ML20082C036
| ML20082C036 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 03/30/1995 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20082C040 | List: |
| References | |
| NUDOCS 9504060135 | |
| Download: ML20082C036 (7) | |
Text
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Ctation Support Dsejastment w
V PECO ENERGY i !Jr g r a,-
965 Chesterbrook Boulevard Wayne.PA 19087 5691 March 30,1995 Docket No. 50-277 Ucense No. DPR,1 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555
SUBJECT:
Peach Bottom Atomic Power Station, Unit 2 Facility Operating Ucense Change Request 95-05
Dear Sir:
PECO Energy Company hereby submits Ucense Change Request 95-05, in accordance with 10 CFR 50.90, requesting a one-time change to Appendix A of the Peach Bottom Atomic Power Station, Unit 2 Facility Operating Ucense.
The proposed change revises Technical Specifications (TS) Section 4.7.D.1.b.(1) by adding a footnote to exempt the High Pressure Coolant Injection motor-operated valve MO-2-23-015 from quarterly stroke testing requirements until refueling outage 2RO11. Attachment 1 to this letter describes the proposed change and Attachment 2 contains the revised.TS pages.
If you have any questions concerning this submittal, please contact us.
Sincerely, 3.a.4og.
G. A. Hunger Jr.,
Director - Ucensing
Enclosures:
Affidavit, Attachments cc:
T. T. Martin, Administrator, Region I, USNRC W. L Schmidt, Senior Resident inspector, PBAPS, USNRC R. R. Janati, Commonwealth of Pennsylvania 95o4o6o135 95o33o
\\t PDR ADOCK 05ooo277 I
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l COMMONWEALTH OF PENNSYLVANIA
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COUNTY OF CHESTER -
- W. H. Smith, Ill, being first duly sworn, deposes and says:
That he is Vice President of PECO Energy Company; the applicant herein; that he has read the attached License Change Request (LCR 95-05) for changes to the Peach Bottom Facility Operating License DPR-44, and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.
' ' 'Vice President (/
Subscribed and sworn to before me this SO day of N 1995.
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Notary Public
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i ATTACHMENT 1 PEACH BOTTOM ATOMIC POWER STATION UNIT 2 Docket No. 50-277 Ucense No. DPR-44 Facility Operating License Change Request 95-05
" Deferral of Quartedy Stroke Testing -
for HPCI valve MO 2-23-015 Until 2RO11" Supporting Information for Changes 1
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PECO Energy Company (PECO Energy), Ucensee under Facility Operating License DPR-44 for the Peach Bottom Atomic Power Station (PBAPS), Unit 2 requests that the Technical Specifications (TS) contained in Appendix A to the Operating License be.
amended. The handwritten proposed change to page 177 is contained in Attachment
[
2.
The proposed change revises TS Section 4.7.D.1.b.(1) by adding a footnote to exempt 4
the High Pressure Coolant injection (HPCI) motor-operated valve MO-2-23-015 from quarterly stroke testing requirements until refueling outage 2RO11, which is scheduled i
for the Fall of 1996.
PECO Energy requests that the changes be approved and implemented by June 15, 1995, which is approximately when the next stroke test is scheduled to be performed.
Descriotion of Changes Ucensee proposes the following change:
Revise TS Section 4.7.D.1.b.(1), (page 177), by adding a footnote which states:
"HPCI MO-2-23-015 is exempted from quarterly testing requirements until 2RO11."
Discussion of Changes The proposed change will add a footnote to TS Section 4.7.D.1.b.(1) to indicate that HPCI valve MO-2-23-015 is exempted from the performance of TS required quarterly stroke testing. MO-2-23-015 is the normally open HPCI inboard steam isolation valve.
This exemption will be in effect until 2RO11, which is the next earliest scheduled opportunity that Unit 2 will be in a cold shutdown de-inerted condition.
Safety Discussion The proposed change revises the TS to allow for a one-time deferral of quarterly stroke testing requirement for HPCl MO 2-23-015. The proposed change is requested due to HPCI MO-2-23-015 being placed on its backseat as a result of a packing leak.
The change to the TS will be in effect until 2RO11. It was concluded that the valve will remain operable during this period, and therefore, capable of performing both its passive and active safety functions. This conclusion is based on the valve's past operating and maintenance history and the absence of any degradation resulting from a time-based failure mechanism. -- -
Through the use of fixed cameras mounted inside the drywell, it was observed that the packing on MO-2-23-015 had partially failed. Based on the observed leakage, the type of packing used in MO-2-23-015, and past operating experience, it is reasonable to l
conclude that further packing degradation would resuit if valve stroke testing were to continue. In order to minimize the potential for continued packing failure, the valve was remotely backseated. MO-2-23-015 is designed with a bonnet backseat that can be used to seal off the stuffing box from the valve cavity for performing packing maintenance under static pressure conditions.
