ML021130454
| ML021130454 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 04/12/2002 |
| From: | Gallagher M Exelon Nuclear |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML021130454 (3) | |
Text
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Exelon Nuclear www.exeloncorp.com Nuclear 20o Exelon Way Kennett Square, PA 19348 10 CFR 50.55a April 12, 2002 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353
Subject:
Proposed Alternative Associated with the Second Ten-Year Interval Inservice Testing (IST) Program
Reference:
Letter from J. W. Clifford (U. S. Nuclear Regulatory Commission) to J. A. Hutton (PECO Energy Company), dated November 28, 2000
Dear Sir/Madam:
In the Referenced letter, the U. S. Nuclear Regulatory Commission provided approval of alternatives and relief requests associated with the second ten-year interval inservice testing (IST) program for Limerick Generating Station (LGS), Units 1 and 2. Attached for your review and approval is a proposed alternative for LGS, Units 1 and 2. Your approval is requested by April 15, 2003.
If you have any questions, please contact us.
Very truly yours, Michael P. Gallagher Director - Licensing & Regulatory Affairs Mid-Atlantic Regional Operating Group cc:
H. J. Miller, Administrator, Region I, USNRC A. L. Burritt, USNRC Senior Resident Inspector, LGS C. Gratton, Senior Project Manager, USNRC
LGS, Units 1 and 2 Proposed Alternative Page 1 RELIEF REQUEST NO. GVRR-7 Condensate Fill for Residual Heat Removal (RHR) System Condensate Fill for Core Spray System 51-1 F090B 51-1 F090D 51-1(2)032A,B 51-1(2)1116B,D 52-1(2)061 52-1(2)046B 51-2F090A 51-2F090C 51-1(2)115B,D 52-1(2)048A,B 52-1(2)045B 52-1 (2)FO30A,B C
Function:
Test Requirements:
Justification:
These check valves close to prevent a loss of inventory from the Safeguard Piping Fill System, which is required to maintain the Emergency Core Cooling System (ECCS) discharge headers filled. Those valves located in the discharge lines from Safeguard Piping Fill Pumps 1 (2)AP256 and 1 (2)BP256 are also required to open to maintain the ECCS discharge lines filled.
ASME OM Code-1 990, ISTC 4.5.2, "Exercising Requirements,"
and Generic Letter 89-04, "Guidance on Developing Acceptable Inservice Testing Programs," Position 2, "Alternative to Full Flow Testing of Check Valves," paragraph (c), allows grouping of check valves while testing at a refuel outage only.
In accordance with GL 89-04, Position 2, paragraph (c), a sample disassembly and inspection plan has been adopted for the check valves identified above. This plan groups the valves of identical construction, which are used in similar applications, and requires testing (at least) one valve in each group during each refueling outage. Input criteria to the group selections included valve design features and materials, service conditions, maintenance/failure history and piping arrangement considerations.
Testing of these valves during non-outages provides an acceptable level of quality and safety for the following reasons:
Systems:
Valves:
Category:
Alternative Test:
LGS, Units 1 and 2 Proposed Alternative Page 2
- 1) All OM Code-1990 requirements, specifically, the disassembly and inspection, and the refueling outage (approximately two (2) year) frequency, are being met.
- 2) The non-refueling outage frequency of approximately every two (2) years is the same length of time between refueling outages.
- 3) Testing of these valves during non-refueling outages will not lesson the quality of the tests as compared to testing during a refueling outage.
- 4) Performing these tests during non-refueling outages increases system availability during outages, and reduces manpower demands during outages.
Perform code testing on Safeguard Valves during non-refueling outages approximately every two (2) years, with no restriction on plant mode (i.e., refuel outage or non-refuel outage). This relief is requested in accordance with 10 CFR 50.55a(a)(3)(i) in that the alternative testing provides an acceptable level of quality and safety.