Text

Ack Receipt of Response to Comments on Plant SALP Rept 50-395/96-99 Issued on 961206.Evaluation,conclusions & Revised SALP Pages Encl
	ML20151J395
Person / Time
Site:	Summer
Issue date:	07/30/1997
From:	Reyes L; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Gabe Taylor; SOUTH CAROLINA ELECTRIC & GAS CO.
References
	50-395-96-99, NUDOCS 9708050145
	Download: ML20151J395 (13)
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July 30, 1997

1

South Carolina Electric & Gas Company

ATTN: Mr. Gary J. Taylor l

Vice President, Nuclear Operations

Virgil C. Summer Nuclear Station

P. O. Box 88 l

Jenkinsville, SC 29065

SUBJECT: RESPONSE TO COMMENTS ON V. C. SUMMER SYSTEMATIC ASSESSMENT

OF LICENSEE PERFORMANCE (SALP) REPORT INSPECTION REPORT

NO. 50 395/96 99 !

l

Dear Mr. Taylor: l

Thank you for your response dated February 12, 1997, and for your presentation

in the NRC, Region II office on March 18, 1997, which provided your comments

and views on the V. C. Summer SALP Report which was issued on December 6, !

1996. -Based on your input, the SALP Board reconvened on March 26, 1997, and

reviewed the information that you provided.

In addition, the NRC also conducted an independent review of the SALP Report. l

After considerable deliberation, I have decided that, for the reasons

presented in Enclosure 1 several changes to the SALP Report were appropriate.

No change to the Plant Support htegory Rating was required; however, the

original rcport was modified afte review by the independent panel. The

associated revised SALP pages are included as Enclosure 2. ;

Should you have any questions concerning this matter, please contact

Mr. A. Belisle at (404) 562-4550.

l

Sincerely,

Original signed by Luis A. Reyes

Luis A. Reyes ,

Regional Administrator

Docket No. 50 395

License No. NPF 12

Enclosures: 1. Evaluation and Conclusions

2. Revised SALP Pages

l cc w/encls: See page 2

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9700050145 970730

i PDR ADOCK 05000395

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l SCE&G 2

i '

i CC W/enCls:

l R. J. White ,

Nuclear Coordinator (Mail Code 802) !

S.C. Public Service Authority '

c/o Virgil C. Summer Nuclear Station !

P. O. Box 88

Jenkinsville, SC 29065 ;

J. B. Knotts, Jr., Esq. '

,

Winston and Strawn !

1400 L Street, NW r

Washington, D. C. 20005 3502

l

!

Chairman

Fairfield County Council

P. O. Drawer 60 >

Winnsboro, SC 29180 ,

,

Virgil R. Autry, Director

Radioactive Waste Management

Bureau of Solid and Hazardous

Waste Management ;

S. C. Department of Health

, and Environmental Control

2600 Bull Street

Columbia, SC 29201 ;

i

R. M. Fowlkes Manager !

Operations (Mail Code 303) 1

South Carolina Electric & Gas Company -

Virgil C. Summer Nuclear Station

P. O. Box 88

Jenkinsville, SC 29065

April Rice, Manager

Nuclear Licensing & Operating

Ex wrience (Mail Code 830)

Sout1 Carolina Electric & Gas Company l

Virgil C. Summer Nuclear Station i

P. O. Box 88 l

Jenkinsville, SC 29065

l

INP0

c Distribution w/encis: 1

l Chairman Jackson i

! Commissioner Diaz '

l Commissioner McGaffigan !

Commissioner Dicus

.

L. J. Callan, ED0

'

!

l Distribution w/encls continued: See page 3 1

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SCE&G 3

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Distribution w/encls: Continued

l H. L. Thompson, Jr., DEDR

N. Dudley, Regional Coordinator, ED0

S. Collins, NRR

A. Galante CIO

L J. Funches, CFO

j B. Boger, NRR

! F. Miraglia, NRR

W. Hehl, RI ~ l

G. Grant, RIII

,

P. Gwynn, RIV ;

K. Perkins, WCF0 '

J. Lieberman, OE

A. Hodgdon, 0GC 1

B. Keeling, CPA/CA :

D. Gamberoni. NRR (2 copies)

l A. Johnson, NRR

L. Garner, RII

P. Ho) kins, RII

,

l

l R. Gi>bs, RII

P. Fillion. RII

l D. Jones, RII

W. Stansberry, RII I

R. Aiello, RII l

K. Clark, RII, PA0 l

'

