ML20128K519
| ML20128K519 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 05/31/1985 |
| From: | Blake J, Girard E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20128K510 | List: |
| References | |
| 50-395-85-22, NUDOCS 8507100606 | |
| Download: ML20128K519 (8) | |
See also: IR 05000395/1985022
Text
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. UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION 11
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,101 MARIETTA STREET, N.W.
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~ ATLANTA. GEORGI A 30323
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' Report No.:/ 50-395/85-22
Licensee:
South Carolina Electric and Gas Company
Columbia, SC 29218
Docket No.: 50-395
License No.: NPF-12
Facility Name: Summer
Inspection Conducted: May 13-17, 1985
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Inspector:
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E. H. Gi ar
Sate Signed
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1 Approved b .
J
Blale, Section Chief
Date Signed
neering Branch
ision of Reactor Safety
Sut9tARY
Scope:
This routine, unannounced inspection entailed 34 inspector-hours on site
in the areas of licensee action on previous enforcement matters, steam generator.
tube leakage, Inspection and Enforcement Bulletin 83-03, and inspector followup
items.
Results:
One violation was identified - Inadequate review of surveillance test
procedures, paragraph 3.a.
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REPORT DETAILS
1.
Persons Contacted
Licensee Employees
- J. G. Connelly, Deputy Director, Operations and Maintenance
- A. R. Koon, Associate Manager, Regulatory Compliance
F. A. Miller, Associate Manager, Quality Control Systems
- A. D. Torres, NDE (Nondestructive Examination) Supervisor
D. R. Moore, Group Manager, Quality Services
- F. J. Leach, Manager, Quality Assurance (QA)
- B. G. Croley, Group Manager, Technial and Support Services
- K. W. Woodward, Manager, Operations
- G. G. Putt, Manager, Scheduling and Material Management
J. W. Turkett, Engineer, Maintenance Engineering and Support
- M. D. Quinton, Manager, Maintenance Services
L. B. Collier, Welding Supervisor
R. J. Bouknight, Technical Specialist, Regulatory Compliance
- C
J. McKinney, Technical Specialist, Regulatory Compliance
M. D. Irwin, Nuclear Licensing Specialist
- F. Zander, Manager, Nuclear Technical Training
- J. F. Helman, Associate Manager, Nuclear Operations Education and Training
M. Williams, Manager, Nuclear Operations Education and Training
- M. D. Blue, Nuclear Licensing Engineer
NRC Resident Inspector
- C. W. Hehl, Senior Resident Inspector
- Attended exit interview
2.
Exit Interview
The inspection scope and findings were summarized on May 17, 1985, with
those persons indicated in paragraph I above.
The inspector described the
areas inspected and discussed in detail the inspection findings.
No
dissenting comments were received from the licensee.
The following new
items were identified during this inspection:
a.
Violation 395/85-22-01:
Inadequate Review of Surveillance Test
Procedures, paragraph 3.a.
b.
Unresolved Item 395/85-22-02:
Training for Visual Examinations,
paragraph 3.b.
The licensee did not identify as proprietary any of the material provided to
or reviewed by the inspector during this inspection.
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3.
Licensee Action on Previous Enforcement Matters
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(Closed) Unresolved Item (395/85-10-02):
Leakage Test Boundary. This item
was opened to address the NRC inspector's finding that the test boundary
identified in the licensee's procedure for leak testing the reactor coolant
pressure boundary (procedure STP 150.001, Rev. 2) appeared inaccurate. The
requirements for the test stem from Technical Specification (TS) 4.0.5 which
specifies inservice inspection requirements in accordance with ASME
Section XI and applicable addenda (hereafter referred to as the Code)
identified through 10 CFR 50.55a(g).
In accordance with 10 CFR 50.55a(g),
the Edition and Addenda of ASME Section XI (the Code) applicable to the
Summer plant is the 1977 Edition with Addenda through Summer 1978 (77578).
