ML20058N177

Responds to NRC Re Unresolved Items Noted in Insp Repts 50-352/90-80 & 50-353/90-80.Plant-specific Technical Guideline Has Been Revised to Ref Contingency Numbers Rather than Transient Response Implementation Plan Procedures

ML20058N177
Person / Time
Site:	Limerick
Issue date:	08/10/1990
From:	Leitch G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9008130276
Download: ML20058N177 (11)

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i PHILADELPHIA ELECTRIC COMPANY ,

o LIMERICK GENER ATING STATION P. O. DOX A j SAN ATOG A. PENNSYLVANI A 1$464

{t t $) 3271200, EXT. 3000 GN AH AM M LEITCH -

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u............m ....n.a Docket Nos. 50-352 50-353 License Nos. NPF-39 NPF-85 i U.S. Nuclear Regulatory Commission Attn Document Control Desk Washington. DC- 20555 t

SUBJECT:

Limerick Generating Station, Units 1 and 2 Response to NRC Unresolved Items Identified in Inspection Report Nos. 50-352/90-80 and 50-353/90-80 Dear Sirs

Attached is Philadelph?a Electric Company's reply to a request for a written response to NRC Inspection Report Nos. 50-352/90-80 and 50-353/90-80 for Limerick Generating Station (LGS), Units 1 and 2.

NRC letter dated July 3, 1990, transmitted the Inspection Report which covered the~ Transient Response Implementation Plan (TRIP) procedures.

This letter requested that we respond to the unresolved items .

. identified in the inspection report within 30 days of receipt of the ,

report. We received the report at LGS on July 13, 1990. The Attachment to this letter provides our response to the unresolved items as well as the other concerns identified throughout the ,

aspection Report. Specifically, this response identifies the short term actions;which have been taken to resolve certain of the concerna '

described in the' Inspection Report. The long term actions to resolve the remaining concerns will be determined by Dacember 31, 1990, and

.provided in a supplement to this response by January 30, 1991.

If you have any questions or require additional information, please do not hesitate to contact us.

Very tyu'y ours,

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DCS:cah Attachment '

cc: T. T. Martin, Administrator, Region I, USNRC l

T. v. Kenny, USNRC Senior Resident Inspector, LGS /

01 9008130276 900810 1 L, hDR ADOCK 05000352PDC I

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Attachm3nti

, .. Paga 1 of-10 Inspection Report 50-352, 353/90-80 Limerick Generating Station, Units 1 and 2 Response to NRC Unresolved Items Identified in '

Inspection Report Nos. 50-352/90-80 and 50-353/90-80 The cover letter that transmitted NRC Inspection Report Nos.-

50-352/90-80 and 50-353/90-80 requested that we provide our short and '

long term' actions relative to the unresolved items identified in the-Executive Summary. The two unresolved items are 352 and 353/90-80"01.

and'352 and 353/90-80-02.- Below is our response to each of these unresolved items. Additionally, we have provided our response to the other concerns identified throughout the report. Each item is addressed below in the order that they appeared in-the Details section of the report.

The Short Term actions (designated ST) make certain enhancements in the Plant Specific Technical Guideline (PSTG) and Transient Response i Implementation Plan ' RIP) procedures.

s The PSTGs and affected-TRIP procedures were all revised, reviewed by the Plant Operations Review

-Committee (PORC).and approved by the Operatio<o and Technical Staffs before July- 15, 1990.- Implementation and the necessary training of

-these changes is expected to be completed by September 15, 1990. Long:

Term items (designated LT) will be reviewed and appropriate actions planned by December 31,-'1990. The results of this review and the action plan will be submitted in a supplement to this response

. expected to be issued by January 30, 1991.

Independent Technical Adequacy Review of the TRIP Procedures, Unresolved Item 90-80-01, Section 4.0 l Item 1 The in3pection team identified that when transitioning to the contilgency portion of the PSTG, the PSTG refers to specific procedure numbe;s, such as the T-100 secies, rather than the individual PSTG contingencies.

