ML20082C185
| ML20082C185 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/12/1991 |
| From: | Leitch G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9107180127 | |
| Download: ML20082C185 (7) | |
Text
.
10 CFR 2.201-P PHILADELPHI A ELECTRIC COM PANY i
LIMEHICK GENER ATING ST ATION l
P. O. BOX A l
S AN ATOG A, PENNSYLV ANI A 19464 l
l tai s) 327.i200, ext. sooo July 12, 1991 onamam u. u nes Docket No. 50-353 i
...,c T'.". ll.".'; !!'...,.
License No. NPF-85 U.S.
Nuclear Regulatory Commission Attn: Document Control D0sk Washington, DC 20555
SUBJECT:
Limerick Generating Station, Unit 2 Reply to a Notice of Violation NRC Inspection Report No. 50-352/91-09 and 50-353/91-10 Attached is Philadelphia Electric Company's reply to a Notice of Violation for Limerick Generating Station (LGS) Unit 2, which was contained in the NRC Inspection Report Nos. 50-352/91-09 and 50-353/91-10 for LGS, Units 1 a.d 2, deted June 5, 1991.
Due to delays in finalizing the corrective actions to prevent recurrence, we have requested a seven day extension for responding to this Notice of Violation.
This extension was approved by Mr.
L.
T.
Doerflein, who was contacted on July 3, 1991, at NRC Region I.
This Notice of Violation involves a failure to follow an approved procedure which resulted in failing to maintain material accountability on the Refuel Floor.
This violation was identified during an NRC inspection cenducted between March 24, 1991 through April 27, 1991,-at LGS, Unt :s 1 and 2.
The attachment to th.s letter provides a restatement of the violation followed by our response, l
If you have any questions or require additional information, please contact us.
Very truly yours, m
/
)
i DMS:cah h%
Attachment l
cc:
T.
T.
Martin, Administrator, Region I, USNRC T.
J. Kenny, USNRC Senior Resident Inspector, LGS 9107180127 910712 k
PDR ADOCK 05000352
/
I I
O PDR
/.
- e bec:
D. M. Smith'- 52C-7 G.
M.
Leitch - 200 D. R. Helwig - 63C-1 J.
W.
Durham - S26-1 G. A.
Hunger, Jr.,
- 200 G.
D.
Edwards - AS-1 J. A. Muntz - 336 G. J. Madsen - SB3-4 J.
M.
Madara -'53A-1 R.
R.
Hess - 63B-3 J.
F. O'Rourke - SB4-3 R. J. Lees - 53A-1 G. J. Beck, Jr., - 52A-5 Secretary, NCB - 51A-13 Correspondence Release Point - 340 DAC PA DER BRP Inspector - 234
(
1 l
't l
1 1
, - - _. _.... _ _ -.. _ _ _. - ~. -., _,.,. -,. _ - _ _.. _. _.. ~...., _,,. - - _ - -,
..-_.._..___.2_,,-,a-._,_._.,
_=
Attachment Page 1 of 6 Inspection Report No. 50-353/91-10 Reply to a Notice of Violation Restatement of the Violation During an NRC inspection conducted from March 24, through April 27, 1991, a violation of NRC requirements was identified.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Ap>endix C, the violation is listed below:
Plant Technical Specification 6.8.1 req 2 ires written procedures to be established, implemented and maintained to control various plant activities.
Administrative Procedure A-30, " Plant Housekeeping," Section s
7.3.1 defines the fuel floor as a Housekeeping Zone II when the reactor cavity shield plugs are off or when fuel handling activities i
are being performed.
Section 7.2.2.2 requires material accountability be established for Housekeeping Zone II areas.
Section 7.4.4 requires a " Material Accountability Log," kept at the entrance of the zone, be used to control accountability.
Contrary to the above, on April 4, 1991, material accountability was not being maintained on the fuel floor, a Housekeeping Zone II area, in that there were tools and materials, including slings and shackles, inside the area that were not listed in material accountability log and there were entries in the log such as
" assorted tools" without indication as to the number, type or size.
This is a Severity Level IV violation (Supplement I)
RESPONSE
Admission of Alleged Violation Philadelphia Electric Company (PECo) acknowledges the violation.
._,,_.s.
Attachment Page 2 of 6 Inspection Repcrt No. 50-353/91-10 i
?
Background
1)
NRC Inspection Report No. 50-352/84-64, dated January 21, 1985, identified a violation of Administrative Procedure A-30, " Plant Housekeeping," regarding hcusekceping activities on the refueling bridge.
Specifically, the violation addressed the failure to properly log items into the Material Accountability Logs.
