IR 05000352/1998009
| ML20205G230 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/30/1999 |
| From: | Cowgill C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Rainey G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| 50-352-98-09, 50-352-98-9, 50-353-98-09, 50-353-98-9, NUDOCS 9904070177 | |
| Download: ML20205G230 (2) | |
Text
SUBJECT:
NRC INSPECTION REPORT 50-352;353/98-09 AND NOTICE OF VIOLATION - REPLY
Dear Mr. Rainey:
This letter refers to your February 5,1999, correspondence, in response to our January 6,1999, letter.
Thank you for informing us of the corrective and preventive actions documented in your letter.
These actions will be examined during a future inspection of your licensed program.
Your cooperation with us is appreciated.
Sincerely, Original Signed By:
Curtis J. Cowgill, Chief Project Branch No. 4 Division of Reactor Projects Docket Nos. 50-352;50-353
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cc: w/o cv of Licensee Response:
'J. J. Hagan, Vice President, Nuclear Station Support G. Edwards, Chairman, Nuclear Review Board and Director - Licensing J. von Suskil, Vke President - Limerick Generating Station M. P. Gallagher, Plant Manager, Limerick Generating Station T. Moore, Manager, Experience Assessment cc:\\w cv of Licensee Reconse:
Secretary, Nuclear Committee of the Board Commonwealth of Pennsylvania 9904070177 990330
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gDR ADOCK 05000352 hg -
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e Mr. Gerald Rainey
Distribution w/cv of Licensee Response:
Region i Docket Room (with concurrences)
NRC Resident Inspector Nuclear Safety information Center (NSIC)
PUBLIC H. Miller, RA/J. Wiggins, DRA C. Cowgill, DRP D. Florek, DRP C. O'Daniell, DRP M. Tschiltz, OEDO B. Buckley, PD 1-2, NRR M. Thadani, PD 1-2, NRR Inspection Program Branch, NRR (IPAS)
R. Correia, NRR DOCDESK i
DOCUMENT NAME: G:\\ BRANCH 4\\RPLYLTR\\ LIM 9809.WPD To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure
"E" = Copy with attachment / enclosure
"N" = No cepy i
OFFICE Rl/DRP l
Rl/DRP l
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l NAME DCullison W CCowgill N,)A Aw DATE 03/30/99 03/ /99 So'qq 03/ /99 03/ /99 03/ /99 OFFICIAL RECORD COPY
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James C. von Suokil Ves President
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Limench Generating Stit:on
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h PECO NUCLEAR
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nco %, c-en, A Unit of PECO Energy Po Box 2300 sMe 1-1 sanatoga. PA 19464 0920
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610 718 3000 / Fax 610 718 3008 Pager 1800 672 2285 #0271
Intemet address: jvonsuskil@peco-erergycom 10 CFR 2.201 February 5,1999 Docket Nos. 50-352 50-353 License Nos. NPF-39 NPF-85 i
U.S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, DC 20555 SUBJECT:
Limerick Generating Station, Units 1 and 2 Reply to a Notice of Violation NRC Inspection Report 50-352/98-09 and 50-353/98-09 Attached is PECO Nuclear's reply to a Notice of Violation for Limerick Generating Station (LGS), Units 1 and 2, that was contained in your letter dated January 6,1999. The Notice identified one violation involving procedural adherence during dry cask shipment preparation activities. The attachment to this letter provides a restatement of the violation followed by our reply.
If you have any questions or require additionalinformation, please contact us.
Sincerely, M
Attachment cc:
H. J. Miller, Administrator, Region I, USNRC w/ attachment A. L. Burritt, USNRC Senior Resident inspector, LGS
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Att:chment
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Dockst Nos. 50-352 end 50-353
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' ;e February 5 1999 :
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REPLY TO A NOTICE OF VIOLATION Restatement of the Viola * ion
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During an NRC inspection conducted between October 18,1998, and November 30,1998, j
a violation of NRC requirements was identified. In accordance with the " General Statement
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af Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed
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below:
1-L A.
