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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20196G4021999-06-18018 June 1999 Comment on FRN Re Rev of NRC Enforcement Policy NUREG-1600, Rev 1 & Amend of 10CFR55.49.Concurs with Need to Provide Examples That May Be Used as Guidance in Determining Appropriate Severity Level for Violations as Listed ML20206H1881999-05-0606 May 1999 Exemption from Requirements of 10CFR50,App K Re ECCS Evaluation Models. Commission Grants Licensee Exemption ML20206M5111999-04-30030 April 1999 Comment Supporting Draft RG DG-1083 Re Content of UFSAR IAW 10CFR50.71(e). Recommends That Listed Approach Be Adopted for Changes to Documents Incorporated by Ref CY-99-007, Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-0071999-02-22022 February 1999 Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-007 TXX-9825, Comment Endorsing NEI Comments on Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness at Npps1998-12-14014 December 1998 Comment Endorsing NEI Comments on Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness at Npps ML20154C4101998-09-30030 September 1998 Comment Re Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Comanche Peak Electric Station Endorses NEI Comment Ltr & Agrees with NEI Recommendations & Rationale ML20216E1051998-04-0707 April 1998 Comment Supporting Draft RG DG-1029 Titled Guidelines for Evaluating Electromagnetic & Radio-Frequency Interference in Safety-related Instrumentation & Control Sys ML20217H3611998-03-26026 March 1998 Comment Opposing Draft GL 97-XX, Lab Testing of Nuclear Grade Charcoal, Issued on 980225.Advises That There Will Be Addl Implementation Costs ML20198Q4851998-01-16016 January 1998 Comment Opposing PRM 50-63A by P Crane That Requests NRC Amend Regulations Re Emergency Planning to Require Consideration of Sheltering,Evacuation & Prophylactic Use of Potassium Iodide for General Public ML20211A4871997-09-12012 September 1997 Changes Submittal Date of Response to NRC RAI Re Proposed CPSES risk-informed Inservice Testing Program & Comments on NRC Draft PRA Documents ML20149L0311997-07-21021 July 1997 Comment on Draft Guides DG-1048,DG-1049 & DG-1050.Error Identified in Last Line of DG-1050,item 1.3 of Section Value/Impact Statement.Rev 30 Should Be Rev 11 ML20140A4871997-05-27027 May 1997 Comment Opposing Proposed Rule Re Safety Conscious Work Environ.Util Agrees W/Nuclear Energy Inst Comment Ltr ML20133G5411996-12-0505 December 1996 Transcript of 961205 Meeting in Arlington,Tx Re Comanche Peak Thermo-Lag Fire Barriers. Pp 1-111 ML20135B7881996-11-29029 November 1996 Order Approving Corporate Restructuring of TU to Facilitate Acquistion of Enserch Corp ML20128M8011996-10-0303 October 1996 Comment Opposing Proposed NRC Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations ML20097D7321996-02-0909 February 1996 Comment Opposing Petition for Rulemaking PRM-50-63 Re CPSES Request for Amend to Its Regulations Dealing W/Emergency Planning to Include Requirement That Emergency Planning Protective Actions for General Public Include Listed Info ML20094Q6421995-11-28028 November 1995 Comment Supporting Petition for RM PRM-50-62 Re Amend to Regulation Re QAPs Permitting NPP Licensees to Change Quality Program Described in SAR W/O NRC Prior Approval If Changes Do Not Potentially Degrade Safety or Change TSs ML20094H4801995-11-0808 November 1995 Comment Supporting Nuclear Energy Inst Comments on Proposed Rules 10CFR60,72,73 & 75 Re Safeguards for Spent Nuclear Fuel or high-level Radwaste ML20091M6441995-08-25025 August 1995 Comment Opposing Proposed Rule Re Review of Revised NRC SALP Program.Believes That NRC Should Reconsider Need for Ipap or SALP in Light of Redundancy ML20086M7921995-07-0707 July 1995 Comment Supporting Proposed GL Process for Changes to Security Plan Without Prior NRC Approval ML20084A0181995-05-19019 May 1995 Comment Suporting Proposed Rule 10CFR50 Re Containment Leakage Testing.Supports NEI Comments ML20077M7311994-12-30030 December 1994 Comments Opposing Proposed Rule 10CFR50 Re Shutdown & Low Power Operations for Nuclear Power Reactors ML20077L8711994-12-22022 December 1994 Comment