ML20148E431
| ML20148E431 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 03/16/1988 |
| From: | Nauman D SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8803250131 | |
| Download: ML20148E431 (4) | |
Text
10CFR2.201 pggna Electric & Gas Company nA a n
cgo unga.gM18 Nuclear Operatens scE&G
- men, March 16, 1988 3,i.o p0: 10 Dr. J. Nelson Grace
~
Regional Administrator U. S. Nuclear Regulatory Commission Region II, Suite 2900 101 Marietta Street, NW 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 88-03
Dear Dr. Grace:
On February 19, 1988, the Nuclear Regulatory Commission (Region II) issued a Notice of Violation for alleged violations of NRC requirements at South Carolina Electric & Gas Company's (SCE&G) Virgil C. Summer Nuclear Station (VCSNS). SCE&G has thoroughly reviewed and investigated the incidents described in the Notice and, pursuant to 10CFR2.201, is responding to the alleged violations.
SCE&G is in agreement with the facts as set forth in the Notice.
The reasons for the violations and the corrective actions taken to prevent recurrence are included in Attachments I, II, and III, Attachment I, Licensee Event Report (LER) 87-30, and Attachment II, LER 87-31 address the cause and corrective action for the violation addressed in, Items A.1 and A.2 respectively. Attachment III addresses the cause and corrective action for the violation addressed in Enclosure 1, Item B.
SCE&G is currently in full compliance with respect to the regulations and will be with respect to the corrective actions stated in Attachments I, II, and III by March 31, 1988.
If you should have any questions, please contact me at your conveniance.
Very truly yours, hYAn ed D. A. Nauman WRH/ DAN: led Enclosures c: See Page Two 8803250131 880316 PDR ADOCK 0500 5
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_ j Or. J. Nelson Grace l
- March 16, 1988 Page 2 of 2 1
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J. G. Connelly, Jr./0. W. Dixon, Jr. /T. C. Nichols, Jr.
E. C. Roberts W. A. Wi!11ams, Jr.
General Managers L. A. Blue C. A. Price R. B. Clary i
W. R. Higgins J. R. Proper R. M. Campbell, Jr.
K. E. Nodland J. C. Snelson 3
G. O. Percival R. L. Prevatte J. B. Knotts, Jr.
NPCF File (815.01) 1 I
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Attachment III to Dr. J. Nelson Grace Letter March 16, 1988 i
Page 1 of 2 ATTACHMENT III l
Response to Notice of Violation Violation Humber 50-395/88-03 Item B I.
Admission or Denial of the Alleoed Violation South Carolina Electtic & Gas (SCE&G) is in agreement with the allege 3 violation.
II.
Reason for the Violation SCE&G attrioutes the cduse of this violation to be personnel error, in that the individual involved failed to notice the two-year review 1
hold stamp on the cover of Sur veillance Test Procedure (STP) 128.310 prior to using the procedure. The two-year review hold stamp is used to denote that a procedure has not been reviewed for adequacy in the last two years.
III.
Corrective Steps Taken and Results Achieved A review of a STP-128.310 was immediately initiated upon determining that it had been used with a two-year review hold stamp affixed to it.
The review determined that the procedure was adequate and technically correct.
j IV.
Corrective Actions Taken to Avoid Further Violation On January 25, 1988, a Management Review Board, chaired by the Vice President, Nuclear Operations, was, convened to review this event in order to determine the cause and ascertain the necessary corrective action to prevent further occurrences.
The Management Review Board established the following corrective actions 1.
Revise Station Administrative Procedure (SAP) 139, "Procedure l
Development, Review, Approval and Control," to require that a i
red "Two Year Hold Stamp" be used to mark Master Control copies of procedures that have exceeded their two year review period.
2.
The Fire Protection Supervisor is to make a presentation at the next Quarterly Supervisor's Meeting covering the following topics:
a.
Generic fire protection issues.
b.
The importance cf completing two-year reviews on procedures.
c.
The importance of everyone being concerned about fire protection.
