IR 05000395/2012002

IR 05000395-12-002; 01/01/2012 - 03/31/2012: Virgil C. Summer Nuclear Station; Fire Protection Heat Sink Performance, Operability Evaluations, and Other Activities

ML12135A453
Person / Time
Site:	Summer
Issue date:	05/11/2012
From:	McCoy G J NRC/RGN-II/DRP/RPB5
To:	Gatlin T D South Carolina Electric & Gas Co
References
IR-12-002
Download: ML12135A453 (39)

Text

May 11, 2012

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 05000395/2012002

Dear Mr. Gatlin:

On March 31, 2012, 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 April 25, 2012, 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 apparent violation that has potentially greater than very low safety significance. Additionally, this report documents four NRC-identified findings of very low safety significance (Green) which were determined to involve violations of NRC requirements. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy. If you contest these NCVs, 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 Agencywide Document Access and management System (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/ Gerald J. McCoy, Chief Reactor Projects Branch 5 Division of Reactor Projects Docket No.: 50-395 License No.: NPF-12

Enclosure:

NRC Integrated Inspection Report 05000395/2012002

w/Attachment:

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

__ ML12135A453__________________ XSUNSI REVIEW COMPLETE X FORM 665 ATTACHED OFFICE RII:DRP RII:DRP RII:DRP RII:DRS RII:DRS RII:DRS RII:DRP SIGNATURE /RA/ /RA/ /RA/ /VIA E-Mial/ /VIA E-Mial/ /VIA E-Mial/ /RA/ NAME JReece ECoffman SNinh PHiggins MThomas AAlen GMcCoy DATE5 5/9/20/12 5/9/2012 5/9/2012 5/1/2012 5/2/2012 5/1/2012 5/9/2012 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO SCE&G 3 cc w/encl: J. B. Archie Senior Vice President Nuclear Operations and Chief Nuclear Officer 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 Andy T. Barbee, Director Nuclear Training South Carolina Electric & Gas Company Electronic Mail Distribution Wayne D. Stuart, General Manager Engineering Services South Carolina Electric & Gas Company Electronic Mail Distribution Robin R. Haselden, General Manager Organizational Development &

Effectiveness South Carolina Electric & Gas Company Electronic Mail Distribution Shaun M. Zarandi, General Manager Nuclear Support Services South Carolina Electric & Gas Company Electronic Mail Distribution Robert L. Justice, Manager Nuclear Operations 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

Donna W. Railey Licensing Technician Nuclear Licensing South Carolina Electric & Gas Company Electronic Mail Distribution Robin J. White Nuclear Coordinator S.C. Public Service Authority Mail Code 802 Electronic Mail Distribution Susan E. Jenkins SC Department of Health & Environmenal Control Bureau of Land and Waste Management 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 Division of Radiological Health TN Dept. of Environment & Conservation 401 Church Street Nashville, TN 37243-1532 Senior Resident Inspector Virgil C. Summer Nuclear Station U.S. NRC 576 Stairway Road Jenkinsville, SC 29065

SCE&G 4 Letter to Thomas from Gerald J. McCoy dated May 11, 2012

SUBJECT: VIRGIL C. SUMMER NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT 05000395/2012002 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. 05000395/2012002 Licensee: South Carolina Electric & Gas (SCE&G) Company

Facility: Virgil C. Summer Nuclear Station Location: P.O. Box 88 Jenkinsville, SC 29065 Dates: January 1, 2012 through March 31, 2012

Inspectors: J. Reece, Senior Resident Inspector E. Coffman, Resident Inspector P. Higgins, Senior Reactor Inspector (Section 4OA5.4) M. Thomas, Senior Reactor Inspector (Section 4OA5.4) A. Alen, Reactor Inspector (Section 4OA5.4)

Approved by: Gerald J. McCoy, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000395/2012002; 01/01/2012 - 03/31/2012: Virgil C. Summer Nuclear Station; Fire Protection Heat Sink Performance, Operability Evaluations, and Other Activities

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

. One apparent violation and four NRC-identified findings were identified. 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.

Cornerstone: Mitigating Systems

Green.

The inspectors identified a non-cited violation of V.C. Summer Nuclear Station Technical Specification 6.8.1 for a failure to implement the requirements of their fire protection procedures for control of transient combustibles associated with a work activity in the Unit 1 'A' train emergency diesel generator (EDG) motor control center (MCC) room. The licensee entered the problem into their corrective action program as condition report, CR-12-00767.

The inspectors determined that the failure to implement the requirements of the fire protection procedures was a performance deficiency (PD). The inspectors also reviewed Inspection Manual Chapter (IMC) 0612, Appendix B and determined the PD is more than minor and therefore a finding, because (1) it was similar to IMC 0612, Appendix E, Example 4k, and (2) it impacted the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and the related attribute of protection against external factors such as fire. The inspectors used IMC 0609,

Appendix F, Attachments 1 and 2 to determine that the finding was of very low safety significance or Green because of the low fire frequency of the Unit 1 EDG MCC room and the short duration of the violation. The cause of this finding involved the cross-cutting area of human performance, the component of work practices, and the aspect of work activity planning, H.3(a), because the licensee failed to adequately evaluate transient combustible controls during planning for a work activity to monitor overloads in safety-related breakers. (Section 1R05)

Green.

The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," for the failure to adequately prescribe a procedure to inspect the service water (SW) pump motor lube oil heat exchangers (HXs) as committed to in the licensee's Generic Letter 89-13 response dated January 31, 1990. Specifically, a review of SW pump motor lube oil HX inspection documents identified that the licensee was not inspecting the internals of the lube oil

HXs and did not adequately implement other accepted performance monitoring methodologies. The issue was entered into the licensee's corrective action program as condition report CR-12-00844. The inspectors determined that the failure to adequately prescribe a procedure to inspect the SW pump motor lube oil HXs was a performance deficiency (PD). The inspectors also reviewed Inspection Manual Chapter (IMC) 0612, Appendix B and determined the PD is more than minor and therefore a finding, because it adversely impacted the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences and the respective attribute of procedure quality because inadequate monitoring of the HX performance would lead to a common mode failure mechanism that would adversely impact the safe operation of the SW pumps during severe environmental conditions. The inspectors performed a risk evaluation using IMC 0609, Appendix A, Phase 1, and determined the finding has very low safety significance (Green) because it was not a design deficiency, did not represent a loss of safety function and did not screen as potentially risk significant due to a seismic, flooding or severe weather initiating event. The cause of this finding did not involve a cross-cutting aspect because it is not indicative of current licensee performance. (Section 1R07)

Green.

The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," for the failure to analyze a moderate energy fluid system for leakage cracks resulting in flooding and/or spray as described in the licensee's Facility Safety Analysis Report (FSAR). Specifically, chilled water piping, located in a fan room located above and with access to the safety-related 1DB switchgear room, was not analyzed for leakage cracks. This issue was entered into the licensee's corrective action program as condition report, CR-12-00844.

The inspectors determined that the failure to analyze a moderate energy fluid system for leakage cracks as described in the FSAR was a performance deficiency (PD). The inspectors also reviewed Inspection Manual Chapter (IMC) 0612, Appendix B and determined the PD is more than minor and therefore a finding, because (1) it was similar to IMC 0612, Appendix E, Example 3i, in that the licensee had to perform calculations to show that design basis requirements were met, and (2) it adversely affected the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences and the respective attribute of design control because the licensee failed to analyze a chilled water pipe which presented a vulnerability to a safety-related motor control center that was not designed for water spray. The inspectors reviewed IMC 0609, Attachment 4, and determined that the finding was of very low safety significance, or Green, because the finding was a design or qualification deficiency confirmed not to result in loss of operability or functionality. The cause of this finding did not involve a cross-cutting aspect because it is not indicative of current licensee performance. (Section 1R15.1)

Green.

A non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," was identified by the inspectors for two examples of the failure to promptly identify and correct a condition adverse to quality (CAQ) involving safety-related chiller trips due to lightning. The licensee entered these problems into their corrective action program as condition reports, CR-11-03187 and CR-11-05225.

