ML20154M904
| ML20154M904 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/11/1986 |
| From: | Conner T CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC COMMISSION (OCM) |
| References | |
| CON-#186-395 OLA, NUDOCS 8603170122 | |
| Download: ML20154M904 (18) | |
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UNITm STAnS OF AMERIC,1 b MAN 131987 k -
NUCLEAR REGUIATUE MSSIN { Era Before the Ccamission 't,
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g In the Matter of )
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Philadelphia Electric Ccmpany ) Docket No. 50-352-OIA
)
(Limerick Generating Station, )
Unit 1) ) March 11, 1986 LICENSEE'S ANSWER IN OPPOSITION TO IATE-FILED PETITION EVR LE,WE TO INTEIWFNE AND REQUEST EUR HEARING BY ROBERT L. ANTH0tN ON AN NO. 2 Preliminary Statorent On February 26, 1986, petitioner Robert L. Anthony filed a late 1
request for leave to intervene and for a hearing with respect to the proposed issuance of an amendment to Facility Operating License No.
NPF-39, which authorizes Philadelphia Electric Ccrpar.y (" Licensee") to operate its Limerick Generating Station, Unit 1 ("Linerick") . .
In an Application for Amendment of Facility Operating License NPF-39 and Exsption to Part 50, Appendix J filed Decstber 18,1985,M Licensee sought an amendnent which would revise Technical Specifications 4.6.1.2.d and g for Unit 1 to allow a once-only extension of time to satisfy local leak rate testing requirenents on certain primary contain-ment isolation valves. Urder the proposed amendnent, the surveillance l
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1/ The Application for Anendment was transmitted by letter dated Decertber 18, 1985 from Eugene J. Bradley, Associate General R. Denton, Counsel, Philadelphia Electric Ccrpany, to Ifarold (copy Director, Office of Nuclear Peactor Pcquiation, NFC attached).
l l 8603170122 860311
! PDR ADOCK 05000352
! 0 PDR L - - - .-.
o testing would be performed during a plant shutdown beginning no later than May 26, 1986, which would be a maxinaan of 84 days beyond the time otherwise required by the Technical Specifications.
Pursuant to its delegated authority under 10 C.F.R. 550.91(a) (2),
the NRC Staff published the Ccumission's proposed determination that the requested amenchent involves "no significant hazards consideration" in the Federal Register on Decenber 30, 1985.2/ %e notice in the Federal Register expressly stated that "any person whose interest may be affect-ed by this prWng and who wishes to participate as a party in the gc-aiing nust file a written petition for leave to intervene" within the time prescribed.3_/ Accordingly, the last day for filing a timely petition to intervene and request for a hearing in the instant matter was January 29, 1986. Mr. Anthony's petition, filed four weeks later, is clearly and inexcusably late. Mr. Anthony has failed to state any
" good cause" for his lateness. Nor has he even discussed, nuch less satisfied, the renaining criteria under the Ccmmission's regulations for accepting late-filed petitions.
Additionally, Mr. Anthony has failed to meet with the Ccurdssion's requirements for intervention under 10 C.F.R. 552.714 (a) (2) and (d) because he has failed to assert any cognizable interest in the amendment at issue. %erefore, under the Ccumission's regulations and precedents, 2/ 50 Fed. Reg. 53226, 53235 (Decarber 30, 1985).
3/ Id. at 53227. The notice erroneously stated the deadline as February 3,1986. This error resulted frcm miscalculation of the actual publication date and was rectified by a subsequent notice which correctly stated the deadline as January 29, 1986. 51 Fed.
Reg.1051 (January 9,1986) .
Mr. Anthony does not qualify for intervention and lacks standing to contest the issuance of the amendment. Accordingly, his petition should be dismissed.
Arument I. Mr. Anthony's Petition is Late Without " Good cause" and Fails to Satisfy the Criteria for Admitting Iate Petitions.
At the outset, the instant petition should be distinguished fran another, entirely different petition filed by Mr. Anthony which is now pending before the duly designated Atanic Safety and Licensing Board.1 In an earlier petition, Mr. Anthony challenged Amendment No. I to the Limerick operating license, which was granted by the NPC on February 6, 1986, following notice of proposed action in the Federal Pagister on Decenber 26, 1985.bI M&dient No. 1 authorized an extension of the allowable interval for testing certain reacter instrumentation line excess flow check valves as required by the plant's Technical Specifica-tions. Both the NPC Staff and Licensee have cpposed Mr. Anthony's amended petition to intervene and request for a hearing regarding the
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4/ Should the Comnission nimilarly designate the same or a new licensing board to decide the instant petition, Licensee's arginents are, of course, directed to the appointed board.
5/ 50 Fed. Peg. 52874 (Decerter 26, 1985). Without apparent reference to the Camissioners and without regard to the requirements of the Federal Pagister Act and the Ca mission's regulations in 10 C.F.R. 52.714 and 550.91, the Office of the Secretary advised Mr. Anthony by letter dated February 6,1986 that a " conforming petition" Mr.
Anthony said he would file "will be docketed and referred to the Atanic Safety and Licensing Board Panel for consideration."
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grant of that operating license amendnent.6,/ On February 12, 1986, the Oiief of the Atmic Safety and Licensing Board Panel established an At mic Safety and Licensing Board to rule upon any petition to intervene and request for hearing associated with that mendment.
'Ihe instant petition by Mr. Anthony pertains to a different license amen &nent request concerning local leak rate testing requirements on certain primary contaiment isolation valves. As noted, notice of that pwpc;;d amendinent was published in the Federal Register on Deceber 30, 1985. 'Ihe request was granted by the NBC on March 3,1986 as Amndment No. 2 to the Limerick operating license.1 Accordingly, Mr. Anthony errs in concluding that the jurisdiction of the Licensing Board already designated in the proceeding regarding Amendment No. 1, absent ocme action by the Ccmission, " extends also" to his petition and hearing request regarding Amendment No. 2.8/ Likewise, there is no basis for Mr. Anthony's atter:pt to incorporate by reference his papers concerning
?..e-dimit No.1 inasruch as they involve an entirely different proceed-ing.
6/ See Response of NPC Staff in Opposition to Petition to Intervene W Pequest for a !! caring by Anthony /ftE Pegarding Licensee's Amendent Pequest (February 25, 1986); Licensee's Answer in Opposition to Late-Filed Petition for Imave to Intervene and Request for Hearing by Robert L. Anthony (February 19, 1986).
7/
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See letter frm Walter R. Butler, Division of Dh"1 Licensing, NFC to Mrd G. Bauer, Jr., Vice President and General Counsel, Philadelphia Electric Corrpany (March 3,1986) (copy attached).
8/ See Petition by Anthony for a Hearing and leave to Interveno (February 26, 1986).
I.
mus, whether Mr. Anthony has shown " good cause" for lateness must be established on the basis of notice pertaining to Amendment No. 2 rather than any ciretsnstances concerning other mendments or proceedings for the Limerick facility. Mr. Anthony's purported justification for lateness, that he received a copy of the Federal Register notice along with an NRC document on January 29, 1986, is totally unconvincing and without merit. As noted, Mr. Anthony had actual rotice of the Applica-
! tion for Amenchnent by virtue of the ecpy served by Licensee on Decertber 18, 1985. He has filed many similar " petitions" before the Ccanission and stust be held accountable for kncwing that deadlines for filings must be met.
To allow intervention on the basis of the Staf f's sunnary of applications, particularly one dated after the expiration of the 30-day notice under 10 C.F.R. 550.91 in the Federal Register, would make a mockery of the Federal Pegister Act and is highly prejudicial to the rights of applicants. The law is clear that publication in the Federal Register gives full notice to all persons who might later seek to intervene The law required that the Nt: clear Pegulatory Ccmnis-sien publish once in the Federal Begister notice of its intention to act on an application for an werd-at to an operating license CIhe Atcmic Energy Act of 1954, as amended, Sec. 189). %e Appeal Board noted, in Jamesport, that "We Federal Regis-ter Act expressly provides that such publication constitutes notice to 'all persons residing within the States of the Union.' 44 U.S.C. 1508 " Img Island Lighting Capany (Jamesport Nuclear Power Station, Units 1 and 2) (,) AIAB-292, 2 NRC 631 (1975). Moreover, many years ago the U.S. Suprevne Court ruled that publication in the Federal Penister i
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l gives legal notice to all citizens (Federal Crop Insurance Corp. v Merrill, 332 US 380-388,1947) .9/
As the Licensing Board aptly stated in the Seabrook proceeding, pubik:a-tion in the Federal Register to parties wishing to intervene in hearings before the NBC "is a notice to all the world." E
'Ihe Appeal Board recently reiterated this very point in a case on all fours with Mr. Anthony's petition, which involved an amenchent to the operating license for the Pilgrim reactor. Like Mr. Anthony, who participated at great length as an intervenor in the Limerick proceed-ing, the petitioner in Pilgrim was a long-time intervenor in NBC cases.
l Nonetheless, he ignored the deadline for timely intervention given in a l Federal Register notice. The petitioner there did not contest the finding that his petition, filed eight days late, was untimely.E# The 1
Appeal Board affirmed, rejecting petitioner's claim that he should have been granted a seccnd opportunity to explain his lateness after the issue had been raised by the Licensee's and NRC Staff's answers to his petition.N l
,9_/ Florida Power and Light Ccmpany (Turkey Point Nuclear Generating Station, Units 3 and 4), wP-79-21, 10 NBC 183, 192 (1979). See also Maine Yankee Atanic Power Capany (Maine Yankee Atcnic Power Station), 2P-82-4, 15 NBC 199, 201 (1982); New England Power f.
Light Capany (NEP, Units 1 and 2), LBP-78-18, 7 NRC 932, 933-34 (1978).
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10/ Public Service Cmpany of New Hartoshire (Seabrook Station, Units 1 l and 2) , IEP-82-76,16 NRC 1029,1085 (1982) .
1 l 11/ Boston Edison Conpany (Pilgrim Nuclear Power Station), ILP- d5-24, l
22 NRC 97 (1985), af f'd, AIAB-816, 22 NFC 461 (1985) .
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2 Pilgrim, supra, AIAB-816, 22 NBC at 466-68.
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Equally important, the Appeal Board held that "given (petitioner's) failure even to address the section 2.714 (a) lateness factors, his ;
intervention petition was correctly denied because it was untimely."33/
It ruled that "the burden of persuasion on the lateness factors is on the tardy petitioner and that, in order to discharge that burden, the petitioner nust cone to grips with those factors in the petition it- >
i self."El Like Mr. Anthony in the instant proceeding, the petitioner in Pilgrim was "by no neans a newcaner to !GC licensing proceedings"E and, given his experience, " fully apprehended the reach of the affirma-tive obligation inposed upon the petitioner who appears on the scene aftertheprescribeddeadlinehaspassed."El The Appeal Board recently had occasion to remind Mr. Anthony of that " affirmative obligation," E but he has nonetheless failed to address the lateness criteria here.
Also on point is the holding in Seabrock dismissing a late-filai petition by a knowledgeable intervenor in the operating license proceed-ing. Citing an argtrent by petitioner which " betrayed his understanding 13/ Id. at 465-66.
14/ Id. at 466.
15/ Id. at 467 16/ Id. at 468.
J_7/ Lincrick, supra, Aue-828, 23 tmC (January 16, 1986) (nlip op.
at 10-16).
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of such legal requirement as notice (in the Federal Register),"E the Licensing Board held:
This appears to be the statment of one well versed in nuclear matters appearing in the Federal Regis-ter. Thus, Petitioner apparently was well qualified to locate notice of hearings in the Federal Register
.... The Board has elected to address this argument to make it clear to others in this proceed-ing who do not understand that ignorance of Federal Register notice is no justification for permitting late intervention or justification for ignoring the matters set forth in Federal Register notices pertaining to this proceeding.H/
Accordingly, Mr. Anthcny's petiticn is four weeks late without " good cause" for lateness.
Mr. Anthony has also failed to address, ::uch less satisfy, the ,
remaining four factors for considering late-filed petitions under 10 (
C.F.R. $2.714(a) (1) . Of On the second factor, other means exist to ,
protect Mr. Anthony's interest. As the Appeal Doard recently ruled in the Limerick case, reliance upon the tac Staff rmy constitute sufficient "other means," depending upon the issues sought to be raised, the relief requested and the stage of the proceedireJ.E# Inasmuch as the Staff han c
18/ Public Service Crepany of New Hangshire (Seabrook Station, Units 1 and 2), Docket Nos. 50-443-OL and 50-444-OL, " Order" (November 15, 1983) (slip op, at 4-5) .
19/ Id. at 5.
20/ Failure even to discuss the five factors itself justifies denial of his late petition. Duke Power Ccevany (Perkins Nuclear Station, Units 1, 2 ard 3), AIF615,12 t#C 350, 352-53 (1980) . See also Metropolitan FAison Ccm sny (Three Mile Islarul Nuclear Station, Unit No.1) , CLI-83-25, ;,8 t4C 327, 331 (1983) .
21/ Limerick, supra, AIAB-828, 23 tHC (January 16, 1986) (slip op.
at 12).
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f already prepared a detailed, written safety evaluation in support o Amendment No. 2, it is clear that it has acted and will continue to act in protection of any interest asserted by Mr. Anthony. f On the third factor, requiring a desnonstration that petitioner can Mr. Anthony has not l assist the Board in developing a sound record, j demonstrated any particular knowledge or expertise on reactor safety. I Mr. Anthony makes no personal claim of exprtise in analyzing the poten-t l tial for significant safety hazards associated with the subject cpera -
ing license anunchent, nor has he provided EI the names of any prosp .
expert witnesses and a sunmary of their proposed testinony.
ir/
On the fourth factor, representation of Mr. Anthony's interests For the I
existing parties, the NBC Staff is a party to every proceeding.
it would adequately represent Mr. Anthony's !
reasons discussed above, In any t
interests if there were a hearing on the challenged amerskent. '
less event, the seccmd and fourth factors are entitled to substantially l
Fifth, regarding the potential for delaying the consideration.E#
proceeding and broadening the issues, it is axicmatic that grantin '
l Anthony's late petition will result in delay because, unless his late i
g/ Accordingly, Grand Gulf thatMr. Anthony
"[wlhen has addresses a petitioner not ccerplied with the this criterico it requi should set out with as much particularity as pos
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l Mississirvi Powr I, LirJh t l stsmarize their preposed testinony." 1 and 2), MAB-704, 16 l c_q (Grand Gulf Nuc1 carSee Station, Unitsalso Washincton Public Powr surely l i tac 1725, 1730 (1982). 18 NHC 1167, 1177 Systeun (WPPSS Nuclear Pro %t tio. 3), MAk747, l
~(1983)t Long Istard Lichtinr1 Crepany (Shoreharn Nuclear Ptwr ,
f Station, Unit 1) , MAD-741,18 tac 387, 399 (1983) . l i
' y/ South Carolina Electric and Gan Ces@any (Virgil C. Stm Station, Unit 1) , NAD-642,1314C H81, 894-95 (1981) . l l
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petitionisgranted,therewouldbenohearingatall.E hllowing lata intervention without good cause is highly prejudicial to the Licensee, which would be put to the time and ew of defending yet another attack on Limerick by petitioners. Further, it is clear that Mr. Ranano l wishes to litigate certain matters not raised by Mr. Anthony, albeit those matters are beyond the scope of this pwceing, such as previous Licensee Event Reports and IE Report 50-352/86-02.E Accordingly, Mr.
