ML20153D059
| ML20153D059 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 09/18/1998 |
| From: | Gallagher M PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-352-98-06, 50-352-98-6, 50-353-98-06, 50-353-98-6, NUDOCS 9809240291 | |
| Download: ML20153D059 (5) | |
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Michael P. Gallagher, P.E.
Plant Manager Lirnerick Generating station
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PECO NUCLEAR reco eme<cvco-a "v Umerick Generating Station A (Jnit of PECO Energy yy3y19464 os20 P
610 718 2000 10 CFR 2.201 September 18,1998 Docket Nos. 50 352 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 50-352/98-06 and 50-353/98-06 Attached is PECO Nuclear's reply to a Notice of Violation for Limerick Generating Station (LGS)
Unit 1, that was contained in your letter dated August 26,1998. The Notice identified one violation, with two examples, where performance measures for certain structures, systems, and components were not adequately established. The attachment to this letter provides a restatement of the violations followed by our reply.
If you have any questions or require additional information, please contact us.
Very truly yours, Enclosure Attachments
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cc:
H. J. Miller, Administrator, Region I, USNRC w/ attachments A. L. Burritt, USNRC Senior Resident Inspector, LGS
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f 9909240291 930918 I gDR ADOCK 05000352E PDR Q
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Dock:t Nos. 50-352 cnd 50-353 Sept:mber.18,1998 Page 2 -
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G: R. Rainey - CB, 63C-3 w/ attachments J. D von Suskil-SMB1-1 l-R. W. Boyce - CB, 63C-3 l
M. P. Gallagher - GML5-1 l
J. P. Grimes - SSB3-1 l
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- G. D. Edwards-CB, 62A-1
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' J. E. Cohen - SSB4-3 T. A. Moore - SSB2-4 LGS ISEG - SSB4-2 NRB Chairman CB,62A-1 Secretary, NCB - CB,62A-1 (11 copies)
PA DEP BRP inspector - SSB2-4 OEAP Coordinator - CB,62A-1
- Correspondence Release Point - SMB1-2 DAC - SMB1-2 I
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Attachmsnt Docket Nos. 50-352 and 50-353 September 18,1998 Page 1 of 3 REPLY TO A NOTICE OF VIOLATION Restatement of the Violations l
During an NRC inspection conducted from July 6 through 10,1998, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and i
l Procedures for NRC Enforcement Actions," NUREG 1600, Revision 1, the violation is l
delineated below:
l 10 CFR 50.65(a)(1) requires, in part, that holders of an operating license shall monitor the performance or condition of structures, systems and components (SSCs),within the scope of the monitoring program, as defined by 10 CFR 50.65(b), against licensee established goals, in a manner sufficient to provide reasonable assurance that such SSCs are capable of fulfilling their intended functions. Such goals shall be established commensurate with safety and, where practical, take into account industry-wide operating experience. When the performance or condition of a SSC does not meet established goals, appropriate corrective action shall be taken.
l 10 CFR 50.65(a)(2), requires, in part, that the monitoring as specified in 10 CFR 50.65(a)(1) is not required where it has been demonstrated that the performance or condition of s SSC is being effectively controlled by performing appropriate preventive maintenance, such that the SSC remains capable of performing its intended function.
I Contrary to 10 CFR 50.65(a)(2), as of July 10,1996, (the time that the licensee elected l
to not monitor the performance or condition of the Safety Relief Valves and the Spent Fuel Pool Cooling system against licensee established goals pursuant to the requirements of 10 CFR 50.65 (a)(1)) the licensee failed to demonstrate that the performance or condition of these systems, within the scope of 10 CFR 50.65, had been effectively controlled through the performance of appropriate preventive maintenance in j
accordance with the requirements of 10 CFR 50.65(a)(2). Specifically, the licensee failed to adequately evaluate the appropriateness of the performance of preventive l
maintenance on these SSCs prior to placing SSCs under Paragraph (a)(2). The licensee failed to establish adequate performance measures for the SSCs and was therefore unable to effectively demonstrate that the SSCs remained capable of performing their intended function as listed below.
Safety Relief Valves (SRV)-Reliability performance measures, in part, were no failures of any grouping of SRVs to lift before the ASME code safety limit for maximum reactor coolant system pressure. This measure would allow multiple l
SRVs to exceed their technical specification set point limits and thus would not ensure that the SRVs remain capable of performing their intended function.
l Spent fuel pool cooling system -Reliability performance measure was no more than two system failures within a two year operating cycle that would result in a loss of spent fuel cooling. This measure allowed repetitive failures of individual operating and standby trains without placing the system in an (a)(1) status.
