ML20079B763

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Annual 10CFR50.59 Rept,930701-940630
ML20079B763
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 06/30/1994
From: Boyce R
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9501090043
Download: ML20079B763 (27)
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. 4 n bert n sosco Plant Manager i

, Umerick Generating Station a

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PECO ENERGY e - - ce - "v Umerick Generating Station PO Box 2300 Sanatoga, PA 19464 4920 I 215 3271200 Ext. 2000 l L

Derember 30, 1994

. Do aet Nos. 50-352- l 50-353 License Nos. NPF-39 NPF-85 I U.S. Nuclear Regulatory Commission i Attn: Document Control Desk  :

Washington, DC 20555  !

SUBJECT:

Limerick Generating Station, Units 1 and 2 ,

Annual 10CFR50.59 Report For the period July 1, 1993 through June 30,. 1994 I

Attached is the Annual 10CFR50.59 Report as required by'  ;

10CFR50.59(b).

If.you have any questions or require additional information, please contact us.  ;

t Sincerely, 2 A' h /3 y "

DBN:bdd cc: T. T. Martin, Administrator Region I, USNRC f N. S. Perry, USNRC Senior Resident Inspector, LGS t

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a 9501090043 940630 ~

(DR ADOCK 05000352 i

PDR

PECO ENERGY 3

PECO ENERGY COMPANY LIMERICK GENERATING STATION g UNITS 1 AND 2 J DOCKET NOS. 50-352 AND 50-353 ANNUAL 10CFR50.59 REPORT JULY 1,1993 THROUGH JUNE 30,1994 LIMERICK GENERATING STATION

PECO ENERGY COMPANY LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50 353 ANNUAL 10CFR50.59 REPORT JULY 1,1993 THROUGH JUNE 30,1994 This report provides a brief description of changes to the facility and procedures as described in the Safety Analysis Report, tests, and experiments that were implemented between July 1,1993 and June 30,1994. A summary of the safety evaluation for each item concluded that an unreviewed safety question, as defined in 10CFR50.59(a)(2), was not involved.

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PFCO ENERGY COMPANY .

LIMEidCK GENERATING STATION i UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 ANNUAL 10CFR50.59 REPORT f

JULY 1,1993 THROUGH JUNE 30,1994 TABLE OF CONTENTS s

'r' PECO ENERGY COMPANY LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 ANNUAL 10CFR50.59 REPORT TABIE OF CONTENTS Modifications Eage fj 5711 1 6071 1 6103 1 6136 2 6140 2 6145 2 6147 3 6148- 3 6194 3 6208 3 6218 4 6220 4 6227 5 6242 5 6248 6 6249 6 8011 6 P00008 6 P00058 7 P00114 7 P00132 7 P00140 7 P00167 8-P00260 8 P00283 8 P00305 8 ECR 93 00%3 and 93-00965 9 ECR 93-01075 9 ))

ECR 94-05389 9 ECR 94-05848 9 ECR 94-05940 10 l

TABLE OF CONTENTS -

Nonconformance Reports 93-00301 10 93-00309 and 94-00027 10 93-00321 11 93-00335 11 93-00342 11 93-00346 12 93-00351 12 93-00361 12 93-00374 13 93-00429 13 93-00434 14 94-00004 14 94-00014 14 94-00041 15 94-00067 and 94-00084 15 Procedures. Tests. or Erneriments A-C-134 15 GP-3 and ST-6-076-360-1 15 GP-5 16 IC-11-02029 and IC-11-02031 16 RT-2-092-901, 902, 903, 904-1 16 SP-132 17 SP-FH-019 17 SP-T-009 17 i

UFSAR Changes LOO 586 18 LOO 618 18 L00634 18 L00643 18 L00648 19 LOO 656 19 LOO 657 19 LOO 658 19 L00659 19-LOO 660 20 Other Core Operating Limits Report, Unit 1 Cycle 5 Rev. 3 20

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PECO ENERGY COMPANY LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 -

ANNUAL 10CFR50.59 REPORT i

JULY 1,1993 THROUGH JUNE 30,1994  :

SAFETY EVALUATION SUMMARIES - 1 I

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1 LIMERICK GENERATING STATION I UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 l LICENSE NOS. NPF-39 AND NPF-85  !

MOD 5711 Unit 1_ Unit 2_ Common x This modification installs permanent chemicalir ion equipment used to inject chemicals into the Raw Water Clarifier. This installation re es temporaryinjection equipment that was installed by Temporary Mod IM-017-001 anc :o removes original equipment that is presently not in service. The chemicalinjection eq 9 ment is provided by the vendor as a l preassembled skid. All installation activities are provided by the Station and are confined l to the Water Treatment Plant. This modification affects a section and figures of the UFSAR and is an overall enhancement to operations.

MOD 6071 Unit 1_ Unit 2_ Common x l This modification installed permanent piping to connect trailer mounted demineralizer skids to the existing water treatment plant piping, installed a permanent platform used to back the trailers up to, and relocated a silica analyzer sample line. The trailer mounted demineralizer j skids are presently being used to provide makeup demineralized water using temporary connections installed under Interim Modification 18-001. The installation of permanent l piping will serve to improve system reliability by eliminating the use of temporary hoses, and l l to increase the water treatment plant capacity by reducing the flow restriction within the j system. The relocation of the silica analyzer line will allow water quality sampling when a j new demineralizer trailer is flushed prior to being placed in service. This modification l affects a section and figures of the UFSAR and is an overall enhancement to operations. J MOD 6103 Unit 1_ Unit 2_ Common x This modification installed a new telephone switch in the second floor of the administration building with its primary power source from the administration building MCC 00B541. The secondary source of power will be from the turbine building MCC 20B129 which is powered from a Unit 2 Division 1 safeguard bus. An uninterruptible power supply with two hours of emergency battery backup power is also being provided to allow time for the control room operators to reconnect the load from MCC 20B129 after being shed following a LOCA signal. The existing telephone switch utilizes older technology and is being replaced under strategic direction from Corporate Telecommunications. This modification affected tables of the UFSAR and is an overall enhancement to operations and emergency response capability.

