ML20196D873
| ML20196D873 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 12/05/1988 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Murley T NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8812090219 | |
| Download: ML20196D873 (2) | |
Text
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s PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 i
PHILADELPHI A. PA.19101 1215) 841 4 5o o JOHN S. KEMPER canion vies.,nssiosur. nuci *^"
December 5, 1988 i
Dr. T. E. Murley, Director Docket No. 50-353 Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Corrmission Attn: Doctrnent Control Desk Mall Station PI-137 Washington, DC 20555
SUBJECT:
Limerick Generating Station, Unit 2 Safety Parameter Display System and Emergency Response Facility Display System
Dear Dr. Murley:
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NUREG-0991, the Limerick Generating Statf or. (LGS) Safety Evalua-tion Report (SER), Supplements 3 and 5, Section 18.2.9, discuss the Invlementation schedule for operability of the LGS-1 Safety Parameter Display System (SPDS) and the related Emergency Response Facility Display System (ERFDS). Our letter of June 7,1985, S. L. Daltroff to W. R. Butler, also discusses the operability schedule of the ERFDS.
These docurents indicate that SPDS and ERFDS should not be declared operable and released for operator use untII the validation process is successfully corroleted to the extent that it assures reliable data are presented to the operator.
Because the validation process required testing of parameter algorithns and logics at pwer levels up to and f
Including 100 percent of rated power, the LGS-1 IIcense was conditioned to require Initial operability of both the SPDS and the ERFDS within thirty (30) days after the cenpletion of the 100-hour warranty run.
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This letter requests that LGS-2 also be allowed to complete SPDS and ERFDS verification during the Power Ascension Test Program and initially declare the LGS-2 data systems operable within thirty (30) days af ter complot ton of the LGS-2 100-hour warranty rtn.
Additional bases to support this request are discussed below.
I Supplement 1 to NUREG-0737 (Generic Letter No. 82-33, Decerrber 17,
[
1982) recuires that IIcensees develop, in parallel, safety status r
assessment of the plant when the SPDS ls not available. Supplement 1 to NUREG-0737 also requires that the operators be trained to respond to accident conditions with end without the SPDS avaIlable. These re-culrements are being tret fer Limerick Generating Station by lmplanent-I Ing the procedures and operator training described belcw.
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G812090219 GG1203 POR ADOCK 05000353 A
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a The BWR Owners' Group symptcmatic emergency procedures have been impicrnented by developing the symptem oriented Limerick Transient Response implementation Plan (TRIP) emergency procedures.
The safety status of the plant can be assessed from the parameters which constitute the entry conditions into these procedures. The TRIPS form l
the basis for primary operator actions during severe transients.
1 The Limerick TRIP emergency procedures are written so that the i
operator uses hardwired instruments to deterTnine the status of the plant and to enter the emergency procedures.
The SPDS displays do not provide any additional direction to the operator for use of the TRIPS beyond that provided by the hardwired instrtrnents.
The operators licensed at Limerick are thoroughly tralned in the use of the TRIPS. Limerick operators are taught to cope with severe transients utt ilzing the TRIPS in conjuncticri with Regulatory Guide 1.97 Instrunentation without the benef f t of SPDS.
In addition, Regulatory Guide 1.97 (Category 1 and 2) Instrunentation in the Control Rocan receives special panel highlighting to enable the operator to identify It for use in the Inplementation of the TRIPS. Use of the i
Regulatory Guide 1.97 Instrtrnentation for primary Indication is stressed in the operator's sinulator tralning where the Instrunents are similarly marked.
i On the basis of the above Infonnation, the NRC Staff found the l
requested schedule acceptable for LGS-1 (see NUREG-0991,- Supplement 5, Sectlon 18.2.9), but requested PECo to provide a sutmary of the prob-lems encountered and the resolutions Inplemented in making the SPDS operable during the power ascension tests and to report the results frcrn the field verification tests of SPDS. The LGS-1 report dated February 26, 1986, Indicated that only routine hardware and software problems were encountered during tne fleid verification tests which validated the SPDS parameters.
PEco will also provide these reports for LGS-2 within thirty (30) days of the Initial declaration of 1
operability.
Should you have any questions or require any additional I nfonna-tion, please do not hesitate to call.
I Sincerely, M
1 ERG /sw/10208801 Copy to: Addressee R. A. Grmm, LGS Unit 2 Senior Resident Inspector W. T. Russell, Regler1 I Administrator R. J. Clark, LGS Project Manager j
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