IR 05000395/1986015

Insp Rept 50-395/86-15 on 860801-31.Violation Noted:Failure to Perform 10CFR50.59 Safety Evaluation Review Prior to Implementing Changes to Plant Operation

ML20214V067
Person / Time
Site:	Summer
Issue date:	09/18/1986
From:	Dance H, Hopkins P, Prevatte R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20214V048	List: IR 05000395/1986015 ML20214V047 ML20214V056
References
50-395-86-15, NUDOCS 8610020127
Download: ML20214V067 (9)

Text

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Report No.: 50-395/86-15 1 Licensee: South Carolina Electric and Gas Company ' Columbia, SC 292.18 Docket No.: 50-395 License No.: NPF-12 Facility Name: V. C. Summer Inspection Conduc ed: August 1-31, 1986 Inspect rs: [/ W / N Richard L. Prevatte, f Ddte Signed W l b Perr C. tiopkins , Dit S'i ned Approved by: 8Nu 11 ugh /C. Dance, Section-Chief 7 8 [[ D/te 61gned Division of Reactor Projects SUMMARY Scope: This routine, announced - inspection was conducted - by the resident inspectors onsite, in the areas of licensee action on previous enforcement matters, onsite followup of events and subsequent written reports, monthly surveillance observations, engineered safety features system walkdown, monthly maintenance observation, operational safety verification, onsite review committee, and other area Results: One violation was identified: Failure to perform a 50.59 review prior to imp.lementing changes to plant operation o 8610020127 860923 PDR ADOCK 00000393 G PDR L

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REPORT DETAILS Persons Contacted Licensee Employees D. Nauman, Vice President, Nuclear Operations 0. Bradham, Director, Nuclear Plant Operations J. Skolds, Deputy Director, Operations and Maintenance G. G. Soult, Manager, Operations M. Browne, Group Manager, Technical and Support Services M. Quinton, Manager, Maintenance Services A. Koon, Manager, Technical Support G. Putt, Manager, Scheduling and Materials Management K. Woodward, Manager, Nuclear Education and Training L. Blue, Manager, Support Services S. Hunt, Manager, Quality Assurance Surveillance Systems W. Higgins, Associate Manager, Regulatory Compliance J. Sefick, Manager, Nuclear Security B. Williams, Supervisor, Operations

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Other licensee employees contacted included engineers, technicians, operators,

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mechanics, security force members, and office personne . Exit Interview (30702, 30703) The inspection scope and. findings were summarized on September 2,1986, with those persons indicated in paragraph 1 above. The inspectors described the areas inspected and discussed the inspection findings. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during the inspection. One violation was identified. The licensee noted that corrective action had been implemented to preclude . recurrence of this violatio . Unresolved Items * See paragraph 11 for the unresolved item discussed in this repor . Licensee Action on Previous Inspection Findings (92701, 92702, 92703)

(Closed) Inspector Followup Item (85-37-02), Parker Hannifin valve inoperable by isolation of its instrument air supply. The inspectors reviewed and verified the associated licensee response and replacement of stainless steel

, valves. This item is closed.

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*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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(Closed) Violation (85-34-01), System alignment errors rendered both RHR trains inoperable with the plant in Mode 3. The licensee provided a written response to this violation in a letter to Region II, dated February'5, 198 The inspector reviewed the licensee's response, and the procedural changes implemented by the licensee to prevent recurrence of this ite These-changes and the additional training and counseling of the operations personnel involved appears to be adequate. This item is close (Closed) Violation (84-29-02), Failure to follow procedures during receipt, inspections and storage of new fuel assemblies. The licensee provided a written response to this violation in a letter to Region II, dated November 16, 198 The inspector reviewed the licensee's response and corrective actions implemented to prevent recurrence of this item. These actions and the additional training conducted appears adequate. This item is close (Closed) Violation (85-23-01), Failure to follow procedure for hanger inspection. The licensee provided a written response to this violation in a letter to Region II, dated July 12, 1985. The inspector reviewed the licensee's response and conducted an inspection of the applicable hanger This inspection revealed that the identified discrepancies had been correcte This item is close (Closed) IE Bulletin 86-09., Static."0" Ring Differential Pressure Switche The licensee provided a written response to this bulletin in a letter to Region II, dated July 25, 1986. The licensee has confirmed that the series 102 and 103 differential pressure switches described in the above bulletin are not used at t eh V. C. Summer Nuclear Station. This item is not applicable and is close (Closed) Violation (85-10-01), Record of test does not include name of data recorder. The licensee provided a written response to this violation in a letter to Region II, dated April 29, 198 The Station Administrative Procedure (SAP) 134 " Control of Station Surveillance Test Activities", has been revised so as to require identification of " Data Recorder" on test procedures. This appears adequate to prevent future occurrences. This item is close (Closed) Inspector Followup Item (85-10-03), Was stroke timing and position indicator verification required and performed. The inspector verified that the Surveillance Test Procedures (STPs) that were used in post maintenance valve stroking and timing were recorded on the STP data sheets. This item is close (Closed) Unresolved Item (83-31-01), Plant operations manual changes do not fully meet the requirements of SAP-13 This item identified that procedural revisions were not indicated by a bar in the right margin to denote applicable changes. The inspector reviewed SAP-139 and verified that this requirement is still contained in that procedur A review of ten operations procedures, revised af ter the above item, indicates that the recuirements of SAP-139 are being followed. This item is close .

