ML19350C788

Responds to NRC Ltr Re Violations Noted in IE Insp Rept 50-395/81-02 on 810203-05.Corrective actions:NCN-4477 Has Been Issued to Identify,Control & Resolve Problem of Packet Instruction Sheet.Affected Personnel Advised

ML19350C788
Person / Time
Site:	Summer
Issue date:	03/27/1981
From:	Nichols T SOUTH CAROLINA ELECTRIC & GAS CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8104060700
Download: ML19350C788 (3)

Text

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, , 4 i SouvH CAnoLINA ELECTaic a gas CoMPA9y

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Cotu=eia, Soutw Camou=4 asais T. C. Nacwots. J a.

we.....s cua March 27, 1981 u.. c .,

Mr. James P. O'Reilly, Director U. S. Nuclear Regulatory Commission Region II, Suite 3100 101 Marietta Street, N. W.

Atlanta, Georgia 30303

Subject:

Virgil C. Su=mer Nuclear Station Docket No. 50/395 RII: JLS-50-395/81-02

Dear Mr. O'Reilly:

Attached is South Carolina Electric and Gas Company's response to the referenced report which sn-arizes Mr. B. R. Crowley's inspection of February 3, 1981 through February 5, 1981. We consider the action *; we have taken appropriate

, to assure that these specific type of events vill no.: recur.

I declare the statements and matters set forth herein are true and correct to the best of my knowledge, information and belief.

Should you have questions or co=ments, please contact us at your convenience.

Very trulj yours, T. C. Nichols, Jr.

RBC:TCN:glb

. Attachment

! cc: V. C.-Summer w/o att. J. B. Knotts, Jr.

G. H. Fischer w/o att. J. L. Skolds l

T. C. Nichols, Jr. v/o att. B. A. Bursey O. W. Dixon, Jr.- O. S. Bradham C. A. Price Document Management Branch D. A. Nauman (55e/21/LER Only)

W. A. Willia =s, Jr. I&E (Washington)

R. B. Clary ISEG A.' R. Koon PRS c2 I ; D' C ff

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A. A. Smith g [#

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NPCF File H. N. Cyrus $ f L b( , s K epi

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ADMISSION OR DENIAL OF ALLEGED VIOLATION South Carolina Ele:tric and Gas Company recognires this item as a violation of procedure requirements as presently written.

REASON FOR VIOLATION The replacement of leaking bellows on penetration 326P was performed in accordance to the disposition of SFR-3263; the document issued to identify the probles to engineering for their review and disposition. The disposition contained special instructions as well as some specific operations. The contents of the disposition was transferred to the " Packet Instruction Sheet" almost verbatius. In doing so the special instructions were sequentially nu=bered as operations along with specific operations. Therefore, so=e of the sequentially nu=bered operations were not signed off because they were information rather than operations. The individual who developed the " Packet Instruction Sheet" failed to cross out those signatures blocks per' procedure requirements that did not require a signature (special instruc-tions). The electrical penetration packet should have had si=ilar cross outs of those information and non-verified operations which did not require craf t sign-of f.

_In addition there existed some lack of clarity in both the work and QC procedures as to whether or not an operation (step) could be signed off later. In the case of d

QC inspection, project policy has been as follows:

QC signs off those operations that are i=pacted by review of related docu=ents

' when . it has - been deter =ined dhat those operations have been accurately com-pleted and verified.

CORRECTIVE STEPS ~TAKEN NCN-4477 has been. issued to identify, control and resolve the problem. In accordance i with procedure QCP-VII-02, the signature blocks for those sequentially listed operations on " Packet Instruction Sheet" that are informational rather thaa operational .ill be crossed out. Any craf t and QC operation which requires sign-off will be ' completed before the packet is considered acceptable. We have evaluated the generic i= plication of this concern and consider it a "sof tware" problem having no apparent impact upon the s truc tur e. -

CORRECTIVE STEPS TO BE T.?EN TO PRECLUDE RECURRENCE Because cf the potential seriousness of the apparent procedural violation, the Site Manager and Project Manager met with the Piping Manager, Superintendent, i

General Foreman, and Project Quality Manager involved and discussed with them the seriousness of violating procedure. They were ' instructed to take action to assure that affected personnel were also advised of:the seriousness of this problem.

, . WP-VII-02 and QCP-VII-02 are presently being evaluated for improvement in the clarity

-of -requiracents such that there will be no question as to intent.

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• DATE OF FL'LL C0lfPLIANCE All actions stated above shall be effect'. by Apr!l 30, 1981.

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