ML20195H109
| ML20195H109 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 06/17/1988 |
| From: | Fogarty E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Kane W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8806280219 | |
| Download: ML20195H109 (6) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHI A, PA 19101 (zis) sai sozo E. P. FOG ARTY NUCLEAR SUPPORT DlWISION June 17, 1988 Docket Nos. 50-277
'50-278 Mr. William F.
Kane, Director Division of Reactor Projects Region I U.S.
Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555
SUBJECT:
Peach Bottom Atomic Power Station Response to Combined Inspection Report No. 50-277/88-10; 50-278/88-10
Dear Mr. Kane:
This is in.esponse to your letter dated May 18, 1988 which transmitted Pecch Bottom Inspection Report No.
50-277/88-10; 50-278/88-10.
Appendix A of your letter described two items, identified as items A and B, which did not appear to be in compliance with NRC requirements.
Your letter stated that no response to item B was required because it was adequately addressed by LER 2-88-05.
The attachment to this letter provides a restatement of item A, and provides Philadelphia Electric Company's response to item A.
If you have any questions or require additional information, please do not hesitate to contact us.
i Very truly yours,
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Attachment cc:
Addressee W. T. Russell, Administrator, Region I, USNRC
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T.
P. Jonnson, USNRC Senior Resident Inspector T.
E. Magette, State of Maryland
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8806J'GO219 880617 PDR ADOCK 05000277 G
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B Attachment Page.1 of 5 Docket Nos. 50-277 50-278 RESTATEMENT OF VIOLATIONS A.
10 CPR 50.73 requires'the licensee to submit a Licensee Evant Report (LER) for specified events or conditions within 30 days after the. discovery ~of the described event or condition.
Contrary to the above, a reportable condition under 10 CFR 50.73(a)(2)(vi) regarding cable separation criteria was identified on November 10,-1987; however, the associated LER (number 2-87-32) was not submitted until March 7, 1988, which was greater than 30 days.
Contrary to the above, a reportable condition under 10 CPR 50.73(a)(2)(v) regarding diesel generator trips during a loss of off site power was identified on December 17, 1987; however, the associated LER (number 2-87-28) was not submitted until February 22, 1988, which was greater than 30 days.
This is a Severity Level IV violation (Supplement I) applicable to DPR-44 and 56.
RESPONSE
Admission or Denial of Alleged Violations:
Philadelphia Electric Company (PECo) acknowledges these violations as stated.
Reason for Violations:
Both LERs dealt with design deficiencies idencified by the PECo Nuclear Engineering Department.
The reasons for the late submittals common t.o both LERs are as follows:
1.
Ineffective managenent of the LER preparation process by the Nuclear Services Department Iicensing Section to assure that all milestones asso;iated with the drafting, review and approval of LERs are met.
2.
Failure to develop.n a timely manner the technical information needed to prepare the LER, or develop a realistic schedule for when the information would be available so that the LER draft (30-day aubmittal) could reflect the need for a follow-up submittal (revised LER) 1 at a later date to completely fulfill the LER content 4
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Attachment Page 2 of 5 Docket Nos. 50-277 50-278 requirements.
The delayed submittal of these LERs is partly due to our intention to completely fulfill the LER content requirements with the first submittal in spite of the fact that-the subjects involved several technical complications which delayed the LER preparation process.
A substantial period of time was needed to identify all of the necessary technical information_and confirm its accuracy.
3.
Failure of the Nuclear Engineering Department to review the LER drafts in a. timely manner.
Additionally, preparation of LER 2-87-12 was delayed due to an isolated case of communications breakdown between the Peach Bottom Compliance Group (onsite) and and Nuclear Services Department Licensing Section (corporate).
As a result, the Licensing Section did not become aware of the November 10, 1987 reportable condition until December 31, 1987.
The Compliance Group identifies reportable events and conditions, and the Nuclear Services Department Licensing Section prepares the LERs.
Extent or Significance of Violations:
Although the Company was slow in reporting these design deficiencies, this is not indicative of the Company's responsiveness in correcting the deficiencies.
The cable l
separation problem reported in LER 2-87-32 was corrected within 1
two months from discovery, while the LER was being prepared.
In addition to the delay in communications, additional LER preparation time was spent identifying the appropriate _ corrective j
actions to prevent recurrence, and identifying the safety-related equipment that could have been affected by the cable separation problem.
In response to the potential Diesel Generator trip issue reported by LER 2-87-28, the Company commenced a design review (by the plant architect / engineer) within three weeks from discovery to identify the scope of the problem and recommend possible corrective measures.
