ML20155G584

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Responds to Violations Noted in Insp Rept 50-395/88-01. Corrective Action:Identified EFW Pump Motor Lubricated on 880121.Reviewing Maint History of All 10CFR50.49 Qualified Equipment
ML20155G584
Person / Time
Site: Summer South Carolina Electric & Gas Company icon.png
Issue date: 05/25/1988
From: Nauman D
SOUTH CAROLINA ELECTRIC & GAS CO.
To: Grace J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8806200027
Download: ML20155G584 (17)
v • d • e


Text

'

[ ,, , , , , 10CFR2.201 l . '. .,

., to th Carolina Electric & Gas Cornpany Da Jenkinsville. SC 29065 Nuchar Operations SCE&G """

> =a - May 25, 1988 Dr. J. Nelson Grace Regional Administrator U. S. Nuclear Regulatory Commission Region II, Suite 2900 101 Marietta Street, NW Atlanta, Georgia 30323

Subject:

Virgil C. Summer Nuclear Station Docket No. 50/395 Operating License No. NPF-12 Response to Notice of Violation NRC Inspection Report 88-01 Gear Dr. Grace:

Enclosed is the South Carolina Electric & Gas Company (SCE&G) response to the violations addressed in Enclosure 1 of NRC Inspection Report 50-395/88-01.

SCE&G is in agreement with the alleged violations, and the enclosed response addresses the reasons for the violation and corrective actions taken to prevent recurrence. In addition, and updated Equipment Qualification Enhancement Program schedule is enclosed as discussed during a conversation with Mr. A. Ruff on May 18, 1988.

If you should have any questions, please advise. \A

~

S Very truly yours, ,

Y! gw

. . an _

HIO:0AN/bgh Enclosures c: J. G. Connelly, Jr./0. W. Dixon, Jr./T. C. Nichols, Jr.

E. C. Roberts W. A. Williams, Jr. G. O. Percival General Managers R. L. Prevatte L. A. Blue J. B. Knotts, Jr.

C. A. Price M. D. Blue R. B. Clary B. L. Johnson W. R. Higgins NSRC J. R. Proper RTS (IE 88001, 04, 05)

R. M. Campbell, Jr. NPCF K. E. Nodland file (815.01)

J. C. Snelson

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8806200027 880525 l l PDR ADOCK 05000395 0 .

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' Enclosure I to Dr. J. Nelson Grace Letter May 25, 1988 "

Page 1 of 1 ENCLOSURE I RESPONSE TO NOTICE OF VIOLATION VIOLATION NUMBER 50-395/88-01-01

1. ADMISSION OR DENIAL OF THE ALLEGF0 VIOLATION South Carolina Electric & Gas Company (SCE&G) is in agreement with ,

the alleged violation.

II. REASON FOR THE VIOLATION ,

A grace period was incorrectly applied to the lubrication schedule of the Emergency Feedwater (EFW) Pump, MPP0021A. This improper input into the "CHAMPS" program allowed a 25% grace period to be applied to the lubrication schedule for the EFW pump motor which requires lubrication every 12 months. This three (3) month grace period extended the maximum period to 15 months. Justification was provided to show that the motor remained qualified until the lubrication maintenance was performed. .

L III. CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVE 0 The identified EFW Pump motor was lubricated on January 21, 1988.

IV. CORRECTIVE ACTION TAKEN TO AV0!D FURTHER VIOLATION SCE&G is in the process of reviewing the maintenance history of all 10 CFR 50.40 qualified equipment. In addition, SCE&G has reviewed the required maintenance for EQ equipment. Upon completion of these reviews, a comparison will be made between the maintenance that is required and the maintenance that has been performed. Any l discrepancies will be resolved.

V. -DATE OF FULL COMPLIANCE The identification of all I.Q equipment requiring maintenance was completed on May 15, 1988. The maintenance history review of 50.49 equipment and the incorporttion of the requirements into an EQ maintenance manual is sch'sculed to be completed by August 15, 1988.

l l

' Enc 1csure II to Dr. J. Nelson Grace Letter May 25. 1988 Page 1 of 1-ENCLOSURE II RESPONSE TO NOTICE OF VIOLATION VIOLATION NUMBER 50-395/88-01-04 I. ADMISSION OR DENIAL OF THE ALLEGE 0 VIOLATION South Carolina Electric & Gas Company (SCE&G) is in agreement with the alleged violation.

