ML20209B792

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Responds to & Updates Implementation Schedule for Mod Required to Comply W/Tmi Lesson Learned Requirement, NUREG-0737,Item II.E.4.2(7) Re High Radiation Isolation of Vent & Purge Lines
ML20209B792
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 04/22/1987
From: Gallagher J
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To: Bernero R
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.E.4.2, TASK-TM NUDOCS 8704280517
Download: ML20209B792 (5)


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i PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHI A, PA.19101 l

saisi e41 san April 22, 1987 1

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Mr. Robert M. Bernero, Director Division of Boiling Water Reactor Licensing U.S. Nuclear Regulatory Commission ATTN:

Document Control Desk Washington, D.C.

20555

SUBJECT:

Peach Bottom Atomic Power Station l

NUREG-0737, Item II.E.4.2(7)

High Radiation Isolation of Vent and Purge Lines

REFERENCES:

(1) Letter dated May 7, 1986 from R. M.

Bernero, NRC, to J. M. Fulton, BWR Owners Group (2) Letter dated January 25, 1984 from 3

L. Daltroff, PECo, to J. F.

Stolz, NRC Dear Mr. Bernero This letter responds to the Reference (1) letter as requested by former NRC Project Manager, G. Gears, and updates the iraplementation schedule for a modification required to comply with a TMI " Lesson Learned" requirement (NUREG-0737, Item II.E.4.2/7).

The Reference (1) letter establishes the NRC's criteria for exempting lines of two inches in diameter or smaller from this NUREG-0737 requirement for high radiation isolation signals based on the NRC's review of analyses provided by the BWR Owners Group (BWROG) in submittals dated June 14, 1982 and June 27, 1981, and in NSEO-78-0882.

The Reference (1) letter stated that:

"... DWR lines of 2 inches in diameter or smaller need not be provided with a radiation isolation signal, provided that a licensee demonstrates on his docket that the BWROG evaluation is applicable to his plant.

This demonstration should include an assessment of the ability of the operators to assess and isolate leakages that would not cause other isolation signals (e.g.,

verification of the BWROG generic assertion of a maximum of 30 minutes)."

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Mr. Robert M. Barnero April 22, 1987 Page 2 Philadelphia Electric Company has determined that the BWROG evaluation is applicable to Peach Bottom Atomic Power i

Station Units 2 and 3.

There are sufficient indications and I

alarms in the control room for the operators to assess leakages, and the small purge and vent valves can be remotely closed by hand switches in the control room.

Therefore, the control room operators could assess and isolate leakages that would not cause other isolation signals within 30 minutes.

Attached is a list of indications and alarms which are available to the operators.

The emergency procedures implemented in accordance with NUREG-0737 and the associated training program identify the l

conditions and operator actions required to assure containment isolation.

In accordance with the Reference (1) letter, we consider high radiation isolation signals for lines 2 inches in diameter i

or smaller to be unnecessary.

The Reference (2) letter, dated January 25, 1984, proposed an implementation schedule of 1985 for Unit 3 and 1986 for Unit 2 based on an earlier understanding that the high radiation trips would apply only to the large lines.

As a result of the subsequent discussions regarding the applicability of this NUREG-0737 requirement and the efforts of the BWROG to obtain NRC approval to exclude the small lines, implementation of the modification was deferred.

Based on the clarification of the regulatory requirement provided by the Reference (1) letter, dated May 7, 1986, the implementation schedule for high radiation trips is prior to startup after the 1987 outages on both Unit 2 and Unit 3.

If you have any questions or require additional information, please do not hesitate to contact us.

Very truly yours,

^f_.tD-Les g)

Attachment cc W. T. Russell, Administrator, NRC, Region I T. P. Johnson, Resident Site Inspector R. E. Martin, NRC Project Manager

Attschmsnt Docket Nos. 50-277 50-278 Page 1 of 3 INDICATIONS AND ALARMS IN CONTROL ROOM FOR ASSESSING RADIATION LEAKAGE DRYWELL PRESSURE Instrument (1)

Alarm PR-4805 No (PR-5805)

PR-8102A,B No (PR-9102A,B)

PI-2508 Yes (H/L)

(PI-3508) and PR-2508 (PR-3508)

DRYWELL TEMPERATURE Instrument (1)

Alarm TR-4805 No (TR-5805)

TI-2501-19 to 27 No (TI-3501-19 to 27)

TI-2501-35 to 39 No (TI-3501-35 to 39)

TI-2501-63 to 66 No I

(TI-3501-63 to 66)

CONTAINMENT IIIGH RANGE AREA RADIATION Instrument (1)

Alarm RR-8103A,B*

Yes (H)

(RR-9103A,B)*

(1)

Instrument numbers in parenthesis apply to Unit 3, others apply to Unit 2.

  • Four channels are indicated on two dual-pen indicator recorders.

Attachment Docket Noa. 50-277 50-278 Page 2 of 3 DRYWELL ATMOSPHERE PARTICULATE, IODINE AND NOBLE GAS RADIATION Instrument Alarm One Alarm on CO3 Panel Yes (ll-ll/H/L) actuated by local l

RIS-4130, 4131, 4132 (Unit 2) and RIS-5130, 5131, 5132 (Unit 3) l REFUELING FLOOR VENTILATION EXilAUST RADIATION Instrument (1)

Alarm RIS-17-458A,B,C,D Yes (11-11,11, L )

  • and RR-17-456 on Panel 20C10 (RIS-17-458A,B,C,D and RR-17-456 on Panel 30C10) l REACTOR BUILDING VENTILATION EXilAUST RADIATION Instrument (1)

Alarm RIS-17-452A,B,C,D Y e s (ll-li,il, L )

  • l and RR-17-455 on Panel 20C10 (RIS-17-452,A,B,C,D and RR-17-455 on Panel 30C10)

MAIN STACK EXHAUST RADIATION Instrument Alarm RIS-17-50A,D Yes (11-11,11, L ) *

  • and RR-17-51 (common to both units) l
  • Isolates on 11-11 i
    • Containment Isolation on 11-11 to be installed under 111 Rad. Isolation Modification (Mod. No. 664).

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Attcchmont Docket Nos. 50-277 50-278 Page 3 of 3 VENT STACK EXHAUST RADIATION Instrument (1)

Alarm RIS-2979A&B Yes (ll-H,H/L)

(RIS-3979A&B) and RR-2979 (RR-3979) l l

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