IR 05000395/2014004: Difference between revisions
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| number = ML14316A278 | | number = ML14316A278 | ||
| issue date = 11/10/2014 | | issue date = 11/10/2014 | ||
| title = | | title = IR 05000395/2014004; 07201038/2014001; on 07/01/2014 - 09/30/2014: Virgil C. Summer Nuclear Station, Unit 1; Integrated Inspection Report | ||
| author name = King M F | | author name = King M F | ||
| author affiliation = NRC/RGN-II/DRP/RPB5 | | author affiliation = NRC/RGN-II/DRP/RPB5 | ||
Revision as of 10:50, 13 February 2018
| ML14316A278 | |
| Person / Time | |
|---|---|
| Site: | Summer, 07201038  |
| Issue date: | 11/10/2014 |
| From: | King M F NRC/RGN-II/DRP/RPB5 |
| To: | Gatlin T D South Carolina Electric & Gas Co |
| References | |
| IR 2014001, IR 2014004 | |
| Download: ML14316A278 (30) | |
Text
November 10, 2014
Mr. Thomas Vice President - Nuclear Operations South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station P.O. Box 88 Jenkinsville, SC 29065
SUBJECT: VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1 - NRC INTEGRATED INSPECTION REPORTS 05000395/2014004 AND 07201038/2014001
Dear Mr. Gatlin:
On September 30, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Virgil C. Summer Nuclear Station, Unit 1. On October 30, 2014, the NRC inspectors discussed the results of this inspection with Mr. George Lippard and members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.
No NRC-identified or self-revealing findings were identified during the inspection period.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's Agencywide Document Access and management System (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,/RA/ Michael King, Chief Reactor Projects Branch 5 Division of Reactor Projects Docket Nos.: 50-395, 072-1038 License No.: NPF-12
Enclosure:
NRC Integrated Inspection Reports 05000395/2014004 and 07201038/2014001
w/Attachment:
Supplemental Information cc Distribution via ListServ Mr. Thomas
SUMMARY
IRs 05000395/2014004; 07201038/2014001; 07/01/2014 - 09/30/2014: Virgil C. Summer Nuclear Station, Unit 1; Integrated Inspection Report
The report covered a three-month period of inspection by resident inspectors, one senior reactor inspector and two emergency preparedness inspectors from the region. No NRC-identified or self-revealing findings were identified. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process" Revision 5.
REPORT DETAILS
Summary of Plant Status
Unit 1 began the inspection period at Rated Thermal Power (RTP) and operated at or near RTP until July 13, 2014, when the unit was removed from service to repair elevated reactor coolant system (RCS) identified leakage. Unit 1 returned to service on July 21, 2014, but experienced an automatic reactor trip the following day, July 22. The unit was returned to full RTP on July 28, 2014, and operated at or near RTP for the remainder of the quarter.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity 1R04 Equipment Alignment
.1 Partial System Walkdowns
a. Inspection Scope
The inspectors conducted five partial equipment alignment walkdowns which are listed below, to evaluate the operability of selected redundant trains or backup systems with the other train or system inoperable or out of service (OOS). Correct alignment and operating conditions were determined from the applicable portions of drawings, system operating procedures (SOP), and technical specifications (TS). The inspections included review of outstanding maintenance work orders (WOs) and related condition reports (CRs) to verify that the licensee had properly identified and resolved equipment alignment problems that could lead to the initiation of an event or impact mitigating system availability.
- Partial walkdown of 'A' and 'B' motor driven emergency feedwater (MDEFW) train during work on turbine driven emergency feedwater (TDEFW)
- Partial walkdown of 'A' service water (SW) pump during work on the 'B' SW pump
- Partial walkdown of 'B' residual heat removal (RHR) pump during work associated with 'A' RHR pump
- Partial walkdown of 'B' emergency diesel generator (EDG) during emergent work on the 'A' EDG
- Partial walkdown of 'A' and 'B' EDG and 'B' train offsite circuit during emergent work to replace voltage regulator, XTF-6
b. Findings
No findings were identified.
.2 Complete System Walkdown
a. Inspection Scope
The inspectors performed a detailed review and walkdown of the reactor building spray system to identify any discrepancies between the current operating system equipment lineup and the designed lineup. In addition, the inspectors reviewed SOPs, applicable sections of the final safety analysis report (FSAR), design basis document, plant drawings, completed surveillance procedures, outstanding WOs, system health reports, and related CRs to verify that the licensee had properly identified and resolved equipment problems that could affect the availability and operability of the system. Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
1R05 Fire Protection
.1 Quarterly Fire Protection Walkdowns
a. Inspection Scope
The inspectors reviewed recent CRs, WOs, and impairments associated with the fire protection system. The inspectors reviewed surveillance activities to determine whether they supported the operability and availability of the fire protection system. The inspectors assessed the material condition of the active and passive fire protection systems and features, and observed the control of transient combustibles and ignition sources. Documents reviewed are listed in the Attachment. The inspectors conducted routine inspections of the following five areas (respective fire zones also noted):
- Auxiliary building switchgear room 463 elevation (fire zone AB-1.29)
- Auxiliary building 374 elevation (fire zones AB-1.1, 1.2 and 1.3)
- Battery and charger rooms 'A' and 'B' (fire zones IB-2, 3, 4, 5 and 6)
- Intermediate building 412 elevation (fire zones IB-1, IB-2, IB-3, IB-4, IB-5 and IB-27)
- TDEFW pump room (fire zone IB-25.2)
b. Findings
No findings were identified.
