ML20086D580
| ML20086D580 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 11/20/1991 |
| From: | Miller D PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9111260160 | |
| Download: ML20086D580 (5) | |
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CCN 91-14197 PillLADELPIIIA ELECTRIC COMPANY
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PLACil BOTRBI AIO%llt POWER STATION R D.1.1%4208 N%i Delta, Itnmyh7nia 173a4 m www rm you ta or a scuttNcs Fl7)i 0 7014 D. B. Miller, R.
Vice Preshient November 20, 1991 Docket Nos. 50-277 50-278 U. S. Nuclear Regulatory Comission ATTN: Document Control Desk Wathington, DC 20555 E
SUBJECT:
Pearn Bottom Atomic Power Station - Units 2 & 3 Response to Combined Inspection Report 91-23/23 Concerning Surveillance Testing Activities
Dear Sir:
In the cover letter for the subject Inspection Report, you requested a response concerning our actions taken or planned to enhance our surveillance testing program as well as to address the unresolved item identified in,your report. Attached is our response. We are continutng to make progress in this area as indic.C 3d by the recent decrease in missed surveillance LERs.
If you have any questions or require additional information, please do not hesitate to contact us.
Sincerely,
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R. A. Burricelli, Public Service Electric & Cas
- 1. M. Gerusky, Comonwealth of Pennsylvania J. J. Lyash, USNRC Senior Resident Inspector T. T. Martin, Administrator, Region 1. USNRC
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H. C. Schwem, Atlantic Electric R. I. fdcLean, State of Maryland J. Urban, Delmarva Poner Y.h1 auruu -u m cm ww w. am PDfi
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I Document Control Desk Page 2 bec: J. W. Austin A4-4N, Peach Bottom J. A. Basilio 52A-5, Chesterbrook G. J. Beck 52A-5, Chesterbrook J. A. Btrnsteir 51A-13, Chesterbrook R. N. Charles 51A-1 Chesterbrook Commitment. -Jinator 5?A-5, Chesterbrook Correspondence Control Program 618-3, Chesterbrook J. B. Cotton 53A-1, Chesterbrook G. V. Cranston 638-5, Chesterbrook E. J. Culien S23-1, Main Office A. D. Dycus A3-IS, Pr ech Bottom A. A. r lvio A4-1S, Peach Bottom u
D. R. Helwie 51A-11, Chesterbrook' R. J. Lees NRB 53A-1, Cher+.erbrook C. J. McDermott 513-1, Main Office D. B. Miller, Jr.
SMO-1. Peach Bottom PB Nuclear Recoids A4-25, Peach Bottom K. P. Powers A4-15, Peach Bottom J. M. Pratt B-2-S, Peach Bottom J. i. Robb 51A-13. Chesterbrook D. M. Smith 52C-7, Chesterbrook
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Document Control Desk Page 3 I
RESPONSE 10 INSPECTION REPORT 91-9/23 Actions Taken or Planned to Enhance Surveillance Testing Program in June, 1991, a Surveillance Test Improvement Project (STIP) led by plant supervision developed immediate corrective actions to resoli, programmatic issues related to missed surveil'ance tests (51's). The foliowing is a listing of near term corrective actions with their current status.
Develop Performance Indicators, Complete including Management goals, for test completion on schedule and in grace.
2.
Refresher training for Cognizant Engineers Complete and Management on A-43 program requirements and the vision for the improved program.
3.
ReviseGP-2(plantstart-upprocedure)
Cornplete to amplify the controls on event tests and restarted periodic tests.
-4.
Revise the Operations Management Manual Complete to formalize expectations on restarting periodic tests after equipment inoperability.
5.
Clarify the scope ano consistency of 4th Quarter 1991 plant staff reviews of completed tests.
6.
Revise A-43 to incorporate various plant 4th Quarter 1991 corrective actions related to the ST program.
7.
Develop Performance indicator for tests 4th Quarter 1991 in the results review process.
8.
Revise the OMM to better define controls 4th Quarter loM for " aborting" tests.
The STIP has also identified longer term actions to resolve underlying concerns with the ST program. These longer term actions will be in place before the end of the 2nd quarter cf 1992.
