identify DRIB/105A&B in the NFPA 805 LAR Attachment A, as doors that do not have a self-closing mechanism. This difference in professional opinion also resulted in a non-compliant fire door since the new NFPA 805 License Basis, as of March 31, 2016, failed to identify DRIB/105A&B as doors without a self-closing mechanism.

2. The corrective steps that have been taken and the results achieved DRIB/105A&B were modified by installing bolted crossbars to mechanically maintain the doors in the closed position. This modification removed the human element previously relied upon to manually close the doors each time they were opened. Maintaining the doors closed in this manner provides alternate compliance with the NFPA 80 Code. This modification was implemented by ECR Minor 50585Y-46 and was completed on October 16, 2016.

3. The corrective steps that will be taken Design Engineering will update Attachment A of the NFPA 805 LAR to identify doors DRIB/105A&B as doors that have been evaluated for variances from NFPA 80 requirements. This update will then be submitted to the NRC as part of the license amendment request to resolve other issues with NFPA 805 amendment.

This corrective action step will update the stations license basis to reflect the current door configuration.

4. The date when full compliance will be achieved The NFPA 805 License Amendment Request will be submitted by April 28, 2017.

Full compliance will be achieved after the NFPA 805 License Amendment Request is approved by the NRC in a subsequent Safety Evaluation.

Document Control Desk Attachment II CR-16-05919 RC-16-0173 Page 1 of 1 VIRGIL C. SUMMER NUCLEAR STATION (VCSNS)

DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 ATTACHMENT II COMMITMENTS Commitment Due Date/Event VCSNS will submit a LAR identifying DRIB/105A&B as doors that have been evaluated for variances from NFPA April 28, 2017 80 requirements.