ML20085M724
| ML20085M724 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 10/23/1991 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20085M721 | List: |
| References | |
| NUDOCS 9111120123 | |
| Download: ML20085M724 (7) | |
Text
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NUCLEAR REGULATORY COMMISSION sq WASHINGTON, D. C. 20555 s
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SAFETY EVALUATION BY ThE OFFICE OF NUCLEAR REACTOR RE_GULM 1,0h PELATED TO APENDMEtlT NOS. 164 AND 167 TO FACILITY OPERATING LICENSE N05. DPR 44 and DPR-56 PHILADELPHIA ELECTRIC COMPANY PUBLl[~$lhVltl'l[~EtThR AND~ BAS COMPANY DELMAfifA'PDklR~AT;D EEhT CDhPANY hTi_Ahtll T W illt,T[1 {CDEPANY PEACH BOTTOM ATOMIC POWER STATIOL UNIT N05. 2 AND 3 DOCKET N05._50,-277,,AND,,5,0,278 1.0 J NTR0puCTION As i W icated in 10 CFR Part 50, Appendix J, Section III, a program is to be developed for leak testing the primary containment and components penetrating the containr:ent boundary. On August 7, 1975, the staff raquested the licensee (Philadelphia Electric Company, et al.) to review its primary containment leak rate testing (PCLRT) program in order to determine the extent of compliance with the requirerents of Appendix J at Peach Bottom Atomic Power Station, Units 2 and 3.
By letter dated Septerber 12, 1975, the licensee submitted its evaluation of the Peach Bottom containment leakage testing program and idertified certain areas of the Technical Specifications (TS) which appeared to be inconsistent with the provisions of Appendix J but could not be changed
.tg achieve conforr.ity with Appendix 0 due to the unique design of the plant.
Subsequently, by letter dated November 18, 1976, the licensee submitted a proposed ar+ndment for Facility Operating License Nos. DPR-44 and DPR-56 to bring ccriain creas of the containment leakage testing program, as specified in Sections 3.7A and 4.7A of the TS, into conformance with the requirements of Apper. dix J and also requested that certain test methodology, components and penetrations be exempted from the requirements of Appendix J.
A revised prorosed arcendment was submitted by letter dated May 15, 1981. The staff and its contractor, the Fraklin Research Center (FRC), reviewed the licensee's PCLRT program and provided a safety evaluation to the licensee in a letter dated December 28, 1981.
In the safety evaluation, the staff concluded that certain areas of the PCLRT program needed to be inproved.
As a followup, the staff notified the licensee on September 12, 1983, that the PCLRT program should be revised to reflect the staff's December 28, 1981 safety evaluation.
Accordingly, by letter dated April 19, 1984, the licensee submitted proposed TS changes which reviscd the November 18, 1976 application. This request was noticed August 22,1984 (49 FR 33367). By letter dated October 10, 1986, the licensee submitted a revised proposed amendment which replaced all earlier proposed ar'endments and reflected discussions with the staff regarding the PCLRT program. This proposal completely supersedes all previous proposals.
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. The staff requested certain additional information by letter dated January 9, 1991 and the licensee provided this information and further revised the October 18, 1986 proposal by letter dated May 17, 1991.
In addition, by letters dated April 21, 1988 and June 23, 1988, the licensee requested certain exemptions from Appendix J for the PCLRT program. The staff responded to the exemptions requested by letter dated November 21, 1990, with the exception of one request which you withdrew by letter dated September 27, 1991. The staff has completed its review of the proposed technical specification changes and provides the following evaluation.
2M EVALUATION 2,.1 Primary _,C_ontainment Lea k Rate,Tes,t_ P,rog,r_am The licensee in itt letters dated October 10, 1986 and May 17, 1991, proposed the following TS changes for the PCLRT program:
2.1.1
,T), pagp,s, Jpp, an,d, Jp7,,pp,c,tipp,,4,,7, A.,2, " Integrated Leak Rate Testing" The licensee proposed to delete the statement "La is 0.5 percent" and add the definition for La in the TS, such that
- a = 0.5 percent of the primary contain-ment volume per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at 49.1 psig, and changed the formula for the maximum allowable test leakage rate from Lt = 0.5 (Ltm/ Lpm) to Lt = La (Ltm/ Lam). The l
licensee also proposed to define that Ltm/ Lam 2 0.7 in lieu of 1.0 in the current TS. The staff finds these changes in agreement with Appendix J,Section III.A.4(a)(1)(iii) and therefore, acceptable.
