ML20198T510

Submits Three Potential Candidates for Differing Professional View on Plant SALP

ML20198T510
Person / Time
Site:	Summer
Issue date:	04/29/1997
From:	Garner L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Mallett B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20198T318	List: ML20198T316 ML20198T348 ML20198T370 ML20198T384 ML20198T418 ML20198T425 ML20198T470 ML20198T487 ML20198T510 ML20199B678
References
NUDOCS 9711170015
Download: ML20198T510 (24)

Text

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. I From: Larry Garner,RIT To: ATP1.BSM1 Pdwd1Lds fLI .

Date: 4/29/9712:29pm

Subject:

Summer Plant Support DPV Good Aftamoon,' [

Three potential candidates for the DPV on the Summer SALP are: ,

1. Paul Karmon

2. Walt Rogers

3. Bill Holland.- _;

I have spoken with each of the individuals and they are willing to serve on the panel if their schedules permit.-If you need additional names, please contact me. Thanks. i

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V. C. SUMMER (VCS) CHRONOLOGY 12/09/96 SALP PRESENTATION - LICENSEE EXPRESSES DISMAY AT PLANT '

SUPPORT AREA RATING. RA INVITES VCS PERSONNEL TO REGION TO ASSURE THAT Ril PERSONNEL HAVE A' L AVAILABLE 4

INFORMATION.

DISCUSSIONS INVITING VCS TO Ril 02/12/97 VCC RESPONDS TO SALP [

02/27/57 MEETING CONDUCTED IN Ril TO REVIEW VCS RESPONSE -

0:$/18/97 VCS INTO Ril TO GIVE PRESENTATION

~

03/26/97 6AbP BOARD MEETS TO REEVALUATE SUMMER RESPONSE .

04/09/97 NRC RESPONSE GENERATED TO THE \tCS SALP RESPONSE 04/17/97 LETTER RECEIVED FROM L. GARNER TO L. REYES ON VCS SALP  !

HE CONTENDS: r r

ORIGINAL DETERMINATION BY SALP BOARD IN ERROR RADCON BASIS, ONE CITED VIO (SL IV) AND ONE NCV

- f J BASIS, DEVELOP CHALLENGING EXERCISE SCENARIOS (EXERCISE WEAKNESS) AND MAINTAINING LMERGENCY SIREN SYSTEM STATUS ,

i

- SECURITY, PERFORMANCE SHOULD BE SUPERIOR VICE i OUTSTANDING FIRE PROTECTION, ACKNOWLEDGE ACTIONS TAKEN AND IMPROVFMENTS SEEN PPR DURING CYCLE DID NOT IDENTIFY DECLINING PERFORMANCE

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NUCLEAR RE T REGloN 11 Y COMMISSION i

h AT NTA dlA IN I

South Carolina Electric & Gas Company ATTN: Mr. Gary J. Taylor '

'Vice President, Nuclear Operations Virgil C. Summer Nuclear Station ,

s P. O. Box 88 '

Jenkinsville, SC 29065

SUBJECT:

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

OF LICENSEE PERFORMANCE (SALP) REPORT INSPECTTON REPORT NO. 50 395/96 99

Dear Mr. Taylor:

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.

26, 1997, and reviewed Basedonyourinput[theSALPBoardreconvenedonMarch the information tha you provided. After considerable deliberation, the SALP poord determined that, for the reasons presented in the enclosure, an adjustment of the SALP score in the Plant Support area is not warranted.

Should you have any questions concerning this matter, please contact us.

Sincerely, Luis A. Reyes

-Regional Administrator Docket No. 50 395 License No. NPF 12 Erclosure: Evaluation and Conclusions cc w/ encl:

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 cc w/ enc 1 continued: .See pa9e 2 1

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I SCE&G' 2 4

4 cc w/ enc 1: Continued J. B. Knotts. Jr., Esq.

l -- Winston and Strawn 1400 L Street, NW ,

Washington, D. C. 20005 3502  :

Chairman . '

Fairfield County Council

-P. O. Drawer 60 Winnsboro, SC 29180 t

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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 '

R. H. Fowlkes. Hanager

, Operations (Mail Code 303) i South Carolina Electric & Gas Company ~

Virgil C. Summer Nuclear Station '

P. O. Box 88  !

Jenkinsv111e, SC 29065 April Rice, Manager Nuclear Licensing & 0)erating Ex>erience (Mail Code 830)

Sout1 Carolina Electric & Gas Company Virgil C. Summer Nuclear Station P. O. Box 88 -

Jenkinsv111e. SC 29065 t

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, 1 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 l SALP Re> ort which was issued on Decembar 6, 1996. The comments ir.,olved five areas t1at collectively comarise the Plant Support SALP functional area. The specific comments from SCE&G are in quotes.

1. - NRC Evaluation of Comments on Radiolonical Control Imorovements "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 identified during this SALP period as supported by the following:"

KE&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 limits.

" Greatly reduced the amount of Reduction of radiological radwaste contaminated trash generated and the amount of contaminated area annually." were conCdered by the SALP Board

" Contaminated surface area within the t radiation control area (RCA) is maintained less than 2%."

"During refueling outages. the This information was discussed at the containment building is maintained SALP Board. .

accessible in street clothes."

'V. C. Summer Nuclear Station [VCSNS] No information was available to is recognized within the industry by confirm or deny this statement.

INP0 and our peers for our contamination control."

ENCLOSURE

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, "NRC Inspection Rewrts have also The inspection history was considered included remarks comol by the SALD Board, contaminationcontroi.imentaryof (94 15, 95 03,

& 95 19)"

"The numbt.r of NRC violations in SALP scores are not a direct function Radiological Controls is consistent of the number of violations. ,

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

" Incidents of radioactive material The NRC staff had not been made aware  !

discovered cutside of the RCA has of the loss of control of radioactive i remained constant when compared to material or contamination during the the last SALP period. There has been previous SALP period; however, the no instance of loss of contamination information regarding contamination control from the protected area." events during this assessment period was considered by the Board.

"A review of Region II SALP history Each plant is considered indicates other plants with recent independently.

incidents of contamination control ,

issues who subsequently received a superior rating in Plcnt Support."

2. NRC Evaluation of Comments on Emeroency Preparedness

" Emergency Preparedness at V. C. Summer has made improvements 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 imarovements. Our continuous improvements in light of the lowered thresiold for problem reporting, discussed earlier, far outweigh any issues raised duri.1g the SALP period as supported by the following:"

SCf&G NRC "The ERO was placed in a four team This is new information. It was not rotation, this has allowed for more independently verified during the effective table top drills, improved SALP period.

accountability and improved teamwork."

" Developed a computerized Emergency _

Information System (EIS) to enhance information exchange between the facilities."

ENCLOSURE

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

geometry system has decreased the independently verified during the time required to conduct SALP period.

, accountability."  ;

"VCSNS has been recognized by the This was not inspected during the state for taking the lead role with SALP period.

. South Carolina utilities in the effort to replace the State's ,

emergency radiac and dosimetry '

inventory. This action was in response to notification that FEMA would no longer fund the F<adiological Defense Program."

" Siren performance has made steady Management support for the Early improvement comrared 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 wich The fundamental initiator for each of interim Emergency Directors and the training drills for the four licensed operators during each months preceding the exercise, which licensed operator training cycle. is the evaluated event, appeared to These drills have been diverse and be the same as for each exercise. A challengino to ensure each shift's drill history with a saectrum of emergency classification ability." initiators coupled wit 1 an exercise with a unique initiator would have been a demonstrative challenge of. the

' integrated emergency response organization.

3. NROJ aluation of Comments on Fire Protection _

"The number of violations and negative con.ments 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 ins)ection, conducted in October to assess performance for the entire SAL) 6.ssessment period, was overall complimentary with only minor discrepancies noted. Our new fire protection team approach is committed to continuous improvement and problem solving to meet raising expectations and maintain a superior level of performance as evidenced I by:"

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- S.QEhQ 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 i 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 i 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 duties."