1
i.g I-Attachment III to Dr. J. Nelson Grace Letter March 16. 1988 Page 2 of 2 SAP-139 "Procedure Development, Review, Approval and Control,'
revision was completed and issued February 18, 1988.. The i
l presentation to the Quarterly Supervisors meeting was comp 1ct'ed on l
January 20, 1988.
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V.
Date of Full Compliance SCE&G is currently in full compliance with respect to the regulations l
and with respect to the corrective actions stated above.
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. Attachment I to Dr. J. Nelson Grace Letter l
March 16, 1988 Page 1 of 4 j
qmC Per 3g y & 82WCLEAR al4ULAT0nv COnesasons WI AMelovt0 owe eso. 3t96 41w LICENSEE EVENT REPORT (LER)
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~ o At a;;roximately 2240 neurs, Decemoer 29, 1987, curing the review of station logs, the Centrol Recm Su:erviser notea tnet an Auxiliary 0;erator (AO) haa mace a leg entry n: ting tnat a fire c Or nad not teen fully snut onen exiting tne penetration area due to wires running uncer tne a:Or. Because tre Integratec Fire Ccmouter System (!FCS) had previcusly :een removea fr:m service, not fully closing the fire acor re:uirea a centinuous fire watch. The Centrol Room Supervisor initiated i=ediate action to fully shut the fire c Or.
The cause of :nis event was cue :: :ers:nnel error. The A0 as a are tnat tne IFCS was removed fr:m service. HowcVer, One A0 ha: tne misc nce:tiCn that a centinuous fire watCn and a c:ntinuous r:ving fire aaten ere the same.
On January 6, 1938, a Management Feview E arc.weeting, cnairea by tne vice President, Nuclear 0: era:1:ns c nvenea t: review tnis event.
The following c:rrective ac N n aill te taken as a result of tnis event:
1.
ine A0 involved in the event attenced tne MRS and will brief eacn snif t Of tnis event in: lessens learne:.
2.
A copy of tnis re: Ort ai'l te : laced in 0:eratio N required reading.
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10 training ill te revie ea an: u: grace: if required.
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. Attachment I to Dr. J. Nelson Grace Letter March 16, 1988 Page 2 of 4
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Virgil C. Sunner Nuclear Station o is Io ti o l3l9IS 0 I 3!0 l-l0 q0 0l2 or 0 l4 a
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PLANI '0 eft'FICATION:
Westinghouse - Pressurizac Water Peactor EOUTPMENT IDENTIFICATION:
Fire Dcor
!!IS-KP Integrated fire System EIIS-I IDENTIFICATION OF M NT:
Failure to imolezent ccm:ensat:ry 5: tion as requirec Oy Technical 5:ecifitations Section 3.7.10. "Fire Rated Assemolies."
(VENT OATE:
12/19/8' REPORT DaTE; 01/2i/88 INITIATING CO M ENT:
inis re crt.as initiatec t, Off-Normal Occurrence Numoer 87-112.
C_giD, ITIC95 N IOC TO EVE NT :
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1 DEStRTATION OF EVENT:
At accroxim nely 0810 hours0.00938 days <br />0.225 hours <br />0.00134 weeks <br />3.08205e-4 months <br />, Decemoer 20, 1987, the Integratec Fire Computer System (IFCS).as removec from service. C ::ensatory action was initiated a recuirec by the l
i Technical Scecifications.
At a;;roximately 2:00 hours, Decem er 29, 1997, ar. Auxiliary 0; erat:r was making nis r:wncs and entered the Penetration Area (PA) througn Fira Door PA-201.
At the time, thermocouples had been located at various lccations within tne PA to monitor temperatures and th; wires ran under PA-201 to a ret:rcer.
the passage of the wires tnrougn it and a caution anen closing the coor.A note had been c i
Auxiliary Operator was exiting tne area, he noted that some of the wires were crimoing As the from catening on the acer base.
damage the wires it ae closed the c00r all the way.Ine Auxiliary Operator as concerneo l
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- ressure across tne cocr. c
- oleta ci:sure of the acer recuirec more inan normal force.)
