ML20155A529
| ML20155A529 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 09/23/1988 |
| From: | Kowalski S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Murley T Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8810050341 | |
| Download: ML20155A529 (4) | |
Text
,:
PHILADELPHIA ELECTRIC COMPANY 23Ol MARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101
{215) 841 4501
- 5. J. KOWALSKI September 23, 1988 vice passionen 1CCFR50 App, J
.m..............
Dr. Thomas E. Murley, Director Docket Nos. 50-352 50-353 Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Ccomission Attn: Doctment Control Desk Mall Station P1-137 Washington, DC 20555
SUBJECT:
Limerick Generating Station, Units 1 and 2 Request for Exmption frcm Paragraphs II.H.4 and I!!.C of Appendix J to 10CFR 50
Dear Dr. Murley:
Philadelphia Electric Company requests an exemption frcm Paragraphs 11.H.4 and !!I.C of 10CFR50, Appendix J for suppression pool inboard contalrment isolation valves that are on lines that ter.minate below the minintm suppression pool water level. The attactment c.o this letter provides Licensee's exemption request on this subject which conforms to the requirements of 10CFR 50.12(a).
If you have any questions, please do not hesitate to contact us.
Very truly rs, IM/eabo6228802 Attactrnent Copy to: Addressee R. J. Clark, USNRC Project Manager j
W. T. Russell, Administrator, Region I, USNRC T. J. Kenny, USNRC Senior Resident Inspector, LGS - 1 R. A. Granm, USNRC Senior Resident inspector, LGS - 2 fol1 OgCH 41 f3GO9,73 m
l ObOOO35p'
\\
P VNU v
_1 LGS Units 1 r. 2
"~
Docket Nos. 50-352 50-353 Request for Exenotion f rom the Requirements of Paragraphs II.H.4 and lli.C OF 10 CFR 50, Appendix J ExemotIon Requested:
r Philadelphia Electric Conpany requests an exemption frcm the requirements of 10 CFR 50, Appendix J, Paragraphs II.H.4 and III.C.
Paragraphs ll.H.4 and I!!.C require leak rate testing of all suppression pool piping penetrations. An exenttion frcm Type C testing is requested for the stem packing of suppressicn pool inboard containment a
Isolation valves that are on lines that tenninate below the n suppression pool water 1cvel. As a result of the valve stem ;..
.ng testing program developed at Peach Bottom Atcmic Power Station in response to the Notice of Violation contained in Inspection Report Nos.
50-277/85-23 and 50-278/85-23, a slml11ar program Is being conducted at Limerick Generating Station. This request for exerrotion represents part of that effort.
Justification for Requested Exemption:
The requested exemption may be granted by the.RC under 10 CFR 50.12(a) provided that the exemption is:
- 1) authorized by law; !!) will not l
l
~esent an undue risk to the pubile health and safety; III) is 1sistent with the ccamun defense and security; and IV) Justifled by
..e presence of special circunstances of the type identified in Section 1
50.12(aX2).
l The Requested Exemptions and the Activities Which Would Be I
A11 cued Thereunder Are Authorized by Law i
v if the criteria established in 10 CFR 50.12(a) are satisfied, and i
if no other prohibition of law exists to preclude the activt ties which would be authori::ed by the requested excmption, then the Ccmnission is authorized by law to grant the exemption request.
Since, as denenstrated herein, the requested excnotion meets the applicable criteria and there is no legal prohibition to its j
grant, the Ccmnission is authorized by law to grant the exemption.
l
!!. _The Requested Exerrotion Will Not Present an Unduo Risk to the Public Health ard Safety, For the reasons stated in Section IV, Special Circunstances, the l
requested exenttien f rcm local leak rate testing the stem packing i
of water covered suppression pool inboard containment 1 solation valves does not present undue risk to the public health and safety i
because design features exist that will significantly Ilmit the
(
j escape of gaseous fission prodects frcm contalnnent through the stem packing glands of these valves.
In addition, any stem l
l packing leakage wcold be into the Reactor Enclosure (Secondary l
Contalrrnent) thus facilitating collection and treatment.
[
l 111. The Recuested Exemption is Consistent with the Ccmron Defense, l
and Security l
j t
l
)
The ccamon defense and security are not endangered by this excrnption request. Only the potential Impact on pubile health and f
safety is at issue and has been detennined to be inconsequential.
]
,s
.g.
LGS Units 1 & 2 Docket Nos. 50-352
^
50-353 IV.
Special Circunstances Tvo special circumstances of the type described in 10 CFR 50.12(a)(2) are present in the request under consideration in a
that: (a) the application of the regulation is not necessary to achieve the underlying purpose of the rule; and (b) ccnpliance would result in undue hardship.
