ML20106B376

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Forwards Response to GL 92-04, Resolution of Issues Re Reactor Vessel Water Level Instrumentation in BWRs Per 10CFR50.54(F). Util Intends to Continue to Support BWR Owners Group Efforts to Resolve Issue
ML20106B376
Person / Time
Site: Hope Creek 
Issue date: 09/24/1992
From: Labruna S
Public Service Enterprise Group
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-92-04, GL-92-4, NLR-N92139, NUDOCS 9210010138
Download: ML20106B376 (5)


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SEP 2 419 9 N LR-N92139 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

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a.:SPONSE TO GENERIC LETTER 92-04 l

RESOLUTION OF THE ISSUES RELATED TO REACTOR VESSEL l-WATER LEVEL INSTRUMEtiTATION IN BWRs PURSUANT TO 10CFR50.54 (F)

HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NO. NPF-57 DOCKET NO. 50-354 Public Service Llectric and Gas Company (PSE&G) hereby submits its response to Generic Letter 92-04 " Resolution _of the Issues Related to. Reactor Vessel Fate-Level Instrumentation in BWR's-Pursuant to' 3 OCFR50. 54 (P) ". The attachraent to this-letter details the actions l

taken by PSE&G to addrers the subject concern. If you have any questions regarding=this response, please do not hesitate to call.

u Sincerely,

',ttachment

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?210010136 920924 DR ADOCK 05000354

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SEP 241992

- bocument Control Desk 2

NLR-N92139 C

Mr.

T.

T.

Martin. Administrator - Region I U.

S.

Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Ms. A Keller U..S.

Nuclear Regulatory c mmission o

MS 14 E-21 Washington, DC 20555 Mr. T. P. Johnson (SOS)

USNRC Senior Resident Inspecto.

Mr.

K. Tosch, Chief NJ Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415

. Trenton, NJ 08625 7-

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l<fa0ESTED ACTIQFJ 1.

In-light of potential errors resulting from the effects of noncondensible gas, each licensee should determine:

i a..The impact of potential level indication errors on automatic safety system response during al l'icensing basis transients and accidents;

b. The impact of potential level indication errors on l

operator's short and long term actions during and after

. j all licensing basis transients und accidents;

c. The impact of potential level indication errors on operator actions prescribed in emergency operating procedures or other affected procedures not covered in (b).

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ESEEG RESPONSE 1.

PSE&G has reviewed the applicable concern for potential

- errors resulting from the effects of noncondensible gas and has determined the following:

a. The impact of potential level indication errors on automatic safety system response during all licensing

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basis transients and~ accidents for-Hopo Creek Generating l

Stat. ion (HCGS) are r n"ided in the BWROG report " BWR REACTOR VESSEL HATt.c

,:JEL INSTRUMENTATION ", revision 1,

fc rwarded: to the NRC on August 20, 1992. PSE&G enducues this report as retlecting the automatic systems and plant response for a late BWR/4 design as installed at HCGS.

i The impact'of potential level indicatJon errors on s.

operatoF c shcrt and long term actions during and after all licensing basis accidents and' transients has been-assessed for HCGS. PSE&G has concluded that operator short and.long term actions are adequitely described in the BWROG report.

Training about the causes-and' effects of the potential phenomenon has been provided to HCGS operators.

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c. 'fhe impact of potential level indication errors on _

operator: actions prescribed-in the emergency opcrating proced res or othe affected procedures not covered in (b) has also been. assessed for HCGS. It has bes.n-L determined that no procedure changes are required at this time.; Additional training in accordance with the t

l EPC recommendations for operators concerning the l

usability-of water level indication is considered appropriate until.long term corrective-actions are

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c EPC recommendatio'ss for operators. concerning Lthe usability of water level indication is considered appropriate until long term corrective actions are determined and recommended by the EPC. This additional-guidance will be based on the BWROG program of testing and analysis.

HEQUESTED ACTIONS 2.

Based on the results of (1), above, each licensee should notify the NPC of short term actions taken, such as:

a.

Periodic' monitoring of level instrumentation system leakage; and, b.

Implementation of procedures and operator training to annure that potential level errors will not result in i.nproper operator actions.

ESE&G RESl?QHSE I

2.

Based upon the results of (1) above, PSE&G provides~the following:

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HCGS began its fourth refueling on-September 12, 1992.

L A walkdown of the instrumentation components inside the I

drywell was performed during the unit shutdown.1Walkdown and inspection of the-instrument-racks outside the drywell has been and will be conducted periodically.

During the normal cooldean of the plant, recorders were provided on each of the-four wide range level p

instrumentation channels to determine if-the-same-

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level indication fluctuations found at some other BWR L

units were present at HCGS. Initial results indicate-that these anomalics are not present at Hope Creek.

Channel' checks which compare indicated level to its counterpart level channels ~ is performed daily.

Acceptance criteria

.r maximum allowed deviation between channels is applied for these checks.

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Other means'to assure that leaks which may develop in L-the level indication system are readily detectable 4

L are;being invertigated.

b.- Operator training about the potential phenomenon-has-been provided to HCGS licensed operators in accordance with the BWROG/EPC letter to the plant operaticns 1

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REQMEETED AQTIONG 3.

Each licensee should provide its plans and schedule for corrective actions, including any proposed hardware modifications necessary to ensure the level instrLnentation system design is of high functionat reliability for long term operation. Since this instrumentation plays an important role in plant safety and is required for both normal and accident conditions, the staff recommends that each utility implement its longer term actions to assure a level instrumentation system of high functional reliability at the first opportunity but prior to starting up after the next refueling outage commencing 3 months after the date of

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this letter.

P!IRRG_RUlil9tMiB 3.

PSE&G intenus to continue to support the BWROG's ef forts in this area. The Owner's Group plans include the collection of plant unique data, tests, analysis, and development of potential modifications. The approach to be taken will be based on full scale prototypal tests of reference leg configurations, and in parallel the developmr.nt of an analytical reference leg model. PSE&G agrees with the BWROG and the staff that the water level instrumentation issue is not an immediate safety concern and believes it is premature to commit to any modifications until the phenomenon and its implications are completely understood.

4 Based on the results of the 3WROG's work, PSE&G will implement the necessary hardware and/or procedutal g

modifications when or if they-are identified. PSE&G will provide the results of this testing and its implicstions for HCGS when complettd. A schedule for corrective actions will also be provided to the NRC at that time.

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