ML20245D777
| ML20245D777 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 09/29/1988 |
| From: | Leitch G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| Shared Package | |
| ML20245D771 | List: |
| References | |
| NUDOCS 8810070094 | |
| Download: ML20245D777 (18) | |
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.3 BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of Docket No. 50-352 PHILADELPHIA ELECTRIC COMPANY APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSE NPF-39 4
Eugene J. Bradley 2301 Market Street Philadelphia, Pennsylvania.19101 Attorney for Philadelphia Electric Company 6
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BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION 4
In th'e Matter 1of Docket No. 50-352 PHILADELPHIA ELECTRIC COMPANY APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSE.
NPF-39 Philadelphia Electric Company, Licensee under Facility Operating License NPF-39 for Limerick Generating Station, Unit 1, the Technical Specifications contained in.
hereby requests that Appendix A to the Limerick Operating License be amended as' indicated by a vertical bar in the margin of the attached pages 3/4 6-21, 3/4 3-80, 3/4 3-70, 3/4 4-11 and 3/4 8-23.
Licensee requests approval for the removal of the Residual Heat Removal system (RHR) Head Spray piping and associated isolation valves, and for blanking off the associated I
Primary Containment penetration and the existing Reactor Head j,
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f Further, Licensee
' piping stubcut used for the Head Spray.
preposes to relocate the' existing seismic monitor XR-VA-151 from Jocation on the Head Spray piping to directly on the the present the reactor vessel nozzle which is presently used Reactor Head at The proposed changes to the Technical for the Head Spray piping.
Specification would eliminate all references to the RHR Head instruments and controls and
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Spray piping and isolation valves, would eliminate the requirements for a special report to the Commission each time seismic monitor XR-VA-151 becomes inoperable because of a necessity to remove the Reactor Head for refueling, maintenance or inspection.
Licensee requests Commission approval for these refueling outage modifications prior to the beginning of the next the changes to the scheduled for January, 1989 and requests that Technical Specifications become ef fective upon completion of the proposed modifications.
Categories cf Proposed Changes The proposed changes to the Technical Specifications may be classified into two categories of changes:
1 Changes to the Limerick Generating Station, Unit (1)
Technical Specifications to delete the Primary Isolation valves and Instrumentation 1
Containment associated with the permanent removal of the RHR Head Spray piping (Category A)..
J
' Changes to the Limerick Generating Station, Unit 1
(2)
Technical Specifications regarding the deportability requirements for seismic monitor XR-VA-151, whenever the reactor head has been removed.
Removal of the reactor head causes this monitor to become inoperable and, therefore, reportable.
Discussion of Category A Changes In crder to remove the reactor head at the beginning of each refueling, or for maintenance or inspection inside the reactor vessel, it is first necessary to remove the RHR Head Spray piping between the flanged connections at the containment
-seal plate and the head spray nozzle on top of the reactor, then cap the containment seal plate.
Upon completion of refueling or maintenance / inspection, the head spray piping must then be re-assembled.
The RHR Head Spray condenses steam in the vessel dome, Generally the Head Spray would to assist in vessel head cooling.
The be used prior to refueling, maintenance, or inspections.
Residual Heat Removal (RHR) system, however, provides sufficient cooldown means to accomplish reactor cooldown without-use of the Therefore, use of the RHR Head Spray has never RHR Head Spray.
been necessary.
Because the Head Spray mode of RHR has proven to be j
unnecessary, and since the Head Spray provides no safety i
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the costs and radiation exposure (approximately 3.5 c
. function, associated with each removal and re-assembly during each 1
man-rem) refueling cycle cannot be justified.
5afety Assessments - Reactor Head Spray (Category A)
Removal of the RHR Head Spray piping and associated The RHR Head Spray System valves does not pose a safety concern.
has no safety functions and no credit has been taken for it in Removal of the RHR Head Spray the Final Safety Analysis Report.
would neither increase nor decrease the Residual Heat Removal System reliability since it has no impact on the other operating The Head Spray was intended to be used modes of the RHR system.
during shutdown cooling in order to increase the reactor vessel Experience at Limerick Station and other head cooldown rate.
Boiling Water Reactors, however, indicates that this accelerated refueling schedules.
cooldown provision is not needed to support Elimination of the Head Spray would reduce refueling critical path time and would also reduce personnel radiation exposure by as much as 3.5 man-rem per outage during the Head Spray piping removal / reassembly work.