Anthony has failed to discuss the five criteria for considering late petitions and has also failed to satisfy those criteria cm balance.
II. Mr. Anthony Has Not Satisfied the Requirments of 10 C.F.R. $$2.714(a) (2) and (d) and Iacks Standing to Intervene.
Under the Ccanission's Rules of Practice, a petition to intervene t
in a licensing proceeding may be granted only if the requirments of 10 l t
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24/ See Houston Lighting and Powr Ccmpany (South Texas Project, Units i 1 and 2) , AU4-549, 9 NBC 644, 650-51 (1979): Tentwenac Valley Authority (Watts Bar Nuclear Plant, Units 1 and 2), A1AB-413, 5 NPC 1418, 1422 (1977). These principles require particular attention to objections on the grounds of standing and tinw11 ness because
" boards should be cautious about triggering such hearings at the behest of those without a statutory right to intervene." South It is noted that delay in Texas, ecmplet Tngsum, AIAB-549, 9 not the proceeding, NBCdelay, at 649.in issuing the license amendment or plant operation, is the controlling factor. Llw rick, supra, ALAB-828, 23 NBC (January 16, 1986) (slip op at 15) .
l ,2_5/
5 IE Report 50-352/86-02 (February 4,1986) (copy attached) involved !
l a routine safety inspection of the Limerick Unit 1 radiation l
protection prcgram. The tac found no violations and required no t l reply to the report. There is no basis for Mr. Acmvo's assertion ;
that the report shcws " welding and improperly proportioned
! concrete." Pomano Petition at 2 (February 24, 1986). N reover, l his allegation is totally unconnected to any aspect of h. bat i
No. 1. t l
O C.F.R. S$2.714 (a) (2) and (d) have been satisfied. %ese prerequisites are set forth below:
(a) (2) he petition shall set forth with particularity the interest of the petitioner in the proceeding, how that interest may be affected by the results of the proceeding, including the reasons why petitioner should be permitted to intervene, with particular reference to the factors in paragraph (d) of this section, and the specific aspect or aspects of the subject matter of the proceeding as to which petitioner wishes to intervene.
(d) We Ccomission, the presiding officer or the atcnic safety and licensing board designated to rule on petitions to intervene and/or requests for hearing shall, in ruling on a petition for leave to intervene, consider the following factors, among other things:
(1) The nature of the petitioner's right under the Act to be made a party to the proccaling.
(2) ne nature and extent of the petitioner's property, financial, or other interest in the proceeding.
(3) We possible offect of any order which m1y be entered in the proceeding on the petitioner's interest.
Ilowever liberally these rcquiramnts might be interpretal in a plenary cporatim license case, a truch more specific shcuing trust im rmde in a case involving only a tmporary schedular change for curpli-ance with plant Technical S[ccifications. In the Pilgrim operating license amendrmnt proceeding, the Licensing Ibird denied a late petition for leave to intervem because the petitioner lacked standing under the stricter standard applicable to armndmnt procealirgs. Oc Ibird held:
Win case concerns a reviuent for a licenne amendrmnt and it is not controlled by the samn standing considerations that govern standing when an operating licence is sought. hhatever tM risk to the nurrounding ccrrunity fecm a reactor arvi its asociatrd fuel pool, the risk frra the fuel pool
alone is less and the distance of residence fra the l pool for which standing would be appropriate would, accordingly, be less. Consequently, we do not consider residence 43 miles from this plant to be !
adequate for standing. We need not decide how close i residence might be before standing would be estab-lished.26]
In affirming that decision in Pilgrim, the Appeal Board expressly left open the question of "whether either [ petitioner's] place of residence or his consurrption of food products originating in the vicini-l ty of the facility serves to clothe (petitioner) with the requisite l
mantle of standing to challenge the proposed wid....it to the Pilgrim operatinglicense."E l
Licensee subnits that the Pilgrim rationale and outcme are con-l trolling here. Mr. Anthony resides in Moylan, Pennsfivania, which lies scum 20 miles southeast of the Linarick plant. The only purported
" interest" in the proposed amer &ent asserted by Mr. Anthony is as f
i fo11cws:
We believe that w are entitled as effected (sic) i residents ard PECo ratepayers (1) to te admittal as i i
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26/ Pilgrim, supra, IBP-85-24, 22 NPC at 99 (enphasis in original).
l The Board added that it knew of "no scenario trAer which radiation
, attributable to the fuel pool would affect a residence 43 miles distant fra the fuel pool; and petitioner has not informed us of any such scenario." d.
I,d 1
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27/ Pilgrim, supra, MRi-016, 22 1.TC at 465. Although it noted one l particular precedent cn standing which it deesrux! relevant, the l Appeal Board in Pilgrim did not cite its prior holding in Viryinis i
Electric arvi Power Crepany (North Anna Nuclear Power Station, tnits l I and 2) , MAB-522, 9 t.'PC 54 (1979). In that case, the Apsmal Board reversal the denial of stanling to ptitioners in a license anmdment procenling to enaMe expansion of the spent fuel pool .
capscity for Units 1 and 2 of tre North Anna plant. It is I uncertain whether the Appeal Board in Piltrim believed that its earlier North Anna holding was distin pashable or should 1;n reconsideral wtwn its opinion would not constitute dicttsn. j i
t t
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i a party to the gc-:::Mngs, and that (2) as property owners and workers in the area of the Limerick plant we have family and financial interests in the gc-- - - Wgs, and (3) if this amardwnt were issued, there would be severe repercussions for us through the threat of radioactive poisoning fra a possible radiological accident, the necessity to sell our property and seek enployment outside the PECo area, and the m nying finarcial and social disruption of our lives.M/
Nothing in these self-serving but 'msupported allegations states how Mr. Anthony, as one who resides, owns property or works 20 miles distant fra the Limerick plant, will suffer any injury or otherwise be affected by a short extension of the time within which Licensee must conduct its local leak rate testing on certain primary contalment isolaticn valves. Nothing asserted by Mr. Anthony states any connection between the grant of such an 4 -at to the plant's operating license and the alleged " threat of radioactive poisoning frm a possible radio-logical accident."E# 'Ihe treru recitation that an accident is possible fails to specify any interest on the part of Mr. Anthony which might be potentially affected by this particular armrdent. Absent a specified nexus between the amen &ent and his putative interest, Mr. Antkrny has failed to deonstrate either the nature of his interent or how it might ,
be affected by the outcan of this proceeding.E! '-
M/ Petition by Anthony for a llearing and brave to Intervene (February 26, 1986).
I 29/ Id. ,
M/ Mr. Anthony atterpts to establish an interest by asserting that the extension " constitutes a high risk . . . since the safe o;eration ,
of the reactor canrot be assured without these tests havnng been '
successfully concludal." M. Apparently, Mr. Anthorr/ is arguing (rootnote Continued)
Put difforently, nothing alleged by Mr. Anthony shows any person-alised grievance which gives him standing under the ccamission's rogu-lations and procedents. As the Camission has stated, see " injury in fact" to the petitioner himself, and not a generalized grievance or interest shared by a large class of the public, is necessary for stand-ing. In Transnuclear, Inc., CLI-77-24, 6 NRC 525 (1977) , the ccanission held as follows in deciding that petitioners lacked standing to request a hearing:
Any right the Petitioner may have to demand a i hearing in the present proceeding must be based upon !
Section 189 of the Atcmic Energy Act of 1954, as amended, 42 U.S.C. 2239. Sat section provides that a hearing must be granted, on the request of persons .'
who can dennonstrate an " interest (which) may be affected by the proceeding." Under the most recent Supreme Court decisions on standing, a party seeking relief must " allege scne threatened or actual injury resulting frce the putatively illegal action before ,
a federal court may asstne jurisdiction." Linda l R.S. v. Richard D. , 410 U.S. 614, 617 (1973) , Warth
- v. Soldin, 422 U.S. 490, 499 (1975); see Simon v.
Eastern Kentucky Welfare Rights Organization, 426 U.S. 26 (1976) . One focus of the " injury in fact" test is the concept that a claim will not normally be entertained if the " asserted hann is a 'gener-alized grievance' shared in substantially equal wasure by all or a large class of citizens . . . ." l Warth v. Seldin, 422 U.S. at 499. @us, even if !
there is a generalized asserted harm, the Petition- i ers nust still show a distinct and palpable harm to l them. Id. at 501. See United states v. Students (Footnote Continued) i that any schedular exmption autcmatically constitutes a safety l hazard. Such rescening is logically deficient because, on that i basis, the NPC could rever grant a schedular exeption or any other license amendm nt upon a finding of "no significant hazards consideration." This allegation does not create any interest on the part of Mr. Anthony. t l
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Challenging Regulatory Action Procedures (SCRAP),
1 412 U.S. 669 (1973) .31/
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'Ihe Cannission reviewed and reaffircrd these requiresnants for standing in rejecting intervention petiticns in Westinghouse Electric Corp. (Export to South Korea), CLI-80-30,12 NRC 253 (1980) . It again enphasized the importance of stating see " injury in fact" to the petitioner himself as a basis for establishing the requisite personal l interest in the proceeding. 'Ihe Camission held:
In developing the " injury in fact" requirment, the Court has held that an organization's are interest in a problem, "no matter how long-standing the interest and no matter how qualified the orga-nization is in evaluating the probi m ," is not sufficient for standing to obtain judicial review.
I Sierra Club v. Morton, 405 US 727, 739 (1972) . Tte organization seeking relief nust allege that it will suffer sme thra.atened or actual injury resulting frm the agency action. Linda R.S. v. Richard D. ,
410 US 614, 617 (1973); Warth v. Seldin, 422 US 490,
! 499 (1975). Simon v. Eastern Kentucky Welfare l Rights Organization, 426 US 26, 40 (1976), made i clear that "an organization's abstract concern with '
a subject that could be affected 17/ an adjudication ;
does not substitute for the concrete injury, required by article III."3_2/
Contrary to these requirements, Mr. Anthony has shown no threatened or actual injury in fact frm the issuance of Amendment No.1. I!is peti-tion states only an abstract, generalized concern for safety E/ 6 NRC at 530-31 (ent asis h added) . While the cited proceeding was for consideration of export license applications, the Canission did not distinguish the standing requiremnts frm those applications in other proceedings, including reactor applications.
32/ 12 NPC at 258.
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See also Nuclear Engineering Corpwl, Inc.
(Sheffield, Illinois, Iow-Irvel Padioactive Waste Disposal Site),
l AIAB-473, 7 NPC 737, 739-43 (1978); A111mi-Ceneral Nuclear Services l (Barnwell Fuel Peceiving and Storage Station), AIAD-328, 3 NRC 420 (1976).
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indistinguishable from the concern of the general public and is there-fore insufficient for standing.
Conclusion For the reasons discussed above, Mr. Anthony's petition for leave to intervene and request for a hearing should be denied.
Respectfully sutnitted, C0hWER & WETTERHAHN, P.C.
- h. -
Troy B. Conner, Jr.
Robert M. Rader Counsel for Licensee March 11, 1986 l
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h t L/ A
,3-i >i MAR 1319R68-29 UNITED STATES OF AMERICA ghgG4 sccr.nnc b
U NUCLEAR REGULATORY COMMISSION 0- ,
In the Matter of ) b -
('
i
)
Philadelphia Electric Company ) Docket Nos. 50-352
, ) 50-353 (Limerick Generating Station, )
l Units 1 and 2) )
CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Answer in Opposition to Late-Filed Petition for Leave to Intervene and Request for Hearing by Robert L. Anthony on Amendment No.
2," dated March 11, 1986 in the captioned matter have been served upon the following by deposit in the United States mail this lith day of March, 1986:
Samuel J. Chilk, Secretary Atomic Safety and Licensing l
Office of the Secretary Appeal Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory l Commission Commission I Washington, D.C. 20555 Washington, D.C. 20555 Nunzio J. Palladino, Atomic Safety and Licensing Chairman Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory
[ Commission commission l
Washington, D.C. 20555 Washington, D.C. 20555 Thomas M. Roberts, Philadelphia Electric Company Commissioner ATTN: Edward G. Bauer, Jr.
l U.S. Nuclear Regulatory Vice President &
Commission General Counsel Washington, D.C. 20555 2301 Market Street l
Philadelphia, PA 19101 i James K. Asselstine, Commissioner Docketing and Service Section U.S. Nuclear Regulatory Office of the Secretary l
Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 i
Frederick M. Bernthni, Commissioner U.S. Nuclear Regulatory Commission
! Washington, D.C. 20555 i
L
Ann P. Hodgdon, Esq.
Counsel for NRC Staff Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Jay M. Gutierrez, Esq.
U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 Mr. Robert L. Anthony Friends of the Earth of the Delaware Valley 106 Vernon Lane, Box 186 Moylan, Pennsylvania 19065 Robert M. Rader
i / UNITED STATES
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! o NUCLEAR REEULATCY COMMISSION usmorou e.c. osse l {'
)
\...../ woasse
/ l
Docket No. 50-352 ,A 4 RECEIVEgy ?
MS, 7 33 .
Mr. Edward G. Bauer, Jr. ( m Vice President and General Counsel - wrno,(m y
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A Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 3
gg/
Dear Mr. Bauer:
SUBJECT:
ISSUANCE OF AMEN 0 MENT NO. 2 TO FACILITY OPERATING LICENSE NO. NPF-39, LIMERICT GENERATING STATION, UNIT 1 The Nuclear Regulatory Comission has issued the enclosed Amendment No. 2 to Facility Operating License No. NPF-39 for the Limerick Generating Station Unit 1.
This amendment is in response to your letters dated December 18, 1985, January 29, February 5, February 25 and March 3, 1986. The amendment extends on a one-time-only basis the surveillance requirements in the Technical Specifications for containment isolation valves which must be performed nominally every eighteen or twenty-four months and which can be done only when the plant is shutdown. Your reason for this extension is that Limerick, Unit I has experienced an extended starten pro-gram schedule and has been shutdown for much of the first surveillance interval.
Therefore you have requested a temporary extension of twelve weeks in the sur-veillance testing to allow the testing to be performed during a maintenance and surveillance testing outage which will begin on or before May 26, 1986. A copy of the related safety evaluation supporting Amendment No. 2 to Facility Operating License NPF-39 is enclosed.
The approval of these amendments also requires a one-time exemption frem certain >
Type C local leakage rate test requirements of 10 CFR Part 50, Appendix J. In response to your letter of December 18, 1985, such a one-time exemption is being issued separately.
Sincerely, I(ll ~
Walter R. Butler, Director BWR Project Directorate No. 4 Division of BWR Licensing
Enclosures:
- 1. Amendment No. 2 to NPF-39
- 2. Safety Evaluation cc: See next page fLc ~ . ,n m ~ : w,
Mr. Edward G. Bauer, Jr Limerick Generating Station Philadelphia Electric Company Units 1 & 2 cc:
Troy 8. Conner, Jr., Esquire Mr. Marvin I. Lewis Conner and Wetterhahn 6504 Bradford Terrace 1747 Pennsylvania Ave N.W. Philadelphia, Pennsylvania 19149 Washington, D. C. 20006 Zori G. Ferkin Frank R. Rosnano, Chairman Assistant Counsel Air & Water Pollution Patrol Governor's Energy Council 61 Forest Avenue 1625 N. Frcnt Street Anbler, Pennsylvania 19002 Harrisburg, Pennsylvania 17105 Federic M. Wentz Charles W. Elliott, Esquire County Solicitor Brose & Poswistilo, 1101 Bldg.
