ML20096F673
| ML20096F673 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 08/31/1984 |
| From: | Boyer V PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20096F678 | List: |
| References | |
| GL-82-28, OL, NUDOCS 8409100176 | |
| Download: ML20096F673 (10) | |
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t PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 (215)841-4500 s.so m CR. VICE PRESIDENT NUCLE AR N3WER.
August 31, 1984 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 8, 1983 2.
Letter, J. F. Stolz, USNRC to E. G.
Bauer, Jr., PECo, " Clarification of Required. Actions Based on Generic Implications of Salem ATWS Events",
October 21, 1983 3.
Letter, V. S. Boyer, PECo, to D. G.
Eisenhut, USNRC, " Response to Generic Letter 83-28," November 10, 1983
Dear Mr. Eisenhut:
Generic Letter 83-28, " Required Actions Based on Generic Implications.of Salem ATWS Events," issued July 8, 1983 requires licensees to address issues related to reactor trip system-reliability and general management capability in the areas of Post-Trip Review, Equipment Classification and Vendor Interface, Post Maintenance Testing and Reactor Trip System Reliability Improvements.
This letter is a follow-up to the Reference 3 letter describing the post-trip review program description and procedures for Limerick Generating Station Units 1 and 2.
The NRC position regarding Post-Trip Review specified as Item 1.1 in Generic Letter 83-28 is restated below along with our response.
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iMr'.JDdrrell.G.E[eenhut August 31, 1984 Page.2 2.
'l.1.
-POST-TRIP REVI'EW ' (PROGRAM DESCRIPTION AND PROCEDURE)
Position Licensees and: applicants shall describe their program for ensuring that unscheduled reactor shutdowns are analyzed andLthat a determination is.madeLthat 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.
2.
The. responsibilities and authorities of. personnel who will perform the review and analysis of these events.
3.
The necessary qualifications and training for the
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responsible-personnel.
4.
The^ sources of plant information necessary to conduct.the review and analysis.
The sources of
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.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. )
5.
The methods and criteria for comparing the event information with known or expected plant behavior
(
.g., that. safety-related equipment operates as e
required by the Technical Specifications or other performance specifications related to.the safety I
function).
I 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 competent 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.
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- JMr.JDarrell G.iEisenhut-August 31, 1984 Page 3
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RESPONSE' l.'l.1
' ACCEPTABILITY OF RESTART-Limerick Procedure:GP-18, Scram Review Procedure, and GP-18 C.O.L. -(Check-Of f List for th'e Scram Review Procedure)1were approved by the Plant Operations and
' Review Committee ' (PORC) on August 29, 1984.
These' procedures are_ attached as Exhibits.1 and 2, respectively.
_ hen. completed,- GP-18 C.O.L.
forms the W
-basis to determine the acceptability of plant restart.
This check-off list _ requires documentation of the. event and key safety parameters, use of the Post Trip Data Log, Sequence of Events - Log and the Emergency Response Facility Data System (ERFDS), and a listing. of any_
discrepancies' in Reactor System operations following.the trip.
The completed check-off list and the resultant Upset Report. which is, generated are then reviewed in the
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process _ described in Response to Item 1.1.2.
Approval to restart the reactor.:Ls granted in Attachment I of
' ~
. Appendix I,to Procedure GP-2, Reactor Start-up and Heat--
Up '(Exhibit. 3) by_the Stat ~ ion Superintendent.or-alternate.
Procedure GP-2, Normal Plant ~Startup-.
oi (Exhibit 4),. requires. resolution of the Check-Of f; List for the Scram Review Procedure C.O.L. GP-18.
.Thus,
' approval for. restart cannot be granted unless there are
-no unexplained'or unresolved conditions noted in C.O.L.
'GP-18 as a result of theLtrip..
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~l ~.1. 2. -
RESPONSIBILITIES AND AUTHORITIES The responsibilities for -review and analysis following a plant trip are delineated in Procedure GP-18, Scram Review Procedure - (Exhibit 1)..Following a plant
. tripping, C.O.L. GP-18 is completed by Shift Supervision or a-Shift Technical Advisor (STA) as directed by_ Shift L
Supervision.- Using.the completed C.O.L.'and by
-conducting interviews with shift personnel involved, the STA prepares a preliminary Upset Re? ort which'is a narrative of the event and discusses the report with plant management: face-to-face or by telephone prior to 1eaving.the site at-the end-of'his shift.
The specific duties of the STA following a transient are delineated g
6 in attached Procedure A-7,..Section 5, Shift Technical j
-Advisor Duties and Responsibilities (Exhibit 5).
