ML20116H147

Requests That Util Be Forbidden to Test/Operate Turbine Generator,Based on Deficiencies & Violations Noted in Insp Repts 50-352/85-03,50-352/85-06 & 50-352/85-14. Related Correspondence

ML20116H147
Person / Time
Site:	Limerick
Issue date:	04/27/1985
From:	Anthony R ANTHONY, R.L., FRIENDS OF THE EARTH
To:	Thompson H Office of Nuclear Reactor Regulation
References
CON-#285-786 OL, NUDOCS 8505020092
Download: ML20116H147 (1)

Text

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Mr. Hup.h L. Thomycen, Jr.,Dir. 31v. of Licensing,NRR April 27,1905 U.S Nuclear Rc gulatory Commis' ion, Washington , 20555 Res Phile Elec.Linerick Gen. Stn.

Dear Mr. Thorpeon,

Docket No. 50-352 Unit 1. Startup "esting We refer to your letter of 4/10/85 to E.G.?nuer in which you nentien a letter to Mr.Denton of 3/25/e5 which indicates TECo's plan to test oper a te the turbine-generator, to 5 % of rated power. You stnte, "We have not identi-fied any conflicts with your plans on this matter..."

On the contrary we hav e identified several deficiencies and violations from recent NRC inspection reports which add up to the conclusion that PECo is not prepared to operate the plant safely at this time up to 5 % power or to test operate the turbine-genere tor. We,therefore, ask you to protect our henith and safet; end that of the public by chcaging your conclusion from " no objections" to we forbid any tect operating of the turbine until the impedi-ments to safe operetion listed below hcve bcen corrected end resolved.

Region I inspection report 85-03 dated 4/2/85 in Appendix A (Sec Attech-ment 1. ) states that Tech. Spec.3 6.1.4 arts vic12ted from 12/29/54 to 1/30/05 tecause FECO allcwed the two independent MSIV lepkn ge control subsystems to be inoperable. This constituted a serious thrert to the public while the reactor was in operation. Operation of the reactor should be suspended until NaC has the assura nce that these systems are in order and PECo will maintain them in RW operation. symptomatic of a.Stargstgekinunesreab{g.{r}ngtgtes that this FSIV-LCS violation "could be In cpection report 85-06, dated 4/10/85, Appendix A, cites two violations which affected the power level of the reactor and which pose serious potentici hazards to the public he n ith and safety. FECo allowed the power level of the reactor to be manipulated without the knowledge and consent of n licensed op-erstor, and pcroitted enintenance work to be done without termission from oper-ation personnel. (See Attachment 2.) A violation of Tech. Spec. (.S.1 and Reg . Guide 1 33 Rev. 2 , App. A ,parn. 9.e.

On page 11 cf this same inspection report which details the uneuthorized raising of the reector power level, under 4.).3 " Corrective Action Revicw",

Mr. S.D.Ebneter,Dir. Reactor Safety, finds that the implementetion of corrective action has not been developed and that review of these steps,1.e. "three cor-rective actions no this event" will have to be covered " in a subsequent inspec-tion. This is considered an unresolved item pending URC review ( 352/85-06-03)."

It is unconceivable that you would allow any te s t oper n tion of the turbine while these uncertainties as to control of the power leveh are unresolved.

Inspection report 85-14, reported 4/23/85,L p.5 ) that" review of the startup test results is in process" and that"a number of changes were required" and "the adequacy of the licensee review of this startup test procedure will be assassed in a subsequent inspection ". And para. 2 3 cites exception reports suppe;edly resolved,"but action still is required to close out the test exception." On an unresolved " swap over situation" involving safety systems page 6,STP-15 states,"This 2,blem ha pro s persisted during tests of HPCI and RCIC" and "in addition HPCI stop valve experienced erratic behavior..during the pump start... A modifica-is also planned... Thene modifications will require retesting of HPCI ". Until the problems with these essential safety systems have been completelp. cured arecertainthatyouwillnotauthorizeanytestoperationofturbine-generkwe tor.

On behalf of intervenor Anthony / FOE , in recognition of the above obstacles to safe opera tion of the Limerick reactor, we pe authority to forbid PECo from test operating the}ition tu'rbineyou

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hers on st. Respectfullysub[mitted, jg4 gj- 1 Eet lor,1oyite.Te. looff l 8505020092 850427 PDR G ADOCK 05000352 PDR 51

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• h71ACHMO)T I JfY R6C!& T W JPcexk)D R&Pb AT' es-a3 APPENDIX A NOTICE OF VIOLATION Philadelphia Electric Company Docket No. 50-352 Limerick Generating Station, Unit 1 License No. NPF-27 As a result of the inspection conducted on January 28 - February 1,1985 and in accordance with the NRC Enforcement Policy (10 CFR 2, Appendix C), published in the Federal Register Notice (49 FR 8583) dated March 8,1984, the following violation was identified:

Technical Specification Limiting Condition for Operation 3.6.1.4 requires two independent MSIV leakage control subsystems to be operable in Opera-tional Condition 2.

Contrary to the above, during the period between December 29, 1984 and January 30, 1985, while in Operational Condition 2, the two independent MSIV leakage control subsystems (Inboard and Outboard) were inoperable, in that the circuit breakers for the associated blowers and heaters were misaligned (opened) due to an incorrect surveillance test procedure.

This is a Severity Level IV 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 re-sults achieved; (2) corrective steps which will be taken to avoid further vio-lations; and (3) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending this response time.

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APPENDIX A NOTICE OF VIOLATION Philadelphia Electric Company Docket No. 50-352 Limerick Generating Station License No. NPF-27 Unit I- -

Limerick, Pennsylvania As a result of the inspection conducted on January 16 - February 7,1985, and in accordance with the NRC Enforcement Policy (10 CFR 2, Appendix C), the following violations were identified.

A. Code of Federal Regulations 10 CFR 50.54(3)(J) requires in part

" Apparatus and mechanisms other than controls, the operation of which may affect the reactivity or power level of a reactor shall be manipulated only with the knowledge and consent of a licensed operator present at the controls". Licensee administrative procedure A-7 in section 5.2.2, states similar requirements.

Contrary to the above, on January 25, 1985, instrumentation and controls personnel in the process of trouble shooting previous indication of erra-tic recirculation pump flow behavior caused an increase in recirculation pump flow, which increased reactor power, when connecting a recorder to the recirculation flow control circuit. This work was performed without the knowledge and consent of the licensed operators present at the controls. .

This is a Severity Level IV Violation (Supplement '1).

B. Technical Specification 6.8.1. a requires, in part, " written procedures be established as recommended in Appendix A of Regulatory Guide 1.33 Revision 2." Regulatory Guide 1.33, Revision 2, in Appendix A, paragraph 9.e, recommends, in part, " general procedures for the control of maintenance which includes items such as a method for obtaining permission and clearance from operation personnel to work".

Contrary to the above, as of January 25, 1985 controls to assure that permission is obtained from operations personnel prior to performing trouble ' shooting activities are not contained in general procedures.

This is a Severity Level IV Violation (Supplement I)

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