ML20127K298

Insp Rept 50-395/85-13 on 850301-31.Violations Noted: Failure to Adequately Implement Procedures Governing Installation of Scaffolding & Lack of Valid Senior Operator License by Person Directing Licensed Operator Activities

ML20127K298
Person / Time
Site:	Summer
Issue date:	04/19/1985
From:	Cantrell F, Hehl C, Wagner P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20127K283	List: ML20127K278 ML20127K285 ML20127K298
References
50-395-85-13, NUDOCS 8505220088
Download: ML20127K298 (11)

See also: IR 05000395/1985013

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UNITE'3 STATES

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ATLANTA, GEORGIA 30303

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A' Report No.: 50-395/85-13

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\ Licensee: . South Carolina Electric and Gas Company '

Columbia, SC 29218

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

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Facility Name: 'V. C. Summer

Inspection Conducte : March 1-31, 1985

Inspectors:

C. W. Hehl

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Dste ' Signed

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P."D. Wagnei- U ~

Date Signed

Approved-by: 4. ////9/D

F. S. Cantfell, Section Chief

Division of Reactor Projects

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SUMMARY

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Scope: This routine, unannounced inspection entailed 129 inspector-hours in the

areas of plant tours; operational safety verifications; monthly surveillance

. observations; monthly maintenance observations; followup on written reports of a

non-routine events; action on previous enforcement items and inspector followup

items; onsite followup of operating events; and independent inspection effort.

l .Results: Two violations were identified - failure to -adequately implement

l. . procedures governing installation of scaffolding; designated individual directing

the activities of licensed operators did not possess a valid senior operator

license.

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PDR ADOCK 05000395

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

• 0. Bradham, Director, Nuclear Plant Operations

K. Woodward, Manager, Operations

B. Williams, Supervisor of Operations

M. Quinton, Manager, Maintenance

• M..Browne, Manager, Technical Support

• B. Croley, Group Manager, Technical and Support Services

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• H. Sefick, Associate Manager, Station Security

• R. Fowlkes, Regulatory Compliance

• J. Cox, Associate Manager, Health Physics

- *J. Derrick, Associate Manager, Maintenance Engineer

• W. Bacon, Associate Manager, Chemistry

• D. Nauman, Director, Nuclear Services

• W. Williams, Jr., Special Assistant, S. C. Public Service Authority

• G._ Putt, Manager, Scheduling & Materials

• 0.:Dixon, Vice President, Nuclear Operations

• M. Blue, Nuclear Licensing Engineer

• M. Irwin, Nuclear Licensing

-*J. Harrison, Manager, Nuclear Security

• S. Hunt, Associate Manager, Quality Assurance Site Surveillance

• W. Baehr, Manager, Corporate Health Physics and Environmental Programs

• J. Connelly, Deputy Director, Operations & Maintenance

• A. Koon, Associate Manager, Regulatory Compliance

• D. Malhmus, Independent Safety Engineering Group

Other -licensee employees contacted included engineers, technicians,

operators, mechanics, security force members, and office personnel.

• Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized on March 29, 1985, with

those persons indicated in_ paragraph 1 above. The licensee acknowledged the

inspection findings and had no comment. 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 Items (92702)

(Closed) Violation 84-25-04, Fuel Handling Crane Operator Qualifications and

Training. This violation was due to an inadequate program governing crane

operator training. The program failed to properly indicate which

individuals were qualified for crane operation. As a result, an unqualified

operator was allowed to operate the crane. Also, the operator failed to

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perform the preoperational crane inspections. The licensee has subsequently

- compiled - a list- of currently qualified Fuel Handling Building crane

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Loperators. Also, the crane operator training program has been upgraded and

.  : training ; responsibility assigned to the Nuclear Technical Education and  :

Training Group.'~ (This training program was implemented on January 31, 1985

and :is dividedLinto five different types of- operator qualifications. .The-

. licensee's~ corrective actions appear adequate.

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i4.. . Operational; Safety-Verification (71707, 71710)

.The inspector observed control room operations, reviewed applicable logs and

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conducted discussions with control room operators during the report period.

The inspector verified the operability of : selected emergency systems,

reviewed. removal and restoration logs, and tagout records, and . verified

-proper return _ to iservice of affected components. Tours of the control,

' auxiliary, intermediate, diesel . generation, service water and turbine

buildings were conducted -to observe plant equipment conditions including

. potenti_al: fire hazards, fluid -leaks, and excessive vibrations, and _to verify

that maintenance requests had been initiated for equipment in need of-

' maintenance. The inspector, by observation and direct interview, verified

that the physical security plan was being implemented.

