ML18219D103

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Letters from Westinghouse Electric Corp to NRC, Providing Information Regarding Environmental Qualification of Safety Related Barton Instruments
ML18219D103
Person / Time
Site: Cook  
Issue date: 07/21/1978
From: Anderson T
Westinghouse Electric Corp
To: Harold Denton
Office of Nuclear Reactor Regulation
References
Download: ML18219D103 (26)


Text

U.S. NUCLEAR REGULATORY COMMISSION NRC FOAM 195 I2-76 I

,.~ NRC DISTRIBUTIONFoR'RT 60 DOCKET MATERIAL DOCKET NUMBEA FILE NUMBER TO:

Mr. Harold R, Denton FROM:

Westinghouse Elec Corp Pittsburgh~

Pa 15230 T.

M Anderson DATE OF DOCUMENT 07/21/78 DATE AECEIVED 07/25/78 ZLETTER QORIGINAL

~OPV DESCRIPTION 0 NOTOR IZED JiKJ NC LASS IF IED PROP INPUT FORM ENCLOSURE NUMBER OF COPIES RECEIVED I C'Q..

2p Forwarding two Westinghouse ltrs dtd July 20 8 17, 1978 providing info re environmental qualfication of safety related Barton Instrumentso

~ ow/att figures~ ~ ~

2p+ 8r PLANT'iVAiK 'OOK UNIT 2 jcm 07/26/78 FOR ACTION/INFORMATION ENVIROIQIENT rS ld'u~il3

~

4JZ HACH CHIEF:

PROJECT MANAGER:

LIC. ASST:

pfWM7 Sd4ufMc'HW Rkl5 ASSIGiVED AD'-

ORE LTR MNPA%5C BRANCH CHIEF:

V DR GOSSICK Q STAFF INTERNAL0 ENGINEERING B.

HARLESS ISTRI BUTION T SYSTEMS anA1+$ 'r's O

CTORS SITE SAFETY G

ENVIRON ANALYSIS DEVTON G NJLLER VVIRON TECH ERNST BALLARD L OD V GENEViT LIViS CTOR SAFETY ROSS NOVAK ROSZTOCZY CHECK LT MAN BAER L R GAIOIILL ( 2 )

V LYSIS VOLL3KR IJVC IVS L?DR: Sr Md'~

EXTERNALOISTRIBUTION CONTROL NUMBER V IC G V J.

HANCHETT) 16 CYS SENT CATEGOR NRC FOAM I95 I2 76I XO ACRS II

'82070009

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NS-TMA-1870 Westinghouse Water Reactor Electric Corporation, Divisions PVN Systems DMsion Box 355 PillsbLtrPhPemsylvanla 15230

, July 21, 1978 HS-PLI:-5256 S.O.

AMP-460

. Mr.. Harold R. Denton, Director Ref:

NS-TMA-1771, 4/26/78 Office of Huclear Reactor Regulation AEW-7111, 4/3/78 U.S. Huclear Regulatory Commission

+I 7920 Norfolk. Avenue

Dear Mr. Oenton:

Py QJ AMERICAN ELECTRIC POMER PROJECTS

@PP DONALD C.

COOK UNIT 2 (DOCKET 50-316)

ENYIRONMEHTAL UALIFICATION OF BARTON TRANSMITTERS Enclosed are:

~

~

~

~

~

1.

Twenty-five (25) copies of two Westinghouse letters to American Electric Power on Env'~onmental gualification of Safety ReIated Barton Instruments (Proprietary).

2.

Forty (40) copies of two Westinghouse letters to American Electric Power on Environmental gualification of Safety Related Barton Instruments (Hon-Proprietary).

Also enclosed are:

l.

One (1) copy of Application for Withholding, AW-78-56, (Non-Proprietary).

2.

One (1) copy of Application for Withholding and Affidavit (Hon-Proprietary),

AW-76-39.

