ML20077B716
| ML20077B716 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/21/1983 |
| From: | Bradley E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8307250401 | |
| Download: ML20077B716 (14) | |
Text
{{#Wiki_filter:a. .e PHILADELPHIA ELECTRIC COMPANY 23O1 M ARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 EDW A R D G. B A U ER, J R. wees Paeseosm? ano sensan6counset EUGENE J. BR ADLEY assoceafs sansma6 counse6 DON ALD BLANKEN RUDOLPH A. CHILLEMI E. C. KIR K M A LL T. H. M AH ER CO RN ELL PAUL AUERBACH assesTaNT SENENas coWD.sEL July 21, 1983 EDW ARD J. CULLEN. J R. THOM AS H. MILLER. JR. I IREME A. Mc K EN N A assistant counsas Mr. A. Schwencer, Chief Docket Nos. 50-352 Licensing Branch No. 2 50-353 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C. 20555
Subject:
Limerick Generating Station, Units I and 2 Responses to Open Review Items from NRC Licensee Qualification Branch (LQB) Re f e rence : Meeting, Philadelphia Electric Company and USNRC, July 13, 1983 File: GOVT l-1 (NRC)
Dear Mr. Schwencer:
Enclosed are responses to four open review items conveyed to Philadelphia Electric at the reference meeting. Attached to each response are draft FSAR page changes which provide the information requested by Licensee Qualification Branch. The information contained in these draft FSAR pages will be incorporated into the FSAR, exactly as it appears in the enclosure, in the revision scheduled for August, 1983. Sincerely, 8307250401 830721 Euge e J. ad1ey PDR ADOCK 05000352 A PDR HDH/gra/36 \\ Enclosures Copy to: See Attached Service List o
O-a cc: Judge Lawrence Brenner (w/o enclosure) Judge Richard F. Cole (w/o enclosure) Judge Peter A. Morris (w/o enclosure) Troy B. Conner, Jr., Esq. (w/o enclosure) Ann P. Hodgdon (w/o enclosure) Mr. Frank R. Romano (w/o enclosure) Mr. Robert L. Anthony (w/o enclosure) Mr. Marvin I. Lewis (w/o enclosure) Judith A. Dorsey, Esq. (w/o enclosure) Charles W. Elliott, Esq. (w/o enclosure) Jacqueline I. Ruttenberg (w/o enclosure) Thomas Y. Au, Esq. (w/o enclosure) Mr. Thomas Gerusky (w/o enclosure) Director, Pennsylvania Emergency Management Agency (w/o enclosure) Mr. Steven P. Hershey (w/o enclosure) Donald S. Bronstein, Esq. (w/o enclosure) Mr. Joseph H. White, III (w/o enclosure) David Wersan, Esq. (w/o enclosure) Robert J. Sugarman, Esq. (w/o enclosure) Martha W. Bush, Esq. (w/o enclosure) Spence W. Perry, Esq. (w/o enclosure) Atomic Safety and Licensing Appeal Board (w/o enclosure) Atomic Safety and Licensing Board Panel (w/o enclosure) Docket and Service Section (w/o enclosure)
6 Item No. 1 (FSAR Section 13.1.2.1) Minimum operating shift crew composition as shown in FSAR Table 13.1-2 is not acceptable.
Response
b Table 13.1-2 is being revised to meet the r e qui gIne n t s of TMI Item I.A.I.3. Draft FSAR Table 13.1-2 is attached. s 4 _._,,,.,.._,.,_._,,,._...,,,ym._..
