ML20092D456
| ML20092D456 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 05/18/1984 |
| From: | Dixon O SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20092D454 | List: |
| References | |
| NUDOCS 8406220007 | |
| Download: ML20092D456 (6) | |
Text
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,~t south CAROLINA ELECTRIC & gas COMPANY
.o s t es p < a 76 COLWS.A. Scute Camouha 29218 0 W D mo%.sp.
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B4 MAY 24 A 9 : 20 l
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May 18, 1984 l
Mr. James P. O' Reilly Regional Administrator U.S. Nuclear Regulatory Commission Region II, Suite 2900 101 Marietta Street, N.W.
Atlanta, Georgia 30303
SUBJECT:
Virgil C.
Summer Nuclear Station Docket No. 50/395 Operating License No. NPF-12 Response to Notice of Violation NRC Inspection Report 84-08
Dear Mr. O'Reilly:
Please find attached South Carolina Electric and Gas Company's response to the violation as addressed in Enclosure 1 of NRC inspection report 84-08.
Management has analyzed the examples constituting the violation individually to ensure specific corrective measures are established.
Additionally, the examples were analyzed collectively to address potential generic trends of program implementation problems.
Measures have been initiated to project the importance of increased personnel awareness in the execution of the activities in order to make our program implementation more effective.
This action will be complete by July 15, 1984.
Very truly yours,-
O. W.
ixon-
- r. '
HCF:OWD/dwf Attachment cc:
V. C.1 Summer C.
L. Ligon (NSRC)
T.
C. Nichols, Jr./O. W. Dixo n, E J r.
K.
E. Nodland E.
H.
Crews,'Jr.
R. A. Stough
.E.
C. Roberts G.
Percival W. A.
Williams, Jr.
C. W. Hehl D. A.
Nauman
- J. B.
Knotts, Jr.
Group Managers I&E-(Washington)
O.
S. Bradham INPO Records Center C.
A.
Price ANI Library NPCF
~D.
A. Lavigne File 8406220007 840531 PDR ADOCK 05000395 O
PDR-
a.
Mr. James P.
O'Reilly
-NRC Notice of Violation 84-08 Page'Two May-18, 1984-RESPONSE TO NOTICE OF VIOLATION EXAMPLE I INSPECTION REPORT 84-08 I..
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION Sou'th Carolina Electric and Gas' Company is in agreement with the first example of the stated violation.
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II.
REASON FOR THE VIOLATION The subject fire extinguisher is one of a group of fire extinguishers issued for use by maintenance personnel when fire watches are required during maintenance activities (i.e.,
welding, cutting, etc.).
This particular fire extinguisher had not been inspected between the dates of September 1,1983, and March 5, 1984, because of inadequate tracking.
III.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED The subject fire extinguisher was inspected and found to be acceptable.
A subsequent walkdown inspection identified no f-other discrepancies.
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IV.
CORRECTIVE ACTION TAKEN TO AVOID'FURTHER VIOLATION The tracking process was' improved by requiring',the fire extinguishers to be tracked.by a morelin' depth log' book when they are issued.for use.
The modified log details the.
-expiration date of the fire extinguishers to.more readily detect an expired inspection condition.
Also, the-group-
- responsible ~for issuing
- and controlling; fire extinguishers from the Tool Room have. received instructions which1 reinforce their; responsibility and accountability _.for control of;the subject fire extinguishers.
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'DATE OF FULL COMPLIANCE The Licensee is-in full: compliance'with the correctiveTaction.
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-.to this exampleLof the.violatione V
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Mr. James P. O'Reilly NRC Notice of Violation 84-08 Page Three May 18, 1984 RESPONSE TO NOTICE OF VIOLATION EXAMPLE II INSPECTION REPORT 84-08 I.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION South Carolina Electric and Gas Company is in agreement with the second example of the stated violation.
II.
REASON FOR THE VIOLATION On March 20, 1984, wall mounted fire extinguishers No. 34 and No. 37 were identified as not having received the required monthly inspection.
The fire extinguisher inspection portion of the applicable Preventive Test Procedure (PTP) had been signed to indicate its completion on March 10, 1984.
Procedural inadequacies resulted in fire brigade inspector oversight.
The procedure required only a final signoff after the fire extinguisher inspection had been completed.
III.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED The subject extinguishers were inspected satisfactorily.
IV.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION PTP-ll4.002 is being revised to require an inspection sign-off-for each fire extinguisher to more adequately identify potential discrepancies.
V.
DATE OF FULL COMPLIANCE The Licensee is in full compliance with the corrective action to this exampleaof the violation.- PTP-114.002 is presently in the review cycle.and will be-issued by-July 1, 1984.
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- Mr. Jr. mea P. O'R3111y NRC Notice of. Violation 84-08 Page Four..
May 18, 1984 RESPONSE TO NOTICE OF VIOLATION EXAMPLE.III INSPECTION REPORT 84-08 I.
AbMISSIONEOR DENIAL OF THE-ALLEGED VIOLATION South Carolina Electric and Gas Company is in agreement with the third example of'the stated violation.