" Formed a fire protection team This item was considered by the (consisting of a System Engineer, Special Inspection Branch and SALP Design Engineer, Test ;;>ecialist 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 res mnsible for This item was considered by the oversight of the Fire 'rotection Special Inspection Branch and SALP program." Board.

" Revised the Fire Protection This item was considered by the Procedures to improve quality and Special Inspection Branch and SAL?

efficiency." Board.

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

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4. NRC Evaluation of Comments on Chemistry

" 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:"

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SCE&G EG .  !

• Developed a program to-incorporate a - No independent NRC verification was secondary p'-int auxiliary system conducted on the program to corrosion monitoring system." incorporate a secondary plant  ;

auxiliary system corrosion monitoring '

" Achieved the INP0 Chemistry Index system.

Performance Goal of <1.20 for the year."  ;

i "Het a challenging goal to mail.tain Lithium and Boron concentrations to help ensure low exposure rates during the refueling outa -

operating cycle." ge and during the ,

" Developed a program to convert to 3- ~

methhox)ropylamine (MPA) secondary plant clemistry control."

5. NRC Evaluation of Conaents on Security

" Superior performance has been maintained within the area of Security, and SCE&G continues to make program enhancements as evidenced by the following:"

SCE&G NRC l

" Installed.the biometrics hand This was recognized by the SALP geometry system." Detrd.

" Installed the vehicle barrier Th'; was not inspected during the system." SALP period.

" Upgraded Perimeter Intrusion This was recognized by the SALP Detectinr. System." Board.

" Converted to the I Star badging This was recognized by the SALP system." Board. ,

" Developed program to incorpcrate This was not inspected during the NEI's Personnel Access Data System." SALP period.

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Conclusion:

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• Performance within the Plant Support area hos improved when compared to the i last SALP period and has been sustained at a :superier. level of performance." l Based on our review of your response and the information provided by ou during the March 18, 1997 meeting, we have concluded that, based on t e

- inspections that were performed during the SALP period, that your attention and involvement were normally well focused and resulted in a good level of-safety performance. In addition, your programs' and procedures normally i provided the necessary control of activities but deficiencies existed in the areas of control of contaminated material,- developing challenging emergency exercise scenarios, and in maintaining awareness of siren system status, i

Additionally, there were human error deficiencies in the implementation of the fire protection program,.and housekeeping in some areas needed improvement.

The SALP Board recommeded no changes in the Category 2 rating, i

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• e V. C, SUMMER Plant Suonort 01/29/95-10/26/96 Radiolocical Controls STRENGTES The radiological control program performed ver/ well in protecting the health and safety of the plant workers and members of the public. The onsite radiation protection program was effective in controlling internal and external radiation exposures below regulatory limits. Site AMRA measures have been Nery successful throughout the monitoring period. Use of Total Risk Assessment reduced the use of respirators.

Otfsite exposures to members of the public were limited by maintaining radionuclide concentrations in liquid and gaseous effluents at a small percentage of their regulatory limits. The licensee had implemented and maintained an effective program to monitor and control liquid and gaseous effluents. The projected offsite doses resulting from those effluents were well within the limits specified in requirements.

The effectiveness of the effluent controls was confirmed by the results of the environmental monitoring program in that l only trace amounts of activity were detected in the samples collected from the environs of the plant resulting in Nery low doses to the public.

Chemistry control programs for monitoring primary and secondary water quality were implemented in accordance with the Technical Specifications requirements. The licensee maintained an effective overall chemistry program to inhibit degradation due to corrosion / erosion of components of both the primary and secondary systems.

The licensee has implemented an effective prtgram for handling, packaging ann transport of radioactive materials.

Shipments of radioactive materials were properly prepared for transport.

The licensee has also been successful in reducing the amount of plant area contaminated, minimizing the generation of low level radioactive waste and reducing the number of personnel contamination events.

1. The licensee was effectively controlling external and internal exposures consistent with the requirements and well within the regulatory limits. (95-03 results)

(95-14 Pg. 8) (95-19 Pgs. 8,9,10) (96-07 Pg. 21).

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2. Use of Total Risk Assessment reduced the number of re.spirators. (95-03 Pg. 11) (D5-14 Pg. 8)

3. The licensee's ALARA program was effective in maintaining site collective. doses low.

During the assessment period the licensee's exposure for refueling cycle 9 was 89 person-Rem.

(96-07 Pg. 21)

The licensee's three vear averace for 1993, 1994 and 1995 was good at 212 person rem. (96-07 Pg.

21)

There appears to be good management support and involvement in the ALARA program. (95-03 Pg. 7)

(26-07 Pg. 21)

4. Good radiological controls and radiation protection staff involvement in planning work in radiological areas were observed throughout the assessment period.

(95-03 Pg. 9) (96-07 Pg. 20) 4.1 Very late in the SALP Period (10/25/96) the licensee identified a person exiting the plant through the security egress point who alarmed the radiation portal monitor. HP surveys found a small particle (2,000 net epm on his pants and material in the tote bag with 5,000 net cpm fixed and 1000 dpm smearable in addition two additional contaminated items were also identified.

(Summary discussion with RPM L.A. Blue on 10/29/96)

5. The licensee had a good program in place to monitor radiological effluents. Doses from liquid and gaseous effluents were significantly less th.r1 their respective limits. (95-19 Pgs. 1,2) (96-07 Pgs. 18,19)

6. The licensee had a good program to detect the effects of radiological effluents due to plant operations.

Plant operations had caused minimum impact to the environment and did not represent a significant radiation exposure of members of the public. (96-07 Pgs. 17,18)

7. The licensee had an effective primary and secondary chemistry program. (95-19 Pgs. 3,4) (96-07 Pg. 19)

8. The radioactive waste transportation program was effective. (96-07 Pg. 18)

9. The licensee has been effective in the reduction of:

Plant Area Contaminated (95-19 Pg. 7)

Personnel Contamination Events (95-03 Pg. 15)

Radioloaical Controls CHALLENGES Maintaining an aggressive Radiation Protection Program and avoiding compliancy.

1. Violation: Example 2: Failure to Follow Procedure to frisk equipment out of RCA. (96-02-01)

2. Violation: Failure to Post and Control Contaminated Areas.

(96-07-09) See 4.1 above for possible additional example.

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Emercency Precaredness .

-i STRENGTES ,

During the NRC' observed graded exercise (July 13, 1995), the licensee demonstrated emergency response capability to protect the health and safety of facility personnel and the general public.

One exercise weakness was observed during the graded  ;

exercise. The weakness involved objectively demonstrating-the ability to evaluate plant conditions and to correctly ,

classify the simulated emergency.

During the period the licensee made several improvements in .

-Alert and Notification System (Sirens) to make them more reliable.

The licensee was proactive in the area of hurricane preparedness. Licensee preparation for Hurricane Fran was conducted to minimize the risk and potential damage to plant facilities from rain and potential high winds. Management

. fully supported all emergency preparations.

1. Licensee performance during drills and exercises were

( generally good. During graded exercise July 13, 1995, l the licensee was successful in demonstrating that

! emergency facilities were' maintained in a state of l readiness and the emergency response organization, with I the exception of one exercise weakness, was adequately prepared to effectively respond and cope with the postulated emergency. (95-11 Pgs. Results, 2)

2. Exercise strengths included notifications to the State and local organizations, and the availability of simulator data on the Safety Parameter Display System

, (SPDS) and Emergency Response Data System (ERDS). (95-L 11 Pgs. Results, 4)

3. The licensee was proactive in the area of hurricane preparedness. Licensee preparation for Hurricane Fran was conducted to minimize the risk and potential damage to plant facilities from rain and potential high' winds. Management fully supported all emergency.

preparations. .(96-09 Pg. 14)

4. Strong management support and upgrades to the Early Warning Siren System and telephone system. (95-04 Pgs.

4, 5, Results) 9

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Emercency Precaredness CHALLENGES

1. Correcting Exercise Weakness. (95-11 Pgs. Results, 2)

2. Correct self-identified errors in Emergency Plan Procedures that were identified in Quality Assurance report. (95-04 Pgs. Results, 3,4)

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• PHYSICAL SECURITY ,

SALP OUTLINE

. FOR V. C. SUMMER NUCLEAR STATION

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The_ licensee continued to implement and support the Physical' Security _ plan.