This information is being submitted to the NRC at the request of your staff and reports on the recent testing of Barton transmitters.

The attached two Westing-house letters 1)

AEW-7156, 7/17/78, M.

H. Judkis to R.

W. Jurgensen 2)

AEW-7157, 7/20/78, M.

H. Judkis to R.

W. Jurgensen provide an updating of 'testing previously described in the referenced letter to you.

By a separate letter, American Electric Power Service Corporation is authoriz-ing this submittal on their docket no.

50-316.

This submittal contains proprietary information of Westinghouse Electric Cor-

'oration.

In conformance with the requirements of 10CFR Section

2. 790, as

. amended, of the Commission's regulations, we are enclosing with this submittal an application for withholding from public disclosure 'and an affidavit.

The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission.

0

NS-TllA-1870 July 19, 1978 Page 2

Correspondence with respect to the affidavit or application for withholding should reference AH-78-56 and should be addressed to R. A. l4iesemann, Manager of Licensing Programs, l4estinghouse Electric Corporation, P.O.

Box 355, Pitts-

burgh, Pa.

15230 Yery truly yours I

T. H.

nderson, flanager Nuclear Safety Department I.

C. Ratsep/fk Attachment cc:

R.

H. Jurgensen, 1L, (AEP) 1A, (5P, 1NP)

R.. F. Hering, 1L (AEP)

S.

H. Horowitz, 1L, (AEP)

" S. J. tlilioti, 1L (AEP)

J.

G. Feinstein, 1L (AEP) lAP

0

- V'(GQlnglloUse Electric Corporation Power Systems Company l'lr. R. ll. Jurgensen, Head Nuclear Engineering Division American Electric Power Service Corporation 2 Broadway New York, New York 10004 pea'9 Sysfcms Kvls:Oil Box 355 Piltstmrpp PaznyiVQlll1 15230 AEl<-7157 July 20, 1978 S.O.

Af1P-325 REF:

AEll-7156 AMERICAN ELECTRIC POllER PROJECT DONALD C ~

COOK UNIT 2 ENVIRONt1ENTAL QUALIFICATIOH OF BARTON TRANSMITTERS

Dear l1r. Jurgensen:

In the referenced letter Westinghouse provided a

summary of the sequential (radiation, seismic, temperature/pressure/chemical spary) environmental test results of the subject Barton pressure and differential pressure transmitters.

Me indicated that during part of the temperature/pressure/chemical spray testing the instruments exceeded their specifications;

however, as outlined in the referenced letter, the test conditions were not representative of any single post-ulated event and llestinghouse was initiating several short term programs to verify the adequacy of the transmitters.

To demonstrate that the large('deviations observed during the sequential testing would not occur under the concurrent radiation/temperature conditions that would exist during postulated accidents Hestinghouse recently completed a

simultaneous radiation/temperature test on a Barton Hodel

(

)a c differential pressure transmi'tter.

The transmitter used was the one described in the referenced letter as an unirradiated instrument having undergone the short term

- portion of the temperature/pressure/chemical spray test.

The concurrent radiation/

temperature test consisted of placing the unit in an oven near a radiation source and simultaneously exposing the transmitter to temperature and radiation.

The transmitter was installed in the oven with its cover removed in an attempt to simulate the same temperature rise on the 'circuit board as seen during the steam test.

By removing the transmitter cover the electronics would heat up at a rate approximating the air temperature.

On the other hand the heat up of the differential pressure sensing cell would lag the electronics due to the thermal inertia of the unit and the energy content of the air.

This is opposite of the situation involving a steam test with the cover in place and consequently(

)errors at the b,c beginning of the test would be expected due to early actuation of the temperature compensation circuitry.

Since the oven temperature could not be raised at a rapid rate it was preheated to ~(

)'Fb c prior to raising the radiation source from its pool.

u.

Hr.

