ML20059A369

Ack Receipt of SALP Rept 50-395/90-11 & Forwards Comments on Rept

ML20059A369
Person / Time
Site:	Summer
Issue date:	07/30/1990
From:	Bradham O SOUTH CAROLINA ELECTRIC & GAS CO.
To:	Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 9008230007
Download: ML20059A369 (3)

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h Car Ina Electr6c & Gee Company ' S. ed l-Jenkinsydie. SC 29065 : Nuctor operatens ~42

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-Mr. S. D. Ebneter U. S.: Nuclear Regulatory Commission Region ll, Suite 2900

-101 MariettalStreet, NW t Atlanta', Georgia 30323- .

Subject:

Virgil C. Summer Nuclear Station  ;

Docket No. 50/395 Operating License No. NPF-12 Systcsatic Assessment of Licensee Performance

• l (NRCinspectionReportNo.90-11)

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Dear Mr. Ebneter:

j South Carolina Electric & Gas Company (SCE&G)~ acknowledges receipt of.the Systematic' Assessment of L1censee Performance (SALP) Report No. IE 90-11

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dated June. 19, 1990, for. Virgil.C. Summer Nuclear Station and appreciates the opportunity to discuss the content of the report in the July 10, 1990, meeting,

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l. Attached is SCE&G's specific coments on the report. If you would like to discuss these items in more detail, please call usfat your convenience.

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, Very truly yours,  ;

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0. S. Bradham >

ARK /OSB:cc H Attachments c: 0. W. Dixon, Jr./T. C. Nichols, Jr.  ;

.E. C. Roberts R. V. Tanner I; General Managers '

J. J. Hayes, Jr.

L- C. A. Price o, R. J. Waselus J. R. Proper K. E. Nodland J. C. Snelson NRC Resident Inspector J. B. Knotts, Jr.

NSRC 1 NPCF RTS (IE 901100)

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Attachment to NRC Region II Letter

' July 30 1990-Page l'of 2.

• VIRGIL C. SUMMER h!4 LEAR STATION SALP REPORT COMMENTS PLANT OPERATIONS During this SALP evaluation period, improvement has been demonstrated in the area of plant operations. In regard to the large number of equipment failures

. experienced during this review period, management attention will continue to be focused to improve overall plant. performance.

RADIOLOGICAL CONTROLS In regard to source term reduction, considerable effort was. expended during

. Refuel V to identify and eliminate leaking fuel assemblies. This effort has been i

. effective.in that the source term for the current cycle is significantly below that of the previous cycle. We will continue in our efforts to reduce the source term. Also, our efforts in contamination control have historicelly been very good. We intend for these efforts to continue. .,

One comment in the report with which we disagree is .in regard to a perception I that our chemistry department lacked aggressiveness in quantifying the resin intrusion event and providing timely recommendations (first paragraph, page 9).

We believe that our actions, based on what was known at the time, were both

-appropriate and aggressive. However, as a result of this event, numerous improvements in the operations and chemistry areas were made.

There is one item of clarification in regard to a statement located in the third '

paragraph on page 7 concerning recognition of dose reduction measures via

" replacement of valves containing stellite." Please be aware that we have  ?

replaced some valves in the plant containing stellite, but we do not have.an ongoing program to replace all such valves. ,

i MAINTENANCE / SURVEILLANCE In this area of evaluation, we are keeping abreast of industry initiatives as part of-our effort for continued improvement. Recent organization changes places additional focus on maintenance activities. We also recognize that we have a potential procedure compliance problem, and we are taking action to address this concern. This is one of the initiatives of our Nuclear Excellence (NUCLEX) effort.

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Attachment to NRC Region 11 Letter >

' July 30, 1990 1 Page 2 of 2_ *

EMERGENCY PREPARE 0 NESS lhe rating.of "2" in this category is one in which we are .1ot satisfied. We beliese that we have improved significantly in the area of emergency preparedness as a result of a number of initiatives undertaken which go beyond that required by the regulations. These include a self assessment, additional drills, and the addition of one person to the emergency preparedness organization. It appears that the' evaluation was based on a-very limited review of our. emergency .

preparedness activities consisting of one inspection, which occurred early in the ,

-evaluation period, and one drill. We were also not aware that the one weakness- '

identified in the drill was as significant as the SALP Report indicates (third paragraph,~page12). We intend to continue a proactive approach in the area of r emergency preparedness.

SECURITY We have made significant improvement in the area of security during this evaluation period. We will r.ot become complacent with these accomplishments and intend to maintain this high level of performance. '

ENGINEERING / TECHNICAL SUPPORT in the area of engineering and technical support, we recognize that there is room for improvement. However, in general, we do not agree with some of the wording in the report in regard to " inconsistent engineering involvement in routine plant <

activities and post maintenance tecting." We are not content with a "2" rating in this category and we will continue to work to improve this rating to a "1". 1 The contents of the SALP Report in this area are extremely detailed and positive on very significant and broad based issues and initiatives. On the other hand, the negative comments are directed at a number of specific examples where an ,

individual failed to perform. This imbalance between positive and negative ,

performance and the absence of any recommendations for improvements from the board perpetuates some uncertainty about the basis for the rating in this area.

There is one correction to the SALP Report. In the last paragraph on page 16, i reference is made to plant specific simulator certification in 1990.

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The certification is actually scheduled for 1991.

SAFETY ASSESSMENT /0VALITY VERIFICATION We have taken a proactive posture in the areas addressed in this category and have seen improvements accordingly. We are pleased to see recognition in the SALP Report of the initiatives and expect there to be continued improvements as a result of these actions. In regard to the need to improve the quality of our Licensing submittals, we intend to work more closely with our NSSS vendor in the future. We have also strengthened our plant staff in order to improve vendor interface and quality of Licensing submittals.

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