ML17199T722
| ML17199T722 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 01/10/1988 |
| From: | Silady J COMMONWEALTH EDISON CO. |
| To: | Murley T Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8801210276 | |
| Download: ML17199T722 (19) | |
Text
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Addres.s Reply to: Post Office *sox 767 Chicago, Illinois 60690 - 0767 Januac-y 10, 1988 Mc-. T. E. Muc-ley, Dic-ector Off ice of Nucleac-Reactoc-Regulation U.S. Nucleac-Regulatoc-y Conunission Washington, DC 20555
Subject:
Dc-esden Station.Unit 3 Refec-ences:
Request foc-Schedulac-Exemption fc-om 10 CFR 50, Appendix J, Type B and C Test Intec-val NRC Docket No. 50-249.
(1)
Januac-y 7, 1988 meeting/confec-ence call between CECo (N. Kalivianakis et al.), NRR (G. Holahan, et al.) and RIII (W. Foc-ney, et al.)
(2)
Septembec-30, 1986 lettec-fc-om J. M. Lydon (Boston Edison) to' W. Pac-lec- (USNRC) c-equesting 10 CFR 50 Appendix J intec-pc-etation (Docket 50-293, BECo Lettec-No.86-153)
(3)
Octobec-6, 1986 lettec-fc-om E. Eenigenbuc-g to H. Dentori tc-ansmitting the Dc-esden 3 Reactoc-Containment Building Integc-ated Leak Rate Test Repoc-t.
Deac-'Mc-. Muc-ley:
Puc-suant to 10 CFR 50.12(a), Conunonwealth Edison c-equests a schedulac-exemption foc-Dc-esden Unit 3 fc-om the two yeac-test intec-val foc-Type B and C leak c-ate tests c-equic-ed*by 10 CFR 50, Appendix J, Sections III.D.2(a) and III.D.3.
The exemption is c-equested to suppoc-t ouc-cuc-c-ent c-efueling outage schedule and avoid the potential foc-an eac-liec-c-eactoc-shutdown.
Dc-esden Unit 3 shutdown foc-its End of Cycle 9 (EOC 9) c-efueling and Recic-culation Pipe Replacement (RPR) outage on Octobec-28, 1985.
Due to the extensive RPR pc-ogc-am, the EOC 9 outage was unusually long with stac-tup not occuc-c-ing until Septembec-, 1986.
Type Band C local leak c-ate testing conunenced on Septembec-27, 1985 and continued thc-ough August of 1986.
. As a c-esult of the extensive RPR outage, a fouc-week midcycle outage c-elated to feedwatec-system pc-oblems, and othec-considec-ations, the shutdown foc-c-efueling has been delayed to Mac-ch 26, 1988.
Maintaining this schedule will c-esult in exceeding the two yeac-test intec-val when the Appendix J c-equic-ement is intec-pc-eted to apply on a component-by-component basis.
- ~-
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pi As was discussed during the Reference (1) teleconference/meeting, the normat practice at Dresden (as well as Quad Cities and Zion Stations) has been to define the Type B and C surveillance intervals on the basis of procedurally defined groups of components/pathways which must all be measured before compliance can be verified with the associated Technical Specification Limiting Condition of Operation (LCO) on Primary Containment Integrity.
Dresden LCO 3.7.A.2.b(2)(a) requires that the summation of leakage rates from all applicable pathways must be less than 603 of the allowable total.
This has been the historical basis for using the completion date of the defined groups.
In Reference (2) Boston Edison formally requested an NRC interpretation of this aspect of Appendix J, i.e., whether testing intervals for Type B & C tests are required on a component specific basis or whether a component group or "program" approach is acceptable.
Our understanding is that a formal NRC interpretation of the regulation has not yet been provided. It is clear from the Reference (1) discussions, however, that the current Staff position is that component specific test intervals not exceed two years.
We therefore request a 90 day extension to the two year Appendix J test interval for the components identified in Attachment 1.
These components either cannot be tested while the reactor is at power or would require entry into an LCO.
The 90 day period from the date of this letter will allow us to reach cold shutdown within our current schedule.
As stated in our Technical Specifications, primary containment integrity (including compliance with the allowable total of local leakage rates) is not required when in the cold shutdown condition.
Commonwealth Edison will, however, test the components listed in Attachment 1 as soon as reasonably possible following the EOC 10 shutdown or during any earlier outage of suitable duration should one occur prior to March 26, 1988.
