IR 05000395/2013009: Difference between revisions
StriderTol (talk | contribs) (Created page by program invented by StriderTol) |
StriderTol (talk | contribs) (Created page by program invented by StriderTol) |
||
| (3 intermediate revisions by the same user not shown) | |||
| Line 19: | Line 19: | ||
=Text= | =Text= | ||
{{#Wiki_filter: | {{#Wiki_filter:UNITED STATES ugust 6, 2013 | ||
==SUBJECT:== | ==SUBJECT:== | ||
| Line 25: | Line 25: | ||
==Dear Mr. Gatlin:== | ==Dear Mr. Gatlin:== | ||
On May 2, 2013, the Nuclear Regulatory | On May 2, 2013, the Nuclear Regulatory Commissions (NRC) Office of Investigations completed an investigation (and in-office review) at Virgil C. Summer Nuclear Station Unit 1 to determine, in part, whether three contract employees deliberately failed to follow an applicable plant procedure and falsified a data sheet associated with safety-related electrical supports by backdating it to a date when the previous procedure (Rev. 8) was in effect. Based on the results of the investigation, the NRC concluded that these individuals deliberately failed to follow the electrical maintenance procedure EMP-391.003, Installation of Electrical Supports, Rev. 8, Change A, while implementing safety-related modification work associated with Work Order (WO) 120155-021 for Engineering Change Request (ECR) 50780. The results of the investigation were discussed on July 31, 2013 with you and other members of your staff. The enclosed inspection report presents the finding resulting from this investigation. | ||
During this inspection, the NRC staff examined | During this inspection, the NRC staff examined activities conducted under your license as they relate to public health, safety and the conditions of your license. Within these areas, the inspection consisted of selected examination of procedures and representative records, observations of activities, and interviews with personnel. | ||
Based on a review of the facts and | Based on a review of the facts and circumstances in this case, the NRC has determined that a Severity Level IV violation of NRC requirements occurred. The violation was evaluated in accordance with the NRC Enforcement Policy. The current Enforcement Policy is included on the NRCs Web site at http://www.nrc.gov/about-nrc/regulatory/enforcement/enfore.pol.html The violation is cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding it are described in detail in the subject inspection report. The violation is being cited in the Notice due to the deliberate misconduct aspects, the fact that of the three contract (two electricians and a lead electrician) employees failed to follow the plant procedural requirements, the lack of oversight of contract workers and inadequate corrective actions. You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. | ||
In light of the above, the NRC requests that your response address corrective actions that have or will be implemented to ensure adequate oversight of contract workers and provide additional details of training for all contract and SCE&G employees to prevent similar issues with procedural compliance in the future. | |||
In light of the above, the NRC requests that your response address | |||
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosures, and your response, will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy or proprietary, information so that it can be made available to the public without redaction. | In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosures, and your response, will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy or proprietary, information so that it can be made available to the public without redaction. | ||
| Line 39: | Line 37: | ||
Sincerely, | Sincerely, | ||
/RA/ | /RA/ | ||
Gerald J. McCoy, Chief Reactor Projects Branch 5 Division of Reactor Projects | Gerald J. McCoy, Chief Reactor Projects Branch 5 Division of Reactor Projects Docket No.: 50-395 License No.: NPF-12 cc w/encl: (See page 3) | ||
Docket No.: 50-395 License No.: NPF-12 | |||
cc w/encl: (See page 3) | |||
===Enclosures:=== | ===Enclosures:=== | ||
1. Notice of Violation 2. Inspection Report 05000395/2013009 w/Attachment: Supplemental Information 3. OI Synopsis, Investigation 2-2012-041 | 1. Notice of Violation 2. Inspection Report 05000395/2013009 w/Attachment: Supplemental Information 3. OI Synopsis, Investigation 2-2012-041 | ||
SUNSI REVIEW COMPLETE FORM 665 TTACHED OFFICE RII:DRP RII:DRP RII:DRP RII:DRP RII:DRP RII:DRP SIGNATURE Via email Via email Via email BDB /RA/ GJM /RA/ CFE /RA/ NAME JReece SNinh ECoffman BBishop GMcCoy CEvans DATE 07/25/2013 07/25/2013 07/25/2013 08/01/2013 08/04/2013 07/24/2013 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO | SUNSI REVIEW COMPLETE FORM 665 TTACHED OFFICE RII:DRP RII:DRP RII:DRP RII:DRP RII:DRP RII:DRP SIGNATURE Via email Via email Via email BDB /RA/ GJM /RA/ CFE /RA/ | ||
NAME JReece SNinh ECoffman BBishop GMcCoy CEvans DATE 07/25/2013 07/25/2013 07/25/2013 08/01/2013 08/04/2013 07/24/2013 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO | |||
