ML20247D848
| ML20247D848 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 05/11/1989 |
| From: | Bradham O SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8905260018 | |
| Download: ML20247D848 (4) | |
Text
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10CFR2-.201 South Carollra Electric & Cas Company Ollie adham Jenkinsville, SC 29065 Nuclear Operations (803) 345-4040 May 11, 1989 j '.
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Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555 p
Subject:
Virgil C. Summer Nuclear Station Docket No. 50/395 Operating License No. NPF-12 Additional Response to N3tice of Violations NRC Inspection Report 88-026 Gentlemen:
This letter provides the South Carolina Electric & Gas Company (SCE&G) follow-up response to the Notice of Violations dated February 27, 1989. See Attachment III, Part 1A, which has been revised to address the corrective actions being taken for Violation 88-26-03, " Legibility of Drawings."
If'you should have any questions, please advise.
Very truly yours,
- 0. S. Bradham
' HID/0SB: led Attachment c:
D. A. Nauman/0. W. Dixon, Jr./T. C. Nichols, Jr.
E. C. Roberts W. A. Williams, Jr.
G. O. Percival General Managers R. L. Prevatte S. D. Ebneter J. B. Knotts, Jr.
C. A. Price /R. M. Campbell, Jr.
NSRC R. B. Clary RTS (IE 882601 & 882603)
J. R. Proper NPCF K. E. Nodland File (815.01)
J. C. Snelson f
~S905260018 890511 pg goa moocxosooms 1
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-Attachment III to 0:cument Control Desk Letter May 11, 1989 Page 1 of 3 ATTACHMENT III (Updated)
RESPONSE TO NOTICE OF VIOLATION VIOLATION NUMBER 50-395/88-26-03 and 89-01 PART 1A I.
ADMISSION OR DENIAL OF THE VIOLATION South Carolina Electric & Gas (SCE&G) is in agreement with the alleged violation.
II..
REASON FOR THE VIOLATION Inadequate indoctrination of Document personnel with respect to drawing legibility requirements.
III.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED A.
The twenty-nine (29) drawings which contained illegible data have been replaced with fully legible drawings.
B.
A change to the drawing control procedure, DCP-103 was issued on 3/7/89 to programmatically address action to be taken when illegible drawings are received or discovered in use.
C.
The requirements of drawing controlled distribution, especially legibility, have been emphasized to Document unit personr,el.
D.
A complete review of all drawings in the Control Room was conducted on 1/20/89 and all illegible drawings that were identified have been replaced. Two additional reviews have been made to ensure quality is maintained, the last being on 3/13/89.
The Control Room drawings with illegible data have been identified and resolved except for forty six (46) 304 series drawings and five (5) IMS series drawings all of which have been identified to Design Engineering for disposition.
It should be noted that these 304 and IMS drawings are "non-essential".
IV.
CORRECTIVE ACTIONS TAKEN TO AVOID FURTHER VIOLATIONS A.
Document Control Procedure DCP-103 was revised and issued 4/28/89.
It provides a specific legibility definit. ion.
DCP-103 also now includes the following Design Engineering disposition options upon the identification of illegible essential drawings:
1.
Do not issue, Engineering will have print redrawn.
2.
Do not issue, Engineering will have print enhanced.
3.
Quality accepted for intended use, issue.
Attachment III to Document Control Desk Letter May 11, 1989 Page 2 'of 3 d.
Best available copy, issue drawing.
Quality will be improved in future revisions.
5.
Other.
B.
The quality upgrade of drawing reproduction is planned through the purchase of more advanced reproduction equipment.
C.
All drawings issued to the Control Room are being reviewed by the Document Supervisor until it is evident that all the clerks understand and fully adhere to the legibility requirements.
D.
Documented training for all Document Clerks is on-going to ensure their full understanding of the legibility requirements and the need to maintain high standards.
E.
A Task Force of Documents, Design Engineering and Operations i
. personnel was tasked with a review of the drawing legibility problem.
i The results of the Task Force Meeting are:
1)
Essential drawings will be defined as those drawings needed in the Control' Room by Operations to operate the plant on a day to day basis.
Operations also maintains Class 1 and 2 (as indicated below) drawings that may be consulted periodically for additional information.
If clarity becomes a concern, the actions specified for the particular class will be followed.
2)
Architect / Engineer (A/E) Drawing series were assigned to one of three categories.
Class 1 - A/E drawings used by the plant on a day to day basis to do work. Written and graphic information must be 100% legible.
Class 2 - A/E drawings occasionally used by plant personnel.
The " User" of the drawing will determine if legibility is adequate for the intended use.
If not, Design Engineering will be contacted to provide information (if alternate source of information is not known by the user) and/or
)
enhance the drawing.
Class 3 - A/E drawings not used by plant personnel in the conduct of normal operation and/or maintenance. These drawings will not be enhanced at this time.
J
. Attachment III to Document Control Desk Letter
,' May 11, 1989 l
Page'3'of 3 l
l 3)
Manufacturer's drawings will be considered as Class 2 A/E drawings in that the user will identify to Design Engineering those drawings or portions of drawings which are not adequate for their intended use. Alternate sources are generally available for the type of information used on
' hese drawings.
V.
DATE OF 7JLL COMPLIANCE A.
ES-416 will be revised by July 30, 1989.
B.
Class 1 and identified illegible Class 2 drawings or portions thereof will be made legible by July 30, 1990.
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