_ procedures _ and associated programs in an outstanding manner. The organizatio-

- and administration of the security arogram reflects-the outstanding professionalism and_ dedication of t1e security management and security force. .

N protected area access control equipment was modern, reliable and-efficiently effective. Plant and security management was proactive in recogniziag and correcting potential problems.

PROGRM STRENGTHS Ine whole security program was strong and well managed. Outstanding. areas were:

. Effectiveness of Ma agement Controls and Support.

. Protected Area Detection-and Access Controls.

. Vital Area Access Controls of Personnel and Vehicles.

. Alarm Stations and Communications Equipment.

. Testing. Maintenance and Comoensatory Measures.

. Security Training and Qualifications.

Audits and Corrective Action, PROGRAM WEAKNESS

.- Analysis and Trending of Security Events not Fully Utilized to Specifically Identify Root Causes.

CHALLENGES

. Preparation for the OSRE visit during the first quarter of 1997.

, Maintaining the dedication and professionalism of the security force and security management in view of the continuing organizational re-engineering.

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10/31/96 F SUMMER 1996 SALP-FIRE PROTECTION.

The Fire Protection Program was satisfactory implemented during this SALP cycle with a marked imorovement during the last part of the cycle. -.

Organization and administration of the fire protection program was good. The fire protection and prevention procedures, including controls provided for ignition sources, transient combustibles and housekeeping, were good.

mplementation. in general, was good. except for a few instances of weak control for the fire watch program. Maintenance, testing and perfomance of the fire protection systems and equipment ware satisfactory and should impros following completion of the installation of the new station fire alam systen to replace the existing obsolete and unreliable system. The fire brigade

- training program and performance of the fire brigade during drills were .

satisfactory. - Quality assurance audits of the fire protection program were -

thorough and corrective action for identified problems was timely.

PROGRAM STRENGTHS a

• Fire prevention implementing procedures were well written and imolementation. especially housekeeping was generally good. (IF 96-11)

• Appropriate design documentation had been completed to resolve tt Thermo-Lag fire uarrler issue in all plant areas by late 1997.

(IR 96-11)

• Replacement of the original obsolete and unreliable fire alarm system with a new station fire alarm system is a major fire protection program enhancement. (IR 96-11)

OA audits of the Fire Protection Program were through and corrective action appropriate and timely.- (IR 95-11)

PROGRAM PROBLEMS Adequate compensatory actions were not taken upon loss of a local fire detection panel .for the Emergency Diesel Generator Building.

4 (VIO 95-13-01)

Failure to follow the test procedures during testing of the site fire alarm system resulting in placing one detector out of servic without establishing the required hourly fire watch. (VIO 95 04)-

• Licensee identified two modifications made to the component cooling water system which resulted in Appenoix R violations.

(URI 96-01-02 and NCV 96-08-02))

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Licensee identificc potential problems related to spurious valve 4

operation for several Appendix R related valves in the event of a

, fire in the main control room. (URI IR 96-11 and EN 31222)

Resident inspector identified weaknesses in the fire brigade response to a fire drill on January 18. 1996. (IR 96-01. page 9)

Fire watch failed tn report a Turbine Building fire to the control room. (NCV 96-07-03)

Repetitive failures were identified by the licensee of the 8-hour Appendix R lighti,:g units not meeting the required illumination duration test. (IR 96-11) b

l;& 'A T cDECISI T '

ISEMI-ANNUAL PLANT PERFORMANCE ASSESSMENT

-(V. C. SUMMER).

1 Assessment Period:-_ -September 95 to March 96 j - SALP Period 01/29/95 through-10/26/96 Dates of SALP- 02/28/93 to-01/28/95 Dates of SALP 09/01/91to'02/27/93

' Last SALP Ratirig: Previous SALP Rating: '

OPS- -1 = OPS 1 MAINT 1 RADCON- 1-ENG 2 MAINT/SURV 1 Declining PS 1 EP 2-Improving SEC 1-ETS 2 SA/QV 1

- 1. Peiformance Overview The plant h'as operated well since a shutdown in March 1995 to perform seal maintenance on the A RCP. Routine operations, maintenance and surveillance activities are generally performed well. However, some human performance type problems have been idantified such as a lack of a questioning attitude by operations personnel and several instances of failure to follow procedures. Engineering.is assuming the role of the architect engineer and outside skill bas been brought in to oversee engineering activities. Self assessment has identified more issues since the identification threshold has been lowered, increased

-management attention-has been focused in planning for the April-refueling outage.

II. Functional Areas Assessments Operations i A. -Assessment:

The overall performance of Operations has been effective in assuring -

continued safe operation of the facility with no operator induced transients. The unit has been at power since May. 24, 1995.

B. Basis:

. Operations management has reviewed the overall performance-of each operations shifts and shuffled crew composition to balance shifts.

Each shift has attended team development training.

- -- Plant management is lowering the threshold for reporting problems and events. -A new problem reporting mechanism is being prepared to-further enhance the' problem' reporting system.

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- 'An effort is being made to manage operator work arounds.

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- On two occasions,- operatnrs did not promptly investigate abnonnal indications and locked in alarms.

C. Future Inspections:

. Perform core resident procedures and licensed operator requalification 1 l program evaluation. , ,

Maintenance A. Assessment:

There were no equipment failures which caused power reductions during the last six months. Safety system performance has besn good and met industry averages. The problems experienced with personnel errors and inadequate procedures do not indicate an overall adverse trend. However, ,

maintenance personnel does not appear to be using the STAR program.

Overall, maintenance performance remains good, i

8. Basis: -

1. Recent maintenance-issues from the Site Integrated Matrix.

Personnel do not appear to be using the STAR program.

Recent Personnel Errors:

- 10/10/95 Personnel failed to remove 2 Rad monitors from 4

service in accordance with a modification.

- 07/26/95 Non-safety CCW pump stator was installed in a safety related pump

- 08/21/95 The licensee failed to control two jumper wires installed in RVLIS

'Recent Inadequate Procedure's: .

- 08/13/35 The licensee failed to incorporate newly-installed CCW valves in the appropriate surveillance procedure

- 07/26/95 The procedure for stroke timing valves did not require timing from the time the-signal was initiated until valve completed its stroke

2. Safety Equipment Performance (Availability %) has been good.

Actual- Industry Average High Press SI 99.4% 99.7 - 99.2%

Aux-Feedwater 99.5% 99.6 - 99.1%

Emergency AC Power 99.3% 99.1 - 98.6%

3. No equipment failures have caused power reduction in last 6 months.

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3 C. Future Inspections:

Assist the resident inspector with the ' normal resident inspector maintenance and surveillance _ program, focus the inspection on procedure adequacy. Conduct the ISI inspection. ,

Enoineerina A .. Assessment: -

Engineering performance at V.C. Summer has generally been good.

However,--there appears to be an adverse trend developing based-on an increase in the number of issues. There was one engineering issue identified during the 3rd quarter of 196 . There were three issues identified during the 4th quarter of 1995. Most of the issues were attributed to inadequate design. Additionally, there have been 2 engineering issues identified in January 1996 (IR 96-01) which were-attributed to inadequate design. Many of the Gilbert design functions are now being brought to the site. These design issues will be evaluated during inspection this PPR pariod.

B. Easis:

The basis for the above assessment was primarily because of the increase in the number engineering issues during the 4th quarter of 1995 as compared to the 3rd quarter of 1995. There were no significant plant i events or unplanned changes in power levels during this PPR period which were attributable to engineering deficiencies.

Design issues include:

Testing of ventilation system charcoal.

An. incorrect modification from 1990 that resulted in a potential breech of the service water pump house.