The inspectors determined that the failures to promptly identify and correct the CAQs for the trips of safety-related chillers due to lightning were performance deficiencies (PDs). The inspectors reviewed Inspection Manual Chapter (IMC) 0612, Appendix E and determined the PDs were more than minor and therefore findings, because they were similar to Examples 4d and 4f in that the failure to correct a condition adverse to quality led to the inoperability of the component. The inspectors determined the PDs were also more than minor because they impacted the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences and the respective attribute of protection against external factors such as lightning. The inspectors reviewed IMC 0609, Attachment 4 and determined that the findings were of very low safety significance or Green because the findings were not a design deficiency confirmed not to result in loss of functionality, were not a loss of safety function, and did not screen as potentially risk significant for a severe weather initiating event. The cause of the findings involved the cross-cutting area of problem identification and resolution, the component of corrective action program, and the aspect of complete and thorough evaluation, P.1(c), because the licensee failed to identify corrective actions for the safety-related chiller trips caused by lightning. (4OA5.2)

• TBD. The NRC identified an apparent violation of V.C. Summer Nuclear Station's Renewed Operating License NPF-12, 2.C(18), "Fire Protection System," with two examples for the failure to comply with Fire Protection Program (FPP) requirements in which the licensee used unapproved fire hoses. Specifically, the licensee selected non-collapsible hose with an incorrect minimum bend radius and failed to use a lined fire hose. The issue was entered into the licensee's corrective action program as condition report, CR-11-05578 and CR-11-05852.

The inspectors determined that the procurement and use of the fire hose which was not in accordance with the FPP was a performance deficiency (PD). The inspectors also reviewed Inspection Manual Chapter (IMC) 0612, Appendix B and determined the PD is more than minor and therefore a finding, because it impacted the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences and the respective attribute of protection against external factors such as fire. The inspectors reviewed IMC 0609, Appendix F, Attachments 1 and 2, and determined that the finding was of moderate safety significance because the non-collapsible rubber hose and portable extinguishers are the only local means of fire suppression for several fire zones, of which the most significant are the 7.2kV safety-related switchgear rooms. The inspectors also obtained the fire ignition frequencies for the areas of concern and in consideration of the exposure time, determined that a phase 2 evaluation is required. Consequently, the risk significance is to-be-determined pending completion of the risk evaluation. The cause of the finding involved the cross-cutting area of human performance, the component of work practices, and the aspect of procedural compliance, H.4(b), because the licensee failed to follow FPP procedural and program requirements for proper fire hose selection and use. (Section 4OA5.3)

B. Licensee-Identified Violations

None.

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

Seasonal Weather Susceptibilities

a. Inspection Scope

On February 24, 2012, a tornado watch was issued for Fairfield County and the inspectors performed a reactive weather related inspection. The inspectors reviewed licensee adverse weather response procedure, OAP-109.1, "Guidelines for Severe Weather," Revision 3, and related site preparations including work activities that could impact the overall maintenance risk assessments.

b. Findings

No findings were identified.

1R04 Equipment Alignment

a. Inspection Scope

The inspectors conducted five partial equipment alignment walkdowns which are listed below, to evaluate the operability of selected redundant trains or backup systems with the other train or system inoperable or out of service (OOS). Correct alignment and operating conditions were determined from the applicable portions of drawings, system operating procedures (SOP), and technical specifications (TS). The inspections included review of outstanding maintenance work orders (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.

• Cross-train walkdown of 'A' and 'B' train motor driven emergency feedwater (MDEFW) pumps during planned maintenance on turbine driven emergency feedwater (TDEFW) pump

• Cross-train walkdown of TDEFW and 'A' train MDEFW pumps during planned maintenance on 'B' train MDEFW pump

• Cross-train walkdown of 'A' train reactor building spray (SP) pump during planned maintenance on 'B' train SP pump

• Cross-train walkdown of 'B' emergency diesel generator (EDG) during planned maintenance of the 'A' EDG

• Cross-train walkdown of 'A' EDG during annual maintenance outage on 'B' EDG

b. Findings

An unresolved item (URI) associated with the cross-train walkdown of 'A' EDG is discussed in section 1R15.2 of this report.

1R05 Fire Protection

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 five areas (respective fire zones also noted):

• Service water (SW) pumphouse (fire zones SWPH-1, 3, 4, 5.1 and 5.2)

• Diesel generator rooms 'A' and 'B' (fire zones DG-1.1, 1.2, 2.1 and 2.2)

• Auxiliary building switchgear room 463' elevation (fire zone AB-1.29)

• Auxiliary building 436' elevation (fire zone AB-1.18)

• Auxiliary building 397' elevation (fire zone AB-1.8)

b. Findings

Introduction:

The inspectors identified a non-cited violation of V.C. Summer Nuclear Station (VCSNS) TS 6.8.1 which involved a failure to implement the requirements of fire protection procedures for control of transient combustibles associated with a work activity in the Unit 1 'A' train EDG motor control center (MCC) room.

Description:

On February 22, 2012, the inspectors identified transient fire loads in the Unit 1 'A' EDG MCC room and consisting of Class A miscellaneous combustibles involving a plastic cart, test equipment with test leads connected to safety-related breaker components in MCC, XMC1DA2Z, duct tape, and energized extension cords without a required fire protection permit. The licensee was using the test equipment to measure breaker overload currents during EDG ventilation fan starts when testing the EDGs. The inspectors identified the following applicable requirements:

• Fire protection procedure (FPP) 20, "Program Administration," Revision 5, step 3.3.1, states in part that all VCSNS personnel are responsible for notifying the shift test specialist (STS) immediately upon discovery of fire service systems/equipment impairments or significant quantities of apparently uncontrolled combustible materials, and prior to the introduction of transient combustible materials into plant areas defined by and in quantities qualifying for permit issuance per FPP-022.

• FPP-22, "Fire Prevention," Revision 3, step 3.3.2 (Responsibilities) section D states in part that all job supervisors shall ensure that:

1) Ensure that each job is evaluated for potential use of Class A and Class B materials. 2) Determine the amount and class of combustible materials associated with each job through consideration of job demands. 3) Determine the appropriate controls to be applied to the given amount and class of combustible materials associated with each job as follows: a) Review Enclosure 6.1 of this procedure which lists plant areas where intervening combustibles are to be restricted. b) Review Enclosure 6.2 of this procedure, which defines the required actions. 4) Establish the need for and obtain, as required, any fire protection permits associated with controlling MWR job functions in accordance with FPP-020, Program Administration. 5) Ensure that fire protection permits are implemented as specified in this procedure.

The licensee evaluated the materials, determined that a noncompliance with their procedures had occurred, and entered the problem into their corrective action program (CAP) as CR-12-00767. The inspectors concluded that the failure to implement the aforementioned procedures was contrary to TS 6.8.1 which requires in part that procedures shall be implemented for the Fire Protection Program.

Analysis:

The inspectors identified a performance deficiency (PD) for the failure to implement the requirements of licensee fire protection procedures, FPP-20 and 22, for control of transient combustibles associated with a work activity in the Unit 1 'A' train EDG MCC room. The PD was more than minor and therefore a finding because

(1) it was similar to Inspection Manual Chapter (IMC) 0612, Appendix E, Example 4k, and (2)it impacted the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and the related attribute of protection against external factors such as fire. The inspectors used IMC 0609, Appendix F, Attachments 1 and 2, to determine that the finding was of very low safety significance (Green) because of the low fire frequency of the Unit 1 EDG MCC rooms, the short duration of the violation, and only a single train of an emergency power supply was exposed to transient combustibles. The cause of this finding involved the cross-cutting area of human performance, the component of work practices, and the aspect of work activity planning, H.3(a), because the licensee failed to adequately evaluate transient combustible controls during planning for a work activity to monitor overloads in safety-related breakers.

