IR 05000395/2016007

Virgil C. Summer Nuclear Station - NRC Problem Identification and Resolution Inspection Report 05000395/2016007 and Notice of Violation

ML16327A378
Person / Time
Site:	Summer
Issue date:	11/22/2016
From:	Davis B J Reactor Projects Branch 7
To:	Lippard G South Carolina Electric & Gas Co
References
IR 2016007
Preceding documents:	ML17019A207 (18 January 2017)
Download: ML16327A378 (21)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 November 22, 2016

Mr. George Lippard Vice President South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station P.O. Box 88 Jenkinsville, SC 29065

SUBJECT: VIRGIL C. SUMMER NUCLEAR STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000395/2016007 AND NOTICE OF VIOLATION

Dear Mr. Lippard:

On October 13, 2016, the Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Virgil C. Summer Nuclear Station. On September 15, 2016, the NRC inspection team di scussed the preliminary results of this inspection with you and other members of your staff. Following completion of additional inspection of the findings, a re-exit was held by telephone with Mr. R. Justice of your staff on October 13, 2016, to discuss the final results of the inspection. The results of this inspection are documented in the enclosed inspection report.

The NRC inspection team reviewed the station's corrective action program and the station's implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. The team identified two findings in problem identification, implementation of the process for prioritizing and evaluating these problems, and the effectiveness of corrective actions taken to resolve these problems.

The team also evaluated the station's processes for use of industry and NRC operating experience information and the effectiveness of the station's audits and self-

assessments. Based on the samples reviewed, the team determined that your staff's performance in each of these areas adequately supported nuclear safety.

The team also evaluated the station's processes for use of industry and NRC operating experience information and the effectiveness of the station's audits and self-assessments. Based on the samples reviewed, the team determined that your staff's performance in each of these areas adequately supported nuclear safety.

Finally the team reviewed the station's programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the team's observations and the results of these interviews the team found no evidence of challenges to your organization's safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available. 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 NRC's Web site at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. We determined that one violation did not meet the criteria to be treated as an NCV because compliance has not been 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 NRC's 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

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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

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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 licensee's 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 facilit y that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should 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 el ectronically for public inspection in the NRC Public Document Room or from the NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

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

Dated this 22 nd day of November 2016 Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION II

Docket No.: 50-395

License No.: NPF-12

Report No: 05000395/2016007 Licensee: South Carolina Electric & Gas (SCE&G) Company

Facility: Virgil C. Summer Nuclear Station Location: P.O. Box 88 Jenkinsville, SC 29065

Dates: August 29 - October 13, 2016 September 12 - 15, 2016

Inspectors: N. Staples, Senior Project Inspector, Team Leader C. Dykes, Reactor Inspector, Region II R. Rodriguez, Sr. Reactor Inspector, Region II S. Seaton, Project Inspector, Region II S. Ninh, Senior Project Engineer, Region II

Approved by: Bradley J. Davis, Acting Branch Chief Reactor Projects Branch 7

Division of Reactor Projects

SUMMARY OF FINDINGS

IR 05000335/2016007, 08/29/2016 - 10/13/2016; Virgil C. Summer Nuclear Station; Biennial Inspection of the Problem Identification and Resolution Program.

The inspection activities described in this report were performed between August 29 and October 13, 2016, by a senior project engineer, a senior project inspector, a project inspector, and a reactor inspector. One Green non-cited violation and one cited Severity Level (SL) IV violation are documented in this report. The significance of inspection findings are indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process," (SDP) dated April 29, 2015. The cross-cutting aspects were determined using IMC 0310, "Aspects Within the Cross-Cutting Areas," dated December 4, 2014. All violations of NRC requirements were dispositioned in accordance with the NRC's Enforcement Policy dated February 4, 2015. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 6.

Identification and Resolution of Problems The NRC inspection team reviewed the station's corrective action program and the station's implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. The team identified two findings in problem identification, implementation of the process for prioritizing and evaluating these problems, and the effectiveness of corrective actions taken to resolve these problems.

The team also evaluated the station's processes for use of industry and NRC operating experience information and the effectiveness of the station's audits and self-assessments. Based on the samples reviewed, the team determined that your staff's performance in each of these areas adequately supported nuclear safety.

The team also evaluated the station's processes for use of industry and NRC operating experience information and the effectiveness of the station's audits and self-assessments. Based on the samples reviewed, the team determined that your staff's performance in each of these areas adequately supported nuclear safety.

