ML20101T124
| ML20101T124 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 01/07/1985 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| CON-#185-122 OL, NUDOCS 8502050834 | |
| Download: ML20101T124 (4) | |
Text
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RELAT:D CC.TZ:PONDENC" t
PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101
[ y SHIELDS L. DALTROFF j
m I#."*""%
January 7, 1985
.c Docket No. 50-352 i
Mr. Thomas T. Martin, Director Division of Engineering and Technical Programs U.S. Nuclear Negulatory Commission Region I
$31 Park Avenue y g OL King of Prussia, PA 19406 b, c ;,
- [(),3d.6 3 O b Dear Mr. Martin Your letter of December 10, 1984, forwarded the results of Inspection No. 50-352/84-57 which cited an activity at our Limerick Generating Station which did not appear to be in full compliance with NRC requirements.
This apparent violation is restated below followed by our response.
Finding u
10 CFR 50, Appendia B, states in Criterion V, " Activities affecting quality shall be prescribed by documented instructions, j
procedures or drawings, of a type appropriate to the eircumstances and shall be accomplished in accordance with these i
ll instructions, procedures er drawings.
Instructions, procedures f
or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished".
Limerick Generating I
station Quality Assurance Plan is written to comply with 10 CFR 50, Appendix 3, and reiterates, in Section 5.1, the requirements of Criterion V and specifies that they be implemented.
Contrary to the above, at sometime between March 22, 1984 and l
October 10, 1984, an activity involving the removal and re-installation e( bolts or nuts ter access Geors to dents and plenum of the tafety related control moon mergency ventilation Bystem, was performed without procedures appropriate to the aircumstance.
As a result of this activity, the system was not properly restored as evidenced by the following access doors y
1 which were found on October 10, 1984 to have missing or loose
]
bolts and/or auts:
1 8502050834 850107 PDR ADOCK 05000352
'i G
Mr. Thoaac T. Martin Jcnuary 7, 1985 Page 2
&ccess poor Location Bolts or nuts missing or loose J
Between 4 of 8 NV-020s and EV-020D setween 3 of 8
'l 3D-C 013A and NY-010A Between 1 of 8 NV-010B and PD-C 013B 1
4 Between 1 of 8 EV-020C and EV-020h Wystream of heaters for 1 of 4 085-192 This is a Severity Level IV violation, (Supplement II)
RESPONSE
This violation was the result of the failure to completely implement esisting procedures.
Startup Administrative Procedures AD6.4 'Startug W(ork Order" (SWO) and AD6.11 "Startup Work Authorisation SWA) require that the scope of work be properly described and Quality control (QC)
- Bold Points" and
- Witness points" be established.
In this case, it appears that work on the Beating, ventilating and Air Conditioning (EVAC) isolation valve actuators regstred the removal of the assess doors.
The SWO's/SER's for pe'rforming 4
this work did not clearly ladicate that the mooess doors were to be removed. -As a. result of this oversight, the reinstallation of access. doors was not prayerly_ identified as requiring QC inspection.
l The missing sats and bolts referenced above were replaced and closures were inspected to verify correct installation.
An inspecties of Varises elevattens and areas'throeghout the reactor buildi and 'the esoteel ecolosure was pe) formed to determine if a gone Jet; At this was am lated seescremoe.
This (em,
,espered @ esiastely of the't= listed ducts stataining G enes'48ers, revealed one missing met and one broken sted met providualy 196stified. D prevent resurrence the Engineerlag & Researob gaelity Assurance Field Branch Nead issued a motice to the a p liemble groups performing work at ses to re-enfort.a O& Program requirseents.
Eibertly af ter this problem was identified by the MC, ansponsibility for these systems was j
transferred to~tte Plant Staff from the Startup organisation.
i
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Mr. Thomas T. Martin Jcnuar) 7, 1985 Page 3 Consequently, work that had been controlled b) the Startup Administrative Manual and procedures is now being controlled b) the Plant Administrative Procedures.
In addition, Electric
.Eroduction QC has established a program of routine monitoring of housekeeping through the use of Quality Control Instructions q
(QCI) that include LGS-QCI-008 which requires the verification that closures are properly installed and any loose or missing parts are identified.
This monitoring is presently performed r
three times a week.
Should you have any questions or require further information, please contact us.
Very truly yours, gMainal signed by 8 I:. IRLTROFE cca Dr. T. E. Murley, Administrator Mr. J. T. Wiggins, Senior Resident Inspector See Service List 9
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cc: Judge Helen F. Hoyt Judge Jerry Harcour Judge Richard F. Cole Judge Christine N. Kohl l
Judge Gary J. Edles Judge Reginald L. Gotchy z
Troy B. Conner, Jr., Feq.
Ann P. Hodgdon, Esq.
Mr. Frank R. Romano Mr. Robert L. Anthony Ms. Phyllis Zitzer Charles W. Elliott, Esq.
Zori G. Ferkin, Esq.
Mr. Thomas Gerusky Director, Penna. Emergency Management Agency Angus T. ave, 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 James Wiggins Timothy R. S. Campbell l
l e
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