ML20096F690

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Forwards Response to Request for Addl Info on SER Confirmatory Issue 6 Re Pressure Isolation Valve Leak Testing
ML20096F690
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 09/04/1984
From: Kemper J
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To: Schwencer A
Office of Nuclear Reactor Regulation
References
OL, NUDOCS 8409100179
Download: ML20096F690 (4)


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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 JOHN S. KEMPER September 4, 1984 VICEfRESIDENT tusemaanswe ano mass AncM

'Mr. A. Schwencer,~ Chief Docket Nos.:

50-352 Licensing Branch No. 2 50-353 Division of Licensing U. S. Nuclear Regulatory Conmission Washington, DC 20555

Subject:

Limerick Generating Station, Units 1 and 2 Additional Information for Mechanical Engineering Branch

Reference:

1)

Letter from J. W. Gallagher to A. Schwencer, dated August 8, 1984 2)

Telecon between PECO and NRC Staff on August 14, 1984

Attachment:

Response to NRC Request for Additional Information on Confirmatory Issue No. 6 File:

GOVT 1-1 04RC)

Dear Mr. Schwencer:

The reference 1) letter transmitted our responses to four Mechanical Engineering Branch concerns, including SER Confirmatory Issue ' No. 6.

Pursuant to the reference 2) telecon, the attached revised response provides additional information on this issue.

We hope that this information will support the final resolution of. SER Confirmatory Issue No. 6.

Should any additional information be required, please do not hesitate.to contact us.

Sincerely,

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Copy to:.See Attached Service List Y* g 8409100179 840904

.PDR ADOCM 05000352

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~ Judge' Peter A. Morris (w/ enclosure)-

l Judge Richard F. Cole.

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-Troy.B. Conner, Jr., Esq.-

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~ Ann P.'. Hodgdon,.' Esq. '

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- Mr.; Frank R.. Romano (w/ enclosure)

Mr. Robert L.-Anthony

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Maureen Mulligan (w/ enclosure)

Charles W. Elliot,-Esq.

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Zori G. Ferkin,:Esq.

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Director, Penna. Emergency

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David Wersan,-Esq.

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Robert J. Sugarman, Esq.

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Board Panel Docket.S Service SectIon (w/ enclosure) e Mr. James Wiggins (w/ enclosure)-

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SER Confirmatory Issue #6 - Pressure Isolation Valves Leak Testing The Surveillance Requirement pertaining to. leak testing of pressure isolation. valves (PIVs) presented in Section 4.4.3.2.2 of Limerick Draft Technical Specification is not complete.

In addition'to the two requirements currently identified in Limerick draft Technical Specification, Section 4.4.3.2.2, the staff requires the PIVs to be

' leak. tested (a) prior to entering the Hot Shutdown whenever the plant has been.in Cold Shutdown for~72 hours or more and if leakage testing has not been performed in the ' previous-9 months and (b) within-24 : hours-following valve actuation due to automatic _or L~

manual action ~or flow through the valve. - Provide additional

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information to' assure that the Limerick plant-has the following plant features: (1) full closure of PIV's is verified in the control room by direct monitoring position indicators, (2) inadvertent opening of PIV's is-prevented by interlocks which require;the primary system pressure to be below subsystem design r

pressure prior to openings, and (3) gross intersystem-leakages _into the. low-pressure core spray, residua! heat removal / low-pressure coolant injection, and residual _ heat removal / shutdown cooling return and suction lines.would be detected by high-pressum. alarms

=and increases in.the suppression pool level. With these plant features in~p, lace, the PIV's are controlled and verified continuously rather than at the intervals specified in (a) and (b)

.above and then, the~ exception for relief from the surveillance

. requirements.(a) and (b) could be accepted.

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-Response I

~ The' Limerick Generating Station Technical = Specifications (Section 4.4.3.2, as modified during the NRC meetings, held June-11-15,1984) and the Limerick Pump and Valve Inservice. Testing Program Plan require that. Reactor Coolant System Pressure Isolation Valves (RCS-PIV) be

' leak ~ tested:

a)

At'least once per 18 months, and b)

Prior' to returning the valve to service following maintenance,

. repair or replacement work on the valve which could affect its

< leakage rate.

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The' additional surveillance requirements (a) and (b) listed in the ii question above are not. required because Limerick has the following

. features:

1). IAll RCS-PIV's listed in Tech. Spec. Table 3.4.3.2-1 have position

. indication-in the control room.

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All low pressure piping systems isolated by the RCS-PIV's listed

. In Tech. Spec. Table 3.4.3.2-1 are protected by Interlocks which require the reactor coolant system pressure to be below the low pressure system design pressure before a direct path may be achieved to the reactor. These interlocks are described along with all safety related high pressure / low pressure system Interlocks in FSAR Section 7.6.1.2.

3)

Any pressure increase caused by leakage past the Core Spray RCS-PIV's IIsted in Tech. Spec. Table 3.4.3.2-1 will be sensed and alarmed in the control room when the set point listed in the table is exceeded. After the first refueling outage, any pressure increase caused by leakage past the RHR system RCS-PIV's in Tech. Spec.

Table 3.4.3.2-1 will be sensed and alarmed in the control room as above. Before the first refueling outage, the RHR pum discharge line pressure will be observed and recorded once per shift from Indicators in the auxiliary equipment room to. infonn.the operators of any pressure increase. Gross Intersystem leakage into the CS and RHR systems may also be detected by monitoring the narrow range suppression pool level Instrunentation, which will be performed in accordance with Technical Specification 4.6.2.1, and by.

monitoring flow to the radwaste collection system.

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