ML20113E212

Responds to NRC Re Violations Noted in Insp Rept 50-352/84-57.Corrective Actions:Missing Nuts & Bolts on Access Doors Replaced & Program of Routine Monitoring of Closures Established

ML20113E212
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
NUDOCS 8501230353
Download: ML20113E212 (4)

Text

I PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 0

• SHIELDS L. DALTROFF ELEcfm c Paoo on Jcnuary 7, 1985 Docket No. 50-352 Mr. Thomac T. Martin, Director Division of Engineering and Technical Programs U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Pruccia, PA 19406

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 10 CFR 50, Appendix D, states in Criterion V, " Activities, affecting quality shall be preccribed by documented instructionc, procedures or drawings, of a type appropriate to the circumctances and shall be accomplished in accordance with these instructions, procedures or drawings. Instructions, procedures or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that Limerick important activities Generating have been catisfactorily accoupliched".

Station Quality Assurance Plan is written to comply with 10 CFR 50, Appendix D, and reiterates, in Section 5.1, the requirements of Criterion V and cpecifies that they be implenented.

Contrary to the above, at sometime between March 22, 1904 and October 10, 1984, an activity involving the removal and re-inctallation of bolts or nuts for access doors to ducts and plenum of the safety related Control Room Emergency Ventilation System, was performed without procedurec appropriate to the circumstance. As a result of this activity, the system was not properly rectored as evidenced by the following access doors which were found on October 10, 1984 to have missing or loose bolts and/or nuts:

0 $2 h j PDR ,y

-_---__________________a__

Mr. Thomas T. Martin Jttuary 7, 1985 Page 2 Access Door Location Bolts or nuts missing or loose Between 4 of G HV-020B and EV-020D Between 3 of 8 PD-C 013A and EV-010A Between 1 of 8 HV-010B and PD-C 013B Between 1 of 8 UV-020C and EV-020A Upstream of heaters for 1 of 4 OBE-192 This is a Severity Level IV violation, (Supplement II)

RESPONSE

This violation was the result of the failure to completely implement existing procedures. Startty Administrative Procedures AD6.4 "Startup Work Order" (SWO) and AD6.ll "Startup Work Authorization" (SWA) require that the scope of work be properly described and Quality Control (QC) " Hold Points" and "Nitness Points" be established.

In this case, it appears that work on the Heating, Ventilating and Air Conditioning (HVAC) isolation valve actuators required the removal of the accces doors. The SWO's/SWA's for performing this work did not clearly indicate that the access doors were to be removed. As a result of this oversight, the reinstallation of access doors was not properly identified as requiring CC inspection.

The missing nuts and bolts referenced above were replaced and closures were inspected to verify correct installation. An inspection of various elevations and areas throughout the reactor building and the control enclosure was performed to determine if a generic problem existed or if this was an isolated occurrence.

This inspection, which covered approximately 80% of the C-listed ducts containing access doors, revealed one missing nut and one broken stud not previously identified. To prevent recurrence the Engineering & Research Quality Assurance Field Branch Ucad issued a Kotice to the applicable groups performing work at LCS to re-enforce CA Program requirements. Shortly after this problem was identified by the NRC, responsibility for these systems was transferred to the Plant Staff from the Startup organization.

Mr. Thomas T. Martin January 7, 1985 Page 3 Consequently, work that had been controlled by the Startup Administrative Manual and procedures is now being controlled by the Plant Administrative Procedures. In addition, Electric Production QC has established a program of routine monitoring of housekeeping through the use of Quality Control Instructions (CCI) that include LGS-CCI-008 which requires the verification that closures are properly installed and any loose or missing parts are identified. This monitoring is presently performed three times a week.

Should you have any questions or require further information, please contact us.

Very truly yours,

' ] /-

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- fl% t cc: Dr. T. E. Murley, Administrator Mr. J. T. Uiggins, Senior Resident Inspector See Service List

cc: Judge Helen F. Hoyt Judge Jerry Harbour Judge Richard F. Cole Judge Christine N. Kohl Judge Gary J. Edles Judge Reginald L. Gotchy Troy B. Conner, Jr., Esq.

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 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 James Wiggins Timothy R. S. Campbell 4

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