ML20203C931
| ML20203C931 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 02/05/1999 |
| From: | Von Suskil J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-352-98-09, 50-352-98-9, 50-353-98-09, 50-353-98-9, NUDOCS 9902120302 | |
| Download: ML20203C931 (3) | |
Text
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James D. von Suskil
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Vcce Preshfent Urnerich Gene ating station i
i PECO NUCLEAR nco %, co,n,an, A Unit of PECO Energy '
I sM81I Sanatoga. PA 19464-0920 610 718 3000 / Fax 610 718 3008
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Pager 1800 672 2285 #0271 Internet address: jvonsuskil@'peco-energycom
]
10 CFR 2.201 February 5,1999 Docket Nos. 50-352 50-353 License Nos. NPF-39 NPF-85 U.S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, DC 20555 4
SUBJECT:
Limerick Generating Station, Units 1 and 2 Reply to a Notice of Violation NRC Inspection Report 50-352/98-09 and 50-353/98-09 Attached is PECO Nuclear's reply to a Notice of Violation for Limerick Generating Station (LGS), Units 1 and 2, that was contained in your letter dmed January 6,1999. The Notice identified one violation involving procedural adherence our;ag dry cask shipment preparation
' activities. The attachment to this letter provides a restatement of the violation followed by our reply.
If you have any questions or require additional information, please contact us.
Sincerely, M
- Attachment cc:
H. J. Miller, Administrator, Region I, USNRC w/ attachment A L. Burritt, USNRC Senior Resident inspector, LGS t
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Dock:t Nos. 50-352 and 50-353 February 5,1999 Page 1 of 2 REPLY TO A NOTICE OF VIOLATION Restatement of the Violation During an NRC inspection conducted between October 18,1998, and 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 violation is listed below:
A.-
Technical Specification (TS) 6.8.1 requires, in part, that written procedures shall be-implernented covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Appendix A of Regulatory Guide 1.33, 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,."NLl-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.
Contrary 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 i
Regulatory Guide 1.33, was not implerrented as required by procedure A-C-079.
Specifically, during the installation of ti e inner cask lid alignment pins, procedure steps 5.7.17 through 5.7.28 were not prformed in sequence resulting in a mis-placed pin.
This is a Severity Level IV violation (Supplement 1).
Repiv to the Violation
' Admission of the Violation PECO Energy acknowledges the violation.
Reasons for the Violation During the performance of procedure M-053-006, "NLl-1/2 Spent Fuel Shipping Cask Preparation and Loading," a PECO Nuclear worker overseeing work being performed by vendor technicians encountered difficulty performing a step associated with removal of the l
lid from the unloaded cask. The worker failed to use appropriate administrative controls to l
change the procedure to reflect the necessary sequence of steps and add guidance to i
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Attachment Dock':t Nos. 50-352 r nd 50-353 February 5,1999
. Page 2 of 2 assure proper placement of two alignment pins. This human performance issue is the result of failure of an individual to manage perceived schedule pressure re uning in an inappropriate individual worker behavior.
4 A contributing factor to this event was that Nuclear Maintenance Division (NMD) Reactor Senrices Section (RSS) management oversight of the planning and preparation phase was
)
Inadequate resulting in conditions which created an error likely situation. While the unique
' nature of the overall evolution was recognized and the necessary administrative controls -
were applied, interface with the vendors during the planning and preparation phase was inadequate. As a result, the implementing procedure contained technical errors that challenged workers in the field.
Corrective Actions Taken and Results Achieved NMD supervision communicated and reinforced expectations for procedure compliance to all workers involved with the activity. In addition, management reinforced expectations for j
procedure compliance with appropriate NMD personnel. This communication emphasized the i
importance of informing supervision when there is a potential problem encountered during execution of procedures. This communication also emphasized that individuals must adhere to procedures in a deliberate, conscientious fashion and correct any procedure deficiencies before i
proceeding, regardless of the impact to the work schedule. Additionally, a detailed procedure review of the implementing procedure was performed by PECO Nuclear and vendor personnel at the site, and the procedure was revised to incorporate guidance for installing the alignment pins as well as other identified enhancements. Following these corrective actions, workers associated with the cask handling activity demonstrated proper use of plant procedures. During subsequent cask handling activities, workers appropriately stopped work, involved supervision and processed procedure changes when necessary.
Also, as part of an ongoing station-wide campaign to focus on procedure compliance, briefings of station work groups have been conducted with emphasis placed on the importance of procedure compliance. Proper use of procedures during a recent mini-outage to replace a leaking fuel bundle is an example of the positive results of this ongoing campaign.
Corrective Actions to Avoid Future Noncomollance
- NMD management reviewed this work activity and the lessons learned with NMD RSS personnel.
This review provided for a thorough understanding of the detailed aspects of the procedure noncompliance and the proceduralinadequacies associated with the activity. In addition, this review focused RSS personnel attention on the less than adequate vendor interface during the planning and preparation phase. This action was completed on January 29,1999.
Date When Full C9mpliance was Achieved Full compliance was achieved on November 11,1998, when the cask pins were properly aligned in accordance with the goveming procedure.
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