ML20045B546

Forwards Request for Exemption from 2-yr Test Interval for Type B & C Leak Rate Tests to Support Current Refueling Outage Schedule & Avoid Extended Reactor Shutdown.List of Surveillance Tests Encl

ML20045B546
Person / Time
Site:	Peach Bottom
Issue date:	06/11/1993
From:	Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9306180056
Download: ML20045B546 (9)

Text

' '

10 CFR 50.12 s -

PHILADELPHIA ELECTRIC COMPANY NUCLEAR GROUP HEADQUARTERS 955-65 CHESTERBROOK BLVD.

WAYNE, PA 19087-5691 (215) 640mo Docket No. 50-278 License Nos. OPR-56 STADON SUPPORT DEPARTMENT U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Peach Bottom Atomic Power Station, Unit 3 Request for Exemption from 10 CFR 50, Appendix J Type B and C Test Intervals

Dear Sir:

Pursuant to 10 CFR 50.12(a), Philadelphia Electric Company (PECo) requests exemption from the two year test interval for Type B and C leak rate tests required by 10 CFR 50, Appendix J, Sections III.D.2(a) and III.D.3.

Attachment I contains a discussion of the specific exemptions and the necessary justification in accordance with 10 CFR 50.12(a). Attachment 2 contains the surveillance tests for which the exemption would apply.

This exemption is requested on a one-time only basis to support our current refueling outage schedule and avoid an extended reactor shutdown.

We request that this exemption be granted no later than August 15, 1993.

We note that Technical Specification Change Request (TSCR) 92-03, dated September 28, 1992, and supplemented in a letter dated June 7, 1993, requested, in part, that the surveillance testing interval for Type B and C tests be changed from 24 months to that required by 10 CFR 50, Appendix J.

This TSCR was submitted to request changes to surveillance intervals to accommodate a 24 month operating cycle. We anticipate this TSCR will be approved prior to August 15, 1993, thus, another TSCR is not being submitted.

If you have any questions, please contact us.

Very truly yours,

~ -

1,i0U.C6 G.A. Hunger,f.,'

Jr Director l Licensing Section /

cc: T. T. Martin, Administrator, Region I, USNRC 'l USNRC Senior Resident Inspector, PBAPS I 9306180056 930611 I" PDR ADOCK 05000278 6 P PDR {j .

l

.. .- ,:l d

i i

f

~!

q  !

ATTACHMENT 1  :

Peach Bottom Atomic Power Station, Unit 3  ;

Request for Exemption- 3 l

from 10 CFR 50, Appendix J -

Type B ard C Test Intervals  :

i 4

6 I

i 1

.. j t

l

.1 J

I i

j

~

J

.RE UEST FOR EXEMPT 10N  :

DISCUSSION AND JUSTIFICATION }

Sections III.D.2(a) and III.D.3 of 10 CFR 50, Appendix J, require that Type B and C containment penetration leak rate tests be performed at intervals no greater than two years. Accordingly, Philadelphia Electric Company (PECo) requests a one time exemption from these requirements for the surveillance  ;

tests (STs) identified in Tables 1 and 2 of Attachment 2 for a period of 60 l days. If granted, the 60 day extension will be applied to the current l expiration date of each ST listed on Tables 1 and 2. j Exemptions are being requested in order to 1) avoid an extended reactor shutdown in order to comply with the two year testing interval, and 2) to allow for scheduling flexibility in an operating cycle of 24 months. Peach 1 Bottom Atomic Power Station, Unit 3 is now utilizing a new core design which allows the intervals between reactor shutdowns for refueling to extend beyond  ;

the maximum allowable two year interval. Prior to the current operating cycle, local leak rate tests were performed in conjunction with an operating  ;

cycle of 18 months. Use of extended cycle core designs has been recognized as  !

a growing trend in the industry as discussed in Generic Letter 91-04, " Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month -

Fuel Cycle," dated April 2, 1991.  :

Table 1 contains 11 of the 38 STs from which PECo is requesting exemption.

These 11 Type B and C STs are due to be tested prior to shutdown of PBAPS, Unit 3 for the upcoming Cycle 9 refueling outage scheduled to occur no later  ;

than September 18, 1993. PECo requests exemption for these tests for a period of 60 days to avoid a premature reactor shutdown resulting from either ,

isolation of necessary safety systems, or the need to access the drywell to test penetrations inaccessible during plant operations. -Performance of these r tests at the scheduled 24 month frequency would result in undue financial hardship with little or no compensating increase in the level of safety or -

quality.

For the 11 STs which will become due while the reactor is still at power, the earliest due date for any of these STs is September 14, 1993. This represents a maximum interval of only 4 days from the date that the ST will become due to the date that the reactor will be in Cold Shutdown. Extending the testing interval 60 days of which only 4 days will be during power operation, will not significantly impact the integrity of the containment boundary and, therefore, ,

would not significantly impact the consequences of an accident or transient in the unlikely occurrence of such an event during the 4 days of power operation.

