ML20093L273
| ML20093L273 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 07/25/1984 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Bishop T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| ANPP-30031-EEVB, NUDOCS 8407310345 | |
| Download: ML20093L273 (25) | |
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Arizona Public Service Company-mW d
July 25,1984 n
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U. S. Nuclear Regulatory Commission Region V y
Creekside Oaks Office Park (3
1450 Maria Lane - Suite 210 en Walnut Creek, CA 94596-5368 Attention: Mr. T. W. Bishop, Director Division of Resident Reactor Projects and Engineering Programs
Subject:
NRC Region V Systematic Assessment of Licensee Performance File: 84-056-026; D.4.33.2
Dear Mr. Bishop:
Your letter of June 11, 1984, to Arizona Public Service Company (APS), to my attention, transmitted a copy of the report entitled "U. S. Nuclear Regulatory Commission, Region V, Systematic Assessment of Licensee Perfomance, Palo Verde Nuclear Generating Station, May 1984" (the "SALP Report"), together with a Notice of Significant Licensee Meeting to be convened at Region V's offices on June 27, 1984, to discuss the SALP Re port. Subsequently, pursuant to notice, the date and location of such meeting were changed to July 5,1984, at Palo Verde Nuclear Generating Station.
Accordingly, on July 5,1984, APS management did meet with the Regional Administrator, yourself and other members of the SALP Board to discuss the SALP Report.
Your letter of June 11, 1984, also directed us to inform you "within twenty days after such meeting of those actions [we] have taken or plan to improve performance within areas assessed as Category 3 and requiring additional NRC and APS attention." The attachment to this letter is submitted in response to such direction in your June 11, 1984 letter.
Very truly yours, CR h
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840731034S O g gg PDR ADOCK 05 PDR E. E. Van Brunt, Jr.
G APS Vice President Nuclear Production ANPP Project Director EEVBJr:ru At tachment ec:
See Page Two
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Mr. T. W. Bishop ANPP-30031 Page Two cc:
RJ. chard DeYoung, Director Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission Washington, D. C. 20555 l
K. L. Turley T. G. Woods, Jr.
D. B. Karner W. E. Ide D. B. Fasnacht A. C. Rogers L. A. Souza D. E. Fowler T. D. Shriver C. N. Russo J. Vorees J. R. Bynum J. M. Allen J. A. Brand A. C. Gehr W. J. Stubblefield W. G. Bingham i
R. L. Patterson l
R. W. Welcher H. D. Foster I
D. R. Hawkinson L. E. Vorderbrueggen R. P. Zimmerman J. R. Martin J. Self M. Woods j
T. J. Bloom Records Center l
Institute of Nuclear Power Operations 1100 Circle 75 Parkway, Suite 1500 l
Atlanta, GA 30339 l
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%6 6 8 STATE OF ARIZONA )
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COUNTY OF MARICOPA)
I, Edwin E. Van Brunt, Jr., represent that I am Vice President, Nuclear Production, Arizona Public Service Company, that the foregoing document has been signed by me on behalf of Arizona Public Service Company with full authority to do so, that I have read such document and know its contents, and that to the best of my knowledge and belief, the ststements made therein are true.
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l SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE l
FOR THE PERIOD MARCH 1, 1983 THROUGH MARCH 31, 1984 t
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RESPONSE OF ARIZONA PUBLIC SERVICE COMPANY TO THE REPORT OF U.S. NUCLEAR REGULATORY COMMISSION, REGION V SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE FOR THE PERIOD MARCH 1, 1983 THROUGH MARCH 31, 1984 Section 1.0 Introduction The Systematic Assessment of Licensee Performance (SALP) program was established by U.S.
Nuclear Regulatory Commission (NRC) to provide a periodic evaluation of li-censee performance based on observations and data collected during a given SALP period.
Such evaluations are made for the purposes of providing --
l (i) a basin for allocating NRC resources, and (ii) meaningful guidance to licensee management to promote quality and safety of plant construc-tion and operation.
Such guidance is provided in the recent SALP Report (May, 1934) through a number of recommendations in those func-tional areas receiving substantial inspection during the SALP period, i.e.,
March 1, 1983, through March 31, 1984.
This response ta the May, 1984 SALP Report is intended to describe the actions which have been or will be taken by licensee Arizona Public Service Company (APS) consistent with the guidance provided by the SALP Report i,
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For-the most part, such actions have.al-recommendations.
