ML20197F863

Forwards Response to RAI Re Adequacy & Availability of Design Bases Info.Detailed Response to Commitment Four of Util ,Provided.Response Constitutes Completion of Required Responses Outlined in

ML20197F863
Person / Time
Site:	Peach Bottom, Limerick
Issue date:	12/22/1997
From:	Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9712300309
Download: ML20197F863 (4)

Text

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Station Support Omartment PECO NUCLEAR nm%c-NNSNm A Unit of PECO Energy December 22,1997 Docket Nos. 50-277/278 50-352/353 License Nos. DPR-44/56 NPF-39/85 U.S. Nuclear Regulatory Commission j

Attn: Document Control Desk

- Washington, DC 20555-0001

Subject:

Peach Bottom Atomic Power Station, Units 2 and 3 Limerick Generating Station, Units 1 and 2 Request for Information Pursuant to 10 CFR 50.54 (f) Regarding Adequacy and Availability of Design Bases Information.

REFERENCE:

1)

Letter from James M. Taylor (USNRC) to C. A. McNeill Jr.

(PECO Energy) dated October 9,1996. " Request for Information Pursuant to 10 CFR 50.54 (f) Regarding Adequacy and Availability of Des gn Bases Iniormation"

2) Letter from D. B. Fetters (PECO Energy Company) to US

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Nuclear Regulatory Commission (USNRC) dated February 4,1997

3) Letter from G. A. Hunger, Jr, (PECO Energy Company) to US Nuclear Regulatory Commission (USNRC) dated May 2, 1997

4) Letter from G. A. Hunger, Jr, (PECO Energy Company) to US Nuclear Regulatory Commission (USNRC) dated May 7, 1997

Dear Sir:

In response to the Reference 1) letter, PECO Energy Company (PECO Energy) provided the Reference 2) response addressing five specific information requests, in addition, the response also provided a description of any ongoing or planned design review or reconstitution programs. As part of this response, 30c m I.lli.llil.lli. l.illi.lll.l ADOC 77-P PDR L

. December 22,1997 Pag,e 2 t

PECO Energy performed an extensive assessment in order to provide a complete and thorough response to the subject request for information. This assessment reviewed the current configuration management programs and controls, the translations of the design bases into the appropriate operating, maintenance and testing procedures, the performance of the Systems, Structures, and Components (SSCs) as it relates to the design bases, the problem identification and corrective action processes, the results of the extensive internal and external assessments of the configuration management program and processes, and the efforts which PECO Energy has pursued in response to various industry events and initiatives and NRC developments. to the reference 2) letter listed and described each commitment PECO Energy made as a result of this assessment.

This letter provides a detailed response, in Attachment A, to commitment 4 of the Reference 2) letter. While the corrective actions in response to this commitme.it are on-going, this letter completes the required response for commitment 4. This attachment refers to PECO Nuclear, which is a unit of PECO Energy.

Also, this letter in conjunction with the Referen&) 3) and 4) letters constitute completion of the required responses outlined in Attachm3nt 3 to the Reference

2) response letter.

If you have any questions regarding this submittal, p! ease contact me.

Very truly yours, t

G A. Hunger Jr.

Director, Licensing

Enclosures:

Attachment cc:

H, J. Miller, Administrator, Region I, USNRC A. C. McMurtray, USNRC Senior Resident inspector, PPAPS A. L. Burritt, USNRC Senior Resident inspector, LGS

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10CFR50.54(f) Response Docket Nosc 50-277/278 3

50-352/353 J ATTACHMENT A i

e:

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Commitment No. 4i Completion of Corrective Actions associated witt, the identification _of affected procedures as a result of design changes.

ISSUE:

9 A review of th's processes for changing the design bases indicates that the processes have the procedural mechanisms to ident!fy the impacted station procedures and revise them. However, numerous assessments have indicated that implementation of the process requires strengthening to assure all impacted procedures are updated as required.

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-_ A review of NRC Inspection Reports, PEP issues, NQA audits, Self Assessments, and ISEG Reports indicates a number of deficiencies have occurred in station procedures due to the inadequate incorporation of design changes into the procedures. Recent data has indicated that the corrective i

actions taken have not adequately resolved this problem.

The number of procedures that require revisions due to design changes is small compared to the body of procedures that implement design basis requirements, and the processes for updating procedures due b design changes are generally being followed. A review of the 1996 procedure revision cause code data found that the missed procedure revisions had minimal impact on plant safety.

Therefore, there is reasonable assurance that procedures adequately reflect the station design basis.

COMMITMENT:

An evaluation of the recognized weakness to identify and_ revise procedures -

Impacted by design basis changes will be performed and appropriate corrective actio7s implemented. Closure of identified discrepancies continue:.. Corrective actions associated with the program concerns will be identified and tracked via the PEP process PECO Nuclear will provide written confirmation to the NRC-within 30 days of completion of this evaluation and identification of corrective actions.

RESPONSE *-

L The evaluations of the weaknesses _in identifying and revising procedures impacted _by design basis changes have been completed. Short term corrective

actions have been implemented and are being monitored for effectiveness. To address the generic weaknesses within the processes that contributed to the 1

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10CFR50.54(f) Response Docket Nos. 50 277/278 50-35?/353 ATTACHMENT A -

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- deficiencies associate 6with inadequate incorporation of design changes into the i

procedures,- a Steering Committee was formed. The Steerlag Committee '.

included representation from Engineering, Operations an'J Maintenance.' A set-of corrective actions that includes both process and behavioral changes has _

a l been developed and training and implementation are planned for the first quarter of 1998. Implementation of the corrective actions includes appropriate

' perfomiance monitoring and success criteria. -

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