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{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION  
{{#Wiki_filter:UNITED STATES
REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257
                                NUCLEAR REGULATORY COMMISSION
  November 22, 2016  
                                              REGION II
                            245 PEACHTREE CENTER AVENUE NE, SUITE 1200
Mr. George Lippard Vice President South Carolina Electric & Gas Company  
                                      ATLANTA, GEORGIA 30303-1257
Virgil C. Summer Nuclear Station  
                                        November 22, 2016
P.O. Box 88  
Mr. George Lippard
Jenkinsville, SC 29065  
Vice President
South Carolina Electric & Gas Company
Virgil C. Summer Nuclear Station
P.O. Box 88
Jenkinsville, SC 29065
SUBJECT: VIRGIL C. SUMMER NUCLEAR STATION - NRC PROBLEM IDENTIFICATION
              AND RESOLUTION INSPECTION REPORT 05000395/2016007 AND NOTICE OF
              VIOLATION
Dear Mr. Lippard:
On October 13, 2016, the Nuclear Regulatory Commission (NRC) completed a problem
identification and resolution inspection at your Virgil C. Summer Nuclear Station. On
September 15, 2016, the NRC inspection team discussed the preliminary results of this
inspection with you and other members of your staff. Following completion of additional
inspection of the findings, a re-exit was held by telephone with Mr. R. Justice of your
staff on October 13, 2016, to discuss the final results of the inspection. The results of
this inspection are documented in the enclosed inspection report.
The NRC inspection team reviewed the stations corrective action program and the stations
implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating,
and correcting problems, and to confirm that the station was complying with NRC regulations
and licensee standards for corrective action programs. The team identified two findings in
problem identification, implementation of the process for prioritizing and evaluating these
problems, and the effectiveness of corrective actions taken to resolve these problems.
The team also evaluated the stations processes for use of industry and NRC operating
experience information and the effectiveness of the stations audits and self-
assessments. Based on the samples reviewed, the team determined that your staffs
performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating
experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of
these areas adequately supported nuclear safety.
Finally the team reviewed the stations programs to establish and maintain a safety-conscious
work environment, and interviewed station personnel to evaluate the effectiveness of these
programs. Based on the teams observations and the results of these interviews the team found
no evidence of challenges to your organizations safety-conscious work environment. Your
employees appeared willing to raise nuclear safety concerns through at least one of the several
means available.


SUBJECT: VIRGIL C. SUMMER NUCLEAR STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000395/2016007 AND NOTICE OF
G. Lippard                                            2
VIOLATION
The team documented one NRC-identified finding of very low safety significance (Green) and
one citied Severity Level (SL) IV violation in this report. Both of these findings involved
Dear Mr. Lippard:  
violations of NRC requirements. The NRC evaluated these violations in accordance Section
On October 13, 2016, the Nuclear Regulatory Commission (NRC) completed a problem
2.3.2.a of the NRC Enforcement Policy, which appears on the NRCs Web site at
identification and resolution inspection at your Virgil C. Summer Nuclear Station. On
http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. We determined that one
September 15, 2016, the NRC inspection team di
violation did not meet the criteria to be treated as an NCV because compliance has not been
scussed the preliminary results of this inspection with you and other members of your staff. Following completion of additional inspection of the findings, a re-exit was held by telephone with Mr. R. Justice of your staff on October 13, 2016, to discuss the final results of the inspection. The results of  
restored. Specifically, the licensee failed to ensure that conditions adverse to fire protection
this inspection are documented in the enclosed inspection report.  
was promptly corrected as noted in a previous NRC-identified Severity Level IV (SLIV) 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. As
of the end of this inspection, compliance had not been restored.
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice of Violation (Notice) when preparing your response. If you have additional
information that you believe the NRC should consider, you may provide it in your response to
the Notice. The NRCs review of your response to the Notice will also determine whether further
enforcement action is necessary to ensure your compliance with regulatory requirements.
If you contest the violations or the significance of the violations, 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 V.C. Summer station.
If you disagree with a cross-cutting aspect assignment or a finding not associated with a
regulatory requirement 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 V.C. Summer 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/
                                                Bradley J. Davis, Acting Chief
                                                Reactor Projects Branch 7
                                                Division of Reactor Projects
Docket No.: 50-395
License No.: NPF-12
Enclosures:
1.       Notice of Violation
2.       Inspection Report 05000395/2016007
          w/Attachment: Supplemental Information
cc Distribution via ListServ


The NRC inspection team reviewed the station's corrective action program and the station's
implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs.  The team identified two findings in
problem identification, implementation of the process for prioritizing and evaluating these
problems, and the effectiveness of corrective actions taken to resolve these problems. 
The team also evaluated the station's processes for use of industry and NRC operating experience information and the effectiveness of the station's audits and self-
assessments.  Based on the samples reviewed, the team determined that your staff's
performance in each of these areas adequately supported nuclear safety. 


   
  ML16327A378                 SUNSI REVIEW COMPLETE     FORM 665 ATTACHED
The team also evaluated the station's processes for use of industry and NRC operating experience information and the effectiveness of the station's audits and self-assessments.  Based on the samples reviewed, the team determined that your staff's performance in each of
OFFICE             RII:DRP       RII:DRP       RII:DRP         RII:DRP         RII:DRP       RII:EICS     RII:DRP
these areas adequately supported nuclear safety.
SIGNATURE         NLS2 via email RJR1 via email RCT1 via email   CDJ1 via email CBS via email /RA/         /RA/
 
NAME               NStaples       RRodriguez     SNinh           CDykes         SSeaton       MKowal       BDavis
DATE                   11/1/2016     11/22/2016     11/1/2016       11/ /2016     11/22/2016     11/22/2016   11/22/2016
Finally the team reviewed the station's programs to establish and maintain a safety-conscious
E-MAIL COPY?         YES   NO   YES     NO   YES       NO    YES     NO     YES     NO                 YES     NO
work environment, and interviewed station personnel to evaluate the effectiveness of these programs.  Based on the team's observations and the results of these interviews the team found
        
no evidence of challenges to your organization's safety-conscious work environment.  Your employees appeared willing to raise nuclear safety concerns through at least one of the several
Letter to George Lippard from Bradley J. Davis dated November 22, 2016
means available.   
SUBJECT: VIRGIL C. SUMMER NUCLEAR STATION - NRC PROBLEM IDENTIFICATION
G. Lippard 2 The team documented one NRC-identified finding of very low safety significance (Green) and one citied Severity Level (SL) IV violation in this report.  Both of these findings involved
            AND RESOLUTION INSPECTION REPORT 05000395/2016007 AND NOTICE OF
violations of NRC requirements.  The NRC evaluated these violations in accordance Section 2.3.2.a of the NRC Enforcement Policy, which appears on the NRC's Web site at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html.  We determined that one violation did not meet the criteria to be treated as an NCV because compliance has not been
            VIOLATION
restored.  Specifically, the licensee failed to ensure that conditions adverse to fire protection
DISTRIBUTION:
was promptly corrected as noted in a previous NRC-identified Severity Level IV (SLIV) 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."  As of the end of this inspection, compliance had not been restored.
S. Price, RII EICS
 
S. Maxey, RII EICS
OE Mail
You are required to respond to this letter and should follow the instructions specified in the
RIDSNRRDIRS
enclosed Notice of Violation (Notice) when preparing your response. If you have additional information that you believe the NRC should consider, you may provide it in your response to the Notice.  The NRC's review of your response to the Notice will also determine whether further
PUBLIC
enforcement action is necessary to ensure your compliance with regulatory requirements.
 
If you contest the violations or the significance of the violations, 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 V.C. Summer station.
 
If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement 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 V.C. Summer 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/        Bradley J. Davis, Acting Chief  Reactor Projects Branch 7
Division of Reactor Projects
   
Docket No.: 50-395
License No.: NPF-12
 
Enclosures:  1. Notice of Violation 2. Inspection Report 05000395/2016007  w/Attachment:  Supplemental Information
cc Distribution via ListServ 
 
  ML16327A378                   SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DRP RII:DRP RII:DRP RII:DRP RII:DRP RII:EICS RII:DRP SIGNATURE NLS2 via email RJR1 via email RCT1 via email CDJ1 via email CBS via email /RA/ /RA/ NAME NStaples RRodriguez SNinh CDykes SSeaton MKowal BDavis DATE 11/1/2016 11/22/2016 11/1/2016 11/   /2016 11/22/2016 11/22/2016 11/22/2016 E-MAIL COPY?     YES NO       YES NO      YES NO       YES NO       YES NO        YES NO     
  Letter to George Lippard from Bradley J. Davis dated November 22, 2016  
SUBJECT: VIRGIL C. SUMMER NUCLEAR STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000395/2016007 AND NOTICE OF VIOLATION  
DISTRIBUTION: S. Price, RII EICS S. Maxey, RII EICS OE Mail RIDSNRRDIRS  
 
PUBLIC  
RidsNrrPMStLucie Resource
RidsNrrPMStLucie Resource
 
  NOTICE OF VIOLATION
South Carolina Electric and Gas Company (SCE&G)  Docket No. 50-395
Virgil C. Summer Nuclear Station, Unit 1    License No. NPF-12 
         
During an NRC 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  
                                        NOTICE OF VIOLATION
licensee amendment request (LAR) dated 11 /15/11 (and supplements dated 1/26/12, 10/10/12,  
South Carolina Electric and Gas Company (SCE&G)                                  Docket No. 50-395
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.  
Virgil C. Summer Nuclear Station, Unit 1                                        License No. NPF-12
During an NRC inspection conducted between August 29, 2016 and October 13, 2016, a
Section 4.7.3 of the LAR states, in part, that Virgil C. Summer Nuclear Station (VCSNS) will  
violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy,
implement a revised quality assurance program to ensure compliance with section 2.7.3 of  
the violation is listed below:
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." 
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
Section 1.7.8 of RG 1.189 states, in part, that conditions adverse to fire protection, such as  
licensee amendment request (LAR) dated 11 /15/11 (and supplements dated 1/26/12, 10/10/12,
failures, malfunctions, deficiencies, deviations, defective components, uncontrolled  
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
combustibles materials, and non-conformances are promptly identified, reported, and corrected.  
12/11/14) and as approved in the safety evaluation report dated 02/11/15.
  Contrary to the above, as of October 13, 2016, the licensee failed to ensure that conditions  
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-
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  
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  
80-1973 and Provide NRC Staff Complete and Accurate Information, were promptly corrected.
accurate information and (2) fire doors DRIB/105A&B currently do not meet self-closing  
Specifically, the licensee failed to implement corrective actions and restore compliance in a
requirements in accordance with the current NFPA 805 licensing basis and no actions were  
timely manner for (1) the noncompliance with 10 CFR 50.9 to provide staff complete and
specified in licensee's corrective action program to restore compliance.  
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
This is a Severity Level IV violation (Section 2.2.2.d)  
specified in licensees corrective action program to restore compliance.
This is a Severity Level IV violation (Section 2.2.2.d)
Pursuant to the provisions of 10 CFR 2.201, SCE&G is hereby required to submit a written  
Pursuant to the provisions of 10 CFR 2.201, SCE&G is hereby required to submit a written
 
statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document
statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document  
Control Desk, Washington, DC 20555-0001 with a copy to the Regional Administrator, Region II,
Control Desk, Washington, DC 20555-0001 with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector at the facilit
and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within
y that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should  
30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should
be clearly marked as a "Reply to a Notice of Violation" and should include: (1) the reason for  
be clearly marked as a "Reply to a Notice of Violation" and should include: (1) the reason for
the violation, or, if contested, the basis for disputing the violation or severity level, (2) the  
the violation, or, if contested, the basis for disputing the violation or severity level, (2) the
corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken, and (4) the date when full compliance will be achieved.  
corrective steps that have been taken and the results achieved, (3) the corrective steps that will
Your response may reference or include previous docketed correspondence, if the  
be taken, and (4) the date when full compliance will be achieved.
correspondence adequately addresses the required response.  
Your response may reference or include previous docketed correspondence, if the
NOV 2  If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified,
correspondence adequately addresses the required response.
suspended, or revoked, or why such other action as may be proper should not be taken.  Where good cause is shown, consideration will be given to extending the response time. 
If you contest this enforcement action, you should also provide a copy of your response, with the basis for your denial, to the Director, Office of Enforcement, United States Nuclear
Regulatory Commission, Washington, DC 20555-0001. 
 
Because your response will be made available el
ectronically for public inspection in the NRC Public Document Room or from the NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response
that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for
withholding confidential commercial or financial information).  If safeguards information is
necessary to provide an acceptable response, please provide the level of protection described
in 10 CFR 73.21. 
 
In accordance with 10 CFR 19.11, you may be required to post this Notice within two working
days of receipt.
 
