ML20101T988
| ML20101T988 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 12/21/1984 |
| From: | Dixon O SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20101T983 | List: |
| References | |
| NUDOCS 8502060494 | |
| Download: ML20101T988 (3) | |
Text
__
.g SOUTH CAROLINA ELECTRIC ~& GAS COMPANY POST OFFICE 764 h
COLUMeiA. SOUTH CAROLINA 29218 i.,'
O. W. DixoN, J.,
suc$*e'd"o'E.Ir"[o S December 21, 1984 Mr.. James P. O' Reilly Regional Administrator U.S. Nuclear Regulatory Commission Region II, Suite 2900 101 Marietta Street, N.W.
Atlanta, Georgia 30323
SUBJECT:
Virgil C. Summer Nuclear Station Docket No. 50/395 Operating License No. NPF-12 Response-to Notice of Violation NRC Inspection Report 84-30
Dear Mr. O' Reilly:
Attached is South Carolina Electric and Gas Company's response for the Violation as addressed in Enclosure 1 of NRC. Inspection Report 84-30.
If'there are any questions, please call us at your convenience.
Very truly yours, J
O. W.
Dix
, Jr.
CJM:OWD/lcd Attachment cc:
V. C.
Summer C.
L. Ligon (NSRC)
T.
C.
Nichols, Jr./O. W. Dixon, Jr.
K.
E. Nodland E.
H.
Crews, Jr.
R.
A.'Stough E. C. Roberts-G.
Percival W.
A. Williams, Jr.
C. W. Hehl D. A.
Nauman J.
B.
Knotts, Jr.
Group Managers I& E (Washington)
O. S. Bradham NPCF C. A.
Price File D. A.
Lavigne l
l l
8502060494 850109 i
PDR ADOCK 05000395 G
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ENCLOSURE l-
't
-RESPONSE TO NOTICE OF VIOLATION INSPECTION ~ REPORT 84-30
+
I.-
ADMISSION-OR DENIAL OF THE ALLEGED VIOLATION ~
South Carolina Electric and Gas Company is in agreement with the alleged vie.lation.
II.
- REASON FOR THE VIOLATION l
The violation of the locked valve ' control program, identified
.on October 29, 1984, is attributed to personnel error. -The
. Virgil ~C.
Summer Nuclear Station was shutdown on September 28,
[
1984, for a. planned maintenance and refueling outage..During this outage, the Plant was in Mode _ 5 and systems -such as i
i.
Component-Cooling required multiple danger. tagging, valve l
alignments, and draining and venting evolutions for maintenance and testing of equipment.
Technical Specification
' 3.7.3, " Component Cooling Water System," requires'two (2) independent Component Cooling water loops for Modes 1, 2, 3, and 4.
At the time of the violation, the system was capable.
of performing its required function of providing cooling water 4
- to the Residual Heat Removal System.
On October-13, 1984, the Component Cooling Heat Exchanger "B"
i Inlet-(XVB-9508B) and Outlet (XVB-9509B) Valves were closed -
i' and Asnger-tagged for performance of a relief ~ valve test.
A ed Valve Tracking Sheet" was filled out and placed in the I
e tracking section of the Locked Valve Book in accordance j
with the requirements of Special Instruction '(SI) 84-05,
" Locked Valve Control," at the. time of the valve isolations.
[
The program requires Operations personnel to~ install the locking device and complete the SI-84-05 tracking sheet upon removal of -danger tags and -repositioning of the valves.
The placement and tracking of danger tags is. controlled by i
~ Station Administrative Procedure-(SAP) 201, " Danger Tagging."
.A component < log sheet'is filled.out prior to the placement of i
. danger tags and is.used to track.the position / status - of i
equipment during maintenance.
Step.6.6.9 of-SAP-201 requires Operations personnel, enter,the normal operable position of the component as-specified;by the applicable' System Operating i
Procedure (SOP). 'The log entry for the-required' operable.
position 'of 'XVB-9508B and XVB-9509B was ' listed asi" Open" ~on E
'the October 13-tag-out; whereas, SOP-ll8, " Component Cooling Wate r," requires the valve positions to be " Locked Open."
- When the danger tags were removed on October 16, 1984,'the. log
. sheet ~ error caused the locked valve control program i
non-compliance.
The operator who repositioned-the valves' was -
{,
unaware that a. Locked Valve Tracking Sheet was in the active-j file and~that a locking device was required.
)
.90 ENCLOSURE 1 Continued II.
REASON FOR THE VIOLATION - continued The " similar violation" of the locked valve control program addressed in NRC Inspection Report No. 50-395/84-23 dated August 27, 1984, was attributed to a lack of program knowledge on the~part of Chemistry personnel.
The program was not followed in both violations; however, the root cause was not similar.
The Licensee believes that the corrective actions addressed below, in addition to those provided in our response dated September 25, 1984, are adequate to preclude recurrence.
III.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED A locking device was immediately installed on the Component Cooling Heat Exchanger valves after the NRC Resident Inspector identified the program violation.
System function had not previously been impaired since the valves were in their correct position.
A system valve alignment on November 28 and' a locked valve audit on December 8 provides additional assurrance of program compliance.
IV.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION The following corrective actions have been taken to prevent recurrence:
i 1)
The response to this violation will be included in the required reading for Operations personnel.
This action is expected to be complete by January 15, 1985.
2)
A training program on precedural adherence and the locked valve control program is presently under~ development.
Plant _ operator training is expected to be complete by January-31, 1985.
V.
DATE OF FULL COMPLIANCE South Carolina Electric and-Gas Company will be in full compliance by January 31, 1985. !
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