IR 05000395/1993025
| ML20058P580 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 12/02/1993 |
| From: | Cantrell F, Thomas Farnholtz, Haag R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20058P560 | List: |
| References | |
| 50-395-93-25, NUDOCS 9312270192 | |
| Download: ML20058P580 (13) | |
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGloN 11 3( )7 S 10) MARIETTA STREET, N.W., SUITE 2900
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Report No.:
50-395/93-25 Licensee:
South Carolina Electric & Gas Company Columbia, SC 29218 Docket No.: 50-395 License No.: NPF-12 Facility Name: Virgil C. Summer Nuclear Station Inspection Conducted: October 14 through November 20, 1993 Insprctors:
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uk 11/1/93 R.C. Haag,SeniorResigntInspector Date Signed P
4.LJNX#
amu T.R.Farnholtz,ResidptInspector Date S'igned Accompanying Inspector:
G. F. Wunder, NRR Project Manager
/4/2/7 Date' Signed]
Approved by:
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F1oyd S/Cantrell, Chief
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Projects Section IB
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Division of Reactor Projects SUMMARY Scope:
This routine inspection was conducted by the resident inspectors and the NRR project manager onsite in the areas of monthly surveillance observations, monthly maintenance observations, operational safety verification, ESF system
walkdown, review of licensee self-assessment capability and review of 10 CFR 50.59 evaluation program.
Selected tourc were conducted on backshift 'or weekends. These tours were conducted on five occasions.
Results:
No violations or deviations were identified.
A lack of periodic cleaning of a strainer in the diesel driven fire pump
engine cooling water supply line was identified during testing. Also, the
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adequacy of the pump retest after the strainer was cleaned was questioned
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(paragraph 3). The actions to anticipate and plan for an engineered safety-feature relay failure and to replace the relay were thorough and well supported by management (paragraph 3). The evaluations of gaps and shrinkage in the spent fuel pool boraflex material appeared to be adequately bounded.
Also, the evaluation provided a long-term resolution for these conditions (paragraph 5). A weakness in the documentation and filing of independent 9312270192 931202 PDR ADOCK 05000395
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i safety engineering group reviews and scope of their reviews for NRC Generic
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Letters was identified (paragraph 7). The licensee has an effective program
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for implementing 10 CFR 50.59 reviews (paragraph 8).
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REPORT DETAILS
1.
Persons Contacted Licensee Employees W. Baehr, Manager, Health Physics
- C. Bowman, Manager, Maintenance Services
- M. Browne, Manager, Design Engineering
- L. Faltus, Acting Manager, Chemistry Services
- M. Fowlkes, Manager, Nuclear Licensing & Operating Experience S. Furstenberg, Associate Manager, Operations
- S. Hunt, Manager, Quality Systems
- A. Koon, Nuclear Operations Project Coordinator D. Lavigne, General Manager, Nuclear Safety
- G. Moffatt, Manager, Planning and Scheduling
- J. Nesbitt, Acting Manager, Technical Services K. Nettles, General Manager, Station Support H. O'Quinn, Manager, Nuclear Protection Services
- M. Quinton, General Manager, Engineering Services
- J. Skolds, Vice President, Nuclear Operations G. Taylor, General Manager, Nuclear Plant Operations
- R. Waselus, Manager, Systems and Performance B. Williams, Manager, Operations 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.
Plant Status The plant was operated at 100 percent power from the beginning of the_
i inspection period until November 2, 1993, when a power reduction was commenced for the purpose of conserving fuel to allow continued operation through the remainder of the operating cycle.
The_ power
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reduction was halted on November 4,1993 at 80 percent and remained at
that level through the remainder of the inspection period.
3.
Monthly Surveillance Observation (61726)
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The inspectors observed surveillance activities of safety related systems and components listed below to ascertain that these activities were conducted in accordance with license requirements. The inspectors 1;
verified that required administrative approvals were obtained prior to
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initiating the test, testing was accomplished by qualified personnel in j
accordance with an approved test procedure, test instrumentation was calibrated, and limiting conditions for operation were met. 'Upon completion of the test, the inspectors verified that test results conformed with technical specifications and procedure requirements, any j
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deficiencies identified during the testing were properly reviewed and resolved, and the systems were properly returned to ser. ice.
