ML20107L175

Requests That NRC Review & Approve Rev 3 to Relief Request GVRR-2 Re Second Ten Yr Interval IST Program

ML20107L175
Person / Time
Site:	Peach Bottom
Issue date:	04/23/1996
From:	Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9604290213
Download: ML20107L175 (5)

Text

. St:tisn Support Department

, A to CFR 50.55a PECO NUCLEAR l1TA"3"Ja,-

i A UNir or PECO ENrncy 965 Chesterbrook Boulevard i Wayne, PA 19087-5691 April 23,199u 5

Docket Nos. 50-277 1 50-278

License Nos. DPR.44 DPR-56 i

i U. S. Nuclear Regulatory Commission

! Attn: Document Control Desk Washington, DC 20555 i

Subject:

Peach Bottom Atomic Power Station, Units 2 and 3 '

Submittal of Revised Relief Request No. GVRR-2, Revision 3 to the Second Ten l Year Interval of the Inservice Testing (IST) Program

) References

• 1. Letter from G. A. Hunger, Jr. (PECO Energy Company) to U. S.

j' Nuclear Regulatory Ccm,r'.i;cn (USNRC), dated February 15, l 1995

2. Letter from J. W. Shea (USNRC) to G. A. Hunger, Jr. (PECO i Energy Company), dated March 13,1905 f

l 3. Letter from G. A. Hunger, Jr. (PECO Energy Co' npany) to USNRC, j dated April 17,1995 i

t

4. Letter from J. F. Stolz (USNRC) to G. A. Hunger, Jr. (PECO

Energy Company), dated July 7,1995

5. Letter from G. A. Hunger, Jr. (PECO Energy Company) to USNRC, dated July 14,1995

6. Letter from G. A. Hunger, Jr. (PECO Energy Company) to USNRC, dated August 9,1995

7. Letter from J. F. Stolz (USNRC) to G. A. Hunger, Jr. (PECO Energy Company), dated September 5,1995

8. Letter from G. A. Hunger, Jr. (PECO Energy Company) to USNRC, I dated September 19,1995

9. Letter from J. F. Stolz (USNRC) to G. A. Hunger, Jr. (PECO Energy Company), dated September 25,1995

Dear Sir:

Attac hed for your review and approval is Revision 3 to Relief Request No. GVRR-2 for the Peac.h Bottom Atomic Power Station (PBAPS), Units 2 and 3 Second Ten Year Interval inservice Testing Program (IST). This Relief Request was also the subject of the Referenced letters. A discussion of the changes, and the basis for relief, is contained in the attached revised Relief Request. We request that this Revision 3 to GVRR-2 be approved by July 12,1996.

9604290213 960423 gDR ADOCK 05000277 ' I I PDR

(

i Apr5 23,1996 i

Page 2

~

• l Relief Request GVRR-2 has been revised to identNy 3 valves (XFC-2(3)-02-11, XFC-2(3)42-21 A and j XFC-2(3)-02-021C) that can be tested during system outages rather than refueling outages. These i

valves were originally identWied in the Reference 9 Safety Evaluation as valves tested during refueling

, outages. However, further review has determined that these valves can be safely tested during system outages. The discussion below provides justNication for testing the valves during sys.am outages, at a refueling outage frequency, rather than quarterly testing as required by the Code.  :

1 AddkloneNy, justification is provided which demonstrates that testing of the valves during a refueling outage, which is permissible in accordance wth ASME/ ANSI OMa 1988, Part 10, also creates undue i hardship wthout a compensating increase in safety.

I

, As requested in Section 3.3.2 (" Valves Tested During System Outages") and Section 3.3.1 (" Valves l Tested During Refueling Outages") of the Reference 9 Safety Evaluation, this revised Relief Request

has been updated to separate the Excess Flow Check Valves (EFCVs) into ty>o categories: 1) EFCVs l that are tested during the system outages, and 2) EFCVs that are tested during refueling outages.

This reformatting is in addklon to the changes proposed by PECO Energy.

i

! Testing of XFC-2(3)-02-11 on a quarterly basis, or during refueling outages, results in an j unnecessary hardship without a compensating increase in safety. This check valve is located in the

] reference leg of level transmitter LT41. This level transmkter's primary function is to provide reactor i level indication during shutdown conditions. Testing of XFC-2(3) 0211 during the hydrostatic test j results in operators controlling reactor vessel level through control of reactor pressure without the

} on-scale level indication provided by LT41. Additionally, performance of this test during the hydrostatic test requires the backftling of the sensing line which subjects the operator to unnecessary risk that can be eliminated if the lines are tested during a system outage. During a

system outage, backftling is not necessary because normal steam condensation will refill the

! sensing line. Since level transmitter LT41 is the only instrument effected by the testing of XFC-2(3)-

02-11, and there are no trip functions associated with LT41, testing this valve at power will enhance j plant safety during the hydrostatic test by providing on-scale level indication throughout the i hydrostatic test.

