ML20132D020

Responds to NRC Re Violations Noted in Insp Repts 50-352/85-16 & 50-353/85-04.Corrective Action:Procedure ST-5-048-800-1 Re Sodium Pentaborate Concentration Revised to Correct Error.Related Correspondence

ML20132D020
Person / Time
Site:	Limerick
Issue date:	07/15/1985
From:	Cooney M PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
CON-#385-892 OL, NUDOCS 8509300033
Download: ML20132D020 (4)

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PHILADELPHIA ELECTRIC COMP Nc0 E 2301 MARKET STREET P.O. BOX 8699 ..

22 A;; .27 PHILADELPHIA. PA.19101

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Docket Nos. 50-352 N 50-353 d' Inspection Report: 50-352/85-16 50-353/85-04 Mr. Samuel J. Collins, Chief Projects Branch 2, Division of Reactor Projects U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of-Prussia, PA 19406

Dear Mr. Collins:

Your letter dated June 17, 1985 forwarded Combined Inspection Report 50-352/85-16; 50-353/85-04 for Limerick Generating Station. Appendix A of your letter addresses one item which does not appear to be in full compliance with Nuclear Regulatory Commission requirements. This item is restated below followed by our response.

Violation Technical' Specification 6.8.1 requires that plant administrative procedures be maintained including those procedures governing the review of safety-related procedures by the Plant Oparations Review Committee (PCRC).

Administrative Procedure A-4 implements the licensee's program for the review of procedures by PORC. A-4 includes an option for the use of a PORC Subcommittee to conduct the review provided the PORC Subcommittee Chairman has determined that an adequate cross-discipline review capability for the specific procedure is present within the Subcommittee.

Contrary to the above, an adequate cross-discipline review capability did not exist in the PORC Subcommittee convenpd to review revision 2 to ST-5-048-800-1, "SBLC Sodium Penta?5 orate 8509300033 850715 PDR ADOCK 05000352 G PDR

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Mr. Samuel.J. Collina July 15, 1985 Page 2 l l Concentration Analysis," in that the Subcommittee was 4

comprised of chemistry department personnel without input

.from any other plant staff organization. Subsequently, the i procedure was determined to be. inadequate because it did not I consider the effect of the low tank water level pump trip

setpoint in determining the total available volume in the '

j standby liquid content tank.

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

Response

Admission or Denial of Alleged Violation We acknowledge the violation as stated above.

Reason for Violation The violation occurred because the requirements for cross-discipline review in sub-PORC's, as set forth in administrative procedure A-4, were not being followed.

Extent or Significance of Violation During the. period in question, the SBLC tank had frequently contained approximately 200 pounds less than the Technical Specification of 5500 pounds of sodium pentaborate. According to worst-case calculations performed by General Electric, assuming control rods all full out (AFO), SBLC shutdown was not precluded in this condition. Because the reactor was limited to less than 5 percent power during the period in question, this worst-case condition (rods AFO) was never approached.

The consequences of this violation were therefore minimal.

In response to the identification of this problem, the Assistant Station Superintendent requested that Electric Production Quality Assurance personnel perform a review to determine adequacy of cross-discipline review by sub-PORC's on 403 Chemistry, Health Physics, Fuel Handling, and Chemistry surveillance test procedures. Of these 403 procedures, 102 should have had a cross-discipline review. Seventy-one did not receive adequate cross-

Mr. Samuel J. Collins July 15, 1985 Page 3 discipline review, thus allowing a potential for technical errors.

J Corrective Actions Taken and Results Achieved A special review of these 71 procedures was conducted by Technical Engineering personnel. Other than the

, previously identified error in ST-5-048-800-1, no technical problems which would cause Technical Specification violations or operational problems were identified. This review was completed on May 22, 1985.

ST-5-048-800-1 was revised to correct the error identified by this violation on March 22, 1985. This item is closed according to your inspection report dated June 25, 1985, which forwarded combined reports 50-352/85-25 and 50-353/85-06.

Corrective Actions to be Taken to Avoid Future Non-Compliance ,

To clarify and emphasize the need for cross-discipline review in sub-PORC's and to reduce the probability of recurrence, a memo from the Assistant Station Superintendent was sent to all PORC-members re-emphasizing the need for cross-discipline reviews and redefining the requirements in administrative procedure A-4 on these reviews.

1 Date When Full Compliance Will Be Achieved i

All corrective actions for this violation have been l completed as stated in this response.

Ve tru y yours,  !

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cc: E. M. Kelly, Senior Resident Site Inspector See Attached Service List j w . . - _ _ . _ _ - . . - . . ,._____.___,_.__ _.-_ ._. _ _ _ _ ___ _ _______.,_.___

cca 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 Zitzer Charles W. Elliott, Esq.

Zori G. Ferkin, Esq.

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

David Wersan, Esq.

Robert J. Sugarman, Esq.

Kathryn S. Lewis, Esq.

Spence W. Perry, Esq.

Jay M. Gutierrez, Esq.

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

E. M. Kelly Timothy R. S. Campbell July 3, 1985 4

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