RC-99-0129, Provides Response to non-cited Violations Noted in Insp Rept 50-395/99-03.C/As:concluded That Cask Loading Pit Inaccessible & Duration of Dose Rates on Operating Floor of Fhb So Short That High Radiation Area Did Not Exist

Provides Response to non-cited Violations Noted in Insp Rept 50-395/99-03.C/As:concluded That Cask Loading Pit Inaccessible & Duration of Dose Rates on Operating Floor of Fhb So Short That High Radiation Area Did Not Exist

ML20209D238
Person / Time
Site:	Summer
Issue date:	07/07/1999
From:	Gabe Taylor SOUTH CAROLINA ELECTRIC & GAS CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RTR-REGGD-08.038, RTR-REGGD-8.038 50-395-99-03, 50-395-99-3, RC-99-0129, RC-99-129, NUDOCS 9907130079
Download: ML20209D238 (4)

Text

g n

? d; ,

3

. . *'!l

[.

1i su R 9- 29 A SCANA COMPANY Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

Gentlemen:

. . - J

Subject:

VIRGIL C. SUMMER NUCLEAR STATION LGwy 1 Tayl" ~

DOCKET NO. 50/395

,"hy, . '

OPERATING LICENSE NO. NPF-12 RESPONSE TO NON-CITED VIOLATIONS NRC INSPECTION REPORT 99-03 y

This letter provides the South Carolina Electric and Gas (SCE&G) response to j Non-Cited Violation Number 50-395/99003-01 delineated in Section O2.1 of l '

NRC Inspection Report No. cA-395/99-03. SCE&G is not in agreement with this violation. The basis for denial of this NCV is contained within the attached response. {

?56uihCerotimilearia.GasCo ,

i Vigil C.Sumc Nuclear Station'.3 Additionally, SCE&G requests reclassification of Non-Cited Violation Number

10. Ba B8 : . 50-3956/99003-06 delineated in Section R1.2 of NRC Inspection Report No. -

ville',5outh Camlim 50-395/99-03. This Non-Cited Violation states that SCE&G failed to properly control access to a high radiation area in accordance with 10CFR20.1601.

803.345A344 '

803.345.5209 ; in an analysis performed by Health Physics personnel under the SCE&G wanuom? ,

corrective action program, it was concluded that the Cask Loading Pit was inaccessible and that the duration of the dose rates on the operating floor level l of the Fuel Handling Building was so short that a high radiation area, as defined f

by 10CFR20 and Regulatory Guide 8.38, did not exist.

/

SCE&G does not deny the violation but rather believes the violation should be against 10CFR20.1501 since Health Physics personnel did not perform -

3 surveys, reasonable under the circumstances, to evaluate the extent of ib,ol radiation levels and the potential radiological hazards that could be present /

during fuel movement.

[ -

f

,' %71g G

l % hs l ~

NUCLEAR EXCELLENCE - A SUMMER TRADITIONI d ,

~

' Document Control D:sk

.lE 990361 lE 990306 RC-99-0129 Page 2 of 2' If you have any questions regarding this request or require additionalinformation, please contact Mr. Donald L. Jones at (803) 345-4480. j i

Very truly yours, i b M ssi~

Gary J. Taylor DLJ/GJT/dr Attachment ,

I c: J. L. Skolds W. F. Conway R. R. Mahan'(without attachment)

R. J. White i L. A. Reyes J. Lieberman K. R. Cotton ,

NRC Resident inspector l H. C. Fields .

D. M. Deardorff L. A. Blue P. Ledbetter J. B. Knotts,- Jr.

NSRC RTS (IE 990301)

RTS (IE 990306)

File (815.01)

DMG (RC-99-0129)

Documsnt Control Desk Letter

' Attachment i IE 990301 RC-99-0129 Page 1 of 2 REPLY TO NON-CITED VIOLATION VIOLATION NUMBER NCV 50-395/99003-01

1. RESTATEMENT OF THE VIOLATION On May 7, the inspectors conducted an inspection of containment to assess material condition and general area housekeeping prior to reactor startup. At the time of this inspection the licensee had completed a reactor building close-out visualinspection per Quality Systems Procedure (OSP)-208," Inspection of Housekeeping and items in Storage," Revision 9 and had entered Mode 4. In general, the material condition of the containment was satisfactory. However, the inspectors identified debris and tools, such as a rubber shoe, a plastic bag, a cloth booty and other smallitems 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 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 8.2.1.8 of OSP-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 close-out. 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 licensce's corrective action program as CER 99-0748 and is identified as NCV 50-395/99003-01.

II. SCE&G POSITION ON THE VIOLATION SCE&G denies the violation as stated above.

111. SASIS FOR SCE&G POSITION The surveillance requirements of Technical Specification 4.5.2.c state in part:

4.5.2 Each ECCS subsystem shall be demonstrated OPERABLE:

l l c. By a visualinspection which verifies that no loose debris (rags,  !

trash, clothing, etc.) is present in the reactor building which could 1

1 1

I

)

Document Control Desk Letter

' Attachment I IE 990301

{ 1 RC-99-0129 Page 2 of 2 be transported to the RHR and Spray Recirculation sumps and cause restriction of the pump suctions during LOCA conditions. >

l l

The purpose of this surveillance requirement is to ensure that the required number of trains of ECCS are OPERABLE and that there is not sufficient debris inside the reactor building that can be transported to the sumps and degrade ECCS performance to a level that its design basis function can no longer be performed.

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 i recommendations of this RG, sump blockage from debris of 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 i conducted at the Alden Research Laboratories during the initial plant licensing phase.

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 debns I 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.

Subsequent to the NRC inspection of the reactor building, Engineering personnel performed an evaluation and determined that the transportable debris found inside the 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 i was adequate.

During conversations between plant staff and the inspectors, it was inferreo 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 the 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.

i The reactor building close-out process is being reviewed by plant management j for potential enhancements. Any such enhancements will be documer ted under '

the VCSNS corrective action program. j

!