ML20151X242
| ML20151X242 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 09/11/1998 |
| From: | Anderson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Rainey G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| 50-352-98-04, 50-352-98-4, 50-353-98-04, 50-353-98-4, NUDOCS 9809160325 | |
| Download: ML20151X242 (2) | |
See also: IR 05000352/1998004
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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KING oF PRUSSIA, PENNSYLVANIA 19406-1415
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September 11, 1998
Mr. G. Rainey, President
PECO Nuclear
Nuclear Group Headquarters
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Correspondence Control Desk
P. O. Box 195
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Wayne, PA 19087-0195
SUBJECT:
NRC INTEGRATED INSPECTION REPORT NOS. 50-352/98-04
AND 50-353/98-04
Dear Mr. Rainey:
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This refers to your September 4,1998 correspondences, in response to our
August 5,1998 letter.
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Thank you for informing us of the forrective and preventive actions documented in your
letter. These actions will be examined during a future inspection of your licensed program.
Your cooperation with us is appreciated.
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Sincerely,
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Clifford J. Anderson, Chief
Projects Branch 4
Division of Reactor Projects
Docket Nos. 50-352;50-353
cc w/ copy of Licensee's Response Ltr:
T. Moore, Manager, Experience Assessment
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Secretary, Nuclear Committee of the Board
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Commonwealth of Pennsylvania
cc: w/o copy of Licensee's Response Ltr:
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G. Edwards, Chairman, Nuclear Review Board and Director - Licensing
J. VonSuskil, Vice President - Limerick Generating Station
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9909160325 900911
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ADOCK 05000352
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Mr. G. Rainey
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Di-stribution w/ copy of Licensee's Response Ltr:
Region i Docket Room (with concurrences)
8. McCabe, OEDO
R. Correia, NRR
F. Talbot, NRR
C. Anderson, DRP
D. Florek, DRP
P. Bonnett, DRP
M. Campion, ORA
R. Junod, DRP
NRC Resident inspector
Nuclear Safety 'nformation Center (NSIC)
PUBLIC
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Inspection Program Branch, NRR (IPAS) '
DOCDESK
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Michael P.(!tliagher, P.E.
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Plant Manager
L:menca Generating Station
PECO NUCLEAR
Peco one.ov comoe -
Limenck Generating Station
A Unit of PECO Energy
Po Box 2300
sanatoga. PA 19464 0920
610 718 2000
September 4,1998
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Docket Nos. 50-352
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50-353
License Nos. NPF-39
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U.S. Nuclear Regulatory Commission
Attn.: Document Control Desk
Washington, DC 20555
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SUBJECT:
Limerick Generating Station, Units 1 and 2
Reply to a Notice of Violation
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NRC Inspection Report 50-352/98-04 and 50-353/98-04
Attached is PECO Nuclear's reply to a Notice of Violation for Limerick Generating Station
(LGS), Units 1 and 2, that was contained in your letter dated August 5,1998. The Notice
identified two violations concerning: (1) the failure to adequately test primary containment
isolation valve (PCIV) logic circuits to verify each valve isolated to its isolation position on a
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containment isolation signal, and (2) the failure to report a condition prohibited by Technical
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Specifications when it was discovered, during a generic review of the condition identified above,
that other e dety-related valves with similar logic circuits also were not adequately tested. The
attachment .c this letter provides a restatement of the violations followed by our reply.
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If you have any questions or require additionalinformation, please contact us.
Very truly yours,
,G
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Enclosure
Attachments
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cc:
H. J. Miller,' Administrator, Region I, USNRC
w/ attachments
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A. L. Burritt, USNRC Senior Resident inspector, LGS
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Attachment
Docket Nos. 50-352 and 50-353
September 4,1998
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Page 1 of 4
REPLY TO A NOTICE OF VIOLATION
Restatement of the Violations
During an NRC inspection conducted between May 19,1998, through July 6,1998, violations of
NRC requirements were identified. In accordance with the " General Statement of Policy and
Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:
A.
Technical Specification 4.6.3.2 requires, in part, that each primary containment isolation
valve (PCIV) shall be demonstrated operable at least once per 24 months by verifying
that on a containment isolation test signal each automatic isolation valve isolates to its
isolation position.
Contrary to the above, since initial plant operation, testing conducted at least once per
24 months to demonstrate the operability of 89 PCIVs, at both units combined, was
inadequate, in that, the testing did not verify that each valve isolated to its isolation
position on a containment isolation test signal. Specifically, when these valves were
tested, the methodology used did not confirm that the valves would close fully, with the
thermal overload protection bypassed, thereby creating the potential for leakage past
the valve.
This is a Severity Level IV violation (Supplement I).
B.
