ML20097E275
| ML20097E275 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 09/12/1984 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| References | |
| TASK-3.D.1.1, TASK-TM OL, NUDOCS 8409180142 | |
| Download: ML20097E275 (7) | |
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PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHI A, PA.19101 JOHN S. KEMPER V IC E-PR ESID E NT RNG4NEFUNG AND RESE ARCH Mr. A. Schwencer, Chief Docket Nos.:
50-352 Licensing Branch No. 2 50-353 U. S. Nuclear Regulatory Ccumission Washington, D.C. 20555
Subject:
Limerick Generating Station
'IMI Its III.D.I.1 Primary Coolant Outside Containment
Reference:
PECO and NRC Telecon dated 9/6/84.
File:
GOVf 1-1 (NRC)
Dear Mr. Schwencer:
As discussed and agreed to with the Meteorological and Effluent Treatment Branch Reviewer in the reference conference call, the Ieakage Reduction Program described in FSAR Section 6.2.8 will be inpimented both prior to and after fuel load in accordance with the following schedule.
Of the sixteen surveillance tests (see attachnent) which are used to satisfy FSAR Section 6.2.8 requi.unents, the Contaminated Pipe Inspection Tests that deal with the Scram Discharge Volume, Residual Heat Reoval, Core Spray, and Safeguard Piping Fill Systems (8 tests in all) will be cmpleted prior to fuel load. These test results will be subnitted to you as supplesnent 1 to this letter after the last test is performed.
The remaining tents will be performed after fuel load as outlined below, since the systems to which they apply are not required to be in surveillance for the fuel load operating condition.
The Contaminated Piping Inspection tests for the Post Accident Sanpling Systs will be cmpleted prior to exceeding five percent power and the Post IOCA Recmbiners will be cmpleted prior to Start-up (Technical Specification Operating Condition 2). The HPCI and RCIC tests are to be run when reactor pressure reaches nornal operating pressure.
The results of these 8 tests will also be subnitted to you as supplement 2 to this letter after the last test has been performed.
V 8409180142 840912 g
PDR ADOCK 05000352 1
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All sixteen surveillance test procedures and test results will be available at the Limerick site for review by NBC Region I Site inspectors.
l As a result of the revised Ieak Reduction program schedule, the attached draft mised FSAR page change to 'IMI Itan III.D.l.1 will be incorporated into thw FSAR exactly as it appears in the attachment scheduled for October, 1984.
Sincerely, M&
RTS/gra/09118401 cc: See Attached Service List J
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g ATTACHMENT Leak Reduction Program Surveillance Tests 1.
ST-1-030-700-1 Post Accident Sampilng System Liquid Sample Contaminated Piping Inspection 2.
ST-1-030-701-1 Post Accident Sanpilng System Atmospheric Sample Loops Contaminated Piping Inspection 3.
ST-1-047-700-1 Control Rod Drive Scram Discharge Volune Contaminated Piping Inspection 4.
ST-1-049-701-1 Reactor Core Isolation Cooling Pw p Contaminated Piping Inspection 5.
ST-1-049-702-1 Reactor Core Isolation Cooling Turbine Contaminated Piping Inspection 6.
ST-1-051-701-1 A residual Heat Removal Contaminated Piping Inspection 7.
ST-1-051-702-1 B Residual Heat Removal Contaminated Piping Inspection 8.
ST-1-051-703-1 C Residual Heat Removal Contaminated Piping Inspection 9.
ST-1-051-704-1 D Residual Heat Renoval Contaminated Piping Inspection 10.
ST-1-052-701-1 A Core Spray Contaminated Piping Inspection 11.
ST-1-052-702-1 B Core Spray Contaminated Piping Inspection 12.
ST-1-052-705-1 Safeguard Piping Fill Contaminated Piping Inspection 13.
ST-1-055-701-1 High Pressure Core Injection Pump Contaminated Piping Inspection 14.
ST-1-055-702-1 High Pressure Core Inspection Turbine Contaminated Piping Inspcction 15.
ST-1-058-701-1 A Post Accident LOCA Recombiner Contaminated Piping Inspection 16.