In response to this violation Procedure A-30 was revised to incorporate a proceduralized Material Accountability Log sheet.
2)
NRC Inspection Report Nos. 50-352/90-25 and 50-358/90-24, dated l
December 21, 1990, identified a non-cited violation regarding housekeeping activities on the Refuel Floor.
This non-cited violation identified that lanyards were not being used for restraining items taken into the Refuel Floor Housekeeping Zone and the failure to properly log items on the material accountability log.
This non-cited violated specifically concerned compliance with procedure A-30 as it applied to the r
- N31 performance of activities of Nuclear Maintenance Division (NMD) personnel on the Refuel Floor during the 1990 Unit 1 Refueling y
Outage.
As a result of this violation, NMD management implemented corrective actions which are discussed below.
These deficiencies were reviewed and evaluated in developing the cause and corrective actions associated with the violation described below.
3)
NRC Inspection Report Nos. 50-352/91-09 and 50-353/91-10 dated June 5, 1991, identified a violation for failing to comply with Procedure A-30 in that the Refuel Floor Material Accountability Log was not properly maintained during the Unit 2 1991 refueling outage.
i t
Reason for the Violation r
The root cause of this violation as well as the previous deficiencies i
was that the plant procedure A-30 established to control Refuel Plov:
material accountability did not clearly define the responsibilities and requirements in sufficient detail to ensure that material accountability was adequately implemented and maintained on the Refuel Floor.
Specifically, this procedure did not clearly delineate the scope of I
responsibility assigned to the various work groups ir. e ved in i
activities on the Refuel Floor for overseeing the conttc1 of material-3 accountability on the Refuel Floor.
1 l
,,_7
-ee 9
g
- -r
"-v'
"~T'~'""
x Attachment Page 3 of 6 Inspection Report No. 50-353/91-10 This overall cause contributed significantly *o the cause of the 1991 violation as well as the non-cited violation in NRC Inspection Report Nos. 50-352/90-25 and 50-353/90-24 which applied specifically to the activities of NMD personnel on the Refuel Floor during the Unit 1
1990 Refueling Outage.
NMD Management implemented the following corrective actions in response to the 1990 NRC non-cited violation.
i A dedicated accountability person was assigned to account o
for materials in the Refeel Floor Housekeeping Zones, Individual meetirgs were conducted with all personnel o
assigned to the dousekeeping Zones, stressing the importance of the accounta'aility for loose materials.
Two additional foremen were added to the NMD work crews in o
order to maintair continuous refuel floor supervision.
PECo recognizes, however, that our evaluation of the causes of the deficiencies identified b) the NRC during the 1990 Unit 1 Refueling Outage focused on the activities of NMD personnel only and did not consider broader la ue:.
i.e., the inadequacies of procedure A-30 described above.
Accordingly, the corrective actions taken by NMD management in 1990 would not have precluded recurrence of similar problems by other work groups performing activities on the Refuel Floor.
In addition, for the reasons described below, the corrective actions taken by NMD management during the 1990 Unit 1 Refueling Outage were not effective in preventing recurrence of material
(
accountability deficiencies by NMD personnel performing activities on the Refuel Floor during the 1991 Unit 2 Refueling Outage, A dedicated person accounting for materials in the Refuel o
Floor Housekeeping Zones used during the latter part of the 1990 Unit / Refueling Outage was deemed unnecessary by NMD management for the 1991 Unit 2 refueling outage.
This decision was based on the assumption that the other corrective actions previously implemented raised the awareness of NMD personnel sufficiently to prevent recurrence of material accountability problems, NMD supervision's over-reliance on NMD personnel knowledge a
of procedure A-30 requirements and subsequent adherence to these requirements was inappropriate.
Refuel Floor Housekeeping Zone entry control point barriers o
were inadequate for several reasons.
Control point postings of the housekeeping requirements were ambiguous, difficult to understand, and requirements necessary for transporting items into the controlled areas were not identified.
As a result, the Material Accountability Logs for the Refuel Floor Housekeeping Zones were poorly maintained.
Attachment Page 4 of 6 Inspection Report No. 50-353/91-10 o
The proper level of detail required to specify items entered in the Material Accountability Log to satisfy housekeeping regulrements was not clearly established or emphasized during pre-job briefings.
For example, a " bag of tools" may have been logged, instead of listing the individual tools.
As a result, routine inspections /walkdowns of the Refuel Floor Housekeeping Zones were ineffective, i.e.,
the Material Accountability Log was only checked for completeness as a result if the absence of specific requirements.
