ML20077R748
| ML20077R748 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 08/19/1991 |
| From: | Skolds J SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9108260036 | |
| Download: ML20077R748 (8) | |
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C th Chfullha lltTINC $ Obl Cofff&ny John L Ia g
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AUG 191991
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Document Cuntrol Desk U. S. Nuclear Regulatory Commission Washington, DC 20555 Gentlemen:
Subject:
VIRGIL C. SUMMER NUCLEAR-STATION DOCKET NO. 50/395 OPERATING LICENSE NO. NPF-12 RESPONSE TO NOTICE OF VIOLATION AND HOTICE OF DEVIATION NRC INSPECTION REPORT 91-10 Attached is the South Carolina Electric & Gas Company (SCE&G) response to the two violations and the deviation delineated in Nuclear Regulatory Commission Inspection Report No. 50-395/91-10.
While the attached' response to Violation Number 50-395/91-10-01 delineates corrective actions to reduce personnel error by members of the Test Unit specifically, it is SCE&G's opinion that the generic concern in the area of procedural compliance is best addressed by the Virgil C. Summer Nuclear Station (VCSNS) continuing program for nuclear excellence. The following actions adequately address the plant-wide concern of personnel error and procedural compliance at VCSNS:
1.
Principles for Excellence - This program stresses the importance of professionalism for all personnel in the Nuclear Operations Division. As part of this program, VCSNS is currently developing discussion guidelines which will include procedural adherence and the-individual's responsibility for quality of work performed.
2.
SELF-CHECK Strategy - VCSNS personnel are encouraged to use the SELF-CHECK strategy, a process of verification steps to complete when performing a task. This strategy is designed to prevent personnel error by helping the worker concentrate on the job being performed.
3.
Quality Systems Semiannual Trend Report - The Vice President of Nuclear Operations and his staff receive and review this report periodically to identify any negative trends in performance.
Monitored in this report is the area of personnel error, which specifically includes procedural non-compliance. SCELG will continue to monitor this area and take appropriate corrective action as deemed necessary.
91'0826UO36 910819
""# LEAR EXCELLENCE - A SUMMCR TRADITION!
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{DR ADOCK 0500
t These actions are part of a continuing effort at VCSNS to reduce personnel error.
Should you have any questions, please call at your convenience.
Very truly yours,
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1 John L. Ske'ds EWR:JLS:smd Attachment c:
- 0. W. Dixon Jr.
R. R. Mahan R. J. White S. D. Ebneter G. F. Wunder General Managers C. A. Price NRC Resident Inspector J. B. Knotts Jr.
J. W. Flitter NSRC RTS (IE 911000)
File (815.01)
NUCLEAR EXCELLENCE - A SUMMER TRADITION!
Attachment to nocument Control Desk letter A
IE 911000 Page 1 of 6 RESPONSE TO NOTICE OF VIOLATION VIOLATION NUMBER 50-395/91-10-01 Requirement:
Technical Specification 6.8.1.c requires that written procedures be established, implemented and maintained covering surveillance and test activities of safety-related equipment.
I.
ADMISSION OF VIOLATION South Carolina Electric & Gas Compt y (SCE&G) is in agreement that Technical Specification 6.8.1.c was violated when Virgil C. Summer Nucicar Station (VCSNS) personnel incorrectly installed the field standard gauges for Surveillance Test Procedure (STP) 105.004,
" Residual Heat Removal (RHR) Pump Test." SCE&G is also in agreement that Technical Specification 6.8.1.c was violated when VCSNS personnel recorded the RHR pump discharge pressure rather than the suction pressure as delineated in '.tep 6.4g of STP 105.004.
II.
REASON FOR VIOLA H QN The reason for this viciation is personnel error. The Test Specialist did not identify the difference in the ranges of the field standard gauges prior to installation.
He therefore arbitrarily installed the higher range gauge on the suction pressure side of the RHR pump.
This error was propagated when a second Test Specialist failed to verify the gauge installation and assumed that the gauge with the lowest pressure range was attached to the RHR pump suction.
As such, he inadvertently recorded RHR pump discharge pressure rather than suction pressure.
Ill.
CQRPHJlVI_SILELTND_AND RFRULILAttt1LVED k
Upon being questioned by the NRC Inspector, the Test Specialists realized that they had installed the field gauges incorrectly. They notified the control room, installed the gauges in their correct locations, and repeated the RHR pump test from the beginning, without incident.
IV.