MO-2-23-015, in its backseated position, is considered operable and capable of performing its intended safety function. The valve is a safety related component and has an active safety function to close for primary containment isolation and a passive safety function to remain open to support HPCI operation. The valve has an open active safety function to supply steam to the HPCI turbine. Unit operation with MO 23-015 in the backseated position does not adversely affect the valve's pressure boundary nor its ability to close. While positioning the valve in the backseated position does increase its stroke time, it has been calculated and demonstrated to close within the TS time limit of 20 seconds.
Draft NUREG-1482, " Guidelines for Inservice Testing at Nuclear Power Plants,"
Paragraph 3.1.1, " Deferring Valve Testing to Each Cold Shutdown or Refueling Outage," states, "The NRC issued guidance in letters to licensees in 1976 which include the following examples of valves that should be specifically excluded from exercising (cycling) tests during power operations:
(1)
All valves whose failure in a non-conservative position during the cycling test would cause a loss of system function. Valves in this category would typically include all non-redundant valves in lines such as a single discharge line from the refueling water storage tank or accumulator discharge lines in pressurized water reactors (PWRs) and the hiah oressure coolant inlection (HPCB turbine steam sucoly and the HPCI pump discharge in boiling-water reactors (BWRs)."
Draft NUREG-1482, Paragraph 3.1.1.3, "De-inerting Containment of Boiling Water 4
Reactors to Allow Cold Shutdown Testing," further states, "OM-10 and Section XI of the ASME Code allow the licensee to test certain valves located in the inerted containment during cold shutdown outages because it is not practical to test them during power operation. However, access to the valve may be required to perform the testing. The staff has determined that de-inerting the containment at each cold shutdown outage solely to perform this testing is impractical." Based on the above guidance, deferral of quarterly testing is being requested until 2RO11. The basis to defer quarterly testing of MO-2-23-015 until 2RO11 is consistent with the guidance provided in Draft NUREG-1482.
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Consistent with NUREG-1433, PECO Energy submitted LCR 93-16 to convert the PBAPS TS to the improved Technical Specifications (ITS). Section 5.5.6 of the ITS idehtifies the Inservice Testing Program (IST) as a program that shall be established, implemented, and maintained. NUREG-1433 provides guidance which allows for the current TS SR 4.7.D.1.(b) to be relocated to the IST program. Accordingly, this surveillance requirement will be relocated to the plant procedures implementing the requirements of the IST program. PECO Energy has revised its IST program to allow for testing of MO 2-13-015 during cold shutdown de-inerted containment conditions.
No Sionificant Hazards Consideration Licensee proposes that this application does not involve significant hazards consideration for the following reasons:
i)
The procosed change does not involve a sionificant increase in the orobabifttv or consecuences of an accident oreviousiv evaluated.
The proposed change does not serve as an initiator or contributor to any accidents previously evaluated. It does not decrease the effectiveness of equipment relied upon to mitigate previously evaluated accidents. A calculation was performed and it has been determined that leakage through the valve's packing will be within the allowabia limits of containment leakage (ly. While positioning the valve in the backseated position does increase its stroke time, it has been calculated and demonstrated that the valve will close within the TS time limit of 20 seconds.
Therefore, the proposed change does not involve a significant increase in the probability or consequence of an accident previously evaluated.
ii)
The orocosed change does not create the oossibifrty of a new or different kind of accident from any oreviousiv evaluated.
The proposed change does not serve as an initiator or contribator to any of the accidents previously evaluated. The proposed change does not introduce any new modes of plant operation.
Implementation of the proposed changes will not affect the design function or configuration of any component or introduce any new operating scenarios or failure modes or accident initiation. It does not impair or prevent safety systems from performing their safety function.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.
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The~ orooosed chanos does not involve a sionificant reduction in a maroin of safety.
q The proposed change does not serve as an initiator or cosibutor to any accidents evaluated in the SAR. It has no impact on any safety erdjA assumptions. Exempting the HPCI valve MO-2-23-015 from quarterly stroke testing until 2RO11 does not impact its reliability or affect its ability to perform its intended sa'ety function. The change does not adversely affect the assumptions or sequence of events used in any accident analysis, Therefore, the proposed change does not involve a significant reduction in a -
margin of safety.
Environmerhlimoact Assessment An environmental impact assessment is not required for the change proposed by this application because the change conforms to the criteria for _" actions eligible for categorical exclusion" as specified t.110 CFR 50.22(c)(9).
The proposed change revises TS Section 4.7.D.1.b.(1) to provide for a one-time exemption of the quarterly stroke test requirement for HPCI valve MO-2-23-015 until 2RO11. This application involves no significant change in the types or significant increase in the amounts of any effluent that may be released off-site, and there will be no significar4 increase in individual or cumulative occupational radiation exposure.
Conclusion The Plant Operations Review Committee and the Nuclear Review Board have reviewed this proposed change and have concluded that it does not involve an unreviewed i
safety question and that it is not a threat to the health and safety of the public.
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