County of Montgomery 325 N.10th Street Ccurthcuse Easton, Pennsylvania 18402 Norristown, Pennsylvania 19404 Eugene J. Bradley Ms. M. Mullicar Philadelphia Electric Ccmpany Livrerick Ecology Action Associate General Counsel 762 Queen St. .
2301 Market Street Pottstown, Pennsylvania 19464 Philadelphia, Pennsylvania 19101 Mr. Karl Abraham Thomas Gerusky, Director Public Affairs Officer Bureau cf Padiation Protection Region 1 Capt. of Enviromental Resources U.S. Nuclear Regulatory Comissicn 5th Floor Fulton Bank Bldg.
631 Park Avenue Third and Locust Streets King of Prussia, PA 19806 Harrisburg, Pennsylvania 17120 Mr. Gene Kelly Senior Resident Inspector .
U.S. Nuclear Regulatory Cortnission P. O. Box 47 Sanatoga, Pennsylvania 19464
Philadelphia Electric Company Limerick Generating Station 1/2 cc:
Sugarr.an, Denworth & Hellegers Director, Pennsylvania Emergency 16th Floor Center Plaza Management Agency 101 North Broad Street Basement. Transportation &
Philadelphia, Pennsylvania 19106 Safety Building Harrisburg, Pennsylvania 17120 Robert L. Anthony Angus Love, Esq.
Friends of the Earth 107 East Main Street of the Delaware Valley Norristcwn, Pennsylvania ?9402 l
103 Vernon Lane, Boy 186 Moylan, Pennsylvania 19065 Helen F. Hoyt, Chairman Kathryn S. Lewis, Esq. Administrative Judge i Punicipal Services Bldg. Atomic Safety & Licensing Board 15th and JFK Blvd. U.S. Nuclear Regulatory Comnission Philadelphia, Pennsylvania 19102 Washington, D. C. 20555 l David Wersan Esq. Dr. Jerry Harbour Assistant Consumer Advocate Administrative Judge Office of Consumer Advocate Atomic Safety & Licensing Board 1425 Strawberry Square U.S. Nuclear Regulatory Connission Harrisburg, Pennsylvania 17120 Washington, D. C. 2C555 Steven P. Hershey, Esq. Dr. Richard F. Cole Community Legal Services, Inc. Administrative Judge Law Center North Central - Bevry Bldg. Atomic Safety & Licensing Board 3701 North Board Street U.S. Nuclear Regulatory Commission l
Philadelphia, Pennsylvania 19140 Washington, D. C. 20555 Hr. J. T. Robb, NS-1 Mr. Spence W. Perry, Esq.
Philadelphia Electric Company Associate General Counsel 2301 Harket Street Federal Emergency Management Agency Philadelphia, Pennylsvania 19101 Room 840 500 C St., S.W.
Timothy R. S. Campbell, Director Washington, D. C. 20472 Department of Emergency Services 14 East Biddle Street West Chester, Pennsylvania 19380 l
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\e UNITEJ tTATES NUCLEAR REGULATORY COMMISSION
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3 WASHINGTON. D. C. 20see t
PHILADELPHIA ELECTRIC COMPANY DOCKET NO. 50-352 LIMERICK GENERATIhG STATION, UNIT 1 AMENCNENT TO FACILITY OPERATING LICENSE Amendment No. 2
, License No. NPF-39
- 1. The Nuclear Regulatory Comission (the Comission) has found that:
A. The application for amendment filed by the Philadelphia Electric Conpany dated December 18, 1985, cceplies with the standards ard recuirements of the Atomic Energy Act of 1954, as amended (the Act) and the Comission's regulations as set forth in 10 CFR Chapter I; B. The facility will operate in confonnity with the application, the provisicns of the Act, and the regulations of the Comission; C. There is reasonable assurance: (i) that the activities authorized by this amendment can be conducted without eridangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Comission's regulations set forth in 10 CPR Chapter I; D. The issuance of this license amendment will not be inimical to the comon defense and security or to the health and safety of the public; E. The issuance of this amendment is in accordance with 10 CFR Part 51 ;
of the Comission's regulations and all applicable requirements have been satisfied.
- 2. Accordingly, the license is amended by changes to the Technical Specifi-cations as indicated in the attachment to this amendment and Paragraph 2.C(2) of Facility Operating License No. NPF-39 is hereby amende<1 to read as follows: ,
(2) Technical Specifications The Technical Specifications contained in Appendix A and the Environ-mental Protection Plan contained in Appendix B, as revised through Amendment No. 2. are hereby incorporated in the license. FECo shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
@ b O V % 3, ;_, I
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- 3. This amendment is effective immediately and is to be fully implemented within 30 days of the date of issuance.
FOR THE NUCLEAR REGULATORY C0fEISSION Walter R. But er. Director Project Directorate No. 4 Division of BWR Licensing
Attachment:
Changes to the Technical Specifications l Date of Issuance: WAP 0 3 SRF,
,0y s
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t e ATTACHMENT TO LICENSE AMEN 0 MENT NO. 2 FACILITY OPERATING LICENSE NO. NPF-39 DOCKET NO. 50-352 Replace the following pages of the Appendix A Technical Specifications with the enclosed pages. The revised pages are identified by Amendment number an-contain vertical lines indicatirg the area of change. Also to be replaced are the following overleaf pages to the amended pages.
Amendment Pages Overleaf Pages 3/4 6-4 3/4 6-3 3/4 6-19 3/4 6-20 3/4 6-20 3/4 6-19 3/4 6-21 3/4 6-22 3/4 6-24 3/4 6-23 3/4 6-25 3/4 6-26 3/4 6-27 3/4 6-28
CONTAINMENT SYSTEMS LINITING CONDITION FOR OPERATION (Continued)
ACTION: (Continued) l
- b. The combined leakage rate for all penetrations and all valves listed in Table 3.6.3-1, except for main steam line isolation valves
- and valves which are hydrostatically tested per Table 3.6.3-1, subject to Typo 8 and C tests to less than or equal to 0.60 L,, and
- c. The leakage rate to less than or equal to 11.5 scf per hour for any one main steam line through the isolation valves, and
- d. The combined leakage rate for all containment isolation valves in hydrostatically tested Ifnes which pentrate the primary containment to less than or equal to 1 gpm times the total number of such valves, prior to increasing reactor coolant system temperature above 200*F.
SURVEILLANCE REQUIREMENTS
- 4. 6.1. 2 The primary containment leakage rates shall be demonstrated at the following test schedule and shall be determined in conformance with the criteria specified in Appendix J of 10 CFR Part 50 using the methods and provisions of ANSI 45.4-1972 and BN-TOP-1 and verifying the result by the Mass Point Methodology described in ANSI N56.8-1981:
- a. Three Type A Overall Integrated Containment Leakage Rate tests shall be conducted at 40 1 10 month intervals during shutdown at P,, 44.0 psig, during each 10 year service period. The third test of each set shall be conducted during the shutdown for the 10 year plant inservice inspection.
b.
If any periodic Type A test fails to meet 0.75 L,, the test schedule for subsequent Type A tests shall be reviewed and approved by the Commission.
If two consecutive Type A tests fail to meet 0.75 L,,
a Type A test shall be performed at least every 18 months until two consecutive Type A tests meet 0.75 L,, at WPich time the above test schedule may be resumed.
- c. The accuracy of each Type A test shall be verified by a supplemental test which:
- 1. Confirms the accuracy of the test by verifying that the difference between the supplemental data and the Type A test data is within 0.25 L,. The formula to be used is: (L, + L,, - 0.25 L,] 5 L e
< (L, + L,, + 0.25 L,] where Le = supplemental test result; L, =
superimposed leakage; L,,= measured Type A leakage.
- 2. Has duration sufficient to establish accurately the change in leakage rate between the Type A test and the supplemental test.
- 3. Requires the quantity of gas injected into the containment or bled from the containment during the supplemental test to be between 0.75 L,and 1.25 L,.
- Exemption to Appendix "J" to 10 CFR Part 50.
LIMERICK - UNIT 1 3/4 6-3
CONTAINMENT'3YSTEMS -
SURVEILLANCE REQUIREMENTS (Continued) d.
Type B and C tests shall be conducted with gas at P,, 44.0 psig*,
at intervals no greater than 24 months"* except for tests involving: l
- 1. Air locks, 2.- Main steam ifne isolation valves,
- 3. Containment isolation valves in hydrostatically tested lines which penetrate the primary containment, and
- e. Air locks shall be tested and demonstrated OPERABLE per Surveillance Requirement 4.6.1.3.
f.
Main per 18steam months.line isolation valves shall be leak tested at least once
- g. Containment isolation valves in hydrostatically testod lines which penetrate the primary containment shall be leak tested at least once per 18 months.**
I
- h. The provisions of Specification 4.0.2 are not appifcable to Specifica-tions 4.6.1.2a., 4.6.1.2b., 4.6.1.2c., 4.6.1.2d., and 4.6.1.2e.
- Unless a hydrostatic test is required per Table 3.6.3-1.
- A Type C test interval extension to May 26, 1986 is permissible for primary containment isolation valves identified by an asterisk in the inboard and
' outboard isolation barrier columns of Table 3.6.3-1, Part A, as discussed in Application for Amendment of Facility Operating License dated December 18, 1985.
LIMERICK - UNIT 1 3/4 6-4 Amendment No. 2
TABLE 3.6.3-1 PART A - PRIMARY CONTAIMENT ISOLATION VALVES M INBOARD OUTBOARD ISOL.
- PENETRATION FUNCTION ISOLATION ISOLATION MAX.ISOL. SIGNAL (S),
' NOTES P&ID NtseER BARRIER BARRIER TIME.IF APP. IF APP.
E (SEC)(26) (20)
U s 0038 CONTAINMENT INSTRUMENT 59-10058 (CK) NA 59 GAS SUPPLY - HEADER 'B' HV59-1298 7 C,H,5 0030-2 CONTAINMENT INSTRUMENT 59-1112*(CK) NA GAS SUPPLY TO ADS VALVES HV59-151B* 45 M 59 E&K 007A(8,C,D) MAIN STEAM LINE HV41-1F022A 5* C,0,E,F,P,Q 6 41
'A'(B,C,0) (B,C,0)
HV41-1F028A 5* C,0,E,F,P,Q 6 w (8,C,D)
> HV40-1F0018 45 EA 6 m (F,K,P) 4
- (XV40-1018 NA 6,1 (F,K,P)
SEE PART 8, THIS TABLE) 008 MAIN STEAM LINE DRAIN HV41-1F016 30 C,0,E,F,P,Q 4 41 HV41-1F019 30 C,0,E,F,P,Q 009A FEEDWATER 41-1F010A(CK) NA 41 HV41-1F074A(CK) NA
> 41-1036A(CK) NA 4 HV41-1308 45 E HV41-133A 45 4 HV41-109A NA 32 4 HV41-1F032A(CK) NA
= HV55-1F105 30 7 P HV44-1F039(CK) NA m
(X-98) 41-1016(X-98, NA 31 X-44)
r_ ._____- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - - _ _ _ _ _ _ _ _ _ - _ _ _ _
TABLE 3.6.3-1 (Continued)
C g PART A - PRINARY CONTAINNENT ISOLATION VALVES 5
n IN80ARD OUT8OARD ISOL.
7 PENETRATION FUNCTION ISOLATION ISOLATION MAX.ISOL. SIGNAL (S), NOTES P&ID e NUMER BARRIER BARRIER TIME.IF APP. IF APP.
3
-i (SEC)(26) (20) w 0098 FEEDWATER 41-1F0108(CK) NA HV41-1F0748(CK) NA 41 41-1036B(CK) NA HV41-130A 45 HV41-1338 45 HV41-1098 NA 32 HV41-1F0328(CK) NA HV49-1F013 23 LFCC HV44-If039(CK) NA (X-9A)
R 41-1016(X-9A, NA 31 X-44)
T g 010 RCIC STEAM SUPPLY HV49-1F007 7.2* K, KA 5 49 HV49-1F008 7.2* K, KA HV49-1F076 45 K, KA 011 HPCI STEAM SUPPLY HV55-1F002 12* L, LA 5 55 HV55-1F003 12* L, LA HV55-1F100 45 L, LA F 012 RHR SHUTDOWN COOLING HV51-1F009 100 A,V 9,22 51 3 SUPPLY PSV51-155 NA
& HV51-1F008 100 A,V 3
" 013A(8) RHR SHUTDOWN COOLING HV51-1F050A*(8*) NA AV 9,22 51 RETURN (CK)
" HV51-151A*(8*) 20 A,V HV51-1F015A(8) 45 A,V 014 RWCU - SUCTION HV44-1F001* 10* 8,J,Y 44 HV44-1F004* 10* 8,J,Y i
e -
TABLE 3.6.3-1 (Continued)
PART A - PRIMARY CONTAI MENT ISOLATION VALVES h IN80ARO OUTBOARD ISOL.
- PENETRATION FUNCTION ISOLATION ISOLATION MAX.ISOL. SIGNAL (S),
' NOTES P&IO Nt#SER BARRIER BARRIER TIME.IF APP. IF APP.
t 3 (SEC)(26) (20)
M g 016A CORE SPRAY INJECTION HV52-1F006A(CK) NA 9,22 52 HV52-1F039A 7 9,22 HV52-1F005 18 l 0168 CORE SPRAY INJECTION HV52-1F006B(CK) NA 9,22 52
{ HV52-1F0398 7 9,22 HV52-108(CK) NA I 017 RPV HEAD SPRAY HV51-1F022 60 A,V 4,9,22 51 1
PSV51-122 NA 9,22 I w HV51-1F023 135 AV k
. 021 SERVICE AIR TO DRYWELL 15-1140 NA 15 4s-*
15-1139 NA 022 DRYWELL PRESSURE HV42-147C 45 10 42 INSTRUMENTATION j 023 RECW SUPPLY TO HV13-106* 40 11,28, 13 l i RECIRC PUMPS 29 l HV13-108* 30 11,28 l 29
] , HV13-109* NA 11,13 l 024 RECW RETURN FROM HV13-107* 40 11,28, 13 l l g RECIRC PUMPS 29 s HV13-111* 30 11,28, l 29 F HV13-110* NA 11,13 l I
TABLE 3.6.3-1 (Continued)
PART A - PRIMARY CONTAINMENT ISOLATION VALVES M IN8OARD OUTBOARD ISOL.
- PENETRATION FUNCTION ISOLATION ISOLATION MAX.ISOL. SIGNAL (S), NOTES P&ID
' NUMBER BARRIER BARRIER TIME.IF APP. IF APP.
