IR 05000395/2011501

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IR 05000395-11-501; 09/26/2011 - 09/30/2011; Virgil C. Summer Nuclear Station, Unit 1; Emergency Preparedness Baseline Inspection
ML11314A247
Person / Time
Site: Summer South Carolina Electric & Gas Company icon.png
Issue date: 11/10/2011
From: Brian Bonser
NRC/RGN-II/DRS/PSB1
To: Gatlin T
South Carolina Electric & Gas Co
M. SPECK
References
IR-11-501
Download: ML11314A247 (11)


Text

November 10, 2011

SUBJECT:

VIRGIL C. SUMMER NUCLEAR STATION - NRC EMERGENCY PREPAREDNESS INSPECTION REPORT 05000395/2011501

Dear Mr. Gatlin:

On September 30, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your V. C. Summer Nuclear Station. The enclosed inspection report documents the inspection results, which were discussed on September 30, 2011, with Mr. J. Archie and members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, no findings of significance were identified.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure and your response, if any, will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Brian Bonser, Chief Plant Support Branch 1 Division of Reactor Safety Docket No.: 50-395 License No.: NPF-12

Enclosure:

Inspection Report 05000395/2011501 w/Attachment: Supplemental Information

REGION II==

Docket Nos.: 05000395

License Nos.: NPF-12

Report No.: 05000395/2011501

Licensee: South Carolina Gas and Electric

Facility: Virgil C. Summer Nuclear Station, Unit 1

Location: Jenkinsville, SC

Dates: September 26 - 30, 2011

Inspectors: M. Speck, Senior Emergency Preparedness Inspector P. Elkmann, Senior Emergency Preparedness Inspector J. Reece, Senior Resident Inspector W. Loo, Senior Health Physics Inspector

Approved by: Brian Bonser, Chief Plant Support Branch 1 Division of Reactor Safety Enclosure

SUMMARY OF FINDINGS

IR 05000395/2011501; 09/26/2011 - 09/30/2011; Virgil C. Summer Nuclear Station, Unit 1; Emergency Preparedness Baseline Inspection.

The report covered an announced inspection by two Emergency Preparedness Inspectors, one Senior Resident Inspector, and one Health Physics Inspector. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process."

A. NRC-Identified and Self-Revealing Findings

Cornerstone: Emergency Preparedness

No findings were identified.

B. Licensee-Identified Violations

None.

REPORT DETAILS

REACTOR SAFETY

Cornerstone: Emergency Preparedness

1EP1 Exercise Evaluation

a. Inspection Scope

Prior to the inspection activity, the inspectors conducted an in-office review of the exercise objectives and scenario submitted to the NRC to determine if the exercise would test major elements of the emergency plan as required by 10 CFR 50.47(b)(14). This inspection activity represents one sample on a biennial cycle.

The onsite inspection consisted of the following review and assessment:

$ The adequacy of the licensee's performance in the biennial exercise conducted on September 28, 2011, was reviewed and assessed regarding the implementation of the Risk Significant Planning Standards (RSPS) in 10 CFR 50.47 (b)(4), (5), (9), and (10), which address emergency classification, offsite notification, radiological assessment, and protective action recommendations respectively.

$ The overall adequacy of the licensee's emergency response facilities with regard to NUREG-0696, "Functional Criteria for Emergency Response Facilities" and Emergency Plan commitments. The facilities assessed were the Control Room simulator, Operations Support Center (OSC), Technical Support Center (TSC), and Emergency Operations Facility (EOF).

$ Other performance areas besides the RSPS, such as the emergency response organization's (ERO) recognition of abnormal plant conditions, command and control, intra- and inter-facility communications, prioritization of mitigation activities, utilization of repair and field monitoring teams, interface with offsite agencies, and the overall implementation of the emergency plan and its implementing procedures.

$ Past performance issues from NRC inspection reports and Federal Emergency Management Agency (FEMA)/Department of Homeland Security (DHS) exercise reports to determine effectiveness of corrective actions as demonstrated during this exercise to ensure compliance with 10 CFR 50.47(b)(14).

$ The post-exercise critique process and the presentation to the licensee's senior management conducted on September 30, 2011, to evaluate the licensee's self-assessment of its ERO performance during the exercise and to ensure compliance with 10 CFR 50 Appendix E.IV.F.2.g.

