ML20028D009

Responds to NRC 821112 Ltr Re Violations Noted in IE Insp Repts 50-277/82-21 & 50-278/82-20.Corrective Actions:Color Coding of Locked Valves Completed,Training Program Revised & Fire Watch Procedures Reviewed

ML20028D009
Person / Time
Site:	Peach Bottom
Issue date:	12/07/1982
From:	Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20028D004	List: ML20028D009
References
NUDOCS 8301140395
Download: ML20028D009 (5)

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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA, PA.19101 SHIELDS L. D ALTROFF aEc'r'n'ic"/[SUio December 7, 1982 Docket Nos: 50-277 50-2 8 Inspection Nos.: 50-277/82-21 50-278/82-20 Mr. Richard W. Starostecki, Director Division of Project and Resident Programs United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406

Dear Mr. Starostecki:

Appendix A of Inspection Report 50-277/82-21 and 50-278/82-20 forwarded by your letter of November 12, 1983, addresses several items which do not appear to be in full compliance with Nuclear Regulatory Commission Requirements. These items are restated below along with our response.

A.1 Technical Specification 6.8 and Regulatory Guide 1.33 (November 1972) require implementation of procedures for the fire protection system. Administrative Procedure 12.1, Revision 3, April 23, 1982, Procedure for Controlling Technical Specification Fire Watch and Fire Watch Patrols, states that the fire watch shall have no other duties, a fire watch instruction sheet shall be completed and provided to the fire watch, and equipment status shall be logged on the Fire System Status Sheet.

l 8301140395 830110 PDR ADOCK 05000277

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W Mr. Richard W. Starostecki' Page'2 A.l.1 Contrary to the above,-from 2:30 PM to 4:00 PM on July 25, 1982, a fire watch posted at an inoperable fire.

t barrier between the Cable Spreading Room and the Radwaste Building had concurrent duties, in'that he was a member of the minimum armed. response force, required ~

by the Accepted Security Plan to be available at all times to respond to a security alert.

A.1.2 contrary to the above, from July 24 to July 26, 1982,.

no fire watch instruction sheet was' completed and provided to the fire watch at the inoperable fire barrier between the Cable Spreading Room and the i Radwaste Building. Further, the inoperable barrier was i not logged on the Fire System Status Sheet.

Response

The fire watch posted at the stated time in the.Radwaste Building was part of the minimum armed response force.

Members of the armed response force are assigned duties throughout the site by Security Supervision and can be directed to proceed to any location to respond to a security situation. The location of each member of the response team and the location of the security incident determine the individual response time. The individual in' question could have been dispatched immediately without a relief or in a short period of time with a relief depending on the severity )

of the incident. In any event, neither of these actions were required.

Since it was not necessary for the assigned fire watch to i respond to a security incident during this period, '

Administrative Procedure A12.1, Rev. 3, April 23, 1982, was not violated. Therefore, licensee hereby requests that this violation be reconsidered by the Commission.

However, Security Supervision has been reminded, that, when requested to post a fire watch by Shift Supervision that the assigned personnel must have no other duties concurrent with the fire watch responsibilities and that members of the minimum armed response force should not be assigned as a fire watch.

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Mr. Richard W. Starostecki 'Page 3

=The licensee-does recognize the need for fire. watch instructions and logging of inoperable equipment. shift Supervision has been reminded'to complete the~ Fire. Watch-

. Instruction Sheet and the logging requirements on the Fire System Status Sheet for technical specification fire watches even when security personnel are used.

A.2 Technical. Specification 6.8 and-Regulatory Guide 1.33 require implementation of procedures for equipment control.

Administrative Procedure A-8, Revision 4, January 22, 1980, Procedure for Control of Locked Valves, and Appendix A-8C, Revision 6, April 1, 1982, require that valves on the Locked i Valve Lists lxt locked with a padlock and chain unless

maintenance or operations in progress require'otherwise.

Contrary to the above, at 10:00 AM on September 21, 1982, Emergency Service Water System Valve 519C, Inlet to theC' Diesel, listed on Locked Valve List A-8C was not-locked and no related operations or maintenance were in progress.

e Response -i 1

. Upon notification, by the inspector, of the correctly positioned i but unlocked valve, the valve was locked. All Unit 3 and common locked valves were rechecked and no deficiencies were discovered.

The Unit 2 locked valves had been checked shortly before this occurrence. . Investigation has not determined how the valve became unlocked.

Several corrective measures which have been or will be implemented are:-

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1) The color coding of each accessible locked valve to high-light its significance has been completed. Inaccessible valves will be color coded during future outages of 4 sufficient duration. In addition to defining locked valve j status, the color codes indicates the normal valve position.

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. Mr.' Richard W. Starostecki- Page 4

2) The auxiliary operator training program has been revised to require individual performance of the. locked' valve check-off-list on each unit, thereby ensuring their knowledge of the'-

location and significance of these valves.

Sincerely

!/ ~ '

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f, .

cc: R. A. Blough, Site Inspector

COMMONWEALTH OF PENNSYLVANIA :

ss.

COUNTY OF PHILADELPHIA  :

S. L. Daltroff, being first duly sworn, deposes and says:

That he is Vice President of Philadelphia Electric-Company, that he has read the foregoing response to Inspection Report No. 50/277/82-21 & 50-278/82-20 and that he knows the contents thereof, and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.

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L / 8 Subscribed and sworn to before me this 10,6 day of D 3a"'"'A

{~.uta -L L/.</in.,14: s

/ v C' Notary Public Notary Public, Philadelphia. Philadelphia Co.

My Commi:sion Exti res July 28,1995 l

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