The Code requires that all ASME Class 1 pressure retaining components be
visually examined for leakage each refueling outage.
During the current NRC inspection the inspector continued his examination of
the licensee's compliance with reactor coolant pressure boundary leakage
test requirements.
In his examination he specifically addressed the
adequacy of the procedure, and the training and qualification of personnel
for performance of the test.
These were examined for compliance with Code
and other regulatory requirements.
The inspector's findings are described
below,
a.
Procedure
The inspector found that the licensee's procedure for performing leak
testing of the reactor coolant pressure boundary components was
inadequate relative to the following:
(1) The outer test boundary for the test as specified in the Summer
1978 Addenda of the Code and clarified in 1980 Edition includes
the entire pressure retaining boundary and extends to the second
of two closed valves. The licensee improperly identified the test
boundary as the first closed valve.
This omitted piping and
valves beyond the first closed valve.
For example, valves 8701A
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and B and the piping between them and valves 8702A and B
respectively, were omitted from testing by the procedure.
It also
omitted as boundaries the flow restrictors in many small diameter
lines - for example, the flow restrictor in the 3/4-inch line at
the Class 1 to Class 2A boundary at location A-15 on drawing
E-302-691.
(2) The examination required by the procedure is extensive.
It
addresses all ASME Class 1 components. There are many components
and locations to be examined for leakage-in affect, many
individual examinations.
The procedure does not provide a means
to assure that examination points are not inadvertently bypassed.
It does not identify the individual examination points and does
not provide for sign-offs to verify individual examinations or
groupings of examinations related by close proximity.
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(3) The procedure uses "should" where "shall" is appropriate for
specifying certain requirements.
For example, section 2.1 of the
procedure states "all requirements for the radiation work permit
should be adhered to".
(4) The acceptance criteria specified by the procedure . revision
originally questioned (150.001, Rev. 2) are not fully correct. As
stated in Attachment 1 to the procedure, the acceptance criteria
are (a) no observable weld leakage and (b) all other leakage as
low as practical. The licensee revised the acceptance criteria in
a revision to the procedure prepared before but issued after the
inspector questioned the boundary identified in the procedure.
The revised acceptance criteria (revision 3 to the procedure)
states as acceptance criteria that (1) there shall be no
observable weld leakage and (2) all other leakage is to be within
the bounds given in procedure GTP-304 for the appropriate sized
piping.or valves.
The criteria in both revisions are unsatis-
factory in that they are inconsistent with the requirements of TS 3.4.6.2.a and d which permit no presssure boundary leakage and a
limit of 10 gpm (gallons per minute) of identified leakage.
(5) The procedure does not provide procedural steps for verification
of the operability of leakage detection systems as required by
IWA-5243 of the Code.
(6) The procedure requires entry into areas that may result in
significant radiation exposure to individuals performing the
prescribed examinations.
Detailed information regarding locations
to be inspected for leakage and how they may be most readily
accessed are needed to aid in assuring that proper locations are
examined and that time is not spent by individuals unnecessarily
making decisions under conditions of radiation exposure.
Procedure 150.001 does not provide or reference such detailed
information, or require review of such information before entry
into radiation areas.
(7) Valve manipulations are required by the procedure.
However, it
provides no identification or verifications for the valve
manipulations.
Note: . It is the inspector's understanding that
the licensee identified this procedural problem following the
inspector's questioning the valve test boundary.
The inspector
was shown a proposed procedure revision that included changes to
the test boundary valves and that added valve alignment verifi-
cations.
In addition to procedural deficiencies described above, the inspector
identified a procedural deficiency in another licensee surveillance
test procedure, as described in paragraph 6 below. These deficiencies
constitute noncompliance with procedural review requirements of
TS 6.5.3.1.a.
This noncompliance is identified as Violation
395/85-22-01, Inadequate Review of Surveillance Test Procedures.
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b.
Training and Qualification of Personnel
The NRC inspector examined the licensee's training and qualification of
l personnel who perform inspections (actually visual examinations) in
accordance with procedure STP 150.001.
