ML20141G199
| ML20141G199 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 06/25/1997 |
| From: | Belisle G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Gabe Taylor SOUTH CAROLINA ELECTRIC & GAS CO. |
| References | |
| 50-395-96-99, NUDOCS 9707030326 | |
| Download: ML20141G199 (12) | |
See also: IR 05000395/1996099
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June 25,1997
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South Carolina Electric & Gas Company l
ATTN: Mr. Gary J. Taylor
Vice President. Nuclear Operations
Virgil C. Summer Nuclear Station
'P. O. Box 88.
Jenkinsville, SC 29065
SUBJECT: MEETING SUMMARY - SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
V. C. SUMMER DOCKET N0. 50 395
. Dear Mr. Taylor: i
This' refers to the December 16, 1996, meeting held to discuss the NRC's
Systematic Assessment of Licensee Performance (SALP) for your V. C. Summer
facility. Our report. 50 395/96 99, dated December 6, 1996, had been
previously sent to you. Enclosure 1 contains a list of attendees and l
Enclosure 2 contains a copy of the SALP presentation. '
In accordance with Section 2.790(a) of the NRC's " Rules of Practice," Part 2,
Title 10, Code of Federal Regulations, a copy of this letter and its
enclosures will be placed in the NRC Public Document Room.
No reply to this letter is required; however, if you have any questions
concerning this matter, please contact us. -
Sincerely, !
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Original signed by George A. Belisle
George A. Belisle. Chief
Reactor Projects Branch 5
Division of Reactor Projects
Docket No. 50 395
License Nos. NFP 12
Enclosures: 1. List of Attendees
2. SALP Presentation
cc w/encis. (See page 2)
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9707030326 970625 (
PDR ADOCK 05000395
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R.'J. White 1
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 .
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Columbia, SC 29201
R. M. Fowlkes, Manager ;
Operations (Mail Code 303)
South Carolina Electric & Gas Company
Virgil C. Summer' Nuclear Station
P. O. Box 88
Jenkinsville, SC 29065
April Rice, Manager
Nuclear Licensing & Operating
Ex wrience (Mail Code 830)
Sout1 Carolina Electric & Gas Company
Virgil C. Summer Nuclear Station
P. O. Box 88
Jenkinsville, SC 290r
Distribution w/encls: See page 3
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Distribution w/encisi
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R. Gibbs, RII
!. P..Fillion, RII .j
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W. Stansberry RII
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PUBLIC
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NAME LGarner alt
DATE % /gaf / 97 06 / / 97 06 / ' / 97 06 / / 97 06 / /b M/ / 97
COPY 7 @' NO YES NO YE$ NO YES NO YES NO YES NO
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LIST OF ATTENDEES
NRC Attendees:
S. Ebneter, Regional Administrator, Region II (RII)
J. Johnson, Deputy Director, Division of Reactor Projects (DRP), RII
F. Reinhart, Acting Director, Project Directorate II 1, Office of Nuclear
Reactor Regulation
G. Belisle, Chief, Reactor Projects Branch 5, DRP, RII
B. Bonser, Senior Resident Inspector Summer Nuclear Station
R. Hannah, Public Affairs Officer, RII
Licensee Attendees:
W. Timmerman, President, SCANA
L. Gressette, Chairman and Chief Executive Officer, SCANA
J. Skolds, President South Carolina Electric & Gas Com]any (SCE&G)
M. Chaplin, Vice President, Generation, South Carolina )ublic Service
Authority (SCPSA)
R. White, SCPSA Representative, Nuclear Coordinator
G. Taylor, Vice President, Nuclear Operations Division
S. Byrne, General Manager, Nuclear Plant Operation
D. Lavigne, General Manager, Nuclear Support Services
B. Williams, General Manager, Engineering Services