The remaining attachments to this letter contain the following:
a) provides our justification for the exemption in accordance with the guidance in 10 CFR 50.12a.
b) provides several tables of additional data and information on the Dresden 3 potential leakage pathways, as discussed and requested during the Reference (1) conference call. Included is a history of the Local Leak Rate Tests (LLRTs) for the untested pathways listed in Attachment 1 including the average as-found leakages for the last three testing programs.
c) summarizes the calc't.1lations performed to conclude that the total leakage of all pathways subject to specification 3.7.A.2.b(2)(a) is l~ss than 0.60 LA when best estimates ar~ included for the components listed in At tactµnen_t 1.
For the 59 local leakage pathways from Tables A and B of Attachment 3 which were testable during operation, the current total leakage recently measured (from January 7 through 9, 1988) is 75 scfh.
This represents a reduction from the total measured for the same pathways at EOC 9 which was 103 scfh, based on the LLRT data reported in Reference (3).
A review of all other CECo nuclear stations has verified that there are no other instances where the two year Appendix J pathway test interval has been exceeded to date in the current operating cycles, based on our understanding of the current Staff position.
Should projections indicate the need for any additional exemptions to complete current operating cycles on the other plants, appropriate requests will be made.
In accordance with 10 CFR 170, a fee remittance in the amount of
$150.00 is enclosed.
One signed original and ten (10) copies of this transmittal are provided for your use.
Please direct any questions you may have regarding this matter to this office.
Very truly yours, f!.A~S~
, Nuclear Licensing Administrator Attachments
"-.. 'ii cc: A.B. Davis - Regional Administrator (RIII)
G. Holahan -
NRR K. Grotenhuis - NRR W. Forney - RIII NRC Resident Inspector - Dresden
VALVE OR PENETRATION TEST PROBLEMS A0-4720 & 4721 A0-4722 & Check Valve 220-57A & 62A
. 1101-1 & 15 1101-1 & 16 1501-lBA & 19A 1501-20A & 3BA 1501-lBB & 19B 1501-20B & 3BB M0-1402-4A, BA, 25A, 36A M0-1402-4B, BB, 25B, 36B.
M0-1301-1 & 2 A0-220..:.44 & 45 ATTACHMENT 1.
LIST OF UNTESTED PATHWAYS FOR WHICH EXEMPTION IS REQUESTED Drywell Pneumatic Supply Isolation Drywell Pneumatic Supply Isolation Feedwater Check Isolation Standby Liquid Control Injection Standby Liquid Control Injection*
LPCI Loop A LPCI Loop A LPCI Loop B LPCI Loop B Core Spray Injection Core Spray Injection Isolation Condenser Steam Supply Recirc Loop Sample Isolation REASON FOR NOT TESTING AT POWER Testing pathway could cause main steam isolation valve to close.
~- -
Testing pathway will cause main ~team isolatio*n valve to close.
Testing would require isolation of the *reactor feedwater system
. and a unit shutdown.*
Test isolation valves are located in the *inerted drywell and inaccessib~e during operation~
Test isolation valves are*located in the inerted drywell and are inaccessibl'e during operation.
- Testing pathway would require entry into a limiting condition of operation.
Testing pathway would require entry into a limiting condition of operation.
Testing pathway would require entry into a limiHng condition of operation.
T~sting pathway.would require entry into a limiting condition of operation.
Testing.pathway would require entry into a limiting condition of operation.. One ~est boundary would' be pressurized at lOOO*psig preventi~g necessary 6P for valid testing.
Testing pathway would require entry into* a limiting.condition of operation.. One test boundary would be pressurized at at 1000 psig preventing necessary 6P for*valid testing.
Testing pathway would require entry into a limiting condition of operation.
One test boundary would be pressurized at at.1000 psig preventing necessary 6P for valid testing.
One test boundary would be pressurized at 1000 psig preventing necess*ry 6P for valid testing.
1*...
ATTACHMENT 1 (Continued)
LIST OF UNTESTED PATHWAYS FOR WHICH EXEMPTION IS REQUESTED VALVE OR PENETRATION 205-2-4 & Flange 205-2-7 & Flange M0-3702 &
3799-126 Reactor Head Cooling.
