Text

Responds to FOIA Request Re Documentation Concerning Declining Performance of Facilities.Forwards App a Documents.Documents Also Available in PDR.SECY-86-595 Nonexistent
	ML20197A612
Person / Time
Site:	Peach Bottom, Limerick, 05000000
Issue date:	10/20/1986
From:	Grimsley D, Grimsley D; NRC OFFICE OF ADMINISTRATION (ADM)
To:	Trapasso B; NUCLEAR INFORMATION & RESOURCE SERVICE
Shared Package
ML20197A618	List: ML20197A612; ML20197A712; ML20199D268; ML20199F561; ML20203G649;
References
	FOIA-86-684 NUDOCS 8610270350
	Download: ML20197A612 (3)
	v • d • e

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R2: F01A-86-684 APPENDIX A 1.

02/25/86 Memo from G. Gears to R. Bernero, thru D. Muller, subject:

NRR input to Philadelphia Electric Company, Peach Bottom 2 and 3 Systematic Assessment of Licensee Performance (SALP)

(10pages) 2.

02/25/86 Memo from G. Gears to S. Collins, subject: NRR SALP input (10pages) 3.

03/04/86 Memo from G. Holahan to D. Muller, subject: SALP Input for Peach Bottom (3 pages)

4.

03/25/86 Letter to S.L. Daldroff from R.W. Starostecki transmits Inspection Report 50-278/86-09(10 pages)(AccessionNo.

8603310157) 5.

03/28/86 Memo to T. Johnson from G. Gears, subject: NRR Revisions to Its SALP Input for Peach Bottom Based Upon the SALP Board Meeting Comments of March 24,1986(3pages) 6.

04/23/86 Memo from D. Eisenhut to J. Axelrad, subject: Enforcement Action 86-59, Peach Bottom, Unit 3 (15 pages)

7.

06/04/86 EN 86-37: Notification of Significant Enforcement Action (1page)(AccessionNo. 8606110274)

8.

06/06/86 Letter from T. Murley to S. Daltroff, subject: SALP, for the period of 12/1/84 through 1/31/86 (Unit 1) and 4/1/85 through 1/31/86 (Units 2 and 3) (139 pages) Acc. No. 8606130051 Systematic Letter to S.L. Daltroff from T.E. Murley), subject:

9.

06/06/86 Assessment of Licensee Performance (SALP, Acc. No. 8606130051 (7pages)w/ encl.SALPBoardReportforperiod4/1/85to 1/31/86, Acc. No. 8606130062 Fiche No. 36436 frames 010-078(69pages)

10. 06/09/86 Letter to S. Daltroff from T. Murley, subject: Notice of Violation and Proposed Imposition of Civil Penalties (NRC Inspection Report No. 50-278/86-09, Acc. No. 8606130069, Fiche No. 36439 frames 132-138(7pages)

11. 06/12/86 Letter from V. Stello to J.L. Everett, III, subject: poor performanceindicators(3pages)Acc.No.8606190661 PDR/A00CK/50-277Q

12. 06/18/86 Letter to V. Stello from J. L. Everett regarding Peach Bottom Units 2 and 3 Performance (1 page)

_ ~ - - _ _ _

r to APPENDIX A F0!A-86-684 Page 2 Letter to T. Murley from T. Conner requesting (a two week

13. 07/08/86 extension to respond to NRC letter of 6/9/86 2pages)

(Accession No. 8607170331)

14. 07/08/86 Letter to S.L. Daltroff from T. Murley (1 page)(Accession No.

8607170326)

15. 07/23/86 LettertoJ.TaylorfromS.L.Daltroff(11pages)(Accession No.8607280145)

THIS DOCUMENT CAN BE LOCATED AT THE NRC PUBLIC DOCUMENT ROOM (PDR) LOCATED AT 1717 H STREET, NW, WASHINGTON, DC 20555, UNDER THE ACCESSION NUMBER IDENTIFIED AT THE DOCUMENT DESCRIPTION.

I

& % le'7 Docket Nos.: 50-277 50-278 VEB 2 51986 NOTE T0: Robert Bernero, Director Division of BWR Licensing THRU:

Daniel R. Muller, Director BWR Project Directorate #2 Division of BWR Licensing FROM:

Gerald E. Gears, Project Manager BWR Project Directorate #2 Division of BWR Licensing

SUBJECT:

NRR INPUT TO PHILADELPHIA ELECTRIC COMPANY-PEACH BOTTOM ATOMIC STATION, UNITS 2 AND 3 SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP)

The Philadelphia Electric Company SALP Board meeting is scheduled for March 24, 1986 at Region 1.

