ML19350B361
| ML19350B361 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 01/30/1981 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| IEB-80-17, NUDOCS 8103200330 | |
| Download: ML19350B361 (11) | |
Text
/ic PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 1881 -1981 PHILADELPHI A. PA.19101 SHIELDS L DALTRopp (2151841 Sool EL c Pst o CT1oes January 30, 1981 Re: Docket Nos. 50-277 59-278 IE Bulletin 80-17 Si Mr. Boyce 11. Grier, Director l'
Office of Inspection and Enforcement j
~
Region I G
/TO
~. I U.S.
Nuclear Regulatory Commission
$ 04kg%f3Y 631 Park Avenue TCing of Prussia, PA 19406 1
{')
$N '
N Dear Mr. Grier-
+
co This letter J=
in response to IE Bulletin 80-17 Supnlement 4 which conc; ins those BUR's now utilizing a continuous monitoring system (CMS) to detect water in the scram discharge volume (SDV).
It is estimated that approximately 40
. hours were expended for the bulletin response preparation and approximately 1525 hours0.0177 days <br />0.424 hours <br />0.00252 weeks <br />5.802625e-4 months <br /> expended associated with corrective actions required by the bulletin.
The " Actions to be Taken by Licensees of Operating BUR's Using CMS" and our responses are treated sequentially.
o_f, CM S f
1.
Rench Test Make available the following information which describes the CMS design and the bench tests which have been perforned to demonstrate systen operability and sensitivity:
(a)
System description including a schematic of the apparatus and associated electronics.
(b)
Type of sensing device and characteristics (include response characteristics versus tempera tt.re).
8103200 % d
L+
Mr. Boyce H.
Crier Page 2 (c)
Calibration criteria, including transmission losses.
(d)
Training and testing of personnel perforning the calibration test.
~
Items a through e above nay be referenced by the licensee if the information has been submitted to the NRC by the equipment manufacturer.
Response
(a)(b)&(c)
The information requested by items (a) through (c) was submitted by General Electric to Mr. ii.
- 9. Mills of the NRC's Office of Inspection and
- nforcement on December 12, 1990 (d)
The calibration and testing of the CMS was perforned by Philadelphia Electric Company instrunent technicians.
The lead technician is qualified to "Special Tester A" (highest rating of site technicians), and has had extensive experience with similar equipnent.
The two technicians who assisted are currently in progression to "Special Tester A".
Resumes.for these three technicians are enclosed in Appendix A.
2.
Onerability Test of CMS Prior to conducting the operability test, verify that the CMP on the SDV is installed and calibrated in accordance with the vendor. recommendations.
.In order to provide assurance of operability of the CMS, if not already perforned, conduct an operability test within 14 days of the date of this bulletin.
In this test, inject a sufficient anount of uater into each SDV header to decernine that the ultrasonic transducers are adequately coupled to the SDV piping and that the trip alar = function of the CMS will
. perform satisfactorily.
The test may be performed by single (nultiple) rod scran. tests while operating.
No water may be i
introduced into the SDV header while the reactor is operating except using the scram function.
Independent level measureuent mu s t: be used to verify CMS operation and proper calibration.
Response
Unit 2 The CMS was calibrated and installed in accordance with the vendor's technical nanual with the exception of the coupling
A:
Mr. Boyec H.
Crier Page 3 compound used.
The first CMS operability test perforned on December 27, 1980, was unsuccessful and the syste= declared inoperable.
Manual UT testing to detect water in the SDV vac perfor=ed during the period of inoperability as describee in Item 5 below.
Corrective =easures included additional cleaning of the SDV pipe exterior, replacement of the coupling compound with a higher tenperature cospound, and realignment of the transducers.
The CMS was successfully tested by individually scrac=ing control rods during a planned power reduction on January 6, 1981.
All 4 transducers responded properly and the water levels measured by the CMS agreed with the SDV level readings obtained.using another UT level ceasuring device.
Alarn setpoints were verified on Decenber 29, 1980, by backfilling the SDV through the scrau instrument volu=e (SIV).
Level was monitored with the CMS, another UT device, and a tenporary sight glass.
All alarss functioned properly.
Unit 3 The CMS was calibrated and installed in accordance with the vendor's technical =anual with the exception of the coucling compound used.
The compound used initially was replaced on December 20, 1980, with a higher tenperature coupling compound.
On Decemberc20, 1980, the CMS.vas tested by
'backfilling the SDV through the SIV.
All four transnitters functioned properly and alarmed at the required set point as confir=ed by independent level measure =ent.
3.
Interin Manual Surveillance Infthe interin 14-day period before the operability test is conpleted, perform a =anual surveillance for the presence of water.in the SDV at least once per shift and after.each reactor scran.-
In order to provide assurance that nanual surveillance can detect water accumulation in the-SDV, verify that the =e'thod.azd the operator have been qualified by testing which.uses or simulates the SDY piping and has the ability to detect different levels of water in the SDV.
