ML20078R727
| ML20078R727 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 11/10/1983 |
| From: | Boyer V PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| GL-83-28, NUDOCS 8311150271 | |
| Download: ML20078R727 (35) | |
Text
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./
O PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 1215)841 4500 V. S. BO Y ER SR. VICE PRESIDENT N U C l.E A,, PO W E R November 10, 1983 Docket Nos. 50-352 50-353 Mr. Darrell G. Eisenhut Division of Licensing U.S. Nuclear Regulatory Commission Washington, DC 20555
References:
1.
Generic Letter 83-28, " Required Actions Based on Generic Implications of Salem ATWS Events",
July R, 1983.
2.
Letter, J. F. Stolz, USNRC to E. G.
Bauer, Jr., PECo., " Clarification of Reauired Actions Based on Generic Implication of Salem ATWS Events",
October 21, 1983.
Dear Mr. Eisenhutt Generic Letter R3-28, Required Actions Based on Generic i
Implications of Salem ATWS Events, issued July 8, renuires l
licensees to address issues related to reactor trip system reliability and general management capability in the areas of Post-Trip Review, Eauipment Classification and Vendor Interface, Post Maintenance Testing and Reactor Trip System Reliability Improvements.
The positions addressed in the Enclosure to Generic Letter 83-2R are as restated below along with our response for Limerick Units 1 and 2.
The Limerick units are currently under construction with a projected fuel load date for Unit 1 being mid-1984.
32
/
l A
A Mr.
D. G. Eisenhut November 10, 1983 Docket Nos. 50-352 Page 2
{
50-353 i
1.1 POST-TRIP REVIEW (PROGRAM DESCRIPTION AND PROCEDURE)
Position Licensees and applicants shall describe their program for ensuring that unscheduled reactor shutdowns are analyzed and that a determination is made that the plant can be restarted safely.
A report describing the program for review and analysis of such unscheduled reactor shutdowns should include, as a minimum:
1.
The criteria for determining the acceptability of restart.
I 2.
The responsibilities and authorities of personnel who will perform the review and analysis of these events.
3.
The necessary aualifications and training for the
.'esponsible personnel.
4.
The sources of plant information necessary to conduct the review and analysis.
The sources of information should include the measures and equipment that provide the.necessary detail and type of information to reconstruct the event
. accurately and in sufficient detail for proper understanding.
(See Action 1.2.)
4 5.
The methods and criteria for comparing the event information with known or expected plant behavior (e.g.,
that safety-related equipment operates as required by the Technical Specifications or other performance specifications related to the safety function).
6.
The criteria for determining the need for independent assessment of an event (e.g., a case in which the cause of the event cannot be positively identified, a component group such as the Plant Operations Review Committee, will be consulted prior'to authorizing restart) and guidelines on the preservation of physical evidence (both hardware and software) to support independent analysis of the event.
cc y
Mr. D. G. Eisenhut November 10, 1983 Docket Nos. 50-352 Page 3 50-353
RESPONSE
1.1 POST TRIP REVIEW Limerick Generating Station Units 1 & 2 are currently under construction and Philadelphia Electric Company is in the process of obtaining an. Operating License.
Plant
' operating procedures are currently being prepared by.the plant staff and reviewed by the Plant Operation Review Committee (PORC).
Currently procedures regarding Post 1
Trip Review have not been completed as part of the procedure writing program.
However, these procedures'and the qualifications and training of personnel responsible for post trip review and analysis will be modeled after those for Philadelphia Electric Company's Peach Bottom Units 2 and 3.
A description of the Peach-Bottom Units 2 and 3 post trip analysis is con'ained in the response to Generic Letter 83-28, S. L. Laltroff, Philadelphia Electric Company to D. G. Eisenhut, USNRC, November 4,
- 1983, Docket Nos. 50-277 and 50-278.
The applicable procedures for Limerick Units 1 and 2 will be forwarded to the Commission prior to fuel loading for Unit 1, along with the program description and personnel qualifications and responsibilities for post trip analysis.
1.2.
POST-TRIP REVIEW - DATA AND 'INFORMATION CAPABILITY Position Licensees and applicants shall have or have planned a capability to record, recall and display data and information to permit diagnosing the causes of unscheduled reactor' shutdowns prior to restart and for ascertaining the proper functioning of safety-related equipment.
Mr. D. G. Eisenhut November 10, 1983 Docket Nos. 50-357 Page 4 50-353 Adequate data and information.shall be provided to correctly diagnose the cause of unscheduled reactor shutdowns.and the proper functioning of safety-related equipment during these events using systematic safety assessment procedures (Action 1.1).
The data and information shall be displayed in a form that permits ease of assimilation and analysis by persons trained in the use of systematic safety assessment procedures.
A report shall be prepared.which describes and justifies the adequacy of equipment for diagnosing an unscheduled reactor shutdown.
RESPONSE
1D POST TRIP DATA tr INFORMATION CAPABILITY Limerick has the following provisions for data collection and analysis for unscheduled reactor shutdowns:
l '.
Capability for Assessing Sequence of Events (On-Off Indications)
This_ capability is provided by the plant process L
computer system.
This system consists of two Honeywell 4010 CPU's in a primary and hot standby configuration.
Several CRT's and printers are provided in the Control Room behind the Operator's Console for this system.
It is powered from an uninterruptible power supply which is backed up by a diesel generator.
The computer system and its power supply are non-Class IE.
The computer. system provides sequence of events monitoring of approximately 270 digital points.
The parameters monitored are listed on attached Table I.
Mr. D. G. Eisenhut November 10, 1983 Docket Nos. 50-352 Page 5 50-353 The sequence of events program is initiated by the occurrence of an interrupt caused by the change of state of any one of the contact points associated with event recording.
For each interrupt entry, the status of these contacts along with the time to the nearest cycle (16.6 msec) will be stored in queue.
Resolution for the sequence of events contacts will be two milliseconds with no guarantee on sequence for those changes faster than this resolution time.
On the first interrupt, the data will be gathered, l
time tagged and queued for later processing.
This data will be processed only after a full queue of 120 events or 5 minutes has elapsed.
The printed output will be continuous log printed on the logging typer with each event having the following format:
TIME CYCLE PT.ID DESCRIPTION ALM STATUS HHMMSS XX XXXX 24 Characters XXXX XXXX During the period of time that this queue is being processed, any additional sequence of events contact status changes will be stored in a second aueue to be processed in the same manner as the first.
The processing of the second queue will begin only after a full cueue of 120 events or 5 minutes has elapsed.
l As long as a full queue can be processed in less
~
tine than the fillina of the second queue, the incorrect time tagging of status changes will be avoided.
For the extreme case of additional Secuence of Events status changes occurring after the second queue is full, but before processing is completed on the first, these events will be logged as part of the Sequence of Events Log; but the time and cycle. field will be left blank.
Mr.