After removing the Head Spray piping and valves as proposed, the Primary Containment penetration would be blanked of f on the cutboard side of containment to maintain primary The Reactor pressure boundary will be containment integrity.
maintained by the addition of an ASME Section III Class I bolted The reactor blank flange over the existing reactor nozzle.
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the and
' pressure boundary is presently tested hydrostatically at of each refueling outage or each time the reactor head is re-Following the removal of the Head Spray, the listing installed.
isolation valves, HV-51-lF022 and HV-51-lF023 of containment would be removed from Table 3.6.3-1 in the Technical Specifications.
The modifications do not effect plant safety, and because a source of potential pipe whip is eliminated along with elimination of containment penetration isolation valves, these modifications increase the plant safety margins.
List of Proposed Page Changes (Category A)
Change Pace Delete Penetration 017 and 3/4 6-21 associated valves from table 3.6.3-1 Delete valves and controls 3/4 3-b0 for HV-51-lF022 and HV 1F023 from Table 3.3.7.4-1 Remove valves HV-51-lF022 3/4 4-11 and HV-51-lF023 f rom Table 3.4.3.2-1.
Remove circuit breaker 52-3/4 6-23 21125 for isolation valve l
HV-51-lF022 from Table 3.8.4.1-3. _ _ - _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _.
e
'Significant Hazards Considerations - RHR Head Spray Piping
' Modification (Category A)
The removal of the Reactor Head Spray piping, along with the capping of the primary containment penetration, does not invc1ve significant hazards considerations.
In order to support a No Significant Hazards Consideration determination, necessary background supporting information is provided below, along with an evaluation of each of the three standards set forth in 10 CFR Section 50.92.
(1)
Operation of the plant under the proposed Technical Specifications after removal of the RHR Head Spray piping and associated valves along with blanking the ascociated primary containment penetration, would not involve a significant increase in the probability or consequences of an accident previously evaluated.
Three areas were previously evaluated in the FSAR regarding the reactor head spray piping:
o Primary Containment Isolation - FSAR Section 6.2 Seismic Analysis - PSAR Section 3.7.4 o
Pipe Whip Analysis - FSAR Section 3.6 o
The Reactor Head Spray piping removal modifiestion was reviewed and f ound to be acceptable in the above referenced FSAR
- aress, The primary containment isolation will be o
maintained after removal of the Reactor Head Spray piping by welding a closure on the outboard containment side of penetration 17.
The penetration is included in the Inservice Inspection (ISI) program and the integrity of the welded closure will be verified by periodic testing.
Seismic Category I piping, hangers and o
snubbers on the RHR Head Spray would be Stress removed by the proposed modification.
calculations have been reviewed and appropriately revised to assure that any remaining components are not impacted.
Any potential pipe whip problems would be o
eliminated by removal of the pipe and pipe supports, as proposed.
Further, Licensee has reviewed the potential effects of f Fire the proposed removal in previous evaluations in the areas o Environmental Qualification, Protection, Electrical Separation, Evaluations in these Inservice Inspection, and Piping Stresses.
uncover any areas of safety significance.
areas did not I
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the Based on these reviews,-the Licensee concludas that involve a significant.
RHR. Head Spray' modifications do not
-increase in tne probability or consequences of an accident previously evaluated.
Operation of the plant under the proposed Technical (2)
Specifications after removal of the Reactor Head Spray System along with blanking the primary containment penetration would not create the possibility of a new or different kind of accident from any accident previously evaluated.
Renicval of the RHR Head Spray piping and blanking the primary containment penetration eliminates the piping from being a potential pipe whip problem and removes the containment No credit has.been penetration as a potential leakage source.
taken for the RHR Head Spray in the mitigation or prevention of the modification does not create the an accident, therefore, possibility of new or different kind of accident from any accident previously evaluated.
Operation of the plant under the proposed Technical (3)
Specifications after removal of the RHR Head Spray and associated valves along with blanking the would not involve primary containment penetration, reduction in a margin of safety.
a significant ___ - - -
The; integrity of the. reactor pressure boundary.after
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' removal of the RHR Head Spray would be maintained by a blank The reactor installed over the Reactor Head Spray nozzle.
flar.ge pressure boundary would then become part of the Inservice Inspection (ISI) program and would be hydrostatically tested each The time the reactor head is reinstalled on the reactor. vessel.
primary containment penetration will be welded closed on the outboard side of the containment penetration and will be periodically tested for' integrity during scheduled integrated The seismic category I piping,' hangers and leak rate testing.
1' snubbers and containment isolation valves on the Head Spray piping would be removed by the proposed modification.
