IR 05000395/1985034

Insp Rept 50-395/85-34 on 850903-06.No Violations or Deviations Noted.Major Areas Inspected:Violations/ Operational Events Resulting from Personnel Errors & Open Item Closeout

ML20198A628
Person / Time
Site:	Summer
Issue date:	10/12/1985
From:	Debs B, David Loveless, Luehman J, Moore R, Poertner W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20198A599	List: IR 05000395/1985034 ML20198A596
References
50-395-85-34, NUDOCS 8511060104
Download: ML20198A628 (9)

Text

'i pQ Cf otj UNITED STATES g'o, NUCLEAR REGULATORY COMMISslON f ~

[" n REGION 11 g ,j 101 MARIETTA STREET, * 's ATLANTA, GEORGI A 30323

. 9 . . . . . ,o Report No.: 50-395/85-36 Licensee: South Carolina Electric and Gas Company Columbia, SC 29218

&)cket No.: 50-395 License No.: NPF-12 Facility Name: Summer Inspection Conducted: September 3-6, 1985 t

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Inspectors: 19. d.9M 10iBlO C W. K. Poertner Date 51gned u V 2h L, IO / 6 / Ss'

J. G. Luehman i Date' Signed w - 10 9 PS Loveles Dath Signed R. Moore

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6 io l,In Date Sfgned Approved by: 7e //

B. T. Debs, Acting Section-Chief Date Signed Divisiun of Reactor Safety

SUMMARY

Scope: This special, unannounced inspection entailed 112 inspector-hours on site in the areas of violations / operational events resulting from personnel errors and open item closeou Results: No violations or deviations were identifie i PDR ADOCK PDR G

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REPORT DETAILS Persons Contacted Licensee Employees

• 0. Bradham, Director, Nuclear Plant Operations

, *J. Connelly, Department Director, Operations and Maintenance

• K. Woodward, Operations Manager

• L. Blue, Manager, Support Services

• M. Quinton, Manager, Maintenance Services

• B. Crowley, Group Manager, Technical and Support Services

• M. Williams, Manager, Nuclear Operations Education and Training 4 *A. Koon, Associate Manager, Regulatory Compliance

• R. Campbell, ISEG Engineer

• G. Putt, Manager, Scheduling and Materials

• C. McKinney, Regulatory Compliance

• R. Williams, ')perations Supervisor

• J. Sefick, As.,0ciate Manager, Station Security

• M. Browne, Manager, Technical Services

• R. Fowles, Regulatory Interface Engineer

• D. Flemming, Regulatory Compliance Clerk J. Heilman, Associate Manager, Nuclear Operations Training T. Matlos, Nuclear Operations Training Supervisor F. Zander, Manager, Nuclear Technical Education and Training P. Locose, Regulatory Compliance J. LaBorde, Project Engineer Other licensee employees contacted included engineers, technicians, and operator NRC Resident Inspectors I

• P. Hopkins

• Attended exit interview Exit Interview The inspection scope and findings were summarized on September 6, 1985, with those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection findings listed belo No dissenting comments were received from the license The licensee did not identify as proprietary any of the materials profided to or reviewed by the inspectors during this inspection, l'

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3. Licensee Action on Previous Enforcement Matters (Closed) Severity Level V Violation 395/85-04-02: Failure to Maintain the "R2" Test Status Chart as Required The licensee response dated March 25, 1985, was considered acceptable by Region II. The licensee reviewed the other control room logs and detennined one other log to be poorly maintained. The Manager, Operations, addressed the need to improve management control of activities in a series of supervisor meetings completed on March 14, 1985. Additionally, the response to the violation was circulated to all licensed personnel via the required reading log. The licensee action is considered sufficient to close this ite (Closed) Unresolved Item 395/85-03-01: Clarification of Procedures for Post Modification Testing This item expressed concern as to the establishment of responsibilities for several areas involved with post modification testing. A review of revisions in the current modification process indicated that the inspectors' concerns have been adequately addresse This item requires no further specific action and therefore is close ,% (Closed) Unresolved Item 395/85-11-02: Acc,ountability of Out-of-Calibration Evaluations in the Mechanical Maintenance Calibration Laboratory The inspector reviewed the present collection / filing system in use in the Mechanical Maintenance Calibration Laboratory. All evaluations are collected and maintained in the lab in a fireproof file cabinet until the instrument is retired. A log has been established for tracking of DPIRs and also a seven-day supervisor review of DPIRs has been initiated. This item is considered close (0 pen) Severity Level IV Violation 395/85-15-22: Failure to Implement the Requirement of Technical Specification 3.3.1, Table 3.3-1, Item 2A This violation was addressed by the licensee in Licensee Event Report (LER)85-10. Licensee corrective action and inspector concerns are still the same. This item remains open and will be closed with the closing of LER 85-10.

