ML20133J282

Concurs W/Actions Taken or Underway Re Emergency Preparedness,Quality Programs & Administrative Controls Affecting Quality & Licensing in Util 850803 Response to SALP Repts 50-416/85-12 & 50-417/85-03

ML20133J282
Person / Time
Site:	Grand Gulf
Issue date:	10/10/1985
From:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Richard J MISSISSIPPI POWER & LIGHT CO.
References
NUDOCS 8510180360
Download: ML20133J282 (5)

See also: IR 05000416/1985012

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October 10, 1985

Mi ssippi Power and Light Company

TTN: Mr. J. B. Richard

Senior Vice President, Nuclear

P. O. Box 23054

Jackson, MS 39205

Gentlemen:

SUBJECT: SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE, REPORT NDS. 50-416/85-12  !

AND 50-417/85-03 [

This refers to the NRC's Systematic Assessment of Licensee Performance (SALP)

Board Report for your Grand Gulf facility which was sent to you on July 23, 1985; ,

our meeting. of July 30, 1985, at which we discussed these reports; and your

written comments dated August 3, 1985, relative to the SALP report.

After careful review of the comments contained in your response to the SALP

report, I concur that the actions taken or underway in the areas of Emergency

Preparedness, Quality Programs and Administrative Controls Affecting Quality, and

Licensing should be effective.

No reply to this letter i,s required; however, should you have any questien

concerning these matters, I will be pleased to discuss them with you.

Sincerely,

Original Signed by

J. N. Grace

J. Nelson Grace  !

Regional Administrator  ;

Enclosure: t

Appendix to Mississippi Power and

Light, Grand Gulf Units 1 and 2

SALP Board Report (dated July 23,  !

1985)

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. D. Kingsley, Vice President <

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K. F. Dale, Director, Nuclear Licensing }

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vr. T. Lally, Manager of Quality Assurance

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- October 10, 1985

ENCLOSURE

APPENDIX TO MISSISSIPPI POWER & LIGHT COMPANY

GRAND GULF UNITS 1 & 2

SALP BOARD REPORT

(DATED JULY 23,1985)

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October 10, 1985

I. Meeting Summary

A. A meeting was held at 10:00 a.m. on July 30, 1985, at your Grand Gulf

facility in Port Gibson, Mississippi to discuss the SALP Board Report.

B. Licensee Attendees

D. C. Lutken, Chairman of the Board and Chief Executive Officer

W. Cavanaugh, President and Chief Operating Officer 4

J. B. Richard, Senior Vice-President

J. Moore, Assistant Vice-President for Informational Services

0. D. Kingsley, Vice-President, Nuclear Operations

J. E. Cross, General Manager

L. F. Dale, Director, Licensing and Safety

T. H. Cloninger, Director, Nuclear Engineering and Construction

S. M. Feith, Director, Quality Assurance

L. L. Tyrone, Acting Director, Nuclear Services

C. R. Hutchinson, Manager, Plant Maintenance

S. H. Hobbs, Manager, Nuclear Safety and Compliance

J. W. Yelverton, Manager, Plant Support

J. G. Cesare, Manager, Nuclear Licensing

W. J. Wright, Manager, Plant Operations

W. E. Edge, Manag,er, Quality Assurance Programs

S. F. Tanner, Manager, Site Quality Assurance

J. E. Reaves, Manager, Suppliers Quality Assurance

J. D. Harrington, Acting Manager, Nuclear Support

L. Daughtery, Compliance Superintendent

J. V. Parrish, Chemistry / Radiation Superintendent

R. H. McAnulty, Electrical Superintendent

R. G. Williams, Office Services Superintendent

J. L. Robertson, Operations Superintendent

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G. A. Ellis, Security Superintendent

K. E. Beatty, Training Superintendent

J. C. Roberts, Technical Superintendent

R. F. Rogers, Technical Assistant

G. O. Smith, Environmental Supervisor _'

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J. C. Vincelli, Radiation Contamination Supervisor

G. D. Chamon, Operations Training Supervisor '

P. B. Benedict, Emergency Planning Coordinator

W. J. Hendry, Nuclear Safety Coordinator

J. O. Ely, Nuclear Safety Coordinator '

J. D. Bailey, Compliance Coordinator . ri-

W. A. Russel, Operations Assistant -

C. W. Angle, Principal Engineer Operational Analysis

C. E. Covaend, Quality Assurance

C. W. Heard, Quality Assurance

G. W. Ingram, Quality Assurance

R. L. Seans, Quality Assurance

L. C. Burgess, Quality Assurance i

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C. NRC Attendees

J. N. Grace, Regional Administrator, Region II (RII)

R. D. Walker, Director, Division of Reactor Projects (DRP), RII

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J. Philip Stohr, Director, Division of Radiation Safety

and Safeguards, RII

V. W. Panciera, Chief, Reactor Projects Section 28, DRP, RII

i R. C. Butcher, Senior Resident Inspector, Grand Gulf, RII

J. Caldwell, Resident Inspector, Grand Gulf, RII

L. Kintner, Project Manager, Operating Reactors Branch, Division of

Licensing, Office of Nuclear Reactor Regulation

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II. Licensee Comments

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Licensee comments submitted in response to the SALP Board Report for Grand

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Gulf follow.

