ML20043G133

Responds to NRC 900614 Ltr Re Violations Noted in Insp Repts 50-352/90-13 & 50-353/90-12.Corrective Actions:Boxes of Completed Procedures Improperly Stored Shipped to Util Storage Vault by 900406

ML20043G133
Person / Time
Site:	Limerick
Issue date:	06/14/1990
From:	Mccormick M PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9006190102
Download: ML20043G133 (5)

Text

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PHILADELPHIA ELECTRIC COM PANY LIMERICK GENER ATING ST ATION P. O. BOX A SAN ATOG A, PENNSYLV ANI A 19464 (23s) 3271200 amt 2000 June 14, 1990 M. J. M cC O ft M IC K. Ja. P,E.

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Docket No. 50-352 License No. NPF-39 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 ,

SUBJECT:

Limerick Generating Station, Unit 1 Reply to a Notice of Violation NRC Inspection Report No. 50-352/90-13 and 50-353/90-12

Dear Sirs:

Attached is Philadelphia Electric Company's reply to a Notice of Violation for Limerick Generating Station (LGS) Unit 1, which was ccntained in NRC Inspection Report No. 50-352/90-13 and 50-353/90-12 for LGS, Units 1 and 2, dated May 7, 1990. Due to a delay in receiving this Inspection Report, we requested an extension to June 14, 1990, for responding to this Notice of Violation. This extension was approved by Mr. L. T. Doerflein, NRC Region I, on June 5, 1990.

This Notice of Violation pertains to the failure to properly  ;

control documents affecting quality and was identified during an NRC '

inspection conducted between March 6 and April 9, 1990, at LGS Units '

1 and 2.

The attachment to this letter provides a restatement of the violation followed by our response. It was also requested that we-address the discrepancies discussed in Section 10 of this Inspection Report. These discrepancies are addressed in the attached Reply to the Notice of Violation.

If you have any questions, or require additional information please contact us.

Very truly yours, QS .

t .

DMSicah Attachment cc: T. T. Martin, Administrator, Region I USNRC T. J. Kenny, USNRC Senior Resident Inspector, LGS

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• PSg3 1 of 4 Inspection No. 50-352/90-13 Reply to a Notice of Violation Restatement of the Violation As a result of an inspection conducted on March 6 - April 9, 1990, and in accordance with NRC Enforcement Policy (10 CPR 2, Appendix C),

the following violation was identified.

10 CFR 50, Appendix B, Criterion VI, "DocumH?t Contrs1," '

requires that measures be established to control the issuance of procedures, including changes, which prescribe all activities affecting quality, and that these procedures, including changes, are distributed to the location where the prescribed activity is performed. These requirements are implemented by Administrative Procedure A-2, " Control of Procedures and Certain Documents."

Contrary to the above, on March 30, 1990, the Construction Building controlled proced res were found to not be maintained

, per A-2 in that there wer- Obsolete procedure revisions, missing l

procedures, misfiled proceoures and a missing volume of procedures.

l l This is a Severity Level V violation. (Supplement I) l RESPONSE 1

l ' Admission of Alleged Violation Philadelphia Electric Company (PECo) acknowledges the violation.

Background

From March 6, 1990, to April 9, 1990, the Limerick Generating Station (LGS) NRC Resident Inspectors conducted an inspection of the Document Control and Records Retention Programs for LGS. During their inspection, they issued one violation related to the Document Control Program. This violation concerned missing and misfiled controlled procedures, incorrect revisions of controlled procedures, and missing controlled procedure books identified in the Controlled Document Locations (CDL). Additionally, the ?rspectors identified discrepancies with the Records Retention Progr.im in that boxes of completed procedures were improperly stored, 11spection of the PECo storage vault was not being properly performed, and periodic testing of the Bechtel storage vault fire protection s / stem was not being performed at the established frequency.

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Inspection No. 50-352/90-13 Reason for the Violation The cause of this violation as well as the identified discrepancies is the result of two principal factors. The first principal factor was insufficient management oversight to ensure that comprehensive programs existed in the areas of Document Control and Record Retention. The second principal factor was that the administrative controls were inadequate to ensure an effective ,

controlled document usage and handling process.

Corrective Actions Taken and Results Achieved '

After Plant Management was notified on March 30, 1990, by the NRC Resident Inspectors of the violation and discrepancies for the Document Control and Records Retention Programs, the following immediate corrective actions were implemented.

o On March 31, 1990, a review of six of the largest CDLs at LGS was initiated. Approximately one-third of the procedures in these CDLs were reviewed to determine the extent of the problem.

