ML20107C665
| ML20107C665 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 02/13/1985 |
| From: | Murley T PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8502220020 | |
| Download: ML20107C665 (4) | |
Text
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i PHILADELPHIA ELECTRIC COMPANY 23O1 M ARKET STREET P.O BOX 8699 PHILADELPHIA. PA.19101 (2s s) s4i-sozo M. J. COON E Y NUCLE PRODUCTaO4 ELECTRec PRODUCTION DEP ARTMENT February 13, 1985 Docket No. 50-352 Mr. Thomas T. Martin, Director Division of Engineering and Technical Programs U.S. Nuclear Regulatory Commission
. Region I 631 Park Avenue King'of Prussia, PA 19406
Dear Mr. Martin:
Your letter of January.14, 1985,. forwarded Inspection No.-50-352/84-68 which cited an activity at Limerick Generating Station which did not appear-to be in full compliance with NRC requirements.
This apparent violation is restated below followed by our response.
Finding Technical Specification 6.8 requires that written procedures be established, implemented, and maintained covering, among other
-activities,' surveillance 1and test activities of safety-related equipment.
Surveillance Test Procedure ST-2-078-402-0,- provides
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requirements for calibrating safety-related chlorine detectors located in the air intake.of the~ Control-Enclosure.- Section'G of
.this procedure requires that "As Found" chlorine detector readout
- data be_ compared with the acceptance limits.found-'in Tables 1 through 4.of-the procedure. 'If "As Found" data is found.not to be-within.the specified limits, the detector is to'be recalibrated, or if recalibration'cannot be performed satisfactorily, shift supervisionJis to.be notified and the
- detector is to be repaired and/or replaced.
8502220020 850213 E
DR ADOCK 05000352 PDR I
t;oI f
a-
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s Mr.' Thomas T. Martin February 13, 1985 Page 2 Contrary to the above, during performance of ST-2-078-402-0, on November 1, 1984 "C" chlorine detector "As Found" trip set point exceeded the acceptance limit specified in Table 2 of the procedure, and the detector was not recalibrated; shift supervision was not notified and the detector was not repaired or replaced.
This is a Severity Level IV violation.
(Supplement I)
Response
On November 27, 1984, a reviou of Control Enclosure chlorine detector surveillance tests was initiated.
It was determined that the calibration surveillance test (ST 078-4 02- 0 ) performed on November 1, 1984 on the "C" detector (AIS-78-016C) contained
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data which was not within acceptable values.
The "As Found" and "As.Left" trip set points were 8.17 milliamps.
This was higher than;the procedure upper acceptable value of 8.16 milliamps which corresponds to the Technical Specification limit of 0.5 ppm Chlorine.
The surveillance test was signed off as " Satisfactory" although the specified test criterion was not met.
During the review of.the surveillance test results it was also determined that on the day after the above calibration was performed, ST-2-078-600-0 " Chlorine Detection System-Control Enclosure Air Intake Chlorine Detector, Channels A & C Functional Test";was performed.
The functional test, performed every 31 days,.:also checks the trip set point of AIS-78-016C.
This test documented the "As Found" trip set point as above the acceptable limit.
As directed by the procedure, the detector was-recalibrated and reche'cked.with'the "As Left" trip' set point correctly'below the acceptable _value.
As a result of the small deviation'from the acceptable value and the short period ofl time-
. that this~ condition existed, the technical consequences of this
- event are small.
~ Upon discovery 1of the situation, the responsible instrument.
technicians;were counseled on-the importance offproperly-following procedures and ensuring!that "As Left"~ values are withinfacceptable. limits...This counseling wasfaccomplished prior toithe. technicians' return to work on November-28, 1984, the day after.the problem was discovered.
f N
t Mr. Thomas T. Martin February 13, 1935 Page 3 To prevent recurrence, a training program for the instrument technicians was modified to stress adherence to administrative procedures and the importance of complying with surveillance test requirements.
All PECo and vendor instrument technicians have attended this program.
In addition, the once/31 day chlorine detector functional t
surveillance tests have been revised to provide margin between the acceptable values and the Technical Specification limit.
The once/18 month chlorine detector calibration surveillance tests will be revised by May 1, 1985 to provide margin between the acceptable values and the Technical Specification limit.
It should be noted that, unlike most instrument specifications in the Technical Specifications, the specification for the chlorine analy crs does not list both a setpoint and an allowable value but rather a setpoint of less than 0.5 ppm.
Should you have any questions or require further information, please contact us.
Ve*
truly yours, h
cc:
Dr. T.
E. Murley, Administrator Mr. J.
T. Wiggins, Senior Resident Inspector See Attached Service List
i cc:
Judge Helen F. Hoyt Judge Jerry Harbour Judge Richard F. Cole Troy B. Conner, Jr., Esq.
Ann P. Hodgdon, Esq.
Mr. Frank R.
Romano Mr. Robert L. Anthony Ms. Phyllis Zitner Charles W.
Elliott, Esq.
Zori G. Ferkin, Esq.
Mr. Thomas Gerusky Director, Penna.-Emergency Management Agency Angus-Love, Esq.
David Wersan, Esq.
Robert J. Sugarman, Esq.
Martha W. Bush, Esq.
Spence W. Perry, Esq.
Jay M. Gutierrez, Esq.
Atomic Safety & Licensing Appeal Board Atomic Safety & Licensing Board Panel Docket & Service Section (3 Copies)
James Wiggins Timothy R. S. Campbell i
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(
January. 16, 1985
)