ML20236M707
| ML20236M707 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/07/1998 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Rainey G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| Shared Package | |
| ML20236M710 | List: |
| References | |
| 50-352-98-02, 50-352-98-2, 50-353-97-09, 50-353-97-9, 50-353-98-02, 50-353-98-2, EA-98-141, NUDOCS 9807140226 | |
| Download: ML20236M707 (6) | |
See also: IR 05000352/1998002
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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475 ALLENDALE ROAD
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KING oF PRUSSIA, PENNSYLVANIA 194061415
July 7,1998
EA 98-141
Mr. G. Rainey, President
PECO Nuclear
Nuclear Group Headquarters
Post Office Box 195
Wayne, Pennsylvania 19087-0195
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL
PENALTY - $55,000
(NRC Inspection Report Nos. 50-353/97-09:50-352/98-02 and
50-353/98-02)
Dear Mr. Rainey:
This letter refers to the two NRC inspections conducted between October 20,1997,and
March 16, 1998, for which exit meetings were held on January 16,1998, and
March 25,1998. During the inspections, the reports of which were sent to you on March 11,
1998, and May '11,1998, apparent violations of NRC requirements were identified.
On
June 10,1998, a Predecisional Enforcement Conference was conducted with you and
members of your staff, to discuss the violations, their causes, and your corrective actions.
Based on the information developed during the inspections, aad the information provided
during the enforcement conference, three violations of NRC requirements are being cited and
are described in the enclosed Notice of Violation and Proposed imposition of Civil Penalty
(Notice). The three violations involve failures to identify and correct conditions adverse to
quanty at the facility; this includes instances where inoperability of safety-related equipment
were not recognized.
The two most significant violations are described in Section I of the enclosed Notice. The first
violation involves the failure to identify and correct a condition adverse to quality that caused
the high pressure coolant injection (HPCI) turbine exhaust valve to be inoperable. Specifically,
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on January 8,1998, the valve, which is a primary containment isolation valve (PCIV), failed
to close on the first attempt during surveillance testing, thereby not meeting the technical
specifications which require that the valve close within 120 seconds. Nonetheless, the valve
was returned to an operable status, based on the fact that it closed on a subsequent attempt,
even though data existed th?t indicated that the valve had internal binding. On January 28,
1998, the valve again failed to close during surveillance testing. The failure to promptly
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resolve the degraded valve performance led to an inoperable primary containment isolation
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function of the HPCI exhaust valve for extended periods of time,'as failures of the HPCI
turbine exhaust valve actually occurred on five occasions between March 1994 and January
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1998.
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Although the valve does not have an automatic isolation function, it is necessary to isolate the
HPCI system in the event of HPCI system leakage and is considered an extension of the
containment boundary. In each of the first 4 occurrences, root cause-analyses were not
adequate to detect the root cause of the problem. Of particular concern is the fact that after
the fifth failure on January 8,1998, the valve was not declared inoperable even though
subsequent data revealed intemal binding of the valve. Rather, the frequency of the valve
tests was irweased to weekly. The valve was not declared inoperable until it again would not
close during an initial attempt when tested on January 28,1998.
The NRC is concerned with the inadequacies of the associated engineering assessment and
safety evaluation which found it acceptable to postpone further valve troubleshooting and
repairs based on an operability determination that was flawed. The engineering assessment,
in considering operability, discounted the need for the valve to close the first time to meet the
closure time required by technical specifications. Also, the plant operations review committee
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(PORC) approved the safety evaluation without evaluating and challenging the short term
- corrective actions to ensure near term reliability of the valve, including its ability to meet the
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required closure time.
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The second violation involved the failure to correct a condition adverse to quality that caused
several modes of residual heat removal (RHR) to be inoperable. Specifically, the 1B RHR
minimum flow valve, which is required to open when an RHR pump is in operation with system
flow less than 1500 gallons per minute (gpm), was not declared inoperable even though it was
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found closed four times in a five month period between September 1997 and January 1998
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while flow was less than 1500 gpm. Although the valve, which provides minimum flow
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protection for the RHR pump, should have been declared inoperable, the operators simply
reopened the valve without identifying the root cause of the problem until after the fourth
occurrence. Afterwards, your staff determined that the valve had a faulty flow control circuit
which caused the system to be inoperable, contrary to the technical specifications.