I. LGS TSAP TAF:.E 13.1-2 (' SHIPI CPFW COMPCSITICN - MINIMUM RECCIPEMENTE8 8,8, s,e s f cNT_,pNT* FUFLED TwD 17NT FUFLEp LICENST Two Dr.its One Unit Cpera*ino and
- wo Unit s post' ION Pr0 DIP'D Cr e ra t ina Cold nu* dows entratina One Unit Ftu tivn ppjjaQh Shift SPO 1
1 1 per 2 1 se r 2 tutit s 1 per 2 unite sis >a rinte ndcnt units a shift sRo 1 1 1 se r 2 1 per 2 units 1 per 2 units swervisor units 1 Control PO 1 The control 1 pe r 2 1 per 2 units operator operator posi- , units tion or the assistant posi-tion till be utvin ed. Assis t ant PO 1 1 per tssit 1 per unit 1 per unit Control ope ra t or "PL.A ef Plant 1 The woneret 1 per 2 1 ser 2 units 1 per 2 unite ( operator crerator posi-units tion or the assistant posi-tion will be sanned. Assist ant 1 1 per 2 1 ser 2 units 1 per 2 units plan t units oserat or 1 per 2 [ [ TT Auxilia ry units 1 m S W" 1M%# oserat or (as At Isast one licensed PO shall be present in the control room and assigned to each reactor that contains fuel. 883 At least 2 licensed Poe, excluding the operator of the second unit, shall be present in the control room during reactor startup, sche & sled reactor shetdown, and recoeery from reactor trips. All core alterations shall be directiv supervised by either a licensed SRO or 3RO I.isdted to Peel Bandling, who ( 83 has no other conewrent responsibility during this operation. (*3 A health phesics technician aball be on site at all times when fuel is in a reactor to ensure implementation of the radiation protectiOR program.' l ) f ga. n,Of/f3
Item No. 2 (FSAR Section 13.1.2.2) We require that each operating shift include at least one individual who has substantive previous BWR operating experience.
Response
The response to Question 630.8 is being revised to provide the requested information. The draft response to Question 630.8 is attached. 's I
i ( LGS FSAR QUESTION 630.8 Does the applicant require that each shift has at least one individual who has substantive previous BWR commercial startup and operating experience?
RESPONSE
Philadelphia Electric Company d:::
- t ccquire th t ch shift
.hase at least one individual who has substanti previous BWR, commercial startup and operating experience tooTo e " The present number of shift people at Limerick with substantive previous BWR commercial startup operating experience are 4 shift Th: refer:, this superintendents and 1 shift supervisor.f.edelphi: -ituatinn will rek: it evosible twc P,y Electric C =peny -te have ene individual with betentpe 5,revicu; EF". cc--ercial arar+up end oper: ting e.pecience o each ohift. & T E co u A m. M , a4a I s Y _I y, 'y. p & da v A v i<ac =r. W 'y L M ~
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9 8 630.8-1 Rev.)d,0[/83
Item No. 3 (FSAR Section 13.4) The applicant's description of what the OSRC will review generally conforms to those matters normally included in the plant technical specifications. However, the description does not include review of safety evaluations for changes to procedures, equipment or systems and for tests and experiments to verify that such action did not constitute an unreviewed safety question. This requirement should be added to the description of OSRC review responsibilities.
