ML20096G748
| ML20096G748 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 09/06/1984 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| References | |
| OL, NUDOCS 8409110121 | |
| Download: ML20096G748 (5) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 JOHN 5. KEMPER
....."%"f?fl1..
SEP 061984 Mr. A. Schwencer, Chief Docket Nos.:
50-352 Licensing Branch No. 2 50-353 U. S. Nuclear 3egulatory Ccmnission Washington, D.C. 20555 1
Subject:
Limerick Generating Station, Units 1 and 2 Use'of Lifted Ieads and Jumpers During Maintenance or Surveillance Testing
References:
(1) Ietter, J. S. Kenper to A. Schwencer, dated July 25, 1984.
(2) 'Iblecon, NRC-PECO, dated August 29, 1984.
(3) Telecon, PRD-NRC, dated Septer:ber 4,1984.
File:
GOVT l-1 (NRC)
Dear Mr. Schwencer:
The reference 1 letter expanded and updated the discussion of Limerick's conformance to Regulatory Guide 1.118 to reflect the need to use lifted leads and jurrpers during maintenance and surveillance testing, and to reflect the additional guidance provided by IE Information Notice 84-37.
The reference 2 telecon identified specific difficulties with the revised information and established a schedule for the resolution of these difficulties.
In reference 3 telecon each of these difficulties was discussed and resolval.
The attached draft FSAR pages reflect the agreenents reached on each of these it ms.
These draft FSAR pages will be incorporated into the FSAR via Revision 37 which will be subnitted in October,1984.
Sincerely, 5%
DK/gra/09058407 cc: See Attached Service List O*
%)I 8409110121 840906 S
PDR ADOCK 05000352 A
cc: Judge-Lawrence Brenner (w/o enclosure)-
Judge Peter A. Morris (w/o enclosure)
Judge Richard F.' Cole
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t LGS FSAR QUESTION'421.36 The FSAR=information which discusses conformance to Regulatory Guide :1.118 : and IEEE 338 is insuf ficient.
Further discussion is required.
As a minimum, provide the following information:
a): -Section 17.1.2.5.26-of the FSAR states that the removal of ifuses and other equipment not hard-wired into the protection
. system.will be used only for the purpose of deactivating I&C
. circuits.
Identify where procedures require such operation.
Provide.further discussion to describe how the Limerick procedures for the protection systems c~onform to~ Regulatory Guide '.1.118 - (Rev. 1) Position C.6 guidelines.
Identify and provide justification for any exceptions.
b). Discuss response time testing, including sensors, for the NSSS and BOP supplied instruments and systems in relation to the-guidance provided in R.G.
1.118 and IEEE 338, Section 6.3.4.
Include in your discussion the effects of thermo wells, restrictions, orifices, or other interfaces with.the process variable and the sensor or instrument in relation to the overall response.
c)' Provide examples and descriptions of typical response time l
tests 1for RPS.and ESF systems.
DRAFT RESP"""
. Evaluation of the systems to be surveillance tested has determined that the actions required will include opening of I
circuit' breakers.
This action is required'in a. limited number of r
cases.
The circuit breakers will be opened.during monthly i
testing but will also bring up an out-of-service alarm.that will
~
l not clear with the breaker open.
i A'
^ f jV S E 2.T
- Sensor response time testing for pressure and differential pressure (level) sensors for the reactor protection system will be performed using a precise hydraulic pressure signal as the input.
Response of the sensor output and the final actuation device will be measured.
Neutron detectors are exempt from (response time testing; response time will be measured from the.
input of'the first electronic component in the channel.
Except
~
'for1the MSIVs, individual sensor response times and logic system h
response: times are!not required for isolation systems because the
- signal.ldelayJ(censor response) is concurrent with the 13-second F
- diesel startup.
(Refer to GE Standard Technical Specification l
3/4.3.2' Isolation Actuation Instrumentation) 421.36-1 Rev. 23, 08/83
~.
~
- ~
4 Shtst 2 of 3 Insert, Page 421.36-1 Lifting of leads will be required in order to perform a limited number of the surveillance tests.
Each of these tests, however, will follow the guidance provided by IE Information Notice No. 84-37, dated May 10, 1984.
No scheduled surveillance tests which require lifting of leads, except for those tests which involve thermocoupled',I will be performed while the unit is at power.
Specifically, the procedures-for these tests will include detailed instructions explicitly requiring the reconnecting of the lifted leads. following the completion of the surveillance.
This procedural step will be documented by a sign-off sheet to be initialled by the tester when the lifted leads have been connected.
Following this, a seperate verification sheet will be initialled to confirm that an independent inspection has been made and that the lifted leads have been returned to service. Finally, functional tests designed to verify the restoration of proper system configuration will be performed.
The lifting of leads will be limited to serveillance tests that
- fall into one of the.four categories below:
1.
Tests that involve thermocouples, 2.
Tests that require the introduction of test equipment into the instrument channel being tested, 3.
Tests, on extensive systems that would otherwise become unnecessarily large and complex, and 4.-
Tests on systems or components for which the plant design permits no other reasonable alternative.
DRAET
- Footnote to 421.36 (1) Experience has shown that there are no technically acceptable alternatives to lifting thermocouple leads. The introduction of test switches would add resistivity problems which degrade the thermocouple channel.
(!
(
' Examples of typical time tests for RPS and ESF systems cannot be provided because no' response time procedures are written at this time.
INSTRUMENTATION BASES 3/4.3.2 ISOLATION ACTUATION INSTRUMENTATION This specification ensures the effectiveness of the instrumentation used to mitigate the consequences of accidents by prescribing the operability trip setpoints and response times for isolation of the reactor systems.
When necessary, one channel may be inoperable for brief intervals to conduct required surveillance.
Sone of the trip settings may have tolerances explicitly stated where both the high and low values are critical and may have a. substantial effect on safety.
The setpoints of other instrumentation, where only the high or low end of the setting has a direct beari'g on safety, are established at a
-level away from the norma) operating range to prevent inadvertent actuation of the system involved.
Except for the MSIVs, the safety analysis does not address individual sensor response times or the response times of the logic systems to which the sensors are connected.
For de operated valves, a 3-second delay is assumed before the valve starts to For ac operated valves, it is assumed that the ac power move.
supply is lost and is~ restored by startup of the emergency diesel generators.
In this event, a time of 13 seconds is assumed before
~
the valve starts to move.
In addition to the pipe break, the failure of the de operated valve is assumed; thus the signal delay (sensor response) is concurrent'with the 13-second diesel startup.
The safety analysis considers an allowable inventory loss in each case, which in turn determines the valve speed in conjunction with the'13-second delay.
It follows that checking the valve speeds and the 13-second time for emergency power establishment.will establish the response time for the isolation functions.
However, to enhance overall system reliability and to monitor instrument channel response time' trends, the isolation actuation instrumentation response time shall be measured and recorded as a part of the isolation system response time.
3/4.3.3 EMERGENCY CORE COOLING SYSTEM ACTUATION INSTRUMENTATION The emergency core cooling system actuation instrumentation is provided to initiate actions to mitigate the consequences of accidents that are beyond the ability of the operator to control.
This specification provides'the operability requirements, trip setpoints, and response times that will ensure effectiveness of the systems to provide the design protection.
Although the instruments are listed by system, in some cases the same instrument may be used to send the actuation signal to more than one system at the same time.
Rev. 23, 08/83 421.36-2
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