ML20247J226

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Forwards Insp Repts 50-352/98-02 & 50-353/98-02 on 980120- 0316 & Notice of Violation.First Violation of Concern Because C/A from Previous Violation Inadequate & Locked Valve Controls Not Yet Effective
ML20247J226
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 05/11/1998
From: Hehl C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Danni Smith
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
Shared Package
ML20247J230 List:
References
50-352-98-02, 50-352-98-2, 50-353-98-02, 50-353-98-2, NUDOCS 9805210370
Download: ML20247J226 (5)


See also: IR 05000352/1998002

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May 11, 1998

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Mr. D. M. Smith, President

PECO Nuclear

Nuclear Group Headquarters

Correspondence Control Desk

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P. O. Box 195

Wayne, PA 19087-0195

SUBJECT:

NRC INTEGRATED INSPECTION REPORT 50-352/98-02,50-353/98-02

Dear Mr. Smith:

This refers to the inspection conducted on January 20,1998, through March 16,1998, at

your limerick Units 1 and 2 reactor facilities. The enclosed report presents the results of

this inspection.

During the eight-week inspection period covered by this report, the conduct of activities at

Limerick Units 1 and 2 was generally characterized by safe and conservative operations

and decision making. Overall your operators' response to the loss of shutdown cooling

event was appropriate and timely. The Unit 1 startup was well controlled with appropriate

operator response to anomalous plant conditions.

However, we identified examples of deficient operability assessments indicating

weaknesses in your operability determination process. For example, operators accepted

the intermittent cycling of the residual heat removal minimum flow valve. They failed to

promptly assess the impact of potentially degraded transistors in safety-related applications

and incorrectly assessed the high pressure coolant injection turbine exhaust valve as

operable.

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Based on the results of this inspection, the NRC has determined that violations of NRC

requirements occurred. These violations are cited in the enclosed Notice of Violation

(Notice) and the circumstances surrounding them are described in detail in the subject

inspection report. The first violation is of concern because your corrective actions from a

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previous violation were inadequate and your locked valve controls are not yet effective.

The second violation is of concern because it involves configuration control of technical .

specification required equipment and your evaluation incorrectly concluded that your staff's

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actions were consistent with the Operations Manual procedures. You are required to

respond to this letter and should follow the instructions specified in the enclosed Notice

when preparing your response. The NRC will use your response, in part, to determine

whether further enforcement action is necessary to ensure compliance with regulatory

requirements.

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9905210370 990511

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PDR

ADOCK 05000352

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0FFICIAL RECORD COPY

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D. M. Smith

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In addition, four apparent violations were identified in this report and are being considered

for escalated enforcement action in accordance with the " General Statement of Policy and

Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600. Repeat

failures of the 1B RHR minimum flow valve and the high pressure coolant injection turbine

exhaust valve, combined with the corrective action issues discussed in NRC Inspection

report 352:353/97-09.th::t involved the D21 emergency diesel generator catastrophic

failure, in aggregate indicate a corrective action problem. The failure to identify and

resolve the underlying degraded conditions led to inoperable systems or failed equipment.

Accordingly, no Notice of Violation is presently being issued for these inspection findings.

In addition, please be advised that the number and characterization of apparent violations

described in the enclosed inspection report may change as a result of further NRC review.

An open predecisional enforcement conference to discuss these apparent violations has

been scheduled for May 27,1998. The decision to hold a predecisional enforcement

conference does not mean that the NRC has determined that a violation has occurred or

that enforcement action will be taken. This conference is being held to obtain information

to enable the NRC to make an enforcement decision, such as a common understanding of

the facts, root causes, missed opportunities to identify the apparent violation sooner,

corrective actions, significance of the issues and the need for lasting and effective

corrective action. In addition, this is an opportunity for you to point out any errors in our

inspection report and for you to provide any information concerning your perspectives on

1) the severity of the violation (s),2) the application of the factors that the NRC considers

when it determines the amount of a civil penalty that may be assessed in accordance with

Section VI.B.2 of the Enforcement Pol lcy, and 3) any other application of the Enforcement

Policy to this case, including the exercise of discretion in accordance with Section Vll.

You will be advised by separate correspondence of the results of our deliberations on this

matter. No response regarding these apparent violations is required at this time.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter,

its enclosure (s), and your response will be placed in the NRC Public Document Room

(PDR).

Sincerely,

Original Signed by:

Charles W. Hehl, Director

Division of Reactor Projects

Docket Nos.: 50-352,50-353

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License Nos: NPF-39, NPF-85

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Enclosures:

1.

Notice of Violation

2.

NRC Inspection Report 50-352/98-02,50-353/98-02

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D. M. Smith

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cc w/encis:

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G. Edwards., Chairman, Nuclear Review Board and Director - Licensing

J. VonSuskil, Vice President - Limerick Generating Station

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J. L. Kantner, Manager, Experience Assessment

Secretary, Nuclear Committee of the Board

,

Commonwealth of Pennsylvania

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D. M. Smith

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Distribution w/encis:

Region I Docket Room (with concurrences)

H. Miller, RA/W. Axelson, DRA (irs)

C. Anderson, DRP

D. Florek, DRP

R.Junod,DRP

NRC Resident inspector

Nuclear Safety Information Center (NSIC)

PUBLIC

Distribution w/encis: (Via E-Mail)

8. McCabe, OEDO

R. Capra, PDI-2, NRR

Inspection Program Branch, NRR (IPAS)

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B. Buckley, PD 1-2, NRR

M. Thadani, PD 1-2, NRR

DOCDESK

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DOCUMENT NAME: G:\\ BRANCH 4\\ LIM \\ LIM 9802.lNS

'See previous concurrences

To receive a copy of this document, indicate in the box: "C" = Copy without

attachment / enclosure

"E" = Copy with attachment / enclosure

"N" = No copy

OFFICE

  • Rl/DRP

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  • Rl/DRP

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NAME

CAnderson

CHehl

DATE

05/

/98

05/ /98

OFFICIAL RECORD COPY

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D. M. Smith

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Distribution w/encls:

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Region i Docket Room (with concurrences)

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H. Miller, RA/W. Axelson, DRA (irs)

C. Anderson, DRP

D. Florek, DRP

R.Junod,DRP

NRC Resident inspector

Nuclear Safety information Center (NSIC)

PUBLIC

Distribution w/encis: (Via E-Mail)

B. McCabe, OEDO

j

R. Capra, PDl-2, NRR

inspection Program Branch, NRR (IPAS)

B. Buckley, PD 1-2, NRP.

M. Thadani, PD 1-2, NRR

DOCDESK

DOCUMENT NAME: G:\\ BRANCH 4\\ LIM \\ LIM 9802.lNS

To receive a copy of this document, indicate in the box: "C" = Copy without

attachment / enclosure

"E" = Copy with attachment / enclosure

"N" = No copy

OFFICE

Rl/DRP

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Rl/DRP,

NAME

CAnderson c$4

CHehlV

DATE

05/ 0 /98

05/ ///98

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OFFICIAL RECORD COPY

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