IR 05000395/2018004
| ML19052A609 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 02/21/2019 |
| From: | Randy Musser NRC/RGN-II |
| To: | Lippard G South Carolina Electric & Gas Co |
| Geanette D | |
| References | |
| IR 2018004 | |
| Download: ML19052A609 (28) | |
Text
ary 21, 2019
SUBJECT:
REISSUED - VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1 - NUCLEAR REGULATORY COMMISSION INTEGRATED INSPECTION REPORT 05000395/2018004
Dear Mr. Lippard:
On February 13, 2019, the U.S. Nuclear Regulatory Commission (NRC) issued the subject inspection report for Virgil C. Summer Nuclear Station, Agencywide Document and Management System (ADAMS) Accession Number ML19044A634. After the inspection report was issued, the NRC noted that the report cover page incorrectly stated, On February 29, 2019, the NRC inspectors discussed the results of this inspection with you and other members of your staff. Accordingly, we have revised Inspection Report (IR) 05000395/2018004 to document the necessary changes. Please replace the original report with the report enclosed.
This reissued report does not change any NRC position that has been communicated in the previously issued report.
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/
Randall A. Musser, Chief Reactor Projects Branch 3 Division of Reactor Projects ary 13, 2019
SUBJECT:
REISSUED - VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1 - NUCLEAR REGULATORY COMMISSION INTEGRATED INSPECTION REPORT 05000395/2018004
Dear Mr. Lippard:
On December 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Virgil C. Summer Nuclear Station, Unit 1. On January 29, 2019, the NRC inspectors discussed the results of this inspection with you and other members of your staff.
The results of this inspection are documented in the enclosed report.
NRC inspectors documented one finding of very low safety significance (Green) in this report.
The finding involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.
If you contest the violation or significance of this NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC resident inspector at the Virgil C. Summer Nuclear Station.
If you disagree with the cross-cutting aspects assigned to the findings 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 U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC resident inspector at the Virgil C. Summer Nuclear Station.
Enclosure 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/
Randall A. Musser, Chief Reactor Projects Branch 3 Division of Reactor Projects Docket No.: 50-395 License No.: NPF-12
Enclosure:
REGION II==
Docket No: 50-395 License No: NPF-12 Report No: 05000395/2018004 Enterprise Identifier: I-2018-004-0046 Licensee: South Carolina Electric & Gas (SCE&G) Company Facility: Virgil C. Summer Nuclear Station, Unit 1 Location: Jenkinsville, SC 29065 Dates: October 1, 2018 through December 31, 2018 Inspectors: J. Reece, Senior Resident Inspector E. Hilton, Resident Inspector J. Diaz-Velez, Senior Health Physicist (Sections 71124.04 and 71151)
S. Downey, Senior Reactor Inspector (Sections 7111108)
C. Dykes, Health Physicist (Section 71124.05)
D. Lanyi, Senior Operations Engineer (Section 1R11)
W. Loo, Senior Health Physicist (Sections 71124.02 and 71124.03)
A. Nielsen, Senior Health Physicist (Sections 71124.01 and 71124.03)
W. Pursley, Health Physicist (Section 71124.02)
R. Williams, Senior Reactor Inspector (Section 71111.08)
Approved by: Randall A. Musser, Chief Reactor Projects Branch 3 Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring licensees performance by conducting a baseline inspection and radiation protection inspection at Virgil C. Summer Nuclear Station, Unit 1, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC and self- revealed findings, violations, and additional items are summarized in the table below. A licensee-identified non-cited violation was documented in report Section 71124.01.
List of Findings and Violations Inadequate Procedure Leading to A EDG Fire Event Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Green NCV [P.3] - Resolution 71111.13 - Maintenance Systems05000395/2018004-02 Risk Assessments and Opened/Closed Emergent Work Control &
71111.19 - Post Maintenance Testing A self-revealing, Green NCV of Technical Specification 6.8, Procedures and Programs, was identified for the failure to ensure procedures for performing maintenance on the A EDG were adequately established which led to a leak in the A EDG exhaust manifold and a consequent fire event.
PLANT STATUS
Unit 1 operated at rated thermal power (RTP) until October 5, 2018, when the unit entered refueling outage 24. The unit return to service on November 28, 2018, and reached RTP on November 29, 2018, and remained at or near RTP for the remainder of the quarter.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection Seasonal Extreme Weather
The inspectors evaluated readiness of the condensate storage tank on December 18, 2018, and the emergency diesel generators (EDG) on December 19, 2018, for seasonal extreme weather conditions prior to the onset of cold temperatures associated with the fall and early winter seasons.
Impending Severe Weather (1 Sample)
The inspectors evaluated readiness for impending adverse weather conditions for Hurricane Michael on October 10, 2018.
71111.04 - Equipment Alignment Partial Walkdown
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) A and B motor driven emergency feedwater (MDEFW) pumps during emergent work on turbine driven emergency feedwater (TDEFW) pump flow control valve; inspection was completed on December 13, 2018
71111.04 - Equipment Alignment Detailed Walkdown
The inspectors evaluated system configurations during a complete walkdown of the A and B trains of the emergency feedwater (EFW) system inside containment; inspection was completed on November 18, 2018.
71111.05AQ - Fire Protection Annual/Quarterly Quarterly Inspection
The inspectors evaluated fire protection program implementation in the following selected areas. A licensee identified violation is documented in the Inspection Results section below.
- (1) Intermediate building 436 elevation (fire zones IB01.25.05.01, and
.02 ,
IB01.25.06.01, and
.02 , IB01.14); inspection was completed on October 17, 2018
- (2) Turbine building (fire zone TB01.01); inspection was completed on October 17, 2018
- (3) Reactor building containment (fire zone RB01); inspection was completed on November 15, 2018
- (4) Control building 482 elevation (fire zones CB22, CB23); inspection was completed on December 28, 2018
- (5) Fire service (FS) pumps and alternate FS pumps (fire zones AFSPH01, CWPH01, CWPH02); inspection was completed on December 28, 2018
Annual Inspection (1 Sample)
The inspectors evaluated fire brigade performance during a fire drill; inspection was completed on December 12, 2018.
