IR 05000395/1988021

Insp Rept 50-395/88-21 on 880919-22.No Violations or Deviations Noted.Major Areas Inspected:Licensee Conformance to Reg Guide 1.97, Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant & Environs..

ML20205M290
Person / Time
Site:	Summer
Issue date:	10/24/1988
From:	Conlon T, Hunt M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20205M289	List: IR 05000395/1988021 ML20205M284
References
RTR-REGGD-01.097, RTR-REGGD-1.097 50-395-88-21, NUDOCS 8811030021
Download: ML20205M290 (12)

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION o '* RF.OlON 11

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101 MARIETTA ST., e,,,, ATLANTA. GEORGIA 30323 a .

Report No.: 50-395/8E-21 Licensee: South Carolina Electric and Gas Company Columbia, SC 29218 ,

Docket No.: 50-395 License No.: NPF-12 Facility Name: Summer Inspection Conducted: September 19-22, 1988

" Inspector: M bl.I , m _

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_ /0 bl Ofte 71gned M. D. Hunt

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Team Members: P. Fillion Approved by:

T. E. Conlon, Sectl on Chief Md:#f />ft f#Date Y.4!85V Sign 6d Division of Reactor Safety ,

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dVMMARY Scope: This routine, announced inspection was in the areas of the licensee's conformance to Regulatory Guide (RG) 1.97, Instruientation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and environs Conditions During and Following an Accident.

Results: In the arr:,. Inspected, violations and deviations were not identi-

fled. !ne licensee has performed the installation and modification of 'nstruments to comply with Regulatory Guide 1.97 Revision P, wever, There were exceptions noted in th Safety Evaluations Report dated April 15, 1985, and subsequent corresponcence with the NR Additional items were identified during this inspection which are discussed in the repor The licensee's Table 7.5-1, Regulatory

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. Guide 1.97 variables, in the FSAR, Amendment 4 dated August 1988 is a compilation of the licensee's intent for meeting RG 1.9 In addition, the licensee developed a high quality comprehensive RG 1.97 Manual for ', heir us Weakness: A minor weakness was identified in the licensee's program concerning trending and evaluation of out of tolerance 'as found" calibration readings for non Technical Specification instrument Strengths:Significant engineering ant raanagement strengths were identified in two areas, the instrument loop diagrams and the RG 1.97 manual. The i developement of these excellent tools indicates the licensee

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recognizes what is needed atd is willing to put forth the effort to provide i ! B 8811030021 ADOCKO%h95 pg PDR Q

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l REPORT 07 TAILS Persons Contacted

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Licensee Employees

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'A. Barton, Engineer, Computer Services

• M. D. Blue Engineer, Regulator Compliance

• 0. S. Bradham, Vice President, Nuclear Operations R. Brown, Plant Support 3pecialist, Design dr.gineering

• M. N. Browne, General Manager, Station Support S. Carroll, Electrical Engineer, Design Engineering -

"A. R. Koom, Manager, Nuclear Licensing

• Moffatt, Manager, Maintenance Services

• D Moore, General Manager, Nuclear Safety J. Nesbitt, Electrical Supervisor, Maintenance

• K. W. Nettles, General Manager, Nuclear Safety V. Prawd:ick, I&C Supervisor, Maintenance C. Osier, Supervisor, System Engineering

• M. D. Quinton, Manager, Systems and Performance Engineering M. Rash, Technician, Electrical Maintenance '

B. Sanders, Technician, Electrical Maintenance

• J. L. Skolds, General Manager, Nuclear Plant Operations

• G. G. South, General Manger, Operations and Maintenance

• G. Walker, Coordinator, Mainter.ance Services T. Watkins, Supervisor, Loop D*aarams, Systems Engineering T. Wessner, I&C Engineer, Design Engineering Other licensee employees contacted during this inspection included engineers, operators, technicians, and administrative personne NRC Resident Inspector l * L. Prevatte

• Attended Exit Interview

' Inspection of Licensee's Implementation of Multiplant Action A-17:

Instrumentation for Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident (Regulatory Guide 1.97) .

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(25587).