Deficiencies similar to those cited in the violation were identified in each CDL. Therefore, on April 2, 1990, a complete audit of all CDLs located at LGS was initiated. All CDLs were audited, and updated, and the discrepancies were corrected by May 10, 1990, o On April 12, 1990, a letter was issued from the LGS Support Manager, responsible for Document Control, to all LGS personnel providing instructions on the proper use and handling of the .

controlled documents in the CDLs.  ;

o On April 23, 1990, a letter was issued frcr the Support Manager to Site Management requesting their assistance to ensure the proper use of all contro] led documents within their departments at LGS.

o The boxes of completed procedures which were improperly stored were shipped to the PECo storage vault by April 6, 1990.

Corrective Actions to Prevent Recurrence To assure adequate oversight of all controlled documents at LGS, the following administrative controls and corrective actions will be implemented and completed. These corrective actions will prevent recurrence of the violation as well as the discrepancies addressed in Section 10 of this Inspection Report.

o A random sampling methodology is being developed using Military Standard 105, " SAMPLING PROCEDURES AND TABLES FOR INSPECTION BY ATTRIBUTES." This periodic random sampling methodology will be

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performed on all the CDLs and will identify specific I deficiencies, potential problem areas, and adverse trends an a timely manner. Follow up actions will be developed for errors  ;

identified during the periodic random sampling based on the i number and the severity of the errors. A procedure will be  !

written to ensure this periodic random sr.upling methodology is i performed on an established frequency. An " Administrative Guideline" (AG) will be written to describe how to perform the periodic random sampling methodology. The AG will be ,

implemented through the above procedure. This random sampling methodology will be implemented by August 31, 1990. In the interim, a second complete audit of all CDLs is currently in progress. This audit was initiated to provide additional l assurance that all CDLs are being adequately maintained. This i audit is expected to be completed by July 31, 1990.

l This random sampling would identify discrepancies of the type I l identified in a previous Violation, 50-353/89-81-01. However, l l the corrective actions taken in response to that violation would l l not have prevented the discrepancies identified in this l violacion frca occurring, o On April 2, 1990, the Document Administration Center (DAC) supervisor was reassigned to a staff fur.ction outside of the Document Control and Records Retention Program areas. The DAC supervisor was replaced on an interim basis by the l Superintendent-Administration until a permanent replacement l could be established. On May 21, 1990, a new DAC supervisor was  ;

L appointed to assume the DAC responsibility. The new DAC supervisor previously worked at LGS as the Bechtel Document Control supervisor and has eleven years experience in this o field. This individual will provide enhanced management oversight of the Document Control Program needed to ensure that these discrepancies will not recur.

o Administrative guidance for all LGS personnel will be issued by July 31, 1990, to provide additional direction on the use and 1 handling of controlled procedures.

o General Employee Training (GET) will be revised to include a segment which emphasizes the responsibilities of all LGS ,

personnel for proper use and handling of controlled procedures. I The additional administrative guidance referenced above will also be addressed in this training. This item will be implemented by August 31, 1990.  ;

1 o A review of the current Document Control and Record Retention l Programs is presently being performed by the new DAC supervisor.

After this review is completed, a reference manual describing the DAC functions, responsibilities, and training requirements will be developed and reviewed with all current and future DAC l personnel. Thja maneal will be controlled and periodically l 1

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POg3 4 of 4 Inspection No. 50-352/90-13 i

reviewed by the DAC supervisor. This item will be completed and implemented by December 31, 1990.

o A revision to Administrative (A) Procedure A-46, " Maintenance of Plant Quality Assurance Records," and a new procedure A-46.1,

" Nuclear Records Management," will be issued by June 29, 1990.

These procedures provide additional clarification on the Record Retention Program processes and define the responsibilities of the DAC personnel and of the personnel who interface with the DAC personnel regarding the storage of controlled documents.

o Quarterly inspection of the PECo storage vault was a responsibility of the previous DAC supervisor who was reassigned on April 2, 1990, as a result of the previous document control problems. This function is now the responsibility of a clerk under the direction of the new DAC supervisor. The issue regarding this Inspection Report was reviewed and discussed with the new supervisor and clerk to stress the importance of performing inspections in accordance with all procedures.

o Control of the Bechtel storage vault fire protection system has been fully assumed by the LGS Fire Protection group. A procedure will be issued by July 31, 1990 to assure that the fire protection system for this vault will be properly tested on an established frequency.

o Previous Violations 50-352/87-05-01, and 50-352/87-19-01, and Section 2.2 of Inspection Report 50-352/90-02, discuss discrepancies with Category I red-lined (as-built) drawingc.  !

This sub group of drawings is controlled by the Modification Coordination Section with procedure A-6, " Control and Distribution of Drawings, Manuals, and Drawing Logs," rather than the DAC personnel with procedure A-2. Because of this, the corrective actions identified for these items would not have precluded this violation from occurring.

Date When Full Compliance W:s Achieved .

I Full compliance was achieved after all the CDLs at LGS were audited, and updated, and the discrepancies were corrected on May 10, 1990.  :

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