IR 05000395/2011004

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IR 05000395-11-004, on 07/01/2011 - 09/30/2011, Virgil C. Summer Nuclear Station, Routine Integrated Inspection Report, Event Followup
ML113000300
Person / Time
Site: Summer South Carolina Electric & Gas Company icon.png
Issue date: 10/27/2011
From: Walker S A
NRC/RGN-II/DRP/RPB5
To: Gatlin T D
South Carolina Electric & Gas Co
References
IR-11-004
Download: ML113000300 (40)


Text

October 27, 2011

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 - NRC INTEGRATED INSPECTION REPORT 05000395/2011004

Dear Mr. Gatlin:

On September 30, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Virgil C. Summer Nuclear Station. The enclosed inspection report documents the inspection results, which were discussed on October 24, 2011, with you and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

This report documents one self-revealing finding of very low safety significance (Green) which was determined to be a violation of NRC requirements. However, because of the very low safety significance and because it was entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV) consistent with Section 2.3.2.a of the NRC's Enforcement Policy. If you contest any NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the United States 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 Virgil C. Summer Nuclear Station.

Additionally, if you disagree with the characterization of any finding 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 Virgil C. Summer Nuclear Station.

SCE&G 2 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 document 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/

Shakur A. Walker, Acting Chief Reactor Projects Branch 5 Division of Reactor Projects

Docket No.: 50-395 License No.: NPF-12

Enclosure:

NRC Integrated Inspection Report 05000395/2011004

w/Attachment:

Supplemental Information cc w/encl: (See page 3)

_ML113000300____________ XSUNSI REVIEW COMPLETE X FORM 665 ATTACHED OFFICE RII:DRP RII:DRP RII:DRP RII:DRS RII:DRS RII:DRP SIGNATURE JTR ETC1 SON RKH1 by email MKM3 SAW4 NAME JReece ECoffman SNinh RHamilton MMeeks SWalker DATE 10/21/2011 10/21/2011 10/27/2011 10/20/2011 10/18/2011 10/27/2011 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO SCE&G 3 cc w/encl: Division of Radiological Health TN Dept. of Environment & Conservation 401 Church Street Nashville, TN 37243-1532 J. B. Archie Senior Vice President Nuclear Operations South Carolina Electric & Gas Company Electronic Mail Distribution Sandra Threatt, Manager Nuclear Response and Emergency Environmental Surveillance Bureau of Land and Waste Management Department of Health and Environmental Control Electronic Mail Distribution Kathryn M. Sutton, Esq.

Morgan, Lewis & Bockius LLP Electronic Mail Distribution Richard Haynes Director, Division of Waste Management Bureau of Land and Waste Management S.C. Department of Health and Environmental Control Electronic Mail Distribution

Mark Yeager Division of Radioactive Waste Mgmt. S.C. Department of Health and Environmental Control Electronic Mail Distribution

Andy T. Barbee Director Nuclear Training South Carolina Electric & Gas Company Electronic Mail Distribution

Bruce L. Thompson Manager Nuclear Licensing (Mail Code 830) South Carolina Electric & Gas Company Electronic Mail Distribution

Robert M. Fowlkes General Manager Engineering Services South Carolina Electric & Gas Company Electronic Mail Distribution Senior Resident Inspector Virgil C. Summer Nuclear Station U.S. NRC 576 Stairway Road Jenkinsville, SC 29065 R. J. White Nuclear Coordinator S.C. Public Service Authority Mail Code 802 Electronic Mail Distribution

Robin R. Haselden General Manager Organizational Development & Effectiveness South Carolina Electric & Gas Company Electronic Mail Distribution George A. Lippard, III General Manager Nuclear Plant Operations South Carolina Electric & Gas Company Electronic Mail Distribution Moses Coleman Manager, Health Physics and Safety South Carolina Electric & Gas Company Electronic Mail Distribution Robert L. Justice Manager Nuclear Operations South Carolina Electric & Gas Company Electronic Mail Distribution Donald D. Shue Manager Maintenance Services South Carolina Electric & Gas Company Electronic Mail Distribution

SCE&G 4 Letter to Thomas from Shakur A. Walker dated October 27, 2011

SUBJECT: VIRGIL C. SUMMER NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT 05000395/2011004 Distribution w/encl

C. Evans, RII L. Douglas, RII OE Mail RIDSNRRDIRS PUBLIC RidsNrrPMSummer Resource

Enclosure U. S. NUCLEAR REGULATORY COMMISSION REGION II

Docket No.: 50-395 License No.: NPF-12

Report No.: 05000395/2011004 Licensee: South Carolina Electric & Gas (SCE&G) Company

Facility: Virgil C. Summer Nuclear Station Location: P.O. Box 88 Jenkinsville, SC 29065 Dates: July 1, 2011 through September 30, 2011

Inspectors: J. Reece, Senior Resident Inspector E. Coffman, Resident Inspector R. Hamilton, Senior Health Physicist (Sections 2RS2, 2RS3, 2RS4, 2RS5, 4OA1.2) M. Meeks, Operations Engineer (Section 1R11.2)

R. Kellner, Health Physicist (Section 4OA3.2)

Approved by: Shakur A. Walker, Acting Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000395/2011004; 07/01/2011 - 09/30/2011: Virgil C. Summer Nuclear Station; Routine Integrated Inspection Report. Event Followup.

The report covered a 3 month period of inspection by resident inspectors and reactor inspectors from the region

. One finding was identified and was determined to be a non-cited violation (NCV). The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SDP). The cross-cutting aspect was determined using IMC 0310, "Components Within the Cross Cutting Areas." Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process" Revision 4, dated December 2006.

A. NRC-Identified and Self-Revealing Findings

Cornerstone: Mitigating System

Green.

A self-revealing, non-cited violation was identified for the failure to comply with Technical Specification 6.8.1 to adequately implement a main steam operating procedure during manipulation of the 'C' main steam isolation valve (MSIV) resulting in excessive steam generator line differential pressure and subsequent safety injection. The issue was entered into the licensee's corrective action program as condition report CR-11-03001.

The failure to implement a procedure for manipulation of the 'C' MSIV was a performance deficiency (PD). The PD was more than minor and therefore a finding because it impacted the initiating events cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown and the related attribute of human performance because the licensee failed to properly implement a procedure controlling the manipulation of a MSIV. In accordance with Inspector Manual Chapter 0609, "Significant Determination Process," the inspectors performed a Phase 1 analysis and determined the finding was of very low safety significance or Green because the finding did not contribute to both the likelihood of both a reactor trip and the unavailability of mitigation equipment and associated functions. This finding involved the cross-cutting area of human performance, the component of the resources, and the aspect of procedure use and adherence, H.4(b), because the licensee failed to adequately follow procedures.

(Section 4OA3.1)

B. Licensee-Identified Violations

A violation of very low safety significance that was identified by the licensee has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensee's corrective action program. This violation and corrective action tracking number are listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status

The unit began the inspection period at full Rated Thermal Power (RTP) and operated at or near full RTP for the remainder of the quarter.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

1R01 Adverse Weather Protection

.1 External Flooding

a. Inspection Scope

The inspectors reviewed the licensee's external flood design mitigation plans to determine consistency with design requirements, updated final safety analysis report (UFSAR) Sections 2.4.2 through 2.4.10, flood analysis documents, Emergency Plan Procedure (EPP)-015, Revision (Rev.) 17, "Natural Emergency", and OAP-109.1, Rev. 3A, "Guidelines for Severe Weather." The inspectors performed walkdowns of the station to verify flood protection features remained as described in the FSAR. Specifically, the inspectors performed visual examinations of the yard storm drain system inside the protected area to verify that drains were not blocked and the ground was properly graded to channel water into the system.

b. Findings

No findings were identified.

1R04 Equipment Alignment

a. Inspection Scope

The inspectors conducted three 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 (WO) and related condition reports (CR) 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. Documents reviewed are listed in the Attachment.

  • 'A' and 'B' component cooling water (CCW) during planned maintenance on the 'C' CCW pump'
  • 'B' reactor building spray (RBS) pump during planned maintenance on the 'A' RBS pump

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Fire Protection Tours

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. The inspectors conducted routine inspections of the following eight areas (respective fire zones also noted):

  • Control room (fire zone CB-17.1)
  • Turbine building (fire zone TB-1)
  • Control building cable spreading rooms (fire zones CB-4, CB-15)
  • Intermediate building 412' elevation (fire zones IB-25.1.1, 1.2, 1.3, 1.5)
  • Diesel generator rooms A and B (fire zones DG-1.1/1.2, DG-2.1/2.2)
  • Control building cable spreading rooms (fire zones CB-1.1, CB-1.2, CB-2, CB-5)
  • Battery and charger rooms A and B (fire zones IB-2, 3, 4, 5, 6)
  • Control building 482' elevation (fire zones CB-22, CB-23)

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

.1 Quarterly Resident Inspector Observations

a. Inspection Scope

The inspectors observed an operator requalification simulator scenario which involved a failure of main turbine first stage pressure, a failure of a nuclear instrumentation channel, a large break loss of coolant accident, a failure of the reactor to automatically trip, a failure of safety injection to automatically initiate, and a failure of the 'A' emergency diesel generator to automatically start. The inspectors observed crew performance in terms of 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 manager, including the ability to identify and implement appropriate TS actions and when required, emergency action levels as the Site Emergency Manager. The inspectors observed the post training critique to determine that weaknesses or improvement areas revealed by the training were captured by the instructor, reviewed with the operators, and appropriate corrective actions initiated.

b. Findings

No findings were identified.

