IR 05000395/1984037

Insp Rept 50-395/84-37 on 841201-31.Violations Noted: Failure to Establish Fire Watch for Inoperable Fire Barrier Door & Failure to Demonstrate Operability of Containment Isolation Valves Prior to Entering Mode 4

ML20132D257
Person / Time
Site:	Summer
Issue date:	01/23/1985
From:	Cantrell F, Hehl C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20132D247	List: IR 05000395/1984037 ML20132D245 ML20132D252
References
50-395-84-37, NUDOCS 8507170009
Download: ML20132D257 (10)

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Moo UNITED STATES o,, NUCLEAR REOULATORY COMMISSION M, ' o REGION li 3 $ 101 MARIETTA STREET, * # ATLANTA. GEORGIA 30303

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Report No.: 50-395/84-37 Licensee: South Carolina Electric and Gas Company Columbia, SC 29218 Docket No.: 50-395 License No.: NPF-12 Facility Name: Summer Inspection Conducted: December 1 - 31, 1984 Inspector: ::; 2 4 /fM C. W. Hehl Dat( Signed Approved by: F.'S. Can~trell, Sectf ' Chief

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'Date Signed Division of Reactor rojects SUMMARY Scope: .This routine, unannounced inspection entailed 136 inspector-hours on site in the areas of plant tours; operational safety verifications; monthly surveil-lance observations; monthly maintenance observations; plant startup from refuel-ing observations; onsite followup of operating reactor events; independent inspection effort; review of inspector followup items and licensee action of previous enforcement matter Results: Two violations were identified-failure to establish a fire watch for fire barrier door IB 310B, paragraph 5; and failure to demonstrate operability of three containment isolation valves prior to entering mode 4, paragraph !

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REPORT DETAILS Licensee Employees Contacted

• 0 Bradham, Director, Nuclear Plant Operations

• K. Woodward, Manager, Operations B. Williams, Supervisor of Operations M. Quinton, Manager, Maintenance

• M. Browne, Manager, Technical Support

• B. Croley, Group Manager, Technical and Support Services

• Irwin, Nuclear Licensing, Specialist

• R. Campbell, Engineer, ISEG

• J. Derrick, Associate Manager, Maintenance Engineering

• C. McKinney, Technical Specialist, Regulatory Compliance

• A. Koon, Associate Manager, Regulatory Compliance

• H. Sefick, Associate Manager, Station Security

• J. Connelly, Deputy Director, Operations and Maintenance Other licensee employees contacted included engineers, technicians, opera-tors rmechanics, secur:ty force members, and office personne * Attended exit interview Exit Interview The inspection scope and findings were summarized on January 4,1985, with those persons indicated in paragraph 1 above. The licensee acknowledged the inspection finding As indicated in paragraph 6 of this report, the licensee expressed a commitment to incorporate into future performances of integrated safeguards testing, a method to ensure that the auto block as well as the auto start functions of the load sequencers are teste The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspectio . Licensee Action on Previous Enforcement and Inspector Followup Items (92702)

(Closed) Inspector Followup Item, 84-30-02. This followup item existed to track implementation of a licensee commitment to submit to NRR a revised program schedule for retrieval and analysis of sample coupons from the spent fuel storage rack The licensee submitted this revised schedule in a letter to NRR on December 14, 198 (Closed) Violation, 83-27-04. This two part violation dealt first with inadequacies in the implementation of the Operational QA Plan requirements for listing measuring and test equipment to be controlled and measures for documenting which safety-related tests were performed with each piece of measuring and test equipment. The second part of this violation dealt with the necessity for upgrading the drawing control program, specifically, to eliminate an existing backlog of drawing revisions and to provide marked up

