05000395/LER-1987-018, Forwards 870827 LER 87-018-00 Which Responds to Violation Addressed in Encl 1,Item a of Insp Rept 50-395/87-24.LER Addresses Reason for Violation & Corrective Actions Taken to Prevent Recurrence

Forwards 870827 LER 87-018-00 Which Responds to Violation Addressed in Encl 1,Item a of Insp Rept 50-395/87-24.LER Addresses Reason for Violation & Corrective Actions Taken to Prevent Recurrence

ML20236R163
Person / Time
Site:	Summer
Issue date:	11/02/1987
From:	Nauman D SOUTH CAROLINA ELECTRIC & GAS CO.
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8711230121
Download: ML20236R163 (1)

LER-2087-018, Forwards 870827 LER 87-018-00 Which Responds to Violation Addressed in Encl 1,Item a of Insp Rept 50-395/87-24.LER Addresses Reason for Violation & Corrective Actions Taken to Prevent Recurrence

Event date:
Report date:
3952087018R00 - NRC Website

text

I 10CFR 2.201 m rotina Electric & Gas Company n A. uan i Columbia, SC 29218 Nuclear Operations

. (803) 748-3513 a scasacwwy November 2, 1987 ,

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Dr. J. Nelson Grace Regional Administrator U. S. Nuclear Regulatory Commission Suite 2900 101 Marietta Street, NW  !

Atlanta, Georgia 30323

SUBJECT:

Virgil C. Summer Nuclear Station Docket No. 50/395 Operating License No. NPF-12 l Response to Notice of Violation }

NRC Inspection Report 50-395/87-24 l

Dear Dr. Grace:

Attached is the South Carolina Electric & Gas Company (SCE&G) Licensee Event Report (LER)87-018, dated August 27, 1987, which responds to the violation addressed in Enclosure 1, Item A, of the NRC Inspection report

{

50-395/87-24. i SCE&G is in agreement with the alleged violation, and the enclosed LER addresses the reason for the violation and corrective actions taken to prevent recurrence. SCE&G will be in full compliance by the end of the first quarter 1988.

Should you have any questions, please advise.

7m r t ul yours, si Dy u RJB: DAN /bjh Enclosure cc: 0. W. Dixon, Jr./T. C. Nichols, Jr. K. E. Nodland E. C. Roberts J. C. Snelson

0. S. Bradham G. O. Percival D. R. Moore R. L. Prevatte W. A. Williams, Jr. J. B. Knotts, Jr.

Group Managers NPCF W. R. Baehr File W. T. Frady C. L. Ligon (NSRC) .

R. M. Campbell, Jr. -

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At 1910 hours0.0221 days <br />0.531 hours <br />0.00316 weeks <br />7.26755e-4 months <br />, July 29, 1987, the Integrated Fire and Security (IF&S) system failed due to severe electrical storms. The system was restored at 0200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br />, LR9 July 30 with was the exception of one panel { Loop Remote (LR) 91 which was in bypass.

subsequently declared operable at 1830 hours0.0212 days <br />0.508 hours <br />0.00303 weeks <br />6.96315e-4 months <br />, July 30. At 1230 hours, July 30, it was identified that containment temperature had not been monitored between the hours of 1910, July 29 to 0200, July 30 and that fire areas ranitored by LR9 had not been patroled from 0200 until 1230 hours0.0142 days <br />0.342 hours <br />0.00203 weeks <br />4.68015e-4 months <br />, July 30.

The Control Room Supervisor failed to properly document the failure of the IF&S system and failed to initiate the monitoring of the containment air temperature as required by Technical Specifications. When the system was restored at 0200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br />, with the exception of LR9, continuation of compensatory action for the areas monitored by LR9 was not verified due to lack of procedural guidance.

The following corrective actions will be taken as a result of this event:

1. Station Administrative Procedure (SAP-131), " Fire Protection Program Plan," will be revised to address all aspects of the fire protection program.

2. A Fire Protection Leader will be assigned to each shift and will be the " single point contact" for all fire protection related activities.

3. The Duty Shift Supervisor at the time of the event attended the Management Review Board meeting, chaired by the Vice President, Nuclear Operations and will'

__ brief each shift on the events that occurred and lessons learned.

U S NUCLt&2 ft1GUL ATOIY COMMis4 ion N2C Feem 364A LICENSEE EVENT REPORT (LER) TEXT CONTINUATION uaovio ove No no.ee.

