RC-97-0019, Submits Response to NRC SALP Insp Rept 50-395/96-99.Licensee Agrees W/Nrc Assessment of Plant Superior Performance in Functional Areas of Plant Operations,Maint,Engineering & Plant Support Including Emergency Preparedness & Security

Submits Response to NRC SALP Insp Rept 50-395/96-99.Licensee Agrees W/Nrc Assessment of Plant Superior Performance in Functional Areas of Plant Operations,Maint,Engineering & Plant Support Including Emergency Preparedness & Security

ML20134L942
Person / Time
Site:	Summer
Issue date:	02/12/1997
From:	Gabe Taylor SOUTH CAROLINA ELECTRIC & GAS CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RC-97-0019, RC-97-19, NUDOCS 9702200026
Download: ML20134L942 (5)

Text

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• South C rolina Electric & Gas C mpany Gary J. Taylor j P.O. Box 88 Vico Przsident

, 'Jenkinsville, Sc 29065 Nuclear Operations 4

(803) 345-4344

. SCFJtG  ;

i esmusc-m .

l February 12,1997 ,

i RC-97-0019  !

! Document Control Desk  !

l U.S. Nuclear Regulatory Commission '

Washington, DC 20555 i

Subject:

VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) j l DOCKET NO. 50/395

! OPERATING LICENSE NO. 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 i f the NRC's Systematic Assessment of Licensee Performance (SALP), inspection Report  ;

j No. 50-395/96-99. I

SCE&G has reviewed the SALP report and agrees with the NRC's assessment of Virgil  !

l C. Summer Nuclear Station's (VCSNS) superior performance in three of the four l functional areas: Plant Operations, Maintenance, and Engineering.  !

To better understand your assessment of the Plant Support functional area, we have i conducted a thorough evaluation of the report, reviewed the comments provided at the SALP Board's presentation, and exs. mined 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 SALP assessment periods and when compared to other Region ll nuclear stations. A brief discussion of activities releted to the Plant Support functional area is attached.

As discussed during the SALP Board presentation, SCE&G requests an opportunity to review the performance of the Plant Support functional area in more detail with Region ll 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 have any questions or comments, please call me at (803) 345-4344 or have your staff call Ms. April Rice at (803) 345-4232.

f ff) g 97o2200026 97o212 Gary Ta r PDR' ADOCK 0500o395 , y G PDR x NUCLEAR EXCELLENCE - A SUMMER TRADITION!

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Document Control Desk RC-97-0019 IE 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 Managers I

i .

Documsnt Control D:sk

! RC-97-0019  ;

Attachment Page 1 of 3 i

j Brief Discussion of Activities Related to the Plant Support Furmtional Area RADIOLOGICAL CONTROLS l In the area of Radiological Controls, V.C. Summer has realized significant reductions in dose, plant effluents, and radwaste generation since the last SALP period. Radioactive  :

material control performance and the number of NRC violations has remained constant when compared to the last assessment period. Improvements in the area have been c mado while at the same time drastically lowering our threshold for problem reporting.

i Radiological Controls improvements far outweigh any issues identified during this '

SALP period as supported by the following:

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• Annual exposure has been reduced from the previous assessment period, even

if the dose from the 1994 steam generator replacement is excluded.

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

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

• Greatly reduced the amount of contaminated trash generated annually.  !

{ Contaminated surface area within the radiation control area (RCA) is maintained

less than 2%. ,

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

• VCSNS is recognized within the industry by INPO and our peers for our j contamination control.

'* NRC Inspection Reports have also included remarks complimentary of

contamination control. (94-15,95-03, & 95-19)

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

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• 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.

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• A review of Region i' SALP history indicates other plants with recent incidents of

. contamination control issues who subsequently received a superior rating in

Plant Support.

j EMERGENCY PREPAREDNESS i

} 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 l

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Documsnt Control D sk

. ' hC-97-0019 Attachment Page 2 of 3 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 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 System (EIS) to enhance information exchange between the facilities.

• Installation of the biometrics hand geometry system has decreased the time required to conduct accountability.

• VCSNS has been recognized by the~ state for taking the lead role with 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 Radiological Defense Program.

• Siren performance has made steady improvement compared to the last SALP period. In 1996 VCSNS achieved an unprecedented average operability of 98.10% with a complete cycle test with 99.06% of sirens sounding.

• Training drills are conducted with interim Emergency Directors and licensed operators during each licensed operator training cycle. These drills have been diverse and challenging to ensure each shift's emergency classification ability. l FIRE PROTECTION The number of violations and negative comments contained in inspection reports has significantly decreased this SALP period despite the fact that we have replaced the fire detection system, rerouted sprinkler systems, and rewritten our fire implementation procedures. An NRC inspection, conducted in October to assess performance for the entire SALP assessment period, was overall complimentary with only minor j 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  !

I has significantly decreased this SALP period.

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

• 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 '

I iconsing Representative and other plant representatives as deemed necessary,) which meets monthly to discuss fire protection issues.

Docum::nt Control Desk '

HC '91-0019

Attachment Page 3 of 3 1

• Changed personnel responsible for oversight of the Fire Protection program.

• Revised the Fire Protection Procedures to improve quality and efficiency. l

• Conducted a performance based engineering evaluation of the fire protection  :

program and revised the testing program to incorporate the evaluation findings. j This evaluation allowed the extension of some testing frequencies based on

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historical equipment performance and system reliability. j i

i

CHEMETRY  !

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

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

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

l

• 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) secondary .

4 plant chemistry control.

i SECURITY  :

I 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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