ML20244B031
| ML20244B031 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 03/30/1989 |
| From: | Bradham O SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8904180330 | |
| Download: ML20244B031 (11) | |
Text
3 10CFR2.201 3..
th Carolina Electric & Gas Company -
me B adham enkin y le SC 29065 Nuclear Operations l
SCE&G
' March 30, 1989 i
i Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC-20555
Subject:
Virgil C. Summer Nuclear Station Docket No. 50/395 Operating License No. NPF-12
)
Response to Notice of Violations NRC Inspection Report 88-026 Gentlemen:
This letter is the South Carolina Electric & Gas Company (SCE&G) response to
' the Notice of Violations (N0V) dated February 27, 1989.
See Attachments I, II and III.
In a telephone conference call with Mr. Floyd S. Cantrell, NRC Region II l
Project,Section Chief 18, on March 29, 1989, the violation response deadline was extended from March 29, 1989-to April 4,1989.
This extension allowed sufficient time to provide an adequate response.
If you should have any questions, please advise.
Very truly yours, O. S. Bradham HID/OSB: led Attachments c:
D. A. Nauman/0. W. Dixon, Jr./T. C. Nichols, Jr.
E. C. Roberts W. A. Williams, Jr.
G. O. Percival General Managers R. L. Prevatte l
S. D. Ebneter J. B. Knotts, Jr.
C. A. Price /R. M. Campbell, Jr.
NSRC R. 8. Clary RTS (IE 88026 & 89001)
J. R. Proper.
NPCF K. E. Nodland File (815.01) l J. C. Snelson 1
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a 8904180330'890330' PDR. ADOCK 05000395 G.
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- Attachment I to Document Control Desk Letter March 30, 1989 Page-1 of 2 ATTACHMENT I RESPONSE TO NOTICE OF VIOLATION VIOLATION NUMBER 50-395/88-26-01 PART 1 I.
ADMISSION OR DENIAL OF THE VIOLATION South Carolina Electric & Gas (SCE&G) is in agreement with the alleged violation.
4 II.
REASON FOR THE VIOLATION The Maintenance Planner did not obtain the transient combustible
- o permit as required by procedure.
III.-
CORRECTIVE STEPS TAKEN AND RESULTS The error was corrected at the time of discovery.
IV.
CORRECTIVE ACTIONS TAKEN TO AVOID FURTHER VIOLATIONS Maintenance personnel were instructed / reminded of the procedural requirements.
The maintenance work request program.and the preventative maintenance and surveillance programs will be reviewed to determine if additional programmatic controls are needed for transient combustibles.
This review will be completed by May 15, 1989.
V.
DATE OF FULL COMPLIANCE September 30, 1989 l
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Attachment I to Document Control Desk Letter L
March 30, 1989 Page 2 of 2 ATTACHMENT I RESPONSE TO NOTICE OF VIOLATION VIOLATION NUMBER 50-395/88-26-01 PART 2 i
I.
ADMISSION OR DENIAL OF THE VIOLATION
-South Carolina Electric & Gas (SCE&G) is in agreement with the alleged violation.
II.
REASON FOR THE VIOLATION SCE&G failed to comply with the intent of Technical Specification 6.8.1.a.
III.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED The procedure was reviewed and replaced within fifteen days (2 weeks beyond the 2 year period).
IV.
CORRECTIVE ACTIONS TAKEN TO AVOID FURTHER VIOLATIONS SCE&G. will ensure that procedures critical to plant operation will be exempt from the " hold" provisions of SAP-139.
Every effort will be made to ensure the two year. requirements are met for all applicable procedures.
V.
DATE OF FULL COMPLIANCE SAP-139 will be changed by July 1, 1989.
i i
Attachment II to Document Control Desk Letter March 30, 1989 i
Page 1 of 2 ATTACHMENT II RESPONSE TO NOTICE OF VIOLATION VIOLATION NUMBER 50-395/88-26-02 1.
ADMISSION OR DENIAL OF THE VIOLATION South Carolina Electric & Gas (SCE&G) is in agreement with the alleged violation.
II.
REASON FOR THE VIOLATION The failure to properly evaluate and notify the NRC of changes made to the facility as described in the FSAR was a result of the improper application of an administrative procedure.
A plant modification should have beer gnerated which would have initiated the appropriate actions to evaluate, revise and notify the NRC of this change.
Due to the repeated spurious operations of deluge valves resulting in inadvertent soaking of charcoal absorber, SCE&G decided to isolate the deluge system and allow manual initiation when required.
This was documented through the plant caution tag program.
Ten fire service isolation valves were affected.
Five (5) of the valves were to non-tech. spec. fire suppression deluge systems protecting non-nuclear safety charcoal filter plenums.
The position of these valves was changed from open as described in the FSAR to closed without a safety evaluation.
