ML20236V184
| ML20236V184 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/27/1998 |
| From: | Anderson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Rainey G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| 50-352-98-03, 50-352-98-3, 50-353-98-03, 50-353-98-3, NUDOCS 9807310353 | |
| Download: ML20236V184 (3) | |
See also: IR 05000352/1998003
Text
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July 27, 1998
Mr. G. Rainey, President
PECO Nuclear
Nuclear Group Headquarters
Correspondence Control Desk
P. O. Box 195
Wayne, PA 19087-0195
SUBJECT:
NRC INTEGRATED INSPECTION REPORT NOS. 50-352/98-03
AND 50-353/98-03
Dear Mr. Rainey:
This refers to your July 16,1998 and your July 21,1998 correspondences, in response to
our June 18,1998 letter.
Thank you for informing us of the corrective and preventive actions documented in your
letter. These actions will be examined during a future inspection of your licensed program.
Your cooperation with us is appreciated.
Sincerely,
Original Signed by.
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Clifford J. Anderson, Chief
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Projects Branch 4
Division of Reactor Projects
Docket Nos. 50-352;50-353
cc w/ copy of Licensee Response Ltr:
T. Moore, Manager, Experience Assessment
Secretary, Nuclear Committee of the Board
Commonwealth of Pennsylvania
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cc:
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G. Edwards, Chairman, Nuclear Review Board and Director - Licensing
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J. VonSuskil, Vice President - Limerick Generating Station
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9807310353 980727
ADOCK 05000352
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0FFICIAL R2 CORD COPY
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Mr. G. Rainey
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Distribution w/ copy of Licensee Response Ltr:
Region I Docket Room (with concurrences)
C. Anderson, DRP
D. Florek, DRP
R.Junod,DRP
NRC Resident inspector
Nuclear Safety Information Center (NSIC)
PUBLIC
Distribution w/ encl: (Via E-Mail)
B. McCabe, OEDO
R. Capra, PDI-2, NRR
inspection Program Branch, NRR (IPAS)
R. Correia, NRR
F. Talbot, NRR
M. Campion, ORA
DOCDESK
DOCUMENT NAME: A:\\RL9803. LIM
To receive a copy of this document, indicate in the box: "C" = Copy without
attachment /epqloyyre
"E" = Copy with attachment / enclosure
"N" = No copy
OFFICE
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DATE
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07/37/98
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OFFICIAL RECORD COPY
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~ Mr.' G. Rainey
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' Distribution w/ copy'of Licensee Response Ltr:
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- . Region i Docket Room (with concurrences)
B. McCabe, OEDO
R. Capra, PDI-2, NRR
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. R. Correi:,, NRR :
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F.' Talbot, NRR
C. Anderson, DRP .
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D. Florek, DRP
M. Campion, ORA
R. Junod, DRP
NRC Resident inspector
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Nuclear Safety information Center (NSIC)
PUBLIC
' Inspection Program Branch, NRR (IPAS)
-DOCDESK
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C0CUMETT NAME: A:\\RL9803'. LIM
'See previous concurrences
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To receive e copy of this document, indicate in the box: "C" = Copy without
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attachment / enclosure
"E"'= Copy with attachment / enclosure
"N" = No copy
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OFFICE
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NAME
DFlorek/DF
CAnderson/CA
DATE
07/27/98
07/27/98
OFFICIAL RECORD COPY
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James D. von Suskil
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Vx:s Presdent
Limanck GenerttnD station
PECO NUCLEAR
Pecc ene,g, c ,,,
A Unit of PECO Energy
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Sanatoga. PA 19464-0920
610 718 3000 / Fax 610 718 3008
Pager 1800 672 2285 #0271
Internet address: jvonsuskil@peco-energycom
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
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Reply to a Notice of Violation
NRC Integrated Inspection Report Nos. 50-352/9Mtfand 50-353/9M
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
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18,1998. The NoJce identified one violation concerning plant conditions not accurately
reflected in the Operations unified control room log (UCRL). The attachment to this letter
provides a restatement of each violation followed by our reply.
If you have any questions or require additional information, please contact us.
