ML20138M825
| ML20138M825 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 12/18/1985 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| Shared Package | |
| ML20138M812 | List: |
| References | |
| NUDOCS 8512230175 | |
| Download: ML20138M825 (15) | |
Text
.*t BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of a
Docket No. 50-35 2 PHILADELPHIA ELECTRIC COMPANY APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSE NPF-39 AND EXEMPTION TO PART 50, APPENDIX J
\\
Edward G. Bauer, Jr.
Eugene J. Bradley 2301 Market Street Philadelphia, Pennsylvania 19101 Atto rneys fo r Philadelphia Electric Company l
l 8512230175 8512 PDR ADOCK 050 52 PDR P
f BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of Docket No. 50-352 PHILADELPHIA ELECTRIC COMPANY APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSE NPF-39 AND EXEMPTION TO PART 50, APPENDIX J l
l Philadelphia Electric Company, Licensee under Facility Operating License NPF-39 for Limerick Generating Station Unit 1, hereby requests that the Technical Specifications contained in Appendix A of the Operating License be temporarily amended to provide an extension of up to twelve weeks (see attachment 1) to the local leak rate test interval (Type C tests) for certain primary containment isolation valves specified in Technical Speci fications 4.6.1.2.d and 4.6.1.2.g (page 3/4 6-4).
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Additionally, Philadelphia Electric Company requests, pursuant to Section 50.12 of the Commission's Regulations, an exemption from l
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the requirements of 10 CFR 50, Appendix J, Section III.D.3 to provide the same temporary relief.
Technical Specifications 4.6.1.2.d and 4.6.1.2.g (page 3/4 6-4) requires local leak rate tests (Type C tests) on the primary containment isolation valves listed in Table 3.6.3-1 to be performed at intervals no greater than 24 months, except for containment isolation valves, in hydrostatically tested lines penetrating the primary containment, which shall be leak tested at least once per 18 months.
The Commission's Regulations (10 CFR 50, Appendix J, Section III.D.3) require local leak test (Type C tests) to be performed during each reactor shutdown for refueling, but in no case at intervals greater than 2 years.
The end of the initial 18 month and 24 month intervals for some of the Limerick Generating Station Unit 1 primary containment isolation valves is approaching.
Type C tests are being performed on those valves that can be safely tested at power within the required test interval.
However, in order to meet the test interval requirements for approximately 15 tests covering thirty-seven valves (out of a total of approximately 245 valves), it would be necessary to shut down the plant prior to March 3, 1986, solely for this purpose, for approximately two we ek s.
A containment entry is required to perform testing upon t
the valves that cannot be tested at power.
Testing of these valves at power poses a personnel hazard due to the radiation field and high ambient temperatures existing within containment. 1
l l
l Additional restraints to testing some of the valves at power include the need to depressurize the reactor, drain the Reactor Enclosure Chilled Water (RECW) system, the Drywell Chilled Water l
System (DCW) or one Emergency Service Water (ESW) lo op, remove l
the recirculation pump or drywell coolers from service, or a l
combination of the above.
The long time associated with obtaining the full power l
license is a major factor in the need for schedule relief.
A l
normal schedule for low power testing, Start-up Testing and 100 j
hour full power warranty run would not have resulted in a j
requirement to extend the testing interval.
All low power (less l
than 5% thermal power) testing was completed prior to late April 1985.
Circumstances beyond the control of licensee delayed the issuance of the full power license until August 1985.
During this period of time the unit was maintained in a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> standby l
condition to demonstrate its availability for operation.
Because of this condition, testing of all of these valves was not i
possible.
During this same time period surveillance testing was completed on a number of valves.
These valves had test intervals that would expire prior to the expiration of the excess flow check valve test interval, which was the controlling interval due to the time required for its performance (i.e. two weeks).
The current schedule is for a maintenance and testing outage beginning on or before May 26, 1986 when the testing for those valves which are known to be maintenance-intensive in Boiling Water Reactors (e.o. main steam isolation valves and feedwater check valves) is required to be performed.
During this l
outage, maintenance activities, surveillance testing and minor plant modifications will be performed which will allow the plant to operate through the first refueling outage.
A two week outage required to perform this testing prior to May 26, 1986 would result in a net increase in overall outage time.
This additional outage would impose an economic penalty of greater than 6 million dollars to area customers as a result of replacement energy costs, and subject plant equipment and systems to the detrimental ef fects inherent in an additional shutdown and startup operation.