E (SEC)(26) (20)
M' s 025 DRYWELL PURGE SUPPLY HV57-121(X-201A) 5** 8,H,S,U,W 3,11,14,25 57 HV57-123 5** 8,H,S,U,W 3,11,14,25 HV57-163 9 B,H,R,S 3,11,14 HV57-109 6** 8,H,S,U,W 11,25 (X-201A)
HV57-131 5** 8,H,S,U,W 11,25 (X-201A)
HV57-135 6** D H,5,U,W 11,25 026 DRYWELL PURGE EXHAUST HV57-114 5** 8,H,5,U,W 3.11,14,25 57 w HV57-111 15** 8,H,S,U
) 5,11,25 HV57-161 9 8,H,R,5 3,11,14
. an SV57-139 5 10 4
" HV57-115 6** 8,H,5,U,W 11,25 HV57-117 5** 8,H,S,U 11,25 SV57-145 5 8,H,R,5 11 027A CONTAINMENT INSTRUMENT 59-1128(CK) NA 59 GAS SUPPLY TO ADS VALVES HV59-151A 45 M.
H,M,&S 028A-1 RECIRC LOOP SAMPLE HV43-1F019 10 8,D 43 HV43-1F020 10 8,D 028A-2 DRYWELL H2/02 SAMPLE SV57-132 5 8,H,R,5 11 57 SV57-142 5 8,H,R,5 11 028A-3 DRYWELL H2/02 SAMPLE SV57-134 5 8,H,R,5 11 57 SV57-144 5 8,H,R,5 11
TABLE 3.6.3-1 (Continued) f PART A - PRIMARY CONTAINMENT ISOLATION VALVES hk INBOARD OUTBOARD ISOL.
PENETRATION FUNCTION ISOLATION ISOLATION MAX.ISOL. SIGNAL (S), NOTES P&ID NUMBER BARRIER BARRIER TIME.IF APP. IF APP.
Ei (SEC)(26) (20)
M 0288 DRYWELL H2/02 SAMPLE SV57-133 5 B,H,R,5 11 57 SV57-143 5 B,H,R,5 11 SV57-195 5 B,H,R,5 11 0308-1 DRYWELL PRESSURE HV42-147A 45 , 10 42 INSTRUMENTATION 035A TIP PURGE 59-1056(CK) NA 59 (DOUBLE "0" RING)
HV59-131 7 B,H,5 16
$$035C-G TIP DRIVES XV59-141A-E NA B,H 11,16,21 59 o,
' (DOUBLE "0" RING)
- 3 XV59-140A-E NA 11,16 037A-D CR0 INSERT LINES BALL CHECK NA 12 47 HCU NA 12 038A-D CRD WITHDRAW LINES HCU NA 12 47
- SDV VENTS & DRAINS XV47-1F010 25 30 XV47-1F180 30 30 XV47-1F011 25 30 XV47-1F181 30 30 039A(B) DRYWELL SPRAY HV51-1F021A(B) 160 4,11 51 4
HV51-1F016A(B) 160 11 040E DRYWELL PRESSURE HV42-147D 45 10 42 INSTRUMENTATION 040F-2 CONTAINMENT INSTRUMENT HV59-101 45 C,H,5 5 59 GAS -SUCTION HV59-102 7 C,H,5
TA8LE 3.6.3-1 (Continued)
C - - - , . .
PART A - PRIMARY CONTAlletENT ISOLATION VALVES R
5 INBOARD QUT80ARD ISOL.
E PENETRATION FUNCTION ISOLATION ISOLATION MAX.ISOL. SIGNAL (S), NOTES P&ID e NUMER . BARRIER BARRIER TIME.IF APP. IF APP.
g (SEC)(26) (20)
~
"" 040G-1 ILRT DATA ACQUISITION 60-1057 NA 5,11 60 60-1058 NA 11 u
040G-2 ILRT DATA ACQUISITION 60-1071 NA 5,11 60 60-1070 NA 11 040H-1 CONTAINMENT INSTRUMENT 59-1005A(CK) NA 59 GAS SUPPLY - HEADER 'A' HV59-129A 7 C.H.S 042 STAND 8Y LIQUID CONTROL 48-1F007(CK) NA 48
, (X-116) HV48-1F006A 60 29 0438 MAIN STEAM SAMPLE HV41-1F084 10 8,0 41
,i HV41-1F085 10 8,0 044 RWCU ALTERNATE 41-1017 NA 5,31 41 RETURN 41-1016(X-9A, NA X-98)
PSV41-112 NA 045A(8,C,0) LPCI INJECTION 'A'(8,C,D) HV51-1F041A*(8,C', NA 9,22 g- D*)(CK) g HV51-142A*(8,C*, 7 9,22 g D*)
3 HV51-1F017A* 38 r+ (8,C",0*)
E 050A-1 DRYWELL PRESSURE HV42-1478 45 10 42 N INSTRUMENTATION 053 DRYWELL CHILLED WATER HV87-128* 60 C.H 11 87
$UPPLY - LOOP 'A' HV87-120A* 60 11,28, 29 HV87-125A* 60 11,28,29
TABLE 3.6.3-1 (Continued)
PART A - PRIMARY CONTAINMENT ISOLATION VALVES M INBOARD OUTBOARD ISOL.
PENETRATION FUNCTION ISOLATION ISOLATION MAX.ISOL. SIGNAL (S), NOTES P&ID
' NtseER BARRIER BARRIER TIME.IF APP. IF APP.
E
~ (SEC)(26) (20)
-4 s 054 DRYWELL CHILLED WATER HV87-129* 60 CH 11 87 RETURN - LOOP 'A' HV87-121A* 60 11,28, 29 HV87-124A* 60 11,28, 29 055 DRYWELL CHILLED WATER HV87-122* 60 CH 11 87
$UPPLY - LOOP 'B' HV87-1208* 60 11,28, 29 HV87-1258* 60 -11,28,29
$056 DRYWELL CHILLED WATER HV87-123* 60 C,H 11 87
. RETURN - LOOP 'B' HV87-1218* 60 11,28,29 g HV87-1248* 60 11,28,29 061-1 RECIRC PUMP 'A' SEAL 43-1004A(CK) NA '
15 43 PURGE (XV43-103A - NA 1 SEE PART B.
THIS TABLE) 061-2 RECIRC PUMP 'B' SEAL 43-10048*(CK) NA 15 43 g PURGE (XV43-1038 - NA 1 3 SEE PART B, g THIS TABLE) 5 062 DRYWELL H2/02 SAMPLE SV57-150(X-220A) 5 8,H,R,5 11 57 g RETURN, N2 MAKE-UP SV57-159 5 8,H,R,5 11
" (X-220A)
HV57-116 30** 8,H,R,5 11 (X-220A)
SV57-190 5 8,H,R,5 11 (X-220A)
TABLE 3.6.3-1 (Continued)
PART A - PRIMARY CONTAIMENT ISOLATION VALVES
$ IN8OARD OUTBOARD ISOL.
- PENETRATION FUNCTION ISOLATION ISOLATION MAX.ISOL. SIGNAL (S), NOTES P&ID
' NUISER BARRIER BARRIER TIME.IF APP. IF APP.
E (SEC)(26) (20)
Z s SV57-191 5 8,H,R,S 11 (X-220A) 116 STANDBY LIQUID CONTROL 48-1F007(CK) NA 48 (X-42) HV48-1F0068 60 29 1178-1 DRYWELL RADIATION SV26-190A 5 8,H,R,5 11 26 MONITORING SUPPLY SV26-1908 5 8,H,R,5 11 i
1178-2 DRYWELL RADIATION SV26-190C 5 8,H,R,5 11 26 MONITORING RETURN SV26-1900 5 8,H,R,5 11 i e 201A SUPPRESSION POOL PURGE HV57-124 5** 8,H,S,U,W 3,11,14,25 57
.4 '*
SUPPLY HV57-131(X-25) 5** 8,H,S,U,W 3,11,14,25 HV57-164 9 8,H,R,5 3.11,14 HV57-109(X-25) 6** 8,H,5,U,W 11,25 HV57-147 6** 8,H,5,U,W 11,25 HV57-121(X-25) 5** 8,H,5,U,W 11,25 202 SUPPRESSION POOL PURGE HV57-104 5** 8,H,5,U,W 3,11,14,25 57 EXHAUST HV57-105 15** 8,H,S,0 5,11,25 HV57-162 9 B,H,R,5 3,11,14 HV57-112 6** 8,H,5,U,W 11,25 HV57-118 5** 8,H,S,0 11,25 l SV57-185 5 8,H,R,5 11 203A(8,C,D) RHR PUMP SUCTION HV51-1F004A(8, 240 4,22, 51 C,D) 19,29 PSV51-1F030A(8, NA 22 C,0)
TABLE 3.6.3-1 (Continued)
PART A - PRIMARY CONTAINMENT ISOLATION VALVES
$ IN80ARO OUTBOARO ISOL.
- PENETRATION FUNCTION ISOLATION ISOLATION MAX.ISOL. SIGNAL (S), NOTES P&ID
' NUfeER BARRIER BARRIER TIME.IF APP.
g IF APP.
~ (SEC)(26) (20)
[204A(B) RHR PUMP TEST LINE AND HV51-125A(8) 180 4,22,29 51 CONTAIMIENT COOLING 205A(8) SUPPRESSION POOL SPRAY HV51-1F027A*(B) 45 C,G 11 51 206A(8,C,0) CS PUMP SUCTION HV52-1F001A 160 4,22,29 52 (8,C,0) 207A(B) CS PUMP TEST AND FLUSH HV52-1F015A(B) 23 C,G 5,22 52 w 2088 CS PUMP MINIMUM RECIRC HV52-1F0318 45 LFCH 5,22,29 52
[ 209 HPCI PUMP SUCTION HV55-1F042 160 L,LA 4,22 55 210 HPCI TURBINE EXHAUST HV55-If072 120 4,22,29 55 212 HPCI PUMP TEST AND FLUSH HV55-1F071 40 B,H 4,22 55 214 RCIC PUMP SUCTION HV49-1F031 60 4,22,29 49 215 RCIC TUR8INE EXHAUST HV49-1F060 80 4,22,29 49 216 RCIC MINIMUM FLOW HV49-1F019 8 LFRC 5,22 49 1
' N s
I
, .F N
TABLE 3.6.3-1 (Continued)
PART A - PRIMARY CONTAIMENT ISOLATION VALVES IN80ARO OUT80ARO ISOL.
- PENETRATION FUNCTION ISOLATION ISOLATION MAX.ISOL. SIGNAL (S),
' NUMER NOTES P&IO BARRIER BARRIER TIME.IF APP. IF APP.
E (SEC)(26) (20)
M 217 RCIC VACUUM PUMP DISCH HV49-1F002 60 5,29 49 49-IF028(CK) NA 218 INSTRUMENT GAS TO 59-1001(CK) NA 59 VACUUM RELIEF VALVES HV59-135 7 C,H,5 219A INSTRUMENTATION - --
HV55-121 45 10 55 SUPPRESSION POOL LEVEL w 2198 INSTRUMENTATION - --
HV55-120 45 10 55
) SUPPRESSION P0OL
,, LEVEL 220A H2/02 SAMPLE RETURN SV57-191(X-62) 5 8,H.R,5 11 57 SV57-190(X-62) 5 8,H,R,5 11 HV57-116(X-62) 30** 8,H,R,5 11 SV57-150(X-62) 5 8,H,R,5 11 SV57-159(X-62) 5 8,H,R,5 11 l
2208 INSTRUMENTATION - --
SV57-101 5 10 57 SUPPRESSION POOL PRESSURE SUPPRESSION POOL LEVEL 221A WETWELL H2/02 SAMPLE SV57-181 5 8,H,R,5 11 57 i
SV57-141 5 8,H,R,5 11 SV57-184 5 8,H.R,5 11 2218 WETWELL H2/02 SAMPLE SV57-183 5 8,H R ' 57 SV57-186 5 . . . 11
UNITED STATES g NUCLEAR REGULATORY COMMISSION 8 .
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR R SUPPORTAMENDMENTNO.2TOFACILITYOPERATINGLICENSENO.NPF-g PHILADELPHIA ELECTRIC COMPANY LIMERICK GENERATING STATION. UNIT NO. I DOCKET NO. 50-352 1.0 Introduction 18, 1985, the Philadelphia Electric Company (the By letter dated December licensee) requested a one-time-only approval to temporarily extend certa surveillance requirements in the Technical Specifications, h which the must be performed nominally every 18 or 24 months and The change would extend the 18 or 24 month surveillance which can only be done plant is shutdown.
intervals for leakage testing of selected containmentThis isolation would d
valves by 12 weeks beyond the time allowed 26, 1986.by the Technical surveillance outage which will begin on or before May By letters dated January 29, February 5, February 25, and March 3 licensee provided additional information in support of the proposed change Technical Specification (TS) 4.6.1.2.d requires that Type C tests shall b ducted at intervals no greater than 24 months except for tests in in hydrostatically tested ifnes.
is consistent with the requirements 18, 1985 of 10foranCFR requested a
Par The licensee's letter of December greater than 2 years. extension In addition,ofinthe 24 month18,TS the December testing 1985 letter the requiremen group of 27 isolation valves.
licensee requested a one-time exemption from the Appendix J 24 requirements for these 27 valves. .
separate Safety Evaluation dated March 3, 1986.
Technical Specification 4.6.1.2.g requires18,that The licensee's letter of December 1985 local le tested at least once per 18 months. requested an extension of *his of 12 weeks for a group of 10 isolation valves. .
1 2.0 Evaluation Since the Limerick Unit 1 plant has been through an extended startup p schedule, which included relatively little startup testing program about April to early August 1985, the scheduled surveillance tests fa period operations.
of what would otherwise be a continuation before of firs these tests and since the licensee plans to shut the plant down on or May 26, 1986 to perfom other surve111arce tests and maintenance l i activities the licensee proposes to extend the surveillance interval for these
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2-valves to allow those tests to also be performed during the outage to begin on or before May 26, 1986.
The 18 and 24 month surveillance intervals were selected to provide flexibility in scheduling these tests for execution during refueling outages. Technical Specification 4.0.2 does allow the 18 month TS interval between surveillance testing to be extended by 25 per:ent in order to provide flexibility in operations scheduling. The end of the most limiting surveillance interval, considering the 24 month limit and the 18 month limit extended by the allowable 25 percent, is March 3, 1986.
The requirements of the TS for testing nominally every 18 or 24 months for which extensions are proposed and the reason these tests can only be performed while the reactor is shutdown are as follows.
General Design Criterion 56, Primary Containment Isolation, requires that lines to be isolated be provided with an isolation valve inside containment and an isolation valve outside containment. The design of the isolation valves and their associated piping and test connections requires personnel access to the primary containment to isolate the valve inside the containment from the balance of its associated system and to implement the test procedure.
Entry into containment during power operations would expose personnel to the nazards of high air temperature (about 120*F), radiation exposure that is high with respect to as-low-as-reasonably-achievable (ALARA) standards (about 10 R/ hour in representative areas) and the nitrogen environment of the inerted containment atmosphere for which self contained breathing apparatus (SCUBA) would be required. The licensee has stated orally that they consider the hazard of the inerted containment atmosphere to be too great to perinit personnel access for routine plant operational tasks. The Itcensee has also stated that further factors which preclude testing these valves at power include the need to depressurize the reactor, drain the reactor enclosure chilled water (RECW) system, drain the drywell chilled water (DCW) system, drain the emergency service water (ESW) loop, remove the reactor recirculation pumps from service or a combination of the above. The staff concludes that the licensee has shown that it is not practical or feasible to test these valves at power and that the plant would be required to shutdown for about *wo weeks to cooldown, depressurize and conduct the tests beginning on March 3, 1986 unless the requested extension in surveillance test periods is granted.