D. G. Eisenhut November 10, 1983 Docket Nos. 50-352 Page 6 50-353 Any " Sequence of Events" contact may also be defined as a regular alarm point.
That is, in addition to being logged in correct sequence as part of the Sequence of Events Log, it will be processed by the normal alarm handlers and typed on the alarm typer with the same resolution as all other alarms.
No permanent storage of the sequence of events is provided on disc or tape.
The printer hardcopy is the only permanent record.
I
O 4
Mr.
D..G.
Eisenhut November 10, 1983 Docket-Nos. 50-352 Page 7 50-353 TABLE I l
'REF.
POINT REF.
POINT NUMBER DESCRIPTION NUMBER DESCRIPTION C1000 MODE SWITCH POSITION RUN C1048 TURBINE OVEPSPEED C1001 MODE SWITCH POS SHUTDOW C1049 TURBINE BACKUP OVERSPEED C1002 MODE SWITCH POS REFUEL C1050 TURB BRG WEAR-TURB END l
C1003 MODE SWITCH POS STARTUP C1051 TURB BRG WEAR-GEN END CIC04 RFPT-A THST WEAR OUTBRD C1052 TURB EHC 24VDC POWER C1005 RFPT-B THST WEAR OUTBRD C1053 TURB EHC SPEED SIGNAL C1006 RFPT-C THST WEAR OUTBRD C1054 TURB EHC HYD FLUID PRESS,
C1013 RFP TURBINE-A C1055 TURBINE MASTER TRIP C1014 RFP TURBINE-B C1056 REAC LVL-TRIP TURB/RFPT C1015 RFP TURBINE-C C1059 COND PMPS DSCH HDR PRESS C1016 RFPT-A HIGH VIBRATION C1060-CONDENSER LOW VACUUM C1017 RFPT-B HIGH VIBRATION C1062 TURBINE HIGH VIBRATION C1018' RPPT-C HIGH VIBRATION C1063 TUR SHAFT PMP DSCH PRES C1019 RFPT-A LOW BRD OIL PRESS C1066 TURBINE UNIT TRIP C1027 RFPT-B LOW BRG OIL PRESS
.C1067 RECIRC MG A DRIV MIR BKR C102; RFPT-B LOW BRG OIL PRESS C1068 RECIRC MG B DRIV MIR BKR C102*
RFPT-A THST WEAR INBRD C1073 TURB TRIP RELAY VOLTAGE C1023 RFPT-B THST WEAR INBRD C1074 CONDENSATE PUMP-A BKR C1024 RFPT-C THST WEAR INBRD C1075 CONDENSATE PUMP-B BKR C1025 DIESEL GEN D11 LOCKOUT C1076 CONDENSATE PUMP-C BKR C1026 DIESEL GEN D12 LOCKOUT C1077 RFP-A LOW SUCTION PRESS C1027 DIESEL GEN D13 LOCKOUT C1078 RFP-B LOW SUCTION PRESS C1028-DIESEL GEN D14 LOCKOU" C1079 RFP-C LOW SUCTION PRESS C1035 LINE PROT RELAYS A 386 A C1086 RFPT-A HI EXHAUST PRESS C1036~
GEN PROT RELAYS A 386C C1087 RFPT-B HI EXMAUST PRESS -
i
.C1037' MN.XFMR PROT RELYS A 386B C1088 RFPT-C HI EXHAUST PRESS C1038 AUX XFMR PROT RLY A 386D C1089 GENERATGR BREAKERS TRIP C1039 LINE PROT RELAYS B 386E C1093 4KV DIESEL GEN BKR D11 C1040 GEN PROT RELAYS B 386G C1094 4KV DIESEL GEN BKR D12
[.
C1041 MN XFMR RLYS B 386F C1095 4 KV DIESEL GEN BKR D13 I
C1042 AUX XFMR PROT RLY B 386H C1096 4KV DIESEL GEN BKR D14 C1043 LP TURB-A EXH HOOD TEMP C1114 13KV BUS BKR 10-11 C1044 LP TURB-B EXH HOOD TEMP C1115 13KV BUS BKR 20-11
.C1045 LP TURB-C EXH HOOD TEMP _
C1116 13KV BUS BKR 10-12 C1046 GEN STATOR COOLANT C1117 13KV BUS BKR 20-12
.C1047 TURB EHC 125VDC POWER C1114 13KV BUS BKR 11 C1122 13KV BUS BKR 12 C1160 4KV BUS BKR 101-D11 C1515 CONTMT HIGH PRESS CH A2
Mr.~D. G. Eisenhut November 10, 1983 Docket Nos. 50-352 Page 8 50-353 I
C1161 4KV BUS BKR 201-D11 C1516 CONTMT HIGH PRESS CH B2 i
C1162 4KV BUS BKR 101-D12 C1517 REACTOR CHNL Al HI PRESS C1163 4KV BUS BKR 201-D12 C151R REACTOR CHNL B1 HI PRESS C1164 4 V BUS BKR 101-D13 C1520 REACTOR CHNL B2 HI PRESS C1165 4KV BUS BKR 201-D13 C1521 REACTOR LO Writ '7LV CH A1 4
- C1166 4KV BUS BKR 101-D14 C1522 REACTOR LO WTR LVL CH B1 l
C1167 4KV BUS-BKR~201-D14 C1523 REACTOR LO WTR LVL CH A2 C1178 SFGD XFMR 161 LOCKOUT C1524 REACTOR LO WTR LVL CH B2,
C1198 STARTUP BUS 10 LOCKOUT C1525 MSL Al HIGH RADIATION C1199 TRANSFORMER 122 LOCKOUT C1526 MSL B1 HIGH RADIATION C1200 10 STA AUX BUS LOCKOUT C1527 MSL A2 HIGH RADIATION C1220 4KV SFGD BUS D11 LOCKOUT C1528 MSL B2 HIGH RADIATION C1221 4KV SFGD BUS D12 LOCKOUT C1529 NEUT MON SYSTEM CHNL Al
~ C1222 4KV SFGD BUS D13 LOCKOUT C1530 NEUT MON SYSTEM CHNL B1 C1223 4KV SFGD BUS D14 LOCKOUT C1531 NEUT MONT SYSTEM CHNL A2 C1224 CIRC WATER PUMP-A BKR C1532 NEUT MON SYSTEM CHNL B2 C1225 CIRC WATER PUMP-B BKR C1537 MANUAL SCRAM CHANNEL A C1726 CIRC WATER PUMP-C BKR C1538 MANUAL SCRAM CHANNEL B C1227 CIRC WA'lER PUMP-D BKR C1539 REACTOR SCRAM CHANNEL A
. C1237 MOIST SEPARATOR Al LEVEL C1540 REACTOR SCRAM CHANNEL B C1238 MOIST SEPARATOR A2 LEVEL C1553 TSV FAST CLOSURE CHNL Al C1239 MOIST SEPARATOR B1 LEVEL C1554 TSV FAST CLOSURE CHNL B1 C1240 MOIST SEPARATOR B2 LEVEL C1555 TSV FAST CLOSURE CHNL A2
~ C1241-MOIST SEPARATOR C1 LEVEL C1556 TSV FAST CLOSURE CHNL B2 4
C1242 MOIST SEPARATOR C2 LEVEL C1557 TCV FAST CLOSURE CHNL Al' C1501 DISCH VOL LVL CHANNEL Al C1558 TCV FAST CLOSURE CHNL B1 C1502 DISCH VOL LVL CHANNEL B1 C1559 TCV FAST CLOSURE CHNL A2 C1503 DISCH VOL LVL CHANNEL A2 C1560.
