ML20151X242

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-352/98-04 & 50-353/98-04 on 980805

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

Text

, . - . . . . . - ~ . . - - . . . . . . - - . . ... . - - - . . . - . _ - _ . . . - - . - . . - . - . . . . - . - . . .

I%, UNITED STATES

$d, [ g NUCLEAR REGULATORY COMMISSION

-

5 ij REGloN 1

0 4 475 ALLENDALE ROAD

Yg ,o D KING oF PRUSSIA, PENNSYLVANIA 19406-1415

-

.....

September 11, 1998 l

l

Mr. G. Rainey, President

PECO Nuclear

Nuclear Group Headquarters i

Correspondence Control Desk

P. O. Box 195 i

Wayne, PA 19087-0195

SUBJECT: NRC INTEGRATED INSPECTION REPORT NOS. 50-352/98-04

AND 50-353/98-04

Dear Mr. Rainey:

1

This refers to your September 4,1998 correspondences, in response to our 1

August 5,1998 letter. '

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.

1

Sincerely, l

'f

\

]

ip j L4y w

o

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 l

Secretary, Nuclear Committee of the Board )

Commonwealth of Pennsylvania

cc: w/o copy of Licensee's Response Ltr: '

G. Edwards, Chairman, Nuclear Review Board and Director - Licensing

J. VonSuskil, Vice President - Limerick Generating Station

l

I

6p)

4'

9909160325 900911 '

1

PDR ADOCK 05000352 .

i

G PDR F

l

,

_ _ .. .._ .. _.. _ . . . . . . _ - . . _ . _ _ _ . . _ _ _ _ . _ . _ . _ - . _ . -

1

,V'

2

i

Mr. G. Rainey

Di-stribution w/ copy of Licensee's Response Ltr:

Region i Docket Room (with concurrences)

8. McCabe, OEDO

R. Capra, PDI 2, NRR

B. Buckley, PD 1-2, NRR

. M. Thadani, PD 1-2, NRR

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

Inspection Program Branch, NRR (IPAS) '

DOCDESK

l

l

,

i

!

l

l ,.

!

l

e

l

t

l

..- - - . . . . . . - - . = _ . . . - - -..- .-. -.... - .-. - _ - . _ . - -

'

. Michael P.(!tliagher, P.E.  ;

• 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

10 CFR 2.201

September 4,1998

i

Docket Nos. 50-352 i

'

50-353

License Nos. NPF-39

-

NPF-85

U.S. Nuclear Regulatory Commission

Attn.: Document Control Desk

Washington, DC 20555  !

SUBJECT: Limerick Generating Station, Units 1 and 2

Reply to a Notice of Violation ,

NRC Inspection Report 50-352/98-04 and 50-353/98-04 l

Attached is PECO Nuclear's reply to a Notice of Violation for Limerick Generating Station I

(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

'

containment isolation signal, and (2) the failure to report a condition prohibited by Technical l

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.  ;

1

If you have any questions or require additionalinformation, please contact us.

Very truly yours,

, ,G

^ W /

'

Enclosure

Attachments

a

cc: H. J. Miller,' Administrator, Region I, USNRC w/ attachments

"

A. L. Burritt, USNRC Senior Resident inspector, LGS

!

.

.

w

.

Attachment

Docket Nos. 50-352 and 50-353

September 4,1998 '

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).

_ _

-_- - - . - - _ . . - . - . . - - - _ _ _ _ - _ ~ - .

_

-. - - - - - -

4

Attichment

Docket Nos. 50-352 and 50-353

,( September 4,1998

Page 2 of 4

Reply to Violation A

j

l

.Mrgission of the Violation

PECO Energy acknowledges the violation.

l

Reasons for the Violations

!

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.

I The surveillance testing deficiency can be traced to initial test development and was caused

j by personnel error related to less than adequate (LTA) review of the PCIV and other similar

! 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

l

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

!

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

l

l 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

l logic configuration that could impact the operability of their associated systems were

satisfactorily tested.

,

i

--.

o

Attachm:nt

Docket Nos. 50-352 and 50-353

September 4,1998

l

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

i generic reviews.

l

.

1

1

1

. _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

. .. .- . .- . . - . - . . . . - - . . . . . . . - -. . .. . - . . - -

. .

6-

'

Attachmtnt

Docket Nos,50 352 and 50-353

( September 4,1998

Page 4 of 4 s

-

Date When Full Compliance was Achieved

f

Full compliance was achieved on July 20,1998, when LER 197-013, Rev.1, was submitted to

report the condition prohibited by Technical Specifications.

l

!

r

h

i

!

,

T

.

!

!

.