The licensee has stated that the types of valves subject to this surveillance schedule extension request have traditionally good maintenance histories and do not include those valves known to be maintenance intensive in boiling water reactors such as the main steam isolation valves or the feedwater check valves.
The licensee also points out that these valves are used in applications where they are either normally open or norinally closed and are not used in a modulating mode to control flow rates. The licensee further states that such valves when
, used in non-modulating applications tend not to have problems meeting leakage criteria. In this regard, the licensee has also considered the leak rate information reported in Licensee Event Report (LER) No. 352/85-102. This LER deals with a valve that is not within the scope of the Limerick surveillance schedule extension request. The licensee has reached a deterinination, with which the staff concurrs, that the LER 85-102 event was an isolated event and as such has no significant effect upon the conclusions and basis for the request for extension.
In support of the position that these valves are reliable in meeting leakage criteria the licensee has interrogated the Nuclear Plant Reliability Data System (NPRDS) for similar types of valves and has reviewed these specific valves' previous leakrate test histories.
The NPRDS query serves as a useful qualitative estimation of these valves' reliability since the reporting of data to the system is on a voluntary basis and therefore there is no representation that the data from the system repre-sents all of the valves in the industry of that specific valve type. Never-theless, the data as presented in the licensee's letter dated January 29, 1986, is useful in considering whether these valve types are generally reliable in meeting their leakage criteria. The licensee notes that the valves in the NPRDS data base have been in service for significant periods whereas the Limerick valves will have experienced only a part of the first fuel cycle's operating time by the date of the next planned surveillance test. The NPRDS data does not suggest that these valves, either individually or collectively, should be expected to experience undue difficulties in meeting the leakage criteria.
N e licensee states that testing has been performed on those valves that can be tested at power such that only 37 valves out of a total of 245 valves in Part A of TS Table 3.6.3-1 require the one-time extension of the surveillance interval.
This is reflected in the following specific system discussions wherein, as applicable, it is noted that the extension request does not apply to all of the valves in a given system since the other valves have been tested on a more recent schedule which does not require their retest until after May 26, 1986.
Technical Specification 4.6.1.2.d-Twenty-Four Mnnth Tests There are 27 valves subject to this specification for which the licensee has requested one time extension of no more than 12 weeks in the surveillance test schedule. These valves are as listed below.
System Valve Number Size / Type
- LPCI injection loops HV-51-1F017A.C,0 12" gate A.C.D
' Suppression Pool Spray HV-51-1F027A 6" globe
- Reactor enclosure cooling water
- supply line HV-13-106,108.109 3d and 4" gate
- return line HV-13-107.110,111 3" and 4" gate
- Drywell Chilled Water, Loops A and 8
- Supply lines HV-87-120A, 125A, 128 8" gate and 1208, 1258, 122
- Return lines HV-87-121A, 124A, 129 8" gate and 1218, 1248, 123
- Reactor Water Cleanup HV-44-1F001, IF004 6" globe supply line
Technical Specification 4.6.1.2.d-Twenty-Four Month Tests (cont'd.)
System Valve Number Size / Type
- Recirculation Pump B seal 43-10048 1" check purge
- Instrument Gas Supply to HV-59-1518 1" globe ads valves E and K 59-1112 1" check The ifcensee's letter of January 29, 1986 also provides information on the previous leakage testing for the specific valves which are subject to this amendment request. As indicated in the licensee's letters the total leakage measured as a result of the previous tests on all applicable Type C valve tests is about 22,000 standard cubic centimeters per minute (SCCM) which is about 23%
of the total allowed by the Technical Specifications. Of this 22,000. SCCM only about 3800. SCCM (or 4% of the TS limit) was contributed by the 27 valves subject to the amendment application. Thus, it may be seen that leakage through these valves would have to increase many times before they contributed a large portion of either (1) the total measured leakage from all such valves or (2) the TS limit value. Some discussion of the individual valves is provided below.
LPCI Injection Valves HV51-IF017A, C and D require an extension of less than 10 weeks in a 24 month surveillance interval. The comparable valve in the B loop was tested on a schedule which does not require its retest until after May 26, 1986. The leakage from these three valves during the previous tests totaled 1210 SCCM or 1% of the TS Ifmit valve. The line in which these valves are located is pro-vided with instrumentation which will detect and annunciate excessive leakage past the valves.
Suppression Pool Spray Valve HV-51-1F027A requires an extension of about 8 weeks in a 24 month sur-veillance interval. The comparable valve in the B loop of suppression pool spray was tested on a schedule which does not require its retest until after May 26, 1986. The leakage from this valve during the previous test was 2.25 SCCM or 0.002% of the TS limit valve.
Reactor Enclosure Cooling Water (RECW)
Valves HV-13-106, 108, 109 in the RECW supply line and HV-13-107, 110, 111 in the RECW return line require an extension of 12 weeks in a 24 month surveillance interval. The leakage from these valves during the previous tests was 145 SCCM or 0.15% of the TS limit for the supply valves and 9 SCCM or 0.01% of the TS limit for the return valves.
1 Drywell Chilled Water i The valves in loops A and B of the drywell chilled water system, each loop having 3 involved valves in the supply line and 3 involved valves in the return line, require an extension of up to 12 weeks in a 24 month surveillance inter- l val. The leakage from these valves during the initial tests was 203 SCCM for i loop A supply valves, 653 SCCM for loop A return valves, 668 SCCM for loop B supply valves and 338 SCCM for loop B return valves for a total of 1862 SCCM or 25 of the TS limit. {
t Reactor Water Cleanup i Valves HV-44-1F001,1F004 in the RWCU supply line require an extension of less than 10 weeks in a 24 month surveillance interval. The leakage from these valves from previous tests was 510 SCCM or 0.5% of the TS limit value. ,
Recirculation Pumo B Seal Purge Valve 43-1004B in the reactor recirculation pump seal purge line requires an extension of 3 weeks in a 24 month surveillance interval. The comparable valve in the A loop line was tested on a schedule which does not require its retest until after May 26, 1986. The leakage from this valve from previous ,
tests was 76 SCCM or 0.1% of the TS limit value. '
Instrument Gas Supply to ADS Valves i Valves HV-59-1518 and 59-1112 in the instrument gas supply to automatic depressurization system (ADS) valves E and K require an extension of less than 2 weeks in a 24 month surveillance interval. Comparable valves in the gas supply line for ADS valves H. M and 5 and other instrument gas supply and return Ifnes were tested on a schedule which does not require retest until after May 26, 1986. The leakage from these valves during the previous tests '
was 9 SCCM or 0.01% of the TS limit value.
Summary for 24 Month Surveillance Interval Valves In assessing whether an extension of 12 weeks in a 24 month surveillance interval would be appropriate for these valves the staff has considered the previous leak rate test results for these valves, their propensity for requiring extensive l maintenance to maintain their leak tight integrity and the consequences of any f additional degradation during the requested extension. Based on its review the staff finds that:
(1) The previously measured Type C test leakage through these valves (3800 SCCM) constituted but 17% of the total measured Type C leakage. There is con- "
siderable margin between these values and the limit established by Appendix Jand and the technical specification of 0.6 LThesevalveswerenotfoundto(94,964SCC C tests. contribute either individually or collectively a disproportionate percentage of the total measured leakage or of the technical specification limit values.
(2) To date these valves have not required maintenance, repairs or adjust-ments which would require reperfo:wance of their Type C test. The Ifcensee's review of similar valves via NPRDS provides a qualitative assessment that supports the licensee's findings that these valves typically have good maintenance histories, do not require intensive maintenance to ensure their leak tight integrity and thus are unlikely to degrade significantly in the period of the extension.
(3) There is ample margin between the leakage previously measured during the Type C isolation valve tests, including the previous tests of the 27 valves subject to this amendment request, and the Ifmiting leakage values in the technical specifications and in Appendix J to accommodate any degradation likely to be experienced by these 27 valves during the extension period.
Therefore the consequences of leakage past these isolation valves is bounded by safety analyses previously performed which were based on the limiting leakage values in the technical specifications and in Appendix J.
The licensee has determined that the proposed changes will have little or no effect on containment integrity and that the proposed amendment will not alter any of the accident analyses. The staff has reviewed these determinations and the associated changes and concludes that, on the bases discussed above, they are acceptable.
Technical Specification 4.6.1.2.0 - Eighteen Month Tests There are 10 valves subject to this specification for which the licensee has requested a one time extension of no more than 10 weeks in the surveillance test schedule. Considering the 25% extension in the nominal 18 month period also provided for in the Technical Specifica'tions these tests would be extended from about 22.5 months to 25 months. These valves are as listed below:
- Shutdown Cooling HV-51-1F050A, 8 12"Chk- O Return Loop A and B Ifnes HV-51-151A, B 1.5" Globe
- Low Pressure Coolant HV-51-1F041A, C, D 12" Check Injection Loop A, C and D HV-51-142A, C, D 1.5" Globe lines Shutdown Cooling Return The extension request for the isolation valves in the shutdown cooling return
' lines apply only to the inboard valves since the outboard (outside containment) isolation valves were tested on a schedule which does not require their retest until after May 26, 1986. These lines are equipped with instrumentation which will annunciate leakage past the isolation valves to the operator. The leakage throu (gpm)gh these for the valves loop during A valves andthe no initial leak leakage measured tests was for0.1 thegallons per minute loop B valves, well below the limit of 1.0gpm imposed by the Technica Specifications.
.- = . . - . _ . - - - - - _-- --
7-Low Pressure Coolant Infection The extension request for these isolation valves in the low pressure coolant injection lines applies to the A, C and D loop valves since the B loop valves were tested on a schedule which does not require their retest until after May 26, 1986. These lines are equipped with instrumentation which will annunciate leakage past the isolation valves to the operator. The leakage through these valves during the initial leak tests was 0.2 gpm for the A loop, 0.002 gpm for the C Toop, and 0.09 gpm for the D loop, all of which are well below the limit of 1.0gpm imposed by the Technical Specifications.
Sununary for Eighteen Month Surveillance Interval Valves In assessing whether an extension of 10 weeks in the 18 month surveillance interval, as extended by 25%, would be appropriate for these valves the staff has considered the previous leak rate test results for these valves, their propensity for requiring extensive maintenance to maintain their leak tight integrity and the consequences of any additional degradation during the requested extension. Based on its review the staff finds that:
4 i
(1) The previously measured leakage for these valves (0.1 gallons per minute (gpm) maximum for any 1 valve) is well below the technical specification l' limit of 1 gpm for any 1 valve. Thus, ample margin exists between the previously measured leakage and the TS limiting value to accommodate any i
degradation likely to be experienced during the extension period.
i
- (2 The lines in which these valves are located are provided with instrumenta-tion which will detect and annunciate excessive leakage past these valves.
(3) The Ifnes in which these valves are located are connected to closed systems outside of containment. Leakage out of those systems would be into the reactor enclosure thus facilitating collection and treatment.
(4) The licensee's review of NPROS data for similar valves provides a qualita- '
tive assessment that supports the licensee's findings that leakge rate test experience with these valves has been excellent.
The licensee has deterinined that these changes have little safety significance
- and that the proposed amendment will not alter any of the accident analyses. !
The staff has reviewed these determinations and the associated changes and j concludes, on the bases stated above, that they are acceptable.
3.0 Environmental Consideration This amendment changes some surveillance requirements on a one-time-only basis.
The staff has determined that the amendment involves no significant increase in
- the amounts, and no significant change in the types, of any effluents that may be released offsite and that there is no significant increase in individual or
- , cumulative occupational radiation exposure. The Conunission has previously 4
issued a proposed finding that this amendment involves no significant hazards
- consideration and there has been no public consnent on such finding within the
s time provided by the Federal Register notice of consideration of the licensee's amendment request. Thus, there is no need to make a final determination regarding no significant hazards consideration. Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b) no environtrental impact statement nor environmental assessment need be prepared in connection with the issuance of this amendment.
However a related exemption from Appendix J to 10 CFR Part 50 is being processed relative to this action and a Notice of Environmental Assessment and Finding of No Significant Impact has been processed relative to the Exemption. This Notice of Environmental Assessment and Finding of No Significant Impact was published in the Federal Register on March 3, 1986 (51 FR 7344).
4.0 Conclusion The staff has concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the will not be endangered by operation in the proposed manner, and (2) public such activities will be conducted in compliance with the Comission's regulations and the issuance of this amendment will not be inimical to the common defense and security nor to the health and safety of the public.
Principal Contributors: R. E. Martin, S. Kucharski, J. S. Guo, J. Kudrick Dated: MAR 0 3 ME
Y
_/ p l' PHILADELPHIA ELECTRIC COMPANY /k ,,.
2301 MARKET STREET 6y'.f P.O. BOX 8699 rO. ~
-r PHILADELPHIA. PA.19101 , ,
- ^"**'^"'"'"- t2isi e4 a.4ooo /1
........... . . A EueEME J. GR AOLEY OON ALD SLAMMEN RUOOLPH A. CHILLEMS
, E. C. MIR M M A LL
- v. M. M AMER CORNELL PAUL AUERSACM g8'
...e.v..e...... . ...,
EDW ARO J. CULLEM. JR.
TMOM AS M. MILLER. JR.
IR ENE A. M.N ENN A Hr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Coamission '
Washington, D.C. 20555 Re: Limerick Generating Station, Unit 1 Docket No. 50-352
Dear Mr. Denton:
Transmitted herewith for filing with the Commission are 3 originals and 19 copies of Philadelphia Electric Company's Application for Amendment of Facility Operating License NPF-39 and Exemstion to Part 50, Appendix J. This Application seeks a 14 week extension in the allowable interval for conducting certain Type C leak rate tests.
There are also transmitted herewith for filing 3 originals and 19 co)ies of an Application for Amendment of Facility Operating License NPF-39 whici requests an extension of the allowable interval for testing certain reactor instrumentation line excess flow check valves.
In accordance with Section 170.12 of the Commission's regulations, there are enclosed Philadel ? hia Electric Company's checks totalling $300 to cover the filing fees for t use Applications.
Very truly yours, w q
' > r Eugene J. Aradley EJB:pke Enclosures cc: See Attached Service List 0137q e '
Gi ) ii m w w o 1, n i; lv a v
V F* 8 g ,
cc: Troy B. Conner, Jr., Esq. (w/ enclosure)
Ann P. Hodgdon, Esq. (w/ enclosure)
Mr. Frank R. Romano (w/ enclosure)
Mr. Robert L. Anthony (w/ enclosure)
Ms. Phyllis Zitzer (w/ enclosure)
Charles W. Elliott, Esq. (w/ enclosure)
Zori G. Ferkin, Esq. (w/ enclosure)
Mr. Thomas Gerusky (w/ enclosure)
Director, Penna. Emergency (w/ enclosure)
Management Agency Angus Love, Esq. (w/ enclosure)
David Wersan, Esq. (w/ enclosure)
Robert J. Sugarman, Esq. (w/ enclosure)
Kathryn S. Lewis, Esq. (w/ enclosure)
Spence W. Perry, Esq. (w/ enclosure)
Jay M. Gutierrez, Esq. (w/ enclosure)
Atomic Safety 6 Licensing Appeal Board (w/ enclosure)
Atomic Safety 6 Licensing Board Panel (w/ enclosure)
Docket 6 Service Section (w/ enclosure - 3 copies))
E. M. Kelly (w/ enclosure)
Timothy R. S. Campbell (w/ enclosure) l l
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9 BEFORE THE Tj i k,#
UNITED STATES NUCLEAR REGULATORY COMMISSION kc ,
In the Matter of a !
