ML20043D586

Forwards LERs90-004 & 90-006 Which Respond to Violation Noted in Insp Rept 50-395/90-12.Corrective Actions:Training Conducted & Tech Spec Instruments Evaluated for Adequate Testing

ML20043D586
Person / Time
Site:	Summer
Issue date:	06/01/1990
From:	Bradham O SOUTH CAROLINA ELECTRIC & GAS CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9006080276
Download: ML20043D586 (1)

Text

I touth Carchne Electric & Gas Company Oll:) S. Brodham j P O.BoxBB Vics Prepoent '

• • ' Jenkinsvme. SC PO65 Nuclear Operations  !

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, (803) 3454040 SCEAG 5

June 1, 1990 l

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Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC. 20555

Subject:

Virgil C. Summer Nuclear Station Docket No. 50/395 Operating License No. NPF-12 Response to Notice of Violation NRC Inspection Report 90-12 Gentlemen:

Attached are the South Carolir.6 Electric & Gas Company (SCE&G) Licensee Event Reports (LERs)90-004 and 00-006 which respond to the violation addressed in Enclosure 1 of NRC Inspection Report 50-395/90-12. SCE&G is in agree'nent with the alleged violation, and the enclosed LERs address the reasons for the '

violation and the corrective actions that have been taken and are being taken to prevent recurrence. It should be noted that LER 90-004 corrective action item number 3 has been completed, and item number 4 is scheduled for completion by the end of Refueling VI.

If you should have any questions, please advise.

1 Very truly yours, l

0. S. Bradham l

HID/OSB:1bs l

' Attachments l

L c: 0. W. Dixon, Jr./T. C. Nichols, Jr.

l~ E. C. Roberts l R. V. Tanner J. C. Snelson -

S. D. Ebneter R. L. Prevatte J. J. Hayes, Jr. J. B. Knotts, Jr.

General Managers NPCF C. A. Price NSRC R. B. Clary RTS(IE901201)

K. E. Nodland File (815.01) 90060s0276 900601 DR ADOCK03OOg5 p

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10CFR50.73 3 4

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l May 7, 1990 I l

Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

Virgil C. Summer Nuclear Station Docket No. 50/395 Operating License No. NPF-12 ,

LER 90-004 Gentlemen:  ;

Attached is Licensee Event Report No.90-004 for the Virgil C. Summer Nuclear Station. .This report is submitted pursuant to the requirements of ,

10CFR50.73(a)(2)(i)(B).

Should there be any questions, please call us at your convenience.

Very truly yours, h sc$ 40"

0. S. Bradham ARR/OSB: led  !

Attachment ,

c: 0. W. Dixon, Jr./T. C. Nichols, Jr.

E. C. Roberts R. V. Tanner J. C. Snelson S. D. Ebneter R. L. Prevatte J. J. Hayes, Jr. J. B. Knotts, Jr.

General Managers INFO Records Center i C. A. Price AN! Library G. J. Taylor Marsh & McLennan J. R. Proper NPCF R. 8. Clary NSRC F. H. Zander RTS (ONO900038)

L T. L. Matlosz Files (818.05 & 818.07)

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Technical Specification Table 3.3-10 Item 14 lists the Reactor Building Level Transmitters (LT-1975, LT-1976) as required accident monitoring instruments. While l implementing a modification to these level transmitters during the fifth refueling  !

outage, it was discovered that two leads for LT-1976 were determinated rendering the i transmitter inoperable. The leads had been determintted during the previous j

refueling outage for maintenance purposes.

The cause of this event was personnel error. The lifted Lead and Jumper Sheet for l the transmitter was inappropriately transferred between work documents. Contributing '

to this event was the use of an inadequate post-maintenance operability test.

The procedure for controlling lifted leads and jumpers is under revision and training I on this process has been conducted with appropriate maintenance personnel. Also, '

I other Technical Specification instruments which f ail to the position of their normal I

indication (e.g., zero span) will be evaluated for adequate testing.

