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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II SAM NUNN ATLANTA FEDERAL CENTER 61 FORSYTH STREET, SW,
SUITE 23T85
ATLANTA, GEORGIA 30303-8931
July 24, 2009 Mr. Jeffrey B. Archie Vice President South
Carolina Electric & Gas Company Virgil C. Summer Nuclear
Station P.O. Box 88 Jenkinsville, SC 29065 SUBJECT: VIRGIL C.
SUMMER NUCLEAR STATION - NRC INTEGRATED INSPECTION
REPORT 05000395/2009003 Dear Mr. Archie: On June 30, 2009, the
U.S. Nuclear Regulatory Commission (NRC) completed an inspection at
your Virgil C. Summer Nuclear Station. The enclosed integrated
inspection report documents the inspection results, which were
discussed on July 14, 2009, 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. Based on the
results of this inspection, no findings of significance were
identified. In accordance with 10 CFR 2.390 of the NRC’s “Rules of
Practice,” a copy of this letter, its enclosure, and your response
(if any) will be available electronically for public inspection in
the NRC Public Document Room or from the Publicly Available Records
(PARS) component of NRC’s document system (ADAMS). ADAMS is
accessible from the NRC Web site 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: Inspection
Report 05000395/2009003 w/Attachment: Supplemental Information cc
w/encl: (See page 2)
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July 24, 2009 Mr. Jeffrey B. Archie Vice President South
Carolina Electric & Gas Company Virgil C. Summer Nuclear
Station P.O. Box 88 Jenkinsville, SC 29065 SUBJECT: VIRGIL C.
SUMMER NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT
05000395/2009003 Dear Mr. Archie: On June 30, 2009, the U.S.
Nuclear Regulatory Commission (NRC) completed an inspection at your
Virgil C. Summer Nuclear Station. The enclosed integrated
inspection report documents the inspection results, which were
discussed on July 14, 2009, 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. Based on the
results of this inspection, no findings of significance were
identified. In accordance with 10 CFR 2.390 of the NRC’s “Rules of
Practice,” a copy of this letter, its enclosure, and your response
(if any) will be available electronically for public inspection in
the NRC Public Document Room or from the Publicly Available Records
(PARS) component of NRC’s document system (ADAMS). ADAMS is
accessible from the NRC Web site 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: Inspection
Report 05000395/2009003 w/Attachment: Supplemental Information cc
w/encl: (See next page)
X PUBLICLY AVAILABLE G NON-PUBLICLY AVAILABLE G SENSITIVE X
NON-SENSITIVE
ADAMS: G Yes ACCESSION NUMBER:__ML092050285 _ X SUNSI REVIEW
COMPLETE GJM
OFFICE RII:DRP RII:DRP RII:DRP RII:DRP RII:DRP SIGNATURE JXZ
/RA/ JTP /RA/ DCA /RA/ JSD /RA/ GJM /RA/
NAME JZeiler JPolickoski DArnett JDodson GMcCoy DATE 07/22/2009
07/22/2009 07/22/2009 07/14/2009 07/24/2009 E-MAIL COPY? YES NO YES
NO YES NO YES NO YES NO YES NO YES NO
OFFICIAL RECORD COPY DOCUMENT NAME:
G:\DRPII\RPB5\SUMMER\REPORTS\2009\SUM 09-03\SUMMERIR09-03.DOC
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SCE&G 2
cc w/encl: R. J. White Nuclear Coordinator S.C. Public Service
Authority Mail Code 802 Electronic Mail Distribution Kathryn M.
Sutton, Esq. Morgan, Lewis & Bockius LLP Electronic Mail
Distribution Susan E. Jenkins Director, Division of Waste
Management Bureau of Land and Waste Management S.C. Department of
Health and Environmental Control Electronic Mail Distribution R.
Mike Gandy Division of Radioactive Waste Mgmt. S.C. Department of
Health and Environmental Control Electronic Mail Distribution Bruce
L. Thompson Manager Nuclear Licensing (Mail Code 830) South
Carolina Electric & Gas Company Electronic Mail Distribution
Robert M. Fowlkes General Manager Engineering Services South
Carolina Electric & Gas Company Electronic Mail Distribution
Thomas D. Gatlin General Manager Nuclear Plant Operations (Mail
Code 303) South Carolina Electric & Gas Company Electronic Mail
Distribution David A. Lavigne General Manager Organization
Development South Carolina Electric & Gas Company Electronic
Mail Distribution
Senior Resident Inspector South Carolina Electric and Gas
Company Virgil C. Summer Nuclear Station U.S. NRC 576 Stairway Road
Jenkinsville, SC 29065
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SCE&G 3
Letter to Jeffrey B. Archie from Gerald J. McCoy, dated July 24,
2009 SUBJECT: VIRGIL C. SUMMER NUCLEAR STATION - NRC INTEGRATED
INSPECTION
REPORT 05000395/2009003 Distribution w/encl: C. Evans, RII L.
