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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217D5211999-09-30030 September 1999 Informs That Remediating 3D Monicore Sys at Pbaps,Units 2 & 3 & 3D Monicore/Plant Monitoring Sys at Lgs,Unit 2 Has Been Completed Ahead of Schedule ML20216J3981999-09-29029 September 1999 Submits Comments for Lgs,Unit 1 & Pbaps,Units 2 & 3 Rvid,Rev 2,based on Review as Requested in GL 92-01,rev 1,suppl 1, Reactor Vessel Structural Integrity ML20212J6561999-09-29029 September 1999 Informs of Completion of mid-cycle PPR of Limerick Generating Station on 990913.Identified No Areas in Which Licensee Performance Warranted Addl Insp Beyond Core Insp Program.Historical Listing of Plant Issues Encl ML20212H6401999-09-24024 September 1999 Forwards Revised Epips,Including Rev 11 to ERP-101 & Rev 18 to ERP-800.Copy of Computer Generated Rept Index Identifying Latest Revs of LGS Erps,Encl ML20212E7941999-09-22022 September 1999 Requests Authorization for Listed Licensed Operators to Temporarily Suspend Participation in Licensed Operator Requalification Program at LGS ML20212E8081999-09-22022 September 1999 Provides Notification That Listed Operators Have Been Permanently Reassigned to Duties That Do Not Require Maintaining Licensed Operator Status,Per 10CFR50.74 ML20212F5481999-09-20020 September 1999 Forwards Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing, for Pbaps,Units 2 & 3 & Lgs,Units 1 & 2 ML20212F8991999-09-17017 September 1999 Provides Written Confirmation That Thermo-Lag 330-1 Fire Barrier Corrective Actions at Lgs,Units 1 & 2 Have Been Completed 05000353/LER-1999-010, Forwards LER 99-010-00,re Manual Actuation of Esf.Main CR Ventilation Sys Was Placed in Chlorine Isolation Mode Due to Rept of Faint Odor of Chlorine in Unit 2 Reactor Encl1999-09-16016 September 1999 Forwards LER 99-010-00,re Manual Actuation of Esf.Main CR Ventilation Sys Was Placed in Chlorine Isolation Mode Due to Rept of Faint Odor of Chlorine in Unit 2 Reactor Encl ML20216F7821999-09-16016 September 1999 Forwards Insp Repts 50-352/99-05 & 50-353/99-05 on 990713-0816.One Violation Noted & Being Treated as NCV, Consistent with App C of Enforcement Policy.Violation Re Inoperability of Automatic Depression Sys During Maint ML20212A8751999-09-13013 September 1999 Forwards Safety Evaluation of First & Second 10-year Interval Inservice Insp Plan Request for Relief ML20211N5061999-09-0909 September 1999 Forwards TSs Bases Pages B 3/4 10-2 & B 3/4 2-4 for LGS, Units 1 & 2,being Issued to Assure Distribution of Revised Bases Pages to All Holders of TSs ML20212A0091999-09-0909 September 1999 Provides Notification That Licenses SOP-11172 & SOP-11321, for SO Muntzenberger & Rh Wright,Respectively,Are No Longer Necessary as Result of Permanent Reassignment ML20211P8571999-09-0808 September 1999 Forwards Reactor Operator Retake Exams 50-352/99-303OL & 50-353/99-303OL Conducted on 990812 ML20211P3891999-09-0303 September 1999 Informs That During 990902 Telcon Between J Williams & B Tracy,Arrangements Were Made for NRC to Inspect Licensed Operator Requalification Program at Plant.Insp Planned for Wk of 991018 05000352/LER-1999-009, Forwards LER 99-009-00,providing 30-day Written follow-up Rept Re Performance of Maint That Affected Safeguard Sys for Which Compensatory Measures Had Not Been Employed1999-09-0101 September 1999 Forwards LER 99-009-00,providing 30-day Written follow-up Rept Re Performance of Maint That Affected Safeguard Sys for Which Compensatory Measures Had Not Been Employed ML20211H2571999-08-26026 August 1999 Informs of Individual Exam Result on Initial Retake Exam on 990812.One Individual Was Administered Exam & Passed ML20211E9191999-08-24024 August 1999 Forwards fitness-for-duty Program Performance Data for Jan-June 1999 for PBAPS & LGS IAW 10CFR26.71(d).Data Includes Listed Info ML20211E9731999-08-23023 August 1999 Forwards LGS Unit 2 Summary Rept for 970228 to 990525 Periodic ISI Rept Number 5, Per TS SRs 4.0.5 & 10CFR50.55a(g) ML20211D6761999-08-20020 August 1999 Forwards non-proprietary Revised Emergency Response Procedures (Erps),Including Rev 29 to ERP-110, Emergency Notification & Rev 17 to ERP-800, Maint Team & Proprietary App ERP-110-1.App Withheld Per 10CFR2.790(a)(6) ML20210T4271999-08-13013 August 1999 Informs That NRC Revised Info in Rvid & Releasing Rvid Version 2 as Result of Review of 980830 Responses to GL 92-01 Rev 1,GL 92-01 Rev 1 Suppl 1 & Suppl Rai.Tacs MA1197 & MA1198 Closed ML20210U2211999-08-10010 August 1999 Forwards Insp Repts 50-352/99-04 & 50-353/99-04 on 990525-0712.One Violation Occurred & Being Treated as NCV, Consistent with App C of Enforcement Policy.Violation Re Late Performance of off-gas Grab Sample Surveillance 05000353/LER-1999-005, Forwards LER 99-005-00,re Actuation of Primary Containment & Reactor Vessel Isolation Control Sys,Esf.Fuse Failed Due to Mechanical Failure of Cold Solder Joint1999-08-10010 August 1999 Forwards LER 99-005-00,re Actuation of Primary Containment & Reactor Vessel Isolation Control Sys,Esf.Fuse Failed Due to Mechanical Failure of Cold Solder Joint ML20211B7881999-08-10010 August 1999 Transmits Summary of Two Meetings with Risk-Informed TS Task Force in Rockville,Md on 990514 & 0714 ML20210M7571999-08-0404 August 1999 Forwards Response to Requesting Addl Info Re Status of Decommissioning Funding for Lgs,Pbaps & Sngs. Attachment Provides Restatement of Questions Followed by Response ML20210P4191999-08-0404 August 1999 Forwards Initial Exam Repts 50-352/99-302 & 50-353/99-302 on 990702-04 (Administration) & 990715-22 (Grading).Six of Limited SRO Applicants Passed All Portion of Exam NUREG-1092, Informs J Armstrong of Individual Exam Results for Applicants on Initial Exam Conducted on 990702 & 990712-14 at Facility.All Six Individuals Who Were Administered Exam, Passed Exam.Without Encls1999-08-0303 August 1999 Informs J Armstrong of Individual Exam Results for Applicants on Initial Exam Conducted on 990702 & 990712-14 at Facility.All Six Individuals Who Were Administered Exam, Passed Exam.Without Encls ML20210L2011999-07-28028 July 1999 Forwards Final Personal Qualification Statement (NRC Form 398) for Reactor Operator License Candidate LB Mchugh ML20211F2641999-07-27027 July 1999 Forwards Three Copies of Rev 12 to LGS Physical Security Plan, Rev 4 to LGS Training & Qualification Plan & Rev 2 to LGS Safeguards Contingency Plan. Without Encls 05000352/LER-1999-008, Forwards LER 99-008-00 Re 990623 Failure of Plant HPCI Sys to Start Due to Failure of HPCI Turbine,Hydraulic Actuator1999-07-23023 July 1999 Forwards LER 99-008-00 Re 990623 Failure of Plant HPCI Sys to Start Due to Failure of HPCI Turbine,Hydraulic Actuator 