REGION II== | REGION II== | ||
Docket No. 50-395 License No. NPF-12 Report No. 05000395/2013009 Licensee: South Carolina Electric & Gas (SCE&G) Company Facility: Virgil C. Summer Nuclear Station, Unit 1 Location: P.O. Box 88 Jenkinsville, SC 29065 Dates: June 24, 2013 through July 31, 2013 Inspectors: J. Reece, Senior Resident Inspector S. Ninh, Senior Project Engineer E. Coffman, Resident Inspector B. Bishop, Project Engineer Approved by: Gerald J. McCoy, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure 2 | |||
Docket No. 50-395 | |||
License No. NPF-12 | |||
Report No. 05000395/2013009 | |||
Licensee: South Carolina Electric & Gas (SCE&G) Company | |||
Facility: Virgil C. Summer Nuclear Station, Unit 1 | |||
Location: P.O. Box 88 Jenkinsville, SC 29065 | |||
Dates: June 24, 2013 through July 31, 2013 | |||
Inspectors: J. Reece, Senior Resident Inspector S. Ninh, Senior Project Engineer E. Coffman, Resident Inspector B. Bishop, Project Engineer | |||
Approved by: Gerald J. McCoy, Chief Reactor Projects Branch 5 Division of Reactor Projects | |||
Enclosure 2 | |||
=SUMMARY OF FINDINGS= | =SUMMARY OF FINDINGS= | ||
IR 05000395/2013009; 06/24/2013 - 07/31/2013; Virgil C. Summer Nuclear Station Unit 1; Plant | IR 05000395/2013009; 06/24/2013 - 07/31/2013; Virgil C. Summer Nuclear Station Unit 1; Plant | ||
The report covered an in-office review of NRC Office of Investigations (OI) Report No. 2-2010-029 by resident inspectors, a senior project engineer and a project engineer. One Severity Level IV violation was identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using IMC 0609, | Modifications The report covered an in-office review of NRC Office of Investigations (OI) Report No. 2-2010-029 by resident inspectors, a senior project engineer and a project engineer. One Severity Level IV violation was identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using IMC 0609, Significance Determination Process. Findings for which the Significance Determination Process does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process Revision 4, dated December 2006. | ||
===Cornerstone: Mitigating Systems=== | ===Cornerstone: Mitigating Systems=== | ||
Severity Level IV: | Severity Level IV: The licensee identified a violation of 10 CFR 50, Appendix B, Criterion V, instructions, procedures, or drawings, when it was determined that the contract employees failed to complete the electrical maintenance procedure EMP-391.003, Installation of Electrical Supports, Rev. 8, Change A, and falsified a data sheet associated with safety-related electrical supports by backdating it to a date when the previous (Rev.8) was in effect. The licensee took substantial disciplinary actions and entered the deficiency into the corrective action program for resolution as CR -12-03100. | ||
The failure to follow procedure issue was a performance deficiency and it would be considered a minor under the reactor oversight process (ROP) because the quality control personnel subsequently inspected the pull box; the components had been installed properly and could have performed their safety-related function. A review of other work performed by these contract employees did not identify any other issues. This minor finding was not warranted to be documented in a quarterly inspection report in accordance with IMC 0612. However, with respect to deliberate misconduct aspects, failure to provide complete and accurate information regarding completion of the electrical maintenance procedure EMP-391.003, Installation of Electrical Supports, Rev. 8, Change A, was a performance deficiency. This issue was dispositioned using traditional enforcement due to the deliberate misconduct aspects of the performance deficiency. Furthermore, the failure to provide complete and accurate information has the potential to impact the NRCs ability to perform its regulatory function. These individuals deliberately violated the requirements in the revised electrical maintenance procedure EMP-391-003, Rev. 8, Change A, on July 16, 2013, in that they failed to follow the procedural requirements to obtain a quality control inspection after the holes were drilled in the concrete wall and then back-dated the procedure to June 29, 2012, to indicate that the work was performed prior to implementation of Rev. 8, Change A, which had an effective date of July 10, 2012. In accordance with the guidance in Section 6.1, Reactor Operations of the Enforcement Policy, this issue is a Severity Level IV violation because it involved information that the NRC required to be maintained by a licensee that was incomplete or inaccurate and of more than minor safety significance. No cross-cutting aspect was identified because this performance deficiency was dispositioned using traditional enforcement. | |||
=REPORT DETAILS= | =REPORT DETAILS= | ||
==REACTOR SAFETY== | ==REACTOR SAFETY== | ||
Cornerstones: | Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity | ||
{{a|1R18}} | |||
{{a|1R18}} | |||
==1R18 Plant Modifications== | ==1R18 Plant Modifications== | ||
