ML20236E995
| ML20236E995 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 10/21/1987 |
| From: | Nauman D SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8710300095 | |
| Download: ML20236E995 (8) | |
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South Caronna Electric & Gas Company Den A.Nauman P.O. Box 704 -
Vice President u
29218 -
Nuclear Operations SCE&G ASCAffs % wy Qqto$eh'21 1987
.& nQ l Dr. J. Nelson Grace V. S. Nuclear Regulatory Commission Region II, Suite 2900-101 Marietta Street, NW Atlanta, Georgia 30323-
SUBJECT:
Virgil C. Summer Nuclear Station Docket No. 50/395 Operating License No. NPF-12 Response to Notice of Violation NRC Inspection Report 87-20
Dear Dr. Grace:
l Enclosed are the South Carolina Electric & Gas Company (SCE&G) responses to=
the violations addressed in Enclosure 1 of NRC Inspection Report 50-395/87-20.
SCE&G is in agreement with the alleged violations, and the enclosed responses address the reasons'for the violations and corrective actions to prevent recurrence.
If-you should have any questions, please advise.
r,.r y ours, s
O A.
man AMM/ DAN:bjh Enclosures pc:
- 0. W. Dixon, Jr./T. C. Nichols, Jr.
W. R. Higgins 1
E. C. Roberts K. E. Nodland
- 0. S. Bradham J. C. Snelson D. R. Moore G. O. Percival W. A. Williams, Jr.
.R. L. Prevatte Group Managers J. B. Knotts, Jr.
W. R. Baehr RTS C. A. Price NPCF W. T. Frady File C. L. Ligon (NSRC)
R. M. Campbell R. B. Clary fd10300095 871021 PDR ADDCK 05000395 G
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ENCLOSURE 1 RESPONSE TO NOTICE OF VIOLATION VIOLATION NUMBER 50-395/87-20-01
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ADMISSION OR DENIAL OF 'lHE ALLEGED VIOLATION l
SouthCarolinaElectric&GasCompany(SCE&G)isinagreementwiththe-alleged violation.
II.-
REASON FOR THE' VIOLATION Ouring the review of design modification packages, the inspector noted that several packages generated by the Licensee appeared to be lacking in the area of design input specifications.. Regulatory Guide 1.64, Revision 2, endorses ANSI N45.2.11-1974, " Quality Assurance Requirements for the Design of Nuclear Power Plants," to which SCE&G is committed. The ANSI Standard states that applicable design inputs are to be identified, documented and their selection reviewed and approved..These-inputs include design bases, regulatory requirements,
' codes and standards. The inspector did.not find in the design packages where the necessary information was formally identified as design input. The packages' contained a collection of statements and
-information, but did not formally distinguish between design inputs, assumptions, and other pertinent information.
Therefore, the inspector concluded that the intent of the ANSI standard had not been met.
SCE&G's design change program utilizes a Technical Work Record (TWR) approach to document the process. Various detailed procedures describe the requirements to be included in each design package and the TWRs document each of these requirements.
The TWR' are detailed summaries, written in each engineer's own style and words, of his process for completing.the design package. While the procedures contain guide lists for specific areas which must be addressed --
e.g., design inputs and various possible regulatory aspects --
1 specific checklists are not included in the program since the TWRs are expected to document the necessary inputs.
Howeve*, because each TWR is written in each engineer's own words, a listing of specific requirements may not be formally included in the TWR sheets in one readily identifiable section.
III.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVE 0 The design change program and specific design packages were discussed with the inspector in an attempt to explain the program and address his specific concerns. The inspector noted in his report that an l
overall improving trend was evident.
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PAGE 2.
IV.-
' CORRECTIVE ACTION TAKEN T0 AVOID FURTHER VIOLATION i
' Procedures currently in existence address the concerns which were
- identifled..by thezinspector..To correct the deficiencies identified byLthe NRC, SCE&G.will conduct ~ additional' training for the engineers-to ensure that.they can more. effectively implement the requirements contained in the established procedures.
V.
DATE OF FULL COMPLIANE Training.will be comp 1eted by-December: 31,1987.
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ENCLOSURE 2 RESPONSE TO NOTICE OF VIOLATION VIOLATION NUMBER 50-395/87-20-02 I.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION South Carolina Electric & Gas Company (SCE&G) is in agreement with the alleged violation.
II.
REASON FOR THE VIOLATION Technical Specifications Section 3/4.7.11 lists th9 nximum Service i
Water pump room' temperature as 102*F. During walu as of the Service Water. Pump house by the NRC on two separate occasions, temperatures in various parts of the pump room as measured with a hand held thermometer were between 1* and 4*F above this limit.
The control l
room indication for the pump room temperatures during both of these
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events. remained below the 102*F limit.
The temperature detectors for 1
the control room indicators were checked and verified to be accurate.
The temperature detectors for the pump rooms are currently located in 1
the inlet to the exhaust duct located near the ceiling and in the ceiling corner directly across from the exhaust.
The detectors were placed there after performing a survey to determine the average ambient room temperature and extrapolating the assumption that less dense, warm air would rise. This helped to ensure that the 2
temperature detectors would sense a conservative ambient room temperature. However, this assumption was not verified as part of the f
design process and therefore could not be proven to the inspector at l
the time of the audit.