.2 Annual Fire Brigade Drill Observation
a. Inspection Scope
The inspectors observed the performance of an unannounced fire brigade drill on August 6, 2014. The inspectors evaluated the readiness of licensee personnel to respond and fight fires including the following aspects:
- Observe whether turnout clothing and self-contained breathing apparatus equipment were properly worn
- Determine whether fire hose lines were properly laid out and nozzle pattern simulated being tested prior to entering the fire area of concern
- Verify that the fire area was entered in a controlled manner
- Review if sufficient firefighting equipment was brought to the scene by the fire brigade to properly perform their firefighting duties
- Verify that the fire brigade leader's firefighting directions were thorough, clear and effective, and that, if necessary, offsite fire team assistance was requested
- Verify that radio communications with plant operators and between fire brigade members were efficient and effective
- Confirm that fire brigade members checked for fire victims and fire propagation into applicable plant areas
- Observe if effective smoke removal operations were simulated
- Verify that the firefighting pre-plans were properly utilized and were effective
- Verify that the licensee pre-planned drill scenario was followed, drill objectives met the acceptance criteria, and deficiencies were captured in post drill critiques
b. Findings
No findings were identified.
1R06 Flood Protection Measures
a. Inspection Scope
The inspectors reviewed and walked down the auxiliary building AB-388' and 400' elevations regarding internal flood protection features and equipment to determine consistency with design requirements, FSAR, and flood analysis documents. Risk significant structures, systems, and components (SSCs) in these areas included the safety injection (SI) pumps, alternate seal injection pump and SI valves. The inspectors reviewed the licensee's corrective action program (CAP) database to verify that internal flood protection problems were being identified at the appropriate level, entered into the CAP, and appropriately resolved. Documents reviewed are listed in the attachment.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program and Licensed Operator Performance
.1 Resident Quarterly Review of Operator Requalification
a. Inspection Scope
The inspectors observed portions of operator requalification exams occurring on August 19 and 20, 2014. The inspectors observed crew performance in the simulator for communications; ability to prioritize failures in order to take timely and proper actions; prioritizing, interpreting, and verifying alarms; correct use and implementation of procedures, including the alarm response procedures; timely control board operation and manipulation, including high-risk operator actions; and oversight and direction provided by the shift supervisor, including the ability to identify and implement appropriate TS actions and when required, emergency action levels as the Site Emergency Director. The inspectors also observed operator performance for a plant job performance measure for correct use and implementation of procedures and knowledge of plant components. The inspectors reviewed the licensee's critique comments to verify that any performance deficiencies were captured for appropriate corrective action.
b. Findings
No findings were identified.
.2 Resident Quarterly Observation of Control Room Operations
a. Inspection Scope
During the inspection period, the inspectors conducted observations of licensed reactor operator activities to ensure consistency with licensee procedures and regulatory requirements. For the two listed activities, the inspectors observed the following elements of operator performance: 1) operator compliance and use of plant procedures including TS; 2) control board component manipulations; 3) use and interpretation of plant instrumentation and alarms; 4) documentation of activities; 5) management and supervision of activities; and 6) control room communications.
- Review of operator activities during Unit 1 shutdown for elevated RCS identified leakage
- Review of operator activities during 'A' EDG maintenance run and surveillance test
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors evaluated two equipment issues described in the CRs listed below to verify the licensee's effectiveness with the corresponding preventive or corrective maintenance associated with SSCs. The inspectors reviewed Maintenance Rule (MR) implementation to verify that component and equipment failures were identified, entered, and scoped within the MR program. Selected SSCs were reviewed to verify proper categorization and classification in accordance with 10 CFR 50.65. The inspectors examined the licensee's 10 CFR 50.65(a)(1) corrective action plans to determine if the licensee was identifying issues related to the MR at an appropriate threshold and that corrective actions were established and effective. The inspectors' review also evaluated if maintenance preventable functional failures or other MR findings existed that the licensee had not identified. The inspectors reviewed the licensee's controlling procedures consisting of engineering services procedure, (ES)-514, Revision (Rev.) 6, "Maintenance Rule Program Implementation," and station administrative procedure, (SAP)-0157, Rev. 1, "Maintenance Rule Program," to verify consistency with the MR program requirements.
- CR-13-02756, MR periodic assessment as required by 10 CFR 50.65(a)(3)
- CR-14-03191, multiple failures of SW-component cooling water (CCW) heat exchanger (HX) cross-connect valves result in the CCW system being placed in MR (a)(1) status
b. Findings
No findings relating to MR evaluations were identified.
1R13 Maintenance Risk Assessment and Emergent Work Control
a. Inspection Scope
The inspectors performed risk assessments, as appropriate, for the five selected work activities listed below: 1) the effectiveness of the risk assessments performed before maintenance activities were conducted; 2) the management of risk; 3) that, upon identification of an unforeseen situation, necessary steps were taken to plan and control the resulting emergent work activities; and, 4) that emergent work problems were adequately identified and resolved. The inspectors evaluated the licensee's work prioritization and risk characterization to determine, as appropriate, whether necessary steps were properly planned, controlled, and executed for the planned and emergent work activities.
- Work week 28, yellow risk condition for scheduled work on the TDEFW pump and associated components
- Work week 31, yellow risk condition for scheduled work associated with the 'A' RHR pump
- Work week 34, yellow risk condition for emergent work to repair a fuel oil leak on the 'A' EDG
- Work week 36, yellow risk condition for scheduled maintenance activities associated with 'B' RHR pump and related components
- Work week 38, yellow risk condition for emergent maintenance to replace voltage regulator, XTF-6
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed five operability evaluations listed below, affecting risk significant mitigating systems to assess, as appropriate: 1) the technical adequacy of the evaluations; 2) whether operability was properly justified and the subject component or system remained available, such that no unrecognized increase in risk occurred; 3) whether other existing degraded conditions were considered; 4) that the licensee considered other degraded conditions and their impact on compensatory measures for the condition being evaluated; and 5) the impact on TS limiting conditions for operations and the risk significance in accordance with the significance determination process. The inspectors also verified that the operability evaluations were performed in accordance with SAP-209, Rev. 1, "Operability Determination Process," and SAP-999, Rev. 12A, "Corrective Action Program."
