ML20112C343
| ML20112C343 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/18/1985 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| References | |
| CON-#285-204, RTR-NUREG-0737, RTR-NUREG-737, RTR-REGGD-01.097, RTR-REGGD-1.097 GL-82-33, OL, NUDOCS 8503210397 | |
| Download: ML20112C343 (27) | |
Text
._
a PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 (2151841 45o2 JOHN S. MEMPE R vset.entssoteer March 18, 1985 l
Mr. A. Schwencer, Chief Docket No.:
50-352 l
Licensing Branch No. 2 l
U. S. Nuclear Regulatory Commission Washington, DC 20555
SUBJECT:
Limerick Generating Station, Unit 1 Safety Paramet er Display System ERFDS Reg. Guidc 1.97 Displays FILE:
GOVT 1-1 (NRC)
Dear Mr. Schwencer:
License Condition 2.C.8(b) requires that the Limerick Safety Limerick Parameter Display System (SPDS) be operable by April 1,1985.
Unit I will meet this condition consistent with regulatory requirements for SPDS as expressed in Supplement 1 to NUREG-0737 (Generic Letter No.
82-33, December 17, 1982). Enclosure No. I to this letter describes the means employed to satisfy this license condition.
The responses to questions 620.1 through 620.7 and 640.30 through 640.32 contained in the Limetick FSAR provide a detailed description of the General Electric Emergency Response Information System (ERIS) SPDS design. All of the hardware and SPDS signal inputs as described in the FSAR are installed and operable, However, the GE ERIS SPDS displays cannot be released for is not use by the operators because the Validation Testing process Consequently, due to the unavailability of the GE ERIS SPDS complete.
displays, alternative displays have been developed and will be utilized in the Limerick SPDS.
The April 1,
1985 schedule date for SPDS (SER),
operability contained in the Limerick Safety Evaluation Report Supplement 3, Section 18.2.9 and License Condition 2.C.8.b was based on both PEco's and the NRC staff's assessment of General Electric's generic validation Test schedule. As stated in the Limerick SER, GE was to have with a test conducted their generic Validation Tests late in 1984, pEco report on the results issued by CE to the NRC by February 1985.
has been advised by GE that these Validation Tests have been rescheduled for completion in March, 1985 because of additional software debugging The test report on the results is and data base compilation activities.
The results of scheduled to be issued to the NBC by CE in April 1985.
where this generic test program must be reviewed and incorporated, into the GE ERIS SPDS displays used in the Limerick SPDS applicable, prior to releasing these displays for use by the operators.
3 m'8185 m &=
6i e
Mr. A. Schwencar, Chief March 18, 1985 The schedule contained in Section 18.2.9 of Supplement No. 3 to the Limerick Safety Evaluation Report also states that the Emergency Response Facility Data System (ERFDS) Reg. Guide 1.97 displays will be functional by April 1,
1985.
The ERFDS Reg. Guide 1.97 displays required to provide Reg. Guide 1.97 variables to the Control Room Operators will be functional by April 1, 1985.
The ERFDS Reg. Guide 1.97 displays designed to provide data to the Technical Support Center (TSC) and the Emergency Operations Facility (EOF) are currently undergoing testing and will not be functional by April 1, 1985.
A portion of this data will be provided to the TSC and EOF by the SPDS as described in Enclosure No. 1, while alternate means which are currently in place will continue to be utilized to provide the remaining data to these facilities.
Enclosure No. 2 describes the current status of the ERFDS Reg. Guide 1.97 displays.
Sincerely,
- C S. /
L DFC/JJG/la la311851145 Enclosures Copy to:
T. E. Murley, It.E Region I Administrator See Attached Service List
e cc: Judge Helen F. Hoyt (w/ enclosure) dudge derry Harbour (w/ enclosure)
Judge Richard F. Cole (w/ enclosure)
Troy B. Connor, Jr., Esq.
(w/ enclosure)
Ann P. Hodgdon, Esq.
(w/ enclosure)
Mr. Frank R. Romano (w/ enclosure)
Mr. Robert L. Anthony (w/ enclosure)
Ms. Phyllis Zitzer (w/ enclosure)
Charles W. Elliot, Esq.
(w/ enclosure)
Zort G. Ferkin, Esq.
(w/ enclosure)
Mr. Thomas Gerusky (w/ enclosure)
Director, Penna. Emergency (w/ enclosure)
Management Agency Angus R. Love, Esq.
(w/ enclosure)
David Wersan, Esq.
(w/ enclosure)
Robert J. Sugarman, Esq.
(w/ enclosure)
Martha W. Bush, Esq.
