ML20070P043

Corrects Errors in 810430 Description of Licensed Operator Training Program & Justifies Lack of specific-event Oriented Procedure for Loss of Instrument Air

ML20070P043
Person / Time
Site:	Peach Bottom
Issue date:	12/28/1982
From:	Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Stolz J Office of Nuclear Reactor Regulation
References
NUDOCS 8301260025
Download: ML20070P043 (3)

Text

www ggy- gggy.m- ggggg a e h PHILADELPHIA ELECTRIC COMPANY 230) M ARKET STREET P.O. BOX 8699 PHILADELPHI A PA.19101 SHIELDS L D ALTROFF

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December 28, 1982 Docket Nos. 50-277 50-278 -

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e Mr . J. F. Stolz, Chief Operating Reactors Branch #4 '

Division of Licensing O. S. Nuclear Regulatory Commission Washington, D. C. 20535

SUBJECT:

Licensed Operator Training Program Peach Bottom Atomic Power Station

Dear Mr. Stolz:

This letter corrects errors in a description of the Peach Gottom Atomic Power Station licensed operator training 30, 1981, and t

[\programsubmittedunderacoverletterdatedAprilprovides justification for not ha ,

pprocedure for loss of instrument air. The need for this e correspondence was identified by the NRC Region I inspectors at a meeting on December 8, 1982.

The Operator Licensing Branch, in a phone conversation on November 21, 1980 requested the transmittal of a description of the currrent licensed operator training program. The information was subsequently submitted on April 30, 1981. At the tima of the submittal, the training program was being revised to reflect the new NRC training criteria issued in a March 28, 1980 letter (H . R. Denton to All Power Reactor Licensees). The description submitted represented an early draft of the proposed new training program and contained several errors that were subsequently corrected prior to the implementation of the new program. The corrections are as follows: )3, 8301260025 821228 PDR ADOCK 050002{ I V

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Mr . J. F. Stolz, Chief Page 2 l

1. Delete item 8, loss of instrument air, on page 2 from the description of the Licensed Operator Requalification Program submitted with the April 30, 1981 letter. The NRC training criteria presented in the March 28, 1980 letter specified training in a loss of instrument air event at Peach Bottom if simulated plant specific.

Since a Peach Bottom specifir loss of instrument air a9ent is not simulated at the Training Simulator, this event is not identified in the current description of the training program. However, the current licensed operator training program, and the training associated with the new symptomatic emergency procedures, do address operator responses to plant conditions which can result from a loss of instrument air. For these reasons, we believe that the Peach Bottom training program is in compliance with the NRC criteria delineated in the March 28, 1980 letter.

2. Delete item 22, Malfunction of reactor coolant pressure / volume control system, on page 3 from the description of the Licensed Operator Requalification Program. This mode of control is not applicable to the BWR design. Malfunctions of automatic control systems which affect reactivity are covered under item 21, page 3.

The other issue raised at the December 9, 1982 meeting involved compliance with Section 6.8.1 of the Peach Bottom Technical Specifications. Section 6.8.1 requires written procedures that conform to the requirements of Regulatory Guide 1.33. The Guide describes an acceptable method of complying with the requirement for written procedures. Included in the list of j

procedures identified in the Guide is a " loss of instrument air" procedure. Previous discussions with the NRC inspector concluded that a loss of instrument air procedure was not necessary because of the low probability that such an event would occur at Peach l

Bottom, and the availability of emergency procedures that address l plant conditions that may result from this event. The new symptomatic procedures, developed in response to the requirements of NUREG 0737, Item I.C.1, address plant conditions resulting from a wide spectrum of events, and therefore meets the intent of Regulatory Guide 1.33. The new procedures are based on the Emergency Procedure Guidelines developed by the BWR Owners' Group and previously submitted to the NRC for review.

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MNEYO4 Mr . J. F. Stolz, Chief Page 3 Should you have any questions or need additional information regarding this matter, please do not hesitate to contact us.

Sincerely

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cc: R. A. Blough Site Inspector - Peach Bottom R. W. Starostecki, Region I P. Beckhan Operating Licensing Branch Nuclear Ragulatory Commission Washington, D. C. 20555

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