- CR-14-03806, NRC identified TDEFW pipe support damage
- CR-14-03919, 'A' RHR pump seal leak
- CR-14-03035, Fisher gaskets with 480 degrees Fahrenheit rating on pressurizer spray valves 444C and D
- CR-14-01926, 'B' SW-CCW HX cross-connect valve failed to open during surveillance
- CR-14-04777, discrepancy discovered between breaker settings and design criteria for safety related chillers XHX1B and XHX1C
b. Findings
No findings were identified.
1R19 Post Maintenance Testing
a. Inspection Scope
For the eight maintenance activities listed below, the inspectors reviewed the associated post-maintenance testing (PMT) procedures and either witnessed the testing and/or reviewed test records to assess whether: 1) the effect of testing on the plant had been adequately addressed by control room and/or engineering personnel; 2) testing was adequate for the maintenance performed; 3) test acceptance criteria were clear and adequately demonstrated operational readiness consistent with design and licensing basis documents; 4) test instrumentation had current calibrations, range, and accuracy consistent with the application; 5) tests were performed as written with applicable prerequisites satisfied; 6) jumpers installed or leads lifted were properly controlled; 7) test equipment was removed following testing; and, 8) equipment was returned to the status required to perform its safety function. The inspectors verified that these activities were performed in accordance with general test procedure, (GTP)-214, "Post Maintenance Testing Guideline," Rev. 5, Change C.
- WO-1407161, 'A' CCW heat exchanger inspection
- WO-1408278, pressurizer safety valve, XVS08010C-RC, replacement
- WO-1310276, revise piping for XVR03026-SP
- WO-1206182, 'A' RHR pump seal replacement
- WO-1408764, repair seat leak on XVT08095A, reactor vessel head vent valve
- WO-1411019, repair fuel oil leak at fitting on north side fuel rack
- WO-1406529, repair XVB03107A-SW following failed open stroke test
- WO-1317741, 'B' RHR pump motor breaker replacement
b. Findings
No findings were identified.
1R20 Refueling and Other Outage Activities
Planned Outage
a. Inspection Scope
The inspectors performed the the inspection activities in accordance with Inspection Procedure (IP) 71111.20, "Refueling and Outage Activities," for a planned outage to investigate and repair the cause of elevated RCS identified leakage. The outage began on July 13, 2014, and completed when the unit returned to full RTP on July 28, 2014. The inspectors reviewed the licensee's outage risk assessments and controls for the outage schedule to verify that the licensee had appropriately considered risk, industry experience and previous site specific problems, and to confirm that the licensee had mitigation/response strategies for losses of any key safety functions. In the area of licensee control of outage activities, the inspectors reviewed equipment removed from service to verify that defense-in-depth was maintained in accordance with applicable TS, that configuration changes due to emergent work and unexpected conditions were controlled in accordance with the outage schedule and risk control plan, and that proper clearance tags were used for control of system status and personnel safety.
During the outage, the inspectors reviewed and/or observed the following:
- Plant shutdown activities
- Decay heat removal system operations
- Reactor heat up, mode changes, startup and power ascension activities The inspectors reviewed various problems that arose during the outage to verify that the licensee was identifying problems related to outage activities at an appropriate threshold and was entering them in the CAP.
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors observed and/or reviewed five surveillance test procedures (STPs) listed below to verify that TS or risk significant surveillance requirements were followed and that test acceptance criteria were properly specified to ensure that the equipment could perform its intended safety function. The inspectors verified that proper test conditions were established as specified in the procedures, that no equipment preconditioning activities occurred, and that acceptance criteria were met.
In-Service Tests:
- STP-220.002, "Turbine Driven Emergency Feedwater Pump and Valve Test," Rev. 8
- STP-223.002A, "Service Water Pump Test," Rev. 10A
- STP-220.001A, "Motor Driven Emergency Feedwater Pump and Valve Test," Rev. 11
- STP-130.003B, "Main Feedwater Valve Operability Testing," Rev. 2C Reactor Coolant System
- STP-114.002, "Operational Leakage Calculation," Rev. 12F
b. Findings
No findings were identified.
Cornerstone:
Emergency Preparedness 1EP2 Alert and Notification System Evaluation
a. Inspection Scope
The inspectors evaluated the adequacy of the licensee's methods for testing the alert and notification system in accordance with NRC Inspection Procedure 71114, Attachment 02, Alert and Notification System (ANS) Testing. The applicable planning standard, 10 CFR Part 50.47(b)(5) and its related 10 CFR Part 50, Appendix E, Section IV.D requirements were used as reference criteria. The criteria contained in NUREG-0654, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Revision 1, were also used as a reference.
The inspectors reviewed various documents which are listed in the Attachment.
Inspectors interviewed personnel involved with siren system maintenance and observed the condition of a sample of siren installations. This inspection activity satisfied one inspection sample for the alert and notification system on a biennial basis.
b. Findings
No findings were identified.
1EP3 Emergency Preparedness Organization Staffing and Augmentation System
a. Inspection Scope
The inspectors reviewed the licensee's Emergency Response Organization (ERO)augmentation staffing requirements and process for notifying the ERO to ensure the readiness of key staff for responding to an event and timely facility activation. The qualification records of key position ERO personnel were reviewed to ensure all ERO qualifications were current. A sample of problems identified from augmentation drills or system tests performed since the last inspection was reviewed to assess the effectiveness of corrective actions.
The inspection was conducted in accordance with NRC Inspection Procedure 71114, Attachment 03, Emergency Preparedness Organization Staffing and Augmentation System. The applicable planning standard, 10 CFR 50.47(b)(2), and its related 10 CFR 50, Appendix E requirements were used as reference criteria.
The inspectors reviewed various documents which are listed in the Attachment. This inspection activity satisfied one inspection sample for the ERO staffing and augmentation system on a biennial basis.
b. Findings
No findings were identified.