Findings in this area were satisfactory with the following exception:

During -a tour of the Diesel Generator (DG) building on March 21, 1985, the

inspector observed that scaffolding had been erected in both DG rooms. .Each

scaffolding, as constructed, spanned the DG unit, passing over the diesel to

generatolr_ coupling area, thus posing a potential fall-down hazard to the DG'

units during a seismic event. The licensee was immediately notified of the o

_ inspectors observation. Following field evaluation of the scaffolding by

the -licensee's Maintenance - Engineering -management, the scaffolding was -

' removed. The unit was at full power at the time of this occurrence.

The erection of scaffolding in areas such as the DG rooms is governed by the.

licensee's General' Maintenance Procedures (GMP) 101.008, Seismic and Vital

Equipment Area Scaffolding / Shielding Evaluation and Utilization. GMP

101.008 requires that, prior to the installation of scaffolding, an

engineering evaluation be conducted and that this ' evaluation include the

impact scaffolding will have on applicable equipment or areas during a

seismic event. Should this evaluation determine the operability of

equipment or_ areas could be adversely affected during a seismic event, the

equipment is to be declared inoperable prior to erection of the scaffolding.

Subsequent inspector review determined that the scaffolding had been erected

on March 20 and 21,1985, to support performance of scheduled preventative

maintenance on the overhead chain hoists located in the DG rooms. As

required by GMP 101.008, prior to erection, requests for scaffolding in

these areas had been evaluated and approved by Maintenance Engineering.

Discussions with Maintenance Engineering determined that this evaluation was

in error and occurred as a result of a communications breakdown with the

scaffold builders in that the scaffolding envisioned by the evaluating

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engineer was not-what was actually constructed. GMP 101.008 did not require

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nor.did the engineer makeja field inspection of the' scaffolding site during

.or.after erection. Since the scaffolding evaluation did not identify- any-

-adverse impact on the - DGs, they were not declared inoperable when the

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' scaffolding was installed.

Technical. Specification- '6.8.1 requires that written procedures be

established, . implemented and -maintained covering the applicable procedum

recommended in Appendix A .of Regulatory Guide- 1.33, Revision 2

February 1978.' Regulatory Guide'1.33 recommends that. general procedures for

the control of maintenance, repair, replacement and modification work be

prepared. GMP' 101.008 implements this requirement for erection of;

. scaffolding:in seismic and vital equipment areas.

Contrary to the above requirements, the scaffolding actually constructed in

the DG rooms on' March-20 and 21, 1985 was not adequately evaluated prior to

' installation for . impact on ' applicable equipment during a seismic event.

This is a violation (85-13-01).

-5. Surveillance Observation (61726)

During the inspection period, the inspector verified by observation / review

that'. selected surveillance- of safety-related systems or components was

. conducted in accordance with adequate procedures, test instrumentation was

calibrated, limiting conditions for operation were met, removal and

. restoration of the affected components were accomplished, test results met

requirements and were reviewed by personnel other than the individual

directing the test, and that any test deficiencies identified during the

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i testing were properly reviewed >and resolved by appropriate management

personnel.

No violations or deviations were-identified in this area.

6. Maintenance Observation (62703)

Station maintenance activities of selected safety-related systems and

components were observed / reviewed to ascertain that they :were conducted in

accordance with regulatory requirements. The following items were

considered.in this review: .the limiting conditions for operations were met;

activities were accomplished using approved procedures; functional testing

and/or. calibrations were performed prior'to returning components or systems

to service; quality control record ~ were maintained; activities were

accomplished by qualified personnel; parts and materials used were properly

certified; and radiological controls were implemented as required.

Maintenance work requests were reviewed to determine status of outstanding

jobs to ~ assure that priority was assigned to safety-related equipment which

might affect system performance.

No violations or deviations were' identified in this area. )

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- T. :On Site Followup:of Written _ Reports of Non-routina Events (92700)

W LThe c inspector < reviewed the : following . Licensee Eventi Reports (LERs) to

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- ascertain;whether the' licensee's review, corrective action, and report of

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~ the11dentified : event ~and ' associated conditions were adequate and ~in

conformance with: regulatory requirements, Technical Specifications, license

' conditions,~and licensee procedures and controls.