71111.07A - Heat Sink Performance
On October 28, 2018, the inspectors evaluated the readiness and availability of B component cooling water (CCW) heat exchanger (HX) during inspection and cleaning.
71111.08 - Inservice Inspection Activities
The inspectors evaluated pressurized water reactor non-destructive testing by reviewing the following examinations from October 15, 2018 to October 25, 2018:
- (1) Eddy Current Examination a) Steam Generator A - ET for tubes R02C25, R110C91, R110C51, ASME Class 1 b) Steam Generator B - ET for tubes R19C40, R02C39, ASME Class 1 c) Steam Generator C - ET for tube R115C62, ASME Class 1
- (2) Liquid Penetrant Examination a) Weld MW-13, pipe to valve weld, ASME Class 2. This included a review of associated welding activities b) Weld MW-14, pipe to valve weld, ASME Class 2.
c) Weld MW-30, pipe to flange weld, ASME Class 3. This included a review of associated welding activities d) Weld MW-31, pipe to flange weld, ASME Class 3
- (3) Magnetic Particle Examination a) Weld MW-24, pipe to flange weld, ASME Class 3. This included a review of associated welding activities.
b) Weld MW-25, pipe to pipe weld, ASME Class 3.
c) Weld MW-32, pipe to flange weld, ASME Class 3
- (4) Ultrasonic Examination a) Weld CGR-1-4308-3, pipe to elbow weld, ASME Class 1 b) Weld CGR-1-4308-4, pipe to elbow weld, ASME Class 1 c) Weld CGE-1-4104-19, pipe to elbow weld, ASME Class 1 The Inspectors evaluated the licensees boric acid control program performance.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification
The inspectors observed and evaluated an operator requalification simulator exam scenario occurring on December 10, 2018.
Operator Performance (3 Samples)
The inspectors observed and evaluated:
- (1) Unit 1 shutdown for refueling outage; observation was completed on October 5, 2018
- (2) Unit reactor coolant system (RCS) cooldown and operator response to letdown alarms; observation was completed on October 6, 2018
- (3) Operators performing transformer lockout testing, maintaining level in steam generators (SG) and secured B EFW pump; observation was completed on October 12, 2018 Annual Review of Licensee Requalification Examination Results (1 Sample)
On August 16, 2018, the licensee completed the annual requalification operating examinations required to be administered to all licensed operators in accordance with Title 10 of the Code of Federal Regulations 55.59(a)(2),
Requalification Requirements, of the NRCs Operators Licenses. The inspectors performed an in-office review of the overall pass/fail results of the individual operating examinations and the crew simulator operating examinations in accordance with Inspection Procedure (IP) 71111.11, Licensed Operator Requalification Program. These results were compared to the thresholds established in Section 3.02, Requalification Examination Results, of IP 71111.11.
71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
- (1) B EDG service water (SW) return piping pinhole leak and subsequent repairs; inspection was completed on November 7, 2018
- (2) Maintenance Rule (a)(1) evaluation for risk significant function, AH08d, EDG ventilation; inspection was completed on December 11, 2018
71111.13 - Maintenance Risk Assessments and Emergent Work Control
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
- (1) Yellow risk condition for RCS lowered inventory for reactor vessel head removal; inspection was completed on November 17, 2018
- (2) Emergent work for repairs on A EDG exhaust system fire; inspection was completed on November 5, 2018
- (3) Emergent work for repairs on digital control system cabinet for moisture separator re-heaters and feedwater heaters; inspection was completed on November 27, 2018
- (4) Emergent work on TDEFW pump flow control valve; inspection was completed on December 13, 2018
71111.15 - Operability Determinations and Functionality Assessments
The inspectors evaluated the following operability determinations and functionality assessments in review of Condition Reports:
- (2) CR-18-01032, Past operability review for SG PORV failure to open; inspection was completed on October 23, 2018
- (3) CR-18-04866, Past operability review for RBCU flow switch IFS1900B; inspection was completed on December 11, 2018
71111.18 - Plant Modifications
The inspectors evaluated procedure controlled temporary modification, Work Order (WO)
===1711177, install temporary power to A spent fuel pool (SFP) pump motor; inspection was completed on November 13, 2018
71111.19 - Post Maintenance Testing (PMT)
The inspectors evaluated the following post maintenance tests:
- (1) WO1709582, A component cooling water (CCW) heat exchanger hydrolase or clean tubes, leak test; inspection was completed on October 30, 2018
- (2) WO1816658, Implement ECR50933B to repair cavitation damage at XVB03121A-SW, SW discharge butterfly valve for A EDG ; inspection was completed on October 29, 2018
- (4) WO1711625, B and C charging pump flow test after maintenance; inspection was completed on November 8, 2018
- (5) WO1711495, Perform as found testing of breaker APN1FB-15; inspection was completed on November 13, 2018
- (6) WO1820647, Repair air leak on IFV03556-PRZ-EF for TDEFW flow control valve; inspection was completed on December 27, 2018
- (7) WO1711728, Repair relief valve with seat leakage on XVR03146C-SW; inspection completed on December 31, 2018
71111.20 - Refueling and Other Outage Activities
The inspectors evaluated Unit 1 refueling outage activities from October 5, 2018, until reactor startup was completed on November 24, 2018. The inspection was completed on November 24, 2018.
