IR 05000395/1981003
| ML20003E699 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 02/27/1981 |
| From: | Kellogg P, Skolds J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20003E693 | List: |
| References | |
| 50-395-81-03, 50-395-81-3, NUDOCS 8104100081 | |
| Download: ML20003E699 (7) | |
Text
,
e
'
'o UNITED STATES
/
NUCLEAR REGULATORY COMMISSION
,
g s
REGION il
101 MARIETTA ST.. N.W.. SUITE 3100 o,
ATLANTA. GEORGIA 30303 s
+...+
Report No. 50-395/81-03 Licensee: South Carolina Electric and Gas Company Columbia, South Carolina Facility Name:
V. C. Summer Docket No. 50-395
,
License No. CPPR-94 Inspection at V. C.
ummer Site near Parr, South Carolina h
M24/P/
Inspector:
7t/t J. L. (j kol io R dent Inspector Dfte Sign d
/ z/)
1 11
/
Approved by:
<
P. J.
ell
, Ject'"164th.164 r-RRPI Branch Dat(e Si/gned i
SUMMARY Inspection on January 2 - February 11, 1981 Areas Inspected This routine unannounced inspection involved 180 inspector-hours onsite in th?
areas of TMI Action Plant Item Followup, Integrated Leak Rate Test Observation, Previous Noncompliance Followup, Quality Assurance Surveillance / Audits, Review of Applicant Commitments, Security Training, Storage of QA Records, Plant Tour, NRR/IE Management Inspection.
Results l
l Of the 9 areas inspected, no violations or deviations were identified in 8 areas; 2 apparent violations were found in 1 area (Failure to establish predetermined locations paragraph 6; Failure to follow procedure paragraph 6).
!
t
.
81041000 6%
l l
.
_-
-
.
.
.
'
.
DETAILS 1.
Persons Contacted Licensee Employees
- 0. S. Bradham, Station Manager.
- J. G. Connelly, Assistant Station Manager
"L. Storz, Operations Supervisor
- S. Smith, Maintenance Supervisor
- B. G. Croley, Technical Support Supervisor
- C. Ligon, Administrative Supervisor
- A. Koon, Technical Services Coordinator
"P. Fant, QC Inspection Coordinator
"H. Donnelly, Independent Safety Engineering Group Other licensee employees contacted included technicians, operators, and office personnel.
- Attended exit interview 2.
Exit Interview _
The inspection scupe and findings were summarized on January 13, 1981, January 27, 1981, and February 6,1981, with those persons indicated in Paragraph 1 above.
The inspector also attended the exit interview of B. Crowley on February 5,1981.
.
3.
Licensee Action on Previous Inspection Findings (0 pen) Noncompliance (395/80-34-01) Failure to establish measures to implement measures established in the Operational QA Plan. The inspector reviewed the applicant's response, dated January 23, 1981. The corrective action taken included an evaluation of the QA Plan in the area of Startup Field Report Review. The evaluation revealed the necessity to revise the QA Plan.
The applicant has committed to revise the QA Plan.
Until this revision is complete, this item will remain open.
(Open) Noncompliance (395/80-34-02) - Failure to follow procedure.
The l
inspector reviewed the applicant's response, dated January 23, 1981. The
!
corrective action included revising Startup Manual Procedure SUM-8-13 " Start l
Up Field ~ Reports", holding training on the revision to the procedure, and holding training for the QC inspectors involved. The inspector reviewed the l'
revised procedure and the training conducted. Both appeared to be adequate.
However, this item will remain open until Starup Field Reports are reviewed
,.
j using the revised Start Up Manual Procedure as guidance.
l 4.
Unresolved Items Unresolved items were not identified during this inspection.
l-
,
~
.
,
'2 5.
TMI Action Plan Followup The inspector reviewed the applicant's response to TMI Action -Plant item I.A.2.1, Upgrading of operator and senior operator training and qualifi-cations. The response listed seventeen courtes to be attended in part by all licensee condidates.
The. inspector reviewed the training records of licensed operator candidates to verify the training records reflected what was indicated in the applicant's response.
The following discrepancies.
existed:
a.
The records being kept on check outs given were of poor quality in that one could not readily determine which check outs had been given and which check outs had not. System terminology differences also made the verification of the check out records difficult.
b.
