ML20133H968
| ML20133H968 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/01/1985 |
| From: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Thompson H Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20132C669 | List: |
| References | |
| NUDOCS 8508090590 | |
| Download: ML20133H968 (17) | |
Text
5052 e
So4sa ENCLOSURE 1 gg MEMORANDUM FOR:
Hugh L. Thompson Jr., Director, Division of Licensing, NRR FROM:
Richard W.
Starostecki, Director, Division of Reactor Projects
SUBJECT:
LIMERICK OPERATING EXPERIENCE This letter is to provide an update of Region I efforts on the issue of apparent personnel errors at Limerick. The issue of personnel errors was discussed with Commissioner Zech by the Limerick Senior Resident Inspector during the Commis-sioner's site visit on December 12, 1984. The apparent trend in operator and technician errors was formally transmitted to the licensee as a regional concern in a January 11, 1985 letter which forwarded an inspection report containing findings involving personnel errors and requested a response to this concern.
Prior to receipt of the licensee's response, the Limerick SALP report for the period between December 1, 1983 and November 30, 1984 also noted the trend in personnel errcrs, and this report was sent to the licensee on February 7, 1985 with the SALP management meeting scheduled for March 12, 1985.
The licensee's initial response to the regional concern was provided by letter dated February 11, 1985 and a followup meeting was held with licensee manage-ment regarding proposed corrective actions
- on February 22.
Licensee corrective actions being taken include independent investigations and analyses of each reportable event to deterrine root cause, a plant wide operational excellence prograr offering a reward to groups with fewest personnel related incidents, and the pursuit of hardware modifications to correct conditions which provide easy opportunities for personnel error. The licensee comeitted to submit a report in late March which will discuss in detail the implementation and results of their corrective actions.
In addition tc the above, Region I has conducted an independent review of reportable events at Limerick from the date of their license, October 26, 1984 through the enc of 1984. The study included telephone reports made under 10 CFR 50.72, and Licensee Event Reports (LERs) made under 10 CFR 50.73. Since 10 CFR 50.72 reports are based on preliminary information with the root cause not clear, study prima-ily used the written LERs and where additional details were our needed, the regional inspection reports concerning the events were reviewed.
The results of the Region I study are provided as Enclosure 1 to this letter.
In sumtary, our review concludes that: 1) of 43 LERs sube.itted or events in 1984, 14 were caused by direct personnel error with another 5 caused by operators not fully understanding the requirements of the plant Technical Specifications, for a total of 19 personnel related errors. Licensee initiatives in this area include plant modifications which are in progress to prevent grounds and shorts during surveillance testing of various electronic instruments in restricted spaces, and to einimize reactor trips experienced during venting and filling differential pressure instruments.
Together these hardware problems contribut OFFICIAL RECORD COPY BEALL2/26/85 - 0001.0.0 02/26/85 8508090590 850729 PDR ADOCK 05000352 P
Memo to H.L. Thompson 2
to 4 of the direct personnel error events. 2) Equipment failures caused 15 of the 43 total events; 10 of these events were due to two separate repetitive problems for which plant modifications are being pursued. One of the problems involved 5 control room ventilation isolations caused by the breaking of the sample tape for' the control room chlorine analyzer. The second problem involved 5 Reactor Water Cleanup (RWCU) System isolations caused by a spurious high temperature signal generated while reading RWCU system temperatures.
In considering whether a personnel error trend exists, the volume of Limerick LERs was reviewed along with the reporting requirements recently emplaced by the 1984 revision to 10 CFR 50.73. Susquehanna 1, which was licensed to load fuel on July 17, 1982, was the most recent lead unit BWR to startup in Region
- 1. During the comparable time period, the first 2 months and 5 days after receipt of an operating license, Susquehanna reported 10 LERs which resulted from personnel error. Of Limerick's 19_ LERs caused by personnel error only 8 would have been reportable prior to January 1,1984. As an example, the actuation of an Emergency Safety Feature (ESF) such as an inadvertent system isolation is now reportable, whereas prior to January 1, 1984, it was not.
Of the 43 LERs Limerick submitted in 1984, approximately 25 were ESF actuations.
In total, these facts suggest that Limerick's reportable personnel errors might not vary significantly from industry experience.
Further, Region I has considered the safety significance of the reported events and has determined that none of the events resulted in a serious degradation of safety barriers. In addition, we believe that the licensee has been conservative in reporting events and that no reportable events have occurred which were not reported.
We will continue to monitor the corrective actions taken by the licensee with special emphasis on the identification of root cause, review by management, and effectiveness of actions taken.
Ori5 ng.15:53K D 8 i
Richard W. Starostecki, Director Division of Rea: tor Projects
Enclosure:
As Stated CC:
A. Schwencer, NRR J. Sniezek, EDO R. Martin, NRR J. Partlow, IE G. Holahan, NRR J. Heltemes, AE0D E. Jordan, IE
O e
ENCLOSURE 1 REGIDN ] REVIEW OF LIMERICK 1984 LERs 14 Personnel Error (Direct) 9 - 16 2 - Poor /No communication w/ operators 2, 31 2 - Ground /short during ST 11, 30 2 - Venting Instrument Lines 7, 19 3 - Mental Mistakes 17, 24, 32 (Left wrong setpoint, did not reset earlier isolation, thought circuit was for a different valve logic)
~
2 - Cy: ling Feeder Switch OC, 14 1 - E: oe: Reisy 20 1 - Miss erstoo: CR Label 15 1 - Did r:t Watch Rx Press 23 E. '*; >>C-S 75-Relate: E-rcrs 5 - Me su.derstood 15/LCO 01, 09, 16, 27, 44 L - Fre:e:.re did adequate 03, 04, 15, 43 IE E:.io e-; Fa'ic es LER #
5 - A.alyze-Tape Erean
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Re a: 5*':c r.
- 2, 26, 34, 31, SE
- - Meta' St ap CE 1 - C-ir:
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Re;.~at:- Faiicre 35 1 - V:': 05:i4: 0-Due 1:
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u E Othe-Ca.ses 1 - M'sse Fire Seals 22 (Co.structior) 2 - Figh Wircs (Desigr) 41, 45 1 - Et:<o; rap *> ~ Isciat'c.
25
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- an s ca t s on n sa w imC wiluntrue leuum 44-02 Scree s aysia s; sec d sdss' t check wa tti stis t's m pe rv s m e s se p s siis to s esi.ueinu. i e s.9 it<M.: s.s. s ein s....e s.rusi asyp smud use preveuum two days tu prevent trip durleig supasr us~ Llew usinectue.
Cu s e en.t i ves ac t suoi e.uinn.e e techselc i an.
84-3e eseactor weter cleanup (sewcut itoa tson, s ai: daon't swe e4. ti.m i a 43 mu...ind slest won l ei o s e u. e nu t =ue...
act ausen.
ine mucteun eine reow trasemma ttar wa s we s wed out but Efee inntsument ugua l leur va lve wem seut up.neud s ee s. a me.
GotroC&:we aC& aun== Cous beI teClost e C 14 es.
2-G r o-n / ho r t durenu Su rver e : s ances Tunt 1SIi te v s ats.
44=#4 3 s&osatson valves auto Clumed; 1&C cdumud a abort e: e s ces s t wai s 1.s t s y e sies s es app s y.gesmpu rm dus a n.: 51 eue e r..
eentterm. Curs uctive act son -- mudt modo un red musiltosh addeu9 tomt,lecha and sw i tcfie m tu pe..vuut s ue u e s unt.u.
84-30 8:555 Imolation; leC grousided a lued dias city bl.
Curs uc t i ves me:s eues -- a mud a m bes s eig purmuesd i n sie6s. e s tunt mw e tt:sias m on the four Idesatical Instruments to avoid l i f't l eeg leadh du r i s.9 tfie bl.
2-Ventina/Fittina instrument Lines by imC 34-07 esv. Is smolation, CCCS and desmes mutas i.ta r t ; e sLC is.ps4spe rl y vueste:I i sis t s umusst I s siu m use this s.:ai: L u s envol instrument rack. Currec t e ve ac t e usi -- i.uunnes s techsisclasst asul pursues head 4.leambo s mud tu amme t wun t s e.9 4ss-s9 steest Shutdown coulisiv s motet tun; sac imps opursy b.chs i s sud a n n i... mon t i.96 t spussuum moon s.um.. ii. s e n s ueet si en another pubstble caumesl. Currect i ve me.t sun -- estabi l mli cle ma, usi pe upus' muthualm of backfillen9
.e s ed va l v s sig instruments into and out of 6ervice.
1-ge snta l 141 s t a kas s hv ImC S4-87 wresig motpoint f or vont I mu le t lose; suwsuw ur 140 bl 6huvud L t... e thu n.u s pu s ses hud huusi me s lied
":..s t a m e.si. t u s y" s i ti uugs coun:.u s techs ic a nas.
e t was El sghtly outmade the acceptable band. Curs esctive act eun
- e panssas sesp coumed 44s-2ss Group B smolatson: Inc did nut rumut 4 :.n s.s t e un pa rt e s t trip r...e umslaus meup see si nu nuett russ asosation. Procedures des r e c e ssic a s :. s.untrsbutuJ s ee teint cau.arang us um a e sur t e lpm we m a:u e s.:d sue 1.u t is wo men' t wem a 6 9nuss bsuch included.e..e.:sua s ews teus pa rtie s specerscelly stated that a partaal trop wouad be 9enura'tud seus trap. Correctsve action -- counses taihuscian, revi ne procedus u and lu.ed o sammen use the propus seu s I n o m.incu or si's.
54-32 ftwCu etoiatlon; two leC group 6 wuea woaheog aedupunduntay usu: 9e uup w :. duany b e use : he uni h.....a r.uc e e un v a vu wath the faulation Dypassed, asid tree mucosed us uup was touublue.huute.9 m mw s s..h p s i.ta l um.
thu mucun.: 9 e n..p i:s s unuuum e y beIloved the swatch invoived this outho s as va ive mu t at ause aou. m e s.
s;.umens ties enbua:d weivu u mesi.L dur a seg this a r troublomnouting. Corrective act son -- e.uunnes s secused us uup us tes.hsisc eassa.
2-Os o ra tor Cvel inu f und hel tch 84-06 Contsul leous vent I mula t a ani; a m s.. r t us te nusseenhuus assu e psubium wets. shu.ssywuse pusqu my:.i..
. shu..pu s.s o u s..yclud a switch which reeds a d rywes t i pusuu two.
ihe swate.h essu s ue..s :. " A" s.s.annu s e. lit us s nu analytue.. u d thu sumi. os puwee caused the amosation to occur. Currectavu ei.tsusi -- s.uuseme l 9.usstus nd a.s.essy the usuctes. e piene u e.ud.
pe ub s um w e s s. s hu sometus uns: s....u u p s.u. i s.u enq 44-s es stenctor Enclosure vent l au l a t iuse; e m p.s s t os troubsumhouting a system, the operator cycled a hwatete whee.h tuuds ru.actue uncau:.use plant 8.ua t s si9 e nn t s umuns.e s s un.