Supporting Proposed Rule 10CFR50,55 & 73 Re Reduction of Reporting Requirements Imposed on NRC Licensees ML20073B6731994-09-19019 September 1994 Affidavit of Cl Terry Re License Amend Request 94-015 ML20073B6951994-09-19019 September 1994 Affidavit of Cl Terry Authorizing Signing & Filing W/Nrc OL Amend Request 94-016 ML20058E0561993-11-10010 November 1993 Comment on Proposed Rule Re Staff Meetings Open to Public. Believes That NRC Has Done Well in Commitment to Provide Public W/Fullest Practical Access to Its Activities ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process ML20045D8321993-06-11011 June 1993 Comment Supporting Proposed Rules 10CFR50 & 54, FSAR Update Submittals. ML20044F3271993-05-21021 May 1993 Comments on Draft NRC Insp Procedure 38703, Commercial Grade Procurement Insp, Fr Vol 58,Number 52.NRC Should Use EPRI Definitions for Critical Characteristics ML20056C0831993-03-19019 March 1993 Texas Utils Electric Co Response to Petitioners Motion to Stay Issuance of Full Power License.* Licensee Urges NRC to Reject Petitioners Motion & to Deny Petitioners Appeal of 921215 Order.Motion Should Be Denied.W/Certificate of Svc ML20056C1881993-03-17017 March 1993 Order.* Directs Util to Respond to Motion by COB 930319 & NRC to Respond by COB 930322.W/Certificate of Svc.Served on 930317 ML20128D9651993-02-0303 February 1993 Memorandum & Order.* Stay Request Filed by Petitioners Denied.W/Certificate of Svc.Served on 930203 ML20128F6221993-02-0303 February 1993 Transcript of 930203 Affirmation/Discussion & Vote Public Meeting in Rockville,Md.Pp 1-2.Related Info Encl ML20128D3391993-02-0202 February 1993 Emergency Motion to Stay Issuance of low-power Ol.* Petitioners Specific Requests Listed.W/Certificate of Svc ML20128D4651993-02-0202 February 1993 Texas Utils Electric Co Response to Emergency Motion to Stay Issuance of low-power Ol.* Petitioner Request Should Be Denied Based on Failure to Meet Heavy Burden Imposed on Party.W/Certificate of Svc ML20128D3461993-01-29029 January 1993 NRC Staff Notification of Issuance of OL for Facility.* Low Power License May Be Issued by 930201.W/Certificate of Svc ML20128D6321993-01-29029 January 1993 Memorandum & Order.* Denies Citizens for Fair Util Regulation for Fr Notice Hearing on Proposed Issuance of OL for Facility.W/Certificate of Svc.Served on 930129 ML20127L9321993-01-26026 January 1993 Affidavit of Re Architzel Re Thermo-Lag Installation at Testing for Unit 2.* Statement of Prof Qualifications Encl ML20128D6111993-01-26026 January 1993 Joint Affidavit of I Barnes & Ft Grubelich Re Borg-Warner Check Valves.* Discusses Issues Re Borg-Warner Check Valves Raised by Cfur & Adequacy of Actions Taken by TU Electric ML20127L9181993-01-26026 January 1993 NRC Staff Reply to Cfur Request for Publication of Proposed Action Re Licensing of Unit 2.* Cfur Request That Notice Re Licensing of Unit 2 Be Published Permitting Parties to Request Hearings Should Be Denied ML20127L9661993-01-26026 January 1993 Affidavit of Rl Pettis Re Borg-Warner Check Valves.* Statement of Prof Qualifications & Certificate of Svc Encl ML20127L9091993-01-25025 January 1993 Tx Util Electric Response to Citizens for Fair Util Regulation Request of 930113.* Request Fails to Raise Worthy Issue & Should Be Denied.W/Certificate of Svc ML20127L8891993-01-21021 January 1993 Order.* License Should File Response to Citizens for Fair Util Regulation Ltr Requesting That Commission Issue Fr Notice Providing for Opportunity for Hearing Re Issuance of OL by 930125.W/Certificate of Svc.Served on 930122 ML20127G9191993-01-19019 January 1993 Order.* Grants Petitioners Extension of Time Until 930122 to File Brief.Replies to Petitioners Brief Shall Be Filed on or Before 930208.W/Certificate of Svc.Served on 930119 ML20127G9441993-01-19019 January 1993 TU Electric Brief in Opposition to Petitioners Appeal of ASLB Memorandum & Order.* Requests That Petitioners Appeal Be Denied & Licensing Board 921215 Memorandum & Order Be Affirmed.W/Certificate of Svc ML20127G8041993-01-15015 January 1993 NRC Staff Response to Appeal of Licensing Board Decision Denying Petition for Leave to Intervene & Request for Hearing Filed by Bi & Di Orr.