Therefore, Licensee requests an extension of up to twelve weeks to the Type C test interval for the specified primary containment isolation valves listed in Table 3.6.3-1, Part A, that require a plant outage, to test and a conforming exemption to the requirements of Appendix J to Part 50 (see attachment 1) for the applicable valves.
The proposed change as shown on enclosed Technical Specification page 3/4 6-4 would extend the test interval for these valves until May 26, 1986.
JUSTIFICATION FOR THE REQUESTED EXEMPTIO:;S NRC regulations provide for specific exemptions if the requested exemption is warranted as follows:
(1) the exemption and the activities to be conducted are authorized by law, (2) operation with the exemption does not endanger life or property or involve undue risk to the health and safety of the public, (3) the common defense and security are not endangered, and (4) the exemption is in the public interest because, on balance, there is good cause for granting it and the public healths and safety are i
adequately protected.
3 I.
The Requested Exemptions Are Authorized by Law and the Activities Which Would Be Allowed Thereunder Do Not' Violate Applicable Laws.
The criteria established in ICCFR50.12(a) are satisfied in this case, and no other prohibition of' law exists which would preclude the activities to be authorized by the requested exemption.
Thus the Commission is authorized by law to grant this exemption request.
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II.
The Requested Exemptions Will Not Endanger Life or Property The ef fects of deferral of the requested Type C tests l
upon the potential for post-accident leakage from the i
primary containment, and thus endangerment of life and property, have been evaluated and are shown to be negligible.
The following forms the basis for this 4
conclusion:
1.
This requested exemption applies only to the first s
scheduled periodic Type C tests for these l
As such, the valves do not have signficant operating hours upon them, and
.__.. _ __._.-.. _ _ _. _.. _ _., _. -. - _.. _ _ -_ -._, _ - ~. -.. -. -. _
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degradation of their sealing capability would not
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be ' expected.
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- 2.
The two-year time limit.of 10CFR50, Appendix J, ya t'
was written Lv ensure that Type C tests are performed on a schedule approximately consistent T
i with normal plant refueling outages.
At Limerick, 2
the schedule indeterminacy of the plant startup test program and the first fuel cycle has caused
- c S;
the two-year time limit for these valves to expire 4a just as ' the plant enters its first period of sustained operation.
The plant has not operated at consistently high power levels until this time; therefore, the subject valves have not been r
continuously exposed to the type of environment Which will occur during normal plant operation.
3..
Operating experience to date with the subject valves has been favorable.
The Type C tests which are the subject of - this exemption request are 4
among the earliest performed during the preoperational containment leakage test program.
Since that time, the valves have not required any maintenance, repairs, or adjustments Which would mandate reperformance of the Type C test in 7
conformance with Paragraph IV of Appendix J.
The requested exemptions are for containment isolation valves which have traditionally good i
maintenance histories in the industry.
No exemptions are being requested for the known maintenance-intensive valves in Boiling Water Reactor (BWR) plants, such as feedwater check valves, main steam isolation valves, and containment purge and -vent valves. (1) 4.
The sum total of the Type C test leakage rates on these valves is not a significant portion of the allowable leakage limits.
For the subject valves which are pneumatically tested and included within the plant's 0.6 La Type C leakage total, the total leakage recorded during the preoperational tests was 3786 sccm, or 18% of the current Limerick Type C test total of 20,910 sccm.
Since the maximum Limerick Type C test total of 0.6 La is 94,964 sccm, these valves would have to experience a significant increase in leakage before the plant's 0.6 La limit is exceeded.
5.
The Limerick preoperational leakage rate test experience with these valves was favorable.
Once system start-up type activities (e.g. system flushing, Limitorque operator settings, etc.) had been completed, the valves readily passed their Type C tests.
6.
Leakage through these valves will not af fect the conclusions of the plant preoperational Integrated
Leakage Rate Test The valve alignments for the ILRT result in the inclusion of minimum pathway leakage within the leakage rate total.
For scoping purposes we have assumed degradation of the tighter containment isolation boundary in the time since the ILRT was conducted, such that maximum pathway leakage would occur.
If the maximum pathway leakage for the valves is tabulated the ILRT results may be adjusted as follows:
Leakage Rates, %/ day Mass Point Analysis Calculated 95% UCL Corrected ILRT 0.1592 0.1646 leakage, from ILRT report (2)
Exemption Request 0.0203 0.0203 Correction Total Adjusted 0.1795 0.1845 ILRT Leakage The adjusted leakage rates show that even under this conservative method of assessment, Limerick is still well below the ILRT test acceptance criteria of 0.375%/ day outleakage, and also the Technical Specification LCO value of 0.5%/ day. ~
III. The Requested Exemptions Will Not Endanger the Common Defense and Security The common defense and security are not implicated in this exemption request.