Bhu :.w s ta.h assu feeds a suector eenceusure ventsentaun panus and thu tumm os power conmud thu i nu s e t s usi to ui.e.u s.
t..nenctivo ac t iusi
-- counmes sech thirt.
o L tMtit a Ch 11 ag*1 { AuStIJ uYEtWLJLP. ufsaLL.l.01131 s.gu /
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1 ads-20 Control Otoom Vesit i sola t s use; meantenanou purmonnus were wurhes.9 use a taum e...te s a.n l asuus m o up m es.1 s...mpu.e sulay nasusLud on ties Cub sCa l door.
The ru t ay t r a ppasil e mul a t iseg t isu bea m d ead ties Iomm of powe r tu tise "D" s.le s ses s eau esed lytur Ceuted the s6eletten to occur. Correc t s wa act euss -- Couestol wurker.
Oman ra tar M a susade rh tuod L alass i 1
I San-S S Iwo endespesideset sampleng/ussalybus not dossu pr eur tu re t ass be ;
4...es t e u l is..um w e a s e "4 s qu ail itedwa r.s u Is l :.e.l..e s qu. Ill-lo flow" was encorroCLly enterpreted ab mossaturisig e ilw.mt. l i seu asuw s tl.u s ti. as 6.mple Ilow, s h.o s..lw
- . i u uses esst radiatsost mon s te r wa s out of serv sce dies to en usses.t s wa ted mampse pump, t.uressotswa acteun -- s esv s hed.euseustica tur w e ndow ased d s 6Cha rge pe rmi t procedure tu require Clinching Of temple r e t. k.
I Omaan ra tor Didan' t hase t ren Mr P rea k hu res 1
44s-2 3 Scree on high reactus prussus es; opera tser d ailse' t seut s ce t ene t s i. tier ges ummiss u we m s eic s em 6 s sig ilu s e u.
Boy.s o u.
Atasm SetpOlnt Wa6 highGr tlse:I bC rash be tpO lent IsuCeuhe the bCree Va lvt. loud Deuss luwused, lau L Lleu aldte u.e t. senvus 08 estyud f rom the O ri g i na l GpeClfsCatsOn. Co rrue:t s wes act ioss -= lowered as l e s's hu tpu s se t t u teo l ow bu ra m.n e.1 foug s se s aav t r y s sig SSLpeint indeX IOr accuracy and completusicht.
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WL H I L F.LLllS CAUhtO UY Luyl rMt sg(J All_ejggL I.usu as S - Cn t u r a na Ana l vlas r I vues B ret a k 44-04 Contro s Room vesit isoletsun; in all o t' t s.u uvents treu mampeu t.e pu usue.u sees us eu us Lieu sous g as - l O Chlerene ana ly2 art caus essy a fuit scalu s ued s teg. Ileu fe s gle cla mu s'wuss va l uu emumed t sou seu s men t vue.e y :. s e.
44-#8 to smulatu a sed an emergune.y framis asr my:.tum tu autu m t se s t. e.ees s ee. t i vu me:s s eus -- e.u vu s e s meuh,....
a.u s e..e ga-33 conb e des ed we tle one, res tucat suss us sempsu pueso m tu s essue.e v lie s.e t s ous, s...mse s u tud use usuembe r 4.
1 enes. lien s
Des *s e lett three avessts touts place artur tile susucatioss ol' Lines mesplu pumpm.
s "aaL AD" Pea l t n ual Lau r l ous heuna1 S
54-12 iswCU 16ulation; in all of tsembe uvusat h L lau "lumpe s e tsaru De t'f ue rest s e l l a essa.sen e t tee s
- w s ts.it" w.s i, ps.a.eut s ee 64-26 trees "M[ AD" po6 8 t ion gestera t e seg a bpursuub begnal Cos's'ou t ive es.t a use a mud i n bu s sag pus huuss tee e lev "ftt A48" 44-34 circuet which will prevent Llee be trapm.
e4-3$
$ - O t he r f au l -~1 failureE 44s-0$
Screa signel; tine metal breid secuseng. In-nu liound s eiduc to r s u e l tai a s s uw e se9 et au.ast ou.e e.e s..n s e u s besits. blie rt circuited it, ased couted ses.e s t o t rasemi sse, llem u tleu s-n.ues s ce. lia :
.e vs. l e esgo misytess> ses.seus s le.e se s
the overvul tage protect euse mu t pu s se t c as.mssig a teep a nd en lumn ses' puwur to t enu 4s Ph seed a e,c o mm.
...su.e s, a se s s us. t i ve actson -- adjust alternate tource voltagu, replace desmayed compunuesta, a sed s esapac t all u tine r
- e. s m o s e r duv s cos t'o r 6 e a s ie r p ret t ee6 44s-1 3 MHM 16 elation failure; e c rimping s t rap sea uws.setud a (;uss t ec t t s um s. lu e s sey. lausassy
- .1 teses InlH s e n.: woussel sust ibolate free Efee remutes thutdowse pastel. Currective actiuss -- el emesis te l eitu s l e s ssee.e ased t.uanp l e. a u ull u tlau r til 's to verify all ether Cesatects.
44-21 ktdCU isolation; durlsig $f a tubt cable pesag bleus'ted blow esig a tumu supply ssag puwes to l ho le t s ues l ug s e.
susays.
CerrtCLive SCLiO4 ** replace fute estd supulr plug.
sde-39 Scram signal; voltage fluctuet tun 6 rrum L eic 6ta t es s uvo s te r f uud t e..I lu nr!,caumud ovesvultegn s e es w e s te SA HPb t rippe.J8 e t pa rt of an bl. Co r rec t ive ac t s uu== ruplace voltage regulatus buesd on Ib Hrh s t a t e s. suvussos.
84s-40 NPS supply breakers tripped usi usades vol t.evu dur s siv s' esc e s s pump stesL. s.us s uc t e ve actlues -- p s u. e.au s es a lassegu to place APS on DC source when startisig sucerc pump mind inve6L ega tes muit to creassgo the AC scusa.u.
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e, LIMERICA LERs OCTOBER 26, 1984 through MAY 7, 1985 11/84*
12/84 1/85 2/85 3/85 4/85 5/85**
TOTAL EVENTS FOR MostTH 22 21 22 5
13 8
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ffM%NNFL EHRORS - TOTAL 19 JZ Q
}
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g sac technician 5
4 7
0 2
1 2
. Ope ra to r 4
0 1
0 0
0 0
Other 1
0 4
0 3
2 0
TECH SPEC RELATED - TOTAL 6
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h Q
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Q Procedure Error 3
1 3
0 2
0 0
Misunderstood TS/LCO 3
2 1
0 0
0 0
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ro RWCU isolation
" Read' O
5 1
1 0
0 0
Switch Spurious Signal Control Room vent Isolation 2
3 0
0 3
1 1
- Chlorine Analyzer Tape Break Other 3
2 3
3 1
2 0
Mf SCELLAN[O!!S 1
4 2
1 2
2 0
(e.g.. Reactor Sullding Isolation Oue to High Winds)
Notes:
- 3 LERs with event dates during October 26 - 31, 1984 a re included' in November data
- Through May 7, 1985 l
t 51 LERs in 1985 22 Personnel Errors LER Nos.
I 12 - I&C
- Poor Communication w/ operators 03, 14, 51
- Ground /short/open during ST 10, 11, 16, 20, 49
- Valving Error 18, 37, 40, 47 1 - Operator 21 9 - Other
- Aux - Poor Commincation 06
- Engineer - Short during troubleshooting 12
- Valve Error 39
- Tagout Inadequate 17, 46
- Firewatch Patrol 33, 43
- Unknown - Reversed Leads 19
- Wired Open Damper 32 6 TS-Related Erros 5 - Inadequate Procedure 02, 15, 22, 34, 38 1 - Misunderstood TS/LC0 13 16 Equipment Failures 5 - Analyzer tape Break 29, 30, 31, 42, 50 2
" Read" Switch 01, 27 9 - Other l
- Voltage Fluctuations 07, 24, 26
- Bad Electrical Connection 09, 41
)
- Unknown 25, 35
- Blown Fuse 48 1
7 Miscellaneous
- High Winds 05
- Loose Fan Fitting 23
- Fire Seals 28, 36
- Hand Held Radio Signal 44
- SPOS Not On Schedule 45 51 Total
4 I
1985 Limerick LERs 85-01 RWCU Isolation, Equipment, "REA0" Switch 85-02 RWCU Isolation, Procedure Error, did not adequately vent piping 85-03 RWCU Isolation, Personnel Error by I&C, poor communication with operator 85-04 HPCI Inop, Miscellaneous, S/D began until RCIC available 85-05 Rx Enclosure Vent Isolation, Miscellaneous, high winds 85-06 Defeated Both RWCU Suction Isolation valves, Personnel Error 85-07 RPS and NSSS Trips, Equipment, voltage fluctuations 85-08 RWCU and Vent Isolation, Equipment, blown fuse l
85-09 HPCI Steam Supp.ly Isolation, Equipment, bad connection l
85-10 RWCU Isolation, Personnel Error by I&C, open during ST 85-11 NSSS Trip, Personnel Error by I&C, short during ST 85-12 Rx Enclosure Vent Isolation, Personnel Error, short during trouble-shooting by engineer 85-13 Partial Loss of HPCI Isolation Ability, Misunderstood TS/LCO, transmitter not placed in trip when not available 85-14 SDV Channel Not Placed in Trip Condition, Personnel Error by I&C, failed to tell operator time limit had expired 85-15 Sprinklers Inop w/o Firewatches Set, Procedure Error, admin. proce-dure covered only safety-related systems 85-16 HPCI Isolation, Personnel Error by I&C, short during ST 85-17 Negative Pressure in Control Room, Personnel Error, inadequate tagout 85-18 Rx Enclosure Vent Isolation, Personnel Error by I&C, improper instru-ment valving during troubleshooting 85-19 Partial Loss of HPCI Isolation Ability, Personnel Error, reversed leads 85-20 Ex EnclosureVent Isolation, Personnel Error by I&C, lifted lead caused inadvertent isolation 85-21 Scram, Personnel Error by Operator, improper valving of instrument line 85-22 MSIV Leakage Control System Inop, Procedure Error, ST left breakers open 85-23 Rx Enciosure Vent Isolation, Miscellaneous, loose fan fitting 85-24 RPS and NSSS Trips, Equipment, voltage fluctuation 85-25 RWCU Isolation, Equi) ment, cause unknown 85-26 RPS and NSSS Trips, Equipment, voltage fluctuations 85-27 RWCU Isolation, Equis, ment, " READ" switch 85-28 Inadequate Fire Seals, Miscellaneous, design drawing deficiency 85-29 CR Vent Isolation, Equipment, chlorine analyzer tape break 85-30 CR Vent Isolation, Equipment, chlorine analyzer tape break 85-31 CR Vent Isolation, Equipment, chlorine analyzer tape break 85-32 Fire Damper Inop, Personnel Error, dinper found wired open 85-33 Inadequate Fire Watches, Personnel Errer, patrol interval greater than 60 minutes 85-34 Inadequate Sodium Pentaborate Volume, Procedure Error, ST included tank volume not available due to pump low level trip setpoint
a 2
85-35 RWCU Isolation, Equipment, cause unknown 85-36 Fire Barrier Inop, Miscellaneous, AT&T personnel inadvertently removed fire seals installing telephone cables l
85-37 ECCS initiation, Personnel Error by I&C, instrument line backfilling l
error 65-38 RHR Isolation, Procedure Error, didn't accomplish reset after ST 85-39 NSSS Trip, Personnel Error, engineer opened instrument line valve j
while " checking" it was closed 85-40 ECCS Initiation, Personnel Error by I&C, valving error during ST 85-41 Rx Enclosure Vent Isolation, Equipment, bad electrical connection 85-42 CR Vent Isolation, Equipment, chlorine analyzer tape break 85-43 Inadequate Fire Watch, Personnel Error, patrol interval greater than 60 minutes 85-44 CR Vent Isolation, Miscellaneous, hand-held radio transmitter generated stray signal ~
85-45 SPOS not Operable on Schedule, Miscellaneous 85-46 Scram, Personnel Error, inadequate tagout 85-47 Excess Flow Check Valves Inop, Personnel Error by I&C, instrument line valves left open after ST 85-48 NSSS Trips, Equipment, blown fuse 85-49 MSIV Trips, Personnel Error by I&C, short during ST 85-50 CR Vent Isolation, Equipment, chlorine analyzer tape break 85-51 RWCU Isolation, Personnel Error by I&C, poor communication with operator l
l 1
o LIMERICK LERs CAUSED BY DIRECT PERSONNEL ERROR 3-Poor Communications by IhC w/CR 85-03 RWCU isolation; due to misunderstanding between i&C and operator. the return line transmitter was valved in whole the auction transmitter was valved out causing s raise dif f^erential flow isolation signal. Co rrect i ve action -- inco rpo ra te instruction letters in training packages for ikC and opurators.
