ML20247J240

Notice of Violation from Insp on 980120-0316.Violations Noted:On 980213,significant Condition Adverse to Quality Identified & Previous C/A on Control of Locked Valves Did Not Preclude Repetition

ML20247J240
Person / Time
Site:	Limerick
Issue date:	05/11/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20247J230	List: ML20247J226 ML20247J240 ML20247J245
References
50-352-98-02, 50-352-98-2, 50-353-98-02, 50-353-98-2, NUDOCS 9805210374
Download: ML20247J240 (2)

Text

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ENCLOSURE 1 NOTICE OF VIOLATION PECO Energy Docket Nos. 50-352;50-353 Limerick Generating Station License Nos. NPF-39; NPF-85 Unit 1 and 2 During an NRC inspection conducted between January 20,1998, through March 16, 1998, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600,the violations are listed below:

A. 10 CFR 50, Appendix B, Criterion 16, " Corrective Action," in part, requires that j measures shall be established to assure that conditions adverse to quality, such as deficiencies, deviations, and non-conformances are promptly identified and corrected, in the case of significant conditions adverse to quality, the condition is determined and corrective action taken to preclude repetition. -

Contrary to the above, on February 13,1998, a significant condition adverse to quality was identified and previous corrective actions on the control of locked {

valves did not preclude repetition. Specifically, the Unit 1 suppression pool hatch )

PP-60-106, a primary containment boundary valve, was found unlocked during power operations.

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

B. Technical Specification (TS) 6.8.1 requires, in part, that written procedures shall be implemented covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Appendix A of Regulatory Guide 1.33, Revision 2, February 1978 recommends administrative procedures which include equipment control and procedures for surveillance tests. Licensee Procedure A-C-043, " Surveillance Testing Program,'" Steps 7.4.4 and 7.5.4, required that operability concerns be identified so that shift management can make an operability determination. OM-L-9.1-1, " Expectations / Conduct," step 2.4, requires that ST/RT performers must notify shift management immediately if unable to perform ST/RT satisfactorily or in its entirety. OM-L-12.2, Equipment Deficiencies / Potential Action Log," step 2.7, requires that "the equipment deficiency / potential action log entry should be closed out in accordance with Exhibit OM-L-12.2:2 when all associated deficiencies are corrected, and the equipment is properly tested and returned to service.

Contrary to the above, on November 18,1997, written procedures required by Appendix A of Regulatory Guide 1.33, were not implemented, in that, required operability concerns for Secondary Meteorological Tower were not identified to the shift management; performers did not notify shift management immediately when l they were not able to perform the surveillance test satisfactorily; and the equipment I 9905210374 990511 l l PDR ADOCK 05000352  ;

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5 Enclosure 1 2 deficiency log was closed out without all the deficiencies corrected. Specifically, the secondary meteorological tower 26' differential temperature monitor was declared operable despite the fact that all associated deficiencies had not been corrected prior to its return to service, l&C technicians did not explicitly discuss with operations staff these deficiencies, so that a proper operability determination could be made.

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

Pursuant to the provisions of 10 CFR 2.201, PECO Energy is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region I, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response mry reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. 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. Where good cause is shown, consideration will be given to extending the response time.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, 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 must specifically identify the portions of your response that you seek to have withheld and provide in 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 I level of protection described in 10 CFR 73.21.

Dated at King of Prussia, Pennsylvania this 11th day of May 1998.  !

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