IR 05000395/1996015

Insp Rept 50-395/96-15 on 961229-970208.Violations Noted. Major Areas Inspected:Operations,Maintenance,Engineering & Plant Support

ML20147G316
Person / Time
Site:	Summer
Issue date:	03/10/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20147G263	List: IR 05000395/1996015 ML20147G258 ML20147G298
References
50-395-96-15, NUDOCS 9703280081
Download: ML20147G316 (34)

Text

U. S. NUCLEAR REGULATORY COMMISSION

REGION II

Docket No.: 50 395 License No.: NPF-12 Report No.: 50-395/96-15 Licensee: South Carolina Electric & Gas (SCE&G)

Facility: Virgil C. Summer Nuclear Station Location: P. O. Box 88 Jenkinsville, SC 29065 Dates: December 29, 1996 - February 8, 1997 Inspectors: B. Bonser, Senior Resident Inspector T. Farnholtz, Resident Inspector D. Jones, Reactor Inspector, RII (Sections R1.1, R1.2, R7.1, and R8.1)

Approved by: G. Belisle, Chief, Reactor Projects Branch 5 Division of Reactor Projects l

l

!

i l

i ENCLOSURE 2 l

9703280081 970310 PDR ADOCK 05000395 G PDR I

.- . . . - - - -- - --- - - . . - _ - _ _ - _ .

I

,

!

I l

EXECliflVE SUPMARY l

, V. C. Summer Nuclear Station j NRC Inspection Report 50 395/96 15 i i i

This integrated inspection included aspects of licensee operations.

maintenance, engineering, and plant support. The report covers a 6 week period of resident iropection

in addition, it includes the results of an

announced inspection by a regional reactor inspector, k rations

'

. In general, the conduct of operations was professional and I safety conscious (Section 01.1).

'

. Control room and building operators demonstrated good plant knowledge i and awareness. Operator resprnse to control room annunciators met j

management's standards (Section 01.2).

I . Control room shift turnovers and shift briefings were being conducted j adequately and in accordance with procedures (Section 01.3).

,

l . The licensee was maintaining adequate configuration control during i surveillance testing that renders equipment inoperable although the entry into Technical Specification (TS) Limiting Condition for Operation

(LCOs) is not declared and documented (Section 01.4).

!' . A walkdown of the emergency diesel generator air start system, the

! Emergency Feedwater System, and the High Head Safety Injection System

identified no discrepancies (Sections 02.1 and 02.2).

. A Non cited Violation (NCV) was identified concerning the failure to adhere to the procedural requirements for the replacement of the B

'

reactor trip bypass breaker and starting a charging pum). The starting !

of the A charging pump for post maintenance testing wit 1out first i establishing Component Cooling Water (CCW) flow demonstrated a lack of !

, self checking and attention to detail while performing an important '

j plant evolution (Sections 04.1 and 04.2).

! . The licensee's locked valve program was being administered i 1 appropriately. A procedural weakness was identified regarding the lack

,

of a requirement to compare the recorded serial number with that of the l old locking device prior to its removal (Section 06.1).

. .

! . A Quality Assurance (QA) audit of the corcactive action program was l

'

.

thorough and beneficial. The audit gave the plant substantive feedback l on the deficiency reporting program. The inspectors also concluded that l holding the QA entrance and exit meetings at the morning plan of the day

meetings had increased QA visibility and was also resulting in greater i l management involvement prior to audits and at the QA exit meetings ,

! (Section 07.1). '

i

..

_ __ _. _ . ____ _ . _ _ _ _ _ _.. _ . _ - . __ _ _ . _ . _ ___

i l 2

.

4

. The licensee was using longstanding Removal and Restorations (R&R)

3 sheets in the R&R log book to track equipment that had no current use but had not been abandoned. Since there was not a system to track this

'

equipment these items remained in the R&R log book to maintain an awareness of the status (Section 08.1).

$ e A violation was identified for not performing a Technical Specification i

'

surveillance to verify Reactor Building penetrations were closed or l capable of being closed by an automatic signal prior to a core '

i alteration (Section 08.2).

.

Maintenance s

. Observed maintenance activities were generally performed in a professional manner using the aapropriate procedures. A lack of

attention to detail was noted w1en technicians were inspecting the upper j valve train area of a diesel engine (Section M1.1).

e Observation of a Reactor Coolant System filter replacement found the d

work performed to be professional and thorough (Section M1.2).

i . The Minor Maintenance Program was effective in reducing the number of j work orders that had to be planned. Work was only being performed on i

non nuclear safety equipment and system engineers were reviewing

completed work documentation when applicable (Section M1.3).

. Observed surveillance testing was performed in an acceptable manner i

using appropriate procedures and techniques (Section M2.1).

l

. The reactor engineer conducting a core flux map was knowledgeable of the

) flux mapping system its operation, the core performance data gathered and its use. The flux mapping system was in a degraded condition making it difficult to obtain core data for the analysis of core performance (Section M2.2).

l

. A violation was identified for several missed slave relay surveillance tests on the emergency feedwater pumps. The inspectors concluded that although this issue was licensee identified, the licensee had missed l many opportunities to identify and correct these surveillance tracking daficiencies (Section M8.6).

Enaineerina e System engineers were knowledgeable of the High Head Safety Injection System and were monitoring the system status adequately (Section E1.1).

• Licensee efforts in resmnse to Generic Letter 96 06 to identify reactor building penetrations w1ich may be subject to overpressurization during some accident conditions were effective. The interim actions taken to place these penetrations in a less suscep ible condition were well conducted and documented (Section E2.1).

_

. _ . _ - ._ _ _

_ . . . - - . . _ - - _ - . . - _ . _- . . _ . - _ _ . _ _ _ _ _ _. _ ._- _ i F

Plant Support

. The licensee was properly monitoring and controlling personnel radiation !

exposure and posting area radiological conditions in accordance with l Station Administrative Procedure (SAP) 500, Health Physics Manual, and !

10 CFR Part 20 (Section R1.1).  !

e The licensee was closely monitoring collective and individual radiation dose exposure and was meeting established As Low As Reasonably Achievable (ALARA) goals and occupational dose limits (Section R1.2). ,

. The onsite oil analysis laboratory facilities were being maintained and administered appropriately. The technician was very knowledgeable of the facilities and procedures (Section R2.1).

'

• The respiratory arotection program was being administered properly with a good level of (nowledge and understanding on the part of the technicians (Section R5.1). .

. The licensee had implemented an effective program of audits and reviews of their radiation protection program (Section R7.1).

. An additional example of failure to follow contamination control procedures for unconditional release of material from the radiological controlled area was identified by the licensee prior to completion of-corrective actions for a previously issued NCV (Section R8.1).

. The licensee was maintaining the emergency facilities in a state of readiness. The emergency information system should be an enhancement to the transfer of information during an emergency (Section P2.1).

. Security activities observed during the conduct of tours and observation of plant activities were good (Section S1.1).

. Fire watches were being performed as arescribed and the fire technicians were knowledgeable of their fire watc1 responsibilities and adequately monitoring personnel performing the fire watches (Section F1.1). l J

Report Details Summary of Plant Status i

Unit 1 began this inspection period at full power. Power was reduced to 95 percent on January 5 for feedwater booster pump repairs. The plant returned j to full power on January 9 and remained at full power through the end of the l inspection perio , Doerations 01 Conduct of Operations 01.1 General Comments (717011 Using Inspection Procedure 71707, the inspectors conducted frequent reviews of ongoing plant operations. In general, the conduct of operations was professional and safety conscious. Specific events and noteworthy observations are detailed in the sections belo .2 Observation of Control Room Activities and Operator Rounds Insoection Scoce The inspectors reviewed control room activities and observed operator rounds during the inspection perio Observations and Findinas On January 19, the inspectors observed the night shift auxiliary building u)per operator during normal shift rounds. The inspectors observed tie operator taking computerized logs, and inspecting the status and condition of equipment. The inspectors also questioned the operator on several items during the course of the rounds. The operator was knowledgeable and performed a thorough jo The inspectors observed the auxiliary building upper operator place the Chemical and Volume Control System (CVCS) cation demineralizer in service, establish a 60 gpm flow through the demineralizer, and remove the demineralizer from service one hour later. The operator performed both evolutions in accordance with the System Operating Procedure (SOP),

S0P 102, Chemical and Volume Control System, Revision 1 On January 16, the inspectors observed operators use SOP-102 Chemical and Volume Control System, Revision 15,Section I, Replacing The Reactor Coolant Filter. Danger tags were hung correctly to isolate the filte On January 30, the inspectors observed the night shift intermediate building operator during normal shift rounds. The inspectors observed the operator taking computerized logs, and inspecting the status and condition of ecuipment. The inspectors also questioned the operator on several items curing the course of the rounds. The operator was knowledgeable and performed a thorough jo . -- - . - . -- - --_ - - -.-.- .- - -

'

!