The inspectors reviewed various documents which are listed in the Attachment.

b. Findings

Introduction:

The team identified an unresolved item (URI) concerning the adequacy of training and procedures to assess and monitor a radiological release using field monitoring teams.

Description:

While reviewing procedures used during the biennial emergency preparedness exercise, inspectors questioned the adequacy of licensee procedure EPP-7, Environmental Monitoring, Rev. 11, used to direct deployment of field monitoring teams to effectively locate radioactive release plume boundaries. The licensee initiated corrective action CR-11-04977 to evaluate this issue. Inspectors concluded that further review of information related to the procedure's adequacy, and its interrelationship with other licensee radiological assessment procedures is necessary to determine if the issue constitutes a violation of regulatory requirements. This issue is identified as URI 05000395/2011501-01, "Adequacy of Procedures to Assess and Monitor Emergency Radiological Releases."

1EP4 Emergency Action Level (EAL) and Emergency Plan Changes

a. Inspection Scope

Since the last NRC inspection of this program area, Revision 59, of the VC Summer Emergency Plan was implemented based on the licensee's determination, in accordance with 10 CFR 50.54(q), that the changes resulted in no decrease in the effectiveness of the Plan, and that the revised Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. The inspector conducted a review of the Plan changes and a sampling review of the implementing procedure changes made between September 1, 2010, and September 1, 2011, to evaluate for potential decreases in effectiveness of the Plan. This review was not documented in a Safety Evaluation Report and does not constitute formal NRC approval of the changes. Therefore, these changes remain subject to future NRC inspection in their entirety.

The inspection was conducted in accordance with NRC Inspection Procedure 71114, Attachment 04, "Emergency Action Level and Emergency Plan Changes". The applicable planning standard 10 CFR 50.47(b)(4) and related requirements contained in 10 CFR 50.54(q) and Appendix E to 10 CFR Part 50 were used as reference criteria.

This inspection activity represents one sample on an annual cycle.

The inspector reviewed various documents which are listed in the Attachment.

b. Findings

No findings were identified.

OTHER ACTIVITIES

4OA1 Performance Indicator (PI) Verification

a. Inspection Scope

The inspectors sampled licensee submittals for the three performance indicators (PI) listed below. For each of the submittals, the inspectors reviewed the period from July 1, 2010, through June 30, 2011. To verify the accuracy of the PI data reported during that period, PI definitions and guidance contained in Nuclear Energy Institute (NEI) 99-02, Regulatory Assessment Indicator Guideline, Revision 6, were used to verify the basis in reporting for each data element.

$ Emergency Response Organization Drill/Exercise Performance (DEP)

$ Emergency Response Organization Readiness (ERO)

$ Alert and Notification System Reliability (ANS)

The inspectors reviewed portions of the raw PI data developed from monthly performance indicator reports, and discussed the methods for compiling and reporting the PIs with the responsible emergency preparedness personnel. The inspectors also independently screened drill and exercise opportunity evaluations, drill participation reports, and drill evaluations. Selected reported values were calculated to verify their accuracy. The inspectors compared graphical representations from the most recent PI report to the raw data to verify that the data was correctly reflected in the report. Reviewed documents are listed in the Attachment.

The inspection was conducted in accordance with NRC Inspection Procedure 71151, "Performance Indicator Verification." This inspection activity represents three samples on an annual cycle.

The inspectors reviewed various documents which are listed in the Attachment.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

On September 30, 2011, the lead inspector presented the inspection results to Mr. J. Archie and members of the onsite management staff. The inspectors confirmed that proprietary information was not provided or taken during the inspection.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

J. Archie, Senior Vice President, Chief Nuclear Officer
E. Bonnette, EP Specialist
L. Bouknight, EP Specialist
T. Gatlin, Vice President Nuclear Operations
R. Haselden, General Manager Organizational Effectiveness
J. Knox, Emergency Planning Specialist
C. Lasseigne, Licensing Specialist
G. Lippard, General Manager Nuclear Power Operations
T. McCullough, EP Supervisor
S. Reese, Licensing Specialist
E. Rumfelt, Licensing Supervisor
B. Thompson, Manager Nuclear Licensing
L. Vance, EP Specialist
R. Williamson, Manager Emergency Services
S. Zarandi, General Manager Nuclear Support Services

ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000395/2011501-01 URI Adequacy of Procedures to Assess and Monitor Emergency Radiological

Releases

Attachment

LIST OF DOCUMENTS REVIEWED