ML20102C175

Requests Reconsideration of 850213 Decision Not to Issue Show Cause Order Revoking Low Power Ol.Addl Info Demonstrating Deficiencies in Safety Equipment & Procedures & Noncompliance W/Nrc Regulations Submitted

ML20102C175
Person / Time
Site:	Limerick
Issue date:	02/25/1985
From:	AFFILIATION NOT ASSIGNED
To:	Harold Denton Office of Nuclear Reactor Regulation
References
NUDOCS 8503050340
Download: ML20102C175 (6)

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Mr. Harold R. Danten,Direc tor Her 186 Moylan,Pa. 19065 NRC Office of Nuclear Reactor Regulation Re:Phila Elec. Limerick Gen.Sta De 2et No. 50-352,353 Washington, D.C. 20555 2/25/85

Dear Mr.Denton,

This is a response to your letter of February 13,1985 In enawering our setition of 12/23/84 ,asking that NRC issue a show cause order on the revoking of the low power operating lisense issued to PECe on 10/26/94, you say that your preliminary review indicates that we have provide 3 no nen information to prompt such an orderthat and none gtnese of matters requires the immediate action we requested, and you decline to take immediate action in raspon se to our petition .

NECESSITY FOR I4GDIAT3 ACTION TO REVOKE THE LICNESS.

We respectfully ask that you reconsider your decision not to issue a show cause order. Furthe rmo re , we submit here additional information from the NRC records on Limerick systems , plant,and operation which demon,trate conclusively that thd Limerick plant is defielent in vital safety equipment and urocedures, has had is. not in compliance with a # umber of essential NRC regulations,and ga series of PECo personn'el errors and supervisory lapses since the start of fuel loading,to which the present, gdemonstrate that PECo is not able at this time to operate the olant without continuing nuclear accident probabilities which threaten the health and safety of the public and PECo employees g and NRC ,taff.

SYST:CIATIC ASSESSMENT _ OF LICENSED FERFORMAUCS 12/1/83- 11/30/84 (Dated 1/14/85 NRC)

IV =

TABL3 3. Violations of NRC regulations, Severity Level,16, Level V- 10= total 26 Since the start of fuel loading in October , through Nov. '84 - 8 violations involving Startup Testing, Oserational re adiness,and Security, There were a total of 22 Con s truction Deficiency Resorts caused b error, Design error, Component error,and Construction error. (TABLE 1.)y Personnel page 10. ".. performance in the area of preservice inssection was weaker than that in other con struction areas." This weakness in preparation to operate is reinforced by:

p. 16: .." a summary of weaknesses identified at each exit meeting.." ,

" 1. Additional training..needed...centrol room logie.."

2. Increased training..... manual scrams..

3. Additional training.. area of fire fighting,.. radiation monitoring.. refueling..

Em mmo J. An overal weakness. . current simulator text materials . . "

01oc.

PECO RESPONSS TO FOUR VIOLATIONS RECORDED IN NRC INSPECTION 84-65,84-14(2/11/05)

LJ " TABLE 1.-CAUSSS OF INCIDSNTS." PECe classifies the Licensee Events which it o:c reported from the start of fuel lo, ding, 10/26/84 to 12/31/84, and the events

%8 from 1/1/85 to 1/31/85; 48 and 26 Events respectively,- 74 Total.

oo m< o This is an average of one Event / 1 35 Days - 10/26to1231 om

/ 1.2 "

1/1 to 1 31/85 co

""g It apoears that each of these Events had the votential to precipite.te a nuclear accident, anji the rate at which they are kapiening increased in January 1985 Attack n3 Error- 27 ;De.ign..Deficiencey. 31 ; Procedure and f Other defle& 4 "Personneliencies = 16* . Total - 74 Ih ))

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The tot.gl of 74 Licensee Events in the 96 days since PECo storted to load nuclear fuel to the end of January, constitutes a warning that PECO 13 not quali-fied to conduct the nuclear rewetion erosess safely. One third of the Events sere caused by personnel error and more thana third ware esused by deficiencies in tha slant. FEco arvaars unable to control the former catagory and many dasign deficiencies cannot be changed,it appears. concern

'J. J.C ooney ( PECo) , A s s. A .. 1. exeresses tha comsany's ybut offers no seecifio slan of netion to correct tne errors. He merely says that PECo will " stress to employees that they cust take sufficient "

time to s aeerly evpluate and eerform g

tasks inde,sendent of schedule needs.