Attached is our SALP input for this meeting.

If you have any comments, please give me a call at x24993.

Gric,10.131 s:1by 0

Gerald E. Gears, Project Manager BWR Project Directorate #2 Division of BWR Licensing

Attachment:

As stated DISTRIBUTION:

Docket File NRC PDR Local PDR PD#2 R/F Glainas GGears SNorris 0FFICIAL RECORD COPY DBL:PD#2 '

D#2 DBL' SNu@lTI7Ic y6 DM 5

/36 2/L. 6 2/y/86 FotA-s/A s4 A\\

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'o UNITED STATES g

NUCLEAR REGULATORY COMMISSION g

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%*...*4 Docket Nos. 50-277 and 50-278 FACILITY: Peach Bottom Atomic Power Station. Units 2 and 3 LICENSEE: Philadelphia Electric Company NRR PROJECT MANAGER: Gerald E.

Gears 1.

INTRODUCTION This report presents the results of an evaluation of the licensee.

Philadelphia Electric Company, in the functional area of licensing activities.

It provides NRR's input to the Peach Bottom SALP review process as described in NRC Manual Chapter 0516.

The review covers the period April 1,

1985 to January 31, 1986.

The approach used in this evaluation was to select a number of licensing actions which involved a significant amount of staff effort or which were related to important safety or regulatory issues for the period from April 1,

1985 to January 31, 1986.

In most cases, the staff applied the evaluation criterion for the performance attributed based on their first hand experience with the licensee or with the licensee's submittals.

Each organi:ation within NRR that was responsible for developing a safety evaluation was obligated to provide a SALP input in accordance with NRR Office Letter No.44.

This input was accumulated and used directly.

However, for certain licensing actions, an evaluation by the Project Manager was also factored in.

Individual SALP evaluations were assembled into a matrin as shown in Appendix A.

This matrix was used in combination with appropriate weighting for the importance of the licensing issue to develop the overall evaluation of the licensee's performance.

This approach is consistent with NRC Manual Chapter 0516 which specifies that each functional area evaluated will be assigned a perf ormance category based on a composite of a number of attributes.

The single final rating is to be tempered with judgement as to the significance of the individual elements.

2.

SUMMARY

OF RESULTS Dased on the approach described in the Introduction, the performance of Philadelphia Electric Company for its Peach Bottom facility is rated Category 2 for licensing activities.

This is a change from the previous evaluated period in which the licensee was rated Category 1.

i m

3.

CRITERIA Evaluation criteria as given in NRC Manual Chapter 0516, Table 1,

were used in this evaluation.

Weighting was used to temper the evaluation of individual licensing issues depending upon their importance to safety.

4.

PERFORMANCE ANALYSIS This evaluation represents the integrated inputs of the Project Manager and those technical reviewers who expended significant amounts of effort and /or prepared a Safety Evaluation for the Peach Bottom facility.

The composite rating also reflects the comments of the NRR Senior Executive assigned to the Peach Bottom SALP assessment.

A written evaluation was circulated to NRR management for comments, which were considered in the final draft.

The basis for this appraisal was the licensee's performance in support of licensing actions that were either completed or had a significant level.of activity during the current rating period.

These actions included license amendment requests, exemption and relief requests, responses to Generic Letters, TMI and Salem (ATWAS) items, and other actions.

Fifty-six (56) licensing actions were completed.

Active actions during this period are classified in Attachment A.

In addition to those specific issues, the licensee was evaluated for the overall performance in many day-to-day issues which arise.

5.

ASSESSMENT OF PERFORMANCE ATTRIBUTES This evaluation of the licensee's performance was based on the consideration of the seven attributes specified in NRR Manual Chapter 0526.

These are

-Management Involvement and Control in Assuring Quality

-Approach to Resolution of Technical Issues from a Safety Standpoint

-Responsiveness to NRC Initiatives

-Enforcement History

-Reporting and Analysis of Reportable Events

-Staffing (including Management)

-Training and Qualification Effectiveness In addition, this evaluation includes an assessment of the licensee's housekeeping practices.