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Specifically, the inspectors witnessed / reviewed portions of the
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followir.g test activities:
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a.
Turbine driven emergency feedwater pump test (STP 220.002). All activities observed were satisfactory.
Equipment performance was-
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within acceptance criteria with no adverse trends, b.
Quarterly surveillance test for the "B" train battery (STP 501.002). No discrepancies were noted.
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c.
Nuclear instrument power range N41, N42, N43, and N44 calibration (STP 310.005, STP.310.006, STP 310.007, and STP 310.008).
Partions of these procedures were used to insert new current values in the nuclear instruments to correct repeated flux tilt alarms that were coming in as a result of reactor power being reduced. The new current values were obtained from an earlier performed incore flux map and were inserted to provide a more accurate relationship between the nuclear instruments and the actual reactor power.
distribution. No discrepancies were identified.
d.
Diesel driven fire pump annual testing (STP 228.001). The original pump was exhibiting degrading performance over a period of several years and was replaced with a new pump. The annual test was done as post-maintenance testing for the new pump. The inspector made the following observations:
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The diesel driven fire pump automatically started at a fire
header pressure of 89 psig and decreasing. The procedure specifies a starting pressure of 85-87 psig. The licensee considers the actual starting pressure adequate and will change the procedure to reflect actual conditions.-
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During performance of the test, the test header discharge pressure was reduced to between 79.5 and 82.5 psig by opening i
the test header valves. When this was done, the engine coolant
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temperature increased above the maximum allowable 200 degrees Fahrenheit to approximately 220 degrees Fahrenheit. This was due to an insufficient flow of cooling water to the engine cooling heat exchanger which is supplied by the discharge of the fire pump.
It was concluded by the licensee that the strainer in the supply line to the engine cooling heat exchanger was partially clogged with debris causing the low flow condition at the decreased header pressure. The inspector noted that no preventive maintenance to clean the strainer is performed on ~ a regular basis. Also, the inspector questioned
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the adequacy of the retest after the strainer was_ cleaned. The inspector was not aware of the pump being tested _at the low discharge pressure and high flow conditions with a clean strainer to ensure engine temperatures remain satisfactory.
The licensee informed the inspector that pump retest activities
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would be reviewed and that they plan to establish a periodic task to clean the strainer. The inspector will followup on the licensee's actions involving the diesel driven fire pump.
e.
Train "A" solid state protection system logic and master relay testing (STP 345.037). This surveillance meets the requirements of TS 4.3.1.1 and 4.3.2.1.
When this testing was last performed for -
the "A" train on September 17, 1993, master relay K501 failed.to give proper test indications on the first attempt.
Repeated
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attempts to test relay K501 resulted in proper test indications.
At that time, a Nonconformance Notice (#4832) was written to accept-relay K501 as-is until no later than the end of Refuel 8.
In anticipation of the possibility of a failure of this relay during the performance of this surveillance test, the licensee wrote a troubleshooting / repair plan and held a pre-job briefing to
prepare for the possible replacement of the relay while at power.
The inspector reviewed the plan and attended the briefing and concluded that the preparations were adequate should the K501 relay fail.
During the surveillance test, on November 19, 1993, the K501 master
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relay again failed to give proper test indications and the licensee proceeded to replace the relay in accordance with the repair plan.
The technicians, engineers, and operators involved in this effort went about their jobs in a professional and deliberate manner. The
newly installed relay was satisfactorily' tested. The licensee is
investigating the cause of the relay failure and the impact the
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failure mode would have had on ESF actuations. The inspectors will review the results of the licensee's investigations.
Testing of the diesel driven fire pump identified a weakness dealing with no periodic cleaning of a strainer in the engine cooling water
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line. Also, the adequacy of the retest following the cleaning of the
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strainer was questioned. All other observed tests were performed in accordance with procedural requirements and demonstrated acceptable
results.
4.