71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Routine
- (1) Surveillance Test Procedure (STP) 206.001, Integrated Leak Rate Test, Revision 5; inspection was completed on October 11, 2018
- (2) STP-220.001A, Motor Driven Emergency Feedwater Pump and Valve Test, Revision 12, and STP 220.008, Motor Driven Emergency Feedwater Pump Full Flow Test, Revision 7C; inspection was completed on October 2, 2018 Reactor Coolant System Leakage Detection Testing ===
STP-114.002, Operational Leakage Calculation, Revision 12G; inspection was completed on November 28, 2018
Containment Isolation Valve(s) (1 Sample)
STP-215-003A, Containment Isolation Valve Leakage Test for the CVCS, ND, RC, SF, ST, SP and WL Systems, Revision 7B; inspection was completed on November 15, 2018
In-service (1 Sample)
STP 230.006A, ECCS Charging Pump Operability Testing (Refueling), Revision 8E; inspection was completed on November 21,
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls Radiological Hazard Assessment
===The inspectors evaluated radiological hazards assessments and controls.
Instructions to Workers===
The inspectors evaluated worker instructions.
Contamination and Radioactive Material Control (1 Sample)
The inspectors evaluated contamination and radioactive material controls.
Radiological Hazards Control and Work Coverage (1 Sample)
The inspectors evaluated radiological hazards control and work coverage.
High Radiation Area and Very High Radiation Area Controls (1 Sample)
The inspectors evaluated risk-significant high radiation area and very high radiation area controls.
Radiation Worker Performance and Radiation Protection Technician Proficiency (1 Sample)
The inspectors evaluated radiation worker performance and radiation protection technician proficiency.
71124.02 - Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls Radiological Work Planning
The inspectors evaluated the licensees radiological work planning by reviewing the following activities:
- (1) Primary Side Steam Generator Work, RWP: 18-04900, RF-24 Primary Steam Generator Work
- (2) Secondary Steam Generator Work, RWP: 18-04902, RF-24 Secondary Side Steam Generator Work Verification of Dose Estimates and Exposure Tracking Systems (1 Sample)
The inspectors evaluated dose estimates and exposure tracking.
Implementation of ALARA and Radiological Work Controls (4 Samples)
The inspectors reviewed ALARA practices and radiological work controls by reviewing the following activities:
- (1) Fuel Movement, RWP-18-4200, RF24 Refuel Activities
- (2) Primary Steam Generator Prep Activities, RWP-4900, RF-24 Primary Manways/Diaphragms/Weld Exam
- (3) Scaffold Installation, RWP-18-4003, Outage Scaffold Installation
- (4) HP Activities, RWP-18-4006, Health Physics Activities for RF24
Radiation Worker Performance (1 Sample)
The inspectors evaluated radiation worker and radiation protection technician performance.
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation Engineering Controls
The inspectors evaluated airborne controls and monitoring.
Use of Respiratory Protection Devices
The inspectors evaluated respiratory protection.
Self-Contained Breathing Apparatus for Emergency Use (1 Sample)
The inspectors evaluated the licensees self-contained breathing apparatus program.
71124.04 - Occupational Dose Assessment Source Term Characterization
===The inspectors evaluated the licensees source term characterization.
External Dosimetry===
The inspectors evaluated the licensees external dosimetry program.
Internal Dosimetry (1 Sample)
The inspectors evaluated the licensees internal dosimetry program.
Special Dosimetric Situations (1 Sample)
The inspectors evaluated the licensees performance for special dosimetric situations.
71124.05 - Radiation Monitoring Instrumentation Walk Downs and Observations
The inspectors evaluated radiation monitoring instrumentation during plant walkdowns.
Calibration and Testing Program (1 Sample)
The inspectors evaluated the licensees calibration and testing program.
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below for the period from October 1, 2017 through September 30, 2018. Inspection was completed on November 15, 2018.
- (1) Mitigating System Performance Index (MSPI) - Heat Removal System
- (2) MSPI - Cooling Water Systems
- (3) Safety System Functional Failures
71151 - Performance Indicator Verification from Radiation Protection Inspection
The inspectors verified licensee performance indicators submittals listed below for the period from April 1, 2017 through September 30, 2018.
- (1) OR01: Occupational Exposure Control Effectiveness
- (2) PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences
71152 - Problem Identification and Resolution Semiannual Trend Review
The inspectors reviewed the licensees corrective action program for trends that might be indicative of a more significant safety issue. Specifically, the inspectors reviewed CR-18-02820, Service water pinhole leaks. Inspections were completed on December 12,
INSPECTION RESULTS
Inadequate Procedure Leading to A EDG Fire Event Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Green NCV [P.3] - Resolution
71111.13 - Maintenance Systems05000395/2018004-02
Risk Assessments and Opened/Closed Emergent Work Control &
71111.19 - Post Maintenance Testing
A self-revealing, Green NCV of Technical Specification 6.8, Procedures and Programs, was identified for the failure to ensure procedures for performing maintenance on the A EDG were adequately established which led to a leak in the A EDG exhaust manifold and a consequent fire event.
Description:
On November 4, 2018, during a surveillance test of the A EDG, exhaust fumes were reported by the operator. Following review by maintenance personnel, the licensee made the determination that this was a normal condition and the decision to load the EDG was made.
Approximately 16 minutes into the full load run, the operators identified visible flames near the exhaust manifold in the vicinity of the turbochargers. The A EDG was immediately unloaded, shutdown, and declared inoperable; operators extinguished the fire using an extinguisher.
The licensee initiated CR-18-05016 to document the event, perform an investigation of the cause, and implement repairs.
The inspectors reviewed the licensees corrective action program (CAP) database and noted that on August 23, 2018, the licensee initiated CR-18-03451 to document an exhaust leak on the A EDG near the turbochargers during a post-maintenance run. The CR was updated on the following day to state that exhaust fumes were no longer visible when the EDG was loaded to greater than 3000 kilo-watts due to suspected gasket leakage prior to exhaust manifold warming up. The inspectors reviewed maintenance history and noted that the exhaust manifold assembly on A EDG was replaced during the Fall refueling outage in 2015, due to cracks in circumferential welds. Additionally, the B EDG exhaust manifold was replaced during the Spring refueling outage in 2017, for similar reasons.
