ML20216E327
| ML20216E327 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 09/03/1997 |
| From: | Rinaldi F NRC (Affiliation Not Assigned) |
| To: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| TAC-M96392, TAC-M96393, NUDOCS 9709100148 | |
| Download: ML20216E327 (4) | |
Text
September 3, 1997 Mr. George A. Hunger, Jr.
Director-Licensing, MC 62A-1 PECO Energy Company Nuclear Group Headquarters Correspondence Control Desk i
P.O. Box No. 195 Wayne, PA 19087-0195
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION (RAI) ON LIMERICK GENERATING STATION, UNITS 1 AND 2 (TAC N05. M96392 AND M96393)
Dear Mr. Hunger:
By letter dated August 8, 1996, PECO Energy Company (PECO) requested our approval of proposed technical specifications to eliminate selected response time testing requirements for the Reactor Protection System, Emergency Core Cooling System, and Isolation Actuation instrumentation.
In response to subsequent telephone conversations with the staff, you submitted a letter dated June 30, 1997, which provided additional information. However, the staff finds that additional information, as stated in the enclosure, is needed to complete our review.
This information was discussed during the recent phone call of August 14, 1997.
Participants of the phone call included l
F. Rinaldi, NRC; P. Loeser, NRC; D. Helker, PEC0; R. Gropp, PEC0; and D. Mantey, PECO.
You are requested to respond to this RAI within 30 days of receipt of this letter so that the staff may continue the review of the proposed amendment in a timely manner.
Please contact me at (301) 415-1447 if you have any questions regarding the enclosure.
Sincerely,
/s/
Frank Rinaldi, Project Manager Project Directorate I-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket Nos. 50-352/353
Enclosure:
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WASHINGTON, D.C. m1 September 3, 1997 Mr. George A. Hunger, Jr.
Director-Licensing, MC 62A-1 PECO Energy Company Nuclear Group Headquarters Correspondence Control Desk P.O. Box No. 195 Wayne, PA 19087-0195
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION (RAI) ON LIMERICK GENERATING STATION, UNITS 1 AND 2 (TAC NOS. M96392 AND M96393)
Dear Mr. Hunger:
By letter dated August 8, 1996, PECO Energy Company (PECO) requested our approval of proposed technical specifications to eliminate selected response time testing requirements for the Reactor Protection System, Emergency Core Cooling System, and Isolation Actuation instrumentation.
In response to subsequent telephone conversations with the staff, you submitted a letter dated June 30, 1997, which provided additional information. However, the staff finds that additional information, as stated in the enclosure, is needed i
l to complete our review. This information was discussed during the recent phone call of August 14, 1997.
Participants of the phone call included F. Rinaldi, NRC; P. Lotser, NRC; D. Helker, PEC0; R. Gropp, PEC0; and D. Mantey, PECO.
You are requested to respond to this RAI within 30 days of receipt of this letter so that the staff may continue the review of the proposed amendment in a timely manner.
Please contact me at (301) 415-1447 if you have any questions regarding the enclosure.
Sincerely, T
(
Frank Rinaldi, Project Manager Project Directorate I-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket Nos. 50-352/353
Enclosure:
RAI cc w/ encl:
See next page
Mr. George A. Hunger, Jr.
Limerick Generating Station, PECO Energy Company Units 1 & 2 cc:
J. W. Durham,-Sr., Esquire Chief-Division of Nuclear Safety Sr. V.P. & General Counsel PA Dept. of Environmental Resources PECO Energy Company P.O. Box 8469 2301 Market Street Harrisburg, PA 17105-8469 Philadelphia, PA 19101 Manager-Limerick Licensing, 62A-1 Director-Site Engineering PECO Energy Company -
Limerick Generating Station 965 Chesterbrook Boulevard P.O. Box A Wayne, PA 19087-5691 Sanatoga, PA 19464 Mr. Walter G. MacFarland, Vice President Limerick Generating Station Manager-Experience Assessment Post Office Box A Limerick Generating Station Sanatoga, PA 19464 P.O. Box A Sanatoga, PA 19464 Plant Manager Limerick Generating Station Library P.O. Box A U.S. Nuclear Regulatory Comission Sanatoga, PA 19464 Region I 475 Allendale Road Regional Administrator, Region I King of Prussia, PA 19406 l
U.S. Nuclear Regulatory Comission i
475 A11endsle Road Senior Manager-Operations King of Prussia, PA 19406 Limerick Generating Station P.O. Box A Senior Resident Inspector Sanatoga, PA 19464 U.S. Nuclear Regulatory Comission Limerick Generating Station Dr.' Judith Johnsrud P.O. Box 596 National Energy Comittee Pottstown, PA 19464 Sierra Club 433 Orlando Avenue Director-Site Support Services State College, PA 16803 Limerick Generating Station P.O. Box A Sanatoga, PA 19464 Chairman Board of Supervisors of Limerick Township 646 West Ridge Pike Linfield, PA 19468-8
RE0 VEST FOR ADDITIONAL INFORMATION The Boiling Water Reactor Owners Group (BWROG), in NEDO-32291 requested elimination of Response Time Testing (RTT) either for devices for which a thorough failure mode and effect analysis (FMEA) had been done, or for devices used in relatively slow respondine systems. The staff's generic safety evaluation report (SER) approving NED0-32291 states, in paragraph four of the conclusion, that:
"The staff, therefore, accepts BWROG Licensing Topical Report NEDO-32291, " System Analyses for Elimination of Selected Response Time Testing Requirements," and the letter from T. Green (BWROG) to P. Loeser (NRC), dated April 15, 1994 (Ref. 12), as a basis for elimination of RTT from TSs for the instruments / components identified in Table I when used in the systems identified in Table 2."
1.
Please justify any systems for which RTT elimination was requested which were not identified in Table 2.
Specifically, please explain why Item 12 on page 9, involving "High Pressure," should be considered as a candidate for elimination of RTT.
2.
Since the elimination of RTT was only for specific equipment listed in Table 1 of the SER, please justify the elimination of equipment not on that list.
Specifically, please state what characteristics of the following equipment make it suitable for elimination of RTT:
Amerace ETR Relay Amerace EPG Relay Amerace GPI Relay Bailey 745 Switch GE CR2940 Relay 3.
Since the elimination of RTT is only for specific systems when using specific equipment, please describe the method by which RTT will be re-initiated for those systems if the specific equipment now used were to be replaced in the future with equipment not listed on Table 1 of the SER.
4.
In those cases where only a portion of the actuation time is no longer measured, but testing for the remainder of the system is still required, please explain what estimated response time will be used for those portions of the system no longer tested when determining overall system response time. What statistically valid analysis was done to ensure this time is appropriate? As an example, if sensor response time testing requirements are eliminated, but there is still a requirement to determine the overall system response time, will the manufacturer's numbers be used?
If historical data is used, by what method is this data analyzed to deterrine the maximum response time possible without affecting calibration er other periodic test?
If the manufacturer's t
response times are to be used, what will be done in those cases where the manufacturer does not provide response time values?
Enclosure
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