ML20023C117
| ML20023C117 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 05/02/1983 |
| From: | Mark Miller Office of Nuclear Reactor Regulation |
| To: | Jordan E, Mattson R, Vollmer R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE), Office of Nuclear Reactor Regulation |
| References | |
| ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8305110122 | |
| Download: ML20023C117 (7) | |
Text
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May 2, 1983 m h. 4 m /330 M,C.-
NRC PDR Local PDR DHood Docket Nos: 50-329 LB #4 r/f
) Miller and 50-330 EAdensam RHernan TNovak MDuncan 11EMORANDtAt FOR:
Roger Mattson, Director, Division of Systems Integration Richard Vollmer, Director, Division of Engineering i
1 Edward Jordan, Director, Division of Emergency Preparedness and Engineering Support THRU:
Thomas H. Novak, Assistant Director for Licensing Division of Licensing Elinor G. Adensam, Chief Licensing Branch No. 4 Division of Licensing FROH:
Ifelante A. Miller, Project Manager Licensing Branch No. 4 Division of Licensing
SUBJECT:
EVALUATION FOR SYSTE!!ATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) - CONSUMERS POWER COMPANY, MIDLAND NUCLEAR PLANT, UNITS 1 AND 2 i
Encnsed is a draft of the NRR input for the SALP for Constners Power Company,111dland Nuclear Plant. This draft report is based upon input solicited from selected staff personnel who have had contact and involvement with Consumers Power Company's licens-ing material. Please review the draft evaluation and provide any comments you feel appropriate. All comments received by May 5,1983, will be considered in the final report.
In order to neet this deadline, oral comments directed to the project manager, X24259, would be adequate. To assist you with review and comment, the following persons were contacted for input:
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~ Randy Eberly CHEB Bill LeFave ASB Darl Hood LB #4 g a.
Joe Kane SGEB Hulbert Li ICSB Ron Hernan LB #4 o
Frank Rinaldt SGEB
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Ray Gonzales EHEB DEPES "o
Hart Hartzman MEB h
Aron 1d Lee EQB Dave Rohrer EPLB gg Hal Walker EQB John Gilray-QAB
.g Jeff Kimball GSB 5
Kaz Campe SAB I
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l RTinald W. Hernan, Project Manager Helanie A. Miller, Project Manager Licensing Branch No. 4 Licensing Branch No. 4 Division of Licensing Division of Licensing j
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Midland Evaluttien Matrix l.icensing Management Approach to Responsiveness Enforcement Reportable Staffing Training _
Acttn Involvement Resolution-History Events Tech Soils and Structures 2
3 2
N/A N/A 2
N/A Emergency Planning 2
2 2
N/A N/A 2
N/A Equipment Qualifi-1 1
1 N/A N/A 1
N/A cction QA Program 2
2 2
N/A N/A 2
N/A Natural Gas Pipe-2 2
1 N/A N/A 2
N/A line Auxiliary Feedwater 1
2 3
N/A N/A No Basis N/A System Instrumentation and 2
1 1
N/A N/A 2
N/A C ntr:1 Systems R; view Seismic Spectra 2
2 1
N/A N/A 2
N/A Fira Protection 2'
2 2
N/A N/A N/A N/A NUREG-073_7 Items 1
2 2
N/A N/A N/A N/A Ovarall Rating 2
2 2
N/A N/A 2
N/A w -
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FACILITY NAME:
Hidland Nuclear Plant, Units 1 and 2 L
LICENSEE:
Constriers Power Conpany HRR PROJECT MANGER: Darl S. Hood I.
INTRODUCTION This report presents the results of an evaluation of the applicant Consumers Power Company, in the functional area of licensing activities.
It is intended to provide NRR's input to the SALP review process as described in HRC flanual Chapter 0516. The review covers the period July 1,1981 to ftarch 31, 1983. A distinction of activities between Units 1 and 2 was not considered feasible or appropriate.
The basic approach used for this evaluation was to first select a number of licensing issues which involved a significant amount of staff manpower.
Coments were then solicited from the staff. The staff applied the evalu-ation criteria for the performance attributes based on their experience with the applicant or his products. Finally, this infomation was assembled in a matrix which allowed an overall evaluation of the appli-cant's perfomance.
II.
Sumary of Results NRC Manual Chapter 0516 specifies that each functional area >evaltsate'd will be assigned a perfomance category based on a composite of a nunber of attributes. The single final rating should be tempered with judgment with respect to the significance of the individual elements.
Based on this approach, the perfomance of Consumers Power Company in the functional area - Licensing Activities - is rated Category 2.
L III.
Criteria Evaluation criteria, as given in NRC Manual Chapter Appendix 0516 Table 1, were used for this evaluation.
IV.
Perfomance Analysis The applicant's perfomance evaluation is based on a consideration of seven attributes as given in the NRC Manual Chapter. For the licensing actions l
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. considered in this evaluation, only four of the attributes were of significance. Therefore, the composite rating is heavily based on the following attributes:
- Management involvement
- Approach to resolution of technical issues
- Responsiveness to NRC initiatives
- Staffing There was no NRR evaluation basis for Enforcement History, Reportable Events and Training.
