ML20248D904

Notice of Violation from Insp on 890529-0625.Violation Noted:Between 840911 & 890509,accumulators Failed to Maintain Pressure During Testing Per Tech Specs But Not Declared Inoperable & Calibr Incorrectly Performed

ML20248D904
Person / Time
Site:	Limerick
Issue date:	07/28/1989
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20248D894	List: IR 05000352/1989012 ML20248D890 ML20248D904
References
50-352-89-12, NUDOCS 8908110165
Download: ML20248D904 (2)

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APPENDIX A NOTICE OF VIOLATION Philadelphia Electric Company Docket No. 50-352 Limerick Unit I License No. NPF39 As a result of an inspection conducted on May 29-June 25, 1989, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, 53 Federal Register 40019 (October 13, 1988), the violations are listed below:

A. Plant Technical Specification 3.1.3.5 requires that all control rod scram accumulators shall be operable in operational conditions 1, 2 and 5. If one or more control rod scram accumulators are determined to be inoperable the appropriate Action specified in Technical Specification 3.1.3.5 shall be taken. Additionally Technical Specifications (TS) 4.1.3.5.6.2 requires each control rod scram accumulator shall be determined operable at least once per 18 months by:

Measuring and recording the time for up to 10 m'r.utes that each individual accumulator check valve maintains the associated accumulator pressure above the alarm set point with no control rod drive pump operating.

Contrary to the above on six documented occasions between September 11, 1984 and May 9, 1989 accumulators failed to maintain pressure during the testing required by TS 4.1.3.5.6.2 and were not declared inoperable nor were TS 3.1.3.5 actions taken.

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

B. Technical Specification 6.11, " Radiation Protection Program", requires in part, that procedures shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.

8.1. Procedure RW-630, " Control of HEPA Ventilation Units," Rev. 1, requires, in part, in Section 6.14, that during use, each operating HEPA Ventilation Unit will be checked at the indicated frequency by Health Physics Technicians providing job coverage to ensure the differential pressure across each filter is still within the acceptable range. The readings will be recorded on the Portable Ventilation Unit Inspection Form (PVUIF).

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Contrary to the above, on May 26, May 30, May 31, and June 2, 1989, Health Physics Technicians providing job coverage under Radiation Work Permits (RWPs) 89-5589 and 89-5619,. failed to ensure that the differential pressure across each filter was within the acceptable range for HEPA Ventilation Unit LGS 1003-4 during each use as required by the PVUIF.

B.2. Procedure HP-310,'" Radiation Work Permits," Rev. 16, requires, in part, in Section 6.1.1, that an RWP .is required for all entries into areas which are posted."RWP Required for Entry."

Contrary to the above, on June 13, 1989, a Health Physics Technician entered Hot Machine Shop Tent #2, posted "RWP Required for Entry",

without signing in on an RWP as required.

The above two examples of failure to follow procedures constitute a violation and are categorized as a Severity Level IV violation (Supplement 1).

C. Technical Specification 3.3.7.5, " Accident Monitoring Instrumentation,"

requires a channel calibration of the Primary Containment Post-LOCA High Range Monitors. Further, Table 4.3.7.5-1, "Accidert Monitoring Instrumentation Surveillance Requirements," states that the Primary Containment Post-LOCA Radiation Monitor channel calibrations shall consist of an electronic calibration of the channel, not including the detector, for range decades above 10 R/hr and a one point calibration check of the detector below 10 R/hr with an installed or portable gamma source.

Contrary to the above, calibrations performed March 4-6, 1989, did not include'an electronic calibration of the channel, not including the detector, for range decades above 10 R/hr.

Thf s is a Severity Level V violation (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, Philadelphia Electric Company is hereby required to submit to this office within thirty days of the date of the letter which transmitted this Notice, a written statement or explanation in reply, including: (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved. Where good cause is shown, considerations will be given to extending this response time.

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