IR 05000395/1989004
| ML20247F709 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 03/15/1989 |
| From: | Jape F, Casey Smith, Wright R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20247F706 | List: |
| References | |
| 50-395-89-04, 50-395-89-4, IEB-85-003, IEB-85-3, NUDOCS 8904040008 | |
| Download: ML20247F709 (7) | |
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- k UNITED STATES.
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j-NUCLEAR REGULATORY COMMISSION
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REGION 11 o,
101 MARIETTA ST., N.W.
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ATLANTA, GEORGIA 30323 em, J
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Report No.:
50-395/89-04
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Licensee:
South Carolina Electric & Gas Company-Columbia, SC 29218 Docket No.:
50-395
= License No.: NPF-12
- q Facility Name: Virgil Cc Summer-Inspection Conducted:
February 13-17, 1989 Inspectors: fMm,-)(4 R - / r Fr9 C. '$N Date Signed /
-#fthf. %&
s/m/s9 R. Wright ([
~.ite Signed Approved by: h h fut' u h e.m s.4 Rf/5fR9 b F. Jap ~e, Section Chief Date Signed
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V Quality Performance Section Engineering Branch Division of Reactor Safety SUMMARY Scope:
This routine unannounced inspection was in the areas of design control, design changes and modifications.
Results:
Independent design review of plant modification MRF 32103, " Rewire Limitorque from 2 Rotor to 4 Rotcr," revealed design control deficiencies regarding specifying ' design input requirements.
The design objectives could not be verified based on review of the design output drawings.
Specifically, design input requirements required to be shown on the M0V limit switch development drawing were not included in the design change package.
The inspectors subsequently determined that licensee management had previously identified this deficiency and NCN 3208 had been written to correct it.
Corrective action recommended was to incorporate Limitorque M0V limit switch adjustment information into the design-engineering program as design basis information. At the time of the inspection, MCN 21360-E was being implemented to show this information on drawing number B208-002.
This deficiency was characterized as a licensee identified violation for which a NOV will not be issued.
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8904040008 890316 PDR ADOCK 05000395 O
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REPORT DETAILS 1.
Persons Contacted Licensee Employees J. Archie, Lead Engineer, Systems and Performance Engineering A. Barth, Lead Engineer, Design Engineering
- M. Browne, Manager, Systems and Performance Engineering
- R. Clary, Manager, Design Engineering J. Geddings, Supervisor, Electrical / Instrumentation and Control
- W. Higgens, Supervisor, Regulatory Compliance
- S. Hunt, Manager, Quality Systems
- A. Koon, Manager, Nuclear Licensing G. Maffatt, Manager, Maintenance Services
- D. Moore, General Manager, Engineering Services J. Nesbitt, Electrical Supervisor, Maintenance
- K. Nettles, General Manager, Nuclear Safety
- C, Price, Manager, Technical Oversight
- J. Skolds, General Manager, Nuclear Plant Operations R. Smith, Lead Engineer, Systems and Performance Engineering B. Thompson, Surveillance Specialist, Quality Assurance J. Wactor, Senior Electrical Engineer, Design Engineering R. Waselos, Associate Manager, Design Engineering
- M. Williams, General Manager, Nuclear Services Other licensee employees contacted during this inspection included engineers, technicians, and administrative personnel.
NRC Resident Inspectors R. Prevatte, Senior Resident Inspector
- Attended exit interview Acronyms and initialisms used throughout this report are listed in the last paragraph.
2.
Modification Control Program (37700)
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MRF-21375 and MCN-A, B, and C, Rtactor Building Spare Penetration Modifications This MRF provided the details for removing the pipe caps which existed on the ends of spare penetrations 505-18 and 600-12.
These pipe caps were cut off and replaced with slip-on and blind flanges bolted at the penetration ends.
The modification of these penetrations was performed to permit easy vendor access into the reactor building for cables, air lines, etc., necessary to support steam generator maintenance services and other temporary services required during plant refueling outages. The basic function of these spare penetrations is to provide containment access during Mode 5 and maintain containment integrity during all other plant operational modes per TS and FSAR requirements.
MCN-A provided guidelines for installation of a temporary fire seal around vendor cables routed through the subject penetrations.
The installation was temporary and only required during core alterations; however, the design provided by this MCN was a permanent typical design that can be used anytime for the referenced penetrations.
MCN-B involved two minor material documentation corrections.
