ML20206N906
| ML20206N906 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 04/13/1987 |
| From: | Johnston W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| NUDOCS 8704210052 | |
| Download: ML20206N906 (2) | |
See also: IR 05000352/1987002
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APR 131987
Docket No. 50-352
Philadelphia Electric Company
,
ATTN: Mr. J. W. Gallagher
Vice President
Nuclear Operations
2301 Market Street
Philadelphia, Pennsylvania 19101
Gentlemen:
"
Subject:
Inspection No. 50-352/87-02
This refers to your letter dated March 19, 1987, in response to our letter
dated February 11, 1987.
Thank you for informing us of the corrective and preventive actions documented
'
in your letter. These actions will be examined during a future inspection of
your licensed program.
Your cooperation with us is appreciated.
1
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Sincerely,
Original SLSns$ gyy
Jacque P. Dun
William V. Johnston, Acting Director
Division of Reactor Safety
cc w/o encl:
John S. Kemper, Senior Vice President, Engineering and Production
G. Leitch, Nuclear Generation Manager
!
J. Franz, Manager Limerick Generating Station
Troy B. Conner, Jr. , Esquire
Eugene J. Bradley, Esquire, Assistant General Counsel
W. M. Alden, Engineer in Charge, Licensing Section
Public Document Room (PDR)
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Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
Commonwealth of Pennsylvania
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OFFICIAL RECORD COPY
RL LIM 1 87-02 - 0001.0.0
04/07/87
8704210052 870413
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Philadelphia Electric Company
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Region I Docket Room (with concurrences)
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Management Assistant, DRMA (w/o encl)
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Section Chief, DRP
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PHILADELPHIA ELECTRIC COMPANY
23Ol MARKET STREET
P.O. BOX 8699
PHILADELPHI A. PA.19101
12151 841 5001
Jossen w. eaLLAeHan
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March 19, 1987
Docket No. 50-352
Inspection Report: 50-352/87-02
Mr. Stewart Ebneter, Director
Division of Reactor Safety
U. S. Nuclear Regulatory Commission
Region I
ATTN: Document Control Desk
D.C.
20555
Dear Mr. Ebneter:
Your letter dated February 11, 1987 forwarded Inspection
Report 50-352/87-02 for Limerick Generating Station.
Appendix A
of your letter addresses an item which does not appear to be in
full compliance with Nuclear Regulatory Commission requirements.
This item is restated below followed by our response.
The
delayed submittal of this response was discussed in a telephone
conversation between W. M. Alden of Philadelphia Electric Company
and A.*Xrasopoulos of the NRC staff, and a one-week extension was
'
found ieceptable.
-
Violatkons
!
10 CFR-50 Appendix B Criterion V requires that " activities
affectiing quality shall be prescribed by documented procedures
and shn11 be accomplished in accordance with these procedures."
The Licensee's Administrative Procedure A-12 Ignition Source
Control Procedure stipulates that "the ignition source worker
prior to first using the ignition source shall enoure that the
required types of fire watches are in place and have the
'
v appropriate fire extinguishers."
Contrary to the above on January 9,
1987 on Reactor Building
,"
Elevation 313, Area 11 a grinding operation was taking place
-
without the required fire watch.
Also on January 8, 1987,
a
welding operation was taking place in the corridor of Elevation
269 Turbine Building Unit 2, on Unit 1 piping without a fire
-
extinguisher in the immediate vicinity.
This is a Severity Level V Violation. (Supplement 1)
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Mr. Stswart Ebnater
March 19, 1987
Paga 2
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Response:
Admission of Alleged Violation:
Philadelphia Electric Company acknowledges the violation in
that two ignition source work activities, which required
adherence to Administrative Procedure A-12, " Ignition Source
Control Procedure", were not performed in accordance with the
procedure's requirements for fire extinguishers and fire
watches.
Reason for the Violation:
The reason for these two incidents was personnel error in
that the personnel involved did not perform their work in
accordance with procedural requirements.
The absence of a fire watch on January 9,
1987 on Elevation
313 of the Reactor Enclosure resulted from a subcontractor
-
mechanic failing to implement procedure A-12 by resuming
.
grinding after his morning break, prior to the return of the
'
designated fire watch.
On January 8,
1987, a fire extinguisher was not in the
,
immediate vicinity of the ignition source activity on
Elevation 269 of the Unit 2 Turbine Building because the
dedicated fire watch failed to implement procedure A-12.