1EP4 Emergency Action Level and Emergency Plan Changes
a. Inspection Scope
Since the last NRC inspection of this program area, no changes were made to the Radiological Emergency Plan and Emergency Action Levels. The licensee determined that, in accordance with 10 CFR 50.54(q), the Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. The inspectors sampled implementing procedure changes made between September 2013, and August 2014, to evaluate for potential reductions in the effectiveness of the Plan. However, this review was not documented in a safety evaluation report and does not constitute formal NRC approval of the changes. Therefore, these changes remain subject to future NRC inspection in their entirety.
The inspection was conducted in accordance with NRC Inspection Procedure 71114, Attachment 04, Emergency Action Level and Emergency Plan Changes. The applicable planning standards of 10 CFR 50.47(b), and its related requirements in 10 CFR 50, Appendix E, were used as reference criteria.
The inspectors reviewed various documents that are listed in the Attachment to this report. This inspection activity satisfied one inspection sample for the emergency action level and emergency plan changes on an annual basis.
b. Findings
No findings were identified.
1EP5 Maintenance of Emergency Preparedness
a. Inspection Scope
The inspectors reviewed the corrective actions identified through the Emergency Preparedness program to determine the significance of the issues, the completeness and effectiveness of corrective actions, and to determine if issues were recurring. The licensee's post-event action reports, self-assessments, and audits were reviewed to assess the licensee's ability to be self-critical, thus avoiding complacency and degradation of their emergency preparedness program. Inspectors reviewed the licensee's 10 CFR 50.54(q) change process, personnel training, and selected screenings and evaluations to assess adequacy. The inspectors toured facilities and reviewed equipment and facility maintenance records to assess licensee's adequacy in maintaining them. The inspectors evaluated the capabilities of selected radiation monitoring instrumentation to adequately support Emergency Action Level (EAL)declarations. The inspection was conducted in accordance with NRC Inspection Procedure 71114.05, "Maintenance of Emergency Preparedness." The applicable planning standards, related 10 CFR 50, Appendix E requirements, and 10 CFR 50.54(q) and (t) were used as reference criteria.
The inspectors reviewed various documents which are listed in the Attachment. This inspection activity satisfied one inspection sample for the maintenance of emergency preparedness on a biennial basis.
b. Findings
No findings were identified. 1EP6 Drill Evaluation Emergency Preparedness (EP) Drill
a. Inspection Scope
On August 12, 2014, the inspectors reviewed and observed the performance of an after-hours, unannounced EP drill that involved fuel failure with required unit shutdown, loss of power to an emergency bus, a faulted steam generator with failure of main steam isolation valves to close and subsequent high containment pressure, and a loss of containment integrity, which required entry into increasing EALs starting with a Site Area Emergency and ending in a General Emergency. The inspectors assessed abnormal and emergency procedure usage, emergency plan classifications, protective action recommendations, respective notifications and the adequacy of the licensee's drill critique. The inspectors verified that drill deficiencies were captured into the licensee's corrective action program.
b. Findings
No findings were identified.
OTHER ACTIVITIES
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, and Occupational Radiation Safety
4OA1 Performance Indicator Verification
.1 Mitigating Systems Cornerstone
a. Inspection Scope
The inspectors verified the accuracy of the licensee's PI submittals listed below for the period July 2012 through June 2013. The inspectors used the performance indicator definitions and guidance contained in Nuclear Energy Institute (NEI) 99-02, Rev. 7, "Regulatory Assessment Performance Indicator Guideline," and licensee procedure SAP-1360, Rev. 2, "NRC and INPO/WANO Performance Indicators," to check the reporting of each data element. The inspectors sampled licensee event reports (LERs), operator logs, plant status reports, CRs, and performance indicator data sheets to verify that the licensee had properly reported the PI data.
- MSPI - High Head Safety Injection System
b. Findings
No findings were identified.
.2 Emergency Preparedness Cornerstone
a. Inspection Scope
The inspectors sampled licensee submittals relative to the PIs listed below for the period October 1, 2013, through June 30, 2014. To verify the accuracy of the PI data reported during that period, PI definitions and guidance contained in NEI 99-02, "Regulatory Assessment Performance Indicator Guideline," Rev. 7, were used to confirm the reporting basis for each data element.
Emergency Preparedness Cornerstone
- Emergency Response Organization (ERO) Drill/Exercise Performance
- ERO Drill Participation
- Alert and Notification System Reliability For the specified review period, the inspectors examined data reported to the NRC, procedural guidance for reporting PI information, and records used by the licensee to identify potential PI occurrences. The inspectors verified the accuracy of the PI for ERO drill and exercise performance through review of a sample of drill and event records.
The inspectors reviewed selected training records to verify the accuracy of the PI for ERO drill participation for personnel assigned to key positions in the ERO. The inspectors verified the accuracy of the PI for alert and notification system reliability through review of a sample of the licensee's records of periodic system tests. The inspectors also interviewed the licensee personnel who were responsible for collecting and evaluating the PI data. Licensee procedures, records, and other documents reviewed within this inspection area are listed in the Attachment. This inspection satisfied three inspection samples for PI verification on an annual basis.
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
.1 Review of Items Entered into the Corrective Action Program
a. Inspection Scope
As required by IP 71152, "Identification and Resolution of Problems," and in order to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensee's CAP. This review was accomplished by either attending daily screening meetings that briefly discussed major CRs, or accessing the licensee's computerized corrective action database and reviewing each CR that was initiated.
b. Findings
No findings were identified.
.2 Annual Operator Work-Around Review
a. Inspection Scope
The inspectors reviewed the licensee's list of identified operator workarounds associated with mitigating system equipment to determine whether any new items since the previous review conducted in 2013 would adversely affect any mitigating system function or affect the operators' ability to implement abnormal or emergency operating procedures. In addition, the inspectors performed an independent review of outstanding control board WOs and known problems with mitigating system equipment to identify any potential workarounds that had not been formally identified and evaluated by the licensee.
b. Findings
No findings were identified.