T. Taylor, General Manager, Engineering Services (INP0 loanee)
K. Nettles, General Manager, Strategic Planning and Development
Local Official Attendees:
J. Jesse, South Carolina De3artment of Health and Environmental Control (DHEC)
W. Corley, South Carolina DiEC
W. Huckins, South Carolina Emergency Preparedness Division
G. Sox, Richland County Emergency Preparedness (EP)
T. Barber, Newberry County EP
W. Frick, Fairfield County
N. Ellis, Lexington County
M. Kirkland, Fairfield County -
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ENCLOSURE 1
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UNITED STATES NUCLEAR
REGULATORY COMMISSISON
/4 47
%
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SYSTEM ATIC ASSESSMENT OF
LICENSEE PERFORMANCE
(S AL P)
V. C. SUMMER NUCLEAR PLANT
APPRAIS AL PERIOD: J ANUARY 29, 1995
THRO UG H OCTOBER 26, 1996
PRESENTATION
DECEMBER 16,1996'
ENCIOSURE 2
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SALP PROCESS -
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Resident ,
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Program \
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Region \
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Inspections \ /
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"*'"9 N.fxBOARD SALP REGIONAL
ADMINISTRATO R >
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special / j
initiatives
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Event / d
Roviews ,[.-
Master :
Inspection
Plan
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PERFORMANCE CATEGORY RATINGS
r CATEGORY 1. LICENSEE ATTENTION AND INVOLVEMENT HAVE BEEN PROPERLY ,
! FOCUSED ON SAFETY AND RESULTED IN A SUPERIOR LEVEL OF
PERFCRMANCE. LICENSEE PROGRAMS AND PROCEDURES HAVE PROVIDED
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EFFECTIVE CONTROLS. THE LICENSEE'S SELF-ASSESSMENT EFFORTS
HAVE BEEN EFFECTIVE IN THE IDENTIFICATION OF EMERGENT
ISSUES. CORRECTIVE ACTIONS ARE TECHNICALLY SOUND, l
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COMPREHENSIVE, AND THOROUGH. RECURRING PROBLEMS ARE
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j ELIMINATED, AND RESOLIITION OF ISSUES IS TIMFt.Y. ROUT CAUSE
! ANALYSES ARE THOROUGH.
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CATEGORY 2. LICENSEE ATTEKTION AND INVOLVEMENT ARE NORMALLY WELL FOCUSED
- . AND RESULTED IN A GOOD LEVEL OF SAFETY PERFORMANCE.
LICENSEE PROGRAMS AND PROCEDURES NORMALLY PROVIDE THE i
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NECESSARY CONTROL OF ACTIVITIES, BUT DEFICIENCIES MAY EXIST,
THE LICENSEE'S SELF-ASSESSMENTS ARE NORMALLY GOOD, ALTHOUGH
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ISSUES MAY ESCAPE IDENTIFICATION. CORRECTIVE ACTIONS ARE
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USUALLY EFFECTIVE, ALTHOUGH SOME MAY NOT BE COMPLETE. ROOT
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) CAUSE ANALYSES ARE NORMALLY THOROUGH.
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CATEGORY 3. LICENSEE ATTENTION AND INVOLVEMENT HAVE RESULTED IN AN
ACCEPTABLE LEVEL OF SAFETY PERFORMANCE. HOWEVER, LICENSEE
PERFORMANCE MAY EXHIBIT ONE OR MORE OF THE FOLLOWING l
CHARACTERISTICS. LICENSEE PROGRAMS AND PROCEDURES HAVE NOT
PROVIDED SUFFICIENT CONTROL OF ACTIVITIES IN IMPORTAKT
AREAS. THE LICENSEE'S SELF-ASSESSMENT EFFORTS MAY NOT OCCUR
UKTIL AFIER A POTENTIAL PROBLEM BECOMES APPARENT. A CLE*R j
UNDERSTANDING OF THE SAFETY IMPLICATIONS OF SIGNIFICANT l
ISSUES MAY NOT HAVE BEEN DEMONSTRATED. NUMEROUS MINOR
ISSUES COMBINE TO INDICATE THAT THE LICENSEE *S CORRECTIVE
U TION IS NOT THOROUGH. ROOT CAUSE ANALYSES DO NOT PROBE
DEEP EN0 UGH, RESULTING IN THE INCOMPLETE RESOLUTION OF ;
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ISSUES. BECAUSE THE MARGIN TO UNACCEPTABLE PERFORMANCE IN 1
IMPORTAKT ASPECTS IS SMALL, INCREASED NRC AND LICENSEE !