. (Closed) Special Report SPR 84-003, SeismicjInstrumentation. This licensee.

- special report, dated March 5, .1984, discussed the identification - of.~ a

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m ' damaged electronic chip in a redundant circuit which provides.annunication

to:the Main Control Board. :No repairs were made within 30 days since the

licensee was: reviewing a. vendora recommended modification which included.

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deletion 4 of .this' circuitry - in order to. reduce the difficulty, and

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inaccuracies of recalibrating the recorders.in the field. The modifications

were' performed and the instrument returned to' service on March 15, 1984.

(Closed) Special Report .84-009, Fire Rated Assemblies. This licensee

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special report dated June 27,.1984, discussed the inoperability of a drywall

fire barrier > in :the ' Intermediate : Building: due to implementation of 'an

approved modification which installed a new concrete curb requiring seven

" days to" cure. A- roving fire watch was established during the period of

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vinoperability. The fire barrier was reinstalled and operable 'on June 14,

1984;

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- ,. (Closed) LER 83-103, . Late Analys1s Following -Power Change. This :LER

' V' reported the failure to perform Reactor' Coolant System Iodine Isotopic

- Analysis -' between two and six hours following a thermal power change

- exceeding 15 percent of. rated power within a one hour period. The analysis

was subsequently performed approximately one hour late. As a result of this

event',--the licensee identified corrective actions which included additional

training for' chemistry specialists on Technical Specification -requirements

and shift turnover proceduresa changes to Station Administrative Procedure

(SAP) 400 ' to incorporate aishift turnover checklist for oncoming and

- offgoing specialists,'and a change to General Operating Procedure (GOP)'4 to

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~ * require the: Operations Group to notify Chemistry when loading or unloading-

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the~ turbine. The inspector reviewed these' corrective actions and found them

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(Closed) _LER 84-001, Failure to Sample Service Water Effluent. This LER

identified six occasions- during which daily grab samples of the Service

Water ' Effluent were not taken.- The inspector. reviewed the licensee's

corrective actions which included implementing SAP .502, dated September-7,

1984,- incorporating computer generated daily and' weekly Technical

4 Specification' sampling requirements. The monthly surveillance requirements

t are addressed -in Surveillance Test Procedure (STP) 901.001. These

corrective actions appear adequate.

(Closed) LER 84-002, Missed Hourly Roving Fire Watch Patrols. This LFR

identified a failure to perform required fire watch patrols in the Auxiliary

Building for an eight hour period. The licensee has instituted a program by

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R which theLroving fire watches on the midshift will verify required checks.

per 'the Removal. and Restoration Log -with'~ the Shif.t Supervisor at midnight

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each day. This corrective action, along with the _ current use of the Fire

Barrier Removal Log appears adequate to prevent recurrence of similar

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events.

? (Closed)) Special .. Report SPR 84-004, Visual ~ Inspection of Fire Dampers Not

performed. This licensee' speciali report, dated - April 10, 1984, discussed

-the fact'that' fire dampers had not been visually inspected since the Startup-

Test - Program.- The licensee had initially thought that the dampers were-

inspected- during EFire- Rated Assembly inspections conducted after Startup

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Testing,z however' these inspections only documented that the dampers ' were

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iinstalled.' The licensee took the following corrective actions; (1)' A 100

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percent functional ~ test 'of the. fire dampers was conducted. (2) A roving -

fire watch :of the entire plant was instituted until the functional testing

was completed. (3) A program was developed whereby the fire damper.

' inspections will be performed in conjunction with the annual ventilation

preventive maintenance program. This program eliminates' duplication 'of

Leffort and is in conformance with the NFPA Code. The fire . damper

' inspections- have been'- incorporated into STPs 128.060 - 128.065. This

corrective action appears-adequate.

-(Closed) Special Report SPR 84-005, Improper Functioning of Fire Dampers.

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As'part of the corrective action which was stated in Special Report 84-004,

the : licensee performed a 100 percent functional test of. the fire dampers.

Ten ' fire

dampers did not perform as designed due to mechanical inter-

ferences;or malfunctions. A roving fire watch was already established as

outlined in . Special Report 84-004. The ten dampers were repaired,

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functionally tested, and declared operable.

(Closed) LER 83-066, Torn Kaowool Wrap. Fire barrier Kaowool Wrap on

conduit SWC-87C was inoperable due to being torn by traffic on a nearby

access ladder.' 'The licensee replaced the Kaowool and installed a protective

- metal cover over it. This LER was previously reported closed in inspection

. report 83-30. However, report 83-30 contained no refer.nce to this LER. It

Lis believed that this LER had not been looked at previously.