4OA3 Event Followup
.1 Unit 1 Shutdown Due to Reactor Coolant System Elevated Identified Leakage
a. Inspection Scope
On July 13, 2014, the inspectors responded to a report of reactor coolant system (RCS) elevated identified leakage at approximately 5 gpm from a seat leak associated with a RCS pressurizer safety relief valve. Any seat leakage or discharge from the RCS safety relief valves or the power operated relief valves is discharged to the pressurizer relief tank of which level is monitored and trended. Typical RCS identified leakage is less than
.05 gpm, and Technical Specification (TS) 3.4.6.2 limits identified leakage at 10 gpm.
Although the leakage remained below the TS limit at approximately 5 gpm, and the licensee made a conservative decision to shut down Unit 1 to validate the source of the leakage and make repairs. The inspectors reviewed the licensee's actions in response to the event and the subsequent shutdown to remove the unit from service relative to compliance with procedures and TS.
b. Findings
No findings were identified.
.2 Unit 1 Automatic Reactor Trip on Low-Low Steam Generator Level
a. Inspection Scope
On July 22, 2014, the inspectors responded to a Unit 1 automatic reactor trip resulting from low-low 'C' steam generator (SG) level following a loss of condensate flow. The inspectors evaluated plant parameters and status, monitored operator actions, confirmed the licensee properly classified the event in accordance with emergency action level procedures as applicable, and reviewed NRC event notification requirements in 10 CFR 50.72.
b. Findings
Introduction:
An unresolved item (URI) was identified by the inspectors for an issue of concern associated with operator actions and procedures associated with the Unit 1 reactor trip on July 22, 2014.
Description:
On July 22, 2014, Unit 1 was holding at 48 percent power for removal of the condensate polishing system from service. During this evolution, condensate flow was lost causing decreasing level and the deaerator storage tank. This resulted in a trip of the running main feedwater pumps causing a loss of feedwater flow, decreasing SG levels, and an automatic reactor trip due to low-low level in the 'C' SG. The subsequent RCS cooldown also resulted in decreasing pressurizer level and a loss of RCS letdown.
The licensee initiated CR-14-04049 for additional evaluations and corrective actions.
Pending completion of evaluations in determining related performance deficiencies and their characterization, this issue is identified as URI 05000395/2014004-01, Operator Actions Associated with Unit 1 Automatic Reactor Trip on July 22, 2014.
.3 (Closed) 05000395/2014-002-00, Reactor Vessel Head Penetrations Weld Indications Attributed To Primary Water Stress Corrosion Cracking
On April 18, 2014, While V.C. Summer Nuclear Station (VCSNS) Unit 1 was in refueling outage and defueled, the licensee identified three reactor vessel head (RVH)penetrations (9, 43, and 5) that did not meet the requirements of 10 CFR 50.55a(g)(6)(ii)(D) and American Society of Mechanical Engineers (ASME) Section Xl Code Case N-729-1. On April 26, 2014, the RVH penetration inspections were finalized and two additional penetrations (15 and 22) were identified for repair. The flaws were repaired using the embedded flaw repair process in accordance with NRC approved WCAP-15987-P, Revision 2-P-A and Relief Request RR-4-05. The apparent cause of the flaws was attributed to primary water stress corrosion cracking.
The inspectors determined that this issue was minor because the volumetric and visual inspections confirmed that the five penetrations did not have any through wall leakage indications and this condition had no actual safety consequences or impact the plant or public safety.
The penetration flaws were identified prior to through wall Ieakage occurring and repaired in a timely manner. The inspectors concluded that this failure to meet requirements of 10 CFR 50.55a(g)(6)(ii)(D) and American Society of Mechanical Engineers (ASME) Section Xl Code Case N-729-1 constitutes a minor violation that is not subject to enforcement action in accordance with NRC's Enforcement Policy. This LER is closed.
4OA5 Other Activities Onsite Fabrication of Components and Construction of an Independent Spent Fuel Storage Installation
a. Inspection Scope
The inspectors conducted a review of licensee and vendor activities in preparation for the concrete placement for the Independent Spent Fuel Storage Installation (ISFSI) pad upon which the HI-STORM (Holtec International STORage Module) FW (Flood and Wind) System will be sited to house spent fuel generated by the licensee. The inspectors walked down the construction area of the ISFSI pad and examined the rebar installation, and verified that the rebar size, spacing, splice length, and concrete coverage on the top, side, and bottom complied to licensee-approved drawings, specifications, procedures, and other associated documents, and that compliance to applicable codes, the Certificate of Compliance (CoC), and TS was met. The inspectors also evaluated the concrete formwork installation for depth, straightness, and horizontal bracing, and verified the overall dimensions and orientation for compliance to the licensee-approved drawings. The inspectors also visited the concrete batch plant contracted to supply the structural concrete to verify that it, and the trucks to be used to transport the concrete to the site, met industry standards and Code requirements. The inspectors interviewed licensee and contract personnel to verify knowledge of the planned work. The inspectors also observed the actual concrete placement and vibration of the ISFSI slab, and observed tests for concrete slump and air content, temperature measurements, and the collection/preparation of cylinder samples for compression tests, to verify that the work was implemented according to approved specifications and procedures. The inspectors later returned to the freshly poured pad to verify that the pad was being cured according to approved specifications and Code requirements. Later, when the 7-day and 28-day compression tests were completed by the independent laboratory, the inspectors reviewed the results to verify that the acceptance criteria were met.
b. Findings
No findings were identified.
4OA6 Meetings, Including Exit
On October 30, 2014, the resident inspectors presented the integrated inspection report results to Mr. George Lippard and other members of the licensee staff. The licensee acknowledged the results of these inspections. The inspectors confirmed that inspection activities discussed in this report did not contain proprietary material.
