ML20235F641

Notice of Violation from Insp on 870713-24.Violation Noted:Design Inputs for Design Change Packages Mrf 10659, 20801,20995,21215 & 21225 Not Formally Identified,Approved or Presented in Detail

ML20235F641
Person / Time
Site:	Summer
Issue date:	09/22/1987
From:	Julian C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20235F629	List: ML20235F626 ML20235F641 ML20235F657
References
50-395-87-20, NUDOCS 8709290255
Download: ML20235F641 (3)

Text

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I ENCLOSURE 1 NOTICE OF VIOLATION South Carolina Electric and Gas Company Docket No. 50-395 Summer License No. NPF-12 During the Nuclear Regulatory Commission (NRC) inspection conducted on )

July 13-24, 1987, violations of NRC requirements were identified. The  !

violations involved inadequate design input and design analysis for design changes, failure to follow and inadequate operating procedures, and inadequate review of previous audit findings for adequacy of corrective action implementation.

Procedure for NRCInEnforcement accordanceActiont,"

with the10" General CFR PartStatement of Policy 2, Appendix C (1986 )and

, the violations are listed below:

A. 10 CFR 50 Appendix B Criterion III, and licensee's accepted Quality Assurance (QA) Program (FSAR Section 17.2) collectively require that measures be established to assure that applicable regulatory requirements are correctly translated into specifications, drawings, procedures and instructions. The licensee is committed to Regulatory Guide 1.64 which endorses ANSI N45.2.11-1974, Quality Assurance Requirements for the Design of Nuclear Power Plants. Section 3.1 of this standard states that applicable design inputs shall be identified, documented, and their selection reviewed and approved and that the design input shall be specified to the level of detail necessary to provide a consistent basis for accomplishing design verification measures.

Contrary to the above, design inputs for design change packages MRF 10659, 20801, 20995, 21215, and 21225 were not formally l identified, specifically approved, nor presented in necessary detail to I provide a consistent basis for design verification measures.

This is a Severity Level IV violation (Supplement I).

B. 1. Technical Specification (TS) 3/4.7.11, Area Temperature Monitoring, l states that the ten's>erature of each area shown in Table 3.7-7 shall s be maintained belou the limits indicated in Table 3.7-7. Item 25 of Table 3.7-7 list 'ne service water pump / screen room temperature limit at 102 F for entering the "A" action statement.

2. 10 CFR 50 Appenoix B Criterion III, and the licensee's accepted QA program collectively required that control measures shall be provided for verifying the adequacy of design. The licensee is committed to Regulatory Guide 1.64 which endorses ANSI N45.2.11 - 1974, Quality Assurance Requirements for the Design of Nuclear Power plants.

Section 4.2 of this standard states that design analyses shall be performed in a correct manner.

8709290255 870922 PDR ADOCK 95000395 PDR G

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.s South . Carolina Electric and Gas Company 2 Docket.No. 50-395 Summer- License No. NPF-12 i

. Contrary to the above, the. licensee did not perform an adequate design analysis for modification MRF 10759-K in that the proposed' locations of the service water: pump / screen room temperature detectors were not measured .to verify that an acceptable reading would be obtained. This led.to the problem that the service water pump room temperature was found to be above 102 F, 'as measured by the inspector and the licensee, on j July 21,1987, with .the licensee not entering the "A" action statement of TS 3/4.7.11.

This is a Severity Level V violation-(Supplement I)

C. 10 CFR 50 Appendix '8 Criteria V, and the accepted QA Program state that activities shall be performed according to procedures and that procedures

'shall include appropriate quantitative criteria.

1. hntrary to the above, activities were not performed according to procedures in that the ' Service Water- System Operating Procedure, 50P 117, Revision 12, list the minimum service water flow to the upper bearing lube oil heat exchanger as.eight gallons per minute and the minimum service water flow to the lower bearing lube oil heat exchanger as four gallons per minute. It was found that flows to the heat exchangers were being maintained at less than the required flows. The discrepancy was 'due to an error in the daily logsheet requirements which did not match the operating procedure requirements.

2. Contrary to the above. Operating Procedure SOP-117 did not list the motor restarting requirements, as listed on the motor data plate, l

in the precautions section or as a caution in the startup section of i

the' procedure.

This is a Severity Level V violation (Supplement I)

D. 10 CFR 50. Appendix 3 Criterion XVIII and tha accepted QA Program collectively require that a comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of.the quality assurance program and to determine the effectiveness of the program. Followup action, including reaudit of deficient areas, shall be taken where indicated. The licensee is committed to Regulatory Guide

-1.144, Auditing of Quality Assurance Programs for Nuclear Power Plants, i Revision 0, which endorses ANSI N45.2.12-1977, Requirements for Auditing ,

of Quality Assurance Programs for Nuclear Power Plants. Section 4.3.2.7 l of this standard requires that specific attention be given to corrective j action on program deficiencies identified during previous audits. l l

Contrary to the above, objective evidence did not exist to assure that adequate attention was given to corrective action program deficiencies identified during previous audits in that:

1. A 1987 audit of Security and Maintenance of Security Equipment (11-10-87-I) did not give adequate attention to corrective action for findings 02, 07, 08, and 09 identified in tne 1986 Security Audit (11-14-86-1). Three of these findings closures were based on procadure revisions, with no evidence of subsequent implementation verification.

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I South Carolina Electric and Gas Company 3 Docket No. 50-395 Summer License No. NPF-12

2. A 1985 Security Audit (II-10-85-I) and the 1986 Security Audit (11-14-86-I) identified repetitive program problems related to control and distribution of security procedures and controller training. The 1987 Security Audit did not identify problems in these areas when in fact, problems continued to exist with procedure control, distribution, and training, as identified by the inspector. These problems resulted from not assuring adequate attention was given to corrective actions for deficiencies identified in the 1985 and 1986 Security Audits.

This is a Severity Level V violation (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, South Carolina Electric and Gas Company is hereby required to submit to this Office within 30 days of the date of the letter transmitting this Notice a written statement or explanation in reply including for each violation: (1) admission or denial of the violation, (2) the reason for the violation if admitted, (3) the corrective steps which have been taken and the results achieved, (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved Where good cause is shown, consideration will be given to extending the response time.

FOR THE NUCLEAR REGULATORY COMMISSION h6 -

% 7 Caudie A. Julian, Chief Operations Branch Division of Reactor Safety Dated at Atlanta, Georgia this 22ndlay of September 1987

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