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PLANT IDENTIFICATION:

Westinghouse - Pressurized Water Reactor ,

EQUIPMENT IDENTIFICATION:'

Post..AccidentMonitoringSystem(IP)-Ells IDENTIFICATION OF EVENT: ,

, o Personnel error 1 m'*. to inoperable Reactor Building Level Transmitter. l EVENT DATE: "

The transmitter leads were lifted sct ievel transmitter LT-1976 on N0vember 14, 1988. A reportable condition was loantified on April 9,1990.

REPORT,0 ATE:

May 7, 1990L

-This. report was initiated by Off-Normal Occurrence Report 90-038.

CONDITION PRIOR TO EVENT: (

o Mode 6. 0% power, fifth. refueling outage

, DESCRIPTION OF EVENT:

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Technical Specification 3/4.3.3.6 requires certain accident monitoring instruments

be operable to ensure that sufficient information is available post-accident to

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_ monitor and assess: selected plant parameters. Table 3.3-10 Item 14 lists the Reactor Building Level Transmitters (LT-1975, LT-1976) as required accident monitoring instruments. While implementing a modification to these level transmitters during the fifth refueling outage, it was discovered that two leads in-cabinet XPN-6002 had been previously disconnected which rendered LT-1976 1, inoperable.

Investigation into this event determined that the leads for LT-1976 were

'determinated during the fourth refueling outage (November 14,.1988) as part of an I

.EquipmentQualification(EQ) inspection. The inspection was performed using a Preventive Maintenance Task Sheet-(PMTS). As required by plant procedure (SAP-300), a Lif ted Lead and Jumper (LL&J) sheet was included with the PMTS to

j. document'the lifted' leads.

/ ,

l On November 17, 1988, during completion of the PMTS, the Electrical Supervisor (who L 'was aware that the Instrumentation and Control group had an open Maintenance Work i Request [MWR 8810501) to repair damaged wires on LT-1976) contacted the I&C L Supervisor to find out if retermination of the leads could be performed by I&C.

L 1 The. intent was that I&C would reland the leads for the EQ inspection and repair the L damaged transmitter wires under MWR 8810501. Both supervisors agreed that this  !

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0l0 0l 3 0l4 action would be acceptable. Subsequently, the retermination portion of the

__ original LL&J sheet was NA'd by the Electrical Supervisor with reference to the retermination via the MWR. The PMTS was signed off on November 17, 1988. However, MWR 8810501'which was supposed to reterminate the leads (per the agreement between

'the~ supervisors) had been field completed on November 8, 1988. The failure to.

reterminate-the leads resulted in the' level transmitter being inoperable until it was discovered during the Refuel 5 modification.

.(AUSE OF EVENT:

The cause of this event was personnel error. Apparently neither supervisor i

realized that the MWR had already been completed and, therefore, could not be used to reterminate the leads. In addition, there was miscommunication between the supervisors regarding the means for using the LL&J sheet to document the tr asfer of work. 'The Electrical Supervisor intended for the !&C Supervisor to generate a new LL&J sheet whereas the I&C Supervisor apparently assumed that the original LL&J sheet would be provided to him for incorporation into the MWR package. Plant procedures-allow transfer of work between documents (with specific controls),

however, the method for transfer of LL&J sheets is not adequately specified.

The curveillance testing requirements for the transmitter requires a monthly channel check and an 18 month loop calibration. The loop calibration (STP-300.006) was performed prior to the determination of the LT-1976 leads. The monthly channel check (STP-135.001), which was also specified as the post-maintenance test, checks that LT-1975 and LT-1976 are within instrument tolerance for redundant channels and are indicating es expected for existing plant conditions. By design the de-energized and, therefore, the LT-1976 fails transmitter to the indicator appeared-to mechanical be reading stop (413 normally (i.e...zero span feet indicated))

during the channel checks. A contributing factor to this event was that the monthly channel check was inadequate for a post-maintenance / modification check of the level transmitter.

ANALYSIS OF EVDIT:

The Limiting Condition for Operation (LCO) for Technical Specification 3.3.3.6

-(when less than the required number of channels is operable) is to repair the inoperable channel within seven days or be in hot shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This event is reportable under 10CFR50.73(a)(2)(1)(B)-since LT-1976 was inoperable for approximately 17 months. The plant was already shutdown at the time the event was discovered. A review of the PMTS and loop calibration for LT-1975 (the redundant Reactor Building Level Transmitter) indicates that it was operable during the period from Refuel 4 to Refuel 5.