Sarveillance of SDV =anual seasurement techniques should be done before cospletion of the operability test described in Item-2.above.
?
d Mr. Woyce H.
Grier Page 4
Response
Unit 2
.As directed by the Bulletin, manual testing for the presence of water in the SDV was performed once per shift using the manual UT level detector which was used prior to installation of the CMS.
This equipment was qualified on a test pipe which is the same diameter and ;all tnichness as the SDV pipe and is operated by station personnel trained in its use and calibration.
The testing of equipment and training of personnel was conducted by personnel from the Philadelphia Electric In Service Inspection Group who are qualified in the use of UT equipment.
Unit 3 Unit 3 was shutdown on December 18, 1930, due to a scram the previous day.
The CMS was successfully tested as required by Iten 2 and determined to be operable prior to startup on December 21, 1980.
For this reason, the interim manual surveillance was not performed or required.
4.
Full Test of CMS to be Conducted During a Planned Outage During a planned outage within six months, perform a full CMS test using the SDV headers:
(a)
Adnit water into the SDV to establish fill rates for several (not less than three) in-leakage flow rates.
The in-leakage rates should range from approximately the minimun which results in water accumulation in the SDV to a full scram.
(b)
Establish and record the resnonse of the C'IS indication and alarm functions from the trip lessl 'co a full SDV.
Provide criteria for replacement or adjustment when exceeding design specifications of the system.
(c)
Verify by independent measurenent that the alarm initiates-at'the proper level setpoint.
Resnonee Unit 2 Tests were performed immediately!following a shutdown on January 1, 1981, at three-different fill rates and the response of the CMSfwas recorded.
The shutdown was completed by manually; scramming the-reactor with'66 control rods at
~
4 Mr, Boyce H.
Grier Page 5 position 43 and all other control rods at 90.
The CMS responded to the increase in water level, indicated a full pipe, and alarmed properly.
The three tests were: 1) Full scram with all control rods at the full in position to obtain the maximum possible flaw rate, 2) Individual scram o f one control rod on each header to obtain the minimes flow rate, and 3) Individual scram of four control rods on each header to obtain a flow rate between the mininum and maxicum.
These tests span the approxicate range of possible flow conditions.
On all three tests, the system responded as expected (i.e.,
indicated increasing water level and alarmed properly).
One transmitter did not respond initially on the third test, however, it worked properly after a minor rep.aitioning adjus,tment.
During the subsequent retest, a '.ull scram occurred.
The CMS worked properly during both the test and the scram.
Unit 3 The full test of the CMS on Unit 3 has not been perforned yet, but is scheduled to be performed during the Spring 1981 refueling outage.
5.
Ooerability of CMS During Reactor Operation The CMS shall be operable prior to reactor startup and during reactor. operation.
If the CMS becomes less than fully operable, within 8 hou rs perform a manual check for water in the SDV and institute procedures for a nanual check of-the SDV each shift ~~and following scram until the CMS is fully operable.
When not fuliv operable, the CMS should be used to the extent' practical in addition to the nanual checks.
If'the CMS is not operable within 7 days, the frequency of the manual check should be increased to once every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
If the CMS is-not operable within 30 days, the plant shall.be shutdown.
To demonstrate continued operability of the' CMS during reactor operation, perform periodic surveillance tests for operability of the CMS.
Forlthese periodic surveillance tests, test as much of the CMS as practical during reactor
. operation without-injecting water in the SDV.
Establish criteria.for ' repair or. replacement when the system. design criteria or estimated service life linitations are exceeded.
The frequency of these periodic surveillance ehechs should be deternined by the licensee.
~
These periodic surveillance tests should include the following:
li
4 Mr. Boyce H.
Grier Page 6
-(a) deteruination that the response and power output of
~
the transducer has not degraded; (b) visual inspection for adequate condition of the transducer to SDV coupling material; and, (c) a calibration check of the electronics to assure alarm initiation in the control room.
Water should be periodically injected into the SDV to perform a CMS operability and calibration check similar to that specified in Item 2 above.
This check should be performed semiannually and during startup after plant outages where maintenance operations may have taken place near to CMS equipment.
Response
Unit 2 The operability _ requirements specified in Item 5 have been followed, with one exception.
The Interim Manual Surveillance Testing.once per shift was initiated upon the receipt of the bulletin, as required by Item 3.
The CMS operability test as required by Item 2 was performed unsuccessfully on 12/27/80.
The unit was restarted on 12/30/80 with the CMS s ti ll inoperable.
Permission was granted by NRC Region I Office-of Inspection and Enforcement through the resident inspector to startup by substituting manual UT_ level measurement readings every 30 minutes in lieu of CMS operability.
On January 3, 1981, the test frequency was_ decreased to once every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> with Region I Inspection and Enforcement. approval.
On January 7, 1981, the CMS was determined to be operable-following-analysis of results of testing which was performed the previous day.