(Closed) LER 84-020, Low Fluid 011' Pressure Switch Calibration. The

.11_censee : identified an ' inadequate calibration procedure during the

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performance of 'a surveillance on low fluid oil pressure switches. The

procedure ; failed to clearly identify and document calibration of the

individual Train related low fluid oil pressure switches. Surveillance Test

ProcedureJ(STP) 302.035 was revised. Following the revision, one switch in

each . channel was ' found to exceed Technical Specification limits. ~The

procedure revision appears adequate to prevent recurrence of this event.

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(Closed) LER 84-015, Purge and Exhaust Air Supply Valves Found Open.

. Operations. personnel found all 4 air supply valves open to the 36 inch

' Reactor- Building Purge valve. The valves cannot be physically locked;

therefore, they are enclosed in a locked box. During a valve lineup, these

valves we,re not verified to be shut prior to locking the lock box. The

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licensee conducted a special training session with all operators concerning

valve position requirements when a lock box is present. The corrective

action appears adequate.

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(Closed) LER 84-013, Smoke Detectors Temporarily Inoperable. The licensee's

Plant Integrated Fire and Security System was modified with new software.

During an administrative review by the licensee, it was discovered that the

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' monitoring of smoke detectors in tow zones of the Intermediate Building had

been deleted. The discrepancy was corrected, tested, and verified operable.

(Closed) LER 84-012, Missed Surveillance on Reactor Building Emergency

Escape Hatch. A required leak rate test was not performed within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />

following closure of the Reactor Building escape hatch. The licensee

conducted the required surveillance test immediately upon discovery

(approximately one day late). The licensee also issued Special Instruction

84-11, Reactor Building Closecut, which requires performance of applicable

surveillance tests following entry for either maintenance or operational

inspections. One copy of this Special Instruction is maintained in the

Control Room.

(Closed) LER 83-119, Turbine Room Sump Liquid Radiation Monitor Insufficient

Sample Flow. The cause of the low sample flow was a clogged strainer in the

sensing line. The strainer was subsequently cleaned and the radiation

monitor returned to operable status. The licensee also completed a

modification (MRF-20355) which installed a strainer capable of being

backflushed. These corrective actions appear adequate.

(Closed) Special Report SPR 84-006, Degraded Kaowool Fire Barriers. The

licensee identified a number of Kaowool fire barriers which were degraded.

However, due to inadequate documentation, not all of the degraded Kaowool

was repaired. The licensee took the following corrective actions:

(1) Degraded fire barriers are to be identified by placing a Maintenance

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Item Identification Tag at each unsatisfactory location. The total number

of tags are to be identified on the associated MWR. (2) The appropriate

MWRs will be forwarded to the Fire Protection Coordinator (FPC) after work

is completed and QC inspections performed. The FPC will also perform an

inspection. These corrective actions appear adequate.

(Closed) Special Report SPR 84-002, Degraded Fire Rated Wall. This licensee

special report, dated February 29, 1984, discussed a hole which was found in

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a fire rated wall in the Control Building. The hole did not penetrate to

the other side of the wall. The area was repaired.

! (Closed) LER 84-025, Reactor Trip Due To Improper Review of System Status.

(Closed) LER 84-019, Pressurizer Safety Relief Valves (PSRV). The LER was

submitted as a followup to a telephone conference with NRC Region II. PSRV

XVR-8010-C was removed and tested in accordance with the ISI program. The ,

valve lifted above allowed Technical Specification setpoint limits. The

valve was adjusted and reinstalled. Also, XVR-8010-A was removed due to

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suspected leakage. The leakage was verified and the valve was replaced with

a spare relief valve.

(Closed) LER 84-016, Actuation of Emergency Safety Feature Load Sequencer.

(Closed) LER 84-03, Composite Sample of Gaseous Effluent Lost / Discarded.

The licensee reported that a number of Main Plant Vent Exhaust and Reactor

Building Purge quarterly composite samples were missing. No alpha or gamma

activity was detected on the lost filters or on the remaining filters from

the composite period. The licensee has constructed a special container for

filter storage and instituted a log book accountability system for these

filters.

(Closed) LER 84-004, Degraded Fire Barrier.

(Closed) Special Report SPR 84-003, Open Fire Doors to Provide Cooling.

