ML19345C903
| ML19345C903 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 11/17/1980 |
| From: | Tedesco R Office of Nuclear Reactor Regulation |
| To: | Bauer E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| NUDOCS 8012080581 | |
| Download: ML19345C903 (4) | |
Text
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a Mr. Edward G. Bauer, Jr.
Vice President & General Counsel Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101
Dear Mr. Bauer:
SUBJECT:
INSERVICE INSPECTION OF PRESSURE ISOLATION VALVES (Limerick Generating Station, Unit Nos 1 and 2)
As a result of our review of your application regarding inservice inspection of pressure isolation valves, we require the following information:
Provide a list of pressure isolation valves included in your testing program with four (4) sets of piping and instrumen-tation diagrams which clearly show the reactor coolant system isolation valves. Also, discuss in detail how your leak test-ing program conforms to the staff position (see enclosure).
It is requested that this information be provided within 15 days of receipt of this letter. This position has previously been provided to your staff.
Sincerely, 4f8t/&
bert L. Tedesco, Assistant Director for Licensing Division of Licensing
Enclosure:
Staff Positioni -
Inservice Inspection of Pressure Isolation V&lves, September 22, 1980 s012080. @ /
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-Mr. Edward G. Bauer, Jr.
=Vice President & General Counsel Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 cc: Troy B. Conner, Jr., Esq.
Conner, Moore & Corber 1747 Pennsylvania Avenue, N. W.
Washington, D. C.
20006 Deputy Attorney General Room 512, Main Capitol Building Harrisburg, Pennsylvania 17120 Mr. Robert W. Adler Assistant Attorney General Bureau of Regulatory Counsel 505 Executive House P.
0.~ Box 2357 Harrisburg, Pennsylvania 17120 Honorable Lawrence Coughlin House of Representatives Congress of the United States Washington, D. C.
20515 Roger B. Rep olds, Jr., Esq.
324 Swede Street Norristown, Pennsylvania 19401 Lawrence Sager, Esq.
Sager & Sager Associates 45 High Street Pottstown, Pennsylvania 19464 Joseph A. Smyth Assistant County Solicitor County of Montgomery Courthouse Norristown, Pennsylvania 19404 Eugene J. Bradley Philadelphia Electric Company Associate General Counsel 2301 Market. Street Philadelphia, Pennsylvania 19101 Mr. Jacque Durr
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Resident Reactor Inspector.
U. S. Nuclear Regulatory Comission P. O. Box 47 Sanatoga, Pennsylva'nia 19464
o 210.0 MECHANICAL ENGINEERING BRANCH There are several safety systems connected to the reactor coolant pressure boundary that have design pressure below the rated reactor coolant system (RCS) pressure. There are also some systems which are rated at full reactor pressure on the discharge side of pumps but have pump suction below RCS pressu e.
In order to protect these systems from RCS pressure, two or more isolation valves are placed in series to form the interface between the high pressure RCS and the low pressure systems. The leak tight integrity of these valves must be ensured by periodic leak testing to prevent exceeding the design pressure of the low pressure systems thus causing an inter-system LOCA.
Pressure isolation valves are required to be category A or AC per IWV-2000 and to meet the appropriate requirements of IWV-3420 of Section XI of the ASME Code except as discussed below.
Limiting Conditions for Operation (LCO) are required to be added to the technical specifications which will require corrective action f.e., shutdown or system isolation when the final approved leakage limits are not met. Also surveillance requirements, which will state the acceptable leak rate testing frequency, shall be provided in the technical specifications.
Periodic leak testing of each pressure isolation valve is required to be performed at least once per each refueling outage, after valve maintenance prior to return to service, and for systems rated at less than 50% of RCS design pressure each time the valve has moved from its fully closed position unless justification is given. The testing interval should average to be approximately one year. Leak testing should also be performed after all disturbances to the valves are complete, prior to reaching power operation following a refueling outage, maintenance and etc.
The staff's present position on leak rate limiting conditions for operation must be equal to or less than 1 gallon per minute for each valve (GPM) to ensure the integrity of the valve, demonstrate the adequacy of the redundant pressure isolation function and give an indication of valve degradation over a finite period of time. Significant increases over this limiting valve would be an indication of valve degradation from one test to another.
Leak rates higher than 1 GPM will be considered if the leak rate changes are below 1 GPM above the previous test leak rate or system design precludes measuring 1 GPM with sufficient accuracy.
These items will be reviewed on a case by case basis.
The Class 1 to Class 2 boundary will be considered the isolation point which must be protected by redundant isolation valves.
In cases where pressure isolation is provided by two valves, both will be inde-pendently leak tested. When three or more valves provide isolation, only two of the valves need to be leak tested.
Provide a list of all pressure isolation valves included in your testing program along with four sets of Piping and Instrument Diagrams which describe your reactor coolant system pressure.f solation valvest 1 Also. discuss in detail how your leak'
. testing program will conform to~ the' above staff position.
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