View source for RC-97-0031, Forwards Response to Request for Info Per 10CFR50.54(f) Re Adequacy & Availability of Design Bases Info

{{Adams
| number = ML20134J442
| issue date = 02/06/1997
| title = Forwards Response to Request for Info Per 10CFR50.54(f) Re Adequacy & Availability of Design Bases Info
| author name = Taylor G
| author affiliation = SOUTH CAROLINA ELECTRIC &amp; GAS CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000395
| license number = 
| contact person = 
| document report number = RC-97-0031, RC-97-31, NUDOCS 9702120138
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 57
| project = 
| stage = Request
}}

=Text=
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South Carolina Electric & Gas Company       Gary J.T;ylor           !
P.O. Box 88                                 Vice Pr:sident Jenkinsville. SC 29065                      NL' , Operations (803) 345-4344 SCE&G saamacmar February 6,1997 RC-97-0031 Document Control Desk U.S. Nuclear Regulatory Comnussion Washington, D.C. 20555 Ladies and Gentlemen:
                                                                                                            )

==Subject:==
VIRGIL C. SUMMER NUCLEAR STATION (VCSNS)                                               !
DOCKET NO. 50/395 OPERATING LICENSE NO. NPF-12                                                           l REQUEST FOR INFORMATION PURSUANT TO 10 CFR 50.54(f)
REGARDING ADEQUACY AND AVAILABILITY OF DESIGN BASES INFORMATION 1
Virgil C. Summer Nuclear Station (VCSNS) provides the following response to your request for            !
information dated October 9,1996. This request for information required that a wdtten response regarding the adequacy and availability of design bases information be submitted under oath or          ;
affirmation in accordance with 10 CFR 50.54(f).                                                        I South Carolina Electric & Gas (SCE&G) is strongly committed to maintaining the performance and configuration of VCSNS consistent with the design bases. VCSNS was licensed for operation in 1982, at which time the NRC found that plant operation provided reasonable assurance of protection of public health and safety. Since the time of licensing, the VCSNS procedures governing operation, maintenance, testing and design control have been established and maintained to conform to NRC requirements, including 10 CFR Part 50, Appendix B. The overall adequacy of our procedures and programs has been confirmed during the NRC's ongoing regulatory oversight processes, as well as our own internal oversight activities.
VCSNS is recognized by the NRC as one of the top performing plants. In its most recent Systematic. Assessment of Licensee Performance (SALP) report, dated December 6,1996, the NRC rated VCSNS superior (Category 1) in the functional areas of Plant Operations, Engineering and Maintenance, and good (Category 2) in Plant Support. The NRC specifically recognized in the recent SALP report (at page 4) that the " licensee's performance in the areas of design control and maintenance of the licensing basis was strong."
Oversight of activities at VCSNS is provided by our line organizations as well as independent review groups. In-line oversight includes management and interdisciplinary reviews, testing and verification activities, and internal evaluations. Independent oversight includes the periodic audits and inspections under 10 CFR Part 50, Appendix B, as well as self-assessments of functional areas and activities and " vertical slice" assessments of major plant systems. The results of these
'9702120138 970206 PDR P
ADOCK 05000395 PDR L
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1 Docum:nt Control Desk                                                                   Page 2 of 4 RC-97-0031 1
1 oversight activities give us added confidence in the structure and functioning of our programs for   i maintaining design bases conformance. An important part of the safety culture at VCSNS is to         I encourage the identification of nonconformances, weaknesses and areas for improvement. When          l nonconformances are identified, they are processed through the 10 CFR Part 50, Appendix B            '
corrective action program. This program calls for an appropriate review for the cause and the extent of the condition, and development of prompt and effective corrective actions. As summarized in the NRC's December 6,1996 SALP report, the VCSNS problem identification and corrective action processes have functioned to achieve timely and effective resolution ofissues.
i SCE&G has also undertaken a number of significant initiatives since plant licensing to help maintain conformance with the design bases and to enhance the quality and availability of design bases information. These initiatives reflect SCE&G's management commitment to examine our own programs to ensure they are functioning reliably, and to incorporate improvements based on our own findings, industry experience and NRC expectations. The major activities have included the following:
In 1985, VCSNS initiated a Design Basis Document (DBD) Program. The DBD program is aimed at compiling (or providing a guide to) plant design bases information that was originally developed by the Architect / Engineers, the NSSS vendor and equipment suppliers. The program consisted of the development of 43 individual DBDs covering the major plant systems, structures and components and relevant topical areas. The DBDs capture the basic design information and requirements or provide a guide (road map) to locate information in       l other design documents. This serves to facilitate informed engineering decisions on plant        l operation. The information contained in the DBDs is reviewed to ensure consistency with the plant as designed and operated.
SCE&G has long appreciated the importance of performing Safety System Functional Inspections (SSFIs) on major safety-related or important to safety systems. Since 1987, the Independent Safety Engineering Group (ISEG) has performed SSFIs on eleven (11) major systems in the plant, including emergency feedwater, service water, emergency diesel generators, component cooling water, and residual heat removal. These SSFIs have generally involved vertical slice reviews covering the areas of system design, design changes, operations, surveillance testing, maintenance, training and Quality Assurance. Specifically, the SSFIs focus on determuung whether the design bases is adequate, the existing configuration complies with the design requirements, and the documentation describing the design bases is consistent. The SSFIs also confirm that changes to the system have not adversely affected the system's ability to perform its design function.
SCE&G has recently instituted a Configuration Management Plan aimed at continually improving our ability to access and control information in order to assure compliance with design and licensing basis requirements. Initial activities withk. the plan center on Design Engineering functions. Overall, the Plan is intended to incorporate areas of improvement

Document Control Desk                                                                   Page 3 of 4 l RC-97-0031                                                                                          '
identified by VCSNS personnel, the Quality Assurance organization, regulatory bodies and industry experience.
                                                                                                      )
In 1993, SCE&G initiated a Design Control Re-engineering Program aimed at improving the        {
efficiency and effectiveness of the design control process. As part of this Program, many      '
design control and configuration management activities have been assessed, including modifications, FSAR changes,10CFR50.59 processing, and drawings and calculations. An           I analysis was performed to identify process and management system improvements, along with      )
performance measures against which the re-engineered processes should be compared. The development and implementation of improved procedures, instructions, and processes is currently in progress.                                                                         l Beginning in March 1996, SCE&G initiated an FSAR review effort which included (1) an Outage Review, (2) an MRF Review, and (3) an Overall FSAR Review. This FSAR review effort is described in detailin Section (d).                                                   l The Overall FSAR Review is an ongoing, systematic and prioritized assessment focusing on discrete systems and programs which correlate with the Design Basis Documents. The approach includes a comprehensive assessment to assure consistency between the FSAR and l
the DBDs or other controlled documents, and a review of those aspects of the FSAR pertinent    j to safe operation for accuracy and consistency. Thus far, six systems have been reviewed       j under this approach. No findings to date have involved safety-significant concerns.            !
I SCE&G is confident that our current programs, processes and procedures, combined with the continuing oversight activities and our initiatives to maintain design bases compliance, provide    i reasonable assurance that our plant is operated and maintained within the design bases and any deviations are reconciled in a timely manner.
This response contains the requested descriptions of our various programs and processes as they     l exist currently. These programs and processes are, of course, subject to change periodically in accordance with appropriate controi- In preparing this response, SCE&G utilized a dedicated team to complie the information contributed by the various responsible organizations. SCE&G also utilized an independent review and verification process by individuals familiar with the information to provide additional assurance that the information presented is accurate. This response has been reviewed by the Plant Safety Review Committee and the Nuclear Safety Review Committee.
SCE&G plans to continue the Overall FSAR Review described above. / Note: This commitment is listed separately in order to avoid confusion as to what commitment is made under this letter.
Any other descriptions or programs are subject to change in accordance with our normal review and change practices, and are not to be considered commitments.]
I

, Docum:nt Control Desk                                                                   Page 4 of 4 l RC-97-0031 l
We trust that the information provided is responsive to your request. Should you have any questions, please contact Mr. Michael J. Zaccone at (803) 345-4328.                                 :
Very truly      rs,                          l N            t 1
1                       ,
Gary T k br Vice President, Nuclear Operations MJZ:GJT Attachment c:       J. L. Skolds                                  J. B. Knotts R. R. Mahan                                   K. R. Jackson R. J. White                                   A. R. Johnson L. A. Reyes                                   CentralFile Syste,m NRC Resident Inspector                        RTS (MSP 960015)
W. F. Conway                                 File (810.32)
NEI STATE OF SOUTIICAROLINA                            :
:      TO WIT :
COUNTY OF FAIRFIELD                                :
I hereby certify that on the  6''     day of Fekw., 19.12, before me, the subscriber, a Notary Public of the State of South Carolina personally ap15 eared Gary ' Taylor, being duly sworn, and states that he is the Vice President, Nuclear Operations of the South Carolina Electric & Gas Company, a corporation of the State of South Carolina, that h provides the foregoing response for the purposes therein set forth, that the statements made are uue and correct to the best of his knowledge, information, and belief, and that he was authorized to provide the response on behalf of said Corporation.
WITNESS my Hand and Notarial Seal                                               e
* NotakPublic My Commission Expires f'/ Cc=S2n EW: Fy13,2005 Date l
NUCLEAR EXCELLENCE - A SUMMER TRADITION!

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l Attachment I to Document Control Desk letter                                                    Page 1 of 24 j RC-97-0031 i
information Request (a)
Description of engineering design had configuration control processes, including those that innplernent 10CFR50,59,10CFR50.71(e), and Appendix B to 10CFR Part 50.
Management Directive 21 Design Change Program, and Management Directive 4, Statement of                           .
Responsibilities, Engineering Services Grout, specify the policy and respasibilities for the design change        ,
program for the V. C. Summer Nuclear Station (VCSNS). The implementation of this policy is through SAP-133, Design Cmtrol/ Implementation and Interface. and various Engineering Services (ES) procedures. The design change program has the following objectives:
i
: 1. Maintenance of the Design and Licensing Bases.                                                       !
: 2. Ensuring conformance of systems, structures, and components to approved design requirements.
: 3. Review of proposed changes to the facility to the original Design Bases.
: 4. Cmtrol of w(rk activities, tercporary changes, and permanent changes to ensure Design and Licensing Bases compliance.
: 5. Documentation which adequately reflects the plant as-built characteristics.
: 6. Ensuring conformance of the Design Basis through revision of Operating and Maintenance procedures, training, and updates of the plant simulator.
The requirements of 10CFR50. Appendix B.10CFR50.54,10CFR50.59 and 10CFR50.71(e) are integrated to ensure there objectives are accomplished.
The descriptions below focus a the common engineering design and con 6guration control processes at VCSNS which assure compliance with and maintenance of the approved Design and Licensing Bases.
The descriptions are broken down into two major categories: those for processes which actually allow changes to the facility (Change Pro sses) and those that ensure documentation is maintained (Document Change Control Processes). The specife topics addressed in each are:
1 Channe Processes:
* Design Change Control
* Procedure Development and Change Control
* Nonemformance Notice (NCN) Dispositioning
* Temporary Bypass, Jumper & Lifted lead Control
* Motor Operated Valve (MOV) Change Program
* Software Change Control                                                                                    ;
Documentation Channe Control Processes:
Final Safety Analysis Report / Fire Protection Evaluation Report (FSAR/FPER) Changes
* Structure, System & Equipment Classife' stion
* Cumulative Effects
* Design Basis Documents
* Calculations
* Drawing Cmtrol
* Database Change Control
* Specification Control
* TechnicalReports
* Plant Lubrication Manual change Processing

Attachmant I to Document Control Desk letter                                                   Page 2 of 24 RC-97-0031 Channe Processes:
Design Change Control a
PurDuse:
: 1. To screen, assess, design and implement changes to the facility in accordance with the station Licensing Basis, considering the original Design Basis d structures, systems, and components important to plant safety. In addition, the process serves as a mechanism to assess the impacts of non-safety activities on safety related structures, systems, and components through a variety of reviews by station personnel.
: 2. Development of design changes in accordance with this program is intenoed to provide consistent,
 !           complete, and thorough products in accordance with our regulatory commitments and good 1
engineering practices.
                                                                                                                      \
Scope:
I The scope of the process includes proposed building, system, equipment, core reloads and setpoint             I changes to the VCSNS. This includes documentation and hardware changes to the facility.
Prucess

== Description:==
l 1
The program is initiated Dy station personnel via a request to Systems and Component Engineering personnel. This group assesses the validity of the request, together with the Originator, and determines the appropriate change proc"; utilizing the screening criteria of ES-452. The Engineering Change processes considered include: 1) Administrative Changes,2) Commercial Changes (Non safety), and 3)
Nuclear Changes. Within each of these change processes a specific level of review and approval is required as described below:
Administrative Changes: The Responsible Engineer assesses the re.tuested or identified change against criteria defined in the procedure to ensure that the requested change does not represent a change to the facility. These criteria include:
* Revisions to reflect minor changes that do not involve design information.
* Documents and/or database records that document existing design.
* Correction to the status of documents to reflect existing design.
* Issuance of drawings / documents for equipment purchased by SCE&G.
                         *  "As-builting" of piping isometrics drawings to show field welds made as a result of non-Engineenng Change Package maintenance activities.
For those activities meeting the criteria. the Responsible Engineer identifies all other impacted documents, including those external to the Engineering Services (ES) group. When required, written notification is provided to impacted departments identifying the document / database requiring revision.
The Administrative Change package is reviewed by Engineering Services personnel per FS-Il0 prior to release. Since an Administrative Change dmt not represent a change to the facility, a 10CFR50.59 screening review / safety evaluation is not required.
Commercial Changes: Commercial changes are changes to structures, systems or components that are outside the scope of a nuclear change, not safety or quality related, do not impact the plant design basis or safety analysis. The Responsible Engineer determines the scope of the

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l Attachment I to Document Control Desk letter                                                 Page 3 of 24 RC-97-Orn; i
change and identifies the plant programs, documents and any codes / standards which are affected or must be considered in the implementation of the requested change. The Responsible Engineer identifies the groups which will be involved in the implementation and solicits input from the      '
Supervisors from those groups. The input includes identifying any impacts to station procedures     i and training and any Return to Service considerations. A Commercial Change Package is               !
developed based on these inputs. A 10CFR50.59 screenmg review / safety evaluation is then           ,
performeu per step 6.8.2 of ES-453 in accordance with SAP-107.
l                  Following package assembly, field work documents are generated and planned by the
!                  Maintenance / Operations Planners. Prior to initiating field implementation, essential drawings are posted in the Control Room to define In Process changes. After implementation activities l
have been completed, package closure efforts are initiated including update of impacted controlled documents.                                                                               -
1 Revisions to the Commercial Change Package are reviewed to determme if the revision is within the scope of the 10CFR50.59 screening review / safety evaluation. For those within the scope of the existing evaluation, the revisim scope is approved by the supervisor of the group which originated the change request and the revision is processed in a manner similar to the original commercial change package. For those revisions which are outside the scope of the 10CTR50.59 screening review / safety evaluation, the originating group supervisor requests a new Engineering Change.
Nuclear Changes: The scope of Nuclear Changes primarily includes work or activities that impact Quality Related and Nuclear Safety Related structures, systems or compments. The different processes which address these type changes include Equal To/Better Than Evaluations (Parts Replacements). Serpoint Changes. Core Reloads, Plam Enhancements and Plant Modifications. [ Note: Setpoint changes and Core Reloads are processed as a Plant Modification ]     j Equal To/Better Than (ETBT): Safety and Quality Related ETBTs are processed through the Engineering Services organization via development of a ETBT evaluation identifying acceptable replacement items, end use restrictions, identification of controlled document impacts, and technical justification. Organizations external to       l Engineering Services are selected for review based on the potential to impact station l
procedures (based on scope of ETBT). A 10CFR50.59 screening review / safety evaluation is performed which is independently reviewed. Approval of the ETBT and 10CFR50.59 screening review / safety evaluation is obtamed from an Engineering Services Supervisor.
A second independent technical content review is performed by Procurement Quality.
I The package is issued and field work documents are generated and planned by the           l Maintenance / Operations Planners. Prior to initiating field implementation, essential    l drawings are posted in the Control Room to define In-Process changes. After implementation activities have been completed, package closure efforts are initiated     l including update ofimpacted controlled documents.
Revisions to the ETBT Package are developed and reviewed in a similar manner, For Plant Enhancements and Plant Modification, the System and Component Engineer develops            i the preliminary design and obtams his supervisors' approval. The change request and preliminary design package is reviewed by the Principal Engineer Review Group, composed of the Discipline Principal Engineers, to determine design inputs and potential impact to the station Design Bases. If it is determined that Design Bases impact is likely due to the scope or I

