IR 05000395/1999005

Insp Rept 50-395/99-05 on 990620-0731.Non-cited Violation Noted.Major Areas Inspected:Operations,Maintenance, Engineering & Plant Support

ML20211L533
Person / Time
Site:	Summer
Issue date:	08/30/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20211L523	List: IR 05000395/1999005 ML20211L518
References
50-395-99-05, NUDOCS 9909080263
Download: ML20211L533 (20)

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i U. S.' NUCLEAR REGULATORY COMMISSION REGION ll

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

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i Report No.: 50-395/99-05 l l

Licensee: South Carolina Electric & Gas (SCE&G)

Facility: Virgil C. Summer Nuclear Station Location: P. O. Box 88

~ Jenkinsville, SC 29065

' Dates

June 20 - July 31,1999 l \

l l l . Inspectors: M. Widmann, Senior Resident inspector M. King, Resident Inspector i G. Belisle, Branch Chief, Ril (Section M8.1)

i K. Coyne, Project Engineer, Ril (Section E1.1, R1.1, R1.2 and P4.2)

I J. Kreh, Reactor inspector, Ril (Section P4.2)

G. McCoy, Surry, Resident inspector (Section E2.1)

G. Salyers, Reactor Inspector, Rll (Section P4.1 and P4.2)

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Approved by: R. C. Haag, Chief, Reactor Projects Branch 5  !

Division of Reactor Projects  ;

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Enclosure 9909000263 990830 PDR ADOCK 05000395 O PDR .

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L EXECUTIVE SUMMARY Virgil C. Summer Nuclear Station NRC Inspection Report No. 50-395/99-05

This integrated inspection included aspects of licensee operations, maintenance, engineering, J l and plant support. The report covers a six-week period of resident inspection; in addition, it !

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includes the results of announced inspections by two regional reactor inspectors, a project '

engineer, a visiting resident inspector, and an in-office review by a branch chie Operations

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• Prompt operator response to unexpected control rod motion during performance of a

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calibration minimized any adverse effects on the plant (Sections O1.1 and M3.1).

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The licensee's actions in response to N-44 power range detector indication exhibiting a current decrease were appropriate, Operations personnel displayed a good questioning attitude by detecting this condition prior to an alarm occurring. The technical assessments, engineering 10 CFR 50.59 screenings, compensatory actions taken and operability assessments were found to be consistent with the guidance of Generic Letter !

91-18, Revision 1, for a degraded but operable component (Section O1.2). )

Maintenance

• Maintenance personnel used good work practices during troubleshooting activities for Non-Conformance Notice 99-1044 conceming N-44 power range detector (Section i O1.2). i

• Routine maintenance and surveillance activities were satisfactorily performed, i.e., .

conducted in an appropriate and professional manner in accordance with established procedures. Good communications and supervisor oversight were noted by the

' inspectors during instrumentation and control surve;ilance activitier (Section M1.1).

• A Non-Cited Violation was identified for failure to establish an adequate procedure for the performance of rack calibration of main feedwater to steam generator C flow control valve, IFV00498 (Section M3.1). i Enaineerina

- Although the troubleshooting plan for unexpected tripping of the pressurizer group 2 heater breaker was appropriate and reasonable, the long-term troubleshooting instructions did not ensure that three multimeters installed for troubleshooting would remain continously operational. This deficiency could have resulted in important troubleshooting information being missed (Section E1.1).

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Plant Suooort

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l Technical Specification requirements for steam generator activity analyses were satisfied

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• ' The inspectors identified an unexpected increase in a secondary coolant tritium that the licensee had not noted or analyzed in their chemistry trend report (Section R1.2).

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The licensee's submittals of the scope and objectives, as well as, the scenario package were timely and appropriate for the biennial emergency preparedness exercise. The exercise scenario was sufficiently detailed and challenging (Section P4.1).

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The licensee's overall performance in response to a simulated emergency was satisfactory. The inspectors concluded that the exercise was a successful demonstration of the licensee's emergency response capabilities. The Alert, Site Area Emergency, and General Emergency declarations were timely and correct, and all offsite notifications I

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were completed within 15 minutes (Section P4.2).

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Command and control in each of the emergency response facilities was effectiv However, there was room for improvement in performing briefings and maintaining the plant status priority board in the Operations Support Center (Section P4.2).

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The Technical Support Engineering (TSE) team recommendations were not based on thorough engineering evaluations in its support of several off-normal actions taken by the

~ Technical Support Center (TSC). In addition, poor communications were noted between the TSC main room personnel and TSE team members concerning the status of plant and equipment conditions (Section P4.2).

A fire brigade drill was performed satisfactorily and met established criteria. The critique conducted was thorough. Areas needing improvement were captured in the drill critique and will be incorporated in quarterly training for fire brigade team members. No concerns were identified with the protected area fire brigade team member qualifications (Section F5.1).