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0l 0 0l 4 or 0l4 f-LT-1976 does not perform any control functions. k Building level indication. This condition did not Itpose is used solely for Reactor a safety concern because

the redundant level transmitter was operable during the period. Also, two Reactor Bui.iding Sump level indicators (range 408-412 feet) were available to provide initial indication of rapidly rising water in the Reactor Building.

CORRECTIVE ACTION: '

p Since_the plan.t was in Mode 6, no immediate corrective action was required. The following corrective measures have been identified for this event.

1, The procedure for controlling lifted leads and jumpers (SAP-300) is being revised to outline programmatic controls / methods for transferring Ll&J sheets from by one July 31,work document to another. This revision is scheduled to be complete 1990.

2.

The proper means to transfer responsibility of LL&J sheets has been discussed with the Electrical and I&C Supervisors. Formal. guidance (memorandum dated April 18,1990) was provided on how to transfer LL&J responsibility and training sessions were conducted with the applicable I&C, Mechanical and Electrical Maintenance personnel. '

3.

A list of Technical Specification instruments which fail to the position of

'their normal indication (e.g., zero span) has been generated. SCE&G will verify that adequate testing has been performed on these instruments prior to

. entering Mode'l from the present refueling outage and will ensure they remain' ,

~

operable throughout the upcoming cycle.

4. -

o The adequacy'of the post-maintenance testing program will be thoroughly g

reviewed by SCE&G. The responsibility for administering post-maintenance l'

' testing will be transferred to the recently formed Test Group. This will improve the technical adequacy and consistency of post-maintenance testing. '

PRIOR OCCURRENCES:

None.

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1 May 10, 1990 l l

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. Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

Virgil C. Summer Nuclear Station Docket No. 50/395-Operating License No. NPF-12 LER 90-006 Gentlemen:

Attached is Licensee Event Report No.90-006 for the Virgil C. Summer Nuclear Station. This report is submitted pursuant to the requirements of 10CFR50.73 (a)(2)(iv). '

Sho'uld there be any questions, please call us at your convenience.

Very truly yours, h 41 uss ~

0. S. Bradham o

EWR/0SB: led i Attachment-c: 0. W. Dixon, Jr./T. C. Nichols, Jr.

E. C. Roberts R. V. Tanner R. ',. Prevatte S. D. Ebneter 1 B. Knotts, Jr.

J. J. Hayes, Jr. S. Slone General Managers E. W. Rumfelt C. A. Price INP0 Records Center G. J. Taylor ANI Library J. R.-Proper Marsh & McLennan R. B. Clary NPCF  ;

F. H. Zander NSRC T. L. Matlosz RTS- (ON0900041)  :

K. E. Nodland Files (818.05 & 818.07)

J. C. Snelson i

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• encan, iame ni i occust sie.n m en m Virgil C. Summer Nuclear Station oistoioiopi i95 ilorl0 51 T4fLS let Diesel Generator Actuation Due to Personnel Error in Terminating Battery ev c ori e u =u .. . ..,=,.n, or .. ..enmu volv. .

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! A Ei d Bi Yi C i Si2:5 0 N i i i i i i i I I i I I I I I I I i i i i SU.*LleiterTAL Aapont e x,gCTS. He won?w car vtan Sv8vit$loN vilII9 v.e ser.so,en. tuqCTIO Svent!S$ ton .A TE) No l l l an,n.Cv m ,, ,. ,a .... . , .N .-, a, , nei On April 12, 1990, an unplanned Engineered Safety Features (ESF) actuation occurred at the Virgil C. Summer Nuclear Station (VCSNS) when the "B" train Emergency Diesel Generator (EDG) automatically started wnile the plant was in Mode 6. At 0630 hours0.00729 days <br />0.175 hours <br />0.00104 weeks <br />2.39715e-4 months <br />, the "B" train battery feeder breaker was closed in to provide an initial charge to a new "B" train battery. Due to personnel errors, the battery was incorrectly coinected with the battery leads reversed. When the battery feeder breaker was closed, the reversed polarity of the battery led to the loss of the "B" train battery ctarger and the swing battery charger, leaving the polarity to-the bus reversed. The  ;

