ML20112H085
| ML20112H085 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/29/1985 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| CON-#285-355 OL, NUDOCS 8504020124 | |
| Download: ML20112H085 (6) | |
Text
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W PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHI A, PA.19101 JOHN S. KEMPER VIC E PR ESID E NT theemss ReseG AND RES. ARCH Docket No.: 50-352 FOL No.:
NPF-27 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.
20555
SUBJECT:
Limerick Generating Station, Unit 1 Safety Parameter Display System
REFERENCE:
Letter, A. Schwencer to E. G. Bauer, Jr.,
dated March 27, 1985 FILE:
GOVT l-1 (NRC)
Dear Mr. Denton:
In response to the reference letter, it is hereby requested that the schedular aspect of License Condition 2.C.8.(b) be modified to provide that the Safety Parameter Display System (SPDS) shall be initially operable within 30 days after the completion of the 100-Hour Warranty Run at 100 percent of rated power (3293 MWth).
The requested change to the License Condition is to permit the completion of the SPDS validation process which was reviewed and approved in Section 18.2.7 of NUREG-0991, SER Supplement 3.
The validation process must be completed prior to releasing the SPDS for use by the Control Room operators.
The final activities in the SPDS validation process must be performed during the Power Ascension Test Program at power levels up to and including 100 percent of rated power.
This activity involves testing the parameter validation algorithms and composed point logics at defined plant power levels.
This work includes refining system constants and performing reasonableness checks which compare the SPDS display data with the hardwired plant 03 g4020124850329 g0 p
ADOCK 05000352 1
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Mr. Harold R. Denton March 29, 1985 Page 2 instrumentation.
Because the plant is currently restrained to 5 percent of rated power (165 MWth), we have not been able to perform the validation testing required to make the SPDS available in conformance with the License Condition.
The proposed License Condition ties the initial operability of the SPDS to a definitive milestone in the plant Power Ascension Test Program.
This milestone, which is 30 days after the completion of the 100-Hour Warranty Run at 100 percent of rated power, will permit the completion of the validation process and the correction of any discrepancies so that the SPDS can be released for use by the operators.
For the purposes of providing a technical definition of initial operability to meet the License Condition, we consider that the SPDS will be initally operable when (1) the SPDS displays are available for callup by the Control Room Operator on the ERFDS CRT's and (2) all validation testing required by the General Electric Verification and validation Program is successfully completed to the extent that the SPDS displays can be released for operator use.
It should be noted that the Radioactivity Control Critical Safety Function of the SPDS, which is being provided by the Radiation and Meteorological Monitoring System (RMMS), is presently operable and available for operator use.
The use of RMMS for this function was reviewed and approved by the Staff in
-Section 18.2.3 of NUREG-0991, SER Supplement 3.
Supplement 1 to NUREG-0737 (Generic Letter No. 82-33, December 17, 1982) requires that licensees develop, in parallel with the SPDS, procedures which describe the timely and correct safety status assessment of the plant when the SPDS is not available.
Supplement 1 to NUREG-0737 also requires that the operators be trained to respond to accident conditions without the SPDS available.
These requirements have been met for Limerick Generating Station by implementing the procedures and operator training described below.
The BWR Owners' Group symptomatic emergency procedures have been implemented by developing the symptom oriented Limerick Transient Response Implementation Plan (TRIP's).
The safety status of the plant can be assessed from the parameters which constitute the entry conditions into these procedures.
The TRIP's form the basis for primary operator actions during severe transients.
All operators licensed at Limerick have been thoroughly trained in the use of the TRIP's.
Limerick operators have been taught to cope with severe transients utilizing the TRIP's in
.Mr. Harold R. Denton March 29, 1985 Page 3 4
1 conjunction with Reg. Guide 1.97 instrumentation without the J
benefit of SPDS.
In addition, all analog Control Room Teg. Guide i
l.97 instrumentation has received special yellow high3?1hting to enable the operator to identify it for use in implementation of l
the TRIP's.
Use of the Reg. Guide 1.97 instrumentation for primary indication was stressed in the operator's simulator training where the instruments are similarly marked.
All of the parameters presented on the SPDS displays are presently available in the control Room for operator use via qualified, hardwired indicators.
These indicators are conveniently located in the Control Room and readily accessible to the reactor operator.
The analog indicators are also 1
highlighted with yellow lines to allow the operator to distinguish their location.
These indicators provide the information that is needed to quickly and reliably assess the safety status of the plant.
The Limerick Transient Response Implementation Plan i.
emergency procedures (TRIP's) are written so that the operator uses the hardwired instruments described in the preceding paragraph to determine 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 TRIP's beyond 1
that provided by the hardwired instruments.
The operators have been trained in the simulator to respond to transient and emergency conditions without the SPDS being available.
Operator actions are not dependent on the availability of the SPDS displays.
Based upon the foregoing, we have concluded that the l
delay in availability of the SPDS displays, as proposed herein, does not involve an unreviewed safety question.
Further, since the proposed modification to the license does not involve a significant increase in the probability or consequences of an accident previously evaluated, or a significant reduction in a safety margin, or create the possibility of a new or different kind of accident than those previously evaluated, we have concluded that no significant hazards considerations are involved with this request.
Mr. Harold R. Denton March 29, 1985 Page 4 The activities remaining to be completed which are required to demonstrate full operability of the SPDS are divided into two areas: (1) those activities which can be completed independent of plant operating status, and (2) those activities which must be completed at various power levels.
For those activities which can be performed independent of plant operating status, the following preliminary schedule has been determined.
The dates may vary depending on the test program results.
Activity Scheduled Completion
.o Installation of Limerick Unique 5/6/85 RTAD Composed Points and Constants o
Validate RTAD Constants and 6/1/85 Composed Point Data Base o
Simulated Test of Parameter 7/15/85 Validation Algorithms o
Prerequisites for Reasonableness 8/1/85 Checks at Power Complete o
Resolve Simulated Test Discrepancies 9/2/85 Those activities which must be performed with the plant at various power levels consist of the following:
o Test parameter validation algorithms.
o Refine system data constants.
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o Perform SPDS reasonableness checks against Control Room indicators.
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i m
Mr. IIarold R. Denton March 29, 1985 Page 5 These activities will be completed prior to declaring the SPDS initially operable in accordance with License Condition 2.C. 8. (b).
Should you have any questions or require any additional information, please do not hesitate to call.
Sinchrely, S*
f cc:
Dr. T. E. Murley, Administrator J. T. Wiggins, Resident Inspector J. Rutberg, Esq.
See Attached Service List f
CG NONWEALTH OF PENNSYLVANIA ss.
COINIY OF PHILADELPlilA J. S. Kemper, being first duly sworn, deposes and says:
'Ihat he is Vice President of Philadelphia Electric Company, the Applicant herein; that he has read the foregoing letter relating to the status of the Safety Parameter Display System and the request for modification of License Condition 2.C.8.(b) and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.
MT }d
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Vice PresMent Subscribed and sworn to beforemethis8 day of March, 1985.
Notiry Public PATRICIA D. SCHOLE Notary Publ.c. Ph:bdelphia. PNiadit;tia Co.
My Commusion bpires febmary 10,1986
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