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Category:CORRESPONDENCE-LETTERS
MONTHYEARPLA-5120, Forwards Change J to SSES Security Training & Qualification Plan.Without Encl1999-10-22022 October 1999 Forwards Change J to SSES Security Training & Qualification Plan.Without Encl ML18040B2951999-09-0808 September 1999 Requests Info Re Any NRC or Susquehanna Documented Concerns with MSIV Reliability Prior to Plant Trip & Assurance to Public That NRC Able to Detect Mgt Problems Early PLA-5094, Forwards,For Review,Change 00 to SSES Physical Security Plan.Without Encl1999-08-24024 August 1999 Forwards,For Review,Change 00 to SSES Physical Security Plan.Without Encl ML18040A9741999-07-0808 July 1999 Forwards Rev 30 to SSES Emergency Plan, Adding EAL to Account for Potential Conditions Associated with Dry Cask Storage Sys Being Installed at Plant ML20207G5051999-06-0707 June 1999 Informs That NRC Office of NRR Reorganized Effective 990328.As Part of Reorganization,Divison of Licensing Project Management Created PLA-5072, Forwards Change Nn to SSES Physical Security Plan.Util Determined That Changes Do Not Decrease Safeguards Effectiveness of Plan,Per 10CFR50.54(p).Encl Withheld from Public Disclosure,Per 10CFR73.211999-06-0404 June 1999 Forwards Change Nn to SSES Physical Security Plan.Util Determined That Changes Do Not Decrease Safeguards Effectiveness of Plan,Per 10CFR50.54(p).Encl Withheld from Public Disclosure,Per 10CFR73.21 ML18040A9731999-05-24024 May 1999 Submits Response to RAI Re Exemption from Biennial Exercise Schedule.Changing of Drill Date Will Not Reduce Level of Emergency Preparedness at Plant ML20195B2181999-05-20020 May 1999 Forwards Proprietary Decommissioning Status Rept for 10% Interest in Sses,Units 1 & 2.Proprietary Info Withheld,Per 10CFR2.790 ML18040B2901999-04-30030 April 1999 Forwards Summary Rept of Safety Evaluations Approved During Period from 961024-981029,per 10CFR50.59(b).Format of Rept, Listed PLA-5041, Forwards Proprietary & Redacted Decommissioning Rept of Financial Assurance for Util 90% Interest in Sses,Units 1 & 2,per 10CFR50.75(f)(1).Proprietary Info Withheld,Per 10CFR2.7901999-03-29029 March 1999 Forwards Proprietary & Redacted Decommissioning Rept of Financial Assurance for Util 90% Interest in Sses,Units 1 & 2,per 10CFR50.75(f)(1).Proprietary Info Withheld,Per 10CFR2.790 ML18040A9691999-03-12012 March 1999 Forwards Revised Proposed Amend 227 to License NPF-14, Proposing Changes to ANFB-10 Critical Power Correlation & MCPR Safety Limits ML17164A9891999-03-12012 March 1999 Informs That Util 990312 Ltr (PLA-5040) Submitted to NRC, Missing Encl C.Requests to Replace Package in Entirety with Encl ML18040A9721999-03-11011 March 1999 Requests That Date for full-participation SSES Exercise, Scheduled for Week of 991115,be Changed Due to FEMA Region III Scheduling Conflicts.Fema Requests That Exercise Date Be Changed to Week of 001031 PLA-4852, Forwards non-redacted Version of Pp&L,Inc Corporate Auditing Rept 739459-2-98,dated 980210.Informs That Document Contains Info to Be Withheld IAW 10CFR2.7901999-02-18018 February 1999 Forwards non-redacted Version of Pp&L,Inc Corporate Auditing Rept 739459-2-98,dated 980210.Informs That Document Contains Info to Be Withheld IAW 10CFR2.790 ML20203G5821999-02-17017 February 1999 Second Final Response to FOIA Request for Documents. Documents Listed in App C Being Released in Entirety. Documents Listed in App D Being Withheld in Part (Ref FOIA Exemption 5) ML20202F4761999-01-29029 January 1999 First Partial Response to FOIA Request for Documents.Records in App a Encl & Being Released in Entirety.App B Records Being Withheld in Part (Ref FOIA Exemption 7C) ML18040A9671999-01-29029 January 1999 Notifies That Util Implemented Severe Accident Mgt Strategy in Accordance with Ltr Dtd 950327.Emegency Plan Revs Which Were Required to Implement Strategy Were Submitted by Ltr Dtd 981125 ML18040A9681999-01-29029 January 1999 Requests Exemption from Requirements of 10CFR50 App E,Items IVF.2.b & C,To Allowed to Reschedule Federally Observed Full Participation Emergency Exercise for SSES from Wk of 991115 to Wk of 001031 ML18040A9651999-01-12012 January 1999 Submits Addl Info Re Proposed Amend 184 to License NPF-22 for ANFB-10 Critical Power Correlation & MCPR Safety Limits ML18030A1021998-12-16016 December 1998 Forwards Tables as Requested During 981202 Telcon Re Proposed Amend 184,dtd 980804,re ANFB-10 Critical Power Correlation & MCPR Safety Limits.Tables Provide Roadmap Identifying Applicability of References to TSs ML18030A4331998-11-25025 November 1998 Forwards Rev 29 to SSES Emergecny Plan.Changes Has Been Made Without Commission Approval as It Does Not Decrease Effectiveness of Plan & Plan as Changed Continues to Satisfy Applicable Requirements of App E to 10CFR50 ML20195J9101998-11-18018 November 1998 Forwards Notice of Withdrawal of Application for Amends to Facility Operating Licenses (Notice).Notice Has Been Filed with Ofc of Fr.Amends Would Have Revised TS to Eliminate HPCI Pump auto-transfer on High Suppression Pool Level ML20155F7201998-11-0303 November 1998 Final Response to FOIA Request for Documents.Documents Listed in App B Being Encl & Being Released in Entirety. Documents Listed in App C Being Withheld in Part (Ref Exemption 7C) ML18026A2941998-10-19019 October 1998 Forwards SSES ISI Outage Summary Rept for Unit 1 Tenth Refueling & Insp Outage ML18030A4321998-10-12012 October 1998 Forwards Rev 28 to SSES Emergency Plan, IAW Requirements of 10CFR50.54q.Change Is Summarized PLA-4993, Forwards Change Mm to SSES Physical Security Plan.Encl Withheld,Per 10CFR73.211998-10-12012 October 1998 Forwards Change Mm to SSES Physical Security Plan.Encl Withheld,Per 10CFR73.21 ML18030A1001998-10-12012 October 1998 Forwards Rev 27 to SSES Emergency Plan. Changes Become Effective Upon Implementation of Improved Tech Specs ML18030A4311998-09-29029 September 1998 Forwards Rev 27 & 28 to SSES Emergency Plan ML20151W4951998-09-10010 September 1998 Informs That as Part of NRC Probabilistic Risk Assessment Implementation Plan,Commission Assigned Two Senior Reactor Analysts (Sras) to Each Regional Ofc.T Shedlosky & J Trapp Has Been Assigned SRAs for Region I IR 05000387/19980081998-09-0808 September 1998 Provides Response to Violations Noted in Insp Repts 50-387/98-08 & 50-388/98-08.Corrective Actions:Current