ML20040G033
| ML20040G033 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 02/05/1982 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0803, RTR-NUREG-803 GL-81-34, NUDOCS 8202110139 | |
| Download: ML20040G033 (7) | |
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PHILADELPHI A ELECTRIC COMPANY REC 5WED g
2301 M ARKET STREET d-2 FEB 101982* :-
P.O. BOX 8699 5 n N: LIM EEmpt tunSS *I PHILADELPHI A, PA.19101 IDEat umME R 19C SHIELDS L. DALTROFF h
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December 29, 1981 (corrected February 5, 1982)
Docket Nos. 50-277 50-278 Mr. Darrell G. Eisenhut, Director Division of Licensing U.S.
Nuclear Regulatory Commission Washington, DC 20555
Dear Mr. Eisenhut:
Your letter of August 31, 1981 (Generic Letter 81-34) forwarded NUREG 0803 " Generic Safety Evaluation Report Regarding Integrity of the BWR Scram System Piping" dated August 1981, with the requirement that we verify certain concerns on a plant specific basis.
The following review addresses the items contained in Section 5 Generic Conclusions Table 5.1 of NUREG 0803 with each item being followed by our response.
Item 1-Periodic Inservice Inspection and Surveillance for the SDV system (with Respect to Pipe Integrity)
Response-The NUREG recommends that the SDV piping should, as a minimum, be subjected to the ASME Section XI Inservice Inspection (ISI) requirements for Class 2 piping.
We shall inspect the piping on Unit 3 equivalent to Class 2 piping for ISI purposes.
Upon completion of tne scheduled modifications on the Unit 2 Scram Discharge System, that piping shall also be treated as equivalent to Class 2.
gdI 8202110139 820205 PDR ADOCK 05000277 P
Mr. Darrell G.
Eisenhut, Director Page 2 Item 2-Threaded Joint Integrity (with Respect to Piping Integrity)
Response-A review of plant specifications indicates that no threaded connections exist in the SDV process piping on either Peach Bottom unit.
Threaded joints were specified for the non-safety related air supply piping (compression fittings) and limited test connections.
Due to these tactors, threaded joint integrity is acceptable.
A walkdown of the Unit 2 piping will be made during the upcoming refueling outage to confirm our Engineering review.
If, as anticipated, no threaded joints are identified, a walkdown of Unit 3 will not be performed.
Item 3-Seismic Design Verification (with Respect to Piping Integrity)
Response-The NUREG requested that a reviev of the SDV piping be made to verify that the piping has been designed for seismic loading.
This was done as a part of the IE Bulletin 79-14 response.
In addition, as part of the modification program resulting from IE Bulletin 80-17, the Unit 3 SDV piping was re-analyzed including seismic loading.
A similar re-analysis of the Unit 2 is underway for similar modifications taking place during the upcoming refueling outage (February 1982).
Item 4-HCU-SDV Equipment Procedures Review (with Respect to Piping Integrity)
Response-The NUREG request that a review of all procedures having the potential for defeating SDV integrity be reviewed and that the review verify that such procedures contain sufficient guidance to ensure that the loss of SDV system integrity will not occur at times when such integrity should be available.
Our review has been initiated, but due
.i Mr. Darrell G.
Eisenhut, Director Page 3 to.the number of procedures involved, it is anticipated that completion will not be possible prior to February 15, 1982.
The procedures reviewed to date do not specifically address the maintaining of scram system boundary integrity as discussed in the NUREG.
However, it is thought that sufficient steps are taken to assure the postulated problem is avoided.
Item 5-Environmental Qualification of Prompt Depressurization Function Response-This item will be addressed in the ongoing Bulletin 79-01B Environmental Qualification Program.
Bechtel has been commissioned to develop the t
necessary environmental ~ profiles, which are scheduled for delivery late in February, 1982.
We will at that time address the equipmtat necessary to mitigate the type of accident postulated in the NUREG.
Item 6-As Built Inspection of the Scram Discharge Volume Piping Supports (with Respect to Piping Integrity) 4 i
Response-A review of the as-built system with regards to comparison with design _ conditions was conducted as part of the IE Bulletin 79-14 compliance program with the results being acceptable.
