ML20198Q870
| ML20198Q870 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 11/06/1997 |
| From: | Anderson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Danni Smith PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| Shared Package | |
| ML20198Q873 | List: |
| References | |
| 50-352-97-06, 50-352-97-6, 50-353-97-06, 50-353-97-6, NUDOCS 9711130070 | |
| Download: ML20198Q870 (2) | |
See also: IR 05000352/1997006
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November 6, 1997
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Mr. D. M. Smith, 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:
INSPECTION REPORT NOS. 50-352/97-06 AND 50 353/97-06 - REPLY
Dear Mr. Smith:
This letter refers to your September 12, 1997, correspondence, in response tc, our
August 13,1997, letter.
Thank you for informing us of the corrective 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 -
Project Branch No. 4
Division of Reactor Projects
. Docket Nos. 50-352;50-353
cc:
G. A. Hunger, Jr., Chairman, Nuclear Review Board and Director - Licensing
W. MacFarland, Vice President - Limerick Generating Station
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. J. L Kantner, Manager, Experience Assessment
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Secretary, Nuclear Committee of the Board
Comm'onwealth of Pennsylvania
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Mr. D. M. Smith
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Distribution:
Region 1 Docket Room (with concurrences)
W. Axelson, DRA
P. Swetland, DRP
A. Linde, DRP
NRC Resident inspector
Nuclear Safety information Center (NSIC)
PUBLIC
W. Dean, OEDO
F. Rinaldi, NRR
inspection Program Branch, NRR (IPAS)
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R. Correla, NRR
F. Talbot, NRR
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19464 4920
Fan 610 718 3008
Pagw 1800 672 2285 #8320
September 12,1997
Docket Nos. 50-352
50-353
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License Nos. NPF-39
NPF-85
Director, Office of Enforcement
U.S. Nuclear Regulatory Commission
Attn.: Document Control Desk
Washington, DC 20555
SilBJECT:
Limerick Generating Station, Units 1 and_2
Response to An Apparent Violation in Inspection Report Nos. 50-
352,353/97-06
Attached is PECO Energy Company's response to the apparent violation for
Limerick Genercting Station (LGS), Units 1 and 2, that was contained in your
lette ' dated August 13,1997. The apparent violation concerns the failure to
ensu e that certain equipment required to assure fire safe chutdown capability
was adequately pre-staged for use in the event of a fire. Tht, reasons for the
apparent violation, the corrective actions taken, and the corrective actions to
avoid future noncompliance are described in LGS Licensee Event Report (LER)
1-96-015; NRC Integrated Inspection Repon Nos.: (1) 50-352/96-06 and 50-
353/96-06, (2) 50-352/97-01 and 50-353/97-01, and (3) 50-352/37-06 and 50-
353/97-06; and the attached response.
A discussion of the identification, prompt and comprehensive corrective actions,
and safety significance of the apparent violations is provided below,
All of the issues identified were the result of non-willful errors.
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Dodet Nos. 50-352 and 50-353
September 12,1997
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identification
The issbes were self identified by the Nuclear Engineering Division (NED) Fire
- Safe Shutdown (F880) Progrram Manager while performing an inventory of all of
the emergency lighting required to support safe shutdown of LG8 in the event of
a fire. This inventory was conducted as part of a voluntary design reconsthution/-
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verification effort that was part of an overall Thermo-Lag reduction project, and
was intended to verify the existing plant design prior to s ecommending changes
for Thermo-Lag reduction. This review required an in depth knowledge of the
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LG8 FSSD design, including the potential for dual-unit shutdown, and previously
analyzed inter-unit dependencies credited in the fire scenario, The identified
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. issues were appropriately reported to the NRC in LGS LER 1-g6-015,
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Ggrrective Actions
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Corrective actions were prompt and thorough as described in the previously-
docketed correspondence described above and the attached response.
Safety SignifiGADGE
- If a fire had occurred, the operators carry hand-held radios and portable _ lights
were available for use in the plant. One of the two required jumper cables was
pr&-staged und could have been used on either unit as needed until a second
jumper could be fabricated. The jumper cable la only needed to transition to cold --
shutdown, and is not required to achieve hot shutdown. The materials
necessary to make the second jumper were available at the site, in the absence
of specific procedural guidance and training to activate the Emergency Fire
Dispatch Center (EFDC) in a fire scenario, operations staff would have mustered _.
at the Operations Support Center (OSC) in a fire event.t Sensitivity studies were
performed which concluded that the increased travel time to and from the OSC -
- would not adversely impact the capability to perform the required manual actions
in a postulated fire scenario.
