ML20086B861
| ML20086B861 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 11/18/1991 |
| From: | Leitch G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9111210079 | |
| Download: ML20086B861 (7) | |
Text
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10 CPR 2.301 I
PIIILADELPhilA ILECTRIC COMPANY LIMERICK GENERATING STAT 10N P. O. IlOX 2300 ICITUIGVN, PA 19464-0920 nm r 18, 1H1 (215) 327 1200. EXT. 3000 Docket Nos.
50-352 GnAHAM M t.EROi 50-353 uutn[IocEiwSIswcw License No3. NPP-39 NPF-85 U.S. Nuclear Regulatory Conunission Attnt Document Control Desk Washington, DC 20555
SUBJECT:
Limerick Generating Station, Units 1 and 2 Reply to a Notice of Violation NRC Inspection Report Nos. 50-352/91-16 and 50-353/91-17 Attached is Philadelphia Electric Company's reply to a Notice of Violation for Limerick Generating Station (LGS) Units 1 and 2, which was contained in the NRC Inspection Report Nos. 50-352/91-16 and 50-353/91-17 c'sted October 11, 1991.
The Notice of Violation involves failure to effectively implement corrective actions to a previous NRO violation (50-353/91-10-03).
The previous violation identified a failure to maintain material accountability in the refuel ficor Housekeeping Zones as required by an approved administrative procedure.
The attachment to this letter provides a restatement of the violation identified during an NRC inspection conducted between July 16, 1991, through August 31, 1991, at LGS, Units 1 and 2, followed by our response.
This letter and its attachment cupersedes our response to NRC violation 50-353/91-10-03 included in NRC Inspection Report Nos. 50-352/91-09 and 50-353/91-10.
If you have any questions or require additional information, please contact us.
Ver ul
- yours, W azd e
JLPicah Attachment cc T. T. Martin, Administrator, Region I, USNRC T. J. Kenny, USNRC Senior Resident Inspector, LGS
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Attachment Page 1 of 6
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Inspection Report Nos. 50-352/91-16 50-353/91-17 i
Reply to a Notice of Violation Restatement of the Violation During an NRC inspection conducted from July 16, 1991, through August 31, 1991, a violation of NRC requirements was identified.
In accordance with the " General Statement of Policy and Procedure t
for NRC Enforcement Actions," 10 CPR Part 2, Appendix C (1991),
the violation is listed below:
10 CPR PartL50, Appendix B, Criterion XVI, Corrective Action, and the Philadelphia Electric Company Quality Assurance Plan require
-that measures.be established to assure that conditions adverse to quality are promptly identified and corrected.
In the case of a significant condition adverse to quality, the measures shall assure that the cause of the condition is determined and i
corrective action taken to preclude repetition.
Contrary to the above, as of August 29, 1991, the licensee had not effectively implemented corrective action to previous NRC violation (50-353/91-10-03) for failure to maintain material accountability in the refuel floor Housekeeping Zones as required by Administrative Procedure A-30, " Plant. Housekeeping."
'Specifically,.various items were noted in the Unit 2 refuel floor Housekeeping Zone which were not logged in the material accountability log, items previously logged into the Unit 1 l
-Housekeeping Zone had been removed but not logged out of the area, and logging of semi-permanent equipment was not consistent between the Unit 1 and Unit 2 Housekeeping Zones.
This is a Sevtrity Level IV violation (Supplement I).
Response
Admission of Alleged Violation Philadelphia Clectric Company (PECo) acknowledges the violation.
Background
1)
NRC Inspection Report No. 50-352/84-64, dated January 21, 1985, identified a-violation of Administrative Procedure A-30,
" Plant Housekeeping," regardity brusekeeping activities on-the refueling bridge.. Specifically, che violation addressed the failure to properly log items into the Material Accountability t
Logs.
l L
Attachment Page 2 of 6 Inspection Report Nos. 50-352/91-16 50-353/91-17 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 50-353/90-24, dated December 21, 1990, identified a non-cited violation regarding housekeeping activities on the Refuel Ploor.
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 violation specifically concerned compliance with procedure A-30 as it applied to the performance of activities of Nuclear Maintenance Division (NMD) personnel on the Refuel Floor during the 1990 Unit 1 Refueling Outage.
As a result of this violation, NMD management implemented corrective actions which focused on the activities of NMD personnel only and did not consider broader issues.
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.
