ML20126B008
| ML20126B008 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 12/17/1992 |
| From: | Skolds J SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9212210335 | |
| Download: ML20126B008 (6) | |
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- South Carohna Clactric & Gas Company John L Skolds Vice Prentdertt P 0 Ilos 88 s.
Jenkinsville $C 790%
' Nuclear Operatons -
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'i (803) 345'4040 5CE&G December 17.-1992 Document Contral. Desk U. S. Nuclear Regulatory Conunission Washington, DC 205FS Gentlemen:
Subject:
VIRGIL C. SUMMER NUCLEAR STATION DOCKET NO. 50/395 OPERATlHG LICENSE NO. HPF-12 RESPONSE Tb NOTICE Of VIOLATION NRC INSPECTION REPORT 92-19 l
Attached is the South Carolina-' Electric & Gus Company (SCE&G) response to the two violations delineated in NRC Inspection Report No. 50-395/92-19.
SCE&G is in agreement with violatien 92-19-01 and is not in agreement with violation 92-19-02.
The basis for this disagreement is contained within the attached reply.
Should you have any questions, please contact Mr. Wesley R. Higgins at (803) 345-4042.
Very truly yours, b
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J John L. Skolds WRH:JLS:smd Attachmeat c:
- 0. W. Dixon R. R. Mahan R. J. White S. D. Ebneter General Managers L. D. Shealy NRC Resident Inspector J. B. Knotts Jr.
J. W -Flitter L
tNSRC
'RTS (IE921901&IE921902)
File.(815.01) 1
=9212210335 921217 PDR ADOCK 05000395 P,I
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NUCLEAR EXCELLENCE - A SUMMER 1RADIT10N!
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~ Enclosure'l-to Document Control Desk letter
- IE'921901
~ Pagel1,of.2
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RESPONSE'TO NOTICE OF V'a.
- DN VIOLATION NUMBER 50-39' G 49-0 1.
RESTATEMENT OF._V10 TAT 10N Techni;al Specificotton 4.3.1.1 requires that.each reactor trip system automatic trip logic be demonstrated operable by performance of the surveillance requirements specified in Table 4.3-1.
Line l tera 22 of Table 4.3-1 for the reactor trip bypass breakers references Notation (13) for the requirement to perform a trip actuating device operational test. Notation (13) of Table 4.3-1 requires the breaker be tripped via the " Local. manual shunt trip (LMST) prior to placing breaker in service."
Contrary to the above:
- i On 0-tober 23, 1992, the trip actuating device operational. test that was performed on the reactor trip bypass breaker-prior to placing it in service did not test the w.unt trip feature of ti.c breaker. This resulted from inadequate procedural controls and equipment-labeling.
Also, testing of the reactor trip bypass breaker shunt trip feature during previous surveillances could not be assured due to tho'same inadequate controls and labeling.
VI.
SCE&G POS!!!ON ON IHIS VIOLATION SCE&G agrees with the violation as stated above.
111.
REASONS FOR THE VIOLATION Ine procedures did not identify which breaker trip method to use-prior to placing'the oypass breakers ir service. Also,_ labeling of
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-the pushbuttons located on the reactor crip switchgear did not '
clearly define the pushbuttons' functions.
_ 'V._
CORRECTIVE STEPS'TAKEN AND RESULTS ACHIEVED After reviewing the-event, the effects on plant safety were-
-minimized due.to no history-of shunt trip operation failures, bypass-
-breakers being installed for a short duration, and the Shunt. Trip Attachment (STA) being verified every six months through additional
-surveillance-testing.
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b to Document Control Desk Letter-IE 921901 Page 2,0f'2 V.
CORRECTIVE STEPS TO Bf lAKEN TO AV010 EURTHER VIOLATIONS AND DATE LOR iUll COMPLIANCE 4
Enhancements were made to the surveillance procedure for-Train 8 SSPS to clearly define tripping of the reactor trip bypass breaker via the LMS1 pushbutton.
The surveillance procedure for Train A.
SSPS will be revised prior to performing the next surveillance test.
Also, the LMST pushbuttons were relabeled to clearly define their function.
VI.
DATE Full COMPLIANCE Will BE ACHIEVED SCELC will be in full compliance by December 31. 1992.
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., Enclosure 2 to Document Control-Desk' Letter y.
-IEL921902 Page 1 of 3-RESPONSE TO NOTICE OF VIOLA 110N VIOLATION NUMBER 50-395/92-19-02 I.
