ML20006E618

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Proposed Tech Specs Requesting Exemption from 10CFR App J for one-time Request for Relief from Requirements That Three Containment Integrated Leak Rate Tests Required During 10-yr Inservice Insp Must Be Performed During Same Outage
ML20006E618
Person / Time
Site: McGuire Duke Energy icon.png
Issue date: 02/20/1990
From:
DUKE POWER CO.
To:
Shared Package
ML20006E617 List:
References
NUDOCS 9002260136
Download: ML20006E618 (9)
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CilANGES TO TEC11NICAL SPECIFICATIONS W

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No CONTAINMENT SYSTEMS Cho/nhe5 l b CONTAINMENT LEAKAGE D

LIMITING CONDITION FOR OPERATION I l

3.6.1.2 Containment leakage rates shall be limited to:

a. An overall integrated leakage rate of:
1) Less than or equal to L , 0.30% by weight of the containment air per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at P,,,14.8 psig, or ]
2) Less than or equal to L , 0.14% by weight of the containment

.airpee24hoursatarhducedpressureofP'74 t PSI'9

b. A combined leakage rate of less than 0.60 L for all penetrations  !

andvalvessubjecttoTypeBandCtests,w$enpressurizedtoP,,

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c. for i Acombinedbypassleakagerateoflessthan0.07L}

penetrations identified as secondary containment b pass'all leakage l paths when pressurized to P,. >

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTION:

With (a) the measured overall integrated containnient leaksge rate exceeding 0,75 L or 0.75 L., as appli::able, or (b) the measured combined leakage  !

rate f8r all conct:ations and valumA subject to Types 3 and C tests exceeding

  • 0.60 L.,, or (c') the waoined bypass leckage rate exceeding 0.07 L te.itort the overall integrated li.skage rate to less than 0.75 L 8rlessthan -

er equal to 0.75 t , as applicab!e, and the combined leakage rate for all '

pentrations and vkives subject to Type B and C tests to less than 0.50 L,, i and the combined bypas: leakage rate to less than 0.07 L prior to .

increasing the Nactor Coolant System temperature above f00 F.  !

SUWEILLANCE REQUIREMENTS ___

4.6.1.2 The containment leakage rates shall be demonstrated at the following test schedule and shall be determined in conformance with the criteria speci-fied in Appendix J of 10 CFR 50 using the methods and provisions of ANSI N45.4-1972 or the mass plot method:

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, McGUIRE - UNITS 1 and 2 3/4 6-2 Amendment No.94 (Unit 1)

Amendment No.76 (Unit 2)

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$URVEILLANCE REQUIREMENTS (Continued) h

4. J Three Type A tests (0vera11 Integrated Containment Leakage Rate)

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eitt4*be conducted shall 14.8 psig, at 40 a 10 month intervals during shutdown at or at P , 7.4 psig, during each 10 year i service P i during the 5 Thethirdteltofeachsetshallbeconducted -)

ownforthe10yearplantinserviceinspection;M j b.

If any periodic Type A test fails to meet either 0.75 L or 0.75 L the test schedule for. subsequent Type A tests shall be feviewed anb, i approved by the Commission. l If two consecutive Type A tests fail to

" meet either 0.75 L or 0.75 L a Type A test shall be performed at i j

leastLevery 18 months until tIo, consecutive Type A tests meet either 0.75

. resume 0;or 0.75g Lat which time the above test schedule may be  ;

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The accuracy of each Type A test shall be verified by a supplemental test which:  !