Slack, RII OE Mail RIDSNRRDIRS PUBLIC RidsNrrPMSummer Resource
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Enclosure
U. S. NUCLEAR REGULATORY COMMISSION
REGION II Docket No.: 50-395 License No.: NPF-12 Report No.:
05000395/2009003 Licensee: South Carolina Electric & Gas
(SCE&G) Company Facility: Virgil C. Summer Nuclear Station
Location: P.O. Box 88
Jenkinsville, SC 29065 Dates: April 1, 2009 through June 30,
2009 Inspectors: J. Zeiler, Senior Resident Inspector
J. Polickoski, Resident Inspector D. Arnett, Project Engineer
(Section 1R06)
Approved by: Gerald J. McCoy, Chief
Reactor Projects Branch 5 Division of Reactor Projects
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Enclosure
SUMMARY OF FINDINGS IR 05000395/2009-003; 04/01/2009 -
06/30/2009; Virgil C. Summer Nuclear Station; Routine Integrated
Inspection Report.
The report covered a 3-month period of inspection by resident
inspectors and a project engineer. No findings of significance were
identified by the NRC. The significance of most findings is
indicated by their color (Green, White, Yellow, Red) using
Inspection Manual Chapter 0609, “Significance Determination
Process” (SDP). The NRC’s program for overseeing the safe operation
of commercial nuclear power reactors is described in NUREG-1649,
“Reactor Oversight Process,” Revision 4, dated December 2006.
A. NRC-Identified and Self-Revealing Findings No findings of
significance were identified B. Licensee-Identified Violations
None
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Enclosure
REPORT DETAILS Summary of Plant Status The unit began the
inspection period at full Rated Thermal Power (RTP). The unit
operated at or near RTP for the entire inspection period. 1.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier
Integrity
1R01 Adverse Weather Protection
Seasonal Weather Susceptibilities a. Inspection Scope The
inspectors performed one adverse weather inspection for readiness
of hot weather.
The inspectors verified the licensee had implemented applicable
sections of operations administrative procedure (OAP)-109.1,
Revision 2D, “Guidelines for Severe Weather.” The inspectors walked
down three risk-significant equipment areas, including the service
water pumphouse (SWPH), emergency diesel generator (EDG) rooms, and
the 1DA/1DB emergency switchgear rooms. The inspectors verified the
proper operation of cooling systems for the associated equipment in
these areas. Also, the inspectors reviewed licensee plant computer
data associated with area and equipment temperatures to verify the
values were within expected operational ranges to prevent any
challenge to equipment operation. The inspectors reviewed the
licensee’s corrective action program (CAP) database to verify that
high temperature weather related problems were being identified at
the appropriate level, entered into the CAP, and appropriately
resolved.
b. Findings No findings of significance were identified.
1R04 Equipment Alignment .1 Partial System Walkdowns a.
Inspection Scope
The inspectors conducted three partial equipment alignment
walkdowns 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 (SOPs), final safety analysis report (FSAR),
and technical specifications (TS). The inspections included review
of outstanding maintenance work orders (WOs) and related
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Enclosure
condition reports (CRs) to verify that the licensee had properly
identified and resolved equipment alignment problems that could
lead to the initiation of an event or impact mitigating system
availability. Documents reviewed are listed in the Attachment. •
‘A’ EDG while ‘B’ EDG was OOS for emergent repair of local alarm
annunciator
panel • ‘B’ and ‘C’ emergency feedwater (EFW) trains while ‘A’
motor driven emergency
feedwater (MDEFW) was OOS for scheduled preventive maintenance •
‘B’ service water (SW) train while ‘A’ SW train was OOS for
scheduled preventive
maintenance
b. Findings
No findings of significance were identified.