.2 Biennial Licensed Operator Requalification Inspection

a. Inspection Scope

The inspectors reviewed the facility operating history and associated documents in preparation for this inspection. During the week of August 8 - 12, 2011, the inspectors reviewed documentation, interviewed licensee personnel, and observed the administration of operating tests associated with the licensee's operator requalification program. Each of the activities performed by the inspectors was done to assess the effectiveness of the facility licensee in implementing requalification requirements identified in 10 CFR Part 55, "Operators' Licenses." The evaluations were also performed to determine if the licensee effectively implemented operator requalification guidelines established in NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," and Inspection Procedure 71111.11, "Licensed Operator Requalification Program." The inspectors also evaluated the licensee's simulation facility for adequacy for use in operator licensing examinations using ANSI/ANS-3.5-1985, "American National Standard for Nuclear Power Plant Simulators for use in Operator Training and Examination." The inspectors observed three crews during the performance of the operating tests. Documentation reviewed included written examinations, Job Performance Measures (JPMs), simulator scenarios, licensee procedures, on-shift records, simulator modification request records, simulator performance test records, operator feedback records, licensed operator qualification records, remediation plans, watchstanding records, and medical records. The records were inspected using the criteria listed in Inspection Procedure 71111.11. Documents reviewed during the inspection are documented in the List of Documents Reviewed.

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 structures, systems, and components (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 (MPFFs) or other MR findings existed that the licensee had not identified.

The inspectors reviewed the licensee's controlling procedures, i.e., engineering services procedure (ES)-514, Rev. 5, "Maintenance Rule Implementation," and station administrative procedure (SAP)-0157, Rev. 0A, "Maintenance Rule Program," to verify consistency with the MR requirements.

  • CR-11-02734, on starting 'B' SW booster pump the respective discharge valve, XVB03107B-SW, did not open

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors evaluated, 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 2011-29: risk assessments for 'B' emergency diesel generator (EDG) maintenance and kW meter calibration resulting in a Yellow risk status
  • Work Week 2011-34: risk assessment for 'B' train SW pump related component maintenance resulting in a Yellow risk status
  • Work Week 2011-35: risk assessments for scheduled maintenance on 'A' EDG and related components resulting in a Yellow risk status
  • Work Week 2011-36: risk assessment for scheduled maintenance on TDEFW resulting in Yellow risk status
  • Work Week 2011-40: risk assessments for switchyard upgrades and 'C' SW component work resulting in a Yellow risk status

b. Findings

No findings were identified.

1R15 Operability Evaluations

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. Also, the inspectors verified that the operability evaluations were performed in accordance with SAP-209, Rev. 0E, "Operability Determination Process," and SAP-999, Rev. 5, "Corrective Action Program."

  • CR-11-03323, Chilled water piping not evaluated in flooding calculation for 1DB switchgear room
  • CR-11-03505, Air intensifier cycles frequently due to an exhaust air leak on the 1A feedwater isolation valve's control block; specifically, Action 1 to evaluate the current valve condition following regulator adjustment
  • CR-05-04504, 'B' SW pump vacuum breaker sprays down terminal boxes
  • CR-11-04060, Forward leakage through motor driven EFW flow control valves
  • CR-11-02173, Reactor vessel head vent system not analyzed for water relief

b. Findings

No findings were identified.

1R18 Plant Modifications

Temporary Modification

a. Inspection Scope

For the one equipment change listed below that was considered a temporary modification, the inspectors witnessed aspects of the implementation and evaluated the change for adverse effects on system availability, reliability, and functional capability.

Documents reviewed, as applicable, included associated 10 CFR 50.59 reviews, Engineering Technical Work Records, engineering design calculations, WOs and implementation packages, corrective action documents, applicable sections of the UFSAR, TS, and design basis information.

  • Bypass Authorization Request (BAR) 11-01, install jumper to disable the 'A' chiller low SW flow alarm.

b. Findings

No findings were identified.

1R19 Post Maintenance Testing

a. Inspection Scope

For the five 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, Rev. 5A, "Post Maintenance Testing Guideline."

  • WO 1100801, PMT for inspection/replacement of components on the SW pump 'B' vacuum breaker
  • WO 1005376, Replace 9 and 9C movable contact on 'A' EDG local, remote and maintenance switch
  • WO 1113791, Replace faulty expansion valve on the 'A' chiller

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors observed and/or reviewed the six 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-220.001, "Motor Driven Emergency Feedwater Pump and Valve Test," Rev. 9
  • STP-205.004, "RHR Pump and Valve Operability Test," Rev. 7 Other Surveillance Tests
  • STP-125.002B, "Diesel Generator 'B' Operability Test," Rev. 2
  • STP-125.013A, "Diesel Generator 'A' Semi-Annual Operability Test," Rev. 0
  • STP-345.037, "Solid State Protection System Actuation Logic and Master Relay Test Train 'A'," Rev. 18
  • STP-345.077, "Engineered Safety Feature Actuation Slave Relay Test for Train 'B' XPN-7021," Rev. 5

b. Findings

No findings were identified.

Cornerstone:

Emergency Preparedness 1EP6 Drill Evaluation

Emergency Preparedness Drill

a. Inspection Scope

On August 31, 2011, the inspectors reviewed and observed the performance of a emergency preparedness drill that involved a steam generator tube rupture, fuel failure, a trip of an emergency diesel generator, and a main feedwater pipe break which required entry into increasing emergency action levels starting with an Alert 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.

RADIATION SAFETY

2RS2 As Low As Reasonably Achievable (ALARA)

a. Inspection Scope

ALARA Program Status The inspectors reviewed and discussed plant exposure history and current trends including the site's three-year rolling average (TYRA) collective exposure history for calendar year (CY) 2007 through CY 2009. Current and proposed activities to manage site collective exposure and trends regarding collective exposure were evaluated through review of previous TYRA collective exposure data and review of the licensee's 5-year ALARA program implementing plan. Current ALARA program guidance and recent changes, as applicable, regarding estimating and tracking exposure were discussed and evaluated.

Radiological Work Planning The inspectors reviewed planned work activities and their collective exposure estimates for U1RFO19 (Unit 1 Refueling Outage 19) work activities and the subsequent actual exposures. For the selected tasks, the inspectors reviewed dose mitigation actions and the established dose goals. During the inspection, use of remote technologies, including teledosimetry and remote visual monitoring, were verified as specified in RWP or procedural guidance. Collective dose data for selected tasks were compared with estimates and, where applicable, changes to established estimates were discussed with responsible licensee ALARA planning representatives. The inspectors reviewed previous post-job reviews conducted for the cycle 18 and 19 refueling outages and verified that the items were entered into the licensee's CAP for evaluation. The licensee's use of a reference outage for estimating plant exposures and decreasing or increasing the plants dose goals based on trend point survey data was reviewed.

Verification of Dose Estimates and Exposure Tracking Systems The inspectors reviewed select ALARA work packages and discussed assumptions with responsible planning personal regarding the bases for the current estimates. The licensee's on-line RWP cumulative dose data bases used to track and trend current personal and cumulative exposure data and/or to trigger additional ALARA planning activities in accordance with current procedures were reviewed and discussed.

Source Term Reduction and Control The inspectors reviewed historical dose rate trends for shutdown chemistry, cleanup, and resultant chemistry and RP trend-point data against the recent U1RFO19 data. The inspectors reviewed the correlation of the exposure trends to the various exposure reduction initiatives taken over the years with historical data.

Problem Identification and Resolution The inspectors reviewed and discussed selected CRs associated with ALARA program implementation. The reviewed items included CRs, self-assessments, and quality assurance audit documents. The inspectors evaluated the licensee's ability to identify, characterize, prioritize, and resolve the identified issues in accordance with licensee procedure SAP-0999, "Corrective Action Program," Rev. 7.

The licensee's ALARA program activities and results were evaluated against the requirements of UFSAR Section 12; TS Sections 6.8 Procedures and Programs, 6.11 Radiation Protection, and 6.12 High Radiation Areas; 10 CFR Parts 19 and 20; and approved licensee procedures. Records reviewed are listed in Sections

2RS1 and 2RS2 of the report Attachment.

b. Findings

No findings were identified.

2RS3 In-Plant Airborne Radioactivity Control and Mitigation

a. Inspection Scope

Engineering Controls The inspectors reviewed the use of temporary and permanent engineering controls to mitigate airborne radioactivity inside the auxiliary building and radioactive waste processing building. The inspectors reviewed and discussed the use of negative pressure units (NPUs) and vacuums to control contamination, observed physical controls in place to prevent unauthorized use of NPUs and vacuums, and reviewed NPU testing records. The inspectors also reviewed ventilation flow, charcoal, and High Efficiency Particulate Air (HEPA) filter test records for the Control Room Emergency Filter and Reactor Building Ventilation Systems. The inspectors evaluated the effectiveness of continuous air monitors and air samplers placed in work area "breathing zones" to provide indication of increasing airborne levels. In addition, plant guidance and its implementation for the monitoring of potential airborne beta-gamma and alpha-emitting radionuclides were reviewed and discussed with licensee representatives.

