IR 05000247/1985099
| ML20138J429 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 12/10/1985 |
| From: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Selman M CONSOLIDATED EDISON CO. OF NEW YORK, INC. |
| Shared Package | |
| ML20138J435 | List: |
| References | |
| NUDOCS 8512170522 | |
| Download: ML20138J429 (4) | |
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i DEC 101985 Docket No. 50-247 Consolidated Edison Company of New York, In ~ ATTN: Mr. Murray Selman Vice President Indian Point Station Broadway and Bleakley Avenue Buchanan, New York 10511 Gentlemen:
Subject: Systematic Assessment of Licensee Performance (SALP)
Report No. 50-247/85-99-This refers to the evaluation we conducted of the activities at Indian Point Nuclear Generating Station, Unit 2, for the period of August 1,1984 through July 31, 1985 and discussed with members of your staff on October 25, 1985 at the Region I office in King of Prussia, Pennsylvania. The list of meeting attendees is attached as Enclosure 1. The NRC Region I SALP Report is provided as Enclosure 2. Our letter of October-11, 1985 (Enclosure 3) forwarded the SALP Board Report and solicited comments within 20 days of our meeting. As discussed during the' October 25 meeting and subsequently documented in your November. 13, 1985 letter (Enclosure 4), the comments relative to reactor vessel surveillance have been clarified in the enclosed report. Your comment. relative to improved performance in radiological control is note Our overall assessment.of your facility operation concludes that your initiatives have improved performance and there is effective management attention and in-volvement oriented toward nuclear safety in the functional areas evaluate Specifically, active corporate and site management actions have resulted in three Category I assessments and improving trends in the remaining areas evaluated. Your programs initiated to identify and deal with previously recog-nized shortcomings in the Radiological Controls area have resulted'in program improvements, the effectiveness of which will be assessed during the current assessment period. We encourage continued management attention to this area to provide for feedback and ongoing evaluation of your program initiative We consider that our meeting and subsequent interchange of information were beneficial and improved mutual understanding of your activities and our regula-tory progra OFFICIAL RECORD COPY ISALP50-247/85-99 - 0001. /21/85 IE4D 8512170522 851210 (
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Consolidated Edison Company of 2 New York
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No reply to this letter is required. Your actions in response to the NRC Systematic Assessment of Licensee Performance will be reviewed during future inspectionsoof your licensed facilit .Your cooperation is appreciate
Sincerely, Original signed by Thomas E. Xurley, Thomas E. Murley Regional Administrator
Enclosures:
1. SALP Management Meeting Attendees 2. NRC, Region I SALP, Indian Point Unit 2, September 24, 1985
.3. NRC, Region I-Letter, T. Murley to M. Selman, October 11, 1985 4. Con Ed Letter, M. Selman to T. Murley, November 13, 1985
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REGION I==
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT 50-247/85-99 CONSOLIDATED EDISON COMPANY, IN INDIAN POINT UNIT 2 NUCLEAR POWER PLANT ASSESSMENT PERIOD: AUGUST 1, 1984 - JULY 31, 1985 BOARD MEETING DATE SEPTEMBER 24, 1985,
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SUMMARY OF RESULTS Overall Facility Evaluation Since the last SALP assessment, the licensee has made major-management changes and has adopted new philosophies of management at the facility. A corporate change has aligned all the key disciplines necessary to operate the facility under one Senior Vice Presiden This has improved communications between the key disciplines and a more coordinated and cohesive approach to plant-related activities appears to be developing. At the facility, the new Vice President has incorporated new management techniques, has conducted team building seminars, and has made several changes in upper level plant management positions. The new management-ideas and team oriented approach to overall operations has begun to spread to lower management and the plant staff. Although more time will be necessary to assess the overall effect of these changes on the operation of-the facility, their initial impact appears to be positive.
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Toward the end of this assessment period, management made personnel and financial commitments that have improved tha general appearance of the entire plant, lowered the radiation levels in the controlled work areas, and begun to improve the records management program. The effects of these commitments are not yet fully realized, since many changes are in a development phase, however, physical and program changes are evident and are considered an improvement in the overall operation of the facilit The licensee initiated a major effort to upgrade the radiological protection program-in response to an Order Modifying License issued early in this SALP period. The improving SALP trend in radio-logical controls reflects the licensee's responsiveness to the issues raised by the Order, particularly the change in management attitude with respect to personal accountability regarding radiation protec-tion. Many. program changes were implemented toward the end of this SALP period; however, the effectiveness of these changes has not yet been fully demonstrated, particularly during outage condition Training The licensee has maintained a strong commitment to training
!- throughout this assessment period. Training played a major role in the upgrade of the radiological protection program by effectively communicating the new philosophies and program changes to the radiation protection staff and all plant staf Licensed operator candidates were well prepared for their exams. Training of operators in symptom-oriented emergency procedures appears to have been'very effectiv _ _ _ - - - _ . . _.- -
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Quality Assurance The Quality Assurance program has maintained an effective involvement in all functional areas. A more direct involvement'in improving plant performance is evident by initiation of such projects as a study of control and lube oil, an area which has caused numerous operational problems in the plant. Also, Quality Assurance is contributing to the ongoing improvement of the records storage progra f I
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9 Facility Performance Functional Category Category Recent Area last Period This Period Trend (February 1,1983 - (August 1, 1984 -
' July 31, 1984) July 31,1985) Plant Operations 2 2 Improving Radiological Controls 3 3 Improving Maintenance 1 2 Improving Surveillance 1 1 Consistent Fire Protection /
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Housekeeping 3 2 Improving Emergency Preparedness 1 1 Consistent Security and Safeguards 2 1 Consistent Outage Management and Modif.ication No basis Activities 2 2 for assessment
. Licensing 2 2 Improving
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l IV. PERFORMANCE ANALVSIS Plant Operations (32.0%, 894 hours0.0103 days <br />0.248 hours <br />0.00148 weeks <br />3.40167e-4 months <br />)
The operations area, including operational support activities, was under continual review by resident inspectors throughout the period with observations in the areas of compliance with license and procedural requirements, training, corrective action systems, onsite committees, and reporting systems. As a result of key management changes initiated onsite, management activities associated with the overall operation of the facility were closely followed during this perio During this period, the licensee effectively managed the overall operation of the facility. Unit availability during the period was the best achieved since initial plant startup while the number of challenges to reactor protection systems and the number of reportable events in the operations area were comparable to the previous assess-ment perio During. followup inspection activitie's for plant events, licensed operators displayed a detailed working knowledge of the plant and the ability to analyze end explain transient response. This indicates experience and a good state of training. ' Shift turnovers are conducted in a thorough and professional manne Significant improvements related to control room habitability and environment have been complete These improvements complement and enhance the professional approach displayed by control room personne ~ Heavy demands were placed on the Operations and Training Departments to complete training in symptom-oriented emergency procedures and to train a class of.SRO candidate The training will enable the licensee to meet their commitment to the NRC to implement the'new emergency procedures in October, 1985. General simulator performance by the SRO class was outstanding, particularly with respect to the use of the symptom-oriented emergency procedures, teamwork, and diagnostic ability. With the licensing of 11 of 12 new SR0 candidates, the licensee is sufficiently staffed with operators to meet-commitments for licensed operator staffing with little or no use of overtim Major concerns ~ highlighted during the previous period were related to timeliness of long-term corrective action programs, Station Nuclear Safety Committee reviews, lack of an effective records management system and, administrative reviews of Licensee Event Report At the beginning of this assessment period, a new General Manager of Technical Support was selected who functions as chairman of the Station Nuclear Safety Committee (SNSC). Improvements have been made in the quality of the reviews of events, procedures, and other items by the SNSC. Also, a multi-disciplinary group called the " Corrective