05000353/LER-1999-004, Forwards LER 99-004-00 Re 990701 Discovery of Pressure Setpoint Drift of Thirteen Mss SRV Due to Corrosion Induced Bonding within SRVs1999-07-23023 July 1999 Forwards LER 99-004-00 Re 990701 Discovery of Pressure Setpoint Drift of Thirteen Mss SRV Due to Corrosion Induced Bonding within SRVs ML20210E6211999-07-22022 July 1999 Submits Rev to non-limiting Licensing Basis LOCA Peak Clad Temps (Pcts) for Limerick Generating Station (Lgs),Units 1 & 2 & Pbaps,Units 2 & 3 ML20216D3081999-07-19019 July 1999 Requests Renewal of OLs for Listed Individuals,Iaw 10CFR55.57.NRC Forms 398 & 396,encl for Applicants.Without Encl ML20216D8041999-07-19019 July 1999 Submits Summary of Final PECO Nuclear Actions Taken to Resolve Scram Solenoid Pilot Valve Issues Identified in Info Notice 96-007 05000352/LER-1999-006, Forwards LER 99-006-00 Re 990614 Discovery That Grab Sample of Plant Offgas Sys Was Not Obtained within Time Limit Required by TS 3.3.7.12,Action 110 Due to Personnel Error1999-07-12012 July 1999 Forwards LER 99-006-00 Re 990614 Discovery That Grab Sample of Plant Offgas Sys Was Not Obtained within Time Limit Required by TS 3.3.7.12,Action 110 Due to Personnel Error ML20209F6341999-07-0909 July 1999 Submits Supplemental Response to GL 94-03, Intergranular Stress Corrosion Cracking of Core Shrouds in Bwrs, for Unit 2.Rev 0 to 1H61R & GE-NE-B13-02010-33NP Repts & Revised Pages to Summary Rept Previously Submitted,Encl ML20209G9121999-07-0909 July 1999 Informs That Ja Hutton Has Been Appointed Director,Licensing for PECO Nuclear,Effective 990715.Previous Correspondence Addressed to Gd Edwards Should Now Be Sent to Ja Hutton ML20209C9041999-07-0808 July 1999 Forwards Monthly Operating Repts for June 1999 for Limerick Generating Station,Units 1 & 2 & Revised Monthly Repts for May 1999 ML20210B4441999-07-0808 July 1999 Forwards Preliminary NRC Form 398 & NRC Form 396 for Reactor Operator for License Candidate LB Mchugh.Candidate Failed Category B Portion of Operating Exam Given at LGS During Week of 990315.Tentative re-exam Has Been Scheduled 990812 05000353/LER-1999-003, Forwards LER 99-003-00,re Bypass of RW Cleanup Leak Detection Sys Isolation Function on Three Separate Occasions.Bypass of Safety Function Was Caused by Inadequate Review & Approval of Change to Procedure1999-07-0707 July 1999 Forwards LER 99-003-00,re Bypass of RW Cleanup Leak Detection Sys Isolation Function on Three Separate Occasions.Bypass of Safety Function Was Caused by Inadequate Review & Approval of Change to Procedure ML20209D8821999-07-0707 July 1999 Submits Estimate of Number of Licensing Actions Expected to Be Submitted in Years 2000 & 2001,as Requested by Administrative Ltr 99-02.Renewal Applications for PBAPS, Units 2 & 3,will Be Submitted in Second Half of 2001 ML20209D2671999-07-0202 July 1999 Responds to NRC 990322 & 0420 RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves ML20196J6301999-07-0101 July 1999 Requests Addl Info Re Status of Decommissioning Funding for Limerick Generating Station,Units 1 & 2,Peach Bottom Atomic Power Station,Units 1,2 & 3 & Salem Nuclear Generating Station,Units 1 & 2 05000352/LER-1999-004, Forwards LER 99-004-00,re Inoperability of Automatic Depressurization Sys Portion of Eccs.Condition Resulted from Incomplete Impact Review of Isolating Portion of ADS Nitrogen Backup Supply on Operability of ECCS Sys1999-07-0101 July 1999 Forwards LER 99-004-00,re Inoperability of Automatic Depressurization Sys Portion of Eccs.Condition Resulted from Incomplete Impact Review of Isolating Portion of ADS Nitrogen Backup Supply on Operability of ECCS Sys ML20209B7001999-06-30030 June 1999 Responds to GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants ML20212J5401999-06-28028 June 1999 Discusses Completion of Licensing Action for NRC Bulletin 96-003, Potential Plugging of ECC Suction Strainers by Debris in Bwrs. Bulletin Closed for Unit 2 by NRC ML20207H8271999-06-24024 June 1999 Informs NRC That Util Has Completed Core Shroud Insps for LGS Unit 2.Proprietary Rept GE-NE-B13-02010-33P & non-proprietary Rev 0 to 1H61R,encl.Proprietary Rept Withheld,Per 10CFR2.790(a)(4) ML20196G7041999-06-24024 June 1999 Forwards Insp Repts 50-352/99-03 & 50-353/99-03 on 990413- 0524.No Violations Noted.Nrc Concluded That Licensee Staff Continued to Operate Both Units Safely ML20196A5641999-06-15015 June 1999 Provides Info Re Util Use of Four Previously Irradiated LGS, Unit 1,GE11 Assemblies in Unit 2 Cycle 6.Encl 990518 GE Ltr Provides Objective of Lead Use Assemblies Program & Outlines Kinds of Measurements That Will Be Made on Assemblies ML20195J6831999-06-11011 June 1999 Provides Proprietary Objectives for Lgs,Units 1 & 2,1999 Emergency Preparedness Exercise Scheduled to Be Conducted on 990914.Licensee Identifies Which Individuals Should Receive Copies of Info.Proprietary Info Withheld 1999-09-09
[Table view] Category:NRC TO UTILITY
MONTHYEARML20062G4531990-11-20020 November 1990 Forwards SE Supporting Util Actions to Address Indication in Reactor Vessel Recirculation Riser nozzle-to-safe End Weld ML20062G4021990-11-19019 November 1990 Forwards Safety Insp Repts 50-352/90-21 & 50-353/90-20 on 900827-31.No Violations Noted ML20062F1771990-11-13013 November 1990 Confirms Dates of 901126-30 for NRC Equipment Qualification Insp of Facility ML20058F1981990-11-0505 November 1990 Advises That 901002 Response to Generic Ltr (GL) 90-03, Relaxation of Staff Position in GL 83-28,Item 2.2 Part 2, 'Vendor Interface for Safety-Related Components,' Acceptable ML20058E6121990-10-29029 October 1990 Forwards Radiological Safety Insp Repts 50-352/90-24 & 50-353/90-23 on 901001-05.No Violations Noted ML20058D2371990-10-26026 October 1990 Informs of Impending fitness-for-duty Program Insp & Requests 10CFR26.20 Required Policies & Procedures ML20058C1331990-10-23023 October 1990 Advises That Reactor Operator & Senior Reactor Operator Licensing Exams Scheduled for Wk of 910121 & Requalification Program Evaluation Scheduled for Wks of 910114 & 21.Ref Matl Listed on Encl Should Be Provided by 901029 ML20058A6241990-10-18018 October 1990 Forwards Insp Repts 50-352/90-22 &50-353/90-21 on 900912-19. No Violations Noted ML20062B7891990-10-12012 October 1990 Forwards Safety Insp Repts 50-352/90-20 & 50-353/90-19 on 900813-0916.No Violations Noted ML20059N5841990-10-0303 October 1990 Informs That Issuance of Senior Reactor Operator Licenses, for Fuel Handling Only,For More than One Facility Conditionally Acceptable IR 05000352/19900801990-09-28028 September 1990 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-352/90-80 & 50-353/90-80.Requests Status of Planned Revs to Procedures & Expected Completion Dates in 910130 