Respiratory Protection Equipment The inspectors reviewed the use of respiratory protection devices to limit the intake of radioactive material. This included review of program guidance for issuance and use of respiratory protection devices, discussion with responsible licensee representatives, and review of devices used for routine tasks and devices stored for use in emergency situations. Selected whole-body count (WBC) routine and investigative analysis results for occupational workers were reviewed and discussed.

The inspectors toured selected onsite air compressors available for supplying breathing air for and filling of Self-Contained Breathing Apparatus (SCBA) bottles and reviewed recent air quality sampling results. Training, fit testing, and medical qualifications for selected HP, maintenance, operations and support staff were reviewed. The inspectors observed administration of a negative pressure respirator (NPR) fit test and SCBA qualification practical factor. The inspectors reviewed the current status, operability and availability of selected SCBA equipment maintained within the technical support center, control room, and fire brigade staging facilities. This review included material condition, number of units, number of spare masks and bottles, the last two years maintenance records and compliance with various regulatory requirements.

SCBA for Emergency Use Maintenance activities for selected respiratory protective equipment, e.g., compressed gas cylinders, regulators, valves, and hose couplings, by certified vendor technicians was evaluated for selected SCBA units. For selected control room operators, the inspectors discussed annual hands-on SCBA training activities including donning, doffing and functionally checking SCBA equipment and availability of corrective lens, as applicable, for on-shift personnel.

Problem Identification and Resolution CRs associated with airborne radioactivity mitigation and respiratory protection were reviewed and assessed. The inspectors evaluated the licensee's ability to identify and resolve the issues in accordance with procedure SAP-0999, "Corrective Action Program," Rev. 7. Documents reviewed are listed in Section

2RS3 of the Attachment to this report.

Licensee activities associated with the use of engineering controls and respiratory protection equipment and airborne radioactivity monitoring and controls were evaluated against details and requirements documented in UFSAR Sections 11 and 12; TS Section 6.8, Procedures; 10 CFR Part 20; Regulatory Guide 8.15, Acceptable Programs for Respiratory Protection; and approved licensee procedures. Documents reviewed are listed in Section

2RS3 of the report Attachment.

b. Findings

No findings were identified.

2RS4 Occupational Dose Assessment

a. Inspection Scope

External Dosimetry The inspectors reviewed National Voluntary Laboratory Accreditation Program (NVLAP) certification data (including TLD testing for neutron, gamma, and beta exposures) and discussed program guidance for storage, processing, and results for active and passive personnel dosimeters currently in use. Comparisons between ED and personnel dosimeter data were discussed in detail.

Internal Dosimetry Program guidance (including derived air concentration (DAC)-hr tracking), instrument detection capabilities, and assessment results for internally deposited radionuclides were reviewed in detail. The inspectors reviewed selected routine and investigative in vivo (Whole Body Count) analyses from January 2010 to June 2011. In addition, capabilities for collection and analysis of special bioassay samples were evaluated and discussed with licensee staff.

Special Dosimetric Situations The inspectors evaluated the licensee's use of multi-badging, extremity dosimetry, and dosimeter relocation within non-uniform dose rate fields and discussed worker monitoring in neutron areas with licensee staff. The inspectors also reviewed records of monitoring for declared pregnant workers from January 2009 to June 2011 and discussed monitoring guidance with licensee staff. In addition, the adequacy of shallow dose assessments for selected Personnel Contamination Events occurring between January 2010 and June 2011 were reviewed and discussed.

Problem Identification and Resolution The inspectors reviewed and discussed selected CAP documents associated with occupational dose assessment. The inspectors evaluated the licensee's ability to identify and resolve the identified issues in accordance with procedure SAP-0999, "Corrective Action Program," Rev. 7. The inspectors also discussed the scope of the licensee's internal audit program and reviewed recent assessment results.

HP program occupational dose assessment activities were evaluated against the requirements of UFSAR Section 12.3; TS Section 6.8; 10 CFR Parts 19 and 20; and approved licensee procedures. Records reviewed are listed in Section

2RS4 of the report Attachment.

b. Findings

No findings were identified.

2RS5 Radiation Monitoring Instrumentation

a. Inspection Scope

Radiation Monitoring Instrumentation: During tours of the auxiliary building, spent fuel pool areas, and RCA exit point, the inspectors observed installed radiation detection equipment including the following instrument types: area radiation monitors (ARM), continuous air monitors (CAM), liquid and gaseous effluent monitors, personnel contamination monitors (PCM), small article monitors (SAM), and portal monitors (PM). The inspectors observed the physical location of the components, noted the material condition, and compared sensitivity ranges with UFSAR requirements.

In addition to equipment walk-downs, the inspectors observed source checks and alarm setpoint testing of various portable and fixed detection instruments, including ion chambers, telepoles, PCM, SAM, and PM. For the portable instruments, the inspectors observed the use of a high-range calibrator and discussed periodic output value testing with a radiation protection technician. The inspectors reviewed the last two calibration records and evaluated alarm setpoint values for selected ARM, PCM, PM, SAM, effluent monitors, laboratory counting systems, and WBC systems. This included a sampling of instruments used for post-accident monitoring such as containment high-range ARMs, and effluent monitor high-range noble gas and iodine channels. Radioactive sources used to calibrate selected ARMs and effluent monitors were evaluated for traceability to national standards. Calibration stickers on portable survey instruments and air samplers were noted during inspection of storage areas for equipment available for issue. The most recent 10 CFR Part 61 analysis for dry active waste (DAW) was reviewed to determine if calibration and check sources are representative of the plant source term. The inspectors also reviewed countroom quality assurance records for alpha and gamma ray spectroscopy equipment.

Effectiveness and reliability of selected radiation detection instruments were reviewed against details documented in the following: Applicable parts of TS Section 3.4; UFSAR Chapters 11 and 12; and applicable licensee procedures. Documents reviewed during the inspection are listed in Section

2RS5 of the report Attachment.

Problem Identification and Resolution: The inspectors reviewed and discussed selected Corrective Action Program (CAP) documents associated with radiological instrumentation. The reviewed items included CRs, self-assessment, and quality assurance audit documents. The inspectors evaluated the licensee's ability to identify, characterize, prioritize, and resolve identified issues in accordance with licensee procedure, SAP-0999, "Corrective Action Program," Rev. 7. Documents reviewed are listed in Section

2RS5 of the Attachment to this report.

b. Findings

No findings were identified.

OTHER ACTIVITIES

4OA1 Performance Indicator (PI) Verification

.1 Cornerstone Mitigating Systems

a. Inspection Scope

The inspectors verified the accuracy of the licensee's PI submittals listed below for the period July 2010 through June 2011. The inspectors used the performance indicator definitions and guidance contained in Nuclear Energy Institute (NEI) 99-02, Rev. 6, "Regulatory Assessment Performance Indicator Guideline," and licensee procedure SAP-1360, Rev. 1, "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. Also, the inspectors discussed the PI data with the licensee personnel associated with the performance indicator data collection and evaluation.

  • Mitigating System Performance Index (MSPI) - Emergency AC Power System
  • MSPI - High Head Safety Injection System

b. Findings

No findings were identified.

.2 Public Radiation Safety Cornerstone

a. Inspection Scope

The inspectors reviewed the Radiological Effluent Technical Specification/Offsite Dose Calculation Manual Radiological Effluent Occurrences PI results from January 2010 through May, 2011. The inspectors reviewed CAP documents, effluent dose data, and licensee procedural guidance for classifying and reporting PI events. Reviewed documents are listed in Section

4OA1 of the Attachment. The inspectors completed one of the required samples specified in Inspection Procedure

71151.

b. Findings

No findings were identified.

4OA2 Identification and Resolution of Problems

Review of Items Entered into the Corrective Action Program

a. Inspection Scope

As required by Inspection Procedure 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.

4OA3 Event Followup

.1 (Closed) LER 05000395/2011-003-00:

Inadvertent Safety Injection During Reactor Startup Due to Excessive Differential Steam Line Pressure and URI 2011003-04: Inadvertent Safety Injection in Mode 3 Due to Opening 'C' Main Steam Isolation Valve

a. Inspection Scope

On May 27, 2011, during a refueling outage Unit 1 was in Mode 3 with the reactor coolant system (RCS) at normal temperature and pressure when a control room operator was requested to open the 'C' main steam isolation valve (MSIV).

Subsequently, the 'C' steam generator (SG) line pressure reduced to greater than 97 psig as compared to the 'A' and 'B' SG line pressures causing a dual train safety injection. The licensee entered this problem into their CAP as CR-11-03001; the NRC opened a related unresolved item (URI) in NRC integrated report 05000395/2011003.

The enforcement aspects are discussed below. This LER and the related URI are closed.

b. Findings

Introduction:

A self-revealing, non-cited violation was identified for the failure to comply with Technical Specification 6.8.1 to adequately implement a main steam (MS) operating procedure during the manipulation of the 'C' MSIV resulting in excessive steam line differential pressure and subsequent safety injection.