(w/ enclosure)
Spence W. Perry, Esq.
(w/onclosure) day M. Gutierrez, Esq.
(w/ enclosure)
Atomic Safety & Licensing (w/er: closure)
Appeal Board Atomic Safety & Licensing (w/ enclosure)
Board Panel Docket & Service Section (w/ enclosure)
Mr. Janes Wiggins (w/ enclosure)
Mr. Timothy R. S. Cmpbell (w/ enclosure)
Enclosure No. 1 PllILADELPHIA ELECTRIC COMPANY LIMERICK GENERATING STATION UNIT 1 DOCKET NO. 50-352 LICENSE NPF-27 SAFETY PARAMETER DISPLAY SYSTDI LICENSE CONDITION 2.C.8.b
1 I.
Compliance with License condition 2.C.8.b The Limerick license condition 2.C.8.b states "the licensee shall have the SPDS operable by April 1, 1985".
As required by the license condition, Limerick Unit 1 will have an SPDS operable and functionally available for use by the operators by April 1, 1985 as discussed in detail below.
The approved Limerick SPDS consists of a set of CRT displays generated on the computer based Emergency Response Facility Data System (ERFDS). The SPDS to be operational by April 1, 1985 will utilize the display formats shown on the attachments which are also generated on ERFDS.
These displays formats will provide an interim SPDS until the validation process is complete on the SPDS display formats described in Supplement 3 to the Limerick Safety Evaluation Report (SER), hereafter reforred to as the GE ERIS SPDS displays.
The interim SPDS will be operational until the GE ERIS SPDS is validated.
This activity is discussed further in Section IV of this report.
The interim SPDS meets the license condition by providing displays which provide a concise display of critical plant parameters and will provide for the safe operation of the plant in accordance with NRC regulatory requirements including NUREG 0737, Supplement 1.
Compliance with the regulatory requirements is discussed in the following sections.
II.
Description of the Interim SPDS The interim SPDS is part of the computer based ERFDS and utilizes the display formats shown on the attachments.
The attachments are black and white copies of the color graphic displays. The interim SPDS utilizes the same ERFDS computer system, data acquisition system, and peripherals hardware as the GE ERIS SPDS displays.
The three major ERFDS subsystems described in Section 18.2.2 of Supplement 3 to the Limerick SER which are the Data Acquisition System (DAS), the Data Processing System (DPS), and the Data Output Peripherals (DOP) are all utilized by the interim SPDS.
The interim SPDS displays and the GE ERIS SPDS displays are both based on the symptom oriented Limerick Transient Response Implementation Plan (TRIP's).
The parameters selected for the interim SPDS are based on the TRIP procedures and are the same as those selected for the GE ERIS SPDS displays.
The parameters selected for the interim SPDS displays are consistent with the " Safety Analysis for Parameter Selection for the Safety Parameter Display System (SPDS)" transmitted by Reference 1.
The Radioactivity Control function of the SPDS is provided by the Radiation Meteorological Monitoring System (RMMS) as described in Supplement 3 to the Limerick SER, Section 18.2.3.
This system is operable and functionally available for use by the operators.
- Containment Radiation is monitored and displayed by RMMS to provide the status of the Radioactivity Control function during periods when the containment is isolated.
This addresses the staff's concern on this matter discussed in Section 18.2.10 of supplement 3 to the Limerick SER.
NUREG 0737, Supplement 1 states that the purpose of the SPDS is to
" provide a concise display of critical plant variables to the control room operators to aid them in rapidly and reliably determining the safety status of the plant."
The safety status of a BWR plant can be assessed from the parameters that are defined as the entry conditions into the TRIP's.
The interim SPDS provides a concise display of these critical plant variables.
The top level interim SPDS display (Attachment #1) contains the entry variables into the TRIP's.
The second level interim SPDS displays (Attachments #2 and #3) provide data to assist the operator in performing the Reactor Pressure Vessel (RPV) Control and Containment control procedures respectively. The interim SPDS displays provide real time plant data to aid in both early emergency procedure entry condition recognition and in the performance of the procedures.
The GE ERIS SPDS displays provide the functions described above and also provide functions which are beyond the basic SPDS requirements as described in NUREG 0737, Supplement 1.
These functions include time trend plots of critical parameters, two-dimensional parameter plots, and critical parameter validation status displays.
The interim SPDS will not provide these functions, however, it still meets the requirements for SPDS as discussed in Section III.
The interim SPDS is intended to be operational during all modes of reactor operation above cold shutdown defined in Table 1.2 of the Limerick Technical Specifications.