Dated this 22
nd day of November 2016
Enclosure U.S. NUCLEAR REGULATORY COMMISSION
REGION II
 
Docket No.:  50-395
License No.:  NPF-12
Report No:  05000395/2016007
  Licensee:  South Carolina Electric & Gas (SCE&G) Company
Facility:  Virgil C. Summer Nuclear Station
  Location:  P.O. Box 88 Jenkinsville, SC 29065
Dates:    August 29 - October 13, 2016 September 12 - 15, 2016
Inspectors: N. Staples, Senior Project Inspector, Team Leader  C. Dykes, Reactor Inspector, Region II R. Rodriguez, Sr. Reactor Inspector, Region II  S. Seaton, Project Inspector, Region II
S. Ninh, Senior Project Engineer, Region II
 
  Approved by:  Bradley J. Davis, Acting Branch Chief Reactor Projects Branch 7
 
Division of Reactor Projects
SUMMARY OF FINDINGS
IR 05000335/2016007, 08/29/2016 - 10/13/2016; Virgil C. Summer Nuclear Station; Biennial Inspection of the Problem Identification and Resolution Program.
 
The inspection activities described in this report were performed between August 29 and
October 13, 2016, by a senior project engineer, a senior project inspector, a project inspector,
and a reactor inspector.  One Green non-cited violation and one cited Severity Level (SL) IV
violation are documented in this report.  The significance of inspection findings are indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined 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 were
dispositioned in accordance with the NRC's Enforcement Policy dated February 4, 2015.  The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 6.
 
Identification and Resolution of Problems
The NRC inspection team reviewed the station's corrective action program and the station's implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems to confirm that the station was complying with NRC regulations and
licensee standards for corrective action programs.  The team identified two findings in problem
identification, implementation of the process for prioritizing and evaluating these problems, and
the effectiveness of corrective actions taken to resolve these problems. 
The team also evaluated the station's processes for use of industry and NRC operating
experience information and the effectiveness of the station's audits and self-
assessments.  Based on the samples reviewed, the team determined that your staff's
performance in each of these areas adequately supported nuclear safety. 
The team also evaluated the station's processes for use of industry and NRC operating
experience information and the effectiveness of the station's audits and self-assessments.  Based on the samples reviewed, the team determined that your staff's performance in each of
these areas adequately supported nuclear safety.
 
Finally the team reviewed the station's programs to establish and maintain a safety-conscious
work environment, and interviewed station personnel to evaluate the effectiveness of these programs.  Based on the team's observations and the results of these interviews the team found
no evidence of challenges to your organization's safety-conscious work environment.  Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available. 
Cornerstone: Mitigating Systems
* Green. The inspectors identified a non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," for the failure to correct a condition adverse to quality associated with a previously issued NCV, 05000395/2012004-02, Inadequate Installation of Unit 1 Service Water Piping and Related Pipe Support.  The licensee entered the issue in the correction action program as condition report (CR)-16-04621.
3 The PD is more than minor because if left uncorrected, the reduction in design margin of the pipe support could affect the Unit 1 SW system's ability to mitigate a seismic event.
  Specifically, Unit 1 service water (SW) piping and support had
been impacted by the reduction in design margin and without formally updating the associated drawings and
calculations or restoring to the original design, future modifications to the system could impact the system's ability to mitigate a seismic event.  Using Manual Chapter 0609 Attachment 04, "Initial Characterization of Findings," Table 2, dated October 07, 2016,
the finding was determined to adversely affect the External Event Mitigating Systems. 
The inspectors screened the finding using Inspection Manual Chapter (IMC) 0609,
Appendix A, "Significance Determination Process (SDP) for Findings at-Power," dated June 19, 2012, and determined that it screened as Green (very low safety significance) because the service water system maintained its functionality to mitigate a seismic
event.  The inspectors determined that the finding had a cross-cutting aspect in the area
of PI&R because the licensee did not take effective corrective actions to address this issue in a timely manner [P.3]. (Section 4OA2) SLIV.  The inspectors identified a cited Severity Level (SL) IV violation of Operating Licensee Condition 2.C.(18) for failure to ensure that conditions adverse to fire protection as noted in a previous NRC-identified SLIV NCV, 05000395/2016001-01, "Failure to Implement Adequate Administrative Controls Following a Departure from National Fire Protection Association (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 licensee's corrective action program to restore compliance.  The licensee entered the issue in their corrective
action program as condition report (CR)-16-04701. 
 
The inspectors determined that the performance deficiency was more than minor because it impacted the ability of the NRC to perform its regulatory oversight function
and was dispositioned using traditional enforcement.  Because the licensee failed to
implement corrective actions and restore compliance in a timely manner, this violation is
being treated as a cited violation, consistent with Section 2.3.2.a of the NRC
Enforcement Policy.  This violation involved traditional enforcement and a cross-cutting aspect was not assigned to this violation.
REPORT DETAILS
4. OTHER ACTIVITIES
  4OA2 Problem Identification and Resolution
.1 Corrective Action Program Effectiveness
  a. Inspection Scope
The team reviewed the licensee's corrective action program (CAP) procedures which described the administrative process for initiating and resolvi
ng problems primarily through the use of condition reports.  To verify that problems were being properly
identified, appropriately characterized, and entered into the CAP, the team reviewed a sample of Condition Reports (CRs) that had been issued between August 2014 and August 2016, including a detailed review of selected CRs associated with the following
risk-significant systems and components: 
Electrical (7.2Kv and 480VAC), Safety Injection (SI), Residual Heat Removal (RHR), and Service Water (SW).  To help ensure
that samples were reviewed across all cornerstones of safety identified in the NRC's
Reactor Oversight Process (ROP), the team selected a representative number of CRs that were identified and assigned to the major plant departments, including
organizational effectiveness, health physics, chemistry, emergency preparedness and
security.  These CRs were reviewed to assess each department's threshold for
identifying and documenting plant problems, thoroughness of evaluations, and adequacy
of corrective actions.  The team reviewed selected CRs, verified corrective actions were implemented, and attended meetings where CRs were screened for significance to determine whether the licensee was identifying, accurately characterizing, and entering problems into the CAP at an appropriate threshold.
The team conducted plant walkdowns of equipment associated with the selected systems and other plant areas to assess the material condition and to look for any deficiencies that had not been previously entered into the CAP.  The team reviewed
CRs, maintenance history, completed work orders (WOs) for the systems, and reviewed
associated system health reports.  These reviews were performed to verify that
problems were being properly identified, appropriately characterized, and entered into
the CAP.  Items reviewed generally covered a two-year period of time; however, a five-year review was performed for selected systems for age-dependent issues.
Control room walkdowns were also performed to assess the main control room (MCR)
deficiency list and to ascertain if deficiencies were entered into the CAP.  A sample of
operator workarounds and operator burden screenings were reviewed and the team verified compensatory measures were implemented for deficient equipment. 
The team conducted a detailed review of selected CRs to assess the adequacy of the
root-cause, apparent-cause, and condition evaluations of the problems identified.  The
team reviewed these evaluations against the descriptions of the problem described in
 
the CRs and the guidance in procedures SAP-1356, "Cause Determination," and SAP-0999, "Corrective Action Program."  The team assessed if the licensee had adequately determined the cause(s) of identified problems and had adequately addressed
operability, reportability, common cause, generic concerns, extent-of-condition, and
 
extent-of-cause as required.
5 The review also assessed if the licensee had appropriately identified and prioritized corrective actions to prevent recurrence for significant conditions adverse to quality.  The
team reviewed site trend reports to determine if the licensee effectively trended identified issues and initiated appropriate corrective actions when adverse trends were identified.
The inspectors attended the CR Review Team (CRT) virtual meetings, where CRs were
screened for significance, to determine whether the licensee was identifying, accurately
characterizing, and entering problems into the CAP at an appropriate threshold.  The
team attended various plant meetings to observe management oversight functions of the corrective action process.  These included Management Review Team (MRT) and Corrective Action Review Board (CARB) meetings.  Documents reviewed are listed in the
 
Attachment.
 
    b. Assessment
Problem Identification
The team determined that the licensee was generally effective in identifying problems
and entering them into the CAP and there was a low threshold for entering issues into the CAP.  This conclusion was based on a review of the requirements for initiating CRs as described in licensee procedure SAP-0999, "Corrective Action Program,"
management's expectation that employees were encouraged to initiate CRs for any reason, and the relatively few number of deficiencies identified by the team during plant
walkdowns not already entered into the CAP.  Trending was generally effective in
 
monitoring equipment performance.  Site management was actively involved in the CAP and focused appropriate attention on significant plant issues.  Based on reviews and walkdowns of accessible portions of the selected systems, the team determined that
system deficiencies were being identified and placed in the CAP.
Problem Prioritization and Evaluation
Based on the review of CRs sampled by the inspection team during the onsite period,
the team concluded that problems were generally prioritized and evaluated in
accordance with the licensee's CAP procedures as described in the CR severity level
determination guidance in procedure SAP-0999.  Each CR was assigned a priority level
at the CR Review Team and adequate consideration was given to system or component operability and associated plant risk.
The team determined that station personnel had conducted root cause and apparent
cause analyses in compliance with the licensee's CAP procedures and the assigned
cause determinations were appropriate, considering the significance of the issues being evaluated.  A variety of formal causal-analysis techniques were used depending on the type and complexity of the issue consistent with SAP-1356.
6 Effectiveness of Corrective Actions
Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the team determined that generally, corrective actions were timely, commensurate with the safety significance of the issues, and effective, in that conditions adverse to quality were corrected.  For significant
conditions adverse to quality, the inspectors determined corrective actions directly
addressed the cause and effectively prevented recurrence through a review of
performance indicators, CRs, and effectiveness reviews demonstrated that the significant conditions adverse to quality had not recurred.  Effectiveness reviews for CAPRs were sufficient to ensure corrective actions were properly implemented and were
effective. 
  c. Findings
1. Failure to implement corrective actions and restore compliance for previous NRC-identified Severity Level (SL) IV non-cited violation (NCV), 05000395/2016001-01.
Introduction:  The inspectors identified a cited SL IV violation of Operating Licensee Condition 2.C.(18) for failure to ensure that conditions adverse to fire protection as noted
in a previous NRC-identified  SLIV 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.
Description:  On May 11, 2016, the NRC issued a SL IV NCV of 10 CFR 50.9(a) as 05000395/2016001-01, "Failure to Implement Adequate Administrative Controls
Following a Departure from NFPA 80-1973 and Provide NRC Staff Complete and
Accurate Information."  In NRC inspection report 05000395/2016001, the inspectors
determined that the fire 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 associated engineering evaluation relied on inadequate administrative controls to ensure the associated replacement doors were
kept closed as a basis for not following NFPA 80-1973 which required the fire doors be
self-closing.  The inspectors determined that the licensee failed to provide complete and
accurate information regarding a deviation from NFPA 805, "Performance-Based
Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 edition, which requires that fire doors conform to NFPA 80.  Specifically, DRIB/105A&B lack self-closing mechanisms as required by NFPA 80.  This information and the
associated engineering evaluation were not provided as part of amendment request
(LAR)-06-00055, which was material because licensing decisions were made in the
development of the operating license.
The inspectors reviewed CRs 15-04027, 16-00242, 16-02705 and the apparent cause
evaluation (ACE) associated with this SL IV NCV and discussed with licensee staff. 
Based on review of these CRs and apparent cause evaluations (ACE), the inspectors
determined that 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 licensee's corrective action program to restore
compliance.  The inspectors reviewed the licensee's operating license and quality 
7  assurance program and determined conditions adverse to fire protection are required to be identified and corrected per Section 1.7.8 of RG 1.89.
 
