ML20071E402
| ML20071E402 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 03/08/1983 |
| From: | William Jones OMAHA PUBLIC POWER DISTRICT |
| To: | Clark R Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 GL-82-28, LIC-83-056, LIC-83-56, NUDOCS 8303150222 | |
| Download: ML20071E402 (9) | |
Text
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Omaha Public Power District 1823 HARNEy a OMAHA. NEBRASMA 681 E
PH 36-4000 AREA CODE 402 LIC-83-056 Mr. Robert A.
Clatk, Chief U.
S.
Nuclear Regulatory Commission Of fice of Nuclear Reactor Regulation Division of Licensing Operating Reactors Branch No. 3 Washington, D.C.
20555
Reference:
Dochet No. 50-23 5
Dear Mr. Clark:
Generic Letter 82-28 Instrumentation for Detection of Inadequate Core Cooling Attached in the District's respor.se to Generic Letter 82-28 which requested information on the status of our propcsed inadequate core cooling ins trurrentation (ICCI) system.
The District has purchased and will install the Combustion Engineering heated junction thermocouple system to monitor reactor coolant systen inventory.
Much of the field preparation and hard-warc installation for this system and the upgraded core exit thermocouple system will be performed during the 1983 refueling outage.
Due to the complex interaction between the requirements of Generic Letter 82-28 and those of NUREG-0737, Supplement 1, schedules for engineering and installation of the ICCI system must be integrated with those for the other requirements.
Thus, the schedule for the ICCI system installation and operation will be addressed in the District's response to Generic Letter 82-33 (NUREG-0737, Supplement 1).
Sincerely,
%db W. C.l Jones 8303150222 830308 Division Manager PDR ADOCK 05000285 Production Operations P
PDR WCJ/TLP:jmm Attachment cc:
LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.
Washington, D.C.
20036 b
Mr. L.
A. Yandell, NRC Senior Resident Inspector
4 Attachment RESPONSE TO GENERIC LETTER 82-28 Request 1 Within 90 days of the date of this letter, identify to the Director, Division of Licensing, the design for the reactor coolant inventory system selected and submit to the Director, Division of Licensing, detailed schedules for its engineering, procurement and installation.
References to generic design descriptions and to prior submittals containing the required information, where applicable, are acceptable.
Response
The District has selected and purchaned the Combustion Engineering heated junction thermocouple (HJTC) system (including IE signal processing).
Reactor internal modifications and signal processing equipment installation will begin during the 1983 refueling outage.
Engineering for a sensor-to-read-out system is not yet complete.
Since this work is directly related to the work being done by the District for Generic Letter 82-33 (Supplement 1.to NUREG-0737, Requirements for Emergency Response Capability), the schedule for completion of the engineering, installation and operation will be provided as part of the District's response to Generic Letter 82-33.
Request 2 i
Within 90 days of the date of this letter review the status of 1
conformance of all components of the ICC instrumentation system, including subcooling margin monitors, core-exit thermocouples, and the reactor coolant inventory tracking system, with NUREG-0737, Item II.F.2 and submit a report on the status of each conformance.
1
Response
Appendices 1 and 2 of this section provides the generic inform-ation which (based on work done to date) the District believes is applicable to the purchased system.
When available, specific information is also cited.
The District believes that, in general, the use of the Combustion Engineering system and the guidance provided in NUREG-0737 will permit a plant specific system to be implemented.
The information cited in the generic documents will be factored into the detailed design.-
When the system design is complete, a final version of Appendices 1 and 2 (and any necessary supporting documents) will be prepared with any deviations noted and analyzed.
The schedule for this will be provided with the District's response to Generic Letter 82-33.
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~ As-stated in our response to Request 1, the District will factor completion of this requirement for information into the response for Generic Letter 82-33.
Request 3 The installation of the ICC instrumentation system shall be completed during the earliest refueling shutdown consistent with the existing status of the plant and practical design and procure-ment considerations.
It has becore apparent, through discussions with owners' grcups and individual licensees, that schedules nust adequately consider the integration of these requirements with other TMI related activities.
In recognition of this and the difficulty in implementing generic deadlines, the Commission has adopted a plan to establish realistic plant-specific schedules that take into account the unique aspects of the work at esch pla r.t.
Each licensee is to develop and submit its own plant-specific schedule which will be reviewed by the assigned NRC Project Vanager.
The NRC Project Manager and licensee will reach an agreement on the final schedule and in this manner provide for prompt' implementation of these important improvements while opti-mizing the use of utility and NRC resources.
Response
As detailed in the District's responses to Requests 2 and 3, the schedule for inplementing the inadequate core cooling system can-not be removed from the schedule for NUREG-0737, Supplement 1.
The inadequate core cooling system must meet the requirenents of Regulatory Guide 1.97, have its use incorporated into the new plant specific Emergency Operating Procedures, and meet the criteria of control room design review.
In summary, the District believes a good faith effort is being made to meet the requirements for emergency response.
The District has purchased the Combustion Engineering HJTC system and signal processing system for the HJTC and CET's.
The information generated by these systems will be monitored by the plant computer and displayed on CRT's.
The District has opted to use its limited staff to make maximun use of the 1983 refueling outage to install much of the field hardware.
