ML19318B450
| ML19318B450 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 06/20/1980 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8006260176 | |
| Download: ML19318B450 (8) | |
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PHILADELPHIA ELECTRIC COMPANY g'
4 2301 M ARKET STREET
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P.O. BOX 8699 PHILADELPHf A, PA.19101
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$HIELDS L. DALTROFF ELtcfm c em ct:om June 20, 1980 Mr. Darrell G.
Eisenhut, Dit ctor Division of Licensing U.S.
Nuclear Regulatory Commission Washington, DC 20553
SUBJECT:
Additional TMI-2 Related Requirements to Operating Reactors
Reference:
Letter from D.
G.
Eisenhut, NRC, to All Operating Nuclear Power Plants, dated May 7, 1980, titled:
Five Additional TMI-2 Related Requirements to Operating Reactors"
Dear Mr. Eisenhut:
In the referenced letter, Philadelphia Electric Company was requested to commit to implementation of the requirements contained therein per the schedule provided. to this letter contains our position on each requirement specified in
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your May 7, 1980, letter.
Many of the modification requirements are generic to all Boiling Water Reactor facilities, and will be subjected to a review by the General Electric Boiling Uater Reactor Owners Group, which was created specifically to address the issues raised by the Three Mile Island accident.
Philadelphia Electric Company is participating on the committees evaluating implementation of these requirements.
Well-defined acceptance criteria and safety evaluations for many of the requirements are needed in order to ensure timely implementation.
These acceptance criteria and safety evaluations, when fully developed, may impact implementation schedules due to the availability of resources for conducting the required studies and developing the required designs.
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Mr. Darrell G.
Eisenhut, Director Page 2 i
I A complete assessment of the impact of the modification 1
requirements has not been possible in the time available to make
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this response.
Following a comprehensive review of the requirements, discussions with the NRC staff regarding alternatives to the strict interpretation of some requirements l
may be appropriate.
Thus, we believe a degree of flexibility is I
necessary in the implementation schedules for good cause shown.
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!!owever, within the constraints described above, it is our intent j
to meet the requirements and schedules of the referenced letter.
Item II.K.3.46 requires the licensees to evaluate the February 21, 1980, General Electric response to Michelson concerns and report their conclusions to the NRC by July 1, 1980. to this letter reports the results of our evaluation.
It is noted that the implementation dates for items II.K.3.30 and II.K.3.31 differ among Enclosure 1, Enclosure 3 part 1, and Enclosure 3 part 2 of the NRC's May 7, 1980, letter.
We would appreciate clarification of the implementation schedule for these requirements.
We trust this letter is responsive to the requirements.
If additional clarification of our position is necessary, please advise us.
Very truly yours, j
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l Enclosure I
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Peach Bottcm Atcrric Power Station Irplmentation CcnTritrents to the NRC May 7,1980 Letter On Additional D1I-2 Related Fequirements Item I.A.1.3
- Shift Manning The shift personnel requirerrents specified by itera I.A.l.3 of hufE-0660, "h% Action Plan Develcped as a Fesult of the D'I-2 Accident" are incorporated into the Peach Bottcra shift organization presently in effect.
As stated in the May 7, 1980 letter, "Five Additional D1I-2 Felated Requircraents to Operating Peactors", additional NPC requirments regarding this action itcrn will be forthcceing in a separate correspondence. We will resperd to the additional requirements follcwing receipt of this correspcndence.
Itern I.A.3.1
- Fevise Scope and Criteria for Licensing Examinations All the May 1,1980 items identified in the March 28, 1980 letter, H. R. Denton, NFC to "All Power Peactor Applicants and Licensees", have been inplernented as requested.
Itern I.C.5
- Procedures for Feedback of Cperating Experience to Plant Staff Several rechanisrrs have been in effect to assure that operating information originating both within and outside the Philadelphia Electric crganization is continually supplied to operators ard other perscnnel as apprcpriate. The Operating Experience Assessrrent Group, consisting of representatives of the Mechanical Engineering, Electrical Engineering, Cuality Assurance, Licensing, and Plant Cperating organizations, evaluate cperational experience supplied frcrn trany sources and dissminate infor-tration to the appropriate individuals and organizations. The ensite ;afety ccrrittee perfor:rs a siciliar role in the dissmination of infonraticn in the interest of educating operating perscnnel, and assuring that appro-priate evaluations and corrective actions are undertaken. Forral distri-butien of Iraterial, daily cIerating shift reetings under the direction of shift supervisien, and the periodic study assigments associated with the operator reqmlification training program are examples of rcechanisrrs used at Peach BottcIn for the dissemination of cperating inforraticn.