Analysis:  Failure to ensure that conditions adverse to fire protection as noted in previous NRC-identified non-cited violation (NCV), SLIV NCV, 05000395/2016001-01, were promptly corrected was a violation.  This violation was more than minor because it
impacted the ability of the NRC to perform its regulatory oversight function and was
dispositioned using traditional enforcement.  Because the licensee failed to implement corrective actions and restore compliance in a timely manner, this violation is being treated as a cited violation, consistent with Section 2.3.2a of the NRC Enforcement policy.  This violation involved traditional enforcement and a cross-cutting aspect was
not assigned to this violation.     
Enforcement: Operating Licensee Condition 2.C.(18) states, in part, that 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 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 LAR states, in part, that 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 RG1.189, 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
licensee's corrective action program to restore compliance. 
Because the licensee failed to implement corrective actions and restore compliance in a
timely manner, this violation is being treated as a cited violation, consistent with Section 2.3.2.a of the NRC Enforcement policy.  A Notice
of Violation is included with this report: VIO 05000395/2016007-01, "Failure to implement corrective actions and restore
compliance for previous NRC-identified SLIV NCV 05000395/2016001-01."
2. Failure to correct a condition adverse to quality associated with a previously issued 
NCV 
8  Introduction: A Green NCV of 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," was identified by the NRC for the failure to correct a condition adverse to quality associated with a previously issued NCV , 05000395/2012004-02, Inadequate Installation of Unit 1 Service Water Piping and Related Pipe Support.
  Description: On November 7, 2012, the NRC issued NCV, 05000395/2012004-02, against 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings,"
for failure to accomplish the installation of Unit 1 service water (SW) piping and supports in accordance with prescribed drawings.  The finding was of very low safety significance and was entered into the licensee's CAP as CR-12-00771.  An engineering information request (EIR) was completed, which concluded that the pipe support was acceptable as
is.  However, no additional action was taken to complete an engineering evaluation, per
ES-120, to formally disposition the pipe support "accept as is," or update related
drawings and calculations and CR-12-00771 was closed.  As a result of NRC questioning during the biennial problem identification and resolution (PI&R) inspection, the licensee opened CR-16-04621, which determined that the degraded condition was
neither corrected nor formally dispositioned as "accept as is."  A work order, WO
1613458, was in the process of being developed to fix the pipe support.  Analysis:  The licensee's failure to correct a non-conforming condition of Unit 1 Service Water Piping and Related Pipe Support, was a performance deficiency (PD).  The inspectors reviewed inspection manual chapter (IMC) 0612, Appendix B, "Issue Screening," dated September 7, 2012, and determined that the PD is more than minor because if left uncorrected, the reduction in design margin of the pipe support could
affect the Unit 1 SW system's ability to mitigate a seismic event.
  Specifically, Unit 1 service water (SW) piping and support had
been impacted by the reduction in design margin and without formally updating the associated drawings and calculations or
restoring to the original design, future modifications to the system could impact the system's ability to mitigate a seismic event.  Using Manual Chapter 0609.04, "Initial Characterization of Findings," Table 2, dated June 19, 2012, the finding was determined
to adversely affect the External Event Mitigating Systems.  The inspectors screened the finding using Inspection Manual Chapter (IMC) 0609, Appendix A, "Significance
Determination Process (SDP) for Findings at-Power," dated June 19, 2012, and determined that it screened as Green (very low safety significance) because the service water system maintained its functionality to mitigate a seismic event.  Using IMC 0310, "Aspects within the Cross-Cutting Areas," dated December 4, 2014, the inspectors determined that the finding had a cross-cutting aspect in the area of PI&R
because the licensee did not take effective corrective actions to address this issue in a timely manner (P.3, Resolution). 
Enforcement:  10 CFR 50, Appendix B, Criterion
XVI, "Corrective Action," states in part
that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected.
  Contrary to the above, as of October 13, 2016, the licensee failed to correct a nonconforming condition of Unit 1
service water piping and related pipe support from a previous issued NRC Green NCV,
05000395/2012004-02.  Because the finding is of very low safety significance and it was
entered into the licensee's CAP as CR-16-04621, this violation is being treated as a
Green NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 
9  05000395/2016007-01, Failure to correct a condition adverse to quality associated with
a previously issued NCV.
  .2 Use of Operating Experience 
    a. Inspection Scope
The team examined licensee's use of industry operating experience (OE) to assess the
effectiveness of how external and internal operating experience information was used to
prevent similar or recurring problems at the plant.  In addition, the team selected operating experience documents (e.g., NRC generic communications, 10 CFR Part 21
reports, licensee event reports, vendor notifications, and plant internal operating
experience items, etc.), issued since February 2014 to verify whether the licensee had appropriately evaluated each notification for applicability to the VC Summer site, and whether issues identified through these reviews were entered into the CAP.  Documents reviewed are listed in the Attachment. 


    b. Assessment
NOV                                            2
Based on a review of documentation related to the review of operating experience issues, the team determined that the licensee was generally effective in screening
If an adequate reply is not received within the time specified in this Notice, an order or a
operating experience for applicability to the plant. Industry OE was screened by the
Demand for Information may be issued as to why the license should not be modified,
corporate OE coordinator and relevant information was then forwarded to the site's OE
suspended, or revoked, or why such other action as may be proper should not be taken. Where
coordinator.  OE issues requiring action were entered into the CAP for tracking and
good cause is shown, consideration will be given to extending the response time.
closure.  In addition, operating experience was included in all root cause evaluations in accordance with licensee procedure SAP-1356.
If you contest this enforcement action, you should also provide a copy of your response, with
the basis for your denial, to the Director, Office of Enforcement, United States Nuclear
  c. Findings
Regulatory Commission, Washington, DC 20555-0001.
  No findings were identified.
Because your response will be made available electronically for public inspection in the NRC
.3  Self-Assessments and Audits
Public Document Room or from the NRCs Agencywide Documents Access and Management
System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-
  a. Inspection Scope
rm/adams.html, to the extent possible, it should not include any personal privacy, proprietary, or
The team reviewed audit reports and self-assessment reports, including those which focused on problem identification and resolution, to assess the thoroughness and self-criticism of the licensee's audits and self-assessments, and to verify that problems identified through those activities were appropriately prioritized and entered into the CAP
safeguards information so that it can be made available to the public without redaction. If
for resolution in accordance with licensee procedure SAP-1350, VC Summer Nuclear
personal privacy or proprietary information is necessary to provide an acceptable response,
Station Assessment Program.  Documents reviewed are listed in the Attachment.
then please provide a bracketed copy of your response that identifies the information that
    b. Assessment
should be protected and a redacted copy of your response that deletes such information. If you
The team determined that the scopes of assessments and audits were adequate. Self-
request withholding of such material, you must specifically identify the portions of your response
assessments were generally detailed and critical, as evidenced by findings consistent with the inspector's independent review.  The team verified that CRs were created to document all areas for improvement and findings resulting from the self-assessments, and verified that actions had been completed consistent with those recommendations.
that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g.,
Generally, the licensee performed evaluations that were technically accurate. 
explain why the disclosure of information will create an unwarranted invasion of personal
 
privacy or provide the information required by 10 CFR 2.390(b) to support a request for
10      c. Findings
withholding confidential commercial or financial information). If safeguards information is
  No findings were identified.
necessary to provide an acceptable response, please provide the level of protection described
.4 Safety-Conscious Work Environment
in 10 CFR 73.21.
    a. Inspection Scope
In accordance with 10 CFR 19.11, you may be required to post this Notice within two working
During the course of the inspection, the team assessed the station's safety-conscious work environment (SCWE) through review of the stations Employee Concerns Program (ECP) and interviews with various departmental personnel.  The team reviewed a  
days of receipt.
sample of ECP issues to verify that concerns were being properly reviewed and
Dated this 22nd day of November 2016
identified deficiencies were being resolved and entered into the CAP when appropriate.  
    b. Assessment
Based on the interviews conducted and the CRs reviewed, the team determined that
licensee management emphasized the need for all employees to identify and report
problems using the appropriate methods established within the administrative programs, including the CAP and ECP.  These methods were readily accessible to all employees. 
Based on discussions conducted with a samp
le of plant employees from various
departments, the team determined that employees felt free to raise issues, and that management encouraged employees to place issues into the CAP for resolution.  The team did not identify any reluctance on the part of the licensee staff to report safety
concerns.  
    c. Findings
No findings were identified.  
4OA6 Meetings, Including Exit
On September 15, 2016, the inspectors presented the preliminary inspection results to
Mr. G. Lippard and other members of the site staff.  The inspectors confirmed that all
proprietary information examined during the inspection had been returned to the
licensee.  Following completion of additional inspection of the findings, a re-exit was held by telephone with Mr. R. Justice of your staff on October 13, 2016, to discuss the final results of the inspection.  
ATTACHMENT:  SUPPLEMENTAL INFORMATION
Attachment SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
  Licensee personnel: G. Lippard, Vice President Unit 1
B. Thompson, Licensing Manager
R. Perry, Licensing
W. Martin, Licensing M. Moore, Licensing Supervisor G. Kelley, ECP


V. Pearson, OD&P  
            U.S. NUCLEAR REGULATORY COMMISSION
                              REGION II
Docket No.:            50-395
License No.:          NPF-12
Report No:            05000395/2016007
Licensee:              South Carolina Electric & Gas (SCE&G) Company
Facility:              Virgil C. Summer Nuclear Station
Location:              P.O. Box 88
                      Jenkinsville, SC 29065
Dates:                August 29 - October 13, 2016
                      September 12 - 15, 2016
Inspectors:            N. Staples, Senior Project Inspector, Team Leader
                      C. Dykes, Reactor Inspector, Region II
                      R. Rodriguez, Sr. Reactor Inspector, Region II
                      S. Seaton, Project Inspector, Region II
                      S. Ninh, Senior Project Engineer, Region II
Approved by:          Bradley J. Davis, Acting Branch Chief
                      Reactor Projects Branch 7
                      Division of Reactor Projects
                                                                      Enclosure


J. Wasieczko, Manager OD&P
                                      SUMMARY OF FINDINGS
R. Justice, Plant General Manager
IR 05000335/2016007, 08/29/2016 - 10/13/2016; Virgil C. Summer Nuclear Station; Biennial
NRC personnel: James Reece, Senior Resident Inspector
Inspection of the Problem Identification and Resolution Program.
Anthony Masters, Chief, Branch 7, Division of Reactor Projects
The inspection activities described in this report were performed between August 29 and
October 13, 2016, by a senior project engineer, a senior project inspector, a project inspector,
and a reactor inspector. One Green non-cited violation and one cited Severity Level (SL) IV
violation are documented in this report. The significance of inspection findings are indicated by
their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined 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 were
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 6.
Identification and Resolution of Problems
The NRC inspection team reviewed the stations corrective action program and the stations
implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating,
and correcting problems to confirm that the station was complying with NRC regulations and
licensee standards for corrective action programs. The team identified two findings in problem
identification, implementation of the process for prioritizing and evaluating these problems, and
the effectiveness of corrective actions taken to resolve these problems.
The team also evaluated the stations processes for use of industry and NRC operating
experience information and the effectiveness of the stations audits and self-
assessments. Based on the samples reviewed, the team determined that your staffs
performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating
experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of
these areas adequately supported nuclear safety.
Finally the team reviewed the stations programs to establish and maintain a safety-conscious
work environment, and interviewed station personnel to evaluate the effectiveness of these
programs. Based on the teams observations and the results of these interviews the team found
no evidence of challenges to your organizations safety-conscious work environment. Your
employees appeared willing to raise nuclear safety concerns through at least one of the several
means available.
Cornerstone: Mitigating Systems
    *    Green. The inspectors identified a non-cited violation (NCV) of 10 CFR 50, Appendix B,
        Criterion XVI, Corrective Action, for the failure to correct a condition adverse to quality
        associated with a previously issued NCV, 05000395/2012004-02, Inadequate Installation
        of Unit 1 Service Water Piping and Related Pipe Support. The licensee entered the
        issue in the correction action program as condition report (CR)-16-04621.


  LIST OF REPORT ITEMS
                                            3
  Opened  05000395/2016007-01 VIO  Failure to Implement Corrective Actions and 
      The PD is more than minor because if left uncorrected, the reduction in design margin of
Restore Compliance for Previous NRC-Identified SLIV NCV  (Section 4OA1.C.1)
      the pipe support could affect the Unit 1 SW systems ability to mitigate a seismic event.
      Specifically, Unit 1 service water (SW) piping and support had been impacted by the
Opened and Closed 05000395/2016007-02  NCV  Failure to Correct a Condition Adverse to Quality Associated with a Previously Issued  NCV (Section 4OA1.C.2)
      reduction in design margin and without formally updating the associated drawings and
      calculations or restoring to the original design, future modifications to the system could
 