This effort will (barring delivery or field problems) include installation of upgraded CET's, HJTC probe holder in-stallation, pressure boundaries for the CET's, signal cables for the SPDS and ICC, and new electrical penetrations for the ICC, HJTC and CET cables.
As stated before, the use of the approved CE designed ICC system should permit compliance with NUREG-0737.
The District believes that by maximizing its ef forts aimed at hardware installation during the 1983 refueling outage, the final date of compliance will be sooner than if some other course were pursued.
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APFENDIX 1 GENERIC CEOG D0C.
ITEM SUBMITTED TO NRC DEVIATION SCHEDULE CO2iMENTS 1
1.
Description of the proposed See response to Request 2.
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final system including:
a.
A final design description of CEN-185 l
additicnal instrumentation and (Section 3)
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t display CEN-185, Suppl. 3 1
CEN-181 Question #4 Question #7 Question #8 1
Question #11 CE0G letter (6/1/82) to D. Crutchfield Question #1 I
b.
Detailed description of
Reference:
District's submittal existing instrumentation dated December 31, 1979.
Imple-i systems mentation completed as planned.
i l
I c.
Description of completed or See discussion of response to planned modifications Requests 1, 2, & 3 and summary.
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4 APPENDIX 1 (Continued)
GENERIC CEOG D0C.
ITEM SUBMITTED TO NRC DEVIATION SCHEDULE COMMENIS l
2.
A design analysis and evalua-CEN-185 (App. A)
See discussion of response to tion of inventory trend Request 2.
instrumentation, and test data CEN-185 (Sect. 6 4
to support design in Item 1
& Suppl. 1, 2, & 3) 1 CEN-181 i
Question,#2 CE0G 1etter (6/1/82) to D. Crutchfield 4
Question #1
)
Question #2 4
l Question #3 Question #4 3.
Description of tests planned CEN-185 Suppl. 1, See discussion of response to and results of tests com-2, a 3 Request 2.
pleted for evaluation, quali-fication, and calibration of CEN-185 additional instrumentation (Section 5) 4 CEN-181
- l Question #12 t
i
APPENDIX 1 (Contiimed)
GENERIC CE0G D0C.
ITEM SUBMITTED TO NRC DEVIATION SCHEDULE COMt1ENTS 4.
Provide a table on description CEN-185 Plant specific data will be covering the evaluation of (Section 8) provided as outlined in re-conformance with NUREG-0737; sponse to Request 2.
II.F.2, Att. 1, & Appendix B.
t 5.
Describe computer, software 8 CEN-185 See discussion' of response to display functions associated (Section 3)
Request 2.
with ICC monitoring in the plant.
CEN-185, Suppl. 3 6.
Provide a proposed schedule See discussion of response to for installation, testing &
Request 2.
calibration & implementation of any proposed new instru-mentation or information displ ays.
7.
Describe guidelines for use CEN-185 Generic Emergency Procedure Guide-of reactor coolant inventory (Section 2) lines are not yet issued.
tracking system, & analyses used to develop procedures.
CEN-181 5ee discussion of response to Request 2.
Question #2 CE0G letter (6/1/82) to l
D. Crutchfield Question #1 1
CEN-152, Rev. 1
APPENDIX 1 (Continued)
GENERIC CEOG D0C.
\\
ITEM SUBMITTED TO NRC DEVIATION SCHEDULE COMPENTS Question #2 &
Question #3 8.
Operator instru:tions in CEN-152, Rev.
District Submittal of emergency operating proce-December 31, 1979 New dures for ICC & how these Generic E0P's Not Yet Issued procedures will be modified when final monitoring sys-tem is implemented.
1 9.
Provide a schedule for Lee Response Item 1 Discussion additional submittals This includes the additional required.
plant specific Question **B regarding the CE HJTC System l
l t
1
APPE!! DIX 2 GENERIC CEOG 00C.
ITEM SUBMITTED TO NRC DEVIATION COMMENTS 1.
Environment Qualflfication CEN-185 (Section 5)
See Response Iten 1 CEN-185, Suppl. 3 2.
Single Failure Analysis CEN-181 See Response Item 1 Discussion 1
Question #11 CE0G letter (6/1/82) to D. Crutchfield Question #4 3.
Class IE power sources See Response Item 1 Discussion The District will be installing the CET and ifJTC Signal Processor using an IE Poear Source one from Train A, one from Trai.n 8 4.
Availability prior to an CEN-185, Suppl. 3 accident CEN-181 CE0G letter (6/1/82) to D. Crutchfield Question #44 a
APPENDIX C (Continued)
GENERIC CEOG 00C.
ITEM SUBMITTED TO NRC DEVIA1 ION COMMENTS 5.
Quality Assurance See Response Item 1 Discussion 6.
Continuous indications CEN-185 See Response Item 1 Discussion (Sections 2 & 4) l 7.
Recording of instrument See Response Item 1 Discussion outputs.
8.
Identification of See. Response Item 1 Discussion instruments 4
9.
Isolation CEOG letter See Response Iter 1 for plant specific (6/1/82) to isolation data schedule D. Crutchfield Question #4 i
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