DRS and DNHS Branch Chiefs

PUBLIC

l Federal Emergency Management Agency

l ATTN: Mr. William McSwain, Chief

l Technical Hazards Branch

3003 Chamblee Tucker Road

Chamblee, GA 30341

l NRC Resident Inspector

! U.S. Nuclear Regulatory Commission

l Route 1. Box 64

Jenkinsville SC 29065 *See previous concurrence - attached

0FFICE Rff:DRP Rff:DPS R!f ORS NpC-NRR Rff DPP Rff:DRS

SIGNAftRE * * * * * *

NAME ABelisle alt KBarr Pfredrickson TReichart JJohnson JJaudon

! DATE 07 / / 97 07 / / 97 07 / / 97 07 / / 97 07 / / 97 07 / / 97

COPY 7 YES NO YES NO YES NO YES NO YES N0 YES NO

OFFICE RIf:0RA

S!GNATURE

NAME BMal t

DATE / / 97 07 / / 97 07 / / 97 07 / / 97 07 / / 97 07 / / 97

COPY 7 / YES NO YES NO YES NO YES NO YES NO YES N0

OttICIAL RLCORD COPY DOCUMENT NAMi G:\50M5 ALP.F15

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SCE&G- 3

. Distribution w/encls: Continued-

F. Miraglia, NRR

W. Hehl, RI :

G. Grant, RIII ,

P. Gwynn, RIV ;

K. Perkins, WCF0 i

J. Lieberman, OE

l

A. Hodgdon. 0GC i

B. Keeling, CPA/CA :

D. Gamberoni, NRR (2 copies) l

F. Reinhart, NRR :

A. Johnson, NRR

L. Garner, RII -

P. Ho) kins, RII !

R. Gi)bs, RII !

P. Fillion, RII

D. Jones, RII ,

W. Stansberry, RII '

R. Aiello, RII I

K. Clark, RII, PA0

DRS and DNMS Branch Chiefs

PUBLIC

Federal Emergency Managemen Agency

ATTN: Mr. John C. Heard, Jr , Chief

Technical Hazards Br nch

3003 Chamblee-Tucker Road

Chamblee, GA 30341

NRC Resident Inspector

U.S. Nuclear Regulatory Commission

Route 1. Box 64

i Jenkinsville SC 29065

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J /r f

DFFICE Rif:DRP f d 11 t Rif MS n NRC:liRR/ ris RIf DRP / Rif:DRS - 'IcW.

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1/ 07 / / 97

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NRC'S EVALUATIONS AND CONCLUSIONS ON SOUTH CAROLINA ELECTRIC AND GAS COMPANY'S

(SCE&G) RESPONSE TO THE V. C. SUMMER SALP REPORT

!

By letter dated February 12, 1997. SCE&G provided comments on the V. C. Summer

SALP Re> ort which was issued on December 6, 1996. The comments involved five 1

areas tlat collectively comprise the Plant Support SALP functional area. The j

specific comments from SCE&G are in quotes.

1 NRC Evaluation of Comments on Radioloaical Control Imorovements

l

l "In the area of Radiological Controls, V. C. Summer has realized

significant reductions in dose, plant effluents, and radwaste generation

since the last SALP period. Radioactive material control performance

and the number of NRC violations has remained constant when compared to

'

the last assessment period. Improvements in the area have been made

while at the same time drastically lowering our threshold for problem ,

reporting. Radiological Controls improvements far outweigh any issues 1

identified during this SALP period as supported by the followirg:" '

l

SCE&G NRC

" Annual exposure has been reduced The lower radiation exposure was )

from the 3revious assessment period,

'

considered and recognized by the SALP

even if t1e dose from the 1994 steam Board.

generator replacement is excluded."

" Outage dose in Refuel 9 was our

lowest in history and 9th lowest

refueling dose ever for PWRs."

" Effectively reduced plant effluents, The doses from effluents were

when compared to last SALP period." recognized by the NRC as being

significantly below regulatory l

limits. l

" Greatly reduced the amount of Reduction of radiological radwaste !

contaminated trash generated and the amount of contaminated area

annually. " were considered by the SALP Board

" Contaminated surface area within the

radiation control area (RCA) is

maintained less than 2%." ;

"During refueling outages, the This information was discussed at the I

r containment building is maintained SALP Board, j

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accessible in street clothes." )

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"V. C. Summer Nuclear Station [VCSNS] No information was available to i

is recognized within the industry by confirm or deny this statement. !