.The Engineer-Operations or his designated alternate reviews the completed ~C.O.L. GP-18' prior to restart to ensure there are no unresolved or unexplained conditions as a result of the event.
The Engineer-Operations
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- Mr. : Darrell G. Eisenhut.
August 31, 1984
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'det' ermines, by virtue of.this review, if further review n;
sof the event is1 required by_ the Plant Operations Review.
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t, Committee. (PORC) in accordance with the Scram Review
' Procedure.
If the_ Engineer-T.ations determines that i
no further. review:is requirca, his signature on C.O.L.
-GP-18~ completes 1this' check-off list for the purpose of-
- ' completing:the; Normal Plant Startup Procedure (GP-2).
TAs described:in response-to Item l'.l.6 below, PORC and'
'the Nuclearf Revi'ew-Board may provide independent review
,,6 Las required.
q 1.1.3.
-QUALIFICATIONS AND' TRAINING x#
Sadh of the Shift Technical Advisors'at Limerick have a Bachelor's' degree in a scientific or engineering m c_
discipline with specific-training in plant design, and response to,'and analysis of the plant for transients
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fand accidents.- Candidates for the STA position must
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_ undergo an intensive six-month training program
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. administered in the following. areas:
- Health Physics and Radiation Protection
- Chemistry Fundamentals and BWR Chemistry
- Materials-Science and Reactor Materials
- Atomic' Physics and Reactor Theory
- Fluid Flow Thermodynamics
- Heat Transfer and BWR Heat Transfer
- Management Skills
- Simulator 1 Training Following the training program, each STA candidate is t
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tested and evaluated-for this position.
The STA's must
'successfully complete this training before being 6
assigned to a shift position.-
uff The~ Plant Operations Review Committee is composed of the
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following permanent' members:
or
,i' VN A.
Station Superintendent - Chairman B.
Station Assistant Superintendent j
C.
, Technical Engineer D.
~ Maintenance. Engineer yV N k E.
Operations Engineer p
F.
Reactor Engineer J.-
G.
Instrument &' Control Engineer
'J V
H.
Senior Health Physicist 7
y 3
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Mr.fDarrell~.G. Eisenhut August 31, 1984
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Page 5 Each' member of-the PORC Committee meets or exceeds the minimum qualifications of ANSI /ANS 3.1, 1978.for-
- comparable positions except-the Senior. Health Physicist who meets or exceed the qualifications of Regulatory Guide?8.8, September 1977.
Individuals presently filling.the_above1 positions'B through E are Senior Licensed' operators with up-to-date requalification.
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~ Members of the. Nuclear. Review Board (NRB), including the Chairman and alternate' members are appointed by.the LVice-President, Electric Production.- These members have an" academic degree in an engineering or physical science field.
Additionally, each member has a minimum of.five years. technical experience, of.which a minimum of three years is in one or more of the following areas:
4 A.-
Nuclear Power Plant Operations B.
Nuclear Engineering C.
fChemistry and Radiochemistry' i '
D.-
Metallurgy E.
Instrumentation and Control
+
F.-
Radiological Safety G.
Mechanical or Electrical Engineering H.
Quality Assurance Practices
'l.1.4.-
. SOURCES OF INFORMATION The plant process computer and ERFDS provide monitoring of both digital and analogLparameters +Lich represent l.
those most critical 11n assessing the operation of-the plant in all operating modes.. In addition'to these, the-
. control room annuciator system provides a "First Out" capability-for: selected alarm points.
This allows identification of the first in a group of alarms
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received.
' CAPABILITY FOR ASSESSING SEQUENCE OF. EVENTS (ON-OFF INDICATIONS)
This capability is provided by the plant process 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.
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w-EMr. Darroll G. Eisenhut.
August 31, 1984
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Page 6
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-The_ computer system provides sequence of events
. monitoring of apptoximately 220 digital points.
The ' sequence of events program. is initiated by the,
-occurrence ofEan. interrupt caused by the chango.of state
- of any~one ofLthe contact points associated with event-recording.
l Any " Sequence of Events" contact'may also be defined as a regular alarm point.
That-is, in addition to being
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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 7
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 COMPUTER BASED DATA SYSTEM The EmergencyLResponse Facility Data System -(ERFDS) is.a
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2 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 system' consists of two VAX 11--
780 CPU's, one of which updates the CRT graphics, the
- other stores-and1 analyzes-transient data.
The analog parameters monitored by ERFDS were-selected based'on the following criteria: (1) those needed to comply with Reg.1 Guide,1.97.for post-accident
. monitoring,. (2) those needed_for the startup transient
' test p'rogram, '(3). those needed to support the displays to be used in conjunction with the Emergency: Procedure Guidelines.
