ML20127H275

Insp Rept 50-395/85-10 on 850311-15.Violation Noted: Failure to Identify Name of Data Recorder on Record of Test

ML20127H275
Person / Time
Site:	Summer
Issue date:	03/28/1985
From:	Blake J, Girard E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20127H222	List: ML20127H218 ML20127H232 ML20127H275
References
50-395-85-10, IEB-83-03, IEB-83-3, NUDOCS 8505210262
Download: ML20127H275 (8)

See also: IR 05000395/1985010

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/ NUCLEAR REGULATORY COMMISSION

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-Report No.: 50-395/85-10

Licensee: '. South' Carolina Electric a'nd; Gas Company

Columbia, SC 29218

Docket No.: 50-395' License No.: NPF-12

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L Facility Name: Summer

Inspection Conducted: March 11-15, 1985^ ,

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Inspe or: O ~

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v r E. H. Girard Date Signed

Approved by: [ de 8[18/# I

J. J. Blake, S%ction Chief ( Da'te Signed

Engineering. Branch

Division of Reactor Safety

SUMMARY

Scope: This routine, unannounced inspection entailed 38 inspector-hours on site

and at the licensee's corporate office in Columbia, South Carolina, in the areas

of. licensee action on previous enforcement matters, inservice testing of pumps

, .and valves, inservice inspection - data review and evaluation, and Inspection and

Enforcement Bulletins. -

Results: One violation was identified - Record of test does not include name of

,-. data recorder, paragraph 5.b.

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REPORT DETAILS

1. Persons Contacted

- Licensee Employees

• 0. S. Bradham, Director, Nuclear Plant Operations

• J. _ G. Connelly, Deputy Director, Operations and Maintenance

• A.1R. Koon, Associate Manager, Regulatory Compliance

F. A.. Miller, Associate Manager, Quality Control Systems

• T. Boyers, Quality Control _ Systems Coordinator

• A. D. Torres, NDE (Nondestructive Examination) Supervisor

.D. R.. Moore, Group Manager, Quality Services

W. T._Frady, Associate Manager,' Procurement Systems

F. J. Leach, Manager, Quality Assurance

'D. R. Goldston, Shift Supervisor, Operations

W. R. Quick, Auxiliary Operator

• G. G. Soult, Associate Manager, Maintenance

• L..B. Collier, Welding Supervisor

• R. J. Bouknight, Technical Specialist, Regulatory Compliance *

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• C. J. McKinney, Technical Specialist, Regulatory Compliance

• M. D. Irwin, Nuclear Licensing Specialist

NRC Resident Inspector

• C. W. Hehl

• Attended exit interview

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2. Exit Interview 3,

The inspection scope and findings were summarized on March 15,_1985, with

those persons indicated 'in paragraph 1 above. The inspector described the

, areas inspected and discussed in detail the inspection findings -listed .

below,

a. Violation 395/85-10-01: Record of Test Does Not Include Name of Data

Recorder, paragraph 5.b.

< b. Unresolved Item 395/85-10-02: Leakage Test Boundary, paragraph 6.a.

c. -Inspector Followup Item 395/85-10-03: Was Stroke Timing and Position

Indicator Verification Required and Performed, paragraph 5.c.

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The licensee indicated disagreement with the violation listed above. The

NRC inspector initially identified the item as unresolved pending discussion

with NRC management. Following his discussion with his management on

March 18, 1985, the inspector notified the licensee by phone that the item

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would be a violation.

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The licensee did-not identify as proprietary any of the materials provided

to or reviewed by the inspector during this inspection.

3. Licensee Action on Previous Enforcement Matters

(Closed) Unresolved Item 395/84-21-01: Exercising Emergency Feedwater

Discharge Check Valves to Closed Position. This item was opened to address

the NRC inspector's concern that the licensee did not appear to have

procedural requirements that would verify the proper closure of the subject

check-valves. A generic problem with regard to adequate closure of such

valves had been -identified in NRC Inspection and Enforcement Information

Notice No. 84-06. Excessive back-leakage through such valves, disabling the

emergency feedwater pumps had been identified at other plants with similar

systems. The inspector had found no procedures in the licensee's pump and

valve test program that would assure that they would not have such pump-

disabling leakage.

During the current inspection, the inspector discussed the matter with the

licensee and found that they had taken action (prior to his original

questioning) to assure that they did -not have excessive back-leakage and

that further actions were under consideration. The inspector verified the

licensee's current chec'ks , which require once-a-shift temperature

measurements on the pump side of the valves to detect any back-leakage of

hot feedwater, by examining the Auxiliary Building logs for March 1-8, 1985,

to verify that appropriate temperatures were recorded. The inspector is

satisfied that the licensee's program has been and is properly addressing

this matter.

4. Unresolved Items

. Unresolved items are matters about which more information is required to

determine whether they' are acceptable or may involve violations or

deviations. A new unresolved item identified during this inspection is

discussed in paragraph 6.a.

