ML20248D624

Responds to NRC 890831 Notice of Violation & Proposed Imposition of Civil Penalty,Per Insp Rept 50-395/89-14. Corrective Actions:Operator Counseled for Assuming Licensed Operator Watch While Unqualified for Position

ML20248D624
Person / Time
Site:	Summer
Issue date:	09/29/1989
From:	Bradham O SOUTH CAROLINA ELECTRIC & GAS CO.
To:	Lieberman J NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 8910040338
Download: ML20248D624 (7)

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South Carolins EL:ctric & Gas Comp ny 01111 S. Eridham i

. P.O. Box 88 Mce Presidint l Jznkinsville, SC 29005 ' Nuclear Operat' 1 41 -(803) 3454040

'SCE&G.-

,.c- ~ September 29, 1989 Mr.: James Lieberman Director, Office of Enforcement

'U. S. Nuclear Regulatory Commission Washington, DC. 20555 Attention: . Document Control Desk

Subject:

Virgil C. Summer Nuclear Station Do;*et No. 50/395 Openting License No. NPF-12 NetR4 cf Vio'iation and Proposed In4.csition of Civil Penalty NRC Inspection Report 89-14

Dear Mr. Lieberman:

On August 31, 1989, the Nuclear Regulatory Commission (Region II) issued a Notice of Violation and Proposed Imposition of Civil Penalty for the alleged violation of NRC requirements, as stated in 10CFR50.54(1), at the South Carolina Electric & Gas Company (SCE&G) Virgil C. Summer Nuclear Station (VCSNS). SCE&G has thoroughly reviewed and investigated the incident described in the Notice and, pursuant to 10CFR2.201, is responding to the alleged violation in Attachment I.

SCE&G strives for performance excellence in the operation of the VCSNS and takes this event seriously. SCE&G has always recognized its responsibilities as-the licensee and operator and holds itself solely accountable for.the June 2, 1989 assumption of licensed operator duties by an operator who had failed the annual requalification exam and had not satisfactorily completed retraining and retesting.

SCE&G does take exception to the NRC statements that we determined that the sole root cause of the violation was the individual licensed operator error and that NRC intervention was necessary to focus our atter> tion on the program weaknesses. SCE&G at no time determined that'the sole root cause of the violation was the individual licensed operator error. During the inspection conducted on June 14-15, 1989,. opinions were expressed concerning individual responsibility and program weaknesses. However, no sole root cause was determined to exist. Also, prior to the NRC involvement, SCE&G had identified program enhancements that needed to be made to prevent this from occurring again. NRC intervention was not needed to focus our attention on the program weaknesses. SCELG does recognize that some additional enhancements were added after discussions with members of your staff.

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Mr. James Lieberman September 29, 1989 Page 2 of 2 SCE&G is in agreement with the basic facts set forth in the Notice of Violation and will not contest-the Imposition of Civil Penalty. Enclosed is a check in the amount of twenty-five thousand dollars ($25,000.00).

If there are any further questions _or comments, please contact us at your.

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

Very.truly yours,

0. S. Bradham WRH/OSB: led Attachment c: D..A. Nauman/0. W. Dixon, Jr./T. C. Nichols, Jr.

E. C. Roberts W. A. Williams, Jr.

.S. D. Ebneter.

J. J. Hayes, Jr.

General Managers C. A. Price R. B. Clary K. E. Nodland J. C. Snelson R. L. Prevatte J. B. Knotts, Jr.-

NPCF NSRC RTS- (IE891400)

File _ (815.01)

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h[' Attachment I to Mr. James Leiberman Letter September 29, 1989 l '

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RESPONSE TO NOTICE OF VIOLATION VIOLATION NUMBER 50-395/89-14 I. ADMISSION OR DENIAL OF THE ALLEGED VIOLATION South Carolina Electric & Gas Company (SCE&G) is in agreement with the alleged violation.

II. REASON FOR THE VIOLATION SCE&G attributes this event to a combination of inadequate programmatic controls and personnel error. The personnel error was the result of the operator failing to recognize and fulfill all of the requalification requirements prior to standing a licensed operator watch. This irdividual, normally assigned to a group outside the operating group, was trying to maintain his watchstanding proficiency in order to sustain his license in an active status. The programmatic controls, in place at the time the event occurred, were inadequate in that they failed to provide the necessary controls in the event of personnel error.

