IR 05000395/2013009

Virgil C. Summer Nuclear Station, Unit 1 - Reply to Notice of Violation, EA-13-106, IR 05000395-13-009

ML13252A240
Person / Time
Site:	Summer
Issue date:	09/05/2013
From:	Gatlin T D South Carolina Electric & Gas Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-106, IR-13-009
Download: ML13252A240 (5)

Text

Thomas D. GatlinVice President, Nuclear Operations 803.345.4342 A SCANA COMPANYSeptember 5, 2013U. S. Nuclear Regulatory Commission ATTN: Document Control DeskWashington, DC 20555-0001

Dear Sir / Madam:

Subject:

VIRGIL C. SUMMER NUCLEAR STATION (VCSNS),

UNIT 1DOCKET NO. 50-395OPERATING LICENSE NO. NPF-12REPLY TO NOTICE OF VIOLATION EA-13-106 NRC INSPECTION REPORT NO. 05000395/2013009 Reference:

Gerald J. McCoy, NRC, letter to Thomas D. Gatlin, SCE&G, datedAugust 6, 2013, "NRC Inspection Report No. 05000395/2013009, NRC Office ofInvestigations Report 2-2012-041 and Notice of Violation" South Carolina Electric

& Gas Company (SCE&G) acknowledges the receipt of the notice ofviolation dated August 6, 2013, for a Severity Level IV violation concerning deliberate misconduct by contract employees, failure to follow plant procedural requirements by contractemployees, lack of oversight of contract workers, and inadequate corrective actions.SCE&G has reviewed the description of the subject violation and will not contest the violation.

As requested, a reply to the notice of violation is provided in Attachment I.This letter contains NRC commitments as described in Attachment II of this submittal.

If you have any questions, please contact Mr. Bruce L. Thompson at (803) 931-5042.

Very truly yours,Thomas D.To GatlinTS/TDG/dr Attachment I -Reply to Notice of Violation EA-1 3-106Attachment II -List of Regulatory Commitments c: K. B. MarshS. A. ByrneJ. B. ArchieN. S. CarnsJ. H. HamiltonJ. W. WilliamsW. M. CherryV. M. McCreeR. E. MartinM. N. BrowneP. Ledbetter NRC Resident Inspector K. M. SuttonNSRCRTS (CR-13-03241)

File (815.01)PRSF (RC-13-0138)

Virgil C. Summer Station * Post Office Box 88. Jenkinsville, SC .29065 .F (803) 941-9776 Document Control DeskAttachment ICR-13-03241 RC-1 3-0138Page 1 of 3ATTACHMENT IReply to Notice of Violation EA-13-106 Following an NRC 01 investigation completed on May 2, 2013, and an in-office review, aviolation of NRC requirements was identified.

In accordance with the NRC Enforcement Policyin effect at the time, the violation is listed below:10 CFR 50, Appendix B, Criterion V, states in part, that activities affecting quality shall beprescribed by documented instructions, procedures, or drawings of a type appropriate to thecircumstances and shall be accomplished in accordance with these instructions, procedures, ordrawings.

EMP-391.003,

"Installation of Electrical Supports,"

Revision 8, Change A, the procedure ofrecord for implementation of safety-related modification work associated with Work Order1201155-021, for Engineering Change Request 50780, provide instructions for installation ofelectrical equipment and conduits, and installation of toggle bolts in drywall for supports.

Therevision added a new QC inspection hold point referenced step 7.2.4 (Cleaned holes) betweenthe steps when the holes are drilled to the necessary depth and the placement of the Hilti bolts.Contrary to the above, on July 16, 2012, three contract employees working for the licenseedeliberately failed to accomplish activities affecting quality in accordance with applicable procedures.

Specifically, the contract employees used a previous revision (Revision 8 insteadof Revision 8, Change A) of procedure EMP-391.003,

"Installation of Electrical Supports",

toimplement safety-related modification work associated with Work Order 1201155-021, forEngineering Change Request 50780, and back-dated the procedure to June 29, 2012, toindicate 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 failedto ensure inspection of work activities by the licensee's quality control personnel as required byEMP-391.003, Rev. 8, Change A.This is a Severity Level IV violation (Section 6.1, Reactor Operations).

(1) Reason for the violation The reason for the violation was determined to be insufficient management oversight ofcontract employee activities.

More specifically, station and contract management didnot ensure appropriate procedures were followed.

