ML20042C098
| ML20042C098 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, Limerick, 05000000, 05000463, 05000464 |
| Issue date: | 03/26/1982 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.K.3.18, TASK-TM NUDOCS 8203300195 | |
| Download: ML20042C098 (2) | |
Text
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PHILADELPHI A ELECTRIC COM PANY g
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2301 M ARKET STREET
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M M 2 9 1082 > T SHIELDS L DALTROFF M)J',*U[g;p g p N
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3 March 26, 1982 y
os Mr. Darrell G.
Eisenhut, Director Division of Licensing U. S.
Nuclear Regulatory Commission Washington, D.C.
20555
SUBJECT:
NUREG-0737 Item II.K.3.18, ADS Initiation Logic Design Modification
Dear Mr. Eisenhut:
This letter concurs with the conclusions of a February 5,
1982 letter (T.
J.
Dente, BWR Owners' Group to D.
G.
- Eisenhut, N PC) regarding the April 1,
1982 schedule associated with NUREG 0737, Item II.K.3.18, Modification of Automatic Depressurization System ( ADS) Logic.
Item II.K.3.18 requires modification to the ADS logic to eliminate the need for manual activation to assure adequate core cooling.
Licensees were required to provide the results of a feasibility study to the NRC staff by April 1,
1981, a detailed description of the proposed modifications by April 1,
1982, and implementation of the modification during a refueling outage following NRC approval of the design.
Philadelphia Electric Company has been a participant in the General Electric BWR Owners' Group feasibility studies addressing this issue.
We concurred in correspondence dated April 2, 1981 (J. W.
Gallagher to D.
G. Eisenhut) with the Owners' Group study as submitted to the NRC on March 31, 1981
.h 8203300195 820326
@0 PDR ADOCK 05000277 P
o Mr.
D. G.
Eisenhut, Director Page 2 (D.
B. Waters, BWR Owners' Group Chairman to D. G. Eisenhut) and endorsed the option proposed by the study involving installation of a timer which bypasses the high drywell pressure signal following a low reactor water level condition.
Recent evaluations by the Owners' Group of the results of the analysis performed in the development of the operator actions for reactivity control contained in the Emergency Procedure Guidelines (EPG) indicates that the logic modifications proposed in the II.K.3.18 study may not be appropriate.
The EPG requires operation with reactor water level below the ADS setpoint for the ATWS situation.
The bypass logic modification propcsed in the II.K.3.18 study would severely complicate operator actions under this condition because the operator would be required to reset the ADS logic at least every two minutes in order to avoid premature activation of this system.
A technical basis for this conclusion is documented in the February 5, 1982 letter previously referenced.
Consequently, a submittal by April 1,
1982 providing a final design description that addresses NUREG-0737 Item II.K.3.18 is not feasible.
The BWR Owners ' Group is in the process of identifying ADS logic design modifications which address the conflict between II.K.3.18 and the EPGs.
Further, the Owners' Group has proposed in the February 5, 1982 letter to submit a supplement to the original study by September 30, 1982.
The supplement will describe the modifications in the same level of detail as that contained in the original study.
Following NRC review and approval of this supplement, we will select one of the options and proceed with the final design description and implementation during the first refueling outage commencing no earlier than six months after the date of NRC approval.
Philadelphia Electric Company will continue to play an active role through our direct participation on the BWR Owners' Group subcommittees addressing these issues so as to develop effective engineering solutions in the most expeditious manner.
Should you have any questions regarding this matter, please do not hesitate to contact us.
Very truly yours sm
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