ML20236M733

Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $55,000.Violation Noted:During 970901-980121, Condition Adverse to Quality Existed Involving Inoperability of 1B RHR Min Flow Valve & No C/As Taken

ML20236M733
Person / Time
Site:	Limerick
Issue date:	07/07/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20236M710	List: ML20236M707 ML20236M733
References
EA-98-141, NUDOCS 9807140238
Download: ML20236M733 (4)

Text

- - - _ _ _ _ - _ _ - _ _ - _ _ - _ - _ _ _ - _ _ _ _ _ _ _ _ - - _ _ _ - _ - _ _ _ _ --_

l ENCLOSURE NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY PECO Nuclear Docket Nos. 50-352;50-353 Limerick Nuclear Generating Stations License Nos. NPF 39; NPF-85 Units 1 and 2 EA 98-141 During NRC inspections conducted between October 20,1997, and Marcle 16,1998, for which exit meetings were held on January 16,1998 and March 25, 1998, violations of NRC requirements were identified. in accordance with the. " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the Nuclear Regulatory Commission proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act),42 U.S.C. 2282, and 10 CFR 2.205. The particular violations and associated <

' civil penalty are set forth below: j

l. VIOLATIONS ASSESSED A civil PENALTY 10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Action", requires, in part, that measures be established to assure that conditions adverse to quality, such as failures,  !

malfunctions, and deficiencies are promptly identified and corrected.' In the case of 4 significant conditions adverse to quality, the measures shall asstare that the cause of the condition is determined and corrective action taken to preclude repetition,

a. Contrary to' the above, between January 8,1998.and January 28,1998,a condition adverse to quality existed, namely potential inoperability of HPCI exhaust valve due to internal binding, and although indications of this incperability were provided when the valve failed to close on its first attempt on January 8,1998, and subsequent data provided indications of such internal binding, measures were not established to assure that this significant condition adverse to quality was promptly corrected until the valve again failed on its first attempt when tested on January 28,1998. As a result, between January 8,1998, and January 28,1998, the HPCI turbine exhaust valve, a primary containment isolation valve (outboard) was not maintained operable with a closing time less than or equal to 120 seconds. This is contrary to Unit 1 Technical Specification 3.6.3, " Primary Containment Isolation Valves", which requires, in part, that the pr! mary

, containment isolation valves shown in Table 3.6.3-1 sha!I be operable with isolation times less than or equal to those shown in Table 3.6.31. The HPCI turbine exhaust valve is listed as an outboard isolation barrier, with a maximum isolation time of 120 seconds. ' (01013)

~

9907140238 990707 PDR ADOCK 05000352 j G PDR _

L ,

l

Enclosure 2 ,

I l b. Contrary to the above, between September 1,1997, and January 21,1998,a l condition adverse to quality existed involving the inoperability of the 1B residual heat removal (RHR) minimum flow valve (HV-051-FOO78) after it was found closed on four occasions, and during that period, adequate corrective actions were i not taken to correct this condition adverse to quality in that although an equipment l trouble tag was initiated in each case to address the anomalous valve operation, the system was considered operable with no basis for doing so. As a result, between September 1,1997, and January 21,1998, the malfunctioning minimum flow valve caused the RHR pump to be inoperable and resulted in technical i specifications being violated, namely: 1

1. during this period, the suppression pool cooling mode of the "B" RHR system was not operable; this was contrary to Technical Specification 3.6.2.3 which requires, in part, that the suppression pool cooling mode of the RHR system shall be operable with two independent loops, each loop consisting of one operable RHR pump, and with one suppression pool cooling loop inoperable, the inoperable loop must be restored to operable -

status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

2. the suppression pool spray mode of the "B" RHR system was not operable; this was contrary to Technical Specification 3.6.2.2. which requires, in part, that the suppression pool spray mode of the RHR system shall,be operable with two independent loops, each loop consisting of one operable )

RHR pump, and with one suppression pool spray loop inoperable, the '

inoperable loop must be restored to operable status within seven days.