Description:

On May 27, 2011, during a refueling outage Unit 1 was in Mode 3 with the RCS at normal temperature and pressure. Additionally, the licensee had performed stroke time testing of the MSIVs in which 'C' MSIV did not pass. The operators left the MSIV's closed and additionally, closed the MSIV bypass valves to maintain RCS normal operating temperature and pressure. During this time the MS header pressure decreased and was not maintained close to the individual SG line pressures. Later in the shift a control room operator, who had briefly relieved the normal control room operator, was requested to open the 'C' MSIV for troubleshooting. Subsequently, the 'C' SG line pressure reduced to greater than 97 psig as compared to the 'A' and 'B' SG line pressures causing a dual train safety injection. The licensee entered this problem into their CAP as CR-11-03001, and the inspectors completed a review of the associated root cause evaluation (RCE). The inspectors noted that the RCE identified the root cause as the failure to implement or utilize a procedure during manipulation of the 'C' MSIV. The inspectors reviewed the licensee's system operating procedure, SOP-102, "Main Steam System," and noted that step 2.15 of Section II, required that MS header pressure is within 25 psig of individual SG header pressures before opening the MSIVs in step 2.17. The inspectors also noted that TS 6.8.1 requires the implementation of procedures as recommended by Regulatory Guide 1.33, Revision 2, of which section 3.i addresses the main steam system. The inspectors concluded the licensee failed to comply with the requirement to adequately implement the respective procedure, SOP-102.

Analysis:

The inspectors determined that the failure to implement a procedure for manipulation of the 'C' MSIV was a performance deficiency (PD). The PD was more than minor and therefore a finding because it impacted the initiating events cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown and the related attribute of human performance because the licensee failed to properly implement a procedure controlling the manipulation of a MSIV. In accordance with Inspector Manual Chapter (IMC) 0609, "Significant Determination Process," the inspectors performed a Phase 1 analysis and determined the finding was of very low safety significance or Green because the finding did not contribute to both the likelihood of both a reactor trip and the unavailability of mitigation equipment and associated functions. This finding involved the cross-cutting area of human performance, the component of the resources, and the aspect of procedure use and adherence, H.4(b), because the licensee failed to adequately follow procedure SOP-102 for the manipulation of the 'C' MSIV.

Enforcement:

TS 6.8.1, "Procedures and Programs," requires in part that written procedures be implemented covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, section 3.i, "Main Steam System." Contrary to the above, on May 27, 2011, the licensee failed to adequately implement procedure SOP-102 while opening the 'C' MSIV which resulted in a SG line differential pressure and subsequent safety injection. Because this finding is of very low safety significance and has been entered into the licensee's corrective action program as condition report CR-11-03001, this violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 05000395/2011004-01, Failure to Implement a Procedure for Manipulation of the 'C' Main Steam Isolation Valve.

.2 On-Site Liquid Effluent Line Leak

a. Inspection Scope

On July 8, 2011, the licensee submitted a non-emergency report (Event Number 47039) to the NRC in accordance with 10 CFR Part 50.72(b)(2)(xi) due to offsite notification of other government agencies regarding an onsite spill of radioactive material. The voluntary notification was made to state and local officials for an on-site leak that may exceed 100 gallons, in accordance with the industry's Groundwater Protection Initiative (NEI 07-07). The report described the July 7, 2011, discovery of a leak in the liquid radwaste discharge line connecting the liquid waste processing system to the discharge point at the Fairfield Pump Storage Facility. Water from the leak in the discharge line collected on the top of the concrete structure of the Fairfield Pump Storage Facility before traveling to the surrounding soil. Analysis of samples of the water identified a Tritium concentration of 2.3 x 10 4 pCi/L, which is in excess of the NEI 07-07 voluntary reporting level of 2.0 x 10 4 pCi/L, but significantly below NRC and Federal regulatory limits established to prevent adverse affects on the health and safety of the public and the environment.

The licensee has taken corrective actions which included draining the liquid from the enclosure for return to the plant for disposal, repair of the liquid radwaste line leak, remediation of the soil around the leak location, entering the event into the decommissioning file as required by 10 CFR Part 50.75(g), and submitting a 30-Day Special Report to the NRC (ML11216A230) per the NEI 07-07 guidance. The licensee has documented the event in their corrective action program (CR-11-03667) and is in the process of evaluating the event to determine the root cause and corrective actions to prevent recurrence. The inspectors reviewed the details surrounding the event and discussed the issue with licensee staff. The inspectors noted that the leak was contained within the owner controlled area and was not expected to migrate to the offsite environs. The NRC has designated groundwater contamination as an "issue of agency-wide concern" and has implemented requirements to document the review of voluntary reports concerning spills and leaks.

b. Findings

No findings were identified.

4OA5 Other Activities

.1 Quarterly Resident Inspector Observations of Security Personnel and Activities

a. Inspection Scope

During the inspection period, the inspectors conducted observations of security force personnel and activities to ensure that the activities were consistent with licensee security procedures and regulatory requirements relating to nuclear plant security. These observations took place during both normal and off-normal plant working hours.

These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors' normal plant status review and inspection activities.

b. Findings

No findings were identified.

.2 (Closed) VIO 05000395/2010004-01, Failure to Notify the Commission of a Change in

Medical Status

This violation identified that from September 9, 2009, to August 26, 2010, the facility licensee failed to notify the Commission within 30 days of learning of the diagnosis that a licensed operator had developed a permanent physical or medical condition, as required. Specifically, the licensed operator was placed in a "no solo" status by the facility licensee's medical review officer due to a permanent change in the individual's medical condition without notifying the Commission. This violation was entered into the facility licensee corrective action program as CR-10-00348. The licensee formally responded to the violation in a letter from Mr. T. Gatlin to the NRC dated 11/22/2010. The facility licensee has implemented corrective actions including hiring a full-time medical coordinator, revising licensee procedures associated with licensed operator medical conditions, and conducting an audit of all licensed operator medical records to determine the extent of condition.

The inspectors reviewed the licensee's actions associated with this violation. The inspectors determined that the programmatic improvements should prove effective in preventing a recurrence of this issue. The inspectors also conducted an independent review of a random sample of licensed operator medical records and verified that improvements in the quality of licensed operator medical records were noted. Additional inspection activity associated with this violation was documented in Integrated Inspection Report 050000395/2011002 (Section 4OA2.2). This violation is closed.

.3 (Closed) AV 2011003-03, Failure to Conduct Adequate Testing of Appendix R Fire Switches

The inspectors issued apparent violation (AV) 2011003-03, Failure to Conduct Adequate Testing of Appendix R Fire Switches, in NRC integrated inspection report 05000395/2011003 pending completion of a risk review by NRC regional senior reactor analysts. This review was completed, and the enforcement aspects are discussed in section

4OA7 of this report.

4OA6 Meetings, Including Exit

On October 24, 2011, the resident inspectors presented the integrated inspection results to Mr. T. Gatlin 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.

4OA7 Licensee-Identified Violations

The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of Section 2.3.2 of the NRC Enforcement Policy, for being dispositioned as an NCV.

  • License Condition 2.C.(18), "Fire Protection System," of the Virgil C. Summer Operating License NPF-12 requires, in part, that the licensee implement and maintain in effect all provisions of the approved fire protection program as described in the FSAR, and as approved in applicable Safety Evaluation Reports related to the fire protection program. FSAR Section 9.5.1 states in part, that the provisions of 10 CFR 50, Appendix R, Sections III.G, III.J, III.O, and III.L apply to the fire protection program requirements, as well as the Virgil C. Summer Fire Protection Evaluation Report (FPER), which is considered a part of the FSAR. The FSAR and FPER require Virgil C. Summer to comply with Appendix A to BTP APCSB 9.5-1, "Guidelines for Fire Protection for Nuclear Power Plants Docketed Prior to July 1, 1976," to satisfy the fire protection requirements of 10 CFR 50.48. Appendix A to BTP APCSB 9.5-1, Position C.5, "Test and Test Control," requires in part, that a test program be established and implemented to assure that testing is performed and verified by inspection to demonstrate conformance with the design and system readiness requirements. Contrary to these requirements, the licensee failed to implement and maintain in effect all provisions of the approved fire protection program as described in the FSAR for the facility, in that, the Appendix R fire switch test program did not adequately verify that the switches were capable of performing their required isolation function. This finding has been entered into the licensee's corrective action program as condition report CR-10-01814.

The finding affected safe shutdown and was judged to represent moderate degradation. Because the finding involved main control room (MCR) fire scenarios and scenarios in multiple fire areas, a phase 3 SDP analysis was performed by a regional senior reactor analyst. The finding was determined to have existed since 1983 when a modification temporarily installed the jumper wire; therefore a one year exposure period was utilized for the analysis. Only fires which could lead to MCR abandonment requiring use of the 'B' EDG isolation switch and which also would damage the 'B' EDG output breaker control circuit would contribute to the risk of the performance deficiency. Only fire scenarios in the MCR (within the main control board (MCB)) and in the cable spreading room which impacted the cable tray and main termination cabinet associated with the 'B' EDG represented credible fire scenarios which could lead to risk from the PD. Factors which mitigated the risk from the PD included: the few credible fire ignition sources, use of thermoset cables, the low cable loading in the specific MCB section housing the EDG and offsite power circuit breaker control switches, detection in the main termination cabinet, and the proceduralized actions for local operation of the 'B' EDG breaker. The dominant sequence was a fire in either the MCR or cable spreading room damaging the EDG and offsite power breaker controls requiring MCR abandonment coupled with failure of the 'B' EDG breaker to operate due to the PD and failure of the operator to locally close the 'B' EDG breaker resulting in core damage from inadequate core cooling. The SDP phase 3 evaluation determined that the risk of the finding was an increase in core damage frequency of <1E-6/year, a Green finding of low safety significance.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