During the inspector's visit, it appeared that I
temperature stratifications could exist at different levels in the room.
l III.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED The design change process which was utilized to place the temperature detectors in their present locations was discussed with the inspector.
It was explained that subsequent changes to the modification program had been made which provide for more thorough justification and
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implementation of design changes.
It was also explained that the 102*F maximum room temperature limit was based on the most limiting equipment qualification requirements in the entire building l
(switchgear room) and was not representative of the equipment in the pumproom; therefore, no safety concerns were present.
The inspector was informed that a modification to increase circulation in the room would be investigated.
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p-ENCLOSURE 2 l
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IV.. CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION Since the modification.was performed to move the temperature detectors, the design change program has been changed to. include
'various. additional pre-and post modification steps.. These steps-include.a more detailed post modification testing program. LHad these-steps been in. existence at'the time'this modification was performed,.
there would have been-verification.that the detectors were in fact accurately placed.
To support this fact, a detailed temperature survey.of the, room has been conducted. With one train of. ventilation.
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in. operation,' temperature readings were taken at both five feet and'15 feet above floor level. Conclusions of this survey. indicated that the detectors are currently located.in the most appropriate positions to sense the room ambient-temperatures.for which equipment qualification requirements are based. Therefore, based'on these:results, no modifications are needed.to the' ventilation system.. However, a
-Technical Specifications change is being generated'by-SCE&G to_ request raising.the maximum allowable pump room temperature to a value which more realistically reflects the equipment qualification requirements q
for that room.
V.
DATE OF' FULL COMPLIANCE A proposed Technical Specifications change will be presented to the NRC for their review by December 31, 1987.
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ENCLOSURE 3 RESPONSE'TO NOTICE OF VIOLATION VIOLATION NUMBER 50-395/87-20-03 l
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ADMISSION OR' DENIAL OF THE-ALLEGED VIOLATION South Carolina Electric & Gas Company (SCE&G)is in agreement with the alleged violation.
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-II.
' REASON FOR THE VIOLATION t
System Operating Procedure (S0P) 117, " Service Water System," lists the required flow for the Service Water, pump oil. coolers as 3 to 4 gallons per minute for the lower. bearing and 10 to 12 gallons per minute for the upper bearing. During a system walkdown performed by.
the inspector..the lower bearing flows for both Service Water pumps i
were found to be 2.2 gallons per minute and the flow on the "B" Service Water pump. upper bearing was found to be 8.0 gallons per minute. The minimum required flows found on the operator's trend log were lower than that required by the SOP, and the as-found values were within those allowed by the logs. Therefore, the discrepancy between the operator's logs and the S0P allowed the condition to exist.
The Service Water motor data plate lists specific motor restart j
requirements in order to protect the motor windings from over-heating and causing winding damage. The manufacturer required that' prior to restart, the operator wait five minutes after the first start, and then 20 minutes if the motor was not running and 45 minutes if the
'I motor was running before the third start. While operations personnel were aware of there requirements, S0P 117 did not specifically list them in the precautions section of the procedure.
III.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED Upon identification of.the flow discrepancies, the flows to both the upper and lower bearings were increased in accordance with S0P 117.
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IV.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION System Design Descriptions were reviewed to verify the correct flows i
required to the upper and lower bearings to the pump oil cooler.
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values designated in 50P 117 were verified to be correct and the operator's trend logs were changed to reflect these values.
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. ENCLOSURE;3 e
PAGE.2 S0P 117 was revised to include the motor. restart requirements in the-precautions ~section of the procedure.. In addition, procedures for all other 7.2KV motors will.be: reviewed to ensure.the. appropriate ~ starting
~ duties'.are identified and proper lubrication' flows exist, where required,-'.on the operator'silogs..
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DATE'0F FULL' COMPLIANCE SCE&G'wiilcompletethereviewsbyDecember31,1987.
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q ENCLOSURE 4 i
RESPONSE T0.N0TICE OF VIOLATION VIOLATION NUMBER 50-395/87-20-04 i
I.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION South Carolina Electric & Gas Company (SCE&G)'is in agreement with the alleged violation.
II.
REASON FOR THE VIOLATION The audit report identified two_ Licensee audit reports which did not provide " evidence or subsequent implementation verification," and
" adequate attention was not given to the corrective actions for deficiencies identified in the 1985 and 1986 Security Audits."
The causes of'these violations are due to inadequate procedures and training of personnel. Although the Quality Assurance Department 3
procedures do specify that specific attention be given to previous findings, they do not adequately describe a programmatic method of evaluating and documenting the results.
In addition, specific training has not been given; therefore, not all reports have adequately documented evaluations of previous findings.
III.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED l
The specifics of this violation have been discussed with the Surveillance Systems QA personnel.
Since the identification of the problem, each audit report has a section specifically identified as
" previous audit findings." The details of the QA review and any followup actions deemed appropriate are documented in that section.
IV.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION i
Quality Assurance procedures will be revised to more fully describe j
the necessary evaluations and documentation which will be required to assure that previous audit findings are given the proper attention.
Specific training will be given to all Surveillance System QA personnel which will describe how to evaluate and document their evaluation of previous findings.
V.
DATE OF FULL COMPLIANCE The procedure changes and training will be completed by December 31, 1987.
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