ML20149G741

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Insp Rept 50-395/97-05 on 970504-0614.Violations Noted.Major Areas Inspected:Licensee Operations,Maint,Engineering & Plant Support
ML20149G741
Person / Time
Site: Summer South Carolina Electric & Gas Company icon.png
Issue date: 07/11/1997
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20149G736 List:
References
50-395-97-05, 50-395-97-5, NUDOCS 9707240043
Download: ML20149G741 (24)


See also: IR 05000395/1997005

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U. S. NUCLEAR REGULATORY COMMISSION

REGION II

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' Docket No.: 50 395

License No.: NPF 12

Report No.:. 50 395/97 05

Licensee: South Carolina Electric & Gas Company (SCE&G)  !

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Facility: V. C. Summer Nuclear Station

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l Location: P. O. Box 88

Jenkinsville, SC 29065

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Dates: May 4 June.14, 1997

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. Inspectors: B. Bonser, Senior Resident Inspector

T. Farnholtz, Resident Inspector

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M. Ernstes, Rector Inspector (Section 05.1)

P. Harmon, Reactor Inspector (Section 05.1)

P. Hopkins, Project Engineer (Sections 01.1 and H2.1

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Approved by: G. Belisle, Chief, Reactor Projects Branch 5

Division of Reactor Projects

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Enclosure 2

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9707240043 970711 l

PDR ADOCK 05000395 i

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EXECUTIVE SUMMARY

V. C. Summer Nuclear Station

NRC Inspection Report No. 50 395/97 05

This integrated inspection included aspects of licensee operations,

maintenance, engineering, and plant support. The report covers a 6-week

period of resident ins)ection; in addition, it includes the results of

announced inspections ay a regional inspector and a project engineer.

Operations

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. Intermediate Building operator logs were taken in accordance with

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administrative procedures (Section 01.1).

. A Non cited Violation was identified for a failure to follow procedure

while performing a test of a CCW pump to restore operability. TMs

error resulted in securing cooling flow to an operating CCP. Tk i event

was not similar to two previous events in which CCPs operated without

CCW. The corrective action for the previous events had not adequately

raised operator awareness to ensure that CCW cooling flow is maintained

to an operating CCP during CCW pump evolutions (Section 01.2).

. The operator aid program was being conducted in accordance with the

Operations Administrative Procedure (Section 01.3).

. Pre-job briefings conducted by the Operations Shift Supervisor

adequately informed maintenance personnel of potential operational risks

and concerns associated with spent fuel cooling and feedwater system

maintenance (Section 01.4).

. A detailed system walkdown found that the safety related chill water

system was considered to be able to perform its design function for

normal and accident conditions. Observations in the areas of poor

housekeeping, poor material condition, minor drawing errors, and a

personnel safety condition were made. These concerns were appropriately

addressed by the licensee (Section 02.1).

. A violation was identified for corrective actions not being effective in

preventing a repetition of storage problems. This was the second NRC

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identified repeat of this violation (Section 02.2).

. A management observation program of Operations was implemented. This

management attention to operations has the potential to enhance

operations by identifying inconsistencies and problems, and reinforce

good practices (Section 04.1).

. Control room operators demonstrated good plant awareness when they

identified a malfunctioning pressurizer spray valve (Section 04.2).

. The inspectors concluded that the Requalification Training Program was

conducted in an effective manner. A strength was identified in the

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direct involvement of Operations in the annual examinations and the

critiques of operator performance. Job Performance Measures (JPMs) were

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not effective in providing performance feedback. The quality of the

JPMs used as test items contributed to this lack of effectiveness. The

annual examination provided an appropriate level of challenge to the

operators to allow meaningful feedback to both the individuals and the

training program. Recent operating history indicated no significant

operator performance problems. Operator performance during the

simulator scenarios was indicative of an effective training program.

The operators exhibited strong command and control, crew discipline, and

excellent communications. The requalification program and the annual

examination met the requirements of 10 CFR 55.59, "Requalification"

(Section 05.1).

. The Plant Safety Review Committee meeting observed met Technical

Specification quorum requirements and focussed on safety while reviewing

agenda items (Section 07.1).

. The Management Review Board meetings, to discuss recent plant trips and

storage problems, were constructive and focussed management's attention

on resolving identified concerns (Section 07.2).

Maintenance

. All observed maintenance tasks were conducted in a competent and

professional manner. Appropriate tools, equipment, and procedures were ,

used. Proper radiological controls were utilued when required (Section

M1.1).

. Surveillance activities were conducted satisfactorily and in accordance

with applicable procedures (Section M2.1).

. Two examples were identified where procedural enhancement had the

potential to compensate for the infrequent performance of activities by

technicians. In one activity, a breaker charging motor was damaged

(Section M4.1).

Enaineerina

. The licensee's consequence analysis for a larger than expected Emergency

Feedwater (EFW) flow differentials between steam generators concluded

that the as found condition of the EFW system would not have produced a

condition which was outside of the plant's design basis. The

methodology and assumptions used in the analysis were acceptable 1

(Section E2.1).

. The modification package to replace the existing sump level probes in

the Auxiliary Building with a more reliable level switch was complete

and appropriately detailed. Specified post modification testing

requirements were acceptable to ensure proper switch operation (Section

E2.2).

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! . The inspectors concluded that the licensee adequately evaluated the

water hammer issues associated with the condensate system and the

l. deaerator (Section E8.1).