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ready been implemented or' are in advanced stages of imple-q.
mentation, and they-have been reported previously to NRC (for' example, see APS' Response to the enforcement actions taken by NRC'as a result'of the Construction Assessment Team P
(CAT) inspection in September, 1983).
-This approach, which avoids ' argument respecting the bases for several recommendations, is taken deliberately to emphasize APS management's dedication to quality and safety -in the construction and - operation of l Palo -Verde.
Even though there may be some disagreement respecting some i.
of the analyses.and conclusions in the May, 1984 SALP Re-t port, APS management agrees with and accepts the SALP Board's-recommendations.
To do otherwise would only obscure the intent of both APS and NRC that everything necessary be done to make Palo Verde a safe and reliable plant.
The response that follows addresses all of the recommenda'tions in the May, 1984 SALP Report in the order in 4
which they were made.
Section 2.0-Startup Testing l
(SALP Report,Section IV. O.1.a)
-Board Recommendations:.
"The Board recommends'that the li-1 censee consider minimizing further orga-nizational and administrative control program ' changes during the balance of the test' program, and that additional emphasis be placed on improved communi-4 !
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cations, more thorough understanding and implementation of exist #og programs, and the execution of more tn. cough analysis of the root causes of problems so that more effective resolutions can be imple-mented."
Response
2.1 Stability of Organization and Controls APS management recognizes the importance of main-taining stability in organizational structures and admini-strative controls.
At the same time, however, management has had the ultimate objective of achieving improvements in effectiveness.
Needless to say, one cannot take the advan-tages of improvements without accepting the disadvantages that may go with changes.
The changes made in the APS management structure, the establishment of the Transition Manager, the redefini-tion of responsibilities of the several APS, Bechtel and CE organizations involved in the transition from construction to operation, the enhancement in communication among such organizations, the changes in work controls and procedures, and the training in the modified controls procedures were actions taken to improve effectiveness.
We believe they have been proven successful, and consequently, we can now give attention to maintaining stability.
The resumption of "Q"
Class work and startup testing on "Q"
Class systems last February was initiated deliberately on a gradual, limited basis in large measure to. -
l test the effectiveness of the changes made in organization and controls,_ to identify areas where adjustments might be warranted, and to obviate the need for major changes after full-scale resumption of work and startup testing.
One of the considerations in adopting this gradual approach was that it offered the chance to minimize the adjustments in controls after full-scale resumption and thus promote sta-bility.
The results achieved since resumption (most sig-nificantly reflected in quality performance very close to a schedule required for a November, 1984 fuel load) have demonstrated that the current organizational structure and administrative controls are effective.
Consequently, it is not anticipated that major changes will be required in the foreseeable future.
Nonetheless, management will be alert to the de-sirability of fine tuning adjustments which can improve quality and effectiveness without disruption.
2.2 Improving Communications Additional emphasis has been placed on improving communications, a more thorough understanding of existing programs, and a more thorough implementation of such pro-grams.
The first step taken in the effort to improve communications was the organization of the Project Manage-ment Interface Task Force (PMITF) composed of managers and -
s.
supervisors of the APS and Bechtel organizations having responsibility for activities during the startup phase.
The functions of PMITF were (i) to perform root cause evalua-tions'of problems disclosed by the CAT inspection and the extensive internal audits conducted by APS, and (ii) to develop and recommend solutions to identified organizational interface problems.
The intensive, coordinated work of PMITF during December, 1983, and January, 1984 necessitated virtually continuous communication of the interfacing organ-izations involved in the startup phase and laid the frame-work for the subsequent steps in improving communications.
The second step taken was the consolidation in January, 1984, of the APS Construction, Engineering, Startup and Operations organizations under a single vice president.
This was followed by the establishment of the Transition Manager responsible for coordination of the interfacing organizations during the transition from the construction phase through the startup phase to full power operations.
Scheduled daily meetings of the Transition Manager and the managers (or their respective representatives) of the inter-facing organizations are key elements in the improvement in communications.
The third step which improved communications was the review and acceptance of selected interfacing procedures by affected organizations and institution of a comprehensive training program to the new procedures prior to the restart of "Q" Class work and startup testing. 1
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Finally, APS adopted in May, 1984 a Project Pro-cedure Interface Control Policy whicP identifies inter-facing procedures and (except in emergency situations) pro-hibits changes or additions to those identified interfacing procedures without -prior review by affected organizations and resolution uf their comments.
