ML20210N940
| ML20210N940 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 08/21/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20210N930 | List: |
| References | |
| 50-395-97-07, 50-395-97-7, NUDOCS 9708260196 | |
| Download: ML20210N940 (26) | |
See also: IR 05000395/1997007
Text
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U.-S. NUCLEAR REGULATORY COMMISSION
REGION II
Docket No.: 50 395
-License No.: NPF 12
--Report No.;- 50 395/97 07
Licensee: South Carolina Electric & Gas (SCE&G)
Facility: V. C. Summer Nuclear Station ,
Location: P. O. Box 88
Jenkinsville, SC 29065
Dates: June 15 July 26,1997
Inspectors: B. Bonser Senior Resident Inspector
T. Farnholtz, Resident Inspector
H. Whitener. Reactor Inspector, RII (Sections Hl.2 and H2.1).
Approved by: - G. Belisle, Chief, Reactor Projects Branch 5
Division of Reactor Projects
Enclosure 2
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EXECtRIVE SUltiARY
V. C. Summer Nuclear Station
NRC Integrated Inspection Report No. 50 395/97 07
This integrated inspection included aspects of licensee operations.
maintenance, engineering, and plant support. The report covers a 6 week
period of resident inspection; in addition, it includes the results of an
announced inspection by a regional inspector.
4 Operations
.
A violation was identified for a failure to comply with Technical
Specification (TS) 3.6.4, " Containment Isolation Systems."
Administrative controls were not established prior to opening the A
train hydrogen monitor containment isolation valves to conduct a
calibration (Section 01.2). s
. The bypass authorization program was being conducted in accordance with
the station administrative procedure. The number of bypass
authorizations approved was small (Section 01.3).
.
The tag out of a boron injection flow path was adequately prepared and
implemented and the TS re
available (Section 01.4). quired number of boron in;ection flow paths was
. A walkdown of accessible portions of the A train and B train Diesel
Generator Air Start Systems and the Yard Fire Main System identified no
concerns (Section 02.1).
. Overall material and housekeeping conditions in locked areas of the
Auxiliary Building were good with one exception noted in the letdown
heat exchanger room. Health physics was adequately monitoring
radiological conditions in these arebs (Section 02.2).
.
Lower Auxiliary Building Operator rounds were completed in accordance
with operations guidelines. The operator was knowledgeable of his
, duties and plant conditions (Section 04.1).
.
Establishing a screening committee to review Condition Event Reports
(CER) has given more consistency to the disposition of CERs and benefits
the licensee's self assessment process (Section 07.1).
Maintenance
.
Observed maintenance activities were conducted in accordance with
approved procedures. Properly calibrated equipment, as well as correct
) arts and supplies were used. The technicians performing the work were
(nowledgeable (Section H!.'.).
- Intermediate Building Sump C, Pump Motor B preventive maintenance
activities were well performed by competent technicians who were
knowledgeable of the assigned tasks (Section Hl.2).
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e Procedures specified valves required to demonstrate boron injection flow
paths, and recently completed valve lineups demonstrated system
operability (Section M2.2),
e During observations of surveillance tests of sev6:al smoke detectors, a
motor driven emergency feedwater pump end valves and a sump pump molded
case circuit breaker, the inspectors observed detailed, concise
procedures, procedural adherence, good planning and good communications
(Section M241).
. The licensee's TS required circuit breaker testing program ensures that
selected groups of breakers will be tested and additional samples will
be taken when a bret.ker in a group fails a tcat (Section M2.3).
EnaineeriD9
e A review of the snubber replacement project identified a violation for a
failure to establish an adequate )rocedure for the installation of
Grinnel type restraints. Althoug1 this issue was licensee identified,-
the licensee missed several opportunities to identify and correct these
procedural deficiencies. Missed op>ortunities included procedure
reviews prior to performing the snu)ber replacement and during the field
installation (Section El.1).
. The licensee's evaluation to allow continued full power operation
following the failure of both reactor compartment cooling fans was >
adequate. The evaluation aas thorough and considered all relevant
aspects of the loss of fx .ed ventilation. Plant response upon
establishing natural circulation ventilatien through the reactor
compartment was as expected (Section E2.U .
. The licensee's modification design package to change the P0 fueling Water
, Storage Tank low level alarm setpoint, associated documents and
indicators was well written and complete. Engineering insttuctions and
supporting documentation were adequate to
complete the modification ($ection E2.2). provide sufficient detail to
A Non cited Violation (NCV) was identified concerning seven inadequate
maintenance and test procedures used to set up the Emergency Feedwater
System flow control valves. Improper set up of these valves resulted in
unbalanced flow to the steam generators following a reactor trip. The
licensee's root cause analysis was adequate (Section E8.1).
Plant Suooort
. A tour of locked high radiation areas ar.d locked rooms in'the Auxiliary
Buildin found that contaminated areas wire kept to a minimum and
Radiolo ical controls were well maintaind (Section R1.1).
- The results of a monthiy pager drill conducted during the inspection
period were satisfactory. The current call back system provided
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adequate assurance that the required minimum staffing positions would be i
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filled in the event of an actual emergency (Section Pl.1). l
- The licensee's administrative controls for the use of the biometric hand
readers were effective to prevent unauthorized use (Section S1.1).
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wet pipe sprinkler systems were appropriate. The causes were identified
j and effective interim corrective actions were instituted (Section F2.1).
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Beport Details
Summary of Plant Status
At the beginning of the inspec.:1on period, the plant was operating at or near
full power until July 5 when power was reduced to 97 percent to perform main
turbine valve testing. Later that same day, power was returned to 100
and remained at that level for the remainder of the inspection period. percent
I. Operations
01 Conduct of Operations
01.1 General Comments (71707)
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Using Inspection Procedure 71707, the inspectors condu:ted frequent
reviews of ongoing plant operations. In general, the conduct of
operations was profeuional and safety conscious; specific events and
noteworthy observations are detailed in the sections below.
