ML20086L242
| ML20086L242 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 12/09/1991 |
| From: | Leitch G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9112160109 | |
| Download: ML20086L242 (7) | |
Text
PHILADELPHIA ELECTRIC COMPANY LIMERICK GENEMTING STATION P. O. BOX 2300 PO1TSTOWN, PA 19464-0920 (215) 327 1200, EXT. 3000 December 09, 1991 GlW4AM M.LEHCH Docket No. 50-352
- 6"gm 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 Nos. 50-352/91-18 and 50-353/91-19 Attached is Philadelphia Electric Compary's reply to a Notice of Violation for Limerick Generating Station (LGS) Unit 1, which was contained in the NRC Inspection Report Nos. 50-352/91-18 and 50-353/91-19 dated November 7, 1991.
The Notice of Violation identifies two events which indicate a weakness ith. personnel recognizing and initiating corrective actions for conditions adverse to quality.
In the first event, station personnel failed to initiate prcmpt corrective action to resolve a problem with a Residual Heat Removal System heat exchanger valve failing to operate properly, resulting in the valve failing acain.
The second event was failure to maintain established m asures that assure special processes, including welding activities, are controlled and accomplished by qualified personnel using qualified procedures in accordance with the applicable codes, standards, specifications, criteria, and other special requirements.
The attachment to this letter provides a restatement of the violations identified auring an NRC inspection conducted between September 1,
- 1991, through Octcber 5, 1991, wt LGS, Units 1 and 2, followed by our responses.
If you have any questions or require additional information, please contact us.
Very ly
- ours, j
/'. )
3 KOS/WGS:cah Attachment cc:
W.
T. Russell, Administrator, Region I, USNRC T. J. Kenny, USNRC Senior Resident Inspector, LGS 9112160109 911209 PDR ADOCK 05000352
(((O/
G PDR
/r
~
bec:
D. M. Smith' 52C-7 J. Doering, Jr.
ADMS-1 D. R. Helwig 63C-1 J. W. Durham S26 1 G. A. Hunger, Jr. - SMB1-1 R. W. Boyce ADMS-1 L. A. Hopkins ADMS-1 D. G. Miller BTC J. A. Muntz SMB3-2 G. J. Madsen SSB3-4 J. F. O'Rourke SSB4-3 R. N. Charles 51A-1 G.J, Beck, Jr., -
52A-5 Secretary, NCB 51A-13 Correspondence Release Point - SMB1-2 JCC PA DER-BRP Inspector - SMB2-2
}
i
Attachm:nt Page 1 of 5 Inspection Report Nos. 50-352/91-18 50-353/91-19 Rep,1y to a Notice of Violation Violation A Restatement of the Violation 10 CPR 50 Appendix B, Criterion XV1, Corrective Action, and the Philadelphia Electric Company Quality Assurance Plan require that measures be established to assure that conditions adverse to quality, such as failures and malfunctions are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to nreclude repetition.
Contrary to the above, on September 9, 1991, the Unit 1 Residual Heat Removal heat exchanger inlet isolation valve, HV-051-lP014B, failed to open when operated remotely from the control room.
Operatore locally freed the valve and operated it; however, the cause sas not determined and corcacted, nor were measures taken to preclude repetition.
Specifically, no equipment trouble tag or maintenance work request was written nor were the engineering valve specialists consulted.
Consequently, on September 19, 1991, the valve again stuck in the closed position and could not be opened remotely from the control room.
This is a Sevetity Level IV Violation.
(Supplement I)
RESPONSE
Admission of Violation Philadelphia Electric Company (PECo; acknowledges the violation.
Corrective Action and Results Achieved Pollowing the initial failure of valve HV-051-lF014B to open on September 9, 1991, an investigation was initiated, involving Operations, System Engineering, a nd Maintenance personnel.
On September 17, 1991, the Maintenance Technical Staff generated a Maintenance Request Form (MRF) to perform Valve Operation Testing and Evaluation System (VOTES) diagnostic testing on the valve.
Prior to performance of the VOTES testing, the valve again failed to stroke open on September 19, 1991, during testing from the Main Control Rocm (MCR) by Operations and System Engineering personnel.