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Action Committee" has been formed to review test and equipment history and trends to determine root causes of failures and evaluate corrective actions to improve plant safety and reliability. The effectiveness of this initiative has not been reviewe Two violations resulted from inadequate records management. As a result of previously identified deficiencies the licensee has initiated a comprehensive review and revision of the records manage-ment program. The upgraded program is expected to be implemented in January 198 This time frame seems appropriate because of the program's large scope. .In the interim, improvements have been noted in records management, in particular, licensee responses to the TMI Action Plan tracking system were consolidated and prompt retrieval of records was noted during an inspection of those item Two violations were isroed relating to implementation of Technical Specification amendments and_one violation for failure to maintain plant logs in accordance with procedures. The licensee responded promptly to these violations and instituted adequate corrective action As noted in Section E, plant housekeeping effort has shown marked improve-ment during the latter half of this assessment perio Operations Department personnel played a significant role in the improvements in the nonradiological area The Operations Department completed a review and upgrade of procedure Only one licensee event was attributed to procedural inadequacy during this assessment compared with three during the preceding perio The licensee increased the number of shift technical advisors (STA)
to 22 and 4 additional candidates are completing training. STAS are assigned a 24-hour tour of duty at the plant and although assigned other duties at the plant, the STA duties take priority. This approach vis-a-vis the potential benefits accruing from a greater shift integration of STAS should be evaluated by the license Improvements are needed in both written and verbal reports of events by the licensee. One violation was issued for not promptly issuing a LER. Safety evaluations have been usually brief and sometimes not comprehensive. For most reports no statement is made to-document prior similar events, and the coded information was frequently omitted or incorrect. Also, one LER (84-025) contained two events that should have been reported separatel A review of the prompt notification of an event on April 16, 1985 received by the NRC HQ Duty Officer showed that a more complete description of events was called fo Licensee management initiated prompt corrective actions including training and procedure reviews, and committed to long-term corrective actions in response to this concern. This problem has not recurred in the few prompt notifica-tions made since Apri .
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L 12 . Conclusion Rating: Category 2 Trend: Improving ' Board Recommendations Licensee: Review causes of trips to reduce frequency of challenges to safety systems. Consider effectiveness of STA program, particularly shift' integration, in light of recent industry experienc NRC: Review activities of off-site safety review committe .
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13 b Radiological Controls (19.5%, 543 hours0.00628 days <br />0.151 hours <br />8.978175e-4 weeks <br />2.066115e-4 months <br />) . Analysis J
There were eight inspections conducted by radiation specialists of
, ' areas affecting radiological controls during this period. Included were radiation protection program implementation, radiochemistry capability, effluent monitoring and_. control, and environmental monitoring. Special inspections were also conducted to review
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implementation of the licensee's action plan to upgrade the radiation protection program and verify and validate implementation of certain
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post-accident sampling and monitoring capabilities specified in NUREG-0737. Resident inspectors also.provided periodic. review of
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radiological control relate' activitie '
Previous asse'ssment of this area revealed substantial weaknesses in the
. . radiation protection program as evidenced by numerous violations and
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programmatic deficiencies and the inability to identify and effect corrective measures necessary to reverse a declining trend in program performance. As a consequence of repeated instances of unplanned radiation exposure to workers, identified at the end of the previous
assessment period, an Order Modifying License was issued September 27, 1984. This Order prescribed specific actions and measures to
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upgrade the radiation protection program. Included was the formation
- of a special senior level Oversight Committee to monitor and report on the effectiveness and quality of the program and the progress of upgrade actions to the Vice President of Nuclear Power and the NRC
. Regional. Administrato As a result of these measures, the licensee has implemented, and continues to demonstrate,. aggressive and thorough development o , program elements, including procedures, personnel training, radio-logical audit and assessment, and ALARA. Additionally,.the Vice President of Nuclear Power is directly involved in the upgrade
activities and maintains a highly visible interest in assuring the
, quality of the program and the completion of planned improvement as scheduled. The Oversight Committee conducts thorough evaluations of program performance. A majority of the committee's recommendations
have been incorporated as program improvement The upgraded Radiological Protection Program became effective on July 1, 1985, on schedule. The new policies involved in the implementation of the.new program were well stated and disseminated to the staf For example, as of July 11, 1985, 56 training sessions had been con-ducted involving about 1000 workers. Each session was personally
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introduced by either a General Manager or the Vice President of i- Nuclear-Power. In this endeavor, previous problems were honestly portrayed and the bases for the upgraded program were. detailed. The s
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training program is designed to provide a thorough understanding of the upgraded radiological controls program. Training provided to workers included training in work practices and procedures in a mock
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radiologically controlled area. Strong emphasis was placed on high radiation area access control, self-monitoring while in these areas and Radiation Work Permit usag These items were particularly weak in the previous assessment period and, as a result of the new traini.ng emphasis, improved performance by the end of this SALP period was evident. Three violations were noted during this assessment period, two of which involved failure to follow procedures resulting in unplanned exposure to workers. This type of violation was typical of the licensee's previous program and occurred prior to the Order Modifying License. These violations also occurred prior to the implementation of the Action Plan to upgrade the radiological controls program. Though the effectiveness and results of the upgrade effort have yet to be evaluated, the foundation of the program is substantially stronger than previously note Personnel changes in the organization were made to strengthen management controls over the program. Selection, qualification and training of personnel is well defined by new procedures and criteri Procedures have been completely reviewed and, in most cases, rewritten to assure effective use. All major elements of the program are defined by Station Administrative Order which assures that the implementation of the radiation protection program is a matter of station policy rather than departmental requirements. This reflects management support to a strong radiological safety program, a change from past practic An aggressive radiological assessment program, independent of the Radiation Protectior.'D?partment, provides direct feedback to responsible managers to effect corrective measures. While some questions remain on formalizing procedures and policies in this area, recent audits have been extensive, thorough and effective in creating awareness of program performanc An ambitious and aggressive ALARA program has been initiated as evi-denced by enhanced corporate policies and'the development of a speci-fic Station Administration Order. Actual implementation is exempli-fied by a program to reduce primary system activity, and extensive decontamination of the primary auxilury building. Both these efforts required the dedication of significant technical and personnel resources and should result in further reduction in contaminated areas and personnel exposure. Though the effectiveness of the new ALARA program is yet to be evaluated, the new program appears to be technically sound and workabl The results of improved management is evident in the Unit i rad-waste area where extensive efforts have been expended with significant reductions in the volume of radioactive waste and contaminated area A special inspection of the licensee implementation of the post-accident sampling and monitoring specifications of NUREG-0737 indi-cated that generally technically sound and thorough approaches were used. The post-accident sampling capability was found to be very
