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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20198L1911998-12-21021 December 1998 Submits Comments Re Proposed Rule to Revise 10CFR50.59, Changes,Tests & Experiments ML20198L1361998-12-15015 December 1998 Comment Opposing Proposed Rule 10CFR50.65 Re Requirements for Monitoring Effectiveness of Maint of NPP ML20217J2161998-03-27027 March 1998 Comment on Proposed Generic Communication Re Lab Testing of nuclear-grade Activated Charcoal ML20217F5361998-03-25025 March 1998 Comment Opposing Draft Regulatory Guide DG-1071, Std Format & Content for Post-Shutdown Decommissioning Activities Rept ML20199J4651998-01-22022 January 1998 Comment Opposing Draft RG-1070, Sampling Plans Used for Dedicating Simple Metallic Commercial Grade Items for Use in Npps. RG Unnecessary Based on Use of EPRI Guideline & Excellent Past History of Commercial Grade Items at DBNPS ML20148M6421997-06-17017 June 1997 Comment on Proposed NRC Bulletin 96-001,suppl 1 Re Control Rod Insertion Problems.Nrc Should Review Info Provided in Licensee 970130 Submittal & Remove Statements of Applicability to B&W Reactors from Suppl Before Final Form ML20134L3401997-01-22022 January 1997 Resolution 96-R-85, Resolution Supporting Merger of Centerior Energy Corp & Ohio Edison Under New Holding Co Called Firstenergy ML20133B6941996-12-18018 December 1996 Submits Ordinance 850-96 Re Approval of Merger of Centerior & Oh Edison Into Firstenergy ML20132A8461996-12-0202 December 1996 Resolution 20-1996 Supporting Merger of Ohio Edison & Centerior Corp Under New Holding Company Called Firstenergy ML20134M6191996-10-28028 October 1996 Proclamation of Support by City of Sandusky,Oh Re Merger of Ohio Edison and Centerior Energy Corp ML20108D9571996-05-0303 May 1996 CEI Response to City of Cleveland 2.206 Petition.Nrc Should Deny Petition ML20097G5731996-02-13013 February 1996 Comment Supporting Petition for Rulemaking PRM-50-63 Re Use of Potassium Iodide ML20097B8721996-01-23023 January 1996 Petition of City of Cleveland,Oh for Expedited Issuance of Nov,Enforcement of License Conditions & Imposition of Appropriate Fines,Per 10CFR2.201,2.202,2.205 & 2.206 ML20101B5841996-01-23023 January 1996 Motion of City of Cleveland,Oh for Partial Summary Judgement Or,In Alternative,For Severance of Issue & Expedited Hearing Procedures.W/Certificate of Svc ML20097B8911996-01-23023 January 1996 Motion of City of Cleveland,Oh for Partial Summary Judgement or in Alternative,For Severance of Issue & Expedited Hearing Procedures ML20096E9781996-01-0808 January 1996 Comment on Proposed Suppl to GL 83-11, Licensee Qualification for Performing Safety Analyses in Support of Licensing Actions ML20087J3611995-08-14014 August 1995 Comment Opposing Proposed Rule 10CFR2 Re Rev of NRC Enforcement Policy ML20086M8241995-06-29029 June 1995 Comment on Proposed Review of NRC Insp Rept Content,Format & Style ML20083M8701995-05-10010 May 1995 Comment on Proposed Rule 10CFR50 Re Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactor ML20081C8841995-03-0303 March 1995 Comment Re NRC Proposed Generic Communication Suppl 5 to GL 88-20, IPEEE for Severe Accident Vulnerabilities. Util Ack NRC Efforts to Reduce Scope of GL 88-20,but Believes That Proposed Changes Still Overly Restrictive ML20077M5831995-01-0404 January 1995 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & low-power Operations for Nuclear Power Reactors ML20072K3611994-08-16016 August 1994 Comment Opposing Proposed Rule 10CFR72 Re Plans for Storage of Sf at Davis Besse NPP ML20072K4411994-08-14014 August 1994 Comment Opposing Proposed Rule 10CFR72 Re Dry Storage of Nuclear Waste at Facility in Toledo,Oh ML20072K5261994-08-12012 August 1994 Comment Supporting Proposed Rule 10CFR72 Re