ML20128R053

Responds to Re Results of NRC Review of Responses to Generic Ltr 83-28, Required Action Based on Generic Implications of Salem ATWS Events. All Sys Contributing to Reactor Trip Function Identified in Current Q-list

ML20128R053
Person / Time
Site:	Peach Bottom
Issue date:	05/29/1985
From:	Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Stolz J Office of Nuclear Reactor Regulation
References
GL-83-28, NUDOCS 8506040390
Download: ML20128R053 (4)

Text

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PHILADELPHIA ELECTRIC COMPANY 23o1 MARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101

[]h y 29, 1985 Docket No. 50-277 50-278 r

Mr. John F. Stolz, Chief Operating Reactors Branch f4 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.

20555

SUBJECT:

Peach Bottom Atomic Power Station - Units 2 and 3 Generic Letter 83 " Required Action Based on Generic Implications of Salem ATWS Events" REFORENCE:

Letter to J. F. Stolz, USNRC, to E. G. Bauer,Jr. PECo., March 14, 1985

Dear Mr. Stolz:

The reference letter forwarded the NRC assessment of the completeness and adequacy of our responses to the subject Generic Letter for Peach Bottom Units 2 and 3.

The results of the NRC review are restated below along with our response.

Item 2.1 (Part 2) - Incomplete:

The licensee needs to confirm that the review of the RTS classification program is complete and that it verifies that RTS components are classified as safety-related and are identified as such on all documents and in information handling systems.

RESPONSE

All systems that contribute to the reactor trip function have been identified as being in the current 'O' list.

Consequently, all components on the identified systems, f

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.Mr. Jchn F. Stolz Page 2

.unless specifically excluded by a unique safety evaluation, are subject to the Quality Assurance program.

In accordance with approved ~ Peach Bottom Administrative Procedures and' Engineering and Research Department Procedures each item or service to be procured regarding procurement,must be reviewed to determine whether or not it is safety This review is performed by a cognizant member of related.-

the Plant Staff or the Engineering and Research Department as

..The determination is guided by the 'Q'-list, applicable.

applicable codes and standards, the Final Safety. Analysis Reprt and information from the Architect Engineer and the NSSS-supplier.

Philadelphia Electric Company believes the current Peach Bottom 'O' list and the existing procedural controls i

, governing its use are adequate to meet the intent of Gener c

' Letter 83-28.

Item 2.2.2 - Incomplete i

The The licensee's response is based on the NUTAC report.

l licensee needs to present his evaluation of the NUTAC program The and describe how it will be implemented at Peach Bottom.

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staff found that the NUTAC program fails to address the I

concern about establishing _and maintaining an interface between all safety-related equipment vendors and.the utility.

Accordingly, the licensee will.need'to supplement his l

i This additional j

response to address this concern.

information should describe how current procedures will'be modified and new ones initiated to meet the elements.of this concern.

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RESPONSE

i-During Philadelphia Electric Company's participation in thewe evalua l

INPO NUTAC program,

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addressing the NRC position contained in item 2.2.2 of the

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Although there is little incentive for Generic Letter.

equipment manufacturers to'be cognizant of equipmentthere is high incentive i

maintenance histories and failures, for utilities to maintain the type of information exchange described within the Vendor Equipment Technical Information Program (VETIP) as defined in the March 1984 NUTAC Report for both plant safety and reliability considerations.

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[Mr. John F. Stolz May 29, 1985 a.

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I Philadelphia Electric Company has. implemented,the program described in the Vendor Equipment Technical Information Program as committed in letter S. L. Daltroff, PECo.. to D.

G. Eissnhut.USNRC, dated April 23, 1984 by issuance of the following_ administrative and implementing procedures:

LS-A-1 Administrative Procedure for Review, Disposition and Monitcring of Responses to NRC IE Bulletins, IE Information Notices, and Division of Licensing Generic Letters

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LS-A-2 Administrative Procedure for Participation in Nucacar Plant Reliability Data System LS-I-5 Implementing' Procedure for Utilization of the INPO NPRD System LS-I-6 Implementing Procedure for Review, Disposition and Monitoring Nuclear Regulatory Commission IE Bulletins, IE Information Notices and Division of Licensing Generic Letters NS-A-5 Administrative Procedure for Review and Implementation of Operating Experience Inforration for Vendor Manual Maintenance In addition to the above listed procedures, the following existing procedures,.which have been prepared as a result of Generic Letter 83-28, are applicable to Items 1, 3, and 4 of the NUTAC Program NSS-I-4 Procedure for Review and Utilization of Operating Experience Information NSS-I-5 Procedure Governing the Use of the Institute of' Nuclear Power Operations Nuclear Network ERDP 6.4 Procedure for Control of Vendor Technical Manuals The requirements for controls for vendor services which

.are safety-related contained in the NUTAC program are specified in procedure A-27, Procedure for Material Control System for Peach Bottom.

Based on the program developed by Philadelphia Electric Company in accordance with the NUTAC-VETIP program, it is requested that NRC re-evaluate this program as a valid response to item 2.2.2 of the Generic Letter.

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n Mr.~ John F. Stolz.

May 29, 1985 Page 4 Item 4.5.3 - Incomplete The staff. finds that modifications are not required to permit on-line testing-of the backup scram valves.

However, the staff concludes that testing of the backup scram valves f

(including initiating circuitry) at a refueling outage

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frequency, in lieu of on-line testing, is appropriate and should be included in the technical specifications surveillance requirements.

The licensee needs to address this conclusion.

?Regarding the scram pilot' valves-(including all. initiating

-circuitry), the licensee needs to provide the results of a review of existing or proposed intervals for on-line testing considering the. concerns.of sub-items 4.5.3.1 to 4.5.3.5 of

.the generic-letter.

The response shall'show how these I

intervals result in high reactor trip system availability and

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present proposed technical specification changes for staff review..

RESPONSE:-

Philadelphia Electric Company participated in the BWR Owners Group effort to address the review of existing technical specification intervals-for testing reactor trip system

--components.

By way of this~ letter, Philadelphia Electric Company endorses the "BWR Owners Group Response to NRC Generic Letter 83-28, Item 4.5.3" (NEDC-30844)'for Peach Bottom Units 2 and 3.

This report was' transmitted for NRC

' staff review on January'31, 1985 via letter, John M..Fulton, Chairman BWROG to D. G. Eisenhut, USNRC.

In accordance'with the instructions contained in the reference letter, our plant specific response.for item 4.5.3 will be submitted within 90 days after.NRC issues its evaluation of NEDC-30844.

I Should you require any additional information, please do not. hesitate to contact us.

Very truly yo rs,

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s/E f'

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.cc:

T. P. Johnson, Resident Site Inspector e

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