A02302, Comments on Draft Evaluation of SEP Topic VI-7.A.3, ECCS Actuation Sys
| ML20054D182 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 04/14/1982 |
| From: | Counsil W CONNECTICUT YANKEE ATOMIC POWER CO. |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| References | |
| TASK-06-07.A3, TASK-6-7.A3, TASK-RR A02302, A2302, NUDOCS 8204220418 | |
| Download: ML20054D182 (3) | |
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CONNECTICUT YANKEE ATOMIC POWER COMPANY BERLIN. CO N N ECTIC U T P.O. BOX 270 H ARTFORD, CONN ECTICUT 08101 April 14, 1982 T E L E asecas t mos-see es" "I
Docket No. 50-213 g%(7 g q
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NCi RECmyEO Director of Nuclear Reactor Regulation APR 2 21982n-13 Attn:
Mr. Dennis M. Crutchfield, Chief Operating Reactors Branch #5
"$$yf U. S. Nuclear Regulatory Commission
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Washington, DC 20555
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References:
(1) Letter, D. M. Crutchfield to W. G. Counsil, dated January 11, 1982 (2) Letter, D. G. Eisenhut to All Light Water Reactor Licensees, dated February 23, 1980 Gentlemen:
HADDAM NECK PLANT SEP TOPIC /I-7.A.3 ECCS ACTION SYSTEM Via Reference (1) the Staff forwarded the draf t evaluation of SEP Topic VI-7.A.3, ECCS Actuation System, for the Haddam Neck Plant.
Connecticut Yankee Atomic Power Company (CYAPCO) has reviewed Reference (1) and offers the following cmments.
SECTION 3.2.b.2 All high pressure safety injection valves are no longer cycled under no-flow conditions on a monthly basis. They are now cycled during cold shutdown conditions. The change in frequency of tes-ting was a result of CYAPCO's review of Reference (2).
SECTION 3.2.b.4 Manual testing of all actuated components to demonstrate operabil-ity is not done monthly but on the frequency summarized in Sections 3.2.b.1, 3.2.b.2 and 3.2.b.3.
SECTION 4.1 The second paragraph should be reworded to read:
" Charging system operation is initiated automatically when the Safety Injection System is actuated and offsite power is available.
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Upon receipt of the initiating signal, the suction of the two centrifugal charging pumps is automatically transferred from the Volume Control Tank to the Refueling Water Storage Tank and borated water is delivered through the charging line to the cold Icg of loop 2.
The charging pumps may be manually started on emergency power if offsite power is not available.
Injection of borated water will continue until the conditions for recirculation flow are established, at which time the operator will terminate safety injection flow and initiate recirculation flow.
SECTION 4.1 (last paragraph) AND 4.2 (last paragraph)
The charging system injects borated watcr into the RCS through Loop 2 cold leg only.
SECTION 4.2.b.1 Although Reference (1) did not specify a frequency of testing, each of the charging pumps is individually tested on a monthly basis, section 4.2.b.2 The motor operated valves on the discharge of the charging line to Loop 2 cold leg are cycled on a quarterly, not monthly basis.
SECTION 4.2.b.3 Manual testing of all actuated components to demonstrate opera-bility is not done monthly but with the frequency summarized in Sections 4.2.b.1 and 4.2.b.2.
SECTION 5.1 (Second paragraph)
Performance of the Core Deluge System is based on operation of one of two Low Pressure Safety Injection pumps, not on operation of one of two Residual Heat Removal Pumps. However, the RHR pumps are ca-pable of supplying water via core deluge after the Reactor Coolant System pressure ii reduced below 145 psig. These pumps can also take suction from the Refueling Water Storage Tank.
SECTION 5.2.b.2 All low pressure safety injection valves are no longer cycled under no-flow conditions on a monthly basis. They are now cycled during cold shutdown conditions. The change in frequency of testing was a result of CYAPCO's review of Reference (2).
SECTION 5.2.b.4 Manual testing of all actuated components to demonstrate opera-bility is not done monthly, but with the frequency summarized in Sections 5.2.b.1, 5.2.b.2 and 5.2.b.3.
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3 SECTION 6.0.1 This paragraph should be revised to read as follows:
"Because system testing from manual or automatic actuation devices to establish system flow during reactor operation cannot be accom-plished due to system design pressure and/or it would cause injec-tion of borated water into the reactor, testing of the High and Low Pressure Safety Injection and charging systems during reactor operation is deemed impractical."
CYAPCO has concluded that the balance of the Staff's evaluation is correct. We trust the Staff will appropriately incorporate these com-ments into a re. vised evaluation for this SEP topic.
Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY
/, 16 W.'G.
Counsil Senior Vice President i