Hardwired Class IE instrumentation which presents the same information is available in the Control Room for the operator should the SPDS become inoperable.
During periods when the plant is in cold shutdown, the interim SPDS may not be operable in order to facilitate and expedite validation of the GE ERIS SPDS displays. This is acceptable because of the low probability of an abnormal and/or emergency condition occuring during cold shutdown and because all information presented on the interim SPDS displays is available to the control room operator on hardwired Class lE instrumentation.
Operators are trained in the use of the GE ERIS SPDS displays and no operator will stand a posted licensed position after April 1, 1985 without being trained on the interin SPDS.
III. Interim SPDS Compliance with NUREG 0737, Supplement 1 The interim SPDS complies with the requirements of NUREG 0737, Supplement 1 as follows:
4
- Requirement 4.la "The. SPDS should provide a concise display of critical plant variables to the control room operators to aid them in rapidly and reliably determining 'the safety status of the plant."
compliance:
The safety status of a BWR plant can be assessed from the parameters that are defined as the entry conditions into the TRIP's.
The top level interim SPDS display shown on Attachment 1 presents the entry condition parameters with their current value and alarm status.
. The interim SPDS displays will display the values of redundant signals for each critical parameter.
Where applicable, values from different instrument ranges will also be displayed.
The values displayed will be range checked prior to display.
Values not within the sensor range will be denoted as bad data on the displays.
4 Requirement 4.lb:
" Continuous ' display of SPDS parameters shall be located conveniently to the control room operator."
Compliance:
The interim SPDS utilizes the same color graphic display consoles located in the control room as the GE ERIS SPDS.
The response to question 620.4 contained in the Limerick FSAR provided information on how this requirement is met for' the GE ERIS SPDS.
That response is
~~"~'"
also applicable for the interim SPDS.
The majority of the validation processes to be performed on the GE ERIS'SPDS Displays can be performed with the interim SPDS Displays operational.
During periods when the color graphic display consoles must be utilized for GE ERIS SPDS testing, the interim SPDS displays will be provided on black and white CRT terminals located in the.
Control Room and TSC adjacent to the ERFDS display consoles.
These black and white CRT's are also driten from the ERFDS computer.
Requirement 4.lc "The SPDS shall be suitably isolated from electrical or electronic interference with equipment and sensors that are in use for safety systems."
_ Compliance:
The interim SPDS complies with this requirement. The interim SPDS utilizes the same equipment discussed in the response to question 620.7
- contained in the Limerick FSAR.
l
4_
Requirement 4.ld:
" Prompt implementation of an SPDS can provide an important contribution to plant safety.
The selection of specific information that should be provided for a particulat plant shall be based on engineering judgement of individual plant licensees, taking into account the importance of prompt implementation."
Compliance:
The schedule date for SPDS operability contained in the Limerick SER, Supplement 3, Section 18.2.9 and License Condition 2.C.8.b was based on both PECo's and the NRC staff's assessment of the SPDS contractor's (General Electric) Validation program schedule. As stated in the Limerick SER, Supplement 3, Section 18.2.9, General Electric was to have conducted Validation tests for their generic ERIS SPDS late in 1984, with a test report on the results issued by GE to the NRC by February 1985.
The GE generic ERIS SPDS Validation Testing has been rescheduled for completion in March,1985 because of additional sof tware debugging and data base compilation activities.
GE has advised PECO that the test report on the results is presently scheduled to be issued to the NRC by GE in April 1985.
The delay in the scheduled completion of the generic ERIS Validation Test Program will not enable the software enhancements and/or corrections resulting from this program to be implemented and tested at the Limerick site by April 1, 1985. The results of this test program must be reviewed and incorporated, where applicable, into the Limerick GE ERIS SPDS Displays prior to the release of these displays for use by the operators.
The interim SPDS displays provide for the implementation of the SPDS function in the control room by April 1, 1985.
The interim SPDS will be operational until the GE ERIS SPDS is validated.
This activity is discussed further in Section IV of this report.
Requirement 4.le:
"The SPDS display shall be designed to incorporate accepted human factors priciples so that the displayed information can be readily perceived and comprehended by SPDS users."
Compliance:
The interim SPDS displays are formated to be consistent with the Limerick TRIP procedures.
The parameters selected for each interim SPDS display are consistent with the parameters selected for the corresponding display in the GE ERIS SPDS.
For example, the paraneters selected for the interim SPDS RPV control display are consistent with those contained on the GE ERIS RPV control display.
. l LThe color coding used on the interim SPDS to designate parameter status (les normal, alarm, and bad data) is the same as used for the GE ERIS SPDS displays discussed in the Limerick SER, Supplement 3, Section 18.2.5.
