ML20059J914

Responds to Violations Noted in Insp Rept 50-395/90-21. Violation Occured,However Description of Violation in Error. Corrective Action:Valve XVT02803B Placed in Proper Position & Verification of Emergency Feedwater Sys Lineup Completed

ML20059J914
Person / Time
Site:	Summer
Issue date:	09/14/1990
From:	Bradham O SOUTH CAROLINA ELECTRIC & GAS CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9009210043
Download: ML20059J914 (3)

Text

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j$$ - o le S. ed m O So th rollne El*ctric & GIs Company Jenkinsville. SC 29065 Nuclear Operations

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September 14, 1990 i

4 Document Control Desk 7 U. S. Nuclear Regulatory Commission a, Washington, DC 20555

Subject:

Virgil C. Summer Nuclear Station Docket No. 50/395 Operating License No. NPF-12 Response to Notice of Violation NRC Inspection Report 90-21 Gentlemen:

Attached is the South Carolina Electric & Gas Company (SCE&G) response to the violation addressed in Enclosure-1 of NRC Inspection Report 50-395/90-21.

SCE&G is in agreement that a violation occurred; however, the description of the violation is in error. Clarification of the description of the violation

-is contained in the respor.se as well as the reason for the violation and the corrective actions being taken to prevent recurrence.

If you should have any questions, please advise.

Very trely yours,

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0..S.- Bradham DCH/OSB: led Attachment c: 0. W. Dixon, Jr./T. C. Nichols, Jr.

r E. C. Roberts R. V. Tanner J. B. Knotts, Jr.

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S. D. Ebneter J. W. Flitter

-J. J. Hayes, Jr. NSRC General Managers NPCF

.C. A. Price RTS (IE 902101)

NRC Resident Inspector File (815.01)

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9009210043 900914

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Attachment 1 to Document Control ~ Letter- '

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' September 14,.1990 k

- Page ILof 4 i

RESPONSE TO NOTICE OF V10LATION  :

VIOLATION NUMBER 50-395/90-21-01

l. ADMljSION OR DENIAL OF VIOLATION  !

South Carolina Electric & Gas Company (SCE&G) is in agreement that the imprcper positioning of valve XV1028038-MS is a violation. However, the Licensee denies that this violation constitJtes a " failure to Take ,

Adequate Corrective Action" based on the two previous events that are referred.to:in the Notice of Violation. The Licensee has determined that the improper valve alignment occurred prior to the implementation of corrective action for violation 90-18-01. Therefore, the corrective i action taken for that violation could not have prevented this occurrence. Also, it is'important to note that, because the mispositioned component was not subject to independent verification, this event does not constitute a failJre or inadequacy of the- .

.i Independent Verification Program. Therefore,-the Licensee does not consider this event to be a third example of the previous violations.

II. REASON FOR THE VIOLATION The reason for the violation is personnel error. The valve was

-apparently mispositioned by either maintenance or operations personnel  !

during maintenance and retest activities on the trip / throttle valve for ,

the Turbine Driven Emergency'Feedwater Pump (TDEFP). These activities  :

took place on June 26 and 27, 1990, which was prior to the' August 10, 1990, response.to violation 90-18-01.

A statement made irtthe Notice of Violation with respect to the r frequency of the valve alignment verifications per S0P 201, " Main Steam System," is incorrect in that these verifications are not performed nor  !

are they required to be performed on a monthly basis. The most recent performance of the S0P-201 alignment prict to this event took place on May 1, 1990. Therefore, the Licensee disagrees with the implication that the cause of the violation is associated with the performance of SOP-201. The surveillance test which was performed as a retest for-the .

maintenance activity did not require manipulation of the valve in

-quertion, and therefore did not require an' independent verification of

- t. Ive's position, p

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• Attachment'I to Document Control Letter '

w y iSeptember 14, 1990 1 M' -

Page 2 of 2

>; =l 111. CORRECTIVE STEPS TAKEN AND'RESULTS ACHIEVED.-

Valve XVT028038-MS was placed in its proper position and a: verification y of the' Emergency feedwater System ~line-up was completed. The results of L the verification showed that no other valves were mispositioned. a L With the exception of the initial line-up, valve XVT028038-MS is not required to be manipulated during the performance of any operating

• J procedure;.therefore, the valve has been." danger tagged" in the closed.

position. 'The mispositioning of valve'XVT028038-MS did not result in an-inoperability.of the TDEFP.and there was no adverse effect on the ability of the system to perform its design function.

I IV. CORRECTIVE ACTIONS TAKEN TO AVOIO FURTHER VIOLATION AND DATE OF FULL i COMPLIANCE- -

Operations management has met with all operating shift personnel to-stress the requirements and the importance of procedural compliance.

Actions are being taken that will identify valves which are frequently 1 manipulated during plant operations such that they may be relabeled to-1 enhance the identification of the component. The relabeling will be completed by December 15, 1990. -t A review of. surveillance test procedures (STP) has been made to identify STP's which manipulate valves during the test but do not include them in- .I the " return as-found" alignment. The STP involved in the retest activities was identified as needing a procedure change to expand the.

." return as-found" alignment. This will be completed by November 1, :i 1990.= i o

Also, a-letter will'be distributed to all Nuclear Operations Division personnel to> emphasize the administrative requirements which dictate.

that all equipment is to be manipulated or directly controlled by 1 Operations personnel-only. The only-exception is manipulations which, 1 i are directed by other department's approved procedures containing.

,, configuration controls equivalent to those used by the Operations y Department. This letter will be issued by. September 28, 1990.

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