Attachment Page 2 of 5 Inspection Report Nos. 50-352/91-10 50-353/91-19 On September 19, 1991, f ollowing t he subi;equent failure of the valve to stroke open, the Residual Heat Removal Service Water (RHRSW) System Enginaer initiated a second MRF, identifying that valve HV-051-lF0148 motor operator breaker trips on excessive torque when attempting to stroke the valve open.
On September 20, 1991, the RHRSW System Engineer prepared a Shift Update Notice (SUN) identifying the stcoking problem on HV-51-lF0148.
The SUN program is used to provide snift operations personnel with updated information on unusual equ.'.pment conditions.
The valve was positioned off of its closed ueat to enuure the valve would open on demand from the MCR.
On September 22, 1991, a blocking permit was applied to alve HV-051-lF014B to support VOTES testing.
VOTES testing was performed which revealed the metor operator torque switch to still be tripped open when the -
que switch bypass limit switch was deactivated after a set time tay.
This caused valve xotion to be interrupted before the t.'7e tully opened.
The torque switch bypass limit switch was adjusted by maintenance to remain in g
effect for an increased duration during the valve open cycle, which 1
is within standard switch setting methodology.
The valve was then j
satisfactorily tested using Surveillance Test (ST) procedure ST-6-012-232-0, "B Loop RHRSW Pump, Valve, and Flow Test," and the valve was declared operable at 215') hours on September 22, 1991.
Corrective Actions Taken to Avoid Future Non-Compliance Administrative (A) procedure, A-26, " Procedure for Plant Maintenance Using the Maintenance Request Form," has been reviewed, along with Operations personnel training on A-26, and both the procedure and the training were determined to be adequate.
The following corrective actions were implemented in order to ensure that corrective
- tions are promptly initiated by operations personnel to ensure t'..at investigations into equipment anomolies are properly tracked via an Equipment Trouble Tag (ETT) or Work order.
Pru4.ptly initiating CTTs entern equipment deficiencies into the corrective maintenance program which ensures that the cause of the condition is determined and corrective actions are taken to preclude repetition.
o On October 30, 1991, a recorded phone message was distributed to all opetations shift supervision and the Shift Technical Advisors emphasizing the importance of promptly initiating corrective actions.
o On November 4, 1991, a letter from the Plant Manager to all licensed Senior Reactor Operator Operations personnel was issued reiterating management's expectations of initial response to equipment malfunctions.
This Jutter
- d that 1)
.u-equipment deficiencies must immediately be ptured in the corrective action process which assures t -at an approp late response is taken, and 2) when Technical Specification
Attachment
~.
Page 3 of 5
' ~
Inspection Report Hos. 50-352/91-18 1
50-353/91-19 equipment is considered operable while an operability
.dctermination is in process, the operations organization is
-responsible to assure that the evaluation is done as quickly as
- possible, o_
lon November 5, 1991, an Operatic 9s Shift Supervision meeting was held to discuss the reasons why corrective actions were not taken in'a timely manner.
This meeting emphasized management's expectations to initiate immediate corrective actions in response-to equipment malfunctions.
The following corrective action was implemented to ensure that all site personnel promptly initiate corrective actions.
Promptly initiating ETTs enters equipment deficiencies into the corrective maintenance. program which ensures that the cause of the condition 10 determined and corrective actions are taken to preclude i
repetition, o-On November 4, 1991, a For Your Information (FYI, notice was developed and distributed to first line supervision.
This FYI notice provided_a clear and concise set of written management expectations regarding the immediate_ corrective actions required to be promptly implemented upon discovery of-deficient plant equipment.
First line supervision then disseminated the expectations of management _-in this FYI to appropriate station personnel to-heighten their awareness of the requirements and management's. expectations.
In addition, on December 1, 1991, Limerick-Gr",erating Station implemented the Plant Information Management Ayptem (PIMS).
Tt. t 4 system ensures that an ETT which is generated for an equipment prob.'em results_in a computerized Action Request.
The Action Request must be. evaluated by'tne responsible organization and, if necessaryc a. work order is generated. -This ensures tracking'of problem investigation even before-sufficient information is available to generate a specific work order.
Date When~ Full Compliance wa Achiev,ed Full compliance was achieved on. otember 17, 1991,-when a MRFLwas written'on valve'HV-51-lF014B; the v 've was repaired and declared
. operable onLSeptember 22, 1991, l:
P
, -. ~....
