ML20040G126
| ML20040G126 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 02/08/1982 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Tedesco R Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0803, RTR-NUREG-803 NUDOCS 8202110304 | |
| Download: ML20040G126 (3) | |
Text
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c PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 1881 -1981 PHILADELPHI A. PA.19101 (215)841 45o2
... = ::: = _
FEB C 1982 m
b Mr. Robert L. Tedesco O
Assistant Director for Licensing RECEIVED Division of Licensing
' [
FEB111982> %
U. S. Nuclear Regulatory Co::: mission Washington, DC 20555
' Wnauslungermuse g
IRune rmuss a O
Subject:
Limerick Generating Station, Units 1 & 2 t
Safety Concerns Associated with Pipe Breaks in the BWR Scram System Docket No. 50-352 and 50-353
References:
a)
Lettee from Robert L. Tedesco (USNRC) to Edward G. Bauer Jr. (PECo),
dated April 30, 1981 b)
Letter from John S. Kemper (PECo) to Robert L. Tedesco (USNRC),
dated November 10, 1981
Dear Mr. Tedesco:
In accordance with the reference b) letter, we are addressing the requirements of NUREG-0803 " Generic Safety Evaluation Report Regarding Integrity of BWR Scram System Piping" as our 120 day response to the reference a) letter. The response date of February 10, 1982 was mutually agreed to, as noted in the reference b) letter.
Our detailed response is as follows:
Item 1 - Periodic Inservice Inspection and Surveillance for the Scram Discharge Volume (SDV) System.
The SDV system will be subjected to periodic inspection and surveillance under the Limerick Inservice Inspection Prograr: ne discussed in Section 6.6 of the FSAR. These lines are classified as an ASME Boiler and Pressure Vessel Code,Section III Class 2 system and they vill be inspected under the Section XI Class 2 rules.
Item 2 - Threaded Joint Integrity.
Not applicable to Limerick per NUREG-0838, Table 5 1.
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- Item 3 - Seismic Design Verification.
The SDV system out to and including the vent and drain valves is designated as Seismic Category I.
The seismic boundaries are shown on FSAR Figure 4.6-6.
This designation indicates that the system will be designed and analyzed for Seismic Category I loadings in accordance with Section III of the ASME Code.
Item 4 - HCU-SDV Equipment Procedures Review.
The system and administrative procedures for Limerick are about to enter the review phase. The review of these procedures will address the maintenance of the scram system boundary integrity as discussed in NUREG-0803 Item 5 - Environmental Qualification of the Prompt Depressurization Function.
Due to the many variables involved in defining the environmental conditions in the reactor building after the postulated failure of a scram discharge volume, it was necessary for us to commission the development of environmental profiles to model this event. When these profiles are complete, we will assess the situation to determine if any of the equipment necessary for the control of this postulated accident would be adversly effected. We will address these concerns as a part of our Environmental Qualification Program.
Item 6 - As-built Insnection of SDV Piping and Support.
In accordance with the quality assurance program at Limerick, all. systems designed to the requirements of Section III of the ASME Code, including the SDV, will be subjected to an as-built inspection prior to the plant start-up. A record of the inspection results will be placed in storage for permanant retention.
Item 7 - Improvement of Procedures.
The NUREG suggests that emergency procedures, being developed by the BWR Owners' Group, be modified to address scram system pipe breaks.
It is our understanding that 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.
k
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 detennine whether to initiate specific actions to modify the Emer6ency Procedure Guidelines.
Item 8 - Verification of Equipment Designed for Water Impingement.
Same response as Item 5 Item 9 - Verification of Equipment Qualified for Wetdown by 212 F Water.
Same response as Item 5 Item 10 Verification of Feedvater and Condensate System Operation Independent of the Reactor Building Environment.
Same response as Item 5 Item 11 - Evaluation of Availability of HPCI-LPCI Turbines Due to High Ambient Temperature Trips.
Same response as Item 5 Item 12 - Verification of Essential Components Qualified for Service at 212 F and 100 Humidity.
Same response as Item 5 Item 13 - Limitation of Coolant Iodine Concentration to standard Technical Specification Values.
It is our intention to limit the coolant iodine concentration at Limerick to the Standard Technical Specification Values.
Should you have any questions please contact us.
Sincerely,
/fg