ML20127E765

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Responds to NRC Re Violations Noted in Insp Rept 50-352/85-03.Corrective Actions:Procedures Revised to Specify Placement of Breakers in Closed Position Upon Completion of Surveillance Test ST-6-040-320-1
ML20127E765
Person / Time
Site: Limerick 
Issue date: 05/02/1985
From: Cooney M
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To: Starostecki R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
CON-#285-917 NUDOCS 8505200196
Download: ML20127E765 (4)


Text

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b PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA.' PA.19101 (215) 841 5020 asacta c emoove e nos antusar May 2, 1985 Docket No. 50-352 Inspection Report No. 50-352/85-03 Mr. Richard W. Starostecki Division of Project & Resident Programs U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 Dear Mr. Starostecki Your letter dated April 2, 1985 forwarded Inspection Report 50-352/85-03.

Appendix A of your letter addresses one item which does not appear to be in full compliance with Nuclear Regulatory Commission requirements.

This ites is restated below along with our respnse.

Appendix C of your letter addresses several items which are characterised as weaknesses related to the effectiveness of the licensee's programs, activities, or organisations.

A response will be provided for the Appendix C items by May 8, 1985, in accordance with your letter.

Violation Technical specification Limiting condition for operation 3.6.1.4 requires two independent MetV leakage control subsystems to be operable in Operational Condition 2.

Contrary to the above, during the period between December 29, 1984 and January 30, 1985, while in operational Condition 2, the two independent M51V leakage control subsystems (Inboard and outboard) were inoperable, in that the circuit breakers for the associated blowers and heaters were misaligned (opened) due to an incorrect surveillance test procedure.

This is a severity Level IV violation (Supplement 1).

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Mr. Richard W. Starostecki

'May 2, 1985 L'

Page 2 i

Responses

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.This event was the result of a procedural error in Surveillance Test ST-6-040-320-1 which was inconsistent with the system operating procedures.. The circuit breakers.for the W IV Leakage Control System blowers and heaters had been closed on December 20, 1984 as a result of performing the check Off Lists.(COL) for system operating procedures 840.3.A and 840.3.B.

Subsequent to performing the COLs, the monthly system operability test, sT-6-040-320-1, was performed on December 27, 1984 and on January 27, 1985. 'This surveillance test specified that the circuit breakers for the blowers and heaters be left in the open position.

Additionally, the operations personnel failed to recognise from the' condition of'the status indication lights on the M81V-LC8 panel that the breakers for the blowers and heaters were not in the proper position.-

Upon identification of the discrepant condition,'the circuit breakers were closed.

Special Event procedure SE-10 "LOCA" l

has been revised to specifically reference system procedures v

340.1.A and 840.1.5 which direct the operator to close all i

circuit breakers associated with the MSIV Leakage Control system.

ST-6-040-320-1 has been revised to specify that the breakers be placed in the closed position upon completion of the surveillance test.

Tags will be placed on the MSIV-LCS panel'to assint operations personnel by indicating the proper condition of the status indication lights during normal plant operation.

Additionally, a plant procedure has been implemented to assist control room personnel in verifying 1

that plant system status and parameters indicated in the control room are in conformance with Technical Specification requirements.

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Additional corrective action has been taken as described in I

l our response to Combined Inspection 50-352/85-02 and 50-.

353/85-01 which was conducted at approximately the same time as the Operational Assessment Team inspection.

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Full compliance was achieved on January 30, 1985 when the circuit breakers were closed.

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Mr. Richard U. Star:Stccki May 2, 1985 Page 3 Should you have any questions or require further information, please do not hesitate to contact us.

Ver truly yours,

/

/hh[M cca Dr. T. E. Murley, Administrator, Region I Mr. J. T. Wiggins, Resident Site Inspector See Attached Service List L

e cc:

Judge Helen F. Hoyt Judge Jerry Harbour Judge Richard F. Cole Troy B. Conner, Jr., Esq.

Ann P. Hodgdon, Esq.

Mr. Frank R.

Romano Mr. Robert L. Anthony Ms. Phyllis Zitner Charles W. Elliott, Esq.

Zori G. Ferkin, Esq.

Mr. Thomas Gerusky Director, Penna. Emergency Management Agency Angus Love, Esq.

David Warsan, Esq.

Robert J. Sugarman, Esq.

Martha W. Bush, Esq.

Spence W. Perry, Esq.

Jay M. Gutierrez, Esq.

Atomic Safety & Licensing Appeal Board Atomic Safety & Licensing Board Panel Docket & Service Section (3 Copies)

James Higgins Timothy R. S. Campbell January 16, 1985

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