* Board 921215 Decision Should Be Upheld.Certificate of Svc Encl ML20127G7451993-01-14014 January 1993 NRC Staff Response to Motion of Petitioners RM Dow & SL Dow, (Disposable Workers of Comanche Peak Steam Electric Station),For Leave to File Out of Time & Request for Extension of Time to File Brief.* W/Certificate of Svc ML20127G7941993-01-12012 January 1993 Opposition of TU Electric to Motion for Leave to File Out of Time & Request for Extension of Time to File Brief by SL Dow (Disposable Workers of Comanche Peak Steam Electric Station) & RM Dow.* W/Certificate of Svc ML20127A5931993-01-0808 January 1993 Brief in Support of Petitioner Notice of Appeal.Aslb Erred by Not Admitting Petitioner Contention & Action Should Be Reversed.W/Certificate of Svc ML20127A6371993-01-0707 January 1993 Notice of Appeal.* Appeal Submitted Due to 921215 Memo Denying Petitioner Motion for Rehearing & Petition for Intervention & Request for Hearings.Proceedings Were Terminated by Aslb.W/Certificate of Svc 1999-06-18
[Table view] Category:PUBLIC COMMENTS ON PROPOSED RULES & PETITIONS FOR
MONTHYEARML20196G4021999-06-18018 June 1999 Comment on FRN Re Rev of NRC Enforcement Policy NUREG-1600, Rev 1 & Amend of 10CFR55.49.Concurs with Need to Provide Examples That May Be Used as Guidance in Determining Appropriate Severity Level for Violations as Listed ML20206M5111999-04-30030 April 1999 Comment Supporting Draft RG DG-1083 Re Content of UFSAR IAW 10CFR50.71(e). Recommends That Listed Approach Be Adopted for Changes to Documents Incorporated by Ref CY-99-007, Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-0071999-02-22022 February 1999 Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-007 TXX-9825, Comment Endorsing NEI Comments on Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness at Npps1998-12-14014 December 1998 Comment Endorsing NEI Comments on Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness at Npps ML20154C4101998-09-30030 September 1998 Comment Re Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Comanche Peak Electric Station Endorses NEI Comment Ltr & Agrees with NEI Recommendations & Rationale ML20216E1051998-04-0707 April 1998 Comment Supporting Draft RG DG-1029 Titled Guidelines for Evaluating Electromagnetic & Radio-Frequency Interference in Safety-related Instrumentation & Control Sys ML20217H3611998-03-26026 March 1998 Comment Opposing Draft GL 97-XX, Lab Testing of Nuclear Grade Charcoal, Issued on 980225.Advises That There Will Be Addl Implementation Costs ML20198Q4851998-01-16016 January 1998 Comment Opposing PRM 50-63A by P Crane That Requests NRC Amend Regulations Re Emergency Planning to Require Consideration of Sheltering,Evacuation & Prophylactic Use of Potassium Iodide for General Public ML20211A4871997-09-12012 September 1997 Changes Submittal Date of Response to NRC RAI Re Proposed CPSES risk-informed Inservice Testing Program & Comments on NRC Draft PRA Documents ML20149L0311997-07-21021 July 1997 Comment on Draft Guides DG-1048,DG-1049 & DG-1050.Error Identified in Last Line of DG-1050,item 1.3 of Section Value/Impact Statement.Rev 30 Should Be Rev 11 ML20140A4871997-05-27027 May 1997 Comment Opposing Proposed Rule Re Safety Conscious Work Environ.Util Agrees W/Nuclear Energy Inst Comment Ltr ML20128M8011996-10-0303 October 1996 Comment Opposing Proposed NRC Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations ML20097D7321996-02-0909 February 1996 Comment Opposing Petition for Rulemaking PRM-50-63 Re CPSES Request for Amend to Its Regulations Dealing W/Emergency Planning to Include Requirement That Emergency Planning Protective Actions for General Public Include Listed Info ML20094Q6421995-11-28028 November 1995 Comment Supporting Petition for RM PRM-50-62 Re Amend to Regulation Re QAPs Permitting NPP Licensees to Change Quality Program Described in SAR W/O NRC Prior Approval If Changes Do Not Potentially Degrade Safety or Change TSs ML20094H4801995-11-0808 November 1995 Comment Supporting Nuclear Energy Inst Comments on Proposed Rules 10CFR60,72,73 & 75 Re Safeguards for Spent Nuclear Fuel or high-level Radwaste ML20091M6441995-08-25025 