The bill of materials incorrectly referenced the stud material as SA-350, when it should have specified SA-320, Grade L43.
Likewise, the original package bill of materials did not specify the gasket type desired (flexitallic or equal gasket - penetration size).
MCN-C was written to document a change to the post modification testing criteria originally provided in the MFR.
This recommended ASME Section XI test assured that the weld and material integrity of the penetrations were acceptable prior to entering Mode 4.
The inspector examined MMP-285.004, Revision 4, which describes the pneumatic leakage testing employed, and WRNs 213750007 and 213750008 which performed and documeated the acceptable post-modification testing conducted on the subsect penetrations.
The inspector conducted discussions with and queried the lead engineer concerning the design, the functional aspects of the subject modi fication, and the supporting documentation contained in the modification package.
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MFR documents reviewed in detail to determine their technical and programmatic adequacy included:
design input considerations; completed 10 CFR 50.59,10 CFR 21, and Appendix R evaluations performed; engineering prerequisite holdpoints established for the work; engineering technical work records; post-modification testing and material requirements; the design verification conducted; sad the operability / return to service records. The latter document provides final objective evidence that all planned implementation was actually performed and is verified by the Lead Engineer, Supervisor Project Controls, and the Shift Supervisor prior to declaring the plant operable. The inspector verified that the required revisions to the TS, FSAR, and plant drawings were properly identified by the MRF. and either have been or are in the process of being revised.
PSRC Meeting No. 89-02, dated January 11, 1989, documents in its meeting minutes that the subject MFR was reviewed per Section 6.5 of the TS.
Based on review of MRF 21375 and its associated MCNs, the technical adequacy and the design change process appear to be satisfactory.
b.
MRF-32103 and MCN-A, Modification of Support Nos. CSH 1641 and CSH 1592.
The motor on valve XVT-8104 (Emergency Borate Valve - CVCS System)
failed on a back shift and was replaced by maintenance personnel with a safety-related spare that was electrically identical but larger in mass. The following day, prior to completion of the subject MWR, the difference in motor mass was identified to supervision and NCN 2103 generated to obtain an engineering evaluation.
During this engineering review (to requalify both the piping system and supports for the increased weight of the new valve actuator motor), it was found that the original weight of the operator was never included in the piping calculations.
Reanalysis performed using the correct total weight of the subject valve and its operator concluded the system would maintain its design function but one support (CSH 1641)
would be over code allowables.
This support was redesigned and modified in the field to meet code allowables per MRF-32103.
A subsequent review of all valves of the type listed in this base MRF was accomplished and one other (valve XVT-8100) was found to have had its operator weight not considered in the piping calcul6 tion. MCN-A was initiated to modify the design and reinforce support CSH-1592 to handle the added load.
As discussed with lead engineers and disclosed in the design review, the system would have maintained its design basis function as
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installed and although the SF of two supports would be reduced, there was no major reduction in safety due to this design error. The work resulting from the subject base modification and its cFange notice increased the SF of supports CSH-1641 and CSH-1592.
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The subject modifications did not change any applicable sections of the FSAR, FPER or plant TS.
This modification did not require any post-modification testing in that it only chanocd two pipe supports which the QC inspection program verified as acceptable.
The 10 CFR 50.59 evaluation performed war, found adequate and all affected drawings and procedures requiring revision were identified in the modification package.
The inspector verified by examination of meeting minutes that the PSRC reviewed the subject modification on January 5,1989, per Section 6.5 of the TS.
The probability of an occurrence or the possibility of a d1fferent type of accident was not increased by the work specified in this modification.
The inspector concluded after review of this modification that it was technically and administrative 1y acceptable.
c.
MRF 21360, Rewire Limitorque from 2 Rotor to 4 Rotor IEB 85-03, MOV Common Mode Failure During Plant Transients Due to Improper Switch Setting" was issued by the NRC on November 15, 1985.
It required licensees to develop and implement a program that ensured valve operator switches are selected, set, and maintained properly for certain safety-related M0Vs. Additional information was provided to the licensees in IEN 86-29, " Effects of Changing Valve Motor Operator Switch setting," concerning potential significant safety effects of changing MOV operator switch settings pursuant to IEB-85-03 requirements.
Plant modification MRF 21360 was developed and implemented by the licensee in response to the concerns identified in IEN 86-29 and INP0's SOER 86-02.