Administrative Controls on Fuel Level in EDG Day Tanks Will Remain in Effect Until TS Change is Approved ML18030A0991998-09-0808 September 1998 Provides Response to Violations Noted in Insp Repts 50-387/98-08 & 50-388/98-08.Corrective Actions:Current Administrative Controls on Fuel Level in EDG Day Tanks Will Remain in Effect Until TS Change Is Approved ML18026A4961998-08-31031 August 1998 Responds to NRC 980731 Ltr Re Violations Noted in Insp Repts 50-387/98-03 & 50-388/98-03.Corrective Actions:Procurement & Affected User Group Personnel Visited EDG Vendor Facilities to Appraise Vendor Work Practices & Discuss Expectations IR 05000387/19980031998-08-31031 August 1998 Responds to NRC 980731 Ltr Re Violations Noted in Insp Repts 50-387/98-03 & 50-388/98-03.Corrective Actions:Procurement & Affected User Group Personnel Visited EDG Vendor Facilities to Appraise Vendor Work Practices & Discuss Expectations ML20202F5501998-07-17017 July 1998 Responds to PP&L Corp Auditing Repts 739459-97,739459-1-97 & 739459-2-98 Re SSES Investigations Into Missed Alarm Tests ML20236P9451998-07-15015 July 1998 Forwards Emergency Response Data Sys Implementation Documents Including Data Point Library Updates for Oconee (Number 255),Dresden (Number 257) & Susquehanna (Number 258) ML18030A4291998-07-0808 July 1998 Forwards Final Version of SSES TS Implementing Improved TS of NUREG-1433.Implementation of Proposed Amend Is Predicted on NRC Issuance of Amends & Proposed to Not Exceed 90 Days from Date of Amend Issue ML18017A2181998-07-0808 July 1998 Forwards Final Version of SSES TS Implementing Improved Tech Specs of NUREG 1433.Implementation of Proposed Amend Is Predicated on NRC Issuance of Amends & Is Proposed to Not Exceed 90 Days from Date of Amend Issuance ML18026A2901998-06-0909 June 1998 Forwards Rev 26 to Emergency Plan IAW 10CFR50.54q.Summary of Changes Listed ML18026A2891998-05-22022 May 1998 Submits Withdrawal of Expedited Review/Approval of Tech Specs/Bases 3/4.3.7.11 & 3/4.11.2.6 & Response to Request for Addl Info Re Offgas Sys Mods ML18026A4941998-05-12012 May 1998 Responds to NRC Request to Resubmit Proposal to Change TS for Plant,Units 1 & 2,to Support Implementation of Improved TS & to Implement Provisions of GL 86-10 Re Relocation of Plant'S Fire Protection Program from TS to Another Document ML20202H1331998-04-16016 April 1998 Partially Deleted Ltr Re Concerns Raised to NRC Concerning PP&L Susquehanna Facility NUREG-0619, Informs That Staff Finds PP&L 980330 Request for Relief from Requirements of Section 4.3 of NUREG-0619,exams of Feedwater Nozzle Bore & Inner Radius for Another Operating Cycle to Be Acceptable1998-04-15015 April 1998 Informs That Staff Finds PP&L 980330 Request for Relief from Requirements of Section 4.3 of NUREG-0619,exams of Feedwater Nozzle Bore & Inner Radius for Another Operating Cycle to Be Acceptable ML20216B6811998-04-0101 April 1998 First Partial Response to FOIA Request for Documents. Forwards Documents Listed in App a Being Released in Entirety ML17159A2341998-03-30030 March 1998 Forwards LER 97-007-01,per 10CFR50.73(a)(2)(i)(B).Revised LER Submitted to Modify Previous Position W/Regards to Entry Into TS 3.0.3 for Event PLA-4865, Forwards Listed non-redacted Pp&L,Inc Corporate Auditing Repts.Informs That Document Contains Info to Be Withheld IAW 10CFR2.7901998-03-11011 March 1998 Forwards Listed non-redacted Pp&L,Inc Corporate Auditing Repts.Informs That Document Contains Info to Be Withheld IAW 10CFR2.790 ML17159A1781998-03-0202 March 1998 Forwards Proposed Amends 203 & 161 to License NPF-14 & NPF-22,revising Tech Specs to Be Consistent w/NUREG-1433,rev 1, Std Tech Specs for GE Plants,Bwr 4. PLA-4856, Forwards Proposed Amends to Licenses NPF-14 & NPF-22, Revising TS to Be Consistent w/NUREG-1433,rev 1, Std TS for GE Plants,Bwr 4. Proposed TS Consistent w/NUREG-1433,rev 1, Encl1998-03-0202 March 1998 Forwards Proposed Amends to Licenses NPF-14 & NPF-22, Revising TS to Be Consistent w/NUREG-1433,rev 1, Std TS for GE Plants,Bwr 4. Proposed TS Consistent w/NUREG-1433,rev 1, Encl PLA-4854, Provides Summary of Investigations That PP&L Performed in Response to Concerns Identified by Former Nuclear Plant Operator.Summary Requested by Cj Anderson on 9802131998-02-27027 February 1998 Provides Summary of Investigations That PP&L Performed in Response to Concerns Identified by Former Nuclear Plant Operator.Summary Requested by Cj Anderson on 980213 ML20203M5071998-02-26026 February 1998 Final Response to FOIA Request for Documents.Records in App a Being Placed in PDR & Encl.Records in App B Partially Withheld (Ref FOIA Exemption 6) ML20203B5931998-02-23023 February 1998 Ack Receipt of & Wire in Amount of $55,000 in Payment for Civil Penatly Proposed by NRC Ltr . Corrective Actions Will Be Examined During Future Inspections 1999-09-08
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARPLA-5120, Forwards Change J to SSES Security Training & Qualification Plan.Without Encl1999-10-22022 October 1999 Forwards Change J to SSES Security Training & Qualification Plan.Without Encl ML18040B2951999-09-0808 September 1999 Requests Info Re Any NRC or Susquehanna Documented Concerns with MSIV Reliability Prior to Plant Trip & Assurance to Public That NRC Able to Detect Mgt Problems Early PLA-5094, Forwards,For Review,Change 00 to SSES Physical Security Plan.Without Encl1999-08-24024 August 1999 Forwards,For Review,Change 00 to SSES Physical Security Plan.Without Encl ML18040A9741999-07-0808 July 1999 Forwards Rev 30 to SSES Emergency Plan, Adding EAL to Account for Potential Conditions Associated with Dry Cask Storage Sys Being Installed at Plant PLA-5072, Forwards Change Nn to SSES Physical Security Plan.Util Determined That Changes Do Not Decrease Safeguards Effectiveness of Plan,Per 10CFR50.54(p).Encl Withheld from Public Disclosure,Per 10CFR73.211999-06-0404 June 1999 Forwards Change Nn to SSES Physical Security Plan.Util Determined That Changes Do Not Decrease Safeguards Effectiveness of Plan,Per 10CFR50.54(p).Encl Withheld from Public Disclosure,Per 10CFR73.21 ML18040A9731999-05-24024 May 1999 Submits Response to RAI Re Exemption from Biennial Exercise Schedule.Changing of Drill Date Will Not Reduce Level of Emergency Preparedness at Plant ML20195B2181999-05-20020 May 1999 Forwards Proprietary Decommissioning Status Rept for 10% Interest