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reliable and reasonably accurate. While some technical deficiencies were noted, corrective measures were initiated to effect resolutio A review of the effluents, environmental monitoring, and plant radio-chemistry found technically sound programs in place to meet the requirements of the licens Radiochemical samples split with the
~NRC indicated that all analyses were in agreement. One minor viola-tion w'as cited for failure to have a procedure to implement the ODC In these programs, though examples were noted where documentation was not properly reviewed, or omissions of information were made in procedures, prompt corrective measures were effected to resolve these item Summary
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The licensee commenced this assessment period with a radiological controls program characterized by repeated violations ~and ineffective corrective action indicative of a programmatic breakdow Following several management meetings, an Order Modifying License was issued. A completely revised radiation protection program was developed. A Radiation Protection Oversight Committee, independent of the licensee and reporting to the Vice President, was constituted to provide assess-
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ment of the adequacy of corporate and station policies, practices and performance of the radiation protection program and to assess progress in upgrading the program. Nine months were required for program development and to train personnel in the implementing procedure This program was reviewed during development by members of the Region I Radiological Protection Branch. This effort is expected to produce marked improvement; however, full implementation one month prior to the close of the assessment period with the unit at full power pre-cluded meaningful evaluation of the results. The " Improving" trend noted in the conclusion to this section resulted from the apparently successful implementation of this revised program during the las quarter of this period and the significanct improvement in management support and oversight of the radiological control progra . Conclusion Rating: Category 3 Trend: Improving 3. Board Recommendations Licensae:
Continue implementation of upgraded program in accordance with commitments pursuant to Order Modifying Licens NRC:
Monitor the effectiveness of program improvements by performing pro-grammatic inspection prior to the next refueling outage. Assessment of program implementation to be performed during outag .
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Conduct Management Meeting to review program status and compare with available observation _
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17 M'aintenance (11.2%, 314 hours0.00363 days <br />0.0872 hours <br />5.191799e-4 weeks <br />1.19477e-4 months <br />) Analysis The assessment during the previous SALP was based largely on highly specialized maintenance / modification activities; e.g., steam generator tube leak repairs. This assessment is based primarily on non-outage maintenance activites. Meaningful comparison of outage performance in this functional area between the two periods is not appropriat The resident inspectors routinely observed corrective and preventive
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maintenance activities. Region based inspectors examined the maintenance aspects of Generic Letter 83-28, the Salem ATW The maintenance program is well established with capable management and a large and experienced staff. Maintenance activities are preplanned and properly classified. QC hold points were established in most procedures reviewed. Quality related maintenance records reviewed were complet A large backlog of non-outage work orders had developed during the assessment period. When the resident inspectors discussed this concern with licensee management, it was apparent that they were aware of the situation and were taking steps to reduce the maintenance backlo These steps included improving efficiency, scheduling, quality of work orders, and the addition of 25 temporary, but experienced maintenance workers from the utility's off-site work forc Because licensee management is committed to improving the physical condition e
of the plant, they have encouraged staff to be alert to equipment deficiencies and report them. This resulted in an initial increase in work orders. However, a decreasing trend in the number of work orders was established by the end of this assessment perio The licensee has initiated a computerized Power Plant Maintenance Information System (PPMIS) for controlling work orders. Although the capabilities of this system are not yet fully developed, it seems to be contributing to more efficient handling of work orders ar.d improved management, planning, and scheduling of the maintenance prr, gra The PPMIS is also to be used in trending equipment failure The' licensee has assembled a Classification Support Package to com-bine all the existing guidance that has been developed to properly classify a component. This package, however, is not a controlled documen The licensee expects to develop a computerized equipment table as part of the PPMI The licensee is establishing control of vendor-furnished technical manuals and documentation. The vendor equipment manual control program is expected to be implemented by January 198 During a review of equipment storage facilities, some safety-related items were found stored in the plant satellite lay-down area without
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providing for the required preventive maintenance or periodic examina-tion. This concern was brought to the licensee's attention and management provided prompt and effective corrective action by direc-ting QA to " embargo" all material stored in.that lay down area and to review each item for deterioration prior to its release for us The IP-2 Central Store (warehouse) has been relocated to Cortlandt, 8 miles away from the plant. The new facility is an improvement over the old storage area, in that there is more, better organized space and level A storage has been provided. The designated materials have been moved to this new warehouse and improvement has been noted in the handling and issuance of stoc . Conclusion Rating: Category 2 Trend: Improving 3. Board Recommendations None
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19 Surveillance (8.4%, 235 hours0.00272 days <br />0.0653 hours <br />3.885582e-4 weeks <br />8.94175e-5 months <br />) Analysis Surveillance activities were routinely observed by the resident inspectors. ~ Region-based inspectors observed the Containment Leak Rate Test and reactor trip breaker surveillance test During this assessment period, the licensee maintained a high level of performance in the surveillance program. The surveillance program is well established. Individuals performing surveillance are quali-fied and experienced. Procedures are well developed with adequate format and technical conten Scheduling of surveillances is tracked by a staff member using a computerized tracking syste During this assessment period, one surveillance test was not done within the required schedule. This was a semi-annual operability -test of smoke detectors in the Safety Injection Pump cubicle. The detectors were tested a month late and found to be operable. For corrective action, the licensee has divided all smoke detectors among~four surveillance procedures for easier tracking of individual detector test Corupleted surveillance tests are reviewed by qualified individual No instance was identified in which a failed surveillance test did not result'in a declaration of inoperability and application of the appropriate action statemen ,
Test-related instrumentation was observed to be properly calibrated and the calibration documentation was complete and traceabl Containment Leak Rate test strategies were observed by the inspector to be well defined and structured in a manner to address any contingencies and resolve'related prcblems identified during the
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test. As a result, during the first unsuccessful CLRT attempt, the
- licensee recognized the test shortcoming and appropriately issued a Licensee Event Report which was followed by a supplemental investigation notification. The subsequent CLRT test was conducted successfully. The inspector, using raw test data, performed an
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independent calculation of the test result and verified the accuracy of the licensee's computer generated calculatio Surveillance test results related to high pressure boundary valves whose leakage could lead to intersystem LOCA (Event V) were inspected by the Resident Inspector. While a specialist inspection remains to be performed, no areas of concern were found by the Resident Inspecto .