Reactor Head Cooling
- RBccw to Drywell coolers Drywell Head Hanway Double Gasket Seal A0-1301-17 & ~O Isola.tion Condenser Vents M0-220-1 & 2 Main Steam Line Drain M0-2301-4 & 5 HPCI Steam S4pply M0-2301-35 & 36 HPCI Pump Suction 3-301-156A,157 Scram Discharge Vo.lume 3-301-160A,161A Scram Discharge' Volume 3-301-156B,157B Scram Discha~ge Volume 3-30i'-160B,161B Scram. Discharge Volume REASON FOR NOT TE*STING AT POWER Test boundary inaccessible dur~ng operation.
Test boundary inaccessible during operation.
Testing of pathway results in loss of drywell cooling and could c~us.e *a reactor scram.
T~st boundary'-inaccessible during*operatio~.
On.e *test boundary will be* pressur.ized at 1000 psig preventing A.*
necessary 6P for valid testing.
~
One test boundary will.be pressurized at 1000 psig preventing necessary 6P for valid testing.
Testin*g pathway would require entry. into a limiting condition
.
- of opera.ti on.
Testing pathway would require entry into a limiting condition of operation.
Testing *Of pathway. could. cause a reactor scram.
Testing.of pathway could cause a reactor scram.
Testing. of pathway could cause a reactor scram.
- Testing of pathway. could cause a reactor scram.
EXEMPTION:
BASIS:
ATTACHMENT 2 JUSTIFICATION FOR SCHEDULAR EXEMPTION FROM 10 CFR 50, APPENDIX J TYPE B AND C TEST FREQUENCY Commonwealth Edison requests a 90 day extension to the 2 year test interval in 10 CFR 50, Appendix J, Sections III.D.2(a) and III.D.3 for certain Type B and C components at Dresden Station Unit 3.
As discussed in the following sections, the requested exemption meets a) the three necessary criteria of 10CFR50.12(a)(l) and, b) and at least one special circumstance described in 10CFR50.12(a)(2) to define when an exemption will be considered.
A.
Criteria for Granting Exemptions Are Met per 10CFR Part 50.12(a)(l}:
- 1. The Requested Exemptions and' the Activities Which Would Be Allowed Thereunder are Authorized by Law.
If the criteria *established in 10 CFR 50.12(a) are satisfied, as they are in this case, and if no other prohibition of law exists to. preclude the activities which would be authorized by the requested exemption, and there is no such prohipition, then the Commission is authorized by law to grant *this exemption request. 11
- 2. The Requested Exemptions Will Not Present Undue Risk to the Public As stated in 10 CFR 50, Appendix J, the purpose of the primary containment leak rate testing requirements is to ensure that leakage rates are maintained within the Technical Specification requirements and to assure that proper maintenance and repair is performed throughout the service life of the containment boundary components.
The requested exemption is consistent with this intent in that it represents a one time only schedular extension of short duration.
The required leak tests will still be performed to assess compliance with Technical Specification requirements and to assure that any required maintenance or repair is performed.
As noted in Sections III.D.2 and III.D.3 of Appendix J, it was intended that the testing be performed during refueling outages or other convenient intervals.
Extending the two year interval by a small 11 See U.S. vs. Allegheny-Ludlum Steel Corp., 406 U.S. 742, 755 (1972).
amount to reach the next refueling outage will not significantly impact the integrity of the containment boundary and therefore will not significantly impact the consequences of an accident or transient in the unlikely event of such an occurrence during the 90 day extended period.
This exemption will not, therefore, "present an undue risk to the public health and safety."
This is further supported by the information provided in.
Tables A and B identify which of the pathways affected by the current Staff position were tested during the July 1986 Integrated Leak Rate Test (ILRT).
Although some local leak rate testing intervals will exceed two years by the end of the current operating cycle, the fact that a number of these pathways were tested as part of the ILRT within two years provides additional assurance that containment integrity has not been compromised.
In addition, the pathways for which testing would be deferred have in general demonstrated good local leak rate test results as indicated in Table c.
Finally our conclusion is that the estimated current total leakage from all applicable pathways is below the allowed value as indicated in Attachment 4.
- 3.
The Requested Exemptions Will Not Endanger The Common Defense and Security The common,defense and security are not in any way compromised by this exemption request. '
B.
At Least One of the Special Circumstances Are Present Per 10CFR50.12(a)(2).
- 1.
