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Insp Rept 50-395/85-21 on 850501-31.Violations Noted:Failure to Implement Requirement to Accurately Measure Record & Apply Necessary Correction Factor for Electrolyte Level & Failure to Classify Notifications for Event
	ML20128L026
Person / Time
Site:	Summer
Issue date:	06/12/1985
From:	Cantrell C, Hehl C; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	;
Shared Package
ML20128K994	List: ML20128K989; ML20128L013; ML20128L026;
References
	50-395-85-21, NUDOCS 8507110200
	Download: ML20128L026 (11)
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UNITED STATES

[p Lt;og ^ NUCLEAR REGULATORY COMMISSION

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REGION It

h 101 MARIETTd STREET, N.W.

c ATLANTA, GEORGI A 30323

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Report No.: 50-395/85-21

Licensee: South Carolina Electric and Gas Company

Columbia, SC 29218

Docket No.: 50-395 License No.: NPF-12

Facility Name: V. C. Summer

Inspection' Conducted: May 1-31, 1985

Inspector: %S _ /dNS

C. W. Hehl V y Datie Signed

Approved by: ef4D A M

F. S. Cantrell, SecLtp' fKhief

/M D

Date Signed

Division of Reactor Projects

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SUMMARY

Scope: This routine, unannounced inspection entailed 166 inspector hours onsite

in the areas of plant tours; operational safety verifications; monthly surveil-

lance observations; monthly maintenance observations; followup on written reports

of non-routine events; licensee action on previous enforcement items; and

followup on operating reactor events.

Results: Two violations were identified - failure to implement the requirement

to accurately measure and record and apply the necessary correction factor for

electrolyte level during a monthly battery inspection; failure to promptly

classify and initiate required notifications for an event requiring declaration

of Notification of Unusual Event.

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

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

S. Hunt, Assistant Manager, Surveillance Systems

H. Sefick, Associate Manager, Station Security

D. Nauman, Director, Nuclear Services

M. Blue, Engineer, Nuclear Licensing

M. Irwin, Nuclear Licensing Technician

J. Connelly, Deputy Director, Operations and Maintenance

D. Lavigne, Manager, Quality Control

R. Campbell, Engineer, ISEG

F. Zander, Manager, Nuclear Technical Education and Training

G. Putt, Manager, Scheduling and Materials

C. McKinney, Regulatory Compliance

R. Fowlkes, Regulatory Compliance

D. Fleming, Regulatory Compliance

Other licensee employees contacted included engineers, technicians,

operators, mechanics, security force members, and office personnel.

Other Organizations

Attended exit interview

2. Exit Interview (30703)

The inspection scope and findings were summarized on May 31, 1985, with

those persons indicated in paragraph I above. The inspector described the

areas inspected and discussed in detail the inspection findings. Two

violations were identified:

Violation 395/85-21-01: Failure to implement the requirements of

Electrical Maintenance 115.011 during performance of the monthly

battery inspection.

Violation 395/85-21-02: Failure to implement the requirements of the

facility Radiation Emergency Plan in a timely manner following the

identification of an event requiring the declaration of Notification of

Unusual Event.

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During this inspection, the licensee did not identify as proprietary any of

the materials provided to or reviewed by the inspector.

3. Licensee Action on Previous Enforcement Items (92702)

(Closed) - Violation (VIO) 84-11-02, Failure to Follow Procedures. This

violation resulted from personnel errors which caused an apparent loss of

operating shift awareness of safety system status. The inspector reviewed

licensee documentation regarding implementation of corrective actions

delineated in their response to the violation. The inspector was satisfied

that the corrective actions had been implemented.

(Closed) - VIO 84-27-01, Failure to Comply with Dress Requirements of RWP.

This violation occurred when a worker disregarded the requirements of the

RWP by not wearing a surgeon's cap during performance of decontamination

activities. The inspector reviewed the licensee's corrective action

commitments and determined that this corrective action was adequate and had

been properly implemented.

(Closed) - VIO 84-25-02, Failure to Perform 10 CFR 50.59 Review of Drag Test

Procedure. In inspector reviewed implementation of the licensee's

corrective action commitments. These commitments were found to be accept-

ably implemented.

