ML20149D388
| ML20149D388 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 12/28/1987 |
| From: | Johnston W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| NUDOCS 8801120310 | |
| Download: ML20149D388 (2) | |
See also: IR 05000352/1987025
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DEC 2 81987
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Docket No. 50-352
License No. NPF-39
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Phila'delphia Electric Company
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ATTN: Mr. J. W. Gallagher
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Vice President
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Nuclear Operations
2301 Market Street'
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Philadelphia, Pennsylvania 19101
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Gentlemen:
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Subject:
Inspection No. 30-352/87-25
This refers to your letter dated December 9,1987, in response to our letter
dated November 12, 1987.
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Thank you for informing us of the corrective and preventive actions documented
in your letter. We appreciate your timely actions in closing the 40 open
Maintenance Request Forms (MRFs) and in revising Administrative Procedure A-26
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to provide time requirements for closure of the MRF process.
These actions
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will be examined during a future inspection of your licensed program.
Your cooperation with us is appreciated.
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Sincerely,
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William V. Johnston, Acting Director
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Division of Reactor Safety
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cc:
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John S. Kemper, Senior Vice President, Engineering and Production
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G. Leitch, Nuclear' Generation Manager
J. Franz, Manager Limerick Generating Station
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Troy B. Conner, Jr. , Esquire
Eugene J. Bradley, Esquire, Assistant General Counsel
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W. M. Alden, Engineer in Charge, Licensing Section
Public Document Room (POR)
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Local Public Document Room -(LPOR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
Commonwealth of Pennsylvania
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OFFICIAL RECORD COPY
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PHILADELPHIA ELECTRIC COMPANY
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2301 MARKET STREET
P.O. BOX 8699
PHILADELPHI A, PA.19101
1215) t 414000
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December 9, 1987
Docket No. 50-352
Mr. Robert M. Gallo, Director
Chief Projects Branch No. 2
Region I
U.S. Nuclear Regulatory Commission
ATTN:
Document Control Desk
Washington, D.C.
20555
SUBJECT:
Response to Inspection Report No. 50-352/87-25
Dear Mr. Gallo:
Your letter dated November 12, 1987 forwarded Inspection
Report No. 50-352/87-25 for Limerick Generating Station.
Appendix A of the letter addressed an item which does not appear
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to be in full compliance with Nuclear Regulatory Commission
requirements.
The Violation is restated below, followed by our
response.
Restatement of Violation
Technical Specifications Section 6.10, "Records
Retention", requires that records of maintenance activities be
retained.
A-26, Revision 12, "Procedure for Corrective
Maintenance", Section 5.7 requires that completed work packages
(Maintenance Request Forms (MRPs)) be reviewed by the I&C
Cngineer for completeness, signed off and entered into CHAMPS (an
automated system for scheduling maintenance activities and
monitoring equipment history) to show completion of the MRP and
to enter the equipment history.
Contrary to the above, as of October 2,
1987, records of
maintenance activities were inadequately ma.intained in that 16
MRPs which had been completed six months or longer had not
received final review and signoff by the I&C engineer and 24 MRPs
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Mr. Robert M. Gallo
Dacember 9,
1987
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had not been entered into CHAMPS to show completion of the
maintenance activity.
Of these 40 open MRFs, a majority of which
were safety related, CHAMPS indicated four MRFs were open over
two years and 19 MRFs were open (ver one year.
This is a severity Level V violation (10 CPR 2, Appendix
C, Supplement I) applicable to NPP-39.
Admission or Denial of Alleged Violation:
Philadelphia Electric Company acknowledges the
violation.
Reason for the Violation:
Administrative Procedure A-26, Procedure for Corrective
Maintenance, was inadequate in the it did not provide time
requirements for the MRF closure process.
Therefore, MRFs were
not always expeditiously and completely closed.
Extent or Significance of Violation:
The inspection report identified a procedure deficiency
that has not resulted in a significant problem.
Forty MRFs were
identified by the inspector as not properly closed.
As stated in
the notice of violation, 24 MRFs were found not closed on CHAMPS
and the remaining 16 MRFs were completed six months or longer and
had not received final review and signoff by the I&C Engineer.
Since the violation was specifically substantiated by a
review of only I&C MRFs, a full review of MRP closure processing
will be completed by January 8,
1988.
Other areas for improving
MRP processing are being identified and will be part of overall
improvements to the MRP processing system.
Corrective Actions Taken and Results Achieved:
The 40 MRFs were closed in CHAMPS by October 19, 1987.
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The 24 MRFs comp ete except for CHAMPS closure were properly
closed in CHAMPS.
The remaining 16 MRP Packages were assembled,
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reviewed, signed off as complete, and closed on CHAMPS.
Corrective Actions to be Taken to Avoid Future Non-Compliance
A-26, Procedure for Corrective Maintenance, will be
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revised to require that all MRFs will be closed within 6 months
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Mr. Robert M. Gallo
December 9, 1987
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of shift supervision acceptance of the completed work or will be
formally dispositioned and tracked.
The revision of A-26 will be
implemented by February 28, 1988.
To provide information to
management, on MRP closure processing, the-following steps have
been taken:
1.
MRP status reporting has been incorporated into
routine PORC meetings, scheduled biweekly.
2.
MRP status reporting is now included in the
Limerick Unit 1 Monthly Management Review Report to
the Vice President.
Date When Full Compliance Was Achieved
By October 19, 1987 the 40 MRFs identified by the
inspector had been closed in CHAMPS and sent to Nuclear Records
Management.
Very truly yours,
Attachments
cc:
Addressee
h. T.
Russell, Administrator, Region I, USNRC
E.
M.
Kelly, Resident Site Inspector
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