ML20199K806
| ML20199K806 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 11/26/1997 |
| From: | Boyce R PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-352-97-07, 50-352-97-7, 50-353-97-07, 50-353-97-7, NUDOCS 9712010206 | |
| Download: ML20199K806 (5) | |
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215 3271200 Est. 2000 10 CFR 2.201 November 26,1997 Docket Nos. 50-352 50-353 License Nos. NPF-39 NPF-85 U.S. Nucleer Regulatory Commission Attn.: Document Control Desk Washing.on, DC 20555
SUBJECT:
Limerick Generating Station, Units 1 and 2 Reply to a Notice of Violation NRC Integrated Inspection Report Nos. 50-352/97-07 and 50 353/97 07 Attached is PECO Energy Company's reply to a Notice of Violation for Limerick Generating Station (LGS), Units 1 and 2, that was contained in your letter dated October 27,1997. The Notice identified violations concerning: 1) a number of valves that were inadequately locked, and 2) issues associated with the Foreign Material Excluslan (FME) program. The attachment to this letter provides a restatement of each violation followed by our reply.
If you have any questions or require additionalinformation, please contact us.
Very truly yours, wfwk, h I
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- Attachment cc:
H. J. Miller, Administrator, Region I, USNRC w/ attachment A. L Burritt, USNRC Senior Resident inspector, LGS D
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Attachment e Docket Nos. 50-352 and 50-353 November 26,1997 Page 1 of 4 Realv To a Notice of Violation Violation A Restatementgf Violation During an NRC inspection conducted on July 22 through September 15,1997, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and
- Procedure for NRC Enforcement Actions," NUREG-1600, the violation is 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 prc:edures. 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 valva handwheel or other operating mechanism to restrict operation of the valve, 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 handwheel 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 I).
REPLY
' Admission of the Violation PECO Energy acknowledges the violation.
Reasons for the Violation The cause of the failure to properly apply locking devices were insufficient recurring training for some personnel regarding proper application of locking devices, an infrequently performed task with specific expectations; lack of sufficient inspections ond surveillances to verify the condition of
' locking devices resulting in devices which had deteriorated due to rust; r.nd, a valve design (T-handle) which is difficult to secure using a standard cable and lock.
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i Attachment
- Doc. set Nos 50 352 and 50-353 November 26,1997 Page 2 of 4 i
Corrective Actions Taken and Results Achieved A briefing sheet was issued to all operations and maintenance personnel to reinforce the expectations for restoration of locked devices. In addition, all site personnel were briefed on locked device expectations, including consideration of material condition when locking devices.
All normally accessible locked valves (2080 valves) were inspected to identify and correct
- deviations from administrative requirements. Thirty-eight (38) valves were found to be improperly locked and nineteen (19) devices were found to have 6cking devices in a deteriorated condition. All devices were found to be in the correct position. The improperly locked devices were immediately corrected. Corrective maintenance action requests were initiated for locked devices which were in poor physical condition and the devices were entered i
in the locked valve log as unlocked devices in accordance with procedure.
Corrective Actions to Avoid Future Noncompilanet Recurring training for appropriate personnel regarding proper locked device manipulation is being developed. The first cycle of recurring training will be completed by April,1998.
A process will b6 created to periodically sample a portion of the locked devices and ensure they are properly locked. This process will be in place by the end of December,1997.
An evaluation is in progress to identify an improved mechanism for securing T-handle valves.
This evaluation is expected to be completed by March,1998.
Date.When Full Compliance was Achieved The improperly locked valves identified by tl.e inspector were restored to compliance with procedural requirements by August 28 1997. The inspection of additionallocked valves was completed and all deviations from administrative requirements were corrected by September 24,1997. No devices were found out of position at any time during the initial discovery or follow-up inspections for this issue.
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Attachment Dochet Nos. 50-352 and 50 353 November 26,1997
- Page 3 of 4 Violation B i
Restatement of Violation During an NRC inspection conducted on July 22 through September 15,1997, a violation of NRC requirements was identified. In accordance with the " General Statement cf Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below; 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 adhere to FME sequirements and on June 26,1997, 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 Severity Level IV violation (Supplement 1).
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REPLY t
Admission of the Vigitti.gn PECO Energy acknowledges the violation.
Reasons for the Violation The primary cause of this cvent was personnel error, related to less than adequate implementation of PECO Nuclear's Foreign Material Exclusion (FME) program. The exact origin of this piece of cloth was not determined, however, it was most likely introduced during the System work performed during the 2R04 refueling outage in February 1997. This would have been caused by less than adequate: worker attention to detail and immediate oversight of activities to ensure compliance with appropriate FME practices.
An associated root cause for this event was less than adequate site-wide implementation of the FME program. During and immediately after the 2R04 refueling outage, a number of foreign material intrusion events were identified. Station management concluded that these events resulted from less than adequate site-wide implementation of the FME program, and therefore initiated a broad based corrective action plan.
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Attachment Docket Nns. 50 352 and 50-353 November 26,1997 i
Page 4 of 4 Corrective Actions Taken and Results Achieved Corrective maintenance on the HPCl Systern identified a small piece of cloth (circular, approximately 1* In diameter) in the turbine exhaust drain pot drain line, upstream of the flow orifice. Th, drain pot drain line was cleaned and reinstalled. The HPCI system was t
satisfactorily post-maintenance tested.
Corrective Actions to Avoid Future Noncomollance The corrective actions to avoid future noncompliances of this nature are related to addressing site-wide implenientation of the FME program. These actions were initiated prior to this event are in progress, and include:
incorporation of FME training in all maintenance continuing training sessions.
e Development of a site wide, multi-organizational task team to identify issues with current FME procedures and practices.
Development of a communication plan to enhance FME awareness.
Clarification and reinforcement of inanagement expectations for performance.
e Evaluate, and revise as necessary, the FME implementing procedures (including consideration of industry best practices),
Perform a follow-up self assessment in 1998 of FME program implementation.
e The T.ajority of these actions are scheduled to be completed k, the end of the first quarter of 1998.
Opb When Full Compliance was Achieved Full compliance was achieved on June 27,1997, when corrective maintenance was completed on the HPCI System and the System satisfactorily completed a post-maintenance test.
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