in Sses,Units 1 & 2.Proprietary Info Withheld,Per 10CFR2.790 ML18040B2901999-04-30030 April 1999 Forwards Summary Rept of Safety Evaluations Approved During Period from 961024-981029,per 10CFR50.59(b).Format of Rept, Listed PLA-5041, Forwards Proprietary & Redacted Decommissioning Rept of Financial Assurance for Util 90% Interest in Sses,Units 1 & 2,per 10CFR50.75(f)(1).Proprietary Info Withheld,Per 10CFR2.7901999-03-29029 March 1999 Forwards Proprietary & Redacted Decommissioning Rept of Financial Assurance for Util 90% Interest in Sses,Units 1 & 2,per 10CFR50.75(f)(1).Proprietary Info Withheld,Per 10CFR2.790 ML17164A9891999-03-12012 March 1999 Informs That Util 990312 Ltr (PLA-5040) Submitted to NRC, Missing Encl C.Requests to Replace Package in Entirety with Encl ML18040A9691999-03-12012 March 1999 Forwards Revised Proposed Amend 227 to License NPF-14, Proposing Changes to ANFB-10 Critical Power Correlation & MCPR Safety Limits ML18040A9721999-03-11011 March 1999 Requests That Date for full-participation SSES Exercise, Scheduled for Week of 991115,be Changed Due to FEMA Region III Scheduling Conflicts.Fema Requests That Exercise Date Be Changed to Week of 001031 PLA-4852, Forwards non-redacted Version of Pp&L,Inc Corporate Auditing Rept 739459-2-98,dated 980210.Informs That Document Contains Info to Be Withheld IAW 10CFR2.7901999-02-18018 February 1999 Forwards non-redacted Version of Pp&L,Inc Corporate Auditing Rept 739459-2-98,dated 980210.Informs That Document Contains Info to Be Withheld IAW 10CFR2.790 ML18040A9681999-01-29029 January 1999 Requests Exemption from Requirements of 10CFR50 App E,Items IVF.2.b & C,To Allowed to Reschedule Federally Observed Full Participation Emergency Exercise for SSES from Wk of 991115 to Wk of 001031 ML18040A9671999-01-29029 January 1999 Notifies That Util Implemented Severe Accident Mgt Strategy in Accordance with Ltr Dtd 950327.Emegency Plan Revs Which Were Required to Implement Strategy Were Submitted by Ltr Dtd 981125 ML18040A9651999-01-12012 January 1999 Submits Addl Info Re Proposed Amend 184 to License NPF-22 for ANFB-10 Critical Power Correlation & MCPR Safety Limits ML18030A1021998-12-16016 December 1998 Forwards Tables as Requested During 981202 Telcon Re Proposed Amend 184,dtd 980804,re ANFB-10 Critical Power Correlation & MCPR Safety Limits.Tables Provide Roadmap Identifying Applicability of References to TSs ML18030A4331998-11-25025 November 1998 Forwards Rev 29 to SSES Emergecny Plan.Changes Has Been Made Without Commission Approval as It Does Not Decrease Effectiveness of Plan & Plan as Changed Continues to Satisfy Applicable Requirements of App E to 10CFR50 ML18026A2941998-10-19019 October 1998 Forwards SSES ISI Outage Summary Rept for Unit 1 Tenth Refueling & Insp Outage ML18030A4321998-10-12012 October 1998 Forwards Rev 28 to SSES Emergency Plan, IAW Requirements of 10CFR50.54q.Change Is Summarized ML18030A1001998-10-12012 October 1998 Forwards Rev 27 to SSES Emergency Plan. Changes Become Effective Upon Implementation of Improved Tech Specs PLA-4993, Forwards Change Mm to SSES Physical Security Plan.Encl Withheld,Per 10CFR73.211998-10-12012 October 1998 Forwards Change Mm to SSES Physical Security Plan.Encl Withheld,Per 10CFR73.21 ML18030A4311998-09-29029 September 1998 Forwards Rev 27 & 28 to SSES Emergency Plan ML18030A0991998-09-0808 September 1998 Provides Response to Violations Noted in Insp Repts 50-387/98-08 & 50-388/98-08.Corrective Actions:Current Administrative Controls on Fuel Level in EDG Day Tanks Will Remain in Effect Until TS Change Is Approved IR 05000387/19980081998-09-0808 September 1998 Provides Response to Violations Noted in Insp Repts 50-387/98-08 & 50-388/98-08.Corrective Actions:Current Administrative Controls on Fuel Level in EDG Day Tanks Will Remain in Effect Until TS Change is Approved ML18026A4961998-08-31031 August 1998 Responds to NRC 980731 Ltr Re Violations Noted in Insp Repts 50-387/98-03 & 50-388/98-03.Corrective Actions:Procurement & Affected User Group Personnel Visited EDG Vendor Facilities to Appraise Vendor Work Practices & Discuss Expectations IR 05000387/19980031998-08-31031 August 1998 Responds to NRC 980731 Ltr Re Violations Noted in Insp Repts 50-387/98-03 & 50-388/98-03.Corrective Actions:Procurement & Affected User Group Personnel Visited EDG Vendor Facilities to Appraise Vendor Work Practices & Discuss Expectations ML18017A2181998-07-0808 July 1998 Forwards Final Version of SSES TS Implementing Improved Tech Specs of NUREG 1433.Implementation of Proposed Amend Is Predicated on NRC Issuance of Amends & Is Proposed to Not Exceed 90 Days from Date of Amend Issuance ML18030A4291998-07-0808 July 1998 Forwards Final Version of SSES TS Implementing Improved TS of NUREG-1433.Implementation of Proposed Amend Is Predicted on NRC Issuance of Amends & Proposed to Not Exceed 90 Days from Date of Amend Issue ML18026A2901998-06-0909 June 1998 Forwards Rev 26 to Emergency Plan IAW 10CFR50.54q.Summary of Changes Listed ML18026A2891998-05-22022 May 1998 Submits Withdrawal of Expedited Review/Approval of Tech Specs/Bases 3/4.3.7.11 & 3/4.11.2.6 & Response to Request for Addl Info Re Offgas Sys Mods ML18026A4941998-05-12012 May 1998 Responds to NRC Request to Resubmit Proposal to Change TS for Plant,Units 1 & 2,to Support Implementation of Improved TS & to Implement Provisions of GL 86-10 Re Relocation of Plant'S Fire Protection Program from TS to Another Document ML17159A2341998-03-30030 March 1998 Forwards LER 97-007-01,per 10CFR50.73(a)(2)(i)(B).Revised LER Submitted to Modify Previous Position W/Regards to Entry Into TS 3.0.3 for Event PLA-4865, Forwards Listed non-redacted Pp&L,Inc Corporate Auditing Repts.Informs That Document Contains Info to Be Withheld IAW 10CFR2.7901998-03-11011 March 1998 Forwards Listed non-redacted Pp&L,Inc Corporate Auditing Repts.Informs That Document Contains Info to Be Withheld IAW 10CFR2.790 PLA-4856, Forwards Proposed Amends to Licenses NPF-14 & NPF-22, Revising TS to Be Consistent w/NUREG-1433,rev 1, Std TS for GE Plants,Bwr 4. Proposed TS Consistent w/NUREG-1433,rev 1, Encl1998-03-0202 March 1998 Forwards Proposed Amends to Licenses NPF-14 & NPF-22, Revising TS to Be Consistent w/NUREG-1433,rev 1, Std TS for GE Plants,Bwr 4. Proposed TS Consistent w/NUREG-1433,rev 1, Encl ML17159A1781998-03-0202 March 1998 Forwards Proposed Amends 203 & 161 to License NPF-14 & NPF-22,revising Tech Specs to Be Consistent w/NUREG-1433,rev 1, Std Tech Specs for GE Plants,Bwr 4. PLA-4854, Provides Summary of Investigations That PP&L Performed in Response to Concerns Identified by Former Nuclear Plant Operator.Summary Requested by Cj Anderson on 9802131998-02-27027 February 1998 Provides Summary of Investigations That PP&L Performed in Response to Concerns Identified by Former Nuclear Plant Operator.Summary Requested by Cj Anderson on 980213 ML20216B7031998-02-22022 February 1998 Partially Deleted Ltr Requesting Copy of OI Rept on Plant, Unit 2,case 1-96-039 PLA-4851, Provides Info That Was Requested by Cj Anderson on 980213 Re Former Util Employee Concern on Radwaste Control Room Offgas Panel Alarm Testing1998-02-18018 February 1998 Provides Info That Was Requested by Cj Anderson on 980213 Re Former Util Employee Concern on Radwaste Control Room Offgas Panel Alarm Testing ML20203M5791998-02-10010 February 1998 Enters Appeal Due to Lack of Response to FOIA Request 97-473 ML18030A0971998-02-0202 February 1998 Forwards Proprietary Response to RAI Re Proposed License Amend 209 to TS Supporting Cycle 11 Reload.Proprietary Info Withheld,Per 10CFR2.790 ML20203G6071998-01-26026 January 1998 Forwards Redacted Version of Pp&L,Inc Corporate Auditings Interim Rept 739459-97,dtd 971015 & Affidavit Pursuant to 10CFR2.790 Justifying That Redacted Portions Be Withheld from Public Disclosure.Without Rept IR 05000387/19970031998-01-0606 January 1998 Provides Updated Response to Violations Noted in Insp Repts 50-387/97-03 & 50-388/97-03.Corrective Actions:Util Currently Scheduling Issuance of All Procedural Revs by End of First Quarter 1998 ML18017A2931998-01-0606 January 1998 Provides Responses to Improved TS Section 3.8 Per 970324 NRC Rai.Schedule 980628 for Improved TS Implementation. Submittal of Revised Specifications Is Planned for Jan 1998 ML18030A4071998-01-0606 January 1998 Provides Updated Response to Violations Noted in Insp Repts 50-387/97-03 & 50-388/97-03.Corrective Actions:Util Currently Scheduling Issuance of All Procedural Revs by End of First Quarter 1998 PLA-4828, Expresses Appreciation for Support Received by Former Project Manager C Poslusny1997-12-29029 December 1997 Expresses Appreciation for Support Received by Former Project Manager C Poslusny IR 05000387/19970041997-12-22022 December 1997 Resolves Commitments Made in Response to NOV Issued As Part of NRC Insp Repts 50-387/97-04 & 50-388/97-04 Dtd 970805. Proposed FSAR QA Program Description Changes,Reason for Changes & Basis Included for Approval ML18026A4901997-12-22022 December 1997 Resolves Commitments Made in Response to NOV Issued as Part of NRC Insp Repts 50-387/97-04 & 50-388/97-04 Dtd 970805. Proposed FSAR QA Program Description Changes,Reason for Changes & Basis Included for Approval ML20203M5741997-12-0505 December 1997 FOIA Request for Copy of Latest OI Rept on Susquehanna Ses Including All Exhibits & for Any Other Communication Between NRC & Susquehanna Ses/Pp&L PLA-4818, Forwards Redacted Version of Pp&L,Inc Corporate Auditings Rept 739459-1-97,dtd 971201 & Affidavit Pursuant to 10CFR2.790 Justifying That Redacted Portions Be Withheld from Public Disclosure.Without Rept1997-12-0404 December 1997 Forwards Redacted Version of Pp&L,Inc Corporate Auditings Rept 739459-1-97,dtd 971201 & Affidavit Pursuant to 10CFR2.790 Justifying That Redacted Portions Be Withheld from Public Disclosure.Without Rept 1999-09-08
[Table view] Category:UTILITY TO NRC
MONTHYEARML18026A3941990-09-0101 September 1990 Requests Waiver of Compliance from Tech Spec 3.8.1.1 to Evaluate Increase in Action from 72 H to 15 Days Re Ac Sources Based on 900829 Borescopic Insp of Emergency Diesel Generator ML17157A2741990-08-0808 August 1990 Forwards Topical Rept PL-NF-90-001, Application of Reactor Analysis Methods for BWR Design & Analysis. IR 05000387/19900801990-08-0303 August 1990 Responds to Violations Noted in Insp Repts 50-387/90-80 & 50-388/90-80.Corrective Actions:Util Conducted Operator Training on How to Implement Eops If Suppression Chamber Pressure Not Available ML18030A0741990-08-0303 August 1990 Responds to Violations Noted in Insp Repts 50-387/90-80 & 50-388/90-80.Corrective Actions:Util Conducted Operator Training on How to Implement EOPs If Suppression Chamber Pressure Not Available ML18026A2351990-07-0202 July 1990 Forwards Application for Proposed Amend 132 to License NPF-14,revising Tech Spec to Support Cycle 6 Reload ML18030A0721990-06-19019 June 1990 Forwards Rev 1 to SEA-EE-183, Evaluation of Unit 1 Computer Class 1E - Non-Class 1E Interfaces & Rev 1 to SEA-EE-184, Evaluation of Unit 1 Annunciator Class 1E - Non-Class 1E Interfaces. ML18026A3931990-06-0707 June 1990 Requests NRC Approval to Install Mod at Plant Determined to Constitute Unreviewed Safety Question When Evaluated.Util Will Implement Administrative Controls to Ensure Larger Min Vol Met for Diesel E Prior to Tech Spec Change ML18030A3671990-05-14014 May 1990 Forwards Proprietary Conclusions of Investigation Re Two False Negative Analytical Results from Two Blind Spike Urine Samples.Investigation Satisfactorily Evaluated Samples. Encl Withheld (Ref 10CFR2.790) ML20043A2461990-05-11011 May 1990 Forwards Draft of Proposed Decommissioning Financial Assurance Plan,Per 10CFR50.33 & 50.75,for Review.Telcon Scheduled for 900515 to Discuss Comments ML18030A0711990-03-19019 March 1990 Responds to Questions Delineated in 900131 Ltr Re Diesel Generator Events That Occurred During Sept & Oct 1989.Draft Procedures for Proposed Intake Air Temp Test Program Transmitted to NRC on 900205.Revised Procedures Encl ML18017A1871990-02-15015 February 1990 Forwards Books 1 & 2 to, Unit 2 Third Refueling & Insp Outage;Outage Summary Rept. IR 05000387/19890331990-02-0505 February 1990 Responds to NRC 900105 Ltr Re Violations Noted in Insp Repts 50-387/89-33 & 50-388/89-31.Corrective Actions:Rhr Svc Water Pump 2P506B Remains in Inoperable Status Until Cause of Deviation Determined & Condition Corrected ML18030A0701990-02-0505 February 1990 Responds to NRC 900105 Ltr Re Violations Noted in Insp Repts 50-387/89-33 & 50-388/89-31.Corrective Actions:Rhr Svc Water Pump 2P506B Remains in Inoperable Status Until Cause of Deviation Determined & Condition Corrected ML18040A9601990-02-0202 February 1990 Forwards Schedules That