.2 Complete System Walkdown a. Inspection Scope
The inspectors performed a detailed review and walkdown of the
EFW system and related piping to identify any discrepancies between
the current operating system equipment lineup and the designed
lineup. This walkdown included accessible areas outside the reactor
building and the equipment alignment configuration as indicated
from valves, pumps, and status lights from the control room. In
addition, the inspectors reviewed completed surveillance
procedures, outstanding WOs, system health reports, and related CRs
to verify that the licensee had properly identified and resolved
equipment problems that could affect the availability and
operability of the system. This inspection sample was completed
using the guidance listed in Operating Experience Smart Sample
FY2009-02, “Negative Trend and Recurring Events Involving Feedwater
Systems.” Documents reviewed are listed in the Attachment to this
report.
b. Findings No findings of significance were identified 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):
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Enclosure
• ‘A,’ ‘B,’ and ‘C’ charging pump rooms (fire zones AB-1.5,
-1.6, and -1.7) • ‘A’ and ‘B’ EDG rooms (fire zones DG-1.1, -1.2,
-2.1, and -2.2) • SWPH (fire zones SWPH-1, -3, -4, -5.1 and -5.2) •
Intermediate building (IB) 412 foot elevation (fire zones
IB-25.1.1, -25.1.2, -25.1.3,
and -25.1.5) • Turbine driven emergency feedwater (TDEFW) pump
room (fire zone IB-25.2)
b. Findings
No findings of significance were identified.
1R06 Flood Protection Measures a. Inspection Scope
The inspectors reviewed and walked down one area (the control
building / auxiliary building 412 foot elevation) regarding
internal flood protection features and equipment to determine
consistency with design requirements, FSAR, and flood analysis
documents. Risk significant structures, systems, and components
(SSCs) in these areas included safety related electrical motor
control centers, the residual heat removal (RHR) heat exchanger
rooms, and spent fuel pool cooling pumps/controls. The inspectors
reviewed the licensee’s CAP database to verify that internal flood
protection problems were being identified at the appropriate level,
entered into the CAP, and appropriately resolved.
b. Findings No findings of significance were identified.
1R07 Heat Sink Performance a. Inspection Scope
The inspectors conducted one heat sink performance sample. The
inspectors observed periodic performance testing for the ‘A’
component cooling water (CCW) heat exchanger that was conducted in
accordance with preventive test procedure, PTP-213.002, Revision 4,
“Service Water System Heat Exchanger Data Collection.” The
inspectors reviewed the ‘A’ CCW heat exchanger test results, CCW
heat exchanger historical trends, and discussed the heat exchanger
monitoring and maintenance program with test and engineering
personnel.
b. Findings No findings of significance were identified.
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Enclosure
1R11 Licensed Operator Requalification Program a. Inspection
Scope On June 8, 2009, the inspectors observed the performance of
senior reactor operator
and reactor operators on the plant simulator during licensed
operator requalification training. The scenario (LOR-ST-091)
involved a turbine first stage pressure instrument failure followed
by a 400 gallon per minute steam generator tube failure. The
inspectors assessed overall crew performance, communications,
oversight of supervision, and the evaluators' critique. The
inspectors verified that any significant training issues were
appropriately captured in the licensee’s CAP.
b. Findings
No findings of significance 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
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 4, “Maintenance Rule
Implementation,” and the Virgil C. Summer “Important To Maintenance
Rule System Function and Performance Criteria Analysis,” to verify
consistency with the MR requirements. • CR-08-03871, control room
outside air intake isolation valve XVB00003B-AH
exceeded its maximum allowed stroke test time • CR-08-04600, ‘A’
safety-related heating, ventilation, and air-conditioning
(HVAC)
chiller failed to provide adequate cooling due to pre-rotation
vanes not moving from the zero position
b. Findings
No findings of significance were identified.
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Enclosure
1R13 Maintenance Risk Assessments and Emergent Work Control a.