CORRECTIVE ACTIONS TAKEN TO AV010 FURTHER VIOLATIONS The following SCE&G actions will aid in preventing similar violations:
- 1. The two Test Specialists were counseled on procedural compliance and the need to pay attention to detail.
- 2. The two Test Specialists conducted " Lessons Learned" training on the event to all Test Unit members.
- 3. The Manager of Technical Services discussed the event in detail with the entire Technical Services Department, stressing the need
Attachment to Document Control Desk letter Il 911000 Page 2 of 6 to pay attention to detoll, the reason for sending two Specialists to perform the test (verificction, r.ot speed), and the importance of the SELF-ClitCK process.
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- 4. In order to ir. crease their knowledge of plant components and systems, Test Specialists will receive formal Aaxiliary Operator (AP) training.
V.
QATE OF full COMPLIANCE
._'in I
Corrective Actions 1, 2, and 3 are complete.
Corrcctive Action 4 is part of a newly issuei initial and continuing training program for the Test Specialists. One-hilf of the Test
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Specialists have completed this A0 course. All the current Test Specialists will have tomoleted the course by the end of 1993.
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Attachment to Document C9ntrol Desk Lettcr IE 911000 o
l Page 3 of 6 RESPONSE TO NOTICE OF VIOLATION VIOLATION NUMBER 50-395/91-10-04 Requirement:
10CFR50, Appendix B, Criterion XVI, " Corrective Action,"
requires that, " Measures shall be established to assure that conditions 3dverse ta qualit31 auch as failures, malfunctions, deficiencit., Jeviations, defective material and equipment, and nonconformances are promptly. identified and corrected."
- 1. ADMISSION OF VIOLATION SCE&G is in agreement with the violation in that VCSNS did not replace thc Condensate-Storage Tank (CST) diaphragm prior to its failure.
II.
REASm, F0fLV101 ATION
>%G initially planned to have the diaphragm vendor install a new CST d-Jhragm during Refuel 5.
During the outage, however, the vendor informed SCE&G that they could not perform the work per the schedule, but could provide a technical advisor.
Based on previou; experience in patching the diaphragm, SCE&G was concerned that the new diaphragm could be damaged during installation. Additionally, SCE&G did not-have the staff available to perform the work.
SCE&G evaluated the diaphragm, considering its d= sign basis and current condition, and decided that it was acceptable to extend its service life. Given this evaluation, the scheduling concerns, and the. possibility of damaging the new diaphragm, SCE&G decided to defer replacement of the diaphragm until Refuel 6.
SCE&G disagrees that VCSNS did not adequately address the potential safety impact of a failed diaphragm. During the evaluation to extend the diaphragr,. service life, the Condensate System Engineer reviewed the indicators of previous tank diaphragm failures such as increased axygen levels, magnes'on content and the presence of diaphr<tgm particles; none of th w parameters were observed to indicate CST diaphragm deteriorattua or degradation. -The System Engineer also considered the consequences of the diaphragm blocking ti arious suction paths from the tank. In the consideration of CSI a ction path slockage (for normal and emergency operation), it was the System Engineer's judgment that biockager would be highly unlikely given thct the design basis and manufacture of the diaphragm is that it floats.
This premise was further supported by previou3ly observed performance of the CST dianbragm over several years of operation.
Furthermore, the System Engineer visually inspected the diaphragm.
Based on these consideretions, and with input from the System Engineer (the same individual'that established the initial replacement frequency of the-diaphragm), SCE&G management concluded that the CST diaphragm replacement could be deferred to Refuel 6.
For added assurance of diaphragm integrity during the nen cycle, the inspection frequency was increased from annually to quarterly. While the documentation to support this evaluation was admittedly lacking, the evaluation was
- Attachment to Document' Control Desk Letter i!E 911000
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Page 4 of 6 thorough and technically complete in its considerat %n of the operational'and safety consequences of diaphragm fai:u m.
The Notice and Inspection Report imply that SCE&G management consciously decided not to replace the CST diaphragm contrary to Quality Control trend reports and_ Design Engineering recommendations to replaca the diaphragm. The replacement interval for the diaphragm had not been specified by the vendor, but rather had been determined by the System Engineer. Since the vendor had not originally established a replacement interval, SCE&G management requested the System Engineer to evaluate the feasibility of extending the service life of the diaphragm.
Taking into consideration the results of this evaluation, SCE&G management decided that the diaphragm's service life could be extended.
In situations such as this, where technical data does not mandate that an action be taken, management should be allowed to exercise judgment based on the best information available.
