ML20113E011
| ML20113E011 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 03/01/1985 |
| From: | Dixon O SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20100K919 | List: |
| References | |
| NUDOCS 8504160146 | |
| Download: ML20113E011 (5) | |
Text
tsl/W c a.d r+(f SOUTH CAROLINA ELECTRIC & GAS COMPANY yg
,ost or, ice m COLUMelA. SouvH CARouNA 29218 C. W. Demon. Ja.
VICE PassioeNT c:)
March 1, 1985 Nucuan O.enarioNs I
56
^
Dr. J.
Nelson Grace Regional Administrator 2.
U.S. Nuclear Regulatory Commission Region II, Suite 2900 101 Marietta Stireet, N.W.
3 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 84-37
Dear Dr. Grace:
Attached is South Carolina Electric and Gas Company's response for the Violations as addressed in Enclosure 1 of NRC Inspection Report 84-37.
If there are any questions, please call us at your convenience.
trul
- urs, O.
I n
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.
I& E (Washington)
Group Managers O.
S. Bradham NPCF C.
A.
Price File S.
R.
Hunt eBil42tBMR818S!h' Ofiicial Copy G
4-
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/
.y ENCLOSURE 1 RESPONSE TO NOTICE OF VIOLATION E
INSPECTION REPORT 84-37 ITEM 1 I.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION South Carolina Electric and Gas Company is in agreement with the alleged violation.
II.
REASON FOR THE VIOLATION Fire door IB-310B was opened at approximately 1300 hours0.015 days <br />0.361 hours <br />0.00215 weeks <br />4.9465e-4 months <br /> on December 19, 1984, to facilitate personnel access during performance of a maintenance test.
The personnel failed to
. realize that they were degrading a fire barrier required to be operable at all times by Technical Specification 3.7.10, " Fire Rated Assemblies."
III.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED Fire door IB-310B was immediately closed upon identification of the violation.
The closure of IB-310B reestablished the integrity of the fire barrier.
IV.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION The following actions have been taken to avoid further violations:
1.
In a. letter dated November 30, 1984, the Director, Nuclear Plant. Operations, emphasized the importance of. maintaining the integrity of fire' doors to plant personnel.
2.
The importance of the Fire Protection Program and action to be taken if. a fire barrier is degraded during a
. maintenance activity will continue to be stressed in Station Ori'entation Training (initial and requalification).
3.
The seriousness of the violation was discussed with the appropriate maintenance personnel on February 20, 1985.
The ' individual counselling for the isolated event is considered to be adequate to avoid further violation.
f' ENCLOSURE 1 RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT 84-37 ITEM 1 continued V.
DATE OF FULL COMPLIANCE South Carolina Electric and Gas Company was in full compliance on February 20,-1985.
i
./'
ENCLOSURE 1 RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT 84-37 ITEM 2 I.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION South Carolina Electric and Gas Company is in agreement with the alleged violation.
II.
REASONS FOR THE VIOLATION The Train " A" isolation times for valves XVG-1678 A, B, and C were verified to be satisfactory prior to entering Mode 4 on December 13, 1984.
However, as stated in the violation, the isolation times from the Train "B"
protection circuitry were not verified.
The failure to demonstrate the operability of the containment isolation valves in response to both protection trains prior to entry into Mode 4 is attributed to the following.
1.
Operators did not identify the valves against Technical Specification Table 3.6-1, " Containment Isolation valves."
The prerequisite in General Operating Procedure (GOP) 1,
" Plant Startup and Heatup from Cold Shutdown to Hot Shutdown," for entry into Mode 4 was considered complete since the valves were thought to be part of the Feedwater Systems with surveillance testing required prior to entry into Mode 3.
2.
Surveillance Test Procedure (STP) 130. 0 01, " Valve Operability Testing," was determined to be inadequate in that:
A.
The procedure addresses the stroking of valves which cannot be tested at power, but it fails to provide guidance on the bypass of interlocks which may prohibit valve stroking.
B.
The mode in which valve operability is required is not identified.
The procedure relied on Operator awareness of the Technical Specifications to make judgements on mode restrictions.
r:
.,~
ENCLOSURE 1 RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT 84-37 ITEM 2 continued III.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED Upon identification of the test deficiency by the NRC Resident Inspector a procedure change was initiated to install the necessary jumpers to perform the Train "B" test prior to entering Mode 3.
A satisfactory test of the isolation times for the valves was completed at 0320 hours0.0037 days <br />0.0889 hours <br />5.291005e-4 weeks <br />1.2176e-4 months <br /> on December 15, 1984.
IV.
CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATION STP-130.001 is being separated into mode dependent procedures with guidance provided on the defeat of interlocks necessary to test valves.
The new procedures will be developed by June 30, 1985.
Changes previously incorporated into STP-130.001 insure the adequacy of the STP until the issuance of the new procedures.
V.
DATE OF FULL COMPLIANCE South Carolina Electric and Gas Company will be in full compliance by June 30, 1985.