ML20148C143

Forwards Insp Repts 50-352/97-01 & 50-353/97-01 & Notice of Violation.Two Instances of Poor Mgt Oversight of Vendor Activities Were Noted During Unit 2 Refueling Outage

ML20148C143
Person / Time
Site:	Limerick
Issue date:	05/07/1997
From:	Keimig R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Danni Smith PECO CONTROLS CORP.
Shared Package
ML20148C149	List: IR 05000352/1997001 ML20148C143 ML20148C151
References
50-352-97-01, 50-352-97-1, 50-353-97-01, 50-353-97-1, NUDOCS 9705150124
Download: ML20148C143 (3)

See also: IR 05000352/1997001

Text

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'3 May 7, 1997

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Mr. D. M. Smith, President

(- PECO Nuclear

1- Nuclear Group Headquarters

i Correspondence Control Desk

P. O. Box 195

Wayne, PA 19087-0195

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SUBJECT: NRC INTEGRATED INSPECTION REPORT 50-352/97-01, 50-353/97-01;

NOTICE OF VIOLATION

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l Dear Mr. Smith:

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!* On February 4,1997 through March 29,1997 the NRC completed inspections at your

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Limerick 1 & 2 reactor facilities. The enclosed report presents the results of those

. inspections.

l' During the 8-week period covered by this inspection, the conduct of activities at the

Limerick 1 & 2 facilities was generally characterized by safe and conservative operations

and decision making. Several conservative decisions associated with the Unit 2 refueling

. outage were made, which appropriately resulted in the expansion of the scope of the

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outage. The bases for those decisions were to ensure component reliability and quality,

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j and demonstrated that there was no unreasonable schedule pressure. Maintenance

performed at both units appeared to be of high quality.

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! . Several region-based reviews of your programs occurred during the period, including the

applied radiological controls program for the Unit 2 outage and the Inservice Inspection

(ISI) program and fire protection. The inspectors concluded that effective applied

radiological controls were established and implemented for the Unit 2 outage. The ALARA-

controls for ongoing work activities were also found to be effective. However, some

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indications of lax worker attention to radiation protection procedures were noted.

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c The implementation of the ISI program at the Limerick Generating Station was found to

i meet the requirements of the American Society of Mechanical Engineers (ASME) Boiler and

Pressure Vessel Code,1986 Edition. Currently, the ISI program is on schedule and all

examinations are scheduled to be completed by the end of the first ten-year interval.

Two instances of poor management oversight of vendor activities were noted during the /

Unit 2 refueling outage. The inspector expressed concern to PECO management after f

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observing several poorly controlled nondestructive examination activities. The inspectors )'

witnessed surface exams being performed with weak controls and under unfavorable

conditions. Upon further investigation, it was discovered that there was no requirement or

' formal program in place for PECO personnel to oversee the vendor Nondestructive

Examination (NDE) activities as performed in the field or to perform over-checks (re-

performance of the examinations) of the field exams. While the PECO Level lli NDE .

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9705150124 970507

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Mr. D. M. Smith 2

inspector does review ten percent of data from the field, this may not preclude identifying

poorly performed exams in the field. As a result of the inspector's concerns, PECO is

evaluating the effectiveness of its NDE oversight program.

The second occurrence involved vendor inspection of spent reactor fuel and resulted in a

violation. The violation ic cited in the enclosed Notice of Violation (Notice) and the

circumstances surrounding it are described in detail in the subject inspection report. The

violation concerns an instance where a modification was made to the Unit 2 fuel

preparation machines that made the information in the Updated Final Safety Analysis

Report (UFSAR) incomplete in that a test fixture was added, causing two spent fuel

assemblies to be raised closer to the water surface pool than allowed by the UFSAR. The

modification was not evaluated to determine if it would make information in the SAR

inaccurate or incomplete. The violation is of concern because this was another example of

inadequate oversight and review of a vendor activity. You are required to respond to this

letter and should follow the instructions specified in the enclosed Notice when preparing

your response.

The fire protection program was found to be satisfactory. We noted a lack of good fire

protection program oversight. Weaknesses were noted in the control of hotwork activities

However, some good initiatives have been taken recently to improve the effectiveness of

this program.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter,

its enclosure (s), and your response will be placed in the NRC Public Document Room

(PDR).

Sincerely,

ORIGINAL' SIGNED BY:

Richard R. Keimig, Chief

Projects Branch 4

Division of Reactor Projects

Docket Nos.: 50-352, 50-353

License Nos: NPF-39, NPF-85

Enclosures:

1. Notice of Violation

2. Inspection Report 50-352/97-01, 50-353/97-01

cc w/ encl:

G. A. Hunger, Jr., Chairman, Nuclear Review Board and Director - Licensing

W. MacFarland, Vice President - Limerick Generating Station

J. L. Kantner, Regulatory Engineer - Limerick Generating Station

Secretary, Nuclear Committee of the Board

Nuclear Safety Information Center (NSIC)

Commonwealth of Pennsylvania

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Mr. D. M. Smith 3

Distribution w/ encl:

Region ! Docket Room (with concurrences)

K. Gallagher, DRP

D. Screnci, PAO (1)

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NRC Resident inspector

PUBLIC

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j Distribution w/ encl: (Via E-Mail)

i W. Dean, OEDO

F. Rinaldi, NRR

q J. Stolz, PDl-2, NRR

i inspection Program Branch, NRR (IPAS)

DOCDESK

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DOCUMENT NAME: g:\ branch 4\9701. lim

To receive e copy of this document. Indicate in the boa: "C" = Copy without ottachment/ enclosure "E" = Copy with attachment / enclosure

"N" = No copy g

OFFICE Rl/DRP , _

Rl/DRP /' # l

NAME PERRY /9 op 1 05A KEIMIG //

DATE 05q /97' 05f//97@

OFFIClfL RECORD COPY

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