ML20128Q368
| ML20128Q368 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/29/1985 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| References | |
| GL-83-28, NUDOCS 8506040171 | |
| Download: ML20128Q368 (6) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET i
i P.O. BOX 8699 PHILADELPHI A. PA.19101 12151 841 5001 v, u p se osn stscrme raooucnoa May 29, 1985 Docket Nos. 50-352 50-353 1
Mr. A. Schwencer, Chief Operating Reactors Branch #2 Division of Licensing U.S. Nuclear Regulatory Commission
-Washington, D.C.
20555
SUBJECT:
Limerick Generation Station - Units 1 and 2 Generic Letter 83-28 " Required Action Based on Generic Implications of Salem ATWS Events"
REFERENCE:
Letter, A Schwencer, USNRC, to E. G. Bauer, Jr. PECo., March 19, 1985
Dear Mr. Schwencer:
The reference letter forwarded the NRC assessment of the
- completeness and adequacy of our responses to the subject Generic Letter for Limerick Units 1 and 2.
The results of the NRC review are as restated below along with our response.
Item 2.1 (Part 1) - Incomplete:
Licensee needs to verify that safety related RTS components are designated as such on all drawings, documents, and in information handling systems.
RESPONSE
All systems that contribute to the reactor trip function have been identified as being in the current 'O' list.
f.
all components on the identified systems, r0 Consequently,ically excluded by a unique safety evaluation, h9-unless specif are subject to the quality assurance program.
1 0 8506040171 850529 PDR ADOCK 05000352 P
p Mr..A. Schwencer,' Chief May 29, 1985 Page 2 In accordance with approved Limerick Administrative Procedures and Engineering and Research Departmental Procedures regarding procurement, each item or service to be procured must be reviewed to determine whether or not.it is safety related.
This' review is performed bri a cognizant member of.the Plant Staff or the Engineering and Research Department as applicable._ The determination is guided by the
O'-l'.st, applicable codes and standards, the Final Safety Analysis Report and information from the Architect Engineer and the.NSSS supplier.
Philadelphia Electric Company believes the current. Limerick
'O' list and the existing procedural controls governing its use are adequate to meet the intent of Generic Letter 83-28.
Item 2.1 (part 2) Incomplete Licensee needs to submit a description of a program to establish and maintain an interface between all vendors of safety-related RTS components and the licensee.
Information submitted shall describe how the progran assures that vendor technical-information is kept current, complete and controlled throughout the plant life and how the program will be implemented at Limerick 1 and 2.
RESPONSE
Philadelphia Electric Company has implemented the program for control of RTS manuals as described in letter V. S. Boyer PECO to D. G. Eisenhut USNRC, dated May 8, 1984, utilizing independent review of NSSS vendor technical reporting methods by the Independent Safety Engineering Group (ISEG).
Certain elements of the procedures placed.in effect by Philadelphia Electric Company referred to in response to the INPO-NUTAC (item 2.2.2 of this letter) specify the administrative-controls and implementing procedures utilized to maintain RTS manuals up-to date.
The program for Limerick Units 1 and 2 is identical to the program established for Philadelphia Electric Company's Peach Bottom Atomic Power Station Units 2 and 3 in response to-the Generic Letter.
Item 2.2.1 - Incomplete The licensee needs to respond to sub-item 6 regarding classification of equipment important to safety.
! y s
~Mr. A.JSchwencer,-Chief' May-29, 1985 Page 3
RESPONSE
U Item'2.2 of the" Generic Letter requires licensees and l
' applicants to submit for staff review, a description of the program for safety related equipment. classification and L
vendor interface'as described in paragraphs 2.2.1.l'through.
12.2.1.5.
Sub-item 6 specifies that " Licensees and applicants need only 3
to submit for staff review the equipment classification program for safety related' components."
Classification programs for components important to safety were not required to be submitted for staff review.
'It~istour-understanding that only classification programs for-
. safety-related equipment require a response for NRC staff H
review for Generic Letter 83-28.
~
1, Item 2.2.2 - Incomplete Licensee needs to describe their program for establishing and
. maintaining an interface with all vendors of safety-related l
equipment thatLassures that vendor technical information is l
kept current, complete, and controlled over the life of the l-plant. ' If the licensee plans to implement the i
recommendationsaof NUTAC,.they should note that the staff found the NUTAC program fails to address the establishment and maintenance of an interface between licensee'and all vendors of safety-related equipment and act to provide the t
needed information.
Where maintenance or test work is performed by other than licensee personnel, the division of
_-responsibility between licensee and vendor for control of procedures and maintenance instructions shall be described.
RESPONSE
l.
