0CAN108502, Comments on 850903 SALP Rept for July 1984 - June 1985.Rept Comprehensive & Objective.Portions of Recommendations Made by Task Force to Evaluate Design Change Process Implemented. Process Significantly Improved & Will Continue to Improve

Comments on 850903 SALP Rept for July 1984 - June 1985.Rept Comprehensive & Objective.Portions of Recommendations Made by Task Force to Evaluate Design Change Process Implemented. Process Significantly Improved & Will Continue to Improve

ML20133G653
Person / Time
Site:	Arkansas Nuclear
Issue date:	10/03/1985
From:	Enos J ARKANSAS POWER & LIGHT CO.
To:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
0CAN108502, CAN108502, NUDOCS 8510160066
Download: ML20133G653 (3)

Text

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ARKANSAS POWER & LIGHT COMPANY POST OFFICE BOX 551 UTTLE ROCK, ARKANSAS 72203 (501) 3714000 October 3, 1985

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OCAN108502 ,

Mr. Robert D. Martin Regional Administrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011

SUBJECT:

Arkansas Nuclear One - Units 1 & 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6 1984/1985 Systematic Assessment of License Performance (SALP) Report Gentlemen:

By letter dated September 3, 1985, (0CNA098501), NRC transmitted the Systematic Assessment of Licensee Performance (SALP) report for Arkansas Nuclear One for the period July 1, 1984, through June 30, 1985. This letter constitutes AP&L's comments on the subject report.

AP&L has in the past and continues to support the SALP process and its goals and objectives. An objective assessment of Licensee performance is useful to both the Licensee and the NRC as well as increasing public u nfidence in the nuclear industry. Such a process promotes continued enhancements in safety and provides a tool which enables both the licensee and the NRC to better utilize resources by focusing on areas with the greatest potential for improvement. In order to accomplish these goals, the SALP report must be objective, comprehensive, and address both the strengths and weaknesses of each area evaluated.

We believe this years SALP report was, for the most part, both comprehensive and objective. The report not only pointed out areas were improvements could be made but also recognized the substantial effort AP&L has made in numerous areas to improve overall performance and plant safety.

In the SALP report, you noted improvements being necessary in the areas of design change control, control of written commitments to the NRC, management of the security system, and completeness of Licensee Event Reports. The following comments address these areas.

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MEMBER MiOOLE SOUTH UTIUTIES SYSTEM I O

N Mr. Robert D. Martin October 3, 1985 As noted in the SALP report, AP&L has mobilized a task force to evaluate the design change process and has already begun implementation of this task force's recommendations. We believe those portions of the program which have already been implemented have significantly improved the design change process and will alleviate a majority of the findings identified during this <

reporting period. Continued improvements of the design change process are scheduled to take place through 1986, thus, further enhancing our capabilities in this area.

AP&L has and will continue to place the highest degree of importance on compliance with written commitments to the NRC and has made significant progress in this area over the past three years. Our primary emphasis in the past has been on establishing a program for active commitment tracking and the verification of information submitted to the NRC. With the active commitment tracking program well under way, we have recently been focusing our attention on the development of a program to identify and assimilate passive commitments (on going commitments to the NRC). A major portion of this program was completed this year with the inclusion of a large number of these passive commitments in the ANO-1 and 2 SARs. Making the passive commitments readily available in these documents should increase personnel knowledge of their existence and, therefore, further assure compliance with NRC commitments. While we do not agree that our emphasis on compliance with NRC commitments has deteriorated over this SALP period, we will continue to improve our commitment tracking program to better identify and track all NRC commitments.

AP&L's management has been and will continue to be committed to a quality security program that is effectively maintained to assure continued compliance will all applicable federal regulations. While some deficiencies in our security program were identified during the latter part of the reporting period, we do not believe those finding were indicative of our overall program and take exception to the SALP reports contention that there has been a conscious effort by AP&L management to lower the priority on security related activities. AP&L's management commitment to the ANO security program is demonstrated by the existence of the ANO Security Task Force and our traditional high performance in this area. The AN0 Security Task Force, which is made-up of representatives from Corporate Security, Site Security, Engineering, Maintenance, Quality Assurance, and Licensing, is responsible for ensuring that the security program at ANO is maintained and upgraded when necessary, to assure compliance with applicable federal regulations. This Task Force reports both to the Vice President of Nuclear Operations and the ANO General Manager who are ultimately responsible for the security program at ANO.

As was noted in the SALP report, regulation pertaining to the reporting of licensee events have recently changed. Since the revision of 10CFR50.73, the only feedback AP&L has received, relative to the content of our reports, was that provided in last years SALP report. In that report, AE0D noted that AP&L had provided adequate event reports during the 1983/1984 assessment period. Therefore, we were surprised when we received this years SALP report, to learn of the NRC's concern in this area. However, as a result of your concerns we are currently evaluating our LER reporting process to determine how it can be improved. The results of this evaluation will be incorporated in future LERs.

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m Mr.' Robert D. Martin October 3, 1985 AP&L places a great deal of importance on the SALP process and evaluation.

Key elements are tracked and evaluated periodically to ensure improvement in identified weak areas as well as to assure performance does not degrade in strong areas. It has been, and remains, our goal to operate the ANO units in the safest possible manner. The SALP report and feedback is an important part of our process to meet this goal and will continue to receive high attention and impact on our activities.

Very truly yours, I

. Ted Enos anager, Licensing JTE/DEJ

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