The
fire watch believed that it was acceptable to know the
'
iccation of the nearest fire extinguisher rather than have a
fire extinguisher readily available in the immediate
>
vicinity.
Significance of Violation:
Elevation 313 of the Reactor Enclosure contains 2 load
centers associated with fire protection safe shutdown methods
for Unit 1.
These load centers are located in the northeast
quadrant of the Reactor Enclosure, approximately 120 ft. from
the location of the grinding operation.
As a result of this
distance, the possibility of a fire at the grinding location
having an adverse impact on the capability to safely shutdown
Unit 1 is small.
The probability of a fire resulting from the ignition source
activity within the security corridor on Elevation 269 of the
,
Unit 2 Turbine Building was very low due to the absence of
-
j
combustible material in area.
Additionally, if a fire had
.
occurred, it would have had no adverse impact on the
!
capability to safely shutdown Unit 1 since this area is well
.
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Mr. Stewart Ebnster
March 19, 1987
Page 3
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outside of the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire barriers protecting Unit 1 safe
shutdown equipment.
Although a fire extinguisher was not in
the immediate vicinity of the ignition source activity, one
was located in the same enclosed corridor which could have
been' reached and used quickly in the event of a fire.
Corrective Actions Taken and Results Achieved:
The immediate action to prevent a recurrence of the absence
of a fire watch on Elevation 313 on January 9 was that the
vendor reinstructed its site personnel in the requirements of
A-12.
This training session was completed on the day of the
incident and was documented.
!
The ignition source activity on Elevation 269 of the Unit 2
!
Turbine Building was immediately suspended upon notification
of the absence of a fire extinguisher in the immediate area
contrary to procedure A-12.
1
Corrective Actions to be Taken to Avoid Future Non-
Compliance:
Further corrective actions were taken by January 20, 1987 to
prevent the recurrence of a grinding activity being performed
without the presence of a fire watch.
Either Philadelphia
Electric Company or Bechtel personnel were assigned fire
watch responsibilities for the duration of the subcontractor
activities.
This subcontractor has completed its work
activities.
A fire watch video training program was created and presented
to Bechtel personnel who are expected to function as fire
watches.
This program is designed, among other things, to
prevent the recurrence of a fire watch failing to have a fire
extinguisher in the immediate vicinity. .
Date When Full Compliance Will be Achieved:
Full compliance was achieved by March 1, 1987 when the
training of fire watch personnel was completed.
!
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Mr. Stewart Ebnater
March 19, 1987
Page 4
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If you have any questions or require additional
information, please do not hesitate to contact us.
Very truly yours,
cc:
Dr.
T.
E. Murley, Administrator, USNRC, Region I
E. M. Nelly, Senior Resident Site Inspector
See Attached Service List
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PHILADELPHIA ELECTRIC COMPANY
23Ol MARKET STREET
P.Oi. BOX 8699
PHILADELPHI A. PA.19101
tanu e4i. san
JOSEPM W. G ALLASHER
.i*.*. .~.*.*.'.*IE.. .
March 19, 1987
Docket No. 50-352
Inspection Report: 50-352/87-02
Mr. Stewart Ebneter, Director
Division of Reactor Safety
U. S. Nuclear Regulatory Commission
Region I
ATTN: Document Control Desk
D.C.
20555
Dear Mr. Ebneter:
Your letter dated February 11, 1987 forwarded Inspection
Report 50-352/87-02 for Limerick Generating Station.
Appendix A
of your letter addresses an item which does not appear to be in
full compliance with Nuclear Regulatory Commission requirements.
This item is restated below followed by our response.
The
delayed submittal of this response was discussed in a telephone
conversation between W. M. Alden of Philadelphia Electric Company
and A. Krasopoulos of the NRC staff, and a one-week extension was
found acceptable.
-
Violation:
10 CFR 50 Appendix B Criterion V requires that " activities
affecting quality shall be prescribed by documented procedures
and shall be accomplished in accordance with these procedures."
The Licensec's Administrative Procedure A-12 Ignition Source
Control Procedure stipulates that "the ignition source worker
prior to first using the ignition source shall ensure that the
required types of fire watches are in place and have the
appropriate fire extinguishers."
