ML20132F810
| ML20132F810 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 06/26/1985 |
| From: | Dixon O SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8508020394 | |
| Download: ML20132F810 (4) | |
Text
V e
SOUTH CAROLINA ELECTRIC & GAS COMPANY POST OFFICE 764 cotuusia, soum canousa as21s O W. Demon. )R.
viCr eams.oeN, June 26, 1985 NUCLE An OpenAriONS Dr.
J.
Ne ls on Grace Regional Administrator U.S.
Nuclear Regulatory Commission Region II, Suite 2900 101 Marietta Street, N.W.
Atlanta, Georgia 30323
SUBJECT:
Virgil C. Summer Nuclear [Ktation Docket No. 50/395 c_
Operating License No. N P F-:12 Response to Notice of Vidi'ation NRC Inspection Report 85-77
Dear Dr. Grace:
pj Attached is South Carolina Electric and Gas Company's reskdpse for the Violation as addressed in Enclosure 1 of NRC Inspectiqm Report 85-27.
If there are any questions, please call us at you r convenience.
Very tru y yours,
=
O.
W.
Dixo Jr.
RMF:0WD/ led Attachment cc:
V.
C.
Summer C.
L.
Ligon ( NS RC)
T.
C.
Nicho ls, Jr./0.
W.
Dixon, Jr.
K.
E.
Nodland E.
H.
Crews, Jr.
R.
A.
S t ou gh E.
C.
Roberts G.
Pe rc iva l W.
A.
Williams, Jr.
C.
W.
Hehl D.
A.
Nauman J.
B.
Knotts, Jr.
Group Managers S.
D.
Hogge 0.
S.
Bradham I & E (Washington)
C.
A.
Price NPCF S.
R.
Hunt File pgaso!88?A8888ll;s
,) gg ol
n-L ENCLOSURE 1
)
RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT 85-27 I.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION South Carolina Electric and Gas Company (SCE&G) is in agreement with the alleged violation.
II.
REASON FOR THE VIOLATION On May 11, 1985 at 1700 hours0.0197 days <br />0.472 hours <br />0.00281 weeks <br />6.4685e-4 months <br /> during a reactor s tar tu p, criticality was achieved below the Lo-Lo Rod Insertion Limit.
For zero power, the limit is Bank C at 118 steps; the observed critical rod position was Bank C at 69 steps.
Immediate action was taken by the operator to emergency borate and fu l ly insert all control rods per the procedural requirements.
The major c on t r ib u t or to the discrepancy between the predicted and actual critical rod position was determined to be with power defect data provided by Westinghouse for Cycle 2.
Due to f lu x redis tr ibution e f f ec t s, which were not previously acc ounted for and a refinement in spectrum factor, a 530 percent mi.11i rh o (pem) discrepancy was id e n t i f ie d.
This, along with differences between measured and predicted critical boron concentrations and differential baron worths used at the plant, accounts for approximately 870 pcm of the difference between the estimated and actual critical positions.
A violation was cited for f ailur e to follow procedures.
These failures were identified by the NRC inspector during his review of the event.
There were four examples of f ailure to follow procedures cited in the Audit Report.
Two failures invo lv ed the incorrect versions of procedures used dur ing the calculation of the estimated critical condition (ECC) and a previous s hu t d o wn margin c a lc u l a t ion.
The other two f ailures invo lv ed the incorrect performance of the inverse multiplication (1/M) c a lc u la t ion procedure.
On one occasion, the improper use of the 1/M plot resulted in an u n c on s e rv a t iv e prediction of core criticality.
Proper performance of the 1/M procedure wou ld h av e closely predicted the ac tual critical condition of the core, thus av o id in g this event.
On the second occasion during the subsequent startup, verbatim compliance with the 1/M procedure was not accomplished.
All four examples of f ailure to follow procedures are a t t r ib u t ed to personnel error.
There were no adverse consequences for this s pec i fic event.
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l III.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED Immediate correc tiv e action was taken in response to the event to emergency borate and fully insert all control rod a s s emb lie s per procedural requirements.
Sh u t d o wn margin was verified to be ad equa t e at all times during the event.
Westinghouse was notified for fu r the r instructions prior to the subsequent restart.
The subsequent s tar tup was conducted using the guidance provid ed by Westinghouse, and criticality was achieved with the expected critical rod position within one step of the actual critical rod position.
IV.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION The following c o r re c t iv e actions were taken to av o id fu r ther violation.
1)
Procedural compliance has been reemphasized in a series of seven meetings he ld by the Deputy Director of Nuclear Plant Operations.
These meetings stressed management concern over violations r e c e iv ed and addressed the potential for individual disciplinary action s h ou ld the present trend persist.
Essentially all plant personnel attended one of these meetings.
2)
Additional adminis trative control has been e s t ab l is hed for satellite files containing blank forms, e.g.,
f o r ms for s hu t d o wn margin and ECC calculations.
a)
A Procedure Cross-Reference Log has been pr ov id e d to control room clerks so that procedure changes and/or revisions will result in ou t-o f-d a t e forms being purged from the satellite files.
b)
Procedure Working Copies will be obtained by control room clerks from the Master Control Copy no more than two days prior to their scheduled use.
This s h ou ld both reduce the chance o f using ou t-o f-da t e procedures and reduce the adm in is t r a t iv e burden on the plant operators.
3)
Training on the use of the new ECC calculation has been accomplished as part of the licensed operator requalification training program.
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IV.
CORRECTIVE ACTION TAKEN TO AVOID-FURTHER VIOLATION Continued
- 4). Ad di t iona l s imu lat or training will be provided for licensed operators to in c lud e startups-using-1/M calculations and plots.
5)
Additional on-shift training will be provided to increase licensed operators' familiarity with the new ECC calculation procedure.
V.
DATE OF FULL COMPLIANCE SCE&G expects to be in fu ll.c omp liance with respect to the s tated correc t ive action by August 15, 1985.
An exception to this da te is mad e for Item 5 ab ov e, due to the on going nature of this training.
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