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[ Plant'Suooort

l . Postings at locked doors between the radiation controlled area and the

. Intermediate Building were satisfactory (Section R1.1).

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. . A pre-job briefing to discuss personnel safety and radiological issues

i prior to a planned reactor building entry was well conducted and >

j- effective. NO concerns were identified (Section R1.2).

. Security activities observed during the conduct of tours and observation

i . of plant activities were acceptable (Section S1.1).

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Reoort Details

Summary of Plant Status

At the beginning of the inspection period, the plant was operating at

approximately 100 percent reactor power. On May 30, power was reduced to

approximately 85 percent to perform repairs on the C main feedwater pum). The

plant returned to full power on June 2 and remained at that level for t1e

remainder of the inspection period.

I. Doerations

01 Conduct of Operations

01.1 General Comments (71707) l

Using Inspection Procedure 71707, the inspectors conducted frequent

reviews of ongoing plant operations. In general, the conduct of

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operations was professional and safety conscious. Specific events and l

noteworthy observations are detailed in the sections below.

The inspectors accompanied an Intermediate Building operator performing

Technical Specification (TS) required rounds. During the tour, the

operator was thorough in verifying and recording the required equipment

parameters.

01.2 Loss of Comoonent Coolina Water System Flow To An Operatina Charaina

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a. Insoection Scope (71707)

The ins)ectors reviewed the circumstances associated with an operator ,

error tlat occurred while performing a Component Cooling Water (CCW) I

pump test.

b. Observations and Findinas l

On May 7, at 2:06 a.m., during the performance of Surveillance Test i

Procedure (STP) STP 222.002, " Component Cooling Pump Test," Revision 2,

to determine operability of the B CCW pump, the A train CCW Jump was i

secured while supplying cooling water to the A Centrifugal Clarging Pump

(CCP) gear and oil cooler. The A CCP ran without cooling for about 57

seconds Mfore this condition was recognized by the operator and action

taken to restore CCW flow. Temperature checks of the pump were

performed and found to be satisfactory.

The STP required the B CCW pump to be started in both slow and fast

speed to establish pump operability. The STP provided the overall

3rocedural guidance while referencing the specific System Operating

)rocedure (S0P) S0P-118 " Component Cooling Water," Revision 13, to

achieve pump starts, stops, speed changes, and necessary system

realignments to conduct the test. The portion of the test that required

the B CCW pump to be started in slow speed was completed satisfactorily.

The operator then proceeded to conduct the fast speed portion of the

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test. This part of the test was more complex since it was necessary to
perform system realignments to accommodate the increased pump flows due.

[ to fast speed operation. Step 6.2.6 of STP-222.002 referenced the

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operator to shift the B CCW pump to fast speed in accordance-with SOP'

L 118.Section IV.E " Shifting Train B To Fast Speed In.The Inactive

Loop." While performing the referenced section of the S0P the operator

misinterpreted a step and secured the A CCW pump by placing the pump

switch in the "After-Stop" position. On the next page of the procedure

a note discussed the status of the A CCP and the necessity.to transfer

the inservice CCP. At this step in the procedure the operator

recognized that CCW cooling to the A CCP was secured and had been

supplied by the A CCW pump.

The licensee assembled a root cause evaluation team to review this

event, determine.the root causes, and recommend corrective action. The

inspectors reviewed the licensee's evaluation and concluded that the

team had identified the causes of the event. The operator performing

the test had not followed the CCW system S0P while performing the ,

section of the'S0P to realign the system for fast speed operation. This

was attributed to misunderstanding the intent of two ste)s in Section

.IV.E of S0P 118. The operator failed to recognize that le was securing

CCW cooling to an operating CCP. The inspectors also reviewed the

licensee's recommended corrective actions which -included procedural

enhancements and concluded that they addressed the causes of this event.

The failure to follow the procedure for maintaining CCW cooling flow to

an operating CCP is identified as a violation. This non-repetitive

licensee identified and corrected violation is being treated as an NCV

consistent with Section VII.B.1 of the NRC Enforcement Policy. This is

identified as NCV 50 395/97005 01.

The inspectors also reviewed this event in comparison to two previous

events that resultad in CCPs operating without CCW cooling. In the two

previous events a CCP was started without CCW cooling. "n this event

cooling water was secured to an operating CCP. The inspectors concluded

after reviewing the two previous events that these were not similar to

the recent violation. The inspectors, however, concluded that the

corrective action for the previous events had not adequately raised

operator awareness to ensure that CCW cooling flow is maintained to an

operating CCP during CCW pump evolutions.

c. - Conclusion

A Non cited Violation was identified for a failure to follow procedure

while performing a test of a CCW pump to restore operability. This

error resulted in securing cooling flow to an operating CCP. This event

was not similar to two previous events in which CCPs operated without

CCW. The corrective action for the previous events had not adequately

raised operator awareness to ensure' that CCW cooling flow is maintained

to an operating CCP during CCW' pump evolutions.