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(Closed) Unresolved Item (84-12-01), Slave relay testing determination of testability of actuation on device This item was evaluated by the Office of Nuclear Reactor Regulation (NRR), in a letter to Region II, dated May 15, 1986. It stated that slave relays or actuated components must be tested or continuity checks provided, unless specifically excluded. The inspectors reviewed the licensee's STPs in which appropriate testing and continuity checks are being accomplished. This item is close (Closed) Inspector Followup Item (85-17-01), Failure to evaluate Westing-house data letters to determine if applicable to V. Summe The inspectors reviewed correspondence from Westinghouse that states that data letters are internal documents to provide information and guidance to personnel at assigned facilities, consequently, it is rare that a licensee would have access to data letters. Westinghouse does not normally provide licensees data letters. They are reviewed for applicability for a particular site. 'The licensee evaluates technical bulletins and/or formal letter This item is close (Closed) Licensee Identified Item (80-37-05), inadvertent boron dilutio The licensee provided a written response to the Office of NRR, Washington, dated June 29, 1982. The inspectors reviewed the response to NRR and the FSAR, Section 15.1.4. The action taken by the licensee appears to be adequate. This item is close (Closed) Inspector Followup Item (85-02-02), Cracking of flywheels on Cummings fire pump engines. This item was identified to the licensee in IN 84-9 The flywheel was replaced under MWR 86M0015 on February 14, 198 This item is close (Closed) Inspector Followup Irem (85-02-01), Out of specification chemistry on steam generator due to resin intrusio The inspector reviewed the procedural changes and corrective action was taken to preclude recurrence of
'this item. This review indicates that this item has been satisfactorily resolved. This item is close (Closed) Violation (86-08-02), Failure to have the capability of notifying offsite authorities within fifteen minutes of declaring an emergency. The licensee provided a written response to this violation in a letter to Region II, dated July 7, 198 The inspector reviewed the licensee's response and inspected the new telephone " Ring-down" equipment installed to permit rapid notification of offsite authoritie A review of records shows, that operations personnel have been instructed in the use of the new equipment. This item is closed. Monthly Surveillance Observation (61726)

The inspectors observed surveillance activities of safety related systems and components to ascertain that these activities were conducted in accordance with license requirements. The inspectors observed portions of selected surveillance tests including all aspects of one major surveillance test involving safety related system The inspectors also verified that the

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t t required administrative approvals were obtained prior to initiating the test, that the testing was accomplished by qualified personnel, that required test instrumentation was properly calibrated, that data met Technical Specifications (TS) requirements, that test discrepancies were rectified, and that the systems were properly returned to servic The following specific surveillance activities were observed: STP 391-007 Triaxial Time History Accelerograph Operational Test STP 122-002 Component Cooling Water Pump "C" Test STP 501-005 D.C. Battery Charger Service Test STP 114-002 Operational Leakage Test

STP 114-001 Operational Leakage to Reactor Coolant Pump Seals STP 120-001 Motor Driven Emergency Feedwater Pump Test STP 102-002 NIS Power Range Heat Balance STP 303-011 Steam Generator "A" Steam Pressure Instrument PT 0476

!  Instrument Operational Test STP 301-002 Containment Hydrogen Monitor Operational Test I

No violations or deviations were identifie . Monthly Maintenarce Observation (62703) The inspectors observed maintenance activities of safety related systems and components to ascertain that these activities were conducted in accordance with approved procedures, TS and appropriate industry codes and standards.

