ML20095E731

Responds to NRC Re Violations Noted in Insp Rept 50-352/92-03 on 920105-0215.Corrective Actions:Procedure Use & Compliance Training Module Developed Re Methods to Change Procedures & Event Reviewed at all-hands Meeting on 920305

ML20095E731
Person / Time
Site:	Limerick
Issue date:	04/23/1992
From:	Leitch G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9204280015
Download: ML20095E731 (5)

Text

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, , 10CPR2.201

, PillLADELPIIIA ELECTRIC COMPANY LIMERICK GENERATING STAllON P. O. BOX 2300 POrITSTGVN, PA 19464-0920 (215) 327-12(0, EXT.XOJ April 23, 1992 GRAHAM M. LDTCH 44,rncI$curNswxw Docket No. 50-352 License No. NPP-39 U.S. Nuclear Regulatory Commission Attn Document Control Desk  :

Washington, DC 20555

SUBJECT:

Limerick Generating Station, Unit 1 Reply to a Notice of Violation NRC Combined Inspection Report Nos. 50-352/92-03 and 50-353/92-03 Atteched is Philadelphia Electric Company's reply to a Notice of Violation for Limerick Generating Station (LGS) Unit 1, which was contained in the NRC Combined Inepection Report Nos. 50-352/92-03 and 50-353/92-03 dated March 24, 1992.

The Notice of Violation identifies the failure to follow an approved maintenance procedure during maintenance on the Unit 1 "B" Residual Heat Removal heat exchanger inlet isolation valve (HV51-1F014B).

The attachment to this letter prcivides a restatement of the violation identified during an NRC inspection conducted between January 5, 1992 through February 15, 1992, at LGS, Units 1 and 2 followed by our response.

If you have any questions or require additional information, please contact us.

E Very ul yours,

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DS/JLPicah Attachment cc T. T. Martin, Administrator, Region I, USNRC T. J. Kenny, USNRC Senior Resident Inspector, LGS 9204280015 920423 PDR ADOCK 05000352 O PDR j/ f c . - .. - - - -

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Attachment Page 1 of 4 Docket No. 50-352/92-03 Reply to a Notice of Violation Restatement of the Violation i

During an NRC inspection conducted on January 5 through February 1 15, 1992, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Prccedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1992), i the violation is listed below:

Limerick Technical Specification 6.8.1.a. requires that written procedures be established, implemented and maintained to cover the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. For maintenance that can '

affect the performance of safety-related equipment, Regulatory Guide 1.33, Appendix A, Section 9.a. recommends it be properly i preplanned and performed in accordance with written procedures, documented instructions, or drawings, Contrary to the above, on January 14, 1992, during maintenance on the residual heat removal heat exchanger inlet isolation valve (HV51-1F014B), the approved maintenance procedure PMO-500-087, ,

" Preventative Maintenance Procedure for Electrical Checkout and .

Adjustment of Limitorque Operators," was not properly implemented as evidenced by-the following exampless.

1. Procedure PMQ-500-087, prerequisite steps 4.2 and 4.4,  :

requires the job leader to record the appropriate torque switch settings and stroke time data, from the Field Engineering Data Sheet, on the Maintenance Data Record Form.

The job leader failed to record the torque switch settings and stroke times.

2. . Procedure PMO-500-087, step 7.9.2, requires the performance of a stroke time-test of the motor operated valve and  :'

verification.that the results are acceptable. The job leader signed this. step as complete without verifying the  !~

acceptability of the stroke time-test results.

3. Procedure PMO-500-087, step 7 10.1, requires the mechanic and 1 quality control inspector verify that test switches, installed earlier in the procedure, are removed. Both the mechanic and-quality control inspector annotated thin step as not applicable although the mechanic actually removed 1he switches.

This is a Severity Level IV Violation (Supplement I).

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Attachment Page 2 of 4 Docket No. 50-352/92-03

RESPONSE

i Admission of Violation Philadelphia Electric Company (PECo) acknowledges the violation.

Reason for the Violation The cause of the violation is procedural non-compliance due to lack of attention to detail on the part of the individuals who performed and verified perfor9ance of the preventive maintenance procedure coupled with a less than adequate procedure ir regards to technical direction and human factor aspects.

