ML19332A662
| ML19332A662 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 07/28/1980 |
| From: | Nichols T SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19332A660 | List: |
| References | |
| CGSV-03-0178, CGSV-3-178, NUDOCS 8009160634 | |
| Download: ML19332A662 (5) | |
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SOUTH CAROLINA. ELECT [O $s'4 lid.'EICW.3 COMPANY TA. " U Post orrics s
~ COLUMBI A S. C. 29218 July 28, Ad 4E CG3V-03-0178 Mr. James P. O'Reilly Office of Inspection & Enforcement U. S. Nuclear Regulatory Commission Region II 101 Marietta St., N.W., Suite 3100 Atlanta, Georgia 30303 Re: Virgil C. Summer Nuclear Station Unit #1 Docket No: 50-395 Report: RII:JLS 80-15
Dear Mr. O'Reilly:
Attached are our responses to the referenced report which summarizes Mr. J. L. Skolds' inspections May 1 through May 31, 1980. Specifically we have addressed the infractions dealing with violations of station programs, procedures and/or FSAR in the areas of start-up procedures, installed snubber protection, and procurement. We consider that the actions taken are appropriate to assure that these type of events will not recur.
Should you have any questions or comments, please contact us at your convenience.
Very truly yours,
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T. C. Nichols, Jr.
Vice President and Group Executive Nuclear Operations ARK: tim cc: Messrs. W. A. Williams H. T. Babb D. A. Nauman
- 0. W. Dixon M. B. Whitaker J.L.Skolds(ResidentInspector)
- 0. S. Bradham A. R. Koon file
- C M 800916.0 $ 3y k
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' SOUTH CAROLINA ELECTRIC AND GAS COMPANY VIRGIL C. SUMMER NUCLEAR STATION UNIT'NO.~1
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Docket Number: 50-395 Report Number: 80-15/ Notice of Violation A.1 Event Date: N/A Description of Event-As required by 10'CFR Appendix B, Criterion V implemented by South Carolina Electric and Gas Company FSAR Section 17.1.5, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings...and shall be accomplished in accordance with these instructions, procedures, or drawings." Start Up Manual Procedure SUM-B-8, " Conduct of Start Up Testing" Section 3.4 states that initialing a step in procedure indicates that, based on personal observation or reports from assigned test personnel, the step has been performed as written, conditions. are as desired and results are as recorded.
Contrary to the above, procedures affecting quality were not adhered to in that:
Step 4.5 of hydrostatic test SI-01-HI (Safety Injection High Head Piping) was initialed indicating the installed relief valve was set at 3525 psi when in fact, it was set at 3540 psi.
Probable Consequences There were no detrimental effects either to personnel safety or equipment protection since the relief-valve was set within appropriate tolerances, even though the subject hydroprocedure did not state those tolerances.
Cause of Event No tolerance for the relief setting was specified in the hydro test procedure.
In
-setting the relief valve, normal site tolerances were used which resulted in an actual' relief valve setting of 3540 psi.
.Immediate Corrective Action Taken The subject Hydrostatic Test Procedure SI-01-HI was revised to include appropriate tolerances for the relief setting.
Subsequent Corrective Action All start-up test supervisors have been advised to insure that relief valves are set-to the requirements of the hydrostatic test procedure and that appropriate toler-ances are included when necessary.
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. SOUTH' CAROLINA ELECTRIC AND GAS COMPANY-VIRGIL'CoSUMMER NUCLEAR STATION UNIT NO. l' 4
Docket' Number: 50-395 Report Number: 80-15/ Notice of Violation A.2 Event Date:
May 5, 1980 Description of Event As required by 10 CFR Appendix B, Criterion V implemented by South Carolina Electric and Gas Company FSAR Section 17.1.5, " Activities affecting quality
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shall be prescribed by documented instructions, procedures, or drawings...
and shall be accomplished in accordance with these instructions, procedures, or drawings. Daniel Construction Procedure QCP-VII-07, Paragraph 4.11.18 requires verificacion of proper protection of snubbers by checking the snobbers are wrapped. Snubbers RHH 134, RHH 135, RHH 136, RHH 157, and RHH 160 were not properly protected in that they were not wrapped on May 5, 1980.
Probable Consequences There are no probable consequences because of the following reasons:
1.
The design of the snubbers precludes the indoctrination of foreign material which would inhibit snubber-operation.
2.
Subsequent snybber testing would have identified any problems associated with the operability of the subject snubbers.
i Cause of Event The subject snubbers had.been uncovered during a start-up test and were not recovered.
Immediate Correction Action Taken The subject snubbers were inspected, and proper protecion including protective wrappings, was installed.
- Subsequent Protective Action A program has been developed _ to perform walkdown inspections of _ installed snubbers to assure adequ' ate protective measures, which includes protective wrappings, are being used.
In support of.this effort, all snubber locations have been individually mapped and. recorded in a snubber log and certain small snubbers have been removed i
- and _placed in protective storage. If the protective covers are found missing during inspection, investigations are conducted to identify the cause_and action taken to prevent reoccurrence.
i In addition,. start-up personnel have been cautioned to insure that protective wrapp-ings removed during testing must be' reinstalled at the conclusion of the test.
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4 SOUTH CAROLINA ELECTRIC AND CAS COMPAhT VIRGIL C. SUMMER NUCLEAR STATION UNIT NO. 1 4
Docket Number:
50-395 Report Number: 80-15/ Notice of Violation B Event Date:
N/A ANSI N45.2.13-1976, Section 3.1 states " Procurement document changes shall be subject to the same degree of control as utilized in the preparation of the original documents." It further states in Section 6.4 "The purchaser and supplier shall assure that measures to control changes in procurement documents are established, implemented and documented, and are in accordance with ANSI N45.2, Section 7."
ANSI N45.2-1971, Section 7 states " Measures shall be established and documented to control the issu-ance of documents, such as instructions, procedures, and drawings, including changes thereto, which prescribe activities effecting quality.
These measures shall assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel and are dis-tributed to and used at the location where the prescribed actiilty is performed.
Changes to documents shall be reviewed and approved by the same organizations that performed the original review and approval unless other organizations are specifically designated.'?
CAUSE The SCE&G procedures which were currently in use at the time that this in-fraction was written did not specifically address the routing and approval of changes to procurement documents after purchase order placement.. Pro-curement document changes were, in fact, being routed to all originally involved organizations for review.
Changes which were of a strictly QA nature, were being routed to the other involved organizations, however, approvals prior to implementation into contracts, were not required by pro-cedure and therefore were not being ;btained.
IMMEDIATE CORRECTIVE ACTION All changes, including strictly QA changes, are now being routed to the originating organization for review and approval prior to imple-mentation. This has resulted in the immediate, short-term correction of the NRC concern as expressed in this finding.
CORRECTIVE STEPS UHICH WILL BE TAKEN TO AVOID FURTHER NONCOMPLIANCE The procedures involved which concerned procurement will be revised to fully reflect the correct routing and approval signatures to changes of procurement documents.
It is the position of SCE&G that the routing and approval should be through and by authorized, qualified persons within the organizations which performed the original review. The SCE6G procedure revisions will assure compliance with ANSI 45.2.13 and ANSI 45.2 wherein " Changes are reviewed for accuracy and approved for release by authorized personnel." The procedure e
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- revision will also assure that " changes to documents shall be reviewed and -
approved by the same organizations that perform the original review and approval unless other organizations are specifically designated."
IMPLEMENTATION DATE The expected implementation date is August 15, 1980.
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