I Attachment i
Page 4 of 5 i
Inspection Report Nos. 50-352/91-18
~
50-353/91-19 i
i I
Reply to a Notice _of Violation Violation B Restatement of the Violation 10 CPR 50 Appendix H, Criterion IX, Control of Special Processes, l
and the Philadelphia Electric Company Ouality Assurance (OA) Plan require measures be-established to assure that special processes, including welding, heat treating, and nondestructive testing, are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements.
Lection IM_of'the ASME Boiler and Pressure Vessel Code requires that qualified procedures and qualified welders be utilized for the
- performanceLof welding activities.
Contrary to the above, on September 24, 1991, Maintenance personnel attempted to weld on the Unit 1 High Pressure Coolant Injection IHPC1) system piping while water was issuing from the joint.
The velding procedure used at the job site, WPS El.1-0-2", was not qualified for welding under wetted conditions; nor was the welder qualified to weld under wetted conditions.
This is a Severity Level IV Violation.
(Supplement I)
RESPONSE
Admission of Violation
- Phi,1adelphia Electric Company.(PEco) acknowledges the violation.
r Corrective Action and Results Achieved On September 24, 1991, Maintenance personnel werefattempting-to weld a small drain line on the HPCI syTtem.. When-Water was-'
observed to be dripping from the pipe,.the-welding work was halted.
Limerick Generating Station (LGS) Maintenance _ personnel then reviewed ~HPCI system pipe drawings to determine if.a better system
. block could be applied _to adequately isolate water leakage from the welding area.
At 1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br />, Operations personnel were requested by LGS Maintenance personnel to reblock the HPCI system. _
Operations personnel reblocked the HPCI system but-the leakage.
remained: unchanged.
At approximately 1700 hours0.0197 days <br />0.472 hours <br />0.00281 weeks <br />6.4685e-4 months <br />, LGS Maintenance i
personnel installed wacer soluble paper into the HPCI system piping near the weld' area which temporarily stopped the water leakage.
- LGS Maintenance personnel then resumed welding activities _on the 9
r-e r
+-
e.e, s
,e
-w n -
-,,--s e n,r
,w-
--w.n a
a v.- - -
~~---=se'
--~=-.r-m's,
Attachment
~
Page 5 of 5 Inspection Report lios. 50-352/91-18 50-353/91-19 HPCI system socket weld.
Welding and Non-Destructive Examination (NDE) inspection work were completed satisfactorily at 2300 hours0.0266 days <br />0.639 hours <br />0.0038 weeks <br />8.7515e-4 months <br />.
Ocgrective Actions Taken to Avoid Future Non-Compliance The following corrective actions will be implemented in order to ensure that management expectations are clearly communicated to Maintenance welding personnel, o
Maintenance Team Meetings are being conducted to discuss the importance of not welding in the presence of foreign material (i.e., water).
All of these team meetings will be conducted by December 31, 1991.
These meetings will clearly convey management's expectation that in the presence of wetted conditions Maintenance technicians will not attempt to fit up pipe t o be welded and weldtrs will not commence welding.
Maintenance technicians and welders who have not participated in one of the team meetings as of December 9, 1991 will be directed to not weld under wetted conditions.
This direction will be provided by Maintenance Supervision by December 10, 1991, or upon their return to work at LGS.
o On December 6, 1991, training was initiated to provide all currently qualified welders and welders to be newly qualified with a read and sign training package.
This training package clarifies that no welding is to be performed on surfaceb when moisture, water, or other fluids are present.
This training will be completed by each welder during their next blannual welder maintenance of qualification training.
o The General Weld Procedure (GWP) will be revised by February 21, 1992.
This revision, in part, will clarify that no welding is to be performed on surfaces when moisture or water are
- present, o
Formal training on the GWP will be developed for initial weldar qualification and for welder maintenance of qualification training programs.
This training will be implemented during the second quarter of 1992 following completion of the revision to the GWP.
Date When Full Compliance was Achieved Pull compliance was achieved on September 24, 1991, when Maintenance personnel stopped water leakage to the area of the HPCI system socket weld and welding activities were completed in accordance with existing qualified procedures.
..