TCV FAST CLOSURE CHNL B2 C1504 DISCH VOL'LVL CHANNEL B2 C1561 APRM CHNL A UPSCALE LVL C1509 MAIN STEAM LINE CHNL Al C1562 APRM CHNL B UPSCALE LVL C1510
'MT.IN STEAM LINE CHNL B1 C1563 APRM CHNL C UPSCALE LVL C1511' MAIN STEAM LINE CHNL A2 C1564 APRM CHNL D UPSCALE.LVL C1512 MAIN STEAM LINE CHNL B2 C1565 APRM CHNL E UPSCALE LVL C1513 CONTMT HIGH PRESS CH Al C1566 APRM CHNL F UPSCALE LVL
. C1514 CONTMT HIGH PRESS CH B1 C1569 IRM CHNL A UPSCALE LVL C1570 IRM CHNL B UPSCALE LVL C1571 IRM CHNL C UPSCALE C1572 IRM CHNL D UPSCALE LVL C1573 IRM CHNL E UPSCALE C1574 IRM CHNL F UPSCALE LVL C1575 IRM CHNL G UPSCALE C1576 IRM CHNL H UPSCALE LVL y
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Mr. D. G. Eisenhut November 10, 1983 Docket Nos. 50-352 Page 10 50-353 COMPUTER BASED DATA SYSTEM The Emergency Response Facility Data System (ERFDS) is a continuous on-line transient monitoring system.
It also is used to provide operating information to the operator via CRT graphic displays which include the Safety Parameter Display.
This sytem consists of two VAX 11-780 CPU's, one of Which updates the CRT graphics, the other stores and analyzes transient data.
The system peripherals consist of two CRT's in the Control Room, two in the Technical Support Center (TSC) and one in the Emergency Operations Facility (EOF).
Hardcopy printers are provided in each of these locations to provide a hardcopy of the CRT display.
A Versatec printer / plotter is provided in the TSC to plot transient data.
A line printer is also provided at the TSC.
The computer system is non-Class IE, but it interfaces with instrument loops through Class IE multiplexers Which L
also provide isolation via fiber optic cables.
The power supplies to the multiplexers are DC.
The Class IE multiplexers use Class IE DC power.
The power to the CPU's and the peripherals is provided by a non-Class IE uninterruptible power supply with battery back up.
After loss of all off-site power, the system will remain functional for at least 15 minutes.
The analog parameters monitored by ERFDS are shown on Table II.
These parameters were selected based on the following criteria:( 1) Those needed to comply with Reg.
i Guide 1.97 for post-accident monitoring, ( 2) Those needed for the startup transient test program, (3) Those needed to support the displays to be used in conjunction with the Emergency Procedure Guidelines.
There are eight scan classes for the input points with the following intervals:
1, 0.5, 0.1, 0.04, 0.02, 0.01, and 0.004 seconds.
The scan rates for each variable were selected based on an analysis by the nuclear steam supplier and.the architect-engineer.
The scan rate selected ~is based on the expected response time and time constant of the instrument and variable being monitored.
The capability exists to display up to ten parameters on one plot from either real time or historical data.
For each parameter, the user is able to select either the engineering unf.ts scaling of his choice or a default automatic scaling occurs.
The plots are marked with the I
4 Mr.-D. G. L.nenhut November 10, 1983
. Docket Nos. 50-352 Page 9 50-353 2.
CAPABILITY FOR ASSESSING THE TIME LISTING OF ANALOG VARIABLES Both strip chart recorders and a computerized transient monitoring computer system are available at Limerick for assessing the time listing of analog variables.
Strip Chart Recorders Strip chart recorders are provided in the Control Room for the following parameters.
These recorders provide continuous indication of the variable.
The power source for the recorder is also shown:
Parameter Power Source Reactor Level Non-Class IE "eactor Pressure Non-Class IE Reactor Level & Pressure Class IE Reactor Vessel Temperature Non-Class IE SRM Flux Non-Class IE IRM/APRM Flux Non-Class IE IRM/APRM/RBM Flux Non-Class IE Condenser Vacuum Non-Class IE Condensate Storage Tank Level Non-Class IE Suppression Pool Level Class IE Suppression Pool Pressure Class IE Drywell Temperature Class IE Recirc Pump Suction Temp Non-Class IE Recirc Loop Flow Non-Class IE HPCI Turbine / Pump Temp Class IE HPCI Turbine Vibration Class IE RHR Hx-Radiation Class IE SRV Outlet Temperature Non-Class IE Reactor Feed Pump Discharge Flow Non-Class IE Feedwater/ Steam Flow Non-Class IE Drywell Nitrogen Flow Non-Class IE Containment Radiation Class IE
Mr. D. G. Eisenhut November 10, 1983 Docket Nos. 50-352 Page 11 50-353 engineering units selected.
The trend plot time interval is any number of minutes within the preceding 30 minutes.
The capability also exists to plot one parameter against another parameter.
This capability allows an arbitrary time window and parameter selection.
Data collected by the Data Acquisition System (DAS) is compared against a unique significant change value.
When that value is reached or at least once every hour, the data is sent to disc where it will reside for approximately 14 days before being overwritten.
This data can be transferred onto tape for data archiving.
The system can also operate in a " trigger mode" wherein selected inputs are scanned and recorded at the selected scan rate when a pre-selected trigger variable exceeds a pre-selected limit.
All single parameter time trends can be displayed either on the CRT's or the printer plotter.
The multi-parameter plots are done on the printer plotter.
3.
.OTHER DATA AND INFORMATION The plant process computer and ERFDS provide monitoring of both digital and analog parameters which represent those most critical in assessing the operation of the plant in all operating modes.
In addition to these, the control room annunciator system provides a "First Out" capability for selected alarm points.
This allows identification of the first in a group of alarms received.
4.
