ML20203G911

Notice of Violation from Insp on 971118-980119.Violation Noted:On 971206,required Narrative Log Entries in Unified Log for Safety Sys Inoperability Were Not Made

ML20203G911
Person / Time
Site:	Limerick
Issue date:	02/23/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20203G899	List: ML20203G894 ML20203G911 ML20203G921
References
50-352-97-10, 50-353-97-10, NUDOCS 9803030105
Download: ML20203G911 (3)

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, ENCLOSURE 1 NOTICE OF VIOLATION PECO Energy Docket Nos. 50-352;50-353 Limerick Generating Station License Nos. NPF-39; NPF-85 Ur.;t 1 and 2 During an NRC insper tion conducted on November 18,1997, through January 19,1998, 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. Units 1 and 2 Technical Specification (TS) 6.8.1 requires, in part, that written procedures snall be implemented covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33 recommends Administrative Procedures for Log Entries as activities that should be covered by written procedures. Operations Manual sections OM-L 8.2, Narrative Logs / Scope of Entry, written to comply with TS 6.8.1, requires in part, that items are to be entered into the log pertaining to system operability or affecting the station. Also, OM-L 12.1, Regulatory Action, step 4.4, requires a narrative log entry in the unifiv log for the safety system inoperability.

Contrary to the above, on December 6,1997, required narrative log entries in the unified log for the safety system inoperability were not r,ade. Specifically, two safety-related systems, the Unit 2 suppression pool sprr.y mode of residual heat removal system (TS 3.6.2.2) and high pressure coolent injection system (TS 3.5.1.c.2) were inoperable for about two hours without a narrative log entry reflecting the system's inoperability in the unified log.

This is a Severity Level IV violation (Supplement 1).

B. Appendix B, Criterion lil, of 10 CFR 50 states, in part, that measures shall be provided for verifying or checking the adequacy of desian changes performed during maintenance and repair, and that design changes, inclu *ield changes shall be subject to design control measures commensurate with ths e applied to the original design.

Contrary to the above, on December 26,1997, measures were not provided for verifying the adequacy of field changes performed during maintenance and repair to ensure that design controls were commensurate with those applied to the origint:

design. Specifically, T ?CO identified a large number of maintenance discrepancies affecting 32 hydraulic control units (HCU) during a follow-up investigation to an individual control rod that fully inserted during a reactor protection system surveillance test, demonstrating that inadequate maintenance had been performed.

Specifically, PECO did not establish adequate measures to assure that the applicable design requirements were adaquately maintained during HCU on-line maintenance.

This is a Severity Level IV violation (Supplement I).

9803030105 900223 PDR ADCCK 05000352 G PDR

2 C. Units 1 and 2 Technical Specification (TS) 6.8.1 requires, in part, that written procedures shall be implemented covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, F0bruary 19,8. Regulatory Guide 1.33 recommends Administrative Procedures for Equipment Control (e.g., locking and tagging) as activities that should be covered by written procedures. Administrative procedure A C-008, Control of Locked Valves and Devices, written to comply with TS 6.8.1, requires in part, that the individual requesting permission for the manipulation of a locked device should enter the valve or device information in the Locked Valve Log and obtain permission from the Shift Management. Shift Management shad then indicate authorization for the manipulation by initiating and dating the Log entry.

Contrary to the above, on October 7,1997, procedures were not correctly implemented,in that, an equipment operator (EO), unlocked and opened floor drain, FD 74, without proper configuration controls as stated in A-C-8, Control of Locked-Valves and Devices. The EO did not properly fill out the Lock Valve Log nor was Shif t Management approval granted prior to removing the floor drain plug. The floor drain remained in an open condition for about 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br />.

This is a Suverity Level IV violation (Supplement 1).

Pursuant to the provisions of 10 CFR 2.201, PECO Energy is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region I, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of e

Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation or severity level, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresset the required response. If an adequate reply is not received withb the time specified in this Notice, an order or e Oemand for Information may be issued as to why the license should not be modified, suspended, or rewked, or why such other action as may be proper should not be taken. Whev jood cause is shown, consideration will be given to extending the response time, if you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be ploced in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request 1

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3 r withholding of such material, you mutt specifically identify the portions of your response i that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted.

invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information), if safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated at King of Prussia, Pennsylvania this 23rd day of February 1998.

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