ML19256D064
| ML19256D064 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/15/1975 |
| From: | Arnold R METROPOLITAN EDISON CO. |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19256D060 | List: |
| References | |
| GQL-1515, NUDOCS 7910160786 | |
| Download: ML19256D064 (5) | |
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mumnwm METROF 3LITAN EDISON COMPANY s:.es:cisRy or acnenAt PUBUC UTitlTIES CoRPORATIO.V OFFICE BOX 542 READING, PENNSYLVANI A 19603 TELEPHONE 215 - 929-3501 v.
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September 17, 1975
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GQL 1515 Director
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Division of Reactor Licensing 4
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C-U. S. Nuclear Co= mission 3
Washington, D. C.
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Dear Sir:
Three Mile Island Nuclear ' Station Unit 1 (D11-1)
Operating License 5DPR-50 Docket #50-289 Your letter dated August 7,1975, requested that Metropolitan Edison Company (Met-Ed) determine if Dil-1 was conducting containment leakage testing in full compliance with 10CFR50 Appendix J.
To date the following Reactor Building Containment Leak Rate Tests have been performed:
1.
Initial Integrated and Local '"ests (during the Startup Program) 2.
Access Hatch Semi-Annual Integrated Leak Rate Tes ts 3.
Access Hatch Periodic Door Seal Tests 4.
Reactor Building Purge Valve Annual Tests 5.
Penetration Pressurication System Quarterly Tests 6.
CA-V2 Post Maintenance Tests The above tests were conducted in accordance with Appendix J requirements.
Refueling f requency leak rate tests ("B" and "C" type) are scheduled for the upcoming January 1976 refueling outage.
In preparation for this leak rate testing, a review of the requirements of Unit #1 Technical Specification 4.4.1 and Appendix J was initiated in late 1974.
This review identified that in addition to the valves listed in Technical Specifications, the following valves required Type "C" tests in accordance with the requirements of Appendix J:
1.
Nuclear Service Closed Cooling Water (NS-V35) 79101607 2.
Intermediate Closed Cooling (IC-V2) 3.
Make-up and Purification (MU-V2 A/B and MU-V25)
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4.
Nuclear Sampling System (CA-V1, CA-V2, CA-V3, Ck-V4 A/B and CA-V13)
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5.
Waste Gas (WDG-V3) 6.
Liquid Waste Disposal (WDL-V303) 7.
Leak Rate System (LR-V49) 8.
Reactor Building Sump Drainage (WDL-V534) 9.
Industrial Cooler System (RB-V2*)
Valve LR-V49 will be tested with the Penetration Pressuriaation System.
Valve CA-V2 will be tested with the Fluid Block System.
The above additional requirements were identified to the TMI-l plant staff who concurred in December 1974 that the above additional Type C Tests would be perf ormed.
Based on the above, Met-Ed considers that the TMI-l Type "B" and "C" Testing Programs will be conducted in accordance with Appendix J. To insure that there is no misunderstanding in our interpretation of the Type "C" Leak Test requirements of Appendix J, Enclosure 1 lists those containment isolation valves which we do not consider require Type "C" testing and which are not scheduled for such testing.
With regard to TMI-l Type "A" testing program the f ollowing exceptions to and/or agreements concerning Appendix J were agreed upon during a January 15, 1974, meeting between GPU Service Corporation and the NRC (Report of Site Visit on January 15, 1974, part C "10CFR50, Appendix J") :
1.
Reactor Building Emergency River Water valves, RR-V3A thru C and RR-V4A thru D were exempt f rom the Type "C" Leak Test requirements of Appendix J,Section III.A.l(d).
Type "C" testing was not required since these valves are required to open under accident conditions to establish flow to the Reactor Building Emergency Cooling Fans.
2.
Nuclear Service Closed Cooling Valves, NS-V52A thru C and NS-V53A thru C were exempt from the Type "C" Test requirements of Appendix J,Section III.A.l(d).
This exemption was agreed upon since these valves are manual normally open valves which are aquired for cooling the Reactor Building E=ergency Cooling Fan motors.
3.
Decay Heat valves, DH-V2 and DH-V3 were exempt f rom the Type "C" test requirements of Section III. A.l(d) since these valves are required to be open for decay heat removal when the reactor is shutdown and must be closed when the plant is at pressure.
Therefore Type "C" testing cc ild not be performed on these valves.
4.
Type "C" testing of Reactor Building Air Supply and Exhaust lk b
valves, AH-VlB and AH-VlC could be accomplished with pressure applied in the opposite direction to that which would exist under accident conditions since testing of butterfly valves in this manner would provide equivalent test results.