All of the foregoing steps have resulted in im-proved communications between interfacing organizations and a more thorough understanding and implementation of existing programs.
APS management will continue to stress these objectives.
2.3 Root Cause Analyses APS management recognizes the need for thorough understanding and evaluations of root causes of problems.
The work of the PMITF is evidence of such recognition.
Similarly, the actions taken prior to the CAT incpection to integrate and coordinate the transition from Construction to Operations also reflect the results of root cause evalua-tions of problems encountered by the interfacing organiza-tions during the startup phase and discovered by internal means.
Such actions included the following:
March, 1983 -- Consolidation of Prerequisite and Preopera-tional Testing under the Unit 2 Startup Manager.
April, 1983 -- S tartup Administrative Procedure Development Group established.
-- Startup Information Center established.
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i Jnne, 1983
-- Consolidation.of Prerequisite and Preopera-tional Testing under the Unit 1 startup Manager.
Aug., 1983' -- Specific component testing criteria estab-lished and implemented, including a re-review of completed safety-related electrical Pre-requisite Tests.
Sept., 1983 -- Implementation (after training) of the new Startup Administrative Program approved in August, 1983, that reflected the consolidated startup organization.
Implementation of some of the foregoing actions was in process during the CAT inspection which, unfortu-nately, may have led to the conclusion that frequent or-4 ganizational and administrative changes were being made thoughtlessly.
On the contrary, these changes, which had been in the developmental phase from April to September, 1983, were made only after thorough root cause evaluations of problems encountered under the previous startup program, where prerequisite and preoperational testing were separated, revealed the need to minimize administrative interfaces and improve organizational communications.
APS will continue to stress root cause problem evaluations, as well as a more detailed and expanded trend analyses.
With the stabilized organizational structure now in place, including particularly the Transition Manager, it is expected that analyses of problems and the identification of solutions that address root causes will be expedited.
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Section 3.0 Plant Operations (SALP Report,Section IV.0.1.b.)
Board Recommendations:
"The licensee should continue prep-aration of programs and procedures for plant operation.
Actions to improve the licensed operator training should be finalized and implemented."
Response
3.1 Programs and Procedures.
All programs, administrative. control procedures and implementing procedures which have been identified as required for fuel 'ioad will be prepared, approved and in place at least 60 days prior to fuel load.
3.2 Improvements in the Licensed Operator Training Prcgram.
An mamessment of the Training Department was con-ducted by an outside consultant which has led to improve-ments in several areas, a systematic approach to training, improvement in the utilization of instructors, and more effective communicition, both internal and external, to the Training Department.
An SRO licensed Shift Supervisor from the Opera-tions Department has been promoted to the position of Li-censed Training Supervisor.
Also, a liaison has been desig-nated by the Operations Department to interface and provide feedback to the Training Departtent.
For all SRO and RO examinations to date, an out-side consultant has administered a screening exam.
We are _.
i evaluating this screening process and changes which can im-prove its effectiveness.
Efforts are continuing to.obtain INPO accredita-tion of the Operator Training Program.
The initial self-evaluation is complete and has been reviewed by INPO.
The Licensed Operator Training Program should be accredited within 12 months of commercial operation of Unit 1.
Section 4.0 Radiological Controls (SALP Report,Section IV.O.2)
Board Recommendations:
"In view of the identified devia-tions and the delay in the preopera-tional test program APS should be sen-sitive to industry experience in the radiological controls areas and take appropriate measures to avoid similar problems."
"In reference to industry experi-ence, the NRC has noted at other NTOL facilities that several licensees have not completed the preoperational test program for effluent monitoring, waste treatment and TMI action items in a timely fashion (in addition, failure to meet commitments in these areas has been frequently identified.)"
Response
APS has established realistic schedules for the completion of preoperational testing of effluent monitoring, I
waste treatment and TMI action items in a timely manner that will meet current regulatory requirements assuming a fuel load date in November, 1984.
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APS will continue its concerted efforts to become
- informed of industry experience and problems encountered over all areas of plant operation, including radiological controls.
These - efforts include active participation in activities of EPRI and INPO as well as the Atomic Industrial Forum and the Edison Electric Institute.