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LIMERICK GENERATING STATION  !

UNITS 1 AND 2 )

DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 I i

MOD 6136 Unit 1 x Unit 2_ Common _

i This modification added CO2 fire protection for the Turbine Generator Exciter Bearings 11 and 12 and heat and smoke detectors in the Turbine Generator Exciter housing for fire detection. This modification was installed to provide the Turbine Generator Exciter with a fire protection system to minimize property damage and unit downtime resulting from a postulated Turbine Generator Exciter fire. This modification affected several sections, figures, and tables of the UFSAR. The added components and systems are nonsafety-related and have no impact on safety-related systems. This modification did not affect any active or passive safety-related systems as described in the SAR.

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MOD 6140 Unit 1 x Unit 2 Common _

This modification removed 264 snubbers from Unit 1. The reduction of unnecessary snubbers reduced the number of snubbers that may require evaluation in the future as a result of not meeting snubber testing acceptance criteria. The reduced snubber population reduces the number of snubbers which will require future functional testing and visual ,

inspection each outage and, therefore, is a cost benefit to the plant. To justify the removal {

of snubbers from the piping system, engineering verified the acceptability of the remaining {

piping supports and structure to which the supports are attached. All pipe work and supports associated with ASME systems was performed in accordance with Section XI I requirements. The systems involved in this modification include: Main Steam, Reactor Recirculation, Main Steam SRV Discharge Lines, HPCI, RCIC, and RHR Shutdown Cooling. Under all conditions, the requirements for system operability as addressed in the i Technical Specifications are maintained. This modification affected several sections of the l UFSAR and is an overall enhancement to maintenance.

MOD 6145 Unit 1 x Unit 2_ Common _

This modification altered the removable reactor cavity ladder to make it possible to install the ladder in a location where it will not interfere with the removal of the drywell head.

This will allow the ladder to remain in place while the drywell head is being removed or installed. The reason for this proposed change is to reduce the refueling floor critical path and to eliminate the safety concern posed by not having a ladder available to access or exit l the reactor cavity when the drywell head is being lifted. This modification affected a figure of the UFSAR and is an overall enhancement to maintenance.

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LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 MOD 6147 Unit 1 x Unit 2_ Common _

This modification installed a cross connection between the Residual Heat Removal (RHR and the Fire Protection systems to provide an alteraate source of water to the drywell spray mode of operation of the RHR system. This cross connection would be used in the event of a " severe beyond design basis" accident in which alllow pressure Emergency Core Cooling System (ECCS) systems fail. At such a time, the cross connection would be made via a 6 inch fire hose and ability to spray the drywellwould be maintained. This modification affects several figures of the UFSAR. The RHR connection has the required isolation of a locked close gate valve along with a safety grade check valve and a cap. During all modes of operation as described in the SAR, the RHR/ Fire Protection cross connection will remain inactive. It would only be used for an accident beyond the design basis.

MOD 6148 Unit 1_ Unit 2_ Common x This modification expanded the Chemistry Laboratory and consists of an 8500 square foot annex that will be located along the w::st end of the existing Radwaste Enclosure and renovated 1360 square feet of existing space within the Radwaste Enclosure adjacent to the annex. The objective of the modification is to provide adequate space for present and future chemical laboratory operations and to provide proper environmental conditions for reliable instrument operations and personnel comfort. This modification affected several sections and figures of the UFSAR and is an overall enhancement to operations.

MOD 6194 Unit 1 x Unit 2 x Common _

This modification added four isolation valves to each loop of the Residual Heat Removal Service Water (RHRSW) system. The valves will be used to isolate the RHR heat exchangers and associated piping for both units in order to facilitate maintenance. This modification affected a figure of the UFSAR and is an overall enhancement to maintenance.

MOD 6208 Unit I _ Unit 2_ Common s This modification upgraded the existing yard near the spray pond for use as a storage pad for Low Level Radioactive Waste (LLRW). The availability of Barnwell to receive LLRW ended on June 30,1994. As a result, it is necessary to store LLRW on site until the regional Appalachian States Compact disposal facility is operational. This modification affected a section and a figure of the UFSAR and is an overall enhancement to operations.

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LIMERICK GENERATING STATION -

UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 4

LICENSE NOS. NPF-39 AND NPF-85~

MOD 6218 Unit 1 x Unit 2_ Common _

This modification removed the reactor recirculation pump stator high temperature trip. This trip function has caused a spurious trip of the IB recirculation pump in the past. The stator -

high temperature trip is provided for pump motor protection. A high temperature alarm and temperature indication is available to the operator to enable corrective actions to be taken without risking plant transients due to a spurious recirculation pump trip caused by erroneous or defective temperature instrumentation. Additionally, ground fault current and phase overcurrent trips are provided to protect the pump, wiring and penetration assemblies.

The temperature switches affected by this modification are classified non-safety related. This modification is an overall enhancement to operations.

MOD 6220 Unit 1 x Unit 2_ Common _

This modification relocated the condensate reject (Control Rod Drive (CRD) water supply) supply location, from the discharge side of the new condensate demineralizers to the discharge side of the newly installed deep bed demineralizers. With the implementation of the deep bed demineralizers, a higher quality deaerated water will be supplied to the CRD mechanisms and the reactor vessel. This modification will not affect the operability of the condensate, deep bed demineralizer, or CRD systems. This modification affected a figure of the UFSAR. The new supply location will provide higher quality water to the CRD system which may result in reduced CRD mechanism degradation. This modification is an overall enhancement to operations and maintenance.

