RC-01-0218, Revised Response to Unresolved Issue (URI) No. 50-395/01-09-01, RC-01-218

Revised Response to Unresolved Issue (URI) No. 50-395/01-09-01, RC-01-218

ML040440308
Person / Time
Site:	Summer
Issue date:	02/10/2004
From:	Byrne S South Carolina Electric & Gas Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
IR-01-009, RC-01-0218, RC-04-0034
Download: ML040440308 (2)

Text

Stephen A. Byrne Senior Vice President, Nuclear Operations 803.345.4622 February 10, 2004 RC-04-0034 A SCANA COMPANY Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555 Gentlemen:

Subject:

VIRGIL C. SUMMER NUCLEAR STATION DOCKET NO. 50/395 OPERATING LICENSE NO. NPF-12 REVISED RESPONSE TO UNRESOLVED ISSUE NRC INSPECTION REPORT 50-395/01-09 South Carolina Electric & Gas (SCE&G) has reviewed the original response to Unresolved Issue (URI) No. 50-395/01-09-01, RC-01-0218, and has determined that a revised response is necessary. Therefore, SCE&G would like to withdraw RC-01 -0218 and have this letter replace it as the response to URI 01-09-01.

SCE&G agrees with the non-cited violation green finding on emergency lighting; however some comments are provided in response to the identified finding on the lack of operator training for entry into Fire Emergency Procedures.

Subsection 'A', "Summary of Findings", states:

A finding was identified, in that, the lack of operator training combined with licensee management's expectations regarding when to enter fire emergency procedure (FEP)-4.0, Control Room Evacuation Due to Fire, could result in the operators taking actions during a fire in the main control room (MCR) that would not be consistent with the licensee's safe shutdown analysis, fire hazards analysis, or procedure FEP-4.0. The operator training program neither addressed nor had job performance measures (JPM)/simulator scenarios for MCR operator actions and evacuation due to a fire in accordance with procedure FEP-4.0.

This finding was determined to have a credible impact on safety because it affected the ability of the operators to perform actions (within the times required by the licensee's safe shutdown analysis and fire hazards analysis) necessary to achieve and maintain post-fire safe shutdown conditions. Licensee management's philosophy and expectations contributed to the operators'performance and slow response in deciding whether to enter procedure FEP-4.0 and evacuate the MCR during two simulator scenarios observed by the team.

1 SCE&G I Virgil C.Summer Nudear Station

• P.0.Box 88 Jenkinsville, South Carolina 29065 T(803) 345.5209

• www.scana.com

Document Control Desk 0-C-01 -1839 RC-04-0034 Page 2 of 2 SCE&G has identified this issue in our corrective action program as Condition Evaluation Report (CER), 0-C-01-1839.

Evaluation of this condition has concluded that under most circumstances, Emergency Operating Procedures and Abnormal Operating Procedures provide sufficient direction to mitigate events. However, it is recognized that entry into Fire Emergency Procedure (FEP)-4.0 is necessary at times. In consideration of this, Operations management philosophy has been that entry into FEP-4.0 is warranted when the fire is of such a nature (due to magnitude, location, or equipment involved) that there is concern about maintaining the ability to safely control the plant. Multiple spurious operations of plant equipment is not a prerequisite to entering the FEPs. Also, in the event of other unforeseen significant problems, the duty Shift Supervisor may exercise discretion for entry into FEP-4.0.

Management's expectations have been communicated to operators through classroom training. The training, which incorporates risk insights gained from the IPEEE, is provided every two years as a part of the licensed operator re-qualification program.

In addition, SCE&G has developed and conducted simulator exercises and job performance measures that require entry into Fire Emergency Procedures, consistent with management's expectations.

Should you have any questions, please call Mr. Jeff Pease at (803) 345-4124.

Very truly yours, Stephen A. Byrne JWP/SAB c: N. 0. Lorick Paulett Ledbetter N. S. Cams K. M. Sutton T. G. Eppink (w/o attachment) W. R. Higgins R. J. White NSRC L. R. Reyes RTS (0-C-01-1839)

K. R. Cotton File (815.01)

M. N. Browne DMS (RC-04-0034)

NRC Resident Inspector