      impact the systems ability to mitigate a seismic event. Using Manual Chapter 0609
  LIST OF DOCUMENTS REVIEWED Procedures: 0-PME-50.12, Periodic Battery Charger Component Replacement, Rev. 2 0-PME-50.15, Non-Appendix R Lighting Inspection and Maintenance, Rev. 4
      Attachment 04, Initial Characterization of Findings, Table 2, dated October 07, 2016,
0-NOP-67.05 Refueling Operations, Rev. 18
      the finding was determined to adversely affect the External Event Mitigating Systems.
1-OSP-99.08A, A Train Quarterly Non Check Valve Cycle Test, Rev.11
      The inspectors screened the finding using Inspection Manual Chapter (IMC) 0609,
ADM-17.08, Implementation of 10 CFR 50.65, The Maintenance Rule, Rev. 27
      Appendix A, Significance Determination Process (SDP) for Findings at-Power, dated
ADM-17.32_MRULE Structure Monitoring, Rev 3 EN-AA-202-1001, Engineering Change and Scope, Rev.7 CDG-01, Cause Determination Guidelines, Revision 17
      June 19, 2012, and determined that it screened as Green (very low safety significance)
EOP 2.2, ES-1.3, Transfer to Cold Leg Recirculation, Revision 17
      because the service water system maintained its functionality to mitigate a seismic
ER-AA-100-2002, Maintenance Rule Program Administration, Rev. 2
      event. The inspectors determined that the finding had a cross-cutting aspect in the area
ES-120, Operability or Functionality Recommendation Development, Revision 1 ES-0514A, Maintenance Rule - Scoping, Revision 0 ES-0514B, Maintenance Rule - SSC Risk Determination. Revision 0
      of PI&R because the licensee did not take effective corrective actions to address this
ES-0514C, Maintenance Rule - Performance Criteria Selection, Revision 0
      issue in a timely manner [P.3]. (Section 4OA2)
ES-0514D, Maintenance Rule - Performance Monitoring, Revision 0
SLIV. The inspectors identified a cited Severity Level (SL) IV violation of Operating Licensee
ES-0514E, Maintenance Rule - (a)(1) and (a)(2) Transitioning, Revision 0 ES-0514F, Maintenance Rule - MRule Expert Panel Roles and Responsibilities, Revision 0 ES-0514G, Maintenance Rule - Periodic (a)(3) Assessment, Revision 0
      Condition 2.C.(18) for failure to ensure that conditions adverse to fire protection as noted
FPP-015, Shift Inspection, Revision 7
      in a previous NRC-identified SLIV NCV, 05000395/2016001-01, Failure to Implement
MSP-100.01, Protective Coating Surveillance Program, Revision 10
      Adequate Administrative Controls Following a Departure from National Fire Protection
OAP-102.1, Conduct of Operations Scheduling Unit, Revision 8
      Association (NFPA) 80-1973 and Provide NRC Staff Complete and Accurate
OAP 103.2, Emergency Operating Procedure Setpoint Document, Rev. 1 OAP-113.1, Operator Workaround and Dark Board Program, Revision 4 PSEG-19, Boric Acid Corrosion Evaluation, Revision 2  
      Information, were promptly corrected. Specifically, the licensee failed to implement
PSEG-12, System and Program Health Reports 
      corrective actions and restore compliance in a timely manner for (1) the noncompliance
Plant Health System Report -Safety Injection - 2015 and 2016
      with 10 CFR 50.9 to provide staff complete and accurate information and (2) fire doors
PSEG-System and Program Health Reports for SI  PTP101.002, 7.2 KV ESF Bus Breaker Alignment Verification, Revision 2 PI-AA-207-1003-10000, Performance Improvement Trend Codes and Keywords, Rev. 5
      DRIB/105A&B currently do not meet self-closing requirements in accordance with the
PSL-ENG-SENS-06-050 Evaluation of Plant Barriers, Rev. 5
      current NFPA 805 licensing basis and no actions were specified in licensees corrective
PI-AA-102-1001, Operating Experience Program Screening and Responding to Incoming Operating Experience, Rev.16 SAP-0143, Preventive Maintenance Program, Revision 1 SAP-0157, Maintenance Rule Program
      action program to restore compliance. The licensee entered the issue in their corrective
SAP-209, Operability Determination Process, Revision 1
      action program as condition report (CR)-16-04701.
SAP-297A, Development of Emergency Operating Procedures, Revision 5
      The inspectors determined that the performance deficiency was more than minor
SAP-0999, Corrective Action Program, Revision 13, Change C
      because it impacted the ability of the NRC to perform its regulatory oversight function
SAP-0999E, Corrective Action Review Board (CARB) SAP-1356, Cause Determination, Revision 7 SAP-1350C, Nuclear Safety Culture Monitoring, Revision 5
      and was dispositioned using traditional enforcement. Because the licensee failed to
SAP-1100, Boric Acid Corrosion Control Program, Revision 3
      implement corrective actions and restore compliance in a timely manner, this violation is
STP 125.001, Electric Power System Weekly Test, Revision 15 
      being treated as a cited violation, consistent with Section 2.3.2.a of the NRC
3  Condition Reports Reviewed:
      Enforcement Policy. This violation involved traditional enforcement and a cross-cutting
11-04585 11-06298 12-00583 12-00771 12-02013 12-02534
      aspect was not assigned to this violation.
12-04908 12-05225 13-00497 13-00566 13-02694 13-03952 14-00233 14-00760 14-01926
14-01930 14-02282 14-03079 14-03806 14-04017 14-04771 14-04946
14-04956 14-05100 14-05412 14-05414 14-05446 14-05542 14-05608 14-05649 14-05676
14-05700 14-05711 14-05737 14-05792 14-05821 14-05864 14-05869 14-05888 14-05897
14-06134 14-06168 14-06191 14-06336 14-06346 14-06404 14-06422
14-06439 14-06626 14-06646 15-00021 15-00071 15-00242 15-00263 15-00359 15-00435
15-00487 15-00541 15-00591 15-00636 15-00662 15-01015 15-01056
15-01083 15-01324 15-01347 15-01355 15-01494 15-01546 15-01615 15-01648 15-01661
15-01672 15-02031 15-02057 15-02087 15-02674 15-02793 15-02875 15-02875 15-03053
15-03057 15-03194 15-03654 15-03658 15-03885 15-04027 15-04275
15-04395 15-04480 15-04681 15-04703 15-04704 15-04706 15-04711 15-04712 15-04725
15-04749 15-04804 15-04829 15-04871 15-04872 15-04950 15-05024
15-05043 15-05043 15-05050 15-05055 15-05075 15-05167 15-05186 15-05253 15-05260
15-05276 15-05318 15-05328
15-05497 15-05607 15-05673 15-05722 15-05756 15-05814
15-05897 15-05900 15-05959 15-06007 15-06171 15-06174 15-06189
15-06199 15-06261 15-06353 15-06446 15-06608 16-00210 16-00550 16-00812 16-00853
16-00972 16-01210 16-01310 16-01351 16-01762 16-01853 16-02005
16-02089 16-02305 16-02504 16-02788 16-02803 16-03099 16-03384 16-03925 16-04396
16-04414 16-04431 16-04440 16-04445 16-04546 16-04579 16-04587 16-04621 16-04695   
4  Corrective Maintenance Work Orders
1415007-001


1500007-001
                                      REPORT DETAILS
1501650-001
4.    OTHER ACTIVITIES
1501880-001
4OA2 Problem Identification and Resolution
.1    Corrective Action Program Effectiveness
  a. Inspection Scope
      The team reviewed the licensees corrective action program (CAP) procedures which
      described the administrative process for initiating and resolving problems primarily
      through the use of condition reports. To verify that problems were being properly
      identified, appropriately characterized, and entered into the CAP, the team reviewed a
      sample of Condition Reports (CRs) that had been issued between August 2014 and
      August 2016, including a detailed review of selected CRs associated with the following
      risk-significant systems and components: Electrical (7.2Kv and 480VAC), Safety
      Injection (SI), Residual Heat Removal (RHR), and Service Water (SW). To help ensure
      that samples were reviewed across all cornerstones of safety identified in the NRCs
      Reactor Oversight Process (ROP), the team selected a representative number of CRs
      that were identified and assigned to the major plant departments, including
      organizational effectiveness, health physics, chemistry, emergency preparedness and
      security. These CRs were reviewed to assess each departments threshold for
      identifying and documenting plant problems, thoroughness of evaluations, and adequacy
      of corrective actions. The team reviewed selected CRs, verified corrective actions were
      implemented, and attended meetings where CRs were screened for significance to
      determine whether the licensee was identifying, accurately characterizing, and entering
      problems into the CAP at an appropriate threshold.
      The team conducted plant walkdowns of equipment associated with the selected
      systems and other plant areas to assess the material condition and to look for any
      deficiencies that had not been previously entered into the CAP. The team reviewed
      CRs, maintenance history, completed work orders (WOs) for the systems, and reviewed
      associated system health reports. These reviews were performed to verify that
      problems were being properly identified, appropriately characterized, and entered into
      the CAP. Items reviewed generally covered a two-year period of time; however, a five-
      year review was performed for selected systems for age-dependent issues.
      Control room walkdowns were also performed to assess the main control room (MCR)
      deficiency list and to ascertain if deficiencies were entered into the CAP. A sample of
      operator workarounds and operator burden screenings were reviewed and the team
      verified compensatory measures were implemented for deficient equipment.
      The team conducted a detailed review of selected CRs to assess the adequacy of the
      root-cause, apparent-cause, and condition evaluations of the problems identified. The
      team reviewed these evaluations against the descriptions of the problem described in
      the CRs and the guidance in procedures SAP-1356, Cause Determination, and SAP-
      0999, Corrective Action Program. The team assessed if the licensee had adequately
      determined the cause(s) of identified problems and had adequately addressed
      operability, reportability, common cause, generic concerns, extent-of-condition, and
      extent-of-cause as required.


1505697-001
                                          5
    The review also assessed if the licensee had appropriately identified and prioritized
    corrective actions to prevent recurrence for significant conditions adverse to quality. The
    team reviewed site trend reports to determine if the licensee effectively trended identified
    issues and initiated appropriate corrective actions when adverse trends were identified.
  The inspectors attended the CR Review Team (CRT) virtual meetings, where CRs were
  screened for significance, to determine whether the licensee was identifying, accurately
  characterizing, and entering problems into the CAP at an appropriate threshold. The
  team attended various plant meetings to observe management oversight functions of the
  corrective action process. These included Management Review Team (MRT) and
  Corrective Action Review Board (CARB) meetings. Documents reviewed are listed in the
  Attachment.
b.  Assessment
    Problem Identification
    The team determined that the licensee was generally effective in identifying problems
    and entering them into the CAP and there was a low threshold for entering issues into
    the CAP. This conclusion was based on a review of the requirements for initiating CRs
    as described in licensee procedure SAP-0999, Corrective Action Program,
    managements expectation that employees were encouraged to initiate CRs for any
    reason, and the relatively few number of deficiencies identified by the team during plant
    walkdowns not already entered into the CAP. Trending was generally effective in
    monitoring equipment performance. Site management was actively involved in the CAP
    and focused appropriate attention on significant plant issues. Based on reviews and
    walkdowns of accessible portions of the selected systems, the team determined that
    system deficiencies were being identified and placed in the CAP.
    Problem Prioritization and Evaluation
    Based on the review of CRs sampled by the inspection team during the onsite period,
    the team concluded that problems were generally prioritized and evaluated in
    accordance with the licensees CAP procedures as described in the CR severity level
    determination guidance in procedure SAP-0999. Each CR was assigned a priority level
    at the CR Review Team and adequate consideration was given to system or component
    operability and associated plant risk.
    The team determined that station personnel had conducted root cause and apparent
    cause analyses in compliance with the licensees CAP procedures and the assigned
    cause determinations were appropriate, considering the significance of the issues being
    evaluated. A variety of formal causal-analysis techniques were used depending on the
    type and complexity of the issue consistent with SAP-1356.


1607787-001
                                          6
  Effectiveness of Corrective Actions
  Based on a review of corrective action documents, interviews with licensee staff, and
  verification of completed corrective actions, the team determined that generally,
  corrective actions were timely, commensurate with the safety significance of the issues,
  and effective, in that conditions adverse to quality were corrected. For significant
  conditions adverse to quality, the inspectors determined corrective actions directly
  addressed the cause and effectively prevented recurrence through a review of
  performance indicators, CRs, and effectiveness reviews demonstrated that the
  significant conditions adverse to quality had not recurred. Effectiveness reviews for
  CAPRs were sufficient to ensure corrective actions were properly implemented and were
  effective.
c. Findings
1. Failure to implement corrective actions and restore compliance for previous NRC-
  identified Severity Level (SL) IV non-cited violation (NCV), 05000395/2016001-01.
  Introduction: The inspectors identified a cited SL IV violation of Operating Licensee
  Condition 2.C.(18) for failure to ensure that conditions adverse to fire protection as noted
  in a previous NRC-identified SLIV 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.
  Description: On May 11, 2016, the NRC issued a SL IV NCV of 10 CFR 50.9(a) as
  05000395/2016001-01, Failure to Implement Adequate Administrative Controls
  Following a Departure from NFPA 80-1973 and Provide NRC Staff Complete and
  Accurate Information. In NRC inspection report 05000395/2016001, the inspectors
  determined that the fire 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 associated engineering evaluation relied on
  inadequate administrative controls to ensure the associated replacement doors were
  kept closed as a basis for not following NFPA 80-1973 which required the fire doors be
  self-closing. The inspectors determined that the licensee failed to provide complete and
  accurate information regarding a deviation from NFPA 805, Performance-Based
  Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001
  edition, which requires that fire doors conform to NFPA 80. Specifically, DRIB/105A&B
  lack self-closing mechanisms as required by NFPA 80. This information and the
  associated engineering evaluation were not provided as part of amendment request
  (LAR)-06-00055, which was material because licensing decisions were made in the
  development of the operating license.
  The inspectors reviewed CRs 15-04027, 16-00242, 16-02705 and the apparent cause
  evaluation (ACE) associated with this SL IV NCV and discussed with licensee staff.
  Based on review of these CRs and apparent cause evaluations (ACE), the inspectors
  determined that 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. The inspectors reviewed the licensees operating license and quality