Addition of Standardized NUHOMS Horizontal Modular Storage Sys to List of Approved Sf Storage Casks ML20072B1581994-08-0909 August 1994 Comment Opposing Proposed Rule 10CFR72 on List of Approved Spent Fuel Storage Casks:Addition ML20029D8221994-04-19019 April 1994 Comments on Proposed Rule 10CFR50 Re Codes & Stds for Nuclear Power Plants;Subsection IWE & Subsection Iwl ML20062M4011993-12-28028 December 1993 Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication ML20046A9561993-07-19019 July 1993 Comment on Proposed Rules 10CFR170 & 171, FY91 & 92 Proposed Rule Implementing Us Court of Appeals Decision & Rev of Fee Schedules;100% Fee Recovery,FY93. ML20056C8951993-07-19019 July 1993 Order Extending Time within Which Commission May Rule on Petitions for Review of LBP-92-32.W/Certificate of Svc. Served on 930720 ML20045F8321993-06-22022 June 1993 Comment on Proposed Rule 10CFR26 Re Mods to fitness-for-duty Program Requirements.Concurs W/Proposed Rule in Reducing Random Testing Rate of Licensees to 50% & Disagrees W/ Maintaining Random Testing Rate of 100% for Vendors ML20044E2781993-05-13013 May 1993 Comment Supporting Petition for Rulemaking PRM-50-58 Re VEPCO Petition to Change Frequency of Emergency Planning Exercise from Annual to Biennial ML20044E1561993-04-29029 April 1993 Comment Supporting Petition for Rulemaking PRM-50-58 Re Frequency Change of Emergency Planning Exercises ML20127L8781993-01-19019 January 1993 Comment Supporting Comments Submitted by NUMARC Re Draft Reg Guide DG-1020 ML20127A6171993-01-0606 January 1993 Order.* Time within Which Commission May Rule on Petitions for Review of Board Order LBP-92-32,dtd 921118,extended Until 930208.W/Certificate of Svc.Served on 930106 ML20126D5801992-12-23023 December 1992 NRC Staff Answer in Response to Petitions for Review Filed by Oh Edison Co,Cleveland Electric Illuminating Co,Toledo Edison Co & City of Cleveland.* W/Certificate of Svc ML20126F6501992-12-23023 December 1992 Answer of City of Cleveland,Oh,Intervenor,In Opposition to Petitions for Review of 921118 Decision of Aslb.* Petitioners Petitions for Review Should Be Denied. Certificate of Svc Encl ML20126D5171992-12-23023 December 1992 City of Brook Park Answer to Petitions for Review.* Opposes Applicants 921208 Petitions for Review Based on Fact That ASLB Decision in proceeding,LBP-92-32,adequately Addressed Issues Raised in Petitions.W/Certificate of Svc ML20126D5461992-12-23023 December 1992 Answer of Cleveland Electric Illuminating Co & Toledo Edison Co to Limited Petition for Review of City of Cleveland,Oh of 921118 Decision of Aslb.* Commission Should Deny City of Cleveland Petition.W/Certificate of Svc ML20126D5781992-12-23023 December 1992 Answer of American Municipal Power-OH,Inc in Opposition to Petitions for Review of Oh Edison Co & Cleveland Electric Illuminating Co/Toledo Edison Co.* W/Certificate of Svc ML20126D4761992-12-22022 December 1992 Alabama Electric Cooperative Answer to Applicants Petitions for Review.* Applicants 921208 Petitions for Review Should Be Denied.W/Certificate of Svc ML20126A5461992-12-10010 December 1992 Order.* Requests That Answers to Petition for Review Be Filed No Later than 921223.W/Certificate of Svc.Served on 921210 ML20126A5751992-12-0808 December 1992 Petition for Review.* Requests That NRC Review LBP-92-32, 921118 Board Decision in Proceeding.Board Erroneously Interpreted Section 105(c) of AEA by Ignoring Fundamental Underpinning of Statute.W/Certificate of Svc ML20126A5871992-12-0808 December 1992 Petition for Review.* Requests That NRC Review ASLB 921118 decision,LBP-92-32.Board Erroneously Interpreted Section 105(c) of AEA by Ignoring Fundamental Underplanning of Statute.Certificate of Svc Encl ML20126A7651992-11-18018 November 1992 Limited Petition for Review of City of Cleveland,Oh of 921118 Decision of Aslb.