2 ,

On January 31, during the restoration from Solid State Protection System (SSPS) testing, the ins >ectors observed an operator rack out the reactor

'

trip bypass breaker. T1e bypass breaker was racked out in accordance with SOP 313, Local Switchgear Breaker Operations, Revision 2 Section

D. Reactor Trip Bypass Breaker Operations.

In addition, the inspectors routinely observed control room operator's 3 response to annunciators. The licensee's Operations Management

'

Standard, OS 001, Communication, Revision 2. states that as annunciators alarm in the control room the Reactor Operator is expected to inform the

Control Room Supervisor of the annunciator, whether it is an expected or unexpected condition, and refer to the annunciator response procedure to

,

ensure follow up actions are completed. The inspectors found that

, normally, operator response was in accordance with the management standard. In one instance, the Shift Supervisor (SS) was observed

responding to an annunciator prior to being informed by the operator of

? the alarm, Conclusions

The inspectors concluded that overall control room and building ,

operators demonstrated good plant knowledge and awarenes Procedures were being used during plant evolutions. Operator response to control-

-

room annunciators met management's-standards.

01.3 Shift Turnover i

2 Insoection Scooe (71707)

'

The inspectors throughout the inspection period frequently observed shift turnover in the control room and the shift briefing by the

'

oncoming SS for day and evening shifts.

! Observations and Findinas  !

The inspectors throughout the inspection period frequently observed ,

shift turnover in the control room and the shift briefing by the l oncoming SS for day and evening shifts. The insaectors found that shift i turnovers were being performed in accordance wit 1 the procedural guidance in Station Administrative Procedure SAP 200, Conduct of Operations, Revision 7. The inspectors observed that both the S5

'

briefing and the individual shift turmvers were reviewing plant status,

,

upcoming evolutions, planned tests, major maintenance work activities, j and other important evo~lutions. The inspectors observed that shift- ,

relief checklists were being complete I a

, Conclusions

i The inspectors concluded that control room shift turnovers and shift j

. briefings were being conducted adequately and in accordance with

,

procedures.

!  ;

f

=x, - m

01.4 Declaration of InoDerability Durina Surveillances Tests Inspection Scope (71707)

The inspectors reviewed the licensee's practice of not declaring equipment inoperable during surveillance testing that renders equipment unable to perform its intended safety functio Observations and Findinas During a control room review of operating logs the inspectors identified that during the conduct of routine surveillance procedures that render equipment inoperable, the TS LCOs were not logged as being entered nor was a Removal and Restoration (R&R) checksheet prepared to indicate the system was inoperable. The inspectors reviewed licensee guidance on this issue and found that SAP-205, Status Control and Removal and Restoration, Revision 8, states that an R&R checksheet is not required when equipment is being tested under the surveillance testing progra Operability of the system is not addresse The inspectors reviewed this issue with the licensee and found that the licensee recognized that during the conduct of many surveillance tests, systems will-not perform their intended safety function. The licensee stated that the logging of the surveillance test in the Control Room Supervisor's log was adequate tracking. If a surveillance test continues over a shift change, then an R&R checklist is normally prepared. The licensee also stated that configuration control of the system being tested is tracked and controlled by the surveillance procedure. The licensee also adheres to train related maintenance weeks which control equipment taken out of service for maintenance and testing. Train related surveillance procedures are consistently performed during their train related wee It has been the position of the NRC that any surveillance or maintenance activity which renders equipment unable to perform its design function should result in the equipment being declared inoperable and the licensee entering the applicable TS Action statements. This is consistent with the definition of operability in the T The inspectors concluded that although the licensee does not declare entry in to a TS LCO and document that equipment is inoperable during surveillance testing, the licensee recognizes that equipment undergoing testing may not perform its intended safety function and that the redundant train of equipment must be operable. In addition, the inspectors concluded that the licensee was maintaining adecuate configuration control during the conduct of these tests. Fowever, the formal controls used when documenting entry into an R&R are not used for the verification of opposite train component operabilit l

i

,

.. . - - . .. _- - . - - - - _ - . _ . . - - . - _ _ - - _ - ..

!

i

'

,

.

.

4-l Conclusions

l The inspectors concluded that the licensee was maintaining adequate l

configuration control during surveillance testing that renders equipment l

inoperable although the entry into TS LCOs is not declared and j documented.

l 02 Operational Status of Facilities and Equipment j

02.1 Enaineered Safety Feature System Walkdown (71707)  !

) l l The inspectors performed a walkdown of the Emergency Diesel Generator l Air Start System and the Emergency Feedwater System. No discrepancies were identifie .2 Enaineered Safety Feature System Walkdown (71707) Insoection SCoDe (71707)

A detailed walkdown and review of the High Head Safety Injection (SI)

System was performed.

. Observations and Findinas I

The ins)ectors performed a detailed review and system walkdown of the l j accessi]le portions of the High Head SI System. All equipment was found 1

,

'

in the expected configuration. Several of the system components were located in infrequently traveled areas of the plant. The inspectors observed that material condition and housekeeping were being maintained at good levels in all areas. Where discrepancies were noted, work i orders had been assigned. The inspectors also observed pump standby and

!

o>erating conditions, and general material conditions in the Centrifugal

, Clarging Pumps (CCP) rooms. A review of the SOPS and plant drawings indicated that they matched and reflected plant configuration.

I

'

The inspectors also reviewed portions of the Final Safety Analysis Report (FSAR). The inspectors identified one discrepancy during this review. Section 6.3.2.2.4.2. Centrifugal Charging Pumps, stated that i t

these pumps deliver flow through the Boron Injection Tank (BIT) to the !

Reactor Coolant System (RCS). The BIT has been removed from the piping i i system. The licensee had previously identified this discrepancy as part i of their continuing FSAR review. The FSAR will be revised to correct i this statemen Conclusions i

'

The inspectors concluded from this system review that the High Head SI I 1 System was properly aligned and in an adequate state of readiness. No i

'

discrepancies were identifie l

<

,

l l

)

04 Operator Knowledge and Performance 04.1 Reactor Trio Bvoass Breaker Positionina a. Inspection Scope (71707)

The ins >ectors reviewed the circumstances surrounding a reactor trip bypass areaker which was found to be in a position other than expected while perforiaing a surveillance tes b. Observations and Findinas On December 27, 1996, while performing Surveillance Test Procedure (STP)-345.074, Solid State Protection System Actuation Logic and Master Relay Test for Train B, Revision 7, it was observed by the technicians that the B reactor trip bypass breaker was in the TEST position and the 4 springs were charged. The ex)ected >osition of this breaker at this l time was for it to be in the )ISCONNECT position with the springs l discharged. The licensee generated a Condition Evaluation Report (CER 96 0502) to document this conditio A records review revealed that this surveillance test was last performed on the B train on November 1, 1996. The breaker was re) laced on i December 3, 1996, as a routine task under STP-506.009, Teactor Trip I Breaker Testing, Revision 13. Since this breaker is normally left in !

the racked out position, it is considered a skill of-the craft task for electrical maintenance personnel to remove the old breaker and install a replacement breaker in the cubicle. The replacement breaker was to be left in the DISCONNECT position by o Local Switchgear Breaker Operations,perations personnel Revision 1. The licenseeusing S0P 313 determined that the breaker was most likely left in the ina)propriate condition during the breaker replacement operation on Decem>er Also, it was determined that the as-found condition of this breaker would not have prevented a reactor trip or otherwise interfere with any reactor safety system. The inspectors agreed with this conclusion. The  ;

licensee revised the associated procedures to clarify the condition that 1 the breaker should be left in following breaker replacemen The failure to restore the B reactor trip bypass breaker to its proper, i racked out position is identified as a violation. This licensee identified violation is being treated as an NCV consistent with Section VII.B.1 of the NRC Enforcement Policy. This is identified as the first example of NCV 50 395/96015 0 c. Conclusions An NCV was identified concerning the failure to adhere to procedural requirements for the replacement of the B reactor trip bypass breake l

- --- -- - - . - - _- . .- -- .. = - -_.

I

'

,

04.2 Charaina Pumo 0Derated Without CCW

, a. InsDection ScoDe (71707)

!

The inspectors reviewed an event in which the A train CCP was operated

, for approximately one minute without CCW.

l b. Observations and Findinas

On January 27, the A train CCP was operated for approximately one minute

without CCW. CCW supplies cooling to the CCP lube oil coolers. The A

'

-

CCP had been taken out of service for scheduled maintenance on the morning of January 27. During the afternoon, the pump was restored and running the pump for mst maintenance testing was necessary to declare the pump operable. T1e pump was started at about 4:40 p.m. About one minute later the SS observed that the A CCW Jump was not running and ordered the operator to secure the A CCP. T1e pump was checked by the 1 building operator with no problems noted and the test was completed.

Operations contacted Systems Engineering for a review of the potential

,

adverse affects of operating the CCP without CCW cooling for about one i minute.

I Since the pump had been removed from service for maintenance, the lube

. oil temperature had cooled to an ambient temperature of approximately 75 degreer F. The lube oil temperature is normally kept warmer by the operation of the auxiliary oil pump. During the one minute CCP

!

'

operation without CCW the operator observed the lube oil temperature to remain unchanged. The system engineer reviewed this information and

. concluded that there had been no adverse effects on the A CC The licensee reported that the operator had started the CCP without

-

referring to the applicable system omrating procedure, SOP 102, Chemical and Volume Control System. Revision 15. The supervisor also failed to ensure that the operator used the procedure. This event was ,

similar to an event on August 25, 1996, when the C CCP was started l without CCW flow. In the August 1996 event the S0P was used but the

'

initial conditions for starting a CCP were in another section of the procedure and not checked. Following the August 1996 event, the licensee revised 50P 102 and made establishing CCW flow prior to CCP pump start a procedural step rather than an initial condition in another part of the 50 The inspectors discussed corrective actions for this event with licensee management. The corrective actions included: a change in the communication standard to include verification of procedure use by supervisors: the operators during this event addressing the lessons learned with their counterparts: and, implementation of a peer check program for operation The inspectors concluded that the starting of the A CCP for post maintenance testing without first establishing CCW flow demonstrated a lack of self-checking and attention to detail while performing an i

!

