ML20077B125
| ML20077B125 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 07/01/1983 |
| From: | Dixon O SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20077B111 | List: |
| References | |
| NUDOCS 8307220552 | |
| Download: ML20077B125 (9) | |
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j SOUTH CAROLINA ELECTRIC & GAS COMPANY h
p post oprics 7e4 C-COLUM81A. SOUTH CAROLINA 29218 g
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N O. W. DIXON. JR.
sb VICE PntsIDENT NUCLEAn OpenATioNs
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Mr. James P. O'Reilly Regional Administrator U.S. Nuclear Regulatory Commission Region II, Suite 2900 101 Marietta Street, N.W.
Atlanta, Georgia 30303
SUBJECT:
Virgil C.
Summer Nuclear Station Docket No. 50/395 Operating License No. NPF-12 Notice of Violation NRC Inspection Report 83-15
Dear Mr. O'Reilly:
Please find attached South Carolina Electric and Gas Company's response to the Notice of Violation as addressed in Appendix A of NRC Inspection Report 83-15.
If there are any questions, please call us at your convenience.
Very truly yours, O.
W. Dixo, Jr..
HCF:0WD/dwf Attachment cc:
V.
C.
Summer C. L. Ligon (NSRC)
E. H. Crews, Jr.
G. J. Braddick T.
C. Nichols, J r.,/0. W. Dixon, Jr.
J. C. Miller E.
C.. Roberts J. L.
Skolds H. N. Cyrus J. B. Knotts, Jr.
Group / General' Manage rs I&E (Washington)
O.
S. Bradham Document Management R. B.
Clary Branch C. A. Price INPO Records Center A. R. Koon NPCF D.
A. Lavigne File (Lic./Eng.)
8307220552 830713 PDR ADOCK 05000395 G
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Mr. James P. 0'Reilly NRC-Notice'of Violation Page Two July 1, 1983 ATTACHMENT I RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT 83-15 (ITEMS A.1, A.2)
I.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION South Carolina Electric and Gas Comdhny is in agreement with the stated violation.
II.
REASONS FOR THE VIOLATION Technical Specification 6.5.1.6 requires that the Plant Safety Review Committee (PSRC) review Station Administrative Procedures (SAP) and their respective changes.
Six (6) of these procedures were not included in the PSRC review cycle for approval which resulted in part A.1 of the violation.
The Station experienced a massive administrative procedure restructuralization in 1982.
During this evolution, the existing A&ninistrative Procedures ( AP) were to be either deleted or incorporated into the new SAP's.
Additionally, the issuance of the Operating License in August 1982 imposed the requirement that the PSRC review the administrative procedures.
The majority of the AP's had been superceded by the SAP's.
The remaining AP's, awaiting to be superceded or deleted, were not detected as being required to be reviewed by the PSRC per Technical Specification.
Part A.2 of the violation addressed the issuance of changes to the SAP's prior to being reviewed by the PSRC.
The reasons are discussed below:
The PSRC had reviewed SAP-133, Revision 0, Change 1, on July 8, 1982.
The Station received the Operating License on August 6, 1982, which instituted the requirements of Technical Specifications.
SAP-133, Revision 0, Change 1, was in the process of becoming SAP-133, Revision 1.
Due to the anticipation of Revision 1 to SAP-133, the Revision 0, Change 1, was not fowarded to the PSRC for review.
SAP-140 and SAP-205 both were inadvertently issued by the Documents Section without prior PSRC review.
These events are attributed to personnel error.
Mr. James P.
O'Reilly
- NRC Notice of Violation Page-Three July 1, 1983 ATTACHMENT I Continued (ITEMS A.1, A.2)
III.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED All of the administrative procedures and changes thereto were verified to have been reviewed and approved by the PSRC.
IV.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION South -Carolina Electric and Gas Company considers the events associated with item A.1 of this violation to be an isolated event; therefore, no further corrective action is deemed necessary.
Station Administration Procedure SAP-139 is in the process of being revised to clarify instructions on the proper development, review and approval of station administrative procedures.
This corrective action is considered adequate to prevent recurrence of the events associated with item A.2 of this violation.
IV.
DATE OF FULL COMPLIANCE Full compliance with this_ violation has been achieved.
SAP-139 will be revised by September 1,1983.
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Mr. James ' P. 0'Reilly NRC Notice of Violation Page Four July 1,-1983-ATTACHMENT II RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT 83-15 (ITEM B.1)
I.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION South Carolina Electric and Gas Company is in agreement with the stated violation.
II.
REASON FOR THE VIOLATION Maintenance personnel were in the process of performing Reactor Trip Breaker Testing, as required by Nuclear Regulatory Commission IE Bulletin No. 83-04.
The technician-responsible for performing the test was not adequately briefed and was under the assumption that he was to perform the entire associated surveillance procedure on the Solid State Protection System.
He had previously performed the test and was f amiliar with the normal method of testing.
When the technician requested release to work from the Control Room Foreman, he was informed that only a partial test was to be performed and that the Safety Injection blocks associated with the Low Pressurizer Pressure and Steamline Pressure were not to be unblocked.
The technician reviewed the test and found the step associated with the Reactor Trip Breakers.
In his review, he found no reason why he could not meet the criteria specified by the Control Room Foreman.