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LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 MOD 6227 Unit 1 x Unit 2_ Common _

This modification replaced heat exchangers for the Residual Heat Removal (RHR) system heat exchangers 1AE205 and IBE205. Also, a new drain line was installed on each heat exchanger outlet pipe to expedite shell drainage. During a heat exchanger performance test and eddy-current examination, it was discovered that a number of the RHR heat exchanger tubes had experienced corrosion, predominantly in the form of pitting. Subsequent investigations concluded that the chemical content of the service water, exacerbated by layup

! techniques and chemical treatments of the heat exchanger, had induced the 304L stainless steel tubes to corrode. Changes in water treatment, layup, and chemical treatment policies were enacted to minimize further degradation, and the tubes with the deepest pitting were l plugged. A corrosion monitoring system was designed and installed to allow evaluation of any further corrosion during the next outage cycle. But it was decided that new tube bundles would be procured for replacement during the following refueling outage. It was concluded that replacement tube bundles fabricated from AL6XN alloy (or equivalent), a 6 - 7%

l Molybdenum stainless steel material that is highly resistant to the observed types of l corrosion, would be procured and installed. The AL6XN alloy represented the best l combination of materials investigated, considering resistance to corrosion, strength, weight, f heat transfer properties, direct ease of replacement, availability, and cost. It was j subsequently decided to have new shells fabricated to facilitate the installation of the shell {

and tube bundle assemblies. The new shells were fabricated using the existing material type, l carbon steel (SA516, Grade 70). This modification affected a section of the UFSAR and t is an overall enhancement to operations and maintenance.

MOD 6242 Unit 1 x Unit 2_ Common _

This modification replaced several existing SMB 000-5 Limitorque Actuators with SMB 00-10

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actuators. Drywell Chilled Water Isolation Valves HV-087-122,123,128, and 129 were l found to have increased operating force requirements requiring a larger valve motor {

operator. (Result of Generic letter 89-10 Program Testing.) Replacement of actuators with  !

larger units will ensure that the valves are capable of performing their safety-related function under design basis cond;tions. The previously existing actuators were at the limits of their capabilities with the torque switch settings set as high as possible and all reasonable conservatism removed from such settings. An increase in the output force (thrust) required an incr:ase in the size of the motor to deliver the necessary torque. To increase the motor size, a larger actuator was required. This modification affected a section and figures of the i UFSAR and is an overall enhancement to operations. l

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l L UNITS 1 AND 2 l DOCKET NOS. 50-352 AND 50-353 l 1 LICENSE NOS. NPF-39 AND NPF-85 MOD 6248 Unit 1 x Unit 2 x Common .

This modification modified the refueling platform to improve its reliability, reduce fuel handling time, ease future maintenance activities, and improve the commonality between the Limerick and Peach Bottom platforms. The items affected by this modi 5 cation include; mast camera system addition, platform utility receptacles modification, main & frame aux hoist load indicating switch relocation, platform intercom system mounting, and one boundary zone logic function. This modification affected a section of the UFSAR and is an overall enhancement to maintenance.

MOD 6249 Unit 1 x Unit 2_ Common _

This is the first of five computer replacement modifications. It will add new power distribution equipment in the Technical Support Center for the new Plant Monitoring System computer for Unit 1. It also revises the power distribution arrangement in the Unit 1 Inverter Room, deleting the existing Computer Static Inverter 10D161. Additional environmental monitors will also be sdded to the TSC Computer Room to allow better operator response to HVAC failures. "his modification affected a section and figures of the UFSAR and is an overall enhanceme at to operations.

MOD 8011 Unit 1_ Unit 2_ Common x This modification involved additions and renovations to the administration building. The physical location of the Operational Support Center (OSC) was relocated to the new Health Physics Field Office, adjacent to the East Access Facility, Urii 2 Turbine Building. This modification relocated the PAB boundary in the administration building ground floor to the outside east wall which was made possible by relocating the security processing function to the TSC. This modification makes changes to the Fire Sprinkler Systems which are included in the UFSAR. This modification is an overall enhancement to operations.

MOD P00008 Unit 1 x Unit 2 x Common x This modification installed 11 strainers and atmospheric barriers (caps) to the fire protection piping going to the Unit 1 and 2 main, auxiliary and safeguard transformers and the Unit 1 spare transformer. The strainers were installed outdoors downstream of the deluge valves.

The strainers are reqmred to resolve the current inadequate flow due to clogging of the nozzles on the transformer deluge system. Inadequate flowwas observed during surveillance testing of the Fire Protection system. An examination of the piping revealed substantial quantities of rust had accumulated within the non-galvanized underground carbon steel pipe.

The strainers and caps will prevent the nozzles from becoming clogged during future actuations. This modification affected a figure of the UFSAR and is an overall enhancement to operations and maintenance.

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LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 MOD P00058 Unit 1 x Unit 2 x Common _

This modification installed 19 manualisolation valves on selected Emergency Service Water (ESW) supply and return branch lines. The installation of these valves provided the capability to isolate certain sections of ESW piping to individual components without impacting ESW to other components. This results in less restrictive Tech Spec Allowed.

Outage Time, thereby permitting more time for repairs. This in turn reduces the potential for forced plant shutdowns to repair ESW leaks. This modification affected figures of the UFSAR and is an overall enhancement to maintenance.

MOD P00114 Unit 1 x Unit 2 x Common _

This modification revised the control logic for the cooling water valve, HV-056-1(2)F-059, i of the High Pressure Coolant Injection (HPCI) system. This change prevents potential flooding of the HPCI turbine as a result of the cooling water valve being open subsequent to securing the turbine. This modification changes the cooling water valve logic to mimic th open/close operation of the turbine stop valve. Therefore, when the HPCI stop valve closes, the cooling water valve auto closes preventing the potential flooding of the turbine.