Response

I The PSTG has been revised to reference contingency numbers rather than TRIP procedure numbers (ST).

Item'2 The inspectors identified a TRIP procedure deviation from the PSTG on entering T-100 (SCRAM procedure) instead of entry into the Reactor Pressure Vessel (RPV) Cor. trol procedure, T-101. Tais constitutes l' extra steps which may not be required and has the potential to cause l operator error.

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h Attcchmant H . Paga 2 of 10 Inspection Report 50-352, 353/90-80

Response

We will; evaluate whether the operator should enter T-101 (RPVLControl) [

instead of-T-100 (SCRAM precedure) when directed to SCRAM in a TRIP

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procedure (LT).

1 Item 3  !

A deviation between the PSTC and the TRIP procedures was identified.

-The:PSTG direction given, when emergency RPV depressurization is j required, is to enter T-101 at Step RC-1 and execute it concurrently.

The TRIP procedures only direct entry into T-ll2, Emergency Blowdown.

' Procedure T-112 has direction to SCRAM the reactor if it has not already been SCRAMed, therefore, entry into T-101 is redundant. The inspect 3an team concludeo that since T-101 gives the operator guidance  !

'to contcol level and power-that T-112 does not, T-101 should be i entered when emergency blowdown is required.

Response

This concl.usion will be reviewed and appropriate actions planned (LT).

Item 4 There were several examplee of incorrect information in the PSTG that- 1 Lreflect on system capability. . The PSTG refers to the steam condensing j mode of RHR, HPCI use for boron injection, LPCI loops C and D heat'  ;

exchanger capability and RPV flooding sources, none of~which exist ~in  !

the plant.

Response j The PSTG,has been revised to reference only Limerick Gene-". ting

-Station (LGS) systems and not generic systems'(ST). i Item 5 '

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.There are several actions contained in the TRIP. procedures which are 1 not directed by the PSTGs. In T-101 (RPV control), when an'SRV is cycling,-adequate core cooling is not considered when establishing suppression pool cooling. T-112 contains direction to avald emergency depressurization of the reactor vessel below 100 psig unless motor driven pumps are available. Technical Specifications actions are included in the SP/T portion of T-102.

Response

We will evaluste whether to remove suppression pool ecoling operation from T-101 or specify to use an RHR pump which is not required for adequate core cooling (LT). T-ll2 has been revised to remove this direction (ST). We will evaluate whether these actions should be 1 removed from T-102 (LT).

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Paga:3 of 10 Inspection Report 50-352, 353/90-80.

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Item 6 ,

A: number of. transition points'were found to be'in error in several TRIP procedures.

Response

All TRIP procedure ficwcharts have been reviewed and revised where necessary-to ensure the proper step numbers at the entry / exit arrows ,

~are correct providing proper transition directions (ST). ,

-Item 7 Terminology used in certain flowcharts is ambiguous. . These terms require concise definitions-that are-clearly understood by the operators.

Response ,

Administrative Procedure A-94, " Preparation of Transient Response Implementation Plan (TRIP) Procedures," has been revised ~to define terms such as " stabilize", " shutdown",.and " consider" (ST). We are evaluating if the TRIPS should give more' guidance on how the operator

- can determine if the reactor is " shutdown" (LT).

Item 8 N The RPV Control procedure, T-101, step RC/P-14, directed an operator to hold at~this step until " power is below 4%."' The PSTG~ requires that the operator determine if-the reactor is " shutdown" at'this '*

- point.

Response ,c 5

T-101 step RC/P-14 has been revised to verify the reactor is

" shutdown" rather than " power...below 4%" (ST).

' Item 9 l

The Primary Containment Control procedure,~T-102, steps SP/L-22 and SP/T-14, permit'depressurization only if boron injection is not required. The PSTG requires depressurization regardless of whether boron injection is' required. I Response i lq The wording "UNLESS BORON IS REQUIRED" has been removed from T-102 (ST).