| Line 104: | Line 75: | ||
=====Description:===== | =====Description:===== | ||
On July 16, 2012, three contract electricians installed pull box PB-CS189 using procedure EMP-391-003 Rev. 8 as part of Work Order (WO) 201155-021 - Alternate Seal Injection Modification (ECR 50780). This procedure had been updated to Rev. 8, Change A, effective July 10, 2012. The electricians backdated the completed procedure to June 29, 2012 to indicate that the procedure had been performed while the previous revision (Rev. 8) was still in | On July 16, 2012, three contract electricians installed pull box PB-CS189 using procedure EMP-391-003 Rev. 8 as part of Work Order (WO) 201155-021 - | ||
Alternate Seal Injection Modification (ECR 50780). This procedure had been updated to Rev. 8, Change A, effective July 10, 2012. The electricians backdated the completed procedure to June 29, 2012 to indicate that the procedure had been performed while the previous revision (Rev. 8) was still in effect. Backdating the completed procedure enabled the electricians to complete the entire job without reaching a quality control hold point, which was required by the latest revision (Rev. 8, Change A). Consequently, the quality control inspection required by the effective version of the procedure was not performed between when the mounting holes were drilled and before the mounting bolts were installed. | |||
This issue was immediately brought to the | This issue was immediately brought to the NRCs attention by the licensee and this issue was entered in the licensees corrective action program (CAP) as CR-12-03100. The licensee and contractor immediately initiated their investigation. | ||
Region II OI investigation was initiated on August 22, 2012, to determine if a contract electrician at V. C. Summer Nuclear Station, Unit 1, employed by Shaw Industry, did willfully violate electrical maintenance procedure EMP-391.003, Installation of Electrical Supports, Rev. 8, Change A, while implementing safety-related modification work associated with Work Order (WO) 1201155-021 for Engineering Change Request (ECR) | Region II OI investigation was initiated on August 22, 2012, to determine if a contract electrician at V. C. Summer Nuclear Station, Unit 1, employed by Shaw Industry, did willfully violate electrical maintenance procedure EMP-391.003, Installation of Electrical Supports, Rev. 8, Change A, while implementing safety-related modification work associated with Work Order (WO) 1201155-021 for Engineering Change Request (ECR)50780. | ||
On May 2, 2013, Region II OI issued a report and concluded, based upon the evidence developed during the investigation, that a contract electrician at V.C. Summer Nuclear Station Unit 1, deliberately failed to follow an applicable procedure and falsified a data sheet associated with safety-related electrical supports by backdating it to a date when the previous revision (Rev. 8) was in effect. Additionally, the OI investigation determined that another contract electrician and a lead electrician deliberately directed the contract electrician to falsify the data sheet associated with safety-related electrical supports. | |||
The inspectors reviewed the OI transcripts, licensees condition reports, and evidence obtained during the OI investigation. The inspectors agreed with the OIs conclusion that these individuals deliberately violated the requirements in the revised procedure EMP-391.003, Rev. 8, Change A, on July 16, 2013, in that they failed to follow the procedural requirements to obtain a quality control inspection after the holes were drilled and then back-dated the procedure to June 29, 2012, to indicate that the work was performed prior to implementation of Rev. 8, Change A, which had an effective date of July 10, 2012. | |||
the | The licensee took disciplinary actions and entered the deficiency into the corrective action program for resolution as CR -12-03100. These three contract employees were subsequently terminated and the pertinent data was placed in Personnel Access Data System. However, the inspectors determined that corrective actions were not adequate to address oversight of contract workers and additional training of all contract employees and SCE&G employees to prevent similar issues with procedural compliance in the future. | ||
The | =====Analysis:===== | ||
The failure to follow procedure was a performance deficiency and it would be considered a minor under the reactor oversight process (ROP) because the quality control personnel subsequently inspected the pull box; the components had been installed properly and could have performed their safety-related function. A review of other work performed by these contract employees did not identify any other issues. | |||
This minor finding was not warranted to be documented in a quarterly inspection report in accordance with IMC 0612. However, with respect to deliberate misconduct aspects, failure to provide complete and accurate information regarding completion of the electrical maintenance procedure EMP-391.003, Installation of Electrical Supports, Rev. | |||