* City of Cleveland Petition for Review Should Be Granted.W/Certificate of Svc ML20115E1771992-10-0808 October 1992 Comment Supporting Draft Mgt Directive 8.6,GL 92-05 ML20105C8971992-09-16016 September 1992 Comment Opposing Proposed Generic Communication Re Generic Ltr Concerning analog-to-digital Replacements Under 10CFR50.59 ML20114A8841992-08-17017 August 1992 Designation of City of Brook Park,Oh of Adopted Portions of Summary Disposition Pleadings.* Brook Park Not Advancing Any Addl Argument or Analysis in Connection W/Designation,Per 920806 Memorandum & Order.W/Certificate of Svc ML20099E1821992-07-28028 July 1992 Comment Supporting Proposed Rules 10CFR20 & 61 Re LLW Shipment Manifest Info & Reporting ML20099A4051992-07-17017 July 1992 Comment on Proposed Rules 10CFR20 & 50 Re Reducing Regulatory Burden on Nuclear Licensees.Supports Rules ML20101R4831992-07-0808 July 1992 Comment Supporting Proposed Rule 10CFR50 Re Receipt of Byproduct & Special Nuclear Matl 1998-03-27
[Table view] Category:PUBLIC COMMENTS ON PROPOSED RULES & PETITIONS FOR
MONTHYEARML20198L1911998-12-21021 December 1998 Submits Comments Re Proposed Rule to Revise 10CFR50.59, Changes,Tests & Experiments ML20198L1361998-12-15015 December 1998 Comment Opposing Proposed Rule 10CFR50.65 Re Requirements for Monitoring Effectiveness of Maint of NPP ML20217J2161998-03-27027 March 1998 Comment on Proposed Generic Communication Re Lab Testing of nuclear-grade Activated Charcoal ML20217F5361998-03-25025 March 1998 Comment Opposing Draft Regulatory Guide DG-1071, Std Format & Content for Post-Shutdown Decommissioning Activities Rept ML20199J4651998-01-22022 January 1998 Comment Opposing Draft RG-1070, Sampling Plans Used for Dedicating Simple Metallic Commercial Grade Items for Use in Npps. RG Unnecessary Based on Use of EPRI Guideline & Excellent Past History of Commercial Grade Items at DBNPS ML20148M6421997-06-17017 June 1997 Comment on Proposed NRC Bulletin 96-001,suppl 1 Re Control Rod Insertion Problems.Nrc Should Review Info Provided in Licensee 970130 Submittal & Remove Statements of Applicability to B&W Reactors from Suppl Before Final Form ML20097G5731996-02-13013 February 1996 Comment Supporting Petition for Rulemaking PRM-50-63 Re Use of Potassium Iodide ML20096E9781996-01-0808 January 1996 Comment on Proposed Suppl to GL 83-11, Licensee Qualification for Performing Safety Analyses in Support of Licensing Actions ML20087J3611995-08-14014 August 1995 Comment Opposing Proposed Rule 10CFR2 Re Rev of NRC Enforcement Policy ML20086M8241995-06-29029 June 1995 Comment on Proposed Review of NRC Insp Rept Content,Format & Style ML20083M8701995-05-10010 May 1995 Comment on Proposed Rule 10CFR50 Re Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactor ML20081C8841995-03-0303 March 1995 Comment Re NRC Proposed Generic Communication Suppl 5 to GL 88-20, IPEEE for Severe Accident Vulnerabilities. Util Ack NRC Efforts to Reduce Scope of GL 88-20,but Believes That Proposed Changes Still Overly Restrictive ML20077M5831995-01-0404 January 1995 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & low-power Operations for Nuclear Power Reactors ML20072K3611994-08-16016 August 1994 Comment Opposing Proposed Rule 10CFR72 Re Plans for Storage of Sf at Davis Besse NPP ML20072K4411994-08-14014 August 1994 Comment Opposing Proposed Rule 10CFR72 Re Dry Storage of Nuclear Waste at Facility in Toledo,Oh ML20072K5261994-08-12012 August 1994 Comment Supporting Proposed Rule 10CFR72 Re Addition of Standardized NUHOMS Horizontal Modular Storage Sys to List of Approved Sf Storage Casks ML20072B1581994-08-0909 August 1994 Comment Opposing Proposed Rule 10CFR72 on List of Approved Spent Fuel Storage Casks:Addition