Enforcement:

VC Summer Nuclear Station TS 6.8.1 states in part that procedures shall be implemented for the Fire Protection Program. Contrary to the above, on February 22, 2012, the licensee failed to implement fire protection program procedures, FPP-20 and FPP-22, to evaluate a work activity and obtain a fire protection permit for transient combustibles associated with the activity. Because the finding is of very low safety significance and because it has been entered into the licensee's CAP as CR-12-00767, this violation is being treated as a Green NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 05000395/2012002-01, Failure to Control Transient Combustibles Adjacent to a Safety-Related Motor Control Center.

1R07 Heat Sink Performance

a. Inspection Scope

The inspectors conducted one heat sink performance sample. The inspectors reviewed a visual inspection report and temperature effectiveness monitoring report for the 'B' SW motor lube oil heat exchanger. The inspectors discussed the test results with the system engineer, reviewed the applicable system health reports, and verified that the heat exchanger performance issues were entered into the licensee's CAP.

b. Findings

Introduction:

The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," for the failure to adequately prescribe a procedure to inspect the SW pump motor lube oil heat exchangers (HXs) as committed in the licensee's Generic Letter 89-13 response dated 1990. Specifically, a review of SW pump motor lube oil HX inspection documents identified that the licensee was not inspecting the internals of the lube oil HXs and did not adequately implement other accepted performance monitoring methodologies.

Description:

The inspectors performed a review of the performance monitoring program for the SW pump motor lube oil HXs as committed to in a letter dated January 31, 1990, to the NRC for their response to GL 89-13,"Service Water System Problems Affecting Safety-Related Equipment." The inspectors noted that the licensee committed to, in part, performing preventative maintenance by inspecting the water side of the SW pump motor bearing lube oil HXs on a routine basis and cleaning as required. This was allowed in lieu of testing and trending heat transfer coefficients due to the lack of instrumentation to properly measure lube oil flow or temperatures and because piping configurations prevented the use of portable flow instruments. Inspectors also noted that the licensee's engineering service procedure, ES-560.211, "Service Water System Heat Exchanger Performance," Revision 10, stated in part that it is governed by 10 CFR 50, Appendix B, and their commitments of NRC Generic Letter 89-13, and that it was revised to follow the guidelines established within EPRI NP-7552, "Heat Exchanger Performance Monitoring Guidelines," dated December, 1991. The inspectors reviewed EPRI NP-7552, Section 9, "Preventative Maintenance Method," which states in part that visual inspection done by fiber scope or disassembly, if able to cover a majority of the heat exchanger surface, is one option to testing. While the inspectors determined that the licensee did perform visual inspections of the piping flanges for the inlet and outlet piping going to the HXs, the licensee was not adequately performing visual inspections of the majority of the HX surface as defined in EPRI NP-7552. Consequently, the licensee initiated CR-12-00844 on February 28, 2012, to evaluate their performance monitoring program for the SW motor lube oil HXs. On a subsequent review of their evaluation, the inspectors noted their statement that the HXs had never been cleaned. However, inspectors determined from a review of previous before and after pictures that the HX inlet and discharge piping/flange areas have been periodically cleaned. Consequently, the inspectors were concerned that this could mask an adverse trend of internal HX fouling.

The inspectors also determined that contrary to their original GL 89-13 commitment, ES-560.211 stated that EPRI's temperature effectiveness methodology would be used for the SW pump motor lube oil HXs. However, the inspectors determined that the licensee's implementation of this methodology was not adequate because the licensee was recording SW inlet temperature and bearing temperature without also monitoring the difference in the SW inlet and outlet temperature as described in EPRI NP-7552.

Subsequently, the licensee added a corrective action to CR-12-00844 to evaluate this problem. The inspectors concluded that the licensee's failure to adequately implement the EPRI temperature effectiveness methodology could also mask an adverse trend of internal HX fouling.

The inspectors noted that ES-560.211 is an Appendix B procedure of which the purpose states in part:

"This procedure will provide a means of performance monitoring for safety-related heat exchangers cooled by Service Water. Therefore assuring these components meet the intended safety function of transferring decay heat to the ultimate heat sink as maintaining the intent of the 10CFR50, Appendix A General Design Criteria 44, 45 and 46." The inspectors also noted that 10 CFR Part 50, Appendix B, Criterion V, states in part that activities affecting quality shall be prescribed and accomplished by documented procedures. The inspectors concluded that the licensee failed to adequately prescribe ES-560.211 as required by Criterion V for an appropriate and successful performance monitoring methodology and, consequently, failed to satisfy the purpose of the procedure.

Analysis:

The inspectors determined that the failure to adequately prescribe a procedure to inspect the SW pump motor lube oil HXs was a PD. The PD was more than minor and therefore a finding because it adversely impacted the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences and the respective attribute of procedure quality because inadequate monitoring of the HX performance would lead to a common mode failure mechanism that would adversely impact the safe operation of the SW pumps during severe environmental conditions. The inspectors performed a risk evaluation using IMC 0609, Appendix A, Phase 1, and determined the finding has very low safety significance (Green) because it was not a design deficiency, did not represent a loss of safety function and did not screen as potentially risk significant due to a seismic, flooding or severe weather initiating event. This finding has no cross-cutting aspects since the PD was a legacy issue resulting from a 1990 licensing commitment and was not representative of current licensee performance.

Enforcement:

10 CFR Part 50, Appendix B, Criterion V, states in part that activities affecting quality shall be prescribed and accomplished by documented procedures. Contrary to the above, on February 28, 2012, the licensee failed to adequately prescribe procedure ES-560.211 to accomplish a performance monitoring program for the SW pump motor lube oil HXs as described in their response to GL 89-13 dated January 31, 1990, in which the licensee committed to, in part, performing inspections of the HXs in lieu of testing and trending heat transfer coefficients and to performing cleaning as required or a different performance monitoring methodology as justified and documented. Because this violation was of very low safety significance and was entered into the licensee's corrective action program as CR-12-00844, this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 05000395/2012002-02, "Failure to Properly Inspect Service Water Pump Motor Lube Oil Heat Exchangers."

1R11 Licensed Operator Requalification Program

Quarterly Resident Inspector Observations

a. Inspection Scope

The inspectors observed an operator requalification simulator training scenario occurring on March 19, 2012, which involved the failures of main turbine first stage pressure transmitter, a unit auxiliary transformer failure, a trip of the 'B' EDG following an auto-start, failure of a bearing on the 'A' component cooling water (CCW) pump motor, and a lockout on emergency bus 1DA. 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 reviewed the licensee's critique comments to verify that performance deficiencies were captured for appropriate corrective action. Additionally, the inspectors reviewed control room operator performance during periods of testing and heightened risk.

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, Revision 5, "Maintenance Rule Implementation," and station administrative procedure (SAP)-0157, Revision 0A, "Maintenance Rule Program," to verify consistency with the MR requirements.

• CR-12-00583, Maintenance Rule (a)(1) goal setting established for air handling system function #8 for adequate ventilation of the emergency diesel generator building

• 10 CFR 50.65(a)(3) assessment for Cycle 19

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors evaluated, as appropriate, for the four 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 2012-03, risk assessment for alternate power feed to new relay house resulting in yellow risk condition

• Work Week 2012-07, risk assessment for 'A' EDG outage and new relay house cable laying resulting in a yellow risk condition

• Work Week 2012-08, risk assessment for 'A' SW pump and 'A' SW booster pump, switchyard bus #2 upgrade activities resulting in an overall yellow risk condition

• Work Week 2012-09, risk assessment for scheduled maintenance on 'B' emergency diesel generator

b. Findings

No findings were identified.

1R15 Operability Evaluations

a. Inspection Scope

The inspectors reviewed four 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, Revision 0E, "Operability Determination Process," and SAP-999, Revision 5, "Corrective Action Program."

• CR-11-03323, Action 3, spray evaluation for chilled water piping crossing through the 1DB safety-related switchyard room

• CR-11-00988, minimum bend radius exceeded for 7.2 kV cables in the SWPH

• CR-12-00771, EIR-81867, Evaluate gap between bottom of eight inch SW pipe (inlet to 'A' EDG jacket water heat exchanger) and support restraint, SWH-245

• CR-12-01029, EDG 'B' relay and terminal panel missing bolts

.1 Failure to Analyze a Moderate Energy Fluid System for Leakage Cracks

Introduction:

The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," for the failure to analyze a moderate energy fluid system for leakage cracks resulting in flooding and/or spray as described in the licensee's Facility Safety Analysis Report (FSAR). Specifically, chilled water piping, located in a ladder chase above and with access to the safety-related 1DB switchgear room, was not analyzed for leakage cracks.