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Docket Nos, 50-352 and 50-353
September 12,1997
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Page 3
The emergency response capability, including the use of the Emergency
Operating procedures and the Emergency Plan procedures, would have
provided thfe operators a success path to safely shutdown the plant in the event
a fire had occurred. Therefore, the missing equipment would have had minimal
impact on the plant's ability to reach the cold shutdown condition in the event of
a fire.
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If you have any questions or require additional information, please contact us,
Very truly yours,
Wk
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Attachment
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cc:
H. J. Miller, Administrator, Region I, USNRC
w/ attachment
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N S, Perr), USNRC Senior Resident inspector, LGS
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- COMMONWEALTH OF PENNSYLVANIA :
COUNTY OF MONTCOMERY
W. G. MacFarland, being first duly swom, desposes and says:
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- That he is Vice President of PECO Energy Company; that he has read the
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attached Response to an Apparent Violation for Limerick Generating Station,
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Units 1 and 2, and knows the contents thereof; and that the statements and
matters set forth therein are true and correct to the best of his knowledge,
information and belief.
b)
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Vice President
Subscribed and sworn to
before me this 4" day
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1997.
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Attachment
Docket Nos. 50-352 and 50-353
September 12,1997 :
Page 1 of 4
Reasonae to An Annarent Violation
Restatement of the Accarent Violation
On July 26,1996, a walkdown of specific equipment installed at Limerick Generating
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Station (LGS) to mitigate design basis fire events was performed by the Nuclear
Engineering Division (NED) Fire Safe Shutdown (FSSD) Program Manager (PM), along
with station Fire Protection personnel. This walkdown identified several deficiencies in
the implementation of the Fire Safe Shutdown Program as described below.
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1. A 150 foot electrical jumper cable was missing from the Unit 2 static invoiter room.
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This jumper cable would be used to provide an altomate electrical power source to
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re-energize the controls for the automatic depressurizati6n system valves for
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depressurization control for the reactor during shutdown following a fire in the
. Remote Shutdown Panel room. The use of this jumper is a repair necessary to
support the transition from Hot Shutdown to Cold Shutdown.
- 2. Emergency lighting was missing in a rreom which required post-fire activities to be '
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performed. In January 1995, revisions were nede to Special Event (SE) .
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procedures SE-8-2 and SE-8-4 related to fire safe shutdown to provide simpler -
pathways for operators to install the electrical jumper cable described above.
However, the new pathways (the Unit 2 static inverter room and the acc Ass stairway -
immediately outside the room) were found not to be illuminated by 8-hour
3. Communications equipment'(microphone) that was to be pre-staged at the
- Emergency Fire Dispatch Center (EFOC) was missing. The EFDC is a muster
location provided to coordinate non-control room operator actions in the event of a
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- firei The EFDC is provided with a " hardened" radio system, designed to maintain
radio contact with the Main Control Room and the Remote Shutdown Panel for 72
. hours _following a fre. Prior to March 1995, this facility also served as the
- Operations Support Center (OSC) in the LGS Emergency Plan.' At that time, a
modification relocated the OSC and required the EFDC to be maintained in the old
- OSC Iccation; This modification retained the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> radio communication
capaollity in the EFDC, although the appropriate microphone was missing. In
addition, administrative actions necessary to maintain the rsquired equipment for
the EFDC were not implemented, procedure revisions necessary to use the EFDC
in a fire event were not performed, and subsequent operator training was not
provioed.
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Attachment
Oocket Nos. 50-352 and 50-353
September 12,1997
Page 2 of 4
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The failure to maintain this equipment was determined to be a violation of LG8 Facility
Operating License Condition 2.C.(3), which requires implememting and maintaining in
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offect all provisions' of tha approved Fire Protection Program as described in the
. Updated Final Saf9ty Analysis Report (UFSAR),
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Reasons for the Acc&ent Violation
These deficiencies, although identified at the same time, were the result of several
different causes, some dating from original Unit 2 start-up (jumper cable & lighting), and
the other from a recent modification. A common cause of the described conditions was
a lack of clear ownership and accountability for the contents and technical accuracy of
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the fire safe shutdown procedures. Personnel knowledgeable in the details of the fire
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safe shutdown analysis were not sufficiently involved in the changes that resulted in the
deficiencies. Specifics are described below.
