ML20246P164
| ML20246P164 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 05/08/1989 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20246P155 | List: |
| References | |
| NUDOCS 8905220104 | |
| Download: ML20246P164 (5) | |
Text
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UNITED STATES j
NUCLEAR REGULATORY COMMISSION o
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'E WASHINGTON, D. C. 20555
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- s e *,o SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING j
AMENDMENT NOS.144 AND 146TO FACILITY OPERATING LICENSE NOS. DPR-44 and DPR-56 PHILADELPHIA ELECTRIC COMPANY PUBLIC SERVICE ELECTRIC AND. GAS COMPANY l
DELMARVA POWER AND LIGHT COMPANY l
ATLANTIC CITY ELECTRIC COMPANY j
PEACH BOTTOM ATOMIC POWER STATION, UNIT NOS. 2 AND 3 DOCKET N05. 50-277 AND 50-278 j
1.0 INTRODUCTION
By letter dated July 31, 1979 as amended on June 4, 1984 and September 15, 1986, Philadelphia Electric Company requested an amendment to Facility Operating License Nos. DPR-44 and DPR-56 for Peach Bottom Atomic Power Station, Unit Nos. 2 and 3.
These amendments would revise the Technical Specifications to incorporate a 90-hour purging restriction, definitions of conditions requiring no justification for purging, limitations on the use of the Standby Gas Treatment System (SGTS), operability requirements for the SGTS, additional TS for the containment purge and vent isolation j
valves and to correct certain valve and penetration numbers.
2.0 EVALUATION The NRC staff's letter of December 12, 1983 requested the Philadelphia Electric Company (PECo) to revise its Technical Specifications (TSs) submittal for the Peach Bottom purge / vent valves.
PEco submitted a revised TS amendment application dated January 4,1984 in response. The staff reviewed that submittal, discussed its concerns with PECo, and by letter dated November 21, 1984 documented ten concerns. As noted in the letter, three of these prior concerns were found to be resolved. Although these three concerns and the fourth concern do not explicitly impact the TS changes proposed in the licensee's September 15, 1986 application they are included here since they are components of the overall purge / vent isolation valve issue and their inclusion enables the establishment of a complete record of the disposition of the issues in the staff's November 21, 1984 letter. The fourth issue is reviewed herein and requires additional implementing actions by the licensee. A statement of the issue is quoted from the staff's letter of November 4, 1984 These l
concerns and their resolution are as follows:
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(1) "The f.irst issue is that the phrase "other safety related reason" in specification 3.7.E.3 is unacceptable.
It is an NRC position that safety related reasons for purging / venting shall be specifically I
stated in the TS.
Inerting, deinerting, and pressure control are
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the three safety related reasons for purging / venting in the STS
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which require no justification from the licensee."
The licensee'has changed the TS such,that the now proposed 3.7.E.2.a reads as follows: '"The large primary containment purge / vent isolation valves may be opened only for inerting, 4
deinerting, and pressure control." This meets the concern of the issue and is acceptable.
l (2) "The second issue is that the NRC position does not permit carry-over of purge / vent time from year to year. This provision must be removed from specification 3.7.E.2.a."
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The currently' stated TS 3.7.E.2.b has been revised to delete the carry over provision. This meets the concern of the issue and is acceptable.
1 (3) "The third issue is that the NRC position does not permit sharing of purge / vent time between units.
Each unit should be permitted 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> per year of purging / venting through the SGTS."
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.The revised TS are specific to each unit and do not reflect any provisions fcr shared purge / vent time between units. This meets the concern of the issue and is acceptable.
(4) "The fourth issue is that the NRC position requires a specification for the leak tight integrity of the safety grade seal air supply system.
Normally the periodic testing consists of pressurizing the region between two closed and sealed valves and observing the rate of leakage past the seals. This testing demonstrates that there is no seal deterioration. With the Peach bottom arrangement this type of periodic testing is not required. Since the seals are continuously pressurized seal integrity is demonstrated, however, we still require that it be demonstrated with a leakage test that there be no seal deterioration associated with the safety grade seal air supply system.
For this reason we require PEC to include a j
specification for the safety grade seal air supply system in their l
TS."
The licensee has addressed this issue by letter dated November 6, 1985.
In lieu of proposing leakage testing requirements for a i
safety grade seal air supply system, which relies on backup bottled nitrogen supplies, the licensee proposes to modify the system to connect the seal air supply system for ther.e valves to the existing ContainmentAtmosphericDilutionSystem(CADS)6000gallonliquid nitrogen storage tank.
The licensee states that a leak rate test of the system is then not deemed to be necessary since all portions of the supply system are pressurized continuously by either the normal instrument air system or the backup CADS supply when required. The licensee states that all but minor leaks would be evident by observation or loss of CADS nitrogen inventory and to this purpose the licensee developed a preliminary surveillance requirement as follows:
"The valve operator and; inflatable seal safety-grade pneumatic supply system shall be demonstrated operable for the CACS and CADS isolation valves by:
1.