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INP0 and our peers for our !

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contamination control." !

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! ENCLOSURE 1

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"NRC Inspection Reports have also The inspection history was considered

included remarks complimentary of by the SALP Board.

contamination control. (94 15, 95 03,

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l & 95 19)" ,

"The number of NRC violations in SALP assessments are not a direct

Radiological Controls is consistent function of the number of violations.

, with the previous SALP period." Enforcement history was considered by

the SALP Board. ,

" Incidents of radioactive material The information regarding -

l discovered outside of the RCA has contamination events during this ,

l remained constant when compared to assessment period was considered by i

! the last SALP period. There has been the SALP Board; the write up was

j no instance of loss of contamination changed to reflect the results of the

l control from the protected area." independent review.

"A review of Region II SALP history The SALP Board reviewed V. C.

indicates other plants with recent Summer's

incidents of contamination control with NRC'sperformance

criteria andinnot

accordance

in

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issues who subsequently received a comparison with other sites. l

j superior rating in Plant Support."

Changes were made to the SALP Resort in the Radiological Control area. The 1

l statement involving the site ALARA program was modified to read:

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The site ALARA program was effective in maintaining low site collective

dose.

The statements involving contamination control were modified to read:

Personnel contamination control measures were generally successful

throughout the period. There were some examples where control of

contamination was lost, in that, contamination and contaminated material

were found outside control boundaries.

2. NRC Evaluation of Comments on Emeraency Preparedness

" Emergency Preparedness at V. C. Summer has made imp,'cvements in the

areas of Emergency Response Organization (ERO) staffing, computerized

information exchange & status, accountability of non essential

personnel, and siren availability. We have continued to receive

positive feedback due to our close working relationship with state and

local governments within our EPZ, and our annual evaluated exercise

results showed im3rovements. Our continuous improvements in light of

the lowered threslold for problem reporting, discussed earlier, far

outweigh any issues raised during the SALP period as supported by the

following:" l

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SCE&G NRC

"The ERO was placed in a four team This is new information. It was not i

,

rotation, this has allowed for more independently verified during the ;

l effective table top drills, improved SALP period. '

i accountability and improved ;

teamwork."

" Developed a computerized Emergency

l Information System (EIS) to enhance

! information exchange between the

L facilities."

l " Installation of the biometrics hand This is new information. It was not

geometry system has decreased the independently verified in Emergency ;

i time required to conduct Preparedness during the SALP period. l

l accountability." Credit was noted for the biometric ,

l hand geometry system in the security l

l area.

! "VCSNS has been recognized by the This was not inspected during the

i state for taking the lead role with SALP period. )

l South Carolina utilities in the

! effort to replace the State's

! emergency radiac and dosimetry

l inventory. This action was in

! response to notification that FEMA

l would no longer fund the Radiological

l Defense Program."

" Siren performance has made steady Management support for the Early

improvement compared to the last SALP Warning System (EWS) and telephone

, period. In 1996 VCSNS achieved an system was considered by the SALP

!

unprecedented average operability of Board,

98.10% with a complete cycle test

with 99.06% of sirens sounding."

" Training drills are conducted with The fundamental initiator for each of l

l interim Emergency Directors and the training drills for the four l

licensed operators during each months preceding the exercise, which i

! licensed operator training cycle. is the evaluated event, appeared to

These drills have been diverse and be the same as for each exercise. A i

challenging to ensure each shift's drill history with a spectrum of

emergency classification ability." initiators, coupled with an exercise

,

with a unique initiator, would have

demonstrated a challenge to the

integrated emergency response

organization. ,

'

Changes were made to the SALP Report in the Emergency Preparedness area. The

. following statements were deleted:

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However, actual response indicated some decline in performance.

.. and in maintaining awareness of siren system status in order to make ;

timely reports. *

Several improvements' were made to .... to make them more reliable.