On November 7, 2014, an additional exit meeting was held via telephone between the senior resident inspector and Mr. Bruce Thompson.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- R. Antonow, CBI/ISFSI Project Manager
- A. Barbee, Director, Nuclear Training
- E. Bonnette, Emergency Planning Supervisor
- L. Bouknight, Emergency Planning Specialist
- M. Browne, Manager, Quality Systems
- M. Coleman, Manager, Health Physics and Safety Services
- B. Dalick, Licensing Engineer
- G. Douglass, Manager, Nuclear Protection Services
- M. Fanguy, Emergency Planning Specialist
- T. Gatlin, Vice President, Nuclear Operations
- M. Harmon, Manager, Chemistry Services
- R. Haselden, General Manager, Organizational / Development Effectiveness
- C. Henderson, Snubber Program
- R. Justice, Manager, Nuclear Operations
- G. Lippard, General Manager, Nuclear Plant Operations
- M. Mosley, Manager, Nuclear Training
- D. Perez, Supervisor, Health Physics - Technical Support
- D. Petersen, Welding Coordinator
- S. Reese, Licensing Specialist, Nuclear Licensing
- R. Russell, SCE&G Design Engineering
- D. Shue, Manager, Maintenance Services
- C. Speas, Independent Qualified Data Analyst
- W. Stuart, General Manager, Engineering Services
- W. Taylor, Nuclear Licensing Engineer
- B. Thompson, Manager, Nuclear Licensing
- L. Vance, Emergency Planning Specialist
- J. Wasieczko, Manager, Organization Development and Performance
- D. Weir, Manager, Plant Support Engineering
- B. Wetmore, Design Engineering
- H. White, Steam Generator Program Owner
- R. Williamson, Manager, Emergency Services
- S. Zarandi, General Manager, Nuclear Support Services
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
- 05000395/2014004-01 URI Operator Actions Associated with Unit 1 Automatic Reactor Trip on July 22, 2014 (Section 4OA3.2)
Closed
- 05000395/LER-2014-002-00 LER Reactor Vessel Head Penetrations Weld Indications Attributed To Primary Water Stress Corrosion Cracking
(Section 4OA3.3)
LIST OF DOCUMENTS REVIEWED
Section 1R04: Equipment Alignment
- STP-112.001, Reactor Building Spray Monthly Valve Inspection, Rev. 3A D-302-661, Reactor Building Spray, Rev. 35
Section 1R06: Flood Protection Measures
- DC03290-006, Evaluation for Auxiliary Building Pipe Rupture/Fiooding Effects, Rev. 0A
Section 1EP2: Alert and Notification System Evaluation Procedures and Reports V.C. Summer Alert Notification System Design Report, Rev. 1
- Federal Commander Digital Telemetry System Reference Manual Federal Signal Corporation 2001-130 Electro-Mechanical Siren Operating Manual
- EMP-170.003, Warning Siren Maintenance, Rev. 13
- EPMP-100, Maintenance of the Early Warning Siren System (EWSS), Rev. 2
- Corrective Action Documents 13-05025; Siren #80 communications failure
- 13-04373; Siren #80 communications failure
- 14-03156; Siren #80 communications failure 14-03242; Siren #67 chopper motor failure 14-04971; ANS Design Report needs added clarity
Section 1EP3: Emergency Preparedness Organization Staffing and Augmentation System Procedures
- EP-100, V.C. Summer Radiation Emergency Plan, Rev. 63
- EPP-105, Conduct of Drills and Exercises, Rev. 10
- VCS-TQP-0605, Emergency Plan Training and Drills, Rev. 0
- Records and Data 2014 Unannounced after-hours drill report 2013 and 2014 pager test results Various EP staff and ERO member training records
- V.C. Summer Unit #1 ERO On-Shift Staffing Analysis, Rev. 0
- Corrective Action Documents 14-01416, Unsatisfactory Pager drill results for 3/13/14 14-01908, Pager drill results for 3/31/14
- 14-04055, Pager drill results for 6/26/14
- 14-04916, Emergency Planning Training module link to print/sign broken
- 14-04969, Actions following failed pager test not well documented
Section 1EP4: Emergency Action Level and Emergency Plan Changes Procedures
- EPP-001, Activation and Implementation of Emergency Plan, Rev. 30C
- EPP-001.1, Unusual Event, Rev. 8C
- EPP-001.2, Alert, Rev. 8C
- EPP-001.3, Site Area Emergency, Rev. 8B
- EPP-001.4, General Emergency, Rev. 8C
- EPP-002, Communication and Notification, Rev. 35
- EPP-002, Communication and Notification, Rev. 36A, B, C
- EPP-027, Hostile Action, Rev. 5
- EPP-027, Hostile Action, Rev. 5A
- EPP-103, Emergency Equipment Checklist, Rev. 10
- Change Packages 10CFR50.54(q) Screen and Evaluation for
- EPP-001, Rev. 30C, dated 1/6/14 10CFR50.54(q) Screen and Evaluation for
- EPP-001.1, Rev. 8C, dated 7/3/14 10CFR50.54(q) Screen and Evaluation for
- EPP-001.2, Rev. 8C, dated 5/29/14
- 10CFR50.54(q) Screen and Evaluation for
- EPP-001.3, Rev. 8B, dated 7/3/14
- 10CFR50.54(q) Screen and Evaluation for
- EPP-001.4, Rev. 8C, dated 5/29/14
- 10CFR50.54(q) Screen and Evaluation for
- EPP-002, Rev. 36A, B, C, dated 6/3/14
- 10CFR50.54(q) Screen and Evaluation for
- EPP-027, Rev. 5A, dated 7/7/14 10CFR50.54(q) Screen and Evaluation for
- EPP-103, Rev. 10, dated 5/5/14
- Corrective Action Documents 14-04988, Typo in
- EPP-27, Rev. 5A
