ML20117K089
| ML20117K089 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/08/1985 |
| From: | Cooney M PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| CON-#285-053, CON-#285-53 OL, NUDOCS 8505150310 | |
| Download: ML20117K089 (6) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 (zt 5) e415020 M. J. COONE Y GLECTR CPRODU ON DE ANYMEfeT May 8, 1985 Docket No. 50-352 Inspection Report No. 50-352/85-03 Mr. Richard W. Starostecki Division of' Project & Resident Programs U.S. Nuclear Regulatory Corrission Region I 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Starostecki:
Your letter dated April-2, 1985 forwarded Inspection Report 50-352/85-03.
Appendix C of your letter addresses several items which are characterized as weaknesses related to the
. effectiveness of the licensee's programs, activities, or organizations.
These items are restated below along with our respense.
Procran Weaknesses
~
A.
Plant Operational Feview Committee (POPC) Subcommittees are permitted to review certain procedures without subsequent full PORC review of the results of the detailed review.
Renpenser Adrinistrative Procedure A-4,
" Plant Operations Review Committee Procedure" has been revised to describe the mechanisns associated with PORC review of Subcommittee activities.
This revision modi fled the PORC Approval Form to provide for a specific individual ascociated with the subcommittee activity to be assigned the responsibility of reporting to PORC.
This mechanism provides for PORC discussion of subcomnittee activities 8505150310 850508 5
PDR ADOCK 05000352
- c' G
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- Mr. Richard W.
Starostecki May 8, 1985 Page 2 and will assure that PORC is fully cognizant of these subccmmittec activities.
B.
Access to the control rcom is not effcchively controlled.
Response
As a result of control room access concerns, the following actions have been taken:
(1) access to the control room has been restricted via the security computer to individuals with specific needs and through the use of the east door only, (2) the control room floor was marked to specify activity / traffic arcas, and stanchions with ropes were provided, (3) signs are utilized to notify personnel when shift turnover meetings are in progress, and (4) the authority and responsibility of Shift Supervision to order the departure of unnecessary personnel from the Control Rocm was re-emphasized.
C.
The Terporary Procedure Change Process is cumbersone and prone to errors as indicated by changes missing from surveillance procedures and valve checkoff lists.
Response
Based on a review of the errors describcd in the inspection report, it is felt that the errors did not However, as a identify a significant safety concern.
result of the expressed concern, plant personnel will be cognizant of TPC process probicmo and will initiate appropriate changes, if necessary, to provide for enhanced, less cumbersome controls.
there is no formal docurented review of In many cases, D.
completed surveillance test data by the responsibic departrient supervision.
In addition, there have been excessive time delays in processing some chemistry surveillance data.
/
t.
+
-.-a
- Mr. Richard W. Starostecki May 8, 1985 Page 3
' Response:
The intent of the review of test results as'specified in Administrative Procedure A-43 is to document the review-of test results by individuals directly concerned with the'results of the test,-e.g.,
the Shift Technical Advisor or_ Shift Supervision.
This mechanism assures
-that shift personnel are-fully aware of the status of plant-equipment.
Although no-formalized documented review is required by A-43, the majority of test results
^ are reviewed by group supervisors. responsible for the test or~their' designated alternates _to assist in identifying problem areas.
Recent review of the status of. chemistry test results
- determined that the= backlog of data awaiting supervisor review has been substantially reduced.
This backlog was the result of an administrative restraint which required that test results data.be entered into the computer system prior to ST sign-off.
These controls will be modified:to provide for documentation of the review of test results in an expeditious manner.
Completion of training of chemistry personnel in computer data entry is required to completely eliminate the ST backlog.
This training is scheduled for completion by July 1, 1985.
E.
The maintenance program does not provide summary data for management overview of work-backlog, preventive raintenance prcgram completion status, or trends.
Unseense:
Periodic issuance of a Maintenance Management Report to station management has been initiated.
This report provides managerent with maintenance. status, trends, work backlogs, and priority of corrective and preventative maintenance requests in order to evaluate program effectiveness.
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L.
Nr'.
Richard W. Starostecki May 8, 1985 Page 4 F.
Environmental Qualification Peports and corresponding revisions are poorly controlled.
Resnonse PECo Engineering and Pesearch Department organizations have issued procedures for the control of Environmental Oualificatien Reports (EOPs) for mechanical equipment and electrical equipment.
These procedures require the specific organization to (1) maintain registers of EOR holders and (2) issue revisions to the EOR to registered holders.
A controlled copy of mechanical and electrical EOR's is available on site.
G.
The Valve Checkoff List for the Automatic Depressurization System was not completed prior to initial unit startup.
Rerponse Plant procedure GP-2 (Normal Plant Startup) has been revised (Rev. 4 dated 2/14/85) to address the performance of the Check Off List for the Autoratic Depressurization System as a prerequisite for plant startup.
II.
More than three hours were required for the inspection team to obtain uneecorted access to the facility rather than the one hour requested by NPC Region I.
Peeponse:
Steps are being taken to provide for more expediticun access processing of NRC personnel.
These steps include the issuance of n security instruction addressing security aspects of site entry (issued 4/17/85).
This guidance, in conjunction with the development of a new abbreviated site specific training program for NPC personnel, should permit granting unescorted access to the plant within the one-hcur period requested by the NFC.
i u
V
- Mr. Richard W. Starostecki May 8, 1985 Page 5 Should you have any questions or require further infornation, please do not hesitate to contact us.
Very truly yours, I
cc:
Dr. T.
E.
Murley, Administrator, Region I Mr. J. T.
Wiagins, Resident Site Inspector See Attached Service List
6 cc:
Judge Helen F.
Hoyt Judge Jerry Harbour Judge Richard F. Cole Troy B.
Conner, J r., Esq.
Ann P. Hodgdon, Esq.
Mr. Frank R.
Romano Mr. Robert L. Anthony Ms. Phyllis Zitner Charles W. Elliott, Esq.
Zori G. Ferkin, Esq.
Mr. Thomas Gerupky Director, Penna. Emergency Management Agency Angus Love, Esq.
David Wersan, Esq.
Robert J. Sugarman, Esq.
Martha W. Bush, Esq.
Spence U. Perry, Esq.
Jay M. Gutierrez, Esq.
Atomic Safety & Licensing Appeal Board Atomic Safety & Licensing Board Panel Docket & Service Section (3 Copies)
James Higgins Timothy R. S. Campbell January 16, 1985