The Peach BottcIn procedures will be reviewed and revised to ensure that these types of activities are controlled by forralized procedures.
ItEra I.K.3.3
- Feporting Safety and Felief Valve Failures and Challenges Failures of a safety and relief valve to close will be reported pm+Lly to the NFC, and challenges to the safety and relief valves will be docurrented in an annual report as requested by the h'ec.
. Iten II.k.3.13 - Separation of HPCI and PCIC Initiation Levels This iten will be analyzed by the EWR Owners Group cn a generic basis by October 1, 1980 as requested. Based en the extent of the anticipated nodifications, flexibility in the iglerentation date of April 1,1981 Iray be requested.
Iten II.k.3.14 - Isolation of Isolation Candensers The Peach Bottan Ataric Power Station desien does not utilize an isolation condenser. 'Iherefore this iten is not applicable.
Itan II.k.3.15 - Modify Break Detection Icgic to Prevent Isolation of HPCI and FCIC Although inadvertent HPCI and PCIC isolation due to pressure spikes has not been a problen at Peach Bottan, we will evaluate this iten to deternine the need for modifications. If nodifications are detennined not to be necessary, we will subnit to the NPC by October 1,1980, an analysis justifying this position. If modifications are required, they will be inplarented by January 1,1981, if equiptrent availability perrits.
Iten II.k.3.16 - Reduction of Challenges and Failures of Relief Valves The relief valve actuation setpoints at Peach Bottan have been previously raised, based on a safety evaluation, to reduce the potential for valve actuation. An investigation of the feasibility of reducing challenges to the relief valves by use of additional nethods proposed in the hE May 7, 1980 letter will be conducted. Other Irethods ray also be considered by the study. 'Ihe feasibility study will be subnitted to the NPC by January 1,1981. Any nodifications resulting fran this feasi-bility study will be proposed by January 1,1982 and inplerented during a refueling outage follcwing Caarission approval as provided for in the NBC ig lementatien schedule.
Iten II.K.3.17 - Report en Cutages of ECC Systers The infonration requested on ECC Systen cutages during the last five years will be submitted to the NPC by January 1, 1981.
Iten II.k.3.18 - Modifications of ADS Icgic A feasibility and risk assessnent study will be perfonted to detenrine the optinum approach for tradifying the ADS actuation logic to elinunate the need for tranual actuation to assure adequate core cooling. 'Ihe feasibility study will be subritted to the NPC by January 1, 1981. If any modifications result fran the feasibility study, they will be proposed by January 1,1982 and inplemnted during a refuel-ing outage follcwing Crission approval as provided for in the NBC
-inplemntation schedide.
. Iten II.k.3.19 - Interlock on Pecirculation Pmp Icops This iten is applicable to plants without jet punps and also applicable to Hmbolt Bay. Since the Peach Bottcm Atcric Power Station design includes jet pumps, this iten is not applicable.
Iten II.k.3.21 - Restart of Core Spray and LPCI on Irw Ievel This iten will be evaluated by our Engineering Department to detemine the need for nodifications.
If nodifications are deter-mined not to be necessary, we will subrit to the hTC by October 1, 1980, an analysis justifying this position. If nodificaticns are required, the design will be developed by January 1,1981 and if equignent availability pemits, will be inplemnted during a refueling outage following Ccmnission approval as provided for in the NBC inplanentation schedule.
Iten II.k.3.22 - Autmatic Switchover of RCIC Suction The design of the PCIC systen will be evaluated to detemine the propriety of an autcratic switchover of the PCIC punp suction frcm the condensate storage tank to the torus, and, if nodificaticns are appro-priate, they will be inplemented by January 1,1982, if equipnent availability pemits. 'Ihe procedures will be revieaed, ard revised by January 1, 1981 if necessary, to ensure that explicit procedural con-trols exist for the manual switchover of the RCIC systen suction frczn the condensate storage ta:* to the suppression pool.
Iten II.k.3.24 - Adequacy of Space Cooling for HPCI and PCIC We will examine the adequacy of space cooling for the HPCI and RCIC systers. If nodifications are required, they will be inplemented by January 1,1982, if equignent availability permits.