5.1 Management Involvement and Control in Assuring Quality During this rating period, the licensee's headquarter management has demonstrated an active role in licensing-related activities.

Strong management involvement has been especially evident where issues have potential for substantial safety impact and extended shutdowns.

This was especially evident in the Unit 3 refueling and pipe inspection program and reracking of Unit 2 and Unit 3 spent fuel pools. These efforts have represented substantial efforts for both the licensee and NRC's staff and management during this ten month assessment period.

Management screening of submittals in these areas was apparent since the submittals were consistently clear and of high quality.

Both of these. efforts show evidence of prior planning, excellent assignment of priorities and stated, defined procedures for control activities.

However, there are two areas indicating the lack of management attention: timely resolution of NRC initiatives and sporadic quality of Sholly evaluations.

Although good effort has been made to initially respond to NRC initiatives in a timely fashion, there appears to be a discernible trend during this report period toward significant delays in followup responses.

Three examples are Appendix J Technical Specifications (TSs). purge / vent valves TSs,and diesel generator fuel oil TSs.

Concerning Sholly evaluations, there has been a noticeable improvement since the last evaluation period, but overall quality is still highly variable.

Additional management attention is required to improve the overall quality in the Peach Bottom Sholly process.

In summary, there was evidence of prior planning and assignment of priorities in major licensing actions, reviews were thorough and technically sound. There was evidence of frequent interfacing between appropriate licensee headquarter staff and the site.

The licensee has shown evidence that records are generally complete, well maintained and available.

However, there continues to be long delays in the submittals of several long-standing NRC initiatives.

Finally, the quality of Sholly evaluations still requires improvements.

Based on the above considerations, the overall rating for this attribute is Category 2.

5.2 Approach to Resolution of Technical Issues From a Safety Standpoint The licensee's submittals generally showed an understanding of issues, a conservatism in their technical presentations, and viable and generally sound approaches.

Resolutions of issues affecting continued operation of the plant or restart were generally timely.

However, there are other areas where the resolution of outstanding issues has not been timely.

NRC initiated issues of long-standing nature include Appendix J TSs and purge / vent valves TSs.

Although the technical approach to resolution of most issues has generally been good, the lack of timely resolutions of certain issues has resulted in the continued backlog of long-standing open items.

Based upon the above, the rating for this attribute is Category 2.

O 5.3 Responsiveness to NRC Initiatives The licensee generally responded to NRC initiatives in a timely fashion.

As reflected in the individual SALP ratings for the multi plant actions, the licensee has few outstanding regulatory issues and resolution has been initially acceptable in most cases.

This is especially true in regards to the licensee's e'ffort concerning the resolution of IGSCC cracking.

However, this assessment must be tempered by the fact that there are still long-standing items which require the licensee's responses before they can be closed out (e.g.,

Appendix J TSs, purge / vent valves TSs).

Also there has been a general trend in delayed follow-ups on certain actions which further contributed to the backlog of actions associated with Peach Bottom.

In summary, when considered against the evaluation criteria for this attribute in NRC Manual Chapter 0516, the licensee's initial responses have been generally timely; however, several long-standing actions and issues are still unresolved due to lack of licensee's input.

Based on the above considerations, the rating for this attribute is Category 2.

5.4 Enforcement History The NRR Project Manager participated in two Enforcement Meetings held at Region 1.

Based upon these events plus the Project Manager's review of the Peach Bottom Inspection Reports for the review period, major violations at Peach Bottom are rare and evidence at the Enforcement Meetings appear to indicate that violations result from minor programmatic breakdowns.

Corrective actions are usually timely and effective in most cases.

However, when actions required licensee's follow-up with NRR (e.g.,

a TS change), delays in such follow-ups have been evidenced.

Based upon the above, the rating for this attribute is Category 2.

5.5 Reporting and Analysis of Reportable Events (This input is being developed by the ORAS staff in NRR. Their analysis is currently being prepared and will be sent to the Region under separate cover but in sufficient time to be used by the SALP Board members at the March meeting.)

5.6 Staffing (Including Management)

During this rating period, an effort was made to increase the effectiveness of the Philadelphia Electric licensing staff to accommodate both the Peach Bottom facility and Limerick Generating station which was recently licensed to operate. These changes have resulted in the continued high technical quality of most Peach Bottom submittals.

However, the problems of delays and backlogs as discussed above appear to indicate that there may be problems in the staffing area.

