ML17055E310

Comments on Re Clarifications & Agreements Reached During 880609 Meeting Re Compliance w/10CFR50,App J, Containment Leak Testing at Plant

ML17055E310
Person / Time
Site:	Nine Mile Point
Issue date:	11/09/1988
From:	Haughey M Office of Nuclear Reactor Regulation
To:	Mangan C NIAGARA MOHAWK POWER CORP.
References
TAC-54152, NUDOCS 8811140143
Download: ML17055E310 (6)

Text

November 9,

1988 Docket No. 50-220 Mr. Charles V. Mangan Senior Vice President Niagara Mohawk Power Corporation 301 Plainfield Road

Syracuse, New York 13212 DISTRIBUTION NRCPDR Local PDR PDI-I Rdg.

SVarga BBoger ACRS (10)

CVogan MHaughey RCapra

JJohnson, RI OGC EJordan BGrimes JPulsipher

SUBJECT:

REVIEW OF THE JULY 28, 1988 LETTER ON APPENDIX J CONTAINMENT LEAKAGE RATE TESTING AT NINE MILE POINT UNIT I (TAC 54152)

On May 6, 1988 the NRC staff issued a Safety Evaluation (SE) regarding compliance with 10 CFR Part 50, Appendix J, containment leak testing at Nine Mile Point Unit 1.

On June 9, 1988 the staff met with representatives of Niagara Mohawk to discuss the SE.

In accordance with the agreement made during the June 9 meeting, on July 28, 1988 you submitted a letter describing the clarifications and agreements reached during the June 9 meeting and responding to commitments made at that meeting.

The staff has completed its review of that submittal and finds that it accurately reflects the clarifications and agreements reached at the meeting and proposes acceptable resolutions to the items that remained open at the end of the meeting with the following exceptions and comments:

1.

During the meeting the staff requested you to address the adequacy of performing Type C local leak rate testing on the Shutdown Cooling System suction and discharge lines containment isolation valves (IV 38-01, -02, -12, and -13) by pressurizing the volume between the two isolation valves in each penetration.

During this mode of testing pressure would be applied on the inside isolation valve in the reverse direction to that which would be experienced when the valve is required to isolate containment.

Appendix J requires that during leak testing the pressure shall be applied in the same direction as would be experienced when the valve would be required to perform its safety function, unless it can be determined that the results from the tests for a pressure applied in a different direction will provide equivalent or more conservative results.

In your July 28, 1988 submittal you did not provide supporting evidence to conclude that testing in the reverse direction would be acceptable.

In fact, your submittal indicated that testing in the reverse direction might not be a conservative test for the inside isolation valves.

Furthermore, your July 28, 1988 letter stated Niagara Mohawk's position is that the subject valves should not be required to be tested in accordance with Appendix J requirements.

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The staff does not agree with Niagara Mohawk's position that these valves need not be leak tested in accordance with Appendix J requirements.

The staff's position is that these valves may be required to provide a primary reactor containment isolation function and, if unable to perform this function adequately, could provide a pathway for leakage from the primary reactor containment to the outside environs.

Consequently, it is the staff's position that these valves be tested in accordance with the requirements of Appendix J.

2.

The staff agrees because of the water seal for the Control Rod Drive System isolation valves

( IV 301-112 and -113), these valves do not require local leak rate testing in accordance with the requirements of Appendix J.

However, it should be noted that this exclusion does not preclude any leak rate testing requirements that may exist under the Inservice Testing Program requirement of 10 CFR Part 50.55a.

3.

Your July 28, 1988 submittal provided portions of a proposed procedure change to ensure that the Containment Spray System discharge line isolation valves would be water sealed in the event of a LOCA.

As it has been discussed with Mr. Peter Francisco of your staff, the NRC staff will complete its review of this issue following receipt of the complete, approved procedure.

In addition, your letter of September 2,

1988 committed to submitting revised Technical Specifications reflecting the resolution of the open Appendix J issues within 30 days after the receipt of our response to your July 28, 1988 submittal.

Some of the Appendix J issues, as discussed

above, have still not been fully resolved; consequently, revised Technical Specifications on these issues should not be submitted until resolution is reached.

However, we note that the non-existance of Technical Specification requirements, does not relieve you of the responsibility to meet Appendix J requirements, particularly for those issues which have been resolved or for which clarification has been provided.

Sincerely, cc:

See next page Mary F. Haughey, Project Manager Project Directorate I-1 Division of Reactor, Projects, I/II NAME :CVogan

MHaughey:dig:RCapra DATE':11/5'88: 11/ /88: 11/oS /88

'OFFICIAL RECORD COPY

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Mr. C.,Y. Mangan Niagara Mohawk Power Corporation Nine Mi1 e Point Nucl ear Station, Unit No.

1 CC:

Mr. Troy B. Conner, Jr.,

Esquire Conner 8 Wetterhahn Suite 1050 1747 Pennsylvania

Avenue, N.

W.

Washington, D.

C.

?0006 Mr. Frank R. Church, Supervisor Town o< Scriba R.

D. ¹2

Osweqo, New York

13126, Mr. James L. Willis General Supt.-Nuclear Generation Niaqara Mohawk Power Corporation Nine Mile Point Nuclear Station Post Office Box 3P

Lycoming, New York 13093 Resident Inspector U. S. Nuclear Regulatory Commission Post Office Box 126

Lycoming, New York 13093 Mr. Gary D. Wilson, Esquire Niagara Mohawk Power Corporation 300 Erie Boulevard West

Syracuse, New York 13202 Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, Pennsylvania 19406 Ms.

Donna Ross New York State Energy Office 2 Empire State Plaza 16th Floor

Albany, New York 12223 Mr. Kim Dahlberg Unit 1 Station Superintendent Nine Mile Point Nuclear Station Post Office Box 32

Lycoming, New York 13093 Mr. Peter E. Francisco, Licensirg Niagara Mohawk Power Corporation 301 Plainfield Road

Syracuse, New York 13212 Charlie Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, New York 10271 Mr. Paul D.

Eddy New York State Public Service Commission Nine Mile Point Nuclear Station-Unit 2 Post Office Box 63

Lycoming, New York 13093

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