ML20132G027
| ML20132G027 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 07/12/1985 |
| From: | Dixon O SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8508020478 | |
| Download: ML20132G027 (3) | |
Text
- _-_
o e
SOUTH CAROLINA ELECTRIC & GAS COMPANY post oprics 7ea COLUMelA. south CAROLINA 29218
- o. w, Dinos. Jn.
5 JtJL 18 P 8
- 3 7 Vice PNsS@sN' July 12, 19 NuCLean orsnarioms l
Dr.
J.
Nelson Grace Regional Adminis trator U.S. Nuclear Regulatory Commis s io n Region II, Suite 2900 101 Marietta Street, N.W.
Atlanta, Georgia 30323
SUBJECT:
Virgil C.
Summer Nuclear Station Docket No. 50/J95 Operating License No. N P F-12 Response to Notice of Violation NRC Inspection Report 85-23
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 85-23.
If there are any questions, please call us at your convenience.
Very trul
- yours,
/
s/
t O.
W.
Di on, Jr.
MDB:0WD/csw l
Attachment cc:
V.
C.
Summer C.
L.
Ligon ( NS RC)
I 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.
Pe rc iva l W.
A.
Williams, Jr.
C.
W.
Hehl D. A.
Nauman J.
B.
Knotts, Jr.
Group Managers S.
D.
Hogge O.
S.
Bradham I & E (Washington)
C.
A.
Price NPCF S.
R.
Hunt File g8020478850712 o
ADOCM c5000395 PDR 1
l l _f!5fd2 /
a Response to Notice of Violation Inspection Report 85-23 Violation 85-23-01 1.
Admission or Denial of the Alleged Violation 4
South Carolina Electric and Gas Company (SCE&G) is in agreement with the violation in that the hanger conditions noted were not in conformance with design drawings.
1 II.
Reason for the Violation Records indicate the hangers noted in the violation (Hangers EFH-4010, CCH-153, SWH-4021) received their last inspection at the completion of construction of the Virgil C. Summer Nuclear Station per Construction Quality Control (QC) Instruction MF-9.
Documentation of the construction inspections reflects acceptable installation of the three hangers. The deficiencies noted on Hanger EFH-4010 (cotter pin missing from the strut connection) and Hanger SWH-4021 (maximum angular tolerance was exceeded for one of the struts assembly installation) are not attributed to insuf ficient QC inspection. There is evidence that the cotter pin was installed and that the excess ive angular tolerance of the strut was caused by pipe movement. The deficiency noted with Hanger CCH-153 (washers were missing for the f our embedded anchor bolts) 'is considered an isolated event to which no. specific cause can be attributed. Additional hanger inspections and a review of past inspections are described in Section III of this report.
III. Corrective Steps Taken and Results Achieved The deficiencies noted with the NRC identified hangers were immediately corrected. An engineering evaluation of the deficiencies determined that the hangers were capable of performing their design function.
Fur the r,
i the Licensee initiated a random sample inspection of additional hangers.
Of the 24 hangers inspected, three deficiencies were identified, corrected and evaluated for operability. Two of the three discrepancies did not affect the operability of the respective hangers. The third discrepancy would have prevented the hanger from performing its design function; however, the affected piping system would have remained operable.
The Licensee also reviewed the inspection. reports on 140 hangers inspected during the 1984 Refueling Outage. Of the 140 inspected, one deficiency was identified and corrected at that time. The deficiency concerned a missing locking device. A thorough review indicates that upset threads j
may not have been visible to the inspector through paint. The hanger was i
disassembled, and a locking device appropriately applied before the thread upset could be verified.
In either case, the deficiency would not have prevented the hanger from performing its design func t ion. Of the 175 hangers evaluated, none of the deficiencies would have resulted in the loss of system function.
.N
Response to Notice of Violation Inspection Report 85-23 Violation 85-23-01 III. Corrective Steps Taken and Results Achieved Cont.
Mechanical Maintenance Procedures (MMP) 200.00 and 305.004 were reviewed for adequacy in controlling the removal, reinstallation and inspection of pipe supports. A sample of the documentation associated with maintenance activities requiring hanger removal and replacement was f ound to be complete. These programmatic controls for pipe support removal, installation and inspection are considered adequate and being properly applied.
IV.
Corrective Action Taken to Avoid Further Violation The use of the formalized maintenance controls and the ongoing Inservice Inspection (ISI) program are considered adequate to assure the maintenance of hanger integrity. As a supplemental ef fort to provide additional program assurance of the continued adequacy of these formal programs,
SCE&G is instructing QC personnel to observe the condition of hangers throu ghou t the plant during routine housekeeping inspections.
V.
Date of Full Compliance SCE&G is in compliance with the corrective actions given above as of this date.
.