ML19350B411

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Requests Concurrence That Existing Facility Fire Hose Testing Requirements Per Tech Spec 4.14.A.4.d Identify Proper Testing Pressures to Comply w/10CFR50.48 & 10CFR50,App R
ML19350B411
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 03/12/1981
From: Daltroff S
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To: Eisenhut D
Office of Nuclear Reactor Regulation
References
NUDOCS 8103200478
Download: ML19350B411 (2)


Text

PHILADELPHIA ELECTRIC COMPANY

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Re: Do c ke t Nos. 50-277 50-278 Mr. Darrell G.

Eisenhut, Director Division of Lie tnsing US Nuclear Regulatory Commission Washington, DC 20555

Reference:

10 CFR 50.48 and 10 CFR 50, Appendix R, Issued November 19, 1980.

Dear Mr. Eisenhut:

Section III.E of Appendix R to 10 CFR Part 50 requires that fire hose must be tested at a pressure of 300 psi or 50 psi above maximum fire main operating pressure, whichever is greater.

However, Section 4.14.A.4.d of the Peach Bottom Units 2 and 3 Technical Specifications establishes a hose testing pressure of at least 50 psi greater than the maximum pressure available at the hose station, but not less than 150 psi.

In accordance with the requirements of the Technical Specifications, the 1 1/2 inch interior hoses at Peach Bottom are tested every three years at 200 psi.

The requirements for hose tests were added to the Technical Specifications on May 16, 1980, by Amendment Nos. 60 and 68 to the Peach Bottom Units 2 & 3 operating licenses.

Tha hose testing requirements had been requested by Philadelphia Electric Company in an Application dated April 15, 1980, and were based upon hose testing requirements stated in a letter from T. A.

Ippolito, NRC to E. G. Bauer, Jr., d ated November 17, 1978, and Section 4.7.7.5 of the NRC's Standard Technical Specifications for General Electric Boiling Water Reactors dated August, 1979 00(

Because of the provisions of Section 50.48 (b) of the 5

Commission's Regulations, it is our view that the hose testing 8103200 $R E

Page 2 requirements as specified in the Technical Specifications are controlling on the question of the appropriate test pressure to be used for the Peach Bottom hose tests.

If the testing requirements of the Technical Specifications were to be replaced by a requirement for a 300 psi test, it would be necessary to replace all fire hoses at Peach Bottom with hose rated for a higher pressure, and due to potential contamination of onsite fire hoses, a sophisticated onsite test facility necessary to test fire hose at the' higher pressure without risk to testing personnel would be required.

The purchase of new hose and the installation of a new test facility does not appear to be cost beneficial under the circumstances, nor does it appear appropriate to require periodic testing at a pressure approximately double the maximum operating pressure.

In view of the foregoing. we would appreciate your advising us of your concurrence that the existing Peach Bottom fire hose testing requirements as specified in the Peach Bottom Technical Specifications identifies the proper testing pressures to be used at Peach Bottom Units 2 and'3 Very truly yours,

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