On April 16, 1991, in response to this violation, NMD implemented corrective actions to achieve full compliance.
Other corrective actions to prevent recurrence of similar material accountability deficiencies during future refueling outages were in the process of being implemented when the nonconformance on August 29, 1991, was identified.
Reason for the Violation There are several factors that resulted in a failure to
-3 effectively implement corrective actions following the previous NRC violation.
Corrective actions to prevent recurrence for the causes of the previous NRC violation were not fully implemented when the deficiency in August 1991 was identified.
Thr immediate corrective actions that had been taken were not adequate to prevent recurrence of the deficiency until the long term corrective actions were to be completed.
Additionally, the root cause investigation did not identify all of the causal factors for the previous deficiency; therefore, comprehensive, thorough corrective actions and actions to prevent recurrence were not identified.
While the long-term corrective actions were being implemented, responsible management did not ensure adequate short-term actions were being implemented to prevent a similar deficiency.
As a result, the causes of the previous violation again contributed to refuel floor material accountability problems.
Attachment Page 3 of 6 Inspection Report Nos. 50-352/91-16 50-353/91-17 As a result of the deficiency identified in August 1991, a separate formal Root Cause Analysis (RCA) was performed which identified causal factors for this material accountability violation.
The following causes of this violation were also identified to be causes for the violation included in NRC Inspection Nos.
50-353/91-09 and 50-353/91-10:
o Less than adequate establishment / maintenance of refuel floor material accountability access control points and housekeeping zone boundaries.
o Less than adequate administrative procedures for material accountability at both the LGS and Peach Bottom Atomic Power Station (PBAPS) facilities.
Plant procedure A-30 did not define the responsibilities and requirements in sufficient detail to ensure that material accountability was adequately implemented and maintained on the refuel floor.
These unclear procedures created confusion for NMD personnel who worked at both facilities by using different terminology and material accountability requirements, such as the degree of detail required when logging material into a material accountability area.
The RCA identified the following additional causal factors for this violations o
Less than adequate turnover between various NMD refuel floor teams in that the turnovers were often informal which resulted in specific refuel floor material accountability concarns not being adequately addressed, o
Less than adequate familiarity with procedure A-30, " Plant Housekeeping," on the part of personnel working on the refuel floor due in part to insufficient training.
Less than adequate individual accou.)ntability sensed by o
personnel working on the refuel floor to comply with procedure A-30, as well as to question parts of procedure A-30 which were unclear.
As a result, personnel failed to follow procedure A-30.
o Less than adequate supervisory oversight of NMD personnel activities to ensure compliance with refuel floor material accountability requirements.
The lack of a clearly defined individual or organization as a single point of accountability for refuel floor material accountability issues also contributed to the problem.
o Less than adequate communication to site and NMD personnel of expectations relative to refuel floor material accountability.
A clear concise, consistent set of expectations of refuel floor material accountability, either verbal or written, did not exist.
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Attachment Page 4 of 6 I
Inspection Report Nos. 50-352/91-16 50-353/91-17 Corrective Actions Taken and Results Achieved l
I Once notified of the repeat deficiency, station management took immediate action to prevent a near-term recurrence until a formal RCA could be completed and adequate corrective actions implemented.
These immediate actions included the following:
1.
The LGS Vice President issued a stop work order for NMD personnel performing tasks on the LGS refuel floor on August 29, 1991.
2.
Signs at the entrance to LGS Unit 1 and Unit 2 refuel floors were posted on August 29, 1991, indicating that no work was to be performed without prior notification of NMD Supervision.
3.
On August 30, 1991, NMD management met with LGS management and developed an action plan.
4.
A separate, formal HCA was initiated to identify causal factors and to develop corrective actions to prevent a repeat occurrence.
As a result of the above identified action plan and RCA, the following corrective actions were implemented:.
1.
On September 4, 1991, a refuel floor housekeeping awareness i
meeting was conducted between NMD and Str.;1on management and NMD Reactor Services work force (i.e., the principal NMD organization performing refuel floor activities.)
The purpose i,
of the meeting was to provide clear expectations regarding housekeeping and-material accountability requirements.
2.
Detailed inventories were conducted for the material accountability zones surrounding the LGS spent fuel pools.
The associated A-30 material accountability zones were updated accordingly after any noted deficiencies were reconciled.
These actions were completed-on September 6, 1991.