PLANNED CHANGES Limerick does not plan any changes or additions to the above described information systems.
l
Mr. D. G. Eisenhut November 10, 1983 Docket Nos. 50-352 Page 12 50-353 TABLE II ANALOG PARAMETERS MONITORED BY ERFDS APRM's*
SRM's*
Reactor Upset Range Pressure
- Reactor Narrow Range Pressure Reactor Wide Range Pressure Reactor Wide Range Level
- Reactor Fuel Zone Range Level
- I Reactor Upset Range Level Reactor Shutdown Range Level Reactor Reference Leg Temperature
- Feedwater Flow MSIV-Leakage Control System Pressure
- Containment Wide Range Pressure
- Containment Narrow Range Pressure
- Containment 02 Concentration
- Drywell Temperature
- Suppression Pool Temp
- Suppression Pool Level
- Suppression Pool Air Temp
- Suppression Pool Pressure
- Identified Leak Rate Unidentified Leak Rate Core Flow Recirc Loop Temp
- HPCI Flot RCIC Flow RHR Service Water Flow
- RHR Hx Outlet Temp
- RHR Hx Inlet Temp
- RHR Flow
- Core Spray Flow
- Standby Liquid Control Tank Level SLC Loop Flow
- Emergency Service Water Flow
- Mr. D. G. Eisenhut November 10, 1983 Docket Nos. 50-352 Page 13 50-353 Emergency Service Water Temperature
- Standby Gas Treatment System Flow Reactor Bldg.
P*
Refueling Floor P*
Hydrogen Recombiner Flow
- l 4KV Bus Volts
- 4KV Diesel Generator Frequency
- DC Bus Volts
- DC Bus Amps
- Condensate Storage Tank Level
- Radwaste Inventory Tank Levels
- Redundant Channels or Multiple Loops are Monitored In addition to the above listed parameters, approximately 69 additional parameters are monitored by this system during the startup transient testing program.
These inputs may or may not be permanently wired into the system.
Mr. D.~G. Eisenhut November 10, 1983 Docket Nos. 50-357 Page 14 50-353 2.1 EQUIPMENT CLASSIFICATION AND VENDOR INTERFACE (REACTOR TRIP SYSTEM COMPONENTS)
Position Licensees and applicants shall confirm that all components Whose-functioning is required to trip the reactor are identified as safety-related on documents, procedures, and information handling systems.used in the plant to control safety-related activities, including maintenance, work orders, and parts replacement.. In addition, for these components, licensees and applicanta shall establish, implement and maintain a continuing program to ensure that vendor information is complete, current and controlled throughout the life of the plant, and appropriately referenced or incorporated in plant instructions and procedures.
Vendors of these components'should be contacted and an interface established.
Where vendors cannot be identified, have gone out of business, or will not supply the information,-the licensee or applicant shall assure that-sufficient attention is paid to equipment maintenance, replacement, and repair, to compensate for the lack of vendor backup, to assure reactor trip system reliability.
The vendor interface' program shall include periodic communication with' vendors to assure that all applicable information has been received.
The program-should use a' system of positive feedback with' vendors for mailings containing technical-information.
This could be accomplished by licensee acknowledgement for receipt of technical mailings.
The program shall also define the interface and division of responsibilities among the licensees and the nuclear and non-nuclear divisions of their vendors that provide service on reactor trip system components to assure that requisite control of and applicable instructions for maintenance work are provided, l
Mr._D. G. Eisenhut November 10, 1983 Docket Nos. 50-352 Page 15 50-353
RESPONSE
.19ue Limerick Project Q-List specifies Which systems are safety related in order to control plant activities on
.these systems.
The 0-list is the single controlling document Which identifies systems as safety related and controls activities on the safety related components within safety related systems.
The Limerick. Project Q-List has been developed by the Architect / Engineer.
This 0-list has been reviewed and approved by the Philadelphia Electric Company Engineering and Research Department.
A review of the
' Limerick Project Q-List indicates that all systems which contribute to the reactor trip function are on the Q-list.
Regarding Vendor Interface, for NSSS related information I
Philadelphia Electric Company has' participated in the General Electric Service Information Letter (SIL) system since its inception.
Philadelphia Electric Company believes that this system provides the necessary instructions to incorporate recommendations into l
applicable procedures to constitute the vendor interface program.
To enhance our review of these types of documents, they will be reviewed by the Independent l
l Safety Engineering Group (ISEG) Which will be formed by March of 1984.
The ISEG, When formed, will review and L
disposition SIL ' recommendations to ensure that such recommendations are evaluated for~their applicability to Limerick.
It is expected that this program will be in effect by June 1, 1984.
By letter dated September 6, 1983 from J.W. Gallagher, L
Philadelphia Electric Company to D.G. Eisenhut, USNRC, we advised the NRC that we are participating in-the BWR Owners' Group generic evaluation regarding equipment classification and vendor interface for reactor trip system components.
The Owners' Group effort and subsequent response to the Commission will be completed by February 29, 1984.
Following evaluation of the Generic Owners Group effort, Philadelphia Electric company.will provide to the Commission by April.15, 1984, any modifications to be made to the current program as described above.
Mr.
D. G. Eisenhut November 10, 1983 Docket Nos. 50-352 Page 16 50-353 2.2 EOUIPMENT CLASSIFICATION AND VENDOR INTERFACE (PROGRAMS FOR ALL SAFETY-RELATED COMPONENTS)
Position Licensees and applicants shall submit, for staff review, a' description of their programs for safety-related equipment classification and vendor interface as i
described below:
1.
For equipment classification, licensees and applicants shall describe their program for
. ensuring that all components of safety-related systems necessary for accomplishing required safety functions are identified as safety-related on documents, procedures, and information handling systems used in the plant to control safety-related activities, including maintenance, work orders and replacement parts.
This description shall include:
(1)
The criteria.for identifying components as safety-related within systems currently classified as safety-related.
This shall not be interpreted to require changes in safety classification at the systems level.
(2)
A description of the information handling system used to identify safety-related components (e.g.,
computerized equipment list) and the methods used for its development and validation.
~
(3)
A description of the process by which station personnel use this information handling system to determine that an activity is safety-related and what procedures for maintenance, surveillance, parts replacement and other activities defined in the introduction to 10 CFR 50, Appendix B, apply to safety-related components.
r-Mr. D. G. Eisenhut.
November 10, 1983 Docket Nos. 50-352 Page 17 50-353 (4)
A description of the management controls utilized to verify that-the procedures for preparation, validation and routine utilization of the information handling system have been followed.
(5)
A demonstration that appropriate design verification and qualification testing is specified for procurement of safety-related components.
The specifications shall include qualification testing for expected safety servi,ce conditions and provide support for the licensees' receipt of testing documentation to support the limits of life recommended bv the supplier.
1 RESPONSE 2.2.1 2.2.1.1 CRITERIA POR SAFETY RELATED EQUIPMENT Within a system currently defined as safety related, the components of that system shall be considered safety related if they are required to assure the following:
(1)
Integrity _of the reactor coolant pressure boundary (2)
Capability to achieve and maintain a safe shutdown (3). Capability to prevent or mitigate the consequence of an accident which could result in potential off-site exposures comparable to the guidelines of 10 CFR Part 100.
