ML20141H107

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Forwards Response to RAI Re License Change Application ECR 96-00982 Dtd 970618,revising TS Surveillance Requirement 3.6.1.3.16 Re Replacement Frequency of Primary Containment Purge & Exhaust Valve Inflatable Seals
ML20141H107
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 07/14/1997
From: Hunger G
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9707220013
Download: ML20141H107 (7)
v • d • e


Text

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Ctr.tlon Support Deprrtm!nt

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Y 10 CFR 50.90

. PECO NUCLEAR nw%c-965 Chesterbrook Ekautevard A Unit of PECO Energy Wayne, PA 19007-5691 July 14,1997 Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

Subject:

Peach Bottom Atomic Power Station, Units 2 and 3 Response to Request for Additional Information Concerning License Change Application ECR 96-00982

Dear Sir:

Attached is our response to your request for additional information concerning License Change Application ECR 96-00982 dated June 18,1997 (letter from J.

W. Shea (U. S. Nuclear Regulatory Commission) to G. A. Hunger, Jr. (PECO Energy Company)). This proposed change will revise Technical Specifications (TS) Surveillance Requirement 3.6.1.3.16 concerning the replacement frequency i of the Primary Containment purge and exhaust valve inflatable seals.

If you have any questions, please contact us.

Very truly yours, G. A. Hunger, Jr.f, ,

Director - Licensing if Attachments A oot 'i cc: H. J. Miller, Administrator, Region I, USNRC W. L. Schmidt, USNRC Senior Resident inspector, PBAPS 9707220013 970714 PDR ADOCK 05000277 :

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. -2 COMMONWEALTP OF PENNSYLVANIA:

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1 COUNTY OF CHESTER l

J. B. Cotton, being first duly sworn, deposes and says:

i That he is Vice President of PECO Energy Company; the Applicant herein; that he has read the attached response to the request for additional information concerning License Change Application ECR 96-00982, for Peach Bottom Facility Operating Licenses DPR-44 and DPR-56, 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.

/

AY /

Vice President Subscribed and sworn to before me this //k day of 1997.

/ Notary Public

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NOTE" AL CAFO.! WWoA) ..tary Putna uy$[niU,/ ._ .aaa dIyN

, RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION I

Question "In the May 9,1997 submittal PECO made the following statements:

(1) "T-ring seal performance reviews since 1986 indicate that documented failures were not due to material condition, but were mainly the result of improper installation."

(2) " Review of the PBAPS purge and exhaust valve performance history has determined that these valves are relatively free of valve leakage problems. Review of valve leakage test date supports this assessment."

. The Torus to Reactor Building vacuum breaker isolation valve leakage test results were also stated as supporting the extension request.

Please provide the purge and exhaust valve and Torus to Reactor Building vacuum breaker valve performance data used to support these statements."

Response

Attached is the performance history of the T-ring seals of the Primary Containment purge and exhaust valves, and Torus to Reactor Building vacuum breaker valves since 1986 (Attachment A). Also included is the Local Leak Rate Test (LLRT) history of the Primary Containment purge and exhaust valves, and Torus to Reactor Building vacuum breaker valves since 1986 (Attachment B).

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ATTACHMENTA -

Performance History for T-Ring Seals .

Unit 2 Valw # Date Problem Descnphon Dispostion/ Comments AO-2-078-2502A* n/a n/a No T-ring faaures documented from 1986 to present.

AO-2-078-2505 n/a n/a No T-ring faRures documented from 1986 to present.

Excessive leakage during LLRT, valve Found dirt between seat and T-ring and found T-ring wom AO-2-07B-2506 11/18/87 jumps ex:essivelywhen opening. at 61)0 position. Localized wear due to dirt buidup, not (Discovered during emended outage.) age related degradation.

AO-2-078-2507 n/a n/a No T-ring faBures documented from 1986 to present.

Replaced T-ring. Cause of falure not specifed.

a nn rep was pmhy mNaM AO-2-078-2511 9/24/94 Failed LLRT on 9/24/92. Due to being in service only 2 years, age degradation is highly unlikely.

AO-2-078-2512 n/a n/a No T-ring faRures documented from 1986 to present.

AO-2-078-2519 n/a n/a No T-ring failures documented from 1986 to present.

AO-2-078-2520 a/a n/a No T-ring failures documented from 1986 to present.

AO-2-078-2521A n/a n/a No T-ring faBures documented from 1986 to present.

AO-2-078-2521B n/a n/a No T-ring faRures documented from 1986 to present.

Unit 3 Valve # Date Problem Description Disposition / Comments AO-3-078-3502A* 9/6/95 Boot seal pressure decreasing Found CCV (Cam Operated Valve) out-of-adjustment.

