ML20096F763

Responds to NRC Re Violations Noted in Insp Repts 50-277/84-20 & 50-278/84-16.Corrective Actions:Individuals Counseled Re Lack of Attention to Detail of Fire Equipment & Fire Equipment Location Signs Installed

ML20096F763
Person / Time
Site:	Peach Bottom
Issue date:	08/31/1984
From:	Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8409100205
Download: ML20096F763 (5)

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,o PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET?

P.O. BOX 8699 PHILADELPHIA. PA.19101

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!2151 841 5001 smetos 1. DALTROFF ELECTaic oo CTross August-31, 1984 Docket Nos. 50-277 50-278

.Mr. Richard W.:Starostecki, Director Division of Project and' Resident Programs

'U.S. Nuclear _ Regulatory Commission Region I

.631 Park Avenue.

King.of Prussia, PA-19406

Dear:

Mr._Starostecki:

Your letter dated July 26, 1984, forwarded Combined

. Inspection Report 50-277/84-20 and'50-278/84-16.

Appendix A of your: letter 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 written procedures for fire protection equipment. ~ Administrative Procedure'A-130, Revision 4, June 10, 1981, Plant Housekeeping Controls, states in paragraph 9, Maintenance of Fire Fighting Capabilities, that the storage of equipment and materials

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shall not impede access to fire-fighting equipment.

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F Contrary to the above, at 8:20 a.m.,. June 27, 1984, access toffire extinguisher 234-5'on the Unit 2 Refuel Floor was impeded lur storage of material in front of the extinguisher.

This is a Severity Level IV' Violation (Supplement I) applicable ~to DPR-44.

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$i Mr. Ridhard-W.'Starostscki.

August 31, 1984 Page 2 JResponse.

This; violation 1was caused as a result of maintenance 1 riggers,' focusing their: attention on relocating. large

. material storage containers, failing to recognize that the containers;in.the new-location would block access to a fire

extinguisher.

LThe1 individuals' involved have been counseled for their lack

.ofiattention;t'o detail. -Fire equipment location signs were installed on July 11, 1984 cut both Unit'2'and Unit 3 refuel 8.ng-floors to. improve fire'equipmentolocation visibility. -This. corrective action was.in response to a

-recent ' previous. NRC inspector ' concern' that fire equipment

-visibility onithe_ refueling floor was restricted by the storage.of large components'during the present

' refuel / maintenance outage.

Peach Bottom management.

concurred with the ' inspector's concerns and initiated fire Lequipment visibility improvements,' prior to the citing of this' violation,' to provide better assurance of continued refueling 1 floor ' safety and compliance.

A letter,. dated

' August 2, 1984, was also. issued to' supervisory personnel to

-remind'all' personnel' of their obligation to' keep fire equipment access clear.

Due.to the short' time ~ frame between

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the initial expressed concern and this. violation, these

' improvements'were not completed before this. violation was issued. "These improvements provide additional assurance of future compliance.

A.2 Technical Specification 6.8.1. states that written-procedures and-administrative = policies shall be established, implemented andfmaintained. ' Administrative Procedure A-6 p'res' crib ~es the methods used to control drawings and assure thatiup-to-date drawings are used.in operation activities.

Contrary.to the above, drawings used in operation activities

-were-not properly ~ controlled,' including drawing M-351 which

.was{found to be. missing main steam relief valve vacuum

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breakers,. drawing M-329'which was missing, and numerous other' drawings which were found to be out-of-date during the'

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. time ~ period June 127 to July 2,'1984.

In addition,: Procedure' A-6,.Rev. 9, : dated 12/2/83, was out-of-date in L that numerous drawings had:been updated and not included in the' procedure.

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_This11s a Severity Level IV Violation (Supplement IV)

' applicable to DPR-44'and DPR-56.

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- Mr.sRichdrd W.fstarostecki' August 31, 1984 Page 3-LResponse.

(The' drawing-deficiencies-~ identified in this violation were

the result of Linadequate maintenance of controlled drawings andfa1 backlog in the completion of drawing ! revisions.

The

controlledidrawin'gs at PBAPS were manually updated as requirediby. Administrative procedure A-6;-but because of 1 extensive drawingLuse,Jthe-changes were torn and lost from lthe drawings.' The missing changes-weresnot corrected' prior sto.thisJinspection.

Upon notification, the inspector cidentified-deficiencies wereLpromptly corrected. ~ In Laddition, a comparison _of the controlled drawings.in the Control; Room, Shift Supervisor's office, and thetTechnical-Support Center was~made with the latest controlled drawing log, land'no other discrepancies were identified.-

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-Presently,: Engineering and Research Department (E&R) procedures do not specify completion time requirements for

^ drawing' revisions following.the completion of a plant.

4 Laodification.; The present time period experienced between

-the : completion of a modification and the final revision of theiassociatedLdrawing has contributed-to drawing f

cinaccuracies.