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Attachment I to Document Control Desk Ietter                                                  Page 4 d24
. RC-97-0031 l
         - complexity of the work, the design package is processed as a Plant Madification. The Plant Fahanmmant Process is the piecess followed for work that does not impact the Design Basis.                        !
Plant Enhancementa: The Responsible Engineer develops the enhancement                                     !
instructions and performs a 10CFR50.59 screening review / safety evaluatim in                             !
accordance with SAP 107. The Plant Enhancemant is independently verified within                           l Fmgi-ring Services. Enhancement package review is performed by affected station                           !
Operatims. Maintenance, nr.d Engineermg Service personnel as required. Personnel                          !
performing reviews of the packages provide emn=ents in addition to identifymg                             i Operability / Return to Service requirements and training / procedure impacts. Following resolution dcammants, an Engineering Service approval is obtamed and concurrence to implement the change is obtamed from the General Manager, Nuclear Plant Operations                        ;
(GMNPO, Plant Manager). The package is then issued and field work dac=-ts are generated and plannad by the Maintenance / Operations Plannars. Prior to initiating field implementatim, essential drawings are posted in the Control Room to define In-Process changes. After implemantation activities have been completed, package closure efforts are initiated including update ofimpacted controlled document =.                                          i Revisions to the Plant Enhancement Package are reviewed to determine if the revision is within the original scope. For those within the scope of the existing evaluatim, the Responsible Fngi-r determines if the revision is major or minor. A revision is considered major if it will result in a change to the 10CFR50.59 screening review / safety                i evaluation, change a plant procedure that was not previously identified, change training requirements, affect operability, affect the scope of post work testing, affect operability / return to service, or contain nuclear safety related (NSR) work in a non                     ,
nuclear safety (NNS) package. Major revisions are prara==ad in a manner similar to as
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the original enhannament change package. Minor revisions are pranecead similarly,                           i except that the minor revision process allows for acx:umulating several minor changes prior to processing a final minor change Enhancement Package and do not require                           ;
external reviews or approvals. For those revisions which are outside the original scope,                  '
the Responsible Engmeer screens the revision in accordance with ES-452 to determine the appropriate change process to be utilized.
Plant Modifications: The Design Engineer prepares a caceptual design package based on the preliminary design Further development of Design Inputs are solicited from department managers, ALARA planners, Principal Engineers and other affected groups.
The Design Engineer compiles the responses and solicits additional input at a Design Input meeting. With this informatim, the Design Engmeer finalizes and assembles the final conceptual design package for review by the General Manager, Nuclear Plant Operatious. Following GMNPO approval, the Design Fngnneer prepares the detailed design package including a 10CFR50.59 screening review / safety evaluation. The package is independently verified within Design Engineering. The package is then                           i reviewed by all Discipline Principal Engineers to ensure Design Basis impacts have                         ;
been properly addressed.- External reviews are performed by affected station personnel and include identifying Operability / Return to Service regmrements and training /
procedure impacts. Following completion of these reviews, an Engineering Service approval is obtained from an Engmeering Services Supervisor. Planning and Pre-implementation meetings are then conducted to support modification implementation and coordinate craft resources Then the package is issued and field work documents are generated and planned by the MaintenanaJOperations Planners. Prior to initiating field implamentation, essential drawings are posted in the Control Room to define In-Process changes. After implamantation activities have been completed, package closure

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l Attachment I to Document Control Desk letter                                                    Page 5 d24 RC-97-0031 efforts are initiated including update d impacted cetrolled documents, including Design Basis informatim when required.
Revisims to the Plant Modification Package are reviewed to determine if the revision is within the original scope. For those within the scope d the existing evaluatim. the l                           Respasible Engineer determines if the revisim is major or minor. Casideratim d l                           minor and major is as described in the Plant Enhancement section. Major revisims are l
promssed in a manner similar to the original Modificatim change package. Minor revisims are processed similarly, exmpt that the minor revisim process allows for l                          accumulating several minor changes prior to processing a final minor change l                           Modification Package and do not require external reviews or approvals. For those revisions which are outside the original scope, the Responsible Engineer screens the mvision in accordance with ES-452 to determine the proper pmcessing.
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i Attachment I to Document Control Desk letter                                                    Page 6 of 24 RC-97-0031 Procedure Development and Change Control                                                                     ;

==Purpose:==
: 1. To describe the process for the development, revision, change, review and approval of procedures specified by Sections 6.8.1 and 6.8.2 of Technical Specifications.
: 2. To ensure the procedural requirements outlined in ANSI N18.71976 and the Operational Quality Assurance Plan are implemented.
I Scope:                                                                                                       i The requirements of the proo:ss apply to all procedures and plans specified in Attachment III of SAP-139.
Process

== Description:==

Requests for procedure changes or development are routed to the appropriate Discipline Supervisor for        I action. The Discipline Supervisor determines the validity of the request and either rejects the proposed     I change or assigns an Originator from his group. The Originator identifies any Procedure / Commitment Accountability Program (P/ CAP) interface, determines the type of change to be processed and prepares a draft of the new procedure or the revision. The draft package is routed back to the Discipline Supervisor for his review, identification of required reviewers and assignment of the 10CFR50.59 evaluator. (At a minimum, the required reviewers are per Attachment III of SAP 139, however, the Discipline Supervisor may also assign additional reviewers as needed.) A 10CFR50.59 scrmning review / safety evaluation is performed for all procedures except those specifically identified per section 6.3.9 of SAP-139.
l The draft procedure package is reviewed by a Qualified Reviewer. Next, the draft procedure package is        I routed for cross-disciplinary reviews as specified by the Discipline Supervisor. Upon cross-discipline review comment resolution completion, the package is seu cack to the Discipline Suoervisor to ensure all comments have been resolved and that the 10CFR50.59 screening review /safary evaluation has been             l performed when required. The Discipline Supervisor also identifies if the parxage must be reviewed by the PSRC and sends the package on for final approval. The Approval Anhority determines whether PSRC review is required prior to implementation of the change. If PSRC review is required prior to implementation, the package is sent to PSRC and upon completion of the re riew, is approved. If PSRC review is not required at this time, the package is approved.
The process also allows for Temporary Approvals of procedures when expeditious processing of a procedure change is required. Temporary Approvals may only be granted if the proposed change:
: 1. Does not alter any P/CAPitem or
: 2. Does not alter the intent of the procedure.
The processing is similar to a permanent change except:
: 1. A 10CFR50.59 screening review / safety evaluation is not required prior to the Temporary Approval since the proposed change does not alter the intent of the procedure.
: 2. The only sequired reviews are a Qualified Reviewer, the Shift Supervisor and Quality Assurance.
: 3. The procedure must receive Final Approval within 30 days from the date of the Temporary Approval or have documented correspondence of the acason it could not be accomplished.

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Attachment I to Document Control Desk letter                                                     Page 7 of 24 RC-97-0031 NCN Dispositioning

==Purpose:==
: 1. To provide methods for dispositioning nonconforming cmditions. A nonconformance is a deficiency in a material, part, component, service cr activity which renders the quality of an item unacceptable.
Nanconformance Notices (NCNs) are used to describe adverse safety, quality or non-safety related hardware or performance related conditions which do not conform to approved design requirements / documentation.
: 2. This process also addresses the test requirements to ensure that the implemented NCN disposition (s) resolves the nmconforming condition such that systems, structures or components are capable of performing their design function.
Scope:
This process applies to the activities performed by Engineering Services persmnel in the processing of        I NCN's submitted or initiated for disposition and evaluation.
Process

== Description:==
i The NCN Dispositioning Process consists of an Engineering Services evaluation to address and resolve NCNs. This process may be implemented via multiple dispositions for a single NCN.
When a NCN is generated, it is reviewed by the Responsible Engineer. The Respcasible Engineer develops and documents a disposition to resolve the NCN. The development of the dispmition includes an identification of any affected documents as well as consideration of the need for a 10CFR50.59 screening review / safety evaluation.                                                                         ;
NCN dispositions are classified into one of the following categories:
* Accept-As-Is
* Clarification
* ConditionalRelease
* Data Collection
* Reject
* Repair
* Rework The Accept-As-Is dispositim may be used when the nonconformance is determined to have no efhet on the proper functicning of the items and will 'pesent no hazard to public safety. Accept-As-Is dispositions require a 10CFR50.59 screenin4 re riew/ safety evaluation unless they are minor in nature such as simple part number changes paperwork discrepancies which do not alter hardware, minor hardware discrepancies that are in "ameritical to functim" attributes, or deviations that a qualified vendor can acknowledge as acceptable under the vendor's design control program via the subject purchase order or other appropriate documents.
The Clarification disposition is used to clarify any part of a previous dispmition of that NCN that is vague, unclear, or confusing and results in the inability to fulfill the intent of the previous dispositions. A clarification disposition does not change the intent of the original disposition.
Clarification dispositions do not require a 10CFR50.59 screemng review / safety evaluation.

Attachment I to Document Cmtrol Desk letter                                                     Page 8 of 24 RC-97-0031 The Conditional Release disposition allows a nonconformance to be corrected after installadon but prior to operation. The dispositim must include a technicaljustification for the cmditional release of the item for installation. Documentation related Conditimal Release nonconformances must not impair the capability to determme that the item is able to fulfill its design function or meet its acceptance criteria for the item to be placed in service. Conditional Release dispositions do not require a 10CFR50.59 screening review / safety evaluatim.
The Data Collection disposition requests specific data such as measurements or investigating results of activities requested by Engineering Services to suppwt future dispositions to that NCN.
Data Collection dispositions do not require a 10CFR50.59 screemog review / safety evaluation.
The Reject disposition involves damage or a amconformance that will make the component unacceptable for service. Rejectim may occur during any phase of castruction or operation.
Reject dispositions do not require a 10CFR50.59 screening review / safety evaluation.
The Repair disposition is used for those nonceforming conditims requiring Engineering Services specific direction to restore a nonconforming characteristic to a cmditim such that the Design Basis and capability of an item and/or system to functim reliably and safely is unimpaired even though that item and/or system still does not conform to the original requirement. Repair dispositims require a 10CFR50.59 screenmg review / safety evaluation.
The Rework disposition is used for those noncmforming cmditions not requiring Engineering Services specific direction to make a amcmforming item conform to its original design cmfiguration by replacement, remrhinmg, reassembling or other corrective means. NCNs related to materials which could be corrected by the application d existing approved procedures are classified as Rework. Rework dispositions do not require a 10CFR50.59 screening review / safety evaluation.
In some cases, an NCN disposition may require an abnormal system or component arrangement or                 ,
alignment which is not part of a normal or emergency plant operatims procedure to maintain the Design        l Basis of the plant. Such a disposition represents a Repair that does not return the system to the original   ;
design condition, and a 10CFR50.59 screening review / safety evaluation is performed to address the impact of this abnormal system or component alignment on design aspects.
After the disposition is developed, a documented review is performed by the appropriate Engineering Services supervisor and the Quality Services (QA) department prior to field implementation of the disposition. The Responsible Engineer interfaces with Maintenance and/or Operations as alclicable to determine what documentation is required to support the NCN disposition testing requirements.
Implementation of the disposition, including identified testing, is then performed by Maintenance and/or Operations personnel with Quality Control inspections as necessary. NCN disposition testing is performed to ensure the affected equipment is capable of performing its Design Basis function.               After the disposition action is complete, the Responsible Engineer ensures that all documentatim changes have been completed. Quality Control (QC) reviews the documentation to assure no further work is required.
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:I Attachment I to Document Control Desk Ietter                                                      Page 9 of 24   ,
RC-97-0031
}                                                                                                                                                      l
!                                     Temporary Bypass, Jumper, and Lifted Lead Control                                                                :
l                                     Purocor:                                                                                                         l i                                                                                                                                                      ?
]                                      1.      To ensure that the installation of electrical jumpers and lifted leads and the bypassing of computer
:                                            ' inputs for in service plant equipment will be properly identified, reviewed, and approved prior to      !
,                                               implementation.
l                                     2.        To ensure the review d Bypass Authorization Requests for temporary bypass, jumper, and lifted lead j.'                                             activities by Design Engineering for the concurrence or disapproval of Bypass Authorization            j j                                               Requests.                                                                                              '
: l.                                    EE2Hti a
j                                     This process applies to the use of electricaljumpers and lifted leads and the bypassing of computer inputs       !
j                                     for all in service plant equipment. This program also provides for Design Engineermg concurrence or .            l
:                                     disapproval of Bypass Authorization Requests.                                                                    i
: i.                                    Process Descriptions:                                                                                            '
SAP - 148 provides for the processing of the Bypass Authorizatim Request (BAR) by Operations and the             i tracking of the installation and removal of jumpers and lifted leads. The BAR is processed through the            l i                                     Manager, Operatims. A Shift Engineer (STA - a degreed engineer who holds at least SRO certificatim)               I is assigned to review and complete the BAR. The Shift Engmeer performs a tehalemi review, which                   l l                                     addresses functimal and operatimal impacts. The Shift Enrneer also provides precautions, wire size, i                                     routing, and location criteria to cmsider channel separation, seismic movement, access, interferwoes.              l j                                     etc.
I j                                     The Shift Engineer performs a 10CFR50.59 screenmg review / safety evaluatim per SAP - 107 and marks j                                     up any affected drawings showmg the installation of the electricaljumper or location of the lifted lead and places the drawing on the Cetrol Room SAP-148 In-Ptocess Drawing stick. The determinatie of an unreviewed safety questim at this point precludes the use of this procedure in performing a Bypass f'                                    Authorization Request. The duty Shift Supervisor provides the final pre-implementation review and approval.
i                                     The Plant Safety Review Committee (PSRC) reviews all changes conducted by this procedure for their possible impact a plant safety. Tne PSRC verifies the bypass does not constitute an unreviewed safety
{                                     question and ensures the bypass does not require a change to the Technical Specifications.                        j j                                     Design Engineering reviews BARS for concurrence or disapproval in accordance with procedure ES - 403.
j                                     The Design Engineer is responsible for 'ehaical review of the BAR activity and the Independent Review of the 10CFR50.59 screening review / safety evaluation. After completion of review, the completed BAR i                                     package is sent to the Manager Nuclear Operatims. BARS which are disapproved by Design Engineering are reviewed by the PSRC and the results submitted to the appropriate Manager.
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l                                     The Associate Manager Shift Operations, performs a review and audit every ninety days of all BARS in
;                                     effect. A Shift Fnp- tracks the status d all active BARS and provides the reason the bypass is still 1                                     installed and not made permanent for all active BARS.
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Attachment I to Document Control Desk letter                                                   Page 10 of 24 I RC-97-0031 MOV Change Program

