ML20097F751
| ML20097F751 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/11/1992 |
| From: | Doering J, Leitch G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9206160005 | |
| Download: ML20097F751 (4) | |
Text
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10-CPR-2.201!
e PHILADELPHIA ELECTRIC COMPANY LIMERICK GENER ATING STA110N P. O BOX A SAN ATOG A, PENNSYLV ANI A 19444 -
(215) 3271200, EXT. 3000 TJune 11, _1992
" Z.W,.'.".',"
Do-;et No. 50-352 u.............."**
Licenae 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 Combined Inspection Report Nos. 50-352/92.
and 50-353/92-13, and Combined Inspection Report.
t Nos. 50-352/92-14 and 50-353/92-14 Attached is Philadelphia Electric Company's reply to a Notice of.
Violation for Limerick Generating, Station-(LGS) Unit 1, which was.
conta.ned-in a NRC letter dated May 12, 1992- that transmitted Combined Inspection Report Nos. 50-352/92-14 and 50-353/92-14'. 'The subject.of-the violation was discussed in NRC Combined Inspect hn Report Nos.' 50-352/92-13 and 50-353/92 T3.
-NRC Enforcement Confercnce Nos.- 50-352/92-13 and 50-353/92-13 vta. held at the NRC Region I office on Apr11-_10,-1992, to discuss the-violation, its-cause,-and: corrective.act. ions-taken. - A _-
follow-up; meeting-was' held at the.NRC, Region __I office on June 9, 1992,-(to resolve questions about the bioassay results:that suggested a-substantial-
. intake of alpha-emitting radionuclides. occurred following-this violation.-
The Notice of Violation'identifles-the failure.t'oLfollow the requirements-and. limitations specified in a Radiation 1 Work Permit.o The attachment to this: letter'provides a-restatement-of-the-violation identified during'an NRC special-inspectioniconducted-at-~ LGS, Units 1 and'2, on March 26-27,_1992,1 and a' follow-up' inspection on April; f_
20-24,?1992,' -- followed by our response.
If you have any questions.or.requireLadditional information.-please contact us.-
--Very truly[-yours, I th JLP:cah
Attachment:
9206160005 920611 PDR--ADOCK 05000352 b
Q
-PDR cc:
'T.:T.1 Martin, Administrator, Hegion I, USNRCs g~
T 7J. Kenny, USNRC Senior' Resident-Inspector,. LGS 150027f
~
t
= Attachment Page 1 of 3 Docket No. 50-352/92-13.
Reply to a Notice of Violation Restatement of the Violation As a result of the inspection conducted on March 26-27, 1992, and in accordance with the NRC Enforcement Policy (10 CFR 2, Appendix C), the following violation was identified:
Technical Specifications, Section 6.8, Procedures, require that written procedures be established, implemented, and maintained.
Procedure A-C-107, Radiation Work Permit Prog.am and Radiological Controlled Area Access Requirements, specifies that a worker's signature on a radiation work-permit _(RWP) means that the worker understood the requirements and limitations specified-in the RWP and will comply with these requirements and' limitations.
Contrary to the above, on March 25, 1992, workers on RWP 920704 entered-the Unit 1 fuel transfer canal in violation of the RWP prohibition on entering this' area.
This.is a Severity Level IV violation (Supplement-IV).
RESPlNSE Admission of Violation Philadelphia Electric Company (PECo) acknowledges the-violation.
Reason for the Violation The cause of the violation is personnel error resulting in procedural non-compliance due to failure to follow' administrative controls and a failure to communicate changes in planned work activities.
Radiation Work Permit-(RWP) 9207074 for the reactor cavity area. included a special instruction that stated, " Entry into the -
--Transfer Canal prohibited on-this RWP."
While waiting for the-Reactor' Services;Section.(RSS)'
Superintendent lto inspect-the reactor pressure vessel-flange. the Job Leader decided to proceed with the planned work activities which included removal of Stop Log #15.
During the course ofc the-
1 Attachment Page 2 of-3 Docket No. 50-352/92-13 cavity cleaning the rope barrier.was remcVed by the Job Leader from across the Transfer Canal Entrance.
The Job Leader knew that the rope barrier should not be removed without the authorization of Health Physics (HP).
Based upon a discussion of the planned work activities with HP personnel earlier in the oay, the Job Leader's perception vas that he received authorization to remove the rope barrier along with the other equipment from the reactor cavity.
Removal of the rope barritr removed a barrier in place to assist personnel to comply with RWP'9207074.
When the Stop Log was lifted, sealant material broke off and fell to the floor of the Transfer Canal.
Gouges were identified in the side of the Stop Log after it was lifted approximately five feet.
At that point the lift was halted and the Job Leader and an Engineer exited the reactor cavity to inspect the gouging from the Fuel Floor.
Stop Log removal was completed after it was determined that the gouging was caused during Stop Log insertion-during a previous outage.
The RSS Superintendent entered the reactor cavity and inspected the reactar pressure vessel flange.
Once the RSS Superintendent completed his inspection, the Job Leader'and the Engineer discussed the Stop Log gouging problem with him._
All-three individuals then entered the Transfer Canal to inspect the Stop Log Keyway for damage because the extent of the damage could not be determined f rom the-cavity' area or Fuel Floor.
These individuals failed to follow administrative controls establisned by Common-Nuclear Procedure A-C-107," Radiation Work Permit Program and Radiological Controlled Area Access Requirements,"
when they made their unauthorized entry into the Transfer Canal and failed to comply with RWP 9207074.
Corrective Action and Results Achieved An outage stand down was conducted on March 26, 1992.
The, outage work stoppage was initiated to provide time to inform all outage workers of several recent events that could have been avoided.
The focus was on the cause of the event and the lessons-to be learned so that similar problems could be avoided.
This event was one of five that was discussed.
Management. conveyed the following expectations to all plant workers based upor. the lessons learned from these events:-
1.
Adhere to procedures.
2.
Think beforr acting.
When in doubt, stop-and ask.
3.
Follow proper Radiation Worker practices at"all times.
,,s Attachment-PageL3 of-3 Docket No.- 50-352/92-13 Corrective Actions Taken to Avoid Future Non-Compliance The following actions were taken or are planned tofbe taken to avoid future non-compliance:
1.
On March 26, 1992, an HP supervisor was assigned to assess the fuel floor HP operations to-determine where improvements in communication and HP-coverage can be made.
The improvements-identified have_been completed.
2.
Group meetings were held with RSS and HP personnel to discuss the event and to-reinforce management's expectations regarding communication, pre-job briefings, radiation worker practices, and adherence to procedures.
3.
Appropriate RSS personnel were-disciplined-in accordance with the disciplinary-guideline for;their failure to-follow the requirements of the RWP.
.Date When Full Compliance was Achieved Full Compliance was achieved on March 26~,
1992, when the-outage. stand-down-was conducted and:all outage workers _were informed of management expectations of-their--conduct to avoid similar-problems.
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