This minimal impact on primary containment integrity has been further reduced l through a large margin in primary containment integrity as discussed below.  ;

The large margin in primary containment integrity can be demonstrated by review of the-total Type B and C minimum pathway leak rates. The as-found value was 35,197 cc/ min. and the as-left was 24,453 cc/ min. as calculated'for the PBAPS, Unit 3, Cycle 8, refueling outage in the Fall of 1991. This as-found and as-left leak rates represent a significant margin to the leak rate

Page 2-value of 125,417 cc/ min. (La, minimum pathway leakage) necessary for primary

-containment. The extension of the 24 month testing interval for 4 days for the 11 STs listed in Table I would not be expected to significantly decrease this margin, even considering the extended operating cycle, to the point that primary containment integrity would be violated.

Table 2 contains the other 27 STs which are Type B and C tests scheduled to be performed after the shutdown of PBAPS, Unit 3 (September 18,1993). PECo .

requests exemption for these tests for a period of 60 days in order to obtain scheduling flexibility during the Cold Shutdown condition in which the need for primary containment integrity is not required resulting in minimal safety significance. This scheduling flexibility will ensure that performance of the i STs will not impact critical path activities and result in an unnecessary increase in the length of the outage. Extending the length of the outage would result in undue financial hardship with little or no compensating increase in the level of safety or quality, e

All surveillance tests associated with this exemption will be completed prior to restart from the upcoming PBAPS, Unit 3, Cycle 9 refueling outage.

10 CFR 50.12 allows the Commission to grant exemptions from the requirements ,

of regulations contained in 10 CFR Part 50 provided that: (1) the exemption is authorized by law; (2) the exemption will not present an undue risk to the public health and safety; (3) the exemption is consistent with the common cafense and security; and (4) special circumstances, as defined in 10 CFR  ;

S0.12(a)(2), are present. Each of these criteria are discussed below.

1. The Requested Exemption is Authorized by Law If the criteria established in 10 CFR 50.12(a) are satisfied, as they are in this case, and if no prohibition of law exists to preclude the activities which would be authorized by the requested exemption, and there is no such prohibition, then the Commission is authorized by law to grant this exemption request.

I

2. The Requested Exemption Does Not Present an Undue Risk to the Public '!

Health and Safety As stated in 10 CFR 50, Appendix J, the purpose of the primary containment leak rate testing requirements is to ensure that leakage rates are maintained within the Technical Specification requirements and to assure that proper maintenance and repair is performed throughout the service life of the containment boundary components. The requested j exemption is consistent with this intent in that it represent a one time  !

only schedular extension of short duration (60 days). During this short duration, only 4 days will be at power operation for 11 STs that will exceed the 24 month interval. Twenty-seve- STswill exceed the 24 month ,

interval while in the Cold Shutdown condition. The required leak tests  !

1 Page 3 will still be performed to assess compliance with Technical Specification requirements and to assure that any required maintenance or repair is performed. Extending the 2 year interval by a short duration will not significantly impact the integrity of the containment boundary and, therefore, will not significantly impact the consequences of an accident or transient in the unlikely event of such an occurrence during the 4 days of power operation. For the 27 STs which exceed the 24 month testing interval during Cold Shutdown, the need for primary containment is not required, thus, reducing the safety consequences of this extens'on.

3. The Requested Exemption Will Not Endanger the Common Defense and Security Containment penetration leak rate testing is not considered in the common defense and security of the nation. Therefore, this exemption will not impact the common defense and security.

4. Special Circumstances are Present 10 CFR 50.12(a)(2) indicates that special circumstances include conditions under which compliance would result in hardship or other costs that are significantly in excess of those contemplated when the regulation was adoptedj When the regulation was adopted, a presumption was made that a two y4ar test interval would easily accommodate perfonnance of these/ tests during an operating cycle. However, the development of new ore designs have resulted in fuel cycles of 24 months, or longer en there are unplanned outages during the cycle.

Performance of th e tests at the scheduled 24 month frequency would result in undue financial hardship resulting from an extended shutdown of the reactor beyond that intended by the regulation with little or no compensatory irfrease in the level of safety or quality. The refore ,.

special circuns'tances are present.

ENVIRONMENTAL IMPA T This schedular esemption would not result in the modification of any plant structures, systems or components. Neither would it result in a change in the /

way plant systdms are operated. The requested exemption involves ar, administrativply controlled surveillance test program and does not represent l any increase #in the maximum allowable routine or postulated post-accident l releases or radioactive material to the environment or occupational exposures.

Therefore, the ewironment would not be adversely impacted.

SCHEDULE i PECo requests that this exemption be granted no later than August 15, 1993.