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20 Conclusion Rating: Category 1
' Trend: Consistent Board Recommendations None
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E. Fire Protection and Housekeeping (5.6%, 155 hours0.00179 days <br />0.0431 hours <br />2.562831e-4 weeks <br />5.89775e-5 months <br />) Analysis One region based inspection and resident inspector observations provide the basis for the fire protection assessment. Observations by all inspectors visiting the facility provide the basis for the housekeeping assessmen In the previous assessment period, the licensee's fire protection program was identified as an area for increased management and NRC attentio The reason for the poor rating was multiple minor violations stemming from inadequate procedures or inadequate hardware modifications to fire protection system Management's reaction to this evaluation was an increased involvement in areas that control and assure quality in the Fire Protection are This involvement is apparent in the area of quality assurance audits of Fire Protection required by Technical Specifications. These. Fire Protection Program audits, particularly those utilizing qualified offsite auditors, are complete, thorough, and timely. These audits attempt to not only identify weaknesses, but try to identify trend The licensee's fire protection program record keeping is adequate, with records well maintained and readily available. With regards to being responsive to NRC concerns, the licensee's responses are technically sound and proposed resolutions to various con'cerns are acceptable as evidenced by the number of unresolved items being close .
The licensee conducted a comprehensive review of fire protection commitments made to the NR Procedure changes and a few hardware changes resulted from this revie An area of previous NRC concern was the lack of an adequate and clearly defined fire protection program. This was addressed by the licensee by revising the plant fire protection procedures, establishing new corporate fire protection procedures for the nuclear plant, and by utilizing qualified consultants to set forth a fire protection program based on NRC guideline Staffing in the area of fire protection is adequate, positions are identified with authorities and responsibilities well define The onsite staff responsible for the implementation of the fire protection program is competent and has direct access to senior management onsite to resolve and expedite fire protection issues. As a result of frequent plant tours by the fire protection staff, transient fire hazards in the plant are kept to a minimum. Training of brigade members is adequate with each person participating in the required number of drill .
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Housekeeping and cleanliness of the facility was poor during the first half of this assessment period. However, the licensee has made a major effort to clean up and refurbish the plant. Housekeeping is now much improved throughout the plant. Management's commitment to establish and maintain good housekeeping is eviden . Increased pride in the plant by the plant staff, due to the improved appearance, is also eviden . Conclusion Rating: Category 2 Trend: Improving Board Recommendations P
Licensee: Continue to emphasize good housekeeping practice NRC: None
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23 Emergency preparedness (4.3%, 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br />) Analysis A partial exercise was conducted on June 5, 1985 which was observed by a team of six NRC Region I and NRC contractor personnel. As a result of the exercise, the inspectors concluded that, within the limitations of the exercise, the licensee's emergency response actions provided adequate protection of.public health and safet The licensee has been responsive to NRC initiatives in that the exercise objectives and scenario package were submitted to the NRC in a' timely manner so that Region I personnel were able to perform an adequate review. In addition, licensee personnel were noted to provide the appropriate upgrades of the scenario as requested by the NRC to demonstrate abilities in the areas of operational assessment, technical support to operations, radiation surveillance, general health physics practices, repair and corrective actions and decision'
making. The upgrade'of the scenario provided the opportunity for the licensee to demonstrate to the NRC during the conduct of the exercise that previously identified concerns were adequately correcte During the exercise, the NRC team identified that the Emergency Action Levels in the Emergency Plan resulted in confusion among-key licensee participants when classifying events. The licensee should evaluate the procedures used to_ determine Emergency Action Levels to eliminate possible ambiguitie The NRC team attended the licerisee's post exercise critique on June 6, 1985 during which key licensee controllers discussed observations of the exercise. At the conclusion of the critique, the NRC team determined that the licensee had the ability to identify areas for improvemen Region I also observed a full-scale exercise conducted at Indian Point 3 on November 28, 1984. Two major deficiencies in the offsite facilities were noted by FEMA Region II during this exercise (Indian Point 2 and 3 share the same offsite facilities.) The problems dealt with difficulties in emergency broadcast rressages from the joint news center and delayed protective action recommendations from Rockland County. Although these deficiencies were beyond the control of the licensee they were corrected and' cleared as a result of an exercise on April 10, 1985. Coned emergency planning staff played an-active role in resolving these deficiencie . Conclusion Rating: Category 1 Trend: Consisten ,, . . . n - . .
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G. Security and Safeguards (12.6%, 353 hours0.00409 days <br />0.0981 hours <br />5.83664e-4 weeks <br />1.343165e-4 months <br />) Analysis
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There were two unannounced physical security inspections performed by region-based inspectors and continual review of the security program during routine resident inspections during this assessment period. No violations were identified. In' addition, a Safeguards
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Regulatory Effectiveness Review (RER) (280 man-hours) was conducted by the NRC's office of Nuclear Material Safety and Safeguards. The RER did not identify any safeguards vulnerabilities, but did disclose some deficiencies which the licensee will be requested to addres It is felt that a majority of the deficiencies can_be resolved effec-tively by concentrating additional management attention in the identi-fied areas.