APS is also an active member of the C-E Owners Group, the Steam Generators owners Group and the Utilities Nuclear Waste Management Group.
Additionally, APS maintains a continuous, close liaison at all levels of management with Southern California Edison Company, a Participant with a vested interest in the Palo Verde project.
Section 5.0 Maintenance (SALP Report,Section IV 0.3.)
Board Recommendations:
" Continue implementation of main-tenance program controls.
The Board recommends that the licensee give pri-ority attention to confirming that the recently instituted actions are effec-tive in eliminating previously identi-fied work control problems."
Response
APS will continue the implementation of mainte-nance program controls and has been monitoring the effec-tiveness of recently instituted actions through three recent audits:
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Startup Work Control Operations Work Control Recovery Program To ' date, these audits indicate that the basic controls for performing. work are adequately defined and implemented.
An additional audit of maintenance activities is scheduled for later this year.
Section 6.0 Fire Protection (SALP Report,Section IV 0.4)
Board Recommendation:
None
Response
None Section 7.0 Emergency Preparedness (SALP Report,Section IV.0.5)
Board Recommendation:
"The licensee should complete the open items commensurate with the schedule for licensing the plant."
Response
Only six items remain open in the Emergency i
Preparedness area.
APS management will continue to assert aggressive attention to closing these items on a schedule commensurate with licensing Unit 1 at the earliest possible time.
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Section 8.0 Security and Safeguards (SALP Report,Section IV.O.6)
Board Recommendation:
"The Board recommends diligence in implementing the security and safeguards program for operations.
Response
APS will comply with the Board recommendations.
Section 9.0 Soils and Foundation (SALP Report,Section IV C.l.)
Recommended Action:
None
Response
None Section 10.0 Containment and Other Safety Related Struc-tures (SALP Report,Section IV.C.2.)
Board Recommendation:
" Licensee management should consider action to improve effectiveness of final QC inspections in this functional area.
The management examination should con-sider identifying and correcting under-lying causes, since the need for im-provement of final QC inspections is not limited to this one area.
The issue is repeated in the functional areas of piping, pipe supports, support systems
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and electrical.
It would appear that
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the system of Quality checks and bal-ances warrents [ sic] assessment.
For example, the licensee should consider an examination of the information available for management decisions regarding ade-quacy of craft work when it is submitted for QC inspection.
Currently the licen-
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see does~ not trend QC identified craft rework? items.
Another example would be
- assessing the adequacy of the management
. information provided by QA' audits 7
which, in. the area of HVAC - supports (discussed-in C.5 below),
failed to
~ identify hardware deficiencies which 4:
were later found by.the ' NRC.
This is
. particularly. noteworthy. since the NRC, -
in.the last SALP cycle-had cautioned APS 1
'that "the HVAC - installation is one of -
the few-activities not given.an in-depth surveillance".
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Response
f 10.1 Improvements in'Bechtel QC Inspections and Craft Work Extensive actions have been taken by Bechtel Con-struction to improve the quality of work and increase the effectiveness of QC inspections and to improve craft work.
The actions include:
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l A.
QC Effectiveness Program l'
The QC Effectiveness Program requires a Lead QC or QC Supervisor to ' perform reverification in-l spections of accepted installations.
The inspec-j'
-tions are to detect'QC errors and determine com-3 pliance to. design drawings, specifications and
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procedures.
The ' results of the reverification inspections are routed through the Project Quality
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Control Engineering - (PQCE) office for corrective i
actions, such as training sessions or reinspec-j tions.
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B.
Craft and Field Engineers Effectiveness Pro-gram This Program implemented a tracking and re-porting system to determine the effectiveness of r
Craft and Field Engineers to perform installations j
properly and to conduct inspections which identify j
and correct all problems prior to final QC inspec-tion.
All accept-reject information is forwarded to-the PQCE office on a daily basis for' review and j
tracking.
The results are also reviewed twice r
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e monthly' by the Project Construction Manager for applicable corrective action.
C.
Quality Talks This Program requires participation of all construction and subcontract personnel.
Approxi-mately 190 " Quality Talk" meetings are held each Tuesday, using a published agenda providing a forum for quality-related matters to be discussed.
Old business is also discussed which provides a feedback mechanism on questions or comments raised in previous sessions.
D.
