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PHILADELPHIA ELECTRIC COMPANY 23ol MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101
PHILADELPHIA ELECTRIC COMPANY 23ol MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101
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* August 16, 1984 i
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Docket No. 50-352 Inspection Report No. 50-352/84-25 Mr. Thomas T. Martin, Director
August 16, 1984 Docket No. 50-352 Inspection Report No. 50-352/84-25 Mr. Thomas T. Martin, Director Division.of Engineering and Technical Programs U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406
,    Division.of Engineering and Technical Programs
!    U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406


==Dear Mr. Martin:==
==Dear Mr. Martin:==
Your letter of July 17, 1984, T. T. Martin, NRC, to J.
Your letter of July 17, 1984, T. T. Martin, NRC, to J.
S. Kemper, PEco, forwarded Inspection Report No. 50-352/84-25.
S. Kemper, PEco, forwarded Inspection Report No. 50-352/84-25.
Appendix A to your letter addresses an apparent violation of NRC requirements. This item 'is restated below along with our i     response.
Appendix A to your letter addresses an apparent violation of NRC requirements.
Criterion V of 10 CFR 50, Appendix B, requires that activities .affecting quality shall be prescribed by procedures appropriate to- the circumstances and shall be accomplished in accordance with those procedures.
This item 'is restated below along with our i
Administrative Directive 6.1-6, System / Component Turnover to PEco, Paragraph 5.5 states that upon acceptance of the. turnover, Startup personnel will place green tags on equipment within the boundaries of the turnover. and that, at
response.
,    completion of green tagging, no blue construction tags with the exception of NCRs, CRs, identification tags or Bechtel " Red" tags at boundary points shall remain in place. If personnel protection is deemed necessary after turnover, Bechtel Construction safety tags shall be placed on boundary equipment.
Criterion V of 10 CFR 50, Appendix B, requires that activities.affecting quality shall be prescribed by procedures appropriate to-the circumstances and shall be accomplished in accordance with those procedures.
Additionally-PECo safety tags shall be placed on boundary l     equipment included in the' turnover.
Administrative Directive 6.1-6, System / Component Turnover to PEco, Paragraph 5.5 states that upon acceptance of the. turnover, Startup personnel will place green tags on equipment within the boundaries of the turnover. and that, at completion of green tagging, no blue construction tags with the exception of NCRs, CRs, identification tags or Bechtel " Red" tags at boundary points shall remain in place.
!-                  Contrary to the above, on May 24, 1984, it was observed that components such as valves, motor operators, pumps etc., with the exception of. electrical switches and breakers, within the l     boundaries of the Residual Heat Removal Service Water (RHR8W)
If personnel protection is deemed necessary after turnover, Bechtel Construction safety tags shall be placed on boundary equipment.
;    System' Turnover No.1-16A-1(F) completed on May 4,1984, had not 0
Additionally-PECo safety tags shall be placed on boundary l
equipment included in the' turnover.
Contrary to the above, on May 24, 1984, it was observed that components such as valves, motor operators, pumps etc., with the exception of. electrical switches and breakers, within the l
boundaries of the Residual Heat Removal Service Water (RHR8W)
System' Turnover No.1-16A-1(F) completed on May 4,1984, had not 0
L
L