!

i

im>ortant plant evolution. This failure to use the 50P to start the A CC) is identified as a violation. This licensee identified violation is being treated as an NCV consistent with Section VII.B.1 of the NRC <

Enforcement Policy. This is identified as a second example of NCV !

50 395/96015 0 !

!

c. Conclusions l An NCV was identified for a failure to adhere to procedural requirements !

when starting a charging pump. The inspectors concluded that the l starting of the A CCP for post maintenance testing without first 1 establishing CCW flow demonstrated a lack of self-checking and attention to detail while performing an important plant evolution.

06 Operations Organization and Administration 06.1 Locked Valve Proaram Review j a. Inspection Scope (71707)

i'

The inspectors conducted an independent review of the licensee's locked valve program as described in Operations Administrative Procedure i (0AP)-106.3, Locked Valve Program, Revision ;

b. 0 A ervations and Findinas K The licensee's locked valve program is used to administratively control valves and other components that are required to be locked in positio The controlling procedure, 0AP-106.3, Attachment I, contained a listing of all valves and components required to be locked, the location, the required position, and a space for the serial number of the locking device. Attachment II of 0AP-106.3 is used when operating a locked component and Attachment III is used when performing the required semi-annual locked component audi The inspecton reviewed the list of locked components which is located in the control room. This list contains the serial number of the locking device for each component. The inspectors selected at random several locked components and independently verified the position and locking device serial number to ensure that it matched the list. No discrepancies were identified. 0AP-106.3 requires that a semi-annual locked component audit be performed. The inspectors reviewed the last such audit which was completed on November 22, 199 Several minor discrepancies were identified during this audit and were corrected as 4 required by Section 6.4 of 0AP-10 The inspectors concluded that the locked valve program was being administered as required by procedure. However, one procedural weakness was identified by the inspectors. Section 6.2 is used to change the position of a locked component. Step 6.2.c requires that the serial nuecer of the old locking device be recorded on Attachment II from Attachment I. Step 6.2.e.1 states to remove the old locking device from

. _ . _ _ _ __ . _- . _ ._- _ . -_ .._ _

I the component. There is no requirement to compare the serial number of the old locking device to the number that was recorded on Attachment II.

>

Ensuring that these two numbers were identical would provide added ,

confidence that the correct locking device was being removed and that '

-

the correct component was being repositioned. The licensee indicated -

that a procedure revision would be made to add this requirement to

0AP 10 l i

i Conclusions

The licensee's locked valve program was being administered appropriately. A procedural weakness was identified regarding the lack of a requirement to compare the recorded serial number with that of the

, old locking device prior to its remova ;

07 Quality Assurance in Operations

07.1 Licensee Self-Assessment Activities

!

j Inspection n Scope (71707. 40500)

i The inspectors evaluated licensee self assessment activities by i i attending a Quality Assurance (QA) exit meeting and entrance meeting Observations and Findinas

!

The inspectors attended a QA exit meeting on January 8, conducted after

the morning plan-of the day meeting, that summarized results from an audit of the licensee's corrective action programs. The audit reviewed I the licensee's Non Conformance Notice (NCN) and CER programs. There !

were no significant issues identified with the NCN program. The CER !

program is relatively new and still evolving. The audit identified i several issue ,

The current CER program relies on the manager of each group to disposition and track the CERs associated with that group. The audit found that all groups are not always tracking the CERs from receipt to closure. There were also cases identified where the Cause & Corrective Action Forms were not being completed or not being completed adequatel Other examples were identified where either a CER was closed prior to completion or a CER was not dispositione The inspectors attended QA entrance meetings on January 14 and February 7. The purpose of the audit beginning on January 14 was to review the Emergency Plan (EP). The purpose of the February 7 audit was to review Fire Protection, especially verification of corrective actions from the last QA audit. The entrance meetings were attended by the ;

appropriate managers and other personnel. Additional items that could be reviewed during the EP audit were also suggested at the entrance meetin !

_ _ _ _ - - . _ _ _ _ _ _ _ _ . _ ... __ ._ . _ _ _ _ . _ _ _ _ _ . .

$

!

I l

9 i The inspectors concluded that the QA audit of the corrective action

program was thorough and beneficial. The audit gave the )lant substantive feedback on the CER program. Also, holding t1e QA entrance

and exit meetings at the morning plan of the day meetings had increased

QA visibility and was also resulting in greater management involvement

.

prior to audits and at the QA exit meeting c. . Conclusions The inspectors concluded that the QA audit of the corrective action program was thorough and beneficial. The audit gave the plant

substantive feedback on the CER program. The inspectors also concluded

'

that holding the QA entrance and exit meetings at the morning plan of the day meetings had increased QA visibility and was also i resulting in greater management involvement prior to audits and at the QA exit meeting Miscellaneous Operations Issues (92901)

i 08.1 (Closed) Unresolved Item (URI) 50 395/96014 02: review of system status

!

and Removal and Restoration (R&R) log book. This URI was opened to i

review the status and disposition of three different components that had been in the R&R log book for several years. The inspectors reviewed the status of the B waste gas recombiner, the waste evaporator, and the pressurizer heaters with the system engineers.

The inspectors found that the B waste gas recombiner was last operated-1 in 1992. One operating recombiner was all that was necessary during 3 plant operation. Due to the time and difficulty involved in calibrating j recombiner instrumentation, only one recombiner was normally used during i an operating cycle. The inspectors found that the B recombiner was l ready to operate after the applicable surveillance requirements and

'

instrumentation calibrations were completed. The licensee stated the

! long term plan is now to periodically swap the recombiners (i.e., each

refueling cycle).

The inspectors found that the waste evaporator was originally planned to be part of the cement waste solidification process. The cement j solidification process was never approved for use. The licensee uses an

ion exchange method, the Duratek system, to clean up waste water before it is put into the waste monitor tanks and then released to the river.

, There is no near term use envisioned for the waste evaporator but it can

,

i be used if a use for it is identifie The three pressurizer heaters in the R&R log had been tagged out since

November, 1988. The ins)ectors found that due to the difficulty in

'

replacing the heaters, tie high dose rates that could be expected, and

difficult post maintenance testing, the licensee had no current plan to j replace these heaters. There was also no history of pressurizer heater failures. There had been no heater failures since these three heaters

'

had failed. With the current heater capacity the licensee was exceeding i

,

_ _ - _- -- - , , _ . . -

. -. - - - - - - .- -- - -- .----=-.-

'$

J l i ,

10  :

the TS requirements. The inspectors concluded that the licensee was justified in not replacing these three inoperable heater The inspectors found that these longstanding R&Rs were tracking i equipment.that had no current use but had not been eL adoned. Since

there was no system to track this equipment, these items remained in the

>

R&R log book to maintain an awareness of the status. The 30 day R&R evaluations were documenting the work necessary to restore the equipment. The inspectors concluded that the R&R log was being used for an unintended purpose. The licensee agreed that they were not timely in

!

addressing these items in the R&R log. However, the licensee disagreed

with the inspectors' conclusion that the R&R log was being used for an i

unintended purpose.

08.2 (Closed) URI 50-395/96007-05

conducting core alteration without containment integrity. A detailed follow up review of this issue by the inspectors identified that on April 21, 1996, the licensee had aerformed functional testing of the refueling machine. The step in Fuel landling Procedure (FHP)-604, Functional Testing of Fuel Handling System Revision 10, Change A, which lowers the refueling machine gripper into ,

the core had not been performed. This step of the procedure was !

performed on April 22 at about 3:30 a.m. The inspectors reviewed the completed Test Data Sheet for STP 110.001, Pre Core Alterations Verifications. Revision 5, and found that all Reactor Building j penetrations had been verified intact on April 22 at 10:30 a.m. The '

inspectors concluded that all Reactor Building penetrations were verified to be in their closed / isolated condition after performing the gripper testing on the refueling machine. Surveillance requirement ,

TS 4.9.4 requires that the penetrations be verified within 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> l prior to the start of core alteration l The NRC staff review of this issue concluded that since the Summer TS i definition of core alterations contains the language " movement or manipulation of any component" a literal interpretation would include lowering the fuel handling bridge gripper into the 3ressure vesse This NRC review concluded that the Summer TS are su) ject to literal inter)retation and therefore the refueling machine gripper manipulation must >e considered as a core alteration. The NRC review is included as Enclosure 3 to this report. The licensee had not performed TS 4. surveillance requirements before performing the refueling machine gripper manipulations on the fuel assembly in the reactor vessel. The inspectors concluded that the safety significance of performing this core alteration without containment integrity verification was minima The failure to perform the TS 4.9.4 surveillance requirement is a VIO 50 395/96015-0 .3 (Closed) URI 50 395/96007-03: paint coat in containment does not meet a) plication specification. The ins >ectors reviewed ANSI N5.12 197 "3rotective Coatings (Paints) for tle Nuclear Industry," and ANSI N101.2-1972, " Protective Coatings (Paints) for Light Water Nuclear Reactor Containment Facilities" referred to in the licensee's 10 CFR Part 50.59 screening for applying a single coat of paint in containment. ,