The scope of the design change involved reterminating wires to new limit switch contacts as shown on B-203 drawings, i.e.,
electrical elementaries.
Requirements for setting rotor 4 to show valve full closed position were also specified.
Additionally, requirements for the field to provide marked up copies of terminal sheets to design-engineering were specified. A total of 15 MOVs.were listed as requiring determination.
The inspectors performed an independent design review of the MRF package to verify that the design-output documents were technically adequate and the hardware changes, shown on the electrical elementaries, were consistent with the design objectives.
The nuclear safety evaluation performed in accordance with the requirements of 10 CFR 50.59 was also reviewed for technical adequacy.
Based on this review the inspectors determined that the design objectives could not be verified from the information contained in the MRF package.
Specifically, information concerning the setting of the open torque by-pass limit switch, actuated by rotor 2, was missing from drawing No. B 208-002, Notes, Legends and Relay Internals, Revision 2.
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The inspectors conducted interviews with the cognizant engineer regarding the apparent omission of required design input information from MRF 21360. They were informed that drawing number B 208-002 was being revised via MCN 21360E to specify the setting of the open torque by-pass limit switch.
The inspectors further determined that NCN 3208 had been written to document a problem concerning erroneous valve closed position indications caused by field adjustment of the open torque by-pass limit switches.
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Review of NCN 3208 revealed that the problem occurred when in response to IEB 85-03, procedure No. EMP 445.007, "M0 VATS hsting of Limitorque Valves," was revised to require setting the open torque by-pass limit switch to 25% of the MOV stroke time. This change was implemented on approximately 50 MOVs during RF04, and was later identified by Nuclear Operations during post-repair testing of valve
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XVG-9606.
The 25% stroke time setting of the torque open by-pass limit switch resulted in erroneous valve close position indication when the valve was still 25% open.
Subsequent evaluations by Nuclear Operations, documented on SCE&G memorandum from G. Soult, General Manager, Operations and Maintenance, to R, B. Clary, dated i
December 6, 1988, identified those MOVs that required corrective action by immediate implementation of MRF 21360.
l The licensee Quality Assurance organization performed a surveillance i
of the disposition of NCN 3208 which is documented in Surveillance Report No. 22-BLT-88-0.
The purpose of the surveillance was to evaluate whether changes made to torque by-pass limit switch settings were design changes.
The report concluded that torque by-pass limit switch settings had never been included in the plant design bases.
These settings were traditionally controlled by maintenance procedures.
It was recommended t!.at torque by-pass limit switch j
settings be incorporated into the plant design bases and be i
controlled by the Design Engineering organization.
The inspectors performed additional reviews of the corrective action proposed by the Design Engineering organization in response to the recommendation contained in Surveillance Report No. 22-BLT-88-0.
No deficiencies were identified during this review.
Failure of the j
design-engineering process to include necessary design input l
information for MRF 21360 was described as a licensee identified violation, 50-395/89-04-01.
However, because the licensee identified the violation; corrective action plans were being implemented; and the requirements of 10 CFR 50 Appendix C Section V were satisfied, a NOV will not be issued.
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Exit Interview The inspection scope and results were summarized on February 17, 1989, with those persons indicated in paragraph 1.
The inspectors described the areas inspected and discussed in detail the inspection results listed below.
Proprietary information is not contained in this report.
Dissenting comments were not received from the licensee.
The following violation was identified during this inspection.
This violation meets the criteria specified in Section V of the NRC Enforcement Policy for not issuing a Notice of Violation and is not cited.
Item Number Status Description VIO 50-395/89-04-01 Closed Omission of required design input for MRF 32103, paragraph 2.c.
4.
Acronyms and Initialisms ASME American Society of Mechanical Engineers CFR Code of Federal Regulations CVCS Chemical Volume and Control System FPER Fire Protection Evaluation Report FSAR Final Safety Analysis Report IEB Inspection and Enforcement Bulletin IEN Inspection and Enforcement Notice INP0 Institute of Nuclear Power Operations MCN Modification Change Notice MFR Modification Request Form MMP Mechanical Maintenance Procedure MWR Maintenance Work Request MOV Motor Operated Valve NCN Nonconformance Notice i
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Number NRC Nuclear Regulatory Commission PSRC Plant Safety Review Committee RF04 Refueling Outage Four SCE&G South Carolina Electric and Gas SF Safety Factor SOER Significant Operations Event Report TS Technical Specifications WRN Work Report Number l
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