Inspection Scope
The inspectors evaluated, as appropriate, for the five selected
work activities listed below: (1) the effectiveness of the risk
assessments performed before maintenance activities were conducted;
(2) the management of risk; (3) that, upon identification of an
unforeseen situation, necessary steps were taken to plan and
control the resulting emergent work activities; and, (4) that
emergent work problems were adequately identified and resolved. The
inspectors evaluated the licensee’s work prioritization and risk
characterization to determine, as appropriate, whether necessary
steps were properly planned, controlled, and executed for the
planned and emergent work activities. • Work Week 2009-14: risk
assessment for scheduled maintenance and testing on
switchyard breaker OCB8852 and related relays (yellow risk),
divers’ inspection of the SWPH intake canal, replacement of five
disconnects for the backup Group 2 pressurizer heaters, and motor
rewind of ‘C’ circulating water pump
• Work Week 2009-16: risk assessment for scheduled maintenance
and testing on switchyard breaker XCB8832 and related relays
(yellow risk), ‘C’ HVAC chiller, ‘A’ isophase bus cooling, reactor
building (RB) entry to repair ‘E’ incore drive, ‘C’ circulating
water pump re-installation, and emergent ‘B’ EDG local annunciator
alarm panel repair
• Work Week 2009-19: risk assessment for scheduled maintenance
and testing on switchyard breaker OCB8792 and related relays
(yellow risk), ‘A’ HVAC chiller, ‘A’ CCW pump, ‘A’ instrument air
compressor, emergent maintenance including a RB entry for increased
RB sump in-leakage, and troubleshooting and maintenance with the
electro-hydraulic control backup speed amplifier
• Work Week 2009-20: risk assessment for scheduled maintenance
and testing on switchyard breaker OCB8772 and related relays
(yellow risk), ‘A’ MDEFW pump, control room ventilation filter
replacement, ‘A’ SW pump, ‘A’ SW booster pump, and unit down power
to conduct main turbine valve testing
• Work Week 2009-23: risk assessment for scheduled maintenance
and testing on the ‘A’ EDG and engine support systems (yellow
risk), ‘A’ RHR pump (yellow risk), ‘C’ HVAC chiller and chill water
pump, and ‘A’ train solid state protection system testing
b. Findings No findings of significance were identified. 1R15
Operability Evaluations a. Inspection Scope The inspectors reviewed
four operability evaluations 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
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Enclosure
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 station administrative procedure (SAP)-209,
Revision 0E, “Operability Determination Process,” and SAP-999,
Revision 4C, “Corrective Action Program.”
• CR-09-00942, degrading trend identified in the performance
test data for the diesel
driven fire pump • CR-09-01523, anomalous indications observed
during testing of ‘B’ EDG local
annunciator alarm panel • CR-09-01658, electro-hydraulic control
electrical malfunction alarm at main control
board alarming and resetting along with the relay panel backup
speed amplifier out of saturation alarm
• CR-09-01724, intermediate building door and steam propagation
barrier to the EDG building (DRIB/301) degraded with slight door
frame movement
b. Findings
No findings of significance were identified.
1R18 Plant Modifications a. Inspection Scope
For the two equipment changes listed below that were considered
temporary modifications, the inspectors evaluated the changes for
adverse effects on system availability, reliability, and functional
capability. Documents reviewed, as applicable, included associated
10 CFR 50.59 reviews, engineering calculations, WOs and
implementation packages, plant electrical and construction
drawings, corrective action documents, applicable sections of the
FSAR, supporting analyses, TS, and design basis information.
• Bypass Authorization Request (BAR) 08-01: temporarily jumper
Parr Hydro Alternate
Alternating-Current (AAC) transformer reverse power relay until
permanent change is implemented in the Fall 2009 refueling outage
(CR-08-02477)
• Interim actions to maintain operability of the intermediate
building to diesel building door and steam propagation barrier as
delineated in CR-09-01724 and the accompanying operability
recommendation per ES-120, Revision 0D, “Operability Recommendation
and JCO Development”
b. Findings
No findings of significance were identified.
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Enclosure
1R19 Post Maintenance Testing a. Inspection Scope
For the six 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 4G,
“Post Maintenance Testing Guideline.”
• WOs 0903305 and 0905655, PMT for main control board switch
wiring repair for the
‘B’ steam generator power-operated relief valve IPV02010-MS • WO
0905418, PMT for repairing ‘B’ EDG local annunciator alarm panel
anomaly • WOs 0900413 and 0817534, PMT for scheduled preventive
maintenance for ‘A’
MDEFW pump • WO 0900396, PMT for scheduled preventive
maintenance for filter replacement in
control room ventilation system • WOs 0807588 and 0900540, PMT
for scheduled preventive maintenance for ‘A’ SW
pump • WOs 0902244, 0902247, 0901534, 0907363, PMT for planned
and emergent
maintenance to overhaul the filter regulators for ‘A’ RHR heat
exchanger bypass flow control valve FCV00605A and RHR heat
exchanger outlet flow control valve HCV00603A, driver card
replacement for FCV00605A, and loop calibration for ‘A’ RHR flow
transmitter FT00605A
b. Findings
No findings of significance were identified.
1R22 Surveillance Testing a. Inspection Scope
The inspectors observed and/or reviewed the six surveillance
test procedures (STPs) listed below to verify that TS 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.