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01.3 Review of Ooerator Aids

a. Insoection Scope (71707)

The inspectors reviewed the conduct of the Operator Aids program which

is controlled by Operations Administrative Procedure (0AP), 0AP 105.1,

" Control of Operator Aids," Revision 2. The inspectors also sampled

several operator aids and verified that they conformed with their

operator aid request.

b. Observations and Findinas

The licensee has defined an operator aid as a label or other device

affixed to a control panel, component, or other structure that enhances

the ability of 0)erations Department and Test Unit personnel to perform

their duties. T1e inspectors' review of the sample of operator aids

found they were all in conformance with their respective operator aid

requests. The inspectors found that the operator aids appeared

technically correct, were appropriately justified and located in the

correct areas. The description on each operator aid was as described in

the operator aid request and they were identified correctly as operator

aids.

c. Conclusions

The operator aid program was being conducted in accordance with the OAP.

01.4 Pre Job Briefinas

a. Insoection Scope (71707)

The inspectors observed pre job briefings by the Operations Shift

Supervisor (SS).

b. Observations and Findinas

The inspectors observed pre job briefings by the Operations SS for

Feedwater Isolation Valve (FWIV) and Spent Fuel Cooling (SFC) valve

maintenance. Both tasks involved higher than normal risk to the plant.

The FWIV maintenance involved replacement of the pilot air pressure

regulator on the C FWIV. The potential existed for FWIV closure and a

plant trip. The SFC valve maintenance involved the repacking of an

unisolable valve from the Spent Fuel Pool (SFP). The valve repacking

was performed on the backseat. If the backseat did not seal, the

potential existed for an eight to ten thousand gallon leak from the SFP

into the Auxiliary Building.

Both briefings with the involved maintenance personnel covered

preparations for the jobs, expected communications, parameters to

monitor, personnel safety, and the potential hazards. The inspectors

concluded that the briefings adequately prepared the personnel involved

for the risks and concerns associated with these tasks. Prior to

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repacking the SFC valve, the inspectors verified that should the

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backseat of the valve not prevent the valve from leaking, the SFP water

level would not drop below the TS minimum.

c. Conclusion

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Pre job briefings conducted by the Operations SS adequately informed .

maintenance personnel of potential operational risks and concerns. '

02 Operational Status of Facilities and Equipment

02.1 Enaineered Safety Feature (ESF) System Walkdown

a. Insoection Scope (71707)

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The inspectors conducted a detailed ESF system walkdown of the j

safety related chilled water system. This walkdown was conducted using l

the guidance provided in Inspection Procedure 71707.  ;

b. Observations and Findinas

The inspectors conducted a detailed system walkdown of the chilled water

system to assess the general condition of system com)onents including l

labeling, to verify that system valve msitions matc1 the system '

drawings and SOP, and to assess plant lousekeeping in the area of system

components. The following procedure and system piping and

instrumentation drawings were used during the performance of this

walkdown:

. S0P 501 "HVAC Chilled Water System," Revision 15. .

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. Drawing D 302 841, " System Flow Diagram, Chilled Water Pump and l

Chiller Area," Revision 22. '

  • Drawing D 302 842, " System Flow Diagram, Chilled Water to 4

Cooling Coils A," Revision 16. 4

. Drawing D 302 843, " System Flow Diagram, Chilled Water to

Cooling Coils B," Revision 15.

The inspectors considered that the chilled water system was able to

perform its design function for both normal and accident conditions. No

misaligned valves were identified and component labeling was adequate.

The inservice air handling units appeared to be functioning properly and

chilled water temperatures throughout the system were as expected for

the prevailing conditions.

Poor housekeeping was identified in areas that were not frequently

traveled. Identified items included foreign material in cable trays,

significant amounts of debris in some areas, and unauthorized

construction material. Also, two minor drawing errors were identified

on drawing D 302 842.

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) .In addition, several. examples of poor material condition were observed, i

A number of chilled water system valves were observed to have a large  !

' amount of corrosion on the bonnets and handwheels. A number of valves

had minor packing leaks. Several inoperable light fixtures and some -

damaged pipe insulation were also noted. One personnel safety issue was

observed involving a safety chain not being installed on a ladder. ,

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These concerns were communicated to the licensee for their resolution. i

L The inspectors also reviewed the applicable sections of the FSAR and i

identified no discrepancies.

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A detailed = system walkdown found that the safety related chill water

l~ system was considered to be able to perform its design function for

! normal and accident conditions. Poor housekeeping,. poor material

! condition, minor drawing errors, and a personnel safety condition were

. observed. These concerns were appropriately addressed by the licensee.

02.2 Failure To Follow Storace Area Reauest Evaluation

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a. Insoection Scope (71707)

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1 In conjunction with an ESF system walkdown, the inspectors reviewed

L overall plant housekeeping and storage.

i b. Observations and Findinas

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i Station Administrative Procedure (SAP), SAP-142, " Station Housekeeping

! Program," Revision 11, Section 6.11, provides the requirements for the

! designation of storage areas in the plant. Engineering services

i wrsonnel are responsible for reviewing all Designated Storage and

. iousekeeping Area Request (DSHARs) for areas inside the Protected Area

to ensure that no design critaria are compromised. This review ,

} includes, as a minimum, an evaiuation of combustible loading, structural '

floor loading, electrical loading and anti falldown (seismic )

interaction). - As required by the procedure, an engineering analysis had

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! been performed, attached to the storage request, and had appropriately

} identified limitations due to potential fire loading and seismic

interactions. SAP 142 also requires that the storage area request j
originator ensure that all provisions, recommendations, or limitations

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identified in the engineering review are complied with in the storage

area.