The Requested Exemptions Will Avoid Undue Hardship or Costs The requested schedular extension is a forced shutdown of Dresden Unit 3.
refueling and maintenance outage are the scheduled shutdown date of March earlier forced shutdown would result required to prevent Preparations for a proceeding based on 26, 1988.
An in an overall increase in the duration of the outage since equipment delivery, preparation and mobilization of work forces could not be accelerated sufficiently to support such a large advancement of the outage.
If a separate forced outage were imposed (and operation resumed until March 26, 1988) the additional testing could require up to a week or more of downtime.
For either scenario, the substantial replacement power costs incurred to provide alternate supplies of power during the outage period would be borne by Commonwealth Edison and our customers.
Because the requested exemption does not jeopardize the health and safety of the public as previously discussed, its approval is warranted in order to prevent the financial impact that would result from an early forced shutdown.
Commonwealth Edison does not believe that,
when Appendix J was implemented, extended outages (such as those required for Recirculation Pipe Replacement) or extended operating cycles (such as those associated with 18 to 24 month fuel cycles or extended coastdowns) were foreseen.
Exemptions to Appendix J requirements have subsequently been granted in such cases.
The Dresden 3 situation therefore represents a special circumstance per item (iii) of 10CFR50.12(a)(2) i.e.
"Compliance would result in undue hardship or other costs that are significantly in excess of those contemplated when the regulation was adopted, or that are significantly in excess of those incurred by others similarly situated."
- 2.
The Requested Exemptions Provide Only Temporary Relief And the Licensee Has Made Good Faith Efforts To Comply As discussed above, the exemption request is for a short duration relative to the two year requirement.
In addition, all testing that can be reasonably performed while the plant is operating has been completed and additional testing will be p~rformed if an unscheduled
.outage of suitable duration should occur.
This meets an additional criterion for a special circumstances per item (v) of 50.12(a)(2), i.e.
"The exemption would provide only temporary relief from the applicable regulation and the licensee or applicant has made good faith efforts to comply with the regulation."
This attachment contains four table~ of d~ta requested in Reference {1).
They are as follows:
Table A Table B Table D provides information for those pathways which are beyond a two year interval based on the current Staff position.
provides information for those pathways which wi 11 exceed a two year interval before the scheduled* refueling outage (based on the current Staff position).
prov ides a hi story of the LLRT data for the untested pathways listed in Attachment 1, including the average as-found leakages for the last three testing programs.
Only the la~t two outages were used for several pathways for reasons stated on the Table.
- contains individual test leakages used to estimate the total maximum path leakage in the Attachment 4 methodology for "case D".
It designates whether the individual leakage listed was measured during the previous refueling outage, measured recently (Jan. 7-9, 1988), or estimated using the historical average (from Table C) for those pathways proposed for test deferral.
TABLE A LOCAL LEAK RATE TESTS BEYOND A 2 YEAR INTERVAL ON A TEST TO TEST BASIS VALVE OR*PENETRATION East Torus Drain Valves West Torus Drain Valves A0-4720 & 4721 A0-4722 & Check Valve 220-57A & 62A Drywell Pneumatic Supply Isolation Drywell Pneumatic Supply Isolation F~edwater Check tsolation 1101-1 & 15 1101-1 & 16 M0-1501-lBA & 19A M0-1501-20A &.3BA M0-1501-lBB & 19B
.M0-1501-20B & 38B Standby Liquid Control Injection standby Liquid.control Injection LPCI Torus Spray Isolation LPCI Test Return LPCI Torus Spray Isolation
- LPCI Test* Return M0~1402-4A,8A,25A,36A Core Spray Injection M0-14_02-4B, BB, 25B, 36B Core Spray Injection M0-1301-1 & 2 Isolation Condenser Steam Supply
'A0-220-44 & 45 Recirc Loop.Sample Isolation Penetration Bellows X-105A Penetration Bellows X-105B Penetration Bellows X-105C Penetration Bellows X-105D Penetration Bellows X-106 Penetration Bellows X-107A Penetration Bellows* *X-108A Penetration Bellows.X-107B Penetration Penetration Penetration Penetration Penetration Penetration Penetration Penetration Penetration Penetration Penetration Penetration Bellows X-109A Bellows X-lllA Bel.lows *X-lliB Bellows X-128 Bellows X-123 Bellows i:-124
. Bellows X-125 M0-3702 & 3799-126
- Drywell Head
.A0-1301-17 & 20 M0-220-1 & 2 M0-2301-4 & S M0-2301-35 & 36.'