Response ML20059F6561990-08-29029 August 1990 Forwards Notice of Withdrawal of 900516 Application for Amend to License NPF-39,revising Tech Specs to Allow one- Time Extension of Visual Insp Period for Three Small Inaccessible Snubbers in Drywell ML20058N0531990-08-0606 August 1990 Discusses Licensee Engineering Initiatives.Encourages Initiation of Initiative Similar to Region V Licensees Establishment of Engineering Managers Forum ML20058M5981990-08-0303 August 1990 Forwards Safety Insp Repts 50-352/90-17 & 50-353/90-16 on 900522-0701 & Notice of Violation.Inspectors Continued to Note Problems W/Procedure Compliance & in Technical Adequacy & Implementation of Procedures ML20058M3311990-08-0303 August 1990 Forwards Radiological Safety Insp Repts 50-352/90-19 & 50-353/90-18 on 900709-13.No Violations Noted.Weakness Observed in Maint of Station Health Physics Procedures ML20055E8641990-07-10010 July 1990 Comments on Util 891228 Response to Generic Ltr (GL) 89-10, Safety-Related Motor-Operated Valve (MOV) Testing & Surveillance. Requests Proposed Schedule for Completion of GL Program Along W/Justification for Alternative Schedule ML20055F5591990-07-0303 July 1990 Forwards Safety Insp Repts 50-352/90-80 & 50-353/90-80 on 900521-25.Plant Transient Response Implementing Plan (Trip) Technically Acceptable.Unresolved Items Noted.Impact of Insp Findings on Peach Bottom Trip Procedures Should Be Reviewed ML20059M8671990-06-13013 June 1990 Forwards NRC Performance Indicators for First Quarter 1990. W/O Encl ML20058K1961990-05-31031 May 1990 Forwards Results & Conclusions of Regulatory Effectiveness Review on 900507-11.Encl Withheld (Ref 10CFR73.21) ML20055C3091990-02-14014 February 1990 Forwards Safety Insp Repts 50-352/90-03 & 50-353/90-03 on 900116-19.No Violations Noted ML20248E7421989-09-27027 September 1989 Forwards Exam Repts 50-352/89-13OL & 50-353/89-22OL Administered on 890612-16 & 19.NRC Concerned About Effectiveness of Util Candidate Screening & Evaluation Process That Permitted Marginal Individual for NRC Exam ML20248G6601989-09-27027 September 1989 Forwards Operational Readiness Insp Rept 50-353/89-81 on 890730-0804 & Notice of Violation ML20248E5181989-09-22022 September 1989 Forwards Safety Insp Repts 50-352/89-15 & 50-353/89-24 on 890626-0730.No Violations Noted.Repts Delineate NRC Concerns Identified During mid-cycle SALP Review & Licensee self-assessment of Conduct of Operations ML20248G9611989-09-21021 September 1989 Forwards Amend 7 to Indemnity Agreement B-101,reflecting Increase in Primary Layer of Liability Insurance.Amends Conform to Changes Made to Price-Anderson Act Enacted on 880820 NUREG-1376, Forwards Tech Specs,NUREG-1376 & Sser 9 Re Application for OL for Facility.W/O Encls1989-09-11011 September 1989 Forwards Tech Specs,NUREG-1376 & Sser 9 Re Application for OL for Facility.W/O Encls ML20247N2331989-09-0808 September 1989 Forwards Insp Repts 50-352/89-17 & 50-353/89-25 on 890724-27.No Violations Noted.Corrective Actions Re Failure of Operators to Properly Classify Events Effective ML20247E7991989-09-0606 September 1989 Forwards Safety Insp Rept 50-352/89-16 on 890807-11.No Violations Noted ML20246D5641989-08-23023 August 1989 Forwards Corrective Action Insp Rept 50-353/89-201 During Wk of 890424 Re Independent Design Assessment.Assessment Provided Needed Addl Assurance That Plant Design Met Licensing Commitments ML20246N4111989-08-15015 August 1989 Forwards FEMA Rept on 890614 Plant Remedial Exercise.Rept Indicates That Deficiency Identified in Lower Pottsgrove Township During 880405 full-participation Exercise.Offsite Preparedness Adequate ML20245K0161989-08-11011 August 1989 Advises That 890403 Response to Generic Ltr 83-28,Item 2.1 Parts 1 & 2 Acceptable ML20245G1511989-08-10010 August 1989 Discusses Emergency Preparedness Insp Repts 50-352/89-11 & 50-353/89-17 on 890522-26 & 0607 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of 75,000 ML20245J8171989-08-0909 August 1989 Advises That Listed Schedule Should Be Used for All Emergency Exercises,Including Submittal & Review of Objectives & Scenario Packages Prior to Exercise ML20245H7151989-08-0909 August 1989 Discusses Insp Rept 50-352/89-14 on 890629 & Forwards Notice of Violation.Insp Reviewed Circumstances Involving Transport of Contaminated Waste from Unit to Quadrex Recycle Ctr in Oak Ridge,Tn on 890620 ML20245G6721989-08-0808 August 1989 Forwards Environ Assessment & Finding of No Significant Impact Re Request for Exemption from 10CFR50.44(c)(3)(i) to Extend Permitted Time of Operation W/Noninerted Containment Until Completion of 100 H Warranty Run ML20248C3571989-07-31031 July 1989 Forwards Request for Addl Info Re Consideration of Severe Accident Mitigation Design Alternatives.Response Requested within 30 Days of Ltr Receipt ML20248D8901989-07-28028 July 1989 Forwards Safety Insp Repts 50-352/89-12 & 50-353/89-19 on 890529-0625 & Notice of Violation.Fire Protection Issues, Discussed in Section 3.1,may Represent Potential Enforcement Issues NUREG-1371, Forwards Tech Specs,NUREG-1371,issued by NRR Re Application for Ol.W/O Stated Encl1989-07-25025 July 1989 Forwards Tech Specs,NUREG-1371,issued by NRR Re Application for Ol.W/O Stated Encl ML20247N4761989-07-25025 July 1989 Forwards Enforcement Conference Rept 50-352/89-14 on 890717. Apparent Violation Noted in Insp Rept 50-352/89-14 Re Area of Transportation of Radioactive Matl Discussed ML20246N1801989-07-13013 July 1989 Forwards Preoperational Insp Rept 50-353/89-20 on 890530- 0621.Programs Adequate to Support Testing & Startup ML20246N4171989-07-12012 July 1989 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-352/89-80 & 50-353/89-80 ML20246K5461989-07-11011 July 1989 Forwards Reactive Safety Insp Rept 50-352/89-14 on 890629. Violations Noted.Concern Expressed Re Lack of Control in Area of Properly Packaging Matl to Ensure External Radiation Levels Mantained.Enforcement Conference Scheduled ML20246G2921989-07-0707 July 1989 Forwards Safety Insp Rept 50-353/89-21 on 890530-0602.No Violations Noted ML20246F5911989-07-0606 July 1989 Forwards to Ecology Ctr of Southern California Re Petition to Fix or Close All Nuclear Power Reactors Designed by Ge.Ltr Ack Receipt of Petition Filed by Ecology Ctr & States Petition Filed Under 10CFR2.206 NUREG-1360, Forwards Tech Specs,NUREG-1360 & Sser 8 Re Application for OL for Unit 2.W/o Encl1989-07-0303 July 1989 Forwards Tech Specs,NUREG-1360 & Sser 8 Re Application for OL for Unit 2.W/o Encl ML20246B6061989-06-27027 June 1989 Ack Receipt of Re Alleged Discrimination Against Employee for Engaging in Protected Activities.Nrc Considers Matter Closed by Review of Info ML20245F0401989-06-22022 June 1989 Forwards License NPF-83 Authorizing Fuel Loading & Precriticality Testing of Util & Fr Notice.Amend 4 to Indemnity Agreement B-101 Also Encl ML20245H6901989-06-21021 June 1989 Forwards Safety Insp Repts 50-352/89-11 & 50-353/89-17 on 890522-26 & 0607.Violations Noted.Enforcement Conference Will Be Held on 890705 to Discuss Operators Inability to Properly Classify Certain Events During walk-through Exams ML20245F2941989-06-20020 June 1989 Approves Util 880621 Power Ascension Test Program for Facility,Per Reg Guide 1.68,for Execution ML20245E6141989-06-20020 June 1989 Forwards SER Accepting Util 890331 & 0602 Responses to NRC Bulletin 88-005, Nonconforming Matls Supplied by Piping Supplies,Inc at Folsom,Nj & West Jersey Mfg Co at Williamstown,Nj ML20245F2991989-06-16016 June 1989 Forwards Safety Insp Rept 50-353/89-23 on 890605-07.No Violations or Deviations Noted 1990-09-28