85-14 TS/LCO violation; ikC failed to tell operator that 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> limit had passed for unavailability of scram discharge volume float switch due to prolonged ST.
Corrective action -- written warning to technician, t ra in i ng i
conducted. additional steps being evaluated.
85-51 RWCU isolation; due to misunderstanding between ikC and operator, the inboard suction valve breaker was closed when ST inserted isolation signal. Corrective action -- counsel involved personnel.
5-Ground /Short/Onen durino ST by lac 85-10 RWCU isolation; inadvertent open circuit during ST.
Corrective action -- revised ST and pursuing design mod.
85-11 RWCU isolation; inadvertent short circuit during ST.
Corrective action -- revised ST and requested design mod.
85-16 H PCl isolation; inadvertent short circuit during ST.
Corrective acticn -- Issued training memo and requested design mod.
85-20 Rx Enclosure vent isolation; lifted lead while troubleshooting a problem on a different i n s t rumen t.
A Tempora ry Circuit Alteration was authorized but lifting the lead caused the unexpected isolation. Corrective action --
hang cautiona ry tags.
85-49 MSev trip; incorrectly installed test equipment blew fuse in the valve controls logic generating the MSIV i
closure signal. Corrective action -- counsel technician.
4-Vo lvino E rro r by IkC 85-18 Reactor enclosure isolation; did not reall2e that refuel floor differential pressure transmitter shared a common reference leg with reactor enclosure differential pressure transmitter and caused the isolation while troubleshooting the refuel floor instrument. Corrective action -- counsel technicians involved and prepare procedure giving guidance on filling, venting and valving i n s t rumen t s.
85-37 ECCS initiation; did not realize that a 100 psig deeln water hose was connected to the instrument rack and inadvertently pressurized the common reference leg during line backfilling. All transmitters effectively failed low producing various ESF actuations including half scram, LPCI, Core Spray, and HPCI initiation occurred as well as the start of the D-12 diesel generator. Corrective action -- counsel technician, revise procedure, added notes to training program.
85-40 ECCS Initiation; did not completely close a valve during ST causing pressurization of drywell pressure sensing line with instrument gas.
This caused initiation of Division 4 ECCS including Core Spray, RHR and D-14 diesel i
ge ne ra to r.
Corrective action -- counsel technician and discuss event with others.
i 85-47 Excess flow check valves inop; did not close manual bypass valves af ter backrilling ST causing 2 excess flow check valves to be inop for about 3 weeks. Another manua l bypass was fort open due to procedure error.
Corrective action -- revise deficient procedure and lock open a ll similar manue l bypass valves, a
a 1 - va s v i no E rro r by Oce ra to r 85-21 Screm; " cracked open" instrument isolation valve while clearing tagout causing pressure decrease sensed by other instruments on same line which generated scram signal on sensed low level. Correct ive action -- not i rled all shifts to let itC do all instrument rack volving.
1 1 - Poo r commun i c a t i on 85-06 Defeated RWCU automatic isolation; misunderstanding between shif t supervisor and control room operator led to a non-licensed operator being instructed to open the feeder breakers to both RWCU isolation valves for seven minutes during channel checks. An existing equipment problem had caused seven spurious RWCU isola tions (e.g.,
85-01) during routine channel checks, so personnel were opening one feeder breaker at a time while reading that 1.
cnannel. The poor communication led to both breakers being opened simultaneously which defeated the ability of i
RWCU to isolate automatically. Corrective Action -- counsel involved personnel, add tra ining, change p rocedures, post operator aid.
2-Personnel Error too Enoineer j
85-12 Rx Enct vent isolation; short circuit during troubleshooting by staff engineering. Corrective Action -- none.
85-39 NSSS isolation signal; volving error by test engineer while checking system lineup. Corrective Action --
generate procedure on performing system valve lineups 2-Inadeauste Taaout 85-17 Negative pressure in Control Room; tagout missed one exhaust valve. Corrective Action -- revise tagout i
sequences, evaluate negative pressure alare.
85-46 Scree signal; tegout omitted opening an instrument equalizer valve so that a slow fitting leak caused a differ-s ential pressure which generated the scram sign 6l.
2-Inadeauate Fire Watch 85-33 Pa t rol interval greater than 60 minutes. Corrective Action -- conduct training, improve controls.
85-43 I
2 - fersonnel Erre r_ by Unknown Individua l s 86-19 Partise loss of HPCI isolation ability; two leads were found to be reversed between a thermocouple and its associated temperature switch. The wi res were untabeled. Co rrec t ive Act ion -- check a l l similar wires and label them, improve ST, add event to reading list, i
85-32 Fire damper inoperable; damper round wired open, last verified correct 15 months previous, investigation i
could not determine when wired open or by whom. Corrective Action -- 230 other dampers checked with none found wired open, issued information meno to plant supervisory personnel, i
I j
1
V TECH SPEC RELATED 5-Procedure Errors 85-02 RWCU isolation; procedure did not allow adequate filling and venting of the system piping prior to placing the 8 domineralizer in service. The high dirrerential flow due to air present in the line lasted long enough to generate the high differential flow isolation. Corrective Action -- revise procedure.
85-15 Sprinklers inoperable; post-modification hydro of fire water supply piping tagged closed sprinkler isolation va lves and set compensatory fi re wa tches. Af ter the hydro was completed the fire watches were secured and the tags clea red. but the valves were left closed rendering thei r associated sprinkler systems inoperable.
The controlling administrative procedure addressed only safety-related systems and did not cover the restoration or non-safety related systems required by Tech Spec.
Correct ive Action -- new hydro procedure, revise adminis-t ra t i ve p rocedu re.
85-22 MSIV leakage control system inoperable; breakers requi red to be shut by Tech Spec were not requi red to be reclosed at the end or an ST and were round to be open.
Corrective Action -- revise ST.
85-34 Inadequate sodium pentaborate volume; the standby liquid control system tank is required by Tech Spec to contain at least 5500 pounds or sodium pentaborate available for injection. The ST which was used to confi rm that this requirement was met did not reflect that tank level below the pump low level trip setpoint would not be available for injection. Corrective Action -- revise ST.
85-38 Inadve rtent isolation of the RHR shutdown cooling line; ST neglected to reposition all appropriate valve control swi tches at the end of the test so that the isolation signal generated during the test was not cleared. When power was restored, system isolation occurred. Co r rec t i ve -- revise ST.
1 - Misunderstood TS/LCO 85-13 Partial loss of HPCI isolation ability; transmitter was not placed in trip condition af ter not being available for one hour during troubleshooting, due to confusion over Tech Spec requirements. Corrective Action -- letter issued to shif t personnel to clarify Tech Spec action statement requirements.
l W
1 s
o EQUIPMENT FAILUMES 5 - Chlorine Ana lyzer Taos Break 85-29 Cont ro l room ventilation; in all of the events the sample tape broke for one of the four chlorine analyzers 85-30 causing a full sca le reading. The high observed value caused the normal vent system to isolate and an emergency 85-31 f resn a i r system to auto sta rt.
Corrective action -- pursue modifications and consider obtaining different 85-42 a na lyze r mode l.
85-50 2
"RE AD" Position Sourious Siona l 85-01 RWCU isolation; in both of these events the " Temperature Differential Transmitter Switch" was placed in the 85-27
" READ" position' generating a spurious signal. Corrective action -- continue to use test equipment to moni tor c i rcu i t, j - JgnageLJluctuatlons 85-01 RPS and NSSS trips; in all of these events voltage fluctuations caused an interruption of power to the protec-85-24 tive system. Troubleshooting and followup of the earlier event showed that the root cause was high temperatures 85-26 in the cabinets housing the power supply. Co rrec t i ve Ac t i on -- c omp l e te mod i f i ca t i ons to i nc rea se ven t a i r f l ow and reduce temperatures inside power supply cabinets.
2 - Bad E lect rica l Connection 85-09 ESr trip; in both cases a bad electrical connection appeared like an open circuit causing safety feature 85-41 actuation. Corrective action ~~ inspection, clean, replace components.