Therefore, the RHR Head Spray modification would not Based on the three involve a reduction in a margin of safety.
standards discussed above, operation of the facility subsequent to. removal of the RHR Head Spray along with the associated isolation valves, involves No Significant primary containment Hazard Considerations, Discussion of Cateoory B Chances Seismic monitors are located in the plant in order to This seismic monitoring record data during a seismic event.
installed in instrumentation (strong-motion accelerographs),
records seismic data in compliance with Regulatory Guide 1.12, Data would order to provide information after a seismic event.
be available af ter an earthquake on the f requency, amplitude and - -_
phase relationships of seismic responses on seismic Category I The seismic recorders provide no shutdown or safety
' structures.
function during normal operation nor do they provide any safety shutdown function during a seismic event.
Seismic monitors only provide post-earthquake information so that a. determination may be made for continued safe operation of the plant.
The post earthquake data.may also be used to determine if the past seismic analysis assur ptions and analytical models used for the ' design of the plant were adequate and if allowable stresses have been exceeded.
One of these seismic monitors, XR-VA-151, is presently located on the RHR Head Spray piping which the Licensee proposes This seismic monitor will be remounted on to permanently remove.
a new reactor head blank flange.
Each time the reactor head is to be removed to accommodate refueling, maintenance or inspection inside the reactor vessel, Seismic Monitor XR-VA-151 must be disconnected and temporarily stored until the reactor head is reinstalled.
When the reactor head is reinstalled, the Seismic Monitor is remounted.
The seismic monitor removal causes the monitor to be declared inoperable because it is no longer available to record Technical j
seismic information on top of the reactor.
Specification Section 3.3.7.2.E requires a Special Report to the Commission each time the Seismic Monitor is inoperable for more than 30 days....
'Because-the reactor head is periodically removed-to i
[
'accccmodate reactor maintenance, refuel ng or inspection, i
licensee proposes to add a footnote to page 3/4 3-70 to revise the deportability requirements for monitor XR-VA-151, eliminating the requirement for a special report when monitor XR-VA-151 becomes inoperable each time _the reactor head is removed.
Safety Concerns - Seismic Monitor Deportability Requirements (Category B)
Following the proposed removal of the RHR Head Spray the seismic Monitor would be remounted on a new reactor
- piping, The monitor location, presently stipulated in head blank flange.
the Technical Specifications as "(on)... Top of reactor vessel head," would remain the same.
Each time the reactor head is to be removed, the seismic monitor on top of the vessel head is disconnected and declared Presently, the Licensee transmits a special report inoperable.
each time the seismic monitor on the reactor head is removed for more than 30 days.
The proposed change, i.e.,
adding a note to the bottom of page 3/4 3-70 would eliminate tne need for a special report durino each refueling, maintenance or inspection per!.od which requires reactor head removal.
The proposed changes f
to the Technical Specifications would not affect any of the other f
plant seismic monitors.
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F.[
List of Proposed Changas - (Category B)
L
. Change Page Add'a triple asterisk note 3/4. 3-70 indicating seismic monitor XR-VA-151.is not' required' to be operable when'the reactor head has been remov'ed.
1 Significant Hazards Considerations Seismic Monitor Deportability Requirements.
(Category B)
Remounting the seismic monitor on the blank flange on iop of the reactor head, in lieu of being mounted on top of the reactor head on the spray piping, does not affect the existing deportability requirements for Seismic Monitor XR-VA-151.
Licensee however, proposes to revise the existing deportability requirements when the monitor is inoperable because the reactor head has been removed.
Changing the deportability requirements for seismic monitor XR-VA-151, does not involve significant hazards In order to support a No Significant Hazards considerations.
Considerations determination, necessary background supporting
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information is provided below, along with an evaluation of each of the standards set forth in title 10 CFR Section 50.92.
Operation of the plant under the proposed Technical (1) the Specifications in regard to changing operability reporting requirements for seismic monitor XR-VA-151 whenever the reactor head has been removed, would not involve a significant increase in the probability or consequences of an accident previously evaluated.
l The Seismic monitor would continue to function under the proposed amendment whenever the reactor head is installed on the When the reactor head has been removed from the reactor vessel.
the seismic monitor will become inoperable by reactor vessel, necessity and presently is reportable after 30 days under the existing Technical Specifications.
The purpose of the existing requirement is to report unexpected seismic monitor malfunctions during periods when Eliminating the monitors are required to be operable.
for submission of a special report when only one requirement seismic monitor becomes inoperable for more than 30 days, during the course of normal activities taking place with the reactor the reporting requirements for the head removal, will not affect Following the re-monitor under any other operating conditions.
installation of the reactor head, the seismic monitor wi11 be re-The reporting connected and its operability re-established.
