ML20082A373

Responds to NRC 831005 Ltr Re Violations Noted in IE Insp Rept 50-395/83-27.Corrective Actions:Revs to Operational QA Plan & Section 17.2.12.2 of FSAR & Engineering Review of Drawing Control Program Initiated

ML20082A373
Person / Time
Site:	Summer
Issue date:	11/04/1983
From:	Dixon O SOUTH CAROLINA ELECTRIC & GAS CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20082A366	List: ML20082A373
References
NUDOCS 8311180127
Download: ML20082A373 (8)

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SOUTH CAROLINA ELECTRIO & GAS COMPANY POST OFFlCE 764 COLuwstA. St3UTH CAROLINA 29218 o.W.Osxon.Jn.

hy j g VICE PRE $iOENT November 4, 1983 sucu o E..,,0 . J ,* 23 Mr. James P. O'Reilly Regional Administrator U.S._ Nuclear Regulatory Commission Region IT., Suite 2900 101 Marietta Street, N.W.

Atlanta, Georgia 30303

SUBJECT:

Virgil C. Summer Nuclear Station Docket No. 50/395 Operating License No. NPF-12 Notice of Violation NRC Inspection Report 83-27

Dear Mr. O'Reilly:

Please find attached South Carolina Electric and Gas Company's response to the Notice of Violation as addressed in Appendix A of NRC Inspection Report 83-27.

If there are any questions, please call us at your convenience.

Very truly yours, O. W. Di on, r.

HID/OWD/mac/fjc Attachment cc: V. C. Summer C. L. Ligon (NSRC)

E. C. Roberts G. J. Braddick E. H. Crews, Jr. D. J. Richards C. Nichols, Jr./O. W. Dixon, Jr. NRC Resident Inspector T.

W. A. Williams, Jr. J. B. Knotts, Jr.

I&E (Washington)

D. A. Nauman Document Management Group Managers O. S. Bradham Branch 4

N. E. Clark INPO Records Center NPCF R. B. Clary File (Lic./Eng.)

C. A. Price A. R. Koon D. A. Lavignne 8311100127 PDR ADOCK 050003g 831109 G

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Mr. James P. O'Reilly NRC Notice of Violation 83-27 Page 1.

November 4, 1983 APPENDIX A NOTICE OF VIOLATION ITEM A I. ADMISSION OR DENIAL OF THE ALLEGED VIOLATION South Carolina Electric and Gas Company (SCE&G) is in agreement with the alleged violation.

II. REASON (S) FOR THE VIOLATION Section 17.2.12.2 of the Final Safety Analysis Report (FSAR) states that subsequent to commercial operation of the Virgil C. Summer Nuclear Station, the Assistant Manager of Maintenance Services will be responsible for the calibration and control of measuring and test equipment (M&TE). The Operational QA Plan; Station Administrative Procedure (SAP)-141, Rev. O, " Control and Calibration of M&TE"; and the individual programs of Quality Control, Health Physics, and Chemistry sections failed to reflect the requirements of the FSAR. The discrepancy between the prograns and the FSAR is attributed to personnel oversight.

The existing M&TE prograns of the Quality Control, Health Physics, and Chemistry sections are acceptable since they meet the criteria of ANSI N18.7 and Regulatory Guide 1.33.

The separation and accountability of the programs were deemed necessary because of the unique nature of the M&TE.

III. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED SCE&G has initiated revisions to the Operational QA Plan and Section 17.2.12.2 of the FSAR. The revisions are designed to reflect the existing plant programs.

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Mr. James P. O'Reilly NRC Notice of Violation 83-27 Page 2~

November 4, 1983 IV. ACTION TAKEN TO PREVENT FURTHER VIOLATION Section 17.2.12.~2 of the FSAR, Operational QA Plan, and SAP-141 will be revised to accurately reflect established programs. This action will be completed by January 1, 1984.

V. DATE OF FULL COMPLIANCE SCE&G will be in full compliance by January 1, 1984.

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• i- Mr.' James P. O'Reilly NRC Notice of Violation 83-27 Page 3 November 4,-1983 APPENDIX.A NOTICE OF VIOLATION

_ ITEM,B I. ADMISSION OR DENIAL OF THE ALLEGED VIOLATION f' South Carolina. Electric and Gas Company (SCE&G) is in agreement with the alleged violation.

t l II. REASON (S) FOR THE VIOLATION a) Procedures A-NQCP-9, " Equipment Control," and CHP-501,

" Calibration and Standardization Requirements," did

, not procedurally require a listing of measuring and test equipment (M&TE), and measures for documenting I- which Safety-Related tests were performed with this 4

equipment. The cause of the procedure inadequacies is t

attributed to personnel error in that the Operational t QA Plan was not adequately. reviewed by the personnel responsible for development / review of the procedures.

b) 'The method presently used to indicate that a drawing has a revision pending is to place a " Hold" on the

drawing. The " Hold" references the modification which af fected the . document and was considered to be adequate identification prior to the issuance of the violation. SCE&G agrees that the program should be revised to clearly delineate changes on essential drawings utilized by plant personnel.

