ML20084K887
| ML20084K887 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 03/27/1984 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20084K858 | List: |
| References | |
| NUDOCS 8405140234 | |
| Download: ML20084K887 (4) | |
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b ENCLOSURE 4 PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 SHIELDS L. D ALT 7 TOFF
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March 27, 1984 Docket Nos. 50-277 50-278 Mr. Richard W. Starostecki, Director Division of Project and Resident Programs U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406
SUBJECT:
1984 Systematic Assessment of Licensee Performance (SALP) for Peach Bottom Atomic Power Station
REFERENCE:
Letter, R. W. Starostecki, to S. L. Daltroff, PECo., dated February 23, 1984 (Systematic Assessment of Licensee. Performance (SALP))
Dear Mr. Starostecki:
The above referenced letter of February 23, 1984 forwarded your Systematic Assessment of Licensee Performance (SALP) of our Peach Bottom Atomic Power Station (PBAPS) facility for the review period March 1, 1983 through December 31, 1983.
On March 2, 1984, a joint meeting of the NRC Region I SALP Board and Philadelphia Electric Company management and support staff was held at the Peach Bottom Unit 1 Conference Center to discuss the findings of your SALP report.
Philadelphia Electric Company appreciates the opportunity to have met with you to discuss our performance and to comment on your report findings.
As a result of our meeting of March 2, 1984 and our review of the above referenced report, Philadelphia Electric Company offers the following comments.
As we discussed at the meeting, we are pleased with the improvement shown during the period of study and we will continue to strive for performance improvements.
We are especially 8405140234 840507 PDR ADOCK 05000277
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Mr. Richard W. Starostecki Page 2 pleased with the NRC acknowledgement that Philadelphia Electric Company has demonstrated a noticeable improvement in Radiological Controls, Surveillance, and Fire Protection and Housekeeping.
Since the last SALP report, we have intensified our efforts in each of these functional areas.
In the Plant Operations area, Philadelphia Electric Company is establishing a more active and stronger presence in monitoring activity inside and outside the control room.
This has been initiated by assigning a supervisor to the control room proper on a continuous basis and by creating a position of
'outside shift supervisor', which is presently staffed for 10 shifts a week.
This position may be broadened to encompass 21 shifts per week when personnel become available.
In response to your SALP comment concerning compliance with ANSI N45.2.9-1974, " Requirements of Collection, Storage and Maintenance of Quality Assurance Records fer Nuclear Power Plants", Philadelphia Electric Company will improve performance in this area.
During 1933, an assistant technician was acquired to log in data to reduce the backload of Radiation Work Permit (RWP) documents.
Two clerks will be retained to maintain a steady flow of RWP documents to the Document Administration Center (DAC) during the scheduled Unit 2 pipe replacement project.
In addition, all senior staff engineers at Peach Bottom have been requested to submit all the required documents and records to the DAC on a steady flow basis.
In the Radiological Controls functional area, Philadelphia Electric Company is pleased with the improved rating, but is striving to build upon this improvement.
Of particular emphasis is the ALARA program.
As part of the ALARA effort, Philadelphia Electric Company has hired a contractor to perform the ALARA program for the upcoming Unit 2 recirculation piping replacement project.
The contractor will be utilizing a computer and its associated software program to generate timely reviews and tracking of the ALARA portion of the pipe replacement project.
During this project, Philadelphia Electric Company will be evaluating the utilization of this tracking mechanism to support ALARA tracking activities for the entire plant on a permanent basis.
Philadelphia Electric Company hue changed its procedural authority regarding the changing of Radiation Work Permit (RWP) requirements.
Senior health physics technicians had previously been instructed before receipt by Philadelphia Electric Company of the 1984 SALP report that verbal changes to RWP's can no longer be accepted.
Minor changes to the RWP will be written on the posted RWP and significant changes will result in rewriting of~the RWP.
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Mr. Richard W. Starostecki Page 3 Philadelphia Electric Company is pleased that the NRC has recognized and acknowledged management involvement with respect to the large diameter pipe weld IGSCC problem.
In response to your comments regarding tracking and coordination of more routine items, Philadelphia Electric will be striving to improve the documentation and correction of minor equipment deficiencies.
As evidenced by our pipe weld IGSCC effort, we will continue to place priorities on equipment associated with the safety-related systems of the plant, but will attempt to improve our efforts in documenting, tracking and correcting or repairing the smaller equipment deficiencies.
In regard to surveillance, Philadelphia Electric Company agrees with the NRC and will strive to improve management, supervisory and QC attention to detail review and evaluation of test data and identification and correction of deficiencies in the approved procedures.
As we discussed at the joint meeting of March 2, 1984, Philadelphia Electric Company acknowledges that not all fire brigade members at Peach Bottom received training at our fire training school and some did not attend shift fire brigade meetings.
The Philadelphia Electric Company fire school trains all PECo personnel, and openinqd were not always available for Peach Bottom personnel.
As r result, we have placed a high priority on site fire brigefa training at the training school.
In addition, a high priority has been placed on attendance at shift fire brigade meetings.
The assignment of this high priority is expected to prevent recurrence.
A dedicated fire protection assistant has been employed.
This new position is expected to improve fire protection program coordination.
In addition, the Peach Bottom Atomic Power Station visual inspection of fire barriers site procedure is in the process of being revised to incorporate improved surveillance and inspection requirements.
In response to the NRC evaluation of our Peach Bottom Atomic Power Station Emergency Drill Exercise of June 28, 1983, Philadelphia Electric Company management will take a more active role in reviewing the lesson plans and incorporate the lessons learned from previous exercises into Emergency Planning.
Regarding activities related to Refueling and Outage work, specifically controlling jumpers on the control rod position indicators, Philadelphia Electric Company has strengthened the administrative control of jumpers by requiring a PORC-apprc ed written procedure before installation of specific jumpers.
A generic procedure for control of jumpers is presently in the review process.
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Mr. Richard W. Starostecki Page 4 In addition, Philadelphia Electric Company agrees with the NRC that additional overview of contractor work appears necessary, especially in the auditing of contracted services.
In late 1983, deficiencies in control of vendor activities were recognized, and a supervising engineer was added to the maintenance organization at Peach Bottom specifically to address this concern.
A separate Quality Control group has been formed within the Electric Production Quality Assurance Division.
This Quality Control group will independently perform QC functions previcusly carried out within the maintenance organization and will provide better control of contractor activities, since they will be inspecting jobs and tasks at " hold points" as well as at completion.
These actions should significantly improve our performance in this area.
Philadelphia Electric Company wishes to thank the NRC again for the opportunity to have met with you to discuss your evaluation of our performance with respect to the operation of Peach Bottom Atomic Power Station.
'u Should you have any question or wish to discuss further any part of our response, please do not hesitate to contact us.
Very truly yours, f
<.c a f cc: A. R. Blough, site Inspector 6
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