ML20087M852
| ML20087M852 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/26/1984 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8404020063 | |
| Download: ML20087M852 (5) | |
Text
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o PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699
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O PHILADELPHI A. PA.19101 E
JOHN S. KEMPER VICE PRESIDENT ENG4 NEE RSNG AND RESE ARCH Mr. A. Schwencer, Chief Licensing Branch No. 2 U. S.
Nuclear Regulatory Commission Washington, D.C.
20555
Subject:
Limerick Generating Station Design Verification Program -
Limerick Unit 1
References:
1.
Letter from NRC - D.
G.
Eisenhut to PECO - E.
G.
Bauer, Jr. dated January 10, 1984.
2.
Telecon between NRC - A. Schwencer and R.
E. Martin and PECO -
J.
T.
Robb on February 15, 1984.
Dear Mr. Schwencer:
The reference 1 letter stated "....the NRC staff has been seeking additional assurances from applicants for operating licenses that the design process used in constructing their plants has fully complied with NRC regulations and licensing commitments."
It also requested that we "....present any plans (we) have for assuring that (Limerick) has been designed and constructed in accordance with the regulations and safety analysis report commitments."
Philadelphia Electric Company believes that Limerick has been and continues to be designed, constructed and tested in accordance with NRC regulations and our licensing commitments.
Because the conduct of the project has involved Philadelphia Electric Company deeply in all aspects of design activities, we have developed confidence that we are building a safe, efficient plant which meets all applicable criteria.
This confidence is based upon many factors including:
1.
In-depth design and calculational reviews of all safety systems at Limerick by PECO responsible system engineers and managers.
2.
Multiple detailed walkdowns of systems installed at the plant.
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The evaluation of the project by the Institute 4>-
i for Nuclear Power Operations.
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4.
The continuing NRC review of the Limerick project
?j including nearly a decade of inspections at the q;
site, the NRC operating license review of our
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application and the periodic Systematic Appraisal
}l of Licensee Performance (SALP) reports.
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The results of our ongoing Quality Assurance
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Program including a series of audits of the design
[g control process.
At the same time, we reuli::e that the additional I
assurance that would be gained would aid the licensing i
process in general if an Independent Design Verification J
d Program (IDVP) were to be performed.
Therefore, as discussed in the reference 2 telecon, we have elected to
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have an IDVP performed for Limerick.
The purpose of this b
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letter is to present briefly the proposed scope of our P
review, to inform you of our selection of a contractor to 4
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perform this review and to discuss the schedule for conduct 7
of the review.
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P The objective of the IDVP is to provide an independent h
assessment of the adequacy of the design process used in the construction of Limerick.
The review will achieve this F
objective by pursuing a two phased approach.
First, a broad
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review of the design control process will be performed.
d This review will evaluate the adequacy of the design control
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process which has been applied to the design of the plant.
.I The second phase will evaluate the application of the design R
control process to a selected system within the plant.
This j
review will include an evaluation of the conformance of the s
final design with design criteria and licensing commitments.
It will test the validity of the assumptions macle and the a
p methods used in the design process.
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1 The following aspects of the design process applied to S
the system selected for the second phase of the IDVP will be b
reviewed:
mechanical, electric power, control systems, H
structural and equipment qualification.
The IDVP will also h
include a walkdown of the system as installed in the plant.
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j We have carefully considered to what system this second
?d phase of the IDVP should be applied.
The system selected L
must meet several criteria if the system reviewed is to be C
truly representative of the overall plant design.
These 3
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include:
- 1 i
1.
The design must be safety related.
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.2.
The design must represent a cross section of technical disciplines.
3.-
The design nust include interfaces between the architect engineer' ' (Bechtel).the nuclear steam
' supplier (General Electric).and Philadelphia Electric company over a significant period of time.
4.
The design should have undergone changes over the study period in' order to fully evaluate the design control system.
After consideration of the objectives of the review and the criteria which the system selected for the second phase of the - IDVP should meet, we have selected the primary components:of.the portions of the core spray system listed
.below as the subject of the review:
- 1..
Loop A of the core spray system in the drywell from the reactor vessel to the outboard containment isolation valve.
2.
Loop A'of the core ' spray system in the reactor
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building, from the outboard containment isolation valve to the suppression poal penetration.
3.
One core spray pump.
We have selected CYGNA Energy Services to perform the IDVP and have awarded'a contract to them for the work.
We believe'CYGNA is well qualified to undertake a project of
-this scope.
We anticipate that CYGNA's experience,
-independence and total responsibility for the conduct of the review'will assure that the product.of the review will be of substantia 1 use - to both the < NRC and Philadelphia Electric
~
Company in providing additional assurance of the adequacy of
. design and construction..
- We'are plan'ning to proceed with the conduct of the IDVP
. as follows:
1.
Develop'the detailed program plan for presentation
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to the NRC staff.
2.-
~ Meet with the staff to review the program plan in detail'and. submit the program plan formally to the
. staff.
m.
a-I' 3.
After receipt of the staff's written concurrence with the program plan, authorize CYGNA to begin the review as independent contractor.
We are currently meeting with CYGNA to establish the administrative procedures which will be followed during the review.
CYGNA is developing the detailed program plan for the conduct of the IDVP so that the plan may be presented to the NRC as discussed above.
The final report on the IDVP will be available for submission to the staff about 13 weeks after receiving your formal concurrence with the program plan.
We believe that CYGNA will be ready to present the
_ program plan on or after April 12, 1984.
We would appreciate your scheduling a meeting for the presentation so that the review can begin in
- a. timely fashion.
Please contact Mr. J. T. Robb to make arrangements for the meeting.
Sincerely, Sl&f JTR/gra/032184955 cc:
See Attached Service List i
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-- C ccr Judge Lawrence'Brenner Judge Peter A.. Morris.
l Judge Richard F. Colei Troy B.. Conner, Jr., Esq.
Ann P.;Hodgdon, Esq.
Mr. FrankiR.Rmano
.l:Mr. Robert L.' Anthony
.Mr. Marvin I. Iewis Charles W.~-Elliot, Esq.
- Zori G. Ferkin, Esq.
I
- Mr. 'Ihanas Gerusky Director, Penna. Emergency
. Management Agency 4
Mr.jSteven P. Hershey.
~
Angus..Iove, Esq..
Mr. Joseph H. White, III
[-
David Wersen,'Esq.
Robert J. Sugarman, Esq.
Spence W.. Perry, Esq.
Jay M.' Gutierrez, Esq.
Atanic Safety.& Licensing c
Appeal Board.
Atanic Safety & Licensing Board Panel Docket & Service Section Martha.W. Bush, Esq.
James Wiggins Mr. Tinothy R.. S. Canpbell
.Phyllis Zitzer
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