ML20010G119

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Advises of Change in 810210 Proposed Mods to TMI Action Item II.K.3.21 Commitments.Core Spray Logic Will Only Allow for Remote Manual Restart of Core Spray.Containment High Range Monitors Can Be Properly Calibr in Lab
ML20010G119
Person / Time
Site: Oyster Creek
Issue date: 09/08/1981
From: Carroll J
JERSEY CENTRAL POWER & LIGHT CO.
To: Crutchfield D
Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.E.4.2, TASK-2.K.3.14, TASK-2.K.3.21, TASK-TM NUDOCS 8109150354
Download: ML20010G119 (2)


Text

1 OYSTER CREEK NUCLEAR GENERATING STATION EiWWEE gq Mfg *gfMC (609) 693-1951 P.O. BOX 388

  • FORKED RIVER
  • 08731
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Septaber 8, 1981 8.1.k f Ok l

g Mr. Dennis Crutchfield g

Operating Reactors Branch #5 Division of Licensing b[i J q Jgg;,

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U.S. Nuclear Regulatory Ocximissian C4 s.s. %, %,

Washington, D.C.

20555

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Dear Mr. Crutchfield:

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Subject:

Oyster Creek Nuclear Generating Station Dccket No. 50-219 NESEG 0737 Clarification Since the publication of NUREG 0737, we have been utilizing large amounts of naterial and human resources in our effort to fulfill the requirements of that doctment. As w haue progrcssed in our design of scme of the required undifications, we have fa nd it necessary to cla-ify previous cmmitments and to take exception with sme of the NURE; requirements.

By letter dated February 10, 1981, we transmitted to you our position on NUREG 0737, item II.K.3.21 " Restart of Core Spray". In that sulnittal we had proposed to nodify our core spray logic to allow for a semi-autcmatic restart. Since that time, w have made substantial progress in the design of the modification and have also had the vwortunity to factor " ' hose applicable portions of the BWR owner's group evaluation on this topic. The BWR owner's group report states, "'Ihese negative impacts include a significant escalation of control system emplexity and restricted operator flexibility when dealing with anticipated events." We have cme to that same conclusion, in that this nodification may have a negative impact on safety. We, therefore, are changing our proposed nodification to only allow for remote / manual restart of Core Spray.

By letter dated January 1,1981, we cmmitted to install a contairstent high range radiation monitor noeting the requirments of NUREG 0737. It is still our intention to cmplete this modification during our next refueling /

maintenance outage; homver, we do take exception with the requ'.rment stated in Table II.F.1-3 of NUREG 0737 which required in situ calibrat.on of the l,

nonitors to 10 R/hr with a calibrated radiation source. Because of the physical location of the containnent high range monitor, their calibration with such a large radiation source would be extremely difficult and would pose a very serious personnel safety hazard. It is our position that these nonitors can be properly calibrated in the laboratory and then calibrated by electronic signal substituuon once installed.

/O oho $h DO PDR

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Mr. Dennis Crutchfield Page 2 September 8, 1981 t

'f Also, please note that by letter dated April 30, 1981, we provided you with our interpretation of NUREG 0737, item II.K.3.14 " Isolation Condenser System Isolation logic" stating that we felt this was not applicable to i

Oyster Creek and by letter dated August 27, 1981, we provided you with our justification for not modifying the Oyster Creek Purge and Vent Isolation logic as suggested i'r NUREG 0737, itan II.E.4.2.

We would request your timely review on these NUREG itans so we ray take the resources currently being utilized on them and assign them to higher priority i' m.

If you have any questions on these topics, please contact Mr. James Knubel, Manager-NR Licensing, at (201) 299-2264.

Very truly yours, 84 J/. T. Carroll, Jr.

Acting Director - Oys Creek JIC:JK: dis l

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