This modification affected a section and a figure of the UFSAR and is an overall enhancement to operations.

MOD P00132 Unit 1 x Unit 2_ Common _

l This modification installed a reactor water level instrumentation reference leg backfill system l to prevent the build-up of non-condensible gases in the reference legs which can lead to reactor water level indication errors. Control Rod Drive (CRD) system water will be used to provide a continuous purge of each of the four reference legs. This modification affected a section and figures of the UFSAR and is an overall enhancement to operations.

MOD P00140 Unit 1 x Unit 2_ Common _

This modification upgraded the Unit 1 and Unit 2 Main Steam Isolation Valves (MSIVs) by replacing the valve internals with a better design in order to improve the seating

, characteristics of the valve and improve its leak rate reliability. The design included; a nose i guided poppet as a replacement for the standard poppet, larger diameter valve stem, new

( valve bonnet, and anti-rotation features on the stem and poppet. This new design has been used at numerous other nuclear utilities with great success. This modification affected a section and a table of the UFSAR and is an overall enhancement to operations and maintenance.

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LIMERICK GENERATING STATION -

UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-E MOD P000167 Unit I _ Unit 2. Common x This modification installed valve pits in the spray pond pump house yard next to buried Emergency Service . Water (ESW) and Residual Heat Removal Service Water (RHRSW) -

piping. The evaluation ensured that systems remained operable during the installation process as well as the final configuration. This work was performed to support installation of a future modification that will install ESW to RHRSW crosstie piping. . This modification -

affected a section and figures of the UFSAR and is an overall enhancement to maintenance.

MOD P00260 Unit 1 x Unit 2_ Common _

This modification installed vent piping for the bonnet cavities of Low Pressure Coolant Injection (LPCI) injection valves HV-051-1F017A&C. The vent piping now interconnects the valve bonnet cavity to the valve test connection located off of the body of the valve on the downstream side of the wedge. This vent path assures that pressure in the bonnet cavity.

is vented to the LPCI piping following a design basis accident depressurization event which' will in turn assure that HV-051-1F017A&C are able to open (not pressure locked). This modification affected a figure of the UFSAR and is an overall enhancement to operations.

MOD P00283 Unit 1 x Unit 2_ Common _

This modification installed a 2" diameter bypass drainage line downstream of the discharge

check valve for each Reactor Feed Pump (RFP) 1AP101, IBP101, and ICP101. The bypass '

is connected to the RFP discharge line (20"-DBD-101) and to the RFP minimum flow recirculation line (10"-DBD-106). It is designed to drain water from the 20"-DBD101 line and return it to the condenser hotwell through the 10"-DBD-106 line. Previously drainage of RFP discharge lines was accomplished by opening RFP discharge check valve bypass valve. Because of the presence of flow orifices in the line, draining the system took approximately 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br />. The new bypass line is expected to reduce this time to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

The 2" diameter bypass is utilized to drain the feedwater system during a refueling outage, and if required, to support maintenance of RFPs during plant operation. The bypass is installed in nonsafety-related portion of the feedwater system,just downstream of the RFP discharge check valves HV-105A, HV-105B, and HV-105C. This modification affected a figure of the UFSAR and is an overall enhancement to maintenance.

I MOD P00305 Unit 1 x Unit 2_ Common This modification installed a permanent ladder on top of the drywell head and a permanent ladder on top of RPV head insulation frame. The ladders are used during refueling outages to perform required reactor assembly and disassembly activities. This modification affected )

a figure of the UFSAR and is an overall enhancement to maintenance. 1 1

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LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 MOD ECR 93-00963 and 93-00965 Unit 1 x Unit 2 x Common _

This modification involves the installation and use of a resin slurry fill system for the condensate deep bed demineralizers. This system will consist of permanent plant piping, valves, and a hose connection off of each demineralizer vessel which will be used in conjunction with a portable skid mounted resin eductor and temporary slurry hose.

Demineralized water will be used as the motive fluid for slunying the resin out of the resin -

container to the demineralizer vessel. New permanent 2" diameter demineralized water connections will be provided for use with the skid mounted eductor. This resin slurry fill system replaces the vac-u-max air resin fill systems originally installed by Modification 5983-1 and subsequently removed due to poor performance. This modification affected a section and a figure of the UFSAR and is an overall enhancement to operations.

MOD ECR 93-01075 Unit 1_ Unit 2_ Common x This modification revised the control circuit for the Residual Heat Removal Service Water (RHRSW) pump trip logic. The relays associated with tripping the RHRSW pumps on high pump discharge pressure were replaced with time delay relays. Inadvertent pump trips had occurred during pump starts due to localized high pressure spikes. A nominal five seconds time delay was added to the high discharge pressure trip logic to eliminate the unnecessary pump trips. This modification affected a section and a figure in the UFSAR and is an overall enhancement to operations.

NOD ECR 94-05389 Unit 1_ Unit 2_ Common x This modification expanded the Inservice Testing (IST) boundary of the spray pond inventory makeup piping from valve 12-0031 to valve 12-1011. The quality classification for valve 12-1011 was upgraded from non-Q to 0-Active. These changes were made to provide better shutoff capability to prevent siphoning of the spray pond water in the event of a pump trip while making up to the sprey pond from the Schuylkill River. The change also reduces maintenance and IST testing. Valve 12-0031 is a check valve and is difficult to seat to prevent siphoning. Valve 12-1011 is a gate valve and provides pmitive shutoff. This modification affected a figure of the UFSAR and is an overall enhancement to operations.

