ML20133P971

Insp Rept 50-395/85-28 on 850601-0705.Violation Noted: Failure to Adequately Evaluate Existing Plant Conditions Prior to Performance of Surveillance Test Which Resulted in Both ECCS Trains Being Inoperable

ML20133P971
Person / Time
Site:	Summer
Issue date:	07/24/1985
From:	Cantrell F, Hehl C, Hopkins P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20133P950	List: IR 05000601/2007005 ML20133P947 ML20133P971
References
50-395-85-28, NUDOCS 8508140557
Download: ML20133P971 (9)

See also: IR 05000395/1985028

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g>R REGu UMITED STATES

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NUCLEAR REGULATORY COMMISSION ,

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M . 101 MARIETTA STREET.N.W.

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Report No.: 50-395/85-28

Licensee: South Carolina Electric and Gas Company

Columbia, SC 29218

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

Facility Name: V. C. Summer

Inspection Conducted: June 1 - July 5, 1985

Inspectors: IM

C. W. Hehl

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Dat'e Sisned

P. C. Hopkins

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Dat'e Si'gned

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Approved by: M

F. S PCa'ntrell , Sectio fhief

7//NT)

Datd $1ghed

Division of Reactor ifr%jects

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SUMMARY

Scope: This routine, unannounced inspection entailed 235 inspector-hours onsite

in the areas of plant tours; operational safety verifications; monthly surveil-

lance observations; monthly maintenance observations; review of inspector

followup items; a survey of licensee's response to selected safety issues; and a

special review of selected issues concerning on-the-job training.

Results: One violation was identified - failure to adequately evaluate existing

plant conditions prior performance of a surveillance test which resulted in both

trains of ECCS being inoperable.

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8508140557 850724

PDR ADOCK 05000395

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REPORT DETAILS

j 1. Persons Contacted

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Licensee Employees

j *0. Bradham, Director, Nuclear Plant Operations

i *K. Woodward, Manager, Operations

, *M. Quinton, Manager, Maintenance

*M. Browne, Manager, Technical Support

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B. Croley, Group Manager, Technical and Support Services

l *A. Koon, Associate Manager, Regulatory Compliance

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• R. Fowlkes, Regulatory Compliance

• J. Connelly, Deputy Director, Operations and Maintenance

j *R. Bouknight, Regulatory Compliance

! *G. Putt, Manager, Scheduling and Materials

• S. Hunt, Associate Manager, Surveillance System

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Other licensee employees contacted included engineers, technicians,

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

i * Attended exit interview

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2. Exit Interview (30703)

i The inspection scope and findings was summarized on July 9, 1985, with those

! persons indicated in paragraph 1 above. The inspector described the areas

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inspected and discussed -the inspection findings. One Violation was

identified:

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Violation 85-28-01: Failure to adequately evaluate plant conditions

prior to authorizing a surveillance test which resulted in both trains

I of ECCS being inoperable.

i The Licensee did not identify as proprietary any of the materials provided

j to or reviewed by the inspectors during the inspection.

3. Licensee Action on Previous Enforcement Items (92702)

{ Not inspected during this period.

, 4. Review of Inspector Followup Items (92717)

! (Closed) Inspector Followup Item (83-17-04), Control of Overtime. This

item raised a concern over the interpretation of TS 6.2.2.f which details

j the licensee's requirements for control of overtime for key plant personnel.

An interpretation provided to the licensee by NRR letter' dated June 27, 1985

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! clarified the requirement and alleviated the inspector concern. Station

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Administrative Procedure (SAP) 152, Control of Overtime for Key Personnel,

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which delineates the licensee's administrative controls for this system was

reviewed and found adequate.

5. Operational Safety Verification (71707, 71710)

The inspector observed control room operations, reviewed applicable logs and

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 service of affected components. Tours of the control,

auxiliary, fuel handling, intermediate, diesel generation, service water and

turbine buildings were conducted to observe plant equipment conditions

including potential 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 in accordance

with the Station Security plan.

During a routine tour of the control room on June 11, 1985, the inspector

determined that neither of the required Emergency Core Cooling Subsystems

(ECCS) were fully operable. The unit was at rated power at the time of this

observation.