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?. Attachm3nt *

' --Pcga-4 of 10 Inspection Report 50-352,-353/90-80 "

Item:10

-The?PrimaryLContainment-Control procedure, T-102, step SP/L-8'has a'  ;

note'whichl states that'at'17.8 feet suppression pool' level, the.

SPOTMOS temperature indication becomes invalid,- The noteLdoes not-

. direct the operator to use~an alternate indication, in this case [

Residual' Heat Removal (RHR). pump suction' temperature indication with an'RHR~ pump in service.

J l Response Note #2 of-T-102 has in3n revised to add use of the RHR suction- 1 temperature' indicator-with:the RHR pump runningJ(ST).

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'The Emergency Blowdown procedure, T-ll2, steps EB-1, EB-2 and EB-3, require the; operator to SCRAM the reactor and enter the~ SCRAM

-procedure,-T-100'. . This action is considered by the inspection team to v beia redundant step.since all T-112 entry conditions but one, T-102 DW/T, already; direct _thefreactor to be SCRAMed prior to~ entering T-

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3 112.

o, a-Response j, We are evaluating placing the SCRAM direction in.T-102 DW/T and  :

removing itifrom the T-112 procedure (LT). q i

Itemil2 T-ll2 step EB-19 directed securing HPCI on high. suppression pool 4'

. level.- This..is considered to'be redundant due to this guidance appearing in-T-102., gj

Response Step EB-19 of'T-112 has been. deleted-(ST).

Item 13 The north:and south stack process radiation monitor HI-HI alarm i setpoints, used~as entry conditions.into the Radioactivity Release 1 Control. procedure, T-104, are conservative with respect to the BWR ,

Owners Group Emergency Proceduro Guideline (EOP) entry condition s requirement of " release rate above the offsite release race which requires an Alert." The T-104 entry conditions are satisfactory with ,

respect'to monitored releases, but do not directly address the t unmonitored release path scenario. }

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Attcchm3nt.

Pago 5 of:10 t *

-Inspection Report 50-352, 353/90-80 Response.

T-104 has been revised:to show an entry from EP-101 (ST). EP-101 has been revised-to.give direction to enter-T-104 on appropriate-  !

radiological conditions (ST). The PSTG has been revised to J tincorporate the above-changes-(ST).

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.; c ; Control Room and Plant _Walkdowns, Sections 5.0-and 10.0 i i

-Item 1 Based 1on walkdowns performed during the Emergency Operating Procedure (EOP) Inspection, the glare from the plexiglass covering the flowcharts in the Main Control Room (MCR) is excessive. The glare makes-it difficult to use the procedures.-

Response

i Actions are being planned to reduce the glare-on the plexig1c. (LT). j l

Item 2 1 1

Non-licensed operators (NLOs) occasionally had difficulty in locating infrequently operated. valves during the walkdown of the T-200 series procedures.

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Response

1 The T-200 sviles procedures will be evaluated to determine why i operators are having difficulties in locating valves-and appropriate  !

actions will-be taken to resolve this problem (LT).  :

Simulator, Section 6.0

' Item 1 One of the comments noted during the plant walkdown was that the ,

. curves in the Safety Parameter Display System (SPDS) in the plant do  ;

not agree with the curves in the TRIP procedures. The SPDS was not j used by operators in the simulator because it.is not yet functional in the simulator.

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Attachm2nt '

P ga 6 of.10-Inspection Report- 50-352,-353/90-80; r Response i

.. t The SPDS. curves are being revised to agree with those in the TRIP  ;

procedures (LT).

Item 2 g The current 11ocation of the SPDS monitors is not conducive for use by the shift supervisor,while using the TRIP procedures. The SPDS *

. monitors are located on the shift supervisors. desk and the reactor.

opdtators' computer desk. .The TRIP procedures.are used by the shift supervisor _on.the back of the reactor operators.comouter desk. <

Neither monitor is visible to-the shift supervirs.

