ML20198T487
| ML20198T487 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 04/17/1997 |
| From: | Garner L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20198T318 | List: |
| References | |
| 50-395-96-99, NUDOCS 9711170009 | |
| Download: ML20198T487 (4) | |
See also: IR 05000395/1996099
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April 17. 1997
HEMORANDUM 10:
L. A. Reyes, Regional Administrato
THROUGH:
J. R. Johnson. Director
Division of Reactor Projects (DRP)
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G. A Belisle. Chief
ReactorProjectsBranch5.ORP
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FROM:
L. W. Garner. Project Engineer. DRP N d . 2 %
SUBJECT:
V. C. SUMMER SYSTEMATIC ASSESSMENT OF l.lCENSEE PERFORMANCE
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(SALP) PLANT SUPPORT AREA
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The purpose of this memorandum is to provide you another perspective and
additional background information concerning the SALP rating in the Plant
Sunort Area.
In addition. I am requesting that the draft RESPONSE TO
C011ENTS ON V. C. SUMMER SYSTEMATIC ASSESSMENT Of LICENSEE PERFORMANCE (SALP)
REPORT INSPECTION REPDRT NO. 50-395/96 99" be modified to reflect that
V. C. Summer's performance in the subfunctional areas of radiological
controls emergency preparedness, and security were superior and that the
improvements in the later part of the SALP cycle. in the fire protection area
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be acknowledged.
Although the information provided in the licensee's SALP response, dated
February 12.1997.'brovided some new information to support a suxrior rating.
the above recommendation is not based upon this new informatio.1 aut upon
information that was available to the SALP Board members prior to the issuance
of the SALP report.
In other words. I believe that the original determination
by the SALP Board was in error. The SALP Board votes were a 2 by the DRP
Deputy Division Director and the NRR representative and a 1 by the DRS
Division Director who was responsible for the majority of the inspection
activities in the Plant Support Area,
Radioloaical Controh:
In radiological controls, a challenge was identified concerning control of
contaminated materials. The basis was one cited violation and one Non Cited
Violation (NCV).
The violation involved one floor smear by an NRC inspector that was
approximately 15 times above limits and was taken immediately outside a
radiological boundary. Tne licensee initially denied the violation based upon
a procedural interpretation that was unacceptable to Region II. After
rejection of their denial, ou October 4.1996, the General Manager had a call
with the ORS Division Director (staff members included the inspector. myself,
etc.) to discuss their perspective on why it should not have been a cited
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L. A, Reyes
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violation.
During the discussion, the NRC agreed with the licensee that this
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was an isolated case, that it did not indicate that a weakness in their Health
Physics program effectiveness existed, and no further corrective actions over
and above cleaning up and re-smearing the area, that was performed the date of
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discovery. was necessary to address the violation.
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The other loss of contamination control issue was listed as an unresolved item
at-the time of the SALP Board. Before the SALP report was issued, this item
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- was identified as an NCV. This item has no relationshi) to the other event.
except that it involved contamination where it did not
>elong.
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The second contamination control issue concerned a situation where an employee
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alarmed the portal monitor at the protected area egress station. The employee
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was taking home some scrap material that he had picked up from a clean trash
container. The trash container was located outside the Radiological
Controlled Area (RCA) adjacent to the radwaste facility fence.
The licensee
was unable to determine how this material got through the radwaste process and
outside the RCA. The root cause analysis identified several ways in which
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their radweste facility controls could be strengthen. Corrective actions were
take' 3 address these items.
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No other as]ects of this subfunctional area were found to have declined since
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the last SA.P period.
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Basing a decline in performance in this subfunctional area on a violation
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which the NRC acknowledged as being an isolated case and an unrelated event
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for which the NRC determined that the corrective action warranted the item
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being classified as an NCV was inappropriate.
Emeroenev Preoaredness:
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In the emergency preparedness subfunctional area, challenges were identified
for developing challenging exercise scenarios and maintaining emergency siren
system status.
Failure to develo) challenging exercise scenarios occurred in the first six
months of the SAL) period and was considered as an exercise weakness. The
issue involved a scenario in which the classification of the event was simple
(an earthquake) and similar scenarios had been trained on by the exercise crew
in the preceding six weeks. The exercise weakness was "saecific training of
the SCR (Simulator Control Room) staff on the initiating EAL (Emergency Action
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Level) for the exercise prevented an objective demonstration of + heir ability
to evaluate plant conditions and classify the simulated emergency.
As noted
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here. the exercise weakness was associated with the Interim Emerge ey Director
-(Shift Supervisor) and did not apply to classifications by Technic 1 Support
Center or Emergency Operations Facility personnel.
In addition, the exercise
weakness was for a failure to demonstrate an ability. not that a problem in
classification actually existed.
Clearly, proper classification of an
emergency by the Shift Supervisor .is very important since that is what
triggers the activation of the Emergency Plan.
However in this instance.
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L. A. Reyes
there was no indication that the NRC was concerned about the ability of the
Shift Supervisors to actually classify an event, just that it had notl
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demonstrated.
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remediated. 2) the NRC made no attempt to determine if the problem was more
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than a dr111 concern. 3) the licensee was never informed
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NRC followup inspection activities were routine.
The other identified challenge in the emergency preparedness subfunctional
The inspector
area was for failure to classify an event in a timely manner.
~ determined that the item was an NCV based upon initiative of the emergency
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preparsdness staff and the corrective action taken by management.
In both radiological controls and emergency preparedness, one of the two
examples cited in the SALP letter to support challenges in these subfunctio
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For an NCV to have such significance that it
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areas involved an NCV.
constitutes one half of the examples to support a Jerformance challenge in aT
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SALP letter is inconsistent with what an NCV 1s.
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to encourage and acknowledge licensee's efforts in identifying and correcting
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problems. To use isolated, single NCVs in such a mann
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sends the wrong message to the licensee.
Security;
The SALP report describes implementation of physical security as "i
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outstanding manner."
performance should be described as superior.
Fire Protection:
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During most of the SALP period there were human performance problem
implementing the fire protection program.
were generally described in inspection reports as license
Although improving or declining trends are no longer
the SALP period.
acknowledging the
typically identified as part of the SALP category rating,he SALP period should
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actions taken and improvements seen in the last part of t
encourage the licensee to continue improvements in this subfunctional area.
Other notable informaticn:
During the SALP cycle none of the Plant Performance Reviews (PPRs) ident
Thus, the SALP Board's
that the Plant Support Area was less than a 1. determination was
as part of the PPR process.
In addition.-inspectors, who performed inspections in the Plant Suoport Area.
generally either expressed surprise or disagreement w
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rating.
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L. A. Reyes
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into the SALP Board deliberations, this information was (or is) most likely
not knNn to the SALP Board meters.
I would be glad to meet with you to discuss this memorandum.
Docket No.: 50 395
License No.: NPF-12
cc:
F. Reirhart
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