05000395/LER-1982-040, Forwards LER 82-040/03L-0.Detailed Event Analysis Encl
| ML20070D535 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 12/08/1982 |
| From: | Dixon O SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20070D537 | List: |
| References | |
| NUDOCS 8212150089 | |
| Download: ML20070D535 (3) | |
Similar Documents at Summer | |
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Category:CORRESPONDENCE-LETTERS
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ML20205D798
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| 3951982040R00 - NRC Website | |
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. e SOUTH CAROLINA ELECTRIC & GAS COMPANY POST OPPICE 784 IE '
CotuusiA. south CARoWNA 29218
- a O. W. DixoN, JR.
g Qg82MO* 3 Nue$'1='"o',*'.ITiOn s Decembe Mr. James P. O'Reilly, Director U.S.
Nuclear Regulatory Commission Region II, Suite 3100 101 Marietta Street, N.W.
Atlanta, Georgia 30303
SUBJECT:
Virgil C.
Summer Nuclear Station Docket No. 50/395 Operating License No. NPF-12 Thirty Day Written Report LER 82-040
Dear Mr. O'Reilly:
Please find attached Licensee Event Report #82-040 for Virgil C.
Summer Nuclear Station.
This Thirty Day Report is required by Technical Specification 6.9.1.13.(c) as a result of an improper interpretation of Technical Specification 3.3.2,
" Engineered Safety Features Actuation System Instrumentation,"
Table 3.3-3, Items 2.c, and 3.b(2) on November 8, 1982.
Should there be any questions, please call us at your convenience.
Very truly yours,
/
O. W.
ixon, Jr.
ARK:OWD:dwf Attachment 1
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Mr. James P. O'Reilly LER No.82-040 Page Two December 8, 1982 DETAILED DESCRIPTION OF EVENT On November 8, 1982, with the Plant operating in Mode 2, it was discovered that Technical Specification 3.3.2, " Engineered Safety Feature Actuation System Instrum6ntation," had not been complied with due to an improper interpretation of the Technical Specification.
Specifically, items 2.c and 3.b(2) of Technical Specification Table 3.3-3 require that four channels of Reactor Building Pressure be OPERABLE for Containment Phase B Isolation and Reactor Building Spray Actuation during Modes 1, 2, and 3.
One of these four channels (PI-950) had previously been taken out of service as described in LER 82-016 submitted on November 2, 1982.
During the time frame that PI-950 was out of service and Action Statement 16 of Technical Specification Table 3.3-3 was being implemented, several Mode changes were made.
Some of the Mode changes were cases where the Plant was escalated from an existing Mode to a higher Mode.
On one occasion, the Plant was escalated from Mode 4 to Mode 3.
Since Technical Specification 3.0.4 is applicable, these Mode changes should not have been made.
PROBABLE CONSEQUENCES There were no adverse consequences because the channel was placed in a bypassed condition as required by the Technical Specification Action Statement.
CAUSE(S) OF THE OCCURRENCE The cause of the occurrence is attributed to personnel error in that the Technical Specifications were not properly interpreted.
There were two errors made in interpreting the Technical Specifications.
The first stems f rom the Table 3.3-3 Action Statement 16 statement that " operation may proceed provided the inoperable channel is placed in the bypassed condition."
This statement was incorrectly interpreted to mean that operations may continue in all applicable Modes, and that the Plant can be escalated from an existing Mode to a higher Mode.
The second error in interpretation was that a comparison was made between Items 1.c, 2.c, 3.b(2), and 4.c of Table 3.3-3.
All of these items involve Reactor Building Pressure Channels.
On two of these items (l.c and 4. c), the provisions of Specification 3.0.4 are not applicable, whereas on the other two items [2.c.
and 3.b(2)] the provisions of Specification 3.0.4 are applicable.
These differences contributed to the error in interpretation.
4 >
Mr. James P. O'Reilly LER No.82-040 Page Three December 8, 1982 IMMEDIATE CORRECTIVE ACTIONS TAKEN Upon verifying the proper interpretation with the NRC Resident Inspector, the on-duty Shift Supervisor was notified of the existing condition and the correct meaning of the Technical Specifications.
ACTION TAKEN TO PREVENT RECURRENCE An internal letter has been issued to all Station Assistant Managers and Shift Supervisors stating the correct interpretation of the subject Technical Specification.