ML19352A187
| ML19352A187 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 03/04/1981 |
| From: | Nichols T SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8103110653 | |
| Download: ML19352A187 (6) | |
Text
-
.c SOUTH CAROLINA ELECTRIC a GAS COMPANY b,
- /
\\cc
,os t o,,,c c.ox...
cotumeu, soum CAROL %A 29218
,s
,/
T. C. NicHo Ls, J n.
S' f
N $ ;g8
"" ",*7,' l,L**"l,"*"'
March 4,1981 5f Q
[
~t
& ('* Eu k!!
Mr. Ilarold R. Denton, Director Office of Nuclear Reactor Regulation 4
fg U. S. Nuclear Regulatory Commission g
Washington, D. C.
20355
Subject:
Virgil C. Summer Nuclear Station 1
Docket No. 50/395 Response to NRC NRR/I&E Management Audit
Dear Mr. Denton:
In response to comments received during the exit interview of the joint NRR/I&E Management Audit which was conducted, as part of the Staff's normal review process for an operating license on February 's-11, 1981, South Carolina Electric & Gas Company (SCE&G), acting for itself and as agent for the South Carolina Public Service Authority (SCPSA),
herewith provides the following responses to issues identified during the visit:
1.
. Appropriate action will be taken to insure that the Operations Quality Assurance Plan is c1carly understood by personnel engaged in activities governed by.10CFR50, Appendix B.
2.
Briefing sessions will be' held with the Plant and Corporate Engineering staffs to communicate and discuss with them their respective roles as delineated in the Management Directives for Nuclear Operations.
Emphasis will be placed on the establishment of a balanced perspective j
for the engineering team's vital role for safe and reliable operation of
. the nuclear plant. This will be accomplished by:
a)
Cross-training of our engineers through work experience to be obtained by rotating these personnel between the plant and Corporate Headquarters for fixed periods of time; b)
Establishment of training programs designed to broaden their technical knowledge and understanding of nuclear power plant systems, and the dynamics' of operational considerations;
.c) _
Plant and Corporate engineers participating in joint assignments and supervision of engineering projects.
.3..
Establish a formal training program for Corporate Headquariers and Plant personnel engaged in management or techniesi support of the nuclear plant. Some of the major features and provisions c
Q'p
- [c ;810s11o(,53 q)
+
7 Mr. Harold-R. Denton Page Two - March 4,1981 of this program are enurcerated below:
a)
Each Group / General Manager, as directed by the earlier mentioned " Management Directives," will, with Corporate Staff assistance, develop or improve the existing training program for their respective groups, b)
Training records will be maintained for employees involved in the training program.
c)
A position or person will be designated as responsible for the maintenance of training records under each Group / General Manager.
d)' A Corporate Staff position reporting directly to the VPGE/NO will provide overall guidance to the Group / General Managers' training programs. The person asMped to this position will remain cognizant of training schedules, programs and their effects. The Corporate Staff position will also assist the Group / General Managers in identifying suitable training programs that are available within the marketplace.
He will also provide an independent overview function for the VPGE/NO by assessing the adequacy of training within each major functional area.
While the formal training program is being developed, the
. Company will continue to upgrade the training for its personnel, making use of industry training programs conducted by Westinghouse, INPO and other qualified bstitutions. Overall effectiveness of the training program will be monitored by the Nuclear Safety Revkw Committee and the Corporate Staff Assistant specifict. 1ssigned to the training overview function.
4.
Establishment of Conuactual Relationships The Company is currently negotiating with Westinghouse Electric Corporation for on-going NSSS engineering support to supplement SCE&G's Corporate and Plant engineering-staffs.
Specifically, Westinghouse would identify specific experienced individuals, in.different disciplines, who are familiar with the Summer plant.- These identified individuals would devote at least two man-months per year to keeping current with the project.
- These individuals would be intimately involved with the review and corrective.; actions takca for plant problems, review of plant engineering changes, review of safety items and sharing of industry experience.. They will also provide a Rapid Response Design Service on an."as-needed"- basis.
. ^
~
w.
1}
Mr. !!arold R. Denton Page Three - March 4,1981 During an emergency condition, this Westinghouse Engineering Support team would report promptly to the Westinghouse Emergency Response center. As more people become available, the Engineering Support Team could be flown to the Summer Site.
The Company is also negotiating with Gilbert Associates for Balance of Plant (BOP) engineering services on a continuing basis.
Gilbert will provide engineering support services categorized by discipline. They will have personnel assigned to the project on a-full or part-time basis who will be available for assignment in response to an emergency situation.
The identification of the Westinghouse Engineering Support Team and the collation of individuals and disciplines for the Gilbert support' service contract are aimed at supplementing SCE&G's Corporate and Plant engineering staffs to provide a level of expertise and competence of technical skills adequate to address the suggested
- guidelines for technical support enumerated in NUREG-0731, to assist in providing the plant with adequatc maintenance services.
The Company plans to contract for Operational Maintenance Support with an experienced engineering. firm and obtain support from Westinghouse in a managed maintenance program. The Company will also ' seek professional assistance in refueling and other specialized activities.
5.
SCE&G will continue-to recruit professionally qualified and experienced personnel suggested in h' REG 0731, " Guidelines for Utility Management: Structure and Technical Resources," and to bring our Corporate and Plant Staffs up'to_ authorized strength.
6.
The. Company will periodically evaluate work activities of our in-house engineering groups.to insure that they are adequately staffed'and. qualified to support plant operations. This evaluation will consider, among other things, the time expended by our
~
engineers'in the performance of duties to ensure that hours worked are not. unreasonable or burdensome.-
- 7.