Response
The requested information has been added to Section 13.4. See draft FSAR pages 13.4-4 and 13.4-5, attached. FSAR page 17.2A.1 -3 has been changed for consistency. )
r '/ k. 2bo octoty ovolucticas icz 1) ebangos to ) '/) procedures, equipant er systema and 2) tests or exprisente ccspleted under the provision of 10 CT3t 50.59, to verif that such actions did not constitute an unrev ewed anfety question. y may appoint, in writing (such as in Committee meeting minutes), subcommittees for purposes such as performing reviews or studies in areas of particular expertise or for performing special investigations. The O&SR Committee, and those performing reviews or audits under the cognizance of the Committee, shall have access to records and personnel as necessary to properly perform their functions. The O&SR Committee shall be kept current on events within its responsibility by reviewing reports and by the activities of the Committee members. The O&SR Committee shall meet at least once every calendar quarter during the initial year of Unit 1 operation following fuel loading, and at least once every six months (or more often as determined by the chairman) thereafter. A quorum shall consist of the chairman, or his designated alternate, and four members or alternates. No more than a minority of the quorum shall have line re.sponsibility for operation of the plant. The O&SR Committee shall review: y g /. Proposed changes to procedures,' equipment or systems that involve an unreviewed safety question as defined in 10 CFR Part 50.59 ( C. f. Proposed tests or experiments that involve an unreviewed safety question as defined in 10 CFR Part 50.59 d. Proposed changes to technical specifications or the / operating license prior to submittal to the NRC s/. Violations of codes, regulations, orders, technical specifications, license requirements, or of internal procedures or instructions having nuclear safety significance. This shall normally be accomplished by review of PORC meeting minutes, special reports, or reports of audits. l [f. Significant operating abnormalities or deviations from normal and expected performance of unit equipment that affect nuclear safety. This shall normally be accomplished by review of PORC meeting minutes, special reports, or reports of audits. $ [. Reports of events requiring 24-hour written notification to the NRC g g. All recognized indications of an unanticipated deficiency in some aspect of design or operation of structures, systems, or components that could affect ( nuclear safety. This shall normally be accomplished by 13.4-4
- D N
a
J ,,. I LGS FSAR i review of PORC meeting minutes, special reports, or reports of audits. b '. Reports and meeting minutes of the PORC / The O&SR Committee shall report to and advise the Vice President of Electric Production in the areas of O&SR Committee review and audit responsibilities. Minutes of O&SR Committee meetings shall be prepared and retained and shall identify documents reviewed, decisions and recommendations made, and actions taken by the Committee. The minutes shall be promptly (normally within 14 days following each meeting) forwarded to the Vice President of Electric Production and to other members of management as appropriate. s 13.4.4 AUDIT PROGRAM Audits of plant. activities in the following areas shall be performed under the cognizance of the O&SR Committee: a. The conformance of unit operation to provisions contained within the technical specifications and applicable license conditions at least once every 12 months b. The pet'formance, training and qualifications of the operating staff at least once every 12 months c. The results of actions taken to correct deficiencies occurring in unit equipment, structures, systems, or method of operation that affect nuclear safety at least once every six months d. The performance of activities required by the operational. quality assurance program to meet the criteria of Appendix B, 10 CFR Part 50, at least once every 24 months e. The emergency plan and implementing procedures at least once every 24 months f. The security plan and implementing procedures at least once every 24 months g. Any other area of unit operation considered appropriate by the O&SR Committee or the Vice President of Electric Production h. The fire protection program and implementing procedures ) at least once every 24 months 13.4-5
- gel 2.5,o8/f5
) s'* 1 l LGS FSAR i 4. ANSI N18.7 - 1976/ANS 3.2, Section 4.3, Independent Review Prooram - The description and activities of the Operation and Safety Review Committee will be as specified in the LGS Technical Specifications. 5. ANSI N18.7 - 1976/ANS 3.2, Section 4.3.2.2, Meetino Frequency - The " period of initial operation" means "one year after fuel loading of Unit 1". 6. A '18. 7 - 1976/ANS 3.2, Section 4.3.4, Subiects Requiri ndependent Review - Item (1) - Written .ety [ evaluations 'ch do not involve an unreviewe ety i TWRA&RAPM question and whi not involve a change the Technical Specificatio e not revi by the O&SR DrurDED A Committee. Depending upon ting organization, safety evaluations would be or by an engin.eer, subjecte'd to design rev , and reviewe the PORC. Because of such red nt reviews, it is n necessary for O&SR to rev' these documents and, becaus f the large numbe such safety evaluations, the requi d effort detract from'more important matters co ered by O&SR. 7. ANSI N18.7 - 1976/ANS 3.2, Section 4.4, Review Activities of the Onsite Operatina Organization - The word " verify' does not imply review or certification by supervisory personnel of every day-to-day operating activity; rather, the performance of reviews of doguments and logs and monitoring activities by supervisory personnel in accordance with station procedures and practices is considered to meet this requirement. 8. ANSI N18.7 - 1976/ANS 3.2, Sec. ion 5.2.1, t Responsibilities and Authorities of Operatino Personnel - Item'(4) is-changed to read: "The responsibility to respond conservatively to instrument indications including the case in which the credibility of the indication is in doubt". This statement permits the operator to compare Control Room instruments and infer instrument error without proving it such as by calibration checks. 9. ANSI N18.7 - 1976/ANS 3.2, Section 5.2.2, Procedure Adherence - The term " supervisor in charge of the shift" 17.2A.II-3 Rev. 2 0[/83
' (J Item No. 4 (FSAR Section 13.4) The applicant's description of the functioning of the ISEC conforms to that presented in TMI Action Plan Item I.B.I.2 o f NUREG-0737 and is acceptable. However, the applicant's proposal to have ISEG composed of only three dedicated full-time engineers is not acceptable because it does not conform with the Action Plan requirement of five engineers.