==Purpose:==
To establish, implement and maintain an overall program for motor operated valves (MOVs). This                l includes various maintenance and testing activities as well as engineering reviews and analyses.             !
Scope:
This prograin applies to all safety-related motor operated valves (MOVs), position-changeable MOVs as         l defined in Generic letter (GL) 89-10 and Balance of Plant MOVs as determined by the MOV Coordinator.
1 This program applies to the following MOV activities:
* Engineering Evaluations
* Corrective Maintenance
* Preventive Maintenance                                                                         l
* Testing                                                                                       I
* Tracking / Trending
* Training Proeram

== Description:==

1 1
The Design Basis information for the MOV Program is contained in design calculations and pertinent            l information has also been incorporated into a Design Basis Document (DDD). This information includes GL 89-10 scoping. Maximum Differential Pressure for MOV Operation Required Opening and Closing               l Thrust, Maximum Allowable Thrust, MOV Design Review and Capability, for the applicable MOVs as               {
well as the data necessary for the static diagnostic testing of these MOVs to ensure Design Basis capability is maintained.
The static and dynamic diagnostic testing is perfamed by qualified Electrical Maintenance test technicians. The static diagnostic testing verifies that the Design Basis requirements, as stated in the     ;
applicable Design Review and Capability calculation, are met based on analysis of the test signatures by a    l qualified test technician. The static diagnostic testing includes allowances for test equipment accuracy as
, well as actuator repeatability, consistent with vendor methodology. The static diagnostic testing also includes an independent review of the test signatures by a qualified MOV test technician. Fa dynamic diagnostic testing, the test signatures are analyzed by a qualified test technician and reviewed by another   '
qualified test technician. Upon completion of static and/or dynamic diagnostic testing, the test signatures and data are reviewed by the MOV Coordmator.
The MOV Coordinator reviews all Preventive Maintenance Task Sheets (PMTS) and Maintenance Work                l Requests (MWRs) which could adversely impact GL 89-10 MOV Design Basis capability to ensure                  l Design Basis capability is maintained. The MOV Coordinator or designee is also responsible for performing a documented review of the static and dynamic diagnostic testing which is then independently       ,
reviewed by another MOV team member from within Engineering Services. This review em.ures that the            l MOV meets Design Basis requirements, including allowances for diagnostic test equipment and actuator          l repeatability, consistent with vendor methodology. Ifit is determined that an MOV does not meet Design Basis requirements, a Nanconformance Notice (NCN) is generated. If it is determined that certain parameters observed during the test are less conservative than that used in the MOV design calculations and that the calculation has sufficient margin to accommodate the new parameter, the affected                 l calculations are revised. The overall review of tested MOV performance versus Design Basis values is l

Awh-t I to Document Control Desk letter                                                          Page 11 d24 RC-97-0031 h-ted in the Generic letter 89-10 Mota Operated Valve Setup Test and Performance Validation Summary Report. -
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,                    The Design Basis capability requirements for those MOVs within the MOV Program are based, in part, on i                   review d Design Basis events as described in the FSAR. The MOV Program ensures that the Design               l 1
Basie capability d these MOVs is maintamed based on the MOV Coordinator or designee reviews d                !
maintenance and test activities, which includes a comparison d tested parameters to Design Basis values.
i                  If the Design Basis capability for a Program MOV is not maintamed, an NCN is generated.
1 Any MOV Program activities whch require updating the FSAR are implemented in accordance with i                    either the Engmeering Change Control or NCN process. Each d these processes address the need for l-updating the FSAR.
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Ate-h=aat I to Document Control Desk letter                                                  Page 12 of 24   3 RC-97-0031                                                                                                  '
Software Change Control                                                                                     i

==Purpose:==
I To catrol software used, software upgrades, or changes required for digital catrol and computer based monitoring system applications used to operate, catrol and muitar the plant.                                .
ESSHE.                                                                                                      I i
This process applies to the software systems for the Fire Service Simplex System and the Turbine Closed     i Cycle Cooling System. Other software systems are described in Computer Software Change Control later        j in this section.
Piscess

== Description:==

Software used in digital catrol and computer based sy;tems for operating, cetrolling , and monitoring       ,
the plant is catrolled in accordance with SAP-1040. Through this process, quality assurance                 i reqmrements in development, procumnent, installatim maintenance, testing, and modifcatim are                 l maintainart and cetrolled. This process also provides a cmcise method for developing software that          l ensures the system meets the reqmrements, that testing processes are sufficient, that the system performs l'
accurately, and that these is suffeient &-:- -- =tatim for operating and auditing purposes.
Software and modifications for digital catrol and computer based maitoring systems used for plant            )
operation and catrol require a 10CFR50.59 screening review / safety evaluatim. There are no nuclear
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safety related applications using software or digital controls at VCSNS.                                    1

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Awh==t I to Document Control Desk letter                                                         Page 13 of 24 RC 97-0031 Final Safety Analysis Report / Fire Protection Evaluatica Report (FSAR/FPER) Changes

==Purpose:==
l To outline the process for the preparation, revision, distribution and cattol of the Final Safety Analysis Report / Fire Protection Evaluation Report (FSAR/FPER).
kallE Applies to the processing of FSAR/IPER changes.
Process Descrintion:
When a change to the FSAR/FPER is identified, a FSAR/FPER Revision Natioe (RN) is submitted to Nuclear Licensing and Operating Exparience (NIAOE). Events which could affect the FSAR/FPER are as follows: completion of a plant modificatim; completim and apprwal d an analysis; apptwal of a plant procedure or procedure change; apprwal of a programmatic change; identificatim of the need for an editorial change (changes that do not alter the meaning of the text or figures in the FSAR/FPER); effective      ,
date of a new regulation. Safety Evaluatico Report (SER), license amendment, or NRC order; l
identification of any other change, correctim, or achnical e
error; and at the end of each refueling outage, partially implemented plant modifications.
The RN catains the following information: descriptim of the FSAR/FPER change; reason and basis for the change; organizatims affected by the change; the 10CFR50.54(a) review requirements; and a summary of the safety evaluation, including the effect on the margin of safety. The 10CFR50.59 Safety Evaluation and the FSAR affected pages, tables, and figures are attached to the RN, exapt for changes which are based on a NRC issued SER or changes that are strictly editorial in nature. These changes mly requise that a 10CFR50.59 Screening Review be attached to the RN.
NIAOE distributes the FSAR/FPER RN to the affected and/or required organizations for review. The RN will also be reviewed by the Plant Safety Review Committee (PSRC) if an unreviend safety question is identified or if the change was not reviewed through another program., such as ECR package. Once the              j review cycle of the RN is complete, final apprwal by the Manager, NIAOE is required.                              l i
The FSAR/FPER is revised (amended) no less frequently than annually or within 6 maths after each                 j refueling outage and reflects all changes up to a maximum of 6 months prior to the date of filing. This           i meets the requirements of 10CFR50.71(c).                                                                          '
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Attachment I to Document Control Desk letter                                                  Page 14 of 24 RC-97-0031 Structures, Systems, and Equipment Classification

==Purpose:==
Provides a mechanism for engineering personnel to define classifications to structures, systems, and equipment including parts thereof, Scope:
This process covers the assignment of classifications for structures, systems, and equipment including parts thereof.
Process

== Description:==

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The Oassification Process consists of two types of classifications: Equipment Oassifications (Structures,   j Systems, and Equipment) and Materials Cassifications (Spare / Replacement Parts and/or Consumable j
Items). The Equipment Classification data is stored in the Computerized History and Maintenance Planning System (CHAMPS). When additions, revisions, or deletions to the CIAMPS equipment classification fields are needed, Design Engineering assigns a lead Engineer to perform the classification.
The lead Engineer researches and determines the required classification dat: (Ceneral Cass, Mechanical Cass Electrical Cass, Code Cass, Environmental Oass, and Seismic Cass). The lead Engineer also determines the affected engineering documents. The classification data, the basis for the classification determination, and the affected engineering documents are included on the Equipment Cassification Data Sheet. A second engineer performs an independent review of the Equipment Cassification and a Supervisor, Engineering Services approves the Equipment Oassification. The equipment classification data is entered into CHAMPS and verified.
The Materials Cassification data is stored in the Materials Management System (MMS). When additions, revisions, or deletions to the MMS classification fields are needed, a lead Engineer is assigned to complete the classification. The lead Engineer researches and determines the required classification data (General Cass, Electrical Cass, and Environmental Cass). The lead Engineer also determines the affected engineering documents. The classification data, the basis for the classification determination, and the affected engineering documents are included on the Oassification of Materials Form. A second engmeer perPs as an independant review of the Materials Cassification and a Supervisor, Engineering Services ap,ses the Materials Cassification. The material classification data is entered into MMS and verified. When the Materials Cassification is being performed to support the development of a vendor specific Procurement Technical Requirements Package (PTR), the Oassification of Materials Form is not used. All the classification information is processed with the PTR package.
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Attachment I to Document Control Desk letter                                                  Page 15 cf 24 ,
RC-97-0031 i
l Cumulative Effects                                                                                           l Purrme:                                                                                                     l i
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: 1. To review changes being made to the plant against subject areas and the assessment of the individual and cumulative effect on the available margin contained in selected output documents.                 j
: 2. To track minor impacts to the design output documents in lieu of revising or reissuing the document.
Scope:
This program applies to the following engineering activities:
* Cable Tray Fill and Weight Loading
* Elcctricalload Monitoring
* Ilydrogen Inside Reactor Bldg.
* Main Control Board /HVAC Board Load Change and Seismic Qualification
* Combustible Loading Materials
* IiVAC and Chilled Water Loads
* Internal Flooding Flood Level Change
* StructuralFloorImad Mapping Items not specifically addressed above are outside the scope of this program and require updates to the calculations and/or subsequent drawing as-builting anytime changes are made.
Procram

== Description:==

The Cumulative Effects Program consists of a screening process and, if required, an evaluation process.
The screening process is initiated fa those activities which may involve changes to plant systems, services or structures to determine if any of these changes affect available margins documented in calculations that envelop the Design Basis of the plant. Design change activities whose screening results in all "NO" answers do not affect the available margins. Design change activities whose screening results in any "YES" answer are evaluated further to determine the impact on the available margin. For those activities determined to have a major impact, either the design is changed to eliminate the major impact or a detailed analysis is performed (and appropriate calculations, drawings, etc. updated) to evaluate and justify the acceptability of the change. The ccanplete package, consisting of the Cumulative Effects Screening Worksheet, the design documentation, and the evaluation are then sent to the respective Discipline Principal Engineers for review. For those activities determined to have a minor impact, the basis for determinadan of minor impact is documented and sent with the Cumulative Effccts Screening Worksheet to the respective Discipline Principal Engineers for review.
Each Discipline Principal Engineer reviews Lat portion of the package pertaining to his disciplino This review is performed to ensure the screening and evaluations were performed correctly and that the impact of the change was correctly identified.       This review also includes ensuring that other outstanding Cumulative Effects have been properly identified and considered in the evaluation. Any package deemed unacceptable by any of the Discipline Principal Engineers' is returned to the originator for comment resolution. For packages deemed acceptable by all Discipline Principal Engineers, each Discipline Principal Engineer signs the Cumulative Effects Screening Worksheet indicating his concurrence.
Additionally, if the Cumulative Effects Screening Worksheet contained any "YES" answers in a given discipline, the respective Discipline Principal Engineer would log the cumulative affect against the appropriate affected calculation.

Attehment I to Document Control Desk letter                                                   Page 16 of 24 RC-97-0031 The completed Cumulative Mets Screening Worksheet and applicable attehme.nts generated are incorporated in the parent /r = ==t. Copies of the Cumulative Effects Screening Waksheet and applicable attehments/ evaluations are placed in the calculation file before the affected calculation so that others are aware that Cumulative Effects are impacting that calculation.
Outstanding Cumulative Effect Changes for which work is complete. are incorporated into the next revision of the document.
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1 Attachment I to Document Control Desk letter                                               Page 17 d24 RC-97-0031 1
I Design Basis Documents (DBDs)                                                                             j i

==Purpose:==
l l
To assemble and capture the Design Basis information for VCSNS which was originally developed by the Architect / Engineers, NSSS supplier and equipment vendors from the following documents: FSAR, Technical Specifications, calculatims, drawings, technical reports, vendor manuals, design /castruction   ,
specifications, files and correspondence.
amm                                                                                                       i DBDs have been developed for key systems and topical areas for VCSNS. There are 43 DBDs that have        ;
been developed and controlled within the program. The DBDs provide a summarization of the plant          ,
Design Basis or a guide (road map) to locate the information in other design documents,                   i Pmeram

== Description:==

The goal of the DBD program is to have under the control of SCE&G pertinent Design Basis information and/or references to locate such information to aid in making informed engineering decisims to support    .
plant operations in a timely manner. The information contained within the DBDs is ast mbled and           I reviewed by knowledgeable SCE&G personnel and contractors to ensure that the information is correct       .
and consistent with the plant as designed and operated. The levels of review which are conducted ensure   l that the information is acrurate in order .o make informed decisions relative to plant design and operation. Additionally, use of the DBD information for design considerations normally requires that the user access the original design documents or sources of information in order to understand the original inputs and assumptions used to develop the design.
ES-423 provides guidance for the development and revision of DBDs. New DBDs will be developed under a review process similar to that used for the initial D3Ds using the most knowledgeable SCE&G and catractor resources available. The primary process for revision of DBDs occurs via other controlled programs related to Engineering Changes. Discipline Principal Engineers review each ECR and identify omitted design documents (including DBDs) which may be affected. The actual DBD revisim is subsequently reviewed by the Discipline Principal Engineer. The Originator also specifies other required reviews by Systems and Comument Engineering Operations and Maintenance. A secondary process of revision can also be initiated by any plant or contractor personnel when deficiencies, clarifications or correctims are identified. Either process requires a review of the proposed changer, to the DBDs by knowledgeable and responsible plant personnel, including as a minimum the Discipline Principal Engineer, and the Manager, Design Engineering.
The DBD Program is a supporting process to other parent processes, such as plant modifications and nonconformances. The 10CFR50.59 screening review / safety evaluadan is performed as part of these parent programs and therefore not required specifically for DBDs. Additionally, DBDs are primarily a summarization of the plant Design Basis which is extracted from other controlled documents, thereby na normally requiring a safety evaluation of their own.
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Anachment I to Document Control Desk letter                                                         Page 18 of 24                 >
RC-97-0031 Calculations

==Purpose:==
:     To catrol the identification, preparation, review, approval, revision and retention of Design Basis calculations and formal engineering analysis.
)     Scope:                                                                                                                            '
This process applies to calcuistions developed in support of confirming the adequacy d or changing plant i    Design Basis.                                                                                                                     -
1                                                                                                                                       i t     Process

== Description:==

i                                                                                                                                       -
New calculations are developed when existing calculations do not cover the topic being analyzed / evaluated. New calculations are developed to the format listed in section 6.2.1 of ES-412 which                        '
d includes identification of Design Inputs and their sources, assumptions used requiring future confirmation, and a description of the methodology used.
The calculation package is verified and approved. The scope of verification is determined by the Izad Engineer. The individual is independent of the calculation preparation process and has sufficient knowledge in the subject area to determine that proper inputs and methodologies have been used and                                l sesults are reasonable.
The approval of the scope of the verification and the calculation itself is performed by the appropriate Discipline Supervisor, Design Engineenng                                                                                           i Revisions to existing calculations are accomplished by making the necessary changes to the affected pages of the current calculation and completing a calculation cover sheet. The calculation package is verified and approved in the same manner as a new calculation.
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Attachment I to Document Control Desk letter                                                 Page 19 d24 RC-97-0031 Drawing Control

==Purpose:==
1 To define the process of generating, reviewing, revising, issuing, and maintainmg drawings for VCSNS.        '
Scope-l This program is applicable to Nuclear Operations Department (NOD) personnel and cetractors                  {
performing activities affecting drawings for VCSNS. The program applies to the following types of            I drawings:                                                                                                   ;
: 1. Interim Drawing
: 2. As-Built Drawing Process

== Description:==

The Drawing Process consists of the methodology to identify, develop, add or revise, check, review, and      l issue a drawing at the VCSNS Distribution of drawings is performed in accordance with procedure DCP-        l 103. The identification of a drawing is determined by the assigned Responsible Engineer, " Holds" are      i placed m drawings, except for administrative changes, in the Drawing Cmtrol Database to alert other         i plant personnel of pending changes. (An alternate method is to place physical " Holds" on drawings           !
utilizing a Drawing Change Notice). Any drawing conflicts identified in the Drawing Cetrol Database          l are msolved with the appropriate engineering personnel.                                                      l Interim Drawings                                                                                  i l
The Responsible Engineer (RE) prepares a DCN form, marks up drawings, reviews the Drawmg          ;
Control Database for holds against the drawings and resolves any conflicts.                       l l
The Computer Aided Drafting and Design (CADD) group determines if the package should be           I processed or rejected. If rejected CADD documents the reason and returns the package to the Originator, For all others, CADD incorporates the changes, checks the drawings for drafting        .
errors, and returns the drawings package to the originator for review.                            i l
The Respmsible Engineer ensures the requested changes have been properly inccrporated. For Main Control Board (MCB) or Cetrol Room Emergency Panel (CREP) drawings, a " Human Factors" review is performed.
As-' Built Drawings 1
Engineering identifies the drawings requiring as-builting to CADD. CADD revises the drawings, prepares any associated FSAR/FPER figures, and forwards the drawings to Document Control for further processing.
The Drawing Process is a supporting process to a parent processes such as ECRs or NCNs. The 10CFR50.59 screening review / safety evaluation is performed as part of the parent process and therefore is not required for the Drawing Process. Administrative changes to drawings normally represent an update to drawings to maintain consistent information to support previously approved design changes processed per parent processes. A 10FR50.59 screening review / safety evaluation is not required for administrative changes to drawings per the criteria set forth in ES-410.