(Closed) - VIO 84-25-03, Failure to Perform Calibration of Load Cell. The

inspector reviewed implementation of the licensee's corrective action

commitments. These commitments were found to be acceptably implemented.

(0 pen) - VIO 84-25-04, Failure to Have a Qualified Crane Operator During Use

of Spent Fuel Bridge Crane. In their response to this violation, dated

November 2,1984, the licensee committed to upgrading and tracking of the

crane operator training programs. This corrective action was to be

completed by January 31, 1985.

Inspector review of implementation of this commitment determined that

upgrading of the crane operator training program had occurred and that this

upgraded program was utilized to train the first group of crane operator

requiring training after January 31, 1985. This first group of crane

operators to train under the upgraded program received their training

beginning February 20, 1985. Nuclear Education and Training (NE&T) Group

Manual,Section III.B.I.1, Rigging and Crane / Hoist Operator Training, is the

procedure governing conduct of this training. Inspector review of this

procedure determined that it appeared adequate to control the training

addressed. Additionally, it was determined that although implemented on

February 20, 1985, it had not been formally reviewed and approved until

May 1, 1985. The companion training program manual, Rigger, and Crane and

Hoist Operator Qualification Manual, which implements the training program

described in the NE&T Section III.B.1.1, likewise was implemented for the

February 20, 1985 training, but as of the date of this review, May 28, 1985,

had not received formal review and approval.

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10 CFR 50, Appendix B Criteria VI, requires that measures be established to

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control the issuance of documents such 'as instructions and procedures,

including changes thereto, which prescribe activities affecting quality.

ANSI N18.7, 1976, paragraph 5.2.15, states that the administrative controls

and quality assurance program shall provide measures to contrcl and

coordinate the approval and issuance of documents, including ch2nges

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thereto, which prescribe all activities affecting quality and that these

measures shall assure that documents, including revisions and changes, are

reviewed and approved. Paragraph 5.2.15 also states that ecch procedure

shall be reviewed and approved prior to initial use.

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The V.C. Summer Operational Quality Assurance Plan, Section 5.0, Document

Control, implements the requirements of 10 CFR 50, Appendix B, and ANSI

N18.7, 1976, by specifying that organizational procedures be established to

control the review, approval and release for issuance and implementation of

the documents for which it is respons'.ble.

The Nuclear Education and Training Group Manual,Section I.B.16, Training

Manual Revelopment, implements the above requirements by deiineating a

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controlled process for preparation, review and comment, approval, control

and distribution of changes to that manual. As described in this section,

, implementation of manual changes follows review and approval.

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Therefore the implementation of the aforementioned Section III.b.1.1 of the

< Nuclear Education and Training Manual and its associated Qualification

Manual prior to review and approval was nce' in compliance with the above

requirements. Subsequent discussions with the licensee has determined that

i these apparent noncompliancesjuere previously identified by onsite QA during

a surveillance verification of th#s corrective action commitment for

4 violation 84-25-04. The inspector reviewed documentation of this QA audit,

findings and associated correspondence, QA Type II Surveillance

rf '$ Audit II-16-84-C. The inspector's review determined that the licensee's QA

organization had previcurly identified these noncompliances and are

presently working to obtain a satisfactory resolution. Therefore, as is the

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NRC practice, no violation will be issued for these noncompliances.

b Inspector review of the 7,1censee's commitment with regard to tracking of

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crane operator quaiifications determined that a computer based tracking

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system was in place to accomplish this function. .but due to some errors

introduced during the input of data, this tracking system did not at the

time of this inspection accurately reflect individual crane operator

, t qualification. As a result of this finding, the inspector made a spot check

>;' of personnel presently performing crane operations against the hard copy

- record of their qualification. No deficiencies were identified. Discus-

sions with training management determined that the apparent inaccuracy of

the computer tracking system had been previously identified by the Training'

Department and corrective action was in progress. The licensee committed

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resolving these tracking system deficiencies and verifying its accuracy by

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May 31, 1985.

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This item, VIO 84-25-04, will remain open pending followup on the tracking

system corrective action identified above, and inspector review of the

properly reviewed and approved Rigger, Crane and Hoist Operator Qualifi-

cation Manual.

4. Operational Safety Verification (71707, 71710)

The inspector observed control room operations, reviewed applicable logs and

conducted discussions with control room operators during the report period.

