ML20141M862

Requests Clarification of 851226 Fr Notice & Response to Listed Questions & Comments.Clarification Needed to Pursue Petition to Enforce Tech Spec Requirements & Require Util to Stop Operating Unit 1 Until Results of Tests Known

ML20141M862
Person / Time
Site:	Limerick
Issue date:	02/11/1986
From:	Anthony R ANTHONY, R.L., FRIENDS OF THE EARTH
To:	Butler W Office of Nuclear Reactor Regulation
References
CON-#186-237 OLA, NUDOCS 8602280483
Download: ML20141M862 (6)

Text

p ppc ANN &

Mr.%1tcr R. Butler, U.S Nuclect Ro C is] Fob.11,1986 BWR Projcot Directorato No. 4. Div. BWR Lieszeing

Yashingtos,. D.C. 20555 Res Phila Eleo. Limerick Gen.Sta. Units 1 & 2.

Pear Mr. Butler, ,

Docket No. 50 0 M M3 As intervenors in the Limerick licensing process under the name R' WVt o L.

Authony/F0E we are referring to the notice in the Fed. Reg, 12/26/85,52874-52876 si fromNRCtag. R, dated 1/gned 27/86 by you and forwarded to ue with anotice P4:q Following the instructions in the F.R. notice we sent a lot e Secre-tary,NRC, opposing the granting of the exemption requested by Pi$DMp'etiton-ing for a hearing and for leave to be admitted as intervenors to proteistpur safety and health. On 2/5/86 we followed this up with an amendment directed to the Secretary petitioning a second time to be admitted as intervenors and asking for a hearing. We trust these petitions will be granted.

what appears to us to be In pursuing confusing and,we our petitions believe we are erroneous handicapped material in the 12 by /26/86 F.R. notice. We ask that you kindly supply clarification. Furthermore,se have been supplied with a copy of a letter,1/29/86,from M.J.Cooney,PECO, to Robert Bernero,Dir.Div. BWR Licensing NRC. We are enclosing a copy of this letter which refers to a request for information (RAI) from R.E. Martin,NRC " in support of a December 18,1985 Re quest for Amendment..". Are we to assume that this is the same letter of 12/18/85:

referred to by you in your F.R. notice,p 52875 , from PEco ? We are also enclosing !

a copy of our letter of 1/30/86 to the Secretary and our amendment of 2/5/86. 6 We seek clarification from you on the questions and comments set forth below.

1. Letter to R.Bernero, 1/29/86. Are the NPRDS valves reviewed in TABLE 1 similar to those which are the subject of the Amendment,F.R. 52874 ? F.R. states that the lines in question " ard small (1 inch or less) " TABLE 1 specifies the sizes 1 " to 12 ". TABLE 2 "is a compilation of information reguarding the valves for which temporary relief of the testing requirement is sought". This table speci-fies 37 valves ranging from three @ 1" to 12 8 8", 8@ 12", and one @ 15". Please explain the discrepancy in sizes between F.R. 52874 and these valves in the tables if this is the same 12/26/85 request for exemption from PEco.

2. If,as it appears to us, the amenament requested by PEco is the same one referred to in all the documents above will it be necessary to publish a cor-in the Fed. Reg. and po kpone action on the amendment ? We were s

rected inforged notice on 2 /5/86 by the Chief of Docketing that the Project Director will be l the person to recommend to accept or deny the amendment request. If this is so, will Mr.R. Martin or any other NRC agent be prevented from acting on PEco's re-quest ? Since Mr. Martin requested additional information and Mr. Cooney stated that a " multi-faceted program " had he.en undertaken but was incomplete as of 1/29/86, will NRC withhold action until the results of the " program" are in ? ,

3 Since the subject of the leak test exemption and extention of time limit is a deadline in the regulations which ends on 2/19/86,apparently, will you require PECo to comply with the regulations and the Technical Specifications and proceed to carry out.the required surveillance tests by 2/19/86  ?

We repeat our petition to you and the Commission and all agencies of NRC to enforce the Tech.Speo. test requirements and require PEco to stop operating the unit i reactor as of 2/19/86 until the safe operation of the plant can be assessed from tha results of the required valve tests.

We are serving copies of this letter by mail on the Respectfully yours following: NRC: Commies.,Sec., Gen.Coun3el,R.Bernaro, o R.E. Martin, Docketing, Conner & Netterhahn hg , ggg ,

Box 186 Moylan,Pa. 1 065

/vV ' MG I ~ , e 2-/m e6o22so4sa e60211 2

7 ADOCK 050

{DR

]

. w PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.OI. BOX 8699 PHILADELPHI A. PA.191ol (zis) er.t.sozo MANAS.R e u., "c"',.""o U..."'.'!*.". v o . . , January 29, 1986 Docket No. 50-352 Mr. Robert Berner'o, Director Division of Boiling Water Reactor Licensing U.S. Nuclear. Regulatory Commission Washington, D.C. 20555

Dear Mr. Bernero:

The following information is provided in response to a Request for Additio'nal Information (RAI) from-Mr. R. E. Martin, Limerick Project Manager, of your staff, in support of a December 18, 1985 Request for Amendment to the Limerick Operating License and Temporary Exemption. to the requirements of Appendix J to 10 CFR 50.

