ML20082R982
| ML20082R982 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 12/09/1983 |
| From: | PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| Shared Package | |
| ML20082R978 | List: |
| References | |
| NUDOCS 8312130377 | |
| Download: ML20082R982 (12) | |
Text
..d BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION i
In the Matter of Docket Nos. 50-277 PHILADELPHIA ELECTRIC COMPANY 50-278 APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSES DPR-44 AND EXEMPTION TO PART 50, APPENDIX J OF THE COMMISSION's REGULATIONS Edward G.
Baue r, Jr.
Eugene J. Bradley 2301 Market Street Philadelphia, Pennsylvania 19101 Attorneys for Philadelphia Electric Company 8312130377 831209 PDR ADOCK 05000277 P
PDR r
BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of Docket Nos. 50-277 PHILADELPHIA ELECTRIC COMPANY APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSES DPR-44 AND EXEMPTION TO PART 50, APPENDIX J OF THE COMMISSION's REGULATIONS Philadelphia Electric Company, Licensee under Facility Operating License DPR 44 for Peach Bottom Unit 2, hereby requests that the Technical Specifications contained in Appendix A of the Operating Licenses be temporarily amended to provide an extension of approximately two months to the local leak rate test interval for primary containment isolation valves.
Additionally, 1
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Philadelphia Electric Company requests, pursuant to Section 50.12 of the Commission's Regulations, an exemption from the requirements of 10 CFR 50, Appendix J, Section III.D.3 to provide an extension of approximately two months to the local leak rate test interval for primary containment isolation valves.
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Technical Specifications 4.7.A.2.f (page 168), and notes 5 and 6 to Tables 3.7.2 through 3.7.4 (page 188) require local leak rate tests on primary containment isolation valves to be performed each operating cycle, but in no case at intervals greater than 2 years.
The Commission's Regulations (10 CFR 50, Appendix J, Section III.D.3 ) requires local leak test to be performed during each reactor shutdown for refueling, but in no case at intervals greater than 2 years The end of the current two-year test interval for Peach Bottom Unit 2 containment isolation valves is approaching.
The first tests requiring the plant to be in the shutdown mode must be performed on or before February 20, 1984 (two calendar years since last test).
The due dates for other isolation valves occur during the two months following this date.
The valves requiring a plant outage to accommodate a local leak rate test, for which an extension in the two year interval is being requested, are the Main Steam Isolation Valves and Feedwater Isolation Valves.
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T' e next refueling outage on Unit 2 was originally scheduled for the Fall, 1983.
Following the shutdown of Unit 2 last summer to accommodate the inspection and repair of primary coolant piping, the start of the refueling outage was rescheduled for February 4, 1984.
Due to unforseen delays resulting from the inspection and repair of IGSCC cracks on primary coolant piping, the Unit 2 startup was delayed until December 3, 1983.
Consequently, the current schedule for the start of the refueling outage may be as late as March 31, 1984.
The current schedule is based on operation of Unit 2 with a projected unit capacity factor to reach the minimum reactor core burnup assumed in the safety evaluation to be submitted with a License Amendment Application to accommodate the next Unit 2 refueling.
To meet the test f requency required by the Technical Specifications and Commission's Regulations would require a plant shutdown prior to February 20, 1984, to accommodate the local leak rate tests.
Estimated duration of the outage required to perform the tests is ten to fourteen days.
Following this outage to accommodate the isolation valve leak rate tests, a return to power would be necessary to complete the current operating cycle core burnup.
After this power run, it would be necessary to shut i
down Unit 2 again for a scheduled thirty-two week outage for refueling and to replace or repair portions of the recirculation 1
system piping.
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e The plant outage schedule described above would result in an overall increase in outage time.
An additional outage of
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two weeks would impose an economic penalty of approximately eleven million dollars to area customers and subject plant equipment and systems to the detrimental effects inherent in an b
additional ohutdown and startup operation.
1 Initiating the refueling and pipe replacement or repair outage on February 20, 1984, would preclude loading of the 292 new f uel assemblies designed and f abricated for installation during the next Unit 2 refueling outage.
Licensing considerations for use of these new fuel assemblies anticipated operating the current fuel cycle to depletion of reactivity and attaining an exposure which is within a licensing basis core exposure window corresponding to 8606 to 9206 MWD /t prior to refueling.
The current incremental core exposure is 6591 MWD /t; therefore, additional core exposure is needed to permit use of the above new f uel assemblies and to assure that the current existing fuel capability is fully utilized.
The core exposure window was chosen to take into account normal operational uncertainties prior to refueling.
- However, due to the unanticipated length of the pipe inspection and repair outage, the licensing basis exposures of 8606'and 9206 MWD /t correspond to operation to about March 16 and April 16, 1984, respectively, prior to refueling.
Therefore, it is requested 4
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that operations be permitted to continue on Unit 2 to attain a core exposure within the licensing bases core exposure window.
Additionally, an outage commencing on February 20, 1984, may jeopardize plans to replace the recirculation system piping during that outage or increase the length of outaga required to perform the work.
An early outage starting date does not provide adequate preparation time for the engineering, training of crafts, and development of procedures associated with a major pipe replacement program, considering that the planning and engineering for this program was only initiated a few months ago following the initial detection of pipe cracks.
