ML20210B319
| ML20210B319 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/01/1987 |
| From: | Cooney M PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Butler W NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8705050286 | |
| Download: ML20210B319 (1) | |
Text
._ __
PHILADELPHIA ELECTRIC COMPANY 23O1 MARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 (215)s41 so20 u.a.cooney May 1, 1987 MANAGER nwcksam supponT semantasum?
Mr. W. R. Butler, Director Project Directorate I-2 Division of Reactor Projects ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C.
20555
SUBJECT:
Application Fee for Limerick Generating Station Unit 1 Request to Remove Reactor Head Spray and Vent Piping and Detension Studs
Reference:
Letter, J. W. Gallagher, PECo, to W. R. Butler, NRC, d6ted April 22, 1987
Dear Mr. Butler:
Please find herein Philadelphia Electric Company's check for $150.00, which was inadvertently not enclosed in the referenced letter, in full compliance with Section 170.12 of the Commission's Regulations.
In the referenced letter, the Commission was requested to review our plans for removal of the Reactor Pressure Vessel (RPV) head spray and vent piping and detensioning the RPV head studs prior to connecting the Standby Gas Treatment System to the refueling area.
We regret any inconvenience the delay in submitting the application fee may have caused.
Very truly yours, 2,
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e Attachments g
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W. T.
Russell, Administrator, Region I, USNRC E. M.
Kelly, Senior Resident Site Inspector See Attached Service List 8705050286 870501 PDR ADOCK 05000352 p
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,p PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. EOX E699 PHILA D ELPHI A. PA.19101 (215] 8415 Col JOSEPH W. G ALLAGH ER
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April 22,1987 Decket No. 50-352 Mr. W. R. Butler BWR Project Directorate 94 Divisicn of Bolling Water Reactor Licensing U.S. Nuclear Regulatory Connissicn Atter.t icn: Document Control Desk Washington, DC 20555
SUBJECT:
Limerick Generating Station Unit 1 Removal of Reactor Head Spray and Vent Piping and Vessel Stud Detensioning
REFERENCES:
a) Letter, V. S. Boyer (PECo) to H. R. Denten (NRC),
Dated September 21, 1984 b) Letter, d. W. Gallagher (PECo) to W. R. Butler (NRC),
Dated March 19, 1987
Dear Mr. Butler:
Limerick Generating Station Unit 1 License Condition 2.C.14 states that until the Standby Gas Treatment System (SGTS) is connected to the refueling area, the Licensee shall not renove the RPV head prior to NRC staff review and approval. License Ccndition 2.C.14 references Section 6.2.3 of SSER-2 and SSER-3 which states that until the SGTS is connected to the refueling area, operations involving removal of the Primary Centainment head as well as the RPV head after initial criticality are prohibited without specific prior NRC approval. This same condition is contained in reference a).
Reference b) requested NRC approval to remove the drywell head prior to connection of the SGTS to the refueling floor. With approval of that request, our plans for the upcoming refueling outage call for removal of the RPV head spray and vent piping and detensioning the RPV head studs prior to connecting the SGTS to the refueling area.
A Safety Evaluation has been performed which concludes,that the SGTS need not be connected to the refueling area while removing the RPV head spray and vent piping and detensicning the RPV head studs for the ar_
folicwing reasons:
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d Removal of the RPV head spray and vent piping and detensioning the the RPV head studs can not result in fuel
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' damage requiring the use of the SGTS to control the release of radiation.
SGTS is not required by the Technical Specification Limiting Conditions for Operation to be operable during removal of the RPV head spray and vent piping and detensioning the RPV head studs.
There'are no Technical Specification Limiting Conditions for Operation requiring that the refueling area secondary containment integrity be verified prior to performing the aforementioned operations. Refueling area secondary containment integrity will be verified prior to handling Irradiated fuel, perfonning core alterations, or operations with the potential to drain the vessel as required by Technical Specification Sectico 3/4.6.5.1.2 Acceptable limits on primary coolant radioactivity prior to initiating the removal of the RPV head spray and vent piping and detensioning the studs can be determined based en the LGS Technical Specification Instantaneous Limits (3.11.2).
Current primary coolant activity is approximately q
1 x 10 uCl/sm (I-131 dose equivalent.) Conservative calculations Indicate that a coolant activity ilmit of 3.65 Ci or 0.02 uCI/gm (I-131 dose equivalent), more than two orders of magnitude above the current coolant activity, will ensure that offsite doses will remain below Technical Specification ilmits. The calculation on which this limit is based is attached (Attachment I).
Prior to removal of the piping and detensioning the studs, coolant activity will be verified to be below the calculated limit.
Irrmediately ypon breaching the flanged connections between the 6" RPV head spray and 4" vent piping and the RPV head, health physics surveys are taken to ensure excessive radioactivity will not be released when the piping is conpletely rerreved. As soon as the piping is removed, blank flanges or HEPA filters are installed on the two RPV head flanges to inhibit the direct corrmtnication between the reactor coolant and the refueling area. The above steps are not unique to the first refueling outage. They are part of the standard procedures to be followed during any refueling outage, as shown in the refueling outage flow diagram, FSAR Figure 9.1-13.
The removal of the RPV head spray and vent piping and detensioning the RPV head studs will be performed in accordance with the appropriate approved plant procedures to assure that the asstrnptions, actions, and conclusions presented in the above discussions remain valid.
Based on the above considerations, it is not necessary to have the SGTS connected to the refueling area prior to the removal of the RPV head spray and vent piping and detensioning the RPV head studs.
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', In ceder to confonn with the intent of license condition 2.C.14, Philadelphia Electric Ccrnpany requests NRC approval to remove the RPV head spray _ and vent piping and detension the RPV head studs prior to the cennecticn of SGTS to the refueling ficor.
If you have any questicns or require addIticnal information en this subject, please do not hesitate to centact us.
In accordance with Section 170.12 of the Ccanission's regulations, enclosed is Philadelphia Electric Ccmpany's check in the amount of
$150.00 to cover the filing fee.
Very truly ycurs, CW/cb/,04028709 Attachment Copy to: Addressee W. T. Russell, Regional Administrator, USNRC, Region I C. Kelly, Senior Resident Site Inspector See Attached Service List t
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a ATTACFNENT I Technical Specification 3.11.2 Instantaneous Limits Definitions:
X/Q = dispersion factor BR
= breathing rate D.F. = dose conversion factor D
= maximum permitted dose Dose = (1500 mr/yr) (1 yr./8760 hr.) (8 hr.)
= 1.37 mr D
= (ci) (x/Q) (BR) (D.F.), assuning an 8 hr. release q
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Where x/Q = 7.3 x 10 s/m per EROL Table 7.1-6 (8 hr. av.)
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BR'
= 1.17 x 10 m /s per R.G.1.109 9
D.F. = 4.39 x 10 mrem /Ci per R.G.' 1 *109 D
= 1.37 mr C'i'~= (Coolant Activity) (Release Fraction)
= CA (RF)
Where: RF = 0.01 per R.G. 1.25 CA
=
D
=
1.37 (RF) (x/Q) (BR) (DF)
(0.01) (1.17 x 10 ') (7.3 x 10 ') (4.39 x 10'),
= 3.65 Ci
= 2 x 10~ uCI/gm i
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