The NRC resident inspector concurred _vith ou r de termination and the nanual' testing was terminated.
The system has bean operable since that eine:
Unit 3 The CMS'has been operabic.since it was tested on December 20, 1980 and therefore has not required additional testing.
' Units 2 and 3 Surveillance tests-have been written to denonstrate continued CMS operability during reactor operation and include the requirements specified by Bulletin 80-17 S4.
Procedures are being written for operability testing and-calibration checks similar to thsse specified in Iten 2 to be performed semi-annually and during startup after plant outages for which
6 Mr. Boyce H.
Grier Page 7 maintenance operations have been performed near CMS equipment.
Based on evaluation of manufacturers service life scommendations, appropriate criteria will be incorporated in these procedures to prevent exceeding service life limitations.
These procedures will be completed by March 1, 1981.
6.
Operating Procedures Develop procedures for operation, periodic testing and calibration of the CMS and for repair or replacement when system. design specifications are exceeded.
Develop procedures for the calibration and use of the hand held UT device
- f. n the event of a malfunctioning CMS.
Notify the NRC before changing the established CMS alare level setpoints.
' Response Procedures for operation,_ testing, and calibration of the CMS have been written or are being developed.
These will be c'onpleted by March 1, 19R1.
Repairs to the system will be performed in accordance with Peach Bottom Administrative Procedures rad the CPS vendor technical manual.
Procedures exist fer the eniibration and use of our manual UT device which we re established. prior to the installation of the CMS.
This manual system serves'the same purpose (redundant monitoring capability)
. as the " hand held UT device" addressed-in this section of the bulletin.
No' changes have been made to the CMS alarm level setpoints.
If you have any questions or require additional information, please do not hesitate'to contact us.
Very truly yours, p
!J f,gw7I
~
cc:
U.S. Nuclear Regulatory Commisolon Office of Inspection and Enforcement Division'of Reactor Operations Inspection Washington, DC 20555-T
Mr. Boyce H.
Grier Page 8 i
APPENDIX A BULLETIN 80-17 SUPPLEMENT 4
- Lead Technician Employed 4/12/72 High School:
Monsignor Bonner - Graduated June 1961 U.S.
Navy:
February 1963 ;' April 1971 - Reactor Operator / Electronics Tech ET - Class A school January to March 1963 Class B school September to November 1968 Nuclear Power School - January to June 1964 Additional Training:
General Physics - Electricity &
Electronics / Process Instrune'. station &
Control 8/11/80 - 9/12/80 General Physics Practical Instrumentation Lab at Limerick Training Center 9/25-26/80 G.E.
Company - BUR Systems & Nuclear Instrumentation Course 9/29/80 - 10/23/80 Works in PECo Susquehanna Test Branch, specializing in accoustic emissions equipnent which is very'similar to CitS.
Special Tester "A" -: Highest rating of Technicians on site i
requires 7 years Electronic Technician experience.
i-w y
r-4' I
+
-r P
=
4 Mr. Boyce H. Grier Page 9 APPENDIX A BULLETIN 80-17 SUPPLEMENT 4 Technician A Employed 1/22/79 High School:
Haddon Heights High - Graduated June 1973 i.
College:
Camden County College - Associates Degree in Electrical / Electronic Engineering Technology - Graduated June 1975 i
Additional Training:
General Physics - Electricity &
Electronics / Process Instrumentation &
Control 8/11/80 - 9/12/80 General Physics - Practical Instrumentation Lab at Limerick Training Center 9/25-26/80 2
Completed local training on Area Radiation
. Monitoring and Feedwater Control Systems in 1979 Currently in progression to Special Tetter "A".
7 1
i 4
e-A dW
.e.
Mr. Boyce d.
Grier Page 10 4
APPENDIX /
BULLETIN 80-17 SUtPLEMENT 4 Technician B Employed 9/8/80 Migh School:
William Penn Senior High - Graduated June 1975 College:
Penn State - Associates Degree in Electrical Engineering Technology - Graduated June 1977 Intro to Microprocessor's Additional Training:
Penn State 1980 Currently in progression to Special Tester "A".
t
}'
i-t b-
?
-~.-c.
2
+
COM!!CMUEALTH OF PENNSYLVANIA :
ss.
COUNTY OF PHILADELPHIA S.L.
Daltroff, being f f +:s t duly sworn, deposes and says:
That he is Vice President of Philadelphia Electric Company; that he has read the foregoing response to IE Bulletin 80-17 Supplenent 4 and knou.i the contents thereof; and that the statements and natters set forth therein are true and correat to "the best of his knowledge, information and belief.
i
/
/
/
aua j j _'
'l
/ t Subscribed and sworn to this h day before me
\\
M\\ \\
of
/Q d0t[
No,tary P u bli c i /\\
/-
EUZABETH H. BOYER )
-- notary puwe. PMa, Phda. Ccd
, ney Commissien Expires jan.g1982
%/-
e s _ r
"