R. II. Jurgensen hf;lt-7157,

<<2>>

July 20, 1978 Once the oven had been preheated to ~{

)'F '

the radiation source was raised providing"a dose rate of ~(

)bsc rads/hour.

Over the first

(

)bsc minutes of the test the oven temperature attained

~(

)'F and the expected(

Ioffset aquas seen.

At (

)bsc minutes into the test the oven b,c attained

~(

)'F"s and remained at this level. for about

(

)bsc minutes.

During this period of time the transmitter error went(

Ibut did not b,o go beyond

~(

)

s span.

The transmitter recoverd to

(

)/o s

span. at approximately

{

)

s hours into the test and remained within (

j s

to b,c

(

)bee to the completion of the test (at ~(

)b sc hours).

Due to the slow cooling of the oven, the temperature did not decrease below ~(

) Fbsc after the

(

) b sc minute,

(

~

)

FD sc condition.

Results of this test support the contention that under simultaneous testina the effects observed under sequential testinq would not be observed (maximumb error of ~(

')bsc span during the simultaneous test as compared to ~(

)

span under sequential testing).

hs outlined in the referenced letter additional testing to determine the dose level at which radiation damage occurs and to determine the temperature at which the characteristic(

) offset is triggered is in process.

'tie will b,c keep you informed of these results when they become available.

The above data concerning the transmitter testing are Hestinghouse proprietary informat'ion and are for your internal use only and should not be released to any persons or other',

organizations without prior approval.of Westinghouse Electric Corporation.

If you have any questions concerning the above, do not hesitate to contact us.

Very truly yours, r+g//

H.

H.

dkis, t1anager Amer'ican Electric Power. Project MGJ/lz/keg cc; ter.

R.

ter.

R.

ter.

S.

Hr. J.

Hr. J.

H. Jurgensen

- 5L F. Hering - 1L H. Horowitz - 1L C. Jeffery - lL G. Feinstein - 1L

%t.< r

~

~

AEtt-7156 0

l"i'esttnghouse t teetric (:orpnration Water Beactor Divisions 1%'iasyst<xa". [rvl".<w Box 355 taiilStXnl;h pCV..",%A@ 15?39 July 17, 1978 S.O.

Ho.:

AttP-325 Ref:

AEH 7026

'lair.

R.

1!, Juvgensen, Head Hucl ear Engineering Divis ion American Ele..tvic Powev Sevvice Corporation 2 Bvoadway Hew Yovk, tlew York 10004 AtiiERICAt't ELECTRIC POUER PROJECT Donald C.

Coot; Unit ?

"Enyo"onm'ntal uglification of Barton Transmitters

Dear Hv. Jurgensen:

In the referenced letter ',!estinghouse provided an update of the Seismic

,.and Environmental Supplemental qualification ProgvaIa and, in particulav, instrument qualification.

Included in the letter weve llestinghouse vecoai-mendations fov the replacement of installed transmitters with adequately qualified instvum nts.

These recommendations i;reve the result of our review of pri'or transmitter qualification tests, the supplemental program qualification tests and the instrument functional requirements.

As described in the letter 1!estinghouse, in conjunction with Barton, had developed modified pi essure and differential pressure transmitters to perform adequately under the test conditions establistied for the

.qualification progv<"m.

At that time temperature/pressure/chemical test-

. ing.hM been performed on prototypes of these modified instruments and test results submitted to the ltRC via Hestingtiouse gene> ic letter reports.

Following the successful completion of these pro'totype tests, Barton initiated procurement of components and building of transmitters.

In Apvil of this year: t!estinghouse initiated tfie qualification and lot verification testing on a sample (three pvessure tv<~iismitters, ltodel I and thvee differential pvessuve transmitters, Model I

J) taken from lot The testing included sequential radiation exposure fol towed by seismic simulation and finally temperature/pressure/chemical exposure.

The radi-ation testing consisted of exposing the instruments to L

'otal integrated dose at a rate of appvoxiaiately>

per hour.

