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| {{Adams
| | #REDIRECT [[IR 05000352/1998005]] |
| | number = ML20199F925
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| | issue date = 01/11/1999
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| | title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-352/98-05 & 50-353/98-05
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| | author name = Yerokun J
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| | author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
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| | addressee name = Rainey G
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| | addressee affiliation = PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
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| | docket = 05000352, 05000353
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| | license number =
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| | contact person =
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| | document report number = 50-352-98-05, 50-352-98-5, 50-353-98-05, 50-353-98-5, NUDOCS 9901220092
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| | title reference date = 09-08-1998
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| | document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE
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| | page count = 2
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| }}
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| See also: [[see also::IR 05000352/1998005]]
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| =Text=
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| January 11, 1999 1
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| Mr. ''i. Rainey, President
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| PECO Nuclear
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| Nuclear Group Headquarters
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| i Correspondence Control Desk
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| l P. O. Box 195
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| Wayne, PA 19087-0195
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| SUBJECT: NRC INSPECTION REPORT NO. 50-352/98-05 AND 50-353/98-05- REPLY l
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| Dear Mr. Rainey:
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| This letter refers to your September 8,1998 correspondence, in reponse to our
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| August 7,1998 letter.
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| Thank you for informing us of the corrective and preventive actions documented in your
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| letter. These actions will be examined during a future inspectic n of your licensed program.
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| Your cooperation with us is appreciated.
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| Sincerely, i
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| !
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| Jimi T. Yerokun, Acting Chief l
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| Engineering Programs Branch
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| Division of Reactor Safety
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| Docket No. 50-352;50-353
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| cc:
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| J. J. Hagan, Vice President, Nuclear Station Support
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| G. Edwards, Chairman, Nuclear Review Board and Director - Licensing
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| J. von Suskil, Vice President - Limerick Generating Station
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| M. P. Gallagher, Plant Manager, Limerick Generating Station
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| T. Moore, Manager, Experience Assessment
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| Secretary, Nuclear Committee of the Board
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| Commonwealth of Pennsylvania
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| 210018 i
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| 9901220092 990111
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| PDR ADOCK 05000352
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| O PDR
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| . .- . - . - . . - - - - - = . . . .-
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| <
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| s =
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| Mr. G. Rainey 2
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| Distribution:
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| Region i Docket Room (with concurrencen
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| W. Lanning, DRS
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| W. Ruland, DRS
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| J. Yerokun, DRS
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| A. Lohmeier, DRS
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| C. 6%3i LL. DRP
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| D. Florek, DRP
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| R. Junod, DRP
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| NRC Resident inspector
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| Nuclear Safety information Center (NSIC)
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| PUBLIC
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| G. Shear, OEDO
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| R. Capra, PDl-2 N3R
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| B. Buckley, PL 1-2, NRR
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| M. Thadani, PD 1-2, NRR
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| R. Correia, NRR
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| M. Campion, ORA
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| DOCDESK
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| inspection Program Branch, NRR (IPAS)
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| DRS File
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| DOCUMENT NAME: G:\ PROGRAMS \LOHMElER\ LIM 9805. REP
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| T4 teceive a copy of this document. Indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with attachrnent/ enclosure "N" = No
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| l COPY n _
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| i OFFICE Rl/DRS fy l ( Rl/DRf,.f3 Rl/DRS IWORA l l
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| NAME ALohmeier / Q{l CCo; Vgf( ' \ JYerokun @7 M
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| DATE 01/06/99 U\ 01/[/99 01/sh/99 V N 01/ /99
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| OFFICIAL RECORD COPY
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| t_re c_,so s,a,-
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| !.
