ML20096G775
| ML20096G775 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 09/06/1984 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| References | |
| OL, NUDOCS 8409110130 | |
| Download: ML20096G775 (4) | |
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PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 JOHNS.KEMPER WIC E#R ESID E NT SEP 061984 Mr. A. Schwencer, Chief Docket Nos.:
50-352 Licensing Branch No. 2 50-353 Division of Licensing U. S. Nuclear Regulatory Ccanission Washington, D.C. 20555
Subject:
Lilnerick Generating Station, Units 1 and 2 Information for Equignent Qualification Branch (EQB)
Regarding SER Open Issue #6 (Seismic / Dynamic Qualification of Equipnent).
Reference:
(1) letter frcxn J. S. Ketper to A. Schwencer, dated August 1, 1984.
(2) Telecon between PECO (Tcm Shannon, et al) and NRC (Arnold Ice) on August 31, 1984.
Attachment:
Limerick Generating Station, Unit 1:
Justification for Interim Operation File:
GOVT l-1 (NRC)
Dear Mr. Schwencer:
The reference (1) letter transmitted our justification for interim 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 monitor (RHRSW PRM) system for safety essential service.
Pursuant to the Reference (2) telecon, the attached revision to our justification for interim operation provides additional information for the Equipnent Qualification Branch.
Should you require any additional information, please do not hesitate to contact us.
Sincerely,
$ TNf RDC/gra/09048402 cc: -See Attached Service List i
\\ \\
8409110130 840906 gDRADOCK 05000352 PDR m
f-eo cc: Judge Lawrence Brenner (w/ enclosure)
P-
'dudge Peter A. N rris (w/ enclosure)
' dudge Richard F. Cole (w/ enclosure)
Troy B. Conner, Jr., Esq..
(w/ enclosure)
Ann P. Hodgdon, Esq.
-(w/ enclosure)
.Mr. Frank'R. Romano (w/ enclosure)
Mr. Robert L. Anthony (w/ enclosure)
Maureen N111gan (w/ enclosure)
Charles W. Elliot, Esq.
(w/ enclosure)
Zori G. Ferkin, Esq.
(w/ enclosure)
Mr. Thomas Gerusky (w/enclosurc)
Director, Penna. Emergency (w/ enclosure)
Management Agency Angus R. Love, Esq.
(w/ enclosure)
David Wersan, Esq.
(w/ enclosure)
-Robert J. Sugarman, Esq.
(w/ enclosure)
Martha W. Bush, Esq.
(w/ enclosure)
Spence,W. Perry, Esq.
(w/ enclosure) day M..Gutierrez, Esq.
(w/ enclosure)
Atomic Safety & Licensing (w/ enclosure)
Appeal Board Atomic Safety & Licensing (w/ enclosure)
Board Panel Docket & Service Section (w/ enclosure)
Mr. James Wiggins (w/ enclosure)
Mr. Timothy R.. S. Cambell (w/ enclosure) iups i
_________.._m.__.
._.a
3 LIMERICK GENERATING STATION, UNIT 1
. JUSTIFICATION FOR INTERIM OPERATION This 'Is the Justification for interim operation of th'e Limerick Generating Station, Unit 1,.pending confirmation of the dynamic qualification of the residual heat removal service water process radiation monitor (RHRSW PRM) for safety essential service as currently coninitted -in the Limerick FSAR.
The RHRSW PRM detects high radiation levels in the cooling water effluent (RHRSW) from the RHR heat exchangers, in case of a heat exchanger tube -
leak of radioactive reactor coolant or suppression pool water to the RHRSW' system. The effluent RHRSW is routed to the cooling towers q
'(normal) or the spray pond (accident). A RHRSW PRM high radiation signal actuates an alarm and automatically doses the RHRSW isolation valves and, if sensed at the loop dischargt header, shuts off the RHRSW pump.
The RHRSW PRM consists of a remote sanpling station (liquid sample rack / scintillation detector) located in the area of the diesel generators and a log count rate meter (LCRM) located in the cuxil?ary control room, plus alarm and trip instrunentation. Dynamic qualification test records, appilcable to Limerick,. are available for all of this equipment except
' for the LCRM. There is strong evidence that the LCRM was qualified by test (seismic bracing was added to the Limerick model LCRM); however, the qualification test records are not readily available.
The Justification for operating Unit I until the first refueling outage, with the qualification records of the LCRM incomplete, is as follows:
1.
Since the RHRSW PRM is not required to be active safety essential (i.e., not required to mitigate the consequences of a Design Basis Accident) the only safety concern is the ootential effect of a PRM conponent failure on either the Class 1E power circuits or on the operation of the safety essential RHRSW system.
Items 2, 3, and 4 below address the possible effects of a PRM component failure.
2.
All Class 1E power circuits are redundant and separated, hence l a single PRM electrical ccmponent failure that causes a Class IE power circuit failure is within the Limerick Design Basis (i.e. failure of a single, active, safety-related component).
3 There are two RHR heat exchangers, each with its own RHRSW l
supply system. Hence shutdown and isolation of one PJiRSW supply system because of a PRM conponent failure is within t Limerick Design Basis (i.e failure of a single, active, safety-related component).
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4.
-If the. shutdown and. Isolation _of one, or both, RHRSW supply
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- systems'results from false.high radiation level PRM trip signals,~-the operator can manually bypass the signals and l.
- roopen_theLRHRSW isolation valves and restart the RHRSW supply.
'pum(s).)- The operator can determine if the trip is due to a l
false high radiation level trip signal because there are.two-
. PRMs on the :RHRSW supply system for. each RIR heat exchanger.
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-5.
'Both RHR heat exchangers are seismically qualified, therefore,
=a safe-shutdown earthquake would not'cause a heat exchanger tube failure. Consequently, the RHRSW PRMs would not be required for. safety essential service because there would not i be any heat exchanger tube leakage into the RHRSW system.
- 6.
All of.- the' RHRSW PRM ccuponents are located in mlId l
. environment areas (auxiliary control room and diesel generator areas) where hydrodynamic loads are minor or nonexistent. All of--the components have been quallfled, except for. the LCRM for which there is strong' evidence of qualification.
' Consequently, PRM component failure is not ilkely.
- 7~
- Because. of the qualification level of the. RHRSW PRM ccuponents, l-the occurrence of multiple failures has a very low probability.-
~
In'theievent that' previous test records do not become avallable, we
/
- will present an acceptable' solution for Irmlementation at the first 2-
' refueling outage. lIt is believed that, for the-reasons outilned above, the probability of a failure associated with the LCRM remains 1ow enough to_ Justify the safe' interim operation of Limerick 1.
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