ML19256G256

Responds to NRC 791214 Telcon Requesting Info Re Implementation of short-term Lessons Learned Task Force Requirements by 800101.Discusses Proposed Schedule & Revisions

ML19256G256
Person / Time
Site:	Peach Bottom
Issue date:	12/21/1979
From:	Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Harold Denton Office of Nuclear Reactor Regulation
References
RTR-NUREG-0578, RTR-NUREG-578 NUDOCS 7912280561
Download: ML19256G256 (5)

Text

PHILADELPHIA ELECTRIC COMPANY 23O1 M ARKET STREET P.O BOX 8699 PHILADELPHI A. PA.19101 SHIEwDS L. DALTHOFF '

ELEctnic Pm o tom December 21, 1979 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

I mp le me nt a t i on of Category A Lessons Learned Requirements NUREG 0578 - Peach Bottom Atomic Power Station

Reference:

(1) Letter dated October 17, 1979, from S. L. Daltroff, Philadelphia Electric Company, to D. G. Eisenhut, Nuclear Regulatory Commission (2) Letter dated November 21, 1979, from S. L. Daltroff, Philadelphia Electric Company to H. R. Denton, Nuclear Regulatory Commission

Dear Mr. Denton:

This letter is in response to a telephone request received from the Nuclear Regulatory Commission, Branch 3 Project Manager f or Peach B ottom Atomic Power S tation on December 14, 1979, to identif y Philadelphia Elect ric Company 's capabilities of implementing NUREG 0578 category A Short Term Lessons Learned requirements by January 1, 1980. Our prop osed s chedule for implementing Lessons Learned requirements was previously provided in references (1) and (2) above. We have reviewed our p revious submittals and are making appropriate revisions as indicated below. All category A Lessons Learned requirements will be implemented on Peach Bottom No. 3 by January 1, 1980, and during the Peach Bottom No. 2 outage to commence on or before January 1,[oy}

g 1980, except as identified below. The category A items not j exp ected t o be complete by January 1, 1980, will be completed as gpp/o 3* BEARO arsu r 1654 081 F. shoPec i i L. 7IAdi D. '!ERLEX.L I n y f 19122no (&l

Mr. H. R. Denton Page 2 soon as possible, but no later than January 31, 1980, unless precluded by material or equipment availability. The impact of equipment and material availability restraints on implementation of category A items is also identified below.

1. Relief and Safety Valve Qualification Testing (2.1.2)

Philadelphia Electric Company is participating in the GE BWR Owners Group to develop and c omplete qualification testing of the safety / relief valves. As discussed in the December 11, 1979 letter from the Chairman of the BWR Owners Group to D. G. Eisenhut, NRC, a test description and s chedule for implementation will not be finaliz ed f or submittal to the NRC until January 31, 1980. The additional time is necessary to c o mp le t e the engineering evaluation of a high level trip on the high p ressure ECCS and feedwater systems, and its review and approval by the BWR Owners Group's participating utilities. It is our understanding that an extension of the due date to January 31, 1980, has been agreed to by the NRC during discussions with the BWR Owners Group representative.

2. Direct S/RV Position Indication, Section 2.1.3a As discussed in reference (1) and (2), direct p os iti on indication in the control room has been provided on all safety / relief valves. Additionally, an acoustic emission system, which we understand is acceptable,is now operational on the Unit 3 code safety valves. Unit 2 is scheduled to be shutdown by January 1, 1980, to accommodate repair of the core spray flow control test loop. At that time, acoustic emission indication on the code safety valves will be made operable in the control room. These systems continue to be reviewed with respect to meeting all required qualifications.

3. Containment Isolation, Section 2.1.4 We have completed a review of the design of the Peach Bottom containment is olation p rovisions . The following is a brief description of the degree of compliance with the four criteria given in NUREG 0578, Section 2.1 4:

Diversity of Isolation Signals - Containment isolation valves currently provided with automatic closure logic receive diverse safety-grade isolation signals in accordance with SRP 6.2.4. As stated in the reference (2) letter, certain valves are provided with alternative isolation signals. These provisions and their justification will be fully described in ou r January 1, 1980 report on containment isolation.

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Mr. H. R. Denton Page 3 Classification of Systems - All lines penetrating primary containment have been classified as essential or non-essential. The results of this review will be reported to the NRC by January 1, 1980.

Isolation of Non-Essential Lines - Non-essential lines are presently provided with automatic isolation valves which are closed either by containment isolation signals or flow (i . e . , check valves, excess flow check valves). As stated in the reference (2) letter, automatic isolation of certain non-essential lines is not warranted or desired; for example, valves identified as being locked closed. The isolation p rovisions for these lines and the justification for 1,

their design will be described in detail in our January 1980 report on containment isolation.

Those valves which were found to require the addition of automatic isolation signals have been closed and the fuses p roviding p ower to these valves renoved. Until app rop riate modifications are made, the fuses wx11 only be reinserted under shift supervisory control to obtain containment radiation measurements during containment isolation.

