ML20035H582
| ML20035H582 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 04/27/1993 |
| From: | Durr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Danni Smith PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| NUDOCS 9305060027 | |
| Download: ML20035H582 (4) | |
See also: IR 05000352/1992081
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APR S 71993
Docket Nos. 50-352
50-353
Mr. D. M. Smith
Senior Vice President - Nuclear
Philadelphia Electric Company
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Nuclear Group Headquarters
Correspondence Control Desk
P. O. Box 195
Wayne, PA 19087-0195
Dear Mr. Smith:
SUBJECT: INSPECTION REPORT NOS. 50-352/92-81 AND 50-353/92-81
This letter refers to your January 8,1993, correspondence, Reply to a Notice of Violation, in
response to our December 4,1992, letter. Thank you for informing us of the corrective and
preventive actions regarding items A.1 and A.2 of the Notice of Violation (NOV). These
actions will be examined during a future inspection of your licensed program.
In your response to item A.3 of the NOV and item 92-81-04 of the subject report, you
disagreed that the inspector's observations during the surveillance testing of the undervoltage
relay constituted a violation of your Appendix B program. The NOV was based on the test
technician's failure to notify the shift supervisor when the time delay of the degraded voltage
relay was measured to be 12 seconds and, hence, greater than the Technical Specifications
limit of 11 seconds. You stated that your investigation of the issue had concluded that the
I&C Technicians adequately communicated with the Shift Supervisor, that there was no valid
as-found time delay reading measured for the prescribed degraded voltage, that the failed test
equipment was the source of the relay time delay reading being outside of the required limits,
and that the Technical Specifications (TS) were complied with. The details provided indicate
that the above conclusions were primarily based on:
1.
The technician and the main control room operator's awareness of the TS limitations
regarding the inoperability of the channel. Steps 5.3.4,6.3.2, and 6.3.4 of
surveillance procedure ST-2-092-324-1, Revision 2, address channel inoperability and
require notification of the Shift Supervisor if the test cannot be accomplished within
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45 minutes.
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9305060027 930427
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ADOCK 05000352
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APR 2 71993
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Mr. D. M. Smith
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2.
The note at the beginning of section 6.4 instructing the operator to adjust the voltage
as necessary and repeat applicable steps, if the elapsed time of any relay trips in
Sections 6.4 through 6.6 exceed Acceptable Limits due to the Test Box voltage
drifting above the "As Found" trip voltage. The time delay outside the Acceptable
Limits was measured while performing step 6.4.12, the same step when the test
equipment failed.
3.
The experience and expertise of I&C technician who judged that the time delay
reading just observed to be outside of the required Technical Specification limit was
invalid and that the failed test equipment was the source of the inaccurate reading.
4.
The technicians properly notifying the Shift Supervisor when the test equipment could
not be repaired in time to accomplish the Sections 6.4 through 6.6 steps within the
specified 45 minutes.
A review of the surveillance procedure confirmed your statements regarding the procedure
steps and note. We also agree with your statement in paragraph 4, above. Considering that:
(1) the note at the beginning of Section 6.4 of the procedure instructs the technician to repeat
the applicable steps when the results fall outside the Acceptable Limits; (2) notification of the
Shift Supervisor based on the requirement of 6.3.4 would have provided the same results,
had Action 37 of the TS not been already initiated by the Shift Supervisor; and (3) the
technician's judgement regarding the validity of the observed measurement proved to be
correct, the subject violation is hereby withdrawn.
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Our review of your letter also indicates an incomplete understanding of the NRC concerns.
For instance, the last paragraph of page 9 inaccurately implies that "the NRC inspector had
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in effect proceeded past step 6.4.12 to step 6.7.20.1" to influence the shift supervisor's
actions and the last paragraph of page 10 incorrectly interprets the reference to step 6.7.20.1
as a suggestion that technician should perform procedure steps out of order.
The inspector became originally concerned when he observed that the reading at step 6.4.12
was not only outside the Acceptable Limits but also outside the Required Limit. This was
evident from Table 2 of the procedure, used by the technician to record the data. As stated
in the report, when the inspector later discussed his observation with the Shift Supervisor,
the inspector determined that only the failure of the test instrument had been reported and not
the 12 seconds reading which, although unconfirmed, was outside the Required (TS) Limit.
Subsequent actions by the Shift Supervisor were the result of his understanding of the
procedure requirements and his discussions with the System Manager, who also had
witnessed the test. Although the inspection report cites failure to meet the requirements of
step 6.7.20.1 as the basis for the violation, these requirements were not observed until later.
0FFICIAL RECORD COPY A:R9281. LIM
APR 2 71993
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Mr. D. M. Smith
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The concern was that the technician did not notify the shift supervisor of his observing a
measurement outside the Required Limit. Although the measurement could not be confirmed
because of the failure of the test instrument, there was no basis for attributing the reading to
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a drift of the supply voltage or to the failure of test instrument, rather than to a drift of the
relay response. For conservatism, it should have been attributed to the latter. In not
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communicating all the pertinent information to Shift Supervision, the I&C technician limited
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the ability to make a safety decision.
Regarding the note at the beginning of Section 6.4 of the procedure, we note that it cautions
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the technician to confirm validity of the results only if they fall outside the Acceptable
Limits. Since the time measurement is voltage dependent and the voltage can change as a
result of plant loading conditions, as stated in your letter, then the note should require
confirmation of all measurements, since even the results that fall within the Acceptable
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Limits could be anomalous.
Your cooperation with us is appreciated.
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Sincerely,
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Jacque P. Durr, Chief
Engineering Branch
Division of Reactor Safety
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0FFICIAL RECORD CC0Y A:R9281. LIM
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Mr. D. M. Smith
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cc:
.T. Doering, Chairman, Nuclear Review Board
D. R. Helwig, Vice President - Limerick Generating Station
G. A. Hunger, Jr., Manager - Licensing Section
3. L. Xantner, Regulatory Engineer - Limerick Generating Station
Secretary, Nuclear Committee of the Board
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
Commonwealth of Pennsylvania
bec:
Region I Docket Room (with concurrences)
E. Wenzinger, DRP
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C. Anderson, DRP
V. McCree, OEDO
F. Rinaldi, NRR
RI:DRS
RI:DRS
RI:DRS
Della Greca
Rulandj
Durr
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[/93
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