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Enclosure
In-Service Tests: • STP-220.002, Revision 7, “Turbine Driven
Emergency Feedwater Pump and Valve
Test” Other Surveillance Tests: • ES-400, Revision 3, “Service
Water Pond Structure and Dam Inspections” • STP-115.001, Revision
15, “Penetration Isolation Verification” • STP-205.004, Revision 7,
“RHR Pump and Valve Operability Test” • STP-120.004, Revision 16,
“Emergency Feedwater Valve Operability Test” • STP-112.003,
Revision 9, “Reactor Building Spray System Valve Operability
Test”
b. Findings
No findings of significance were identified.
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation a. Inspection Scope
On May 14, 2009, the inspectors reviewed and observed the
performance of a simulator drill that involved a loss of offsite
power initiating event, followed by loss of both trains of
safeguards power (EPD-09-02A) which required a General Emergency to
be declared. The inspectors assessed the emergency procedure usage,
emergency plan classifications, notifications, and protective
action recommendation development. The inspectors evaluated the
adequacy of the licensee’s conduct of the drill and critique
performance. The inspectors verified that the drill critique
identified drill performance weaknesses and entered these items
into the licensee’s CAP.
b. Findings No findings of significance were identified.
4. OTHER ACTIVITIES 4OA1 Performance Indicator (PI) Verification
a. Inspection Scope
Cornerstone: Reactor Safety Barrier Integrity
The inspectors verified the accuracy of the licensee’s PI
submittals listed below for the period April 2008 through March
2009. The inspectors used the performance indicator definitions and
guidance contained in Nuclear Energy Institute (NEI) 99-02,
Revision 5, “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),
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Enclosure
operator logs, plant status reports, CRs, and performance
indicator data sheets to verify that the licensee had properly
reported the PI data. Also, the inspectors discussed the PI data
with the licensee personnel associated with the performance
indicator data collection and evaluation. • Reactor Coolant System
(RCS) Specific Activity • RCS Identified Leak Rate
b. Findings
No findings of significance were identified.
4OA2 Identification and Resolution of Problems .1 Review of
Items Entered into the Corrective Action Program
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 corrective action program. 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.
.2 Semi-Annual Review to Identify Trends a. Inspection Scope
The inspectors performed a review of the licensee’s corrective
action program and associated documents to identify trends that
could indicate the existence of a more significant safety issue.
The review was focused on repetitive equipment issues, but also
considered trends in human performance errors, the results of daily
inspector corrective action item screening discussed in Section
4OA2.1 above, licensee trending efforts, and licensee human
performance results. The review nominally considered the six-month
period of January 2009 through June 2009. Documents reviewed
included licensee monthly and quarterly corrective action trend
reports, engineering system health reports, maintenance rule
documents, department self-assessment activities, and quality
assurance audit reports.
b. Assessment and Observations
The inspectors identified two adverse trends listed below. •
Maintenance Rule Implementation Adverse Trend: This trend involved
two
examples where the licensee failed to properly evaluate whether
the performance or condition of an SSC was being effectively
controlled through the performance of appropriate preventive
maintenance. The first example involved ‘B’ train control room
ventilation not being accounted for in a system common mode
failure, unavailability hours not counted against the affected
trains, and maintenance rule
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Enclosure
goal setting not established. This issue was previously
documented in NRC Integrated Inspection Report 05000395/2009002 and
identified as NCV 05000395/2009002-01, Failure to Effectively
Monitor the Performance of the Control Room Normal and Emergency
Air Handling System per the Maintenance Rule. The second example
involved a MPFF of ‘A’ HVAC chiller that was not evaluated by the
maintenance rule expert panel for the opportunity for goal setting
despite exceeding the maintenance rule performance criteria.
Further details of this problem are discussed in Section 4OA2.3 of
this report under the annual sample review for CR-08-04600.
• Lack of Thorough Corrective Action Evaluations Trend: This
trend involved
examples discussed in detail in section 4OA2.3 of this report
associated with CR-08-03871, CR-08-04600, and CR-09-00279, as well
as the maintenance rule evaluation weaknesses discussed in NCV
05000395/2009002-01.
