IR 05000395/1990006
| ML20012E517 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 03/20/1990 |
| From: | Cantrell F, Modenos L, Prevatte R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20012E514 | List: |
| References | |
| 50-395-90-06, 50-395-90-6, NUDOCS 9004050310 | |
| Download: ML20012E517 (12) | |
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NUCLEAR REGULATORY COMMIS$10N
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REGION 11
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101 MARIETTA STREET,N.W.
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I Report No.:
50-395/90-06
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Licensee: South Carolina Electric & Gas Company
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Columbia, SC 29218 j
Docket No.:
50-395 License No.: NPF-12
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L Facility Name:
V.'C. Summer
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L Inspection Conducted:
February
- 28, 1990 i
Inspectors: '[
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L Rfchard L. Prevatte' //
Date Signed
8 FW Leo P. Modenos
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Da'te Signed fvNd Approved by:
e Floyd5.Cantrell.SectiopfChief D6te Signed Reactor Projects Branch 4 Division of Reactor Projects SUMMARY
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Scope:
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This routine inspection was conducted by the resident inspectors onsite in the
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areas 'of monthly surveillance observations, monthly maintenance observation.
operational' safety verification, onsite follow-up of events at operating power
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reactors, preparation' for refueling and other areas.
Selected tours were conducted on backshift or weekends.
Backshift or weekend tours were conducted on.13 occasions.
Results:
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The. plant was operated at 100 percent power for the reporting period.
Observations in the surveillance area (paragraph 2) detected a weakness in the control of special test equipment.
In the area of maintenance, the licensee's
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performance is still considered satisfactory with no deficiencies identified
during this inspection.
The licensee experienced two events, identified as examples a. & b. of one violation, which indicates that personnel are not complying with procedural requirements and that operations is not maintaining L
strict control of system alignments.
The first event resulted in the spill of L
contaminated water from the chemical and volume control system when maintenance l
attempted to change a filter without isolating, and draining the component and i
obtaining permission from operations prior to starting work (paragraph Sa).
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second event involved the automatic start of the turbine driven emergency l"
9004050310 900320 PDR ADOCK 05000393 O
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feedwater pump due to a loss of air to the turbine steam supply valve, In'this I
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l case, the instrument air. supply root valve to the air operated valve was found l
closed when it was required to be open (paragraph Sc). Several discussions were-i
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, held with plant management on the above items. An additional concern, related
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I to-the above involving a' perceived increase in personnel error and procedural.
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ri non-compliance, was discussed in detail.
In response, the-licensee provided a
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study of the off-normal occurrences for 1988 and-1989 which indicates that the'
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number of personnel errors had not increased in the past year.
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Two examples of one ' violation were identified.
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h REPORT DETAILS I
1.
Persons Contacted
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Licensee Employees W. Baehr, Manager, Chemistry and Health Physics C. Bowman, Manager, Scheduling and Modifications
- 0. Bradham, Vice President, Nuclear Operations M. Browne, Manager Systems Engineering & Performance W. Higgins, Supervisor, Regulatory Compliance
- S. Hunt, Manager. Quality Systems
- A. Koon Manager, Nuclear Licensing
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- G. Moffatt, Manager, Maintenance Services
- D. Moore, General Manager, Engineering Services
- K.. Nettles, General Manager, Nuclear Safety
- C. Price, Manager, Technical Oversite M. Quinton, General Manager, Station Support J. Shepp, Associate Manager, Operations J. Skolds, General Manager, Nuclear Plant Operations G. Soult, General Manager, Operations and Maintenance
- G. Taylor, Manager, Operations D. Warner, Manager, Core Engineering and Nuclear Computer Services
- M. Williams, General Manager, Administrative & Support Services K. Woodward, Manager, Nuclear Operations Education and Training Other licensee employees contacted included engineers, technicians, operators, mechanics, security force members, and office personnel.
- Attended exit interview Acronyms and initialisms used throughout this report are listed in the last paragraph.
2.
Monthly Surveillance Observation (61726)
The inspectors observed surveillance activities of safety related systems and components to ascertain that these activities were conducted in accordance with license requirements. The inspectors observed portions of five selected surveillance tests including all aspects of Train B Containment Hydrogen Monitor Operation Test, STP 301.007. The inspectors i
verified that required administrative approvals were obtained prior to
initiating the test, testing was accomplished by qualified personnel, data i
met TS requirements, test discrepancies were rectified, and the systems (
were properly returned to service.
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On February 21, 1990, the inspectors observed 1&C technicians performing Train B Containment Hydrogen Monitor Operational Test, STP 301.007.
