ML20206C157

Interim Deficiency Rept 249-2 Re Nonavailability of Safe Shutdown Capabilities from Outside Control Room in Event of Fire.Initially Reported on 881006.Design Change Will Be Performed.Root Cause of Condition Still Under Evaluation

ML20206C157
Person / Time
Site:	Limerick
Issue date:	11/04/1988
From:	Kowalski S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Russell W NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
249-2, NUDOCS 8811160128
Download: ML20206C157 (3)

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J PHILADELPHIA ELECTRIC COMPANY 230i MARKET STREET I

P.O. BOX 8699 5

PHILADELPHI A. PA.19101 l

(a s s) edi.4soa j

"df.",$7.N',",

November 4, 1988 l

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Mr. William T. Russell Docket No. 50-353 4

1 Regional Achinistrator U.S. Nuclear Regulatory Ccnmission Region i Attn Docment Control Desk i

Washington, DC 20555

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Subject:

Significant Deficiency Report No. 249-2

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Interim Report for the ibn-Availablilty

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of Tafe Shutdown Capabilities frcm Outside i

j the Control Roon in the Event of a Fire l

l Lirerick Generating Station - Unit ?

1 PRC Construction Permit No. CPPR-107 l

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Reference:

Telecon of PECo to NRC dated October f>,1983 l

Flie:

QUAL 2-10-2 (SDR tb. 249-2)

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Dear Mr. Russell:

f We have determined that the stbject deficiency is reportable and i

in empilance with 10CFR Part 50.55(e) we hereby sutritt an interim J

j report. The Philadelphia Electric Ccnnany discussed this condition by telephone with the USNRC Region 1 Office on Octcher 6, 1988, after It

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was determined that this rny be a reportable incident, j

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A PECo-initiated review of work done to support the LGS Fire l

1 Protection Evaluation Report (FPER) determined that scrw Instrtrwnta-l tion required to support safe shutdown frcm outside the control recrn j

in the event of a fire tray not be available as described below.

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Section 5.2.3 and Table A-23 of the LGS FPER Identlfles reactor l.

water level and reactor vessel pressure Indication as being available to support safe shutdem frcm outside the control rom (Shutdcun Method R).

Contrary to these cermitrwnts, ac power to these Instrments, I

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Wilch are located on the Renote Shutdcwn Panel (RSP), ruy be un.

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j available unt ti rmnual actions to restore ac power are ecroleted.

l The possible unavailabill) e of all ac pcwer.ntt i rerual actions j

are cm pleted would be a result of both tha design basis fire and the j

consequences of fire danage. Regulatory recuirements tripose the ar.smption of a loss of offsite pcwer concurrent with a non-8811160128 881104 I

ADOCK 0500 g,

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mechanistic, all constming fire. For Shutdo m Method R, a loss of onsite ac pover rnay result frcm fire danage to the circuits for ESW p

valves supplying Jacket cooling for all the diesel generators. Without

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Jacket cooling, the diesel generators will trip on high tenverature f

and cannot be returned to service until rnanual actions to restore ESW and the diesel generators are concleted.

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In addition, if tha fire damage occurs before an operator rmnually f

positions isolation switches at the rmote shutdown panel, dernage rmy I

occur to the RCIC speed controller and fluv tranunitter such that control of RCIC frctn the RSP and the control rocm rnny not be available i

because these ccroonents are used to support RCIC operation and control frcm both locations.

1 Considering the above failures with respect to the asstrmtions associated with a design basis fire, a viable safe shutdown r ethod frcm outside the control room does not exist. This condition is in conflict i

with ccrTiltinents rmde in the LGS (FPER).

t As permanent corrective action, a uesign change will be performd l

l to provide the RSP reactor water level and reactor vessel pressure Indicators with a de poer source that is continuously available in the event of a design basis fire in Fire Areas 23, 24, and 25.

In addi-l tion, a design change will be performed to provide the ASP with RCIC i

controls and ficw Indication that are not subject to fire damage in the l

event of a design basis fire in Fire Araas 23, 24, and 25. These i

design changes will be ccurleted prior to start o af Unit 2.

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We are still in the crocess of evaluating the root cause of this i

condition. Up:41 determination of the root cause, subsequent corrective j

j actions to prevent recurrence end a schaquie for ccrmletion of these r

1 actions will be Identified, if required. The root causes, corrective

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actions to prevent recurrence, and schedule for cctmietion of thess j

acticca, as required, will be provided by February 1,1989.

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This issue was recognized to be apollcable to LGS Unit 1 and the i

I appropriate PRC rotifications have been rnade.

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Sincerely, t

f Ces/sw/1101E801 1

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.' t Copy !.o:

W. T. Russell, Administrator United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 i

R. A. Gramm, Senter Resident Inspector i

Limerick Generating Station - Unit 2 U.S. Nuclear Regulatory Commission P.O. Box 46 Sanatoga, PA 19464 L

R. J. Clark, Project Manager i

Division of Reactor Projects - i, !!

i U.S. Nuclear Regulatory Cornission Mall Stop 14C-21 Washington, DC 20555 i

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