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Report Details Summary of Plant Statug The unit operated at approximately 100 percent power for the entire inspection period,

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l. Operations 01 Conduct of Operations 01.1 General Comments (71707)

The inspectors conducted frequent reviews of ongoing plant operations. In general, the conduct of operations was professional and safety-conscious. The unit experienced no significant transients. The inspectors noted good operator response to unexpected inward control rod motion during performance of calibration procedure ICP-0235.003, ;

" Main Feedwater Control Valve IFV00498," Revision 9. Operator actions limited the temperature transient and restored the rod control system to normal (see Section M3.1). ,

l The inspectors noted improvements in equipment material condition and overall general i housekeeping throughout the plant during the inspection perio )

Other specific events and noteworthy observations are detailed in the sections belo .2 Nuclear Instrumentation N-44 Drift J Insoection Scooe (71707. 37551)

The inspectors observed and reviewed the licensee's response to a slow downward drift in nuclear instrumentation N-44 power range detector curren Observations and Findinos During this inspection period operations personnel noted unexpected decreasing detector currents on power range instrument N-44. Through review of computer history data the operators noted a slow downward drift in N-44 detector currents as compared to the other three channels (N-41, N-42, N-43). The operators noted this condition prior to receiving a power range channel deviation alarm. An in-core detector flux map I confirmed that the indication was a problem with the N-44 instrumentation and not a real flux tilt in the reactor cor Initial troubleshooting efforts focused on the high voltage power supply for N-44. No 1 problems were noted with the power supply. Westinghouse was contacted and indicated moisture on the outside of the detector cables or connection points could potentially cause this type of behavior. Detector pull boxes were checked and no water was note The licensee swapped the N-44 power range drawer with a spare drawer, however, the ,

downward drift continued. The previously installed N-44 drawer was thoroughly )

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examined in the Instrumentation and Control (l&C) shop and no problems were identified. The licensee also had a vendor perform time domain reflectometry testing to

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determine any problems with the N-44 cabling and connections from the control room drawer connection to the detectors. No cable or connector problems were identifie The inspectors reviewed the dispositions for two condition evaluation reports (CERs)

generated for the N-44 condition (CER 99-1024 and CER/ Non-Conformance Notice (NCN) 99-1044). The technical assessments, engineering 10 CFR 50.59 screenings, compensatory actions taken and operability assessments were found to be appropriate

- and consistent with the guidance of Generic Letter 91-18, Revision 1, "Information to Licensees Regarding NRC Inspection Manual Section on Resolution of Degraded and Nonconforming Conditions." The licensee's conclusion that N-44 remains operable and capable of performing its design function was reasonable. This decision was based on the licensee's ability to meet Technical Specification (TS) requirements and surveillance criteri The inspectors verified that operations personnel logged the nuclear instrumentation detector currents once per shift to identify any adverse trend. The inspectors also reviewed Station Order No. 99-08 which would initiate a compensatory calibration prior to the 2 percent TS limit on difference between excore channel indication and calorimetric power being approached. The actions dispositioned by CER/NCN 99-1044 will continue until the actual cause of the behavior of N-44 is identified and additional corrective actions are determine Conclusions The licensee's actions in response to N-44 power range detector indication exhibiting a current decrease were appropriate. Operations personnel displayed a good questioning attitude by detecting this condition prior to an alarm occurring. Good work practices i were used in the troubleshooting activities. The technical assessments, engineering 10 CFR 50.59 screenings, compensatory actions taken and operability assessments were found to be consistent with the guidance of Generic Letter 91-18, Revision 1, for a degraded but operable componen Operational Status of Facilities and Equipment O2.1 Enaineered Safety Feature (ESF) System Walkdown - Service Water Pond Cateaorv i Seismic Dam insoection Inspection Scope (71707)

The inspectors performed a walkdown and detailed review of the service water (SW)

pond dams and embankmen Observations and Findinos

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On July 27, the inspectors performed a walkdown of the three SW pond dams (north, south, and east) and the west embankment. The inspection also included the intake and discharge structures and the SW pump house. This inspection was conducted in

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conjunction with a review of the SW pond dams by an employee of the Federal Er;ergy Regulatory Commission who was accompanied by an NRC representative from the Office of Nuclear Material Safety and Safeguards (NMSS).

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The overall general condition of the dams, west embankment and the structures were good. No issues or problems were identified that presented an immediate concern to the continued operation of the dams or the facility. However, several items were identified that the licensee needs to consider for long term corrective actions. A report from FERC through the office of NMSS is forthcoming and will include a detailed discussion of these item . Conclusions

- The inspectors concluded that the service water pond dama, west embankment, intake and discharge structures, and service water pump house were in adequate condition to be able to perform their intended design functio Miscellaneous Operations issues (92901)

08.1 (Closed) Licensee Event Reoort (LER) 50-395/99009-00: reactor trip due to spurious high flux trip signal in power range nuclear instrument drawer N-43. This LER l documented the reactor trip that occurred on June 4,1999. This event and licensee )

performance had previously been reviewed and documented in NRC Integrated Inspection Report No. 50-395/99-04, Section O1.3. The inspectors reviewed and concluded that the subject LER documented the cause, event analysis and the corrective actions taken for this reactor trip. No new issues were revealed by this LE II. Maintenance M1 Conduct of Maintenance M1.1 Observation of Work Activities Inspection Scope (62707. 61726)

