ML20096B101
| ML20096B101 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 08/16/1984 |
| From: | Cooney M PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| OL, NUDOCS 8408310417 | |
| Download: ML20096B101 (3) | |
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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET RELATED CC.WSi'CTiDENCE P.O. BOX 8699 PHILADELPHIA. PA.19101 E'.kf 4ris) e4 soro n J cw cv yM
.uc,0Pf."S.C.'.'!.'.,-.,
ust 16, 1984 Docket No. 50-352 6 4-
)x, Inspection Report No. 50-352/84-25 r;u Mr. Thomas T. 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 July 17, 1984, T. T. Martin, NRC, to J.
S. Kemper, PECo, forwarded Inspection Report No. 50-352/84-25.
Appendix A to your letter addresses an apparent violation of HRC requirements.
This item is restated below along with our response.
Criterion V of 10 CFR 50, Appendix B, requires that activities affecting quality shall be prescribed by procedures c
appropriate to the circumstances and shall be accomplished in accordance with those procedures.
L.
P Administrative Directive 6.1-6, System / Component Turnover to PECo, Paragraph 5.5 states that upon acceptance of the turnover, Startup personnel will place green tags on 2
equipment within the boundaries of the turnover and that, at completion of green tagging, no blue construction tags with the exception of NCRs, CRs, identification tags or Bechtel " Red" tags at boundary points shall remain in place.
If personnel protection is deemed necessary after turnover, Bechtel Construction safety tags shall be placed on boundary equipment.
Additionally PECo safety tags shall be placed on boundary equipment included in the turnover.
r.
Contrary to the above, on May 24, 1984, it was observed that components such as valves, motor operators, pumps etc., with the exception of electrical switches and breakers, within the boundaries of the Residual Heat Removal Service Water (RHRSW)
System Turnover No.1-16A-1(F) completed on May 4, 1984, had not 8408310417 840816 PDR ADDCK 05000352 G
i Mt. Thomas T. Martin August 16, 1984 s
Page 2 been green tagged nor had blue construction tags been removed.
In addition, two boundary valves HV-2-12 and HV-2-13, which isolate the RHRSW system from the Unit-2 cooling tower and which were included in the turnover, had Bechtel Construction boundary cafety tags in place but the additional PECo safety tags had not been placed on the valves.
This is a Severity Level V violation (Supplement II).
gespggse Based on the results of previous PECo Engineering & Research Department Quality Assurance Section auditing of system tagging, it is our belief that inadequate status tagging of this system was an isolated incident.
Upon notification by the NRC, Quality Assurance performed an audit which reaffirmed the situation and resulted in the issuance of an NCR having five open items.
i The responsible System Startup-Engineer walked down the equipment within the boundaries of the RHRSW System Turnover No.1-16A-1(F) and assured that valves, instruments, switches, and components were properly tagged and corrected the items cited in the NCR.
Upon completion, the system was walked down again by the Startup Group Supervisor and the to verify that all necessary (green, System Startup Engineer blue or safety) tagging was complete and proper.
In order to prevent recurrence of this isolated incident, the System Startup Engineer (SSE) the Administrative Directives for the RHRSW System reviewed (AD 6.1 and AD 2.2) associated with turnover tagging and a discussion was held to assure that the SSE understood the procedure. The Startup QC organization also issued a Startup Training Bulletin (TB No.
84-XXXIII, 5/25/84) to System Startup Engineers on the subject of green tagging in order to reinforce previous training and prevent further difficulties.
If you should have any questions, please do not hesitate to contact us.
Very truly yours, rigind pn:d by M. 'J. CO' ZY J
JCNtydw
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.cc:
Judge l Lawrence Brenner Judge Peter A. Morris Judge Richard F. Cole Troy B. Conner, Jr., Esq.
Ann P. Hodgdon, Esq.
Mr. Frank R. Romano Mr. Robert L. Anthony Maureen Mulligan Charles W. Elliott, Esq.
Zori G. Ferkin, Esq.
Mr. Thomas Gerusky Director, Penna. Emergency Management Agency Angus Love, Esq.
David Wersan, Esq.
Robert J. Sugarman, Esq.
Martha W. Bush, Esq.
Spence W. Perry, Esq.
Jay M. Gutierrez, Esq.
Atomic Safety & Licensing Appeal Board Atomic Safety & Licensing Board Panel Docket & Service Section (3 copies)
Timothy R. S. Campbell S
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