4. Unresolved Items Unresolved items were not identified during this inspection.

5. Violations / Operational Events Resulting From Personnel Errors Due to resident and regional concern with the increase in violations, LERs, and operational events associated with personnel errors at the V. C. Summer

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i Nuclear Power Plant, Region II conducted this special inspectio The purpose of this inspection was to review selected events to determine if this trend is due to programmatic problems and to determine what actions the licensee has instituted or plans to institute to correct this tren A partial summary of events that lead to Region II concern over the ,

operation of the V.C. Summer Nuclear Plant is outlined below.

f On February 28, 1985, a positive rate reactor trip occurred during startup due to a failure of the shift supervisor to be fully aware of plant statu On April 9,1985, with NI-41 out of service, control room personnel failed to perform a Quadrant Power tilt ratio as required by Technical Specification On March 20, 1985, scaffolding was constructed simultaneously over each 4 Diesel Generator potentially affecting the operability of the Diesel Generators during a seismic even On September 25, 1984, operators failed to recognize that Overpressure Delta Temperature instrument ITI 4228 had failed a channel check surveillance. Once brought to the attention of Operations Department Management, compensatory action was not initiated and the actual status of the associated protective channel was not verified until approxi-mately 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> late On December 13, 1984, during plant heatup in preparation for plant restart, required stroke testing of several valves had not been completed prior to changing modes. The control room supervisor had initialed the General Operating Procedure indicating the stroke testing as being complete On May 8,1985, conditions existed requiring the licensee to declare an unusual event. The declaration of an unusual event did not occur and j required notifications were not made for nearly nine hour On May 11, 1985, the plant achieved criticality below the rod insertion limit On June 11, 1985, the shift supervisor did not adequately evaluate plant conditions prior to authorizing surveillance test activities which resulted in both trains of low pressure Emergency Core Cooling being inoperabl ;

On February 21, 1985, the licensee failed to perform a Technical j Specification (TS) surveillance on effluent from the main vent stack a

within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of a reactor startu _ - - . . .

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l On March 20, 1985, training personnel discovered that an operators license had expired on February 3,1985, and a renewal application had

, not been submitte On August 23, 1985, both trains of Residual Heat Removal were rendered inoperable for their injection function due to system alignment error On August 24, 1985, during plant startup, the reactor tripped from approximately 10 percent power on Intermediate Range High Flu The trip resulted from personnel errors associated with the implementation of trip setpoint dat On August 24, 1985, during plant startup, the reactor tripped from in Steam approximately)26 Generator (SG percent power due to a low low levelA, caused by the autom isolation valve which feeds that steam generator.

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On August 29, 1985, the licensee determined that omission of required jumpers from the Overpower Delta Temperature trip circuitry allowed the trip setpoint to increase in value on decreasing reactor coolant average temperature and that this condition had existed since initial plant startup in October 198 On August 29, 1985, the licensee notified the NRC that the startup strainer in the suction piping for Reactor Building Spray Pump "B" was

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still in place in the pump suction. Subsequently, on August 30, 1985, the licensee determined that the startup strainer in the suction of Reactor Building Spray Pump "A" was still installe As a result of off-normal occurrence trending, the licensee had already identified this adverse trend in operations and is developing a Performance Improvement Program to correct this adverse trend in plant performance. The licensee has identified four areas with significant problems.

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Procedure Compliance

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Attention to Detail

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Training in Skill Levels Regarding the Significance of Such Events

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Overall Attitude Problem i The inspectors reviewed selected LERs and off-normal occurrence reports, conducted interviews with plant management, operations, and engineering personnel. The inspectors monitored control room activities and conducted tours of the plant. The inspectors made the following observation Some of the events reviewed indicated that, at least in part, the events I

took place because the licensee has not been effectively tracking the entrance into TS required action statements under Limiting Condition for Operation. In the case of out-of-service equipment and maintenance work,

