ML20046C591

Forwards Response to Violations Noted in Insp Repts 50-395/93-03 & 50-395/93-17,including Response to NRC 930629 Ltr Re Util Denial of Violation 93-03-02.Corrective Actions: Mechanical Maint Procedure (MNP-300.033) Developed

ML20046C591
Person / Time
Site:	Summer
Issue date:	08/06/1993
From:	Skolds J SOUTH CAROLINA ELECTRIC & GAS CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RC-93-0216, RC-93-216, NUDOCS 9308110192
Download: ML20046C591 (8)

Text

-

South C:rolina Electrie 4 Gas Company hn ko s Nuclear Opwatons

&%b t jengmSlfjegg g

C 2m SCE&G

,,c.,,_,

August 6, 1993 Refer to: RC-93-0216 Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555 e

Gentlemen:

Subject:

VIRGIL C. SUMMER NUCLEAR STATION DOCKET NO. 50/395 OPERATING LICENSE N0. NPF-12 RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORTS 93-03 AND 93-17 Attached is the South Carolina Electric & Gas Company (SCE&G) response to Notice of Violation delineated in NRC Inspection Report No. 50-395/93-03 and 93-17. SCELG is in agreement with the violations listed in 93-17, and the enclosed responses address the reasons and corrective actions being taken to prevent recurrence for those violations. Also, the response to NRC letter, dated June 29, 1993, concerning SCE&G's denial of Violation 93-03-02 is included.

Should you have any questions, please call at your convenience.

Very truly yours

/

w bc John L. Skolds CAC:lcd Attachment c: 0. W. Dixon (w/o attachment)

R. R. Mahan (w/o attachment)

R. J. White S. D. Ebneter L. D. Shealy NRC Resident Inspector J. B. Knotts Jr.

J. I. Byrd NSRC Central File System RTS (IE 930302, IE 931701 & IE 931702)

File (815.01) )

100067 9308110192 930806 PDR ADOCK 05000395 C eg/'j' l

PDR

. 4 %

[j v

G NUCLEAR EXCELLENCE - A SUlHER TRADITION!

l

Enclosure 1 to Document Control Desk Letter IE 931701 Page 1 of 3 RESPONSE TO NOTICE OF VIOLATION VIOLATION NUMBER 50-395/93-17-01

1. RESTATEMENT OF NRC VIOLATION Technical Specification 6.8.1.c requires that written procedures be established, implemented and maintained covering the applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2. Section 9.a of Appendix "A" states, in part, that

" maintenance that can affect the performance of safety-related equipment should be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances". Electrical Maintenance Procedure EMP 295.013 Inspection and PM of EFW Pump Motors, provides instruction for lubrication of the emergency feedwater (EFW) pump motor bearings. '

Contrary to the above:

(1) On June 7, 1993, the procedure for the Motor Driven Emergency Feedwater Pump (MDEFP) bearing oil change was inadequate in that it did not specify an acceptable method of refilling the ,

oil reservoir to ensure that the required lube oil level was obtained or that the correct amount of lube oil was added. '

This resulted in bearing lube oil _ levels below the pump manufacturers recommended level, and the amount of lube oil added being below the quantity specified in the plant lubrication manual. An evaluation had not been made to justify the lower oil level.

(2) On May 25, 1993, paragraph 7.5, " Test Run of Equipment" was not performed following the lubrication of the motor bearing.

The failure to perform the applicable steps in paragraph 7.5 .

resulted in the excessive grease not being removed from the  !

motor bearings. During a subsequent operability test of the .

MDEFP, a high temperature alarm for a motor bearing was  :

received and the test was halted.  !

II. SCE&G POSITION ON THIS VIOLATION SCE&G agrees with the violation as stated above.

III. REASON FOR THE VIOLATION In the case of example 1 above, the procedure was inadequate in that it lacked the detailed steps necessary to ensure a proper oil change method.

t

t L

Enclosure 1 to Document Control Desk letter IE 931701 Page 2 of 3 Example 2 above was caused by a lack of procedure adherence.

