ML20069A767
| ML20069A767 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 03/08/1983 |
| From: | Dixon O SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.2, TASK-TM GL-82-28, NUDOCS 8303160237 | |
| Download: ML20069A767 (9) | |
Text
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SOUTH CAROLINA ELECTRIC & GAS COMPANY PCsf OFFICE 764 CoLuusiA Soum CAnoWNA 29218 o, W. DixoN, Jn, vice PassicaNT March 8, 1983 NUCLeam OpenAnON.
Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Subject:
Virgil C. Summer Nuclear Station Docket No. 50/395 Operating License No. NPF-12 Generic Letter 82-28 Inadequate Core Cooling TMI Item II.F.2
Dear Mr. Denton:
On December 15, 1982, South Carolina Electric and Gas Company (SCE&G) received Generic Letter 82-28 concerning the Inadequate Core Cooling Instrumentation System.
Because of the status of construction and licensing of the Virgil C.
Summer Nuclear Station at the time of issuance of the TMI NUREGs (NUREG 0578, 0660, 0737 and 0696), SCE&G has provided much information to the Staff pertaining to TMI Item II.F.2, Inadequate Core Cooling.
The Staff reviewed and approved our system through cycle one in the Virgil C.
Summer Nuclear Station Safety Evaluation Report, NUREG 0717, Supplement 4, dated August, 1982.
Because of continuing difficulties in procurement and qualification of equipment, SCE&G may utilize different incore thermocouple hardware and core subcooling instrumentation from that described in our letter to the NRC dated June 8, 1981.
Even if the instrumentation described in the June 8 letter is not changed, hardware procurement and delivery limitations prohibit installation until our estimated first refueling outage.
Our Operating License (NPF-12) contains a license condition 2.C.23(d) that requires upgrading of the incore thermocouple wiring and qualification of isolators, reference junction boxes and connectors prior to startup after the first major shutdown or refueling outage af ter June, 1983.
However, the Final Rulemaking on Environmental Qualification of Equipment, 10CFR50.49, (effective Feburary 22, 1983) states that final qualification of safety related equipment is not required until the second refueling outage after March 31, 1982 or by f
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Mr. Harold R. Denton Generic Letter 82-28 March 8, 1983 Page #2 March 31, 1985 whichever is earlier. Additionally, this rule supersedes all previously imposed dates and no change to the license is required.
It is likely that the March 31, 1985 date for completion of equipment qualification will apply to the Virgil C. Summer Nuclear Station.
The Reactor Coolant Inventory Tracking System at the Virgil C.
Summer Nuclear Station is the Westinghouse Reactor Vessel Level Instrumentation System (RVLIS) as described in FSAR Section 7 and will not be changed.
This Westinghouse RVLIS has been approved by the Staff as documented in Generic Letter 82-28.
Appendix 1 to this letter addresses the additional information and references to previous submittals as requested in Generic Letter 82-28.
If different instrumentation than that described previously will be utilized, SCE&G will provide information to the Staff concerning any changes made to the system, along with schedules for additional submittals by September 1, 1983.
If you have any questions, please let us know.
Very truly yours, f
O. W.
Dixon, Jr.
NEC:OWD/fjc Attachmen$
cc:
(See Page #3)
Mr. Harold R.
Denton Generic Letter 82-28 J
March 8, 1983 Page #2 i
cc:
V. C.
Summer l
E.
C.
Roberts H. N. Cyrus T.
C. Nichols, Jr.
O. W.
Dixon, Jr.
M. B.
Whitaker, Jr.
J.
P.
O'Reilly H.
T. Babb D. A.
Nauman C. L. Ligon (NSRC)
W.
A. Williams, Jr.
R. B.
Clary O.
S.
Bradham A.
R.
Koon C.
A.
Price G. J. Braddick J. C. Miller J. L.
Skolds J.
B.
Knotts, Jr.
B. A.
Bursey NPCF File
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APPENDIX 1 Reference Deviation or Explanation Schedule (1-a) Letter
- a. No deviation for RVLIS - Generic N/A from letter 82-28 states that the T.
C.
Nichols to Westinghouse RVLIS is considered H.
R. Denton by the NRC to be an acceptable dated 6/8/81 Reactor Coolant Inventory Tracking System.
Letter from
- b. No additional displays required March 31, T.
C. Nichols to for indication of Inadequate Core 1985 H.
R.
Denton Cooling.
However, the present dated 7/20/82 core subcooling monitor which also provides backup thermo-couple readout, may be replaced by a similar system that is qualified and provides the necessary isolation.
- c. A minimum of sixteen thermo-March 31, couples, two in each quadrant 1983 for each channel, will be upgraded to meet NUREG 0737 requirements.
No deviation.
(1-b) Letter No deviation N/A from T.
C. Nichols to H.
R. Denton dated 6/8/81 (1-c) Letter Deviations and planned modifications N/A from are described in (1-a)(1-b) above.
T.
C.
Nichols to H.
R. Denton dated 6/8/81
- 2) Letter from No deviation T.
C. Nichols to H.
R.
Denton i
dated 6/8/81
- 3) Letter from If the system as presently des-March 31, T.