Mr. Thom:3 T. M:rtin                                 August 16, 1984 Pcgo 2 been green tagged nor had blue construction tags been removed.
Mr. Thom:3 T. M:rtin August 16, 1984 Pcgo 2 been green tagged nor had blue construction tags been removed.
In addition, two boundary valves HV-2-12 and HV-2-13, which isolate the RHRSW system from the Unit 2 cooling tower and which were included in the turnover, had Dechtel Construction boundary safety tags in place but the additional PECo safety tags had not boon placed on the valvoo.
In addition, two boundary valves HV-2-12 and HV-2-13, which isolate the RHRSW system from the Unit 2 cooling tower and which were included in the turnover, had Dechtel Construction boundary safety tags in place but the additional PECo safety tags had not boon placed on the valvoo.
This is a Savority Lovel V violation (Supplomont II).
This is a Savority Lovel V violation (Supplomont II).
Responso Based on the results of previous PECo Engincoring & Roccatch Department Quality Assuranco Section auditing of system tagging, it is our belief that inadequate status tagging of this system was an isolated incident.
Responso Based on the results of previous PECo Engincoring & Roccatch Department Quality Assuranco Section auditing of system tagging, it is our belief that inadequate status tagging of this system was an isolated incident.
Upon notification by the NRC, Quality Assurance performed an audit which reaffirmed the situation and resulted in the issuance of an NCR having fivo opon items. The responsible System Startup- Engineer walked down the equipment within the boundation of the RHRSW System Turnover No.1-16A-1(F) and assured that valvos, instruments, switches, and components woro properly tagged and corrected the itoma cited in the NCR. Upon completion, the syntom was walked down again by the Startup Group Supervisor and the System Startup Engincor to verify that all nococcary (groon, blue or safety) tagging was completo and proper.
Upon notification by the NRC, Quality Assurance performed an audit which reaffirmed the situation and resulted in the issuance of an NCR having fivo opon items.
The responsible System Startup-Engineer walked down the equipment within the boundation of the RHRSW System Turnover No.1-16A-1(F) and assured that valvos, instruments, switches, and components woro properly tagged and corrected the itoma cited in the NCR.
Upon completion, the syntom was walked down again by the Startup Group Supervisor and the System Startup Engincor to verify that all nococcary (groon, blue or safety) tagging was completo and proper.
In order to provent recurrence of this isolated incident, the System Startup Engineer (SSE) for the RHRSW System reviewed the Administeativo Directivos (AD 6.1 and AD 2.2) ancociated with turnover tagging and a discusalon was hold to assure that the SSE understood the proceduro. The Startup QC organization also laaued a Startup Training Bulletin (TD No.
In order to provent recurrence of this isolated incident, the System Startup Engineer (SSE) for the RHRSW System reviewed the Administeativo Directivos (AD 6.1 and AD 2.2) ancociated with turnover tagging and a discusalon was hold to assure that the SSE understood the proceduro. The Startup QC organization also laaued a Startup Training Bulletin (TD No.
84-XXXIII, 5/25/84) to Syntom Startup Engincora on the subject of green tagging in order to reinforce previous training and provent further difficultion.
84-XXXIII, 5/25/84) to Syntom Startup Engincora on the subject of green tagging in order to reinforce previous training and provent further difficultion.
If you ohould have any quantions, pleano do not hooltato to contact us.
If you ohould have any quantions, pleano do not hooltato to contact us.
t very truly yours,
t very truly yours, bidy
                                          /       ibidy cc   J.T. Wiggina, Sito Inapoctor Soo Attached Service List l
/
i cc J.T. Wiggina, Sito Inapoctor Soo Attached Service List l


  . , o cca                                           Judge Lawrence Brenner                                                                                   .
, o cca Judge Lawrence Brenner Judge Peter A. Morris Judge Richard F. Cole Troy B. Conner, Jr., Esq.
Judge Peter A. Morris Judge Richard F. Cole Troy B. Conner, Jr., Esq.
Ann P. Hodgdon, Esq.
Ann P. Hodgdon, Esq.                                                                                   l Mr. Frank R. Romano Mr. Robert L. Anthony Maureen Mulligan Charles W. Elliott, Esq.
l Mr. Frank R. Romano Mr. Robert L. Anthony Maureen Mulligan Charles W. Elliott, Esq.
Zori G. Ferkin, Esq.
Zori G. Ferkin, Esq.
Mr. Thomas Gerusky Director, Penna. Emergency Management Agency Angus Love, Esq.
Mr. Thomas Gerusky Director, Penna. Emergency Management Agency Angus Love, Esq.
Line 62: Line 66:
Spence W. Perry, Esq.
Spence W. Perry, Esq.
Jay M. Gutierrez, Esq.
Jay M. Gutierrez, Esq.
Atomic Safety & Licensing Appeal Board Atomic Docket Safety & Licensing
Atomic Safety & Licensing Appeal Board Atomic Safety & Licensing (Board Panel Docket & Service Section 3 copies)
                                                                & Service Section (Board Panel 3 copies)
Timothy R. S. Campbell i
Timothy R. S. Campbell i
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Latest revision as of 07:08, 13 December 2024

Responds to NRC Re Violations Noted in Insp Rept 50-352/84-25.Corrective Actions:Startup QC Organization Issued Startup Training Bulletin Re Green Tagging on 840525
ML20098C734
Person / Time
Site: Limerick Constellation icon.png
Issue date: 08/16/1984
From: Cooney M
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To: Martin T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19292E203 List:
References
NUDOCS 8409270161
Download: ML20098C734 (3)
v • d • e


Text

.