Monthly Maintenance Observation (62703)
Station maintenance activities for the safety-related systems and components listed below were observed to ascertain that they were conducted in accordance with approved procedures,. regulatory guides, and industry codes or standards.
The following items were considered during this review:
that limiting
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conditions for operation were met while components or systems were removed from service, approvals were obtained prior to initiating the work, activities were accomplished using approved procedures and were l
inspected as applicable, functional testing and/or calibrations were
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performed prior to returning components or systems to service,
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activities were accomplished by qualified personnel, parts and J
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materials used were properly certified, and radiological and fire prevention controls were implemented. Work requests were reviewed to
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determine the status of outstarling jobs and to ensure that priority
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was assigned to safety-related equipment maintenance that may affect system performance. The following maintenance activities were observed:
a.
Repair of an oil leak on the outboard bearing of the
"B" spent fuel cooling pump (MWR 9304345).
b.
Replacing the float level for the purge unit on the
"C" chiller (MWR 9304458).
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c.
Oil cleanup in the
"C" chiller using the non safety-related filtering system (MWR 9304342). An attempt was made to clean the oil using a system permanently installed on the chiller but was not qualified as safety related. The system consists of an eductor, a filter, and associated piping and valves. A person was
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stationed in the chiller room while this system was in service with instructions to secure the cleanup and isolate the system anytime he left the area or if any adverse conditions appeared.
The inspector reviewed the controls that were implemented for the use of this system and concluded that the licensee had taken adequate precautions.
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n.
Comparator and rate drawer calibration (PMTS P0169889). The drawer generates a startup rate signal from each source and intermediate range channel.
It also compares each of the four power range channels and generates an alarm signal if a deviation of greater than 2 percent of full power exists between any of the channels. All activities were satisfactory, e.
Troubleshooting the improper operation of "A" EDG fuel oil day tank level switch ILS5411 (MWR 9304500). This switch provides the starting and stopping signal for the lead and backup fuel oil transfer pumps. During an EDG surveillance test, the lead transfer pump did not stop at the established 450 gallon level.
The operators noted that the pump had started at the required 350 gallon level but failed to stop until manual. action was taken.
The day tank has an overfill line back to the underground storage tank. This condition was corrected by an adjustment to the level switch.
During the post-maintenance testing the transfer pump started to
"short cycle" between the approximate 340-370 gallon range.
Additional repair efforts did not identify.the cause of the pump stopping prior to reaching the 450 gallon level.
In later EDG runs, the transfer pump cycled on and off between the 350 to 395 gallon range. The backup transfer pump when tested started'and i
stopped at the required levels of 250 and 450 gallons. Since the licensee did not have a complete replacement level switch assembly, engineering accepted this condition (short cycling) on a l
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temporary basis. The licensee intends to replace the level-switch assembly once a replacement is obtained. The inspector reviewed the " accept as-is" disposition and concluded that an adequate
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basis had been established to allow continued operation with the level switch operating in this manner. The disposition addressed'
both the immediate and the potential long term impact on fuel oil transfer pump.
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The observed maintenance activities were performed using good work practices and per the applicable procedural instructions.
5.
Operational Safety Verification (71707)
a.
Plant Tour and Observations The inspectors conducted daily inspections in the following areas:
control room staffing, access, and operator behavior; operator
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adherence to approved procedures, TS, and limiting conditions for operations; and review of control room operator logs, operating orders, plant deviation reports, tagout logs, and tags on components to verify compliance with approved procedures.
The inspectors conducted weekly inspections for the operability verification of selected ESF systems by valve alignment, breaker positions, condition of equipment or component (s), and operability of instrumentation and support items essential to system actuation or performance.
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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
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missile hazards. Reactor coolant system leak rates were reviewed to ensure that detected or suspected leakage from the system was recorded, investigated, and evaluated; and that appropriate actions were taken if required. Selected tours were conducted on backshifts or weekends.
b.
