IR 05000395/1985026

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Discusses Insp Rept 50-395/85-26 on 850603-07 & Forwards Notice of Violation.Violations Categorized as Severity Level Iii.Civil Penalty Deemed Inappropriate Based on Util Prompt Corrective Actions
ML20207T568
Person / Time
Site: Summer 
Issue date: 03/11/1987
From: Grace J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To: Nauman D
SOUTH CAROLINA ELECTRIC & GAS CO.
Shared Package
ML20207T569 List:
References
EA-85-101, NUDOCS 8703240139
Download: ML20207T568 (3)


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MAR 111987 Docket No. 50-395 License No. NPF-12 EA 85-101 South Carolina Electric and Gas Company YATTN: Mr. D. A. Nauman, Vice President Nuclear Operations P. O. Box 764 (167)

Columbia, SC 29218 Gentlemen:

SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-395/85-26)

This refers to a special safety inspection conducted on June 3-7, 1985 of activities authorized by NRC Operating License No. NPF-12 for your Summer

facility. As a result of this inspection, violations of fire protection requirements were identified, some of which you identified. At the conclusion of the inspection, these findings were discussed with members of your staff as stated in the above referenced inspection report. This report was sent to you with our letter dated August 20, 1985. An enforcement conference to discuss the violations was held in your office on August 9, 1985.

Violation A described in the enclosed Notice of Violation (Notice) involves power cables associated with both redundant trains of charging pumps and three source range nuclear instrumentation channels that were not provided with adequate fire protection features. Violation B involves inoperable fire barriers, in a floor / ceiling penetration and conduit raceway, without actions to establish fire watches as required by Technical Specifications.

The staff recognizes that a significant amount of time has elapsed since the referenced inspection report was issued. This is because the NRC has been developing the enforcement guidance for Appendix R based on earlier NRC inspections and comments from the industry regarding the basis upon which

. compliance with Appendix R would be evaluated. The NRC held workshop discussions in each of the five regions in 1984 to solicit industry questions and coments.

In the Spring, 1986, the Commission approved the staff's Appendix R interpretations and, with revisions, the enforcement guidance.

. Although the violations identified at Summer did not involve issues related to those interpretations of Appendix R, the staff did not believe it was appropriate to proceed with escalated enforcement action until the interpretations and enforcement guidance were issued.

In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986), the violations described in the enclosed Notice have been categorized in the aggregate as a Severity Level III problem. Although the base civil penalty for a Severity Level III violation or problem is $50,000, after consultation with the Director, Office of Inspection and Enforcement, a civil penalty was not considered appropriate in this case. The NRC Enforcement Policy allows for reduction of a civil penalty ur. der certain circumstances.

In this case, based on your prompt G703240139 B70311

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South Carolina Electric and Gas Co.

MAR 111987 identification and reporting of certain of the violations and your unusually prompt and extensive corrective actions, a civil penalty will not be proposed.

Since.your corrective actions for these violations have already been examined and accepted by the NRC, no response to the-Notice of Violation is required.

If you choose to respond to this letter, you should. follow the instructions spacified in the enclosed Notice when preparing your response.

In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title

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10, Code of Federal Regulations, a copy of this letter and its enclosures will be placed in the NRC Public Document Room.

The responses directed by this letter and the enclosures are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.

Sincerely, J. Nelson Grace Regional Administrator Enclosure: Notice of Violation cc w/ encl:

V0. S. Bradhcm, Director, Nuclear Plant Operations

/J. L. Skolds, Deputy Director Operations and Maintenance VJ. B. Knotts, Jr.

Debevoise and Liberman

/W. A. Williams, Jr., Special Assistant, Nuclear Operations -

Santee Cooper VA. M. Paglia, Jr., Manager Nuclear Licensing

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