ML20195D347

Application for Amend to License NPF-39,making Mods to Certain Containment Penetrations to Permit Forward Testing of Associated Isolation Valves & Testing of Valve Packing Leakage

ML20195D347
Person / Time
Site:	Limerick
Issue date:	11/01/1988
From:	Bradley E, Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Shared Package
ML20195D327	List: ML20195D324 ML20195D347 ML20195D354
References
NUDOCS 8811040321
Download: ML20195D347 (18)

Text

, _ .

, a s'T 8 t

• - BEFORE Tile-UNITED STATES NUCLEAR REGULATORY COMMISSION in the Matter of  :

Docket No. 50-352 PillLADELPillA ELECTRIC COMPANY  :

APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSE NPP-39 Eugene J. liradley 2301 Market Street Philadelphia, Pennsylvania 19101 Attorney for

' Philadelphia Electric Company 1

l i

f RO11040321 891101

' PDR ADOCK 05000352 PDC P

. m

3 * .

k

~

UEFORE Tile UNfTED STATES NUCLEAR HEGULATORY COMMISSION g

F In the Hatter of  :

IMcket No. 50-352 PilILADELPill A El ECTRIC COMPANY  :

APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSP.

1 NPF-39 4

Philadelphia Electric Company, Licensee under Facility Operating i.icense NPP-39 l'or Limerick Generating Station, Unit 1, hereby requestu that the Technical Specifications contained in Appendix A t.o the License be amended an indleated by a vertical bar in the margin of the attached pages 3/4 6-22, 3/4 6-24, 3/4 6-26 and 3/4 6-29. Licensee proponen to modify certain containment penetrations whose inboard containment isolation va l veu havr- their stem packing exposed to cont.alnment atmosphere and proponco t.o revise testing methoda in ordur that the stem packing be included during leak testing. The penetrations will be modified t o allow per iodic testing to include leakage through e

e a

. s t

the valve (s) ntem packing in accordance with 10 CPR 50, Appendix J. hicensee also proposes to revise the associated Technical Specifications which lists the isolation valves, deleting the page notes which reference "Reverse" testing of affected isolation valves. Modifications to these penetrations would allow "Forward" testing to test valve packinq leakage along with the leakage through the valve seat.

1,1censee requesto approval of the enanges to the icotation valves and to the Technical Specifications so that the proposed modifications can be completed durinq the next refueling outage, scheduled to begin in January 1989. hicensee further requestu that the Technical Specification changes be made ettective atter complellon of the physical modifications.

T Con ta i nme ni Isolation System The design basis for the Primary Cont.ainment Isolation Synt em allows the normal and emergency passag., of fluids through the containment boundary. Isolation valves are installed at each penetration to prevent (or limit) the escape of fission products s

which would accumulate inside the containment during an accident.

At least two harriers are required at each containment ll penetration. Generally, two valveu are located between the containment atmosphere (or the reactor coolant system) and the outside atmospncre, to act as barriero, ao that failure of any alngle valve would not prevent isolation of the containment penetration during an accident.

e _ _ _ _ _ .

g- a At I.imerick Station both isolation valves are sometimes located outside the primary containment, rather than one valve inside containment and one valve outside containment. The two isolation valves are sometimes located outside of the containment for the following reasons:

o Most of these valves would be required to operate during an accident and the containment environment might be unacceptable for valve operation during an ,

accident.

i o Since the containment is inerled during operation, I

locating these valves outsfde of the containment allows periodic inspection, testing and maintenance to be performed while the plant is operating. ,

Various types of valve (i.e. gate, globe, etc.) are 7 inuta11ed at i.imerick Station for use as primary containment isolation valves. All of these valves requi re periodic tettling  ;

for leak tigntness. The methods used for periodic leak tightness testing are designated in 10 CPR SO Appendix J as type A tests, e type H tests and type C Lents. Only type C Lenting of globe valvea lu discussed below, with type A tests, type 11 testo, and the type C tenta of other valve types being outside the purview l r

of this requetit.

i i

Type C testing is accomplished on inillvidual valves and is sometimen accomplished in the "Reverse" direction, i.e., the ,

l 5

-J- l

_ _ ~ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ - _ _ . _ _ _ _ _ _

test pressure is not from the containment direction, but is from out. side t.he cont alnment , directed toward the valve in the ,

cont:alnment di rection. "Porward" testing would refer to type C I I

test ing of valves f rom the same direction 'as 'that which the valve.

