ML19325E565
| ML19325E565 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 10/27/1989 |
| From: | Mccormick M PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8911070401 | |
| Download: ML19325E565 (5) | |
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PHILADELPHIA ELECTRIC COMPANY j
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I s AN ATOG A. PENNSY3.V ANI A 19464 s
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Docket No. 50-353 i
F License No. NPF-85 4
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,0.S.. Nuclear Regulatory Commission.
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SUBJECT:
i,imerick Generating <Staticn, Unit 2 x
. Reply to a Notice of Violation
,e NRC1nspectionReportNo.50-353/Ll9-81 N..
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NGC letter dated September 27, 1989,' forwarded Inspection Report.No. 150:-353/89-81 for Lin:erick Generating Station Unit 2.
A.This. Inspection Reportscontained a Notic'e of Violatfon involving inadequate control of changen made'to a curveillen:e' test s
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procedure.
Our response to this violation is provided ir, the l
attachment to tnis letter.
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't If you have any questions or require additional informati6n, p q.
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- i Very trtdy yours,
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. Attachmer:t s
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W. T. Russell, Administrator, Region I, USNRC T. J. Kenny, USNRC Senior Realdent Inspector, LGS q.
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0911070401 891027 j@Of NP 1
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V,IOLATION p.
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't 10 CP'R 50, Appendix B, Criterion VI, " Document Control," '
w requires that measures be established to rent.ici the issuance of i*
procedures, including changes, and that'these procedures including changes, be reviewed for adequacy and approved for release.
These requirements are impleneated by administrative i
d se procesore A-2, " Control of Procedurec and Certain Documents."
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J Contrary'to the above, surveillance test procedure I
ST-6-M3-200-2, " Reactor Retirculation System Quarterly Valvo 1
W st " Revision 2, dated Junts 13, 1989, contained errors from the i
revision process, and no review was performed prior to its 4
issuance and use on August 3, 1989.
In addition, on August-4, 198'), a controlled copy of this procedure did not contain the i
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most recent re'ilsion which had been approved two months earlier.
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These deficiencies are collectively a Severity Level'V Violation (Supplement I).
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Admiss. ion of Violation o
3 I In Philadelphia Electric Company acknowledges the violation.
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f,L This violation involves two different problems associated
,l with the same procedure.. These problems consisted of, 1).a d
printing. error in a Unit 2 Surveillance test (ST) procedure L;j revision (i.e. FT 4-043-200-2 Revision 2) that was not detected
- during the procedure revision review process and a failure to update the revision bar markers, and 21 an outdated revision of ST-6-043-200 located in the Technical Support Center (TSC) j 4
Records Room.
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11e_an_on for_ the Violation, j
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!,.kO As required by Administrative Procedure A-2, " Control of i
ls Procedures and Certain Documents' " procedure revisions are Q'
Hubmitted for Plant Operations Review Committee (PORC) review.
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.The changes may be typed or indicated with hand written changes 1.
made to the previous revision.
After PORC review is obtained.
Ma the procedure.is then returned to a typist for incorporation'of f
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final changes.
These final changes include incorporating any 9,.,
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.t Attcchment Pags 2 of 4 Docket No. 50-353 handwritten comments, any PORC review changes, and revision bar changes.
This typing process first involves inccrporating all
' handwritten comments and revision bar changes on a computerized word processcr and then sending those changes to an assigned printer.
The final procedure sa prini:ed arid reviewed by a t
preparer and/or typist.
The procedure is then approved by the I
Plant Manager or an authorized individual disignafed to review and approve the procedure for the Plant Manager.
The procedure is then distributed by Document Control personnel.
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Proposed Revision 2 to ST-6-04J-200-2 contained handwritten comments to be incorporated following PORC review.
The procedure was type 3, however, the typist failed to update tha revision bars in the new revision as required by procedure A-2.
