ML20216C448
| ML20216C448 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 02/27/1998 |
| From: | Norris J DUKE ENGINEERING & SERVICES |
| To: | Collins S NRC (Affiliation Not Assigned) |
| Shared Package | |
| ML20216C455 | List: |
| References | |
| NUDOCS 9803160017 | |
| Download: ML20216C448 (5) | |
Text
g LMe&qirarirg&ServicesEE55 400 Soue si Street JOHN F. NORRIS, JR.
P.o. St-President & ChHof Executive Offcer Charlot% _.,282011004 704 382-7448 Fax 704 382 7969 February 27,1998 i
Mr. Samuel. J. Collins Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission
' Washington, D. C. 20555
Subject:
DEMAND FOR INFORMATION TO YANKEE ATOMIC ELECTRIC COMPANY (YAEC) AND TO DUKE ENGINEERING & SERVICES, INC.
(DE&S)- RE: PROVIDING INADEQUATE ENGINEERING ANALYSES AND MATERIALLY INCOMPLETE AND INACCURATE INFORMATION TO AN NRC LICENSEE i
Reference:
NRC Letter dated December 19, 2997 from Samuel J. Collins to Messrs. Donald K.
Davis (YAEC) and John F. Norris, Jr. (DE&S)
Dear Mr. Collins:
i As requested by the referenced letter, issued pursuant to 10CFR2.204, the enclosed report provides the Duke Engineering & Services, Inc. (DEAS) response to the subject Demand for Information (Demand).
The Demand speMically requests DE&S and/or Yankee Atomic Electric Company (YAEC) to provide information as to: (1) why the NRC should permit NRC licensees to use the services of DE&S and/or YAEC to perform LOCA or safety-related analyses, and (2) why the NRC should not consider the inadequate analyses described in the Demand to be the result of willfulness on the part of DE&S and/or YAEC personnel. Additionally, the Demand identifies four generai j
NRC concerns and four specific NRC technical issues. The enclosure provides the DE&S response to each of these NRC concerns and technical issues.
i DE&S, a wholly-owned affiliate of Duke Energy Corporation, prides itself on quality work and compliance with NRC requimments. DE&S, a current provider of technical services to the nuclear industry, is committed to bring its nuclear professionalism and experience to tb acquired i
YAEC organizations. In this regard, DE&S conducted a number ofindependent arressnents of the acquired YAEC organizations and the products and services they provide. The results of these assessments were then reviewed by DE&S senior management. Throughout this process.
DE&S did not identify any areas where the current performance of, or the products and services provided by, the acquired YAEC organizations is unacceptable. Meaningful improvements had been made, since the events described in the Demand, in the quality of YAEC procedures and the i
emphasis these piocedures place m NRC requirements and NRC reporting. The technical quality of work products currently being produced, as well as the professionalism and technical i
g 9803160017 990227 9
Loa ^""
l Poli' k
M!ElE,E,M..ER.
k, 3.#
L J
U.S. Nuclear Regulatory Commission Page 2
~ February 27,1998 competence of the workforce, are consistently high. Another common finding of the DE&S assessments was the high degree ofintegrity and openness of the employees. DE&S has found no evidence that would question the sincerity and dedication of this workforce, or would otherwise prevent DE&S activities to be performed in full compliance with NRC requirements.
Additionally, DE&S has strengthened the acquired YAEC Boltoa office leadership with a proven nuclear industry executive, William H. Rasin. Effective March 1,1998, Mr. Rasin will become the DE&S Vice-President of Nuclear, Fuel, and Quality Assurance Services. DE&S also has underway a systematic transition of the acquired YAEC organizations into the DE&S project planning and work execution programs and procedures. The DE&S project planning process emphasizes clear definition and documentation of project-specific requirements, both technical and organizational, and training of project personnel on these requirements.
It should be noted that the DE&S programs and procedures described within the enclosure are revised on a routine basis to ensure that management expectations for continuous improvement are met. These revisions also maintain effective DE&S programs and procedures that are in line with current industry practices and compliant with NRC requirements. Full transition and integration of the acquired YAEC organizations into DE&S will place the acquired YAEC work practices, products and services under this continuous improvement process.