.3 Annual Sample Review a. Inspection Scope
The inspectors reviewed the three issues listed below in detail
to evaluate the effectiveness of the licensee's corrective actions
for important safety issues. • CR-08-03871, Control room outside
air intake isolation valve XVB00003B-AH
exceeded its maximum allowed stroke time • CR-08-04600, ‘A’ HVAC
chiller failure to provide adequate cooling • CR-09-00279, NRC
identified spent fuel pool area radiation monitor (RM)-G8 Power
On availability light was not lit on January 21, 2009 The
inspectors assessed whether the issues were appropriately
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 corrective actions. Also, the inspectors
verified the issues were processed in accordance with SAP-999,
Revision 4C, "Corrective Action Program.”
b. Findings and Observations
The inspectors identified several weaknesses and areas for
improvement as listed below with the licensee’s evaluation and
documentation of the three problems reviewed. • CR-08-03871 Review
Items: The apparent cause evaluation was completed
October 17, 2008, by a Failure Modes Analysis team. The failure
was determined to be the displacement of the butterfly valve bottom
sleeve bearing and shaft seal which allowed process debris to
buildup in the void created by the displaced bearing. This buildup
of debris occurred over a long period of time as evidenced from the
nature of the debris and resulted in increased valve frictional
forces to the extent that caused the valve to hang up in
mid-position during its closed stroke test on September 6, 2008.
The reason for the sleeve bearing displacement was attributed
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Enclosure
to failure of an adhesive used by the vendor to secure the
bearing in place. However, the cause of the adhesive failure was
not determined by the licensee. Based on subsequent interviews with
personnel on the evaluation team, the inspectors learned that the
team had not conclusively determined (from material analysis)
whether there was actually adhesive present when the valve was
disassembled for repair. As such, the licensee would have been
unable to conclude whether the bearing movement was attributable to
a valve original manufacturing problem that either failed to apply
or incorrectly applied the adhesive. While the operability section
of the evaluation recognized that XVB00003B-AH was one of four
identical butterfly valves used in the Control Room outside air
intake isolation (two per system train), there was no urgency in
priority placed on determining whether the bearings were in a
similar displaced configuration in the other three valves from an
operability and common mode failure susceptibility perspective.
Based on the inspectors’ review of historical stroke time data for
the subject valves, the nature of the failure of XVB00003B-AH (to
hang up in mid-position) could not be predicted or anticipated,
i.e., the stroke times may not degrade prior to an actual failure.
While the CR created actions to completely refurbish the other
three valves, including replacement of the lower bearings, these
actions were not scheduled to be completed until August 2009 for
the two ‘A’ train valves and October 2009 for the remaining ‘B’
train valve. The CR evaluation did not consider interim measures
prior to the planned full valve refurbishments, such as visual
inspection of the bearing sleeve configuration via removal of the
bottom bearing cover or the conduct of manual torque checks to
identify abnormal valve friction.
• CR-08-04600 Review Items: The apparent cause evaluation was
completed on
February 27, 2009, detailing three conditions combining to
result in the degraded performance of the ‘A’ HVAC chiller. These
three conditions included evaporator pressure out of specification
indicative of low refrigerant charge; a leaking ¼-inch copper
intake line causing air intrusion into the chiller; and, a variable
current limiting resistor in the chiller control circuitry found
above its calibration value. After extensive questioning by the
inspectors into the details of the apparent cause evaluation and MR
assessment, the licensee performed an engineering re-evaluation
which involved greater technical expertise from the chiller vendor,
plant chiller technicians, and senior chiller engineers.
Subsequently, the licensee determined that air intrusion into the
chiller was the primary cause of the chiller’s inability to lower
chill water temperature versus an out of tolerance variable current
limiting resistor or low refrigerant charge. The inspectors
determined that available tools and technical expertise to support
the initial engineering evaluation were not fully utilized despite
the complexity of the ‘A’ HVAC chiller technical issues. Following
inspector identification that the MR performance criterion was
exceeded and a review to place ‘A’ HVAC chiller in MR goal setting
was not performed, the licensee placed the ‘A’ HVAC chiller in
maintenance rule goal setting and evaluated the cause of the
chronological timing of maintenance rule evaluations that resulted
in MPFF accounting confusion. The licensee initiated CR-09-02381 to
address these NRC identified issues. The inspectors determined this
issue was not a violation of the Maintenance Rule since the
failures that led to the performance criteria being exceeded
involved different root causes.
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14
Enclosure
• CR-09-00279 Review Items: The apparent cause evaluation was
completed March 2, 2009, and determined the reason that the Power
On availability light was not lit on the remote area monitor panel
for spent fuel pool area radiation monitor RM-G8 was due to a blown
alarm power isolation fuse. The consequences of this blown fuse was
that, during the period of at least, January 19 - 21, 2009, the
RM-G8 remote alarm horn and red light would not have functioned.
However, the RM-G8 alarm capability on the central radiation
monitoring panel in the Control Room was not affected. The specific
cause of the blown fuse was not determined, although a possible
cause was thought to be a momentary short when an operator replaced
what was thought to be a failed bulb in another area radiation
monitor RM-G12 remote Power On availability lamp socket on January
19, 2009. The RM-G8 remote alarm power shared the same power
circuit as area radiation monitor RM-G12, as well as RM-G3, RM-G4,
and RM-G11.