Contrary to the above on January 9, 1987 on Reactor Building
Elevation 313, Area 11 a grinding operation was taking place
without the required fire watch.
Also on January 8, 1987,
a
welding operation was taking place in the corridor of Elevation
269 Turbine Building Unit 2, on Unit 1 piping without a fire
extinguisher in the immediate vicinity.
This is a Severity Level V Violation. (Supplement 1)
l
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Mr. Stswsrt EbnSter
Msrch 19, 1987
Page 2
,
4
1
Response:
!
Admission of Alleged Violation:
Philadelphia Electric Company acknowledges the violation in
that two ignition source work activities, which required
adherence to Administrative Procedure A-12, " Ignition Source
,
Control Procedure", were not performed in accordance with the
procedure's requirements for fire extinguishers and fire
watches.
f
Reason for the Violation:
The reason for these two incidents was personnel error in
);
that the personnel involved did not perform their work in
i
accordance with procedural requirements.
]
The absence of a fire watch on January 9, 1987 on Elevation
,
313 of the Reactor Enclosure resulted from a subcontractor
mechanic failing to implement procedure A-12 by resuming
grinding after his morning break, prior to the return of the
designated fire watch,
l
On January 8,
1987, a fire extinguisher was not in the
immediate vicinity of the ignition source activity on
Elevation 269 of the Unit 2 Turbine Building because the
dedicated fire watch failed to implement procedure A-12.
The
<
l
fire watch believed that it was acceptable to know the
location of the nearest fire extinguisher rather than have a
fire extinguisher readily available in the immediate
vicinity.
i
Significance of Violations
Elevation 313 of the Reactor Enclosure contains 2 load
centers associated with fire protection safe shutdown methods
for Unit 1.
These load centers are located in the northeast
quadrant of the Reactor Enclosure, approximately 120 ft. from
the location of the grinding operation.
As a result of this
distance, the possibility of a fire at the grinding location
!
having an adverse impact on the capability to safely shutdown
i
Unit 1 is small.
i
The probability of a fire resulting from the ignition source
activity within the security corridor on Elevation 269 of the
!
Unit 2 Turbine Building was very low due to the absence of
combustible material in area.
Additionally, if a fire had
i
occurred, it would have had no adverse impact on the
'
capability to safely shutdown Unit 1.since this area is well
l
.-_ ._.
-.-
- - . - - .
-.
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.
- - . - _ . -.
- - - - .
-
- . . . - -
-
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Mr. StswSrt Ebnster
March 19, 1987
Page 3
.
outside of the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire. barriers protecting Unit 1 safe
shutdown equipment.
Although a fire extinguisher was not in
!
the immediate vicinity of the ignition source activity, one
was located in the same enclosed corridor which could have
been reached and used quickly in the event of a fire.
,i
Corrective Actions Taken and Results Achieved
i
The immediate action to prevent a recurrence of the absence
of a fire watch on Elevation 313 on January 9 was that the
vendor reinstructed its site personnel in the requirements of
i
A-12.
This training session was completed on the day of the
incident and was documented.
,
The ignition source activity on Elevation 269 of the Unit 2
Turbine Building was immediately suspended upon notification
of the absence of a fire extinguisher in the immediate area
contrary to procedure A-12.
J
Corrective Actions to be Taken to Avoid Future Non-
Compliance:
Further corrective actions were taken by January 20, 1987 to
prevent the recurrence of a grinding activity being performed
without the presence of a fire watch.
Either Philadelphia
,
Electric Company or Bechtel personnel were assigned fire
!
watch responsibilities for the duration of the subcontractor
i
activities.
This subcontractor has completed its work
activities,
j
'
A fire watch video training program was created and presented
to Bechtel personnel who are expected to function as fire
watches.
This program is designed, among other things, to
'
prevent the recurrence of a fire watch failing to have a fire
j
extinguisher in the immediate vicinity.
l
I
i
j
Date When Full Compliance Will be Achieved:
Full compliance was achieved by March 1,
1987 when the
training of fire watch personnel was completed.
!
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Mr. Stswart Ebn2 tor
March 19, 1987
Page 4
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If you have any questions or require additional
information, please do not hesitate to contact us.
Very truly yours,
cc:
Dr.
T.
E. Murley, Administrator, USNRC, Region I
E.
M.
Kelly, Senior Resident Site Inspector
See Attached Service List
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