During Philadelphia Electric Company's participation in the INPO NUTAC program,.we evaluated the merits of,the program in
. addressing the NRC position contained in item 2.2.2 of the i
Generic Letter. 'Although-there is little incentive for equipment manufacturers to be cognizant of equipment maintenance histories and failures, there is high incentive
~
.for utilities to maintain the type of information exchange Ldescribed within the Vendor Equipment Technical Information Program (VETIP) as defined in the March 1984 NUTAC Report for
>both plant safety and reliability considerations.
i
M s - ;
(Mr.'A.1Schwancar, Chief May 29, 1985-
,t Page 4 p,
Phihadelphia Electric Company has' implemented the program described in,.the_ Vendor Equipment Technical Information-Program as committed in-letter S. L. Daltroff, PECo., to D.
- 13. Eisenhut;-USNRC, dated April 23, 1984 by issuance of the
- following administrative and implementing procedures:
LS-A-1, Administrative Procedure for; Review, Disposition and Monitoring of Responses to NRC IE Bulletins,-IE
-information Notices, and Division of' Licensing-i Generic Letters b
- LS-A-2' Administrative Procedure for" Participation in l
Nuclear Plant Reliability Data System LS-I-5 Implementing Procedure for Utilization of the'INPO NPRD System i:
l.
LS-I-Implementing Procedure for Review, Disposition and l
Monitoring. Nuclear Regulatory Commission.IE Bulletins, IE Information Notices and Division of Licensing Generic Letters I
t NS-A-5 Administrative Procedure for-Review and
-Implementation of Operating Experience Information for Vendor Manual Maintenance L
In addition to the above listed procedures,. the following-l existing procedures, which have been prepared as a result of l-Generic Letter 83-28, are applicable to Items 1, 3, and 4 of L
the NUTAC Programs l~
L.
NSS-I-4 Procedure for. Review and Utilization of Operating l
Experience Information-L -
L-NSS-I-5 Procedure' Governing the Use of the Institute of Nuclear Power Operations Nuclear Network f
-ERDP 6.4-Procedure for Control of Vendor Technical Manuals i
eb The requirements for Controls for vendor services which are' safety-related contained in the NUTAC program are specified
~
in A-27.3; Administrative Procedure for the Procurement ~of Safety Related Services for Limerick.
Based on the program developed by Philadelphia Electric Company in accordance with the NUTAC-VETIP program,. it is requested that NRC're-evaluate this program as a valid response
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to item 2.2.2 of the Generic Letter.
1
m m-7
- ..s7/'
I Mr.LA..Schwencer, Chief May 29, 1985 e
Page 5 1
\\
w/,
Items 3.1.3 and 3.2.3 - Incomplete
' Licensee.needs to state if they have found any post-maintenance. testing requirements;for either RTS-components or-l
'other safety-related equipment that may degrade safety.
If any such are-identified, the licensee shall describe actions to be taken including submitting needed Technical E
Specification changes.
' RESPONSE:
E-During the preparation of the Limerick Technical specifications, no post-maintenance testing requirements ~were I
identified that may degrade safety.
Item 4.5.3 - Incomplete
' Licensee needs to present the results of their study of
= existing or proposed intervals for on-line. testing of the
. reactor trip system.
Such studies shall consider each of the
' concerns expressed in sub-items 4.5.3.1 through 4.5.3.5. of the generic-letter, show how the-intervals result'in high reactor trip systen availability, and presents any resulting Technical Speficification changes for staff review.
.The staff finds that modifications'are not t*1uired to permit on-line testing-of the backup scram valves.
However, the L
staff concludes.that testing of the backup scram valves
'(including initiating circuitry) at a refueling outage i
frequency, in-lieu of on-line testing, is appropriate'and should be included in the technical specifications surveillance requirements.
The. licensee needs to address this conclusion.
RESPONSE
l-Philadelphia Electric. Company participated in the BWR Owners
[
Group effort to' address the review of existing technical specification intervals for testing reactor trip system components.
By way of.this letter,. Philadelphia Electric Company endorses the "BWR Owners Group Response to NRC Generic Letter 83-28, Item 4.5.3" (NEDC-30844) for Limerick
-Units.1 and 2.
This report was transmitted for NRC staff review on January 31, 1985 via letter, John M. Fulton, Chairman BWROG to,D. G. Eisenhut, USNRC.
'In accordance with the instructions contained in the i
. reference-letter,.our plant specific response for item 4.5.3 m
g L
Mr. A. Schwencer, Chief May 29, 1985 Page 6 will be submitted within 90 days after NRC issues its evaluation of NEDC-30844.
Should you require any additional information, please do' not hesitate'to contact us.
Very truly
- ours,
['
j
.sb d
cc:
..J.. T. Wiggins,' Resident Site Inspector See Attached Service List d
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