A number of records were not in individual training records even though the applicant's response indicated these individuals attended certain courses. Specifically, records of attendance in Health' Physics' courses and supervisory training courses were missing from a number of personnel qualification folders. These records have been located and the records corrected.
This TMI Action Plant item will remain open pending future inspector review.
~
6.
Storage of Quality Assurance Records In reviewing the training records described in paragraph 5, the inspector reviewed the storage of the training records. The following references were used:
a.
10 CFR 50 Appendix B, Criterion XVII b.
FSAR, Section 3A c.
Administrative Procedure (AP) 301.2, " Nuclear Operations Records Control Procedure", Rev. O.
d.
AE3I N45.2.9 - 1974.
Findings were acceptable with the following exceptions:
a.
10 CFR 50 Appendix B, Criterion XVII states in part that consistent with applicable regulatory requirements, the applicant shall establish requirements concerning record retention, such as duration, location and assigned responsibility. Section 5.2 of ANSI N45.2.9-1974 states that the quality assurance record files shall be stored in predeter-mined locations as necessary to meet the requirements of applicable standards, codes and regulatory agencies. At present, the Permanent Records Facility is being phased in and some lifetime records are being kept in temporary storage facilities. However, these records are not
-
.
3'
being kept in predetermined locations.but rather wherever a permanent record exists, a temporary records facility exists.
The failure to designate the predetermined locations is considered to be in violation of 10 CFR 50, Appendix B (395/81-03-01).
b.
10 CFR 50 Appendix B, Criterion V : states that activities affecting quality shall be prescribed by documented instruction', procedures or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions or orocedures or drawings. Section 5.3.1 of Reference (c) states that until records are transmitted to the permanent records facility, they may be.kept in a Records-Temporary Facility and that this facility shall be a fire retardant filing cabinet or other fire retardant enclosed storage device or area. Also, a Records-Temporary Storage Facility shall have at least the following controls:
(1) A list of personnel authorized access will be maintained in the immediate area of the facility. Only those persons listed will be allowed access except under unusual circumstances at which time the responsibl_e organization supervisor may grant access. to others on a temporary basis by written permission, (2) A log of all QA records or record packages currently in the facility must be maintained and (3) The prescribed method of record removal as specified in the Permanent Record System Description will be followed.
The training qualification records were being kept in non-fire retardent cabinets and controls (1),(2) and (3) above were not being followed.
This is considered in violation of 10 CFR 50, Appendix B, Criterion V (395/81-03-02).
!
It was also noted by the inspector that the QA Program identified in l
Type II Surveillance I-II-8-80 that the Nuclear Operations Chemistry l
Group were not storing records in fireproof cabinets. The corrective l
action taken did correct that specific problem but was limited in scope
and did not identify nonfireproof cabinets being used in the Training l
Group.
Also, a Type II Surveillance T-II-23-80 was performed ' on l
training activities where training records were reviewed. The nonfire-proof cabinets were not noted during this surveillance. This indicates a lack of adequate corrective action and a' lack of knowledge of the Quality Assurance requirements.
7.
The inspector reviewed the procedure for the integrated leak rate test
(LR-3) to ensure that the requirements of Appendix J to 10 CFR 50, ANSI 45.4, Section 6.2 and 14.1 of the FSAR and Regulatory Guide 1.68 were included.
The inspector also reviewed valve lineups and test conditions prior to and during the test. The inspector had a number of comments i
.
r i
concerning valve lineups and test equipment which were resolved either before or during the test. no vilations were identified.
8.
Quality Assurance Audits / Surveillance
<
The inspector reviewed the implementation of the on site Quality Assurance surveillance program. References used were as follows:
a.
10 CFR 50, Appendix B, Criterion XVIII-b.
Operational Quality Assurance Plan c.
Section 17.2, FSAR d.
Quality Assurance Procedure No. 23, Rev. 2, " Site Surveillance" e.
Quality Assurance Procedure No.19, Rev.1, " Internal Audits" The following Type II surveillances were reviewed:
a.
T-II-3-3, Mechanical Activities b.
T-II-4-2, Nonconformance Control c.
T-II-1-9, Electrical Start Up d.
T-II-2-6, Material Control e.