1 l

- - = .

l

-E s i

3 t

i >

E

-i

1 i

2 Pue I satqui 2 IN3WH3V11V

'f

- - TABLE 1 ]

3R09 SURVEILLANCE TESTS - EXPIRE BEFORE 9/18 Page' 1 3 SORTED BY LAST PERFORMANCE DATE DESCRIPTION EXPIRATION ,

LAST PERFORMED DATE PENETRATION  ;

ST NO, AND VALVE NUMBERS

- 30.16.01 "A" INST 10 0/W 09/15/91 09/14/93 N-22 A0 3969A CHK33202A

-30.368.01 D/W BREATHING AIR 09/15/91 09/14/93 N-102B,0 HV E5476 HV E5007 30.01A.01 MSly 09/17/91 09/16/93 N-7C  ;

A0 BOC A0 B6C 30.03.01 09/17/91 09/16/93 N-38 CV 32A CV 32B CV 35A CV 358 CV 33 CV 36 30.10.08 TDRUS C00LlhG & SPRAY 09/17/91 09/16/93 N-210A, 211A ,

MD 348 MO 388 MO 39B 30.10.D9 TORUS COOLING & SPRAY 09/17/91 09/16/93 N-210A, 211A MO 34B MO 388 ,

30.10.12 09/17/91 09/16/93 N-39A MO TiB i

30.01A.03 MAIN STEAM DRAIN 09/18/91 09/17/93 N-8  ;

MO 74 MO 77 30.01J.01 09/18/91 09/17/93 N AD 316 AD 317 30.02E.01 09/18/91 09/17/93 N-41 AD 39 A0 40 30.07A.10 D/W HEAD ACESS D9/18/91 09/17/93 N-4

'rotal 11 J

9

- - TABLE 2 3R09 SURVEILLANCE TESTS - EXP!RE 9/18 OR LATER Page 1 SORTED BY LAST PERFORMANCE DATE DESCRIPTION EXPIRATION ,

ST Nn. AND VALVE NUMBERS LAST PERFORMED DATE PENETRATION 30.07A.11 RPV STABILI2ER MANWAYS 09/19/91 09/18/93 N-110A-H 30.078.13 D/W PURCE SUPPLY 09/19/91 09/18/93 N-25 '

A0 3505 AD 3519 A0 3520 AD 3521A AD 35218 30.078.14 "0" RINGS 09/19/91 09/18/93 N-25 A0 3519 A0 3505 A0 3520 30.078.15 "0" RINGS 09/19/91 09/18/93 N-2058 A0 3521A A0 3521B 30.10.13 09/19/91 09/18/93 N-13A MO 25B AD 46B A0163B 30.13.08 RCIC VAC RELF 2"1300 09/19/91 09/18/93 N-217B MO 5244 30.61.01 TOPUS LEVEL INDICAT 09/19/91 09/18/93 'N-206A,8 30.10.14 NEAD SPRAY BLANK FLANCE 09/20/91 09/19/93 N-17 MO 32 MO 33 30.13.02 RCIC SUCTION 09/20/91 09/19/93 N-225 MO-13-39 MD-13-41 30.16.03 B INST N2 TO DW & TRS VAC BKR 09/20/91 09/19/93 N-218A 30.20A.01 D/W FLCOR DRAIN SUMP 09/20/91 09/19/93 N-18 A0 82 SO 83 30.35.01 RBCCW D/W ISOL 09/20/91 09/19/93 N-23, 24 MO 2374 i

30.35,01 RacCW D/W ISOL 09/20/91 09/19/93 N-23, 24 MG 2373 I

30.36A.01 D/W SERV AIR MAN VLVS 09/20/91 09/19/93 N 21 HV 30165 HV 30163 30.14A.01 TORUS WiTER CU 09/21/91 09/20/93 N-225 MO 71 MO 70 30.20B.01 D/W FLOOR DRAIN SUMP 09/21/91 09/20/93 N-19 i A0 94 A0 95 30.23.02 09/21/91 09/20/93 N-227 MD 23-57 Mo 23-58 30.23.05 HPCI STOP CHK "0" RING CHK-12 09/21/91 09/20/93 N-214

?

30.07A.20 EXPANSION JOINTS c 09/~5/91 09/21/93 N-11, 12, 13A, 14, 16A,17 )

i:n -

_ l 30.07A.19 EXPAWSION J0!NTS 09/24/91 09/23/93 N-7A-D, 9A, 98 l l

l

i TABLE 2 (Continued) 3R09 $URVEILLANCE TESTS + EXPIRE 9/18 OR LATER Page 2 SORIED BY LAST PERFORMANCE DATE l DESCRIPTION EXPIRATION AND VALVE NUMBERS LAST PERFORMED DATE PENETRATION ST Wo.

30.06.03 09/26/91 09/25/93 N-98 MO 298 6-28B 09/27/91 09/26/93 N 9A 30.06.01 '

MO 29A 6-28A 09/27/91 09/26/93 N-9A 30.06.02 MO 29A 6-96A MO 38A MO 2319 30.06.04 09/27/91 09/26/93 N 98 HO-298 6-288 MO-3BB MO 1321 MO 1268 30.10.11 CONT. SPRAT 10/05/91 10/04/93 N-39A e

No 268 MO 31B 30.14.02 10/11/91 10/10/93 N-16A HV-14-14 CHK-14138 A014-15B MO-14-128 i

30.10.01- 5/D COOLING 10/27/91 10/26/93 N-12 MO 10-17 MO 10-18 Totet 27 7

-