ML20197G750
| ML20197G750 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/13/1986 |
| From: | Eisenhut D Office of Nuclear Reactor Regulation |
| To: | Anthony R ANTHONY, R.L. |
| Shared Package | |
| ML20197G754 | List: |
| References | |
| 2.206, DD-86-06, NUDOCS 8605160389 | |
| Download: ML20197G750 (4) | |
Text
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s May 13,1986 Docket No. 50-352 (10 CFR 2.206)
Mr. Robert L. Anthony Box 186 Moylan, Pennsylvania 19065
Dear Mr. Anthony:
On March 5, 1986, the Secretary of the Commission informed you that certain pleadings filed by you with the Commission requesting a stay of License Amendment No. 1 issued on February 6, 1986 to the Philadelphia Electric Company for its Limerick Generating Station Unit 1, had been referred to the NRC Staff for consideration pursuant to 10 CFR 2.206. For the reasons set forth in the enclosed Director's Decision under 10 CFR 2.206, DD-86-06, I decline to take any action staying the effectiveness of License Amendment No. 1.
A copy of the Decision will be filed with the Secretary of the Commission for its review in accordance with 10 CFR 2.206(c) of the Commission's regu-lations. As provided by this regulation, the Decision will constitute the final action of the Commission twenty-five days after the date of issuance of the Decision unless the Commission, on its own motion, institutes a review of the Decision within that time.
I have also enclosed for your information a copy of the notice that is being filed with the Office of the Federal Register.
Sincerely, vriginal signed by Darrell G. Eisenhut, Acting Director Office of Nuclear Reactor Regulation
Enclosures:
1.
Federal Register Notice 2.
Director's Decision DD-86-06 cc: w/ enclosure See next page DISTRIBUTION See next page
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cc: Mr. Edward G. Bauer, Jr.
Vice President & General Counsel Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, DC 20555 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, DC 20555
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DD-86 06 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Harold R. Denton, Director J
In the Matter of PHILADELPHIA ELECTRIC COMPANY Docket No. 50-352 (10 CFR i 2.206)
)
(Limerick Generating Station,
)
Unit 1)
)
DIRECTOR'S DECISION UNDER 10 CFR 62.206 INTRODUCTION On December 18, 1985, the Philadelphia Electric Company (licensee), in a letter to the NRC, requested an amendment to its Limerick Unit 1 operating i
license. The licensee requested permission, on a one-time-only basis, to temporarily extend the surveillance requirements of certain valves which under the Technical Specifications must be inspected nominally every 18 months; this surveillance can only be performed when the plant is shut down. The change would extend the 18 month surveillance interval by fourteen weeks 1
i i
beyond the maximum 25 percent extension allowed by the Technical Specifications..
This amendment would permit the licensee to delay performing the testing until a maintenance and surveillance outage which is scheduled to begin on or before i
May 26, 1986.
The NRC staff, after a review of the licensee's request, determined that the condition of the valves in question would not change significantly during the short extension period. The staff found that issuance of the amendment 4
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. would not involve a significant hazards consideration and issued the amend-ment on February 6,1986.
On January 30, 1986, Mr. R. L. Anthony / Friends of the Earth in the Delaware Valley (Collectively "F0E") filed a petition to intervene in connection with the licensee's request fer an amendment and, on February 5,1986, supplemented that request with an amended petition. The NRC staff has opposed F0E's petition in a pleading filed on February 25, 1986 before the Atomic Safety and Licensino Roard (ASLB) convened to hear the matter. The ASLB, after conducting a prehearing conference on March 27, 1986, dismissed F0E's petition in a Memorandum and Order dated April 4, 1986 (ASLBP No. 86-522-07-LA (Check Valves) and ASLBP No. 86-526-04-LA (Containment Isolation)).
On February 17, 1986, F0E, after receiving notice of the issuance of License Amendment No. 1, filed with the Commission a one page request for a stay of the effectiveness of the amendment, and, in that pleading, incorporated by reference its two previous petitions to intervene.
On February 15, 1986,-F0E filed yet another pleading with the Commission containing eleven " contentions." At the end of this pleading, F0E renewed its request for a stay.
On March 5,1986, the Secretary of the Commission informed F0E by letter that its stay reouest of February 12, 1986 had been referred to the NRC staff for consideration pursuant to 10 CFR 6 2.206.
In addition, the Secretary's letter noted that, to the extent that F0E's February 15, 1986 filing requested a stay, the NRC staff was to consider it in its response pursuant to 10 CFR 2.206.
My decision in this matter follows.
t
s 3-t DISCUSSION Pursuant to 10 CFR 62.206, any person may file a request to institute a proceeding pursuant to 10 CFR 5 2.202 to modify, suspend or revoke a license, or for such other action as may be proper. The F0E request for a stay in the context of a license amendment proceeding following the effective date of the amendment is, in the context of 10 CFR 5 2.206, a request for an order immedi-ately suspending the effectiveness of the amendment and an order to show cause why the amendment should not be revoked. To warrant such an order, substantial health or safety issues must be raised. Consolidated Edison Co. of New York (Indian Point, Units 1, 2, and 3), CLI-75-8, 2 NRC 173,176 (1975); Washington Public Power Supply System (WPPSS Nuclear Project No. 2), DD-84-7, 19.NRC 899, 923 (1984). Clearly this is not the case here.