PHILADELPHIA ELECTRIC COMPANY 23ol MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101

)

(ass) set soto

" L*.i.*."l' i

n.e,."T.'."o"%,ll.~~....,

August 16, 1984 Docket No. 50-352 Inspection Report No. 50-352/84-25 Mr. Thomas T. Martin, Director Division.of Engineering and Technical Programs U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406

Dear Mr. Martin:

Your letter of July 17, 1984, T. T. Martin, NRC, to J.

S. Kemper, PEco, forwarded Inspection Report No. 50-352/84-25.

Appendix A to your letter addresses an apparent violation of NRC requirements.

This item 'is restated below along with our i

response.

Criterion V of 10 CFR 50, Appendix B, requires that activities.affecting quality shall be prescribed by procedures appropriate to-the circumstances and shall be accomplished in accordance with those procedures.

Administrative Directive 6.1-6, System / Component Turnover to PEco, Paragraph 5.5 states that upon acceptance of the. turnover, Startup personnel will place green tags on equipment within the boundaries of the turnover. and that, at completion of green tagging, no blue construction tags with the exception of NCRs, CRs, identification tags or Bechtel " Red" tags at boundary points shall remain in place.

If personnel protection is deemed necessary after turnover, Bechtel Construction safety tags shall be placed on boundary equipment.

Additionally-PECo safety tags shall be placed on boundary l

equipment included in the' turnover.

Contrary to the above, on May 24, 1984, it was observed that components such as valves, motor operators, pumps etc., with the exception of. electrical switches and breakers, within the l

boundaries of the Residual Heat Removal Service Water (RHR8W)

System' Turnover No.1-16A-1(F) completed on May 4,1984, had not 0

L

Mr. Thom:3 T. M:rtin August 16, 1984 Pcgo 2 been green tagged nor had blue construction tags been removed.

In addition, two boundary valves HV-2-12 and HV-2-13, which isolate the RHRSW system from the Unit 2 cooling tower and which were included in the turnover, had Dechtel Construction boundary safety tags in place but the additional PECo safety tags had not boon placed on the valvoo.

This is a Savority Lovel V violation (Supplomont II).

Responso Based on the results of previous PECo Engincoring & Roccatch Department Quality Assuranco Section auditing of system tagging, it is our belief that inadequate status tagging of this system was an isolated incident.

Upon notification by the NRC, Quality Assurance performed an audit which reaffirmed the situation and resulted in the issuance of an NCR having fivo opon items.

The responsible System Startup-Engineer walked down the equipment within the boundation of the RHRSW System Turnover No.1-16A-1(F) and assured that valvos, instruments, switches, and components woro properly tagged and corrected the itoma cited in the NCR.

Upon completion, the syntom was walked down again by the Startup Group Supervisor and the System Startup Engincor to verify that all nococcary (groon, blue or safety) tagging was completo and proper.

In order to provent recurrence of this isolated incident, the System Startup Engineer (SSE) for the RHRSW System reviewed the Administeativo Directivos (AD 6.1 and AD 2.2) ancociated with turnover tagging and a discusalon was hold to assure that the SSE understood the proceduro. The Startup QC organization also laaued a Startup Training Bulletin (TD No.

84-XXXIII, 5/25/84) to Syntom Startup Engincora on the subject of green tagging in order to reinforce previous training and provent further difficultion.

If you ohould have any quantions, pleano do not hooltato to contact us.

t very truly yours, bidy

/

i cc J.T. Wiggina, Sito Inapoctor Soo Attached Service List l

, o cca Judge Lawrence Brenner Judge Peter A. Morris Judge Richard F. Cole Troy B. Conner, Jr., Esq.

Ann P. Hodgdon, Esq.

l Mr. Frank R. Romano Mr. Robert L. Anthony Maureen Mulligan 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 3 copies)

Timothy R. S. Campbell i

V I

i l

l I

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