Key management positions have been identified with defined authorities and responsibilities, but staffing, although technically competent, appears not to be adequate at times due to difficulties with backlogs.

Based on the above considerations,.the rating for this attribute is Category 2.

5.8 Training and Qualification Effectiveness We have no basis for evaluating this attribute during this report period.

5.9 Housekeeping Observations made while visiting the site on various occasions during this rating period indicate that the licensee's housekeeping practices are adequate.

Areas within the plant facility as well as the outside grounds were generally clean and free of combustibles.

Plant personnel appeared to conduct themselves in a professional manner.

Based on the above considerations, the rating for this attribute is Category 2.

6.0 Conclusion An overall performance rating of Category 2 has been assigned in the licensing area.

Section 042 of the Manual Chapter 0516 defines the meaning of rating the licensee's performance Category 2 as follows:

"NRC attention should be maintained at normal levels.

Licenseu management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and reasonably effective such that satisfactory performance with respect to operational safety or construction is being achieved."

We believe that no less management effort on the part of the

I licensee should be exerted in licensing activities.

We suggest that

- more management involvement may be needed to improve response time while maintaining quality.

We also conclude that no less NRC attention in the licensing category would be appropriate.

i i

e i

n.

PEACH BOTTOM ATOMIC POWEP STAllDN-SALP REP 0ti SALP CATE60F.!ESt TYPE TA:

TITLE OF ACTICN SE COM5LT CAT.1 CAT.2 CAT.3 CAT.4 CAT.5 CAT.6 It!MIEF LATE Malts-olait actiens M

42922 3 MASONRY WALL DESlEN. IEP-80-!!

B5/06/14C M

53027.9 ITEM 3.1.3-POST MAIN. TEST. CHS. 10 TS 65!06/22C 1

1 1

M 53617,8 liEM !.2-POST TRIP REVIEW-DATA 1!NFO CAP.95/06/02C 3

2 M

53266.7 ITEM 3.2.3-F3Si PAINT. TEST.-CH6 TO TS 85!06/28C 1

1 1

M

$5606 INS. OF EWR FIPIKE ACC.10 EL.94-!!(PB2)S5/06/06C M

55607 INS. OF BWD. PIPINS ACC. ID GL.24-!!(Pf3)25/09/30C M

5533~,9 DIESEL EENERATOR 15.