ATTENTION IS RE0'iiG. t
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3 ANT 03ERK IONS
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CATEGORY 1
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STRENGTHS:
! e OPERATOR PERFORMANCE DURING SHUTDOWNS AND
- STARTUPS
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l e ASSESSMENT OF PLANT RISK
e CONSERVATIVE APPROACH TO UNIT OPERATIONAL
l DECISIONS
e SOUND OPERATIONAL PROCEDURES AND PROGRAMS
- e MANAGEMENT SUPPORT FOR SELF ASSESSMENT
ACTIVITIES
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CHALLENGES:
o PERFORMANCE DURING IN-PLANT FUEL HANDLING AND
TAGGING ACTIVITIES
e SELF-CHECKING PROGRAMS
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- MAIhTENANCE l
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CATEGORY 1 l
STRENGTilS:
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e MANAGEMENT INVOLVEMENT AND SUPPORT
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e INSPECTION AND TESTING PROGRAMS ,
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- TECHNICIANS QUESTIONING AliITUDES l
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! e STRONG SELF-ASSESSMENTS
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e PERSONNEL EXPERIENCE AND KNOWLEDGE j
. * MANAGING ON-LINE MAINTENANCE ,
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e ATTENTION'TO DETAIL IN USING AND REVISING j
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PROCEDURES
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ENGINEERING
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- DESIGN CONTROL AND MAINTENANCE OF LICENSING
- BASIS
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e CONTROL OF ENGINEERING WORKLOAD
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e SUPPORT TO PLANT OPERATIONS
I e ENSINEERING - MAINTENANCE INTERFACE
e SELF ASSESSMENT ACTIVITIES
i e LICENSING SUBMIllALS
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CHALLENGES:
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e MAINTAIN EXCELLENT LEVEL OF PERFORMANCE
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P _AN~~ SU 3 30 F
CATEGORY 2
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STRENGTHS:
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e RADIOLOGICAL DOSE CONTROL PROGRAM
e EFFLUENT CONTROLS AND ENVIRONMENTAL MONITORING
e CHEMISTRY PROGRAM
i e PHYSICAL SECURITY PROGRAM IMPLEMENTATION
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CHALLENGES:
o CONTROL OF CONTAMINATED MATERIAL
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e DEVELOPING CHALLENGING EMERGENCY EXERCISE
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SCENARIOS
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o HUMAN PERFORMANCE ERRORS IN FIRE PROTECTION
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SUMMER NUCLEAR PLANT
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! SALP RATING SUMMARY
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l AREA THIS PERIOD LAST PERIOD l
PLANT OPERATIONS 1 i 1
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ENGINEERING 1 2 \
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o UNITED STATES
/p Ho ,%,4
NUCLEAR REGULATORY COMMISSION
- % T EGION 11
7 I P # S 101 MARIETTA STREET, N.W., SUITE 2900
( /'[ ATLANTA, GEORGIA 30323-0199
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Decenber 6, 1996
South Carolina Electric & Gas Company
ATTN: Mr. Gary J. Taylor i
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Vice President, Nuclear Operations
Virgil C. Summer Nuclear Station
P. O. Box 88
Jenkinsville, SC 29065
SUBJECT: SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) l
(INSPECTION REPORT NO. 50 395/96 99) l
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Dear Mr. Taylor:
The U.S. Nuclear Regulatory Commission (NRC) has completed the Systematic
Assessment of Licensee Performance (SALP) for the Summer Nuclear Plant.
The facility was assessed in four functional areas for the period of
January 29, 1995, through October 26, 1996. The results of the assessment are
documented in the enclosed SALP report which will be discussed with you
at a public meeting at the Summer site on December 16, 1996, at 1:00 p.m.