II.
REASON FOR THE VIOLATION An open quart can of motor oil was found unattended in a safety related area.
The-Licensee considered the oil to be within theLscope of Fire Protection Procedure 003 (FPP-003),
" Control of Transient Combustibles," because:
(a)
This particular quantity of oil was-not required to be controlled by the transient combustibles permit.
(b)
The oil ~was located-a safe distance.of approximately 25 feet away from any. safety-relatedLequipment.-
(c)
The oil'was protected.from ignition sources by a sprinkler supression system.
It is acknowledged that the unattended container constituted poor housekeeping practice.
III.
CORRECTIVE STEPS-TAKEN AND RESULTS ACHIEVED-
'The oil was immediately removed from the safety related area.
IV.
CORRECTIVE ~ ACTION TAKEN TO AVOID FURTHER VIOLATION-The Licensee; plans-to revise FPP-003 to more adequately
' address low fire loading _ combustibles. - Additionally, internal
. correspondence 1has-been. generated.tofincreaseithe: awareness-of-plantffire. watch personne11to recognize and report poor;
~
. housekeeping practice;with respect-to1 potential. fire hazards.
~ DATE OF FULL: COMPLIANCE; V.
ThelLicenseeLis inlfull compliance with'thelcorrectiveLaction
' T to'this' example.of.the' violation.-1FPP-003_will becrevised.by'
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, July l5,71984.,
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-Mr. JCae3 P. O'Railly "NRC Notics ofLViolation 84-08 Page Five May 18, 1984 RESPONSE TO NOTICE OF VIOLATION EXAMPLE IV INSPECTION REPORT 84-08 I.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION South Carolina Electric and Gas Company is in agreement with the fourth example of the stated violation.
II.
REASON FOR THE VIOLATION The wooden storage box identified in the violation was of a medium fire loading which requires control via a transient combustible permit.
Personnel oversight allowed the box to remain in the area.
The Licensee considered the poly bottle aof fuel oil identified to be within the scope of Fire Protection' Procedure 003 (FPP-003) for the following reasons:
(a)
This particular. quantity of fuel oil was of a low fire loading and was not required to be~ controlled-by a transient combustible permit.
(b)
The fuel oil was protected from ignition sources by a sprinkler. system.
However,,the procedure will be revised to more clearly. address combustibles in the low fire ~ loading category.
.It'is recognized that the unattended bottle constituted poor housekeeping practice.
III.
CORRECTIVE STEPS TAKEN'AND RESULTS ACHIEVED Both the wooden storage; box and.the poly' bottle ~of' fuel oil-were removed.from the area.- A subsequents walkdown revealed no
+
e other discrepancies.
IV..
CORRECTIVE ACTIONLTAKEN TO AVOID FURTHER VIOLATION =
'The. Licensee' plans, toirevise FPP-003 ' ta) more. adequately address low fire loading / combustibles.. Additionally, internalf
-correspondence has been generated to increase' the' awareness ofL splantefire watch _ personnel to recognizeLand reportfpoor. house-
-keeping' practice, with respect to potential fire hazards.-
V.-
-DATE OF FULL 1 COMPLIANCE-
~
The Licnesee is -in - full.complianceLwithithe. corrective action -
.to thisiexample of the violation.
FPP-003lwill;be' revised?by
-July:15,11984.-
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_~q Mr. Jcmeo P. O'Railly NRC N:tice of Violction 84-08 Page Six May 18, 1984 RESPONSE TO NOTICE OF VIOLATION EXAMPLE V INSPECTION REPORT 84-08 I.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION South Carolina Electric and Gas Company is in agreement with the fifth example of the stated violation.
II.
REASON FOR THE VIOLATION The area where the welding was to be performed was located approximately six (6) feet below the 436' elevation deck grating of the Turbine Building.
The welder had installed protective screens for that area.
However, the material and the welding electrodes utilized for the welding operation required the welder to make local adjustments on the welding machine for proper heat (amperage) setting.
The welder had left the work area to make the adjustment.
The welder struck a test arc on a piece of scrap material while he was adjacent to the welding machine on the 436' elevation to verify the proper heat setting prior to returning to the work area.
This was a momentary operation (approximately one minute).
The welder then returned to the protective screened work area.
The welder did not remember that he was outside the protective screen area when adjusting the welding machine.
The wood.
scaffolding in question was of treated lumber (fire resistant).
As such, it was not considered to be a combustible material and required no protective covering.
Finally, the " actual" welding operation was performed below the 436' elevation and there were no open deck gratings below the. work area.
Hence, open deck grating protective coverings were not needed.
III.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED The welder and his supervisor were apprised of the situation in an effort to prevent recurrence.
IV.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION All welders and their assistants are required to review FPP-005, " Burn Permit."
V.
DATE OF FULL COMPLIANCE The Licensee is in full compliance with the. corrective action to the violation.
The required reading of FPP-005 will be performed by June 15, 1984.
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