ML20092A085
| ML20092A085 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/14/1984 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20092A067 | List: |
| References | |
| FOIA-84-327 NUDOCS 8406190008 | |
| Download: ML20092A085 (3) | |
Text
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PHILADELPHIA ELECTRIC COMPANY l
2301 M ARKET STREET P.O. BOX 8699 PHILADELPHIA. PA 19101 gif]Q t2is 841-4so2 JOHN S. MEMPER v4CE PRESIDENT seet.sms a mena aseo asse ansee Mr. Thomas E. Murley, Regional Administrator United States Nuclear Regulatory Comission Of fice of Inspection and Enforcement, Region I 631 Park Avenue King of Prussia, PA 19406
Subject:
US NRC IE Region I Letter, dated February 13, 1984 Systematic Assessment of Licensee Perf ormance (SALP)
File: GOVT 1-1 (1983 SALP)
Dear Mr. }brley:
As a result of our meeting in the Limerick Training Center cn 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 cod 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 1mprovement 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 even though our Design and Construction activities have improved, there is still room for improvement. We will continue to strive f or excellence, and I can assure you that this is PECO Management's conmitment.
In the Engineering Area, 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 each item considers possible generic implications. For instance, the review of the first item, concerning the adequacy of the seismic flex leg in an instrument installaton, included reviewing the other disciplines, electrical,
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piping, civil, etc. for similar problems, and none 'were f ound. This l-fact, together with the recent resolution of item A3, by further Engineering i
explanations rather than re-analysis or rework, gives us a further-
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l degree of confidence.that the project does not have a potential weakness in the engineering area.
8406190000 840524 PDR FOIA WARNER 84-327
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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 overall 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.
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 f uel loading, we have already taken action in this area. We will continue to monitor this area carefully to support a proper and coordinated ef fort to complete the testing and assure plant readiness f or operation.
In our initial test efforts in mid 1983, the Reactor Pressure Vessel hydro test and the plant integrated system flush were accomplished on an accelerated schedule.
Considering these early successes, the overall schedula 'ans advanced late in 1983.
The analysis of the overall progress on 6nm chedule 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 items, we would be pleased to discuss them with you.
An affidavit relating to this response is enclosed.
Sincerely, JMC/drd Enclosure Copy to:
Director of Inspection and Enforcement United States Nuclear Regulatory Commission Washington, DC 20555
,i 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 t
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 Limerick Cenerating Station Units I and 2; that he has read the foregoing Response to USNRC Region I Systematic Assessment of Licensee Performance for Limerick Generating Station dated February 13, 1984 and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.
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y-Subscribed and sworn to before me this /
day hdA/Al If N' of 8
PATutc:A D. SCHott' Notary PubLc. P.Y:a'elphia. Pld.'sdciphie Ces g
My Usinnnaslun En;nr5s Isbruary 10,19tG
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