August 1995 Comment Opposing Proposed Rule Re Review of Revised NRC SALP Program.Believes That NRC Should Reconsider Need for Ipap or SALP in Light of Redundancy ML20086M7921995-07-0707 July 1995 Comment Supporting Proposed GL Process for Changes to Security Plan Without Prior NRC Approval ML20084A0181995-05-19019 May 1995 Comment Suporting Proposed Rule 10CFR50 Re Containment Leakage Testing.Supports NEI Comments ML20077M7311994-12-30030 December 1994 Comments Opposing Proposed Rule 10CFR50 Re Shutdown & Low Power Operations for Nuclear Power Reactors ML20077L8711994-12-22022 December 1994 Comment Supporting Proposed Rule 10CFR50,55 & 73 Re Reduction of Reporting Requirements Imposed on NRC Licensees ML20058E0561993-11-10010 November 1993 Comment on Proposed Rule Re Staff Meetings Open to Public. Believes That NRC Has Done Well in Commitment to Provide Public W/Fullest Practical Access to Its Activities ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process ML20045D8321993-06-11011 June 1993 Comment Supporting Proposed Rules 10CFR50 & 54, FSAR Update Submittals. ML20044F3271993-05-21021 May 1993 Comments on Draft NRC Insp Procedure 38703, Commercial Grade Procurement Insp, Fr Vol 58,Number 52.NRC Should Use EPRI Definitions for Critical Characteristics ML20105C8951992-09-14014 September 1992 Comment Opposing Proposed Generic Ltr Concerning analog-to-digital Replacements Under 10CFR50.59 ML20091Q8661992-01-31031 January 1992 Comment Opposing Draft NUREG-1022,Rev 1, Event Reporting Sys,10CFR50.72 & 50.73,Clarification of NRC Sys & Guidelines for Reporting ML20077C9891991-05-21021 May 1991 Comment Opposing Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery TXX-9103, Comment Supporting Proposed Rule Re SECY-90-347, Regulatory Impact Survey Rept1991-01-28028 January 1991 Comment Supporting Proposed Rule Re SECY-90-347, Regulatory Impact Survey Rept ML20247R5611989-09-18018 September 1989 Comment on Proposed Rules 10CFR30,40,50,60,70,72 & 150 Re Preserving Free Flow of Info to Commission.Rules Do Not Seem to Limit Subcontractor Tier at Which Licensee Responsibilities End TXX-8855, Comment Supporting Proposed Rule 10CFR50 Re Addl Applications of leak-before-break Technology.Util Strongly Endorses Proposal to Investigate Safety Benefits Associated w/leak-before-break Technology1988-08-0505 August 1988 Comment Supporting Proposed Rule 10CFR50 Re Addl Applications of leak-before-break Technology.Util Strongly Endorses Proposal to Investigate Safety Benefits Associated w/leak-before-break Technology ML20154G2921988-04-19019 April 1988 Comment Supporting Proposed Rules 10CFR50 & 73 Re Policy Statement on Nuclear Power Plant Access Authorization 1999-06-18
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DOCKET HUMBL3 3 PROPOSED RU!.E L _50 0
63)C*/( //.3//
M C% W MM ~
Log # TXX-88557 L -File # 903.1 903.11 '88 AUG -8 P 5 :08 -
TUELECTRIC Ref. # 10CFR50.4(a) 0Fn - N 00Cni.i -
Wmism G. Coumil August 5, 1988 We becutive Vice Pressdent Mr. Samuel J. Chilk, Secretary of the Commission U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn: Docketing and Service Branch
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
COMMENTS ON ADDITIONAL APPLICATIONS OF LEAK-BEFORE-BREAK TECHNOLOGY (53 FED. REG. 11311, APRIL 6, 1988)
Dear Mr. Chilk:
In the subject Federal Register publication, the NRC stated that it is proposing to investigate the safety benefits associated with using leak-before-break technology to modify functional and performance requirements for emergency core cooling systems (ECCS) and environmental qualification (EQ) of safety-related electrical and mechanical equipment. The publication requested comments on this proposal, with particular emphasis on "documented evidence describing safety degradations and safety enhancements due to postulated pipe rupture requirements on EQ and ECCS...". It indicated that the priority which it "assigns to modifying functional and performance requirements for EQ and ECCS.will be determined in large measure from the balance between accrued safety benefits and detriments' believed to result (including impacts on severe accident performance)."
