ML20149M303
| ML20149M303 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 02/16/1988 |
| From: | Dance H, Hopkins P, Prevatte R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20149M276 | List: |
| References | |
| 50-395-88-03, NUDOCS 8802250472 | |
| Download: ML20149M303 (9) | |
See also: IR 05000395/1988003
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION 11
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101 MARlETTA STREET,N.W.
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ATL ANTA, GEORGI A 30323
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Report No.:
50-395/88-03
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: January 5-31, 1988
In specto,rs:
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Richard L. Prevatte'
Date Signed
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'2-12fk1V
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Perry C. Hopkins
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Dat'e Signed
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Accompanying Personnel:
T. O'Connor (January 5-8, 1988)
M. S. Lewis (January 5-8, 1988)
Approved by:
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HughC.yance,SectionChief
Da~te Signed
Division of Reactor Projects
SUMMARY
Scope: This routine, announced inspection was conducted by the resident
inspectors onsite, in the areas of monthly surveillance observations, monthly
maintenance observation, operational safety verification, engineered safety
features system walkdown, onsite followup of events and subsequent written
reports, radiological protection, and physical security.
Paragraph 10 contains the results of an onsite inspection conducted by Region
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II inspectors in the area of procedures for natural circulation cooldown.
Results:
Two violations were identified in the areas of fire protection
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conpensatory action patrols and outdated procedures.
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REPORT DETAILS
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1.
Persons Contacted
Licensee Employees
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D. Nauman, Vice President, Nuclear Operations
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Bradham, Director, Nuclear Plant Operations
- D. Moore, General Manager, Engineering Services
- M. Williams, General Manager, Nuclear Services
K. Nettles, General Manager, Nuclear Safety
- J. Skolds, General Manager, Station Operations
- M. Browne, General Manager, Station Support
- G. Moffatt, Manager, Maintenance Services
+G. Soult, Manager, Operations
- +A. Koon, Manager, Nuclear Licensing
C. Bowman, Manager, Scheduling and Modifications
+K. Woodward, Manager, Nuclear Operations Education and Training
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W. Baehr, Manager, Chemistry and Health Physics
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S. Hunt, Manager, Quality Systems
- K. Beale, Manager, Nuclear Protection Services
C. Price, Manager, Technical Oversite .
D. Warner, Manager, Core Engineering and Nuclear Computer Services
J. Shepp, Associate Manager, Operations
- +W. Higgins, Supervisor, Regulatory Compliance
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NRC Resident Inspectors
- +R. Prevatte, Senior Raside.it Inspector
- P. Hopkins, Resident Inspector
Other licensee employees contacted included engineers, technicians,
operators, mechanics, security force members, and office personnel.
- Attended Resident Inspectors exit
+ Attended Region II Inspectors exit
2.
Exit Interview (30702,30703)
The inspection scope and findings were summarized on January 19, and
March 1,
1988, with those persons indicated in paragraph 1 above.
The
inspectors described the areas inspected and discussed the inspection
findings.
The licensee acknowledged two violations discussed in para-
graph 5.
The licensee did not identify as proprict3 ry any of tne
materials provided to or reviewed by the inspectors during the inspec-
tions
3.
Monthly Surveillance Observation (61726)
The inspectors observed surveillance activities of scfety related systems
and components to ascertain that these activities were conducted in
accordance with license requirements. The inspectors observed portions of
13 selected surveillance tests including all aspect: of the Solid State
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Protection System Actuation Test on Train
"B".
The inspectors also
verified that required administrative approvals were obtained prior to
initiating the test, testing was accomplished by qualified personnel,
required test instrumentation was properly calibrated, data met Technical
Speci#i ition (TS) requirements, test disc ~epancies were rectified, and
the syf taus were properly returned to service.
No violations or deviations were identified.
4.