1The Company is presently negotiating for PWR experienced 9RO personnel _to serve, in an advisory capacity, in the plant's control room. : These personnel.will provide our operating staff additional
" hands-on" 'Large Commercial Reactor experience. At this time, we are negotiating-with a _' personnel contractor to' continue with
- SRO personnel currently. assigned to our Plant Operating Staff.
These individuals would: continue to serve in the control room during
? the^ plant's ~ initial operating phase. These contract SRO's, or other
- qualified SRO's
- would be retained in this advisory capacity.'at least until~ full power operation is-achieved.
'1}
?
L>
N Mr. liarold R. Denton Page Four - Blarch 4,1981 8.
SCE&G will continue to retain the consulting services of Frank L. Kelly, President of Personnel Qualification Services, Inc. (PQS) to evaluate and advise our operations training staff of ways to improve and strengthen its training programs.
Additionally, the Company plans to retain the services, on a contractual basis, of a representative of Westinghouse Electric Corporation, or come equally qualified individual, who has in-depth simulator training experience, to serve full time on the staff of the Vice President and Group Executive, Nuclear Operations. In this capacity he will, in conjunction with the ISEG, evaluate SCE&G's training programs and make recommendations for improving their effectiveness.
9.
The Company is making every effort to retain the services of contract-SRO personnel presently on site to perform duties as described in Item 7 above. The Company also has agreements with Westinghouse and Gilbert Associates to continue the services of several of the key startup personnel through the power escalation test period. These persons are currently participating in preoperational checkout and startup activities in areas such as reactor and engineering safeguards systems, reactor protective systems and important control systems on the secondary side of the plant.
.10.
- The Company is vigorously recruiting for an engineer with Large Commercial Reactor Nuclear Fuel Management experience to fill an authorized reactor engineer position at the nuclear plant.
If such a qualified candidate is not readily available, we would plan to contract for such an individual to augment the plant staff until the vacancy can be filled by a permanent employee.
To further_ augment our nuclear fuel management experience,
'SCE&G has entered into an agreement with Westinghouse which, among other things, as described in Item 4 above, will provide i
nuclear fuel management support on a long-range basis. The Company has also entered into a one-year agreement with Science Applications, Inc.. (SAI) to train our fuel management personnel in the use of the Advanced Recycle Methodology Program (ARMP) developed ?oy'the Electric Power Research Institute (EPRI). SAI will also assist us-in customizing the ARMP computer program to our specific reactor core.
l
' 11.
. To improve the Company's operating experience at the Senior
. Management level, the Vice President and Group Executive, Nuclear Operations will augment his personal staff with individuals having in-depth and broad nuclear experience. Resumes' of two prospective candidates #or'these positions have been provided to the NRC staff in Bethesda for information.
~
y - wd
Mr. Ilarold - R. Denton Page Five - March 4.1981 These assistants, secured from industry on a contractual basis, will support the VPGE/NO in the following manner:
a)
Advise the Independent Safety Review Group of Methods and techniques that could be employed to evaluate safety related programs and to suggest ways to detect possible safety problems that might not have been identified by the plant; b)
Serve on the Nuclear Safety Review Committee in an advisory capacity to assist the Committee in discharging its duties and responsibilities as described in the Management Directives; c)
Observe the working relationships and interfaces between Shift Technical Advisors-Shift Supervisors; Plant and Corporate Engineering and General / Group Managers and advise VPGE/NO how these relationships may be improved; d)
Check the flow of NRC and industry information to determine that it is being properly utilized to improve procedures, correct deficiencies in operator training, and to see in general that proper action is being taken to maximize the benefits of industry experiences in mitigating or preventing the impact of transients or deficiencies in plant components or system; e)
Observe and advise the Operations Supervisor in his Reactor Operator performance and suggest methods or techniques that could be employed to enhance plant operation.
f)
Consult' with the Plant Training Supervisor to see that the j _.
training techniques, procedures, programs and equipment are the state-of-the-art and suggest ways of improving the qualification and training of operate ts; g)
Work with and advise the Corpor.te Staff Training position L
in the-assessment of the training programs for Corporate and plant' engineers and assist the Group / General Managers in the development and evaluation of'their training activities.
-h)
Consult with the IIealth Physics Supervisor regarding the adequacy of his practices and procedures end recommend improvements to reduce the radiation exposure of employees in
'the performance of their duties; i -:
Mr. IIarold R. Denton Page Six - March 4, 1981 i)
Meet frequently with VPGE/NO and keep him informed by written reports of their observations, recommendations and action taken by the appropriate party to correct deficiencies detected; and j)
Familiarize themselves with the Management Directives and assist the VPGE/NO in making sure that the Directives are being adhered to.
These assistants may also perform any other duties assigned by the VPGE/NO that he considers vital to the safe operation of the plant.
12.
The Company will continue to update and improve Management Directives, Administrative Instructions and Implementing Procedures to establish clear lines of authority and control.
South Carolina Electric & Gas Company is confident that these efforts will clearly define areas of responsibilities, establish guidelines to integrate the performance of activities and provide the necessary mechanism to achieve an effective working relationship among Corporate Groups and between Corporate Groups and the Plant.
f Very truly yours, T. C. Nichols, Jr.
TCN:bwm cc - V. C. Summer G.11. Fischer T. C. Nichols C. A. Price D. A. Nauman W. A. Williams R. B. Clary A. R. Koon A. A. Smith H. N. Cyrus J. B. Knotts J. L. Skolds B. A. Bursey O. S. Bradham ISEG NPCF/Whitaker File PRS v.-. _
_ _ _ _ _ _..