On June 4, during a tour of the Control Building 482 foot level, the

inspectors inspected a permanent equipment storage area adjacent to

safety related equipment. The storage area contained charcoal

change out carts (hoppers) on rollers and hoses used to replace charcoal

in the ventilation equipment installed on that level. The inspectors

reviewed the DSHAR and the associated engineering review that was

attached to the wall in the storage area. The inspectors found that the  !

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material was not being stored in accordance with the posted storage

limitations.

The engineering review identified a concern with the flammability of the

flexible hoses used with the change out equipment. The review

recommended that the hoses be removed and stored in a non-safety /non-

seismic structure or location in order to maintain area combustible

loading at a minimum. There was no automatic fire suppression

capability in that area of the control building where the cart and hoses

were being stored. The engineering review also recommended that the

equipment be secured to the building wall by the installation of pad

eye (s) and cabling to prevent these items from moving around during a

potential seismic event. The engineering review designated an adjacent

area where the equipment should be stored. The inspectors found that

the engineering recommendations identified in the engineering review

were not being implemented. The hoses were not stored in a separate

location and the change-out equipment was not in the location designated

in the storage request and not secured to the building wall.

This failure to follow station storage requirements is the second repeat

(third occurrence) identified by the inspectors. Previous violations of

storage requirements were identified on July 15, 1996, and on December

11, 1996. In both the previous violations, the licensee failed to

follow the engineering evaluation attached to the storage request.

Previous corrective actions including personnel counseling, verification

of storage requests, and procedural changes did not prevent recurrence.

This is identified as Violation 50 395/97005 02.

c. Conclusions

A violation was identified for corrective actions not being effective in

preventing a repetition of storage problems. This was the second NRC

identified repeat of this violation.

04 Operator Knowledge and Performance

04.1 Control Room Manaaement Observations l

a. Insoection Scope (71707)

The inspectors observed an Operations observation program. I

b. Observations and Findinas

On May 19, plant management began an eight week around the clock

operations observation program. Independent observers witnessed

operational activities in the control room and in the plant to give

feedback on the conduct of plant operations. The program was

implemented, in part, as a response to recent o The

observations were being compiled in a log book.perational

The inspectorsproblems.

concluded that this management attention to plant operations has the

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potential to enhance performance by identifying inconsistencies and

problems, and reinforcing good practices.

c. Conclusions

A management observation program of operations was implemented. This l

management attention to operations has the potential to enhance

operations by identifying inconsistencies and problems, and reinforcing

good practices.

04.2 Pressurizer Soray Valve

a. Inspection Scoce (71707)

The inspectors reviewed the circumstances surrounding the identification

of a partially stuck open pressurizer spray valve.

b. Observations and Findinas

On May 31, operators observed on the main control board unusual

indications of control group heater amps with the RCS pressure steady

and normal. A review of plant computer data indicated that the

pressurizer spray valve off the A RCS loop, PCV 444D RC, was open with a

closed demand signal.

An evaluation of plant computer data for the spray valves indicated that

PCV 4440 RC was partially open. The valve apparently failed to fully

close after receiving a close demand signal. A subsequent Reactor

Building (RB) entry and troubleshooting by the licensee identified that

the spray valve was in fact partially open due to a problem with the

valve's air control system. A volume booster in the air control system

was replaced, and the valve was returned to a fully functional status.

The inspectors concluded that this observation by control room operators

demonstrated plant awareness and attention to changing plant conditions.

c. Conclusions

Control room operators' demonstrated good plant awareness when they

identified a malfunctioning pressurizer spray valve.

05 Operator Training and Qualification

05.1 Licensed Operator Reaualification Proaram Evaluation -(71001)

a. Inspection Scoce

During the week of May 5 through 8. Region based inspectors used the

guidance of Inspection Procedure 71001 to assess the Licensed Operator

Requalification Program. The inspectors witnessed the administration of

week 2 of the 5 week examination process. The Operating shift crew

examined during the inspection was D Shift, with a total of seven Senior

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Reactor Operators, and four Reactor Operators. The inspectors observed

simulator examination scenarios, plant and simulator walk through l

examinations in the form of Job Performance Measures (JPMs), and l

reviewed the 50 question written examination. In addition, the l

inspectors reviewed the administrative controls the licensee used to

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ensure the Requalification Program met the requirements in 10 CFR 55.59. l

b. Observations and Findinas

The inspectors evaluated th written examination and concluded the

50 question test was challenging and comprehensive. The examination was

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an open reference examination, using test items sufficiently complex to

meet the guidance of NUREG 1021, " Operator Licensing Examination

Standards for Power Reactors," Attachment 3. " Examination Sample Plan,"

and Appendix B. " Written Exam Guidelines." The Requalification written

examination bank contained approximately 800 items, which satisfied the

guidance in NUREG 1021.

The licensee has taken an exception to the guidance of NUREG 1021 and no

longer administers a static simulator examination. The inspectors

determined that plant and control systems typically evaluated in this

section of the examination were appropriately sampled on the written

examination.

The dynamic simulator operating examinations were appropriately

discriminating. The scenarios presented challenges to the operating

crews that allowed a valid assessment of the crews and individuals.

Dominant accident sequences identified from the facility's Probabilistic

Risk Assessment (PRA) were incorporated into the operating tests.

