ML20094B873
| ML20094B873 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 08/01/1984 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| References | |
| OL, NUDOCS 8408070289 | |
| Download: ML20094B873 (5) | |
Text
y-1 PHILADELPHIA ELECTRIC COMPANY 23O1 M ARKET STREET P.O. BOX 8699 AUG 01 1984 PHILADELPHI A. PA.19101 (2151841 4502 VICE-PR ESID E NT LMG9 NEE RING AND RESE ARCH
- Mr. A. Schwencer, Chief Docket Nos.:
50-352 Licensing Branch No. 2 50-353 Division of Licensing
-U. S. Nuclear Regulatory Cmmission Washington, D.C. 20555
Subject:
Limerick Generating Station, Units 1 and 2 Information for Equipnent Qualification Branch (EQB) Regarding SER OpenNIssue #6 (Seismic / Dynamic Qualification of Equignent).
Reference:
(1)
" Trip Report for Seismic Qualification Review Team Plant Site Audit",
R. E. Martin (NRC) to E. G. Bauer, Jr.,
(PECO), dated May 31, 1984.
Attachmnt:
(1) Limerick Generating Station, Unit 1:
Justification for Interim Operation File:
GOVT l-1 (NRC)
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Dear Mr. Schwencer:
In response to the two follow-up actions requested by the Seismic Qualification Review Team (SQRr) in reference (1), we are pleased to provide the following information.
1)
Upgrading and modifications to the Limerick Unit 1 RCIC
- turbine _ assembly have been cmpleted except for the installation of threaded taper pins which assist in maintaining alignment after pedestal bolting. The hold down bolts which attach the turbine pedestal to the baseplate have been installed. GE and the turbine assanbly vendor require that taper pins be installed after final (hot) alignment of
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the turbine assembly.
Hot alignment is scheduled after nuclear steam has been applied to the turbine assembly, approximately 6-12 weeks after fuel load, to bring it up to operating temperature and pressure. The schedule for taper pin installation on the Linerick Unit 1 HPCI turbine assembly is the same as described above.
Except for the installations of the threaded taper pins, the modified assenbly is now similar to the turbine which was used for dynamic qualification testing, thereby achieving qualification of the Limerick Unit 1 PCIC turbine assarbly.
No additional maintenance tasks are required due to these mdifications.
8408070289 840001 PDR ADOCK 05000352 g
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[Attaclwent (1).. provides our justification for interiln operation of Limerick Unit 1, until the first refueling outage,- pending -confirmation of the dynamic qualification of the -residual. heat removal service water process radiation nonitor -(RIIRSW PIE) systen for safety essential service as currently comnitted in the Limerick FSAR.
n Should you require any additional infonration, please do not
-hesitate to contact us.-
Sincerely, SYf u
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$l JHA/gra/07108401 cc: :See Attached Service List t
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!cc: ' Judge Lawrence Brenner (w/ enclosure)
--Judge Richard F. Cole (w/ enclosure)
Troy _B.
Conner, Jr., Esq.
' (w/ enclosure) s 0~
Ann-P. Hodgdon, Esq.
(w/ enclosure)
Mr.. Frank R. Romano
.(w/ enclosure)
Mr. Robert L. Anthony (w/ enclosure)
Charles W..Elliot, Esq.
(w/ enclosure)
Zori G.~ Ferkin,uEsq.
(w/ enclosure)
Mr. Thomas Gerusky (w/ enclosure)
' Director,. Penna. Emergency (w/ enclosure)
Management Agency.
Angus R. Love,.Esq.
(w/ enclosure)
David Wersan, Esq.
(w/ enclosure)
Robert.J._Sugarman, Esq.
(w/ enclosure)
Spence W. Perry, Esq.
(w/ enclosure)
Jay-M. Gutierrez, Esq. _
(w/ enclosure)
Atomic Safety & Licensing (w/ enclosure)'
Appeal Board Atomic Safety & Licensing (w/ enclosure)
Board Panel Do'cket & Service Section
.(w/ enclosure)
Martha W. Bush, Esq.
(w/ enclosure)
(w/ enclosure)
Mr. James Wiggins (w/ enclosure)
Mr. Timothy R. S. Campbell Ms. Phyllis Zitzer (w/ enclosure)
Judge Peter A. Morris (w/ enclosure) 5 f-L_
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JUSTIFICATION FOR INTERIM OPERATION
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.,G erating Station, Unit'1, pending confirmation of the dyna-ic is is the justification for interim operation of.the Limerick -
- g qualification of the residual heat removal service water" process y
- radiation monitor (RHRSW PRM) for safety essential service as currently committed in the Limerick FSAR.
-The.RHRSW PRM' detects high radiation levels in the cooling water effluent
,3 (RHRSW) Trom.the-RHR heat exchangers, in case of a heat exchanger tube
.j leak'of radioactive reactor coolant or suppression pool water to the
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- RHRSW system. The effluent RHRSW is routed to the cooling towers (normal) or the spray pond (accident). A RHRSW PRM high radiation signal actuates an alarm ~and automatically closes the RHR SW isolation valves Ty
'and, if sensed at the loop discharge header, shuts off the RHRSW pump.
g OJ The RHRSW PRM consists of a. remote samp' ling station (liquid sample rack / scintillation detector) located in the area of the diesel generators and a-log count rate meter. (LCRM) located in the auxiliary control room, plus alarm and-trip instrumentation. Dynamic qualification test records, f.
applicable'to Limerick, are avai1 @ lc for all of this equipment except for,the LCRM._ There is strong evidencqIthat the LCRM was qualified by 3
test ~.-(seismic bracing was added to the Limerick model LCRM); however, the qualification test records areln9t rea'dily' available.
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,The justification for operating Unit 1.until,the first refueling outage, s
?with the qualification records of the LfRM incompl,ete, is as follows:
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Since the RHRSW PRM is notsrequired to be active safety essential' (1.e. i not required to mitigate the consequences of a b'
iDesign Basis Accident) the only safety concern is the potential effect of a PRM component failure on ellher the Class IE power circuits or on the operation of the safaty essential RHRSW g
system.
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All of the RHRSW PRM components are located in mild environment areas (auxiliary control room and diesel generator areas) where hydrodynamic loads are minor or nonexistent.- All of the components have been qualified, except for the LCRM for which there is strong evidence of qualification. Consequently, PRM component failure is not likely.
3.
All Class IE-power. circuits are redundant and separated, hence d a single PRM electrical cpmmor.ent failure that causes a Class
_ IE power circuit failure' iUwithin the Limerick Design Basis (i.e. failure of a single, active, safety-related component).
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lThere are two RHR heat exchangers, each with its own RHRSW supply system. Hence shutdown and is'olation of one RHRSW supply systett becgse of a PRM component failure is within the Limerick Design Basis (i.e.' failure of a single, active, gafety-relatedcomponent).
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If the shutdown and isolation of one RHRSW supply system results from a false high radiation level PRM trip signal, the operator can manually bypass the signal and reopen the RHRSW
' isolation valves and restart the RHRSW supply pump. The operator can determine if the trip is due to a false high radiation level trip signal because there are two PRMs on the RHRSW supply system for each RHR heat exchanger.
6.
Because of the qualification level of the RHRSW PRM components, the occurrence of multiple failures has a very low probability.
In the. event that previous test records do not become available, we will.present an acceptable solution for implementation at the first refueling' outage.
It is believed:that, for the reasons outlined above, the probability of a failure associated with the LCRM remains low enough to justify the safe. interim operation of Limerick 1.
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