2 - Unknown Cause 85-25 RWCU isolation; in both cases the isolation took place while performing the ST on an unrelated instrument 85-35 located in the same cabinet. Attempts to duplicate the event were not successful. Corrective Action --
install monitoring equipment to produce data If event recu rs.
1 - Slown Fuse 85-48 NSSS trips; a fuse in the NSSS logic blew causicg various isolations, cause unknown. Corrective action --
inspect ci rcuit. Install circuit monitoring equipment.
O s
OTHER LERS 85-04 HPCs inoperable; the failure of a transmitter made operators feel tha t HPCI might be Inoperable. The operators isolated HPCI and, since RCIC was already inoperable, began a shutdown. RCIC was restored and the shutdown was secu red.
Corrective Action -- discuss matter with operations personnel, send memo to licensed operators, modify requa lification program.
85-OS Rx Enclosure vent isolation; high winds caused false input to differential pressure sensors. Co r rec t ive action -- pursue system modifications, d
85-23 Rx Enclosure vent isolation; loose fan fitting caused zero blade pitch on exhaust fan which led to a loss of negative pressure and isolation. Corrective action -- check other fittings, change time delays on standby fan to prevent recurrence.
m 1
3 s
I7590-01]
U. S. NUCLEAR REGULATORY COINISSION DOCKET NOS. 50-352/3b3 PHILADELPHIA ELECTRIC COMPANY LIMERICL GEhERATING STATION, UNITS 1 AND 2 ISSUAhCE OF DIRECTOR'S DECISION UNDER 10 CFR 2.206 liotice is hereby givu. that the Director, Office of Nucien he:4ctor Regulation, has denied the Petition and supplementing oocur.ients filed under 10 CFR '.106 by F. L. Ar.thony and the Friends of the Een.l. regaroing the Luierid c
Generating Station Units 1 and 2 (the facility).
The Petitioner requested that the tFC institute show cause prececen.g to revoke the Ft.cility Operating License No. NPF-E7. heretofore granted to the Philodelphiu Electric Cctrary (PECo) to authorize operatici, cf the Limerick Unit 1 facility at power levels not to exceed five percent of rated power.
Variubs issues related to the safe operation of the. Liverick Unit 1 piatit wi:ii; raiseo by the Petiticn and its supplements. Issues includeo the appropriater. Css cf certain exemptions granted when License ho.14PF-27 was issued and alleged poor f acility design and operational performance. The Director concluded that those issues did not constitute a substantial safety concern warranting the institution of show cause proceedings.
The reasons for the above c.onclusions are fully described in a
" Director's Decision Under 10 CFR 2.206", dated July 29,1965, (LL-L5-11) which is available for public inspection in the Comissior,'s Fublic Document Roon located at 1717 h Stru t,!!.11., Washington D.C.
20FF6, t.r.d at tN Pottstuur, Public Library, 500 High Street, Pottstown,1ennsylventa 19404
o o
e 2-A copy of the Decision will be filed with the Secretary for the Commission's review in accordance with 10 CFR 2.206(c).
Dated at Bethesda, Maryland, this 29th day of July 1985.
FOR THE NUCLEAR REGULATORY COMMISSION Harold R. Denton, Di. rector
/
Office of Nuclear Reactor Regulation e
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k NUCLEAR REGULATORY COMMISSION UNITED STATES j
WASHING TON, D. C. 20555
/
FEB 13 1985
~
Docket Nos.: 50-352 50-353 (10 CFR 2.206)
Mr. Robert L. Anthony Box 186 Moylan, Pennsylvania 19065
Dear Mr. Ant.hony:
This letter acknowledges receipt of the Petition filed by you on behalf of yourself and Friends of the Earth (Petitioners) on December 23, 1984. The Petition requests that the Director of the Office of Inspection and Enforce-ment institute proceedings pursuant to 10 CFR 2.202 by serving an order on the Philadelphia Electric Company (Licensee) to show cause why License No. NPF-27 issued for the Limerick Facility should not be revoked.
The Petition argues that certain exemptions granted to the Licensee when License No. NPF-27 was issued were improvidently granted and that the public health and safety is thereby endangered. Specific exemptions identified are concerned with control room habitability, the standby gas treatment system, compliance with 10 CFR Part 50 Appendix J, and the adequacy of isolation valves for certain systems. Secondly, the Petition argues that Licensee Event Reports issued by the Licensee since the comencement of operation under the low-power license are further indication that activities under the license are being conducted in an unsafe fashion. Thirdly, the Petition makes reference to various Inspection Reports issued by the NRC and to correspondence between the Licensee and the NRC as identifying additional deficiencies warranting revocation of the license.
Finally, the Petition suggests that the Independent Design Verification Program undertaken for the Limerick Facility was insufficient to support issuance of the low-power license.
Although your Petition was directed to the Office of Inspection and Enforce-ment my office will respond to your Petition in that it deals with activities authorized by the low-power license for the Limerick Facility which this office issued.
The Petition is being treated under 10 CFR 2.206 of the Comission's regulations. The Staff will review the Petition and I will issue a formal decision in regard to it within a reasonable time. The Petition does request the irmediate issuance of a show cause order to the Licensee based on the concerns identified in the Petition.
Preliminary review of the Petition indicates that the Petition provides no new information which would serve as a basis for such action.
The exemptions referred to in the Petition, as indicated by Paragraph 2.0 of License No. NPF-27, were evaluated by the NRC staff and discussed in the
&d,
, /
d-M4%i)}U r_)g Ylp.
2 Safety Evaluation Report related to the operation of the Limerick Generating Station, Units 1 and 2 (NUREG-0991) or in supplements thereto. These SER findings support issuance of the exemptions granted in License No. NPF-27 Licensing Event Reports (LERs) are required to be filed with the NRC only after issuance of a facility operating license, and are promptly evaluated.
This has in fact occurred with the LERs that have been issued for the Limerick facility. The NRC review of those LERs does not justify any imediate actions with respect to the facility.
The NRC staff was aware of the issues addressed in the Inspection Reports and correspondence between the licensee and the staff, referenced by the Petition, at the time of issuance of License No. NPF-27 and considered those issues as appropriate to allow issuance of the License. The specific Inspection Reports referenced in your letter documented the results of inspections conducted prior to the issuance of License No. NPF-27 on October 26, 1984.
Although some of the reports were fonnally issued to the Licensee after October 26, the findings in these reports were well known to the NRC prior to issuance of the license. Each of the inspection findings was assessed by the NRC to determine the potential safety impact. Those findings necessary to be resolved prior to license issuance were so resolved and documented in subsequent Inspection Reports. Similarly, those findings necessary to be resolved prior to initial reactor criticality were satisfactorily resolved prior to the start of this plant evolution on December 22, 1984. No new information has been set forth in the Petition which would call into question those earlier decisions.
Finally, the status of the NRC staff's review of the Independent Design Verification Program at the time of issuance of License No. NPF-27 was reported in Supplement 3 of the Safety Evaluation Report. For the reasons stated there, the staff concluded that completion of the program was not necessary prior to issuance of License No. NPF-27.
As discussed above these are all matters of which the NRC staff is well aware.
None of these matters requires immediate action sought by the petition regarding continued operation of the facility. Consequently, I decline to take any immediate action on the basis of your Petition. A copy of the Notice that is being filed for publication with the Office of Federal Register is enclosed for your information.
Sincerc'y,
[
/
Harold R. Denton, Director Office of Nuclear Reactor Regulation i
Enclosure:
As stated cc(w/ encl.):
See next page
LIMERICK Mr. Edward G. Bauer, Jr Vice President & General Co.unsel Philadelphia Electric Company Philadelphia, Pennsylvania 19101 Troy B. Conner, Jr., Esquire Mr. Marvin I. Lewis Conner and Wetterhahn 6504 Bradford Terrace 1747 Pennsylvania Ave, N.W.
Philadelphia, Pennsylvania 19149 Washington, 0..C.
20006 Zori G. Ferkin Frank R. Romano, Chairman Assistant Counsel Air & Water Pollution Patrol Governor's Energy Council 61 Forest Avenue 1625 N. Front Street Ambler, Pennsylvania 19002 Harrisburg, Pennsylvania 17105 Federic M. Wentz Charles W. Elliott, Esquire County Solicitor Brose & Poswistilo, 1101 Bldg.
County of Montgomery 325 N.10th Street Courthouse Easton, Pennsylvania 18402 Norristown, Pennsylvania 19404 Eugene J. Bradley Ms. M. Mulligan Philadelphia Electric Company Limerick Ecology Action Associate General Counsel 762 Queen St.
2301 Market Street Pottstown, Pennsylvania 19464 Philadelphia, Pennsylvania 19101 Mr. Vincent Boyer Mr. Karl Abraham Senior Vice President Public Affairs Officer Nuclear Operations Region I Philadelphia Electric Company U.S. Nuclear Regulatory Comission 2301 Market Street 631 Park Avenue Philadelphia, Pennsylvania 19101 King of Prussia, PA 19806 Mr. Suresh Chaudhary Thomas Gerusky, Director Resident Inspector Bureau of Radiation Protection U.S. Nuclear Regulatory Comission Dept. of Enviromental Resources P. O. Box 47 Sth Floor, Fulton Bank Bldg.
Sanatoga, PA 19464 Third and Locust Streets Harrisburg, Pennsylvania 17120 James Wiggins, SR. R.I.
U. S. Nuclear Regulatory Comission P. O. Box 47 Sanatoga, Pennsylvania 19464
Sugarman, Denworth & Hellegers Director, Pennsylvania Emergency 16th Floor Center Plaza Management Agency 101 North Broad Street t asement, Transportation &
l Philadelphia, Pennsylvania.19106 Safety Building Harrisburg, Pennsylvania 17120 Robert L. Anthony Angus Love, Esq.
Friends of the Earth 107 East Main Street Delaware Valley Norristown, Pennsylvania 19402 103 Vernon Lane, Box 186 Moylan, Pennsylvania 19065 Martha W. Bush Helen F. Hoyt, Chairman Deputy City Solicitor Administrative Judge Municipal Services Bldg.
Atomic Safety & Licensing Board 15th and JFX Blvd.
U.S. Nuclear Regulatory Comission Phildelphia, Pennsylvania 19107 Washington, D. C.
20555 David Wersan, Esq.
Dr. Jerry Harbour Assistant Consumer Advocate Administrative Judge Office of Consumer Advocate Atomic Safety & Licensing Board 1425 Strawberry Square U.S. Nuclear Regulatory Comission Harrisburg, Pennsylvania 17120 Washington, D. C.
20555 Steven P. Hershey, Esq.
Dr. Richard F. Cole Comunity Legal Services, Inc.
Administrative Judge Law Center North Central - Bevry Bldg.
Atonic Safety & Licensing Board 3701 North Board Street U.S. Nuclear Regulatory Comission Philadelphia, Pennsylvania 19140 Washington, D. C.