In accordance with the requirements of General Maintenance Procedure (GMP)

101.008, Seismic and Vital Equipment Area Scaffolding / Shielding Evaluation

and Utilization, the potential adverse effects (Seismic fall down) of

scaffolding proposed for erection in the vacinity of Residual Heat Removal

(RHR) pump "A" had been evaluated by Maintenance Engineering and a

determination made to declare the pump inoperable for the period the

scaffolding would be in place. The scaffolding was needed to support

performance of a planned Inservice Inspection (ISI) of a weld. At 7:10 a.m.

on June 11, 1985, Removal and Restoration (R&R) Report No. 850-344 was

written declaring RHR pump "A" inoperable. The Scaffolding was erected at

approximately 8:45 a.m. on June 11, 1985.

During performance of the planned ISI weld inspection Station Quality

Control (QC) identified a potential deficiency in RHR system mechanical

snubber RHH-164. As a result of this QC finding, at approximately

10:15 a.m. on June 11, 1985 a Nonconformance Notice (NCN) 1978 was written

on Snubber RHH-164 and a second R & R report no. 850-345 was written ,

declaring RHR Pump "A" inoperable based on the deficient snubber. Snubber j

RHH-164 was removed at approximately 12:30 p.m. and a replacement installed

at approximately 3:15 p.m. on June 11, 1985.

Coincident, with the above inoperability of RHR Pump "A", the Shift

Supervisor authorized Instrument Maintenance (I&C) personnel to perform

Surveillance Test Procedure (STP) 345.076, Solid State Protection System

Monthly Actuation of Train B Reactor Trip Breaker and Test of SI Time Delay.

STP 345.076 requires the Solid State Protection System (SSPS) Train "B"

Input Error Inhibit Switch be placed in the " INHIBIT" position. Placing l

this switch in the " INHIBIT" position open circuits all input relays for the

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train under test, thus blocking all trips and safequards actuations from

that train. The June 11, 1985 performance of STP 345.076 resulted in the

blockage of safequard actuations from ECCS Train "B" during the periods of

approximately 8:50 a.m. to 10:47 a.m. and 1:14 p.m. to 2:18 p.m.

For the plant condition (Mode 1) which existed on June 11, 1985, Technical

Specification 3.5.2 requires that two independent Emergency Core Cooling

Subsystem (ECCS) be OPERABLE with each subsystem comprised of:

a. One OPERABLE centrifugal charging pump,

b. One OPERABLE residual heat removal heat exchanger,

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c. One OPERABLE residual heat removal pump, and

d. An OPERABLE flow path capable of taking suction from the refueling

water storage tank on a safety injection signal and automatically

transferring suction to the residual heat removal sump during the

recirculation phase of operation.

TS 1.18, Operable-Operability, establishes criteria for operability which

includes a system, subsystem, train, component or device being capable of

performing its specified functions.

Since a function of the ECCS is to respond to automatic initiation signals

from its respective SSPS train and placing the Input Error Inhibit Switch in

the " INHIBIT" position blocks automatic actuation of safequard functions,

during performance of STP 345.076 Train "B" ECCS is inoperable. Since RHR

pump "A" had also been declared inoperable, on the morning of June 11, 1985

for a period of about two hours and again in the af ternoon for a period of

about one hour, neither of the required ECCS's were fully operable.

With both required trains of ECCS less than fully operable, TS 3.0.3

requires that within one hour, action be initiated to place the unit in a

Mode in which TS 3.5.2 is not applicable. With TS 3.5.2 applicable in Modes

1, 2 & 3, the existing condition required actions to be initiated to bring

the plant to Mode 4. Contrary to this requirement, on June 11, 1985, no

actions was initiated to place the plant in Mode 4. This failure to

initiate the required action of TS 3.0.3 is a violation (85-28-01).

Discussions with licensee personnel determined that there have been two

barriers established to preclude this type occurrence. First, an attempt is

made by the licensee's Planning and Scheduling Group to schedule surveil-

lance and routine maintenance activities such that activities affecting

Train "A" or "B" components are performed during alternate weeks. In this

instance, the performance of STP 345.076 had been scheduled for June 5,

1985, a week designated for Train "B" work. The ISI inspection on "A" RHR

piping had been scheduled for the week of June 10, 1985, a week designated

for Train "A" work. Unfortunately, the licensee's scheduling system had no

adequate means of providing timely feedback on the schedule slippage of STP

345.076. Secondly, and most important, the Shift Supervisor is the ultimate

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barrier to preclude this type occurence, and if not precluded, then to take

the required compensatory actions. Station Administrative Procedure (SAP)