The maintenance job leader (mechanic) involved in this event believed that recording the torque switch data au specified in procedure PHo-500-087, step 4.2 was not required bec ese no torque switch setting was to be made. Non-cornllance Uith steps 4.4 and 7.9.2 occurred when the maintenance job leader requested stroke time settings, but was unable to obtain the data and the job proceeded without it. The maintenance job leader stated that he was comfortable with the content of the procedure and was not reading the procedure step-by-step which caused the procedure non-compliance for step 7.10.1. The quality verification inspector misunderstood the conditions that applied to procedure PMO-500-087 step 7.10.1 as stated in the Maintenance Data Record For- (MDRP) because the MDRP only partially stated this step.

PMO-500-087 was inadequate in the following ways:

1. It referred to Field Engineering (a group that no longer exists) and to MOVATS testing (a valve diagnostic method that is no longer utilized at Limerick).

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2. Prerequisites require recording data in the remarks section of the MDRP rather than at the procedure step being performed.

3. Multiple tasks are included in only one sign-off step.

4. The procedure did not specify when VOTES testing (a valve j diagnostic method currently utilized at Limerick) was l required after limit switch adjustment.

5. Sign-offs for some steps do not adequately describe the content of the procedure.

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Attachment Page 3 of 4 Dochet No. 50-352/92-03 Corrective Action and Results Achieved Because of previous occurrences of a similar nature, the lack of procedural compliance discovered during this event was quickly

' l recognized as a generic problem throughout the '

Maintenan:e/ Instrumentation and Controls (I&C) organization. On

. February 13, 1992, the Maintenance /I&C Superintendent issued a stop work order that implemented a review system by upper level Maintenance /I&C management of all work before it in performed to ensure that procedure ;mpliance is fully implemented within the culture of the organization. Thn quality verification inspector l

involved with this event was restricted from performance of inspection duties. '

Corrective Actions Taken to n/oid Puture Non-Compliance The following actions were taken to avoid future non-compliance due to a lack of attention to detail

1. This event was reviewed in a Maintenance /I&C section all-hands meeting on March 5, 1992 to stress the importance i of attention to detail when using procedures.

2. A procedure use and compliance training module was developed .

within the Maintenance /I&C Section. This training included the methods to get procedures changed. This training was i given by individual first line supervisors to their work teams between February 24, 1992, and March 6, 1992.

3. A performance improvement plan was developed for the quality verification inspector involved in this event by quality verification supervision that included remedial training, a written examination, and a performance demonstration prior to allowing the quality verification inspector to renume his inspection duties on Nirch 20, 1992.

4. An all-hands meeting was held on February 14, 1992, with quality verification section personnel to identify the '

problems'with activities associated with this event, to reinferee management expectations for inspector performance I and to heighten the awareness of the maintenance problems to i the quality verification planners.

l l 5. - An additional all-hands meeting was conducted on March 20, 1992, to reinforce to all quality verification inspectors management's expectations regarding strict procedural-compliance, attention-to-detail, customer focus, and independence of the quality verification section. This meeting included' emphasis on For Your Information (FYI) notice FYI-12, " Attention-to-Detail" and PYI-15, "Use of ,

Procedures," which provide a clear, concise set of written management expectations to first line supervision who then

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Attachment Page 4 of 4 Docket No. 50-352/92-03 disseminate the expectations to station' personnel; work order planning; the process for revising the scope of work orders; the proper method of reconciling discrepancies between procedure text and-MDRF; the Temporary Change process for procedures; and referral of issues which require interpretation or are controversial in nature to quality verificaclon vupervision.

6. To determir.e the potential generic implications of this event, quality verification management is conducting an analysis to identify barriers which may rccuire strengthening. This review is expected e completed by May 1, 1992.

The following actions were taken to avoid future non-compliance due to less than adequate procedures:

1. PMO-500-087 was revised on March 17, 1992 to include require (

VOTES testing, improved human factor aspects, and better defined acceptance criteria. All procedures thet interface with motor operatored valves were reviewed-to update Maintenance /I&C organizational changes,-work control processes, and VOTES testing requirements.

2. Maintenance Guidtiine MG-20, " Post-Maintenance test ng," was .

revised on March 11, 1992, to be more specific about IJmit switch adjustments and VOTES testing.

Date When_ Full Compliance was Achieved Full compliance was achieved on February 13, 1992, when a review system by upper level Maintenance /I&C management of all work before its performance was implemented. Following the completion of the corrective actions previously described, first line management in Maintenance /I&C became responsible for procedural compliance of maintenance activities, i

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