ML20073S140
| ML20073S140 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/04/1983 |
| From: | Bradley E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.C.1, TASK-1.C.6, TASK-1.D.1, TASK-1.D.2, TASK-1.G.1, TASK-3.A.1.2, TASK-TM NUDOCS 8305060457 | |
| Download: ML20073S140 (9) | |
Text
re PHILADELPHIA ELECTRIC COMPANY 23O1 M ARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 EDW ARD G. B AU ER, J R.
(21510414000 vice enssionne aseo ennessas coussak EUGENE J. BR ADLEY assoceava esmunak counset DON ALD BLANKEN RUDOLPH A. CHILLEMI 4, MO E.C.KIRKHALL T. H. M AH ER CO RN ELL PAUL AUERE ACH Assestan, emeesnak cousosak EDW ARD J. CULLEN. JR.
THOM AS H. MILLER, JR.
BRENE A. Mc K EN N A Assant Anv counss6 Mr. A. Schwencer, Chief Licensing Branch No. 2 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C. 20555
Subject:
Limerick Generating Station, Units 1 and 2 Response to TMI Items File:
GOVT 1-1 (NRC)
Dear Mr. Schwencer:
The attached documents are draft responses to TMI Items I.C.1, I.C.6, I.D.1, I.D.2, I.G.1 and III.A.1.2.
These responses will be formally incorporated into the FSAR no later than June, 1983.
Sincerely, l
radley Eu 2ne l
D LN/gra/Z-13 cc:
See Attached Service List 8305060457 830504 PDR ADOCK 05000352 A
pyg
a.
e cc: Judge Lawrence Brenner (w/ enclosure)
Judge Richard F. Cole (w/ enclosure)
Judge Peter A. Morris (w/ enclosure)
Troy B. Conner, Jr., Esq.
(w/ enclosure)
Ann P. Hodgdon (w/ enclosure)
Mr. Frank R. Romano (w/ enclosure)
Mr. Robert L. Anthony (w/ enclosure)
Mr.'Marvin I. Lewis (w/ enclosure)
Judith A. Dorsey, Esq.
(w/ enclosure)
Charles W. Elliott, Esq.
(w/ enclosure)
Mr. Alan J. Nogee (w/ enclosure)
Thomas Y. Au, Esq.
(w/ enclosure)
Mr. Thomas Gerusky (w/ enclosure)
Director, Pennsylvania Emergency Management Agency (w/ enclosure)
Mr. Steven P. Hershey (w/ enclosure)
James M. Neill, Esq.
(w/ enclosure)
Donald S. Bronstein, Esq.
(w/ enclosure)
Mr. Joseph H. White, III (w/ enclosure)
Walter W. Cohen, Esq.
(w/ enclosure)
Robert J. Sugarman, Esq.
(w/ enclosure)
Rodney D. Johnson (w/ enclosure)
Atomic Safety and Licensing Appeal Board (w/ enclosure)
Atomic Safety and Licensing Board Panel (w/ enclosure)
Docket and Service Section (w/ enclosure)
Response to I.C.1 Emergency operating procedures have been developed from the BWR Owners Group Emergency Procedure Guidelines (EPGs), Revision 2, which have been reviewed and approved by the NRC.
The development of the EPGs was based on reanalysis of transients and accidents and inadequate core cooling.
The licensed operator training program includes training on the emergency operating procedures.
Additional information has been provided in a letter from V. S. Boyer to D. G. Eisenhut dated April 15, 1983.
4 7
,,e
Response to I.C.6 Plant procedures will describe a system for the proper control of removal and restoration and alignment of safety-related plant systems or equipment.
This system will use a combination of control room indicators, operability testing, or independent verification (subject to radiation exposure limitations) to assure that equipment is in its correct alignment.
Response to I.D.1 The Control Rocm Design Review (CRDR) effort directed by Item I.D.1 and required by Supplement 1 to NUREG-0737 began in 1980 with PEOD's participation in the Boiling Water Reactor Owners Group (BhKG) CEDR Subcm mittee. The subcm mittee produced a BKFOG Generic CRDR Program which addresses Its 5.1.b of Supplement 1.
This Generic Program was subnitted to the NFC for review in August,1981. The review and subsequent discussions between the NBC and representatives of the subcamittee have resulted in a supp1 ment to the review program.
A preliminary review of the Limerick control rocm was conducted using the original design review program in October, 1981. At that time, the Iamerick control rom was still in the construction phase and the formal Limerick unique Emergency Procedures were not available for the walk-through.
PEOD is currently developing a program to address the Assessment, Implmentation and Verification phases of the Limerick Control Rom Design Review Program.
BASIC REQUIREMENTS CmPLETION DATES:
(Numbering refers to corresponding portions Section S of Supplement 1) 5.1. a)
As was the case during the initial review phase, a person cmpetent in human factors engineering as well as persons empetent in system design and system operation will be included in the assessment phase of the Program. This assessment will be cmpleted by January,1984.