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Attachment I to Document Cmtrol Desk letter                                                 Page 20 d24                        l RC-97 0031                                                                                                                     i i-l
:               Database Change Control                                                                                                        l

==Purpose:==
                 !. To control the processes of developing, modifying, and maintammg engineering database programs.
2.
f To provide a methodology to update Engineering catrolled databases, and to provide Engmeering j                     Information to databases controlled by groups outside of Eng'meering Services.                                           ;
i
: i.              Sggigt                                                                                                                         !
This process applies to the following activities.
: 1. The development, use, and maintenance of Design Engmeermg Database Management Systems.                                     !
:               2. Providing updates to "Catrolled" and " Uncontrolled" databases.
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j               Prwess

== Description:==
;                                                                                                                                               I l               Changes made to hei-ing Services controlled databases are identified as either: 1) changes to be made a               upon receipt or,2)pending changes for future incorporatim. An Independent Review is performed for j               changes to" controlled"informatim. Tyhnical approval is provided for both controlled and uncatrolled -                        j l               information by the Approval Authority. Changes are inputted by an Administrative Specialist and the j               data entry verified by another individual.
!               Changes to information contained in databases, that are not under the control of Engineering Services, are 4
identified and forwarded to the appropriate groups.
i               The original packages and supportmg information is forwarded to plant records.
!               A 10CFR50.59 screenmg review / safety evaluation per SAP 107 is Wormed for all initial applications and subsequent changes to computer databases except for those sp' t n'ly identified per Section 6.3.9 of SAP-1040.
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i                                   At*=cha-at I to Document Control Desk letter                                                    Page 21 of 24 i                                   RC-97-0031 t
Specification Control

==Purpose:==
i 1.To control the identifration, preparatim/ revision, review, certificatim (ASME Design Specifmatims),            .i approval, and retentim of ASME Design Specifratims, Procuremant Specificatims and Construction Specirmations performed at VCSNS.
2.To provide guidance to correctly specify requirements to control procurement d items or activities in the construction, repair, replacement, modificatim, or operation of structures, systems, or equipment at the VCSNS.
EfdlitE.                                                                                                            )
The scope d the Specificatim Control program includes ASME Design Specifications for design,                        I construction, and installatim of ASME Code compments and piping; Procurement Technical                              l Requirements utilized in the procurement of equipment, material and/or services for use in plant                     I operations; and procurement and construction specifmatims utilized in the procurement of equipment, material or services for use in plant operations, maintenance or modifications.
Prvcess

== Description:==

ASME Des *um Snecifmations. Procurement Snecifications and Castructim Snecircatims The Specifwatim Cmtrol process initiates with a determinatim of the need for a specifcation. Ifa replanamant of existing equipment or a change to system requirements is to be performed and there is an existing specificatim, that specifration is revised. For all other cmditions, a new specifwation is developed. Design requirements are extracted and compared to operating parameters. Series 302/912 drawings, applicable calculations, component function, and change dac=aantation are used to determine operating parameters. The established operating parameters are compared to the maximum parameters to ensure the values are not erraadad, If the values are excaeded, a revision notification to the initiating change process shall be generated and the parameters must be reconciled.
Design Specifrations require an indanandaat review by an Engineering Specialist in Design Engineering or by the Originator's Supervisor. A Professional Engineer review and certification is required in additim to the initial indanandant review. The Mechanical Supervisor of Design Engineering provides the final approval.
Procurement and Castruction Specifrations require an independent review by a qualified reviewer.
Procurement Quality reviews all Safety Related and Quality Related specircations. The Manager Design Fnginaering provides the fmal approval.
Procurement TechnicalReauirement Procurement Technical Requirement (FfR) documents are initiated when it is determmed that procured items and/or services are required in the construction, repair, replacement, modification, or operation of structures, systems, or equipment. PfR's are intended to be used for new equipment and replacement in-              !
kind procurements. In addition, spare and restock parts may have FIR's developed to aid in future reorders. Design and Construction Specircations may be incorporated into the FfR's and not issued as separate dac=aants. Where a PfR serves as a technical design specifacation, other existing specifmations may be affected and require deletion or revision. In this case, the Enginaering Change Request process is used to delete or revise affected specifications since these specifications must reflect as-built conditions of the systems and equipment.
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i                                                                                                                                           i Attachment I to Document Control Desk letter                                                  Page 22 of 24 RC-97-0031 l
The Supervisor of Procurement Quality & Receiving Inspection is responsible for the review and approval               i of Safety Related and Quality Related PTR's.
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Attachment I to Document Control Desk letter                                                 Page 23 of 24 RC.97-0031 j
2         Technical Reports i         Purpose-2 To record a wide range of engineering reports or studies.
i         EE9EE:
j         Technical reports typically document the results d an engmeering study in a particular subject area.
;         usually as a result d a regulatory issue. These documents may demonstrate continued compliance with regulatory commitments and require changes to be reviewed and approved accordingly.
Process

== Description:==

1 ES-lG1 describes the process for preparation, review, level d use designation, and approval of controlled docaw u developed by Engiineering Services.
A techr#:al report i:: a design output document that is used to record a wide range of engineering reports
;         or studies that may record positions on specific issues summarize the results of calculations or record the results d studies. It is not used to work on plant equipment, manipulate plant equipment, a conduct
;         routine tests on ple's equipment; therefwe technical reports do not require 10CFR50.59 screening
.         review / safety evaluations.
1 Technkal reports can originate in Systems & Components Engineering (SCE) or in Design Engineering
;         (DE). Typically the responsible supervisor assigns an originator who prepares the document. If the 4
tc~hnicr' apart originates in Systems & Components Engmeering, the required reviewer is a supervisor              !
l         in Systems & Components Engineering, and the approval authority is the manager of Systems &                       I
)         Camponents Engineering. If the technical report originates in DE. the required reviewer is a discipline
;         Principal Fngmeer in DE, and the Approval Authority is the Manager. DE.
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Attachment I to L:~n. cat Cmtrol Desk Letter                                                 Page 24 of 24 RC-97-0031 Plant Lubrication Manual Change Processing Purnose:
l To control and maintain lutmication informatim to assure component reliability through the Preventive Maintenance Program.
Ef!Itti                                                                                                                     I This change process applies to all plant equipment nqui.mg lubricatim for Preventive Maintenance.                           l l
Process

== Description:==

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Evaluatim maintenance and control d the Plant Lubricatim Manual (PLM) are the responsibility d the Manager Design Engineermg. Changes and additions to the Plant Lubrication Manual are initiated per                          1 SAP-143, Changes or additions to the PLM can be initiated from within and outside d hgia-ing                                j Services by submitting a marked-up copy d an existing Equipment Lubrication Data Sheet (SAP-143) for i
changes or a new Equip;nent Lubricatim Data Sheet (ELDS) for addities. Evaluatim d changes are                              ;
pericuned in accord with ES-418. All approved Equipment Lubricadon Data Sheets are sent to Document Cmtrol for controlled distributim to all PLM holders, j
Significant changes, as described in ES-418, receive a 10CFR50.59 screening review / safety evaluation.
1 When required, sevisims to the FSAR/FPER are processed in accordance with SAP-1163.
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Attachment II to Document Contml Desk letter                                                       Page 1 of 4 RC-97-0031 Information Request (b)
Rationale for concluding that design bases requirements are translated into operating, maintenance, and testing procedures.

===Response===
SCE&G's rationale for cmcluding that that design bases requirements are translated into operating, maintenance, and testing procedures is based upon:
* Multi-discipline procedure reviews
* Systematic processes
* Internalreviews
* Quality Systems activities
* Safety System Fandanal Inspections (SSFIs)
* Externalinspections Service Water System Operational Performance Inspection (SWSOPI)
Electrical Distribution System Functional Inspection (EDSFI)
The programs described in the response to information request (a) provide the bases for the establishment, maintenance, and documentatim of the various design bases and configuration management sources. It is vital that the requirements contained therein are effectively translated into procedures which are used for the operation, maintenanz and testing of the systems, structures and components (SSCs) which comprise the facility.
Multi-discipline Reviews:
The procedure development, review and control process is the vital tool to link the requirements specified in design bases sources to usable, functional procedures. These procedures provide personnel with a means to operate and maintain the facility in such a way as to minimize the risk to the public's health and safety. A systematic approach is taken to procedure development. Once the need for a new procedure is identified, a person in the responsible discipline is assigned the task, and the procedure is processed per SAP-139. A 10CFR50.59 screening review / safety evaluation is performed, which includes a detailed review of 211 applicable sections of Technical Specifications, the Final Safety Analysis Report, and the Fire Protection Evaluation Report. The discipline supervisor of the group responsible then assigns interface reviewers based on an established interface review matrix found in SAP 139.
The scope of reviewers varies with the type of procedure. After the screening review / safety evaluation is completed, it is independently reviewed by a knowledgeable Qualified Reviewer. The Qualified Reviewer reviews the content of the procedure and conducts an independent review of the 10CFR50.59 screening worksheet or safety evaluation. Additional levels of review are provided by independent Quality Control personnel. If the pro:xxiure requires a safety evaluation (any screening review question is answered yes), the procedure change / revision is also reviewed by the Plant Safety Review Committee (PSRC). If any safety evaluation question is answered yes, the activity may involve an unreviewed safety question and is not implemented unless/until NRC approval is obtained. All interface review comments are resolved prior to implementation of the change / revision.

l Attachment II to Document Control Desk letter                                                        Page 2 of 4 4
RC-97-0031 l
Procedures that follow the described process include.
l Operatims Department procedures which require manipulation of plant equipment, are used to work on or test plant equipment, or describe the administrative controls associated with plant f
i operations.                                                                                       i Test procedures which contain unique lineups or configurations to systems and include steps to ensure the test lineup is established, equipment is tested, and the system is returned to its original state in accordance with the plant's design bases. Testing of plant equipment is performed per General Test Procedures (GTPs) and Surveillance Test Procedures (STPs).             j i
Inservice Test Procedures which are developed with the intent of verifving that associated        l compcnents are capable of satisfying their required design or licensing basis function. Required  j design minimum and maximum system flow rates, test pressures, inspection boundaries, stroke
{
times, r.nd differential pressure test limits as applicable and other related test acx:eptance    '
criteria, are documented in the applicable Surveillance Test Procedures.
Maintenance Procedures which are developed with the inteat of verifying that plant components are repaired or refurbished, as required, to return the component to its original design configuration as defined by the vendor or by approved design documents.
1 Systematic Revision Process:                                                                                     i Revisions to these procedures follow essentially the same pro ss as defined above. A primary initiator of changes to plant procedures are as a result of planned modifications to station equipment. The identification of impacts to these procedures takes place during the modification package interface review process. Once the need fx a new proadure, change, or revision has been identified due to the plant modification, a person in the responsible discipline is assigned the task to develop the necessary documentation. For plant modification initiated changes a review by Design Engineering is required. A Qualified Reviewer reviews the content of the changehwision and performs an independent review of the 10CFR50.59 screening review / safety evaluation.
All engineering change packages are reviewed in detail by affected department representativer for procedure and testing impact. Meetings concerning engineering changes are attended by representatives from these affected crganizations. Implementation of the new procedure or procedure change takes place in accordance with a preapproved schedule of activities.
Other initiators to procedure changes are proposed changes (Amendments) to the Technical Specifications, Final Safety Analysis Report, and Fire Protection Evaluatiac Report. Existing department procedures are reviewed fac impact based on these changes. If any procedures are affected, the procedure changes are prepared, and implemented at the time the amendment is implemented.
Internal Reviews:
Internal reviews of these procedures by the VCSNS staff, both before approval and after implementation, represent a programmatic assessment of the effectiveness with which design bases sources have been incorporated into procedures. Vertical slice reviews of eleven (11) plant systems by the Independent Safety Engineering Group (ISEG) represent both an independent assessment of the effectiveness widt which procedures incorporate design bases requirements as well as fostering an attitude of continuous self-evaluation and self assessment.