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the licensee does have a tracking lo However, in the area of TS surveillance testing, the licensee has in the past relied on the shift supervisor's memory to track what work is being done. Because of recent events in the area, the licensee is presently implementing a fonnal tracking system for surveillance testing in progres The inspectors have looked at this new system which has been partially implemented and though it is too early to evaluate it fully, told the licensee that one tracking system covering surveillance maintenance and out-of-service equipment might be more effective. The inspectors suggested the licensee evaluate the systems used by other licensee The inspectors noted that many of the events reviewed occurred during startu In discussions with operations personnel, the inspectors determined that the feedwater system is of primary concern during a reactor startu V. C. Summer has D-3 type steam generator As a result of tube vibration and wear caused by the high velocity of the feedwater into the steam generators, Westinghouse developed the Preheater Inlet Modification for installation in the model D2/D3 steam generators. This modification diffuses the incoming feedwater to create a more uniform, less turbulent flow field entering the tube bundle. This modification includes six internal manifold boxes which are bolted together. At low feedwater flows and low feedwater temperatures, these bolts undergo thermal cycle To avoid bolting stress concerns, V. C. Summer prewarms the feedwater line The feedwater prewarming consists of a forward flush and a reverse flus The forward flush consists of taking hot water from the deareating (DA)

storage tank and pumping it through the feedwater lines to a four-inch line just upstream of each feedwater isolation valve that ties back into the DA storage tank. The reverse flush takes water from the steam generators through the feedwater lines to a tie in line just downstrGam of the feedwater isolation valve that is directed to the Steam Generator Blowdown line To prevent thermal cycling of the manifold bolts at low feedwater flows and low feedwater temperatures, a feedwater isolation occurs when feedwater flow is less than 16 percent coincident with a feedwater temperature of less than 225 degrees. In discussions with the licensee, the inspectors were told >

that V. C. Summer is the only plant with D3 Steam Generators that feeds through the preheater inlet during a reactor startup. Other plants with D3 type steam generators modified the feedwater lines to allow feeding through

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the auxiliary feedwater line during startup. This allows the preheater inlet to be bypassed during low feedwater flow and low feedwater temperature

! conditions. During a startup, the operators are extremely concerned with l increasing reactor power to a point where the feedwater flow interlock is l cleared prior to feedwater temperature dropping to less than 225 degrees.

I The licensee recognizes that during startup, increased attention is placed i on the feedwater system and that the shift supervisors may not be paying as much attention to the rest of the plant. The licensee plans to have a backup shift supervisor in the control room during startups to ensure that t

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the overall plant status is maintained during a reactor startu The licensee is also investigating modifications to the feedwater system to help alleviate this proble The inspector reviewed the disposition of IE Information Notice 85-23:

Inadequate Surveillance and Post Maintenance and Post Modification System Testing. This Notice described an event at McGuire Unit 2 where an electrical jumper was not installed on two of the four overpower delta temperature input logic cards, thereby making the channels inoperable. This same situation later occurred at V. C. Sumner but was not identified during review of the IE Notice by the license The individuals reviewing the Information Notice did not address the specific examples as stated in the Information Notice. The individuals reviewed the programs at V. C. Summer Nuclear Station dealing with surveillance, post maintenance, and post modification system testing. These individuals determined that the present V. C. Summer procedures were adequate to .nreclude occurrence of similar events. In addition to the IE Notice, the licensee received correspondence from Westinghouse identifying the problem and the type of cards involve The Maintenance Department reviewed all instrumentation that contained these ca rd However, at V. C. Summer, overpower delta temperature does not i contain the specific cards identified in the Westinghouse correspondence so the overpower delta temperature cards were not inspected. The inspector reviewed the licensee's programs for evaluating Information Notices and feedback of operating experience. No discrepancies were identified.

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During the inspection, the inspectors monitored control room activities and toured the plant. The turbine building was very clean and well kept. The intermediate building, auxiliary building, and outside areas were clearly satisfactory. In the control room, the inspectors noted burned out lights,

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. logs that were missing review initials, and unnecessary personnel in the area. Additionally, a number of empty soft drink cans and some food was left on the control room operator's desk. The inspectors also noted that the Operators Logs appeared sparse and to contain very little useful information about the status of the plant.

