ML20209H221

Discusses Util 861029 Proposed Tech Specs Re Limitations & Testing Requirements for drywell-suppression Pool Vacuum Breakers to Reduce Potential for Bypass Leakage.Mod to Second Sentence of 3.7.A.4.b Necessary for NRC Acceptance

ML20209H221
Person / Time
Site:	Peach Bottom
Issue date:	04/28/1987
From:	Butler W Office of Nuclear Reactor Regulation
To:	Bauer E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
TAC-46787, TAC-46788, NUDOCS 8705010169
Download: ML20209H221 (3)

Text

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April 28, 1987 Dockets Nos. 50-277/228 Mr. Edward G. Bauer, Jr.

NRC PDR ~

OGC - Bethesda Vice President and General Counsel Local PDR JPartlow Philadelphia Electric Company PD12 Reading RClark/RMartin 2301 Market Street SVarga M0'Brien Philadelphia, Pennsylvania 19101 BBoger ACRS'(10)

SUBJECT:

DRYWELL-SUPPRESSION POOL VACUUM BREAKERS (TAC NOS 46787 and 46788)

RE:

Peach Bottom Atomic Power Station, Units 2 and 3' By letter dated October 29, 1986, you submitted proposed Technical Specifications (TS) relating to limitations and testing requirements for the 1

Drywell-Suppression Pool Vacuum Breakers to reduce the potential for bypass leakage. The submittal was an amendment to the TS you subniyted December 2, 1985, which was an amendment to a previous application.

The initial application for amendments was dated August 6,1981. The proposed TSs have been the subject of numerous phone discussions and several yeetings. The purpose of this letter is put forth for your consideration a position that would be acceptable to the NRC staff.

We have reviewed your October 29, 1986 proposed TSs.

The proposed TSs would,

be acceptable if in the second sentence of 3.7.A.4.b at the bottom left hand i column on page 170, you reverted to the language in your December 2,1985 revision. The wording for 3.7.A.4.6 would be identical to your draft submittal of April 1986. We appreciate the complexity of the testing and the problem of getting a specialist in to initiate testing within eight hours if the indicators malfunction on the back shifts during weekends or on a holiday.

However, if a vacuum braaker was significantly open (i.e., more than about 3*)

and if an accident occurred, there is a potential for bypassing the suppression pool and not achieving the intended suppression. For this reason,.we feel that if there is an indication that a vacuum breaker is rot fully seated, action should be initiated in about one shift to test whether the problen is the indicator (s)orifthevalve(s)areunseated. Ve recognize that it takes in the order of eight hours to complete the testing ~if no problems are encountered.

Generally, the situation would be assessed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. We consider it more important to initiate action within a short period of time (e.g., eight hours) to determine the nature of the problem than to try to specify a time for completion of the testing.

Sincerely, 8705010169 870428 PDR ADOCK 05000277 P

PDR Walter R. Butler, Director Project Directorate I-2 Division of Reactor Projects I/II cc: See next page 1

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April 28, 1987 DocYe'tsNos. 50-277/228 u

Mr. Edward G. Bauer, Jr.

Vice President and General Counsel Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101

SUBJECT:

DP.YWELL-SUPPRESSION POOL VACUUM BREAKERS (TAC N05. 46787 and 46788)

RE:

Peach Bottom Atomic Power Station, Units 2 and 3 By letter dated October 29, 1986, you submitted proposed Technical Specifications (TS) relating to limitations and testing requirements for the Drywell-Suppression Pool Vacuum Breakers to reduce the potential for bypass leakage. The submittal was an amendment to the TS you submitted December 2, 1985, which was an amendment to a previous application. The initial application for amendments was dated August 6,1981. The proposed TSs have been the subject of numerous phone discussions and several meetings. The purpose of this letter is put forth for your consideration a position that would be acceptable to the NRC staff.

We have reviewed your October 29, 1986 proposed TSs. The proposed TSs would be acceptable if in the second sentence of 3.7.A.4.b at the bottom left hand column on page 170, you reverted to the language in your December 2, 1985 revision. The wording for 3.7.A.4.6 would be identical to your draft submittal of April 1986. We appreciate the complexity of the testing and the problem of getting a specialist in to initiate testing within eight hours if the indicators nalfunction on the back shifts during weekends or on a holiday.

However, if a vacuum breaker was significantly open (i.e., more than about 3 )

and if an accident occurred, there is a potential for bypassing the suppression pool and not achieving the intended suppression. For this reason, we feel that if there is an indication that a vacuum breaker is not fully seated, action should be initiated in about one shift to test whether the problem is the indicator (s) or if the valve (s) are unseated. We recognize that it takes in 4

the order of eight hours to complete the testing if no problems are encountered.

Generally, the situation would be assessed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. We consider it more important to initiate action within a short period of time (e.g., eight hours) to determine the nature of the problem than to try to specify a time for completion of the testing.

Sincerely, Walter R. Butler, Director Project Directorate I-2 Division of Reactor Projects I/II cc: See next page

~

i Pr. E. G. Pauer, Jr.

' Peach Bottom Atomic Power Station, Philadelphia Electric Company Units 2 and 3

• cc:

Mr. R. A.'Heiss, Conrdinator Mr. Eugene J. Bradley Assistant General Counsel Pennsylvania State Clearinghouse Philadelphia Electric Company Governor's Office of State Planning 2301 Market Street and Deielopment Philadelphia, Pennsylvania 1910i P.O. Box 1323 Harrisburg, Pennsylvania 17120 Troy B. Conner, Jr., Esq.

1747 Pennsylvania Avenue, N.W.

Mr. Thomas M. Gerusky, Director Washington, D.C.

20006 Bureau of Radiation Protection Pennsylvania Department of Thomas A. Demfng, Esq.

Environmental Resources Assistant Attorrey General P.O. Box 2063 Department of Natural Resources Harrirburg, Pennsylvania 171?0 Annapolis, Maryland 21401 Mr. Albert R. Steel, Chaireaa Philadelphia Electric Company Board of Supervisors ATTN: Mr. R. Fleishmann Peach Bottom Township Peach Bottom Atomic R. D. #1 Power Station Delta, Pennsylvania 17314 Delta, Pennsylvania 17314 Mr. Gary Mock Mr. M. J. Cooney, Superintendent P.O. Box 09181 Generation Division - Nuclear Columbus, Ohio 43709 Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Mr. Anthony J. Pietrofitta, General Manager i

Power Production Engineering Atlantic Electric P. O. Box 1500 1

1199 Black Horsa Pike Pleasantville, New Jersey 08232 Msident Inspector U.S. Nuclear Regulatory Comission Peach Bottom Atomic Power Station i

P.O. Box 399 Delta, Pennsylvania 17314 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 631 Park Avenue l

King.of Prussia, Pennsylvania 19406 l

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