' The cause of the missing second cable was inadequate procedures. Prior to the start-
up of Unit 2, an engineering review of the operator actions needed for safe shutdown
was performed and procedure revisions were implemented. However, due to the lack
of clarity in SE-8-2 and SE-8-4, station personnel did not recognize that two (2) cables
- may be necessary to perform a dual unit shutdown in the event of a firc in the Remote
Shutdown Panel room. '
The cause of the lack of specific battery powered lighting units for the revised pathway
was personnel error. There ws" ' , inadequate review of the proposed revision to the
SE procedures. The reviewr
.d riot take into account the lighting requirements
- when establishing the revisw.. ,Jmper cable pathway. -
< The cause for the failure to proceduralize the operation and maintenance of the EFDC
during relocation of the OSC was personnel error.- The members of the modification
team responsible for the OSC relocation recognized the need to establish the EFDC
- and requirements were included in the modification documents. However, the actions
to proceduralize the implementation of the EFDC were not assigned for action and not
pursued.
c A contributing factor to the above discrepancies was an inadequate periodic inventory
procedure. - Pre-staged equipment for support of fire safe shutdown is routinely verified
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- y a periodic inventory procedure.1 However, the procedure failed to includ1 these
- components for verification.
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Attachment
Docket Nos. 50-352 and 50-353
September 12,1997
Page 3 of 4
Corrective Actions Taken and Resu!ts Achieved
The following immediate corrective actions were implemented.-
An engineering review of the fire safe shutdown analysis was performed to
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. determine thr, equipment and procedures required to be available in the EFDC.
A second 100 foot electrical jumper cable was fabricated and located in the Unit
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2 static inverter room.
Procedures SE-8-2 and SE-8-4 were revised to clearly indicate the use of two-
(2) jumper cables.
Procedures' SE-8 and SE-12 were revised to direct use of the EFDC in a fire
event,
The radio microphone was replaced and copies of the necessary SE procedures -
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were securely installed in the EFDC.
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Signt were posted on the door to the EFDC to identify the facility and on the
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locked cabinet inside the EFDC containing the radio microphone. =
. It was verified that the operators carry hand-held radios and have access to high
intensity portable lights (staged at several locations throughout the plant),
interim guidance was provided to Operations personnel via a Shift Night Order--
-(SNO) entry reinforcing the expectation that'all operators carry hand-held radios
!and high intensity portable lights in a fire event. The SNO entry was read at tiie
shift turnover rceetings.-
A Non-Conformance Report (NCR) was generated to determine the permanent
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corrective actions for providing battery powered lights for the jumper cable
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pathway and for recommending if additional permanent equipment for the EFDC
is required.
-The following additional corrective actions have been completed,
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e : Emergency Response Procedure ERP-230 has been revised to instruct the
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activation of the EFDC in the event of a fire.
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Attachment
Docket Nos. 50-352 and 50-353
September 12,1997-
Page 4 of 4
As a result of the NCR, all emergency lighting required to support Unit 1 and
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Unit 2 safe shutdown has been verified as being installed and properly
surveillsJ. A design document has been developed which tabulates the
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location, function, and basis for all of the 8-hour emergency lights installed for
FSSD.-
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Equipment nosdod to_ implement all of the FSSD procedures has been
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-inventoried and verified to be complete. The FSSD semiannual Inventory
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surveillance procedure har been revised to ensure that all equipment required to
support the FSSD procedures is properly maintained.
Modification team members associated with the OSC relocation have been
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counseled.
Conective Actions to Avoid Future Noncomollance ,
The Operations Suport Branch has been assigned the overall responsibility for
managing the content and technical accuracy of all of the Special Event procedures
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- including the Fire Safe Shutdown procedures. An individual knowledgeable in the '
details of the LGS fire safe shutdown analysis will be involved in reviewing proposed .
changes when appropriate.:
Extensive changes in the modification process have been implemented since the
development of the OSC relocation modification. These changes are considered
- sufficient to address the modification process aspects of the deficient modification.
Date When Full Comoniance was Achieved
Full compliance va achieved on July 26, %96, when the immediate corrective actions
described above were implemented. These immediate corrective actions re-
- established the minimum operator capability and knowledge necessary to correct the
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