ML20197C172

Responds to NRC Re Violations Noted in Insp Repts 50-352/98-04 & 50-353/98-04.Corrective Actions:Extensive Document Reviews & in-plant Wiring Insps Were Performed, Affected PCIV Population Was Identified & Testing Completed

ML20197C172
Person / Time
Site:	Limerick
Issue date:	09/04/1998
From:	Gallaghar M, Gallagher M PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-352-98-04, 50-352-98-4, 50-353-98-04, 50-353-98-4, NUDOCS 9809100069
Download: ML20197C172 (5)

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Michael P. Gilichrr, P.E.

. Plant Manager Limerick Generating station ,

PECO NUCLEAR escoe" <9vco-oe"v Limenck Generating station

. A Unit of PECO Energy

{ng,,3y19464-0920 p

610 718 2000 10 CFR 2.201 September 4,1998 Docket Nos. 50-352 50-353 License Nos. NPF-39 NPF-85 U.S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, DC 20555 l

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  ;

i Attached is PECO Nuclear's reply to a Notice of Violation for Limerick Generating Station l (LGS), Units 1 and 2, that was contained in your letter dated August 5,1998. The Notice j identified two violations concerning: (1) the failure to adequately test primary containment 1 l

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 Specifications when it was discovered, during a generic review of the condition identified above, that other safety-related valves with similar logic circuits also were not adequately tested. The attachment to this letter provides a restatement of the violations followed by our reply.

If you have any questions or reqti a additional information, please contact us.

Very truly yours, Enclosure Attachments cc: H. J. Miller, Administrator, Region I, USNRC w/ attachments A. L. Burritt, USNRC Senior Resident inspector, LGS  !

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9809100069 990904 PDR ADOCK 05000352 G PDR 090083

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Attachm:nt Dock:t Nos. 50-352 and 50-353 l 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 l Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below.

l 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 i 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

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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 1).

B. 10 CFR 50.73 (a) requires the holder of an operating license for a nuclear power plant (licensee) shall submit a Licensee Event Report (LER) for any 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: (l)(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 I condition prohibited by the plant's Technical Specifications within 30 days after the l discovery of the event. Specifically, on February 2,1998, the licensee identified 20 safety relaied 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 Severity Level IV violation (Supplement 1).

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, 1 Attachm:nt Dock 2t Nos. 50-352 cnd 50-353 September 4,1998 Page 2 of 4 Repiv to Violation A Admission of the Violation PECO Energy acknowledges the violation.

Reasons for the Violations j The reason for the violation, as stated in Licensee Event Report 1-97-013, Rev.1, for Limerick l Generating Station (LGS), Units 1 and 2, is described below.

The surveillance testing deficiency can be traced to initial test development and was caused 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 l 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. I Corrective Actions Taken and Results Achieved ,

I The corrective actions taken, as stated in Licensee Event Report 1-97-013, Rev.1, are l described below. )

l Extensive document reviews and in-plant wiring inspections were performed, the affected PCIV l population was identified, and testing of affected valves was completed.  :

1 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 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 prior 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 logic configuration that could impact the operability of their associated systems were satisfactorily tested.

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i Attachm

nt Docktt Nos. 50-352 and 50-353 September 4,1998 Page 3 of 4 Reply to Violation B

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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 5ection (EAS) personnel maintained an informal work practice of assigning an internal action, through the PEP issue associated with the identified condition, to reevaluate the additionai 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 reportability.

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 generic reviews.

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Attichmtnt  :

Dock t Nos. 50-352 and 50-353 September 4,1998  ;

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Date When Full Compliance was Achieved 1

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Full compliance was achieved on July 20,1998, when LER 1-97-013, Rev.1, was submitted to '

report the condition prohibited by Technical Specifications.

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