ML20113H914

Responds to NRC 920608 Request for Info Re Specific Fire Watch Activities at Facility & Concern That Fire Watch Personnel Assigned to Monitor Ongoing Welding Near Unit 2 Turbine Encl Left Area While Welding Continued

ML20113H914
Person / Time
Site:	Limerick
Issue date:	07/17/1992
From:	Leitch G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 9208060153
Download: ML20113H914 (4)

Text

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PHILADELPHIA ELECTRIC COMPANY 44 j

< - L,lMERICK CENER ATING STATION P, O. BOX A

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S AN ATOG A, PENNSYLV ANI A 19464

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(215) 3271200, EXT. 3000 c

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,.. Ju1y 17, 1992-Docket Nos.- 50-352 50-353 License Nos. NPF-39 NPF v>

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.Mr.-T.-T. Martin,~ Administrator

.U._- S.: Nuclear Regulatory Commission

_ Region:I:

'475 Allendale. Road Kingiof Prussia, PA 19406-

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! SUBJECT -- Limerick._ Generating Station, Units 1 and.2 ResponseLto Request for_Information Concerning' Fire

, ~ Watch Activities 1

Dear. Sir:

On: June -10,.1992, we: received NRC letter dated June 8, 1992,-  !

Erequesting information concerning specific fire-watch activities at the  !

ELimerick Generating: Station'(LGS). .The: letter requested that the

resu?ts of:our reviewLand disposition of this matter be submitted to Region Iswithin 30.daysioffthe datecof receipt.of'the-letter.

7 A seven

-(7)

day: extension was! granted by Mr.-J.-Lyash, of-Region I,'on July _ 8,  ;

1992.-::This 7etter provides:-the results of our. investigation and. i

disposition]of=theLmatter.<:Asnrequested-in--the--letter of June 8, 1992,

thisfr_esponsei does notLeontain

"personaliprivacy,' proprietary, or-

, safeguards:information.

TheLidentifiedLconcern is:that. fire watch'. personnel assigned to (monitor ongoing welding 'near_ the;41 line" in the Unite 2 Turbine Enclosure we'te-leaving the areat while the_ welding continued. This'is contrary to;the; requirements;of-Administrative <(A)-: procedure A-12, _

" Ignition; Source: Control Procedure." The-personnel involved in this-Lactivity were(most'likely_the contractors workingLfor the' Installation-Section'toFinstall'the Unit 2 Deep. Bed _Demineralizer modification in the

' Unit 12 Turbine Enclosure.

We have_investidatedLthis concern w ' similar fire-watch ,

iactivitiesfat LGS andshave concluded that; welding,.or other-ignition source workicontrolled by: procedure _A-12 did not continue in'the absence offthe fire watches. .-We-did,Lhowever, discover discrepancies _between e theitimes that the_ individuals were logged into the_ plant areas as E '

tracked by,the: security computerDand the fire watch sign-in and sign-out

times, documented onsthe ignition source log sheets. . Random sampling of

~the.: ignition source documentation was performed by Quality Assurance and ,

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- M'r.2N.JT.* Martin - July 17,-1992 Docket Nos. 50-352 50-353 site personnel,-and included the organizations that performed ignition source work between January 1992 and July 1992. The_ organizations were:

the Nuclear Maintenance Division (NMD), the site Maintenance Section, and the contractors working for the Installation Section and the Maintenance Section. The types of discrepancies identified were as '

follows.

1 .- Time differences of less than 10 minutes between the security 1 computer time and the time entered by the fire watch on the log.

The cause~of-these discrepancies is differences between the security computer time and the watches used by the workers. This has been' determined to not be a-procedure non-compliance concern and no corrective actions are necessary.

2. Fire watch _pe'rsonnel left and returned to the work area without signing off-and signing back on to the ignition source log sheets.

- 3. Time. differences of greater than 10 minutes between the security computer time and_the time entered by the fire watch on the log.

The cause of these last two discrepancies has been determined to be personneloerror due to lack of full understanding of the requirements.of procedure A-12. Interviews of individuals involved in the fire watch activities indicated that they understood'the general requirements of the procedure but either, l 1) forgot to sign cut and sign back in, 2) believed that they couldLleave the area if.no-ignition source work occurred, or 3) believed that they_could sign in on the log sheet during work preparations beforetentering the work area. -Although the fire watches? received training on procedure A-12, the.results of the interviews revealed,that there-is an, apparent lack!o't~

understanding _of the documentation requirements, . i n particular, the :importance of strict adherence to the requirements -with respect to' signing in and out on the log.- It was evident that-the Eworkers-did understand the intent of procedure A-12; to provide dedicated fire watch coverage during ignition source work and for

_the thirty (30) minutes following_ completion of the ignition source work.

Follow-up. discussions with the-fire watches and the ignition source workers, and further security zone traces identified that while

= thel fire watches were away from the work area, no welding or other ignition ~ source work. controlled by_ procedure A-12 was performed until a "firetwatch' returned to the work location and the-fire watch remained

- posted for the thirty (30) minutes following completion of the ignition

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"Mr_.f[.T.' Martin' ' July 17, 1992'

_. . Docket Nos. 50-352 50-353 4

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_None.of the ignition source workers-interviewed were aware of any

instances where an ignition source' fire watch left the work area while

' ignition-source work was in progress. There is no evidence to support i

.any_ deliberate-violations or willful falsification of documentation, j A's a result of the identified discrepancies, the Installation Section, utilizing site Fire Protection personnel, has performed retraining of.the craftsmen working for both Installation Section contractor and a follow-up review of newly issued ignition source log i

sheets to verify compliance. Since.the retraining, no additional

. discrepancies involving the Installation Section contractors have been identified.. A Maintenance Training Bulletin (MTB) is being developed by Esite_ Maintenance Section and site Fire Protection personnel to provide retraining on procedure A-12 of the remaining ignition source works who work at LGS. The MTB will be issued to supervisors of ignition source workers and fire watches in the site Maintenance Section, the site Maintenance Section contractor, and the NMD. The supervisors will discuss _the MTB with the appropriate personnel.

Long term corrective actions include a review, and revision if

necessary of procedure'A-12 to human factor the procedure and provide clarification of the documentation requirements. The training programs

-involving-the' ignition' source workers and fire watches will be reviewed to; determine whether clarification is needed in the training related to

precedure A-12.

In addition to -viewing the ignition source fire watch activities, a review- of: the-Technical Specifications (TS) required fire watch activities was performed. A review of selected TS fire watch patrols conducted between_ April 17, 1992'and May 10, 1992 was performed

-and the_ data was'comoared_to the security computer-data._-The information docume 3'by.these firewatches was verified to be accurate.

EIn summary,-er a result of our investigation, minor instances of

procedure non-compliances were identified, however, we have concluded that no ignition source work was performed without an ignition source fire watch,_and that there_was no intentional violation of procedural requirements or falsification of documentation.

=If-there-are any additional questions regarding this matter,

-please dornotshesitate to contact us.

Very trulyg yours, N/t , $1%

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[ cc: Document Control Desk, ~.NRC, Washington, D.C.

l T.--J._ Kenny, USNRC Senior Resident Inspector, LGS

~ C. W. Hehl,;USNRC, Region I, King of Prussia, PA (I

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