ML20113C959

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Submits Addl Info Requested in 850408 Telcon Re Conclusion That No Significant Hazards Associated W/Requested Schedule Change for Initial Operability of Spds.Change Requires No Rev to Operating Limits,Procedures or Setpoints
ML20113C959
Person / Time
Site: Limerick Constellation icon.png
Issue date: 04/09/1985
From: Kemper J
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To: Harold Denton
Office of Nuclear Reactor Regulation
References
CON-#285-503, RTR-NUREG-0737, RTR-NUREG-737 OL, NUDOCS 8504120170
Download: ML20113C959 (5)


Text

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3 PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHIA, PA.19101 JOHNS.KEMPER WICE#R ESID E NT ENeeNEERtNG AND RESE ARCH April 9, 1985 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

Limerick Generating Station, Unit 1 Docket No.:

50-352 FOL No.:

NPF-27

REFERENCES:

1)

Letter, J. S. Kemper to H. R. Den on, dated March 29, 1985

2) Telecon between R. Martin, USNRC and W. Alden, PEco, April 8, 1985 FILE:

GOVT 1-1 (NRC)

Dear Mr. Denton:

In the reference 2) telecon, we were requested to provide supplemental information to our reference 1) letter which specifically supports our determination that no significant hazards are associated with the requested schedule change for the initial operability of the Safety Parameter Display Syster.1 (SPDS).

This letter provides the requested information.

The Limerick SPDS is a ' computer based system which monitors numerous system parameters and displays them on CRT's in the control Room.

The non-operation of the SPDS cannot adversely affect any of the systems which it monitors because qualified isolation devices have been used between the SPDS computer system and the monitored instrument loops.

This isolation feature was reviewed by the NRC Staff and found acceptable in NUREG-0991, Supplement SER 3, Section 18.2.6.

8504120170 850409 PDR ADOCK 05000352 F

PDR 0

s\\s

Mr. H;rold R. Denton April 9, 1985 The non-availability of the SPDS during power operation will not adversely affect the operators' response to transient operating conditions.

All of the parameters presented on the SPDS displays are presently available in the Control Room for operator use via qualified, hardwired indicators.

These indicators are conveniently located in the control Room and are readily accessible to the reactor operator.

The analog indicators are also highlighted with yellow lines to allow the operator to distinguish their location.

These indicators provide the information that is needed to quickly and reliably assess the safety status of the plant.

As required by NUREG-0737, Supplement 1, the Limerick emergency operating procedures have been written so that the operator can determine the safety status of the plant in a timely manner without the SPDS being available.

The NRC Staff has reviewed and approved the Limerick emergency operating procedures in Section 13.5 of NUREG-0991, Supplement 2.

In addition, the operators have been trained in the simulator to respond to transient and emergency conditions without the SPDS being available.

The operator training described above along with the use of the emergency procedures and the system isolation devices demonstrate that the proposed modification in the schedule for initial operability of the SPDS does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The requested change in initial operability of the SPDS does not require any revision or modification to any plant systems, structures, components, technical specifications or operating procedures.

As a result, the number and types of abnormal operating transients already analyzed in the FSAR and reviewed and accepted by the NRC Staff will not be affected.

Operator response to these transients is covered in the existing normal and emergency plant operating procedures which do not require an operable SPDS for their successful execution. Therefore, the requested change in initial operability of the SPDS will not create the possibility of a new or different kind of accident from any previously evaluated.

The requested change in initial operability of the SPCS does not require any revision to cperating limits, setpoints, or operating procedures.

For this reason, the requested change does not involve a reduction in a margin of safety.

[l u'

,_ Mr..flarold R. Danton April 9, 1985 The foregoing discussion provides the specific bases for our

, conclusion that'the proposed modification to NPF-27 meets the standards in Section 50.92(c) of the Conanission's regulations for a detemination of no significant hazards considerations.

Sincerely, s_

$ 5, /$f EPS:did.

DD4985L815 cc Dr. T. E. Murley, Administrator,. Region I J. T._Wiggins, Resident Inspector J. Rutberg, Esq..

Attached Service List

=w._.

i 4

r COMMONWEALTH OF PENNSYLVANIA ss.

COUNTY OF PHILADELPHIA J. S. Kemper, being first duly sworn, deposes and says:

That he is Vice President of Philadelphia Electric Company, the Applicant herein; that he has read the foregoing letter related to the request for modification of License condition 2.C.8. (b) 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.

<WfMf f ice Presid'nt e

Subscribed and' sworn to 9

/O4 before me this day of April, 1985.

' 4Y ns j y p.

Notary P lic

/

PATRIC A'A JONES Notary Public, Phila., Phila. Co.

. My Commission Expwos Oct.13.1986

cc: Judge Helen F. Hoyt Judge Jerry Harbour Judge Richard F. Cole Troy B. Conner, Jr.', Esq.

J Ann P. Hodgdon, Esq.

Mr. Frank R. Romano Mr. Robert L. Anthony Ms. Phyllis Zitzer Charles W. Elliot, Esq.

Zori G. Ferkin, Esq.

Mr. Thomas Gerusky Director, Penna. Emergency Management Agency Angus R. Love, Esq.

David Wersan, Esq.

i I

Robert J. Sugarman, Esq.

Martha W. Bush, Esq.

Spence.W.

Perry, Esq.

Jay M. Gutierrez, Esq.

l Atomic Safety & Licensing Appeal Board l

Atomic Safety G Licensing Board Panel Docket'& Service Section Mr. James Wiggins Mr. Timothy R. S. Campbell f.

.