EA-97-340 - Limerick 1 & 2 (PEPCO Nuclear)
September 29, 1997
Mr. D. M. Smith, President
Nuclear Group Headquarters
Correspondence Control Desk
Post Office Box 195
Wayne, Pennsylvania 19087-0195
SUBJECT: NOTICE OF VIOLATION (NRC Inspection Report Nos. 50-352/97-06 and 50-353/97-06)
Dear Mr. Smith:
This letter refers to the NRC inspection conducted at the Limerick Generating Station, Units 1 and 2, between May 28, 1997 through July 21, 1997, the findings of which were discussed with Mr. B. Boyce and other members of your staff at the exit meeting on July 21, 1997. The inspection report was forwarded to you on August 13, 1997. During the inspection, the NRC reviewed the circumstances associated with an apparent violation of fire protection requirements 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 enforcement decision on the apparent violation. In a telephone conversation with Mr. P. Swetland, NRC Region I on August 25, 1997, Mr. Boyce indicated that a conference was not needed. Subsequently, 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 to the NRC in Licensee Event Report No. 96-015, and in your September 12, 1997 letter, one violation is being cited and is described in the enclosed Notice of Violation. The violation involves the failure to implement and maintain in effect certain provisions of your approved Fire Protection Program for the Limerick facilities. Specifically, a temporary jumper cable did not exist, as required, to provide power to the Unit 2 automatic depressurization system (ADS) solenoid pilot valves, in the event of a fire, in order to depressurize the reactor if needed. In the event of a design basis fire in the Remote Shutdown Panel Room, both units would be affected and two electrical jumper cables 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 addition, the pathways for the installation of the temporary cables for both Unit 1 and Unit 2, areas to which access may be needed for manual actuation of safe shutdown equipment, were not provided with fixed self-contained lighting units with individual 8 hour battery power supplies. While such pre-staged equipment should normally be verified by periodic inventory procedures, your procedures did not list these components for verification.
In your LER, you indicated that there were no adverse consequences from this violation, and it would have had no impact on your fire brigade's ability to control a fire. You noted that the room is restricted to operations personnel, contains a very low combustible loading, and is protected by the automatic fire suppression system. Also, operators were carrying hand held radios, and high intensity portable lights were available. Nonetheless, since certain required equipment were not available to achieve cold shutdown in the event of a fire, the violation has been classified at Severity Level III in accordance in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600.
In accordance with the Enforcement Policy, a base civil penalty in the amount of $55,000 is considered for a Severity Level III problem. Because your facility has been the subject of escalated enforcement action within the last 2 years,1 the NRC considered whether credit was warranted for Identification and Corrective Action in accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement Policy. Credit is warranted for Identification because the violation was identified by your staff. In fact, the NRC commends the engineer who identified this violation during a tour of the facility. Credit is also warranted for Corrective Action which were prompt and comprehensive. These corrective actions included, but were not limited to: (1) conduct of an engineering review to determine equipment and procedures required to be available in the Emergency Fire Dispatch Center; (2) fabrication of a second cable; (3) revision of applicable procedures to clearly indicate the use of two jumper cables; (4) verification 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 turnover meetings; and (5) installation of permanent battery powered lighting for the jumper cable pathway.
Therefore, to encourage prompt identification and comprehensive correction of violations, I have been authorized not to propose a civil penalty in this case. However, significant violations in the future could result in a civil 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 LER and your September 12, 1997 letter. Therefore, you are not required to respond to this letter unless the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to provide additional information, you should follow the instructions specified in the enclosed Notice.
In accordance with 10 CAR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its enclosure, will be placed in the NRC Public Document Room (PDR).
Sincerely, ORIGINAL SIGNED BY WILLIAM L. AXELSON FOR Hubert J. Miller Regional Administrator
Docket Nos. 50-352; 50-353
License Nos. NPF-39; NPF-85
Enclosure: Notice of Violation
G. Hunger, Jr., 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
NOTICE OF VIOLATION
PECO Nuclear Docket Nos.50-352; 50-353 Limerick Nuclear Generating Station License Nos.NPF-39; NPF-85 Units 1 and 2 EA No.97-340
During an NRC inspection conducted between May 28, 1997 through July 21, 1997, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is set forth below:
Limerick Generating Station (LGS) Unit 2 License Condition 2.C.(3) requires that the licensee shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in the Updated Final Safety Analysis Report (UFSAR) for the facility.
LGS UFSAR Section 9A.3.2.2 describes repair actions that may be needed in order to compensate for the effects of fire-caused damage to equipment and systems involved in achieving and maintaining shutdown condition. Section 9A.3.2.2, Item 33.a, describes as a repair action the installation of a temporary cable to provide power to the Automatic Depressurization System (ADS) solenoid pilot valves.
LGS UFSAR Section 9A.3.1.2, Item 108, states that fixed self-contained lighting units with individual 8 hour battery power supplies are provided in all areas to which access may be needed for manual actuation of safe shutdown equipment, and in access and egress routes thereto.
Contrary to the above, as of July 26, 1996, the licensee did not implement and maintain in effect certain provisions of the approved Fire Protection Program as described in the Updated Final Safety Analysis Report (UFSAR) for the facility in that
1. a temporary cable to provide power to the Unit 2 ADS solenoid pilot valves did not exist; and
2. the pathways for the installation of the temporary cables for both Unit 1 and Unit 2, areas to which access may be needed for manual actuation of safe shutdown equipment, were not provided with fixed self-contained lighting units with individual 8 hour battery power supplies. (01013)
This is a Severity Level III violation (Supplement I).
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 Licensee Event Report No. 96-015, as well as your September 12, 1997 letter to the NRC. However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to respond, clearly mark your response as a "Reply to a Notice of Violation," and send it 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).
Dated at King of Prussia, Pennsylvania
this 29th day of September 1997
1. A Notice of Violation and Proposed Imposition of Civil Penalty in the amount of $80,000 was issued to PECO on August 5, 1997 for violations involving Limerick.