Provide Details of Tasks Required to Complete Activities Re Diesel Generators & Advises of Plan to Have Spare Parts on Site in Timely Manner to Support Each Diesel Insp ML20006B4501990-01-25025 January 1990 Forwards Preliminary Scope & Schedule for Security Upgrade Project.Encl Withheld (Ref 10CFR73.21) ML17156B6031990-01-25025 January 1990 Forwards NPDES Discharge Monitoring Rept for Dec 1989 & State of Pa,Dept of Environ Resources Monthly Facility Rept Form (01-112).Noncompliances for Zinc on Cooling Tower Blowdown on 891228 & for Missed Sample Noted ML18040B2671990-01-0505 January 1990 Forwards Rev 0 to SEA-CW-037, Analysis of B & C 1989 Diesels Failure. Rept Details Util Analysis of Overpressurization Incidents Which Occurred in Sept & Oct 1989 of Diesel Generators ML18040B2651989-11-27027 November 1989 Forwards Response to Generic Ltr 89-21.Table of USIs for Which Technical Resolution Has Been Achieved Encl ML19325F1991989-11-0909 November 1989 Responds to Generic Ltr 89-07, Power Reactor Safeguards Contingency Planning for Surface Vehicle Bombs. Util Has Developed & Issued Procedure Which Includes Safeguards Contingency Planning Using Approach Noted in Generic Ltr ML19325D7411989-10-19019 October 1989 Forwards Application for Amends 126 & 77 to Licenses NPF-14 & NPF-22,respectively,requesting Emergency Temporary Relief from Certain Requirements of Tech Specs 3.2.2 on One Time Basis for Period of 3 Months ML19325C3771989-10-11011 October 1989 Forwards Change DD to Physical Security Plan.Change Withheld (Ref 10CFR73.21) ML18040B2581989-10-0202 October 1989 Forwards Final Response to Request for Addl Info Re Generic Ltr 88-01, NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping. Listed Items Included in Previous & Current Ref Responses ML18040A9441989-09-12012 September 1989 Responds to Remaining Questions Raised During NRC Insp of Training Programs.Training Procedure Re Technical Exam Bank Instrumentation & Control Training Exams.Health Physics Technicians Trained Re High Radiation Levels PLA-3251, Forwards Response to Regulatory Effectiveness Review Rept. Util Established Team to Evaluate Appropriate Scope for Planned Major Project to Upgrade Security.Scope of Project to Be Finalized & Approved in Nov 1989.Response Withheld1989-08-31031 August 1989 Forwards Response to Regulatory Effectiveness Review Rept. Util Established Team to Evaluate Appropriate Scope for Planned Major Project to Upgrade Security.Scope of Project to Be Finalized & Approved in Nov 1989.Response Withheld ML18040A9421989-08-22022 August 1989 Requests Concurrence W/Scheduling of 1990 Annual NRC Observed Emergency Preparedness Exercise at Plant on 900502. Concurrence Requested by 890930 ML18040B2531989-08-10010 August 1989 Discusses Insp of Operational Status of Emergency Preparedness Program.Susquehanna Review Committee 1987 & 1988 Emergency Plan Audits Encl W/Other Supporting Documentation ML20246A0191989-06-30030 June 1989 Submits Comments on Containment Performance Improvement Program (Cpi).Believes Program Will Be Generic Approach to Improving Containment Performance During Severe Accident PLA-3218, Submits Info Re Settlement Agreements for Discrimination Matters Arising Under Energy Reorganization Act of 1974. No Settlements Made Between Licensee & Any Employees in Section 210 Proceedings1989-06-27027 June 1989 Submits Info Re Settlement Agreements for Discrimination Matters Arising Under Energy Reorganization Act of 1974. No Settlements Made Between Licensee & Any Employees in Section 210 Proceedings ML18040B2501989-06-20020 June 1989 Forwards Summary Rept of Safety Evaluations Approved During 1988.Changes Include Backseating Control Box to Electrically Backset HV-202168 to Reduce Steam Leakage & Rerouting Condensate Supply Line to Main Condenser Keepfill PLA-3194, Forwards Change CC to Physical Security Plan.Change Withheld (Ref 10CFR73.21)1989-05-30030 May 1989 Forwards Change CC to Physical Security Plan.Change Withheld (Ref 10CFR73.21) ML18040A9301989-04-28028 April 1989 Responds to 890322 Request for Addl Info Re Plant Fire Protection Review Rept.Analysis of Circuits Having Potential for Being Impacted by Fire Resulting in Multiple High Impedence Faults Will Be Completed by Last Quarter 1989 ML18040B2441989-04-14014 April 1989 Forwards Application for Amends to Licenses NPF-14 & NPF-22, Resulting from Mods Performed to Essential Svc Water Sys,Per 10CFR50,App R,Consisting of Proposed Amends 23 & 70 PLA-3173, Forwards Change Bb to Physical Security Plan.Encl Withheld (Ref 10CFR73.21)1989-03-22022 March 1989 Forwards Change Bb to Physical Security Plan.Encl Withheld (Ref 10CFR73.21) ML18040A9271989-03-10010 March 1989 Forwards Rev 6 to ISI-T-100.0 for Unit 1 & Rev 3 to ISI-T-200.0 for Unit 2 Pump & Valve Inservice Insp Testing Program. ML18040A9261989-03-0707 March 1989 Discusses Util Position Re Completion & Implementation of NRC Requested Actions Specified in Suppl 1 to NRC Bulletin 88-007, Power Oscillations in Bwrs. ML17156B0131989-02-0202 February 1989 Forwards Proprietary Rept & Affidavit Supporting Proposed Amend 119 to License NPF-14 ML17156A9771988-12-15015 December 1988 Forwards Rev 11 to Susquehanna Units 1 & 2 Emergency Plan ML18040B2331988-11-22022 November 1988 Forwards Listed Addl Info Re Plant Fire Protection Review rept.W/16 Oversize Drawings ML17156A9211988-11-0909 November 1988 Forwards Proprietary GE Rept, Tech Spec Improvement Analysis for Reactor Protection Sys for Susquehanna Steam Electric Station,Units 1 & 2. Rept Withheld (Ref 10CFR2.790) ML18040A9111988-09-15015 September 1988 Informs That Mods Re Fire Barrier Upgrades,Hvac Fan Switches,Ct Secondaries & Raceway Wrapping Completed Except as Listed ML18040A9101988-08-10010 August 1988 Forwards Application for Amend to License NPF-14,extending Operation During Cycle 4 W/One Circulation Loop Out of Svc. Fee Paid ML18040B2221988-08-10010 August 1988 Responds to Generic Ltr 88-01, NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping. Staff Position on Matls, Water Chemistry,Crack Evaluation & Repair Criteria & Insp Schedules Among Topics Addressed.Flaw Evaluations Encl ML18040B2201988-07-27027 July 1988 Forwards Comments to Each Specific SALP Category,Per 880707 Meeting W/Nrc.Presentations from Meeting Also Encl ML18040A9061988-07-21021 July 1988 Forwards GE Rept, Susquehanna Unit 1 CRD