This request was directed towards supplying information relative to industry experience with valves similar to those which were the subject of the Amendment Request. In order to support this RAI, a multi-faceted program has been undertaken which includes the following: 1) Review of Nuclear Plant Reliability Data systems; 2) Contact with other utilities identified as having similar valves; 3) Contact with valve manufacturers of the specific valves; and 4) Review of general experience with testing of similar valves at Peach Bottom Atomic Power S tation (PBAPS) .

Table 1 (attached) addresses item 1 above. Items 2 and 3 remain under investigation. In response to item 4, general experience with similar valves at PBAPS indicates that valve leakage appears to be related to type of service and time in service. Valves which are used in non-modulating applications, such as those which are the subject of this amendment request, tend not to have problems meeting leakage criteria.

Table 2 (attached) is a compilation of information regarding the valves for which temporary relief of the testing requirement is sought.

W

r-s s e b Mr. Robert Bernero January 29, 1986 Page 2 The.information gathered thus far has revealed nothing which would alte'r or affect the conclusions contained within our

. application.

Should you have any questions or require additional information, please do not. hesitate to contact us.

Very truly yours,

/

/

/

Attachments cca Dr. Thomas E. Murley, Administrator, Region I, USNRC E. M. Kelly, Senior Resident Site Inspector See Attached Service List Table Explanation Results of review of industry experience conducted through Nuclear Plant Reliability Data System Columns 1,__2, 3, 4 ,

Manuf acturer, Model Number, Size and Type of valves which are the subject of the amendment request.

Column 5 - Similar Number Identified Number of valves identified upon interrogation of NPRD data base. Search was based upon manufacturer, type and size

' range (e.g. Velan, gate, 2"-6") . Computer generated listing was manually sorted to identify similar model numbers. If no similar model numbers were identified, the number reported represents the numbers of all valves of same manufacturer, type and specific size.

, Column _6_

NPRD f ailure reports were obtained for all valves identified and reported in Column 5. These reports were reviewed and those f ailures which were relevant to leakage rates and isolation function are tabulated. It is notable that the reported f ailures concern valves which have been in service for significant periods and were reported to NPRD as " wear-out" .

Column 7 Identifies those totals which are reported for all valves of same size when similar model numbers could not'oe identified.

TABLE 1 .

NPRDS REVIEW OF SIMIIAR VALVES l

i SIMIIAR MPANINGEUL l NCIEER FAIIURES

. omNUFACTURER FEDEL SIZE TYPE IDENTIFIED REEORED COME'IS Velan B12-00054B-02hN 3" Gate 30 0 BlO-000548-02hN Crane Cat. f 47)liF 8" Gate 198 0

Rcckwell l-3624F316 IMP 1" Globe 492 28 1 1/2-3624F316IMIT 13/2" Globe ,

1 Atwood & Morrill 13673-02-03-05-06 12" CK 0(61*) 6* *All Models. .

13673-01-04 Anchcr/Darlirg SJO-2171-52 8" Gate 0 (337*) 4* *All Models.

1

~

SJO-2159-15 6" Globe 0(46*) 1* *All Models.

i

, SJO-2159-16

, SJo-5348-06 SJO-5348-07 12" Gate 0(226*) 1* *All Models.

Borg Warner Part No. 77940 1" CK 0(21*) O Circle Seal NV02-14 1" CK 0(14*)' 2* *All Models.

~

TABLE 2 .

Panatration Number Valve Numbers Test Frequency"of Previous Process Valve ,

tnd Dcscription (Size - Inches) Medium Valve Operation Test Results Fluid _ 2fanufacturer Type Model Number X-3D '

HV-59-1513 (1) N.O. Stroked Quart 7.54 SCCM PCIC or Rockwell Globe 1-3624 F316DfI

~ 'Instrumedt cas 59-1112 (1) Air Check Stroked Refuel 1.45 SCCM Instrumert Circle Seal Check NV02-14 Supply. Air . ,

X-13A ! HV-51-1F050A (12) Air / Check Stroked Refue.1 0.1 CPM

• Reactor Atwood & Morrill check 13673-01-04 Water N.C. Not Stroked 0.1 CPM

• Demineralized

'A' RRR Shutdown HV-51-151A (1.5)

Coolia.g Return Water Rockwell Globe 1 1/2-3624F316 1.Mttr' X-135 HV-51-1F0503 (12) - Air / Check Stroked Refuel 0.0 CPM

• Reactor Atwood & Morrill check 13673-01-04

'B' RHR Shutdown s Water N.C. Not Stroked 0.0 CPM ,

HV-51-1513 (15) Demineralized Rockwell Globe 1 1/2-3624F316 LM:C Ccolir.g Return Water __

