ML20064D984
| ML20064D984 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 11/18/1982 |
| From: | Dixon O SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20064D957 | List: |
| References | |
| NUDOCS 8301040804 | |
| Download: ML20064D984 (7) | |
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s SOUTH CAROLINA ELECTRIC & GAS'COM'PANYL O 'i Post orrics 7e4
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vics passiosNr NucteAn OPanATIONs November 18, 1982 Mr. James 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 Operating License No. NPF-12 Notice of Violation NRC Report 82-50
" Fire Protection" I
Dear Mr. O'Reilly:
On August 27, 1982, South Carolina Electric and Gas Company (SCE&G) submitted an interim report to the Nuclear Regulatory Commission Region II concerning noncompliance with the provisions of Operating i
License item 2.0.(18).
The purpose of this letter is to provide a final report on the matter.
In addition, the enclosed attachments provide a response to the Notice of Violation as addressed in Appendix A of Inspection Report 82-50.
The Phase I and II walkdowns, as described in the August 27, 1982, letter, have been completed.
They identified any existing discrepancies that would require resolution.
This effort was completed under the Operations Quality Assurance Plan and was audited and found satisf actory by NRC Region II Inspector Mr. W.
H.
Miller during his inspection visit on September 21 - 24, 1982.
All discrepancies which were identified as part of the Phase I and II walkdowns have been resolved.
All associated work was completed on November 5, 1982.
This provides completion of the immediate corrective action that has been taken by SCE&G.
8301040004 821203 PDR ADOCK 05000395 G
Mr. James P. 0'Reilly NRC Notice of Violation NRC Report 82-50 Page Two November 18, 1982 Long term corrective action and action taken to prevent recurrence have been implemented.
These actions include development of necessary repair and Quality Control Procedures for the identification and resolution of fire barrier deficiencies and completion of the review of the Fire Protection Evaluation against plant design documents to assure identification and resolution of
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any discrepancies.
In addition, SCE&G has developed and implemented the " Quality Related Plan for Fire Protection," which specifically provides programmatic controls and responsibilities within SCE&G to assure continued compliance with design and regulatory commitments.
Thir document provides cpecific guidelines for the fire protection decign control to assure that future design changes are programmatically addressed to maintain the Fire Protection System in accordance with the Fire Protection Evaluation, FSAR, and regulatory requirements.
l If additional information on this matter is desired, please call us at your convenience.
Very truly yours, O. W.
Dixon, Jr.
ARK /0WD/dwr Attachments cc:
V.
C.
Summer A.
R.
Koon T.
C.
Nichols, J r.
H. Radin G.
H. Fischer Site QA 0.
W.
Dixon, Jr.
C.
L. Ligon (NSRC)
H.
N.
Cyrus G. J. Braddick H. T.
Babb J.
L.
Skolds D.
A.
Nauman J. B. Knotts, Jr.
M.
B.
Whitaker, Jr.
B.
A.
Bursey W.
A.
Williams, Jr.
I&E (Washington)
O.
S.
Bradham Document Management Branch R.
B.
Clary NPCF M. N.
Browne File
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Mr. James P. O'Reilly NRC Notice of Violation a
NRC Report 82-50 Page Three November 18, 1982 ATTACHMENT I RESPONSE TO NOTICE OF VIOLATION A INSPECTION REPORT 82-50 i
I.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION South Carolina Electric and Gas Company is in agreement with the stated violation.
II.
REASONS FOR VIOLATION As described in our August 27, 1982 letter, a number of factors contributed to the previously described deviations from the Fire Protection Evaluation.
These were as follows:
i 1.
A proper construction drawing interface review was not performed to assure the drawings incorporated all require-ments of the Fire Protection Evaluation.
It should be noted that at the time the drawings were finalized, a formal design verification program was not required in the Fire Protection Area.
2.
At the time of license issuance installation of fire barriers had not been completed, and the assessment of l,
fire barriers that was made to determine where to post Tire watches did not identify all deficiencies that l
existed.
III.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED A " Phase I" walkdown program was instituted consisting of a visual inspection of designated fire areas and fire rated assemblies where design drawing discrepancies were identified.
The action statements of the applicable sections of the Technical Specifications were met for all discrepancies identified during the Phase I walkdown.
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9 Mr. James P. O'Reilly NRC Notice of Violation NRC Report 82-50 Page Four November 18, 1982 ATTACHMENT I Continued A " Phase II" walkdown program was developed and completed.
This provided an engineering design review team to ensure all applicable design drawings used for construction were consistent with the Fire Protection Evaluation.
Under this Phase II program, a walkdown checklist was developed for use to ensure all designated fire areas had fire rated assemblies, as required.
This walkdown utilized construction quality control and operations personnel to perform a 100%
walkdown of all fire areas.