I

From this review the inspectors found that these standards were intended to provide a common basis on which protective coatings (paint) for containment surfaces may be compared and selected by reproducible evaluation tests. The licensee has established that their paint vendor qualified the paint used in containment to these common standard II. Maintenance M1 Conduct of Maintenance M1.1 General Comments a. Inspection Scope (62707)

The inspectors observed all or portions of the following work activities:

. Maintenance Work Request (MWR) 94T3172, Repair Diesel Generator (DG) B Start Counte . Preventative Maintenance Task Sheet (PMTS) P0206564, Inspect for Broken Studs on DG B Fuel Injection Pump . PMTS P0206427. DG B Engine Quarterly Maintenanc . MWR 96I3192, Replace Relays K1 and K2 for the Up and Down Count to the Computer for Shutdown Bank . MWR 96T3395. Repair or Replace as Necessary XVG06057 20A HR, Reactor Building Back up Purge Line Isolation Valv b. Observations and Findinas The inspectors independently verified by visual inspection that there were no broken studs on the B DG fuel injection pumps during the i performance of PHTS P0206564. The work performed under this PHTS was !

properly conducte Part of the work associated with PMTS P0206427. DG B Engine Quarterly l Maintenance, included removing the covers from the top of each cylinder to expose the upper part of the valve train to allow the technicians to perform a visual inspection of this area to identify any abnormal conditions. The inspectors observed what appeared to be a loose clamp and rubber boot near the top of one pushrod on one cylinder. This was an abnormal condition which would not have interfered with the operation ,

of the engine dua to the design of the pushrod/ rocker arm interfac l However, the inspectors were concerned that the technicians did not observe this condition during the course of the maintenance. The inspectors attributed this to a lack of attention to detail

!

I i

!

- . The work associated with MWR 9613192 and MWR 96T3395 demonstrated a good level of knowledge and understanding on the part of the technician Conclusions The observed maintenance activities were generally performed in a professional manner using the appropriate procedures. The inspectors observed a lack of attention to detail when technicians were inspecting the upper valve train area of a diesel engine.

M1.2 Reactor Coolant Filter Replacement Insoection ScoDe (62707)

The inspectors observed an RCS filter replacemen Observations and Findinas On January 16, the inspectors observed mechanical maintenance technicians replace RCS filter XFL0009. This filter replacement was performed under work request 96H3030. The filter replacement was performed manually due to the filter dose rates being relatively lo This job is performed remotely when dose rates are high. When this job is performed manually mechanics in the filter cubicle manually remove the used filter cartridge, bag it, and replace it with a new filte The highly contaminated filter is then carried to a storage locatio The inspectors observed the Health Physics (HP) pre job briefing, verified that appropriate tools were used by the mechanics, verified the tag out to isolate the filter vessel was hung correctly, verified that adequate radiation control measures were implemented during the filter replacement, and that the highly contaminated filter was disposed of appropriately. The inspectors identified no concerns during the conduct of this maintenanc Conclusions The inspectors observation of the RCS filter replacement found the work performed to be professional and thoroug !

!

M1.3 Review of Minor Maintenance Proaram Inspection Scone (627071

'

The inspectors reviewed the licensee's Minor Maintenance Program as implemented in General Maintenance Procedure (GMP)-104.001, Minor Maintenance Program, Revision Observations and Findinas

'

The licensee's Minor Maintenance Program is patterned after industry guidelines. Minor maintenance is work that can be conducted without detailed written work instructions and without overall plant scheduling. 1

._. _ _ - _ . _ . _ _ _ . _ _ . _ _ _ . _ _ _ _ _ _ . . _ . _ . _ _ ,

1 ,

!

,

'

l Minor maintenance is performed on equipment designated as Non Nuclear i System (NNS) components, systems, and structures. The minor maintenance  !

procedure provides examples of work that is considered to be minor maintenance. Other maintenance can be determined to be minor maintenance by maintenance supervisors and if concurred on by the

, Operations Shift Supervisor.

'

The inspectors reviewed completed minor maintenance and found that minor maintenance was being performed on only NNS equipment. The work was

,

!

j evaluated in accordance with the checklist in GMP 104.001 and ap> roved

by the Operations Shift Supervisor. The inspectors found that t1e minor maintenance forms were appropriately designating job requirements and

.

!

post maintenance testing.

] l

Normally, the licensee enters a record of work performed in their i

'

computerized equipment history tracking system (CHAMPS). The inspectors  !

noted that minor maintenance records were stored in the minor  :

maintenance office and work performed had not been entered in this  !

tracking system. The licensee recognized that this was an area needing I i improvement. The inspectors found that minor maintenance was being  !

reviewed for M61ntenance Rule applicability and the work performed was l l reviewed by the system engineer when applicable.

l The inspectors also reviewed a QA surveillance of Minor Maintenance  !

j performed in July 1996. The QA review found that the overall program

appears to be successfully implemented. There were no discrepancies j noted.

The inspectors concluded that the Minor Maintenance Program was l

-

effective in reducing the number of work orders that had to be planned.

that work was only being performed on NNS equipment and that system j engineers were reviewing completed work documentation when applicabl ,

c. Conclusions The inspectors concluded that the Minor Maintenance Program was effective in reducing the number of work orders that had to be planned, i

that work was only being performed on NNS equipment and that system j engineers were reviewing completed work documentation when applicable, j M2 Maintenance and Material Condition of Facilities and Equipment M2.1 Surveillance Observation 4 Insoection Scope (61726)

The inspectors observed all or portions of the following surveillance tests:

<

. Surve111ance Test Procedure (STP) 106.001, Moveable Rod Insertion

-

Test. Revision 3.

. _ . - . . . _

,

- - - - . -- .___-. _-_- - .-.._ - -.-- - -.

.

14

. * STP-205.019, Charging / Safety Injection (SI) Pump A Monthly Vibration Checks, Revision 0.

,

• STP 345.037. Solid State Protection System (SSPS) Actuation Logic j and Master Relay Test for Train A. Revision 1 , Observations and Findinas

.

Section 6.3 and 6.5 of STP 106.001 was performed as a >ost maintenance '

test following the replacement of relays K1 and K2. T1e test results i

indicated that the plant computer and the group rod position indicators

matched.

l The vibration checks on the A charging /SI pump were performed with the

) ump running in a normal charging lineup. This was done because of a

) earing vibration which was observed to be in the alert range during

.

full flow pump testing performed during Refueling Outage 9. In a relief request dated November 20. 1996, the licensee committed to >erforming a

! monthly vibration test at reduced flow on this pump until t1e tenth

! refueling outage when full flow testing can be performed. The results

+

of this test indicated that all bearing vibrations were well within the acceptable range.

The inspectors observed good control and repeat backs by the Instrument and Control (I&C) technicians during the conduct of the SSPS procedure.

} Conclusions I

The observed surveillance testing was performed in an acceptable mar.ner

using appropriate procedures and techniques.

M2.2 Observation of Reactor Core Flux Manoino Surveillance l l Inspection Scope

.

The inspectors observed reactor engineering perform a flux map of the !

reactor cor !

.

t

'

, Observations and Findinos j On January 24. the inspectors observed reactor engineering perform a flux map of the reactor core in accordance with STP 212.001, Reactor

.! Core Flux Mapping, Revision 6. The purpose of the flux map is to obtain

! core data for the analysis of core power distributio !

l The inspectors observed that the movable incore detector system was in a

! degraded condition during the testing. Detector B could not be used and

no readings were taken in the B detector paths. Two flux maps on ,

detector E did not record and had to be reperformed. The test met the

, initial cor.dition requirements of at least 75 percent of the thimbles

available for flux mapping and a minimum of two thimbles per core i

l

_ . .

- .. - .- - - - . - - - .-- - - . - - - -

.

15  ;

quadrant. The reactor engineer submitted work requests to repair the

'

flux mapping syste Subsequent to this observation, the licensee determined that the flux mapping data taken with the E detector on the E drive was invalid and ,

could not be used. Since i.he E drive data could not be used this i reduced the number of ore locations to less than the minimum required.

'

The licensee subsequently re>erformed the entire test on January 30 and obtained sufficient data. Tw test on January 30 confirmed that the E :

) detector was not usable. Locations on the E drive were taken with the D ,

detector in the emergency mode of operation. The licensee initiated a

work order to re> air the E detector during the next shutdown of sufficient lengt1,  !

'

The inspectors concluded that the reactor engineer conducting the test was knowledgeable of the flux mapping system, its operation, the core performance data gathered and its use. The incore detector mapping ,

system was in a degraded condition making it difficult to obtain core data for the analysis of core performance.

$ c. Conclusions

The inspectors concluded that the reactor engineer conducting the core flux map was knowledgeable of the flux mapping system, its operation,

, the core performance data gathered and its use. The inspectors also concluded that the flux mapping system was in a degradec condition

.

making it difficult to obtain core data for the analysis of core

'

performanc MB Miscellaneous Maintenance Issues (92902)

M8.1 (Closed) Violation (VIO) 50 395/96005-01: TS leakage assessment progra ,

.