1513705-001
                                          7
  assurance program and determined conditions adverse to fire protection are required to
  be identified and corrected per Section 1.7.8 of RG 1.89.
  Analysis: Failure to ensure that conditions adverse to fire protection as noted in
  previous NRC-identified non-cited violation (NCV), SLIV NCV, 05000395/2016001-01,
  were promptly corrected was a violation. This violation was more than minor because it
  impacted the ability of the NRC to perform its regulatory oversight function and was
  dispositioned using traditional enforcement. Because the licensee failed to implement
  corrective actions and restore compliance in a timely manner, this violation is being
  treated as a cited violation, consistent with Section 2.3.2a of the NRC Enforcement
  policy. This violation involved traditional enforcement and a cross-cutting aspect was
  not assigned to this violation.
  Enforcement: Operating Licensee Condition 2.C.(18) states, in part, that 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 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 LAR states, in part, that 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 RG1.189, 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.
  Because the licensee failed to implement corrective actions and restore compliance in a
  timely manner, this violation is being treated as a cited violation, consistent with Section
  2.3.2.a of the NRC Enforcement policy. A Notice of Violation is included with this report:
  VIO 05000395/2016007-01, Failure to implement corrective actions and restore
  compliance for previous NRC-identified SLIV NCV 05000395/2016001-01.
2. Failure to correct a condition adverse to quality associated with a previously issued
  NCV


1607042-001
                                        8
1610285-001
Introduction: A Green NCV of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action,
1610285-002
was identified by the NRC for the failure to correct a condition adverse to quality
associated with a previously issued NCV, 05000395/2012004-02, Inadequate Installation
of Unit 1 Service Water Piping and Related Pipe Support.
Description: On November 7, 2012, the NRC issued NCV, 05000395/2012004-02,
against 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings,"
for failure to accomplish the installation of Unit 1 service water (SW) piping and supports
in accordance with prescribed drawings. The finding was of very low safety significance
and was entered into the licensees CAP as CR-12-00771. An engineering information
request (EIR) was completed, which concluded that the pipe support was acceptable as
is. However, no additional action was taken to complete an engineering evaluation, per
ES-120, to formally disposition the pipe support accept as is, or update related
drawings and calculations and CR-12-00771 was closed. As a result of NRC
questioning during the biennial problem identification and resolution (PI&R) inspection,
the licensee opened CR-16-04621, which determined that the degraded condition was
neither corrected nor formally dispositioned as accept as is. A work order, WO
1613458, was in the process of being developed to fix the pipe support.
Analysis: The licensees failure to correct a non-conforming condition of Unit 1 Service
Water Piping and Related Pipe Support, was a performance deficiency (PD). The
inspectors reviewed inspection manual chapter (IMC) 0612, Appendix B, Issue
Screening, dated September 7, 2012, and determined that the PD is more than minor
because if left uncorrected, the reduction in design margin of the pipe support could
affect the Unit 1 SW systems ability to mitigate a seismic event. Specifically, Unit 1
service water (SW) piping and support had been impacted by the reduction in design
margin and without formally updating the associated drawings and calculations or
restoring to the original design, future modifications to the system could impact the
systems ability to mitigate a seismic event. Using Manual Chapter 0609.04, Initial
Characterization of Findings, Table 2, dated June 19, 2012, the finding was determined
to adversely affect the External Event Mitigating Systems. The inspectors screened the
finding using Inspection Manual Chapter (IMC) 0609, Appendix A, Significance
Determination Process (SDP) for Findings at-Power, dated June 19, 2012, and
determined that it screened as Green (very low safety significance) because the service
water system maintained its functionality to mitigate a seismic event.
Using IMC 0310, Aspects within the Cross-Cutting Areas, dated December 4, 2014, the
inspectors determined that the finding had a cross-cutting aspect in the area of PI&R
because the licensee did not take effective corrective actions to address this issue in a
timely manner (P.3, Resolution).
Enforcement: 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, states in part
that measures shall be established to assure that conditions adverse to quality, such as
failures, malfunctions, deficiencies, deviations, defective material and equipment, and
non-conformances are promptly identified and corrected. Contrary to the above, as of
October 13, 2016, the licensee failed to correct a nonconforming condition of Unit 1
service water piping and related pipe support from a previous issued NRC Green NCV,
05000395/2012004-02. Because the finding is of very low safety significance and it was
entered into the licensees CAP as CR-16-04621, this violation is being treated as a
Green NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV


1510413-001
                                            9
      05000395/2016007-01, Failure to correct a condition adverse to quality associated with
      a previously issued NCV.
.2    Use of Operating Experience
  a. Inspection Scope
      The team examined licensees use of industry operating experience (OE) to assess the
      effectiveness of how external and internal operating experience information was used to
      prevent similar or recurring problems at the plant. In addition, the team selected
      operating experience documents (e.g., NRC generic communications, 10 CFR Part 21
      reports, licensee event reports, vendor notifications, and plant internal operating
      experience items, etc.), issued since February 2014 to verify whether the licensee had
      appropriately evaluated each notification for applicability to the VC Summer site, and
      whether issues identified through these reviews were entered into the CAP. Documents
      reviewed are listed in the Attachment.
  b. Assessment
      Based on a review of documentation related to the review of operating experience
      issues, the team determined that the licensee was generally effective in screening
      operating experience for applicability to the plant. Industry OE was screened by the
      corporate OE coordinator and relevant information was then forwarded to the sites OE
      coordinator. OE issues requiring action were entered into the CAP for tracking and
      closure. In addition, operating experience was included in all root cause evaluations in
      accordance with licensee procedure SAP-1356.
  c. Findings
      No findings were identified.
.3    Self-Assessments and Audits
  a. Inspection Scope
      The team reviewed audit reports and self-assessment reports, including those which
      focused on problem identification and resolution, to assess the thoroughness and self-
      criticism of the licensee's audits and self-assessments, and to verify that problems
      identified through those activities were appropriately prioritized and entered into the CAP
      for resolution in accordance with licensee procedure SAP-1350, VC Summer Nuclear
      Station Assessment Program. Documents reviewed are listed in the Attachment.
  b. Assessment
      The team determined that the scopes of assessments and audits were adequate. Self-
      assessments were generally detailed and critical, as evidenced by findings consistent
      with the inspectors independent review. The team verified that CRs were created to
      document all areas for improvement and findings resulting from the self-assessments,
      and verified that actions had been completed consistent with those recommendations.
      Generally, the licensee performed evaluations that were technically accurate.


1600730-001
                                            10
  c. Findings
      No findings were identified.
.4    Safety-Conscious Work Environment
  a.  Inspection Scope
      During the course of the inspection, the team assessed the stations safety-conscious
      work environment (SCWE) through review of the stations Employee Concerns Program
      (ECP) and interviews with various departmental personnel. The team reviewed a
      sample of ECP issues to verify that concerns were being properly reviewed and
      identified deficiencies were being resolved and entered into the CAP when appropriate.
  b. Assessment
      Based on the interviews conducted and the CRs reviewed, the team determined that
      licensee management emphasized the need for all employees to identify and report
      problems using the appropriate methods established within the administrative programs,
      including the CAP and ECP. These methods were readily accessible to all employees.
      Based on discussions conducted with a sample of plant employees from various
      departments, the team determined that employees felt free to raise issues, and that
      management encouraged employees to place issues into the CAP for resolution. The
      team did not identify any reluctance on the part of the licensee staff to report safety
      concerns.
  c. Findings
      No findings were identified.
4OA6 Meetings, Including Exit
      On September 15, 2016, the inspectors presented the preliminary inspection results to
      Mr. G. Lippard and other members of the site staff. The inspectors confirmed that all
      proprietary information examined during the inspection had been returned to the
      licensee. Following completion of additional inspection of the findings, a re-exit was held
      by telephone with Mr. R. Justice of your staff on October 13, 2016, to discuss the final
      results of the inspection.
ATTACHMENT: SUPPLEMENTAL INFORMATION


Self-Assessments: 1966524, Pre-NRC Problem Identification& Resolution (PI&R) Inspection Self Assessment
                              SUPPLEMENTAL INFORMATION
                                  KEY POINTS OF CONTACT
Licensee personnel:
G. Lippard, Vice President Unit 1
B. Thompson, Licensing Manager
R. Perry, Licensing
W. Martin, Licensing
M. Moore, Licensing Supervisor
G. Kelley, ECP
V. Pearson, OD&P
J. Wasieczko, Manager OD&P
R. Justice, Plant General Manager
NRC personnel:
James Reece, Senior Resident Inspector
Anthony Masters, Chief, Branch 7, Division of Reactor Projects
                                  LIST OF REPORT ITEMS
Opened
05000395/2016007-01                  VIO          Failure to Implement Corrective Actions and
                                                  Restore Compliance for Previous NRC-
                                                  Identified SLIV NCV (Section 4OA1.C.1)
Opened and Closed
05000395/2016007-02                  NCV          Failure to Correct a Condition Adverse to
                                                  Quality Associated with a Previously Issued
                                                  NCV (Section 4OA1.C.2)
                                                                                    Attachment


                              LIST OF DOCUMENTS REVIEWED
Work Orders:  
Procedures:
38026485-02
0-PME-50.12, Periodic Battery Charger Component Replacement, Rev. 2
0-PME-50.15, Non-Appendix R Lighting Inspection and Maintenance, Rev. 4
0-NOP-67.05 Refueling Operations, Rev. 18
1-OSP-99.08A, A Train Quarterly Non Check Valve Cycle Test, Rev.11
ADM-17.08, Implementation of 10 CFR 50.65, The Maintenance Rule, Rev. 27
ADM-17.32_MRULE Structure Monitoring, Rev 3
EN-AA-202-1001, Engineering Change and Scope, Rev.7
CDG-01, Cause Determination Guidelines, Revision 17
EOP 2.2, ES-1.3, Transfer to Cold Leg Recirculation, Revision 17
ER-AA-100-2002, Maintenance Rule Program Administration, Rev. 2
ES-120, Operability or Functionality Recommendation Development, Revision 1
ES-0514A, Maintenance Rule - Scoping, Revision 0
ES-0514B, Maintenance Rule - SSC Risk Determination. Revision 0
ES-0514C, Maintenance Rule - Performance Criteria Selection, Revision 0
ES-0514D, Maintenance Rule - Performance Monitoring, Revision 0
ES-0514E, Maintenance Rule - (a)(1) and (a)(2) Transitioning, Revision 0
ES-0514F, Maintenance Rule - MRule Expert Panel Roles and Responsibilities, Revision 0
ES-0514G, Maintenance Rule - Periodic (a)(3) Assessment, Revision 0
FPP-015, Shift Inspection, Revision 7
MSP-100.01, Protective Coating Surveillance Program, Revision 10
OAP-102.1, Conduct of Operations Scheduling Unit, Revision 8
OAP 103.2, Emergency Operating Procedure Setpoint Document, Rev. 1
OAP-113.1, Operator Workaround and Dark Board Program, Revision 4
PSEG-19, Boric Acid Corrosion Evaluation, Revision 2
PSEG-12, System and Program Health Reports
Plant Health System Report -Safety Injection - 2015 and 2016
PSEG-System and Program Health Reports for SI
PTP101.002, 7.2 KV ESF Bus Breaker Alignment Verification, Revision 2
PI-AA-207-1003-10000, Performance Improvement Trend Codes and Keywords, Rev. 5
PSL-ENG-SENS-06-050 Evaluation of Plant Barriers, Rev. 5
PI-AA-102-1001, Operating Experience Program Screening and Responding to Incoming
  Operating Experience, Rev.16
SAP-0143, Preventive Maintenance Program, Revision 1
SAP-0157, Maintenance Rule Program
SAP-209, Operability Determination Process, Revision 1
SAP-297A, Development of Emergency Operating Procedures, Revision 5
SAP-0999, Corrective Action Program, Revision 13, Change C
SAP-0999E, Corrective Action Review Board (CARB)
SAP-1356, Cause Determination, Revision 7
SAP-1350C, Nuclear Safety Culture Monitoring, Revision 5
SAP-1100, Boric Acid Corrosion Control Program, Revision 3
STP 125.001, Electric Power System Weekly Test, Revision 15


