ML20058M603

Notice of Violation from Insp on 900522-0701.Violations Noted:Licensee Used Generically Expanded Differential Pressure Ranges for safety-related Pumps W/O Appropriate Technical Justification

ML20058M603
Person / Time
Site:	Limerick
Issue date:	08/03/1990
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20058M601	List: IR 05000352/1990017 ML20058M598 ML20058M603
References
50-352-90-17, NUDOCS 9008100207
Download: ML20058M603 (2)

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,,- . i APPENDIX A i

NOTICE OF VIOLATION Philadelphia Electric Company ' Docket No. 50-352 l Limerick Unit 1 License No. NPF-39 As a result of an inspection conducted on May 22 through July 1,1990, and in accordance ,

with NRC Enforcement Policy (10 CFR 2, Appendix C), the following violations were identined:  ;

A. Technical Specincation 4.0.5.a requires that inservice testing of ASME Code Class 1, 2 and 3 pumps shall be performed in accordance with Section XI of the ASME Boiler .;

and Pressure Vessel Code and applicable Addenda as required by 10 CFR Part 50,  !

Section 50.55a(g), except where specine written relief has been granted by the Commission pursuant to 10 CFR Part 50, Section 50.55a(g)(6)(i).Section XI, Article j IWP-3210 states that the allowable ranges of inservice test quantities in relation to the j reference values are tabulated in Table IWP-3100-2. If these ranges cannot be met,  !

the Owner shall specify in the record of tests the reduced range limits to allow the 1 pump to fulfill its function, and those limits shall be used in lieu of the ranges given in Table IWP 3100 2.

Contrary to the above, since February 8,1985, the licensee has been using generically expanded differential pressure ranges for safety related pumps which extend beyond those specified in Table IWP-3100-2 of Section XI of the ASME Boiler and Pressure Vessel Code without appropriate technical justifkion. In several cases the pump differential pressure ranges were expanded even though the actual pump data had not fallen outside of the Code range. In add! tion, the ranges were extended so broadly ,

that the Inservice Testing Program was not' assured of satisfactorily performing its intended function, to assess the operational readiness of safety related pumps. ,

This is a Severity Level IV violation (Supplement 1).

B. Technical Specincation 6.8.1 requires the plant to be operated using established procedures. Procedure RE-201, AppendiA B, " Reactor Maneuvering Shutdown Instructions," gives specific instructions for control rod insertion.

Contrary to the above, on June 4, while conducting a unit shutdown the operater, on the advice of the reactor engineer, deviated from the specific instructions contained in procedure RE-201, Appendix B. This resulted in control rods being in positions different from Gose specified in RE-201, Appendix B. Therefore, the unit was operated outs'de the established procedure for inserting control rods during a shutdown of the unit.

This is a 3everity Level IV violation (Supplement I).

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V! , Pursuant to the provisions of_10 CFR 2.201, for Violation A above, Philadelphia Electric

- Company is hereby required to submit to this office within thirty days of the date of the letter.

M  : which transmitted this Notice, a written statement or explanation in reply, including:' (1) the =

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corrective steps which have been taken and the results achieved; (2) corrective steps which '

will be taken to avoid further violations; and (3) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending this response time. For Violation B above, ao response is required because prompt and corrective action -

n4 by the licensee has been verified by the resident inspector.

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