3.-
NMD management conducted several day long meetings with NMD foremen and job leaders to clearly specify expectations relative to refuel floor material accountability.
Among other pertinent issues, procedural compliance, individual accountability,-proper-turnovers, job briefings to address changing refuel floor c3nditions, and monitoring to ensure procedure A-30 adherence were stressed.
A listing of short and long-term expectations for NMD foreman and job leaders was develcped and issued on September 10, 1991.
4.-
Supervision and craft personnel who were involved in the violation identified on August 29, 1991, were disciplined.
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Attachment Page 5 of 6 Inspection Report Nos. 50-352/91-16 50-353/91-17 5.
As previously committed, procedure A-30, " Plant ilousekeeping,"
was revised.
A new procedure A-30.10, "Puel Ploor Housekeeping," was written and approved to supplement procedure A-30 by specifying additional housekeeping and material accountability requirements for the refuel floor.
Procedure A-30.10 greatly simplifies and clarifies refuel floor housekeeping and material accountability requirements.
6.
As previously committed, refuel floor material accountability zone access control points and zone boundaries were upgraded.
These control points are administrative 1y controlled by procedure A-30.10 and now include highly visible and sturdy control point desks where requirements are clearly posted and log books are firmly mounted.
7.
Responsibilities for refuel floor material accountability and housekeeping have been clarified and specified in procedure A-30.10 and a new LCS Maintenance -NMD Maintenance Interface Agreement issued on October 25, 1991.
8.
A responsible individual has been designated to serve as a single-point of accountability for refuel floor housekeeping and material accountability issues.
This individual is a member of LGS Maintenance or NMD as specified in the Maintenance Interface Agreement.
9.
As previously committed, a Por Your Information (PYI) notice (PYI - 17) was developed and distributed to first line supervision on October 15, 1991, to provide a clear, concise set of written expectations regarding refuel floor-housekeeping and material accountability.
First line supervision then disseminated the expectations of management in FYI-17 to station and NMD personnel to heighten their awareness of the requirements and management expectations.
- 10. Guidelines for NMD refuel floor team turnovers were developed that include detail concerning material accountability requirements.
These guidelines consist of a turnover checklist which was transmitted by letter to NMD foremen.
- 11. Shift Training Bulletin No. 91-2, " Refueling Floor," was issued to ensure awareness of and compliance with refuel floor material accountability requirements.
This bulletin was posted at each refuel floor accountability zone control point.
All personnel. entering these zones or performing work on the refuel floor are required to read this bulletin and sign to acknowledge awareness of applicable requirements.
- 12. A program to perform regular walkdowns of the refuel floor to ensure compliance with material accountability requirements has been implemented through procedure A-30.10 along with three other Routine Test procedures to assure proper material accountability on the refuel floor.
These Routine Test procedures include checks of the material accountability logs.
Attachment Page 6 of 6 Inspection Report Nos. 50-352/91-16 50-353/91-17 On October 31, 1991, LGS and NMD management reviewed the results of the above corrective actions at which time LGS management removed the stop work order for NMD personnel performing tasks on the refuel floor.
Corrective Actions Taken to Avoid Future Non-Compliance:
The following corrective actions will be implemented in order to strengthen the corrective actions already completed to prevent recurrence of similar material accountability deficiencies:
1.
The refuel floor material accountability training bulletin will be incorporated into applicable station and NMD continuing training programs by March 15, 1992, to minimize inconsistencies.
2.
Administrative procedures at PBAPS and LGS governing refuel floor material accountability and housekeeping zone access control points and zone boundaries will be revised by January 31, 1992, to minimize inconsistencies.
3.
During the next LGS refueling outage, NMD shall perform a self assessment of refuel floor housekeeping and material accountability performance to verify corrective actions are effective.
This self assessment will be completed by April 15, 1992.
Date When Full Compliance Will Be Achieved The actions listed under the " Corrective Action Taken and Results Achievad" section outline a basis for continued refuel floor work in compliance with applicable housekeeping and material accountability requirements.
Completion of these actions resulted in removal of the stop work order for NMD personnel performing tasks on the refuel floor on October 31, 1991.
Accordingly, full compliance was achieved at that time.
The actions listed under the " Corrective Action Taken and Results Achieved" section together with the actions listed under the
" Actions Taken to Avoid Future Non-Compliance" section provide a basis to assure continued compliance.
The self assessment of refuel floor housekeeping performance will verify effectiveness of the corrective actions.
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