Description:

On June 14, 2011, the inspectors identified that an internal flooding calculation for the 1DB 7.2kV Switchgear room did not consider the 6-inch chilled water supply and return headers as water sources even though they were located above a ladder chase that would communicate with the floor of the switchgear room. The inspectors determined that this was a nonconforming condition in which the field installed piping did not match current licensing basis documents, i.e., the flooding calculation. Consequently, the licensee initiated CR-11-03323 for corrective actions and performed an evaluation that showed the flooding level in the room would be limited to 1.7 inches which would not impact the switchgear found in the room. Inspectors reviewed this evaluation against FSAR Section 3.6.2.1.1.1 which describes an "analysis-which demonstrates that acceptable protection against the effects of piping failures outside of containment" and that this analysis "satisfies the intent of the guidelines of Branch Technical Position (BTP) APCSB 3-1 and MEB 3-1," and against FSAR Section 3.6.2.1.4 which describes an analysis to postulate cracks in moderate energy piping and to form a "provision of maximum required protection against spray," unless specific exemption criteria were met. The inspectors determined that the licensee did not evaluate the aforementioned chilled water piping for postulated leakage cracks and resultant spray as required by the above FSAR sections.

On December 14, 2011, the licensee added a corrective action to CR-11-03323 and evaluated the potential for water spray on motor control center (MCC) 1DB2X with a conclusion of no impact. On January 23, 2012, inspectors reviewed the completed evaluation and determined that the section of piping above the ladder was in direct line of sight with 1DB2X which was a National Electric Manufacturing Association (NEMA) type 1 enclosure which is not rated for water spray. Consequently, the licensee performed a design calculation, DC05670-300, "MELC Evaluation 6" VU Piping" on February 2, 2012, to determine if the chilled water piping could be excluded from required protective measures based on the stress equation stated in BTP 3-1 and FSAR 3.6.1.2.4.

The inspectors reviewed DC05670-300, and noted that the licensee initially used the ASME code pressure stress values for the stress calculation which would not allow for exemption to protecting against spray. Therefore, the licensee modified the pressure stress used in the stress equation of FSAR 3.6.2.1.4 in order for the exemption criteria to be met. The inspectors are continuing to review the licensee's calculation from a corrective action standpoint in regard to proper application, or in this case the absence of the ASME code for conservative pipe stress values in evaluating the potential for pipe cracks.

Analysis:

Inspectors determined that the failure to analyze a moderate energy fluid system for leakage cracks as described in the FSAR was a PD. The PD was more than minor and therefore a finding because

(1) it was similar to IMC 0612, Appendix E, Example 3i, in that the licensee had to perform calculations to show that design basis requirements were met, and

(2) it adversely affected the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences and the respective attribute of protection of design control because the licensee failed to analyze a chilled water pipe which presented a vulnerability to a safety-related motor control center that was not designed for water spray. The inspectors reviewed IMC 0609, Attachment 4, and determined that the finding was of very low safety significance, or Green, because the finding was a design or qualification deficiency confirmed not to result in loss of operability or functionality. The cause of this finding did not involve a cross-cutting aspect because it is not indicative of current licensee performance.

Enforcement:

Title 10 CFR Part 50, Appendix B, Criterion III states in part that measures shall be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures and instructions. Contrary to the above, on February 2, 2012, the inspectors determined that the licensee failed to assure that design basis requirements regarding analysis of moderate energy system piping for leakage cracks and associated spray were correctly translated into specifications and drawings. Because this violation was of very low safety significance and it was entered into the licensee's CAP as CR-11-003323, this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 05000395/2012002-03, Failure to Analyze a Moderate Energy Fluid System for Leakage Cracks.

.2 Nonconformance of Service Water Pipe Support, SWH-245, With Design Documents

Introduction:

A URI was identified by the inspectors for a SW pipe support, SWH-245, which did not conform to the licensee's drawings and calculations.

Description:

On February 22, 2012, during a cross-train walkdown the inspectors identified that SWH-245 was not supporting it's respective SW pipe (inlet to the 'A' EDG intercooler) due to the existence of an approximate

.125 inch gap between the bottom of the pipe and the support.

The inspectors reviewed the associated design drawing, S-321-251 sheet 245A, noted that SWH-245 should carry a dead weight load of 3206 pounds, noted that the downstream inlet nozzle on the 'A' EDG intercooler, XHE0017A-HE3, would be affected, and concluded that this issue of concern was a performance deficiency. The licensee iniated CR-12-00771 and subsequently completed engineering information request (EIR) 81867 which was reviewed by the inspectors and a NRC headquarters pipe stress analyst. The NRC determined that EIR81867 contained several errors consisting of using incorrect stress values and failed to consider stress due to moments on the affected intercooler nozzle. Additionally, the inspectors determined that CR-12-00771 did not identify this problem as a nonconformance. Pending completion of the licensee's correction to their engineering evaluation for additional consideration in determining if the PD is more than minor, this is identified as URI 05000395/2012002-04, Nonconformance of Service Water Pipe Support, SWH-245, With Design Documents.

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, Revision 5A, "Post Maintenance Testing Guideline."

• WO 1108026-002, Post maintenance run of TDEFW pump following maintenance on the governor and associated linkage

• WO 1107450-001, Post maintenance test of 'B' train SW pump motor upper and lower on cooler piping/flanges

• WO 1113539-001, Major preventative maintenance on 'B' EDG including crack repair to cylinder #9 valve cover

• WO 1002016-001, Post maintenance test of FWIV's following packing adjustment, replacement of air intensifier and rebuilt air control valves

• WO 1114574-001, Disassemble flange for SW pipe inspection

b. Findings

Introduction:

A URI was identified by the inspectors for feedwater isolation valve (FWIV) testing having potentially inadequate operability testing criteria.

Description:

On March 2, 2012, during review of post maintenance test WO 1002016-001, "Post Maintenance Test of FWIVs Following Packing Adjustment, Replacement of Air Intensifier and Rebuilt Control Valves," inspectors noted that the test criteria used for stroke closure timing was not consistent with factory qualification test data taken during initial qualification of the respective air actuators where load was varied and closure time was recorded. Specifically, factory qualification tests for the actuators show closure time should be less than 1.87 seconds with no feedwater flow and 1092 psig steam generator pressure. For WO 1002016-001, operability testing of closure time was performed while the plant was in Mode 5, e.g. when there was no feedwater flow and only approximately 2.5 psig in the steam generators. However, the test acceptance criteria was 5 seconds, and the measured stroke times for the A, B and C FWIVs were 4.0, 4.1 and 4.0 seconds respectively.

The inspectors also noted that non safety-related instrument air is not isolated prior to performance of the operability test. The licensee entered the concerns into their corrective action program as CR-12-00899. The prompt operability evaluation performed by the licensee indicated that the valves were operable based on FSAR 6.2.1.3.10.3.3.2 which states in part that feedline isolation may be provided by either the feedwater isolation valve or closure of both the feedwater regulating valve and the feedwater bypass control valve. The total response time of 10 seconds includes a 1.5 second instrument response time and 8.5 second valve stroke time. The inspectors will review all regulatory aspects of this concern once the evaluation is complete in CR-12-00899. This item is identified as URI 05000395/2012002-05, Potentially Inadequate Test Criteria for Operability Testing of the Feedwater Isolation Valves.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors observed and/or reviewed the five surveillance test procedures (STPs) listed below to verify that TS or risk significant surveillance requirements were followed and that test acceptance criteria were properly specified to ensure that the equipment could perform its intended safety function. The inspectors verified that proper test conditions were established as specified in the procedures, that no equipment preconditioning activities occurred, and that acceptance criteria were met.