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. III. CORRECTIVB-ACTION TAKEN AND RESULTS ACHIEVED a) The respective organizations are evaluating Procedures A-NQCP-9 and CHP-501, and revisions will be made.to insure compatability with Section 10.3.1 of the

Operational QA' Plan.

b) An engineering review of the drawing control program l was initiated upon identification of the violation.

Actions and-time schedule for completion of items are

! addressed in Section IV of this response.

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Mr.~ James P. O'Reilly NRC Notice of Violation 83-27

'Page 4 November-4, 1983 IV. ACTION TAKEN TO PREVENT FURTHER VIOLATION a) Quality Control and Chemistry. sections will establish, in procedures A-NQCP-9 and CHP-501, a list of M&TE to be controlled, and measures for documenting which Safety-Related tests were performed with the M&TE. The procedure revisions will be completed by December 1, 1983.

b) The following actions will be taken to improve the drawing control program:

1. A list of drawings affected by existing

! modification packages will be developed and priorities for revision assigned by November 15, 1983. Drawings which are considered important for control and operation of the

Plant are the following series: 108 (Logic),

208 (Elementary), 302 (Piping and Instrumentation) , and 912 (HVAC) drawings.

i Any drawings identified as requiring revision that are in these series will be worked on a priority basis. Expected completion date for revision and' issue of these drawings is March  ;

1,'1984. The remaining. drawings will also 4

be worked on a priority basis. A Task Engineer has been assigned to expedite revision and issuancelof these drawings.

2. SCE&G will egrablish additional procedural

!, controls by January 1, 1984. The changes

will require that if the' drawings = identified in paragraph tV.b.1 are included in the modification, an interim copy of this drawing will be provided with the modification package. The interim drawing will lue a L'

complete copy of the drawing showing the modification, and which can replace the original file copy of the drawing when the 4 modification is complete.

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Mr.-James P. O'Reilly NRC Notice-of Violation 83-27 Page 5

-November 4, 1983

- IV. ACTION TAKEN TO PREVENT FURTHER VIOLATION - Continued The remaining drawings will continue to be controlled with the existing " Hold" procedure. These drawings will be marked

" Hold" and the modification package number '

identified. The modification package will describe the changes being made. Upon completion of the modification, the drawings will be revised with the revision block identifying the modification number.

The revised permanent drawings will then be issued to controlled distribution to replace the copies marked " Hold". Final revision of these drawings will be worked -

on a priority basis and.will be. tracked and expedited by an assigned Task Engineer.

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V. DATE OF FULL COMPLIANCE SCE&G will be in full compliance by March 1, 1984.

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Mr. James P. O'Reilly NRC Notice of Violation 83-27 Page 6 November 4, 1983 APPENDIX A NOTICE OF VIOLATION ITEM C I. ' ADMISSION OR DENIAL OF THE ALLEGED VIOLATION South Carolina Electric and Gas Company (SCE&G) is in agreement with the alleged violation.

II. REASON (S) FOR THE VIOLATION Operators in the Control Room have been utilizing "For Information Only" drawings in violation of the requirements of Plant Document Procedure (PDP)-102,

" Drawing Control." The drawings are smaller and easier to use than the controlled set and as such they were utilized by operations personnel.

Currently, the controlled drawings, while reflecting a

" Hold" to indicato a change, do not reflect which area of the drawing has changed without additional research into records.

III. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Operators were instructed on September 2,198 3, and again on October 17, 1983, not to use the small "For Information Only" drawings to perform work. The drawings can still be used as a memory aide, provided other documents such as

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approved procedures are used to control actual operator actions. The drawings have not been used by operators in the performance of their work since notification of the violation on September 2, 1983.

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Mr. James P. O'Reilly NRC Notice of Violation 83-27 Page 7 November 4, 1983 IV. ACTION TAKEN TO PREVENT FURTHER VIOLATION The following actions were taken to prevent further violation:

1. Operators were instructed on September 2, 1983, and again on October 17, 1983, not to use the "For Information Only" drawings.

2. A controlled set of small " Flow System Diagrams," which are the most commonly used by operations personnel, were issued on October 31, 1983.

3. The book which contains the "For Information Only" drawings was clearly marked prior to November 4,.1983, to indicate possible out-of-date status of the drawings and that they are not to be utilized for the performance of work related activities.

V. DATE OF FULL COMPLIANCE SCE&G was in full compliance on November 4, 1983.

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