ML20246H984
| ML20246H984 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood, 05000000 |
| Issue date: | 08/01/1989 |
| From: | Hunsader S COMMONWEALTH EDISON CO. |
| To: | Murley T Office of Nuclear Reactor Regulation |
| References | |
| RTR-REGGD-01.097, RTR-REGGD-1.097 0178T:3-4, 178T:3-4, NUDOCS 8909050009 | |
| Download: ML20246H984 (5) | |
Text
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] Commonwealth Edison
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Xadress Reply to: Post OEce BoiT6T
-l Chicago, Illinois 60690 - 0767 August 1,1989 Dr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 Attn: Document Contrp1 Desk
Subject:
Byron Station Units 1 and 2 Braidwood Station Units 1 and 2 Regulatory Guide 1.97 Compliance NRC Docket Nos. 50-454/455 and 50-456/457
Reference:
(a) February 27, 1987 K.A. Ainger letter to H.R. Denton (b) September 1, 1987 S.C. Hunsader letter to T.E. Murley (c) November 6, 1987 L. Olshan letter to L.D. Butterfield i
(d) December 28, 1987 S.C. Hunsader letter to T.E. Hurley l
(e) May 5, 1988 L. 01shan letter to H.E. Bliss (f) July 27, 1988 S.C. Hunsader letter to T.E. Murley (g) May 19, 1989 S.P. Sands letter to T.J. Kovach (h) June 19, '989 S.C. Hunsader letter j
to T.E. Murley (1) July 24, 1989 R.H. Cooper letter to C. Reed l
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Dear Dr. Murley:
Reference (a) provided Commonwealth Edison's (Edison) preliminary i
evaluation of the Byron and Braidwood instrumentation for compliance with Regulatory Guide 1.97, Revision 3.
Reference (b) provided the results of Edison's final evaluation which were included as Attachments to that letter.
j Attachment A to reference (b) provided an update of Table 5-1.
Attachment B to reference (b) provided the revised Human Factors Engineering Review.
These l
supplemented the information provided in reference (a) and, together, constituted Edison's " Final Report" concerning Reg 11atory Guide 1.97 compliance for the Byron and Braidwood Stations.
Reference (c) provided the results of the initial NRC review and evaluation of references (a) and (b).
Edison's response to these was provided 4
in reference (d).
In reference (e), the NRC staff indicated that it had completed its review of Edison's submittels and had concluded that Edison's i
justification for the exceptions to Regulatory Guide 1.97, Revision 3 for some items was acceptable.
However for other items, additional justification was required.
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In response'to'the NRC staff's review, reference-(f)~provided the additional justification or provided an' appropriate response to the NRC
' staff's concerns.
Subsequently, reference (g) was issued that reported the final-results'of the NRC Staff review of Edison's submittals.
Reference (h) provided corrected pages to two (2) of Edison's submittals as identified'during the NRC inspection at Braidwood during the week of June.12. 1989.
In both cases the range of ammeters II-AP062 and
'II-AP094 were changed from "0-1200 AMP" to "0-200 AMP".
Also, instruments II-AP064 and II-AP096-(0-150 AMP) were identified as Byron only.
Due to an oversight these had been listed incorrectly.
Reference (1) provided the results of the NRC inspection at Braidwood-Station during the week of June 12, 1989 (456/457-89018) which included an
. inspection of the implementation of Reg Guide 1.97.
In reference (1) it was identified that for'the Spray Additive Tank Level indication, indicator lights had been provided, but-recording capability had not been provided as required for h Reg Guide 1.97 Category I Type A variable instrument.
The purpose of this. letter, in part, is to provide Edison's justification for this deviation.
This is provided in Attachment A.
The second purpose of this letter is to provide the implementation schedule, requestsj in Reference (g), for the four (4) remaining open items.
In reference (g), all open items had been accepted by the NRC staff with the exception of the following:
- 1) Accumulator Tank Level and Pressure
- 2) Containment Sump Hater Temperature.
- 3) RHR Heat Exchanger Outlet Temperature
- 4) Quench Tank Temperature Attachment B provides.the status and actions to be taken for these items.
Please address any questions regarding this submittal to this office.