Boraflex Panel Integrity Reviews Boraflex neutron absorbing panels are used in the high density fuel storage racks to increase the shutdown margin in the spent i
fuel pool (SFP). The boraflex_ panels are enclosed by the side -
walls of fuel racks. During a five year surveillance inspection of boraflex coupons at another nuclear power plant, one coupon was found to be nearly empty of boraflex material. An estimated 90 percent of the material was missing. The other coupons had 30 to 50 percent of the boraflex material missing.
Degradation of the boraflex panels at V. C. Summer has also i
occurred. The licensee has inspected the boraflex coupons and d
also performed neutron absorption (blackness) tests on selected
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cells in the spent fuel pool. The blackness test consist of a neutron source and' detectors which measure thermal neutrons that pass through' flaws in the boraflex panels. The first test performed in 1988 revealed that 21 out of 52 cells tested had gaps ranging in size from 0.5 to 1.2 inches 'in the boraflex material.
Two subsequent blackness tests were performed on a larger number of cells. The test results identified that new gaps had formed and the previous gaps had increased in size. However, the latest test identified a smaller increase in gap size which indicates the shrinkage of boraflex is nearing a saturation point. The licensee's analysis of the boraflex gaps determined that the K eff limit of less than 0.95 would be maintained. Additional information on the boraflex gaps was provided in NRC Inspection Report 50-395/91-17.
The licensee has completed six inspections of boraflex coupons from the SFP. A total of 14 coupons were inspected with the inspection criteria being satisfied for all the coupons.
It should be noted that the degraded coupons inspected at the other plants were full length coupons. A short-set coupon from that plant (similar to the coupons at V. C. Summer) had retained 100 l
percent of the boraflex material.
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The inspector reviewed a criticality analysis for the SFP, issued in April 1993, which considered the boraflex shrinkage and gaps.
The assumption in the analysis for the. size and locations of the gaps / shrinkage bounded the conditions which were discovered during the blackness test. Also, the analysis assumptions used industry guidance on boraflex gaps and shrinkage. The licensee is in the process of submitting a TS change to incorporate the results of SFP criticality analysis. The inspector concluded that assumptions contained in the analysis adequately modeled the existing conditions of the SFP.
c.
Control of Debris in the Reactor Building (RB)
The inspectors had previously reviewed the licensee's controls for debris and fibrous material in RB in response to NRC Information Notice 93-34, " Potential for Loss of Emergency Cooling Function Due to a Combination of Operational and Post-LOCA Debris in Containment" and NRC Bulletin 93-02, " Debris Plugging of Emergency Core Cooling Suction Strainers". The concern dealt with material.
plugging / clogging the suction strainers, located in the RB sumps, which are used in the recirculation phase'of the emergency core cooling systems. Another nuclear plant had experienced clogging-of ECCS pump suction strainers during non-accident operation of the system.
Fibrous material from temporary cooling filters in the containment was identified as the cause of the clogged straine l l
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The inspectors reviewed the licensee's response to NRC Bulletin 93-02, which stated that temporary fibrous air filters are not used nor stored inside the containment.
In clarification to this statement, the licensee informed the inspector that this statement referred to power operations. During outages temporary filters, (i.e., HEPA filters are used in the RB).
The response also stated that all temporary material used during an outage and located inside the containment is removed and a QC inspection of the RB at
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closeout includes an inspection of the sumps for foreign material.
For the last refueling outage (March - May,1993), the inspectors
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were aware of the concern with temporary filters. During tours of the RB, with a heighten attention in this area, the inspectors did
not identify any inconsistent usage of this type of material.
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Near the end of the outage in preparation of RB closeout, the inspectors noted that nearly all temporary equipment and material
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had been removed from the RB. The completed surveillance sheets
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for QC inspection of the ECCS sump were reviewed by the inspectors and verified to be completed.
Limited usage of temporary air filters occur in the RB during outages. The licensee has controls to ensure they are removed prior to RB closeout. Also, the licensee performs independent inspections of ECCS sumps near the end of refueling' outages.
6.
ESF System Walkdown (71710)
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The inspectors verified the operability of an ESF system by performing -
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a walkdown of portions of the station instrument air system. During the walkdown the area of concentration included the air compressors, receiver tank, air dryers, and portions of the system that service
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important equipment. The inspectors confirmed that the licensee's system line-up procedures matched plant drawings and the as-built
configuration. The inspectors looked for equipment conditions and items that might degrade performance (hangers and supports were t
operable, housekeeping, etc.). The inspectors verified that valves, including instrumentation isolation valves, were in proper position, power was available, and valves were locked as appropriate. The inspectors compared both local and remote position indications.
l No violations or deviations were identified.
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7.
Review of Licensee Self-Assessment Capability (40500)
The inspector attended a meeting of the Nuclear Safety Review Committee (NSRC) on October 20, 1993. The meeting was held to discuss and approve the proposed Technical Specification (TS) change requests
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related to replacement of the steam generators.
Engineering provided a
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presentation of the affected TS changes and the evaluations that provided the bases for the proposed changes.
The presentation included a good mixture of background material and technical details to provide a good understanding of the issues related to the.TS changes. The
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review.of the TS changes were resolved during the presentation. The inspector considered that the extent of review provided by the NSRC for this proposed TS change request exceeded the requirements in the administrative controls section of TS.
In response to an NRC survey, the inspectors reviewed the licensee's implementation of the Independent Safety Engineering Group (ISEG). The requirements for ISEG activities are delineated in TS 6.2.3.
The function of ISEG is to examine operating characteristics, NRC
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issuances, industry advisories, LERs and other. sources of plant design and operating information which may indicate areas for improving plant safety. A minimum of five multi-disciplined and dedicated engineers or appropriate specialists is specified by TS 6.2.3.3 for ISEG composition. The TS also requires that ISEG make detailed recommendations for improving plant safety to the General Manager, Nuclear Safety.
The inspectors reviewed procedures and records, and conducted interviews with appropriate personnel to verify that all of the above requirements were being met. Five engineers and a supervisor perform the ISEG independent verifications.
ISEG is part of the Quality Systems organization and reports to the Manager of Quality Systems who in turns reports to the General Manager, Nuclear Safety. While-reviewing procedures, the inspector noted that two recent ISEG related guidance instructions for reactor trip safety reviews and outage safety reviews were issued. Detailed instructions were provided on the various review attributes to ensure consistency for different
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individuals performing the reviews. The inspectors were particularly impressed with content of Al-600, ISEG Outage Safety Review Guidelines, which thoroughly addressed the areas of decay heat removal capability, inventory control, power availability, reactivity control and'
containment integrity.
The results of ISEG activities are documented in monthly progress reports or special safety review reports. Adequate information was contained in the reports reviewed by the inspector to~ understand ISEG initiatives and recommendations for improving plant safety. The
inspector verified that ISEG was on distribution for most NRC issuances and other sources of operating experience information which may be applicable to the plant. One exception to ISEG receiving NRC issuances for review involved NRC Generic Letters (GL). The ISEG files.did not
contain a category for GLs.
It appeared that ISEG does not programmatically review GLs in a manner similar to NRC Bulletins and
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Information Notices. The inspector was showed some documented reviews of technical subjects discussed-in previous GLs. However, in response to the inspector's request for reviews associated with 1992 and 1993 GLs, the licensee did not have documentation available to show that all
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applicable items had been reviewed.
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i While reviewing ISEG files for 1992 and 1993 NRC Information Notices-i (IN), the inspector noted that several IN reviews were not included in the files.
The inspector was informed that some ins were not
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applicable to the plant and that some ins had not been processed and distributed to ISEG yet, however, several ins which the inspector considered important for review were not documented by ISEG. The inspector could not determine if ISEG had reviewed the issues-identified in these ins.
Examples of ins with no documented reviews were 92-07, Rapid Flow-Induced Erosion / Corrosion of Feedwater Piping; 92-30, Falsification of Records; 92-64, Nozzle Ring Settings on Low Pressure Water-Relief Valves; and 93-32, Nonconservative Inputs for Bcron Dilution Event Analysis. The licensee informed the inspector that they are continuing their records search to determine if these issues were previously reviewed by ISEG and that they will review their process for ISEG involvement with GLs.