- 1. Complete Plant Information Monitoring System (PlHS) Implementation PIMS ST Module implementation will provide a new computer scheduling system with improvements over the one currently in use, for example, it will schedule tests from their last performance date and have the flexibility to schedule to the appropriate Tech Spec frequency. A
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Document Control Desk Page it
~1ech Spec change consistent with industry and standard Tech Specs is required to implement this process in PIMS.
PIMS will also contain 1
OPCON codes for each test (not in use at Peach Bnttom currently), and allow integrated scheduling of daily work.
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Also, in implementing PIMS, new administratin controls will be introduced to control test scheduling, issuance, performance, results i
review, and storage.
- 2. Develop feedback Mechanisms Performance indicators, including management goals, will be established for various key steps in the ST prograin to allow monitoring program performance.
These will display program performance and allow declining trends to be recognized and corre-ted.
- 3. Situational Test Control Processes Developed and Implemented All Tech Spec required situational testing is being identified and captured with the test that-satisfies the Tech Spec requirements and the procedures that trigger the performance of situational tcsts.
This relationship will ne formalized in the procedures themselves and will be monitored in the procedure revision process.
The administrative controls to ensure situational testing is controlled are also being enhanced.
rion-Tech Spec testing is also being reviewed for potential situational requirements and will be I
controlled in a fashion similar to the lech Spec testing.
- 4. Develop Process Improvement Tools The development of various cross-references will aid control room and raaintenance planning personnel in verifying the proper post-maintenance testing is performed and equipment testing is performed prior to returning equipment to an operable status. Cross-references will also significantly enhance program effectiveness in post maintenance testing and LCO testing identification.
Actions Taken to Resolve NRC Open Item 91-23/23-01/01 Failure to establish goals and required resources to implement the licenseeTST grogram and improvements _in the program under PIMT~
The above discussed plans of the STIP including longer term issues involving PIMS have been sponsored and encouraged by line management.
Appropriate resources have been designated to develop this program.
Additional management review of this problem has been performed by the Nuclear Review Board which is an advisory committee to the Senior Vice-President-Nuclear and by the Nuclear Committee of the Board which is an advisory committee to the Board of Directors. We believe that this t
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Document Control Desk Page 5 program will aggressively lead us to world class performance in the area of surveillance testing.
The number of LERs written because of Technical Specification surveillance tnat continue to be missed Trending data of LERS associated with missed Tcch Spec surveillances indicate to us that the trend of missed surveillances has decreasrd in the last half of 1991. We are encouraged by this and expect that with the completion of our near and longer term actions with the ST program, this tr Md will continue. Management oversight of surveillances has been also strengthened.
Routinely, our daily plant leadership meeting looks at v veillances to minimize tests that enter their grace period.
It is earacted that this pre-emptive approach to surveillances will continue to t
help eliminate missed surveillances. The decrease in missed surveillance LERs is a result of improvement in the performance of routine surveillance
- testing, j
failure to implement Corrective Action in Response to problems in the area of completed ST reviews and Dispositions The commitment identified in the inspection report concernir.g developing guidance for operations personnel review of completed surveillance tests is in progress. This guidance will help ensure that timely and proper Tech Spec actions are taken on deficient surveillance test results.
A review of the Commitment Tracking Program was performed to determine if similar omissions existed concerning commitments conteined in cover letters of PECo responses to the NRC. No similar deficiencies were identified.
Rccer.t self-assessments and audits of the Commitment Tracking Program (CIP) have indicated that CTP is comprehensive and well controlled, peficiencies with the scheduling of STs defined es 7 or 31 day tests by i
1, chnical SpecificatEns e
As previously discussed as part of the STIP longer term action, ST scheduling is being transferred into a new computer tracking system, PlHS.
This will allow for more precise scheduling of 7 and 31 day tests.
in the interim, controls have been implemented to ensure these tests are treated as "7" and "31" day tests and not as " weekly" and " monthly" tests.
Appropriate involved groups have been informed of this.
No deficiencies have been noted since implementation of these controls.
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