Attachment II to Document Control Desk letter                                                      Page 3 of 4 RC-97-0031 Sigmficant examples of the type of problems identified in procedures during the performance of SSFis are listed below:
: 1. System Operating Procedure (SOP-306). " Emergency Diesel Generator," Section IV-II,
            ' Transferring Bus IDA from Offsite to Diesel Generator," was revised in February,1988, to eliminate the possibility of loading ESF equipment onto the bus in a different sequence than designed.
: 2. Operations procedures and Technical Specification Iogs did not list a maximum pressure for the service water pump discharge. 'Ibe Service Water System Design Basis pressure was incorporated
          ' into operations procedures and the Technical Specifications Iogs in January.1988.
Maintenance of the VCSNS plant design basis has been enhanced by the SSFI reviews cmducted by the ISEG group. Procedural discrepancies have been identified and resolved, llowever, no deficiencies have been identified to date that have actur.Ily prevented a system from performing its design function in its intended manner.
In addition. Quality Assurance reviews procedures / plans / documents to assure that proposed activities are adequately described and that they comply with sterfacing procedures, applicable codes. FSAR cemitments, standards and regulatory requirements. Quality Control performs additional inspections in the field to assure acceptable levels of quality are maintained.
Listed below are significant procedure deficiencies that were identified during Quality Systems inspections:
Mechanical Maintenance Procedure MMP-250.001, " Encapsulated Valve Chambers, Removal / Installation." did not adequately address the installation me: hod nor did it reflect the correct preloading of the fit.nge toggle bolt assembly for the valve encapsulation chargers as described in Equal To Better Than (ETBT) 231. Quality Control personnel noted this deficiency during a May,1996, inspection and wrote Nonconformance Notice (NCN) 5466.                           l A special audit of the station maintenance program was performed in April,1995. A configuration     I management problem was identified by Finding QA-AUD-95005-1. A Lubrication Manual change            l identified a frequency of six months to change the grease in the bearings of XFN0019A-M and XFN0019C-M. Since the CIIAMPS preventive maintenance program was not revised cmcurrent with the Lubrication Manual change, the frequency identified in the CIIAMPS database remained
            " annual", therefore, the lubrication was not performed at the specified frequency.
* A configuration control problem was noted during the station design activities audit which was performed in July.1995. Finding QA-AUD-950ll-1 was issued for Engineering's failure to obtain required interface reviews for a Modification Change Notice (MCN) during the implementation of Modification Request Form (MRF) 20951. Test procedure ITP-il4.042 was affected by the MCN.
The Fire Protection group was not notified regarding the modification change. This resulted in a declared unsatisfactory test when performing the quarterly flow test per ITP-114.042, due to        ,
modification work in progress.                                                                      I Maintenance of the VCSNS plant design basis has been enhanced by Quality Systems' reviews. Procedural discrepancies including recommended enhancements are being identified and resolved. No deficiencies have been identified to date that have prevented a system from performing its design function in its intended manner.
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Attachment II to Document Cmtrol Desk letter                                                          Page 4 of 4           i RC-97-0031 External Reviews:
External reviews have also been cmducted utilizing a " vertical slice" technique. These reviews are both                    I independent and comprehensive in nature. The SWSOPI and EDSFI inspections provided additional                               l confidence to VCSNS that the design bases requirements are translated into operating, maintenance and                       ;
testing procedures.
The scope of the SWSOPI included verification that the SW System is capable of fulfilling its thermal and 4
hydraulic performance requirements and is operated casistent with its design basis, and assessed the SW
'        System operational cetrols, maintenance, surveillance and testing, and personnel training to ensure the SW System is operated and maintamed so as to perform its safety-related functims. The SWSOPI cmcluded the following with regard to procedures:
: 1. Operating procedures reviewed accomplish their intended objectives.
: 2. Operating logs, with me minor exceptim, comply with surveillance requi ements and are adequate and accurate.
: 3. The ter.hnical adequacy of the maintenance procedures reviewed is acceptable.
: 4. Review of a representative sample of STPs concluded that they are capable of being performed
,                      as written and found the test paths casistent with plant drawings.
The EDSFI conducted in March and April,1992, simila !y concluded the following:
: 1. The Electrical Distribution System has the capacity to perform its intended safety functions.
: 2. The inspection team's overall findings were positive, reflecting good design, maintenance and testing.
Summary:
The rationale that design bases requirements are translated into operating, maintenance and testing procedures is founded on thorough multi-discipline reviews, systematic processes and rigorous internal and external evaluations.
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Attachment III to Document Control Desk Ixtter                                                          Page 1 of 10 RC-97-0031 Information Request (c)
Rationale for concluding that system, structure, and component configuration and perfornunce are ccmsistent with the design basis.
Resmts SCE&G's rationale for concluding that system, structure and component (SSC) configuration and performance are        i consistent with the design basis is:
* Comprehensive Configuration Management Plan.
Administrative controls for administrative changes, engineering change design and implementation, temporary changes, procedure verifications, plant operation including work control process, and other activities affecting plant configuration.
Comprehensive system and component checkout, functional, and performance testing.
* Design Bases review, reconstitution and/or reanalysis.
Self-assessments of safety system functional and performance characteristics.                         i
* NRC and third party assessments such as EDSFI and SWSOPI.
I As described in responses to information requests (a) and (b), VCSNS maintains design bases information within       i various programs and ensures that this information is appropriately translated into procedures in other programs. l The programs which control the configuration of plant's SSCs, and those programs, processes and assessments which provide information on the performance of these items, are the assurance that the design bases of the plant continues to be preserved.
l l
The broad spectrum of programmatic requirements designed to ensure this preservation ranges from engmeermg programs which manage the cmfiguration of calculaticos, documents and drawings, to Operations programs which track the physical configuration of the plant components. Maintenance and testing programs are designed to ensure that SSC performance meets and will continue to meet certain standards of performance, such that their ability to carry out their design function is reasonably assured.
Confieuration Mananement Plan:
The Configuration Management Plan currently includes Design Engineering activides related to self improvement initiatives. The document also includes selected initiatives related to intedacing departments and processes, as required, to enhance Design Engineering's' capability to assure continuing compliance with the Design and Licensing basis for the plant. This plan, along with the processes described in request (a), provide the appropriate controls for management of engineering programs.
Administrative Controle:
The following Operations Programs are used to track the physical configuration of plant components: Control of System Alignment and Operation, Status Control / Removal and Restoration, Temporary Bypass, Jumpers and Lifted leads, Operating Logs, Special Instructions and Station Orders, and the Locked Valve Program.
Control of System Alignment and Operation The normal vehicle for operating plant systems is the System Operating Procedure (SOP). Majcr evolutions such as reactor power changes, startups and shutdowns, and Mode changes are performed through the use of General Operating Procedures (GOP's), but individual system alignments or manipulations are made by the SOPS which are referenced throughout the GOP's. All GOP's and SOPS are written, reviewed, and approved through the SAP-139 procedure process, which ensures all Operating Procedures m:eive a 10CFR50.59 review as part of their

Attachment III to Document Control Desk letter                                                        Page 2 of 10 RC-97-0031 development or change. All Operating Procedures are required to be adhered to, as specified by SAP-123, Procedure Use and Adherence.
System lineups are performed and documented by qualified operators in accordance with operatims standards requiring second verification. This ensures a redundant check on a system configuratim change specified by the SOP. All SOP specified alignments are consistent with design bases referenws as a base cmfiguration for the plant for a given plant state or mode.
Manipulations to the system to effect normal plant operation such as swapping running / idle trains of equipment,  1
, stopping and starting equipment, and placing subsystems in operation are awomplished utilizing subsections of the SOP, Removal of plant equipment to perform maintenanw, whether preventive or to effect necessary repairs, is done through the plant's approved tagging programs.
SAP-201, the Danger Tagging Procedure, speifles the guidelines under which plant equipment is removed from and returned to service. Although primarily concerned with equipment and personnel safety, it provides a framework for establishing and controlling the physical configuration of the plant. Documentation for the current operating cycle is archived in an area accessible to the Control Room, to provide a record of the status of the system and its components. The physical configuration of the plant, incorporating redundant trains and components, normally allows for the removal of equipment for maintenance while at the same time preserving the minimum level of required system performance as specified by the plant's design and licensing bases. Should more involved maintenance be necessary which would require longer term or greater portions of the system to be removed from service, the plant would need to be placed in a mode or state where the design and licensing bases configuration would not be impacted.
SAP-202, " Caution Tagging", is the procedure which establishes a uniform, reliable method for controlling plant equipment which is subject to certain precautions. In addition, it provides a method for evaluating both design change (ECR) and procedure change requirements for caution tagged equipment. Equipment is caution tagged to ensure that, prior to operatim, certain per:inent information regarding its operation is communicated via the tag  i and associated documentation.
1 As part of the preparation of the caution tagout, tu screening questions are asked to determine if other programmatic controls must be employed in addition to the tagout:
Will installation of the Caution Tag require ECR initiation for permanent reposition of equipment that deviates from the FSAR?
Willinstallation of the Caution Tag requirc revision to plant procedures?
If either question is answered,"3es", the appropriate programs fcr plant modification or prowdure change must be initiated prior to the cautim tag being hung. This ensures that the overall programmatic controls for plant configuration management are adhered to, and that the plant is not placed in a state which is outside the design bases, since these programmatic controls both require a 10CFR50.59 screenmg/ safety evaluation be performed.
OAP-105.2," Equipment Misalignment Status",is the Operations prwedure which addresses short term equipment alignments which are different than specified by normal cperating procedures. Due to the short term nature d those alignments, the procedure change program (SAP-139) and Danger Tagging Program (SAP-201) are not required.
Entries into the Equipment Misalignment Status Iog must be approved by the Shift Supervisor or Control Room Supervisor. Their approval indicates that a condition which is unusual exists, and that a procedure change is not

1 Attachment III to Document Control Desk Ixtter                                                          Page 3 of 10 RC-97 0031 required. Additionally, an evaluation is performed to ensure that the misalignment does not impact the compment or system's ability to perform its design function.
All entries in the Equipment Misalignment Status Img are audited every 30 days to determine the need for continued misalignment. Continued misalignment in excess of 30 days results in the item being removed from the Equipment Misalignment Status Iog and tracked via the Caution Tagging program, described above.
Surveillance testing of plant equipment is performed per Surveillance Test Procedures (STPs) which are developed, reviewed. and approved using the SAP 139 process which ensures a thorough 10CFR50.59 evaluation. Test l
procedures contain unique lineups or configurations to systems and include steps to ensure the test lineup is        I established, equipment is tested, and the system is returned to its original state in accordance with the plant's design bases.
Plant personnel are trained on the importance and impact of adherence to plant procedures while operating and testing equipment. Guidelines are established in SAP-139 for Temporary Approvals to procedures to provide a means for quick turnaround, but still incorporate a 10CFR50.59 review and an independent review by a qualified reviewer prior to approval by the Shift Supervisor.
System Status files are maintained to include documentatim controlling the change in a system alignment since the last documented full system alignment. These documents include: Completed danger tagouts. locked valve tracking sheets. STPs. and Removal and Restoration checksheets. This documentation provides a history of any system changes and ensures that the system is kept in or returned to a configuration necessary to perform its function as specified in the design bases.
Status Control / Removal and Restoration                                                                             l Statim Administrative Procedure SAP-205. Removal and Restoratim. specifies the methodology used to control system status for those systems required by pir.pt Technical Specifications or other administrative programs.
Removal and Restoratim (R&R) Checksheets are implemented any time a designated system which is required to be operable is found to be or made to be inoperable, except when done so for the purpose of testing per an approved
: STP, The Duty Shift Supervisor has the respmsibility for operability determinations on plant systems and components.
When applicable, it is his respmsibility for ensuring that appropriate Technical Specificatim Action Requirements are met and time frames are acknowledged such that equipment is restored in a timely manner.                         i All licensed shift positions, including the Shift Engineer (STA) are required to review the R&R log prior to assuming their normal shift positions so that they are aware of changes to the plant configuration.
The R&R checksheet provides all essential document references to allow for the coordinated return of the system or component to service. These documents referenced include: applicable Technical Specification numbers and action timeframes, maintenance work documents or work package numbers, danger tagout numbers. S'l? tasksheet numbers, and, where applicable. Modification Request Form (MRF) numbers. Depending on the pre-planning interface with Operations , an Operability / Return to Service form may also be required. This paperwork ensures that all post-modification testing, procedure development or changes, drawing changes. and training requirements are documented complete prior to the system being declared operable by the Shift Surervisor.
The R&R Checksheet is reviewed by the Licensed Operator at the Controls and the Senior Licensed Control Room Supervisor or Shift Supervisor to ensure all referenced documentation reflects that the system is aligned and has been tested satisfactorily prior to being de:lared operable.

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Attachment III to Document Control Desk letter                                                               Page 4 of 10 RC-97-0031
)      R&R Chechheets are utilized by Engineering personnel to track and trend the performance of systems, structures i
and components to ensure their performance levels are consistent with the design bases. The checksheets are i       audited daily to ensure agreement between the R&R log, plant computer, and Main Control Board identifying tags. Any R&R which has been in effect for more than 30 days is further evaluated to determine if there is justification for the out of service interval and to assess whether an additional programmatic measure is necessary.
4 Temporary Bypasses. Jumpers. and Lifted leads i
In cases where it becomes necessary to lift electrical leads, open electrical links, or install electrical jumpers for in-service plant equipment, Station Administrative Procedure, SAP-148 is implemented. This procedure is utilized in cases which are not addressed by other existing Operating Procedures developed, reviewed, and approved under SAP-139 specifically for equipment status control. It is also not meant to supersede or duplicate those temporary modifications to the plant which are approved and installed under SAP 133 and ES-416. In all cases, the programmatic process utilized incorporates a 10 CFR 50.59 screening and review.
i Bypass Authorization Requests (BARS) are submitted by the originator to Operations Management to determine l
the necessity and applicability of the request. If determined that the request is not addressed by an existing procedure, nor that it involves a temporary modification, it is assigned to a Shift Engineer (STA) for completion.                   l 1
l The Shift Engineer (STA) reviews the request for technical accuracy, and performs a 10CFR50.59 review to screen                      <
for any Unreviewed Safety Questions. The General Manager, Nuclear Plant Operations must give final concurrence prior to implementation of the BAR. The actual installation or bypass is accomplished through the controls of Plant                  1 Maintenance Procedures (SAP-300) and is coordinated by the Shift Engineer (STA).
l 4      The implemented BAR is reviewed by the Plant Safety Review Cnmmittee (PSRC) for its impact on plant safety.
The PSRC verifies the bypass does not constitute an unreviewed safety question and ensures the bypass does not require a change to Technical Specifications. Design Engineering reviews BARS for concurrence or disapproval in accordance with ES 403.
Quarterly Audits are performed on each outstanding BAR to assess its continued applicability or whether a permanent design change to the plant is more appropriate.
Operatina Logs Operating logs are another mechanism used to periodically document surveillances on equipment and operating parameters which define the reference bounds for the design of the plant. These surveillances are normally defined i
by the Technical Specifications but also include equipment operating parameters which are essential to ensuring that equipment performance is consistrat with the design basis.
Parameters monitored periodically per required logs are controlled by Operations Administrative Procedure OAP.
106.1. Changes to the facility per the appropriate design processes are fed into the operator logs through revision to
 !      this procedure, which includes the logs themselves as Attachments. This is accomplished through the SAP-139 process and includes a 10CFR50.59 evaluation. Operations interface in the planning phase of the Modification process ensures timely recognition of certain specific logged parameters associated with the design bases such that necessary changes to tha logs are identified.
Special Instructions and Station Orders 1
Special Instruction and Station Orders are a means of establishing policy or disseminating short term informdon to shift personnel tasked with operating the plant. These administrative controls are of an informational nature and 4
are intended to supplement, not supersede, the bank of approved operating procedures.

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Attachment III to Document Control Desk letter                                                          Page 5 of 10 RC-97-0031 Locked Valve Program The lackM valve program, as described in Operations Admmistrative Procedure OAP-106.3, provides the
 ; administrative cmtrols for valves which are required, due to the extreme importance of their cmfiguration, to be locked in position. Rese components are required for reasons specified in sources including the design bases, to be locked in a controlled position which may be open, closed, or throttled depending on the valve's design functim.
The act of locking the valve limits the chance of accidental operation by requiring a separate cmscious action in order to change the valve's position, and, thus, the plant's configuration.
A locked valve tracking log provides the admmistrative mechanism for identifying all companents within the i program, as well as the current serial numbers for the locking devices.
l  Maintenance Work Requests This process provides control of the maintenance and repair process and ensures that SSC cmfiguratim and performance remain consistent with the design basis.
+
l  Equipment repairs are accomplished under the Maintenance Work Request (MWR) process under the guidelines of SAP-300 and SAP-601. Activities are planned and controlled through the planning and scheduling department.
Activities are scheduled to coincide with other work being performed on a system and reviewed by Operations to ensure designated protection train equipment is available to perform its safety function.
Prework reviews are required by SAP-601 to be performed by the responsible discipline planner, Quality Cmtrol.
Health Physics, and Operations. Additionally, for activities associated with air operated valves, motor operated valves and modificatims, an Engineermg Servi s review is required.
l  Equipment is reworked to its original design condition. When rework has been completed a retest is performed to verify equipment performs its designed functim. Post-maintenance retest is controlled by GTP-214. Retest
:  requirements are determined by the responsible planner, perfoemer and job supervisor. Operability retest requirements are determmed by Operations.
Upon completion each package is reviewed by the Respmsible Supervisor Quality Cmtrol. Operatims Systens and Component Fngineering, NPRDS Coordinator, and Planmng and Scheduling.
j  Equipment problems and failures which require immwiiate attention are designated " priority" by the Shift Supervisor. Due to the necessity to work these items as soon as possible after they have been identified, they do not go through the normal planning and scheduling process. However, they still are reviewed, implemented, and retested in the manner described above.
Replacement parts are purchased as exact replacements. If a part is unavailable and substitution is required, the replacement part is certified by an " Equal To/Better Than" evaluatim by Engineering Services. Quality Control verifies replacement on safety related and quality elated components.
System and Component Testine:
Surveillance Testing and Preventive Maintenance Programs Rese programs provide a means for smveillance tests, calibratims and preventive maintenance performed by the
 , VCSNS Maintenance department to ensure that SSC cmfiguratim and performance remain consistent with the design bases.

