ML20215J928
| ML20215J928 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 10/17/1986 |
| From: | Nauman D SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| NUDOCS 8610270251 | |
| Download: ML20215J928 (7) | |
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$ oggna m a cas conipany gn g,aune j) gu,rngag29218 Nuclear Operations SCE&G m..~~,
October 17,1986 Mr. J. M. Taylor Director, Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington,DC 20555
SUBJECT:
Virgil C. Summer Nuclear Station Docket No. 50/395 Operating License No. NPF-12 Response to Notice of Violation and Proposed Imposition of Civil Penalty NRC Inspection Report 86-12
Dear Mr. Taylor:
On September 22,1986, the Nuclear Regulatory Commission (Region 11) issued a Notice of Violation and Proposed Imposition of Civil Penalty for alleged violations of NRC requirements at South Carolina Electric & Gas Company's (SCE&G) Virgil C.
Summer Nuclear Station. SCE&G has thoroughly reviewed and investigated the incidents described in the Notice and, pursuant to 10 CFR 2.201, and is responding to the alleged violations in the enclosed Attachment I.
SCE&G considers this enforcement action very serious and has implemented extensive corrective actions in response to the violation.. As outlined in, SCE&G manngement has focused its attention on long term corrective actions, in addition to corrective actions specific to the violation,in order to preclude any further occurrences of this nature. These actions will enhance training and will improve the overall educational level and professionalism of personnel within the department.
The Licensee is in agreement with the basic facts set forth in the Notice of Violation and will not contest the imposition of Civil Penalty. Enclosed is our check in the amount of fifty thousand dollars ($50,000.00).
3610270251 861017 PDR ADOCK 05000395 G
PDR (E : '
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M r. J. M. Taylor NRC Inspection Repc,c: 36-12 October 17,1986 If there are any further questions or comments, please contact us at your earliest convenience. The undersigned affirms that the statements and matters set forth in this letter and its attachment are true and correct to the best of my knowledge, information, and belief.
Very trul) hts, t
WRH: DAN /dwf I
Attachment c:
O. W. Dixon, J r./T. C. Nichols, Jr.
E. H. Crews, J r.
E. C. Robeds O. S. Bradham D. R. Moore J. G. Connelly, Jr.
W. A. Williams, Jr.
H. R. Denton J. Nelson Grace Group Managers C. A. Price W. T. Frady C. L. Ligon (NSRC)
R. M. Campbell, Jr.
K. E. Nodland R. A. Stough G. O. Percival R. L. Prevatte J. B. Knotts, J r.
Document Management Branch NPCF File 2
i ATTACHMENT I RESPONSE TO NOTICE OF VIOLATION VIOLATION NO. 50-395/86-12,I,11
- 1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION South Carolina Electric & Gas Company (SCE&G) is in agreement with the alleged violation.
i 11.
REASON FOR THE VIOLATION SCE&G attributes this event to personnel error and inadequate procedures. The personnel error was a result of the inadequate understanding of the system design. The operating procedures inadequately addressed the various system configurations which are created by maintenance and modification activities.
Administrative procedures for removal and restoration of equipment were also identified as being inadequate for control of equipment for post-maintenance and modification testing.
On June 12,1986, the licensee identified a condition for which the breaker alignment of the "B" Train Charging / Safety injection (SI) pumps resulted in disabling the pumps from an automatic start under conditions of a Loss of Offsite Power followed by a ' St. Following equipment modification retest activities on June 6,1986, the "B" Charging /S! Pump was capable of performing its intended function, but it had outstanding modification paperwork to be reviewed and signed off for completion of the modification and return of the equipmentto j
operable status. The "B" Charging /S! Pump switch was placed in the pull-to-lock position in order to prevent automatic starting of the pump. The "C" Charging /SI Pump was aligned to the "B" Train and was considered to be the operable pump on that train for the purp(ose of meeting the Technical Specification Limiting Condition for Operation LCO). However,the alignment of the "B" and "C i
Charging /51 Pumps on the "B" Train with the "B" Charging /S! Pump switch in ' he t
pull-to-lock position would have prevented the automatic start of either pump on i
"B" Train under the conditions of Loss of Offsite Power followed by an 51. This design feature was not recognized by the operators and was not procedurally addressed at the time the action was taken to place the "B" Charging /SI Pump switch in pull-to-lock.
