ML20125E599
| ML20125E599 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/07/1985 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Butler W Office of Nuclear Reactor Regulation |
| References | |
| CON-#385-526 GL-83-28, NUDOCS 8506130172 | |
| Download: ML20125E599 (6) | |
Text
-
1.-
PHILADELPHIA ELECTRIC COMPANY 23O1 MARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 WNM**I sH erLos L. oALTaorr stsc'in [ 0o E ion June 7, 1985 Docket Nos. 50-352 50-353 Dr. Walter R.
Butler, Chief Operating Reactors Branch #2-Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.
20555
SUBJECT:
Limerick Generating Station Units 1 and 2 Generic Letter 83-28 (Salem ATWS Event)_
REFERENCE:
1.
Letter, V.
S.
Boyer, PECo, to D.
G.
Eisenhut, USNRC, dated-November 10, 1983 2.
Letter, V.
S.
Boyer, PECo, to D. G. Eisenhut, USNRC, dated May 8, 1984 3.
- Letter, S.
L.
Daltroff, PECo, to A.
Schwencer, USNRC, dated May 29, 1985
Dear Dr. Butler:
This letter describes the implementation status of Philadelphia Electric Company commitments to the NRC contained in
'the Reference 1 and 2 letters regarding Generic Letter 83-28 for Limerick-Generating Station Units 1 and 2 as requested by the Limerick NRC Project Manager.
The commitments and status are summarized below along with the applicable action required by licensees contained in the-enclosure to the Generic Letter.
0 8506130172 850607 l
h PDR ADOCK 05000352 P
PDR k
u
a.
/
Dr. Walter R.
Butler.
June.7, 1985 Page 2 p
Item 1.1 Post-Trip Review (Program Description and Procedure)
~
Philadelphia Electric Company submitted the description of l _
the program and applicable procedure to be utilized to analyze unscheduled reactor shutdowns required in sub-items 1.1.1 through 1.l~.7 in-letter dated August 31, 1984, V. S. Boyer, PECo, to D.
G.
Eisenhut, USNRC.
- Item l'.2~- Post-Trip Review (Data and Information Capability)
Philadelphia Electric Company' submitted the description of the plant hardware'and software capability to recall, record-and display:information pertinent to the analysis of unscheduled reactor shutdowns required.by items 1.2.1 through 1.2.4 in the Reference 1 letter.
At the time the Reference 1 letter was forwarded to the l
NRC, construction activities had not yet been completed on Unit 1.
The-description of the plant data'and recall capability did not Linclude a proposed schedule for operability of this equipment.
-A portion of the data and information capability, as
. described in the Reference 1 letter to be utilized in the analysis l
L of unscheduled reactor shutdowns, is the Emergency Response Facility l
Data' System-(ERFDS), a continuous on-line transient monitoring.
I system. -.1iue ERFDS also provides operating information to the l
operator via CRT graphic displays which include the Safety Parameter Display System (SPDS).
By letter dated March 29, 1985, J.
S.
Kemper, PECo, to H.
R.-Denton, USNRC, Philadephia Electric Company requested that the SPDS.be initially operable within 30 days after the completion of
-the 100-Hour Warranty Run at 100 percent of rated power to permit validation of SPDS during power ascension testing.
h Since the SPDS is part of the ERFDS, Philadelphia Electric Company proposes that the ERFDS be initially operable on a schedule consistent with the operability requirements proposed for SPDS.
Item 2.1 - Equipment Classification and Vendor Interface (Reactor Trip System Components)
Philadephia Electric Company committed to the independent review by the PECo Independent Safety Engineering Group (ISEG) of
.NSSS. vendor reporting mechanisms as a vendor interface program for reactor trip' function components.
As specified in the Reference 1.
v Dr. Walter R.: Butler June 7, 1985 Page'3 m'
i L
'and 2 letters, applicable procedures and the ISEG program-were to be l
in effect by June 1, 1984.
ISEG Procedure NSS-I-4, " Procedure for Review and Utilization of Operating Experience Information", which includesLreview and disposition of NSSS vendor-information was=
approved for use April 12, 1984.
In addition to the ISEG program, Philadelphia Electric Company committed :to prepare a new Engineering and Research Department Procedure (ERDP), for maintenance of controlled vendor manuals in a-manner similar to existing controls for drawings.
Engineering and Research Department Procedure ERDP 6.4,
" Procedure for Control of Vendor Technical Manuals", was approved for use and placed in effect September 21, 1984.
Item 2.2 - Equipment Classification and Vendor Interface (Programs for all Safety-Related Components)
The Philadelphia Electric Company commitments regarding
-items 2.2.1.1:through 2.2.1.5'are contained in_the Reference 1 letter.
These commitments relating to procedural controls for equipment classified as safety-related.are summarized as follows:
'The Engineering'and Research Department Procedure governing the Limerick 'O list will be modeled after the procedure applicable to Philadelphia Electric Company's Peach Bottom.
