ML19331C980
| ML19331C980 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 08/04/1980 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| TASK-06-06, TASK-6-6, TASK-RR NUDOCS 8008270003 | |
| Download: ML19331C980 (7) | |
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$'t UNITED STATES p.
NUCLEAR REGULATORY COMMISSION j
, j WASHINGTON, D. C. 20555 e
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August 4, 1980 Docket No. 50-155 4
1 Mr. David P. Hoffman Nuclear Licensing Administrator Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201
Dear Mr. Hoffman:
We are continuing our review of your submittals regarding Appendix J to 10 CFP. 50, Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors.
Based on our review and that of our consultant, we have found that the additional information identified in the enclosure is needed to continue our review.
To maintain our review schedule, please provide your response within 30 days of receipt of this letter.
tz W k -
u$yw p Dennis M. Crutchfield, Chief i
Operating Reactors Branch #5 Division of Licensing
Enclosure:
Request for Additional Information cc w/ enclosure:
See next page 8008270 003
. August 4, 1980 Mr. David P. Hoffman cc w/ enclosure:
Mr. Paul A. Perry, Secretary U. S. Environmental Protection Consumers Power Ccmpany Agency 212 West Michigan Avenue Federal Activities Branch Jackson, Michigan 49201 Region V Office ATTN: EIS C0ORDINATOR Judd L. Bacon, Esquire 230 South Dearborn Street Consumers Power Conpany Chicago, Illinois 60604 212 West Michigan Avenue r
Jackson, Michigan 49201 Herbert Grossman, Esq., Chairman Atomic Safety and Licensing Board Joseph Gallo, Esquire U. S. Nuclear Regulatory Commission Isham, Lincoln & Beale Washington, D. C.
20555 1120 Connecticut Avenue Room 325 Dr. Oscar H. Paris Washington, D. C.
20036 Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Peter W. Steketee, Esquire Washington, D. C.
20555 505 Peoples Building Grand Rapids, Michigan 49503 Mr. Frederick J. Shon Atomic Safety and Licensing Board Sheldon, Harmon and Weiss V. S. Nuclear Regulatory Commission 1725 I Street, N. W.
Washington, D. C.
20555 Suite 506 Washington, D. C.
20006 Big Rock Point Nuclear Power Plant ATTN: Mr. C. J. Hartnen Mr. John O'Neill, II Plant Superintendent Route 2, Box 44 Charlevoix, Michigan 49720 Maple City, Michigan 49664 Christa-Maria Charlevoix Public Library Route 2, Box 108C 107 Clinton Street Charlevoix, Michigan 49720 Charlevoix, Michigan William J. Scanlon, Esquire Chai rman 2034 Pauline Boulevard County Board of Supervisors Ann Arbor, Michigan 48103 Charlevoix County Charlevoix, Michigan 49720 Office of the Governor (2)
Room 1 - Capitol Building Lansing, Michigan 48913 Director, Technical Assessment Division Office of Radiation Programs (AW-459)
U. S. Environmental Protection Agency Crystal Mall #2 Arlington, Virginia 20460
REQUEST FOR ADDITIONAL INFORMATION IMPLEMENTATION OF'10CFR50, APPENDIX J, CONTAINMENT LEAKAGE TESTING BIG ROCK POINT
1.0 BACKGROUND
In a letter dated September 15, 1975 Consumers Power Company (CPC) requested certain exemptions from the requirements of 10CFR50, Appendix J.
In a subsequent letter dated Fqbruary 13, 1976, CPC requested additional exemptions and also proposed revisions to the technical specifications for e
Big Rock Point regarding containment leakage testing.
2.0 INFORMATION REQUESTED 2.1 AIRLOCK TEST PRESSURE AND FREQUENCY Exemption Requests C and E of CPC's letter of September 15, 1975, refer to exemptions from the requirements of Appendix J relative to Type B testing of containment airlocks.
CPC's request to conduct airlock tests at a pressure of slightly less than 5 psig and at a frequency of once every six months, regardless of openings in the interim, is unacceptable.
In order for an exemption' co be found acceptable, the following requirements must be satisfied:
1.
A test of the entire airlock assembly once every six months at peak calculated accident pressure (Pa).
2.
A reduced-pressure test within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of every first of a series of openings during the interim between the six-month tests.
l In recognition of the difficulty some operating plants have in meeting the requirements of Appendix J regarding the testing of airlocks, the NRC staff L
has developed positions which enable the licensees to consider alternatives that satisfy the objectives of the airlock-testing requirements.
The staff positions on the implementation of airlock-testing requirements are appended to this request for information (see Appendix A).
Submit an airlock-testing program which meets the minimum requirements described in the section above as amplified in Appendix A.
2.2 CLOSED SYSTEMS INSIDE CONTAINMENT CPC's letter of February 13, 1976 requested exemption from Type C testing for valves associated with systems or lines which
. are closed systems inside containment and not liable to Enclosure
rupture during a LOCA and, therefore, manual or check valves were either not provided during initial plant construction or if manual valves were provided at the containment boundary, they are normally left open.
CPC's conclusion is that it is'not the intention of the requirements of Appendix J that these penetrations be tested. These penetrations include:
1.
