ML20078S160
| ML20078S160 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 02/15/1995 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9502240012 | |
| Download: ML20078S160 (3) | |
Text
Ststien Support Dspartment 10 CFR 50.55a T~
PECO ENERGY
=3Lt=L, bG5 Chutem + C et s 2 o Wayne. PA 190 ESC 91 February 15,1995 I
Docket Nos. 50-277 50-278 Ucense Nos. DPR-44 DPR-56 U. S. Nuclear Regulatory Commission Attn: Document Control Desk l
Washington, DC 20555
Subject:
Peach Bottom Atomic Power Station, Units 2 and 3 Revision 2 to Relief Request No. GVRR-2 of the Second Ten Year Interval of the Inservice Testing (IST) Program
Dear Sir:
Attached for your review and approval is Revision 2 to Relief Request No.
GVRR 2 for the Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3 Second Ten Year Interval inservice Testing (IST) Program. Previously approved Revision 1 to Relief Request No. GVRR-2 permitted the testing of Excess Flow Check Valves (EFCVs) during refueling outages in lieu of the code requirement of performing quarterly testing of EFCVs. This revision to GVRR-2 requssts that EFCV testing be performed during system outages and other appropriate opportunities during power operation, as well as refueling outages, and on a frequency of once per refueling cycle.
The test history of these valves has been reviewed, and PECO Energy believes this testing frequency of once per refueling cycle is appropriate; however, performing these tests exclusively during refueling outages has become burdensome. Therefore, PECO Energy would like to take advantage of scheduled system outages and other opportunities during power operation to perform the EFCV testing. It is our intent to minimize the removal of systems from service exclusively to perform EFCV testing.
PECO Energy has implemented extensive programmatic and procedural controls to ensure that the impact on plant safety is understood prior to removing equipment from service. This process is consistent with industry 7
practice and NRC guidance, and has been recognized as an effective method 95o224o012 95o215
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PDR ADOCK 0500o277 k
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Fcbruary 15,1995 Page 2 of controlling the impact of plant activities on safety. These controls are an effective way of removing activities from the refueling outage scope. During a refueling outage, the constraints on resources are at a premium, and the elimination of work that can be safely performed independent of these 4
constraints is both practical and prudent.
We are requesting that this revision to GVRR-2 be approved by April 1,1995.
1 This date will allow us to perform the EFCV testing of the Unit 3 High Pressure Coolant injection system during a scheduled system outage window currently scheduled to occur in early April,1995.
If you have any questions, please contact us.
Very truly yours, fo G. A. Hunger, Jr.
Director - Ucensing Enclosures cc:
T. T. Martin, Administrator, Region I, USNRC W. L. Schmidt, USNRC Senior Resident inspector, PBAPS 4
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i RELIEF REQUEST NO. OVRR-2, REVISION 2 l
j Valves:
Excess Flow Check Valves Category:
A, C Testing Requirement (s): Exercise quarterly g
Basis for Relief Excess flow check valves are installed on instrument lines penetrating containment to minimize leakage in the event of an instrument line failure outside the containment in accordance I
with Regulatory Guide 1.11.
The excess flow check valve is basically a spring loaded ball check valve. Since the system is normally in a static condition, the valve ball is held open i
by the spring.
Any sudden increase in flow thru the valve 1
(i.e.
line break) will result in a differential pressure across the valve which will overcome the spring and close the valve. Functional testing of valve closure is accomplished by venting the instrument side of the valve while the process side is under pressure and verifying the absence of leakage 4
thru the vent.
The testing described above would require the removal of the associated instrument or instruments from service on a quarterly basis. Removal of any of these instruments from service outside of a scheduled refueling, system outage, or i
during power operation without appropriate plant 3
administrative or procedural controls may cause a spurious signal which could result in a plant trip, an inadvertent initiation of a safety system, loss of decay heat removal 4
j and/or the defeating of safety interlocks.
In addition to plant safety concerns resulting from performing a
these tests on a quarterly basis, personnel safety concerns l must be considered since the process side of these valves is normally high pressure (>500 psig) and/or high temperature
(>2000F) and highly contaminated reactor coolant.
i In summary, plant and personnel safety concerns and plant operating conditions render the testing of these valves on a quarterly or cold shutdown frequency to be impractical.
Exercise testing will be performed during a refueling outage, j
system outage, or during power operation when appropriate i
plant administrative and procedural controls are in place to prevent inadvertent safety system initiation. Those valves y
selected to be exercise tested during a system outage, 4
refueling outage, or during power operation will have appropriate measures in place for personnel and plant safety and to maintain personnel exposure in accordance with ALARA guidelines.
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Alternate Testing Functional testing will be performed on a refueling outage cycle frequency during a refueling outage, system outage, or during power operation when appropriate plant administrative and procedural controls are in place.
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