ML20094B251

Responds to Generic Ltr 84-09 Re Recombiner Capability Requirements of 10CFR50.44.Facility Complies W/Technical Criteria Established in Generic Ltr 84-09.Recombiner Capability Not Required

ML20094B251
Person / Time
Site:	Peach Bottom
Issue date:	07/31/1984
From:	Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
GL-84-09, GL-84-9, NUDOCS 8408060321
Download: ML20094B251 (3)

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A PHILADELPHIA ELECTRIC COMPANY 23ol M ARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 SHIELDS L. DALTROFF et Er*l,UI'E"chon July 31, 1984 Docket Nos. 50-277 50-278 Mr. D. G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission

. Washington, DC 20555

SUBJECT:

Peach Bottom Atomic Power Station, Units 2 and 3 - Recombiner Capability Requirements of 10 CFR 50.44 (c) (3) (ii)

REFERENCES:

(a) T. B. Conner (Conner & Moore) letter to S. J. Chilk (NRC) dated April 8, 1982 (b) T. J. Dente (BWROG) letter to D. G. Eisenhut (NRC) dated June 21, 1982 (c) W. G. Counsil (NUSCo) letter to W. J. Dirks (NRC) dated August 6, 1982 (d) W. G. Counsil (NUSCo) letter to W. J. Dirks (NRC) dated November 5, 1982 (e) USNRC Generic Letter 84-09 dated May 8, 1984 (f) S. L. Daltroff (PECo) letter to J. F. Stolz (NRC) dated June 2, 1983

Dear Mr. Eisenhut:

This letter responds to Generic Letter 84-09 regarding recombiner requirements of 10 CFR 50.44 (c) (3) (ii) . In reference

-(a), Philadelphia Electric Company petitioned for reconsideration and alternatively exemption from Interim Requirements related to Hydrogen Control, 10 CFR 50.44 (c) (3) (ii) . This petition was based on our contention that inerting of the primary containment was the primary means of_ combustible gas control used at Peach Bottom and that, as such, the recombiner capability requirement did not apply.

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Mr. D. G. Eisenhut' July 31, 1984 Page 2

-The Boiling Water Reactor Owners' Group (BWROG) and Northeast Utilities (NUSCo) have subsequently submitted substantial information (references b, c & d) which demonstrates that post-LOCA recombiner capability is not required for BWR's s with inerted Mark I containments. In Generic Letter 84-09 (reference e), the NRC acknowledged the validity of the BWROG contentions and stipulated that "a Mark I BWR plant will be found

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not to rely upon purge /repressurization systems as the primary means of hydrogen control if certain technical criteria are satisfied". Thus, plants meeting these technical criteria are not required to have recombiner capability per 10 CFR 50.44 (c) (3) (ii) .

BWROG generic studies were directed by Philadelphia

, Electric Company personnel and specifically apply to Peach Bottom Units 2 and 3. Additionally, NUSCo submittals on this topic have been reviewed and confirmed to apply to the Peach Bottom units.

Inerting is the primary means of combustible gas control utilized at Peach Bottom and a safety-grade Containment Atmosphere Dilution (CAD) System has been provided as a backup. The CAD system is described in FSAR Supplement I, Response to Question

.14.6. The following Peach Bottom Atomic Power Station information is submitted relative to the specific criteria stated in Generic Letter 84-09:

1) Technical Specification 3.7.A.5.a requires that the containment atmosphere be maintained at less than 4%

oxygen, i 2) Pneumatic control systems inside containment are supplied with recycled containment atmosphere by the Primary Containment Instrument Gas System as described

!. in FSAR Supplement 1, Response to Question 10.4.

L Essential pneumatic use'rs inside containment (i . e . , ADS ,

SRV's) are provided with a safety-grade backup supply derived from cylinders of nitrogen gas as described in l reference (f).

3) There are no known potential sources of oxygen in containment following an accident other than radiolysis of the reactor coolant. Appropriate guidance for the

. management of combustible gases under all accident situations will be a part of the BWR Owners' Group l

Emergency Procedure Guidelines, Rev. 4. Plant specific procedures based on this guidance will be implemented following NRC approval of the EPG's. In the interim,

-post-accident combustible gas control practices will be in accordance with plant Technical Specificaion 3.7. A.5 j and CAD operating procedures Sl7.1, S17.2, and S17.3.

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July 31, 1984 Mr . D. G. Eiser. hut Page 3 i~ Ba' sed on the above, it is concluded that Peach Bottom is in compliance with the technical criteria established in Generic Letter 84-09 and that recombiner capability is therefore not required.

Please contact us if further information on this topic Very truly yours,

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cc: A. R. Blough, site Inspector

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