20555 Mr. J. T. Robb, NS-1 Mr. Spence W. Perry, Esq.
Philadelphia Electric Company Associate General Counsel 2301 Market Street Federal Emergency Management Agency Philadelphia, Pennylsvania 19101 Room 840 500 C St., S.W.
Timothy R. S. Campbell, Director Washington, D. C.
20472 Department of Emergency Services 14 East Biddle Street West Chester, Pennsylvania 19380
f7590-01]
NUCLEAR REGULATORY COMMISSION IDocket Nos. 50-352,50-353]
PHILADELPHIA ELECTRIC COMPANY (Limerick cacility)
Request for Action Under 10 CFR 2.206 Regarding Continued Operation At The Limerick Facility Notice is hereby given that, by a Petition dated December 23, 1984, R. L. Anthony and Friends of the Earth (Petitioners) requested that the Nuclear Regulatory Comission institute proceedings by issuing an order to show cause to the Philadelphia Electric Company (Licensee) why License No. NPF-27 for its Limerick Facility should not be revoked. The Petition bases its request for license revocation upon four concerns, namely; that exemptions granted with the issuance of License No. NPF-27 were improperly granted and consequently continued operation raises public health and safety concern:; that Licensee Event Reports filed since the issuance of the License demonstrate that continued operation of the facility is unsafe; that NRC Inspection Reports and correspondence between the NRC and the Licensee further indicate deficiencies at the facility requiring license revocation; and that the Independent Design Verification Program conducted for the facility was insufficient to provide assurance of safe operation under License No. NPF-27.
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The Petition is being, treated pursuant to 10 CFR 2.206 of the Comission's regulations and accordingly appropriate action will be taken on the request within a reasonable time. A copy of the Petition is available for inspection in the Comission's,Public Document Room,1717 H Street, N.W., Washington, DC 20555 and at the local document room for the Limerick facility located at the Pottstown Public Library, 500 High Street, Pottstown, Pennsylvania 19464 Dated at Bethesda, Maryland, this 13th day of February 1985.
FOR THE NUCLEAR REGULATORY COMMISSION.
l Harold R. Denton, Director Office of Nuclear Reactor Regulation t
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DISTRIBUTION GREEN TICKET - E00 Ticket #000238 Docket File 50-352/353 NRC PDR*
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VYanez, TIOC-2 ASLP ASLAP l
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' Docket Nos. 50-352/353 i
L (10 CFR 2.206) i Mr. Marvin I. Lewis 6504 Bradford Terrace Philadelphia, Pennsylvania 19149 0'
Dear Mr. Lewis:
15, 1985, This letter acknowledges receipt of your letter to me of February commenting on the Petition filed by Mr. Robert L. Anthony on Decenber 23, That Petition sought the 1984 on behalf of trimself and Friends of the Earth.
I.
i institution of proceedings pursuant to 10 CFR 2.202 by serving an order on I
p the Philadelphia Electric Company to show cause why License No. NPF-27 issue I
l Your letter provides your for the Limerick facility should not be revoked.
t' l
You coments on certain issues raised by Mr. Anthony in his Petition.
i Your coments will be request that Mr. Anthony's Petition be granted.
considered in the formal decision I reach in respect to this matter pursuant t
to 10 CFR 2.206.
Sincerely, Orip sced 6f H. R. Denton Harold R. Denton, Director Office of Nuclear f.eactor Regulation Distribution 1 Docket File NRC PDR Local PDR L8#2 Reading EHylton EMGfliG AD/L, P. O'Brien DL#794
- Previous concurrences concurred on by:
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Docket Nos. 50-352/353
- ~
Mr. Robert L. Anthony Box 186 Moylan, Pennsylvania 19065
Dear Mr. Anthony:
This letter acknowledges receipt of your letter to me dated February 25, 1985 reiterating the request made in the Petition filed by you on December 23, 1984 that I institute proceedings pursuant to 10 CFR 2.202 by serving an order on the Philadelphia Electric Company to show cause why License No. NPF-27 issued for the Limerick facility should not be revoked.
Your letter will be treated as a supplement to the Petition and the information it contains will be taken into consideration in the formal decision which I will issue.
For the same reasons stated in my letter of February 13, 1985 to you, however, I decline to take any innediate action on the basis of the information contained in your letter.
Sincerely.
Ont'm8 M U
- n. R. Dentes Harold R. Denton, Director Office of Nuclear Reactor Regulation Distribution:
Docket File NRC POR local PDR PRC System LB#2 Reading EHyl. ton (hMa r,t,{@
AD/L, P. O'Brien DLp794 g
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lf U.S.NUCT m REGULATORY COEJISSION f ic0 /
5 Re PHILA. ELEC. Co.
Limerick Nuclear con Sta.
Docket No.
50-352,353 %
~
April, 5,1985 APPEAL RY R.L. ANT.10NY/FCE FROM REFUSAL OF NRC DIRECTOR OF REACTOR REGULATION TO ACT ON OUR PETITION OF 12/23/8.1 TO SERVE A SHOW CAUSE ORDER,AND OUR REQUEST FOR AECONSIDERATION, 2/25/85 ; MS FOR AN'URDER FROM TE CCVMISSION.
On12/23/85 we submitted a petition to t$ DirectorTNaspeetion and En-forcenent to issue a show c use order to start proceedings to revoke low power a
license NFF-27 Te included substantiating evidence and references to show that PEco is not able to operate the Limerick % idteirasafely.
After a delay of 1 months Mr.E.Denton replied that our petition did not require any immediate action and he declined to take any immediate action.
We replied to Mr. Denton's letter on 2/25/85,asking for reconsideration and submitting further evidence from PEco's operation to date, of the faults in equip-ment and operator performance which demonstrated further PEco'r inability to operate without endingering the public,NHC staff,and PECo employees. In a 3/26/85 letter Mr. Denton again " decline (d) to take any immediate action".
It is now more than three months since our petition for a show cause order, and PEC's operating record contains many more reports of violatione and repeated errors which at higher levels of operation could have brought on a serious accident and threat to the public health and s fety.
We believe themDirector's a
withholding of action on our petition amounts to a delaying tactic which threat-ens our he lth and safety under PECo 's imminent ascension to levels above 5 %,
a (See letter Daltroff to Denton 3/25/85), predicting a full power license n April.
We hereby petition the Commission to order the-Director to issue a show cause order and to institute a hearing process on the revoking of t&m low power license.
We further petitiorr the Commission to order the reactor to be held in a shut down state until a decision on revoking the license hae been made.
We present further evidence of PEco's inability to operate the reactor safely Conditions required under the license have not been satisfied as follows:
IM?IGEMENT LOADS ON PIPES & SUPPORT (Torrey Pines) 3/8/85 R.E. Martin to PEco.
REDUNDANCY IN REMOTE SEUTDOWN CAPA3ILITY 3/ 85 A.Schwencer to E.G. Bauer DETAILED CONTROL ROOM DESIGN REVIEW
/85 SAFETY PARAMETER DISPLAY SYSTEM
/85 a
m The reactor cannot be safely operated until there has been a complets check' y
on all safety systems and re-training of operators and supervisors to eliminate the possibility of process and equipment failure with consequences for accidents com 73 8 as indiented below N
-Safety-related equipment removed from service without permission, Violation p
85-02 and Control Room avAC system change without NRC approval, Violation 85-0 jy
- INapiction 85-11 possible diesel fire ptasp flywheel crack,p.5; troubleshoot pf
- Por 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> containment isolation valves inoperable,Inspecti 85-08,1/15/85 i )o Y
- For Th hours without protection of volume level switch,
-14,1/18/85 L.
- Tag-out operated by construction /craf t personnel inste o lER,85-15, v
Repeated isolation of RWUU as in LEHs85-25,85-27( "cause of event remnna no NO under investigation") and previous LERs 84 12",26,34,35,36.
- Repeated scrams and half scrams from loss of power to safety systems,LER 85-24 and LERs. 84-05,39,and 85-07 We petition the Commission to order a show catse order and to require a hearing to take testimony as to the revoking of the licenseNPF-27,and in the g
interval to suspend operation of the Limerick reactor.
, Ce s (S
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t PEGULATORY INFORMATION DISTRIBUTION SYSTFM (RIOS)
ACCESSION NPP: 850409030o DUC.D ATE : 85/04/05 NOTARIZED: NO DOCKET u FACIL:50-352 Limerick benerating Station, Unit 1,
Philadelphia Ele 05000352 50-353 Limerick uen* rating 9tation, Unit 2, Philadelphia Ele 05000353 AUTH.havE AUTHUR AFFILIATION ANTHON),P.L.
- Anthony, M.L.
RECIP.NAMt RECIPILNT AFFILIATION Commissioners
SUBJECT:
Petition for commission to order H Denton to issue show cause order % to institute hearing process on revoking facility low power license based on 850225 submittal of further evidence of util faulty operations.
DISTRIBUTION CODE: DS030 LOPIES RECEIVED:LTR g( ENCL 32 SIZE
/
TITLE: Filings (Not Orig by 44RC)
NOTES:LPDR 2cys Transcripts.
05000352 OL:10/26/84 LPDR 2cys Transcripts.
05000353 HE C I P I L P'T LOPIES RLCIPIENT COPILS IV CODE /NAkE LTTR ENCL 10 CODE /NAME LTTR ENrL NOW ' nQC 1
NRR LB2 LA 1
CMakTIN,o]
1 ASL6P 01 1
J INTERNAL: ASLAP S
i LLD/PSB 1
GC 1
1 ope APON,J.
1 PA 1
1 HGN1 1
EXTERAAL: LPOR 1
NRC PbR 1
1 NOTES:
4 2
TOTAL NbudEh 0F COPIES nfuu1PLO: LTTR 18 ENCL
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4
$r.haroldR.Denton, Dir. NRC Off. Nuclear Reactor Reg.
'tay 9,1985 7ashington, D.C. 20555 des Phila. Elec.Co., Limerick.
Gen.Sta. Units 1&2. Doc.50-jy
Dear Mr.Denton,
We are again calling your attention to our petition of 12/23/84 and our further petition of 2/25/85 requesting that you issue a show cause order to initiate proceedings to revoke low power license NPF-27 issued to Phila. Elec.
Co. for its Limerick plant, unit //1.
7e' are enclosing a copy of our letter,
4/27/35, to Hugh L. Thompson as further evidence to back up the need for this orde:
The evidence which we subctitted to you conclusively proves that PICo is not qunlified to operate the plant safely en d the license should be revoked until equipment, employee,and process deficiencies have been comp 1~etely rece-died.
The present operation of this plant by PECo is a present and continuing threat to our health and safety.