Section 1EP5: Maintenance of Emergency Preparedness Procedures
- EP-100, Radiation Emergency Plan, Rev. 63
- EPP-103, Emergency Equipment Checklist, Rev. 10
- EPP-105, Conduct of Drills and Exercises, Rev. 10A
- EPP-106, Enclosure H, Essential Equipment Readiness PI Reporting Form, Rev. 3
- EPP-108, Emergency Action Level Technical Basis Document, Rev. 0
- SAP-0127, Emergency Preparedness, Rev. 3A
- Records and Data 2/20/13 B-to-D ERO Turnover Training Drill with C-Operations Shift, dated 3/19/13 5/22/13 A-ERO Training Drill with MERT and A-Operations Shift, dated 7/3/13
- 9/4/13 A-ERO Hostile Action Practice Drill with A-Operations Shift, dated 9/30/13
- 11/20/13 A-ERO Hostile Action Evaluated Exercise with A-Operations Shift, dated 1/23/14
- 1/28/14 D-ERO INPO Evaluated Drill with B-Operations Shift, dated 4/3/14
- QA-AUD-201303, dated 6/6/13 QA Audit Report
- QA-AUD-201405, dated 5/2/14
- Corrective Action Documents 13-02310, Procedure related items from the 5/22/13 A-ERO training drill 13-04894, Procedure related items from the 11/2013 NRC HAB graded exercise 13-04897, Alert declared which was not in accordance with the scenario
- 14-00655, Richland County Warning Point hung up prior to notification
- 14-05003, NRC Observations
Section 4OA1: Performance Indicator Verification Procedures
- EP-100, Radiation Emergency Plan, Rev. 63
- EPP-001, Activation and Implementation of Emergency Plan, Rev. 30C
- EPP-001, Attachment I, Emergency Action Level Classification Matrix, Rev. 30A
- EPP-105, Conduct of Drills and Exercises, Rev. 10A
- EPP-106, Emergency Preparedness Performance Indicator Procedure, Rev. 3
- EPP-108, Emergency Action Level Technical Basis Document, Rev. 0
- Records and Data Drill and Exercise Performance opportunities documentation from 4th Quarter 2013, through 2nd Quarter 2014
- Drill and exercise participation records of ERO personnel from 4th Quarter 2013, through 2nd Quarter 2014
- Siren Test results from 4th Quarter 2013 through 2nd Quarter 2014
- Corrective Action Documents 13-04085, Determine why the Shift Supervisor never declared the expected Unusual Event EAL
- 14-00638, UE declared due to earthquake felt in control room
- 14-04436, Less than 25 DEP opportunities were provided during the 2nd quarter LOR training 14-04932, Error in 3Q13 DEP data
Section 4OA5: Other Activities
- Licensee Documents Calculations DC02160-001, Development of Final Boring Logs, Revision 2 DC02160-002, Development of Geotechncial Parameters, Revision 2 DC02160-003, Evaluation of Liquefaction Potential and Post Earthquake Settlement under the ISFSI Pad, Revision 5
- DC02160-004, ISFSI Pad Overturning, Sliding and Bearing Capacity, Revision 3 DC02160-005, ISFSI Pad Settlements, Revision 3 DC02160-007, Evaluation of ISFSI Pad Subgrade, Revision 4
- DC02160-023, STRUCTURAL DESIGN OF ISFSI AREA DUCT BANKS, Revision 1 DC02160-025, Structural Analysis of ISFSI Pad at VC Summer, Revision 2
- DC04160-020,
- DC08610-006, ISFSI Storage Pad Grounding Analysis, Revision 3
Condition Reports
(CRs)
- CR-05-01298, NRC Regulatory Issue Summary (RIS) 2005-05:
- Regulatory Issues Regarding Criticality Analyses for Spent Fuel Pools and Independent Spent Fuel Storage Installations.
- Regulatory information that requires review for impact to VCSNS.
- CR-12-00517, Used Fuel Storage Project ECR issue schedule is in jeopardy.
- ECR 50717 (FHB Crane Trolley Replacement) interface review was completed approximately 2
months late.
- CR-13-00163, Environmental Groundwater Site #109 was decommissioned as part of the ISFSI project.
- The well is no longer required by the latest Hydrogeological Study, and needs to be removed from the ODCM and HPP-1022.
- CR-13-01663, ISFSI dirt spoils area, behind the VBS and near the industrial ponds is blocking the drain path for water to drain from the field.
- During heavy rains, the water is backing up in the field due to the silt fencing; dirt and rock blocking the trench for water to drain out of the field.
- CR-13-02430, QC review of SHAW/CB&I Erosion Control Inspection Reports associated with ISFSI project identified the last inspection, performed by a Certified Erosion Prevention and Sediment Control Inspector was on 12/20/2012.
- Since this date, weekly erosion control inspections have been performed by uncertified personnel.
- The question raised is whether we are in compliance with DHEC permit requirements for erosion control pertaining to weekly inspections by a certified inspector.
- CR-13-03172, During the Security audit
- QA-AUD-201308, several recommendations were made by the audit team.
- CR-13-04302, ISFSI Project - Scheduled activity to pour concrete for the North Duct Bank from ISFSI Pad Edge to center sections within ISFSI Pad.
- Upon review of as-builts provided by surveyor, the surveyor used questioning attitude for the height of the installed conduits.
- Request CB&I Engineering to review as-builts and provide feedback.
