ML20082Q538
| ML20082Q538 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 04/17/1995 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9504280243 | |
| Download: ML20082Q538 (4) | |
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PECO ENERGY-is.f=,t*.g.,,,,,
965 Chesteocok Boulevard Wayne, PA 19087-5691-April 17,1995 Docket Nos. 50-277 50-278 -
License Nos. DPR-44 DPR-56 L.
U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington,DC 20555
Subject:
Peach Bottom Atomic Power Station, Units 2 and 3 "eepoiiseto Additionalinformation RegardingRevision2 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 4 a revised 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. This revised relief request is our responseto your request for additionalinformation dated March 13,1995 concerning our submittal of February 15,1995 on this subject. This response was discussedin our conference call of March 27,1995 between PECO Energy Company and your staff. As also discussedin our call of March 27,1995, we are removing our request to test the Excess Flow Check Valves (EFCV) at power during conditions -
that would not involve a system outage.
This revised revision to GVRR-2 requests that EFCV testing be performed during system outages or refueling outages on a frequency of once per operating 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 to perform the EFCV testing. It is not our intent to remove systems from service exclusively to perform EFCV testing.
As requested, the reliet request has been revised to indicate the applicabee systems. It would not be prudent, however, to indicate which valves will be tested during refueling outages and which valves will be tested during system outages as this division is subject to change Scheduling of EFCV testing, as is the case w'th all the surveellance tests at PBAPS, is controlled through the use of computer-based systems which automatically update test schedule dates based on the last performed test date. These systems will ensure that EFCV testing is '
performed at the required refueling outage frequency.
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April 17,1995
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Page2' 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 practice and NRC guidance, and has been recognized as an effective method of controlling the impact of plant activities on safety. These controls are also an effective way of assessingthe impact 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 independentof these constraints is both practical and Prudent.
We are requestingthat this revision to GVRR-2 be approved by June 1,1995.
If you have any questions, please contact us.
Very truly yours, t
G. A. Hunger, Jr.
Director - Licensing Enclosures l
cc:
T. T. Martin, Administrator, Region I, USNRC W. L Schmidt, USNRC Senior Resident inspector, PBAPS 3
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RELIEF REQUEST NO. GVRR-2, REVISION 2 l
Valves:
Excess Flow Check Valves (EFCVs)
HPCI System Reactor & Recirculation System RCIC System Core Spray System RWCU System i
Residual Heat Removal System Category:
A, C Testing Requirement (s):
Exercise quarterly 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 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 by the spring. Any sudden increase in flow through the valve (i.e. line i
break) will result in a differential pressure across the valve which
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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 through 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 outage or a controlled system outage l
may cause a spurious signal which could result in a plant trip, i
an inadvertent initiation of a safety system, loss of decay heat removal, and/or the defeating of safety interlocks.
j Testing of the EFCVs can be performed during a scheduled system outage when appropriate plant administrative procedures and controls are ut!Ilzed to ensure plant safety.
Although system outages are per'ormed in order to enhance system performance, system outages are scheduled on a less than quarterly frequency (typically once an operating cycle) in order to maintain system availability. Testing the valves on a quarterly basis during forced system outages nould result in reduced system availability and result in increased risk to the plant. Therefore, quarterly testing of the EFCVs impractical.
In addition to plant safety concerns re ulting from performing EFCV tests on a quarterly basis during plant operation without an appropriate system outage, personnel safety concems must be considered since the process side of these valves is normally high pressure (>500 psig) and/or high temperature (>200oF) and highly contaminated reactor coolant.
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i in summary, plant and personnel safety concems render the testing of these valves on a quarterly basis to be impractical.
Exercise testing will be performed during a refueling or system
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outage, on a refueling outage frequency, when appropriate plant administrative controis are in place to prevent inadvertent safety -
system initiation and ensure plant safety. Those valves selected J
to be tested will have appropriate measures in place for personnel and plant safety and to maintain personnel exposure -
in accordance with ALARA guidelines.
Alternate Testing:
Functional testing will be performed on a refueling outage -
frequency during a refueling outage or system outage when i
appropriate plant administrative controls are in place. '
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