On April 11, 1989, the licensed operator in question took his annual written requalification exam and on April 21, 1989, it was determined that he had failed that exam (exam score was 72.7%). A letter was sent to the General Manager, Nuclear Plant Operations (equivalent to Plant Manager) by the Manager, Nuclear Operations Education and Training, on April 21, 1989, informing him that the operator had failed the annual written requalification exam. Copies of this letter were also sent to the operator in question, the operator's supervisor, and the Manager of Operations. This letter also suggested that the operator be removed from licensed operator duties.

The operator inquired of the training group when he would be scheduled for retraining and the makeup requalification exam. The operator was informed that the retraining and makeup exam would be scheduled at some later date. This later date was to coincide with the retraining and makeup exam for another operator who had failed an NRC administered exam. On one occasion, the operator was also verbally informed that he was not qualified to stand a licensed operator watch by the Manager, Operations.

On April 28, 1989, the Shift Supervisors were informed via an informal Shift Supervisor Night Order Book entry that the operator had failed his annual requalification exam and could not stand watches as a licensed operator.

In May 1989, with the second calendar quarter greater than half over, the operator realized that time for standing the required five

" twelve hour shifts" for the quarter had nearly elapsed. The j operator, after looking at his personal schedule, decided to stand the necessary watches on the five Fridays in the month of June. On May 30, 1989, the operator made arrangements with the Control Room Supervisor to stand the first of five " twelve hour shifts" on June 2, 1989.

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Attachment I to'Mr. James Leiberman Letter September 29, 1989 Page 2 of 5 On June 2, 1989 -the operator. relieved the Nuclear Reactor Operator l at the Controls at approximately 0730. At approximately 1000, the Shift Supervisor overheard a discussion in which the operator.

indicated that he had failed his annual written requalification exam and had not taken a makeup exam. Upon discovery that the operator was not qualified to. stand a licensed operator watch, the duty Shift Supervisor had him relieved of the watch.

When the operator' assumed the shift, the plant was in Mode 5. The operator only recorded log readings and did not perform any control board manipulations. In addition to the operator in question..the-shift complement in the control room. area included a Shift Supervisor (SRO. licensed), a Control Room Supervisor (SR0 licensed), and a Balance of Plant Operator (R0 licensed).

III. CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED SCE&G implemented the following corrective actions:

1. On Jur,e 2, 1989, the operator was counseled for assuming a.

licensed operator watch while being unqualified to do so. It was pointed out to the operator in this counseling session that his actions were in violation of Station Administrative Procedure (SAP-200), " Conduct of Operations," and NRC requirements.

2. On June 5, 1989, the Manager, Operations, in a letter addressed to the operator, informed the. operator that his active license status was terminated.

3. On June 5, 1989, the Associate Manager, Operations, in a letter to all licensed cperators, reminded the licensed operators that they are responsible for insuring that they are fully qualified before assuming a licensed operator watch. They were also reminded that they are responsible for notifying the Nuclear Licensing group and their respective supervisor of any changes in health or training status that could affect their license qualification.

, 4. On June 6, 1989, the operator's supervisor submitted the j paperwork terminating the operator active license.

5. On June 8, 1989, the Vice President, Nuclear Operations, mailed to the home of each licensed operator a letter outlining the special responsibilities that each license holder has under the terms of their license. The letter also states that each license holder and SCE&G had obligations to uphold in assuring compliance with our commitment.

6. On June 9, 1989, the operator was given a day off without pay as disciplinary action.

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' Attachment I-to Mr. James Leiberman ' Letter September 29, 1989

Page 3.of 7. .On June 16, 1989, a psychological assess. ment was conducted on the operator by:a practicing psychologist. The results of that psychological assessment. indicated that the operator had no.

. evidence of a psychological abnormality or impairment.