Thera assears to be no assurance that ?indings on Violations B,C, and D, Aip A,s.5-7 will not be re eeated: o=erators stnrting recirculation pums without floor drain t.nk relessed to blowdown line, the restoring and required tests theand verific.'

Reactor ion,on sussly bre.kers without following the Protecti established prose &bres, and Violation A, p. 3," disassembly and removal of re-quired pine whip restraints..".

GVI3A OF MitC ILSFECTIOS dJi O.tT3 -33PTht 1H4 to JdJ.LtY 1995

'!RC'g 4LP Re sort ,1/14/95. TA3LS 3, s.3-5 records 12 Viola tions of nhC regulations E]Hrough deport 84-69. leiorts 35-01 and 85-09 add two more viola-tions and one Deviation through 1/21/95 These reports testify as to PEco's inability to o=erate the Limerick reactor safaly. In addition to' the .vtalations. there are a series of excaptions and deviations which ram 31u open. Te are not aware of any summary which closed out these osen itez"eseecially the ones required before initial critionlity. Some of the inspectors' warnings about PECo's . unsatisfactory oseration follow:

Insp. 84-65 (1/11/85) p.1. " In addition I note that since the stnre of fuel load activities there have been, several instances of problems which apsarently have involved personnel errors.... they may be indicative of an adverse trend. "

94-70 (2/7/85) para 8. " .. shif t turnover activities resulted in a very noisy and di tracted period, principally due to the various work groupe and other per-sonnel not displaying the discipline that should be exercised in the control room."

85-01 (1/22/85) s.1. "... the problem with the two containmant isolation valves resulted from a personnel error which occurred during the 31eoperational, tcat progren.... we are concerned that the error "has gone undetected by both the qual-ity Asnuro.nce and elpnt testing programs.

85-09 (2/1/95) p.1. " ..an error made by a licensed operator. This error was not detectad and prometly corrected by the senior-licensed su'ervisors on shift.

We are concernad about the aynarent wenkness in the controls exercised by these siservinors over licensed oierator activities..."

84-65. M.J.Cooney to NRC ( 2/11/95, Asp.A. n.1. "PICo mamagement has also been concerned with the numbar of License Event leports e.nd suspected licensee event resorts... "

It aisears ,d so, that the NRC Commissionars have been aware of these errors since the issuance of a low power license to PECo. From transcript of 1/9/85 Cormission meeting ( p.35) " Concissioner Zech: My review of the Limerick per-formsnce during their low power tenting indicates that they have been havidg some probinas mainly due- it seems to me - in the area of personnel errors,perhaps a few more than we might expect."

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OTHER DEFICIENCId3 IN PLANT SAFETY BASED ON NRC INSPECTION EXCEPTIONS AND DEVIATIONS Some of the predominant deficiencies carried as unrasolved items in the Inssection Reports are summarized below. In this section and the following sec-tions we attempt to make the connections between Limeriek's deficient equipment and procedures which,in interaction with poorly trained personnel and questionable supervision,have combined to produce such an alarming series of licensee events, and which are headed in the direction of nuclear acoidents if PECO is allow ed to continue to operate the reactor under the current conditions.

We sense that the disjointed activities at Limerick under the low power license have been brought about largely by the lack of confidence of the personnel in their own training and the workability and safety of the plant. The denger-ous operating an3paintenance mistakes have involved the control room,the reactor primary containment and the automatic sefety systems. testing and monitoring procedures and *ctivity have afforded the setting for mistakes as well.

