ML17037C494

Transmits Original of Document Entitled, Request for Exemption Together with Attachments a and B in Regards to Technical Specifications to Appendix J to 10 CFR Part 50 of the Commissions' Regulations

ML17037C494
Person / Time
Site:	Nine Mile Point
Issue date:	10/31/1975
From:	LeBoeuf, Lamb, Leiby & MacRae, Niagara Mohawk Power Corp
To:	NRC/SECY
References
Download: ML17037C494 (20)

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NRC DISTRIBUTION FOR PART SO DOCKET MATERIAL (TEMP 0 RA R Y FO R M)

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'MacRae Wash.'D,C, 200 6 10-31-75 11-4-75 ORIG CC OTHER 1 signed SENT LOCAL PDR CLASS UNC LASS PROP INFO INPUT NO CYS REC'D DOCKET NO:

1 ~ 50-220 DFSCRIPTION: Ltr submitte on behalf of ENCLOSURES: Reques t .for Exemption from Niagara Mohawk Power'Corp. 'taans -the App. J to 10 CFR Part 5Q with attachment

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", Safety Ecaluation for Niagara mohawk.

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~ CERTIFICATE- OF SERVICE dated .10>>31-75 PLANT NAME: Nine Mile't.. Uni.t- 1 shw svc of Request fo Exemption .u on own'f R. Jones FOR ACTION/INFORMATION DHL 11-8-75 BUTLER (L) SCHWENCER (L) ZIEMANN (L) REGAN (E) REID (L)

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LAW OFFICES OF LEBOEUF, LAMB,LEIBY 8 IvIACRAE I7S7 N STREETI N. W.

WAsHINGToN, D. C. 20036 ARVIN E. UPTON I40 BROADWAY LEONARD M. TROSTEN NEW YORK, N Y.il0005 WILLIAM O. DOUB October 31, 1975 EUGENE B. THOMAS'R.

WASHINGTON TCLCPHONF, HARRY H. VOIGT L. MANNING MUNTKING 202 872 BBBB LEX K. LARSON CABLE ADDRESS HENRY V. NICKEL WASHNIOTON PARTNERS gegIIlatory Docket file LALALUeWASHINGTON D C TKLKXI440274 Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Re: Niagara Mohawk Power Corporation (Nine Mile Point Nuclear Station No.

Docket No'. 5'0-220'ear Sir:

On October 28, 1975, Niagara- Mohawk Power Corporation filed with the Commission an Application For Amendment To Operating License to conform Nine Mile Point Unit No. 1's technical specifications to Appendix, J to 10 C.F.R. Part 50 of the Commission's regulations. A member of the Commission's Regulatory Staff has requested that the company seek an exemp-tion from those provisions of Appendix J which are the basis for October 28th filing.

Accordingly, pursuant to Section 50.12 of the Com-mission's regulations, we hereby transmit an original of a document entitled "Request For Exemption" together with Attachments A and B. Two additional copies of this document are also transmitted for your convenience.

A Certificate of Service showing service of these documents upon the persons listed therein is also enclosed.

Very truly yours, LII.i5ueg, 4u,oi hah a ILIA,gLL LeBoeuf, Lamb, Leiby MacRae Attorneys for Niagara Mohawk DOCggpp Power Corporation UStiIRg NOtry tg~

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~gggUletory Docket File

<filly BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION 4+ygg~lT~

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NIAGARA MOHAWK POWER CORPORATION ) Docket No. 50-220 (Nine Mile Point Nuclear Station )

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CERTIFICATE OF SERVICE I hereby certify that I have served a document entitled "Request For "Exemption" by mailing a copy thereof first class, postage prepaid, to the following persons this 31st day of October, 1975.

Mr. Robert P. Jones Dr. William E. Seymour Supervisor Staff Coordinator Town of Scriba New York State Atomic R. D. N4 Energy Council Oswego, New York 13126 New York State Department of Commerce Miss Juanita Kersey 99 Washington Avenue Libarian Albany, New York 12210 Oswego City Library 120 E. Second Street Oswego, New York 13126 Hope M. Babcock LeBoeuf, Lamb, Leiby 6 MacRae Attorneys for Applicant

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'll'egufatory Docket File UNITED STATES OF AMERICA ...~>.I ~E.:af NUCLEAR REGULATORY COMMISSION In the matter of NIAGARA MOHAWK POWER CORPORATION ) Docket No. 50-220 (Nine Mile Point Nuclear Station )

Unit No. 1) )

RE UEST FOR EXEMPTION Pursuant to Section 50.12 of the regulations of the Nuclear Regulatory Commission, Niagara Mohawk Power Corporation, holder of Facility Operating License No. DPR-63, hereby requests that it be exempted from certain provisions of Appendix J to 10 CFR Part 50. The specific exemptions requested are set forth in Attachment A to this application. A safety evaluation which demonstrates that the proposed exemptions will not endanger life and property or the common defense and security and are otherwise in the public interest is set forth in Attachment B. The proposed exemptions would not authorize any change in the types or any increase in the amounts of normal plant effluents or any change in the authorized power level of the facility.

C' WHEREFORE, Applicant respectfully requests that it be exempted from Appendix J to 10 CFR Part 50 as set forth in Attachment A.'IAGARA MOHAWK POWER CORPORATION ey I Geral K. ode Vice President - Engine'ering Subscribed and sworn to before me this ~og day of October, 1975.