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regairements f or other seismic-monitors would not be af fected by
, this proposed change.
The intent of'the specification for reporting seismic monitor malfunction would continue under the proposed amendment.
Lack of a report whenever. the reactor head is removed, does not affect.the intent of the specification which is to accrue data on unexpected seismic monitor. malfunctions and on the reliability of the monitors, rather than on intentional disconnections of a monitor.
Therefore, deletion of the deportability requirement under these expected conditions would not involve a significant increase in tne probability or consequences of an accident previously evaluated.
(2)
Operation of the plant under the proposed Technical Specifications in regard to changing the operability reporting requirements for Seismic Monitor XR-VA-151 whenever the reactor head has been removed would not create the possibility of a new or different kind of an accident from any accident previously evaluated.
After completion of the proposed Head Spray removal modification, a blanking flange on the reactor nozzle would maintain the reactor pressure boundary.
Seismic monitor XR-VA-151 would be remounted at that time to the new blanking flange on l
top of the reactor vessel head.
No other changes are being a
Also, tha reportsbility proposed for seismic monitor XR-VA-151.
' requirements would not'be changed for any other monitor except XR-V A-151 under the proposed amendment.
Changing the deportability requirements for seismic monitor XR-VA-151 when the reactor head has been removed does not affect any plant safe shutdown capabilities.
Therefore, elimination of the repcrtability requirements without making changes to the location or to the normal create the operability status of the seismic monitor would not kind of accident from any possibility of a new or different accident previously evaluated.
Operation of the plant under the proposed Technical (3)
Specifications in regard to changing the operability reporting requirements for Seismic Monitor XR-VA-151 whenever the reactor head has been removed would not involve a significant reduction in a margin of safety.
The Seismic Monitoring System provides information to the operators after a seismic event and does not perform any When shutdown function or affect plant operation.
direct plant monitor XR-VA-151 becomes inoperable during times the RPV head is does not provide any information following a seismic removed, it occurring during that period.
Other monitors in the plant event The lack of remain operable and would provide this information.
post-seismic data from seismic monitor XR-VA-151 would remain the _ _ _ _ - _ _ _ _ _ - _ _ - - _ _ _ _ _ _ _.
..same whether or not a special report was submitted to the Commission.
Elimination of the Special Report when seismic monitor XR-VA-151 is inoperable during times when the RPV head is involve a significant reduction in a margin of removed, does not The lack of seismic information from seismic monitor XR-safety.
VA-151 after any seismic event when the reactor head is removed, would not affect the safety of the plant.
Seismic monitors provide information to reinforce and verify previous seismic Other monitors in the plant would provide this calculations.
information when XR-VA-151 is not operable.
Based on the three standards discussed above, operation of the facility after changing the seismic monitor deportability involves No requirements in the Technical Specifications, Significant Hazards Considerations.
Environmental Considerations This amendment would delete the piping, the isolation valves and the instrumentation along with the associated Primary Isolation provisions for the RHR Head Spray and would Containment also delete the requirement for a Special Report whenever seismic monitor XR-VA-151, located on the reactor head, becomes inoperable when the reactor head has been removed.
The proposed changes do not involve any increase in the amounts and no changes in the types of effluents that may be No increase will occur in the individual or released offsite.
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l Thereforo, no
' cumulative occupational radiation exposure.
environmental impact report is required.
i Conclusion The Plant Operations Review Committee and the Nuclear Review Board have reviewed these proposed changes to the Technical Specifications and have concluded that they do not involve any unreviewed safety questions, nor do the changes involve Significant Hazards Considerations, or Environmental l
Considerations and will not endanger the health and safety of the 1
public.
I Respectfully submitted, PHI PH A ELECTRIC COMPANY M:
Vice esident - _ _ _ _ _ _ _ _ _ - _ _ _ -
l c.
COMMONWCALTU OF PENNSYLVANIA
'ss.
COUNTY OF PHILADELPHIA G. M. Leitch, being first duly sworn,-deposes and says:
he is Vice President of Philadelphia Electric Company, That tne 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.
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Vice President Subscribed and sworn to before me thisAb day of, d%., 1988.
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/}0 Nctary Publit flif,ROR K. HUZZAPD NOTARY FUDUC PDTTSTOM BOCOUGH, M0!.iOOMERY COUNTY MY C0ft.ct;s10N [%PlD[$ JAN, y, jg,y Ei Wr. Fermsyhnu Ataciation cf f.oieries
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