ML20076F840
| ML20076F840 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 05/11/1983 |
| From: | Dixon O SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20076F830 | List: |
| References | |
| NUDOCS 8306140457 | |
| Download: ML20076F840 (7) | |
Text
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SOUTH CAROLINA ELECTRIC & GAS COMPAN 2 E!5CION 3 J
POST OFFr05 784 COLUMe A. south CAROLINA 29218 a
e O. W. OlXoN. JR.
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VICE P.ESIDENT My n, M83 uvCts.
o....T,on.
Mr. J.
P.
O'Reilly, Regional Administrator U. S. Nuclear Regulatory Commission Region II, Suite 2900 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 83-08, " Examination of Management and Quality Assurance Controls"
Dear Mr. O'Reilly:
Please find attached South Carolina Electric and Gas Company's (SCE&G) responses to the Notice of Violations as addressed in Appendix A of NRC Inspection Report 83-08.
If there are any questions, please call us at your convenience.
Yours ver,truly,
-)
O. W. D'xon, r.
/fjc
Attachment:
cc:
V.
C.
Summer T.
C.
Nichols, Jr./O. W.
Dixon, Jr.
E.
C. Roberts H.
N.
Cyrus Group / General Managers O. S. Bradham R.
B.
Clary C.
A.
Price A.
R.
Koon C.
L. Ligon (NSRC)
G.
J. Braddick J.
C. Miller J.
L.
Skolds J.
B. Knotts, Jr.
NPCF File (Lic./Eng.)
f;306140457 830525 PDR ADOCK 05000395 0
PDR u
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Mr. James P. O'Reilly NRC Notice of Violation Page Two May 11, 1983 RESPONSE TO NOTICE OF VIOLATION A NRC INSPECTION REPORT 83-08 I.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION South Carolina Electric and Gas Company is in agreement with this violation as stated.
II.
REASON (S) FOR THE VIOLATION The reason for this condition was that the Station Quality Assurance group did not adequately monitor the timely issuance of reports.
III.
IMMEDIATE CORRECTIVE ACTION TAKEN AND ACTION TAKEN TO PREVENT RECURRENCE A meeting was held with Quality Assurance (QA) staff personnel to emphasize the importance of timely issuance of' audit reports.
Lead auditor personnel were assigned specific responsibilities to assure that audit reports are prepared in sufficient time to allow for an adequate and thorough review prior to issuance to managenent positions responsible for the areas audited.
The' Station-Quality Assurance Group has established an internal tracking system which assures that audit reports are forwarded to management positions reponsible for the areas audited.within 30 days.
All audit reports which
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have been issued subsequent to this Notice of Violation have complied with the Technical Specification.
HIV.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Corrective action as stated above has been corapleted.
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Mr.-James P.
O'Reilly NRC Notice of Violation Page Three May 11, 1983 RESPONSE TO NOTICE OF VIOLATION B NRC INSPECTION REPORT 83-08 I.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION South Carolina Electric and Gas Company is in agreement with this violation as stated.
II.
REASON (S) FOR THE VIOLATION The reason for this condition was twofold:
1.
A failure on the part of the plant staff to respond to audit reports as requested, and their unfamiliarity with ANSI N45.2.12 requirements relative to providing a schedule of corrective action completion dates compounded the failure to respond to QA within the 30 day time period.
2.
The SCE&G/QA organization was keenly aware, via it's internal tracking mechanisms, of the status of all audit findings; however, SCE&G/QA perforiaed qualitative evaluations of the importance of individual findings and pursued each item accordingly.
No finding, however, has been closed without proper justification.
I III.
IMMEDIATE CORRECTIVE ACTIONS TAKEN AND ACTION TAKEN TO PREVENT RECURRENCE Subsequent to the Notice of Violation, the Plant Manager issued a memo to plant management personnel directing that SCE&G/QA audit reports be responded to by the requested date.
Additionally, the memo requested that if corrective action could not be completed by the requested date, that scheduled corrective action commitment dates be provided.
l
Mr. James P.
