ML20127B198
| ML20127B198 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 05/10/1985 |
| From: | Dixon O SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8506210377 | |
| Download: ML20127B198 (3) | |
Text
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SOUTH CAROLINA ELECTRIC & GAS COMPANY POST OFFICE 764 COLUMBIA. SOUTH CAROUNA 29218 3}
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- o. W. OtaON. Ja.
e VICs P.Esto NT May 10, 1985 uuCte. o,
..r,0 Dr.
J.
Nelson Grace Regional Administrator U.S.
Nuclear Regulatory Commission Region II, Suite 2900 101 Marietta Street, N.W.
Atlanta, Georgia 30323 i
SUBJECT:
Virgil C.
Summer Nuclear Station Docket No. 50/395 Operating License No. NPF-12 Response to Notice of Violation NRC Inspection Report 85-11
Dear Dr. Grace:
Attached is South Carolina Electric and Cas Company's response for the Violation addressed in Enclosure 1 of NRC Inspection Report 85-11.
If there are any questions, please call us at you r convenience.
Very truly yours, 4
4 0.
W.
Di o CJM:0WD/ led Attachment ec:
V.
C.
Su mme r C.
L.
Ligon ( NS RC)
T.
C.
Nichols, Jr./0.
W.
Dixon, Jr.
K.
E.
Nodland E.
H.
Crews, Jr.
R.
A.
S t ou gh E.
C.
Roberts G.
Percival W.
A.
Williams, Jr.
C.
W.
Hehl D.
A.
Nauman J.
B.
Knotts, Jr.
Group Managers I& E (Wa s hin g t on)
O.
S.
Bradham NPCF C.
A.
Price File S.
R.
Hunt jDOCK05000395 0377 850510 DR G
PDR.
Z2 01
ENCLOSURE 1 RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT 85-11 1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION South Carolina Electric and Gas Company is in agreement with the alleged violation.
II.
REASON FOR THE VIOLATION St ation Adminis t rative Procedure (SAP) 141, " Control and Ca l ib ra t ion of Measuring and Test Equipment (M&TE),"
e s t ab lis he s the programmatic controls f or De f ect iv e Precision Instrument Reports (DPIR).
The failure to establish time constraints on DPIR evaluations with safety implications is a t t r ib u t ed to personnel oversight during the preparation and review of SAP-141.
Factors which mitigate the consequences of this oversight are:
1.
The M&TE program is based on hardware performance.
Adverse trends in calibration drif t or failures of M&TE are corrected by either replacement of the instrument or increasing the c a l ib ra t ion frequency to prevent performance adverse to quality.
2.
The initial reviews performed by the Instrument and Control technicians and their supervisor r e s po n s ib l e for a means of the research and preparation of DPIRs p r ov id e early detection and c o r r e c t iv e action for significant M&TE errors which potentially c ou ld impact the safety function of plant equipment.
III.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED Increased emphasia has been placed on the timely completion of DPIR reviews.
On May 1, 1985, there were only 10 outstanding reports of greater than 3 months which had not been reviewed.
The Licensee has not identified any M&TE error which impacted the safety fu n c t i on of plant equipment during these reviews.
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IV.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION The Licensee will review and revise SAP-141.to ensure that the duties and responsibilities relating to ou t-o f-calib r a t ion M&TE are properly clarified.
Additionally, a time' constraint of 90 days for evaluation of DPIRs with potential for adverse impact'on safety related equipment will be established in the revision.
V.
DATE~OF FULL COMPLIANCE South Carolina Electric and Gas Company will be in full compliance by July 19, 1985.
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