ML20236R508
| ML20236R508 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/16/1998 |
| From: | Von Suskil J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-352-97-10, 50-353-97-10, NUDOCS 9807220087 | |
| Download: ML20236R508 (4) | |
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James D. von Suskil Vce President l
Urnerick Generatrig station v
PECO NUCLEAR ruo %, c-e, A Unit of PECO Energy
$3 j 3 8 "2300 sanatoga, PA 19464-0920 610 718 3000 / Fax 610 718 3008 Pager 1000 672 2285 #0271 Internet address: jvonsuskil@peco-energy com 10 CFR 2.201 July 16,1998 Docket Nos. 50-352 50-353 License Nos. NPF-39 NPF-85 U.S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, DC 20555
SUBJECT:
Limerick Generating Station, Units 1 and 2 Reply to a Notice of Violation NRC Integrated inspection Report Nos. 50-352/97-10 and 50-353/97-10 Attached is PECO Energy Company's reply to a Notice of Violation for Limerick Generating Station (LGS), Units 1 and 2, that was contained in your letter dated June 18,1998. The Notice identified one violation concerning plant conditions not accurately reflected in the Operations brMed control room log (UCRL). The attachment to this letter provides a restatement of each violation fo!1 owed by our reply.
If you have any questions or require additional information, please contact us.
Very truly you s, achment ec:
H. J. Miller, Administrator, Region I, USNRC w/ attachment A. L. Burritt, USNRC Senior Rasident inspector, LGS l
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.g Docket Nos. 50-352 and 50-353 July 16,1998 Page 2 l
bec:
G. R. Rainey - CB, 63C-3
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.-J. D von Suskil-SMB1-1 R. W. Boyce - CB,63C-3 M. P. Gallagher - GML5-1 3
J.' A. Hutton - GML5-1 G. D. Edwards - CB,62A-1 j
J. E. Cohen - SSB4-3 T. A. Moore - SSB2-4 LGS ISEG - SSB4-2 '
NRB Chairman - CB,62A-1' q
Secretary, NCB - CB,62A-1 (11 copies)
OEAP Coordinator - CB,62A-1 Correspondence Release Point - SMB1-2 DAC - SMB1-2 4
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' Attachment Docket Nos. 50-352 and 50-353 July 16,1998 -
Page 1'of 2 Reniv To a Notice of Violation yjolation A Restatement of Violation During an NRC inspection conducted on March 17,1998 through May 18,1998, a violation of ~
NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for N'lC Enforcement Actions," NUREG-1600, the violation is listed below:
Appendix B, Criterion XVI, of 10 CFR 50 states, in part, that measures shall be established to assure that conditions adverse to quality, such as nonconformances 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.
Contrary to the above, measures established to correct nonconformances regarding log entries, identified in violation 97-10-01, did not preclude repetition of a similar problem, as evidenced by the following examples:
1.
On April 4,1998, operators declared the D-13 emergency diesel generator inoperable. This condition consequently rendered the control room emergency fresh air supply (CREFAS) system inoperable, however operators did not enter in the control room unified log that they had entered the Unit 2 CREFAS Technical Specification limiting condition for operation (LCO) 3.7.2.a.1.
2.
On April 4,1998, with the D-13 emergency diesel generator inoperabie and the
'B' CREFAS system inoperable, the operators did not enter in the control room unified log that they had entered the Unit 2 CREFAS Technical Specification LCO 3.7.2.a.3.
This is a Severity Level IV violation (Supplement 1).
REPLY Admission of the Violation PECO Energy acknowledges the violation.
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Attachment Docket Nos. 50-352 and 50-353 July 16,1998 Page 2 of 2 Reasons for the Violation The management expectation for logging'of LCOs was not effectively reinforced to Operations shift management. As a result, a common practice of logging only the most restrictive TS action develonad
.d d.Z r,;= ;;ement did not recognize this practice as a deficiency.
Rsagunas to previous logging deficiencies focused on individual performance lapses and did not involve an assessment of overall compliance with the expectations for log entries. As a result, previous corrective actions did not address the underlying causes for the most recent deficiencies as cited in this notice of violation.
- Corrective Actions Taken and Results Achieve.d The appropriate UCRL regulatory action entry for the Unit 2 CREFAS TS action due to the inoperability of the D-13 emergency diesel generator was created on May 14,1998.
The appropriate UCRL regulatory action entry for the Unit 2 CREFAS TS action due to the inoperability of the D-13 emergency diesel generator and 'B' CREFAS was created on June 13, 1998.
The Senior Manager of Operations promptly reinforced the expectation that all applicable TS actions be logged in UCRL.
Shift managers have incorporated the reinforcement for TS action logging in their routine reviews of operator logs.
Corrective Actions to' Avoid Future Noncompilance Shift managers will conduct additional face-to-face briefings with all senior licensed operators to reinforce log-keeping expectations. These briefings are expected to be completed by August
-15,1998.
Operations initiated a review of log-keeping guidance, including industry standards and best practices. Guidance for operator log-keeping will be revised to incot ic. ?te the results of this review. This is expected to be completed by August 15,1998.
Date When Full Comoliance was Achieved
' Full compliance was achieved on June 13,1998 when th' required UCRL entry for the e
inoperability of the D-13 emergency diesel generator and 'B' CREFAS was created.
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