8, Change A, was a performance deficiency. This issue was dispositioned using traditional enforcement due to the deliberate misconduct aspects of the performance deficiency. Furthermore, the failure to provide complete and accurate information has the potential to impact the NRCs ability to perform its regulatory function. These individuals deliberately violated the requirements in the revised electrical maintenance procedure EMP-391-003, Rev. 8, Change A, on July 16, 2013, in that they failed to follow the procedural requirements to obtain a quality control inspection after the holes were drilled in a concrete wall and then back-dated the procedure to June 29, 2012, to indicate that the work was performed prior to implementation of Rev. 8, Change A, which had an effective date of July 10, 2012. In accordance with the guidance in Section 6.1, Reactor Operations of the Enforcement Policy, this issue is a Severity Level IV violation because it involved information that the NRC required to be maintained by a licensee that was incomplete or inaccurate and of more than minor safety significance. The violation is being cited in the Notice because the deliberate misconduct aspects, the | |||
nature of the three contract (two electricians and a lead electrician) employees failure to follow the plant procedural requirements, lack of oversight contract works and inadequate corrective actions in accordance with the NRCs Enforcement Policy in effect at the time of the violation. No cross-cutting aspect was identified because this performance deficiency was dispositioned using traditional enforcement. | |||
=====Enforcement:===== | =====Enforcement:===== | ||
10 CFR 50, Appendix B, Criterion V, states in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. | 10 CFR 50, Appendix B, Criterion V, states in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. | ||
EMP-391.003, | EMP-391.003, Installation of Electrical Supports, Revision 8, Change A, is the procedure of record for implementation of safety-related modification work associated with Work Order 1201155-021, for Engineering Change Request 50780. | ||
Contrary to the above, on July 16, 2012, three contract employees working for the licensee deliberately failed to accomplish activities affecting quality in accordance with applicable procedures. Specifically, the contract employees used a previous revision (Revision 8 instead of Revision 8, Change A) of procedure EMP-391.003, | Contrary to the above, on July 16, 2012, three contract employees working for the licensee deliberately failed to accomplish activities affecting quality in accordance with applicable procedures. Specifically, the contract employees used a previous revision (Revision 8 instead of Revision 8, Change A) of procedure EMP-391.003, Installation of Electrical Supports, to implement safety-related modification work associated with Work Order 1201155-021, for Engineering Change Request 50780, and back-dated the procedure to June 29, 2012, to indicate that the work was performed prior to implementation of the latest revision (Rev. 8, Change A) to the procedure dated July 10, 2012. Additionally, these contract employees failed to ensure inspection of work activities by the licensees quality control personnel as required by EMP-391.003 Rev. 8, Change A. | ||
The violation is being cited because of the deliberate aspects, and because the three contract employees deliberately violated an applicable procedure and falsified a data sheet associated with safety-related electrical supports by backdating it to a date when the previous (Rev.8) was in effect, in accordance with Section 6.1.d of the | The violation is being cited because of the deliberate aspects, and because the three contract employees deliberately violated an applicable procedure and falsified a data sheet associated with safety-related electrical supports by backdating it to a date when the previous (Rev.8) was in effect, in accordance with Section 6.1.d of the NRCs Enforcement Policy in effect at the time of the violation: VIO 05000395/2013009-01, Installation of a modification using a superseded version of a procedure. | ||
{{a|4OA6}} | {{a|4OA6}} | ||
| Line 144: | Line 116: | ||
KEY POINTS OF CONTACT | KEY POINTS OF CONTACT | ||
Licensee | Licensee | ||
: [[contact::T. Gatlin]], Vice President, Nuclear Operations | : [[contact::T. Gatlin]], Vice President, Nuclear Operations | ||
: [[contact::B. Thompson]], Manager, Nuclear Licensing | : [[contact::B. Thompson]], Manager, Nuclear Licensing | ||
: [[contact::M. Browne]], Manager, Quality Systems | : [[contact::M. Browne]], Manager, Quality Systems | ||
: [[contact::E. Lynch]], Outage Management | : [[contact::E. Lynch]], Outage Management | ||
: [[contact::L. Bennett]], Manager, Business Services | : [[contact::L. Bennett]], Manager, Business Services | ||
: [[contact::L. Evans]], Director, Chicago Bridge and Iron Company | : [[contact::L. Evans]], Director, Chicago Bridge and Iron Company | ||