Response
The requested information has been added to Section 13.4. See draft FSAR page 13.4-7 and figure 13.1-1, attached. l
LGS FSAR '( field. The ISEG may also contain additional engineers, other ~ . technically oriented personnel, and administrative support personnel. The ISEG will be responsible for maintaining surveillance of unit activities to provide independent verification that these activities are performed correctly and that human errors are reduced as much as practical. The ISEG will not be responsible for sign-off functions. The ISEG will ke detailed recommendations for revised procedures, eq ent modifications, maintenance activities, operation acti ities or other means of improving plant safety to the Engineer-In-Charge of the Nuclear Safety Section', who will be
- located in the corporate offices.-
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, m -. m m.-- "'^~~~" .'."'...."".."..".,'y..........'"' T:! 7:::'.".T ;E.:..' :.,'.::2 '.:r': :'"L '. "'The ~ Engineer-In-Charge of the Nuclear Safety Section reports to the Superintendent-Nuclear Services on matters of a routine nature and to the Chairman of the Operating and Safety Review Committee
- f on matters of a safety-related nature.
9 ./ 4 9 Rev.1/,'o/'a3 13.4-7
-_4_ = _ - _.. - _ J i i i (l),1RE.15 4=7 } Insert A corporate ISEG group and the Operating Experience Assess-ment Committee will complement the Limerick ISEG in the performance of independent safety assessment functions. The corporate ISEG group will be composed of at least two dedicated, full-time engineers, each with a bachelor's degree in engineering or related science. This group will (1) evaluate internal plant upset reports, QA audit reports.and Plant Operating Review Committee minutes; (2) screen external operating experience information and distribute pertinent information to the Limerick ISEG; (3) maintain the implementation status of recommendations contained in significant operating experience information, such sas General Electric Company's Service Information Letters and the Institute of Nuclear Power Operations Significant Operating Experience Reports; (4) track implementation status of significant f corrective action with regard to ISEG recommendations; (5) provide on-site technical assistance, when required, to assist in Limerick ISEC investigations; and (6) provide an interface between the Limerick ISEG and Engineering and Research Department personnel, located in the corporate of fices, who design plant modifications. The Operating Experience Assessment Committee will be composed of representatives from plant staff from both Limerick and Peach i Bottom, from ISEG groups at both Limerick and Peach Bottom, from j. Electric Production Department's Quality Assurance Division and from Engineering and Research Department's Mechanical Engineering and Electrical Engineering Divisions. The committee members will receive, on a continuing basis, significant internal and external operating experience information, and will meet monthly to discuss it. This committee will provide a broad inter-disciplinary review and may make recommend &tions on improving operations, procedures, training, and maintenance. This committee will facilitate the exchange of information on operating and design problems encountered at both Limerick and Peach Bottom. I Also, since the Limerick and Peach Bottom plant designs are similar, many of the Peach Bottom ISEG's assessments, particularly i in the areas of design, training, corrective maintenance and, to some extent, operations, may be directly applicable to Limerick and vice-versa. The Peach Bottom ISEG will be similar in composition to and will have similar responsibilities as the Limerick ISEG. i 4 1 ..-.,___-o .,m,, ,.-,,n., ,.s, w,w - i--
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