In-Service Tests

• STP-105.003, "Safety Injection Valve Operability Test," Revision 15

• STP-220.002, "Turbine Driven Emergency Feedwater Pump and Valve Test," Revision 7N

• STP-223,002A, "Service Water Pump Test," Revision 9E

• STP-220.002, "Reactor Building Spray Pump Test," Revision 6C Reactor Coolant Sytem Leakage Tests

• STP-114.002, "Operational Leakage Calculation," Revision 12

b. Findings

No findings were identified.

1EP6 Drill Evaluation

a. Inspection Scope

On February 15, 2012, the inspectors reviewed and observed the performance of an emergency preparedness drill that involved a component cooling water pump failure, an earthquake, a charging pump failure, failed fuel, a small break loss of coolant accident and various valve failures 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.

4OA1 Performance Indicator (PI) Verification

Cornerstone:

Initiating Events

a. Inspection Scope

The inspectors verified the accuracy of the licensee's PI submittals listed below for the period January 1, 2011, through December 31, 2011. The inspectors used the performance indicator definitions and guidance contained in NEI 99-02, Revision 6, "Regulatory Assessment Performance Indicator Guideline," and licensee procedure SAP-1360, Revision 1, "NRC and INPO/WANO Performance Indicators," to check the reporting of each data element. The inspectors sampled licensee event reports (LERs), operator logs, tagout records, plant risk records, 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.

• Unplanned Scrams per 7000 Critical Hours

• Unplanned Power Changes per 7000 Critical Hours

• Unplanned Scrams with Complications

b. Findings

No findings were identified.

4OA2 Identification and Resolution of Problems

.1 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.

.2 Annual Sample Review

CR-11-02537, XVG01036-EF seats are mis-positioned causing leakby through the valve

a. Inspection Scope

The inspectors reviewed CR-11-02537, "XVG01036-EF seats are mis-positioned causing leakby through the valve," in detail to evaluate the effectiveness of the licensee's corrective actions for important safety issues. The inspectors assessed whether the issue was properly identified; documented accurately and completely; properly classified and prioritized; adequately considered extent of condition, generic implications, common cause, and previous occurrences; adequately identified root causes/apparent causes; and identified appropriate and timely corrective actions. Also, the inspectors verified the issues were processed in accordance with procedure SAP-999, Revision 5, "Corrective Action Program."

b. Findings

No findings were identified. The inspectors noted that based on the discovery of a manufacturing defect resulting in a misalignment of the valve seats in a safety-related Anchor Darling gate valve used in emergency feedwater applications the licensee performed a Part 21 review and concluded that no report was required because there was no substantial safety hazard. Further review by the inspectors determined that the licensee's programs did not address notification of the vendor or other licensees to allow an evaluation of other potential safety-related applications of this component at other sites and verified that in fact, the licensee had not notified the vendor or other licensees through the operating experience process. In response to this programmatic vulnerability, the licensee initiated CR-12-00971 for appropriate corrective action.

The inspector's review of the Part 21 evaluation also included the licensee's accept-as-is evaluation contained in technical work record (TWR) CH42299 which included a 50.59 evaluation. The inspectors noted that the TWR stated that a search of abnormal and emergency operating procedures was performed regarding the closure of the affected valve and none were identified. The inspectors performed a search of other licensee documents including the beyond design mitigation guideline (BDMG) procedures and found that the affected valve was used. However, although the inspectors determined that there was no adverse impact since the application involved a throttling process, the inspectors identified that in regard to 10 CFR 50.54(hh) or 10 CFR 50.34(i):

• The licensee had no programmatic methods to review plant changes against the requirements of these rules;

• The licensee had no reference to these rules in any of their plant documents; and

• The licensee had not addressed the requirements of 50.34(i) which the inspectors concluded was a minor violation in regards to traditional enforcement.

The licensee entered the performance deficiencies into their CAP as CR-12-00997.

4OA3 Event Followup

(Closed) LER 05000395/2011-003-01: Inadvertent Safety Injection During Reactor Startup Due to Excessive Differential Steam Line Pressure The inspectors closed revision 0 of this LER in NRC integrated inspection report 05000395/2011004. The inspectors reviewed revision 1 of this LER and determined that there was no new information warranting any additional regulatory action. This LER is closed.

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) URI 05000395/2011005-02, Lightning Induced Trips of Safety-Related Chillers

a. Inspection Scope

The inspectors opened unresolved item (URI)05000395/2011005-02, "Lightning Induced Trips of Safety-Related Chillers," in NRC integrated inspection report 05000395/2011005 to allow further review the problem in relation to 10 CFR 50, Appendix A, General Design Criteria 2, "Natural Phenomena." The NRC completed a review which identified a previous evaluation that stated: "Although lightning is not specifically identified [in GDC 2], it is implicitly included in the natural phenomena for which protection must be provided." Additionally, with respect to GDC 4, the evaluation stated in part that the environmental conditions cited implicitly include electrical transients and their sources and that qualification of safety-related systems and components for the applicable environmental conditions is required for conformance with this criterion. Consequently, the inspectors confirmed that 10 CFR 50, Appendix B requirements are applicable to the issue of concern described in the aforementioned URI which is hereby closed as discussed below.

b. Findings

Introduction:

A Green NCV of 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," was identified by the inspectors for two examples of the failure to promptly identify and correct a condition adverse to quality involving safety-related chiller trips due to lightning.

Description:

On October 13, 2011, following a lightning strike at the station the 'A' train safety-related chiller tripped on overcurrent when the 250 amp limit for circuit 1 of the two circuit chiller was exceeded. The 'B' train of chilled water system was also inoperable which required the licensee to enter TS 3.0.3. The 'B' train chiller was returned to an operable status within 24 minutes which cleared the associated 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> action statement. The licensee entered the problem into their CAP as CR-11-05225 and performed an operability evaluation. The inspectors completed a review of this evaluation which stated, "Engineering considers the A Chiller OPERABLE and capable of performing its design and support functions as it is currently designed." The evaluation also referenced CR-11-03187 that documented a similar, previous trip of the 'C' chiller while aligned to 'A' train power on June 5, 2011, during a lightning storm. The inspectors reviewed the ACE for CR-11-03187 which noted the following: "This event is significant since it resulted in a trip of one of the station's safety-related chillers. A walkdown of the affected equipment was performed with no observed abnormal conditions. All annunciators and relay flags were reset satisfactorily. The 'C' chiller and respective fan were both restarted with no issues. No additional corrective actions are required. No additional actions are recommended relative to corrective actions that should minimize the event from recurring."

Analysis:

The inspectors determined that the failures to promptly identify and correct the CAQs for the trips of safety-related chillers due to lightning were PDs. The inspectors reviewed IMC 0612, Appendix E and determined the PDs were more than minor and therefore were findings, because they were similar to Examples 4d and 4f in that the failure to correct a condition adverse to quality led to the inoperability of the component.

Additionally, the PDs were also more than minor because they affected the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences and the respective attribute of protection against external factors such as lightning. The inspectors reviewed IMC 0609, Attachment 4, and determined that the findings were of very low safety significance or Green because the findings were not a design deficiency confirmed not to result in loss of functionality, were not a loss of safety function, and did not screen as potentially risk significant for a severe weather initiating event. The cause of the findings involved the cross-cutting area of problem identification and resolution, the component of corrective action program, and the aspect of complete and thorough evaluation, P.1(c), because the licensee failed to identify corrective actions for the safety-related chiller trips caused by lightning.

Enforcement:

10 CFR 50, Appendix B, Criterion XVI states, in part, that measures shall be established to assure that CAQs are promptly identified and corrected. Contrary to the above, on June 5 and October 13, 2011, the licensee failed to promptly identify and correct CAQs involving safety-related chiller trips due to lightning. Because the findings were of very low safety significance (Green) and were entered into the licensee's CAP as CR-11-03187 and CR-11-05225, this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 05000395/2012002-06, Failure to Promptly Correct Conditions Adverse to Quality for Lightning Induced Trips of Safety-Related Chillers.

