ML20126H195

Appeals NRC Position on turbine-driven Auxiliary Feedwater Tech Specs,Per Generic Ltr 84-08.NRC Position That More Stringent Tech Specs Be Imposed on turbine-driven Auxiliary Feedwater Pump Constitutes Backfit

ML20126H195
Person / Time
Site:	Maine Yankee
Issue date:	06/11/1985
From:	Whittier G Maine Yankee
To:	John Miller Office of Nuclear Reactor Regulation
References
5836L-GDW, GDW-85-167, GL-84-08, MN-85-112, NUDOCS 8506180279
Download: ML20126H195 (2)

Text

-

EDISON DRIVE MAME HARHEE ATOMICPOWERCOMPARUe avausra, ualuE oa33s

] (207) 623-3521 e

June ll, 1985 MN-85-ll2 GDW-85-167 Director of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Mr. James R. Miller, Chief Operating Reactors Branch No. 3 Division of Licensing

References:

(a) License No. [PR-36 (Docket No. 50-309)

(b) USNRC Letter to MYAPCo dated May 14, 1985

Subject:

Auxiliary Feedwater System Evaluation Gentlemen:

Reference (b) forwarded the NRC Staff's evaluation of the design of the Maine Yankee Auxiliary Feedwater and Emergency Feedwater systems. The evaluation concluded, in part, that the turbine driven auxiliary feedwater pump is not required, or relied upon, to mitigate the effects of any postulated design basis accident.

Maine Yankee has proposed technical specifications for the turbine driven auxiliary feedwater pump as part of the technical specifications associated with the alternate shutdown system which was installed to meet the requirements of 10 CFR 50 Appendix R. Reference (b) states "However, information relating to Technical Specifications for Appendix R (which concern the turbine driven AFW pump) will be the subject of a future Generic Letter".

Nevertheless, the attachment to Reference (b) states that it is the staff's position that a limiting condition for operation and surveillance requirements for the turbine driven auxiliary feedwater pump must be established, apparently to provide protection against station blackout. i Station blackout, the loss of all AC power, is not a design basis accident for l Maine Yankee, as has been stated in earlier correspondence. Station blackout is currently under review by the NRC to determine whether nuclear power plants will be required to be protected against these postulated events.

Maine Yankee believes that the Staff's position that more stringent l technical specifications be irrposed on the turbine driven auxiliary feedwater pump to protect against non design basis events (station blackout) constitutes a backfit. We are hereby appealing the Staff's position on turbine driven AFW pump technical specifications in accordance with the provisions of Generic f , ,

I .

t Letter 84-08. '

B506180279 850611 9 l kp PDR ADCCK 0500 g 5836L-GDW P

' MAINE YANKEE ATOMIC POWER COMPANY

. m United State Nuclear Regulatory Commission Page Two

-Attention: Mr. James R. Miller, Chief W-85-ll2 We will contact you to schedule a mutually convenient-date for an appeal meeting.

Very truly yours, MAINE YANKEE ATOMIC POWER COWANY khN G. D. Whittier, Manager Nuclear Engineering & Licensing GDW/bjp cc: _Dr. Thomas E. Murley Mr. Cornelius F. Holden

58%L-GDW