ML20244E418
| ML20244E418 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/14/1989 |
| From: | Mccormick M PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8906200331 | |
| Download: ML20244E418 (4) | |
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10CFR2.201 PHILADELPHIA ELECTRIC COMPANY l
LIMERICK GENER ATING STATION P. O. BOX A -
SAN ATOG A, PENNSYLV ANI A 19464 (215) 3271200 zur. 2000 M,' J. M cC O RM IC M, J... P.E. '
$,...'. 2 *.".'."."((.*,.* ".....
Docket No. 50-352 License No. NPF-39 g
l-U.S. Nuclear Regulatary Commission L
ATTN:
Document Control Desk
' Washington, D.C.
20555
SUBJECT:
Limerick Generating Station, Unit 1 Reply to a Notice of Violation NRC Combined Inspection Report Nos. 50-352/89-09 and 50-353/89-15
.NRC letter dated May 16, 1989, forwarded Combined n
.. Inspection Report 1.'os. 50-352/89-09 and 50-353/89-15 for the Limerick Generating Station, Units 1 and 2.
This Inspection Report contained a Unit 1 Notice of Violation concerning the failure to follow procedures during the performance of
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maintenance on the Main Steam Safety Relief Valves.
Our response to this Violation is provided in the attachment to this letter.
In the Inspection Report a Quality Control Work interface weakness was identified.
Corrective actions for the weakness are being identified and implemented and, upon completion, the NRC resident inspector will be notified.
If you have any questions, or require additional informat' ion, please contact us.
Very truly.yours l,
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l DCS:bg Attachment cc: W. T. Russell, Administrator, Region I, USNRC f
l-T. J. Kenny, USNRC Senior Resident Inspector I
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8906200331 890614 PDR ADOCK 05000352 k
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Page 1.of 3
' Docket No. 50-352 VIOLATION:
Plant Technical Specification 6.8.l' requires written procedures to be-established, implemented and maintained to m
control,various plant activities.
Maintenance Procedure M-041-007 provides measures for the control of' work on the Main Steam Safety Relief Valves to ensure the work is performed properly and damage to the i-'.
valves'does not occur during valve disassembly and L
reassembly.
Contrary to the above, during the disassembly of Main Steam Safety Relief Valve PSV-041-lF013L, damage occurred-to the valve as a result of failure to properly adhere to procedural cautions, and the unauthorized use of a hydraulic jack which was not specified by the procedure.
This is a Severity Level IV. violation (Supplement I).
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4 Attachment Page 2 of 3 Docket No. 50-352
RESPONSE
Admission of Alleged Violation:
Philadelphia Electric Company acknowledges the violation.
Reason for the Violation:
The primary cause of this violation was PECo supervision did not assure the contractor personnel were familiar with the Main Steam Relief Valve work prior to the start of work as is normal practice.
Also it was not clear to the workers what involvement contractor and PECo supervision should have when a problem occurs during job performance.
On March 22, 1989, the Maintenance Engineering Technical Staff was notified that the contractor could not reinstall the pilot cartridge assembly into PSV-041-lF013L.
Upon investigation it was determined that the contractor had improperly rigged the MSRV pilot cartridge violating step 7.1.19 of M-041-007.
Because the valve was located in the drywell, proper rigging for removal of the pilot cartridge was difficult to achieve.
This improper rigging caused the pilot cartridge to be cocked and wedged in the MSRV pilot bore.
The contractor then used a single Enerpac Hydraulic Jack, and jacked the pilot cartridge out of the MSRV pilot bore.
This burred the pilot bore, and bent the pilot cartridge.
Procedure M-041-007 does not provide for the use
- of a hydraulic juck to remove the pilot cartridge.
Corrective Actions Taken and Results Achieved:
When the contractor group foreman notified the utility sub-forem4". of the problem with PSV-041-lF013L, the Maintenance Engineering Technical Staff performed a L
dimensional check of the pilot cartridge bore, and a concentricity check of the pilot cartridge.
The pilot cartridge bore was honed to within the manufacturer's specified tolerances and the pilot cartzidge was replaced with an identical spare with the same.ntpoint.
After successful performance of the Operational Hydrostatic and Surveillance Testing, which strokes the MSRV pilot valve, the valve was declared operable.
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Attachment Page 3 of 3 Docket No. 50-352 l
Corrective Actions Taken to Avoid Future Non-Compliance:
This event will be included in future training as an example of the result of non-compliance with PORC approved procedures.
Additionally, PECo supervision, vendor supervision and vendor craft roles will be clarified when vendor craft perform maintenance work for PECo, particularly during outages.
This clarification of each individuals role will improve communications.
The roles of vendor craft, craft supervision, and PECo supervision will be reviewed during each work group meeting by July 30, 1989.
In addition, prior to the next refueling outage, each group will be indoctrinated as to the role of vendor craft, vendor supervision and PECo supervision while performing maintenance work activities.
Maintenance Procedure M-041-007 will be revised by September 30, 1989, to normally require pilot valve rotation of the MSRV outside of primary containment prior to valve installation to ensure a vertical rigging lift.
If a pilot assembly must be rotated inside containment, a separate instruction identifying rigging pick points and rigging equipment will be prepared prior to performing this work.
i Training of contractor personnel will emphasize the t
importance of strict adherence to procedural guidance.
Date When Full Compliance Will be Achieved:
The pilot cartridge bore and pilot cartridge were repaired / replaced as required and the work package was completed.
The v&lve was tested and declared operable on April 27, 1989.
The roles of vendor craft, craft supervision, and PECo supervision will be reviewed during each work group meeting by July 30, 1989.
Revision of M-041-007 will be completed by September 30, 1989.
The completion of these actions will ensure compliance with plant Technical Specification 6.8.1.a.
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