The evaluation was based on our evaluation of the following licensing activities:
- Soils and Structures
- Emergency Planning
- Equipment Qualification
- Quality Assurance Program
- Natural Gas Pipeline
- Auxiliary Feedwater System
- Instrumentation and Control Systems Review
- Seismic Spectra
- Fire Protection
- Implementation of NUREG-0737 Items A.
Management Involvement The overall rating of this criterion is Category 2 with 2 activities receiving individual ratings of Category 1.
For the licensing activi-ties evaluated, there appeared to be appropriate management attention with decision making taking place at adequate levels. During numerous audits conducted by NRR, including audits relating to the soils issue, emergency planning,' instrumentation. and control systems, fire protection and equipment qualification, the records maintained by the licensee were generally complete, well maintained and available.
In almost every area, the appropriate level of management participated in meetings with the NRC.
on safety, technical, and licensing issues and demonstrated knowledge on the meeting's subject matter..In the soils and structures area, however, management involvement was less than desirable since some of the infor-motion given to the NRC at meetings on that subject was later detemined -
to be inaccurate or misleading.
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. Clear lines of responsibility were established in support of the staff's safety evaluation and subsequent issuance of the Safety Evaluation Report.
i Priorities established by licensee management were generally consistent with and supportive of those priorities established by the staff. Com-mitments made to incorporate resolutions into FSAR revisions were kept and were generally timely. The licensee also made an objective and 4
extensive effort to track open issues related to the safety evaluation.
One issue which involved implementation of a THI Action Plan item (Item I.B.I.2) reached an apparent impasse between the staff and applicant.
Ilowever, when the proper level of management attention was focused on the issue, both sides were able to reach an acceptable resolution.
B.
Approach to Resolution of Technical Issues 4
The overall rating for this criterion is Category 2 with the performance rating for individual licensing areas falling into Categories 1 or 3 in three areas.
In general, licensee personnel involved in resolution of technical questions were knowledgeable and clearly understood the issues.
During the appraisal period, technical submittals from the licensee to the NRC were usually complete and conservative.
Resolution of two tech-nical issues during the safety evaluation required elevation to the Division Director appeals level.
In one of these issues, relief was given to the Itcensee.
In the other, the licensee was required to com-mit to installation of a third auxiliary feedwater pump.
In both cases, however, the licensee prepared reasonable technical justification for their position.
In addition, the licensee's response once the appeals i
decision on the auxiliary feedwater pump had been made was excellent.
Licensing activities for which this criterion was rated a Category 1 1
include the area of seismic equipment qualification, where a clear understanding of equipment qualification requirements against design basis and seismic margin earthquakes was demonstrated. The licensing area of soils and structures needs improvement insofar as the. approach to technical issues:
In the absence of NRC requirements, there was reluctance by the Itcensee to perform certain soils remedial work utilizing accepted quality assurance procedures.
In regards to the buried piping issue, the licensee appeared to lack a thorough under-standing of the safety issues involved.
Improvement in the soils area over the appraisal period has been evidenced by more specific and clearer submittals to the NRC.
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. C.
Responsiveness to NRC Initiatives The overall rating for this area is Category 2 with the performance rating for individual licensing action falling in all 3 categories.
In general, responses to the flRC were timely and thorough. The licensee was particularly responsive in the areas of equipment qual-i ifications and instrumentation and control systems. Additionally, in questions concerning the natural gas pipeline, the licensee demon-strated a willingness to address NRC concerns effectively and respon-siveness increased accordingly. Responsiveness was rated poorly for those licensing issues which remained unresolved for a long period of time such as resolution of the buried piping problem.
D.
Enforcement History There is no basis for a NRR evaluation of this attribute.
E.
Reportable Events There is no basis for a NRR evaluation of this attribute at this time.
F.
Staffing Overall rating of this criterion is Category 2.
Positions appear to be well-defined and responsibilities identified. Staffing is adequate and at levels consistent with the activity for the licensing activities evaluated. The licensee effected reorganizations and personnel replace-ments within a reasonable time insofar as key positions.
In some cases, however, the staff considers that too much reliance was placed upon representation by consultants and by the architect / engineer.
G.
Training There is no basis for a NRR evaluation of this attribute at this time.
V.
CONCLUSION Based on the evaluation of Consumers Power Company's'perfomance for a number of activities in the functional area of licensing, an overall perfomance rating of Category 2 has been assigned.
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, Generally, in licensing actf eities the licensee expressed a willingness to respond to NRC initiatives. Submittals were usually timely and thorough.
Especially notable is the degree of nanagement attention directed toward Itcensing activities as evidenced by meeting partici-pation and the level at which decisions occur. Areas of above average perfornance in all criteria include equipment qualification and instrunentation and control systeas reviews. Conversely, although inprovement in the soils areas has been seen during this appraisal period, aspects remain weak such as technical response and management control.
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