01.2 Hydroaen Analyzer Containment Isolation Valyas
a. Incoection ScoDe (71707)
The inspectors reviewed the licensee's practice of openir.g the
containment hydrogen monitor Containment Isolation Valves (CIV) during
the conduct of a hydrogen monitor calibration,
b. Observations and Findinas
On June 20 during a routine control board walkdown, the inspectors
identified that the train A containment hydrogen monitor intake and
exhaust line CIVs. SVX 6050A SVX 6051A, SVX 605?.A, and SVX 6053A, were
open. These valves had been opened for a calibration of the hydrogen
monitor. The inspectors questioned whether containment integrity was
adequately maintained with these valves open. The 3/8 inch hydrogen
monitor process lines are opened to the containment atmosphere in order
to sample the post accident environment for hydrogen. During post-
accident operation, the hydrogen monitor atmospheric samples are passed
through the two hydrogen analyzers located in the Auxiliary and Fuel
Handling Buildings and returned to containment.
Valve SVX 6050A receives an automatic containment isolation signal. The
other three CIVs on the A train hydrogen monitor receive no automatic
isolation signal. The automatic isolation feature on SVX 6050A was
added to isolate a containment pressure transmitter sensing line
branching off the hydrogen monitor return line outside containment. All
these valves are operated by hand switches from the main control board.
These remotely operated manual valves are designated as CIVs in the
Final Safety Analysis Report (FSAR).
The hydrogen monitor CIVs were opened as part of a once every refueling
Surveillance Test Procedure (STP). STP 301.004, " Train A Containment
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Hydrogen Monitor Calibration," Revision 2. The licensee told the
inspectors that the valves were normally opened during this surveillance
test and this was a normal practice to conduct this test and open these
CIVs while operating, The licentee completed the surveillance and
closed the hydrogen monitor CIVs. Several days later when the
inspectors questioned the licensee again on this issue, the licensee
issued an internal Operation's memorandum directing operators to ensure
the hydrogen monitor CIVs remain closed pending a review.
The inspectors found that the control room operators were aware of the
testing and had adequately documented that testing was in progress. The
inspectors found that the testing was documented in shift turnover
checklists and the A train hydrogen monitor had been declared inoperable
in an Action Removal and Restoration (R&R) Checklist (R&R #970279)
effective on June 19, at 5:00 a.m.
The inspectors concluded that the licensee had failed to comply with the
action requirements of Technical Specification (TS) 3.6.4 " Containment
Isolation Valves," by failing to implement administrative controls while
the hydrogen monitor CIVs were open during
3.6.4, requires, when in Modes 1 through that 4. plant
each operation
containment (Mode 1).- TS
isolation valve shall be operable. The TS states that locked or sealed
closed valves may be opened on an intermittent basis under
administrative control. The hydrogen monitor CIVs are remotely operated
valves that are not locked closed during normal operation These valves
are provided for containment penetrations and do not com)ly with the
normal isolation provisions of General Design Criteria (GDC) 56,
"Primar
valves,yandContainment
hence fallIsolation," 1.e., automatic
into the category or locked
of a specific classclosed
of lines,
such as instrument lines, that have containment isolation provisions
that are acceptable on some other defined basis. The inspectors
considered that the intent of " sealed closed valves" could be applied to
the-remotely operated hydrogen monitor CIVs.
The bases for TS 3.6.4 states that the administrative controls include
the following considerations: (1) stationing an o mrator, who is in
constant communication with the control room, at tie valve controls. (2)
instructing this o
situation, and (3)rerator to close
assuring these valves in
that environmental an accident
conditions will not
preclude access to close the valves. In this case, the licensee had not
-implemented these or any similar administrative controls.
The inspectors concluded that the licensee failed to comply with TS 3.6.4 by not establishing administrative controls prior to opening the
hydrogen monitor CIVs. The inspectors, therefore, considered the
hydrogen monitor CIVs to be inoperable during the conduct of STP 301.004
on June 20. The inspectors found that these CIVs were open over two
shifts on June 20. The licensee had not documented the exact times
these CIVs were manipulated and could not accurately determine the times
these valves were opened. This surveillance, however, typically takes
eleven to twelve hours to complete. The CIVs were opened early in the
test and closed late in the test.-
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In an accident situation the hydrogen monitor CIV status would be
indicated on the main control board containment isolation light panel.
Early in the response to an event, a control board operator would be
expected to review the status of this panel and close these valves if
they were open.
This failure to comply with the requirements of TS 3.6.4, is identified
as Violation (VIO) 50 395/97007 01.
The inspectors also reviewed the FSAR descri) tion of the hydrogen
monitor and the hydrogen monitor CIVs. The :SAR states that these
valves will be normally closed during plant operation. The design of
the reactor building penetration lines containing the hydrogen monitor
CIVs for both trains was approved in the FSAR under GDC 56. The
hydrogen monitor lines do not meet the specific criteria specified in
GDC 56. GDC 56 states that exceptions to the isolation reauirements are
allowed provided that "it can be demonstrated that the cont'ainment
isolation provisions for a specific class of lines, s'ich as instrument
lines, are acceptable on some other defined basis." The Summer FSAR
provided no basis on which these lines were accepted and no basis for
opening these lines during plant operation.
The inspectors also reviewed the design of the Hydrogen Monitoring
System. Based on a vendor letter dated October 30, 1990, the pressure
boundary for the Hydrogen Monitoring System was defined to end at the
CIVs. The system was designed as a >ost accident system, which would
normally be in a standby mode with tle CIVs closed. Although the system
was built to withstand post Loss of Coolant Accident-(LOCA) temperatures
and pressures the hydrogen monitor can not be considered part of the
primary containment boundary,
c. ConclusiQD1
- A VIO was identified for a failure to comply with TS 3.6.4.
Administrative controls were not established prior to opening the A
train hydrogen monitor CIVs to conduct a calibration.