- Docket No. 50-35 2 PHILADELPHIA ELECTRIC COMPANY APPLICATION EUR AMENDMENT OF FACILITY OPERATING LICENSE NPF-39 AND EXEMPTION TO PART 50, APPENDIX J Edward G. Bauer, Jr.
Eugene J. Bradley 2301 Market Street Philad elphia, Pennsylvania 19101 Atto rneys fo r Philadelphia Electric Company l
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BEFORE THE UNITED STATES NUCLEAR REGULA'1VRY COMMISSION In the Matter of a
- Docket No. 50-352 PHILADELPHIA ELECTRIC COMPANY APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSE NPF-39 AND EXEMPTION TO PART 50, APPENDIX J t
f 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 teos ts) for certain primary containment isolation valves specified in Technical Specifications 4.6.1. 2.d and 4.6.1.2.g (page 3/4 6-4) .
Additionally, Philadelphia Electric Company requests, pursuant to Section 50.12 of the Commission's Regulations, an exemption from i
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tho requiremanto of 10 CFR 50, Appendix J, Secticn III.D.3 to provide the same temporary relief.
I J 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 in terval. However, in order to 4
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 t
weeks.
)
4 A containment entry is required to perform testing upon 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.
, . _ . - - - - - , . . . - . -_-.-,_--,__._,n-,,,-.,-__._,_~._.n. .
Additionni reatrcinto to tcsting ocQo cf tho v31v00 ot pswer include the need to depressurize the reactor, drain the Reactor Enclosure Chilled Water (RECW) system, the Drywell Chilled Water System (DCW) or one Emergency Service Water (ESW) lo op, remove the recirculation pump or drywell coolers from service, or a combination of the above.
The long time associated with obtaining the full power license is a major factor in the need for schedule relief. A normal schedule for low power testing, Start-up Testing and 100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> full power warranty run would not have resulted in a regairement to extend the testing interval. All low power (less 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 condition to demonstrate its availability for operation. Because of dhis condition, testing of all of these valves was not 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 in te rval, 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.g. main steam isolation valves and feedwater check valves) is required to be performed. During this 3-
" e e ,
9 l
._ cuttga, maintcnnnco cetivitico, curveillance 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 not 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 (ses attachment 1) for the applicable valves. The proposed change as shewn on enclosed Technical Specification page 3/4 6-4 would extend the test interval for these valses until May 26, 1986.
JUSTIFICATION POR THE REQUESTED EXEMPTIONS 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)
. _ _ _ - - - , . - , , - - , - .-,n- --, - _ _ _ - , , - . - - - - - - - - - ---
tho common dcfon00 cnd s:curity cro not endnngored, cnd (4) tho exemption is in the public interest because, on balance, there is good cause for granting it and the public health and safety are adequately protected.
I. The Requested Exemptions Are Authorized by Law and the i Activities Which Would Be Allowed Thereunder Do Not Violate Applicable Laws.
The criteria established in 10CFR50.12(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.
II. The Requested Exemptions Will Not Endanger Life or Prope r ty The ef fects of deferral of the requested Type C tests upon the potential for post-accident leakage from the 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 conclusion:
- 1. This requested exemption applies only to the first scheduled periodic Type C tests for these -
penetrations. As such, the valves do not have i
signficant operating hours upon them, and
~5- ,
m- e e
- I
, . degrcontion of their sealing ccpability would not 1
be expected.
j
- 2. The two-year time limit of 10CFR50, Appendix J, was written to ensure that Type C tests are performed on a schedule approximately consistent with normal plant refueling outages. At Limerick, the schedule indeterminacy of the plant startup test program and the first fuel cycle has caused
- the two-year time limit for these valves to expire just as the plant enters its first period of sustained operation. The plant has not operated at consistently high power levels until this timer the refore, the subject valves have not been continuously exposed to the type of environment i
which will occur during normal plant oper4 tion.
- 3. Operating experience to date with the subject 1
valves has been favorable. The Type C tests which are the subject of this exemption request are among the earliest performed during the preoperational containment leakage test program.
Since that time, the valves have not required any main tenance, repairs, or adjustments which would mandate reperformance of the Type C test in conformance with Paragraph IV of Appendix J.
The requested exemptions are for containment i
isolation valves which have traditionally good e . .
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maintentnco hicterioc 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 o containment purge and vent valves. (1) l
- 4. The sum total of the Type C test leakage rates or[ ,
these valves is not a significant portion of thei allowable leakage limits. For the subject valves which are pneumatically tested and included within the plant's 0.6 La Type C laakage total, the total-leakage recorded during the preoperational tests was 3786 seca, or 18% of the current Limerick Type C test total of 20,910 seca. Since the maximum Limerick Type C test total of 0.6 La is 94,964 ,
scem, these valves waald have to experience a significant increase in leakage before the plant's 0.6 La limit is exceede'd. '
- 5. The Limerick preoperational leakage rate test experience with thers valver was f vorable. once system start-up type activities (e.g. system flushing, Limitorque ope r'ator' settings, etc.Y 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
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Locktga Rato TO3t . Tho v31v3 Olign cnto fOr tho l
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 0.3754/ day outleakage, and also the Technical Specification LCO value of 0.St/ day.
III. Th9 Requeqt'd Ex cptienn Will Nnt End'nq1r thn Common Defense and Security The common defense and security are not implicated in Ehis 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 Elect ric Companyt Primary Reactor Containment Integrated Leakage Ra t e Tes t for Limerick Generating Station, Unit 1, Final Report August 1984.
Signi ficant Hammrd, Cnnqidorntien Determinnticn 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 i
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.
. , - - - . - . .__ _ - - - - - , . . _ - _ _ - - - , , . _ - - - - _ _ _ , , - , _ -_# __ _ .___-, 7 _,.--
i (2) The intent of the Technical Specifications and Section l 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, i these valves will have been subjected to rated temperature conditions for only approximately ten months se 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.
l (3) Five of the tests, which include ten valves, for which extension is requested are for hydrostatically tested ;
i j 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 approximately 0.2 GPM, i
6 i
---_----~n--__, .n . . - - . - _ , . . . - _ _ _ . - _ _ . , - -,- ,_.,.,,.., - . - ----,-...n,
- . - .. . _ _ . - = - _.- - . = . - . ..
. which 10 subatenticily belcw tho maxitua 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.1.1. Any leakage out of this system 3 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 hazards consideration in that it would nots
- 1. Involve a significant increase in the probability or consequences of an accident previously evaluated because the change extends the surveillance interval
- less than 201 beyond the current conservative surveillance requirements and has no ef fect on the assamptions of valve leakages assumed in the present '
analysest 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 i i
.wm gye r --ww w, .y-+-+
+na -e.,- -w--- - , .e----=...-i..--+iww,-.., . , , , - , ,
9
. of centninment lockcgar thcrcforo, new ccaident scenarios are not credible based upon scheduling of this testing aloner 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 safuty question
Cr o cignificant hazard 3 c:noidoration cnd will nnt cnd:ngor the public health and safety.
Respectfully Submitted, PHILADELPHIA ELECTRIC COMPANY Vicd l' resident
~
I a
CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)
- d. Type 8 and C tests shall be conduc ed with gas at P,, 44.0 psiga, >
at intervals no greater than 24 monthl*except for tests involving: I
- 1. Air locks,
- 2. Main steam line isolation valves,
- 3. Containment isolation valves in hydrostatically tested lines which penetrate the primary containment, and
- e. Air locks shall be tested and demonstrated OPERA 8LE per Surveillance Requirement 4.6.1.3.
- f. Main steam ifne isolation valves shall be leak tested at least once per 18 months.
- g. Contain ent isolation valves in hydrostatically tested lines which penetra;a the primary containment shall be leak tested at least once per 18 months. ** l
- h. The provisions of Specification 4.0.2 are not appitcable to Specifica-tions 4.6.1.2a., 4.6.1.2b., 4.6.1.2c., 4.6.1.2d., and 4.6.1.2e.
"Unless a hydrostatic test is required per Table 3.6.3-1.
- A Type C test interval extension to May 26, 1986 is permissible for primary containment isolation valves listed in Table 3.6.3-1.
Part A, which are identified in Application for Amendment of Facility Operating License dated December 18, 1985 that need a plant outsge to test.
LIMERICK - UNIT 1 3/4 6-4 B 'J ! 2. 2 2 0 / EI O T , ,
t' age 1 ot 3 r
i Stammary Of Valves For Which A Ounrige is Requested IIR $ Penetratim Descripticn Valve f Test Meditus Extentim Restricticns J$pendix J Duraticn nr r+1r.g W ted Regtnized ,
131 X-13A A SM Ccoling Return W-51-IIO50A* hter 9 weeks 5 days Qntairunert No N 151A* hter 9 weeks 5 days Entry No 141 X-13B B S A Cooling Return IW-51-IIO50B* hter 9 weeks 5 days "
No W-51-151B* hter 9 weeks 5 days -". ,
. No 451 X-45A A IPCI Injectim W IIO41A* hter 9 weeks 5 days Qntalment . No W-51-142A* hter 9 weeks 5 days Ehtry, RX No W-51-11017A* Air 9 weeks 5 days Defressuriza- y ticn 471 X-45C C IPCI Injecticn W-51-IID41C* hter 9 weeks 4 days Qntainment
. W-51-142C* hter 9 weeks 4 days Ihtry, RX W-51-11017C* Air 9 weeks 4 days Depressuri za-tien Yes .
4GL X-45D D IPCI Injecticn W-51-11041D* hter 9 weeks 4 dp Qntairunert
. W-51-142D' mter 9 weeks 4 days Entry, RK W-51-13017tf Air 9 weeks 4 days Degressuriza-y, ticn C51 X-205A !bE pressim Pool IW-51-IIO27A' Air 8 weeks 1 day O mtainsert Spray Ehtry .Yes -
- B;uipped with through leakage detection systan. l
au u u . u .s 1 a ,
Page 3 of 3
, mmmary Of Valves For Which A Change is Requested I (ccntinued)
I2R 8 Penetraticri Descripticri Valwr i Tes t Meditum Exterticn Restriccicns Appendix J Duraticn Wir=
Reyested Required 21 X-56 IDt Return W-87-121B Air 11 weeks 2 days Otntalrunert Yes W-87-123 Air 11 weeks 2 days Entry, DOf Yes
' W-87-124B Air 11 weeks 2 days Dralned, All Yes DAt (boling Off 151 X-14 30CU Sugply W-44-11001 Air 9 weeks 3 days Omtaisumert Yes W-44-11004 Air 9 weeks 3 days Entry, No Yes ~
IBCU, RK Yes Degressurized Yes 532 X-61B 'B' Recire 43-1004B Air 3 weeks Otntairunert Yes seal Ptrge D try, 'B' Recire Off 021 X-3D ' Instr. Gas W-59-151B Air 1 week 4 days Ontairunert Yes
!bsply 59-1112 Air 1 week 4 days Entry Yes .
I i D e
Page 2 of 3 Smenary Of Valves For Which A Ourge e
is Deguested *
(Ocntinued) ~
UA 8 Penetratica Descripticn Valve 9 Yest Medium Extertion Restrictions Diraticn Wiw J Rapiested %
Required 201 X-23 IEOfSugply W-13-106 Air 11 weeks 5 days Otntairunert Yes W-13-10B Air 11 weeks 5 days Entry; Recire. Yes
- W-13-109 Air 11 weeks 5 days Ptsups Off; Yes sent & ained:
E5it & ained (1 hxe):
no Bucu 211 X-24 IEOf Return W-13-107 "
Air 12 weeks Yes W-13-110 Air 12 w eks "
Yes W-13-111 Air 12 weeks "
Yes 491 X-53 Inc % 1y W-87-120A Air 12 weeks Otntalismert Yes W-87-125A Air 12 weks Ehtry, DOf Yes W-87-128 Air 12 weeks drained, All Yes DAt (bolirg Off 501 X-54 ids Return W-87-121A " .
Air 11 weeks 5 days Yes W-87-124A Air 11 weeks 5 days "
Yes W-87-129 Air 11 weeks 5 days "
Yes 511 X-55 Int Sugply W-87-1208
- Air 6 weeks 1 dar Yes W-87-122 Air 6 weks I day "
Yes W-87-1258 Air 6 weeks 1 day
- Yes I
I
, CCDetDNWEALTH OF PENNSYTNANIA a l as.
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 t and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.
7 ll Subscribed and sworn to M
before me this /f day at - AW a u n 4 / k 2.
Notary Public Pan 6,t, o. s:n:.>.
Nityp puttg p .,s. ;,', , , , 9, El UEll44 b;, fe4 a ....fj 6, ;,
- == e e
UNITED STATES OF Abst!CA NUCLEAR REGULATORY 03041SSION Before the Atomic Safety and Licensina Board In the Matter of : Docket No. 50-352 PHILADELPHIA ELECTRIC COMPANY :
(Limerick Generating Station, t 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 this 19th day of December, 1985 I
l Kathryn 3. Lewis, Esquire Atomic Safety 4 Licensing k nicipal Services Building Appeal Board Panel 15th 4 JFK Blvd. U. S. Nuclear Regulatory Commission Philadelphia, PA* 19107 Washington, D.C. 20555 Ann P. Hodadon, Esquire Robert J. Sugarman, Esquire Counsel for !stC Staff Sugarman, 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 Petterhahn, P.C.
107 8. Main Street 1747 Pennt/1vania Avenue, NW Norristown, PA 19401 Washington, D.C. 20006 1
i e
l o 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 190d5 Pennsylvania Emergency Management Agency Basement, Transportation 4 Safety Building
') avid Wersan, Esquire Harrisburg, PA 17120 Assistant Constner Advocate Office of Constner Advocate Jay M. Gutierres, Esquire 1425 Strawberry Square U. S. Nuclear Regulatery Commission Harrisburg, PA 17120 Region 1 631 Park Avenue Atomic Safety 4 Licensing Board Panel King of Prussia, PA 19406 U. S. Nuclear Regulatory Cosmission Washington, D.C. 20555 Phyllis Zitser 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 Getusky, Director Senior Resident Inspectcr 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 1hird 4 Locust Streets Harrisburg, PA 17120 Spence W. Perry, Esquire Associate General Counsel PB R, Room 840 500 C Street, SW Washington, D.C. 20472 q C, ~
?
6,.)I&dQ, Eugene J.for Attorney Bradley !'
Philadelphia Electric Company 2301 Harket Street Philadelphia, PA 19101
~
3 f' ,,
e, UNITE 0 STATES NUCLEAR REZULATORY COMMISSION l
casmotcN. o. c. rosse i ?
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0 Docket No. 50-352 Mr. Edward G. Bauer, Jr. h ,4 %G d/ rYr#p
- C #
I i
Vice President and General Counsel Philadelphia Electric Company 1h'
'S
$*d ' '8'
- j 1
2301 Market Street Philadelphia, Pennsylvania 19101 (t i-
Dear Mr. Bauer:
SUBJECT:
ISSUANCE OF AN EXEMPTION FOR FACILITY OPERATING LICENSE NO. NPF-39, LIMERICK GENEPATING STATION, UNIT 1 The U.S. Nuclear Regulatory Comission has issued the enclosed one time exemption from the requirements of Appendix J 10 CFR Part 50 for Facility I Operating License No NPF-39 for the Limerick Generating Station, Unit 1 located in Montgomery County, Pennsylvania. This exemption deals with an extension in the schedule for conducting leak rate tests on certain contain-ment isolation valves.