ML20029D8221994-04-19019 April 1994 Comments on Proposed Rule 10CFR50 Re Codes & Stds for Nuclear Power Plants;Subsection IWE & Subsection Iwl ML20062M4011993-12-28028 December 1993 Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication ML20046A9561993-07-19019 July 1993 Comment on Proposed Rules 10CFR170 & 171, FY91 & 92 Proposed Rule Implementing Us Court of Appeals Decision & Rev of Fee Schedules;100% Fee Recovery,FY93. ML20045F8321993-06-22022 June 1993 Comment on Proposed Rule 10CFR26 Re Mods to fitness-for-duty Program Requirements.Concurs W/Proposed Rule in Reducing Random Testing Rate of Licensees to 50% & Disagrees W/ Maintaining Random Testing Rate of 100% for Vendors ML20044E2781993-05-13013 May 1993 Comment Supporting Petition for Rulemaking PRM-50-58 Re VEPCO Petition to Change Frequency of Emergency Planning Exercise from Annual to Biennial ML20044E1561993-04-29029 April 1993 Comment Supporting Petition for Rulemaking PRM-50-58 Re Frequency Change of Emergency Planning Exercises ML20127L8781993-01-19019 January 1993 Comment Supporting Comments Submitted by NUMARC Re Draft Reg Guide DG-1020 ML20115E1771992-10-0808 October 1992 Comment Supporting Draft Mgt Directive 8.6,GL 92-05 ML20105C8971992-09-16016 September 1992 Comment Opposing Proposed Generic Communication Re Generic Ltr Concerning analog-to-digital Replacements Under 10CFR50.59 ML20099E1821992-07-28028 July 1992 Comment Supporting Proposed Rules 10CFR20 & 61 Re LLW Shipment Manifest Info & Reporting ML20099A4051992-07-17017 July 1992 Comment on Proposed Rules 10CFR20 & 50 Re Reducing Regulatory Burden on Nuclear Licensees.Supports Rules ML20101R4831992-07-0808 July 1992 Comment Supporting Proposed Rule 10CFR50 Re Receipt of Byproduct & Special Nuclear Matl ML20101R4791992-07-0606 July 1992 Comment on Draft Reg Guide DG-1021, Selection,Design, Qualification,Testing & Reliability of Emergency Diesel Generator Units Used as Class IE Onsite Electric Power Sys & Nuclear Power Plants.Endorses NUMARC Comments ML20101R6211992-07-0606 July 1992 Comment on Proposed Rule 10CFR50 Re Loss of All Alternating Current Power & Draft Reg Guide 1.9,task DG-1021.Supports Rule ML20096E7861992-05-13013 May 1992 Comments on Draft NUREG-1449, Shutdown & Low Power Operation at Commercial Nuclear Power Plants in Us. Endorses NUMARC Comments ML20095K6501992-04-27027 April 1992 Comment Supporting Draft Reg Guides DG-8010, Criteria for Monitoring & Methods for Summation of Internal & External Occupational Doses, & DG-8011, Radiation Dose to Embryo/ Fetus ML20092D2861992-02-0303 February 1992 Comments on Draft Rev 1 to NUREG-1022, Event Reporting Sys,10CFR50.72 & 50.73,Clarification of NRC Sys & Guidelines for Reporting ML20086T8431991-12-26026 December 1991 Comment on Draft Reg guides,DG-8003,DG-8004,DG-8005 & DG-8006.Proposed Rev to Reg Guide 8.25 Recommends Specific Air Sampling Practices Not Suited to Commercial Power Reactor Industry ML20077C3701991-05-10010 May 1991 Comment Opposing Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery ML20077A9391991-04-29029 April 1991 Endorses NUMARC Comments on Proposed Rule 10CFR50, Codes & Stds for Nuclear Power Plants ML20070T6121991-03-15015 March 1991 Comments on Draft Reg Guide DG-1009, Std Format & Content of Technical Info for Applications to Renew Nuclear Power Plant OLs & Associated Draft Srp.Endorses NUMARC Comments ML20070D5901991-01-30030 January 1991 Comment Supporting Proposed Rule on Secy 90-347 Re Regulatory Impact Survey Rept ML20066B3031990-12-21021 December 1990 Comment Endorsing NUMARC & Nuclear Util Backfitting & Reform Group Comments on Proposed Rule 10CFR50 Re Emergency Response Data Sys ML20058H4381990-10-19019 October 1990 Comment Conditionally Supporting Proposed Rule 10CFR51 Re Scope of Environ Effects