The procedure specified the use of test equipment that included two test
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gauges. FS 2790 and FS 2804 The I&C technicians followed.the procedure
verbatim by selecting gauge FS 2804.
During the test, the ins sector
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observed that gauge FS 2804, which was connected to an oxygen )ottle
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had an attached label with red markings in three different places which h
read, "Not To Be Used On Oxygen."
Gauge FS 2804 had been contaminated with oil approximately one year ago and had been labeled "Not To Be Used i
On Oxygen" by the Metrology group.
Since the gauge had not been cleaned to the point where absolute assurance could be provided that there was no l
oil in the gauge, it was decided the gauge could be used, but not with
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oxygen, and installed the above warning label for safety purposes.
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oil and oxygen could ignite and cause equipment damage and/or personal injury.
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After being questioned by the inspectors, the I&C technicians returned the test gauge to the shop and had their supervisors review the procedure.
The licensee performed a procedure change which deleted the reference to specific gauge numbers in the procedure. The STP was then completed with
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a new test gauge.
This is an example of blindly following a procedure while ignoring other cautions.
The licensee is in agreement with this weakness and has agreed to provide additional indoctrination to plant
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personnel on this item.
i No violations or. deviations were identified.
f 3.
Monthly Maintenance Observation (62703)
The inspectors observed maintenance activities on safety related systems and components to ascertain that these activities were conducted in accordance with approved procedures TS, industry codes and standards.
The inspectors determined that the procedures used were adequate to control the activity, and that these activities were accomplished by qu Nafied personnel.
The inspectors independently verified that the equipment was properly tested before being returned to service.
Additionally, the inspectors reviewed several outstanding job orders to determine that the licensee was giving priority to safety related maintenance and not developing a backlog which might affect a given system's performance.
The following specific maintenance activities were observed:
MWR 214750034 Breach and reseal fire barriers as required by MRF 21475B PMTS P0119249 Fire service jockey pump discharge valve functional test
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PMTS P0125793 Loop calibration of Si accumulator B level switch, ICT 00926 l
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f PMTS P0130879 Perform weekly lubrication and inspection of DG A & B-injection pumps and fuel control linkage o
PMTS P0118071 Charging /SI pump A miniflow isolation valve XVT08109A test j
No violations or deviations were identified.
4.
Operational Safety Verification (71707)
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The inspectors conducted daily inspections in the following areas:
control room staffing, access, and operator behavior; operator adherence to approved procedures, TS, and limiting conditions for operations; examination of panels containing instrumentation and other reactor protection system elements to determine that required channels are operable; and review of control room operator logs, operating orders, plant deviation reports, tagout logs, jumper logs, and tags on components to verify compliance with approved procedures.
The inspectors conducted weekly inspections in the following areas:
verification of operability of selected ESF systems. by valve alignment, breakerpositions,conditionofequipmentorcomponent(s),andoperability of instrumentation and support items essential to system actuation or performance.
Plant tours included observation of general plant / equipment conditions, fire protection and preventative measures, control of activities in progress, radiation protection controls, physical security controls, plant housekeeping conditions / cleanliness, and missile hazards.
The inspectors conducted biweekly inspections in the following areas:
l verification review and walkdown of safety related tagout(s) 'in effect; review of sampling program (e.g., primary and secondary coolant samples, bnric acid tank samples, plant liquid and gaseous samples); observation of coatrol room shift turnover; review of implementation of the plant problem
j identification system; verification of selected portions of containment isolation lineup (s); and verification that notices to workers are posted
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as required by 10 CFR 19.
Selected tours were conducted on backshifts or weekends.
Inspections included areas in the cable vaults, vital battery rooms, safeguards areas, emergency switchgear rooms, diesel generator rooms, control room, auxiliary building, containment, cable penetration areas, service water l
intake structure, and other general plant areas.
1eak rates were reviewed to ensure that detected or suspected leakage from the system was recorded, investigated, and evaluated; and that appropriate J
actions were taken, if required.
On a regular basis, RWP's were reviewed
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and specific work activities were monitored to assure they were being
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conducted per the RWP's.
Selected radiation protection instruments were i
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periodically checked, and equipment operability and calibration frequency
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were verified.
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In the course of monthly activities, the inspectors included a review of F
the licensee's physical security program.
The performance of various a
i shifts of the security force was observed in the conduct of daily activities to include:
protected and vital areas access controls; searching of personnel, packages and vehicles; badge icsuance and
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retrieval; escorting of visitors; and patrols and compensatory posts.
