ML20151Y861

Responds to 860127 Monthly Notice Re Application & Amends to OLs Involving Nshc.Extension of Period for Testing Certain Instrument Lines Opposed Due to Importance of Lines in Plant Operation & Operator Info Needs

ML20151Y861
Person / Time
Site:	Limerick
Issue date:	01/30/1986
From:	Anthony R ANTHONY, R.L.
To:	NRC OFFICE OF THE SECRETARY (SECY)
Shared Package
ML20151Y859	List: ML20151Y854 ML20151Y861
References
OL, NUDOCS 8602130197
Download: ML20151Y861 (2)

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• COUL TE Soorotory of the Cammiosion - Lockoting & ServeRC Bor 186 Moylon,Pa 19065 U.S. Nuclcor Regulatory Commissica l3 i

Washington,D.C. 20555 January 30, 1986

Dear Si r,

'86 FER 12 Pl2 :00 We~are responding to a copy of a doegment dated 1/27/86 to Mr.4.G. Bauer, Phila Eleo. Co., from NRC which is a formD%4dt_in, g ~.toeLimerick Generating Sta-tion, Unit 1, identified as " Monthly Noticej Ap)19sitions and Amendments to Opera-l ting Licenses Involving no Significant Hasards considerations, dated Dec. 264 30, 1986 and Jan. 9, 1986 ". With this document we received copies of the Federal Register which inform that the NBC is considering issuance of an amendment to Op. Lie # NPF-39 to PEco for the operation of Limerick Cen.Sta. No 1. This would allow PEco an extention of time for testing certain instrument lines to a nazi-num of 96 days beyond the time required in the Tech.Speos.

As an intervenor in theLimerick licensing proceedings under the name R.L.

Anthony /FOR we register our opposition to the granting of this extention of time and petition for leave to intervene. In accordance with and we requestona hearing the instructions p.52 575 F.R. we notified Western Union this morning D

1. 3737 to NRC,to this effect. We call your attention to the fact that we could not have responded any earlier since the NRC notice ,l/27/86, reached us only on 1/29/86.

We are convinced that any extention of time for the tests required to determine the ability of the instrumentation lines to function properly would pose risks to our health and safety since these lines are essential to operator information and functioning in every aspect of the plant & operation and are a key link in the control of the nuolear process and absolutely essential to the safe shutdown of the plant in the event of any accident at the plant which could {

result ing u in the release of radioactive poisons to the ' environment,thereby threates- l and the publio.

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It is especially important for these lines to be checked for any faults or 1 weaknesees which could cause them to mal-function in case of any accidental force which might be applied to them from the rupture or whipping of adjacent pipes.

This kind of eventuality was reported in a study by Torrey Pines Technology for PEco, entitled

• Independent Desiga Review of Limerick Generating Station, Unit no.1 , Core Spray System." We are enclosing a copy of page 12 from Vol.1 j of this study, Executive Summary, Nov.1984, which gives conclusions on small pipes.

The findings in this study are particularly significant in relation to  !

instrumentation lines and possible jet impingement loads. Paragraph two.on page 12 points out " unconservative extrapolations of test data" and calls attention to the need for sophisticated analyses and possible impingensat barriers. We have no information as to whether such barriers have ever been placed. This would be oneof the avenues of on questioning in a hearing. We would also follow l up the warnings in paragraph three, " multiple errors and inconsistencies"and "the impact of the errors" which "could not be assessed within the TPT (Torrey Pines) review scope ". We have so information on" analyses"or" design modifications "

iwhich are listed as possible corrective actions.

We suggest to the Commission that a essential for the safe operation of the instrumentation lines to conduct the te sts on the schedule set up in the Tech.

Space. The safe operation of the plant and the protection of the health and safety of the public depend on this.APy action b Eac( p.12 Torrey Pines Design Review,Nov.y 1984NRC without a hearing would be prejudici Sincerely yours, ocs Others NRC Exeo. on gl gt, Conner and Wetterhahm hI . fnk*

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,QA.Primr~ ill!r.3 4- Arnu. soe u-High and Moderate Energy Line Break Analysis. Feature 10 One Observation and three Findings resulted from the review of this feature, he Observation notes that an h7AC duct which was subject to jet impingement from a Core Spray line break was not identified in the analyses for 3

the consequences of that break. Subsequent investigation revealed redundant cold air sources so that there would be adequate cooling.

One of the Findings pointed out the use of unconservative extrapolations of test data to evaluate the adequacy of instrunentation line subject to jet impingement loads. Review of subsequent conventional computer analysis by BPC for the instrunent line impinged by a jet from a broken Core Spray pipe showed the adequacy of that instrunent line. However, there were other instrunent 11_nes which were considered adequate based on the same unconservative - '

extrapolation of the test data. Be PECo CAP states that analyses will be made for all such instrunent lines, and that if conventional computer analysis does not show the adequacy of the instrunent lines, more sophisticated analyses or tests would be perfcrmed. Only as a last resort would jet impingement barriers be utilized. The CAP adequately addresses the concerns raised by the Finding.

The renaining two Firdings addressed multiple errcrs and inconsistencies in the analyses which were perfonned to show that the plant could te safely _, .

shut down follcwing postulated breaks in the Core Spray piping. An accurate assessnent of the impact of these errors would have required significant review of plant systens and equignent which were not within the CSS. This would have gone far beyond the intended scope of the TFT review. Thus the impact of the errors could not be assessed within the TPT review scope, he multiplicity of the errors also suggested that other errors could exist which were, not investi _

gated, he PECo CAP for these two Findings identifies that all plant safety analyses associated with jet impingement will te reviewed to assure that a logical prescribed methodology is follcued and that all errors and ,

inconsistencies found are corrected. he prescribed methodology includes : .

provision for more sophisticated analyses, or, as.a last r'esortl-designbf[

modifications. he CAP adequately adhsses the concernsYaihd'bf 'the

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