Drawings
- 1MS-81-001, Dry Fuel Storage Project Cask Storage Pad Details, Sheet 1 of 3, Revision 3 1MS-81-001, Dry Fuel Storage Project Cask Storage Pad Details, Sheet 2 of 3, Revision 3
- 1MS-81-001, Dry Fuel Storage Project Cask Storage Pad Details, Sheet 3 of 3, Revision 3
- E-008-003, ISFSI Storage Pad Layout Plan, Revision A
- E-216- 041, Underground Electrical ISFSI Ductbank and Manhole Plan, Sheet 2, Revision A
- E-216- 041, Underground Electrical ISFSI Ductbank Sections, Sheet 3, Revision A E-216- 041, Underground Electrical ISFSI Ductbank Details, Sheet 4, Revision A E-216- 041, Underground Electrical ISFSI Ductbank Sections and Details, Sheet 5, Revision A
- E-219-186, ISFSI Overall Grounding Plan, Sheet 1, Revision E
- E-232-002, ISFSI Pad Embedded Conduit Plan and Details, Sheet 1, Revision A E-232-002, ISFSI Pad Embedded Conduit Plan and Details, Sheet 2, Revision E E-232-002, ISFSI Pad Embedded Conduit Plan and Details, Sheet 3, Revision C
- E-232-002, ISFSI Pad Embedded Junction Box Cage, Sheet 5, Revision C
- E-434-207, ISFSI Storage Pad - Plan, Sections, and Details, Revision B
- E-744-501, ISFSI Storage Pad - Final Grading Plan, Revision A
- Specifications
- SP-0850, Design, Fabrication, Delivery, & Implementation of a Spent Fuel Dry Storage System, Revision 2
- SP-0853, Construction of an Independent Spent Fuel Storage Installation, Revision 3
- SP-0854, Construction of an Independent Spent Fuel Storage Installation, Revision 3
Other Documents
- Reviewed 7-Day Compressive Test Results for North Section of ISFSI Pad
- 28-Day Compressive Test Results for North Section of ISFSI Pad
- 50.59 Screening Evaluation of Engineering Change Request (ECR) 50793A, Construct ISFSI Pad for Used Fuel Storage, Revision 0 50.59 Screening Evaluation of Engineering Change Request (ECR) 50794, Construct Haul Path for Used Fuel Storage, Revision 0 Engineering Change Request (ECR) 50792, Relocate Underground Utilities for Used Fuel Storage, dated 10/26/2012
- ECR 50793A, Construct ISFSI Pad for Used Fuel Storage, dated 4/17/2013 Engineering Information Request (EIR) 82002, Evaluation of Impacts during ISFSI Construction, Revision A ISFSI Pad Construction Daily Field Density Report for June 4, 2014
- ISFSI Pad Construction Daily Field Density Report for June 5, 2014 ISFSI Pad Construction Daily Field Density Report for June 6 and 7, 2014 Laboratory Test Results of ISFSI Structural Fill/Engineered Control Fill from On-Site Stockpile on May 16, 2014 Laboratory Test Results of ISFSI Structural Fill/Engineered Control Fill from ISFSI Pad Construction Lift #2 on June 6, 2014 Laboratory Test Results of ISFSI Structural Fill/Engineered Control Fill from ISFSI Pad Construction Lift #4 on June 11, 2014 Management Plan for Project Quality (MPPQ) for the Independent Spent Fuel Storage Installation (ISFSI) Pad, Dated 5/14/2014 Manufacturing Surveillance 2013-0098, Procurement Quality and Quality Control Inspection/Evaluation of VCSNS Units 2 and 3 Batch Plant to NRMCA Recommendations Nonconformance & Disposition Report 1497940010-ND-14-000014, Revision 0 Quality Assurance Oversight Plan for the V. C. Summer the Independent Spent Fuel Storage Installation Project, Revision 1, dated 7/22/2014 QA-
- SUR-201301-0, Design Engineering Activities Surveillance for the V. C. Summer ISFSI Project QA-
- SUR-201307, ISFSI Project QA-
- SUR-201354510, ISFSI - Observation of Work Activities Associated with
- ECR 50791 TR02160-002, Engineering Services Technical Report, Geotechnical and Geophysical Investigation Plan, Revision 0
- TR02160-006, Engineering Services Technical Report, Final Test Report, Laboratory Testing of Soils for the Spent Fuel Dry Storage Project at V.C. Summer Nuclear Station, Revision 0 TR02160-007, Engineering Services Technical Report, Haul Path Evaluation Report, Revision 0 TR02160-009, Engineering Services Technical Report, Geotechnical Design Report, South Carolina Electric and Gas Company, V.C. Summer Nuclear Station, Revision 0 Technical Requirements Package (TRP)-43, ISFSI Storage Pad and Temperature Monitoring System, Revision 1
- CB&I Documents Nuclear Quality Site Instruction (QSI)
- QSI 11.1, Sampling and Testing of Concrete and Concrete Related Materials, Revision 001
- QSI 11.3, V. C. Summer Civil Materials Testing Laboratory Quality System Manual Development and Control, Revision 001
- Construction Site Instructions U1-CSI 3-30-0, Batch Plant and Delivery Equipment - Testing, Calibration, and Certification, Revision 0 U1-CSI 3-31-0, Concrete Batch Plant Operations, Revision 0 U1-CSI 3-32-0, Concrete Batch Plant Mix and Material Control, Revision 0
- U1-CSI 03-33-0-B - Concrete Field Testing and Curing Records, Revision 0, Change B
- U1-CSI 3-36-0, Unit 1 Field Adjustment of Fresh Concrete, Revision 0
- U1-CSI 3-42-0, Unit 1 Bending and Cutting Reinforcing Steel, Revision 0
- Quality Inspection Plans
- VS1-F-C113-001, Unit 1, ISFSI Concrete Placement Inspection, Revision 1, Change 3
- VS1-F-C114-001, Unit 1, ISFSI Concrete Post-Placement Inspection, Revision 2
LIST OF ACRONYMS
CFR Code of Federal Regulations
CoC Certificate of Compliance
NCV Non-Cited Violation
TDEFW Turbine Driven Emergeny Feedwater
TS Technical Specification
U1 Unit 1
WANO World Association of Nuclear Operators