IR 05000395/1988013
| ML20207G406 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 08/17/1988 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Bradham O SOUTH CAROLINA ELECTRIC & GAS CO. |
| References | |
| EA-88-151, NUDOCS 8808240110 | |
| Download: ML20207G406 (4) | |
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o AU617 588 Docket No. 50-395 License No. NPF-12 EA 88-151 Sputh Carolina Electric and Gas Company WTN: Mr. O. S. Bradham, Vice President Nuclear Operations Post Office Box 88 Jenkinsville, South Carolina 29065 Gentlemen:
SUBJECT:
NOTICE OF VIOLATION (NRC INSPECTION REPORT N0. 50-395/88-13)
This refers to the Nuclear Regulatory Comission (NRC) inspection conducted at the V. C. Sumer Plant on May 1 - 31, 1988.
The 'nspection included a review
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of the circumstances associated with the degraded service water flow to the reactor building cooling units following a reactor trip on May 12. 1988.
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report documenting this inspection was sent to you by letter dated June 16,
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1988. As a result of this inspection, a significant failure to comply with regulatory requirements was identified, and accordingly, NRC concerns relative to the inspection findings were discussed in an Enforcement Conference held on June 24, 1988.
The letter sumarizing this Conference was-sent to you on July 22, 1988.
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The violation described in the enclosed Notice of Violation (Notice) involved a
'r failure by your operations staff to identify degraded service water flow to the reactor building cooling units (RBCUs).
This problem should have been identified frou a post trip review of plant performance data available to the operations staff following the reactor trip of May 12, 1988.
However, because of the inadequate post trip review performed, this problem was not promptly identified and the reactor was subsequently restarted on May 12, 1988, with the degraded
service water flow to the RBCUs.
On May 16, 1988, the Independent Safety Evaluation Group conducted an independent review of the rear. tor trip data package and subsequently identified the degraded service water flow problem.
Consequently, innediate corrective action was initiated.
Nevertheless, the reactor was operated for approximately 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> without the operations staff being aware that service water flow to
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Ll.a RBCUs was degraded. A more thorough initial review of the operational data should have led to the determination that service water flow was less than required. The performance data was available, but it is evident that the i
repetitive columnar format of the data package contributed to the degraded service water flow data being overlooked during the initial review.
Your staff has shown initiative addressing this data format problem by adding graphics enhancement to the existing program. Another concern made evident as a result of this event is the approach of the operations staff to the control room I
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i annunciators immediately following the reactor trip.
The trip caused over 85 annunciators to activate and two of those annunciators should have indicated
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possible problems with service water.
It is apparent that as the operations staff were clearing the annunciators, they were not alert fnr problem indica-t tions and were routinely resetting systems which resulted in a missed oppor-tunity to detect the service water degradation problem.
Management should address the issue of the operations staff being sensitive to system indicators
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and ensure that before any system configuration change or event termination that l
they are fully aware of plant conditions.
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The NRC has emphasized reviewing reactor. trip packages and surveillance data to l
assure that components actuate properly and function within the required parameters.
Furthermore, degraded flow of critical safety systems due to clams,
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corbicula, or microbiological induced corrosion has also been the subject of NRC bulletins and notices transmitted to power reactor licensees.
The NRC is encouraged by your consideration of the possibility of adding flush
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i connections on those lines subject to biofouling.
The capability of periodically flushing lines would expand your biofouling protection measures, espeed 'ly in light of your known susceptibility to that problem because of service water
pond clam infestation.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the violation described
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in the enclosed Notice has been classified as a Severity Leve! III violation.
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Normally, a civil penalty is considered for a Severity Leve' III violation.
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However, after consultation with the Director, Office of Enforcement, and the
Deputy Executive Director for Regional Operations, I have decided that c civil s
penalty will not be proposed in this case because of your actions, particularly
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t with regard to improving your post-trip review. Also, considered were the j
actions of your independent review group which identified the problem although i
it was missed during the initial post-trip review.