J. Archie, Senior Vice President, Nuclear Operations
A. Barbee, Director, Nuclear Training
L. Bennett, Manager, Plant Support Engineering
L. Blue, Manager, Nuclear Training
M. Browne, Manager, Quality Systems
M. Coleman, Manager, Health Physics and Safety Services
G. Douglass, Manager, Nuclear Protection Services
M. Fowlkes, General Manager, Engineering Services
T. Gatlin, Vice President, Nuclear Operations
M. Harmon, Manager, Chemistry Services
R. Haselden, General Manager, Organizational / Development Effectiveness
R. Justice, Manager, Nuclear Operations
G. Lippard, General Manager, Nuclear Plant Operations
D. Shue, Manager, Maintenance Services
W. Stuart, Manager, Design Engineering
B. Thompson, Manager, Nuclear Licensing
R. Williamson, Manager, Emergency Planning
S. Zarandi, General Manager, Nuclear Support Services

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000395/2011004-01 NCV Failure to Implement a Procedure for Manipulation of the

'C' Main Steam Isolation Valve (Section 4OA3.1)

Closed

05000395/LER-2011-003-00 LER Inadvertent Safety Injection During Reactor Startup Due to Excessive Differential Steam Line Pressure (Section 4OA3.1)
05000395/FIN-2011003-04 URI Inadvertent Safety Injection in Mode 3 Due to Opening 'C' Main Steam Isolation Valve (Section 4OA3.1)
05000395/2010004-01 VIO Failure to Notify the Commission of a Change in Medical
Status (Section 4OA5.2)
Attachment
05000395/2011003-03 AV Failure to Conduct Adequate Testing of Appendix R Fire Switches (Section 4OA5.3)

Discussed

None

LIST OF DOCUMENTS REVIEWED

Section 1R04: Equipment Alignment

Procedures

and Drawings

D-302-011, Main Steam (Nuclear), Revision 39
D-302-085, Emergency Feedwater (Nuclear), Revision 43 D-302-611, Component Cooling, Revision 39

Section 1R11: Licensed Operator Requalification Program

Records: License Reactivation Packages (3 Records Reviewed). LORP Training Attendance records (4 Records Reviewed; 2 years history). Medical Files (5 Records Reviewed). Remedial Training Records (4 Records Reviewed). Remedial Training Examinations (1 Record Reviewed). Time-on-Shift Records (3 staff Operators and SROs Reviewed; 2 years history). Feedback Summaries (all licensed operator training feedback for six (6) training cycles, LOR-
09-07 through
LOR-09-12). Final compilation of cycle exam results. Licensed Operator Requalification (LOR) program Curriculum Review Committee (CRC) Meeting minutes for three (3) calendar quarters (third quarter 2010 through first quarter 2011). Simulator Deficiency Reports (for the period July 2010-July 2011).
Written Examinations:
VCS
LOR 2011 Exam 1 SRO, administered 07/22/2011. VCS
LOR 2011 Exam 1 SRO (Retake), administered 07/29/2011. VCS
LOR 2011 Exam 3 SRO, administered 07/29/2011.
VCS
LOR 2011 Exam 3 RO, administered 07/29/2011. VCS
LOR 2011 Exam 4 SRO, administered 08/04/2011. VCS
LOR 2011 Exam 4 RO, administered 08/04/2011. VCS
LOR 2011 Exam 5 SRO, administered 08/11/2011. VCS
LOR 2011 Exam 5 RO, administered 08/11/2011.
VCS
LOR 2011 Exam 2 SRO, administered 08/18/2011. VCS
LOR 2011 Exam 2 RO, administered 08/18/2011.
Procedures:
TQP-104, Simulator Review Group, Revision 1, 02/12/2010.
TQP-304, Development, Review, Approval and Revision of Simulator Scenarios, Revision 0 Change A, 12/14/2010.
TQP-408, Development and Validation of Licensed Operator Annual Requalification Examinations, Revision 1 Change A, 03/04/2011.
TQP-408A, Scheduling and Administration of Licensed Operator Annual Requalification Examinations and Post-Examination Activities, Revision 0, 04/26/2011.
TQP-414, Simulator Training and Evaluation, Revision 0 change B, 01/06/2011.
TQP-804, Licensed Operator Requalification (LOR) Program, Revision 1, 05/25/2011.
TQP-1101, Simulator Discrepancy Reporting, Revision 30, 10/30/2009.
Simulator Steady State Tests:
IST-4.1, 100% Power Steady State Test, Revision 22, conducted 7/13/10.
Attachment IST 4.2, 75% Steady State Accuracy Test, Revision 20, conducted 7/15/10. IST 4.4, 25% Steady State Accuracy Test, Revision 6, conducted 7/16/10.
IST-11.1, Simulator Real Time Test, Revision 15, conducted 08/11/10.
Simulator Transient Tests:
IST-7.1, Simultaneous Closure of all MSIVs, Revision 15, 05/06/2008 (reviewed test results from testing performed in 2008, 2009, and 2010).
IST-7.4, Loss of Coolant Accident with Loss of Offsite Power, Revision 16, 08/06/2008 (reviewed test results from testing performed in 2008, 2009, and 2010).
IST-7.10, Maximum Rate Power Ramp, Revision 16, 08/06/2008 (reviewed test results from testing performed in 2008, 2009, and 2010).
Simulator Malfunction Tests:
IST-6.1.4.2, Loss of Service Water System, Revision 8, conducted 12/11/09.
IST-6.4.5, Ejected Rod (48 Rods), Revision 7, conducted 02/21/10.
IST-6.5.12, Leak in Charging Line, Revision 8, conducted 12/11/09.
IST-6.6.18.1, Failure of ESF Transformer
XTF-4, Revision 7, conducted 12/12/09.
IST-6.8.10, Steam Generator Safety Valve Fails Open, Revision 6, conducted 12/12/09.
IST-6.12.8.2, RCS RTD Loop Failure (Cold Leg Fails Low), Revision 7, conducted 12/13/09.
IST-6.4.4.2, Failure of Secondary Gripper, Revision 4, conducted 08/05/10.
IST-6.5.13, Letdown Leak Outside Containment, Revision 7, conducted 12/13/10.
IST-6.6.6.1, Diesel generator Failure, Revision 7, conducted 08/05/10. IST 6.6.10, Containment Cooling Fan Failure, Revision 3, conducted 08/05/10. IST 6.7.3.2, Emergency Feedwater Pump Trip, Revision 7, conducted 08/05/10. IST 6.7.15.1, FW Control Valve Position Failure-Open, Revision 5, conducted 08/10/10.
IST-6.8.3, Steamline Break Inside Containment, Revision 4, conducted 08/10/10.
IST-6.8.5.2 Steam Dump Valve Control Failure-Low, Revision 6, conducted 08/10/10.
IST-6.9.3.2, Power Range Channel Failure, Revision 6, conducted 08/10/10.
IST-6.11.4.2, Relief Valve Fails Open-Interlock Not Functional, Revision 4, conducted 08/11/10.
IST-6.11.5, Pressurizer Pressure Channel Failure (Protection), Revision 6, conducted 08/11/10.
IST-6.12.3, Reactor Coolant Pump Trip, Revision 7, conducted 08/11/10.
IST6.12.4, Reactor Coolant Pump Locked Rotor, Revision 7, conducted 08/11/10.
IST-6.12.9, RCS Media Signal Selector Failure, Revision 8, conducted 08/11/10.
Scenario Packages:
LOR-SA-006R:
25% POWER, BOL, N-44 SPIKES LOW,
PT-464 FAILS LOW, LOSS OF
XSW-1C SERVICE BUS, HIGH RCS ACTIVITY, SBLOCA, "A" SWBP FAIL TO START WITH
PVB-3107A OPEN, "B" EFW PUMP FAILURE; Revision 2; 06/08/2011.
LOR-SA-014R:
100% POWER, BOL,
NI-44 FAILS LOW, OBE EARTHQUAKE, MFP TRIP, RWST LEAK, DBALOCA; Revision 0; 06/23/2011.
LOR-SA-017R:
75% POWER, BOL, "B" RCP #1 SEAL FAILURE,
FT-487 FAILS LOW, "A" MSIV FAIL TO CLOSE, RB SPRAY PUMP FAILURES, ONE RBCU FAILURE ON SI, MSLB (IRC); Revision 8; 06/15/2011.
LOR-SA-036R:
100% POWER, BOL,
PT-508 FAILS LOW, 30 GPM SGTL, RCP#1 SEAL FAILURE, "B" CHARGING PUMP FAILURE,
PVG-503C FAIL TO CLOSE, "C" MSIV FAILS OPEN, SGTR - ALTERNATE ISOLATION; Revision 9; 07/12/2011.
LOR-SA-049R:
100% POWER, BOL,
PT-495 FAILS LOW, RCP HIGH VIBRATION, SBLOCA, CHARGING PUMP FAILURE, "A" TRAIN PHASE "A" FAILURE; Revision 11; 06/23/2011.
Attachment
LOR-SA-073R:
100% POWER, BOL,
LT-3783A/B, # 2 HTR TO DA FAILS HIGH,
PT-444 FAILS LOW, "B" CHARGING PUMP BEARING FAILURE, ATWS, PZR STEAM SPACE LEAK; Revision 14; 07/06/2011.
JPM Packages:
JPP-002C Shift Component Cooling Water Pump "C" to Fast Speed .
JPP-004B Manually Start "B" Diesel Generator I.A.W.
SOP-306 Section
IV.D.
JPP-021 Locally Control EFW Flow.
JPP-085A Local Operation of a Steamline PORV.
JPP-098 Locally Isolate Condenser From the CST.
JPP-106 Locally Isolate Condenser From the CST.
JPP-108 Locally Isolate Condenser From the CST.
JPP-112 Loss of Containment Integrity (XVG-503C).
JPP-145B Energize SI Accumulator Isolation Valves.
JPP-163B Loss of CCW (Transferring "C" CCW Pump to "B"' Train Mechanically).
JPP-181 Locally Start The Turbine Driven Emergency Feedwater Pump.
JPP-182 Isolate S/G Blowdown per
FEP-1.O.
JPP-184 Start TDEFP and Feed SGs per
FEP-4.0.
JPP-185 Locally Align HVAC Chiller per
FEP-4.0.
JPP-206 Nuclear Reactor Operator Actions for
FEP-4.0.
JPP-409 Emergency Borate by Gravity Draining the BAT to the Charging Pump Suction per
AOP-106.1.
JPP-816B Flood Containment Using In-Plant Fire Service via RB Spray Header (Train B) IAW
BDMG-7.0.
JPP-818B Flood Containment Using In-Plant Fire Service via RB Spray Pump Sump (Train B)
IAW
BDMG-7.0.
JPP-828 GAG Closed the SW to CCW Cross-Connect Valves per
AOP-220.1.
JPP-028A Startup and Parallel #1 Rod Drive M/G Set.
JPP-048 Control Room Evacuation (Duties of BOP Operator).
JPP-049 Control Room Evacuation (Duties of BOP Operator) (NRC Exam Modified Version of
JPPF-047).
JPP-066 Locally Isolate RCP Seals During a Total Loss of ESF Power
JPP-096-2 Locally Trip the Reactor.
JPP-166B Establish Chilled Water Alternate Cooling to Charging Pumps.
JPP-167B Establish Demineralized Water Alternate Cooling to Charging Pumps (Failure of
Chilled Water Supply).
JPP-403 Using Service Water For Emergency Feedwater.
JPA-021 Perform Boric Acid Dilution Volume Determination.
JPS-003 Emergency Borate.
JPS-007 Steam Generator Tube Rupture (Depressurize RCS TO < Ruptured S/G Pressure).
JPS-008 Loss Of Power Range Instrument N-44.
JPS-018 Respond To Feedwater Heater Level Malfunction.
JPS-047 Classify Emergency (GE - LOSS OF AC PWR).
JPS-051 Classify Emergency (UE - AREA RAD MON).
JPS-076 Classify Emergency (SAE- ATWS - PARS).
JPS-095 Monitor Critical Safety Functions Per
EOP-12.0.
JPS-144 Classify Emergency (UE - HOSTILE ACT).
JPS-156 Classify Emergency (GE - ATWS).
Attachment
JPS-159 Respond to RCP Hi Vibration at 100% Power.
JPSF-003 Emergency Borate.

