ML20125C162
| ML20125C162 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 12/04/1992 |
| From: | Hodges M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Danni Smith PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| Shared Package | |
| ML20125C165 | List: |
| References | |
| NUDOCS 9212110077 | |
| Download: ML20125C162 (4) | |
See also: IR 05000352/1992081
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DEC 0 41932
Docket Nos. 50-352
50-353
Mr. D. M. Smith
Senior Vice President - Nuclear
Philadelphia Electric Company
Nuclear Group Headquarters
Correspondence Co' trol Desk
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Post Office Box 195
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Wayne, Pennsylvania 19087-0195
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Dear Mr. Smith:
SUBJECT:
ELECTRICAL DISTRIBUTION SYSTEM FUNCTIONAL INSPECTION OF
L.lMERICK GENERATING STATION, UNITS 1 AND 2 COMBINED
REPORTS NO. 50-352/92-81 AND 50-353/92-81
This letter transmits the report of the team inspection conducted by Mr. A. L. Della Greca
and other NRC and contractor personnel, from August 31 to October 2,1992, at the
Corporate Offices and at the Limerick site. Mr. Della Gaa discussed the findings of the
inspection with G. V. Cranston and J. Doering of your staff, on October 2e 1992. Several
findings were further discussed with W. J. Boyer and other members of your staff on
October 6 and 8,1992. In addition, clarifications regarding violations were provided on
October 9,1992.
The primary objective of the inspection was to determine whether the Limerick electrical
distribution system, as designed, installed and configured, was capable of performing its
intended safety functions. In addition, an assessment of engineering and technical support
relative to the electrical distribution system was performed.
The inspection was directed toward areas important to public health and safety. Areas
examined during this inspection are discussed in the enclosed inspection report. Within these
areas, the inspection consisted of selective examinations of design calculations, relevant
procedures and representative records, installed equipment, interviews with personnel, and
observations by the inspectors. The inspection concluded that,-for the areas reviewed and
taking'into consideration the compensatory actions regarding bus transfers, the design
implementation of the electrical distribution system at Limerick is acceptable and that the
engineering organizations provide adequate technical support for the safe operation of the
plant. A number of strengths, observations and unresolved items, as detailed in the enclosed
report, were also identified.
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Mr. D. M. Smith
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Based upon the results of this inspection, four of your activities appeared to be in violation of
NRC requirements. Three of these activities, pertaining to the de loading calculations and to
the surveillance testing of de batteries, and degraded voltage relays are as set forth in the
Notice of Violation, enclosed herewith as Appendix A. The violations have been categorized
by severity level in accordance with the General Statement of Policy and Procedure for NRC
Enforcement Actions,10 CFR Part 2, Appendix C. You are required to respond to the
Notice of Violation and, in preparing your response, you should follow the instruction in
Appendix A.
The fourth activity involved your potential noncompliance with the requirements of general
design criterion (GDC) 17 and possibly GDC 35. The issue was the result of the control
logic used to automatically transfer the accident loads to the alternate and standby power
sources in the event of a loss of the preferred source. The NRC is concerned that the safety
and regulatory significance of this issue was not recognized by your safety review committees
when it was initially identified and no appropriate corrective actions were taken until this
issue was identified by the NRC EDSFI team. The NRC is considering this apparent
violation for escalatcd enforcement action in accordance with the " General Statement of
Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy),10 CFR Part 2,
Appendix C (1992). Accordingly, no Notice of Violation is presently being issued for this
inspection finding.
An enforcement conference to discuss this apparent violation has been tentatively scheduled
for January 6,1993, in the NRC Region I office. The purposes of this conference are to
discuss the apparent violation, its causes and safety significance; to provide you the
opportunity to point out any errors in our inspection report; to provide an opportunity for you
to present your proposed corrective actions and actions taken; and to discuss any other
information that will help us to determine whether enforcement action in accordance with the
Enforcement Policy is appropriate.
Pertaining to this apparent violation, at the enforcement conference, you should be prepared
to discuss (1) your compliance with the independence requirement of GDC 17 and the single
failure requirement of GDC 35; (2) the causes which led to the design deficiencies; (3)
whether the emergency buses and, hence, the safeguards components were inoperable during
any period of time prior to the corrective actions of October 5,1992; (4) adequacy of your
safety review committecs' evaluation as it pertains to the electrical bus transfer scheme
problem, following its identification in 1989 during your Independent Design and
Construction Assessment; and (5) adequacy of the corrective actions thereof.
You will be notified by separate correspondence of the results of our deliberations on this
matter. Please be advised that the characterization of the apparent violation described in the
enclosed report may change as a result of further NRC review. No response regarding this
apparent violation is required at this time.
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DEC 0 4 i%l
Mr. D. M. Smith
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In addition to the above deficiencies, the team identified six issues which require further
evaluation by you. We request that you provide us, in writing, within 60 days from the date
of receipt of this letter, with a schedule for the resolution of thc other unresolved issues
identified to you at the exit meeting and in this report. The sections of the report which
address the specific findings are identified in the table titled " Summary of Inspection
Findings."
Your cooperation with us in this matter is appreciated.
Sincerely,
r,.un : 3 r- c ry
.. ivm 'il. 'sa
Marvin W. Hodges, Director
Division of Reactor Safety
Enclosures:
1. NRC Notice of Violation, Appendix A
2. NRC Combined Inspection Report No. 50-352/92-81 and 50-353/92-81
cc w/ encl:
R. Charles, Chairman, Nuclear Review Board
D. R. Helwig, Vice President - Limerick Generating Station
G. J. Beck, Manager - Licensing Section
G. Madsen, Regulatory Engineer - Limerick Generating Station
Secretary, Nuclear Committee of the Board
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
K. Abraham, PAO (2)
NRC Resident Inspector
Commonwealth of Pennsylvania
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DEC 011932
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Mr. D. M. Smith
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bec w/ encl:
Region I Docket Room (with concurrences)
E. Wenzinger, DRP
C. Anderson, DRP
DRS/EB SALP Coordinator
V. McCree, OEDO
R. Clark, NRR
W. Lanning, DRS
R. McBrearty, DRS
bec w/ Executive Summary Only:
C. Hehl, DRP
B. Norris, DRP
C. Miller, PDI-2, NRR
D. Ilokxfy, EO
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