Faults and events were related to a degree that allowed a logical,

reasoned approach by the operating crews in determining the nature of

the faults and accidents. During the simulator scenarios the operators

were observed to maintain good situational command and control. Three

part communications were used, throughout the exercises, in accordance

with station procedures.

The JPMs were adequate to ensure that a safety critical task could be

performed. However, several JPMs were not sufficiently complex to

provide a reasonable degree of confidence that the candidate was

demonstrating a mastery of the requalification training material or of

the functional position. For example, JPM 036B was a simulator JPM in

which the operator is required to respond to a continuous rod withdrawal

event. The initiating cue provided by the evaluator arompted the

operator to " respond to rod motion." After placing t1e Rod Control Bank

Selector to MANUAL, (which did not stop the withdrawal), the operator

was expected to trip the reactor. This was the only action required to

successfully complete the JPM. Other JPMs required a single, simple

step response from the o>erators. Although any training program

requires demonstrating tlat all required tasks be mastered, whether

simple or comalex, the testing process should be predisposed toward

those items w11ch provide meaningful feedback. A simple, single action

task will seldom provide any significant data for determining areas in

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which retraining is needed or where training programs should be

modified. Test items that r e too easy or fundamental such that  ;

individuals with performan c problems could answer them correctly are

not sufficiently discrimbatir.g and should be used with discretion. i

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The inspectors discussed this issue with both Training Management and

Operations Management. The total population of JPMs in the licensee's l

examination bank was approximately 150 test items, which satisfied the

guidance in NUREG 1021.

The requalification examination was administered as planned, with a

minimum of changes in content or schedule. This reflected effective

planning and strong experience levels by the training staff. The

training staff involved in the examination used appro)riate performance

standards in grading and evaluating the operators. T1e staff conducted

critiques immediately after each dynamic simulator exercise. The

critiques were effective in identifying errors or problems, and

assigning the proper corrective actions. The threshold for providing

corrective feedback was appropriately conservative. Operations

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management actively participated in both the dynamic simulator

evaluation and in the critique of the crew and individuals. The

involvement of Operations in the training pmcess was especially useful

during the >ost scenario assessments. Thr e erations managers provided

direct feed)ack to Training regarding wha >erations expected in

matters of crew and individual behavior, munications, and procedural

adherence. This aspect of the Requalifit on program is considered a

strength.

Crew and individual feedback was provided n the form of completed

critique sheets for each of the dynamic simulator exercises. The sheets

were presented to each student at the completion of the examination

week, prior to returning to shift. The inspectors interviewed one SR0

and one R0 regarding the feedback provided. Both felt the feedback was

detailed enough to allow an accurate assessment of their performance.

c. Conclusions

The inspectors concluded that the Requalification Training Program was

conducted in an effective manner. A strength was identified in the

direct involvement of Operations in the annual examinations and the

critiques of operator JPMs were not effective in providing

performance feedback. performance.The quality of the JPMs used as test ite

contributed to this lack of effectiveness. The annual examination

provided an appropriate level of challenge to the operators to allow

meaningful feedback to both the individuals and the training program.

Recent operating history indicated no significant operator performance

problems. Operator performance during the simulator scenarios was

indicative of an effective training program. The operators exhibited

strong command and control, crew discipline, and excellent

communications. The requalification program and the annual examination

met the requirements of 10 CFR 55.59, "Requalification."

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07 Quality Assurance in Operations

07.1 Plant Safety Review Committee (PSRC) Meetina

a. Insoection Scope (71707)

The inspectors attended a PSRC meeting to assess the effectiveness of ,

the process. '

b. Observations and Findinas

On June 10, the inspectors attended a PSRC meeting during which several

SAP changes were discussed. These changes were reviewed by the PSRC

with all questions and concerns being fully addressed. The PSRC voted

to approve each change. No concerns were identified.

In addition, the PSRC members were briefed on an Emergency Feedwater

(EFW) consecuence analysis which was performed following greater than

expecttd EFh flow differentials noted after the April 22 reactor trip.

Details of this analysis are described in Section E2.1.

c. Conclusions

The PSRC meating observed met TS quorum requirements and focussed on

safety while reviewing agenda items.

07.2 Manaaement Review Board (MRB) Meetinas

a. Inspection Scooe (71707)

The inspectors observed MRB meetings on May 9 and June 13.

b. Observations and Findinas

On May 9, the ins)ectors attended a MRB meeting which was held to review

the plant trips tlat occurred in April and the operating crew's

performance during the trips and subsequent restarts. The MRB also

discussed problems that were seen in the plant that needed resolution

including feedwater pump speed controls and feedwater system

performance, potential waterhammer problems, EFW status, and the

electro hydraulic system 0 ring failure.

The June 13 MRB meeting was held to review continued problems with

equipment storage in the plant. The meeting covered the recent storage

issue (see Section 02.2), the current program to designate storage

areas, and proposed ways to enhance the program.

Both HRB meetings were chaired by the Vice President, Nuclear

Operations. The meetings were attended by plant general managers and

other department managers. The inspectors considered the discussions to

be constructive, open, and focussed on resolving outstanding concerns.

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The meetings resulted in establishing action items to resolve the

identified concerns.

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c. Conclusions

. The MRB meetings,.to discuss recent plant trips and storage problems,

i were constructive and focussed management's attention on resolving

. identified concerns.

