ML19347A797
| ML19347A797 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 09/26/1980 |
| From: | Finfrock I JERSEY CENTRAL POWER & LIGHT CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8009300261 | |
| Download: ML19347A797 (4) | |
Text
.
p 4
\\
Jersey Central Power & IJght Company, JPDSPw NDH Madison Avenue at Punch Bowl Road Mornstown, New Jersey 07960 (201)455-8200 September 26, 1980 Mr. Darrell G. Eisenhut Director, Division of Licensing U.S. Nuclear Regulatory Corrmission Washington, D. C.
20555
Dear Mr. Eisenhut:
Subject:
TMl2 Related Requirements for Operating Reactors (NUREG 0660)
Oyster Creek Nuclear Generating Station Docket No. 50-219 in response to your letter dated September 5, 1980, JCP&L has reviewed all of Oyster Creek's TMI lessons learned activities against the clarlfled requirements of that letter. As a result of that review, we are requesting that the implementation date of sane items be extended.
Attachment A and B to this letter provide alternative schedules and justification for two items:
'. l.K. 3.14, Isolation of the Isolation Condensers on High Radiation in hnt and ll.K.3.27, Common Reference Level for Vessel Level Instrumentation.
Our position on these two items was originally addressed in our June 23, 1980 letter written in response to your May 7,1980 letter.
/ so, since a plant shutdown would be required to complete item Ii.K.3.19, Interlock on Recirculation Pump Loop, we would propose completing that item during a Spring 1981 shutdown scheduled for the purpose of completing other action plan items. We feel this is justifled since JCP&L has already imp lemented comprehensive administrative controls to assure at least two recirculation loops are open at all times.
These administrative controls include:
establishing this as a Safety Limit in Oyster Creek's Technical Specifications, procedure changes, hinged covers over all recirculation loop isolation valves and conspicuous warning signs on each cover.
Further, the Federal Environmental Protection Agency's National Pollution Discharge Permit for Oyster Creek, prohibits in Section 9.b.5, planned shutdowns during December through March. This leaves a very brief period for planning and preparation for the modification, including provisions for adequate ALARA review.
We also feel that a shutdown before January 1981 would not f actiltate the completion of other items, but would in fact divert resources from the items that are required to be completed by January 1, 1981.
9(i 8 09800 ers.y central Power & bght Company is a Memoer of the General Pubhc Utihties System
O
/
vr. Darrell 3. Eisenhut September 26, 1980 JC3&' cannot yet commit to completing the revised requirements of item li.E.4.2.3, Containment !. solation Dependability, until we have had a chance to r ev iew the additional NRC guidance on requirements for three (3) diverse isolation signals and e.ssential vs. nonessential systems.
I f you should have any questions regarding the resconse, please contact
- t.. lames KnubeI (201-455-8753) of my staff.
Very truly yours, d
Ivan R. Finfro n, Jr Vice Preside
o
/.
ATTACHMENT A lSQLAT10N OF THE ISOLATION CONDENSERS ON HIGH RADI ATION IN VENT (NUREG 0660, 11 K.3.14)
NRC REQUIREENT i
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 from the plant through the shell side vents to the atmosphere. Such a release could only oCC Jr *f there dere a tube leak. Modifications should be complete by January 1, 1981.
OYSTER CREEK's PRESENT DESIGN The isolation condenser isolation logic is somewhat dif ferent 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 Iine radiation monitor which is used to isolate the reactor from the condensers.
OYSTER 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 welI suited for long term core cooling.
JCP&L's concern is that if this modification is not properly de:Igned, it wil have an adverse effect on availability.
To do this job properly we cannot simply rewire the existing vent line radiation monitor alarm i n t( the isolation circuit.
In our judgement, the existing monitor would alarm, even if there were no tube f ailure simply because cf the extremel y high radiation level s expected in the area of the monitors from the isolated condenser's steam & condensate piping. Furthermore, it is impractical to shield the present detectors suf ficiently to ensure that their alarming imp i les a tube rupture.
JCP&L f eels that a modification to this system which achieves the desired results cannot be completed by January 1, 1981. At this time the required radiation monitoring scheme has not been specified and obviously the procurement lead times are unknown.
We propose to submit a design for this modification by January 1, 1981 and at that time will also include an n'olementation schedule based upon vendor supplied delivery dates.
i i
ATTACHMENT B CO.'.fA0N REFERENCE LEVEL FOR VESSEL LEVEL INSTRUMENTATION (NUREG 0660, 11. K.3.27)
NRC REQUIREW.NT Modi fy all reactor' vessel water level instrumentation so that they have a common reference level. Complete by January 1, 1981.
OYSTER CREEK's POSITION in general we agree with the concept of having a common reference level for al l 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 f rom the present system may have a confusing ef fect and consequently be the cause of operational problems.
In addition, a substantial adm inistrative task is associated with this alteration. Relebeling the faces of the indicators and recorders is relatively simple compared to the task of Identi f ying and revising all logs and operations, emergency and surveillance procedures which use the present system of level instrumentation.
JCP&L proposes the following alternate schedule. By October,1980, all level indicators and recorders will have their faces altered showing two scales.
One will be he present markings and the other will be referenced to the top of the active fuel. We will also identi?y alI documents (e.g. logs and procedures) which will need to be revised as a result of enanging the reference point. The period between October 1980 and the 1981 refuoling outage wIII be a transition period during ahIch the operators w1II beccw accustomed to the new scales and changes to al l documentation will be draf ted. The elimination of the old scales and changes to all affected procedores, logs, etc will occur during the 1981 outage.
It is felt that an outage period is the best time for this transition because level inst unentation in the normal cperating ranges is not used and therefore the opportunities for operator misjudgement are minimized. The spring outage will al so prov ide a block of time during which the required training sessions can be conducteo.