Monthly Maintenance Observation (62703)
The inspectors observed maintenance activities of sa e y related systems
and components to ascertain that these activities nore conducted in
accordance with approved procedures, TS and appropriate industry codes and
standards. The inspectors also determined that the procedures used were
adequate to control the activity, and that these activities were accomp-
lished by qualified personnel. The inspectors independently verified that
equipment was properly tested before being returned to service. Addition-
ally, the inspectors reviewed several outstanding job orders to determine
that the licensee was giving priority to safety related maintenance and a
backlog which might affect its performance was not developing on a given
system. The following specific maintenance activities were observed:
PMTS P0098299
Inspect and repair connectors to the operator
for component cooling isolation valve XVG6516
PMTS P0098339
Inspect and repair connectors on splices on low
safety injection head valve operator 8887A
PMTS P0098251
Inspect and repair limitorque operator connectors on
the comoonent cooling water supply isolation header
control valve (XVB09525A-0-CC)
PMTS 0093334
Inspect and repair wiring and drainage on residual
heat removal suction header isolation valve (VXV8812A-SI)
MWR 88E0002
Inspect / install
"T"
trains as required on limitorque
valve XVG8884-SI
PMTS P0098430 Inspect, repair, replace as necessary lugs, wiring, and
splices on RHR pump "A" miniflow valve FCV00602A-0-RH
KWR 8800069
Remove and repair reactor trip breaker (XSW001-RT4)
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MWR 317450002 Determinate, remove, reinstall' and terminate motor leads
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for MRF 31745 (installation of drain in component cooling
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watermotorhousing)
MWR 209040007 Install Kirk Key interlock and manual operators for CC
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water pump motor speed switches
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MWR 209040003 Perform wiring modifications and electrical checkout of
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XPP0001 CCW speed switch for MRF 20904
MWR 87M0559
Repair tack weld on diesel generator air start valve
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XVP10986B-DG
No violations or deviations were identified.
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5.
Operational Safety Verificatio; (71707)
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a.
The inspectors toured the control room, reviewed plant legs, records
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and held discussions with plant staff personnel to verify that the
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plant was being operated safely and in co iformance with applicable
requirements.
Spacific items
inspected in the control
room
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included:
adequacy of staffing and attentiveness of control room
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personnel, TS and procedural adherence, operability of equipment and
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indicated control room status, control room logs, tagout books,
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operating orders, jumper / bypass controls, computer printouts and
annunciators. Tours of other plant areas were conducted to verify
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equipment operability, control of ignition sources and combustible
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materials, the condition of fire detection and extinguishing equip-
ment, the control of maintenance and surveillance activities in
progress, the implementation of radiatior protective controls and the
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physical security plan.
Tours were conducted during normal and
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random off hour periods.
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b.
On December 28, 1987, with the plant in Mode 1, fire door PA201 was
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declared inoperable at 4:30 p.m. , and an hourly fire watch was
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established in accordance with TS 3.3.3.7.
The inoperability of the
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door resulted from temporary instrumentation wiring passing through
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the door,
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On December 29, 1987, at 8:10 a.m.
the Integrated Fire Computer
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System (IFCS) was declared inoperable due to sof tware and hardware
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problems. At 8:48 a.m. on December 29, 1987, door PA201 was declared-
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operable and was closed with the temporary wiring still passing
through it.
On December 29, 1987, at 9:00
a.m.,
an auxiliary
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operator while conducting rounds of the auxiliary building, observed
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that the instrumentation wiring under door PA201 was being crimped.
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He then partially closed the door to prevent wire damage and made the
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notation on the auxiliary operators log.
On December 29, 1987 at
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10:40 a.m. a review of the logs by the shift supervisor identified
that PA201 was not closed. He immediately had the door closed.
The
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opened door constitutes a breached fire barrier. - The door had been
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open for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 40 minutes without a continuous fire watch as
required by TS 3.7.10.
On December 29, 1987, with the plant in Mode 1, the IFCS failed at
8:10 a.m
The fire protection technician reviewed the roving fire
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watch patrol (RFhP) logs at 9:10 p.m. and identified that four areas
EPAA 12.02, 36.02, FH63.01 and 12.01 were not listed on the RFWP
logs.
Since these four areas had not been listed on the fire watch -
logs, these areas had not been covered by the compensatory roving
fire watch while the IFCS was inoperable. _ This condition existed for
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a period of approximately 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />. This is contrary to the require-
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ments of TS 3.3.3.7 which requires that a roving fire watch be
established within one hour of the loss of instruments provided by
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the IFCS failure.
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These two events constitute a violation, "Failure to take required
compensatory action on loss of the IFCS", 88-03-01.
This violation
is similar to violation, 87-24-01, "Inadequate action for degraded
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fire detection equipment".
