ML20003D514
| ML20003D514 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 03/20/1981 |
| From: | Nichols T SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8103270559 | |
| Download: ML20003D514 (4) | |
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March 20, 1981 S1 MAR 2 6198 8 "m,w 'd Mr. James P. O'Reilly, Director 9
U. S. Nuclear Regulatory Commission Region II, Suite 3100 Cu
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g 101 Marietta Street, N. W.
Atlanta, Georgia 30303 Subj ect: Virgil C. Summer Nuclear Station Docket No. 50/395 RII: JLS-50-395/81-03
Dear Mr. O'Reilly:
Attached is South Carolina Electric and Gas Company's response to the referenced report which summarizes Mr. J. L. Skolds' inspection of January 3, 1981 through February 11, 1981. Specifically, we have addressed the violations concerning storage and control of Quality Assurance records. We consider the actions we have taken appropriate to assure that these specific type of events will not recur.
Should you have questions or comments, please c =:cct us at your convenience.
I declare the statements and matters set forth herein are true and correct to the best of my knowledge, information and belief.
to [Y A
T. C. Nichols, Jr.
/'Datel JWP:TCN:gib Attachment cc:
V. C. Summer J. B. Knotts, Jr.
G. H. Fischer J. L. Skolds T. C. Nichols, Jr.
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 NPCF A. A. Smith File l
H. N. Cyrus PRS
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l 8108270559
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w SOUTH CAROLINA ELECTRIC & GAS CO.
VIRGIL C. SLHMER NUCLEAR STATION, UNIT #1 DOCKET NO: 50-395 REPORT NO: RII:JLS 81-03 NOTICE OF VIOLATION A EVENT DATE: FEBRUARY 2, 1981 DESCRIPTION OF EVENT 10 CFR 50, Appendix B, Criterion XVII requires that consistent with regulatory requirements, the applicant establish requirements concerning record location.
Appendix 3A to the FSAR ce=mits the applicant to Regulatory Guide 1.88, Revision 2 which endorses ANSI N45.2.9-1974.
Section 5.2 of ANSI N45.2.9-1974 states that the quality assurance record files shall be stored in predeter-mined locations, as necessary to meet the tequirements of applicable codes, standards and regulatory agencies.
Contrary to the above, on February 2,1981, quality assurance files not presently stored in the permanent record vault were not stored in pre-determined locations.
ADMISSION OR DENIAL OF ALLEGED VIOLATIONS South Carolina Electric and Gas Conpany recognizes this item as a violation of the aforementioned regulatory requirements.
REASONS FOR VIOLATION It has been the understanding of-South Carolina Electric and Gas Company that full implementation of the subject requirement is to be effected prior to fuel load. Full implementation at an earlier date see ed i= practical due to the temporary nature of such storage facility locations during the construc-tion phase.
CORRECTIVE STEPS TAkTN A revision to AP.301.2, " Nuclear Operations Records Control Procedure", has been submitted for approval. This revision reflects the requirement for
-Quality Assurance records retention in predetermined locations and provides a list of all such authorized locations.
CORRECTIVE STEPS TO BE TAKEN TO PRECLUDE RECURRENCE A transmittal to appropriate plant personnel will be issued requiring their review of the subject. requirements and full compliance thereto.
DATE OF FULL COMPLIANCE All actions stated above shall,be effected by April 20, 1981.
c.
o SOUTH CAROLINA ELECTRIC & GAS CO.
Page 1 of 2 VIRGIL C. SUMMER NUCLEAR STATION, UNIT #1 DOCKET NO: 50-395 REPORT NO: RII:JLS 81-03 NOTICE OF VIOLATION B
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EVENT DATE: FEBRUARY 2, 1981 DESCRIPTION OF EVENT 10 CFR 50, Appendix B, Criterion V, implemented by FSAR Section 17.1.5 requires that activities affecting quality be prescribed by documented instructions, procedures or drawings of a type appropriate to the circum-stances and shall be accomplished in accordance with these instructions, procedures or drawings. Administrative Procedure (AP) 301.2 " Nuclear Operations Records Control Procedures", Section 5.3 states in part that records may be retained in a Records - Temporary Storage Facility and that this facility shall be a fire retardant filing cabinet or other fire retardant enclosed storage device or area. Also, the Records - Temporary Storage Facility shall have at least the following controls:
1.
a list of personnel authorized access will be maintained in the immediate area.
o 2.
a log of all QA records or record packages currently in the facility.
3.
the prescribed method of record removal as specified in the Permanent Record System Description will be followed.
Contrary to the above, on February 2, 1981, the training qualification records were not being kept in accordance with AP 301.2 in that:
1.
the records were not retained in a fire retardant filing cabinet, storage device or area.
-2._
a list of personnel authorized access was not maintained.
3.
a log of all QA records in the facility did not exist.
4.
the prescribed method of record removal as specified in the Permanent Record System Description was not followed.
ADMISSION OR DENIAL OF ALLEGED VIOLATIONS S,outh Carolina Electric and Gas Company recognizes this item as a violation of_the aforementioned regulatory requirements.
REASONS FOR VIOLATION It has been.the understanding of_ South Carolina Electric and Gas Company that full implementation of the subject requirements is 'to be effected prior to fuel load.
CORRECTIVE STEPS TAKEN Fire retardant filing' facilities - fire retardant fire cabinets have been obtained cnd training qualification records are being transferred to them.
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NOTICE OF VIOLATION B Page 2 o
CORRECTIVE STEPS TAKEN (Cont'd.)
Authorized Access - A list of personnel authorized access to training qualification records files has been established and is presently maintained in the immediate area of said files.
QA Raccrls Leg - A Quality Assurance Reccrds Lag is being established to conform to the requirements of AP 301.2, " Nuclear Operations Records Control Procedure".
Record Removal - A system for control of records removal is being developed.
This system will conform to the requirements of AP 301.2.
CORRECTIVE STEPS TO BE TAKEN TO PRECLUDE RECURRENCE A meeting with key training personnel will be held to discuss this violation, implementation of the aforementioned corrective steps, and the importance of future compliance to the subject requirements.
DATE OF FUI.L COMPLIANCE All actions stated herein shall be completed by June' 1, 1981.
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