Information for the NRC
inspector's examination of this area was obtained through discussions
with cognizant licensee personnel and review of the following related
procedures and records:
Nuclear Operations Training Instruction NTCI-18, Rev.1; Visual
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~ Inspector (VT-2)-Qualification Program
-Nuclear Quality Control Procedure (NQCP) A-NQCP-8, Rev. 2;
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Qualification and Certification of Nuclear Quality Control
Inspection Personnel
Quality Assurance Audit Finding No. II-24-83-D-03, dated 11/21/83
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8/27/84 letter from (QA) Services to Operations stating verifi-
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cation of implementation of an acceptable visual examination
training program and on that basis closing Audit Finding No.
II-24-83-D-03
Certification records for individuals qualified to perform
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inspections in accordance with STP 150.001.
(Three of the
individuals certifcations were reviewed in detail).
In discusions with cognizant personnel the NRC inspector was informed
that qualification and. training of personnel for the subject surveil-
lance test- procedure had been originally performed by the licensee's
Quality Control Systems organization, then later by the Operations
organization, and, finally, it had been assigned to the Nuclear
Operations-Education and Training organization.
In the course of his
examination the inspector - found that licensee QA personnel were
auditing training, and in discussions with the auditors he was informed
that there had been a previous relavent audit finding.
The finding
(referenced above) which was identified in 1983, indicated that
Operations (then responsible for the training and qualification) did
not.have a formal program for qualification of pesonnel to perform VT-2
examinations.
VT-2 examinations are the Code defined examinations
utilized in performance of inspections such as those addressed in -
procedure STP 150.001.
The audit finding also noted that four of 14
individuals whose records were checked did not have complete
certification records.
It is the inspector's understanding that it was
as a consequence of this finding that the responsibility for training
and qualification of personnel for VT-2 examinations (and also for Code
required VT-4 examinations) was transferred to the Nuclear Operations
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ud Training organization.
The NRC inspector's findings, from his
examinction of the area, indicate that the licensee's current training
progra:n may continue to be inadequate.
Concerns identified by the
inspector relative to the program were as follows:
(1) Procedure NTCI-18 requires that Nuclear Operations Education and
Training (NDET) retains all applicable records for individuals'
certification for VT-2 examinations (as required by the Code).
The inspector found that the licensee had not identified what
records were required or where they were to be kept (specific
file).
The content of individual's qualfication files that were
provided to the inspector for review was inconsistent.
Certifi-
cation tests were included for some individuals and not for
others, experience information was not included and distant vision
test results and experience data required by the Code were not
included.
(2) Qualification requirements for the instructor were not identified
and the inspector was informed that the instructor had no
certification indicating his qualifications as a VT-2 instructor.
(3) Set-up requirements for practical testing were not described. No
basis for evaluation or grading of the practical test was
indicated.
(4)
It was not clear who would be responsible for evaluating the
results of annual eye tests and assuring implementation of any
restrictions resulting therefrom.
(5)
It was not clear who develops and approves the test questions for
qualification tests - it appeared to be the responsibility of the
VT-2 Level III examiner in the Nuclear Quality Control organization.
(6) No time limit was given on the period allowed between the
completion of qualification tests and the start of certification.
The inspector noted instances in which a period of over five
months elapsed before certification.
This could allow excessive
time to pass before periodic re-evaluation and re-certification of
individuals.
(7) Directly related to (5) above and indirectly related to other
items, it was not clear what the Level III examiner's responsi-
bilities were relative to assurance of the maintenance of
proficiency of personnel, determining (and approving) the adequacy
of visual examination procedures (such as STP 150.001),
determining the need for additional training, assuring the proper
presentation of training, etc.
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The inspector informed the licensee management personnel having
responsibility for the visual examination training and for performance
of the related examinations of his concern that the training program
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appeared inadequate.