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Criterion 13, "Instrumentation and Control", of Appendix A to 10 CFR '

Part 50 includes a requirement that instrumentation be provided to monitor variables and systems over their anticipated ranges for accident condi-tions as appropriate to ensure adequate safety. Regulatory Guide 1.97 (RG 1.97) describes a method acceptable to the NRC staf f for complying  ;

with the Commission's regulations to provide instrumentation to monitor ,

plant variables and systems during and following an acciden ,

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r The purpose of this inspection was to verify that the licensee has an instrumentation system for assessing variables and systems during and ,

following an accident, as discussed in Regulatory Guide (RG) 1.97. Under 1 accident conditions it is necessary that the operating personnel have (1)

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information that permits the operator to take preplanned actions to i accomplish a safe plant shutdown; (2) determine whether the reactor trip, Engineered Safety-Feature Systems (ESFS), and that other manually ,

initiated safety systems important to safety are performing their intended '

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functions; and (3) provide information to operators that will enable them ,

to determine the potential for a breach of radiation release barriers provided to the operator if the barriers are being challenged that will ,

allow the release of radioactive materials. For this reason multiple i

' instruments with overlapping ranges may be necessar The required ;

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instrumentation must be capable of surviving the accident environment for

the length of time its operability is require It is desirable that components continua to function following seismic event '

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As a result, five types of variables have been specified that serve as guides in defining criteria and the selection of accident-monitoring

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instrumentation. The types are: Type A - Those variables that provide ,

! information needed to permit the control room operating personnel to take i i specified manual actions for which no automatic control is provided and  !

i that are required for safety systems to accomplish their functions for i

! design basis accident events. Type B - Those variables that provide

information to indicate whether plant safety functions are being accom-

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p11shed. Type C - Those variables that provide information to indicate  !

the potential for barriers being breached or the actual breach of barriers ,

l to fission product releas Type D - Those variables that provide  !

! information to indicate operation of individual safety systr,ms and other '

systems important to safety. Type E - Those variable to W monitored in 3 determining the magnitude of the release of radioactive materials and for  !

continuously assessing such releas :

The design and qualification criteria are separated into three separate i i categories that provide a graded approach to requirements depending on j

, the importance to safety of the measurement of a specific variabl ,

j Category 1 provides the most stringent requirements and and is intended e i for key variables. Category 2 provides less stringent requirements and j j generally applies to instrumentation designated for indicating systems  :

! operating statu Category 3 is intended to provide requirements that  !

i will ensure that high quality off-the-shelf instrumentation is obtained [

and applies to backup and diagnostic instrumentation. A key variable is  ;

i that single accomplishment of a safety function (Types B and C), or the l

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operation of a safety system (Type 0), or radioactive material release t (Type E), Type A variables are plant specific and depends on the  ;

j operations that the designer chooses for planned manual action l l Inspection of Categories 1 and 2 equipment was performed as described  !

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. Category 1 Instrumentation The instrumentation listed in the Category 1 Table, of this section, was examined to verify that the design and qualification criteria of RG 1.97 had been satisfied. The instrumentation was inspected by

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reviewing drawings, procedures, data sheets, other documentation, and i

performing walkdowns for visual observation of the installed equipment. The following areas were inspected:

(1) Equipment Qualification - The EQ Master Equipment List and the Q-List were reviewed for confirmation that the licensee had addressed environmental qualification requirements for class IE equipmen (2) Redundancy - Walkdowns were performed to verify by visual observation the specified instruments were installed and

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separation requirements were met. In addition loop drawings were reviewed, to verify redundancy and channel separatio (3) Power Sources -

Loop drawings were reviewed to verify the

instrumentation is energized from a safety-related power source.

2 (4) Display and Recording - Walkdowns were performed to verify by

< visual observation that the specified display and recording i instruments were installed. Loop drawings were reviewed to

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verify there was at least one recorder in a redundant channel and two indicators, one per division (channel) for each sneasured variable.

j (5) Range - Walkdowns were performed to verify the actual range of

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the indicator / recorders was as specified in RG 1.97 or the SE .

Review of calibration procedures verified sensitivity and overlapping requirements of RG 1.97 for instruments measuring

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the same variabl (6) Interfaces - The loop drawings and Q-List were reviewed to j verify that safety-related isolation devices were used when

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required to isolate the circuits from non safety systems.