39021349
                                3
40051270
Condition Reports Reviewed:
40291617
11-04585                14-06168  15-03194 15-05900
40297503
11-06298                14-06191  15-03654 15-05959
40299899 40301755 40303405
12-00583                14-06336  15-03658 15-06007
40306989 40311432-05
12-00771                14-06346  15-03885 15-06171
40316415
12-02013                14-06404  15-04027 15-06174
40317485 
12-02534                14-06422  15-04275 15-06189
12-04908                14-06439  15-04395 15-06199
12-05225                14-06626  15-04480 15-06261
13-00497                14-06646  15-04681 15-06353
13-00566                15-00021  15-04703 15-06446
13-02694                15-00071  15-04704 15-06608
13-03952                15-00242  15-04706 16-00210
14-00233                15-00263  15-04711 16-00550
14-00760                15-00359  15-04712 16-00812
14-01926                15-00435  15-04725 16-00853
14-01930                15-00487  15-04749 16-00972
14-02282                15-00541  15-04804 16-01210
14-03079                15-00591  15-04829 16-01310
14-03806                15-00636  15-04871 16-01351
14-04017                15-00662  15-04872 16-01762
14-04771                15-01015  15-04950 16-01853
14-04946                15-01056  15-05024 16-02005
14-04956                15-01083  15-05043 16-02089
14-05100                15-01324  15-05043 16-02305
14-05412                15-01347  15-05050 16-02504
14-05414                15-01355  15-05055 16-02788
14-05446                15-01494  15-05075 16-02803
14-05542                15-01546  15-05167 16-03099
14-05608                15-01615  15-05186 16-03384
14-05649                15-01648  15-05253 16-03925
14-05676                15-01661  15-05260 16-04396
14-05700                15-01672  15-05276 16-04414
14-05711                15-02031  15-05318 16-04431
14-05737                15-02057  15-05328 16-04440
14-05792                15-02087  15-05497 16-04445
14-05821                15-02674  15-05607 16-04546
14-05864                15-02793  15-05673 16-04579
14-05869                15-02875  15-05722 16-04587
14-05888                15-02875  15-05756 16-04621
14-05897                15-03053  15-05814 16-04695
14-06134                15-03057  15-05897


40321728
                                              4
40322723
Corrective Maintenance Work Orders
40327300 40331897 40333771
1415007-001
40340194 40347394 40353053
1500007-001
40353054
1501650-001
40359242
1501880-001
40359243
1505697-001
40360192 40365018 40365437
1607787-001
40365438 40398236 40454409  
1513705-001
40454416  
1607042-001
40458771  
1610285-001
94011628  
1610285-002
381026626  
1510413-001
4006440001  
1600730-001
4006440201  
Self-Assessments:
Condition Reports Generated:  
1966524, Pre-NRC Problem Identification& Resolution (PI&R) Inspection Self
16-04124  
Assessment
16-04444  
Work Orders:
16-04695  
38026485-02              40311432-05                  40347394            40398236
16-04701  
39021349                40316415                    40353053            40454409
40051270                40317485                    40353054            40454416
Other Documents: ES-513, MOV PROGRAM IMPLEMENTATION, REV. 2, 3/2/16  
40291617                40321728                    40359242            40458771
SAP-160, MOTOR OPERATED VALVE PROGRAM, REV. 1, 4/20/16  
40297503                40322723                    40359243            94011628
SYSTEM HEALTH REPORTS  
40299899                40327300                    40360192            381026626
SERVICE WATER SYSTEM, 1-2015-3  
40301755                40331897                    40365018            4006440001
SERVICE WATER SYSTEM, 1-2016-1 RESIDUAL HEAT REMOVAL SYSTEM, 1-2015-3 RESIDUAL HEAT REMOVAL SYSTEM, 1-2016-1  
40303405                40333771                    40365437            4006440201
40306989                40340194                    40365438
Condition Reports Generated:
16-04124
16-04444
16-04695
16-04701
Other Documents:
ES-513, MOV PROGRAM IMPLEMENTATION, REV. 2, 3/2/16
SAP-160, MOTOR OPERATED VALVE PROGRAM, REV. 1, 4/20/16
SYSTEM HEALTH REPORTS
SERVICE WATER SYSTEM, 1-2015-3
SERVICE WATER SYSTEM, 1-2016-1
RESIDUAL HEAT REMOVAL SYSTEM, 1-2015-3
RESIDUAL HEAT REMOVAL SYSTEM, 1-2016-1
Drawings:
1MS-22-333, REV. 11
ECR, 50585Y
E-206-005, Simplified Plant Electrical Distribution, Rev.29
E-206-022, Electrical One Line & Relay Diagram 7200V SWGR Busses 1DA, 1DB, 1EA & 1EB,
Rev.16


                                          5
Drawings: 1MS-22-333, REV. 11
E-206-034, Electrical One Line & Relay Diagram 480/277V SWGR Busses 1DA1, 1DA2, 1DB1,
ECR, 50585Y E-206-005, Simplified Plant Electrical Distribution, Rev.29 E-206-022, Electrical One Line & Relay Diagram 7200V SWGR Busses 1DA, 1DB, 1EA & 1EB,
Rev.16 
5  E-206-034, Electrical One Line & Relay Diagram 480/277V SWGR Busses 1DA1, 1DA2, 1DB1,  
1DB2, 1EA1 &1EA2, Rev. 21
1DB2, 1EA1 &1EA2, Rev. 21
}}
}}

Latest revision as of 11:44, 30 October 2019

NRC Problem Identification and Resolution Inspection Report 05000395/2016007 and Notice of Violation
ML16327A378
Person / Time
Site: Summer South Carolina Electric & Gas Company icon.png
Issue date: 11/22/2016
From: Bradley Davis
Reactor Projects Branch 7
To: Lippard G
South Carolina Electric & Gas Co
References
IR 2016007
Download: ML16327A378 (21)
v • d • e


See also: IR 05000395/2016007

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

245 PEACHTREE CENTER AVENUE NE, SUITE 1200

ATLANTA, GEORGIA 30303-1257

November 22, 2016

Mr. George Lippard

Vice President

South Carolina Electric & Gas Company

Virgil C. Summer Nuclear Station

P.O. Box 88

Jenkinsville, SC 29065

SUBJECT: VIRGIL C. SUMMER NUCLEAR STATION - NRC PROBLEM IDENTIFICATION

AND RESOLUTION INSPECTION REPORT 05000395/2016007 AND NOTICE OF

VIOLATION

Dear Mr. Lippard:

On October 13, 2016, the Nuclear Regulatory Commission (NRC) completed a problem

identification and resolution inspection at your Virgil C. Summer Nuclear Station. On

September 15, 2016, the NRC inspection team discussed the preliminary results of this

inspection with you and other members of your staff. Following completion of additional

inspection of the findings, a re-exit was held by telephone with Mr. R. Justice of your

staff on October 13, 2016, to discuss the final results of the inspection. The results of

this inspection are documented in the enclosed inspection report.

The NRC inspection team reviewed the stations corrective action program and the stations

implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating,

and correcting problems, and to confirm that the station was complying with NRC regulations

and licensee standards for corrective action programs. The team identified two findings in

problem identification, implementation of the process for prioritizing and evaluating these

problems, and the effectiveness of corrective actions taken to resolve these problems.

The team also evaluated the stations processes for use of industry and NRC operating

experience information and the effectiveness of the stations audits and self-

assessments. Based on the samples reviewed, the team determined that your staffs

performance in each of these areas adequately supported nuclear safety.

The team also evaluated the stations processes for use of industry and NRC operating

experience information and the effectiveness of the stations audits and self-assessments.

Based on the samples reviewed, the team determined that your staffs performance in each of

these areas adequately supported nuclear safety.

Finally the team reviewed the stations programs to establish and maintain a safety-conscious

work environment, and interviewed station personnel to evaluate the effectiveness of these

programs. Based on the teams observations and the results of these interviews the team found

no evidence of challenges to your organizations safety-conscious work environment. Your

employees appeared willing to raise nuclear safety concerns through at least one of the several

means available.

G. Lippard 2

The team documented one NRC-identified finding of very low safety significance (Green) and

one citied Severity Level (SL) IV violation in this report. Both of these findings involved

violations of NRC requirements. The NRC evaluated these violations in accordance Section

2.3.2.a of the NRC Enforcement Policy, which appears on the NRCs Web site at

http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. We determined that one

violation did not meet the criteria to be treated as an NCV because compliance has not been

restored. Specifically, the licensee failed to ensure that conditions adverse to fire protection

was promptly corrected as noted in a previous NRC-identified Severity Level IV (SLIV) 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. As

of the end of this inspection, compliance had not been restored.

You are required to respond to this letter and should follow the instructions specified in the

enclosed Notice of Violation (Notice) when preparing your response. If you have additional

information that you believe the NRC should consider, you may provide it in your response to

the Notice. The NRCs review of your response to the Notice will also determine whether further

enforcement action is necessary to ensure your compliance with regulatory requirements.

If you contest the violations or the significance of the violations, 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 V.C. Summer station.

If you disagree with a cross-cutting aspect assignment or a finding not associated with a

regulatory requirement 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 V.C. Summer 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/

Bradley J. Davis, Acting Chief

Reactor Projects Branch 7

Division of Reactor Projects

Docket No.: 50-395

License No.: NPF-12

Enclosures:

1. Notice of Violation

2. Inspection Report 05000395/2016007

w/Attachment: Supplemental Information

cc Distribution via ListServ

ML16327A378 SUNSI REVIEW COMPLETE FORM 665 ATTACHED

OFFICE RII:DRP RII:DRP RII:DRP RII:DRP RII:DRP RII:EICS RII:DRP

SIGNATURE NLS2 via email RJR1 via email RCT1 via email CDJ1 via email CBS via email /RA/ /RA/

NAME NStaples RRodriguez SNinh CDykes SSeaton MKowal BDavis

DATE 11/1/2016 11/22/2016 11/1/2016 11/ /2016 11/22/2016 11/22/2016 11/22/2016

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

Letter to George Lippard from Bradley J. Davis dated November 22, 2016

SUBJECT: VIRGIL C. SUMMER NUCLEAR STATION - NRC PROBLEM IDENTIFICATION

AND RESOLUTION INSPECTION REPORT 05000395/2016007 AND NOTICE OF

VIOLATION

DISTRIBUTION:

S. Price, RII EICS

S. Maxey, RII EICS

OE Mail

RIDSNRRDIRS

PUBLIC

RidsNrrPMStLucie Resource

NOTICE OF VIOLATION

South Carolina Electric and Gas Company (SCE&G) Docket No. 50-395

Virgil C. Summer Nuclear Station, Unit 1 License No. NPF-12

During an NRC 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)

Pursuant to the provisions of 10 CFR 2.201, SCE&G is hereby required to submit a written

statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document

Control Desk, Washington, DC 20555-0001 with a copy to the Regional Administrator, Region II,

and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within

30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should

be clearly marked as a "Reply to a Notice of Violation" and should include: (1) the reason for

the violation, or, if contested, the basis for disputing the violation or severity level, (2) the

corrective steps that have been taken and the results achieved, (3) the corrective steps that will

be taken, and (4) the date when full compliance will be achieved.

Your response may reference or include previous docketed correspondence, if the

correspondence adequately addresses the required response.

NOV 2

If an adequate reply is not received within the time specified in this Notice, an order or a

Demand for Information may be issued as to why the license should not be modified,

suspended, or revoked, or why such other action as may be proper should not be taken. Where

good cause is shown, consideration will be given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response, with

the basis for your denial, to the Director, Office of Enforcement, United States Nuclear

Regulatory Commission, Washington, DC 20555-0001.

Because your response will be made available electronically for public inspection in the NRC

Public Document Room or from the NRCs Agencywide Documents Access and Management

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

rm/adams.html, to the extent possible, it should not include any personal privacy, proprietary, or

safeguards information so that it can be made available to the public without redaction. If

personal privacy or proprietary information is necessary to provide an acceptable response,

then please provide a bracketed copy of your response that identifies the information that

should be protected and a redacted copy of your response that deletes such information. If you

request withholding of such material, you must specifically identify the portions of your response

that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g.,

explain why the disclosure of information will create an unwarranted invasion of personal

privacy or provide the information required by 10 CFR 2.390(b) to support a request for

withholding confidential commercial or financial information). If safeguards information is

necessary to provide an acceptable response, please provide the level of protection described

in 10 CFR 73.21.

In accordance with 10 CFR 19.11, you may be required to post this Notice within two working

days of receipt.

Dated this 22nd day of November 2016

U.S. NUCLEAR REGULATORY COMMISSION

REGION II

Docket No.: 50-395

License No.: NPF-12

Report No: 05000395/2016007

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

Facility: Virgil C. Summer Nuclear Station

Location: P.O. Box 88

Jenkinsville, SC 29065

Dates: August 29 - October 13, 2016

September 12 - 15, 2016

Inspectors: N. Staples, Senior Project Inspector, Team Leader

C. Dykes, Reactor Inspector, Region II

R. Rodriguez, Sr. Reactor Inspector, Region II

S. Seaton, Project Inspector, Region II

S. Ninh, Senior Project Engineer, Region II

Approved by: Bradley J. Davis, Acting Branch Chief

Reactor Projects Branch 7

Division of Reactor Projects

Enclosure

SUMMARY OF FINDINGS

IR 05000335/2016007, 08/29/2016 - 10/13/2016; Virgil C. Summer Nuclear Station; Biennial

Inspection of the Problem Identification and Resolution Program.