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0l0 O l2 01 Si PLANT IDENTIFICATION:

Westinghouse - Press 0rized Water Reactor at EQUIPMENT IDENTIFICATION:

Integrated Fire and Security System IDENTIFICATION OF EVENT:

Failure to implement compensatory action as required by Technical-Specifications Section 3.3.3.7, " Fire Detection Instrumentation."

EVENT DATE: 07/30/87 REPORT DATE: 08/27/87 This report was initiated by Off-Normal Occurrence Number 87-077.

CONDITIONS PRIOR TO EVENT:

Mode 1 - Reactor Power 100%

DESCRIPTION OF EVENT:

At approximately 1910 'nours, July 29, the Integrated Fire and Security (IF&S)-

system failed due to severe electrical storms in the immediate area. Plant security notified the Control Room Supervisor (CRS) that the IF&S system was off-line and they (security) had initiated the compensatory security and roving fire watch patrols for the areas monitored by the IF&S system. The CRS reviewed the Removal and Restoration (R&R) log and the Fire Barrier Removal log, and established a continuous fire watch in areas with breached or degraded fire barriers. However, the CRS failed to properly document the failure of the IF&S system in the R&R log and failed to initiate action to monitor the containment air temperature hourly as required by Technical Specifications.

At approximately,0200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br />, July 30, security notified the CRS that the IF&S system was restored with the exception of one panel [ Loop Remote (LR) 91 which was in bypass and security compensatory action had been taken for security points monitored by LR9. Security discontinued the compensatory security and roving fire watch patrol'which had been initiated on the loss of the system assuming that the CRS would identify areas monitored by LR9 and place them on the regular roving fire watch log. The CRS assumed that security personnel were continuing to perform the hourly fire watch patrols.

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At approximately 0730 hours0.00845 days <br />0.203 hours <br />0.00121 weeks <br />2.77765e-4 months <br />, July 30, the on-coming Shift Supervisor and Control Room Supervisor independently reviewed fire points in alarm or off-normal status, as identified on the IF&S display, and verified that the areas identified were on the roving fire watch log. They also reviewed the R&R log and noted that continuous fire watches were still in place for areas with <

breached or degraded fire barriers.

At approximately 0800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br />, the Senior Fire Protection Technician reviewed the R&R log and at that time notified the Shift-Supervisor and Control Room Supervisor that the breached fire barriers had been repaired and the continuous fire watch could be secured.

By clearing the R&R log which identified areas with breached or degraded barriers and from the information reviewed on the IF&S display, the Control Room Supervisor and Shift Supervisor believed that the IF&S system was on-line. It has since been identified that the program used to display fire points in alarm or off-normal status would not  ! display any fire points that are in a off-line status.

At 1230 hours0.0142 days <br />0.342 hours <br />0.00203 weeks <br />4.68015e-4 months <br /> security notified the CRS that LR9 was being placed back in service. The CRS questioned the status of LR9 because he was aware that the roving fire watch log did not identify fire points associated with LR9. It was identified at this time that the required compensatory fire watch round had not been performed since 0200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br />. The control room supervisor took immediate action to initiate action as required by Technical Specifications and initiated an Off-Normal Occurrence (ONO) report documenting the event.

CAUSE OF EVENT:

The cause of this event was due to personnel error and lack of procedural guidance. When the CRS was notified that the IF&S system was off-line, he immediately performed a review of the R&R log and the Fire Barrier Removal log to identify areas with breached or degraded barriers and established a continuous fire watch as required. The CRS initiated an R&R which identified those areas with degraded barriers and inoperable smoke detectors which required a continuous fire watch; however, he failed to properly document the failure of the IF&S system in the R&R log. In addition, the CRS failed to review the applicable Technical Specifications to ensure all required compensatory action had been taken and as a result, containment air temperature was not monitored as required by Technical Specifications.

At 0200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br />, security notified the Control Room Supervisor that the IF&S was on-line with the exception of LR9 which was in bypass and security compensatory action had been taken. The compensatory action taken at this

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time by security was the stationing of armed guards at two doors monitored by LR9. The CRS was not notified that the compensatory fire watch roving patrols were being secured at this time and the CRS assumed that the

" security compensatory action" was the continuation of the hourly roving patrols for fire points monitored by LR9.

