ML20207G396
| ML20207G396 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 08/17/1988 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Bradham O SOUTH CAROLINA ELECTRIC & GAS CO. |
| Shared Package | |
| ML20207G403 | List: |
| References | |
| EA-88-151, NUDOCS 8808240110 | |
| Download: ML20207G396 (3) | |
See also: IR 05000395/1988013
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NUCLEAR REGULATORY COMMissl0N
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AUG 17 $88
Docket No. 50-395
License No. NPF-12
EA 88-151
South Carolina Electric and Gas Company
ATTN: Mr. O. S. Bradham, Vice President
Nuclear Operations
Post Office Box 88
Jenkinsville, South Carolina 29065
Gentlemen:
SUBJECT: NOTICE OF VIOLATION
(NRC INSPECTION REPORT NO. 50-395/88-13)
This refers to the Nuclear Regulatory Comission (NRC) inspection conducted at
the V. C. Sumer Plant on May 1 - 31, 1988.
The inspection included a review
of the circumstance associated with the degraded service water flow to the
reactor building cooling units following a reactor trip on May 12, 1988.
The
report documenting this inspection was sent to you by letter dated June 16,
1988. As a result of this inspection, a significant failure to comply with
regulatory requirements was identified, and accordingly, NRC concerns relative
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to the inspection findings were discussed in an Enforcement Conference held on
June 24, 1988.
The letter summarizing this Conference was sent to you on
July 22, 1988.
The violation described in the enclosed Notice of Violation (Notice) involved a
failure by your operations staff to identify degraded service water flow to the
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reactor building cooling units (RBCUs).
This problem should have been identified
from a post trip review of plant performance data available to the operations
staff following the reactor trip of May 12, 1988.
However, because of- the
inadequate post trip review performed, this problem was not promptly identified
and the reactor was subsequently restarted on May 12, 1988, with the degraded
service water flow to the RBCUs.
On May 16, 1988, the Independent Safety Evaluation Group conducted an
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independent review of the reactor trip data package and subsequently identified
the degraded service water flow problem.
Consequently, imediate corrective
action was initiated.
Nevertheless, the. reactor was operated fu approximately
90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> without the operations staff being aware that service water flow to
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the RBCUs was degraded. A more thorough initial review of the operational data
should have led to the determination thet service water flew was less than
required.
The performance data was available, but it is evident that the
repetitive columnar format of the data package contributed to the degraded
service water flow data being ovar' coked dumtig the initial review.
Your staff
has shown initiative addressin
- ta fc N t prob'em by adding gra hics
enhancement to the existing pr
3ther .oitcern nade evident as a result
of this event is the approact
. tons staff to the control room
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South Carolina Electric
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annunciators immediately following the reactor trip.
The trip caused over
85 annunciators to activate and two of those annunciators should have indicated
possible problems with service water.
It is apparent that as the operations
staff were clearing the annunciators, they were not alert for problem indica-
tions and were routinely resetting systems which resulted in a missed oppor-
tunity to detect the service water degradation problem.
Management should
address the issue of the operations staff being sensitive to system indicators
and ensure that before any system configuration change or event termination that
they are fully aware of plant conditions.
The NRC has emphasized reviewing reactor trip packages and surveillance data to
assure that components actuate properly and function within the required
parameters.
Furthermore, degraded flow of critical safety systems due to clams,
corbicula, or microbiological induced corrosion has also been the subject of
NRC bulletins and notices transmitted to power reactor licensees.
The NRC is encouraged by your consideration of the possibility of cdding flush
connections on those lines subject to biofouling.
The capability of periodically
flushing lines would expand your biofouling protection measures, especially in
light of your known susceptibility to that problem because of service water
pond clam infestation.
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In accordance with the "General Statement of Policy and Procedure for NRC
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Enforcement Actions," 10 CFR Part 2. Appendix C (1988), the violation described
in the enclosed Notice has been classified as a Severity t.evel !!! violation.
Normally, a civil penalty is considered for a Severity Level III violation.
However, after consultation with the Director. Office of Enforcement, and the
Deputy Executive Director for Regional Operations, I have decided that a civil
penalty will not be proposed in this case because of your actions, particularly
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with regard to improving your post-trip review.
Also, considered were the
actions of your independent review group which identified the problem although
it was missed during the initial post-trip review.
Finally, your prompt
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corrective action and good past performance, along with an increasingly
aggressive approach toward problem identification and resolution contributed
to no civil penalty being issued in this matter.
You are required to respond to this letter and the enclosed Notice and should
follow the instructions specified therein when preparing your response,
in
your response, you should document the specific actions taken and any additional
actions you plan to prevent recurrence.
Your response should describe those
particular actions taken or planned to improve the effectiveness of your
management control program.
After reviewing your response to this Notice,
including your proposed corrective actions and the results of future
inspections, the NRC will determine whether further NRC enforcement action
is necessary to ensure compliance with NRC regulatory requirements.
In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2,
Title 10. Code of Federal Regulations, a copy of this letter and its enclosure
will be placed in the NRC Public Document Room,
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South Carolina Electric
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The responses directed by this letter and its enclosure are not subject to the
clearance procedures of the Office of Management and Budget as required by the
Paperwork Reduction Act of 1980, Pub. L. No.96-511.
Should you have any questions concerning this letter, please contact us.
Sincerely,
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J. Nelson Grace
Regional Administrator
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Enclosure:
cc w/ enc 1:
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J. L. Skolds, General Manager
Nuclear Plant Operations
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J. B. Knotts, Jr.
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Bishop. Cook, Purcell & Reynolds
W. A. Williams, Jr., Technical
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Assistant, Nuclear Operations -
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Santee Cooper
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A. R. Koon, Jr. , Manager
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Nuclear Licensing
R. E. Rainear Executive Vice President,
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South Carolina Public Service Authority
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