Testing of XFC-2(3)-02-21 A and C on a quarterly basis, or during refueling outages, also results in undue hardship without a compensating increase in safety. These check valves are located in lines which connect to calibrated jet pumps 1 and 11, These lines connect flow transmitters FT-2(3) 63A and C to the high pressure test taps of calibrated jet pumps 1 and 11. Also connected to calibrated jet pumps 1 and 11 are excess flow check valves XFC-2(3)-02-23 A and C which are j tested during system outages and not refueling outages. Testing of XFC-2(3)-02-23A and C during system outages presents the opportunity to also test XFC 2(3)-02-21 A and C since these lines are also safely isolated during the system outage. The lines for XFC-2(3)-02-21 A and C are used to j measure flow through the jet pump and would not provide a safety function during the system outage Therefore, testing of XFC-2(3)-02-21A and C on a quarterly basis, or during refueling outages, results in undue hardship resulting from lost efficiency which can be obtained through testing the excess flow check valves during the system outage when the system is safely isolated and other system testing (Le., XFC-2(3)02-23A and C) is occurring Additionally, resources are at less of a premium during system outage than during a refueling outage.

If you have any questions, please contact us. i Very truly yours, d.

G. A. Hunger, Jr.

f.

Director - Licensing Enclosure cc: T. T. Martin, Administrator, Region I, USNRC W. L Schmidt. USNRC Senior Resident inspector, PBAPS

ip a, , .

REUEF REQUEST NO. GVRR-2, REVISION 3 l Valwee: Excess Flow Check Valves (EFCVs) tested during system outages- I Reactor & Recirculation System:

XFC-2(3142-007A(B)

! XFC-2(3) 02-023A(B,C,D), XFC-2(3)-02-025 XFC-2(3)-02-305A(B)

XFC-2(3)42462A(B,C,D)

XFC-2(3)42-031 B(C,D,E,G,H,J,K,M,N,P,R,T,U,V,W) l l l XFC-2(3)-02 011, XFC-2(3)02-021 A(C)

{ XFC-2(3)-02-064A(B,C,D) l RWCU System:

l XFC-2(3) 12 066A(B), XFC-2(3)-12-80457L(H) i j RCIC System: XFC 2(3)-13455A(B) j Core Spray System: XFC-2(3)-14431A(B)

HPCI System: XFC-2(3)-23-037A(B) l EFCVs tested during refueling outages:

j Reactor & Recirculation System:

XFC-2(3)42-008A(B) l XFC-2(3)-02 015A(B), XFC-2(3)-02-017A(B) 3 XFC-2(3)-02419A(B), XFC-2(3)42-021B(D)

XFC-2(3)42-027, XFC-2(3)-02 033, XFC-2(3) 02437A(B)

XFC-2(3)-02-073A(B,C D,E,F,G,H) j

Category: A, C Testing Requirement (s): Exercise quarterly l

j Basis for Relief: Excess flow check valves (EFCVs) are installed on instrument lines

penetrating containment to minimize leakage in the event of an j instrument line failure outside the containment in accordance with Regulatory Guide 1.11. The EFCV is a spring loaded ball check i

valve. Since the system is normally in a static condition, the valve l ball is held open by the spring. Any sudden increase in flow t through the valve (i.e. line break) will result in a differential pressure across the valve which wIl overcome the spring and l close the valve. Functional testing of valve closure is acco,Sished by venting the instrument side of the valve while the j process side is under pressure and verifying the absence of j leakage through the vent.

