ML20247E413
| ML20247E413 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 05/16/1989 |
| From: | Bradham O SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8905260247 | |
| Download: ML20247E413 (5) | |
Text
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th Caro In2 Electric & Gas Company Ollie d tm Jenkinsville. SC 29065 Nuclear Operations (803) 345-4040 A aCANnCurveny May 16, 1989 Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
Virgil C. Summer Nuclear Station Docket No. 50/395 Operating License No. NPF-12 Response to Assessment Open Issues NRC Inspection Report 89-05 Gentlemen:-
Enclosed is the South Carolina Electric & Gas Company (SCE&G) response to the assessment open issues addressed in Enclosure. I of NRC Inspector Report 50-395/89-05..The enclosed response addresses the open issues and. the actions being taken to resolve each issue.
Very truly yours,
- 0. S. Bradham HID/0SB: led Enclosure c:
D. A. Nauman/0. W. Dixon, Jr./T. C. Nichols, Jr.
E. C. Roberts W. A. Williams, Jr.
G. O. Percival S. D. Ebneter R. L. Prevatte J. J. Hayes, Jr.
J. B. Knotts, Jr.
General Managers NSRC C. A. Price /R. M. Campbell, Jr.
NPCF R. B. Clary-RTS (IE 090501, 02, 03, 04 & 05)
K. E. Nodland File (815.01)
J. C. Snelson s 1 r
t.
__ to Document Control Desk Letter Mdy 16, 1989 Page 1 of 4 I.
WEAKNESS:
Incomplete implementation of adopted Electric Power Research e
Institute (EPRI) chemistry guidelines for secondary water chemistry.for sulfate and cation conductivity (50-395/89-05-01).
ASSESSMENT:
The guidelines were adopted, and were used in developing station e
procedures. Sufficient flexibility was incorporated into the procedures to allow deviation from the guidelines with management review and approval.
Initial actions were consistent with the guidelines. Subsequent actions were considered to meet the intent of the guidelines (i.e., cleanup the secondary system as quickly as possible), and were based on the best available information at the time, including discussions with EPRI. When further information became available, the plant was shut down in i
accordance with station procedures.
ACTIONS:
e We have committed to notify the NRC via the Emergency Notification System within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of deviation from the approved EPRI Steam Generator Water Chemistry recommended corrective action statements.
DATE:
This commitment is already in effect and will continue through e
Refuel 5, scheduled for the Spring of 1990.
II.
WEAKNESS:
Lack of followup on ALARA action items by the ALARA Review e
Committee. (50-395/89-05-02)
ASSESSMENT:
i SCE&G management agrees that improvement is warranted in both the e
followup and completion of ALARA action items.
I
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' to Document Control Desk Letter
.May 16, 1989
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.Page 2 of 4 ACTION:'
e The status'of all ALAP,A action items will be discussed at each regularly scheduled ALARA Committee meeting.-- Each responsible
. party will be: required to provide the ALARA Committee with action item status and progress toward completion which will be documented in the meeting minutes. Should the committee
' determine that additional' emphasis or higher priority be~given to
- a. project, the committee will make such recommendations to management.
DATE:
This commitment will be in effect by August 1, 1989.
e III.
WEAKNESS:
Minimal use of the ALARA suggestion program (50-395/89-05-03).
e ASSESSMENT:
SCE&G agrees with the identified weakness.
Improvements are e
needed to the ALARA Suggestion Program.
ACTION:-
During the next regularly scheduled ALARA Committee meeting e
(second quarter, 1989) improvements to the ALARA Suggestion Program will be discussed including ways to elevate the program's visibility and encourage suggestions. ALARA suggestion programs from other plants will also be reviewed.
DATE:
Program improvements will be implemented by September 30, 1989.
IV.
WEAKNESS:
. Slowness in completion of evaluation of review of dose reduction e
initiatives (50-395/89-05-04).
__ -to Document Control Desk Letter.
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'Miy 16, 1989 Page 3 of 4 ASSESSMENT:
Although the completion of some dose reduction initiatives have taken several years, SCE&G does not consider their evaluation to be unjustifiably slow.. ALARA initiatives are always given due consideration along with other equally important capital improvements through the established planning and prioritization program.
ACTIONS:
RTD bypass replacement and the reactor vessel head shield installation have been scheduled. Other ALARA initiatives such as system decontamination and cobalt reduction are continuing to be evaluated and,.if approved, will be implemented in a timely manner. Source term reduction in the primary is being pursued through the incorporation of smaller mesh primary system filters, thus removing smaller particulate matter.
DATE:
RTD bypass is scheduled for Refuel 5 (Spring 1990) and reactor e
vessel head shield installation is scheduled for Refuel 6 (Fall
.1991).
V.
WEAKNESS:
Infrequent use of still photographs, video tapes, and mockups for e
valve and pump maintenance training (50-295/89-05-05).
ASSESSMENT:
Some valve and pump maintenance training has contained the use of mockups, including courses on Chem Pumps, Charging Pumps, and training on Limitorque Valves. Additionally, a scale model of a reactor coolant pump seal is available and is used in pre-outage training on seal maintenance. Slides (35mm) of some pump and valve maintenance evolutions currently exist in Health Physics Job Code files. The ALARA Pre-Job Review and Checklist form has an item to prompt the HP Planner to evaluate the current slide file for adequacy.
I ACTIONS:
e A camcorder has been ordered so that selected in-progress maintenance evolutions can be filmed and used more frequently in pump and valve maintenance training.
The Training Instruction that covers the development of lesson e
plans will be revised to require the developer to consider the use of photographs, video tape, and mockups, that would support the station's ALARA Program.
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' to Document Control: Disk Letter
.'May 16, 1989 Page 4 of 4 A recommendation for constructing a multi-discipline, practical, e
hands-on training capability, utilizing additional pump and valve mockups, is being evaluated.
Refresher training for HP personnel on the use of existing job code files.in pre-outage briefings, which contain pictures / slides, will be conducted.
DATES:
o The camcorder will be available for use by June 30, 1989.
The Training Instruction that covers the development of lesson-e plans will be revised by June 30, 1989 to require the developer to consider the use of photographs, video tape, and mockups, that would support the station's ALARA Program.
The recommendation for constructing a multi-discipline, e
practical, hands-on training capability will be evaluated by September 30, 1989.
Refresher training for HP personnel on the use of job code-e file slides will be completed by September 30, 1989.
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