Radiation exposures during the refueling / modification outage will be considerable, and additional timo to implement an effective ALARA program for this major modification is essential to minimize total accumulated personnel exposure.
Consequently, to permit a plant shutdcwn for refueling, pipe replacement or repair, and containment isolation valve testing, Licensee hereby requests an extension of the local leak rate test interval from February 20, 1984, to April 21, 1984.
Additionally, Licensee hereby requests that the next surveillance interval for the Unit 2 local leak rate tests commence at the start of the next operating cycle.
The latter request is necessary to compensate for the extended refueling / modification outage on Unit 2 in 1984 which will defer the next refueling outage until the Spring of 1986.
The change would permit subsequent local leak rate testing within the two-year interval.
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Safety Hazards Consideration Determination i
The Commission has provided guidance concerning the 4-application of standards in 10 CFR 50.92 for determining whether license amendments. involve significant hazards consideration by j
providing certain examples which were published in Federal Register on April 6, 1983 (48 FR 14870).
One of the examples F
(vi) of an action involving no significant hazards consideration i
is a change which may in some way reduce a safety margin, but where the results of the change are clearly within all acceptable
.cri teri a'.
The requested change fits this example.
Postponing i
the aforementioned local leak rate tests until a refueling outage commencing on or before April 21, 1984, would allow for uninterrupted operation of the plant and would have little or no effect on containment integrity for the following reasons.
(1)
The primary containment isolation valves are designed to provide redundant isolation barriers; that is, two l
isolation valves in series.
Consequently, a reduction in the effectiveness of one seal would not compromise containment integrity.
Deterioration in the overall 4
integrity of the containment penetrations is normally a gradual process.
Considering the redundancy of the isolation barriers and the short duration of the requested extension of the test interval, the reduction 6
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in containmsnt integrity during the two-month extension period would be negligible, (2)
Local leak rate tests (type C tests) are required to be performed during each reactor shutdown for refueling, t
with a calendar lim!.t of two years, by paragraph 4.7.A.2.f (page 168) of the Peach Bottom Technical Specifications, and Section III.D.3 of Appendix J to 10 CFR 50.
This would subject the MSIV and the feedwater isolation valves to full power rated temperature conditions approximately 16 months between type C testing, based on an 18-month fuel cycle and 2-month ref ueling outage.
As a result of the extended refueling outage in the Spring of 1982, and the current five-month 4
long pipe repair outage, these valves have been subjected to full power temperatures for only approximately 12 months.
Consequently, the valves have been subjected to operating conditions less severe than that recognized by the test schedule identified in the regulations.
A two-month extension in the type C test interval does not appear to be inconsistent with the intent of the test schedule specified by the Technical I'
Specifications and Appendix J.
i (3)
The feedwater isolation valves for which relief is requested are asociated with systems that provide 7
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additional barriers to an off-site release and therefore mitigate the consequences of an accident.
Leakage through the feedwater valves would be' inhibited by the water seal effect of the feedwater system.
4 For these reasons, the proposed amendment to the Peach Bottom Operating License does not involve a significant hazards consideration, since it would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated, or (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety.
The Commission's Regulations, 10 CFR 50.91(a)(5),
permits approval of a license amendment involving no significant hazards consideration without prior notice and opportunity for a hearing or for public comment, provided an emergency situation exists, in that failure to act in a timely manner would result in i
j derating or shutdown of the Unit.
The current situation at Peach Bottom Unit 2 satisfies the Commission's definition of an emergency situation, as described in paragraph 50.91; i
consequently, we request that the staf f dispense with prior public notice and comment in the processing of this amendment application.
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Pursuant to 10 4.'.FR Section 170. 22, " Schedule of Fees for Facility License Amendments", Philadelphia Electric proposes that l
this Application for Amendment be considered a Class III Amendment, since the proposed change involves a single safety issue and is deemed not to' involve a significant hazards consideration.
Plant Operation and Review Committee and the Operation and Safety Review Committee (Nuclear Review Board) have reviewed this proposed change to the Technical Specifications and exemption request and have concluded that it does not involve an unroviewed safety question or a significant hazards consideration and will not endanger the health and safety of the public.
Respectfully submitted, PHILADELPHIA ELECTRIC COMPANY
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j Vice 'Presiddnt 9
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4 COMMONWEALTH OF PENNSYLVANIA ss.
COUNTY OF PHILADELPHIA S. L. Daltroff, being first duly sworn, deposes and says:
That he is Vice President of Philadelphia Electric Company, th'e Applicant herein; that he has read the foregoing Amendment to Application for Amendment of Facility Operating Licenses 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.
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-Subscribed and sworn to before me this day of I$$0 Notary Public
' ' PATRICIA D. SCHOLt.
Notary Publc, Philadelphia, Philadc!phia Co.
My Commission Expires f ebruary 10,1986 W
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CERTIFICATE OF SERVICE-I' certify that service'of the foregoing Application was made
. upon the. Commonwealth of Pennsylvania, by. mailing a copy thereof, via first-class mail, to. Thomas R. Gerusky, Director, Bureau of Radiological Protection,
.P.O. Box 2063,:Harrisburg,-Pennsylvania,-i7120; all this 9th' day of December, L1983.
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Eug6ne J'. Bradley
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Attorney for Philadelphia Electric Company 4
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