ML20079A268

Requests Exemption from Two Yr Test Interval for Type B & C Leak Rate Tests Required by 10CFR50,App J,Sections III.D.2(a) & III.D.3 Per 10CFR50.12(a) & Forwards Documentation Justifying Exemption

ML20079A268
Person / Time
Site:	Peach Bottom
Issue date:	02/22/1995
From:	Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9502280362
Download: ML20079A268 (11)

Text

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PECO ENERGY lla"l12.:"L.

965 Chesterbrook Doulevard Wayne.PA 19087 5691 February 22,1995 Docket No. 50-278 License Nos.DPR-56

'l 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), PECO Energy Company (PECO Energy) requests exemption from the two year test interval ror Type B and C leak rate tests required by 10 CFR 50, Appendix J.

Sections Ill.D.2(a) and lilD.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 June 1,1995.

If you have any questions, please contact us.

Very truly yours,

. W 1.

G. A. Hunger, J Director Licensing Attachments cc: T. T. Martin, Administrator, Region 1. USNRC W. L Schmidt, USNRC Senior Resident inspector, PBAPS 9502290362 950222 \

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ATTACHMENT 1  !

Peach Bottom Atomic Power Statkx 'Jnit 3 1

Request for Exemption ,l l from 10 CFR 50, Appendix J  ;

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I Type B and C Interals 1 4

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PQge 1 REQUEST FOR EXEMPTION  !

DISCUSSION AND JUSTIFICATION Sections lil.D.2(a) and Ill.D.3 of 10 CFR 50, Appendix J, require that Type B and C containment i penetration leak rate tests be performed at intervals no greater than two years. Accordingly, PECO l Energy Company (PECO Energy) requests a one time exemption from these requirements for the j survegiance tests (STs) identified in Tables 1 and 2 of Attachment 2 for a period of 60 days. If granted, the 80 day extension wRI be applied to the current expiration date of each ST listed on Tables 1 and 2.

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 flexibuity in an operating cycle of 24  !

months Peach Bottom Atrmic Power Station, Unit 3 is now utgizing a core design which allows the i intervals between reactor shutdowns for refueling to extend beyond the maximum allowable two year l Interval. Local leak rate tests were originally p Lisced in conjunction with an operating cycle of 18 l months. Use of extended cycle core designs has been recevcued as a growing trend in the industry as discussed in Generic Letter 91-04,

• Changes in Technical Specification Surveillance intervals to -

Accc c ..cdete a 24-Month Fuel Cycle," dated AprR 2,1991.  ;

r Table 1 contains 52 STs from whice PECO Energy is reqcesting exemption. These 52 Type B and C STs are due to be tested prior to stubwn of PBAPS, Unit 3 for the upcoming Cycle 10 refueling outage scheduled to begin no later than S(ptember 30,1995. PECO Energy requests exemption for these tests l for a period of 60 days to avoid a premature reactor shutdown resulting from either isolation of j necessary safety systems, or the need to access the drywell to test penetrations that are inaccessible '

during plant operations, and to obtain scheduling flexibilty during the Cold Shutdown condition in which I the need for primary containment is not necessary. Performance of these tests at the scheduled 24 l month frequency would result in undue financial hardship with little or no compensating increase in the j level of safety or quality. 1 I

For the 52 STs which wRI become due whle the reactor is stRI at power, the earliest due date for any of these STs is August 12,1995. This represents a maximum interval of only 49 days from the date that the ST wBl become due to the date that the reactor wRI be in Cold Shutdown. Extending the testing interval

)i 60 days, of which only 49 days wRI be during power operation, wRl 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 49 days of power operation.

