ML20235Y564
| ML20235Y564 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 02/27/1989 |
| From: | Gibson A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20235Y562 | List: |
| References | |
| 50-395-88-26, NUDOCS 8903140329 | |
| Download: ML20235Y564 (3) | |
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i ENCLOSURE 1 NOTICE OF VIOLATION South Carolina Electric & Gas Company Docket No. 50-395 V.C. Summer License No. NPF-12 During the Nuclear Regulatory Commission (NRC) inspection conducted on November 14-18, December 5-9, and December 20-23, 1988, violations of NRC requirements were identified.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions",10 CFR Part 2, Appendix C (1988), the violations are listed below:
A.
Technical Specification 6.8.1 requires that written procedures shall be established, implemented, and maintained for activities recommended in Appendix A of Regulatory Guide 1.33, which include operation of the safety-related systems, planning and performance of maintenance activi-ties, and annunciator response.
1.
Contrary to the above, the licensee failed to implement procedures for planning and performing maintenance, in that Maintenance Work Request 8801131 was released by maintenance planners without the Transient Combustible Permit required by Procedure FPP-003, Control of Transient Combustibles, Revision 7, specifying fire protection requirements.
As a result, on December 7, 1988, a total of 45 drums of charcoal filter material, containing 200 pounds each, were stored in the Auxiliary Building with no compensatory fire protection measures.
2.
Contrary to the above, Annunciator Respnnse Procedure (ARP) for "A" Diesel Generator, ARP-004-XCX-5201, Revision 2, did not receive a review within the allowable 2-year period as required by Procedure SAP-139, Procedure Development, Review, Approval and Control, Revision 11, and was removed by the licensee from Diesel Generator Room "A" on November 3, 1988. The procedure review was subsequently completed and the procedure issued on November 18, 1988.
During the intervening 15-day interval, no approved ARP was available for use in Diesel Generator Room "A".
This is a Severity Level IV Violation (Supplement I).
B.
10CFR50.59 allows the licensee to make changes to the facility as described in the Final Safety Analysis Report (FSAR) unless the change involves a change in the Technical Specifications or an unreviewed safety question. A written safety evaluation which provides the basis for the change must be performed and a description of the change must be submitted in a report to the NRC.
Contrary to the above, the position of 10 fire system manual isolation valves for deluge of charcoal filters in the fuel handling building, reactor building, auxiliary building, and control building was changed from open as described in the FSAR, to closed, some as early as December 5, 1986, and others on or before August 18, 1987. These changes were made 9903140329 G90227 PDR ADOCK 05000395 FDC g
South Carolina Electric & Gas Company. 2 Docket No. 50-395 V. C. Summer License No. NPF without an evaluation of the change and without initiation of appropriate actions to revise the FSAR and operational procedures where required. Also, these changes were not reported to the NRC in the first subsequent annual report in accordance with the provisions of 10' CFR 50.4 and 50.59 (b)(2).
.This is a Severity Level IV Violation (Supplement I).
C.
10CFR50 Appendix B, Criterion VI, Document Control, requires that drawings and' procedures for activities affectire quality shall be reviewed for adequacy prior to issuance.
1.
Contrary to the above, copy. number 9 of safety system Drawing L
'D-302-222, Service Water, Revision 24, was inadequately reviewed prior to its issuance to the control' room on August 5,1988.' As a result, on December 7,1988, this drawing was in use in the control room and was inadequate in that portions were illegible. A subse -
quent audit'by the'liscensee identified 28 additional safety-related drawings that were in use and that were also illegible.
2.
Contrary to the above, procedures for the operation and surveillance of safety related systems were inadequately reviewed prior to issuance and use during November and December 1988.
Errors intro-duced by retyping the procedures included incorrect valve positions in system alignment checklists for at least three valves in SOP-101, Reactor Coolant System, Rev. 17, and at least four valves in SOP-112, Safety Injection System, Rev. 12.
Also, at least two incorrect acceptance criteria were in the surveillance test procedure STP-310.004, Nuclear Instrument System Intermediate Range Calibra-tion, Rev. 6.
This is a Severity Level IV Violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, South Carolina Electric & Gas Company is hereby requirea to submit a written statement or explanation to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC-l 20555, with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector, V. C. Summer, within 30 days of the date of the letter transmitting this Notice. This reply should be clearly marked as a " Reply to a Notice of Violation" and should include [for each violation]: (1) admission or denial of the violation, (2) the reason for the violation if admitted, (3) the corrective steps which have been taken and the result _s achieved, j
(4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time.
If an adequate reply is not received within the time specified in this Notice, an. order may j
be issued to show cause why the license should not be modified, suspended, or
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revoked or why such other action as may be proper should not be taken.
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South Carolina Electric & Gas Company 3
Docket No. 50-395 V. C. Summer License No. NPF-12 Security or safeguards information should be submitted as an enclosure to facilitate withholding it from public disclosure as required by 10 CFR 2.790(d) or 10 CFR 73.21.
FOR THE NUCLEAR REGULATORY COMMISSION (fff 6' Albert F. Gibson, Di ctor Division of Reactor ~ Safety Dated at Atlanta, Georgia this 27thday of February 1989 s