ML17333A588
| ML17333A588 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 09/27/1996 |
| From: | Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Fitzpatrick E AMERICAN ELECTRIC POWER CO., INC. |
| References | |
| NUDOCS 9610090337 | |
| Download: ML17333A588 (4) | |
Text
September 27, 1996 Mr. E.
E. Fitzpatrick Senior Vice President Nucle'ar Generation Group American Electric Power Company 500 Circle Drive
- Buchanan, MI 49107-1395
Dear Mr. Fitzpatr ick:
Thank you for your letter of September 9,
1996, responding to our Systematic Assessment of Licensee Performance (SALP) 13 report.
It is important to us that our licensees feel they can respond to issues or evaluations raised in our reports or other NRC correspondence.
Feedback from our licensees, positive or negative, is a significant contributor to providing a balanced view and can be an indicator of how well we are fulfillingour statutory responsibilities.
In response to your request to have the score in the maintenance area reconsidered, the SALP Board reconvened on September 19, 1996, to review the additional information you provided and to reconsider the performance category rating in the area of maintenance.
The Board concluded, after considering all of the information provided, that a change in the performance category rating for the maintenance area was not warranted.
Although no change in the performance category is merited, there are several general issues I would like to address concerning the information you provided.
With respect to the perceived "overly negative" aspect of the maintenance functional area of the SALP and lack of consideration of positive initiatives, there were both positive and negative performance issues discussed at the original SALP Board which were not included in the report.
This is our assessment of your performance, and is not a report on all of the positive events and accomplishments you feel should be included.
In addition, the SALP report does not and should not reflect all of the performance issues discussed.
In your September 9 letter, you discuss your improved performance during the last outage compared to the previous outage.
This improved performance was recognized during the SALP board and the public SALP meeting, but was not noted in the SALP report.
The SALP report did identify some other positive performance issues such as the high degree of safety system performance in 1995 for certain safety related systems.
After again discussing your improved performance during the reboard meeting, we concluded that it would have been appropriate for the SALP report to also include a
statement that recognized the performance improvement in the last refueling outage.
9hi0090337 960927 PDR ADOCK 050003i5 8
E. Fitzpatrick You also commented that you believe that balance-of-plant (BOP) systems played too prominent a role in our evaluation.
Although I acknowledge that the condition of BOP systems may have played a prominent role in the SALP rating, I would disagree that it played too prominent a role.
The consideration of BOP systems for this SALP evaluation focused on the contribution of BOP maintenance and performance to plant transients,
- trips, and other challenges to operations personnel.
As such, we believe that BOP discussions in the SALP were considered appropriately.
We are pleased that you are seeing significant improvement in your performance and in BOP materiel condition during the current SALP period.
We also considered the other issues raised in your letter.
While we agree with some, we disagree with others as well.
Thus, in my view, it would not be productive to debate each one.
- However, we will be contacting your staff to schedule a meeting to discuss some of the issues you raised, in particular, the potential pre-conditioning of equipment prior to surveillance testing.
We will also be evaluating the positive trends that you have identified in the maintenance area during the next SALP cycle.
In closing, superior performance is a higher level of performance than that described in the SALP report, and I concur with the recommendation of the SALP Board.
I appreciate your views and your comments, and your open and candid discussion during the SALP Board public meeting.
Although I disagree with your view of performance in the area of maintenance/surveillance, I encourage you to continue to provide your views in an open and professional manner as you have done in this case.
Sincerely, Original. signed by A. Bill Beach Docket No. 50-315 Docket No. 50-316 A. Bill Beach Regional Administrator cc:
A. A. Blind, Site Vice President John
- Sampson, Plant Manager James R. Padgett, Michigan Public Service Commission Michigan Department of Public Health See attached continued distribution
E. Fitzpatrick Distribution continued Docket File PUBLIC I
OC/LFD SRI D.
C.
Cook B. L. Burgess DRP RIII PRR D.
C.
- Cook, PH, NRR A. B. Beach W. L. Axelson See attached concurrence DOCUMENT NAME:
G:iLtrsalp.cook To receive e copy cf this document, indicate In the box C" ~ Copy w/o attach/enct 'E
~ Copy w/attach/enct 'N' No copy OFFICE RIII NRR RIII RIII RIII NAME Kro M'I Hannon
~
Gran Gro ldwe11 Axel o
each DATE 9~< 96 9~96 9 >c 96 OFFICIAL RECORD COPY 9
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