The remaining five (5) valves were to tech. spec. fire suppression deluge systems protecting safety related charcoal filter plenums.
The position of these valves was also changed from open, as described in the FSAR, to closed.
This change was documented in a tech, spec. interpretation and an associated safety evaluation.
This safety evaluation adequately justified the reasons for this change not being an unreviewed safety question.
However, changes to the FSAR and operational procedures were not initiated since the valves were considered to be controlled under the tagging procedure.
III.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED Subsequent to the closure of the ten (10) valves, SCE&G initiated a modification package to revise the plant drawings, procedures and the FSAR in order to remove the valves from the tagging log.
At the time of the NRC audit, SCE&G had revised the plant drawings, issued an FSAR Change Notice and was in the process of revising the plant procedures.
The Nf3 audit team noted that the modification package failed to identify the need for revision to the control room annunciator response procedure.
The final as-built plant drawing was issued on January 11, 1989 and operational procedures were revised as of January 27, 1989.
The caution tags were cleared following the above drawing and procedure revisions.
Notification of the NRC will be made in the next annual report in accordance with the provisions of 10CFR50.4 and 50.59 (b)(2).
iAttachment II,to Document Control Desk Letter.
March 30, 1989
- Page 2 of 2 l
IV.
CORRECTIVE ACTIONS TAKEN TO AVOID FURTHER VIOLATIONS Station Administrative Procedure 202,
" Caution Tagging," will be revised as follows:
1.
To alert the operations auditor of the' caution tag program to determine the need to initiate design changes per the modification (MRF) program for permanent. repositioning of i
equipment that deviates from the FSAR.
I 2.
To evaluate the need to revise ' plant procedures as a result of the installation of the caution tag.
V.
DATE OF FULL COMPLIANCE June 30, 1989 i
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AttachmentIIItoDocumentControlDesEletter March 30, 1989 1
Page 1 of 6 ATTACHMENT III.
RESPONSE TO NOTICE OF VIOLATION VIOLATION NUMBER 50-395/88-26-03 and 89-01 PART 1A 1.
ADMISSION OR DENIAL 0F THE VIOLATION South Carolina Electric & Gas (SCE&G) is in agreement with the alleged-violation.
II.
REASON FOR THE VIOLATION Inadequate indoctrination of Document personnel with respect to drawing legibility requirements, i
III.
CORRECTIVE STJPS TAKEN AND RESULTS ACHIEVED A.
The twenty-nine (29) drawings which contained illegible data have been replaced with fully legible drawings.
B.
A change to.the drawing control procedure, DCP-103 was issued on 3/7/89 to programmatically address action to be taken when illegible drawings are received'or discovered in use.
C.
The requirements of drawing controlled distribution, especially legibility, have been emphasized to Document unit. personnel.
D.
A complete review of all drawings in the Control Room was conducted on 1/20/89 and all illegible drawings that were identified have been replaced.
Two additional reviews have been made to ensure quality is maintained, the last being on 3/13/89.
The Control Room drawings with illegible data have been identified and resolved except for forty six (46) 304 series drawings and five (5) IMS series drawings all of which have been
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identified to Design Engineering for disposition.
It should be noted that these 304 and 1MS drawings are "non-essential".
IV.
CORRECTIVE ACTIONS TAKEN TO AVOID FURTHER VIOLATIONS A.
Document Control Procedure DCP-103 is in revision to provide specific legibility definition.
DCP-103 will also be revised to incorporate the following Design Engineering disposition options upon the identification of illegible essential drawings:
1.
Do not issue, Engineering will have print redrawn.
2.
Do not issue Engineering will have print enhanced.
3.
Quality accepted for intended use, issue.
l
Attachment III to Document Control Desk Letter March 30, 1989-Page 2 of 6
' 4. -
Best available copy, issue drawing.
Quality will be improved in future revisions.
5.
Other.
B.-
The quality upgrade of drawing reproduction is' planned through the purchase of more advanced reproduction equipment.
C.
All. drawings issued to the Control Room will. be initially reviewed by the Document Supervisor until it is evident that all the clerks understand and fully adhere to the legibility requirements.
D.
Documented training.for all Document-Clerks will be on-going to ensure their full understanding of the legibility requirements and the need to maintain high standards.
E.
. The legibility / usability of non-essential drawings is being evaluated and corrective actions and schedule (s) for implementation will be provided by May 15, 1989.
V.
DATE OF FULL COMPLIANCE To be determined and supplied by May 15, 1989.
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JAttachment1III.to Document Control Desk Letter March 30, 1989-Page 3 of,6 7 a
i ATTACHMENT III-RESPONSE TO NOTICE.0F VIOLATION o
VIOLATION NUMBER 50-395/88-26-03 and,89-01 PART 1B I.
ADMISSION OR DENIAL 0F THE VIOLATION.