85/09/06C 1

1 1

M 5 532.9 PEC0MBINES CAFABILITY 85/06/19C 2

M 56675 P! PINS INSP. FRDS. FOR E5 REFUELINS(FB3)25/09/30C 1

1 1

M

!7162.3 MAFF 1 DHWELL VA:.!FEAl..(GL 23-09) 85/06/06C 1

M 5'40.1 JUS!!FICAfl0N FDP INTER!M SPLS AAD REV.C65/12/23C 2

2 2

M 6(227 9 FOLLOW-UP DN ITEM !.2(SL.93-29) 05'!!'23C Plant spe:ific actiens P

543i7.5 TS CHAh5E TO DELETE DRfWELL A!R MON!T0P B5/05!!6C 2

1 P

54900.1 FEV. OF PROF 0 SED TS ON A!R SUPPLY 85/07/14C P

55157,8 TE CHANGE INVOLVING MANAGEPENT RE056. 85!07/0!C 2

2 P

55174 JET PUMP INTPu' TENT NO2ZLE CRACKS (UNIT 295/06/06C P

5:400.1 FEVIEW OF SECOND TElH EAR 151/I51 PR06. 85!!0/!5C P

55576 CRAttS IN FISER SAFE EN53 (UNIT 21 85!06/06C P

55577 CRACES IN RISEP SAFE ENDS (UNIT 3) 86/01/31 1

1 1

P 56?40,1 ADDITIONAL ISI REllEF RED' JEST (IST 10 YRIB5/05/14C 1

1 P

56942.3 REACIOR WATER LEVEL INSTR. LCO TS 95/06/120 2

2 P

5694?,50 TS CPANSES REL. TO RETS (REVISION 11 25/0?/10C 2

1 1

P 57237 A5DENDA TO C)CLE 7 RELOADfuhli 31 85/07/03C 2

2 P

57536,7 EMEREENCY PSEPARECNESS-SCHEDULAR CHANSE E5/07/01C P

5?957,9 NDD CAT!0tS OF ORDERSf 6/14/951-REV.2 85/09/05C P

$8012 SPINT FUEL PCOL EIPAtSION 95/12/11 1

1 2

P 59291,2 ISfs) CHANGES IWOLVINS BYF4SSING SCRAMS 25'10/3!C 1

1 1

P 5944,5 PURSE AND VENT VALVE S10PS 85/10/24C 2

8 8

P 5'446,7 CONTROL ROOM UPECADE-APP.R (CARPETi 85/10/10C 1

1 1

P

$9449,9 ENERGY ABSOR!ERS 95/10/2'C 2

2 2

P 59779 EMERS. TS ON LPCI PUMP FLOW B5!!!/13C 2

2 2

TMI a:tions T

54E29,8 TS CHANGES ON RWL & II.K.3.16 85/06/0!C 2

2 2

33333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333 CALCULATED AVERAEES 1.611111 1.45 1.411764 2

ERR ERR e Reterded values represer.t input received by the Project Manager.

Information to be Added to Section 5 of SALP Report

" Supporting Data and Summary" 1.

NRR/ Licensee Meeting / Site Visits Site visits: June 12, 1985, November 21, 1985 Meetings:

05/13/85:

SALP Board Meeting 05/30/85:

" Energy Absorbers" 06/14/85:

SPDS 09/05/85:

Unit 3 Pipe Cracks 09/17/86:

Unit 3 Core Spray Sparger Cracks 10/01/85:

Unit 3 Cracks in Safe Ends 10/31/85:

N-1 Safe-Ends 12/19/85:

Cracks in Shroud Head Bolts and Wear Rings

2. Commission None

3. Scheduler Extensions Granted 08/05/85; submittal of DCRDR Summary Report

4. Relief Granted 05/14/85; ISI Relief

5. Exemptions Granted None

6. License Amendments Issued Amendment Nos.109,112 issued June 6, 1985; approves miscellaneous Ts changes Amendment Nos. 110,113 issued July 17, 1985; approves 50.72 & 50.73 reporting requirement' Amendment Nos. 111,115 issued October 2, 19E5; approves correction of set points and Emerg. Plan Test Freq Amendment No. 114 issued August 23,1985; Unit 3 Reload Amendment Nos. 112,116 issued November 19.1985; approves changes in t

coolant leakage detection systems i

Amendment Nos. 113,117 issued November 19, 1986; Nureg-0737 TSs Amendment Nos. 114,118 issued November 22,1985; administrative control TSs Amendment Nos. 115,119 issued December 10, 1985; revised certain portions of RETS l

7. Emergenty/ Exigent Technical Specifications None 8."+

ers Issued L

e None 9.

NRR/ Licensee Management Conferences None k

1 I

t

Qgkw $'l Docket Nos.: 50-277 50-278 E

MEMORANDUM FOR: Samuel J. Collins, Chief Project Branch #2 Division of Reactor Projects Region 1 THRU:

Daniel R. Muller, Director BWR Project Directorate #2 Division of BWR Licensing FROM:

Gerald E. Gears, Project Manager BWR Project Directorate #2 Division of BWR Liceasing

SUBJECT:

NRR SALP INPUT - PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 Attached is NRR's input for the March 24, 1986 SALP Board meeting for the Peach Bottom Atomic Power Station, Units 2 and 3.

As discussed in the attachment, our evaluation was conducted according to NRR Office Letter No. 44, dated January 3,1984 and NRC Manual Chapter 0515, Systematic Assessment of Licensee Performance.

Orisinal cigne'd b[

Gerald E. Gears, Project Manager BWR Project Directorate #2 Division of BWR Licensing

Attachment:

As stated cc w/ enclosure R. Bernero T. Johnson (Sr. Resident Inspector)

DISTRIBUTION:

Docket File NRC PDR PD#2 R/F Glainas,.AD GGears SNorris 0FFICIAL RECORD COPY 2:D p)t DBL PD#2

~' PD#2 DBL:

SN ris:nc Ge vs DM) e 2/jp86 2/g/86 27,/86 Fet A-86-4 8 4-

. gat 3p'7919 A 2.-

a

pa ng*o UNITED STATES NUCLEAR REGULATORY COMMISSION o

y, I

WASHINGTON, D. C. 20555

%.....M Docket Nos. 50-277 and 50-278 FACILITY: Peach Bottom Atomic Power Station, Units 2 and 3 LICENSEE: Philadelphia Electric Company NRR PROJECT MANAGER: Gerald E.