would be subjected to during an accident. Tecting is accomplished on some valves in a manner, (or from a direction),

which would not include the leakage through the valve packing, because the packing is opposite from the valve globe which elicct.lvely blocke the test pressure from the packing. In those cases where the valve is installed with the packing on the containment aide of the valve, i.e., exposing the stem packing to pouaible containment pressures and creating a potential path for t

containment ttuid Icakage during an accident, t.he packing must be leak t.cated during type C Lesting. Once the affected l

penetrations are modified, the valves' stem packing could then be i

j Lype C tested. In the case of two of the isolation valves, the valve testing methods are going to be revised, without making any physical moditications, in order to allow the packing Icakage to be tested.

buring type C Leuting, both the direction of the test preuoure on the valve, the position of the valve in relationship to the containment and the position of the valve stem packing in relationship to the test pressure are of prime importance:

o birectinn of Test 1*reasure

• • t **

't i

&h i Test pressure used for type C Lesting of valves is normally required to be from the same direction an containment

. pressure during an accident ("Forward" direction), unless it can be demonstrated that the valve has the same, or more conservative, leak Lightness when tested from a different direction, o position of Valve _ Stem l'acking in Relationship to Test Pressure The valve stem packing, if it would also be exposed to containment atmosphere during an accident, is also tested for t leak tightness during type C Lesting. Further,. valves which are open during an accident, such as bio.: king valves used for f 4

testing, would have their packing exposed, because they are

only closed during testing. Therefore, the packing on block l

valves is also exposed to test prosaure during testing, 016 eking Valves,Needed

! inocking valves are installed between the containment  !

boundary wall and some of the Isolation valves to accommodate {

i testing. The closed blocking valve maintains gas pressure .

i' l introduced via a test tap permanently installed between the blocking valve and the isolation valve to be used during Type C Let. Ling. Block valves remain open except when they are being used during Type C testing. 1,1cenace propouen to add new blocking valven between containment and the existing isolation j valves llV-57-111, llV-57-105 and valve 60-1073 so that gas l 2

-s-  !

-- _a- _- - , _ _ . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _

presuure car. be applied to these valven from t.he containment "Porward" direction daring. type C testing. The "Forward" direction of testing would, therefore, allow leakage testing of these isolation valves' stem packing. The new blocking valves will be oriented such that their packings are included in the.

type C test boundary.

I'roposed Gloue Valve Changes Two types of changes are proposed for globe valves used for cor.tainment isolation:

(1) Add a blocking Valve and Test Tap A new blocking valve and test Lap would be added to allow testing on valves liv-57-Ill (Drywell Purge Exhaust), IIV 105 (Suppression l'ool Purge Exhaust) and 60-1073 (ILRT Data Acquisition System).

(2) {tevised testing methods wlli allow testing valves 60-1057 and t10-1071 in_the "Porward" direction to incl _ude leak testing of yiese two valve (s) stem packing l'enetrations 40 G-1 and 40 G-2 are isolated by valves 60-1057 L

and 60-1071 located outside containm.'nt. A revised method of tenting these valves will allow "Porward" testing, including leak testing of the valve (s) stem packing, A temporary test plug and test rig will be used for type C testing from inside

g &

the containment which will allow testing the valve (s) stem packing.

M3 L 0tles o_f_ Proposed Technical Specification Changes "Note 5" la present.ly listed in the Technical Specification, penetration listing on pages .1/4 6-22, 3/4 6-24, 3/4 6-26 and 3/4 6-29. "Note 5" states, "inboard globe valve teated in Lne reverse direction." All of the proposed changes to the technical upecifications are related to deletion of "note 5" trom the valve penetration lintings for penetrations 26, 40G-1, 40G-2, 202 and 227. No other technical specillcation changes are being proposed. The changes to the Technical Specifications for these five valves are all related and involve the position of the valve and type C testing of the valve stem packing.

List of Proponed Changen to the Technical Specifications Table 3.6.3-1 Pa r t _A Propoued Change ,

Penetration 26 Delete reference to note 5 for vaive llV-57-111.

(Drywell Purge 10xhaust)

Penetration 40G-1 Delete reference to note 5 on valve 60-1057 (ILRT Data acquinition penetration)

Penet. rat ion 40G-2 Delete reference to note 5 on valve 60-1071 (1LRT Data ai:quisition penetration)

Penetratlon 202 Delete reference to note 5 on va 1ve IIV-57-105.

