ML20206K086

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Provides Comments Re NRC SALP Repts 50-413/88-24, 50-414/88-24,50-369/88-21 & 50-370/88-21
ML20206K086
Person / Time
Site: Mcguire, Catawba, McGuire, 05000000
Issue date: 11/21/1988
From: Tucker H
DUKE POWER CO.
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8811290264
Download: ML20206K086 (2)


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Duke Ibuvr Cornpany llu il Tann PO Bar 33198 Wf IW'idnt Charlour,1N C 28242 Nuclear Production G04)373 4531 DUKE POWER November 21, 1988 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555

Subject:

Catawba Nuclear Station, Docket Nos. 50-413 and 50-414 SALP Report 50-413/88-24 and %-414/88-24 McCuire Nuclear Station, Dor.ket Nos. 50-369 and 50-370 SALP Report 50-369/88-21 and 50-370/88-21 Dear Sir By letter dated October 13, 1988, the NRC transmitted the Systematic Assessment of Licensee Performance (SALP) reports for McGuire and Catawba.

Meetings were held on October 20 and 21, 1988 at the respective stations to discuss the reports.

The company appreciates the perspective offered by the NRC in the SALP Reports and will utilize this input to further improve the quality of our operations.

Duke has already taken actions to initiate these improvements which were discussed with NRC management on August 10, 1988. The SALP reports have been reviewed to ensure that these actions are appropriate and comprehensive for any identified weaknesses and to assist management in focusing future actions and involvement in particular areas of station operation and support. As a result of this review, we have the following comments concerning the SALP reports:

- We agree the SALP report is a good mechanise that focuses attention on the overall offectiveness of management.

However, your new philosophy of rating the degree a licensee exceeds regulatory requirements as a measure of a Itcensee's commitment to nuclear safety and plant reliability is interesUng, but an area beyond the jurisidiction of the NRC. Other organizat.'ons, for example, INPO, are in a better position to evaluate performancs rather than just compliance. The NRC's use of the results of SALP evalua*.lons to determine the appropriate degree of inspection and management inttention needed for a plant may b' appropriate. Also, rating performance.s a much more subjective task ana the outcome of evaluations will rely heas11y on evaluators' opinions. This might Icad to erroneous comparisons beiween different SALP reports written by different individuals.

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',... s U. S. Nudicar Regulatory Commission November 21, 1988 Page Two On page 5 of McGuire's SALP Report it is stated: "[iln the plant manager's absence the lack of initiative on the rest of the staff is often apparent in that his conservative and thorough approach to problem resolution is not continued."

It is thought this statement was based on a single event that occurred on November 5, 1987. This event was the result of Component Cooling (KC) heat exchanger testing and operability concerns that developed in the station manager's absence. This single event is not indicative of a lack of initiative by the plant staff in resolving plant problems.

Any differences, in the approach of the morning management meetings when the station manager is absent, are a reflection of the personality differences of staff members. Also, the morning meetings are brief and it nay not be readily apparent that much preparation behind the scenes has already occurred for key participants.

The station staff has consistently demonstrated safety consciousness and its willingness to resolve safety concerns. Each incident that occurs strengthens our awareness and resolve to make prudent decisions. This is constantly improving with the maturity of the plant.

Thank you for the opportunity to comment on the SALP reports.

Very truly yours,

h. /[w lal B. Tucker PGL/

xc: M. L. Ernst Acting Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 W. T. Orders NRC Resident Inspector Catawba Nuclear Station P. K. Van Doorn NRC Resident Inspector McGuire Nuclear Station