ML19318C431
| ML19318C431 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 06/23/1980 |
| From: | Finfrock I JERSEY CENTRAL POWER & LIGHT CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0660, RTR-NUREG-660 NUDOCS 8007010468 | |
| Download: ML19318C431 (6) | |
Text
Jersey Central Power & Ught Company Madison Avenue at Punch Bowl Road Mornstown, New Jersey 07960 (201)455-8200 June 23, 1980 Darrell G. Eisenhut Director, Division of Licensing U. S. Nuclear Regulatory Comission Washington, D. C.
20555
Dear Mr. Eisenhut:
Subject:
Additional 'IMI2 Related Requirements for Cperating Reactors (NUREG 0660)
Oyster Creek Nuclear Generating Station Docket !O. 50-219 Your letter of of May 7, 1980 requested JCPSL to commit to the implementation of a number of additional TMI 2 related requirements.
It is JCP&L's intention to be fully responsive to this request, however well defined acceptance criteria for many of the requirements are needed in order to ensure timely implementation. The acceptance criteria when fully developed may impact schedules due to the availability of resources for conducting the required studies and developing the required designs. Thus we believe that a degree of flexibility is necessary for good cause shown. to this letter is JCP&L's initial assessment of the applicability of each of the 32 requirements & our ability to satisfy them. In two cases (II.K.3.14, &.27) we have provided an alternate approach which we feel meets the intent of the requirement. Also in the case of "Shif t Manning" (I. A 1.3), we have not yet received your guidance; once received it will be reviewed and we will inform you of our ability to complete it on schedule.
If there are any questions, please advise.
Very truly yours, M,
Ivan R. Fin ock Jr.
Vice President oo/
5 8007010468 Jersey Central Power 8.gt Company is a Member of the General Pub!ic Utat:es System
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Page 1 of 5 Mr. D. G. Eisenhut OYSTER CREEK NUCLEAR GENERATING STATION June 23, 1980 COMMITMENTS REGARDING NRC'S MAY 7; 1980 LETTER HUREG 0660 NRC ITEM ITEM NO.
TITLE SCHEDULE REMARKS 1
IA.1.3 Shift Manning:
Personnel Requirement 7/1/82 NRC Guidance has not yet been provided.
When received. JCP&L will review it and
' Overtime Procedures 8/1/80 inform the NRC if the schedules can be met.
2 IA.3.1 Revised Scope & Criteria for Licensing Exams 5/1/80 Note I 3
IC.5 Procedures for Feedback of Operating Experience 1/1/81 Note I to Plant Staff 4
IIK.3.1 Automatic PORV Isolation System 7/1/81 Not Applicable, PWR's Only 5
IIK.3.2 PORY Failure Report 1/1/81 Not Applicable, PWR's Only 6
IIK.3.3 Report of Safety & Relief Valve Failures and 1/1/81 Note I Challenges 7
IIK.3.5 Automatic Reactor Coolant Pump Trip 1/l'/81 Not Applicable, PWR's Only 8
IIK.3.9 PID Controller Modification 7/1/80 Not Applicable, Westinghouse PWR's Only 9
IIK.3.10 Anticipatory Trip Modification TBD Not Applicable, Westinghouse PWR's Only 10 IIK.3.12 Confirm Existance of Anticipatory Trip on 7/1/80 Not Applicable, Westinghouse PWR's Only Turbine Trip 11 IIK.3.13 Separation of HPCI & RCIC Initiation Signals 10/1/80 Not applicable since Oyster Creek does not have HPT.I & RCIC systems.
12 IIK.3.14 Isolation of Isolation Condensers on High 1/1/81 Refer to Attachment A Radiation in Vent m
Page 2 of 5 OYSTER CREEK NUCLEAR GENERATING STATION COINITHENTS REGARDING NRC'S MAY 7,1980 LETTER NUREG 0660 NRC-ITEM ITEM NO.
TITLE SCilEWLE REMARKS 13 I I K. 3.15 Modify Break Detection Logic to Prevent Spurious 1/1/81 Not applicable since Oyster Creek does not Isolation of HPCI and RCTO Systems have HPCI and RCIC Systems.
14 IIK.3.16 Feasibility Study and Modifications to Reduce 1/1/81 Note I Challenges and Failures of Relief Valves (Study) 15 IIK.3.17 Report on Outages of ECC Systems 1/1/81 Note I 16 IIK.3.18 Fer.sibility Study and ADS Modifications for 1/1/81 Note I Increased Diversity (Study) 17 IIK.3.19 Recirculation Loop laterlocks 1/1/81 Note I 18 IIK.3.20 Loss of Service Water for Big Rock Point 1/1/81 Not applicable to Oyster Creek.
19 IIK.3.21 Restart of Core Spray on Low Level Signal 1/1/81 Not applicable; the desired feature is already included in the Oyster Creek design.
20 IIK.3.22 Automatic Switchover of RCIC System Suction 1/1/81 Not applicable, since Oyster Creek does not (Review) have a RCIC System.
21 IIK.3.24 Adequacy of Space Cooling for HPCI and RCIC 1/1/82 Not applicable since Oyster Creek does not Systems have HPCI & RCIC systems.