The inspectors observed all or portions of maintenance and surveillance testing activities listed belo j l

• ICP-160.010 " Component Cooling Pump Discharge Header A Flow IFT07030 Calibration," Revision 4 MMP-320.013 " Component Cooling Water Pump Maintenance," Revision 7 l

l SPP-210 " Security Lock and Key Control," Revision 9

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STP-225.001A " Diesel Generator Support Systeme Pump and Valve Test,"

Revision 4C

• STP-228.001 " Fire Protection System Fire Pumps Test," Revision 2E, annual operability test for electric fire pump XPP0134A

• STP-310.005 " Nuclear Instrumentation Power Range N-41 Calibration," Revision

• STP-345.074 " Solid State Protection System Actuation and Logic Master Relay

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Test for Train B," Revision 9A

= STP-395.055 " Refueling Water Storage Tank Level Instrument ILT00991 Operational Test," Revision 6 i

= STP-395.057 " Refueling Water Storage Tank Level Instrument ILT00993 Operational Test,* Revision 6 i

a STP-396.013 " Emergency Feed Pump Suction Pressure 111 Instrument (IPT03634) Operational Test," Revision 5B MWR 9909149 Disassemble Outboard Bearing and Replace Seal on B Centrifugal Charging Pump; Fix Oil Leak

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MWR 9909373 Replace filter XFLOO9 Reactor Coolant Filter

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MWR 9910294 Troubleshooting Plan for N-44 Power Range Drawer in accordance with ICP-500.019, " Nuclear Instrumentation Power Range and Miscellaneous Drawers Alignment for Troubleshooting

/ Maintenance," Revision 2

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MWR 9910613 Calibration and Venting of IFT-07044 Residual Heat Removal Heat Exchanger B / Component Cooling Water Flow Transmitter b. Observations and Findinas The inspectors' observations verified that work was performed with the work package present and actively referenced. Generally, activities observed were conducted in accordance with written procedure instructions. Procedures provided sufficient detail and guidance for the intended activities. Technicians demonstrated that they were experienced and knowledgeable of their assigned tasks. Quality control personnel were present whenever required by procedure and when applicable. The inspectors noted that appropriate radiation contmi measures were in place. The inspectors concluded that routine maintenance and surveillance activities were satisfactorily performe Specific areas of concern or notewoithy items are documented below.

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During observation of Surveillance Test Procedure (STP)-345.074, the inspectors r,oted that a miscommunication occurred between l&C personnel, but was corrected through the proper use of three-way repeat backs. By allowing a pause between taking an action and closure of the three-way communication, a potential switch mispositioning was prevented. Good communication practices and supervisor oversight were observed by the inspectors throughout the performance of this procedure.-

. During discussions with personnel working on the Component Cooling Water (CCW)

system, MWR 9910613, the inspectors noted several of these workers were unaware that the system contained potassium chromates, in discussions with operations personnel the inspectors generally found they were knowledgeable of this fact; however, -

one individual indicated that he believed potassium chromates had been removed from the system. Discussions with the Chemistry Manager and review of system documentation confirmed that the system still does contain potassium chromates. This chemical is commonly used as a corrosion inhibitor and is a skin irritant concem. The Chemistry Manager indicated that actions would be taken to address this issue. The inspectors noted an e-mail was issued discussing this concern as a reminder to all plant personnel. The inspectors did not identify any instances where workers' skin was exposed to potassium chromates or where it was improperly controlled or released to the environmen During a documentation review of completed surveillance procedure STP-125.013,

" Diesel Generator Semiannual Operability Test," Revision 6, the inspectors noted an error in the time calculated for the diesel generator to reach rated frequency and voltag The error involved the entry and exit point in the band of rated voltage and frequenc This error did not impact successful completion of the test. Actual times met the rated frequency and voltage requirements within specified limits. The error was also noted and corrected by the Associate Manager of Operations during the responsible supervisor review process. The inspectors independently verified the strip chart calculations met TS requirement Conclusions i

Routine maintenance and surveillance activities were satisfactorily performed, j 1.e., conducted in an appropriate and professional manner and in accordance with l established procedures. Good communications and supervisor oversight was noted by the inspectors during instrumentation and control surveillance activitie :

M3 Maintenance Procedures and Documentation M3.1 Control Rod Stenoina Durina Rack Calibration of Main Feedwater Control Valve Inspection Scope (62707. 40500)

The inspectors reviewed the licensee's investigation and evaluation of control rods unexpectedly stepping inward during performance of main feedwater rack calibration activities. The inspectors reviewed the licensee's response to this operational event to

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assess problem identification, root cause analysis, and the implementation of corrective action b. Observations and Findinas On June 29, control rods unexpectedly stepped inward nine steps when l&C technicians performed rack calibration procedure ICP-0235.003, " Main Feedwater Control Valve IFV00498," Revision 9. The rods stepped in when relay card UY/768-l, loop C main feedwater flow control valve, was removed per step 7.6.1 of ICP-0235.003. Removal of

! this card not only removed controlling function of the valve but also resulted in a loss of reference temperature (T-ref) signal input which caused the control rods to insert. The control room operators promptly placed the rod control system in manual to stop inward rod motion. Proper operator response to this unexpected event minimized the effect on the unit. Reactor Coolant System average temperature (Tavg) decreased approximately 0.5 degree Fahrenheit during the event. CER 99-0966 was generated to address this condition and a formal Root Cause Analysis, (RCA) 99-04, was also initiated.

