ML20072D947

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Responds to NRC Re Violations Noted in IE Insp Rept 50-395/82-57.Corrective Actions:Fire Suppression Water Sys Test Apparatus Mfg on Site & Full Flow Test Satisfactorily Performed
ML20072D947
Person / Time
Site: Summer South Carolina Electric & Gas Company icon.png
Issue date: 02/23/1983
From: Dixon O
SOUTH CAROLINA ELECTRIC & GAS CO.
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20072D933 List:
References
NUDOCS 8303210521
Download: ML20072D947 (2)


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SOUTH CAROLINA ELECTRIC & GASUbMMPiYEG' -?!

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{ g NUCLEAR OpenAfioNS February 23, 1983 Mr. James P. O'Reilly, Director U. S. Nuclear Regulatory Commission Region II, Suite 3100 101 Marietta Street, N. W.

Atlanta, GA 30303

SUBJECT:

Virgil C. Summer Nuclear Station Docket No. 50/395-Operating License No. NPF-12 Notice of Violation NRC Report 82-57

" Fire Suppression Water System"

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 82-57. In order to improve the effectiveness of management control systems, increased management attention to details has been emphasized to all levels in order to achieve the desired results. It is not felt that additional management controls are necessary beyond that stated above and that already addressed under the Corrective Action Section of this Report.

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

Very trul you ,

O. W. D'xon, r.

HCF:OWD:dwf/fjc Attachment-cc: V. C. Summer A. R. Koon T. C. Nichols, Jr. G. D. Moffatt E. C. Roberts Site QA

.O. W. Dixon,-Jr. C. L. Ligon (NSRC)

H. N. Cyrus G. J. Braddick H. T. Babb J. L. Skolds D. A. Nauman J. B. Knotts, Jr.

M. B. Whitaker, Jr. B. A. Bursey W. A. Williams, Jr. I&E (Washington)

O. S. Bradham Document Management Branch R. B. Clary NPCF C. A. Price. File O O G ,

~' 'uo. * '

Mr. James P. O'Reilly NRC Notice.of Violation Page Two February 23, 1983 RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT 82-57 I. ADMISSION OR DENIAL OF THE-ALLEGED VIOLATION South Carolina Electric and Gas Company is in agreement with the stated violation.

II. REASON (S) FOR THE VIOLATION Personnel that were assigned the task of tracking the completion of all surveillances required for entry into Mode 6 had previously been informed that Surveillance Requirements 4 '. 7. 9.1.1. ( d ) and (e) were included in Surveillance Test Procedure (STP) 128.020, " Fire Protection System Refueling Functional Test." On August 6, 1982, the Fire Protection Group realized that the three (3) year flow test identified by Surveillance Requirement 4.7.9.1.1.e was not adequately addressed by SfP-128.020.- However, the Fire Protection Group did not realize that the requirement was a restriction for entry into Mode 6. A new procedure (STP-128.021, " Fire Service Three Year Flow Test") was developed. This STP was not performed due to a lack of test equipment (cap gauge) which had been on order since July 1982.

III. CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED Subsequent to NRC Inspector W. H. Miller's exit interview on November 19, 1982, the test apparatus was manufactured on site, and the full flow test was satisfactorily performed at 1600 hours0.0185 days <br />0.444 hours <br />0.00265 weeks <br />6.088e-4 months <br /> on that same day.

IV. CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION Personnel involved were counseled on the importance of completing the testing required by Technical Specifications and, whenever dates cannot be met, to notify station management immediately. A review was conducted on all fire protection testing requirements to ensure total compliance with Technical Specifications. A revision was made to the surveillance test tracking program to include STP-128.021.

This action serves to prevent recurrences of this type in the future.

V. DATE OF FULL COMPLIANCE The subject STP-128.021 was satisfactorily completed on November 19, 1982. This procedure was incorporated into the surveillance test tracking program on January 14, 1983.

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