Violations, exceptions, Plant location or Systam Inspection 84-53 cables control room 84-57 Emergeney ventil. tion . detectors . access doors solid, liquid, gas monitoring post accident standby ras treatment reactor b1dg.

84-66 sampling (16 unresolved items) " "

desiduni Heat Removal pump valves 84-64 thel bundle channel severely scr atched in handling

• refueling floor 28 osen test exceptions; 11 closed by PECo no NHC

• ( Also fuel bundle hit pool wall, 8/22/84."kndI7 84-43, 9/21/84, para.6.)

84s65 equi pment for habitability, unresolved control room personnel errors pipe whip restraints, reactor building reoirculating pump without required test, floor drain relegse, improper restoring service reactor protections Loss of -20 VDC neutron monitoring 84- 70 ventilation control room 31 open test exceptions (practically the same items as 84-64,above.)

84-72 equipment feilure, emergency ventilation centrol room di s c re pe.ncy , inboard and outboord valve isolation reactor water cleanup loss of -20VDC power, caused by technician shorting reactor b1dg.

85-01 testing, rework and inspection error centsinment isolation wiring error in monitor relay. This necessitsted refueling area verifying documentation for all secondary containment isolation for automatie closure frcs all isolation signals 85-08 operator error: both containnent isointion valves ascer wat-r cleanup rendered inoperable for seven minutes SAFETY EVALUATION REVIEW BEFORE INITIAL CRITICALITY 7e have no indiention that there was any summary or review of opan insyse-tion items, ereestions, violations or deviations which were required to be resolved before the # 1 reactor fission process was started on 12/22/84 and initial criti-eality reaggeg. We have no adbranee tant the items in the inspection reports (above) which were g resIlved before initial criticality, were resolved,and that some of them still may be open at this time. Lacking the fulfillment of all requirements for criticality, we assert the reactor operation is not in compliance with NRC regulations + and the low power licen e s should be revoked immediately.

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INEVITABILITY OF EkdOR AND ACCIDSNT IN THE LIMEdICK SUCLSAR OPZRATION l PSCo's analysis of the causes of the incidents (potential accidents) at Limerick , from 10/26/84 to 1/31/85 , total - 74, ( Cooney PECo response to NRC Insp. 84-65, 2/11/e5 Attachment, p 3,4.) assigns 27 to Personnel Error, 31 to Design Manufactiring, Construction / Installation Deficiency, an d 16 to l Procedure Deficiency and Other Causes.  ;

Under Personnel _ Error the general categories are:

Failure to follow proc e dure . rule s , re gula tion s 10 Failure to communicate, observe changing cenditions, interpret information 8 Failure to perform required insnections/ tests 5 Other Personnel Errors 4 We assume that many of these errors derive from the complexity of the plant and will continue to escur because the processes and equipment will never be successfully understood by the operators and maintanance workers. It should be noted that PECo's reliance on training at its Peacch Bottom plant.eeund cause falso confidence pince the difference in complexity of the two plents can make much of the experience not transferr able.

Under D,esign..Def_toiencies there may be some factors which can be corrected or modified,but many of these deficiencies will continue to interact with,and aug-ment personnel errors. They can continue to bring about employee disillusionment and carelessness. -

Under Procedure Deficiencies and Othar there are factors which can mislead employees,or subject them to blame for errors in observation or jud ment. Here there is, also ,the potential for continued degrading of personnel morale.

The record of 74 incidents (potentiel accidents) in 96 days afford a measure of the design and construction deficiencies an(hk'te personnel errors. On closer examination they show that there is no cure and the"inoidents" will continue to accumulate.as long as the deficiencies in. )lant and personnel nersist in the present form.

There can be so solution without a revoking of the license and shutting down the reaction process,followed by a radical review of and correction sf and repincoment of all construction and procedure deficiencies. In addition there will have to be a re-defining and simplification of operating procedures with re-education r.nd requalification of operators and supervisors.

