ML20198N170

Notice of Violation from Insp on 970722-0915.Violation Noted:Inspector Identified Valve Locking Devices Not Applied Through Valve Handwheel or Other Operating Mechanism to Restrict Operation of Valves Listed on Valve List Exhibits

ML20198N170
Person / Time
Site:	Limerick
Issue date:	10/27/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20198N168	List: ML20198N165 ML20198N170 ML20198N177
References
50-352-97-07, 50-352-97-7, 50-353-97-07, 50-353-97-7, NUDOCS 9711030175
Download: ML20198N170 (2)

Text

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ENCLOSURE 1 NOTICE OF VIOLATION PECO Energy Docket Nos. 50 352:50 353 Limerick Generating Station License Nos. NPF 39; NPF 85 Unit 1 and 2 '

During an NRC inspection conducted on July 22 through September 15,1997, a violations of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the violations are listed below:

A. Units 1 and 2 Technical Specification (TS) 6.8.1 requires, in part, that written procedures shall be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Regulatory Guide 1.33 recommends Administrative Procedures for Equipment Control (e.g., locking and tagging) as activities that should be covered by written procedures. Administrative procedure A C 008, Control of Locked Valves and Devices, written to comply with TS 6.8.1, requires in part, that a locking device be applied through the valve handwheel or other operating mechanism to restrict operation of the velve, for valves listed on the Locked Valve List exhibits.

Contrary to the above, between August 18 and 28,1997, the inspector identified valve locking devices not applied through the valve handwheal or other operating mechanism to restrict operation of valves listed on the locked Valve List exhibits.

Additionally, operations personnel Identified other similar valves during a subsequent walkdown of accessible locked valves.

This is a Severity Level IV violation (Supplement 1).

B. Administrative procedure A C-131, Foreign Material Exclusion, requires in part that FME control recommendations be defined and included in the work package, and that workers shall understand and adhere to Foreign Material Exclusion (FME) requirements.

Contrary to the above, workers failed to adequately understand and adhore to FME requirements and on June 25,1997, a small piece of cloth was found in the Unit 2 high pressure coolant injection (HPCI) drain line flow orifice, resulting in operators declaring the Unit 2 HPCI system inoperable.

This is a Severit) Level IV violation (Supplement 1).

Pursuant to the provisions of 10 CFR 2.201, PECO Energy is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region I, and a copy to the NRC Resident inspector at the facility that is the ,

subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if kDk AD 5 52 0 PDR

Enclosure 1 2 contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If permnal privacy or proprietary information is necessary to provide an acceptable response, Qon please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. l' you request withholding of such material, you muS1 specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withhold-ing (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptatie iesponse, please provide the level of protection described in 10 CFR 73.21.

Dated this 27th day of October 1997, King of Prussia, Pennsylvania.