ML20128K519

Insp Rept 50-395/85-22 on 850513-17.Violation Noted: Inadequate Review of Surveillance Test Procedures for RCS Leak Test

ML20128K519
Person / Time
Site:	Summer
Issue date:	05/31/1985
From:	Blake J, Girard E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20128K510	List: ML20128K505 ML20128K512 ML20128K519
References
50-395-85-22, NUDOCS 8507100606
Download: ML20128K519 (8)

See also: IR 05000395/1985022

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) . UNITED STATES

[eEto 4- NUCLEAR REGULATORY COMMISSION

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REGION 11

,101 MARIETTA STREET, N.W.

• t ~ ATLANTA. GEORGI A 30323

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' Report No.:/ 50-395/85-22

Licensee: South Carolina Electric and Gas Company

Columbia, SC 29218

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

Facility Name: Summer

Inspection Conducted: May 13-17, 1985

Inspector: . I

E. H. Gi ar Sate Signed

1 Approved b .

J Blale, Section Chief

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Date Signed

neering Branch

ision of Reactor Safety

Sut9tARY

Scope: This routine, unannounced inspection entailed 34 inspector-hours on site

in the areas of licensee action on previous enforcement matters, steam generator.

tube leakage, Inspection and Enforcement Bulletin 83-03, and inspector followup

items.

Results: One violation was identified - Inadequate review of surveillance test

procedures, paragraph 3.a.

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

• J. G. Connelly, Deputy Director, Operations and Maintenance

• A. R. Koon, Associate Manager, Regulatory Compliance

F. A. Miller, Associate Manager, Quality Control Systems

• A. D. Torres, NDE (Nondestructive Examination) Supervisor

D. R. Moore, Group Manager, Quality Services

• F. J. Leach, Manager, Quality Assurance (QA)

• B. G. Croley, Group Manager, Technial and Support Services

• K. W. Woodward, Manager, Operations

• G. G. Putt, Manager, Scheduling and Material Management

J. W. Turkett, Engineer, Maintenance Engineering and Support

• M. D. Quinton, Manager, Maintenance Services

L. B. Collier, Welding Supervisor

R. J. Bouknight, Technical Specialist, Regulatory Compliance

• C J. McKinney, Technical Specialist, Regulatory Compliance

M. D. Irwin, Nuclear Licensing Specialist

• F. Zander, Manager, Nuclear Technical Training

• J. F. Helman, Associate Manager, Nuclear Operations Education and Training

M. Williams, Manager, Nuclear Operations Education and Training

• M. D. Blue, Nuclear Licensing Engineer

NRC Resident Inspector

• C. W. Hehl, Senior Resident Inspector

• Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized on May 17, 1985, with

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

areas inspected and discussed in detail the inspection findings. No

dissenting comments were received from the licensee. The following new

items were identified during this inspection:

a. Violation 395/85-22-01: Inadequate Review of Surveillance Test

Procedures, paragraph 3.a.

b. Unresolved Item 395/85-22-02: Training for Visual Examinations,

paragraph 3.b.

The licensee did not identify as proprietary any of the material provided to

or reviewed by the inspector during this inspection.

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c 3. Licensee Action on Previous Enforcement Matters

(Closed) Unresolved Item (395/85-10-02): Leakage Test Boundary. This item

was opened to address the NRC inspector's finding that the test boundary

identified in the licensee's procedure for leak testing the reactor coolant

pressure boundary (procedure STP 150.001, Rev. 2) appeared inaccurate. The

requirements for the test stem from Technical Specification (TS) 4.0.5 which

specifies inservice inspection requirements in accordance with ASME

Section XI and applicable addenda (hereafter referred to as the Code)

identified through 10 CFR 50.55a(g). In accordance with 10 CFR 50.55a(g),

the Edition and Addenda of ASME Section XI (the Code) applicable to the

Summer plant is the 1977 Edition with Addenda through Summer 1978 (77578).

The Code requires that all ASME Class 1 pressure retaining components be

visually examined for leakage each refueling outage.