The inspectors reviewed the results of the investigation documented in CR-18-05016 and noted the following comments: it was determined the exhaust manifold bellows flange serving the #8, #9, and #12 cylinders nearest the right bank turbo was almost completely disassembled and was the source of the significant exhaust leakage. Five of the six bellows flange bolts had worked loose and had fallen off into the exhaust manifold shroud and/or cover which provided approximately a 1/4 wide circumferential gap allowing exhaust gas leakage. The inspectors noted the hot gas leakage along with residual oil led to the fire.
While the licensee did not perform an apparent cause evaluation, the inspectors noted that related vendor drawing P12620219, Sheet 1 of 3, specified a torque value of 35 - 50 foot pounds for the bolts which had loosened and fallen out of the exhaust bellows flanges. The inspectors reviewed safety-related mechanical maintenance procedure, MMP-180.050, Diesel Generator Exhaust Manifold Maintenance, XEG0001A/B-E, Revision 1, and noted that step 7.2.4 stated, Tighten exhaust joints and bellows bolts wrench tight verifying bolts do not protrude through the nut plate and contact the bellows. The inspectors noted there was no torque specification for the bolting.
The inspectors concluded the licensee failed to adequately establish MMP-180.050 to stipulate required torque specifications contrary to the requirements of TS 6.8.1a, which states in part that written procedures shall be established covering the activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2, Section 9, Procedures for Performing Maintenance. Although the failure occurred during a refueling outage with the unit in a defueled mode in which the A EDG was not required by TS or for risk mitigation, the inspectors also concluded that had the A EDG been depended upon during its mission time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> during the previous operating cycle, the resulting vibration, loss of bolting material, and resultant exhaust leakage most likely would have led to a fire event.
Additionally, the inspectors concluded that the licensee had opportunities for more timely corrective action prior to the fire event when identified previously in CR-18-03451.
Corrective Action(s): The licensee implemented CR-18-05016 to identify causes and appropriate corrective actions.
Corrective Action Reference(s): The licensee entered this issue into their CAP as CR-18-05016. CR-18-03451 was also previously initiated for an exhaust leak on A EDG. WO 1818803 was initiated to correct the similar condition adverse to quality (CAQ) on B EDG.
Performance Assessment:
Performance Deficiency: The licensees failure to adequately establish MMP-180.050 with required torque values which led to exhaust leakage and consequent fire event was a performance deficiency (PD).
Screening: The inspectors determined the PD was more than minor because 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 equipment performance relative to maintenance. Specifically, the licensee failed to adequately establish MMP-180.050 with required torque values for exhaust manifold bolting material.
Significance: The inspectors used IMC 0609, Significant Determination Process, 4, dated October 7, 2016, and Appendix A - Exhibit 2, dated July 1, 2012, and determined the finding was of very low safety significance or Green because the finding was not a design deficiency or loss of function.
Cross-cutting Aspect: The inspectors reviewed IMC 0310, Aspects Within Cross Cutting Areas, dated December 4, 2014, and determined the cause of this finding involved the cross-cutting area of problem identification and resolution and the aspect of resolution, P.3, because the licensee failed to take effective corrective actions commensurate with an issues safety significance in that they failed to correct a CAQ involving the A EDG exhaust leak documented in CR-18-03451.
Enforcement:
Violation: TS 6.8.1a states in part that written procedures shall be established covering the activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Section 9 of RG 1.33 requires procedures for performing maintenance on safety related equipment. MMP-180.050, Diesel Generator Exhaust Manifold Maintenance, XEG0001A/B-E, Revision 1, was established to perform maintenance on the EDG exhaust manifolds.
Contrary to the above, on November 4, 2018, the licensee failed to adequately establish MMP-180.050 to stipulate required torque specifications for bolting materials which led to exhaust leakage and consequent fire event Disposition: This violation is being treated as an NCV consistent with Section 2.3.2.a of the Enforcement Policy.
Observation and Minor Violation for SW Pinhole Leaks 71152 Trend Review Minor Violation: 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, for failure to promptly identify and correct a condition adverse to quality (CAQ). Specifically, the licensee did not initiate corrective actions related to cavitation damage on the downstream pipe tees for the component cooling water heat exchanger discharge butterfly valves, XVB03123A&B-SW, which are normally throttled for flow control. As a result, the piping tees were damaged to the extent that multiple pinhole leaks developed requiring the licensee to seek NRC approval for multiple relief requests and non-code repairs.
Screening: Because the licensee implemented prompt corrective actions during the subsequent refueling outage and the components remained in an operable but degraded condition, the inspectors identified this as a minor violation of Criterion XVI.
Enforcement:
This failure to comply with 10 CFR 50, Appendix B, Criterion XVI constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy. The licensee entered the multiple problems into their CAP as trend CR-18-02820.
The inspectors performed a corrective action program (CAP) trend review for problems related to service water (SW) pinhole leaks after facilitating multiple licensee requests for temporary non-code repairs for SW pinhole leaks for emergency diesel generators (EDGs)and component cooling water (CCW) heat exchangers (Hx) over the previous inspection quarters. Additionally, the inspectors noted the licensee initiated CR-18-02820 for a similar trend and to also perform a common cause evaluation. Specifically, the inspectors identified 14 CRs for SW pinhole leaks and are listed in the documents attachment.
The inspectors had previously documented CAP observations and a minor violation regarding cavitation damage downstream of throttled butterfly valves in NRC Integrated Inspection Report 05000395/2018001. The observations discuss historical aspects of cavitation damage relating to the downstream SW piping for the EDGs. The inspectors identified additional historical information relating to the licensees awareness of the cavitation issues associated with throttle butterfly valves, XVB03123A&B-SW.
- An engineering Technical Work Record, TWR-LS11312, dated May 18, 2005, evaluated wall thinning downstream of a butterfly valve, XVB03125A-SW, throttled for back-flushing of CCW Hxs. The TWR stated, The CC Hx valves are manufactured by Henry Pratt and the Henry Pratt Company recommends that their butterfly valve not be used for throttling with less than a 15 degree opening or when cavitation can occur.