T-II-17-18, Control Room Activities f.
T-II-2-14, Start Up I & C g.
f-II-22-80, Nonconformance Control h.
T-II-8-80, Nuclear Operations Chemistry Findings were acceptable with the following exceptions:
a.
When a Type II Surveillance is performed the results can be categorized as a " Finding" or a " Concern" by the individual performing the surveillance. Findings are considered to be more serious than concerns and are violations of some requirement. Concerns are items identified which the individual performing the surveillance feels may lead to a condition which would violate a requirement. However, concerns are not necessarily required to be followed up or responded to.
Individuals performing surveillances differ in their interpretations of findings and concerns.
Some individuals make nearly everything findings, some make nearly everyting concerns and others fall somewhere in between.
The surveillance program should identify what is not being done properly.
If the individual performing the surveillance has a concern about the way a program is being conducted, this concern should be
~
resolved either through the surveillance program or outside the surveillance program.
In 'either case, it needs resolution.
At present, some concerns have not been followed up once - they are identified in a Type II surveillance because they are classified as concerns and require no response.
This item will remain open (395/81-03-03) pending further inspection.
.
. -.. -
.-,
.-
.. -
.
.
,
9.
Review of Various Commitments The inspector reviewed the following letters to NRR which involve commit-ments on the part of the applicant:
a.
A letter dated 1/23/81, was written concerning the Emergency Feedwater System, Steam Generator Atmospheric Relief Valves, Engineered Safety Features potential design deficiencies and various other issues. The commitments made concerning the emergency feedwater system will be part of open item 80-EF-01. All other commitments in this lette'r will be designated as open item (395/81-03-04).
b.
A letter dated 12/22/80 was written concerning the Turbine Building Sump Pumps and an event at North Anna.
The letter indicates that valves and stainless steel piping between the turbine building sump pump discharge and the waste processing system was being installed.
Until this piping is installed, this item will remain open (395/81-03-05). Attachment 2 to the letter describes portions of the CVCS System which would prevent having an event similar to that at North Anna. The attachment indicates that "two level controllers cause a three way modulating valve to divert seal return to the Recycle Holdup Tanks on high level." Actually letdown flow and not seal return is diverted to the Recycle Holdup Tanks. The attachment also indicates that Component Coolant Pump miniflow returns to the VCT. Actually, Charging / Safety Injection Pump miniflow is returned to the VCT. These errors were minor and do not affect the substance of the response and therefore do not require a correction.
c.
A letter dated 12/15/80, was written concerning the operation of the condensate polishers. The letter stated that it is not intended to operate the Condensate Polishing System if a Steam Generator tube leak occurs.
The inspector informed the applicant that this commitment would severely restrict the use of the condensate polishing system and that it may be desirable to use this system to concentrate and localize the activity in the secondary system.
This item will remain open pending furture inspection (395/81-03-06).
'
d.
A letter written 12/29/80, concerning containment sumps includes a commitment to retest the RHR system subsequent to the installation of flow restricting orifices on the outlet of each RHR heat exchanger.
Until the inspector reviews the results of this testing, this item will remain open. (395/81-03-07)
e.
A letter written 1/15/81, concerns the results of the Control Room Human Factors Audit.
This letter includes numerous commitments to i
change controls, indications and displays in the control room.
The inspector will verify implementation of these commitments at a future date. This item will remain open (395/81-03-08) until then.
f.
A letter dated 11/21/80, changed section 12A of the FSAR. Included in the change was a description of access routes to vital areas in a post accident condition. The inspector informed the applicant that these
s
.
.
..
.
routes must be made available to operators and technicians in some other form than the FSAR. That is, it is not expected that in a post accident condition the FSAR will be used to locate these routes. Thi;
-
item will remain open pending future review (395/81-03-09).
10.
Security Training The inspector attended a security training class for general employees.~ Th~e
. material covered appeared to be adequate. No violations were identified.
11.
Plant Tour The inspector toured the plant at various times to observe construction activities, housekeeping, maintenance, equipment preservation and log books.
Finaings were acceptable.
12. NRR/IE Management Inspection The inspector participated in the joint NRR/IE Management Inspection on February 9-11, 1981. Results of this inspection will be documented in other correspondence and the Safety Evaluation Report (SER)..
.