01.3 Bgylew of Jumoer and lifted Leads Proaram
a. Insoection Scope (71707)
The inspectors reviewed the licensee's bypass authorization controls
established by Station Administrative Procedure (SAP), SAP 148,
" Temporary Bypass, Jumper, and Lifted Lead Control," Revision 8.
b, ObservationsandFindiD91
Procedure SAP 148 ensures that the installation of electrical jumpers
and lifted leads for in service plant equipment will be properly
identified, reviewed, and approved prior to implementation. The
inspectors found that the licensee maintains a small number (three) of
bypass authorizations. The Bypass Authorization Requests reviewed
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complied with the program requirements in SAP 148. The inspectors also
reviewed the initiation, approval. and review by the Plant Safety Review
Committee (PSRC), of a request to juniper out the EHC Electrical
Malfunction annunciator on the main control board. The inspectors were
satisfied that the Bypass Authorization Request was adequately reviewed
and appropriate compensatory actions were taken. The inspectors
concluded that by) ass authorizations were being implemented in
accordance with tle procedure.
c. Conclusions
The bypass authorization program was being conducted in accordance with
the station administrative procedure. The number of bypass
authorizations approved was small.
01.4. Observation of Taa 0ut On Boric Acid Transf2 (BAT) System
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a. Inspection Scope (71707)
The inspectors reviewed and observed a tag.out of the B train BAT system
and verified that there were adequate baron injection flow paths
availabic with this train of boron injection removed from service,
b. Observations and Findinas
On July 2. the inspectors observed an operator hang red tags on several
B train BAT system valves to isolate the B train BXT pump discharge
valve for maintenance. The inspectors also compared the tag out with
the system drawing and concluded that the valve to be repaired was
adequately isolated. The inspectors observed the control roram shift
supervisor brief the control room statf on the remaining boron injection
flow paths. The inspectors reviewed the most recent test
STP 104.003. "Boration System Valve Lineup Verification." procedure.
Revision 5. to
verify the remaining boron injection flow paths had been verified
operable. The inspectors identified no concerns.
c. Conclusions
The inspectors concluded that the tag out of a boron injection flow aath
was adequately prepared and implemented and that the TS required num)er
of boron injection flow paths was available.
02 Operational Status of Facilities and Equipment
02.1 Enaineered Safety Feature System Walkdown (71707)
The inspectors performed a walkdown of accessible portions of the A
train and B train Diesel Generator Air Start Systems and the Yard Fire
Main System. No discrepancies or concerns were identified.
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02.2 Plant Walkdown of Locked Rooms In The Auxiliary Buildina
a. Jnsoection Scope (71707)
The inspectors walked down locked high radiation rooms and locked rooms
in the Auxiliary Building to review material, housekeeping, and
radiological conditions,
b. Observation and Findinas
On July 2, the inspectors, accompanied by a Health Physics (HP)
technician, walked down locked high radiation rooms and other normally
locked areas in the Auxiliary Building. Most of these rooms are not
frequently entered and many contained areas of high radiation or the
potential for high radiation. The HP technician accompanying the
inspectors was familiar with these locked areas and identified to the
inspectors how these areas are routinely monitored. The inspectors
found that contaminated areas were kept to a minimum and overall
equipment material condition and housekeeping were good. The inspectors
identified one exception in the letdown heat exchanger room. In this
room, a high radiation area, there was boron buildu) on the head flange
area of the heat exchanger and on the floor under tw flange.
The inspectors questioned the licensee's monitoring of this leakage
since it had the potential to corrode the flange mating surface and
flange studs and result in greater Reactor Coolant System (RCS) leakage
into the Auxiliary Building. The licensee has delayed repairs to the
heat exchanger since it involves the potential for high radiation
expcsure. The inspectors reviewed a licensee inspection of the heat
exchanger performed in May 1996. The boron was cleaned off the heat
exchanger, a stud was replaced, and a visual inspection identified
noticeable corrosion on the head of the tube sheet. This leakage,
however, has not significantly increased and has not resulted in greater
RCS leakage. The licensee plans to repair the letdown heat exchanger
during the upcoming refueling outage in October.
The inspectors concluded that overall material and housekeeping
conditions in locked areas of the Auxiliary Building were good with one
exception noted in the letdown heat exchanger room. The inspectors also
concluded that HP was adequately monitoring radiological conditions in
these areas.
c. Conclusions
Overall material and housekeeping conditions in locked areas of the
Auxiliary Building were good with one exception noted in the letdown
heat exchanger room. HP was adequately monitoring radiological
conditions in these areas.
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04 Operator Knowledge and Performance
04.1 Lower Auxiliary Buildina Giserator Rounds
a. Insoection Scope (71707)
The inspectors observed the licensee performing Lower Auxiliary Building
Operator rounds,
b. Observations and Findinas
On June 29, the inspectors observed the night shift Lower Auxiliary
Building 0)eratcr recording his TS logs. The log readings were recorded
on a hand leld data entry device. The ins >ectors reviewed the log
readings with the operator as they were tacen. All data taken met
acceptance criteria and channel checks were performed as required by TS.
The inspectors observed that the operator made an effort to observe and
understand all plant conditions going beyond normal log keeping. The
operator also investigated an oil and water leak in the B chiller room.
In addition to the TS rounds, the inspectors observed the operator
>erform System Operating Procedure (SOP), S0P 119, " Waste Gas
)rocessing," Section C. Revision 14. The operator switched gas decay
tanks from Bank A to Bank B.
c. Conclusions
Lower Auxiliary Building Operator rounds were completed in accordance
with Operation's guidelines. The operator was knowledgeable of his
duties and plant conditions.
07 Quality Assurance in Operations
07.1 Condition Event Report (CER) Screenina Meetina
a. JESDection Scone (71707)
The licensee formed a CER screening committee in order to bring more
consistency to the CER review process. The inspectors attended a CER
screening meeting to review the screening process,
b. Observations and Findinas
Due to inconsistencies identified in the CER dis)osition process, the
licensee established a screening committee, whic1 meets several times a
week, to review CERs and to ensure that they receive an appropriate
review and dis)osition. These screening meetings also ensure that CERs
are assigned tie correct cause codes to aid in trending. The inspectors
observed a screening committee meeting and concluded that establishing
this review process has brought more consistency to the disposition of
CERs.