22 IIK.3.25 Effect of Loss.of Cooling to Recirc Pump Seals 1/1/82 Note I 23 IIK.3.27 Common Reference Level for Reactor Vessel Level 10/1/80 Refer to Attachment B Instrumentation 24 IIK.3.28 Verify Qualification of ADS Valve Accumulator 1/1/82 Not applicable, Oyster Creek's ADS valves do not have accumulators.
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Page 3 of 5 0YSTER CREEK NUCLEAR GENERATING STATION COMMITMENTS REGARDING NRC'S MAY 7, 1980 LETTER NUREG 0660 NRC ITEM ITEM NO.
TITLE SCHEDULE REMARKS 25 IIK.3.29 Study to Demonstrate Performance of Isolation 4/1/81 Note I Condenser with Non-Condensible Gases 26 IIK.3.30 Revise Small Break LOCA Methods to Show Com-7/1/83 Note I pliance with App. K.
27 IIK.3.31 Calculations to Show Compliance with 10 CFR 50.40 >1983 Note I 28 IIK.3.44 Evaluation of Anticipated Transients with 1/1/81 Note I Single Failure to Verify No Fuel Failure 29 IIK.3.45 Evaluation of Depressurization with Other Than 1/1/81 Note I Full ADS 30 IIK.3.46 Applicability of Michelson Concerns 7/1/80 Note I 31 IIK.3.57 Identification of Water Source. Prior to Manual 10/1/80 Note I ADS 32 IID.3.4 Control Room Habitability Review and Modifica-1/1/81 Note I tions (Review)
Note I: At this time it is JCP&L's intention to satisfy the requirements of this task by the indicateddate(s).
In some cases, increases in the currently perceived work scope or equipment delivery problems may cause an alteration of the schedule. JCP&L will inform the NRC when these situations arise.
Page 4 of 5 A'ITACHMENT A (ENCIDSUPE 1)
ISCLATICN CF '111E ISCIATION CCNDENSE.RS ON HIGi FADIATION IN VENT (NURES 0660, II K.3.14)
NRC PAQUIREMENT Modify the isolation condenser logic so that the isolation condensers are isolated from the reactor upon the receipt of a high radiation signal in the atmospheric vent monitor instead of the steam line monitor. The goal of this modification is to increase the availability of the isolation condensers during an accident by isolating them only if there is radiation being released frcan the plant enrougn tne snell side vents to the atmosphere.
Such a release could only occur if there were a tube leak.
Modifications should be complete by January 1, 1981.
CYSTER CFzEK'S PRESENT CESIGN Tne isolation condenser isolation logic is somewhat different from that described for the typical BWR. A vent line radiation monitor does exist which alarms in the control room, however Oyster Creek does not have a steam line radiation monitor wnich is used to isolate the reactor from the condensers.
CYSTER CREEK POSITION JCP&L agrees with the NRC's goals of increasing the availability of the isolation condensers, post accident.
They are passive systems and are well suited for long term core cooling. JCP&L's concern is that if this modification is not properly designed, it will have an adverse effect on availability. To do this job properly we cannot simply rewire the existing vent line radiation monitor alarm into the isolation circuit.
In our judgement, the existing monitor would alarm, even if there were no tube failure simply because of the extremely high radiation levels expected in the area of the monitors from the isolated condenser's steam & condensate piping. Furthermore, it is impractical to shield the present detectors sufficiently to ensure that their alarming implies a tube rupture.
JCP&L feels that a modification to this system which achieves the desired results cannot be completed by January 1, 1981.
At this time the required radiatir.n monitoring scheme nas not been specified and obviously tne procurement lead times are unknown.
We propose to subnit a design for this modification by January 1,1981 and at that time will also include an implementation scheduled based upon vendor supplied delivery dates.
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Page 5 of 5 A'ITACE!fRf B (ENCICSUPE 1)
CC&KN PiFERENCE LEVEL FCR VESEL LEVEL INSTRLMENTATION (NUREG 0660, II K.3.27)
NRC RECUIREMENT Modify all reactor vessel water level instrumentation so tnat tney nave a common reference level. Complete by October 1, 1980.
CYSTER CPLEK'S POSITION In general we agree with the concept of having a comron reference level for all reactor vessel level instrumentation. Most persons not involved with control room operations find the present system of level instrumentation cumbersome and difficult to comprehend.
Control room operators and shift supervisors who have been working with the present system for a number of years, however, are quite comfortable with it and adept at using it.
JCP&L is concerned that an abrupt change from the present system may have a confusing effect and consequently be the cause of operational problems.
In addition, a substantial administrative task is associated witn this alteration. Relabeling tne faces of the indicators and recorders is relatively simple compared to the task of identifying and revising all logs and operations, emergency and surveillance procedures which use the present system of level ihstrumentation.
JCP&L proposes the following alternate scneaule. By Cctober, 1980, all level indicators and recorders will have their faces altered showing two scales.
One will te the present markings ard the other will be referenced to the top of the active fuel. We will also identify all documents (eg. logs and procedures) wnich will need to be revised as a result of cnanging the reference point. The period between Octocer 1980 and the 1981 refueling outage will be a transition period during wnich the operators will become accustcraed to the new scales and enanges to all documentation will be drafted. 'Ibe elimination of the old scales and changes to all affected procedures, logs, etc. will occur during the 1981 outage. It is felt that an outage period is the best time for this transition because level instrumentation in the normal operating ranges is not used and therefore the opportunities for operator misjudgement are minimized. The outage will also provide a block of time during which the required training sessions can be conducted.
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