These criteria' are in accordance with the requirements of'10 CPR Part 50, Appendix B.
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Mr. D. G. Eisenhut November 10, 1983 Docket Nos. 50-352 Page 18 50-353 l
2.2.1.2 INFORMATION HANDLING SYSTEM For the Limerick Generating Station, safety relatNd components are identified via the Limerick Project O-List.
The O-List is the single controlling document Which completely' identifies those structures, systems and components Which are safety related.
As' stated in j
the previous paragraph (2.2.1.1), the criteria for identifying these components as safetyfrelated are in accordance with the requirements of 10 CFR Part 50, Appendix B.
Contained within the 0-list are Ouality Assurance Diagrams (OAD's).
These OAD's, which are P.iping and Instrument Diagrams, identify which components within a safety related system are safety related by using bold face lines to indicate safety related equipment.
If certain items _cannot be clearly depicted on a OAD, they are located in a detailed listing under " Additions To" or " Exceptions From" the 0-list.
g The Limerick Project 0-List has been generaIted by the Architect / Engineer from a detailed review of all design drawings from the following three basic disciplines:
1.
Civil / Architectural 2.
Electrical 3.
Mechanical, Plant Design and Control Systems s
Within each discipline pertinent design drkwings are reviewed and structures, systems and/or components are classified as either safety related or not safety related.
'The 0-list is now under the control of the t
Architect / Engineer Who is responsible for reviewing proposed changes and distributing the revised 0-list.
Control of the O-list will be turned over to the Philadelphia Electric Company When construction on each unit is completed.
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Mr. D. G. Eisenhut November 10, 1983 Docket Nos. 50-352 Page 19 50-353 r
~~
3.~k s- *. i It is anticipated that when' the 0-list is turned over to Philadelphia Electris Company, it will be under the e
control of the Engineering and Research Department whc Gn' will control the Q-list in a manner similar to Philadelphia Electric Company's handling of th'e Peach Eottom Units 2 and 3 (Docket Nos. 50-277, 50-f78 O-u List).
ControllDf the Peach Bottom 0-List is as specified in Enginesring\\ and Res'earch Procedure (ERDP 3.2).
s 1
+
The procedure governinq the Limerick 0-list will be s
modeled after those procedures applicable to
! Philadelphia" Electric Company's Peach Bottom Units 2 and 3 and is described as follows:
u.
' ~
The Mechanical Project Engineer (MPE) is responsible 'for receiving a'nd distributing amendment requests and '.'
distributing the revised 0-list.
The MPE also mainthins
, (-
the. project 0-list Amendment Request Tag and the
\\
1 I
Regiyter for 0-list holders.
i i-s Processino 0-List Amendment Reauests h
q:
Currently,'O-list amendment reauests are handled by the Architect / Engineer.
O-list amendment requests can be C
initiated from within any discipline.
The initiator completes a 0-List Change Request Form (OLCR), upon Which is clearly indicated the chan'ge and if the change 's
- s should be a special addition to the 0-list or,. included in the next' revision.
The initiatoi thentraksmitsthe7+
t OLCR to the discipline Quality. Engineering Coordinator,,
for review and signature.
The OLCR is then transmitted N q,V
^
to both the appropriate dincipline Group Supervisor and Project Nuclear Engineer for review and signature.
The
,' j l
l OLCR is then routed back to Quality Engineering for s
final disposition.
As indicated by3the initiator, Ouality Engineering will eithyr issue a special' addition
.to the 0-list or include the revision in the next j
revision of the 0-list.
s It is anticipated that When control of the O-list is turned over to Philadelphia Electric Company 0-list processing will be handled in the following manner.
This is similar to the current method of handling the O-
4 Mr.
D. G.
Eisenhut November 10, 1983 Docket Nos. 50-352 Page 20 50-353 list for Philadelphia Electric Company's Peach Bottom Units 2 and 3.
The initiator of a 0-List Amendment Request completes the Project Q-List Amendment Request l
form.
The initiator's supervisor reviews the Amendment Request, and, if acceptable, signs and dates the request and sends the request form to the Mechanical Project l
Engineer.
The Mechanical Project Engineer assigns a number to the Amendment Request and enters it in a log which shows the number, the responsible group, and the disposition of the Request.
The Mechanical Project Engineer distributes copies of the Amendment Request via Document Control Forms (DCF's), which requires review by l
Quality Assurance and by chose engineering groups having responsibility for equipment involved with or interfacing with the Amendment Request.
The DCF indicates the engineering group to receive the original of the amendment request and having overall responsibility for processing the amendment request.
l Quality Assurance Section and each interfacing group receiving a copy of the amendment request for review reviews the request and documents the results of the review thereon.
Quality Assurance Section and reviewing engineering groups sign, date and return their DCF's, the completed review checklists, and any comments to the responsible group indicated on the DCF.
The Responsible Engineer, upon receiving the signed-of f DCF's and appropriate review checklists, determines the overall acceptability of the Amendment Request and as necessary, holds meetings or discussions with the reviewers to resolve conflicting comments.
Such meetings or discussions are documented by the Responsible Engineer and the results reflected on the review checklists of the appropriate organization (s).
For items being deleted from the O-list, a Safety Evaluation (SE) must be prepared in accordance with Engineering and Research Departmental Procedure (ERDP).
A copy of the SE is attached to the approved amendment request to document that the change will not involve an unreviewed safety question.
If the deletion resulted from a modification, the Safety Evaluation performed for the modification is sufficient if the deletion of the particular item from the O-list is clearly addressed and determined to be non-safety related.
The safety evaluation must be completed and signed by all required
-4 Mr. D.'G.'Eisenhut November 10, 1983
. Docket Nos. 50-352 Page 21 50-353 l
parties before the Amendment Request is sent to the Section/ Branch Head / Group Leader.
If the amendment request is to be approved, the following action is taken:
(1) The Responsible Engineer initials and dates.the original copy of the Q-list Amendment Request and sends it to his Section/ Branch Head or Group Leader.
(2) The Section/ Branch Head or I
Group Leader, after receiving the initiated Amendment Request from the responsible engineer reviews the I
request-for completeness and accuracy and, if I
acceptable, shall sign and date the request.
(3) The l
Responsible Engineer shall (a) initiate changes, in accordance with appropriate ERDP's to each of the documents listed in the Amendment Request, except for Quality Assurance Diagrams and other drawings referenced
-in the Q-list which are revised in accordance with other I
E RDP ' s.
(b) Provide the approved Q-list Amendment Request and the completed review checklists and DCF's to the Mechanical Project Engineer.
(c) Initiate changes to appropriate QAD's and other drawings referenced in the O-list in accordance with other ERDP's.
The Mechanical Project Engineer or staff shall: (a)
Record approval of the Q-list Amendment Request number in.the log.
