ML17306A588

Responds to 920116 Amend Request Re Proposed Deletion of Type C Testing for 8 Valves in Shutdown Cooling Sys for Each Unit,Per 10CFR50,app J, Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors

ML17306A588
Person / Time
Site:	Palo Verde
Issue date:	03/19/1992
From:	Trammell C Office of Nuclear Reactor Regulation
To:	Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
References
TAC-M82811, TAC-M82812, TAC-M82813, NUDOCS 9203240300
Download: ML17306A588 (6)

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 March 19, 1992 Docket Nos.

50-528, 50-529 and 50-530 Mr. William F.

Conway Executive Vice President, Nuclear Arizona Public Service Company P.O.

Box 53999

Phoenix, Arizona 85072-3999

SUBJECT:

PROPOSED DELETION OF TYPE C TESTING OF SHUTDOWN COOLING ISOLATION VALVES (TAC NOS.

M82811, M82812, AND M82813)

This is in response to your amendment request of January 16, 1992, wherein you requested approval to delete Type C testing for 8 valves in the shutdown cooling system of each unit.

Type C testing is defined in 10 CFR Part 50, Appendix J, "Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors."

As we discussed with your staff, in our initial review of your request, we could not find a requirement in your technical specifications to actually conduct a Type C test on the valves in question.

Technical Specification 4.6.3.4 requires that the check valves specified in Section D of Table 6.3-1, "Containment Isolation Valves,"

be demonstrated to be operable pursuant to 10 CFR Part 50, Appendix J,'ith the exception of those check valves footnoted as "not Type C tested."

The valves which are the subject of the amendment request are not located in Section D of Table 3.6-1, and there are no other Appendix J references or call-outs in the other surveillance requirements associated with this table.

We learned from our discussion that, in practice, Arizona Public Service Company uses Table 6.3-1, "Containment Isolation Valves," as a list for valves that are subject to Type C testing.

This is suggested by the appearance of the symbol "II", indicating that the valve is not Type C tested, appearing opposite a number of other valves in sections other than Section D discussed above.

This tends to suggest that all the other valves listed in the table are subject to Type C testing, when in fact there is no surveillance statement that explicitly says so.

Because this is confusing, you may wish to propose a

clarifying amendment in the future.

We would like to turn now to the substance of your amendment request:

whether or not it is acceptable to delete Type C testing of these 8 specific valves.

The justification that you provide is that Appendix J,Section II.H, does not include these valves in the four categories of containment isolation valves that are subject to Type C testing.

9203240300 920319 PDR ADOCK 05000528 P

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Mr. Willaim F.

Conway This may be correct, although there is some question as to whether these valves have the potential to "operate intermittently under post-accident conditions."

Regardless,Section II.H does not provide the complete definition of which containment isolation valves must be Type C tested.

Standard Review Plan Section 6.2.6 requires testing of containment isolation valves that are potential containment atmosphere leak paths.

This is supported by Section III.A.1(d) of Appendix J, which states that containment isolation valves in certain systems defined therein must be tested in accordance with III.C (i.e.,

be Type C tested).

Since the shutdown cooling return lines are connected to the reactor coolant system, and the reactor co'olant system would be ruptured and open to the containment atmosphere during a loss-of-coolant accident, the return lines are potential containment atmosphere leak paths.

Therefore, the containment isolation valves in these lines must be Type C tested.

This completes NRC action on this matter.

Sincerely, Vfl~v Charles M. Trammell, Sr. Project Manager Project Directorate V

Division of Reactor Projects III/IV/V Office of Nuclear Reactor Regulation CC:

See next page

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Mr. William F.

Conway Arizona Public Service Company Palo Verde CC:

Nancy C. Loftin, Esq.

Corporate Secretary 8 Counsel Arizona Public Service Company P.

O.

Box 53999, Mail Station 9068

Phoenix, Arizona 85072-3999 James A. Beoletto, Esq.

Southern California Edison Company P.

O.

Box 800

Rosemead, California 91770 Senior Resident Inspector U.S. Nuclear Regulatory Commission HC-03 Box 293-NR

Buckeye, Arizona 85326 Regional Administrator, Region V

U. S. Nuclear Regulatory Commission 1450 Maria Lane Suite 210 Walnut Creek, California 94596 Jack R.

Newman, Esq.

Newman

& Holtzinger, P.C.

1615 L Street, N.W., Suite 1000 Washington, D AC.

20036 Curtis Hoskins Executive Vice President and Chief Operating Officer Palo Verde Services 2025 N. 3rd Street, Suite 220

Phoenix, Arizona 85004 Roy P.

Lessey, Jr.,

Esq.

Bradley W. Jones, Esq.

Arkin, Gump, Strauss, Hauer and Feld El Paso Electric Company 1333 New Hampshire Ave., Suite 400 Washington, D.C.

20036 Mr. Charles B. Brinkman, Manager Washington Nuclear Operations ABB Combustion Engineering Nuclear Power 12300 Twinbrook Parkway, Suite 330 Rockvi lie, Maryland 20852 Mr. William A. Wright, Acting Director Arizona Radiation Regulatory Agency 4814 South 40 Street

Phoenix, Arizona 85040 Chairman Maricopa County Board of Supervisors 111 South Third Avenue

Phoenix, Arizona 85003

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Mr. Willaim F.

Conway March 19, 1992-This may be correct, although there is some question as to whether these valves have the potential to "operate intermittently under post-accident conditions."

Regardless,Section II.H does not provide the complete definition of which containment isolation valves must be Type C tested.

Standard Review Plan Section 6.2 '

requires testing of containment isolation valves that are potential containment atmosphere leak paths.

This is supported by Section III.A.1(d) of Appendix J, which states that containment isolation valves in certain systems defined therein must be tested in accordance with III.C (i.e.,

be Type C tested).

Since the shutdown cooling return lines are connected to the reactor coolant system, and the reactor coolant system would be ruptured and open to the containment atmosphere during a loss-of-coolant accident, the return lines are potential containment atmosphere leak paths.

Therefore, the containment isolation valves in these lines must be Type C tested.

This completes NRC action on this matter.

Sincerely, Original Signed By:

Charles M. Trammell, Sr. Project Manager Project Directorate V

Division of Reactor Projects III/IV/V Office of Nuclear Reactor Regulation CC:

See next page DISTRIBUTION:

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