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 components. 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

that maintenance 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. No violations or deviations were identified in this

area.

5. Surveillance Observation (61726)

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

that selected surveillances of safety-related systems or components was

conducted in accordance with adequate procedures, test instrumentation was

calibrated, limiting conditions for operation were met, removal and

restoration of the affected components were accomplished, test results met

requirements and were 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

personnel. No violations or deviations were identified in this area.

6. 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

considered 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

to service; quality control record were maintained; activities were

accomplished by qualified personnel; parts and materials used were properly

certified; and radiological controls were implemented as required. Mainte-

nance 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.

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On May 3, 1985, the inspector observed Electrical Maintenance personnel

performing a monthly preventative maintenance inspection on station safety

related battery XBA-1A and a daily preventative maintenance on station

safety related battery XBA-18.

The governing procedure for performance of these preventative maintenance

inspections is Electrical Maintenance Procedure (EMP) 115.011, Battery

Inspection. The procedure in use on May 3,1985 was EMP 115.011, Revision

4, issued March 26, 1985. EMP 115.011, step 7.2, requires, as part of the

monthly inspection, that the electrolyte level below the full mark be

measured and recorded for each cell. EMP 115.011, step 7.2.3, requires that

the level correction factor be determined for each cell and the specific

gravity measurement be adjusted to obtain the corrected specific gravity.

Attachment 10.1 to EMP 115.011 specifies that a correction of 0.00375 be

subtracted from the specific gravity measurement for every one-eighth inch

of level below full.

Inspector review of the data taken during the May 3,1985 performance of

EMP 115.011 determined that the electrolyte level of each cell had not been

accurately measured and recorded in that the data sheet failed to identify

that the cells listed below had electrolyte levels below full.

Cell Electrolyte Level (inches below full)

3 -1/8

4 -1/8

10 -3/8

31 -1/4

47 -3/16

50 -1/4

The corrected specific gravity readings recorded on the EMP 115.011 data

sheet did not correct for these deviations from full.

Technical Specification 6.8.1.a. requires that the applicable procedures

recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, February

1978 be established, implemented and maintained. Appendix "A" of Regulatory

Guide 1.33 recommends procedures for performing maintenance. EMP 115.011

implements this requirement for the periodic preventative maintenance

inspection of the station batteries. The above noted failure to accurately

measure and record the individual cell levels and apply the required level

correction factors to obtain the corrected specific gravity for the above

cells is a failure to adequately implement EMP 115.011. This failure to

adequately implement EMP 115.011 is a violation (85-21-01).

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-7. On Site Followup of Written Reports of Non-routine Events (92700)

The inspector reviewed the following Licensee Event Reports (LERs) to

ascertain whether the Licensee's review,~ _ corrective action, and report of

the identified event and associated conditions were adequate and in

conformance with regulatory requirements, Technical Specifications, license

conditions, and licensee procedures and controls.

-(Closed) LER 84-022, Failure to Maintain Required Boration Flow Path.

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(Closed) LER 84-021, Degraded Kaowool Fire Wrap.

(Closed) LER 83-144, Erratic Behavior of Powe- Ranga Nuclear Instrument.

(Closed) LER 84-050, Actuation of RPS With Plant in Mode 3 Due to Personnel

Error. ;

(Closed) LER 85-005, Reactor Trip Resulting From MSIV Closure Caused by

Faulty Test Switch.

(Closed) LER 85-003, Reactor Trip on High Flux Positive Rate. This LER

reported the February 28, 1985 startup during which a reactor trip occurred

on high flux positive rate trip. The inspector reviewed and verified

implementation of the corrective action identified in the LER. The results

of this review were satisfactory.

(Closed) LER 83-136, Isolation of RHR System While in Mode 5. This event

resulted in a licensee commitment to generate APN power distribution lists

to enhance operator anticipation of plant instrumentation responses during

transients where power is lost to or removed from vital instrument power *

supply panels. Inspector review determined that the committed to APN feeder

lists had been generated.

(Closed) LER 85-001, Rod Control System Failure.

8. Onsite Followup of Operating Events

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a. At 5:20 a.m. on May 9, 1985, in accordance with the facility Radiation

Emergency Plan, a Notification of Unusual Event (N.U.E.) was declared.