The statement involving the Alert and Notification System was modified to

read:

l The Alert and Notification System sirens had been effectively ;

i maintained. l

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No changes were appropriate for issues involving the four team notation, the !

computerized information system, and taking the lead note with South Carolina. -

! 3. NRC Evaluation of Comments on Fire Protection

"The number of violations and negative comments contained in inspection

reports has significantly decreased this SALP period despite the fact

that we have replaced the fire detection system, rerouted sprinkler

systems, and rewritten our fire implementation procedures. An NRC

l ins xction, conducted in October to assess performance for the entire

l SAL) assessment period, was overall complimentary with only minor

!

discrepancies noted. Our new fire protection team approach is committed

to continuous improverrient and problem solving to meet rising

expectations and maintain a superior level of performance as evidenced

by:"

SCE&G NRC

! "The number of violations and The inspection and enforcement '

negative comments contained in performance was considered by the

inspection reports has significantly SALP Board.

decreased this SALP period."

" Replaced the fire detection computer The installation of this system was

system with a new enhanced state of, in process at the time of the fire

, the art Simplex fire detection protection inspection in October

system." 1996. The estimated installation

completion was scheduled for late

1996. This new system was considered

by the SALP Board.

" Performed a job task analysis for This item was not inspected.

, personnel performing fire protection

I duties."

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" Formed a fire protection team This item was considered by the

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(consisting of a System Engineer, Special Inspection Branch and SALP

l Design Engineer, Test Specialist I&C Board.

Technician, Fire Protection

Supervisor, a Licensing

Representative and other plant

,

! representatives as deemed necessary)

! which meets monthly to discuss fire ,

!

protection issues."

" Changed personnel resmnsible for This item was considered by the

oversight of the Fire )rotection Special Inspection Branch and SALP

l program." Board. ;

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l " Revised the Fire Protection This item was considered by the !

'

! Procedures to improve quality and Special Inspection Branch and SALP

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efficiency. " Board.

" Conducted a performance based This item was not inspected. I

, engineering evaluation of the fire

protection program and revised the

testing program to incorporate the

evaluation findings. This evaluation

allowed the extension of some testing

frequencies based on historical )

equipment performance and system !

reliability."

Changes were made to the SALP Report in the fire protection area to reflect

noted improvement in performance during the last six months of the assessment

period. The statement involving Fire Protection program implementation was l

modified to read:

The Fire Protection program implementation was satisfactory early in the

assessment period and improved to good by the end of this period.

This statement addresses the new fire detection system.

The statement involving organization and staffing changes was modified M

read:

l Organization and staffing changes were made late in the period in an

! effort to improve performance and some improvement was evident.

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This statement addresses the fire protection team and changes in personnel

j oversight.

The statement involving housekeeping was modified to read:

{

! Housekeeping, in general, was very good,

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A review of fire protection procedures identified that the procedures were i

adequate. No change was appropriate to the SALP Report for procedure issues J

related to the job task analysis and performance based engineering evaluation. '

4. NRC Evaluation of Comments on Chemistry i

" Performance within the chemistry area continues to be maintained at a

superior level and SCE&G continues to make program enhancements as

illustrated by the following:"

l

SCE&G NRC

" Developed a program to incorporate a No independent NRC verification was i

secondary plant auxiliary system conducted on the program to i

corrosion monitoring system." incorporate a secondary plant l

auxiliary system corrosion monitoring :

" Achieved the INPO Chemistry Index system.

' Performance Goal of <1.20 for the ;

year." l

i "Het a challenging goal to maintain ,

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Lithium and Boron concentrations to l

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l help ensure low exposure rates during

l the refueling outage and during the

operating cycle."

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" Developed a program to convert to 3-

methhox)ropylamine (MPA) secondary l

plant caemistry control."

No changes were made to the SALP report in the chemistry area. :

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5. NRC Evaluation of Comments on Security

" Superior performance has been maintained within the area of Security, I

and SCE&G continues to make program enhancements as evidenced by the

following:"

SCE&G NRC

" Installed the biometrics hand This was recognized by the SALP l

geometry system." Board.

" Installed the vehicle barrier This was not inspected during the i

system." SALP period. I

" Upgraded Derimeter Intrusion This was recognized by the SALP l

Detection System." Board. !

I

i " Converted to the I Star badging This was recognized by the SALP i

, system." Board. l

! " Developed program to incorporate This was not inspected during the I

NEI's Personnel Access Data System." SALP period.

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No changes were made to the SALP report in the security area. The statement. l

"the protected area access control equipment was reliable and effective." :

includes inspection of biometrics, perimeter intrusion and badging.

Conclusion: [

!

Based on our review of your response and the information provided by you (

during the March 18, 1997 meeting, we have concluded that, based on the

inspections that were prformed during the SALP period, your attention and !

l involvement were normally well focused and resulted in a good level of safety

performance. In addition, your arograms and procedures normally provided the ;

necessary control of activities aut some deficiencies existed, i

The SALP Board recommended no changes to the Category rating.

