ML20247J026

Forwards Vol Ii,Book 1 to Limerick Generating Station-Unit 2 Independent Design & Const Assessment & Supplemental Info Re Instrument Setpoints Discussed in Previous Status of Design Observation Rept 021

ML20247J026
Person / Time
Site:	Limerick
Issue date:	05/25/1989
From:	Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20247J030	List: ML20247J026 ML20247J052
References
NUDOCS 8906010016
Download: ML20247J026 (5)

Text

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_.,s P'H1'LADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET-

- P.O. BOX 8699

g. PHILADELPHIA A. PA.19101 (215)841 4500 imamon vbN5ns'sfosWwucLc An MAY 251989 U. S. Nuclear Regulatory Conmission Docket No. 50-353 Attn: .Docunent Control Desk Washington, D.C. 20535

Subject:

Limerick Generating Statlon, Unit. 2 Independent Design and' Construction Assessment i

Reference:

1) Letter, J. S. Kemper (PECo) to Docunent Control Desk (NRC) dated Apell 18, 1989, same subject.

2) Letter, J. S. Kemper (PECo) to Document Control Desk (NRR) dated May 16, 1989, same subject.

Gentleme :

Enclosed for-your Information is the Hazards Program Evaluation Supple-ment.(Attachment 2) to the Design Assessment Report (Reference 1). This evaluation concludes that the high energy line break and seismic II/I' programs are acceptable.

Also enclosed is supplemental Information (Attachment 1) regarding Instrunent setpoints as discussed in our previous status of Design Observa-tion Report (DOR) - 021 (Reference 2).

Please let me know if you have any questions regarding this submittal or require addltlonal Information.

Sincerely, i-ldKf Attachments (2)

' ERG /dk/052289 Copy to: W. T. Russell, USNRC Administrator, Region I T. J. Kenny, USNRC Senior Resident Inspector, Limerick R. J. Clark, USNRC, Project Manager, Limerick p0g i L 3

8906010016 890525 PDR I h A

ADOCK 05000353 PDC ,

bec: C. A. McNeill, Jr. 526-1 S. J. Kowalski S25-1 D. R. Helwig S25-1 E. J. Bradley 523-1 R. C. Brown 514-2 E. P. Fogarty 57-1 J. M. Madara, Jr. 57-1 G. A. Hunger, Jr. S7-1 D. P. Helker S7-1 R. M. Krich S7-1 D. B. Fetters N4-1 L. B. Pyrlh N2-1 A. J. Marie N2-1

'H. D. Honan N2-1 G. M. Leitch LGS MC 200 P. J. Duca, Jr. LGS MC A5-1 C. R. Endriss LGS MC A2-1 A. S. MacAinsh LGS MC SB3-4 M. S. Iyer BPC/SF DAC NG-8

ATTACHMENT 1 DOR-21 BOP Q-Functlonal Instrument Setpoints and Tolerances PECo corrmitted to address the following actions:

1. Confirm that all Bechtel established BOP Q-functional instrument setpoints have been reviewed to demonstrate the adequacy of an 18 month surveillance / calibration frequency. This frequency will be employed or the basis for any adjustment of these frequencies will be provided.

RESPONSE

Calculations have been completed for all Unit 2 specific systems that have Bechtel established Q-functional setpoints. These calculations demonstrate that an 18 month calibration surveillance / calibration frequency is adequate.

The calculations for Unit 2 cormion systems have not yet been finalized. Any setpoint revisions that may be identified as a result of finalizing these calculations will be Implemented prior to fuel load.

For certain Drywell Coolers and RERS Instrument loops, process setpoints and tolerances were not originally specified on the Instrument Setpoint Data Sheets (ISDS) because the setpoints were dependent on the switch location in the duct and duct air flow characteristics. These setpoints were to be detennined during startup testing based on full flow instrtment output. The results of the startup testing were factored into the calculations and suitable setpoints determined for these switches. The final process setpoints and tolerances for these switches have been subsequently documented in the ISDS's.

While performing the calculations for the air flow switches for safety-related drywell coolers 2AV212, 2BV212, 2GV212, and 2HV212 It was determined that the switches supplled may not perform as required in a post-LOCA stecm envi r.,nment . Subsequent review Indicates that not all of the drywell cooler fans are reqired to operate post-LOCA and the affected sections of the FSAR wl11 be revised to show that operation of two safety-related drywell cooler fans post-LOCA is sufficient to ensure proper mixing of the containment atmosp%re. The appropriate FSAR changes will be initiated and approved prior to fuel load.

Routine instrument calibration is performed under the station's comprehensive Preventative Maintenance Program. A calibration frequency Is assigned to each instrument loop, dependent on the Instrtment loop's importance to the safe and rel table operatlon of the plant, manufacturer's reconmendat tons, and operating experience. In addition to the Preventative Maintenance Program, system func-tional tests are perfonned periodically to assure proper system operation. If proper system operation cannot be derronstrated, corrective maintenance requests are initiated, which may include Instrument recalibration. Instrument recall-bration may also be initiated in response to observations of abnonnal performance during nonnal day-to-day operations.

o.. ,

In addltion to the Preventative Maintenance and system functlonal' testing programs, the station maintains an Instrumentation and Controls Trending Program. . This trending program reviews maintenance requests, normal surveillance test data, equipment history, and vendor and industry experience for instrumentation and controls, to identify equipment performance trends and evaluate repetitive problems. Appropriate action, including increased surveillance, equipment replacement, or a plant modification is initiated.

This trending program has been developed in accordance with INPO Good Practice MA-310 -- Maintenance History Program and the Limerick Generating Station Quality Assurance Program.

The preventative Maintenance, system functional testing, and Instrtment and Controls Trending Programs are sufficient to assure proper instrument operation, to identify repetitive instrumentation problems, and initiate the appropriate corrective actions as required.

2. Demonstrate that the lack of rigorous analysis of test Instrumentation inaccuracies did not invalidate the conclusions on satisfying BOP system performance requirements. Both temporary and permanent plant instrumentation used to obtain test data will be addressed.

Response

A review of the preoperational test results for eight representative mechanical and electrical systems was performed. The acceptance criteria, the measured values, the measuring instruments, and measuring instrtment accuracles were identified. An evaluation was performed for each case in which the acceptance criteria values were exceedod by the measured values plus or minus a value corresponding to the measuring instrument accuracy.

Each case evaluated was concluded to be acceptable without the need for further testing. Based on this analysis, it was demonstrated that the lack of rigorous analysis for test instrumentation inaccuracies did not invalidate the conclusions on satisfying BOP system performance requirements.

3. Confirm that setpoint calculations are completed for vendor package Instrument replacements performed by Bechtel/PECo.

Response

A review was performed to identify vendor packages with BOP Q-functional instruments. The following vendor packages were identified:

- Emergency Diesel Generators

- Hydrogen /0xygen Analyzers

- Hydrogen Recombiners

- Heat Tracing

- Chlorine Detection System

- Suppression Pool Temperature Monitoring System Only the Hydrogen Recombiners were identified as having had vendor package Instruments changed out by Bechtel/PECo. Calculations have been performed, reflecting these instrument changes.

. . ~,

Based on the results of these calculations, the process tolerances for six instruments in each recombiner package were increased to envelope the expected instrunent loop performance. No setpoint changes were. required as there was excess margin between the process design limits and the corre-sponding setpoints. The ISDS's have been revised to reflect the increased process tolerance.

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