As sucn. tn9 Auxiliary Operat0r Opticrec to close tne coor against tne laten and note
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canau,mn this c0nditi0n On tne log. At ac;reximately 2240 hours0.0259 days <br />0.622 hours <br />0.0037 weeks <br />8.5232e-4 months <br />, the Control Room Supervisor noted the c;ncition, 'erifiec tnat tne fire c0or was not fully closed by questioning the Auxiliary Operator and tc0k immec i att: acti0n to fully close the fire door.
CAUSE OF EVENT:
Tne cause of this event aas cue to :ersonnel error (0:erations Personnel). During the pre-snift meeting, it aos icentifie: that the IFCS.as off-lint and ccmcensctory action was in o' ace. When the Auxiliary 0;erator a.0ted that fully cicsing the fire 00er may 1amage tne tnermoccuole ires anc 0;ti0nec t; only cl0se the dcor against the latch, ne did n0 thin < that any acciticnal action aas required. The Auxiliary Operator nr.d the misc;nceptien tnat a continu0us fire watcn sna a centinuous reving fire waten were the f.ame anc that ro accitional action aos re:uired other than noting tne condition on the 109 ANALYSIS OF EVENT:
Tne censecuences cue to this event aere minimal. Although the fire coor was not fully latchec, being closea against the laten alle.ed the fire door to functicri as a fire break. In acciticn, time curaticn of this c:ncitien as only one hour ard forty minutes.
Inis report is ceifig submittec pursuant to the requirements of 10CFR50.73(a)(2)(1).
CCEPECTIVE ACTION:
On January 6, '388, a Management Reviea-scarc (MRB) Meeting, enaired by the Vice Presinent Nuclear Operat*:ns as c nvenec :: reviea inis event. At a result of the MRB meeting, tne follcaing corrective acti0ns aill be taken:
1.
The Auxiliary Operator involvec in the event attended the MRB am will brief each snift en tne event and lessons learnea. (To be completed by February 15,1988.)
- C0f7LETED***
1 2.
f c0py of this report aill be placed in Operations required reaaing. (To be completec by Maren 15,1988.)
- COMPLETED ****
3.
Auxiliary Operator fire protection trainino will te revie ea ar.d upgrade if require:. (To be ccmoletec ey Marct: 15, 1988. ) * ** COMPLETED ***
4 Expedite the implementation of accitionel personnel that will be trained by the Fire Protecti0n Coorainator in tne cuties anc resconsibilities of Fire Protection to cualify tnem for the ocsition cf Fire Protection Shif t leaders and to serve ss a i
single :cint Of contact fer fire related matters. (This item was identified in LER
$7-018, catec August 27, 1987, ana is seneduled to be completea by the end of the I
first cuarter 1988.)
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Attachment I to Dr. J. Nelson Grace Letter
' March 16, 1988 j
Page 4 of 4 i
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At approximately 0810 hours0.00938 days <br />0.225 hours <br />0.00134 weeks <br />3.08205e-4 months <br />, Decemoer 29, 1987, the Integrated Fire Computer System (IFCS) was removed from service. A fire watch patrol was established and the fire watch log in the Fire Service System Operating Proceaure (50P-509) was utilized to document the fire watch patrol. At approximately 2110 hours0.0244 days <br />0.586 hours <br />0.00349 weeks <br />8.02855e-4 months <br />, a detailed review of the fire watch patrol log by the Fire Protection Coordinator revealed that four rooms were not listed.
Im.ediate action was taken to establit,h roving patrols in these rocms and to correct the fire watch log.
The event was caused by an inadequate Fire Service System Operating Procedure, SOP-509.
On January 6, 1988, a Management Review Board Meeting chaired by the Vice President.
Nuclear Operations, convened to review this event.
The following corrective actions were determined to address immediate concerns:
1.
The system operating pocedure for fire service (50P-509) was reviewed against the Technical Specifications in order to provide assurance that there were no further discrepancies.
2.