[Table view] Category:OUTGOING CORRESPONDENCE
MONTHYEARML20212J6561999-09-29029 September 1999 Informs of Completion of mid-cycle PPR of Limerick Generating Station on 990913.Identified No Areas in Which Licensee Performance Warranted Addl Insp Beyond Core Insp Program.Historical Listing of Plant Issues Encl ML20216F7821999-09-16016 September 1999 Forwards Insp Repts 50-352/99-05 & 50-353/99-05 on 990713-0816.One Violation Noted & Being Treated as NCV, Consistent with App C of Enforcement Policy.Violation Re Inoperability of Automatic Depression Sys During Maint ML20212A8751999-09-13013 September 1999 Forwards Safety Evaluation of First & Second 10-year Interval Inservice Insp Plan Request for Relief ML20211N5061999-09-0909 September 1999 Forwards TSs Bases Pages B 3/4 10-2 & B 3/4 2-4 for LGS, Units 1 & 2,being Issued to Assure Distribution of Revised Bases Pages to All Holders of TSs ML20211P8571999-09-0808 September 1999 Forwards Reactor Operator Retake Exams 50-352/99-303OL & 50-353/99-303OL Conducted on 990812 ML20211P3891999-09-0303 September 1999 Informs That During 990902 Telcon Between J Williams & B Tracy,Arrangements Were Made for NRC to Inspect Licensed Operator Requalification Program at Plant.Insp Planned for Wk of 991018 ML20211H2571999-08-26026 August 1999 Informs of Individual Exam Result on Initial Retake Exam on 990812.One Individual Was Administered Exam & Passed ML20210T4271999-08-13013 August 1999 Informs That NRC Revised Info in Rvid & Releasing Rvid Version 2 as Result of Review of 980830 Responses to GL 92-01 Rev 1,GL 92-01 Rev 1 Suppl 1 & Suppl Rai.Tacs MA1197 & MA1198 Closed ML20211B7881999-08-10010 August 1999 Transmits Summary of Two Meetings with Risk-Informed TS Task Force in Rockville,Md on 990514 & 0714 ML20210U2211999-08-10010 August 1999 Forwards Insp Repts 50-352/99-04 & 50-353/99-04 on 990525-0712.One Violation Occurred & Being Treated as NCV, Consistent with App C of Enforcement Policy.Violation Re Late Performance of off-gas Grab Sample Surveillance ML20210P4191999-08-0404 August 1999 Forwards Initial Exam Repts 50-352/99-302 & 50-353/99-302 on 990702-04 (Administration) & 990715-22 (Grading).Six of Limited SRO Applicants Passed All Portion of Exam NUREG-1092, Informs J Armstrong of Individual Exam Results for Applicants on Initial Exam Conducted on 990702 & 990712-14 at Facility.All Six Individuals Who Were Administered Exam, Passed Exam.Without Encls1999-08-0303 August 1999 Informs J Armstrong of Individual Exam Results for Applicants on Initial Exam Conducted on 990702 & 990712-14 at Facility.All Six Individuals Who Were Administered Exam, Passed Exam.Without Encls ML20196J6301999-07-0101 July 1999 Requests Addl Info Re Status of Decommissioning Funding for Limerick Generating Station,Units 1 & 2,Peach Bottom Atomic Power Station,Units 1,2 & 3 & Salem Nuclear Generating Station,Units 1 & 2 ML20212J5401999-06-28028 June 1999 Discusses Completion of Licensing Action for NRC Bulletin 96-003, Potential Plugging of ECC Suction Strainers by Debris in Bwrs. Bulletin Closed for Unit 2 by NRC ML20196G7041999-06-24024 June 1999 Forwards Insp Repts 50-352/99-03 & 50-353/99-03 on 990413- 0524.No Violations Noted.Nrc Concluded That Licensee Staff Continued to Operate Both Units Safely ML20206Q5871999-05-14014 May 1999 Advises That Info Contained in ,Which Submitted Revised Procedures for Plant EP Response Procedures Will Be Withheld from Public Disclosure,Per 10CFR2.790(a)(6) ML20206R3031999-05-11011 May 1999 Informs That on 990407,NRC Administered GFE Section of Written Operator Licensing Exam to Employees of Facility. Forwards Copies of Both Forms of Exam,Including Answer Keys & Grading Results of Facility ML20206N1111999-05-0707 May 1999 Forwards Insp Repts 50-352/99-02 & 50-353/99-02 on 990302-0412.Three Violations of NRC Requirements Occurred & Being Treated as non-cited Violations,Consistent with App C of Enforcement Policy ML20206H2651999-05-0606 May 1999 Informs That on 990112 Licensee Submitted to NRC Core Shroud Insp Plan for Plant,Unit 2,in Response to GL 94-03, Intergranular Stress Corrosion Cracking of Core Shrouds in Boiling Water Reactors ML20206G5131999-05-0303 May 1999 Approves Change of Completion Date for Implementation of Thermo-Lag Fire Barrier Corrective Actions at Plant from End of April 1999 Limerick Unit 2 RFO to 990930 ML20206H8301999-04-30030 April 1999 Forwards Exam Repts 50-352/99-301 & 50-353/99-301 on 990312-19 (Administration) & 22-26 (Grading).Four of Five RO Applicants & Three of Four SRO Applicants Passed All Portions of Exams ML20206E6951999-04-30030 April 1999 Advises That Plant,Unit 2 Cycle 6 Safety Limit Mcpr, ,contained in PECO Energy Co 990311 Application & 990204 Affidavit Will Be Withheld from Public Disclosure,Per 10CFR2.790 ML20206F4221999-04-27027 April 1999 Informs of Individual Exam Results for Applicants on Initial Exam Conducted on 990312 & 990315-19 at Facility.Completed ES-501-2,power Plant Licensing Exam Results Summary & Summary of Overall Exam Results Encl.Without Encl ML20205N2291999-04-0909 April 1999 Discusses Limerick Generating Station Plant Performance Review Conducted for Period April 1998 Through 990115 & Informs of NRC Planned Insp Effort Resulting from Review. Historial Listing of Plant Issues,Encl IR 05000352/19980091999-03-30030 March 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-352/98-09 & 50-353/98-09 Issued on 990106.Actions Will Be Examined During Future Insp of Licensed Program ML20205C2711999-03-26026 March 1999 Forwards Insp Repts 50-352/99-01 & 50-353/99-01 on 990112-0301.One Violation Noted & Being Treated as Non-Cited Violation.Staff Conduct of Activities During Insp Generally Characterized by Safe & Conservative Decision Making ML20205G7651999-03-22022 March 1999 Forwards RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs, for