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c. Conclusions
Establishing a screening comittee to review CERs has brought more
consistency to the disposition of CERs and benefits the licensee's
self assessment process.
08- Miscellaneous Operations Issues (92901)
08.1 (Closed) Unresolved Item (URI) 50 395/96007 04: control room meters
reading outside green indication zone. The licensee committed to
completing a modification to instrument meter green bands by
Maren 31, 1997. The purpose of the modification was to change the
placement of the bands such that the metors would read within the green
zone when the parameters were in a normal at power condition. The
modification was performed under Modification Review Forms (MRFs) 90102C
and G.- The inspectors reviewed the MRFs and observed the completed
meter changes in the control room and concluded that the modification
was completed satisfactorily. The modification was completed on
March 26, 1997.
II. Maintenance
M1 Conduct of Maintenance
M1.1 General Comments
a. InSDection Scooe (62707)
The inspectors observed or reviewed all or portions of the following
work activities:
- Maintenance Work Request (MWR) 9711331. Remove A Diesel Generator
(DG) Heat Exchanger End Covers and Perform Visual Inspection of
Selected Tubes.
- Preventive Maintenance Task Sheet (PMTS) P0211153, A DG Engine
Quarterly Maintenance.
- PNTS 9711621, Service Water Pump B 7.2 kV Breaker Operational
Check.
-- * MWR 9603078, Perform VT Examination on A Component Cooling Water
Pump Support,
b. Observations and Findinas
The inspectors observed the licensee's use of approved procedures,
calibrated equipment, and parts and supplies during the performance of
plant maintenance activities.
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The observed work was conducted in an appropriate manner and the
technicians exhibited a good level of knowledge and expertise regarding
the erk they were performing. No concerns were identified.
c. (20clusions
Observed maintenance activities were conducted in accordance with
approved procedures. Properly calibrated equipment, as well as correct
> arts and supplies were used. The technicians performing the work were
(nowledgeable.
Hl.2 Intermediate Buildina Sumo Puma Motor Preventive Maintenance
a. J.ntoection Scope (62700)
The inspectors reviewed and observed the electrical portions of
Haintenance Work Request / Task Sheet (HWR/TS) 9705447, Preventive
Haintenance Task Sheet (PHTS) P0211021, Perform PH on Sump C, Sump
Pump B Hotor,
b. Observations and Findinas
The insmetors observed portions of the Intermediate Building Sump C,
Pump B iotor preventive maintenance which involved and was performed in
conjunction with the molded case circuit breaker testing in accordance
with procedure EMP 295.004, " Inspection and PM of Electric Hotors."
Revision 9. Activities witnessed included visual inspection of the
breaker, overload reset (three times minimum), gasket material
inspection, and cycling of the breaker (five times minimum). These
activities were adequately performed.
c. Conclusions
Intermediate Building sump motor preventive maintenance activities were
well performed by competent technicians who were knowledgeable of the
assigned tasks.
H2 Maintenance e.nd Haterial Condition of Facilities and Equipment
H2.1 Surveillance Observations
a. Insoection Scone (62700)
The inspectors reviewed or observed all or portions of the following
surveillance tests:
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STP 128.302, " Intermediate Building Pre Action Sprinkler
Operational Test," Revision 11.
Test," Revision 5.
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- STP 508.003, "Holded Case Circuit Breaker Testing," Revision 8.
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b. Observations and Findinas
The inspectors observed the actuation of smoke detectors in the field.
The licensee used a test gas to simulate smoke at the detectors.
Observations were made in the field to verify that the detectors
actuated and then reset when the gas dissipated. The inspectors also
verified that the Simplex Graphics Monitor in the control room
identificd the detector and its location and status. Communication
between the control room and the fiele, was maintained, test personnel
were knowledgeable of the system. and test procedure STP 128.302 was
followed in performance of the test.
The inspectors observed the pre job briefing and test performance of-
Motor Driven Emergency Feedwater Pump A in accordance with procedure
STP 220.001A. The following activities were observed and determined to
be satisfactory:
. Recording as found conditions.
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Installation of calibrated test instrumentation.
.- Valve alignment to recirculation flow path.
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. Pump start and operation from the control room.
. Adjustment of flow to the reference value.
. Recording measured pump parameters and vibrations.
. Verification of check valve operability.
Test group personnel were knowledgeable of the procedure and the system.
The test was performed in a competent and professional manner.
The inspectors observed the testing of the molded case circuit breaker
for Intermediate Building Sump C, Puap B. This testing was performed in
the electt ical shop by procedure STP 508.003. The breaker was
disassembled, inspected, cleaned and meggered. In addition, the breaker
contacts were replaced and the trip setpoints were adjusted und tested.
The procedure specified acceptable ranges, torque values, and lifted
wire data sheets. The technicians were knowledgeable of the assigned
task and used appropriate safety precautions,
c. Conclusions
During observations of surveillance. tests of several smoke detectors, a
motor driven emergency feedwater pump and valves and a sump pump molded
case circuit breaker, the inspectors observed detailed, concise
procedures, procedural adherence, good planning and good communications.
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H2.2 Boration System Valve lineuo Verification
a. Inspection Scooe (61726)
The inspectors reviewed surveillance procedure STP 104.003, "Boration
System Valve Lineup Verification," Revision 5 to verify that it included
all the required valves to demonstrate operability of the boron
injection flow paths required in Mode 1.
b. Observations and Findinas
The inspectors reviewed STP 104.003 with the system drawings and found
that the surveillance procedure included all the valves required to
demonstrate operability of the boron in,1ection flow paths. The
inspectors also reviewed recent boration system valve lineups to verify
that they were completed satisfactorily,
c. Conclusioni
The inspectors verified that-procedures specified valves required to
demonstrate boron injection flow paths, and recently completed valve
lineups demonstrated system operability.