Tn of Sections of license NPF-27:
Pari. addition we now cite PECo's violatioShe license
- 1. C. Limerick will operate in violation of through the use of Schuylkill 3
River water for ccoling during the low flow season,a d by demanding releases n
from the Blue Marsh reservoir,and by renouncing its ageement to the " river follower mode" with the Delaware River Ba in Commission. PECo's applications s
0 of 3/15/85 and 4/23/85 to DREC call-for removal of the 59 temperature limit.
from glue M rsh sto 3/19 & 4/26/85 to Serv $ce Eist wi.h encIosures. rage.(M.J.7etterhahn lettersThe and rol ase
- 1. D.
cooling will enda ger the health and safety of downstream watet-users by n
threatening the biglogical life of the river and, drawing upon reserves of drinking water,and Eonsuming water needed by industry to maintain jobs.
- 1. G.
PEco's use of Schuylkill water is inimical to family and community services and community health and safety because of the threat to public water supply.
Even in this time of drought MF.7.S. Boyer, PECo V.P. called upon DRVC in his written statement on 5/7/85 for " Equitable demands upon all im-poundments" despite PECo's agpeement with DRBC to be limited by flow condi-i Thish n violation of PECo's agreement with DRBC tions in the Schuylkill.
and in violation of the conditions of g e NRC license.
Sect. 31 of thd Appendix requires that's ppendix 3 of license NP7-27
- 1. H. Furthermore, PECo is in violation a "the licensee shall prepare and re-cord an environmental evaluation" before making such an application as this one to ch,nge the consumptive dem nds on the Schuy1xill river.
a Sect. 5 3 requires "an assessment of the environmental impact" and "NRC ap-proval of the proposed changes in the form of a license amendment incorpora-ting the appropriate revision to the EPP" (Environmental Protection Plan)
PECo's application to DRDC violates b'oth of these requirements of Appendix D.
As further evidence of the threat to the health and safety of the public from this consumptive use of Schuylkill water and Blue Marsh reserves, we cite the testimony of Mr. David C. Yaeck Executive Director,Chegter County dater Re-in oppo ition to the removing of the 59 restriction and sources Authority, s
the release of Blue Marsh water for Limerick consumption.
He testified at the DRBC hearing on 5/7/85 in aest Tronton as to the inviolate base that alue Marsh water constitutes for public wqter resource planning in Chester County. He said that a temporary request by PECo had the potential of becoming permanent, and his public agency (3ee DRDC trt.nscript 5/7/85) is completely opposed to PEco's modification of DRBC Docket D-69-210 CP, Ve are enclosing a copy of our 4/29/95 petition to ALA3 on this matter.
On 5/2/85 ALAB dismissed our petition and advised us to submit it to your office, cc a NRC ALAB, ASLD,Couns al, Docketing, PEco,DRBC Respectfully yours,,
qg0thersonServ. List
N
- kr. Hugh L. Thompcon, Jr.,Dir. Div. of Licensing,NRR April 27,1985 U.S Nuclear Regulatory Commis? ion, 7/ashington, 20555 Res Phile Elec. Limerick Gen. Sta.
Dear Mr.
- Thempson, Docket No. 50-352 Unit 1. Startup Testing We refer to your letter of 4/10/85 to E.G.Bauer in which you mentien a letter to Mr.Denton of 3/25/85 which indicates PECo's plan to test oper te a
the turbine-generator, to 5 % of rated power.
Ycu stnte, Ne,have not identi-fied any conflicts with ;pur plans on this =atter..."
the contrary we ha e identified several deficiencies and violations On v
from recent URC inspection reports which add up to the conclusion that PECo is not prepared to operate the plant safely at this time up to 5 % power or to test operate the turbine-generator.
We,therefore, ask you to protect our health and safety end that of the public by changing your conclusion froc " no objections" to we forbid any test operating of the turbine until the impedi-ments to safe operation listed below have been corrected end resolved.
Recicn I inspection report 85-03 dated 4/2/05 in Appendix A (3ec At9ch-ment 1. ) states that Tech. Spec.3 6.1 4 was violated from 12/29/94 to 1/30/85 because PECO allowed the two independent MSIV le knge control subsystems to be a
This constituted a serious threat to the public while the reactor was in operation.
Operation of the reactor should be suspended until FRC has the assur nce that thase systees are in order and PECo will caintain them in a
ogration.ptocatic opV.Stargst{ckianunesreabQ.Qnptes that thic PSIV-LCS violation "could be R
s In pection report 85-06, dated 4/1C/85, Appendix A, cites two violations s
which affected the power level of the reactor and which pose serious po+entiel hasards to tre public he lth and safety.
FECo allowed the power level of the a
reactor to be manipulated without the knowledre and consent of a licensed ep-erator, and pcroitted taintenance work to be done without per=incion from oper-(See Atta h=ent 2.)
A violation of Tech. Spec. (.8.1 er.1 stion personnel.
c Reg. Guide 1 33 Rev. 2, App. A, para. 9.e.
N page 11 of this same inspection report which deteils the uneuthorized reising of the re9ctor power evel, under 4.J.3 " Corrective Action Revies",
Mr. S.D.Ebneter,Dir. Renctor Safety, finds that the implementation of corrective action has not been developed and that review of these stepe,1.e. "three cor-rective actions to this event" will have to be covered " in a subsequent inspec-tion.
This is considered an unresolved item pending NRC review ( 352/85-06-03)."
It is unconceivable that you would allow any te t oper, tion of the turbine s
n while these uncertainties as to control of the power leveh are unresolv d.
In pection report 85-14, reported 4/23/s5,(. p.5 ) that" review of the startup s
test results is in process" and that"a number of changes were required" and "the adequacy of the licensee review of this startup test procedure will be assessed in a subsequent inspection ".
And para. 2 3 cites exception reports supposedly resolved,"but action still is required to close out the test exception." On page 6,STP-15 2,blem ha nn unresolved
" swap over situation" involving safety systoms states,"This pro s persisted during tests of HPCI and RCIC" and "in addition HPCI stop valve experienced erratic behavior..during the pump start... A modifics-is also rianned... These modifications will require retesting of HPCI ". Untti the problems with these eseential safety systems have been com letn1. cured ne F
are certain that you will not authorise any test operation of utbine-gener4 tor.
On behalf of intervenor Anthony / FOS,
in recognition of the abcve otatacles to safe operation of the Limerick reactor, we pejition 3 cu to excroise your authority to forbid TECo from test operating the turbine-ceneretor.
Ut f Couns l ces go,og:ers on ger, AULgeketing, Respec tfylly sub[mi tted, v.
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IMJP&cXte;x) RSPbR.T gf-e3 APPENDIX A NOTICE OF VIOLATION Philadelphia Electric Company Docket No.
50-352 Limerick Generating Station, Unit 1 License No. NPF-27 As a result of the inspection conducted on January 28 - February 1,1985 and in accordance with the NRC Enforcement Policy (10 CFR 2, Appendix C), published in the Federal Register Notice (49 FR 8583) dated March 8,1984, the following violation was identified:
Technical Specification Limiting Condition for Operation 3.6.1.4 requires two independent MSIV leakage control subsystems to be operable in Opera-tional Condition 2.
Contrary to the above, during the period between December 29, 1984 and Janua ry 30, 1985, while in Operational Condition 2, the two independent MSIV 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 I).
Pursuant to the provisions of 10 CFR 2.201, Philadelphia Electric Company is hereby required to submit to this office within thirty days of the date of the letter which transmitted this Notice, a written statement or explanation in reply, including: (1) the corrective steps which have been taken and the re-sults achieved; (2) corrective steps which will be taken to avoid further vio-lations; and (3) the date when full compliance will be achieved.
Where good cause is shown, consideration will be given to extending this response time.
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Wh *[rr 1-APPENDIX A I
NOTICE OF VIOLATION Philadelphia Electric Company Docket No. 50-352 Limerick Generating Station License No. NPF-27 Unit 1 Limerick, Pennsylvania l
As a result of the irtspection conducted on January 16 - February 7,1985, and in accordance with the NRC Enforcement Policy (10 CFR 2, Appendix C), the following violations were identified.
A.
Code of Federal Regulations 10 CFR 50.54(3)(J) requires in part
" Apparatus and mechanisms other than controls, the operation of which may affect the reactivity or power level of a reactor shall be manipulated l
only with the knowledge and consent of a licensed operator present at the controls".
Licensee administrative procedure A-7 in section 5.2.2, states similar requirements.
Contrary to the above, on January 25, 1985, instrumentation and controls personnel in the process of trouble shooting previous indication of erra-tic recirculation pump flow behavior caused an increase in recirculation pump flow, which increased reactor power, when connecting a recorder to the recirculation flow control circuit.
This work was performed without the knowledge and consent of the licensed operators present at the controls.
l This is a Severity Level IV Violation (Siapplement 1).
B.
Technical Specification 6.8.1. a requires, in part, " written procedures be established as recommended in Appendix A of Regulatory Guide 1.33 Revision 2."
Regulatory Guide 1.33, Revision 2, in Appendix A, paragraph 9.e, recommands, in part, " general procedures for the control of maintenance which includes items such as a method'for obtaining permission and clearance from operation personnel to work".
l Contrary to the above, as of January 25, 1985 controls to assure that permission is obtained from operations personnel prior to performing trouble shooting activities are not contained in general procedures.
This is a Severity Level IV Violation (Supplement I) l i
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U.S. NUCLEAR REGULATORY C0 EMISSION... ATOMIC SAFETY AND LICENSING APPEAL BOARD i
PHILA.ELEC. CO.
LIMERICK GEN.STA. Units 1 & 2.
DOCKET # 50- 352,353
~
Judge C.E. Kohl April 29,1985 Judge G.J.Edles Dr. R.L. Gotchy PETITION TO ALAB BY R.L. ANTHONY / FOE TO ORDER PECO TO EA}~E A CG2LETE ENVIRON -
- TAL STUDY OF THE PROPOSED CHANGES IN THE DELANARE RIVER BASIN COMPACT p$ TO ISSUE A STAY.
A On 3/19/85 PECo forwarded to the Bo rd a copy of its 3/15/85 applicatio n a
to the Delaware Basin Commission to remove the temperature limits on withdraw-als from the Schuylkill River and to increase releases from the Blue Marsh Resevoir to augment the flow in the river.
We are opposed to these changes in the River Basin Co= pact as set forth below,and we ask the Board to order PECo to withdraw this application until an evironmental impact study of the consequences of the changes has been comclet-
'ed and approved by NRC and an opportunity has been provide to intervenors to present evidence on these impacts.
We further petition the Board to issue an immediate stay on any further pursuit by PECo of this application or its imple-mentation.