Gears 1.

INTRODUCTION This report presents the results of an evaluation of the licensee, Philadelphia Electric Company, in the functional area of licensing activities.

It provides NRR's input to the Peach Bottom SALP review process as describe'd in NRC Manual Chapter 0516.

The review covers the period April 1.

1995 to January 31, 1986.

The approach used in this evaluation was to select a number of licensing actions which involved a significant amount of staff effort or which were related to important safety or regulatory issues for the period from April 1,

1985 to January 31, 1986.

In most cases, the staff applied the evaluation criterion for the performance attributed based on their first hand experience with the licensee or with the licensee's submittals.

Each organization within NRR that was responsible for developing a safety evaluation was obligated to provide a SALP input in accordance with NRR Office Letter No.44.

This input was accumulated and used directly.

However, for certain licensing actions. an evaluation by the Project Manager was also factored in.

Individual SALP evaluations were assembled i n to a matri:'

as shown in Appendi::

A.

This matrix was used in combination with appropriate weighting for the importance of the licensing issue to develop the overall evaluation of the licensee's performance.

This approach is consistent with NRC Manual Chapter 0516 which specifies that each functional area evaluated will be assigr.ed a performance category based on a composite of a number of attributes.

The single final rating is to be tempered with judgement as to the significance of the individual elements.

2.

SUMMARY

OF RESULTS Based on the approach described in the Introduction, the performance of Philadelphia Electric Company for its Peach Bottom facility is rated Category 2 for licensing activities.

This is a change from the previous evaluated period in which the licensee was rated Category 1.

3.

CRITERIA Evaluation criteria as given in NRC Manual Chapter 0516, Table 1,

were used in this evaluation.

Weighting was used to temper the evaluation of individual licensing issues depending upon their importance to safety.

4.

PERFORMANCE ANALYSIS This evaluation represents the integrated inputs of the Project Manager and those technical reviewers who expended significant amounts of effort and /or prepared a Safety Evaluation for the Peach Bottom facility.

The composite rating also reflects the comments of the NRR Senior Executive assigned to the Peach Bottom SALP assessment.

A written evaluation was circulated to NRR management for comments, which were considered in the final draft.

The basis for this appraisal was the licensee's performance in support of licensing actions that were either completed or had a significant level of activity during the current rating period.

These actions included license amendment requests, exemption and relief requests, responses to Generic Letters, TMI and Salem (ATWAS) items, and other actions.

Fifty-six (56) licensing actions were completed.

Active actions during this period are classified in Attachment A.

In addition to those specific issues, the licensee was evaluated for the overall performance in many day-to-day issues which arise.

5.

ASSESSMENT OF PERFORMANCE ATTRIBUTES This evaluation of the licensee's performance was based on the consideration of the seven attributes specified in NRR Manual Chapter 0526.

These are:

-Management Involvement and Control in Assuring Quality

-Approach to Resolution of Technical Issues from a Safety Standpoint

-Responsiveness to NRC Initiatives

-Enforcement History

-Reporting and Analysis of Reportable Events

-Staffing (including Management)

-Training and Qualification Effectiveness In addition, this evaluation includes an assessment of the licensee's housekeeping practices.

5.1 Management Involvement and Control in Assuring Quality During this rating period, the licensee's headquarter management has demonstrated an active role in licensing-related activities.

Strong management involvement has been especially evident where issues have potential for substantial safety impact and extended shutdowns.

This was especially evident in the Unit 3 refueling and pipe inspection program and reracking of Unit 2 and Unit 3 spent fuel pools. These efforts have represented substantial efforts for both the licensee and NRC's staff and management during this ten montil assessment period.

Management screening of submittals in these areas was apparent since the submittals were consistently clear and of high quality.

Both of these efforts show evidence of prior planning, excellent assignment of priorities and stated, defined procedures for l

control activities.

However, there are two areas indicating the lack of management attention: timely resolution of NRC initiatives and sporadic quality of Sholly evaluations.

Although good effort has been made to initially respond to NRC initiatives in a timely fashion, there appears to be a discernible trend during this report period toward significant delays in followup responses.

Three examples are Appendix J Technical Specifications (TSs), purge / vent valves TSs,and diesel generator fuel oil TSs.