In addition, during the transfer of the finalized procedure from the word j
- processor to the assigned printer for output, a printer error occurred such that alignment of t:te text on a page of the procedure was shifted resulting in part of the procedure page not p
being printed.
However, during this final review the typist 1
P failed to identify the incorrect revision bar markers and the misprinted page due inpart to a lack of detailed guidance.
L Item 2 Unit 2 procedures ir.cluding the ST-6 procedures were added to c'
the TSC Records Room in April 1989 in preparation for issuance of u.
'the Unit 2 Operating License.
When these procedures uere physically added to this location, they were to be placed on the procedure distribution schedules ehich are used to identify those locations that must be maintained up-to-date with current i
approved procedure revisions'.
The Unit 2 procedures, in the TSC Records Room were not cdded to the procedure distribution
.nchedules due to a personnel etror.. The individual.Ienl)onsible
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for updating the procedure distribution schedules fallad to it properly transcribe the added procedure locations on the.
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jN appropriate distribution schedules.
This error war das in part
'W' to a temporary instruction conteined on the schedule intended to H:
control the issuance of the added procedure locations In N
addition, > this investigaf.lon revealed that the Unit 2 procedures M
-in the Emergency Operations Faci.lity (EOF) also had not been j.S updated because of the same error.
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. Corrective Action and Re6ults Achieved i
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f' On N.tgust 8,,
.1989, procedure ST-6-043 -200-2 was revised to correct the revision bar markers and the misprinted page.,
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' August 9,'
1989, all Unit 2 ST-6 procedures and a random sampling N?
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- ic Docket No. 50-353 k },
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or all other plant procedures were reviewed ~for sjallar problems.
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fitation personnel checked 425 procedures and two~ additional printing deficiencies were identified.
Both errors were insignificant and did not affect the technical information in the m
procedura.
As of October 2s, 1989 approximately 1100 procedurcs ont of a total of 7280 procedures have been processed and reviewed without similar errors.
These two procedures have been reprinted an6 distributed to the appropriate locations.
Item 2
. On August 9,1989, each procedure distreibution location was audited and Station personne:' verified that all procedures et each designated location are listed on the appropriate procedure p
distribution schedule.
Additionally, by August 9, 1989, all Unit 2 procedure books in the TSC and the EOF Records Rooms were l
-j audited.
Station personnel verified that each procedure was the lc proper revision.
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L Corrective Actionn Taken to Avoid Future Non-Compliance g1 2
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On. August 8, 1989, a letter was sLnt by the Superintendent-Admitu.+ ration to all on-site supervision who have individuals responsible for typing, proofreading, or checking s'
. procedures.
This letter discussed the identified procedure
!j revtslon process deficiency and provided a checklist to assist in the final procedure review procesu.
This checklist of items will
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.be used by those.-individuals who type, proofread, and check 1
procedures to assure that no procedure pages-are misprintt.4 and I. that revision bars are correct pr.ior to final issuance.
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December'31, 1989, written guidance will be provided to all i;
preparers, typists, ptoofreaders, and checkers of procedures i
detailing their responsibilities during the procedure revision hL process.- Additionally, an investigation.has been initiated to 1.. [
7 etermine and implemeat corrective actions to eliminate the d
,*p printer deficiency that reeults in misprJnted pages.
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The individual responsible for the error associated with the W
R p ocedure-distribution schedule was counseled on the need to use l/g,
caution.when modifying or updating the procedure disdribution W
nchedules.
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Docket No. 50-353
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l-l All procedure locations and the procedure distribution
'.I, schedules were reviewed and no ej.nllar deficiencies were
. identified.
Therefore, this event is considered an isolated occurrence and no further corrective actions are planned.
Date When Full Compliance was Achieved Full. compliance was achieved or. August ?,1989 when ST-6-0A3-200-2 was revised, the procedure audit was completed and c,-
a checklist was in place to provide exact guidance on all final procedure typing and pioofreading prior to distribution and implementation.
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