RESTATEMENT OF VI0tATION Technical Specification 6.8.1.A requires that written procedures be established, implemented and maintained covering the applicable proceduret recommended in Appendix A of Regulatory Guide 1.33 Revision 2.
Section 1.A of Appendix A lists equipment control as a safety-related activity that should be covered by written procedures.'
Contrary to the above:
On October 29, 1992, the procedures covering the control of the "B" Emergency Diesel Generator (EDG) air start system were inadequate in that they did not insure the correct position of the selector switch for the pressure switches which autostart the air compressors, while the air start system was in an abnormal condition. This resulted in the upper air start receiver tank (XTK0009C) being overpressurized.
II.
SCafG POSITION ON THE VI0lATION SCE&G denies the violation as stated above.
BASIS FOR SCE&G POSITION SCE&G does not consider that the procedures for control of the EDG during maintenance activities are inadequate. However, a labeling deficiency contributed to a personnel error.
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lhe danger tag procedure provided adequate guidance to isolate the air i
1 start tank for which the maintenance was'being-performed.~ The l
selector switch position was discussed by the Shift Supervisor with l
the operator performing the danger tagout prior to the actual hanging of the danger tags. -Direction ~from the Shift Supervisor was to select the switch position for the tank-which-was to remain in service.1 L
Control of the switch position andLits return to a normal _ lineup was-covered by' inclusion of the switch 411gning the restoration section of the-danger; tag-form..The restoration section is addressed in-the danger tag procedures and requires the Shift Supervisor to address L
components manipulated.inside the.tagout' boundary such that the normal alignment may be-restored.upon completion of the maintenance and restoration of the system to service.
This provides adequate = control of the component to ensure proper alignment both during -and following the maintenance ~ activity. :The licensee attributes-the problem with1 the-Incorrect switch position to be associated.withithe labeling of-the switch and personnel error as described below.
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-,: Enclosure 2 to' Document. Control Desk Letter IE 921902-Page 2 of'3 On October 29,~ 1992, the lower air start tank-(XTK00090) for the "B" EDG was danger tagged out, isolated, and depressurized in order to-change out the tank's relief valve._ SCE&G had intended for the upper-air start tank (XTK0009C) to remain pressurized during the valve replacement activity.
There are two pressure switches (one for each air start tank) which start and stop the air compressors that supply these tanks. On'the local control panel for the EDG there is a three position selector switch for choosing either pressure switch, or both, to control the air compressors.
This selector switch is normally Tr: the "B0Til" position. The operators recognized that the switch would have to'be moved to correspond to the tank that would remain pressurized. The-labeling on the selector switch was not consisttnt with the tank designations. -The-three position selector switch har positions "1",
"2", or "BOTH" while the two tanks have the. letter designations "C" and "0".
The letter designations of the tanks had-been incorrectly penciled in above the selector switch positions. The operators selected the switch position associated with the depressurized air tank. The operator noted tank air pressure to be approximately-375 psig and observed the air-dryer light on. This light is energized fifteen minutes prior to a compressor start. -Having observed conditions appropriate for pending compressor start, t_he operator resumed his rounds. The air compressors subsequently received a continuous run demand signal from the pressure switch associated _with the depressurized tank.
Subsequent to the installation of danger tags by Operations, it was'.
noted by a Resident NRC Inspector that both compressors were running even though the pressure of XTK0009C_was at 460 psig-(pressure-switch normally shuts off the compressors at 425 psig and the tank's design pressure is 430 psig).
During the tagout process, the Shif t Supervisor and_ control room _.
personnel discussed the proper alignment of the selector 1 switch. -This was due to the infrequent nature of this type _ maintenance activity and
-was per Station Administrative Procedure 201.
IV.
CORRECTIVE STEPS TAKEN Design Engineering performed an evaluation that showed that the EDG air start system was not overstressed as a result of this event.
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~The selector switch label will be revised:by-December 31, 1992, under l
-modifIcationrequestform-(MRF-21632)," Human _FactorsMainControl-Board Discrepancies."
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, Enclosure 2 to Document Control-Desk Letter IE.921902 x
-Page 3 of 3-All the skid mounted panels are being walked down by Operations personnel looking for other labeling discrepancies. Additionally, Nuclear Licensing and Operating Experience personnel are. independently looking at all-control panels.for labeling discrepancies. Both i
walkdowns and labeling enhancements for all control panels ~will be completed by June 30, 1993.
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