This licensee special report, dated July 27, 1984, discussed a licensee

concern that a potentially inadequate HVAC supply for Chilled Water Pump

Rooms "A" and "C" exited. The licensee opened fire rated doors to assist in

cooling. However, additional analysis indicated that adequate cooling was

available. The fire doors were then restored to operable status.

8. Review of Inspector Followup Items

(Closed) Inspector Followup Item (IFI) 82-49-12, Undetectable Failure in the

Solid State Protection System (SSPS). In August, 1982, the NRC was notified

by SCE&G of an undetectable failure which could exist in the SSPS on line

test circuits. Interim actions and final resolutions are discussed in

reports transmitted by the licensee on September 3, 1982, November 29, 1982,

February 2,1983, July 29,1983, and November 20, 1984. During the facility

first refueling outage, the licensee implemented a Westinghouse developed

hardware modification which eliminates the undetectability of this potential

failure. The inspector reviewed Modification Request Form (MRF) 20358 and

its associated documentation describing the implementation of this hardware

modification. This item is considered closed.

(Closed) IFI 82-41-14, Low Power Testing. This IFI was opened tc track a

licensee commitment to meet condition (23)b of the Unit 1 Facility Operating

License. Condition (23)b stated SCE&G shall provide a report describing the

results of a comparison of the actual plant data taken during the natural

circulation test program to the simulator responses described in the SCE&G

1etter, T. C. Nichols, Jr. to H. R. Denton dated March 31, 1982. This

commitment was met by a reprot from 0. W. Dixon, Jr. to H. R. Denton

submitted on July 16, 1984.

(Closed) IFI 84-30-03, Level of Supervision of Spent Fuel Pool Activities.

The licensee has implemented a change to Station Administrative Procedure

(SAP) 200, Conduct of Operations (Revision 2, Change A), requiring an

Operations Group Supervisor to supervise all activities related to fuel

movements that are performed in the Fuel Handling Building. This change

also lists specific responsibilities of the Fuel Movement Supervisor. The

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-licensee has also implemented a change. to Reactor Engineering Procedure

(REP) 100.001, i Special Nuclear Material Inventory and Control, which

identifies spent fuel pool rack _ locations that are unacceptable for storage

of fuel assemblies. _ These identified unacceptable ' locations _ will 'only be

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used for.-- storing burnable poison assemblies. These changes adequately

implement licensee commitments described in IE Report 84-30.

(Closed) IFI 82-31-03,. Wide Range Reactor Coolant System Pressure

Transmitter. On May 12, _ September 8, December. 29, 1982 and November 28,

1984, the licensee provided; to the NRC reports on a. substantial safety

hazard concerning the wide range reactor coolant pressure' transmitters.

Those reports described interim and final corrective actions taken to

resolve this -issue. The final . corrective action taken was the imple-

mentation 'of a modification, proposed by Westinghouse, involving instal-

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'lation of two new' wide range pressure transmitters in a mild environment

outside containment using the Reactor Vessel Level Indication System (RVLIS)

pressure- sensing lines. The existing wide range pressure' transmitters were

removed and .their lines icapped. The inspector reviewed the associated

modification package, MRF 20306, documenting implementation _of this

corrective action. MRF 20306 was completed and the system declared operable

on December 7,1984. There were no adverse findings identified during this

review.

9. Onsite Followup of Events at Operating Reactors (93702)

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a. At 9:34 on March 13, 1985 with the unit at 100% power, electricians

performing preventative maintenance.(PM). inadvertently started Reactor

Building (RB) Spray Pump A. The control room operator immediately

secured the pump. No spray into the Reactor Building occurred as the-

pump's downstream isolation valve had been closed ' for the PM; a

subsequent reactor building entry confirmed no spray flow had occurred.

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The event occurred during performance of Electrical Maintenance

Procedure (EMP) 445.001, - Limitorque Preventative Maintenance, on ' RB

Spray Isolation Valve XVG 3003 A. While adjusting the setting of the

shut . valve operator limit switch, the electrician aused a ground in

the limit switch circuitry which actuated RB Spray r> ump A through its

associated Safeguard Test Cabinet Test Relay,'. K644. No'other actions

occurred or were expected when the K644 relay actuated.