: [[contact::S. Dunn]], Manager, Chicago Bridge and Iron Company | : [[contact::S. Dunn]], Manager, Chicago Bridge and Iron Company | ||
: [[contact::F. Joy]], Employee Concerns Program | : [[contact::F. Joy]], Employee Concerns Program | ||
NRC | NRC | ||
: [[contact::G. McCoy]], Chief, Division of Reactor Projects (DRP), Reactor Projects Branch 5 (RPB5) | : [[contact::G. McCoy]], Chief, Division of Reactor Projects (DRP), Reactor Projects Branch 5 (RPB5) | ||
: [[contact::J. Reece]], Senior Resident Inspector | : [[contact::J. Reece]], Senior Resident Inspector | ||
: [[contact::E. Coffman]], Resident Inspector | : [[contact::E. Coffman]], Resident Inspector | ||
: [[contact::S. Ninh]], Senior Project Engineer, DRP, RPB5 | : [[contact::S. Ninh]], Senior Project Engineer, DRP, RPB5 | ||
: [[contact::B. Bishop]], Project Engineer, DRP, RPB5 | : [[contact::B. Bishop]], Project Engineer, DRP, RPB5 | ||
LIST OF ITEMS OPENED, CLOSED, AND REVIEWED | LIST OF ITEMS OPENED, CLOSED, AND REVIEWED | ||
Opened | Opened | ||
05000395/2013009-01 | 05000395/2013009-01 VIO Installation of a modification using a superseded | ||
version of a procedure | |||
Official Use Only | Official Use Only - OI Investigation Information | ||
- OI Investigation Information | SYNOPSIS | ||
This investigation was initiated by the | |||
: [[contact::U.S. Nuclear Regulatory Commission (NRC)]], Office of | : [[contact::U.S. Nuclear Regulatory Commission (NRC)]], Office of | ||
Investigations (OI), Region II (RII), on August 22, 2012, to determine whether a contract | Investigations (OI), Region II (RII), on August 22, 2012, to determine whether a contract | ||
electrician employed by Shaw Power Services | electrician employed by Shaw Power Services Division (Shaw) at South Carolina Electric and | ||
Gas Inc., (SCE&G), Virgil C. Summer Nuclear Station (Summer) willfully failed to follow | |||
applicable procedures and falsified a data sheet associated with safety related electrical supports. Additionally, OI:RII sought to determine whether another contract electrician and a lead electrician willfully directed the contract electrician to falsify the data sheet associated with | applicable procedures and falsified a data sheet associated with safety related electrical | ||
safety related electrical supports. | supports. Additionally, OI:RII sought to determine whether another contract electrician and a | ||
lead electrician willfully directed the contract electrician to falsify the data sheet associated with | |||
Based on the evidence developed during this investigation, OI:RII substantiated that a contract electrician at | safety related electrical supports. | ||
Based on the evidence developed during this investigation, OI:RII substantiated that a contract | |||
falsify the data sheet associated with safety related electrical supports. | electrician at V.C Summer deliberately failed to follow applicable procedures and falsified a data | ||
sheet associated with safety related electrical supports. Additionally, it was determined that | |||
another contract electrician and a lead electrician deliberately directed the contract electrician to | |||
falsify the data sheet associated with safety related electrical supports. | |||
Approved for release by Oscar DeMiranda | Approved for release by Oscar DeMiranda | ||
NOT FOR PUBLIC DISCLOSURE WITHOUT APPROVAL OF | |||
SPECIAL AGENT IN CHAGE, OFFICE OF INVESTIGATIONS, REGION 11 | |||
Official Use Only - OI Investigation Information | |||
Case No. 2-2012-041 Enclosure 3 | |||
}} | }} | ||
Latest revision as of 14:47, 20 December 2019
| ML13218B149 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 08/06/2013 |
| From: | Gerald Mccoy NRC/RGN-II/DRP/RPB5 |
| To: | Gatlin T South Carolina Electric & Gas Co |
| References | |
| EA-13-106 IR-13-009 | |
| Download: ML13218B149 (14) | |
Text
UNITED STATES ugust 6, 2013
SUBJECT:
VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1 - NRC INSPECTION REPORT NO. 05000395/2013009, NRC OFFICE OF INVESTIGATIONS REPORT 2-2012-041 AND NOTICE OF VIOLATION
Dear Mr. Gatlin:
On May 2, 2013, the Nuclear Regulatory Commissions (NRC) Office of Investigations completed an investigation (and in-office review) at Virgil C. Summer Nuclear Station Unit 1 to determine, in part, whether three contract employees deliberately failed to follow an applicable plant procedure and falsified a data sheet associated with safety-related electrical supports by backdating it to a date when the previous procedure (Rev. 8) was in effect. Based on the results of the investigation, the NRC concluded that these individuals deliberately failed to follow the electrical maintenance procedure EMP-391.003, Installation of Electrical Supports, Rev. 8, Change A, while implementing safety-related modification work associated with Work Order (WO) 120155-021 for Engineering Change Request (ECR) 50780. The results of the investigation were discussed on July 31, 2013 with you and other members of your staff. The enclosed inspection report presents the finding resulting from this investigation.
