ML20107F942
| ML20107F942 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 02/13/1985 |
| From: | Cooney M PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| CON-#185-777 OL, NUDOCS 8502260241 | |
| Download: ML20107F942 (4) | |
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s-2 PHILADELPHIA ELECTRIC COMPANY
-i 2301 M ARKET STREET g
P.O. BOX 8699 al PHILADELPHI A. PA.19101 1
(215) 841-5020 M. J. COONEY NUC%E Aft PM DUC T ROM ELECf tt*C PRODuGTsON D EP AstTha E NT 2
i February 13, 1985 3=
Docket No. 50-352 j
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Mr. Thomas T. Martin, Director d
Divicion of I:ngineering and Technf t Programs U.S. Nuclear Regulatory Corimiccic:
Region I 631 Park Avenue T
King of Prussia, PA 1940G
Dear 2:
- r. Martin:
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Your lutter of January 14, 1985, forwarded Inspection
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!fo. 50-352/04-68 which cited an activity at Limerich Generating f
Station which did not appear to be in full compliance with NEC requirements.
This apparent violation in restated below followed by.our response.
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Finding la Technical Specification 6.3 requiren that written procedures.be established, implemented, and maintained covering, among other activities, surveillance and tect activitien of cafety-related g
y equipment.
Surveillanco'Tcat Procedure ST-2-078-402-0, provides yj requirenants for calibrating uafety-related chlorine detectors located in the air intake of the Control Enclosure.
Section 6 of y
s this procedure requires that "Aa round" chlorine detector readout
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data be compared with tho acceptance limite found in Tables 1 ij through 4 of the proceduro.
If "As Found" data is found not to be within the apccified limits, the detector is to be recalibrated, or if recalibration cannot be perforned saticfactorily, ahift suporvision in to be notified and the detector is to ba repaired'and/or replaced.
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8502260241 950213 q
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I-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 review of Control Enclosure chlorino detector surveillance tests was initiated.
It was determined that the calibration surveillance test (ST-2-078-402-0) performed on November 1, 1984 on the "C" detector (AIS-78-01CC) contained 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 1 16 of 0.5 ppm Chlorine.
The surveillance test was signed o..
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 rechecked 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 of time.
that this condition existed, the technical consequences of.this event are small.
- Upon discovery of the situation, the responsible instrument technicians were counseled on the importance of properly following procedures and ensuring that "As Left" values are within acceptable limits.
This counseling was accomplished prior to the technicians' return to work on November 28, 1984, the day after the problem was discovered.
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Mr. Thomas T. Martin February 13, 1985 Page 3 i
To prevent recurrence, a training program for the instrument L
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
. 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
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the' Technical Specifications, the specification for the chlorine analyzers does not list both a setpoint and an allowabic value but rather a setpoint of less than 0.5 ppm.
I-Should you have any questions or require further
' information, please contact us.
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_truly yours,
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- Dr. T. E. Murley,. Administrator
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.Mr. J. T. Wiggins, Senior. Resident Inspector See-Attached Service List Y
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cc:
Judge Helen F. Hoyt Judge Jerry Harbour
. Judge Richard F. Cole Troy D. 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 Gerucky Director, Penna. Emergency Management Agency Angus Love, Esq.
David Wersan, Esq.
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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-
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Timothy R. S. Campbell 4
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' January 16, 1985:.
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