The clicensee has evaluated and determined no ill effect resulted from

the period of time the RB Spray' Pump operated with the spray isolation

p valve closed. The licensee is continuing to evaluate and formulate

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. actions to reduce the likelihood of recurrence of this type event.

b. At 5:03 a.m. on March 17, 1985, while performing surveillance testing

+ ' on .the Main Steam- Isolation Valves (MSIV's), MSIV PVM-2801A closed

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fully resulting in a steam generator A low level reactor trip. The

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unit was at 100% power at the time of the trip. All safety systems

appeared to function properly during the event with the exception of

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Steam Generator Feedwater Isolation Valve XVG 1611A which cycled

open/ closed until the feedwater isolation was reset. The plant was

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stabilized - in Mo'de 3.- Hot Standby, following the event. Subseq'uent

troubleshooting of ~ MSIV PVM-2801A control circuitry determined that a

faulty test switch _ for the MSIV caused the valve closure. The test

switch was replaced, -.the MSIV .successfully tested, and following

completion of post-trip review,' the unit was brought critical at 3:24

p.m.,.on.. March 17, 1985.

Sur.veillance Test Procedure (STP) 121.002, Main Steam Valve Operability

Test 'was in progress when the trip occurred. STP 121.002 implements

the requirements of ASME'Section XI to demonstrate operability of the

MSIV by stroking .these' valves partially closed at least once per 92.

days. . The circuitry for each valve, actuated through individual test

switches, causes the associated MSIV to close 10% then reopen. The

test switch failure, that resulted in PVM-2801A going full closed,

occurred when - switch contacts which return - the normal air supply to-

~ the MSIV failed to close when the switch was returned to its normal

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.(non-test) position.

The 'above noted cycling of Steam Generator Feedwater Isolation Valve

XVG 1611A' is a recurring problem believed to result .from an internal

-hydraulic . leak within the valve operator. This cycling action of XVG

.:1611A was observed and investigated following the reactor trips of

February 16 and 27,1985. _ and reported in LER 85-001. .After closure,

the valve cycles open approximately one-half inch, then closes again.

the period of cycling is approximately thirty-five seconds._ The

licensee has discussed this condition with NRR and has committed to

repairs-during the next outage of sufficient duration. In the inter _im,

' a temporary modification was installed that adds a trip of the feed-

water booster pumps -to the feedwater isolation actions initiated by

a safety injection signal. Accomplishment of final repairs will be

reviewed as part.of the closure requirements for LER 85-001.

'10. Independent-Inspection (92706)

' On . March 29, 1985, the licensee reported that due to a administrative

oversight, the . license- renewal- application for one of the Control Room

Supervisors (CRS) had not been submitted. The subject CRS's Senior Reactor

' Operator; (SRO) licensee expired on February 3, 1985. The CRS .was

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immediately removed from licensed duties. During the period between

. February'3, 1985 and March 20, 1985 the CRS had been actively engaged in his

licensed duties of directing the licensed activities of' licensed operators.

.The licensee reported .that in November 1984, a renewal application for the

CRS'had been prepared but was not submitted. This discrepancy was found

during a Nuclear Education and Training Department self-initiated audit of

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. license renewal applications. The licensee did not have a method for

tracking the status of. license renewal applications.

From February 3,-1985 to March 20, 1985, the CRS was on shift performing his

~ 1icensed duties on 29 days. A review of shift schedules and control room

log- book Lentries revealed that for each.of the twenty-nine days the number

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of SR0s on _ shift met the TS requirements without . reliance on the CRS's

expired license. Additionally, on all but two da'ys, either the operator at

the controls or the assistant control room operator were licensed at the

senior reactor operator level. Inspector review of training records for the

subject CRS determined that he had been a successful participant in the

Licensed.0perator Requalification Program and had received a passing grade

on the Annual Requalification Exam..

10 CFR 55.33, Renewal of Licenses, requires that. for. a license not to

expire, not less than thirty days prior to expiration of the existing .

license, the. licensee must submit an application for renewal in proper form.

The failure of the licensee (CRS) to submit an application for renewal

resulted in the expiration of his license on February 3,1985.

10 CFR 50.54(1), Conditions of ' Licenses, requires the licensee (SCE&G) .to

designate individuals to be responsible for directing the -licensed

activities of licensed operators. This part further states that these

individuals shall be licensed as senior operators pursuant to 10 CFR

Part 55.

' Contrary to this requirement, during the period February 3, 1985 to .

March 20, 1985 the subject CRS, who did not possess a valid senior operator

license, was an individual designated by the licensee and did perform the

duties of directing the activities of licensed operators. This is a

violation (85-13-02).

4