ML18018A569

Forwards Replacement Page 2 to Attachment 2 of 830520 Ltr Which Commented on SALP Rept

ML18018A569
Person / Time
Site:	Harris, Brunswick, Robinson, 05000000
Issue date:	05/27/1983
From:	Eury L CAROLINA POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML14184A421	List: ML14184A424 ML18018A569
References
LAP-83-215, NUDOCS 8306290555
Download: ML18018A569 (4)

Text

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r Carolina Power & Light Company Aa ~~I< f Pll: ~ I)

SERIAL: LAP-83-215 May 27, 1983 XX'~

Mr. James P. O'Reilly, Regional Administrator United States Nuclear Regulatory Commission Suite 2900 101 Marietta Street, NN Atlarta, GA 30303 RESPONSE TO SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) BOARD ASSESSMENT OF BRUNSHXCK, H. B. ROBINSON, AND SHEARON HARRIS PLANTS REPORT NOS. 50-325/83-09, 50-324/83-09 50-261/83-07, 50-400/8 -10 AND 0-401/83-10

Dear Mr. O'Reilly:

Please find attached a replacement page for page 2 of Attachment 2 to 'Carolina Power & Light Company's letter of May 20, 1983 (Serial:

LAP-83-195), which provided comments on the SALP Board assessment of the Brunswick, H. B. Robinson, and Shearon Harris Plants. This replacement page corrects a typographical error which appeared in the section entitled "Maintenance." Please replace the original page with the attached revision.

This change was discussed with Mr. P. R. Bemis of your staff on May 27, 1983.

Should you have any questions on this matter, please do not hesitate to call.

Yours ver y truly,

/g~znzi L. M. Eury Senior Vice President Power Supply JJS/mf (037SRZa)

Attachment cc: NRC Resident Inspector (SHNPP)

NRC Resident Inspector (BSEP)

NRC Resident Inspector (HBR) 8306290555 8306i4 PDR ADOCK 0500026i Q

PDR 411 Fayettevilte Street ~ P. O. Box 1551 ~ Raleigh, N. C. 27602

CP&L is confident that the initiatives undertaken above and the level of management involvement and attention evident in these actions will result in continuing enhancements in this area during future SALP evaluation periods.

With the recognition of the CP&L initiatives under taken, the effective corrective actions implemented, and the level of management involvement and attention evident in the area during the evaluation period proper ly noted, CP&L believes a Category 2 rating is appropriate.

Surveillance (SALP Board Rating: Category 1)

No comment.

5. Fire Protection (SALP Board Rating: Not Rated)

CP&L'elieves that a Category 1 rating is justified for fire protection. Several outside organizations and persons (including NRC Inspectors) have made positive comments about the Robinson Plant Fire Protection Program and Organization.

During the evaluation period, Fire Protection Technical Aides were placed on each operating shift; weekly and daily housekeeping and Fire Protection inspections were per formed by the Fire Protection Technical Aides; the training in the area of Fire Protection, both for Fire Protection personnel and plant personnel, in general, has been substantially increased; and generally, problems uncovered in the Fire Protection area have been found and identified by CP&L, with appropriate corrective action implemented in order to preclude recurrence. Therefore, there has been sufficient licensee activity to justify a rating.

Although, the SALP Report stated that "there was 'not sufficient inspection activity in this area (Fire Protection) during the evaluation period to justify a rating" the Report also states "no violations were identified." Since the SALP Board also stated, "the level of plant fire safety was greatly improved," and the previous SALP evaluation on Fire Protection was a Category 2, it would be appropriate for the Fire Protection area to have been rated a Category 1.

6. Emer enc Pre aredness (SALP Board Rating: Category 2)

No comment.

7. Securit and Safe uards (SALP Board Rating: Category 2)

No comment.

8. ~Refuelin (SALP Board Rating - Category 1)

No .comment.

9. Licensin Activities (SALP Board Rating Category 3)

"Licensing Activities" has not been used as a category for evaluation in previous CP&L SALP Reports, accordingly it. is difficult to

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responding to the new rule were anticipated when considering'he resources and time previously devoted to satisfying the approved SER.

With respect to Project Management Administration, CP&L recognizes that timeliness and thoroughness have occasionally been problems with respect to licensing issues. We also believe, however, that the report fails to recognize the extraordinary demand placed on the licensing and plant staff during the extensive self-analysis performed by CPAL during the summer of 1982, which resulted in heavy licensing activities during the remainder of Considering the number of audits, the level of outage work and the '982.

several hundred pre-startup items which were processed during that period, we believe that this area was handled satisfactorily.

Based on the above, the rating of Category 3 seems inappropriate, and CPAL believes this rating should be changed to Category 2.

10. Qualit Assurance Pro ram (NRC rating: Category 3)

Paragraph 10, Board Comments, cites "failure to identify deficiencies in operational programs and failure to take effective corrective action" as the reason for a Category 3 rating. However, during this SALP report period, the Corporate Quality Assurance Department strengthened and improved the Performance Evaluation Unit. Additional Quality Assurance Specialists were added, and the frequency and scope of audits at the plants were increased. Increased attention was also given to obtaining corrective action to audit findings. The status of all open items from previous audits was reviewed during each audit and the status of these items is identified in each audit report. The escalation process was added to the audit procedure and this has resulted in increased management involvement in obtaining corrective action.

Also, the BSEP Operations QA staff technical capability was increased by the addition of QA Engineers as recommended by the QA program assessment that was performed by an outside consultant.

In summary, CPKL believes that corrective actions have been implemented to improve performance in this area.

C (SALP-C)