1) }

Confirms the accuracy of the Type A test by verifying that the difference between supplemental and Type A test data is within )

0.25 L,, or 0.25 Lg ; l

2) Has a duration sufficient to establish accurately the change in

, leakage and rate between the Type A test and the supplemental test; i E

3) Requires the quantity of gas injected into the containment or i bled from the containment during the supplemental test to be 14.8 psig, orgP . 7.4 psig, equivalent to at least 25% of the tot d.

j Type 8 and C tests shell ne en W etej with gas rt P , 14.8 esig M i intervals no gnater than .74 months except fer testl foveltierp

1) Air locks, '

'2) Dusi-ply bellows essemblies on cortainment penetrations between the containment building and the annulus, and

, 3) Purge rmpply and exhaust is4lation valtas with resilient esterial seals. J

4) Type C tests perforced on containment penetrations M72, H373 without draining the glycob water mixture frca the Wats of 3  !

i their diaphragm valves (NF 228A, NF-2338, and NF-234A), if meet-ing a zero indicated leakage rate (not including instrument ,

error) for the diaphragm valves. These tests may be used in lieu of tests which are otherwise required by Section III.C.2(a) of 10 CFR 50, Appendix J to use air or nitrogen as the test p medium. The above required test pressure (Pa) and test interval are not changed by this exception.

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Purge supply and exhaust isolation valves with resilient material "

a of Specification 4.6.1.9.3 or 4.6.1.9.4, as applicabl McGUIRE - UNITS 1 and 2 Amendment No. (Unit 1) 3/4 6-3 Amendment No. (Unit 2)

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' * -The Type A test on Unit.I which is scheduled for the 10 year ISI outage.

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, -(ROQ 7. 1991) will'be performed instead.during the EOC 6 outage (1990).-
The 40 +,10 month interval will be maintained. This constitutes an '

exemption to 10 CFR50, Appendix J. Paragraph III.D.I.(a).

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CONTAINMENT SYSTEMS w s p y e.

.SURVE!LLANCE REQUIREMENTS (Continued)

f. The combined bypass leakage rate shall be determined to be less than 0.07 L by applicable Type B and C tests at least once per 24 months except,for penetrations which are not individually testable; penetra-tions not individually testable shall be determined to have no detect-able leakage when tested with soap bubbles while the containment is  ;

pressurized to P,, 14.8 psig, or Pg, 7.4 psig, during each Type A test;

g. Air locks shall be tested and demonstrated OPERABLE per Specification 4.6.1.3; .

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h. The space between each dual ply bellows assembly on containment i penetrations between the containment building and the annulus shall be vented to the annulus during Type A tests. Following completion i

of each Type A test, the space between each dual-ply bellows ,

assembly shall be subjected to a low pressure test at 3-5 psig to ,

verify no detectable leakage or the dual ply bellows assembly shall be subjected to a leak test with the pressure on the containment ,

side of the dual ply bellows assembly at P , 14.8 psig, or P .

  • 7.4;psig,toverifytheleskagetobewit$1nthelimitsof g i Specification 4.6.1.2f. ;

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i. All test leakage rates shall be calculated using observed data i converted to absolute values. Error analyses shall be performed to
  • select a balanced Integrated Leakage Measurement System; and -
j. The ptotisions of Specification 4.0.2 are not applicable

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1 Amendment No. 53 (Unit 1)

McGUIRE - UNITS I and 2 3/4 6-4 Amendment No. 34 (Unit 2)

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l ATTACl& LENT. II JUSTIFICATION AND SAFETY ANALYSIS s

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-Discussion / Justification of Proposed Changes The proposed' change to Specification 3/4.6.1.2 is to provide a >

f one time exemption to the Technical Specifications (and 10CFR50, '

Appendix J) to facilitate scheduling of containment Type A leakage tests. The current schedule is based on the 40 + 10 month requirement of the Technical Specification including the '

preoperational test.

By this current schedule, the third Type A test for McGuire Unit ,

! I will come during the end of cycle 6 (EOC 6) outage in 1990.

The dates of the previous tests are: ,

f Preoperational August, 1979 ,

Test 1 April, 1983 t Test 2 August, 1986 The first operational test was scheduled based upon the '

preoperational test, not the commercial operation date, which

, resulted in an early test. This was done with NRC concurrence at the time.

In order to meet the 40 1 10 month requirement, the third test is scheduled for the EOC 6 outage. This, however, does not meet the Tech Spec (and Appendix J) requirements which requires the third ILRT to be performed during the ten year ISI outage which would be EOC 7. 4 Performing a Type A Test during EOC 5 and again during EOC 7 is considered unnecessary and would likewise not be in conformance >

with Specification 3/4.6.1.2 in that four tests would have been performed during the ten year interval.