Notary Public PATRICIA A. CONNOR Nolery Public tn the State ol New York Quelrfied tn Onondette Co. Nor 4608264 Mtr Conrnrtrrion fxtrtret Merdr 30, t9+ 7

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Attachment A Niagara Mohawk Power Corporation License No. DPR-63 Docket No. 50-220 RE UESTED EXEMPTIONS TO 10 CFR 50, APPENDIX J Specific exemptions to the testing requirements of 10 CFR 50, Appendix J are hereby requested as follows.

The supporting information for these exemptions is contained in Attachment B.

Penetrations T e 8 Tests)

1. Control rod drive hydraulic piping (262)

2. Containment ventilation lines (9)

3. TIP system indexer cables (4)

4. All spare penetrations (104)

Isolation Valves T e C Tests)

Valves which may be called upon to perform a contain-ment isolation function during a Loss-of-Coolant Accident, which are not testable, include:

1. Reactor cleanup - all isolation valves

2. Shutdown cooling - outside check valve and both inside isolation valves

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Attachment A (Continued)

3. Drywell equipment and floor drain isolation valves

4. Emergency cooling steam line drain isolation valves (Test connections will be provided by the Spring, 1977 refueling outage.)

An appropriate Technical Specification change was sub-on October 24, 1975 addressing these exemptions 'itted and the following valves discussed below.

Ho exemptions were requested for valves which are or may be relied upon to operate during a Loss-of-Coolant Accident since they are not considered to perform a containment isolation function. These valves are in the Feedwater (HPCI), Emergency Cooling, Liquid Poison, Control Rod Drive Hydraulic, Reactor Head Spray, Airborne Activity tlonitor, Core Spray and Containment Spray piping.

It should be noted that Emergency Cooling is the only ECCS system which is not normally sealed with water and that isolation valves are provided in the branch piping systems which will be tested in accordance with Appendix J. Valves in the Recirculation Pump and Drywell Cooler Water Supplies are not considered to perform a contain-ment isolation function since these systems are not open to the free space of the containment or reactor vessel under normal or accident conditions.

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Attachment 8 Niagara Mohawk Power Corporation License No. DPR-63 Docket No. 50-220

'AFETY EVALUATION Attachment A'resents the proposed exemptions to 10 CFR 50, Appendix J. The Nine Mile Point Unit 1 plant was designed and con-structed prior to the issuance of the General Design Criteria of 10 CFR 50, Appendi.x A. Though the facility does not fully comply with the specifics of the containment design criteria, it does meet the general intent of those criteria. Approximately 73 percent of those valves which perform a containment isolation function will be tested in accordance with Appendix J. >(hen test connections are completed on the Emergency Cooling steam line drain valves, by the Spring of 1977, this figure will rise to about 79 percent.

Penetrations Penetrations will be tested for leakage in accordance with the requirements for Type 8 tests, with the exception of a few which have been classified as non-testable. Non-testable penetrations include control rod drive, containment ventilation, TIP system, and spares.

No provisions exist to test the control rod drive penetrations, As described in the FSAR, each control rod drive pipe (262 in all) is welded to a sleeve which in turn is welded to the drywe11 liner.

Similarly, containment ventilation lines are welded directly to the penetration sleeves. Thus, there is no chamber between the line and .

penetration sleeve which makes testing impossible. The TIP system indexer cables are fed through a solid flange on the inside of the penetration sleeve, and must be free to move. There is no provision for testing these since the penet'ration sleeve outside the drywell is open ended. Also, no provision exists For the testing of spare penetrations since these penetration sleeves are welded shut from the inside and are open-ended on the outside.

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Attachment B (Continued)

Isolation Valves Valves which are relied upon to perform a containment isolation function will be tested for leakage in accordance with'he requirements for ape C tests, with the exception of those which have been classified as non-testable. Justification for each non-testable classification follows:

Reactor Cleanu and Shutdown Coolin The only.')ocally testable valve in these systems is the outside valve for the line carrying shut-down cooling water from the reactor. These are closed systems where leakage outside the system is an unlikely possibility, The inside valves on both systems cannot be isolated from the reactor for air or nitrogen tests. A water test is not feasible since the reactor would have to be pressurized and the test connection is inside the containment. The outside valves on the water return lines of both systems consist of check valves which were not designed to meet the stringent leakage criteria of Appendix J. The power operated outside valve on the cleanup

'ine leaving the reactor is located in an area of high radiation even during shutdown. Local testing of this valve would result in high employee radiation doses.

2. Dr well E ui ment Drain Line and Floor Drain Line Testing these valves would require drainage of the systems and pressurization of the containment.

3. Reactor Cleanu S stem Relief Valve Dischar e Testing these valves would require. the lowering of the suppression pool. water level by about 3.5 feet which is impractical.

Emer enc Coolin There are presently no test connections on the steam line drain valves. Test connections will be provided by the next major refueling outage to permi t these valves to be tested. This outage is currently planned for Spring, 1977.

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Attachment B (Continued)

All of the penetrations and isolation valves which perform an isolation function are tested during the integrated containment leak test (Type A). Leakage from the penetrations and valves listed in Attachment A of this report would be measured during this test. There-fore, the lack of local leak test capability does not preclude measure-ment of leakage through these valves and penetrations although the frequency of such measurement would be reduced. In addition, the systems involved in the exemptions're all normally filled with water, with the exception of Emergency Cooling, and therefore leakage from the containment is an unlikely possibility. As previously noted, the Emergency Cooling steam line drain valves have been committed to be made testable by the Spring of 1977.

It is concluded that these proposed exemptions will not endanger life and property or the common defense and security and are otherwise in the public interest.

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