ML20098E926
| ML20098E926 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 09/27/1984 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| References | |
| CON-#484-249 OL, NUDOCS 8410020128 | |
| Download: ML20098E926 (4) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 23O1 MARKER STREET P.O. BOX 8699 PHILADELPHIA, PA.19101 (215)841-4502
...!?" = Z -.
SEP 2 71984 Mr. A. Schwencer, Chief Docket No.:
50-352 I
Licensing Branch No. 2 50-353 Division of Licensing U. S. Nuclear Regulatory Ccamission Washington, D.C.
20555
Subject:
Limerick Generating Station, Units 1 and 2 Mditional Information for Mechanical Engineering Branch
References:
1)
Letter fran J. S. Kanper to A. Schwencer, dated Septenber 4,1984 2)
Telecon between B. Siegel (NRC) and B. Cronin (PEOO) on Septerber 24, 1984
Attachment:
Response to NRC Request for Additional Information on Confirmatory Issue No. 6 File:
GOVT 1-1 (NRC)
Dear Mr. Schwen r:
The reference 1) letter transmitted our response to SER Confirmatory Issue number 6, which deals with reactor coolant systen pressure isolation valve (RCS-PIV) leak testing. It was identified in the reference 2) telecon that our response should be changed to include leakage past the RHR shutdown cooling supply line BCS-PIV's as leakage which is sensed and alarmed in the control roan when the set point listed in the Technical Specifications is exceeded. Pursuant to the reference 2) telecon, the revised response is attached.
l-Sincerely, 1r BDC/mlb/09258401 cc: See Attached Service List
/
.)
}
8410020128 840927 PDR ADOCK 05000352 I
E PDR
cc: Judge Lawrence Brenner (w/ enclosure)
Judge Peter A. Morris' (w/ enclosure)
Judge Richard F. Cole (w/ enclosure)
Judge Christine N. Kohl (w/ enclosure)
Judge Gary J. Edles (w/ enclosure)
Judge Reginald L. Cotchy (w/ enclosure)
Troy B. Conner, Jr., Esq.
(w/ enclosure)
Ann P. Hodgdon, Esq.
(w/ enclosure)
Mr. Frank R. Rmano (w/ enclosure)
Mr. Robert L. Anthony (w/ enclosure)
Ms. Maureen Mulligan (w/ enclosure)
Charles W. Elliot, Esq.'
(w/ enclosure)
Zori G. Ferkin, Esq.
(w/ enclosure)
Mr. 'Ihmas Gerusky (w/ enclosure)
Director, Penna. Ermrgo:y (w/ enclosure)
Management Agency Angus R. Iove, Esq.
(w/ enclosure)
David Wersan, Esq.
(w/ enclosure)
Robert J. Sugarman, Esq.
(w/ enclosure)
Martha W. Bush, Esq.
(w/ enclosure)
Spence W. Perry, Esq.
(w/ enclosure)
Jay.M. Gutierrez, Esq.
(w/ enclosure)-
Atanic Safety & Licensing (w/ enclosure)
Appeal Board Atomic Safety & Licensing (w/ enclosure)
Board Panel Docket & Service Section (w/ enclosure)
Mr. James Wiggins (w/ enclosure)
Mr. Timothy R. S. Campbell (w/ enclosure) s
4-3 3.
SER Confirmatory issue f6 - Pressure Isolation Valves Leak Testing j
J The Surveillance Requirement pertaining to leak testing of pressure 1
isolation valves (PIVs) presented in Section 4.4.3.2.2 of Limerick
-Oraft 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 Shutdcun for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or more and if leakage testing has not been performed in the previous 9 months and (b) within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following valve actuation due to automatic or manual action ~or flow through the valve.
Provide additional 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 pressure prior to openings, and (3) gross intersystem leakages.into the low-pressure core spray, residual heat removal / low-pressure
. coolant injection, and residual heat removal / shutdown cooling return and suction lines would be detected by high-pressure alarms and increases in the suppression pool level. With these plant features in glace, 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.
Response
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.
The additional surveillance requirements (a) and (b) listed in the question above are not required because Limerick has the following features:
1)
.All.RCS-PIV's listed in Tech. Spec. Table 3.4.3.2-1 have position indication in the control room.
SEP 261984
~
e 2)
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 or the RHR shutdown cooling supply 1Ine RCS-PIV's listed in Tech. Spec. Table 3.4.3.2-1 will be sensed and alanned in the control room when the set point Iisted in the table is exceeded. After the first refueling outage, any pressure Increase caused by leakage past the remainder of 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 frcrn Indicators in the auxiliary equipment room to inform the operators of any pressure increase. Gross intersystan 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 nonitoring flow to the radwaste collection system.
l SEP 261984