ML20083C145
| ML20083C145 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 04/25/1995 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20083C122 | List: |
| References | |
| NUDOCS 9505150138 | |
| Download: ML20083C145 (8) | |
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UNITED STATES
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'S NUCLEAR REGULATORY COMMISSION 5
i WASHINGTON, D.C. 20066 4 001
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING l
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AN EXEMPTION FROM 10 CFR PART 50. APPENDIX J REQUIREMENTS FOR
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CONTAINMENT LEAK RATE TESTING PECO ENERGY COMPANY
.i PUBLIC SERVICE ELECTRIC AND GAS COMPANY j
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DELMARVA POWER AND LIGHT COMPANY ATLANTIC CITY ELECTRIC COMPANY PEACH BOTTOM ATOMIC POWER STATION. UNIT 3
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DOCKET N0. 50-278
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l.0 INTRODUCTION j
By letter dated February 22, 1995, PECO Energy Company (PEco, the licensee) requested a one-time schedular exemption from the requirements of 10 CFR Part 50, Appendix J, Sections III.D.2(a) and III.D.3. The schedular exemption would extend the interval for Type B and C local leak rate tests (LLRT) for certain Peach Botton Atomic Power. Station, Unit 3 (Unit 3) containment penetrations for 60 days beyond the requirements of 10 CFR Part 50, Appendix J.
The affected penetrations and valves or boundaries are listed in Table 1 and Table 2.
Appendix J requires that these tests be performed at every refueling outage, but with the interval not to exceed 2 years.
PEco performed LLRTs on the affected penetrations between August 10, 1993 and November 5, 1993 just prior to and during' refueling outage 3R09. The Peach Bottom Atomic Power Station units are currently operating on a 24-month refueling outage schedule; the next Unit 3 refueling outage, 3R10, is scheduled to commence no later than September 30, 1995.
The licensee divided the affected penetrations into two groups: 1) those that require shutdown reactor conditions but come due prior to the scheduled commencement of 3R10 on September 30,1995 (see attached Table 1), and 2) those that require reactor shutdown conditions and come due after the scheduled commencement of 3R10 (see attached Table 2). The licensee presented information to justify an LLRT extension for theses two groups. The staff's evaluation of the licensee's justification is provided below.
9505150138 950425 PDR ADOCK 05000278 P
. 2.0 EVALUATION 2.1 Need For Extendina lhe Test Interval By 60 Days The licensee has stated that those components in Table 1 cannot be tested at power for two reasons. Many of the Table 1 penetrations require access to the drywell in order to conduct the tests. The drywell is inaccessible during power operations.
Certain penetrations of those listed in Table 1 require safety systems to be isolated which is unadvisable during power operation.
Therefore, a shutdown would be required in order to completely test all of the affected penetrations.
The licensee presented a description of the special circumstances that would result in hardship or other costs significantly in excess of those contemplated when Appendix J was adopted. The licensee has adopted improved technology reactor fuel which allows operation on a 24-month operating cycle.
Performance of the affected penetration leak tests within the strict 24-month requirements of Appendix J would require an extended or early plant shutdown.
j Granting of the exemption would allow operation for the 49 remaining days in the planned operating cycle.
In addition, the requested 60-day exemption would allow flexibility when scheduling the performance of the affected LLRT (both Table 1 and Table 2 penetrations) during the outage.
PEco stated that little or no safety benefit would result from an early extended shutdown for the purpose of performing the affected LLRTs.
2.2 Leak Rate Test Performance History The licensee presented information in support of their request for a 60-day extension of the Type B and C test intervals. The maximum allowable leakage rate for maintaining primary containment (L - minimum pathway leakage) is 125,417 cc/ min for Unit 3.
Theas-foundtotalTypeBandCminimumpathway leakage rate observed during Unit 3 refueling outage 3R09 during the fall of 1993 was 33,434 cc/ min. The as-left leak rate for that same outage was 27,188 cc/ min. The licensee stated that an extension of the leak test interval to allow for 49 days of operation is not likely to decrease the margin between as-found leak rates and L,.
OEco also stated that the remainder of the total 60-day extension, requested for outage planning flexibility, will have minimal safety significance since the unit will be in cold shutdown.
Primary containment integrity is not required during cold shutdown.
The staff reviewed the leak rate information presented by the licensee and concurs that an additional 49 days of operation at power will not significantly decrease the margin between the expected as-found leak rates and the maximum allowable total leak rate L The balance of the requested 60-day exemption provides reasonable flexibilily. for test planning under conditions in which primary containment integrity will not be required.
. 2.3 Intent of Anoendix J The staff notes that the 2-year interval requirement for Type 8 and C components is intended to be often enough to prevent significant deterioration from occurring and long enough to permit the tests to be performed during plant outages.
Leak rate testing of the penetrations during plant shutdown is preferable because of the lower radiation exposures to the plant personnel.
Moreover, as noted before, some penetrations cannot be tested at power. For penetrations that cannot be tested during power operation, or for which testing at power is inadvisable as discussed above, the ir. crease in confidence in containment integrity following a successful test is not significant enough to justify a plant shutdown specifically to perform the tests so close to the end of the 2-year time period.
3.0 CONCLUSION
Based on the above evaluation, the staff finds that the requested temporary exemption, to allow the Type B and C tests intervals for those penetrations listed in Table 1 and Table 2 to be extended 60 days from their current expiration date, to be acceptable.