The NRC considers this violation significant since pump damage could occur under no flow
conditions in as little as three minutes. The NRC is particularly concerned that similar to the
issue concerning the HPCI turbine exhaust valve, this problem revealed a lack of
comprehensive troubleshooting by the engineering staff, as well as improper acceptance by
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the. operators that the pump was operable even though the cause of the problem was not
identified.
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These two violations lndicate a significant lack of attention tr 6~d responsibilities.
Therefore, the violations are c!assified in the aggregate as a f y ay Level lli problem in
accordance with the " General Statement of Policy and Procedure for NRC Enforcement
Actions," NUREG-1600 (Enforcement Policy).
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PECO Nuclear.
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A base civil penalty in the amount of $55,000 is considered for this Severity Level lli problem.
Because Limerick has been the subject of escalated enforcement actions within the last 2
years,' the NRC considered whether credit was warranted for / identification and Corrective
Act/on in accordance with the civil penalty assessment process in Section VI.B.2 of the
Enforcement Policy. ' Credit for identification is not warranted in either case. Although your
staff identified all of the examples of the failure to the HPCI exhaust valve to close, as well
as the RHR minimum flow vaive being in the wrong position, the NRC identified the conditions
adverse to quality that these findings represented, namely the Inoperability of the valves
contrary to the technical specifications, as well as the failure to promptly address the root
cause of these failures. Credit for your corrective actions is warranted because at the time
of the enforcement conference, your actions were considered prompt and comprehensive.
These actions included, but were not limited to, (1) a programmatic evaluation of the
operability process; (2) implementation of improved procedural guidance for operability
determinations; (3) enhancement of the troubleshooting process; and (4) training of staff on
the enhanced guidance. The NRC plans to continue to follow your actions closely to
determine the effectiveness of your actions in precluding future problems.
To emphasize the importance of appropriate evaluations of problems at your facility, as well
as prompt determination of operability of equipment, as well as prompt development of-
appropriate corrective action, I have been authorized, after consultation with the Director,
Office of Enforcement, to issue the enclosed Notice of Violation and Proposed imposition of
Civil Penalty in the amount of $55,000 for these violations.
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The third violation involves the fai!ure to promptly identify and correct a condition adverse to
quality regarding the iraproper installation of a connecting rod bearing for one of the eight
Emergency Diesel Generators (EDG). This violation has been classified at' Severity Level IV
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and is described in Section ll of the enclosed Notice.
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You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response. The NRC will use your response, in part, to
determine whether further enforcemerit action is necessary to ensure compliance with
regulatory requirements.
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e.g., a Notice of Violation and Proposed Imposition of Civil Penalty was issued on Augt ;t 5,1997 for a
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Severity Level II violation related to the failure to maintain complete and accurate records at the facility.
' (Reference: EA 97-050;97-115).
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PECO Nuclear
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in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its
enclosure, and your response will be placed in the NRC Public Document Room (PDR).
Sincerely,
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H
rt J. Miller
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Regional Administrator
Docket Nos. 50-352;50-353
Enclosure: Notice of Violation and Proposed imposition of Civil Penalty
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cc w/ encl:
G. Edwards, Chairman, Nuclear Review Board and Director - Licensing
J. VonSuskil, Vice President - Limerick Generating Station
J. Kantner, Manager, Experience Assessment
Secretary, Nuclear Committee of the Board
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Commonwealth of Pennsylvania
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DISTRIBUTION:
PUBLIC
SECY
CA
LCallan, EDO
AThadani, DEDE
JLieberman, OE
HMiller, RI
FDavis, OGC
SCollins, NRR
RZimmerman, NRR
Enforcement Coordinators
RI, Ril, Rill, RIV
BBeecher, GPA/PA
GCaputo, 01
DBangart, OSP
HBell, OlG
TMartin, AEOD
OE:Chron
OE:EA
NUDOCS
DScrenci, PAO RI
NSheehan, PAO-RI
LTremper, OC
Nuclear Safety Information Center (NSIC)
NRC Resident inspector - Limerick
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30043
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