ML20195J523

Informs That Util Concurs W/Nrc Assessment of Current Level of Performance at Plant,Per SALP Rept for Sept 1987 - Aug 1988

ML20195J523
Person / Time
Site:	Comanche Peak
Issue date:	11/28/1988
From:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
TXX-88802, NUDOCS 8812020221
Download: ML20195J523 (2)

Text

F c ,

o 5:::ll'lllllllll: Log i TXX-88802 File # 10130

- IR 87-40 r C IR 87-31 1UELECTRIC November 28, 1988 UONE,1, U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50 445 AND 50-446 COMMENTS ON SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP)

Gentlemen:

By letter dated October 21, 1988 the Nuclear Regulatory Commission (NRC) transmitted its Systematic Assessment of Licensee Performance (SALP) Report for Comanche Peak Steam Electric Station (CPSES) to TV Electric. This report documented the staff's arsessment of the performance of TV Electric with regard to CPSES during the period September 1, 1987 through August 31, 1988.

The staff concluded that TV Electric has established a solid foundation for excellent performance. The SALP Report noted Tb Electric's ongoing commitment to Comanche Peak Response Team and Corrective Action Program activities; the leadership and support provided to CPSES by upper management; the extensive nuclear experience of TV Electric by upper management; its thorough and conservative approach to preparation for operations; and its positive attitude toward NRC regulations, safety issues, and employee concerns. With regard to overall performance, the staff concluded that management attention to and involvement in nuclear safety and safeguards has resulted in a level of performance above that needed to meet regulatory requirements.

In reaching its conclusions, the staff cautioned TV Electric that much work remains to be done to complete construction at CPSES and make the transition from Construction to Operations, in addition, the staff noted that additional i attention on the part of TV Electric is warranted in the area' of deficiency identification a'id correction including root cause determination, particularly given the large backlog of open deficiencies, and in ensuring that the dedication to safety and quality evident in upper management is properly projected throughout the organization.

TV Electric has carefully reviened and evaluated the information contained in the SALP Report and concurs with the conclusions, cautions, and recomendations contained therein. The improvements noted in the SALP Report indicate that we are making significant progress toward our overali objective of achieving excellence in all areas of performance.

S812O20221 ss112s ADOCK 0500044"i

{DR Poc [Ph y

a sawa sur<< u si M w ro w u t

' , i TXX-88802 i November 28, 1988 Page 2 of 2 TV Electric has explored and will continue to explore new and better ways of communicating and reinforcing management's commitment to excellence. Some of the more recent efforts in this regard are implementation of a quality awareness program, enhancements to the role of the Senior Management Quality  ;

Overview Committee, consolidation of procurement functions, revised project  ;

status meeting formats, and a task force approach to operational readiness (

issue completion. Complementing these efforts, our major contractors have '

initiated "quality circles" to enhance vertical and horizontal communication.

In addition, TV Electric has become more aggressive at communicating isolated I program changes down to the worker level through training sessions and weekly i site newsletters (the existing monthly newsletter will continue to be issuad), f A recent example of this was the training conducted on revisions to work [

packages contrciling heating, ventilating, and air conditioning (HVAC) system  ;

work and inspections.  !

The SALP Report r.oted that there is a large backlog of potentially deficient conditions awaiting evaluation and cort.ction. This backlog resulted from the implementation of the CPRT and Corrective Action Programs, which reevaluated t the quality of construction and design against currently applicable standards,  !

using a very conservative approach. While this backlog remains high, we i believe that it is being successfully managed and appropriate resources are [

being devoted to reduce it. These efforts appear to be succeeding and the  ;

backlog is being reduced. .It has been and continues to be our goal to reduce  ;

the number of outstanding items such that at the time of operating license (

issuance there are no items which might impact safe and reliable plant cperation, and the total population of outstanding items does not represent a significant burden for available resources. ,

In conclusion, TV Electric concurs with the NRC's assessment of the current i level of performance at CPSES. We believe this level of performance is the  !

result of the considerable efforts made to date toward our goal of overall  !

excellence. While we recognize that much work remains to be done, we believe [

that we have established a solid foundation for the achievement of the  !

improvements needed to assure successful completion of construction and '

transition to safe and reliable plant operation.

Very truly yours, W. G. Counsil h'k%

l ROD /mlh f

c - Mr. R. D. Martin, Region IV t Resident Inspectors, CPSES (3)  !

i s

i