ML20216E492
| ML20216E492 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 09/04/1997 |
| From: | Geoffrey Edwards PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-89-10, NUDOCS 9709100205 | |
| Download: ML20216E492 (5) | |
Text
Garr tt D.Edw:rd)
Plant Manager A
Itach Bottom Atonuc ftwer Statnwi
=_,.
PECO NUCLEAR ncme c-1848 Lay Road A UNtr or /YC()[Af g;>
Detta PA 17314 9032 717 456 4244 September 4, 1997 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
Subject:
Peach Bottom Atomic Power Station (PBAPS) Units 2 & 3 Generic Letter 8910 Program Closure Plan Status
Reference:
1)
Letter from U.S. Nuclear Regulatory Commission (NRC) to D. M. Smith (PECO Energy Company), dated June 3,1996.
2)
Letter from G.D. Edwards (PECO Energy Company) to NRC, dated August 6,1996.
In Reference 1, the NRC requested that PECO Energy Company provide a written response to address several issues identified during the NRC inspection of PECO Energy's Gs neric Letter (GL) 89-10 Program at the Peach Bottom Atomic Power Station (PBAPS) conducted March 25-29,1996 and April 9-12,1996.
Reference 2 provided PECO Energy's initial plan to address the actions required for GL 89-10 closure at Peach Bottom. Given the time that has elapsed since this initial plan was submitted, PECO wishes to provide a status update of the restraints towards Generic Letter 89-10 Program Closure as stated in Reference 1. PECO Energy will notify the NRC Staff when the actions required to resolve the program closure restraints have been completed.
If you have any questions or require additionalinformation, please do not hesitate to contact us.
Garrett D. Edwards Plant Manager Peach Bottom Atomic Power Station D'
cc:
W. T. Henrick, Public Service Electric & Gas R. R. Janati, Commonwealth of Pennsylvania H. J. Miller, US NRC, Administrator, Region i W. L. Schmidt, US NRC, Senior Resident inspector T. M. Messick, Atlantic Electric
\\
R. l. McLean, State of Maryland A. F. Kirby lil, DelMarVa Power 4,
m,
's
@\\t\\@gaa. s..\\\\
"" ' - " 5 '
9709100205 970904 PDR ADDCK 05000277-P PDR
bec:-
OEAP Coordinator 62A-1, Chesterbrook Correspondence Control Program 61B-3, Chesterbrook NCB Secretary (11) 62A-1 Chesterbrook D. M. Smith 63C 3, Chestertrook G. R. Rainey 63C-3, Chesterbrook T. N. Mitchell SMB4-9, Peach Bottom J. B. Cotton 62C-3, Chesterbrook T. J. Niessen 53A 1, Chesterbrook E. J. Cullen S23-1, Main Office E. W. Callan '
SMB4-6, Peach Bottom G; A. Hunger 62A 1 Chesterbrook J. G. Hufnagel 62A 1, Chesterbrook C. - J. McDermott S13-1, Main Office G. D. Edwards A41S, Peach Bottom M.E. Wamer SMB3-5, Peach Bottom V. Cwietniewicz PB-TC, Peach Bottom R. A, Kankus 61C 1, Chesterbrook G.J.Lengyel A4-4S, Peach Bottom j'
R. K. Smith A4 SS, Peach Bottom l
E. L Cartwright SMB 3-3, Peach Bottom m
i Status Update of Generic Letter 8910 Closure Restraints Reference 1 (Section E1.1.6) identifies the following two GL8910 Program Closure Restraints for Peach Bottom APS:
NRC Closure Restraint 1:
Provide "the plan and schedule for inclusion and verification of capability for the 16 valves, that have active safety features during surveillance testing, into the GL 89-10 Program or a PORC approved safety evaluation stating why the valves need not be included in the program and plans for ensuring that these valves can perform their safety functions".
PECO Enerav Plan Status:
l The following actions to address and/or verify design basis capability have been or will be taken conceming the 16 valves in question.
All 16 MOVs, with the exception of the Core Spray Outboard injection Valves (MO-2/3 011 A/B), will be included within the scope of GL89-10 which requires the demonstration of design basis functional capability. Reference 2 provided a preliminary capability assessment for each of these MOVs. These capability assessments still apply pending the completion of any design basis venfication activities as described below. The Core Spray Outboard injection Valves are administratively controlled such that when they are out of their normally standby position, the affected system / train is declared inoperable in accordance with PBAPS Technical Specifications and the applicable TS Action Statement is entered. in effect, the Core Spray Outboard injection Valves are conservatively treated as passive, manual valves. Therefore, a safety evaluation is not required for excluding the Core Spray Outboard injection Valves from the GL89-10 Program.
