IR 05000395/1980034
| ML19345F769 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 12/16/1980 |
| From: | Kellogg P, Skolds J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19345F754 | List: |
| References | |
| 50-395-80-34, NUDOCS 8102190253 | |
| Download: ML19345F769 (9) | |
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O ATLAN TA, GEORGIA 30303
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Report Nos. 50-395/80-34 Licensee: South Carolina Electric and Gas Company Columbia, SC 29218 Facility: V. C. Summer Nuclear Station License No. CPPR-94 Inspection at V. C. Summer Nuclear Station near Parr, South Carolina Inspector:
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Date Sighed SUMMARY Inspection on October 6,1980 thru November 16, 1980 Areas Inspected This routine inspection by the Resident Inspector involved 120 inspector-hours onsite in the areas of Nonconformance Control, Preoperational Test Review, Independent Inspection Effort, Preservice/ Inservice Pump and Valve Program and Plant tour.
Resul ts Of the 5 areas inspected, no apparent items of noncompliance or deviations were identified in 4 areas; 2 apparent items of noncompliance were found in 1 area.
l (Infraction - Failure to follow procedure. - paragraph Sa; Infraction - Failure to establish corrective action measures - paragraph Se).
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Details 1.
Persons Contacted
- 0. S. Bradham, Station Manager
- J. G. Connelly, Assistant Station Manager
- L. Storz, Operations Supervisor
- S. Smith,flaintenance Supervisor
- B. G. Croley, Technical Support Supervisor
- C. Ligon, Administrative Supervisor
- A. Koon, Technical Services Coordinator
- P. Fant, QC Inspection Coordinator Other licensee employees contacted included construction craftsmen, technicians, operators, mechanics, security force members, and office personnel.
2.
Exit Interview The inspection scope and findings were summarized on 10/24/80 and 11/14/80 with those persons indicated in Paragraph 1 above. The Resident Inspector also attended the exit interview of E. Girard on 10/24/80 and J. Wray on 11/6/80.
3.
Licensee Action on Previous Inspection Findings Not inspected.
4.
Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve noncompliance or deviations. New unresolved items identified during this inspection are discussed in paragraph 5d.
5.
Nonconformance Control References (a)
10CFR 50, Appendix B, Criteria XV, XVI (b) ANSI N18.7 - 1976 (c)
Startup Manual Procedure SUM-B-13
"Startup Field Reports" (SFR)
(d) Administrative Procedure AP-209 "Non-conformance Control" (e) Operations QA Plan The inspector reviewed the following SFR's 1304 Service Water Pump C
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1305 CCW Valves 9523 8 and C
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1306 HVAC Control Baard
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1308 Low Voltage Power Circuit Breakers i
1309 Recycle System 1318 Chilled Water Welds FW6 and FW10 2401 Waste Processing System 2402 Service Water Pump Speed Switch 2403 Plant Technical Specifications 2404 Wiring Error in XPN 6001 2408 Access doors on XFN 23A and B 2411 Fan blades on XFN 23A and B 2421 SI Pump Operational Test 2423 Torque switches 2425 Auxiliary Building Intake Damper XDP - 116 - AH 2462 Teflon Tape 2464 RCDT Pressure Indicator 2465 Comparators FB3561B, 3571B and 3581B 2475 RHR Pump B Elementary Drawing change 2384 Safety Injection Piping
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957 Safety Injection Piping i
1118 Safety Injection locking devices 943 Valve 8063C
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3077 1600 psid across S/G i
3149 Premature lifting of valve 80108 (
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The inspector reviewed the nonconformance control system established for the Start Up Program and for Plant Operations.
The Start Up Program uses the Start Up Field Report to document nonconformances.
The Operations program uses the Nonconformance (NCN) program to document nonconformances. The programs were reviewed to verify the programs contain sufficient measures to provide reasonable assurance that nonconforming materials, equipment and components are properly identified, documented, repaired or reworked and that proper ccrrective action has been taken to preclude recurrence.
Findings were acceptable with the following exceptions:
The SFR system has five categories (Nonconformance, deficiency, SA, SB, a.
which are used to classify the situation identified during the Start Up Program that need correction or evaluation. The definitions in procedure SUM-B-13 are vague and created confusion among the test personnel.
For instance, the definition of a NONCONFORMANCE was "a nonconforming situation that required SCE&G Nuclear Engineering approval and QA concurrence for resolution." The Startup Manual gave 3 examples of nonconformances. A deficiency was defined as those
"nonconformances" which can be corrected by existing approved drawings or procedures. This would imply that every deficiency is a nonconformance.
Nonconformances and category SA SFR's received the same degree of review. SFR's classified as "SA" when they should have been nonconformances or vice versa was of no concern since the level of review was identical. However if an SFR was classified as "SB",
" deficiency or "other" and it should have been "SA" or
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"Nonconformance" it would not receive the proper review.
10 CFR50, Appendix B, Criterion V, implemented by FSAR Section 17.2.5 states that activities affecting quality shall 12 perscribed by documented instructions, procedures and drawings... and shall be accomplished in accordance with these procedures and drawings.