Concerning License Renewal Process ML20055F4351990-07-0606 July 1990 Comments on Petition for Rulemaking PRM-50-55 Re Revs to Fsar.Util Agrees That Revising Update Frequency to Following Refueling Outages Would Provide More Timely Reflection of Facility than Current Requirement ML20012C7531990-03-12012 March 1990 Comment on Proposed Rule 10CFR50, Fracture Toughness Requirements for Protection Against PTS Events. Util Endorses NUMARC & Nubarg Comments ML19332G5191989-12-0101 December 1989 Comment on Draft Reg Guide,Task DG-1001, Maint Programs for Nuclear Power Plants. Util Strongly Supports NUMARC Position.Nrc Should Consider Possible Alternatives for Addressing Objectives of Policy Statement ML20245F5701989-08-0101 August 1989 Comment on Draft Reg Guide DG-1003, Assuring Availability of Funds for Decommissioning Nuclear Reactors, Per Request. Suggests Specific Wording Included in App B Be Replaced W/More General Summary of Principle Items to Be Addressed ML20246N5491989-07-0606 July 1989 Comment Opposing Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plants Structures,Sys & Components. Mod to Existing Regulations Would Not Provide Most Effective Course of Action ML20246C8021989-06-19019 June 1989 Comment Supporting Proposed Rules 10CFR50,72 & 170 Re Storage of Spent Nuclear Fuel in NRC-Approved Storage Casks at Nuclear Power Reactor Sites ML20245D2481989-06-16016 June 1989 Comment on Proposed Rules 10CFR50,72 & 170 Re Storage of Spent Nuclear Fuel in NRC-Approved Storage Casks at Nuclear Power Reactor Sites. NRC Must Consider Provision in Rule to Permit Indiscriminate Storage of Spent Fuel at Reactors ML20235V5571989-02-27027 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants. Util Supports NUMARC Position on Proposed Rule ML20206C8451988-11-10010 November 1988 Comment Opposing Proposed Rule 10CFR26 Re Random Drug Testing.Concurs W/Commissioner Roberts That Behavioral Observation by Trained Supervisors Will Detect Drug Abuser W/Less Intrusion of Privacy than Random Testing 1998-03-27
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N h W 57p.'swA7 I eEmmon ENERGY ssy);p g),
Donald C. Shelton 300 Madcon Avenue Vice Presdent Nac! ear Toledo, OH 436520001 Dave Bene (419)2G2300 Docket Number 50-346 License Number NPF-3 q "i
Serial Number 2095 d f]
n October 8, 1992 Fj 'l
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o Chief, Rules and Directives Review Branch a s U.S. Nuclear Regulatory Commission W 1 Vashington, D.C. 20555
Subject:
Comments on Draft Management Directive 8.6, " Systematic Assessment of Licensee Performance," Generic Let ter 92--05, NRC Vorkshop on the Systematic Assessment if Licensee Petformance (SALP)
Gentlemen:
These comments are submitted by Toledo Edison in response to the request of the NRC as stated in Generic Letter 92-05, "NRC Vorkshop on the Systematic Assessment of Licensee Performance (SALP)." Toledo Edison, a subsidiary of Centerior Energy, is partial owner of and is responsible for operation of the Davis-Besse Nuclear Power Station.
Toledo Edison has been authorized for power operation of the Davis-Besse Nuclear Power Station since 1977. As a 10 CFR 50 licensee, Toledo Edison has vested interest in any NRC program changes that may affect the management and operation of Davis-Besse.
Toledo Edison commends the Staff for initiating improvements to the current SALP Program. The program should provide a meaningful vehicle for dia'ogue with the NRC regatding Davis-Besse performance. Towards that end, a review has shown that draft Management Directive 8.6, entitled " Systematic Assessment of Licensee Performance (SALP)" as part of Generic Letter 92-05, includes sections which Toledo Edison believes '
require enhancements or clarifications to ensure an effective SALP process.