During this inspection, the NRC staff examined activities conducted under your license as they relate to public health, safety and the conditions of your license. Within these areas, the inspection consisted of selected examination of procedures and representative records, observations of activities, and interviews with personnel.
Based on a review of the facts and circumstances in this case, the NRC has determined that a Severity Level IV violation of NRC requirements occurred. The violation was evaluated in accordance with the NRC Enforcement Policy. The current Enforcement Policy is included on the NRCs Web site at http://www.nrc.gov/about-nrc/regulatory/enforcement/enfore.pol.html The violation is cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding it are described in detail in the subject inspection report. The violation is being cited in the Notice due to the deliberate misconduct aspects, the fact that of the three contract (two electricians and a lead electrician) employees failed to follow the plant procedural requirements, the lack of oversight of contract workers and inadequate corrective actions. You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response.
In light of the above, the NRC requests that your response address corrective actions that have or will be implemented to ensure adequate oversight of contract workers and provide additional details of training for all contract and SCE&G employees to prevent similar issues with procedural compliance in the future.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosures, and your response, will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy or proprietary, information so that it can be made available to the public without redaction.
Sincerely,
/RA/
Gerald J. McCoy, Chief Reactor Projects Branch 5 Division of Reactor Projects Docket No.: 50-395 License No.: NPF-12 cc w/encl: (See page 3)
Enclosures:
1. Notice of Violation 2. Inspection Report 05000395/2013009 w/Attachment: Supplemental Information 3. OI Synopsis, Investigation 2-2012-041
SUNSI REVIEW COMPLETE FORM 665 TTACHED OFFICE RII:DRP RII:DRP RII:DRP RII:DRP RII:DRP RII:DRP SIGNATURE Via email Via email Via email BDB /RA/ GJM /RA/ CFE /RA/
NAME JReece SNinh ECoffman BBishop GMcCoy CEvans DATE 07/25/2013 07/25/2013 07/25/2013 08/01/2013 08/04/2013 07/24/2013 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO
REGION II==
Docket No. 50-395 License No. NPF-12 Report No. 05000395/2013009 Licensee: South Carolina Electric & Gas (SCE&G) Company Facility: Virgil C. Summer Nuclear Station, Unit 1 Location: P.O. Box 88 Jenkinsville, SC 29065 Dates: June 24, 2013 through July 31, 2013 Inspectors: J. Reece, Senior Resident Inspector S. Ninh, Senior Project Engineer E. Coffman, Resident Inspector B. Bishop, Project Engineer Approved by: Gerald J. McCoy, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure 2
SUMMARY OF FINDINGS
IR 05000395/2013009; 06/24/2013 - 07/31/2013; Virgil C. Summer Nuclear Station Unit 1; Plant
Modifications The report covered an in-office review of NRC Office of Investigations (OI) Report No. 2-2010-029 by resident inspectors, a senior project engineer and a project engineer. One Severity Level IV violation was identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using IMC 0609, Significance Determination Process. Findings for which the Significance Determination Process does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process Revision 4, dated December 2006.
Cornerstone: Mitigating Systems
Severity Level IV: The licensee identified a violation of 10 CFR 50, Appendix B, Criterion V, instructions, procedures, or drawings, when it was determined that the contract employees failed to complete the electrical maintenance procedure EMP-391.003, Installation of Electrical Supports, Rev. 8, Change A, and falsified a data sheet associated with safety-related electrical supports by backdating it to a date when the previous (Rev.8) was in effect. The licensee took substantial disciplinary actions and entered the deficiency into the corrective action program for resolution as CR -12-03100.
The failure to follow procedure issue was a performance deficiency and it would be considered a minor under the reactor oversight process (ROP) because the quality control personnel subsequently inspected the pull box; the components had been installed properly and could have performed their safety-related function. A review of other work performed by these contract employees did not identify any other issues. This minor finding was not warranted to be documented in a quarterly inspection report in accordance with IMC 0612. However, with respect to deliberate misconduct aspects, failure to provide complete and accurate information regarding completion of the electrical maintenance procedure EMP-391.003, Installation of Electrical Supports, Rev. 8, Change A, was a performance deficiency. This issue was dispositioned using traditional enforcement due to the deliberate misconduct aspects of the performance deficiency. Furthermore, the failure to provide complete and accurate information has the potential to impact the NRCs ability to perform its regulatory function. These individuals deliberately violated the requirements in the revised electrical maintenance procedure EMP-391-003, Rev. 8, Change A, on July 16, 2013, in that they failed to follow the procedural requirements to obtain a quality control inspection after the holes were drilled in the concrete wall and then back-dated the procedure to June 29, 2012, to indicate that the work was performed prior to implementation of Rev. 8, Change A, which had an effective date of July 10, 2012. In accordance with the guidance in Section 6.1, Reactor Operations of the Enforcement Policy, this issue is a Severity Level IV violation because it involved information that the NRC required to be maintained by a licensee that was incomplete or inaccurate and of more than minor safety significance. No cross-cutting aspect was identified because this performance deficiency was dispositioned using traditional enforcement.