The condition resulting in the N.U.E. was the simultaneous inopera-

. bility of both emergency diesel generators (DG) for a period of greater

than one hour. The Unit was in Mode 3 (Hot Standby) at the time of

this event. At 1:30 p.m. on May 9,1985, the necessary repairs and

testing to return DG "A" to operability were completed and the N.U.E.

was terminated. Preceding this event, the plant had been shutdown for

a preplanned maintenance outage which began on April 29, 1985. On

May 1,1985, at the time the DG's were declared inoperable, the unit

was c' a heatup to rated temperature and pressure in anticipation of a

reacter startup and return to power.

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At 7:30 p.m. on May 8, 1985, during routine surveillance testing of DG

"A", in accordance with Surveillance Test Procedure (STP) 125.002, the

automatic voltage regulator failed. During surveillance testing, the

DG started satisfactorily and achieved the desired voltage and

frequency within the required 10 seconds. During the subsequent

attempt to synchronize with the off site grid, the control room

operator determined that remote automatic voltr.ge control was not

functioning properly.

Local control of the automatic voltage regulator was attempted, but was

likewise unsuccessful. DG "A" was shutdown and subsequently declared

inoperable.

The automatic voltage regulator (AVR) circuitry is locked into a preset

position during operation of the DG in response to an Engineered

Safeguard Feature (ESF) signal. Following each shutdown of the DG, the

AVR returns to this preset position such that on a subsequent restart

of the DG, it will achieve the require voltage to satisfactorily power

its associated ESF equipment. The manual voltage regulator was

unaffected by the above failure of the automatic circuitry.

With one DG inoperable, Technical Specification (TS) 3.8.11 requires

that the other DG be demonstrated operable within one hour. At

7:50 p.m. on May 8,1985, DG "B" was started and proper voltage and

frequency were obtained within the required 10 seconds. As usual for

the starting of large pieces of equipment at V.C. Summer, a local

operator was positioned in the DG room to record locally available data

and to monitor equipment performance. Discussions with licensee

personnel determined that just prior to securing the DG following the

successful operability start, the operator reported hearing a loud

bang. Upon investigation, the local operator found water on the side

of the DG in the vicinity of cylinder no. 1. The DG was immediately

shutdown and declared inoperable. Initial licensee investigation into

the DG "B" failure found several ounces of water in the no. 1 cylinder.

No water was found in the remaining other eleven cylinders.

Following unsuccessful initial attempts to return either DG to operable

status, at 5:20 a.m. on May 9,1985, the licensee declared the N.U.E.

The NRC Emergency Operations Center was notified of the N.U.E. at

5:45 am on May 9, 1985.

Subsequent troubleshooting of the DG "A" determined that the AVR

potentiometer had mechanically " frozen" in position near one end of its

travel causing diodes controlling the potentiometer drive motor and the

drive motor to fail. A replacement AVR was obtained from the licensee

warehouse and installed, but this AVR was found to have a defective

drive motor. With no other AVR's available on-site or readily

obtainable from the vendor, the AVR from DG "B" was removed and

installed in DG "A". Following successful post-maintenance test and

the performance of a successful STP operability test, at 1:30 p.m. on

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May 9, 1985, DG "A" was declared operable and the N.U.E. was

terminated.

In accordance with vendor recommendations, the no. I cylinder liner,

cooling jacket, cylinder head and injector were removed from DG "B" and

subjected to hydrostatic testing to identify the source of the water in

leakage. Hydrostatic testing of these components determined that the

fuel injector cooling jacket had developed a cooling water leak near

the tip of the injector which projects into the cylinder through the

head. This injector had been installed approximately a week prior to

its failure during a scheduled 18 month inspection of DG "B", which

included replacement of all injectors. Following this 18 month

inspection, DG "B" had successfully completed the full load 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months run

described in TS 4.8.1.1.2.d.7. The failed injector was "new" at the

time of installation. At the time of this event, pre-installation

hydrostatic testing of injectors was not a vendor recommended action

nor an action required by the licensee's procedures. The licensee is

adding to their procedures a requirement to hydrostatically test each

injector prior installation.