6. Licensee Action on previously Identified Inspection Findings

IFI 85-07-01 (Closed): In report 85-07, the inspectors expressed concerns l in six areas of the licensee's operator requalification program. Current

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revisions of NTCI-1 and the utility's Nuclear Education and Training Group i Manual adequately address the inspectors' concerns. This item is close IFI 85-07-02 (Closed): This item covered concerns that the licensee had conducted an audit to verify operator eligibility for requalification after the 1984 annual requalification exan, and therefore, identified deficiencies were not corrected prior to administering the annual examinatio The utility's Nuclear Education and Training Group Manual is being revised to require the audit to be a prerequisite to taking the examination. This item is considered close _ . _ _ _

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IFI 85-07-03 (Closed): It was identified that the licensee's program did not specify corrective actions for personnel who fail to accomplish the control manipulation required by Harold Denton's March 28, 1980 letter. The licensee identified one individual who had failed to complete all of these annual practical factor The one area of deficiency was corrected without delay and prior to the facility itself undergoing evolutions in this are In addition, the utility's Nuclear Education and Training Group Manual has been updated to address these required manipulations and to indicate a-required course of action for such situations in the futur The above actions are considered sufficient to close this ite IFI 85-07-04 (Closed): The inspector had expressed concern that the

" Required Reading Book" in the control room was not governed by a requirement limiting the time to accomplish the required reading that it containe Without such a criteria, the bcpk did not fully meet the intent of Section (4) of NUREG 0737, Item I.C.5, foncerning prompt feedback of information. The current revision of SAP-200, Item 6.13.3, requires this reading to be accomplished within 30 days of posting. This item is close IFI 85-07-05 (0 pen): This item revealed that mitigating core damage training for managers had been given initially but no retraining had been provided for non-licensed managers in the operations chain. Since this time the licensee has developed and administered a training course in this area.

The training topic outline and management attendance sheets were reviewed and found satisfactory.

During this inspection period, the licensee committed to providing this training on a regular basis. This item remains open pending the development of this administrative requiremen IFI 85-07-06 (Closed): The inspector expressed concerns that the evaluation of I&C's Basic Nuclear Systems (BNS) course meeting NUREG 0737, Item II.B.4, should be documented. A memo to file, signed by the Manager, Nuclear Technical Education and Training, was signed February 19, 1985, confirming that past and current review showed that the BNS course completely covered the topic of " Mitigating Core Damage". This is sufficient to close this ite IFI 85-04-01 (Closed): The inspector observed two housekeeping discrepancies which consisted of standing groundwater. The licensee has since sealed the areas of concern, and current inspection revealed no areas of standing groundwater. This item is close IFI 85-03-02 (0 pen): The licensee had stated that the Westinghouse Maintenance Manual for the DS-416 reactor trip switchgear would be issued to the site as a controlled document in February 1985 and any unresolved comments would be issued as a revision to the manual. Westinghouse review of revisions is still prohibiting incorporation of licensee comments into ;

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IFI 85-11-04 (Closed): The inspector reviewed Revision 2 of Mechanical Maintenance Procedure 285.006. This item is close IFI 85-24-02 (Closed): The inspector verified Diesel Generator Vendor Tech Manuals change distribution and implementation. This item is close . Onsite Followup of Written Reports of Non-Routine Events LER 85-10 (0 pen): This LER addresses a failure to meet the requirements of Action Statement 2.C, Table 3.3-1, Technical Specification 3. A power range excore nuclear instrumentation channel was removed from service for calibration. This evolution normally takes between three and four hour Because of faulty scaling data, the calibration time took 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> to complete. Action Statement 2.C above requires a quadrant power tilt ration j (QPTR) calculation to be performed every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> with reactor power above

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75 percent and one power range channel inoperable. This action was not take Corrective Action addressed in the LER and subsequently taken by the licensee was to revise surveillance test procedures which require entry into Action Statenent 2 of Table 3.3-1 to include a precaution to alert Operations of the requirement to monitor QPTR at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per

specificatio The ir5pector expressed concern that this corrective action was inadequate because it does not address the actual problem. The problem was not that the operator did not know initially of the TS, it was that he did not realize after 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> that the Power Range Channel was out-of-servic The licensee understood the inspectors' concerns and agreed to address the issue in future correspondence to the Commission. This item remains open pending further licensee corrective actio ,

LER 84-052 (Closed): The LER discussed an event involving leads lifted which would have prevented a turbine trip on "B" Train Steam Generator Hi-Hi or on a Safety Injection Signa The missing leads were found within one week of plant startu Extensive licensee review including paperwork reviews and personnel interviews could not determine why or when the leads were lifted. The licensee trained I&C technicians on the importance of ensuring equipment is returned to normal operable status upon work completion. This item is considered close _