Only the potential impact on public health and safety is at issue.
IV.
The Requested Exemptions are In the Public Interest The requested exemptions are in the public interest in that if literal compliance with the applicable provisions of Appendix J discussed in Section II above were mandated, a forced outage would be required resulting in substantial increased costs to the public without, as shown above, a commensurate increase in the protection of the public.
(1)
M. B. Weinstein,
" Containment Failure Experience -
Implications for Testing" presented at the Eleventh Biennial Topical Conference on Reactor Oprating Experience of the American Nuclear Society, Scottsdale, Az, August 1-3, 1983.
(2)
Philadelphia Electric Company; Primary Reactor Containment Integrated Leakage Rate Test for Limerick Generating Station, Unit 1, Final Report August 1984.
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~ Significant Hazards Consideration Determination The Commission had provided guidance concerning the application of standards in 10 CFR 50.92 for determining whether license amendments involve significant hazards consideration by.
providing certain examples Which were published in Federal Register on April 6, 1983 (48 FR 14870).
One of the examples (vi) of an action involving no significant hazards consideration is a change Which may in some way reduce a safety margin, but where the results of the change are clearly within all acceptable criteria.
The foregoing requested change and exemption fits this example.
Postponing the aforementioned local leak rate tests until an outage commencing on or before May 26, 1986 would allow for continued operation of the plant and would have little or no ef fect on containment integrity as discussed above and for the following additional reasons.
(1)
Redundant primary containment isolation valves are provided for each penetration; that is, two isolation valves in series.
Consequently, a reduction in the ef fectiveness of one seal would not compromise containment integrity.
Deterioration in the overall integrity of the containment penertations is normally a gradual process.
Considering the redundancy of the isolation barriers and the short duration of the requested extension of the testing interval, any reduction in containment integrity during the 12 week extension period would be negligible. -
(2)
The intent of the Technical Specifications and Section III.D.3 of Appendix J to 10 CFR 50 is to require testing of the isolation valves once every fuel cycle.
A normal reactor fuel load is designed to provide an 18 month cycle with approximately 16 months of full power operations.
Consequently, the primary containment isolation valves are normally exposed to 18 months of rated temperature conditions between each Type C test.
Due to the limited power history of the Limerick Generating Station since the initial Type C tests, these valves will have been subjected to rated temperature conditions for only approximately ten months as of May 26, 1986.
Consequently, the valves have been subjected to operating conditions less severe than that anticipated by the test schedule identified in the regulations.
A 12 week extension in the Type C test interval does not appear to be inconsistent with the intent of the test schedule specified by the Technical Specifications and Appendix J.
'(3)
Five of the tests, Which include ten valves, for Which extension is requested are for hydrostatically tested valves in Which the leakage is excluded from the Type C leakage rate total per Paragraph III.C.3 of Appendix J.
The preoperational leakage rate test experience with these valves was excellent; the aggregate leakage for the ten af fected valves was approxidately 0.2 GPM, which is substantially below the maximum leakage limit of 1.0 GPM times the total number of the valves.
These valves are in lines which connect-to closed systems outside of containment.
The closed system is missile protected, Seismic Category I, quality group B, and designed to the temperature and pressure conditions that the system will encounter.
The integrity of this closed system is assured by the leakage reduction and maintenance program developed in response to NUREG 0737, Item III.D.l.l.
Any leakage out of this system will be into the reactor enclosure, thus facilitating collection and treatment.
For these reasons, the proposed temporary amendment to the Limerick operating License does not constitute a significant l
hazards consideration in that it would not 1.
Involve a significant increase in the probability or consequences of an accident previously evaluated because the change extends the surveillance interval less than 20% beyond the current conservative surveillance requirements and has no ef fect on the assumptions of valve leakages assumed in the present analyses; or 2.
Create the possibility of a new type of accident or a dif ferent kind of accident from any accident previously analyzed in that current analyses assume certain values of containment leakage; therefore, new accident scenarios are not credible based upon scheduling of this testing alone; or 3.
Involve a significant reduction in the margin of safety because, based on the adjusted ILRT and initial LLRT results, these valves have exhibited a high degree of leak tight reliability.
Additionally, the valves have been exposed to operating conditions less severe than are normally experienced between testing.
The requested amendment concerns schedular relief for surveillance testing of a limited number of containment isolation valves and will not result in a significant change in the amounts or types of ef fluents that may be released of f-site.