Housing Cap Screw Corrosion. Rept Completes Action on Item ML18040A9031988-07-19019 July 1988 Forwards Approved Version of Topical Rept PL-NF-87-001-A, Qualification of Steady State Core Physics Methods for BWR Design & Analysis, Per 880428 Ltr ML18040A9041988-07-19019 July 1988 Forwards Rev 39 to Updated FSAR for Susquehanna Steam Electric Station Units 1 & 2 Per 10CFR50.71 ML18040B2131988-06-24024 June 1988 Forwards 1987 Annual Rept for Allegheny Electric Cooperative,Inc ML18040A9021988-06-15015 June 1988 Provides Revised Response to NRC 871130 Ltr Re Violations Noted in Insp Repts 50-387/87-19 & 50-388/87-19.Corrective Actions:Incumbent Will Be Removed from Emergency Plan Position of Radiation Protection Coordinator PLA-3028, Responds to Suppl 1 to Bulletin 85-003, Motor-Operated Valve Common Mode Failures During Plant Transients Due to Improper Switch Settings. No Revs to Design Review for Original Bulletin Required as Result of Suppl1988-05-31031 May 1988 Responds to Suppl 1 to Bulletin 85-003, Motor-Operated Valve Common Mode Failures During Plant Transients Due to Improper Switch Settings. No Revs to Design Review for Original Bulletin Required as Result of Suppl ML18040A8691988-04-0606 April 1988 Forwards Application for Proposed Amends 110 & 61 to Licenses NPF-14 & NPF-22,respectively,revising Tech Specs Re Radiation Monitoring Instrumentation.Fee Paid 1990-09-01
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E~na/n uce ? & f Q Pennsylvania Pow;r & Light Company Two North Ninth Street
- 2151770 5151 Harold W. Kaiser Vice President-Nuclear Operations 215/770-7502 NOV 151985 Mr. Harry B. Kister, Chief Project Branch No. 1 Division of Reactor Projects U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King cf Prussia, PA 19406 !
.SUSQUDIANNA STEAM ELECTRIC STATION NRC INSPECTION REPORTS 50-387/85-28 AND 50-388/85-23 ER 100450 FILE 841-04 Docket Nos. 50-387 .
PIl-2553 50-388 -
Dear Mr. Kister:
This letter provides PP&L's res;fonse to your letter of October 17, 1985 which forsarded NRC Region I Combined Inspection Reports 50-387/85-28 and 50-388/Q-23 with Appendix A, Notice of Violation, m Your Notice advised that PP&L was to submit a written reply within thirty (30) days of the date of the letter. We trust'that the Comz::ission will find the attached response acceptable.
Very truly yours, b/ / '
O, H. N. eiser Vice President-Nuclear Operations Attachment cc: Mr. R. H. Jacobs - NRC Senior Resident Inspector Ma. M. J. Campagnone - FRC (NRR Project ManaRer) 8607010303 860625 PDR ADOCK 05000387 G PDR
RESPONSE TU N0flCE OF VIOLATION Violation (337/85-28-03; 388/85--23-02)
Technical Specifications 4.3.2.1 and 4.3.3.1 require the performance of monthly Channel Functional Tests on the HPCI isolation and actuation channels.
Technical Specification Definition 1.6 specifies that the Channel Punctional Test uhall test the entire channel. !
Contrary to the above, surveillance procedures SI-152-203, SI-152-201, SI-152-211, and SI-180-205, which implement this requirement on the HPCI steam line delta pressure channels, HPCI steam supply pressure channels, HPCI turbine exhaust diaphragm pressure channels and the HPCI high reactor vessel level trip channals, respectively, fail to test the entire channel. 'The corresponding Unit 2 surveillance procedures also fail to test the entire channel.
Response
It is PP&L's p3sition that testing in accordance with the referenced surveillance procedures reprananta a valid inte.rpretation of Technical Specification requirements, rather than noncompliance. It is therefore requented that the Notice of Violation be withdrawn. , ,
. 1 The Technica' Specifications applicable to trip functions referenced in the Notice are as follows:
HPCI Stean Line Delta-Pressure-High 4.3.2.1, Table 4.3.2.1-1, function 6'."a HPCI Steam Supply Pressure-Low 4.3.2.1, Table 4.3.2.1-1, function 6.b HPCI Turbine Exhaust Diaphragu 4.3.2.1, Table 4.3.2.1-1, function 6.c Pressure-High Reactor vessel Water Level- 4.3.3.1. Table 4.3.3.1-1, function 3.e High, Level 8 Each of these rec,uires performance of a CHANNEL FUNCTIONAL TEST in accordance with Definition 1.6 on a frequency of at leaut once per 31 days. The SSES Technical Specifications provides the following definition for CHANNEL FUNCTIONAL TEST:
"A CHANNEL FTNCTIONAL TEST shall be:
- e. Analog Channels - the injection of a almulated eignal into the channel as close to the sensor as practicable to verify OPFRABILITY including alarm and/or trip functions and channel failure trips.
- t. Bistable channels - the injection of a simulated signal into the sensor to verify OPERABILITY including alarm and/or trip functions.
The CHANNEL FUNCTIONAL TEST may be performed by any series of esquential, overlapping or total channal aceps such that the entire channel is tested."
The Technical Specifications do not provide a definition of the term
" chancel".
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The standarda do not utilise the word " instrumentation" in the definition because their use of the channel concept is not limited to l ins t rumentation. In the standards usage, the protection channel consists i of " components and modules".
While instrumentation is included.
" components and modules" also include wires, transietors, switches, !
motors, relays, solenoids, pipes, fittings, pumps. tanks. valves or other l identifiable devices or pieces of equipment. The channel as defined in the standards is a subset of a protection system which provides protective action signals to the protective action system. It is not limited to an
" instrumentation channel" as called out in Technical Specifications.
- 2. The inspection report notes that "the associated relays and contacts (i.e.
those that would be tested under the IEEE standards definition of
" channel") are tested during the logic system functional test". The l Technical Specification definition of LOGIC SYSTEM FUNCTIONAL TEST (LSET) is as follows:
"A LOGIC SYSTEM FUNCTIONAL TEST shall be a test of all logic conponents, i.e. all relays and contacts. all trip units, solid state logic elements. . .
etc. of a logic circuit, from sensor through and including the actuated device. to verify OPERABILITY. The LOGIC SYSTEM FUNCTIONAL TEST may be
- l parformed by any series of sequential, overlapping or total system stspa such that the entire logic system is tested."
