ML20247G763
| ML20247G763 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/16/1989 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8905310065 | |
| Download: ML20247G763 (8) | |
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' i, a PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O'. BOX 8699 PHILADELPHIA A. PA.19101 1215)841 4500 m...
KEMPER JOH N S.'
MAY161989 U. S. Nuclear Regulatory Commission Dc ket No. 50-353 Attu:
Document Control Desk Washington, D.C.
20555
SUBJECT:
Limerick Generating Station, Unit 2 Independent Design and Construction Assessment Gentlemen:
During the week of April 24th to 28th your review team was in Bechtel Power Corporation's office in San Francisco, CA to perform a follow-up review of the design portion of the Indepen-dent Design and Construction Assessment (IDCA) program.
An exit meeting was' held on April 28, 1989 to discuss the results of the weeks review.
At this meeting your staff requested that Phila-d.elphia Electric Company (PECo) prepare a letter to address the
'following items:
1.
Confirm co.npletion of IDCA action items or identify specific action items that are not yet complete.
It was also requested that an evaluation cf significance be provided for any open item that would not be com-plete by fuel load.
2.
Address what short tern actions are being taken to address calculational concerns as identified in DOR-118 and in the Design Assessment Report Section 4.1.7.
In response to these requests we submit the following:
Attachment #1 addresses the open items for the design portion of the IDCA program.
This attachment segre-gates actions that will be completed prior to fuel load and those that will be completed post fuel load.
The IDCA action items not identified in Attachment #1 are completed.
The action items for the construction portion of the IDCA program are complete.
Attachment #2 addresses PECo short term commitments to address calculational concerns identified during the design assessment.
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Please let me know if you have any questions regarding this submittal or require additional information.
Sincerely, gv WWP05111/dbd Attachments 1 and 2 Copy to:
T. J. Kenny, LGS, NRC Senior Resident Inspector W. T. Russell, Region I NRC Administrator R. J. Clark, LGS, NRC Project Manager 1
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ATTACHMENT #1 This attachment identifies the open actions from responses to l
Design Observation Reports and from discussions with the NRC during the IDA review the week of 4/24 to 4/28.
Part A actions identified will be completed prior to fuel load.
Part B actions will be completed post fuel load and contains an evaluation for completion after fuel load.
PART A DOR ACTION TO BE TAKEN 021
- 1. Confirm that all Bechtel established BOP Q-functional instrument setpoints have been reviewed to demonstrate the ade-quacy of an 18 month surveillance /cali-bration frequency.
This frequency will be employed or the bacis for any adjust-ment of these frequencies will be pro-vided.
- 2. Demonstrate that the lack of a rigorous analysis of test instrumentation inaccur-acies did not invalidate the conclusions on satisfying BOP systen performance requirements.
Both temporary and perma-nent plant instrumentation used to obtain test data will be addressed.
- 3. Confirm that setpoint calculations are completed for vendor package instrument replacements performed by Bechtcl/PECo.
Our response to address these items will be transmitted to you by 5/22/89.
083 Revise Plant operating procedure M-041-022 &
M-041-025.
These procedures address installation and removal of Steam Separators.
086 Revise EQ Package 087 Prepare calculation to reassess battery capacity considering 105% inverter load and 108V battery end of life voltage.
088 Develop Cable Bus rating based on In-Fitu testing and develop guidelines to demonstrate cable functional capability and to monitor ambient temperature / load current.
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DOR ACTION TO BE TAKEN 115' Revise Plant operating procedure to impose operating restrictions in the alignment of 13.8 KV buses due to dual unit operations.
056 Revise SQRT forms.
071 Revise SQRT report.
102 Revise EQ packages.
lil Evaluate acceptability of Class 1E 125Vdc components and establish preventative maintenance trend program.
114-Develop replacement / maintenance program for Class 1E Agastat relays in mild environment and confirm all lE Aghstat GP relays (non-HVAC) have been replaced with EGP relays.
094 Complete evaluation of suppliers instruction for EQ impact and log in uncontrolled instructions.
091 Revise SQRT report.
096 Complete relief valve adequacy review and implement required corrective actions.
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PART B F/C D-OR ACTION TO BE TAKEN-COMPLETION DATE 021 A.
Develop unique'setpoint Prior ~to determination procedure 5% Power PECo will' publish a unique setpoint determination procedure.
Pre- '
sently setpoints are determined
'using good engineering practices, vendor information, operating history and qualification infor-mation in a conservative manner, and documented in accordance with existing engineering proce-dures-for preparing general de-sign calculations.