For the present there is no way to e rercome the deficiencies er to rebuild the ability of the personnel to function safely in an environment where they de not have confidence in the plant er taoir understanding of the process or their effest-iveness to handle it. As exa mples of the factors which have undermined morale' we cite the demoralizing effect on employees of :

22 unexpexpected automatie isolations during the first 75 days with fuel in t'ne reacter, 10 incidents during surveillance tests, and 5 somplete automatie shut downs of the reacter.

Repeated incidents [8c$ured, isolating the centrol room because of tae breaking of t'ae tape en a monitor. LERs(84-06,08,10,20,28,33, . 46 )

Mysterious isolation of t'ae reactor enclosure occured,apparently as the result of a monitor recording high winds outside the plant. ( 84-45, 85-5 )

Automatio isolation of the Reactor Water Cleanup System resulted 6 times when operators switched t'ne monitor to " Read". ( 84-12,26,34,35,36 , 85-01 )

To overcome this repeated malfunctioning the opera +ers opened bet'a inbeard and autheard nower breakers of the isolation v lves a for the roaster water cleanum system. This lef t the system for 7 minutes without isolation iretection en i/15/85,

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in diroot violation of NRC regulations.

Had the reaetor been operating at higher power at the time of this incident there would have been the potential for release of consider a ble radiopativity to the building in ease of a nuclear accident.( NRC Insp.85-08, dated 2/1/85 , para.3.)

RELATIONSHIP OF INCIDENTS (LERs) TO LICENSE REQUIREMENTS AND SXEMPTIONS.

There are undoubtedly many causal sonnections between faulty construction and faulty procedures waich we have not had time to relate to specifie incidents, but the PECe letter (ibove) with Atta hment, e Table 2 sets forth the deficiencies under these eategories: Inadequate application of design principles, Construe-tion /insta11stian errer, Peor workmanship, Testing not facilitated by design, HVAC air balancing not performed.

Most of the 31 eategories of design and cor etruction defielencies listed in Table 2 (above) aave contributed to operating incidents and will accelerate,/ to moreserious safety breaches if PECe is allowed to continue eseration of the reactor.

We further and that NRC must be held responsible for the lack of review of all the surveillanse tests required before initial critie.11ty as set forth in License NPF 27 , 10/26 There are 11 sategories (para.1.)

and 4 entagories (para. 2.)/84, Attachment 1.

These tests are listed in Appendix B,(NRC Insp. 84-70, 2/7/85). Para 6.

specifies a total of 120 surveillance tests required prior to initial eriticality. ,

In this inspection we find that the inspector reviewed.enly a s e mple, "12 seleet-ed complated surveillance (denoted by R in Apsendix B)fer specific complianee with the technical specifications and also reviewed seven selected procedures ( denoted by P in the appendir ).."

We a r e not aware of any certifiention that the remaining 101 surveillanee tests were reviewed by NRC. In NRC Insp. 84-72,1/21/85, Initial criticality Preparation , para. 6.1, there is this general statement : "All test exceptions designated as initial critica lity items were satisfactorily resolved prior to commencing the reac tor startup. " We have seen ne record te subs tantiate that the requirements of Attachment 1,te License NPF 27, relating to tests and test exceptions were fulfilled priar to initial criticality.PECe and NRC are,therefore, not in compliance with NRC regulations and the public is being subjected to l conseq sent risks beca use cf deficient safety facilities and protections . The license should be revoked.

l The connections with incomplete tests,excsytions, violations and unresolved safety items show up in the record 6f incidents through1/10/85 There are 10 connected with the control room, 9 connected with t'ae reastor enclosure, and 11 sonnected with reactor water cleanup system. The to improperly granted in LicenseNPP 27 also make these areas more vulnerable exemg/8astecontrolpanel for the control room; incomplete isolation protection for the hydrogen rec,ombiner, j deferred inspection of airlock doors, and absense of standby ga s . treatment to j tne refueling floor for the reaetor enclosure.

FURTHER UNCERTAINTY OVER DESIGN AND CONSTRUCTION.

T'ne Independent Design Review of the Limerick No 1 Core Spray System,eom-misnioned by PECe and completed by Terrey Pines Technology in November 1984, eencludes that the system was probably construoted an d will function as planned.