This violation was issued as a result of not recording the integrated ;

leakage assessments for the Spring 1993 and Fall 1994 refueling outages '

as required by General Test Procedure (GTP) 006, General Procedure for System Leakage Assessment, Revision 5. The licensees actions to correct this condition consisted of u) grading the tracking device from a Preventive Maintenance Task Sleet (green sheet) to a Surveillance Test

, Task Sheet (pink sheet). During the most recent surveillance period, the data was properly recorded on Attachment I of GTP 006.

!

M8.2 (Closed) Licensee Event Report (LER) 50 395/95004: missed surveillanc This LER involved the failure to include CCW system valves in the TS surveillance that verifies CCW valve positions every 31 days. This issue was reviewed and documented as an NCV in NRC Inspection Report No. 50 395/95 15. This LER is closed based on the review performed for the NCV on this issu ~

M8.3 (Closed) VIO 50-395/96005 04: failure to submit a required LER. This

, violation involved a failure to submit an LER when a condition

'

prohibited by the plant's TS was entered. The licensee submitted an LER

,

when the failure to meet this reporting requirement was identified. The

- . . -

--

- . - - - - - . . - - -- . - - -

.

I'

l

'

failure to submit an LER was due to an isolated instance of a misinterpretation of the reportable incident and the applicable i i reporting requirements. All subsequent LERs were submitted on time.

-

\

"

M8.4 LClosed) VIO 50 395/96005 02: draining of Spent Fuel Pool (SFP) due to inadequate corrective action. This item identified a failure to correct an identified valve leakage problem due to an inappropriately voided MWR which was initiated to repair the valve. This issue was reviewed in NRC i Inspection Report No. 50 395/96 11 and left open pending completion of the MWR to repair the valve. This MWR was completed on November 21, 1996. The licensee's trouble shooting determined that there was nothing i

wrong with the valve internals. The valve had not been fully closed 4 when it had previously leaked by its seat due to the orientation of the valve handwheel which made it difficult to manipulate. The licensee

, reoriented the handwheel and fully closed the valve. No valve leakage

was noted. The inspectors concluded that this maintenance had resolved

the leakage issue associated with this valve.

, M8.5 (Closed) LER 50 395/94006: reactor coolant system pressure boundary.

This issue involved a RCS pressure boundary leak in the C Reactor i e

Coolant Pump (RCP) seal injection line. The root cause evaluation for '

i this event concluded that the seal injection nozzle failed as a

'

consequence of possible defects in the root pass of the weld which were aggravated over time by intergranular stress corrosion. The licensee

, examined the weld to identify the extent of the failure. The defective i Sortions of the weld were removed and the joint was re welded.

d Examinations of the new weld confirmed that repairs were satisfactory.

4 In April 1996, during Refueling Outage 9, the licensee examined the remaining eight seal injection nozzles. Indications were detected on i

five welds. The five nozzle assemblies were replaced. The inspectors observed defect removal, welding, and NDE activities associated with the nozzle replacements and examined the completed welds (see NRC Inspection

, Report No. 50 395/96 07).

.

1 M8.6 (Closed) URI 50-395/96014 03: missed TS surveillance test on the turbine driven emergency feedwater pum). The issue concerned missed TS surveillance requirements on t1e Emergency Feedwater (EFW) pumps. The j EFW pumps include two motor driven EFW pumps and a turbine driven EFW j pum i- On December 2,1996, plant personnel discovered that the portion of STP 220.002, Turbine Driven Emergency Feedwater Pump Test, which starts )

the pump from the train A SG low low actuation slave relay K634 had not i been performed within the interval specified by TS 3.3.2, Engineered

'

i l Safety Feature Actuation System Instrumentation. The TS Surveillance Requirement 4.3.2.1 (Table 4.3 2, Item 6b) requires a quarterly test to verify the operability of this slave relay. Review of the surveillance history identified that the test had last been performed on August 7, 1996. The next test was required to be performed no later than November 30,1996 (including the test frequency extension allowed under TS i

_ _ _ . _ _ _ - . _ _ _ _ _ - _ . . _-_ . __-

I

4.0.2). The required testing of the train A slave relay (K634) was ;

subsequently performed on December 2, 1996.

l The licensee reviewed all surveillance test procedures associated with the Inservice Testing (IST) Program to evaluate the potential for similar surveillance deficiencies. The results o' this review showed that only IST procedures associated with testing on the EFW i pumps had the potential for surveillance frequency errors. Only three procedures contained several surveillance requirements that i r were not individually tracked by the surveillance tracking syste i j The results of the licensee's review showed a high potential for missed I l surveillances requirements during the performance of the following two ;

l

'

EFW STP )

.

'

. STP 220.001A, Motor Driven Emergency Feedwater Pump and Valve Test. The procedure contains several surveillance requirements at monthly and quarterly intervals.

'

. STP 220.002, Turbine Driven Emergency Feedwater Pump Test. The procedure contains several surveillance requirements at monthly, quarterly and refueling interval A licensee review of the EFW surveillances from the present back to l Refueling Outage 8 (Fall of 1994) identified that an additional four surveillances were not performed within the interval specified by T On the missed surveillance tests the licensee took credit for the 25 percent maximum allowable extension allowed by TS 4.0.2:

. Motor driven EFW pump Train A SG Low Low Level Actuation Relay K633, missed its required quarterly surveillance test, STP 220.001A, Motor Driven Emergency Feedwater Pump and Valve Test (TS 4.3.2.1, Table 4.3 2 Item 6.b). Required testing was completed on January 3,1996, and was not completed again until July 16,1996. Total ela) sed time was 164 days (115 days is the ,

maximum limit including t1e TS 4.0.2 extension, 92 days is the '

time interval specified in the TS, 92 days X 1.25 = 115).

. Motor driven EFW pump Train B SG Low Low Level Actuation Relay !

K633, missed its required quarterly surveillance test, )

TiP-220.001A (TS 4.3.2.1, b ble 4.3 2 Item 6.b). Required testing

'

ras completed on July 5. T.,94, and was not completed again until January 17, 1995. The total elapsed time was 194 day . Motor driven EFW pump Train A SG Low Low Level Actuation Relay K633, missed its required quarterly surveillance test, l STP-220.001A (TS 4.3.2.1. Table 4.3 2 Item 6.b) Recuired testing )

l was completed on July 19, 1994, and was not completec again until January 10, 1995. The total elapsed time was 175 day l

* Turbine driven EFW pump Train B SG Low-Low Level Actuation Relay l K634, missed its required quarterly surveillance test, STP 220.002 l

._ _ ._. _- - - . _ . ..

t

(TS 4.3.2.1. Table 4.3 2 Item 6.b). Required testing was l completed on June 28, 1994, and was not completed again until December 21, 1994. The total elapsed time was 176 day The EFW surveillance procedures contain multiple monthly / quarterly testing requirements. These multiple tasks were not individually l tracked in the licensee's surveillance tracking system. It was left up l

to the individuals performing the surveillance test to determine which ,

! of the requirements needed to be performed each month. The failure to l l track the specific surveillance requirements contained in these l l procedures resulted in exceeding the test interval l The results of all the missed surveillance tests were satisfactory when they were performed. The inspectors concluded that equipment operability was maintained during the intervals the surveillances were missed. The inspectors also concluded that although this issue was licensee identified, the licensee had missed many opportunities to identify and correct these surveillance tracking deficiencies. This failure to meet TS Surveillance Rsquirement 4.3.2.1 (Table 4.3-2, Item 6b) is identified as violation 50-395/96015 0 III. Enaineerina El Conduct of Engineering E1.1 Review of Hiah Head Safety In.iection System and Charaina Pumos a. Insoection Scope (37551)

The inspectors reviewed the A CCP and High Head SI System status with the system engineer following its operation without CCW. The inspectors also walked down the High Head SI System with the system enginee b. Observations and Findina l The inspectors reviewed the status of the A CCP with the system engineer and found that System Engineering was consulted when the pump was operated without CCW and the potential adverse effects had been evaluated. The inspectors also reviewed the SI system status with i regards to the Maintenance Rule. The charging system had been assigned (a)(1) status due to the higher than expected unavailability of the A CCP. The inspectors noted that the ) ump out of-service time had rarely caused train unavailability due to tie availability of a swing pum The licensee concluded that the accumulation of several maintenance tasks had caused the higher than expected unavailability of the A CC The licensee determined that there was not an equipment concern with the

! A CCP. Better coordination and planning of the maintenance could have l

reduced the out of service time. The inspectors agreed with the licensee's evaluation.

I

- - - - - , - -- -- . - - - -- ..

19

,

The inspectors also walked down the High Head SI System with the system engineer. The ins)ectors observed that the system engineer was knowledgeable of t1e system, ecuipment locations, and current issue In the less frequently travelec areas inspected during this walkdown, housekeeping and contamination control was good.

,

c. Conclusions The ins)ectors concluded that System Engineering was knowledgeable of the Hig1 Head SI System and was monitoring system status adequately.

.

E2 Engineering Support of Facilities and Equipment

E2.1 Reactor Buildina Penetrations

a. Inspection Scope (37551)

, The inspectors reviewed the licensee's efforts regarding NRC Generic i Letter (GL) 96-06 Assurance of Equipment Operability and Containment Integrity During Design Basis Accident Conditions, issued September 30,

,

199 b. Observations and Findinos

In response to NRC GL 96 06, the licensee identified five Reactor Building (RB) penetrations containing isolated piping sections which could be subject to overpressurization during accident conditions.

