ML20084L858
| ML20084L858 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/19/1984 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Murley J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20084L808 | List: |
| References | |
| NUDOCS 8405150079 | |
| Download: ML20084L858 (3) | |
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9, ENCLOSURE 4 PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 MAR 141984 JOHN SmMEMPER VICE-PR ESID ENT g sessssstesses Asso massancee
. Mr. Thomas E. Murley, Regional Administrator United States Nuclear Regulatory Comission Office of Inspection and Enforcement, Region 1 631 Park Avenue King of Prussia, PA 19406 Subj ect: US NRC IE Region I Letter, dated February 13, 1984 Systematic Assessment of Licensee Performance (SALP)
File: GOVT 1-1 (1983 SALP)
Dear Mr. Murley:
As a result of our meeting in the Limerick Training Center on February 24, 1984, and our review of the subject report, we offer the following comments:
We believe that the meeting between key NRC representatives and Philadelphia Electric Co. management was beneficial and improved the mutual understanding of our project and the NRC evaluation of it.
We have reviewed the 1983 NRC SALP Report and are very pleased with the assessment of the Design and Construction activities. For several years we have made it a practice to review the SALP Report in detail and to devise what we called a "SALP Improvement Program". We think these programs have been extremely beneficial to the Project, and judging by the improvement in our SALP ratings in the last two years, the NRC also finds that our effort has been effective.
We plan to take a similar approach this year. We recognize that j.
even though our Design and Ccn C a t: an activities have improved, there l
is still room for improvemenJ.
1 w! 1 continue to strive for excellence, and I can assure you tha' U1-o PEC) Management's comitment.
In the Engineering h ea, all of the NRC concerns have been addressed, and we agree with the NRC observation that the identified problems appear to be isolated instances. Our review of asch item considcrs possible generic implications. For instance, t'e revicw of the first item, concerning the adequacy of the seismic flex leg in an instrument l
insta11aton, included reviewing the other discip1hes, electrical, piping, civil, etc. for similar problems, and none t-re found. This fact, together with the recent resolution of item A3, by further Engineering explanations rather than re-analysis or rework, gives us a further degree of confidence that the project does not have a potential weakness in the engineering area.
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s However, in sharing your concern, we propose to again review the problems and our responses to be certain that we have addressed the root causes and that these problems taken together do not constitute a weakness in-the overa11 Engineering ef fort.
In the Design Change Control area, in view of the recurrent nature of some of the problems, we concur with your concern. Accordingly, we will institute a review of the Design Change Procedures currently in use by the Project with the goal of simplifying and consolidating the procedures in order to minimize the potential for recurring problems of the type previously experienced.
I Regarding the need for increased management attention in the area of supporting the preoperational ef fort and providing a coordinated approach to plant staff readiness f or fuel loading, we have already taken action in this area. We will continue to moniter this area carefully to support a proper and coordinated ef fort to complete the testing and assure plant readiness for operation.
In our initial test efforts in mid 1983, the Reactor Pressure Vessel hydro test and the plant integrated Considering system flush were accomplished on an accelerated schedule.
these early successes, the overall schedule was advanced late in 1983.
The analysis of the overall progress on the schedule at the end of 1983 revealed that an adjustment was required. Recently, the tentative advanced fuel load date of May,1984 was re-forecast to July,1984. In addition, to support this effort schedulers and planners have been added to develop detailed and sequenced schedules to ensure that proper support is provided when and where required to meet the revised schedule.
Should you have any questions concerning these itens, we would be pleased to discuss them with you.
An affidavit relating to this response is enclosed.
Sincerely, J)C/drd Enclosure Copy to: Director of Inspection and Enforcement United States Nuclear Regulatory Commission -
Washington, DC 20555 S. K. Chaudhary, US NRC Resident Inspector J. Wiggins, US NRC Resident Inspector l-
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COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF PHILADELPHIA JOHN S. KEMPER, being first duly sworn, deposes and says:
That he is Vice President of Philadelphia Electric Company, the holder of Construction Permits CPPR-106 and CPPR-107 for Liraerick Generating Station Units 1 and 2; that he has read the foregoing Response to USNRC Region I Systematic Assessment of Licensee Performance for Limerick Gen'erating Station dated February 13, 1984 and knows t.he contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.
M A r
4 Subscribed and sworn to before me this /
day hAA.tAl If N' of 8
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PATRICIA D. SCHOLE Notary Pold:c, Phdadelphia. Philadelphla CN Aly Commission Empires February 10.194 e