On June 10,1986, the "A" Diesel Generator (DG) was removed from service for preventive maintenance. This included the verification of the operability of the "B" Train components in accordance with the Action Statement of Technical Specification LCO 3.8.1.1 item c. Again,it was the operator's understanding that the "C" Chargin,g/SI Pump was the operable pump on "B" Train. Urwer these conditions, the A" and "C" Charging /S! Pumps would have started on an 51 actuation. For a Loss of Offsite Power condition, the Charging /SI Pumps are not required to start automatically. For the situation where an 51 event is followed by a Loss of Offsite Power, both the "A" and "C" Charging /S! Pumps would have automatically started on an Sl; however, following the Loss of Offsite Power, only l
the "C" Pump would have restarted since it was previously running. For the Loss of Offsite Power followed by an 51 condition, no Charging /SI Pumps would have automatically started.
Page 1 of 5
4 ATTACHMENT I-- Continued On June 11,1986, an operator questioned the alignment of the "B" Train Charging /SI Pumps, and following discussions and evaluation by the Shift Supervisor, the "B" Charging /SI Pump breaker was racked out. This alignment would allow the automatic start of the "C" Charging /SI Pump under all the conditions previously discussed.
The consequences to safety for this event were minimal. The Charging /SI Pumps would have functioned per design for all accident scenarios with the exception of a Loss of Offsite Power followed by an 51. However, under these conditions, the "B" or "C" Charging /SI Pumps would have been manually started from the Control Room as part of the operator'simmediate actions. With both the "A" DG and the "B" Train Charging /S! Pumps in the condition that they were in, the Licensee considers this event to be a failure to meet the intentions of both the LCO's for Technical Specifications 3.8.1.1 action item c.1 and 3.5.2 action item a.
Ill.
CORRECTIVE STEPSTAKEN AND RESULTS ACHIEVED The Licensee has implemented the following interim actions untillong term corrective actions have been completed:
1.
The three operators directly involved in placing the "B" Charging /SI Pump switch in the pull-to-lock position on June 6,1986, were relieved of their shift responsibilities and placed in a special three week intensive training program.
This special training program included the following topics:
a.
The first two weeks of training consisted of intensive swing component classroom and simulator training conducted jointly by Training and Technical Services. In addition to their work on the technical aspects of Swing Components, the participants focused attention on the correct implementation of the Removal & Restoration Log, the Station log, and the Shift Turnover Procedure. Also emphasized in this training was the necessity for the operators to approach their job with an inquisitive attitude. To accomplish this objective, training was provided to help them develop effective questioning techniques. The first two weeks was concluded with a comprehensive written, oral, and simulator operating exam.
b.
During the third week of training the operators, through the use of Team Building skills, turned their attention to determining what necessary changes could be made to the Removal & Restoration Log,the Station Log, and Shift Turnover Procedure to preclude such an event from happening again.
c.
Finally the operators developed a lesson plan and student handouts transmitting the knowledge gained during the previous three weeks to all licensed shift operating personnel. The developed lesson plans and student handout materials were submitted to Training and Technical Services for approval prior to use.
2.
Breakers for swing components which are not fully operable (either technically or administratively) are required to be " racked out" Racking out breakers for swing components, when their operability is in question, renders the component totally inoperable and, therefore, alleviates the operator of having to rely on his memory of how swing component logics work.
Page 2 of 5
6 ATTACHMENT I-- Continued 3.
The use of the pull-to-lock feature will be restricted to situations specifically addressed in procedures or emergency situations to prevent equipment from starting or operating. Again, this will alleviate the operator from having to rely on his memory of how swing cornponent logics work.
4.
A moratorium, on design changes for all equipment and systems that could impact on the operability of the equipment required to support plant operations, was put into effect until all outstanding modification requests were reviewed forinclusion of pre-modification planning and post-modification testing requirements. The inclusion of pre-modification planning and post-modification testing into the modification packages outlined information required to support the modification and to expeditiously return the component or system to operability.
5.
The event and interim corrective actions were reviewed with the Operations personnel to assure their awareness of the consequences of this event and to address the short term actions implemented for control of swing components.
