ML20210R550

Ack Receipt of 990707 Response to NCVs Identified on 990607 Re Activities Conducted at VC Summer.Informs That After Consideration of Basis for Denial of NCV 50-395/99-03, Concluded,For Reasons Stated,That NCV Occurred

ML20210R550
Person / Time
Site:	Summer
Issue date:	08/05/1999
From:	Plisco L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Gabe Taylor SOUTH CAROLINA ELECTRIC & GAS CO.
References
50-395-99-03, EA-99-204, NUDOCS 9908170138
Download: ML20210R550 (10)

See also: IR 05000395/1999003

Text

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August 5, 1999

EA 99-204

South Carolina Electric & Gas Company

ATTN: Mr. Gary J. Taylor

Vice President, Nuclear Operations

Virgil C. Summer Nuclear Station

P. O. Box 88 -

- Jenkinsville, SC 29065

Dear Mr. Taylor:

SUBJECT: NRC INTEGRATED INSPECTION REPORT NO. 50-395/99-03

Thank you for your response of July 7,1999, to our Non-Cited Violations (NCVs) identified on

. June 7,1999, concoming activities conducted at your facility, in your response, you denied

NCV 50-395/99003-01, " failure to remove loose debris from the reactor building," and requested

reclassification of NCV 50-395/99003-06, " failure to properly control access to a high radiation

area."

After careful consideration of the basis for your denial of NCV 50-395/99003-01, we have

concluded, for the reasons presented in the enclosure to this letter, that the NCV occurred as

stated in NRC Integrated Inspection Report No. 50-395/99-03.

NCV 50-395/99003-06 stated that you failed to properly control access to a high radiation area

in accordance with 10 CFR 20.1601, " Control of access to high radiation areas." You did not

deny the violation, but rather stated that the violation should be cited against 10 CFR 20.1501

since Health Physics did not perform surveys, reasonable under the circumstances, to evaluate

the extent of radiation levels and the potential radiological hazards that could be present during

fuel movement.

We carefully reviewed the material you provided in support of your request for reclassification

and material that was gathered during the onsite inspection. The reviewed material included

Condition Evaluation Report (CER) 99-0520, the Regulatory Assessment of CER 99-0520, and

Technical Specification 6.12, "High Radiation Areas." We agree that failure to do an adequate

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survey was an issue in this event; however, we have elected to focus on the control of the high

radiation area in our regulatory action because that control represents a more direct risk for an

individual.

We disagree with your position that extreme measures would have been needed to access the

drained pit area.' ' A Radiation Work Permit already existed for entry into the pit and it would not

have been difficult for Health Physics Technicians and other workers to utilize it again.

. Additionally, we do not view a ladder located just a few feet below the accessible floor level as a

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situation requiring extreme measures to gain access to the drained pit. An extreme measure

could have existed if the ladder had not been in the pit.

Therefore, it is our conclusion that your request for reclassification was not supported and that

NCV 50-395/99003-06 will remain as stated in NRC Integrated Inspection Report No.

50-395/99-03.

We appreciate your cooperation in this matter.

Sincerely,

Orig signed by Charles A. Casto for

Loren R. Plisco, Director

Division of Reactor Projects

Docket No.: 50-395

License No.: NPF-12

Enclosure:

Evaluations and Conclusion (NCV 50-395/99003-01)

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SCE&G: 3

cc w/ encl:

R. J. White

Nuclear Coordinator (Mail Code 802)

' S.C. Public Service Authority

Virgil C. Summer Nuclear Station -

P. O. Box 88

Jenkinsville, SC 29065

' J. B. Knotts, Jr., Esq.

Winston and Strawn

1400 L Street, NW

Washington, D. C. 20005-3502

Chairman

Fairfield County Council

P. O. Box 60 -

Winnsboro, SC 29180

.