08 Miscellaneous Operations Issues (92901)

08.1 (Closed) Temocrary Instruction (TI) 2515/86: Inspection of licensee's

actions taken to implement Generic Letter No. 81 21. " Natural

Circulation Cooldown." The licensee's training program to implement

Generic Letter (GL) 81 21 was reviewed in NRC Inspection Report (IR) No.

50 395/87032 and found to be acceptable. Inspectors' reviews of

licensee procedures for natural circulation cooldown and operator

interviews on the use of these procedures were documented in NRC IR Nos.

50 395/88003 and 50 395/88026. Following the licensee's resolution of

several procedural deficiencies identified during the inspection, the-

licensee's procedures were considered satisfactory. Based on the

results of these previous inspections, TI 2515/86 is closed.

,

II. Maintenance

M1 Conduct of Maintenance

M1.1 General Comments

.

a. Inspection Scope (62707)

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The inspectors reviewed or observed all or portions of the following

work activities:

.

  • Maintenance Work Request (MWR) 9710453, A Chiller Surging / Restore

Proper Operation.

  • Preventive Maintenance Task Sheet (PMTS) P0210557, Lubricate C

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Charging / Safety Injection (SI) Pump Motor.

  • PMTS P0210454, Quantify Leakage from Mechanical Seals on the C

3 Charging /SI Pump.

  • PMTS P0210474, Perform Operational Check, Electrical Inspection,

and Cleaning on the C Charging /SI Breaker.

j e MWR 9710605, Install Mounting Bracket for Level Switch ILS01966.

Packing.

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. NWR 9710844, Replacement of C Feedwater Isolation Valve '

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_ (XVG01611C) Pilot Air Pressure Regulator.

  • MWR 9700139, Agastat Relay Calibration / Replacement XSW1DA13.

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b. Observations and Findinas

The observed maintenance on the C chiller was performed in accordance l

with established procedures using acceptable work practices.

The preventive maintenance associated with the C charging /SI pump seals I'

was accomplished using the proper tools and equipment. Demineralized

water was used to clean the residual boric acid crystals from the seal

areas. Proper Health Physics (HP) procedures were utilized during the i

performance of this task. l

The mounting bracket installation for level switch ILS01966 was

performed in accordance with Hodification Review Form (HRF) 34428. The

existing level switch was replaced with a switch of a different design.

This required the installation of a different type of mounting bracket.

Level switch ILS01966 was located in a radiologically contaminated area.

This required HP assistance and the use of appropriate personnel

contamination protection.

The FWIV air pressure regulator replacement and the Spent Fuel Cooling

(SFC) system valve repacking were performed in accordance with the

procedures using acceptable work practices. These two tasks were

especially noteworthy because they both posed higher than normal plant

risk.

c. Conclusions

All observed raaintenance tasks were conducted in a competent and

professional manner. Appropriate tools, equipment, and procedures were  !

used. Proper radiological controls were utilized when required.

M2 Maintenance and Material Condition of Facilities and Equipment

H2.1 S_urveillance Observation

a. Inspection Scope (61726)

The inspectors reviewed or observed all or portions of the following

surveillance tests:

. STP 121.00, " Main Steam Valve Operability Test," Revision 10.

  • STP-170.010 " Fire Switch Functional Yest for XFN0064B and

XFN0065B, B Trai,, RBCUs," Revision 2.

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  • STP-125.002, " Diesel Generator Operability Test," Revision 17.

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. STP 120.004, " Emergency Feedwater Valve Operability Test,"

Revision 12.

. STP 124.001, " Control Room Emergency Air Cleanup," Revision 7.

  • STP-102.001, " Source Range Analog Channel Operational Test,

N 31, N 32 N 33," Revision 5.

. STP 345.037, " Solid State Protection System Actuation Logic and

Master Relay Test - Train A," Revision 13.

b. Observations and Findinas

As part of the STP 345.037 review, the inspectors verified that the

licensee had revised the procedure to include complete verification of

the P 4 circuitry (see NRC IR No. 50 395/97001).

During observation of the surveillance tests, the inspectors observed

good planning, communications and procedural adherence.

c. Conclusions

Surveillance activities were conducted satisfactorily and in accordance

with applicable procedures.

M4 Maintenance Staff Knowledge and Performance

M4.1 Pgrformance of Breaker Testina

a. Inspection Scoce (62707)

The inspectors observed the performance of Electrical Maintenance

Procedure (EMP). EMP 405.013. "7.2 kV Circuit Breaker 500 Operation

Maintenance," Revision 10, on the A train breaker for the C charging /SI

pump and STP 506.009, " Reactor Trip Breaker Testing," Revision 14.

b. Observations and Findinas

The inspectors observed that the technicians performing EMP 405.013 did

not understand how to properly connect a Multi Amp SST-2 timer to

measure the breaker's as found open and close times. The technicians

contacted their supervisor for additional guidance, and the proper

connections were established to provide the required data. A procedure

change was initiated to clarify the use of the Multi-Amp timer. A

similar problem was also identified during the performance of STP-

506.009.

In a later section of procedure EMP-405.013, the technicians manually

charged the charging springs using a ratchet handle. The ratchet handle i

was not removed when it was no longer required. When the charging motor

was energized later in the procedure, the charging motor was damaged and

had to be replaced. The ratchet was used in the clockwise direction

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instead of the counter clockwise direction as recommended in the 7.2 kV

Magna Blast circuit breaker technical manual. The technicians also

manually charged the springs with the breaker control mwer connected.

