ML20128P478

Responds to Violations Noted in Insp Rept 50-395/85-22. Corrective Actions:Surveillance Test Procedures Addressing Inservice Insp & Code Requirements Will Require Review of Inservice Insp/Maint Engineering Group

ML20128P478
Person / Time
Site:	Summer
Issue date:	07/10/1985
From:	Dixon O SOUTH CAROLINA ELECTRIC & GAS CO.
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8507260422
Download: ML20128P478 (4)

Text

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. '. de s SOUTH CAROLINA ELECTRIC & GAS COMPANY PC t C.sece 744 cotuusia. soutw cAnouuA assis O. W Deso=. J.-

v.c. e...... ' Ju1y 10, 1985 uvet... o,...r.o . ca ut c-C2 r-Dr. J. Ne ls on Crace .-

Regional Administrator '"

U.S. Nuclear Regulatory Commission p Region II, Suite 2900 e 101 Marietta Street, N.W. =+

Atlanta, Georgia 30323 s

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SUBJECT:

Virgli C. Summe r Nuclear Sta tion Docket No. 50/395 Operating License No. NPF-12 Response to Notice of Violation NRC In s pe c t ion Report 85-22

Dear Dr. Grace:

Attached is South Carolina Electric and Gas Company's response to the Violation as addressed in Enclosure 1 of NRC Inspection Report 85-22.

If there are any questions, please call us at your convenience.

Very truly yours,

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0. W. Di on, r-RMF:0WD/ led Attachment cc V. C. Summe 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 C. Pe rc iva l W. A. Wi lliams , Jr. C. W. Hehl D. A. Nauman J. B. Knotts, Jr.

Croup Managers S. D. Hogge O. S. Bradham I &E (Washington)

C. A. Price NPCF S. R. Hunt File a

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• ENCLOSURE 1 RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT 85-22

1. ADMISSION OR DENIAL OF THE ALLEGED VIOLATION South Carolina Electric and Gas Company (SCE&G) is in agreement with the alleged violation as stated below.

l II. REASON FOR THE VIOLATION The reason for the violation is a t t r ib u t ed to inadequate procedure review. The Licensee c ons id er s this to be an isolated case due to the na tu r e and scope of the procedure in v o lv e d . Surveillance Test Procedure ( S T P )-15 0.001, " Re ac t o r Coolant System (RCS) Leak Test," e s t ab lis he s the boundaries for leak testing of the entire RCS in accordance with Technical Specification Surveillance Requirement 4.0.5 and ASME Code Section XI. The inspector identified seven (7) deficiencies with respect to this procedure and leak testing of the RCS.

1) The procedure did not include piping and valves beyond the first closed va lve at the end of the class boundary and omitted the flow restrictors which are identified as RCS pressure boundaries in many small lines.

2) The procedure did not p r ov id e a means to assure that examination points were not inadvertently bypassed.  ;

3) The procedure uses "shouid" indicating permissiveness, wher e "sha ll" wou ld be more appropriate for specifying requirements.

4) The procedure did not include acceptance criteria consistent with the requirements of Technical Specification 3.4.6.2(a) and (d).

5) The procedure does not p r ov id e steps for the verification of the ope rab ility of leakage detection systems required by subsection IWA-5243 of the Cod e .

6) The procedure does not include in f orma t ion regarding locations to be examined and how they are to be accessed ,

to avoid unneces sary rad ia t ion exposure.

7) The procedure provides no verification for r equired va lve ,

manipulations.

Also id en t i f ied as part of this violation was a deficiency in STP-123.003, " Service Wate r Sys tem Va lve Oper abilit y Tes t ."

The procedure did not contain acceptance criteria for the testing of check valves in c lud ed in the survelliance test to address the concerns of IEB 83-03.

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s III. CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED

1) Action has been taken by the Licensee to in c lud e the boundaries in question into STP-150.001. The flow restrictors will be tested under STP-115.008,

2) Each test performer is required by SAP-134 to document the areas of the RCS for which he performed a VT-2 inspection.

This shouId preclude an inadvertent bypassing of required test points.

l 3) The use of "shouId" will be deleted from the procedure.

4) Clarification of the acceptance criteria will be addressed in the next revision to STP-150.001. However, the purpose of this procedure is not to satisfy Technical Specification 3.4.6.2 but to sat is f y the requirements of ASME Code Section XI per Technical Specification 4.0.5.

Other surveillance test procedures address the requirements of Technical Specification 3.4.6.2.

5) The valve stem and vessel flange leakage collection systems are Code Class 2 or non-code class piping and as such are ou t s id e the scope of the requirements of this procedure. The pump seal leakage collection system has been p r ev i ou s l y included in STP-150.001.

6) Conduct of this test is under the provisions of the Radiation Work Permit program for specification of expected radiological conditions. The test is performed by quellfled Operations personnel familiar with plant conditions, procedural requirements, plant s ys tems , and the location of points to be e x a min ed . It is not the intent of this procedure to p r ov id e guidance to the extent that it couid be performed by a person unfamiliar with plant procedures and s ys te ms .

7) The next revision of STP-150.001 will incorporate the va lve position verification requirements.

In addition, STP-123.003 has been revised to include l acceptance criteria for the testing of check valves in the service water supply to the diesel generators.

IV. CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION The Licensee has taken the following action to avoid fu r ther violation. Surveillance test procedures which addres s inservice inspection and code requirements will require the I review of the ISI/Haintenance Engineering Gr ou p. The Licensee fg expects this action to p r ov id e the necessary review to ensure that the surveillance test program con f orms with the applicable Code requirements.

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V. DATE OF FULL COMPLIANCE SCE&G expec ts to be in full compliance with respect to the s tated correct ive action by August 15, 1985.

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