Incorrect classification of close cooling system for Appendix R.

- A jumper installed in a radiation monitor combined class IE and

, non-1E circuits.

There were inconsistences noted in 50.59 reviews.

Some control room instruments are operating out of the " Normal" band.

C. Future Inspections:

Inspection Reason Outage Flux tilt, modifications Engineering Finish core program

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- A. Assessment:

One Region based Radiation Protection (RP) inspection was conducted.

during this PPR perind. Effluent monitors were found to be properly 1

calibrated and functionin'g. Water Chemistry controls were consistent with.EPRI, guidelines. External and internal radi.ation exposures were within regulatory limits. The Emergency Pr'eparedness (EP) program was being maintained at an adequate level of operational readiness. .

Overall, site security has been satisfactory. Implementation of the -

fire protection program was not fully satisfactory. ,

B. Basis:

- Site Integration Matrix shows no adverse trend an'd that the only ,

violation identified in the radiation protection area in the past year occurred.in 4/95 (NCV for failure to obey radiological postings).

.- The licensee was effectively implementing its radiological control procedures to maintain personnel radiation exposures ALARA.

- Housekeeping and the control of contaminated and radioactive material within the Auxiliary, Radioactive Waste, Fuel Handling, and Intermediate Buildings were.very good.

Water chemistry control programs ~had been implemented in accordance with Tech. Spec. requirements and industry guidelines.

- .The surveillance programs for meteorological and effluent radiation monitoring instrumentation were effective.

An exercise weakness was identified during the annual emergency preparedness'e.xercise in 7/95 because the Control Room staff was unable to . appropriately demonstrate. emergency c1:ssification as a result of having participated in two practice drills involving an

. essentially identical initiating event. This exercise weakness was indicative of poor drill planning rather than inadequate performance by the Control Room staff.

Security inspections, conducted by resident inspectors identified overall-good performance.

Special security inspection followed up on licensee-identified vital area access problem.

1 Several fire protection discrepancies included: smoke detector panel inoperable with no compensatory measures and detection system out of service with no fire. watch.

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C. Future Inspections:

Inspection Reason, Rad Effluents. & Environ.- Observe system and personnel performa.nce.

~ Rad Solid Waste Observe rad waste control and transportation.

EP Core Program Full. program review due once in SdLP -

cycle.

Security core Review audits, corrective action, plans and management support Security core Review PA equipment, vital access, alarms, cepmasures--and-training Fire protection RI Problems with equipment'and personnel performance x ,.

111. Attachments

1. - Inspection Plan

2. Power Profile 1

3. Plant Issues List

4. Current NRC Performance Indicators

5. Licensee Organization Chart

6. ' Allegation Status

7. Enforcement History

8. Major Assessments 9

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Carolina Elect-ic & Gas Company T or Jenidnsvtile, Sc 29065 Nuclear Operatods (803) 345 4344 SCE&Q Aman:%

February 12,1997 RC 97-0019 Document Control Desk U.S. Nuclear Regu:;. tory Commission Washington, DC 20555

Subject:

VIRGIL C. SUMMER NUCLEAR STATION (VCSNS)

DOCKET NO. 50/395 OPERATING LICENSE N6. NPF-12 RESPONSE TO SALP '

(INSPECTION REPORT NO. 50 395/96 99)

Gentlemen:

South Carolina Electric and Gas Company (SCE&G) hereby submits the response to -

the NRC's Systematic Assessment of Licensee Performance (SALP), inspection Report No. 50 395/96-99.

SCE&G has reviewed the SALP report and agrees with the NRC's assessment of Virgil C. Summer Nuclear Station's (VCSNS) superior performance in three of the four functional areas: Plant Operations, Maintenance, and Engineering. - -

To better understand your assessment of the Plant Support functional area, we have conducted a thorough evaluation of the report, reviewed the comments provided at the SALP Board's presentation, and exam!ned inspection reports from the period.

SCE&G's conclusion is that VCSNS has maintained a superior level of performance in the Plant Support functional area as compared to past SALD assessment periods and when compared to othe: Region ll nuclear stations. A brief discussion of activities related to the Plant Support functional area is attached.-

As discussea during the SALP E.oard presentation, SCE&G requests an opportunity to review the performance of the Plant Support functional area in more detail with Region 11 staff. Based on the information provided in the attached document and discussions with your staff, SCE&G requests the NRC reassess this functional area.

We appreciate the opportunity to provide comment on the SALP report. Should you havo any questions or comments, please call me at (803) 345-4344 or have your staff call Ms. April Rice at (803) 345-4232.

V tr ,

^ og Gary a rd M er Sy C NUCLEAR EXCELLENCE - A SUMMER TRADITION!

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Document Control Desk.

. RC-97-0019 lE 960099 >

Page 2 of 2..

I RAM /GJT/nkk -

Attachment c: J.L Skolds NRC Resident inspector W.F. Conway J.B. Knotts, Jr.

. R.R. Mahan (w/o attachment) NSRC R.J. White RTS (IE960099)

L.A. Reyes File (815.01)

A.R. Johnson DMS (RC-97-0019)-

General Mangers l'

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RC-9F0019 '

Attachment '

Page 1 of 3

- Brief Dlacussion of Activities Related to the Plant Support Punctional Area RADIOLOGICAL 00hTROLS j

, in the area of Radiological Controls, V.C. Summer has realized significant reductions in ,

dose, plant effluerns, and radwaste generation since the last SALP period.' Radioactive material control performance and the number of NRC VMlations 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 identified during this SALP period as supported by the following:

n Annual exposure has been reduoed from the previous assessment period, even if the dose from the 1994 steam generator replacement is excluded, e

• Outage dose in Refuel 9 was our lowest in history and 9th lowest refueling dose ever for PWRs.

• Effectively reduced plant effluents, when compared to last SALP period.

• Greatly reduced the amount of contaminated trash generated annually.

Contaminated surfaos area within the radiation control area (RCA) is maintained

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less than 2%.

During refueling outages, the containment building is maintained accessible in street clothes.

• VCSNS is recognized w'rthin the industry by INPO and our peers for our contamination control.

• NRC Inspection Reports have also included remarks complimentary of contamination control. (94-15,95-03, & 95-19)

• The number of NRC violations in Radiological Controls is consistent with the previous SALP period.

• Incidents of radioactive material discovered outside of the RCA has remained constant when compared to the last SALP period. There has been no instance of loss of contamination control from the protected area.

• A review of Region 11 SALP history indicates other plants with recent incidents of contamination control issues who subsequently received a superior rating in Plant Support..

EMERGENCY PREPAREDNESS Emergency Preparedness at V.C. Summer has made improvements in the areas of Emergency Response Organization (ERO) staffing, computerized information exchange

& status, accountability of non-essential personnel, and siren availability. We have 4

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continued to receive positive feedback due to our close working relationship with state end local governments within our EP2, and our annual evaluated exercise results showed improvements. Our continuous improvements in light of the lowered threshold - ,

for problem reporting, discussed earlier, far outweigh any issues raised during the '

SALP period as supported by the following: .

. - The ERO was placed in a four team rotation, this has allowed for more effective

, - table top drills, improved accountability and improved teamwork. -

Developed a computerized Emergency information Systwm (EIS) to enhance information exchange between the facilities.

Installation of the biometrics hand geometry system has decreased the time '

u' required to conduct accountability.

VCSNS has been recognized by the state for taking the Oad role with South L Carolina utilities in the effort to replace tne State's emergency radiac and ,

i dosimetry inventory. This action was in response to notification that FEMA

! would no longer fund the Radiological Defense Program.

Siren performance has made steady improvement compared to the last SALP 3

period. In 1996 VCSNS achieved an unprecedented average operability of L

98.10% with a complete cycle test with 99.06% of sirens sounding.

Training drills are conducted with. interim Emergency Directors and lleensed i- operators during each licensed operator training cycle. These drills have been

, diverse and challenging to ensure each shift's emergency classification ability.