No personnel were injured during this event, but the c1arging motor was

damaged and required replacement.

The inspectors reviewed the training records for the electrical

technicians involved in the breaker maintenance and found they had

received training in 1993. The training staff used the a) proved )

procedures and the circuit breaker technical manual as a 3 asis for the q

training program for the 7.2 kV breakers. The training facilities were

considered to be adequate.

c. Conclusions

Two examples were identified where procedural enhancement had the

potential to compensate for the infrequent performance of activities by  !

technicians. In one activity, a breaker charging motor was damaged.

III. Enaineering j

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E2 Engineering Support of Facilities and Equipment

E2.1 EFW Flow Balance

a. Inspection Scooe (37551. 92903)

The inspectors reviewed the licensee's consecuence analysis which was

performed because of larger than expected EFv flow differentials between

Steam Generators (SGs) following the manual reactor trip on April 22.

b. Observations and Findinas

An Unresolved Item (URI) was owned in NRC IR Ho. 50 395/97003 (URI 50-

395/97003 05) concerning a higler than expected differential EFW flow

between each of the SGs following a manual reactor trip. Part of this

URI involved a review of the consequences of the observed system

conditions to determine if the design basis assumptions were met.

The licensee performed an EFW consequence analysis to address the

question. The analysis included three system performance evaluations:

. Maximum flow to a faulted SG.

. Automatic isolation of emergency feed to the faulted SG.

  • Minimum flow to the intact SGs.

The results of these evaluations indicated that the system's function to

limit the maximum EFW flow to less than or equal to 1000 gallons per

minute (gpm) to a faulted SG may not have been met. The automatic

isolation and the minimum flow evaluations showed that they would have

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been met with the EFW system in the as found condition. As a result of

these evaluations, the licensee performed a consequence analysis to

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address the impact of EFW flow exceeding 1000 gpm to the faulted SG.

The licensee determined that the inability to limit EFW flow to less

4

than or equal to 1000 gpm to the faulted SG potentially impacts two

design basis analysis:

. RB pressure and temperature analysis for steam line break

. RB flood analysis

'

The analysis showed that the resulting pressure and temperature

conditions inside the RB would be within the bounds of current analyses.

4

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Also, the resulting RB flood level would have been acceptable for

current plant equipment to ensure accident mitigation, establish safe

l- shutdown co titions, and perform post accident monitoring functions.

.

The inspectort, reviewed the licensee's methodology and assumptions used j

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in the analysis. The EFW system hydraulic model was a normalized

version of the same model that was originally used for the system

analysis. The specific post trip system conditions were analyzed. The

3 assumptions used were reasonable and provided an acceptable level of

confidence in the results. The inspectors agreed with the licensee's ,

. conclusion that the as found condition of the EFW system would not have  !

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produced a condition which was outside of the plant's design basis.

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The URI (50 395/97003 05) will remain open pending review of the

licensee's root cause evaluation to determine the cause of the

{ out of specification valve stop adjustments.

c. Conclusions

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The licensee's consequence analysis for larger than expected EFW flow I

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differentials between SGs following a manual reactor trip concluded that l

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the as found condition of the EFW system would not have produced a

condition which was outside of the plant's design basis. The inspectors i

determined that the methodology and assumptions used in the analysis  !

were acceptable. I

E2.2 Modification to Replace Leak Detection System Switches j

, a. InsDection Scope (37551) I

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The inspectors reviewed the MRF 34428 Jackage and sup)orting

i documentation. The purpose of this MR was to make t1e Auxiliary

Building leak detection system more reliable.  ;

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b. Observations and Findinas l

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The licensee initiated a modification to replace the existing Magnetrol

capacitance probes in the Residual Heat Removal (RHR) pump room sumps,

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the waste evaporator room sumps, and the alarm drains in the Auxiliary

Building. A more reliable Magnetrol flood level switch was designated

as a replacement instrument.

The inspectors reviewed the 10 CFR 50.59 screening review which was

completed in sup) ort of this modification. The screening review

indicated that t11s activity did represent a change to the facility as

described in the Final Safety Analysis Report (FSAR) or the Fire

Protection Evaluation Report (FPER). Because of this, a 10 CFR 50.59

safety evaluation was completed. All questions on the safety evaluation

were answered N0 and appropriate justification was included. The FSAR

was identified as requiring revision to change the description of the

level sensing devices. No change to the FPER was required.

Appropriately detailed instructions were provided to the Instrumentation

& Control (I&C) technicians, the civil maintenance technicians, and the

electrical maintenance technicians to complete the required tasks. The

replacement switches required that a different bracket be fabric ited and

installed in the various sumps. Drawings and measurements were govided

to modify the existing brackets to accommodate the replacement switches.

The replacement switches did not require a 120 volt AC power su) ply as

did the original probes. The instructions addressed removing t11s power

supply. The replacement switches were designated as seismically

qualified and seismically mounted as were the original probes.

Post modification testing requirements were specified in the HRF

package. A functional test was specified following installation. This

required plugging the drain in each sump or temporarily disabling the

sump pump, and filling the sumps with water until the switch actuated.

The acceptance criteria for the post modification functional testing was

specific and included the appropriate alarm functions. ,

1

c. Conclusions

The modification package to replace the existing sump level probes in I

the Auxiliary Building with a more reliable level switch was complete I

and appropriately detailed. Specified post modification testing

requirements were acceptable to ensure proper switch operation.