Specific comments on draft Management Directive 8.6 are enclosed. In addiclon, general comments on items not spectfled in the draft Management Directive 8.6 are also enclosed. Since the NRC is interested in licensee perspectives on the proposed changes to the SALP Program, Toledo Edison requests the Staff's consideration of the enclosed ct;nments in developing the revised SALP program, opememg companies 9210220036 921008 Clevotond flectnc iliuminutmg PDR PR Toledo Edmon F11SC 57FR39249 PDR
O I "
Docket-Number 50-346 1
License Number NPF-3
' Serial Number 209:
Page 2
~-;
Should you have any questions or require clarification'of any comments #
on'the enclosures, please contact Mr. Robert V..Schrauder, Manager -
Nuclear Licensing at (419) 249-2366.
Very tru yours, n ;
KAF/dle Enclosures cc A. B. Davis, Regional Administrator, NRC Region III' J. B. Hopkins, NRC Senlor Project Manager DB-1 NRC Senior Resident inspector UStIRC Document Control Desk Utility Radiological Safety Board .
s 9
d 4 y y u .r.-._ . . - - . . - _ , , , , , . - - . .
Docket Number $0-346 License Number NPP-3
. Serial Number 2095 Entlosure i Page 1 TOLEDO EDISON'S RESPONSE TO GENERIC LETTER 92-05
- 1. DRAFT Handbook 8.6 Page 7, paragraph 1 " Engineering" Toledo Edison Comments l
- a. The SALP proc, i should evaluate the effectiveness of a plant i modification. Currently the NRC only evaluates the quality of 1 the modification and the modification package. An assessment I should be made to evaluate whether the solutfon engineered and implemented by the modification actually corrects the initiating problem. By comparison, other functional areas (e.g., Security) are credited for a major cystem improvement in that functional area,
- b. The maintenance and execution of the Inservice Inspection and Containment Leak Rate programs is generally under the purview of-Engineering functions and should therefore be evaluated under the Engineering functional area.
- c. Since the SALP is a plant driven process, the effectiveness of generic corporate engineering programs and directives are not .
comprehensively evaluated. Such evaluations _ vill be helpful for licensees to further improve performance in this area.
- d. A significant portion of engineering resources.is devoted to identifying and implementing ways of improving plant operation- ,
rnd reliability. The result of these efforts can reduce concerns such as scram frequency, safety syste, unavailability, and source term. These efforts should be incluoed in the Engineering assessment.
- 2. DRAFT Handbook 8.6 Page 7, paragraph 2 "This functional area covers all activities related to plant support functions, including radiological controls, emergency preparedness, security, housekeeping controls, chemistry, and fire protection."
Toledo Edison Comments i
- a. The elevated importance of Radiological Protection at nuclear facilities in combination with public opinion and awareness of radiological effects on the population and environment supports a stand alone functional area for Radiological Protection.
Radiological Protection is an area that demonstrates the
... - - . -_ - _, . = ~ . . . . , , - - . - . - . - - -..a. . . . . . . .
Docket Number 50-346
' License Number NPF-3
. Serial Number 2095 Enclosure 1 Page 2-overall effectiveness of a licensee's organization. Toledo '
Edison believes that Radiological Protection requires the attention and-is better presented in the SALP process and SALP Report as a separate functional atJa.
- b. Toledo Edison believes that fire protection should not be specifically incorporated into the_ Plant Support functional area. Fire Protection has been treated by licensees and the Staff as a regulated compliance issue. _Thetefore, this issue should not differ from any other regulated issues. The Engineering, Operations, and Maintenance. organizations all have unique responsibilities in implementing and continuing to be in compliance with the fire protection-requirements. The assessment of fire protection activities should either be :
encompassed into the applicable functional areas, or be-assessed independently as a "special" short-term functional atea as described in the Draf t llandbook (page 7, paragraph 3).
- 3. Draft llandbook 8.6 Paga 12, paragraphs 1 and 2 "NRC should examine licensee per formance during the assessment period to deterrane whether a trend exists. ... The performance trend should be determined us ;ectively and should be reserved for those instances in which it is necessary to focus the attention of NRC and the licensee on an area vith a declining performance trend, or to acknowledge an improving trend in licensee performance."