5. Inservice Testing of Pumps and Valves (92706B)

The inspector observed pump testing and reviewed records of pump and valve

tests to determine the licensee's compliance with their commitments and the

regulatory requirements including the requirements of the Code applicable to

the testing, ASME Section XI (77S78). The inspector's observation and

review are described below,

a. Observation of Test Performed on Residual Heat Removal (RHR) Pump

The inspector observed selected activities in the performance of the

pump test required by the Code on RHR pump B. The licensee's procedure

for this test is Surveillance Test Procedure (STP) 105.004, Rev.7. The

inspector specifically observed the valve alignments and taking of flow

and pressure data to verify the following:

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(1) Propergageslu' sed

(2) Gage calibration verified

<(3) ; Pump run of sufficient. time toLassure stability before taking data-

(4) ,Special valve alignments conducted

(5) z Gages properly read (pressure and flow data)

(6) ' Data properly recorded

- b. Review of Record of RHR Pump Test

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The inspector reviewed: the ' data sheets for the' pump test described

above to verify that all of the data and verifications required by the

procedure had properly recorded and met the Code requirements. The

Linspector found that the data sheet did not identify the names of .any

- -of the individuals involved in taking any of the test data pressure,

~ flow or vibration. A Surveillance Test Tracking. Sheet (STTS) used as

'a cover sheet for the test data. identified the individual responsible

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for the test and indicated the test'date. However, this individualsdid

not- record either 'the pressure and flow data or the vibration data

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required by the procedure and did not observe the recording of the

data. The inspector _'noted that 10 CFR'50, Appendix B, Criterion XVII, >

requires that. test records identify the data recorder. The licensee's

failure to identify .the ~ data recorder i s identified as . Violation l

395/85-10-01, Record of Test Does Not Include Name of Data' Recorder. "

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c.  : Testing: Valves After' Repairs

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The inspector: reviewed thel licensee's computer listing' of valve-

maintenance activities. performed during the 1984 refueling outage to ,

determine what work had been performed on valves and selected two

valves to ' determine whether they had received Code required testing

following - maintenance. .

The valve numbers, Maintenance Work Request - 3

(WR)' numbers, and the type of repairs indicated on- the listing for the-

valves. selected were as follows:

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(1) . Component Cooling Val.ve No. XVG09568-CC, WR No. 84M0734:' Repair-

To A1leviate Binding; WR No. 8402304: Electrical Repair to

Correct Conditions that Cause Leak-Rate Failure-

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(2) Component Cooling Valve No. XVG09605-CC WR No. 8402306: Repair-  !

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to Operator of Valve

The computer listing indicated that leakage tests were performed on the ,

valves after repair. The listing did not identify the performance of 2

The' . inspector' questioned whether ithe

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any other Ccde valve tests.

repairs performed on~these valves ~would not have made remote. indicator

-verification and stroke' timing tests' also necessary in accordance with

th'e Code. The inspector informed the licensee that the question of

whether all required testing had -.been performed would be examined '

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' further in : a subsequent inspection. The inspector identified this

matter as Inspector- Followup Item 395/85-10-03, Was Stroke Timing and

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Position Indicator Verification Required and Performed.

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Within the areas. examined, no violations or' deviations were observed except

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_asireported in paragraph 5.b. above.

6;- Inservice Inspection Data Review and Evaluation (737558)

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The 11 nspector. reviewed _ inservice ' inspection (ISI) related records to .

. determine their compliance with the licensee's Technical Specifications and

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-ISI. program. Via reference from the Technical Specifications through 10 CFR

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50.55a(g), the Code applicable to the ISI is ASME Section XI (77S78). The

e inspector's review is described below.

a. Frequency and Extent of Examinations

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The inspector reviewed the records to verify that components required

L to be examined during the first refueling outage had been examined.

~ This ' included steam generator tubing, the reactor vessel . interior, and

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the_ ASME Class:1 exempt components identified _by the Code as

Category B-P. Further, . the inspector reviewed the records and

procedures for the reactor vessel interior and ASME Class 1 exempted

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components' examinations to verify that the extent of the examinations

were in accordance with the Code requirements. The inspector;found

~t hat the licensee's ' procedure for examination of exempted components,

' Procedure STP-150.001, Rev. 2, indicated _ an ' examination boundary that

omitted certain piping and valves that it appeared should have 'been

= examined. The Code required examination of exempted components

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consists of a visual examination for leakage and is performed at normal

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. reactor operating pressure. It covers those components that are

!- exempted 'from other Code. required. examinations - principally small

diameter oiping -and valves. The exempted components 'which the

inspector found to be omitted were all located beyond the first closed

valve in the exempted Class-1 piping and it appeared that the licensee

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had designated the first closed valve as the boundary. _ The inspector

u noted that this resulted in the omitted Class 1 components not

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receiving any examination until the hydrostatic test required at the

end of the first 10 year ' interval 'of commercial operation. -Licensee

personnel indicated that this was permitted and that they believed that

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it _ had - been addressed by a Code interpretation. The inspector found-

L the following notes in the Code -that are relevant to the question of '

the examination boundary:

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(1)- The ' Summer 1978 Addenda of the Code, which is the latest Addenda

L applicable to the -licensee's ISI examinations, identifies the

l_ requirement for the examinations in Table IWB-2500-1, Examination

l Category B-P. In a footnote to the requirements for the leakage

L e test, this table indicates that the (outer) test boundary is to

l- include the entire pressure boundary of the reactor coolant

i system.