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134, Control of Station Surveillance Test Activities, specifies that the

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Shif t Supervisor (SS) is ultimately responsible for safe, effective conduct

j of all surveillance activities and requires that, prior to authorizing

performance, he evaluate each surveillance activity request to determine if

jl plant conditions allow performance. Subsequent discussions with the on-duty

Shift Supervisor determined that at the time he authorized performance of

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STP 345.076, he was aware of the inoperable status of RHR Pump "A", but that

he did not consider the performance of STP 345.076 as rendering the other

ECCS train inoperable. He felt that the I&C personnel could have been

directed to realign SSPS Train "B" had the system been called upon to

function. Thus, neither of these established barriers functioned adequately

, to preclude this event.

TS 6.8.1 requires that written procedures be implemented for control of

surveillance and test activities of safety related equipment. SAP 134

implements this requirement. Therefore, the above noted inadequate

evaluation of existing plant conditions prior to authorizing the performance

of STP 345.076 constitutes a violation - failure to adequately implement SAP

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134. This violation is a second portion of the above violation

. The safety significance of this occurrence appears to be two fold. First is

the significance of the event itself, secondly, and potentially of greater

significance, is the operating philosophy which allowed this event to occur.

l The declaration of RHR pump A inoperable was a necessary conservation in

lieu of a costly detailed engineering evaluation of the potential affect the

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scaffolding would have had on the RHR system during a seismic event. The

i declaration of the RHR system inoperable based on the defective snubber was

! also a necessary conservation pending the required engineering evaluation of

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its potential affect on system operation. Subsequent to this event, the

i licensee has conducted evaluations of the affect on RHR Train "A" of both

, the scaffolding and the defective snubber (including its removal for

replacement). The evaluations for the defective snubber (while in place and

while removed for replacement) indicate that RHR Train "A" would have been

! able to perform its function. The results of the scaffolding evaluation

, indicate that the RHR Pump could have been rendered inoperable. Never-the-

i less, with the probability of a seismic event occuring during the time

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period the scaffolding was in place being small, and considering that ECCS

Train "A" was otherwise operable, the impact on plant safety of this event

due to equipment status was relatively minor.

! What is of more than minor safety significance in this event is the

philosophy that prompted the SS to authorize performance of STP 345.076  !

fully aware of the existing plant conditions. As previously noted, during l

subsequent discussion with the on-duty SS it was determined that he did not i

, consider the performance of STP 345.076 as rendering ECCS Train "B"  !

inoperable, despite the inhibiting of that train's automatic actuation l

j functions. This philosophy was based on the thought that a trained operator

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would be able to rapidly discern the need for actuation and direct the local l

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test performer to re-align the SSPS. He was also aware of the potential

conservatisms underlying the declarations of inoperablity associated with

RHR Train "A". Thus his decision to allow performance of STP 345.076 was

based on conjecture, unsupported 'oy analytical evaluations, regarding the

actual status of RHR Train "A" and the ability of manual operator actions to

mitigate a potential event requiring automatic ECCS response. It is this 1

philosophy, that decisions regarding plant safety can be made based on

conjecture, unsupported by analytical evaluations, that is of significance

in this event. It is this philosophy that is the root cause of the above  :

noted violations.

6. Surveillance Observation (61726)

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

that selected surveillances 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

testing were properly reviewed and resolved by appropriate management

personnel.

No violations or deviations were identified, except as noted in paragraph 5.

7. 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. Mainte-

nance 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.

8. Fuel Receipt and Storage (60705) .

Ascertained that fuel received at the site is properly accepted, and  ;

safeguarded and that it is stored in accordance with NRC requirements.

The following procedures were reviewed prior to receipt of fuel for

adequacy.

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FHP 602 - (Fuel Handling Procedure) Rev. 2, March 15, 1982, Limitations

j and Precautions for Handling New and Partially Spent Fuel

Assemblies.

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! FHP 608 - (Fuel Handling Procedure) Rev. 4, October 22, 1984, Transfer of

New Fuel Assemblies to the New Fuel Elevator.

FHP 604 - (Fuel Handling Procedure) Rev. 4, October 22, 1984, Functional

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Testing of the Fuel Handling Systems.

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i FHP 605 - (Fuel Handling Procedure) Rev. 5, October 9,1984, Receipt of

j New Fuel and Control Components.