Plant, Units 1 & 2.Response Requested within 90 Days of Receipt of Ltr ML20204G9721999-03-11011 March 1999 Informs of Completion of Review of Changes Proposed by PECO Energy Co to Lgs,Units 1 & 2,EALs.Proposed EALs Incorporate Guidance in NUMARC/NESP-007,Rev 2.Forwards Safety Evaluation Supporting Proposed Changes ML20204H8171999-03-10010 March 1999 Discusses Request That NEDC-32645P, Limerick Generating Station,Units 1 & 2,SRV Setpoint Tolerance Relaxation Licensing Rept, Rev 2,dtd Dec 1998,be Withheld from Public Disclosure.Determined Info Proprietary & Will Be Withheld ML20207J0611999-03-0808 March 1999 Provides Authorization to Administer Initial Written Exams to Listed Applicants on 990312.NRC Region I Operator Licensing Staff Will Administer Operating Tests on 990315-19 at Limerick Generating Station ML20203G6721999-02-17017 February 1999 Second Partial Response to FOIA Request for Documents. Records in App D Encl & Being Made Available in Pdr.App E Records Being Withheld in Part (Ref FOIA Exemption 5) & App F Records Completely Withheld (Ref FOIA Exemptions 6 & 7) ML20203B9001999-02-0808 February 1999 First Partial Response to FOIA Request for Documents. Forwards Documents Listed in App a Already Available in PDR, Documents in App B Released in Entirety & Documents in App C Being Withheld in Part (Ref Exemption 6) ML20202J0261999-02-0303 February 1999 Informs of Completion of Licensing Action for NRC Bulletin 96-03, Potential Plugging of Emergency Core Cooling Suction Strainers by Debris in Boiling-Water Reactors ML20203A6111999-01-22022 January 1999 Confirms 990115 Conversation Between Mj Williams & P Orphanos Re Arrangements Made for Administration of Licensing Exam at Limerrick Generating Station & Peach Bottom Atomic Power Station During Week of 990705 ML20199F9251999-01-11011 January 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-352/98-05 & 50-353/98-05 ML20199C6501999-01-0606 January 1999 Forwards Insp Repts 50-352/98-09 & 50-353/98-09 on 981018- 1130 & Notice of Violation.Violation of Concern Because Technicians Exercised Poor Judgement & Deviated from Procedure in Attempt to Resolve Problem Without Mgt ML20198H4951998-12-18018 December 1998 Forwards Results of Audit of Licensee Year 2000 Program for Limerick Generating Station,Units 1 & 2 ML20198A3721998-12-10010 December 1998 Forwards Safety Evaluation Re Licensee Response to GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves ML20198B1751998-12-0808 December 1998 Advises of Planned Insp Effort Resulting from Limerick mid-year Insp Resource Planning Meeting Held on 981110. Historical Listing of Plant Issues & Details of Insp Plan for Next Six Months Encl IR 05000352/19980081998-11-23023 November 1998 Discusses licensee-identified Issue Involving Potential for Bypass of Suppression Pool as Documented in Insp Repts 50-352/98-08 & 50-353/98-08.NOV Will Not Be Issued & Civil Penalty Will Not Be Proposed ML20196C3311998-11-23023 November 1998 Forwards Insp Repts 50-352/98-08 & 50-353/98-08 on 980901-1017.No Violation Identified.Security Program Insp Identified That Security Program Effectively Protects Public Health & Safety ML20195D1491998-11-13013 November 1998 Forwards RAI Re on-going Review of IPEEE Submittal Dtd 951014.Understands That Licensee Will Inform NRC in Writing, by 981130,on How Question Re Effects of New Probable Max Precipitation at Plant,Units 2 & 3 Will Be Addressed IR 05000352/19980061998-10-15015 October 1998 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-352/98-06 & 50-353/98-06 on 980826.Finds C/As for Violation Involving Failure to Select Performance Measures to Be Acceptable ML20154F8191998-10-0101 October 1998 Forwards Notice of Withdrawal of 960503 & Suppl Application for Amend to Fols.Amend Would Have Modified Facility TSs Pertaining to Rev to Frequency of Testing Stand Gas Treatment Sys & Reactor Encl Recirculation Sys ML20154A3461998-09-25025 September 1998 Forwards Insp Repts 50-352/98-07 & 50-353/98-07 on 980707-0831.No Violations Noted.Weaknesses Noted with Reactor Engineering Support to Rod Pattern Adjustment ML20153G4291998-09-24024 September 1998 Forwards Request for Addl Info Re Licensee Revised Emergency Action Level Guidelines for Limerick Generating Station, Units 1 & 2 & Peach Bottom Atomic Power Station,Units 2 & 3. Response Requested within 30 Days of Receipt of Ltr ML20153D0151998-09-21021 September 1998 Informs of Completion of Licensing Action for GL 92-08, Thermo-Lag 330-1 Fire Barriers, for Plant, Units 1 & 2 ML20151X2421998-09-11011 September 1998 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-352/98-04 & 50-353/98-04 on 980805 ML20151W9601998-09-10010 September 1998 Informs That as Part of NRC PRA Implementation Plan, Commission Has Assigned Two Senior Reactor Analysts (Sras) to Each Regional Ofc.T Shedlosky & J Trapp Were Selected as SRAs for Region I ML20237D5421998-08-26026 August 1998 Ack Receipt of & Fee for $55,000 in Payment for Civil Penalty Proposed by NRC in .C/As Will Be Examined During Future Insps 1999-09-09
[Table view] |
See also: IR 05000352/1989080
Text
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-JUL 12' 1989
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- Docket.Nos; 50-352.-
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, ;50.-353
' Philadelphia Electric Company.
' ATTN: Mr. C. ~ A. McNeill', ~Jr.
. Executive Vice' President
Nuclear- - !-
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. Correspondence ~ Control Desk
P. O. Box.7520' ,.
Philadelphia, PA. 19101-
Gentlemen:
-Subject: Combined Inspection 50-352/89-80 and 50-353/89-80
~
This: refers to your letter dated May 8,1989,:in response to our = letter
dated March 23, 1989
'Thank'you for.'qforrring es of'the corrective and preventive. actions' documented
in your letter' . Those setions will be examined during a~ future inspection of-
.your licensed program.
;Your cooperation with us is appreciated.
Sincerely,
. Original Signed BY8
P. K. Eopen
Jacque P. Durr, Chief
. Engineering ' Branch
Division of Reactor. Safety.
.cc,w/ enc 1:
J. S. Kemper,'Sr., Senior Vice President - Nuclear Construction
G. _M. Leitch, Vice President - Limerick Generating Station
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S. J. Kowalski, Vice' President - Nuclear Enginee' ring
.
D. R. Helwig, General Manager - Nuclear Servcies
M. J. McCormick, Jr.,: Manager - Limerick Generating Station
W.' T. Ullrich, Manager . Limerick Unit 2 Startup
A. S~. MacAinsh, Manager '- Limerick Quality Division
l0 G. A Hunger, Jr. , Director - Licensing Section
l T. B. Conner, Jr. , Esquire
E. J. Bradley, Esquire, Assistant General Counsel
H..D. Honan,-Branch Head -~ Nuclear Engineering Licensing
-
.