- An engineering services procedure, ES-505, Service Water System Corrosion Control and Monitoring Program, inspection of XVB03123B-SW on May 6, 2008, had pictures of the gate valve which exhibited cavitation damage.
- An ES-505 inspection of XVB03123A-SW on October 27, 2009, had pictures of the gate valve and downstream piping. The inspectors noted both components exhibited indications of cavitation damage when compared to other components with known cavitation damage. The inspectors noted the licensee documented the inspection was performed for suspected cavitation but there were no indications of cavitation.
- An ES-505 inspection conducted on the same valve on October 27, 2012, stated, The valve body and disc had areas of moderate cavitation damage from years of throttling.
The inspectors identified pictures with similar cavitation damage as shown in the 2009 pictures of the same component. The inspectors also noted the licensee failed to provide any documentation of the downstream piping tee.
- The inspectors identified historical operating experience (OE) documents within the licensees OE files discussing the cavitation phenomenon with one of the primary causes as the throttling of butterfly valves for flow control.
Licensee Identified Non-Cited Violation 71124.01 Inspection Results This violation of very low safety significant was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a Non-Cited Violation, consistent with Section 2.3.2 of the Enforcement Policy.
Violation: TS 6.8.1, Procedures and Programs, requires, in part, that written procedures be implemented covering the activities recommended in Appendix A of Regulatory Guide 1.33, Rev. 2, Section 7(e), Radiation Protection Procedures. Specifically, VCS-HPP-0160.001, Radiological Posting and Labeling, Revision 1, Attachment II, HRA, LHRA, and VHRA Down-Posting Checklist, states in part, that prior to actual down posting, HP survey the area to confirm radiation levels do not exceed criteria for down-posted conditions prior to worker access.
Contrary to the above, on November 3, 2018, prior to an actual down posting, the licensee did not conduct a survey of the area to confirm that radiation levels did not exceed criteria for down-posted conditions prior to worker access. Specifically, after the HRA boundary around the reactor head was moved on November 3, 2018, a survey was not performed until the next shift by an HP who identified dose rates up to 110 mr/hr at 30 cm outside the posted HRA boundary.
Significance/Severity Level: The inspectors reviewed Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, dated August 19, 2008, and determined the finding was of very low safety significance, Green, because the finding was not related to the As Low As Reasonably Achievable (ALARA)planning, did not involve an overexposure or substantial potential for overexposure, and the ability to assess dose was not compromised.
Corrective Action Reference: The licensee has documented this problem in their CAP as CR-18-05037.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
The inspectors confirmed that proprietary information was controlled to protect from public disclosure.
On October 25, 2018, the inspector presented the in-service inspection results to George Lippard, Site Vice President, and other members of the licensee staff.
On November 9, 2018, the inspectors presented the baseline radiation protection inspection results to Mr. George Lippard and other members of the licensee staff.
On January 29, 2019, the inspectors presented the quarterly resident inspector inspection results to Mr. George Lippard and other members of the licensee staff.
DOCUMENTS REVIEWED
71111.01 - Adverse Weather Protection
OAP 109.1, Guidelines for Severe Weather
71111.04 - Equipment Alignment
SOP-211, EMERGENCY FEEDWATER SYSTEM, Rev 14I
Drawing number C-314-081 sheet 25, Rev 8
Drawing number C-314-081 sheet 23, Rev 9
Drawing number C-314-081 sheet 27, Rev 7
Drawing number E-001-031, Rev 53
Drawing number E-001-021, Rev 62
Drawing number D-302-083, Rev 54
CR-18-04827, NRC Identified paint flaking on EFW piping in containment
CR-18-04828, NRC Identified rotated pipe support on EFW piping in containment
71111.05A/Q - Fire Protection Annual/Quarterly
29-CFR-1910.1200, Hazard Communications
29-CFR-1910.120, Hazardous Waste Operations and Emergency Response
AOP-900.01, Fire Response Initial Actions, Rev 3
AOP-900.011, Yard Fire Zone Response Actions, Rev 0
MSDS Exxon Univolt 60
MSDS DIALA Oil AX
Specification, SP-0326, Main Power Transformer, Rev 1
VCS-ERP-0020, ERU Preplan Development and Control, Rev 0
VCS-ERP-0080, ERU Emergency Response Drill Management, Rev 1
CR-18-05943, Station Fire Preplan for Transformer Yard Not Adequate
STP-728.030, Reactor Building Fire Barrier Inspection, Rev 5B
STP-728.033, Turbine Building Fire Barrier Inspection, Rev 5J
STP-728.048, Intermediate Building Elevation 436 Fire Barrier Inspection, Rev 4G
