ML20244A547

Responds to Requesting Reconsideration of Violation 3 Noted in Insp Repts 50-454/89-09 & 50-455/89-06. Violation Considered Valid.Issue Re Design Requirements Not Meeting Seismic Qualifications Needs Further Attention

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: ML20244A547 ML20244A553
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

.luN 21989-

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

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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

See Attached Distribution

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lPWR Operations.

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Licensing Manager.

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Licensing Fee _ Management Branch

Resident Inspector, RIII Byron

Resident Inspector, RIII.

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D. W. Cassel,iJr., Esq.

Richard Hubbard

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Diane Chavez, DAARE/ SAFE

L. 01shan, NRR' LPM.

H.: S. Taylor, Quality A'ssurance

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