IR 05000315/1985001

App to SALP 5 Board Rept Discussing SALP Repts 50-315/85-01 & 50-316/85-01 for Apr 1984 - Sept 1985

ML20203N956
Person / Time
Site:	Cook
Issue date:	05/02/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20203N949	List: IR 05000315/1985001 ML20203N947 ML20203N970 ML20203N977
References
50-315-85-01, 50-315-85-1, 50-316-85-01, 50-316-85-1, NUDOCS 8605060238
Download: ML20203N956 (6)

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APPENDIX SALP 5 SALP BOARD REPORT U.S. NUCLEAR REGULATORY COMMISSION

REGION III

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 50-315/85001; 50-316/85001 Inspection Report N Indiana and Michigan Electric Company Name of Licensee Donald C. Cook Units 1 and 2 Name of Facility April 1, 1984 through September 30, 1985 Assessment Period 8605060238 860502 PDR ADOCK 05000315 G PDR

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1, D.C. COOK 1 and 2 Facility

. Summary of Meeting with American Electric Power Service Corporation on January 23, 1986

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The findings and conclusions of the SALP Board documented in Inspection Reports No. 50-315/85001; No. 50-316/85001 were discussed with the licensee

on January 23, 1986, at the Region III office in Glen Ellyn, Illinois. The licensee's regulatory performance was presented and found to be acceptable i overall. The licensee was informed that performance had improved in only one area (i.e., licensing activities) since the last SALP period and that

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the NRC's perception was that the overall performance appeared to have

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declined substantially since the last rating period.

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Attendees The following licensee and NRC personnel attended the meeting:

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AEPSC/IMEC

J. E. Dolan, Vice Chairman, Engineering and Construction M. P. Alexich, Vice President-Nuclear R. Kroeger, Manager of Quality Assurance

. W. G. Smith, Jr. , Plant Manager i P. Barrett, Senior Licensing Engineer and others of the staff U.S. NRC ,

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! J. G. Keppler, Regional Administrator 4 E. G. Greenman, Deputy Director, Division of Reactor Projects i N. J. Chrissotimos, Chief, Projects Branch 2

C. W. Hehl, Chief, Projects Section 2A

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B. L. Jorgensen, Senior Resident Inspector J. K. Heller, Resident Inspector

] C. Wolfsen, Resident Inspector

! D. L. Wigginton, Licensing Project Manager, NRR and others of the staff Regional Administrator Comments By letter dated March 4, 1986, the licensee provided written comments on i

the SALP Report; the letter indicated there were no errors in the report

requiring correctio ;

, The licensee also described actions to improve regulatory performance

! at the D.C. Cook facility. Based on the staff's review of the licensee's

submittal we have the comments set forth below. We request that these 4 comments be addressed in upcoming quarterly meetings as identified belo . RADIOLOGICAL CONTROLS

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As indicated in your response, a performance ennancement program is underway. In future quarterly meetings please present a status

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report which updates the degree of completion of your program milestones. For uncompleted program milestones and for certain parameters for which no quantitative milestone has been established, we recommend a discussion of trends noted to date. Possible items to be discussed could include, but are not limited to: supervisory hours in the field; the square footage of contaminated space and equipment; and the frequency and type of personnel contamination occurrence . REFUELING No further action or information appears necessary for this area at this tim . QUALITY PROGRAMS AND ADMINISTRATIVE CONTROLS (a) Procedural Adherence No date is provided either for completion of the video tape on procedural adherence or implementing its use. Considering ( the influx of craft personnel and otners for the outage, these l actions should be accomplished expeditiousl Please provide your projected date for completion of the tape and the results

, of its effectiveness (for example, as measured by QA and QC

" adherence" statistics, or some other parameter), if any, in accomplishing your intended goa (b) Corrective Action (1) No information has been provided regarding plans, if any, to improve the Corporate-wide corrective action progra You are requested to provide this information, which, as a minimum, should include an outline of proposed plans and projected schedular implementation date (2) Please describe the steps you intend to take (such as increased training or other measures) to improve the review of Condition Reports and other quality-related documents in relation to their safety significance and the adequacy of proposed corrective actions. This description should include projected schedule dates and the major milestones you plan to accomplish, in sufficient detail for us to assess the differences between the old and new approache (3) NRC inspections continue to note problems relating to the pre-August 1984 measures that implemented corrective action Please describe your plans, if any, to improve handling of existing long-standing "open" documents (e.g.,

request for change, condition report and job order).

Ideally, this description should address: the steps you

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intend to take to ensure the appropriateness of the corrective action specified; whether potential priority classifications of such documents need revision; and any interim measures / controls intended to implement pending completion of long term effort (c) Trending The trending program description appears acceptable, but the schedule has not been completely developed. Milestones and completion dates for development and implementation of the trending program, which were supplied to Region III in response to violation 315/85007-04E; 316/85007-04E and in follow-up discussions, are no longer valid. The referenced violation was written in March 1985, and the required date when full compliance will be achieved has still not been provide Please supply appropriate milestone dates and the final implementation date for the D. C. Cook trending progra You are requested to provide the information referenced in Items 3.(a), (b) and (c) in conjunction with your presentation on corrective actions, to be made at the previously arranged meeting for May 8, 1986. Should you require an extension to this date, you are requested to contact Mr. F. Hawkins of this office at (312) 790-555 . SURVEILLANCE The NRC SALP 5 Board Report and the licensee's response both make reference to the Regulatory Performance Improvement Program (RPIP) as an activity which should contribute to improved performance in this area. Further, a Confirmatory Action Letter (CAL) dated August 30, 1985, addressed several additional specific actions related to surveillance. The licensee completed these after the SALP evaluation period ended. Two specific concerns, however, remai First, the ability of surveillance procedures to ensure technically complete and correct safety equipment performance, while not adversely affecting the equipment, needs to be demonstrated over an extended period of time. Review of procedures for the appropriate attributes is an ongoing licensee activity, and should be subject to greater emphasis by the licensee and by NRC in its inspection progra Second, the licensee has not specified the criteria to be used to segregate significant Technical Specification upgrade program findings from less significant one Region III will need more specifics concerning these criteria, especially as they relate to the issue of Technical Specifications literal compliance, i

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. SECURITY A Performance Improvement Plan is currently under development which should adequately address past problems and, if aggressively implemented, build the foundation for future security program enhancement. In that Region III staff have been actively working with the licensee, no further specific information in this area appears necessary at this tim The separate, but related, topic of redefining plant protective areas will be discussed further, as suggested by the licensee, in the quarterly joint meeting __ ___

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