Text

NRC Problem Identification and Resolution Inspection Report 05000395/2016007 and Notice of Violation
	ML16327A378
Person / Time
Site:	Summer
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

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

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 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

ML16327A378

Text

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