ML20237C798
| ML20237C798 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 12/10/1987 |
| From: | Nauman D SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8712220191 | |
| Download: ML20237C798 (5) | |
Text
_ _. _ _ _ - _.
So m Caro na Electric & Gas Company Dan au n Columbia, SC 29218 Nuclear Operations 4
(803) 748-3513 SCE&G December 10, 1987
{
M -. 4 14 e i : 04 Dr. J. Nelson Grace Regional Administrator U. 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 NPF-12 Response to Notice of Violation NRC Inspection Report 87-30
Dear Dr. Grace:
1 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-
- 30. SCE&G is in agreement with the alleged violations, and the enclosed responses address the reasons for the violations and corrective actions to I
prevent recurrence. As requested, additional information relative to the Unresolved Item is also provided.
If you should have any questions, please advise.
ru{yours, r
7 Al. - k D
auman HID/ DAN:jez Enclosures c:
- 0. W. Dixon, Jr./T. C. Nichols, Jr.
R. M. Campbell, Jr.
E. C. Roberts R. A. Stough
- 0. S. Bradham J. C. Snelson D. R. Moore G. O. Percival Group Managers R. L. Prevatte W. R. Baehr J. B. Knotts, Jr.
C. A. Price I&E Washington R. B. Clary Surveillance Systems W. R. Higgins RTS F. J. Leach NPCF C. L. Ligon (NSRC)
File 8712220193 g7323o gDR ADOCK 05000395 PDR 6
an
-Enclosure 1 to Dr. J. Nelson Grace Letter Page 1 of 2 December 10, 1987 ENCLOSURE 1 RESPONSE TO NOTICE OF VIOLATION VIOLATION NUMBER 50-395/87-30-01 I-ADMISSION OR DENIAL 0F THE ALLEGED VIOLATION South Carolina Electric & Gas Company (SCE&G) is in agreement with the alleged violation.
II.
REASON FOR THE VIOLATION During a.walkdown of conduits and junction boxes to obtain sample data i
relative to installation of splices, the RII inspection team noted a Raychem splice with a bend radius of less than the allowable bend radius and a Raychem protective sleeve which was not properly shrunk.
It was also noted that both installations were inspected by the same quality control inspector.
The lack of attention to procedural detail by maintenance and quality control personnel during installation of the RHR pump motor lead repair sleeve.which was performed in 1982, resulted in the improperly shrunk sleeve deficiency. Relative to the Raychem bend radius i
deficiency, at the time of' installation (1985), plant procedures governing the installation / inspection of Raychem products did not address the restriction on the bending of splices. However, subsequent to the 1985 time period, procedures were revised to include the minimum bend radius acceptance criteria.
It should be noted that a recent industry test report has confirmed that a Raychem splice completely bent 180*, as was the configuration cited at Virgil.C. Summer Nuclear Station, can perform its design basis function.
III.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED The specific RHR pump motor lead repair sleeve was reheated and properly shrunk. The splice with the minimum bend radius deficiency has subsequently been replaced with a new splice within the allowable bend radius.
.- to Dr. J. Nelson Grace Letter Page 2 of 2 December 10, 1987 l
IV.
CORRECTIVE ACTION TAKEN'TO AVOID FURTHER VIOLATION Installation / inspection procedures have provided details for installing Raychem sleeves in an acceptable manner since 1986.
Raychem representatives have provided on-site refresher training to maintenance and quality control personnel on the correct installation of Raychem products.
In addition, a program is underway to reinspect and replace, as necessary, those splices which do not meet the
. acceptance criteria.
V.
DATE OF FULL COMPLIANCE Refresher training for installation of Raychem Products has been conducted and was completed on December 3, 1987. The reinspection / replacement program is scheduled to be completed prior to startup from the 4th refueling which is scheduled for the 4th Quarter of 1988.
J 4
4
. to Dr. J. Nelson Grace Letter Page 1 of 1 December 10, 1987 ENCLOSURE 2 RESPONSE TO NOTICE OF VIOLATION VIOLATION NUMBER 50-395/87-30-02 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 The violation resulted from the fact that the original EQ analysis for taped splices did not take into consideration the use of a V stub l
taped splice configuration, and the applicable drawings / procedures did not reflect the requirement to seal the crotch areas of the V stub taped splices. These omissions resulted in the splice being installed 4
in an unqualified configuration. This condition had previously been i
noted by SCE&G and reported to RII prior to the inspection.
III.
CORRECTIVE ACTION TAKEN TO AVOIO FURTHER VIOLATION The EQ File, CA7-K03-0682, has been updated to reflect the similarity analysis for the V stub taped splice configuration. Drawing S-200-912 will be revised to include a configuration make-up of a V stub taped i
splice that is acceptable, by similarity, to that which was qualified including sealing of the crotch area. Electrical maintenance procedure EMP 405.003 has already been revised to reflect the acceptable V stub taped splice configuration.
Instrument and Control 3
(I&C) procedures ICP 240.132 and 300.012 will also be revised to reflect the acceptable V stub taped splice configuration.
j V.
DATE OF FULL COMPLIANCE i
Drawing S-200-912 will be revised no later than February 29, 1988.
I&C procedures will be revised / issued no later than December 31, 1987.
The identified taped splices are being inspected and all the V stub splices will be reworked or repaired, as necessary, to conform to an acceptable configuration. This work will be completed prior to startup from the 4th nfueling, presently scheduled for the 4th Quarter of 1988.
l
r
. ;,-. to Dr. J. Nelson Grace Letter c,
'Page 1 of 1 i
December. 10, 1987
~
ENCLOSURE 3 RESPONSE TO UNRESOLVED ITEM NUMBER 50-395/87-30-03 I.
ITEM Unresolved Item 50-395/87-30-03, Ambient Temperature Greater Than Design.
II.
RESPONSE'
.At the time of the RII inspection, the West Penetration Area.
Elevation 436, was found to be at an temperature of approximately 118'F. A subsequent investigation of the West Penetration Area HVAC syr, tem by SCE&G revealed that the system was operating at approximately 25% capacity with only one (1) out of four (4) intake / exhaust fans running. The HVAC system was restored to 100%
capacity and the ambient temperature again measured with a result of 89"F at the s'ame location. This temperature is less than the 104*F FSAR design value.
SCE&G is in the process of developing a Temperature Monitoring Program to document and track ambient temperature profiles in selected areas of the plant. This data will be collected for.approximately one (1) year and used as additional design basis information to confirm postulated ambient temperatures and/or to revise design basis ambient temperatures. The program is scheduled to be initiated during the 4
first Quarter of 1988. Any required adjustment in Qualified Life of EQ equipment will be made based on the re-evaluated design basis area ambient temperatures.
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