The new unique setpoint determination procedure will provide a consistent methodo-logy for determining instrument setpoints and documenting the cal-culations in a readily retrievable manner.
The existing methods used to determine instrument setpoints are' sufficient to operate the plant in a safe and reliable manner.
Consequently there is no impact if this unique procedure is not pub-lished until after Unit 2 fuel load.
B.
Long term Configuration Prior to Management Program definition Commercial Operation PECo will define a program to reconstitute the design basis calculations for instrument set-points.
Existing setpointr. have been determined using good engi-neering practices and are ade-quate to operate the plant in a safe and reliable manner.
The purpose of this program is to reconstitute the design basis calculations that were perft,rmed to determine these setpoints and document these calculations in a readily retrievable manner, thereby providing for more respon-sive and comprehensive analyses of plant opera *'ous and future modifications, with respect to original design basis of plant, b
PART B --Cont'd F/C DOR ACTION TO BE TAKEN COMPLETION DATE as may be necessary.
Consequently, there is no impact if this program is not fully implemented until after unit 2 fuel load and subse-quent to full power operation.
039 Determine the TOL element trip Prior to setting for all 460V continuous 5% Power Class 1E operating motors required for safe shutdown.
Based on discussion with the NRC review team during the IDA review this item is not significant with respect to fuel load but it is a 5% power commitment.
103 Revise Voltage Regulation Study Irior to including grid voltage swing 5% Power evaluation.
Based on discussions with the NRC review team during the IDA i
review this item is not signifi-cant with respect to fuel load but it is a 5% power commitment.
088 Revise plant operating procedure Prior to to impose identified operating Commercial restrictions or the cable bus.
Operation Preliminary results of the cable bus analysis have indicated that Case 5 from the DOR is the only case identified that would cause the cable to be operated in excess of its rating.
Case 5 represents a double contingency in that both the Unit Auxiliary Transformer must be out of ser-vice and all of the available loads must be connected to a 1
single offsite source eventhough
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both sources are available (ab-j normal system configuration).
If I
l the electrical plant were con-1 figured per the operating proce-l dures, the load on the cable bus would be reduced to less than 1900A which is well within the expected continuous rating of the bus.
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PART B - Cont'd F/C DOR' ACTION TO BE TAKEN COMPLETION DATE Therefore, by requiring that electrical plant be configured per the procedures, there are no, anticipated cases that would result in the rating of the cabic bus being exceeded.
084 Vendor Print File (VPF) update drawings to reflect Field Deviation Disposition Request (FDDR) Changes.
The VPF update program has no safety impact since the as-installed condition.was verified.using the base VPF document in conjunction with all associated change documents.
This program is being pursued solely for drawing handling and clarity.
The overall VPF update program will be evaluated and an action plan-developed to address the issue of unincorporated'FDDR's and FDI's by 6/15/89.
This action plan will be imple-mented via the configuration.
Management Project on a schedule consistent with the overall Project schedule.
114 Preventative Maintenance Program 8/1/89 will be updated to include the Class lE Agastat EGP relays, located in mild environment, to identify required replacement dates.
Based on thermal aging cal-culations using the Arrhenius methodolgy, the minimum qualified life for the relays located in mild environment is 8 years.
We have confirmed that the Agastat l
EGP relays used in' Unit 2 were not manufactured prior to 1982.
The Preventative Maintenance Pro-l gram for mild environment relays will be in effect by 8/1/89 to ensure that all relays to be replaced in 1990 will be addressed.
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9 ATTACHMENT #2 Calculational Concerns (DOR-ll8)
This attachment addresses PECo's short term commitment with respect to calculational concerns that were raised during the design assessment.
In order to support both plant modifications and operations support activities in the near term, we have revised-our engi-neering procedures.
These r6 visions emphasize.the necessity to assure that base design calculations are appropriate to support the design activity being performed.
The revisions will assure that if modification design'or operation support activities rely on. margins developed in base design calculations, a review is performed to-verify that sufficient margins are available.
.This review is to include consideration of the significance of the margins:in the base calculation relative to the margins required-for the design activity, validity of calculation assumptions, engineering judgements and methodology, and consistency with the current plant configuration.
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5 i-PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHIA A. PA 19101 (215)8414000 NUCLEAR ENGINEERING DEPA RTMENT U. S. Nuclear Regulatory Conmission Attn: Document Control Desk Washington, D. C.
20555 On May-16, 1989 in error a copy of this document was sent to you.
Enclosed is the orlainal.
Sorry for any inconveniences this error might hrve caused you.
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