The inspectors determined that the licensee’s investigation into
this issue was not
thorough and complete. There was no follow-up at the time of the
investigation to confirm or deny the possible fuse failure
assumption, such as inspection of the RM-G12 lamp socket for signs
of a suspected momentary short or attempts to interview the
operator that replaced the RM-G12 bulb for any visual or audible
indications that a short had occurred. The licensee’s investigation
did not provide any details into why the extinguished RM-G8 Power
On lamp was not identified by either plant operators or engineering
and health physics personnel in the spent fuel pool that were
conducting fuel reconstitution activities between January 19 and
21, 2009. In addition, the past operability evaluation stated that
RM-G8 was “technically inoperable” based on it failing the TS
3.3.3.1 analog channel operational test surveillance requirement
due to not being capable of producing an audible and visual alarm
in the spent fuel pool area. Later in the same evaluation, a
statement was made that RM-G8 was “operable, but degraded” since
the Control Room alarm feature was not impacted. However, radiation
monitoring system licensing basis information was not provided to
support why the reviewer believed that the TS 3.3.3.1 operability
requirement for RM-G8 alarm functionality only included the Control
Room alarm capability and not the remote alarm capability in the
spent fuel pool area.
The inspectors determined that a potential performance
deficiency existed for the
licensee’s failure to identify the degraded remote alarm
condition of RM-G8 until being alerted to the condition by NRC
inspectors on January 21, 2009. The inspectors identified an
unresolved item (URI) to evaluate whether this issue was a
performance deficiency and/or involved a violation of TS 3.3.3.1,
“Radiation Monitoring Instrumentation,” for failure to complete the
required TS Action Statement (of performing area surveys of the
spent fuel pool area) when RM-G8 was considered inoperable. This
issue will remain unresolved pending NRC review and inspection of
the licensee’s re-evaluation of this issue. The licensee planned to
document the results of their re-evaluation in CR-09-00279. This
URI is identified as 05000395/2009003-01: Review Licensee
Re-Evaluation of Degraded Spent Fuel Pool Area Radiation Monitor
RM-G8.
-
15
Enclosure
4OA3 Event Followup (Closed) Licensee Event Report (LER)
05000395/2008004-01: Technical Specification
Violation Due to Alternate AC Unavailability The inspectors
reviewed the subject LER and applicable condition reports
(CR-08-02381
and CR-08-02477) associated with the issue to verify the LER
accuracy and appropriateness of the specified corrective actions.
The supplement to this LER provided additional details of the
licensee’s root cause evaluation and associated corrective actions.
The failure to conduct proper post modification testing for
installing the underground tie line from the Parr Hydro generating
station to Virgil C. Summer resulting in the non-compliance with
the limiting condition for operation (LCO) of TS 3.8.1.1.b.4 was
the subject of NRC identified Non-Cited Violation (NCV)
05000395/2008007-02. No new findings of significance were
identified. This LER is closed.
4OA5 Other Activities 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 of significance were identified.
4OA6 Meetings, Including Exit Exit Meeting Summary
The inspectors presented the integrated inspection results to
Mr. Jeffrey Archie and other members of the licensee staff on July
14, 2009. 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
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Attachment
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel J. Archie, Vice President, Nuclear Operations
L. Bennett, Manager, Plant Support Engineering L. Blue, Manager,
Nuclear Training M. Browne, Manager, Quality Systems A. Cribb,
Supervisor, Nuclear Licensing G. Douglass, Manager, Nuclear
Protection Services M. Fowlkes, General Manager, Engineering
Services D. Gatlin, General Manager, Nuclear Plant Operations R.
Justice, Manager, Maintenance Services D. Lavigne, General Manager,
Organizational / Development Effectiveness G. Lippard, Manager,
Operations M. Mosley, Manager, Chemistry Services P. Mothena,
Manager, Health Physics and Safety Services J. Nesbitt, Manager,
Materials and Procurement D. Shue, Manager, Planning / Outage W.