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The licensee was effective in achieving a high degree of performance during this assessment period, and continuing improvements in program l
l implementation were observed. Of particular note was an increase in management's attention to the program. This was evident by the continuing efforts to upgrade the Security Plan and implementing procedures, the purchase and installation of improved equipment, improvements to facilities, more indication of prior planning and interface with other departments on site, and increased attention to maintenance and testing ~of equipment. While maintenance and testing of security-related equipment received increased attention by the licensee during-this period, continued management involvement is warranted to strengthen the program more expe'ditiously. Weaknesses in the security barrier installations' maintenance and testing programs were also observed by the RER tea Corrective actions implemented as a result of violations identified during previous assessment periods have been effective; no violations l were identified during this period. Increased licensee emphasis on I the training and requalification program and on supervision of the contract security force contributed to the improved performanc Licensee reporting and analysis of events, in accordance with 10 CFR 73.71, are generally prompt and complete. Problems with the security computer which precipitated more than half the last pe-$od's 10 CFR 73.71 reports have been rectified; only one event related to the com-puter occurred during this perio .
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An analysis of the event reports submitted during this period (seven)
indicated a need to improve contract employee awareness of the security program and procedures. Two of the event reports involved the unauthorized entry into vital areas by contract employees and one involved a contract employee attempting to enter
'the protected area with a weapon in'the rear of a vehicle. The security force responded properly and effectively to these events in a prompt manner. However, there appears to be a need for increased emphasis in contract employee training to achieve compliance with security program requirement Compensatory measures, when required, were adequate and promptly implemente The site security program is directed by a licensee employee who had previously been assigned on an acting basis and was appointed on a permanent basis in the latter portion of the assessment period. He is assisted by a Field Operations Supervisor and four Shift Supervisors who are also licensee employees. The administrative workload appears to be appropriately assigned such that sufficient oversight can be exercised with respect to the contracto In about the middle of the assessment period, the licensee engaged the services of a new security force contractor to provide for the administration, supervision and training of the security force which remained essentially intact. The transition to the new contractor went very smoothl The licensee and the new' contractor have implemented several initiatives which should result in a strengthened program and an' increase in the morale of security personne The licensee's training and qualification progrcm has improved during
.this assessment period as evidenced by the lack of procedural violations by members of the security force. This is attributable to upgraded procedures, more effective training and an increase in management attention. Additionally, an increase in the frequency and realism of contingency plan drills was noted during the period which also may have contributed to better performanc Security program records were generally found to be complete and available. However, an effort should be made to centralize records and reports to enable easier and more effective proprietary oversight and awareness of program and equipment status. Several of the RER findings appear to be a. result of inadequate awareness on the part of site security management as!to the extent of certain self-idectified deficiencie While.the security program annual audit;during this assessment period appeared to be more comprehensive than previous audits, improvements could be effected by' conducting more frequent audits and narrowing the scope of each. This, coupled with a more detailed audit plan,
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27 i prepared by knowledgeable security personnel, would greatly enhance the audit program.
2. Conclusion Rating: Category 1 Trend: Consistent '
3. Board Recommendation None
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28 Outage Management and Modification Activities (6.4%, 178 hours0.00206 days <br />0.0494 hours <br />2.943122e-4 weeks <br />6.7729e-5 months <br />)
' Region-based inspectors. conducted inspections of the Cycle 7 refueling-startup physics testing, and Reactor Trip Breaker Shunt Trip
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Modification. The resident inspectors conducted reviews of on going outage activitie The cycle 6/7 refueling outage was completed during the first quarter of this assessment period. . Numerous technical issues were encountered during this outage. These included the installation of nozzle ~ dams, an expanded steam generator inspection program, and an indication in the reactor vesse The outage man-rem exposure was significantly over the estimated exposure Problems in the radiological controls area led to an Order Modifying License which is discussed in Section IV.B of this repor Licensee management has agressively pursued improvements in outage manage-ment. A reorganization has established a planning group with new responsi-bilities and approaches for the planning and scheduling of future outage activitie Based on inspectors' observations, it appears that adequate preparation is being made for the forthcoming outag During the last outage, the licensee completed all fuel movements without incident. This indicates good operator training and coordination with con-tractor The start-up physics testing procedures were adequate, and the test results were satisfactory and properly evaluated. The reactor engineering staff exhibited sound knowledge and competency in the areas inspecte The successful test completion and consistency in actual and intended fuel load schedule support the conclusion that the licensee's involvement to control quality was adequat The licensee implemented the Reactor Trip Breaker Shunt Trip Modification in a timely manner. Procurement, installation, operation, testing and maintenance of the. shunt trip circuitry were performed according to the approved progra During the assessment period, modification work on the Auxiliary Feedwater (AFW) pumps resulted in the power feeds to solenuid valves for the steam-driven AFW pump steam isolation valves being disconnected. The root cause was identified as inadequate drawings to describe actual field condition Licensee corrective actions include increased emphasis on field walkdowns by engineers prior to issuance of design change Since the plant was operating at power during the last quarter of the assessment period, no basis exists for determining a recent trend in this functional are . Conclusion Rating: Category 2 Trend: No basis for trend assessment
_ _ _ _ _ __
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.,
29 Board Recommendations Licensee: None NRC: ' Conduct team inspection to review modification management; specialist
. inspections of corporate design effort and corporate / site interfac .