We point out that this application is in violation of the requirements of Appendix 3 of NRC Licence NPF-27 issued to PECo on 10/26/84:
3 1... Before engaging in additional construction or operational activi-ties which may significantly affect the environment, the licensee shall prepare and record an environmental ev luation of such activity.
a 5 3 Changes in Environmental Protection Plan.
Requests for changes in the EPP shall include an assessment of the eviron-mental impact or the proposed chenge and a sunporting justification.
Implementation of such changes in the BPP shall not commence prior to R
N C approval of the proposed changes in the form of a license amendment incorporating the appropriate revision to the EPP.
PECo's environmental considerations included in the application are super-ficial and ins fficient,as are those in the Amerdment No.1 dated 4/23/85. They u
do not in any way fulfill the requirement for an environmental impact study or a license amendment incorporating revisions to the EPP as specified in para. 5 3.
A thorough study of the effects on river biological life and downstream users is requirfd.
Wo nota also the Bo rd's stntement of 9/26/84 ( ALAB - 785, p. 60) " The n
Board correctly noted that the Blue Marsh Heservoir is not now a real alternative for supplementing the Schuylkill River water for Limerick." FECo's plan to with-draw Blue Earsh water is in contradiction to this.
We enclose our summary in opposition to the application sont to DRBC 3/20/95 which adds further pointe supporting an order by the Board and an immediote stay.
henrec tfully/-.
ces NRC ASLB, Staff Counsel, Docketing, submitted.
b t-An-Wu/
PECo, DRBC, R.Sucnrran,othere on Sorv.Lis t g
)g Box 106
!,:oyl a n, Pa. 19065(
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.* E'. Surn Disrn, Sacrotary Box 186 Moyltn,Pc.19065 s
enrn River Basin Crmmiccion DalcIJ60 West Trenton,N.J. 08628 Mnrch 28, 1985 Box
Dear Es. Weisman,
As an intervenor in the NRC licensing procedings for Philadelphia Electric Company's Limerick Nuclear plant, we have been representing citizen he lth and a
safety interests under the name of Robert L. Anthony / Friends of the Earth in the Delaware Valley.
We recently were provided with a copy of PECo's application,
dated 3/15/85, seeking Da3C's authorization to change the standards for the Schuylkill River and to provide cooling water by releases from the Blue Maesh
~
reservoir.
We wish to inform DR3C of our vital interest in this application and to request that we be admitted as parties and included in written presenta-tions and afforded the opportunity to testify before the Commission.
We ask that DRBC provide us time to make a thorough study of the impacts of the authorizations requested by PECo ahd to submit our evidence against any change in the present regulations governing the Schuylkill River before any final consider tion by the Commission.
a At the mo=ent we summarize our opposition to PEco's application under the following he dings:
a
- 1. DRSC, set its standards for the Schuylkill af ter careful study and these should not be changed,even temporarily,without a nos environmental impact study.
2". A temporary permit could certain'ly lead to a lon'ger ters one,since there is uncertainty over the sts,tus of the Pt. Pleasant diversion and continuing litigation.
~
- 3. The City of Phila. has 'offe-red to sell water to PEco.
The possibility of accelerating this connection could provide a temporary,and a permanent, solu-tion of the supplemental water supply.
4 If DRBC decided that using its water reserves for Limerick cooling wss a proper use of area water,it only arrived at this conclusion on the basis of combining water from the Delaware with the Schuylkill.
Providing water from the Schuylkill alone, the Commission, wisely never authorized and this decision should not be modified in any way.
5 PRCo has not demonstrated that it has explored alternatives,such as water from the City of Phila.
( See PE0o Attachment 2.)
- 6. Other users will be enda gered as FECo intimates in Attach. 2 (1) in n
stating that consumptive use will make the Schuylkill "largely unavailable for such (PECo) withdrawals during the period June to October.1995."
DR3C made the water unavailable to protect water resources on a sound basis.
- 7. Nothing ho s chn eed to modify DER Secretary R. A.Lukaa's position quotsiin n
Attach. 2 (3),
- Green Lane is not large enough to meet the combined needs of P3d Co. and Limerick."
9.
Me suring diserivad oxygen levels is not a substitute for the 53 tempera-a ture constraint. Higher temperatures impact the biological life of the river.
- 9. A dissolved oxygan restraint should be added to the Schuylkill standarde, not substituted for the 59 limitation.
- 10. The current rainfall shortage could progress into a drought. This reinfor-ces the need to conserve water resources and not to modify the present restrictions.
- 11. We oppose PEco's appitcation as it would degrade the Schuylkill and im-peril essential water reserves.
Oct NRC-ASLB Judges, Staf f, Docke ting -
Respectfully submitted,
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Mr. Harold 2.Denton, Dir. NRC Off. Nuclocr Reactor Reg.
may 9,1 m Washington, D.C. 20555
- te : Phila. Elec.Co., Limerick ~
Gen.Sta. Units 1&2. Doc.50-y We are again calling your attentiorr to our petition of 12/23/84 and our further petition of 2/25/85 rguesting that you issue a show cause order to initiate proceedings to revoke low power license NPF-27 issued to Phila. Elec.
Co' for its Limerick plant, unit #1'... We' are enclosing a copy of our letter,
f 4/27/85, to Hugh L. Thompson as further evidence to back up the need for this order The evidence which we submitted to you conclusively proves that PECo is not qu lified to opera:te the plant safely en d the license should be revoked a
until equipment, employee,and process deficiencies have been completely reme-died.
The present operation of this plant by PECo is a present and continuing threat to our health and safety.
pg addition ne now cite PECo's violatiogf Sections of license NPP-27:
license
- 1. C. Limerick will operate in violation of through the use of Schuylkill g
River water for cooling during the low flow season,a d by demanding rele ses n
a from the Blue Marsh reservoir,and by renouncing its ageement to the " river follower mode" with the Delaware River Ba in Commission. PECo's applications l
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of 3/15/85 and 4/23/85 to DR3C call-for removal of the 59 temperature limit.
I and rele ses from Blue M rsh sto age.(M.J.Wetterhahn letters 3/19 & 4/26/85 to Service List with encfosures.
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- 1. D.
The operation of Limerick with dependence on Schuylkill water for l
aooling will enda ger the health and safety of downstream water users by l
n threatening the biglogical life of the river and drawing upon reserves of drinking water,and Eonsuming water needed by industry to maintairr jobs.
- 1. G.
PEco's-use of Schuylkill water is inimical to family and community j
l services and co=munity health and safety because of the threat to public water l
supply. Even in this time of drought M8.7.S. Boyer, PEco V.P. called upon
'JRVC in his written statement on 5/7/85 for " Equitable demands upon all in-ag eement with DRBC to be limited by f'.ow condi-poundments" despite PEco'sThis{jnviolationofPEco'sagreementwithDRBC tions in the Schuylkill.
and in violation of the conditions of tlae NRC license.
oI 3 1 of thd Appendix' requires that's ppendix B of license NPF-27
- l. H. Furthermore, PECo is in violation A "the licensee shall prepare and re-Sect.
cord an environmental evaluation" before making such an application as this one to change the consumptive dem nds on the Schuylkill river.
a Sect. 5 3 requires "an asseesment of the environmental impact" and "NRC ap-proval of the proposed changes in the form of a license amendment incorpora-ting the appropriate revision to the IPP" (Environmental Protection Plan)
PEco's application to DRBC violates b"oth of these requirements of Appendix B.
As further evidence of the threat to the health and safety of the public from this consumptive use of Schuylkill water and Blue Marsh reserves, we cite the testimony of Mr. David C. Taeck, Executive Director,Chegter County #ater Re-in oppo ition to the removing of the 59 restriction and sources Authoiity, s
the release of Blue Marsh water for Limerick consumption.
He testified at the DRBC hearing on 5/7/85 in #est Trenton.as' to the inviolate base that Blue Marsh water constitutes for public wgter. resource planning in Chester County. He said that a temporary request by PEco had-the potential of becoming permanent, is completely opposed to PECo's modification of DREC and his public agency (See DRBC transcript 5/7/85.1 Docket D-69-210 CP,
- eareenclosingacopyofour4/29/85petitiontoAL13onthismatter.
On 5/2/85 ALAB. dismissed our petition and advised us to submit it to your office, Respectfully cc: NRC ALAB,ASLB, Counsel, Docketing, PECo,DREC g i,yours,,
Others on Serv. List M a -,.
W-c-Sor 186 P ylan,Pa. 19065 9 b J f(O ) 6,w a 0 I P-
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b.S Nuclea r R.gulatory Commis* ion, Jarhington zup>>
Res Phila Elec.Li=erick Gen. Sta.
Dear Mr.
- Thompson, Docket No. 50-352 Unit 1. Startup Testing
'#e refer to your letter of 4/10/85 to E.G.Bauer in which you centien a letter to Mr.Denton of 3/25/85 which indicates PECo's plan to test oper te a
the turbine-generator, to 5 % of rated power.
You stnte, "We have not identi-fied any conflicts with jour plans on, this matter..."
4 On the contrary we have identified several deficiencies and violations from recent NRC inspection reports which add up to the conclusion that PECo is not prepared to operate the plant safely at this time up to 5 % power or to test operate the turbine-generator.
We,therefore, ask you to protect our health and safety and that of the public by changing your conclusion from " no objections" to we forbid any test operating of the turbine until the impedi-ments to safe operation listed below have been corrected end resolved.
Region I inspection report 85-C3 dated 4/2/85 in Appendix A (Sec At'ech-ment 1. ) stetes that Tech Spec.3 6.14 was violated from 12/29/84 to 1/30/85 l
because PECO allowed the two independent MSIV le k ge control subsyste=s to be an i
This constituted a serious threat to the public while the reactor j
was in operation.
Operation of the reactor should be suspended until lac has the assur nce that these systems are in order and PECo will caintain them in a
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(
t operation.
R7 n un es$reablE.{ie}nk.p'tes that this FSIV-LCS violation "could be symptomatic of a.Starkst eki In pection report 85-06, dated 4/lo/85,Appendir A, cites two violations s
which affected the power level of the reactor and which po:se serious potential i
hazards to the public he lth and safety.
FECo allowed the power level of the l
a reactor to be manipulated without the knowledge and consent of a licensed op-I erator, and permitted ceintenance work to be done without permussion from oper-(See Atta h=ent 2.)
A violation of Tech. Spec. (. 9.1 a r.d ation personnel.
c Reg. Guide 1 33 Rev. 2, App. A, para. 9.e.
On page 11 of this same inspection report which 'deteils the unauthorized raising of the reactor power level, under 4 3 3 " Corrective Action Review",
Mr. S.D.Ebneter,Dir. R'esctor Safety, finds that the t=plementation of corrective action has not been develope'd and that review of these steps,i.e. "three cor-rective actions to this event" will have to be co'ered " in a subsequent inspec-v tion.