Virgil R. Autry,' Director

Radioactive Waste Management l

Bureau of Solid and Hazardous

Waste Management -

S, C. Department of Health

.

and Environmental Control-

2600 Bull Street

Columbia, SC 29201

- R. M, Fowlkes, Manager

Operations (Mail Code 303)

South Carolina Electric & Gas Company

Virgil C. Summer Nuclear Station

P-. O. Box 88

Jenkinsville, SC 20065

April Rice, Manager

Nuclear Licensing & Operating

l

Experience (Mail Code 830)

Virgil C. Summer Nuclear Station

j

P. O. Box 88

Jenkinsville;SC 29065

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EVALUATIONS AND CONCLUSION (NCV 50-395/99003-01)

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On June 7,1999, a Non-Cited Violation (NCV) was identified during a routine NRC inspection for

failure to adequately remove loose debris from the reactor building in accordance with Technical

Specification surveillance requirement 4.5.3.1.1 South Carolina Electric & Gas Company

responded to the NCV on July 7,1999. The licensee contends that the amount of debris found

by the inspectors represented a negligible challenge to Emergency Core Cooling System

(ECCS) sump performance and therefore performance of the surveillance requirement was

ac; equate. The NRC's evaluations and conclusion regarding the licensee's arguments are as

follows:

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Restatement of NCV 50-395/99003-01

On May 7, the inspectors conducted an inspection of containment to assess mMerial

condition and general area housekeeping prior to reactor startup. At the time of this

inspection the licensee had completed a reactor building closeout visual inspection per

Quality Systems Procedure (QSP)-208, ' Inspection of Housekeeping and items in ,

Storage," Revision 9 and had entered Mode 4. In general, the material condition of the - l

! containment was satisfactory. However, the inspectors identified debris and tools, such

as a rubber shoe, a plastic bag, a cloth booty and other small items within accessible

areas of containment. The debris identified by the inspectors was subsequently

removed from the reactor building. The inspectors estimated the total amount of debris

to be approximately two square feet. The inspectors were informed by engineering

personnel that the transportable debris could block approximately two percent of one

train's sump suction screen and therefore this debris represented a negligible challenge j

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to sump performance. The inspectors agreed with this assessment.

TS Surveillance Requirement 4.5.3.1, " Emergency Core Cooling Systems," which is

, applicable for Mode 4, requires that the licensee perform a visual inspection per TS , 4.5.2.c, to verify that no loose debris is present in the reactor building. Section 8.2.1.B of  !

QSP-208, which implements the requirements of surveillance requirement 4.5.2.c, '

requires, in part, that the licensee identify and correct reactor building housekeeping

discrepancies prior to reactor building closeout. The failure to adequately remove loose

debris from the reactor building is a violation of TS 4.5.3.1. This Severity Level IV  ;

violation is being treated as a Non-Cited Violation (NCV), consistent with Appendix C of -

the NRC Enforcement Policy. This violation is in the licensee's corrective action program

as CER 99-0748 and is identified as NCV 50-395/99003-01.

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Summary of Licensee's Response to NCV 50-395/99003-01 4

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The licensee contends the following:

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The purpose of surveillance requirement 4.5.2.c is to ensure that the required number of ,

trains of the Emergency Core Cooling System (ECCS) are operable and that there is not  !

sufficient debris inside the reactor building that can be transported to the sumps and

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degrade ECCS performance to a level that its design basis functions can no longer be

performed.

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The design of the ECCS sumps complies with the recommendations of Regulatory Guide

(RG) 1.82, " Water Sources for Long-Term Recirculation Cooling Following a Loss of

Coolant Accident," Revision 0, dated 6/74. Under the recommendations of this RG,

cump blockage from debris up to 50% is assumed. The design of the Virgil C. Summer

. Nuclear Station (VCSNS) sumps was verified as adequate for the 50% blockage criteria

by scale model testing conducted at the Alden Research Laboratory during the initial

plant licensing phase. -

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The potential sources of LOCA generated debris were also investigated during the

original plant licensing phase. Section 6.3.2.6.1 of the VCSNS FSAR describes the

potential sources of LOCA generated and other types of debris present inside the reactor

building. The NRC reviewed this investigation and concluded that the sumps could

perform their design function considering the debris blockage criteria of RG 1.82.

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Subsequent to the NRC inspection of the reactor building, Engineering personnel ,

performed an evaluation and determined that the transportable debris found inside the j

reactor building could block approximately two percent of one train's sump suction

screen and that this represented a negligible challenge to ECCS sump performance.

The inspectors agreed with this assessment. Therefore, it is SCE&G's position that the

- Technical Specification surveillance was adequate.

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During conversations between plant staff and the inspectors, it was inferred that the ease

in which the debris was found was a contributing factor to issuance of the violation. It is

SCE&G's position that, although the presence of debris in the reactor building after

establishment of containment integrity was undesirable and showed lack of attention to

detail, the ease with which the debris was located is not a valid basis for a violation.