Specifically, the concern was that a trapped volume of fluid between the 1 inside and outside containment isolation valves could be heated

following certain postulated accidents which could cause an overpressure condition. The licensee was continuing to analyze these penetrations for susceptibility to this phenomenon but performed some interim actions to reduce the possibility of overpressurization. The following RB

penetrations were identified as being potentially susceptible to overpressurization:

. XRP0231. RB Demineralized Water Supply.

. XRP0404. Fire Service Supply Header to the R ;

j . XRP0419, Refueling Cavity Spent Fuel Purification Supply Heade l

. XRP0421, Spent Fuel Purification Header Refueling Cavity.

l . Fuel Transfer Tub l The actions associated with RB penetrations XRP0231, XRP0404 XRP0419, '

and XRP0421 consisted of draining the space between the inside and outside containment isolation valves and maintaining them in a drained '

condition. The fuel transfer tube gate valve (XVM 06737 SF) was repositioned 10 to 15 turns open to relieve the space between the gate

, valve and the blind flang The inspectors reviewed the 10 CFR 50.59 safety evaluation worksheets that were generated to evaluate these changes. The answers to all the questions on the screening sheet were "no" and adequate justification was included. There were no unreviewed safety questions identified. In addition, the inspectors reviewed the revised procedure (STP 115.001, Penetration Isolation Verification, Revision 12) which was used to drain the RB penetrations XRP0231, XRP0404, XRP0419, and XRP0421. The procedural guidance provided was adequate to ensure that the penetrations were drained and that they were left in an appropriate condition, c. Conclusions The licensee's efforts associated with GL 96 06 to identify RB penetrations which may be subject to overpressurization during some accident conditions were effective. The interim actions taken to place these penetrations in a less susceptible condition were well conducted and documente E7 Quality Assurance in Engineering Activities (37551)

E7.1 Review of Vodated Final Safety Analysis Report (UFSAR) Commitments A recent discovery of a licensee o mrating their facility in a manner contrary to the UFSAR description lighlighted the need for a special focused review that compared plant practices, procedures and/or parameters to the UFSAR description. While performing the inspections discussed in this report, the inspectors reviewed the applicable portions of the FSAR that related to the areas inspected. The inspectors identified one discrepancy during an ESF system review. FSAR Section 6.3.2.2.4.2. Centrifugal Charging Pumps, stated that these pumps deliver flow through the BIT to the RCS. The BIT ilas been removed from the piping system. An FSAR change request has been submitte I Plant Support R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 Occuoational Radiation Exposure Control Procram a. Inspection Scope (83750)

The inspectors reviewed implementation of selected elements of the licensee's radiation protection program pertaining to the requirements in 10 CFR 20 Subparts F G, and J for monitoring personnel radiation exposure, access controls to radiation areas, and posting radiation areas. The review included observation of radiological protection activities including pre work briefings, personnel monitoring, radiological postings, and verification of posted radiation dose rates within the Radiologically Controlled Area (RCA).

.

,

l

[

b. Observations and Findinas The inspectors conducted tours of the RCA and observed radiation i protection activities. Personnel preparing to enter the RCA were l

observed being briefed on the radiological conditions in the areas to be entered. The briefings were given by radiation control personnel before access was granted for entry into the RCA and covered the dosimetry and the protective clothing and equipment recuired by the Standing Radiation ,

Work Permit (SRWP) for the entry. The acministrative limits for the allowed dose and dose rate for the entry were emphasized during the briefings. The briefings provided thorough descriptions of the existing dose rates which could be encountered during the entry. The inspectors determined that personnel entering the RCA were adequately briefed on the radiological hazards which could be encountered while in the RCA and the radiological protective measures required to be taken during the entr The inspectors observed the use of personal radiation exposure monitoring devices by personnel entering and exiting the RC Thermoluminescent Dosimeters (TLDs) were used as the primary device for monitoring personnel radiation exposure. In addition, direct reading electronic dosimeters were used for monitoring the accumulated dose and the encountered dose rates during each RCA entry. The electronic dosimeters were set to alarm at administrative limits established for the specific SRWP under which the RCA entry was being made. As the individuals exited the RCA the accumulated dose and encountered dose rate information was transferred from the electronic dosimeters to the Computerized Exposure Nuclear Tracking System (CENTS) data base in order to track individual exposures. During tours of the RCA the inspectors noted that the required dosimetry was being properly worn by personnel when entering and while in the RCA. The inspectors also noted that personnel exiting the RCA routinely surveyed themselves for contamination using personal contamination monitors (PCMs).

During tours of the RCA the inspectors noted that general areas and individual rooms were properly posted for radiological condition ;

Posted survey maps were used to indicate dose rates end contamination l levels at sxcific locations within rooms. At the inspectors * request,

'

a licensee iP staff member performed surveys of doses rates in several l rooms and locations. The inspectors verified that the survey instrument i readings were consistent with the dose rates recorded on the posted j survey map c. Conclusions Based on the above reviews, it was concluded that the licensee was properly monitoring and controlling personnel radiation exposure and posting area radiological conditions in accordance with Station Administrative Procedure SAP 500, Health Physics Manual and 10 CFR i Part 20.

. _ _

22 l l

R1.2 As low As Reasonably Achievable (ALARA) Inspection Scope (83750)

The inspectors reviewed licensee records of personnel radiation exposure and discussed ALARA program details, implementation and goals with the

,

l licensee. The annual site collective dose and individual exposures were '

compared to licensee established ALARA goals and occupational dose limits, respectivel Observations and Findinas The licensee provided the inspectors with records of personnel radiatior exposure for Calendar Years (CY) 1994, 1995, and 1996. Those records indicated that the licensee had initially established an ALARA goal of 506 person-roentgen equivalent man (rem) for the 1994 site collective dose. That goal included a projected 360 person rem for the scheduled Steam Generator Replacement Project. After the actual exposure for that ,

project was determined to have been 224 person rem, the annual goal was '

reduced from the initial projection of 506 person-rem to 376 person-re The final collective dose for CY 1994 was 348 person rem. Only normal plant operations were scheduled for CY 1995 and therefore an ALARA goal of 10 person rem was established for that year. The final collective dose for CY 1995 was 9.7 person rem. The licensee established performance based ALARA goals for the CY 1996 Refueling Outage (RF0).

The criteria were: satisfactory - < 110 person rem, good - < 95 l person rem, and excellent - < 80 person rem. The actual exposure for I the RF0 was 89 person rem and that was much less than half of the exposure incurred during any of the 8 previous RFOs. The annual goal for the 1996 site collective dose was established at 117 person rem and the actual collective dose was 107 person rem. The next RF0 is scheduled for October 1997: therefore, the annual goal for the 1997 site coilective dose was established at 117 person rem. The licensee !

indicated that their overall objective is for their three year moving average of annual collective doses to be in the top quartile (when ranked in ascending order) of all PWRs. The licensee's three year l moving average annual collective doses for CYs 1994, 1995, and 1996 were 218, 212, and 155 3erson rem, respectively. Those values were not in ,

the top quartiles aut do indicate an obvious decreasing trend in overall )

personnel radiation ex)osure. The inspectors determined that the

'

licensee was meeting t7eir established ALARA goals for collective dos :

The licensee also provided the inspectors with data from the CENTS l

, pertaining to radiation exposure to individuals. Those data indicated i that the maximum individual exposures for CYs 1994, 1995, and 1996 were 1340, 223, and 828 mrem, respectively and well within the 5 rem limit for occupational dose as specified in 10 CFR 20.1201(a). l The inspectors also reviewed licensee records for Personnel Contamination Events (PCEs) and total contaminated area within the RC The licensee maintained logs which categorized PCEs as: Low Level Events

[ personnel contamination > 100 net counts per minute (ncpm) above m

i background and < 1000 ncpm]: skin contamination > 1000ncpm; and Discrete i Radioactive Particles > 1000 ncpm on skin or clothing. The licensee's .

records indicated that the total number of PCEs during CYs 1994, 1995, '

and 1996 were 341,11, and 245, respectively. The licensee's records ;

also indicated that, following the 1996 midyear RF0, the total :

contaminated floor space within the RCA (excluding the reactor building) r was approximately 4400 scuare feet, or 3.3 percent of the RCA total i floor space. By year enc the contaminated floor space was reduced to ;

2083 square feet, or 1.6 percen c. Conclusions Based on the above reviews and observations, the inspectors concluded that the licensee was closely monitoring collective and individual radiation dose exposure, and that the licensee was meeting established ALARA goals and occupational dose limit R2 Status of RP&C Facilities and Equipment R2.1 Chemistry Samolina Facilities a. Inspection ScoDe (71750)

The inspectors observed the activities associated with the oil analysis I laboratory facilities which is located onsite and performs oil analysis !

on safety and non safety-related equipment throughout the plan j b. Observations and Findinas The inspectors toured the oil analysis laboratory and observed the equipment available for use by the technician for different types of lubricating and fuel oil analysis. The equipment was in good condition and displayed current calibrations. General housekeeping was very good with appropriate precautions taken for spills and fire The technician responsible for conducting the analysis demonstrated a good level of knowledge and a thorough understanding of the primary governing procedure (Chemistry Procedure (CP)-400 Administrative Guidelines Procedure for the 011 Lab, Revision 16). The results of safety related oil analysis were entered into a computer data base to be tracked and trended. New oil received on site was analyzed to ensure that it meets the specifications prior to its use in plant equipmen c. Conclusions The onsite oil analysis laboratory facilities were being maintained and administered appropriately. The technician was very knowledgeable of the facilities and procedure j L

._

- .-. . _ --

s

'

R5 Staff Training and Qualification in RP&C RS.1 Resoiratory Protection Procram

-

a. Inspection Scooe (71750)

'

l The inspectors reviewed Health Physics Procedure (HPP)-163, Qualification Process for the Use of Respiratory Protection Equipmen Revision 7, and observed its implementation.

