ML20028B400

From kanterella
Jump to navigation Jump to search
Safety Evaluation Supporting Licensee Request for Exemption from 10CFR50.54(o) & App J
ML20028B400
Person / Time
Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 11/23/1982
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20027A774 List:
References
NUDOCS 8211300352
Download: ML20028B400 (4)


Text

_. __ __

/y youm'o UNITED STATES c

b'~:q?'.(

NUCLEAR REGULATORYCOMMISSION

! 9.

9( l WASHINGTON, D. C. 2G555 t S $a.) f,,

p SAFETYEVALUATIONBYTHEOFFICEOFNUCLEARREACTORREGULATION CONSUMERS POWER COMPANY t

BIG ROCK POINT PLANT DOCKET NO. 50-155 f

1.0 INTRO 0,UCTION 1

On August 5,1975(1), the NRC requested the Consumers Power Company l

(CPC) to review its containment testing program for the Big Rock Point Plant (Big Rock Point), and the asser.iated Tschnical Specifications, for compliance with the requirements of Appendix J to 10 CFR Part 50.

1 Appendix J to 10 CFR Part 50 was published on February 14, 1973.

Since by this date there were already many operating nuclear plants 4

and = d.iber more in advance stages of design or construction, the NRC decided to have these plants re-evaluated against the requirements of this new regulation.

Therefore, beginning in August 1975, requests for' review of the extent of compliance with the requirements of Appendix JTGre made of each licensee.

Following the initial responses to these requests, NRC staff positions were developed which would assure that the objectives of the testing requirements.of the above cited regulation were satisfied.

These staff positions have since been applied in the staff review of the submittals filed by the' licensee for Big Rock Point.

The results of the staff evaluatier, are provided below.

~

/

i' 2.0 EVALUATION

~

TheFranklinResearchCenter(fRC),theNRCstaffconsultant,hasreviewed the licensee's submitta's (2, 3, 4, 5) and prepared an evaluation of containment leakage tes'.s for Big Rock Point (Enclosure 3)*.

The staff has reviewed this evaluation and concurs in its bases and findings.

l However, as noted below, the staff conclusion concerning testing of capped, spare pipe penetrations (see section 3.8 below) differs slightly from those of the FRC.

The FRC concludes that exemptions from local testing requirements should be granted for these penetrations.

This con-clusion implicitly assumes that the spare pipe penetration caps are welded on; if this is so, the staff concludes that local testing is not i

required by Appendix J and no exemption is required. However, if some of the caps are merely threaded, local testing is required for those threaded 1

caps.

The staff has discussed this matter with the FRC and they concur with that finding.

1 1

  • E9 closure 3 to the transmittal letter for this action.

8211300352 eh123

~

PDR A00CK 05000135 P

PDR

- ~__.__.-_ _ _ _,_

3.0 CONCLUSION

Based on the review of the enclosed technical evaluation report (TER)*

regarding the Appendix J review for Big Rock Point, the staff concludes that:

3.1 Testing of isolation valves in the reactor cleanup system by local leakage rate testing procedures and back-correctjng the results of the containment integrated leakage rate test to ac-count for these valves is in accordance with Section III.A.1(a) of Appendix J.

No exemption is necessary.

a 3.2 CPC's proposal to test containment airlocks every six months and f

not within three days of opening does not satisfy the requirements of, Appendix J.

A satisfactory airlock testing program, which considers the unique features of the Big Rock Point plant, has been suggested in Section 3.2.1.

The issue of more frequent testing, beyond once every six months, has been placed oq the list of open items to be resolved as part of the Integrated Assessment under the Systematic Evaluation Program (SEP).

3.3 CPC's proposed exemption to test electrical penetrations in conjunction 6" with Type A tests should be granted based upon the favorable operating experience with these penetrations.

3.4 CPC's proposed exemption to test penetrations with expansion bellows in conjunction with Type A tests should be granted based upon the favorable operating experience with these penetrations.

3.5 CPC's proposed exemption to test the main steam isolation valve and the main steam line drain isolation valve with water and determine acceptability based upon drops per second does'not satisfy the requirements of Appendix J.

The issue of Type C testing of these i

valves has been deferred to the SEP, pending resolution of the issue of adequate containment isolation provisions on the main steam and l

I main steam drain lines.

3.6 An assessment of the leak testing provisions for six penetrations which are claimed to have closed systems inside containment has been deferred pending the completion of the containment isolation system review being conducted on the Big Rock Point plant under the SEP.

If changes in the isolation provisions are required at that time, the staff will establish leak testing requirements for the penetrations l

in conjunction with the Integrated Assessment of the plant.

i l

w__

--y

3.7 Type C testing of the penetrations for the core spray recirculation system is not required by Appendix J.

No exemption 1s, required.,

3.8 Tyae B or C testing is not required by Appendix J for spare pipe

.netrations which are closed by fully welded caps.

For. spare pipe penetrations closed by threaded caps, the caps must be Type B tested, in accordance with the requirements of Appendix J.

3.9 CPC's proposed exemption to test the seals on sensing lines for five containment pressure instruments in conjunction with Type A tests should be granted based upon favorable operating experience with these penetrations.

In Reference 3, CPC indicated that the containment pressure instrument !ines do not contain isolation valves and, therefore, Type C testing of those lines is not required by Appendix J.

We agree with this conclusion. However, in the course of their review under contract to the NRC, Franklin Research Center (FRC) determined that the connections of the instrument lines to the instruments are containment penetrations whose design incorporates seals, gaskets, or sealants.

Therefore, FRC concludes that Type B testing of these lines is required by Appendix J.

w-These penetrations are not designed to permit local leak testing, but they are tested as part of the Type A integrated leak rate tests, Also, experience indicated that there is little significant time-dependent increase in leakage through +hese penetrations.

Therefore, an exemption to the Type B test requirements of Appendix J should be granted for these penetrations.

i 3.10 An exemption should be granted to permit hydraulic testing of the check valves in the control rod drive pump supply lines, in lieu of pneumatic testing.

This testing should be conducted at a pressure of 1.1 Pa..

l 3.11 The proposed changes to the Technical Specif,1 cations should be l

revised to conform to the findings of this report, particularly with regard to the value of Pt, airlock testing reqairements, and substitution of hydraulic testing for pneumatic testing, 4.0 ACKNOWLEDGEMENTS j

This evaluation has been prepared by J. Pulsipher and R. Emch.

l Date: November 23, 1982

\\

4-

5.0 REFERENCES

1.

K. R. Goller (NRC) letter to R. B. Sewell (CPC), dated

  • August 5, 1975.

2.

R. B. Sewell (CPC) letter to K. R. Goller (NRC), dated September 15, 1975.

~

3.

R. B. Sewell (CPC) letter to Director, NRR dated February 13, 1976.

'4.

D. A. Bixel (CPC) letter to D. K. Davis (NRC), dated December 20, 1977.

5.

D.,P. Hoffman (CPC) letter to D., M. Crutchfield (NRC),

dated October 10, 1980.

6.

T. C. Bordine (CPC) letter to D. M. Crutchfield (NRC),

dated August 19, 1982.

7.

T. C. Bordine (CPC) letter to D. M. Crutchfield (NRC),

dated October 12, 1982.

t,c,.

Attached:

TER, dated 04/30/82

.o 9

9 9