ML20062J280

Responds to NRC Request for Info Re Implementation of TMI-2 Action Plan Requirements.Initiation Levels of HPCI & RCIC Sys Should Be Separated So That RCIC Sys Will Initiate Higher Water Level than HPCI Sys

ML20062J280
Person / Time
Site:	Peach Bottom, Limerick, 05000463, 05000464
Issue date:	10/02/1980
From:	Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
NUDOCS 8010070339
Download: ML20062J280 (6)

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PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET :

P.O. BOX 8699 -

JCSEPH W. GALLAGMER PHILADELPHIA PA.19101 N' q )

stactnic Pooouc7 or osPamf asame, 12151841 5003 ,

i October 2, 1930

't r . Darrell C. Eisenhut, Director

')ivision of Licensing L' S ;uclear Res;ulatory Commission

a s hin g t on , DC 20535 3 C ".J 5 C T : Cospliance with T:II-2 Related Requirenents 1eferences: 1) Letter dated ::ay 7, 1930, D. G. Eisenhut,

2C, to all Operating Reactor Licensees

2) Letter dated July 31, 1930, D. G. Eisenhut,

iR C to All Licensees of Operatin;;

Plants and Applicants for Operating Licenses and Holders of Construction Permits.

3) Letter dated September 5, 1930, D. C. Eisenhut to All Licensees of Operating Plants, providing preliainary clarification of T:II Action Plan Requirements.

Dear ifr. Eisenhut:

The IIuclear Regulatory Commission by way of the correspondence referenced above has requested infornation from the Licensees regarding implenentation of T !I-2 related requirements. Our response to these requests are submitted below.

1. 7ecuirenent: !!PCI/ aCIC Initiation setpoint (Item II.K.3.13a of reference 1)

The initiation levels of the HPCI and ROIC system should be separated so that the RCIC systen initiates at a higher water level than the 3PCI system. This change has the notential to reduce the number of challenges to the HPCI system and could result in less

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stress on the vessel'from cold water injection.

Analyses should be cerformed to evaluate-these

' changes. The analyses-should be submitted to the I staff by October.1, 1930, and changes should'be implemented'by-April 1, 1931 if . justified by the analysis.

Resoonse

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It is our conclusion that setpoint. changes vill yield mininal reduction in the thermal cycle history. This matter was discussed in a telephone conversation between R. A. Hill of General Electric Company, T. Shannon representing the BUR Owners' Group, and Wayne Hodges of the NRC on June 13 and 17. Mr. Hodges indicated that the plan not to implement the changes appeared to i -

be appropriate if the evaluation of the change demonstrates 7

\ negligible reduction in thermal cycles. In order to permit a  ;

thorough review of the Owners Grouo evaluation, we propose a  ;

{ submittal date of October 24, 1980 for providing the bases for i our conclusion on this issue.

2. Recuirement: RCIC Auto Restart (Item II.K.3.13b of j reference 1)

The RCIC' system initiation logic should be modified so that the RCIC system will restart on low water level. The reason for this proposal and the actions requested are identical to i.

requirement i above.  !

f Resnonse  ;

i ,r ' Our assessment of this proposal indicat2s that it will enhance  !

\. the availability of the system while having no adverse affect on j system function, reliability or safety. The modification includes relocating the high level trip signal.from the RCIC 7 turbine trip valve to the RCIC steam supply valve. This change elininates the manual reset feature from the RCIC trip on high.  ;

reactor level. The modification provides a steam supply valve

closure on a high reactor level trip. The existing control logic ,

! will reopen the steam supply valve when the reactor level  !

decreases'to the low level trip setpoint. This modification will' be comoleted on Peach Bottom Units 2 and 3 by April 1, 1981 as required in reference 1.  !

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3. Recuirement: Common Reference Level (Item II.K.3.27 of f l reference 1) i i

, Different reference points of various reactor vessel water >

level instruments may cause operator confusion. Therefore, all level instruments should be referenced to the same

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Mr. D. C. Eisenhut :Page 3

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. point. Documentation of.the modification shall be submitted I by October 1, 1930 aesconse We have completed the installation of new scales to several level instrunents to provide for a common reference point of 538 inches above the bottom of the vessel. This point was chosen to limit

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the number of level instruments requiring scale changes so as to uinimize the confusion associated with the reorientation of the control room operators to a new reference scale. The modification changes che scales on the fuel zone level'(narrow 4

range) recorder and the shutdown level (vide range) indicator to  !

reflect a zero point that is consistent with the other three I

ranges of level instrumentation.

f 4 Requirement: Identify Water Sources Prior.to Manual i i

Activation of ADS (Item II.K.3.57 of reference 1) i Emergsacy procedures should include verification that a-source of cooling water, such as core spray, LPCI, or l condensate systems is available prior to manual actuation of 4

the automatic depressurication system'(ADS). The Licensee

! should verify that the Emergency Procedures have been ,

appropriately revised.

