ML20083L916
| ML20083L916 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 03/08/1984 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20083L908 | List: |
| References | |
| NUDOCS 8404170406 | |
| Download: ML20083L916 (3) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 23o1 MARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 SHIELDS L. DALTROFF
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March 8, 1984 Docket Nos. 50-278 50-278 Inspection Report Nos. 50-277/83-32 50-278/83-30 Mr. Thomas E. Martin, Director Division of Engineering and Technical Programs U. S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Martin:
Your letter of February 9,1984, forwarded combined Inspection Report 50-277/83-32 and 50-278/83-30.
Appendix A addresses one item which appears to be a deviation from the actions described in an October 19,1981 letter from S. L.
Daltroff, Philadelphia Electric Company, to T. T. Martin, NRC.
This item is restated below along with our response.
A letter from S. L.
Daltroff, Philadelphia Electric Company, to T. T. Martin, NRC, subject: Response to Notice of Violation, dated October 19, 1981, committed to full compliance with ANSI N45.2.9-1974, Requirements of Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants, by June 1983.
The standard requires permanent and temporary record storage be provided for maintenance, preservation, and the safety of required records.
Procedure A 46.1, Transmittal of Records to the Nuclear Records Management System, Revision 0, permits the various departments generating records to retain such records for periods up to four years.
8404170406 840410 PDR ADOCK 05000277 G
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" Mr. Thomas E. Martin, USNRC March 8, 1984 i
Page 2 of 3 I
Contrary to the above, adequate preservation and 1
-protection was not provided certain permanent records in that; j
maintenance records were stored in several cardboard boxes placed at various locations (e.g. under desks, along aisles) about the Maintenance Office floor; and, radiation work permits and other l
Health Physics loose records we e stored in stacks atop various 1
desks in the Health Physics Office.
A sampling of.these records indicated they had been retained in this fashion between sixty j
days and one year.
Response
A substantial backlog of Maintenance Request Forms (MRFs) were j
stored in several cardboard boxes at various locations about the-Maintenance Engineering of fice floor and had-accumulated as a j
result of a Nuclear Plant Reliability Data System (NPRDS) ' review l
effort.
Philadelphia Electric Company is involved in NPRDS Which is under I
the management of the Institute' of Nuclear Power Operations 4
(INPO).
The majority of the component failure information' submitted to INPO for NPRDS is identified through-the station.
I maintenance activities Which are controlled'by means of MRF's.
MRF's are reviewed for NPRDS reportability prior to their.
transfer to the Document' Administration Center (DAC) for inclusion in the Nuclear Records Management System (NRMS).
All backlog MRF's identified during the inspection have been sent to the DAC for processing and inclusion into NRMS.
- Likewise, Peach Bottom has instituted a Computerized History and i
Maintenance Planning System (CHAMPS) which incorporates the-j information contained on MRF's into a computer system.. Teil...-[v/ar t #
1 reporting to NPRDS will thereby be accomplished by reviewing thd information contained in CHAMPS thus allowing the hard copies of i
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the MRF's to' be transferred to the - DAC in a more timely ' f ashion.
i Radiation Work Permits (kWF9) were stored in stacks atop various J
I desks in the Health-Physics Office and had' accumulated as a i
result of Philadelphia Electric Company's ALARA program.-
1 In an effort to provide a better ALARA program, completed RWPs are reviewed and important exposuro-information is recorded' I
before the records are transferred'to the DAC.
This data provides'an exposure history that will enable health physics i
personnel to more accurately. keep.exposurescas low asLreasonably achievable.
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f Mr. Thomas E. Martin,'USNRC March 8, 1984 Page 3 of 3 l-l The accumulation of RWPs occurred because manpower efforts were placed in areas given higher priorities.
The problem with the accumulation of records was recognized and corrective. actions were being implemented prior to the NRC inspection of the area.
A technician was assigned the task of reviewing these records to
. reduce the backlog.
The required information has since been recorded and the records identified ~in the inspection are now in the DAC.
Additional clerical staff will be used during the upcoming Unit 2 refuel / maintenance outage to handle ~an anticipated large quantity l
of RWPs.
This should prevent any future large accumulation of RWPs awaiting ALARA review.
Additionally, a letter has been sent tx) all Senior Staff responsible forithe work groups listed in Administrative Procedure Exhibit A-46.1-1, "PBAPS Document Responsibilities by i
l Work Group".- The letter requests that the procedure be reviewed l
and that any large accumulation of records listed in this procedure be transferred to the DAC.
The work groups are requested to provide the DAC with a steady flow of records to prevent any future large accumulation of records.
Exhibit A-46.1-1 is being revised to emphasize this request for future reference.
We believe this. meets the intent of ANSI N45.2.9-1974 in that only active records will not be in the process of transfer to the DAC.
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If you have any further questions, please do not hesitate to contact us.
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-Very truly yours, d
cc:
Mr. A. R. Blough, Site Inspector I
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