H2.3 Circuit Breaker Surveillance Testina
a. Insoection Scope (61726)
The inspectors reviewed the licensee's program for TS required circuit
breaker surveillance testing.
b. Observations and Findinas
On June 26, breaker XHCIC3X 51JL failed to meet the acceptance criteria
for instantaneous overcurrent trip on surveillance test STP 508.003,
"Holded Case Circuit Breaker Testing," Revision 8. The breaker was
replaced and returned to service. The inspectors reviewed the
licensee's program for compliance with TS 4.8.4.3, " Circuit Protection
Devices." The TS requires that for each circuit breaker found
inoperable, an addition'1 representative sample of at least ten percent
of all the circuit breakers of the inoperable type shall also be
functionally tested until no more failures are found or all circuit
breakers of that type have been functionally tested.
The inspectors found that the licensee had separated the breakers to be
tested into groups and monitored the testing of breakers in each group
to ensure each breaker was tested on a rotating basis. The inspectors
also found that when a breaker test failure occurred, an additional
sample was taken as required.
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c. Cenclusions
The inspectors concluded that the licensee's breaker testing program
ensured that selected groups of breakers would be tested and additional
samples would be taken when a breaker in a group fails a test.
III. Enaineerina
El Conduct of Engineering
E1.1 Snubber Removal /Reclacement Pro.iect
a. Inspection Scoce (37551)
ectors reviewed the licensee's on line snubber
The insp/ replacement project.
removal The inspectors observed a snubber removal
and replacement with a strut, reviewed the modification )ackage, and the
licensee's guidance and controls fer implementation of tie project,
b. Observations and Findinos
During the inspection period, the licensee im)lemented the on line phase
of their snubber reduction project. The snub >er reductions occurred in
two manners, either specified snubbers were removed or specified
snubbers were removed and were replaced with struts.
The inspectors reviewed the licensee's evaluation of system operability
during the transition between the-two piping analyses that applied while
the project was in progress. There was an original analysis for the
snubbers in place before the snubber reduction project began and an
analysis for the completed project that included the snubbers that were
replaced with struts and/or removed. There was no specific analysis for
the transition between the two analysis. The licensee's review
concluded that the seismic qualification of the systems being modified
would not be degraded below what was minimally acceptable to maintain
compliance with American Society of Hechanical Engineers Code criteria
during the temporary configurations created by the snubber removal
project. The inspectors reviewed the licensee's evaluation and
concluded that the licensee had adequately estat,lished that system
operability during these system transitions would be maintained.
The inspectors found that the licensee had established clear operational
guidelines for the snubber reduction project through a Station Order.
The first items worked on a specific system were snubber removals.
During this phase the system was considered operable. When a snubber
was re) laced with a strut. Operations declared the system inoperable
until Engineering provided Operations with evidence that the work was
complete and that the system configuration was in accordance with the
modifict. tion specifications.
_ _ _ _ _ _ _ _ .
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12
On June 26, the inspectors observed a snLbber to strut replacement on
safety related su) port MK CSH 1494 on the Chemical and Volume Control
System (CVCS). T11s was the first snubber to strut replacement
performed. The inspectors observed the conduct of the work and
discussed the modification with the design engineer during the snubber
replacement. The work was completed under MWR 9707569 and performed
using Mechanical Maintenance Procedure. MMP 305.004, " Installation,
Removal, Rework and Reinstallation of Pipe Supports," Revision 5, and
MRF 223528 " Snubber Reduction for CVCS System." The inspectors had no
questions and concluded that the strut was installed correctly.
On July 10, during a review of MWR 9707569 the licensee identified an
inconsistency between the steps in the body of
the sign off steps in the proceduce data sheet.The procedure procedureMMP
data 305.004 and
sheet did not require that the strut movement tolerance measurements
specified in step 7.12.8.C be documented. The licensee's investigation
found that the step had been completed but not specifically documented.
An engineering review of the step determined that documentation was not
necessary based on other verifications performed in the procedure.
A further review of the procedure and other completed work documentation
by the licensee identified that MMP 305.004 had not been adequately
revised to reflect specific installation requirements for Grinnel type
restraints. The original modification package had been prepared using
Bergen Paterson restraints. The MRF was later revised to use Grinnel
restraints. A review of the procedure had not been performed to ensure
that the different installation requirements were included in the
procedure. The procedural discrepancies identified included: Step
7.12.9 of INP 305.004 required verification of less than a four degree
angular tolerance between the structural attachment and the pipe
attachment. The MRF for the Grinnel restraints required a maximum three
degree-angalar tolerance. Step 7.12.11 re
to-torque values given in Enclosure 10.4. quired torquing
The torque the locknuts
schedule given in
Enclosure 10.4 was for Bergen Paterson type restraints. The Grinnel
restraints required hand tightening plus 1/8 of a turn.
When these )rocedural issues were identified, the licensee immediately
stopped wor ( on the snubber replacement project until the hardware and
procedural issues were resolved. 1he licensee verified in the field
-
that the two Grinnel restraints installed were installed correctly. The
licensee also revised HMP 305.004 to reflect-the MRF requirements for
the Grinnel type restraints. A root cause evaluation team was also
established to determine the causes of this problem.
The ins >ectors' review of this issue with the licensee concluded that
althoug1 a deficient procedure had been used, the restraints were
installed correctly. The technicians performing the snubber
re)lacements were aware of the correct installation requirements in the
MR: and had noted the specific Grinnel restraint installation
requirements on the procedure data sheet. The technicians, however, had
not followed procedure adherence requirements by failing to revise the
procedure before proceeding with restraint installation.
._ _ _. _
I .
.
13
The inspectors concluded that procedure HMP 305.004 was inadequate in
that it did not include all the specific requirements for installation
of the Grinnel type restraints. The procedure had not received the
appropriate interface review prior to implementing the snubber
replacement. The inspectors also concluded that the technicians
prforming the restraint installation had not followed SAP 139.
