ML20198N849

Notice of Violation from Insp on 981011-1121.Violation Noted:On 980715,operations Personnel Authorized Maint Activities on ECCS Accumulators a & C Outlet Isolation Valve Breakers Without Recognizing Sys Would Become Inoperable

ML20198N849
Person / Time
Site:	Summer
Issue date:	12/21/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20198N841	List: IR 05000395/1998009 ML20198N834 ML20198N849
References
50-395-98-09, 50-395-98-9, NUDOCS 9901060230
Download: ML20198N849 (2)

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NOTICE OF VIOLATION South Carolina Electric & Gas Company Docket No. 50-395 V. C. Summer Nuclear Station License No. NPF-12 ,

l During an NRC inspection conducted on Octobt 11 through November 21,1998, a violation of NRC requirements was identaied. in accordance with the " General Statement of Policy and

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Procedures for NRC Enforcement Actions," NUREG-1600, the violation is listed below:

Technical Specification (TS) 6.8.1.a requires that written procedures be implemented l covering the activities recommended in Appendix "A" of Regulatory Guide (RG) 1.33, j Revision (Rev.) 2, February,1978. RG 1.33, Appendix "A", paragraph 1.h identifies log i entries, record retention, and review procedures as typical safety-related activities that j l should be covered by written procedures. j 1 '

Station Administrative Procedure SAP-204," Operating Logs and Records," Rev 7, paragraph 6.1.6 states that the shift supervisor is ultimately responsible for determining which actions and information will be entered in the Station Log Book and identifies entries that shall be made. Paragraph 6.1.6 and Substep 6.1.6.C.20 of SAP-204 state that a Station Log Book entry shall be made for any LCO action entry not covered by a removal and restoration (R&R),

Contrary to the above:

1. On July 15,1998, operations personnel authorized maintenance activities on ECCS Accumulators A and C outlet isolation valve breakers without recognizing the work would render the system inoperable due to being outside of the TS surveilled conditions. The work was controlled under a maintenance work order, 4 without the completion of a removal and restoration form. The shift supervisor failed to document entry into the applicable TS LCO Action statement for TS 3.5.1, " Accumulators" in the Station Log Book.

2. On January 26,1998, operations personnel authorized maintenance activities on i the Charging /High Head Safety injection Cross-connect valve 81338-0-CS without recognizing the work rendered the system inoperable due to being outside of the TS surveilled conditions. The work was controlled under a i

maintenance work order, without the completion of a removal and restoration form. The shift supervisor failed to document entry into the applicable TS LCO Action statement for TS 3.5.2, " Emergency Core Cooling Systems Subsystems -

Tavg greater than or equal to 350 degrees Fahrenheit"in the Station Log Book.

This is a Severity Level IV violation (Supplement 1).

The NRC has concluded that information regarding the reason for the violation, the corrective l actions taken and planned to correct the violation and prevent recurrence and the date when i full compliance will be achieved is already adequately addressed on the docket in NRC l Integrated Inspection Report No. 50-395/98-09. However, you are required to submit a written l statement or explanation pursuant to 10 CFR 2.201 if the description therein does not i

Enclosure 1 9901060230 981221 PDR ADOCK 05000395 G PDR

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accurately reflect your corrective actions or your position. In that case, or if you choose to respond, clearly mark your response as a " Reply to a Notice of Violation," and send it to the I U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C.  ;

20555 with a copy to the Regional Administrator, Region 11, and a copy to the NRC Resident l Inspector at the V. C. Summer Nuclear Station, within 30 days of the date of the letter l

, transmitting this Notice of Violation.

l If you contest this enforcement action, you should also provide a copy of your response, with the basis for your denial, to the Director, Office of Enforcement, United States Nuclear  ;

Regulatory Commission, Washington, DC 20555-0001. l If you choose to provide a response, the response will be placed in the NRC Public Document Room (PDR). To the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction.

In accordance with 10 CFR 19.11, you may be required to post this Notice within two working days.

Dated this 21st day of December 1998  ;

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UNITED STATES

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n NUCLEAR REGULATORY COMMISSION WASHINGTON. D.C. Ogges 40M

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• • • • • September 10, 1998 MEMORANDUM TO: Geoffrey E. Grant, Director  !

Division of Reactor Projects  !

Region III  !

FROM:

Elinor G. Adensam, Acting Director Lui g c r - --* 0 % =

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Division of Reactor Projects III/IV i Office of Nuclear Reactor Regulation

SUBJECT:

TIA 98-004 - LACK OF ALLOWED OUTAGE TIME GUIDANCE FOR INOPERABLE HAZARD PROTECTION EQUIPMENT - DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1 (TAC NO. MA1667)

By memorandum dated April 23, 1998, you forwarded the subject request for i technical assistance. The Plant Systems Branch (SPLB), with assistance from I the Generic Issues and Environmental Projects Branch (PGEB) and the Technical Specifications Branch (TSB), has reviewed your request, as documented below.

A copy of your memorandum is attached. This letter and attachment are also being forwarded to the other regional offices.

You requested NRR assistance to determine hether additional industry and/or i

. inspector guidance is needed for what constitutes acceptable allowed outage times (A0Ts) for inoperable hazard protection equipment. This hazard '

protection equipment includes barriers, and doors that act as barriers, for protection against floods, high energy line breaks (HELBs), and other i potential hazards.