, FIRE PROTECTION L

The number of violations and negative comments contained in inspection reports has ,

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significantly decreased this SALP period despite the fact that we have replaced the fire 4

detection system, rerouted sprinider systems, and rewritten our fire implementation procedures. An NRC inspection, conducted in October to assess performance for the 4

entire SALP assessment period, was overall complimentary with only minor discrepancies noted. Our new fire protection team approach is committed to continuous improvement and problem solving to meet raising expectations and maintain a superior level of performance as evidenced by:

The number of violations and negative comments contained in inspection reports

. has significantly decreased this SALP period. '

e'

- Replaced the fire detection computer system with a new enhanced state-of the-art Simplexfire detection system.

. Performed a job task analysis for personnel performing fire protection duties.

Formed a fire protection team (consisting of a System Engineer, Design Engineer, Test Specialist, l&C Technician, Fire Protection Supervisor, a Licensing Representative and other plant representatives as deemed necessary,) which meets monthly to discuss fire protection issues.

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'* 93*d 7J101 Document Corttrol Deck O RC-97-0019 Attachment Page 3 of 3 Changed personnel responsible for oversight of the Fire Protection program.

Revised the Fire Protection Procedures to improve quwlity and efficiency.

Conducted a performance based engineering evaluation of the fire protection program and revised the testing program to incorporate the evaluation findings.

This ovaluation allowed the extension of some testing frequencies based on historical equipment performance and system rsilability.

CHEMISTRY Performance within the chemistry area continues to be maintained at a superior level and SCE&G continues to make program enhancements as i!!ustrated by the following:

Developed a program to incorporate a secondary plant auxiliary system corrosion monitoring system.

Achieved the INPO Chemistry Index Performance Goal of <1.20 for the year. .

Met a challenging goal to maintain Lithium and Boron concentrations to help ensure low exposure rates during the refueling outage and during the operating cycle.

Developed a program to convert to 3 methhoxpropylamine (MPA) seconcary ..

plam chemistry control.

SECURITY Superior performance has been maintained within the area of Security and SCE&G continues to make program enhancements as evidenced by the following:

Installed the biometrics hand geometry system.

Installed the vehicle barrier system Upgraded Perimeter intrusion Detection System.

Converted to the I Star badging system Developed program to incorporate NEl's Personnel Access Data System.

Conclusion:

Performance within the Plant Support area has improved when compared to the last SALP period and has been sustained at a superior level of performance.

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Decernber 6,'19961 South Carolina Electric & Gas Company:

ATTN:: Mr. Gary J Taylor

-Vice President Nuclear Operations

- Virgil C,1 Summer Nuclear Station

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

1 Summer Nuclear. Plant performance was assessed in four functional areas: Plant Operations Maintenance, Engineer' g, and Plant Support. Performance in Operations:and'Haintenance remained superior. Performance in Engineering Limproved and is- now considered superior. Performance in Plant Support declined but remains 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 declined to a good level based on

-challenges in control-of contaminated material, maintaining awareness of emergency siren system status, developing challenging emergency exercise scenarios, and human performance errors in the fire protection area.

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.

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' Should you have any questions or comments. I would be pleesed to discuss them-with you.

Sincerely, original signed by Stewart D.12sneter Stewart D. Ebneter Reg,snal Administrator Docket No. 50 395 License No. WPF 12

Enclosure:

SALP Peport cc w/ encl:

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 Washington, D. C. 20005 3502 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 cc w/enti continued: See page 3

l SCE&G 3 cc w/ enc 1: C'o ritinued R. H. Fowlkes, Manager Operations (Hail Code 303)

South Carc, lina Electric & Gas Company Virgil C. Summer Nuclear Station P 0. Box 88 Jenkinsville, SC 29365 April Rice. Han iger Nuclear 1.icens.ng & Operating Ex)erience (Mail Code 830)

Sout1 Carolina Electric & Gas Company Virgil C. Summer Nuclear Station P. O. Box 88 Jenkinsville, SC 29065 INPO Distribution w/ encl:

Chairman Shialey Ann Jackson Commissioner K. C. Rogers Commissioner G. J. Dicus Commissioner Dr. N. J. Diaz Commissioner E. McGaffigan, Jr.

J. H. Taylor EDO H. L. Thompson, Jr. EDO G. H. Tracy, EDO J. L. Hilhoan. EDO S. C. Varga. NRR F. J. Miraglia. NRR R. W. Cooper. RI J. L. Caldwell. RIII J. E. Dyer, RIV D. L. Gamberoni, NRR (2 copies)

F. H. Reinhart. NRR A. R. Johnson, NRR L. W. Garner, RII R. D. Gibbs, RII P. J. Fillion. RII Distribution w/enci continued: See page 4 4

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_Cr D. Payne, RII.

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DRS and DNMS Branch Chiefs

-PUBLICS NRC: Resident Inspector .

U.S. Nuclear Regulatory Commission-Route 1. Box 64-

- Jenkinsv111e. SC -

1Mr, John C. Heard, Jr.

Chief. Technical Hazards Branch Federal Emergency Management Agency- ,

-Suite 706A-'

11371'Peachtree Street. N.E.

r Atlanta. GA 30309 1

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K.: M. Clark. RII.- PA0 DRS and DNHS Branch Chiefs PUBLIC ,

-_ . :NRC Residen spector _

U.S.-Nuc r Regulatory Commission 1024fi ey Drive Min, Val. VA 23117 NRC Resident pector U.S. Nucle Regulatory Commiss on-

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-Surry N ear Power Station /

'5850-jggIslandRoad- /' -

Surcy. VA 23883 -/

j Mr. Thomas M. Majusiak _- /

Chief. Technical Hazards Branch Federal Emergency Managemerit Agency Region III /

Liberty Square Building 105 South Seventh Street Philadelphia, PA 19106 '

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1024 Haley Drive Mineral .VA 23117

.NRC- Resident Inspector:

U.S. Nuclear Regulatory Commission Surry Nuclear Power Station ,

5850 Hog Island Road' Surry. VA: 23883-Mr. Thomas H. Hajusiak-

-Chief, Technical Hazards Branch f Federal Emergency Management Ager y Region III Liberty Square Building 105 South Seventh Street Philadelphia, PA 19106 i

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,.c SYSTEMATIC ASSESSMENT OF LICENSEE PERFORrlANCE REPORT SUMMER NUCEAR PLANT 50 395/96-99 I. BACKGROUND The SALP-board convened on November 13, 1996, to assess the nuclear safety performance of the Sumer Nuclear facility for the period January 29, 1995. through October 26, 1996. The board was conducted in accordance with Management Directive 8.6, " Systematic Assessment of Licensee Perforn nce." Soard Members were J. R. Johnson (Board Chairperson) Deputy Director, Division of Reactor Projects.

A. F. Gibson, Director, Division of Reactor Safety, and F. H. Reinhart.

Acting Director Project Directorate II 1. Office of Nuclear Reactor Regulation. This assessment was reviewed and approved by the Regional Administrator.

II. PLANT OPERATIONS This functional area addresses the control and execution of activities directly related to operating the facility. It includes activities such as plant startup power operation, plant shutdown, and response to transients. It also includes initial end requalification training programs for licensed operators.

Overall performance in the Plant Operations area remained superior dering the assessment period. Unit performance was characterized as a ve y stable period of power operations with relatively few transients, no plant trips, generally conservative decision making, and a good focus on safety.

Operator performance was very good during the relatively few shutdowns and startups conducted. A special steam generator rioisture carry over test was well controlled. Senior Reactor Operators demonstrated excellent supervisory skills, and strong operator knowledge and ability was demonstrated during plant evolutions as well as during requalification training. Rotation of licensed control room operators to auxiliary building tours was effective. Auxiliary building operators were thorough in monitoring and recording system parameters during their rounds and were generally knowledgeable of their duties.