Requirement 4.lf:
"The minimum information to be provided shall be sufficient to provide information to plant operators about 1)
Reactivity Control li)
Reactor core cooling and heat removal from the primary system iii) Reactor coolant system integrity iv). Radioactivity Control v)
Containment conditions The specific parameters to be displayed shall be determined by the licensee."
Compliance:
The top level interim SPDS display shown on Attachment 1 presents the entry condition parameters with their current value and alarm status.- The parameters. presented on the top level interim SPDS display are as follows:
1)
Reactor Power (APRM's) 2)
Scram Status 3)
MSIV Isolation Command Status 4)
Reactor Water Level 5)
Reactor Pressure 6)
Suppression Pool Temperature 7)
Suppression Pool Level 8)
Drywell Pressure 9)
Drywell Temperature t
The interim RPV Control Display (Attachment 2) presents the j-following parameters i
1)
Reactor Power (APRM's) l l
l L
m.
- 2)
Reactor Water Level 3)
Reference Leg Temperatures 4)
Reactor Pressure 5)
Reactor Pressure Vessel Temperatures The interim Containment Control Display (Attachment 3) presents the following parameters:
1)
Suppression Pool Temperature 2)
Suppression Pool Level 3)
Drywell Pressure 4)
Drywell Temperature 5)
Wetwell Pressure The display shown on Attachment 4 provides safety relief valve status information.
The displays shown on Attachments 5 through 11 provide containment Isolation Valve status and Isolation Command status.
The Radioactivity Control function of the SPDS is provided by the Radiation Meteorological Monitoring System (RMMS) as described in the Limerick SER, Supplement 3, Section 18.2.3.
In summary, the parameters displayed on the interim SPDS displays are sufficient to provide information to control room personnel about the plant functions required by NUREG-0737, Supplement 1, Section 4.1.f.
The parameters selected for the interim SPDS displays are consistent with the SPDS Safety Parameters identified in Table 1 of Section 18.2 of Supplement 3 to the Limerick SER.
IV.
Implementation Status of GE ERIS SPDS GE has advised PECO that the generic ERIS Validation Tests to be performed at GE's San Jose, CA, facility are now scheduled to be completed in March 1985 with a test report on the results issued to the NRC by GE in April 1985.
The results of this test program must be reviewed and system modifications made as required prior to release of the GE ERIS SPDS Displays for use by the operators.
The ERFDS hardware installation is complete at the Limerick site.
ERFDS software and GE ERIS SPDS display formats are loaded into the system and have undergone site installation testing. Software problems have been identified and documented and are in the process of being resolved by General Electric.
F
~
-y-Calibration of the input signals into ERFDS required to support the GE ERIS SPDS Displays will be complete by April 1, 1985.
Validation activities are in progress at the Limerick site to validate the numerous Limerick specific constants, composed point logics, (eg event targets) and parameter validation algorithms which are required to support the General Electric ERIS SPDS displays.
A portion of these activities involves exercising and testing the parameter validation algorithms and composed point logics at plant operating conditions above 5% power.
This process also includes reasonableness checks comparing the GE ERIS SPDS display data with hardwired plant instrumentation.
This validation process will be performed during the Power Ascension Test Program.
The GE ERIS SPDS Displays will be released for use by the operators when all Validation testing is complete.
l JJG/la la3885m838 Attachments
References:
- 1) J. S. Kemper to A. Schwencer letter dated September 2, 1983
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4 Enclosure No. 2 PHILADELPHIA ELECTRIC COMPANY LIMERICK GENERATING STATION UNIT 1 DOCKET NO. 50-352 LICENSE NPF-27 ERFDS REG. GUIDE 1.97 DISPLAYS
1 ERFDS Reg. Guide 1.97 Displays I.
Limerick Safety Evaluation Report (SER)
Schedule for ERFDS Reg. Guide 1.97 Displays The schedule in Section 18.2.9 of Supplement 3 to the Limerick SER states that the Emergency Response Facility Data System (ERFDS) Reg.
Guide 1.97 displays are to be functional by April 1, 1985.
II.
Implementation Status of the ERFDS Reg. Guide 1.97 Displays The ERFDS Reg. Guide 1.97 Displays that present those Post Accident Monitoring variables in FSAR Table 7.5-3 which are only available on the ERFDS, will be operable and functionally available for use by the operators by April 1,
1985.
These displays, hereafter referred to as Type 1, will be available in the Control Room, Technical Support Center (TSC) and Emergency Operations Facility (EOF) on color graphic display consoles driven from the ERFDS computer system.