This minimal impact on primary containment integrity has been further reduced 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 33,434 cc/ min. and the as-left was 27,18R cc/ min. as calculated for the PBAPS, Unit 3 Cycle 9 refueling outage in the fan of 1993. This as-found and as-left leak rates represent a significant margin to the minimum pathway leakage, La, value of 125,417 cc/ min. for primary containment The extension of the 24 month testing interval for 4g days for the 52 STs listed in Table 1 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 28 STs for Type B and C tests which wiR currently become due on or after the shutdown of PBAPS, Unit 3 (September 30,1995). PECO Energy requests exemption for these tests for a period of 80 days in order to obtain scheduling flexibilty during the Cold Shutdown condition in which i the need for primary umtainment integrity is not required.

l The scheduling flexibRity gained with a 80 day extension for the tests listed in Tables 1 and 2 wul ensure l that performance of the STs wRI not impact critical path activities and result in an unnecessary increase i in the length of the outage. Extending the length of the outage would result in undue financial hardship 1 with little or no compensating increase in the level of safety or quality. )

- 3 Page 2 The survetlance tests associated with this exemption wil be completed prior to restart from the

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i upcoming PBAPS, Unt 3, Cycle _10 refueling outage.

10 CFR 50.12 allows the Commiselon 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 wHI not present an undue risk to the public health and safety; (3) the exemption is consistent with the common defense and securty; and (4) special circumstances, as defined in 10 CFR 50.12(a)(2), are present. Each of these criteria are discussed below.

1. The Raouested Exemotion is Authorized by Law if the crteria 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 actMties 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.

2. The Raouested Exemotion 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 exemption is consistent with this intent in that it represents a one time only schedular extension of short duration (60 -

days). During this short duration, only 49 days wRl be at power operation. During this 49 days at power operation,52 STs wBl exceed the 24 month interval. 28 STs wIl exceed the 24 month interval whle in the Cold Shutdown condition. The required leak tests wNI stil be performed to mana== compilance wth Technical Speculcation requirements and to assure than any required maintenance or repair is performed Extending the 2 year interval by a shost duration wIl not significantly impact the integrty of the containment boundary and, therefore, wHl not signllicantly impact the consequences of an accident or transient in the unlikely event of such an occurrence during the 49 days of power operation. For the 28 STs which exceed the 24 month testing hierval during Cold Shutdown, the need for primary containment is not required, thus, reducing the safety consequences of their extension.

3. The Rar=* Fwamr*lan WII Not Endanner the Common Defense and Aaemity Containment penetration leak rate testing is not considered in the common defense and security of the nation. Therefore, this exemption wil not impact the common defense and securty

4. Special Circumstances are Present 10 CFR 50.12(a)(2) indicates that special circumstances include conditions under which compliance would result in hardship cr other ccsts that are significantly in excess of those contemplated when the regulation was adopted. When the regulation was adopted, a presumption was made that a two year test interval would ensly accommodate performance of these tests during an operating cycle. Howswer, the development of new core designs have resulted in cycles of 24 months, or longer when there are unplanned outages during the cycle.

Performance of these 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 increase in the level of safety or quality. Therefore, special circumstances are present

.... . Page3 ENVIRONMENTAL IMPACT i This schedular exemption would not result in the modification of any plant structures, systems or {

components, Neither would it result in a change in the way plant systems are operated. The rary*

, exemption Ire.~h sn administratively controlled survetlance test program and does not represent any  ;

increase in tie medmum allowable routine or postulated post-accident releases, or radioactive material ,

to the environment, or occupational exposures. Therefore, the erwironment would not be adversely  :

impacted.  ;

i SCHEDULE  !

i PECO Energy requests that this exemption be granted no later than June 1,1995 in order to complete our planning for the p.4 outage l t

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ATTACHMENT 2 Tables 1 and 2

1 TABLE 1 1

3R10 SURVEILLANCE TEST - EXPIRE BEFORE 9/30 l

DESCRIPTION LAST EXPIRATION l ST NO. AND VALVE NUMBERS PERFORMED DATE PENETRATION  !

