ML20024D874
| ML20024D874 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 06/29/1983 |
| From: | Dolan J INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20024D864 | List: |
| References | |
| AEP:NRC:0829, AEP:NRC:829, NUDOCS 8308080323 | |
| Download: ML20024D874 (5) | |
Text
=
lNDIANA & MICHIGAN ELECTRIC COMPANY P.O. BOX 18
~
BOWLING GREEN ST ATION N EW YORK, N. Y.10004 June 29, 1983 AEP:NRC:0829 Donald C. Cook Nuclear Plant Unit Nos. 1 and 2 Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 SALP COMMENTS Mr. J. G. Keppler, Regional AC.ministrator Office of InspecLica and Enforcement U.D. Nuclear Stegulatory Commissicn Fegicn III 799 Rcosevelt Acad Gle.n Ellyn, Illinois 60137 Deer hr. rteppler:
We bave carefully reviewed your Systematic Appraisal of Licensee Performance (SALP) for tne period April 1,1982, through March 31, 1983. Oar neeting on June 22, 1963, was most constructive and provided the cpportunity for ourselves and our staff s to discuss in detail your appraisal of our performance in each area evaluated.
As a consequence of this thorough review, we do not plan to comment for the record concerning your findings. On balance, we feel your evaluation was accurate, and reflects the high standards demanded of our industry.
We do, however, believe that there are factors in the functional area of Plant Operations which merit consideration for evaluating this significant area in your highest assessment category.
We agree with your conclusion expressed in paragraph IV.l.b that with respect to the preceding period which received the same mark,
"... improvement was evident, especially in the overall management and conduct of operations." Indeed, we believe that from the operational point of view, this most recent SALP period has been among the best in the history of both Units, and reflects a commitment by both Plant management and personnel to the attainment of superior operations and improved safety.
JUL 5 1983 8308080323 830803 PDR ADOCK 05000315 O
[
Mr. James G. Kappler 2
AEP:NRC:0829 During the past twelve months, embracing a substantial part of the SALP period, both Units achieved new plant records for consecutive days of operation. Unit 1 set an operating record of 174 days, 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> and 21 minutes (previous record 141 days, 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br /> and 56 minutes),
terminated by planned shutdown for ice condenser Technical l
Specification surveillance. Unit 2 started a record run on January 28, 1983 which established a record of 145 days, 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> and 43 minutes in June of 1983 (previous record 122 days, 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 3 minutes),
terminated by an electronic component failure. Each unit experienced j
only one operator error shutdown during the SALP period. Despite time d
lost to major refueling in both Units, the availability factors were l
74.9% and 77.7% on Units 1 and 2, respectively.
We feel that there is a strong correlation between safe, reliable operations and good operations management and practices. This l
correlation is supported by the improvements noted in your report, concomitant improveme:lt in surveillance performance snd reduced i
operations related Licersee Event Reports. The high level of perforaance reflecto dedicated effort by Plant personnel. We telieve i
th.it recognition in the form of en improved evaluation, where warranted, provides a strong incer.tiv$ to further improvement and has a saleMzy e:.fect on our nutual goel of increased reactor safet;r.
Very truly yours,
}-
ohn E. Dolan
(
Vice President
)
5 f
cc:
M. P. Alexich 1
\\
1 t
I i
1 t-i
ENCLOSURE 1 Significant SALP Report Findings for the Donald C. Cook Nuclear Power Plant General Observations Improvements were made in the category ratings of three Functional Areas, while one area declined.
Improvement was also noted in the operations area even though the category rating remained the same. Noncompliances decreased from 59 in SALP 2 (18 months) to 26 in SALP 3 (12 months),
however, potential enforcement actions are still unresolved for over 40 findings in the areas of quality assurance and fire protection; therefore, conclusions are difficult to make from noncompliance data. Reportable events increased significantly for both units, partly due to an increase in LER's related to fire protection as described in Sections IV.5 and V.
The lack of significant improvement in regulatory performance especially in the area of QA/QC indicates that the licensee's Regulatory Performance Improvement Program (RPIP) has not been completely effective.