Corrective Actions Taken and Results Achieved Since NMD personnel comprise the majority of workers performing essential tasks on the Refuel Floor during refueling operations, the following corrective actions were implemented specifically for NMD personnel.
1.
On April if, 1991, NMD personnel audited the Refuel Floor Material Accountability Logs and inspected the Refuel Floor Housekeeping Zones.
The Material' Accountability Logs were audited, and all items that were improperly accounted for in the Housekeeping Zones were removed.
2.
On April 16, 1991, procedure A-30 Refuel Floor housekeeping requirement briefings were conducted at the beginning of each shift for all NMD personnel performing work on the Refuel Floor.
These briefings reviewed the Procedure A-30 housekeeping requirements for the Refuel Floor, and emphasized the importance of complying with these requirements.
3.
On April 16, 1991,-shift covetage of the Refuel Floor Housekeeping Zones during the 1991 Unit 2 Refueling Outage was implemented by the NMD.
Individuals were posted to ensure that proper completion of the accountability logs was performed, and to ensure that all personnel on the Refuel Floor complied with the applicable housekeeping requirements while refueling activities were in progress.
The shift coverage of the Refuel Floor housekeeping activities was terminated after completion of the Unit 2 Refueling Outage.
.=
Attachment Page 5 of 6 Inspection Report No. 50-333/91-10 The following corrective actions were implemented for NMD and non-NMD personnel who perform activities on the Refuel Floor.
1.
A Shift Training Bulletin (STB) detailing the Refuel Floor housekeeping requirements was developed and reviewed at the Unit 2 Reactor Reassembly pre-job meetings conducted on May 1, 1991, and May 2, 1991.
The 123 individuals from various plant groups who attended the meetings were given a copy of the STB.
Following these briefings, all attending personnel signed a verification sheet indicating that they had read and understood the STB.
In addition, copies of the STB and verification sheets were posted at the Refuel Floor Housekeeping Zone entry control points for plant personnel who did not attend the meetings to read and sign prior to entering a particular Refuel Floor Housekeeping Zone.
This STB was removed from the control points after the Unit 2 Refueling Outage was completed.
2.
A 'For Your Information (FYI) Notice,' addressing the Refuel Floor housekeeping requirements, was developed and distributed in accordance with Administrative Guide AG-94, "For Your Information Program," to first line supervision on May 10, 1991.
This FYI notice described the housekeeping requirements for the Refuel Floor and directed all plant personnel to comply with these requirements.
FYI notices are used as a means to convey Plant Management expectations on certain issues, and to provide a means for employee feedback.
FYI notices are given to first line supervision of applicable work groups for dissemination of' information to plant personnel in order.to heighten their awareness on specific plant issues.
Corrective Actions Taken to Avoid Future Non-Compliance i
The following corrective actions will be impleganted in order to prevent recurrence of similar housekeeping deficiencies during future refueling outages.
1.
Procedure A-30 will be revised and/or a new procedure will be developed and implemented detailing the Refuel Floor Housekeeping Program responsibilities, requirements, and expectations.
This action is expected to be completed and implemented by September 30, 1991.
2.
The Refuel Floor Housekeeping Zone entry control points will be modified to strengthen Refuel Floor housekeeping activity control.
Physical changes and supporting administrative controls will be implemented to ensure that the Refuel Floor housekeeping requirements are complied with during future refueling outages.
These corrective actions are expected to be completed by September 30, 1991.
Attachment Page 6 of 6 Inspection Report No. 50-353/91-10 s
3.
A FYI notice addressing items 1 and 2 above will be developed and distributed to first line supervision by October 15, 1991.
Additionally, General Employee Training (GET) will be updated by November 31, 1991 to include a discussion of this violation and the corrective actions taken.
4.
In order to ensure overall accountability is maintained, signs will be posted on or adjacent to all entrance doors leading into the Refuel Floor area requiring all plant personnel to contact NMD prior to entering a housekeeping zone or performing any work activities on the Refuel Floor.
This is expected to be completed by August 31, 1991.
To ensure that the housekeeping requirements of Procedure A-30 are being complied with for other areas of the plant similar to the Refuel Ploor (i.e., Suppression Pool), the following corrective action will be completed.
5.
Procedure A-30 for plant housekeeping will be reviewed to determine if weaknesses exist for other areas of the plant, and appropriate actions will be developed and implemented as necessary.
This item is expected to be completed by September 30, 1991.
Date When Full Compliance was Achieve _d_
Full compliance was achieved on April 16, 1991, when the Material Accountability Control Logs were audited, and all items that were improperly accounted for in the Refuel Floor Housekeeping Zones were removed.
~
...-___--__m.
- - - - - -