Other Documents

Reviewed:
LER 2010-001-000:
Reactor Building Cooling Units Reduced Air Flow Rate Below Technical
Specification Limits, 06/28/2010.
LER 2010-002-001:
Unanalyzed Condition Due To Wiring Discrepancy In The "B" Emergency
Diesel Generator (EDG) Appendix R Isolation Circuitry, 04/28/2011.
LER 2010-003-000:
Inadequate Procedural Guidance Results In Violation of Technical
Specification 3.0.4 During Plant Startup, 11/22/2010.
LER 2011-001-000:
Unanalyzed Condition Due to Failure to Maintain One Train of Systems For
Safe Shutdown in Accordance With Appendix R Section
III.G.A/III.G.3, 07/01/2011.
LER 2011-002-000:
Unanalyzed Condition Due to Failure to Maintain One Train of Systems for
Safe Shutdown in Accordance With Appendix R Section
III.G.A/III.G.3, 07/01/2011.
LER 2011-003-000:
Inadvertent Safety Injection During Reactor Startup Caused By Excessive
Steam Line Differential Pressure, 07/26/2011.
CR-10-03215,
XRF-1
PNL-ETM Main Transformer Temperature Monitoring, 08/15/2010.
CR-10-03226, B Train of chill water was inadvertently drained resulting in the inoperability of B
Chill Water due to an inadequate tagout, 08/16/2010.
CR-10-04161, Corrective Actions taken in response to previously identified issues not effective in driving sustained performance improvement, 10/20/2010.
CR-10-04686, Priority A work was not authorized or performed in the scheduled time frame,
12/02/2010.
CR-11-00169, When preparing to establish flush flow to B CVCS Mixed Bed Demineralizer anticipatory to transferring resin, an incorrect valve was inadvertently operated, 1/13/2011.
CR-11-00432, Too many tagouts for the OPS shift to clear occurred on 01/27/2011.
CR-11-02692, Both EHC pumps were run without a suction path, 05/15/2011.
CR-11-03189, After hanging tags for LOTO 11-1150 it was discovered that the tagout removed power from XBA5122 requiring an unplanned entry into a seven day action IAW FPP-
027, 06/06/2011.

Condition Reports

Written as a Result of the Inspection:
CR-11-04191, Document Comments Identified by NRC during
IP 71111.11 inspection,
08/09/2011.
CR-11-04365, Simulator Comments from the 2011 NRC IP71111.11 inspection, 08/22/2011.

Section 2RS2: Occupational

ALARA Planning and Controls Procedures and Guidance Documents
HPP-0151, Use of the Radiation Work Permit and Standing Radiation Work Permit, Rev. 9
HPP-0153, Administrative Exposure Limits, Rev. 15
HPP-0401, Issuance, Termination, and Use of RWPs and SRWPs, Rev. 19
HPP-0403, Radiological Work Controls for Nuclear Work Activities, Rev. 10
SAP-500, Health Physics Manual, Rev. 11
Records and Data Reviewed
2010 Annual ALARA Report Refuel 18 Outage ALARA Report Attachment Refuel 19 Outage ALARA Plan Excel Spreadsheets for 2009, 2010 and 2011 dose goal calculations ALARA Committee Meeting Minutes, March and April 2011
RWP 11-04004, Seal Table PMs, Thimble Cleaning, and associated work
RWP 11-04101, All QC Inspections (to include support work)
RWP 11-04200, Refueling Activities
RWP 11-04201, High Risk Activities Refueling Activities
RWP 11-04301, All Work for
LCV-459 & -460 & -8085
Corrective Action Program Documents
CR-10-00432, The Dose Estimate for
RWP 09-04901 S/G Eddy Current Activities was Incorrect.
CR-11-00185, The Work Week Dose Estimate was exceeded due to Higher Dose being received during a Containment Building Entry.
CR-11-01372, CR to track action items from the 1

st Quarter 2011 ALARA Committee Meeting held on March 9, 2011. CR- 11-02384, CR Generated To Document that the RWP Task Estimate Associated with the Removal/Installation of the Reactor Head "O"-Rings Was Exceeded. CR- 11- 02972, Air Sampling Data for

RWP 11-4201 was not found During Audit of RWP Packages.