Startup Manual Procedure SUM-B-13, "Startup Field Reports" (SFR), Section 4.4.2 states that a category "SB" SFR shall be limited to changes in working intent drawings.
SFR 1309 was classified as "SB" yet this SFR requested and approved a design change for the Recycle System. This change involved more than working intent drawings.
SFR 1118 involved reconinending and approving locking devices for the throttle valves in the high head safety injection lines. This SFR was classified as SB yet had nothing to do with working intent drawings. SFR 2462 concerned the request to use Teflon tape on CHV/SI pump seal piping. The request was approved.
The SFR was classified as SB yet had nothing to do with working intent drawings.
SFR 3149 concerned the premature lighting of Pressurizer Safety Valve 8010B during Hot Functional Testing. This 5FR was classified as "other".
Startup Manual Procedure SUM-B-13, "SFR" Section 4.11 states that an SFR classified as "other" be limited to additional design information or clarification of a system engineering intent.
SFR 3149 involved no additional design information and did not clarify a system engineering intent yet was classified as "SB".
The above SFR was classified as SB yet had nothing to do wth working intent drawings.
SFR 3149 concerned the premature lighting of Pressurizer Safety Valve 8010B during Hot Functional Testing. This SFR was classified as "other".
Startup Manual Procedure SUM-B-13. "SFR" l
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section 4.11 states that an SFR classified as "other" be limited to additional design information or clasification of an system engineering intent.
SFR 3149 involves no additional design information and did not clarify a system engineering intent yet was classified as "SB".
The above examples are considered an item of noncompliance (80-34-02)(See paragraph 5b. for another example).
b.
The inspector reviewed the following Operations Nonconformance Notices (NCN):
- 20 XVT 1678 A, B, C
- 22 Diesel Generator A & B
- 23 MSIV
- 26 D/G injection tube gaskets
- 29 Valve 89888 135 1600 psid across S/G 143 Undersize plug
D/G air gap
No.122 Teflon wire The disposition of NCN #20 states that after valves XVT1678 A, B and C were reworked, they would be acceptable for reinstallation and use if the minor diameter was 2.512+.005 inches, if the anglo of the disc was 29 degrees + 1/2 degree and if the stellite thickness was greater than 1/16 inch.
A thintenance Work Request (MWR) was written to repair each valve. The
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valves were deemed acceptable and reinstalled with the minor diameter of valves XVT 1678 A and B equal to 2.565 inches and 2.570 inches respectively.
This failure to follow procedure is another example of the item of noncompliance described in Paragraph Sa.
Section 12.2.2 9 of the Operational QA Plan requires periodic analysis c.
of nonconformances to identify quality trends and recommend corrective action to preclude recurrence.
An on site QA surveillance discovered that this was not being done in the Start Up program. Subsequent to that, a program to detect trends was initiated.
However, the program -
failed to identify who was responsible for the program, how often the data is taken, who reviews the results, how the results are determined and who are the results sent to.
The Operational Nonconformance Notice program is supposed to have a system to detect trends also. However at this point, the data base is i
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not large enough to generate any meaningful results. The Inspection Coordinator indicates a procedure to perfom trending on NCN will be written.
The Startup program trending procedure is also being generated.
Until the trending procedures are approved, this will remain an open item (80-34-03).
d.
SFR 1308, Low Voltage Power Circuit Breakers, described a condition where 14 safety related ITE circuit breakers were discovered with grease on contnct surfaces. The Technical Manual for these breakers state that N0-0X-ID grease is not to be used on any main and arcing contact surfaces.
The inspector spoke with maintenance personnel who indicated that the grease on the contact surfaces was NO-0X-ID grease and that the grease was present - the circuit breakers upon installation of the circuit breakers.
(ie. they do not put the grease
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on the circuit breakers after installation).
Since this SFR was considered a deficiency, it did not recieve a review for reportability under 10CFR50.55(e) or 10CFR21.
Until this SFR is reviewed for reportability, this item will remain unresolved.(80-34-07).
e.
10CFR50 Appendix B, Criterion XVI states that measures be established to assure that conditions adverse to quality are promptly identified and corrected. Also, in the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is
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determined and corrective action taken to preclude recurrence.
The measures described in Appendix B are established in the Operational QA Plan and Section 17.2 of the FSAR. Section 17.2.16.2 of the FSAR states that corrective action controls are described in approved procedures and establish the method of identifying and controlling nonconforming conditions and other conditions adverse to quality.
Section 12.5.2 of the Operational QA Plan states inpart that in the case of SFR's, nonconfoming documents are evaluated by the Startup Supervisor to identify adverse quality conditions.
The Startup Supervision detemines the cause of the conditions and recomends appropriate corrective action.
Procedures do not exist, as required by Section 17.2.16.2 of the FSAR, which implement these measures.
Section 12.2.2.f of the Operational QA Plan states that the Startup Suoervisor, in the case of SFRs, reviews procedures to assure controls are delineated to describe criteria for determining disposition in one of the following categories:
(1) accepted as is (2) rework (3)
repairs or (4) reject.