8. On June 16, 1989, the operator underwent a drug screening in which the results were negative.

9. On July 21, 1989, the Quality Assurance group issued the results of.an audit completed on the Licensed Operator Requalification program.. The audit included a review and verification of compliance with the 10CFR55.59 requirements that must be adhered-to before an operator can assume.a licensed. operator _ watch. 'The-audit concluded that with only two exceptions, all individuals that were checked were found to be in compliance with 10CFR55.59. The.two exceptions were:

[ 1) Control Room Supervisor assuming watches with an expired license. This was reported in Licensee Event Report 85-06.

2) The June 2, 1989 event.

10. On June 22, 1989, in a telephone call with Mr. Albert F. Gibson of the NRC, Region II, SCE&G agreed that the operator would not be-allowed to stand any licensed operator watches without first discussing it with Region II. This phone call was followed up with a letter addressed to Mr. Gibson stating that position.

IV. CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION The following long term programmatic control changes have been developed in order to preclude any further violation of this type:

1. The Station Administrative Procedure (SAP-200), " Conduct of Operations," was revised to require the following:

a. Each off-going watchstander is to ensure to the best of his ability that the relieving individual is physically and mentally capable of accepting the duties of the position.

b. The oncoming Shift Supervisor will verify that his shift is adequately manned and the personnel are qualified on their watchstations and are fit for duty.

c. Shift relief shall include acknowledgement by the oncoming operator that they are aware of current plant conditions, and to the best of their knowledge they are fully qualified to stand the watch.

2. Nuclear Licensing Procedure (NL-117), "NRC Licensed Operator Qualification Tracking " was written to track the active or

inactive status of operator licenses. An updated Operator License Status List is maintained in the Control Room and a copy of that list is sent to each shift supervisor.

i Attachment I to'Mr. James Leiberman Letter.

-September 29, 1989..

'Page 4 of 5 3., Operations Administrative Procedure (OAP-101.4), " Quarterly Report of Licensed Watchstanding," was generated to document and track the minimum number of eight or twelve hour shifts an operator must stand in order.to maintain his license in an-active status. A0P-101.4 also documents'the' changes in license status from active to inactive and from inactive to active.

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4. .NuclearServiceAdministrativeProcedure(NSAP.II.B4), ..

"Requalification Program for USNRC Licensed Operators and Senior Operators," was revised to formalize the notification'of.

licensed operator requalification failures.

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5. Management Directive (MD-63), " Responsibilities of Nuclear Operations Division Management and Personnel Requiring Special Qualifications," was generated to outline the responsibilities.

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'of the Nuclear Operations. Division (NOD) management and personnel requiring special qualification. MD-63 points out

that

a. N0D management is responsible for the overall direction and

. supervision of their personnel to ensure the plant is operated in a safe and efficient manner in compliance with

'the Facility Operating License and Technical Specifications.

b. NOD managers are directly accountable for ensuring'that

, their personnel adhere to applicable regulatory l requirements and N00 procedures in the performance of their duties.

c. NOD managers must also be cognizant of their employees qualification status,

d. In those cases where an individual has more than one manager supervising his/her activities, the manager directing his/her technical work for a specific job is responsible for his/her performance in that job including qualification status.

e. Personnel requiring special qualifications (this includes

, NRC licensed-and non-licensed personnel) are responsible for ensuring that they are medically and technically qualified to carry out the duties they are assigned. These personnel are also required to notify their respective management of any change in qualification status.

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6. Management Directive (MD-56), " Premium Pay for NRC License / Certification and for Shift Engineer, Lead Engineer, and Systems Engineer Qualification," was written to replace Station Directive (50-13), "NRC Licensed Certification Premium Pay."

MD-56 more clearly defines active and inactive licenses and what the requirements are for maintaining an active license.

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. September 29, 1989- .

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7. . The Nuclear. Safety Review Committee (NSRC) has reviewed the' -

Licensed Operator Qualification Program to assess the overall adequacy and expected effectiveness of the corrective actions identified above. This assessment looked at the methods employed by Training, Security, Nuclear. Licensing, Personnel, and Operations in performing functions and transmitting l information which directly relates to the qualification of-NRC I, licensed operators at the VCSNS.

l In summary, the NSRC review has determined that'the actions taken are adequate to prevent a similar situation from happening

, in the future.

V. DATE OF FULL COMPLIANCE The action listed above was completed by September ~11, 1988.

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