It is SCE&G's position-that, based on the available technical data, the best decision was made.
SCE&G also disagrees with the Notice's cover letter wording that SCELG failed to replace the diaphragm, "despite indications it was past its 1
service life." The diaphragm was past its System Engineer recnmmended replacement interval, but none of the observed parameten indicated that the diaphragm was deteriorating or degraded. There was no technical basis to-preclude extending the service life of the diaphragm.
Finally, SCE&G disagrees with the statement in the Notice that the CST diaphragm failure is similar to the previous failures of diaphragms in the Boric Acid Tanks and the Reactor Makeup Water Storage Tank. These diaphragms deteriorated snd were discovered chemically or by ircreased levels of oxygan, in contrast, the CST diaphragm appeared to be intact _and samples indicated no traces of magne:ium or debris and no abnormal increase in oxygen prior to the event.
III.
C0RRFCT1VE3ILillAKM_AND_RESULIS Am1LVED SCE&G implemented the action statement-of Technical Specification 3.7.1.3, " Condensate Sterage Tank," and removeo the diaphragm from the CST.
The bottom of the CST was cleaned to remove the rubber debris which was shaved off the diaphragm during removal. The CST was then flushed and the contents restored to coMensate grade water.
On July 10, 1991, a Management keview Board (MRB) meeting was convened to review the decision makt v: prc. cess involved in deferring the i
replacement of the CST diaphragm. The intent of the meeting was to ensure that nonconservative decisions were not being made.
The MRB reviewed-the thought process involved in the decision and discussed that, while the m is pressure during refueling outages to maintain schedules, it is the MRB's consensus that scheduling pressure should not cause management to make norconservative decisions.
The MRB's consensus is that the decisions made in deferring the diaphragm replacement were conservative and based on sound judgment.
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. Attachment to Document Control Desk letter IE 911000 Page 5 of 6 IY.
CORRECTIVE ACTIONS TAKEN TO AVOID FURTHER VIOLATIONS AND DATE OF FULL G,0MPLIANCE SCE&G will evaluate the need for a CST diaphragm to control oxygen in the secondary side of the plant. This evaluation will be completed prior to Refuel 7. scheduled for the Spring of 1993.
As part of this evaluation, it is intended that the CST diaphragm will not be installed during the operating cycle leading up to Refuel 7.
If deemed necessary, the diaphragm will be installed during Refuel 7.
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" Attachment to Document Control Desk Letter IE 911000 Page 6 of 6 RESPONSE f0 DEVIATION DEVIATION NUMBER 53-395/91-10-02 Commitment: To enter the inlet and outlet valves to both trains of cooling water _provided to the component cooling water pump motors in the Locked Valve Program. (from SCE&G's August 10, 1^90, response _to NRC Inspection Report No. 50-395/90-18.)
I.
RESPONSE TO NOTICE,OF.0EVIAT10N SCE&G dentes the deviation of a written commitment in that the subject valve, X'!T-6446A, was entered into the station Locked Valve Program and was being controlled per this program.
At the time of the event, the
" Locked Valve Tracking Sheet" was being maintained in the VCSNS Control Room and indicated that the vulve was in the throttled position. Tnis is in accordance with the Locked Valve Program and provides the administrative controls specified in NRC Inspection Report 50-395/90-
- 18. SCE&G recognizes the Locked Valve Program as the governing mechanism for controlling components and believes that the flexibility needs to exist to provide interim positions of components due to varying plant conditions.
II.
CORRECTIVE ACTIONS Valve XVT-6446A was caution tagged-in the throttled position per the Nonconformance Notice (NCN) disposition until an additional disposition was completed to change the required position of the valve to the locked throttled position. Valve XVT-6446A was place ' in the locked throttled position following-a change to the Locked Valve Program and the System Operating Procedure in accordance with the subsequent NCN disposition.
SCE&G agrees that improvements can be made in the VCSNS program for configuration control during the implementation of NCN's. As a result of this, SCE&G hhs instituted.a committee to review configuration control using the NCN process. This committee will investigate ways to stiengthen configuration control _and to improve engineering / operation interface during NCN implementation.
Based on this review, SCE&G will strengthen the program to improve configuration control.
This review and program revision will be completed by June 1992.
Additionally, SCE&G will review all open NCN's to ensure that the required positive controls are in place for those components whose stLtus is affet. Led by the disposition of an NCN. This review will be completed by December 31, 1991.
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