During the current NRC inspection the inspector continued his examination of

the licensee's compliance with reactor coolant pressure boundary leakage

test requirements. In his examination he specifically addressed the

adequacy of the procedure, and the training and qualification of personnel

for performance of the test. These were examined for compliance with Code

and other regulatory requirements. The inspector's findings are described

below,

a. Procedure

The inspector found that the licensee's procedure for performing leak

testing of the reactor coolant pressure boundary components was

inadequate relative to the following:

(1) The outer test boundary for the test as specified in the Summer

1978 Addenda of the Code and clarified in 1980 Edition includes

the entire pressure retaining boundary and extends to the second

of two closed valves. The licensee improperly identified the test

boundary as the first closed valve. This omitted piping and

i valves beyond the first closed valve. For example, valves 8701A

and B and the piping between them and valves 8702A and B

respectively, were omitted from testing by the procedure. It also

omitted as boundaries the flow restrictors in many small diameter

lines - for example, the flow restrictor in the 3/4-inch line at

the Class 1 to Class 2A boundary at location A-15 on drawing

E-302-691.

(2) The examination required by the procedure is extensive. It

addresses all ASME Class 1 components. There are many components

and locations to be examined for leakage-in affect, many

individual examinations. The procedure does not provide a means

to assure that examination points are not inadvertently bypassed.

It does not identify the individual examination points and does

not provide for sign-offs to verify individual examinations or

< groupings of examinations related by close proximity.

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(3) The procedure uses "should" where "shall" is appropriate for

specifying certain requirements. For example, section 2.1 of the

procedure states "all requirements for the radiation work permit

should be adhered to".

(4) The acceptance criteria specified by the procedure . revision

originally questioned (150.001, Rev. 2) are not fully correct. As

stated in Attachment 1 to the procedure, the acceptance criteria

are (a) no observable weld leakage and (b) all other leakage as

low as practical. The licensee revised the acceptance criteria in

a revision to the procedure prepared before but issued after the

inspector questioned the boundary identified in the procedure.

The revised acceptance criteria (revision 3 to the procedure)

states as acceptance criteria that (1) there shall be no

observable weld leakage and (2) all other leakage is to be within

the bounds given in procedure GTP-304 for the appropriate sized

piping.or valves. The criteria in both revisions are unsatis-

factory in that they are inconsistent with the requirements of TS 3.4.6.2.a and d which permit no presssure boundary leakage and a

limit of 10 gpm (gallons per minute) of identified leakage.

(5) The procedure does not provide procedural steps for verification

of the operability of leakage detection systems as required by

IWA-5243 of the Code.

(6) The procedure requires entry into areas that may result in

significant radiation exposure to individuals performing the

prescribed examinations. Detailed information regarding locations

to be inspected for leakage and how they may be most readily

accessed are needed to aid in assuring that proper locations are

examined and that time is not spent by individuals unnecessarily

making decisions under conditions of radiation exposure.

Procedure 150.001 does not provide or reference such detailed

information, or require review of such information before entry

into radiation areas.

(7) Valve manipulations are required by the procedure. However, it

provides no identification or verifications for the valve

manipulations. Note: . It is the inspector's understanding that

the licensee identified this procedural problem following the

inspector's questioning the valve test boundary. The inspector

was shown a proposed procedure revision that included changes to

the test boundary valves and that added valve alignment verifi-

cations.

In addition to procedural deficiencies described above, the inspector

identified a procedural deficiency in another licensee surveillance

test procedure, as described in paragraph 6 below. These deficiencies

constitute noncompliance with procedural review requirements of

TS 6.5.3.1.a. This noncompliance is identified as Violation

395/85-22-01, Inadequate Review of Surveillance Test Procedures.