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Based on a review of the event the inspectors determined that the unexpected control I rod movement during performance s (ICP-0235.003 occurred as the result of an inadequate procedure. The procedt, e did not contain instructions to place the rod control system in manual prior to the relay card removal. This procedure was previously performed off-line without incident, but a recent scheduling change allowed the rack calibration to be performed with the plant on-line. The review for this scheduling change failed to identify that there were multiple inputs into this relay card and, therefore, did not require the rod control system to be in manual prior to commencement of the calibration activity. A review of the original Westinghouse drawing and subsequent licensee loop diagrams did not indicate that the relay card had muitiple input The actual cause for the procedure inadequacy was attributed to drawings that did not indicate that a relay card to be removed during the procedure had multiple input Criterion V, " Instructions, Procedures, and Drawings," of 10 CFR 50, Appendix B states, in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."

Procedure ICP-0235.003 is safety-related and govemed under the licensee's Operational Quality Assurance Plan. This failure to update and maintain the ICP-0235.003 procedure to ensure a proper test setup and correct configuration control necessary to prevent unexpected control rod motion is identified as a violation of 10 CFR 50, Appendix B, Criterion V. This Severity Level IV violation is being treated as a Non-Cited Violation (NCV), consistent with Appendix C of the NRC Enforcement Policy. This violation is in the licensee's corrective action program as CER 99-0966 and RCA 99-04 and is identified as NCV 50-395/99005-0 This event demonstrates the importance of proper change management with careful and thorough procedure reviews for on-line maintenance activities which had been previously performed during outage _

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- . - , 7 Conclusions An NCV was identified for failure to establish an adequate procedure for the performance of rack calibration of main feedwater to steam ganerator C flow control valve, IFV0049 Prompt operator response to unexpected control rod motion caused by this inadequate procedure minimized any adverse effects on the plan M8 Miscellaneous Maintenance issues (92902)

M8.1 (Closed) Insoection Followuo item (IFI) 50-395/97011-01: determine cause/ corrective action of degraded snubber condition. The licensee's snubber reduction program reduced the number of snobbers from 1635 to 663. The remaining snubbers were put into a service life monitoring program. The licensee has determined that most snubber failures are due to false brinelling or fretting corrosion caused by high frequency low amplitude piping vibrations. The inspectors reviewed NCNs 97-0761 and 98-1038. NCN 97-0761 detailed the results of snubber testing performed during refueling outage (RFO)

11. The sample of snubbers picked was determined after RFO 10. NCN 98-1038 ,

detailed the repairs to a snubber that was not expect to fail based on the service life

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monitoring program. The licensee is continuing to develop data on snubber failures and {

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is using this data to refine the service life monitoring progra ~

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E1 Conduct of Engineering E Review of Pressurizer Heater Breaker Troubleshootino Activities Insoection Scope (37551)

The inspectors reviewed the engineering guidance and implementation of troubleshooting activities for unexpected tripping of the pressurizer group 2 heater breaker (XSW1DB-05). Observations and Findinos The pressurizer group 2 heater breaker has unexpectedly tripped three times since l September 1998. Failure of this breaker requires entry into TS 3.4.3.a. " Pressurizer," l action statements which state that the plant is to be shutdown if the inoperable heater group cannot be restored within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Following a spurious breaker trip in September 1998, the licensee replaced the breaker (see NRC Integrated Inspection Report 50-395/98-08, Section M1.2). After another spurious breaker trip in February 1999, the licensee installed temporary instrumentation in the breaker control circuitry to attempt to identify the cause of the spurious trips. The licensee also initiated NCN 99-0131 to evaluate corrective actions for the condition. In May, the pressurizer heater breaker again tripped and the temporary monitoring instrumentation captured a trip signal generated within the breaker control circuit. Based on this information, the licensee eliminated the breaker as a cause of the trip and focused their troubleshooting

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- efforts on the control circuitry, in order to locate the portion of the breaker control circuit initiating the spurious trips, the licensee installed three recording multimeters inside the control cabinets associated with the breaker control circuit. On July 6, the inspectors found that the batteries in all three multimeters had become discharged. The inspectors were concerned that had a trip signal been generated within the breaker control circuit,

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the trip actuating signal would have not been recorded in this condition. The licensee l

replaced the batteries and revised the NCN disposition to increase the battery '

replacement from every four weeks to every two weeks. The inspectors rechecked the .