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| PECO NUCLEAR n co c,em ,co ,an,
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| A Unit of PECO Energy M,x23OO i
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| sanatoga. PA 19464 0920
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| 610 718 3000 / Faz 610 718 3008 ,
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| Pager 1800 672 2285 #02 71
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| Internet address gvonsuskilia'gwco energyenr.,
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| 10 CFR 2.201
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| 1
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| September 8,1998
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| Docket Nos. 50 352
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| 50-353
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| License Nos. NPF-39
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| NPF-85
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| U.S. Nuclear Regulatory Commission '
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| Attn.: Document Control Desk
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| Washington, DC 20555
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| SUBJECT: Limerick Generating Station, Units 1 and 2
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| Reply to a Notice of Violation
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| NRC Inspection Report 50-352/98-05 and 50-353/98-05
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| Attached is PECO Nuclear's reply to a Notice of Violation for Limerick Generating Station
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| (LGS) Unit 1, that was contained in your letter dated August 7,1998. The Notice identified one !
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| violation, with two examples, where conditions adverse to quality were not promptly identified
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| and corrected. The attachment to this letter provides a restatement of the violations followed
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| by our reply.
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| If you have any questions or require additional information, please contact us.
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| Very truly yours,
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| l
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| $50k
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| Enclosure
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| Attachments
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| cc: H. J. Miller, Administrator, Region I, USNRC w/ attachments
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| A. L. Burritt, USNRC Senior Resident inspector, LGS "
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| Atttchment
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| l , Dock t Nos. 50-352 and 50-353
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| S:ptamb:r 8,1998
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| Page 1 of 3
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| 1
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| REPLY TO A NOTICE OF VIOLATION
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| Restatement of the Violations
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| During an NRC inspection conducted between June 1,1998, and June 24,1998, a violation of
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| NRC requirements was identified. In accordance with the General Statement of Policy arid
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| >
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| Procedure for NRC Enforcement Actions, NUREG-1600, the violation is listed below:
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| A. 10 CFR 50, Appendix B, Criterion XVI, requires, in part, that: " Measures shall be
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| established to assure that conditions adverse to quality, such as failures, malfunc; ions,
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| deficiencies, deviations, defective material and equipment and nonconformances . ire
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| promptly identified and corrected."
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| l Contrary to the above, the following conditions adverse to qualit, .ce not promptly
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| l Identified and corrected.
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| 1.
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| Defective equipment (an incorrectly wired current transformer) in the supply l
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| circuit breaker of load center 124B was not identified and corrected, and on l
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| March 22,1998 the breaker tripped unexpectedly and de-energized all the loads I
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| supplied by the load center. PECO was aware of potential wiring errors !
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| affecting the circuit breakers used at Limerick since November 1996 based on
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| industry operating experience. PECO had failed to revise the pendic
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| calibration procedure, which could have identified the incorrectly wired current .
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| i transformers and prevented the event.
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| 2. Deficiencies (age-related failures) in Agastat relays in three panels (OA, OB,
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| and OC-C124) were not identified and corrected. Due to higher panel
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| temperatures, the continued use of these Agastat relays beyond their
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| appropriate service life led to higher age-related failures, including the l
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| April 4,1998, event in which the B train of the control room emergency fresh air ;
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| supply (CREFAS) system did not actuate. On June 19,1998, several such !
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| relays remained in service, considerabiy beyond their calculated service lives.
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| This is a Severity Level IV Violation (Supplement 1).
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| Attachment I
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| Dock;t Nos. 50-352 and 50-353
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| Sept:mb;r 8,1998
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| * Page 2 of 3
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| Reply to Violation A
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| AoQsion of the Violation
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| PECO Energy acknowledges the violation.
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| Reaso s for the Violations
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| 2
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| Both ext uples cited in the violation were caused by untimely completion of corrective actions
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| for self-ic antified problems.
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| -_
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| The reason for example (1) of the violation, as stated in Licensee Event Report 1-98-005, Rev.
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| ; 0, for Limerick Generating Station (LGS), Unit 1, is described below.
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| The 124B load cen'er tripped due to improper wiring of the current transformer (CT)
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| circuit for one of the load center feeder breaker's protective re!ays. This improper
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| i configuration causec' the feeder breaker (124B-62) to trip prematurely under normal l
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| plant loading. The improperty wired CT circuit was supplied in that configuration by the
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| manufacturer, however, station calibration procedures were less than adequate to
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| !dentity this situation. An Operating Experience item, related to CT configuration l
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| causing a premature creaker trip, was reviewed in November 1996, determined to be
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| app!!c.able, and the procedure revision action item was created. The CT configuration !