O'Reilly NRC Notice of Violation Page Four May 11, 1983 RESPONSE TO NOTICE OF VIOLATION B (Cont'd)
NRC INSPECTION REPORT 83-08 A meeting was held with the QA Manager, Plant Manager, and QA Director, Surveillance Systems, to discuss a course of comprehensive corrective action.
It was agreed that a total compilation of all outstanding audit findings under the Plant Manager's jurisdiction would be provided to responsible assistant managers with a brief explanation of ANSI N45.2.12 requirements. A new response date was also requested.
Subsequent to the initial meeting, it was agreed that the QA Manager, Plant Manager, and the QA Director, Surveillance Systems, would meet with each responsible Assistant Manager to review all open audit items and pursue positive corrective action commitment dates.
To date, a meeting has been held with each Assistant Manager and positive corrective action commitment dates, or item specific resolution, has been obtained and documented in meeting minutes.
Additionally, the QA Director, Surveillance Systems, has met with the Station QA staff to affirm the position that the Station QA organization would not evaluate specific findings for importance, but would treat resolution of each with equal merit.
A review of ANSI N45.2.12 requirements as they relate to audit finding follow-up and corrective action (including need for commitment dates) was also conducted to assure total understanding within the Station QA organization.
IV.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED It is anticipated that full compliance with the corrective action described above will be completed by May 31, 1983.
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b i
e Mr. James P. O'Reilly i
NRC Notice of. Violation
. Page Five May 11, 1983 RESPONSE TO NOTICE OF VIOLATION C NRC INSPECTION REPORT-83-08 4
I.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION South Carolina Electric and Gas Company is in agreement with the violation as stated.
l II.
REASON (S) FOR THE VIOLATION l
i This violation _ occurred due to reliance, as the inspector-noted, on an informal system of operator briefings.
i III.
IMMEDIATE CORRECTIVE ACTION TAKEN AND ACTION TAKEN TO PREVENT RECURRENCE The implementing procedure III.A.4, "Requalification Program for USNRC Licensed Operators and Senior Operators," is being revised.
This revision will provide for documentation of the cognizance of licensed operators r.
and senior operators of significant changes, as determined by the Assistant Manager, Operations, or Supervisor of i
Operations, to:
I a.
-Facility Design Changes l
b.
Procedure Changes c.
Technical Specification Changes d.
Facility Operating License Changes e.
Operating Experiences This documentation will be by means of sign-of f sheets in the Operations Required Reading Book.
l l
The implementing procedure also provides for documentation when dissemination of the above information is accomplished by other methods, such as lectures, or Operations Supervisor's meetings.
Implementation of these procedure changes should prevent recurrence of this violation.
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Mr. James P. O'Reilly NRC Notice of Violation Page Six May 11, 1983 RESPONSE TO NOTICE OF VIOLATION C (Cont'd)
NRC INSPECTION REPORT 83-08 IV.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED It is anticipated that all necessary procedure reviews and approvals will be completed by June 30, 1983.
4
Mr. Janes P.
O'Reilly NRC Notice of Violation Page Seven May 11, 1983 RESPONSE TO NOTICE OF VIOLATION D NRC INSPECTION REPORT 83-08 I.
ADMISSION OR DENIAL OF ALLEGED VIOLATION South Carolina Electric and Gas Company is in agreement with the violation as stated.
II.
REASON (S) FOR THE VIOLATION In some cases, initial required reading had been completed by plant employees but not documented in training records.
In other cases, initial required reading had not been completed on time.
Some of the published lists of initial required reading had become outdated, leading to lessened attention to this procedural requirement by supervisors.
Management action taken to ensure the completion and documentation of required reading had too little impact during the last twelve months.
III.
IMMEDIATE CORRECTIVE ACTION TAKEN AND ACTION TAKEN TO PREVENT RECURRENCE The initial corrective action taken was to revise the required reading lists.
Publication of these lists will follow their approval by plant management. Using the newly published lists we will ensure that plant personnel, who are deficient in regard to the initial reading requirement, satisfy that requirement promptly.
In order to prevent recurrence, it is planned to institute a tracking system which will alert Nuclear Education and Training when a new employee is nearing his or her target date for reading compliance.
IV.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED It is anticipated that full compliance with the corrective action stated above will be completed by June 30, 1983.
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