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Attachment III to Document Control Desk letter                                                           Page 6 of 10 ,
RC-97-0031                                                                                                            I l
System performance and accuracies are verified through periodic testing to meet the requirements of Technical Specifications, SAP-134 (Surveillance Tests) and SAP-143 (Preventive Maintenance).                                    I Activities are planned and scheduled through the Planning and Scheduling group to ensure that the work is being performed during the proper train maintenance period, providing assurance that the designated protected train equipment is available to perform its required safety function. The work is coordinated through the Operatims         j department to ensure that the current plant conditims allows the work to be performed, in a time frame not exceedmg operability commitments.
l The level of review is dependent upm the type of work performed. Surveillance tests are reviewed by the Operations Shift Supervisor, respmsible discipline supervisor, Quality Cmtrol, and the outage scheduling supervisor. Preventive maintenance reviews are conducted by the respmsible discipline supervisor, Operations, Quality Control, and Systems and Component Engineering. Test /calibratim packages are reviewed for data accuracy. Test deficiencies are evaluated for operability impact and resolved commensurate with their safety significance.
IST i rogram                                                                                                          l The following discussion presents the attributes of each individual program that makes up the IST Program, and        i how the associated testing verifies the ability of the systems and associated components to meet the design bases.
Pump Program:
The Pump IST Program, as described in GTP-301, incorporates the requirement that the " operability          l limits of pumps must always meet, or be consistent with, Licensing Basis assumptions in the plant safety analysis". Pump performance data is compared to IST limits as documented in the Surveillance Test Procedures for tested pumps. In addition, pump performance data is compared to both IST limits and          ;
licensing basis limits as documented in the Surveillance Test Procedures for the Charging /SI, Emergency    l Feedwater, and Residual Heat Removal Pumps.
Valve Program. GTP-302:
The Valve IST Program, as described in GTP-302, provides for inservice testing of specified valves to ensure operational readiness of the valve to perform its intended function. Acceptance criteria, for example, maximum stroke time allowable, are specified by valve type to ensure compliance with the Design Bases assumptions.
System Pressure Testing. GTP-304:
The implementation of the System Pressure Testing Program is documented in the associated Surveillance Test Procedures. These Surveillance Test Procedures document the required test boundaries and required test pressures. The selection of test boundaries and associated test pressures are based on the application of the associated code requirenlents in conjunction with the safety function of the system as described in the plant's design and licensing basis documents.
Inservice Examination Program The Inservice Examination (ISE) Program is a 10 par plan maintained to schedule, implement and report the inspections performed for compliance with the ASME Code, Section XI,1989 Edition. These inspections are for the purpose of monitoring the structural reliability of code systems.

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Attachment III to Document Control Desk letter                                                             Page 7 of 10 RC-97-0031 l
In additim to the mandatory requirements of the AShE Code, the program also addresses piping and component inspections performed for ccxnpliance with regulatory documents such as Regulatory Guides, Bulletins and Plant Technical Specifications, where the inspections are similar to those required by the code.
The scope of the Inservice Examination (ISE) Program is limited to visual, surface and volumetric nm-destructive examinations (NDE) of plant piping and compments, with the exception of snubbers, which are also dynamically tested. The compments that are subject to examination are, for the most part, defined by the AShE code.
However, several examinations are performed on items in respmse to Technical Specifications or other regulatory documents.
The following describes the elements of the Inservice Examination Program:
Piping and components are mcnitored to assure pressure boundary integrity. NDE examinations are performed in accordance with the requirements of Section XI of the 1989 edition of the AShE Code. These requirements assign one or more methods of NDE to be performed on various populations and at frequencies which assure that the structural integrity of code boundaries are within design requirements.
Component supports are monitored to assure their .icsign functier, is maintained. Visual examinations are performed on supports in accordance with the requirements of Section XI of the 1989 editim of the AShE Code.
These requirements prescribe the population and area of interest of supports to be examined to assure supports are adequately providing their design function.
Visual examinations and dynamic testing are performed on snubbers as prescribed by Technical Specifications.
These requirements also satisfy the requirements of the AShE Code and assure that snubbers are adequately providing their design function.
All inspections, including those associated with pressure testing, performed to satisfy the ISE program, are reported each refueling. Repairs and material replacements are also reported, when required by the code, each refueling.
1 All items identified as a result of the ISE program receive specific corrective actions or evaluations as prescribed by I the code. These actions assure that the design parameters of the material are maintained prior to continuing service.
The ISE program (the 10 ear   3   plan) is reviewed and approved by Quality Systems and the Authorized Nuclear Insurance Inspector (ANII). The current, as well as the previous. ISE programs were submitted to, reviewed, and approved by the NRC.
The Inservice Examination Program reports are reviewed by the ANII agency, and a Ievel III NDE Inspector.
The refueling inspection summary report (NIS-1)is submitted to the NRC for review.
Desien Bases Review / Reconstitution Efforts:
SCE&G has performed a large amount of design basis review, reconstitutim and/or reanalysis as a result of past projects. These efforts give added confidence to our rationale that our SSC configuratica is consistent with the design basis.
Design Basis Documents (DBDs) were developed between 1985 and 1993 by the Architzt/ Engineers, NSSS supplier and equipment vendors from the following documents: FSAR, Technical Specificatims, calculations, drawings, technical reports, vendor manuals, design / construction specifications, files, and correspondence. The program consists of 43 individual DBDs covering the major plant SSCs and relevant topical areas. The purpose of the DBD program was to assemble and capture the design basis information for VCSNS.

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1 Attachment III to Document Control Desk letter                                                         Page 8 of 10   i RC-97-0031 Each DBD was originated by the Architect Engineers or NSSS supplier using senior persmnel who were involved and familiar with the original design of VdNS. Draft DBDs were reviewed externally by a multi-discipline task       l force of senior personnel at the originating organizatim, and internally by knowledgesble personnel in SCE&G's        l Engineering. Operations and Maintenance Departments.                                                                l l
Several assessments and inspections have been conducted since 1989 which have provided a continuous.
l comprehensive focus on design bases review and maintenance. Some examples are the Equipment Qualificatim              l Assessment, the IPEEE assessment, the Service Water System Operational Performance Ir.spectim, and the                I Electrical Distribution System Functional Inspectim. Reviews conducted for these effcrts have resulted in the identification and performance of nconstitution and/or meanalysis of Design Bases.
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I From 1992 to 1996, Steam Generator Replacement. Low Pressure Turbine Rotor Replacement, and Plant Uprate            I changes served to reanalyze the entire FSAR Chapter 15, Accident Analysis. These comprehensive engineering          l projects revisited (either through reanalysis or reconstitution) all FSAR Chapter 6 and 15 accident analysis.       I Additionally, a review of supporting plant systems was conducted for impact due to these major plant projects.
Due to changes in the design bases resulting from the above projects, reanalysis and/or reconstitution was performed on these systems.
Beginning in March 1996. SCE&G initiated an FSAR review effort which included (1) an Outage Review, (2) an MRF Review, and (3) an Overall FSAR Review. This FSAR review effort is described in detail in Section (d).
The Overall FSAR Review is an ongoing, systematic and prioritized assessment focusing on discrete systems and programs which correlate with the Design Basis Documents. The approach includes a comprehensive assessment to assure consistency between the FSAR and the DBDs cr other controlled documents, and a review of those aspects of the FSAR pertinent to safe operation for accuracy and consistency. Thus far, six systems have been reviewed under this approach. No findings to date have involved safety-significant concerns.
SCE&G plans to continue the Overall FSAR Review described above. / Note: This commitment is listed separately in order to avoid confusion as to what commitment is made under this letter. Any other descriptions or programs are subject to change in accordance uith our normal review and change practices, and are not to be considered commitments.)
I' Self Assessments:
VCSNS has conducted several self-assessment activities of safety system functional and performance characteristics. Self-assessment activities provide feedback to cmfirm that activities related to plant cmfiguratim and performance are satisfactorily accomplished. The following provides the type of self-assessment conducted, and examples of the issues identified.                                                                                l 1
Vertical slice reviews of eleven plant systems have been conducted by the ISEG group since 1987. These represent both an independent assessment of the operational readiness of a sptem to meet its design bases seguirements (i.e.,
determine if the system is capable of performing its design basis functim) as well as fostering an attitude of continuous self-evaluation and self assessment.
An indication of the type of comments generated from performance of an SSFI are listed below.
: 1)        The minimum emergency feedwater flow control valve accumulator pressure listed on the Auxiliary Building Technical Specification log was inadequate to meet the post accident design requirements to maintain the valve closed for three hours after the event. To ensure adequate pressure, plant modification (MRF 21215) was implemented in 1987 to place full instrument air system pressure on the accumulator.

4 A:tachment III to Document Control Desk Ietter                                                            Page 9 of 10 RC-97-0031
: 2)        Adequate guidance was not provided for determmmg A) which HVAC compments were                            ,
necessary to support safety related equipment nor B) the maximum equipment operability temperature limits. The HVAC DBD was revised in June,1991, resolving this issue.
: 3)        Incmsistencies between the CVCS DBD and Westinghouse calculatim N4SA-CG-165 concerning instrument alarm setpoints were discovered for the:
: a. Boric Acid Tanks Temperature
: b. Reactor Coolant Pumps No.1 Seal Differential Pressure
: c. Reactor Coolant Pumps No.1 Seal Bypess Flow i                                 Completion of three plant modificatims (MRFs 10673,10734, and 22052) in 1991,1991, and i                                 1995 respectively, revised the setpoints addressed in this concern.
,'                      4)        Reactor Vessel coupon surveillance requirements and Heatup and Cooldown curves in use did not match the FSAR specificatims. The FSAR was revised in August,1993, correcting these inemsistencies.
Maintenance of the VCSNS plant design basis has been enhanced by ISEG's reviews. Design discrepancies have been identified and resolved. However, no design d(ficiencies have been identified thr.t have actually prevented a system from performing its design function in its intended manner.
I The VCS Quality Assurance Organization performs ratine audits of Design Engineering activities. The program includes measures necessary to verify cmformance with the directions contained in the FSAR and the Operational
* Quality Assurance Plan. In the past, these audits tended to cmcentrate a procedure compliance areas. In the last two years, however, additional focus has been directed toward configuratim management and how well our design
;              documentation is maintained Examples of deficiencies that were identified during Quality Systems inspections:
: 1. During the Eddy Current inspectim of Diesel Generator "A" Intercooler Heat Exchanger, indicatims i                            revealed 405 of the 406 tubes reflected areas of wall thickness loss. As a result, Quality Control wrote NCN 5402 to identify the problem and have it resolved.
: 2. 'ihe QA audit of Design Engineering activities performed in 1995 resulted in four findings and a Corrective Action Request (CAR).
The four findings were written against responsible organizations as described below:
Operations for the SAP 148 procedure not addressing drawing hold stamps                              l
* Licensing for not maintaining the FSAR cunent with respect to MRFs
* Nuclear Support Services for status control of design documents
                                  *-   Systems Engineermg for a troubleshooting MRF                                                         ;
I These items are resolved pending Q A verification.
i The major areas in the Corrective Action Request can be summarized as follows:
* Backfit old calculations to identify in progress work
* Clearing / Updating drawing hold stamps for closed design packages
* Establish finner catrols on design calculations
* Overview "Old Packages" for additional impacted documents

i l
Attachment III to Document Control Desk letter                                                          Page 10 of10 RC-97-0031 Corrective Actim Request respcose action is approximately 95% complete for the identified deficiencies. Completion is expected in 1997.
QA audits provide an additional level of confidence that acceptable quality is maintained.                           I Third Party Assessments:
l External reviews have also been conducted utilizing a vertical slice technique. These reviews are both independent and comprehensive in nature. The SWSOPI and EDSFI inspections provided additional confidence to VCSNS that           !
system, structure and component (SSQ configuration and performance are consistent with the design basis.
The scope of the SWSOPI included verificatim that the SW System is capable of fulfilling its thermal and
. hydraulic performance requirements and is operated consistent with its design basis, and assessed the SW System operational controls, maintenance, surveillance and testing, and personnel training to ensure the SW System is operated and maintained so as to perform its safety-related functions. The SWSOPI conckded the following with regard to SSC configuration and performance:
,           1. The Service Water System meets it's thermai/ hydraulic performance requirements.
: 2. Operating procedums reviewed accomplish their intended objectives.
: 3. Pump and valve surveillance and testing programs established for the SW System are thorough and contmue to demonstrate the SW System will operate as designed.
  'lhe EDSFI similarly concluded the following:
s
: 1. The Electrical Distribution System has the capacity to perform its intended safety functions.
: 2. The inspection team's overall findings were positive, reflecting good design, maintenance and testing.
Summary:
The rationale for concluding that system, structure and component (SSQ configuratim and performance are consistent with the design bases is founded on a Comprehensive Configuration Management Plan.
Administrative controls for administrative changes, engineering change design and implementation, temporary changes, procedure verifications, plant operation including the work control process, and other acdvities affecting plant configuration. Comprehensive system and component checkout, functicnal, and performance testing. Design Bases review, reconstitution and/or reanalysis, self-assessments of safety system functional and performance characteristics, and NRC and third party assessments such as EDSFI and SWSOPI provide additional confidence that our SSC configuration and performance are consistent with the design bases.

i
:    Attachment IV to Document Control Desk letter                                                            Page 1 of 14
(    RC-97-0031 i
Information Request (d)
(d) Processes for identification of problems and implementation of corrective actions, including actions to determine the extent of problems, action to prevent recurrence, and reporting to the NRC.
Oversight of activities at VCSNS is provided by our line organizations as well as independent review groups. In-line oversight includes management and interdisciplinary reviews, testing and verification activities, and internal evaluations. Independent oversight includes the periodic audits and inspections under 10 CFR Part 50. Appendix B. as well as self-assessments of functional areas and activities and " vertical slice" assessments of major plant l    systems. The results of these oversight activities give us added confidence in the structure and functioning of our programs to maintain design bases control and consistency. An important part of the safety culture at VCSNS is to          ,
encourage the identificatim of nmconformances, weaknesses and areas for improvement. When nonconformances are identified, they are processed through the 10 CFR Part 50. Appendix B corrective action program. This program calls for an appropriate review for the cause and the extent of the condition and development of prompt and effective corrective actions.
VCSNS utilizes a number of site-wide, comprehensive programs for identifying problems at the station. In addition, independent reviews and assessments are used to provide added assurance that our problem identification          ;
is thorough and complete. These processes are comprised of the following:
* Continuing Program Overviews                                                                                 '
: l. Condition Evaluation Reports (CERs)
: 2. Nonconformance Notices (NCNs)
: 3. Quality Assurance (QA) Audits
* Department Improvement Initiatives
* Independent Assessments / Overviews
: 1. VerticalSlice Review
* Electrical Distribution System Functional Inspection (EDSFD e    Service Water System Operational Performance Inspection (SWSOPI)
* Safety System Functicnal Inspections (SSFIs)
: 2. FSAR Review
                                                                                                                                 )
l The following pages in this section describe those activities associated with these reviews and assessments.                i l
l

Attachment IV to Document Control Desk letter                                                            Page 2 of 14 RC-97-0031 Pmeram Overviews:
Condition Evaluation Reports

==Purpose:==
The purpose of this process is to provide a method for identifying, documenting, evaluating, reporting, and verifying resolution of conditions potentially adverse to quality and/or reliability of the plant.
Scope:
This process applies to any events, occurrences, activities, programs and/or hardware which may not be consistent with known practices and information. 'Ibe process applies to all personnel working at the plant.
Procram description:
SAP-ll22 provides a single set of forms and administrative guidelines for plant personnel to identify plant related problems. The procedere provides guidelines on the threshold fa identificatim, documentation, reporting, evaluation, disposition and completion of corrective action. Supporting this administrative procedure are several interfacing procedures which provide specific details on how to perform the various evaluatims including:
equipment operability,10CFR50.72/73. Reportability,10CFR50.59 Unreviewed Safety Evaluation,10CFR21 Reportmg of Defects and Noncompliances, etc.
Both hardware and non-hardware related problems are identified and processed by the program. Those conditions which affect or potentially affect equipment operability, reportability or could affect continued plant operation are evaluated by the Shift Supervisor, who is responsible for initiating appropriate compensatory action, as required.
After the Shift Supervisor review, the CER is sent to Nuclear Licensing & Operating Experience for a reportability evaluation (if applicable), and then to an appropriate dispositioner where 10CFR21,10CFR50.59. and/or any other evaluations are performed. The dispositioner then provides a disposition, identifying a cause and corrective action.
The CER is then sent to the assigned action group where the disposition is implemented.
Trending & Root Cause Analysis:
Periodic trending is performed in accordance with Station procedures. Result of these trends are documented, n: viewed by management and identified weaknesses tracked until corrective actions are completed.
Root Cause evaluations are performed per SAP-900. This procedure provides administrative guidelines on when a root cause should be done, how to perform an evaluation, how to document the results and tracking close out of the corrective actions identified.