STP-728.041 Control Building Elevation 505 & 482 Fire Barrier Inspection, Rev 5D
STP-728.032, Fire Service Pump House Building Fire Barrier Inspection, Rev 5B
71111.08 - Inservice Inspection Activities
Procedures
54-ISI-400-022, Multi-Frequency Eddy Current Examination of Tubing, Rev 22
Examination Technique Specification Sheet: ETSS1, ETSS2, ETSS3
PSEG-19, Boric Acid Corrosion Evaluation, Rev 2
QSP-504, Magnetic Particle Testing, Rev 9
SAP-1100, Boric Acid Corrosion Control Program, Rev 3
SGMP-100.006, Steam Generator Tube Inspection Eddy Current Data Analyst Guidelines, Rev 4
VCS-PTP-151.001A, Inspection for Boric Acid Corrosion, Rev 0
VCS-QSP-501, Solvent Removable Liquid Penetrant, Rev 1
WD-STD-1036, Generic Procedure for the Ultrasonic Examination of Austenitic Pipe Welds in
Accordance with PDI-UT-2, Rev 4
WM-1.0, Welding Manual Procedure, Rev 16
NDE Examiner Qualifications:
Certificate of Personnel Qualification for Examiners: C3340, D4825, M6664, F1726, R3716
Curtiss-Wright Personnel Certification Statement (Pearson), dated 03/18/2017
Curtiss-Wright Personnel Certification Statement (Weidner), dated 11/7/2016
Sonic Systems International Certificate of Qualification (Michael), dated 08/16/2018
Sonic Systems International Certificate of Qualification (Shaugabay), dated 08/22/2018
System One Certificate of Method Qualification (Stone), Level II - Magnetic Particle, dated
01/04/2017
Condition Reports
CR-17-02169 CR-18-02857 CR-18-04458
CR-17-02244 CR-18-03144 CR-18-04459
CR-17-04662 CR-18-03647 CR-18-04644
CR-18-00305 CR-18-04456
CR-18-02808 CR-18-04457
Miscellaneous Documents
51-9289098, VC Summer 1RF24 Steam Generator Degradation Assessment (Fall 2018), Rev 1
51-9289100, Site Validation of Eddy Current Techniques for V C Summer 1RF24, Rev 0
51-9289124, VC Summer Unit 1 - RF24 ECT Inspection Plan, Rev 0
Certificate of Performance for Eddy Current Probe SNs: 754362, 754385
ECR 50933B, SW Cooler Return Piping Replacement
SAP-0158 Steam Generator Management Program, Rev 3
SG-SGMP-14-15, V.C. Summer Unit 1 Steam Generator Cycle 21 Condition Monitoring and
Cycles 22, 23 and 24 Operational Assessment, Rev 0
UT Report No. RF24-UT-001, dated 10/16/2018
Work Orders: 1703793-002, 1704591-002, 1814841-001
71111.12 - Maintenance Effectiveness
WO 1814841, Implement ECR 50933B to repair SW piping pinhole leaks
ECR 50933B, Modification to change SW piping configuration to reduce cavitation
FSAR Sections: 1.2.3.8.1, 3.7, 3.9.2, 9.2.1, 9.4.7, 18.2.33
Drawing, 302-222, sheets 1 & 3
CR-18-03942, XFN0045B failed to start on 9/26/18
71111.20 - Refueling and Other Outage Activities
GOP-2, Plant Startup and Heat-up (Mode 5 To Mode 3), Rev 18
GOP-3, Reactor Startup From Hot Standby To Startup (Mode 3 To Mode 2), Rev 13G
GOP-4B, Power Operation (Mode 1 - DESCENDING), Rev 1F
GOP-5, Reactor Shutdown From Startup To Hot Standby (Mode 2 To Mode 3), Rev 12C
GOP-6 Plant Shutdown From Hot Standby To Cold Shutdown (Mode 3 To Mode 5), Rev 14C
GOP-7 Core Refueling (Mode 5 To Mode 6 Defuel and Refuel To Mode 6), Rev 11G
SOP-101, Reactor Coolant System, Rev 30K
SOP-115, Residual Heat Removal, Rev 22E
SOP-117, Service Water System, Rev 24E
SOP-118, Component Cooling Water, Rev 19A
SOP-123, Spent Fuel Cooling System, Rev 16I
SOP-211, Emergency Feedwater System, Rev 14I
SOP-304,115KV 7.2KV OPERATIONS, Rev 14B
SOP-305, 480 Volt Engineered Safety Features Distribution, Rev 9F
SOP-306, Emergency Diesel Generator, Rev 19E
SOP-307, Diesel Generator Fuel Oil System, Rev 13D
SOP-310, Engineered Safety Features 120 VAC Instrumentation and Control Power System, Rev 12A
SOP-311, 125 VDC System, Rev 13
SSP-002, Planning and Scheduling of Outage Activities, Rev 6H
SSP-004, Outage Safety Review Guidelines, Rev 5D
SSP-010, Control of Critical Work Activities, Rev 1B
Core Reload Verification
MTF 18-13, Core Offload
MTF 18-15, Core Reload
SAP-0152, Fatigue Management and Work Hour Limits, Rev 10A
OAP-108.4, Operations Outage Control of Containment Penetrations, Rev 2D
DC00020-252, V.C. SUMMER Time To Boil Following Loss of Decay Heat Cooling in Mode 5
DC00020-198, Heat-Up Model for Water in the SFP, Reactor Cavity, and Reactor Vessel
71111.18 - Plant Modifications
EMP-100.004, Installation of Temporary Alternate Feed Cable for Spent Fuel Pumps, Rev 6b
SAP-364, Control of Temporary Cables, Rev
SS-200-927, Sheet 3, 480 Volt Load Center Relay and Breaker Settings (Breaker 1A3)
SS-200-927, Sheet 15, 480 Volt Load Center Relay and Breaker Settings (Breaker 1DA2)
SS-200-927, Sheet 17, 480 Volt Load Center Relay and Breaker Settings (Breaker DB2)
Request for Engineering Evaluation, REE22572, Emergency Power for SF Cooling Pumps
71151 - Performance Indicator Verification
Control Room Logs for October 1, 2017 through September 30, 2018
Licensee raw MSPI data for Months of October, 2017 through September, 2018
Procedures
VCS-EPAP-0106 Emergency Preparedness Performance Indicator Procedure. Rev. 2
Records and Data
DEP opportunities documentation for 4th quarter 2017, and 1st and 2nd quarters 2018
