ML20099F097
| ML20099F097 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 11/15/1984 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8411260259 | |
| Download: ML20099F097 (3) | |
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PHILADELPHIA ELECTRIC COMPANY Y
2301 MARKET STREET P.O. BOX 8699 I' -
g PHILADELPHIA, PA.19101 GHIELDS L. D ALTROFF
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ELacTasc Pn C lost November 15, 1984 Docket Nos. 50-277 50-278 Inspection Report Nos. 50-277/84-24 50-278/84-20 Mr. Richard W. !.arostecki, Director Division of Project and Resident Programs U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Starostecki:
Your letter of October 17, 1984, forwarded combined Inspection Report 50-277/84-24 and 50-278/84-20.
Appendix A of your letter addresses one activity which does not appear to be in full compliance with Nuclear Regulatory Commission requirements.
This item is restated below along with our response.
A.
10 CFR 50.59 allows licensees to make changes in the facility as described in the aafety analysis report (SAR) without prior Commission approval, unless the proposed change involves a revision to the Technical Specifications or an unreviewed safety question.
Further, licensees shall maintain records of changes in the facility as described in the SAR, including for each change a written safety evaluation which provides the bases for the determination that the change does not involve an unreviewed safety question.
FSAR Section 4.8.6 states that during the Low Pressure Coolant Injection mode of operation of the Residual Heat Removal (RHR) System, a bypass line to the suppres'lon pool is provided so that the pumps are not damaged by operating with the discharge valves shut.
b 8411260259 841115 PDR ADOCK 05000277 5p G
Mr. Richard W.'St'arostecki November 115, l'84 9
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Contrary lto-the above, on-April 27, 1982,- and on June 22-25, y
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1984, the minimum flow' bypass line for.an RHR pump was deactivi'ated in~the closed. position with the-reactor
' operating.
TheLLPCI mode.of RdR was considered operable,-yet.
no; written. safety: evaluation was-maintained'to. provide the
. basis that the change did not' involve an unreviewed safety-question.
This,is a Severity Level IV violation' (Supplement I).
applicable to DPR-56.
Response
Plant staff discussed the inoperability of.the minimum flow valves.on the occasions identified in the inspection report.
In considering pump operability, the' plant staff considered that the pump would be'able to perform its' intended function during a design basis'LOCA.
A' written safety evaluation to document this decision was not provided.
Operability of this pump during a LOCA which. maintained reactor pressure above pump shutoff head for a_ considerable length of-time was considered a very low probability.
However, in retrospect,-
such a LOCA could result.in damage _to the pump thereby making it' inoperable.
In any case, judgement by the plant = staff-resulted in considering the. pump _as operable and maintaining it in operable status in all aspectc.with the exception-that the min' mum flow valve was closed and inoperable.
As indicated in the Inspection Report and above,-a written safety evaluation which satisfies 10 CFR 50.59 requirements was not developed.
Operations personnel have been instructed i
not to deactivate any minimum flow valves, and in a letter dated September 11, 1984, Operations personnel were instructed to discuss any abnormal ECCS configurations with a Senior Engineer to determine if the configuration requires a safety evaluation.
The senior staff has been instructed to be more attentive to areas which could involve possible 10 CFR 50.59 consideration.
In addition, Philadelphia-Electric-s I
Company, in response'to the NRC Order dated June 18, 1984, created an appraisal team which is currently evaluating our
. process for performing safety evaluations and reviews of procedures at the-Peach Bottom Atomic Power Station.
This evaluation began on Septemberg4, 1984, following NRC approval of the plan.
The resolution of the appraisal team findings
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and recommendations Wila be reported to the NRC three months after. completion of th appraisal team's report.
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To justify maintaining'an RHR pump which has an inoperable minimum flow valve in an~ operable state,'an RHR pump was
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' Mr. Richard W. Starostecki November. 15, 1984 Page'3 capacity tested with the minimum flow valve fully open.. The test proved that the pump can adequately supply;the required Technical Specification LPCI flow with an open minimum flow valve.
Tho test will be repeated on the otner pumps to
-verify ~their ability to also satisfy-the Technical Specification requirements.-
If the RHR system line up with 1
an inoperable minimum flow valve open and deactivated is determined to be desirable, a written safety evaluation will be completed.
If the pumo cannot meet-the flou criteria and the minimum flow valve becomes. inoperable, then the pump will be declared inoperable.
Because testing is expected to provide an alternative to closing and deactivating the minimum flow valve, und because a closed, inoperable m!nimum flow valve will he considered to result in pump inoperability, a safety evaluation justifying pump operability with a closed, deactivated mibimum flow valve is not required and will not be. completed.
Should you require additional information, please do-not hesitate to contact us.
Very truly yours,
,a y cc:
A.
R. Blough, Site Inspector k
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