3. the low pressure coolant injection (LPCI) mode of the "B" RHR system removal system was not operable; this was contrary to Technical Specification 3.5.1.b which requires, in part, that the LPCI system of the RHR system be operable consisting of 'our subsystems .with each subsystem comprised of one operable LT 'l pump, and with one LPCI subsystem inoperable, the inoperable LPCI pump must be restored to an operable status within 30 days. (01023)

These violations represent a Severity Level 111 problem (Supplement 1).

Civil Penalty - $55,000.

II. VIOLATION NOT ASSESSED A CIVIL PENALTY 10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Action", requires, in part, that measures be established to assure that conditions adverse to quality, such as failures, malfunctions, and deficiencies are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.

I l

l

r_ - _ _ _ _ _ _ .__ - _ _ _ _ _ _ . _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ -

Enclosure 3 Contrary to the above, between August 1994 and October 7,1997, a condition adverse to quality existed, namely a reversed bearing on the D21 emergency diesel generator, and this condition adverse to quality was not promptly identified and corrected despite an opportunity to do so because of a previous reversed bearing on the D22 EDG at Limerick between December 1995 and May 1996. (03013)

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

"ursuant to the provisions of 10 CFR 2.201, PECO Nuclear (Licensee) is hereby required to submit a written statement or explanation to the Director, Office of Enforcement, U.S. Nuclear i Regulatory Commission, within 30 days of the receipt of this Notice of Violation and Proposed imposition of Civil Penalties (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each alleged violation: (1) admission or denial of the alleged violation, (2) the raasons for the violation if admitted, and if denied, the reasons why, (3) the corrective steps that have been taken and the results achieved, (4) the corrective steps that will be taken to avoid further violations, and (5) the date when full compliance will be achieved. If an adequate reply is not received within the time specified in this Notice, an Order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked or why such other action as~may be proper should not be taken. Consideration may be given to extending the response time for good cause shown. Under the authority of Section 182 of the Act,42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

.Within the same time as provided for the response required above under 10 CFR 2.201, the Licensee may pay the civil penalties by letter addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, with a check, draft, monay order, or electronic transfer payable to the Treasurer of the United States in the amount of the civil penalties proposed above, or may protest imposition of the civil penalties, in whole or in part, by a written answer addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Comrnission. Should the Licensee fail to answer within the time specified, an order imposing the civil penalties will be

-issued. Should the Licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalties, in whole or in part, such answer should be clearly marked as an " Answer to a Notice of Violation" and may: (1) deny the violations listed in this Notice, in whole or in part, (2) demonstrate extenuating circumstances, (3) chow error in this Notice, or (4) show other reasons why the penalties should not be imposed. In addition to protesting the civil penalties in

( whole or in part, such answer may requect remission or mitigation of the penalties.

In requesting mitigation of the proposed penalties, the factors addressed in Section VI.B.2 of tne Enforcement Policy should be addressed. Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate parts of the 10 CFR 2.201 reply by specific reference (e.g., citing page and paragraph numbers) to avoid repetition. The attention of the Licensee is directed to the l other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalty.

l

I l

Enclosure 4 1 1

Upon failure to pay any civil penalty due that subsequently has been determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil  ;

action pursuant to Section 234c of the Act,42 U.S.C. 2282c.

The response noted above (Reply to Notice of Violation, letter with payment of civil penalty, and ..

Answer to a Notice of Violation) should be addressed to: James Lieberman, Director, Office of ) '

Enforcement, U.S. Nuclear Regulatory Commission, One White Flint North,11555 Rockville Pike, Rockville, MD 20852-2738, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region 1, and a copy to the NRC Senior Resident inspector at the facility that is the subject of this Notice.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent l pessible, it should not include any personal privacy, proprietary, or safeguards information so that  !

it can be'placed 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 withholding of such material, you mME1 specifically identify the portions of your response that you seek to have withheld and provide in l 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. 3 Dated at King of Prussia, Pennsylvania this 7th day of July 1998 l

l l

l I

l

,