The enclosed rqx>rt consists of five sections. Section 1.0 provides an introduction to the report, including an overall discussion of the DE&S response methodology and background information on events described in the Demand. Section 2.0 describes the DE&S assessment of the acquired
.YAEC organizations and the products and services provided by these organizations. Section 3.0 addresses the four general concerns identified in Section IV of the Demand. Section 4.0 addresses the four specifk technical issues described in Section 111 of the Demand. Section 5.0 provides the DE&S response to the two information requests stated in Section V of the Demand.
Also provided, as Appendices to the enclosed report, are copies of various assessment reports and other detailed information that support and supplement the main report. Appendix A contains background information pertaining to DE&S, the DE&S Design Control and Quality Assurance Programs, and an overview or the DEAS acquisition of certain YAEC organizations.
Appendix B provides a summary of the actions taken by YAEC in response to the safety allegations involving inadequate safety analyses performed for Maine Yankee Atomic Power Company (MYAPCo). Appendices C through G contain the reports of the assessment teams chartered by DE&S to independently evaluate the acquired YAEC organizations and the issues and concerns raised by the Demand. Summary reports ofindependent assessments of DE&S/YAEC safety analyses performed for Vermont Yankee and Seabrook are provided in Appendices 11 and I, respectively.
j
i U.S. Nuclear Regulatory Commission Page 3 February 27,1998 In summary, DE&S independent assessments of the acquired YAEC erganizations and DE&S management evaluation of these assessmert results did not identify any areas where the current performance of, or work products and senices provided by, these organizations is unacceptable.
l Consistent with previous DE&S acquisition experience, these assessments did highlight areas that require DE&S management attention to ensure a successful transition and integration of the acquired YAEC organizations into DE&S. Actions that address these areas have been initiated.
1 For these reasons, combined with the nuclear commitment and experience represented by DE&S, the NRC should have a high degree of confidence that safety-related analyses, products and services provided by DEAS to NRC power :eactor licensees comply with the principles of: (1) adherence to NRC requirements and appreciation for NRC expectations, (2) effective management control of safety-related activities, (3) accurate and complete communication with licensees and the NRC, and (4) conduct of work in accordance with NRC requirements.
Therefore, DE&S concludes that there is no reason to preclude DE&S from continuing to provide the full range of nuclear senices to NRC licensees, including safety-related analyses.
Furthermore, DE&S concludes that there is no evidence that the concerns and issues identified in j
the Demand were the result of willfulness on the part of DE&S and/or YAEC personnel.
We look forward to meeting with you and your staff to discuss the e fosure in more detail and our plans for going forward. If there are questions about the information in this response, please contact Bill Rasin at (978) 779-6711.
Very truly yours, hn F. Norris, Jr.
JFNjr/fgh Enclosures
)
I U.S. Nuclear Regulatory Commission Page 4 February 27,1998 J. F. Norris, Jr., being duly sworn, states that he is President and Chief Executive Officer of Duke Engineering & Services, Inc., a wholly-owned affiliate of Duke Energy Corporation; that he is authorized on the part ofsaid company to sign and file with the Nuclear Regulatory Commission i
this response to the Demand for Information pursuant to 10CFR2.204; and that all statements and
{
matters set forth herein are true and correct to the best of his knowledge.
b O
F. Norris,'Jr.
'/'
o Subscribed and sworn to me Albmht 27, /P7(
{
Date i
- W p
Notary ublic My commission expires: g 5,.2cc /
'(Seal) i i
l
cc: James Lieberman Director, Office of Enforcement
{
U.S. Nuclear Regulain y Commission Washington, D.C. 20555 Lawrence J Chandler Associate General Counsel for Ileanngs, Enforcement, and Administration U.S. Nuclear Regulatory Commission Washington, D.C. 20555 liubert J. Miller Regional Administrator U.S. Nuclear Regulatory Commissior, Region I 475 Allendale Road King of Prussia, PA 19406-1415 Donald K. Davis, YAEC Michael Meisner, MYAPCo LOCA Group Manager i
LOCA Principal Engineer l
1