IR 05000352/1988001

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-352/88-01

ML20153D902
Person / Time
Site:	Limerick
Issue date:	04/29/1988
From:	Bellamy R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Corbin McNeil PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
NUDOCS 8805090318
Download: ML20153D902 (2)

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, APR 2 91988 Docket No. 50-352 Philadelphia Electric Company ATTN: Mr. C. A. McNeill Executive Vice President Nuclear

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2301 Market Street Philadelphia, Pennsylvania 19101 Gentlemen:

Subject: Inspection No. 50-352/88 01 This refers to your letter dated April 4,1988, in response to our letter dated March 4,1988.

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Thank you for informing us of the corrective and preventive actions documented

{ in your. letter. These actions will be examined during a future inspection of your licensed program.

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Your cooperation with us is appreciated, i

Sincerely,

Original Signed By:

Walter J. Pasciak i

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Ronald R. Bellamy, Chief Facilities Radiological- Safety and Safeguards Branch Division of Radiation Safety and Safeguards cc:

L John S. Kemper, Sr., Senior Vice President - Nuclear

, E. C. Kistner, Chairman, Nuclear Review Board i

Graham M. Leitch, Vice President, Limerick Generating Station

, J. W. Gallagher, Vice President - Nuclear

{ Troy B. Conner, Jr. , Esquire

, Eugene J. Bradley, Esquire, Assistant General Counsel

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W. M. Alden, Director, licensing Section Public Document Room (POR)

, Local Public Document Room (LPOR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector Commonwealth of Pennsylvania I

0FFICIAL RECORD COPY RL LIM 1 88-01 - 0001.0.0 \

04/18/88  ;

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8805090318 880429

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Public Service Electric and APR 2 91988

. Gas Company 2 bec:

Region I Docket Room (with concurrences)

Management Assistant, DRMA (w/o encl)

Section Chief, DRP Robert J. Bores, DRSS CW RI:DRSS -

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Gordon/gcb Lazarus ellkmy 4/J} /88 4M /88 4/71/88 0FFICIAL RECORD COPY RL LIM 1 88-01 - 0002.0.0 04/18/88

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- PHILADELPHIA ELECTRIC COM PANY 2301 MARKET STREET P O. BOX 8699 PHIL ADELPHl.A, PA 19101 1:15) 841 5001 April 4, 1988 JOSEPH W. G ALLAGHCR

Docket No.. 50-352

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Mr. Ronald R. Bellamy, Chief Facilities Radiological Safety and Safeguards Branch U.S. Nuclear Regulatory Commission Region I Attn: Document Control Desk Washington, DC 20555 Subject: Limerick Generating Station Inspection Report No. 50-352/88-01

Dear Mr. Bellamy:

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Your letter dated March 4, 1988 forwarded Inspection Report 50-352/88-01 for Limerick Generating Station. Appendix A of your letter addressed two items which do not appear to be in full These compliance with Nuclear Regulatory Commission requirements.

items are restated below followed by our responses.

i Violation 1:

I 10 CFR 50.54(t) requires an annual review of the emergency preparedness program and that the results of the review, along with recommendations for improvements, be documented and reported to the licensee's corporate and plant management.

Contrary to the above, the licensee did not report the results of a J review of the emergency preparedness program to appropriate corporate and plant management for the 1986 audit, nor were proposed l

recommendations for improvement developed for the identified deficiencies.

Severity Level IV Violation ,

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! Resoonse:

l Admission of Alleged Violation:

Philadelphia Electric Company acknowledges the violation.

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Mr. Ronald R. Bellamy, Chief April 4, 1988 Page 2 Reason for the Violation:

The reason for the inadequate distribution and resolution of the 1986 10 CFR 50.54(t) review findings is that no clear procedural definition of responsibility for generation and distribution of the review and development of appropriate corrective actions existed at the time. The Emergency Preparedness Section had contracted Enercon Services to perform the required independent 10 CFR 50.54(t) review. It was recognized that Emergency Preparedness could not issue the report because they lacked the required independence. This situation was not immediately resolved and subsequently the distribution was not completed.