10 CFR 50.73 (a) requires the holder of an operating license for a nuclear power plant
(licencee) shall submit a Licensee Event Report (LER) for cny event of the type
described in this paragraph within 30 days after the discovery of the event.
10 CFR 50.73 (a)(2) requires the licensee shall report: (I)(B) any operation or condition
prohibited by the plant s Technical Specifications.
Contrary to the above, as of March 4,1998, the licensee had not submitted an LER for a
condition prohibited by the plant's Technical Specifications within 30 days after the
discovery of the event. Specifically, on February 2,1998, the licensee identified 20
safety related valves that had not been adequately tested in accordance with Technical Specifications 4.6.3.2 and this was not reported in an LER.
This is a Seventy Level IV violation (Supplement I).
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Attichment
Docket Nos. 50-352 and 50-353
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September 4,1998
Page 2 of 4
Reply to Violation A
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.Mrgission of the Violation
PECO Energy acknowledges the violation.
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Reasons for the Violations
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The reason for the violation, as stated in Licensee Event Report 1-97-013, Rev.1, for Limerick
Generating Station (LGS), Units 1 and 2, is described below.
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The surveillance testing deficiency can be traced to initial test development and was caused
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by personnel error related to less than adequate (LTA) review of the PCIV and other similar
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valve logic diagrams and LTA recognition of the scope of testing. The initial surveillance
test development failed to adequately verify whether data provided on the logic diagrams
were absolute or nominal values. This resulted in the failure to determine the appropriate
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logic path required to be tested for closing the PCIVs and other similar valves.
Corrective Actions Taken and Results Achieved
The corrective actions taken, as stated in Licensee Event Report 1-97-013. Rev.1. are
described below.
Extensive document reviews and in-plant wiring inspections were performed, the affected PCIV
population was identified, and testing of affected valves was completed.
Corrective Actions to Avoid Future Noncompliance
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The planned corrective actions stated in Licensee Event Report 1-97-013, Rev.1. are
expanded upon below.
A Design Change Request (DCR) has been posted against each affected drawing to identify
the drawing inaccuracy to potential users.
A detailed review of the control room emergency fresh air supply (CREFAS) system drawings
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was performed to ensure the logic system testing satisfies applicable requirements. No
deficiencies were identified and no further reviews are planned.
The applicable surveillance tests will be permanently revised to include the previously untested
closing contact. These revisions will be completed pnor to the next scheduled performance.
Date When Full Compliance was Achieved
Full compliance was achieved by February 2.1998, when all safety-related valves with a similar
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logic configuration that could impact the operability of their associated systems were
satisfactorily tested.
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Attachm:nt
Docket Nos. 50-352 and 50-353
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September 4,1998
Page 3 of 4
Reply to Violation B
Admission of the Violation
PECO Energy acknowledges the violation.
Reasons for the Violation
The cause of this violation is that there is no administrative control to ensure that reporting
requirements are reconsidered when generic implications reviews identify similar or additional
concerns. Procedure LR-C-10," Performance Enhancement Program (PEP)," establishes the
requirements for identification, analysis, and correction of significant conditions adverse to
quality. This procedure also provides the administrative control for making reportability
determinations regarding identified conditions. When similar or additional concerns were
anticipated to result from the planned corrective actions taken in response to an identified
condition, the station Experience Assessment Section (EAS) personnel maintained an informal
work practice of assigning an internal action, through the PEP issue associated with the
identified condition, to reevaluate the additional concerns for reportability. However, this
practice was not institutionalized in procedure LR-C-10. In the particular case described in LER
1-97-013, Rev. O, for LGS, Units 1 and 2, the PEP issue was not perceived to have any
potential for additional concerns. Therefore, no evaluation was created at that time to perform
a re-review for reponability.
Also, expectations about getting EAS personnel involved, as appropriate, based on the results
of subsequent generic implications reviews, were not clearly communicated to station
personnel.
Corrective Actions Taken and Results Achieved
On an interim basis pending procedure revision, all site personnel responsible for final
reportability determinations were instructed that an internal action is to be created for each
reportable PEP to revisit findings from generic implication reviews to ensure that additional
reportability requirements are identified and addressed.
All PEP investigation review leaders were informed of the expectation that the EAS be involved
for a reportability determination when concerns beyond the scope of the original condition are
identified as part of ongoing generic implication reviews.
Corrective Actions to Avoid Future Noncompliance
Procedure LR-C-10 was revised to ensure a reportability determination is performed when
additional concerns beyond the scope of the original condition are identified as part of ongoing
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generic reviews.
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Attachmtnt
Docket Nos,50 352 and 50-353
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September 4,1998
Page 4 of 4
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Date When Full Compliance was Achieved
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Full compliance was achieved on July 20,1998, when LER 197-013, Rev.1, was submitted to
report the condition prohibited by Technical Specifications.
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