ML19322C085
| ML19322C085 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 03/17/1977 |
| From: | Eisenhut D Office of Nuclear Reactor Regulation |
| To: | Goller K Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7912300073 | |
| Download: ML19322C085 (7) | |
Text
---
+wf' F.
y ivk-M Nt.t 7 G TT, 1
h IsiORA!iDUM FOR:
K. R. Goller, Assistant Director for Operating Reactors, Division of Operating Reactors FROM:
D. G. Eisenhut Assistant Director for Operational Technology, Division of Operating Reactors
SUBJECT:
REPORT ON TAC NO. 6443:
IMPLEMENTATIO!! 0F APPENDIX J FOR Ti!E OCONEE NUCLEAR STATI0il, UNITS 1, 2, AND 3 Plant Name: Oconee Nuclear Station, Units 1, 2, and 3 Docket Numbers: 50-269/270/287 Responsible Branch: ORB #1 Project Manager:
J. Neighbors Reviewing Branch: Plant Systems Branch Requested Completion Date:
February 28, 1977 i
Review Status: Awaiting Information In
- response to your Technical Assistance Request, TAC No. 6443, the Plant Systems.BranchXas r@icWed' the. applicable sections of the Oconee Station's FSAR"a'n~d7cWtain%th~er' documents. filed by.. tile licEnie%[~~~ ~ '
~
regarding~ proposed exemptions from the requirements'of Appendix J~to-10 CRR 50.
The enclosed evaluation was developed from an application of our generic positions for the implementation of Appendix J to operating plants. Our i
deteminations relative to acceptability of the proposed exemptions and modifications have been identified within the text of this evaluation.
l D. G. Eisenhut, Assistant Director for Operational Technology Division of Operating Reactors
Enclosure:
As stated 4
I
Contact:
D. Shum 492-8077 cc: See Page 2 i
- 1~ sl L _.
- M*#8*
'bh 4'_
f MO ni s
mWeg's gy
-,-M M
y g
g
.79k2300 p g
/#
K. R. Goller i
cc w/ enclosure:
!}
V. Stello W. Butler B. Buckley i
A. Schwencer D. Shum J. 14eighbor C. Grimes K. Seyfrit j
R. Shewmaker G. Lainas i
i J. Shapaker 1
DISTRIBUTION Central Files PSB Files
,,,,.m m ead thi:; r;gulition, Jjete forc., beginn'ing. in Aught bb 'rehes ts..
DS blish the de9PCe Jof ccW1i:r.CG 'il th the requircicents. of anne.,: s fY""*, lC}i
$. 9 the'initiql re.x,w Olify 0 l
'?
.,?
'*C))
f i
I i
i i
l DOR /PSB. ; D. O.RLS /PSB DOR /C/PSB_QDOR /ADL.
03/g/77")/ Ali,pnA.1_
WButler s
DShum:pa BBuc eV
...n...,
03/p /77
/
03//Y/77 A31/f]77
"* ~
W u. s. novsnn.sur paintino orrects ist..mae-see I
Perun ABC.)l3 (Rev. p.33) ABCM 0?.40 t
Enclosure EVALUATION OF THE CONTAINMENT LEAK TESTING PROGRAM FOR THE OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3
1.0 INTRODUCTION
By our letter, dated August 4,1975, the Duke Power Company (DPC) was requested to review the Occnee Nuclear Station, Units 1, 2, and 3 with regard to the current containment leak testing program, and the associated Technical Specifications, for compliance with the require-ments of Appendix J to 10 CFR Part 50.
As part of this request, DPC was to describe the planned actions and the associated schedule for attaining conformance with the above cited regulation.
Appendix J to 10 CFR 50 was published on February 14, 1973.
Since nany operating nuclear plants had either received an operating license or were in advanced stages of design or construction at that time, some plants may not now be in full compliance with the requirements of this regulation.
Therefore, beginning in ' August 1975, requests to establish the degree <of compliance.with the. requirements aof Appendix.
J were made of each licensee.
Following the' initial response to these requests, NRC staff developed positions which would provide assurance that the objectives of the testing program were satisfied.
These staff positions have since been applied in our review of reports filed by the Oconee Station's licensee and the results are reflected in the following evaluation.
The Duke Power Company (DPC) submitted its response on December 6, 1976.
In this submittal, DPC requested that some of the isolation valves (shown in FSAR Table 5-4, Reactor Building Isolation Valve Information),
which cannot be tested or which can only be tested in the reverse direction, be exempted from the requirements of 10 CFR 50, Appendix J.
Our evaluation of the DPC submittal is presented below.