To correct this deficiency, Engineering and 1

Research Department. procedure, ERDP-3.6, will be revised to frequire.: time ' frames : for revisions cf various types of

! drawings following completion of plant modifications.

This-corrective action will more expeditiouslygprovide PBAPS with accurate. drawings 1and reduce-the likelihood'of manually

updated, changes.being torn'and lost from the controlled This correcti'e action is expected tozbe'in place

' drawings.

v by October 31, 1984.

Prior?to.this violation, controlled drawings were being maintained by individuals who were not assigned to the modification office.

To correct this problem and' enhance

-controlled drawing review, responsibility-for maintaining the - controlled drawings has 'been assigned to personnel in C

'the' modification office.

The chlorination system:at Peach Bottom was replaced with a L'

new sodium hypochlorite system for which a new P&ID (M-2601) was created.

As a result, P&ID M-329 was deleted and removed fromLth'e Control Room,'the Shift Supervisor's

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Loffice, and the Technical Support' Center to preclude'any use

'of1this P&ID..Fowever, P&ID M-329 was not removed-from

~ Administrative Procedure A-6, Table A6,'due to an.

Administrative oversight. HTo correct this. problem, P&ID M-2601 forithe~ sodium hypochlorite system is being renumbered

'M-329, to replace the deleted.P&ID for the chlorination

. system.

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-Mr.! Richard W. Starostecki August 31, 1984 Page 4

Personnel responsible for the review of' controlled drawings have.been_using-a controlled document entitled, " Drawing

-Control Log",_in addition'to Administrative Procedure A-6,_

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3 Table A6,- in f the review of controlled -drawings =and their

' latest revisions.- Additional drawings were added to.the

~ Drawing Control Log to ensure. that. the scope :of drawings

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.used;in operations activities.is_ complete.. However,:the additionalfdrawings were not.added to Administrative

Procedure A-6, Table A6,-because of an administrative oversight.

sAdministrative Procedure'A-6 will be revised to refer to-the

-Drawing Control Log.and_ Table A-6 will be deleted from the

-procedure.

This corrective action will-be completed lar September 30,.1984.

'The exten'sive corrective actions identified in this response should preclude the occurrence of similar controlled drawing

_ problems.

A.3; Technical Specification 6.8.1-states that written procedures and administrative policies shall be established, implemented and maintained. -Administrati.e Procedure A-2 prescribes ;the method for control, issuance, and use of

' documents and revisions.

Paragraph 7.5.1 states that' l controlled copies of documents shall be distributed in accordance with the Controlled Copy Distribution Table.-

. Changes to controlled copies shall be placed in the 1 notebooks.lur the office staf f unless requested otherwise by the> notebook holder.

. Contrary to'the above, on July 2, 1984, the controlled copy of:GP procedu'res,'in the Technical Support Center,, contained-

-GP-2, Rev.135, and GP-18, Rev.

2, when GP-2, Rev. 36, dated 5/18/84-and'GP-18,.Rev.

3,~ dated 12/27/83, should have been

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filed in the notebook.

'This is a Severity Level V Violation (Supplement I)

_ applicable to DPR-44 and DPR-5C.

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. Response 1NRC Inspection Report 50-277/84-08; 50-278/84-08 identified minor nonconformancies in controlled copy procedure notebooks.;

In a ' June 3,.1984 letter, Philadelphia : Electric Company responded to'this violation'by stating the cause of the occurrence,' ensuring-that the inspector identified nonconformancies were corrected, and initiating appropriate

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Mr.' Richard 5W. Starontacki August 31,-1984 Page 5

. corrective action to prevent recurrence, which included clerical-staff' training and procedure revision.

The committed: compliance date for this corrective action was

' July.30, 1984.

As a result of the corrective actions taken to prevent recurrence stated above,-the Technical Support Center (TSC) controlled procedure deficiencies had been identified by-the clerical staff which had begun the process of replacing the out-of-date procedures' prior to'this inspector's-procedure notebook audit.

Philadelphia Electric Company believes that the corrective actions identified in the response to NRC Inspection Report 50-277/84-08; 50-278/84-08 are adequate.

This second apparent violation, identified on July 2, 1984,.of

-individual' controlled procedure book deficiencies occurred because the corrective actions that had been initiated, which must_be applied to a very large number of procedures as well as procedure locations, had not been completed.

Because the TSC controlled procedure notebook deficiencies

-were already identified and were being corrected, and because this second apparent violation waszissued well in advance of the Julyf30, 1984 expected compliance date, Philadelphia. Electric'_ Company' respectfully requests that this apparent' violation be reconsidered.

A seven-day extension of this response was discussed

-with Robert M. Gallo'of your staff and found acceptable.

We regret any inconvenience this late submittal may have caused.

-If4you-require any-additional information, please do not hesitate-to contact us.

Very truly yours, cc:

A. R. Blough, Site Inspector