30.13.5 RCIC Stop Check O-Rings 09/08/93 09/10/95 N-212 30.36A.1 Drywell Service Air 09/19/93 09/21/95 N-21 30.368.1 D/W Breathing Air Iso Viv 09/19/93 09/21/95 N-1028  ;

30.60E.2 Tip Ball Valves 09/19/93 09/21/95 N-35 30.7A.22 Test Nozzle (N-150) 09/14/93 09/16/95 N-150 30.7A.23 Test Nozzle (N-250) 09/09/93 09/11/95 N-250 30.7A.4 Torus Manway O-Rings 09/17/93 09/19/95 N-200A 30.7A.7 D/W Airlock O-Rings 09/14/93 09/16/95 N-2 30.7A.9 Tip Penetrations O-Rings 09/11/93 09/13/95 N-35A-G l 30.78.12 Torus Purge Exhaust 08/26/93 08/28/95 N-219 30.78.16 D/W Purge Supply;AO-3523 09/16/93 09/18/95 N-25 30.78.3 Torus Vacuum Brkr 'A' 09/17/93 09/19/95 N-205B 30.7B.4 3502A & 26A O-Rings 09/09/93 09/11/95 N-205B 30.78.5 Torus Vacuum Brkr 'B' 08/25/93 08/27/95 N-205A 30.78.6 3502B & 268 O-Rings 08/25/93 08/27/95 N-205A 30.7B.8 AO-3506,3507 O-Rings 09/13/93 09/15/95 N-26 30.78.9 Inst N2 Compress Suction 08/26/93 08/28/95 N-26 30.7E.1 'A' CAD Analy Iso V!v 08/17/93 08/19/95 N-219 30.7E.2 'B' CAD Analy Iso Viv 08/10/93 08/12/95 N-26 30.7E.3 'C' CAD An% iso Ylv 08/13/93 08/15/95 N-51C 30.7A.15 3AS197 D/W to Torus Exp. 09/17/93 09/19/95 N-201 A, B 30.7A.16 30S197 D/W to Torus Exp. 09/01/93 09/03/95 N-2010, D 30.7A.17 3CS197 D/W to Torus Exp. 09/23/93 09/25/95 N-201E, F 30.7A.18 3DS197 D/W to Torus Exp. 09/02/93 09/04/95 N-201G, H

l TABLE 1 i 3R10 SURVEILLANCE TEST - EXPIRE BEFORE 9/30 DESCRIPTION LAST EXPIRATION ST NO. AND VALVE NUMBERS PERFORMED DATE PENETRATION 30.10.14 RPV Head Spray 09/20/93 09/22/95 N-17 30.10.2 'A' Torus Cooling & Spmy 09/27/93 09/29/95 N-211B l 1

30.10.3 'A' Torus Cool & Spray Pack 09/20/93 09/22/95 N-211B 30.10.5 'A' Containment Spray 09/20/93 09/22/95 N-398 30.10.6 'A' Containment Spray Pack 09/20/93 09/22/95 N-39B j 30.10.7 'A' RHR Pump Discharge 09/21/93 09/23/95 N-13B 30.13.2 RCIC Pump Suction 09/21/93 09/23/95 N 225 l 30.13.4 RClO Turb Exh 10' Line 09/22/93 09/24/95 N-212 l 30.13.6 RCIC Turb Exh 2' Line 09/24/93 09/26/95 N-212 30.13.8 RCIC Vacuum Relief Valve 09/22/93 09/24/95 N-217B 30.14.1 Core Spray 'A' Loop 09/20/93 09/22/95 N-168 30.14A.1 Torus Water Cleanup 09/22/93 09/24/95 N-225 30.16A.1 "A" ADS Backup N2 Supply 09/21/93 09/23/95 N-102BC 30.16A.2 "B" ADS Backup N2 Supply 09/21/93 09/23/95 N-47 1 30.23.10 HPCI Vac Relief Viv Pack 09/21/93 09/23/95 N-217B 30.23.2 HPCI Pump Suction 09/20/93 09/22/95 N-227

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30.23.4 HPCI Turbine Exhaust 09/21/93 09/23/95 N-214 30.23.5 HPCI Stop Check 0-Rings 09/21/93 09/23/95 N-214 1 30.23.6 HPCI Turbine Exh 2' Line 09/21/93 09/23/95 N-214 30.23.8 HPCI Vacuum Relief Valve 09/21/93 09/23/95 N-217B 30.3.1 Scram Disch Volume 09/24/93 09/26/95 SDV I 30.6.1 F/W Check Valve 28A 09/23/93 09/25/95 N-9A