(Suppression Pool Purge Exhaust)

Penetration 22*/ Delete reference to Note 5 on valve 60-1073. (ILRT Data Acquisition System)

Safety Significance - Proposed Isolation Valve Changes The addition of blocking valves and tent taps and/or revised testing methods will allow the affected penetration luolation vaivan to be leak tented in the "Porward" direction including the valve stem packing. Leak testing of the valve olem packing will allow timely repairs to any valves which have excensive packing leakage. The timely repairn of defective valven decteases the posaibiliLy for containment atmosphere to ,

1 eucape to the environment during an accident. The effectiveness of the inolation nystem in therefore increaand by the proposed changea.

gigniticant llazarda Considerationn - Cor.tainment luolatlon Valve Changen

The addition of blocking valves and test laps, and/or revising Leut methods, does not involve any Significant ilazards Considerallons. In order to support a No Significant llazards Consideration determination, necessary background supporting information su provided below, along with an evaluation of each ot the three standards set forth in title 10 CFR section ! O 92.

(1J Operation of the plant under LL,' p oposed Technical Specifications after the addition <.f Blocking yalves and test taps and/or revisan@ the leakage testing methods, would not involve a significant increase in the probabilltv or cons gggnces of an accident _previously evaluated.

The containment isolation system is evaluated in section 6.2.1.1 of the Final Safety Analysis tport. The Final Safety Analysis 11eport evaluated the containment luotation system in eleven design areas:

a. The containment isolation system is designed to allow

he normal or emergency passage of fluids through the containment boundary while preserving the ability of the boundary lo prevent. or limit the escape of radioactive materialu that can result from postulated accidents.

o The addition at blocking valven and test taps will not affect the ability of the luolation system to limit or prevent the encape of radioactive

_9

-g l-materials that cculd result from postulated accidents.

b. The containment isolation system lu designed to either automatically isolate fluid penetrations or provide the capability for remote manual isolation from the control rocm.

o Isutomatic and remote manual isolation would remain the same at ter the proposed modifications.

t

c. The arrangement of containment is0.ation valves for 1

fluid systems that penetrate the primary containment conforms to General Design Criteria 54, 55, 56 and 57 to the greatest extent practin ble, i

o The isolation valves wou1J continue to conform to General Design criteria SA, 55, 56 and 57 to the l name degree as the origina': design, after the ,

proposed modifications.

f

d. Pluid instrument lines that penetrate primary containment conform to the isolation criteria of llegulatory Guide 1.11 to the greatent extent ,

i practicable.

o No fluid instrument lines are affected by the t proposed modifications.

t

e. Containment isolation provisicns are designed to withstand the most severe natural phenomer.on or site-related event (e.g., carthquake, tornado, hurricane, flood, or transportation accident) without impairing their functions, o Stress and pipe support calculations have been reviewed to enoure that changen and additions natisfy the existing seismic dealgn criteria.

f. 'Ibe containment isolation nystem in designed with proviolons for periodic operability and leak rate Leuting.

o The proposed modifications would allow more effective and accurate leak rate testing. Periodic operability and leak rate testing provinions on inolation valves will be enhanced by the proposed modifications and new testing snuthods,

g. Valve closure timen are nelected to ininimize the release of containment almanphere to the environn, to mitigate oftnite radiological consequences, and to ensure that 1:CCS effectivenena is not degraded.

o Valve clonure timen would not be affected by the proposed modifIcatlona.

0 ,

h. tiesign provisionu are made to detect possible leakage ,

trom lines ~provided with remote manually controlled i luotation valves, o The leak detection provisions would not be affected -

by the proposed modifications,

l. luolation valves, actuators, and controls are protected against loss of functional capability from missiles and impact accident environments.

1 o The proposed modificallon has been evaluated for protection against loss of functional capability

from missiles and impact accidents.

l i

j. Redundancy and physical separation are provided in the electrical and mechanical deolgn to ensure that no  !

ulngle failure in the containment luolation system can '

4 r

prevent the system from performing its intended ,.

l i tunction. l l

o No changen are proposed in the design of the t

electrical and mechanical redundancy and separation j i

i provisions for isolation valveu. l L. The design of the control systems for automatic ,

concainment isolation valvoo is such that resettlug the  !

f I  !

l l

t

Isolation signal does not result in the automatic reopening of containment isolation valves.

o. The design for isolation valven will continue to maintain the containment isolation valves closed after_ resetting the isolation nignal.

