ML20244A547
| ML20244A547 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 06/02/1989 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Reed C COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML20244A551 | List: |
| References | |
| NUDOCS 8906120068 | |
| Download: ML20244A547 (3) | |
See also: IR 05000454/1989009
Text
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JUN
21989
Docket No. 50-454
Docket No. 50-455
Commonwealth Edison Company
ATTN: Mr. Cordell Reed
Senior Vice President
Post Office Box 767-
Chicago, IL 60690
Gentlemen:
This refers to your response dated May 22, 1989, to Inspection Report No.
(50-454/89009; 50-455/89006) dated April 13, 1989.
In your response you requested that we reconsider violation No. 3 issued for
failing to address all acceptance criteria.for the post-modification test for
Modification M6-2-87-132. After review of the information you submitted, we
conclude that the violation is valid and a response is required.
The post-modification. test provided seven acceptance criteria. Acceptance
criterion No. 4.3 stated; " verify that Auxiliary Feedwater Pump 2A does not
trip out due to low level 3 suction pressure signal during the first 2.5
seconds'of pump operation." Acceptance criterion No. 4.4 stated;." verify that
AF Pump 2AF00lPA will trip out due to Low Level 3 suction pressure signal any.
time after first 2.5 seconds of pump operation." A similar set of acceptance
criteria were included for the 4 seconds delay in arming the Sx suction valves
(Criterion Nos. 4.5 and 4.6 respectively). The test was run by inserting the
Low Level 3 suction pressure signal before starting the pump and observing
that no trip signal was generated for the first 2.5 seconds and the Sx suction
valves were not armed during the first 4.0 seconds. Thus, the test satisfied
criteria 4.3 and 4.5.
Criteria 4.4 and 4.6 were not satisfied by this test in
that the test as run did not confirm that the pump would trip (or valves arm)
immediately u)on the insertion of a low Level 3 suction pressure signal after
the pump had >een running for 2.5 (or 4.0) seconds. The inspector cited the
" erroneous" logic diagram included in the design package as an example of a
logic that would have satisfied criteria 4.3 and 4.5 but not criteria 4.4 or
4.6.
This was the basis for the inspectors comment that the test as run could
not distinguish between the " erroneous" and intended logics. The only way for
criteria 4.4 and 4.6 to be satisfied was to run a second test with the low
pressure signal inserted after the pump had been running for 2.5 or 4.0
seconds and observing immediate pump trip and valve arming.
The violation was issued for failure to address all acceptance criteria during
the post-modification testing. While installation testing and inspections had
been performed to verify installation per design, the post-modification test
is an independent functional test confirming both design and installation.
The test as run did not provide this confirmation.
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Commonwealth Edison Company
2
We also wish to comment on your response to violatior.s 1.a (454/89009-01;
455/89006-01B) and 1.c (455/89006-01C). Both violations representicases in
which the Pressurized Water Reactor Engineering (PWRE) Organization failed-to
assure all design requirements had been met.
In the case of violation'l.c,
the. failure to provide the station with complete information-(i.e., periodic
relay contact cleaning requirements) could have compromised the design
objective of improving the' reliability of this relay.
Violation 1.a also
represented a failure to assure all design requirements had been met (i.e.,
seismic qualification of all' valves). Your response did not aggressively
address this issue. We request that you'give this-issue further attention-
during the' engineering meetings referenced elsewhere in your response.
Your response to open item (454/89009-04; 455/89006-05) did not fully address
.
the inspectors' concern. The first step in a dedication process involves the
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identification of those characteristics of a basic component important to its.
safety-related application (critical characteristics). The next step is
verifying that these characteristics are met.
If a qualified manufacturer's-
or supplier's technical description of the component covers the critical
characteristics, then a certificate of conformance or other certification may
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be an adequate means:of verification; however, the. critical characteristics
must first be identified. The inspectors' concern was that Station Procedurc
BVP 100-2 did not require explicit identification of these critical
characteristics.
We anticipate examining this area in more depth in a future inspection.
In
the interim, we direct your attention to Prairie Island Inspection Report
(282/88201; 306/88201) for a more in-depth expression of NRC concerns in this
area. A copy of this report has been provided to all Region III licensees.
Sincerely,
GRIGINhl SIGNED BY GEOFFREY C. W
H. J. Miller, Director
Division of Reactor Safety
Enclosure: Letter dated
May 22.-1989
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R'. Pleniewicz,' Station Manager.
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Licensing Fee _ Management Branch
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Resident Inspector, RIII Byron
Resident Inspector, RIII.
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D. W. Cassel,iJr., Esq.
Richard Hubbard
J. W. McCaffrey; Chief, Public-
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Diane Chavez, DAARE/ SAFE
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H.: S. Taylor, Quality A'ssurance
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