This requirement establishes the testing frequency at IS months for operation of hardware downstream of the " channel", such as relays, contacts, links, conductors, and final elements. The "associatad relays and contacts" called out in the inspection report are precisely the same type of hardware included in an LSFT. It is not reasonable to assume that by arbitrary definition the frequency requirement for a small group of thesa that logic components should be greater; therefore it is not apparent the ef fectiveness of the surveillance program is in any way degraded due to the scope of testing employed at SSES.
3.
IE Infornation Notice 84-37 discusses mitigation of the potentially adverse safety impact of using jumpers and lifting leads in support of survoillance testing.
~
Uhile the Susquehanna design does ensure that safety related instrumentation can be practically tested during plant operation, the same cannot be said for interposing relays which are part of the logic circuitry. To perfonn CHANNEL FUNCTIONAL TESTS in this case, some circuits would require disabling via measures such as lifted leads or booted contacts to prevent an actuation from occurring during testing of the interposing relay. An example of this situation is found with the HFCI Steam Line Delta-Pressure-High circuits. Actuation of the interposing relay along with the individual instrument would cause a - 5 system isolation.
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4.
ANSI /IEEE Standard 338-1977 states that a functional test "... should not be lengthy nor require extensive test equipment or personnel."
In certain cases, while verification of relay actuation is possible, an unnecessary burden would be imposed on plant resources. An additional individual would be required for each test to monitor components in a separate location. Civan the large number of CHANNEL FUNCTIONAL TESTS required and the frequency at which they are performed, the additional resource commitmont is very significant.
The factors described above provided the reasoning for using the following definition for where a channel ends as opposed to the IEEE standards definition:
"For the purpose of channel functional testing, the end of the channel is tha input node (s) of the coil of the actuated relay (a) which catcr into <
combinational logic with logic provided by other channels."
This definition requires testing of all alarm and/or trip functions of the ..
channel, i.e.,
it ensures that the sensor is intact and that the channel generates appropriate bistable action (s). It therefore satisfies the ~
requirements of the Technical Specifications. Furthermore, the definition minimi=es equipment, personnel and time in test status - souething that application of the IEEE definition vould fail to accomplish.
It sh'ould be noted that the position adopted by PP&L, while permitting limitations of testing scope for situations as described above, does not mean that testing is limited to verification of instrument actuation in all cases.
Rather, the policy states that instrumentation channel testing vill extend into logic circuitry as far as practical (typically to a point where ~
annunciator actuation vill indicate a successful test). This approach provides a significant sample of logic components which are tested at CHANNEL FUNCTIONAL TEST f requencies. Should generic problems be identified with a particular type cf co=ponent, corrective actions would address all applicabic devices.
(
PP&L telieves that this issue arises from the lack of a specific definition of the term " channel" in the Technical Specifications. We have adopted a definition of this term which is consistent with the Technical Specification application of " channel" to require testing of instrumentation channels. We recognize that several industry standarda utilize the same term " channel" in a i similar application. However, their usage also incorporates the concept of a logic channel and hence is not appropriate for this discussion. PP&L has extensively reviewed its definition in light of its relationship to Technical Specification requirements, and has determined it to be valid.
l In conclusion, PP&L requests that the Notice of Violation be withdrawn due to the lack of Technical Specification definition of the term " channel". Our interpretation did not degrade the safe operation of SSES (as mentioned
Page 5 previously reliability of the componente in question is ensured by the 18-month LSFT). However. due to the level of concern generated on this issue, we vill submit our definition of the term instrumentation channel for NRC reytev and approval as a change to the SSES Technical Specifications.
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...iiUTES PORC MEETING No.84-117 Date: May 25, 1984 F1#b
' e following eic constituted members a quorumwereat in allattendance times. at various times throughout the meeting Chairman: H. W. Keiser Member: G. L. Merrill (A)
Member: D. J. Thompson Member: C. M. McClain (A)
Member: C. A. Smith Member: B. J. Veazie (A)
Secretary: C. M. McClain Member: B. J. Rarig (A)
Guests: F. T. Eisenhuth R_. C. Collier F. G. Butler F._S. Gruscavage K. C. Lionarons Su_bject of Review 1.
Procedures as required by Technical Specification 6.8 and changes thereto, and any other proposed procedures or changes thereto, as determined by the Superintendent of Plant-Susquehanna to af fect nuclear safety.
A.
The following procedures were recommended for approval and do not constitute an unreviewed safety question:
1.
AD-QA-406, Rev. I, Operating Experience Review Assessment a.
Add to action taken list " requires procedure revision" and
" requires-work authorization".
- 2. AD-QA-520, Rev. 2A, Station Welding Program 3.
EO_100-009, Rev._1, Plant Shutdown from Outside Control Room 4
E0-200-009, Rev. 1, Plant Shutdown from Outside Control Room 5.
EO-100-014, Rev. O, Anticipated Transient with Failure to Scram (ATWS)
- 6. GO-100-002, Rev. 1, Plant Startup and Heatup 7.
GO-200-002, Rev. O, Plant Startup and Heatup
- 8. GO-100-003, Rev. 1. Power Operation
- 9. GO-200-003, Rev. 1, Power Operation
- a. Correct the power flow map.
~~
- 3. Proposed tests and experiments that affect nuclear safety A. The following proposed tests were recommended for approval and do not constitute an unreviewed safety question:
- 1. ST 27.0, Rev. 5, Turbine Trip and Generator Load Rejection
- 2. ST 27.1, Rev. 4. Turbine Trip
- 3. ST 27.2, Rev. 5, High Power Generator load Rejection 8.
The following Startup Test Change Notices were recommended for approval and do not constitute an unreviewed safety question:
- 1. STCN 036
- 2. STCN 042 C.
The following Test Exception Reports were recommended for approval and do not constitute an unreviewed safety question:
- 1. TER 002
- 2. TER 003
- 3. TER 004 4 TER 005
- 5. TER 006
- 4. Items of Significance:
A. The POR:
reviewed a request to accept data taken from other tests and other W.A.'s in lieu of performing surveillances. Upon review of the data, PORC recommended that the data be accepted as meeting ~~the intent of tne following surveillance:
.... l. SI-288-204 B.
The PORC reviewed a position paper by F. G. Butler on Scope _ of Testing
- Cnannel Functional _ Tests. Discussion on the paper centered around j
/
the definition of " Entire Channel". F. T. Eisenhuth refuted the position taken in the paper and presented excerpts from the
+
,' /
Surveillance Program Task Force Position Paper on Channel Functional ,
Tests. The committee voted 3 to 2 to accept Mr. Butler's position as j l 1 the official SSES position. Attached to these mirutes are copies of f both the accepted postion paper and the dissenting opinion letter submitted by Messrs. Eisenhuth and McClain.