Finally the team reviewed the station's programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the team's observations and the results of these interviews the team found no evidence of challenges to your organization's safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.

Cornerstone: Mitigating Systems

Green.

The inspectors identified a non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," for the failure to correct a condition adverse to quality associated with a previously issued NCV,05000395/2012004-02, Inadequate Installation of Unit 1 Service Water Piping and Related Pipe Support. The licensee entered the issue in the correction action program as condition report (CR)-16-04621.

3 The PD is more than minor because if left uncorrected, the reduction in design margin of the pipe support could affect the Unit 1 SW system's ability to mitigate a seismic event.

Specifically, Unit 1 service water (SW) piping and support had been impacted by the reduction in design margin and without formally updating the associated drawings and calculations or restoring to the original design, future modifications to the system could impact the system's ability to mitigate a seismic event. Using Manual Chapter 0609 Attachment 04, "Initial Characterization of Findings," Table 2, dated October 07, 2016, the finding was determined to adversely affect the External Event Mitigating Systems.

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

Appendix A, "Significance Determination Process (SDP) for Findings at-Power," dated June 19, 2012, and determined that it screened as Green (very low safety significance) because the service water system maintained its functionality to mitigate a seismic event. The inspectors determined that the finding had a cross-cutting aspect in the area of PI&R because the licensee did not take effective corrective actions to address this issue in a timely manner [P.3]. (Section 4OA2) SLIV. The inspectors identified a cited Severity Level (SL) IV violation of Operating Licensee Condition 2.C.(18) for failure to ensure that conditions adverse to fire protection as noted in a previous NRC-identified SLIV NCV,05000395/2016001-01, "Failure to Implement Adequate Administrative Controls Following a Departure from National Fire Protection Association (NFPA) 80-1973 and Provide NRC Staff Complete and Accurate Information," were promptly corrected. Specifically, the licensee failed to implement corrective actions and restore compliance in a timely manner for (1) the noncompliance with 10 CFR 50.9 to provide staff complete and accurate information and (2) fire doors DRIB/105A&B currently do not meet self-closing requirements in accordance with the current NFPA 805 licensing basis and no actions were specified in licensee's corrective action program to restore compliance. The licensee entered the issue in their corrective action program as condition report (CR)-16-04701.

The inspectors determined that the performance deficiency was more than minor because it impacted the ability of the NRC to perform its regulatory oversight function and was dispositioned using traditional enforcement. Because the licensee failed to implement corrective actions and restore compliance in a timely manner, this violation is being treated as a cited violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy. This violation involved traditional enforcement and a cross-cutting aspect was not assigned to this violation.

REPORT DETAILS

4OA2 Problem Identification and Resolution

.1 Corrective Action Program Effectiveness

a. Inspection Scope

The team reviewed the licensee's corrective action program (CAP) procedures which described the administrative process for initiating and resolvi ng problems primarily through the use of condition reports. To verify that problems were being properly identified, appropriately characterized, and entered into the CAP, the team reviewed a sample of Condition Reports (CRs) that had been issued between August 2014 and August 2016, including a detailed review of selected CRs associated with the following risk-significant systems and components:

Electrical (7.2Kv and 480VAC), Safety Injection (SI), Residual Heat Removal (RHR), and Service Water (SW). To help ensure that samples were reviewed across all cornerstones of safety identified in the NRC's Reactor Oversight Process (ROP), the team selected a representative number of CRs that were identified and assigned to the major plant departments, including organizational effectiveness, health physics, chemistry, emergency preparedness and security. These CRs were reviewed to assess each department's threshold for identifying and documenting plant problems, thoroughness of evaluations, and adequacy of corrective actions. The team reviewed selected CRs, verified corrective actions were implemented, and attended meetings where CRs were screened for significance to determine whether the licensee was identifying, accurately characterizing, and entering problems into the CAP at an appropriate threshold.

The team conducted plant walkdowns of equipment associated with the selected systems and other plant areas to assess the material condition and to look for any deficiencies that had not been previously entered into the CAP. The team reviewed CRs, maintenance history, completed work orders (WOs) for the systems, and reviewed associated system health reports. These reviews were performed to verify that problems were being properly identified, appropriately characterized, and entered into the CAP. Items reviewed generally covered a two-year period of time; however, a five-year review was performed for selected systems for age-dependent issues.

Control room walkdowns were also performed to assess the main control room (MCR)deficiency list and to ascertain if deficiencies were entered into the CAP. A sample of operator workarounds and operator burden screenings were reviewed and the team verified compensatory measures were implemented for deficient equipment.