The additional LER preparation time was spent primarily developing a complete and accurate assessment of the postulated consequences of the condition.
The delayed submittal of these LERs may have delayed potential NRC action on the reported conditions, and may have delayed dissemination of useful information to the industry regarding the reported conditions.
The condition reported by LER 2-87-32, however, was reported to the Commission by telephone within four hours from discovery.
Attachment Page 3 of 5 Docket Nos. 50-277 50-278 Corrective Actions Taken to Prevent Puture Non-Compliance and Results Achiaved:
To assure a LER submittal within 30 days, numerous activities must be conpleted in an expeditious manner.
These include (1)
'eportability evaluation and notification to the Licensing mection, (2) identification of an information contact, (3) obtain and/or develop all pertinent information, (4) draft the LER, (S) review by appropriate Philadelphia Electric Company technical and management personnel and (6) rewrite and re-review as necessary to obtain approval.
Additional time is often required to resolve differences of opinion and recycle revised drafts for review.
1.
LER Preparation Management Improvements:
To improve management of this process, the responsible licensing engineer now identifies milestone dates for each task.
Failure to meet milestones are reported to Licensing Section supervision and the supervision of those responsible for the specific task to expedite action.
This minimizes the time for compilation of information and management review.
Further, if all the technical information needed to prepare a draft LER cannot be compiled within the allotted time frame, a commitment to provide the unavailable information in a revised LER is stated in the draft rather than jeopardize the 30-day submittal.
These steps have improved our LER preparation performance.
2.
Nuclear Engineering Department Interface Improvements:
The process for requesting Nuclear Engineering support has been streamlined, and personnel in the Nuclear Engineering Department Licensing Branch have been dedicated to activities associated with the preparation of licensing correspondence and reports.
This has significantly improved the responsiveness of the Nuclear Engineering Department to the recuired LER preparation activities.
3.
Notification of Reportable Events and Conditions:
a)
Previously, the Licensing Section relied primarily on a verbal notification from the station Compliance Group of a reportable event or condition.
To improve the notification process the Licensing Section now receives copies of suspected LER (SLER) forms to serve as a backup to the verbal notification procedure.
The
Attachment Page 4 of 5 Docket Nos. 50-277 50-278 Licensing Section screens the SLERs to identify possible missing or delayed verbal notifications.
b)
On April 11, 1988 the Nuclear Engineering Department instituted a new written process for handling licensing matters including a requirement that Nuclear Engineering Department personnel immediately notify the Nuclear Engineering Department Licensing Branch of potentially reportable events.
After a preliminary review, a SLER form will be completed and delivered to the Nuclear Services Licensing Section (who in turn will notify the Compliance Group).
By implementing the above items the Licensing Section is notified at the initial stage of the reportable event / condition identification process, rather than later in the process, as previously was the case.
Additionally, the creation of a new station regulatory organization (which includes the Compliance Group) under the Superintendent-Technical earlier this year has improved the identification of reportable events / conditions.
The organization is supervised by the Regulatory Engineer whose primary focus is on compliance issues.
Corrective Actions to be Taken to Prevent Future Non-Compliance:
In addition to improving the LER preparation process, the Nuclear Group of Philadelphia Electric Company has recognized the need to
)
improve its ability to identify and disposition potentially i
reportable events / conditions.
A new process for identifying and dispositioning potentially reportable items has been developed i
and is being reviewed by the Nuclear Group management.
The entire Nuclear Group (nuclear stations, Nuclear Engineering, Nuclear Services and Naclear Quality Assurance) will participate j
in this process, which will establish a uniform approach for the i
identification and evaluation of potentially reportable items.
A manual will be issued to provide guidance on reportability requirements and training will be conducted to support the new process.
As a result, more personnel will be educated on reportability requirements and stronger controls will be i
established for dispositioning potentially reportable events / conditions.
The Company is currently training personnel in the implementation of the new process.
~
Attachment Page 5 of 5 Docket-Nos. 50-277 50-278 Achievement of Full Compliance:
The corrective actions taken have and will continue to prevent-late LERs due to delays in the LER preparation process.
The implementation of the new process for identifying and' dispositioning potentially reportable events / conditions will prevent late or missed LERs due to untimely identificaf; ion of or failure to identify reportable events / conditions (which recently caused a fire barrier problem to be reported late, LER 2-38-07 dated May 16, 1988).
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