Reference Volume Sensing Line 2.
Instrument Air Line 3.
Service Air Line 4.
Service Water Line 5.
Reactor Building Heating Steam System Air Operating Lines to CV-4040 a'nd CV-4114 (Reactor Coolant 6.
Blowdown Valves) and CV-4029 (RCW Inlet to Shutdown Cooling Heat Exchangers).
Shutdown Flushing Line (subsequent correspondence indicates that 7
this line has been capped since the 2-13-76 submittal).
Generally, in order to meet the intent of Appendix J, closed systems inside containment must be designed to engineered-safety-feature (ESF) system criteria (seismically designed, protected against internal missilos, safety class, etc.).
For systems not designed to ESF system criteria, provide a basis for the statement that the systems are not liable to rupture during LOCA.
2.3 CORE SPRAY RECIRCULATION SYSTEM VALVES l
CPC's letter of February 13, 1976, requested exemption from Type C testing for valves in the core spray recirculation lines (3 penetrations) and in two additional penetrations associated with the core spray system and CPC's basis for this position is that the the back-up core spray system.
systems are in use for long-term cooling following a postulated accident at a the lines are not pressure f ar in excess of containment pressure and that In order to justif y your position, provide provided with automatic isolation valves.
the systems will remain operating during the post-accident
(
an evaluation that period considering the possibility of a single active failure since such isolation function.
If such failure may cause a valve to perform a containment an evaluation cannot be provided, submit a plan of action to conform with the requirements of Appendix J including a schedule for accomplishing the plan.
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s 2.4 WATER SUPPLY LINE TO THE CONTROL ROD DRIVE PUMPS AND FEEDWATER CHECK VALVES CPC's letter of February 13, 19'76 requested hydraulic testing, in lieu of pneumatic testing, for the isolation valves in the water supply to the control rod drive pumps because the line is configured such that it cannot be completely drained of water.
CPC also stated that it appears likely that following a LOCA, suf ficient water will remain in this line to form an effective hydraulic seal.
CPC's letter of February 13, 1976 also requested hydraulic testing of the feedwater check valves because $hese valves cannot be tested pneumatically.
Hydraulic testing of the above valves is acceptable provided the testing is used to verify that the leakage rate is such that there is sufficient water inventory to provide an effective water seal during and following a postulated LOCA.
Provide the following information which is needed to complete our evaluation of these requests.
1 Total water inventory available to each valve.
2.
The water-leakage-rate limits or pressure-decay-rate limits allowed during the hydraulic tests.
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APPENDIX A CONTAINMENT AIRLOCKS Appendix J to 10CFR50 requires that reactor containment airlocks be leak-tested at the peak calculated accident pressure (Pa) at six-month intervals.
Further, should the airlocks be opened during such intervals, the airlocks will be leak-tested after each opening. Appendix J calls out these specific require-ments for airlocks because they present potentially large leakage paths which cre subject to human error to a larger degree than other potential leakage paths.
The staff's interpretation of the objectives of the airlock-leak-testing requirements are:
1.
That the six-month test will provide an integrated leakage rate for the entire airlock assembly including electrical and mechani-cal penetrations, the airlocks cylinder, hinge assemblies, velded connections, and other potential leakage paths.
2.
That the "after-each-opening" test would provide a means of ensur-ing that the door seals had not been damaged or seated improperly
- during airlock use.
For those operating facilities that were designed and constructed prior to the issuance of Appendix J, consideration has been given to the alternatives to the specific testing requirements which will meet the provisions of Appendix J.
Listed below are a number of guidelines which may be useful when considering or revising current airlock-leak-testing programs.
1 At six-month intervals the entire airlock assembly shall be leak-tested at the peak pressure, Pa.
If the test pressure will lift the inner airlock door off its seat, a strongback or other mechani-cal device should be used so that meaningful test results can be obtained at Pa.
2.
Should the airlock be opened during the interval between the six-month tests, the airlock door seals shall be tested within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of every first of a series of openings. This relaxation in the "after-each-opening" test requirement of Appendix J recognizes these that a significant amount of time is required to conduct intermediate tests in relation to the frequency of use of the air-lock.
These tests would be conducted whenever containment integ-rity is required.
3 For those plants which require the use of a strongback or clamps to leak-test the door seals at a pressure, Pa, a lower pressure (e.g., manufacturer's recommended pressure, which would not require the use of such clamping devices) should be used to con-duct the intermediate tests. The results of leakage tests at the i
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reduced pressure must be conservatively extrapolated to the leakage at the accident pressure, Pa, to determine accept-(The extrapolation to be utilized must be submitted ability.
to the NRC.)
In lieu of the intermediate tests, an acceptable alternative would be the use of a continuous monitoring system to achieve the objective of the "af ter-As in the case of the reduced-pressure inter-each-opening" test requirement.
it must be demonstrated that the continuous monitoring system is mediate test, sufficiently sensitive to detect unacceptable leakage rates and that the accept-able leakage-rate limitsivill be based upon a conservative extrapolation to the limiting leakage rate experienced under accident conditions (e.g., at a pressure of Pa).
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