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Item 7-Improvement of Procedures (with Respect to Accident Mitigation)
Response-The NUREG suggests that emergency procedures in development by the BWR Owners' Group be modified to address scram system pipe breaks.
Mr. Darrell G.
Eisenhut, Director Page 4 It is our understanding the BWR Owners' Group has reviewed the guidance of NUREG-0803 regarding modification of the Emergency Procedure Guidelines and acknowledges the benefits of treating the subject generically.
The BWR Owners' Group is in the process of completing an extension of the Guidelines to include steps for reactivity control, and certain other modifications to the Guidelines which have been discussed with your staff.
After current activities on the Guidelines are substantially complete, Philadelphia Electric Company will support a preliminary study by the BWR Owners' Group to determine the best approach to fulfilling the intent of the guidance provided in NUREG-0803.
When that study is complete, currently expected to be near the end of the first quarter of 1982, the Owners' Group will determine whether to initiate specific actions to modify the Emergency Procedure Guidelines.
Item 8-Verification of Equipment Designed for Water Impingment (with Respect to Environmental Qualification)
Response-As discussed in Item 5 above, this item will be addressed as part of the environmental qualification program.
Item 9-Verification of Equipment Ouali fied for Wetdown by 212 F Water (with Respect to Environmeital Qualification)
Response-As discussed in Item 5 above, this item will be addressed as part of the environmental qualification program.
Mr. Darrell G. Eisenhut,. Director Page 5 Item 10-Verification of Feedwater or Condensate System 4
Operations Independent of the Reactor Building Environment (with Respect to Environmental Qualification)
Response-As discussed in Item 5 above, this item will be addressed as part of the environmental qualification program.
Item 11-Evaluation of Availability of HPCI-LPCI Turbines due to High Ambient Temperature Trips (with Respect-I to Environmental Qualifications)-
Response-As discussed in Item 5 above, this item will be addressed as part of the environmental qualification program.
Item 12-Verification of Essential Components Qualified for Service at 212 P and 100% Humidity Response-As discussed in Item 5 above, this item will be addressed as part of the environmental qualification program.
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Item 13-Limitation of Coolant Iodine Concentration to Standard Technical Specification Values (with Respect to Accident Mitigation)
Response-The attached tabulation of 4 years of monthly iodine data demonstrates that the likelihood of Peach Bottom operating with coolant iodine levels in excess of those delineated din the Standard Technical Specifications (STS) is extremely remote.
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Eisenhut, Director Page 6 During this four year period, the average reactor coolant iodine concentration was at least two orders of magnitude less than the STS values and in many cases, three orders of magnitude.
Should there be any further questions, p13ase do not hesitate to contact us.
Very truly yours, l'
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Rea'ctor Coolant Iodine Concentration
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8.3114 1'.'0113 5.53N4 1.25N1 2.ON4 8.27N4 m
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2.48N3 4.,4N4. 1.65N4 8.63N4 3.1174 1.13N3
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MAR.
3.26N4 1.30N3 1.9N4s '2.36N4 1.25N3 1.03N3 3.4N4 2.25N3
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8.94h4 3.005-1.s14N4 1.11N3 2.3tI4 (3)
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MAY 3.26N4 7.32N4,,_ '( 2 )
6.07N4 5.8N3 9.41N4 1.6114 (3) m
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JUNE 3.97N4 6.74114 (2)
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3.84N4 1.57N3 1.5H4 (3)
JULY 4.67N4 1.86N3 (2) 1.034N4 7.30N3 1.56N3 2.8N4 (3) 3
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AUG.
3.R5N4 1.11'13 1.6N4
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4. 3 2114 1.31M3 2.2N4 (3) s.n.
2.86t148\\85N
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OCT.
l'.5104 4.35F4 1.89N4 1.15N3 5.57N4 (2) 2.74N4 3.51N5 NOV.
2.84N4,7.30N4 2.28N4 7.16N4 2.97N3 1.36N4 2.61N4 8.69N5 3
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