Section 2RS3: In-Plant Airborne Radioactivity Control and Mitigation

Procedures, Guidance Documents, and Manuals
HPP-154, Issuance and Control of Respiratory Protection Equipment, Rev. 12
HPP-602, Fit Testing, Rev. 14
HPP-0155, Control of Airborne Radiation Exposure (DAC-HRS), Rev. 12A
HPP-0303, Airborne Activity Sampling Techniques, Rev. 8B
HPP-0311, Alpha Monitoring, Rev. 1
HPP-0416.001, Radiological Controls for Use of Vacuum Cleaners, Rev. 0
HPP-0416.002, Radiological Controls for Use of Portable HEPA Ventilation Equipment, Rev. 0
HPP-603, Survey and Cleaning of Respiratory Protection Devices, Rev. 14
HPP-0605, Use of MSA Pressure Demand Airline Respirator with Portable Air Supply System, Rev. 5
HPP-0610, Certification of Flow Rates for Portable Air Samplers, Rev. 13
HPP-0633, Inspection, Maintenance and Storage of Respiratory Protection Devices, Rev. 5D
HPP-639, Calibration of MSA Pressure Demand Regulators, Rev. 1
HPP-0808, Sample Analysis, Rev. 13B
HPP-0825, Weighted DAC Determination for Airborne Alpha Activity, Rev. 3
Records and Data Air Sample Analysis Result, Air Sample ID SP11-1647, 05/17/2011 Air Sample Analysis Result, Air Sample
ID 1826, 05/28/2011
Laboratory Report Compressed Air/Gas Quality Testing, Report Number
107397 - 0, PLANT B AIR XAC0012, 07/19/2009 Laboratory Report Compressed Air/Gas Quality Testing, Report Number 107397-1, PLANT B AIR XAC0012, 07/19/2009
Attachment Laboratory Report Compressed Air/Gas Quality Testing, Report Number
131422 - 0, XAC0012, 08/16/2010 Laboratory Report Compressed Air/Gas Quality Testing, Report Number
107422 - 0, XAC0013 SCBA COMPRESSOR, 07/20/2009 Laboratory Report Compressed Air/Gas Quality Testing, Report Number
107422 - 1, XAC0013 SCBA COMPRESSOR, 07/20/2009 Laboratory Report Compressed Air/Gas Quality Testing, Report Number
129054 - 0, XAC0013 SCBA COMPRESSOR, 07/09/2010 Certificate of Testing, PortaCount Pro Model 8030, S/N
8030093405, 08/06/2010
Certificate of Testing, PortaCount Pro Model 8030, S/N
8030093407, 01/11/2011 Certificate of Calibration, PosiCheck 3 Model 54-20-2110, S/N L01325, 07/08/2010 MSA Respiratory Protection Equipment Test and Repair Technician Certifications: Registration No.
AM-296, 05/20/2009 Registration No.
M-0358, 05/13/2010 Registration No.
F-0358, 11/03/2010 Registration No.
AM0358, 11/03/2010 SCOTT SCBA Maintenance and Overhaul Technician Certifications dated 05/05/2009 and 08/06/2009
SA11-HP-01, Self Assessment Report-Health Physics Instrumentation and Calibration Lab, 02/02//2011 Control Room Ventilation Radiation Monitor (RMA-1) Repair/Calibration Work Package - Work Order 0904995-001, STP0360.031-RMA0001, 08/20/2009 Control Room Ventilation Radiation Monitor (RMA-1) Repair/Calibration Work Package - Work Order 1014260-001, STP0360.031-RMA0001, 12/09/2010 Fuel Handling Building Exhaust Radiation Monitor (RMA-6) Repair/Calibration Work Package - Work Order 0805059-0 11, STP0360.039-RMA0006, 08/19/2008 Fuel Handling Building Exhaust Radiation Monitor (RMA-6) Repair/Calibration Work Package - Work Order 0913759-001, STP0360.039-RMA0006, 03/25/2010 Reactor Building Charcoal Clean-Up Unit 4A, Charcoal Sample Test Work Package - Work Order: 1006484-001, Procedure: MMP0460.20-XAA0004A, 05/16/2011 Reactor Building Charcoal Clean-Up Unit 4B, Charcoal Sample Test Work Package - Work Order: 1006488-001, Procedure: MMP0460.20-XAA0004B, 05/16/2011 Reactor Building Cooling Unit Performance Test (HEPA DOP Test) Work Package - Work Order: 1007796-001, Procedure: STP0453.001-AH, 05/20/2011 Control Room Emergency Filter Plenum A, Charcoal Sample Test Work Package - Work Order: 1007797-001, Procedure: STP0454.001-XAA0029A-2, 04/13/2011 Control Room Emergency Filter Plenum B, Charcoal Sample Test Work Package - Work Order: 1007798-001, Procedure: STP0454.001-XAA0029B-2, 03/29/2011 Control Room Emergency Filter Plenum A, HEPA DOP and Flow Rate Test Work Package - Work Order: 1007799-001, Procedure: STP0454.002-XAA0029A, 04/06/2011 Control Room Emergency Filter Plenum b, HEPA DOP and Flow Rate Test Work Package - Work Order: 1007800-001, Procedure: STP0454.002-XAA0029B, 03/24/2011
HP-633, Attachment X, Monthly Breathing Air Cylinder Inspection Log, June 2011
HP-633, Attachment IX, SCBA Inspection Logs: Selected data sheets from the1

st

QTR 2010, 2

nd

QTR 2010, 1

st

QTR 2011, and complete data sheets from the 2

nd

QTR 2011
Attachment CAP Documents
CR-09-03505, SCBA operability and return during fire brigade drills
CR-10-00512, Security (Wackenhut) emergency use respiratory devices do not meet regulatory requirements.
CR-10-03555, HP Shift Leader qualifications for assigning respiratory protection based on radiological conditions
CR-11-02972, A representative (breathing zone) air sample was not obtained in the reactor cavity while workers were wearing respiratory protection
CR-11-03564, Error on SCBA Quarterly data sheet

Section 2RS4: Occupational Dose Assessment

Procedures

and Guidance Documents

HPP-0202, Interlaboratory Intercomparison Program, Rev. 3A
HPP-0405, Personnel Decontamination and Skin Dose Determination, Rev. 16D
HPP-0411, Monitoring Exposure With Multibadging, Rev. 11
HPP-0505, Issuance and Termination of Personnel Dosimetry, Rev.18A
HPP-0512, Tritium Bioassay, Rev. 9
HPP-0514, Interpretation of Bioassay Analyses, Rev. 14
HPP-0518, Exposure Control Documentation, Rev. 11
HPP-0520, Set-Up, Calibration, and Generation of Quality Control Bands for the Stand-Up Whole Body Counter, Rev. 7
HPP-0521, Daily Quality Control and Whole Body Counting with the ND People Mover Whole Body Counter, Rev. 7B
HPP-0522, Set-Up, Calibration, and Generation of Quality Control Bands for the Chair Whole Body Counter, Rev. 9
HPP-0523, Quality Control and Whole Body Counting with the Chair Whole Body Counter, Rev.
4A
HPP-643, Operation of the Electronic Dosimeter Readers, Rev. 1
HPP-652, Respirator Decision Logic, Rev. 1 HPSS Administrative Instruction 11-001, Fuel Cycle 19 Alpha Characterization, 02/10/2011
Health Physics Technical Work Record, Correction Factor to Estimate Neutron Dose, TWR#: 2.1.4 / 06-002, 07/11/2006 Health Physics Technical Work Record, Algorithm for Use with
GDS 760 Neutron Dosimeters at VCSNS, TWR#: 2.1.4 / 07-003, 03/12/2007 Health Physics Technical Work Record, Update to Algorithm for Neutron Badges (TWR 07-003), TWR#: 2.1.4 / 07-016, 10/17/2007 Stand-Up Whole Body Counter Calibration Package (HPP-0522, Enclosure A and accompanying data), 04/20/2010 Stand-Up Whole Body Counter Calibration Package (HPP-0522, Enclosure A and accompanying data), 09/17/2010 Chair Whole Body Counter Calibration Package (HPP-0522, Enclosure A and accompanying data), 09/03/2010
Records and Data Reviewed
ABACOS 2000 Whole Body Counting Gamma Spectroscopy Library Report,
NVLAP Certificate of Accreditation to ISO/IEC 17025:2005, Effective Dates 2010-07-01 through 2011-06-30
Attachment NVLAP Certificate of Accreditation to ISO/IEC 17025:2005, Effective Dates 2010-10-01 through 2011-09-30 SA10-HP-05S, Rev. 1, Snapshot Self-Assessment of the Bioassay Program, 03/10/2011 2010 Level I Personnel Contamination Event Tracking Log (HPP-0405 Attachment IV), dated 03/10/2010 through 07/14/2010 2011 Level I Personnel Contamination Event Tracking Log (HPP-0405 Attachment IV), dated 04/24/2011 through 05/31/2011 2011 Level II and III Personnel Contamination Event Log (Electronic report log file), 06/02/2011 ED Dose Rate Alarm Evaluation Logs (HPP-0419, Enclosure 7.4) for the period 05/21/2010 through 06/07/2011 Radiation Monitor Setpoints (Enclosure A of
HPP-0904, Use of the Radiation Monitoring System (RMS), Rev. 12B), 04/21/2011 10 CFR Part 50/61 Certificate of Analysis, Vendor Laboratory Analysis Document Work Order:
250440, 05/03/2010 Eckert & Ziegler Report, Results of Radiochemistry Cross Check Program, South Carolina Electric and Gas Co. VC Summer, 3

rd Quarter 2010

Corrective Action Program (CAP) Documents
CR-09-01830, Large variance in TLD versus ED results for 1

st Quarter 2009

CR-10-00979, Error in NRC Form 5 produced by Sentinel
CR-10-01586, Incorrect dose reported in NRC Form 5
CR-10-04097, 3

rd Quarter TLDs not returned as of 10/15/2010

CR-11-02194, Individual Neutron exposure >25% different than estimated
CR-11-02264, ED alarm on logout, worker did not inform HP of alarm
CR-11-02647, Off scale SRPD in multi badge pack (dosimetry investigation)
CR-11-02217, ED alarm
CR-11-02105, ED alarm
CR-11-02170, Personnel Contamination Event, skin dose assessment
CR-11-02758, Personnel Contamination Event, skin dose assessment