Performance during in-plant fuel handling and tagging activities and in response to support system panel alarms remained a challenge. Locked in alarms on the control room HVAC panel and untimely resolution of a fuel handling building differential improve questioning attitudes. pressure condition Self-verification programsdemonstrated were a nee ENCLOS!RE

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generally adequate: however, two significant events during the most recent refueling outage indicated a need for improved self checking to assure operation of designated equipment and to assure completeness of procedures prior to use.

Plant operations management demonstrated a commitment to assessing plant risk during planning and scheduling activities as well as during special system configuration in a refueling outage. Station management provided excellent risk information in the control room in the form of operator aids listing special refueling conditions, abnormal operating procedures, applicable boration flow paths, and time-to boil in the spent fuel pool. Management provided the operations staff a " safety function matrix" to assist shift supervisors and the operations scheduling staff to evaluate the impact on plant risk of approving preventive maintenance activities on line.

Operations management demonstrated a conservative approach to unit operational decisions. Technical Specification Limiting Conditions for Operation were properly entered when equipment was degraded and during a critical temporary system realignment. Power reductions were conducted prior to several planned maintenance activities as a contingency to assure that reactor conditions would remain stable if secondary plant transients occurred. A station wide standdown was conducted to review safety procedures as a preventative measure and not in response to any special event.

Operational procedures and programs were fundanentally sound and resulted in good adherence. Operator workarounds were wall managed with causes and corrective actions identified, responsibilities assigned, and completion dates scheduled.

Management self-assessment activities were generally effective. Monthly operations monitoring included a trend of personnel errors by shift and a performance annunciator panel assessment of personnel, program, and equipment performance indicators. Support for benchmarking observations by other utilities was strong and the licensee was active in initiatives with cther utilities to learn and share good practices. This was demonstrated by several rotations in management positions, implementation of good practices from other utilities, and a human performance critique of a wrong component operation by an outside utility.

The Plant Operations area is rated Category 1.

III. MAINTENANCE This functional area includes activities associated with diagnostic, predictive, preventive, and corrective maintenance of plant structures, systems and components; maintenance Gf the physical condition of the plant: and traimng of the maintenance staff. It also includes surveillance testing, in-service inspec. tion and testing, instrument

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calibration, operability testing, post-maintenance testing, post outage testing, containment leak rate testing, and special testing. -

Management demonstrated strong commitment to and support of maintenance.

activities. Coordination with Engineering to resolve related technical

-issues was excellent. Overall. the licensee demonstrated superior performance in implementing the station maintenance program and in resolving related technical issues.

Diagnostic, preventive, and corrective maintenance was well performed in that resolution of technical issues and actions to repair heat exchanger head flange leaks on the residual heat removal- and spent fuel pool cooling systems were effective.

The-licensee continued their excellent performance in inspection and testing programs. Surveillance activities were planned, conducted in a professional manner, and resulted in a high degree of confidence that the tested components would perform as designed. In addition, surveillance activities satisfactorily demonstrated equipmeat operability. In service inspection and testing programs were effectively implemented. Instrument calibrations were performed within required calibration due dates. Outage and post maintenance testing was performed well, especially with rq;ard to station modifications to accommodate an approved power uprate accomplished during the last refueling outage in the Spring of 1996. Containment leak rate testing was well performed on containment penetrations. The containment purge supply and exhaust isolation valves, with resilient seals which require frequent testing, were well within the leakage acceptance criteria.

The licensee provided strong supervision, and technicians demonstrated aggressive questioning attitudes. Work packages were thorough and complete, and the backlog of work items was well managed.

Self assessments, root cause analyses, and trending remained strong and effective, In this regard, an excellent licensee initiative replaced the Off-Normal Occurrence reporting system with an in-depth Condition Evaluation Report system that focused on system trending. These trends will be evaluated by quality assurance personnel.

- Maintenance personnel performing work were experienced, well-trained, and very knowledgeable of plant procedures and equipment. Work areas were orderly and well maintained. Material stored in maintenance storage areas was properly identified and protected. Working relationships within the maintenance department and among other departments were supportive and constructive.

Plant management at all levels was well versed on the details of the maintenance rule. Personnel were able to demonstrate comprehei.sive knowledge of the rule in their appropriate area of responsibility. In support of the maintenancc program, as an excellent initiative, the licensee developed a " safety function matrix" to assist in evaluating and managing the impact of on line mainterance with regard to plant

4 safety. The matrix helped to maximize plant safety by managing the combinations of equipment simultaneously taken out of service on each train and by preventing planned simultaneous work on opposite trains.

While mintenance procedures were generally of high quality, attention to detail in using and revising the procedures was a challenge.

While the material condition of the plant was gooi additional challenges included reducing some water and oil leaks.

The Haintenance area is rated Category 1.

IV. ENGINEERING This functional area addresses activities associated with the design cf plant modifications and engineering suoport for operations, maintenance, surveillance and licensing activities.

The licensee's performance in the areas of design control and maintenance of the licensing basis was strong. The engineering workload was well managed, the turnover of design activities previously performed by their primary architect / engineer was well planned and procedures for reviewing changes to the facility were sufficiently detailed to ensure compliance with 10 CFR 50.59. An Engineering Dasign Control Board was established and was effective in prioritizing design changes and disseminating design information to the appropriate staff. Several errors in the design control process were identified by the licensee.

Root causes were identified and appropriate torrective actions were imalemented. Thes performance was a noted improvement over the last SA_P period.

Engineering provided effective support to Plant Operations. Challenging design issues including high moisture carryover from the new steam generators and an unexpected neutron flux tilt, were resolved to improve plant performance. The backlog of engineering work was well managed enabling timely response to problems identified by operators. Operator workarounds were aggressively pursued.

Maintenance problet.s were resolved in a timely manner Engineering worked closely with Maintenance on several design changes that improved plant reliability. Problem identification and root cause analysis of equipment issues supported timely. effective resolution.

The licensee's performance in the area of self-assessment directed toward engineering was good. The Engineering organization initiated frequent contacts with other licensees to identify opportunities for improved performance. The Quality Assurance organization contributed by performing an in-depth audit of the design control program.

{

5 Technical engineering submittals made to the NRC were of high quality with well prepared safety evaluations.

The Engineering area is rated Category 1.

V. PUWT SUPPORT This functional area addresses all activities related to the plant j support function, including radiological controls, radioactive I

effluents, chemistry, emergency preparedness, security, fire protection, and housekeeping.

The radiological control progrcm was effective in rotecting the health

) and safety of plant workers ano members of the pub ic. The onsite radiation orotection program controlled internal and external radiation exposures aelow regulatory limits. Site ALARA and personnel contamination control measures were generally successful throughout the period although some decline was noted. Specifically, contamination and contaminated material were found outside control boundaries. Control of contaminated material is a challenge.

Offsite radiation exposure to members of the public was substantially below regulatory limits. The environmental monitoring program confirmed effective effluent controls in that only trace amounts of radioactivity were detected in the environs of the plant.

Etfective chemistry programs were implemented to inhibit degradation due to corrosion of components in both primary ano secondary systems. The program for handling, packaging and transport of radioactive materials functioned very well.

The emergency preparedness program was generally effective in maintaining site readiness to respond to emergencies. However, actual response indicated some decline in performante. Challenges were noted in developing challenging emergency exercise scenarios and in maintaining awareness of siren system status in order to make timely reports. Several imnrovements were made to the Alert and Notification System sirens to make them more reliable. Preparations for a burricane minimized the risks and potential damage to plant facilities from rain and high winds.

The licensee continued to implement eri support the Physical Security Plan, procedures and associated programs in an outstanding manner. The security program was strong and well managed. The protected area access control equipment was reliable and effective. Station managnment was active in identifying and correcting potential problems.

The iire Protection program performance declined but was generally implemented in an adequate manner during this period. Human performance errors persisted throughout the period and caused deficiencies in the implementation of the program. Maintenance and testing of fire

6 l

protection systems were satisfectory. Organization and staffing changes were made late in the period in a effort to improve performance and some improvement was evident. Quality assurance audits were thorough end corrective actions were timely. Housekeeping was satisfactory but additional improvements could be made in some areas.

