ML20081H271

Responds to NRC 830901 Ltr Re Violations Noted in IE Insp Rept 50-395/83-24.Corrective Actions:Auxiliary Bldg Logs Restructured to Eliminate Confusion & Ensure Compliance W/ Tech Spec

ML20081H271
Person / Time
Site:	Summer
Issue date:	09/29/1983
From:	Dixon O SOUTH CAROLINA ELECTRIC & GAS CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20081H242	List: ML20081H271
References
NUDOCS 8311070372
Download: ML20081H271 (6)

Text

• SOUTH CAROLINA ELECTRIC & GAS COMPAK,3 . .,

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CotuusiA SouTM CAROLINA 29218

o. W. DixoN, JR. Oq ,,y vica passios=r UJ Ob I il P2: 35 wComan ormaatio .

September 29, 1983 Mr. James P. O'Reilly Regional Administrator U.S. Nuclear Regulatory Commission Region II, Suite 2900 101 Marietta Street, N.W.

Atlanta, Georgia 30303 SUr ECT: Virgil C. Summer Nuclear Station Docket No. 50/395 Operating License No. NPF-12 Notice of Violation NRC Inspection Report 83-24

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 83-24.

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

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

CJM/0WD/mac Attachment ec: V. C. Summer C. L. Ligon (NSRC)

E. C. Roberts G. J. Braddick E. H. Crews, Jr. J. C. Miller T. C. Nichols, Jr./0. W. Dixon, Jr. J. L. Skolds H. N. Cyrus J. B. Knotts, Jr.

Group Managers I&E (Washington)

O. S. Bradham Document Management R. B. Clary Branch C. A. Price INPO Records Center A. R. Koon NPCF D. A. Lavigne File (Lic./Eng.)

J. F. Heilman 8311070372 831020 PDR ADOCK 05000395 G PDR

Mr. James P. O'Reilly NRC Notice of Violation 83-24 Page 2 September 29, 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 The reason for the violation is attributed to personnel error. The surveillance of the Intermediate Building (IB) 412' elevation is normally included on the Auxiliary Building Checklist, since it is part of the Radiation Control Area (RCA). During the steam generator outage of March 17 through May 20, 1983, the IB 412' elevation was removed from the RCA and another watch station was to assume responsibility for monitoring the area. The associated logs became fragmented and resulted in neither station inspecting the subject doors. The logs were revised by the control room foremen and shift supervisors but thef failed to observe that the doors were not checked.

III. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED The failure to comply with Surveillance Requirement 4.7.10.2.(a) was not dircovered until July 6, 1983. No immediate corrective action was taken since SCE&G was in compliance with the surveillance requirement at the time of the discovery.

IV. ACTION TAKEN TO PREVENT FURTHER VIOLATION i

l The following actions were taken to prevent further violation:

1) The failure to observe the non-compliance during the i

review process is attributed to inattention to detail which has been addressed in a series of lectures completed on May 27, 1983.

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Mr. James P. O'Reilly NRC Notice of Violation 83-24 Page 3 September 29, 1983 APPENDIX A NOTICE OF VIOLATION ITEM A IV. ACTION TAKEN TO PREVENT FURTHER VIOLATION - Continued

2) The Auxiliary Building logs have been restructured to eliminate confusion and insure compliance with Technical Specification Surveillance Requirements.

The new logs were issued on August 1, 1983 V. DATE OF FULL COMPLIANCE South Carolina Electric and Gas Company was in full compliance on August 1, 1983 l

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Mr. James P. O'Reilly NRC Notice of Violation 83-24 Page 4 September 29, 1983 APPENDIX A NOTICE OF VIOLATION ITEM B I. ADMISSION OR DENIAL OF THE ALLEGED VIOLATION South Carolina Electric and Gas Company is in agreement with the alleged violation.

II. REASON (S) FOR THE VIOLATION The reason for the violation is attributed to procedural inadequacy in that Surveillance Requirement 4.6.1.7.2 had not been adequately addressed. The opening and closing times of the valves was being documented on the Control Building logs; however, the cumulative time that the valves had been open during the previous 365 days was not being determined on a weekly basis.

III. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED A review of the Control Building logs was initiated to determine the cumulative time that the valves had been open during the previous 365 days. This review, completed on July 1, 1983, concluded that the 6-inch containment purge supply and exhaust valves had not exceeded the 1,000 hour0 days <br />0 hours <br />0 weeks <br />0 months <br /> criteria of Technical Specification 3.6.1.7.(b).

IV. ACTION TAKEN TO PREVENT FURTHER VIOLATION Surveillance Test Procedure (STP)-720.001, " Mini Purge Valves Time Limitation," has been developed to implement Surveillance Requirement 4.6.1.7.2 on a weekly basis.

This procedure was issued for plant usage on July 1, 1983.

V. DATE OF FULL COMPLIANCE South Carolina Electric and Gas Company was in full compliance on July 1, 1983.

Mr. James P. O'Reilly NRC Notice of Violation 83-24 Page 5 September 29, 1983 APPENDIX A NOTICE OF VIOLATION ITEM C I. ADMISSION OR DENIAL OF THE ALLEGED VIOLATION South Carolina Electric and Gas Company is in agreement with the alleged violation.

II. REASON (S) FOR THE VIOLATION The reason for the violation is attributed to procedural inadequacy in that Surveillance Test Procedure (STP)-115.001, " Penetration Isolation Verification," did not adequately address Surveillance Requirement 4.6.1.1.a of Technical Specification 3.6.1.1, " Containment Integrity." Five (5) valves located outside of the containment and fourteen (14) valves inside the containment were installed in the plant during the construction phase to allow local leak rate testing but were not included in the subject STP.

III. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Immediate corrective action was taken to inspect all outside containment isolation valves, including test valves, to verify that the valves were in the required position. A review was also made of all completed STP data sheets for individual penetrations to verify that all test connections inside the containment had been restored to their required position and independently verified. No discrepancies ware noted.

IV. ACTION TAKEN TO PREVENT FURTHER VIOLATION STP-115.001 was revised to include the omitted valves on August 17, 1983 V. DATE OF FULL COMPLIANCE South Carolina Electric and Gas Company was in full compliance on August 17, 1983.

Mr. James P. O'Reilly NRC Notice of Violation 83-24 Page 6 September 29, 1983 APPENDIX A NOTICE OF VIOLATION ITEM D 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 The reason for the violation is attributed to personnel error. The requirements of Section 6.17 and 6.21 of Station Administrative Procedure (SAP)-147, " Operating Experience Reports," were not fully complied with because of the increased time demand on the Shift Technical Advisors (STA's) during completion of the Phase III test program, concurrent with their participation in the operator licensing program.

III. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED The following corrective actions were taken upon the identification of the noncompliance with Sections 6.17 and 6.21 of SAP-147

1) Monthly reports which have been submitted to the Station Manager since June 1983, were revised to identify closed items in the August report. SCE&G has been in full compliance with Section 6.17 of SAP-147 since August 1983

2) Plant personnel were assigned the responsibility of developing a system to trend in-house operating experience events upon identification of the noncompliance with Section 6.21 of SAP-147 This program will be fully implemented prior to December 1, 1983 IV. ACTION TAKEN TO PREVENT FURTHER VIOLATION The corrective actions identified above are considered sufficient to prevent further violation.

V. DATE OF FULL COMPLIANCE South Carolina Electric and Gas Company will be in full compliance by December 1, 1983

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