ML20076N541
| ML20076N541 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 06/22/1983 |
| From: | Dixon O SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20076N531 | List: |
| References | |
| NUDOCS 8307220065 | |
| Download: ML20076N541 (6) | |
Text
,_ ________-_____-- _________ _ _ _ - _ _ _ _
SOUTH CAROLINA ELECTRIC & GAS COMPANY Post ospecs ve4 CotuuslA. SOUTH C AROLINA 29218 y
y LJ MIgw O. W. DmoN-JR, p
C 7,{J vice PassicaNr June 22, 1983
'5 qo svet... o... vio s 95
- r, P
up oc Mr. James P. O'Reilly m,5 Regional Administrator
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U.S. Nuclear Regulatory Commission
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Region II, Suite 2900 101 Marietta Street, N.W.
Atlanta, Georgia 30303
SUBJECT:
Virgil C. Summer Nuclear Station Docket No. 50/395 Operating Licerme No. NPF-12 Notice of Violat.cn NRC Report 83-09
Dear Mr. O'Reilly:
Please find attched South Carolina Electric and Gas Company's response to the Notice of Violation as addressed in Appendix A of NRC Inspection Report 83-09.
If there are any questions, please call us at your convenience.
Very truly yours,
/
O. W.
ixon r.
CJM:OWD/meb/fjc Attachment cc:
V.
C.
Summer C. L, Ligon (NSRC)
E. H. Crews, Jr.
G. J. Braddick T.
C. Nichols, Jr.,/O.
W. Dixon, Jr.
J.
C. Miller E.
C.
Roberts J. L. Skolds J.
B.
Knotts, Jr.
H. N.
Cyrus I&E (Washington)
Group / General Managers O.
S.
Bradham Document Management Branch R. B.
Clary C. A. Price INPO Records Center NPCF A.
R. Koon D. A. Lavigne File (Lic./Eng.)
OFFICIAL COPf
~5I 8307220065 830714 PDR ADOCK 05000395 C
m Mr. James P. O'Reilly NRC Notice of Violation Page 2 June 22, 1983 RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT 83-09 PART A I.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION South Carolina Electric and Gas Company (SCE&G) is in agreement with the alleged violation.
II.
REASON (S) FOR THE VIOLATION 1.
The gas decay tanks were not alternated every two days during the period of February 21, 198 3, to March 6, 1983, in accordance with the requirements of System Operating Procedure (SOP)-119 (Waste Gas Processing) because:
A.
Operations personnel failed to comply with the procedural requirements to alternate the gas decay tanks because of personnel error.
B.
A procedural inadequacy also existed in that an adequate means of tracking and documenting the rotation of the tanks did not exist.
2.
Station Administrative Procedure (SAP)-132, "Of.f Normal Occurrence Evaluation, Reporting and Resolution," was not implemented on January 13, 1983, and January 19, 1983, because of personnel error.
Operations personnel recognized the applicability of Technical Specification 3.3.3.6 in reference to the failed condensate storage tank level transmitters and initiated all of the appropriate documentation and repair activities with the exception of the Off Normal Occurrence report.
3.
Health Physics Procedure (HPP)-160, " Control and Posting of Radiation Control Zones," was not complied with in that a Quality Control Inspector entered the radiation control zone to observe work on the residual heat removal pump without following the complete dress requirements identified on the Radiation Work Permit (RWP).
The reason for this failure to follow RWP requirements is attributed to personnel error.
Mr. James P.
O'Reilly NRC NGtice of Violation Page 3 June 22, 1983 III. CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED 1.
Station Order 83-04, " Rotation of Gas Decay Tanks,"
was initiated on March 11, 1993, to provide a means of recording and tracking the rotation of the Gas Decay Tanks.
Rotation is now being accomplished every two days while the reactor is at power.
2.
A series of lectures was conducted with operators and their supervisors concerning attention to detail and follow through in the performance of their duties.
These lectures were completed on May 27, 1983.
SAP-132 has been implemented correctly in all instances since the identification of this violation and completion of the lectures.
3.
Quality control Inspection personnel were counseled on the importance of following RWP requirements on April 7, 1983.
There have been no additional violations of RWP dress requirements identified as of the date of this response.
IV.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION 1.
The plant operator logs are being revised to track the rotation of the gas decay tanks.