. meters within the subsequent two weeks and again noted a meter with a discharged battery. The licensee then implemented a daily check of the meters in an effort to establish the correct frequency for battery replacement. The licensee intends to continue to monitor the breaker circuitry until refueling outage 12. The inspectors considered scope of the troubleshooting plans for the group 2 pressurizer heater breaker to be reasonable, however, the plans were not implemented thoroughly, Conclusions Although the troubleshooting plan for unexpected tripping of the pressurizer group 2 heater breaker was appropriate and reasonable, the long-term troubleshooting instructions did not ensure that three multimeters installed for troubleshooting would remain continously operational. This deficiency could have resulted in important troubleshooting information being misse E2 Engineering Support of Facilities and Equipment E Year 2000 (Y2K) Readiness Proaram' Review (2515/141)

The staff reviewed the portions of Temporary Instruction (TI) 2515/141, " Review of Year 2000 (Y2K) Readiness of Computer Systems at Nuclear Power Plants," which had not been completed in the May 10-14,1999, review These portions of the Tl were not performed at that time due to the licensee not having completed all their planned -

evaluations. The evaluations of the Bailey Control System for the Turbine Closed Cycle Cooling System and the Plant Computer were reviewed and determined to be completed in accordance with industry guidance. The Integrated Contingency Plan had also been completed and was determined to be in accordance with NEl/NUSMG 98-07, " Nuclear Utility Year 2000 Readiness Contingency Planning."

l The licensee has developed an " Integrated Action Plan Checklist" within the Contingency Plan which contains preparatory actions which must be completed prior to January 1, 2000. The inspectors noted that the licensee had not met the completion dates for the three actions which were due prior to July 15,1999. This was identified to the licensee management and the dates in the checklist are being re-evaluate Conclusions regarding the Y2K readiness of the facility are not included in this repor The results of this review will be combined with the results of reviews of other licensees in a NUREG publicatio r3

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1 , .9 IV. Plant Suonort

.R1 - Radiological Protection and Chemistry (RP&C) Controls R General Comme 018 i

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, The inspectors observed radiological controls during conduct of routine inspections and observation of operation and maintenance activities and found them to be acceptabl = On July 8, the inspectors observed an individual unsuccessfully attempt to exit through

!. the protected area radiation portal monitors. The individual was unable to pass through l the portal monitors or frisk with a handheld radiation detector without causing an alar After the individual stated that she had not entered the radiologically controlled area, the portal access security guard allowed the individual to exit the protected area. The

inspectors immediately contacted health physics personnel and informed them of the L observation.' The licensee informed the inspectors that the individual involved had l received a radioiodine injection the previous day. The inspectors were also informed that the individual was not in the licensees dosimetry issue program and had not received training on requirements to contact health physics when receiving a radionuclide medicalinjection. Although the requirement to notify health physics when receiving a medical radionuclide injection is contained in training given to individuals who are issued dosimetry, individuals who are not issued dosimetry do not receive training on

.this requirement. The inspectors were concemed with security personnel response to exit portal alarms and specifically allowing an individual to exit without health protection department personnel first being notified. The licensee initiated CER 99-1002 to evaluate corrective actions for this condition.

l R1.2 : Review of Steam Generator Chemistry

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' The inspectors reviewed steam generator chemistry sample results to verify compliance with TS 3.7.1.4, " Activity," requirements. The inspectors also reviewed chemistry data trending and analysis, Observations and Findinas The inspectors reviewed the licensee's implementation of TS requirements for steam generator coolant activity level and dose equivalent iodine (DEI). The licensee routinely samples steam generator coolant activity five times a week, a frequency greater than the TS required periodicity of once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Based on the current steam generator coolant activity level, DEI is required to be sampled every six months. The inspectors reviewed completed surveillance test procedures and analysis results for steam generator activity level and DEI and concluded that the licensee satisfied TS requirements. The measured secondary coolant activity levels were substantially below the TS action level. While reviewing the database used for chemistry data trending, the inspectors noted that the analysis results for the June 17,1998, DEI sample was omitted l

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from the chemistry database. The analysis results for this DEI sample were recorded on the associated surveillance procedure data sheet. The licensee initiated CER 99-1064 to evaluate corrective action for this conditio The inspectors assessed the condition of the primary sample laboratory, where secondary samples for activity analysis are drawn, and the counting room. General area -

housekeeping was good, as evidenced by minimal amounts of debris, orderly conditions in the lab areas, and adequate area lightin In accordance with Chemistry Procedure 605, " Chemistry Group Intemal Audits," the chemistry department performs a periodic review of chemistry data. The inspectors reviewed the results of the 1998 chemistry data review for steam generator chemistry.