Response ,

~The need for relocating the SPDS terminals in tr.J MCR so & person using the TRIPS can read the terminals is being evaluated and >

appropriate' actions will be determined (LT). 3 Human Factors Review of the EOPs, Unresolved Item 90-80-02, Section 7.0 Item 1 Two principal human factors concerns about the TRIP flowcharts were identified size and complexity. .T-101-(RPV Control) and:T-102 (Primary. Containment Control) are inconvenient to use because of'their dimensions. The size of the flowcharts is related to the wording of .

the step instructions which are frequently long and complex.

Response

Actions .are being planned to reduce the si::e, words, and steps of flowcharts (LT). Additionally, specific human factors findings itemized in Attachment C will be addressed by an encompassing human' factors review'(LT).

Walkdown Comments, Attachment B E

Item 1 Many of the T-200 series procedures contain sets of steps which

' install jumpers or lift leads. However, the purpose for performing

! each-step is not always obvious.

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Attachmsnt

. Page 7 of 10 Inspection Report 50-352, 353/90-80 i n

Response _,

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A review will be performed to determine whether descriptive text'for o

each' major set of jumper / lifted lead steps should be added to the T-200 series procedures (LT).

L IEem 2 r Inspectors noted that some of the area maps an signs formerly located at the 'tcps of stairwells and entrances to areas have f al2 rn down, or are missing. .This makes it more difficult for operatore to locate infrequently operated components which are required to be operated in ,

the T-200 series procedures. i

Response

.A plan will~be developed to ensure all area maps in the Reactor Enclosure are-in place or to incorporate maps into appropriate TRIP procedures _(LT).

, Item 3 Step RC/P-8 of T-101~has the operator open the Main Steam Isolation Valves (MSIVs) to provide a heat sink, using procedure T-221-if necessary. LT-101 did not " Restore Instrument Air" after a.LOCA signal per procedure SE-10, nor.did T-221 restore instrument air to the i outboard MSIVs.- Without. instrument air, the outboard MSIVs.could not- i be opened. ,

Response

We added the proper steps to T-221_ prior to the inspection team t departing the site (ST). Additionally, we will review whether T-101 also requires a revision for this concern (LT).

Item 4 The T-102 related curves in the SPDS did not match the current revision of the BWR Owners Group EOPs. SPDS does caution the operators that the curves currently in SPDS are not valid'for use with

,the TRIP procedures. i

Response

Revision to the SPDS curves is ongoing and is expected to be completed by October 31, 1990.

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Attachmsnt- {

Pcga 8 of 10 1 Inspection Report 50-352, 353/90-80

-ItemLS f a* '

Curve PC/P-3 (Primary. Containment Pressure Limit) of T-102 asks for 7: Drywell. Pressure on recorder PR57-*01 to calculate containment > level.

The recorder'is labeled 4"Pri Cont Atm" versus "Drywell' Pressure". '

(@ . -i Response 4 The: TRIP flowchart was corrected to agree with the recorder (ST).

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In step RF-19 of T-116, "RPV Plooding," the operator is directed to check for a 69 psid' pressure 1 difference between the reactor pressure

. vessel and the suppression pool. The RPV pressure instrument has 20- ,

psig scale increments.and the SP instrument has S psig scale 1"crements.. A 69 psid would be difficult to read.

' Response The 69 psid has been changed to 70 paid (ST).  ;

.t Item 7 The borax and boric acid stored in the locker near the'SLC tank would 3 t

be of--little use for filling the CRD pump suction ' strainer body, as it s would need to be transported-down three floors and from the reactor- .

enclosute building to the-turbine building. The' locker contains'no-  ;!

thermometer as specified~in the procedure. '

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A thermometer was added to the cabinet prior to the inspection team leaving'the site. The T-211 procedure, _"CRD System Boric Acid-Sodium. - ,.