Isaued on the design arean discussed above, as previously evaluated in the Pinal Safety Analynio Report, and based on the determinallon that there'would be'no significant changes to these arcan following the proposed modifications, operation of the plant under the propoced technical specifications after the addillon of blocking valves and test taps and/or revising the test methods would not involve a significant increase in the probability or consequences of an accident previously evaluated.

(2) Onoration of the plant und'r the proposed Technical Specifications after the addition of blocking valves and tent _tapa_and after revising the leakage test methodn for valves 60-LO57 and 60-1071, would not create the pounibility__of a new or different kind _of accident from

.ny, accident previously evaluated.

3 Chapter 15 of the Final Safety Analynis Heport examined postulated aceldento to determine their effect on the containment tuolation nyatem. The barrier performance nections, (an explained in PSAR section 15.0.3.4) includen analysis of anticipated operational occurrences (e.g., l.ous of Electrical i

I,oa d ) ; off-design, ahnormal transients; pontulated accidents (e.g., sudden loss of a major component) and; hypothetical events l

suen an an anticipated transient without scram. The proposed  !

modifications would not adversely affect any of theno analyses.

Adding block valves and test taps and/or revising the leakage test methods, would not change the evaluations made in the Final Sately Analysis Section 15, and therefore, the proposed changes would not increase the possibility of a new or different type accident from those previously evaluated.

(3) Operation of the plant under the proposed Technical Specifications after the addition of_ blocking valves and test laps and/or revising the leakage test methods, would not involve a significant reduction in a margin of[

safety.

Tne existing margin of safety for the containment isolation valves is based upon the assurance of operability, the isolation closure times of the valves and the leak tightness of these valves. This margin of safety is periodically confirmed by surveillance testing, which would continue on the same schedule following the valve modifications. Surveillance testing would continue, atter making the proposed modifications, to verify that the icolation valves:

o Maintain leak Lightneus to a degree which provides an adequale margin of safety.

o Close af.ter receipt of a closure signal in a time which would preclude escape of radioactive materlain to the environs.

c- o Continue to remain operable, isolating the containment in the event of an accident and would continue to be periodically tested for continued operability, liccause of a new ability for better leakage testing of containment isolation valve stem packing, the proposed modifications would be more conservallye in the event of challenges to the containment isolation system, because packing '

leakage if excessive, would be discovered and corrected. Based on continued testing of the containment isolation valves' operability, their closure times and their leak tightness, j following modt[ications, the proposed changes would not involve a

significant reduction in a margin of safety.

Conclusion:

llaned on the three standards discussed above, operation of the facility after the addition of blocking valves and test [

tapa uued tor testing containment isolation valves IIV 57-111, IIV-57-105 and 60-1073; and revising the testing methods for those valves and 60--1057 and 60-1071, so that the . tinting of isolation valves in the Technical Specifications can be revised to indicate "Forward" Lesting of ';hese valves, involves no Significant j llazards Considerations.  !

. -1S-e

l '

4 9 /

Environmental Considerations This amendment would allow "Porward" testing of five isolation valves in order to include leakage testing of the valves' stem packing and wculd also delete "note 5" from Tecnnical Speci fication lir.eing of the isolation valves.

The proposed changes do not involve any increase in the amounts and no changes in the typeu of effluents that may be released offsite. No increase will occur in the individual or cumulative occupational radiation exposure. Therefore, no environmental impact report is required.

Conclusion The Plant Operations Review Committee and the Nuclear Review Board have reviewed these proposed changes to the Technical Specifications and have concluded that they do not involve Significant llazards Considerations, do not involve an unreviewed catet y question, do not involve environmental conuiderations and will not e.ndanger the healt h and safety of the public.

Respectfully submitted, PilILADELPilIA ELECTRIC COMPANY L

Vice Pro ' Bent n.

, v.

• ^

s .

COMMONWEALTH OF. PENNSYLVANIA'

ss.

COUNTY OF PHILADELPHIA  :

I t

J. W. Gallagher, being first duly swcrn, deposes and

. says:

1 1

That he is Vice President of Philadelphia Electric Compar.y, the Applicant herein; that he has read the foregoing <

Application.for Amendment of Facility Operating License.and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.

% h _00 + } : _-

u u Subscribed and sworn to d

before me this / day of kWin /zA, / 7 T' T

_j{ht ! r- P f- c, $~a l Notary Public NoTANAL SEAL MgtfjaE R CAMPANELLA Notsfy Put*C

. Civ et Pechia, Phits Coun4 >

w m-w Exevee Feti 12.1990

- _- - - -- ___- ______--