Principal Contributor:
J. Shea Date: April 25, 1995
l TABLE 1 LEAK TESTS EXPIRING PRIOR TO SEPTEMBER 30. 1995 EXPIRATION OF PENETRATION
-CURRENT LEAK NUMBERS RATE TEST AFFECTED VALVE NUMBERS N-212 09/10/95 RCIC Stop Check 0-Ring N-21 09/21/95 DW Service Air N-102B 09/21/95 DW Breathing Air Iso Valve N-35 09/21/95 TIP Ball Valves N-150 09/16/95 Test Nozzle (N-150)
N-250 09/11/95 Test Nozzle (N-250)
N-200-A 09/19/95 Torus Manway 0-Rings N-2 09/16/95 DW Airlock 0-Rings N-35 A-G 09/13/95 TIP Penetration 0-Rings N-219 08/28/95 Torus Purge Exhaust 08/19/95 "A" CAD Analyzer Iso Valve N-25 09/18/95 DW Purge Supply; A0-3523 N-2058 09/19/95 Torus Vacuum Breaker "A" 09/11/95 3502A, 26A 0-Rings N-205A 08/27/95 Torus Vacuum Breaker "B" 08/27/95 35028, 26B 0-Rings N-26 09/15/95 A0-3506, 3507 0-Rings 08/28/95 Instrument N2 Compress Suction 08/12/95 "B" CAD Analyzer Iso Valve N-51C 08/15/95 "C" CAD Analyzer Iso Valve N-201A 09/19/95 3AS197 DW to Torus Exp N-201B 09/19/95 3AS197 DW to Torus Exp N-2010 09/03/95 3BS197 DW to Torus Exp
LEAK TESTS EXPIRING PRIOR TO SEPTEMBER 30. 1995 (Con't) r N-2010 09/03/95
.3BS197 DW to Torus Exp N-201E 09/25/95 3CS197 DW to Torus Exp N-201F 09/25/95 3CS197 DW to Torus Exp N-20lG 09/04/95 3DS197 DW to Torus Exp N-20lH 09/04/95 3DS197 DW to Torus Exp N-17 09/22/95 RPV Head Spray N-211B 09/29/95 "A" Torus Cooling & Spray 09/22/95 "A" Torus Cool & Spray Packing N-398 09/22/95 "A" Containment Spray 09/22/95 "A" Containment Spray Packing N-13B 09/23/95 "A" RHR Pump Discharge N-225 09/23/95 RCIC Pump Suction I
09/24/95 Torus Water Cleanup N-212 09/24/95 RCIC Turbine Exhaust 10" Line 09/26/95 RCIC Turbine Exhaust 2" Line N-2178 09/24/95 RCIC Vacuum Relief Valve 09/23/95 HPCI Vacuum Relief Valve Packing 09/23/95 HPCI Vacuum Reilef Valve N-163 09/22/95 "A" Core Spray Loop N-102BC 09/23/95 "A" ADS Backup N2 Supply N-47 09/23/95 "B" ADS Backup N2 Supply N-227 09/22/95 HPCI Pump Suction N-214 09/23/95 HPCI Turbine Exhaust 09/23/95 HPCI Stop Check 0-Rings 09/23/95 HPCI Turbine Exhaust 2" Line
LEAK TESTS EXPIRING PRIOR TO SEPTEMBER 30. 1995'(Con't) ri SDV 09/26/95 Scram Discharge Volume
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N-9A 09/25/95 FW Check Valve 28A N-350 09/27/95 TIP Purge Supply j
N-110 A-H 09/23/95 RPV Stabilizer Manways-N-7 09/28/95 30S199 Expansion Joints N-9 09/28/95 305199 Expansion Joints l
N-ll 09/28/95 30S198 Expansion Joints N-12 09/28/95 305198 Expansion Joints N-13 09/29/95 30S200 Expansion Joints l
N-16 09/29/95 305200 Expansion Joints N-213A 09/04/95 Torus Drain 0-Ring N-2138 09/04/95 Torus Drain 0-Ring t
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TABLE 2 LEAK' TESTS EXPIRING ON-OR~AFTER SEPTEMBER 30. 1995-EXPIRATION OF PENETRATION CURRENT LEAK NLSSERS RATE TEST AFFECTED VALVE NUNBERS N-42 10/03/95 Standby Liquid Control N-16A 10/10/95 Core Spray "B" Loop.
N-22 09/30/95 "A" Inst N2 to D/W N-52F 10/01/95 "B" Inst N2 to D/W N-218A 10/03/95 Inst N2 to Torus /DW Vac N-18 10/03/95 DW Flor Drain Sump Disch N-19 10/01/95 DW Equip Drain Sump Disch N-11 10/08/95 HPCI Steam Supply N-206 10/07/95 Torus Level Instrument N-B 10/23/95 Main Steam Line Drain N-57 10/26/95 Main Steam Sample N-12.
10/18/95 Shutdown Cooling N-39A 10/22/95 "B" Containment Spray 10/15/95 "B" Cont. Spray Packing N-13A 10/16/95 "B" RHR Pump Discharge N-211A 10/24/95 "B" Torus cooling & Spray 10/15/95 "B" Torus Cool & Spray Packing N-14 10/28/95 RWCU Pump Suction N-10 10/25/95 RCIC Steam Supply N-23 10/17/95 RBCW DW Isolation N-24 10/17/95 RBCW DW Isolation e N-53 10/21/95 DW Chilled Water N-54 10/21/95 DW Chilled Water N-55 10/21/95 DW Chilled Water
l n-i TABLE 2'(cont.)
-l LEAK TESTS EXPIRING ON OR AFTER SEPTEMBER 30. 1995 l
N-56 10/21/95 DW Chilled Water N-9A-10/25/95 "A" FW Check Valve N-9B 10/28/95 "B" FW Check Valve l
10/26/95 FW Check Valve 288 DW Head 11/07/95 DW Head Seal N-2008 10/25/95 Torus Manway 0-Ring t
N-1 11/07/95 DW Equipment Access N-41 11/01/95 Recirculation Sample l
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