REPORT DETAILS
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
1R18 Plant Modifications
a. Inspection Scope
The inspectors reviewed the OI summary and transcripts of interviews conducted by OI investigators related to plant modifications conducted by the contract employees as well as 10 CFR 50 Appendix B requirements, license conditions, Technical Specifications, procedures and the UFSAR to determine if violations of regulatory requirements occurred.
b. Findings
Introduction:
The licensee identified a violation of 10 CFR 50, Appendix B, Criterion V, instructions, procedures, or drawings, when it was determined that the contract employees failed to complete an applicable plant procedure and falsified a data sheet associated with safety-related electrical supports by backdating it to a date when the previous (Rev.8) was in effect.
Description:
On July 16, 2012, three contract electricians installed pull box PB-CS189 using procedure EMP-391-003 Rev. 8 as part of Work Order (WO) 201155-021 -
Alternate Seal Injection Modification (ECR 50780). This procedure had been updated to Rev. 8, Change A, effective July 10, 2012. The electricians backdated the completed procedure to June 29, 2012 to indicate that the procedure had been performed while the previous revision (Rev. 8) was still in effect. Backdating the completed procedure enabled the electricians to complete the entire job without reaching a quality control hold point, which was required by the latest revision (Rev. 8, Change A). Consequently, the quality control inspection required by the effective version of the procedure was not performed between when the mounting holes were drilled and before the mounting bolts were installed.
This issue was immediately brought to the NRCs attention by the licensee and this issue was entered in the licensees corrective action program (CAP) as CR-12-03100. The licensee and contractor immediately initiated their investigation.
Region II OI investigation was initiated on August 22, 2012, to determine if a contract electrician at V. C. Summer Nuclear Station, Unit 1, employed by Shaw Industry, did willfully violate electrical maintenance procedure EMP-391.003, Installation of Electrical Supports, Rev. 8, Change A, while implementing safety-related modification work associated with Work Order (WO) 1201155-021 for Engineering Change Request (ECR)50780.
On May 2, 2013, Region II OI issued a report and concluded, based upon the evidence developed during the investigation, that a contract electrician at V.C. Summer Nuclear Station Unit 1, deliberately failed to follow an applicable procedure and falsified a data sheet associated with safety-related electrical supports by backdating it to a date when the previous revision (Rev. 8) was in effect. Additionally, the OI investigation determined that another contract electrician and a lead electrician deliberately directed the contract electrician to falsify the data sheet associated with safety-related electrical supports.
The inspectors reviewed the OI transcripts, licensees condition reports, and evidence obtained during the OI investigation. The inspectors agreed with the OIs conclusion that these individuals deliberately violated the requirements in the revised procedure EMP-391.003, Rev. 8, Change A, on July 16, 2013, in that they failed to follow the procedural requirements to obtain a quality control inspection after the holes were drilled and then back-dated the procedure to June 29, 2012, to indicate that the work was performed prior to implementation of Rev. 8, Change A, which had an effective date of July 10, 2012.
The licensee took disciplinary actions and entered the deficiency into the corrective action program for resolution as CR -12-03100. These three contract employees were subsequently terminated and the pertinent data was placed in Personnel Access Data System. However, the inspectors determined that corrective actions were not adequate to address oversight of contract workers and additional training of all contract employees and SCE&G employees to prevent similar issues with procedural compliance in the future.
Analysis:
The failure to follow procedure was a performance deficiency and it would be considered a minor under the reactor oversight process (ROP) because the quality control personnel subsequently inspected the pull box; the components had been installed properly and could have performed their safety-related function. A review of other work performed by these contract employees did not identify any other issues.
This minor finding was not warranted to be documented in a quarterly inspection report in accordance with IMC 0612. However, with respect to deliberate misconduct aspects, failure to provide complete and accurate information regarding completion of the electrical maintenance procedure EMP-391.003, Installation of Electrical Supports, Rev.
