ML20005G258

Provides Written Comments Re SALP Board Repts 50-352/88-99 & 50-353/88-99 for May 1988 - Aug 1989 by Summarizing Presentations at 891221 Meeting.Concurs W/Salp Board Assessment of Activities at Plant

ML20005G258
Person / Time
Site:	Limerick
Issue date:	01/10/1990
From:	Leitch G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9001180348
Download: ML20005G258 (3)

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$. f . PHILADELPHIA ELECTRIC COMPANY 1 l

1 (IMERICK GENER ATING STATION '

- P. O. BOX A

- SAN ATOG A. PENNSYLV ANI A 19464 (215) 3271200, EXT, 2000

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,................uvi January 10, 1990 Docket Nos. 50-352

!4 50-353 License Nos. NPF-39'

m. NPF-85

.; 'U.S. Nuclear Regulatory Commission V  : Attn: Document: Control Desk Washington, DC- 20555

SUBJECT:

Limerick: Generating Station, Units 1 and-2

' Systematic! Assessment of Licensee Performance Board Report No. 50-352/88-99; 50-353/88-99 i

' Submittal of Written Comments Gentlemen::

'NRC: letter dated December 1, 1989, transmitted the VNRC's Systematic Assessment of' Licensee Performance (SALP) Board Report which-provided an~ assessment of our Limerick Generating Station (LGS), Units 1 and 2,=for the period May 1, 1988 through August 31,:1989.. We then met with NRC representatives on:

, December 21,,1989 at the LGS site, to discuss the Board Report assessments-and our plans to correct the identified weaknesses.

AtLthatstime',',we by! January 10 1990. stated that we would

-Accordingly, thisrespond letter to the Board provides ourReport 7 ~ -: written comments-regarding the SALP Board Report by summarizing

,' our; presentations at the December 21, 1989 meeting.

Overall', we concur with the SALP Board's assessment of

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activities'at LGS. We find that the Board Report accurately recognizes not only our successful efforts to achieve "world class" performance, but the effectiveness of the corrective actions'which are underway to strengthen identified weaknesses as well. Specifically, in the Emergency Preparedness (EP) area we have-developed a long-term corrective acticn plan based on the recommendations of our management root cause assessment team. We are now in the process of implementing the long-term Management Plan that we-first discussed with the NRC on July 6, 1989, and

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t, subsequently:provided-an updato u status. report during our meeting fat the:NRC Region I offices on October 23, 1989. While our timmediate' corrective actions re-established compliance with EP

' -regulatory requirements, the current implementation of our long-term-plancincludes maintaining strong senior management oversight, improving communications between corporate management i .and the EP staffs.at the. site and the corporate office, increased EP staffing, an elevated = site EP reporting level, and EP training

' improvements. As stated at both-the October 23, 1989-and December 21,11989' meetings, we plan to meet with the NRC in i

. April,.1990,.to present-the status of our long-term plan. We would be ready for the NRC to conduct an assessment of the p , . improvements of our EP program at that time.

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In the Engineering / Technical Support area, we 1 presented the findings and' recommendations of our root cause .

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• . assessment ofusome weaknesses in the routine engineering support '

-of LGS'at our meetingiwith the NRC on September 27, 1989. We q also note the SALP Board's comment concerning the lack of "!

p . critical self-assesscent by Nuclear Engineering Department (NED) management. Accordingly, a number of corrective actions'have been initiated and,cin some cases, completed. These include 4 strengthening-the'NED presence _on site and increasing the '

. involvement of NED personnel in site, activities and publishing a quality expectations ~ document. The NED has alco been reorganized' .

-i 3, so as_to provide a better " operating plant" support focus, is conducting'self-evaluations and performance monitoring, and has  ;

2 expanded the training provided to NED' personnel. As stated at '

the December 21,:1989 meeting, we will be ready to present our

-overall corrective action implementation plan,.which will address  !

.theifindings and recommendations of the root cause assessment, to '

.the NRC in March, 1990.

Lastly, we plan to continue the self-assessment-process that was conducted during the Unit 2 Power Ascension

-Program. This self-assessment of station operations will be

. performed on a quarterly basis through 1990, and the process will be re-evaluated at.the end of the year. We plan to present the interim results of'this self-assessment during the next LGS mid-

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cycle.SALP meeting with the NRC at a date to be arranged. t i

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j . If you have any questions,or need additional' information, please contact us.

Very ul ours, 52 4l -

cc: W. T. Russell, Administrator, Region I, USNRC T. J.-Kenny, USNRC> Senior Resident Inspector, LGS

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