ML20247J693

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Forwards Response to NRC Re Violations Noted in Insp Rept 50-395/88-31.Search of Containment Structure Conducted Prior to 881210 Restart of Reactor.Safeguards Contingency Plan to Be Reviewed & Revised by 890630
ML20247J693
Person / Time
Site: Summer South Carolina Electric & Gas Company icon.png
Issue date: 03/27/1989
From: Bradham O
SOUTH CAROLINA ELECTRIC & GAS CO.
To: Lieberman J
NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 8904050076
Download: ML20247J693 (3)


Text

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10CFR2.201 Sogth C:rolina El1ctric & G s C:mpiny Ollis dhim 1

enkinsv e SC 29065 Nuclear Operations SCE&G l

l March 27, 1989 S M UMDS E DRATON l

Mr. James Lieberman Director, Office of Enforcement U. S. Nuclear Regulatory Commission Washington, DC 20555 Attention: Document Control Desk l

Subject:

Virgil C. Summer Nuclear Station Docket No. 50/395 Operating License No. NPF-12 Reply to Notice of Violation and Proposed Imposition of Civil Penalty NRC Inspection Report 88-31

Dear Mr. Lieberman:

On March 2, 1989, the Nuclear Regulatory Commission (Region II) issued a Notice of Violation and Proposed Imposition of Civil Penalty for alleged violations of HRC requirements at the South Carolina Electric & Gas Company (SCE&G)VirgilC.SummerNuclearStation(VCSNS).

1 SCE&G is in agreement with the facts as set forth in paragraphs I.A, I.B and II. of the Notice. SCE&G is in partial agreement with paragraphs I.C and I.D with the following clarifications. The date of the events described in paragraphs 1.C and 1.0 of the Notice is incorrect and should be November 11, 1988.

In relation to paragraph 1.D, SCE&G does not agree that a violation occurred. SCE&G does agree that a search may be prudent; however, the extent and scope should be commensurate with the circumstances of the event. Event 3A of the Safeguards Contingency Plan requires that a search of affected areas be conducted only if the initial assessment indicates that foul play is l

indicated. SCE&G determined that no foul play was involved and no unauthorized access to the containment had occurred; consequently, no search was conducted. After discussions with the NRC inspector and in the spirit of cooperation, a search of the containment structure was conducted by security personnel in conjunction with inspections conducted by operations and health physics personnel prior to restart of the reactor on December 10, 1988.. The i

Safeguards Contingency Plan and related procedures will be reviewed and I

revised no later than June 30, 1989, to remove any subjectivity in l

determining the need to conduct searches in the future.

jf k,' D nsu h b M ed

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8904050076 990327 n;

PDR ADOCK 05000395 6

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{ F fl N gg ATTACHMENT CONTAINS SAFEGUARDS UNI $dd M

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INFORMATION UPON SEPARATION THIS y

PAGE IS DECONTROLLED,

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i Mr. James Lieberman i

March 27, 1989 j

Page 2 of 3 l

Attachment I to this letter provides copies of SCE&G Licensee Event Reports (LERs) 88-S01,88-502, 88-S03, and 88-504 which were previously submitted on October 20, November 2, Nover' 'r 28, and December 2,1988, respectively.

These LERs address the reaso.

sr the violations and corrective actions taken to prevent recurrence ft the majority of the violations assessed a civil penalty as correlated below:

Notice Paragraphs Applicable LER I.A.1 88-501 I.A.2 88-502' I.B 88-S02 I.C. I.D 88-504 II 88-S03 Attachment II to this letter provides the reasons for the violation and corrective action taken to prevent recurrence for the violations (1.E, I.F.

and III) not addressed in the LERs.

SCE&G regrets that any of the violations addressed in the Notice of Violation occurred at the VCSNS.

Even though there was no significant impact on the ability to protect the health and safety of the public, we recognize and appreciate the potential seriousness of incidents of this nature.

SCE&G believes that its record in identifying and correcting potential problem areas in its operations is an excellent one and will make every effort to assure that it continues in that manner. Specifically, the security program at the VCSNS has been deemed as one of the best in the industry, and the SCE&G goal is to maintain this level of excellence.

SCE&G believes that the corrective actions taken in regard to these incidents demonstrate the strength of its concern with safe operation of VCSNS.

In closing, SCE&G appreciates the mitigation of the associated civil penalties; a check in the amount of sixty two thousand, five hundred dollars ($62,500) is enclosed.

Should you have any questions, please advise.

Very truly yours,

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0. S. Bradham HID/0SB:mrg Attachment c:

57e Page 3 ATTACHMENT CONTAINS SAFEGUARDS SAFEGUES INF0NMl0N

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SAFEGl!ARDS INFOR1ATl01 Page 3 of 3 c:

D. A. Nauman/0. W. Dixon, Jr./T. C. Nichols, Jr.

E. C. Roberts P. A. Williams, Jr.

S. D. Ebneter J. J. Hayes, Jr.

General Managers C. A. Price /R. M. Campbell, Jr.

R. B. Clary K. E. Nodland J. C. Snelson G. O. Percival R. L. Prevatte J. B. Knotts, Jr.

NSRC NPCF RTS (IE 883100)

File (815.01) h.

q ATTACHMENT CONTAINS SAFEGUARDS S ',

O'IN ti%J II INFORMATION UPON SEPARATION THIS j

PAGE IS DECONTROLLED.

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