! The inspectors also determined that the procedures used were adequate to ' control the activity, and that these activities were accomplished by quali-fied personnel. The inspectors independently verified that equipment was I properly tested before being returned to servic Additionally, the inspectors reviewed several outstanding job orders to determine that the licensee was giving priority to ' safety related maintenance and a backlog . which might affect its performance was not developing on a given system. The l following specific maintenance activities were observed: MWR 860064 Over Speed Tfip Alarm on Diesel Generator "A" MWR 8600802 High Intake Filter Differential Pressure on Diesel l Generator "B" j MWR 86E0120 Repair Emergency Siren Motor MWR 86E0129 Repair of Exciter Voltage Regulator I.

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S l PMTS P0073473 Repair Isophase Bus Duct j , EMP 170.003 Repair Offsite Emergency Siren Motor and Perform Two Year Inspecti'm PMTS P0015482 Clean and Repair Valve Operator Stem MWR 85E0410 Inspect, Repair or Replace Torque Switch EMP 445.002 Limitorque Operator Maintenance MWR 86E0139 Inspection of Limitorque Wiring

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MWR 86E0140

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. MWR 86E0141

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MWR 86E0142

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MWR 86E0143

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MWR 86E0145 No violations or deviations were identifie , 7. Operational Safety Verification (71707) The -in'spectors toured the control room, reviewed plant logs, records and held discussions with plant staff personnel to verify that the plant was being operated safely and in conformance with applicable requirement Specific items inspected in the control room included: adequacy of staffing ' and attentiver.ess of control room personnel; TS and procedural adherence; operability of equipment and indicated control room status; control room ' logs, tagout books, operating orders, jumper / bypass controls; computer printouts and annunciators. Tours of other plant areas were conducted to verify equipment operability; control of ignition sources and combustible materials; the condition of fire detection and extinguishing equipment;

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the control of maintenance and surveillance activities in progress; the ' implementation of radiation protective controls and the physical security pla Tours were conducted during normal and random off hour period On July 18, 1986, during a thunderstorm, the licensee started diesel gener-ator "A", paralleled it with the offsite 115 kV power source, and opened the offsite power feeder breaker to the 7.2 kV safety related bus IDA. This electrical configuration resulted in the standby emergency diesel geners. tors ! providing power to the t' rain "A" safety related buses. These conditions existed for approximately two hours and forty-five minute The inspectors on July 28, 1986, questioned the licensee as to why a decision, , although not prohibited by technical specifications, was made to operate under this plant electrical configuration, while the preferred source of l

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6  : l offsite power was still available and had not been declared inoperable. The licensee stated that due to.two recent events which resulted in power losses of the 115 kV offsite power source, a management decision had been made to transfer bus IDA to the onsite emergency diesel generator, if it was deter-mined that actual or potential electrical storms on the plant vicinity would threaten or possibly degrade this power sourc This decision was implemented in Special Instruction 86-16, which was issued on July 16, 1986. After discussions between the licensee and the senior resident inspector, on July 28, 1986, the licensee cancelled the part of 86-16 which addressed 4 this issue, pending further investigatio Further discussion between the licensee, Region II, and the inspectors on this issue, resulted in the licensee agreeing to address the following NRC concerns associated with the above plant electrical lineup: (1) would the safety related bus strip all non-safety loads on receipt of a safety injection (SI) signal, (2) would the load sequencer function correctly and load all safety loads if a SI should occur under the above conditions, (3) if a SI occurred under these conditions, did the potential exist for overloading the diesel generator, (4) if the diesel generator should trip or become inoperable under these conditions, did procedural steps exist for an orderly return to offsite power and, (5) had a 10 CFR 50.59 review been conducted to. insure that no unreviewed safety questions existed, while operating under the conditions prescribed by Special Instruction 86-1 To answer the above questions and concerns, the licensee agreed to perform a 50.59 review. This review was accomplished by Gilbert Commonwealth, Inc., on August 6, 1986. This review determined that there were safety questions which had not been previously addressed, and that when operating with the emergency diesel generators supplying bus 1DA, under the conditions pre-scribed in Special Instruction 86-16, the diesel could be potentially overloaded ~during accident conditions. The review indicated that under the conditions that existed on July 18, 1986, the diesels would not have been overloade The review showed that if the swing charging / safety injection pump had been aligned to the "A" train and an accident had occurred, the

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diesel could have been overloaded. It was additionally noted, that no procedures exist to verify alignment of swing components before allowing the emergency diesel to be used for the power source to bus IDA and that no specific procedural guidance had been provided to operators' on steps to be taken to transfer the 7.2 kV bus back to the offsite power source if the diesel generator should be los The failure to perform a 50.59 review of this abnormal electrical alignment, prior to operating under the conditions described in Special Instruction 86-16, is contrary to the requirements of 10 CFR 50.5 This is a violation: , Failure to perform a 50.59 review prior to implementing changes to plant l operations (86-16-01).