(2) The subsequent 1980 Edition of the Code changed the footnotes at

the end of the table referred to in (1)~above to indicate that the

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examination should extend to the second closed valve in the system

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with all valves in their normal position. - This would eliminate

including an outer reactor coolant system valve if it was normally

open.

In accordance with either of the above, the examination boundary set by

_#% . the. licensee is unacceptable. The licensee excludes from their

",.7- examination boundary any valves beyond the first (normally inner)

closed valve. Examples of apparently improperly excluded valves

includes valves 1-8058A, B, and C as depicted on Drawing E-302-601,

Rev. 2IA. These valves are the second closed valves within the reactor

coolant pressure boundary.

This matter was identified near the end of the inspection and both the

licensee and inspector indicated they wished to research it further to

assure they fully understood the requirements. . As a consequence, the

inspector identified the matter as Unresolved Item 395/85-10-02,

. Leakage Test Boundary.

b .' Content of Records

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The inspector r.eviewed the records of selected ISI examinations to

verify that they contained or provided reference to the following,

where required:

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Examination results and data sheets

Examination equipment data

Calibration data sheets

Examination evaluation data

Records on extent of examination

Records on deviation from program and procedures including

i justification for deviation

Records on disposition of findings

Re-examination data after repair work

Identification of NDE material

The examinations addressed by the inspector in this review were as

follows:

Visual examination of the interior of the reactor vessel (Code

Examination Category B-N-1)

Visual examination of body of RHR system valve 8701B (Code

Examination' Category B-M-2)

Ultrasonic and penetrant examinations of steam generator A reactor

coolant system piping weld SDM, identified on drawing CGE-1-4100

(Code Examination Category B-J)

Magnetic particle examination of main steam system integral

support weld WS-6, identified on drawing CGE-2-2301 (Code

. . Examination Category C-C)

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. c. Compliance with Examination Requirements

The inspector reviewed the records of selected examinations of piping

welds to verify that the.following requirements were met:

' T'he i examination unit' calibration = data sheets . show no major

' deviations between initial and final calibrations.

Collected exaraination data and any. recordable indicationsT are

-properly recorded to permit accurate evaluation and' documentation.

Evaluation of examination ' data performed by ~ a Level II or

Level III' examiner.

. Evaluation of examination data. complies with the procedure.

Evaluation of indications (if applicable) comply with the criteria

of the NDE procedure and ASME Section XI.

Incomplete examinations and results were repeated to permit full

. evaluation (if , applicable).

The welds for which the examination records- were reviewed were as

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follows:

- ASME ~ Class 1, reactor coolant system. weld SDM on drawing.

CGE-1-4100.

ASME Class-1, safety injection system welds 1, 2,'and 3 on drawing

CGE-1_4104

d. .' Vendor Audit

The. inspector reviewed the records of the licensee's pre-award audit of

1the vendor who performed most of their ISI examinations during the 1984

refueling' outage. The ' vendor was Nuclear Energy ' Services,.

Incorporated. The inspector specifically. reviewed the audit report

dated September 18, 1984, the checklist used in performing the audit,

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and the handling of the one finding identified ~ in the audit. The

inspector's-review was performed to verify the following': ,

c' Completion and retrievability of required _ records for the survey

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in.accordance with their Quality Assurance Procedures QAP-16 Bland

o -QAP-20.

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Compliance with the: licensee's commitments to NRC Regulatory Guide'

~1.144. Rev. O, Auditing of Quality Assurance Programs for Nuclear

Power Plants

Within the areas' examined, no violations or deviations were identified.

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7. Inspection and Enforcement Bulletins (IEBs) (927038)

(0 pen) IEB 83-03: Check Valve Failures in Raw Cooling Water Systems of

Diesel Generators

This IEB deals with generic aspects of multiple swing check valve failures

identified ' in raw cooling water _ systems for diesel generators. The

licensee's initial response to this IEB, dated June 8,1983, was reviewed

and determined acceptable by Region II. The licensee had committed' to

perform tests, to verify the condition of the subject check valves, as

- requested ~ by the IEB. The inspector requested the records of the test.

Almost two days after the original request for records, the licensee

provided copies of data sheets for the tests but not the test procedure or

the final report to NRC requested by the IEB. When questioned on this

matter, the licensee indicated that the IEB had already been closed out by

another NRC inspector and that they had failed to prepare the final report.

The inspector requested and the licensee agreed that the licensee would

prepare and submit the final report required by the bulletin. The

inspector informed the licensee that the IEB would be re-opened for their

plant and.that it would remain open pending receipt of the final report and

review of the related records in a subsequent inspection.