ML20207U082
| ML20207U082 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/19/1987 |
| From: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| CON-#287-2943 OL, NUDOCS 8703240595 | |
| Download: ML20207U082 (4) | |
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s PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.0L BOX 8699 PHILADELPHIA. PA.19101 1215 e41 sool JOSEPH W. G ALLAGHER o.T.I.~.'/.'."I"7.
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 Washington, 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 dircussed 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 Licensee'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.
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This is a Severity Level V Violation. (Supplement 1)
I 8703240595 B70319
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0 PDR ADOCK 05000352 p
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l Mr. Stswart'Ebnator March 19, 1987 Page 2
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 l 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 location 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 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
Mr. Stewart Ebneter 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.
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.
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 ti.
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 Ebneter March 19, 1987 Page 4 If you have any questions or require additional informatioa, 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 4.
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