05000395/LER-2007-002, Re Failure to Follow Administrative Controls Results in LCO 3.6.4 Violation
| ML073390662 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 12/04/2007 |
| From: | Archie J South Carolina Electric & Gas Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| LER 07-002-00 | |
| Download: ML073390662 (4) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(viii)(B) 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(ix)(A) 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(v)(A), Loss of Safety Function - Shutdown the Reactor 10 CFR 50.73(a)(2)(v)(B), Loss of Safety Function - Remove Residual Heat 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(v), Loss of Safety Function |
| 3952007002R00 - NRC Website | |
text
Jeffrey B. Archie Vice President, Nuclear Operations 803.345.4214 A SCANA COMPANY December 4, 2007 Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555
Dear Sir/ Madam:
Subject:
VIRGIL-C. SUMMER NUCLEAR STATION (VCSNS)
DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 LICENSEE EVENT REPORT (LER 2007-002-00)
FAILURE TO FOLLOW ADMINISTRATIVE CONTROLS RESULTS IN LIMITING CONDITION FOR OPERATION (LCO) 3.6.4 VIOLATION Attached is Licensee Event Report (LER) No. 2007-002-00, for the Virgil C. Summer Nuclear Station (VCSNS). The report describes the sequence of actions that led to a violation of VCSNS Technical Specification LCO 3.6.4. This report is submitted in accordance with 10 CFR 50.73(a)(2)(i)(B).
Should you have any questions, please call Mr. Bruce Thompson at (803) 931-5042.
Very truly yours, Jeffrey B. Archie JW/JT/JBA/cjm Attachment c:
K. B. Marsh S. A. Byrne N. S. Carns J. H. Hamilton R. J. White V. M. McCree R. E. Martin NRC Resident Inspector M. N. Browne K. M. Sutton D. L. Abstance P. Ledbetter R. J. Schwartz EPIX Coordinator INPO Records Center J&H Marsh & McLennan NSRC RTS (CR-07-02894)
File (818.07)
PRSF (RC-07-0174)
SCE&G I Virgil C. Summer Nuclear Station
- P. 0. Box 88.]enkinsville, South Carolina 29065.T (803) 345.5209
- www.sceg.com A f
NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 08/31/2010 (9-2007)
, the NRC may (See reverse for required number of not conduct or sponsor, and a person is not required to respond to, the diqits/characters for each block) information collection.
- 3. PAGE Virgil C. Summer Nuclear Station 05000 395 1
OF 3
- 4. TITLE Failure to Follow Administrative Controls Results in LCO 3.6.4 Violation
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED MONTH DAY YEAR YEAR SEQUENTIAL REV MONTH DAY YEAR FACILITY NAME DOCKET NUMBER NUMBER NO.
05000 FACILITY NAME DOCKET NUMBER 10 05 2007 2007 2
0 12 04 2007 05000
- 9. OPERATING MODE
- 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply)
Mode 1 E] 20.2201(b) 5 20.2203(a)(3)(i) 50.73(a)(2)(i)(C)
[] 50.73(a)(2)(vii)
E] 20.2201(d) 5 20.2203(a)(3)(ii)
[
50.73(a)(2)(ii)(A) 5 50.73(a)(2)(viii)(A) 5 20.2203(a)(1) 5 20.2203(a)(4) 5 50.73(a)(2)(ii)(B)
C] 50.73(a)(2)(viii)(B) 5 20.2203(a)(2)(i) 5 50.36(c)(1)(i)(A) 5 50.73(a)(2)(iii) 5 50.73(a)(2)(ix)(A)
- 10. POWER LEVEL 1J 20.2203(a)(2)(ii)
[]
50.36(c)(1)(ii)(A) 50.73(a)(2)(iv)(A) ri 50.73(a)(2)(x) 5 20.2203(a)(2)(iii) 5 50.36(c)(2) 5 50.73(a)(2)(v)(A) 5 73.71 (a)(4) 100%
[] 20.2203(a)(2)(iv)
Q 50.46(a)(3)(ii) 5 50.73(a)(2)(v)(B) 73.71 (a)(5) 5 20.2203(a)(2)(v)
El 50.73(a)(2)(i)(A) 5 50.73(a)(2)(v)(C) 5 OTHER
[= 20.2203(a)(2)(vi)
[
50.73(a)(2)(i)(B)
[
50.73(a)(2)(v)(D)
Specify in Abstract below or in
CAUSE OF EVENT
The cause of this event is attributed to a misapplication of VCSNS Technical Specification 3.6.4. The demineralized water penetration is normally kept drained to prevent overpressurization when it is isolated. The operators confused the fact that the penetration would be declared inoperable when it was not in its drained condition, with the fact that the original plan included administrative requirements to maintain the penetration isolation valves operable when the valves were open. Once this confusion occurred, operators thought that the administrative requirements to allow opening the valves were no longer needed and that the only action required was to isolate the penetration within four hours as required by LCO 3.6.4.c. LCO 3.6.4 describesactions to perform if a containment isolation valve is inoperable, not an entire penetration. In this case, LCO 3.6.4.c did not apply. Since the preplanned administrative controls were not formalized in an approved document, the operators deviated from the preplan without a comprehensive review. They displayed "group-think" in that they believed once the "penetration" was inoperable, there was no need for administrative controls. They relaxed these controls and believed that LCO 3.6.4.c would compensate, but did not realize that the first section of the actions require at least one penetration isolation valve to be operable, which they did not have in this case.
ANALYSIS OF EVENT
Although administrative controls of the containment isolation valves was not continuously maintained, the risk incurred from this evolution was not significant. A Probabilistic Risk Assessment evaluation determined that penetration XRP0231 does not constitute a Large Early Release Frequency (LERF) pathway based on NEI 00-04 section 6.2 and Regulatory Guide 1.201. This penetration satisfies the NEI 00-04 section 6.2 criterion for low safety significance based on a size of less than two inches. This penetration is not considered a potentially significant source of leakage. Two inches is also the established LERF criterion for containment penetration size in the VCSNS PRA. Based on this, there is no change in LERF associated with XRP0231 valves. In addition, in the event of an accident, operators were available to isolate the penetration flowpath in a short period of time.
CORRECTIVE ACTIONS
Immediate corrective action was to drain XRP0231 and return the penetration to operable status. This event is still under investigation. Upon completion of the investigation, further corrective actions will be identified in a supplement to this report. A revised report is projected to be submitted by March 1, 2008.
PRIOR OCCURRENCES There have been no recent occurrences of inadequate administrative control leading to technical specification violations.
NRC FORM 36EA (9-2007)
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