The provision of fire protection shift leaders (officers) as referenced in LER 87-018 is on schedule to meet the Maren 31, 1988 cemitment date. The addition of these fire protection officers will provide aaded attention to the daily fire protection activities and allow single point accountability regarding fire protection. The fire protection officers are currently undergoing site specifi,C
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. Attachment II to Dr. J. fielson Grace Letter Marr'. 16, 198d Page 2 of 3 i
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Virgil C. Sumer Nuclear Station oisto M o 131911617 013l1 010 O!2 0F 0 l 1_
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Westinghouse - Pressurized Water Reactor E0VIPMENT IDENTIFICATION:
Fire Service Syttem EIIS-KP IDENTIFICATION OF EVENT:
The Limiting Condition for Operation in Technical Specifications Section 3.3.3.7, "Fire Detection Instrumentation," was exceeded when the fire watch patrol failed to inspect four rooms because of an inadequate procedure.
EVENT DATE:
12/29/87 REPORT DATE:
01/28/88 This reDort was initiated by Off-Normal Occurrence Number 87-113.
PREVIOUS SIMILAR EVENTS:
LER 87-002, dated Maren 18, 1987 LER 87-008, dated June 25, 1987 LER 87-018, dated August 27, 1987 i
LER 87-030, dated January 21, 1990 CONDITIONS W OR TO EVENT:
Mode 1 - Reactor P0wer 100%
DESCRIPTION OF EVENT:
At approximately 0810 hours0.00938 days <br />0.225 hours <br />0.00134 weeks <br />3.08205e-4 months <br />. Decemoer 29, 1987, !ne Integrated Fire Computer System (IFCS) was removed frem service. A fire natch patrol was establisted as part of compensatory action required by the Technical Specifications. ATTACHMENT Vl!!, the firt watch log, of the Fire Sertice System Operating Pro 0 dure (50P-509) was uttlired to document the fire watch pa'rol. The fire watch log was divided into two sections 1
discriminating between raCation control areas (RCA) and non-radiation control areas in order to facilitate inspection of the rooms, At approximately 1900 hours0.022 days <br />0.528 hours <br />0.00314 weeks <br />7.2295e-4 months <br />, the Fire Pretect'on Coordinator was notified that several rooms within the RCA on the 412' elevation of the Control Builolng wer6 on the f(re watch patrol for the non-RCA rooms. At this time the Fire Protection Coordinat.or conducteo a detailed review of the fire watch log to provide cssurance that no more d 4crepancieG existed. During the review, it was discovered that four rooms required to be inspected were Nt listed on the fire watch log because of typographical errors. Immediate action was titen to add these rooms to the fire watch log. A procedure change was made to SOP-509 to correct the errors.
The affected rooms were FH 63-01 and FH 12-01 in the fuel Handling Building along with EPAA 36-02 cnd EPAA 12-02 in the East Penetration Access Area, goo.. m.
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, Attadhnent 11 to Dr. J. Nelson Grace Letter March 15, 1988 Page 3 of 3 Ulbw u i veuan aiovwoav co==wo=
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CA'JSE OF EVENT:
The event aas caused by an inadequate Fire Service System Operating Procedure, SOP-509.
Typugraphical errors existed within 50P-509 that eliminated four rooms from the fire watch log attachment.
ANALYSIS OF EVENT:
The consecuences due to this event were minimal.
The duration of this event was thirteen hours.
In addition to this event, the inadequate fire watch log was also used on Cecemoer i
16, 1987 and Decemoer 17, 1987 for a duration of 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> and 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> respectively.
This report is being submitted pursuant to the requirements of 10CFR50.73(a)(2)(i).
CORRECTIVE ACTION:
On January 6,1988, a Management Review Board (MRB) Meeting, chaired by the Vice President, Nuclear Operations was convened to review this event.
As a result of the MRB meeting, the following corrective actions were determined to address immediate concerns:
- 1. The system operating procedure for fire service (SCP-509) was reviewed against the Technical Specifications in orcer to provide assurance that there were no further discrepancies.
No additional discrepancies were identified.
- 2. The provision of fire protection shift leaders (officers) as referenced in LER 87-018 is on scneaule to meet the Maren 31, 1998 comitment date. The addition of these fire protection officers will provide added attention to the daily fire protection activities and allow single point accountability regarding fire protection. The fire protection officers are currently uncergoing site specific training.
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