No violations or deviations were identified.
5.
Onsite follow-up of Events at Operating Power Reactors (93702)
a.
On January 30, 1990 MWR 9000219 was written to replace RC filter (XFL 009) due to high differential pressure and was assigned to the mechanical maintenance group.
On January 31, 1990, the maintenance planner obtained a RWP for the filter change scheduled for the morning of February 1, 1990.
The HP computer system was out-of-service at that time.
The ALARA planner explained this to the maintenance planner and said that he would issue a computer generated RWP the i
following morning.
The ALARA planner assigned RWP 90-0052 and entered this number on the applicable block of the MWR, The MWR was then returned to the control room.
On February 1,1990, the mechanical planner picked up the work package from the control room.
The work package had not been signed or released by the shift supervisor.
The planner was told to return
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later during the day to have the work package signed and released.
The planner returned the MWR to the mechanical supervisors area.
The HP computer was still out-of-service at that time.
The ALARA planner stated he planned to hand write the RWP but got side tracked with other activities.
Maintenance called the HP during the morning and told the HP shift leader that they would be down in a couple of hours to change the filter.
The HP shift leader called the ALARA planner and discussed the required RWP.
The ALARA planner and HP shift leader each incorrectly assumed that the other would write the RWP.
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On the afternoon of February 1, 1990, the mechanical job supervisor assig'aed the filter change task to four mechanics. The job supervisor failed to recognize that the MWR had not been signed and released by the shift supervisor.
Step 5.3 of procedure MMP 225.003, Rev. 3, Remote and/or Contact Changeout of Contaminated Filters, requires that the system will be isolated, tagged out, and drained prior to a
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i filter change.
The mechanics proceeded to unbolt the filter housing -
without any attempt to verify that the equipment had been isolated, tagged out, and drained.
As soon.as the filter housing bolts were
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loosened, water began spraying from the filter housing and it became
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apparent to the workers that the system was not isolated or drained.
At this time, the control room received a radiation alarm from the RC filter area, and operators observed that the VCT level was decreasing.
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Within five minutes the shift supervisor arrived at the scene and isolated the RC filter.
Approximately 150 - 250 gallons of water
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spilled in the RC filter cubical room and drained into a floor drain tank.' HP hot spot smears of the RC filter cubical room were 10 - 40 Rad, with the general area radiation reading 1700 mrem.
Decontamina-tion of the room on February 1 and 2,1990, resulted in a total personal exposure of 215 mrem.
Procedures that were violated included:
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MMP 225-003, Remote and/or Contact Changeout of Contaminated Filters, step 3.2 which requires that a RWP be obtained if required on the work request, and step 5.3 which requires that the system to isolated, tagged, and drained prior to starting work.
2.
HPP 151, Use of RWP & SRWP, step 5.2.1 which requires that the job supervisor and work crew review the RWP prior to beginning work, and step 5.2.2 which requires that the job supervisor ensure special instructions are followed.
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Special Instruction 02-02, which requires that the HP supervisor contact the shift supervisor and document in the HP shift log that the system has been drained and is ready for work.
4.
SAP 601, Application, Scheduling and Handling of Maintenance Activities, step 6.6.D which requires that the organization performing the work notify operations, HP, engineering and QC prior to job start.
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SAP 300, Conduct of Maintenance, step 6.1.M which requires that the group performing the maintenance activity be responsible for all programmatic controls including notification of operations
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and QC prior to job start and to ensure that HP concurs with the l
correct RWP/SRWP used for the particular work activity.
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This failure to follow procedures is the first example of Violation 90-06-01, Failure to Follow Procedures.
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The inspectors reviewed maintenance activities which used MMP
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225.003 for the last two years and found that 24 MWR's had been issued to accomplish safety-related filter changeouts and that
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the components'were not tagged out on any of these occasions as F
required by the procedure.
The mechanical maintenance group stated that was the way they have been operating for a number of i,
p years.
This lack of attention to the detail could result in
equipment damage or failure end possible personnel injury.
'L The licensee has taken or is planning the following corrective actions:
1.
The plant manager has issued a letter to all managers and supervisors requiring that they instruct their people and ensure that operations permission is obtained prior to starting work on plant equipment.
2.
Change MMP 225.003 to accurately reflect the way filters are changed.
Include appropriate precautions and limitations. The licensee has also taken administrative actions on the involved individuals.
Additional training and counseling of other plant
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personnel is planned to prevent a recurrence of this event.
3.
Provide more detailed program definition in SAP 300 which describes the worker's responsibility to verify equipment is ready for work prior to job start,
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b.