Summer Nuclear Plant performance was assessed in four functional areas: Plant
Operations Maintenance, Engineering, and Plant Support. Performance in
Operations and Maintenance remained superior. Performance in Engineering
improved and is now considered superior. Performance in Plant Support
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 avjiting and rotations of personnel. This
i included both staff and management in order to improve station self assessment
l 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.
M Mloh 3h 3y4 'lN
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SCE&G 2 l
i Should you have any questions or comments I would be pleased to discuss them
with you.
5 Sincerely.
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- Stewart D. Ebneter
Regional Administrator
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Docket No. 50 395
License No. NPF 12
- Enclosure
- SALP Report
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R. J. White
Nuclear Coordinator (Mail Code 802)
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S.C. Public Service Authority
c/o Virgil C. Summer Nuclear Station
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P. O. Box 88
Jenkinsville, SC 29065
J. B. Knotts, Jr., Esq.
Winston and Strawn
1400 L Street, NW l
Washington, D. C. 20005-3502
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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/enci continued: See page 3
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cc w/ enc 1: Continued
l R. M. Fowlkes, Manager ,
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Operations (Mail Code 303)
- South Carolina Electric & Gas Company
- Virgil C. Summer Nuclear Station
P. O. Box 88
Jenkinsv111e, SC 29065
April Rice, Manager
Nuclear Licensing & Operating
. Ex>erience (Mail Code 830)
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Sout1 Carolina Electric & Gas Company,
Virgil C. Summer Nuclear Station
- P. O. Box 88
j Jenkinsville, SC 29065
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE REPORT l
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SUMMER NUCLEAR PLANT
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50-395/96-99 l
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! I. BACKGROUND
The SALP board convened on November 13, 1996, to assess the nuclear
safety performance of the Summer 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
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Licensee Performance." Board Members were J. R. Johnson (Board
Chairperson), Deputy Director, Division of Reactor Projects,
A. F. Gibson, Director, Division of Reactor Safety, and F. M. 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 I
directly related to operating the facility. It includes activities such j
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as plant startup, power operation, plant shutdown, and response to
transients. It also includes initial and requalification training
programs for licensed operators.
Overall aerformance in the Plant Operations area remained superior l
during t1e assessment period. Unit performance was characterized as a i
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very stable period of power operations with relatively few transients,
no plant trips, generally consertative decision making, and a good focus
on safety, j
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Operator performance was very good during the relatively few shutdowns j
and startups conducted. A special steam generator moisture carry over J
test was well controlled. Senior Reactor Operators demonstrated i
excellent supervisory skills, and strong operator knowledge and ability l
was demonstrated during plant evolutions as well as during '
l requalification training. Rotation of licensed control room operators
to auxiliary building tours was effective. Auxiliary building operators
were thorough in maaitoring and recording system parameters during their l
rounds and were generally knowledgeable of their duties. l
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response to' support system aanel alarms remained a challenge. Locked in
alarmt 3n the control room iVAC panel and untimely resolution of a fuel
handl,9 building differential pressure condition demonstrated a need to
imprc a questioning attitudes. Self-verification programs were
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E'dCLOSURE ,
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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 i
procedures prior to use. l
Plant operations management demonstrated a commitment to assessing plant
risk during planning and scheduling activities as well as during special
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system configuration in a refueling outage. Station management provided .
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excellent risk information in the control room in the form of operator l
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aids listing special refueling conditions, abnormal operating
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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
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scheduling staff to evaluate the impact on plant risk of approving
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preventive maintenance activities on line.
! Operations management demonstrated a conservative approach to unit
l operational decisions. Technical Specification Limiting Conditions for ;
i Operation were properly entered when equipment was degraded and during a
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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
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safety procedures as a preventative measure and not in response to any
special event.
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Operational procedures and programs were fundamentally sound and
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resulted in good adherence. Operator workarounds were well 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 other 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.