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b. Training and Qualification of Personnel

The NRC inspector examined the licensee's training and qualification of

l personnel who perform inspections (actually visual examinations) in

accordance with procedure STP 150.001. Information for the NRC

inspector's examination of this area was obtained through discussions

with cognizant licensee personnel and review of the following related

procedures and records:

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Nuclear Operations Training Instruction NTCI-18, Rev.1; Visual

~ Inspector (VT-2)-Qualification Program

- -Nuclear Quality Control Procedure (NQCP) A-NQCP-8, Rev. 2;

Qualification and Certification of Nuclear Quality Control

Inspection Personnel

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Quality Assurance Audit Finding No. II-24-83-D-03, dated 11/21/83

- 8/27/84 letter from (QA) Services to Operations stating verifi-

cation of implementation of an acceptable visual examination

training program and on that basis closing Audit Finding No.

II-24-83-D-03

- Certification records for individuals qualified to perform

inspections in accordance with STP 150.001. (Three of the

individuals certifcations were reviewed in detail).

In discusions with cognizant personnel the NRC inspector was informed

that qualification and. training of personnel for the subject surveil-

lance test- procedure had been originally performed by the licensee's

Quality Control Systems organization, then later by the Operations

organization, and, finally, it had been assigned to the Nuclear

Operations-Education and Training organization. In the course of his

examination the inspector - found that licensee QA personnel were

auditing training, and in discussions with the auditors he was informed

that there had been a previous relavent audit finding. The finding

(referenced above) which was identified in 1983, indicated that

Operations (then responsible for the training and qualification) did

not.have a formal program for qualification of pesonnel to perform VT-2

examinations. VT-2 examinations are the Code defined examinations

utilized in performance of inspections such as those addressed in -

procedure STP 150.001. The audit finding also noted that four of 14

individuals whose records were checked did not have complete

certification records. It is the inspector's understanding that it was

as a consequence of this finding that the responsibility for training

and qualification of personnel for VT-2 examinations (and also for Code

required VT-4 examinations) was transferred to the Nuclear Operations

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ud Training organization. The NRC inspector's findings, from his

examinction of the area, indicate that the licensee's current training

progra:n may continue to be inadequate. Concerns identified by the

inspector relative to the program were as follows:

(1) Procedure NTCI-18 requires that Nuclear Operations Education and

Training (NDET) retains all applicable records for individuals'

certification for VT-2 examinations (as required by the Code).

The inspector found that the licensee had not identified what

records were required or where they were to be kept (specific

file). The content of individual's qualfication files that were

provided to the inspector for review was inconsistent. Certifi-

cation tests were included for some individuals and not for

others, experience information was not included and distant vision

test results and experience data required by the Code were not

included.

(2) Qualification requirements for the instructor were not identified

and the inspector was informed that the instructor had no

certification indicating his qualifications as a VT-2 instructor.

(3) Set-up requirements for practical testing were not described. No

basis for evaluation or grading of the practical test was

indicated.

(4) It was not clear who would be responsible for evaluating the

results of annual eye tests and assuring implementation of any

restrictions resulting therefrom.

(5) It was not clear who develops and approves the test questions for

qualification tests - it appeared to be the responsibility of the

VT-2 Level III examiner in the Nuclear Quality Control organization.

(6) No time limit was given on the period allowed between the

completion of qualification tests and the start of certification.

The inspector noted instances in which a period of over five

months elapsed before certification. This could allow excessive

time to pass before periodic re-evaluation and re-certification of

individuals.

(7) Directly related to (5) above and indirectly related to other

items, it was not clear what the Level III examiner's responsi-

bilities were relative to assurance of the maintenance of

proficiency of personnel, determining (and approving) the adequacy

of visual examination procedures (such as STP 150.001),

determining the need for additional training, assuring the proper

presentation of training, etc.

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The inspector informed the licensee management personnel having

responsibility for the visual examination training and for performance

of the related examinations of his concern that the training program

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appeared inadequate. The licensee was informed that the matter would

be examined more extensively to determine its significance during a

subsequent NRC inspection and it was identified as Unresolved Item

395/85-22-02, Training for Visual Examinations.

4. Unresolved Items

Unresolved items are matters about which more information is required to

determine whether they are acceptable or may involve violations or

deviations. A new unresolved item identified during this inspection is

discussed in paragraph 3.b.