I" ht an integrated dose oi'i g(the dose assnland to enveiopo the radiation received by ttie instrualents under postulated LOCA conditions in ttie tia'e period for,auto!aatic pro+ ctive function initiation) the transn>itter error tjas n [ ] span.

The error at L

] f.otal inte-grated dose was less thanL J span.

Thc seismic'testing of ttiese ivvadi<ted transmitters cons'isted of multi-frequency bi<ixial'eismic sim-ulation vliti: a broad band response spectra ofLgtisles gravity[

Errors noted during the seismic testing weve in most cases less than Lj span.

a,c G. sc b,c b,c b,c b,c b,c b,c b,c b,c b,c

llr. R.

1!. Jurge'nsen July 17, 1978 h,c b,'c at approximate'ly [

[

specificat:ion for about[

hours (Figure 3).

illl test units (pressure and diffevential pressure returned irithin specitication, stabilized with an error of about) span and successfully completed the accel-e ated ion term monitoring portion of the test.

b,c r

g I

To put the results in proper perspective the tempevature/pressure/chem-istry test conditions unposed on instruments that "have been irradiated to a total integrated dose of[

) are not representative of any b.c single postulated event (loss ot coolant accident or steamline break) since the total dose at the time the instrument would experience the postulated acci'dent.'s steam/tempevature transient would be several ordeis of magnitude less than the[

)

Hestinghouse has initi-b,c ated several short term programs, to be completed within the next few weeks, to demonstrate the adequacy of the transmitters.

1!e have recently tested an univradiated transmitter from 'lot one.

Results sho;red a small initial deviation (see Figure 4) possessing the same characteristics ot irradiated instrum nt testing.

These

data, along <rith other data from the supplier; indicate that damage induced by irradiation followed by temperature has a [

) effect on the accuracy of the i:ransmitters.b,c Westinghouse is currently investigating th effect by: '1) determining the dose level at which radiation damaqe occurs by exposing amplifier circuits to varying dose levels and (2) by determininq the temperature at which the characteristic effects are tvigqered.

Also vre will shortly be pevfovr[)ing a simultaneous vadiation/tempevature test to de[aonstrate that the effect observed during sequential testing would not occur under concurrent, radiation/te[rperature conditions that, 1rould be present during postulated accidents (especially loss of coolant accident).

1lhile ere believe that the above programs vrill demonstrate the adequacy of the transr[11 ttel"s and enable us:to explain and propevly evaluate the results observed in the qualification tests, 1!estinghouse has evaluated the impact of the results as they apply to the D.

C.

Cook Unit 2 plant.

In ou1 evaluation l:re reviewed the test r esults from the aspects of auto-matic p1.otection function initiation and post event operator actions.

With respect, to automatic protective function initiation, it has been Autoclave testing (steam/pressure/chemical) began on the transmitters in mid June, 1978.

Figuie 1 provides the specitied test conditions.

Results of f:his testing included deviations in the output of the tlans-mitters which exceeded the allowed test tol evances.

1!hen subjected to the. test conditions the narrow range pressure transmitter (to be used to monitor pressurizer pressure tor trip/safety inpection function

'in'itliitlon) exhlb'lied a laax'Imuia

) ol i'oi" of[

)spall 'tile't vms.

ou o

sp c f

e ification (+10% span fov the first fear minutes of the test (see fi'gure 2).

The wide range pressure transmitters, used to 1,o1 'editor

~ veactol coolant system pressure, also exceeded their post, accident monitoring speci.fication of +10% span.

Iws can be seen in Figu1e 2, these instrum.nts did not go beyond approximatelyf span at any

~

oint.

The differential pressure transmitters, used o', pressurizer eyel and steam genevator level applications did not exceed the

+10%

span tolerance fov automatic plotective function initiation before going c

The units exceeded the

+25% long term monitovirg tolerance minutes into the test and vemained outside of the b,c

ter.