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Our review indicates that only one other exception is required for the TMI-l Type "A" Test Program to comply with the requirements of Appendix J.
Specifi/cally, it is requested that Decay heat Injection valves, DH-V4A and B be exempted from the Type "C" Test requircaents of Section III.A.l(d).
These valves are required to automatically open under accident conditions for icw pressure inj ection and flow is required to be established through both low pressure injection lines. Therefore, local leak tests of these valves is unnecessary.
In summary, Met-Ed has concluded that the planned TMI-1 Containcent Leak Rate Testing Program complies with the requirements of Appendix J, subject to the exceptions approved during TMI-l Start-up and Test Progran and the additional exception requested above.
In addition, a change to TMI-l Technical Specifications will be submitted by October 30, 1975 to incorporate the additional Type "C" T aak Test requirements to be perfor ed, incorporate the fluid block and Penetra-designate the value of L tion Pressurization Acceptance Criterion 3 clerical errors, and request',
clarify pretest inspection, correct an exemption related to the reactor building access and emergency air locks pursuant to 10CFR50.12, to allow door seal testing at manufacturers reco== ended test pressure (10 psig) rather than at accident test pressure
,Pa).
The door operating mechanisms are being damaged by tight adj ust=cnts
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required to pass leak tests at the higher test pressure.
Further, with regard to the reactor building door seals exc=ption request, it should be noted that:
(a) at present, the reactor building door seal tests are in accordance with the requirements of TMI-1 Technical Specifications 4.4.1.2.5b which we believe also meets the practical interpretation of Appendix J Section D.2., and (b) the referenced 10CFR50.12 exc=ption would serve to alter testing frequency as presently required by Technical Specification 4.4.1.2.55 and the Appendix J required test pressure of Pa as noted above.
Sincerely,,
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?f-R. C., Arnold Vice President RCA:CWS:pa
Enclosure:
TMI-l Containment Isolation Valves 1446 0/7 File 20.1.1/7.7.3.1.1 J
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Not Subject To Type C Test Requirements VALVE OPERATOR E.'S.
I.CTUATED l
F ITION
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f High Pressure Injection p and MU-V16A,B,C,D Motor Yes open Hich Pressure Injectiott.,
cation MU-V10TA,B,C,D (check valve)
NA open r Service NS-Vll (check valve)
NA closed nuclear Service Supply Isolation Cooling RB Fan Motor Cooling NS-V52 A,B,C Manual NA open RB Fan Motor Cooling US-V53 A,B,C Manual NA open ediate IC-V16 (check valve)
NA closed I.C. Supply Isolation' IC-V18 (check valve)
NA closed I.C. Supply Isolation g;
g Heat DH-V2 motor No closed Decay Heat Removal Letdown DH-V3 motor No closed Decay Heat Removal Letdown Low Pressure Injection DH-Vh A/B motor Yes open Lov Pressure Injection DH-V22 A/B (check valve)
NA open DH-V6 A/B motor No closed Reactor Building Sump al Addition CA-Vl92 (check valve)
NA closed Reclaimed Water Isolation ng Spray BS-VIA/B motor Yes open Spray Injection BS-V30A/B (check valve)
NA open Spray Injection en Supply NI-V26 Manual NA locked 650 Psig Hitrogen Supply closed HI-V27 Manual NA locked 650 Paig Nitrocen Supply closed g
Fuel Cooling SF-V22 Manual NA locked Fuel Transfer Canal to SpcTit closed Fuel Cooling /BWST, EB Emergency Cooling Supply RR-V3A/B/C motor Yes open mergency RR-VhA/B/C/D motor Yes open water 4
Instrument isolation ing Spray ^CN BS-V37A/B/C/D Manual No open C.D N
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a bec:
Mr.,G. A. Olson, Secretary J. J. Calitz Pritae Movers Committee T. M. Crimmins Edison Electric Institute D. N. Grace
- 90. Park Avenue J. F. Fritzen New York, NY 10016 R. H. Hawk J. G. Herbein R. A. Govers R. W. Heward Babcock & Wilcox R. M. Klingaman,(2)
Power Generation Group L. L. Lawyer P.O. Box 1260 J. F. Peters Lynchburg, VA 24505 C. W. Synth H.'B. Shipman (W. I. #225-10)
J. R. Thorpe-Chairman, GORB, DfI-l Al & SR # 75-525)
J. P. O'Hanlon-Chaircan, PORC, n11-1 B. M. McCutcheon*
1446 075
.