Section 2RS5: Radiation Monitoring Instrumentation

Procedures, Guidance Documents, and Manuals Technical Specifications, Virgil C Summer Nuclear Station, Unit No.1, Docket No. 50-395
HPP-0301 Operation of Station Portable Survey Instruments, Rev 13.
HPP-0513 Operation of The J. L. Shepherd 25 Irradiator, Rev 7.
HPP-0520 Set-Up, Calibration, and Generation Of Control Bands For The Stand-up Whole Body Counter, Rev 7.
HPP-0521 Daily Quality Control and Whole Body Counting With The ND People Mover Whole Body Counter, Rev 7B
HPP-0522 Set-Up Calibration And Generation Of Quality Control Bands For the Chair Whole Body Counter, Rev 9.
HPP-0523 Quality Control and Whole Body Counting With The Chair Whole Body Counter, Rev 4A.
HPP-0607 Periodic Testing Of RCA Contamination Monitors, Rev 2.
HPP-0611 Calibration of Station Survey Instruments, Rev 15A
HPP-0612 Operation of the J. L. Shepherd Model 28 And 89 Calibrators, Rev 3
HPP-0620 Operation And Calibration of the Eberline Portal Monitor
PCM-1B
Attachment
HPP-0630 Recertification of J.L Shepherd Sources, Rev 6.
HPP-0646 Calibration And Operation of the Eberline
PCM-2 Personnel Contamination Monitor, Rev 5.
HPP-0648 Operation and Calibration of the Eberline
PM-7 Personnel Monitor, Rev 3
HPP-0649 Calibration and Operation of the NE SAM Tool and Bag Monitor, Rev 4
HPP-0651 Maintenance of the J.L. Shepherd Calibrators, Rev 0A
HPP-0653 Calibration and Operation of the RADOS RTM110 Hand and Foot Monitor, Rev 1
HPP-0654 Calibration and Operation of the RADOS RTM860TS Portal Monitor, Rev 2
HPP-0704 Radioactive Source Inventory and Accountability, Rev 11
HPP-0709 Sampling and Release of Radioactive Gaseous Effluents, Rev 11
HPP-0710 Sampling and Release of Radioactive Liquid Effluents, Rev 12A
HPP-0711 Unconditional Release of Trash and Scrap Materials, Rev 8
HPP-0801 Counting Statistics and QC Testing For Health Physics Counting Systems, Rev 8
HPP-0808 Sample Analysis, Rev 13B
HPP-0816 Operation of the
MS-2 and
BC-4 Beta Counting Systems, Rev 5
HPP-0817 Quality Control of Sampling and Sample Analysis Methods, Rev 9
HPP-0818 Operation, Calibration and QC of the
LS-6500 Liquid Scintillation Counter, Rev 8.
HPP-0827 Setup, Calibration, Quality Control, and Operation Of Germanium Detector Spectroscopy Systems, Rev 3C
EPP-003 Plant Radiological Surveying, Rev 14
EPP-007 Environmental Monitoring, Rev 11
STP-360.045, Main Plant Vent Atmospheric Radiation Monitor Rm-A13 Calibration, Rev 9 Technical Work Record 89-016, "Efficiency Calibrations for Gamma Spectroscopy Systems, Oct, 19, 1989. Technical Work Record 96-003, "Criteria for Accepting Spectroscopy Calibrations Using Weak Standards. Technical Work Record 10-013, "Sensitivity Study of the RADOS RTM860TS Monitors & Determination of Minimum %ALI Values," June, 25

th 2010. Technical Work Record 10-005, "Technical Evaluation of the Impact of Hard-to-Detect Radionuclides on the RTM860TS Portal Monitors and the

SAM-11 Alarm Set Points. ITMR System Function & Performance Criteria Analysis, Radiation Monitoring Important to Maintenance Rule, 12/27/2005
GS-9, Enclosure D, Rev 11, Area Radiation Monitors Records and Data
V.C. Summer Interlaboratory Comparison Program Schedule
WBC Chair Calibration performed 09/03/10 Stand-up WBC (People Mover) Calibration performed 04/20/10 Stand-up WBC (People Mover) Calibration performed 09/17/10 BBA libraries used for routine analysis Health Physics Instrument Equipment Inventory Log, 06-14-11 Recertification of JL Shepherd Sources, June 2010 Plant Drawing #04 4461 B-814-473 4, "Aux Bldg El. 485',
RM-A3 and A-4 Plant Vent Exhaust Radiation Monitors." Survey of JL Shepherd Model 28-5 Table Irradiator w/source exposed @1 ft, Dated 06-28-2011 Daily Instrument Performance Check Response Log, Dated 06-28-11 Site Count Room Lower Limit of Detection Sample/Counting Parameters, Rev 3 Required LLD's for Liquid and Gaseous Effluents, Rev 13
Attachment RMS Setpoint Worksheet, Rev 12, Dated 06-08-2011 Maintenance Dept. Pre-Job Brief, WO #1104273-001 Completed WO# 1104273-001,
RMA-13 Calibration, 06-28-11 Calibration Record for HPGe Det#1, 02-11-08
LWRP #NM-11-167, 06-28-2011 Decayed DPM report, 06-28-2011 WO#1016634-001, Calibration Record for
RMA-2 Performed 02-24-2011
WO#1014829-001, Calibration Record for
RMA-3 Performed 03-14-2011
WO#0815554-001, Calibration Record for
RMG-7 Performed 11-24-2009
WO#0815554-001, Calibration Record for
RMG-18 Performed 02-24-2009
WO#1013153-001, Calibration Record for
RMG-8 Performed 12-08-2011 WO#1013158-001, Calibration Record for
RML-9 Performed 11-30-2010
Calibration record for RADOS 860TS, Serial #837, Dated 10-12-09 Calibration record for
PCM-2, Serial #126, Dated 11-09-10 Calibration record for
SAM-11, Serial #334, Dated 12-1-10 Calibration record for
PM-7, Serial #264, Dated 11-30-10
Calibration record for
RO-20, Serial #3159 (last) Certification of J. L. Shepherd Model 28 And 89 Calibrators, Dated 12/07/10
CAP Documents
CR-11-01610, Daily verification of High Radiation Setpoints were not documented on 4/8/11 for
RM-L3 and
RM-L10 as required by the Steam Generator Release Permit (SG-11-02 -
HPP-0710, Attachment VIII).
CR-11-03120, The daily 47 mm Tc-99 source used for source checking the
AMS-4 continuous air sampler was discovered damaged.
CR-11-01752, The second daily change out of
RM-A4 was not completed within 24 hrs.
CR-10-01887, Management observation identified several procedural noncompliance items and several administrative deficiencies with completion of some instrument calibration records.
CR-10-00879, Potential near miss of Tech Spec surveillance requirement for RMA0002
CR-10-00802, This CR is being written to document that the performance indicator for liquid radwaste effluents for the month of January is in the red.
CR-11-02450, While performing a walk down of the
TB 436' on 05/06 at 2130 a Safety Services contractor noticed RMA0009 in alarm mode.
CR-11-03572, Possible maintenance issue with Cs-137 used for Rad Monitor calibrations.
Self Assessments/Audits
CR-10-04192, Self-assessment SA10-HP-02 Radwaste Group
CR-10-00515,
QA-AUD-201001-0, Station Radiation Control Audit
CR-10-04514, Self-assessment of the Health Physics Count Room, SA10-HP-03

4OA1 Performance Indicator (PI) Verification

Nuclear Operations Monthly Performance Report Operations Data January -June 2010 Nuclear Operations Monthly Performance Report Operations Data July -December 2010 Nuclear Operations Monthly Performance Report Operations Data January -May 2011 Monthly Effluent Dose Calculations and Release Permits for January 2010 -May 2011
Attachment

Section 4OA3: Followup of Events and Notices of Enforcement Discretion

Event Notification Report: Event Number 47039 30-Day Special Report to the NRC (ML11216A230

LIST OF ACRONYMS

ADAMS Agency Document Access and Management System
ALARA As Low As Reasonably Achievable
ANSI American National Standards Institute
APCSB Auxiliary Power Conversion Systems Branch
ARM Area Radiation Monitor
AV Apparent Violation
BTP Branch Technical Position
CAM Continuous Air Monitor
CAP Corrective Action Program
CB Control Building
CCW Component Cooling Water
CFR Code of Federal Regulations
CR Condition Report
CY Calendar Year
DAW Dry Active Waste
DG Diesel Generator
EDG Emergency Diesel Generator
EFW Emergency Feedwater
EPP Emergency Plan Procedure
ES Engineering Services Procedure
FPER Fire Protection Evaluation Report
FSAR Final Safety Analysis Report
GTP General Test Procedure
HEPA High Efficiency Particulate Air
IB Intermediate Building
IMC Inspection Manual Chapter
IR Inspection Report
JPM Job Performance Measures
LER Licensee Event Report
MCB Main Control Board
MCR Main Control Room
MPFF Maintenance Preventable Functional Failure
MR Maintenance Rule
MS Main Steam
MSIV Main Steam Isolation Valve
MSPI Mitigating System Performance Index
NCV Non-Cited Violation
NEI Nuclear Energy Institute
NPR Negative Pressure Respirator
NPU Negative Pressure Units
NRC Nuclear Regulatory Commission
NUREG Nuclear Regulatory
OAP Operations Administrative Procedure
OOS Out of Service
PARS Publicly Available Records

PCM Personnel Contamination Monitor PD Performance Deficiency

Attachment

PI Performance Indicator
PM Portal Monitor
PMT Post-Maintenance Testing
RBS Reactor Building Spray
RCE Root Cause Evaluation
RCS Reactor Coolant System
REV. Revision
RG Regulatory Guide
RHR Residual Heat Removal
RTP Rated Thermal Power
RWP Radiation Work Permit
SAM Small Article Monitor
SAP Station Administrative Procedure
SCBA Self-Contained Breathing Apparatus
SCE&G South Carolina Electric and Gas
SDP Significance Determination Process
SFP Spent Fuel Pit
SG Steam Generator
SOP System Operating Procedure
SSC System, Structures, and Components
STP Surveillance Test Procedure
SW Service Water
TB Turbine Building
TDEFW Turbine Driven Emergency Feedwater
TS Technical Specification

TYRA Three-Year Rolling Average

U1RFO18 Unit 1 Refueling Outage 18 (2009) U1RFO19 Unit 1 Refueling Outage 19 (2011)

UFSAR Updated Final Safety Analysis Report
URI Unresolved Item
VIO Violation
WBC Whole Body Count WO Work Order