II. REASON FOR THE VIOLATION Ouring a review of the lubricant grease Equipment Qualification (EQ) file, the NRC inspection teu noted a lack of documentation with respect to similarity between the Gulf lubricants and the other lubricants that replaced the Gulf lubricants. In addition, other lubricants were also omitted from the EQ file. The lack of programmatic controls allowed the EQ file to be affected by equal-to-or-better-than evaluations without being properly revised.

Supporting documentation existed, but had not been properly incorporatea into the EQ file.

III. CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVE 0

, The lubricant EQ file has been reviewed and will be revised to include the proper documentation.

IV. CORRECTIVE ACTION TAKEN TO AVOIO FURTHER VIOLATION Engineering procedures now provide for proper programmatic EQ file input and review. In addition, the Virgil C. Summer EQ file is being reconfigured/ reformatted to make it more accessible.

V. DATE OF FULL COMPLIANCE The lubricant EQ file will be revised by September 2, 1988. The programmatic controls for proper EQ file input and review are in place. The EQ procedure was created on March 1, 1988. The proper instructions for EQ input for equal-to-better-than evaluations was proceduralized on February 21, 1988

Enclosure III to Dr. J. Nelson Grace Letter ,

May 25, 1988 Page 1 of 1 ENCLOSURE III RESPONSE TO NOTICE OF VIOLATION

-VIOLATION NUMBER 50-395/88-01-05

1. ADMISSION OR DENIAL OF THE ALLEGE 0 VIOLATION South Carolina Electric & Gas Company (SCE&G) is in agreement with the alleged violation.

II. REASON FOR THE V!OLATION The cause of the violation, relative to the D. G. O'Brien penetrations, was due to an incorrect assumption made during the insulation resistance (IR) calculations. It was assumed that the -

straight line extrapolation of test data would provide a valid result. This was later found to be incorrect. The use of incorrect IR values for the Conax penetrations was due to the incorrect report being referenced in the EQ file. This report did not contain the post LOCA data.

III. CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVE 0 SCE&G has elected to pursue additional test reports which provide IR readings taken during LOCA test conditions for both the Conax and 0.G. O'Brien penetrations. These reports are being used for the basis in determining the IR values used in the instrument loop accuracy calculations. These reports will be entered and referenced in the EQ program. In cases where test reports were obtained from other utilities, a commonality analysis was performed to augment the EQ file to reflect the similarity of penetration connections and terminal blocks. The bounding document which provides analysis, calculations, and justification for the affect of IR on instrument loop accuracies will be the Instrument Loop Insulation Resistance (IR)calculationsdocument(VCS-0423-0C15).

IV. CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION IR values used for calculations will be documented and controlled through the Instrument Loop Insulation Resistance (IR) calculations document (VCS-0423-DC15). The additional reports used in determining IR values during LOCA conditions will also be added to the EQ file.

V. DATE OF FULL COMPLIANCE SCE&G will be in compliance with respect to the corrective actions as stated no later than September 15, 1988.

I

Enclosure IV to Dr. J. Nelson Grace Letter May 25,1988 -

i i

ENVIRONMENTAL QUALIFICATION ENCHANCEMENT PROGRAM '

ACTIVITIES AND SCHEDULE 1

4

A. TRAINING REsPON$lBM ACTIVITY PERSON 348 4/88 s/88 6/88 7/88 8/88 9/88 10/89, ' STATUS 11/88 12/88 If ' 39 3/89 I I I I I I I I I I T i

1. Upgrade EQ Training Program for Jim Loftin l,

Maintenance and QC Personnel + (Completed)

(40) Complete s/1

2. Establish EQ Training Program for Jim Loftin l Bids recieve week Er.gineering + Steve Carrol!

6/30 f 5/23/88. Under evaluation 3 Complete initial Train ng For i

Jim Loftin Erigmeenng + Steve Carroll ) g, See item A.2 ggo). above t

4 Complete Initia! Training for Jim L ftin Training in g

( 40)"

Maintenance and QC + progress 5 Develop Program for Continuing EQ Training on a Regular Periodic Basis Later i

Total Manhours: 1200 Includes cours2 preparation time by training and manhours of course participants

  • Inctodes course preparation time for training and manhours of course participants

+ Activity associated with a NRC Commitment legend: > x/yy = Wojected

. - -- - - - - -- - - - -- - - - -- - - - - + Co m plet ed Task (55) completion (zz-c) date estimated estimated contractor SCE8G Manhours manhours

B. MAINTENANCE -

Activity Responsible Person 3ess 4/8a s/88 6/86 7/e8 828 938 10/88 11/88 12/88 1/89 2/89 3/89 Status i I I I I I I I I I I I I