The criteria for determining disposition in one of the above categories is in Nuclear Engineering procedures.
Procedures do not exist, as required by Section 17.2.16.2 of the FSAR requiring the Startup Supervisor to review Nuclear Engineering procedures. The failure to establish procedures to implement the measures established in the Operational QA Plan is considered on item of item of noncompliance.(80-34-01).
6.
Preoperational Test Review
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The inspector reviewed preoperational test procedure SF-6, Containment Isolation Preoperational Test. The procedure was reviewed to ensure it was technically adequate and to ensure it was consistent with the commitments made in Chapter 14 of the FSAR and with Regulatory Guide 1.68.
Findings were acceptable with the following exceptions:
SG-6 checks to ensure that valves 6050A, 6051A, 6052A, 6053A and 6051C a.
close on a Containment Isolation Phase A signal.
A recent design change eliminated these valves from Phase A closure signals.
b.
SG-6 does not verify that all valves, dampers, etc., remain in the safe position when the isolation signal is reset. This concern arose from the issues discussed in I&E Bullatin 80-06 Engineered Safety Feature (ESF) Reset Controls".
SG-6 verifies that a Phase B Containment Isolation occurs when switches c.
SGA1 and SGA2 are actuated together in the control room.
The test fails to verify that an isolation occurs when switches SGB1 and SGB2 are actuated together in the control room.
d.
In reviewing SG-6, FSAR Table 6.2-54 was reviewed and two errors were discovered. Penetration 308 indicates that valve 1633A recieves a E(A)
closure signal.
E(A) is not defined in the FSAR.
Penetrations 301A and B list valves 6050A, 6051A, 6052A, 6053A and 6051C as closed on a Phase A containment isolations.
A recent change eliminated these valves from Phase A containment isolation signals.
The above will be considered open (80-34-04) pending future inspection.
In reviewing changes to preoperational tests, the inspector found that additions were made to approved preoperational tests by generating minor changes. The additions to the approved tests in some cases had nothing to do with the original " intent" of the procedure, tiajor changes to preoperational tests are defined in the Startup Manual as changes to the scope, intent or acceptance limits.
It was determined that to qualify as a major change, a change would have to change the scope or intent as described in Chapter 14 of the FSAR and that additional testing which is deemed necessary by the Test Supervisor to document system operating parameters or revisions to plant design may be added as a minor change to a preoperational test.
Section 17.2.2.5 of the FSAR states that the SCE&G QA organization on site will perform surveillance of the performance, of preoperational tests to ensure conformance to all adminstrative requirements. The inspector reviewed Type I Surveillances performed on preoperational test DG-5, CC-1 SI-6, TE-1, LR-4, RC-1 and ES-01-E-16.
Findings were acceptable.
7.
Preservice and Inservice Pump and Valve Program The inspector reviewed the Preservice and Inservice Pump and Valve Program
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that was submitted to the NRC. The program was reviewed to verify
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conformance to regulations, comnitments and to verify the program is technically adequate.
Findings were acceptable with the following exceptions.
l a.
The subnitted plan has a " POSITION INDICATION" column and each valve listed in the program is designated as either "YES" or is left blank.
After speaking with a number of plant personnel involved in the program, it was clear that the basis for the designation of YES" in this column was not clear. The inspector requested that this be interpreted.
b.
It was not clear what was used as the basis for the scope of the program.
That is, why were the valves that were listed actually included in the program.
c.
The stroke times listed in the program did not correspond with stroke times listed in the FSAR.
d.
Valve 8028 is listed as Normally Open.
It should be normally closed.
e.
Many valves (excluding check valves) do not have a normal position listed.
f.
No alternate test is listed for valve 1015B,1001A, B,1022A, B.
g.
Valves 971 B and C were omitted from the program.
h.
Relief requests G-1, G-2, G-3 and G-4 assume that either both trains of Service Water are always operating or that even if one train is not running, it cannot be tested during operation.
It was not clear to the inspector why relief is needed in these cases.
These items will be considered additions to open item 79-31-06 and will remain open pending future inspector review.
8.
Meetings The inspector participated in the following meeting between NRR and SCE&G:
a.
Energency Feedwater Reliability b.
Seismic Qualification Team c.
Case Load Forecast Panel d.
1 & C, Power Systems and Reactor Systems.
9.
Independent Inspection Effort The inspector reviewed a letter to the NRC dated October 2,1980 concerning the Fire Protection Evaluation.
These were numerous commitments made in the
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letter concerning the plant's ability to reach cold shutdown from outside-i the control room.
The inspector will review these comitments at a later i
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date to ensure implementation and this item will remain open (80-34-05).
The response to Question 221.7 of the FSAR indicates that training will take i
place on the operation and maintenance of the loose parts monitoring system.
The training on the maintenance of the loose parts monitor has not yet been
established. This will remain an open item (80-34-06) pending future inspector review.
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Plant tour
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The inspector toured the plant at various times to observe construction activities, housekeeping, maintenance, equipment preservation and log books.
Findings were acceptable.
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