2.1.2 TS pages,1pp_ and_19_2, Section 4.7. A.2.e.
l The licensee removed references to leak testing methodology which are not required by the staff in Standard Technical Specifications. The staff finds l
this change acceptable.
l 2.1. 3 TS_page,169, Section_4.7.A.2.f The licensee proposed to revise this TS section to require local leak rate testing (LLRT, of primary containment isolation barriers in accordance with Tables 3.7.2, 3.7.3, and 3.7.4 of the TS.
The staff finds the proposed change acceptable since it clearly defines the valves and penetration barriera to be local leak rate tested.
TS Pace 184,, Table,3.7.2,,,"Testab,le__P_enetrations with Double 0-Ring Seals."
2.1.4 e
The licensee proposed to revise the nomenclature for penetration N-2 in Table 3.7.2 to correctly identify it as the " equipment access and personnel airlock" penetration, and to insert Note (7) to specify its test frequency.
The
, licensee also proposed to add to Table 3.7.2 six penetrations, which have potential leakage pathways in valve to pipe penetrations that contain testable 0-ring seals. The staff finds that the change would clearly define the air lock test requirement ar.d test frequency in accordance with Appendix J, and would provide needed additions to Table 3.7.2, and, therefore, is acceptable.
2.1.5 TS Page_184a,_ Table 3.7.3, " Testable Penetrations with Testable Bellows."
The licensee proposed to revise Table 3.7.3 to correct the nomenclature for penetration N-9B from "RPV Head Spray" to RHR Head Spray," and to revise the-nomenclature for the MSL and the RHR shutdown cooling.
The changes are only editorial in nature and are acceptable since they reflect the present plant nomenclature for the penetration.
2.1.6 TS Pages 185 thru 188, Table 3.7 A _"P, rima,ry, Con _ta,inment Test _ab,le Isola-
,t i o n_ V a l,v e s. "
The licensee proposed to replace Table 3.7.4 in its entirety with the revised Table 3.7.4 as shown on revised pages 185, 186, 187, 187a, 188, ar.d new pages
. 187b, 188a, 188b and 188c. The changes in Table 3.7.4 are evaluated as follows:
(1) The asterisk footnote on page 85 was revised to read " Effective isolation boundary for this penetration following the 8th refueling outage on Unit 3" for penetrations 16A and 16B. Also, penetrations 13A and 13B have been revised to reflect the removal of this footnote.
The staff finds the change reflects the present plant configuration as a result of irndifica-tions and is, therefore, acceptable.
- (2) tew testable isolation valves on penetrations 234 (Unit 2) and 234B Unit
- 3) were added as a result of the installation of a new post-accident sdmpling system (PASS). The change is merely_an addition as a result of plant modifications and is, therefore, acceptable.
(3) The valve number and reference notes in penetration 14 were revised to differentiate between the M0-12-15 valves on Units 2 and 3 since the MO-12-15 valve on Unit 2 is a gate valve, and the M0-12-15 valve on Unit 3 is a globe valve.
The change-is only editorial in nature, and is, therefore, acceptable.
(4) Penetration 35F and associated reference notes were added to identify check valve, SV-109, as a testable isolation valve. The check valve (SV-109) on the 1-inch nitrogen supply line to the TIP system was previously indicated as not capable of being tested because of the plant design. The staff finds that modifications were made which permit the valve to be-tested, and, therefore, the TS change is acceptable.
(5) Note 9 was revised to delete mention of testing in a conservative direction, which was merely explanatory. The matter of direction of testing direction for MSIV's was fully addressed in the Appendix J l
Exemption issued November 21, 1990. This change'in werding is consistent with that exemption and is accept 6ble, j
(6) Dote (10) was revised to permit the following gate valves to be tested in the reverse direction:
M0-2-74, M0-13-15, M0-23-15, M0-10-32 (Unit 2),
M0-10-31 A, B, M0-10-18, and M0-12-15 (Unit 2). Appendix J, Section 111.C.1 states the test pressure shall be applied in the same direction as when the valve would be required to perform its safety function, unless it can be shown that applying the test pressure in a different direction will yield equivalent or more conservative results. The licensee's basis for the requested exempt. n is that normal force o
between the seat and the disk generated by the stem force alone is greater than ten times the post-accident normal force induced by peak containment differential pressure, Pa (49.1 psi ), except for valves 3
MO-10-31A, B which is 7.97 times the post-accident normal force, therefore, it is unlikely that the 49.1 psig test pressure will lift the valve disk off its seat during the LLRT due to the magnitude of the thrust generated. The sealing capabilities are essentially equivalent regardless of the direction in which the test pressure is applied. This change is, therefore, acceptable.