On January 23, 1990, at 4:45 a.m., the licensee tagged out B DG for scheduled maintenance.
This resulted in voluntary entry into TS Action Statement 3.8.1.1.b.
The chilled water A system chiller was out for repairs, the B chiller was aligned to the B train and the C chiller was aligned to the A train.
The repairs on A chiller were completed, and at 1:35 p.m., the A chiller and chiller water pump were placed in operation on A train. The C chiller and chiller water pump were secured.
This action would permit both A and C chiller to automatically start on A train.
At 6:25 p.m., the C chiller and chilled water pump were restarted and at 6:28 p.m., the A chiller and chilled water pump were placed in pulled to lock. This action made A chiller and pump inoperable and prevented their automatic start.
When the evening shift came on duty, the shift supervisor recognized that the A chiller was still racked in. He questioned the justifica-tion for this alignment since the breaker for A and C chillers and
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pumps were closed and this contradicted procedural requirements. At i
7:30 p.m., the A chiller and chilled water pumps were racked out thereby aligning only the C chiller to A train.
A review of this event shows that both pumps were aligned to A train for approximately 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.
Procedure HVAC Chilled Water, S0P-501, Rev.10, precautions requires that only one chiller and its associated chiller water pump
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be racked in at any time on each train to prevent overloading the diesel generator during accident conditions.
Caution step 2.3 requires that two trains of chillers be operable, and one of the following conditions met:
a) C chiller must be the operable unit on the train to which it is aligned with the normal chiller and chilled
water pump breakers racked out or b) C chiller and pump breaker must be racked out.
The operators on the day shift failed to recognize that both the B DG t
and A chilled water trains were inoperable' for approximately five hours and take action specified in TS 3.8.1.1.
The operators believed that they were in a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> action statement for the chiller, a less restrictive statement than the action statement of TS 3.8.1.1.
The licensee was fortunate in that this condition did not exceed the six
hours allowed by the LCO.
The inspectors were informed of this event on on February 5,1990, The licensee stated that all operations watchstanders would be informed of the event.
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Additional corrective actions include:
1.
TS 3.1.8.1 " Interpretation" has been revised and clarification has been made on Action Statement b.3.
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Procedure NL 116. TS change, Rev. 1, will be revised to include a check list that incorporates TS interpretations, procedures, FSAR, etc., on any TS amendments.
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The licensee will review current TS interpretations to assure that they reflect the latest TS amendments.
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4.
Modify GTP 702, Surveillance Activities Tracking and Triggering, Rev. 8, to address a tracking mechanism for TS 3.8.1.1.B.3 to ensure monitoring the status of the operable train equipment.
5.
Establish a threshold for significant in-house events and initiate a formal program to ensure that they are discussed in detail with each on-coming shift.
c.
At approximately 12:30 p.m., on February 20, 1990, with the unit at 100 percent power, the licensee discovered the TDEFW pump running at 3400 RPM and supplying 60 to 90 GPM of feedwater to the steam generators.
The turbine steam supply control valve indication on the main control board indicated that this valve was closed.
Inspection at the pump indicated that the valve was 1/8 to 1/4 inch open but the closed limit switch had not moved enough to actuate the open indica-tion.
The licensee closed the steam supply valve and returned the pump to its normal standby conditio F[M
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An investigation into this event revealed that the pump started because the air supply to the steam supply valve. IFV 2030-MS, had
"t been isolated by closing the instrument air root valve IFV 2030 AV1-MS.
The steam supply valve.is normally maintained in the closed position by. air pressure acting against spring tension.
If the air
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supply is reduced or lost, the valve will fail in the safe (open)
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This system also contains a check valve and accumulator
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which stores a sufficient volume of air to keep the valve closed for
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three hours on a loss of normal instrument air.
When the pump was
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discovered running, the air supply valve was found closed and the
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accumulator pressure had fallen from 62 PSI to approximately 20 PSI.
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i Further investigation into this event revealed that STP 120.007 Backup Air Supply Check Valve Surveillance Test, was performed at approximately 1:40-a.m., on the previous shift.
This test required
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that the air supply valve IFV 2030-AV1-MS, be closed, the cap be removed from the vent line and vent valve IFV 2030-AV3-MS opened.
When the pressure was vented off, the check valve would backseat and the accumulator would maintain the pressure required to keep the
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valve closed. After the test is completed, the vent valve is closed, the line is capped and the air supply valve is opened to return the system to its normal configuration.
The completed STP indicated that the test was completed satisfactorily and all valves were returned to the normal position. The test record also shows that a second independent verification was accomplished on
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these valves.