(b) Send the completed review checklists, DCF's and a copy of the signed Amendment Request to the Document-Administration Center (DAC).
(c) Distribute the O-list Amendment Request within 14 days after receiving it to all registered holders of the Q-list via the transmittal / receipt form and record the return of receipts in a log which lists each holder of a L
controlled copy of the Q-list, each Q-list Amendment, and 0-list Revision issued.
Receipts may be discarded after their return has been recorded in the log.
(d)
Enter the Q-list Amendment Request Number (OLAt) in the
~
Mechanical-Engineering Division Outstanding Items List to track its status.
All registered Q-list holders incorporate Q-list Amendment Requests into the front of their copy of the Q-list and return their receipts to the Mechanical Project Engineer.
The MPE initiates periodic follow-ups to ensure that the holders of the Q-lists return the receipt forms.
e s
Mr. D. G. Eisenhut November 10, 1983 Docket Nos. 50-352 Page 22 50-353 i
Processing Revisions to the Project O-List As a minimum, the Mechanical Project Engineer revises and reissues the complete O-list when one of the following occurs:
(1) Within thrse months after the fifth 0-list amendment has been issued against a given revision of the 0-list.
(2) Within three months after any 0-list amendment, which is issued against the current revision of the 0-list attains an age of two years.
(3) Revised portions of the O-list are annotated in the margin adjacent to the change (s) with a vertical bar, the O-list revision number in a triangle, and the number of the 0-list amendment request which authorized the change directly below the triangle.
No change to the O-list.is permitted unless the change has been authorized by an approved 0-list Amendment Recuest.
Thersfore, the only review reauired for a revision to the O-list is to ensure that the authorized 0-list Amendment Requests are properly incorporated.
Revisions to the O-list are prepared by the Mechanical Project Engineer or staff, signed by the Mechanical Project Engineer af ter ensuring that the only changes are those authorized by approved 0-list Amendment Request and then issued via the Transmittal Receipt Form.
Revisions to the Project 0-list become ef feccive on the date that the Mechanical Project Engineer signs the revision.
The Mechanical Project Engineer records the transmittal of the revision and return of receipts in the log.
Holders of the Project 0-list maintain their copies of the O-list current and return transmittal receipts to the Mechanical Project Engineer.
The MPE initiates periodic follow-ups to ensure that the holders of the O-list return the receipt forms, f
2.2.1.3 USE OF INFORMATION HANDLING SYSTEM Safety related activities are required by administrative maintenance procedures to be conducted under the Maintenance Request Form (MRF) System.
Philadelphia Electric Company is currently establishing an interactive computer file on plant maintenance activities.
This file is called the Computerized
4 Mr. D. G. Eisenhut November'10, 1983 Docket Nos. 50-352 Page 23 50-353
[
History and Maintenance Planning System (CHAMPS).
The CHAMPS system will automate the MRF system for planned and preventive maintenance activities in the plant.
Preparation of the MRF requires (in Section 2 of'the-MRF) plant staff investigation and approval.
Section 2 of the MRF reouires among other things, that the Q-list status of the equipment be indicated.
At the present time, this action is carried out by the appropriate Plant Engineering Staff Supervisor by conducting a review of the hard copy of the latest revision of the O-list.which is generated as described in the response to Item 2.2.1.2.
The CHAMPS Program, when fully operational, will provide I
a CRT screen for each section of the MRF to be completed
)
I for maintenance.
It is expected that the system will "be fully operational by January.1985.
Philadelphia l
Electri: Company.is considering the incorporation of the l
Q-list discussed in response to Item 2.1 into the CHAMPS program.
If this is completed, the CHAMPS program will automatically insert the O-list status of the component
~
into Section 2'of the computerized MRF eliminating'any human involvement in review of a hard copy of the O-
' list.
We do not know at this time when this automation will be complete, however, the plant engineering staff
. supervisor's review of the Project G-List is adequate to ensure that safety related activities are carried out according to procedural controls for Q-listed eauipment.
- 2. 2.1. 4 MANAGEMENT CONTROLS As stated in the response to Item 2.2.1.2, the 0-list and activities involved in its control, handling and use
'are under control of the Architect / Engineer.
For this activity, Philadelphia' Electric Company relies on the Q-A Program of the Architect / Engineer.
When the Q-list is turned over to Philadelphia Electric Company, the Engineering and Research Department will be responsible for coordinating, maintaining, and
A -
Mr. D. G. Eisenhut November 10, 1983 Docket Nos. 50-352 Page 24 50-353 distributing requests for revisions to the Project Summary 0-List.
Philadelphia Electric Company's Quality Assurance Program will assure through audits and surveillance that procedures for preparation and
-utilization of the O-Listed system have been followed.
The Engineering and Research Department Quality Assurance Section will audit activities regarding the O-List at least every two years to d+termine that the O-List has been maintained and utilized properly.
The Electric Production Department Quality Assurance Division in turn will perform audits on the Engineering and Research Quality Assurance Section at least every two years.to ensure that O-List activities are properly conducted.- Additionally, the Electric Production Department Quality Assurance Division will also routinely audit plant procedures and the Maintenance Request Form System to insure that plant activities regarding safety related equipment are properly implemented.
l 2.2.1.5 PROCUREMENT OF SAFETY RELATED EQUIPMENT Procurement of safety related equipment is currently the responsibility of the Architect / Engineer who is responsible.for all activities regarding safety related activites.
For all systems, the Architect / Engineer System Design Engineer specifies the material and i
equipment to be purchased.
For safety related equipment, the Architect / Engineer Quality Engineering L
Group reviews the design package to verify that the purchased equipment and material is designed to operate and qualified for the expected service conditions.
When the procurement function is turned over to
~ Philadelphia Electric Company, the procurement function-will be under control of the Encineering and Research Department Procedures (ERDP's).
Engineering and Research Department Procedures (ERDP's) assure that agnropriate design verification and qualification Lee'-ing for expected safety service conditions is specified for procurement of safety
~
I Mr. D. G.-Eisenhut November 10, 1983 Docket Nos. 50-352 Page 25 50-353 related components.
The ERDP's contain provisions which assure that qualification documentation is received.
The applicable ERDP's are:
3.4, 4.4, 4.5, 4.6, 6.2, 6.3, and 7.1.
ERDP's 6.2, 6.3 and 7.1 are not yet fully applicable to Limerick but it is anticipated that they will be by_the time Unit 1 becomes operational.
l ERDP 3.4
" Procedure for Design Control".
I This procedure requires that the design input document prepared for each modification addresses the environmental qualifications of equipment and the process and service conditions expected.
The following three procedures require review of the procurement documents to ensure that the purchased equipment is designed to operate in the expected service i
and process conditions and qualified for the expected environment.
Supporting Qualifi. cation documents are required as a condition of payment on all purchase orders.