(7) Note (11) was added to permit the following globe valves to be tested in the reverse direction: A0 '2-80A to D, A0-4240 (5240) A0-4247 (5247),
M0-10-38A,B,A0-10-34A,B,A0-20-82,MO-12-15(Unit 3},A0-20-94, A0-2509 (3509), A0-2-39, A0-2-316, and A0-2513 (3513). This note is conservative because testing pressure applied in the reverse direction on these valves yields conservative results since the force from test pressure is in the direction of lifting the plug off its seat.
Testing in the reverse direction is, therefore, acceptable.
(8) Lote (12) was added to permit the following butterfly valves to be tested in the reserve direction: A0-2520 (3520), A0-2511 (3511), A0-2502A
- -.(3502A), A0-2506 (3506), and A0-25218 (3521B). This note is acceptable since the valves are equipped with inflatable resillient seats which provide equival nt bi-directional sealing.
(9) Note (13) was added to permit the manual globe valves in the following penetrations to be tested in the reverse direction: N-32C, N-218C, and N320. These valves are oriented such that the leakage test pressure is applied in the reverse direction and tends to push the valve disk into the valve seat. The valve manufacturer stated that the test pressure applied either over or under the disk of the valve will yield equivalent leakage results. Testing in the reverse direction is, therefore, acceptable.
(10) Note (14) was added to read: " Gate valves utilized for containment isolation in both directions. Test performed only in one direction.
Valve normal force ratio is 17.9.
Leakage path is between separate torus penetrations only." -The note is referenced for valves, M0-4244, 4244A (Unit 2) ar.d 5244, 5244A (Unit 3) in penetraticn 217B for the high pressure coolant injection and reactor core isolation cooling pump turbine exhaust lines to the suppression pool. The licensee's basis for not testing in both directions is that normal force between the seat and the disk generated by the stem alone is greater than ten (10)-times the 4
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o post-accident force induced by peak containment differential pressure, pe (49.1 psig). There1cre, it is unlikely that the 49.1 psig test pressure wi'l lift the valve disk off its seat during the local leak rate test (LLRT). The sealing cepabilities are essentiaily equivalent regardless of the direction in which the test pressure is-applied. The staff, therefore, finds testing in only one direction acceptable, although the valves are used for conteinment isolation in both directions.
(11) IJote (15) was added and referenced for penetrations 217B, 221,)and 223 to indicate that the stop-chec! valves (13-9, 23-12, 23-13,13-10 serve only as block valves to allow testing of the outboard containment isolation valves. The staff has reviewed the system configuratis and the licensee's rationale for not considering these valves require testing, as presented in the licensee's subenittal dated May 17, 1991.
Fecause these are not relied upon to perform a containment isolation function and 3re therefore, not containment isolation valves, the staff finds this change ar<eptable.
(12) The licensee proposed to add a note which applies to n1ves F0-14-70, PC-23-58, and M0 13 a1. The valves are retained in Table 3.7.4 of " Primary Containment Testable isolation Valves " and the proposed footnote appears to present a rationale for not (' sting :.he valves. Appendh J does not require Type C testing of water sealev valves.
Also these valves are identified in T6ble 3.7.4 by footnote (9) which c:;b for testing by epplying pressure between the inboard and outboard valves, but the licensee's answer to question 17 in the licensee's submittal of May 17, 1991 speaks of deleting references to reverse testing. The staff finds the poposed change does not clearly e
itiditate whether or not the licensee intends to test these valves.
Because tM ptoposed change is ambiguous, the staff finds it to be unacceptable, (13) tiote (17) w a added to state that certain valves discharge below the minimum torus water level and will thus have a water seal after an accident.
Therefore, Type C testing of these valves is not required per Appendix 0 to 10 CFR Part 50, Section 111.C.3. The staff finds this change acceptable.
(14) tiote (18) was added to exclude Type C testing for the individual valves on the CRD bydraulic control units.