Public Document Room (PDR)
l Local Public Document Room (LPDR)
L Nuclear Safety Information Center (NSIC)
NRC Resident' Inspector
Commonwealth of Pennsylvania
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: PHILADELPHIA ELECTRIC COMPANY
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LIMERICK GENERATING ST ATION
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SAN ATOG A. PENNSYLVANIA A 19464
(215) 3271200 sat. 2000
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M. J. M cCO M MIC K. 'J a.. P.E.
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6 .-3.fl'.".'.."l."$*.".m... 'May 8, 1989 -
Docket Nos. 50-352
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50-353
License No. NPF-39
Construction Permit No. CPPR-107
U.S. Nuclear Regulatory Commission
ATTN: Document Control Desk
-Washington, D.C. 20555
SUBJECT: Limerick denerating Station,-Units 1 and 2
Response:to Observed Weaknesses Noted in
Special Maintenance. Team Inspection
Report No. 50-352/89-80, 50-353/89-80
NRC letter dated March 23, 1989, transmitted Special
Maintenance: Team Inspection Report No. 50-352/89-80, 50-353/89-80
for the Limerick Generating Station, Units 1.and 2. .This letter
also requested that we address the noted weaknesses contained in
the report and outlined in Appendix 3.- The letter requested a
written response within.45 days to the noted items. Attached to
this letter is our-response to each observed weakness.
If you have any questions or require additional
information, please do not hesitate to contact us.
Very truly yours,
Ql 41 0
v
M. V. McCormick, Jr.
Plant Manager
DBN: kap
Attachment
cc: W. T. Russell, Administrator, Region I, USNRC
T. J. Kenny, USNRC Senior Resident Inspector
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Attachment 1
Page 1 of 11
NRC Inspection Report
50-352/89-80
50-353/89-80
Item 1
NRC Observed Weakness
Communications with offrite engineering organizations could be
improved (Ref. II.4.1 {pg. 12}).
Response
Regarding the general issue of communications between the
station and the offsite engineering organization, an update to the
response provided to NRC Inspection Report 50-352/88-20 is provided
below.
-The Engineering Work Request (EWR) process, implemented at
Limerick in 1989 has provided engineering support for station
requests in such areas as Licensee Event Reports (LERs), Equipment
Qualification (EQ) evaluations, potential deportability and
operability evaluations, and specific design related questions. The
EWR process is being tracked and trended along with the !
Non-Conformance Report (NCR) and Engineering Review Request Form
(ERRF) processes using the Nuclear Engineering Task Tracking (NETT)
system. Over 600 individual Limerick requests have been responded
to by Engineering between January and April 1989.
The status of the tracking and trending is reported monthly in
the Senior Management Report (SMR) and includes information
regarding timeliness of responses, total requests processed and the
current backlog of requests. This report is discussed monchly with
the nuclear group vice-presidents and their direct reports.
Six deu cated engineering personnel have been located onsite and
additional engineering resources are located at the
Architect / Engineer's (A/E's) Pottstown, Pennsylvania office. An i
Engineering project management staff, located at the site, {
coordinates and tracks each individual request using the NETT j
process and ensures effective communications between the station and ]
the offsite engineering organizations. Members of the staff attend j
the daily routine plant meetings (e.g. morning meeting, TRIPOD, j
PORC) and provide needed support. Our goal is to locate i
approximately ten individuals from the engineering organization at I
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the site by the end of December 1989.
The station engineering personnel have been trained on how to
properly complete an EWR to ensure that station requests for
engineering support clearly identify needs and expectations. This
will help provide effective use of the EWR thereby,providing
effective communications. l
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Page 2 of 11
NRC Inspection Report .
50-352/89-80 .
50-353/89-80 )
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. Periodic meetings between station and engineering management 1
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were held on a bi-weekly basis during the outage and are presently !
scheduled to continue to be held on a monthly basis after the 1
outage. These meetings have been effective in prioritizing and j
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resolving problems which require engineering support.
Potentially reportable issues identified by the offsite i
engineering organization are communicated to the station regulatory
personnel by way of a Deportability Evaluation Form (REF). Station .
management can then evaluate the need for compensatory or other
required actions, to make any required notifications, and to request
additional engineering support utilizing the EWR process. This
mechanism has provided effective communications between the offsite l 1
engineering organization and station personnel such that potential
deportability / equipment operability concerns are raised to station !
operations personnel in a timely manner. !
Some examples of recent effective engineering support and
com.nunication between the offsite engineering organization and
station personnel especially in the area of maintenance include 1)
investigation and evaluation of the jet pump riser nozzle crack and
design of modifications to install crack monitoring equipment, 2)
development of the test procedure and design of the required
modifications for the main turbine torsional testing, 3)
investigation and evaluation of indications on the Low Pressure
Turbine blades, 4) design of a modification to relocate the
Suppression Pool Temperature Monitoring System (SPTMS) temperature
probes, 5) the project task force which is reviewing and resolving
problems identified during the review of the 10CFR50 Appendix R
related fire protection issues, and 6) the establishment of periodic
Service Water System Reliability Group meetings involving
engineering and station personnel.
In conclusion there is clear evidence that there are improved
communications between the offsite engineering organizations and the
station staff.
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Attachment 1
Page 3 of 11
NRC Inspection Report
50-352/89-80
50-353/89-80
Item 2
NRC Observed Weakness: .
The operability of the HPCI room unit coolers was a concern in
view of the ESW piping corrosion and no periodic performance test
for these coolers. (Ref. II.4.2 (pg. 14})
Response
During the Unit 1 Second Refueling Outage the NRC inspector
observed several activities related to Emergency Service Water (ESW)
system valve and pipe replacements including the High Pressure
Coolant Injection (HPCI) system room unit cooler supply piping.
This planned modification work was-being done to increase supply
piping sizes to several ESW components to allow for aging
degradation of this piping. During this pipe replacement,
significant pipe corrosion was observed in the removed piping. The
NRC inspector questioned the future operability of the HPCI room
unit coolers in light of the observed corrosion.
4
During the pipe replacement work, pipe friction coefficients
were estimated and incorporated into a computerized ESW system flow
network model. Engineering and the Architect / Engineer analyzed the
ESW model using the new data and new piping sizes and determined
that a successful two unit ESW flow balance could be achieved.
The two unit flow balances were performed during the Unit 1
Second Refueling / Unit 2 Tie-In Outage and proved ESW is capable of
providing adequate flows to all components in both units including
the HPCI room coolers for all six acceptance criteria modes. An
additional mode proved both ESW loops could independently support
eight diesel generators while providing the required' flows to both
units' safety related heat exchangers.
To ensure the ESW system will continue to meet its required
demands and support operability, several actions have been and will
be taken. A solution to the general ESW piping corrosion issue is
described under item 3 of this attachment. Quarterly flow balancing
of the ESW system will be performed and piping and components will ,
be periodically inspected. In addition, the Technical Specification
required quarterly ESW pump performance test will be performed and
pump capacity performance will be monit: red and evaluated. A
further description of the quarterly flow balancing and component
inspection program is described below.
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Page-4 of 11
NRC Inspection Report
-50-352/86-80
50-353/89-80
Routine ESW flow balances tests RT-1-Oll-251-0 and
RT-1-011-252-0 will be performed quarterly. The procedures were
based on the flow balances performed as part of the two unit flow '
balance test program. They have beenspecifically-designed to
closely monitor ESW components with marginal performances observed
in'the two unit flow balance test program. .-Every quarter, potential
' problem' components will be tested. Included in this category.will
be all Residual Heat Removal (RHR) system. pump seal coolers, RHR
motor oil coolers, the Unit 1 HPCI room coolers, and the Unit 2
Reactor Core Isolation Cooling (RCIC) system room coolers. These
. components are more'likely to become ' problem' components because of
their piping configurations. The remaining components will be
tested a minimum of once during each cycle as part of the scheduled
. quarterly tests. Acoustic flow monitors will be used to verify the
accuracy of the procedure. Acoustic flow testing will be performed
on any component with unusually high differential pressure (DP)
readings and on coolers with a past history of fouling. This
redundant verification will ensure that we maintain a close watch on
potential problems.