Toledo Edison Comments The criteria for. establishing " improving" and " declining" performance trends are not specified in the handbook. Toledo Edison believes that it vould be difficult to establish clear and
~
consistent trending criteria for all licensees, and therefore, trending designations should be eliminated from the performance rating. Since the current process is inconsistent and misinterpreted, the trending analysis should be limited to the discussion sections of the report. If the Staff plans to utilize the trending designation, Toledo Edison believes that a seven tier rating system (i.e., 1, 1 ,2+,2,2 ,3+,3) 1s a better rating method for SALP assessment. An improving or declining trend would be self explanatory by a change in rating. A seven tier system would also n11ov attention to be more-focused on the applicable assessment' period. Ilistorically it appeared that previous performance may had:
influenced the Staff in SALP evaluations. For example, a Category I rating may not have been received because of average performance (i.e., Category 2) in the previous assessment period.
t
Docket Number 50-346 a
License Number NPP-3 I Serial Number 2095 i Enclosure 1 Page 3 In addition. Toledo Edison believes the NRC Staff does not consistently follow the guidance presented in the !!andbook. Since
" sustained performance" from previous assessment periods is not 'l included as an Evaluation criterion (page 10, paragraph F), .j functional areas should be evaluated on performance during the '
applicable SALP period. In addition, it appears the majority of l the SALP report contents have pertained to issues that arose in the l latter portions of assessment periods. Many-issues in the beginning of the period are not mentioned.
- 4. Draf t 11andbook 8.6 Page 18, paragraph 2 "The transmittal letter should strive to characterire NRC's confidence in or concern with the licensee's performance and the underlying reasons therefor and should place in perspective any significant events or findings that took place outside the assessment period that bear on the evaluations in the i report."
Toledo Edison Comments This statement allows the Staff to consider events that occurred outside the assessment period to influence the performance ratings. The trending criteria (see comment 4) suggest that evaluations be limited to the applicable SALP period.. The draft llandbook should be consistent in the valuation process for assessing licensee performance. Evei.cs that occurred outside the period should be reflected in the corresponding assessment periods. As a minimum, the statement on page 18 should be supported by examples to clarify its intent.. Page 12, paragraph 1 of the draft flandbook states:
"NRC should examine licensee performance during.the assessment period to determine whether a trend exists." l Page 15, paragraph 4 of the draft Handbook statest "All board voting members should (1) have visited the site during the assessment period and reviewed 1,lant performance and (2) be familiar with inspection report findings that vere issued during the assessment period.
The aforementioned sections of.the draft Handbook stress evaluation of licensee performance during the assessment period. l b
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l l
. - - . _ - - . _ - - - - . = . - - = . . - - .
Docket Number 50-346
. .' License Number NPF-3 Serial Number 2095 Enclosure 2 Page 1 TOLEDO EDISON
S
- 1. The draft Handbook 8.6 Introduction states
" Unacceptable performance is addressed through various NRC programs and policies, and the implementation of these activities should not be delayed to avait the results of a SALP assessment." ... "The SALP ... is not intended to propose problem resolutions or solutions."
Occasionally, licensees have been " surprised" by issues that vere not specifically identified or discussed in inspection reports or docketed correspondence by the NRC Staff. This situation resulted in additional time and expense by both the NRC and the licensees _
on issues that should have been resolved dnring the assessment period. In addition, new issues may ca"se irreparable damage to the licensee regarding press and publi. apinion. Therefore, the SALP report s.ould be consistent with SALP Program guidance.
- 2. 'the draft llandbook does not contain provisions for extending or decreasing SALP periods for licensees who have undergone Senior Resident Inspector and/or designated NRC management changes during the assessment period. Toledo Edison has experienced periods without Senior Resident Inspectors and designated Project Managers.
Staff changes place the licensee at a disadvantage since the direct line of communication is lost.
The draft Handbook states on page 15, paragraph 4:
"To effectively support the goals of the " Overview" section of the report, it is impor*'nt that the board voting membership remain constant ring the evaluation process.""
Since inspection reports are part of the evaluation process, and the Project Manager and Senior Resident inspector are voting mernbers of the SALP Board, an 18 month assessment period experiencing changes in key staff positions may not result in an adequate and consistent SALP report.
The evaluation frequency criteria should include provisions for NRC Staff changes.
I i