, Although the audit addressed steam generator chemistry trends encountered due to a l

condenser tube leak and power changes, the audit did not provide an analysis for an approximate doubling in secondary coolant tritium concentration experienced in May 1998. During the following four months, the tritium level slowly decreased back to the April 1998 level of approximately 0.4x104 pCi/ml. The licensee was unable to determine the cause of the tritium concentration increase. Because an unexpected increase in ,

secondary tritium concentration could indicate increasing steam generator tube leakage, ;

the inspectors questioned chemistry department supervision if the increase in secondary ,

tritium activity warranted discussion in the annual chemistry audit. The chemistry l l

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supervisors stated that they would have expected the tritium activity trend to be addressed in the chemistry audit. The inspectors were concemed that trending data was l not captured in the trend report and that the licensee had not noted the issue previousl '

c. Conclusions Technical Specification requirements for steam generator activity analyses were satisfied. However, the inspectors identified an unexpected increase in secondary coolant tritium that the licensee had not noted or analyzed in their chemistry trend repor P4 Staff Knowledge and Performance in Emergency Preparedness (EP)

P4.1 Review of Exercise Objectives and Scenarios for Power Reactors (82302)

a. Insoection Scope The inspectors reviewed the exercise scenario to determine if it was of sufficient detail and challenge to permit the licensee to demonstrate its exercise objectives and meet regulatory requirement *

b. Observations and Findinas Prior to the exercise, the licensee submitted a complete scenario package along with the scope and objectives for NRC review. The exercise scenario was judged to provide a L

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sufficiently detailed and challenging sequence of simulated emergency conditions to demonstrate the designated objectives and test the licensee's onsite and offsite

._ emergency organization Conclusions The licensee's submittals of the scope and objectives, as well as, the scenario package were timely and appropriate for the biennial emergency preparedness exercise. The exercise scenario was sufficiently detailed and challengin ~ P4.2 ~ Evaluation of Exercises for Power Reactors (82301) Inspection Scope The inspectors observed and evaluated the V. C. Summer Nuclear Plant biennial, full-participation emergency preparedness exercise and monitored selected activities related to the licensee's conduct and self-assessment of the exercise. Licensee activities inspected during the exercise on July 21,1999, included those occurring in the Control Room Simulator (CRS), Technical Support Center (TSC), Operations Support Center (OSC), and Emergency Operations Facility (EOF). The inspectors reviewed licensee recognition of abnormal plant conditions, classification of emergency conditions, notification of offsite agencies, development of protective action recommendations, command and control, communications, adherence to Emergency Plan implementing Procedures (EPIPs), and the overall irr.plementation of the Radiological Emergency Pla Emeroency Response Facility (ERF) Observations and Findinos b.1 Control Room Simulator An Alert was declared at 8:01 a.m. by the Shift Supervisor (who at that time became the interim Emergency Director) in response to the report of a tomado onsite. A publ?c address announcement promptly ordered activation of the ERFs. Offsite notifications to the state and counties as well as the NRC were timely, although message number 1 contained excessive technical terminology which hampered the verbal transmission of the message. Command and control by the interim Emergency Director was effectiv b.2. Technical Suooort Center The TSC was activated at 8:30 a.m., following the Alert emergency declaration. The continuous flow of incoming information into the TSC necessitated the Emergency Director's (ED) frequent and thorough briefs which kept the TSC and OSC staff well informed.'

The ED exercised good command and control in the TSC; however, the ED had difficulty managing the technical issues, as evidenced by making critical decisions without a !

technical basis or engineering analysis (see Section P4.2.b.3).

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The TSC, along with the other ERFs, shared an Emergency Information System (EIS) to maintain a log and communicate information. The inspectors observed the EIS fail at 10:57 a.m. and return to service at 10:5g a.m. When EIS was returned to service, the system lost all historical data. This lost information included position logs, equipment failures and status, events, completed emergency tasks, and personnel accountabilit The inspectors observed that in the TSC there were no backup indications (status

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boards) of plant conditions, equipment status, emergency status, or radiological condition Also, at approximately 11:43 a.m., the integrated Plant Computer System (IPCS) failed and was never returned to servic b.3 Technical Supoort Enaineerina (TSE) Team The TSE team provided expertise in engineering and design activities as required by the TSC Technical Support Supervisor. The Technical Support Supervisor maintained communications with the engineering team throughout the exercise. Although the engineering team generally was kept appraised of TSC priorities and significant events, occasionally information relayed to the engineering team was either delayed or incorrec For example, the TSE team was unaware of a change in the operating status of the B emergency diesel generator for over an hour and initial damage assessments for the Fuel Handling Building significantly underestimated the extent of damag With the exception of the electrical engineering staff, the TSE team generally was reactive, cther than proactive, in evaluating plant status and system performanc Team members relied on information supplied by the main TSC center and did not fully utilize other information resources available in the TSC, such as the IPCS. However, on several occasions, the inspectors observed the electrical engineering staff perform detailed evaluations of electrical distribution system status, develop contingency actions, and recommend actions to mitigate system damag Generally, recommendations by the TSE team were based upon discussions among  ;

team members and were not supplemented by a review of available resources, such as the Final Safety Analysis Report, plant drawings, and other design basis document The inspectors noted three examples of significant technical support recommendations i that were not based on a thorough engineering evaluation:

the use of the spent fuel pool (SFP) as a heat sink for component cooling water during a loss of service water with damaged fuel in the SFP,