.3 (Closed) URI 05000395/2011005-01, Fire Protection Program Requirements for Procurement and Use of Approved Fire Hose

a. Inspection Scope

The inspectors opened URI 05000395/2011005-01, "Fire Protection Program Requirements for Procurement and Use of Approved Fire Hose," in NRC integrated inspection report 05000395/2011005 to allow further review the problem and extent of condition. The inspectors completed their review, and this URI is closed.

b. Findings

Introduction:

The NRC identified an apparent violation of V.C. Summer's Nuclear Station Renewed Operating License NPF-12, 2.C(18), "Fire Protection System," with two examples for the failure to comply with Fire Protection Program (FPP) requirements in which the licensee used unapproved fire hoses.

Description:

On November 3, 2011, based on previous inspector identified fire hose issues including kinks and blemishes, the inspectors performed a focused inspection on non-collapsible fire hose. The inspectors noted that the licensee was using 1.5" Thermoid Mexacon General Purpose (GP) 250 PSI hose at a majority of the Fire Protection Evaluation Report (FPER) and non-FPER interior hose reel stations. The inspectors determined that HBD Thermoid's specification for the hose noted a minimum bend radius of 10.5", conflicting with the 5" radius of the respective hose reels. The HBD Thermoid hose was installed in 2008 at a majority of the FPER and non-FPER hose stations throughout the plant. The licensee initiated CR-11-05578 and performed an engineering evaluation to address this discrepancy.

On November 18, 2011, inspectors reviewed the engineering evaluation for the Thermoid hose, and noted that the evaluation failed to include other non-collapsible fire hose as part of an extent of condition review. The inspector's extent of condition review identified that 1.5" Gates Duro Flex hose, installed in 2011, had a minimum bend radius of 12", but was installed on six reels with a 5" radius. The licensee then initiated CR 11-05852 to evaluate the Gates Duro Flex hose. The licensee also took compensatory actions including staging approved collapsible fire hose at the two affected FPER hose reels. On November 21, 2011, an engineering evaluation for the Gates Duro Flex hose determined that two FPER hoses and four non-FPER hoses were not compatible with the hose reels due to exceeding the minimum bend radius of the hose.

The inspectors noted that the operating license for V.C. Summer requires the licensee to implement their FPP as described in the FSAR of which section 9.5.1.1 includes the FPER. Section C.1 of the FPER requires in part that technical and quality requirements will be developed for procurements. The inspectors also noted that approved, quality related procedure, Technical Requirements Package (TRP) No. 2, "Fire Protection," Revision 8, states in part that during procurement, technical requirements shall be reviewed to assure application of the appropriate requirements and determine their acceptability. The inspectors determined that the minimum bend radius requirement for the hoses purchased in 2008 was not reviewed during procurement. The inspectors also determined that this was an example of the licensee's failure to comply with their FPP.

During the FPER review, inspectors identified a second example of the licensee's failure to follow their FPP involving the Gates and HBD Thermoid hose along with the original hose that was installed prior to 2008. Inspectors noted that FSAR section 9.5.1.1 includes the FPER of which Section 5.E.3.(d) states in part that non-collapsible hose will meet the appropriate American Nuclear Insurers (ANI) specifications. Inspectors also noted ANI specification "Basic Fire Protection for Nuclear Plants," April 1976, which states that interior fire hose shall be "lined fire hose" and determined that the licensee was not in compliance.

In 1979, during construction procurement, the licensee's contractor specified 1.5" non-collapsible "Amce-Hamilton Vari-Purpose Air Hose Specification 23-5132 or equal" on the bill of material for use as fire hose. In 2008, the licensee revised Procurement Technical Requirement (PTR) ME-3N adding the following brand name for the hose manufacturer: "Thermoid Maxecon/GP." According to Thermoid's specifications sheet, GP stands for General Purpose and the hose is characterized as an air and water service hose. Further, inspectors noted that the 1.5" Gates Duro Flex hose was also multi-purpose hose. Inspectors determined that the Gates, HBD Thermoid and Acme-Hamilton hoses were not UL listed for fire protection use and were not lined fire hose.

After discovering that minimum bend radii had been exceeded and that lined fire hose was not being used, inspectors looked for recent hose failures and reviewed CR-11-01634 dated April 12, 2011, in which the licensee stated that there had been four failures of 1.5" non-collapsible rubber hose prior to May 2011. Two failures consisting of one FPER hose and one non-FPER hose were at normal operating pressure during non-emergency use. The other two failures were non-FPER hose failures during three-year hydrostatic testing. Further, at the time of these failures, the licensee had only hydrostatically tested six 1.5" non-collapsible hoses; from May 2011 until November 2011 no three-year hydrostatic tests were performed on the 1.5" non-collapsible hoses even though the hoses were purchased in 2008.

Based on the inspector's discovery of the use of unapproved fire hose, the licensee had replaced all non-collapsible rubber hose with approved, collapsible fire hose by December 10, 2011. The licensee is currently in the process of testing all 1.5" non-collapsible hoses that were removed in 2011. As of March 22, 2012, an additional 17 out of 25 non-collapsible hoses have failed the three-year hydrostatic test.

Analysis:

The inspectors identified a PD with the two aforementioned examples in which the licensee failed to comply with FPP requirements regarding the use of approved fire hose.

The PD is more than minor and therefore a finding because it impacts the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences and the respective attribute of protection against external factors such as fire. The inspectors reviewed IMC 0609, Appendix F, and determined that the finding was of moderate safety significance because the non-collapsible rubber hose and portable extinguishers are the only local means of fire suppression for several fire zones, of which the most significant are the 7.2kV safety-related switchgear rooms. The inspectors also obtained the fire ignition frequencies for the areas of concern and in consideration of the exposure time, determined that a phase 2 evaluation is required.

Consequently, the risk is to-be-determined pending completion of the risk evaluation. The cause of the finding involved the cross-cutting area of human performance, the component of work practices, and the aspect of procedural compliance, H.4(b), because the licensee failed to follow FPP procedural and program requirements for proper fire hose selection and use.

Enforcement:

V.C. Summer Nuclear Station Renewed Operating License NPF-12, 2.C(18) states, in part, that V.C. Summer Nuclear Station shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in the FSAR for the facility. FSAR section 9.5.1.1 includes the FPER of which Section 5.E.3.(d) states in part: that non-collapsible hose meet the appropriate ANI specifications and that technical and quality requirements will be developed for procurement, consistent with approved procurement procedures (FPER Section C.1). ANI specification entitled "Basic Fire Protection for Nuclear Power Plants," 1976 edition, requires in part that 1.5" lined fire hose be provided in all buildings. Contrary to the above, from the issuance date of their license to December 9, 2011, the licensee used air, general purpose and multi-purpose non-collapsible hose that was not classified or qualified as lined fire hose. Technical Requirements Package (TRP) No. 2 entitled "Fire Protection," Revision 8 states in part that the technical requirements shall be reviewed to assure application of the appropriate requirements and determine their acceptability. Contrary to the above, on August 8, 2008, the licensee modified the Procurement Technical Requirement (PTR) ME-3N entitled "Hose Reel Fire Hose: 1-1/2" Non-Collapsible," choosing a hose with a minimum bend radius of 10.5" to be used on a reel with a 5" radius. The issue was entered into the licensee's corrective action program as condition reports CR-11-05578 and CR-11-05852. Pending determination of the safety significance, this finding is identified as apparent violation (AV)05000395/2012002-07, Failure to Follow Fire Protection Program Requirements for Procurement and Use of Approved Fire Hose.

.4 (Closed) NRC Temporary Instruction (TI) 2515/177, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (NRC Generic Letter (GL) 2008-01)"

a. Inspection Scope

The inspectors reviewed the implementation of the licensee's actions in response to GL 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems." The systems reviewed included the emergency core cooling system (ECCS), residual heat removal system (RHR), and the reactor building spray system (SP).

The inspectors reviewed the licensing basis of the facility to verify that actions to address gas accumulation were consistent with the operability requirements of the subject systems.

