ML20133H713

Notice of Violation from Insp on 961022-1216.Violation Noted:Licensee Provided Application to Nrc,Per 10CFR20.2002 for Approval of Proposed Procedures to Dispose of Slightly Contaminated Solids by Spreading Matl

ML20133H713
Person / Time
Site:	Limerick
Issue date:	01/09/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20133H694	List: ML20133H691 ML20133H713 ML20133H739
References
50-352-96-09, 50-352-96-9, 50-353-96-09, 50-353-96-9, NUDOCS 9701170268
Download: ML20133H713 (2)

Text

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I ENCLOSilRE 1 NOTICE OF VIOLATION E_ECO Enerav Docket Nos. 50-352:50-353 Limerick Generatina Station License Nos. NPF-39: NPF-85 Units 1 and 2 l I

During an NRC inspection conducted during the period October 22 - December 16,1996,a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," (60 FR 34381; June 30,1995), i the violation is listed below:

10 CFR 50.9 (a) requires thet information provided to the Commission by an applicant or a licensee shall be complete and accurate in all material respects.

10 CFR 20.2002 specifies methods for obtaining approval of proposed radioactive material disposal procedures and specifies that a licensee may apply to the NRC for )

approval of proposed procedures, not otherwise authorized in the regulations. 10 l CFR 20.2002 further specifies that the application shallinclude a description of the proposed manner and conditions of waste disposal, and an analysis and evaluation 1 of pertinent information on the nature of the environment.  !

Contrary to the above, when on April 6,1995, the licensee provided an application l to the NRC, pursuant to 10 CFR 20.2002, for approval of proposed procedures to dispose of slightly contaminated flowable solids by spreading the material at a l specific location on the owner-controlled property, the description of the proposed .

manner and conditions of waste disposal was not complete or accurate. l Specifically, the PECO Energy proposal failed to describe that the material would be deposited on an existing 40,000 square foot (4-foot thick) concrete storage pad. i Further, the information provided in the application, relative to onsite and offsite l dose analyses, did not consider the presence of the concrete slab and did not i demonstrate that the dose analysos provided in the application bounded those j doses potentially attributable to the presence of the slab. The licensee received j NRC approval for the proposed procedure, based on the incomp'ete information, on l July 10,1996, and as of October 29,1996, had disposed of :. bout 8,000 cubic j feet of the material at the location. This inaccuracy was material, in that, the i presence of the concrete storage pad, when identified, required further technical review by the NRC staff to determine if any new consequence was introduced.  ;

l This is a Severity Level IV violation (Supplement Vll). )

i Pursuant to the provisions of 10 CFR 2.201, PECO Energy is hereby required to submit a l written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:  !

Document Control Desk, Washington, D.C. 20555 with a copy to the Regional  !

Administrator, Re.gion I, and a copy to the NRC Resident Inspector at the facility that is the ;

subject of this Notice, within 30 days of the date of the letter transmitting this Notice of I Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if 9701170268 970109 PDR ADOCK 05000352 G PDR 1

ft .

s Mr. D. M. Smith 2 in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its enclosure (s), and your response will be placed in the NRC Public Document Room (PDR).

Sincerely, ORIGINAL SIGNED BY:

Walter J. Pasciak, Chief Projects Branch 4 Division of Reactor Projects Docket Nos.: 50-352,50-353 License Nos: NPF-39, NPF-85

Enclosures:

1. Notice of Violation

2. Inspection Report 50-352/96-09, 50-353/96-09 l l

cc w/ encl:

G. A. Hunger, Jr., Chairman, Nuclear Review Board and Director - Licensing W. MacFarland, Vice President - Limerick Generating Station J. L. Kantner, Regulatory Engineer - Limerick Generating Station  !

Secretary, Nuclear Committee of the Board l Nuclear Safety information Center (NSIC)

Commonwealth of Pennsylvania l

1 l

l

('

s Mr. D. M. Smith 3 Distribution w/ encl:

Region I Docket Room (with concurrences)

K. Gallagher, DRP D. Screnci, PAO (1)

NRC Resident inspector PUBLIC Distribution w/ encl: (Via E-Mail)

W. Dean, OEDO F. Rinaldi, NRR J. Stolz, PDI-2, NRR Inspection Program Branch, NRR (IPAS) l l

DOCUMENT NAME: g:\ branch 4\9609. lim To receive e copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure "N" = No copy p p OFFICE Rl/DRP l Rl/Dqh l l6 l l

NAME PERRY PASC,16K(

DATE 01/ /97 01/ /97 \ !

OFFICIAL RECORD COPY l

); b

b Enclosure 1 2 contested, the basis for disputing the violation; (2) the corrective steps that have been taken and the results achieved; (3) the corrective steps that will be taken to avoid further

! violations; and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for information may be issued as to why the .