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the diversion of Refueling Water Storage (RWST) inventory from the safety injection system to the reactor building spray system to reduce containment pressure. The peak containment pressure during the exercise was approximately five psig, and a

the use of rags to seal a tornado-induced leak in the condensate storage tank

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The TSE team did not fully consider the negative impikations associated with these recommendations prior to providing them to TSC management. For example, the TSE

' team did not evaluate the effect of reducing RWST inventory available for safety injection or the potential for foreign material intrusion (e.g. rags) into the emergency feedwater system. Additionally, the basis for these recommendations was not documente b.4 Operations Support Center (OSC)

The OSC was activated at 8:07 a.m., following the Alert emergency declaration. In the OSC, congestion and noise were minimized, and habitability of the facility was verified on a periodic basis. The facility and equipment properly supported the OSC's missio The OSC Supervisor's command and control were observed to be acceptable, but with room for improvement. For example, priority tasks requested by the TSC ED were generally understood by the OSC Supervisor and were effectively communicated to the

- assigned teams but were not always communicated to other personnel in the OS Also, the plant status priority board in the OSC was not properly maintained. The inspectors observed that the priority of tasks on the board in the OSC differed from that specified by the TSC and five priority tasks were never entered on the board in the OS In addition, the Supervisor conducted OSC briefs infrequently, i.e., only three briefs during the approximately six-hour dril The OSC personnel resource status boards were well maintained and effectively used to track available personnel in each technical discipline. Sufficient numbers of personnel were available from the different maintenance and support groups to quickly respond to assigned tasks. Teams were readily assembled, adequately briefed, and dispatched within minutes of their specific mission being assigned. In the field, OSC teams were professional and focused on their emergency activities. Upon returning to the OSC, teams were sufficiently debriafed including observations about unexpected conditions encountered in the fiel The inspectors observed that information was not communicated from the OSC to the TSC consistently.. Specifically, the status of teams returning from the field and the i i

information they had gathered were not consistently or effectively communicated to the TSC. The lack of this information could have impacted the resources and priorities in the TS b.5 Emeroency Operations Facility (EOF)

i The EOF was activated at 8:56 a.m. The EOF staff functioned efficiently and l professionally. Command and control of EOF operations by the Offsite Emergency l Coordinator (OEC) was effective. Periodic status briefings by the OEC were useful in i keeping the staff informe The declarations of a Site Area Emergency at 9:57 a.m. and a General Emergency at 11:23 a.rr.. were timely and correct. Offsite notifications in each case were made within

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- '15 minutes, as required. The information contained in the notifications provided accurate and concise event description b.6 Scenario Control Scenario data beginning at approximately 240 minutes into the mercise contained errors in isotopic and field-survey data that led to player confusion and a protective action recommendation far more extensive than what the scenario had intended. This problem was recognized and fully identified by the licensee. A root-cause analysis will be

. performed and tracked as one of the issues under CER 99-107 b.7 Licensee Exercise Critiaue Following the exercise, the licensee conducted facility critiques in which the players assessed their own performance and identified areas for improvement. The player critiques in the CRS, TSC, OSC, and EOF were observed to be thorough, open, and self-critical. Following the player critiques, the licensee's controller / evaluator organization held detailed discussions, reviewed documentation, and conducted *

interviews as required to develop its critique results. With the exception of the performance of the Technical Support Center Engineering group, the licensee's critique identified the issues discussed in this report. The licensee identified additional follow-up items which were characterized as items requiring corrective action and improvement items. On July 23,1999, the lead exercise controllers provided a detailed presentation of the critique findings to licensee management and plant staf The licensee stated that CER 99-1077 will be used to track all licensee identified action I items as well as the NRC's observations pertaining to command and control in the OSC, and the need for a more thorough analysis of engineeing recommendations submitted to the TSC by the TSE tea c.- Overall Exercise Conclusions The licensee's overall performance in response to a simulated emercancy was satisfactory. The inspectors concluded that the exercise was a successful demonstration l of the licensee's emergency response capabilities. The Alert, Site Area Emergency, and ;

General Ernergency declarations were timely and correct, and all offsite notifications ;

were completed within 15 minute !