8, Change A, was a performance deficiency. This issue was dispositioned using traditional enforcement due to the deliberate misconduct aspects of the performance deficiency. Furthermore, the failure to provide complete and accurate information has the potential to impact the NRCs ability to perform its regulatory function. These individuals deliberately violated the requirements in the revised electrical maintenance procedure EMP-391-003, Rev. 8, Change A, on July 16, 2013, in that they failed to follow the procedural requirements to obtain a quality control inspection after the holes were drilled in a concrete wall and then back-dated the procedure to June 29, 2012, to indicate that the work was performed prior to implementation of Rev. 8, Change A, which had an effective date of July 10, 2012. In accordance with the guidance in Section 6.1, Reactor Operations of the Enforcement Policy, this issue is a Severity Level IV violation because it involved information that the NRC required to be maintained by a licensee that was incomplete or inaccurate and of more than minor safety significance. The violation is being cited in the Notice because the deliberate misconduct aspects, the
nature of the three contract (two electricians and a lead electrician) employees failure to follow the plant procedural requirements, lack of oversight contract works and inadequate corrective actions in accordance with the NRCs Enforcement Policy in effect at the time of the violation. No cross-cutting aspect was identified because this performance deficiency was dispositioned using traditional enforcement.
Enforcement:
10 CFR 50, Appendix B, Criterion V, states in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
EMP-391.003, Installation of Electrical Supports, Revision 8, Change A, is the procedure of record for implementation of safety-related modification work associated with Work Order 1201155-021, for Engineering Change Request 50780.
Contrary to the above, on July 16, 2012, three contract employees working for the licensee deliberately failed to accomplish activities affecting quality in accordance with applicable procedures. Specifically, the contract employees used a previous revision (Revision 8 instead of Revision 8, Change A) of procedure EMP-391.003, Installation of Electrical Supports, to implement safety-related modification work associated with Work Order 1201155-021, for Engineering Change Request 50780, and back-dated the procedure to June 29, 2012, to indicate that the work was performed prior to implementation of the latest revision (Rev. 8, Change A) to the procedure dated July 10, 2012. Additionally, these contract employees failed to ensure inspection of work activities by the licensees quality control personnel as required by EMP-391.003 Rev. 8, Change A.
The violation is being cited because of the deliberate aspects, and because the three contract employees deliberately violated an applicable procedure and falsified a data sheet associated with safety-related electrical supports by backdating it to a date when the previous (Rev.8) was in effect, in accordance with Section 6.1.d of the NRCs Enforcement Policy in effect at the time of the violation: VIO 05000395/2013009-01, Installation of a modification using a superseded version of a procedure.
4OA6 Meetings, Including Exit
Exit Meeting Summary
On July 31, 2013, the results of this inspection were presented to Mr. Gatlin, Site Vice-President, and other members of the licensee staff, who acknowledged the findings. No proprietary information was provided or examined during the inspection.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- T. Gatlin, Vice President, Nuclear Operations
- B. Thompson, Manager, Nuclear Licensing
- M. Browne, Manager, Quality Systems
- E. Lynch, Outage Management
- L. Bennett, Manager, Business Services
- F. Joy, Employee Concerns Program
NRC
- J. Reece, Senior Resident Inspector
- E. Coffman, Resident Inspector
LIST OF ITEMS OPENED, CLOSED, AND REVIEWED
Opened
05000395/2013009-01 VIO Installation of a modification using a superseded
version of a procedure
Official Use Only - OI Investigation Information
SYNOPSIS
This investigation was initiated by the
- U.S. Nuclear Regulatory Commission (NRC), Office of
Investigations (OI), Region II (RII), on August 22, 2012, to determine whether a contract
electrician employed by Shaw Power Services Division (Shaw) at South Carolina Electric and
Gas Inc., (SCE&G), Virgil C. Summer Nuclear Station (Summer) willfully failed to follow
applicable procedures and falsified a data sheet associated with safety related electrical
supports. Additionally, OI:RII sought to determine whether another contract electrician and a
lead electrician willfully directed the contract electrician to falsify the data sheet associated with
safety related electrical supports.
Based on the evidence developed during this investigation, OI:RII substantiated that a contract
electrician at V.C Summer deliberately failed to follow applicable procedures and falsified a data
sheet associated with safety related electrical supports. Additionally, it was determined that
another contract electrician and a lead electrician deliberately directed the contract electrician to
falsify the data sheet associated with safety related electrical supports.
Approved for release by Oscar DeMiranda
NOT FOR PUBLIC DISCLOSURE WITHOUT APPROVAL OF
SPECIAL AGENT IN CHAGE, OFFICE OF INVESTIGATIONS, REGION 11
Official Use Only - OI Investigation Information
Case No. 2-2012-041 Enclosure 3