ML20212J987
| ML20212J987 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 08/05/1986 |
| From: | Bernero R Office of Nuclear Reactor Regulation |
| To: | Bauer E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| NUDOCS 8608140584 | |
| Download: ML20212J987 (5) | |
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AUG 05 g Docket No. 50-352 Mr. Edward G. Bauer, Jr.
Vice President and General Counsel Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101
Dear Mr. Bauer:
SUBJECT:
CONTINUED OPERABILITY OF LICENSEE STATEMENTS Re:
Limerick Generating Station, Unit 1 This letter concerns the continuing operability of statements previously made by the Philadelphia Electric Company (PECo) in support of licensing activities for the Limerick Generating Station, Units 1 and 2.
Specifically, in the second paragraph of an application for amendment ' f the Unit I operating license dated o
December 18, 1985 PECo stated.as one of its bases for the action requested by the amendment application that it would be necessary to shut the plant down to perform the surveillance testing on the instrumentation line excess flow check valves. The staff understood this to be applicable to all of the excess flow check valves in the subject Technical Specification since the PEco amendment application addressed itself to Technical Specification 4.6.3.4 and its associ-ated table of excess flow check valves.
The staff reviewed the application for the amendment and issued the amendment on February 6, 1986. The Atomic Safety and Licensing Board conducted a pre-hearing conference in Philadelphia on March 27, 1986 to consider the petition of Mr. Robert L. Anthony concerning license amendment no. 1, as well as license amendment no. 2.
In a decision dated April 4, 1986 the Licensing Board termin-ated the intervention proceeding and in a decision dated May 12, 1986 the Appeal Board dismissed Mr. Anthony's appeal from the Licensing Board's decision.
The issue that concerns us here is that from late February through May 2, 1986 the potential for testing a subset of the excess flow check valves in Technical Specification 4.6.3.4 while at power was explored, procedures were developed and testing was carried out on this subset of valves while the unit was at power.
We are not concerned with the act of testing at power itself. Rather we are concerned that these activities were carried out without notifying the Office of Nuclear Reactor Regulation which had previously issued the license amendment under the assumption that shutdown was required.
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We have not identified any plant operational safety significant aspects of the earlier testing of some of these valves; however the issue does raise concerns with respect to the adequacy of PECo's coordination of plant activities with infonnation previously submitted to the staff. Although this failure may not constitute a legal violation, it clearly represents a departure from the highest standards of communication that we expect from licensees at all times. Based on our conversations with members of your staff we understand that your staff is now fully appraised of the events surrounding this issue and is sensitive to the need to maintain the high standards of communication in these matters.
Therefore we have not Hentified any further need for corrective action and no response is required to this letter.
Sincerely,
's I
ob M. Bernero, Director
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Division of BWR Licensing D
cc: See next page 1
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y Mr. Edward G. Bauer, Jr Limerick Generating Station Philadelphia Electric Company Units 1 & 2 cc:
Troy B. Conner, Jr., Esquire Chairman Board of Supervisors of Conner and Wetterhahn Limerick Township 1747 Pennsylvania Ave, N.W.
646 West Ridge Pike Washington, D. C.
20006 Limerick, Pennsylvania 19468 Barry M. Hartman Frank R. Rcmano, Chairman Office of General Counsel Air & Water Pollution Patrol Post Office Box 11775 61 Forest Avenue Harrisburg, Pennsylvania 17108 Ambler, Pennsylvania 19002 Federic M. Wentz Dept. of Environmental Resources County Solicitor ATTN:
Director, Office Radiologic County of Montgomery Health Courthouse P. O. Box 2063 Norristown, Pennsylvania 19404 Harrisburg, Pennsylvania 17105 Mr. John Franz, Plant Manager Ms. M. Mulligan Limerick Generating Station Limerick Ecology Action Post Office Box A 762 Queen St.
Saratoga, Pennsylvania 19464 Pottstown, Pennsylvania 19464 Mr. Karl Abraham Thomas Gerusky, Director Public Affairs Officer Bureau of Radiation Protection Region I Dept. of Enviromental Resources U.S. Nuclear Regulatory Commission 5th Floor, Fulton Bank Bldg.
631 Park Avenue lhird and Locust Streets King of Prussia, PA 19806 Harrisburg, Pennsylvania 17120 Mr. Gene Kelly Governor's Office of State Senior Resident Inspector Planning and Development U.S. Nuclear Regulatory Commission ATTN: Coordinator, Pennsylvania P. O. Box 47 State Clearinghouse Sanatoga, Pennsylvania 19464 P. O. Box 1323 Harrisburg, Pennsylvania 17102 4
Philadelphia Electric Company Limerick Generating Station 1/2 cc:
Director, Pennsylvania Emergency Management Agency Basement, Transportation &
Safety Building Harrisburg, Pennsylvania 17120 Robert L. Anthony Angus Love, Esq.
Friends of the Earth 107 East Main Street of the Delaware Valley Norristown, Pennsylvania 19402 103 Vernon Lane, Box 186 Moylan, Pennsylvania 19065 Helen F. Hoyt, Chairman Kathryn S. Lewis, Esq.
Administrative Judge Municipal Services Bldg.
Atomic Safety & Licensing Board 15th and JFK Blvd.
U.S. Nuclear Regulatory Commission Philadelphia, Pennsylvania 19102 Washington, D. C.
20555 David Wersan, Esq.
Dr. Jerry Harbour Assistant Consumer Advocate Administrative Judge Office of Consumer Advocate Atomic Safety & Licensing Board 1425 Strawberry Square U.S. Nuclear Regulatory Commission Harrisburg, Pennsylvania 17120 Washington, D. C.
20555 Dr. Richard F. Cole Mr. Spence W. Perry, Esq.
Aaministrative Judge Associate General Counsel Atomic Safety & Licensing Board Federal Emergency Management Agency U.S. Nuclear Regulatory Commission Room 840 Washington, D. C.
20555 500 C St., S.W.
Washington, D. C.
20472 Mr. J. T. Robb, NS-1 Philadelphia Electric Company 2301 Market Street Philadelphia, Pennylsvania 19101 Timothy R. S. Campbell, Director Department of Emergency Services 14 East Biddle Street West Chester, Pennsylvania 19380
s Aug 05 We have not identified any plant operational safety significant aspects of the earlier testing of some of these valves; however the issue does raise concerns with respect to the adequacy of PECo's coordination of plant activities with information previously submitted to the staff. Although this failure may not constitute a legal violation, it clearly represents a departure from the highest standards of communication that we expect from licensees at all times.
Based on our conversations with members of your staff we understand that your staff is now fully appraised of the events surrounding this issue and is sensitive to the need to maintain the high standards of communication in these matters.
Therefore we have not identified any further need for corrective action and no response is required to this letter.
Sincerely, tristmal signedBy4
,3short L Deresse Robert M. Bernero,' Director Division of BWR Licensing cc: See next page
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