1. Completeinspectionsof J. Yon harsh environment equip. + > complete du ing refuel *4 gii,7is) 12/15
2. Continueinspection of riild J. Yon (4.455) progress to be evaluated environment splices y 9/16 pnor to RF #4
3. Continueinspection of mild J~ Yon a" environ equip for other "' 9'*"* * ***'""d enwironmental qual. concerns > 9n6 ""
4. Issue M51s for Instrumentation + J. Yon (60) completed 2/11 8"alissuecomplete Revision in croc<ess 5 'teview Maint. history of J. Yon --f (100) Complete for Electrical all 50 49 qualified equip. &

forward results to Engineen_ng +

46

  • group.1&C Review in progress 6 issue M5is for future disposition J. Yon N contmuing as Required of NCN 2852 (40) 6n
7. Implement future disposition J. Yon F j yji5 Complete during RF #4 af NCN 2852 as issued ' ( , , ,)

8 Complete evaluation of J. Yon I C *0' d""ng RF # 4 potential mixed grease and (40) for s remainmg vivs that are repor t results to Engineering +

inauen.ble dunng ops

9. Revise EMPs, eCPs, & MMPs to J. Yon >

incorporate EQ Concerns (220) 8/1 in progress See Engineer Activity 1-3 Total Manhours: 16,670

  • *
  • Included in item B-2

+ Activity associated with a NRC commitment

B. MAINTENANCE (CONT *D.) .

Responsible ACTIVITY Per;on 3/88 4/88 sees sees 7/88 8/88 9/88 io/88 11/88 12/88 i/89 2/89 3/89 Status

10. Develop temp. control I I I I I I I I I I I I i J. Yon ,

methods to ensure maint. is done ' MSI-34. Rev. O issued for on qualified equip. or the (40) review & comment 3/30 &

6/1 replacement of qualified equip. I&C comments being is reflected in EQ files resolved

11. Gen /Rev. Maint. Proc. to J. Yon Later "Close Documentation Loop" to ensure EQ files are kept up to date
    • See Engineer Activity 1-3 Total Manhours: 16.670
  • *
  • Included in item B-2

,C. ENGINEERING

1. Field Walkdowns .

Activity Responsible Person 3/88 4/88 5/88 6/88 7/88 8/88 9,88 Status 10/88 11/88 12/88 1/89 2/89 3/89 E 5 E B B B B 5 5

'****+

5 5 5 5 i c lanf y insp (ntena for J. Mundy Complete mst r umentation +

(32) Completed 2/11 c Determine need to continue B. waselus > Initial determination to nJd E Q insp (other than (40) 8/15 Continue inspections; will

.pi,c es) re-eva'uate by 8/15 3 ev av.ae insp cntena for re-riaining stems (7.2KV mtrs.

5. Carroll ) 7.2 kv motor NCN disp.

(41) (160-C) 7/1 issued: Rotork MOV 1:otor k vivs. etc ) Review M515.

Criteria 10 follow 4 Add motor drain infor. J. Mundy --

--- 4 Complete en.in..n for unws to NC N (4)(16-C) Completed 4/6 s u.ma e Rwsi Pit Spli(e J. Mundy ) G/C MRF issued for I/R on so ri.w.a.ng (120) (240-C) 6/15 5/2/88 6 Pniv.de ingr support for eval B. Waselus -

l Field walk downs dunng RF #4 + (680) (1,020 20 m/h per day @ 85 days) 12/31 7 Generate simple /(oncise status hst refle(ting (ompleted (40) woe k & insting implementing 6/15 dot umerits MSI. T 5. etc )

of work lett to be done

" 9 we* Ms's & P"> vide input J. Mundy i,vn va t..mment ,esolution ..........4 (Comple ted) Complete S. Carroil (60) Sfg

+ Activity associated with NRC commitment

l lI. EQUIPMENT QUALIFICATION FILE WORK -

.~.

Responsible ACTIVITY Person 3/88 4/88 5/88 6/88 7/88 8/88 948 10/88 11/88 12/88 1/89 2/89 3/89 Status i

3 I I I I I il l I I I I I

1. Complete file revisions required To be completed B W asetus asa result of followup action of the (35) (250-C) 9/2 during impell EQ EQ Audit + File Upgrade
2. Add field walkdowninformation 8 waselus  ; To b(. completed during
to EQ Files (75) (750-C) 2/28 Impell EQ File Upgrade for available data - remainder to be added later 3 incorporate summary evals. into files and consider reconfiguring B. wasetus l To be completed during (710) (1500-C)(75 @ 20 hr) 9/2 Impell EQ File Upgrade files. As a min. include a summary of qual. parameters, req. installa-tion parameters, & delete / relocate history data. +

4 Resolve Impell "Open items" 8. wasetus To be completed during c>n EQ Files (100) (1000-C)(50 @ 20 hr) l 9/2 Impeli EQ File Upgrade

5. Identify all required maint. for - - - -

- t Completed 5/15 Preliminary data base environmental qualified equip. 8 * ' *'u' complete; see item C.llt.3 not just that above the normal (40) (400-C) maint specified elsewhere +

6. Add seismic test reports to 9/2 a wasetus To be completed EQ files (100) (1500-C) (150 @ 10 hr) during Impell EQ File Upgrade
7. Incorporate item B-12 tater (maint feedback of field work) into E..g proc. & EQ files 8 Develop generic issues file Later
9. Rev equip. class. based on actual tater environmental data & zone maps deveioped as part of Eng. Item Vil-2
10. Establish seismic files for NSR toter equip. without existing EQ files

111. EQUIPMENT QUALIFICATION INDEX AND MAINTENANCE MANUAL ..

REsPONs!BLE PERSON 3/88 4/89 $/88 6/E8 7/88 8/88 9/88 10/88 11/88 12/98 1/89 2/89 3/89 STATUS I I l I a a a g g g i a

1. Determine desirability to continue Prelim. position B. Waselus l to maintain mild environment equip. in is to maintain the the equip. qual. index & maint. manual. (24) 6/15 Mild files; Consider archiving mild evaluate environment equip. qualification files cost / benefits by 6/15 2 Resolve disagreements between S. Crumbo in progress, also the index & Champs, Master List, 6/15 associated with (60) (100-C)

FSAR, etc. "9' 05 -

Two (2) discrepancies still need resolution

3. Incorporate identified maint. +
5. Crumbo > Impell Prelim.

requirements from Task 11-5 int manual & issue to Maintenance; Maint. Manual review results of item B5 and (40) (80-C) 8/15 received 5/16/88; disposition as required. Reviewin progress

4. Resolve discrepanciesidentified +

by review of PM tasksin CHAMPS S. Crumbo y unnpared to recommend vendor tasks (100) (200-C) 9/2

5. Incorporate Maintenance Require.

Later into CHAMPS or Master List data base

+ Activity associated with a NRC commitment

IV. OPERABILITY REVIEWS,JCOs AND WALKDOWN EVALUATIONS '-

Responsible ACTIVITY Person ima 4ma s/88 6/88 7m8 8m8 9/88 10/88 11/88 1248 1/89 2/89 3/89 Status

' ' ' ' I I I I I I I ' I

1. Revise JCO for splice list + Complete items to include new circuits from J. Mundy --- -f G/C (10) (32-c) Completed 3/15
2. Complete Review of field +
5. Carroll I

Wa downs of harsh equip. for t

Impell to provide C tra tor Services for

1. Complete evaluation of 81 + J. Mundy --+ Completed 3/15 complete additional potentially spliced terminations locludein Disp. to (40) (160-C) .

NCN 2852.

4. Complete evaluation of group S. Crumbo .........y Completed 4/22 10 valves & include in disp. t Complete j NCN 2852 (Six valves) (40)
5. Evaluate timitorque Bolt S. Crumbo m Discrepancies r On schedule (60) (200-C) 6/15
6. Complete review of field walk 5. Carroll (160) (1.610-C) downs of mild equip. for (10 hr per pkg) reportability later

+ Activity associated with a NRC commitment

V. EQUIPMENT QUALIFICATION MASTER LIST ' '

t' Responsible ACTIVITY Person 3/88 4$8 5/88 6/88 7/88 8/88 9/88 10/88 11/88 12/88 1/89 2/89 3/89 - bIOIUS a I s a a a a a a a a i s

1. Update FSAR, Resolve R.G. + F.

& G/C scope document to be 1.97 Category 2 items Thompson '

9) g c) issued by 6/3.
2. Complete & verify data base for S. Crumbo t G/C developing data base.

new Master List (including sub '

components & sealin9 5g 9 requirements

- 8/1

3. Resolve disagreements between S. Crumbo data base and CHAMPS, FSAR.

Associated with Eng. Item

& G/C List V.2 (80) 8/1

4. Develop procedure to control S. Crumbo > Not yet started new Master List & issue as a (80) controlled document 9f3
5. Rewrite FSAR Section 3.11 to be Later (onsistant with current regutations
6. Tie essential equipment list to Later data base 7 Tie Master List Data Base to Later CHAMPS

+ Activity associated with a NRC commitment i

I

V

I. PROCEDURE

REVISIONS ., .

Responsible ACTIVITY Person 348 4/88 s/88 6/88 7/88 848 9/88 10/88 11788 12/88 t/89 2/89 3/89 Status

. I I I  ! I I I I I I I I i 1 Revise TS-301 toinclude EQ M. Curtiss ) issued for comment concerns 7/1 2 ReviseTS-137,114, & 144 T. Curtin to ensure EQ concerns

) T5-13 7 issue for comment-S. Carroll (90) are addressed & proper interfaces 7/31 TS-144 issued for comment at e covered 15-114 issued for comment

3. Revise MD-#31 to better address B. Waselus t Not yet started EQ interfaces and functional r 7/31 responsibilities (30)

+ Activity associated with a NRC comment

9 Vll. ENVIRONMENTAL PARAMETERS . - -

Responsible AGIVITY Person 3/88 4e8 se8s 6/88 7/88 8/88 9/88 10/88 11/88 12/88 1/89 2io9 3/89 Status I i i I i i i i i i I I i

1. Complete MRF on correcting G. Baker )

over temperature conditions in MRF written; G/C preparing poo) (soo-c) 7/1 scope to perform design IB 436 2 Develop Environment zone B Waselus '

maps ' 8/1 G/C Performing Task (4g3 g433.c3

3. Issue TRP on NNS HVAC Systems 5. Crumbo servicing areas containin9 ) 8/1 G/C 5 cope estimate expected (60) (300-c) by 5/31/88 environmental qualified equip.

2 4 Review other parameters (radia- S. Crumbo tion, humidity, etc.) to determine l /1 Y' (59) pon_c) need for field verification of 1

design basis & log term monitoring program

5. Obtain results of one year temp. 5. Crumbo monitoring program per G. Baker Monitoring program i

MSI- 87T0293. Complete / evaluate > continuing. G/C (300) (loss-C) reviewingMSI and will data & continue or close monitor 4/15/89 program correlate / evaluate results 6 Retest E&W PA temp S. Cr umbo > WPA 436' el, test successful. -

(75) 7fj HVAC damper problems creating setback. MWR written to rework.

7. Review effects of temp. on 22 B. Waselus  ;;

items identified in CGGS-37197 6/15 Impell performing review (10) (80-C) 1

Vill OTHERS ,

.2 Responsible ^

ACTIVITY Person Status 3ms 4:88 saa 6/88 7/88 8/88 9/88 10/88 11/88 12/88 U8) 2/89 3/89 5 I i i i 1 i i i i

1. Complete list of hermetic con- J. Mundy i

& List is complete - 5 hermetic nectors & decideif additional (5) connectors to be added -

need to be added + (25) (250 0 6/15 will request G/C for scope doc.

2. Process all analysis work done S. Crumbo 4

in preparation for & during the EQ ) Non Formal EQ File

  1. 0C Calculations / Analysis will be Audit as formal calculations (G/C or5CE8G as appropriate) processed formally under Impell's EQ File Upgrade
Task. NCN 2852 Calc / analysis l requiring formal processing have been identified (5).

i Of these,4 calc. have been processed. 2 await assump-tion verification.

i .

a

3. Resolve seismic concern with B. Waselus - - - -

+

condulets mounted on ASCO vivs T. Lovett Completed Complete. NCN 2852 (ioo) (coo.c) 4/28 Disp. # 58 issued.

4 Review results of Maintenance T. Ef finger  ;

item #4 Mixed greaseissue + e a nt. Item B 8 (40) 2/1 S Oose NCN 2661 + F. Thompson --- -----

-+

(m) 5/1 Completed Complete 6 Complete & verify loop accuracy T. Wessner calculations + G/C calcs. complete - E5 I

(s00) U134 c) 6/1 reviewing for approval 7 Review Impell Supplementary

Evaluations & EQ Update for 5. Carroll '

r I

inpact onG/C Design Records To be completed as part of EQ (25) (100 0 10/1 File Upgrade project

8. Resolve Impell identified IMS vendor manual concerns F. Thompson I Not yet started (60) 8/l

, --N Vill. OTHERS (CONT'D) *

.?

s ;

e Responsible -

ACTIVITY Person was 4S8 s/sa 6ma 7/88 8/88 9/88 10/88 11/88 12sa 1/89 2/89 3mg Status

9. Define long te 'urces & Later program needet. .ntain ef fective EQ Prca
10. Generate EQ DBD Later
11. Consider establishing separate Later EQ screen on Champs

'12 Develop EQ DG Coordinate Later with Training Dept include History from TS-137

+ Activity associated with a NRC Commitment .

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