ERDP 4.4
" Procedure for Procurement of Specially Engineered Equipment Materials, Services or Combination thereof with a Specification".
ERDP 4.5
" Procedure for Procurement of Nuclear Safety Related Items and Services by the Preliminary Requisition Method".
ERDP 4.6
" Procedure for Procurement of Nuclear Safety
-Related Items under the Catalog Method".
g L
I" l
Mr. D. G. Eisenhut November 10, 1983 l
Docket Nos. 50-352 Page 26 50-353 i
I L
L ERDP 6.2
" Procedure for Processing Vendor Documentation".
L The procedure provides for the logging and control of the incoming vendor documents.
The required review ensures the incorporation of the recuired design parameters and assures identification of the equipment with limited life components.
The data concerning limited life components is then entered into a computer program utilized for maintaining equipment.
The required maintenance for these components will then be " flagged" at the appropriate times.
ERDP 6.3
" Procedure for Processing Documents", provides the logging and control of the incoming vendor l
documents which assure the incorporation of the reauired design parameters, and assures company review of the equipment limited life components.
ERDP 7.1
" Procedure for Receipt, Inspection and Storage of Materials and Equipment".
The procedure provides a Oc hold on any eauipment which is missing documentation.
This ensures ~that all procured equipment has had the appropriate review.
Position 2.2.2 2.2.2.
For vendor interface, licensees and applicants shall establish, implement and maintain a continuing program to ensure that vendor information for safety-related components is complete, current and' controlled throughout the life of their plants, and appropriarely n
9
.o.
9-
-Mr.
D. G. Eisenhut November 10, 1983 Docket Nos. 50-352 Page 27 50-353 referenced _or incorporated in plant instructions and procedures.
Vendors of safety-related equipment should be contacted and an interface established.
Where vendors cannot be identified, have gone out of business, or will.not supply information, the licensee or applicant shall assure that sufficient attention is paid to equipment maintenance, replacement, and repair, to compensate for the lack of vendor backup, to assure reliability commensurate with its safety function
( GDC01 ).
The program shall be cloraly coupled with action 2.2.1 above (equipment qualification).
The program shall include periodic communication with vendors to assure that all applicable information has been received.
The program should use a system of positive feedback with vendors for mailings containing technical information.
This could be accomplished by licensee acknowledgment for receipt of technical l
mailings.
It shall also define the interface and I
divii. ion of responsibilities among the licensee and the nuclear and non-nuclear divisions of their vendors that provide service on safety-related equipment to assure that requisite control or and applicable instructions for maintenance work on safety-related equipment are provid ed.
RESFONSE l
L Philadelphia Electric Company has been an active participant in INPO NPRDS and SEE-IN Programs since their inception.
The Significant Operating Experience j
_ Reports and Significant Event Reports issued by INPO are reviewed for anolicability to Limerick by the Engineering and Research Department.
This task will be transferred to the Nuclear Generation Division after Limerick Unit 1 becomes operational.
The NRC has concurred with utilization of these INPO programs as vendor' interface by letter from D. G.
Eisenhut, USNRC to E. P. Griffing, INPO-NUTAC Chairman, dated September 28, 1983, in regards to an INPO sponsored NUTAC effort.
b e -
Mr. D. G.-Eisenhut, November 10, 1983 Docket Nos. 50-352 Page 28 50-353 By letter dated September 6, 1983 from J.W. Gallagher, Philadelphia Electric Company to D.G. Eisenhut, USNRC, we. informed the NRC that we are participating in an INPO sponsored NUTAC for a generic evaluation of the NRC position regarding equipment classification and vendor interface for all other safety-related components.
The NPRD System may be routinely used to provide vendor information on installed safety related equipment.
The NUTAC effort is expected to be completed by February 1,1994 After evaluation'of the results of the NUTAC effort, we expect to submit our response to this position by April 15, 1984 311 POST-MAINTENANCE TESTING (REACTG1 TRIP SYSTEM COMPONENTS)
Position The following actions are applicable to post-maintenance
-testing:
1.
Licensees and applicants shall submit the results of their review of test and maintenance procedures and Technical Specifications to assure that post-maintenance operability testing of safety-related
-components:in.the reactor-trip system is required to be conducted and that the testing demonstrates that the equipment is capable of performing its safety functions before being returned to service.
.2.
-Licensees and applicants shall submit the results of their check of vendor and engineering recommendations to ensure that any appropriate test guidance is included in the test and maintenance procedures or the Technical Specifications, where
' required.
3.
Licensees and applicants shall identify, if applicable, any post-maintenance test requirements in existing Technical Specifications which can be demonstrated to degrade rather than enhance safety.
Appropriate changes to these test requirements,
~.
e*
Mr. D. G. Eisenhut November 10, 1983
- Docket Nos. 50-352 Page 29 50-353
_with supporting justification, shall be submitted for staff approval.
(Note that action 4.5-discusses on-line system functional testing.)
l
RESPONSE
H3.1.1.
Preventive and corrective maintenance. activities at Limerick will be implemented into the " Computerized History and Maintenance Planning System (CHAMPS)".
It is expected that the CHAMPS system will be fully operational-by January 1, 1985.
In order to perform maintenance activities, a
_ Maintenance Request Form (MRF) will be generated on the CHAMPS computer screen.. In accordance with the currently approved administrative. procedures governing maintenance activities, an Operation Verification Form is completed by the Engineer-Operations staff or plant 4
staf f group as assigr ad by the Engineer-Operations to specify sufficient post repair testing, observation requirements or acceptance criteria to: assure that the equipment has been returned to fully operable status.
For Q-Listed eouipment an entry in the Verification Test and Results Summary section must include or reference sinformation which shows that the acceptance criteria for each verification method was met.
An acceptable way to meet this requirement is to record the Surveillance Test (or portion thereof) or other tc7t procedure which was performed'and note that the results were " SAT" for
-satisfactory completion of the test.
Where existing procedures are not used, more information(such as the specific actions taken and the results) must be entered.
Following completion of the work the OPERATION 3 -
VERIFICATION METHOD is reviewed in relation to the information in Section 5 of the MRP to verify that the
- specified method is appropriate for the scope of work actually performed.
Section 5'of the MRF is entered by
- the work group leader or supervisor and is a statement of the defects found.
The entry also includes a
k Mr.'D. G. Eisenhut November 10, 1983 Decket Nos. 50-352 Page 30 50-353 statement of the work actually performed to correct the problem and, where appropriate, indicates that the cause of the failure was corrected.
All testing requirements are added to the OPERATION VERIFICATION METHOD entry because all testing actually performed will be documented in the OPERATION VERIFICATION TEST r RESULTS
SUMMARY
Section of the form.
The proper post maintenance operability testing is thus ensured by
'following the established maintenance procedure.