The Plant Support area is rated Category 2.

' .' paa 5:uth Car: lina Deetric & G:s Campany Cary J.1:ytor P.o. Box 88 Vee Presicent Jerhnsv6 tie, sC 29005 Nuclear Operations (803) 3454 344 SCE&G esc =cnev October 9, 1996 RC-96-0240 Document Control Desk U.S Nuclear Regulatory Comgssi&S 15 P105 Washington, DC 20555 Gentlemen:

Subject:

VIRGIL C. SUMMER NUCLEAR S1 ATION (VCSNS)

DOCKET NO. 50/395 OPERATING LICENSE NO. NPF 12 RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 96-07

Reference:

Albert F. Gibson letter to Ga y J. Taylor dated September 10,1996.

Gary J. Taylor letter to Document Control Desk dated July 31,1996.

This letter provides the South Carolina Electric & Gas Comp 5ny (SCE&G) reply to a Notice of Violation delineated in NRC Inspection Report No. 50/395/96 07.

South Carolina Electric & Gas Company accepts the violation. The enclosed response to the violation addresses the corrective actions taken in response to the violation.

SCE&G considers itself to be in full compliance at this time, if there are any questions, pleace call at your convenience.

Very r

" -~~

ours J

Ga . aylr SBR /GJT/nkk Attachment

c. J. L. Skolds NRC Re:ident Inspector W. F. Ccoway S. F. Fipps R. R. Mahan (w/o att.) K. R. Jackson R. J. White J. B. Knotts, Jr.

L. A. Blue NSRC R. B. Clary RTS (IE 960709)

S. D. Ebneter File (815.02)

A. R. Johnson DMS (RC-96-0240)

NUCLEAR EXCELLENCE - A SUMMER TRADITI NI

\s

-kb 6@W---- --- -

Attachm:nt to Docum:nt Control D:sk Lctt:r '

IE 960709 RC-96 0240 Page 1 of 2 RESPONSE TO NOTICE OF VIOLATION NUMBER 50-395/96-07 09

1. RESTATEMENT OF NRC VIOLATION Technical Specification 6.8.1 requires, in part, that written procedures be established, implemented and maintained covering the activities referenced in the applicable procedures rx mmended in Appendix A of Regulatory Guide 1.33, Revision 2, dated February 1978. Paragraph 7.e of Appendix A to Regulatory Guide 1.33 states that the licensee have written rad,alon protection procedures.

Station Administrative Procedure SAP 500, Health Physics Manual, revision 8, dated December 9,1993, Section 6.4.L, Monitoring and Control of Surface Contamination, subsection 1 states,

• Contaminated surfaces of permanent structures within the Radiation Control Area are controlled and posted if Beta-Gamma emitting loose surface contamination levels exc,eed 1,000 dpm/100cm .*

Health Physics Procedure HPP 158, Contamination Control for Areas, Equipment and material, revision 7, daled April 3,1996, Section 5.1, Contamination Control of Areas / Equipment within the Radiological Controlled Area (RCA), subsection states, " Areas and equipment within the RCA are controlled and posted if the smearable contamination levels exceed 1000 dpm/cm' Beta-Gamma or 100 dpm/100 cm' Alpha."

Contrary to the above, on April 30,1996, on elevation 436'in the Hot Machine

'~'

Shop, the licensee failed to follow the procedural requirements for postincj and controlling contaminated areas, The NRC identified contamination levels 15 times greater than the procedurallimits for Beta Gamma outside the posted contamination area.

11. STATEMENT OF POSITION South Carolina Electric and Gas Company (SCE&G) accepts the violation as stated above.

, .e ,

Attachm:nt t) Docum:nt C:ntrol Desk Lett:r -

IE 960700 R,C 96-0240 Page 2 of 2 lil. _ REASON FOR THE VIOLATION A small area of contamination was found outside the posted contaminated area. '

The contamination exceeded the procedurallimit of 2 1000 dpm/cm' Beta-Gamma. The area of contamination was not widesprsad as determined by i hallway sweeps and step off pad surveys taken during this time period in a telephone conference with the NRC and SCE&G on October 4,1996, it was l mutually agreed that this incident did not indicate that a weakness in the Health Physics program effectiveness existed. However, the discovery of the small ,

area of loose surface contamination did exceed the posting requirements established by HPP 158 and does not meet SCE&G's expectations for '

contamination control.

IV.

CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED The crea was reposted and decenned and smears were taken on and around I the step off pad to ensure that there was not a contamination control problem.

Hallway sweep surveys taken during this time period also indicate there was no further spread of loose surface contamination.

In addition, smears taken by the inspector during this inspection of similar posting configurations found no evidence of contamination exceeding posting '

limits. SCE&G's monitoring of posted areas since the incider:t and the fact that only one of many smears taken during the inspection period revealed any cc,ntamination demonstrates that SCE&G's Health Physics Program continues to be effective and that this was an isolated condition. ,

1

- V.-

CORRECT:VE ACTIONS TAKEN TO AVOID FURTHER VIOLATIONS ,

The corrective actions takea upon the discovery of the contamination are

. adequate. SCE&G feels that no further action is necessary since this was an isolated condition. ,

VI.

DATE FULL COMPLIANCE WILL BE ACHIEVED SCE&G considers itself to be in full compliance at this time.

^

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6

• UNITED STATES

/p* C8 by'o:,* NUCLEAR REGULATORY COMMISSION

'i '

MEGtDN ll i Y'l 101 MARIETTA STREET. N W. SUITE 2500 ATLANTA. GEomGIA 303234190

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\,',' P /

March 17,.1995

• .+.*

South' Carolina Electric & Gas Company ..

-ATTN: Mr. Gary J. Taylor *

-Vice President, Nuclear Operations -

,. Virgil C. Summer Nuclear Station P. 0.cBox' 88 . . . '

Jenkinsville, SC- 29065 -

SUBJECT:

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE.($ ALP) V. C. SUMMER NUCLEAR STATION REPORT NO. 50 395/95-99 Gentlemen:

The NRC Systematic Assessment of Licensee Performance (SALP)'has been ,

completed for your V.C. Summer Nuclear Station. The facility was evaluated.

for the period of February 28. 1993, through January 28, 1995. The results of the evaluation are documented in the enclosed SALP report. .This report will be discussed with you at a public meeting to be held at the V.C.. Summer site-on March 24, 1995,'at 10:00 a.m.

Summer sustained- superior performance in the functional area of Operations, Maintenance and Plant Support. Contributors to this superior performance were active management involvement, effective programs, and conservative decision-

-making. Effective self-assessments provided early identification of engineering problems and corrective actions were successful in minimizing the development of adverse trends. Within the plant support area, it was noted that the emergency preparedness program improved significantly during this period.

Performance in- the Engineering Functional Area was assessed as being good.

. Performance in this area could be improved by more attention to the accuracy, thoroughne:s and timeliness of engineering outputs. . The steam generator replacement. program was noted as an example of excellent engineering output.

Inacco[dancewithSe'ction2.790oftheNRC's"RulesofPractice,"acopyof this letter and its enclosure will be placed in the NRC Public Document Room.

Should you have any questions or comments, I would be pleased to discuss them with you. I look forward to discussing this assessment with,you on March 24, 1995.

Sincerely, syd >.

ewart D. Ebneter Regional Administrator Docket No.: 50-395 License No.: NPF-12 9

Enclosure:

(See-page-2) .

\g r A m r+ Q m

=

i SCE&G 2

Enclosure:

SALP Report cc w/ enc 1:

R. J. White i

Nuclear Coordinator S.C. Public Service Authority .

. Virgil C. Summer Nuclear Station .

, _ P. O. Box BP (Mail Code 802) .

Jenkinsvillt. SC 29065 J. B. Knotts, Jr., Esq.

Winston and Strawn 1400 L Street, NW Washington, D. C. 20005-3502 Chairman .