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30A 1. Licensing Activities Analysis During the present rating period, the licensee's management demonstrated
~
active participation in licensing activities and kept abreast of current and anticipated licensing actions. The management's involvement was evident in the use of a Regulatory Action Tracking System in which all open actions were scheduled and tracked. The management's involvement in licensing activities generally assured a timely response to requirements of.the' Commission's rules. The licensee's management generally exercised good control over its internal activities and its contractors and maintained effective communication with the NRC staf Generally, the licensee has met schedules or informed NRC at an early date of schedule problems. However, it should be noted, that the licensee did not meet the revised schedule date contained in the Appendix R scheduler exemption issued October 16, 1984 and did not notify the staff that the schedule would not be me In addition, the licensee seems to have a great deal of difficulty processing a letter out of their office even when required on an urgent basis. We feel that improvement could be made in this are The interaction of the licensee, including visits and management dis-cussions/ meetings, with the NRC staff, have resulted in clear under-standing of safety issues. Generally sound technical approaches are taken by the licensee's technical staff toward their resolutio Conservatism is usually exhibited in relation to significant safety issue *
It should be noted that during the review of the IP-2 reactor vessel indication,- it is the staff's view that the licensee did not obtain sufficient field data to support his conclusion that the size of the vessel indication fell within'the acceptable limits of the industry code to not require repair or augmented inspection. Because the inspection tool had been removed from the reactor vessel, additional measurements on a representative vessel configuration as well as several meetings with the licensee were required to conclude that-while vessel repair was not required, augmented inspection of the vessel at a frequency of three times over the next ten years must be performe The good communications between the licensee and the NRC staff have been beneficial to both in the processing of licensing actions and minimizing the need for additional informatio The licensee has been responsive to NRC initiatives in most instance However, there are a few instances when the licensee's delays have
' caused delays in closing out issues. For instance, the licensee has delayed in responding to requests for additional information in the areas of Inservice Testing, Fire Protection Relief Valve and Safety Valve Testing, Control of Heavy Loads, and Snubbers Technical Speci-fication. In most other instances when the original commitment could l
.._ ___. _ _ _
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30 Licensing Activities
. . Analysis ;
During.the present rating period, the licensee's management emonstrated active participation in licensing activities and kept reast of current and anticipated licensing actions. The ma gement's involvement was evident in the use of a Regu.latory Act n Tracking System in which all open actions.were scheduled and track . The management's involvement in licensing activities
. genera assured a timely response to requirements of the Commissi 's rules. The licensee's management generally exercised good cont 1 over its internal activities and its contractors and maintained fective communication with the NRC staff. Generally, the licensee as met schedules or informed NRC at an early date of ,
schedule probi s. However, .it should be noted, that the licensee ,
did not meet the revised schedule date contained in the Appendix R schedular'exempti issued October 16, 1984 and did not notify the staff that the sche le would not be me In addition, the licen e seems to have a great deal of diff.iculty processing a letter out f their office even when required on an urgent basis. We feel th improvement could be made in this are The interaction of the licen e, including visits and management
~
l !
discussions / meetings, with the NRC staff, have resulted in clear understanding of safety issue enerally sound technical' approaches are taken by the licensee's techn cal staff toward their resolution.
Conservatism is usually exhibited relation ~to significant safety issue In most instances, sound technical just fication is provided by the licensee for deviations from staff guida However, it should be 4 noted that during the review of the reacto vessel flaw, in the opinion r of the staff, the licensee did not obtain s ficient field data to
'
. reach a definitive conclusion regarding the 1 ation and size of the j' . indication before the inspection tool was remo d from the. reactor
. vessel. This necessitated an augmented.inspecti program for long-
'
term resolution.
,
The. good communications between the licensee and the C staff have
-
been beneficial to both in the processing of licensing ctions and minimizing the need for additional informatio The licensee has-been responsive to NRC initiatives in most instance However, there are a'few instances when the licensee's delay have caused delays in closing out issues. For instance, the licens has
- delayed in. responding to requests for additional information in he
~
,
areas of Inservice Testing, Fire Protection, Relief Valve and-Sa y
- Valve Testing, Control of Heavy Loads, and Snubbers Technical Spe -
fications. In most other instances when the. original-commitment cou
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not be met, the licensee was prompt to discuss the problems and pro-vide a new schedule. It should be noted, however, that the licensee is usually much quicker responding to their own initiatives than the NRC' '
The licensee has a licensing staff which' appears ta be sufficient to provide adequate and timely response ~ Conclusion Rating: Category 2 Trend: Improving Board Recommendations
~None
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V. SUPPDRTING DATA AND SUMMARIES Escalated Enforcement Actions t Civil Penalties None Orders Order Modifying License dated September 27, 1984 to establish an effective program to assure adequate radiological controls of licensed activities and to minimize the-radiological hazards associated with the performance of those activitie . Confirmatory Action Letter None
. Management Conferences Held During the Assessment Period
- November 7, 1984 -'SALP Management Meeting at Indian Point Unit . January 3, 1985 -
Management Meeting at NRC Region I on supplemental information provided by-the licensee in response to Order Modifying Licens Licensee Event Reports (LER's)-
Tabular Listing Type of Events Personnel Error 5
' Design. Man./Constr./ Instal External Cause 0 Defective Procedure 2 Component Failure 16 Other 1
__
TOTAL 25
,
. Causal Analysis-
-1- - - .,,,_m - , ._-.r - , , . . . -
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O
Two common causal chains were identified:
. Service Water Pump Discharge Check Valve Leakage 84-011 CCW pump motors tripped on overcurrent after the CCW pump cubicle flooded during outage maintenanc The water leaked past service water pump discharge check valves from the essential to the non-essential heade While at cold shutdown, leakage was observed past service water pump discharge check valves. This could have led to service water pumps being inoperable. No mention was'made in this LER of the previous similar even Based on the Indian Point 2 Probabilistic Risk Study, the service water system' is the second most important system in reducing risk and failure of the discharge check valves are a significant failure mode for that syste _
The affected check valves were repaired and tested satisfactoril Loss of Main Boiler Feed Pumps Result in Unit Trip 85-02 One main boiler feed per,5 tripoed and in the course of the resulting transient, the reactor tripped due to high pressurizer pressur Both main boiler feed pumps tripped. The operator manually tripped the unit in anticipation of an automatic. tri One main boiler feed pump tripped and in the course of the resulting transient, the reactor tripped due to low-low level in steam generator #2 The control oil systems for the main boiler feed. pumps were overhauled. Three conditions were discovered and repaired that could have caused the pumps.to tri l I
l
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T1-1 TABLE 1 TABULAR LISTING OF LERs B'Y FUNCTIONAL AREA INDIAN POINT STATION, UNIT 2 Cause Code Area A B C D E X Total Plant Operations 3 1 1 5 Radiological Controls O Maintenance 1 1 Surveillance 1 1 Fire ~ Protection /
Housekeeping 1 1 Emergency Preparedness 0 Security and Safeguards 0 Outage Management and Modification Activities 1 1 2~ Licensing Activities 0 Other 15 15
. Totals 5 1 0 2 16 1 25 Cause Codes: Personnel Error Design, Manufacturing, Construction, or Installation Error External Cause Defective Procedure Component Failure Other
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T2-1 TABLE 2 INSPECTION HOURS SUMMARY (8/1/84 - 7/31/85)
INDIAN POINT STATION - UNIT 2 Hours % of Time Plant Operations. . . . . . . . . . . 894 3 Radiological Controls . . . . . . . . 543 1 Maintenance . . . . . . . . . . . . . 314 1 D. . Surveillance. . . . . . . . . . . . . 235 Fire Protection / Housekeeping. . . . . 155 Emergency Preparedness. . . . . . . . 120 Security and. Safeguards . . . . . . . 353 1 Refueling (Modifications) . . . . . . 178 Licensing Activities. . . . . . . . . N/A N/A Total 2792 100
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T3-1 TABLE 3 ENFORCEMENTSUMMARY(8/1/84-7/31/85J INDIAN POINT STATION - UNIT 2 Number and Severity Level of Violations Severity Level No Severity Level I 0 Severity Level II 0 Severity Level III 1 Severity Level IV 5 Severity Level V _4 Total 10 Violations Vs.. Functional Areas Severity Levels FUNCTIONAL AREAS I II III IV V DEV TOTALS Plant Operations 0 0 0 3 4 7 Radiological Controis- 1 2 3 Maintenance Surveillance
. Fire Protection & Housekeeping Emergency Preparedness - Security and Safeguards Outage Management & Modifications Licensing Activities
. Violation and Deviation Totals: 1 5 4 10
_
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T3-2 TABLE 3 (CONT'D) Summary - Enforcement Data Inspection Inspection Severity Functional Report N Date Re Level Area ___ Violation 84-21 8/1-8/31/84 10CFR IV Ops- Failure to produce 50.34 a system for receipt of QA records, retrieval of information without undue delay, and a list of personnel with file access.