Stuart, Manager, Design Engineering B. Thompson, Manager, Nuclear
Licensing R. Williamson, Manager, Emergency Planning S. Zarandi,
General Manager, Nuclear Support Services
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened
05000395/2009003-01 URI Review Licensee Re-Evaluation of Degraded
Spent Fuel
Pool Area Radiation Monitor RM-G8 (Section 4OA2.3) Closed
05000395/2008004-01 LER Technical Specification Violation Due to
Alternate AC
Inoperability (Section 4OA3)
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Attachment
LIST OF DOCUMENTS REVIEWED Section 1R04.1: Partial Equipment
Alignment Procedures and Drawings SOP-306, Emergency Diesel
Generator, Revision 17G SOP-211, Emergency Feedwater System,
Revision 13A SOP-117, Service Water System, Revision 20L Section
1R04.2: Complete System Alignment Procedures and Drawings SOP-210,
Feedwater System, Revision 20H SOP-211, Emergency Feedwater System,
Revision 13A STP-120.003, Emergency Feedwater Valve Verification,
Revision 8H STP-120.004, Emergency Feedwater Valve Operability
Test, Revision 16E STP-220.001A, Motor Driven Emergency Feedwater
Pump and Valve Test, Revision 9 STP-220.002, Turbine Driven
Emergency Feedwater Pump and Valve Test, Revision 7K Corrective
Action Documents CRs 08-00540, 08-03332, 09-00335, 09-00413,
09-01989, 09-02026, 09-02065, and 09-02310 Other NUREG/CR-5838,
Auxiliary Feedwater System Risk-Based Inspection Guide for Virgil
C. Summer Nuclear Plant Condition Reports Initiated for NRC
Identified Issues CR-09-00942 (Actions 2, 3, and 4), Diesel fire
pump performance evaluation weaknesses CR-09-01478, Method used to
verify valve required position inconsistently documented
CR-09-01701, Packing leak on TDEFW steam drain trap level switch
valve LS02031-LR1-MS CR-09-01707, Temperature sensors for CCW heat
exchanger performance testing not installed in accordance with
preventive test procedure CR-09-01721, Fire penetration barrier
trace TR-108-IB-12-10E seal material found degraded CR-09-01724,
Operability evaluation for degraded pressure boundary door lacked
appropriate details CR-09-01904, Weaknesses in security force
training on radio functionality, testing, and B.5.b related
communications CR-09-01920, Wrong light bulbs installed in ‘B’ EDG
local annunciator panel CR-09-01989, Active governor oil leak
observed on TDEFW pump turbine CR-09-02271, Ladder found in ‘A’ RHR
heat exchanger room improperly controlled CR-09-02330, 412 foot
intermediate building east penetration room drains/sump covered
without engineering approval during room painting CR-09-02371,
Ladder left in ‘A’ RHR pump room improperly controlled CR-09-02381,
Discrepancies noted in Maintenance Rule evaluation of safeguards
chiller failures CR-09-02485, Personnel contamination events not
entered in corrective action database CR-09-02546, Security
officers do not have direct access to corrective action database
CR-09-02583, Weaknesses identified in health physics timely setting
of new alarm setpoints for radiation monitor RM-A2 (Iodine channel)
following media changeout
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Attachment
LIST OF ACRONYMS AB Auxiliary Building AAC Alternate
Alternating-Current ADAMS Agency Document Access and Management
System BAR Bypass Authorization Request CAP Corrective Action
Program CB Control Building CCW Component Cooling Water CFR Code of
Federal Regulations CR Condition Report DG Diesel Generator EDG
Emergency Diesel Generator EFW Emergency Feedwater EPD Emergency
Preparedness Drill ES Engineering Services Procedure FSAR Final
Safety Analysis Report FY Fiscal Year GTP General Test Procedure
HVAC Heating, Ventilation, and Air Conditioning IB Intermediate
Building INPO Institute of Nuclear Power Operations LCO Limiting
Condition for Operation LER Licensee Event Report MDEFW Motor
Driven Emergency Feedwater MPFF Maintenance Preventable Functional
Failure MR Maintenance Rule NEI Nuclear Energy Institute NCV
Non-Cited Violation NRC Nuclear Regulatory Commission NUREG NRC
Technical Report Designation OAP Operations Administrative
Procedure OOS Out of Service PARS Publicly Available Records PI
Performance Indicator PMT Post-Maintenance Testing PTP Preventive
Test Procedure RB Reactor Building RCS Reactor Coolant System RHR
Residual Heat Removal RM Radiation Monitor RTP Rated Thermal Power
SAP Station Administrative Procedure SCE&G South Carolina
Electric and Gas SDP Significance Determination Process SOP System
Operating Procedure SSC Structures, Systems, and Components STP
Surveillance Test Procedure SW Service Water SWPH Service Water
Pump House TDEFW Turbine Driven Emergency Feedwater TS Technical
Specification URI Unresolved Item WANO World Association of Nuclear
Operators WO Work Order
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