2.0 EVALUATION, 2.1 Penetrations for Systems that are not Engineered Safety' Features DPC proposed that the containment isolation valves associated with fifteen penetrations, as presented in Table 4.4.1 of the proposed Technical Specifications, entitled Local Leak Rate Tests, not be leak tested for containment leakage.
l 5-i
e In regard to the above, we do not concur with the licensee's view that the valves in the penetrations, Nos. 4, 43, 47, 53, 59, 55, and 51 should not be leak tested.
These containment isolation valves may be required -
to prevent unacceptable radiological release following a postulated loss-of-coolant accident.
Therefore, the proposed change to delete the requirement for leakage rate testing of these valves, as required by paragraph II.H of Appendix J to 10 CFR 50, has not been supported by the licensee.
In accordance with our letter of August 4,1975, we request that for each of the above lines, DPC identify those valves which require Type C testing in accordance with Section II.H considering potential single active failures and without reliance on non-safety grade system boundaries.
Further, for each area where non-compliance exists, describe the planned actions ar.f the associated schedule for achieving compliance with the requirements of.\\ppendix J.
2.2 Penetrations for Engineered Safety Feature Systems DPC proposed that the containment isolation valves associated with twenty-three of the penetrations as presented in Table 5-4 of the FSAR entitled Reactor Building Isolation Valve Information, not be required to be leak tested for containment leakage.
These twenty-three penetrations are:
(a) Penetration No. 8, loop nozzle warning lines; u,-
r.rt, e v;-
(b) Penetration No. 9, normal make-up to RC system; (c) Penetration No.10, RCP seal injection lines; (d) Penetration Nos.13 and 14 RB spray inlet lines; (e) Penetrations Nos. 15 and 16, LPI and decay heat removal lines; (f) Penetration No.17, emergency feedwater inlet line; l
(g) Penetration No. 23, RCP seal injection line; (h) Penetrations Nos. 25, 26, 27, and 28, feedwater and steam lines; (i) Penetration Nos. 30, 31, 32, 33, 34, and 35, RB emergency cooler outlet and inlet lines; (j) Penetration Nos. 36 and 37, RB sump recirculation lines; l
(k) Penetration No. 50, emergency feedwater inlet line; and (1) Penetration No. 52, emergency reactor injection line.
f p_{
We do not concur with the licensee's view that the valves in the above listed penetrations will not be required to perform a containment isolation function.
While it is correct that the containment isolation function of these lines may not be required when the systems are intact and operating, these containment isolation i/alves may be required to prevent unacceptable radiological releases when the systems are not operating. Therefore, we find that the proposed change to delete the leakage rate testing requirement for these valves,as required by paragraph II.H of Appendix J to 10 CFR 50, has not been supported by the licensee.
In accordance with our August 4,1975 letter, we request, that for each of the above cited lines, DPC identify those valves which require Type C testing in accordance with Section II.H, considering potential single active failures and without reliance on non-safety grade system boundaries.
- Further, for och area where non-compliance exists, describe the planned actions and the associated schedule for achieving compliance with Appendix J.
Penetrations to be Tested in a Direction Opposite to its Safety Function 2.3 Direction DPC proposed that the inboard containment isolation valves associated with five pen.etrations be permitted to be tested in c direction opposite to its safety function direction. These five penetrations are:
(a) Penetration No. 5, RB normal sump drain line; (b) Penetration No. 7, RC pump seal outlet line; (c) Penetration No.18, quench tank vent line; (d) Penetration No. 29, quench tank drain line; and (e) Penetration No. 54, component cooling water outlet line.
In regard to the above listed penetrations, we find that the proposed exemptions from the requirements of the regulations are not necessary, since Appendix J allows reverse direction testing of these cla':sas of valves. However, the licensee will be required to demonstrate that the results of testing in the opposite direction for each of the above penetrations will be equivalent to or more conservative than if the tests were made with the pressure applied in the Further, we will require that the li.ensee document correct direction.
these determinations and their bases and that he arranges to have this document available at the plant site.
2.4 Airlocks With regard to the periodic retest schedule of Type B tests for airlocks, the licensee, in its letter, dated February 17, 1977, described the difficulties that would be encountered in meeting certain specific aspects of j
f i
.a.
.~
the requirements and concluded that the Oconee airlocks could not be tested without modifications (i.a., installing test clamps to physically restrain the it.ner door from lifting off its seats during testing).
Therefore, the licensee i
requested that the exemptions from the requirements of 10 CFR 50, Appendix J j
i as identified in its letter of September 5,1975 be granted.
We have reviewed the licensee's rationale for requesting the exemptions.
We conclude that the exemptions requested by the licensee, regarding the testing of airlocks, should not be granted. We require that ti.- licensee perform the Type B tests to airlocks in accordance with Appendix J.
The guidelines delineated in our Novembe-23, 1976 letter to the licensee, as they re c'9 to airlock testing, remain applicable and may be used by the licensee in developing an acceptable airlock testing program.
i 4
l
-