Siren test data for 4th quarter 2017, and 1st and 2nd quarters 2018
Drill & exercise participation records of ERO personnel for 4th quarter 2017, and 1st and 2nd
quarters 2018
Corrective Action Program Documents
CR-18-02305, EP to evaluate the process for selecting DEP opportunities
71152 - Problem Identification and Resolution
NAMCO Cavitation Analysis
Engineering Information Request 80756: Provide operational criteria for S-321- 001 (Pipe
Support Erection Standards) that provides an angular tolerance of +/- 3 degrees for liner
supports
71124.01 - Radiological Hazard Assessment and Exposure Controls
Procedures, Guidance Documents and Manuals
CMP-400.001, Excavation Backfill and Earthwork, Rev. 10
VCS-HPP-0160.002, Access Control of High Radiation, Locked High Radiation, and Very High
Radiation Areas, Rev. 1
VCS-HPP-0302, Radiation and Contamination Survey Techniques, Rev. 2
VCS-HPP-0303, Airborne Activity Sampling Techniques, Rev. 1
VCS-HPP-0158, Radioactive Material Control, Rev. 0
Records and Data
Air Sample Results, A S/G Platform, 10/21/18
Gamma Spec Analysis 21_2018-03-22_005, SB Pit Dirt
Gamma Spec Analysis 24_2018-03-06_001, Soil Sample #1 SE Corner
Gamma Spec Analysis 25_2018-03-06_001, Soil Sample #2 NE Corner
Gamma Spec Analysis 24_2018-10-24_004, Rock Sample From Under EQ Hatch
HPSS Administrative Instruction No.17-002, Fuel Cycle 24 Alpha Characterization, 08/10/17
Lapel Air Sample Results, Reactor Building Sump, Serial No. 25739, 10/12/18
National Source Tracking System Annual Inventory Reconciliation, 01/25/18
Radiological Survey VCS1-M-20181006-28, Auxiliary Building 463-02, 10/6/18
Radiological Survey VCS1-M-20180830-2, Auxiliary Building 463-02, 08/30/18
Radiological Survey VCS1-M-20180927-2, ISFSI, 09/27/18
Radiological Survey VCS1-M-20180730-3, ISFSI, 07/30/18
Radiological Survey VCS1-M-20181023-42, S/G Primary Platform and Bullpens, 10/23/18
Radiological Survey VCS1-M-20181022-5, RCDT-A Tagout, 10/21/18
RWP 18-04900, RF-24 S/G Eddy Current Activities, Rev. 1
RWP 18-04081, Aggressive Work in Posted Alpha Level 2 Areas - All Alpha Level 3 Work
Activities, Rev. 1
Source Inventory Sheet, Unit 1, 05/31/18
VC Summer Nuclear Station Work Order (W/O) 1802399-055
CAP Documents
CR-18-04734
CR-18-05037
Procedures, Guidance Documents, and Manuals
SAP-0121, ALARA Committee, Revision 10, Change B
Records and Data
ALARA Committee Minutes, RVHR ALARA Plan Review
ALARA Plan, RF-24 Primary Steam Generator Work, RWP: 18-04900
ALARA Plan, RF-24 Secondary Steam Generator Work, RWP: 18-04902
ALARA Plan, RF-24 Primary Manways/Diaphragms/Weld Exam, RWP 18-4901
ALARA Post Job Review, RWP 17-04950, Reactor Vessel Head Replacement, 04/03/17
VCS ALARA Group Excellence Plan
- V.C. Summer, RF-23 Post Outage Critique, ORVCH Disposal, June 28, 2017
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Procedures, Guidance Documents, and Manuals
SAP-0999, Corrective Action Program, Rev. 18, Change A
VCS-HPP-0154, Issuance and Control of Respiratory Protection Equipment, Rev. 0, Change A
VCS-HPP-0303, Airborne Activity Sampling Techniques, Rev. 1
VCS-HPP-0403, Radiological Controls for Nuclear Work Activities, Rev. 0
VCS-HPP-0416, Use and Control of HEPA Filtration Units, Vacuum Equipment, Fans, and
Portable A/C Units, Rev. 0
VCS-HPP-0163, Qualification Process for the Use of Respiratory Protection Equipment, Rev. 0,
Change C
VCS-HPP-0602, Fit Testing, Rev. 0, Change B
VCS-HPP-0633, Inspection, Maintenance, and Storage of Respiratory Protective Devices,
Rev. 0
VCS-HPP-0924, Operation and Maintenance of High Pressure SCBA Compressor, Rev. 0
Records and Data
EPT-11, C-Q-EP-SCBA, SCBA Qualification Records for selected personnel in Health Physics,
Instrumentation and Controls, and Mechanical Maintenance for 2018
HEPA Filter Integrity Test Results, HEPA Unit 17, 5/15/18
HEPA Filter Integrity Test Results, HEPA Unit 43, 10/10/18
Hydrostatic Retest Data Sheets and Visual Inspection Data Sheets for Bottles OP333747,
OP333748, and OP342361
Scott Air Supplied Products, Specialist Level Course certificates for personnel, 11/02/17
Scott Air Supplied Products Technician, Maintenance and Overhaul certificates for personnel,
01/12/18
SCOTT PosiChek3, Visual / Functional Test Results, for the following SCBA Nos.: 6, 01/22/16;
33, 07/27/15 and 06/21/17; and 64, 04/28/15 and 06/26/17
TRI Air Testing, Laboratory Reports, Compressed Air/Gas Quality Testing, Grade D Air, Bauer
Compressor # 30542, 07/27/17 and 08/02/18
VCS-HPP-0633, Attachment VI, Rev. 0, SCBA Inspection Log, 3rd Quarter 2018
VCS-HPP-0633, Attachment VII, Rev. 0, Monthly Breathing Air Cylinder Inspection Logs, June -
October 2018
CAP Documents
CR-17-03981
CR-18-01276
CR-18-01974
71124.04 - Occupational Dose Assessment
Procedures, Guidance Documents, and Manuals
TWR 2.1.3-17-017, Calibration Bias for Electronic Dosimetry (SRDs), 12/07/17
VCS-HPP-0157, Personnel Monitoring, Decontamination, and Skin Dose Determination, Rev. 1
