ML20054G711
| ML20054G711 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/15/1982 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8206220228 | |
| Download: ML20054G711 (3) | |
Text
9 PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 1881 -1981 PHILADELPHI A. PA.19101 1215)041-4502 VICE PRESIDE N T June 15, 1982
...........o......"
Mr. A. Schwencer, Chief Docket Nos: 50-352 Licensing Branch No. 2 50-353 Division of Liwnsing U. S. Nuclear Pegulatory Camission Washington, DC 20555
Subject:
Limerick Generating Station, Units 1 and 2 Request for Additional Infonnation Frcm NFC Power Systems Branch
Dear Mr. Schwen r:
to your letter dated February 25, 1982 listed a number of cmponents Systms which your Power Systms Branch (PSB) felt should be explicitly identified in Table 3.2-1 of the Limerick FSAR. Accordingly, we have revised Table 3.2-1 (Revision 6, subnitted June 3,1982) to explicitly list those cmponents. also contained PSB's position that offsite power systs equipnent in the switchyards, including the interconnecting circuitry between the switchyards and the C3 ass lE distribution systms, is important to safety, and that a quality assurance program for installation, inspection and testing must be provided.
We do not believe any portion of the offsite power systs to be important to safety, because failure of the offsite power systs cannot adversely affect the operation of the safety related Class lE AC distribution systm or the equignent supplied by it. Any potential for such adverse interaction is precluded by the use of Class lE 4KV safeguard busses and the offsite power syst s, in accordance with Pegulatory Guide 1.75, Revision 1. These circuit breakers are shown in FSAR Figure 8.1-1 and have the following equipnent numbers:
101-Dll 101-D21 201-Dll 201-D21 101-D12 101-D22 201-D12 201-D22 101-D13 101-D23 201-D13 201-D23 101-D14 101-D24 201-D14 201-D24 As discussed in FSAR Section 8.3.1.1.2.11, safety related protective relaying is provided to isolate the Class 1E safeguard busses under degraded voltage or faulted conditions on the offsite systs, in accordance with Branch Technical Position PSB-l.
The above circuit breakers and associated protective relaying are subcmponents of the engineered safety feature 4KV switchgear shown in FSAR Table 3.2-1 as Item X.A.1.
Table 3.2-1 has been revised (Revision 6, subnitted June 3,1982) to clarify this.
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. For these reasons, we have not considered the offsite power systen as important to safety in the context of Appendix A to 10CFR50, and have not implanented a quality assurance program under Appendix B to 10CFR50 covering these systans.
The Limerick substaticms and interconnecting circuitry are an inportant part of the Philadelphia Electric Canpany transmission systen, and of the Pennsylvania - New Jersey - Maryland (PJM) interconnection. We are proud of the reliability record of these systans and inte d that these new systems be designed, constructed, tested and maintained to assure that systen reliability is not jeopardized.
In sunmary, we believe that the design of the Limerick Generating Station incorporates adequate safety grade electrical features to assure that disturbances in the offsite power systan will not adversely affect operation of the safety-related onsite power systans and equipnent.
For the above reasons, we respectfully request that the Power Systans Branch reconsider its position that the offsite power systans are important to safety.
Sin rely, s n,t-HDH/pb/Z-35 cc:
See attached list i
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Judge Lawrence Brenner Judge Richard F. Cole Judge Peter A. Morris Troy B.
Conner, Jr., Esq.
Stephen H. Lewis, Esq.
Mt. Frank R. Romano Mr. Robert L. Anthony Mr. Marvin I. Lewis Judith A. Dorsey, Esq.
Charles W. Elliott, Esq.
Mt. Alan J. Nogee Robert W. Adler, Esq.
Mr. Thomas Gerusky Director, Pennsylvania Emergency Management Agency Steven P. Hershey James M. Neill, Esq.
Donald S. Bronstein, Esq.
M. Joseph H. White, III r
Dr. Judith H. Johnsrud Walter W.
Cohen, Esq.
Robert J. Sugarman, Esq.
Mr. W. Wilson Goode Atomic Safety and Licensing Appeal Board Atomic Safety and Licensing Board Panel Docket and Service Section t
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