For all discrepancies identified during the Phase II walkdown, action was taken to meet the Technical Specifications.
Necessary procedures and revisions relating to construction completion activities have been developed and implemented to cover all aspects of the Fire Protection Program.
All of the above activities are being performed under the criteria of the Operational QA Plan with in depth QA input and review.
The text of this letter provides a synopsis of the results achieved to date.
IV.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATIONS The long term corrective actions and the actions taken to prevent recurrence are as discussad in the August 27, 1982, letter, and as further discussed in the text of this letter.
They will provide a comprehensive pecgram to preclude further violations.
V.
DATE OF FULL COMPLIANCE Correction of fire barrier deficiencies was completed as of Novembe r 5, 1982.
Mr. James P. O'heilly NRC Notice of Violation NRC Report 82-50 J
Page Five November 18, 1982 ATTACHMENT II RESPONSE TO NOTICE OF VIOLATION B (ITEM B.1, LOCKED VALVE VIOLATION)
I.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION South Carolina Electric and Gas Company is in agreement with the stated violation.
II.
REASONS FOR VIOLATION The locked valve program at the Virgil C.
Summer Station was established using flow diagrams, which show valves which are to be locked.
The Fire Service flow diagram does not reflect that the valves identified in Fire Protection Evaluation Section 5.E.3.(b) are to be locked.
Therefore, the only valves which were locked were the outside Post Indicator Valves.
III.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED Valves listed in Section 5.E.3.(b) were immediately verified i
open and locked in the open position.
No valves were found in the closed position.
The monthly surveillance procedure which requires a position verification was revised to reflect valves which were to be locked open.
IV.
CORRECTIVE ACTIONS TAKEN TO AVOID FURTHER VIOLATIONS Valve lineup verification procedures were revised to indicate valves listed in Section 5.E.3.(b) are to be locked open at all times, unless required to be closed for maintenance or casualty actions.
V.
DATE OF FULL COMPLIANCE Procedure revisions have been issued and locks were installed by September 24, 1982.
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Mr. James P. O'Reilly NRC Notice of Violation NRC Report 82-50 Page Six November 18, 1982 ATTACHMENT II RESPONSE TO NOTICE OF VIOLATION B (ITEM B.2, WOOD VIOLATION)
I.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION South Carolina Electric and Gas Company is in agreement with the stated violation.
II.
REASONS FOR VIOLATION The stated violation resulted due to the nature of the work for which the wood was being used.
A decision was made to continue the sealing of fire barrier penetrations rather than stop the work and remove the combustible wood and await the delivery of fire retardant treated wood.
The non-treated wood was a holdover from earlier construction activities.
During the construction phase, controls on the use of wood throughout the plant were not as stringent as are required in the operations phase.
This resulted in the use of combustible non-treated wood in the plant.
III.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED Non-treated combustible wood will not be used within the protected area at the station.
An effort was undertaken and is on going to ensure the removal of all non-treated combustible wood from within the protected area.
The controls as set forth in Section 5.3.3.(c) of the Fire Protection Evaluation are being enforced fully at the site.
IV.
CORRECTIVE ACTIONS TAKEN TO AVOID FURTHER VIOLATIONS Non-treated combustible wood will not be used within the protected area of the plant.
A periodic inspection program of all buildings containing safety-related equipment has been implemented.
This inspection includes checks for the use of non-treated combustible wood and is conducted under the direction of the Fire Protection Program Coordinator.
V.
DATE OF FULL COMPLIANCE Final completion and removal of all non-treated wood is anticipated by November 30, 1982.
Mr. James P. O'Reilly NRC Notice of Violation NRC Report 82-50 Page Seven November 18, 1982 ATTACHMENT II RESPONSE TO NOTICE OF VIOLATION B (ITEM B.3, FIRE HOSE VIOLATION) l I.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION South Carolina Electric and Gas Company is in agreement with the stated violation.
II.
REASONS FOR VIOLATION Interior fire hoses had been hydrostatically tested on July 12, 1982.
Due to an error in the surveillance procedure not identifying subject hose rack as containing 100 f eet of hose, the testers were unaware that the subject hose was required to be in the Technical Support Center cabinet.
Therefore, following the testing of the hoses, the subject hose was placed in a hose rack in the Service Building.
III.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED An immediate search was conducted to locate the missing fire hose.
The hose was located to be in a Service Building hose rack.
The hose was removed from the Service Building and replaced in the hose rack in the Technical Support Center and that hose was placed into the rack in the Service Building.
IV.
CORRECTIVE ACTIONS TAKEN TO AVOID FURTHER VIOLATIONS Procedures for inspecting and tes ting of interior fire hoses were revised to reflect the requirement for the Technical Support Center fire hose to be 100 f eet.
V.
DATE OF FULL COMPLIANCE Final completion of corrective items was September 24, 1982.
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