ML20236B113

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Responds to NRC Re Violations Noted in Insp Rept 50-352/87-09.Corrective Actions:Info Re Combustible Matl Control Requirements within Combustible Free Zone Incorporated Into General Employee Training Program
ML20236B113
Person / Time
Site: Limerick Constellation icon.png
Issue date: 07/17/1987
From: Gallagher J
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To: Gallo R
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8707280346
Download: ML20236B113 (3)


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1 PHILADELPHIA ELECTRIC COMPANY-2301 MARKET STREET

! y P.O. BOX 8699 PHILADELPHIA A. PA.19101 (2 51 841500:

JOSEPH W. G ALLAGHER.

July 1*/, 1987-m,.6...

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Docket No. 50-352 Inspection Report:

50-352/67-09 Mr. Robert M. Gallo, Chief Projects Branch No. 2 Division'of Reactor Projects Region I-U.S. Nuclear Regulatory Commission l

ATTN:. Document Control Desk Washington, D.C.

20555

Dear Mr. Gallo:

l Your letter dated June 18,.1987 forwarded Inspection l

Report 50-352/87-09 for Limerick Generating Station.

Appendix A of your letter addresses an item which does not appear to be in

-full compliance with Nuclear Regulatory Commission requirements.

The item of concern is restated below, followed by our response.

Violation:

'10 CFR 50 Appendix B Criterion V requires that'" activities affecting quality shall be prescribed by documented procedures y

and shall be accomplished in accordance with these procedures."

l Administrative Procedure A-12.2, Control of Combustible Materials, prohibits the unattended storage of any comb'ustible I

. material in areas designed as combustible free zones.

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.Contrar.y to the above,'on May 12, 1987, in Area 15 of Reactor Enclosure Elevation 217 (Fire Zone 44), numerous combustible i.

items, equivalent to about two bags of trash, were found l.-

unattended'in a designated combustible free zone.

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This'is a severity level V violation (Supplement I).

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B707280346 870717 F

PDR. ADOCK 05000352 G

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. July 17, 1987.

.Mr.:R..M. Gallo-

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-Response:

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! Admission-o'f1 Alleged' Violation:-

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. Philadelphia Electric Company acknowledges the' violation as.

stated.

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L Reason for the' Violation:

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The reason for~the incident was a personnel error.

Craftsmen-

, working on the construction.of a-temporary control rod drive n

. repair structure in the Combustible Free Zone (CFZ) on elevation L

217' failed to. adhere to posted instructions within the.CFZ, Prohibiting unattended combustible materials.in the CFZ.

The l

combustible materials consisted of fire retardant' treated wood, plastic bags, a cardboard box and rags, with a total combustible 1

. volume of less.than;one cubic-foot.

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_' Significance of Violation:

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'Although the plant. approved procedure' prohibited unattended combustible materials within a CFZ, the amount and location?of the combustible materials did~not present a serious challenge:to-p the'CFZ's ability to perform its intended function.. This. fire 4

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barrier, which separates redundant safe shutdown areas, was not i

significantly degraded.

If a fire were to have occurred in this b

CFZ, the fixed fire. detection system and' suppression systems

- would have provided early warning and activated automatic fire suppression within the affected area.

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Corrective Actions Taken and Results Achieved:

i-L The' combustible materials were removed from the CFZ within one

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half hour of our notification by the NRC inspector.

Quality i

Control' personnel, Maintenance personnel and Fire Protection

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personnel have. increased routine roving inspections of the power L

block for'the~ remainder of the outage, to assure housekeeping and

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fire protection compliance.

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' Meetings between the station's Fire Protection Assistant and the Construction Department' management and Maintenance Department

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management and contracted maintenance supervision and work f.

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Gallo July 17, 1987 i

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foremen were held on May 14, 1987 to stress the importance of adhering to the CFZ requirements.

CFZ requirements were then l

discussed with the craftsmen during the contractor craft weekly j

safety meetings held on May 18, 1987.

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Corrective Actions to be Taken to Avoid Future Non-Compliance:

4 Information regarding the combustible material control requirements within a CFZ will be incorporated into the General Employee Training (GET) program by December 31, 1987.

Administrative Procedure A-12.2, Control of Combustible Materials, will be revised to include more detailed requirements j

for the control of work related combustible materials within a CFZ-and is expected to be completed by August 7, 1987.

Date When Full Compliance Will Be Achieved:

I Full compliance was achieved when the unattended combustible materials were removed from the CFZ.

If you have any questions or require additional information, please do not hesitate to contact us.

j Very truly yours, cc:

W.

T.

Russell, Administrator, Region I, USNRC E.

M. Kelly, Senior' Resident Site Inspector 1

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