VCS-HPP-0411, Monitoring Exposure with Multibadging, Rev. 0
VCS-HPP-0505, Issuance and Termination of Personnel Dosimetry, Rev. 0, Change B
VCS-HPP-0509, Leak Test and Calibration of Self-Reading Dosimetry, Rev. 0
VCS-HPP-0515, Interpretation of Bioassay Analysis, Rev 0, Change B
VCS-HPP-0517, Multiple Whole Body and Extremity Badging Exposure Calculations, Rev. 0
VCS-HPP-0518, Exposure Documentation Control, Rev. 0, Change B
VCS-HPP-0523, Quality Control and Whole Body Counting with the Chair Whole Body Counter,
Rev. 0
VCS-HPP-0717, Sample Collection, Preparation, and Analysis Techniques for Assuring
Compliance with 10 CFR 61
Records and Data
CFR 61 Analysis of 2017 DAW, December 17, 2017
2017 PCOs and PCEs report (undated)
2018 PCEs report (undated)
Dosimetry Self-Assessment, dated 10/23/2017
NVLAP, Certificate of Accreditation to ISO/IEC 17025:2005, Valid from January 7, 2018 to June
30, 2019
CAP Documents
CR-17-02677 CR-18-00244 CR-18-04305
CR-17-02994 CR-18-00484 CR-18-04306
CR-17-03725 CR-18-01957 CR-18-05090
CR-17-04838 CR-18-03344
CR-17-05410 CR-18-04227
71124.05 - Radiation Monitoring Instrumentation
Procedures, Guidance Documents, and Manuals
VCS-HPP-0522, Set-Up, Calibration, Quality Control and Operation of Gamma Spectroscopy
Systems with ORTEC Software, Rev. 0, Change C
VCS-HPP-0801, Counting Statistics and QC Testing for Health Physics Counting Systems,
Rev. 0, Change A
Data and Records
ARGOS Personnel Contamination Monitor #1803-094, 05/25/18Calibration Review and Approval:
Gamma Det #25, 1LML0 07/09/18, #23 1LML 09/18/16, and
- 23 CHAR-01 08/13/18
HPP-0818 Attachment III HIDEX 02/18 - 03/18, 04/18 - 06/18
Quality Control: BC-4 #1029, 01/01 - 03/31/18, and 04/01 - 06/30/18
Thermo Fisher Scientific Calibration Certificates: Telepole II #428016-053 02/16/17; and
Telepole II #428016-015, 02/16/17
VCS-HPP-0522, Set-Up, Calibration, and Generation of Quality Control Bands for the Chair
Whole Body Counter ENCLOSURE A: Upper Energy Calibration 08/25/17 and 09/19/17,
and Stand-up Calibration Count 09/19/17
VCS-HPP-0611 Calibration Certificate: Ludlum 9-3 #333134, 09/13/18; Ludlum L-177 #266938
07/10/17, 07/02/18; and Thermo Fisher RO-20AA 02/08/17, 02/08/18
VCS-HPP-0648, Operation and Calibration of the Eberline PM-7: #585 11/09/17; #264 08/9/16,
07/17/17, and 11/30/17
VCS-HPP-0648, PM7 Calibration Data Sheet: #264, 08/09/16 and 08/09/17
VCS-HPP-0649, Calibration and Operation of the SAM Tool; #334 08/10/18,
VCS-HPP-0649, Small Articles Monitor Calibration Report: #334, 03/03/17, 08/08/17, and
08/08/18
VCS-HPP-0653, Calibration Certificates: Hand and Foot Monitor #490, 11/03/18 and 11/02/16
VCS-SAP-0501, Defective Instrument Report, ASP-1 #2194, 02/13/18; and ASP2E #1376,
06/15/18
CAP Documents
17-03725 18-02770 18-00377
17-04099 18-03590
18-02292 18-03068
71151 - Performance Indicator Verification
Procedures, Guidance Documents, and Manuals
SPIG-01, Station Performance Indicator Guidelines, Rev. 1
VCS-HPP-0242, Reporting NRC Performance Indicators, Rev. 0
Records and Data Reviewed
Annual Radioactive Effluent Release Report, Virgil
- C. Summer Nuclear Station, Unit 1, January 1 -
December 31, 2017
ED Dose and Dose Rate Alarm Summary Report (CY2017)
ED Dose and Dose Rate Alarm Summary Report (YTD2018)
ED DOSE RATE ALARM EVALUATION LOG (VCS_HPP-04 Enclosure B), March 2017 - October
2018
Gaseous and liquid effluent release report summaries for January 2018 - September 2018
Performance Indicator Data Radiation Safety, July 2017 - July 2018
71152 - Problem Identification and Resolution Trend Review
CR-17-00198, Operator identified a pinhole leak in the flange downstream of XVB03121A-
CR-18-02364, Operator identified a pinhole leak in field weld below XVB03123B-SW (B
train CCW Hx)
CR-18-02706, Operator identified a pinhole leak in pipe tee downstream of XVB03123B-SW
CR-18-02797, NRC identified a pinhole leak in the pipe tee downstream of XVB03123A-SW
(A train CCW Hx)
CR-18-02857, An additional pinhole leak was identified in the pipe tee downstream of
XVB03123A-SW
CR-18-03296, Operator identified a pinhole leak in the flange downstream of XVB03121B-
CR-18-03561, Operator identified 3 additional pinhole leaks (Total of 4) near XVB03121B-
CR-18-03577, Operator identified 1 additional pinhole leak (Total of 5) near XVB03121B-SW
CR-18-03579, Operator identified 1 additional pinhole leak (Total of 6) near XVB03121B-SW
CR-18-03735, Operator identified 1 additional leak (Total of 7) near XVB03121B-SW
CR-18-03736, Operator identified 1 additional leak (Total of 8) near XVB03121B-SW
CR-18-03887, Flange downstream of XVB03121A-SW is not expected to survive another
operating cycle without pinhole leaks and requires replacement
CR-18-04083, Multiple SW pinhole leaks downstream of throttle butterfly valves created
operable but degraded conditions; corrective actions and bridging strategies required.
CR-18-04354, Additional pinhole leak identified on pipe tee below XVB03123A-SW
23