The licensee was informed that the matter would
be examined more extensively to determine its significance during a
subsequent NRC inspection and it was identified as Unresolved Item
395/85-22-02, Training for Visual Examinations.
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 3.b.
5.
Steam Generator Tube Leakage (92706)
TPe inspector questioned the cognizant licensee supervisor as to what
problems they had encountered with operationally-induced tube leaks and what
actions they were undertaking to avoid development of further tube leaks.
The inspector was informed that they had experienced leakage in several
tubes in row 1 of steam generator (SG) B.
The leaks were all in the U-bends
of the tubes.
They appreared to be the result of stress corrosion cracking
induced from the primary (reactor coolant) side of the tubes.
The main
factors believed involved are the temperatures, tube material, and the
residual bending stresses in the tubes in the U-bend areas.
It may be
possible to prevent the cracking by thermally stress relieving the U-bend
areas.
The license has plugged all row 1 SG B tubes in expectation that
this may prevent further cracking in the row 1 tubes.
If a successful method of stress relief is demonstrated they may wish to
relieve the stresses and unplug these tubes to allow them to become
functional again, at some future date.
It is not clear why only SG B tubes
have leaked thus far.
Row 1 in SGs A and C may be plugged (similar to row 1
in SG B) in a future outage.
The inspector was informed that the licensee
is also trying to follow the guidelines developed by the Electric Power
Research Institute for avoidance of tube leakage and that they meet these
guidelines except for problems in transient areas and'for their lack of
capabilities to perform on-line sampling.
6.
InspectionandEnforcementBulletins(IEBs)(927038)
(Closed) 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
perfonn tests, to verify the condition of the subject check valves, as
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reg,'ested by the IEB.
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During inspection 395/85-10, conducted March 11-15, 1985, the NRC inspector
found that the licensee had not provided a final report requested by
In response to questioning by the inspector, the licensee stated
that this was an oversite and indicated the report would provided.
The
report was subsequently provided in a letter to NRC Region II dated
March 21,1985.
This response was reviewed and determined acceptable by
Region II.
During inspection 395/83-27, conducted August 1 - September 2, 1983, the NRC
Resident Inspector at the Summer site reviewed the licensee's procedure for
the IEB 83-03 related valve testing. The procedure was STP 123.003, Service
Water System Valve Operability Test.
The Resident Inspector reported that
STP 123.003 was unacceptable in that it did not contain acceptance criteria
for the IEB-related test.
During the current NRC inspection, the NRC
inspector again reviewed STP 123.003. The inspector fcund that the licensee
had not corrected the procedure and that it still contained no acceptance
criteria for the IEB testing.
The licensee's failure to appropriately
review and to correct the procedure is considered an additional example of
Violation 395/85-22-01, described in 3.a. above.
IEB 83-03 is considered
closed, additional concerns regarding the licensee's testing in response to
the IEB will be addressed in subsequent NRC inspection of Violation
395/85-22-01.
7.
Inspector Followup Item (IFIs) (92701B)
(0 pen) IFI (395/85-10-03):
Was Stroke Timing and Position Indicator
Verification Required and Performed?
This item was opened to address the NRC inspector's concern that he would
not determine whether proper testing had been performed on certain valves
after maintenance - testing required to assure their acceptable operation.
During the current inspection the NRC inspector was informed that the
licensee had investigated his concern.
The inspector reviewed the results
of the investigation as documented in a Nuclear Operations memorandum
identified CGSS-01-1195-N0, File No. 108.60, dated May 2, 1985.
The
investigation concluded that while the valves had been subsequently proven
to function satisfactorily there was no clear documented evidence that the
test had been performed when required, because of the manner in which the
work was documented.
As a consequence of their findings the licensee
identified actions (in the referenced memorandum) that would be taken to
better track and document such tests.
In response to questioning by the NRC
inspector during the exit meeting, the licensee stated that the actions
could be considered a commitment.
The inspector stated that the IFI would
remain open pending NRC verification that the proposed actions were
implemented and were effective.