X-14 HV-44-1F001 (6) Air N.O. Stroked Quart 24.0 SCCM Reactor Anchor / Darling C1cbe 530-2159-15 Razctor Water i HV-44-1F004 (6) N.O. Stroked Quart 485.75 SCCM Demineralized ' As.chor/ Darling Globe SJ0-2159-16 Cleanup Supply . Water N.O. Stroked Refuel 121.8 SCCM, React. Encl. Velan Cate 312-000543-02W I-23 . ..n HV-13-106 (4) Cooling Water Velan Cate~ 310-000543-02W Rsactor Enclosure. HV-13-108 (3) Air N.O. Stroked Refuel 23,.25 SCCNe N.C. Not Stroked 23.25 SCCMe Demin. Water Velan Cate 310-000548-02W i Cosling Supply HV-13-109 (3)

X-24 N.O. Stroked Refuel 5.2 SCCM React. Encl. Velan Cate 312-000548-02W HV-13-107 (4) Cooling Water Velan Cate 310-000548-02W Raactor Enclosure HV-13-110 (3) Air N.C. Not Stroked 3.6 SCCM*

N.O. Stroked Refuel 3.6 SCCM*, Valan Cate 310-00054B-02W Ceoling Return. HV-13-111 (3) Demin. Water l X-45A HV-51-1F041A (12) Check Stroked Refuel 0.0198 GPMe Suppression Atwood & Norrill check 13673-02-03-05-06

Air / Pool Water Anchor /Derling Cete SJo-5348-07 EHR LPCI 2V-51-1F017A (12)- N.C. Stroked Refuel 84.75 SCCM

'A' Water ~ Rockwell Globe 1-3624F316LNMI HV-51-142A (1.5) N.C.-Not Stroked 0.0198 CPMe .

X-45C HV-51-1F041C (12) Air / Check Stroked Refuel 0.002 CPM

• Suppression Atwood & Morrill Check 13673-02-03-05-06

'C' RER 12CI , HV-51-1F017C (12) Water N.C. Stroked Refuel 148. SCCM Pool Water Anchor / Darling Cate SJO-5348-07 N.C. Not Stroked 0.002 CPM

• Rockwell Globe 1-3624F316Uctr HV-51-142C (1.5)

X-45D RV-51-1F041D (12) -

Air / Check Stroked Refuel 0.0828 CPM

• Suppression Atwood & Morrill check 13673-02-03-05-C6

'D' BRR LPCI '

HV-51-1F017D (12) Water N.C. Stroked Refuel 976.8 SCCM Pool Water Anchor / Darling Cate SJ0-5348-07 HV-51-142D (1.5) N.C. Not Stroked 0.0828 CPM

• Rockwell Clobe 1-3624F316LNNr X-53 HV-87-120A (8) N.O. Stroked Quart 170.5 SCCM*e Deminer ized Crane Cate ._ No,.,

Dryvs11 Chilled HV-87-125A (8) Air N.C. Stroked Quart 170.5 SCCM , gar

• Water Supply 32.25 SCCM Anchor 7 Darling Cate SJ0-2171-52 HV-87-128 (8) N.O. Stroked Quart

TABLE 2 .

Penetration Number Valve Numbers Test Frequency of Previous Process Valve e,nd Description (Size - Inches) Medium Valve Operation Test Results Fluid Manufacturer Type Model Number X-54 NV-87-121A (8)' N.O. Stroked Quart 556.2 SCCH4 Crane Cate Cat. No. 47IUF Drywall Chilled hT-87-124A (8) Air N.C. Stroked Quart 556.2 SCCM

• Demineralized Crane Cate Cat. No. ~47IUF Water Return EV-87-129 (8) N.O. Stroked Quart 97.2 SCCM Water Anchor / Darling Cate SJ0-2171-52 X-55  : EV-87-120B (8) N.O. Stroked Quart 656.5 SCCM* .

Crane Cate Cat. No. 471UF N.C. Stroked Quart Demineralized Anchor / Darling Cate Dryvsll Chilled EV-87-122 (8) Air 11.4 SCCM ' SJ0-2171-52 Water Supply N.C. Stroked Quart 656.5 SCCM* Water Crane Cate Cat. No. 47xUF HV-87-1255 (8)

I-56 '

HV-87-12.B (8) N.O. Stroked Quart Juz.t> WLit" Crane Cate Cat. No. 47XUF Drywell Chilled HV-87-123 (8) Air N.C. Stroked Quart 35.5 SCCM Demineralized Anchor / Darling Cate SJ0-2171-52 Water Return . EV-87-1245 (8) N.C. Stroked Quart 302.6 SCCM4 Water * , Crane Cate Cat. No. 47IUF l

X-61B CRD or BN Wamer i

Rectre. ?tany Check Stroked Refuel 75.9 SCCM Reactor Check Part No. 77940

'B' 43-10048 (1) Air Demin. Water I SaalPurge{

X-205A 3 Suppression Suppressios ! EV-51-1F027A (6) Air- N.C. Stroked Quart; 2.25 SCCM Pool Water Anchor / Darling Clobe SJ0-5348-06 Pool Spray  ; or Air .-

l N.O. Normally Open

• Valves tested N.C. Normally Closed together.

• i f L'eakagg assign-I ed to both.

,, Current total

of type C test 22.000 i

SCCM ,

i e

e