The lack of timely and adequate correc-
tive action on violation 87-24-01 may have contributed to this
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violation.
c.
On January 12, 1988, with the plant in Mode 1, the licensee, while
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reviewing surveillance test procedures for completion and documenta-
tion, noted that on January 8,1988 operations personnel completed
STP 128.310, diesel generator areas preaction sprinkler system (XPN
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079) operational test, with a procedure that contained a "hold for
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two year review" stamp affixed, dated November 14, 1987.
SAP 139,
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Procedure development,
review and approval,
required certain
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procedures to be reviewed every two years and states that safety-
related and quality-related procedures shall r.ot be used beyond their
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two year review date.
This is a violation, "Use of an outdated
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procedure", 88-03-02.
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Two violations were identified as discussed in paragraphs b. and c. above.
6.
ESF System Walkdown (71710)
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The inspectors verified the operability of an engineered safety features
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(ES?) system by performing a walkdown of the accessible portions of the
Control Room Normal and Emergency Ventilation System.
The inspectors
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confirmed that the licensee's system lineup procedures matched plant
drawings and the as-built configuration.
The inspectors looked for
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equipment conditions and items that might degrade performance (hangers and
supports were operable, housekeeping, etc.) and inspected the interiors of
electrical and instrumentation cabinets for debris, loose material,
jumpers, evidence of rodents, etc.
The inspectors verified that valves,
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including instrumentation isolation valves, were in proper position, power
was available, and valves were locked as appropriate.
The inspectors
compared both local and remote position indications.
Minor deficiencies
identified during th2 inspection were corrected by the licensee.
No violations or deviations w re identified.
7.
Onsite Followup of Events and Subsequent Written Reports
(92700, 93713, 93702)
The inspectors reviewed the following Licensee Event Report (LER) to
ascertain whether the licensee's review, corrective action and report of
the identified event or deficiency was in conformance with regulatory
requirements, technical specifications, license conditions, and licensee
procedures and controls.
Based upon this review the following item is
closed.
LER 87-026
No violations or deviations were identified.
8.
Radiological Protection (71709)
The in.spectors, as a part of other routine inspections and work activities
inside the radiation controlled area (RCA) of the plant, observed and
inspected selected areas of the licensee radiological program and
controls.
Specific items included:
a.
Proper use of protective clothing, respiratory equipment and
dosimetry.
b.
Preparation, use and control of dosimetry cards,
c.
Use of hand held and portal monitors by personnel exiting contami-
nated areas and the RCA.
d.
Posting of radiation areas, contaminated areas, "hot spots" and
radioactive material containers,
e.
Personal adherence to NRC regulations and licensee procedures for
radiation protection.
f.
Health physicr. technician coverage when required.
The inspectors additionally selected a Radiation Work Pe rmi t (RWP),
Inspection by NRC of EQ wire splices, 88-0047, and verified that the RWP
contained the information required by the licensee's procedures to perform
the work in a safe manner under controlled conditions.
The inspectors
observed the activities and health physics coverage provided under this
RWP.
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No violations or deviations were identified.
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9.
Physical Security (71881)
The inspectors verified that the security organization shift manning met
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the requirements of the licensee physical security plan. Special inspec-
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tions and routine observations conducted during the performance of other
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duties and inspections verified that installed access control equipment,
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barriers and systems were maintained operational and~ utilized to control
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personnel, packages.and equipment access to protected and vital areas of
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the plant.
Positive- identification and badgtng is- required for plant
staff personnel. Positive control is maintained over authorized visitors.
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Compensatory action is taken on each occasion when search equipment, alarm
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systems or protective barriers become inoperable.
Plant areas are
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adequately illuminated--and adequate patrols are maintained.
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licensee's security procedures are enforced.
Instd Nd detection- and
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assessment equipment and systems are well maintained end properly used by-
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the security force.
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No violations or deviations were identified.
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10.
Natural Circulation Cooldown (25586)
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The licensee has implemented Revision 1 of the Westinghouse Owners Group
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(WOG) Emergency Response Guidelines (ERG) for natural circulation
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cooldown.
The procedure utilized by the facility is Emergency Operating
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Procedure E0P-1,3, Natural Circulation, Revision 1.