Corrective Action Reverification Program (CARV)
The CARV Program was established to reverify the effectiveness of previous corrective actions taken for selected quality problems which (1) were serious enough to have been reported to the NRC; (2) have a history of recurrence; or (3) may be generic.
Results of these actions to date reveal an in-creased quality product as measured by the Acceptance-Rejection Monitoring Program.
Also, awareness of the need for quality has increased as a result of the Quality Talk Program.
10.2 Improving QA Effectiveness QC effectiveness has not been the only area of concentration.
Another area which has received increased attention is in QA effectiveness.
QA Monitoring-Surveillance Programs have undergone review for their adequacy.
As a result, some key areas have been targeted as requiring greater emphasis and management attention.
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. 19
.A.
The Bechtel Audit Program has now been'
_ geared to place increased. emphasis on physical or hardware verification-activities.
B.
The Bechtel Surveillance Programs'will-review physical work activities which have been completed as well as the programmatic controls utilized.
10.3.-Improvements in APS QA/QC Programs-4 Corrective Action has not been -limited to Con-1 struction QA/QC activities.
APS has performed an evaluation i
- of its QA/QC activities z.nd has taken action to prevent deficiences from occurring in its areas of responsibilities 5
as' outlined below.
A.
APS has established a Quality Control Effectiveness Program similar to that described in Item A - of Section 10.1 above.
This Program is.
B.
Training of APS QC personnel is being j
developed and coordinated through the Corporate QA Training Section.
The Corporate Training Section i
will review and monitor certification and qual-ification.
C.
Personnnel associated with the Project have been and are required to view a video' tape prepared by. APS regarding the quality of work l
required and expected on the Project.
D.
APS QA has focused a large effort toward
_ rectifying the need for overall improvement in.the i
APS Corrective Action System in the areas'of time-liness and effectiveness.
In addition, greater-i management attention has been directed toward identifying the root cause of a problem and the effectiveness of a resolution.
The.APS-Corrective I
Action Procedure has been completely rewritten to provide comprehensive action on the part of the responsible organizations, including root cause analysis, when responding to a cited deficiency.
Additionally, procedural controls have been estab-lished which will escalate Corrective Action Reports to higher levels of management when re-sponses are untimely or inadequate.
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A weekly program to provide and exchange information to and among all QA/QC personnel is being planned and will be implemented in late July, 1984.
10.4 Control of Subcontractor Work In the area of control of subcontractor work, APS management was aware of the problem as a result of physical verification audits performed in late 1983.
These audits included the Fire Protection System and'the Security System.
As a result, APS QA identified and reported a trend to APS and Bechtel Project Management concerning ineffective sub-contractor control.
Subcontractor control has been dis-cussed at recent monthly Bechtel/APS Management Quality Meetings and Executive Review Meetings.
As a result of these actions, a plan has been developed to accomplish two objectives.
1.
Improve effectiveness of subcontractor work and QC inspections.
2.
Evaluate each subcontractor performing safety-related or important-to-safety work to see if additional reviews, inspections or controls are required.
To accomplish the first objective, several pro-grams have been strengthened or developed.
Some examples i
include:
A.
Bechtel Construction QC surveillance of "Q" subcontract documentation and work activities are conducted on a daily basis.
When a subcon-tractor is actively involved in "Q" work, a QCE will be assigned to survey the activities.
B.
The Field Subcontracts organization has been instructed to direct the subcontractors to - ~ - -
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submit and document, via the supplier Design Deviation Request (SDDR) process, all requests for deviations from specifications.
C.
A process has been instituted to review all subcontractor documentation for completeness and compliance to the subcontract for all work performed.
D.
More emphasis has been placed by QA on surveillance of hardware installations.
E.
All new construction subcontract per-sonnel are required to attend a Quality Orienta-tion Program.
To accomplish the second objective, the method and frequency of monitoring the work of each quality related subcontractor has been reviewed and evaluated to determine if sufficient evidence is available to gain confidence that subcontractor activities were performed correctly.
The results of these actions and of past audits and surveillance findings, indicate that, with the exception of the heating, ventilation and air conditioning (HVAC) and fire protection subcontractors, there is no evidence that reinspection activities need to be initiated.
Based on recent Deficiency Evaluation Reports (DER's), Corrective Action Requests (CAR's) and audit findings, increased sur-veillance and monitoring activities of the HVAC and fire protection subcontracted work have been instituted and will be continued.
