ML20078Q879
| ML20078Q879 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 12/23/1994 |
| From: | Skolds J SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9412230108 | |
| Download: ML20078Q879 (3) | |
Text
r South C;rolin1 Electric & G:s Company John L Skolds P.O. Box 88 Senior Vee Prssident Jenkinsville. SC 29065 Nuclear operations (803)345-4001 SCE&G
^ *** W Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555 Gentlemen:
Subject:
VIRGIL C. SUMMER NUCLEAR STATION DOCKET NO. 50/395 OPERATING LICENSE NO. NPF-12 RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 94-24 This letter provides South Carolina Electric & Gas Company (SCE&G) response to a Notice of Violation delineated in NRC Inspection Report No. 50-395/94-24.
South Carolina Electric & Gas Com ny is in agreement with this violation. Detailed response to this violation is attach Should you have any questions, please call at your convenience.
Very truly yours, 4[9(a John L. Skolds RAM:ews i
Attachment 1
c:
O. W. Dixon J. B. Knotts Jr R. J. White S. D. Ebneter.
R. R. Mahan S. F. Fipps G. F. Wunder NRC Resident inspector J. W. Flitter NSRC Central File System RTS (IE 942401)
File (815.01)
Q NUCLEAR EXCELLENCE-A SUMMER TRADITION!
941223o100 941223
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PDR ADOCK.05ooo395 Q
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Att chmtnt I to Docum:nt Centrol' Desk Lctt:r e
IE 942401 Page 1 of 2 RESPONSE TO NOTICE OF VIOLATION e
VIOLATION NUMBER 50-395/94-24-01 l
[
.l.
RESTATEMENT OF VIOLATION i
i 10 CFR 50, Appendix B, Criterion V, " Instructions, Procedures, and l
Drawings," requires that, " activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to -
the circumstances and sha'l, be accomp'lished in accordance with these instructions, procedures, or d rawinc s.
Paragraph 4.1 of the Operational l
Quality Assurance Plan which describes requirements for procedural i
development and usage states in part,... " activities which affect the ability of safety-related structures, systems or components to perform their intended function must be governed by written procedures."
Contrary to the above, on October 26,1994, a cleanliness cover was discovered missing on "A" steam generator secondary manway opening.
A final cleanliness mspection the steam enerator secondary side had already been performed. Approximatel four days earlier a cleanliness i
cover was also discovered missing for a s milar steam generator opening.
l The actual causes for the missing cleanliness covers could not be determined. However based on a review of the applicable work related documents it was determined that adequate instructions for cleanliness control were not provided.
ll.
SCE&G POSITION ON THIS VIOLATION South Carolina Electric & Gas Company (SCE&G) is in agreement with the violation as stated.
i Ill.
REASONS FOR THE VIOLATION This violation occurred during steam generator replacement activities.
These activities were procedurally controlled by SCE&G procedures and a
work documents as well as contractor procedures and work documents.
Interviews with personnel who performed work on the steam generators l
have determined that the clean liness covers had been installed, that the workers were aware of the requirement for the covers, and that the workers were knowledgeable of the direction provided by the procedures and work documents.
The permanent steam generator manway covers were being installed by SCE&G personnel at the time of this occurrence.
i
I
-.4 Att: chm::nt I to Docum:;nt Centrol Desk Lettsr
." ' IE 942401 Page 2 of 2 Interviews with personnel involved identified that the cleanliness covers were secured to the vertical surface of the steam generator with safety related duct tape. It is believed that the duct tape did not adh9re sufficiently to ho!d the cleanliness covers in place and the covers fell off the manways while station personnel were not in the area.
The cleanliness control program at Virgil C. Summer Nuclear Station is prescribed in SAP-142,
- Station Housekeeping Program"; GMP-100.003, Personnel, Material, Tools, and Equipment Accountability"; and SAP-300,
" Conduct of Maintenance". SCE&G provided foreign material exclusion control training to maintenance personnel as part of continuing training i
during 1993.
The cleanliness control p,,rogram for associated contractor activities is prescribed in SAP-1022, Guidelines for Controlling Contractor and Non-Station SCE&G Work A :tivities" and WP/P10, " Housekeeping".
SCE&G procedural requirements governed the work being performed relative to " A" steam generator during the time specified in this violation.
IV.
IMMEDIATE CORRECTIVE ACTIONS in response to the missing cleanliness cover, SCE&G issued a nonconformance notice requiring another cleanliness inspection of the "A" steam generator prior to installation of the permanent manway cover.
The steam generator was inspected and the manway tem 3orarily covered on October 28,1994. No foreign material was found insic e the steam generator.
V.
CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATIONS SCE&G considers that the programs for cleanliness control in effect at the V. C. Summer Nuclear Station are adequate to preclude further violations.
A VI.
DATE FULL COMPLIANCE WILL BE ACHIEVED SCE&G is currently in full compliance.
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