The Philadelphia Electric Company requested this exemption in its letter dated December 18, 1985. The staff has found that approval of the extension in the schedule for testing the sub,iect isolation valves recuires the granting of the above identified exemption. The related arendment to the Unit 1 Technical Specifications is being issued separately.
A copy of the related safety evaluation supporting the exemption is enclosed.
Also enclosed is a copy of a related notice of environmental assessment and finding of no significant impact which was published in the Federal Refister.
A copy of the exemption it being filed with the Office of the Federal Register.
Sincerely, y K sYg Walter D. Butler, Director BWR Project Directorate No. 4 Division of BWR Licensing
Enclosures:
- 1. Exemption
- 2. Safety Evaluation
- 3. Notice of Environmental Assessment cc: See next page g 6 Q Vi b(J U2 h '
Mr. Edward G. Bauer, Jr Limerick Generating Station Philadelphia Electric Company Units 1 & 2 cc: ,
Troy B. Conner, Jr., Esquire Mr. Marvin I. Lewis Conner and Wetterhahn 6504 Bradford Terrace 1747 Perrsylvania Ave, N.W. Philadelphia, Fennsylvania 19145 Washington, C. C. 20006 l Tori G. Ferkin Frank R. Romano, Chairman t
Assistant Counsel Air & Water Pollution Patrol '
Governor's Energy Council 61 Forest Aver.ce 1625 N. Frcnt Street Anbler, Pennsylvania 19002 Harrisburg, Pennsylvente 17105 Federic M. Went.: Charles W. Elliott, Esquire Cctnty Solicitor Brose & Poswistilc,1101 Bldg. !
l Ccur.ty ct hontgomerj 325 f4.10th Street
! Ccurtt. cute Caston, Pennsylvania 184C2 :
l Norristown, Pennsylvar.it 19tCt i Euger.e ?. Bradley Ms. M. Mullicar i Philadelphia Electric Cor par.y Lirerick Ecology Action
. Associate General Ccunsel 762 Cuten St.
130' f*tr>et Street Pottstown, Pennsylveria 15464 l Philacelphia, Pennsylvanta 19101 i Mr. Karl Abrahar Thera: Gerusky, Director '
Fublic 7.ffairs Officer Bureat ef Pictation Protection le tept. of Enviromental Pesctrees l
I l'.gicr.I
.. f:oclear Regulatory Conc.tsstu, 5th Floor, Fulton Bank Blde.
(21 Park Averve Third and Locust Strcets
, King of Prussia, PA 1990f Perrisburg, Pennsylvanto 1714L s i
l l'r. Ce.s rsli) l Str 10r f.edicent Inspectcr ,
l U.S. Ftclear Regulatory Co'ristict.
l F. C. Ec) 67 Sanatoga, Pennsjivanic 'ctf4 i
\
l
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l -
1 i
j Philadelphia Electric Ccrpr.y -E- Livrerick Generating Staticr. :/2
- cc:
l Sugarman, Denworth & Hellegers Director. Pennsylvatiia Er.:erger.cy 16th Ficor Center Plaza Management Agency 101 North Broad Street Caserent. Transportation &
l- Philadelphia. Fennsylvania 19106 Safety Building i
Harrisburg, Pennsylvanie ;71LG l
[
Robert L. Anthony Angus Love, Esc.
Friends of the Earth 107 East Main Street of the Delaware Valley Norristcwn, Pennsylvania 19402 103 Vernon Lane, Box 16e Meylar, Fernsylvania 19065 l Helen F. Hoyt, Chairnan l Kathryn S. Lewis, Esq. Adrainistrative Judge l Punicipal Services Fler. Atcr.ic St.f ety & Licensing Boarc i 15th ar.c JfL Chd. (l.S. Nuclear Regulatcry Cerr.issico
( Philadelphia, Fer,rsyhrrir 10102 Washington, D. C. 2055E Cavic l'erson, Esq. Dr. Jerry harbour Assistant Consurer Advocate Adrir.tstrative Judge Of f1ct. of Censurer Advocate Atonic Safety t. Licensing Board 1425 Strawberr, Squan. U.S. 7:velear Rrgulatory Core 11ssior.
Harrisburg. Ptrrr;;vsnie 17120 Washington, C. C. 2CEEE i
Stevec P. Herstc;, Est. Lr. Richard F. Cole Corraur.ity Legal Services, Inc. Adriristrathe Judge Law Center f, orth Cenoci Ervry Fitg. Atornie Safety & Licentir.g Eccro 3701 fiorth Board Street U.S. f t. cit.ar Regulatory Cormisstor, j Philectlphia, Pennsylvante ;9 '.4C l't t t 4rgter D. C. 20555 fir. J. T. kot'b , liS-1 te.r. 5;er ce.11. Perry. Esq.
f Philace.'rFir Electric Corparj Ass 0cie n Cer. tral Counsel l L;C.' l'ertet Street Federal Ecergercy t't.r.ager et.t Agency Fhilaceiphta, Fennfi s vw.t *0:01
. Fece 840 500 C St., S.W.
Tiretty P. !. C4.r pleii, Isirector Washingtcr., D. C. 20472 Departrnent of Energency St.n ice.s l 14 East Biddle Street l 1:est Crester. Pennsylvanie 19?P0 l
l I e l
[7590-1]
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )
Philadelphia Electric Company ) Docket No. 50-352 Limerick Generating Station Unit 1 EXEMDTION I
The Philadelphia Electric Company (PECo./the licensee) is the holder of racility Operating License No. NPF-39 which authorizes operation of the Limerick Generating Station, Unit 1 at a power level not in excess of 3293 megawatts thermal for each unit. The facility is a boiling water reactor located at the licensee's site in Montgomery County, Pennsylvania. The license provides, among other things, that the facility is subject to all rules, regulations and orders of the Comission now or hereafter in effect.
II Paragraphs !!!.C.3 and !!!.0.3 of Appendix J .o 10 CFR Part 50 require that containment isolation valves which may provide a pathway for leakage of con-tainment atmosphere are re:uired, cr at least a 24 month frequency, to have their leakage measured fer comparison with the limiting value of 0.6 L, for -
Type 8 and Type C tests.
G o ) Q) O U .b U
r i
The Philadelphia Electric Company proposed a one-time extension to the Surveillance Requirements for Technical Specification 4.6.1.2 which would allow the 24 month interval for conducting Type C tests with gas on 27 iso-
! lation valves to be extended by 12 weeks until May 26, 1986. The staff has l
l found that approval of the proposed extension is warranted and is authorf2ed l
l by the granting of this one-time exemption so that Unit I may continue to operate until a shutdown is required on May 26, 1986 to perfonn other extensive surveillance and maintenance activities.
l l III l
The NRC staff has evaluated the licensee's basis for recuesting the extension j in the surveillance interval and finds that not granting this exemption would l require the licensee to shut down the plant on March 3, 1986 for a period of l
l about two weeks to conduct the testing. Granting of this exemption is likely to result in a negligible reduction in containment integrity during the 12 wee 6 l extension period. In evaluating the changes to the Technical Specifications and the associated exemption, the staff reviewed the licensee's technical
! justifications for the requested extension. The staff reviewed the licensee's position that these tests cannot be conducted during power operations and that therefore a shutdown would be required to perform the tests. The staff reviewed the types of valves involved to ascertain that these are not the types of valves used in boiling water reactors which have a greater propensity to require intensive maintenance to maintain their leaktight integrity. The staff considered the uses l
L
3 of these valves to ascertain that they are not used during normal plant operations in the relatively more demanding applications such as modulating valves to continuously control flow rates or pressure. The staff reviewed available data provided by the licensee on similar valves used elsewhere in the industry which supports the licensee's position that these valves have traditionally good maintenance histories in the industry. The staff also reviewed previous leakage test results on the specific valves subject to the exemption request and has found that there is substantial margin between the values previously measured and the limiting values in Appendix J and the Tech-nical Specifications to accommodate any additional degradation likely to occur during the period of the extension. The details of the above described review are discussed in the attached Safety Evaluation. Based on the information provided by the licensee, the staff's evaluation of the licensee's submittals, the hRC staff concludes that the licensee has provided an adequate basis for the conclusion that postponing the subject local leak rate tests until May 26, 1986 is likely to have little er no effect on containment integrity.
The Commission has amended its regulations, effective on January 13, 1986, in 10 CFR 50.12 (50 FR50764-50778) to modify tne criteria for granting exemptions from its regulations. The amended regulations in 10 CFR 50.12 state that the Connission will not consider granting an exemption unless special circumstances are present. In its letter of February 25, 1986 the licensee has addressed two of those special circurstances which are applicable to th's exemption request.
.a.
The licensee states that the special circumstances of 10 CFR 50.12 (a)(2)(ii) are present in that application of the regulation in 10 CFR 50. Appendix J for the Type C leakage testing of 27 containment isolation valves within 24 months, i.e. by March 3,1986, of their initial tests versus the requested one-time extension until May 26, 1986 is not necessary to achieve the under-lying purpose of the rule. Appendix J states that a purpose of the tests is to assure that leakage through the primary reactor containment and systems and components penetrating prirrary containment shall not exceed allowable leakage rate values as specified in the technical specifications or associated bases.
The licensee has provided various bases for its conclusion that the recuested delay of 12 weeks is not likely to result in a situation wherein the measured leakage from these valves would cause the Ilmitations of the technical specifi-cations to be exceeded. These bases, which are discussed in more detail in the enclosed Safety Evaluatter and the licensee's submittals, include the Itcensee's characterization of these valves as being of the type which tradt-tionally have good maintenance histories, are not used in the relatively more demanding applications and which have shown in their initial leakage tests that they do not contribute an undue proportier of either the total measured j containment Ieakage or the technical specification allowable leakage values.
On these bases the staff agrees that it is unlikely that the delay in the testing of the subject 27 valves would result in measured leakage that would cause the allowable technical specification values to be exceeded. Thus the
- NRC sta'f concludes that the aderlying purpose of Appendix J in this regard,
t i*
i to provide assurance that leakage shall not exceed technical specification allowable values, will be met with this one-time extension of the test schedule.
i The licensee also states that the special circumstances of 10 CFR 50.12 (a)
(2)(v) are present in that the exemption would provide only temporary relief from the applicable regulation and the licensee has made good faith efforts to comply with the regulation.
The exemption is temporary since it provides relief from the requirement to conduct the subject tests only from March 3, 1986 until during a shutdown which shall begin no later than May 26, 1986. The ifcensee submits that it -
has made a good faith effort to cceply with the requirements of the regulation I
in that it has tested all but 27 valves out of a total population of over l 200 valves subject to such testing by the date initially required by Appendix l J and the technical specifications. The licensee also describes its attempts l to minimize the number of valves which would require the schedular relief by proceeding with the tests of all valves necessary to permit operations until May 26, 1986 which could be tested without reautring the shutdown of the plant.
This effort was undertaken following the delay between the completion of low power testing activities and issuance of the full power license. Thus the NRC staff concludes that the requested esemption meets the criterion of pro-viding only temporary relief and has been accompanied by a good faith effort to comply with the regulatten.
l t
l I i
Based upon the staff's findings that postponing the local leak rate tests from March 3 until May 26, 1986 is likely to have little or no effect en containment integrity and the staff's assessment of the special circumstances associated with this request for an exemption the NRC staff finds that operation of Limerick Unit 1 during the proposed extension period is acceptable. Therefore, the staff finds that the proposed temporary exemption from 10 CFR 50 Appendix J.
Paragraph !!!.D.3 is acceptable.
i IV Accordingly, the Commission has determined that, pursuant to 10 CFR 50.12, the exemption is authcrized by law, will not endanger life or property or the common defense and security and is otherwise in the public interest. Therefore, the Commission hereby grants tne exemption as follows:
"An exemptien is granted from the requirement te conduct Type C testing on containrent isolation valves at an interval no greater than 24 months as stated in 10 CFR 50 Appendix J. Paragraph !!!.0.3. This exemption is granted for the period specified ir, the licensee's December 18, 1985 reauest for exemption (from March 3, 1966 until May 26, 1986) and is only applicable te 27 valves in Limerick Unit I as indicated in the modified Technical Scacification Table 3.6.3 1 acecmpanying the issuance of Amendment No. 2 0 License No. NPF 37."
Pursuant to 10 CFR 51.32. tea Cormission has determined that the issuance of the exemption will have ne significant impact on the environment (51FR7344 March 3,1986).
o A copy of the Connission's Safety Evaluation dated March 3,1986 related to this action is available for public inspection at the Connission's Public I
Document Room, 1717 H Street, N.W., Washington, DC and the Pottstown Public Library, 500 High Street, Pottstown, Pennsylvania 19464 This Exemption is effective upon issuance and is to expire at midnight on l l
May 26, 1986.
FOR THE NUCLEAR REGULATORY COMMISSION 1
, 4 / . %.sv Robert Bernero, Director i Division of BWR Licensing l Dated at Bethesda, Maryland this 3rd day of March 19M 1
l l
l i !
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l SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORT EXEMPTION FROM APPEN0!X J FACILITY OPERATING LICENSE NO. NPF-39 PHILADELPHIA ELECTRIC COMPANY MONTGOMERY COUNTY. PENNSYLVANIA LIMERICK GENERATING STATION, UNIT NO. 1 DOCKET NO. 50-352 1.0 Introduction By letter dated December 18, 1985, the Philadelphia Electric Company (the licensee) requested a one-time-only approval to temporarily extend certain surveillance requirements in the Technical Specifications, which must be performed nominally every 24 months and which can only be done when the plant is shutdown. The change would extend the 24 month surveillance intervals for leakage testing of selected containment isolation valves by up to 12 weeks beyond the time allowed by the Technical Specifications. This would permit the licensee to delay performing this testing until a maintenance and surveillance outage which will begin on or before May 26, 1986. The staff has found that appreval of the proposed change to the Technical Specification would also require the granting of an exemption from Appendix J along with the issuance of the requested amendment.
By letters dated January 29. February 5, February 25 and March 3,1986 the licensee provided additional information in support of the proposed changes.
Technical Specification (TS) 4.6.1.2.d requires that Type C tests shall be conducted at intervals no greater than 24 months except for tests involving valves in hydrostatically tested lines. The 24 month interval for this Type C testing is consistent with the requirements of 10 CFR Part 50, Appendix J, paragraph !!!.0.3 which specifies that Type C tests shall be performed at l i
intervals no greater than 2 years. The licensee's letter of December 18, 1985 requested an extension of the 24 month TS testing requiremenc by a maximum of )
12 weeks for a group of 27 isolation valves. In addition, in the December 18, 1985 letter the licensee requested a one-time exemption from the Appendix J 24 month testing requirements for these 27 valves.