Bellows X-126 Bellows X-138 Bellows X-147 Bellows X-149A Bellows X-149B RBCCW to Drywell Coolers Hanway Double.. Gasket Seal Isolation Condenser Vents Main Steam Line Drain HPCI Steam Supply.
HPCI Pump Suction VOLUMES VENTED DATE PREVIOUSLY AND DRAINED DURING PERFORMED JULY 1986 ILRT 9-27-85 x
9-27-85.
x 10-31-:-85 10-31-85.
11~5-85. *.
11-13-85
- l.1-13-85 11-14-85 11....
- 14-85 11-15-85 11-15-85 11-16-85 n-11....:s5 12-1-85 12-8-85 12-8-85 12-8-85 12-8-85 12-8-85 12-8-85
. 12-'-8-85 12-8-85 12-8-.85 12-8-85 12-8-85 12-8-85 12-8-85
- 12-8-85 12-8-85 12-8-85 12.'...8-85 12-:8.-85 12-8-85
'12-8-85 12-8-85.
12-9-85
- 12-15-85 12-1.7-85 12-18-85 1-2-86 1-2..:.86 x
x x
x x
x x
x x
x x
x x
x x
x
- x.
x x
x x
.x x
x x*
x
.X
COMPONENT A0-3-301-156A,157 A0-3-301-160A,161A A0-3-301-156B,157B A0-3-301-160B,161B A0-2001-5,6 A0-2001-105,106 A0-1599-61,62 X-136A X-136B X-136C X-136D X-136E X-136F A0-205-2-4 & Flange A0-205-2-7 & Flange A0-2499-1A,2A A0-2499-1B,2B A0-2599-2A,23A A0-2599-4A,5A A0-2599-4B,5B X-200C X-201B X-202B X-202BB X-202D X-20iF X-202J X-202N X-202Q X-202S
. X-202W X-203B X-204A*
X-204E X-204H X-204M X-204N X-204Q X-204S X-205B M0-1601-57,58,59 X-313A X313B TABLE B LOCAL LEAK RATE TESTS THAT WILL EXCEED THE 2 YEAR INTERVAL ON A TEST TO TEST BASIS DESCRIPTION Scram Discharge Volume Vents and Drains Scram Discharge Volume Vents and Drains Scram Discharg.e Volume Vents and Drains Scram Discharge Volume Vents and Drains Drywall Equipment Drain Sump Discharge Dryw:ell Floor Drain Sump Discharge Torus to Condenser Drain Tip Monitor Flange Tip Monitor Flange Tip Monitor Flange Tip Monitor Flange Tip Monitor Flange Tip Monitor Flange Reactor Head Cooling Reactor Head Cooling
- CAM H2 to.Sensor CAM H2 to Sensor ACAD Purge ACAD Vent ACAD Vent Electrical Penetrations Electrical Penetrations Electrical Penetrations Electrical Penetrations Electrical Penetrations Electrical Penetrations Electrical Penetrations Electrical Penetrations Electrical Penetrations
.Electrical Penetrations Electrical Penetrations Electrical Penetrations Electrical Penetrations Electrical Penetrations Electrical Penetrations Electrical Penetrations Electrical Penetrations
- El~ctri6al Pen~trations Electrical Penetrations Electrical Penetrations N2 Makeup To Drywell E. To:i;-us Drain W. Torus Drain VOLUMES VENTED DATE PREVIOUSLY AND DRAINED DURING PERFORMED 1-11-86 1-11.:..86 1-11-86 1-11-86' 1-11-86*
1-21-86 1-21-86
. 2-2-86 2-2-86 2-2-86 2-2-86 2-2-86 2-2-86 2-6-86 2-6-86 2-16-86 2-16-86 2-23..:86 2-23-86 2-23-86 3-2-86 3-2-86 3-2-86 3-2-86 3-2-86 3-2-86 3-2-86 3-2-86 3-2-86 3-2-86 3-2-86 3-2-86 3....:2-86 3..,.2-86 3-2-86 3-2-86 3-2-86 3-2-86 3-2-86
.3-2-86 3-16-86.