, ANSI V Ops Failure to N4.2.9- maintain 1974 transient or operational cycling records on machiner ' 8/16-8/17/84 TS 6.11 Rad Con Failed to follow-Order 9/27/84 III procedures for S/G entry by not reading highest dosimete /27-8/31/84 TS 6.11 IV Rad Con Failed to follow procedures for S/G entry by not recording exposure after each jum /1-11/30/84 TS 6. IV Ops Failure to follow proper procedures for lo~gging abnormal plant parameter CFR50 IV Ops Failure to alter plant status in accordance with amendment change CFR V Ops Failure to present 50.73 a licensee event report within 30 days of even . . - . -
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T3- TABLE 3 (CONT'D)
- Inspection Inspection -Severity Functional Report N Date Re Level Area ___ Violation 85-05 2/25-3/1/85 TS 6. IV Rad Con Failure to establish written procedures covering the off
, site dose calculation manual 85-10 4/1-5/17/85 10CFR50 V Ops Failure to 0AD-21 provide an information feedback system sign-off shee /1-7/31/85 TS 6. V Ops Failure to follow procedure t
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. l T4-1 TABLE 4 INSPECTION REPORT ACTIVITIES (8/1/84-7/31/85)
INDIAN POINT STATION - UNIT 2 Report / Dates Inspector Hours Areas Inspected 84-21 Resident 110 Routine, daily inspections and 8/1-8/31/84 unscheduled backshift inspections 84-22 Specialist 25 Roetine, unannounced inspection 8/16-8/17/84 of the licensee'~s radiation protection program 84-23 Specialist 32 Routine, unannounced inspection 8/20-8/24/84 of the licensee's radioactive waste management program 84-24 Specialist 45 Routine, unannounced inspection 8/27-8/31/84 of the licensee's radiation protection program 84-25 Specialist 30 Routine, unannounced inspection 9/17-9/21/84 of the licensee's nonradiological
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chemistry program 84-26 Resident 137 Routine, daily inspections and 9/1-9/30/84 unscheduled backshift inspections 84-27 Specialist 49 Routine, unannounced inspection 9/17-9/21/85 of the containment leakage testing program 84-28 Specialist 76 Routine, unannounced safety 9/27-9/28/84 inspection of'the_ licensee's 10/16-10/19/84 radiation protection program 84-29 Specialist 36 Routine, unannounced inspection 9/24-9/28/84 cf physical protection and safeguards
" 84-30 Resident 178 Routine, daily inspections and
'
10/1-10/31/84 unscheduled backshift inspections 84-31 Specialist ~ 40 Routine, unannounced inspection 10/1E-10/19/84 of startup physics testing following refueling of Unit 2, Cycle 7
,
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T4-2 Table 4 (Continued)
84-32 Residen Routine, daily inspections and 11/1-11/30/84 unscheduled backshift inspections 84-3 Resident 82 Routine, daily inspections and 12/1-12/31/8 unscheduled backshift inspections 84-34 Resident 18 Special inspection of throttle 12/10-12/19/84 valves setting in the auxiliary feedwater system 85-01 .
Resident 116 Routine, daily inspections and 1/1-1/31/85 unscheduled backshift inspections 85-02 Specialist 170 Special, announced safety 1/14-1/18/85 inspection of the licensee's implementation and status of NUREG-0737 85-03 9 Meeting - Requested by NRC to 1/3/85 discuss supplemental information provided by licensee in response to order modifying license 85-04 Resident 89 Routine, daily inspections and 2/1-2/28/85 unscheduled backshift inspections 85-05 Specialist 102 Routine, unannounced inspection 2/25-3/1/85 of the licensee's chemical and radiochemical measurements program 85-06 Cancelled 85-07 Resident 96 ' Routine, daily inspections and 3/1-3/31/85 unscheduled backshift inspections 85-08 Specialist 37 Routine, unannounced physical 3/25-3/29/85 protection inspection 85-09 . Specialist 124 Announced inspection of-3/25-3/29/85 licensee's actions to address the concerns identified in NRC Generic Letter 83-28 85-10 Resident 201 Routine, daily inspections and 4/1-5/17/85 unscheduled backshift inspections
. .