I,

i' , ,.

l The testing described above would require the removal of the associated instrument or instruments from service on a quarterly

basis. Removal of any of these instruments from service outside e

of a scheduled refueling outage or a controlled system outage may cause a spurious signal which could result in a plant trip, an l Inadvertent initiation of a safety system, loss of decay heat removal

, and/or the defeating of safety interlocks.

l

! l Testing of some EFCVs can be performed during a scheduled system outage when appropriate plant administrative procedures and controls are utuized to ensure plant safety. System outages

are performed in order to enhance system performance and

maximize system avalabilty. They are scheduled on a less than quarterly frequency (typicaNy once an operating cycle). Taking

system outages quarterly solely for the purpose of EFCV testing would result in reduced system avaBabutty and increased risk to

[ the plant. NUREG-1482, Section 3.1.2 recommends mir46Mg

! equipment out of seivice time. The additional assurance of operational readiness afforded through surveillance testing must I j outweigh the impact on plant safety incurred when removing j equipment from service 4

In Section 4.1.4 of NUREG 1482, the USNRC approves the deferral

) of backflow testing of check valves to refueling outages when the

testing requires the installation of test equipment The intent of j this request is the same in that EFCV testing requires a plant i evolution which should be avoided unless appropriate plant j administrative controls are in place.

I As discussed in NUREG 1482, the staff recommends that the basis for relief address whether: (1) the proposed attemative gives an acceptable level of quality and safety, (2) compilance would result in a hardship without a compensating increase in the level of safety, or (3) complying with Code requirements is impractical.

Two of these criteria, and the basis for meeting the criteria are provided below:

The ornnnaad altamative alves an accantable level of nuality and Balitut A review of NPRDS Industry fauure data for the Dragon excess flow check valves, which is the manufacturer of the valves used at PBAPS, reveals only 7 faRures. The 7 faHures break down as follows; 2 were a result of an IST surveulance which failed to meet the acceptance criteria for leakage, I was an indication (limit switch) problem, and 4 were leakage caused by a bad gasket.

Both IST falures occurred at Peach Bottom. A thorough review of Peach Bottom excess flow check velve test history has shown that l the 2 NPRDS falures above are the only 2 out of 956 valve tests since 1900. One of the failures,1.1 gpm measured leakage, was due to dirt on the seating surface of the valve; the other,4.0 gpm measured leakage, was due to a defective seating surface in the manual bypass port;on of the EFCV. These are 2 independent l faBures which have not been repeated. On!y 2 faHures out of 956 valve tests indicates that the valves are highly reliable. Further, this review of surveulance test history shows evidence of no time 3

i

r .

=

.t

. . . 4 L based fature rnochanisms or chronic falures associated with the meaam Sow check valves Although the testing of the EFCVs was

performed on the previous refueling cycle frequency

(approximately 18 months), testing of the EFCVs has been 4 performed since 1993 on a 24 month refueling outage frequency.

Therefore, performing the testing of the EFCVs on a 24 month i frequency is appropriate.

l l Comnilance wavM raank in a hardshio without a comoeriaatina increase in safety.

! Personnel safety would decrosse if EFCV testing would be l f

performed on a quarterly basis during plant operation without an  !

appropriate system outage During power operation, the process I side of the EFCVs is normally high pressure (>500 psig) and/or

high temperature (>200aF) and highly contaminated reactor j coolant. Testing EFCVs during system outage windows with the 4

appropriate administrative procedures and controls applied will ensure personnel safety. Additionally, testing at a frequency l greater than once per operating cycle would also result in l increased radiation dosage and reduced system avalability without i any compensating increase in safety.

l Improvements in work planning and scheduling have resulted in a

{ significant reduction in outage duration at Peach Bottom. As a ,

i result of these improvements, EFCV testing has become an outage i i crkical path activity. Due to the large number of EFCVs and the l plant conditions required to perform the testing (reactor pressure j > 500 psig), testing aN the valves during refueling results in an

outage duration increase of approximately 2 days. Based on

{ current replacernent power costs, this equates to an expenditure i of $900,000 per year for the life of the plant. In order to reduce j this level of burden, extensive programmatic and procedural

controls are used during system outages to ensure that the impact on plant safety is understood prior to removing equipment from ,

! service This process is consistent with industry practice and 1 j USNRC guidance, and has been recognized as an effective j method of controlling the impact of plant activities on safety.

During a refueling outage, the constraints on resources are at a j premium, and the elimination of work wh!ch can be safely i performed independent of these constraints is both practical and <

In summary, considering the extremely low falure rate, personnel l and plant safety concoms, and the high monetary cost of testing l

, during refueling outages, EFCV testing at a frequency greater than I j once per operating cycle and exclusively during refueling outages

is impracticable and results in a hardship without a compensating j increase in the level of safety.

Alternate Testing: Functional testing wul be performed once per operating cycle during a refueling outage or system outages when appropriate

! plant administrative controls are in place. I l

. _ _ _ - _ _ . _ _ _ _ __ . .