( Observations and Findinas i

During the inspection period, the inspectors renewed his respirator qualification in accordance with HPP 163. During this process, the

inspectors observed a good level of knowledge and understanding of the requirements on the part of the technicians performing the fit tes The equipment used was in good working order with current calibrations.

The procedure included sufficient detail and was complet c. Conclusions l The respiratory 3rotection program was being administered properly with

a good level of (nowledge and understanding on the part of the

-

technicians.

'

R7 Quality Assurance in RP&C Activities R7.1 Radiation Protection Proaram Audits and Aporaisals i a. Insoection Scope (83750)

i The inspectors reviewed reports for recent audits and appraisals of the licensce's radiation protection program. The scope and corrective actions were evaluated for consistency with the requirements for review of program content and implementation specified in 10 CFR 20.1101(c).

.

b. Observations and Findinas l The inspectors reviewed Sections 6.8.5 and 6.8.6 of SAP-500. Health

'

Physics Manual, and Sections 15.1, 15.2, and 15.3 of the Operational

. Quality Assurance Plan and determined that the licensee's audit program consisted of a combination of audits, surveillances, and

'

self assessments. The general intent of the audits, surveillances, and l self assessments was to evaluate program content and implementation,

, conformance with procedures, and detailed work practices, respectively.

'

The inspectors reviewed reports for five audits (0A AUD 95013, 96002, 96003, 96009, 96015), seven Surveillances (0A SUR 96057, 96078, 96091, !

!' 96105, 96107, 96131, 96143), and two recent self-assessments. From the i review of those reports the inspectors determined that the audits /surveillances/self assessments were thorough and well documented

, and the results were reported to appropriate levels of managemen '

Substantive issues were identified for corrective action and/or program !

4 l

,

,

- . - . - - - .-- - . _ - _ . - - - - - - - . . --.. -.

!

l

,

j 1 i

4 enhancements. Condition evaluation reports were issued to document and track completion of corrective actions for significant issue I During discussion of the audit program the licensee indicated that the i

, relevant sections of the Health Physics Manual were being revised to be !

,

editorially consistent with the guidance provided by the answer to <

! Question 118 in NUREG/CR 6204 " Questions and Answers Based on Revised !

10 CFR Part 20".

'

, Conclusions Based on the above reviews, it was concluded that the licensee had

implemented an effective program of audits and reviews of their I

radiation protection progra l

R8 Miscellaneous Radiological Protection and Chemistry Issues (92904) '

,

R8.1 Control of Contaminated Material Backaround As discussed in NRC Inspection Report No. 50 359/96011 an Unresolved

'

Item (URI), 50-395/96011-05, was identified regarding contaminated material found outside the RCA. That item was closed in Inspection

, Report No. 50-359/96013 and changed to NCV 50-395/96013 04, which was closed based on the licensee *s corrective actions, taken and planne During this inspection the licensee's progress in completing those planned corrective actions was reviewe Discussion During October 1996, an individual exiting the protected area actuated the alarm on the radiation monitor at the security portal. Two wires in the individual's possession were surveyed and found to have fixed and smearable contamination in excess of the licensee's procedural limits

.'

for unconditional release of material from the RCA. The individual had removed the wires from an underwater light fixture which the individual had found in a recyclable metals storage bin located outside of the RC The light fixture was surveyed and found to also have fixed and smearable contamination in excess of the release limits. The licensee initiated a root cause investigation to determine how radioactive materials got outside of the RCA and to identify corrective action The investigation could not definitely establish the specific means by which the material was removed from the RCA but the procedural requirements for unconditional release of material from the RCA were clearly violate Recommended corrective actions included more management oversight of radwaste processing, procedural enhancements for decontamination and release of material from the RCA, and training affected personnel on those procedural enhancements. The expected completion date for the procedure revisions and training was March 199 Based on the licensee's corrective actions, taken and planned, this issue was dispositioned as an NCV (50 395/96013 04) for failure to

,

-

t l

l

,

26 ,

follow contamination control procedures for unconditional release ,

requirements procedure During this inspection another event occurred :

involving discovery of contaminated material outside of the RCA. On January-14, a ladder with radioactive material stickers applied was ,

found in a closet in the Containment Access Building (CAB). The closet >

was outside of the remote RCA portal located in the CAB. The CER (N ) issued for this event indicated that no loose contamination was j detected on the ladder but one foot of the ladder had 150 ncpm of fixed contamination. After discussion of this issue with NRC regional management, the inspectors informed the licensee that this issue was deemed to be an additional example of failure to follow contamination '

control procedures but no further enforcement action would be taken because the licensee had not completed their corrective actions for the previous violation. The licensee was also informed that their corrective actions for the previous violation should be reexamined to assure that those corrective actions would preclude recurrence of this additional example. During the plan of-the day staff meeting on January 17, the Health Physics and Radwaste Manager announced that the remote RCA portal located in the CAB was closed until further notic l P2 Status of EP Facilities, Equipment, and Resources  !

P2.1 Tour of Emeraency Facilities i a. Insoection Scope (71750)

The inspectors toured the Emergency Operations Facility (EOF) to observe readines b. Observations and Findinas On February 4, the inspectors toured the EOF with EP personnel to review the emergency areparedness of the facility. The inspectors reviewed the operation of t1e Emergency Information System (EIS) with the licensee and observed several of its functions. The EIS is a computer based system that replaced the paper and status boards that were used to display, document, and transmit information generated during an emergency. Terminals for the EIS are available for each of the key positions in each of the emergency rer.ponse centers. The inspectors found the EOF readily available and M .:d for emergency operation The inspectors routinely toured the .,~al Support Center and found it also to be well maintaine c. fonclusions The inspectors concluded that the licensee is maintaining their emergency facilities in a state of readiness. The inspectors concluded that the EIS should be an enhancement to the transfer of information during an emergency.

t k

_ _ ..- . . - - . . - - .. - . . - - -

f

S1 Conduct of Security and Safeguards Activities '

>

S1.1 General Comments (71750) l The inspectors observed security and safeguards activities during the conduct of tours and observation of plant activities and found them to be good. The inspectors also reviewed the progress of a plant modification to reroute electrical conduit from outside to inside the

, Protected Area (PA) fence. The modification involved digging a hole under the PA fence to route the conduit. The inspectors reviewed the

,

work progress with electrical maintenance and security. The inspectors were ratisfied that appropriate security precautions were being observed and that there was good coordination between electrical maintenance and security. The inspectors also verified that adequate lighting was employed around ditches that had been du F1 Control of Fire Protection Activities F1.1 Review of Fire Rounds l Insoection Scope (71750)

The inspectors reviewed with fire protection technicians the conduct of continuous fire watches in the control buildin Observations and Findinas On January 16 the inspectors reviewed with fire protection technicians the conduct of continuous fire watches in the control building during a modification to the sprinkler system. The inspectors reviewed the continuous rover logs, fire watch locations, methods used to verify completion of the rounds, and fire watch qualifications. The fire watches were being performed as prescribed. The inspectors concluded that the fire technicians were knowledgeable of their fire watch responsibilities and adequately monitoring personnel performing the fire watche .

l Conclusions l The ins)ectors concluded that fire watches were being performed as prescriaed and the fire technicians were knowledgeable of ' heir fire watch responsibilities and adequately monitoring personnel performing the fire watche u _ _ _ . _

. _ _ _ _ .. ~ _ _ . _ - _ _ . . _ _ . . . _ _ _ _ . _

l l

l

,

j 28

, Manaaement Meetinas X1 Exit Meeting Summary f The inspectors ) resented the inspection results to members of licensee  ;

l management at t1e conclusion of the ins >ection on January 17 February 10, and March'7, 1997. The licensee ac(nowledged the findings presented. The licensee stated at the exit meeting that they do not i agree with the NRC's interpretation of Core Alteration i The inspectors asked the licensee whether any materials examined during  !

the inspection should be considered proprietary. No proprietary  !

information was identifie '

,

l l

l L

-,

t

PARTIAL LIST OF PERSONS CONTACTED l f

Licensee F. Bacon, Manager, Chemistry Services  :