Finally, your prompt corrective action and 9000 past performance, along with an increasingly aggressive approach toward problem identification and resolution contributed
to no civil penalty being issued in this matter.
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I You are required to respond to this letter and the enclosed Notice and should
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follow the instructions specified therein when preparing your response.
In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence.
Your response should describe those
particular actions taken or planned to improve the effectiveness of your management control program. After reviewing your response to this Notice,
including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action j
is necessary to ensure compliance with NRC regulatory requirements.
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In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2, i
Title 10, Code of Federal Regulations, a copy of this letter and its enclosure
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will be placed in the NRC Public Document Room.
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South Carolina Electric-3-AUG11P19El3 and Gas Company The responses directed by this letter and its' enclosure are not subject to the clearance procedures of-the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.
Should you have any questions concerning this letter, please centact us.
Sincerely, ORIGINAL SIGNED BY:
J. NEl3ON GRACE J. Nelson Grace Regional Administrator Enclosure:
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cc w/ encl:
v?fL.Skolds,GeneralManager
)'uclear Plant Operations W. B. Knotts, Jr.
Bishop Cook, Purcell & Reynolds Off A. Williams, Jr., Technical Assistant, Nuclear Operations -
Santee Cooper (A{R.Koon,Jr., Manager A uclear Licensing J. E. Rainear,-Executive Vice President, South Carolina Public Service Authority
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NOTICE OF VIOLATION South Carolina Electric and Gas Company Docket No.
50-395 V. C. Summer Unit 1 License No.
NPF-12 EA 88-151 During the Nuclear Regulatory Comission (NRC) inspection conducted on May 1 -
31, 1988, a violation of NRC requirements was identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C (1988), the violation is listed below:-
Technical Specification (TS) 3.6.2.3 requires two independent groups of reactor building cooling units (RBCUs) be operable in Modes 1, 2, 3, and 4.
ACTION Statement "b" of TS 3.6.2.3 requires that with both trains of RBCUs inoperable and both trains of reactor building spray systems operable, to restore at least one train within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
TS 3.0.4 specifies entry into an operational mode shall not be made unless the conditions of the Limiting Condition for Operation are met without reliance on provisions contained in the ACTION requirements.
TS 6.8.1 requires procedures to be established and implemented covering the activities referenced in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978. Appendix "A" of Regulatory Guide 1.33, Revision 2, specifies that administrative procedures be established and implemented.
Station Administrative Procedure 132 requires that the shift engineer review the computer post trip review printout (that includes service water flow) prior to plant restart.
It specifically states to ascertain the cause of each alarm and determine that any required automatic action functioned properly.
Contrary to the above, entry into mode 2 was made at 8:24 p.m. on May 12, 1988, and subsequently into Mode 1 at 12:21 a.m. on May 13, 1988, with both t.ains of RBCUs inoperable. The post trip review failed to detect that RBCUs were inoperable due to low service water flow, and therefore, the plant was in TS 3.6.2.3 Action Statement "b."
ThisisaSeveritylevelIIIviolation(Supplement 1).
Pursuant to the provisions of 10 CFR 2.201, South Carolina Elet iric and Gas Company (licensee) is hereby required to submit a written stat..nent or explana-tion to the Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555, with a copy to the Regional Administrator, Region II,
and a copy to the NRC Resident Inspector, within 30 days of the date of the
letter transmitting this Notice. This reply should be clearly marked as a
"Reply to a Notice of Violation" and should include (1) admission or denial of the violation, (2) the reason for the violation if admitted (3) the corrective steps which have been taken and the results achieved, (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full
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compliance will be achieved. Where good cause is shown, consideration will be
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given to extending the response time.
If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause.
why the license should not be modified, suspended, or revoked or why such other t
action as may be proper should not be taken.
FOR THE NUCLEAR REGULATORY COMMISSION j
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ORIGINAL SIGNED BY:
A net 30N GRACE
J. Nelson Grace Regional Administrator
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t Dated at Atlanta, Georgia
this (4#1 day of August 1988
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