E7 Quality Assurance in Engineering Activities (37551)

E7.1 Review of Updated Final Safety Analysis Report (UFSAR) Commitments I

A recent discovery of a licensee o)erating their facility in a manner l

contrary to the UFSAR description lighlighted the need for a special l

focused review that compared plant practices, procedures and/or l

parameters to the UFSAR description. While performing the inspections l

discussed in this report, the inspectors reviewed the applicable

portions of the FSAR that related to the areas inspected. No

discrepancies were identified.

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E8 Miscellaneous Engineering Issues (92903)

E8.1 (Closed) Insoection Followuo Item (IFI) 50 395/97003 02: Licensee I

corrective action to prevent DA transients. This item adaressed the

licensee's evaluation and proposed corrective actions for water

hammer / pressure transients that occurred in the condensate system and

Deaerator (DA) during the plant restarts following the plant trips in

A)ril 1997. The engineering evaluation concluded that the transients in

t1e DA were caused by the injection of relatively cool condensate water

(75 100 Fahrenheit (F)) into a relatively hot DA (approximately 330 1

F), causing' flashing of the condensate, immediate pressure and

temperature depression in the DA heater section, bulk boiling and

flashing of the storage tank water, and generally high stress loads on l

the DA. The licensee's evaluation of these events recommended revision

of SOPS and operator training to minimize occurrences of this type of

event. The procedure revisions will include a review of the need to

maintain a hot DA during plant restart conditions. The stringent

feedwater temperature requirements for the model D 3 SGs have been

relaxed since the SGs were replaced. A recommendation was also made for

a comprehensive inspection of the interior of the DA during the next

refueling outage. The inspectors concluded that the licensee adequately

evaluated the water hammer issues associated with the condensate system

and the DA.

IV. Plant Support

R1 Radiological Protection and Chemistry Controls

R1.1 General Comments

The inspectors observed radiological controls during the conduct of

tours and observation of maintenance activities and found them to be

acceptable. During an ESF system walkdown the inspectors observed

postings at locked doors between the radiation controlled area and the

Intermediate Building. All postings were found to be satisfactory.

R1.2 Pre-Job Briefina for RB Entry

a. Insoection Scope (71750)

The inspectors attended a pre job briefing conducted in preparation for

a planned RB entry.

b. Observations and Findinas

On June 2, the inspectors attended a pre-job briefing prior to the

licensee performing a RB entry to isolate air to a RCS spray valve. The

purpose of the briefing was to ensure that all involved individuals were

familiar with their s)ecific responsibilities and the expected

conditions in the wor ( area. Attendees included the shift engineer,

maintenance perscanel, and HP personnel. The heat stress conditions and

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the radiological controls were discussed in detail. The inspectors

considered the briefing to be effective and well conducted.

c. Conclusions

A pre job briefing to discuss personnel safety and radiological issues

prior to a planned RB entry was well conducted and effective. No

concerns were identified.

S1 Conduct of Security and Safeguards Activities

S1.1 General Comments (71750)

The inspectors observed security activities including compensatory

measures during the conduct of plant tours and plant activities and

found them acceptable.

V. Manaaement Meetinas

X1 Exit Meeting Summary

The inspectors ) resented the inspection results to members of licensee

management at t1e conclusion of the inspection on June 19, 1997. The

licensee acknowledged the findings presented.

The inspectors asked the licensee whether any materials examined during

the inspection should be considered proprietary. No proprietary

information was identified.

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PARTIAL LIST OF PERSONS CONTACTED

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Licensee l

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F. Bacon. Manager, Chemistry Services i

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L. Blue, Manager, Health Physics

S. Byrne, General Manager, Nuclear Plant Operations

R. Clary, Manager, Quality Systems

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M. Fowlkes, Manager, Operations

S. Furstenberg, Manager, Maintenance Services

D. Lavigne, General Manager, Nuclear Support Services l

G. Moffatt, Manager, Design Engineering  !

K. Nettles, General Manager, Strategic Planning and Development l

H. O'Quinn, Manager, Nuclear Protection Services

A. Rice, Manager, Nuclear Licensing and Operating Experience

G. Taylor, Vice President, Nuclear Operations

R. Waselus, Manager, Systems and Component Engineering

R. White, Nuclear Coordinator, South Carolina Public Service Authority

B. Williams, General Manager, Engineering Services

G. Williams, Associate Manager, Operations

INSPECTION PROCEDURES USED

IP 37551: Onsite Engineering

IP 61726: Surveillance Observations

IP 62707: Maintenance Observations

IP 71001: Licensed Operator Requalification Program Evaluation

IP 71707: Plant Operations

IP 71750: Plant Support Activities

IP 92901: Followup Plant Operations

IP 92903: Followup Engineering

ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

50 395/97005 01 NCV Securing of CCW to an operating charging pump

(Section 01.2).

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50 395/97005-02 VIO Failure to implement effective corrective action for '

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equipment storage violations (Section 02.2).

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I Closed

50 395/97005 01 NCV Securing of CCW to an operating charging pump

(Section 01.2).

l 50 395/97003-02 IFI Licensee corrective action to prevent DA transients

(Section E8.1).

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Discussed

50 395/97003 05 URI Evaluation of high EFW system differential flow rates

(Section E2.1).