Every refueling outage, Maintenance will perform visual
inspections of ESW and Service Water pipe and components via the
Preventive. Maintenance Program. Once again, ESW components
identified to have a. potential problem such as RHR seal coolers,
Unit'l HPCI room coolers.and Unit 2 RCIC room coolers will be
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inspected each refueling outage. In addition, any component that
experienced poor performance in the quarterly flow balances will be
inspected. The piping associated with the inspected coolers will
also be inspected. Flow balances will establish a constant
reference point of ESW flow versus total system dynamic head. Each
quarter this will be compared with past results and the data
obtained will be used to monitor pipe fouling. Low DP readings on
heat exchangers during the flow balances could also indicate low
flow conditions due to flow restrictions. The computerized ESW
system flow network model will be utilized in the ESW monitoring
program. The monitoring program will enable us to predict system
performance and potential problems. The monitoring program will be
continually evaluated and modified as necessary to ensure continued
system operability.
Item 3
NRC Observed Weakness: l
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A comprehensive solution to the ESW piping corrosion issue was
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not yet well defined. (Ref. II.4.2 {pg. 15})
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NRC Inspection Report
50-352/89-80 ,
50-353/89-80
Response
Based.on observations of service. water system components prior
to-commercialfoperation of Unit 1, a service water / circulating water
(cooling tower) chemical treatment program was developed. The
program was developed to limit corrosion, deposition and
microbiological fouling in circulating water, service water.and
portions of ESW. This treatment system was installed and made
operational shortly after commercial' operation (after receipt of the
required NPDES permit from the Pennsylvania Department of
Environmental Resources). Provisions for corrosion rate monitoring,
using corrosion coupons, were included in the scope of this
installation. It was recognized that, although reductions in
corrosion rates were expected, further corrosion protection could.be
achieved with clean pipe surfaces. We therefore began to
investigate cleaning alternatives in parallel with instituting the
corrosion treatment program and periodically monitoring the
effectiveness of the program using the corrosion coupons, an
instantaneous corrosion monitor, and individual component
inspections (conducted as components are isolated and opened due to
maintenance activities).
Due to the amount of piping involved in these systems, and the
isolation / availability constraints and outage schedule limitations
associated with mechanical cleaning, chemical cleaning techniques
.were pursued. A chemical cleaning technique was identified and
. testing was' conducted, using samples of service water piping removed
from Limerick. Although this two step chemical cleaning process
(deposit softening followed by mild acid wash) was demonstrated to
be effective in a similar application at another utility, it was not
effective in removing Limerick's deposits. Investigations into
chemical cleaning techniques continued into cycle 2 for Unit 1. An
alternate cleaning program has been identified similar to the
previously_ tested two step program, which based on recent successful
application in a similar application has proven effective. We plan
to test this program using ESW piping samples removed during the
second Refueling Outage.
In addition, during a design review prior to the Unit 1 First
Refueling Outage, we recognized that due to normal aging (corrosion
degradation) of the pipe, there would not be sufficient system flows j
to support 2 unit operations and some ESW supply piping would need '
to be replaced. During the First Refueling Outage, sections of
piping in the 'A' loop of ESW were replaced with larger diameter
piping. Inspection and testing of the piping replaced during this
outage indicated that a corrosion problem existed in small ESW
lines, specifically the one-inch diameter piping to the RHR pump
seal coolers and RER motor oil coolers, but was not evident in the
larger diameter piping inspected or replaced.
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Attachment 1
Page 6 of 11
NRC Inspection Report
50-352/89-80
50-353/89-80
During the Second Refueling Outage, secticns of piping of the
'B' loop of ESW were replaced for the aging concern described above.
The new piping was passivated with a high concentration of corrosion
inhibition chemicals prior to wetting. Passivation is a chemical
treatment applied to the inner metal surface of the piping to
inhibit corrosion. The removed sections of pipe contain similar
amounts of corrosion as contained in the 'A' loop piping removed 18
months earlier with the exception of the HPCI room unit cooler
piping. The 'A' loop piping replaced during the first refueling
outage was inspected and found to contain a very small amount of
corrosion after 18 months of service. Evaluation of the corrosion
monitoring data and the observations made during the second
Refueling Outage indicate that the corrosion rate within the ESW
piping has been reduced. Samples of the deposits obtained from the
ESW piping were analyzed and the results indicate that the fouling
problem is caused by general iron corrosion products and not from
silt / mud deposition, microbiological fouling or microbiological 1y
influenced corrosion.
Based upon the chemical analysis results, ESW system
inspections, and several tests involving the service water system
(which normally supplies the ESW piping and components), we have
determined the causes of the ESW system fouling to be the following:
'l . Ineffective layup practices during plant construction and
testing phase which resulted in prolonged periods of exposure
of the piping to raw water in stagnant or intermittent flow
conditions. This resulted in high corrosion rates and
deposition / accumulation of the corrosion products on the pipe
surface.
2. An effective cleaning program was not identified and
implemented coincident with the chemical treatment program.
This limited the effecti"oness of the chemical treatment.
3. Although the cooling tower corrosion treatment program does l
provide some corrosion protection of ESW, isolation of )
certain ESW components and low or intermittent flow '
conditions when in standby mode further limit this
protection.
Chemical treatment of the service water and ESW systems has been
recently upgraded to provide enhanced dispersant and anti-corrosion
chemicals. Initial results of this upgraded treatment program
indicate even lower corrosion rates than achieved during the !
previous treatment program. A study is in progress to determine the ;
feasibility of a targeted biocide and corrosion inhibitor program to !
address the corrosion problems during stagnant / intermittent !
operating conditions present in the ESW and Residual Heat Removal l
Service Water (RHRSW) systems. A Service Water System Reliability
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Page 7 of.ll
NRC Inspection' Report
50-352/89-80
50-353/89-80
Group, composed of onsite and offsite engineering and technical
: personnel, was initiated in December,-1988, to identify and address
specific Service Water and ESW problems.
. These actions will provide the comprehensive solution to the ESW
piping corrosion issue.
Item 4
NRC Observed Weakness:
Deletion of QC witness points in certain maintenance procedures
without specific guidance (Ref. II.4.4 {pg. 18}).
Response::
The weakness identified as the process for deleting QC witness
points =was recognized by NQA during the NRC inspection and
appropriate 1 corrective measures were taken at that time. As stated
in the Inspection Report, the problem stemmed from the efforts to
increase accountability for quality at the worker level and sharpen
the focus of QC on the more critical aspects of the work activities.
Without formal guidance to accomplish this, QC witness points were
inconsistently applied and, in some instances, appropriate QC
witness points had been deleted from certain procedures along with
those that were. unnecessary. During the NRC inspection, a~ review
was initiated by the QC Division which determined that of
approximately 700 Maintenance Procedures, seventy-seven (77) were
revised without the specific guidance being in place. These seventy
seven procedures were reviewed and eleven (11) required revision to
reinstate the appropriate QC witness points which were inadvertently
deleted. The eleven procedures including the emergency diesel;
engine and motor control center preventive maintenance procedures
identified by the NRC inspector were appropriately revised prior to
performance of any work activities utilizing them. i
As committed to during the inspection, formal guidance for
y determining QC points for specific work activities has been
l proceduralized. Maintenance Guideline No. 28, titled
" Identification of Quality Control Witness Points" and a supplement
to the QC Inspection Program Procedure, Supplement NQA-4-SlA,
" Determination of QC Action Points", provide the formal guidance to
the maintenance procedure writer and QC procedure reviewer for
determining when QC witness points are to be included in the
electrical and mechanical preventive maintenance procedures.
