ML20092P286

Requests Extension for Submittal of Responses Re Compliance W/Reg Guide 1.97 Until 840928 & NUREG-0737,Item II.K.3.18 Until 840914

ML20092P286
Person / Time
Site:	Peach Bottom
Issue date:	06/28/1984
From:	Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, RTR-REGGD-01.097, RTR-REGGD-1.097, TASK-2.K.3.18, TASK-TM NUDOCS 8407060138
Download: ML20092P286 (2)

Text

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'9 PHILADELPHIA ELECTRIC COMPANY 23O1 M ARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 SHIELDS L. DALTROFF aul%',U"JJ,"I,o- June 28, 1984 Docket No. 50-277 .

Mr. Darrell G. Eisenhut, Director Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555

SUBJECT:

Peach Bottom Atomic Power Station Units 2 and 3 NUREG-0737, Item II.K.3.18 and Regulatory Guide 1.97

REFERENCE:

(1) Letter from G. L. Daltroff, PECo, to D. G. Eisenhut, dated April 15, 1983

Subject:

PBAPS Response to NUREG-0737, Supplement 1 (2) Letter from S. L. Daltroff, PECo, to D. G. Eisenhut, dated January 16, 1984

Subject:

PBAPS Implementation of NUREG-0737, Supplement 1, Regulatory Guide 1.97 (3) Letter from S. L. Daltroff, PECo, to J.F. Stolz, NUREG-0737, Item II.K.3.18, ADS Actuation, dated July 15, 1983

Dear Mr. Eisenhut:

This letter requests an extension in the commitment dates for the submittal of two responses regarding compliance with Regulatory Guide 1.97 and NUREG-0737, II.K.3.18.

The reference (1) letter established NRC commitment dates for the submittal of two reports detailing Peach Bottom's compliance with the design and qualification criteria specified by Regulatory Guide 1.97. The first report was submitted January 16, 1984, as two attachments to the reference (2) letter. This report detailed Peach Bottom's compliance with all Regulatory Guide 1.97 variables except " Primary Containment Isolation Valve Position Indication." The report concerning primary containment isolation valve position indication was committed to the NRC by 8407060138 840626 I i i PDR ADOCK 05000277 p PDR

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'Mr. Darrell G. Eisenhut June 28, 1984 Page 2

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July 1, 1984, in the reference (1) and (2) letters. The Commission, by Order dated June 14, 1984, confirmed this commitment date.

The review of the primary containment isolation valve i position indication portion of Regulatory Guide 1.97 involves an extensive investigation of the design (including power sources, cable routing, equipment qualification, quality assurance, ,

control room display) of the approximately 160 isolation valves -

on each unit. At the time the NRC commitment was made, the date appeared to be realistic. We have been supporting this effort on an overtime basis. Our best estimate as to the date for submittal of the report to the NRC is now September 28, 1984.

Accordingly, we request an extension in the schedule to September 28, 1984 for submitting the report addressing our plans for r compliance with the primary containment isolation valve position indication requirements of Regulatory Guide 1.97.

The reference (3) letter contains Philadelphia Electric Company's commitment to modify the logic of the automatic depressurization system (ADS) on Peach Bottom APS Units 2 and 3 ,

in response to Item II.K.3.18 of NUREG-0737, " Clarification of TMI' Action Plan Requirements." Additionally, the letter committed to the submittal of a Technical Specification amendment application addressing this modification' by June' 30, 1984. The modification involves the bypass of the high drywell pressure signal after a specific time interval following the receipt of a low reactor water level signal and the addition of a manual inhibit switch. The time delay is determined by a plant-specific analysis. This analysis was recently completed by our consultant and is undergoing in-house review. This review, and the  ;

preparation and review of the required Technical Specification amendment application, will necessitate an extension in the schedule for submitting the application until September 14, 1984.

Should you have any questions regarding this matter, please do not hesitate tx) contact us.

Very truly yours,'

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s s WCB:vdw cc A. R. Blough, Site Inspector ej