thargers had been aligned in parallel to provide a backup DC power source while the leattery'was disconnected. The ensuing transient caused the Bus 1DB incoming breaker to trip, resulting in the loss of offsite power to the "B" train. The "B" EDG 4 tarted on the loss of Bus 108, but the field flash circuitry would not actuate on a negative DC voltage. Without the field excitation, the generator voltage did not rise,.and the EDG did not load. i The Shift Supervisor, recognizing a transient on the DC Bus, requested Operations personnel to reopen the battery feeder breaker and to secure the EDG. At this point, both~AC and DC power to the "B" train was lost. Core alterations were immediately suspended. The "A" train Electrical Power System, which was providing the power source required by Technical Specifications, remained operable throughout the event.

To prevent similar events from occurring, the individuals involved in the incorrect battery termination will conduct " lessons learned" training to personnel in their respective groups. Additionally, programs and procedures at VCSNS are being reviewed to determine programmatic enhancements that can be made to prevent similar occurrences.

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Westinghouse - Pressurized Water Reactor E0VIPMENT IDENTIFICATION:

.DC Power Systems - Class 1E Ells - LJ IDENTIFICATION OF EVENT:

Duet to personnel-errors, a DC, System transient, created by reversed leads to the "B" Battery, caused the AC normal feed breaker to ESF Bus 108 to trip open. The "B"-EDG started.on the loss of Bus 108, but did not come up to voltage because the:

-field failed to flash on the reversed DC voltage.

EVENT DATE:

April 12, 1990' REPORT DATE: 1 No later'than May H , 1990.

'This' report wasl initiated by Off-Normal Occurrence Roport 90-041.

CONDITIONS PRIOR TO EVENT:-

_ Mode 6 - Defueling Reactor The "B" train battery was being replaced and was, therefore, tagged out. The "B" train DC System control power was being provided by'the "B" battery charger and the

-swing. battery. charger, which were aligned in a parallel configuration.-

DESCRIPTION OF EVENT:

'On April,4.'1990, during Refuel 5 at the Virgil C. Summer Nuclear Station (VCSNS),

South Carolina Electric & Gas Company employees began work on a modification to

-replace the existing station batteries with new, higher capacity batteries. To provide a backup source of DC power while the battery was disconnected, VCSNS had

-aligned the swing battery charger in parallel with the "B" train battery charger.

When the new "B" train battery was installed, the leads to the battery terminals were incorrectly terminated, with the polarity reversed. -At approximately 0630 hours0.00729 days <br />0.175 hours <br />0.00104 weeks <br />2.39715e-4 months <br /> on April 12, 1990, the feeder breaker from the battery was closed in-to provide the battery with an initial charge. When the battery breaker was closed, s

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0l0 0l3 oF 0l5 m, w , u,u. . .n.a . .a.mc w w mm the reversed polarity damaged / tripped both of the battery chargers, leaving the polarity to the bus reversed. The reversed polarity transient in the DC control system for Engineered Safety Features (ESF) Bus 10B tripped the incoming breaker to ESF Bus 108 and resulted b e 9ss of offsite power to the "B" train. The "B" Emergency Diesel Generator 6 0G) started on the loss of Bus 1DB, but the field flash circuitry would not actuate on a negative DC voltage. Without field excitation, the generator voltage did not rise, and the EDG did not load. The EDG was secured by Operations personnel.

When the 10B normal incoming breaker opened, DC control power from the battery was available to the ESF bus, but the polarity was reversed. This resulted in the main control board indicating DC control power available by the status lights on the 10B ncrmal incoming breaker, but the DC Bus voltage meter indicated "zero" volts. The Shift Supervisor instructed an Auxiliary Operator to reopen the battery breaker, at which time.all indication of DC control power was lost. With the "B" EDG secured,

~the AC normal incoming breaker tripped open, and the' battery feeder breaker opened, there was no AC or DC power available to the "B" train.