The inspectors reviewed the design of the subject systems to verify that actions taken to address gas accumulation were appropriate, given the specifics of the functions, configurations, and capabilities of these systems. The inspectors reviewed the design and operation of the decay heat removal system to determine if flashing in RHR suction lines would challenge system operability. The inspectors reviewed selected analyses performed by the licensee to verify that methodologies for predicting gas void accumulation, movement, and impact were appropriate. The inspectors verified that the licensee's void acceptance criteria were consistent with the NRC Nuclear Reactor Regulation Office's void acceptance criteria. The inspectors performed walkdowns of selected portions of the subject systems to verify that the reviews and design verifications conducted by the licensee had drawn appropriate conclusions with respect to piping slopes and configurations that could result in gas accumulation susceptibility.

The inspectors reviewed testing implemented by the licensee to address gas accumulation in subject systems. Selected test procedures were reviewed to verify that they were appropriate to detect gas accumulations that could challenge subject systems.

The inspectors reviewed the specified testing frequencies to verify that the testing intervals had appropriately taken into account historical gas accumulation events as well as susceptibility to gas accumulation. The inspectors reviewed the station's program procedure for gas intrusion management to verify the program's adequacy to properly identify, evaluate, and prevent gas accumulation in the subject systems. The inspectors reviewed other selected gas accumulation procedures used for filling and venting following conditions which may have introduced voids into the subject systems to verify that the procedures addressed testing for such voids and provided processes for their reduction or elimination.

The inspectors reviewed selected licensee's assessment reports, CAP documents, and trending data to assess the effectiveness of the licensee's CAP when addressing the issues associated with GL 2008-01. In addition, the inspectors verified that selected corrective actions and commitments identified in the licensee's 9-month and supplemental reports were completed, or otherwise tracked in the licensee's CAP.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

On March 30, 2012, the DRS inspectors conducted an exit meeting with Mr. T. Gatlin and other members of the licensee's management and staff to discuss the results of the TI-177 inspection (Section 4OA5.4). Proprietary information reviewed by the team as part of routine inspection activities was returned to the licensee in accordance with prescribed controls.

On April 25, 2012, the resident inspectors presented the integrated inspection report 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.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

J. Archie, Senior Vice President, Nuclear Operations

A. Barbee, Director, Nuclear Training

M. Browne, Manager, Quality Systems

R. Burtt, Plant Support Engineering

M. Coleman, Manager, Health Physics and Safety Services

G. Douglass, Manager, Nuclear Protection Services

J. Garza, Nuclear Licensing

T. Gatlin, Vice President, Nuclear Operations

M. Harmon, Manager, Chemistry Services

R. Haselden, General Manager, Organizational / Development Effectiveness

R. Justice, Manager, Nuclear Operations

K. Leonelli, Design Engineering

G. Lippard, General Manager, Nuclear Plant Operations

M. Mosley, Manager, Nuclear Training

N. Smith, Operations Support

D. Shue, Manager, Maintenance Services

T. Stewart, Nuclear Licensing

W. Stuart, General Manager, Engineering Services

B. Sumner, Plant Support Engineering

B. Thompson, Manager, Nuclear Licensing

D. Weir, Manager, Plant Support Engineering

B. Wetmore, Design Engineering

R. Williamson, Manager, Emergency Planning

S. Zarandi, General Manager, Nuclear Support Services

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000395/2012002-04 URI Nonconformance of Service Water Pipe Support, SWH-245, With Design Documents (Section 1R15.2)

05000395/2012002-05 URI Potentially Inadequate Test Criteria for Operability Testing of the Feedwater Isolation Valves (Section 1R19)

05000395/2012002-07 AV Failure to Follow Fire Protection Program Requirements for Procurement and Use of Approved Fire Hose (Section 4OA5.3)

Closed

05000395/LER-2011-003-01 LER Inadvertent Safety Injection During Reactor Startup Due to Excessive Differential Steam Line Pressure (Section 4OA3)

05000395/FIN-2011005-01 URI Fire Protection Program Requirements for Procurement and Use of Fire Hose (Section 4OA5.3)

05000395/FIN-2011005-02 URI Lightning Induced Trips of Safety-Related Chillers (Section 4OA5.2)

05000395/2515/177 TI Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (NRC Generic Letter (GL) 2008-01) (Section 4OA5.4)

Opened and Closed

05000395/2012002-01 NCV Failure to Control Transient Combustibles Adjacent to a Safety-Related Motor Control Center (Section 1R05)

05000395/2012002-02 NCV Failure to Properly Inspect Service Water Pump Motor Lube Oil Heat Exchangers (Section 1R07)

05000395/2012002-03 NCV Failure to Analyze a Moderate Energy Fluid System for Leakage Cracks (Section 1R15.1)

05000395/2012002-06 NCV Failure to Promptly Correct Conditions Adverse to Quality for Lightning Induced Trips of Safety-Related Chillers

(Section 4OA5.2)

Section 1R05: Fire Protection

• TR07800-007, Rev. 0, Fire Ignition Frequency Analysis

SOP-306, Rev. 18, Emergency Diesel Generator

Section 1R07: Heat Sink Performance

ES-560.211, "Service Water System Heat Exchanger Performance," Revision 10

ES-505, Service Water System Corrosion Monitoring and Control Program," Revision 1G

• EPRI

NP-7552, "Heat Exchanger Performance Monitoring Guidelines," December 1991

• EPRI

TR-107397, "Service Water Heat Exchanger Testing Guidelines," March 1998

• SCE&G Response to Generic Letter 89-13 dated January 31, 1990

SOP-306, Rev. 18, Emergency Diesel Generator

CR-12-00844, NRC identified concerns regarding

ES-560.211 and ES-505

Section 1R15: Operability Evaluations

• Branch Technical Position APCSB 3-1, "Protection Against Postulated Piping Failures in Fuild Systems Outside Containment," November 24, 1975

CR-11-03323, NRC identified concerns regarding flooding calculation DC03490-003

• DC03490-003, "Intermediate Building Flooding Evaluation," December 9, 2002

Section 1R12: Maintenance Effectiveness

CR-12-01520, NRC identified issue with untimely maintenance rule evaluations contrary to procedure requirements Section 4OA5.3: Other Activities

CR-11-05578, NRC identified concern about exceeding the minimum bend radius of Thermoid Maxecon/GP hose being used as fire hose

CR-11-05852, NRC identified concern about exceeding the minimum bend radius of Gates Duro Flex hose being used as fire hose

STP-728.015, "Fire hose Stations Valve Flow Check, Hose Hydrostatic Pressure Test and Visual Inspection," Revision 4B

• TRP No. 2, "Fire Protection," Revision 8D

• ANI specification, "Basic Fire Protection for Nuclear Plants," April, 1976

Section 4OA5.4: Other Activities (TI-177)

Licensing Bases Documents

• ML082890534, South Carolina Electric & Gas Company, Virgil C. Summer Nuclear Station, Unit 1, Docket Nos. 50-395, Nine-Month Response to NRC Generic Letter 2008-01, October 13, 2008

• ML082890534, South Carolina Electric & Gas Company, Virgil C. Summer Nuclear Station, Unit 1, Docket Nos. 50-395, Response to RAI Related to NRC Generic Letter 2008-01

Attachment

• ML110872033, South Carolina Electric & Gas Company, Virgil C. Summer Nuclear Station, Unit 1, Docket Nos. 50-395, Closeout of NRC Generic Letter 2008-01, April 7, 2011

Procedures

ES-427, Program/Issue Screening, Rev 3

SAP 0162, Gas Intrusion Management Program, Rev 0

SOP-102, Chemical and Volume Control System, Rev 23C

SOP-112, Safety Injection System, Rev 17H

SOP-115, Residual Heat Removal, Rev 21A

SOP-116, Reactor Building Spray System, Rev 15H

STP-105.006, Safety Injection / Residual Heat Removal Monthly Flowpath Verification Test, Rev 12

