ML20076D533
| ML20076D533 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 07/26/1991 |
| From: | Skolds J SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | George Wunder NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.D.3, TASK-TM NUDOCS 9107290223 | |
| Download: ML20076D533 (2) | |
Text
l, N.
South Carohna Electric & Gas Cornpany John L Skolds i
P O. Bcx S3 Vere Premdent 1
Je%tnwme. SC ?9%5 Nvdem Opera!cns (803; 3 6 4040
.SCE8G-Jllt 2 61991 Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC. 20555 Attention: Mr. G. F. Wunder Gentlemen:
Subject:
VIRGIL C. SUMMER NUCLEAR STATION DOCKET N0. 50/395 OPERATING LICENSE NO. NPF-12 POSITION ON NUREG-0737 (MRB 891105)
As a result of discussing the following matter with Mr. R. C. Haag (Senior Resident Inspector) and George Wunder (Project Manager), South Carolina Electric & Gas Company (SCELG) is submitting this letter to state its position regarding the requirements of NUREG-0737. Item II.D.3.
_The requirements of NUREG-0737. Item II.D.3 are stated as follows:-
Position i
Reactor Coolant System relief and safety valves shall be provided with a positive-indication in the control room derived from a reliable valve-position detection device or a reliable indication of flow in the valve discharoe pipe.
There is also a statement of clarification:
Clarification i-l 1.
The basic requirement is.to provide the operator with unambicuous indication of valve position (open or closed)-
l so that operator actions can be taken.
VirgilC.SumerNuclearStation(VCSNS)utilizesseismicallyqualified acoustic monitors on each safety valve tailpipe to satisfy the requirements of. Item II.D.3.
During two events at VCSNS where a pressurizer safety valve l
actually lifted (ref. LERs89-011 and 89-015), it was noted that the acoustic L
monitors for the other two safety valves indicated a partial opening of their respective valves due to the noise transmitted from the lifted valve.
Even though-these indications did not impact the course or outcome of either event, VCSNS management requested that the indications, as received, should be examined against their design requirements.
1 9107290223 910726 PDR ADOCK 05000395
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Document Control Desk MRB 891105 Page 2 i
A review of SCE&G's design with respect to item 11.D.3 was evaluated, yielding the following results:
1.
The Acoustic Monitoring System does provide unambiguous indication and alarm that at least one pressurizer safety valve is open.
2.
It also provides unambiguous indication that all pressurizer safety valves are closed.
3.
The procedurally prescribed actions for a lifted pressurizer safety valve are continuous actions that are to be followed until all valves indicate closed.
Therefore, the safety significance of the requirrment for a " reliable indication of flow in the valve discharge pipe" (nly involves the ability to have accurate indication of both "no flow" and ".ny flow" conditions. The present acoustic monitoring system meets these
- quirements.
This determination is supported by Regulatory Guide 1.97 which classifies the pressurizer safety valve status as a variable with a required range of indication of closed /not closed.
In conclusion, SCE&G takes the position that the Acoustic Monitoring System fully meets the indication requirements of NUREG-0737, item II.D.3, for the pressurizer safety valve position.
If you should have any questions concerning this matter, please contact David Haile at (803) 345-4322.
Very truly yours, b
John L. Skolds DCH:JLS:grs
~
c:
- 0. W. Dixon Jr.
R. R. Mahan R. J. White S. D. Ebneter General Managers NRC Resident Inspector J. B. Knotts Jr.
NSRC File (819.31)
NUCLEAR EXCELLENCE - A SUPNER TRADITION!
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