VCSNS was in the process of defueling the reactor during the transient. Core alterations were immediately suspended. Inside containment, the fuel Manipulator Crane was positioned over an assembly, but was not latched. In the fuel Handling Building, there was an assembly in the Upender in the upright position.

The "A" train Electrical Power System, which was being credited as the power source system required by Technical Specifications, was not affected and remained operable throughout the event.

CAUSE OF EVENT:

The immediate cause of the event was pertonnel error: The battery was incorrectly terminated.

The intermediate personnel errors contributing to the incorrect termination were:

(a) .The battery leads were not labeled for polarity when they were determinated.

Tie modification originally required the lead cables to be removed so that the. conduit could be modified to support termination of the new battery. The desi,'n package was revised to allow the lead cables to remain in place to reduct. the potential for ccDe damage incurred from being pulled through conduit. The employee performing the determination, unaware of the revision to the design package, did not label the leads for polarity.

(b) The termination of the new battery was not proceduralized because of the simplicity of the work involved.

(c) A polarity check was not performed on the leads.

During the pre-planning meeting for the modification, a polarity check for the leads was not identified as a check-out test which needed to be formalized. Though the design package included a statement regarding L

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010 014 0' 0 lE I verification of feeder cable polarity, the check was not performed on the I leads.:

Miscommunicatirn between the Lead Engineer for the modification and the Day Shift Maintenince Supervisor resulted in the Maintenance Supervisor thinking-that the Engsneer had specified the polarity of the leads. Because of this, a polarity <. heck on the leads was not performed. This miscommunication carried over to the Night Shif t Maintenance Supervisor responsible for impl6mentir.g the-termination and subsequently'to Quality Control.(QC)-

personnel responsible for inspecting the cable termination.- As a result, the cable termination was accepted as being correct.

ANALYSIS OF EVLNT:

There "A"

were no adverse consequences to safety as a result of this event because the train Electrical %wer System.-which was being credited as the single _ power source the event._ system reodred by Technical Specifications, remained operable throughout IMMEDIATE CrARECTIVE ACTION:

-Immediate corrective action was taken with the reopening of the feeder breaker from the battery. Core alterations were suspended, and the EDG was secured. Work to

-repair the damaged battery chargers-was initiated immediately following the transient. Polarity sensitive electronic equipment connected to the bus was checked for damage and necessary repairs and replacements were made.

ADDITIONAL CORRECTIVE ACTION:

To ensure that appropriate attention was given to the event, a Management Review Board (MRB) meeting was held on April'19, 1990, to discuss the event and to provide Action Items designed to prevent similar occurrences. The following items resulted from the MRB meeting:

1.

The individuals involved in the incorrect termination event will provide

" Lessons Learned" training.to personnel in their respective groups.

2. Programs and procedures are being reviewed to determine what programmatic enhancements can be made to prevent similar occurrences. - Specifically:

Post Modification testing practices will be evaluated to i

determine ways to improve checkout testing and to identify the degree of lead engineer involv- ent in determining the adequacy 1 of the recommended checkout testing for modification packages.

VCSNS Station Administrative Procedure 133, " Design <

Control / Implementation and Interface," will be reviewed to verify that requirements for Post Modification Testing are L being followed.

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0l0 0l5 or 0 l5 un in - w.c. . o. .mmac ra. mso nn Quality Control will review, for adequacy, their inspection program for cable terminations. This review will' include the objective evidence required prior to QC acceptance.

All of the above corrective actions will be completed by July.1, 1990. -

PRIOR OCCURRENCES:

LER 89-07, dated May'15, 1989, describes an event.similar to this occurrence in

-that adequate Post Modification testing, in both circumstances. would have prevented the events. The corrective actions resulting from LER.89-07 did not address Post Modification testing because.the root cause of the event was " unclear instructions in a modification package." Item 2 in the " Additional Corrective Action" of this' Report (LER 90-06) focuses on Post Modification. testing and is designed to prevent similar occurrences.

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