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rv,w ,wa.a-.-< .a. nance msonm l ANALYSIS OF EVENT:

The consequences due'to this event were minimal. The containment air temperature was monitored between 2000 and 2200 hours0.0255 days <br />0.611 hours <br />0.00364 weeks <br />8.371e-4 months <br />, July 29 to satisfy the surveillance requirements of Technical Specifications Section 3.6.1.5,

" Containment Air Temperature." The failure to monitor the containment air '

temperature as a result of the loss of the IF&S system did not degrade the fire protection objective for the containment. The principal fire protection objective for the containment is to demonstrate that a single fire will not damage redundant equipment and cabling. This is achieved by separation consistent with 10 CFR 50 Appendix R. A secondary fire protection objective for this area is to prevent fire from spreading to or from adjacent fire areas. This is achieved by the three-hour rated containment boundary, the reactor coolant pump oil system collection, and an overall fire loading which requires less than a one-half hour fire resistance rating.

The affected areas monitored by LR9 are located in the Auxiliary Building and consist of the general floor area at 436' elevation and the solid waste drumming station (436' & 447'). All affected areas are within one fire zone l

(ABl.18) and the fire loading for the zone is very low at 24,900 BTU /ft2 The "A" train equipment and cabling in this zone are separated from "B" train equipment and cabling by a distance of greater than 30 feet and three concrete walls. In addition, the area was patrolled every two hours by station security personnel as part of their normal security rounds.

CORRECTIVE ACTION:

On August 25, 1987, a Management Review Board (MRB) meeting, chaired by the Vice President, Nuclear Operations was convened to review this event. It was noted that the Off-Normal Occurrence (ONO) Trend Report for the second quarter of 1987 identified that the number of occurrences associated with firewatches did decrease during this quarter indicatirg that the corrective actions implemented during the first quarter have been effective. However, LERs for 1986 to the present associated with the fire protection program were reviewed to determine if there existed a common denominator among any of the previous reportable events and to assess the corrective action taken for each event. Alth'ough personnel error is common to the majority of the events, each event was unique and appropriate corrective action appeared to have been taken.

l It was identified that there does not exist a " single document" which identifies each specific action required on the loss and recovery of the.IF&S system or a portion thereof. Security personnel are provided guidance by Security Procedures; Operations personnel are provided guidance by Operations Procedures and Technical Specifications, but there does not exist an interface procedure to ensure all required fire protection action is initiated. In conjunction with the absence of a " single document", it was also identified that a " single point of contact" whose sole responsibility is fire protection needs to be established for each shift.

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As a result of the Management Review Board meeting, the following corrective action wi)1 be taken.

1. The Duty Shift Supervisor at the time of the event attended the MR8 and l will brief each shift on the events that occurred and lesson learned. (To be completed by October 1,1987.) *** COMPLETED ***

2. A copy of this report will be placed in Operations' and Security's required reading. (To be completed by October 15, 1987. ) *** COMPLETED ***

3. Abnormal Operating Procedure 509.1, " Loss of IF&S Computer," will be issued which details action to be taken on the loss of IF&S system. When I power is restored, the procedure will require that a Log Point Summary printout be obtained from security to determine which fire points or Loop Remotes have not been returned to service. This will aid the Control Room personnel in updating the hourly Fire Watch Patrol log as required. (To be completed by September 15,1987.)'*** COMPLETED ***

4. A computer program has been identified that will allow the display of fire points in alarm, off-normal or in a off-line status. Instructions in the use of the program will be displayed at the IF&S console in the Control Room. (To be completed by September 15, 1987. ) *** COMPLETED ***

5. All Licensee Event Reports pertaining to the Fire Protection Program that have been initiated from 1986 to present will be reviewed during the forthcoming Operators' Requalification Trcining. The cause and corrective action of each event will be discussed. This discussion will also include what future corrective action can be taken to preclude. recurrence of such events. (To be completed by October 15, 1987. ) *** COMPLETED ***

6. Station Administrative Procedure (SAP-131), " Fire Protection Program Plan," will be revised and will provide single document reference to address all aspects of. Fire Protection Program. (To be completed by December 31,1987.)

7. Additional personnel will be trained by the Fire Protection Coordinator in the duties and responsibilities of fire protection to qualify them for the position of Fire Protection Shift Leaders and to serve as a single point contact for fire related matters. (To be completed by the end of the first quarter 1988. In the interim, security personnel will be designated as Security Fire Watch Coordinator and will be responsible for interfacing with the Shift Supervisor and CRS on all fire protection / fire watch activities.)

8. In order to c'entralize the fire protection responsibilities, effective August 29, 1987, the Fire Protection Organization will be transferred from Operations to Nuclear Protective Services. ***COMPLETEC***

6

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