AO-3-078-3502A* 7/31/95 Boot seal found de9ated Found limit switch out-of-adjustment. I AO-3-078-3502A* 11/1/89 sse e ' " Ex:essive dirt found. Cleaned valve and mplaced T-ring.

du I T scale leakage du@ as-found Boot seal fou@o WdaW Mom vale was fuHy AO-3-07B-3505 9/17/93 LLRT. closed. Sequencing problem identifed.

alw leah by ahW Incom W seat angle suW W Wor. WeM AO-3-078-3505 11/1/93 replacement. problem.

u e ne sea ama aM hstaM AO-3-078-3506 11/1/89 eakage -of- ustme t iden ifed g during ILRT.

Page 1 of 2

ATTACHMENTA -

Performance History for T-Ring Seals .

AO-3-07B-3507 n/a i n/a No T-ring fatures documented from 1986 to present.

T-ring was replaced per PM on 9/24/93. Subsequent LLRT AO-3-078-3511 11/2/93 Valve leaks fared on 11/2/93. Incorrect T-ring seat angle supplied by vendor.

T-ring was replaced per PM on 9/23/93. Subsequent LLRT AO-3-078-3512 11/2/93 Valve leaks faHed on 10/21/93. Incorrect T-ring seat angle supplied by vendor.

AO-3-078-3519 n/a n/a No T-ring falures documented from 1986 to present.

T-ring was replaced per PM on 10/22/93. Subsequent AO-3-078-3520 11/2/93 Valve leaks LLRT fared on 11/2/93. Incorrect T-ring seat angle supplied by vendor.

AO-3-078-3521A 10/31/93 Failed LLRT Air supply and etaust tubing reversed during PM.

T-ring was replaced per PM on 10/24/93. Subsequent AO-3-078-35218 11/6/93 Valw leaks LLRT faBed on 11/6/93. incorrect T-ring seat angle supplied by wndor.

Page 2 of 2

Attachmcnt B .

Measured Leakage of Purge and Vent Valves .

AO-2/3505

^ AO-2/3506 AO-2/3511

^ AO-2/3507 AO-2/3512 AO-2/3502A AO-2/3502B AO- 521A AO-2/35218 (3)

UN/T 2 As Found/As Left As Found/As Left As Found/As Left As Found/As Left As Found/As Left 1987 Outage (1) 243/665 20/75 (a) 10/10 20/130 20/350 1990 Outage (2) 78/80 10 39 901/10 1506 1991 Outage 100 61 10 30 1606/1802 1992 Outage 10/202 10/25 10/10 34/50 561 1994 Outage 310/90 51/49 OS/140 10 368 1996 Outage 20 20 20 38 250 UNIT 3 ,

1987 Outage (1) 10/200 10/15 (d) 10/89 300/621 (b) 85/10 1990 Outage (2) 881 1991 Outage 10 10 180/339 221/181 50/185 1993 Outage OS/10 (c)(f) 65/70 10/240 (e) 282 261 1995 Outage 700 20 25/940 20 20 Single Valve ea g 7000 cc/ min 5000 cc/ min 7500 cc/ min 7500 cc/ min 7500 cc/ min ept e Limits (1) Extended Shutdown (2) Mid Cycle Outage OS = Off-Scale Leakage (3) These valves are tested at the same time Page 1 of 2 Leakage Rates in cc/ min

ATTACHMENT B Measured Leakage of Purge and Vent Valves Notes:

(a) AO-2506 - The as-found LLRT (Local Leak Rate Test) was performed on 3/13/87 prior to the extended shutdown (20 cc/ min). A subsequent LLRT was performed on this Primary Containment purge and exhaust valve in 11/18/87 with offscale leakage recorded. After maintenance, an as-left LLRT was performed on 9/9/88 with satisfactory results (75 cc/ min).

l (b) AO-3502A - An as-found LLRT was performed (300 cc/ min). The Integrated Leak Rate Test (ILRT) was performed and valve leakage was identified (11/1/89). Maintenance was performed on the valve and an as-left LLRT was y performed with satisfactory results (621 cc/ min).

(c) AO-3505 - The as-found LLRT was offscale as a result of the T-ring inflating i too rapidly. Troubleshooting was performed and the external COV (Cam i Operated Valve) was found to be defective, ar.d was replaced. A subsequent "as-found" LLRT was performed on the boundary and the leakage was determined to be 350 cc/ min. The T-ring was replaced per scheduled Preventive Maintenance (PM). An incorrect T-ring seat angle was supplied by the vendor. A new T-ring was installed and an as-left LLRT was performed with satisfactory results(10 cc/rnin).

(d) AO-3506 - An as-found LLRT was performed (10 cc/ min). A subsequent ILRT was performed and valve leakage was identified (11/1/89). 1 Maintenance was performed and was followed by an as-left LLRT with satisfactory results (15 cc/ min).

(e) AO-3511 & AO-3512 - Leakage was identified after a PM T-ring replacement  !

during an intermediate LLRT. This LLRT was not the as-left LLRT.

(f) AO-3520, AO-3521 A & AO-35218 - Leakage was identified after a PM T-ring replacement during an intermediate LLRT. This LLRT was not the as-left .

LLRT.

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