3:--18-86 3-18-86 JULY 1986 ILRT X' x x
x x
x x
x x
x x
x x
x x
x x
x x
x x
x x
x x
- x
- x.
x
,~
RECENT TEST DATE None None None None 1-9-88 1-9-88 1-8-88 1-9-88 1-9-88 1-9-88 e 1-9-88 1-9-88 1-9-88 None None 1-8-88 1-8-88 1-8-88 1-8-88 1-8-88 1-9-88 1-9-88 1-8-88.
1-9-88 1-8-88 1-9-88 1-8-88 e
. 1-8-88 1-8-88
- 1-8-88 1-9-88 1-9-88 1-8-88 1-8-88 1-8-88 1-9-88 1-9-88 1-9-88 1-9-88 1-9-88 1-9-88 1-9-88 1-9"'-88
TABLE C, LLRT.HISTORY OF UNTESTED PATHWAYS.
MAXIMUM PATH LEAKAGES IN SCFH*
1982.
1984 1985 AVERAGE PENETRATIONS AS FOUND AS LEFT*
AS FOUND.
AS.LEFT AS FOUND AS. LEFT AS FOUND 4720 & 4721 0.00
.0.00 4.14 4.14 2.62 2.62 2.25 4722 & Check 0.24 0.24 3.92
.J.92 1.949 1.949 2.04 220-57A & 62A 25.9 25.9 87.9 9.33 10.85 10.85 41.55 e 1101-1 & 15 0.96 0.96 11.115 11.115 0.00 6:00 4.02 1101-1 & 16
- 23.14 23.14 0.00 0.00 11.81 11.81 11.65 1501-18A & 19A 0.00 0.00 1.185.
1.36 4.534 4.534 1.91 1501-20A & 38A 7.83 7.83 4.OS*
4.05 1.94 1.94 4.61 1501-18B & 19B 0.38 0.38
. 0.00
.783 0.5917 0.5917 0.32 1501-20B & 38B 2."48 2.48 0.00 0.00 1~294 1.294 1.26 1402-4A,8A,2SA,36A 0-.56 0.56 0.00 0.00 3.44 3.44 1.33 1402-4B,8B,25B,36B 0.00 0.00 0.918 0.918 1.821 1.821 0.91 1301-1 & 2 0.00 0.00
- 2.15 2.15 0.9365 0.9365 1.03 220-44 & 45 0.00 o:oo 0.00 0.00 0.033 0.033 0.01 205-2-4 & Flange 0.09 0.09 O.OQ 0.00 17.92 17.92 6.00 205-2-~ & Flange 0.28 0.28 0.00 0.00 0.00 0.00 0.09 3702 & 3799-126 0.289 0.289 0.00 0.00 0.15 1301.:.17 & 20 1.07 1.07
, 0.649 0.649
- 1. 74
- 1. 74 1.15 220-1 & 2 6.49 2.84 7.67 7.67 54.328
- 1. 736 22.83 2301-4 & 5 1.02 1.02 2.12 2.12 3.44 3.'44 2.19 e 2301-35 & 36 0.00 0.00 79.82 19.73 1.437 1.437 27.09 Drywell Head Hanway 0.00 O.QO
. 0.00 0.00 0.00 0.00 0.00 3-301-156A,157A 1.67 1.67 3.82 3*.82*
2.75 3-301-160A,161A 0.53 0.53 0.19 0.19 0.36 3-301-156B,157B 116.23 0.86 3.58 3.58 59.91 3-301-160B,161B 4.39 4.39 5.37 5.37 4.88 70.44 66.79 "328.75 75.674 133.64
. 81.05 200.29
- - Indicates that the valves were installed as a modification during the 1982 refueling outage and were not in service.during the pre~ious operating cycle.
- - Indicates that these valves were not tested prior to the 1984 program based on previous interpretatio~ of closed loop systems..