Iten II.k.3.25 - Icss of AC Power on Pmp Seals We will evaluate the consequences of a less of cooling water to the reactor recirculation punp seal coolers and report the results to the NBC. If modifications are necessary, inple9entation will be effected by January 1,1982, if equiprent availability pemits.
Itan II.k.3.27 - Comen Reference Iavel for Vessel Level Instrurentatien Most of the reactor vessel water level instrumentation is currently referenced to the same point. The retaining instrumentation will be nodi-fled by Cctober 1,1980 to emply with this criteria provided our evaluation does not uncover any adverse censequences.
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. Itsn II.k.3.28 - Qualifications of Accuntlators en ADS Valves This itan will be exa:rined by the BWR Owners Group on a generic basis to deten: tine functional design criteria. We will review the qualifications of the accu:tulators of the ADS valves with respect to the functional design criteria. The results of this review will be sutrcit-ted to the hTC by January 1,1982.
Iten II.k.3.29 - Perfonrance of Isolation Condensers with Ncn-o ndensi-bles Peach Bottan Ataric Pwer Station does not utilize isolation condensers. Therefore this iten is not applicable.
Iten II.k.3.30 - Small-break IOCA Analysis - Ccrpliance with App. K General Electric Carpany is preparing, on behalf of all licensees, a response to the NRC that addresses the conclusicns and reccanendations regarding strall-break IOCA analytical methods set forth in iters 1-5 of Section 4.2.10 of NUREG-0626. We believe General Electric's response will satisfy all NFC concerns. General Electric's response will be subritted by the required date.
Itsn II.k.3.31 - Plant Specific Strall-break IOCA Analysis We believe the need to perform plant specific s:rall break IOCA calculations reay not be required after the NBC reviews General Elec-tric's response to NUREG-0626 as discussed in iten II.k.3.30.
If, after reviewing General Electric's response to NUREG-0626, the NPC still believes that plant specific analyses are required, we will subrit such analysis by the required date.
Itan II.k.3.44 - Anticipated Transients with Single Failure Anticipated transients carbined with the worst single failure will be analyzed by the BWR Owners Group on a generic basis. The results of this analysis will be suhritted to the hPC by Januarf 1, 1981.
Itsn II.k.3.45 - Depressurization With Other Than ADS An analysis to support depressurization redes other than full activa-tien of the ADS will be perfonned. 'Ihe results of this analysis will be subritted to the NRC by January 1,1981.
i Iten II.k.3.46 - ACRS Consultant Concerns l
l The results of our evaluation of Mr. Michelsen's concerns as
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they relate to Peach Bottan Atanic Power Station are presented in.
- Iten II.K.3.57 - Identify Water Sources Prior to Manual Activation of ADS The requirment to verify that a source of cooling water is avail-able prior to tranual actuation of the autmatic depressurization systen (AES) has been previously incorporated into the Peach Bottan D ergency Procedures.
Itsn III.D.3.4 - Control Rocm Habitability J
A review of Control Poom habitability for confomance with Regula-tory Guides 1.78 and 1.95, Sections 2.2.1, 2.2.3, and 6.4 of the Standard Beview Plan, will be perfomed by January 1,1981 by our engineering Depart: rent with support fran outside consultants. Modifications, desned necessary by the review will be implenented by January 1,1983 if equignent availability permits.
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Peach Bottom Atomic Power Station Response to Michelson's Concerns A letter, D. F. Ross to T. D. Keenan, "Information Required to Address Michelson's Concerns for Boiling Water Reactors," dated October 17, 1979, requested that the BWR Owners' Group review and respond to questions posed
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by Mr. Mi;helson ( ACRS Consultant). General Electric has reviewed these qte stions and prepared responses on behalf of the BWR 0wners' Group. Item II.K.3.46 of the May 7, le80 letter, "Five Additional TMI-2 Related Require-
. ments to Operating Reactors," requests each licensee to assess applicability and adequacy of the G.E. response to their plants.
Our evaluation of the G.E. responses concludes that they accurately reflect the Peach Bottom system designs and method of operation. We concur with all the conclusions presented in the General Electric e' +~ ucions. The only addi-tional information we consider appropriate is in regards to Michelson's question No. 7 regarding the sharing of common piping by the HPCI and RHR systems. The RHR pumps do not share common piping with the HPCI or RCIC systems. The HPCI and RCIC systems have a common section of suction pipe from the condensate storage tank. The suction piping for these systems has been sized such that adequate.NPSH is er.sured ' during all simultaneous operating modes of these systems.
WCB:jio
' 6/20/80 t
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