McGuire Nuclear station is therefore requesting a one time .

exemption to the Technical Specificatian and Appendix J-requirements to test during the specified (10 year ISI) outage.

The test interval of 40 + 3 0 months will be matutained.to ensure containment integrity, and future scheduling will ensure the situation is resolved by the second " Ten year ISI" outage. The -

tentative schedule to accomplish this is -

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2 Test . Months Set Test Outage Date Since Previous 0- 1 Pre-Op 8/79 N/A .

Commercial Operation 12/81 (28) 1 2 EOC 1

  • 4/83 44 1 3 EOC 3 8/86 41 1 4 EOC 6 (5/90) 45 i 2 5 EOC 9 (5/94) 48 ,

2 6 EOC 12 (5/98) 48 2 7 EOC 14 ** (1/2001) 32

    • (Second) Ten year'ISI outage Therefore, a one time. exemption to Technical Specifications and to Appendix J is requested in accordance with 10CFR50.90 and 10CFR50.12.

Analysis of Significant Hazards Considerations Pursuant to 10CFR50.91, this analysis provides assurance that the proposed amendments do not involve any significant hazards considerations as defined by 10CFR50.92.

(1) The proposed amendments would not involve a significant increase in the probability.or consequences of an accident previously evaluated.

The containment serves to mitigate the consequences of an accident and serves no role in accident initiation. The consequer.ces of an accident would be unchanged as '

containment integrity is maintained and verified by periodic

-testing within the pecified interval (40 1 10 months). The proposed change would allow McGuire to stay on the proper

' interval by exenpting a specific outage requirement from the

.TechnicAi specifications and 10?PR50, Appendix J. t (2) Mhe proposed change would not create the pessibility of a new or different kind of accident from any accident previously evaluated.

I The: proposed change would affect only the interval, on a one time basis, of a test that is presently performed. The test method is unchanged and the proposed changes would not cause any hardware changes, therefore the change could not create any new accident scenarios. ,

(3) The' proposed change would not involve a significant ,

reduction in a margin of safety.

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3 Containment integrity will continue to be assured by periodic testing. The allowed containment leakage rates would remain unchanged and the test interval is maintained, thus no reduction in a margin of safety can occur.

Based upon the preceding analysis, Duke Power concludes that the proposed amendments to the McGuire Nuclear Station Technical Specifications do not involve any significant hazards considerations as defined by 10CFR50.92.

Exemption to 10CFR50, Appendix J, Section III.D.1.(a) 10CFR50.12 allows the Commission to grant exemptions from the regulations of 10CFR50 if certain criteria are satisfied. In this case, the criteria are met:

10CFR50.12(a)(1) Authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security.

As previously discussed, the specified test interval in the McGuire Technical Specifications is satisfied, assuring that '

containment integrity is maintained. With containment integrity '

maintained, the public health and safety are not endangered by the proposed exemption.

s 10CFR50.12(a)(2)(1) Application of the regulation in the particular circumstances conflicts with other rules or requirements of the commission.

1 Application of the rule would require violation of the McGuire Nuclear Station Tschnical Specifications. The Tech Specs require testing on a 40 3 10 month interval. The latest scheduled outage within this interval is EOC 6, a year short of the 10 year ISI outage. To perform the third test on the 10 year outage (as 1 required by the regulation and the specification) would fell outside the tolerance of the interval. Similarly, testkng at both outaggs would shorten the intervsl and cause the fourth test to fall cr. the ten year outage. The requirements are in conflict.

The schedule for conducting ILRTs is based upon the pre-operational test as opposed to commercial operation. This was done with NRC concurrence. As shown in the tentative schedule this is a one-time exemption, and McGuire can be on  ;

track for the second ten year ISI outage.

l Therefore, as the proposed exemption does not present any risk to I the public health and safety, would resolve conflicting l requirements, and is only needed on a one time basis, the proposed exemption is justified under 10CFR50.12, 1

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