Resnonse 4

This requirement has been incorporated into the emergency procedures for a loss of coolant accident. The revision was completed as part of the phase 1 effort of the General Electric i 3tJR Owners' Group procedure improvement program-required by NUREG

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0573, "TMI-2 Lessons Learned Task Force Status Report'and Short

' Term Recommendations." ,

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5. Recuirement: Minimum Shift Staffing (reference 2) "

i Reference 2 provides interim criteria for minimum shift staffing and requests the Licensees to advise the NRC within 90 days of the date by which their shift staffin; will be in j compliance with this criteria.

a Resnonse An examination of our current staffing practices and capabilities

^ reveals that the Peach 30ttom organization is in compliance _with the interim criteria except for the requirement that a licensed i senior reactor ooerator (SRO) shall, at all times, be'in the control room. Two supervisin; senior licensed operators are assigned to each shift. Normally at least one 510 is stationed 4.

1 within the control room complex at all times; however, this has l j' ,

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Cisenhut Page 4 not previously been a rigid requiresent. Offective November 1, 1980, instructions will be issued, and the administrative procedure regarding shift staffing revised to ensure that a +

licensed senior reactor operator (SRO) is.at all cines in the control room conalex from which a reactor is being operated.

6. ".equirement: Dedicated ;Iydrogen Penetrations (Item II.E.4.1 of reference 3)

Hvaluate the design of the purge systas for post-accident combustible gas control of the containment atmosphere.

Soecific design criteria are identified. The'systen design information shall be submitted by October 1, 1930.

,- Resnonse .

1 This requirement carallels item 2.1.Sa of NUREG 0573, Short Ters Lessons Learned. Our review of the design criteria presented in.  ;

II.E.4.1 of reference 3, concludes that the previously proposed

, modifications,and information submitted to the NRC meet the

. requirements of this item. The proposed modifications were identified in correspondence dated January 2, 1900, S. L.

Daltroff to H. R. Denton, NRC. The modifications involve additional containment isolation valves on the Containment-Atmospheric Dilution (CAD) system. The descriptive information

., requested by October 1, 1980 was provided in a Peach-Bottom

, Operating License amendment application, dated July.16, 1980.

' 7. Recuirement: Small-Break LOCA Methods (Ices II.K.30 of reference 3)

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Requires the methods used by the NSSS vendor for small break LOCA analysis to be in compliance with Appendix K to 10 CFR r

50. A schedule for meeting this requirement was requested ,

by October 1, 1980, and-the additional inforcation requested by January 1, 1982.

Resoonse i

N L'12 G 0573, item 2.1.9, Short Tern Lessons Learned, directed the licensee to analyze the small break loss-of-coolant accidents.

This task was performed by the General Electric Company under the direction of the 3UR Owners Group, and submitted to the NRC for their review in NEDO 24703, dated August 1979. We have reviewed this matter with the Chairnan of the BWR owners Group, and concur I with this plan to have General Electric Company, under the direction of the Owners Group, to provide the additional '

information as requested. . Additionally, we have been informed l that Mr. S. J. Stark of the General Electric.Conpany discussed I

with Mr. 3. G. Eisenhut of the NRC, on September 24, 1980, the 4

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Mr. D. C. Eisenhut Page 5 .

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date for submitting a schedule for implenentation and was

, informed by'Mr. .Eisenhut'that additional time will be granted in i a forthcoming revision to the Septenber 5, 1980 letter.

3. 7eouirement: High Range Effluent Noble Gas' Monitors (II.F.l(l))

Reference 3 provides additional design criteria for

upgrading the noble gas effluent-monitors by October 1, 1981..

i Resoonse This requirement parallels item 2.1.3b of NUREG 0578, Short Tern Lessons Learned. Three new monitoring systems we e installed ~

earlier this year to meet the NUREG 0573 requirements. A letter from R. 'I . Reid, NRC - Division of Licensing, to E. G. Sauer, states that Philadelphia Electric Company has satisfied the NRC requirements related to Item 2.1.3.b of the TMI-2 Short Term

! Lessons Learned requirenents and Item III D;2.1 of the TMI Action l

Plan (NUREC 0660). In light of the revised requirements for this system specified in the September 5, 1930 letter from D. G.

Eisenhut, it is not clear at this time whether any further action regarding these monitors is required by Philadelphia Electric Coopany. We propose that the modifications previously implemented, remain as an acceptable response to the requirement

[ for upgrading the noble gas monitors.

9. Recuirenen.: Performance Testing of Relief and Safety Valves (Item I I~ . D .1 of reference 3)

A plant specific submittal for safety and relief valves is

! required by July 1981.

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Resoonse l

The Peach 3otton type safety and relief valves are included in the scope of the prototype qualification testing to oe performed under the auspices of the 3UR Owners Group. We are providing the l necessary support through the Owners Grous to develop and complete the testing program. The best effort for the owners Group to complete the qualification testing is July 1, 1981.

Additional time will be necessary to evaluntu the data and provide a plant specific submittal. We propose that the schedule l presented in correspondence dated September 17, 19GO, D. 3.

l flaters, Chairman of the BUR Owners Group,-to R. 3. Vollmer, NRC, be considered as an acceptable schedule to satisfy this requirement. The proposed schedule is as follove:

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': r . D. G. Cisenhut Page 6 connlete test facility: December 31, 1930 Complete s h . :c e .i e u n tests: February 15, 1931 Complete operability tests: July 1, 1931 Complete test reports: Deconher 31, 1931 Should you have any questions regarding this natter, niease do not hesitate to contact us.

Very truly yours,

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