The team conducted a detailed review of selected CRs to assess the adequacy of the root-cause, apparent-cause, and condition evaluations of the problems identified. The team reviewed these evaluations against the descriptions of the problem described in

the CRs and the guidance in procedures SAP-1356, "Cause Determination," and SAP-0999, "Corrective Action Program." The team assessed if the licensee had adequately determined the cause(s) of identified problems and had adequately addressed operability, reportability, common cause, generic concerns, extent-of-condition, and

extent-of-cause as required.

5 The review also assessed if the licensee had appropriately identified and prioritized corrective actions to prevent recurrence for significant conditions adverse to quality. The team reviewed site trend reports to determine if the licensee effectively trended identified issues and initiated appropriate corrective actions when adverse trends were identified.

The inspectors attended the CR Review Team (CRT) virtual meetings, where CRs were screened for significance, to determine whether the licensee was identifying, accurately characterizing, and entering problems into the CAP at an appropriate threshold. The team attended various plant meetings to observe management oversight functions of the corrective action process. These included Management Review Team (MRT) and Corrective Action Review Board (CARB) meetings. Documents reviewed are listed in the

.

b. Assessment Problem Identification The team determined that the licensee was generally effective in identifying problems and entering them into the CAP and there was a low threshold for entering issues into the CAP. This conclusion was based on a review of the requirements for initiating CRs as described in licensee procedure SAP-0999, "Corrective Action Program,"

management's expectation that employees were encouraged to initiate CRs for any reason, and the relatively few number of deficiencies identified by the team during plant walkdowns not already entered into the CAP. Trending was generally effective in

monitoring equipment performance. Site management was actively involved in the CAP and focused appropriate attention on significant plant issues. Based on reviews and walkdowns of accessible portions of the selected systems, the team determined that system deficiencies were being identified and placed in the CAP.

Problem Prioritization and Evaluation Based on the review of CRs sampled by the inspection team during the onsite period, the team concluded that problems were generally prioritized and evaluated in accordance with the licensee's CAP procedures as described in the CR severity level determination guidance in procedure SAP-0999. Each CR was assigned a priority level at the CR Review Team and adequate consideration was given to system or component operability and associated plant risk.

The team determined that station personnel had conducted root cause and apparent cause analyses in compliance with the licensee's CAP procedures and the assigned cause determinations were appropriate, considering the significance of the issues being evaluated. A variety of formal causal-analysis techniques were used depending on the type and complexity of the issue consistent with SAP-1356.

6 Effectiveness of Corrective Actions Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the team determined that generally, corrective actions were timely, commensurate with the safety significance of the issues, and effective, in that conditions adverse to quality were corrected. For significant conditions adverse to quality, the inspectors determined corrective actions directly addressed the cause and effectively prevented recurrence through a review of performance indicators, CRs, and effectiveness reviews demonstrated that the significant conditions adverse to quality had not recurred. Effectiveness reviews for CAPRs were sufficient to ensure corrective actions were properly implemented and were effective.

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 licensee's corrective action program to restore compliance. The inspectors reviewed the licensee's operating license and quality assurance program and determined conditions adverse to fire protection are required to be identified and corrected per Section 1.7.8 of RG 1.89.

Analysis:

Failure to ensure that conditions adverse to fire protection as noted in previous NRC-identified non-cited violation (NCV), SLIV NCV,05000395/2016001-01, were promptly corrected was a violation. This violation was more than minor because it impacted the ability of the NRC to perform its regulatory oversight function and was dispositioned using traditional enforcement.

Because the licensee failed to implement corrective actions and restore compliance in a timely manner, this violation is being treated as a cited violation, consistent with Section 2.3.2a of the NRC Enforcement policy.

This violation involved traditional enforcement and a cross-cutting aspect was not assigned to this violation.

Enforcement:

Operating Licensee Condition 2.C.(18) states, in part, that SCE&G shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment request dated 11 /15/11 (and supplements dated 1/26/12, 10/10/12, 2/1/13, 4/1/13, 10/14/13, 11/26/13, 1/9/14, 2/25/14, 5/2/14, 5/11/14, 8/14/14, 10/9/14, and 12/11/14) and as approved in the safety evaluation report dated 02/11/15.

Section 4.7.3 of LAR states, in part, that VCSNS will implement a revised quality assurance program to ensure compliance with section 2.7.3 of NFPA 805 and the revised fire protection quality assurance program is based on Regulatory Position 1.7,"Quality Assurance," in RG1.189, Rev. 2, Fire Protection for Operating Nuclear Power Plants."