_ ~
C. The PORC reviewed the following documents, but did not recommend their approval:
- 1. OP-TY-013, Rev. 0 - needs H. J. Palmer signature.
- 2. PMR 83-423 - PORC will not approve the Safety Evaluation to change the drawing.
- 3. PMR 83-424 - PORC will not approve the Safety Evaluation to change the drawing.
Submitted:
C. M. McClain Approved: [D. [IJ. Thompion
%.<l e t Approved:
]&
H. W. Keiser ' '
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Hay 23, 1984 PORC CHAIRMAN - SSES SUSQUZHANNA STEAM ELECTRIC STATION SCOPE OF TESTING - CHANNEL FUNCTIONAL TESTS We have been requested to provide a position paper regarding our interpretation of the extent of testing necessary to fulfill Technical Specification requirements which involve " Channel -
Functional Tests" (CFT's). The issue which prompted this request deals with the interpretation of where the " entire channel" ends.
The definition must adequately address the Tech Spec definition for CPT's while being flexible enough to provide universal application to the many plant systems in a reasonable manner.
We propose to define the "end of the channel" 'or the purpose of channel functional testing to be the input node (s) of the coil of the actuated relay (s) which enter into combinational logic with logic provided by other channels. This definition sets a minimum requirement
- which provides adequate channel testing .nd, in several ca'es, s fulfills requirements without excessive personnel or testing apparatus.
Further testing involving operational m:1- .
fication of actuating relays and downstream combinational logic is accomplished by Logic System Functional Testing (LSFT) when re-
.$E quired by Technical Specifications. We helieve this policy to be l in step with the intent of testing required by Tech Specs while complying with testing description of IEEE 338-1977 and meeting the recommendations of NRC IE Inf Notice No. 84-37.
I P E N N $ Y L VA NI A POWE 4 & LIG H T COMPANY '
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May 23, 1984 CHANNEL FUNCTIONAL TESTS Page 2 The minimum requirement, as stated above, tests all alarm and/or trip functions of the channel while requiring a minimum of personnel and equipment this minimizing the time required for the tested equipment to be in the abnormal "in test status". The CFT's intent is to ensure that the sensor is in tact and the channel generates appropriate bistable action (s). The effect of imposing the minimum requirements proposed above is to employ the LSFT to verify operation of downstream hardware such as relays. links, conductors and final elements. However, of these devices are precisely the same type of hardware already included in existing LSFT's, thus no reduction in the effectiveness of the surveillance program is apparent.
.^
It shculd be noted that the effect of imposing the above requirecept is that in a few cases, where only " blind" bistables are utilized, the -CT u@end--at the -input nodas of these devices and actuation
~
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of devices downstream of the input nodes will not be checked by the CFT. ,
In all other cases, it is our policy to check channel bistable action as far as practicable i.e.,
if a plant response (annunciator, valve movement, etc.) results from the single channel action, this response is verified by the CFT.
It is recommended that the above definition be adopted as policy gi fo r CFT's .
If it is desirable to extend the scope of testing beyond -
that proposed, it is suggested that in each case where blind bistables are in evidence, modifications be ende to achieve compliance with the
- general guidelines for functional tests (i.e. minimum equipment, .'
- personnel, time in test status). To impose the mora " conservative" ~
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May 23, 1984 CHANNEL FUNCTIONAL TESTS Page 3 requirement at this time would, in our opinion, create undue risk and exposure to plant safety and reliability by requiring unnec-essarily complicated testing on a frequent basis.
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F. G. Butler I6C/C Supervisor FGB/ eat An exception is taken when interposing logic (i.e. mode switch) prevents the signal from going this far in the channel.
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P E NNS YL VA NI A POWE R & LIGHT COMPANY
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PORC CHAIPJfAN - SSES SUSQUEHANNA STEAM ELECTRIC STATION SCOPE OF TESTINC - CHANNEL FUNCTIONAL TESTS In PORC Meeting No.84-117, hald on May,25, 1984, the committee considered a position paper (attached) from F.G. Butler regarding required scope of
, surveillance testing for Channel Functional Tests (CFT) . The committee l recommended acceptance of this position, with dissenting opinions fr'om the undersigned, i
The basis for dissent involves the requirement contained in Technical Specifications. Definition 1.6 that a CFT must be conducted " . . . such that the entire channel is tested." Technical Specifications do not provide a definition for a channel, but IEEE Std. 603-1980 and ANSI /IEEE Std.
279-1971 contain the following:
" Channel: An arrangement of components and modules as required to generate a single protective action signal when required by a gen-erating station condition. A channel loses 'its identity where single action signals are combined".
At issue is the application of this definition of Channel to specific circuitry installed at SSES. '
i In practical usage, the definition "end of the channel" adopted in the paper means that in some cases testing will extend only to the switch contact at the instrument rack. Since additional component (s) in the circuitry (nor= ally relays) actuate only in response to the " single protective action signal" genecated by the sensor associated with the instrument bistable, it is believed that these component (s) are part of the Channel in accord with the IEEE definition. Taking this interpretation. the testing des-i cribed will not meet Technical Specification requirements. Support for this interpretation can be found in a change being made to Specification 4.1.3.1.4 b (see Proposed Amendment No. 43 to the Unit I Licens9) calling out a check of switch actuation rather than a CFT. This change is being made to avoid having to test beyond the instrument switch contact in the specific case of the Scram Discharge Volume float level switches.
The committee heard discussion that testing which included verification of these additional components would violate the dictates 'of ANSI /IEEE Std. 338-1977. This standard states that a functional test " . . . should not be lengthy nor require extensive test equipment or personnel." Problems arise due to lack of annunciation or status lights associated with the subject relays, necessitating introduction of test equipment or jumpers into relay cabinets. The undersigned agree that with present designs, this " keep it simple" test objective cannot be fully achieved. Measures taken in pursuit l of this goal are strongly supported. However, the guidance of IEEE standards I
. I PENNSYLVANI A POWE A & tsGHT ' COMPANY j l
a . e does not supercede direct requirements of Technical Specifications and any conflicts must be resolved in favor of Technical Specifications.
The position taken by the undersigned is in conformance to that adopted by the Surveillance Program Task Force in their Issue No. 2 (see PLIS-13997 and expanded discussion in PLIS-13301) . It is also noted that this is perceived to be a regulatory compliance issue rather than a nuclear safety issue. The NRC, through its logic System Functional Test require-ments, has established that 18 months is the appropriate testing interval for traditional logic components such as relays, switches, etc. No evidence has been presented to suggest that.18 month testing is inappropriate, so the testing program adopted by Mr. Butler appears to satisfy reliability assurance aspects.
It is felt that proper resolution of this issue should take one of two courses. Either:
a.
Testing =cthods be revised to include verification of relay act-uation for those e.oeponents which actuate response to a single Technical Specification required signal. To meet concerns re- .
lating to ANSI /IEEE Std. 338-1977 guidance. it is recer, ended that design codification be expedited to provide approp ste status indicators which vill facilitate verifications. Or, b.
Submit a revision to Definition 1.6 to define a CFT as a verification of switch actuation to f or=alize the interpretation currently being accepted by PORC.
f h 6 $i F.T. Eisenhuth b
C.M. McClain
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