There will be no significant increase in individual or cumulative occupational radiation exposure as a result of the requested amendment which merely requests to delay testing.
The Plant Operations Review Committee and the Nuclear Review Board have reviewed these proposed temporary changes to the Technical Specifications and exemption request and have concluded that they do not involve an unreviewed safety question
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or a significant har.ards consideration and will not endanger the public health and safety.
Respectfully Submitted, PHILADELPHIA ELECTRIC COMPANY x
Vicd Frasident i
COMMONWEALTH OF PENNSYLVANIA :
ss.
COUNTY OF PHILADELPHIA S.
L.
Daltrof f, being first duly sworn, deposes and says:
That he is Vice President of Philadelphia Electric Company, the Applicant hereint that he has read the foregoing Application for Amendment of Facility Operating License NPF-39 and Exemption to Part 50, Appendix J and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief, n/
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}l Subscribed and sworn to M
before no this /8 day at AW nk / hat Notary Public PATRtCIA O. SCHOLL Nctry Pttt:. PNHv; p3, ) c r., negn 9,,
My bm. abo 09 74.I Ic6ary 10, ILM l
UNITED STATES OF AMERICA NUCLEAR REGULATORY CO2 FISSION Before the Atomic Safety and Licensing Board In the Matter of Docket No. 50-352 PHILADELPHIA ELECTRIC COMPANY (Limerick Generating Station, Unit No.1)
CERTIFICATE OF SERVICE I hereby certify that copies of Philadelphia Electric Company's Application for Amendment of Facility Operating License NPF-39 and Application for Amendment of Facility Operating License NPF-39 and Exemption to Part 50, Appendix J in the above-captioned matter were served on the following by deposit in the United States mail, first-class postage prepaid on this19th day of December, 1985 Kathryn S. Lewis, Esquire Atomic Safety 4 Licensing Municipal Services Building Appeal Board Panel 15th 4 JFK Blvd.
U. S. Nuclear Regulatory Commission Philadelphia, PA 19107 Washington, D.C.
20555 Ann P. Hodgdon, Esquire Robert J. Sugarman, Esquire Counsel for NRC Staff Sugannan, Denworth 4 Hellegers Office of the Executive Legal Director 16th Floor, Center Plaza U. S. Nuclear Regulatory Commission 101 North Broad Street Washington, D.C.
20555 Philadelphia, PA 19107 Angus R. Love, Esquire Troy B. Conner, Jr., Esquire Montgomery County Legal Aid Conner 4 Wetterimhn, P.C.
107 E. Main Street 1747 Pennsylvania Avenue, NW Norristown, PA 19401 Washington, D.C.
20006
Docket 4 Service Section Timothy R. S. Campbell, Director U. S. Nuclear Regulatory Commission Department of Emergency Services Washington, D.C.
20555 - (3 copies) 14 East Biddle Street West Chester, PA 19380 Mr. Robert L. Anthony 103 Vernon Lane, Box 186 Director Moylan, PA 19065 Pennsylvania Emergency Management Agency Basement, Transportation 4 Safety Building David Wersan, Esquire Harrisburg, PA 17120 Assistant Consumer Advocate Office of Consumer Advocate Jay M. Gutierrez, Esquire 1425 Strawberry Square U. S. Nuclear Regulatory Commission Harrisburg, PA 17120 Region 1 631 Park Avenue Atomic Safety 4 Licensing Board Panel King of Prussia, PA 19406 U. S. Nuclear Regulatory Commission Washington, D.C.
20555 Phyllis Zitzer Limerick Ecology Action Mr. Frank R. Romano P.O. Box 761 61 Forest Avenue 762 Queen Street Ambler, PA 19002 Pottstown, PA 19464 Zori G. Ferkin, Esquire Charles W. Elliott, Esquire Governors' Energy Council Counsel for Limerick Ecology Action P.O. Box 8010 325 N.10th Street 1625 N. Front Street Easton, PA 18042 Harrisburg, PA 17105 E. M. Kelly Mr. Thomas Gerusky, Director Senior Resident Inspector Bureau of Radiation Protection U. S. Nuclear Regulatory Commission Department of Environmental Resources P.O. Box 47 Fulton Bank Building, 5th Floor Sanatoga, PA 19464 Third 4 Locust Streets Harrisburg, PA 17120 Spence W. Perry, Esquire Associate General Counsel FEMA, Room 840 500 C Street, SW Washington, D.C.
20472
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Eugene J. Bradley /
Attorney for
/
Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101