ML20115C035
| ML20115C035 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/08/1996 |
| From: | Walter MacFarland PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9607110147 | |
| Download: ML20115C035 (4) | |
Text
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- iv /YC'O f a !.a Sanroca FA 19464 0920 610 718 3000 Fax 610 718 3008 Pager 1800 672 2285 # 8320 10 CFR 2.201 July 8, 1996-Docket Nos. 50-352 50-353 i
License Nos. NPF-39 NPF-85 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 i
SUBJECT:
Limerick Generating Station, Units 1 and 2 Reply to a Notice of Violation NRC Combined Inspection Report Nos. 50-352/96-03 and 50-353/96-03 Attached is the PECO Energy Company reply to a Notice of 1
Violation for Limerick Generating Station, Units 1 and 2, that was contained in your letter dated June 13, 1996.
The violation concerned the failure to maintain temporary plant alterations (TPAs) in accordance with procedures, and to establish appropriate criteria to-ensure that operators were 1
cognizant of currently installed TPAs.
The attachment to this letter provides a restatement of the violation followed by our reply.
If you have any questions or require additional information, please contact us.
Very truly yours, 1
J Wal er G.
MacFarland,IV Attachment cc:
T. T. Martin, Administrator, Region I, USNRC w/ attachment N.
S.
Perry, USNRC Senior Resident Inspector, LGS l
.l 9607110147 960708 PDR ADOCK 05000352
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<\\s
t Attachment i
Docket.Nos. 50-352 and 50-353 i
July 8, 1996 l
Page 1 of 3 Reolv to a Notice of Violation Restatement of the' Violation During an NRC inspection conducted April 22 through'May 3,
- 1996, a violation of NRC requirements was. identified.
In accordance I
with the " General Statement of Policy and Procedure for NRC
]
Enforcement Actions," NUREG-1600, the violation is listed below:
10;CFR Part 50, Appendix B,-Criterion V,
" Instructions, Procedures, and Drawings," states, in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings...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 important activities have been satisfactorily accomplished."
Contrary to the above, activities affecting quality were.not accomplished in accordance with procedures, in that on May 3, 1996, the NRC identified that PECO Energy failedcto perform Temporary Plant Alterations (TPAs) in accordance with controlled procedure MOD-C-7, Revision 1, and failed to' establish appropriate criteria to ensure that an-important activity, ensuring operator awareness of currently installed TPAs, was.
satisfactorily accomplished.
This is a severity level IV violation (Supplement I).
RESPONSE
Admission of the Violation j
PECO Energy Company acknowledges the violation.
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i Reason for the Violation The cause of the failure to maintain a hard copy of the TPA packages in the MAIN Control Room (MCR) files was failure to follow procedure due to personnel error.
Procedure MOD-C-7,
" Temporary Plant Alterations (TPAs)," Revision 1, requires that a j
copy of the Engineering Change Request (ECR), associated attachments, and the original TPA Tagging and Approval Form be' filed in the MCR once the. installation is completed.
'As indicated in the associated NRC' inspection report, copies of the
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4 Attachment Docket Nos. 50-352 and 50-353 July 8, 1996 Page 2 of 3 ECR packages were missing from the MCR files for a few TPAs.
The investigation into this event was unable to determine whether the copies of the ECR packages were never placed in the MCR file or were lost once they had been filed.
A contributing factor is procedure MOD-C-7 does not clearly delineate who has the responsibility to ensure the ECR package is appropriately filed.
The cause of the Shift Manager's difficulty in determining the current status of the TPAs was a less than adequate method for l
tracking installed TPAs.
Operations relied upon the ECR packages filed in the MCR along with a computer printout to track active TPAs.
However, the computer printout provided potentially inaccurate information in that it listed all " approved" TPAs, some of which may not have been installed in the plant.
l Therefore, without the copy of the ECR package in the MCR file, i
the status of the TPA could not adequately be determined from the MCR.
A contributing factor was the lack of procedural l
requirement for a formal method, other than the files in the MCR, l
to track installed TPAs.
Corrective Actions Taken and Results Achieved l
Copies of the missing ECR packages for the installed TPAs were l
placed in the MCR TPA file, and copies of the ECR packages for all other installed TPAs were verified to be in the file.
- Also, l
the method for MCR logging of installed TPAs was changed from a computer based system to a paper based system, and the paper based log was verified to accurately reflect all installed TPAs.
l A Shift Night Order (SNO) was issued to ensure that Operations personnel were aware of the revised method for identifying the l
current status of installed TPAs.
The owner of the TPA program l
instructed the Shift Operations Assistant on the proper maintenance of the log.
An Engineering self-check item was issued reminding Engineering personnel of the need to ensure that copies of all TPA ECR packages are placed in the MCR file.
The revised logging method, along with the MCR file, was assessed l
twice following this incident with no problems identified.
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Corrective Actions to Avoid Future Noncomoliance A more effective mechanism for tracking installed TPAs will be developed.
Procedure MOD-C-7 will be revised to incorporate the associated tracking controls, and to more clearly define who has the responsibility for ensuring that hard copies of the installed TPAs are placed in the MCR file.
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a Attachment Docket Nos. 50-352 and 50-353 July 8, 1996 Page 3 of 3 l
Other programs that require logging information in the MCR will be reviewed to ensure the completeness of information provided
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and appropriateness of the logging controls.
Date When Full Comoliance was Achieved Full compliance was achieved on May 3, 1996, when the missing ECR packages for the installed TPAs were placed in the MCR file, copies of ECR packages for all other installed TPAs were verified to be in the MCR file, and Operations was made aware of the status of all installed TPAs.
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