At Davis-Besse, the Resident Inspectors (RIs) noted that the access door from I the turbine deck to the main control room had been blocked open for a 5-hour period because of ongoing work associated with the security computer system.  !

The RIs questioned the acceptability of blocking it open since the door, when closed, functioned to protect operators and equipment in the control room from a main steam line break (MSLB) for main steam lines located near the control room doors. The licensee responded that an intra-company memorandum had been implemented permitting the door to be blocked open for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

According to the RIs, that memo, which included an engineering evaluation stating that the 72-hour A0T was acceptable, was originally intended for doors that provided access to equipment rooms housing one train of safety equipment.

However, the RIs identified that inherent in the licensee's analysis was that the other train of equipment was unaffected.

The inspectors were concerned that with the door open, control room operators, and both tr:ains of equipment required for safe plant operation and shutdown,

'would be vulnerable to a HELB while the A0T was in effect. However, the RIs found a lack of NRC guidance relating to an acceptable A0T for inoperable

. hazard protection equipment (barriers) such as the doors for the control room.

ENCLOSURE 4

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G. Grant ,

The staff agrees with the RIs' assessment of the licensee's response and the inappropriate application of the 72-hour A0T to the control room door. The A0Ts for barriers are presently specified by the equipment which the barriers protect. For example, if a barrier (including a door acting as a barrier) is removed, opened for more than routine ingress and egress, or otherwise made incapable of performing its design safety function, the equipment protected by the barrier should be declared inoperable and the A0T identified in the appropriate Limiting Condition for Operation (LCO) specified in the technical specifications (TSs) would apply. If there is no corresponding LCO, or if the barrier protects redundant trains of equipment, then the plant would be outside its design basis and an operability determination would have to be made, including a 50.59 evaluation of the change. Generally, adequate compensatory measures (such as removing the hazard, providing a temporary barrier, or reliance on operator action to restore the barrier if possible) would have to be put in place in order to determine that an unreviewed safety question does not exist if the barrier affects more than one train. This is because, with the barrier removed /open, an event such as a HELB could result in the inability to safely shut down the plant even without any additional single active failures. Where the barrier only affects ene train, the plant should still be capable of responding to any design basis event during the A0T provided no additional single active failures occur. Therefore, the plant is still considered to be operating within its licensing and design basis for the duration of the A0T.

Protected equipment for temporarily removed barriers may not have to be declared inoperable if justifiable compensatory measures have been taken and the licensee has determined that the compensatory measures can provide assurance that the degraded equipment in combination with the compensatory measures can perform the required safety functions. For the case of the Davis-Besse equipment, the control room door not only acts as a barrier to protect against the dynamic forces and environmental conditions created by a HELB, but also acts as a part of the control room pressure boundary. When the door is not capable of performing its pressure boundary function, the control room emergency ventilation system should be declared inoperable and the appropriate TS action statement should be entered. For the control room door's function of protection against a HELB at Davis-Besse, there are probably no adequate compensatory measures that could be taken (short of isolating the. main steam lines) to provide a similar level of protection to the control room personnel and equipment in the event of a MSLB. Because of the resultirg environment (possibly disabling the operator) and the rapidity of the blowdown, operator action cannot be relied upon to close the door.

Therefore, if the control room door is determined to be inoperable or incapable of protecting against a design basis MSLB, then the plant should enter any applicable LC0(s). In addition, if the plant is outside its design basis, appropriate corrective action should be taken.

In addition to licensee determinations of continued operability with the planned use of temporarily degraded equipment, a licensee should assess the planned temporary change to the plant in accordance with the requirements of

, 10 CFR 50.59. In accordance with established industry guidance (NEI 96-07,

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. G. Grant

Revision 1, is the present indu:try standard), a licensee should evaluate any i temporary change to the facility to determine if an unreviewed safety question l

exists. The established industry guidance suggests that licensees evaluate all temporary modifications involving temporary blocks and bypasses, or temporary supports or equipment. If the licensee review determines that the J planned use of temporarily degraded equipment involves an unreviewed safety question, the licensee must obtain NRC review and approval before the temporary modification is implemented.

With respect to additional staff guidance on a generic basis, the staff, in s

SECY-97-287, " Final Regulatory Guidance on Risk-informed Regulation Policy

Issues," proposed to undertake an assessment of acceptable guidelines for temporary plant changes. If the development of such guidelines were to take place, the guidelines would be provided in a future revision to Regulatory Guide 1.174 (Draft Guide DG-1061), "An Approach For Using Probabilistic Risk Assessment In Risk-Informed Decisions On Plant-Specific Changes To The Current j licensing Basis." In the meantime, tamporary changes such as barrier removal, tsithout declaring protected equipmant inoperable, should be evaluated in accordance with the NE! guidance. If the protected equipment is declared inoperable, any applicable TS Action Statements (and allowed outage time) for the inoperable equipment would apply.

If you have any questions regarding this issue, please contact Allen Hansen of my staff at (301) 415-1390 or William LeFave, SPLB, at (301) 415-3285.

Attachment:

As stated cc w/att: C. Hehl, RI L..Plisco, RII T. Gwynn, RIV l

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