Attachment IV to Document Control Desk letter                                                           Page 3 of 14 RC-97-0031 Nonconformance Control Program: QA Review Purtwie:
Quality Control (QC) is responsible for identifying, reporting, and cmtrolling nmemforming conditions. Quality Assurance (QA) reviews Nonconformance Notices (NCNs) to assure that the condition is adequately described, the dispositim will not violate established FSAR requirements, and the quality requirements, methods, etc., are adequately addressed.
Scope:
QC is responsible for assuring that the plant's design bases are maintained following a Nonemformance, which include: physical defects, test failures resulting from a hardware defect, incorrect or inadequate documentatim, and deviatims from prescribed processing, inspection, or test procedures resulting in a hardware impact. QA review is required for all NCN dispositims prior to implementation as addressed by SAP-ll41, "Noncmformance Cmtrol Program." and QSP lO4, " Review of Nonconformances."
Program

== Description:==

QC verification is required for all dispositims relating to Nuclear Safety Related and Quality Related components and/or systems. While not required for Non-Nuclear Safety Related dispositions, upon request by the dispositioning engineer, a verificatim is performed. The verification ensures that the disposition in its entirety is implemented. The methods of verification include, but are not limited to: monitoring the work activity, reviewing data, and performing NDE testing, as applicable. The NCN dispositim may be questioned and returned to the engineering group for further dispositioning. For example, when the NCN requires the replacement of a component, QC will verify the material, configuration and/cr installation. Any deviation from the original hardware or design, that has not been previously addressed, will be questioned, and resolution will be obtained prior to final acceptance. When a drawing or procedure requires revision by a disposition, QC initiates a Request for Document Hold or Revision Notice (SAP-1141, Attachment VI) and routes the notice to the responsible group ensuring proper notification of all affected plant persmnel in a timely manner, Due dates are assigned and tracked.
Quality Assurance reviews NCN dispositions per QSP-104," Review of Nonconformances," to ensure that:
l
: 1. The description of the nonconformance is the same as the condition addressed by the NCN                I disposition.
: 2. Cause and correction action is adequate, and common mode failures are considered.
: 3. All regulatory requirements, reportability reviews, design basis criteria, codes, etc., necessary to resolve the nonconformance and assure quality are considered.
: 4. All impacted documents are referenced on the NCN so that a Request for Revision Notice is generated.
The aforementimed reviews specifically cmsider a 10CFR50.59 review, a 10CFR50.72/50.73 review, and a 10CFR21 evaluation. He review of impacted documents not only cmsiders applicable procedures / drawings, but data bases and programs such as the EQ Data Base. Erosion / Corrosion program, and the Plant Lubrication Manual. Any comments resulting from the above reviews require resolution prior to concurrence with the disposition. Concurrence with a disposition determination is indicated by the reviewers signature on the SAP-1141, Attachment I form.
In addition, Quality Assurance performs semi-annual audits of the NCN program per Technical Specifications section 6.5.2.8.c. The NCN program is assessed for compliance to regulatory and procedural requirements during

Anachment IV to Document Control Desk leuer                                                         Page 4 d 14 RC-97-0031 i
the performance d the audits. Surveillances d elements d the NCN program may be scheduled per QSP-15,                     !
                         " Scheduling of Quality Assurance Surveillances."                                                                         '
k i
f t
t k
f h
I l                                                                                                                                                  i 1
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l I
t l
I i

   -. .    ~ - . - . . -             - . , - . . . - - . - . - . .- - . -                   _. ~ . - - - . - . .                   . - - . ~ _ . -
i                                                                                                                                                    -
Awh-t IV to Document Control Desk letter                                                                 Page 5 of14                 i RC-97-0031 l
t Quality Assurance (QA) Audit / Surveillance Program                                                                                  !

==Purpose:==
Audits are programmatic evaluations to determine that applicable elements d the quality assurance program have l'              been developed, documented, and effectively implemented. Surveillances are much narrower in scope (one or 1
several program elements evaluated) and provide an in-depth evaluation of the particular activity being assessed.
l               Surveillances are usually performed en-mansurate with work activities being caducted; surveillances employ                           l l               performance based techniques which focus on the areas, activities, and elements that are most important to safety and reliability, Currently, Quality Assurance schedules audits to meet the requirements for the performance of audits within the                      h areas identified by Technical Specificatims sectim 6.5.2.8.           Audits to ensure conformance to the Technical -
Specifications. Operational Quality Assurance Program, and Fire Protectim Programs, for example, are required.
If the results of monitoring indicate the need fa more frequent audits and special audits, or if manngement requests the need for additional audits; they will be performed.
[
Surveillanas are scheduled at a frequency commensurate with the work activities potential impact to the plant. As                    !
a minimum, one surveillance is performed per month within the Maintenance and Operatims category, and one surveillance is performed per quarter within the Fngineering category. An increased frequency may be prescribed                      ;
l               for groups identified with areas of concern                                                                                          ~
Prustram

== Description:==

The audit / surveillance program is addressed by QSP-106,'" Conduct of Quality Assurance Audits and Surveillances," QSP-107, " Conduct of Performance Based Activities," and QSP-15. " Scheduling of Quality Assurance Surveillances."
Sectim 17.2 of the FSAR addresses each of the eighteen criteria of 10CFR50, Appendix B. This section provides the Operatimal Quality Assurance Program (OQAP) fa the plant and describes the actions to be taken by SCE&G to assure that the safe operation and installed quality of equipment in the plant are maintamed throughout the operatimal life of the plant. The OQAP is the implementation document sub-tkr to the FSAR, Section 17.2. As previously stated. Techn*w al Specifications requires the audit d activities required by the OQAP. The areas d design, procurement, installation, inspection, testing, operation, maintenance, and refueling, for example, are assessed for cmformance to previously established requirements which affect the installed quality and operatimal capability of the station. Audits /surveillances provide an evaluatica d the adequacy and effectiveness of the program measures established for the areas being audited.
Audits and surveillances are conducted in accordance with the reference procedures which describe the methods used for preparing, caducting, and reportmg audits /surveillances. QSP-106 and QSP-107 require an evaluation for program adequacy by the use of scope sheets and checirlists, which consider design bases information in the FSAR. Reports must identify deficient conditions found (CARS, Findings, and QAls) and recommendations fa corrective action. The formal report is forwarded to management for evaluatim, response, and, if necessary, the                       l timely initiation of corrective action. Respmses are evaluated for acceptability and corrective action is verified to be satisfactorily implemented prior to the closing of a deficiency.
Provisions are made to escalate the issues to the appropriate level of management to obtain resolution in a time frame commensurate with its safety significance.
l l

4 Attehment IV to Document Control Desk letter                                                              Page 6 of 14 RC-97-0031 Department Improvement Initiatives

==Purpose:==
Informal or formal procedures or instructions used to provide feedback to individual groups on clarifications of group responsibilities and field activities.
Program

== Description:==

I i   A number of mechanisms are in place to provide feedback to initiate procedure / program improvements. The following are typical examples of such feedback mechanism to identify and update documents for the Mechanical Maintenance Department.
Rework Analysis: Used to identify conditions caused by a previous maintenance activity or a condition not resolved during previous activity (Maintenance Special Instruction 32).
Task Feedback form: Used to identify problems, deficiencies or situations not covered by the planning and scheduling process of a maintenance evolution (SAP-300).
Procedure Change Request form: Used to identify procedure errors, points of confusion or areas where enhancement can improve procedure performance. Note: Any error that will prevent performance of a procedure as written is processed as a change prior to procedure use (SAP-300).                   ,
Initiation of these requests are reviewed and incorporated into controlled documents, as required, to prevent recurring issues or undesirable activities from the workers point of view.
j                                                                                                                                  '
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                                                                                                                                   )
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Attachment IV to Document Control Desk lettn                                                           Page 7 of 14 RC-97-0031 Independent Assessments:
Vertical Slice Review: Electrical Distribution System Functional Inspection Purrme:
Assess the capability of the Elec+rical Distributim System to perform its intended functims and the adequacy of the engineering and technical suppt provided to maintain the operability of the system.
Scope:
: 1. A technical review was conducted by the licensee to provide an assessment of the readinet i the plant electrical design and its associated documentation to meet the requirements of an Electrical Distribution System Functional Inspection (EDSFI).
: 2. The NRC inspection consisted of a selective review of design calculadons, relevant procedures, representative records, and installed equipment; including interviews with engineering and technical support staff.
Proeram

== Description:==

The readiness technical review conducted by the licensee was performed by a team over a three week period at the plant. The items and concerns raised by the review were assigned to various individuals or groups for actim and resolution. The response team resolved the items and concerns and followed the recommendations of the technical review to prepare for the EDSFI. The EDSFI repats for other plants were reviewed and concerns or findings documented. These cmcerns were each reviewed for applicability to the plant and the appropriate action taken to resolve the issue as applied to VCSNS. The self-initiated efforts and Design Engineering's level of preparation of design documents such as calculatims, design basis documents, and licensing documents led to a successful NRC EDSFIinspection.
The NRC assessment of the capability of the Electrical Distribution System (EDS) was based on findings and conclusims obtained by examining and evaluating the design, installation, modification, operation, maintenance, and testing of the EDS and the other systems which support its functions. Considerations in assessing engineering and technical suppcxt included adequacy of modifications, problem identificatim and resolution, support provided in testing and analysis of results, etc.
Electrical compments considered in the assessment included the off-site circuits from the 115 and 230 kV switchyard; the Emergency Diesel Generators (EDG); the 7.2 kV and 480 VAC transformers; the 7.2 kV switchgear and related equipment; the 480 VAC switchgear, load centers, and motor control centers; the 125 VDC batteries, chargers and distribution systems; the 120 VAC distribution systems; protective relaying; AC grounding; and electrical penetration protection. Additionally, the mechanical systems which are required to support the EDG and provide cooling for electrical components were specifically examined. These included the EDG engine, air start system, lube oil system, fuel oil system, and water cooling system; and the necessary IIVAC for various EDS components.
EDSFI Results:
The readiness technical review identified several significant concerns in the mechanical, elec+ al, and surveillance areas. As a result of this review reveral calculations were updated and revised for tl electrical loading and voltage drop, the diesel generator electrical loading and diesel fuel oil loading consumption, IIVAC loading, and battery loading. The review revealed that Motor Control Center motor protection thermal overload devices as well as breaker and load infamation were not being tracked and properly recorded for the updating and revision of design drawings and calculations. Electrical maintenance procedures and methods were not adequate

_._ _ . _. . __            . _ _ . _ _ _ . _ _ _ .      _    - - _ _ . _ _ _ _ _ _ __. _-                      ___ _ __ _ ._. _ _ ~ _ _ ,
1
!                   Attachment IV to Document Control Desk I.etter                                                                Page 8 of 14 RC 97-0031 i
i i                   to provide evidence for periodic inspection d various electrical items. Some operations procedures did not collect           ;
j                   and document adequate data to support design consideratims.                                                                  '
l                   Corrective n=asures were taken to resolve the readiness team cmcerns. The team assessment cmcluded that based                t on the level of preparatim activities and the availability d design documents such as calculation, design basis              i i                  documents, and licensing basis document that the self-initiated efforts and ability to support an EDSFI were better          5 that average.
The NRC inspection team assessed the adequacy of the engineering and technical support provided to maintain the Electrical Distribution System (EDS). The assessment was based on examination of the following areas: technical organizations and interfaces, problem identification and resolution, modifications, and engineering involvement in routine plant EDS activities.
The inspection team assessed the capacity d the EDS to perform it intended functions and the adequacy d the
;                   engineering and technical support provided to maintain the operability of the EDS. It was concluded that:
i i                             1. The EDS has the capacity to perform its intended safety functions
:                             2. Engineering and technical support are adequate i
j                   The inspection team's overall findings were positive, reflecting good design, maintenance, and testing. Various strength were observed. Examples included the availability of a computer program to analyze the DC system, a l                   generally good fuse control program, good monitoring of fuel oil quality, and knowledgeable engineering personnel.
Several matters of concern were identified, but their impact on the overall adequacy of the EDS and of engineering j                   and technical support provided to maintain the EDS were limited. These matters included violations of regulatory i                   requirements, a deviation from a enmmitment, and other negative findings. There were four violadons, one j                   deviation, and four findings identified in the audit.
3
?
i i                   All violations ano findings have been resolved and the items closed in an NRC follow-up audit. There are no                   i
{                   outstanding items or concems as a result of the EDSFI.
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Awh-at IV to Document Control Desk letter                                                             Page 9 of 14  .
RC-97-0031
!                                                                                                                                 i 4
i
: j.           Vertical Slice Review: Service Water System Operational Performance Inspection (SWSOPI) a
!            P igg3lllgg:
l I
l 3            Assess VCSNS' planned or completed actions in response to Generic letter 89-13. " Service War System                 {
j            Proble:ns Affecting Safety-Related Equipment," dated July 18,1989.                                                   I i                                                                                                                              1 5
Verify that the SW System is capable of fulfilling its thermal and hydraulic performance requirements and is j            operated consistent with its design basis.                                                                           l I
I '
J            Assess the SW System operatimal controls, maintenance, surveillance and testing, and personnel training to
{            ensure the SW System is operated and maintained so as to perform its safety-related functions.
l                                                                                         .
8
;            Assess VCSNS' preparatory actions taken and/or proposed to address issues identified as a result of their l            preparations prior to the SW System self assessment.
i            Provide eachnal=y and industry experience transfer thmugh the inspection process. General areas of focus were:
?
* Re===andations for Design Bases Enhancement
* Walkdown and Planned Maintenance Programs
* I&C Setpoint Program
{
j
* Configuration Managunent Program i                        e              -
R+ --< ==dations on the Design Control Program Self Assessment Methodology i
)            U
,            The scope of this assessment included selected SW System components and interactims of the SW System and
!            supportmg systems including modificatims to these systems. Other plant programs and organizations were
,            assessed as they applied to the SW System to determine whether these programs were implesnented in a mann r to i            operate, support and maintain the SW System consistent with the design basis.                        These other 1            programs / organizations were: Operations, Maintenance, Surveillance and Testing, Training, Corrective Action j            and Quality Assurance. Nuclear Regulatory Canmission (N'C) Inspection Manual Temporary Instruction No.
2515/118, Rev. 2, was used as guidance to perform this inspection.
1            Prestram