Supplement NOA-4-SlA is expected to be formally issued by June 30,
1989.
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' Item-5'
NRC Observed Weakness: F
Low' Level-QA/QC involvement in the ESW piping corrosion issue.
(Ref. .II.4.4 {pg. 19))
. Response
The ESW piping system corrosion problem had been previously
identified during flow balancing of the ESW system during
pre-operational testing. A flow network analysis was performed-to.
aid in flow balancing and modifications were initiated to ensure.
that no unacceptable flow restrictions existed as the ESW piping
aged. . These modifications were identified and substantiated by
written Safety Evaluations and Plant Operating Review Committee
revi'ews.
During the course of on going ESW piping modifications, QC-
inspection personnel questioned the acceptability of the ESW piping
corrosion.
'
However, in the absence of specific cleanliness .
acceptance criteria in the governing specification, and in light'of
the on-going. modifications, flow network ' analysis -and engineering
study, NQA management ' and QC supervision felt that the ESW corrosion'
problem was adequately identified and controlled and concluded that
it was not necessary to issue nonconformance reports..
In order to avoid recurrence in situations where the involvement
of the' appropriate personnel would not be as evident, supplement to
NOA-QC inspection procedures are being developed to more clearly.
define' cleanliness acceptance' criteria for plant operating systems.
These crite ia sill include loss of cross-sectional area that could
impair or pronibit mechanical piping system components.such as' check
! valves, coolers or heat exchangers from performing their. intended
function. The supplemental inspection procedures are expected to be
issued by. June 2, 1989. These criteria will be used to determine
the acceptability of internal cleanliness conditions.of plant piping
systems and if not met will be the basis for issuance of Equipment
Trouble Tags (ETT's) or Nonconformance Reports (NCR's) in accordance
with procedure NOA-24 " Control of Hardware Non-Conformances" (now
NGAP NA-03N001).
In addition, a committee has been appointed by the NOA-General
Manager to revise NOA-24 (NGAP NA-03N001) to ensure that ambiguity
will not exist in the procedure regarding nonconforming conditions
and the issuance of NCR's. The procedure revision is expected to be
completed by September 30, 1989.
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These, or any other nonconformances that are found to be
repetitive, shall be considered a significant nonconformance in
accordance NQA-24. As such, a Corrective Action Request shall_be
initiated to management attention in accordance with existing
procedure NOA-25, " Corrective Actions," to request a root cause
analysis and to determine corrective action to prevent recurrence.
Item 6
NRC Observed Weakness:
The lack of preparation of a Maintenance Procedure to support
lapping operations for D/G crankshaft bearings. (Ref. III.S.0 {pg.
25}).
Response:
The need for a bearing journal lapping procedure was previously
identified during the construction phase of Limerick Unit 2.
Bearing inspections were scheduled to be performed on all four Unit
1 emergency diesel generators (D/G's) during the Unit 1 second
refueling outage and during this inspection, journal lapping is not
normally required. In addition, there were no vibration problems
indicating that the journal bearings would need replacing and
journal lapping was not expected to be necessary during the second
refueling outage. Therefore, incorporation of journal lapping
instructions into permanent procedures was determined to be of a
lower priority than revision and enhancement of other procedures
required to support the Unit 1 Refuel Outage. During the overhaul
of the D12 D/G, journal lapping was identified to be required arid a
lapping procedure was generated shortly thereafter.
Journal lapping instructions are expected to be incorporated
into the appropriate permanent Maintenance Procedure (s) prior to
July 31, 1989.
1
Item 7
]
l
NRC Observed Weakness: l
1
i
Slow implementation of the PRA into the prioritization of )
maintenance work. (Ref. III.5.0 (pg. 27J) '
l
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Response:
Several factors inhibited early extensive use of the
Probabilistic Risk Assignment (PRA) in the maintenance process and
at Limerick in general. These included:
1) The lack of a comprehensive, living PRA that reflected the
as-built plant, and,
2) The lack of a user friendly PRA tool that would simplify and
expedite use of the.PRA.
The following describes actions taken over the past few years to
eliminate these factors:
1) The PRA originally performed in 1980 was reviewed during the
plant licensing process and updated in September 1982. Before
widespread use could be made of the PRA, the system models had
to be revised to reflect as-built designs. Also, station
operating procedures, that were non-existent in 1982, had to be
incorporated. The PRA was updated in August 1986 to reflect
Unit 1 as-built design and most of the emergency operating
procedures (i.e. the Transient Response Implementation Plan
(TRID) procedures). A second update was completed in November
1988 tict completed the incorporation of the TRIP procedures and
reflected two unit operation. Completion of this update
addresses the first factor providing Limerick with a
comprehensive, living PRA that reflects the as-built plant and
supports applications.
2) PRA applications in the past were limited due to the available
computer software that was difficult and cumbersome to use. In
1987, the Nuclear Engineering Department PRA Branch purchased a
personal computer (PC) workstation that streamlined the process
of modifying and using the PRA. The conversion of the PRA to
the workstation model was completed by November 1988. The PRA
work station was used to develop the PRA parameters (i.e. what
systems and equipment are PRA important and how they affect Core
Damage Frequency) to be utilized by the station PRA programs and
will be used by engineering to answer specific PRA based
questions from the station. The PRA workstation addresses the
'
second factor; it is the tool that was needed to simplify PRA
use and provide better responsiveness to PRA requests.
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With the above described improvements completed in November of
3988, Limerick has been able to develop several programs involving
the PRA. Specific to the prioritization of maintenance work, these
programs include Administrative Guidelines (AG) AG-42, "PRA
Applications in Plant Maintenance" and AG-43, " Guideline for the
Performance of System Outages." Following extensive training of
Limerick personnel, these programs became effective in January 1989
and have since then been implemented.
Item 8
NRC Observed Weakness:
The lack of adherence to an administrative procedure (A-26) resulted
in traceability problems of mechanical tools. (Ref. III.7.0 {pg.
36))
Response:
This problem had been identified prior to the inspection and the
Maintenance Request Form (MRF) had been changed in late 1988 to
allow recording of up to 15 tools versus 5 allowed on the old form.
On February 9, 1989, the next day following identification of the
problem by the NRC inspector, a meeting was held with the
maintenance department personnel. The importance of recording all
tools used during maintenance activities on the MRF was stressed in
the meeting. Continuing training for Maintenance personnel will
address the need to include calibrated tool serial numbers on the
MRF in order to provide traceability.
A review of all out of tolerance (OOT) tools is being performed.
Prior to January 1, 1988, Quality Assurance (QA) personnel recorded
all calibrated tools used on sa'.'ety related equipment in parallel to
the work activity. A similar traceability problem is net likely to
have occurred prior to January 1, 1988 nor after the meeting held on
February 9, 1989 and therefore the review will encompass the OOT
reports from the calibration facility received from January 1, 1988
to February 15, 1989. This review will compare the OOT tool
reports, the tool usage log and the referenced MRF's to ensure that
the OOT tools are properly identified on the MRF and that the affect
of the OOT tools have been evaluated. This review includes the nine
MRF's identified during the NRC inspection. Any deficiencies
identified during this review will be evaluated and corrected. In
addition, a maintenance guideline is being prepared for the control
of calibrated tools. All corrective actions are expected to be
completed by September 1, 1989.
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