This revision is expected to be completed by July 31, 1983, and Station Order 83-04 will be withdrawn from use at that time.
2.
The corrective action previously taken by the licensee and documented in Section III of this response is l
considered adequate to prevent a possible future failure to implement SAP-132.
3.
The failure to comply with RWP dress requirements documented on March 17, 1983, is considered an isolated event.
All station personnel attend an i
I annual Station Orientation Training requalification which emphasizes compliance with the RWP.
This training is considered adequate to avoid further violations.
V.
DATE OF FULL COMPLIANCE 1
SCE&G will be in full compliance by July 31, 1983.
l l
m
Mr. James P.
O'Reilly NRC Notice of Violation Page 4 June 22, 1983 RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT 83-09 PART B I.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION South Carolina Electric and Gas Company is in agreement with Item 2 of the alleged violation but does not agree with Item 1.
II.
REASON (S) FOR THE VIOLATION 1.
The Virgil C.
Summer Nuclear Station had general plant operating procedures (GOP) in effect at the time of the violation which address the requirement for de-energizing residual heat removal (RHR) isolation valves 8701B and 8702A.
The Reactor Coolant System had been drained to half pipe conditions per applicable procedure (GOP-10) prior to hhe identification of the violation in NRC Inspection Report 83-09 and the subject valves were de-energized and locked open at that time.
Subsequent electrical maintenance activities on the valves required re-energization for short periods of time.
At the completion of this activity operations personnel inadvertantly failed to de-energize the valves.
When the discrepancy was noted by the NRC Resident Inspector the breakers were immediately de-energized and danger tagged open.
The plant was in compliance with Appendix A of Regulatory Guide 1.33 in that adequate procedure controls did exist for the performance of safety related activities.
The fact that the requirement is not addressed in more than one procedure is immaterial since the discrepancy was a result of operator error and is an example of a failure to follow a procedure as identified in Part A of this violation.
1 s
Mr. James P. O'Reilly NRC Notice of Violation Page 5 June 22, 1983 2.
While troubleshooting steam generator blowdown valves (9398A, B,
and C) on February 8 and 9, 198 3, test activities were conducted with inadequate procedural controls as identified in the violation.
The cause of the procedural inadequacy is considered to be an over-sight by plant personnel.
The possible consequences that could have resulted from this event were mitigated by:
A.
The inoperable condition of the valves was tracked in the Removal and Restoration Log in accordance with the requirements of SAP-205, " System Status and Equipment Removal and Restoration to Service."
B.
Operation of the valves during the troubleshooting activities was continuously tracked in the Station Log Book in accordance with SAP-204, " Operating Logs and Records."
III. CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED 1.
The breakers for RHR isolation valves (8701B and 8702A were immediately de-energized and danger tagged open when the NRC Resident Inspector notified Operations personnel of the discrepancy.
The danger tags insured that the valves would remain open until required to be re-positioned by the applicable GOP's for Mode escalation.
2.
No immediate corrective action was taken on the inadequate procedural controls identified by the NRC Resident Inspector for the event of February 8 and 9, 1983.
Reference Section IV for action to be taken to avoid further violation.
IV.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION 1.
The following actions will be taken to insure future compliance with GOP-10, " Preparation for Refueling,"
in reference to the positioning of the RHR Loop Suction Valves:
e Mr. James P. O'Reilly NRC Notice of Violation Page 6 June 22, 1983 A.
Additional operator training will be performed to increase their awareness of the reason for and importance of de-energizing the RHR Loop Suction Valves with the Reactor Coolant System open to atmosphere, the reactor vessel head on and the steam generators not available for decay heat re-moval.
This training is scheduled to commence on July 25, 1983 and will be completed by August 31, 1983.
B.
GOP-10 will be revised by August 31, 1983, to require that the valves be danger tagged in the future when they are de-energized and locked open.
2.
SCE&G is evaluating the Station Administrative Procedures in order to determine which one is the most appropriate for revision.
This revision will provide adequate administrative controls to assure that Technical Specification requirements are met in future situations similar to the event of Feburary 8, 1983, where valves 9398A, B,
and C were unisolated for troubleshooting after entering the action statement.
The evaluation and procedure revision will be complete by August 31, 1983.
V.
DATE OF FULL COMPLIANCE 1
SCE&G will be in full compliance by August 31, 1983.
i