ML20196B008
| ML20196B008 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 06/23/1988 |
| From: | Fogarty E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Murley T Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8806300177 | |
| Download: ML20196B008 (4) | |
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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHI A, PA 19101 (zis) e41.sozo c.r.roGARTY uv etaan.'u o=
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June 23, 1988 Docket Nos. 50-277 50-278 Dr. Thomas E. Murley Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
Subject:
Peach Bottom Atomic Power Station Units 2 and 3 Request for Exemption from Certain Requirements of Appendix J to 10 CFR 50
Reference:
Letter from J. W. Gallagher (PECo) to T.
E. Murley (NRC) dated April 21, 1988
Dear Dr. Murley:
On April 21, 1988, Philadelphia Electri', Company filed with the Commission, a revised request for exemption from certain requirements of Appendix J of 10 CFR 50.
In that submittal, it was stated that Licensee would file an exemption request for penetration M-102D (Breathing Air System) provided that vendor documentation could be obtained to justify the exemption.
Attachment A of this letter provides Licensee's exemption request on this subject which conforms t o t '.a requirements of 10 CFR 50.12(a).
If you have any questions, please do not hesitate to contact us.
Very truly yours, cc:
Addressee 4{]
W.
T. Russell, Administrator, Region I, USNRC g 0 T.
P. Johnson, USNRC Senior Resident Inspector T.
E. Magette, State of Maryland i
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Attachmsnt A Docket Nos. 50-277 50-278 Page 1 Peach Bottom Atomic Power Station Units 2 and 3 Request for Exemption from the Requirements of Paragraph III.C.1 of 10 CFR 50, Appendix J Exemption Requested:
Philadelphia Electric Company requests an exemption from the requirements of 10 CPR 50, Appendix J, Paragraph III.C.l.
Paragraph III.C.1 states that the test pressure shall be applied in the same direction that accident pressure is applied when the valve is required to perform its safety function unless it can be shown that tests using a test pressure applied in a different direction will yield equivalent or more conservative results.
An exemption is requested from this' requirement so as to permit a Type C (local leak rate) test of the below identified inboard containment isolation valve in the reverse direction.
Justification for Requested Exemption:
The requested exemption may be granted by the NRC under 10 CFR 50.12(a) provided that the exemption is: I) authorized by law; II) will not present an undue risk to the public health and safety; III) is consistent with the common defense and security; and IV) justified by the presence of special circumstances of the type identified in Section 50.12(a)(2).
I.
The Requested Exemption and the Activities Which Would be Allowed Thereunder are Authorized by Law If the criteria established in 10 CFR 50.12(a) are satisfied, and if no other prohibition of law exists to preclude the activities which would be authorized by the requested exemption, the Commission is authorized by law to grant the exemption request.
Since, as demonstrated herein, the requested exemption meets the applicable criteria and there is no legal prohibition to its grant, the Commission is o-authorized by law to grant the exemption.
II.
The Requested Exemption Will Not Present an Undue Risk to the Public Health and Safety For the reasons stated in Section IV, Special Circumstances, the proposed local leak rate testing of the containment isolation valve in the reverse direction, in lieu of the specified Appendix J requirements, does not present undue risk to the public health and safety.
The proposed alternative testing will equally determine the condition of
F-Attachmsnt A Docket Nos. 50-277 50-278 Page 2-4 the isolation valve and its ability to maintain containment isolation integrity during an accident.
III. The Requested Exemption is Consistent with the Common Defense and Security The common defense and security are not endangered by this exemption request.
Only the potential impact on public health and safety is at issue and has been determined to be inconsequential.
IV.
Special Circumstances Two special circumstances of the type described 1.n 10 CPR 50.12(a)(2) are present in the request under cons;ideration in that: (a) the application of the regulation is nct necessary to achieve the underlying purpose of the rule, and; (b) compliance would result in undue hardship.
The purpose of 10 CFR 50, Appendix J is to provide appropriate containment leakage test requirements for nuclear power reactors.
The underlying purpose is to demonstrate by periodic testing that the primary reactor containment will be able to perform its function of providing a leak tight barrier against the uncontrolled release of radioactivity to the environment.
The alternative measures proposed in the discussion below will meet the underlying purpose of the regulation.
10 CPR 50, Appendix J, III.C.1 states that test pressure shall be applied in the same direction that accident pressure is applied when the valve is required to perform its safety function unless it can be shown that tests using a test pressure applied in a different direction will yield equivalent or more conservative results.
An exemption is requested to Type C (local leak rate) test the following inboard containment isolation valve (gate type) in the reverse direction.
Containment Isolation Valve Tested in Reverse Direction Pen. #
(N-
)
System Description
Valve #
Type Unit (s) 102B Breathing Air System HV-3-36E-33043 GT 3
The subject valve is a manual gate valve which is locked closed during power operation.
The 3" line which contains the manual gate valve is used to supply breathing air to the drywell during an outage.
The valve is shown on the Peach Bottom Atomic Power Station UFSAR Figure 7.3.llj.
The basis
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- Attachmsnt A Docket Nos. 50-277 50-278' Page 3 for this exemption lies in the fact that the normal force between the seat and the disc generated by stem force alone is greater than ten (10) times the normal force induced by test differential pressure of 49.1-psig which is the calculated peak accident _ pressure.
Therefore, it is unlikely that the 49.1 psig test pressure will lift the valve disc off its seat during a forward direction or reverse direction local leak rate test due to the magnitude of the thrust generated.- The sealing capabilities are essentially s
equivalent regardless of the direction in which the test pressure is applied.
Therefore, in lieu of the forward test, a reverse test pressure would be applied which would equally demonstrate the sealing capabilities of the valve.
The necessary hardware modifications that would need to be installed in order to Type C (local leak rate) test the aforementioned line in the forward direction are as follows:
Pen. #
(N-
)
Hardware Required 102B 1 - 3" block valve 1 - 1" test connection Application of the Appendix J, III.C.1 requirements would require monetary expenditures and additional radiation dose to workers to install the above block valve and test connection inside containment for forward testing with no commensurate increase in safety levels.
In addition, the forward flow test would have to be conducted inside primary containment, subjecting those performing the test to higher radiation doses.
Installation of the hardware above would not be necessary to serve the underlying purpose of the rule which is to ensure that the primary containment serves as an essentially leak tight barrier against the uncontrolled release of radioactivity to the environment.
Based on the above discussion, there is no increase in the probability of higher post accident offsite or onsite doses related to the exemption, and therefore, no increase in environmental impact beyond that experienced with no exemption.
The alternative measures proposed in the discussion above, will provide assurance that the primary reactor containment.
is an essentially leak tight barrier against the uncontrolled release of radioactivity to the environment.
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