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

corrected.

Contrary to the above, as of October 13, 2016, the licensee failed to ensure that conditions adverse to fire protection as noted in a previous NRC-identified SL IV NCV,05000395/2016001-01, "Failure to Implement Adequate Administrative Controls Following a Departure from NFPA 80-1973 and Provide NRC Staff Complete and Accurate Information," were promptly corrected. Specifically, the licensee failed to implement corrective actions and restore compliance in a timely manner for

(1) the noncompliance with 10 CFR 50.9 to provide staff complete and accurate information and

(2) fire doors DRIB/105A&B currently do not meet self-closing requirements in accordance with the current NFPA 805 licensing basis and no actions were specified in licensee's corrective action program to restore compliance.

Because the licensee failed to implement corrective actions and restore compliance in a timely manner, this violation is being treated as a cited violation, consistent with Section 2.3.2.a of the NRC Enforcement policy. A Notice of Violation is included with this report: VIO 05000395/2016007-01, "Failure to implement corrective actions and restore compliance for previous NRC-identified SLIV NCV 05000395/2016001-01."

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

Introduction:

A Green NCV of 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," was identified by the NRC for the failure to correct a condition adverse to quality associated with a previously issued NCV ,05000395/2012004-02, Inadequate Installation of Unit 1 Service Water Piping and Related Pipe Support.

Description:

On November 7, 2012, the NRC issued NCV,05000395/2012004-02, against 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings,"

for failure to accomplish the installation of Unit 1 service water (SW) piping and supports in accordance with prescribed drawings. The finding was of very low safety significance and was entered into the licensee's CAP as CR-12-00771. An engineering information request (EIR) was completed, which concluded that the pipe support was acceptable as is. However, no additional action was taken to complete an engineering evaluation, per ES-120, to formally disposition the pipe support "accept as is," or update related drawings and calculations and CR-12-00771 was closed. As a result of NRC questioning during the biennial problem identification and resolution (PI&R) inspection, the licensee opened CR-16-04621, which determined that the degraded condition was neither corrected nor formally dispositioned as "accept as is." A work order, WO 1613458, was in the process of being developed to fix the pipe support.

Analysis:

The licensee's failure to correct a non-conforming condition of Unit 1 Service Water Piping and Related Pipe Support, was a performance deficiency (PD). The inspectors reviewed inspection manual chapter (IMC) 0612, Appendix B, "Issue Screening," dated September 7, 2012, and determined that the PD is more than minor because if left uncorrected, the reduction in design margin of the pipe support could affect the Unit 1 SW system's ability to mitigate a seismic event.

Specifically, Unit 1 service water (SW) piping and support had been impacted by the reduction in design margin and without formally updating the associated drawings and calculations or restoring to the original design, future modifications to the system could impact the system's ability to mitigate a seismic event. Using Manual Chapter 0609.04, "Initial Characterization of Findings," Table 2, dated June 19, 2012, the finding was determined to adversely affect the External Event Mitigating Systems. The inspectors screened the finding using Inspection Manual Chapter (IMC) 0609, Appendix A, "Significance Determination Process (SDP) for Findings at-Power," dated June 19, 2012, and determined that it screened as Green (very low safety significance) because the service water system maintained its functionality to mitigate a seismic event. Using IMC 0310, "Aspects within the Cross-Cutting Areas," dated December 4, 2014, the inspectors determined that the finding had a cross-cutting aspect in the area of PI&R because the licensee did not take effective corrective actions to address this issue in a timely manner (P.3, Resolution).

Enforcement:

10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," states in part that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected.

Contrary to the above, as of October 13, 2016, the licensee failed to correct a nonconforming condition of Unit 1 service water piping and related pipe support from a previous issued NRC Green NCV,05000395/2012004-02. Because the finding is of very low safety significance and it was entered into the licensee's CAP as CR-16-04621, this violation is being treated as a Green NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 05000395/2016007-01, Failure to correct a condition adverse to quality associated with a previously issued NCV.

.2 Use of Operating Experience

a. Inspection Scope

The team examined licensee's use of industry operating experience (OE) to assess the effectiveness of how external and internal operating experience information was used to prevent similar or recurring problems at the plant. In addition, the team selected operating experience documents (e.g., NRC generic communications, 10 CFR Part 21 reports, licensee event reports, vendor notifications, and plant internal operating experience items, etc.), issued since February 2014 to verify whether the licensee had appropriately evaluated each notification for applicability to the VC Summer site, and whether issues identified through these reviews were entered into the CAP. Documents reviewed are listed in the Attachment.

b. Assessment 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 site's 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 inspector's independent review. The team verified that CRs were created to document all areas for improvement and findings resulting from the self-assessments, and verified that actions had been completed consistent with those recommendations.