Upon permission to perform the test, the technician performed the Precautions and Initial Conditions section of the procedure _and proceeded to the step for Reactor Trip Breaker Testing.
In the process of partially performing the procedure, step 7.4.3 was accidentally omitted, which caused an invadvertent Safety Injection to occur.
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Mr. James P. O'Reilly NRC Notice of Violation Page Five July 1, 1983 ATTACHMENT II Continued.
(ITEM B.1)
III.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED The technician has been counselled that deviations from the normal routine (procedures) should be evaluated by supervision prior to implementation.
The I&C Foreman-was counselled on the fact that the technician should be fully briefed on the job he is to perform.
If a procedure is to be performed in part, a thorough evaluation of the procedure and its applicability to the subject activity should-be performed prior to conducting the - test.
An evaluation will be made if a separate procedure needs to be developed to address the required activity.
IV.
CORRECTIVE ACTION-TAKEN TO AVOID FURTHER VIOLATION South Carolina Electric and Gas Company believes the aforementioned corrective actions to be adequate to prevent recurrence.
IV.
DATE OF FULL COMPLIANCE All actions mentioned above have been completed.
Mr.LJames P.!O'Reilly NRC Notice of-Violation Page Six.
-July 1, 1983 ATTACH 14ENT III RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT 83-15
.(ITEMS B.2, B.3)
I.
.. ADMISSION OR DENIAL OF THE ALLEGED VIOLATION South Carolina Electric and Gas Company -is in agreement with the stated violation.
II.-
-REASONS FOR THE VIOLATION During the time.the violation was identified, the plant was in an outage with a large number of modifications underway that
-required burn permit application.
Regarding item B.2 of the violation, burn permits were not posted at the job site due to the movement of the work crews, traffic, and an attempt to maintain the reactor building in a clean. condition.
It is 'important to note that the act of posting-the permit, whileirequired by procedure, has no effect on the ability of the program ' to execute its fire protection controls.
Item B.3 resulted from construction personnel being unfamiliar with.the operational programs and thus not signing the permit.
- During this time and throughout the outage period, approximately 300 permits were issued; therefore, the two (2) permits identified as not being signed were only a small f raction' of the total that were active.
III.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED A sample walkdown of the areas that contained burn permits was conducted to assure. that the permits were posted.
No other discrepancies were discovered, i
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p' Mr. James P. O'Reilly NRC Notice of Violation
. 3e Seven July 1,~1983-ATTACHMENT III Continued (ITEMS B.2, B.3)
IV.
CORRECTIVE ACTION TAKEN TO ' AVOID' FURTHER VIOLATION The requirement for burn permits. to be posted will be removed f rom the Burn Permit Procedure, FPP-005.
Additionally, FPP-005 will be revised to incorporate a more accurate tracking method to ensure the completion of the permit.
IV.
DATE OF FULL COMPLIANCE These actions will be complete by August 15, 1983
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A Mr. James P. O'Reilly NRC Notice of Violation Page Eight July 1, 1983 ATTACHMENT IV RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT 83-15 (ITEM C)
I.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION South Carolina Electric and Gas Company is in agreement with the stated violation.
II.
REASONS FOR THE VIOLATION The Component Cooling Water System (CCW) utilizes the Service Water System (SW) for the emergency make-up source.
The CCW system contains'chromates for corrosion control.
The SW system is an open, raw-water system.
These systems are connected by air operated make-up isolation valves (XVG-9627A and B -- one [1] valve in each train).
The cross connects contain no check valves.
During plant start-up, prior to chromating the CCW system, an event took place that caused XVG-9627 A and B to spuriously open.
Component cooling water discharged through the idle service water train to the service water pond.
Had the CCW system been chromated, the chromates would have been discharged to the environment.
Also, with the discharge, a partial loss of component cooling water inventory occurred.
Therefore, prior to chromating the CCW system, XVG-9627 A and B were gagged shut to prevent an inadvertent opening.
These valves were gagged in accordance with the plant Danger Tag procedure in effect at that time.
The plant had not received the Operating License, thus, the requirements of 10 CFR 50.59 did not apply.
The Operating License was issued in August 1982.
In preparing for mode escalation, Station Management evaluated the ramifications of XVG-9627 A and B being gagged.
However, a formal 10 CFR 50.59 review was never documented.
The potential detrimental impact of chromates being released to the environment and the potential loss of component cooling water inventory outweighed the loss of the valves' operability.
Mr. -Ja'mes ' P'.
O ' Reilly NRC~ Notice of-Violation
.Page Nine July 1, 1983 ATTACHMENT IV (ITEM C)
-III.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED L
A l'0 CFR 50.59 review has been performed with the conclusion that the gagging of the valves presents no unreviewed safety question.
IV.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION A new administrative procedure is being developed to establish controls for temporary jumpers, lif ted leads, and' mechanical modifications on equipment when determined to be required by plant. conditions.
Additionally, a modification has been initiated to incorporate check valves in the cross-connect between the two (2)~ systems to preclude reverse flow from the CCW to the SW system.
V.
DATE OF FULL COMPLIANCE The above mentioned procedure will be implemented by August 15, 1983.
The check valve modification will be completed upon design approval, material procurement, and plant availability.