The matter at hand involved a modest extension of a surveillance interval for certain valves. The matter has been specifically evaluated by the NRC staff in its Safety Evaluation Supporting Amendment No. I to License No. NPF-39 of February 6, 1986, a copy of which is enclosed, supporting issuance of the amendment. There the staff concluded:
The safety related aspects of extending this surveillance interval on a one time basis for about three months are insignificant for the following reasons.
(1) Flow through the valves or from the lines in which they are located will be limited by the small line size and the provision of flow restricting orifices to further reduce potential flow rates.
(2) Any leakage from these lines outside of primary containment would be contained in the secondary containment and processed by the standby gas treatment system. The analysis of such an event has already been performed and is included in the Final Safety Analysis Report in Section 15.6.2.
As indicated in the FSAR there would likely be a variety of indicators to the operator of a failed instrument line thus alerting plant staff to the need to isolate the line by use of other manual valves in the line. The staff has previously reached the conclusion in section 15.6 of the i
SER that the Limerick instrument line design is acceptable.
(3) The licensee has examined the records of the initial flow testing per-
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formed on these valves and found that all valves were tested success-i fully. The licensee further states that, based on available data, e
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.. the valves are believed to be highly reliable in performing their function of checking flow. The staff concludes that the condition of the valves is not expected to change significantly during the short extension period.
Based on the above, the NRC staff concludes that extension of the interval for the surveillance testing by 14 weeks on a one-time s
only basis is acceptable because the increased surveillance interval does not significantly increase the possibility that an uiidetected failure will occur in the instrumentation line excess flow check valves covered by this Technical Specification. Safety Evaluation.
Support Amendment No. 1, Facility Operating License No. NPF-39, Philadelphia Electric Company, (Limerick Generating Station, Unit No. 1), at 2 (February 6, 1986.)
F0E presents no sound arguments calling the staff's view into question.
While F0E does make reference in its January 30, 1986 filing to the " Independent Design Review of the Limerick Generating Station, Unit No. 1, Core Spray System" (IDVP) performed by Torrey Pines Technology, the Torrey Pines findings have no.
bearing on the license amendment at hand.
In this regard, as mentioned by F0E, the IDVP focused on the effects on instrumentation lines of jet impingement from-j a postulated core spray line break. No effort is made by F0E to establish a nexus with the subject matter of License Amendment No. 1.
The staff notes that the subject of License Amendment No. I deals with surveillance tests which would be l
conducted periodically to determine whether the excess-flow check valves will s.
respond functionally to check tNe flow of fluid in the instrumentation lines 2
upon being subjected to excessive differential pressure across the valve. The 1
scheduling of such tests, whether perfomed more or less frequently, would have no effect on whether the instrumentation lines or the systems associated with such instrumentation lines were adequately designed to withstand the effects of ruptured pipes. This latter issue was the subject of the staff's review of the IDVP and was found to be resolved as stated in Supplement No. 4 to the Limerick Safety Evaluation Report, at Section 17 (May 1985).
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.. F0E also makes reference in its February 15, 1986 filing to several reports recently issued by the NRC staff on Probabilistic Risk Assessment (PRA) insights.
F0E references these reports as they relate to interfacing systems loss-of-coolant-accidents (LOCAs) attributable to the check valves in the resid-ual heat removal (RHR) or low pressure coolant injection (LPCI) lines. F0E fails to note however that the two plants that it has referred to are pressurized water reactors, not boiling water reactors like Limerick, and fails to provide any connection between the significance of the issue of interfacing system LOCAs for those plants and the Limerick plant. More importantly, F0E fails to note that the valves which are the subject of Amendment No. 1 to the limerick license are excess-flow check valves which are in instrumentation lines which..are designed to accommodate the primary system pressure and which terminate in the secondary containment. Accordingly, these lines are closed systems within the secondary containment and the excess flow check valves do not provide an interface between the high pressure reactor primary system and any low pressure secondary systems as do the valves of concern in the referenced PRA insights reports.
CONCLUSION In the absence of any substantial health or safety issues associated with the issuance of License Amendment No. 1, I decline to institute proceedings pursuant to 10 CFR 6 2.202. Accordingly, I decline to grant F0E its requested
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. relief pursuant to 10 CFR S 2.206. As provided by 10 CFR 2.206(c), a copy of this decision will be filed with the Secretary for the Commission's review.
odginal signed by Darrell G. Eisenhut, Acting Director Office of Nuclear Reactor Regulation Dated at Bethesda, Maryland this h day of May 1986.
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- Previously concurred:
PD#4/PM PD#4/LA PD#4/D BWEB AD/BWR OELD
- REMartin:lb
- M0'Brien
- WButler
- BDLiaw
- Glainas
- RHoefling 04/17/86 04/18/86 04/18/86 04/21/86 04/21/86 04/28/86 05/01/86
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