ML19332A197

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Forwards Response to Mgt Review Concerns Identified at 800708-10 Meeting w/NRC.Point-by-point Comparison W/ Document Entitled Criteria for Util Mgt & Technical Competence Will Be Submitted at Later Date
ML19332A197
Person / Time
Site: Summer 
Issue date: 09/09/1980
From: Nichols T
SOUTH CAROLINA ELECTRIC & GAS CO.
To: Harold Denton
Office of Nuclear Reactor Regulation
References
NUDOCS 8009110211
Download: ML19332A197 (5)


Text

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s SOUTH CAROLINA ELECTRIC a GAS COMPANY POST OFFICE BO A 764 COLUMBIA,$0UTH CAROLINA 20218 T.C.NicHols,Jn.

September 9, 1980 (Nuclear Operations)

Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Subject:

Virgil C. Summer Nuclear Station Docket No. 50/395 Response to Management Review Concerns

Dear Mr. Denton:

On July 8-10, 1980, the NRC Staff met with South Carolina Electric &

Gas Company management to discuss our qualifications to operate the Virgil C. Summer Nuclear Station. Twelve (12) concerns were identified at the exit meeting. This provides the responses to those items.

In addition to the twelve (12) concerns, SCE&G was requested to perform a formal point by point comparison of our organization with the latest draft of the staff document entitled " Criteria for Utility Management and Technical Competence". This review is in progress. Results will be provided in a later submittal.

t It is our intention to keep NRC Staff abreast of changes within our company as they occur in relation to the guidance provided.

If further information is needed at this time, please advise.

.i Very truly yours,

'Z d A

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T. C. Nichols, Jr.

RBC:TCN:rh cc:

V. C. Summer G. H. Fischer W. A. Williams, Jr.

B. A. Bursey T. C. Nichols, Jr.

E. H. Crews, Jr.

H. T. Babb D. A. Nauman O. S. Bradham O. W. Dixon, Jr.

T. B. Conner R. B. Clary 8009110.2//

NPCF/Whitaker File

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1 ATTACHMENT (1)

The SCE&G Corporate Nuclear Engineering Group should be relocated under the Vice President & Group Executive for Nuclear Operations as a separate line function or combined with the Licensing line function.

RESPONSE

The Corporate Nuclear Engineering Group was relocated under the Vice President & Group Executive for Nuclear Operations as a separate line function effective July 15, 1980

.See Figure 1 for current organizational configuration of functions reporting to the Vice President & Group Executive for Nuclear Operations.

(2)

An SCE&G corporate nuclear traini,ng function should be established under the Vice President & Group Executive for Nuclear Operations.

RESPONSE

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An SCE5G corporate nuclear training function is currently being developed which will report directly to the Vice President & Group Executive for Nuclear Operations. The scope of the duties and responsibilities for this position are currently under study.

It is expected the function will be established within the next 60 days.

(3)

An SCE&G corporate nuclear maintenance function should be established under the Vice President & Group Executive for Nuclear Operations.

RESPONSE

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An SCE&G corporate nuclear maintenance function is curre'tly being n

developed which will report directly to the General Manager for Nuclear Operations. The scope of the duties and responsibilities for this pesition are currently under study. It is expected the function will be established by fuel load, i

(4)

There is no SCE&G corporate involvement in the plant training program.

RESPONSE

SCE&G corporate involvement in the plant training program will be established within the scope of duties and responsibilities of the corporate training position. Refer to response to concern number 2.

4

s (5)

The current and projected size' of the SCE&G engineering organization will likely result in too much reliance on outside assistance.

RESPONSE

The SCE&G engineering organization is being organizationally restructured to address the " Criteria for Utility Management

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and Technical. competence". Upon approval of this new organization by company management a copy of same will be forwarded to the staff for review.

(6)

There is insufficient hands-on operating experience in the SCE&G organization.

RESPONSE

SCE&G is actively seeking to employ the services of personnel with PWR operating experience to provide additional depth to its staff for startup and initial operation of the facility.

For those positions that the company cannot satisfactorily staff prior to fuel load, it will make arrangments-to supple-ment these positions with contractural help.

(7)

The lines of communication in the SCE&G Corporate organization are too informal.

RESPONSE

Formal lines of communications.in the SCE&G corporate organization are being established by developing a corporate procedures manual.

These procedures will implement on a corporate level the guidelines and policies established in the FSAR and the SCE&G Operational Quality Assurance Plan. Theexistingproceduresofeach]SCE&G organization are being revised to interface these corporate procedures.

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(8)

There appears to be no formal review;of plant operating procedures in the SCE&G corporate organization.

RESPONSE

The newly established Independent Safety Engineering Group (ISEG) will review plant operating procedures. This review will supplement the review currently beiag done by Westinghouse. The ISEC is in existance and is currently being staffed. Procedures are being written for the group and they should be able to commence their work within the next 30 days.

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'(9)

The on-site Engineering Evaluation Group should be operating now.

RESPONSE

The on-site Engineering Evaluation Group is currently in the process of being staffed. It should be functionally operational within 30 days.

. This group is the same as the ISEG identified in concern number 8.

(10)

The off-site Review Group should be operating now.

RESPONSE

The charter for the off-site Review Group has been issued and qualified personnel have been assigned to the committee. The first meeting was convened in August. This committee is now considered operational.

(11)

The SCE&G management should take immediate steps to assure that all levels of the plant management understand and are committed to making the Shift Supervisor / Shift Technical Advisor interface function pro-perly. There appears to be a significant potential for a conflict based on the interviews we conducted.

RESPONSE

The SCE&G Vice President & Group Executive of Nuclear Operations has taken a personal interest in this finding. He has visited the plant several times to talk with plant management and affected groups to insure that an adequate interface is accomplished and workable.

1 (12)

There appears to be a lack of administrative procedures to address interfaces between the plant and'the SCE&G corporate office.

RESPONSE

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As described in the response to concern number 7, a corporate procedures manual is currently being written. In this manual, administrative procedures addressing interfaces between the plant and other organizations located off-site at the corporate offices will be included.

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- NUCLEAR OPERATIONS VICE PRESIDENT AND NUCLEAR SAFEU RE IEW GROUP GROUP EXECUTIVE NUCLEAR OPE. RATIONS T. C. Nichols Executive Assistant C. A. Rust 1

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4 General Manager Group Manager Nuclear Engineering Group Manager and Licensing Quality Assurance Nuclear Operations D. A. Nauman H.T.Babb M. B. Whitaker Manager i

Nuclear Engineering C. A.- Price Independent safety Licensing Engineer Engineering Group i

R4 B. Clary

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