ML20138J351

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Provides Supplemental Info to Tech Spec Change Request 142 Confirming That Listed Requirements Would Be Met During Time Period Needed to Install Environmentally Qualified Level Instrumentation & Forwards Standing Order 38
ML20138J351
Person / Time
Site: Oyster Creek
Issue date: 10/22/1985
From: Fiedler P
GENERAL PUBLIC UTILITIES CORP.
To:
Office of Nuclear Reactor Regulation
Shared Package
ML20138J356 List:
References
NUDOCS 8510290321
Download: ML20138J351 (3)


Text

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i GPU Nuclear Corporation Nuclear  :=:;388 Forked River, New Jersey 08731-0388 609 971-4000 Writer's Direct Dial Number:

October 22, 1985 Director, Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission

( Washington, DC 20555

Dear Sir:

Subject:

Oyster Creek Nuclear Generating Station Docket No. 50-219 Techr.ical Specification Change Request No.142 On Friday, October 18, 1985, a conference call was conducted betweeen members of your staff and GPUN. Based on that discussion, it was agreed tnat a supplemental letter was needed to confirm that the following requirements would be met during the time period needed to install the environmentally qualified level instrumentation.

The first commitment was that both Core Spray systems would remain operable.

The requirements for reduced availability will be met per Technical Specification 3.4.A for both systems.

The second commitment was that the written instructions identifying the requirements of the temporary change to the Technical Specifications be provided. A Standing Order has been approved and is attached for your reference.

The third commitment regarded the acutation of functions of the LOW-LOW Water Level Instruments that are listed in table 7.6.-l of the FSAR. It was agreed that sufficient components would remain operable to the extent that these components could be operated from the Control Room or from local control stations to perform their intended functions. Justification for the loss of each automatic actuation was provided in our October 18, 1985 letter and is repeated here for clarity.

1. Core Spray initiation - Core Spray system auto initiation is not required to be operable when the requirements for reduced availability are met per Technical Specification 3.4.A.
2. Containment Spray initiation "If primary containment integrity is not renuired, the containment spray system may be made inoperable".

T.S. 3.4.C.6

3. Reactor isolation - Currently the action statement for Item B.1 of Table 3.1.1 states "close main steam isolation valves and close isolation condenser vent valves, or place in cold shutdown condition." The status of the plant will be " cold shutdown" during replacemant nf low-inW instrumentation.

8510290321 851022 PDR ADOCK 05000219 P PDR FI g

GPU Nuclear Corporation is a subsidiary of the General Public Uhhhes Corporation

Direct:r Nucle:r R: actor Regulation Page 2 In addition, we have proposed in the TSCR that Note gg to Table 3.1.1 should be added under the shutdown mode. This provides the added assurance of monitoring reactor water level.

4. Containment isolation - Not required to be operable when primary containment integrity is not required to be maintained. - T.S. Note U to Table 3.1.1.
5. Recirculation Pump Trip - not in Tech Specs - not required unless in RUN mode.
6. Isolation Condenser initiation - not required if reactor coolant temperature is less than 212*F per T.S. 3.8. A.
7. SGTS initiation - T.S. we are attempting to change with TSCR No.142, "Not require;j when secondary containment integrity is not required" -

T.S. 3.5.B.2. Note that Standby Gas Treatment would be initiated should we lose the normal reactor building ventilation system.

8. Annunciators - do not perform a safety function and are not required by Technical Specifications to be operable. The LOW level annunciator will be operable to alert the operator if water level starts dropping.
9. Isolates Cleanup System - same as reactor isolation.
10. Isolates Shutdown Cooling System - same as reactor isolation.
11. Isolates RBCCW to drywell - same as containment isolation.
12. Isolates Air /N2 to drywell - same as containment isolation.

In our October 18, 1985 letter we stated that items 2 and 6 would not be manually initiated upon receiving the LOW level trip setpoint. Item 4 was inadvertantly omitted and should also have been listed. Containment isolation is not required to be operable when primary containment integrity is not required to be maintained.

With the exception of items 2, 4, and 6 at least one train in each system would remain operable.

Currently we are proceeding as described in our October 18, 1985 letter. We have made provisions to disconnect hoses and cables passing through the airlock doors which would be required to be shut in establishing primary containment. Each containment penetration in Table 3.5.2 has an operable isolation valve identified.

u __ - - _ - _ - _ _ _ __ _ __ _ _ _ - _ _ - _ __ ____ - _ _ _ _

P Director Nuclear Reactor Regulation Page 3 If there are any questions, please contact Mr. Michael Laggart, Manager, BWR Licensing at (201)299-2341.

Very truly yours, k

Vice President and Director Oyster Creek PSF /MWL/ dam Attachment cc: Dr. Thomas E. Murley, Administrator Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 Mr. Jack N. Donohew, Jr.

U.S. Nuclear Regulatory Connission 7920 Norfolk Avenue, Pnillips Bldg.

Bethesda, MD 20014 Mail Stop No. 314 NRC P.esident Inspector Oyster Creek Nucleare xnerating Station Forked River, NJ 08731