Reset of Is ola ti on signals - We have revised the schedule for implementation of those modifications necessary to assure that resetting the isolation logic will not result in automatic reopening of any containment is ola tion valves.

The required logic changes were completed on Unit 3 during an outage which began on December 6, 1979. Similar modifications will be made on Unit 2 during an outage scheduled to begin on or before January 1, 1980.

4. Integrity of Systems with High Radioactivity, Section 2.1.6a The first quarterly leakage identification program described in reference (1) was proposed for the first quarter of 1980.

We are presently accelerating implemenrktion of this program with the objective of completing the first inspection by early January 1980, but no later than January 31, 1980. In addition, we expect to submit by January 1, 1980, our response to the North Anna letter dated October 17, 1979.

5. Plant Shielding Review, Section 2.1.6b A radiation and shielding design review that evaluates the effects of post accident radiation levels due to shine from systems containing radioactivity, will be complete by January 1, 1980, except for the evaluation concerning the effects of p os t accident levels of radiation on safety equipment. The design review that evaluates the radiation effects on equipment will be complete January 31, 1980.

Similar 1 formation sas requested by Bulletin 79-01 and our resp ons e (S. L. Daltroff, Philadelphia Electric toB. H.

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Mr. H.R. Denton Page 4 Grier, NRC, dated October 17, 1979) proposed a submittal date of January 31, 1980.

We will continue to investigate the effects of airborne radiation leaking f rom p rima ry containment on personnel and equipment during post accident conditions. This review will be complete by January 31, 1980.

6. Post Accident Sampling, Section 2.1.8a A review of post accident sampling capabilities at Peach Bottom has been c o mp le t e d . Provisions and procedures currently exist f or sampling and analyzing p os t accident gases and liquids at radiation levels permitted by plant shielding design.

The commitments in reference (2) proposed a March 1, 1980, c omp le t i on date f or developing p rocedures and techniques to imp rove our sampling ard analyzing capabilities of highly radioactive liquid samples . We will accelerate our efforts so as t a c omp le te these improvements by January 31, 1980.

Further improvements in plant procedures and equipmeat design t o p e rmi t sampling and analysis of radioactive fluids at levels based on the NRC source term criteria, will be identified early next year and implemented by January 1, 1981.

7. High Range Effluent Monitor, Section 2.1.8b The commitment in reference (2) p rop os ed an April 1, 1980 c o mp le t i on date to p rovide a method for estimating high level noble gas release rates from the offgas stack and react or building exhaus t vents. Our plans for implementing this requirement involve the installation of new high range noble gas effluent monitoring systems on each of the three plant effluent vents. All equipment has been procured and installation is in progress with an expected completion date of mid January 1980. Procedures for calibrating the monitors also will be completed by mid January. Therefore, we expect to establish operability of these monitoring systems by January 31, 1980.

8. Transient and Accident Analysis, Section 2.1.9 Philadelphia Electric Company committed tt incorp orating the small break lass-of-coolant accident guidelines into the emergency procedures and operator training by January 31, 1980 in reference (2). Additionally, we committed to implementing the inadequate core cooling guidelines within three months following receipt of the General Electric recommendations.

The modified guidelines, as submitted to the NRC by letter dated November 16, 1979, from the Chairman of the General Electric Boiling Water Reactors Owners Group ra D. F. Ross, 1654 084

Mr. H. R. Denton Page 5 Director Bulletins and Orders Task Force, will be incorp orated into the emergency procedures and the related operator t raining will be compisted by December 31, 1979.

Implementation of these guidelines will satisfy the small break accident analysis requirement identified in section 2.1.9, and Phase 1 of the inadequate core cooling analysis requirement identified in section 2.1.3b and discussed in the November 16, 1979 letter f rom T. D. Keenan toD. F.

Ross. It is our understanding that the above described commitment will satisfy all of the requirements of sections 2.1.3b and 2.1 9 that involve the General Electric analysis and are required to be completed by December 31, 1979.

9 On Site Technical Support Center, Section 2.2.2b All of the design features required by January 1, 1980 as identified in the NRC clarification letter of October 30, 1979, will be incorp orated int o the interim on Site Technical Supp ort Center by this date with the exception of direct display of plant parameters. Installation of a closed circuit television link from the Unit 2-3 control room that will monitor the ins t rumentation panels has been authorized and a purchase order is in the process of being issued. The manufacture has identified the lead time for the electronic equipment to be 30-45 days; therefore, installation of this system is not possible at this time.

Our objective is to have the TV system operable by March 31, 1980.

10. On Site Operational Supp ort Center, Section 2.2.2c An operational support center has been established near the control room. However, permanent communications with the control room will not be c o mp le t e until mid January 1980.

The routing of the communication cable is t h r ou gh the cable spreading room and therefore, its design and installation must be compatible with the fire protection and safety related specifications. This accounts for the additional time to complete this provision.

If additional clarification of our p osition is necessary, please advise us.

Very truly yours, g'n w p f . l gy 1654 085