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interim drawing for use following system modification until permanent revisions are availabl The inspector reviewed changes to Nuclear Quality Control Procedure A-NQCP-9, Equipment Control, and Chemistry Procedure CHP-501, Calibration and Standardization of Requirements. These changes incorporated controlled listing of measuring and test equipment, and a methodology for documenting which test equipment was utilized on which safety-related equipmen The inspector also reviewed the Instrument and Control Department program for complying with these requirements. These requirements were determined to be adequately implemented thus closing the first part of this violatio The second part of the violation dealt with required upgrades to ensure that drawings classified as essential, those considered by Operations to be essential .for control and operation of the plant, accurately reflect the as-built condition of the plant. To accomplish this goal, the licensee implemented a program to resolve the existing drawing revision backlog and to require the issuance of interim drawings, which accurately reflect the area of change, following plant modifications' requiring changes to essential drawing These controlled interim drawings are replaced with permanent drawing revisions once generated. The inspector reviewed the results of this upgrade effort and determined that the licensee had brought the backlog of drawing changes under control and changes to the modification program had been implemented to require the issuance of the interim drawings to reflect the as-built condition of the plant. Presently, the licensee is experienc-ing some problems with the reproducibility of the interim drawings. for distribution, but controlled full scale interim drawings are available for use by the control room and the planning and scheduling group. The licensee has committed to resolving-this reproduction proble . Unresolved Items *

Unresolved items were not identified during this inspectio . Operational Safety Verification (71707, 71710)

The inspector observed control room operations, reviewed applicable logs and conducted discussions with control room operators during the report perio The inspector verified the operability of selected emergency systems, reviewed removal and restoration logs, and tagout records, and verified proper return to service of affected component Tours of the control, auxiliary, intermediate, diesel generation,- service water and turbine

' buildings were conducted to observe plant equipment conditions including potential fire hazards, fluid leaks, and excessive vibrations, and to verify

• An Unresolved Item is a matter about which more information is required to determine whether it is acceptable or may involve a violation or deviatio )

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that maintenace requests had been initiated for equipment in need of maintenance. The inspector, by observation and direct interview, verified that the physical security plan was being implemented in accordance with the Station Security plan.

During a tour of the plant on December 19, 1984, conducted by a NRC Region

.II security inspector accompanied by a licensee-security guard, fire door IB 310B was found to be- open and unattended. The subject fire door was found-to be propped open by insertion of two screw drivers. Upon identification,

the licensee security guard immediately returned the door to its required closed positio Technical' Specification (TS) 3.7.10 requires that fire doors separating safety related fire areas be operable at all times. With a fire door i

inoperable the licensee is to within one hour, establish a continuous fire watch or verify operability of the fire detector on at least one side of the inoperable door and establish an. hourly fire watch patrol.

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Subsequent review of_this finding has determined that the cognizant licensee

' organization was unaware that fire door IB 310B was inoperable and therefore had not implemented the compensatory action required by TS 3.7.10. This failure to satisfy the requirements of TS 3.7.10 is a violation. Failure to establish required fire watch for fire door IB 310 (84-37-01) Surveillance Observation (61726)

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During the inspection period, the inspector verified by observation / review

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that selected surveillances of safety-related systems or components were conducted in accordance with adequate procedures, test instrumentation was calibrated, limiting conditions for operation were met, removal and resto-ration of the affected components were . accomplished, test results met requirements and ware reviewed by personnel other than the individual directing the test, and that any test deficiencies identified during the testing were - properly reviewed and resolved by appropriate management

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personne During this review the following deficiency was identifie The ' inspector reviewed data taken during the performance of Surveillance

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Test Procedure (STP) 125.005, Integrated Safeguards - Test, for safeguards l trains A and B, Oneuof the purposes of STP~ 125.005 is to verify that for events such as a loss of off ' site power or a loss of off site power in conjunction.with an Engineered Safeguards Feature (ESF) actuation signal, the diesel generators start and energize their associated emergency power buses and auto-:onnect

, appropriate safety system. loads through the load sequencers. In add. tion to

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the auto-connect function, the load sequencers block auto start of.certain- i loads depending upon equipment status and initiating signal ~. The above i

verifications are required by TS 4.8.1.1.2 to demonstrate diesel generator operability.