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jj MISSISSIPPI POWER & LIGHT COMPANY

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MI P. O. B O X 16 4 0. J A C K S O N. MIS SIS SIP PI 39215-1640

wucuan uce=uwo a weTv oteaaTMENT August 29, 1985 -

U. S. Nuclear Regulatory Commission . . ,

Region II ,,

101 Marietta St., N.W., Suite 2900

Atlanta, Georgia 30323 c,

Attention: Dr. J. Nelson Grace, Regional Administrator -

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Dear Dr. Grace: -

SUBJECT: Grand Gulf Nuclear Station

Unita 1 and 2

Docket Nos. 50-416 and 50-417

License No. NPF-29

File: 0260/15521

Response to SALP Report

(Nos. 50-416/85-12 end

50-417/85-03)

AECM-85/0267

_ Your letter dated July 23, 1985, transmitted the Systematic Assessment of

Licensee Performance (SALP) report for the Crand Gulf Nuclear Station (CGNS)

facility fer the period Octcber 1, 1983 through April 30, 1985. On July 30,

1985, members of our staff and the CGNS Safety Review Committee met with you

and men;bers of your staff to review the results of the report. Mississippi

Power & Light Company (MP&L) is responding to that report via this letter. -

MP&L endorses the SALP concept and believes that objective evaluations of

licensee performance benefit the licensee, the NRC, and the public by

identifying and focusing attention and resourcac on matters important to safety

of plant operations. MP&L is cocnnitted to operating CGNS safely and in -

accordance with all applicable regulations. Accordingly, va intend to be

responsive to the conclusions and recommendations discussed in your report. -

MP&L believes that a candid and cooperative relationship chould exist

between the NRC and its licensees in order to promote the free Interchange of

information necessary to facilitate the regulatory process and enhance nuclear -

safety. We believe that this sort of relationship exists between MP&L and

your office and intend to maintain the spirit of cooperation that has

characterized our dealings in the past. Further, we have recognized and

addressed the areas where past SALP reports have shown that our operations

needed additional management attention and believe that the significant

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improvements documented in this SALP report provide evidence that we have

been responsive and are committed to nuclear safety in the operation of Crand

Gulf Nuclear Station.

MP&L was pleased with your assessment that there has been marked

improvement in the areas of plant operations, maintenance, and surveillance

activities and that startup testing, radiological controls and fire protection

were also improving. Of particular note was your assessment of our security

operations as a Category 1.

MP&L appreciates your observations that the identified weaknesses in this

SALP report occurred early in the rating period, that MP&L has taken

aggressive corrective action to address them, and that the performance trend

is improving. We believe we have worked diligently to address concerns that

occurred in late 1983 and early 1984 before receiving the full power

operating license for Grand Gulf and that our performance in all areas over

the last year has been fully acceptable and supportive of safe plant

operations. Additionally, your report recognized our commitment to and active

pursuit of improved performance in the future.

In accordance with your letter of July 23, 1985, the following address

the actions MP&L has taken or plans to take in response to each Category 3

rating:

Emergency Preparedness

We have reviewed your comments and our records or activities in this

area. We acknowledge some weaknesses exhibited during the April, 1984

full scale exercise and have taken aEFressive corrective action on

these items and subscquently cenducted a fully successful exercise in

Feb ruary , 1985. We believe our prograt has been inproving during this

SALP period, but acknowledge that we can and should improve further. The

following describes ~ actions that have been taken or are underway to -

further improve this area:

1. Procedure 10-S-01-05 has been revised to resolve NRC concerns and the

associated violation has been closed. _

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2. MP&L responded to the four NRC identified inconsistencies in Emergency

Plan Revision 8 and 9 via letters in March and July 1985. Revision 10 -

to the Emergency Plan incorporates MP&L's commitments and is expected

to be issued in September, 1985.

3. The weaknesses identified during the 1984 exercise have been addressed -^ -

and resolved as demonstrated by MP&L's performance during the 1985

exercise, which was characterized by the NRC as " fully successful".