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(7) Direct Measurement - Loop drawings were reviewed to verify that

! the parameters are directly measured by the sensors, j (8) Service, Testing, and Calibration - The maintenance program for

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performing calibrations and surveillances was reviewed and

, discussed with the licensee. Calibration and surveillance i procedures and the luest data sheets for each instrument were I reviewed to verify the instruments have a valid calioratio i

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CATEGORY 1 TABLE Instrument N Loop And Variable (Channel or Train) Wiring Drawings RCS Pressure PT-402 A VCS-IPT00402 - RC !'

(Wide Range) PI-402 PI-403 B VCS-IPT00403 - RC PI-403 l PR-402 A Both Above L RCS Hot leg TE-413 A VCS-ITE00413-RC Temperature TI-413 T hot (Wide Range) TE-423 A VCS-ITE00423-RC TI-423 '

TE-433 B VCS-ITE00433-RC TI-433 i TR-413 A All Above i RCS Cold leg TE-410 B VCS-ITE00410-RC l Temperature TI-410 [

T cold (Wide Range) TE-420 B VCS-ITE00420-RC :

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TI-420 TE-430 A VCS-ITE00430-RC l TI-430 i TR-410 B All of Above <

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Reactor Building LT-1975 A VCS-ILT01975-LD ;

Level LI-1975 )

l LR-1975 LT-1976 B VCS-IL'01976-LO LI-1976 l

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Reactor Building PT-950 A VCS-IPT00950-SI

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(Containment) PI-950 *(IMS-51-099)

Pressure PR-950 l Normal Range PT-951 A VCS-IPT00951-SI PI-951 *(IMS-51-113)

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PT-952 B VCS-IPT00952-SI !

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PI-952 *(IMS-51-125) l PT-953 B VCS-IPT00953-SI PI-953 *(IMS-51-141) L l

Reactor Building PT-954A A VCS-IPT00954A-HR I (Containment) PI-954A *(IMS-51-644) l Pressure PR-954 i Extended Range PT-954B B VCS-IPT00954B-HR !

l PI-954B *(IMS-51-649) l f

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Reactor Building C1-8257 A B-208-0 t Sheet 21 (Containment) XCP-6105 and Sheet 22 Hydrogen CI-8258 B SS-211-054 Sheet J2 Concentration XCP-6105 Sheet C5 Reactor Building LT-1969 A VCS-ILT01969-LD $

(Containment) LI-1969 RHR Sump LR-1971 Level LT-1970 B VCS-ILT01970-LO LI-1970 *(IMS-51-312)

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Steam Generator LT-474 A VCS-ILT00474-MS Level LI-474 *(IMS-51-902)

Narrow Range LT-475 A VCS-ILT00476-MS LI-475 t LT-476 B VCS-ILT00476-MS

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LT-476 *(IMS-51-117) ,

LR-478 l

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LT-484 A VCS-ILT00484-MS LI-484 *(IMS-51-415)

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L LT-485 A VCS-ILT00485-MS l LI-485 *(IMS-51-409)

LT-486 B VCS-ILT00486-MS l LT-486 *(IMS-51-118)

LR-4SS l

LT-494 A VCS-ILT00494-MS '

LI-494 LT-a95 A VCS-ILT00495-MS l i LI-495 <

LT-496 B VCS-ILT00496-MS !

LI-496 LR-498 r

h Steam Generator LT-477 A VCS-ILT00477-MS

. Level LI-477 [

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Wide Range LR-478 LT-487 A VCS-ILT00487-MS ,

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LR-488 i LT-497 B VCS-ILT00497-MS LI-497 i LR-498 i

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Steam Line PT-474 A VCS-IPT00474-MS P1-474 i Pressure PT-475 B VCS-IPT00475-MS !

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< PI-475 PT-476 8 VCS-ITP00476-MS i PI-476

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PT-484 A VCS-IPT00484-MS PI-484 PT-485 B VCS-IPT00485-MS PI-485 PR-475 PT-486 B VCS-IPT00486-MS i PI-486 *(IMS-51-134) l PT-494 A VCS-IPT00495-MS PI-494 <

PT-495 A VCS-IPT00495-MS PI-495 *(IMS-51-129)

PR-475 PT-496 B VCS-IPT00496-MS !

