ML20045E645

Proposed Tech Spec 4.7.A.2.f Re Containment Leak Rate Testing

ML20045E645
Person / Time
Site:	FitzPatrick
Issue date:	06/28/1993
From:	POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:
Shared Package
ML20045E630	List: ML20045E629 ML20045E637 ML20045E645
References
JPN-93-044, JPN-93-44, JPTS-93-007, JPTS-93-7, NUDOCS 9307020268
Download: ML20045E645 (10)

Text

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ATTACHMENT 11 to JPN-93-044 PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING CONTAINMENT LEAK RATE TESTING JPTS-93-007 l t

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JAMES A. FiTZPATRICK NUCLEAR POWER PLANT Docket Nu. 50-333 l DPR-59 9307020268 930628 PDR AP.Cl'. 05000333 P PDR F

JAFNPP '

4.7 (cont'd)

(5) Type C test. .

! Type C tests shall be performed during each reactor shutdown for refuelino but in no case at intervals greater than two year.

(O Other leak rate tests specified in Section 4.7.d chall be performed during each reactor shutdown for refueling but in no case at intervals greater than two years.

f. Containment modification

• Any major modification, replacement of a component which is part of the primary reactor containment boundary, or resealing a seal-welded -

door, performed after the preoperational leakage -

rate test shall be followed by either a Type A, Type B, or Type C test, as applicable, for the area affected by the modification. The measured leakage from this test shall be included in the test report. The acceptance criteria as appropriate, shall be met. Minor modifications, replacements, or resealing of seal-welded doors, performed directly prior to the conduct of a scheduled Type A test do not require a separate test.

" in accordance with an exemption from 10 CFR 50 Appendix J, a Type A, B, or C test is not required for the replacement of piping and welds which constitute the Core Spray System minimum flow lines (3"-

W23-152-7A, B) during the 1993 maintenance outage.

I Amendment No. A0' 97,125,134,14d, 174

- Attachment til to JPN-93-044 .;

SAFETY EVALUATION FOR .-

. . t PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING .-i CONTAINMENTIEAK RATE TESTING j JPTS-93-007 i i

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JAMES A. FITZPATRICK NUCLEAR POWER PLANT  !

Docket No. 50-333 }

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1 Attachment lit to JPN-93-044 SAFETY EVALUATION FOR"  !.

PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING i CONTAINMENT LEAK RATE TESTING (JPTS-93-007_) .!

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1. DESCRIPTION OF THE PROPOSED CHANGE *

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The proposed change to the James A. FitzPatrick Technical Specifications revises the -;

note associated with Specification 4.7.A.2.f on page 174. ,

i The note is changed to read as follows:

In accordance with an exemption from 10 CFR 50 Appendix J, a Type A, B, or  !

C test is not required for the replacement of piping and welds which constitute

• the Core Spray system minimum flow lines (3"-W23-152-7A, B) during the 1993  ;

maintenance outage.  ;

The existing note applied to two previous exemptions from 10 CFR 50 Appendix J.

These exemptions: the replacement of the HPCI system turbine exhaust line block i valve (HPI-11) during 1988 maintenance outage, and the repair of the Core Spray l System test return line weld 10-14-884A during the 1989 maintenance outage, have i both expired.

ll. PURPOSE OF THE PROPOSED CHANGES t The proposed change to the James A. FitzPatrick Technical Specifications eliminates the requirement for the Authority to perform a Type A primary containment integrated j leak rate test (ILRT) during the fall 1993 maintenance outage due to the provision of l Technical Specification 4.7.a.2.f. The proposed change allows for the replacement of .  !

piping and welds which constitute the Core Spray System minimum flow lines (3"-W23- 1 152-7A, B), without having to pedorm a Type A ILRT as required by Technical ';

Specifications. The new welds will be located on sections of the "A" and "B" Core Spray minimum flow piping which cannot be isolated to allow pedormance of a local leak rate test. These sections of piping are shown on the marked up copy of drawing FM-23A, " Flow Diagram - Core Spray System 14" included as Attachment IV. r i

Compensatory measures consist of an attemate inspection program, including of 100%

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radiography of the new welds, surface examination of new welds that form a portion of  ;

the primary containment boundary, and a system leakage test (in accordance with .

ASME Section XI code,1980 Edition through Winter 1981 Addenda, paragraph IWA- i 5213), to ensure structural integrity and leak tightness.

The Authority requests that this application for an amendment request be approved  ;

prior to startup from the fall 1993 maintenance outage currently scheduled to end in .;

September. .

Ill. IMPACT OF PROPOSED CHANGE ,

The most significant impact of the proposed change would be to allow the FitzPatrick plant to restart following the completion of the Fa!! 1993 maintenance outage without l performing Type A ILRT. Performance of compensatory non-destructive examinations j (NDE) of the new welds in lieu of a Type A leakage test as required by Technical Specifications has ne impact on the safety of the plant and is technically justifiable as ,

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Attachment ill to JPN-93-044 SAFETY EVALUATION Page 2 of 4 described below.