Verifying at least once per day that the backup nitrogen supply inventory is adequate for maintaining the operability of the I
valves.
2.
Once per operating cycle, conduct a functional test that demonstrates the operability of the backup nitrogen supply system upon loss of the normal supply system."
Further, the licensee states that minor leaks are not a safety concern since the CADS storage tank is accessible during a severe accident and can be recharged from liquid nitrogen trucks.
The licensee has proceeded to implement this connection of the CADS supply to these inflatable seal isolation valves by implementing Modification No. 1316. The licensee plans to fully implement this modification for Unit 2 by the third quarter of 1990 and for Unit 3 by late 1989.
The licensee proposed an alternate approach in its November 6, 1985 proposal to any contemplated at the time of the statement of the ten problem areas in the staff's letter of November 21, 1984.
Therefore, pending receipt of the staff's response to the licensee's November 6, 1985 proposal for the CADS tie in, the licensee did not address this issue in its September 15, 1986 proposed TS amendment.
However, the staff has reviewed the licensee's response to this concern and on the basis of the larger capacity of the CADS system, i
the ability to replenish the CADS storage tank and the proposed surveillance requirements which the licensee has committed to implement, the staff finds the response to be acceptable.
Complete implementation of the licensee's response will require the licensee to submit the proposed surveillance TS and to complete Modification 1316 on both units.
(5) "The fifth issue is a typographical error..."
The licensee has corrected this by cdding the words "previously measured" into TS 4.7.E.2.
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l (6)
"The sixth issue is the valve and penetration numbers in the proposed specification 3.7.E.2.b.
These numbers are correct for PB2, but not for PB3. PEC should submit a separate specification for PB3."
The licensee has now included the valve and penetration numbers for Unit 2 on its version of TS page 178a and for Unit 3 on its version of page 178a; thus resolving this concern.
I (7/8) The seventh and eighth issues were resolved as stated in the staff's letter of November 21, 1984.
(9) "The ninth issue is that specification 3.7.D is incomplete.
Specification 3.7.D.1 states that all isolation valves and instrument line flow check valves listed in Table 3.7.1.shall be operable. This statement is followed by an action statement for the isolation valves, but no action statemant is given for the check valves.. An action statement for the check valves should be included in this specification.
Specification 3.7.D.2 is the action statement for the isolation valves.
It provides a procedure if one of a pair of isolation valves fails, but gives no indication of what should be done if both valves fail. We suggest that PECo compare their proposed TS with the STS to see an acceptable approach to this concern. Specification 3.7.D is not part of our review and we are not requesting PEco to take action on it at this time. This issue is included here simply because it was raised on the telecon."
Even though this issue was not within the original scope of review of the proposed license amendment the licensee has added an action statement for the excess flow check valves as TS 3.7.D.3.
The licensee has also added a standard action statement addressing inoperability of the isolation valves that is consistent with the STS. These actions meet the concerns of this issue and are acceptable.
(10) "The tenth issue was resolved as stated in the staff's letter of November 21, 1984."
The licensee also made changes to TS 3.7.B.1 to implement the operability restraints on the Standby Gas Treatment System that were requested in the staff's letter of December 12, 1983. The proposed change is responsive to the request and is acceptable.
1 3.0
SUMMARY
i As noted above the staff concludes that an acceptable technical resolution has been proposed for all of the ten issues identified in the staff's letter of November 21, 1984. The staff also concludes that the TS proposed in the licensee's application dated September 15, 1986 are I
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i acceptable for the Peach Bottom station. As noted above, the licensee-1 must take certain actions to implement the resolution of issues raised in the staff's letters of December 12, 1983 and November 21, 1984 and the licensee's letter of November 6,1985 on the primary containment purge and vent isolation valves.
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4.0 ENVIRONMENTAL CONSIDERATION
S These amendments involve a change to a requirement with respect to the installation or use of a-facility component located within the restricted area as defined in 10 CFR Part 20 and changes to the surveillance requirements.
The staff has determined that the amendments' involve no significant increase in the amounts, and no significant change in the types, of any effluents that.may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration and there has been no public comment on such finding. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forthin10CFR51.22(c)(9). Pursuantto10CFR51.22(b),noenvironmental impact statement nor environmental assessment need be prepared in connection with the issuance of the amendments.
4.0 CONCLUSION
The Commission made a proposed determination that the amendments involve no significant hazards consideration which was published in the Federal Register (51 FR 41864) on November 19, 1986 and consulted with the State of Pennsylvania.
No public comments were received and the State of Pennsylvania did not have any comments.
The staff has concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the ublic will not be endangered by operation in the proposed manner, and p(2) such activities will be conducted in compliance with the Commission's regulations, and the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor:
R. E. Martin Dated: May 8, 1989 i
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