Other than the above, no other violations or deviations were identified.

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8. ESF System Walkdown (71710) The inspectors verified the operability of an engineered safety features (ESF) system by performing a walkdown of the accessible portions of the charging / safety injection system. The inspectors confirmed that the licensee's system lineup procedures matched plant drawings and the as-built configuration. The inspectors looked for equipment conditions and items that might degrade performance (hangers and supports were operable, house-keeping, etc.) and-inspected the interiors of electrical and instrumentation cabinets for debris, loose material, jumpers, evidence of rodents, etc. The inspectors verified that valves, including instrumentation isolation valves, were in proper position, power was available, and valves were locked as appropriate. The inspectors compared both local and remote position indication No violations or deviations were identifie . Onsite Follewup of Events and Subsequent Written Reports (92700, 93702) The inspectors reviewed the following Licensee Event Reports (LERs) and Special Procedures Reports (SPRs) to ascertain whether the licensee's ' review, corrective action and report of the identified event were in conformance with regulatory requirements, technical specifications, license conditions, and licensee procedures and controls. Based. upon this review the following items are close SPR 85-017 Diesel Generator."A" Failure SPR 86-003 Digital Impact Monitor System Failure SPR 85-020 Inoperable Fire Door LER 85-023 R'esidual Heat Removal System Misalignment LER 85-029 Exceeded Surveillance Interval for Shutdown Margin Calculation LER 85-014 Challenge of Overpressure Protection System, on ESF Bl'ackout Load Sequencer Actuation LER 85-010 Missed QPTR Surveillance, due to Personnel Error, Failing to

Recognize the Requirement ,. SPR 85-009 Diesel Gener* tor Fuel Oil Leak due to Cracked Line LER 85-028 ESF Actuation Attributed to Operations Personnel Error No violations or deviations were identified.

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10. Onsite Review Committee (40700) The inspectors attended the Plant Safety Review Committee (PSRC) meeting,

-on August.5, and August 25, 1986. Items discussed were modification requests, nonconformance notices, off normal occurrence reports, reactor trips, procedure revisions, and the environmental equipment qualification of limitorque motor operated valve wirin . Other Areas Recent equipment qualification inspections, conducted at selected nuclear plants, identified a potential generic problem associated with internal jumper wiring in Limitorque Motor Operated Valves. On August 19, 1986, the inspectors reviewed the documentation of actions taken by the licensee in response to Inspection and Enforcement (IE) Information Notice 86-03, which identified this potential proble This inspection revealed that the licensee had contacted the valve suppliers who provided the limitorque operators and requested documentation to support the qualification of the questionable internal wirin Letters had been received which indicated that the wiring used by their valve suppliers was qualified. .The licensee was additionally developing a program to conduct inspections of the internal wiring as a part of the regularly scheduled maintenance progra On August 22, 1986, Region II notified the licensee of the need to conduct a timely inspection of the above item. The licensee was also informed that if questionable or nonqualified wiring was discovered during this inspection, a letter of justification for continued operation would be require The licensee's review of records revealed that 131 limitorque motor operated valves, requiring equipment qualifications, were installed in the plan Twenty-four are inside containment and one-hundred seven are outside con-tainment. As-to-date, nineteen of these valves have been inspecte Of these nineteen, thirteen were supplied by Westinghouse and six by Balance of Plant (BOP) suppliers. Six of the Westinghouse valves were found to have wiring with questionable qualification Five of these were outside-containment 4and one was-inside containmen The licensee has replaced the questionable wiring in these six valves. The majority of the questionable wiring was labeled KALAS TFF, which the licensee could not identify as qualifie The licensee, on August 25, 1986, received a letter from Westinghouse, stating that they had determined that the TFF wiring was

< qualified for use outside containmen The licensee, on August 25, 1986, submitted a letter to Region II, providing a basis of justification for continued operation until all limitorque wiring could be inspected and repaired as require Region II is currently reviewing this correspondence. The' inspectors will continue to follow the licensee's , action on this item until it is resolved. This item is identified as an unresolved item, Limitorque Wiring Qualification (86-15-02).

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