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The inspection involved a review of the WOG ERG's E0P-1.3, Station Admini-
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strative Procedures (SAP), and supporting documentation.
In general,
E0P-1.3 appears adequate and within the commitments documented in the
licensee's letter to the NRC dated July 30, 1984.
The July 30, 1984
letter documents the licensee's decision not to write a separate E0P
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procedure based on ERG ES-0.3, "Natural Circulation Cooldown With Steam
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Void in Vessel (with RVLIS)." The licensee states that those steps from
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ES-0.3 which monitor reactor vessel level indication and provide direction
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for dealing with reactor vessel void formation have been includec in
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E0P-1.3.
The inspectors review of E0P-1.3 indicates that appropriate ERG
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steps from ES-0.3 were included except for the inclusion of a caution
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statement that would alert the operators to adjust pressurizer level to
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accommodate void growth or collapse in the reactor vessel as noted in the
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Additionally, the review indicated that the
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PURPOSE section, CAUTION III, and Steps 1, 12, and 16 appear to lack the
clarity which is essential for the accurate execution of emergency
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operating procedures.
Interviews with licensed operators reinforced the
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inspectors concerns, as noted below.
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SAP-207, Development of Emergency Operating Procedure, Revision
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provides instructions for the development, verification, validation,
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training, and implementation of E0P's.
E0P Step Documentation forms, as
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specified by SAP-207, are required for each E0P step. Step Documentation
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forms justify differences between each E0P and ERG step, if any, and the
source of any numerical values used.
During the review of the Step
Do_cumentation forms for E0P-1.3, revisions O and 1,- the inspectors noted
that the justification section for differences lack detail, attributing a
majority of the differences to "fermal only".
The inspectors interviewed two operators on the usage and location of
controls and instrumentation necessary to support the operator actions in
E0P-1.3.
The operators located all necessary controls and instrumenta-
tion, and adequately explained the significance of parameters and control
manipulations related to the capability to reach cold shutdown via natural
circulation.
Hesitation, however, on the operators part was noted when
questioned by the inspectors on the PURPOSE section, what parameters
constituted adequate core cooling (CAUTION III), what parameters would be
verified for boron mixing, and did such verification . constitute verifica-
tion of adequate boron shutdown concentration (Step 1).
Additionally,
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operator hesitation was noted when questioned on what conditions the
operators would refer to E0P-18.2 ".tESPONSE TO VOID IN REACTOR VESSEL"
(Step 12 and 16).
Operator . classroom and simulator training for natural circulation were
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reviewed during a previous NRC inspection as documented in Inspection
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Report 50-396/87-32.
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Based on concerns expressed by the inspectors and acknowledged by the
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licensee, the licensee has committed to review and clarify, as necessary,
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E0P-1.3, Natural Circulation, Revision 1, in the following areas:
The PURPOSE sectiun will be clarified to- provide operators with
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succinct direction for procedure usage in regards to Reactor Coolant
flow status and plant cooldown.
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Caution III will be clarified to indicate under what parameters
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safety injection is necessary, thereby removing possible operator
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confusion regarding "adequate core cooling" versus "inadequate core
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cooling".
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Step 1.b will be revised to ensure that boron shutdown concentration,
as well as mixing, are verified prior to plant cooldown.
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Steps 9.b and 13.b, alternative action columns, will be corrected by
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renumbering as steps 9.c and 13.c, respectively. Step 9.b will also
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be revised to indicate the correct nomenclature for the pressurizer
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power relief valves,
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Steps 12 and 16 will be revised to provide consistent parameters upon
which the ccerators are to base their decisions.
Steps 12 and 16,
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alternative action, will also be clarified to indicate under what
corditions the operators will refer to E0P-18.2 "RESPONSE TO VOID IN
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REACTOR VESSEL", Additionally, the licensee will evaluate the need
to include a caution statement directing the operators to adjust
pressurizer level to accommodate void growth or collapse in the
reactor vessel.
E0P-1,3 will be revised to provide operators with specific direction
as to what instruments are to be utilized in determining the
subcooling margin,
Additionally, the licensee will review the
adequacy of the subcooling margin calculations.
Step Documentation forms will be revised, as necessary, to provide
detailed justification for differences from the WOG ERGS.
Fulfillment of the aforementioned licensee commi .ments is identified as
Inspector Followup Item 88-03-03.
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