The purpose of 10 CFR 50, Appendix J !s to provide appropriate containment leakage test reautr eents for nuclear power reactors.
The underlying purpose is to denenstrate by periodic testing that the primary reactor contalrnent will be able to perform its (tnction of providing a leak tight barrier against the uncontrolled release of radioactivity to the envirorment. The alternative measures In the discussion below, in lleu of the l
j opp 11 cable Appendix J, Type C test, will meet the underlying purpose of the regulation.
(
t 10 CFR 50, Appendix J, Paragraphs II.H.4 and II.C requires local leak rate testing of all suppression pool piping penetrations. An exemption of Type C (local leak rate) testing is requested for the a
stem packing of suppression pool inboard contalrment isolation valves that are on lines that terminate below the minimtm suppression pool water level. These valves are currently Type C tested in the reverse post-LOCA flow direction with test pressure 4
tending to unseat the valves.
In this orientation, the stem packing on the globe and stop check valves would not be part of 3
L l
the test boundary. The stem packing on the gate valves would only be part of the test boundary if the wedge is pushed off its outboard seat. Thus, there is no assurance that the stem packing on these valves will be exposed to the test medlun at test pressure.
This exemption would apply to the following valves:
Pene. 8
System Description
Valve NtnterM Type
[
j 203 A-D RHR Puro Suction HV-51-1F004A-D GT 204 A,B RHR Purp Test Line and HV-51-125 A,B GT r
Containment Cooling l
206 A-D CS Puro Suction HV-52-1F001 A-D GT 207A,B CS Purp Test and Flush HV-52-1F015 A,B GB 208 B CS Puro Min. Recirc.
HV-52-1F031 B GB i
209 HPCI Puro Suction h.-55-1F042 GT I
210 HPCI Turbine Exhaust HV-55-1F072 GT 212 HPIC Puro Test and Flush HV-55-1F071 GT l
214 RCIC Puro Suction HV-49-1F031 GT 215 RCIC Turbine Exhaust HV-49-1F060 GT l
l 216 RCIC Min. Flow HV-49-1F019 GB l
I 217 RClC Vacuuri Purra Discharge HV-49-1F002 SCK l
226 A,B RHR Min Reclrc.
HV 51-105 A,B GT
[
235 CS Puro Min. Recirc.
HV-52-1F031 A GB f
l 236 HPCI Pum Min. Rect rc.
FN-55-1F012 GB 237-1 Suppression Pool Cleanup Purp HV-52-127 GT i
)
Suction 238 RHR Rollef Valve Discharge HV-C51-1F104 8 GB 239 RHR Rollef Valve Discharge hV-C51-1F103 A GB l
i
[
3 LGS Units 1 & 2 Docket Nos. 50-352 50-353 HUnit I valve numbers shown. Unit 2 valves are the same except for replacing the "1" with a "2",
e.g., HV-51-2F004A-D Legend GB-Globe Valve GT-Gate Valve SCK-Stop Check Valve These lines discharge below the minirnun suppression pool water level and will thus have a water seal after an accident which would prevent the release of gaseous fission products from the suppression pool air space. Any sten packing leakage would be into the Reactor Enclosure (Secondary Contalrrnent) thus facilitating collection and treatment. Additionally, the leak tightness of these valves 15 assured in the post accident direction at peak accident pressure during the Integrated Leak Rate Test performed every other refueling outage. With the above assurance, literal appilcation of the regulation is not necessary to achieve the underlying purpose of the rule which is to ensure the Integrity of the primary containnent against the uncontrolled release of fission products.
The minimun necessary hardware nudifications required to Type C (local leck rate) test the sten packing would be the installation of test connections at the stem leak off ports of each of the containwent isolation valves with the exception of the stop check valve on penetration N-217.
This valve would reaut re a block valve and test tap between the Isolation valve and the wetwell.
These modifications would result in undue hardship as r. result of the ncnetary expenditures with no comnensurate increase in safety levels.
Based on the above, there is reasonable assurance against undue leakage of gaseous fission products through suppression pool isolation valve stan packings provided under the exanotion and that no increase in the probability or extent of leakage of gaseous fission products through suppression pool isolation valve sten packings is to be expected. Therefore, there is no increase in the probability of higher post accident offsite or onslte doses related to the exanption and therefore no increase in envirormental Impact beyond that experienced with no exemption.
The discussion above provides assurance that the primary reactor containment is an essentially leak tight barrier against the uncontrolled release of radioactivity to the environrent.
MH/eab06188808
.