There are two disturbing features,however, w'a iah cas t a oleud over the design work at Limeriek done by G.E. and the planning and calculation for safety features by Beistel Power Corp.

The G.E. desig'n control program was missing 10 items for th= Core Spr y System d e s i gn , n e e d e d to authentisate the design adequ rey review. Despite G.E.'s attenyt L_

p. s -s

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at a" technical review"of t'ae 10 items, we are not persueded that the possibility of desirn flaws have been ruled sut. This y,rt of t'ne Core Spray System is,there-f are, sus pec t.(Terrey Pine s Report, Vol. 2 p.29)More far reashin g,however, is the uncertainty about other G.E. designs for LLmerick of the .same period in which a design adequ,cy review may be hampered by t'ae lack of dooumantation of a G.E.

design control program. We have not seen any documentation to warrant the Report's optimistie conclusion (3.29): "These procedures and descriation, coupled with af-fidavits . . . .provided a high degree af assuranee that all required reviews were performed and documented..."

The Limerick operating license osould be revoked until proper verifiention of t'ais aspect of G.B. 's design for equipment and s/ stems has been completed.

The Torrey Pines study also broug'at te light serious flaws in t'ae Limerick

" slant safe sautdown serability fe11 ewing postulated breeks in the core spray line."

(PFR's2524-023and2524-024,p. 56 ) The study found errers in evaluating safe-shutdown because of " (a) taking credit for instruments w'aiah could aise be lost a s a consequence of g line break; (b) taking eredit for instruments which were not identified on the instrument list and not in the plant design; and (e) not assuming t'ae wors t case single active failure with the line break."

The study discovered that these errorf applied to theAutomatic Depressurizing System,the Reactor Trote= tion System and thh Containnent Isolation Systen as well as the Core Spray System, but concluded :" Determining the impset of these various

~ errors would.have required a knowledge of all ytant systeds end components..."

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The Terrey Pines study was not authorized to make a design adequacy review of any of the safety systems for safe s'aut denn , except t'ne Core Syray System.

The warning in its report,however, should have caused NRC to stop PECe from bringing the reaeter to initial criticality, and should have suapended the license sEnoe the safe aiutdown capability was t'arown into question because of the"e rrore and inconsistensies in the analysis t'ast was used to s'aos plant safe 1hutdown.."(p.56 The eenclusive evidence wass

.." Because Torrey Pines (TPT) was unable to assess t'ne impact of these j orrors,and because t'ae repetitive nature of the errors suggested that et'aer errors i mig'at oscur, the tua PFas were elassified as findings. "

The corrective action proposed by PECe (p.56) " safety eva lu ation ealculations asrosiated with jet impingement " does not address Torrey Pines questions about l "all 31 ;nt systems and components" and " taking credit for instruments which could also be los t ,.. in s t rumen t s . . . not in the plant design " and the other"errore and incendis tenoies" (p.56)

! As a result of the Terrey Pines Report NRC s'< )uld have insi=ted on a complete l

review of design and construction of 111 systems and somponents related to l t'as plant safe shutdown capability before approving overs ting t'ae reacter. This it mast now require, and the license must be suspended during this process.

l We believe that we have presented conclusive proof t'ast PECo 's present opera-tien of the Limerisk reactor is a threat to the safety and 'nesit's of the publie, PECo employees and t'ne NRC Staff,and is not in compliance with the requirements of license NPF 27 We urgently repeat our petition to NRC to immediately institute proceedings for the issuanea of a show eause order why t'ae NRC lisense issued to PECo to op-Grate t'ae No 1 reester at limerisk should not now be revoked, cc: NRC LB,AB, Staff Counsel, Docketing Serv. Respectfully yours, PECo, LEA, F. Romano ,0t'mers on S,ery. List Senator Arlen Specter,Sen. John Heinz Congressmen Robert Edgar, Peter Kostmayer,

[M' ox 186 Moylan,Pa. 19065 William Grey, Lawrence Coughlin

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