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Command and controlin each of the emergency response facilities was effectiv '. However, there was room for improvement in performing briefings and maintaining the plant status priority board in the Operations Support Cente i The Technical Support Engineering (TSE) team recommendations were not based on i thorough engineering evaluations in its support of several off-normal actions taken by the Technical Support Center (TSC). In addition, poor communications were noted between the TSC main room personnel and TSE team members concerning the status of plant and equipment condition ;

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F1 ' Control of Fire Protection Activities l

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F GeneralComments During routine tours of the plant the inspectors examined control of ignition sources and i

' flammable materials, general condition of fire alarms, fire fighting and extinguishing equipment, emergency lighting, and fire barriers. The inspectors identified no significant

' concerns, the control of combustible and flammable materials was effective, fire

- protection systems appeared operational and well maintaine F5- ' Fire Protection Staff Training and Qualification -

F Review of Fire Briaade Drill and Qualifications Inspection Scope (71750) i

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Inspectors observed and reviewed documentation of a shift fire brigade drill conducted

= under preventive maintenance task sheet PMTS 9905167. The inspectors also reviewed the status and tracking of fire brigade member qualification Observations and Findinas On July 16, the inspectors witnessed an unannounced fire brigade drill in the 7.2 kV switchgear and electrical equipment room (XSW1DA-01, Bus 1DA normal incoming 3 breaker) located in the intermediate building (1863-01). The fire brigade leader responded promptly (within two minutes) to the area. The five fire brigade mernbers

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responded in full fire fighting gear (protective clothing and self contained breathing apparatus being wom) within 10 minutes. Personnel from security, maintenance and operations also responded properly to the drill. The actions by the fire brigade and

. support personnel were assessed as satisfactor Fire brigade members simulated the use of portable carbon dioxide (CO 2) extinguisher The inspectors noted that backup hose lines were properly deployed, radio communications with the control room were adequate and the necessary equipment was l brought to the scene to properly perform fire fighting operations. A total of 14 minutes elapsed between the time of the first fire alarm drill announcement and the simulated fire being declared out by the controller. A drill critique was conducted by the lead controller with all fire brigade members present immediately following the drill. Items needing improvement were captured in Fire Protection Procedure (FPP)-026, " Fire / Hazmat Response," Revision 2, Attachment 111, Drill Critique Sheet. Specifically, fire brigade team members did not bring the fire pre-plans and equipment (helmet and vest) for the fire brigade leader to the scene. Fire pre-plan instructions were directed via radio from '

the control rcom during the drill and this did not result in unsatisfactory drill performanc The inspectors reviewed the drill planning guide, drill scenario and discussed drill issues with the lead controller following the critique. Issues identified by the inspectors during the drill were captured by the licensee and incorporated in the program for upcoming

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training. The inspectors also reviewed the status and tracking of fire brigade member qualifications. The summary training and medical records tracking documents were reviewed for protected area fire brigade personnel and were verified as current with no discrepancies identified. Personnel with expired or incomplete training were clearly indicated with appropriate remarks recorded for the disqualificatio Conclusions A fire brigade drill in the 7.2 kV switchgear and electrical equipment room was performed satisfactorily and met established criteria. The critique conducted was thorough. Areas needing improvement were captured in the drill critique and will be incorporated in quarterly training for fire brigade team members. No concerns were identified with the protected area fire brigade team member qualification V. Manaaement Meetinas X1 Exit Meeting Summary l The results of the emergency preparedness exercise inspection were presented to members of licensee management and plant staff on July 23,1999. The inspectors presented remaining inspection results to members of licensee management at the conclusion of the inspection on August 5,1999. The licensee acknowledged the findings presente The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie PARTIAL LIST OF PERSONS CONTACTED Licensee J. Archie, Manager, Planning & Scheduling F. Bacon, Manager, Chemistry Services L. Blue, Manager, Health Physics and Radwaste M. Browne, Manager, Plant Support Engineering S. Byrne, General Manager, Nuclear Plant Operations i R. Clary, Manager, Plant Life Extension C. Fields, Manager, Quality Systems M. Fowlkes, Manager, Operations L. Hipp, Manager, Nuclear Protection Services D. Lavigne, General Manager, Nuclear Support Services G. Moffatt, Manager, Design Engineering A. Rice, Manager, Nuclear Licensing and Operating Experience G. Taylor, Vice President, Nuclear Operations R. White, Nuclear Coordinator, South Carolina Public Service Authority B. Williams, Genera, Manager, Engineering Services G. Williams, Manager, Maintenance Services

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INSPECTION PROCEDURES USED IP 37551: Onsite Engineering IP 40500: Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems IP 61726: Surveillance Observations j

, IP 62707: Maintenance Observations

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IP 71707: Plant Operations IP 71750: Plant Support Activities IP 82301: Evaluation of Exercises for Power Reactors IP 82302: Review of Exercise Objectives and Scenarios for Power Reactors

. IP 92901: Followup - Plant Operations IP 92902: Followup- Maintenance Tl 2515/141: Review of Year 2000 (Y2K) Readiness of Computer Systems at Nuclear Power Plants l

ITEMS OPENED AND CLOSED l

Opened-50-395/99005-01- NCV failure to establish an adequate procedure for the perfonnance of rack calibration of main feedwater l to steam generator C flow control valve (Section -

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L Closed 50-395/99009-00 LER reactor trip due to spurious high flux trip signal in power range nuclear instrument drawer N-43 (Section O8.1)

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50-395/99005-01 NCV failure to establish an adequate procedure for the l performance of rack calibration of main feedwater to steam generator C flow control valve (Section '

j M3.1)

50-395/97011-01 IFl determine cause/ corrective action of degraded j snubber condition (Section M8.1)

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