ML20028B718
| ML20028B718 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 12/01/1982 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Reed C COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML20028B719 | List: |
| References | |
| NUDOCS 8212030178 | |
| Download: ML20028B718 (3) | |
See also: IR 05000010/1982010
Text
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December 1, 1982
Docket No. 50-10
Docket No. 50-237
Docket No. 50-249
Commonwealth Edison Company
ATTN:
Mr. Cordell Reed
Vice President
Post Office Box 767
Chicago, IL 60690
Gentlemen:
This refers to the management meeting held by me and other NRC representa-
tives with Mr. Cordell Reed and other representatives of Commonwealth
Edison Company on June 2,1982, to review the results of the NRC's assess-
ment of the utility's regulatory performance at the Dresden Nuclear Power
Station in accordance with NRC Manual Chapter 0516, " Systematic Assessment
of Licensee Performance (SALP)," covering the period July 1, 1980 through
December 31, 1981.
A preliminary copy of the SALP Report was provided for your review in
advance of our meeting. The final SALP Report including the SALP Board
Chairman's letter to you and your written comments concerning the report
is enclosed.
In addition to the assessments and recommendations made by the SALP Board
contained in the enclosed SALP Report, I wish to give you my overall obser-
vations and assessment relative to the utility's regulatory performance
during the assessment period:
1.
With respect to the SALP ratings, the Regional SALP Board views the
Category 2 rating as the rating which it anticipates most licensees will
achieve. A Category 1 rating is given only for superior performance and
there is reasonable expectation that it will continue. A Category 3
rating is given when the licensee's performance is considered minimally
acceptable and identified weaknesses warrant special licensee management
and NRC attention.
2.
It is my view that the overall regulatory performance of the Commonwealth
Edison Company at the Dresden Nuclear Station is adequate consisting of
both positive and negative attributes. Management is commended for the
positive finding in Emergency Preparedness, Security and Safeguards,
Refueling Activities and Licensing Activities. However, I concur with
the SALP Board's findings that management attention is warranted in Plant
Operations, Radiological Controls and Safety Review Committee Activities.
In your letter of June 18, 1982, forwarding specific comments on the SALP Report
(Enclosure 2 to your letter) you commented on the validity of several conclusions
8212030178 821201
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Commonwealth Edison Company
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December 1, 1982
and their basis. We have reviewed your response and from our perspective we
believe our overall observations and conclusions are still valid, warranting
additional management attention to correct the identified concerns.
With respect to personnel errors associated with unplanned reactor trips
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and LERs, we believe you missed the main thrust of the analyses. While
we acknowledge that two reactor shutdowns should not have been attributed
to personnel errors, this still leaves seven either directly related or
indirectly related to personnel error. Although the percentage increase
of LERs from the previous SALP due to personnel errors is not statistically
significant, the change in the character of these events is significant.
This is evident when you consider that of the 27 LERs attributed to person-
nel error, eleven were due to missed or late surveillance testing and eight
were due to valving errors. While you may disagree with the way we
characterized these events, it does not lessen the need for additional
management attention to minimize the number and nature of personnel errors.
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The discussion on the December 4,1980, sequence of reactor trips was not
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the sole justification for the Category 3 rating in Plant Operations and
was cited as another example which we considered indicative of a fundamental
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problem.
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We acknowledge that we may not have addressed all positive findings such as
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the facility availability factors that you pointed out; however, we still
believe our SALP rating in Plant Operations was correct. The analysis
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section for Plant Operations identified what we considered weaknesses in
you operations that required management attention. We believe the rating
and Board recommendations were consistant with the findings in that a
Category 3 rating says performance was satisfactory; however, weaknesses
were identified warranting additional attention.
We do not disagree with you that repressurization of the reactor coolant
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system, loss of cooling water to the diesel generators, and water in the
HPCI steamlines were complicated events; however, we believe these events
pointed out weaknesses in your review process requiring management attention
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as addressed under Board Recommendations,Section IV.10.
Relative to your concern for more definitive assessment standards, there is
not much to add that has not already been discussed in our meetings. You
were furnished a copy of NRC Manual Chapter 0516 which describes the SALP
criteria and guidance. The SALP Board reviews the integrated collection of
data and observations in an attempt to assure a fair assessment and consistent
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application of the criteria. We acknowledge that the process may not adequately
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assess all the various attributes of a licensee and some of the guidance may be
applied subjectively. While we respect your comments and we are attempting to
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improve SALP, the SALP process is not intended to be an accounting type of
exercise against specific criteria nor is it intended to be purely consultive
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to the extent of pointing out what must be done to rise above a satisfactory
level. The SALP process attempts to categorize management's regulatory per-
formance from the NRC perspective to help set priorities on our efforts and
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Commonwealth Edison Company
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December 1, 1982
resources and provide guidance to licensee management. These findings are
shared with licensees in an effort to help them improve their performance in
the areas where we have identified concerns.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2,
Title 10, Code of Federal Regulatior.s, a copy of this letter and the SALP
Report will be placed in the NRC's Public Document Room.
No reply to this letter is required; however, should you have any questions
concerning these matters, we will be pleased to discuss them with you.
Sincerely,
Original signed by
James G. Keppler
James G. Keppler
Regional Administrator
Enclosure: SALP Report
No. 50-10/82-10,
No. 50-237/82-14 and
No. 50-249/82-15
cc w/ encl:
Louis 0. De1 George, Director
of Nuclear Licensing
D. J. Scott, Station
Superintendent
DMB/ Document Control Desk (RIDS)
Resident Inspector, RIII
Karen Borgstadt, Office of
Assistant Attorney General
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