4. Concerning effective coordination with the State of Mississippi on

emergency news information, MP&L initiated monthly EP Status Meetings

with state and local officials in June, 1984 to addrens and resolve

concerns generated from the April 1984 exercise. These meetings were

, not limited to emergency news information and have significantly

! enhanced inter-organization coordination.

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5. MP&L is increasing management attention to this area, in that, for

the next several months the Emergency Planning Coordinator will be

functionally reporting directly to the Director, Nuclear Licensing

and Safety in order to focus day-to-day upper level management

attention on emergency preparedness. Additionally, MP&L will request

by separate communication that it begin holding quarterly EP status

meetings with NRC similar to those presently being conducted in the

licensing area.

Training

As discussed in the SALP report, this area was considered to be at a

Category 2 during the latter half of the rating period and improving. The

report did not recommend any increase in NRC inspection activity or change

in licensee management attention. Corrective actions taken to address

previous NRC concerns in this area are well documented and NRC has

recognized their effectiveness. Consequently, no further discussion is

presented here.

Quality Programs And Administrative Controls Affecting Quality

MP&L understands the NRC's comments and observations and acknowledges that

improvement needs to be made in some areas of this program. Consequently,

, the following actions have been or are being taken:

1. The site Monitoring Audit Report has been reformatted to

specifically highlight field observations. This emphasizes the

icportance of field work to the auditor and displays a more

obvious " quality presence" to operating personnel.

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2. Several QA Department personnel have cocpleted training in the -

BWR systems course thereby increasing technical knowledge.

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3. Training has been initiated in the area of quality improvement

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versus simply auditing for compliance. .

4. MP&L is actively pursuing INPO accreditation of the QC training _

program.

5. QA has accepted major new responsibilities in the areas of NDE,

ISI, & visual inspection which requires day-to-day contact with -._

Plant Staff organizations.

6. The reorganization and subsequent merger of the Plant Quality

Section into the corporate Quality Assurance Department became

effective on April 1, 1985. This merger, plus the implementation

i of staffing study recommendations, has served to increase the

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overall QA effectiveness and address the NRC's concern regarding

the line organization's direct responsibility for quality, 1

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7. Management changes have occurred within and directly above

Nuclear Plant Engineering to improve this group's effectiveness

and performance. More emphasis is being placed on the areas

identified as needing management attention.

Performance in the " Quality Programs & Administrative Controls

Affecting Quality" category is recognized by management to be the

responsibility of all members of the Nuclear Production Department (KPD).

The QA Department will continue to work with other NPD organizations to

increase their quality program implementation effectiveness. Similarly,

the QA Department intends to increase its effectiveness through additional

training in technical areas & assessment techniques; continued high level

of presence in daily plant activities; and new emphasis on quality

improvement.

Licensing

MP&L recognizes that this rating is predicated to a large degree on two

recently proposed enforcement actions for issues going as far back as 1980.

Corrective actions have been taken to address the issue of accuracy of NRC

submittals. Specifically, MP&L has implemented a comprehensive information

certification procedure. This procedure requires verification of

information and personal sign-off by MP&L staff and management prior to

submittal to the NRC and replaces the less structured practices which were

used previously. The procedure includes a written sign-off by a chain of

individuals to ensure that responsibility and accountability for the

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accuracy of submittals is personalized. MP&L believes that through this

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procedure of redundant checks, it has enhanced substantially its ability to

fulfill the fundacental obligation that it has as an NRC licensee to

provide accurate information in all submittals.

The Nuclear Licensing and Safety Department has developed and implemented

a work control and action tracking system which requires that activities -

necessary to respond to the NRC on issues be positively assigned to

responsible individuals and tracked to ensure due dates are met. This

system is used by department management personnel to ensure that proper

priority is assigned, that work is ongoing, and that work is completed

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and documentation developed and transmitted in a timely manner.

The reorganization of the Nuclear Production Department in May, 1984 placed -

more emphasis and management attention on the licensing function.

Additionally, the Vice President - Nuclear Operations is devoting a

significant amount of his time in overseeing activities in this area.

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MP&L expects continued improvement as a result of these actions.

We appreciate the efforts of you and your staff in helping identify areas

where improvement of our operations is needed. We believe the corrective

. actions we have taken have been effective and expect continued improvement in

the future. We look forward to positive indications of this in the next SALP

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report.

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AECM-85/0267

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We shall be happy to discuss this response or answer any questions

you have.

Yours truly,

L. F. Dale

Director

LFD: dam

ec: Mr. J. B. Richard

Mr. O. D. Kingsley, Jr.

Mr. R. B. McGehee

Mr. N. S. Reynolds

Mr. H. L. Thomas

Mr. R. C. Butcher

Mr. James M. Taylor, Director

Office of Inspection & Enforcement

U. S. Nuclear Regulatory Commission

Washington, D. C. 20555

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