The remaining ERFDS Reg. Guide 1.97 displays are designed to present the Reg. Guide 1.97 variables which are also displayed via hardwired indicators. The primary purpose of these displays, hereafter referred to as Type 2, is to provide Reg. Guide 1.97 data to the TSC and EOF.
These display formats are loaded into the ERFDS computer system and are undergoing testing. The testing of the Type 2 ERFDS Reg.
Guide 1.97 displays has been delayed due to GE's ERFDS software debugging activities and the priority necessarily given to the testing and checkout of the interim SPDS displays. These displays will be released for use in the Control Room, TSC, and EOF when all testing is complete.
This testing will be ccepleted during the Power Ascension Test Program.
During periods when the color graphic display consoles must be utilized for GE ERIS SPDS testing, the Type 1 Reg. Guide 1.97 displays will be provided on black and white CRT terminals located in the Control Room and TSC.
These black and white CRT's are also driven from the ERFDS computer.
III. Compliance with NUREG-0737, Supplement 1 Requirement 6.1.b
" Provide measurements and indication of Type A,
B, C,
D, E
variables listed in Regulatory Guide 1.97 (Rev. 2). "
Compliance:
Section 7.5 of the Limerick FSAR provides our response to the requirements of Section 6.1.b of NUREG-0737, Supplement 1.
The Type 1 ERFDS Reg. Guide 1.97 displays that present those Post Accident Monitoring variables in FSAR Table 7.5-3 which are only available on the ERFDS, will be operable and functionally available for use by the operators by April 1, 1985.
' Requirement 8.2.1.h "The following variables shall be available in the TSC:
i) the variables in the appropriate Table 1 or 2 of Regulatory Guide 1.97 (Rev. 2) that are essential for performance of TSC functions; and 11) the. meteorological variables in Regulatory Guide 1.97 (Rev. 2) for site vicinity."
Compliance:
The Reg. Guide 1.97 parameters listed on Attachment #1 will be available in the TSC by April 1,1985 on ERFDS color graphic display consoles.
These parameters will be provided by the interim SPDS displays and the Type 1 ERFDS Reg. Guide 1.97 displays.
The meteorological variables will be provided by the Radiation Meteorological Monitoring System (RMMS) CRT terminal in the TSC.
This system is now operational in the TSC.
The remaining Reg. Guide 1.97 variables will be available to the TSC through communicators in the Control Room and TSC until the Type 2 displays are released for use. The appropriate communication equipment is in place in the TSC and Control Room and personnel have been trained to acquire this data.
This method of data acquisition and communication has been utilized during the plant Emergency _ Drills performed during the past year, and has been demonstrated to be both effective and not a burden to Control Room personnel.
~
Requirement 8.4.1.g
" Variables from the following categories that are essential to EOF function shall be available in the EOF:
1)
Variables from the appropriate Table 1 or 2 of Regulatory Guide 1.97 (Rev. 2), and li) the meteorological variables in Regulatory Guide 1.97 (Rev. 2) for site vicinity.
. Compliance:
The Reg. Guide 1.97 parameters listed on Attachment #1 will be available in the EOF by April 1, 1985 on the ERFDS color graphic display console. These parameters will be provided by the interim SPDS displays and the Type 1 ERFDS Reg. Guide 1.97 displays.
The meteorological variables will be provided by the Radiation Meteorological-Monitoring System (RMMS) CRT terminal in the EOF.
This system is now operational in the EOF.
o
- The remaining Reg. Guide 1.97 variables will be available to the EOF through comanunicators in the Control Room, TSC, and EOF.
The appropriate _ communication equipment is in place in the TSC, EOF, and Control Room and personnel have been trained to acquire this data.
This method of data acquisition and communication has been utilized during the plant Emergency-Drills performed during the past year, and has been demonstrated to be both effective and not a burden to Control Room personnel.
JJG/la Attachment
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Attachment #1 y
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Reg. Guide 1.97 Variables Displayed on Interim SPDS and Type 1 ERFDS Reg. Guide 1.97 Displays 1.
Reactor Power (APRM's) 2.
Scram Status 3.
Reactor Water Level 4.
Reactor Pressure 5._
Suppression Pool Temperature 6.
Suppression Pool Level 7.
Drywell Pressure 8.
Drywell Temperature 9.
Wetwell Pressure 10.
Drywell Sump Levels 11.
North Stack Instrument Room (ARM) 12.
Post Accident Sampling Station 13.
Safety Relief Valve Status 14.
Containment Isolation Valve Status