ML20147B759
| ML20147B759 | |
| Person / Time | |
|---|---|
| Issue date: | 02/23/1988 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | Wilgus W BABCOCK & WILCOX OPERATING PLANTS OWNERS GROUP, FLORIDA POWER CORP. |
| References | |
| NUDOCS 8803020185 | |
| Download: ML20147B759 (3) | |
Text
-
e
%[s e
.. ...,jog UNITED STATES
! o NUCLEAR REGULATORY COMMISSION
$ t N WASHINGTON, D. C. 20555 k.....,/ February 23, 1988 Mr. Walter S. Wilgus, Chaiman B&W Owners Group Evaluation Comittee Florida Power Corporation 3201 34th Street South P.O. Box 14042 St. Petersburg, Florida 33733
Dear Mr. Wilgus:
SUBJECT:
BABCOCK AND WILCOX OWNERS GROUP (BWOG) PROGRAM TO EVALUATE UTILITY DISPOSITIONS OF SAFETY AND PERFORMANCE IMPROVEMENT PROGRAM (SPIP)
RECOMMENDATIONS In ycu letter of November 24, 1987, you nnted that a program of the type astablished by the BWOG would ensure the quality of the impicmentation of the recomendaticos by each nenber utility.
We corcur with the first phasa of your program, the evaluation for membar utilities progres for managirq SPIP recomendations, for which the BWOG Executive Comittee has established an evaluation team with a predetemined schedule for reviewing each of the utilities progran by mid-February 1988. We also concur with the remaining two phases of your program, the assessment of the technical adecuacy of the implementation of the recomendations by each utility and the monitoring of the schedule for implementation. Hewever, your letter contained no schedule for completion of either of these two phases of the program.
In your letter of December 21, 1987 which provided coments on the NRC staff's rafety evaluation report (SER) on the BWOG plant reassessment prograr, you stated that it may not be possible to provide an implementation schedule by June 1.1988 for most of the recomendations, as requested, because further evaluation and potential follow-up actions may be required. In addition, you further stated that forral orders are not needed since the BWOG recorrendation tracking system (RTS) through periodic updates will provide the status of pro-gress and schedular infomation requested by the NRC staff in the SER.
The staff concludes that your program and the RTS should help achieve your goals. We note, however, that there is not an Owners Group authority that can assure that those goals and objectives are actually accomplished by each indi-vidual utility.
Since the BWOG lacks the authority to enforce comitments, the NRC staff in the SER recomended that the individual utilities rather than the BWOG provide schedules for implmentation of the recomendations. These implerentation schedules should be signed by a representative of the utility authorized to make such comitnants. Although tha staff recognizes that your December 21, '
- y, ))
1987 letter states it is not possible to provide an inplenentation schadule
.\
esoaoames eso22a DR TOPRP ENVB 'g}
, d -
Kalter S. Wilgus for most of the reconscendations by June 1.1988, it is requested that by that date the individual utilities provide a schedule for implenentation of those recomendations that have been evaluated and a tentative schedule for those recomendations requiring further evaluation with justification for the delays in implenentation.
The use of the implementation schedules provided by the utilities, if determined to be appropriate by the staff, would be acceptable provided these schedules are updated en a regular basis to include the remaining recorrendations and early notification of schedular slippages with adequate justification. The BWOG recorcenaation tracking system (RTS) could still be used by the staff to determine the progress being made overall by each individual utility on a regular basis.
The staff believes that completion of implementation.for the SPIP recomen-dations will result in an increase in plant safety and a decrease in the number and complexity of plant transients. As a result, the staff intends to assure that the recoceendations are appropriately and expeditiously implemented by closely monitoring the utilities progress to assure they are implemented on the schedule comitted to by the utilities. The NRC Project Managers for each B&W designed plant will be responsible for tracking these schedular conmitments.
If progress is deemed not to be acceptable the staff will consider the initia-tion of regulatory actions on a plant specific basis. We intend to inform each individual utility of this position.
The staff has also received the November 1987 update to the RTS report and compared this to the July and September 1987 updates. Although it is recog-nized that this may not be representative of actual progress made, the staff is nevertheless concerned by the fact that the numbers show little progress appears to have been made in itiplementing the recomerdations between these reporting periods. Based en a discussion with William O' Conner of Toledo Edison it appears that this apparent lack of progress may in part be due to guidance the BWOG has provided to the utilities. For enmple the utilities have been infomed that a reconnendation cannot be changed from the "evalue-tion" to the "implertentation" category until a firm in:plementation date has been established. Since it is the BWOG intent to utilire the RTS to keep the staff inforn.ed of progress it is reconmended that either more detail be pro-vided directly in the RTS report or that the BK0G provide as an enclosure to the RTS update report transirittal letter supplemental information for the staff to evaluate progress of the program.
If the approach described is acceptable to the BWOG and the utilitics, it is proposed that a meeting between the NRC staff, the Sh00, and utility representa-tives be held in the NRC office in Rockville. Maryland sometime in March to discuss the details of the schedular comitments for implen.cntation of the recomendations and to identify the additionel information needed to augment what is currently presented in the updated RTS reports.
In addition, as previously mentioned in our SER, we intend to verify through independent NRC staf f audits, that the Bh06 recomendations have been satisfac-torily implerrented by the utilities (ircluding installaticn where required).
We expect that the utilities implementation reccrds will support our efforts.
i, . .-
. Walter S. Wilgus. i Please contact Byron Siegel, the Lead Project Manager for the BWOG reassessment program at (301) 492-3019 to arrange a meeting date or if you have any questions regarding :this letter.
- Sincerely.
- Original sisnod by Dennis M. Crutehtield Dennis M. Crutchfield, Director Division of Reactor Projects -:III.
IV, Y and Special Projects Office of Nuclear Reactor Regulation DISTdBUTION
% cket File NRC & Local PDRs PDf4 R/F, D. Crutchfield ADR4/ Collins J. Calvo P. Noonan B. Siegel OGC-0WF E. Jordan
'J. Partlow ACRS (10) _ ,
Subject File
. T. Murley.
J. Sniezek F. Miraglia
.L..Shao A.' Thadant Typed By Cress DOC NAME (LTR TO WILGUS 2/17/88) 0FC: LA:PD :PM:PD :D:PD4 gD: P NME:PNocsan :BSiege :JCalvo :DC i ield bkTE bh)k)b bhbh )b $bh)/1)b bhhh3 b $
OFFICIAL RECORD COPT