1 Paragraphs !!!.C.3 and !!!.0.3 of Appendix J require that containment isolation i valves which may provide a pathway for leakage of containment atmosphere are required, on at least a 24 month frecuency, to have their leakage measured for for Type 8 and Type C tests.
comparisonwiththeIfmitingvalueof0.6Llfromisolationvalvesthatare Paragrap' !!!.C.3 also provides that leakag sealed with fluid may be ercluded from the sunvaation of Type 8 and Type C tests.
Consistent with this provister the Itcensee has identified that 10 of the 37 valves addressed in the Cecember 18, 1985 application amendment are sealed by fluid and therefore are hydrostatically tested on a nominal frecuency of 18 months. The acceptability of hydrostatically testing these valves in the
,u&v 7 l l
2- ,
shutdown cooling return line and in the low pressure coolant irjection line is addressed in Section 6.2 of the Limerick Safety Evaluation Report dated August 1983. The measured leakage from these hydrostatically tested valves is compared to the limit of 1 gallon per minute in the pressure isolation valve section of the TS and not to the 0.6 L criteria for Type 8 and Type C tests and accord-ingly the testing of these $alves is not eithin the scope of the issues addressed by tne licensee's exemption request. The acceptability of the sur-veillance extension for hydrostatically tested valves is addressed in the safety evaluation accompanying the amendment to the technical specifications.
2.0 Evaluation Since the Limerick Unit 1 plant has been through an extended startup program schedule, which included relatively little startup testing program activity frem about April to early August 1985, the scheduled surveillance tests fall in a period of what would otherwise be a continuation of first fuel cycle power operations. Since the plant must be shutdown for about two weeks to perform these tests and since the licensee plans to shut the plant down on or before May 26, 1986 to perform other surveillance tests and maintenance activities the licensee proposes to extend the surveillance interval for these isolation valves to allow those tests to also be performed during the outage to begin on or before May 25, 1986. The end of the present most limiting surveillance interval is March 3, 1986.
The requirements of the TS for which extensions are proposed and the reason these tests can only be performed while the reactor is shutdown are as follows, General Design Criterion 56, Primary Containment Isolation, requires that lines to be isolated be provided with an isolation valve inside containment and an isolation valve outside containment. The design of the isolation valves and their associated piping and test connections requires personnel access to the primary containment to isolate the valve inside the containment from the balance of its associated system and to implement the test procedure. Entry into con-tainment during power operations would expose personnel to the hazards of'high air terrperature (about 120'F), radiation exposure that is high with respect to as-low-as-reasonably-achievable (ALARA) standards (about 10 R/heur in represen-tative areas) and the nitrogen environment of the inerted containment atmosphere for which self contained breathing apparatus (SCUBA) would be recuired. The licensee has stated orally that they consider the hazard of the inerted contain-ment atmosphere to be too great to permit personnel access for routine plart operational tasks. The licensee has also stated that further factors which preclude testing these valves at power include the need to depressurize the reactor, drain the reactor enclosure chilled water (RECW) system, drain the dry-well chilled water (DCW) system, drain the emergency service water (ESW) loop, remove the reactor recirculation pumps from service or a combination of the above.
The staff concludes that the licensee has shown that it is not practical or feasible to test these valves at power and that the plant would be required to
F I.
shutdown for about two weeks to cooldown, depressurize and conduct the tests beginning on March 3, 1986 unless the requested extension in surveillance test periods is granted.
The licensee has stated that the types of valves subject to this surveillance schedule extension request have traditionally good maintenance histories and do not include those valves known to be maintenance intensive in boiling water reactors such as the main steam isolation valves or the feedwater check valves.
The licensee also points out that these valves are used in applications where they are either normally open or normally closed and are not used in a modulatina mode to control flow rates. The licensee further states that such valves when used in non-modulating applications tend not to have problems meeting leakage criteria. In this regard, the licensee has also considered the leak rate in-formation reported in Licensee Event Report (LER) No. 352/85-102. This LER deals with a valve that is not within the scope of the Limerick surveillance schedule extension request. le licensee has reached a determination, with which the staff concurs, that the LER 85-102 event was an isolated event and as such has no significant effect upon the conclusions and basis for the request for extension.
In support of the position that these valves are reliable in meeting leakage criteria the licensee has interrogated the Nuclear Plant Reliability Data System (NPRDS) for similar types of valves and has reviewed these specific valves' previous leakrate test histories.
The NPRDS query serves as a useful qualitative estimation of these valves' reliability since the reporting of data to the system is on a voluntary basis and therefore there is no representation that the data from the system repre-sents all of the valves in the industry of that specific valve type. Never-theless, the data as presented in the licensee's letter dated January 29, 1986, is useful in corsidering whether these valve types are generally reliable in meeting their leakage criteria. The licensee notes that the valves in the NPRDS data base have been in service for significant periods whereas the Limerick valves will have experienced only a part of the first fuel cycle's operating time by the date of the next planned surveillance test. The NPRDS data does not suggest that these valves, either individually or collectively, should be expected to experience undue difficulties in meeting the leakage criteria.
The licensee states that testing has been performed on those valves that can be tested at power such that only 27 valves out of a total of 245 valves in Part A of TS Table 3.6.3-1 recuire the one-time extension of the 24 month surveillance interval. This is reflected in the following specific system discussions wherein, as applicable, it is noted that the extension request does not apply to all of the valves in a given system since the other valves have been tested on a more recent schedule which does not require their retest until af ter May 26, 1986.
r Technical Specification 4.6.1.2.d-Twenty-Four Month Tests There are 27 valves subject to this specification for which the licensee has requested one time extensinn of no more than 12 weeks in the surveillance test schedule. These valves are as listed below.
System Valve Number _S_i_ ze / Type
- LPCI injection loops HV-51-1F017A.C.D 12" gate A.C.D
- Suppression Pool Spray HV-51-1F027A 6" globe
- Reactor enclosure cooling water
- supply line HV-13-106,108,109 3" and 4" gate
- return line HV-13-107,110,111 3" and 4" gate
- Drywell Chilled Water, Loops A and B
- Supply lines HV-87-120A, 125A, 128 8" gate and 1208, 1258, 122
- Return lines HV-87-121A, 124A, 129 8" gate ard 121B, 1248, I?3
- Reactor Water Cleanup HV 44-1F001, IF004 6" globe supply line
- Recirculation Pump B seal 43-1004B 1" check purge .)
'i
- Instrument Gas Supply te PV-59-151B 1" globe ADS valves E and K 59-1112 1" check The licensee's letter of January 29, 1986 also provides information on the previous leakage testing for the specific valves which are subject to this amendment request. As indicated in the licensee's letters, the total leakage measured as a result of the previous tests on all applicable Type C valve tests is about 22,000. standard cubic centimeters per minute (SCCM) which is about 23% of the total allowed by the Technical Specifications. Of this 22,000. iCCM .
only about 3800. SCCM (or 41 of the TS limit) was contributed by the 27 valves subject to the amendment application. Thus, it may be seen that leakage through these valves would have to increase many times beforc'they contributed a lar portion of either (1) the total measured leakage freq all such valves or (2)gethe TS limit value. Some discussion of the individual valves is provided below.
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LPCI Injection Valves HV51-1F017A, C and D require an extension of less than 10 weeks in a 24 month surveillance interval. The comparable valve in the B loop was tested on a schedule which does not require its retest until after May 26, 1986. The leakage from these three valves during the previous tests totaled 1210 SCCM or 1% of the TS limit valve. The line in which these valves are located is pro-vided with instrumentation which will detect and annunciate excessive leakage past the valves.
Suppression Pool Spray Valve HV-51-1F027A requires an extension of about 8 weeks in a 24 month sur-veillance interval. The comparable valve in the B loop of suppression pool spray was tested on a schedule which does not require its retest until after May 26, 1986. The leakage from this valve during the previous test was 2.25 SCCM or 0.002% of the TS limit valve.
Reactor Enclosure Cooling Water (RECW)
Valves HV-13-106, 108, 109 in the RECW supply line and HV-13-107, 110, 111 in the RECW return line require ar extension of 12 weeks in a 24 month surveillance interval. The leakage from these valves during the previous tests was 145 SCCM or 0.15% of the TS limit for the supply valves and 9 SCCM or 0.01* of the TS limit for the return valves.
Drywell Chilled Water The' valves in loops A and B of the drywell chilled water system, each loop having 3 involved valves in the supply line and 3 involved valves in the return line, require an extension of up to 12 weeks in a 24 month surveillance inter-val. The leakage from these valves during the initial tests was 203 SCCM for loop A supply valves, 653 SCCM for loop A return valves, 668 SCCM for loop P supply valves and 338 SCCM for loop B return valves for a total of 1862 SCCM or 2% of the TS limit.
Reactor Water Cleanup Valves HV-44-IF001, IF004 in the RWCU supply line require an extension of less than 10 weeks in a 24 month surveillance interval. The leakage from these valves from previous tests was 510 SCCM or 0.5% of the TS limit value.
Recirculation Pump B Seal Purge Valve 43-10048 in the reactor recirculation pump seal purge line requires an extension of 3 weeks in a 24 month surveillance interval. The comparable valve in the A loop line was tested on a schedule which does not require its retest until after May 26, 1986. The leakage from this valve from previous tests was 76 SCCM or 0.1': of the TS limit value.
(_.
Instrument Gas Supply to ADS Valves Valves HV-59-151B and 59-1112 in the instrument gas supply tc automatic depressurization system (ADS) valves E and K require an extension of less than 2 weeks in a 2a month surveillance interval. Comparable valves in the gas supply line for ADS valves H, M and S and other instrument gas supply and return lines were tested or a schedule which does not require retest until after May 26, 1986. The leakage from these valves during the previous tests was 9 SCCM or 0.01% of the TS limit value.
Suninary for 24 Month Surveillance Interval Valves In assessing whether an extension of 12 weeks in a 24 month surveillance interval would be appropriate for these valves the staff has considered the previous leak rate test results for these valves, their propensity for requiring extensive maintenance to maintain their leak tight integrity and the consecuences of any additional degradation during the requested extension. Based on its review the staff finds that:
(1) The previously measured Type C test leakage through these valves (3800 SCCM) constituted but 17'. of the total measured Type C leakage. There is con-siderable margin between,these values and the limit established by Appendix J and tne technical specification of 0.6 La (94, 964 SCCM) for the Type B and C tests. These valves were not found to contribute either individually or collectively a disproportionate percentage of the total measured leakage or of the technical specification limit values.
(2) To date these valves have not required maintenance, repairs or adjust-ments which would reaufre reperformance of their Type C test. The licensee's review of similar valves via NPRDS provides a qualitathe assessment that supports the licensee's findings that these valves typically have good maintenance histories, do not require intensive maintenance to ensure their leak tight integrity and thus are unlikely to degrade significantly in the period of the extension.
(3) There is ample margin tvtween the leakage previously measured during the Type C isolation valve tests, including the previous tests of the 27 valves subject to this amendment request, and the limiting leakage values in the technical specifications and in Appendix J to accommodate any degradation likely to be experienced by these 27 valves during the extension period.
Therefore the consequences of leakage past these isolation valves is bounded by safety analyses previously performed which were based on the limiting leakage values in the technical specifications and in Appendix J.
The licensee has determined that the proposed changes to the TS will have little or no effect on containment integrity ana that the proposed amendment will not alter any of the accident analyses. The staff has reviewed these determinations and the associated changes and concludes that, on the bases discussed above, they are acceptable. In addition the staff concludes that the licensee has pro-vided sufficient bases for the terporary extension of the 24 month surveillance interval required by Appendix J and that a temporary exemption from the require-ments of Paragraph III.D.3 is acceptable.
3.0 Conclusion The staff has concluded, based on the considerations discussed above, that the proposed temporary exemption fron 10 CFP 50, Appendix J. Paragraph III.D.3 is authorized by law, will not endanger life or prcperty or the common defense ard is otherwise ir the public interest and should be granted.
Cated: Marc 5 3,1986
T
[7590-01]
UNITED STATES NUCLEAR REGULATORY COMMISSION PHILADELPHIA ELECTRIC COMPANY 2,
LIMERICK GENERATING STATION, UNIT 1 8 DOCKET NO. 50-352 NOTICE OF ENVIRONMENTAL ASSESSMENT AND FINDING OF NO $1GNIFICANT IMPACT The U.S. Nuclear Regulatory Ccmmission (the Consission) is considering issuance of an Exemption to 10 CFR 50, Appendix J, Paragraph III.D.3 for Facility Operating License No. NPF-39, issued to the Philadelphia Electric Company (the licensee), for operation of the Limerick Generating Station, Unit 1, located in Montgomery County, Pennsylvania.
ENVIRONMENTAL ASSESSMENT Identification of Proposed Action: This Exemption would suspend the requirement to conduct Type C leakage testing at intervals no greater than 24 months, as stated in 10 CFR 50, Appendix J, Paragraph III.D.3, for 27 containment isolation valves from March 3, 1986 until May 26, 1986.
The Need for the Proposed Action: The proposed Exemption from the regulation is required in order to allow continued operation of the plant until May 26, 1986 when the plant will be shutdown for extensive maintenance and surveillance testing activities. Without this Exemption, a forced shutdown, beginning on March 3, 1986 and lasting about two weeks, would be required in order to perform the necessary surveillance tests, u O
r 2-i Environmental Impacts of the proposed Action: There are no environ & ental impacts of the proposed action. During the period of the extension the plant will con-tinue with normal operations. On May 26, 1986 the plant will be shutdown and the containment isolation valve Type C leakage tests will be performed during that outage. The surveillance test will be performed at that time, in every other respect, the same as if it had been performed during an outage prior to March 3, 1986. The staff has reviewed the information provided by the licensee and finds that postponing these leakrate tests until May 26, 1986 would have little or no effect on containment integrity. No changes are being made in the allowable amounts and no significant changes are being made in the types of any effluents that may be released offsite, and there is no significant increase in the allowable individual or cumulative occupational radiation exposure. There-fore, the Commission concludes that there are no significant radiological environmental impacts associated with this proposed Exemption.
Alternative to the proposed Actions: Since we have concluded that there is no measurable environmental impact associated with the granting of the proposed Exemption, any alternative to this Exemption will have the s'ame or greater environmental impact.
The principal alternative would be to deny the Exemption which would require a two week shutoown beginning no later than March 3, 1986.
Alternative Use of Resources: This action does not involve the useiof resources not previously considered in connection with the " Final Environmental Statement" related to the operation of the Limerick Generating Station, Unit 1, dated April 1, 1984.
Agencies and Persons Consulted: The NRC staff performed the entire review of the licensee's position and did not consult other agencies or persons.
Findings of No Significant Impact: The Commission has determined not to prepare an environmental impact statement for the proposed Exemption.
Based on the foregoing environmental assessment, we conclude that the proposed action will not have a significant effect on the quality of the human environment.
For further details with respect to this action see Amendment No. 2 to NPF-39, which is available for public inspection at the Comnission's Public Document Room, 1717 H Street, N.W., Washington, DC 20555 and at the Pottstown Public
Library, 500 High Street, Pottstown, Pennsylvania 19464. A copy may be obtained on request addressed to the U.S. Nuclear Regulatory Connission Washington, D.C.
20555, littention: Walter R. Butler, (301) 492-7456.
Dated at Bethesda, Maryland this 26th day of Februarj,1986 FOR THE NUCLEAR REGULATORY COMMISSION
, 4 Walter R. Butler, Director BWR Project Directorate No. 4 Division of BWR Licensing
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