ML19290D971

Responds to NRC 791221 Ltr Re Violations Noted in IE Insp Repts 50-277/79-27 & 50-278/79-30.Corrective Action:Radwaste Control Room Has Been Placed on Controlled Distribution List for Radwaste Procedures

ML19290D971
Person / Time
Site:	Peach Bottom
Issue date:	01/09/1980
From:	Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19290D968	List: ML19290D971
References
NUDOCS 8002290583
Download: ML19290D971 (2)

Text

'. . .

t PHILAD ELPHI A ELECTRIC COM PANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 SHIELDS L. DALTROFF ELacTRfC PR CION

~ January 9, 1980 RE: D ocke t Nos.: 50-277 50-278 Inspection Nos.: 50-277/79-27 50-278/79-30 Mr. George H. Smith, Chief Fuel Facility and Materials Safety Branch US Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406

Dear Mr. Smith:

This letter is in response to combined Inspection Report 50-277/79-27 and 50-278/79-30 dated December 21, 1979 Appendix A t o y ou r letter addresses two items as not appearing to be in full c o mp li a n c e with Nuclear Regulatory Commission requirements. Both items are categorized as infractions. They are restated with our responses.

A. 10 CFR 50, Appendix B, Criterion VI states in part

" Measures shall be established to control the issuance of d ocu me n t s , such as instructions, procedures, and drawings, including changes thereto... these measures shall assure that docunents... are distributed to and used at the location where the activity is performed.

The licensees NRC accepted Quality Assurance Plan, Volume III, Section 2, paragraph 6.1 states in part

" documents, including changes... are distributed to and used at the location where the p res cribed a ctivity is performed."

Contrary to the above requirements current revisions of radwaste procedures S.10.4.1.3 and S.10.4.1.C were not distributed to and used at the radwaste panel, the 8002200 ggg

4 Mr. George H. Smith, Chief Page 2 location at which the activities described in the procedures were performed.

Response

Current revisions to the p rocedures mentioned in this item were not subject to controlled distribution to the radwaste control room area. Therefore, some of these procedures may have been misplaced or never incorp orated into the p rocedu re book in this location. To correct this situation, the radwaste control room has been placed on the controlled distribution list for ap p rop ria t e radwaste procedures (S.10.3 and S.10.4 series). This mechanism will insure that the most current revisions of the above mentioned p rocedures are p romp t ly placed in the procedure b o ok .

B. Technical Specification 6.8.1 requires that " Written procedures and administrative policies shall be established, implemented and maintained that meet the requirements of Section 5.1 and 5.3 of ANSI N18.7-1972 and Appendix "A" of USAEC Regulatory Guide 1.33."

Licensee procedures S.10.4.1.B and S.10.4.1.C, each developed pursuant to Technical Specification 6.8.1, require that a ch e ck-of f list be comp leted in the initial step of the p rocedure.

Contrary to the above requirement the activities described in the p rocedures were performed on several occasions in October 1979, including October 31, and no check-off lists were completed.

Response

An indepth review of procedures S.10.4.1.B and S.10.4.1.C was performed to determine whether the check-off list sh ould be completed each time that the procedure is implemented. It has been determined that there is no technical reas on f or the check-off lists to be completed each time the p rocedures are to be used since the equipment is used on a daily basis and in some cases more than once du ring s ome operating shifts. The operator who performs these functions receives direction f rom the p revi ou s shift op era t or regarding the status of these items. C omp le ti on of the check-off lists is not necessary for operation of the system, therefore, the requirement to complete the check-of f lists has been celeted f rom the procedures.

Very truly yours, l

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