ML20206H485
| ML20206H485 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 04/09/1987 |
| From: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Butler W Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8704150372 | |
| Download: ML20206H485 (11) | |
Text
{{#Wiki_filter:., PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHIA PA.19101 1215) 841 5001 ""L.'"'..'.=,*" ~ " ' " ' " ~ ' Apri1 9, 1987 Docket No. 50-352 Mr. W. R. Butler, Director Project Directorate No. 4 Division of Boiling Water Reactor Licensing U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555
Dear Mr. Butler:
The purpose of this letter is to provide additional information for Philadelphia Electric Company's January 13, 1987 Application for Amendment of Facility Operating License NPF-39 which requests changes to the Technical Specifications to reflect modifications to the Standby Gas Treatment System to connect it to the refueling floor volume as required by License Condition 2(c)(14). The additional information was requested by Mr. Robert Martin, Limerick Project Manager, of the NRC staff during a meeting in Bethesda, MD on March 23, 1987. The questions are provided, followed by our responses, in the enclosure. The two requested sketches and revised Technical Specification Bases pages are also enclosed. If you have any questions concerning our responses or require more additional information, please do not hesitate to contact us. Very truly yours, 8704150372 870409 ] DR ADOCK 05000352 p PDR Enclosures cc: Dr. T. E. Murley, Administrator, Region I, USNRC g6 Mr. Robert Martin, LGS Project Manager i fg E. M. Kelly, Senior Resident Site Inspector \\ See Attached Service List
COMMONWEALTH OF PENNSYLVANIA : a ss. { COUNTY OF PHILADELPHIA J. W. Gallagher, being first duly sworn, deposes and j i says: That he is Vice President of Philadelphia Electric Company, 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 v u Subscribed and sworn to before me thisLY ay d of Occt', i 't e' ,, J, vtV 'i. ba + / C, + 6 (/ Notary Public JUDITH Y. FRANKLIN Notary Public PNie Phile. Co. My Commission Expires July 26,1967
Dockzt No. 50-352 PHILADELPHIA ELECTRIC COMPANY RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION RESULTING FROM NRC/PECO MEETING ON MARCH 23, 1987 STANDBY GAS TREATMENT SYSTEM (SGTS) MODIFICATION 1. Question: Indicate the status of the existing SGTS fans after the modification is conpleted and clarify the effect of potential missiles generated by the now SGTS fans on safe shutdowi capability.
Response
The new SGTS fans (OAV163 and OBV163) will be installed in the same rocxn and in approximately the same location as the existing SGTS fans (OAV109 and OBV109). The existing fans will be electrically disconnected and blanked off from the existing ductwork and left in place. The existing SGTS fans were previously evaluated for missile hazard protection as discussed in PECo's response to FSAR Question 410.10. The analysis and conclusions reached in this response were evaluated for applicability to the new SGTS fans. Since the new SGTS fans are being installed in the same room and in approximately the same location, and were built to the same design requirements, the original conclusion that there will be no effect on safe shutdown capability resulting from potential missiles is still appilcable. FSAR Question 410.10 will be revised to include the new SGTS fans. 2. Question: Clarify the proposed Technical Specification Section 4.6.5.3.b.3 on page 3/4 6-53 of the appilcation for amendment to the license as to whether it is Intended to be Individual zone tests or a multi-zone test.
Response
The test proposed in Technical Specification Section 4.6.5.3.b.3 on page 3/4 6-53 of the application for amendment to the IIcense Is Intended to be performed as a nulti-zone test thru use of test switches. These test switches, being Installed as part of this modification, wl11 provide operator flexibility such that all the tested zones need not be isolated to perform the test. Simultaneous isolation of all the tested zones is very difficult to perform due to conflicting operational conditions during which the diffurent secondary containmont zones are required to be operable by the Technical Specifications. A multi-zone test is more conservative than a single zone test and a reactor enclosure flowrate of 2800 cfm mininun and a refueling area flowrate of 2200 cfm mininun will assure that the design drawdow1 time will be maintained. A clarification has also been added to the Technical Specification Bases which states "The Technical Specification surveillance requirement 4.6.5.3.b.3 is Intended to be a multi-zone air balance verification without isolating any test zone".
-g-3. Question Item 9. on page 3/4 6-54 of the application for amendnent to the license refers to "any major system alteration". Please define this term.
Response
A clarification of "any major system alteration" has now been added to the Technical Specification Bases on page B 3/4 6-Sa which states "... any modification which will have an effect on the SGTS flowrate such that the ability of the SGTS to drawdown the reactor enclosure to greater than or equal to 0.25 inch of vacuun water gage in less than or equal to 121 seconds could be affected". 4. Question Provide clarification of the use and controls associated with the new silde gate dampers being added to the reactor enclosure and refueling area ductwork as part of the modification.