MOD ECR 94-05848 Unit 1 x Unit 2 x Common _

This modification connected the lower air start subsystems to the aft main bearing oil

%oster pump on each of the Emergency Diesel Generators (EDGs). This increased the aliability of the aft main bearing in case of an emergency .; tart. This modification was in response to a commitment made in LER 1-93-013. This modification affected a section and a figure of the UFSAR and is an overall enhancement to operations.

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LIMERICK GENERATING STATION .

UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 MOD ECR 94-05940 Unit 1 x Unit 2. Common _

This modification deleted the Unit I Residual Heat Removal (RHR) system corrosion monitors which were originally installed under modification 6221. The corrosion monitors -

were installed to monitor the status of the 304 stainless steel tubes in the 1A and IB RHR heat exchangers. These tubes had experienced extensive pitting as a result of manganese deposition. Modification 6227 replaced the 1A and 1B RHR heat exchanger tubes with tubes fabricated from a material with superior corrosion resistance. Therefore, the corrosion monitors are no longer needed. This modification affected a section and a figure of the ,

UFSAR and is an overall enhancement to operations.

NCR 93-00301 Unit 1 x Unit 2, Common _

High Pressure Coolant Injection (HPCI) system pressure control valve PCV-056-1F035 contains certain parts which were not manufactured to ASME III requirements. This situation arose because the valve bonnet flange and bolts were not originally classified as part of the ASME III pressure boundary. This error was discovered by Target Rock Corporation in the course of responding to a customer inquiry ngarding the pressure retaining boundary definition for the valve. There have been no failures associated with the subject components. This NCR approved the temporary use-as-is of non-ASME III pans in HPCI valve PCV-056-1F035 until replacement ASME III parts were installed.

NCR 93-00309 and 94-00027 Unit 1 x Unit 2 x Common _

These NCRs discussed the main turbine mechanical trip test overspeed frequency. These NCRs recommended that Unit 1 and Unit 2 not be removed from service to perfonn overspeed testing as originally recommended by the manufacturer. Limerick is subject to l safety criterion involving probability of generating of turbine wheel missiles that could

damage safety related systems in the plant. One of the contributing factors in the probability I calculation is the probability of overspeed from overspeed protection failure. An overspeed test interval of 6 to 12 months was recommended by GE in a report titled, Probability of Missile Generation in General Electric Nuclear Turbines. Limerick committed to the recommendations of this report in the UFSAR sections 10.2.3.6. In order to perform this test, the unit must be unloaded, tripped, and physically oversped to the trip setpoint.

Conservative engineering calculations prove that the margin of safety to overspeed probability limits it, larger if the unit is left on-line until the next refueling outage. -

Therefore, the calculation supports that the unit be left on-lir.e, and if the unit is tripped for any reason, the overspeed test must be performed. Additionally, the operating probability limit will not be exceeded as long as the unit is trip tested during the next refueling outage.

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LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 ,

NCR 93-00321 Unit 1 x Unit 2 x Common _

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UFSAR Tables 8.3 disagree with the calculation for the Emergency Diesel Generator (EDG) loading. This calculation was conducted by Engineering to bring all plant loading documentation into agreement and was revised to agree with the Plant Loading Study. The results of this review showed that all 8 Diesel Generators remained within the Plant Technical Specifications. The disposition of the NCR is use-as-is with a documentation change. This disposition affected a figure of the UFSAR.

NCR 93-00335 Unit 1 x Unit 2 x Common _

A discrepancy was found between the Inservice Test (IST) program ML 008 and the Component Record List (CRL) regarding the O classification of Emergency Service Water system valves HV-011-011A, HV-011-011B, HV-011-015A, and HV-011-015B. ML-008 classifies these valves as O-passive and the CRL classifies them as O-active. These valves should be classified as O-passive in the CRL and the UFSAR (table 3.9-8). This is based on the fact that these valves are normally open, and do not have a safety function in the closed position other than to support fire safe shutdown. Valves HV-011-011B and HV-011-015A are normally open and are required to be closed in certain 10CFR50 Appendix R fire safe shutdown scenarios. It has been previously determined in Chemical Engineering Branch BTP 9.5-1, " Guidelines for Fire Protection for Nuclear Power Plants," that no additional quality requirements, beyond who is needed for reasons other than fire safe shutdown, shall be imposed on equipment used to ensure post fire shutdown capability. This determination is documented in licensing section " Interpretation of Quality As.;urance Program Requirements with Respect to Fire Protection Safe Shutdown Equipment." Therefore,if a valve's only active function is to support fire safe shutdown, it is not required to be treated as an active component under the Limerick Quality Assurance Program. The disposition of the NCR is use-as-is with a documentation change.

NCR 93-00342 Unit 1 x Unit 2 x Common _

During the preparation of Design Basis Document (DBD) L-T-02 " Containment," a discrepancy between the UFSAR and the design calculations was identified. The discrepancy involved the seismic acceleration values used in the design of the containment I class MC components (drywell head, containment locks and batches). The UFSAR lists one set of design accelerations which were originally used in the design of the class MC components. However, as the design progressed to include the effects of the Mark II d)namic loads, analysis showed that the class MC components would experience lower seismic accelerations. These lower accelerations were combined with the hydrodynamic accelerations and were used in the final design of the class MC components. The UFSAR was revised to include the correct values for the seismic accelerations.

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4 LIMERICK GENERATING STATION -

UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 NCR 93-00346 Unit 1 x Unit 2 x Common _

A data bank error regarding the J-factors for GE-11 fuel was discovered by GE Nuclear. j These J-factors are used try the plant process computer in the calculation of fuel bundle power distribution. Power distribution determination is the basis for the calculation of operating margins to Technical Specification operational thermal limits. GE Nuclear also determined that the data bank error could introduce a 2% non-conservatism in the process computer determination of plant operational margins to Technical Specification thermal limits. GE Nuclear issued a revised data bank and the LGS data bank was corrected and verified on August 10,1993. During tne intervening period (July 23 to August 20), LGS plant staff elected to verify compliance with plant thermal limit LCOs by administrative controls limiting operation period, LGS operated at all times with CMFLPD, MAPRAT and MFLCPR less than or equal to 0.98 thus maintaining adequate margin to Technical Specification thermal limits. The disposition of this NCR was use-as-is until the data bank was corrected provided the administrative 2% thermallimit penalty was maintained. GE Nuclear confirmed that the 2% thermallimit penalty recommended on July 23,1993 was indeed bounding.