== Description:==

;            The SWSOPI Inspection Team consisted of seven contract consulting engineers with 146 3ears cumulative nuclear l            power plant experience, at the Engineer level, as well as direct line management in Operations Maintenance, l            Engineering and Chemistry. This inspection provided an independent assessment from mtside individuals who 3           had performed numerous SWSOPIs, EDSFIs, SSOMIs, SSFIs and HVAC Inspections.                                         j ji                                                                                                                                 -
Over 1.100 hours were expended fully assessing the areas of Operations, Design. Maintenance, Testing, Quality Assurance, and Corrective Action. Approximately 800 of these hours were actual onsite activities during the weeks of January 8. January 22 and libruary 5,1996. All areas of the NRC Temporary Instruction 2515/118,             !
1 Revision 2, with the exception of actually witnessing surveillance testing-in-progress (none achadelaA) were        I evaluated                                                                                                            i l
1          It is important to note that this SWSOPI Team assessment is only a part of the overall scope undertaken by VCSNS     l j            in their self assessment efforts related to Generic Ietter 89-13. For example, there was an independent review of I
station activities related to GL 89-13 Recommended Action Items I and III in December 1989, an ISEG Service Water System SSFI in 1988. Open C3cle Cooling Systems Evaluation Team (OCCSET) review, and the internal

Attachment IV to Document Control Desk letter                                                           Page 10 of 14 RC-97-0031 preparations and reviews for this team assessment have been ongoing since mid-September 1995. The conclusions of this assessment reflect the comprehensive actions of VCSNS.
During the assessment, a total of seventy-four (74) Information Requests. Questions, and Concerns were issued. A concern is issued when the response to an information request or question does not completely resolve the evaluator's question or a significant technical issue is identified. There were twenty-six (26) such concerns issued as part of this evaluation. At the time of the exit on February 9.1996 nine (9) Concerns were closed. requiring no further actions. Proposed actions addressing the remaining seventeen (17) concerns were ao:epted by the assessment team. Five (5) issues sequired evaluation via tbr aff Normal Occurrence (now the CER) process.
Overall, there are no outstanding operability concerus, no NCNs were issued, and the complete scope of NRC TI 2515/118, Revision 2 was completed consistent with regulatory guidelines.
SWSOPI Results:
The Service Water System meets it's thermal / hydraulic performance requirements. The assessment team identified a concern with the current heat exchanger thermal performance testing program in that it establishes a new maximum SW inlet temperature per heat exchanger based on fouling factor. The establishment of a new maximum SW inlet temperature based on GL 89-13 and Supplement I was recorded and mmitared by the System Engineer. ONO 96-26 was written during the Assessment to formalize notification of Operatims regarding any temporary restrictions related to SW inlet temperature Technical Specifications (TS).                                 l The design changes reviewed adequately maintain the design basis and drawings reflect the as-constructed cmfiguration. A comprehensive single failure analyses had been performed that indicated no credible commnent          l failures would prevent the SW System from performing its design function, however it is recommended that Als analysis be expanded cmsistent with GL 89-13. Supplement I to include the applicable closed cooling loops and supporting systems.
Setpoints are controlled through the design change process. Reactor Protection and Engineered Safety Features setpoints, their bases, and development methodology (including inaccuracies and uncertainties) are documented in a Design Basis Document. Ilowever, the bases, methodology (including inaccuracies and uncertainties), and suppcrting calculations for the balance of plant instrument setpoints are not similarly documented in all cases.
Normal operating procedures assure SW System operatim within the design envelope. Maintenance history for the SW System indicates components have been very reliable. Overall material cmdition is impressive. Biofouling and corrosion monitoring programs are comprehensive and well coordinated. An area for improvement however is the level of documentation ofinspection results and completed maintenance activities. Better documentation could provide the basis for extending cleaning, inspection, and testing intervals.
Pump and valve surveillance and testing progrr ns established for the SW System are thorough and continue to demonstrate the SW System will operate as designed.
Completed actions taken in response to Generic Letter 89-13 were found acceptable. It is recommended that a comprehensive GL 89-13 Program document be developed to capture the appropriate information and programs being utilized by VCSNS to satisfy GL 89-13. The generic letter requires a long term program of monitoring, treatment, and testing. By compiling all the VCSNS commitments, procedures, etc. in one program document, the basis for the actions necessary to ensure long tenn compliance to the GL 89-13 requirements will be maintamed

Attachment IV to Document Control Desk Letter                                                       Page 11 of 14 RC-97-0031 i
l Vertical Slice Review: Safety System Functional Inspections

==Purpose:==
; To assess the operational readiness of a system (i.e., determine if the system is capable of performing its design i basis function), and to identify and correct the causes of potential deficiencies.
{
Scope:
Safety System Functional Inspections (SSF1s) are performed on Nuclear Safety Related systems and systems which are important to safety. Since 1987 ISEG has performed an SSFI on each of the following systems:
* Emergency Feedwater
* Emergency Power
* Service Water
* Emergency DieselGenerator
* Component Cooling Water                                                                                   !
* ResidualIIcat Removal l
* AirIIandling                                                                                              l
* Chemical and Volume Control / Safety Injection
* Reactor Coolant
* Containment
* Fire Service Program

== Description:==

l l
SSFIs at the VCSNS are performed utilizing the guidance provided in QSP-600, " Independent Safety Engineering Group" and NSAC-121. " Guidelines for Performing Safety System Functional Inspections."
l An SSFI is generally a vertical slice review of a plant system that includes the areas of: System Design Design    '
Change, Operations, Surveillance Testing, Maintenance, Training, and Quality Assurance. The purpose of each of these major categories is provided below:
System Design: The purpose of the system design phase of the SSFIis to determine if the design basis is adequate, the existing configuration complies with the design requirements and the documentation which describes the design basis is consistent.
Design Change: The objective of the system design change review is to determme if changes made to the system design as a result of a planned modification, upgrade, or non-conforming condition have impacted the system in a manner that adversely impacts the ability of the system to perform its design related function.
Operations: The purpme of this section is to verify that procedures are technically adequate to ensure satisfactory performance of the system and to ensure that they provide proper guidance to allow operators to efectively operate the system. An additional purpose is to identify any problems with the system as perceived by Operations personnel.
Surveillance Testing: The purpose of this phase of the SSFI is to determine if the periodic surveillance tests performed on the system are adequate to verify that the system is capable of performing its safety-related function as defined in the design basis.

Attachment IV to Document Control Desk letter                                                          Page 12 of 14 RC-97-0031 Maintenance: The primary objective of the Maintenance section is to determine if maintenance performed on the system is adequate to assure that the system would perform its safety-related function.
Training: The purpose of this phase of the inspection is to determme if plant personnel are trained adequately in the operations and maintenance of the safety-related system under review.
Quality Amurance: The primary objective of this review is to evaluate the effectiveness of the quality assurance program for the safety-related system under revic w.
Completed ISEG assessments are internally reviewed by the by the ISEG Team, and Manager, Quality Systems prior to issuing the final report. The final report is then issued and reviewed by the affected station mangers to address and implement, as required, the identified issues. Identified issues and recommendations are forwarded to the affected group (s) Manager for review, agreement, and corrective action implementation.
ISEG SSFI Findines:
The following are examples of the type of issues generated from performance of an SSFI, listed below is an example of a design basis and configuration issues made from each of the eleven SSFIs performed:
: 1. Component Cooling Water essential drawings and the Design Basis Document disagreed on the classification of two valves as containment isolation valves. The Design Basis Document was revised in October,1989, to correctly list the valves as non-containment isolation components.
: 2. Status lights on the main control board indicated an RHR valve open at 10%, whereas the FSAR and Reg. Guide 1.97 require valves to be open 90% prior to providing open indication. As a result of ISEG's comment. Design Engineering conducted an evaluation and identified six additional valves which exhibited the same behavior. A plant modification (MRF 33475) was completed in October, 1991, adequately addressing the issue.
: 3. A review of design basis documentation identified discrepancies between FSAR Table 6.2-54,
               " Isolation Valve Summary," and plant essential drawings and as-built configurations. To address these concerns, the FSAR was revised in 1993.
: 4. During implementatics of the Fire Detection and Alarm System Modification, essential drawings were not revised to reflect the in-process changes. A major modification change notice (MCN 20951E) was written in December,1996, to incorporate the essential drawing revisions.
ISEG SSFI Results:
Maintenance of the VCSNS Plant Design Basis has been enhanced by ISEG's reviews. Design discrepancies have been identified and resolved. However, no design deficiencies have been identified that could have actually prevented a system fmm performing its design function in its intended manner.
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l Attachment IV to Document Control Desk letter                                                                  Page 13 of 14 RC-97-0031 FSAR Review

==Purpose:==
1,   Provide a Refuel 9 (Spring 1996) outage review to investigate key outage related topics in the FSAR to identify and resolve issues which cmid impact the refueling outage.
: 2. To perform a MMification Request Form (MRF, now called ECR) review of Refuel 9 outage and other open modifications forFSAR impact.
: 3. To conduct an overall FSAR Review to assess, correct a .d improve the VCSNS FSAR.
Scope:
The Outage Review focused on key outage related topics defined in the FSAR.
The review of modifications included the identification and incorporation of FSAR changes for work that has been field canpleted, including recognitim of the FSAR sectims that would require revision after implemectatiot. The review included modifications that were field complete, yts still open (not all relevant documentation as-built) and          .
or ' age MRFs, including power uprate, scheduled for implementation during Refuel 9.
The Overall FSAR Review is an ongoing, systematic and priuritized assessment focusing m discrete systems and programs which correlate with Design Basis Documents (DBDs) and plant programs. The approach includes a comprehensive assessment to assure consis'ency between .he FSAR, DBDs, and other conuolled documents, including a focused review of those aspects of the FSAR pertinent to safe operation for accuracy and casistency.
Program

== Description:==

Outaae Revieuc i
An Outage Review Aan provided gui.fclines for investigaticr et thu following 10 high level subject areas-Spent FuelHandling                                     Reactivity Instrnmentation & Cmtrois                              Inventory Outage MPF50.59 Evaluations                            Outage Planning                                              ,
PowerUprare 50.59Evaluatims                            Catamment Catainment Tendm Testing                               DecayIIcat Thew areas were then broken into 265 concepts, called " items". An item is defined as a significant aspect of the FSAR which may be affered by plant operations. Typical examples include:
restnctions on reactivity conditims in mode 6 reactor shut down time prior to moving fuel
'           +    cooling down on naturalcirculatior Each item was characterized in terms d discussions ir. the FSAR, Techmcal Specifications, promdures, programs, or hardware, etc. Each of these asrects were evaluated fcr acaracy and for consistency between various documents. Any discrepancies were noted in a request form, and tne dispositiming organization generated Armnent changes, as nanestery No findings were identified during this review that invo8ved safety significant concerns.
l l MRF Review:
M "MRF vs. FSAR Assessment Flan" was developed to provide a review orocess that focused on an independent cunpanson d the mndi6e=& o the    t FSAR, verifying consistency and acx:urac I

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i l            The major steps in the MRF Review process included:                                                                     1
.                  1. Considering the subject d the MRF and identification of applicable FSAR/FPER sections that could potentially catain cammitments or sequire revision.
[
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: 2. Reviewing the selected sections d the FSAR including figures and tables, for cammitments and                  j cafiguratim data.                                                                                              I
:                                                                                                                                    i j                  3. Comparing the MRF package to the FSAR sections for the items below:
1
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* Did the MRF incorporate or consider the applicable FS AR cammitments?                                    !
Does the MRF package list the FSAR sectims, figures, and tables that will require revision afte           !
)                           implementatim as " Design Documents Affected" and does the 10CFR50.59 screening review / safety .        l
!                           evaluation reference the applicable sections for reference?                                              1
;                           If an FSAR/FPER Change Notice has been prepa ed for the MRF,is it c 7plete?                              l 4                                                                                                                                    !
!;           Actim items were identified to an appropriate dispositioning group to assess and support generation of document          '
changes, as necessary. No Sadings were identi6ed dermg this review that inwdved safety significant concerns.
l
!            Overall FSAR Review-t.
.            An Overall FSAR Review Plan was developed to prende a method dcrmmently connparing the FSAR against the DBD,
!            Techniem! Speedications, plant procedures, etc., notmg correlatim for each aspect of the FSAR. Other catrolled l            dmm. sits, particularly in cases where the DBD does not provide affrmit informatica, are used on a case by case basis
,            to corroborate the FSAR. Regulatory drnments (e.g., Taranical S,r=rificarianc) serve as higher level <krnments for assessing the accuracy of the PSAR. Discrepancies betwee the FSAR and any other document (s) leads to further
;            investigation and resolution d the douwy.
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[            Currently. 6 systems have been reviewed using the above approach. To date,3 CERs have been generated. The following is a summary of those issues
* FSAR sevision process (S AP-1163): information missing from a previous revision.
* Spent Fuel system for RWST level instrumentation did not specifically include instrument error .
* FSAR Chapter 15 fyures were missing from a previous revision.
No safety significant concerns have been identified a date.
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Attachment V to Document Control Desk Ixtier                                                               Page1ofI l     RC-97-0031 Information Request (e)
The overall effectiveness of your current process and progrann in concluding that the configuration of your plant (s) is consistent with the design basis.
SCE&G Management has ennrulace that the existing processes at VCSNS prwide reasmable assurance that the plant configuratim is cmsistent with the design bases and that the plant is fully capable of fulfilling its safety function. The primary reasons for reaching this emclusion are:
Our current processes catain strict administrative cmtrols and multi-level reviews to identify and correct errors and ensure Regulatory compliance. Our processes require multi-discipline participation which prwides reasonable assurance that impacts to affected procedures, programs, and trairing are identified and considered in the change process.
l A significant number of internal and external audits and self assessments (including " vertical slice" reviews) have been performed since the plant began operation.
i SCE&G has performed a large amount of design basis review / reconstitution. Some examples are:
* Design Basis Document Program
* Equipment Qualificatim Assessment
* IPEEE j
* Service Water System Operational Performance Inspection
;
* Electrical Distribution System Functional Inspection l
* Steam Generator Replacement
* Low Pressure Turbine Rotor Replacement
* Plant Uprate
'                   =   FSAR Review Our corrective actim processes prwide a comprehensive mechanism for identifying the cause of the problem j         and dealing with the problem in a time frame consistent with its safety significance.
1 Our design control, configuration management, and corrective action processes are a product of cmtinuous
,         imprwement. We have performed Re-engineering of our Design Control and Appendix R processes. Our 4
corrective action process has continually " lowered the threshold" for reportmg of plant problems which have the potential to adversely affect the quality or reliability of the plant. We have had our programs assessed to ensure we are remammg on a success path.
The mu; any management fosters identification of problems by routinely promoting a questioning attitude.
Progrr.ra such as the current S T-A-R program are indicative of this attitude. This philosophy promotes self-identification and carection of problems disc:wcred in the plant procedures and programs, independent of planned self-assessment activities.
SCE&G has exercised diligence throughout the life of the plant to keep design      m ' famation current. Our programs are the result of continuous imprwement and will continue to imprwe in the future. As problems occur, we are committed to using good engineering practices to assess and solve them, including expanding the solution to programmatic means when necessary. Periodic trips are made to the NRC for information exchange. Active participation in industry groups such as NEI, various utility groups, Westinghouse Owners Group, INPO, munerous peer visits, and rewiew ofindustry Operating Experience aid in VCSNS benchmarking activities.}}