IR 05000352/1997006

Discusses Insp Repts 50-352/97-06 & 50-353/97-06 on 970528-0721 & Forwards Nov.Violation Involves Failure to Implement & Maintain in Effect Certain Provisions of Approved Fire Protection Program for Limerick Facilities

ML20198Q901
Person / Time
Site:	Limerick
Issue date:	09/29/1997
From:	Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Danni Smith PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
Shared Package
ML20198Q873	List: ML20198Q870 ML20198Q901 ML20198Q918
References
50-352-97-06, 50-352-97-6, 50-353-97-06, 50-353-97-6, EA-97-340, NUDOCS 9711130080
Download: ML20198Q901 (3)

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8 [anse\ VNRED sMMs NUCLEAR REGUL.A10RY COMMISSION i stoioN i KING OF Pt s A, NN LV 1A 19441416

• • • • • September 29, 1997 EA 97 340 l Mr. D. M. Smith, President PECO Nuclear Nuclear Group Hoodquarters Correspondence Control Desk Post Office Box 196 Wayne, Pennsylvanta 19087 0195 .

SUBJECT: NOTICE OF VIOLATION (NRC Inspecthn Report Nos. 50-352/97 08 and 50 353/97-06)

Dear Mr. Smith:

This letter refers to the NRC inspection conducted at the Limerlek Generating Station, Unita 1 and 2,between May 28,1997through July 21.1997,the findings of whloliwere discussed with Mr. B. Boyce and other memtars of your staff at the exit meeting on July 21,1997. The I inspaction report was forwarded to yw on August 13,1997. During theinspection, the NRC ,

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reviewed the circumstances associated with an apparent violation of fire protection req'ilrements that was identified by your staff and reported to the NRC. In our August 13,1997 letter forwarding the report, we Indicated that it was not necessary to conduct a predecisional enforcement conference (conference) in order to enable the NRC to .

make an enforotment decision on the apparent violation, in a telephone conversation with Mr. l P. Swetland, NRC Region i on August 25,1997, Mr. Boyce indicated that a conference was not needed. Subtsquently, in a letter dated September 12.1997, you provided a response to the NRC findings.

Based on the information obtained during the inspection, as well as information you provided i to the NRC in Licensee Event Report No.96-015, and in your September 12,1997 letter, one vie'ation is being cited and is described in the enclosed Notice of Violation. The violation involves the f ailure to implement and maintain Ir effect certain provisions of y.sur approved Fire Protectlen Program for the Umerick facilities. Specifically, a temporary jumper cable did not exist, as required, to provide power to the Unit 2 automatic depressurization system (ADS)

solenold pilot valves,in the event of a fire,in order to depressurize the reactorif needed. In the event of a design basis fire in the Remote Shutdown Panel Room, both units would be affected and two electrical)umper ceblos would be needed to ensure power to the related ADS solenoid pilot valves. However, since the start-up of Unit 2 in 1989, a jumper cable was not provided, in eddition, the pathways for the installation of the temporary cables for both Unit 1 and Unit 2, areas to which access ;nay be needed for manual actuation of safe shutdown equipment, were not provided with fixed self contained lighting units with Individual 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> battery power supplies. While such pre staged equipment should normally be verifled by periodic invent ory procedures, your procedures did not list these components for verification.

AD h M PDR

50/10*d tSES4EE019 ddG ET E0 4E6t-02-d3S

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PE00 Nuclear 2 in your LER, you indicated that there were no adverse consequences from this violation, and it would have had no impact on your fire brigede's ability tu control a fire, You noted that the room le restricted to operations personnel, contains a very low combustible loading, and is protected by the automatic fire suppression system. Also, operators wor'. strying hand held radios, and high Ireensity portable lights were available. Nonetheless, sinee certain required

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equipment were not available to achieve cold shutdown in the event of a fire, the violation has been classified at Sevedty Level Illin accordanos in accordanos with the " General Statement

' of Policy and Procedure for NRC Enforoement Actions" (Enforcement Policy), NUREG 1600. ..,

in socordance with the Enforcement Policy, a base olvil penalty in the amount of $56,000 is L considered for a Severity Level lli proHom. Boosuse your fooluty has been the subject of l escalated enfotoement action within the last 2 years,' the NRC considered whether orodit was l' warranted for identMoetion and CwrectNo Acedon in sooordance with the olvil penalty assessment process in Section VI.B.2 of the Enforcement Policy. Credit is warranted for

/dentMession beoeuse the vloistion was identified by your staff. In fact, the NRC commends the engineer who identitled this violation during a tour of the foollity. Credit is eleo warranted j ' for Cwreceke Acidon whleh were prompt and comprehensive. These corrective actions q

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included, but were not limited to: (1) conduct of an engineering revlew to determine egalpment '

. and procedures required to be svallable in the. Emergency Pire Dispatch Center; (2) fabrication *

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of a second cable; (3) revision of applicable procedures to clearly indicate the use of two jumper cables (4) verlilcation that operators carried hand held radios with access to high Intensity portable lights, and informing personnel of actions via a shift Night Order entry and reading at shift tumover meetingel and (6) Installation of permanent battery powered lighting for the jumper cable ~ pathway,'

r Ttwrefore, to encourage prompt identification and comprehensive correction of violations, I have been authorized not to propose a olvil penalty in this case. Hawever, significant

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violations in the future could result in a olvil penalty.

- The NRC has concluded that information regarding the reason for the violation, the corrective actions taken and planned to correct the violation and prevent recurrence, and the date when full compliance was achieved is already adequately addressed on the docket in your 1.ER and your September 12,1997 letter.' Therefore, you are not required to respond to this letter-unless the description therein does not accurately refloot your corrective actions or your position, in that case, or if yoJ choose to provide additional Information, you should follow

the instructions spoolfied in the enclosed Notics.

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' A Nodes of Violation and Proposed Imposition of Civil Penalty in the amount of $80,000 was issued to PBCO en Ausut 5,1997 for vlotauens involving unwriene.

SO/E0 *d - tGESLEE019' eJ3 Ei 80 4661-DE-d3S

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i PECO Nuclear 3 in scoordance with 10 CAR 2.790 of the NRC's ' Rules of Practice,' a copy of this letter and its enclosure, wlil be placed in the NRC Public Document Room (PDR).

Sincerely,

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l Hubert J. iller L Regional Administrator W- - .

Docket Nos. 50-362:60 353 Ucense Nos. NPF-39; NPF-85 *

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Enclosure Notice of Violation I

eo w/encli G. Hunger, J ., Chairman, Nuclear Review Board and Director Licensing .

W..MacFarland, Vice President - Limerick Generating Station J. Kantner, Manager, Experience Assessment Secretary, Nuclear Committee of the Board Commonwealth of Pennsylvania SX'VED N PSESLEE019 ckK! PI:80 466I-0E-d35 a