L. Blue. Manager, Health Physics l M. Browne, Manager, Planning and Scheduling S. Byrne, General Manager, Nuclear Plant Operations R. Clary, Manager, Quality Systems M. Fowlkes Manager, Operations S. Furstenberg, Manager, Maintenance Services D. Lavigne General Manager, Nuclear Support Services G. Moffatt, Manager, Design Engineering K. Nettles, General Manager, Strategic Planning and Development H. O'Quinn, Manager, Nuclear Protection Services A. Rice, Manager, Nuclear Licensing and Operating Experience G. Taylor, Vice President, Nuclear Operations R. Waselus, Manager, Systems and Component Engineering R. White, Nuclear Coordinator, South Carolina Public Service Authority B. Williams, General Manager, Engineering Services G. Williams, Associate Manager, Operations INSPECTION PROCEDURES USED IP 37551: Onsite Engineering IP 40500: Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems IP 61726: Surveillance Observations IP 62707: Maintenance Observations IP 71707: Plant Operations IP 71750: Plant Support IP 83750: Occupational Radiation Exposure IP 92901: Followup - Plant Operations IP 92902: Followup - Maintenance IP 92904: Followup Plant Support t

i l

l

30 1 ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50 395/96015 01 NCV failure to adhere to procedural requirements to restore the B reactor trip bypass breaker to its proper, racked out position and failure to establish CCW flow prior to starting A CCP as required (Sections 04.1 and 04.2)

50-395/96015 02 VIO failure to perform TS surveillance to verify Reactor Building penetrations were closed or capable of being closed by an automatic signal prior to a core alteration (Section 08.2) ,

i 50-395/96015 03 VID numerous examples of missed TS required surveillance tests associated with the motor and turbine driven emergency feedwater pumps (Section M8.6)

Closed 50 395/96014 02 URI review of system status and removal and restoration log book (Section 08.1)

50 395/96007 05 URI conducting core alteration without containment integrity (Section 08.2)

50 395/96007 03 URI paint coat in containment does not meet application I specification (Section 08.3)

50 395/96005-01 VIO TS leakage assessment program integrated leakage '

assessments for Spring 1993 and Fall 1994 refueling outages were not recorded as required by GTP (Section M8.1)

50 395/95004 LER missed surveillance (Section H8.2)

50 395/96005-04 VIO failure to submit a required LER (Section M8.3)

50 395/96005-02 VIO draining of spent fuel pool due to inadequate corrective action (Section M8.4)  ;

50 395/94006 LER RCS pressure boundary leak in the C RCP seal injection line (Section M8.5)

50 395/96014-03 URI missed TS surveillance test on the turbine driven emergency feedwater pump (Section M8.6) i i

-- *m

.- - . . __ ..- - . __ __ - _- ._.._= -. .- . - - . -

,

'

l 50 395/96015 01 NCV failure to adhere to procedural requirements to e restore the B reactor trip bypass breaker to its l s

proper, racked out position and failure to establish CCW flow prior to starting A CCP as required (Section 04.1 and 04.2)

! Discussed

"

50 395/96011-05 URI Contaminated material found outside the RCA (Section R8.1)

! 50 395/96013 9 . NCV Failure to follow contamination control procedures

for unconditional release of material from the RCA (Section R8.1)

!

L_ _

.- -. . . - - ._

l

. G orc oq

-

• O2

.,

UNITED STATES f*g

, ,y j

g NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20M50001 k[ ....

D'. jo# JANUARY 13, 1997 MEMORANDUM T0: Jon R. Johnson, Acting Director Division of Reactor Projects Region 11 FROM: F. Mark Reinhart, Acting Director g Q6 Project Directorate 11-1 Division of Reactor Projects - 1/11 @

Office of Nuclear Reactor. Regulation SUBJECT: TASK INTERFACE AGREEMENT 96-010 V.C. SUMMER NUCLEAR STATION - TECHNICAL SPECIFICATIONS DEFINITION FOR CORE ALTERATIONS REFERENCE: TIA 96-010 - To Clarify Licensing Basis for Interpretations of Technical Specification Definition for Core Alterations, dated July 17, 199 In response to your request to evaluate South Carolina Electric & Gas Company's (SCE&G) interpretation of the V. C. Summer Nuclear Station Technical Specification (TS) definition of CORE ALTERATION, the attached memorandum ( . Grimes, Chief, TSB to F. M. Reinhart, Acting Director, PD2-1, dated December 10, 1996), provides the staff position, One clarification with regard to this position is that the following activity should have been added to the list of activities outlined in the attached memorandum:

+

All operations external to the Core Support Assembl The TSB included this item in the list of activities that fall within the definition of a literal interpretation of the TS as a CORE ALTERATION within !

the pressure vesse In conclusion, licensees are to comply with the literal requirements, which include definitions, of their Technical Specifications. Licensees desiring to benefit from the improvements provided by the improved Standard Technical Specifications (iSTS), are encouraged to convert to the iST Attachment: Memorandum to F. Mark Reinhart, Acting Director, PDll-1 from Christopher 1. Grimes, Chief, Technical Specifications Branch, NRR, dated December 10, 199 ENCLOSURE 3 ( a

y - -- . - - - ~ ~ - - ~ - - ~ ~ ~^ ~ ~ "~ " " ^ " ~ ~ ~ ~ ~ ~ ' ~

- . _ ...- -

pa arco

!

ATTACHMENT

,

g* 'g . UNITED STATES l

'

e S (

NUCLEAR REGULATORY COMMISSION

-

i fI wassinoTon, o.c. 2o565-o003 i

% % n tf4 *5 l

• • .s+ Deceraber 10, 1996 I

,

!

t MEMORANDUM TO: F. Mark Reinhart, Acting Director  !

Project Directorate ll-1 {

,

Division of Reactor Projects 1/11, NRR .

-

l FROM: Christopher I. Grimes, Chief l-e '

{

Technical Specifications Branch Associate Director for Projects, NRR

,

j i

SUBJECT: V. C. SUMMER NUCLEAR STATION TECHNICAL -f SPECIFICATIONS -DEFINITION OF CORE ALTERATIONS i (TAC M96128)

l

!

By memo dated July 17,1996, Region !! forwarded TIA 96-010. This TIA requested NRR  !

assistance in evaluating the position taken by the licensee for the V. C. Summer Nuclear l

Station regarding interpretation of their Technical Specification (TS) definition of CORE j ALTERATION. The TlA includes the list of specific activities that the licensee does not

!

consider to be CORE ALTERATION j i

At Summer, a CORE ALTERATION is defined as follows: " CORE ALTERATION shall be the  !

movement or manipulation of any component within the reac'or pressure vessel with the !

vessel head removed and fuelin the vessel." Because of the language " movement or [

maniculation of any comoonent" in that definition, a literal interpretation of the Summer i TS would include, as CORE ALTERATIONS, the following activities within the pressure  !

vessel from,TIA 96-010 which the licensee believes should be excluded:

}

Exercising the Internals Vent Valve *

All video camera inspections external to the volume of the COR j

Control Component Retainer handling operation >

+

Suspension and manipulation of lightweight tools or components within the vessel but outside the Core Regio * l Indexing the Main and Auxiliary Fuel Handling Bridges fuel and control rod grapples to the reactor core location {

• I Withdrawsi/ Insertion of incore detector !

Movement of lights, cameras and reactor vessel material specimen's within the !

reactor vesse * j Movement of ENA Flux thimbles within the Core (but not the detectors which could ;

be considered a source).

Movement of the reactor vessel upper internals within tiie reactor vessel with fuel in the vesse CONTACT: E. B. Tomlinson, NRR 415-3137 (_ -;

-

.

'

.. . \

M. Reinhart d -2-Decenber 10. 1996 The definition of CORE ALTERATION in NUREG-1431, Standard Technical Specifications

'(STS) for Westinghouse Plants, is derived from the need for control of reactivity changes and the consequences of fuel handling accidents. Therefore, the NUREG-1431 definition of CORE ALTERATION was limited to movement of any fuel, sources, or reactivity control components within the reactor vessel:

l CORE ALTERATION shall be the movement of any fuel, sources, or reactivity !

control components, within the reactor vessel with the vessel head removed I and fuelin the vessel. Suspension of CORE ALTERATIONS shall not  !

preclude completion of movement of a component to a safe positio I

i s

'In developing the STS definition, the staff recognized that licensees must satisfy the f guidance in NUREG-0612 with respect to an adequate design basis for controlling heavy !

loads, including movement of loads within the reactor vessel when there is fuelin the

{

vessel. Additional restrictions like those imposed by the Summer definition of CORE '

ALTERATIONS would preclude the licensee from exercising design options relative to load handling as detailed in NUREG-061 While there is considerable difference between the NUREG 1431 and the Summer TS regarding the definition of CORE ALTERATION, the Summer TS are subject to literal interpretation. Therefore, the activities listed above must be considered as CORE j

l l

ALTERATIONS at Summer until such time as the licensee amends the license to include !

the NUREG-1431 definitio in the list of activities in TIA 96-010, there are some activities that are not considered to !

be CORE ALTERATIONS by either the Summer TS or NUREG-1431 definitions. Those . i activities involve movement of loads over the open reactor vessel. The conduct of these '

activities should conform with the guidelines in NUREG-061 ;

!

The Reactor System:, Branch and the Plant Systems Branch concur in this position if you -l have any questions, please contact E. B. Tomlinson of my staff on 415-3137. This  !

completes our efforts under TAC No. M9612 ]

i cc: R. Zimmerman

{

S. Varga J. Roe ,

]

A. Johnson '

l G. Holahan T. Collins L. Marsh -

J. Lieberman l

l u.