STP-112.003, Reactor Building Spray System Valve Operability Test, Rev 9

STP-112.005, ECCS Void Removal Verification, Rev 1A

STP-112.010, Charging Pump Suction Piping Void Removal Verification, Rev 0

STP-112.011, Spray Pump Suction Piping Void Removal Verification, Rev 0

Drawings

• 5444, Horizontal RHR Details (Sheet 2 of 3), Rev 4

• 5493, Outline Drawing of the Horizontal RHR heat exchanger, Rev 1G

• C-314-641, Piping Stress Analysis Diagram - RHR System Isometric Dwgs. Series

• C-314-661, Piping Stress Analysis Diagram - Rx Bldg. Spray Isometric Dwgs. Series

• C-314-671, Piping Stress Analysis Diagram - Chemical Volume Control Sys - From RWST to A/B/C CCPs (SH. 23), Rev 5

• C-314-671, Piping Stress Analysis Diagram - Chemical Volume Control Sys - Charging Pumps A/B/C Suction (SH. 31), Rev 2

• C-314-691, Piping Stress Analysis Diagram - Safety Injection Isometric Dwgs. Series

• E-302-641, Piping System Flow Diagram - Residual Heat Removal, Rev 20

• E-302-651, Piping System Flow Diagram - Spent Fuel Pool Cooling, Rev 43

• E-302-661, Piping System Flow Diagram - Reactor Building Spray System, Rev 35

• E-302-675, Piping System Flow Diagram - Chemical and Volume Control, Rev 32

• E-302-691, Piping System Flow Diagram - Safety Injection, Rev 13

• E-302-692, Piping System Flow Diagram - Safety Injection, Rev 14

• E-302-693, Piping System Flow Diagram - Safety Injection, Rev 22

Calculations

• DC04410-024, Dynamic Venting and Froude Numbers for Gas Intrusion Under

GL 2008-01, Rev 0 and Rev 1

• DC04410-025, Gas Intrusion from Containment Recirculation Sump Isolation Valves, Rev 0 * DC04410-026, Evaluation of Gas Intrusion for the HHSI/Charging System, Rev 0

• DC04410-027, Evaluation of Gas Intrusion for the LHSI/RHR Spray System, Rev 0

Attachment

• DC04410-030, Parametric Evaluation of Void Volumes to Address Generic Letter 2008-01, Rev 2

• DC04660-038, Evaluation of Gas Intrusion for the Reactor Building Spray System, Rev 0

• DC05600-084, Potential Gas Accumulation Locations in SI, RH, and SP Piping, Rev 1

• DC05600-085, Review of Water Hammer Forces on SI, RH, and SP Pump Discharge Piping Due to Gas Voids, Rev 1

• DC05600-086, Review of Water Hammer Forces on SI, RH, and SP Pump Suction Piping Due to Gas Voids, Rev 1

• DC05600-087, Disposition of Possible Gas Void Locations to Mitigate Effects of Gas Intrusion in the SI, RH and SP Systems, Rev 0

EIR 81447, RWST to Pump Suction Piping Layout for Gas Intrusion Considerations, dated 9/4/2008

EIR 81464, Estimates of Potential Gas Accumulation Inside Heat Exchangers to Support Response to NRC

GL 2008-01, 9/18/2008

Self Assessment

• SA10-DE-01S, Snapshot Self-Assessment Plan/Report - NRC

TI-177 Gas Intrusion, dates 3/29/2010 - 4/09/2010

• SA11-PE-06S, Snapshot Self-Assessment Plan/Report - NRC

TI-177 Gas Intrusion, dates 09/19/11-09/22111

Engineering Changes (ECs)

ECR 50723, Generic Letter 08-01 Vent Line Additions, 2/5/2009

Miscellaneous

• Anthony P. Ulses, Reactor Systems Branch Suggestions for the Inspection of Virgil C. Summer using the guidance of Instruction 2515/177, July 28, 2010, ML101930240

• The Generic Letter (GL): "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," NRC Generic Letter 2008-01, ML072910759, January 11, 2008.

NCRs Reviewed

CR-04-03724, Westinghouse

NSAL-0407: Containment Sump Line Fluid Inventory. Review for VCSNS Applicability, 11/30/2004

CR-08-00162, Station tracking CR for NRC Generic Letter,

GL 2008-01, Response, 1/15/2008

CR-08-04230, Void Located on RHR Piping at

RB-Penetration 316, 9/30/2008

CR-08-04247, Void Located on SP Piping at Vent Valve XVT13021-SP During Performance of STP112.011, 10/1/2008

CR-08-04636, During Performance of STP105.006, RHR Venting, Small Voids Were Found on Two of the Vent Points. 11/3/2008

CR-08-04653, Void Located on SP Piping at Vent Valve XVT13013-SP During Performance of STP112.011, 11/4/2008

Attachment

CR-08-04959, Void Located on SP Piping at Vent Valve XVT13016-SP During Performance of STP112.011, 11/25/2008

CR-08-05275, Void Located on CS Piping at Vent Valve XVT18105-CS During Performance of STP112.010, 12/23/08

CR-09-00645, Void Located on SP Piping at Vent Valve XVT13021-SP During Performance of STP112.011, 2/16/2009

CR-10-00923, EIR #81639 Requests an IST Program Change, 2/26/2010

CR-10-04910, Level Indicator Reading 4", which is Below the Minimum Required Level of 5", 12/16/2010

CR-11-04287, XVT13021-SP - Void Identified During Performance of STP112.011, 8/15/2011

NCRs generated as a result of TI

CR-12-01317, Gas Accumulation Due to Adverse Slope Leading to Valve 8811A/B Not considered, 3/30/12

CR-12-01235, Alcat Gas Flow Meter Does Not Have a Calibration Sticker, 3/25/112

CR-12-01206,

SAP-162, Allowable Gas Limits, 3/22/12

CR-12-01207, Gravity Feed in Sodium Hydroxide Tank, 3/22/12

CR-12-01294, Engineering Guidance in

SAP-0162 on Void Analysis, 3/29/12

CR-12-01295, Functional Check for Air Accumulation Indication Devices, 3/29/12

CR-12-01296, Procedural Enhancement for

STP-112.003, 3/29/12

LIST OF ACRONYMS

AB Auxiliary Building

ACE Apparent Cause Evaluation

ADAMS Agency Document Access and Management System

ANI American Nuclear Insurer

ASME American Society of Mechanical Engineers

AV Apparent Violation

BTP Branch Technical Position

CAP Corrective Action Program

CAQ Condition Adverse to Quality

CB Control Building

CCW Component Cooling Water

CFR Code of Federal Regulations

CR Condition Report

DG Diesel Generator

EDG Emergency Diesel Generator

EPRI Electric Power Research Institute

ES Engineering Services Procedure

FPER Fire Protection Evaluation Report

FPP Fire Protection Program

FSAR Final Safety Analysis Report

GDC General Design Criteria

GL Generic Letter

GP General Purpose

GTP General Test Procedure

HX Heat Exchangers

IMC Inspection Manual Chapter

INPO Institute of Nuclear Power Operations

IR Inspection Report

LER Licensee Event Report

MCC Motor Control Center

MDEFW Motor Driven Emergency Feedwater

MR Maintenance Rule

NCV Non-Cited Violation

NEI Nuclear Energy Institute

NPF Nuclear Power Facility

NRC Nuclear Regulatory Commission

NUREG Nuclear Regulatory

OAP Operations Administrative Procedure

OOS Out of Service

PARS Publicly Available Records

PD Performance Deficiency

PI Performance Indicator

PMT Post-Maintenance Testing

PTR Procurement Technical Requirement

SAP Station Administrative Procedure

SCE&G South Carolina Electric and Gas

Attachment

SDP Significance Determination Process

SOP System Operating Procedure

SP Spray

SSC System, Structures, and Components

STP Surveillance Test Procedure

STS Shift Test Specialist

SW Service Water

SWPH Service Water Pumphouse

TBD To Be Determined

TDEFW Turbine Driven Emergency Feedwater

TRP Technical Requirements Package

TS Technical Specification

TWR Technical Work Record

UFSAR Updated Final Safety Analysis Report

URI Unresolved Item

VCSNS [[]]

V.C. Summer Nuclear Station

WANO World Association of Nuclear Operators WO Work Order