PI-495 Refueling Water LT-990 A VCS-ILT00990-SF [

Storage Tank LI-990 *(IMS-51-408 & 413)

Level LR-3621 i

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LT-991 A VCS-ILT00991-SF '

LI-991 LT-992 B VCS-ILT00992-SF !

LI-992 *(IMS-51-411)

LT-993 8 VCS-ILT00993-SF LI-993 *(IMS-51-412) *

Pressurizer LT-459 A VCS-LTS00459-RC Level LI-459 LR-459 LT-460 A VCS-LTS00460-RC LI-460 LR-459 LT-461 8 VCS-LTS00461-RC LI-461 LR-459 Emergency FT-3561 A VCS-FT503561-EF Feedwater FI-3561 *(IMS-51-286) t Flow FT-3571 B VCS-FT503571-EF t F1-3571 *(IMS-51-673 Sheet 5) !

FT-3581 B VCS-FT503581-EF ,

F1-3581 *(IMS-51-283) i e

"Indicates vendor (Westinghouse) drawings used for verification,

' Category 2 Instrumentation r

The instrumentation listed in the Category 2 Table, of this section, I

was examined to verify that the design and qualification criteria of i

RG 1.97 had been satisfied. The instrumentation was inspected by ,

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performing walkdowns for visual observation of the installed equipment. The following areas were inspected:

(1) Equipment Qualification - The EQ Master Equipment List and the Q-List were reviewed for confirmation that the licensee had addressed environmental qualification requirements for Class IE equipmen (2) Power Sources - Loop drawings were reviewed to verify the instrumentation is energized from a high quality or a safety-related power sourc (3) Display and Recording - Walkdowns were performed to verify by visual observation that the specific display and recording instruments were installed. Loop drawings were reviewed to verify there was at least one recorder, where required by RG 1.97, in a redundant channel and two indicators, one per division (channel) for each measure variabl (4) Range - Walkdowns were performed to verify the actual range of the indicators / recorders was as specified in RG 1.97 or the SE Review of calibration procedures verified sensitivity and overlapping requirements of RG 1.97 for instruments measuring the same variabl (5) Interfaces - The loop drawings and Q-list were reviewed to verify that sa f ety-rel ateci isolation devices are used when required to isolate the circuits from computer systems (not safety-related).

(6) Direct Measurements - Loop drawings were reviewed to verify that the parameters are directly measured by the sensor (7) Service, Testing, and Calibration - The maintenance program for performing calibrations and surveillances was reviewed and discussed with the license Calibration and surveillance procedures and the latest data sheets for each instrument were reviewed to verify the instruments have a valid calibratio CATEGORY !! TABLE Instrument N Loop and Variable (Channel - Train) Wiring Drawings Condensate LT-3621 A VCS-ILT03621-CS Storage Tank LI-3621 "(IMS-51-204)

Level LR-3621 Charging FT-122 A VCS-I F 0122-CS System FI-122 Flow

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Letdown FT-150 A VCS-IFT00150-CS Flow FI-150 Volume LT-115 A VCS-ILT00115-CS Control Tank LI-115 Level HHS! FT-940 A VCS-IFT00940-SI l Flow F1-940 t FT-943 8 VCS-IFT00943-51 FI-943 RHR FT-605A A VCS-IFT00605A-RH ;

Flow FI-605A  ;

FT-605B B VCS-IFT00605B-RH !

FI-605B Service FT-4466 A *IMS-51-296 Water FI-4466 System FR-4466 Flow FT-4496 8 *IMS-51-314 FI-4496 FR-4496 Accumulator LT-920 A VCS-ILT00920-$1 Tank LI-920 Level LT- 922 B VCS-ILT00922-SI LI-922 LT-924 A VCS-ILT00924-SI LI-924 LT-926 B VCS-ILT00926-SI LI-926 LT-928 A VCS-ILT0092S-SI LI-928 LT-930 B VCS-ILT00930-SI LI-930 *(IMS-51-ISS)

Accumulator PT-921 A VCS-ILT00921-SI Tank PI-921 Pressure DT-923 B VCS-ILT00923-51 PI-923 PT-925 A VCS-ILT00925-SI PI-925 PT-927 B VCS-ILT00927-SI PI-927 PT-929 A VCS-ILT00929-SI PI-929 PT-931 B VCS-IPT00531-SI PI-931

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AC Voltage XSW1A A 207-013 & 014 V-1A XSW1B B V-1B XSW1C C V-1C DC Voltage X/,BA1A A 206-062 (Battery) V-B-1A Sheets 1, 2, & 3 XBA1B B V-B-18 ,

Pressurizer APN04101 Verified by calibration Heater AM-PH-1 data & drawing '

Current APN04102 i

AM-PH-2 APN04103  !