Data collected by the Data Acquisition System (DAS) is compared agai a unique significant change value.
Wb n that'value is reached or at least once every hour, the data is sent to disc where it will reside for
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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.
Detailed descriptions of the capability to assess
. transit.;t ' sequence of events and the ERFDS computerized transient monitoring system were provided to the NRC Division of Licensing in the Reference 3 letter.
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-Mr. : Dar'rell G. ' Eisenhut._
August 31, 1984' Page.7' il. l. 5. -
. METHODS AND' CRITERIA FOR COMPARISON tThe Scram. Review Check-Off List, Procedure C.O.L.'GP-18,
'is: divided into sections 1for review and' analysis of_the
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event.. Completion of the check-cff' list' allows
- verification of the proper. operation of the. Reactor
- Protection' System (RPS),-Primary Containment Isolation-
' System - (PCIS), Emergency Core. Cooling Systems (ECCS),-
Land the 4Kv'and 13Kv electrical systems.
C.O.L. GP-18 is formatted in-such a way that system
-response associated with the event is compared with the expected system response-for a specific transient. -This
.jls accomplished by completing Parts II through V which, based on the nature of the scram, indicates whether a
-particular. system response to the condition was required.
If system response was not required, no further analysis of the system in that part is required.
If-the system was required-to operate, the remainder of
'that part of~-the check-off list must be completed'as indicated to determine-if the system has operated as designed for the transient condition.
- 1.l.6.
CRITERIA FOR NEED FOR INDEPENDENT ASSESSMENT PORC review of an event is mandated if any of the following conditions occurred during the event.
A.
Undetermined cause.of the SCRAM B.
Unexplained or unidentified action or events C.
Failure of ECCS to operate properly l'
i D.
Failure of all control rods to fully. insert E.
Failure of RPS,-PCIS or other systems subject
.to Limited Safety System Setting to operate as required
~ Any other.significant event deemed necessary
-F.-
1 for PORC review by the Engineer-Operations PORC review is conducted to determine the necessary y
remedial actions which must be taken prior to unit U
restart.
The PORC also determines if the-condition was
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such that a review of the event is required by the Nuclear Review Board (NRB).
Review of the event by the l
NRB is mandated if any condition concerning the' event
- was different from those evaluated in the Safety Analysis Report'or if NRB review is requested by the PORC.
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-Mr.fDarrell G. Eisenhut~
August 31, 1984 Page 8 We trust theLinformation contained in the above response is sufficent for Nuclear Regulatory Commission review of
. Philadelphia' Electric Company's post trip review program and procedures for Limerick Units 1 and 2.
Should you required any further information, please do not hesitate-to contact us.
Very truly yours,
Enclosures:
Exhibits 1 through 5 cc: _
Dr. T. E. Murley, Administrator See Attached Service List i
Docket-1:os. 50-277 50-278 COMMONWEALTH OF PENNSYLVANIA :
ss.
' COUNTY OF PHILADELPHIA V.'S._Boyer, being first duly sworn, deposes and.says:
That he is Senior Vice President of Philadelphia Electric Company; that he has. read the foregoing partial response to' Generic Letter 83-28 relative to Limerick Units 1 and 2 and
-knows the contents thereof; and that-the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.
M.L v
Subscribed and sworn to beforemethis3/kay-of
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,; Notary Public y
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'PATftl CIA D SCHOLI:
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Notary Pubi'c, Philadelphia, Phi!adciphia Co.
O My CommisAiort Expires February 10,1986 l'
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y Lcc: Judge Lawrence Brenner
-(w/o enclosure)
.dudge Peter A. Morris (w/o enclosure)
Judge Richard F. Cole.
(w/o enclosure)
Troy B. Conner, Jr.,- Esq.
(w/o enclosure)
Ann P. Hodgdon,.Esq.
(w/o enclosure)
Mr. Frank R. Romano (w/o enclosure)
Mr. Robert L. Anthony (w/o enclosure)
Maureen Mulligan (w/o enclosure)
-Charles W. Elliot, Esq.
(w/o enclosure)
Zori G.'Ferkin, Esq.
(w/o enclosure)
'Mr. Thomas Gerusky (w/o enclosure)
. Director, Penna. Emergency (w/o enclosure)
Management Agency Angus R.. Love, Esq.
(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)
Jay M. Gutierrez, Esq.-
(w/o enclosure)
' Atomic Safety S Licensing (w/o enclosure)
Appeal Board Atcynic Safety S Licensing (w/o enclosure)
Board Panel
,1 Docket & Service Section (w/o enclosure)
Mr. James Wiggins (w/o enclosure)
Mr. Timothy R. S. Campbell (w/o enclosure)
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