In response to this NRC request for comments, IV Electric strongly endorses the proposal to investigate the safety benefits associated with using leak-before-break (LBB) technology to modify functional and performance requirements for ECCS and EQ and urges the NRC to initiate a proposed rulemaking to implement such benefits.
The following comments describe the substantial safety benefits that would be derived from such additional applications of LBB technology. Although TV Electric cannot at this time provide documented data in support of such benefits it believes that the arguments are sufficiently convincing-that the NRC should assign high priority to a proposed rulemaking in this area.
l 8808160079 880805 PDR PR 50 53FR11311 PDR
,b5JO 400 North Olive Street iB 81 l>allas, Texas 7H01
TXX-88557 August 5, 1988 Page 2 of 5 EQ Related Comments (a) The current interpretation of accident criteria develops calculated l radiation exposures of 108 to 109 rads gamma plus beta for areas inside containment. Instruments gnd elegtrical penetrations in common ,
usage meet the requirements of 10/ to 100 rads gamma. The I application of leak-before-break (LBB) technology would reduce the level j of calculated radiation exposures inside containment under accident !
criteria and thus-provide the follovfing significant safety benefits: '
(1) Elimination of Additional Qualification Testing Reduction in the qualification testing will make more types of instrumentation available to the designer at reasonable cost.
The system safety will be improved by the introduction of diverse safety equipment. For example, the AMSAC equipment utilized by CPSES has taken advantage of the availability of an alternative manufacturer (FSAR Section 7.8.1.9) . 3 (2) Utilization of Proven Equipment Standard equipment models represent the hulk of manufacturer operational experience and, in general, perform the best. If special adaptations are made to meet excessive radiation requirements, then the new material selection or design feature.
may not perform equivalently. This has many actual examples. A common one is the substitution of a more radiation resistant but i harder gasket material resulting in more repeated maintenance I than a resilient material would require. 1 (3) Improved Quality, Availability and Cost of Replacement Parts The discussion with respect to instrumentation availability as given in (1) is equally applicable to replacement parts. The discussion with respect to the use of proven equipment as given in (2) is equally applicable to the quality and capability of replacement parts.
(4) Elimination of Unnecessary Shielding If the equipment radiation resistance cannot be improved, the designer may elect to shield the equipment from the hypothetical radiation. This case is analogous to t':e additional supports eliminated by the original LBB interpretation. Elimination of the unnecessary shielding improves access for maintenance and testirig of the ECCS instruments.
/
1
. 1 TXX-88557 August 5, 1988 Page 3 of 5 i
(5) Elimination of Unnecessary Surveillance and Maintenance in Radiation Areas '
Elimination of an unnecessarily high "reserve life" to accormnodate an accident will allow a longer qualified life, thcs reducing maintenance and replacement activity. This more 1
realistic approach will reduce the overall radiation exposure to {
plant workers. Less frequent maintenance activity will also improve plant availability. INP0 87-022 "Operational Performance of Reactor Protection Systems In U.S. Pressurized Water Reactors:
1981-1985" identifies trips while one channel is out for maintenance or surveillance, as a major cause of unplanned automatic scrams.