5. Steam Generator Tube Leakage (92706)

TPe inspector questioned the cognizant licensee supervisor as to what

problems they had encountered with operationally-induced tube leaks and what

actions they were undertaking to avoid development of further tube leaks.

The inspector was informed that they had experienced leakage in several

tubes in row 1 of steam generator (SG) B. The leaks were all in the U-bends

of the tubes. They appreared to be the result of stress corrosion cracking

induced from the primary (reactor coolant) side of the tubes. The main

factors believed involved are the temperatures, tube material, and the

residual bending stresses in the tubes in the U-bend areas. It may be

possible to prevent the cracking by thermally stress relieving the U-bend

areas. The license has plugged all row 1 SG B tubes in expectation that

this may prevent further cracking in the row 1 tubes.

If a successful method of stress relief is demonstrated they may wish to

relieve the stresses and unplug these tubes to allow them to become

functional again, at some future date. It is not clear why only SG B tubes

have leaked thus far. Row 1 in SGs A and C may be plugged (similar to row 1

in SG B) in a future outage. The inspector was informed that the licensee

is also trying to follow the guidelines developed by the Electric Power

Research Institute for avoidance of tube leakage and that they meet these

guidelines except for problems in transient areas and'for their lack of

capabilities to perform on-line sampling.

6. InspectionandEnforcementBulletins(IEBs)(927038)

(Closed) IEB 83-03: Check Valve Failures in Raw Cooling Water Systems of

Diesel Generators

This IEB deals with generic aspects of multiple swing check valve failures

identified in raw cooling water systems for diesel generators. The

licensee's initial response to this IEB, dated June 8,1983, was reviewed

and determined acceptable by Region II. The licensee had committed to

perfonn tests, to verify the condition of the subject check valves, as

! reg,'ested by the IEB.

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During inspection 395/85-10, conducted March 11-15, 1985, the NRC inspector

found that the licensee had not provided a final report requested by

IEB 83-03. In response to questioning by the inspector, the licensee stated

that this was an oversite and indicated the report would provided. The

report was subsequently provided in a letter to NRC Region II dated

March 21,1985. This response was reviewed and determined acceptable by

Region II.

During inspection 395/83-27, conducted August 1 - September 2, 1983, the NRC

Resident Inspector at the Summer site reviewed the licensee's procedure for

the IEB 83-03 related valve testing. The procedure was STP 123.003, Service

Water System Valve Operability Test. The Resident Inspector reported that

STP 123.003 was unacceptable in that it did not contain acceptance criteria

for the IEB-related test. During the current NRC inspection, the NRC

inspector again reviewed STP 123.003. The inspector fcund that the licensee

had not corrected the procedure and that it still contained no acceptance

criteria for the IEB testing. The licensee's failure to appropriately

review and to correct the procedure is considered an additional example of

Violation 395/85-22-01, described in 3.a. above. IEB 83-03 is considered

closed, additional concerns regarding the licensee's testing in response to

the IEB will be addressed in subsequent NRC inspection of Violation

395/85-22-01.

7. Inspector Followup Item (IFIs) (92701B)

(0 pen) IFI (395/85-10-03): Was Stroke Timing and Position Indicator

Verification Required and Performed?

This item was opened to address the NRC inspector's concern that he would

not determine whether proper testing had been performed on certain valves

after maintenance - testing required to assure their acceptable operation.

During the current inspection the NRC inspector was informed that the

licensee had investigated his concern. The inspector reviewed the results

of the investigation as documented in a Nuclear Operations memorandum

identified CGSS-01-1195-N0, File No. 108.60, dated May 2, 1985. The

investigation concluded that while the valves had been subsequently proven

to function satisfactorily there was no clear documented evidence that the

test had been performed when required, because of the manner in which the

work was documented. As a consequence of their findings the licensee

identified actions (in the referenced memorandum) that would be taken to

better track and document such tests. In response to questioning by the NRC

inspector during the exit meeting, the licensee stated that the actions

could be considered a commitment. The inspector stated that the IFI would

remain open pending NRC verification that the proposed actions were

implemented and were effective.