IV.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION The following long term corrective actions have been developed in order to preclude any further violation of this type:
1.
Corporate management has reviewed the schedules and commitments of the Nuclear Operations Education and Training (NOE&T) to ensure that plant operators receive the highest priority of the training effort. Based on the review, the following activities are being initiated:
a.
Effective August 25,1986, the Manager, Operations, was transferred to Manager, Nuclear Operations Education and Training; the Associate Manager, Maintenance Services (a former shift supervisor), was promoted to Manager, Operations; the previous Manager, Nuclear Operations Education and Training was promoted to Group Manager, Nuclear Regulatory and Developmental Services. In this promotion he will coordinate the activities for both operator and craft training. These organizational changes are expected to provide new direction and improved performance in both Operations and Training.
b.
SCE&G is entering into an agreement with the University of Maryland to enroll selected Operations and other Nuclear Operations Department personnelinto a four-year Bachelor of Nuclear Science degree program, starting in early 1987. This program will improve the overall educational level and professionalism of personnel within the department by providing an opportunity for those individuals interested in obtaining a four-year degree.
c.
Qualified contractor assistance will be provided to assist in the review of training material for accuracy, level of detail, and conformance to current plant design. In addition, contract assistance will be provided for the ongoing simulator testing program. The training material review, due to its magnitude,is a two-year program (December 1988).
i Page 3 of 5
ATTACHMENT I-- Continued The simulator testing program is expected to be completed in December 1987.
In addition to the proposed long-term contractor assisted review of training material, NOEST has initiated a review of training material for other systems that contain interlocks which may cause operator confusion. This review compares the plant electrical elementary drawings to existing training material to verify accuracy and level of detail. Training material is being updated as errors are noted. This effort is approximately 80% complete and will be completed prior to the start of the 1987 requalification training program.
2.
An approved training program, developed by the three operators directly involved in the event, was presented to all licensed shift operating personnel during a four hour block ofinstruction. This training consisted of the following four segments.
a.
Charging Pump Misalignment, which discussed Licensee Event Report 86-010 and the causes and corrective actions.
b.
Swing Pump Operations, which detailed the various swing component interlocks and use of 208 series drawings for decision making.
c.
Lessons Learned, which discussed the need for attention to details and challenging activities not addressed by procedures.
d.
Methods to improve Teamwork and Promote an Inquisitive Attitude, plus improvements to the Removal and Restoration Program, Turnover and Administrative Logs,which discussed ways and means to make good decisions and how to improve logs and turnovers.
3.
Modified simulator software to duplicate the inplant Charging /SI Swing Pump logic in order to provide hands-on training.
4.
Retraining of the logic associated with Engineered Safety Features (ESF) equipment interlocks will be provided annually.
5.
The licensed operator simulator requalification training has been expanded from 8 to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per requalification training week to provide more hands-on training for normal as well as emergency conditions.
6.
Technical Services Procedures, TS-128, TS-129, TS-132, and TS-135, have been revised to address pre-modification implementation planning and post-modification testing requirements for the design change control program.
7.
Station Administrative Procedure, SAP-205, has been revised to more effectively address the tracking of ec uipment removed from service.
Incorporated in this revision are guic ance for stricter controls on inoperable equipment and lessons learned from this event.
8.
Station Scheduling Procedure, SSP-001, has been revised to more clearly delineate the responsibilities of the operating and maintenana personnel with respect to ensuring that all areas of concern have been addressed with regards to maintenance or modification activities performed on plant equipment.
Page 4 of 5
h.
ATTACHMENT I-- Continued 9.
Station Operating Procedure, SOP-102, has been revised to address the interlocks associated with the Charging /SI Swing Pump. This revision includes precautions associated with operatmg the Swing Pump.
- 10. By the end of the third refueling (currently scheduled for the spring of 1987),
the Charging /SI, Chilled Water, and Service Water Swing Pumps will be converted to installed spares. As installed spares, both trains of swing pump breakers will be " racked out" unless being used as a replacement for either of the train specific pumps.
V.
DATE OF FULL COMPLIANCE SCE&G expects to be in compliance with the corrective actions stated above, with the exception of the training material review, by December 1987. Due to the scope of work involved in improving the level and quality of training material, SCE&G expects to be in compliance to this additional corrective action by December 31, 1988.
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