Pentaborate Injection," has since been cancelled as recommended by the inspection team since this. procedure is not feasible to implement and

.more desirable methods are available (ST). [

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Item 8 The handswitch for SV-57-201 also controls SV-57-239, but is not labeled as - such on ttie control board. il

Response

l; A revieu of the Main Contfal Room panel labels will be conducted and L appropriate corrective actions planned (LT). ,

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~.,$ , [ i' Attcchment Page 9'of 10-Inspection Report- 50-352,' 353/90-80 1- ,

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Human' Factors Examplea, Attachment C Item 1' Administrative' Procedure A-94, " TRIP Writer's Guide," provides'no-guidance for the_ writing of logic statements.

Responne Guidance will be included in A-94 for writing logic statements (LT).

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A-94 does not define a very effective way of using color in the flowcharts.

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Response

Guidance will be included in A-94 on effective use of color-in the flowcharts (LT). 1 1

Item-3 A-94tdoes not-fully state-the conventions.for presenting; referencing H

o: instructions (i.e.c instructions to execute.another procedure (

concurrently) 'and branching instructions (i.e., instructions to leave q

-the,present, procedure or branch and go_t'o-another procedure). In: the j flowcharts, references to T-200. procedures are put-inLcommand boxes. '

References to T-100: procedures are put in special symbols unless:the 0 reference is. conditional, in which case.it appears in the recheck step-

-command symboll These practices were found"to:be used consistently, .

but they are not mentioned in A-94. References.to'non-TRIP procedures

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are not treeted-as consistently. Sometimes they are in;the command

box and sometimes in the reference symbol. . Examples of this

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inconsistency are given in the findings related to the TRIP l

-procedures.

' Response.-

, Writer's guidance will be provided to ensure that consistency is :l maintained'(LT).

Item 4

'. A-94' specifies that_ flow lines are to be darker than the flowchart symbols. The difference in line intensity is substantial. The

_ guidance is inconsistent with the recommended practice (as indicated

'in NUREG/CR-5228). -

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. Inspection Report 50-352, 353/9m 30 1

Response

A-94 and the TRIP procedures will be reviewed with the current direction provided in NUREG/CR-5228 and'a resolution will be p ' determined for the difference identified-(LT). j L

Item 5-l

'A-94 does not provide guidance on the method of verification, i.e., it i does not say what will be done to verify a procedure or procedure revision. A-94 also.provides no guidance on how problems identified during thl's verification will be resolved.

Response

Additional guidance will be included in A-94 on methods of verification and validation (LT).

l Items 6 and 7 A-94 does not provide guidelines for determining when verification is ,

required >and when validation 11s required. These decisions are left to i the discretion'of the procedure writer who makes recommendations to the Plant Operations' Review Commit *;e (PORC). Additionally,-A-94 does notLmake'it completely clear that .erification and validation apply to  ;

satellite procedures:(T-200 serit , as well as to the flowcharts. Of particular concern is the need to make sure that satellite procedures tare' walked down in sufficient detail to make sure that they are -

accurate, feasible, and appropriate for the. emergency. situation; that -

the'in plant components involved can be readily located; and that the tools, materials, and equipment needed to perform the tasks are available.

Response

• Actions will ba planned to ensure that all T-200 series and satellite procedures receive verification and validation (LT).

A root cause investigation of the noted EOP/ TRIP findings is not expected to yield significant or specific corrective actions for the

process. Therefore, we do not plan to conduct such an investigation..

The. cover lettar that transmitted the inspection report also requested that we review these findings to determine if they affect the Peach Dottom Atomic Power Station (PBAPS) TRIP procedures. These items were discussed with Operations Support personnel at PBAPS and they agreed to perform the review. Additionally, these findings will be incorporated into the Nuclear Group Administrative Procedure which is being developed to provide a common procedure for the TRIP procedure development process ar.d writers guide for both LGS and PBAPS.