The inspection activities described in this report were performed between August 29 and

October 13, 2016, by a senior project engineer, a senior project inspector, a project inspector,

and a reactor inspector. One Green non-cited violation and one cited Severity Level (SL) IV

violation are documented in this report. The significance of inspection findings are indicated by

their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined 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 were

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 6.

Identification and Resolution of Problems

The NRC inspection team reviewed the stations corrective action program and the stations

implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating,

and correcting problems to confirm that the station was complying with NRC regulations and

licensee standards for corrective action programs. The team identified two findings in problem

identification, implementation of the process for prioritizing and evaluating these problems, and

the effectiveness of corrective actions taken to resolve these problems.

The team also evaluated the stations processes for use of industry and NRC operating

experience information and the effectiveness of the stations audits and self-

assessments. Based on the samples reviewed, the team determined that your staffs

performance in each of these areas adequately supported nuclear safety.

The team also evaluated the stations processes for use of industry and NRC operating

experience information and the effectiveness of the stations audits and self-assessments.

Based on the samples reviewed, the team determined that your staffs performance in each of

these areas adequately supported nuclear safety.

Finally the team reviewed the stations programs to establish and maintain a safety-conscious

work environment, and interviewed station personnel to evaluate the effectiveness of these

programs. Based on the teams observations and the results of these interviews the team found

no evidence of challenges to your organizations safety-conscious work environment. Your

employees appeared willing to raise nuclear safety concerns through at least one of the several

means available.

Cornerstone: Mitigating Systems

Criterion XVI, Corrective Action, for the failure to correct a condition adverse to quality

associated with a previously issued NCV,05000395/2012004-02, Inadequate Installation

of Unit 1 Service Water Piping and Related Pipe Support. The licensee entered the

issue in the correction action program as condition report (CR)-16-04621.

3

The PD is more than minor because if left uncorrected, the reduction in design margin of

the pipe support could affect the Unit 1 SW systems ability to mitigate a seismic event.

Specifically, Unit 1 service water (SW) piping and support had been impacted by the

reduction in design margin and without formally updating the associated drawings and

calculations or restoring to the original design, future modifications to the system could

impact the systems ability to mitigate a seismic event. Using Manual Chapter 0609

Attachment 04, Initial Characterization of Findings, Table 2, dated October 07, 2016,

the finding was determined to adversely affect the External Event Mitigating Systems.

The inspectors screened the finding using Inspection Manual Chapter (IMC) 0609,

Appendix A, Significance Determination Process (SDP) for Findings at-Power, dated

June 19, 2012, and determined that it screened as Green (very low safety significance)

because the service water system maintained its functionality to mitigate a seismic

event. The inspectors determined that the finding had a cross-cutting aspect in the area

of PI&R because the licensee did not take effective corrective actions to address this

issue in a timely manner [P.3]. (Section 4OA2)

SLIV. The inspectors identified a cited Severity Level (SL) IV violation of Operating Licensee

Condition 2.C.(18) for failure to ensure that conditions adverse to fire protection as noted

in a previous NRC-identified SLIV NCV,05000395/2016001-01, Failure to Implement

Adequate Administrative Controls Following a Departure from National Fire Protection

Association (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. The licensee entered the issue in their corrective

action program as condition report (CR)-16-04701.

The inspectors determined that the performance deficiency was more than minor

because it impacted the ability of the NRC to perform its regulatory oversight function

and was dispositioned using traditional enforcement. Because the licensee failed to

implement corrective actions and restore compliance in a timely manner, this violation is

being treated as a cited violation, consistent with Section 2.3.2.a of the NRC

Enforcement Policy. This violation involved traditional enforcement and a cross-cutting

aspect was not assigned to this violation.

REPORT DETAILS

4. OTHER ACTIVITIES

4OA2 Problem Identification and Resolution

.1 Corrective Action Program Effectiveness

a. Inspection Scope

The team reviewed the licensees corrective action program (CAP) procedures which

described the administrative process for initiating and resolving problems primarily

through the use of condition reports. To verify that problems were being properly

identified, appropriately characterized, and entered into the CAP, the team reviewed a

sample of Condition Reports (CRs) that had been issued between August 2014 and

August 2016, including a detailed review of selected CRs associated with the following

risk-significant systems and components: Electrical (7.2Kv and 480VAC), Safety

Injection (SI), Residual Heat Removal (RHR), and Service Water (SW). To help ensure

that samples were reviewed across all cornerstones of safety identified in the NRCs

Reactor Oversight Process (ROP), the team selected a representative number of CRs

that were identified and assigned to the major plant departments, including

organizational effectiveness, health physics, chemistry, emergency preparedness and

security. These CRs were reviewed to assess each departments threshold for

identifying and documenting plant problems, thoroughness of evaluations, and adequacy

of corrective actions. The team reviewed selected CRs, verified corrective actions were

implemented, and attended meetings where CRs were screened for significance to

determine whether the licensee was identifying, accurately characterizing, and entering

problems into the CAP at an appropriate threshold.

The team conducted plant walkdowns of equipment associated with the selected

systems and other plant areas to assess the material condition and to look for any

deficiencies that had not been previously entered into the CAP. The team reviewed

CRs, maintenance history, completed work orders (WOs) for the systems, and reviewed

associated system health reports. These reviews were performed to verify that

problems were being properly identified, appropriately characterized, and entered into

the CAP. Items reviewed generally covered a two-year period of time; however, a five-

year review was performed for selected systems for age-dependent issues.

Control room walkdowns were also performed to assess the main control room (MCR)

deficiency list and to ascertain if deficiencies were entered into the CAP. A sample of

operator workarounds and operator burden screenings were reviewed and the team

verified compensatory measures were implemented for deficient equipment.

The team conducted a detailed review of selected CRs to assess the adequacy of the

root-cause, apparent-cause, and condition evaluations of the problems identified. The

team reviewed these evaluations against the descriptions of the problem described in

the CRs and the guidance in procedures SAP-1356, Cause Determination, and SAP-

0999, Corrective Action Program. The team assessed if the licensee had adequately

determined the cause(s) of identified problems and had adequately addressed

operability, reportability, common cause, generic concerns, extent-of-condition, and

extent-of-cause as required.

5

The review also assessed if the licensee had appropriately identified and prioritized

corrective actions to prevent recurrence for significant conditions adverse to quality. The

team reviewed site trend reports to determine if the licensee effectively trended identified

issues and initiated appropriate corrective actions when adverse trends were identified.

The inspectors attended the CR Review Team (CRT) virtual meetings, where CRs were

screened for significance, to determine whether the licensee was identifying, accurately

characterizing, and entering problems into the CAP at an appropriate threshold. The

team attended various plant meetings to observe management oversight functions of the

corrective action process. These included Management Review Team (MRT) and

Corrective Action Review Board (CARB) meetings. Documents reviewed are listed in the

Attachment.

b. Assessment

Problem Identification

The team determined that the licensee was generally effective in identifying problems

and entering them into the CAP and there was a low threshold for entering issues into

the CAP. This conclusion was based on a review of the requirements for initiating CRs

as described in licensee procedure SAP-0999, Corrective Action Program,

managements expectation that employees were encouraged to initiate CRs for any

reason, and the relatively few number of deficiencies identified by the team during plant

walkdowns not already entered into the CAP. Trending was generally effective in

monitoring equipment performance. Site management was actively involved in the CAP

and focused appropriate attention on significant plant issues. Based on reviews and

walkdowns of accessible portions of the selected systems, the team determined that

system deficiencies were being identified and placed in the CAP.

Problem Prioritization and Evaluation

Based on the review of CRs sampled by the inspection team during the onsite period,

the team concluded that problems were generally prioritized and evaluated in

accordance with the licensees CAP procedures as described in the CR severity level

determination guidance in procedure SAP-0999. Each CR was assigned a priority level

at the CR Review Team and adequate consideration was given to system or component

operability and associated plant risk.

The team determined that station personnel had conducted root cause and apparent

cause analyses in compliance with the licensees CAP procedures and the assigned

cause determinations were appropriate, considering the significance of the issues being

evaluated. A variety of formal causal-analysis techniques were used depending on the

type and complexity of the issue consistent with SAP-1356.

6

Effectiveness of Corrective Actions

Based on a review of corrective action documents, interviews with licensee staff, and

verification of completed corrective actions, the team determined that generally,

corrective actions were timely, commensurate with the safety significance of the issues,

and effective, in that conditions adverse to quality were corrected. For significant

conditions adverse to quality, the inspectors determined corrective actions directly

addressed the cause and effectively prevented recurrence through a review of

performance indicators, CRs, and effectiveness reviews demonstrated that the

significant conditions adverse to quality had not recurred. Effectiveness reviews for

CAPRs were sufficient to ensure corrective actions were properly implemented and were

effective.

c. Findings

1. Failure to implement corrective actions and restore compliance for previous NRC-

identified Severity Level (SL) IV non-cited violation (NCV),05000395/2016001-01.

Introduction: The inspectors identified a cited SL IV violation of Operating Licensee

Condition 2.C.(18) for failure to ensure that conditions adverse to fire protection as noted

in a previous NRC-identified SLIV 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.

Description: On May 11, 2016, the NRC issued a SL IV NCV of 10 CFR 50.9(a) as05000395/2016001-01, Failure to Implement Adequate Administrative Controls

Following a Departure from NFPA 80-1973 and Provide NRC Staff Complete and

Accurate Information. In NRC inspection report 05000395/2016001, the inspectors

determined that the fire 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 associated engineering evaluation relied on

inadequate administrative controls to ensure the associated replacement doors were

kept closed as a basis for not following NFPA 80-1973 which required the fire doors be

self-closing. The inspectors determined that the licensee failed to provide complete and

accurate information regarding a deviation from NFPA 805, Performance-Based

Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001

edition, which requires that fire doors conform to NFPA 80. Specifically, DRIB/105A&B

lack self-closing mechanisms as required by NFPA 80. This information and the

associated engineering evaluation were not provided as part of amendment request

(LAR)-06-00055, which was material because licensing decisions were made in the

development of the operating license.

The inspectors reviewed CRs 15-04027, 16-00242, 16-02705 and the apparent cause

evaluation (ACE) associated with this SL IV NCV and discussed with licensee staff.

Based on review of these CRs and apparent cause evaluations (ACE), the inspectors

determined that 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. The inspectors reviewed the licensees operating license and quality

7

assurance program and determined conditions adverse to fire protection are required to

be identified and corrected per Section 1.7.8 of RG 1.89.

Analysis: Failure to ensure that conditions adverse to fire protection as noted in

previous NRC-identified non-cited violation (NCV), SLIV NCV,05000395/2016001-01,

were promptly corrected was a violation. This violation was more than minor because it

impacted the ability of the NRC to perform its regulatory oversight function and was

dispositioned using traditional enforcement. Because the licensee failed to implement

corrective actions and restore compliance in a timely manner, this violation is being

treated as a cited violation, consistent with Section 2.3.2a of the NRC Enforcement

policy. This violation involved traditional enforcement and a cross-cutting aspect was

not assigned to this violation.

Enforcement: Operating Licensee Condition 2.C.(18) states, in part, that 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 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 LAR states, in part, that 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 RG1.189, 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.

Because the licensee failed to implement corrective actions and restore compliance in a

timely manner, this violation is being treated as a cited violation, consistent with Section

2.3.2.a of the NRC Enforcement policy. A Notice of Violation is included with this report:

VIO 05000395/2016007-01, Failure to implement corrective actions and restore

compliance for previous NRC-identified SLIV NCV 05000395/2016001-01.

2. Failure to correct a condition adverse to quality associated with a previously issued

NCV

8

Introduction: A Green NCV of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action,

was identified by the NRC for the failure to correct a condition adverse to quality

associated with a previously issued NCV,05000395/2012004-02, Inadequate Installation

of Unit 1 Service Water Piping and Related Pipe Support.

Description: On November 7, 2012, the NRC issued NCV,05000395/2012004-02,

against 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings,"

for failure to accomplish the installation of Unit 1 service water (SW) piping and supports

in accordance with prescribed drawings. The finding was of very low safety significance

and was entered into the licensees CAP as CR-12-00771. An engineering information

request (EIR) was completed, which concluded that the pipe support was acceptable as

is. However, no additional action was taken to complete an engineering evaluation, per

ES-120, to formally disposition the pipe support accept as is, or update related

drawings and calculations and CR-12-00771 was closed. As a result of NRC

questioning during the biennial problem identification and resolution (PI&R) inspection,

the licensee opened CR-16-04621, which determined that the degraded condition was

neither corrected nor formally dispositioned as accept as is. A work order, WO 1613458, was in the process of being developed to fix the pipe support.