R.

H. Ouvgensen

~ 3w July 17, 1970

~

d that the obsevved test results. ~Io!iot, invalidate the safety ks ov loss of coolant analysis results for steamline

breaks, feedline brea; accident analyses.

llith respect.to operatov actions following postulated in containment

events, two acth~ities for which in containment instru-mentation is normally used on which to base operatov action are impacted b

h t t lt The first of'hese concerns is terminating safety y t e es resu s.

ed steamline ln Qc'

)ection and auxiliary feedwater flow following a postulate s

break to ensure 'that veactor vessel conditions are not exceed d.

operator would normally monitor RCS wide range temperature and pressure and p>'Qssuvizer level and take action based on these signals.ls.

Hith the assumption that the current, test results are applicable to this event

. the indicated pvessure and level values could be much lower than actual values and consequently, pressure in the reactor coolant system could be greater than indicated.

An evaluation of your vessel fov the first full power year of operation s!iows that following such an event opevat.on of t!ia reactor coolant system at the pressurizev safety valve setpoint iE acceptable fov an extended period of time.

Thevefore any delayed

'action taken by the opera'.or would have no adverse effect on the integrity.

of tlie reactor coolant system.

The second area reviewed concerned proceeding to cold shutdown following a secondavy side break.

hany plant emergency operating instructions state that the operator is to pvoceed to cold shutdown as:soon as the plant conditions have stabilized.

To do this tlie operator monitors wide g

an e reactov coolant system pressure

> hich is also interlocked with the RHR systemi val Yes.

Ollce tile reactor cool ant system pressure i s e

b low a preset valve the intevlocks will be satisfied and the oper<itor can align the RIIR system to the RCS.

If the results of the tests are applied to this situation and the actual RCS pvessurizer is greater than indicated and the oper<itor connects the RHR to the reactor coolant system the RHR system could be overpressurized.

To pvevent this situation from occurring llestinghouse recommends tll<it the operating procedures be revised to main-tain the plant in a hot shutdown condition, which is a safe shutdown condition, for an extended period of time (i.e., several hours).

The attached test data demonstrates that,.during this period 'the transmittevs vill recover to an accuracy of[

]span.

At this point in time b,c/,

the opevatov should verify the reading of the wide range reactor coolant sy'tem instrument with another instrument from which reactor coolant system pressure can be evaluated, fov example, this 'instrument could be a diverse incontainment reactor coolant system pressure instrum.nt or an out of containm nt instrument such as charging pump dischavge pressure.

Following tliis point the operator can proceed to cold shutdown.

It should be noted that this recov.:>ended revision is viewed as an interim procedure until the transmitter results can be evaluated in light, of the short term programs previously described.

~

Although the transmitter test results exceeded ouv specifications for certain functions, I!Qstinghouse is confident that the additional programs will confirm the adequacy of'l>e Barton transmitter.

The above data

Hr. R.

H. Jurgensen July l7, l978 concelning t >e ransm~

el l t tt~r testing, including the test conditions, and ro rietar

.he attached figuves are considered to be Westinghouse propr y

nal use onl and should not be veleased information and is fov your ii>ternal y

to any persons or other organizations vrithout prior appvova o.;es.in Electric Corporation.

If you have any questions concerning the aboYe, do riot hesitate to contact us.

t~iHJ:mvr Very truly yours, w~~cr~~

H.

l. Ju k's, Nanagev American Electric Po>e'er Project cc:

Hr.

R.

Hv.

R.

l'v. S.

.l~iv. J.

.:lkr. J.

1J. Jurgensen-F. Hering - lL.