In addition, development and implementation cf the RPTP has been alos. Mcwever, because an acceptable program has been agread upon, the licensee shculd ensure that suifici>nt nanpower and rescarces are devoted to eff. ret tirely implementation. The improvements in the licensee's attitude and managenent i
as indicated in Section V.I and elsewhere in the report should te con-tinued and increased. Efforts by the plant manager to improve areas out-l side the sccpe of the RPIP are commendable and should also be continued.
J Functional Arcas Operations 1
Noncompliances descreased from nine to five and there were fewer plant trips indicating that the licensee has taken a more conservative and responsive
}
approach in the operations area. The licensee is also pursaing other improve-ments such as reducing nuisance alarms. ' Implementation of certain aspects of j
the RPIP has been slow.
1' Radiological Controls The licensee made several physical improvements in which state-of-the-art equipment has been installed.
Personnel exposures remained low; radioactive releases were average. Radwaste transportation has also improved. Airborne activity in the auxiliary building continued to be a problem,.and other weaknesses were noted.
Maintenance and Modifications The category rating for this area decreased from 2 to 3 based on weaknesses in work controls and in QC inspection policies. There were four items of noncompliance and several LERs which indicated weak work control practices, and an enforcement conference was held which discussed an inadequate QA
<,a
--m g-e se-
.----+-n7,y.,
,.w.e-y e-9-q_g.9
,g9,..,.w, 9i,.,ygy-,
p.,9,,
,a-,., -
9
-+4.,
m,y,.n
.-pgq,.,.+.-.9 g-.www99_f sg 9-,,.n.
i,p,w
--.>w*pg,,p, g,-
.q,
,.gp.,.,pqp w. y w.
ys7.g.
inspection on safety-related equipment. The Performance Appraisal Inspection also noted several weaknesses in the areas of maintenance and design changes.
Surveillance and Inservice Testing The category rating improved from 3 to 2.
Significant improvement was noted in that fewer required surveillances were missed. This appeared to be due to improved scheduling. Some problems were observed in test procedure prepara-tion and review and in trending instrument drift.
Fire Protection and Housekeeping The results of a special inspection covering implementation of 10 CFR 50, Appendix R, were issued. Enforcement action on these findings has not been taken pending completion of an investigation concerning inaccurate statements.
One Confirmation of Action Letter was issued concerning safe shutdown pro-cedures and there were 3 noncompliances which resulted from other inspections.
The licensee completed their safe shutdown analysis and was in the process of resolving the findings of that report. The rate of LERs increased significantly and was still high at the end of the evaluation period indicating that the licentee's corrective actions were r:ot completely successful.
Emc,rger.cy Preparecnesa The category rating impecved f rom 3 to 2 bued on increased responsivenese to NRC concerns. The problems with the licensee's Emergency Operations Facility (F0F) identified in SALP 1 were resolved.
Security aad Safegoards Three concompliances w.ere issued in this area, and corrective actions were promptly taken by the liceasee.
Improvement vas noted in the reduction of personnel to whim unescorted access to the control room was granted, and in the key control program.
Refueling Two noncompliances were issued, one of which concerned an event in which a fuel assembly was damaged. Licensee corrective actions appear to have been adequate.
Licensing Activities The category rating improved from 3 to 2.
Problems were noted concerning use of support from outside organizations such as Exxon for licensing submittals and in communications between the corporate and site offices concerning licensing matters. Licensing submittals were timely, although the move of the corporate offices from New York to Columbus, Ohio, appears to have had an adverse impact.
Quality Assurance i
.Seven noncompliances and numerous other findings were noted, many of which indicated programmatic problems. Management support for quality programs appeared to be-weak based upon the number and significance of the findings, i
and on the lack of timely and aggressive actions to improve this area.
l 4
i 1
l I
9 4
l 1
2 T
...r.
. ~.. -,
yy
,_____-_,.,_,,.,~.c y.
yr-..
,m.__
._.,,e__,
, - _ -,, -.-