(2) The corrective steps that have been taken and the results achievedImmediate corrective actions were taken to verify field installation conditions met Document Control DeskAttachment ICR-13-03241 RC-13-0138 Page 2 of 3procedural requirements.

There were no examples of substandard work found and postinspections were satisfactory.

The three contract employees involved in this eventreceived substantial disciplinary action from their employer.

All three workers'Personnel Access Data System records were updated with appropriate derogatory information.

Two department stand-downs were performed to address the event, the importance offollowing procedures and the importance of providing accurate documentation.

Thedepartment stand-down conducted at the time of the event was not adequately documented in the original condition report. The second stand-down was conducted onJuly 22, 2013, by contractor management and senior station management for currentcontract employees.

An apparent cause evaluation (ACE) was performed to identify the cause for theprocedure violation.

The ACE identified four apparent causes for this event:a. Procedure non-compliance by the workers,b. A production mentality versus a healthy regard for quality in performance of procedures, c. Two workers and their lead chose to falsify the documents, andd. Supervision failed to convey a safety-conscious work environment.

Corrective actions that resulted from the ACE are discussed below in Item Number 3.The contract company installed a new management team in the first quarter of 2013.This team focused on performing work activities in strict compliance with stationprocedures.

The following improvements have been observed since this management change:a. Increased field observations and improvement in the quality ofobservation documentation, b. Hiring an additional staff member to provide oversight of observations and corrective actions, andc. A closer working relationship between the contract company and thestation.(3) The corrective steps that will be takenThe following corrective actions have been documented in the corrective actionprogram to prevent reoccurrence of this event:a. Station personnel are to complete required computer based training forProcedure Use and Adherence (PU&A) to provide additional emphasison the procedural requirements for the station.b. Supplemental workforce targeted observations on PU&A will beconducted with a focus on place keeping and ensuring documentation is Document Control DeskAttachment ICR-13-03241 RC-13-0138 Page 3 of 3maintained current.

The observations will be conducted over a six monthperiod with a total count goal of 20 PU&A observations each month.c. A communication to station personnel will be developed on the recentindustry trend documented in the NRC Information Notice 2013-15 -Willful Misconduct/Record Falsification and Nuclear Safety Culture.d. Accountability training will be developed and presented to supervisors and above. The training will include case study examples of willful orcareless disregard behaviors not in compliance with expectations established in 10CFR50.9

-Completeness and accuracy of information and 1OCFR 50.5 -Deliberate misconduct.

e. 1OCFR50.9

-Completeness and accuracy of information and 10CFR50.5 -Deliberate misconduct and the potential consequences for failureto comply will be reinforced annually to station personnel.

(4) The date when full compliance will be achievedCompletion of corrective actions that will be taken are outlined in Attachment II of thissubmittal.

Full compliance will be achieved by June 30, 2014.

Document Control DeskAttachment IICR-13-03241 RC-13-0138 Page 1 of 1ATTACHMENT IIList of Regulatory Commitments The following table identifies those actions committed to by SCE&G, Virgil C. Summer NuclearStation in this document.

Any other statements in this submittal are provided for information purposes and are not considered to be commitments.

Please direct questions regarding thesecommitments to Mr. Bruce L Thompson, Manager, Nuclear Licensing, (803) 931-5042.

-ITM.NT , K DU~C,. i ',.""',..

.: .,Station personnel are to complete required computer based training forProcedure Use and Adherence (PU&A) to provide additional emphasis September 30, 2013on the procedural requirements for the station.Supplemental workforce targeted observations on PU&A will beconducted with a focus on place keeping and ensuring documentation is maintained current.

The observations will be conducted over a six June 30, 2014month period with a total count goal of 20 PU&A observations eachmonth.A communication to station personnel will be developed on the recentindustry trend documented in the NRC Information Notice 2013-15 -October 31, 2013Willful Misconduct/Record Falsification and Nuclear Safety Culture.Accountability training will be developed and presented to supervisors and above. The training will include case study examples of willful orcareless disregard behaviors not in compliance with expectations June 30, 2014established in 1OCFR50.9

-Completeness and accuracy of information and 1OCFR 50.5 -Deliberate misconduct.

1 OCFR50.9

-Completeness and accuracy of information and 1 OCFR50.5 -Deliberate misconduct and the potential consequences for June 30, 2014failure to comply will be reinforced annually to station personnel.