Procedure Development, Review, Approval and Control," Revision 17, in
that they had not corrected the discrepan ios in procedure MMP 305.004
prior to performing the Grinnel restraint installation. A quality
control ins)ector raised a question on HMP 305.004 which resulted in the
review of t1e snubber replacement project.
The failure to establish an adequate procedure for the installation
of the Grinnel type restraints is identified as a VIO. The inspectors
concluded that although this issue was licensee identified, the licensee
had missed several opportunities during the process to implement this
modification to identify and correct the procedural deficiencies.
These included procedure reviews prior to performing the snubber
replacement and during installation in the field. This is identified
as VIO 50 395/97007 02.
c. Cpnclusions
A review of the snubber replacement project identified a VIO for a
failure to establir.h an adequate procedure for the installation of
Grinnel type restraints. Although this issue was licensee identified,
the licensee had missed several o)portunities to identify and correct
these procedural deficiencies. T1e missed op)ortunities included
procedure reviews prior to >erforming the snu)ber replacement and during
the field-installation by tie technicians.
E2 Engineering Support of Facilities and Equipment
E2.1 Evaluation oi' the Failure of Reactor comoartment Coolino Fans
a. Insoection Scooe (37551)
The inspectors reviewed an engineering evaluation performed to allow
continued operation of the 31 ant following the failure of both reactor
compartment cooling fans, X N00009A and B.
b. Observations and Findinas
Early into the present operating cycle (May 1996), the motor on reactor
compartment cooling fan XFN00009A failed. The two reactor compartment
cooling fans XFN00009A and B are each 100 percent capacity cooling fans
which provide forced ventilation to the compartments surrounding the
reactor vessel. Witt, the A fan failed, the 8 fan was able to provide
the required forced cooling with the plant operating at 100 )ercent
power. On July 11, high vibration alarms were received on tle B fan and
the fan was shut down.
_ _ _ _ _ _ _ _ _ _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
14
In July 1996, the licentee evaluated the consequences of a loss of
forced ventilation to the reactor compartment during full power
,
operation. The evaluation considered the design basis functional areas
of average Reactor Building temperature, concrete temperature, and
environmental qualification of nuclear instrumentation. In addition,
the evaluation addressed flooding, fire, hot gaps, and the accuracy of
the power range nuclear detectors.
The licensee's evaluation concluded that the design basis functions of
the Reactor Building Cooling and Filtering System would continue to be
met following the loss of both reactor compartment cooling fans provided
that natural circulation ventilation was established through the reactor
compartment. The average Reactor Building temperature wou~.1 remain
below the maximum of 120*F since the cooling fans only circulate reactor
compartment air and do not provide any cooling ef fect. The calculated
temperature of the concrete inside the reactor cavity would exceed the
150'F design limit in the area of the reactor support steel. However,
an associated calculation assumed a 200"F temperature in this area. The
nuclear instrumentation was evaluated to remain operable if natural
circulation ventilation was established within 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />. This would
ensure that the instruments would not be exposed to temperatures greater
than 200'F. The inspectors reviewed the details of the analysis and
concluded that the supporting arguments were reasonable and addressed
the concerns adequately.
As described above, the design basis functions would continue to be met
provided that natural circulation ventilation was established through
the reactor compartment. This would be achieved by opening the door to
the incore instrument chase within 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of the loss of forced
cooling. The licensee's evaluation considered the consequences of 4
Vlooding and fire with this door open.
On July 11, the licensee made a Reactor Building entry to establish
natural circulation ventilation in the reactor vessel comaartments. The
inspectors reviewed computer generated plots for incore clase area
temperatures, nuclear detector instrument response, and quadrant power
tilt ratios. These plots spanned a time frame from the day before fan
XFN00009B was shut down to several days after the fan was shut down and
the incore instrument chase door was opened. The incore chase area
temperature response was as expected with the equilibrium temperature on
natural circulation reactor building cooling actually slightly lower
than with forced cooling. The plots showed a slight decrease in the
power range detector response with the N42 instrument showing the
largest change. The N42 instrument, located closest to the incore
instrument ch8se door, realized the largest temperature change upon
establishing natural circulation ventilation. The change in detector
output was less than one percent and was relatively stable as predicted.
Using a heat balance, nuclear instrumentation was adjusted to compensate
for this effect. The inspectors had no concerns with the plant
response.
.
, .
,
15 ;
c. Conclusions
The licensee's evaluation to allow continued full power operation
'
l following the failure of both reactor compartment cooling fans was
adequate. The evaluation was thorough and considered all relevant
aspects of the loss of forced cooling. Plant response upon e tab 11shing
, natural circulation ventilatio'1 through the reactor compartment was as
. expected.
l E2.2 Refuelina Water Storaoe Tank (RWST) Level Setooint Change
a. Insoection Scooe (3755D
The inspectors reviewed a plant modification design package to change
,
the RWST low level alarm setpoint from 90 percent to 93 percent,
b. Observations and Findinas
To account for measure n nt error, the licensee changed the TS
- surveillance log limit for RWST minimum icvel from 88 percent to 91
percent. The previous setting for the RWST low level alarm was 90
- percent which was below the new TS log minimum level. To maintain the
function of this alarm, the alarm setpoint was increased to 93 percent
'
using Engineering Change Request (ECR) 50033. This would provide an
anticipatory alarm (two percent above the TS log minimum) to allow time
for plant operators to correct the condition before entering a TS
- required action. In addition. ECR 50033 changed the color labeling on
- the main control board indicators for RWST level to provide a blue
.
indicator at 91 percent to correspond to the TS log minimum limit and !
changed the green band to 91 to 100 percent-to reflect the new
conditions.
2
The inspectors reviewed the ECR and the associated 10 CFR 50.59
screening review form and concluded that they contained all pertinent
information to make the modification. All affected documents and
- procedures were identified which would require revision including STPs.
annunciator response procedures, and integrated plant computer system
changes. The design package also included sufficiently detailed
<
engineering instructions for performing the required modifications. The
inspectors identified no concerns with the ECR.
c. Conclusions
,
i The licensee's modification design package to change the RWST low level
.
