ML20031B999

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Forwards IE Insp Repts 50-277/81-12 & 50-278/81-13 on 810504-08 & Notice of Violation
ML20031B999
Person / Time
Site: Peach Bottom  
Issue date: 09/18/1981
From: Martin T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Daltroff S
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
Shared Package
ML20031C000 List:
References
NUDOCS 8110060418
Download: ML20031B999 (3)


See also: IR 05000277/1981012

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SEP 181981

Docket Nos. 50-277

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Philadelphia Electric Company

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ATTN: Mr. S. L. Daltroff

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Vice President

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Electric Production

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2301 Market Street

Philadelohta, Pennsylvania 19101

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Gentlemen:

Subject: Combined Inspections 50-277/81-12 and 50-278/81-13

This refers to the routine safety inspection conducted by Mr. N. Blumberg of

this office on May 4-8, 1981, at Peach'Dottom Atomic Power Station, Units 2

and 3, Delta, Pennsylvania, of activities authorized by NRC License Nos.

DPR-44 and DPR-56 and to the discussions of our findings held by Mr. Blumberg

with Mr. T. Ullrich and other members of your staff at the conclusion of the

inspection, and to a subsequent telephone discussion between Mr. Blumberg and

Mr. Ullrich on June 1, 1981.

Areas examined during this insoection are described in the Office of Inspection

and Enforcement Inspection Report which is enclosed with this letter. Within

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these areas, the inspection consisted of selective examinations of procedures

and representative records, interviews with personnel, and observations by the

inspector.

Our inspector also verified the steps you have taken to correct the item of

noncompliance (Item J) brought to your attention in the enclosure to our

letter dated June 30, 1977; the item of noncompliance brought to your attention

in a letter dated February 22, 1979; and the item of noncompliance brought to

your attention in a letter dated April 21, 1980. We have no further questions

regarding your action at this time. With regard to an item of ncqcompliance

(Item C) brought to your attention in a letter dated August 27, 1979, this

item was not fully corrected and has recurred.

Based on the results of this inspection, it appears that one of your activities

was not conducted in full compliance with NRC requirements, as set forth in

the Notice of Violation, enclosed herewith as Appendix A.

This item of noncompli-

ance has been categorized into the levels described in the Federal Register

Notice (45 FR 66754) dated October 7, 1980. You are required to respond to

this letter and in preparing your response, you should follow the instructions

in Appendix A.

In addition to the need for corrective action regarding this

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0FFICIAL RECORD COPY

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Philadelphia 5 Electric Cnmpany

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claimed that the informatica should be withheld from public disclosure. This-

section further requires the statement to addreas with specificity the consider-

ations listed in 10 CFR 2.790(b)(4). The information sought to be withheld

shall be incorporated as far as possible into a separate part of the affidavit.

If we do not hear from you in this regard within the specified periods noted

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above, the report will be placed in the Public Document Room. The telephone

notification of your intent to request withholding, or any request for an

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extension of the 10 day period which you believe necessary, should be made to

the Supervisor, Files Mail and Records, USNRC Region I, at (215) 337-5223.

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Should you have any questions concerning this inspection, we will be pleased

to discuss them with you.

Sincerely,

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' Thomas T. Martin, Acting Director

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Division of Engineering and Technical

Inspection

Enclosures:

1.

Appendix A, Notice of Violation

2.

Combined Office of Inspectior: and Enforcement Inspection Report Numbers

50-277/81-12 and 50-278/81-13

cc w/encls:

'W.

T. Ullrich, Station Superintendent

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Troy B. Conner, Jr. , Esquire (Without Report)

Eugene J. Bradley, Esquite (Without Report)

Raymond L. Hovis, Esquire (Without Report)

Michael J. Scibinico, II, Assistant Attorney General (Without Report)

Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

Commonwealth of Pennsylvania

bec w/encls:

Region I Document Room (with concurrences)

Trcy B. Conner, Jr. , Esquire

Eugene J. Bradley, Esquire

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Raymond L. Hovis, Esquire

Michael J. Scibinico, II, Assistant Attorney General

NRC Resident Inspector

Chief, Operational Support Section (w/o encis)

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0FFICIAL RECORD COPY

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Philadelphia Electric Company

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specific item of noncompliance, we are concerned about the implementation of

your management control systems that permitted it to occur. Consequently, in

your reply, you shoule describe in particular, those actions tsken or planned

to improve the effectiveness of your management control systems.

The item of noncompliance in the Notice of Violation enclosed with this letter

was identified during a previous inspection of your licensed activities on May

24, 1979 and was documented in the enclosure to our letter dated August 27,

1979. Your letter to this office dated September 17,-1979 stated that in

order to preclude the recurrence of lost maintenance records, personnel were

instructed in the importance of adherence to Administrative Procedure A-26.

From our May 4-8, 1981 inspection, it appears that stated corrective actions

were not effective since this item has recurred.

Recurrent items of noncompli-

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ance are given additional weight in the consideration and selection of appropri-

ate enforcement action. Therefore, in your response to this letter, you

should give particular attention to those actions taken or planned to ensure

that identified items of noncompliance will be completely corrected and will

not recur.

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In addition, Unresolved Item (277/81-12-03, 278/81-13-03) described in the

attached inspection report noter instances in which compliance to ANSI N45.2.9,

" Requirements for Collection, Storage and Maintenance of Quality Assurance

Records for Nuclear Power Plants," appears not to have been fully established.

Your Quality Assurance Program established in the Final Safety Analysis Report

(FSAR), Appendix D, dated May,1977, states an intended commitment that your

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company will establish full compliance to ANSI N45.2.9.

However, no date was

established for completion of full compliance.

It 1s, however, expected that

such commitments ce achieved in a timely manner. Therefore, in your response

to this letter, in addition to your response to the item of noncompliance

identified in the inspection report, it is requested that you notify us, in

writing, of the portions of ANSI N45.2.9 to which your records management

program is in compliance; the portions of ANSI N45.2.9 to which your records

management program is not in compliance; and the date by which your records

management program and its implementation will be in full compliance to ANSI

N45.2.9Property "ANSI code" (as page type) with input value "ANSI</br></br>N45.2.9" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..

In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of

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this letter and the enclosures will be placed in the NRC's Public Document

Room.

If this report contains any information that you (or your contractors)

believe to be exempt from disclosure under 10 CFR 9.5(a)(4), it is necessary

that you (a) notify this office by telephone within ten (10) days from the

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date of this letter of your intention to file a request for withholding; and

(b) submit within 25 days from the date of this letter a written application

to this office to withhold such information. Consistent with section 2.790(b)(1),

any such application must be accompanied by an affidavit executed by the owner

of the information which identifies the document or part sought to be withheld,

and which contains a full statement of the reasons on the basis which it is

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OFFICIAL RECORD COPY

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