.TABLE D TYPE OF PATHWAY:
Primary Containment Isolation Valves Penetration Leakage Number Volume Being Tested SCFH Source of Leakage Used X-310B 1402-4B,8B,25B,36B
.91 Historical Average X-311A 1501-18A&19A 1.91 Historical Average X-311B 1501-18B&19B
.32 Historical Average X-310B 1501-20B&38B
- 1. 26 Historical Average X-310A 1501-20A&38A 4.61 Historical Average NA 1599-61&62
- 3. 77 Recent Test X-126,304 1601-57,58,59 0.421 Recent Test X-118 2001-5&6
.854 Recent Test X-117 2001-105&106
.281 Recent Test X-128 2301-4&5 2.19 Historical Average NA 2301-35&36 27.09 Historical Average X-202V 2499-1A&2A 0.0 Recent Test X-204B 2499-1B&2B 0.0 Recent Test X-202V 2599-2A&23A 3.285 Recent Test X125,318 2599-4A&5A 9.235 Recent Test X-125,318 2599-4B&SB 1.558 Recent Test X-123 3702&3799-126
.15 Historical Average X-139D 4720&4721 2.25 Historical Average X-121 4722 & Check 2.04 Historical Average X-313A E. Torus Drain Vlvs 0.0 Recent Test X-313B
- w. Torus Drain Vlvs 0.0 Recent Test X-147 205-2-4&flange 6.00 Historical Average X-147 205-2-7 &flange 0.09 Historical Average X-106 220-1&2 22.83 Historical Average X-122 220-44&45
.01 Historical Average X-107A 220-57A&58A 41.55 Historical Average NA 302-156A&157A 2.75
- Historical Average NA 301-160A&161A
.36 Historical Average NA 301-156B&157B 59.91 Historical Average NA 301-160B&161B 4.88 Historical Average X-138 1101-1&15 4.02 Historical Average X-138 1101-1&16 11.65 Historical Average X-108A 1301-1&2 1.03 Historical Average X-108A, 109A 1301-17&20 1.15 Historical Average X-310A 1402-4A,8A,25A,36A 1.33 Historical Average
TABLE D TYPE OF PATHWAY:
Drywell Bellow Seals Penetration Leakage Number Volume Being Tested SCFH Source of Leakage Used X-105A Hain Steam 3.412 Recent Test X-105B Main Steam 0
Recent Test X-105C Main Steam co Recent Test X-1050 Main Steam 0
Recent Test X-106 Main Steam Drain 0
Recent Test X-107A Feedwater 0.604 Recent Test X-107B Feedwater 0
Recent Test X-108A
!so. Cond. Steam 0
Recent Test X-109A
!so. Cond. Condensate 0
Recent Test X-lllA Shutdown Cooling 1.9 Recent Test X-lllB Shutdown Cooling 0
Recent Test X-128 HPCI Steam 0
Recent Test X-123 RBCCW Inlet 0
Recent Test X-124 RBCCW Outlet 0
Recent Test X-125 Vent From DW 0
Recent Test X-126 Vent To DW 0
Recent Test X-138 SBLC 0.562 Recent Test X-147 Rx head Spray 0
Recent Test X-149A Core Spray 0.432 Recent Test X-149B Core Spray
- 0. 734 Recent Test
TABLE D TYPE OF PATHWAY:
Double Gasketed Seals Penetration Leakage Number Volume Being Tested SCFH Source of Leakage Used X-136A Tip Flange 0.0 Recent Test X-136B Tip Flange
.082 Recent Test X-136C Tip Flange 0
Recent Test X-136D Tip Flange 0
Recent Test X-136E Tip Flange
.661 Recent Test X-136F Tip Flange 0.0 Recent Test X-137 ow head Hanway 0.0 Historical Average X-313A E. Torus Drain 0.0 Recent Test X-313B
- w. Torus Drain 0.0 Recent Test
TABLE D TYPE OF PATHWAY:
Electrical Penetrations Penetration Leakage Number Volume Being Tested SCFH Source of Leakage Used X-200C LV Power & Control 8.130 Recent Test X-201B HV Power 1.016 Recent Test X-202B CRD Indication 0.103 Recent Test X-202BB CRD Indicator 0.0 Recent Test X-2020 HV Power 0.0 Recent Test X-202F Thermocouples 8.965 Recent Test X-202J Neutron Monitor 0.. 0 Recent Test X-202N Neutron Monitor 0.0 Recent Test X-202Q Instrumentation 0.0 Recent Test X-202S CRD Indicators 2.571 Recent Test X-202W CRD Indic.ators 3.074 Recent Test X-203B HV Power 0.0 Recent Test X-204A HV Power 2.376 Recent Test X-204E Neutron Monitor 0.0 Recent Test X-204H Neutron Monitor 0.103 Recent Test X-204M LV Power 6.125 Recent Test X-204N CRD Indicator 0.00 Recent Test X-204Q CRD Indicator 0.561 Recent Test X-204S LV Power & Control 14.062 Recent Test X-205B CRD Indicator 0.0 Recent Test
ATTACHMENT 4 An estimation of the present total local leak rate is presented in this attachment using six different methodologies based on 1985 as-found, 1985 as-left, recent test, and averaged data from the last three test programs.