NCR 93-00351 Unit 1_ Unit 2 Common x Unanchored lockers and cabinets located in the Main Control Room had the potential to interact with safety related control panels in the event of a seismic event. The condition was evaluated and it was determined that plant operation is not adversely affected, but the panels are required to be removed or properly secured. The disposition of the NCR was use-as-is until the lockers and cabinets are removed or properly secured.

NCR 93-00361 Unit 1_ Unit 2_ Common x The satellite meteorological tower equipment is obsolete and difficult to maintain. This NCR retired the satellite tower from service since this equipment is not required by the Offsite Dose Calculation Manual (ODCM) and eliminated the need to record data on strip charts at the base of towers 1 and 2 since this data is redundant to data recorded in the Main Control Room (MCR). Only one meteorological measurement location is necessary and the third location (the satellite tov,er)is not needed.

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, . LIMERICK GENERATING STATION UNI 131 AND 2 DOCKET NOS. 50-352 AND 50-353 l

LICENSE NOS. NPF-39 AND NPF-85

- NCR 93-00374 ~ Unit 1 x Unit 2 x Common _

The Residual Heat Removal (RHR) and Core Spray unit coolers are periodically heat transfer and flow verification tested in accordance with station procedures. Results from unit cooler tests and subsequent engineering analysis showed that the RHR and Core Spray maximum pump compartment temperatures would exceed the UFSAR maximum temperature limit of 115'F. Nonconformance Reports were initiated to address these unit coolers not meeting the design. As a result of the above, an engineering evaluation was performed which concluded that the maximum temperature limit in the RHR and Core Spray pump compartments could be raised to 140 F. Additionally, PECO calculation LM-414, Rev. O predicts maximum compartment temperatures for the RHR and Core Spray pump rooms for the LOCA scenarios analyzed in UFSAR Section 6.3. This calculation predicts that the maximum Post LOCA temperature for these compartments will not exceed 140 F.

NCR 93-00429 Unit 1 x Unit 2_ Common .

The manual air start valve 92-1304B on the Unit 1 D12 Emergency Diesel Generator (EDG) ,

developed an air leak through its exhaust port such that the air start subsystem feeding l engine cylinders 7 through 12 bled down to 90 psig. The leak was stopped by temporarily installing a plug in the port to restore the EDG to an operable status. This activity disabled the manual start capability on the affected air start subsystem. The disposition of the NCR was use-as-is until a final rewurk could b.: executed to replace the leaking valve. The automatic starting capability of both air start subystems remained unaffected by the installation of the plug.

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LIMERICK GENERATING STATION -

UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 NCR 93-00?34 Unit 1 x Unit 2 x Common _

The main steam line plugs are used during refueling to prevent loss of inventoy when the steam lines or the MSIVs are open for repair. The Westinghouse plugs were purchased to be an alternate to the existing GE plugr, because they are designed with some features which are compatible with wet lift operations and which may reduce refueling outage critical path time: two plugs can be installed simultaneously, installation can be performed with the reactor cavity flooded, the refueling platform auxiliary hoist can be used for plug installation thereby freeing the reactor enclosure crane, and the plugs are equipped with a vent to aid in main steam line draining and filling. This NCR was generated because the vent line on the plugs that were supplied is larger than specified in purchase specification NE-18. The main steam line plugs are Q components to insure sufficient water inventog is maintained over irradiated fuel during refueling. The vent size is an important parameter because it represents a potential for loss of water inventory from the reactor cavity. Specification NE-18 limited allowable leakage through a plug to a level equivalent to c 50 gpm makeup supply. Recalculating allowable leakage using the larger vent size and the actual geometry of the vent pipe yields a minimal impact on makeup water requirements. The inventory makeup capacity required to be available during refueling operations far exceeds the calculated 60 gpm leakage rate. Therefore, a slight increase in vent size is acceptable.

NCR 94-00004 Unit 1. Unit 2_ Common x This NCR was generated as a result of the UFSAR text discrepancies in sections 9.4.8.2 and 9.4.8.2.2. The NCR was generated to evaluate the as-left condition of the hot tool room installed per Mod 6050-0. The as-left condition was actually a decon room maintained at a negative pressure in lieu of a hot tool room which had been maintained at a positive pressure. The mod abandoned dust collector 00Y-5008; however, the UFSAR text was not changed in the UFSAR change generated for the mod. Additionally, the mod did not address the Offsite Dose Calculation Manual (ODCM). The as-left condition was determined to be acceptable and the UFSAR and the ODCM were revised.

NCR 94-00014 Unit 1 x Unit 2 x Common _

The UFSAR Change revises statements regarding DC component sizing and ratings to reflect the as-built configuration of the plant. This NCR evaluated the interim disposition to permit continued use of existing plant ECCS inverters until more efficient inverters were l

procured. Loads on the inverters exceeded the original sizing criteria. Calculations and testing criteria for the battery were changed until the inverters were replaced. The existing battery loads permitted this change, and all testing performed satisfactorily validated the capacity of the batteries.

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LIMERICK GENERATING STATION ,

UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 NCR 94-00041 Unit 1 x Unit 2 x Common .

The UFSAR and the Component Record List (CRL) incorrectly described the Reactor Recirculation pump discharge valves (HV-43-1(2)F031A/B) as active safety-related components. This required that the valves be tested in the Inservice Testing (IST) program.