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'i Inspector review of data collected during performance of STP 125.005 deter-mined that due to system configuration at the time of the test, the capa-bility of the load sequencer to energize component cooling pump A had not

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been verified. Additionally, the capability of the sequencers to block auto start of certain " swing" pumps (component cooling pump C, service water pump

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C and changing pump C) upon receipt of an ESF actuation signal had not been

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verified. The inspector informed licensee management of this finding and-these load sequencer functions were subsequently verified and documented pr*cr to unit-restar In that a malfunction of.the auto block sequencer function would be readily apparent during the performance of these tests, coupled w 'h the licensee's prompt action to verify this function and a subsequent licensee commitment to implement a procedure change to require verification of this function during future performances of STP 125.005 ~ appears adequate to resolve this issue. This licensee commitment will be tracked as an Inspector Followup Item (84-37-02).

No violations or deviatio.ns were identified in this are . Maintenance Observation (~62703)

Station maintenance activities of selected safety-related systems and components were observed / reviewed to ascertain that they were conducted in accordance with regulatory requirements. The following items were con-sidered in this review: the limiting conditions for operations were met; activities were accomplished using approved procedures; functional testing and/or calibrations were. performed prior to returning ccaponents or systems to service; quality control record were maintained; activities were accom-plished_ by qualified personnel; parts and materials used were properly certified; and radiological controls were implemented as required. Main-tenance Work Requests were reviewed to determine status of outstanding jobs to assure that priority was assigned to safety-related equipment which might affect system performance. No violations' or deviations were identified in this are . Plant Startup From Refueling (71711)

The inspector reviewed plant procedures and conducted discussions with control room operators and operations management to verify that the licensee i

L had developed administrative controls and checklists for returning to an operable status those safety-related systems and/or components which under-went maintenance or were disturbed during the outage. The inspector reviewed -plant startup procedures to verify that these procedures required adherence to the facility TS and other commitments pertaining to startup ,

testing and power operatiun prerequisites. Following system realignments in preparation for startup, the inspector performed walkdown of appropriate l

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l loads depending upon equipment status and initiating signal. The above verifications are required by TS 4.8.1.1.2 to demonstrate diesel generator operabilit Inspector review of data collected during performance of STP 125.005 deter-mined that due to system configuration at the time of the test, the capa-

.bility of the load sequencer to energize component cooling pump A had not

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been verified. Additionally, the capability of the sequencers to block auto l start of certain " swing" pumps (component cooling pump C, service water pump i- C and changing pump C) upon receipt of an ESF actuation signal had not been i verified. The inspector informed licensee management of this finding and l these load sequencer functions were subsequently verified and documented l prior to unit restart.

l l In that a malfunction of the auto block sequencer function would be readily l apparent during the performance of these tests, coupled with the licensee's l prompt action to verify this function and a subsequent licensee commitment

to implement a procedure change to require verification of this function during future performances of STP 125.005 appears adequate to resolve this I issue. This licensee commitment will be tracked as an Inspector Followup Item (84-37-02).

No violations or deviations were identified in this area.

! Maintenance Observation (62703)

Station maintenance activities of selected safety-related systems and components were observed / reviewed to ascertain that they were conducted in accordance with regulatory requirements. The following items were con-sidered in this review: the limiting conditions for operations were met; activities were accomplished using approved procedures; functional testing and/or calibrations were performed prior to returning components or systems l to service; quality control record were maintained; activities were accom-plished by qualified personnel; parts and materials used were properly

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certified; and radiological controls were . implemented as required. Main-tenance Work Requests were reviewed to determine status of outstanding jobs l to assure that priority was assigned to safety-related equipment which might affect svstam performanc No violations or deviations were identified in this ars l Plant st_,6up From Refueling (71711)

i j The inspector reviewed plant procedures and conducted discussions with ( control room operators and operations management to verify that the licensee

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had developed administrative controls and checklists for returning to an operable status those safety-related systems and/or components which under-i went maintenance or' were disturbed during the outage. The inspector reviewed plant startup procedures to verify that these procedures required !

