ML17305A434

Comments on Regulatory Commitment Tracking Sys & Timeliness of Util Actions to Close NRC Open Items.Of 33 Items Noted as overdue,17 Found Completed

ML17305A434
Person / Time
Site:	Palo Verde
Issue date:	11/14/1989
From:	Bailey J ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
192-01521-JNB-T, 192-1521-JNB-T, NUDOCS 8912130235
Download: ML17305A434 (12)

Text

AC CELERATED D1 BUTION DEMONSTR ON SYSTEM REGULATO NFORMATION DISTRIBUTION TEM (RIDS)

I ACCESSION NBR:891 213023.5'OC.DATE: 89/ll/14 NOTARIZED: NO DOCKET

FACIL

STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi 05000528 STN-50-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi 05000529 STN-50-530 Palo Verde Nuclear Station, Unit 3, Arizona Publi 05000530 AUTH. NAME AUTHOR AFFILIATION BAILEY,J.N. Arizona Public Service Co. (formerly, Arizona -Nuclear Power RECIP.NAME RECIPIENT AFFILIATION MARTINiJ.B. Region 5, Ofc of the Director

SUBJECT:

Comments on regulatory commitment tracking sys 6 timeliness of util actions to close NRC open items.

DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR I ENCL .t SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response S

NOTES:

Standardized plant.

Standardized plant.

05000528 05000529 05000530 j h

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD5 PD 1 1 CHANiT 1 1 DAVISgM. l. 1 INTERNAL: ACRS AEOD 1 1

~ 2 2 AEOD/DEIIB 1 AEOD/TPAD 1 1 DEDRO 1 1 NRR SHANKMAN,S 1 1 NRR/DET/DIR 8H3 1 1 NRR/DLPQ/LPEB10 1 1 NRR/DOEA DIR 11 1 1,. NRR/DREP/PEPB9D 1 1 NRR/DREP/PRPB11 2' 2 NRR/DRIS/DIR l. 1

.NRR/DST/DIR 8E2 1 NRR/PMAS/ZLRB12 1 1 NUDOCS-ABSTRACT .' 1 ~

B JIB MAN,J 1 1 OGC/HDS1 1 1 REG FILE 02 1 1 RES MORISSEAUgD 1 1 RGN5 LE Ol 1 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 NOTES: 1 l.

D TOTAL NUMBER OF COPIES REQUIRED: LTTR 29 ENCL 29

Arizona Public Service Company P.O. BOX 53999 ~ PHOENIX. ARIZONA 85072-3999 192-01521-L1NB/TDS JACK N. BAILEY VICE PRESIDENT NllllVPO 'All: I8 NUCLEAR SAFETY AND LICENSING Mr. John B. Martin, Regional Administrator U. S. Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596-5368

Dear Sir:

Subj ect: Regulatory Commitment Tracking System File'9-002.419 06 '9-056-026 During the discussions held in'your offices on October 10, 1989, I advised you of my concerns regarding the Regulatory Commitment Tracking, system and, in particular, regarding the timeliness of APS's actions to close NRC open items.

As a result, I directed that a review of commitments be performed to determine if the open items listed as being overdue were: (1) completed and the closure documentation not yet submitted to update the tracking system, (2) entered into the tracking system with an inappropriate completion date, or (3) 'not completed within the committed time frame.

The sample evaluated was the computer listing of overdue commitments as of October 13, 1989. The results of the review are -as follows. Thirty-three items

("hard") were identified as being overdue. Of the 33 items identified 'as overdue, 17 were found to have been completed. Of the 16 remaining items 10 were considered to have inappropriate completion dates in the tracking system (e.g.,

the commitments provided for completion before achieving specified conditions in Units 1 and 3 and the tracking system was using outdated estimates of achieving those conditions) two (2) were typographical errors and did not represent overdue commitments and four (4) were overdue without adequate justification.

Appropriate submittals have been or will be made; as necessary, to provide the NRC updated completion dates for the overdue commitments. A plan of action has been developed to provide increased assurance that the revised commitment dates will be met and that other regulatory commitments are fulfilled by the commitment dates. The plan is described in the attached memorandum. An overall implementation schedule for this plan will be developed and forwarded to you by December 1, 1989. If you have any questions or require additional information, please contact me.

Very truly yours, 8912130235 991114 PDR ADOCH, 05000528 P

4 Letter to.Mr. John B. Martin Page 2 JNB/TDS/kj Attachments CC: NRC Document Control Desk M. J. Davis T. L. Chan T. J. Polich A. C. Gehr

P

~ ~ e 9@~A 4ev2 99 1190.900191 IOX/5001 hrizona PubHc Service Company COMPANY CORRESPONDENCE ID 9: 102-01433-TDS DATE: September 28, 1989 TO: J. N. Bailey Sta. 9: 7040 Ext 9 4789 FROM: T. D. Shriver Sta. 9 6148 Ext. 2521 FILE1 89-056-026

SUBJECT:

Overdue NRC Commitments As I discussed with you earlier this week, I have been developing an action plan to eliminate the backlog of actions required to resolve NRC concerns. You will note that'his plan is designed as a "stop gap" measure to address the current problem. Upon successful completion, additional actions will be required to prevent recurrenc'e. I recommend the immediate implementation of the following plan:

~Ste 1 A. Develop an overall implementation schedule.

B. -- Assemble data on all open NRC action items by functional area.

Assign a specific Compliance Engineer (CE) to each functional area (see attached).

D. Assign an individual from the line organization to be a single point of contact for the Cg.

~Ste 2 A. 'he CE will be assigned to review each open item with the line organization contact.

Consolidate required actions where possible to minimize actual work required and eliminate duplication.

C. If necessary or advantageous the commitment should be revised corrective action can be achieved in a more expeditious if the same manner.

f Memo to J. N. Bailey

'Overdue NRC Commitments Page 2 D. Develop a definitive schedule for item completion providing measurable milestones.

E. Develop supplement/revisions to the committing documents based upon actions taken .in the preceding items if required.

~Ste 3 A. Develop a simple, easy-to-read statusing document to be provided to senior management and the NRC.

B. Schedule an initial meeting with NRC Regional Management to explain the program.

Schedule periodic meetings with the NRC Senior Resident and middle-level regional management to update status.

As discussed, this plan is designed to address a current issue and is intended to be managed similar to a task force effort. You will note that all the responsible licensing personnel are from my department.

That was done intentionally to facilitate the assignment of priorities, control of overtime and minimize the need for direct management involvement. I have begun implementation of this program within my department, but will wait for your approval before approaching line management.

TDS/kj cc: Compliance Personnel

J RESPONSIBILITY ASSIGNMENTS

1. Unit 1 S. Jones

2. Unit 2 R. Roehler

3. Unit 3 A. Johnson EED R. Rouse

5. NED D. Larkin

6. Central/Plant Services J, Malik

7. RP S. Karimi

8. Miscellaneous P. Coffin

9. RCTS Coordination B. Brown

10. Project Overview T. Bradish

l' C