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pa44 UNITED STATES

9'o NUCLEAR REGULATORY COMMISSION

g

[ n REGION 11

l 5 j ATLANTA FEDERAL CENTER

" 61 FORSYTH STREET. SW, SUITE 23T85

! k ATLANTA, GEORGIA 30303

! *****

South Carolina Electric & Gas Comoany

ATTN: Mr.' Gary J. Taylor

Vice President, Nuclear Operations

Virgil C. Summer Nuclear Station

P. O. Box 88

Jenkinsville, SC 29065

SUBJECT: SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP)

(INSPECTION REPORT NO. 50-395/96 99)

Dear Mr. Taylor:

The U.S. Nuclear Regulatory Commission (NRC) has completed the Systematic

Assessment of Licensee Performance (SALP) for the Summer Nuclear Plant.

The facility was assessed in four functional areas for the period of

January 29, 1995, through October 26, 1996. The results of the assessment are

documented in the enclosed SALP report which will be discussed with you

at a public meeting at the Summer site on December 16, 1996, at 1:00 p.m.

Summer Nuclear Plant performance was assessed in four functional areas: Plant

Operations Maintenance Engineering, and Plant Support. Performance in

Operations and Maintenance remained superior. Performance in Engineering

improved and is now considered superior. Performance in Plant Support was

good.

Plant Operations superior performance was characterized by stable power

operations, strong operator knowledge and ability, and effective management

self-assessment activities. Superior performance in Maintenance was sustained

by strong management support, a firm commitment to inspection and testing

programs and well trained and knowledgeable personnel. Engineering achieved

superior performance due to an improved design control process, strong

maintenance of the licensing basis, and effective support to other

organizations. Plant Support performance was generally good with some

examples where deficiencies existed.

Initiatives that contributed to superior performance in the majority of

functional areas were strong management support for benchmarking and self-

assessment activities including auditing and rotations of personnel. This

included both staff and management in order to improve station self-assessment

and quality verification activities.

In accordance with Section 2.790 of the NRC's " Rules of Practice," a copy of

this letter and its enclosure will be placed in the NRC Public Document Room.

I

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j Enclosure 2

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V. PLANT SUPPORT

This functional area addresses all activities related to the plant

support function, including radiological controls, radioactive

effluents, chemistry, emergency preparedness, security, fire protection,

and housekeeping.

The radiological control program was effective in protecting the health

and safety of plant workers and members of the public. The onsite

radiation )rotection program controlled internal and external radiation

exposures 3elow regulatory limits. The site ALARA program was effective

in maintaining low site collective dose. Personr.el contamination

control measures were generally successful throughout the period. There

were some examples where control of contamination was lost, in that,

contamination and contaminated material were found outside control

boundaries.

Offsite radiation exposure to members of the public wns substantially l

below regulatory limits. The environmental monitoring program confirmed i

effective effluent controls in that only trace amounts of radioactivity

were detected in the environs of the plant.

1

Effective chemistry programs were implemented to inhibit degradation due l

'

to corrosion of components in both primary and secondary systems. The

program for handling, packaging and transport of radioactive materials l

functioned very well. l

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The emergency preparedness program was generally effective in !

maintaining site readiness to respond to emergencies. A challenge was .

noted in developing challenging emergency exercise scenarios. The Alert )

and Notification System sirens had been effectively maintained. '

Preparations for a hurricane minimized the risks and potential damage to

plant facilities from rain and high winds.

1

The licensea continued to implement and support the Physical Security I

Plan, procedures and associated programs in an outstanding manner. The i

security program was strong and well managed. The protected area access

control equipment was reliable and effective. Station management was !

active in identifying and correcting potential problems.

The Fire Protection program implementation was satisfactory early in the

assessment period and improved to good by the end of this period. Early

in the period, a number of human aerformance errors existed, but a

marked improvement was noted in t1e implementation of the program at the

end of the period. Maintenance and testing of fire protection systems

were good with a significant reduction in the backlog of fire protection

related maintenance items. Organization and staffing changes were made

late in the assessment and im) roved performance was evident. Quality

assurance audits were thoroug1 and corrective actions were timely.

Housekeeping, in general, was very good.

The Plant Support area is rated Category 2.

Enclosure 2

ML20151J395

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