Sionificance of Violation:

The results of the 1986 50.54(t) review did not identify any significant conditions adverse to the quality of the Emergency Preparedness Program. The review stated, "The Review Team determined, based on this information, facilities and equipment reviewed and the individuals interviewed, that the LGS Emergency Preparedness Program is currently in generally acceptable order and in a state of preparedness to respond effectively to an emergency."

Corrective Actions Taken and Results Achieved:

The Emergency Preparedness Section has re-evaluated the 1986 10 CFR 50.54(t) review results and distributed the open items to appropriate levels of management for resolution. Action plans have been developed for the tracking and closure of the items.

Corrective Actions Taken to Avoid Future Non-Compliance:

The Nuclear Quality Assurance organization has been assigned the responsibility for the performance of future 10 CFR 50.54(t)

reviews and their distribution. The review will be distributed as an attachment to the OA Audits. The findings and associated corrective actions and recommendations will be dispositioned and tracked in accordance with Emergency Preparedness Section procedures as discussed in response to Violation 2 below.

Date When Full Comoliance Will Be Achieved:

The re-evaluation of the 1986 10 CFR 50.54(t) review results was completed in January 1988 and individual items were entered into the Emergency Preparedness Action Item Tracking System.

- ~ ~ Completion dates for resolution of all those items were L.i; u fEestablished as of March 31, 1988.

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April 4, 1988 Mr. Ronald R. Bellamy, Cnief Page-3 Violation 2:

10 CFR 50, Appendix B, Part XVI requires that measures be established to assure that conditions adverse to quality, such as deficiencies, E are promptly identified and corrected. r Contrary to the above, audits performed in 1986 and 1987 revealed that f there were several deficiencies in the emergency preparedness program

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which had been identified during previous audits that were either !

recurrent or had nct been adequately addressed. .

Severity Level IV Violation

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Response:

Admission of Alleoed Violation:  ;

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Philadelphia Electric Company acknowledges the violation.

Reason for the Violation: ,

The reason for the violation was the lack of an overall effective program to ensure adequate responses to identified findings and Action Items, track emergency preparedness commitment due dates, ;

and notify appropriate levels of management if commitments became past due.

Sionificance of Violation:

Correction of the deficiencies identified as recurrent or not {

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adequately addressed would have enhanced the emergency response program; however, the deficiencies did not adversely affect the '

f ability of the emergency preparedness program to respond to nuclear accidents as demonstrated in recent emergency drills and the annual emergency preparedness audits.

Corrective Actions Tak,en and Results Achieved:

The existing Emergency Preparedness Action Items Tracking System has been improved to generate periodic status reports (currently biweekly) which present summaries of scheduled Action Item completion dates to senior management and the individual I responsible group management.

Corrective Actions Taken to Avoid Future Non-Comoliance:

Emergency Preparedness established a project team in February, 1988 with two goals: 1) close out, or develop action plans to ;

close out existing emergency preparedness related open items l

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M:. Ronald R. Bellamy, Chief April 4, 1988 Page 4

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ir,cluding Nuclear Quality Assurance aucit fincings for Limerick, Peach Bottom, and Corporate; and 2) develop a long term program

"Emergency Preparedness Actior Items" to identify, resolve, and close out Action Items, including programs to manage data, track items to completion, and report status to appropriate levels of management.

Date When Full Compliance Will Be Achieved:

The Emergency Preparedness Action Items Tracking System is currently in place and revision of the controlling procedures will be completed by June, 1988.

If you have any questions or require additional information, please do not hesitate to contact us.

Very truly yours, R W14 d&

cc: Addressee W. T. Russell, Administrator, Region I, US!!RC T. J. Kenny, Senior Resident inspector

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