This is considered an unrasolved item pending NRC review ( 352/85-06-03)."
It is unconceivable that you would allow any te t operg, tion of the turbine s
while these uncertainties as to control of the power leveh are unresolved.
In pection report 85-14, reported 4/23/85,(. p.5 ) that" review of the startup s
test results is in process" and that"a number of changes were required" and "the adequacy of the licensee review of this startup test procedure will be assessed in subsequent inspection ".
And para. 2 3 cites exception reports supposedly a
resolved,"but action still is required to close out the test exception." On page 6,STP-15 2,blem ha an unresolved
" swap over situation" involving safety systems states,"This pro s persisted during tests of HPCI and RCIC" and "in addition HPCI stop valve experienced erratic behavior..during the pump start... A modifica-is also planned... These modifications will require retesting of HPCI ". Until the problems with these essential safety systems have been com letely. cured'ce arecertainthatyouwillnotauthorizeanytestoperationofkurbine-generdtor.
j!
On behalf of intervenor Anthony / FOE,
in recognition of the above obstacles !
to safe oper tion of the Limerick re ctor, we pe a
a authority to forbid PECo from test operating the}ition you to exercise your turbine-gen e ra t or.
ces g o,ogff Counsger,ASLB Docketing Respectfylly submitted, St l
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INJPeesum R&Pb kT qS-c13 APPENDIX A 5
NOTICE OF' VIOLATION Philadelphia Electric Company Docket No.
50-352 Limerick Generating Station, Unit 1 License No. NPF-27 As a result of the inspection conducted on January 28 - February 1,1985 and in accordance with the NRC Enforcement Policy (10 CFR 2, Appendix C), published in the Federal Register Notice (49 FR 8583) dated March 8, 1984, the following violation was identified:
Technical Specification Limiting Condition for Operation 3.6.1.4 requires two independent MSIV leakage control subsystems to be operable in Opera-tional 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
,
- MSIV 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 I).
Pursuant to the provisions of 10 CFR 2.201, Philadelphia Electric Company is hereby required to submit to this office within thirty days of the date of the letter which transmitted this Notice, a written statement or explanation in reply, including: (1) the corrective steps which have been taken and the re-sults achieved; (2) corrective steps which will be taken to avoid further vio-lations; and (3) the date when full compliance will be achieved.
Where good cause is shown, consideration will be given to extending this response time.
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NOTICE OF VIOLATION Philadelphia Electric Ccmpany Docket No. 50-352 Limerick Generating Station License No. NPF-27 Unit 1 Limerick, Pennsylvania As a result of the inspection conducted on January 16 - February 7,1985, and in accordance with the NRC Enforcement Policy (10 CFR 2, Appendix C), the following violations were identified.
A.
Code of Federal Regulations 10 CFR 50.54(3)(J) requires in part
" Apparatus and mechanisms other than controls, the operation of which may affect the reactivity or power level of a reactor shall be manipulated only with the knowledge and consent of a licensed operator present at the controls".
Licensee administrative procedure A-7 in section 5.2.2, states similar requirements.
Contrary to the above, on January 25, 1985, instrumentation and controls personnel in the process of trouble shooting previous indication of erra-tic recirculation pump flow behavior caused an increase in recirculation pump flow, which increased reactor power, when connecting a recorder to the recirculation flow control circuit.
This work was performed without the knowledge and consent of the licensed operators present at the controls.
This is a Severity Level IV Violation (Supplement 1).
B.
Technical Specification 6.8.1. a requires, in part, " written procedures be established as recommended in Appendix A of Regulatory Guide 1.33 Revision 2."
Regulatory Guide 1.33, Revision 2, in Appendix A, paragraph 9.e, recommends, in part, " general procedures for the control of maintenance which includes items such as a method for obtaining permission and clearance from operation personnel to work".
Contrary to the above, as of January 25, 1985 controls to assure that permission is obtained from operations personnel prior to performing trouble shooting activities are not contained in general procedures.
This is a Severity Level IV Violation (Supplement I) f h
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-.a p' U.S. NUCLEAR REGULATORY COMaISSION... ATOMIC SAFETY AND LICENSING APPEAL BOARD PHILA.ELEC. CO.
LIMERICE GEN.STA. Units 1 & 2.
DOCKET #
50- 352,353 Judge C.H. Kohl April 29,1985 Judge G.J.Edles Dr. R.L. Gotchy PETITION TO ALAB BY R.L. ANTHONY / FOE,TO ORDER PECO TO EAKE A COMPLETE ENVIRON -
FUTAL STUDY OF THE PROPOSED CEANGES IN THE DELAWARE RIVER BASIN COMPACT AND TO ISSUE A STAY.
On 3/19/85 PEco forwarded to the Bo rd a copy of its 3/15/85 application a
to the Delaware Basin Commission to remove the temperature limits on wiithdraw-als from the Schuylkill River and to incre se releases from the Blue Marsh a
Resevoir to augment the flow in the river.
We are opposed to these changes in the River Basin Compact as set forth below,and we ask the Board to order PECo to withdraw this application until an.evironmental impact study of the consequences of the cha ges has been comulet-n
'ed and approved by NRC and an opportsnity has been provide to intervenors to present evidence on these impacts.
We further petition the Board to issue an immediate stay on any further pursuit by PECo of this application or its imple-mentation.
We point out that this a"pplication is in violation of the requirements of Appendix 3 of NRC Licence NPF-27 issued to PEco on 10/26/84:
3 1... Before engaging in additional construction or operational activi-ties which may significantly affect the environment, the licensee shall prepare and record an environmental evaluation of such activity.
5 3 Changes in Environmental Protection Plan.
Requests for changes in the EPP shall include an assessment of the eviron-mental impact oI the proposed chenge and a supporting justification.
Implementation of such changes in the EPP shall not commence prior to R
N C approval of the proposed changes in the form of a license amendment incorporating the appropriate revision to the EPP.
PEco's environmental considerations included in the application are super-ficial and in ufficient,as are those in the Amendment No.1 dated 4/23/85. They s
do not in any way fulfill the requirement for an environmental impact study or a license amendment incorporating revisions to the EPP as specified in para. 53 A thorough study of the effects on river biological life and downstream users is requir d.
e We note also the Bo rd's statement of 9/26/84 ( ALAB - 785, p. 60) " The a
Board correctly noted that the Blue Marsh Reservoir is not now a real alternative for supplementing the Schuylkill River water for Limerick." PECo's plen to with-draw Blue Marsh water is in contradiction to this.
We enclose our summary in opposition to the application sent to DRBC 3/28/85 which adds further points supporting an order by the Board and an i=mediste stay.
cet NRC ASLB, Staff Counsel., Docketing, Respectfully submitted, PECo, DRBC, R.Sugarman,others on Serv. List M
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Box 186 Moylan,Pa. 19065l
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n March 28, 1985 Box b0 Wsot Tranton,N.J. 08628
Dear Es. Weisman,
As an intervenor in the NRC licensing procedings for Philadelphia Electric Company's Limerick Nuclear plant, we have been representing citizen he lth and a
safety interests under the name of Robert L. Anthony / Friends of the Earth in the Delaware Valley.
We recently were provided with a copy of PECo's application dated 3/15/85, seeking DasC's authorization to change the standards for the Schuylkill River and to provide cooling water 'by releases from the Blue Marsh reservoir.
We wish to inform DR3C of our vital interest in this application and to request that we be admitted as parties and included in written presenta-tions and afforded the opportunity to testify before the Commission.
We ask that DRBC provide us time to make a thorough atudy of the impacte of the authorizations requested by PECo and to submit our evidence against any change in the present regulations governing'the Schuylkill River before any final consider tion by the Commission.
a At the moment we summarire our opposition to PECo's application under the following he dings:
a
- 1. DR3C. set its stand'a ds for the Schuylkill af ter careful study and r
these should not be clianged,even tempor rily without a new environmental impact a
- study,
- 7. A temporary permit could certain'ly lead to a lon'ger term one,since there is uncertainty over the sts,tus of the Pt. Pleasant diversion and continuing litigation.
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- 3. The City of Ehila. has offered to sell water to PECo.
The possibility of accelerating this connection could provide a temporary,and a permanent, solu-tion of the supplemental water supply.
4 If DRBC decided that using it,s water reserves for Limerick cooling was a proper use of area water,it only arrived at this conclusion on the basis of combining water from the Delaware with the Schuylkill.
Providing water fro =
the Schuylkill alone, the Commission, wisely never authorized and this decision should not be modified in any way.
5 PRCo has not demonstrated that it has explored alternatives,such as water from the City of Phila.
( See PEco Attachment 2.)
- 6. Other users will be enda gered as PECo intimates-in Attach. 2 (1) in n
stating that consumptive use will make the Schuylkill "largely unavailable for such (PEco) withdrawals during the period June to October.1985."
DR3C made the water unavailable to protect water resources on a sound basis.
- 7. Nothing ho s cha ged to modify DER 3ecretary R. A.Luksa's position quo tais in n
Attach. 2 (3), " Green Lane is not large enough to meet the combined needs of PSW Co. and Limerick."
8.
Me suring dissived oxygen levels is not a substitute for the 59 tempera-a ture constraint. Higher temperatures impact the biological life of the river.
- 9. A dissolved oxygen restraint should be added to the Schuylkill standards, not substituted for the 59 limitation.
- 10. The current rainfall shortage could progress into a drought. This reinfor-ces the need to conserve water resources and not to modify the present restrictione.
- 11. We oppose PECo's application as it would degrade the Schuylkill and im-peril essential water reserves.
Cc s NRC-ASLB Judges, Staff, Docketing -
Hespectfully submitted, PEco,PD!A, FEMA, Angus Love,0thers on Limerick Serv.
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_.2 APR 2 31985 Docket Nos.: 50-352/353 (10 CFR 2.206)
Mr. Fr'ank R. Romano, Chainnan Air and Water Pollution Patrol 61 Forest Avenue Ambler, PA 19002
Dear Mr. Romano:
This letter acknowledges receipt of your letter to me dated Mirch 11, 1985, joining in the petition filed by Robert L. Anthony of the Friends of the Earth concerning the Limerick facility.
Your letter expands upon Mr. Anthony's petition in requesting that until the alternative of shelter-ing during an emergency is fully examined, the Limerick facility not be permitted to operate.
Since your letter is based upon the issues raised in Mr. Anthony's petition, it will be treated as a supplement to that petition.
Accordingly, the information raised in your letter will be taken into consideration in the final decision I will issue on Mr. Anthony's petition.
Sincerely, Originst signed hf H. R. Denten Harold R. Denton, Director Office of Nuclear Reactor Regulation cc: Mark Wetterhahn, Esq.
and Service List
- See previous concurrence concurred on by:
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