3.1.2 VENDOR AND ENGINEERING RECOMMENDATIONS In order to assure that the most recent vendor and engineering recommendations are included in the Limerick pre-operational tests, updates to drawings and vendor manuals are the responsibility of the Architect-Engineer's Document Control group located at the site.
-The pre-operational test procedures are prepared by the staff of the' Architect-Engineer and procedures are required to be written to the latest revision of
. documents in their control.
The prepared procedures are reviewed by the plant test engineering staff and
. approved by the Test Review Board (TRB).
Part of the considerations in the review and approval process is whetherfthe latest revisions-to drawings and vendor information has been included in the procedure since changes in these documents could have occurred between the time the procedure was prepared and the time of
~
review.
An additional check is provided by the Startup Engineer who may add excentions to the procedure as approved by the TRB based on the latest Design Change Notices received from the Architect-Engineer Document Control Group.
In this manner, during the *re-operational test phase at Limerick, appropriate and up-to-date test guidance is included in the test procedure.
.With the Document Control. System in place, Philadelphia
. Electric Company will begin operating Limerick with the most recent vendor and engineering recommendations for testing.
'After turnover of the Unit 1 from the Architect-Engineer to Philadelphia Electric Company, participation in those programs specified in response to Items 2.1 and 2.2 will maintain up-to-date vendor and
4 a
-e
'Mr. D. G. Eisenhut November 10, 1983 Docket'Nos. 50-352 Page 31 50-353 engineerino test guidance for test procedures used at Limerick.
3.1.3 The Limerick Technical Specifications are in the process of being writt in at this time and are not complete.
It is expected that the Limerick Technical Specifications will be submitted to the Commission for approval by January'1, 1984. 'If in the pre-submittal review of the Technical Specifications, post maintenance test requirements are identified which can be demonstrated to degrade rather than enhance safety, appropriate changes to these test requirements will be proposed.
3.2 POST-MAINTENANCE TESTING
( ALL OTHER SAFETY-RELATED COMPONENTS)
Position The following actions are applicable to post-maintenance testing:
1.
Licensees and applicants shall submit.i report documenting the extending of test and aaintenance procedures and Technical Specificatiotts review to assure that post-maintenance operability testing of all safety-related equipment is required to be conducted and that the testing demonstrates that the equipment is capable of performing its safety functions before returning to service.
2.
Licensees and applicants shall submit the results of their check of vendor and engineering recommendations to ensitre that any appropriate test guidance is 1 cluded in the test and maintenance procedures or the Technical Specifications where required.
3.
Licensees and applicants shall identify, if applicable, any post-maintenance test requirements in existing Technical Specifications which are perceived to degrade rather than enhance safety.
Appropriate changes to these test recuirements,
.s N
9 v
s o
[
Mr' D. G.
Eisenhut November 10, 1983 Docket Nos. 50-357 Page 32 50-353 l
with supporting justification, shall be submitted for staff approval, f
RESPONSE
3.2.1, 3.2.2, and 3.2.3:
The responses to the position regarding Post Maintenance Testing for all other safety-
}
related components is as stated for those responses j
regarding the reactor protection system.
The existing administrative procedures in effect at Limerick require l
post maintenance cperability testing on any O-listed I
system or component.
4.5 REACTOR TRIP SYSTEM RELIABILITY (SYSTEM FUNCTIONAL TESTING)
Position On-line functional testing of the reactor trip system, including independent testing of the diverse trip features, shall be performed on all plants.
1.
The diverse trip features to be tested include the breaker undervoltage and shunt trip features on Westinghouse, B&W (see Action 4.3 above) and CE plants; the circuitry used for power interruption with the silicon controlled rectifiers on B&W plants (see Action 4.4 above); and the scram pilot valve and backup scram valves (including all initiating circuitry) on GE plants.
2.
Plants not currently designed to permit periodic on-line testing shall justify not making modifications to permit such testing.
Alternatives to on-line testing proposed by licennees will be considered where special circumstances exist and where the objective of high reliability can be met in another way.
3.
Existing intervals for on-line functional testing required by Technical Specifications shall be
Mr.
D. G. Eisenhut November 10, 1093 Docket Nos. 50-352 Page 33 50-353 reviewed to determine that the intervals are consistent with achieving high reactor trip system availability when accounting for considerations such as:
a.
Uncertainties in component failure rates, b.
Uncertainty in common mode failure rates.
c.
Reduced redundancy during testing, d.
Operator errors during testing.
e.
Component " wear-out" caused by the testing.
RESPONSE
The Limerick Technical Specifications which will contain the requirements for functional testing of reactor trip function components are not complete at this time.
The proposed Limerick Technical Specifications will be submitted to the Commission for approval by January 1, 1494 By letter dated September 6, 19R3, from J.
W.
- Galagher, Philadelphia Electric Company to D.
G. Eisenhut, USNRC, we advised the NRC that we are participating in the BWR Owners' Group generic evaluation regarding reactor trip system reliability.
The Owners' Group effort and subsequent response to the Commission will be completed by February 29, 1984 Following submission of the proposed Limerick Technical Specifications to the Commission and evaluation of the Generic Owners' Group effort, Philadelphia Electric Company will provide a response to the position stated in Item 4.5 by April 15, 19A4
o t
's Mr. D. G. Eisenhut November 10, 1983 Docket Nos. 50-352 Page 34 50-353 l
l l
We trust that the information contained in the above l
responses is sufficient for Nuclear Regulatory Commission review l
of Philadelphia Electric Company's current conformance with the
{
positions stated in Generic Letter 83-2R.
In accordance with the l
Reference 42 letter, we have provided, to the best of our knowledge, our current status retarding the NRC positions in Generic Letter 83-28.
Where appropriate, schedules to achieve I
conformance with these positions have been proposed.
We have also provided an explanation for those items for which we cannot provide implementation schedules at this time, and have specified when these NRC positions will be addressed.
f Should you require any further information, please do not hesitate to contact us.
Very truly yours, o
cc: J. Wiggins, Site Inspector bec: J. S.
Kemper S. L. Daltroff J. W. Gallagher E.J. Bradley R. H. Moore R.
S. Fleischmann, II R. H. Logue G. M. Leitch A.
R.
Diederich W. M. Alden/RCB R. A. Mulford E. F.
Sproat DAC i
h
?
l COMMONWEALTH OF PENNSYLVANIA :
i ss.
COUNTY OF PHILADELPHIA
.V.
S. Boyer, being first duly sworn, deposes and says:
That he is Senior Vice President of Philadelphia Electric Company, the Applicant herein; that he has read the foregoing response to Generic Letter 83-28, and knows the contents thereof; and that the staterents and matters set forth therein are true and correct to the best of his knowledge, information and belief.
o
{
)
Subscribed and sworn to before me this /0M day
/kN of Notary Public PATRICIA D. $CHOE Notary Pude. Phi!a:!elphia. Philaddphia Co.
My Commission Expes February 10,1986
_ - _ _ _ _ _ _ _.