ML20129C858
| ML20129C858 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, Limerick, 05000000 |
| Issue date: | 06/26/1985 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Thompson H Office of Nuclear Reactor Regulation |
| References | |
| GL-85-07, GL-85-7, NUDOCS 8507160352 | |
| Download: ML20129C858 (6) | |
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PHILADELPHIA ELECTRIC COMPANY 23O1 M ARKET STREET P.O. BOX 8699 PHILADELPHI A, PA.19101 12151841-4502 VIC E+R ESID E N T
...........o......c" June 26, 198S Mr. Hugh L. Thompson, Jr., Director Division of Licensing Office of 1.uclear Reactor Regulation j
NRC, Washington, DC
Subject:
Philadelphia Electric Company Position on Generic Letter 85-07 Peach Bottom Atanic Power Station (50-277 & 50-278) and Limerick Generating Station (50-352 S 50-353)
Dear Mr. Thompson:
Attached to this letter is our response to Generic Letter 85-07 in the format requested.
In addition, we would like to ampilfy our response.
Philadelphia Electric Company is conmitted to a major corporate organizational change that will enhance our existing systems and methodology for manag hg the modification work at our nuclear generating facilities. As we select personnel, and establish the organization, to implement this change, we intend to make integrated scheduling a key element.
We feel that this is the appropriate time to initiate such a change since most of the major industry concerns, i.e., ATWS, Fire Protection, Mark I, Mark II, have been incorporated into both Peach Bottom and Limerick. We now expect to have a few years without the press of major regulatory backfit requirements to establish our improved organization.
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B507160352 850626 PDR ADOCK 05000277 p
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As.noted 'in your' Enclosure 2, we plan to schedule the selection of our methodology in Septenber of 1986 with a schedule for submittal to the NRC in Decenber of 1986. The effort required to bring Limerick Unit 1 to Cornnercial Operation and the completion of major modifications at Peach Bottom have seriously impaired our efforts to make organization changes and develop the integrated
. schedule concept. However, we support the concept and look forward to working with your staff in its implementation.
Very truly yours,
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DBF/mtk/05298503
ENCLOSURE 2 RESPONSE FORMAT - GENERIC LETTER 85-07 PLANT NAM:
Peach Bottcm Atomic Power Station Units 2 & 3 UTILITY:
Philadelphia Electric Cmpany I.
INTENTIONS A.
Intend to work with the staff to develop an X
ILS B.
Have reservations that nust be resolved before developing ILS C.
Do not presently intend to negotiate an ILS with the staff D.
Plan to implement an informal ILS only II.
STATUS A.
If you answered I.A above:
1.
Have you settled on a method for prioritizing the work at your plant (s)?
Circle One:
Yes If yes, select best description:
Engineering Judgement Analytic Hierarchy process Risk based analysis Cost-benefit analysis Other (please describe)
If no, provide estimated date for selecting a methodology
- Date or If not presently available provide estimated date for scheduling the selection of a methodology:
Sept. 1986 2.
What is your estimated date for making a submittal to the NRC -
of If not presently available, planned date for scheduling a submittal to the NRC Dec. 1986
B.
If you answered I.B above:
1.
Please explain your reservations on separate sheet (s) or provide your schedule for supplying an explanation See separate sheet (s):
or Separate submittal scheduled for (Date) 2.
If available to meet with the staff to discuss your concerns, propose a time frame for such a meeting and provide a contact that can make arrangements Contact / Time Frame Phone Nurber C.
If you answered I.C 1.
Would you be willing to meet with the staff to discuss the development of an ILS for your facility (s)?
Circle One:
Yes No If yes, propose a time frame for such a meeting and provide a contact that can made arrangements.
Contact Time Frame Phone Nutber If no, any constructive comnents you have would be appreciated.
III. ADDITIONAL ITEMS Please make any suggestions you may have as to how a utility
' sponsored availability / reliability project might be credited for plant safety enhancement. Provide additional constructive comnents as appropriate.
DBF/mtk/05298504
ENCLOSURE 2 RESPONSE FORMAT - GENERIC LETTER 85-07 PLANT NAME:
Limerick Generating Station, Units 1 & 2 UTILITY:
Philadelphia Electric Conpany I.
INTENTIONS A.
-Intend to work with the staff to develop an X
ILS B.
Have reservations that must be resolved before developing ILS C.
Do not presently Intend to negotiate an ILS with the staff D.
Plan to inplement an informal ILS only II.
STATUS A.
If you answered I.A above:
1.
Have you settled on a method for prioritizing the work at your plant (s)?
h Circle One:
Yes If yes, select best description:
Engineering Judgement Analytic Hierarchy process Risk based analysis Cost-benefit analysis Other (please describe)
If no, provide estimated date for selecting a methodology:
Date or If not presently available provide estimated date for scheduling the selection of a methodology:
Sept. 1986 2.
What is your estimated date for making a submittal to the NRC -
or If not presently available, planned date for scheduling a se:311ttal to the NRC Dec. 1986 i
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r B.
If you answered I.B above:
1.
Please explain your reservations on separate sheet (s) or provide your schedule for supplying an-explanation See separate sheet (s):
or Separate submittal scheduled for (Date) 2.
If available to meet with the staff to discuss your concerns, propose a time frame for such a meeting and provide a contact that can make arrangements Contact / Time Frame Phone Nurber C.
If you answered I.C 1.
Would you be willing to meet with the staff to discuss the development of an ILS for your facility (s)?
Circle One:
Yes No If yes,_ propose a time frame for such a meeting and provide a contact that can made arrangements.
Contact Time Frame Phone NuTber If no, any constructive conments you have would be appreciated.
III. ADDITIONAL ITEMS Please make any suggestions you may have as to how a utility sponsored availability / reliability project might be credited for plant safety enhancement. Provide additional constructive conments as appropriate.
DBF/mtk/05298505