A review of the operating requirements of the valves concluded that the valves are passive safety-related valves and can be removed form the IST program. The disposition of the NCR is use-as-is with a documentation change.

NCR 94-00067 and 94-00084 Unit 1 x Unit 2_ Common .

This NCR evaluated the existence of some "losi parts"in the Unit I reactor vessel. These parts, a piece of a tungsten welding electrode and possibly some small pieces of a steam separator tube, and the cumulative effects of other previously lost parts will not compromise safe reactor operations. The NCR concluded there: is no concern for fuel bundle flow blockage, no concern for interference with control rod motion, and no concern for adverse chemical or corrosion reaction. The disposition of the NCR was use-as-is.

PROCEDURE A-C-134 Unit 1 x Unit 2 x Common _

This procedure titled, " Hazard Barriers," provides for the control of doors and hatches in the safety-related areas of the plant to protect safety-related equipment. Modification 6227 replaced the Residual Heat Removal (RHR) heat exchangers on Unit 1. To support transportation of the heat exchangers into the Reactor Building, Doors 195 and 203/ Unit 1 Reactor Enclosure Truck Bay /must be opened simultaneously. An exemption to procedure A-C-134 was approved for the transportation of the heat exchangers into and out of the Reactor Enclosure. The evaluation concluded that alternate compensatory measures were adequate to ensure operability of required equipment.

PROCEDURE GP-3 and ST-6.076-360-1 Unit 1 x Unit 2. Common _

These procedures provide instructions for plant shutdown and testing of the Unit 1 Reactor Enclosure Secondary Containment ventilation system. These procedures were revised to allow for the extension of Secondary Containment Boundary out to the Refuel Floor Area Enclosure to permit removal of one layer of drywell head shield plegs during the start of the refueling outage. This will prevent the Unit 1 Reactor Enclosure ventilation system from potentially overpressurizing the Refuel Area on a Fan Failure, due to the Blowout Panel Setpoints being different in the Reactor Enclosure and Refuel Enclosure.

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l- LIMERICK GENERATING STATION -

UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 PROCEDURE GP-5 Unit 1 x Unit 2_ Common x ..

This procedure titled, " Plant Operation," was revised to make changes for coastdown to reflect the increase in allowable feedwater heating temperature reduction. Steps were added for removal of the 5th stage feedwater heaters and a new graph of allowable feedwater temperatures was added. The limit on maximum core flow was also changed to accommodate maintaining a constant Reactor Recirculaticn Pump speed during coastdown.

This change also included the Core Operating Limits Report (COLR) Unit 1, Cycle 5, Rev.

2. The COLR revision reflected a new analysis from GE which increased the allowable reduction in feed water temperature from 60 F to 105 F.

P.ROCEDURE IC-11-02029 and IC-11-02031 Unit 1 x Unit 2 x Common i

i These procedures provide instructions for performing maintenance on battery cells of safety-i '

related batteries while maintaining the battery and the DC electrical system operable. The procedures provide details on connection of the seismic battery cart to the safeguard batteries.

PROCEDURE RT-2-092-901. 902. 903. 904-1 Unit 1 x Unit 2_ Common .

1 These procedures titled, " Calibration of D11 (12,13,14) and D114 (124,134,144) Load Center Transformer Protective Relays and Instruments," provide direction on performing divisional 4KV protective relay and instrument calibrations while the division is energized.

The procedures involve removal of divisional safeguard bus instruments and protective relays l from service for calibration while the bus is energized. The instruments are ammeters, ~-

I voltmeters and voltage transducers. The relays are overcurrent and differential phase current relays. The relays provide bus protection from fault conditions by providing isolation. They do mt provide for load secuencing or transferring. The design of both the

! relays and instruments allows for removal and installation without disturbing the energized i bus. Defeating the function of each protective relay, one at a time, for less than one minute l will not adversely impact operability of the associated bus.

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B LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 PROCEDURE SP-132 Unit 1 x Unit 2_ Common _

This procedure provides for the establishment and monitoring of core circulation as an alternate means of reactor coolant circulation during the IR05 outage in order to support the jet pump hold-down be-am replacement activity. In the event that the team performing the beam replacement experiences difficulties completing the work with forced circulation

  • in effect (from RHR SDC or Recirc), an analysis was performed of natural core coolant circulation which is unique to the expected 1R05 outage reactor conditions with a decay heat load of approximately 4 MW thermal. As a demonstration of the establishment of natural circulation, the subject procedure will direct periodic measurement of temperatures in the reactor vessel downcomer area, at the core exit area, and near the surface of the refueling canal.

PROCEDURE SP-FH-019 Unit I _ Unit 2_ Common x This procedure titled, "Shoreham Irradiated Fuel Unpackaging and Inspection," was written to provide instructions for installation and removal of the fuel packaging machine and for fuelinspection associated with the Shoreham fuel. Use of this equipment is not described in the UFSAR. As part of the effort to transfer slightly irradiated fuel from the Shoreham Station to the Limerick Generating Station numerous plastic spacers are to be inserted into the unchanneled bundles prior to transport. Once the bundles arrive at Limerick these plastic spacers need to be removed from the bundles prior to re-channeling. The spacers will be inserted, and removed, by a Fuel Packaging Insertion and Removal Tool. The Fuel Packaging Insertion and Removal Tool consists of a supporting frame, process control system, an index system, and separator magazines installed on a support frame which will be mounted over the curb of the fuel storage basin. Following the removal of the rods and re-channeling of the individual bundles the machine was removed from the site. Operation of the machine will not alter any assumptions previously made in evaluating the radiological consequences of an accident described in the SAR.

PROCEDURE SP-T-009 . Unit I _ Unit 2 x Common .

