UNITED STATES NUCLEAR REGULATORY COMMISSION … › docs › ML0920 › ML092080009.pdfSAM NUNN ATLANTA FEDERAL CENTER 61 FORSYTH STREET, SW, SUITE 23T85 ATLANTA, GEORGIA 30303-8931

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)

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

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

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

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

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

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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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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• ‘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


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.


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.


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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


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


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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


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


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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


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


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.


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


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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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.


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

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)

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

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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