Analysis: The licensees failure to correct a non-conforming condition of Unit 1 Service

Water Piping and Related Pipe Support, was a performance deficiency (PD). The

inspectors reviewed inspection manual chapter (IMC) 0612, Appendix B, Issue

Screening, dated September 7, 2012, and determined that the PD is more than minor

because if left uncorrected, the reduction in design margin of the pipe support could

affect the Unit 1 SW systems ability to mitigate a seismic event. Specifically, Unit 1

service water (SW) piping and support had been impacted by the reduction in design

margin and without formally updating the associated drawings and calculations or

restoring to the original design, future modifications to the system could impact the

systems ability to mitigate a seismic event. Using Manual Chapter 0609.04, Initial

Characterization of Findings, Table 2, dated June 19, 2012, the finding was determined

to adversely affect the External Event Mitigating Systems. The inspectors screened the

finding using Inspection Manual Chapter (IMC) 0609, Appendix A, Significance

Determination Process (SDP) for Findings at-Power, dated June 19, 2012, and

determined that it screened as Green (very low safety significance) because the service

water system maintained its functionality to mitigate a seismic event.

Using IMC 0310, Aspects within the Cross-Cutting Areas, dated December 4, 2014, the

inspectors determined that the finding had a cross-cutting aspect in the area of PI&R

because the licensee did not take effective corrective actions to address this issue in a

timely manner (P.3, Resolution).

Enforcement: 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, states in part

that measures shall be established to assure that conditions adverse to quality, such as

failures, malfunctions, deficiencies, deviations, defective material and equipment, and

non-conformances are promptly identified and corrected. Contrary to the above, as of

October 13, 2016, the licensee failed to correct a nonconforming condition of Unit 1

service water piping and related pipe support from a previous issued NRC Green NCV,05000395/2012004-02. Because the finding is of very low safety significance and it was

entered into the licensees CAP as CR-16-04621, this violation is being treated as a

Green NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV

9

05000395/2016007-01, Failure to correct a condition adverse to quality associated with

a previously issued NCV.

.2 Use of Operating Experience

a. Inspection Scope

The team examined licensees use of industry operating experience (OE) to assess the

effectiveness of how external and internal operating experience information was used to

prevent similar or recurring problems at the plant. In addition, the team selected

operating experience documents (e.g., NRC generic communications, 10 CFR Part 21

reports, licensee event reports, vendor notifications, and plant internal operating

experience items, etc.), issued since February 2014 to verify whether the licensee had

appropriately evaluated each notification for applicability to the VC Summer site, and

whether issues identified through these reviews were entered into the CAP. Documents

reviewed are listed in the Attachment.

b. Assessment

Based on a review of documentation related to the review of operating experience

issues, the team determined that the licensee was generally effective in screening

operating experience for applicability to the plant. Industry OE was screened by the

corporate OE coordinator and relevant information was then forwarded to the sites OE

coordinator. OE issues requiring action were entered into the CAP for tracking and

closure. In addition, operating experience was included in all root cause evaluations in

accordance with licensee procedure SAP-1356.

c. Findings

No findings were identified.

.3 Self-Assessments and Audits

a. Inspection Scope

The team reviewed audit reports and self-assessment reports, including those which

focused on problem identification and resolution, to assess the thoroughness and self-

criticism of the licensee's audits and self-assessments, and to verify that problems

identified through those activities were appropriately prioritized and entered into the CAP

for resolution in accordance with licensee procedure SAP-1350, VC Summer Nuclear

Station Assessment Program. Documents reviewed are listed in the Attachment.

b. Assessment

The team determined that the scopes of assessments and audits were adequate. Self-

assessments were generally detailed and critical, as evidenced by findings consistent

with the inspectors independent review. The team verified that CRs were created to

document all areas for improvement and findings resulting from the self-assessments,

and verified that actions had been completed consistent with those recommendations.

Generally, the licensee performed evaluations that were technically accurate.

10

c. Findings

No findings were identified.

.4 Safety-Conscious Work Environment

a. Inspection Scope

During the course of the inspection, the team assessed the stations safety-conscious

work environment (SCWE) through review of the stations Employee Concerns Program

(ECP) and interviews with various departmental personnel. The team reviewed a

sample of ECP issues to verify that concerns were being properly reviewed and

identified deficiencies were being resolved and entered into the CAP when appropriate.

b. Assessment

Based on the interviews conducted and the CRs reviewed, the team determined that

licensee management emphasized the need for all employees to identify and report

problems using the appropriate methods established within the administrative programs,

including the CAP and ECP. These methods were readily accessible to all employees.

Based on discussions conducted with a sample of plant employees from various

departments, the team determined that employees felt free to raise issues, and that

management encouraged employees to place issues into the CAP for resolution. The

team did not identify any reluctance on the part of the licensee staff to report safety

concerns.

c. Findings

No findings were identified.

4OA6 Meetings, Including Exit

On September 15, 2016, the inspectors presented the preliminary inspection results to

Mr. G. Lippard and other members of the site staff. The inspectors confirmed that all

proprietary information examined during the inspection had been returned to the

licensee. Following completion of additional inspection of the findings, a re-exit was held

by telephone with Mr. R. Justice of your staff on October 13, 2016, to discuss the final

results of the inspection.

ATTACHMENT: SUPPLEMENTAL INFORMATION

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel:

G. Lippard, Vice President Unit 1

B. Thompson, Licensing Manager

R. Perry, Licensing

W. Martin, Licensing

M. Moore, Licensing Supervisor

G. Kelley, ECP

V. Pearson, OD&P

J. Wasieczko, Manager OD&P

R. Justice, Plant General Manager

NRC personnel:

James Reece, Senior Resident Inspector

Anthony Masters, Chief, Branch 7, Division of Reactor Projects

LIST OF REPORT ITEMS

Opened

05000395/2016007-01 VIO Failure to Implement Corrective Actions and

Restore Compliance for Previous NRC-

Identified SLIV NCV (Section 4OA1.C.1)

Opened and Closed

05000395/2016007-02 NCV Failure to Correct a Condition Adverse to

Quality Associated with a Previously Issued

NCV (Section 4OA1.C.2)

Attachment

LIST OF DOCUMENTS REVIEWED

Procedures:

0-PME-50.12, Periodic Battery Charger Component Replacement, Rev. 2

0-PME-50.15, Non-Appendix R Lighting Inspection and Maintenance, Rev. 4

0-NOP-67.05 Refueling Operations, Rev. 18

1-OSP-99.08A, A Train Quarterly Non Check Valve Cycle Test, Rev.11

ADM-17.08, Implementation of 10 CFR 50.65, The Maintenance Rule, Rev. 27

ADM-17.32_MRULE Structure Monitoring, Rev 3

EN-AA-202-1001, Engineering Change and Scope, Rev.7

CDG-01, Cause Determination Guidelines, Revision 17

EOP 2.2, ES-1.3, Transfer to Cold Leg Recirculation, Revision 17

ER-AA-100-2002, Maintenance Rule Program Administration, Rev. 2

ES-120, Operability or Functionality Recommendation Development, Revision 1

ES-0514A, Maintenance Rule - Scoping, Revision 0

ES-0514B, Maintenance Rule - SSC Risk Determination. Revision 0

ES-0514C, Maintenance Rule - Performance Criteria Selection, Revision 0

ES-0514D, Maintenance Rule - Performance Monitoring, Revision 0

ES-0514E, Maintenance Rule - (a)(1) and (a)(2) Transitioning, Revision 0

ES-0514F, Maintenance Rule - MRule Expert Panel Roles and Responsibilities, Revision 0

ES-0514G, Maintenance Rule - Periodic (a)(3) Assessment, Revision 0

FPP-015, Shift Inspection, Revision 7

MSP-100.01, Protective Coating Surveillance Program, Revision 10

OAP-102.1, Conduct of Operations Scheduling Unit, Revision 8

OAP 103.2, Emergency Operating Procedure Setpoint Document, Rev. 1

OAP-113.1, Operator Workaround and Dark Board Program, Revision 4

PSEG-19, Boric Acid Corrosion Evaluation, Revision 2

PSEG-12, System and Program Health Reports

Plant Health System Report -Safety Injection - 2015 and 2016

PSEG-System and Program Health Reports for SI

PTP101.002, 7.2 KV ESF Bus Breaker Alignment Verification, Revision 2

PI-AA-207-1003-10000, Performance Improvement Trend Codes and Keywords, Rev. 5

PSL-ENG-SENS-06-050 Evaluation of Plant Barriers, Rev. 5

PI-AA-102-1001, Operating Experience Program Screening and Responding to Incoming

Operating Experience, Rev.16

SAP-0143, Preventive Maintenance Program, Revision 1

SAP-0157, Maintenance Rule Program

SAP-209, Operability Determination Process, Revision 1

SAP-297A, Development of Emergency Operating Procedures, Revision 5

SAP-0999, Corrective Action Program, Revision 13, Change C

SAP-0999E, Corrective Action Review Board (CARB)

SAP-1356, Cause Determination, Revision 7

SAP-1350C, Nuclear Safety Culture Monitoring, Revision 5

SAP-1100, Boric Acid Corrosion Control Program, Revision 3

STP 125.001, Electric Power System Weekly Test, Revision 15

3

Condition Reports Reviewed:

11-04585 14-06168 15-03194 15-05900

11-06298 14-06191 15-03654 15-05959

12-00583 14-06336 15-03658 15-06007

12-00771 14-06346 15-03885 15-06171

12-02013 14-06404 15-04027 15-06174

12-02534 14-06422 15-04275 15-06189

12-04908 14-06439 15-04395 15-06199

12-05225 14-06626 15-04480 15-06261

13-00497 14-06646 15-04681 15-06353

13-00566 15-00021 15-04703 15-06446

13-02694 15-00071 15-04704 15-06608

13-03952 15-00242 15-04706 16-00210

14-00233 15-00263 15-04711 16-00550

14-00760 15-00359 15-04712 16-00812

14-01926 15-00435 15-04725 16-00853

14-01930 15-00487 15-04749 16-00972

14-02282 15-00541 15-04804 16-01210

14-03079 15-00591 15-04829 16-01310

14-03806 15-00636 15-04871 16-01351

14-04017 15-00662 15-04872 16-01762

14-04771 15-01015 15-04950 16-01853

14-04946 15-01056 15-05024 16-02005

14-04956 15-01083 15-05043 16-02089

14-05100 15-01324 15-05043 16-02305

14-05412 15-01347 15-05050 16-02504

14-05414 15-01355 15-05055 16-02788

14-05446 15-01494 15-05075 16-02803

14-05542 15-01546 15-05167 16-03099

14-05608 15-01615 15-05186 16-03384

14-05649 15-01648 15-05253 16-03925

14-05676 15-01661 15-05260 16-04396

14-05700 15-01672 15-05276 16-04414

14-05711 15-02031 15-05318 16-04431

14-05737 15-02057 15-05328 16-04440

14-05792 15-02087 15-05497 16-04445

14-05821 15-02674 15-05607 16-04546

14-05864 15-02793 15-05673 16-04579

14-05869 15-02875 15-05722 16-04587

14-05888 15-02875 15-05756 16-04621

14-05897 15-03053 15-05814 16-04695

14-06134 15-03057 15-05897

4

Corrective Maintenance Work Orders

1415007-001

1500007-001

1501650-001

1501880-001

1505697-001

1607787-001

1513705-001

1607042-001

1610285-001

1610285-002

1510413-001

1600730-001

Self-Assessments:

1966524, Pre-NRC Problem Identification& Resolution (PI&R) Inspection Self

Assessment

Work Orders:

38026485-02 40311432-05 40347394 40398236

39021349 40316415 40353053 40454409

40051270 40317485 40353054 40454416

40291617 40321728 40359242 40458771

40297503 40322723 40359243 94011628

40299899 40327300 40360192 381026626

40301755 40331897 40365018 4006440001

40303405 40333771 40365437 4006440201

40306989 40340194 40365438

Condition Reports Generated:

16-04124

16-04444

16-04695

16-04701

Other Documents:

ES-513, MOV PROGRAM IMPLEMENTATION, REV. 2, 3/2/16

SAP-160, MOTOR OPERATED VALVE PROGRAM, REV. 1, 4/20/16

SYSTEM HEALTH REPORTS

SERVICE WATER SYSTEM, 1-2015-3

SERVICE WATER SYSTEM, 1-2016-1

RESIDUAL HEAT REMOVAL SYSTEM, 1-2015-3

RESIDUAL HEAT REMOVAL SYSTEM, 1-2016-1

Drawings:

1MS-22-333, REV. 11

ECR, 50585Y

E-206-005, Simplified Plant Electrical Distribution, Rev.29

E-206-022, Electrical One Line & Relay Diagram 7200V SWGR Busses 1DA, 1DB, 1EA & 1EB,

Rev.16

5

E-206-034, Electrical One Line & Relay Diagram 480/277V SWGR Busses 1DA1, 1DA2, 1DB1,

1DB2, 1EA1 &1EA2, Rev. 21

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