This position was reviewed at the P' ant Operation Review Committee (PORC) meeting 97-0045, MO-2/3-13-030 - RCIC Test Retum Valve A differential pressure (D-P) test for both MOVs has been completed to quantify available margin and increase our confidence in the MOV's capability. Each of these MOVs has successfully demonstrated closure capability under design basis full flow test conditions. These tests were performed during the first quarter of 1997.
MO-2/3-14-026A/B - Core Sorav Test Return Valve PCIV These MOVs are stroked closed against maximum D-P during quarterly system surveillance testing. These quarterly uninstrumented D-P tests will continue as prev,ously committed to i
maintain our confidence in the capability of these MOVs to function under worst case dynamic conditions. In effect, this quarterly surveillance testing provides periodic MOV design basis D-P testing which satisfies GL E9-10 requirements for demonstrating design basis MOV capability.
MO-2/3-23-021 - HPCI Test Return Valve PECO Energy's plan to perform an instrumented D-P test for each MOV was delayed due to potential system / equipment concems resulting from the prolonged high flow in the pump min-flow line during execution of the test. These concerns have since been resolved by verifying the size of the installed flow limiting orifice. To further improve design margin, gear changes have been completed for each of the affected MOVs. Instrumented D-P tests were performed as part of post-installation acceptance testing. These changes demonstrate analytical design margin consistent 2
. -. - ~ - - -.
.. ~ ~.. - - - -. -. - - -.. ~ -. _ -
e_
with non-testable GL89-10 MOVs further validated by in-situ design basis testing. This updated plan provides additional design margin than that previously committed to in Reference 2.
I MO-2/3 23-024 - HPCI Test Retum Valve to CST isolation MO 2/3 23-021(MO-2/3-13-030) provide the full flow test return line isolation function which prevents HPCl(RCIC) flow diversion. With these upstream valves providing the flow isolation function, the D-P across MO-2/3-23-024 is very low (< 100 psid), and adequate as left MOV capability with high margin can be analytically demonstrated by applying bounding design parameters. Since the safety related D-P for MO-2/3-23-024 is very low, an instrumented D-P test would not provide meaningful data and, consistent with Reference 2, is not planned to be
. performed.
The torque switch setting for MO-3-023-024 was reset in April 1997 to resolve a potential motor over torque concem described in Reference 2.
D The D-P calculation revision and setup criteria design change for MO-2/3-23-024 are in progress and will be completed by the end of the 3* quarter 1997, MO-2/3-23-031 - HPCI Test Retum Valve to Torus. PCIV MO-2/3-23-021(MO-2/3-13-030) provide the full flow test return line isolation function which prevents HPCl(RCIC) flow diversion., With these upstream valves providing flow isolation, the D-P across MO 2/3-23-031 is very low (<100 psid), and adequate as-left MOV capability with high margin can be analytically demonstrated by applying bounding design parameters. Since the safety related D-P for MO-2/3-23-031 is very low, an instrumented D-P test would not provide meaningful data and, consistent with Reference 2, is not planned to be performed.
1 in October 1996, the previous overthrust condition for MO-2-23 031 was resolved by verifying actuator hardware and torque requirements stipulated by Kalsi Engineering Report No.175W and PECO Specification NE-119.
The D-P calculation revision and setup criteria design change for MO 2/3-23-031 are in progress and will be completed by the end of the 3* quarter 1997.
NRC Closure Restraint 2:
Re-affirm the commitment to " dynamically test an additional Unit 3 Core Spray system injection valve to strengthen valve friction factor assumptions during the upcoming refueling outage".
PECO Enerav Plan Status:
During refueling outage 2R11, PECO Energy performed an instrumented DP test on Core Spray system injection valve MO-214-012A. Although data quality was not acceptable to extract valve factor data, tha test demonstrated capability under design basis D-P conditions, which are less than the as-tested D-P conditions, and re-affirms PECO's methodology. Additionally, the MO-3 14-012B is scheduled to undergo an instrumented DP test during the upcoming Unit 3 refueling outage. Because this testing is done during reactor pressure vessel flood-up at the beginning of a refueling outage, only one opportunity to test is available during each 24 month refuel cycle.
MO-3-14-012B will undergo repeat DP testing as part of PECO's participation in the Joint Owner's Group MOV Periodic Test (GL 96-05) Program to trend potential valve factor and actuator output degradation. This follow-up testing should be considered by the Staff as part of PECO's GL 96-05 program.
3
+
It'is PECO Energy's understanding, as stated in Reference 1, that successful resolution of the above mentioned NRC Closure Restraints will complete the requirements for formal closure of the Peach Bottom Generic Letter 8910 Program. Should the Staff require any additionalinformation to support GL8910 Program Closure, please contact us. PECO Energy will submit a follow-up letter when all required actions discussed above have been completed.
I s
4