The inspector will followup on these items after the licensee completes their review.
During review of the monthly progress reports for 1993, the inspector noted that the number of ISEG open items has decreased.
In January, 18 open items existed while in October the number was 12.
Efforts were given to close the older open items. The two remaining 1988 open items have been addressed and are awaiting a minor modification and an engineering evaluation to close out the items.
The licensee appears to be implementing the ISEG functions; however, a weakness in the documentation and filing of ISEG reviews was identified. Additional inspector followup will be provided for some important ins to determine if the reviews were not performed or if the document was incomplete.
ISEG has issued comprehensive guidance for some of their routine activities.
8.
Review of Licensee's 10 CFR 50.59 Program The inspector conducted a review of the licensee's program for determining the acceptability of changes, tests, and experiments under-the provisions of 10 CFR 50.59. The review of the licensee's program included an examination of the procedures and controls associated with the 10 CFR 50.59 program, a review of the training records associated with the 10 CFR 50.59 program, a review of several packages for completeness and accuracy, and a detailed examination of a sample of changes (MRF) made under the provisions of 10 CFR 50.59.
Formal guidance for implementing the requirements of 10 CFR 50.59 at Summer Station has been established in Station Administrative Procedure SAP-107. This procedure contains guidance for determining whether 10 CFR 50.59 app'.ies, and whether an unreviewed safety question is involved. Tha inspector determined that adherence to SAP-107 will ensure that all changes, tests, and experiments are evaluated for 10 CFR 50.59 applicability, and that safety evaluations are performed when appropriate. The inspector also determined that adherence to the procedure will also ensure that independent reviews are performed on ell evaluations of changes, tests, and experiments.
The inspector verified that training and qualification standards have been established for personnel who prepare, review, or approve 10 CFR
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50.59 packages. A formal procedure for qualification of individuals to
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perform 10 CFR 50.59 reviews is in place. The licensee maintains records of individuals that have successfully completed formal.10 CFR.
50.59 training. The inspector reviewed a list of 22 lead engineers on 10 CFR.50.59 packages, the date the packages were prepared, and the date the lead engineer completed formal training. No discrepancies
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were noted.
Twenty 10 CFR 50.59 packages were reviewed for completeness and
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accuracy. The inspector found the licansee's procedure for determining ~
10 CFR 50.59 applicability to be acceptable.
In addition, for the
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packages reviewed by the inspector, no deficiencies in the area of-determining whether or not a safety evaluation should have been
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performed were noted. The inspector performed a detailed review of the 10 CFR 50.59 evaluations for four MRFs. The inspector found that the safety evaluations were sufficiently detailed, and that the conclusions
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were logically supported.
The licensee has an effective program for implementing the requirements of 10 CFR 50.59.
Individuals performing the reviews were adequately trained. The review packages contained sufficient information to i
support the conclusions and bases of the reviews.
9.
Exit Interview (30703)
The inspection scope and findings were summarized on November 23, 1993, with those persons indicated in paragraph 1.
The inspectors described
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the areas inspected and discussed the inspection findings.
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 inspection.
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10.
Acronyms and Initialisms
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AI Administrative Instruction
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ECCS Emergency Core Cooling System
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EDG Emergency Diesel Generator ESF Engineered Safety Feature
GL Generic Letter HEPA High Efficiency Particulate IN Information Notice i
ISEG Independent Safety Engineering Group K eff K Effective
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LER Licensee Event Report LOCA Loss of Coolant Accident
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MRF Modification Request form MWR
. Maintenance Work Request NRC Nuclear Regulatory Commission NRR Nuclear Reactor Regulation NSRC Nuclear Safety Review Committee
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PMTS Preventive Maintenance Task Sheet i
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k PSIG Pounds Per Square Inch Gauge QC Quality Control
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RB Reactor Building l
RCS Reactor Coolant System RWP Radiation Work Permit i
SAP Station Administrative Procedure SFP Spent Fuel Pool SPR Special Report l
STP Surveillance Test Procedure
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TS Technical Specification
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