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| issue m3 reviewed again in 1997 when the vendor issued a 10CFR Part 21 notice for l
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| the same concem. The target breaker calibration procedure had not been revised
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| when it was used during breaker maintenance four days prior to this event.
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| The reason for example (2) was work prioritization such that the review of Agastat relay service
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| conditions and the planned relay replacements in the OA,08, and OC-C124 panels were not
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| completed in a timely manner. The OA, Otl, and OC-C124 panels are designated as a mild
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| environment in design documents. Relay replacement dates were therefore established, using
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| PECON procedures, commensurate with the safety significance of the relays and the expected
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| service environment. In 1997, failure data indicated that the service environment in the OA, !
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| 08, and OC-C124 p anels may be contributing to a higher than expected failure rate. A service
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| environment and relay failure study was initiated for the subject panels and other panels. This
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| resulted in a recommendation that Agastat relays be established as a Maintenance Rule
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| Program (a)(1) system. Corrective actionT were initiated that included accelerated
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| replacement of certain relays, including specific relays in the OA, 08, and OC-C124 panels.
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| The data analysis re.vealed that the higher than expected Agastat relay failure rate in these
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| panels was caused by localized heating effects. The majority of relays that failed were either
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| at the top of the prnel (highest temperature in the panel) or were near energized instrument
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| power supplies.
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| Corrective Actions Taken and Results Achieved
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| The corrective actions for the load center breaker issue (example (1)) are described in LER 1-
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| 98-005. An Engineering analysis was ccmpleted on March 26,1998, that determined that
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| there was no adverse impact on t5e operability of load center breakers susceptible to the same
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| , ,. Attrchmsnt
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| Dockst Nos. 50-352 and 50-353
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| 7 Ssptsmber 8,1998
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| *
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| Page 3 of 3
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| ' CT configuration concern. The load center breaker calibration procedure (M-C-700-230) was
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| revised on April 4,1998. No additionalload center breaker trips, due to CT configuration, have
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| occurred sirice March 22,1998.
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| Completed corrective actions for the Agastat relay issues (example (2)) are described below.
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| To date,85 % of the Unit 1 and Common (oldest) Agastat relays in the subject panels (OA,08,
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| and OC-C124) have been replaced. All of the remaining normally energized relays (including
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| Unit 2) are scheduled for replacement prior to the end of 1998. An Engineering analysis was
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| completed on August 4,1998, and documented the acceptability of continued use of Agastat
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| relays in the OA, OB, and OC-C124 panels up to the time of their scheduled replacement.
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| Engineering has evaluated the status of th'e Limerick Agastat relay failure analysis and
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| replacement program, including an assessment of the technicalissues raised during the June
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| 1998 NRC inspection. Corrective actions include appropriately adjusting relay replacement 4
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| due dates and frequencies, maximizing the planning and execution effort for all relays, and I
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| applying lessons leamed to the Unit 2 panels with normally energized relays. Engineering
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| provided a presentation to station management in August,1998 on the status of the Agastat
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| relay evaluation and replacement program.
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| Corrective Actions to Avoid Future Noncompliance
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| As of August 28,1998, all but three (3) load center breakers had been tested with the revised
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| test. The remaining three (3) are scheduled to be completed by December 1,1998.
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| Agastat relay failures and service life estimates are being tracked and evaluated on an
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| ongoing basis and the relays are replaced on an ongoing basis. The results of the in-plant
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| data analysis are being incorporated into the Preventive Maintenance program for each Q-
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| listed Agastat relay. Expected service lives are being adjusted based on service environment
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| ' effects, such as localized heating. The Agastat relay system Maintenance Rute Program (a)(1)
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| action plan will be used to restore performance to (a)(2) status.
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| pate When Full Compliance was Achieved
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| Full compliance was achieved on August 4,1998, when Engineering analyses were completed
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| that supported continued operation in light of the identified load center breaker CT
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| configuration and Agastat relay service life issues.
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| !
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| !
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| }}
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