ML20234F025
| ML20234F025 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 12/30/1987 |
| From: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| Shared Package | |
| ML20234F028 | List: |
| References | |
| EA-87-196, NUDOCS 8801110301 | |
| Download: ML20234F025 (3) | |
See also: IR 05000352/1987027
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December 30, 1987
Docket No. 50-352
License No. NPF-39
EA 87-196
Philadelphia Electric Company
ATTN:
Mr. John S. Kemper
Senior Vice President
Engineering and Production
2301 Market Street
Philadelphia, Pennsylvania 19101
Gentlemen:
Subject:
(NRC Inspection Reports Nos. 50-353/87-11 and 50-352/87-27)
This refers to a special construction team inspection conducted between June 22
and July 2,1987 at Limerick Generating Station, Unit 2, and a follow-up
inspection conducted on October 20, 1987 at Unit 1 following receipt of an
event report from your staff on October 5, 1987 concerning a violation of
the fire protection requirements at Unit 1.
The reports documenting these
inspections were sent to you with letters dated September 28, 1987 and
November 23, 1987. On October 22, 1987, an enforcement conference was
,
conducted with Mr. S. Kowalski and other members of your staff to discuss
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the violation, its cause, and your correc.tive actions.
I
The violation described in the enclosed Notice of Violation involved the failure
to provide adequate fire protection features for control cables associated with
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the Emergency Diesel Generators (EDGs) to assure that one redundant train
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remained free of fire damage.
These control cables were associated with flow
switches for the automatic fire suppression system used to shutdown the EDGs
in the event of a fire in the EDG rooms. These cables were routed in the
same pipe tunnel and as a result of this deficiency, a fire in the pipe tunnel
area could result in the multiple loss of these flow switches and associated
time delay relays, thereby causing the tripping of all four EDGs. Without the
EDGs, safe shutdown, once achieved, could not be maintained after three hours.
The NRC recognizes that the probability of a fire in the tunnel area is low
given the amount of onsite combustibles in the area and that it is unlikely
that transient combustibles would be introduced into the area.
This violation was identified by your staff during their review, subsequent to
the June-July 1987 inspection, of a potential problem with the interaction of
safety and nonsafety-related circuits involving these flow switches at Unit 1.
The NRC is concerned about the inadequacy of previous evaluations of the
interaction between safety-related and nonsafety-related EDG circuits, both
during the original design and after the identification in 1984 of another
problem related to a fire protection system time delay feature in the EDG trip
circuitry.
If an adequate engineering evaluation was performed in 1984 to
determine the extent of the interaction deficiency, the violation could have
been identified and reported to the NRC in accordance with 10 CFR 50.55(e).
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This violation emphasizes the importance of complete and thorough evaluations
to ensure prompt (1) identification and correction of existing deficiencies, and
(2) maintaining systems important to safe shutdown of the unit in such a condition
that they remain free of damages in the event of a fire.
In accordance with the
" General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1987), the violation has been categorized at a Severity
Level III since safe shutdown could not be maintained without an operator taking
certain manual actions to restart the EDGs.
This condition was not previously
analyzed in the fire hazards analysis. Although a civil penalty is normally
proposed for a Severity Level III violation, I have decided, after consultation
with the Director, Office of Enforcement, and the Deputy Executive Director for
Regional Operations, that a civil penalty will not be proposed in this case
because (1) your corrective actions to this violation, when identified, were
unusually prompt and extensive, and (2) your enforcement history at Limerick
concerning adherence to the separation, suppression and detection requirements
has been good.
You are required to respond to this letter and should follow the instructions
specified in the enclosed Notice when preparing your response.
In your
response, you should document the specific actions taken and any additional
actions you plan to prevent recurrence, including discussion of your procedures
for review of safety issues to avoid situations such as occurred in this case.
After reviewing your response to this Notice, including your proposed corrective
actions and the results of future inspections, the NRC will determine whether
further NRC enforcement action is necessary to ensure compliance with NRC
regulatory requirements.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2,
Title 10, Code of Federal Regulations, a copy of this letter and its enclosure
will be placed in the NRC Public Document Room.
The responses directed by this letter and the enclosed Notice are not subject
to the clearance procedures of the Office of Management and Budget as required
by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.
Sincerely,
Orici"n1 Sic;ned By
CI:::'
i, ::; SDLL
William T. Russell
.-
Regional Administrator
Enclosure: Notice of Violation
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Philadelphia Electric Company
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cc w/ encl:
John S. Kemper, Senior Vice President, Engineering and Production
G. Leitch, Nuclear Generation Manager
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J. Franz, Manager Limerick Generating Station
' Troy B. Conner, Jr. , Esquire
Eugene J. Bradley,- Esquire, Assistant General Counsel
W. M. Alden, Engineer in Charge, Licensing Section
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
!
Commonwealth of Pennsylvania
DISTRIBUTION:
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J. Taylor, DEDO
J. Lieberman, OE
W. Russell, RI
T. Murley, NRR
L. Chandler, OGC
T. Martin, DEDRO
Enforcement Coordinators
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H. Wong, OE
F. Ingram, PA
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