South Carolina Electric and Gas (SCE&G) is in agreement' with? the alleged. violation.
II.
REASON FOR THE VIOLATION
'A.. Required documentation.was not generated by Engineering. to
-provide direction to the Document Unit.to.effect required drawing-updates in the Control Room.
This caused:=the.following-deficiencies::
six (6) modifications (MRF's) had been canceled,;
but the necessary paperwork had not been issued by Engineering to remove the hold stamps;, three (3) drawings were not affected..by the.MRF's ' indicated on the hold. stamp;.-two (2) in-process drawings had.not been issued as required;-two (2) MRF's had been completed'but the hold _ stamp ~had not been' removed.
B.-
.With respect to a Hold Stamp being placed on Drawing - 0302-011 vice : D302-111 as required, the Document personnel applied ' the--
Hold Stamp in error. This was an isolated case.
.C.
Formal Drawing. Control. training had not been conducted for the Operations personnel.
D.-
The Document Units quarterly review was limited in' scope with respect to MRF' status.
III.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED A.
All drawings in the Control Room have been checked to insure proper holds are in place and correct as-built drawings are on file.
B.
The as-built drawing system in the Control Room has been discussed with Operation supervision and management to assure that personnel understand how the system functions.
C.
Design Engineering has provided documentation to Documents to effect the removal.of incorrect " HOLD" stamps.
The documentation was provided by the responsible personnel.
IV.
CORRECTIVE ACTIONS TAKEN TO AVOID FURTHER VIOLATIONS i
Attachment III'to Document C'atrol Desk Letter
~*
March 30, 1989.
]
Page 4 of 6 A.
The Document Unit will expand the scope of its review to include MRF status. DCP-103 will be revised accordingly.
B.
Drawing Control training will be integrated into operator training 'at the Nuclear Training Cer.ter following revision ~ of Drawing Control procedures.
C..
Design Engineering personnel will be. reminded during procedure-training to 1) place drawings on the in-process stick when an MRF l
is being implemented, and 2) check for multiple MRF's which affect the same drawing (s) when placing drawings on the "as.
built" stick.
The drawing control process will be reviewed with Design Engineering personnel.
l V.
DATE OF FULL COMPLIANCE A.
DCP-103.will.be revised. by May 1, 1989.
The next quarterly review will be completed by June 1, 1989.
i B.
The Nuclear-Training Center training will be scheduled for operations personnel subsequent to issue of DCP-103, and the Design Engineering procedure revisions at the next cycle of training sessions.
1 i
y-Attachment III to Document Control Desk Letter March 30, 1989 Page 5 of 6 ATTACHMENT III RESPONSE TO NOTICE OF VIOLATION VIOLATION NUMBER 50-395/88-26-03 PART 2A 1.
ADMISSION OR DENIAL OF THE VIOLATION South Carolina Electric & Gas (SCE&G) is in agreement with the alleged violation.
II.
REASON FOR THE VIOLATION A number of procedures were revised which involved a change in the word processing system and resulted in numerous typographical errors.
SCE&G personnel failed to perform adequate reviews of the revised procedures.
III.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED Identified discrepancies have been corrected.
IV.
CORRECTIVE ACTIONS TAKEN TO AVOID FURTHER VIOLATIONS Management will reemphasize the necessity of attention to detail with respect to procedure reviews.
This is to include both editorial and technical accuracy.
The conversion of operating procedures to the new word processing system is approximately 75% complete.
The expected completion date for the conversion of all operating procedures is December,1989 with the exception of Hydrostatic System Pressure Test l
Procedures, which will be converted and reviewed prior to their next required performance.
During this time frame the Operations' Procedures Writing Group will be especially sensitive to the potential l
for typographical errors.
Once the conversion is complete it is expected that the number of typographical errors in the procedures revision process will be significantly reduced.
V.
DATE OF FULL COMPLIANCE SCE&G achieved full compliance January 10, 1989.
L'A * * : LAttachment III to Document Control Desk' Letter March 30, 1989-q.
- Page 6 of 6 ATTACHMENT III RESPONSE TO NOTICE.0F VIOLATION VIOLATION NUMBER 50-395/89-01 PART 28 I.
ADMISSION OR DENIAL OF THE VIOLATION South Carolina Electric & Gas (SCE&G) is in agreement with the alleged violation.
II.
REASON FOR THE VIOLATION Procedures were inadequate in that' data such as valves, drawing references, etc., were omitted from the valve line-up sheets and valve positions were incorrect.
III.
- CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVE 0 Identified. discrepancies have been corrected.
IV..
CORRECTIVE ACTIONS TAKFN TO AVOID FURTHER VIOLATIONS All safety related valve line-up sheets will be ~ reviewed _(system walk down included) for accuracy.
V.
DATE OF FULL COMPLIANCE End of refueling outage number five.
NOTE:
Many systems are not accessible during operation
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