Generally, the licensee performed evaluations that were technically accurate.

c. Findings

No findings were identified.

.4 Safety-Conscious Work Environment

a. Inspection Scope

During the course of the inspection, the team assessed the station's safety-conscious work environment (SCWE) through review of the stations Employee Concerns Program (ECP) and interviews with various departmental personnel. The team reviewed a 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 samp le of plant employees from various departments, the team determined that employees felt free to raise issues, and that management encouraged employees to place issues into the CAP for resolution. The team did not identify any reluctance on the part of the licensee staff to report safety concerns.

c. Findings

No findings were identified.

4OA6 Meetings, Including Exit

On September 15, 2016, the inspectors presented the preliminary inspection results to Mr. G. Lippard and other members of the site staff.

The inspectors confirmed that all proprietary information examined during the inspection had been returned to the licensee. Following completion of additional inspection of the findings, a re-exit was held by telephone with Mr. R. Justice of your staff on October 13, 2016, to discuss the final results of the inspection.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

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)

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

Condition Reports

Reviewed:

11-04585 11-06298 12-00583 12-00771 12-02013 12-02534

2-04908 12-05225 13-00497 13-00566 13-02694 13-03952 14-00233 14-00760 14-01926

14-01930 14-02282 14-03079 14-03806 14-04017 14-04771 14-04946

14-04956 14-05100 14-05412 14-05414 14-05446 14-05542 14-05608 14-05649 14-05676

14-05700 14-05711 14-05737 14-05792 14-05821 14-05864 14-05869 14-05888 14-05897

14-06134 14-06168 14-06191 14-06336 14-06346 14-06404 14-06422

14-06439 14-06626 14-06646 15-00021 15-00071 15-00242 15-00263 15-00359 15-00435

15-00487 15-00541 15-00591 15-00636 15-00662 15-01015 15-01056

15-01083 15-01324 15-01347 15-01355 15-01494 15-01546 15-01615 15-01648 15-01661

15-01672 15-02031 15-02057 15-02087 15-02674 15-02793 15-02875 15-02875 15-03053

15-03057 15-03194 15-03654 15-03658 15-03885 15-04027 15-04275

15-04395 15-04480 15-04681 15-04703 15-04704 15-04706 15-04711 15-04712 15-04725

15-04749 15-04804 15-04829 15-04871 15-04872 15-04950 15-05024

15-05043 15-05043 15-05050 15-05055 15-05075 15-05167 15-05186 15-05253 15-05260

15-05276 15-05318 15-05328

15-05497 15-05607 15-05673 15-05722 15-05756 15-05814

15-05897 15-05900 15-05959 15-06007 15-06171 15-06174 15-06189

15-06199 15-06261 15-06353 15-06446 15-06608 16-00210 16-00550 16-00812 16-00853

16-00972 16-01210 16-01310 16-01351 16-01762 16-01853 16-02005

16-02089 16-02305 16-02504 16-02788 16-02803 16-03099 16-03384 16-03925 16-04396

16-04414 16-04431 16-04440 16-04445 16-04546 16-04579 16-04587 16-04621 16-04695

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

39021349

40051270

291617

297503

299899

40301755

40303405

40306989

40311432-05

40316415

40317485

40321728

40322723

40327300

40331897

40333771

40340194

40347394

40353053

40353054

40359242

40359243

40360192

40365018

40365437

40365438

40398236

40454409

40454416

40458771

94011628

381026626

4006440001

4006440201

Condition Reports

Generated:

16-04124

16-04444

16-04695

16-04701

Other Documents:

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

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

SYSTEM HEALTH REPORTS

SERVICE WATER SYSTEM,

1-2015-3

SERVICE WATER SYSTEM,

1-2016-1 RESIDUAL HEAT REMOVAL SYSTEM,

1-2015-3 RESIDUAL HEAT REMOVAL SYSTEM,

1-2016-1

Drawings: 1MS-22-333, REV. 11

ECR, 50585Y E-206-005, Simplified Plant Electrical Distribution, Rev.29 E-206-022, Electrical One Line & Relay Diagram 7200V SWGR Busses 1DA, 1DB, 1EA & 1EB, Rev.16

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

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