In addition, as stated previously, increased focus by QA on hardware installation activities has been instituted. -
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x 10.5 Conclusions
.In summary, the corrective actions that have been described have resulted-in an increased. awareness of the im-
.l portance of quality, an improved ' effectiveness ~of. QC -in-i i
.spect ons and improved control of' subcontract work.
QA and management are now able to more readily identify root causes' and take timely action.
1 With respect to previously' accomplished work, it is not impossible that minor deficiencies may still be
-found.
Nevertheless,-in the light of the findings to date i
from extensive inspections and reinspections, testing and 3
' retesting, evaluations and other corrective actions that have been taken, APS is confident that Palo Verde has been constructed to a high level of quality and safety.and that
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any deficiencies that have not been uncovered are indeed i
j minor and will have no effect on the safety of Palo Verde.
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Section 11.0 Piping Systems and Supports I
(SALP Report,Section IV.C.3)
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Board Recommendation:
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" Licensee management should ensure i
that corrective action taken in response i
to identified problems is comprehensive, timely and effective.
While this ap-1 pears to have -been done for the ' CAT findings, performance is not consistant (sic) in-this functional area.
Licensee actions ' regarding QC effectiveness were j-included in the Board recommendation for i
area C.2."-
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Response
See Section 10.0 of this Response.
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l Section 12.0 Safety Related Components (SALP Report,Section IV.C.4)
Board Recommendation:
" Greater licensee attention should be given to the APS/CE interface in-cluding offsite activities to identify the underlying problems that have led to the reportable deficiencies.
Aggressive management action should be taken to en-sure a proper and stringent adherence to QC qualification requirements."
Response
Increased emphasis nas been and will continue to be placed on the APS/CE interface.
Combustion Engineering is an integral part of many meetings and review groups, such as the weekly Project Staff Meeting and the Test Working Group.
Additionally, an APS/CE Management QA Meeting has been established since May, 1984 to discuss quality prob-lems.
Further, the interface within Combustion Engineering between on-site and off-site is becoming more formalized.
During an upcoming audit of Combustion Engineering's Home office, increased emphasis will be placed on:
1.
Deficiency Evaluation Reports (DER's) initiated as a result of equip-ment failure to determine the underlying problems of the design failure.
2.
Nonconformances initiated by combustion Engineering with " Accept-As-Is" and " Repair" dispositions to assure the engineering justification is substantiated by backup data.
3.
Corrective Action taken as a result of identified deficiencies as-sures that the cause of the condition is determined and action taken will pre-clude repetition..- -
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t Additionally, action has been initiated to review and evaluate QC qualification.
If additional action, not already described to the NRC, is required, such action will be taken promptly following identification of a deficiency.
Section 13.0 Support Systems (SALP Report,Section IV.C.5)
Board Recommendation:
"The licensee should increase man-agement attention to subcontracted work and ensure that identified issues such as nonconformance reporting and engi-neering changes are properly performed."
"The licensee actions regarding QC final inspection effectiveness are dis-cussed in Section C.2 of this SALP re-port."
j
Response
See Section 10.0 of this Response i
Section 14.0 Electrical Power Supply and Distribution l
(SALP Report,Section IV.C.G) j Board Recommendation:
"The licensee should take aggres-sive action to ensure QA precepts are understood and practiced by craft, sup-ervision and the QC organization."
"The actions regarding QC final in-spection adequacy are addressed in Sec-tion C.2 of this report."
Response
l See Section 10.0 of this Response.
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s Section 15.0 Instrumentation and Controls (SALP Report,Section IV.C.7)
Board Recommendation:
"The licensee should maintain an aggressive program of overview of the vendor products and onsite work."
Response
APS will continue its aggressive program of over-view of vendor products and onsite work.
Section 16.0 Licensing Activities (SALP Report IV.C.8)
Board Recommendation:
l "The licensee should apply more management attention to the remaining licensing issues so that responses are timely and sound."
Responses:
APS management will continue its active and ag-gressive attention to the remaining licensing issues so that responses are timely and sound.
With respect to backfitting of previously approved designs to meet new or changed regulatory requirements, the right to challenge and appeal is clearly provided by NRC regulations and practice.
An occasional judicious exercise of such rights should not be cited as demonstration of the lack of aggressive response to NRC initiatives.
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