ML20205P964

Submits Supplemental Response to Enforcement Action 86-45. Proposed Civil Penalty Should Be Mitigated in View of Inaccurate SALP Assessment Re Degradation of Mgt Controls

ML20205P964
Person / Time
Site:	Summer
Issue date:	05/23/1986
From:	Nauman D SOUTH CAROLINA ELECTRIC & GAS CO.
To:	Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
EA-86-045, EA-86-45, NUDOCS 8605280072
Download: ML20205P964 (2)

Text

th roina Electric & Gas Company Dan A n Nuclear Operations gumgag29218 SCE&G

~~

May 23,1986 Mr. J. M. Taylor Director, Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission (NRC)

Washington, DC 20555

Subject:

Virgil C. Summer Nuclear Station Docket No. 50/395 Operating License No. NPF-12 Supplemental Response to EA 86-45, NRC Inspection Report 86-06

Dear Mr. Taylor:

On May 15,1986, South Carolina Electric & Gas Company (SCE&G) provided its response to the Notice of Violation and Proposed Imposition of Civil Penalty forwarded in the subject enforcement action. In that response, SCE&G asked the Staff to consider mitigating the pro aosed civil penalty in view of, among other things, SCE&G's past performance. Past perrormance was evidently the crucial factor in the proposed imposition of the civil penalty. Dr. Grace's April 15,1986 letter, transmitting the enforcement action, stated that mitigation was not appropriate because of SCE&G's ' prior poor performance in the area of concern."

SCE&G ex aressed the view in its response that its recent efforts to improve performance in the overa I operation of the Virgil C. Summer Nuclear Station had evidently not been considered by NRC in determining the amount of the proposed civil penalty.

Since preparing our response, SCE&G has received modifications to the most recent Systematic Assessment of Licensee Performance (SALP) Soard Report. In transmitting the modifications, the Region acknowledged that the NRC assessment regarding

" degradation of management controls" at the Virgil C. Summer Nuclear Station was inaccurate. In his May 8,1986 letter, Dr. Grace revised his finding and provided replacement pages showing this change.

SCE&G believes that this action by the Region provides further evidence that the Staff's perception of prior poor aerformance was based in large measure,if not entirely, on what has now been acknowlec ged to be an inaccurate SALP assessment. This confirms that the proposed civil penalty was not warranted, or at least should be substantially mitigated.

Therefore, SCE&G requests that the Staff take thi<, modification of the recent SALP Board Report into account when considering whether to mitigate the proposed civil penalty.

The undersigned affirms that the statements and matters set forth in this letter are true and correct to the best of my knowledge,information and belief.

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W /NauMan g[2gg gy ,

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Mr. J. M. Taylor PageTwo May 23,1986 MDB: DAN:tdh c: O. W. Dixon, JrJT. C. Nichols, Jr.

E. H. Crews, J r.

E. C. Roberts J. G. Con nelly, Jr.

W. A. Williams, Jr.

H. R. Denton J. Nelson Grace Group Managers O. 5. Bradham D. R. Moore C. A. Price W.

C. L.T. Frady(NSRC)

Ligon R. M. Campbell K. E. Nodland R. A. Stough G. O. Percival R. L. Prevatte J. B. Knotts, J r.

Document Management Branch NPCF File 4

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