ML20149E139

Notice of Violation from Insp on 970330-0527.Violation Noted:Master Keys Were Not Properly Controlled & Were in Possession of Unauthorized Personnel & Temporary Change to GP12 Altered Intent of Original Procedure

ML20149E139
Person / Time
Site:	Limerick
Issue date:	07/11/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20149E126	List: IR 05000352/1997003 ML20149E121 ML20149E139
References
50-352-97-03, 50-352-97-3, 50-353-97-03, 50-353-97-3, NUDOCS 9707180116
Download: ML20149E139 (2)

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ENCLOSURE 1 l

NOTICE OF VIOLATION

'PECO Enerov Docket Nos. 50-352:50-353 j Limerick Generatino Station License Nos.NPF-39: NPF-85 l Units 1 and 2 i

l l During an NRC inspection conducted during the period March 30 - May 27,1997,

! violations of NRC requirements were identified. In accordance with the " General l Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the l violations are listed below: l A. Units 1 and 2 Technical Specification 6.12.2 requires, in part, that areas accessible to personnel with radiation levels such that a major portion of the body could ,

l receive in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> a dose greater than 1000 mrems shall be provided with locked l

doors to prevent unauthorized entry, and the keys shall be maintained under the l l administrative control of Shift Supervision on duty and/or the health physics supervision.

1 l Contrary to the above, between rnid-1993 and November 1996, grand master keys '

j that could be used to open locked high radiation areas, were not properly controlled l and were in the possession of unauthorized personnel. Specifically, copies of grand l master keys were made and distributed to fire protection personnel by the corporate locksmith and the keys were not under the administrative control of Shift Supervision on duty and/or health physics supervision.

l This is a Severity Level IV violation (Supplement IV).

l l B. Unit 1 Technical Specification 6.8.3 requires, in part, that temporary changes to l procedures of Specification 6.8.1 may be made, provided the intent of the original l procedure is not altered. Technical Specification 6.8.1 requires, in part, that written '

l procedures shall be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Regulatory Guide 1.33 recommends General Plant Operating Procedures for Power Operation and Process Monitoring as activities that should be covered by written j procedures. ]

Contrary to the above, on September 23,1995, a temporary change was made to General Plant Operating Procedure GP-12, Water Chemistry Control Action Plan, l which altered the intent of the origirial procedure. Specifically, GP-12 was changed i to remove a required immediate plant shutdown when Action Level 3 criteria for sulfates was exceeded.

This is a Severity Level IV violation (Supplement 1).

The NRC has concluded that the information regarding the reason for the violations, the corrective actions taken or planned to correct the violations and prevent recurrence, and ,

the date when full compliance was achieved is already adequately addressed on the docket I l

t 9707180116 970711 PDR ADOCK 05000352 G PDR

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- 353/97-01; for the radiological aspects of the key control issue . However, you are l required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to respond, clearly mark your response as a " Reply to a Notice of Violation," and send it to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region l 1, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).

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l Dated this .11th day of July 1997, King of Prussia, Pennsylvania.

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