ML20054H049

Responds to NRC Re Deviations Noted in IE Insp Rept 50-395/82-26.Corrective Actions:Conducted QC Insp of Emergency Lighting Battery Packs & Will Ensure That Future Installation of Units Conducted Under QA Program

ML20054H049
Person / Time
Site:	Summer
Issue date:	05/25/1982
From:	Nichols T SOUTH CAROLINA ELECTRIC & GAS CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20054H041	List: IR 05000395/1982026 ML20054H040 ML20054H049 ML20054H057 ML20054H067
References
NUDOCS 8206220524
Download: ML20054H049 (4)

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SOUTH CARoldNA ; ELECTRIC & GAS COMPANY O'EdT twhics sox 7s4 COLUMBI A. S. C. 29218 NI2 kNh* 23) 1982 Mr. J. P. O'Reilly, Director U. S. Nuclear Regulatory Commission Region II, Suite 3100 101 Marietta Street, N.W.

Atlanta, GA 30303

Subject:

Virgil C. Summer Nuclear Station Docket No. 50/395 Inspection Report 82-26

Dear Mr. O'Reilly:

Attached is South Carolina Electric and Gas Company's response to the referenced report which summarizes Mr. W. H. Miller, Jr.'s inspection of March 30 through April 2, 1982.

Specifically, we have addressed the two deviations concerning the installation and inspection of the emergency battery powered lighting units.

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 any questions or comments, please contact us at your convenience.

Very truly yours, k l Nichols, h s]"W Jr.

y T. C.

Senior Vice President Power Operations HCF:TCN,jr:dwf Attachment cc: V. C. Summer A. R. Koon G. H. Fischer H. Radin O. W. Dixon, Jr. Site QA H. N. Cyrus C. L. Ligon (NSRC)

H. T. Babb G. J. Braddick D. A. Nauman J. L. Skolds M. B. Whitaker, Jr. J. B. Knotts, Jr.

W. A. Williams, Jr. B. A. Bursey O. S. Bradham I&E (Washington)

R. B. C'_ary NPCF M. N. Browne File 8206220524 820611 PDR ADOCK 05000395 0 PDR

SOUTH CAROLINA ELECTRIC & GAS COMPANY VIRGIL C. SUMMER NUCLEAR STATION, UNIT #1 Description of Events

1. 392/82-26-02 Section 5.D.5(a) of the Fire Protection Evaluation Report, dated July 1977, Revisions 1-8, states that fixed emergency lighting consisting of sealed beam units with individual 8-hour minimum battery power supplies is provided in the control room, control room evaluation panel rooms, ESF switchgear room in the l Intermediate Building; generator local control panel and motor control center areas in the Diesel Generator Building; the ESF switchgear and motor control center rooms on elevations 412' and 463' in the Auxiliary Building; and along access and egress routes to these areas.

Contrary to the above, the lighting units for all of the above areas, except the ESF switchgear room in the Intermediate Building, are not supplied by a battery unit rated for a duration of eight hours. Also, individual battery lighting units were not installed in the generator local control panel and motor control center areas in the Diesel Generator Building.

2. 395/82-26-03 Response to FSAR Question 421.77 states that the QA program will be applied to the installation and preoperational testing of fire protection equipment and that the QA program for fire protection is part of the overall QA program. Installation, testing and subsequent operations for areas containing safety related equipment are processed by procedures similar to those utilized for safety related work.

Contrary to the above, the individual battery powered emergency lighting units required by the Fire Protection Evaluation Report dated July 1977, Revisions 1-8, Section 5.D.5(a) for areas needed for operation of safe shutdown were not installed and tested under a QA program.

Admission or Denial of Alleged Deviations South Carolina Electric & Gas Company (SCE&G) recognizes that a portion of these items constitute a deviation of the aforementioned commitments, in that all areas requiring individual 8-hour battery units presently do not have them and that no QA t

program was administered to the installation or acceptance testing of the units. However, units which are installed with two or fewer lamp heads do meet the 8-hour requirement, as stated in the manufacturer's literature.

Reasons for Deviations The reason for the deviations is that at the time of installation the system was not considered fire protection equipment and was installed as a backup to the installed D-C powered essential lighting system. Therefore, no QA/QC inspections of the installation was deemed in order.

The problem leading to the deviation occurred when a ruling was made that the battery powered lighting units were fire protection equipment.

The name plates on the installed battery units list that the batteries will provide power for seven (7), 12-watt lamp heads for one and a half (1.5) hours. However, a review of the manufacturer's literature has revealed that the battery units are rated for eight (8) hours for two (2), 12-watt bulbs. At the time of the inspection, one (1) battery unit was discovered to be supplying three (3) lamp heads versus two (2) as called for.

Corrective Steps Taken To correct the conditions noted in the deviations, the following immediate actions have been taken:

a. A QC inspection of the installation of the emergency lighting battery packs was made. This inspection was performed to verify: (1) the installed locations of the emergency light heads and battery packs to be in accordance with the reference drawings; (2) the model number of each battery pack and light head; and (3) that battery packs and light heads were installed in all areas called for by Section 5.D.5(a) of the Fire Protection Evaluation.

b. The V. C. Summer Start-Up Test Group will perform operability tests to verify that emergency lights will operate upon a loss of normal lighting to the affected area and an 8-hour " burn" test to verify the manuf acturer's rating. (These tests will be conducted following the completion of the QC installation inspection and resolution of the QC findings.)

Upon completion of the QC inspection, a Nonconformance Notice,

1. 1485E, was issued showing that nine (9) units were not installed in accordance with the reference drawings. From this, a Purchase Order (#N307274) was issued to acquire the necessary fixtures to complete installation in all areas. Once installation and inspection is complete, SCE&G Start-Up Test Group will perform the aforementioned tests.

Correction Steps Taken to Preclude Recurrence The Manager, V. C. Summer Nuclear Station, will coordinate efforts to ensure that future installation of emergency battery lighting units are conducted under the QA program established for Fire Protection Equipment.

Date of Full Compliance SCE&G anticipates being in full compliance with the aforementioned statements prior to Fuel Load, t

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