ML20196D580
| ML20196D580 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 12/05/1988 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Wenzinger E NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8812090137 | |
| Download: ML20196D580 (3) | |
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PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 f
12151841 4500 JOHN S. MEMPER SEN40m vlCE PRESIDENT. NUCLE A R December 5, 1988 i
Mr. E. C. Wenzinger Chief, Projects Branch tb. 2 2
Divistcn of Rcactor Projects U. S. Nuclear Regulatory Ccmnission Docket No. 50-353 ATTN: Documnt Control Desk Mall Station P1-137 Wa,hington, D.C.
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Subject:
Limerick Generating Station, Unit 2
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Inspection Report No. 30-353/88-25 i
Site inspection from 9/12/88 to 10/16/88 j
Dear Mr. Wen:
Inger:
Your letter dated thvenber 3,1988 forwarded inspection Report Pb. 50-355/88-25 for Limerick Generating Station Unit No. 2.
Appendix
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A of your letter addressed one item thich does not appear to be in full ccrm11ance with Nuclear Regulatory -* f oston requirtanents and re-cuested a response within 30 days.
, item is restated in Attach-l L
ment A folicwed by our ccrmlete ren.nse.
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If you need addittor:a1 Information or have any questions, please do not hesitste to contact us.
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Sincerely, E
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l ERG /ds/12018802 7
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Attactrient
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R. J. Clark, UStRC Project Manager
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i W. T. Russell, Actninistrator, Region I. USNRC l
j R. A. Granin, USNRC Senior Resident inspector, LGS-2 i
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i G812090137 881205 5
PDR ADOCK 05000353
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PDC s
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w ATTACHOJT A Violation:
"10 CFR 50, Atpendix B, Criterlon 111 states thct the system design basis shall be correctly translated into design drawings.
The Limerick Final Safety Analysis Report section 7.6.1.8.3.3 states that the Redmdant Reactivity Control System initiation shall cause a feodwater punp runback to zero percent ficw within 15 seconds.
General Electric Design specification 22A7477 further states that either logic division of the Redundant Reactivity Control systm shall be capable of causing the feedvater punp runback.
Contrary to the above, on Septenber 27, 1988, Gencral Electric elementary diagram 791E408TR sheet 5 for the feedvater runback circuit was found to depict a wiring conflquration that would not provide the full feedwater purnp runback frcrn either of the independent logic divisions.
The plant wiring was found in accordance with the erroneous design drawing."
This is a Severity Level IV violation.
Response
_ Admission or Denial of Alleged Violation Philadelphia Electric Carpany acknowledges the violatinn as stated.
Reason for Violation The wiring configuration deficiency was apparently due to inade-quate design incorporation of a Unit I design change into the Unit 2 design. Design deficiencies were Identified on Unit 1 and were cor-rected by issuance of a Fleid Deviation Disposition Request (FDDR).
Design review perforred by the vender recognized Unit 2 appilcability of the Unit 1 FDDR but failed to initiate a Unit 2 FDDR which would have Irvlermnted the des tgre change.
Significance of Violation There is rn safety significance to this event. The Redundant Reactivity Ccntrol Systne is a two-divisional system designed to mitigate the potential consequences of an anticipated transient wittout scram (ATWS) event. The wiring discrepancy, iaft unchecked, would defeat the single failure criteric of the systun, however, it would have had an impact on the functinnat test and would have been found during normal preoperational testing.
. s Corrective Action Taken and Results Achieved PECO Finding Report 2N-633 and GE FDDR-HH2-6630 were prepared and issued to address this discrepancy.
Per the recemnendation of this Finding Report, GE reviewed 310 FDDRs to determine if Unit 2 action was required.
These 310 FDDRs were Identifled from the original 198h review of 3500 FDDRs, as still needing a Unit 2 FDDR.
Flvo (5) additional Unit 1 FDDRs were found that required Unit 2 action; these FDDRs were written and are in the Issue cycle.
They are FDDRs m2-6674, HH2-6675, HH2-6676, HF2-6677, and HH2-6685.
Four (4) of these FDDRs were documnt only discrep-ancies.
The fifth required a hardware change; the removal of a redundant wire, which was a suspected ground loop. The wiring discrepancy v.tilch was identifled by the NRC would have had an Irvact on the functional test, thereforo vould have been round during Blue Tag and Preoperational testing.
The wiring discrepancy found during the review by GE would not have been detectable during testing because it has no f'unctional impact on any systml.
The doctr,entation discrepancies were minor and would have no effect on functional performance.
Corrective Action Teken to Avold Future Non-Ccnpilance The above action was sufficient to assure th7t all FDDRs written against Unit I were reviewed for impact on Unit 2 and if a Unit 2 FDDR was required it was written.
GE reviewed approximately 3500 Unit 1 FDDRs, in 19FL, for oppilcability to Unit 2.
This review was initiated when the Unit 2 design freeze was rerrr;ved.
Of the 3500 FDDP.s reviewed, 1500 vare identified as needing a Unit 2 FDDR. Of these 1500, all but 310 were covered by existing FDDRs.
These 310 FDDRs were reviewed in Noventer of 1988 to assure that they were Ircorporated into the Unit 2 design.
During this review, 6 vare Identified as still requiring a Unit 2 FDDR.
Four (4) of these vere doctinentation errors and two (2) were wiring changes, one (1) of which was the wiring problem addressed in the finding.
In addition, for the period frcn 1984 to date, all Unit 1 FDDRs were reviewed, at the time they were generated to determine a Unit 2 inpact and if any, a Unit 2 FDDR was processed.
Based on the exterciely Icw incidenu of error (
<.2%) and the adecuacy of the present practices, no significant Irprovement would be reallred with additional training or procedure revision. Therefore, no further action is planned.
Date When Full Corrollance Will Be Achieved The six FDDRs which have been issued to eddress this discrepancy will be Incorporated into the plant design prior to Unit 2 fuel load.
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