AM-PH-3

• Indicates vendor (Westinghouse) drawings used for verificatio ,

Discussion ,

The licensee was well prepared and expended every effort to assist the inspectors in performing the RG 1.97 inspection. All previously requested documentation including the Q-List, the EQ-List, electrical drawings, r instrument loop diagrams, and calibration data sheets were pulled and t

available in an organized manner. In addition the licensee had developed a RG 1.97 Manua ,

The RG 1.97 Manual was organized as a comprehensive book containing all '

the pertinent engineering and regulatory requirements. The manual was  !

complete and prepared in a professional manner indicating an extended

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effort was required to produced i Another significant area of improvement was identified. The licensee had i established a program to upgrade the instrumentation drawings by l

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developing instrument loop drawings. An instrument loop diagram contains "

all the necessary information including the electrical wiring for a technician to troubleshoot and understand how the loop operates. It could i be considered the most important instrument drawing at an operating (

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facilit The quality of the licensee's loop drawings was exceptiona The results of the inspection were that the licensee has met the require-ments of RG 1.97 with two exceptions: the need for environmentr.lly [

qualified Category J instrumentatien to monitor accumulator tank level and I

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pressure; and the common designation of Category 1 and 2 instrument on the main control board, i l

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The NRC staff is still evaluating, generically, the need for environ-mentally qualified Category 2 instrumentation to monitor the accumulator tank level and pressure. This will remain an open item until the generic review process is complet RG 1.97 Revision 3 states that Types A B and C instruments desginated as Categories 1 and 2 should be specifically identified with a common designation on the control panels so that the operator can easily discern that they are intended for use under accident conditions. The licensee has elected to identify these instruments with labels having a yellow background and block letters (other instruments are identified with labels having a white background and block letters). During the walkdown of instruments in the main control room, the inspector observed that with one exception the yellow background labels were used for each of the parameters in the inspection sample. However, the licensee volunteers the information that a few instruments that should have the yellow background labels did not have them. The licensee presented a preliminary copy of Modification Change Notice (MRF # 21061). The purpose of this change notice would be to install yellow background labels where necessary to meet RG 1.9 The licensee committed to proceed with this modification, and this was acceptable to the NR Druing the review of the RG 1.97 instrumentation data sheets, several of the "as found" readings were initially out of tolerence. The inspector questioned the licensee to determine if a trendirg and evaluation program existed to monitor these out of tolerance "as found" reading The licensee stated only Technical Specification instruments were monitored, but a program for other instruments was being considered. It is to be noted the licensee is not required to have a trending program for non Technical Specification instrument . Exit Interview The inspection scope and results were summarized on September 22, 1983, with those persons indicated in Paragraph 1. The inspector described the areas inspected and discussed in detail the inspection results listed belev. Proprietary information is not contained in this repor Otssenting comments were not received from the license . Acronyms and Initialisms FI -

Flow Indicator FR -

Flow Reader FT -

Flow Transmitter HHSI -

High Head Safety Injection LI -

Level Indicators LR -

Level Recorder LT -

Level Transmitter MCB -

Main Control Board MST -

Maintenance Surveillance Test

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PAM -

Post Accident Monitoring PI -

Pressure Indicator PR -

Pressure Recorder PT -

Pressure Transmitter RHR -

Residual Heat Removal RC -

Reactor Coolant RCS -

Reactor Coolant System RG -

Regulatory Guide RWST -

Refueling Water Storage Tank SCE&G -

South Carolina Electric and Gas SER -

Safety Evaluation Report TE -

Temperature Element TI -

Temperature Indicator TR -

Temperature Recorder TT -

Temperature Transmitter l

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