'
alarm setpoint, associated documents and indicators was well written and
complete. Engineering instructions and supporting-documentation were
adequate to provide sufficient detail to complete the modification.
.
L
w 4 - - .. ,, ,r , < , . , - ,3 -~m-- v---- c m---- m,- w,_,- , - - - - - - ,- <-- e e - - w,--
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _
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16
E7 Quality Assurance in Engineering Activities (37551)
E7.1 Review of Updated Final Safety Analysis Report (UFSAR) Commitments
A recent discovery of a licensee o>erating their facility in a manner
contrary to the UFSAR description lighlighted the need for a special
focused review that compared plant practices, procedures and/or
parameters to the UFSAR description. While performing the inspections
discussed in this resort, the inspectors reviewed the applicable
portions of the UFSAl that related to the areas inspected. No
discrepancies were identified.
E8 Hiscellaneous Engineering Issues (92903)
E8.1 1Clqted) URI 50 395/97003 05: evaluation of high Emergency Feedwater
(EFW) System differential flow rates. As described in NRC Integrated
Inspection Report (IIR) 50 395/97003, the licensee identified a larger
than expected differential in EFW flows to each Steam Generator (SG)
upon automatic actuation of EFW following a reactor trip on April 22,
1997. This condition was corrected prior to start up of the plant end
the inspectors had no concerns with the as left condition of the EFW
system. A subsequent consequence analysis was completed and reviewed in
NRC IIR 50 395/97005. This analysis concluded that the as found
condition of the EFW system would not have )roduced a condition which
was outside of the plant's design basis. T1e licensee completed a root
cause analysis on August 4 to determine how the EFW system had been left
in a condition that provided unbalanced flow to the three SGs. The
inspectors reviewed the analysis and the proposed corrective actions.
The cause of the flow imbalance was identified as incorrect stroke
length on the EFW flow control valves. These valves are three inch,
normally open, air operated globe valves. Adjustable mechanical stops
are used to limit the opening stroke length of the stem which in turn
limits the flow rate through the valve. The valves were left in the
incorrect condition following maintenance which did not include
verification of proper valvo set up. The analysis identified seven
maintenance and test procedures that were used on the EFW flow control
valves which did not adequately address the proper set up or testing
of the valves. Specifically, HMP 300.021. " Type 657 Actuators,"
Revision 6, contained instructions on replacement of the valve operator
diaphragm but did not recognize that this replacement could affect the
valve stroke length and did not verify stroke length following diaphragm
replacement. In addition, the following procedures did not recognize
that full stroke of the actuator may not include all available stroke
and did not address the need to verify full stroke in both normal and
emergency modes:
to Stm Gen. A IFT03531," Revision 7.
Calibration," Revision 8.
. . . . . . . . .
___ _ __
'
.
f 17
. ICP 195.012, * Emergency FW to Stm Gen. C Flow IFT03551
Calibration," Revision 6.
. STP 396.001, " Emergency FW to Steam Generator "A" Flow Instrument
(IFT03561) Calibration," Revision 4.
. STP 396.002. " Emergency FW to Steam Generator "B" Flow Instrument
(IFT03571) Calibration," Revision 4.
- STP 396.003. " Emergency FW to Steam Generator "C" Flow Instrument
(IFT03581) Calibration," Revision 4.
The licensee's corrective actions as described in the root cause
analysis report included revising the design basis document and
supporting design documents to establish an EFW flow balance criteria
and performing the required analysis for the procedure revisions. The
corrective actions also included establishing allowable tolerances for
the set up of the flow control valves, and incorporating the tolerances
and the as found and as left stroke length measurements into the revised
procedures. In addition, a new procedure would be generated to perform
a flow balance test. The inspectors considered these actions adequate
to provide the necessary guidance to properly set up the EFW flow
control valves and to prevent a similar differential flow balance
condition. The inspectors considered the licensees' root cause analysis
to be adequate.
The failure to provide adequate maintenance and testing procedures to
maintain proper set up of the EFW flow control valves is identified as a
violation. This non repetitive, licensee identified and corrected
vinlation is being treated as a Non cited Violation (NCV) consistent
with Section VII.B.1 of the NRC Enforcement Policy. This is identified
as NCV 50 395/97007 03.
JL Plant Support
R1 Radiological Protection and Chemistry (RP&C) Controls
R1.1 General Comments
The inspectors observed radiological controls during the conduct of
tours and observation of maintenance activities and found them to be
acceptable. The inspectors observed during a tour of locked high
radiation areas and locked rooms in the Auxiliary Building that
' contaminated areas were kept to a minimum and radiological controls were
well maintained.
I
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18
P1 Conduct of Emergency Preparedness (EP) Activities
Pl.1 Radio Paoer Drill
a, Insoection Scope (71750)
The inspectors reviewed the results of a radio pager drill conducted by
the licensee on June 10.
b. Observations and Findinas
On June 10, the licensee conducted a monthly pager drill designed to
test the ability of the pager system to reach the Emergency Response
Organization (ER0) members after hours and away from the site and to
test the ability of the ERO members to receive the page. The test
results indicated that 82 percent of the available members responded.
This constituted a satisfactory drill (greater than 80 percent response
is considered satisfactory) although a higher percentage is normally
expected. All positions required for minimum staffing were filled.
Several positions not required for minimum staffing were not filled.
Available licensee personnel who carry ERO pagers (approximately 200)
are required to respond to a page within one hour by calling a 1 800
number to connect to the Emergency Response Organization Notification
System computer. As an alternative, members may call a member of the
emergency response group and leave a voice mail message to acknowledge
the page. The resmnse is then correlated and tabulated by position and
the results publisled in a remrt. The inspectors considered these
expectations reasonable and t1at the call back system provided
acceptable assurance that the minimum required positions would be filled
in the event of a real emergency,
c. Conclusions
The results of a monthly pager drill conducted during the inspection
period were satisfactory. The current call back system prolided
adeguate assurance that the required minimum staffing positions would be
filled in the event of an actual emergency.