This procedure titled, " Unit 2 Feedwater Tracer Test, " was revised to include critique items from the previously performed Unit 1 test. This test uses sodium-24 to accurafdy measure feedwater flow and the results are used to calibrate the feedwater flow inecrumentation.

This procedure involves a test not described in the SAR and does not involve an unreviewed safety question.

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LIMERICK GENERATING STATION - l UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85

.UESAR CHANGE IA0586 Unit 1 x Ut.it 2 x Common This UFSAR change revised UFSAR section 8.3.1.1.3.3. This section stated that the diesel generator " fail to start" relay (SFR) deenergizes the shutdown relay and governor shutdown solenoid. This statement conflicted with the plant configuration and vendor wiring schematics. The SFR will deenergize the " start relay" and the " ready for auto start" relay to prevent another start of the diesel. The UFSAR change revised this paragraph to incorporate the correct logic description. There were no physical changes to the facility as a result of the change.

UFSAR CHANGE IA0618 Unit 1. Unit 2_ Common x This UFSAR change was initiated to remove three sentences from the UFSAR that did not reflect current practices for periodic testing ofinstrumentation and control equipment. The UFSAR contradicts itself in the same paragraph by saying that lifting leads for surveillance tests is permitted and then not permitted. Currently, the station does lift leads in a limited number of tests. The revised controls listed in the UFSAR are consistent with an NRC Information Notice (84 37) which dealt with lifted leads and listed several steps to ensure the leads are returned correctly.

UFSAR CHANGE L00634 Unit 1 x Unit 2 x Common _

This UFSAR change increases the maximum High Pressure Coolant Injection (HPCI) and Reactor Core Isolation Cooling (RCIC) system room temperatures from 120 F to 140 F and deletes the minimum cooler flows. Also, the heat transfer rates for HPCI and RCIC pump rooms were updated. The UFSAR change is to reflect the revised EQ and LOCA analysis relative to ECCS room heat loads.

UFSAR CHANGE L00643 Unit 1_ Unit 2_ Common x This UFSAR change removed the charcoal absorber from the Radwaste Enclosure Ventilation System. This removal was desimble since the charcoal did not pass its surveillance test due to excessive moisture carryover from the radwaste tanks vented by this system. The safety evaluation determined that the charcoal absorber had not been considered in calculated releases and that there would be no adverse affect to removing it from the system.

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  • LIMER!CK GENERATING STATION s UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 UFSAR CHANGE LOO 648 Unit 1 x Unit 2 x Common _

This UFSAR change deleted the seal cooling requirements for Unit 1 and Unit 2 Residual Heat Removal (RHR) pumps. The justification is based upon an analysis done by the seal manufacturer which concluded that based on the required operating conditions of the seals that seal cooling is no longer required. The impact of closing the seal cooling valves on the Emergency Service Water (ESW) system was evaluated. The conclusion was that closing the seal cooler valves would not increase the probability of ESW pipe failure due to corrosion or biological activity. The reason is that no flow through the pipe will result in an oxyg:n and nutrient deficient atmosphere which is not conducive to biological activity.

UFSAR CHANGE L00656 Unit 1_ Unit 2 Common x This UFSAR change revised Section 12.3.4.2 to eliminate references to Maximum Permissible Concentration (MPC) and MPC hou4s. The new 10 CFR 20 was implemented 1/1/94 uses Derived Air Concentrations (DAC) and DAC hours. This change also revised the requirement to obtain grab samples for all Continuous Air Monitor (CAM) alarms since grab samples are not always necessary (i.e., when the cause of the alarm is known).

UFSAR CHANGE LOO 657 Unit 1_ Unit 2_ Common x This UFSAR change revised section 12.3.4.1.3 to eliminate the requirement for remote readout on the Area Radiation Monitor (ARM). It also clarifies that a portable alarming dose rate meter is required only during fuel transfer operations.

i UFSA.R CHANGE LOO 658 Unit 1. Unit 2_ Common x This UFSAR change revised section 9.1.3.2.3 on fuel pool demineralizer egeneration

. criteria. The change deleted the requirement to regenerate the demin based on dose rate and airborne limits. These requirements resulted in premature regeneration and extra radwaste. The demins are to be changed out on high differential pressure or low decontamination factor. The decontamination factor criteria is more appropriate for maintaining doses ALARA and for minimizing radwaste.

UFSAR CHANGE LOO 659 Unit 1_ Unit 2_ Common x This UFSAR change revised section 4.4.6.1.4 to delete a paragraph regarding minimization of radiation exposure from the operation section of the Loose Parts Monitoring System. The minimization of radiation exposure is applicable to all plant work and is covered in UFSAR Chapter 12, 19

LIMERICK GENERATING STATh0N .

UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 UFSAR CHANGE LOO 660 Unit 1_ Unit 2_ Common x This UFSAR change revised UFSAR section 12.5.2.1.7 to remove the statements which allow personnel to perform a self decontamination. Only HP personnel are currently trained on ~

proper decontamination techniques.

Core Operating Limits Report. Unit 1 Cycle 5 Rev. 3 Unit 1 x Unit 2_ Common .

This revision established the upper limit for core flow as the most limiting of one of the following three factors; recirculation pump speed not to exceed 1500 rpm (due to a concern -

with Jet Pump sensing line vibration), core flow limited by the MG Set electrical and mechanical stops, or core flow limited to 110 Mlb/hr. During coastdown the flow resistance through the core decreases, requiring less drive flow (Recirc Pump speed) to maintain a given core flow. This coupled with the fact that the MG Set stops are based on rated power and ilow conditions (100% Power /100% Flow), allows the unit to eventually operate at 110%

core flow during coastdown. The limit on Recirc Pump speed should prevent the MG Set stops from becoming the limiting factor.

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