ML20033D324
| ML20033D324 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 10/26/1981 |
| From: | Nichols T SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20033D318 | List: |
| References | |
| NUDOCS 8112070529 | |
| Download: ML20033D324 (3) | |
Text
-
4 fj<
i;,.
- e USNRC REGION :I E
f {j SOUTH CAROLINA ELECTRIC JLpAK $QAPAFif C D O A A I-POST OFFICE BOX 764 f
CotuMaiA, SOUTH CARollNA 29218 e
d, ldd10CT '29 P l. $
/ I T. C. NichoLs, JR.
October 2 6, j ' ' wer Petsiotwe Ano Gaous bachnvr
/
NuCLEAs OrtainCMS Mr. James P. O'Reilly, Director U.S. Nuclear Regulatory Commission
/
Region,II, Suite 3100 101 Ma'rietta Street, N.W.
' Atlanta, Georgia 30303
Subject:
Virgil C. Summer Nuclear Station Docket No. 50/395 RII: JLS-50-395/81-23 1
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 August 1 through August 31, 1981.
Specifically, we have addressed the violation concerning review of procedures by Quality Assurance.
'Should you have questions or comments, please contact us at your j
corvenience.
j I declare the statements and matters set forth herein are true and correct tp the best of my knowledge, information, and belief.
Very truly yours, WJA s i(
T.C. Nichols, Jr.
JIIP/TCN/bsg Attachment
'/
cb V.C. Summer J.L. Skolds
.J G ll. Fischer J.B. Knotts, Jr.
II. N. Cyrus I6E (Washington)
/
/
T.C. Nichols, Jr.
NPCF O.W. Dixon, Jr.
File D.A. Nauman W.A. Williams, Jr.
R.B. Clary 0.S. Bradham A.R. Koon A.A. Smith II. Radin M.N. Browne II.E. Yocom B.A. Bursey
+
J.C. Ruoff f
n rp i,
[r 8112070529 811117
/
I',
PDR ADOCK 05000 j
a
[..
^ ;, p.
N,' q.
y Page 1 of 2 SOUIH CAROLIfA ELECTRIC & GAS CO.
VIRGIL C. SUP9ER NUCLEAR STATION, UNIT #1 DOCKET NO:
50-395 REPORT NO:
RII: JLS 81-23 NCrfICE OF VIOIATION EVENT DATE: August 1-31, 1981 DESCRIPTION OF EVENT 10CFR50, Appendix B, Criterion V, requires activities affecting quality be prescribed by doctanented instructions, procdires or drawings cumugiate to the ciretanstances.and shall be aucamplished in accordance with these instructions, p ocedures or drawings.
Section 4.5.2 of the Operational OA Plan requires OA review of the
{
Start-up Manual prior to implementation. Section 4.6 of the Operatinal OA Plan requires that changes to procedures receive a level of review equivalent to the applied to the original s veadures.
(bntrary to the above, changes to the Start-up Manual did not receive a level of review equivalent to that applied to the original Irocedures in that 04 did not review minor changes Erior to implementation.
ADMISSIm OR DENIAL OF ATJRmn VIOLATIWS SCE&G recognizes that this itesn constitutes a violation of.the aformentioned regulatory requirements in that minor danges were made in the Start-up Manual that changed the intent of the procedures and did not receive a review equivalent to that applied to the
. original pocedures as required by Sections 4.6 and 4.5.2.
REASWS FOR VIOLATION The reasans for the violation are two-fold. First, % en the start-up program was developed, minor' changes were rxt considered changes since they were defined to greclude alteration of the intent-of procedures, and therefore be outside the' scope of the OA Plan _ review:
purposes. Second, the OA Plan review Iequirenents were developed after the start-up program and minor changes were not. addressed based on the logic that minor-(no intent modification). & anges:were not considered changes and therefore~neal not be addressed.
'Ihe poblem leading to the violation occurred een minor changes were male,that changed the procedure intent whid fell within the QA Plan
. review rammts. At this point a OA Plan violation occurred sich H
was not detected within. the reviow, surveillance,.or atulit efforts of.
F-the OA Program.. Also,: it now became apparent that the logic used to ~
. contend that mirur changes do not constitute changes may not be :
_1
. clearly,sugued en a pogram basis..
4:
, ~._i_-
4
,i' W
r
,3' g,
h
- s 2
, u _-
._2_ w d__
g
1 Page 2 of 2 Report Not RII:
JIS 81-23, Notice of Violation I
CORRECTIVE STEPS T!AN ao correct the conditions noted in the violation and eliminate the j
possible weaknesses in logic regarding minor changes, the following intermediate actions have been taken:
l a) Revision 3 of SIM-B-3 was approved on September 4,1981, deleting all references to " minor d anges."
b) ?.he V. C. Stauner Quality Assurance Group has reviewed.and 1
concurred with all minor changes affected. This review confirmed the changes could not have jeopardized the safety j
of operations of the V. C. Sunener Nuclear Station at any time.
c) The 3CEsG QA Section has assa==M th potential for similar groblens existing in other sveadure review cycles. 'the conclusion is that a very low Irobability exists for this condition to be elsewhere since other sucedures under the @
t Plan do not utilize the " minor change" logic, the @
participation.in the rev.ew cycles as tracked within @
indicates that grocedures are being reviewed, and surveillance and audits to date have revealed few grablems concerning review cyc.'les.
CORRECTIVE STEPS TAKEN '!O PPurrnns' RECURRENCE The Manager, V. C. Sununer Nuclear Station, will coordinate efforts with the Quality Assurance Group in assuring that frequent @.
surveillances include trovisions.for assuring conformance to the Irocedure review grogram and that the requirements of the operational l
[
Quality Assurance Plan are implananted in a timely manner.
DATE OF PtEL C00FLIANCE 4
b South Carolina Electric & Gas Ompany anticipates being in full ompliance with the above statements by !bvember 1,1981.
~ '
a s
k s
L
~
d
'v m
m 9p 1
=
9
._