TABLE 1 3R10 SURVEILLANCE TEST - EXPIRE BEFORE 9/30 l

DESCRIPTION LAST EXPlRATION ST NO. AND VALVE NUMBERS PERFORMED DATE PENETRATION 30.60E.1 TIP Purge Supply 09/25/93 09/27/95 N-35C j 30.7A.11 RFV Stabilizer Manways 09/21/93 09/23/95 N-110A-H i 30.7A.19 3OS199 Expansion Joints 09/26/93 09/28/95 N-7,9 l

30.7A.20 30S198 Expansion Joints 09/26/93 09/28/95 N-11.12 30.7A.21 3OS200 Expansion Joints 09/27/93 09/29/95 N-13,16 i

30.7A.8 Torus Drain C-Ring 09/02/93 09/04/95 N-213A&B l

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TABLE 2 3R10 SURVEILLANCE TEST - EXPIRE 9/30 OR LATER DESCRIPTION LAST EXPIRATION ST NO. AND VALVE NUMBERS PERFORMED DATE PENETRATION 30.11.2 Standby Liquid Control 10/01/93 10/03/95 N-42 30.14.2 Core Spray "B" Loop 10/08/93 10/10/95 N-16A N-22 I 30.16.1 'A' Instr N2 to D/W 09/28/93 09/30/95 30.16.2 'B' instr N2 to D/W 09/29/93 10/01/95 N-52F 30.16.3 Inst N2 to Torus /DW Vac 10/01/93 10/03/95 N-218A l 30.20A.1 D/W Floor Drn Sump Disch 10/01/93 10/03/95 N-18 '

30.208.1 D/W Equp Dm Sump Disch 09/30/93 10/01/95 N-19 30.23.1 HPCI Steam Supply 10/06/93 10/08/95 N-11 30.61.1 Torus Level Instrument 10/05/93 10/07/95 N-206 j Main Steam Line Drain N-8 j 30.1 A.3 10/21/93 10/23/95 30.1J.1 Main Steam Sample 10/24/93 10/26/95 N-57 30.10.1 S/D Cooling 10/16/93 10/18/95 N-12 30.10.11 'B' Cont. Spray 10/20/93 10/22/95 N-39A 30.10.12 'B' Cont. Spray Packing 10/13/93 10/15/95 N-39A 30.10.13 'B' RHR Pp Disch 10/14/93 10/16/95 N-13A 30.10.8 'B' Torus Og & Spray 10/22/93 10/24/95 N-211 A 30.10.9 'B' Torus Og & Spray 10/13/93 10/15/95 N-211 A Packing 30.12.1 RWCU Pump Suct 10/26/93 10/28/95 N-14 30.13.1 RCIC Steam Supply 10/23/93 10/25/95 N-10 ,

30.35.1 RBCW D/W lsol. 10/15/93 10/17/95 N-23, 24 30.44A.1 D/W Chilled Wtr 10/19/93 10/21/95 N-53,54,55,56 30.6.2 'A' F/W Check Viv 10/23/93 10/25/95 N-9A l

30.6.4 *B' F/W Check Viv 10/26/93 10/28/95 N-98

TABLE 2 3R10 SURVEILLANCE TEST - EXPIRE 9/30 OR LATER DESCRIPTION LAST EXPIRATION  ;

ST NO. AND VALVE NUMBERS PERFORMED DATE PENETRATION 30.7A.2 D/W Head Seal 11/5/93 11/7/95 DW Head 30.7A.5 Torus Manway 0-Ring 10/23/93 10/25/95 N-2008 30.7A.6 D/W Equip Access 11/5/93 11/7/95 N-1 30.2E.1 Recirc Sample 10/30/93 11/1/95 N41 30.6.3 F/W Check Valve 28B 10/24/93 10/26/95 N-9B P

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