H. Horo',ritz

-. lL C. Jeffery lL G. Feinstein - lL

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7/~i'~ 0 REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS>

DISTRIBUTION FOR INCOMING MATERIAL 50-316 REC:

KEPPLER J G

NRC ORG:

TILLINGHAST J IN 5 MI PWR DQCDATE: 06/30/78 DATE RCVD: 07/19/78 DGCTYPE:

LETTER NOTARIZED:

NG COPIES RECEIVED

SUBJECT:

LTR 1

ENCL 0 INFQ Rr MEFTING BETWEEN LICENSEE MANAGMENT AND PLANT OPERATORS CONCERNING REASONS FOR LARGE NBR OF EVENT REPTS AND NEW CONTROI PROCEDURES TQ BE USED.

PLANT NAME: COOK UNIT 2 REVIEWER INITIAL:

XBT DISTRIBUTOR INITIAL:

DISTRIBUTION OF THIS MATERIAL IS AS FOLLOWS I

NOTES:

1.

SEND 3 COPIES OF ALL MATERIAL TG ISE ED REEVES-1 CY ALL MATERIAL INCIDENT REPORTS (DISTRIBUTION CODE A002>

FOR ACTION:

INTERNAL:

EXTERNAL:

BR CHlEF GRBNi BC+4lLTR ONLY(4)

REG FlL

+LTR ONLY(i>

R GINLYCS) 8.

C SYSTEMS BR+~LTR ONLY(1)

NQVAK/CHECK4+LTR ONLY( 1)

AD FOR ENG4t~LTR QNLY(1>

HANAUER4~%LTR ONLY< 1 )

AD FOR SYS 5 PROJ++LTR ONLY(1>

ENGINEERING BR++LTR ONLY< 1)

KREGER/J.

CGLLINS++LTR ONLY(i>

K SEYFRIT/IE+4LTR ONLY< 1)

LPDR'S ST.

JOSEPH MI+~LTR ONLY(1)

TICi LIZ CARTER4~4~LTR ONLY< 1)

NSIC~~LTR ONLY(1>

ACRS CAT B+4LTR ONLY(16)

NRC PDR++LTR ONLY(i>

MIPC++LTR ONLY<3)

EMERGENCY PLAN BR>>LTR ONLY(1)

EEB44LTR ONLY(i)

PLANT YSTEMS BR>>LTR ONLY(1)

AD FOR PLANT SYSTEMS4<LTR ONLY<

REACTOR SAFETY BR>+LTR ONLY(i>

VOLLMER/BUNCH~4LTR ONLY< 1)

POWER SYS BR>+LTR ONLY(i>

DISTRIBUTION:

LTR 45 ENCL 0 CONTROL NBR:

7820

~ 7 SIZE:

4P THE FND 44%%%%%%%%44%%%4%4%%%%%%%%%%%

h II

INDIANA R MICHIGAN POWER COMPANY P. O. BOX 18 BO WL I N G G R E EN STAT ION NEW YORK, N. Y. 10004 Donald C.

Cook Nuclear Plant Unit 2

Docket No.

50-316 License No.

DPR-74 June c,Airi 30, i1978 xx:i)

Wl G3 Mr. J.

G. Keppler, Regional Director U.

S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 8'.

Dear Jim:

A letter was sent to you yesterday by Mr. D. V. Shaller, Plant Manager of our Donald C.

Cook Nuclear Plant, enclosing the Licensee Event Report for the incident, which occurred on June 15, 1978 wherein both emergency diesel generators were inadvertently removed from service during maintenance.

Our engineering staff in the American Electric Power Service Corp.,

including myself and John Dolan, worked with the plant staff management in formulating the corrective actions needed to prevent recurrence.

I would like to personally supplement Mr. Shaller's report and give you a summary of the steps taken by management in the AEPSC to improve operating activities at the plant not only with respect to this event, but in the whole broad spectrum of plant operation now that both units are in service.

I would like to point out that the suggestions of your staff, the meeting with you personally on June 16, and particularly our NRC resident inspector have been helpful to us as we formulated these intensified programs.

First, I went to the plant on April 23 and 24 to discuss with the plant management their problems and concerns.

