ML13252A240

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 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. Gatlin Vice President, Nuclear Operations 803.345.4342 A SCANA COMPANY September 5, 2013 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

VIRGIL C. SUMMER NUCLEAR STATION (VCSNS), UNIT 1 DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 REPLY 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, dated August 6, 2013, "NRC Inspection Report No. 05000395/2013009, NRC Office of Investigations Report 2-2012-041 and Notice of Violation" South Carolina Electric & Gas Company (SCE&G) acknowledges the receipt of the notice of violation dated August 6, 2013, for a Severity Level IV violation concerning deliberate misconduct by contract employees, failure to follow plant procedural requirements by contract employees, 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 Gatlin TS/TDG/dr Attachment I - Reply to Notice of Violation EA-1 3-106 Attachment II - List of Regulatory Commitments c: K. B. Marsh M. N. Browne S. A. Byrne P. Ledbetter J. B. Archie NRC Resident Inspector N. S. Carns K. M. Sutton J. H. Hamilton NSRC J. W. Williams RTS (CR-13-03241)

W. M. Cherry File (815.01)

V. M. McCree PRSF (RC-13-0138)

R. E. Martin Virgil C.Summer Station

• Post Office Box 88. Jenkinsville, SC. 29065 . F (803) 941-9776

Document Control Desk Attachment I CR-13-03241 RC-1 3-0138 Page 1 of 3 ATTACHMENT I Reply to Notice of Violation EA-13-106 Following an NRC 01 investigation completed on May 2, 2013, and an in-office review, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy in effect at the time, the violation is listed below:

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, the procedure of record for implementation of safety-related modification work associated with Work Order 1201155-021, for Engineering Change Request 50780, provide instructions for installation of electrical equipment and conduits, and installation of toggle bolts in drywall for supports. The revision added a new QC inspection hold point referenced step 7.2.4 (Cleaned holes) between the 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 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 licensee's quality control personnel as required by EMP-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 of contract employee activities. More specifically, station and contract management did not ensure appropriate procedures were followed.

(2) The corrective steps that have been taken and the results achieved Immediate corrective actions were taken to verify field installation conditions met

Document Control Desk Attachment I CR-13-03241 RC-13-0138 Page 2 of 3 procedural requirements. There were no examples of substandard work found and post inspections were satisfactory. The three contract employees involved in this event received 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 of following procedures and the importance of providing accurate documentation. The department stand-down conducted at the time of the event was not adequately documented in the original condition report. The second stand-down was conducted on July 22, 2013, by contractor management and senior station management for current contract employees.

An apparent cause evaluation (ACE) was performed to identify the cause for the procedure 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, and

d. 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 station procedures. The following improvements have been observed since this management change:

a. Increased field observations and improvement in the quality of observation documentation,

b. Hiring an additional staff member to provide oversight of observations and corrective actions, and

c. A closer working relationship between the contract company and the station.

(3) The corrective steps that will be taken The following corrective actions have been documented in the corrective action program to prevent reoccurrence of this event:

a. Station personnel are to complete required computer based training for ProcedureUse and Adherence (PU&A) to provide additional emphasis on the procedural requirements for the station.

b. Supplemental workforce targeted observations on PU&A will be conducted with a focus on place keeping and ensuring documentation is

Document Control Desk Attachment I CR-13-03241 RC-13-0138 Page 3 of 3 maintained current. The observations will be conducted over a six month period with a total count goal of 20 PU&A observations each month.

c. A communication to station personnel will be developed on the recent industry trend documented in the NRC Information Notice 2013 Willful Misconduct/Record Falsificationand Nuclear Safety Culture.

d. Accountability training will be developed and presented to supervisors and above. The training will include case study examples of willful or careless disregard behaviors not in compliance with expectations established in 10CFR50.9 - Completeness and accuracy of information and 10CFR 50.5 - Deliberatemisconduct.

e. 10CFR50.9 - Completeness and accuracy of information and 10CFR 50.5 - Deliberatemisconduct and the potential consequences for failure to comply will be reinforced annually to station personnel.

(4) The date when full compliance will be achieved Completion of corrective actions that will be taken are outlined in Attachment II of this submittal. Full compliance will be achieved by June 30, 2014.

Document Control Desk Attachment II CR-13-03241 RC-13-0138 Page 1 of 1 ATTACHMENT II List of Regulatory Commitments The following table identifies those actions committed to by SCE&G, Virgil C. Summer Nuclear Station 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 these commitments to Mr. Bruce L Thompson, Manager, Nuclear Licensing, (803) 931-5042.

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

Station personnel are to complete required computer based training for Procedure Use and Adherence (PU&A) to provide additional emphasis September 30, 2013 on the procedural requirements for the station.

Supplemental workforce targeted observations on PU&A will be conducted with a focus on place keeping and ensuring documentation is maintained current. The observations will be conducted over a six June 30, 2014 month period with a total count goal of 20 PU&A observations each month.

A communication to station personnel will be developed on the recent industry trend documented in the NRC Information Notice 2013 October 31, 2013 Willful Misconduct/Record Falsificationand Nuclear Safety Culture.

Accountability training will be developed and presented to supervisors and above. The training will include case study examples of willful or careless disregard behaviors not in compliance with expectations June 30, 2014 established in 10CFR50.9 - Completeness and accuracy of information and 10CFR 50.5 - Deliberatemisconduct.

10CFR50.9 - Completeness and accuracy of information and 1 OCFR 50.5 - Deliberatemisconduct and the potential consequences for June 30, 2014 failure to comply will be reinforced annually to station personnel.