ML20033E288
| ML20033E288 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 03/01/1990 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9003120141 | |
| Download: ML20033E288 (4) | |
Text
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March 1, 1990 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D. C.
20555
Subject:
McGuire Nuclear Station, Docket Nos. 50-369 and 50-370 SALP Report 50-369, 370/89-34 Duke Power Comments
Dear Sir:
By letter dated January 19, 1990 the NRC transmitted the Systematic Assessment of Licensee Performance (SALP) report for McGuire Nuclear Station.
i I appreciate the perspective offered by the NRC in the SALP Report and will utilize this input to further improve the quality of our operations. We have already taken actions to initiate improvements which were discussed with NRC management on January 30, 1990. The SALP report has been reviewed to ensore that these actions are appropriate and comprehensive for any identified weaknesses and to assist management in focusing future actions and involvement in particulcr areas of station operation and support. As a result of our review of the SALP report and the discussions held during our January 30 meeting, we would like to make several comments.
Our comments are listed i
below and are addressed by the functional areas evaluated in
- +,e SALP report.
Plant Operations 1.
On page 6, the last paragraph states, in part The McGuire simulator has been incorporated into the operator l
training program for less than one year and has not been certified.
l This needs to be clarified that this is a new, higher fidelity simulator and is McGuire's second simulator.
2.
On page 7, it is stated that deviations from the generic WOG ERGS were not adequately documented.
An E0P deviations document for Catawba was reviewed and approved by the NRC as part of the OL process. Duke considered this document to be valid for McGuire due to the similarity of the McGuire and Catawba E0Ps. A deviations document for McGuire was submitted on June 28, 1989 following l
the SGTR event, as requested by the NRC.
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Page 2 March 1, 1990 Emergency Preparedness 3.
On page 15, in the Recommendations section, the schedule for completion of the TSC is given as June 1992; it is presently scheduled for December 1992.
Security and Safeguards 4.
On page 16, in the Recommendations section, the statement "... repeated I
identification of issues involving noncompliance without taking correc.
tive actions." is made. We believe this is inaccurate.
Corrective actions were taken in all events.
However, in some cases the corrective actions were not successful in precluding recurrence. The SALP report suggests that no corrective actions were taken Additionally, the Recom-c mendations section states several concerns, but makes no recommendations.
Engineering / Technical Support 5.
On page 17, fourth paragraph, the staff states that "... the licensee was slow in identifying Annulus Ventilation system deficiencies despite an applicable information notice early in the assessment period." The e
referenced Information Notice was not obviously applicable to Pressurized Water Rcactors as it was the discussion of a BWR problem.
It was Duke's design work that identified the parallel to the dual (ice condenser) containment.
6.
On page 18, third paragraph, the Maintenance Engineering group is referred to where the Performance group should be. The system expert program should be discussed in conjunction with the Performance Section, not the Project Services group.
This paragraph should be rewritten as follows:
Plant support by the onsite engineering organization has been effective, although a need for improvement was identified in post modification test development activity as previously discussed.
For example, the Service Water System performance evaluations, response to generic nuclear plant check valve problems, and the establishment of an on-line system to monitor Component Cooling Water System heat exchanger fouling demonstrated effective plant support. A formalized system expert program was imple-mented this assessment period to enhance site engineering support activities.
1 The Performance Section has provided strong technical support to the station. The Project Services group also provided effective onsite engineering and technical support in their coordination of modification implementation activity with Design Engineering and administration of the Station Problem Report (SPR) program.
The SPR program has provided ar, effective mechanism for identification and documentation of plant
- problems, i
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Page 3 March 1, 1990 Safety Assessment /Ouality Verification 7.
In regards to the Regulatory Compliance group, we feel that the overall quality of their efforts is greatly improved since the last review period. Management involvement has increased significantly. During this review period the quclity of technical specification revisions has improved significantly and none were rejected.
Likewise, the quality of responses to NRC generic letters and bulletins has significantly improved. We believe that this improving trend should be reflected in the report.
8.
On page 20, in discussion of the MSRG, the term " Occasionally" is used.
The frequency of this occurrence is unclear and it is not clear that this is considered to be a consistent problem. The three examples cited (out of 69 LERs) were the only examples, though it is implied there are more.
Of the examples cited, one was re-worded, and one was self-identified.
Additionally, the referenced violations were issued for the incidents themselves, not the MSRGs handling of the events. The statement dis-cussing the violations should be deleted.
9.
The McGuire SALP Report stated that "... Corporate QA audits remain heavily weighted toward documentation review."
For the early part of the review period, i.e. 1988, we could agree with this statement. However, considering the entire time frame, we believe our audits are more indicative of the statement "... Corporate QA audits were more results oriented than had been the case previously, with more emphasis on the review of activities rather than a review of documentation,". This appears in the Catawba SALP for basically the same time frame. During this period, an effort has been in place to move QA audits to a more performance-based approach, and the Catawba SALP indicates the effects of this effort.
Because Corporate QA audits all the Duke nuclear stations and performs the audits to the same procedures, utilizing the same work force, the improvements noted in the Catawba SALP should also be true of the audits of the McGuire Nuclear Station. Our plans are to continue to improve the Corporate audits through training and experience in the performanced-based auditing concept.
10.
Page 21 of the report makes the assertion:
A weakness was identified relative to the program for follow-up of NRC Information Notices. Untimely follow-up occurred relative to two notices...
This assertion is without basis in requirements.
Each NRC Information Notice contains the statement:
However, suggestions contained in this information notice do not constitute NRC requirements; therefore, no specific action or written response is required.
Any action taken as a result of an NRC Information Notice is not required and is on Duke's own initiative. The paragraph denoting this as a weakness should be deleted, i
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Page 4 March 1,'1990 Review of Licensee Reports
- 11. On page 23, the totals include voluntary LERs. To encourage and maintain the free flow of information from licensees to the NRC, these totals should not include voluntary reports.
Additionally, incidents where both an LER and a violation were issued should be noted to avoid " double" counting.
Thank you for the opportunity to comment on this SALP report.
Very truly yours,
~ d
/
h Hal B. Tucker xc: Mr. S. D. Ebneter Regional Administrator, Region II U. S. Nuclear Regulatory Commission 101 Marietta St., NW, Suite 2900 Atlanta, Georgia 30323 Mr. Darl Hood U. S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, D. C.
20555 Mr. P. K. VanDoorn NRC Resident Inspector McGuire Nuclear Station l
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