ML20127H275
| 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: |
| 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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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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, 101 MARIETTA STREET,N.W.
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ATLANTA, GEORGI A 30323
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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.:
2.
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Facility Name:
Summer
Inspection Conducted: March 11-15, 1985^
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Inspe or:
v r E. H. Girard
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Date Signed
Approved by: [
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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
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Enforcement Bulletins.
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Results: One violation was identified - Record of test does not include name of
data recorder, paragraph 5.b.
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8505210262 850401
ADOCK 05000395
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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
- C. J. McKinney, Technical Specialist, Regulatory Compliance
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- 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.
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c.
-Inspector Followup Item 395/85-10-03: Was Stroke Timing and Position
Indicator Verification Required and Performed, paragraph 5.c.
,s,
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
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-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
for the test and indicated the test'date. However, this individualsdid
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not- record either 'the pressure and flow data or the vibration data
- required by the procedure and did not observe the recording of the
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data. The inspector _'noted that 10 CFR'50, Appendix B, Criterion XVII,
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requires that. test records identify the data recorder. The licensee's
- failure to identify .the ~ data recorder i s identified as . Violation
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395/85-10-01, Record of Test Does Not Include Name of Data' Recorder.
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c.
- Testing: Valves After' Repairs
The inspector: reviewed thel licensee's computer listing' of valve-
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maintenance activities. performed during the 1984 refueling outage to
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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 -
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(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
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valves after repair. The listing did not identify the performance of
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any other Ccde valve tests.
The' . inspector' questioned whether ithe
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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
_asireported in paragraph 5.b. above.
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Inservice Inspection
Data Review and Evaluation (737558)
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The 1 nspector. reviewed _ inservice ' inspection (ISI) related records to .
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. 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 50.55a(g), the Code applicable to the ISI is ASME Section XI (77S78). The
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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
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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
components' examinations to verify that the extent of the examinations
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were in accordance with the Code requirements. The inspector;found
~ hat the licensee's ' procedure for examination of exempted components,
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' 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
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
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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
had designated the first closed valve as the boundary. _ The inspector
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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
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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-
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the following notes in the Code -that are relevant to the question of
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the examination boundary:
(1)- The ' Summer 1978 Addenda of the Code, which is the latest Addenda
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applicable to the -licensee's ISI examinations, identifies the
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requirement for the examinations in Table IWB-2500-1, Examination
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Category B-P.
In a footnote to the requirements for the leakage
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test, this table indicates that the (outer) test boundary is to
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include the entire pressure boundary of the reactor coolant
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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
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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.
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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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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 ~
Level II or
a
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
follows:
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- 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
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inspector's-review was performed to verify the following':
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Completion and retrievability of required _ records for the survey
in.accordance with their Quality Assurance Procedures QAP-16 Bland
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-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.