Prior to reassembly of DG "B", the no. I cylinder liner and head were

subjected to liquid penetrant examination; the cylinder cooling water

jacket, head cooling jacket and replacement fuel injector were

hydrostatically tested; the no. 1 piston examined and piston rings

replaced. No damage to these components was identified.

Following reassembly of DG "B", a vendor recommended "run-in" of the

diesel was performed and a successful STP operability test was

performed. At 3:30 p.m. on May 11, 1985, DG "B" was declared operable.

During this event, the inspector monitored and observed the licensee's

troubleshooting and maintenance activities. These activities were

conducted in accordance with properly reviewed and approved procedure

and performed by qualified individuals. No deficiencies were observed

during these activities. As a result of this occurrence, a special

inspection was conducted by a team of Region II inspectors. The scope

and results of this inspection are presented in IE Report 395/85-24.

The facility Radiation Emergency Plan, (REP), Table 4-1, identifies

Emergency Action Levels (EALs) which are used to describe each of the

four emergency classes. These EALs are composed of plant parameters

(such as system status) that can be used to give relatively quick

indication to the operating staff of the severity of a situation. The

purpose of the EALs is to provide the earliest possible notification of

actual or potential accident situations. REP, Table 4-1, Item 8,

identifies "Both Diesel Generators In Operable for 1 1 hr" as a

detection method for an EAL associated with the N.U.E.

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Station Administrative Procedure (SAP) 200, Conduct of Operations,

requires that -the Shift Supervisors implement established procedures

for normal operations and emergency conditions. The REP further

clarifies these responsibilities in that the Shift Supervisor, as the

Interim Emergency Director, is responsible for classifying the

emergency and notifying offsite organizations and agencies.

As identified above, by approximately 7:50 p.m. on May 8,1985, both

emergency diesel generators had been declared inoperable, therefore, at

approximately 8:50 p.m. on May 8,1985, the EAL identified in the REP

for declaration of N.V.E. existed. This declaration of N.U.E. did not

take place and notifications to offsite organizations and agencies did

not take place until nearly 9 hours1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months later. This is clearly a failure

to adequately implement the intent of the REP to, in a timely manner,

classify the occurrence and initiate required notifications.

TS 6.8.1 requires that Emergency Plan Procedures be established,

implemented and maintained. The facility REP was established to meet

this requirement. The above noted failure to adequately implement the

requirements of the REP is a violation (85-21-02).

b. At 4:08 p.m. on May 11, 1985, following restoration of the DG as

described above, a reactor startup was initiated in preparation for

returning the unit to power operations. As required by General

Operating Procedure (GOP)-3, at 5:00 p.m. on May 11, 1985, the reactor

was shutdown by emergency boration and inserting control rods following

criticality at a control rod height (control rod bank C at 69 steps)

below the required Rod Insertion limit (control rod bank C at 118

steps) for the existing plant conditions. The estimated critical rod

position calculation performed for this startup had predicted

criticality at a rod height of 65 steps on control rod bank D.

Initial review of this startup by the licensee and Westinghouse did not

resolve the apparent discrepancy between the actual and predicted

critical rod height. As result of this initial review, Westinghouse

recommended that a subsequent restart of the unit proceed utilizing the

known critical condition data from the aborted startup and compensating

with boron to achieve the desired rod height for criticality.

Following Plant Safety Review Committee concurrence with this

Westinghouse recommendation, a successful startup was performed and

criticality achieved at 3:55 a.m. on May 12, 1985.

On May 13, 1985, a special NRC inspection of this event was initiated,

the results of which are presented in IE Report 395/85-27.

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9. In-Office Review

The following items were evaluated by the Reactor Safety, Radiation Safety

and Safeguards, and Reactor Projects Regional staff. Based on this review

and the results of the . latest Resident and Region based inspection

activities in the affected functional areas, . the following items were

determined to require no additional specific followup and are closed.

a. Inspector Followup Items (IFI):

(82-23-01) Complete Discrepancy Items Noted in TE-1, Rev. 2

(82-04-09) Revise Liquid Scintillation Procedure for H-3 Counting

b. Part 21 Report:

(P21 82-01) Electrical Control Panels

c. Unresolved Items (URI):

(82-13-01) Installation of Locking Devices

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ML20128L026

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