In the safety evaluation supporting the Appendix 0 Exemption for Peach Bottom Atomic Power Station, Units 2 and 3, dated tJovember P1,1990, the staff discussed the CRD hydraulic control units. The staft concluded that "these lines provide a continuous water seal and do not constitute a potential atmospheric leak pathway and Appendix J does not require Type C testing of the associated isolation valves."
s (15) Note (19) was added and referenced for penetrations 35A to E to indicate that the Transversing In-Core Probe (Tip) shear valves are not Type C tested.
In the.%ppendix J Exemption for Peach Bottom Atomic Power Station, Units 2 and 3, dated November 21, 1990 the staff excluded the T1P shear valves from 'ype C testing.
Thestafffindsnote(19) f acceptable.
(16)11cte[20]wasaddedtoperraittheexplosionvalves(XV-14A,E)in penetration 42 to be tested in the severse direction.
The licensee's justification for this position is thet the explosion valves have a bi-directional sealing device, are normally closed, and open only on a standby liquid contral system (SLCS) actuation. The staff agrees th't testing in the reverse direction wuuld provide equivalent results of that for a forward flow test.
Therefore, the staff finds note (20) acceptable.
(17) flote (21) was added and referenced for penetration flo.102B to indicate that two gatt valves on the breathing air system are to be tested in the reverse direction.
In the safety evaluation supporting the Appendix J E>erption for peach Bottom Atomic Power Station, Units 2 and 3, dated tiov er.ber 21, 1990, the staff discussed the breathing air system. The staff four.d thet " reverse direction testing is acceptable." Since it confotr s with Appendix 0, Section 111.C.1, the staff finds note -(21) acceptable.
(10) Lte (22) was added to indicate that the butterfly valves, A0-2402B and A0-3502B in penetration 20SA are to be tested in the reverse direction.
Since these valves provide equivalent bi-directional sealing, testing in the reverse direction will yield an equivalent test result to that for the forward direction, and, therefore, note (22) is ecceptabic.
2.1.7 Ty P, app,,1,97, and 192a Clarifying changes to Bases page.192 and 19?a were proposed.
Certain cf the proposed charges relate to an Ap;.endix J exemption request to exclude tiSIV
'rfastrec' ltelagt fror; inclusion in.be local leak rate test limit of 0.6 La.
This request v.as ender review by ths staff nd has..uce been withdrawn by the licensee by letter dated September 2/, 1991 The change may create confusien and is, therefore, denied.
In surriary, as described above, the staff finds th(
icensee's. proposed technical specification changes acceptable with respect to:
1.
Deletion of testing requirements for certain water
.aled valves which do not ceristitute a potential atmospheric leak pathway.
2.
Certain wording changes so that technical specifications are consistent with the Appendix J Exemption for Peach Bottum Atomic Power Station issued liovember 21, 1990.
3.
Certain proposed changes related to valve testing in the reverse direction.
4 Certain changes so that technicbi specifications agree with current plant configuration.
S.
Wording changes to more closely match the plant technical specifications with Appendix J and Standard Technical Specifications.
__ __ _ _ l
l 6.
Certain editorial changes.
{
The staff finds unacceptable:
1.
The proposed addition of a note which the staff considers ambigucus to Table 3.7.4 related to testing valves MO-14-70 M0-23-58, and M0-13-41.
2.
Changes to Bases pages 192 and 192a which pertain to a withdrawn exernption request and therefore could create confusion.
3.0 STATECONSUQATiph In accordance with the Commission's regula+ ions, the Pennsylvania State.
official was notified of the proposed issuance.of the amendments.
The State official bad no corrients.
4.0 }RV,1fO!gRTM,,C,0RSJDERATION The an,endnents change a requirement with respect to installation or use of a fecility conponent located within the restricted area as defined in 10 CFR Part 20. The NPC staff has determined that the arnendnents involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the an4ndnents involve no significant hazards consideration, and there has been no public con.nent on such finding (56 FR 47242). Accordingly, the amendnients raeet the eligibility criteria for categorical exclusion set forth in 10 CFR
,51.22(c)(9).
Pursuant to 10 CFR 51.?2(b) no environmental irnpact statement 01 drivironntntal assessrient need be prepared in connection with the issuance of the ar4ndnents.
5.0 CONCLUSION
The Conrission has conclnded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of 3
the public will not be endangered by operation in the proposed manner,
(?) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendnients will not be inimical to the comn:en defense and security or to the health and safety of the public.
Principal Contributors:
J. S. Guo V. L. Ruoney Date:
Octcher 23, 1991
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