The Core Spray rninimum flow pipe repair will be conducted in accordance with the JAF ISI Program and ASME Section XI 1980 Edition through Winter 1981 Addenda, which is the current inspection code in use at the FitzPatrick Plant. As allowed by ASME Se sion XI, paragraph IWA-4120, the design code specified for the pipe replacemet +he original plant design code, ANSI B-31.1-1967 with Addenda A. As per ASME Sectir. XI, no pre-service inspection is required. However, ANSI B-31.1-1967 requires that 'k tightness be demonstrated. This section states:

it sh# ' - ., adatory that the design, fabrication, and erection of power piping, c instructed under this Code demonstrate leak ti;Nness. This requirement shall be .7' by a hydrostatic leak test prior to initial operation. Where a hydrostatic test is not practicable, an initial service leak test, a vacuum test, or 100 percent radiography of all welded joints in an all welded system may be substituted. (emphasis added)

The Authority will perform 100% radiography of the new welds. In accordance with ASME Section XI,1980 Edition through Winter 1981 Addenda, paragraphs IWA-5213, 5214(b), and 5222(d), a system leakage test of the new welds will be performed. In addition to these code requirements, a surface examination will be performed on the new welds that form a portion of the primary containment boundary. These non-destructive examinations meet the intent of the existing Technical Specification i 4.7.A.2.f which is to assure that modifications to the containment pressure boundary  :

are leak tight. The Authority will perform an ILRT during the 1995 refueling outage. '

This situation is similar to the repair of weld 10-14-884A on the Core Spray System return test line (10"-W23-152-98) in 1989. That weld repair required the creation of a new weld which could not be local leak rate tested. The Authority requested an exemption from 10 CFR 50, Appendix J and a proposed change to the Technical Specifications (Reference 1). This request was granted by the NRC in Reference 2.

The Authority plans to replace Core Spray System minimum flow piping with an improved material (currently planned as ASTM A376 Type 316 stainless steel) that is more resistant to cavitation induced pitting than the current pipe material. In addition, the location of the orifice within the pipe line will be changed to reduce the effects of cavitation. This modification will improve plant design ano make this piping less susceptible to potential cavitation induced pitting in the future.

IV. EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION Operation of the FitzPatrick plant in accordance with the proposed amendment would not involve a significant hazards consideration as defined in 10 CFR 50.92, since the proposed changes would not:

1. involve a significant increase in the probability of an accidelt or consequence previously evaluated. The proposed change would allow fm the replacement of -

piping and welds which constitute the Core Spray System minimum flow lines (3"-W23-152-7A, B), without performing a leakage test ac required by Technical Specifications. This replacement will improve the structural capability of the Core Spray System by use of improved materials.100% radiography, system

Attachrnent lit to JPN-93-044 SAFETY EVALUATION Page 3 of 4 leakage test, and surface examinations on the new welds forming a portion of  !

the primary containment boundary will assure structural integrity of the new welds and the lack of any flaws through which a leakage path could develop.  :

Since the structural integrity of the containment pressure boundary through these new welds are assured, the probability of occurrence or consequences of l any accident previously evaluated is not significantly increased. l t

2. create the possibility of a new or different kind of accident from those previously evaluated. Not performing an ILRT during the Fall 1993 maintenance outage

• cannot initiate any type of accident. The replacement of piping and welds which constitute the Core Spray System minimum flow lines (3"-W23-152-7A,B) improves the Core Spray System structural capability. Using the improved material for this piping reduces the probability of cavitation induced pitting in the future. The planned compensatory measures provide assurance of the ,

structural and leak integrity of the piping. Since the structural integrity of the  !

containment pressure boundary through these welds are assured, no change is i made to the possibility of a new kind of accident from those previously evaluated. ,

3. involve a significant reduction in the margin of safety. Performance of 100%

radiography, surface examinations, and a system leakage test, in lieu of a pneumatic leak rate test on the new welds, is conservative. These examinations assure the structural integrity of the new welds and the lack of ,

any flaws through which a leakage path could develop. In combination, these '

examinations ensure zero leakage through the new welds. The construction code (ANSI B-31.1-1967) allows for 100% radiography as an alternate to leakage testing when such testing is not practicable. There is no reduction of any margin of safety.

V. IMPLEMENTATION OF THE PROPOSED CHANGES Implementation of the proposed changes will not adversely affect the ALARA or Fire  :

Protection Program at the FitzPatrick plant, nor will the changes impact the I environment.

VI. CONCLUSION The changes, as proposed, do not constitute an unreviewed safety question as defined in 10 CFR 50.59. That is, they:

a. will not increase the probability of occurrence or the consequences of an  !

accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report

b. will not increase the possibility of an accident or malfunction of a different type from any evaluated previously in the safety analysis report; and i

c. will not reduce the margin of safety as defined in the basis for any technical (

specification; and  !

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Attachment ll1 to JPN-93-044 SAFETY EVALUATION

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d. involve no significant hazards consideration, as defined in 10 CFR 50.92.

Vll. REFERENCES

1. NYPA letter, J. C. Brons to NRC, dated September 28,1989 (JPN 89-062),

" Exemption from 10 CFR 50 Appendix J and Proposed Change to the Technical Specifications Regarding Containment Leak Rate Testing (JPTS-89-025).*

2. NRC letter, D. E. LaBarge to J. C. Brons, dated October 4,1989, issuing Amendment 140 to the FitzPatrick Technical Specifications.

3. James A. FitzPatrick Nuclear Power Plant Updated Final Safety Analysis Report.

4. James A. FitzPatrick Nuclear Power Plant Safety Evaluation Report (SER),

dated November 20,1972, and Supplements.

5. James A. FitzPatrick Nuclear Power Plant Drawing FM 23A, " Flow Diagram -  ;

Core Spray System 14," Revision 34, dated April 21,1993.

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. . j ATTACHMENT IV to JPN-93-044 FM-23A Drawina. " Flow Diaaram - Core Sorav System 14" JPTS-93-0DZ I

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