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l III. MAINTDIANCE
This functional area includes activities associated with diagnostic,
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predictive, preventive, and corrective maintenance of plant structures,
systems and components: maintenance of the physical condition of the
plant; and training of the maintenance staff. It also includes
surveillance testing, in-service inspection 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 l
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 reculted in a high degree of confidence that
the tested components would perform as designed. In addition,
surveillance activities satisfactorily demonstrated equipment
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 .
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performed well, especially with regard 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.
PIant management at all levels was well versed on the details of the
maintenance rule. Personnel were able to demonstrate comprehensive
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knowledge of the rule in their appropriate area of responsibility. In
, support of the maintenance program, as an excellent initiative. the
licensee developed a " safety function matrix" to assist in evaluating
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and managing the impact of on line maintenance with regard to plant
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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, j
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While maintenance 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 good, additional
challenges included reducing some water and oil leaks. j
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The Maintenance area is rated Category 1. j
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IV. ENGINEERING
This functional area addrestes activities associated with the design of
plant modifications and engineering support for operations, maintenance, i
surveillance and licensing activities. l
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The licensee's performance in the areas of design control and i
maintenance of the licensing basis was strong. The engineering workload
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- was well managed, the turnover of design activities previously performed l
by their primary architect / engineer was well planned, and procedures for !
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reviewing changes to the facility were sufficiently detailed to ensure i
compliance with 10 CFR 50.59. An Engineering Design Control Board was
established and was effective in prioritizing design changes and
disseminating design information to the appropriate staff. Several 1
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errors in the design control process were identified by the licensee.
Root causes were identified and appropriate corrective actions were l
im31emented. This performance was a noted improvement over the last 1
SA_P period.
Engineering provided effective support to Plant Operations. Challenging i
design issues, including high moisture carryover from the new steam ;
generators and an unexpected neutron flux tilt, were resolved to improve 1
plant performance. The backlog of engineering work was well managed
enabling timely response to problems identified by operators. Operator
workarounds were aggressively pursued. j
Maintenance problems were resolved in a timely manner. Engineering !
worked closely with Maintenance on several design changes that improved i
plant reliability. Problem identification and root cause analysis of ;
equipment issues supported timely, effective resolution. l
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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 i
improved performance. The Quality Assurance organization contributed by !
performing an in depth audit of the design control program. )
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Technical engineering submittals made to the NRC were of high quality l
with well prepared safety evaluations. l
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The Engineering area is rated Category 1. !
V. PLANT SUPPORT
This functional area addresses all activities related to the plant i
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l support function, including radiological controls, radioactive
effluents, chemistry, emergency preparedness, security, fire protection,
l and housekeeping.
The radiological control program was effective in protecting the health
and safety of plant workers and members of the public. The onsite
radiation arotection program controlled internal and external radiation
exposures )elow regulatory limits. Site ALARA and personnel
contamination control measures were generally successful throughout the
period although some decline was noted. Specifically, contamination and
I 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
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effective effluent controls in that only trace amounts of radioactivity
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l Effective chemistry programs were implemented to inhibit degradation due
to corrosion of components in both primary and secondary systems. The
program for handling, packaging and transport of radioactive materials
functioned very well.
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The emergency preparedness program was generally effective in
maintaining site readiness to respond to emergencies. However, actual
! response indicated some decline in performance. Challenges were noted
i in developing challenging emergency exercise scenarios and in
maintaining awareness of siren system status in order to make timely
reports. Several improvements were made to the Alert and Notification
System sirens to make them more reliable. Preparations for a hurricane
minimized the risks and potential damage to plant facilities from rain
and high winds.
l The licensee continued to implement and 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 management was
active in identifying and correcting potential problems.
The Fire Protection program performance declined but was generally
implemented in an adequate manner during this period. Human performance
errors persisted throughout the aeriod and caused deficiencies in the
r implementation of the program. iaintenance and testing of fire
.
6
protection systems were satisfactory. 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 and
corrective actions were timely. Housekeeping was satisfactory but
additional improvements could be made in some areas.
The Plant Support area is rated Category 2.
.