ML19352A364
| ML19352A364 | |
| 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) |
| Shared Package | |
| ML19352A363 | List: |
| References | |
| NUDOCS 8104160852 | |
| Download: ML19352A364 (3) | |
Text
_
[O, umRc -..,.'v ".
SOUTH CAR'OYlNi Eticinic a gas COMPANY
~
post orrice som,e4 Soutu CAgouIph aseis Cotums:Ag
'I T. C. NicM ots,J R.
March 27, 1981 we e.o.
... c. oca,==
u.o n.
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. Summer 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 summarizes Mr. B. R. Crowley's inspection of February 3, 1981 through February 5, 198'..
We consider the actions we have taken appropriate to assure that these specific type of events will not 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 comments, please contact us at your convenience.
Very truly yours, 4
T. C. Nichols, Jr.
RBC:TCN:glb Attachment ec:
V. C. Summer w/o att.
J. B. Knotts, Jr.
G. H. Fischer w/o att'.
J. L. Skolds T. C. Nichols, Jr. w/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. Williams, Jr.
I&E-(Washington)
R. B. Clary ISEG A. R. Koon PRS A. A. Smith NPCF H. N. Cyrus File 4
e ADMISSION OR DENIAL OF ALLEGED VIOLATION South Carolina Electric and Gas Company recognizes 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 problem to I
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 verbatium. In doing so the special instructions were sequentially numbered as operations along with specific operations. Therefore, some of the sequentially numbered 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 similar cross outs of those information and non-verified operations which did not require craf t sign-off.
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 QC inspection, project policy has been as follows:
QC signscoff those operations that are impacted by review of related documents when it has been determined that 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 with procedure QCP-VII-02, the signature blocks for those sequentially listed operations on " Packet Instruction Sheet" that are informational rather than operational will 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 implication of this concern and consider it a "sof tware" problem having no apparent impact upon die structure.
CORRECTIVE STEPS TO BE TAKEN TO PRECLUDE RECURRENCE Because of the potential: seriousness of the-apparent procedural violation, the Site Manager and Project Manager met with the Piping Manager, Superintendent, 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 requirements such that there will be no question as to intent.
DATE OF FULL COMPLIANCE i
All actions stated above shall be effected by April 30, 1981.
i i
,