NRC Evaluation of Licensee's Response

The NRC staff has carefully reviewed your response and considered the following items:

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Technical Specification surveillance requirement (SR) 4.5.2.c, which is referenced by TS 4.5.3.1, requires, in part, that the ECCS subsystem be demonstrated operable *by a

visual inspection which verifies that no loose debris (rags, trash, clothing, etc.) is present j

in the reactor building which could be transported to the RHR [ residual heat removal] and  !

Spray Recirculation sumps and cause restriction of the pump suctions during LOCA

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conditions." Contrary to your position that the purpose of SR 4.5.2.c is to ensure debris '

is not present that could prevent the ECCS sumps from performing their design basis

function, the SR does not reference a quantity of debris relative to ECCS sumps being  !

able to perform their function. The NRC recognizes that minor debris such as tie wraps, '

small pieces of paper, etc., which remained in the reactor building following the visual

inspection of SR 4.5.2.c would not necessarily cause the SR to be viewed as

inadequate. However, the NRC considers that the type ofloose debris found by the

inspectors (e.g. rubber shoe, plastic bag, and cloth booty) was not minor and could

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reasonably be transported to the RHR and Spray Recirculation sumps and cause

restriction of the ECCS pump suctions.

_ Our interpretation of SR 4.5.2.c requirements is consistent with your response to NRC

Bulletin 93-02," Debris Plugging of Emergency Core Cooling Suction Strainers." In this

Bulletin, the NRC requested licensees to identify temporary sources of fibrous materials

which are installed or stored in containment. In your June 10,1993, response to Bulletin

93-02, you stated that "all temporary material used during an outage inside containment

is removed so as to not reduce the performance of the emergency sumps." Your letter

further stated that the " Quality Control organization performs a reactor building closeout

inspection (each outage) which assures miscellaneous equipment / debris is removed

from the building." We believe that your response to Bulletin 93-02 is consistent with our

interpretation that the intent of SR 4.5.2.c is to remove all loose debris from the reactor

building.

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Your engineering evaluation concluded that the transportable debris found in the reactor

building could block approximately two percent of one train's sump suction screen.

Although the NRC agrees that a two percent blockage of the ECCS sump represents a

negligible challenge to sump performance, your response did not consider the aggregate

effects of the debris identified by the inspectors with other potential sources of debris in

the reactor building. VCSNS Final Safety Analysis Report (FSAR) section 6.3.2.6.1,

" Containment Sump and its Effect on Long Term Cooling Following a LOCA," discusses

other potential sources of debris within the reactor building. FSAR section 6.3.2.6.1

does not identify loose debris of the type identified by the inspectors as potential

blockage sources for the ECCS sumps. Therefore, this debris represents an additional

two percent blockage beyond the sump debris loading assumed in the safety analysis.

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The NRC considered the quantity of loose debris in the reactor building, including the

potential for ECCS sump screen blockage, when evaluating the severity level of the

violation. Although you failed to comply with TS 4.5.2.c, the NRC agrees that the

additional challenge created by the loose debris would not result in the ECCS system

being unable to perform its intended function. Therefore, based on guidance contained

in NUREG-1600, Rev.1, " General Statement of Policy and Procedure for NRC

Enforcement Actions," the NRC characterized the violation at a Severity Level IV.

Violations at Severity Level IV, the least significant of the four severity levels established

in the NRC Enforcement Policy, involve noncompliances with NRC requirements for

which the associated risks are not significant. Consistent with Appendix C of the

Enforcement Policy, the NRC treated this Severity Level IV violation as an NCV.

With regard to your comment concerning the ease in which the debris was found and the

inference that this was'a contributing factor to the issuance of the violation, the NRC did

consider the fact that the debris was located within readily accessible areas of the

reactor building. Based on the type of debris and its location in readily accessible areas,

it is reasonable to believe that the debris could have been transported to the reactor

building sump. In dispositioning this violation, the NRC considered the ease of the

inspectors' identification in the evaluation of the accessibility and transportability of the 1

loose debris.' I

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NRC Conclusion

For the above reasons, the NRC staff concludes that the NCV 50-396/99003-01, " failure to

remove loose debris from the reactor building," occurred as stated,

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