C. Nichols cribed in the reference remains as 1985 to H. R.
Denton the final system, then the addi-dated 6/8/81 tional testing stated in the reference is applicable.
If the system is changed as described in (lb) above, then descriptions of testing and qualification will be provided in a future submittal.
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Page #2 APPENDIX Reference Deviation or Explanation Schedule
- 4) Letter from 4.1 RVLIS -No deviation N/A T. C. Nichols to 4.2 Refer to attachment 1 H.
R. Denton dated 6/8/81
- 5) Letter from No deviation N/A T.
C. Nichols to H.
R.
Denton dated 6/8/81
- 6) Letter from See Table below T.
C. Nichols to H.
R. Denton dated 6/8/81 TABLE Equi m nt Installation Calibration Qualification Testing 1.
RVLIS Couplete Conplete Conplete Conplete 2.
Core Sub-Conplete Couplete See text Conplete cooling Monitors 3.
Incore Conplete Conplete Not required Couplete Thermocouples (See R.G. 1.97 Rev. 3 Draft I) 4.
Cabling for March 31, 1985 N/A March 31, 1985 N/A 16 qualified TCs 5.
Qualified March 31, 1985 N/A See text March 31, reference 1985 junction boxes and connectors 6.
Qualified isolators frcan cutput March 31, 1985 N/A March 31, 1985 March 31, of subcooled 1985 monitor to process com-puter and TSC crutputer a
Page #3 APPENDIX Reference Deviation or Explanation Schedule
- 7) NRC Audit No deviations - Virgil C.
Summer N/A Report 50-395 EOPs were found acceptable as 82-29, documented in SER page #22-50.
Virgil C.
Summer Nuclear Station Safety Evaluation Report (NUREG 0717)
Page 22-50
- 8) NRC Audit A program for updating the N/A Report 50-395 Emergency Operating Procedure based 82-29 on the Westinghouse Owners Group ERG Guidelines is being developed in accordance wi'h Generic Letter 82-33, Supplement 1 to NUREG 0737
- 9) Letter from No deviations N/A T.
C. Nichols to H. R. Denton dated 6/8/81
Page #4 APPENDIX 1 ATTACHMENT I NUREG 0737 II.F.2 Design and Qualification Criteria for Pressurized Water Reactor Incore Thermocouples Reference Deviation or Explanation Schedule
- 1) Letter from No de'11ation N/A T.
C.
Nichols to H.
R.
Denton dated 6/9/81
- 2) Letter from As indicated in our June 8, N/A T.
C. Nichols 1981 letter, the alarm and to H.
R.
Denton trend typewriters have been dated 6/8/81 replaced with high speed printers.
Computer push-button controls have been relabelled to enhance readability and to minimize substitution errors.
- 3) Letter from No deviation N/A to H.
R.
Denton dated 6/8/81
- 4) NRC Audit The procedure for use of the N/A Report 50-395 incore thermocouple displays 82-29 has been reviewed and approved (see Audit Report 82-29).
The use of the primary and backup displays is described in other sections of this report.
The reactor operators and shift technical advisors receive simulator training and classroom instruction on the emergency operating procedures dealing with Inadequate Core Cooling.
Additionally, operators receive training on Mitigating Core Damage.
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Page #5 APPENDIX 1 ATTACHMENT I NUREG 0737 II.F.2 Design and Qualification Criteria for Pressurized Water Reactor Incore Thermocouples Reference Deviation or Expalantion Schedule
- 5) Letter from The addition of the Subcooling March 31, T.
C. Nichols Monitor and RVLIS Instrumenta-1985 to H.
R.
Denton tion in the Control Room was dated 6/8/81 reviewed during the Human Factor Engineering Evaluation and Letter from Improvement Program for Virgil T.
C. Nichols C. Summer Nuclear Station.
This to H.
R.
Denton review and the NRC Staff dated 4/30/82 Acceptance of it are documented in the references.
The deviations Letter from from the criteria of NUREG 0737, T.
C. Nichols to Attachment 1 and Appendix B are H.
R. Denton identified and justified in the dated 2/23/82 referenced documents.
A minimum of sixteen thermocouples, two in each SER Supp. #4 quadrant for each channel, along (pp 22-5,6) with associated cabling, connectors, junction boxes and penetrations SER Supp. #1 meeting the requirements of NUREG (pp 22-41-42) 0737 will be installed by March 31, 1985.
- 6) Letter from The deviations are described in N/A T.
C. Nichols the referenced response to NUREG to H.
R.
Denton 0737 II.F.2, Attachment 1.
dated 6/8/81
- 7) Letter from The deviations are described in the T.
C. Nichols referenced document and in other to H.
R.
Denton sections of this response.
dated 4/30/82
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Page #6 APPENDIX 1 APPENDIX B NUREG 0737 II.F.2 A.
RVLIS Reference Deviation Letter from T.
C.
Nichols to None H. R. Denton dated 12/30/80 B.
CORE SUBCOOLING MONITOR Reference Deviation Letter from T.
C. Nichols to Deviations are H. R. Denton dated 6/8/81 discussed in the references.
C.
CORE EXIT THERMOCOUPLES Reference Deviation Letter from T.
C. Nichols to Deviations are H. R. Denton dated 6/8/81 discussed in the reference.
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