. Technical Specification (TS) 6.8.1 requires, in part, that written procedures shall be
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implemorated covering the activities recommended in Appendix A of Regulatory
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Guide 1.33, Revision 2, February 1978. - Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, requires that maintenance be properly pre-planneo and.
I performed in accordance with written procedures. Licensee Procedure A-C-079, j
" Procedure Adherence and Use," step 7.5.3 requires e,t the user perform each step 5 the sequence specified in a Category Level 1 p..sedure. Procedure M-053-
j 006, "NLl-1/2 Spent Fuel Shipping Cask Preparation and Loading," a Category Level
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1 procedure, steps 5.7.17 through 5.7.28, specifies the sequence for installation of i
the inner cask lid alignment pins.
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Contrary to the above, on November 5,1998, procedure M-053-006, "NLI-1/2 l
. Spent Fuel Shipping Cask Preparation and Loading," required by Appendix A of j
Regulatory Guide 1.33, was not implemented as required by procedure A-C-079.
l Specifically, during the installation of the inner cask lid alignment pins, procedure
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steps 5.7.17 through 5.7.28 were not performed in sequence resulting in a mis-
, laced pin.
p This is a Severity Level IV viola' tion (Supplement 1).
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Roolv to Gw Violation
Admission of the Violation I
PECO Energy acknowledges the violation.
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Reasons for the Violation i.
J I-During the performance of procedure M-053-OO6, "NLl-1/2 Spent Fuel Shipping Cask Preparation and Loading," a PECO Nuclear worker overseeing work being performed by vendor technicians encountered difficulty percrmirg a step associated with removal of the lid fror the unloaded cask. The worker failet :o use appropriate administrative controls to
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change the procedure to reflect the necessary sequence of steps and add guidance to
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Attachment
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Dockst Nos. 50-352 cnd 50-353 February 5,1999
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Page 2 of 2 assure proper placement of two alignment pins. This human performance issue is the resdt of failure of an individual to manage perceived schedule pressure resulting in an j
inappropriate individual worker behavior.
A contributing factor to this event was that Nuclear Maintenance Division (NMD) Reactor Services Section (RSS) management oversight of the planning and preparation phase was i
inadequate resulting in conditions which created an error likely situation. While the unique.
nature of the overall evolution was recognized and the necessary administrative controls
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were applied, interface with the vendors during the planning and preparation phase was
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inadequate. As a result, the implementing procedure contained technical errors that challenged workers in the field.
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Corrective Actions Taken and Results Achieved
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NMD supervision communicated and reinforced expectations for procedure compliance to all workers involved with the activity. In addition, management reinforced expectations for procedure compliance with appropriate NMD parsonnel. This communication emphasized the
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importance of informing supervision when there is a potential problem encountered during
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execution of procedures. This communication also emphasized that individuals must adhere to procedures in a deliberate, conscientious fashion and correct any procedure deficiencies before
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i proceeding, regardless of the impact to the work schedule. Additionally, a detail" procedure review of the implementing procedure was performed Jy PECO Nuclear av
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at the site, and the procedure was revised to incorporate guidance for inste..g the alignment
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pins as well as o%r identified enhancements. Following these correctivs actions, workers
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associated with a cask handling activity demonstrated proper use of plant procedures. Dunng
.eabsequent cask handling activities, workers appropriately stopped work, involved supervision
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and processed procedure changes when necessary.
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Also, as part of an ongoing station-wide campaign to focus on procedure compliance, briefings of
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station work groups have been conducted with emphasis placed on the importance of procedure j
compliance. Proper use of procedures during a recent mini-outage to replace a leaking fuel
bundle is an example of the positive results of this ongoing campaign.
Corrective Actions to Avoid Future Noncompliance NMD management reviewed this work activity and the lessora. 'eamed with NMD RSS personnel.
This review provided for a thorough understanding of the detailed aspects of the procedure i
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i noncompliance and the proceduralinadequacies associated with the activity. In addition, this review focused RSS personnel attention on the less than adequate vendor interface during the l
planning and preparation phase. This action was completed on January 29,1999.
Date When Full Compliance was Achieved
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Full compliance was achieved on November 11,1998, when the cask pins were properly aligned in accordance with the governing procedure.
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