I was particularly -interested in their views as to the reasons for 7820 10307 gt vd IBl8

Mr. J.

G. Keppler Page 2

June 30, 1978 the number of licensee event reports.

This was followed by a sequence of meetings on May 3

and 4 with broader participation by both plant supervisors and AEPSC engineering personnel.

These meetings were conducted by the AEPSC Nuclear Safety and Design Review Subcommittee on Plant Occurrences and, in addition to myself, John Dolan our Senior Executive Vice President, Engineering and R.

W. Jurgensen our Chief Nuclear Engineer, participated.

As a result of the discussions at, these meetings, a program of action was established.

I am sure you would be interested in those actions we are taking which relate particularly to incidents of the kind experienced on June 15.

These are broad policy considerations and are in addition to the specific items referred to in Mr. Shaller's lette'r.

1.

Personnel Attitudes The Plant Manager has had meetings with key staff members to discuss the need for developing problem solving attitudes throughout the organization.

On a continuing basis, the Plant Manager will meet with all personnel on a department by department basis.

The Operating Department has established the policy whereby any incident which has an effect on safety, unit, capability, equipment capability and/or personnel is to be reviewed and reported in writing to the Department Head by the end of the work period.

The Department Head is to disseminate this review to other personnel.

2.

Technical Specifications AEPSC engineers are working with the plant staff.

to review plant-identified problem areas with Technical Specifications, especially those caused by different specifications for the two units.

We intend to request changes of the NRC to, eliminate these disparities.

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Mr. J.

G. Keppler Page 3

June 30, 1978 3.

Transfer of Information and Training of Operators The "Change Installation Authorization" (CIA) form has been modified to indicate training required prior to installation.

Licensee Event Reports at time of preparation are distributed to each Shift Operating Engineer for dissemination to each shift member.

Steps are being taken to provide similar dissemination in other departments as applicable.

A monthly summary sheet of all CIAs and LERs will be prepared and distributed to all departments.

4.

Operations Quality Assurance (a)

We have' full time effort in progress to update Operations QA procedures.

(b)

An additional auditor has been hired.

5.

Improved Instructions and Indication of Equipment Status General instructions are being developed to guide the director of a unit startup.

This includes the development of a flow diagram graphically illustrating inter-relationships of all activities.

In addition, a permanent=record of the status board is now being maintained.

6.

Plant Vacancies The number of staff vacancies has been substantially reduced.

The plant has established a priority list for filling these vacancies.

7.

Loss of Offsite Power We have had three instances of loss of offsite power since 1975, although our second,

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Mr. J.

G. Keppler Page 4

June 30, 1978 independent source (the 69 kV line into the plant which can be manually connected as the emergency source of offsite power) was not affected.

To reduce the probability of losing offsite power we recently added a third source of offsite power through a new transformer that steps down from the 345 kV yard to the 345 kV plant reserve system.

This third source of offsite power is a backup to the existing 765/345 kV autotransformer.

In addition to these

steps, we will be reviewing the training and requalification of plant operating and maintenance staff to perform safety-related duties.

We will make sure that we give proper training to each person prior to performing a task, identify clearly to him what work he is to perform with any precautions

noted, and if errors are still made, to take other actions to further reduce the possibility of error.

In plant operations I am convinced that the person who actually operates and maintains the equipment is the best source of information as to where improvements can be made to reduce error.

I have therefore asked the Plant Manager to consider,,a merit system to stimulate good ideas.

In conclusion, I believe these actions demonstrate that management is intensely concerned and involved in the operation of the plant.

We will continue to monitor and audit the plant operations to make sure that the areas of present concern are corrected and that we have a plant operating in a fashion that is both safe and smooth.

I hope that we can meet with you and your staff next fall and mutually discuss a record which we can all be proud of.

Very truly yours, J

n h

ce Presi ent JT:p cc:

D. V. Shaller J.

E. Dolan R.

W. Jurgensen