ML20199C657

Notice of Violation from Insp on 981018-1130.Violation Noted:On 981105,procedure M-053-006,required by App a of Reg Guide 1.33,not Implemented as Required by Procedure A-C-079

ML20199C657
Person / Time
Site:	Limerick
Issue date:	01/06/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20199C656	List: ML20199C650 ML20199C657 ML20199C664
References
RTR-REGGD-01.033, RTR-REGGD-1.033 50-352-98-09, 50-352-98-9, 50-353-98-09, 50-353-98-9, NUDOCS 9901190046
Download: ML20199C657 (2)

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l ENCLOSURE 1 NOTICE OF VIOLATION l 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 between October 18,1998, through November 30, 1998, a violation 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:

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

Revision 2, February 1978 requires that maintenance be properly pre-planned and performed in accordance with written procedures. Licensee Procedure A-C-079,

" Procedure Adherence and Use," step 7.5.3 requires that the user perform each step in the sequence specified in a Category Level 1 procedure. Procedure, M-053-006, "NLI-1/2 Spent Fuel Shipping Cask Preparation and Loading," a Category Level 1 procedure, steps 5.7.17 through 5.7.28, specifies the sequence for installation of the inner cask lid alignment pins.

Cont'ary to the above, on November 5,1998, procedure M-053-006,"NLl-1/2 Spent Fuel Shipping Cask Preparation and Loading," required by Appendix A of Regulatory Guide 1.33, was not implemented as required by procedure A-C-079.

Specifically, during the installation of the inner cask lid alignment pins, procedure steps 5.7.17 through 5.7.28 were not performed in sequence resulting in a mis-placed pin.

This is a Severity 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 contested, the basis for disputing the violation or severity level, (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. Where good cause is shown, consideration will be given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response to t the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.

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9901190046 PDR 990106 ADOCK 05000352 O PDR

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Enclosure 1 2 l 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 l information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide i 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. If you request withholding of such material, you must 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 acceptable response, please provide the level of protection described in 10 CFR 73.21.

l Dated at King of Prussia, Pennsylvania this 6th day of January,1999.

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