Fairfield County Council P. O. Drawer 60 Winnsboro, SC 29180 Max Batavia, Chief Bureau of Radiological Health S. C. Department of Health and Environmental Control 2600 Bull Street Columbia, SC 29201 R. M. Fowlkes, Manager Nuclear Licensing and Operating Experience South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station P. O. Box 88 ,

Jenkinsville, SC 29065 ,

INPO 700 Galleria Parkway ,

Atlanta, GA' 30339-5957 Mr. John C. Heard, Jr.

Chief, Tech. Hazards Branch Federal Emgcy. Mgmt. Agency Suite 706A 1373 Peachtree Street, N.E.

Atlanta, GA 30309

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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE REPORT VIRGIL C. SUMMER NUCLEAR STATION 50-395/95-99

1. BACKGROUND ,

The SALP Board convened on February 16, 1995, to assess the nuclear.

safety performance of V.'C.' Summer Nuclear Station for the period.

February 28, 1993, through' January 28, 1995.- The Board was conducted in. i accordance with Management Directive 8.6, " Systematic Assessment of Licensee Performance." Board members were E. W. Merschoff (Board

. Chairperson) Director, Division of Reactor Projects; A. F. Gibson, Director, Division of Reactor Safety; B. S. Hallett, Deputy Director, Division of Radiation Safety and Safeguards; and W. H. Bateman, Director, Project Directorate 11 1, NRC Office of Nuclear Reactor Regulation. This assessment was reviewed and approved by the Regional Administrator.

!!. PLANT OPERATIONS This functional area addresses the control and execution of activities t directly related to operating the plant. It included activities such as plant startup, power operation, plant shutdowns and response to transients. it also included initial and requalification training programs for licensed operators.

Man.gement's attention and involvement in the Operations area has been effective in assuring the continued safe operation nf the Summer facility. The plant operated well during this period, with no reactor trips or significant transients encountered during the entire 23-month SALP period. Effective operational programs and processes, along with management's support of operational activities and conservative operational decisions, contributed substantially to this sustained period of. superior plant performance.

Routine plantJoperations were accomplished in a safe manner. Plant startup and shutdown activities were well controlled and demonstrated effective operator training for these infrequently performed evolutions.

Close monitoring of plant parameters was exhibited on several occasions when operators identified and pursued early indications of problems.

Improvement from the previous assessment period was noted in the control of plant system configuration as a result of management attention and the focused efforts of plant personnel.

Self-assessment efforts were generally effective in identifying and adequately focusing attention on emergent issues. Late in the period, there were indications of operation's willingness to live with deficient conditions.

Thorough corrective actions were taken for some declining performance noted early in the assessment period. Comunication improvements occurred both.within the operations organization and with other support groups, improvements were noted toward the end of the assessment period 9

b

i 1

I 2

- in reducing personnel errors related to procedural adherence during routine tasks. ]

The Plant Operations area was rated Category 1.

III.. MAINTENANCE This functional area. addresses activities associated wfth diagnostic,.

' predictive, preventive and corrective maintenance of pl ant structures.

+

systems, and components. It also includes all survefilance testing, in- t service inspection and other tests associated with equipment and system operability.

The licensee was successful in correcting the declining trend related to problems resulting from maintenance and surveillance activities identified during the previous assessment period. This improvement'was demonstrated by the lack of forced outages during this assessment period

• and was due, in part, to strong corrective and preventive maintenance

~

programs. The programs were strong because they were effectively implemented by technicians who were well managed. Maintenance personnel  :

regularly utilized the procedure feedback proces., and were aggressive in looking beyond their immediate work assignment to identify other issues.

The work planning process was generally thorough in developing complete work packages. Management frequently monitored work in progress and documented their observations. These documented observations were entered into a tracking system that provides indications of trends that  !

can lead to. early detection of problems.

Surveillance, in-service inspection and testing, and diagnostic programs were effectively implemented. Post-modification testing was generally well planned, coordinated, and conducted as exemplified by the program to monitor the thermal expansion of the new steam generators and associated piping during plant heatup following steam generator replacement.. Post-modification testing,

. however, exhibited a number df instances of incomplete tests throughout the assessment period, which indicates a need for

. improvement in the work planning process.

deveral examples of issues attributed to weaknesses in either training or

< skill of the craft were . identified early in the assessment period. These concerns were addressed and the number of examples trended downward over the period indicating effective licensee corrective action.

The interface between maintenance and operations was good with improvement noted late in the assessment period due to improved management attention and involvement in the area. Operations and Maintenance were conservative in selecting equipment outages to ensure safe plant operations. '

?

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3 The mater ial condition of the plant was good. The total amount of contaminated area remains low which contributes to the overall success of effective performance of maintenance activities. ,

The Maintenance area was rated Category 1. -

IV. ENGINEERING This functional area addresses activities associated with the design of plant modifications and engineering support'for opera'tions, surveillance and licensing activities.

Management attention and involvement were appropriately focused on major engineering activities such as the steam generator replacement end other major plant modifications. Engineering for the steam generator replacement project was excellent. Performance in areas receiving this focused attention and involvement was superior. The level of performance in the routine engineering areas remairied good.

Programs and procedures provided the controls over engineering a'ctivities necessary to achieve good performance. Programs were well developed and, in general, were effectively implementea. However, the lack of thoroughness and timeliness noted for the previous assessment period continued through this period and resulted in errors and oversights in some engineering calculations and evaluations. The oversight of

engineering contractors was effective.

l The licensee's self-assessment efforts were effective in identifying and trending deficiencies in engineering processes and in program implementation. Problem identification was enhanced by active participation of the line organization in self-assessment activities.

Appropriate corrective actions were taken to resolve identified deficiencies.

I Effective engineering efforts t~o improve equipment reliability contributed to strong plant performance. System engineers maintained I good knowledge of assigned systems and aggressively pursued corrective actions when appropriate. Design changes were made when necessary to improve reliability. With a few exceptions. corrective actions for long-Root cause analyses standing problems were completed in a timely manner.

were normally thorough. .

The Engineering area was rated Category 2.

V. PLANT SUPPORT This functional area addresses radiological controls, radioactive effluents, chemistry, emergency preparedness, security, fire protection and housekeeping controls.

The radiation control program was effective in controlling radiation doses to workers and the spread of contamination during significant i

y .

9 4

outage work. A strong As Low As Reasonably Achievable program contributed to low personnel doses through the aggressive use of pre-work decontaminations, controlled chemistry during shutdowns, remote monitoring and mock up training sessions, improvements were noted in the use of shielding to help control the source term. The staff was proactive in limiting the size of contaminated areas to extremely low levels. Self-assessments were thorough and identified is.tues that improved performance. Corrective actions were extensive and timely.

Chemistry and radiological effluent programs provided superior support to operation of the plant. The staff was effective in maintaining key parameters and releases well below regulatory limits. The staff aggressively monitored and reacted to emerging problems. The attention to quality control was effective and resulted in a demonstrated high level of analytical performance. in general, radioactive waste processing was good with adequate attention to detail during waste shipment preparation.

The emergency preparedness program improved significantly during the assessment period. Command and control and offsite notification weaknesses noted in the 1993 exercise were effectively corrected and performance improved during the 1994 exerci:e. Management was proactive in upgrading the emergency response facilities argLma4ctturmte-of-3c-siren cortind the =creeney nnt 4HrntiCygtem. Self-assessments and exercise critiques were effectively used to identify areas needing corrective actions. The training program was excellent in providing capable emergency responders, who performed well in classifying and mitigating the consequences of events during the exercises.

In general, the security program performance was effectively implemented.

A comprehensive and high quality training program resulted in competent and knowledgeable security force staff. Preparation and planning for

-outages and potential problems resulted in effective access controls.

Strong testing and maintenance programs resulted in low incidences of security equipment problems. Assessment and detection of alarms was normally good. An exception was noted for response to an alarm late in the assessment period.

The fire protection program was managed at a good level overall. Once problems were identified, corrective actions were comprehensive and aggressively pursuti.

Management attention to housekeeping declined late in the period.

The plant Support area was rated Category 1.

f