(b) Application of LB8 technology in determining the environmental requirements within containment will reduce the temperature and pressure parameters (as well as the radiation). This reduction would:
(1) Eliminate some additional qualification testing as in (a)(1) above.
(2) Enable more standard equipment to be applied as in (a)(2) above.
(3) Improve availability as in (a)(3) above.
(4) Extend qualified life and reduce surveillance and maintenance as in (a)(5) above.
(c) The nature of a large bore guillotine pipe break outside containment, e.g. main steam line break (MSLB), is to create harsh environmental conditions removed.
not only in the vicinity of the break, but in rooms far The application of LBB technology would:
(1)
Reduce EQ Requirements for Rooms Which Do Not Contain High Energy Piping Correspondingly, leak detection provisions outside containment will need to be supplemented and improved. The designer would be required to show that the leak detection capabilities are consistent with the reduction in the propagation of the environmental effects. Provision of radiation monitors for leak detection outside containment may have limited application.
However, area temperature and humidity monitors located in compartments where high energy piping failures are postulated should improve leak detection capability, w _-
._ _ ~ _. . _. .. .
TXX-88557 August 5,11988 Page 4'of 5 (2) Improved Knowledge of Plant Condition An increased number of leak detection instruments distributed
-strategically throughout the plant would provide Control Room personnel with improved knowledge of pressure boundary performance. For the stme expenditure, the capability of the defense-in-depth is improved by investment in leak detection rather than by investment in qualifying equipment located in compartments that are remote from the postulated break area.
Use of various and appropriate. leak detection devices would represent a diversification of safeguard 5 as compared to the environmental qualification of existing equipment.
Equipment as presently specified is over-designed for the environment that it is likely to see throughout its lifetime.
The reduction of EQ requirements represents a more cost effective selection of equipment. An additional benefit of the extensive leak detection system will be better plant availability since operators will be able to respond earlier to a leat rather than ,
to the break that might ensue. Among the benefits of early response would be a reduction of drainage ano wastes.to treat.
I (d) Similarly to item (c), a postulated break in the letdown line creates an area of harsh chemical, temperature and dynamic effects. Under application of LBB technology:
If the harsh chemical environment br.s ruled out the use of some equipnient, benefits to diversit.v as described 'in (a)(1) will be possible; and If the harsh chemical environment has necessitated modifications to equipment, benefits to the quality of equipment'as described in (a)(2) will be possible.
l
TXX-88557 August 5, 1988 Page 5 of 5 '
ECCS Related Comments '
(a) The designer can use LBB methodology to define a new "Design Maximum i 1.eak" as justified by the system components and piping employed, i defining a new "Design Maximum Leakage" may allow reduced capacity !
requirements for the ECCS pumps. With a reduced capacity requirement, I the designer could improve pump reliability by lowering motor starting ,
torque, reducing required Net Positive Suction Head (NPSH), and improving l the NPSH available to the pumps. These factors would improve seal wear '
ring, and bearing wear and enhance equipment performance during testing and actual operation. I With reduced ECCS pump motor sizes, operational benefits will be accrued when loading the Emergency Diesel Generator (EDG). Assuming loss of offsite power, these pump motors will sequerce onto the safeguards hus more reliably because the load step with transient instability will be !
lower. Mitigation of this transient may also be achieved by expanding '
the timing allowed for the EDG loading sequence. ;
(b) The designer can use ti,e removal of the sudden large break case to revise the instrument setpoints for ECCS actuation. This would create a larger !
margin to the normal operating range. This application of L8B technology l
would reduce the occurrences of inadvertent actuations of the ECCS systems due to the widening of margins'for normal instrumentation ,
readings. The occurrenco of spurious scrams amounted to 17% of the cases !'
as reported in INPO 87-022.
l Once again, TV Electric strongly endorses the initiation of a proposed I rulcmaking to bring practical realism to modify functional and performance requirements for ECCS and EQ.
Very truly yours,
/ 7 W. G. Counsil HAM /grr c - Mr. R. D. Martin, Region IV Resident inspectors, CPSES (3)
.