Procedure steps were signed for removal and replacement of grease ,

plugs. The electricians did not realize that these signoffs were associated with the step requiring the pump to be run in order to remove excess grease. Subsequent turnover did not identify that the pump had not been run to allow excess grease to be removed from the bearing housing.

IV. CORRECTIVE STEPS TAKEN FOR EXAMPLE 1:

Mechanical Maintenance Procedure (MMP-300.033), " Changing 011 in Pump Equipped With Trico Opto-matic Oilers," has been developed to provide instructions for changing oil and setting proper oil level in pumps equipped with Trico Opto-matic oilers.

A dimensional analysis of pump bearing assembly was performed to determine if the minimum constant level oiler setting resulted in contact between the oil and the lowest point of the oil slinger ring. This analysis indicates contact of approximately .006 inch.

While this is below the manufacturer's recommendation, a review of past oil analysis, vibration analysis, and pump performance shows adequate oil levels were provided.

FOR EXAMPLE 2: ,

The problem with failure to remove excessive grease from_the bearing housing was corrected following discovery during the surveillance testing. The excess grease was removed from the housing, and the pump was satisfactorily retested without further temperature ,

problems with the bearing.

The electricians were formally counseled concerning the failure to follow procedures, and procedure adherence was stressed at'all '

levels within the maintenance organizations.

V. CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATIONS Management Review Boards were convened on July 13, 1993, and July 20, 1993, to review the circumstances of the event related to the ,

bearing grease changeout for the MDEFP. Corrective actions were I reviewed by the board along with interviews of the personnel i involved in order to better understand the causes of the event and  !

verify-the adequacy of the corrective actions. I I

Maintenance procedures providing instructions for pump maintenance including MMF-195.002, " Emergency Feedwater Pump Maintenance Motor Driven, will be reviewed to determine adequacy of instructions for method of refilling the oil reservoirs. Changes will be made to upgrade this procedure as determined by the review.

i Procedure adherence will continue to be stressed at all levels.  !

Enclosure 1 to Document Control Desk Letter

, -IE 931701 Page 3 of 3 '

. j VI. DATE FULL COMPLIANCE WILL BE ACHIEVED SCE&G will be in full compliance by October 1, 1993.

1 1

I 5

l i

h i

3 I

-Enclosure 2 to Document Control Desk Letter IE 931702 Page 1 of 3 RESPONSE TO NOTICE OF VIOLATION VIOLATION NUMBER 50-395/93-17-02 I. RESTATEMENT OF NRC VIOLATION Technical Specification 6.8.1.c requires that written procedures be established, implemented and maintained covering the applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33 Revision 2. Section 3.5(2)(b) of Appendix "A" requires procedures for startup, operation and shutdown of the onsite AC electrical system. Section B of System Operating Procedure SOP-313,. Local Switchgear Breaker Operations, provides detailed instructions for racking out 480 volt breakers.

Contrary to the above, on June 7, 1993, the sequence of steps specified in S0P-313 was not followed when racking out the feeder breaker for auxiliary building exhaust fan XFN 19B because the operators used " skill of the craft" to rack out the breaker rather than referring to the SOP. The removal of DC power from the breaker was not documented in the Danger Tag Log. This contributed to the inadvertent disabling of "B" service water booster pump.

II. SCE&G POSITION ON THIS VIOLATION SCE&G agrees with the violation stated above with the following exception. The cause of the violation was not related to use of

" skill of the craft." The operators failed to follow the requirements of written procedures in performing this activity.

III. REASON FOR THE VIOLATION This violation was the result of a failure to adhere to procedure 50P-313, Local Switchgear Breaker Operation. Also contributing to this event was a lack of configuration control for positioning control power breakers for the Danger Tag Program.

IV. CORRECTIVE STEPS TAKEN Procedure adherence has been stressed to all operations personnel.

A Root Cause Evaluation was performed to ensure all contributing factors were identified and corrected.

V. CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATIONS Management Review Boards were convened on July 13, 1993, and July 20, 1993, to review the circumstances of the event related to the inadvertent disabling of the "B" service water booster pump.

Corrective actions were reviewed by the board along with interviews

Enclosure 2 to Document Control Desk Letter IE 931702 Page 2 of 3 of the personnel involved in order to better understand the causes of the event and verify the adequacy of the corrective actions.

Procedure adherence will continue to be stressed at all levels. The corrective actions identified as a result of the Root Cause Analysis i will be implemented including:

- Labeling enhancements to the electrical switchgear.

- Addition of DC control power breakers to danger tagouts .

- Re-emphasty of the methods to be utilized by Operations personnel during the independent verification process for ,

danger tagging as required by station administrative procedures.

VI. DATE OF FULL COMPLIANCE WILL BE ACHIEVED SCE&G will be in full compliance by October 30, 1993.

VII. Skill Of The Craft Regulatory Guide (RG) 1.33 (Appendix A, Section 9) states " Skills normally possessed by qualified maintenance personnel may not require detailed step-by-step delineation in a procedure." As stated in the VCSNS FSAR, SCE&G's Operational QA Plan complies with the recommendations of RG 1.33. The Operational QA Plan (paragraph '

4.2.1) states " Procedures are developed with detail such that a qualified person can safely perform the activity with acceptable results. The level of detail will depend on the complexity of the activity. These commitments are found in documents such as ANSI N18.7, the FSAR, Technical Specifications, etc." ANSI N18.7 (paragraph 5.2.7) states"Maintenanceormodificationofequipment shall be preplanned and performed in accordance with written procedures, documented instructions or drawings appropriate to the circumstances which conform to applicable codes, standards, specifications, and criteria. Skills normally possessed by  !

qualified maintenance personnel may not require detailed step-by- i step delineations in a written procedure." ANSI N18.7 is endorsed )

by RG 1.33. I SCE&G considers, based upon the complexity of the activity, that  !

skills normally possessed by qualified personnel may not require detailed step-by-step written procedures, Examples of activities considered skill of the craft are:

For operators, stroking of valves or starting of pumps which do r.at require extensive initial conditions or prerequisites.

For maintenance personnel, the installation and use of test equipment such amp-meters, multi-meters, i

1

-Enclosure 2 to Document Control Desk Letter IE 931702 Page 3 of 3 I

_For testing personnel, installation and routine operation of field j standards and data collection equipment. l l

i l

1 i

P a

t i

l t

J i

d

Enclosure 3 to Document Control Desk Letter 1

, IE 930302 Page 1 of 1 RESPONSE TO N014CE OF VIOLATION .

NUMBER 50-395/93-03-02 l 1

I. RESTATEMENT OF NRC VIOLATION Technical Specifications 6.8.1.c requires that written procedures be established, implemented and maintained covering surveillance and test activities of safety-related equipment. Paragraph 4.4.7 of the Operational Quality Assurance Plan states that written test procedures shall include test methods and any special test equipment or calibrations required to conduct the test.

Contrary to the above:

On January 26 and 27, 1993, relays in safety-related switchgear IDB1 and IDB2 were tested without written procedures which addressed the connection of related test equipment to the switchgear. Jumpers were used to provide the 120VDC power supply from the switchgear to the test equipment; however, the relay testing procedure did not provide any work instructions involving the s:'ichgear.

II. CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED After the conversation with the Inspector, SCE&G Relay Department personnel obtained an external power supply that would generate the needed 120VDC. This power supply was used to test the remaining differential current relays.

III. CORRECTIVE ACTIONS TAKEN TO AVOID FURTHER VIOLATIONS As noted in the NRC Inspection Report, SCELG realized that relay ,

testing could be improved by the use of an external power supply to obtain the 120VDC needed to perform relay testing. Based on this, the applicable 190 series electrical maintenance procedures were revised to require an external power supply to be utilized for future relay testing.

_ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ . _