ML20203J753

Insp Rept 50-395/97-14 on 971130-980110.Violations Noted. Major Areas Inspected:Operations,Maintenance,Engineering & Plant Support

ML20203J753
Person / Time
Site:	Summer
Issue date:	02/09/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20203J745	List: ML20203J741 ML20203J747 ML20203J753
References
50-395-97-14, NUDOCS 9803040275
Download: ML20203J753 (19)

See also: IR 05000395/1997014

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U. S. NUCLEAR REGULATORY COMMISSION

REGION 11

Docket No.: 50 395

License No.: NPF 12

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. Report No.:- 50 395/97-14

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

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Facility: .V. C. Sumer Nuclear Station

Location:- P. O. Box 88

Jenkinsv111e, SC 29065'

Dates: November 30, 1997 - January 10, 1998

-Inspectors: B. Bonser Senior Resident Inspector

l T. Farnhcitz, Resident Inspector

Approved by

R. C. Haag, Chief. Reactor Projects Branch 5

DivisionofReactorProjects

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EXECUTIVE SUMMARY

V. C. Summer Nuclear Station

NRC Inspection Report No. 50 395/97-14

1his integrated inspection included aspects of licensee operations,

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

period of resident inspection.

Doerations

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A Technical Specification required plant shutdown to Mode 5 due to the

inoperable "A Diesel Generator was conducted in accordance with

applicable procedures. Good communication techniques and coordination

between operators were observed

(Section 01.2).

The plant start-up following the Technical Specification required

shutdown for the inoperable "A" Diesel Generator was conducted safely.

Good control and communications were observed in the control room.

Control rod movement was controlled and closely monitored

(Section Gi.3).

• Operators responded promptly to a pressurizer spray valve malfunction

and prevented further challenges to the plant (Section 01.4)

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. A walkdown of the main steam supply and main steam drains to the Turbine

Driven Emergericy Feedwater Pump identified a small steam leak. No other

concerns were identified (Section 02.1).

• No problems or concerns were identified with the licensee's program for

cold weather protection. All requirements of the procedures governing

preparations for the onset of severe weather had been completed. Heat

tracing and insulaticn were in good condition on critical sensing lines

(Section 02,2).

Maintenance

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Maintenance activities on a component cooling water pump speed switch

and breaker, on a failed diesel generator indicator lamp, and on a

reactor coolant pump thermal barrier flow sensing circuit were

conducted in accordance with approved procedures and performed in a

professional and competent manne Proper tools and equipment were

utilized (Section 111.1).

• The licensee's efiJrts to identify and correct problems with the "A"

Diesel Generator governor were thorough and comprehensive. The

licensee's telephone conferences during the resolution of the diesel

generator problems were useful in providing the NRC staff with a better

understanding of the "A" Diesel Generator issues (Section M1.2).

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. Weekly "A" Diesel Generator surveillance testing met Technical

Specifications requirements for increased f,'equency of testing. Post

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maintenance surveillance testing provided adequate assurance that the

"A" Diesel Generator was operable (Section H2.1).

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l e The first example of a violation was identified for failure to init161

L and date the Prerequisites Complete and Limits and Precautions Reviewed

l steps when performed as required by maintenance control procedures

(Section M4.1).

. The second example of a violation was identified for the failure to meet

the specified criteria for the storage of a portable air monitoring

cabinet in the vicinity of safety reuted Service Water System equipment

(Section M4.2).

• A non-cited violation was identified concerning the failure to implement

the requirements of the foreign material and debris control procedure.

A utility knife was dropped into the spent fuel pool while attaching a

lanyard cord (Section M4.3).

Enaineerina

e . A violation was identified for failure to perform a safety evaluation

for a modification to the Reactor Coolant System Leop ~B" hot leg wide

range temperature indicator on the Control floom Evacuation Panel. The

modification represented a change to the facility as described in the

safety analysis report. No unreviewed sbTety question was involved

(Section El.'l)

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The estimated critical condition calculation and inverse count rate

ratio plot performed by Reactor Engineering were useful and were

performed accurately (Section El.2).

e The Feeder Effects list was a useful tool in identifying important

plant electrical loads. The list was being adequately maintained

-(Section E3.1).

Plant Sucoort

• Radiological controls observed during the conduct of tours and

observation of maintenance activities were acceptable (Section R1.1).

• Security activities including compensatory measures. were' acceptable

(Section S1.1).

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Reoort Details

Summary of Plant Status

The Unit began this inspection period opcrating at 100 percent power. On

December 3 power was reduced to 90 percent for main feedwater pump

maintenance. On Decemb v 5 power was reduced further to 40 percent to

evaluate main condenser leakage. The unit returned to full power on

December 8. On January 2 the )lant commenced a Technical Specification

required shutdown and reached iode 5 on January 3. The unit commenced a

reactor start-up and went critical on January 6. Full power was reached on

January 7. The plant remained at 100 percent power for the remainder of the

inspection period.

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I. Ooerations

l 01 Conduct of Operations

01.1 General Coninents (71707)

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i The inspectors conducted frequent reviews of ongoing plant operations.

In general, the conduct of operations was professional and safety-

conscious: specific events and noteworthy observations are detailed in

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01.2 Technical Soecification (TS) Reauired Plant Shutdown

a. Inspection Scone (71707)

On January 2 the inspectors observed control room activities during a TS

required plant shutdown,

b. Observations and Findinas

On December 30 the "A" Diesel Generator (DG) was declared inoperable due

to an unsatisfactory surveillance test. Action statement b 4 or TS 3.8.1.1. "A.C. Sources." was entered which includes a requirement to

restore the "A" DG to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in Mode 3

within the next six hours and in Mode 5 within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

The 72-hour time limit expired on January 2. and a plant shutdown was

commenced. Mode 3 was entered within the required 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Mode 5

was entered within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

The plant shutdown was accomplished using the following procedures:

• General Operating Procedure (GOP)-4, " Power Operation (Mode 1)." ',

Revision 12.

• GOP-5. " Reactor Shutdown from Start-up to Hot Standby (Mode 2 to

Mode 3)." Revision 9.

• GOP-6. " Plant Shutdown from Hot Standby to Hot Shutdown (Mode 3 to

Mode 4)." Revision 7.

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e GOP-7, " Plant Shutdown and Cooldown from Hot Shutdom to Cold

Shutdown (Mode 4 to Mode 5)," Revision 6.

The inspectors observed portions of the shutdown and considered the

actions of the control room operators to be in acccrdance with the

applicable procedures. The use of good communication techniques and

good coordination with operators in other areas of the plant was noted.

Positive control of plant parameters was maintained throughout the

evolution. No concerns were identified.

c, Conclusions

A Technical Specifications required plant shutdown to Mode 5 due to the

inoperable "A" Diesel Generator was conducted in accordance with

applicable procedures. Good communication techniques and coordination

between operators were observed.

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l 01.3 Plant Start-uo

a. Insoection ScoDe (71]_0]l

The inspectors observed control room operations during the conduct of a

plant start-up on January 6.

b. Observations and Findinos

On January 6. the inspectors observed a reactor start-up following the

plant shutdown for maintenance on the "A" DG, The inspectors noted that

the operations crew performing the reactor start up had practiced a

start-up on the simulator prior to taking the shift. The start-up

commenced at 4:40 p.m. The reactor operator declared the reacto"

critical at 5:40 p.m.

During the start-up, the inspectors observed good control of activities

by the Control Room Supervisor (CRS) and good communications among the

CRS. the reactor engineer and the operating staff. Control rod movemert

was well controlled and closely monitored. Following each rod movement

the count rate was monitored and an Inverse Count Rate Ratio (ICRR) plot

was performed to predict criticality. The reactor was declared critical

at 78 steps on Control Bank D. 1, ' estimated critical condition

procedure performed prior to the a art-up had calculated an estimated

critical rod position of 74 steps on Control Bank D. Actual critical

rod position was well within the acceptance criteria of the start-up

procedure.

On January 7 at 9:47 a.m.. the inspectors observed operators tie and

load the main genarator on the grid. The evolution was performed safely

with good control and communication.

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c. Conclusions

The plant start-up following the Technical Specifications required

shutdown for the inoperable "A" Diesel Generator was conducted safely.

Good control and communications were observed in the control room.

Control rod movement was well controlled and closely monitored.

01.4 Flant Doerations

L a. Insoection Scooe (71707)

l The inspectors observed and reviewed significant plant operations,

b. Observatanns and Findinas

On January 7. a Reactor Coolant System (RCS) low pressure alarm

I (setpoint 2185 psig) was observed by operators in the contrnl room. The

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RCS pressure had taken a step drop from about 2235 psig to 2180 asig.

Pressurizer pressure immediately started returning to normal wit 1

Control Group heaters as called for by the pressurizer control system.

The reason for the pressure drop was not immediately clear. About eight ,

minutes later at 1:45 a.m. operators observed that the RCS loop 'C'

pressurizer spray valve (PCV-444C) had gone full open. At the time of

this event the spray valve was in automatic control and pressurizer

pressure was normal. Operators took manual control and closed the spray

valve. Pressure drop)ed to 2208 psig before the valve was closed. The

problem was found to )e a failed circuit card in the spray valve

controller. The controller was repaired and the valve was restored to

normal operation. The inspectors concluded that the control room

oLerators had taken prompt corrective action to prevent a further

clallenge to the plant,

c. Conclusions

Operators responded promptly to a pressurizer spray valve malfunction

and prevented further challenges to the plant.

02 Operational Status of Facilities and Equinment

02.1 Enaineered Safety Feature System Walkdown

a. InspectionScone(71707)

The inspectors performed a walkaown of the m61n steam sup)1y and main

steam drains to the Turbine Driven Emergency Feedwater (T)EFW) Pump,

b. Observations and Findinas

-On December 24. the inspectors performed a walkdown of the main steam

supply and main steam drains to the TDEFW pump. One concern was

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identified and repori.ed to th9 shift supervisor. The inspectors

observed a small steam leak through an insulated drain line off the main

steam supply header in the TDEFW pump room. The leak appeared to be

downstream of the two closed drain line isolation valves. XVT-22826 MS i

and XVT-22827 MS. The licensee initiated a maintenance work request to

correct the steam leak. There were no other concerns identified. -

c. Conclusions

A walkdown of the main steam supply and main steam drains to the Turbine

Driven Emergency Feedwater Pump identified a small steam leak. No other

concerns were identified.

02.2 Cold Weather Preoarations

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a. Insoection Scoof (71714)

The inspectors conducted an independent review of the licensee's

preparation for the onset of cold (sub-freezing) weather.

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b. 60servations and Findinas

The inspectors reviewed the e *

Administrative Procedure (0AP)quirements contained

-109.1 " Guidelines in Operations

for Severe Weather."

Revision 1. Section 6.1 of 0AP-109.1 contains the requirements for. -

preparing for prolonged ex)osure to subfreezing ambient conditions. The

inspectors verified that tie requirements of Section 6.1 had been  ;

completed which included preparing the Service Water (SW) System the

Industrial Cooling Water System, the Control-Rod Drive Mechanism Cooling

System. the-Condensate System and the auxiliary boiler for the onset of

cold weather. In addition. 0AP 109.1 gives guidance for providing for-

building protection by verifying doors and louvers-are closed and that

space heaters are operable.

' Operations personnel routinely verify that installed heat tracing is

operating properly. The inspectors-verified that the heat trace

circuits were energized and that no unexplained alarms were present.

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-of theinstallation

electrical maintenanceand maintenance

group.of heat tracing

As part o the licensee's coldis the responsi

weather protection program. Electrical Maintenance Procedure

(EMP)-120.002. " Freeze Protection Heat Tracing Inspection." Revision 3

was completed on September 7-(Preventive Maintenance Task. Sheet (PMTS)

9714306). The inspectors independently walked down the level sensing

lines associated with the Condensate Storage Tank and the Refueling

Water Storage Tank. The insulation and heat tracing for these lines-

were in good condition.

The inspectors did not' identify any concerns wit l1 the licensee's cold

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weather program. By the end of the inspection period, the plant had

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experienced prolonged periods of subfreezing ambient temperatures. No

freeze related problems were experienced during these periods.

c. Conclusions

No problems or concerns were identified with the licensee's program for

cold weather protection. All requirements of the procedures governing

preparations for the onset cf severe weather had been completed. Heat

tracing and insulation were in good condition on critical sensing lines.

II. Maintenance

M1 Conduct of Haintenance

M1.1 General Comments

a. Insoection Stone (62707)

The inspectors observed or reviewed all or portions of the following

work activities:

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Preventive Maintenance (PMTS) 9720225. Inspect. Clean. and Check

Termination Integrity On the 'B" Component Cooling Water (CCW)

Pump Speed Switch.

. PMTS 9720291. Inspect. Clean, and Perform Operational Check On the

'B' CCW Pump 7200 Volt Breaker.

• Work Request (WR) 9721709. Investigate Failure of Light IL5 To

Energize While "B" DG Is Running.

• hR 9000110. Check Alarm Setpoint For High Flow On IFT07138

b. Observations and Findinas

The inspectors reviewed the work performed to complete WR 9800110. The

control room had been receiving repeated annunciator alarms for 'A"

reactor coolar.t ) ump thermal barrier high flow. A review of flow data

indicated that tie flow was spiking intermittently. There was no

evidence of a thermal barrier leak. In order to reduce the number of

nui. ance alarms and maintain the function of the annunciator to alert

for thermal barrier leakage, a 0.5 second ti em delay was added to the

alarm circuitry. This was accomplished using precedure GMP-100.005.

' Instrument and Controls General Maintenance Procedure." Revision 7.

The inspectors concluded that the high flow alarm would continue to

fulfill its function with the time delay added in the alarm circuitry.

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Haintenance activities on a component cooling water pump speed switch

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and breaker, on a failed diesel generator indicator lamp, and on a

reactor coolant pump thermal barrier flow sensing circuit were ,

conducted in accordance with approved procedures and performed in a  :

professional and competent manner. Proper tools and equipment were

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, M1.2 (Ocen) Insoection Followuo Item (IFI) 50 395/97013-01: Licensee's I

efforc to identify the root cause and corrective action for the "A" DG

problems.

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a. Insoection Scope (62707)

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On December 2 and on December 30. the "A" DG failed the routine i

surveillance tests. These failures were the third and fourth recent- t

failures of the "A" DG, The two previous failure cccurred on November

11 and 21 (see NRC Inspection Report No. 50 395/07-13 for additional '

details). On December 2. the "A DG exhibited v J instability with '

load spikes up to 500 KW. The load swings were comparable to those '

the governor failure on November 11. On December 30.

.theobserved durin'Ibited frequency oscillations a!ter the "A" DG was

"A" DG exh ,

unloaded and the output breaker was opened. The inspectors observed and

reviewed the licensee's efforts to correct the problems identified on

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the "A" DG governor. ,

b. Observations and Findinas

0n December 2 at 2:00 p.m., the "A" DG was declared inoperable after it

failed the weekly surveillance test due to-load instability.. Load

- swings up.to 500 KW were similar to' those experienced on November 11.- <

The: licensee's troubleshooting plan focussed on a possible defective-

governor electronic-control unit (EGA unit), motor operated  ;

potentiometer or incorrect droop setting.

The "A" DG was run with the unit uncoupled and with the inputs and ~

output for the unit monitor The engine started and loaded properly

and ran steady on the hydraulic governor (EGB unit). The output from

the EGA unit was periodically spiking.. The EGA unit was subsequently-

replaced with a refurbished EGA unit. Following additional maintenance,

set-up of the EGA unit, and maintenance runs, the "A" DG operability- F

w surveillance testing was conducted. All surveillance tests were t

satisfactory and the "A" DG was declared operable at 3:50 a.m. on .

December 5. As part of thu review effort, the licensee requested the .

governor service representative review-the troubleshooting efforts for

the previous "A" DG failure >;. The independent review by the service -

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representative agreed that the scope of the licensee's troubleshooting

efforts was sufficiently broad to adequately resolve the previous

. failures of the "A" DG.

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On December 30. during the required weekly surveillance test, the "A" DG

started and was loaded properly. At the end of the one-hour loaded run.

when the output breaker was opened, the frequency (speed) oscillated

from between approximately 58 Hertz (Hz) to 62 Hz. .The "A" DG was

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declared inoperable and the 72. hour action statement associated with TS 3.8.1.1 was entered.

, The licensee developed a-troubleshooting plan to identify the cause of

the frequency oscillations. A governor service representative was on

site to assist in this effort. Previous failures of the "A" DG s>eed

control system had been attributed to failures in the EGA unit (tle

electrical portion ci the speed control system). The EGA unit was

removed and bench tested on December 30. No problems were identified.

The EGA unit was reinstalled and the "A" DG was run for testing.

Although of lesser magnitude, the "A" DG continued to experience

frequency oscillations. Troubleshooting efforts continu?d and included

a null voltage adjustment on the EGB unit (the mechanical portion of the

speed control system), flushing of the EGB unit using fuel oil

replacing the Motor Operated Potentiometer (M0P), and replacing the

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yield link which connects the EGB unit to the fuel rack mechanism.

Interim maintenance runs of the "A" DG resulted in frequency-

oscillations of varying magnitudes after the "A" DG output breaker was

opened, The EGB unit was replaced and a subsequent maintenance run was

performed which resulted in continued frequency oscillations.

On the morning of January 2, a plant shutdown was commenced due to the

expiration of the 72-hour action statement time limit, Additional setup

and adjustment of the EGA/EGB units were performed which improved and

eventually eliminated the frequency oscillations. Multiple maintenance

runs were! conducted with temporary instrumentation connected to the "A"

DG to measure various engine and covernor functions. No additional

frequency. oscillations or other p. %s were identified.

Following the completion of maintenance .. tk and the removal of all

temporary instrumentation, the licensee-performed a set of surveillance

-tests designed to prove the operability of the "A" DG. The results cf

all these tests were satisfactory. The "A" DG was declared operable on

January 5.

The inspectors monitored the licensee's efforts and observed much of the

troubleshooting and maintenance runs of the "A" DG. The licensee

conducted a: thorough and ccmprehensive effort to identify and correct

the frequency oscillations after the December 30 surveillance test

failure. No concerns were identified with the observed maintenance

associated with the "A" DG.-

The EGB unit that was removed was ship)ed to the governor vendor for

testing. The vendor's report stated tlat during bench testing, severe

oscillations-in the mechanical speed setting portion of the EGB unit

-were observed at governor ;11 temperature of approxniately 150'F.

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Subsequent disassembly of the EGB unit identified several nicks on the

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lower land area of the main relay plunger. The vendor stated that this

L item could cause the observed instability at elevated temperatures.

The licensee conducted conference calls with members of the NRC regional

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and headquarters staff on January 2 and 4.1998. The purpose of these

calls _was to explain the symptoms and direction of troubleshooting

L efforts and to answer any questions. The inspectois considered these

calls to be useful in providing a better uderstanding of the issues.

l The licensee is continuing with a detailed root cause analysis for these

l events along with the previous "A" DG failures. Pending completion of

this work. IFI 50 395/97013-01 will remain open.

c. Conclusions

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The licensee's efforts to identify and correct problems with the "A" DG

governor were thorough and comprehensive. The licensee's telephone

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conferences during the resolution of. the "A" DG problems were useful in

providing the NRC s staff:with a better understanding of the "A" DG

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M2 Material Condition of Facilities- snd Equipment

M2.1 Surveillance Observation

a.. Insoection Stone (61725.).

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The inspectors reviaed and observed surveillance tests on the "A" DG -

during routine weekly testing and operability testing following the

-governor problems experienced on December 2 and December 30,

b. Observations and Findinas

The inspectors reviewed routine weekly operability testing on the "A"

DG and operability retesting following governor maintenance. The

surveillance tests included Surveillance Test Procedure (STP)-125.002.

• Diesel Generator Operability Testing." Revision 18: STP-125.013.

" Diesel-Generator Semiannual Operability Test." Revision 6: and

STP-125.004. " Diesel Generator Load Rejectirn Test," Revision 7. The

ins)ectors concluded that the licensee was meeting the recuirements for

weetly increased TS surveillance. testing of the "A" DG anc that post

maintenance testing was comprehensive and adequately established "A" DG

o perability,

c. Conclusions-

Weekly "A" DG surveillance testing met TS requirements for increased

frequency of testing--- Post maintenance surveillance testing provided

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M4 Maintenance Staff Knowledge and Performance

M4.1 Motor Driven Emeroency Feedwater (MDEFW) Pumo Maintenance

a. Insoection Scooe (62707)

The inspectors observed portions of preventive maintenance on the "A"

MDEFW pump to check the oil levels in the inboard and outboard bearings.

The procedure in use was Mechanical Maintenance Procedure (MMP)-300.033.

" Changing 011 in Pumps with Trico Opti-Matic Oilers." Revision 2.

b. Observations and Findinas

On December 9. the inspectors observed 3reventive maintenance to check

oil levels on the inboard and outboard ) ear),1gs of the "A" MDEFW pump.

This maintenance was performed under Preventive Maintenance Task Sheet

(PMTS) 9718530.

Attachment I data sheet of MMP-300.033 included spaces for the

maintenance technician to initial and date each step upon completion.

The inspectors noted that none of the spaces on the Attac' aent I data

sheet had %en initialed or dated although the work had already been

completed. S)ecifically. Section 3.0 (Prerequisites Complete) and

Section 5.0 (.imits and Precautions Reviewed) had not been initialed and

dated at the time the tasks had been completed. Section 3.0 contained a

requirement to verify that the working copy of the procedure used in the

field had been compared to the master control copy. Section 5.0

contained information concerning safety precautions for personnel and

equipment. In discussions with the inspectors, the maintenance

technicians stated that they had performed Sections 3.0 and 5.0. however

the signoffs had not been completed.

Station Administrative Procedure (SAP)-300. " Conduct of Maintenance."

Revision 8. Paragraph 6.11.2.0 states that " Procedure use and adherence

is to be performed in accordance with SAP-123." Step 6.2.9 of SAP-123. '

" Procedure Use and Adherence." Revision 2. states that " Procedure steps

that have sign-offs shall be signed off at the completion of each step

unless specific direction is provided within the 3rocedure that allows

6nother method." No other method is provided in IMP-300.033 to record

the satisfactory completion of work other than the Attachment I data

sheet. The inspectors were concerned that the requirements and

information cont 61ned in Sections 3.0 and 5.0 of the )rocedure were not

documented as being completed prior to proceeding wit 1 the task.

The licensee's failure to sign off procedural-steps on the data sheet

following the completion of each step is identified as a Violation

(VIO). This is identified as the first example of VIO 50-395/97014-01.

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c. Conclusions

Failure to initial and date the Prerequisites Complete and Limits and

Precautions Reviewed steps when performeo as required by maintenance

control procedures was identified as the first example of a violation.

M4.2 Storaae of_Comoonents in the Vicinity of Safety-Related Eauioment

a. Insoection Scooe (62707)

During a routine tour of the Fuel Handling Building, the inspectors

observed a portable air monitor mounted on wheels stored in the vicinity

of the "B" Service Water (SW) booster pump discharge valve and

associated piping.

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l b, Observations and Findinas

On December 17, the inspectors were conduct'ng a routine tour of the

Radiological Controlled A ea (RCA) including the Auxiliary Building, the

Fuel Handing Building, and portions of the Intermediate Building.

During this tour, the inspectors observed an unused portable air monitor

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cabinet mounted on wheels and stored in the vicinity of the "B" SW

booster pump discharge valve and associated piping. This portion of the

SW System is considered safety-related since it su) plies cooling water

to the Reactor Building Cooling Units (RBCUs) whic1 would be relied upon

to remove heat from the Reactor Building during and following certain

postulated accidents. The air monitor dimensions were approximately two

feet deep, three feet wide, and six feet tall. The cabinet was

approximately ten feet away from the safety-related SW components. An

equipment hold tag was attached to the cabinet.

The use of the equipment hold tag is described in SAP-300. " Conduct of

Maintenance," Revision 8. Paragra)h 6.9.6. A of SAP-300 states that the

storagerequirementsofequipment)eingcontrolledbyanequipmenthold

tag shall be compatible with SAP-142. Station Housekeeping Program."

Revision 12. Paragraph 6.10,1.B 8.h of SAP-142 addresses storage

requirements in the vicinity of safety / quality related equi) ment. This

section of SAP-142 provides two options for storage under tiese

conditions: 1) comply with the specified interaction criteria, or 2)

comply with the specified restraint criteria. The interaction criteria

. requires that at least two wheels shall be locked on a component that

has wheels. The restraint criteria provides requirements for the type

and use of resi.raint devices. In the case of the observed cabinet in

the Fuel Handling Building, neither of these requirements were met.

None of the wheels were locked and no restraining devices of any kind

were in place.

The licensee's failure to comply with the interaction criteria or the

restraint criteria-for the storage of components-in the vicinity of

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safety related eq'01.11pment was identified as the second example of

V10 50 395/97014-

c. {cnclusions

The failure to meet the specified criteria for the storage of a portable

air monitoring cabinet in the vicinity of safety related Service Water

-System equipment was identified as a second example of a violation.

M4.3 Utilitv Knife Drocoed in the Soent Fuel Pool

,

a. Insoection Scooe (62707)

The inspectors reviewed an event were the licensee dropped a utility

kn1fe into the spent fuel pool.

b. Observations and Findinas

On November 26. during maintenance on a level transmitter near the edge

of the spent fuel pool, a utility knife fell into the pool while the

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attachina the lanyard cord-for the knife. The knife settled on the

bottom of the pool in an area between the spent fuel racks and the pool

wall. A Condition Evaluation Report (CER 97-1348) was written to

document this event.

As specified in SAP 363, " Foreign Material and Debris Control."

Revision 0, the spent fuel pool area is classified as a housekee)ing

zone III area for the purposes of Foreign Material Exclusion (FMD. 'As

such, in accordance with SAP-363.-a buffer zone had been established

around the spent fuel pool which would remain free of loose tools,

parts, equipment, materials, and debris. Also. SAP-363 contains a

requirement to use lanyards on tools and items which may be dropped.

At the time of this event, the licensee's expectatiori for the conduct of

work in the aret around the spent fuel >ool was that all tools and

equipment would be secured to prevent t1em from falling into the pool

prior to entering the area, h the case of the level transmitter

-maintenance, lanyards were connected to the necessary tools and the

tools were placed in a bag to be transported to the job site near the

edge of tla spent fuel pool. As a tool was required, the tool was

removed from the bag and the free end of the lanyard was attache to the

wrist of the maintenance technician to prevent it from falling-into the

pool._ This activity was in progress with the utility knife when it was

' dropped into the pool. - The practice of transporting tools into an FME

zone without first securing them was not in accordance with either the

-licensee's expectations or with SAP-363. A lanyard was not properly

utilized and the FME zone did not remain free of loose tools.

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- The-licensee-has formulated a plan to remove the utility knife in March.

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'1998 with the-assistance of a nuclear fuels vendor. Additional

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corrective actions included personnel training in FME controls,

clarification of licensee expectt'.lont for work performd in an FME

area, and the procurement of special ;ools designed for use in FME

areas. Also, discussicns were held with the individuals involved in

this event to stress the importance of FME controls. The inspectors

considered these corrective actions were adequate to address this event.

The failure to implement the requirements of the foreign material and

debris control proce6 ire is identified as a violation. This non

repetitive. licensee identified and corrected violation is being tr9ted

as a Non-Cited Violation (NCV) consistent with Section VII.B.1 of the

NRC Enforcement Policy. This item is identified as NCV 50-395/97014-02

c. Conclusions

An NCV was identified concerning the failure to implement t'

requirements of the foreign material and debris control pre; A

utility knife was dropped into the spent fuel pool while attc...ang a

lanyard cord.

III. Enaineerina

El Conduct of Engineering

El.1 Failure..To Perform Safety Evaluation

a. Insoection Scoce (3755_l)

The inspectors reviewed the licenue's 10 CFR 50.59 Safety Evaluation

Screening Questions for a modification to the Control Room Evacuation

Panel (CREP) wide range temoerature indication.

b. Observations and Findinas

3n November 21. the licensee returned the CREP RCS loop ~B" hot leg wide

range temperature indication (ITI004?3A) to service following failure of

the Resistance Temperature Detector RTO) (see NRC Inspection Report No.

50-395/97-13). The licensee preparea a modification package to restore

the temperature indication. . As an interim signal source for the

temperai.ure indication, the iicasee identified a spare RTD element on

RCS loop ~B" hot leg. In order to route the temperature signal to the

CREP. spare cables located in panels ici the relay room were utilized.

'

The reiay room is part of the Control Hu11 ding. These cables were

chosen as they were already 'nstalled and there was no need to run new

field cable.

,

Subsequent to the i,stallation of this modification. the inspectors

reviewed the licerisee's 10 CFR 50.59 Safety Evaluation Screening

Questions. The safety evaluation screening is part of the licensee's

process to cetermine if an Unreviewed Saf*y Question (US0) exists per

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10 CTR 50.59. Station Administrative Procedure. SAP-107, ~10 CFR 50.59

Unreviewed Safety Question Review-Process," Revision 1, provides the

direction to perform the screening. If any of the screening questions

are answered

evaluation is required to determine If an US0 exists.Yes" then either a TS change is n

The licensee ,

screening for the CREP wide range hot leg temperature indication

modification answered "No" to all the questions.

The inspectors reviewed the 10 CFR 50.59 screening questions and did not

agree with the licensee's conclusion that all answers were "No." The

inspectors concluded from their rwiew of the Fire Protection Evaluation

Report (FPER) that the answer to the screening question that stated

"Does the activity represent a change to the facility as described in t

the FSAR or FPER?" st ;uld have been marked "Yes." The licensee't, safety 1

analysis report is considered to be the Final Safety Analysis Dmort

! (FSAR) and the FPER. The safety analysis re) ort referred tc 20 CFR i

50.59 is the most recently updated FSAR and :PER.

,

FPER Section 3.3.3, " Indication of Natural Circulation Ccoling,"

discusses natural circulation for decav heat removal dur'ag a 10 CFR 50

Appendix R iequired shutdown. Heat removal through at h ast one Steam

Generator (SG) loop is necessary. Verification of the existence of

natural circulation in the selected SG loop requires both RCS hot leg

and cold leg temaerature in.iication for the monitored loop. This FPER

section states tlat for a fire requiring control room evacuation,

shutdown will be initiated and controlled from the CREP. It further

states that the CREP provides hot leg and cold leg temperature

indication for each SG loop which are each independent of the Control

Building. The FPER concludes that for any fire that requires control

room evacuation, hot leg and cold leg temperatore indication for the

selected SG loop will be available at the CREP, along with indication

for the other two SG loops. This modification, therefore, represented a

change to the description in the FPER since one of the CREP RCS

temperature indications was not independent of the Control Building.

The modification routed the signal cable from ITI00423A through the

Control Building relay room. A fire in the Control Building could now

render the indication for the RCS loo) "B" wide range hot leg

temperature indic& tion unreliable. T1e inspectors brought this concern

to the licensees attention. The licensee agreed that a safety

--evaluation should have been performed since this modification

represented a change to the facility.

On December 18 th licensee completed a safety evaluation. The

licensee conclude; that an US0 did not exist. The inspector's review of

the modification, the FPER, and the supporting design documentation that

included the Appendix R Composite Equipment List (DC-862-025) conclu:%d

that the licensee was correct. The current Appendix R design does rot

take credit for the availability of all six hot and cold leg RCS wide

range temperature indications at the CREP for a cuntrol room evacuation.

The FPER and DC-862-025 indicated that the RCS loop "C" hot and cold leg

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wide range temperature indications have been credited for use in a

c0ntrol room evacuation for the confirmation of naturel circulation. t

The RCS loop ~B" hot leg wide range tem)erature is not credited for 5

shutdown from the CREP although it may se available.

c. Conclusions

. A violation was identified for failure to perform a safety evalbation

for a modification to the Reactor Coolanc System Loop "B" hot leg wide

range temperature indicator on the Control Room Evacuation Panel. The

modification represented a change to the lacility as described in the

s3fety analysis repcrt. No unreviewed safety question was involved.

El.2 Review of Reactor Enaineerina Start-uo Procedures

a. Insoection Scnoe (375511

,

The inspectors reviewed Reactor Engineering Procedures (REP)-109.001.

" Calculation of Estimated Critical Condition." Revision 3. and

REP-109.002. " Inverse Count Rate Ratio Plot." Revision 3. during the

plant start-up on December 6.

b. Observations and Findinas

During the reactor start-u) on December 6. the inspectors reviewed and

discus.<:ed the results of tie Estimated Critical Condition (ECC)

calculation (REP-109.001) with the reactor engineer. The ECC

. calculation accurately predicted critical rod position. The inspectors

observed the Inverse Count Rate Ratio (ICRR) clot (REP-109.002) during

the reactor start-up and concluded that it was N rformed r.orrectly. The

ICRR was a useful tool in monitoring the effects of rod movement and

predicting criticality,

c. Conclusions

The estimated critical condition calculation and inverse count rate

ratio plot performed by I'eactor Engineering were useful and were

performed accurately.

E3 Engineering Procedures and Documentation

L E3.1 R_eview of Feeder Effects list (FEL)

a. Insoection Scone (37551)

The inspect s reviewed the use and maintenance of the FEL (document

number SS-200-903). The review was prompted by several Condition

Evaluation Reports (CER) being written on issues related to the FE8

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b. Observations and Findinos

The FEL is a document maintained by Design Engineering to assist in

identifying the loads that would be de-energized upon o)ening a

respective breaker. The FEL is intended to list those areakers that

control multiple loads and may not be obvious from the breaker service

description on other documents. The loads included in the FEL, can be

characterized as those that would effect plant operation or have the

potential to shut the plant down. The review of the FEL, by the

inspectors, was prompted by at least 13 CERs written since October,

1996, on issues related to the list. The most recent CER 97-1409)

indicated that a safety-related RBCU flow switch was danger tagged, and

inadvertently deenergized due to incorrect information. Several other

, CERs written on the list indicated that some panels and loads were not

included in the list.

The inspectors reviewed these CER identified issues and held discussions

with Design Engineering management. The inspectors found that in

general the FEL was accurate and that the licensee had responded to all

the CER identified concerns. Several CERs, suggested that the FEL was

deficient because it did not list all loads. The inspectors found that

the intended purpose of the FEL was not to include all loads. Many

, olant loads were not listed such as lighting Janels and other less

'mportant

i breakers. The concern with the RBCJ flow switch was reviewc i

and focad to be incorrect. -In response to the CERs several other lor.as

and panels were being added as they were identified. Some of these

other loads had not been added due to pending modifications. The

inspectors also found that the FEL was not intended to be the only

source of information when removing electrical ecuipment from service.

The licensee's danger tagging procedure recommencs using other

information such as plant drawings as well as the FEL.

'

The inspectors concluded that the intended purpose and content of the

FEL was understood by the users of the list and that the FEL appeared to

be a useful tool in identifying important lo tds. The licensee was

,

maintaining the list adequately.

c. Conclusions

The Feeder Effects List was a useful tool in identifying important

plant electrical loads. The list was being adequately maintained.

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IV Plant Sucoort [

R1 Radiological Protection and Chemistry (RP&C) Cor+*ols

R1,1 General Comments _G12501-

The inspectors observed radiological controls during the conduct of

tours and observation of mainter'nce activities and-found them to be

acceptable.-

R8 Miscelleneous RP&C Issues

l

R8.1 (Closed) - Unresolved Item 50-395/97003-06: failure to meet ,'

requirements-of 10 CFR 70.24 for new fuel criticality monitors. This

-issue involved the failurc to have in place either a criticality

monitoring system for storage and handling of new (non-irradiated) fuel

or an NRC approved exemption to this requirement contained in 10 CFR

-70,24. This issue was closed via a letter to the licensee dated

Decerter 19, 1997.

l S1 Conduct of Security and Safeguan- \ctivities

S1.1 kneral Comments (7175.01-

The inspectors observed security activities including compensatory

measures during the conduct of plant tours and plant activities and

found them to be acceptable.

V. Manaoement Meetinas

X1 Exit Meeting Summary-

The inspectors ? resented the inspection.results to rabers of licensee

management at t1e conclusion of the. inspection-on January 16. 1998. 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

Licensee-

- F. Bacon,-Manager, Chemistry Services

-

L.. Blue. Manager, Health Physics

S, Byrne, General Manager.-Nuclear Plant Operations-

R. Clary,- Manager, Quality Systems

-

M. Fowlkes Manager.-Operations

S.-Furstenberg. Manager,. Maintenance Services

D. Lavigne, General-Manager. Nuclear Support Services

.

G. Moffatt, Manager,- Design Engineering

K. Nettles, General Manager, Strategic Plannina and Development

H. 0*0uinn, 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 Carclinc Public Service Authority

B. Williams, General Manager. Engineering Services

G. Williams, Associate Manager. Operations

, INSPECTION PROCEDURES USFD  !

IP.37551n Onsite Engineering

IP 61726:-Surveillance Observations:

IP-62707: Maintenance Observations

IP 71707:~ Plant Operations

IP 71714: Cold Weather Preparation 1

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IP 71750: Plant Support Activities

ITEMS OPENED CLOSED, AND DISCUSSED

Opened

50-395/97014-01 VIO Two examples: failure to initial and date'the-

Prerequisites Complete and-Limits and Precautions-

Reviewed steps when performed as required by-

maintenance control procedures (Section M4.1) and

failure to meet the sprified criteria for the

storage of a portable air monitoring cabinet in the

vicinity of safety-related service water system

equipment (Section M4.2)

50-395/97014-02 NCV Failure to implement the requirements of foreign

material and debris control procedure (Section M4.3)

50-395/97014-03 VIO- Failure to prepare a safety evaluation for a

modification to the RCS loop "B' hot leg wide range

temperature indication (Section E1.1)

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Closed

50-395/97014-02 NCV Failure to implement the requirements of foreign

material and debris control procedure (Section M4.3)

50-395/97003-06 URI Failure to meet requirements of 10 CFR 70.24 for new

-

fuel criticality monitors (Section R8.1)

Discussed

50-395/97013-01 IFI Licensee's effort to identify the root cause and

corrective action for the "A" DG problems

(Section M1.2)

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