HPP 407 - (Health Physics Procedure) Rev. 2, August 20, 1984, Controls

for Receipt of New Fuel.

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These procedures were determined to be technically adequate for the receipt

inspection and storage of new fuel, to include inspection and handling.

On June 26, 1985, fuel shipment No. CA00543 by carrier Westinghouse No. 960

arrived at V.C. Summer. This shipment consisted of 14 fuel assemblies in

seven casks. The inspector observed receipt, unpackaging and storage of

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this new fuel. No violations or deviations was noted.

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9. Survey of Licensee's Response to Selected Safety Issues

During this inspection period, a special survey of this licensee's response

to selected safety issues was completed. The survey was conducted to

determine the actions that licensee's at operating reactors have taken to

, address a selected sample of safety issues. The issues reviewed were

identified in IE Information Notices (IEN) 83-75 and 84-06. These

particular issues were also the subject of Institute of Nuclear Power

j Operations (INPO) Significant Operating Experience Reports (SOER) 84-02 and

I 84-03.

IEN 83-75 and 50ER- 84-02 were concerned with control rod mispositioning

events which can result in fuel cladding damage either directly or in

conjunction with plant transients. Several events had occurred at other

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facilities in which the mispositioning of control rods have resulted in fuel

damage.

IEN 84-06 and SOER 84-03 were concerned with the potential steam binding of

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auxiliary feedwater pumps due to back leakage. Thii steam binding had

occurred at several facilities resulting in inoperability of the affected

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auxiliary feedwater pumps,

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, The inspectors review determined that these two safety issues had been '

} evaluated for applicability to the licensee's facility and applicable

i compensatory measures had been implemented to reduce the potential for these

j types occurrences. Applicable INPO SOER recommendations had been '

j implemented or evaluations and justifications for not implementing were t

J reviewed.

i The information gathered during this review was forwarded to NRR for

j inclusion in their survey results.

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10. Special Training Review

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i As a result of continuing NRC interest regarding the circumstance of and

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potential contributing factors to the February 28, 1985 Positive Rate Trip

Event, discussed in IE Report 50-395/85-12, a special review of selected

. portions of the facility Licensed Operator Training Program was conducted. '

] The primary focus of this review was to determine the following:

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j a. Training program status of the trainee who manipulated the controls

during the subject event.

! b. Whether the licensee's program addresses a time frame during which

! in plant training (practical factors) are to be accomplished.

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c. Whether the licensee's program designates the method and standards by

which the in plant training is accomplished.

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d. Whether the licensee's program identifies training requirements for

personnel conducting the in plant training phase.

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The inspectors accomplished this review by i n-office training materials

i review, discussions with Training Department personnel and a review of

) personnel training records. The results of this review are as follows:

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(1) The trainee of interest was a qualified Auxilliary Operator and

had completed the first week of the licensed Reactor Operator

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Training Program, which was conducted the week of February 18,

! 1985. This first week of training included the following

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instruction: Introduction to Thermodynamics; Operation of a PWR; *

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Properties of Water; Steam Surges; Rod Control; PWR Chemistry;

] Corrosion in PWR Systems; and a Prescreening Examination.

} (2) The Licensee's Program does not specify a time frame for

accomplishment of practical factors although, in general the

i required in plant practical factors are accomplished during the

i trainee's 90 days on shift as a extra person. The program does

not require the associated classroom training prior to in plant

I training. Practical factors are accomplished by actual

performance, walk-through or on the plant specific simulator.

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I In accordance with NRC requirements, each candidate must

I manipulate the controls of the reactor during five significant

reactivity changes. The reactivity manipulations must be

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accomplished at the plant.

(3) Specific guidance to assure program consistency is included in the

. practical factors portion of this program. The program contains

both instructions to the examiner and the trainee identifying the

t knowledge to be demonstrated and the method by which the

l evaluation is to be performed.

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(4) Aside from the guidance provided as described in Item C above, an

oral Examination Seminar was conducted for potential examiners

4 (SRO'S) as part of the 1984 Licensed Operator Requalification

Program. This training was conducted in response to an INP0

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recommendation identified during the INPO Accreditation Process.

At present no formal program exists to periodically administer

j this type training to persons authorized to administer oral

i examinations.

l It is noted that the Shift Supervisor overseeing the trainee

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during the February 28, 1985 event did not attend this seminar.

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