Pl.2 EP Drills 31750)
The inspectors observed a practice EP drill on June 18 which was
conducted in preparation for the scheduled biannual drill conducted in
July. Observations were made from the simulated control room, the
Emergency Operations Facility and the Technical Support Center. No
concerns were identified.
The inspectors observed portions of the biannual EP drill conducted on
July 16. Details of this exercise along with observations and
conclusions are documented in NRC IIR 50 395/97010.
. _ . . _ _ _ _ . __ _ _ _ _ _ _ _ _ _ _ _ - _
.
19
S1 Conduct of Security and Safeguards Activities
S1.1 Access to the Protected Area Usino left Hand
a. Inspection Scooe (71750)
The inspectors reviewed the acceptability of a licensee employee gaining
access to the >rotected area using the left hand inserted palm up into
the biometric land reader.
b. Observations and Findinas
On July 1, the ins)ectors observed a licensee employee using the left
hand, palm up in t1e biometric hand reader to gain access to the
protected area. It was not obvious to the inspectors why the employee
could not use the right hand, palm down in the hand reader as would
normally be expected. The inspectors auestioned the licensee about this
)ractice and were informed that two people were authorized to use the
land reader in this fashion. One person was missing a finger on the
right hand such that the associated peg in the hand reader could not be
properly engaged and the other had been exposed to >oison ivy and was
experiencing swelling in his right hand such that t1e hand reader may .
not allow access. The ins
'
exposed to the poison ivy.pectors The licenseehad demonstrated
observed thethat
person that had been
acceptable
administrative controls were in place to prevent unauthorized use of the
hand readers but that some flexibility could be used when necessary,
c. Conclusions
The licensee's administrative controls for the use of the biometric hand
readers were effective to prevent unauthorized use but still provide
reasonable flexibility when necessary. Two plant employees were
authorized to use the hand readers in a manner other than the normally
used method.
F2 Status of Fire Protection Facilities and Equipment
F2.1 Wet Pioe Sorinkler System Pressures
a. Insoection Scope (71750)
The inspectors reviewed the licensee's actions regarding an overpressure
condition in several non safety related wet pipe sprinkler systems in
the Turbine Building and the Control Building.
b. Observations and Findinas
On July 26. the licensee identified an overpressure condition in three
wet pipe sprinkler systems servicing the Turbine Building and the
Control Building. The normal pressure in these systems was 125 psig.
The observed pressure on the installed pressure instruments for these
three systems ranged from 200 to 285 psig. The fire protection system
_ _ _ _ _ _ _ - _ _ - _
_. __ __ _.
'
.
20
engineer walked down the remainder of the wet pipe systems and
identified several others which were pressurized in excess of their
working pressure.
The cause of the overpressure condition was identified as pressure
surges and fluctuations in the supply pipe which trap water on the
downstream side of clapper valves installed in each individual system.
The system pressure increases with repeated pressure surges since there
were no provisions made to relieve the pressure. Also, high ambient
temperatures were identified as contributing to the condition which tend
f
to increase system pressure as the trapped water temperature increases.
The licensee did not identify any operability con wns with the observed
condition after walking down the entire Fire Protection System. No
I.
system leaks or other damage were noted. The overpressure condition was
corrected by relieving system pressure through manual valves. Six wet
pipe sprinkler systems were placed on a periodic monitoring schedule
with instructions to the operators to manually relieve system pressure
when it reached 175 psig. System pressure was to be lowered to 135
psig.
The inspectors did not identify any concerns regarding the licensee's
actions. The system engineer appeared to understand the causes and was
pursuing long term corrective actions.
c. Conclusions
The licensee's actions concerning an overpressure condition in multiple
wet pipe sprinkler systems were appropriate. The causes were
established and effective interim corrective actions were instituted.
V. Manaaement Meetinos
X1 Exit Meeting Summary
The inspectors ) resented the inspection results to members of licensee
management at t1e conclusion of the inspection on July 30, 1997. The
licensee acknowledged the findings presented.
The inspectors asked the licensee whether any materials examined during
the inspection should be considered proprietary. No proprietary
information was identified.
i
.
21
PARTIAL LIST OF PERSONS CONTACTED
Licensee
F. Bacon, Manager, Chemistr Services
L. Blue, Manager, Health Ph sics and Radwaste
S. Byrne, General Manager, uclear Plant Operations
R. Clary, Manager. Quality Systems
C. Fields Manager, Materials and Procurement
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 Planning and Development
H. O'Quinn, Manager, Nuclear Frotection Services
A. Rice, Manager Nuclear Licensing and Operating Experience
G. Taylor, V'.ce President Nuclear Operations.
R.-Waselus. Manager, Systems and Component Engineering
R. White, Nuclear Coordinator, South Carolina Public Service Authority
B. Williams, General Manager, Engineering Services
G. Williams, Associate Manager, Operations
.
... .
. . . . .
.. ..
. _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _
4
22
INSPECTION PROCEDURES USED
IP 37551: Onsite Engineering
IP 61726: Surveillance Observations
IP 62707: Maintenance Observations
IP 71707: Plant Operations
IP 71750: Plant Support Activities
IP 92901: Followup Plant Operations
IP 92903: Followup Engineering
ITEMS OPENED AND CLOSED
Opened
50 395/97007 01 VIO failure to comply with requirements of TS 3.6.4,
containment isolation valves (Section 01.2).
50 395/97007 02 VIO inadequate procedure for snubber replacement
(Section E1.1).
50 395/97007 03 NCV failure to provide adequate maintenance and
testing procedures to maintain proper set up of
the EFW flow control valves (Section E8.1).
ClQied
50 395/96007 04 URI control room meters reading outside green
indication zone (Section 08.1).
50 395/97003 05 URI evaluation of high Emergency Feedwater System
differential flow rates (Section E8.1).
'
50 395/97007 03 NCV failure to provide adequate maintenance and
testing procedures to maintain proper set u
the EFW flow control valves (Section E8.1).p of
.
.mm&