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T4-3 Table 4 (Continued)
85-11 Specialist 32 Special, announced inspection to 4/10-4/12/85 review the licensee's implementation of radiological controls improvement program
'
85-12- Cancelled 85-13 Cancelled 85-14 Specialist 120 Routine, announced emergency 6/4-6/6/85 preparedness inspection 85-15 Resident 139 Routine, daily inspections and 5/18-6/30/85 unscheduled backshift inspections 85-16 Specialist 116 Licensed operator exams and 7/8-7/12/85 review of requalification program 85-17 Specialist 12 Review of licensee's contingency 6/17-6/21/85 plans for continued operation during a possible strike 85-18 . Resident 132 Routine, daily inspections and 7/1-7/31/85 unscheduled backshift inspections 85-19 Specialist 43 Review of environmental 7/22-7/26/85 monitoring system
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85-20 Specialist 40 Fire protection program 7/22-7/26/85
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T5-1 TABLE 5 LER S NOPSIS (8/1/84-7/31/85)
INDIAN POINT STATION, UNIT 2 LER Number Event Date Cause Code Description 84-008 7/13/84 E Spurious Act'uation One Channel Safety Injection While Shutdown 84-009 7/19/84 E Reactor Coolant Pump Undervoltage Setpoint 84-010 7/23/84 E Excessive Service Water Containment Isolation Valve Leakage 84-011 8/13/84 E Flooding of CCW Pump Motors84-012 9/10/84 E Auxiliary Feedwater Pump Relays Defective f
84-013 9/20/84 B Deficient Fire Dampers 84-01 /7/84 D 480 V Undervoltage Relay Setpoints Not Changed per Technical Specifications84-015 10/8/84 A Safety Injection Signal on Loss of Instrument Bus84-016 10/16/84 E Safety Valve Lifted, Suberitical Steam Generator Delta P Safety Injection Signal 84-017 10/21/84 A Turbine /Reac' tor Trip During Overspeed Test 84-01 /20/84 A Reactor Trip - Steam Flow / Feed Flow Mismatch, Steam Generator Low Level 84-019 10/22/84 E Turbine Fire - Turbine / Reactor Trip (6% PWR)
_- . . . _ _- ._ . _ - - _ -
.e
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T5-2 Table 5 (Continued)84-020 10/26/84 E Inoperable Cable Tunnel Fans Due to Closed Louvers84-021 10/02/84 E Service Water Pumps Inoperable Due to Check Valve Leakage 84-022 11/27/84 0 Auxiliary Feedwater Steam Isolation Valves Fail to Close in Test, Power Feed Disconnected During Modification 84-023 12/7/84 X Auxiliary Feedwater Valves Throttled Incorrectly 84-024 12/18/84 A Weld Channel to Electrical Penetration Inoperable (ILRT),
Personnel Error During e
Modification 84-025 12/19/84 E Turbine Generator Fire 12/19; Safety Injection Pumps Inoperable 12/28 84-026 12/28/84 E Spurious SI Signal (High Steam Flow Instrumentation Drf"t)85-001 2/2/85
~
A Turbine Generator Hydrogen and ,
Oil Leakage / Manual Reactor Trip, '
Cuno Filter Reassembled 1 Incorrectly ,
l 85-002 2/4/85 E Unit Trip /High Pressurizer l Pressure, One MBFP Tripped 85-003 2/13/85 E Hydrogen Recombiner Inoperable l 85-004 3/6/85 E Unit Trip / Faulty Relays, Steam j Generator Level Controls i l
'85-005 3/26/85 E Both MBFP's Tripped / Reactor Trip 85-006 4/16/85 E One MBFP Tripped / Reactor Trip
I
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T6-1 TABLE 6 PLANT SHUTDOWNS DATE DESCRIPTION CAUSE Oct. 17, 1984 Startup following Cycle 6/7 refueling / maintenance /10 year ISI outage Oct. 20, 1984 Reactor trip from 5% power: Operator did not Steam generator (SG) low level adequately respond-with steam flow /feedwater flow to plant conditions mismatch after switching from auxiliary to main feedwater pumps (MFP)
Oct. 20, 1984 Startup
'Oct. 21, 198 Reactor trip from 10% power during Operator used turbine generator overspeed tes incorrect gauge during overspeed tes Oct. 21, 1984 Startup Oct. 22,-1984 Reactor tripped from 6% power: Turbine: oil fire turbine manually tripped Reactor: low setting on interlock P-7 Oct.;23, 1984- Startup Nov. 30, 1984 Reactor shutdown for scheduled maintenance Dec. 2, 1984 Startup
~Dec. 19, 1984 Reactor tripped: low SG level Turbine generator while rapidly shutting down from hydrogen and oil 100% power fire-Dec. 27, 1984 Startup
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Table 6 (continued) T6-2 Dec. 28, 1984 Reactor shutdown because safety Leaking boron injection (SI) pumps inoperable injection tank (BIT) valves and inadequate flushing procedures caused boric acid solidification of SI pump Jan. 2, 1985 Startup
.
Feb. 2, 1985 Reactor manually' tripped from
~
Incorrect 50% power re-assembly of filter led to hydrogen seal oil system malfunction Feb. 4, 1985 Startup Feb. 4, 1985 Reactor trip from 100% power: One MFP tripped high pressurizer pressure following turbine runback with control rods in manual and steam dumps in pressure mode -
Feb. 5, 1985 Startup Mar. 6, 1985 Reactor trip from 100% power: Faulty relay in SG SG low level with stea.t flow / level controller feedwater flow mismatch Mar. 7, 1985 Startup Mar. 26, 1985 Manual trip from 25% power Both MFP tripped in anticipation of automatic trip Mar. 27, 1985 Startup
,
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Apr. 16, 1985 Reactor trip from 100% power: One MFP tripped low-low SG level Apr. 17, 1985 Startup
.
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ENCLOSURE 3
.,e e*CEfog UNITED STATEL Oe 4 hg NUCLEAR REGULATORY COMMISSION g o REGloN I
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OCT 111985 Docket No. 50-247 Consolidated Edison Company of New York, In ATTN: Mr. Murray Selma Vice President, Nuclear Power Indian Point Station Broadway and Bleakley Avenue Buchanan, New York 10511 Gentlemen:
Subject: Systematic Assessment of Licensee Performance (SALP) Report No. 50-247/85-99 The NRC Region I SALP Board has reviewed and evaluated the performance of activities at the Indian Point Nuclear Generating Station Unit 2, Buchanan, New York for the p2riod August 1,1984 through July 31, 1985. The results are contained in the enclosed repor A meeting to discuss this assessment has been scheduled for 9:00 a.m., October 25, 1985, at the Region I offices, King of Prussia, Pennsylvani At the SALP meeting, you should be prepared to discuss our assessments and-your plans to improve performance where weakness was noted. The meeting is intended to be a dialogue wherein any comments you may have regarding our report may be discussed. Additionally, you may provide written comments within 20 days after the meetin Your cooperation is appreciate
Sincerely,
_
Thomas E. Murley Regional Administrator Enclosure: SALP Repo-t No. 50-247/85-99 Docket No. 50-247 '
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r. 6,T 1 1) S Consolidatsd Edison Company 2 of New York, In '
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cc: w/ enc 1:
J. Reliability D. O'Toole, Vice President, Nuclear Engineering, Quality Assurance and M. Blatt, Director, Regulatory Affairs F. Mitra, Resident Construction Manager R. L. Spring, Nuclear Licensing Engineer
~ Kokolakis, Director, Nuclear Licensing Brent L. Brandenburg, Assistant General Counsel Public Document _ Room (PDR)
local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident ~ Inspector State of New York
.