ML20151B655
| ML20151B655 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 04/04/1988 |
| From: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Ronald Bellamy NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8804110096 | |
| Download: ML20151B655 (4) | |
Text
. - _ - _
s.
~
PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHI A, PA 19101 (2:5) e41 soon April 4, 1988 JOSEPH W. G ALL AGHER
-l2;;;'.i'::,"l..
Docket No. 50-352 Mr. Ronald R.
Bellamy, Chief Facilities Radiological Safety and Safeguards Branch U.S. Nuclear Regulatory Commission Region I Attn: Document Control Desk Washington, DC 20555
Subject:
Limerick Generating Station Inspection Report No. 50-352/88-01
Dear Mr. Bellamy:
Your letter dated March 4, 1988 forwarded Inspection Report 50-352/88-01 for Limerick Generating Station.
Appendix A of your letter addressed two items which do not appear to be in full compliance with Nuclear Regulatory Commission requirements.
These items are restated below followed by our responses.
Violation 1:
10 CPR 50.54(t) requires an annual review of the emergency preparedness program and that the results of the review, along with recommendations for improvements, be documented and reported to the licensee's corporate and plant management.
Contrary to the above, the licensee did not report the results of a review of the emergency preparedness program to appropriate corporate and plant management for the 1986 audit, nor were proposed recommendations for improvement developed for the identified deficiencies.
Severity Level IV Violation
Response
Admission of Alleged Violation:
cj]E {
Philadelphia Electric Company acknowledges the violation.
l
\\T 8804110096 880404 PDR ADOCK 05000352 G
cco
s Mt. Ronald R. Bellamy, Chief April 4, 1988 Page 2 Reason for the Violation:
The reason for the inadequate distribution and resolution of the 1986 10 CFR 50.54(t) review findings is that no clear procedural definition of responsibility for generation and distribution of the review and development of appropriate corrective actions existed at the time.
The Emergency Preparedness Section had contracted Enercon Services to perform the required independent 10 CFR 50.54(t) review.
It was recognized that Emergency Preparedness could not issue the report because they lacked the required independence.
This situation was not immediately resolved and subsequently the distribution was not completed.
Significance of Violation:
The results of the 1986 50.54(t) review did not identify any significant conditions adverse to the quality of the Emergency Preparedness Program.
The review stated, "The Review Team determined, based on this information, facilities and equipment reviewed and the individuals interviewed, that the LGS Emergency Preparedness Program is currently in generally acceptable order and in a state of preparedness to respond effectively to an emergency."
Corrective Actions Taken and Resulta Achieved:
The Emergency Preparedness Section has re-evaluated the 1986 10 CPR 50.54(t) review results and distributed the open items to appropriate levels of management for resolution.
hetion plans have been developed for the tracking a.nd closure of the items.
Corrective Actions Taken to Avoid Future Non-Compliance:
2 The Nuclear Quality Assurance organization has been assigned the responsibility for the performance of future 10 CFR 50.54(t) reviews and their distribution.
The review will be distributed as an attachment to the QA Audits.
The findings and associated corrective actions and recommendations will be dispositioned and tracked in accordance with Emergency Preparedness Section procedures as discussed in response to Violation 2 below.
Date When Full Compliance Will Be Achieved:
The re-evaluation of the 1986 10 CFR 50.54(t) review results was completed in January 1988 and individual items were entered into the Emergency Preparedness Action Item Tracking System.
Completion dates for resolution of all those items were established as of March 31, 1988.
r Mr. Ronald R. Bellamy, Chief April 4, 1988 Page 3 Violation 2:
10 CPR 50, Appendix B, Part XVI requires that measures be established to assure that conditions adverse to quality, such as deficiencies, are promptly identified and corrected.
Contrary to the above, audits performed in 1986 and 1987 revealed that there were several deficiencies in the emergency preparedness program which had been identified during previous audits that were either recurrent or had not been adequately addressed.
Severity Level IV Violation
Response
Admission of Alleged Violation:
Philadelphia Electric Company acknowledges the violation.
Reason for the Violation:
The reason for the violation was the lack of an overall effective program to ensure adequate responses to identified findings and Action Items, track emergency preparedness commitment due dates, and notify appropriate levels of management if commitments became past due.
Significance of Violation:
Correction of the deficiencies identified as recurrent or not adequately addressed would have enhanced the emergency response program; however, the deficiencies did not adversely affect the ability of the emergency preparedness program to respond to nuclear accidents as demonstrated in recent emergency drills and the annual emergency preparedness audits.
Corrective Actions Taken and Results Achieved:
The existing Emergency Preparedness Action Items Tracking System has been improved to generate periodic status reports (currently biweekly) which present summaries of scheduled Action Item completion dates to senior management and the individual responsible group management.
Corrective Actions Taken to Avoid Future Non-Compliance:
Emergency Preparedness established a project team in February, 1988 with two goals: 1) close out, or develop action plans to close out existing emergency preparedness related open items 3.
s Mr. Ronald R. Bellamy,-Chief April 4, 1988 Page 4 including Nuclear Quality Assurance audit findings for Limerick, Peach Bottom, and Corporate; and 2) develop a long term program "Emergency Preparedness Action Items" to identify, resolve, and close out Action Items, including programs to manage data, track items to completion, and report status to appropriate levels of management.
Date When Full Compliance Will Be Achieved:
The Emergency Preparedness Action Items Tracking System is currently in place and revision of the controlling procedures will be completed by June, 1988.
If you have any questions or require additional information, please do not hesitate to contact us.
Very truly yours, h8 A g
cc:
Addressee W.
T.
Russell, Administrator, Region I, USNRC T. J. Kenny, Senior Resident Inspector l