Response
The slide gate darrpers (SGD 206-1 and SGD 206-3) are being added to provide the capability to isolate each zone from the SGTS In the event that its secondary containment isolation system is out of service as permitted by the Technical Specification. This will prevent connection of the SGTS to an area which cannot be drawndown. These silde gate dampers will have redundant external position switches to block any isolation signal to the SGTS while the damper is closed. Additionally, these position switches will annunicate a control room alarm signifying that the slide gate damper is in the closed position. Plant adninistrative procedures will assure that the slide gate damper has been returned to its locked open position prior to declaring the secondary contairvnent Isolation system operable. MJM/kkf/03258709
CONTAINMENT SYSTEMS BASES 3/4.6.5 SECONDARY CONTAINMENT Secondary containment is designed to minimize any ground level release of radioactive material which may result from an accident. The Reactor Enclosure and associated structures provide secondary containment during normal operation when the drywell is sealed and in service. At other times the drywell may be open and, when required, secondary containment integrity is specified. Establishing and maintaining a vacuum in the reactor enclosure secondary containment with the standby gas treatment system once per 18 months, along with the surveillance of the doors, hatches, dampers and valves, is adequate to ensure that there are no violations of the integrity of the secondary containment. The OPERABILITY of the reactor enclosure recirculation system and the standby gas treatment systems ensures that sufficient iodine removal capability will be available in the event of a LOCA or refueling accident (SGTS only). The reduction in containment iodine inventory reduces the resulting SITE BOUNDARY radiation doses associated with containment leakage. The operation of this system and resultant iodine removal capacity are consistent with the assumptions used in the LOCA and refueling accident analyses. Provisions have been made to continuously purge the filter plenums with instrument air when the filters are not in use to prevent buildup of moisture on the adsorbers and the HEPA filters. Although the safety analyses assumes that the reactor enclosure secondary containment drawdown time will take 135 seconds, these surveillance requirements specify a drawdown time of 121 seconds. This 14 second difference is due to the diesel generator starting and sequence loading delays which is not part of this surveillance requirement. The reactor enclosure secondary containment drawdown time analyses assumes a starting point of 0.25 inch of vacuum water gauge and worst case SGTS dirty filter flow rate of 2800 cfm. The surveillance requirements satisfy this assumption by starting the drawdown from ambient conditions and connecting the adjacent reactor enclosure and refueling area to the SGTS to split the exhaust flow between the three zones and verifying a minimum flow rate of 2800 cfm from the test zone. This simulates the worst case flow alignment and verifies adequate flow is available to drawdown the test zone within the required time. The Technical Specification Surveillance Requirement 4.6.5.3.b.3 is intended to be a multi-zone air balance verification without isolating any test zone. LIMERICK - UNIT 1 B 3/4 6-5
CONTAINMENT SYSTEMS (Continued) BASES The SGTS fans are sized for three zones and therefore, when aligned to a single zone or two zones, will have excess capacity to more quickly drawdown the affected zones. There is no maximum flow limit to individual zones or pairs of zones and the air balance and drawdown time are verified when all three zones are connected to the SGTS. The three zone air balance verification and drawdown test will be done prior to initial criticality of Unit 2 or after any major system 3 alteration,which is any modification which will have an effect on the SGTS flowrate such that the ability of the SGTS to drawdown the reactor enclosure to greater than or equal to 0.25 inch of vacuum water gage in less than or equal to 121 seconds could be affected. The field tests for bypass leakage across the SGTS charcoal adsorber and HEPA filter banks are performed at a flow rate of 3000 + 10% cfm. This flow rate corresponds to the maximum overall three zone inleakage rate of 3264 cfm. The SGTS filter train pressure drop is a function of air flow rate and filter conditions. Surveillance testing is performed using i either the SGTS or drywell purge fans to provide operating convenience. Each reactor enclosure secondary containment zone and refueling area secondary containment zone is tested independently to verify the design leak tightness. A design leak tightness of 1250 cfm or less for each reactor enclosure and 764 cfm or less for the refueling area at a 0.25 inch of vacuum water gage will ensure that containment integrity is maintained at an acceptable level if all zones are connected to the SGTS at the same time. 3/4.6.6 PRIMARY CONTAINMENT ATMOSPHERE CONTROL i The OPERABILITY of the systems required for the detection and control of hydrogen combustible mixtures of hydrogen and oxygen ensures that these systems will be available to maintain the hydrogen concentration within the primary containment below the lower flammability limit during post-LOCA conditions. The primary containment hydrogen recombiner is provided to maintain the oxygen concentration below the lower flammability limit. The combustible gas analyzer is provided to continuously monitor, both during normal operations and post-LOCA, the hydrogen and oxygen; concentrations in the primary containment. The primary containment atmospheric mixing system is provided to ensure adequate mixing of the containment atmosphere to prevent localized accumulations of hydrogen and oxygen from exceeding the lower flammability limit. The hydrogen control system is consistent with the recommendations of Regulatory Guide 1.7, " Control of Combustible Gas Concentrations in Containment Following a i LOCA," March 1971. B3/4 6-Sa LIMERICK - UNIT 1
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