Very truly you ,
J
Betachment
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cc:
H. J. Miller, Administrator, Region I, USNRC
w/ attachment
A. L. Burritt, USNRC Senior Resident inspector, LGS
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Docket Nos. 50-352 and 50-353
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July 16,1998
Page 2
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G. R. Rainey - CB,63C-3
w/ attachment
J. D. von Suskil - SMB1-1
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R. W. Boyce - CB, 63C-3
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M. P. Gallagher - GML5-1
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J. A. Hutton - GML5-1
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G. D. Edwards - CB,62A-1
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J. E. Cohen - SSB4-3
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T. A. Moore - SSB2-4
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LGS ISEG - SSB4-2
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NRB Chairman - CB,62A-1
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Secretary, NCB - CB,62A-1 (11 copies)
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OEAP Coordinator - CB,62A-1
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Correspondence Release Point - SMB1-2
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DAC - SMB1-2
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Attachment
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Docket Nos. 50-352 and 50-353
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July 16,1998
Page 1 of 2
Repiv To a Notice of Violation
Violation 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 NRC 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 inoperable 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 I).
REPLY
Admission of the Violation
PECO Energy acknowledges the violation.
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Attachment
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Docket Nos. 50-352 and 50-353
July 16,1998
Page 2 of 2
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Reasons for the Violation
The management expectation for logging of LCOs was not effectively reinforced to Operations
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shift management. As a result, a common practice of logging only the most restrictive TS
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action developed and shift management did not recognize this practice as a deficiency.
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Responses to previous logging deficiencies focused on individual performance lapses and did
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not involve an assessment of overall compliance with the expectations for log entries. As a
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result, previous corrective actions did not address the underlying causes for the most recent
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deficiencies as cited in this notice of violation.
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Corrective Actions Taken and Results Achieved
The appropriate UCRL regulatory action entry for the Unit 2 CREFAS TS action due to the
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inoperability of the D-13 emergency diesel generator was created on May 14,1998.
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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.
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Shift managers have incorporated the reinforcement for TS action logging in their routine
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reviews of operator logs.
Corrective Actions to Avoid Future Noncomollance
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Shift managers will conduct additional face-to-face briefings with all cenior licensed operators to
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reinforce log-keeping expectations. These briefings are expected to be completed by August
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15,1998.
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Operations initiated a review of log-keeping guidance, including industry standards and best
practices. Guidance for operator log-keeping will be revised to incorporate the results of this
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review. This is expected to be completed by August 15,1998.
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Date When Full Compliance was Achieved
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Full compliance was achieved on June 13,1998 when the required UCRL entry for the
inoperability of the D-13 emergency diesel generator and 'B' CREFAS was created.
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Jame2 0 van Suikd
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Vce President
Umench Gensrating Stacco
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PECO NUCLEAR
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A Unit of PECO Energy
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sanatoga. PA IS464 0920
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610 718 3000 / Fax 610 718 3008
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Pager 1800 672 2285 *0271
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Internet address: jvonsuskd@peco enerQYCom
July 21,1998
Docket Nos. 50-352
50-353
License Nos. NPF-39
NPF-85
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U.S. Nuclear Regulatory Commission
Attn.: Document Control Desk
Washington, DC 20555
SUBJECT:
Limerick Generating Station, Units 1 and 2
Correction to July 16,1998 Reply to a Notice of Violation
NRC Integrated Inspection Report Nos. 50-352/98-03 and 50-353/98-03
The purpose of this letter is to provide a correction to the cover letter for the subject
Limerick Generating Station Reply to Notice of Violation dated July 16,1998. The cover
letter for the reply incorrectly referenced NRC Integrated Inspection Report Nos. 50-
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352/97-10 and 50-353/97-10. The correct reference is Integrated inspection Report
Nos. 50-352/98-03 and 50-353/98-03. This correction has no impact on the content of
the original reply and, therefore, a copy of the original reply has not been included with
this letter.
If you have any questions or require additional information, please contact us.
Very truly yours,
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cc:
H. J. Miller, Administrator, Region I, USNRC
A. L. Burritt, USNRC Senior Resident inspector, LGS
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