Specifically, as of July 10,1996 using this measure, the system was placed in the (a)(2) category despite two complete system failures and multiple individual train failures.
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I* Attachment l
Dockrt Nos. 50-352 and 50-353 l
September 18,1998 Page 2 of 3 This is a severity level IV violation, NUREG-1600, Revision 1, Supplement i Admission of the Violati_qn PECO Energy acknowledges the violation.
Reasons for the Violations Both examples cited in the violation were caused by the selected performance criteria being inadequate in that it could have allowed the system to degrade to a point where it would be incapable of fulfilling its intended function. This situation resulted from interpretation of performcnce monitoring guidance contained in NUMARC 93-01.
The reason for example (1) was the bases of the performance indicator which stated that the failure of any groupings of SRVs to lift which challenges or exceeds the safety limit for maximum Reactor Coolant System Pressure. This definition of functional failure l
for the SRVs was developed to indicate furth9r degradation of the SRV performance.
The SRV setpoint drift issue has been an industry issue since 1985. Actions have been taken and plans are in place to resolve this industry issue. Based on the historical l
performance of the SRVs, setting the Maintenance Rule performance indicator at a component level similar to the Technical Specification requirement would not have i
provided any new information and would not have indicated when further degradation had occurred. Therefore, the performance indicator was set as stated above.
The reason for example (2) was that the Fuel Pool Cooling system was scoped into the Maintenance Rule for being used in the EOP's. The system is not risk significant and is normally in service. Since there are multiple trains in this system which can all be cross-l configured, train level monitoring did not seem appropriate. The entry condition for the associated EOP seemed to be an appropriate performance indicator since this was the bases for the system being scoped into the rule. Corrective actions had been taken for the past pump motor failures. Based on the selected performance indicator and the current performance of the system, the system was not classified as (a)(1).
Corrective Actions Taken and Results Achieved Completed corrective actions for example (1) are described below. The performance indicator for "SRV - Component MPFFs" has been changed to only address the inadvertent lift of a single SRV. A new performance indicator for "SRV - Component FFs" has been added. Within this performance indicator, a functional failure is defined as the failure of a single SRV to lift within +/- 1% of its setpoint. The performance criteria has been set at 3 FFs/24 months to be consistent with Technical Specifications.
Completed corrective actions for example (2) are described below. The Fuel Pool Cooling system performance indicator of ON-125 Entries remains as a system level indicator; however, two new performance indicators have been added to monitor at a lower level so as not to mask equipment failures. The new performance indicators are
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- * ' [ ' Attachment Dockst Nos. 50-352 and 50-353 September 18,1998 Page 3 of 3 l
" Pump MPFFs" and " Heat Exchanger MPFFs". Based on historical data and procedural l
guidance, the performance criteria for these indicators has been set at 2 MPFF's/24 l
months and 1 MPFF/ 24 months, respectively.
Corrective Actions to Avoid Future Noncomollanga All non-risk significant SSCs within the Maintenance Rule scope were reviewed to determine if any other SSC's are currently being monitored at a level where possible masking could occur or the system could degrade to a point where it would be incapable of fulfilling its intended function. Twenty-three (23) SSCs were identified as having system or plant level monitoring where possible masking could occur. These SSC's are being evaluated to determine the appropriato level of monitoring necessary to ensure that masking of failures does not occur, Date When Full Compliance was Achieved The new performance indicator for "SRV - Component FFs" was approved for SSC 41 A by the Expert Panel on September 17,1998. Within this performance indicator, a functional failure is defined as the failure of a single SRV to lift within +/- 1% of its setpoint. The performance criteria was approved at 3 FFs/24 months to be consistent with Technical Specifications.
The new performance indicators for " Pump MPFFs" and " Heat Exchanger MPFFs" were approved by the Expert Panel on September 17,1998. Based on historical data and procedural guidance, the performance criteria for these indicators was approved as 2 MPFF's/24 months and 1 MPFF/ 24 months, respectively.
The additional twenty-three (23) SSC's which may require revision will be evaluated.
For those determined to require revision, the performance indicators and criteria will be i
established and approved by the expert panel by December 21,1998.
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