Combinations of the data are exhibited on the attached table.
The basis of each meth.odology can be derived from the table or the attached description list.
All cases except case D result in a total estimated leakage of less than the 0. 6 LA value of 493. 116 SCFH.
Case D was evaluated to have one data point which was considered to be an outlier. and case D' deletes that data point.
All calculations were based on mcµci~um path leakage as requested by the Staff in Reference (1).
However,
- the total minimum path leakage, which is the usual method of assessing primary containment integrity for postulated accident conditions, is less than 0. 5 LA.
This is based on the most limiting methodology in the attached matrix (case D) except for the use of minimum leakage paths.
METHODOLOGY A
B c
D D'
E UNEXPIRED 224 224 224 224 224 224 RECENTLY TESTED 75 75 75 75 75 75 UNTESTED AS LEFT AVG 3 AS FOUND AVG 3 AVG 3 AS FOUND EXPIRED
'85 AS FOUND
'85 50 126 103 126 126 103 UNTESTED AS LEFT AS LEFT AS LEFT AVG 3 AVG 3 AS FOUND EXPIRES
'85
'85
'85 1/11 - 3/26 31**
31**
31**
74 18 31**
TOTAL 380 456 433 499 443 433
[0.6 LA = 493.116 SCFH)
UNEXPIRED:
RECENTLY TESTED:
UNTESTED EXPIRED:
UNTESTED EXPIRES:
1/10/88 - 3/26/88 AS LEFT '85 AVG. 3 AS-FOUND AS-FOUND '85 TOTAL:
DEFINITIONS Results for the as-left 1985 local leak rate test (LLRT)*
for those type B & C tests which will not exceed a two year component-by-component test interval prior to unit shutdown, in standard cubic feet per hour (SCFH).
Results from those Type B & C tests, which have or would have exceeded a
two year component-by-component test interval and have been tested within the last week during power operation, in SCFH.
Those Type B & C tests which have exceeded a two year component-by-component test interval and can not reasonably be tested during power operation.
Those Type B & C tests which will expire between now and the unit outage.
As left leakage in SCFH for tests performed during the 1985 LLRT*.
Simple average** of the as-found test results for the last three (3) tests, in SCFH.
As-found leakage in SCFH. for tests performed during the 1985 LLRT*.
Total leakage, in SCFH, for actual and averaged individual test results, as noted.
- Reactor Containment Building Integrated Leak Rate Test report, Dresden Nuclear Power Station, Unit 3 (E. Eenigenburg to H. Denton dated Oct. 6, 1986).
- The six valves repairs at EOC 9.
same.
in this category were acceptable without any required The as-left '85 and as-found '85 values are therefore the
METHODOLOGY DESCRIPTION A.
This methodology uses results from the most recent tests (running total method).
B.
This methodology uses actual as-left (1985) or recent (as-found) data for all test points measured within the last two years as of January 11, 1988, and simple averages of the last three as-found test results for those points which have exceeded the two year test interval.
- c.
This methodology uses actual as-left (1985) or recent (as-found) data for all test points measured within the last two years, as of January 11, 1988, and the as-found (1985) test results for those points which have exceeded the two year test interval.
D.
This methodology uses actual as-left (1985) or recent (as-found) data for all test points measured within the last two years, as of January 11, 1988, and the simple average of the as-found test results for the last three (31 test intervals for those points which can not be reasonably tested during power operation and have or will have exceeded the two-year test interval by the start of the unit outage.
o'. This methodology is the same as case o, with the following exception.
Review of the case D data revealed that a single test, a scram discharge volume drain valve t~st, exhibited a**1arge (.- 116 SCFH) leakage.
The cause was evaluated and considered. to be a unique and isolated case.
For this reason, this data point was considered to be an outlier, and has been deleted from the data base:
E.
This methodology uses actual as-left (1985) or recent (as-found) data for all test points measured within the last two years, as of January 11, 1988 and as-found 1985 te~.t result,s fQr those test points which can not be reasonably tested during power *operation and have or will have exceeded the two year test interval by.the start of the unit outage.