Very truly yours, J c. f W ~
S.C. Hunsader Nuclear Licensing Administrator
/LB/0178T:3-4 cc:
L. 01shan-NRR S. Sands-NRR
'J. Hinds-RIII R. Cooper-RIII Resident Inspector-Byron Resident Inspector-Braidwood
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ATTACHMENT A 93 j
~ BYRON /BRAIDWOOD UNITS 1 and 2 REGULATORY GUIDE 1.97 REV. 3 COMPLIANCE SPRAY ADDITIVE TANK LEVEL The Spray Additive Tank Level parameter is listed in the Regulatory Guide 1.97, Compliance " Final Report", dated September 1, 1987, as a Type A, Category 1, instrument. Contrary to Category 1 requirements, only status indicating lights are supplied for low level?indictions, and not " Continuous Real-Time Display."
As stated in the Regulatory Guide 1.97, the Type A variable is plant specific and is provided to supply "Information Required for Operator Action."
Byron /Braidwood emergency operating procedures X IBEP-1 and X IBHEP-1, Step 8B, requires the operator to verify if the spray additive tank low-low (Lo-2) level lights are lit as follows:
a.
If they are lit, the operator is directed to close the containment spray -
(CS), educator spray additive isolation valves % CS019A & B, b.
If they are'not 11t..the operator is directed to monitor the lights untti they are lit; then the operator closes the X CS019A & B valves.
- As evidenced by the'above, tee use of the indicatf61 lights is appropriate for this plant specific variable. Cottinuous. real time display is not necessary since this display would not provide a ut?ful purpose to the operators during an emergency situation.
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bllACHMENLE 1'
BYRON /BRAIDWOOD UNITS 1 and 2 REGULATORY GUIDE 1.97 REV. 3 COMPLIANCE STATUS AND ACTION
SUMMARY
I 1
The NRC Staff issued the Byron /Braidwood Safety Evaluation Report (SER) regarding compliance to Regulatory Guide 1.97 Revision 3 on May 14, 1989. All justifications have been accepted by the NRC staff except for four (4) items. The purpose of this document is to outline the present status and actions for these items.
The four (4) instruments affected are:
- 1) Accumulator Tank Level and Pressure
- 2) Containment Sump Hater Temperature
- 3) RHR Heat Exchanger Outlet Temperature
- 4) Quench Tank Temperature l
The following describes the status and the applicable implementation j
schedule for upgrading these items:
1.
ACCUMULATOR TANK LEVEL AND PRESSURE The NRC staff is continuing to review and determine on a generic basis, the need to replace this instrumentation.
Since this is the case, 'no action is being taken at this time.
2.
CONTAINMENT SUMP HATER TEMPERATURE The NRC staff is continuing to review and determine on a generic basis, the need to replace this instrumentation.
Since this is the case, no action is being taken at this time.
3.
RHR HEAT EXCHANGEILQUTJIT TEMPERATURE The existing RHR heat exchanger outlet temperature instrumentation will be replaced with environmentally qualified instrumentation. Approximately l
420 feet of conduit and 950 feet of cable for each of Units 1 and 2 will have to be re-routed to facilitate this change.
This modification is scheduled to be installed during the following refueling outages:
Byron Unit 1..... FIR 04 (July, 1991)
Byron Unit 2....
B2R02 (September, 1990) i Braidwood Unit 1
.. AIR 02 (March, 1991)
Braidwood Unit 2
.. A2R02 (September, 1991) l l
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4.
QUENCH TANK TEMPERATURE Edison believes the existing pressurizer relief tank temperature instrumentation can be rescaled from a range of 500F - 3000F to 500F
- 3400F and can be performed without replacing the existing instrumentation via the setpoint change request program. As a result, this change will be initated.
If this approach is not successful, the temperature instrumentation will be replaced with environmentally qualified instrumentation that contains the appropriate temperature range scale.
Either of these changes are scheduled to be made prior to startup following the completion of these refueling outages:
Byron Unit 1......... BIR04 (July, 1991)
Byron Unit 2.......
B2R02 (September, 1990)
.Braidwood Unit 1....... A1R02 (March, 1991)
Braidwood Unit 2....... A2R02 (September, 1991)
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