l adherence tc the facility TS and other commitments pertaining to startup l testing and power operation prerequisites. Following system realignments in

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preparation for startup, the inspector performed walkdown of appropriate

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portions of several systems disturbed during the outage to independently ascertain that they had been properly returned to servic In preparation for return to power from this extended refueling outage, the licensee conducted an alignment of all systems. These alignment verifica-tions were accomplished using the approved System Operating Procedure (SOP)

for each system. Each of SOPS include valve, electrical and instrument lineup shaets which are performed by an operator and then reviewed and verified complete by a licensed Senior Reactor Operato The inspector reviewed a sample of ten of these completed SOPS and performed and indepen-dent walkdown inspection of two safety systems. No significant deficiencies were identified during this revie The licensee General Operating Procedures (GOP) 11,1, 2, 3 and 4 are the controlling documents for taking the plant from the completion of fuel load back to full power operation. A review of these procedures determined that each procedure includes check sheets and associated sign-offs which require the operator to verify prior to changing plant modes, that system alignments are current and to evaluate whether systems which were out of service or disturbed require realignment. In addition to these alignment checks, each procedure requires the operator to review the Equipment Removal and Resto-ration Log, the Danger Tag Log and the Maintenance Work Request Log for any existing equipment / configuration limitations prior to each plant mode change. The GOP's were found to include steps to trigger and sign-offs to verify complet ion of required surveillance testing. Surveillance check lists in the for. of attachments to the licensee's General Test Procedure (GTP) 702, Surveillance Activity Tracking and Triggering, identify surveil-lance activities required to be current for each plant mode change. The inspector reviewed the completed G0P's, GTP 702 attachments and a sampling

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of the associated surveillance data sheets at selected points during piant startup. The following deficiency was identified during this revie On December 13, 1984, during review of completed GOP-1, Plant Startup and Heatup From Cold Shutdown to Hot Shutdown, the inspector determined that required stroke time testing of feedwater reverse flush valves XVG-1678 A, B and C had not been completed prior to changing plant mode TS 3.6.4 requires these valves to be operable in plant modes 1, 2, 3 and 4. TS 4.6.4.3 requires demonstration of this operability by determining that the isolation time of these valves is within its limit when tested pursuant to the licensee's Inservice Inspection Progra TS 4.0.4 precludes entry into an operational mode unless the surveil-lance requirements associated with the limiting condition for operation have been satisfie Valves XVG 1678 A, B and C are identified in TS Table 3.6-1 as Phase

"A" containment violation valves and receive separate isolation signals from protective trains "A" and "B". Station Surveillance Test Pro-cedure (STP) 130.001, Valve Operability Testing, implements the TS 4.6.4.3 Inservice Inspection Program isolation time measurement

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requirements for these valves by requiring them to be stroke timed (closed) in response to signals from both protection train "A" :nd protection "B" switches. On December 13, 1984,- the plant was taken from mode 5 to mode 4 but the required testing of these valves in response to a signal from protection train "B" had not been performe This failure to demonstrate operability of these containment isolation valves in response to both protection trains prior to entering mode 4 is a violation of TS 4.0.4 (84-37-03).

Since valves XVG 1678 A, B and C are normally closed (their phase "A" isolation position) except for brief periods of time during plant startup and these valves had been successfully stroke timed in response to protection train "A" signal, the safety significance of not verify-ing the stroke time in response to protection train "B" is of minimal safety significance. However, what is of concern is that the licen-see's controls to assure required surveillances were completed prior to mode change did not prevent this occurrenc As indicated above, the licensee's GOP's contain triggers and sign-offs to assure required surveillances are complete prior to changing mode GOP-1, Step IV 3.g. contains the trigger and sign-off designed to accomplish this for mode change 5 to 4. Step IV 3.g. requires the operator to review General Test Procedure (GTP) 702, Attachment IIC.,