Units 2 and 3.
The Limerick "Q" list will remain under the control of -the Architect / Engineer during the first fuel cycle.
By the conclusion of the first refueling outage for Limerick Unit 1, control of the "O"' list will be turned over to Philadelphia Electric Company.
at that time, be specified Procedural control-of the "Q" list will, in an Engineering ~and Research Department procedure similar to the procedure applicable to Peach Bottom Units 2 and 3.
Procurement of safety-related equipment will be performed in accordance with applicable Engineering and Research Departmental Procedures when the procurement function is turned over to Philadelphia Electric Company from the Architect / Engineer.
The applicable ERDP s are as follows:
ERDP 3.4
" Procedure for Design Control"
TT V~4-
~
^
-Dr. WaltersR.-_.Butlerr June _7, 1985
- ^
' 'Page 4
~
24 IERPD 4.4 "Proced'ure-for. Procurement'of-Specially
. Engineered Equipment Materials, Services or combination thereof:with a Specification".
~
L ERDP'4.5
" Procedure. 'for Procurement of Nuclear Safety-Related Items and Services by the Preliminary N
Requisition, Method".
~ERDP:4.6
" Procedure for Procurement of Nuclear Safety-Related Items under the Catalog Method".
ERDP 6.?
" Procedure for Processing Vendor Documentation"-
.ERDP 6.3
" Procedure-for Processing Documents"
'ERDP 7.-l
" Procedure for Receipt, Inspection and Storage of
~
Materials and Equipment" The above listed procedures regarding procurement.of safety-related equipment,.which also apply to Peach Bottom
= Units 2 and 3, are currently:in effect for control of these activities for Limerick' Generating Station Unit 1.
The computerized History _and Maintenance Planning System
- (CHAMPS), described in the Reference 1 letter as the information handling : system for safety-related maintenance activities in the plant,~is' operational and is being used to generate maintenance' request forms.
The system was put into operation in May, 1984.
Regarding Item 2.2.2 of the Generic Letter, Philadelphia Electric Company has. implemented the. commitment to develop procedures.to address the recommendations contained in the Vendor Equipment Technical Information ' Program (VETIP) described in the
.INPO-NUTAC report? submitted with the Reference 2 letter.
The procedures listed below'were placed into effect on the dates indicated:to address the NUTAC recommendations:
-- LS-A-11 ( 3 85 )
Administrative Procedure for Review, Disposition and Monitoring of Responses to i
i.-
h L.
P L
a ' 3( _
~*
. a q.b V;
Drj^ Walter;R.' Butler-June 7,.1985 Page 5
~
NRC:IE Bulletins, IELInformation Notices, and Division of-Licensing' Generic-Letters
.LS-A-2 (3-21-85) l Administrative Procedure for Participation in Nuclear Plant Reliability Data System-tLS-I-5 (3-21-85).
Implementing Procedure for Utilization of
'the INPO NPRD System
~
LS-I-6'(3-21-85)
Implementing Procedure for Review, Disposition and Monitoring Nuclear-Regulatory Commission'.IE Bulletins, IE Information Notices and Division of Licensing Generic Letters NS-A-5 (3-19-85)c Administrative Procedure for Review and Implementation of Operating Experience Information for Vendor Manual Maintenance L
In addition-to the above listed procedures, the following procedures, Which were prepared as a result of Generic Letter 83-28, are1 applicable to portions of the NUTAC program:
4 NSS-I-4 Procedure for Review and Utilization of Operating
' Experience Information NSS-I-5
. Procedure Governing the Use'of the Institute of v.
Nuclear Power Operations Nuclear Network Regarding the NUTAC recommendations for controls of vendor-services Which'are' safety-related, procedural control for such services.is specified in Limerick procedure A27.3, Administrative
' Procedure for the Procurement of Safety-Related Services.
Item 4.5:- Reactor Trip System Reliability (System Functional Testing)
A description of the testing performed and frequencies was
~
provided in the' Reference 2 letter for items 4.5.1 and 4.5.2.
- Regarding item 4.5.3, as specified in the Reference 3,
. Philadelphia Electric Company endorsed the BWR Ownerst Group Topical
- Reportf(NEDC-30844) for' Limerick Units 1 and 2 addressing testing intervals contained within the Technical Specifications.
A subsequent plant ' unique response ' for Limerick Units 1 and 2 will be.
L
c --
S....
t Dr. Walter R.: Butler June 7, 1985
.Page 6
-made within 90 days following issuance of the NRC evaluation of the
-Topical Report.
. The foregoing summarizes the commitments for Limerick l
Generating Station Units 1 and 2 regarding Generic Letter 83-28.
Should you re' quire _ additional information, please do not hesitate to contact us.
Very truly
- ours,
/
)
/
/
', jbhfb f "A f
/
cca Limerick NRC Resident Inspector See Attached Service List 9
.m.
.. _,,