The licensee has interviewed each of the operators involved in the above tests and all personnel that could have entered the TDEFW pump room during the time period in question. The operators
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have stated that the system was restored to the correct condition.
All other personnel state that they have no knowledge of the cause of this event.
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Several additional deficiencies were identified during the inspector's review of this item which requires licensee attention and/or corrective action.
These include:
valves IFV 2030-AV2 and AV3-MS
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are not listed on the valve line-up sheets for the main steam S0P 201; the drawings which show the above valves, IFV 2030-AV1-MS,
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IFV 3531, 3541, 3551, 3536, 3546 and 3556 AV1, AV2, AV3-EF and MS are not referenced in the EFW and main steam S0P 201 and S0P 211; and the CHAMPS tag was missing from IFV 2030-AV3-MS.
The independent verification procedure, SAP 153 Rev. O. Step 6.5 used by operations
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to verify that the system was restored after surveillance testing required that all components be verified to have correct identifica-tion tags installed.
This was not accomplished during the above verification chec _.
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Based on the above, it is apparent that control of the alignment for this system as specified in 50P 201 and STP 120.007 was not maintained. This (
item will be cited as a second example of Violation 90-06-01, " Failure to
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Follow Procedures".
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One violation was identified.
6.
PreparationForRefueling(60705)
i The inspectors continued to review the licensee's receipt of new fuel and control components, and unpacking, inspecting, and handling of new fuel assemblies.
The inspectors verified that the receipt of new fuel activities were performed in accordance with prescribed procedures.
7.
Other Areas A review of the January resident inspector's report 50-395/90-01. indicates that a clarification is needed in paragraphs 4 and 5.
In paragraph 4, the licensee has concluded that they did not have unanalyzed conditions and that they were not operating outside of the system design basis.
A 10 CFR 21 report was submitted by Gilbert / Commonwealth on February 9, 1990 for inadequate design of the chillers.
Corrective action will be implemented under the MRF program.
Full corrective actions and the schedule has not yet been finalized.
In paragraph 5. LER 88-15 was closed and a statement was made that the modifications will be implemented in the next refueling outage.
The modifications are currently scheduled to be performed during the sixth refueling outage.
8.
Exit Interview (30703)
The inspection scope and findings were summarized on March 2,1990, witn those persons indicated in paragraph 1 The inspectors described the areas inspected and discussed the inspection findings. The problem
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associated with the use of a potentially oil contaminated gauge on an oxygen system was discussed.
The violation associated with attempted replacement of the CVCS filter by maintenance without operations release and the improper alignment of an air supply valve for the TDEFW pump steam
supply valve were discussed in detail.
The licensee presented the results
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of an analysis of 1988 and 1989 ON0's which indicates that personnel
errors had not increased in the past year. Although the above events and violation did not have a high degree of safety significance, the licensee
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appeared to be aware of the consequences of events that could occur under similar conditions.
Licensee management indicated that they will take any action deemed necessary to insure that system work and alignments are controlled.
No dissenting comments were received from the licensee. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during the inspectio,
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Acronyms and initialisms
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ALARA As Low As Reasonably Achievable DG
' Diesel Generator CHAMPS Computerized History and Maintenance Program System CVCS Chemical Volume Control System
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EDG Emergency Diesel Generator
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ESF Engineered Safety Feature
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FSAR Final Safety Analysis Report r
FS Field Standard.
- GPM Gallons Per Minute
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i GTP General Test Procedure L
1&C Instrumentation and Control i
HVAC Heating, Ventilation, & Air Conditioning l
LER Licensee Event Reports
LC0 Limiting Conditions for Operations MMP Mechanical Maintenance Procedure MRF Modification Request Form
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MWR-Maintenance Work Request i
NL Nuclear Licensing i
NRC Nuclear Regulatory Commission NRR Nuclear Reactor Regulation
,0N0 Off Normal Occurrence
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PSI Pounds Per Square Inch
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PMTS Preventive Maintenance Task Sheet
QC Quality Control RC Reactor Coolant RCS Reactor Coolant System
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RCSLK9 Reactor Coolant System Leak Rate RWP Radiation Work Permits RPM Rotations Per Minute SAP Station Administrative Procedure l
SI Safety Injection
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S0P System Operating Procedure SPR Special Reports SRWP Standing Radiation Work Permit STA Shift Technical Advisor STP Surveillance Test Procedures TS Technical Specifications TDEFW Turbine Driven Emergency Feedwater VCT Volume Control Tank
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