which lists the surveillances required to be complete prior to changing from mode 5 to 4. Inspector review of these documents determined that GTP 702 attachment IIC. utilized for mode change on December 13, 1984 identified STP 130.001 as not complete, yet, GOP-1 step IV 3.g. had been initialed as compet It is this apparent inadequate review by operations prior to mode change that is the significant element of the above violation. Inspector review of subsequent mode changes identi-fied no other instances of this natur The inspector witnessed unit startup following refueling and observed and/or reviewed documentation of selected startup tests. The inspector verified that the startup was performed in accordance with technically adequate and approved procedures which had been revised to reflect changes made to the facility and to the startup test program, and that startup activities were conducted in accordance with TS requirement The inspector verified - that surveillance test required to be performed before the startup were satis-factorily ~ complete The following startup activities were observed or reviewe Activity Controlling Procedur Initial Criticality Reactor Engineering Procedure (REP) 107.003 Moderator Temperature- . STP 210.002 Coefficient-Measurement Control Rod. Worth' REP 103.001

' Measurement

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Boron Endpoint REP 107.008 Measurement RCCA Rod Drop Time STP 208.001 Measurement No violations or deviations were identified during the initial criticality and startup testing phase of this inspection. Criticality was achieved at 8:46 p.m., on December 18, 198 . Followup of Events at Operating Reactors (93702)

On December 18, 1984, the unit was brought critical following an extended refueling outage which began on September 28, 198 At 10:55 a.m., on December. 27, 1984, with the unit at 75% power, the unit experienced a reactor -trip from a low steam generator level signal coin-cident with a steam flow greater than feedwater flow mismatch. The trip occurred when a technician, installing test equipment for performance of a load rejection test, inadvertently caused the steam generator programmed level control signal to generate a false low level demand. This false low level control signal caused the closure of feedwater regulating valves resulting in the reduction of feedwater flow. Prior to the test equipment installation, nuclear power range channel, N-42, had been placed in test for calibration, requiring the tripping of the associated low steam generator level bistables. The unit was successfully restarted at 2:50 p.m. , on December 27, 198 . Independent Inspection Effort (92706) First Refueling License Conditions and Commitments As previously reported in IE Reports 84-30 and 84-34, the inspector is ~

reviewing the licensee's implementation of first refueling license conditions and commitments and will report the results of this con-tinuing review in~ subsequent reports.

During this inspection period, the inspector reviewed meeting minutes from a Plant Safety Review Committee (PSRC) meeting held on December'6, 1984, at which the status of these license conditions and commitments were reviewed in preparation for unit restart. The PSRC review deter-mined that the first refueling license conditions and other commitments to be accomplished during this outage had been satisfie Facility license conditions 2C(23a) required that prior to startup after the first refueling outage, the licensee implement emergency operating procedures based on guidelines approved by the NRC. Prior to startup from this first refueling outage new emergency operating procedures (EOPs) based on Westinghouse Owner's . Group Emergency

Response Guidelines, revision 1, were implemented. As identified in

the licensee's response to NRC Generic Letter 82-33, E0P Generation .

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-Package, the licensee conducted training on these new E0Ps prior to implementation. The inspector reviewed this operator training and observed two days of one of the four day training courses. The train-ing was conducted in two phases, a classroom phase and a simulator phase. During the classroom phase, the background and purpose of the E0Ps was presented followed by a step-by-step review of each E0P. The simulator portion was conducted on the licensee's plant specific simulator and presented the students with' a series of scenarios designed to ' allow practice using the new E0Ps. This training was

. presented to each shift during it's normal training week such that each shift was trained as a team. Prior to unit restart, all licensed operators assigned to shift duties had received this training. The inspector will review other portions of the licensee's program for generating these new E0Ps during subsequent inspection Training of Operators on Plant Modifications During this refueling outage, a significant number of plant modifica-tions were implemented. To familiarize plant operators with the most pertinent of these changes, the Operations Department conducted train-ing on .these modifications prior to unit restart. The inspector attended one of these training sessions and found the content and method of instruction adequate to familiarize operators with these

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change Subsequent discussions with Training Department personnel determined that training on these pertinent modifications will also be included in the Operator Requalification Trainin No violations or deviations were identified in this are