! license should not be modified, suspended, or revoked, or why such other action as may l be proper should not be taken. Where good cause is shown, consideration will be given to '

extending the response time.

Because your response will be placed in the NRC Public Document Room (PDR), to the j extent possible, it should not include any personal privacy, proprietary, or safeguards l information so that it can be placed in the PDR without redaction. However, if you find it l necessary to include such information, you should clearly indicate the specific information that you desire not to be placed in the PDR, and provide the legal basis to support your request for withholding the information from the public.

I Dated at King of Prussia, PA this 9thday of January 1997 i

i

e e The maintenance staff performed the 18 month inspection and maintenance of the D24 emergency diesel generator (EDG) well. Improved housekeeping practices ,

during the outage were observed, but foreign material exclusion controls, although l adequate, need to be improved. The persistent effort of plant personnel to identify j the cause and correct an oscillation problem associated with the EDG governor was l

notable. The operations and technical staffs' performance of the loss of offsite '

power / loss of coolant accident surveillance test was very good (Section M1.4).

o Observed surveillance tests were conducted well using approved procedures, and were completed with satisfactory results. Communications between the various work and support groups were good, and supervisor oversight was good (Section

)

M1.5). '

e Several concerns raised to plant management by the inspectors necessitated corrective action to improve the material condition of the EDGs. Governor and generator oil levels were found low, and numerous materials were found astray on  ;

the engines. After corrective actions were taken, the inspectors concluded that the '

material condition of the EDGs had improved, that management expectations for maintaining the current condition of the EDGs is clear, and that the plans for maintaining the condition of the EDGs are being properly implemented (Section M 2.1 ).

Enaineerina

• Engineering personnel should have been more proactive in monitoring the condition of a cell, with low specific gravity, in the Unit 2 Division 4 safeguards battery, after it was identified as being weaker than the rest. Although the battery would have-adequately performed under design conditions with the low cell, the cell condition was not tracked and trended for a one month period, resulting in the entry into an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> technical specification action statement. The weak cell was replaced expeditiously, and the battery was returned to a fully operable status (Section E1.1).

e The engineering staff performed a high quality review and assessment into the failure of the electro-hydraulic control components that caused the Unit 2 scram.

The continued effort to assess the main steam vibration problem is a positive initiative to correct the problem in the future (Section E1.2).

e Plant personnel notified the NRC on December 6, of a condition where provisions of the Fire Protection Program were not properly maintained. The NRC concluded that the compensatory actions taken were adequate, and the corrective actions completed were appropriate and properly completed. The issue of the apparent non-compliance with a license condition will remain unresolved pending NRC review of the root cause and final corrective actions (Section E1.3).

e The inspectors were concerned that inadequate maintenance may have caused the high pressure coolant injection turbine speed sensor connector to become degraded due to overtightening. This issue will remain unresolved pending NRC review of any iii

l 6

EXECUTIVE

SUMMARY

Limerick Generating Station, Units 1 & 2 NRC Inspection Report 50-352/96-09, 50-353/96-09 This integrated inspection included aspects of PECO Energy operations, engineering, maintenance, and plant support. The report covers an 8-week period of resident inspection; in addition, it includes the results of announced inspections by a regional radiation specialist, and three emergency preparedness specialists.

Operations

• In general, the operators conducted normal plant activities well. The control room staff demonstrated good comrnunication skills and control during several plant evolutions, including the Unit 1 on-line hydraulic control unit (HCU) maintenance and removal of the fifth stage feedwater heaters at Unit 2. Operators also responded well to stabilize plant conditions following the Unit 1 power decrease on October 22 (Section 01.1).

i I

• Unit 2 operators responded well by manually scramming the unit on December 6.

Good operator awareness to changing plant conditions contributed to the decision  !

to scram the reactor after a turbine control valve fast closure half scram had I alarmed (Section 01.2).

• Operators conduct of the Unit 2 reactor start-up was very good (Section 01.2).

• The Nuclear Review Board and Plant Operations Review Committee (PORC) self-assessment activities were effective. PORC scheduled several special meetings to discuss root causes and corrective actions for the Unit 2 scram and corrective actions necessary to achieve compliance with the facility operating license regarding a safe shutdown fire (Section 07.1).

Maintenance

• The Fix-It-Now team performed the troubleshooting and replacement activities of a core spray trip unit safely. A good questioning attitude was demonstrated by technicians when questionable loose electrical grounds were identified (Section M 1.1 ).

• The maintenance outage at Unit 2, following a scram, was conducted very well.

Many work activities were safety and successfully completed without incident (Section M1.2).

• Nuclear Maintenance Division personnel established good control and oversight of HCU work activities. Technicians and operators completed the activity without error or challenge to safe plant operations (Section M1.3).

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