ST-1-058-702-1 8 Post Accident LOCA Rocarbiner Contaminated Piping Inspection RJS/gra/09118402 i
i
o cc: didje Lawrence Brenner (w/ enclosure)
Judge. Peter A. Morris (w/ enclosure)
Judge Richard F. Cole (w/ enclosure)
Judge Christine N. Kohl (w/ enclosure)
Judge Gary J. Edles (w/ enclosure)
Judge Reginald L. Gotchy (w/ enclosure)
Troy B. Conner, Jr., Esq.
(w/ enclosure)
' Ann P. Hodgdon, Esq.
(w/ enclosure)
Mr. Frank R. Rcmano (w/ enclosure)
Mr. Robert L._ Anthony (w/ enclosure)
.Ms. Maureen Mulligan (w/ enclosure)
Charles W. Elliot, Esq.
(w/ enclosure)
Zori G. Ferkin, Esq.
(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)
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. Tinothy R. S. Cenpbell (w/ enclosure) l
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Staffing of the, EOF and the TSC is described in the Limerick Emergency Plan, Table'I.1.
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x IIk.A.2 EMERGZNCY PREPAREDNESS Position j'
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Each nucle)ar facility (1) provide reasonable ass \\shall upgrade its emergency plan to urance that adequate protective s
measures can and will be taken in the event of a radiological ens;rgency.
Specific criteria tc meet this requirement is,. delineated in NUREG-0654 (FEMA-REP-1),
"Criteriasfor Preparation and Evaluation of Radiological Emergency Response Plans and Preparation in Support of Nuclear Power Plants."
(2)
Perform an emergency response exercise to test the integrated capability and a major portion of the basic elements existing within emergency preparedness plans and A
t organizations.
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Response
Emergency planning is ' discussed in 'Section 13.3.
III.D.1.1 PRIMARY COOLANT OUTSIDE CONTAINMENT j(-
Position 1
Applicants shall implement a program to reduce leakage from systems outside containment that would or couJd contain highly radioactive fluids during a serious transient or accident to as-low-as-practical levels.
This program shall include the following:
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1.13-72a Rev. 20, 05/83
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Immediate leak reduction gg (a) -Implement'all practical leak reduction measures for all systems that could carry radioactive fluid outside of containment.
(b) ' Measure actual leakage rates with system in operation and report them to the NRC.
(2)'
Continuing Leak Reduction--Establish and implement a program of preventive maintenance to reduce leakage to as-low-as-practical levels.
This program shall include periodic integrated leak tests at intervals not to exceed each refueling cycle.
Clarification Applicants shall provide a summary description, together with initial leak-test results, of their program to reduce leakage from systems outside containment that would or could contain primary coolant or other highly radioactive fluids or gases during or following a serious transient or accident.
(1)
Systems that should be leak tested are as follows (any f
other plant system which has similar functions or 4
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postaccident characteristics even through not specified herein, should be included):
(a)
Containment spray recirculation, (c)
High-pressure injection recirculatio,n, (d)
Containment and primary coolant sampling, (e)
Reactor core isolation cooling, (f)
Makeup and letdown (pressurized water reactors only),
and (g)
Waste gas (includes headers and cover gas system outside of containment in addition to decay or storage system).
Include a list of systems containing radioactive materials which are excluded from program and provide justification for exclusion.
(2)
Testing of gaseous systems should include helium leak detection or equivalent testing methods.
!f 1.13-73 Rev. 19, 04/83
l DRA,r,,.,t.
Should consider program to reduce leakage potential release paths due to design and operator deficiencies as discussed in our letter to all operating nuclear power plar.ts regarding North Anna and Related incidents, dated October 17, 1979.
Response
A review of all systems designed to handle highly ra'dioactive fluids during or.after a serious transient or accident has been performed to ensure that appropriate design features to minimize leakage have been. included... System isolation provisions have been reviewed in conjunction with this effort (Section 6.2.7).
A leak reduction program for these systems will be implewented prior toafuel load to measure actual leakage rates and to identify sources of leakage in order that total leakage may be reduced
- o as-low-as-practical levels.
The leakage reduction program is described in Section 6.2.8.
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Rev. 19, 04/83 1.13-74
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