5.1.b)
A preliminary review of the control rocm has been ccupleted as discussed in current status above. Completion of the review to address the supplemental check list, those itms not included in the prelinunary review due to construction status, and the Emergency Procedure Walk-through is scheduled for October, 1983.
This date is contingent on NBC concurrence with the review approach used in the BKFCG-CRDR program.
5.1.c)
Assessment of the Human Engineering Discrepancies (HED's) will be cmpleted by January,1984.
5.1.d)
Proposed improvements will be reviewed by the multi-disciplinary task force described in 5.1.a to assure the proposed change addresses the identified HED and does not create additional HED's.
All changes will be integrated with other control rcan modifications.
This will be cmpleted by February, 1984.
l i
5.2.a)
The program plan for completing the Control Room Design Review is outlined below:
1.
Complete the Generic review program including the supplemental review and the emergency procedure walk-through.
ii. Assess the identified HED's and generate recommendations for modifications to those HED's that warrant a change.
iii. Each of the proposed modifications will be reviewed to verify that it corrects the HED it was intended to correct and does not create any new unacceptable HED's.
The modifications will be coordinated with the balance of the NUREG-0737 Supplement 1 initiatives, iv.
A summary report will be prepared to document the program actions and recommendations.
It will also contain a schedule for modifications to correct the HED's.
5.2.b)
A summary report will be prepared and submitted May, 1984.
This will include proposed modifications and the proposed schedule. Any human factors enhancements (paint-tape-label) will be completed prior to fuel load. The modifications that require hardware changes will be scheduled according to equipment availability and start-up schedule. They may be deferred until the first refueling outage.
i i
l l
l
Response to I.D.2 The Limerick Design includes an Emergency Response Facility Data System (ERFDS).
This system is based on the General Electric Emergency Response Information System. The SPDS at Limerick will be a part of this ERFDS.
The hardware design is essentially complete with installation scheduled to begin in Aptil, 1983.
The software effort is proceeding on schedule to support system check out in August, 1983.
It is expected that the system will be operational by fuel load.
The parameters included in the Safety Parameter Display System (SPDS) display are based on the entry conditions for the Limerick sympton-based emergency procedures. As changes and improvements are mcde to the reactor pressure vessel control and containment control procedures, the system can be modified to reflect these changes. The SPDS parameters are a subset of the parameters available in the ERFDS data base, which is based on the Regulatory Guide 1.97 Rev. 2 BWR parameter list.
The system has been designed in accordance with the guidance provided in NUREG-0696.
A written safety analysis describing the basis on which the selected parameters are sufficient to assess the safety status of each identified function for a wide range of events will be available by August 1983.
Prior to fuel load, the SPDS will be reviewed in conjuction with the other NUREG-0737 supplement initiatives. As one of the final steps in integrating all of the control room modifications (i.e. Reg. Guide 1.97, SPDS, Emergency Operating Procedures), an emergency procedure walk-through is scheduled as part of the control room review.
l i
(
)
~
Response to I.G.1 The BWR Owner's Group Program for compliance with NUREG-0737 Requirement I.G.1 was transmitted to the NRC via letter (BWROG-8120) from D. B. Waters to D. G. Eisenhut. The generic program described in this document is ' '
- ~
divided into five sections: I-Preoperational Testing; II-Cold Functional Testing; III-Hot Functional Testing; IV-Startup Testing; and V-Additionaj Training and Testing. The initial test program for Limerick as described in FSAR Chapter 14 follows the testing described in the first four sections of the Owner's Group Program. During this program, PECO expects to perform significant plant transients only once, but with a maximum of licensed personnel in attendance. The Limerick unit unique simulator provides an -
excellent mechanism for training people without affecting the real plant.. -
Repetition of startup tests solely for testing purposes will be done on s,
this simulator.
,/-
Additional information is provided in the responses to SRAI-8 and Question 640.11.
T:
/
4.
n e
W.p
- l t
.+
f
/
- k
-w a
y
__y
,__r
_.g 7_
y
i te Response to III.A.1.2 The three types of ERF's required by Section 8 will be provided for Limerick.
The Technical Support Center (TSC) vill meet all of the requirements of Section 8.2.1.
The TSC will be fully functional by January, 1984.
Tho Operational Support Center (OSC) will meet all of the requirements of Section 8.3.1.
The OSC will be fully functional by January, 1984.
The Emergency Operations Facility (EOF) is located in an existing f
structure approximately 17 miles from the Limerick site. The EOF will meet all of.the technical requirements of Section 8.4.1.
The building
/
alterations necessary for the EOF will be completed by September, 1983.
The EOF will be fully functional by January, 1984.
Staffing of the EOF and the TSC is described in the Limerick Emergency Plan, Table I.I.
i f"
?
1
/
r w
e 6
l
- _ - - -, - - -,