ML20063B538
| ML20063B538 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 01/12/1994 |
| From: | Ralph Beedle POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | |
| Shared Package | |
| ML20063B536 | List: |
| References | |
| NUDOCS 9402010028 | |
| Download: ML20063B538 (7) | |
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BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION in the matter of
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NEW YORK POWER AUTHORITY
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Docket No. 50-333 James A. FitzPatrick Nuclear Power Plant )
APPLICATION FOR AMENDMENT TO OPERATING LICENSE The New York Power Authority requests an amendment to the Technical Specifications contained in Appendix A to Facility Operating License DPR-59 for the James A. FitzPatrick Nuclear Power Plant. This application is filed in accordance with Section 10 CFR 50.90 of the Nuclear Regulatory Commission's regulations.
This application proposes a temporary waiver of the two year maximum surveillance interval for the Type C test (local leak rate test) of the shutdown cooling isolation valves. The proposed change would permit a deferral in the performance of this test until the next refueling outage.
The proposed change to the Technical Specifications is Attachment 11 to this Application for Amendment to the Operating Ucense. The Safety Evaluation for the proposed change is included as Attachment Ill.
i New York Power Authority l
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.Q afp E. Be.dle Executive V e President Nuclear Ge eration
'y STATE OF NEW YORK COUNTY OF WESTCHESTER Subscribed and swom to before me this /A day ofpn< uup994.
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Notary Public KATHLEEN D GALLAGHER Notary Pubhc, State of t.ew York No. 5o04481 OUalified in Westchester Counth/
Commission Expues Nov.16,19,#'
9402010028 940111 PDR ADOCK 05000333 P
ATTACHMENT I to JPN-94-001 f
JUSTIFICATION FOR EXEMPTION FROM THE REQUIREMENTS OF 10 CFR 50. APPENDIX J StiUTDOWN COOLING ISOLATION VALVE LEAK RATE TESTING l'
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New York Power Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT i
Docket No. 50-333 DPR-59 l'
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Attachment I to JPN-94-001 i
JUSTIFICATION FOR EXEMPTION FROM THE REQUIREMENTS OF 10 CFR 50, APPENDIX J SHUTDOWN COOLING ISOLATION VALVE LEAK RATE TESTING i
in accordance with 10 CFR 50.12(a), The New York Power Authority requests a one-time schedular exemption from a requirement of 10 CFR 50, Appendix J Section lil.D.3 for the James A. FitzPatrick Nuclear Power Plant. The exemption requested would temporarily waive the two-year maximum surveillance interval for the Type C test (local leak-rate test) of the shutdown cooling iso! Mon valves (10MOV-17 and 10MOV-18). 10 CFR 50 Appendix J, Section Ill.D.3 states.
" Type C tests shall be performed during each reactor shutdown for refueling but in no i
4 case at intervals greater than 2 years."
1 The shutdown cooling isolation valves were previously tested during the last refueling outage -
(Reload 10 / Cycle 11). This was an extended outage that began in November 1991 and ended in January 1993. be Type C tt~is on the subject valves were performed on May 30, 1992 for the outboard shutdown cooling isolation valve (10MOV-17), and June 5,1992 for the inboard shutdown cooling isolation valve (10MOV-18). Subsequent delays in the outage resulted in these tests being performed significantly in advance of the start of operating cycle 11 (more than seven months prior to the end of the outage). As a result, the two year test interval will be reached for these valves (May 30,1994 / June 5,1994) six to seven months prior to the next scheduled refueling outage. The exemption would permit a deferral in the l
performance of the Type C test of the shutdown cooling isolation valves beyond the two-year limiting interval to the next refueling outage (Reload 11/ Cycle 12), currently scheduled to begin in November 1994.
JUSTIFICfTION.FOR EXEMPTION 10 CFR 50 ' /y states that the Nuclear Regulatory Commission may grant exemptions from the requirements of the regulations contained in 10 CFR 50 provided that:
The exemption is authorized by law; The exemption does not present an unde risk to the public health and safety; The exemption will not endanger the common defense and security; j
l Special circumstances are present as defined in 10 CFR 50.12(a)(2).
i to JPN-94-001 EXEMPTION REQUEST Page 2 of 5 1.
The requested exemption is authorized by law.
The Nuclear Regulatory Commission is authorized by law to grant this exemption.
II.
The requested exemption does not present an undue risk to the public health and safety.
The operating configuration of the shutdown cooling isolation valves and the RHR system when the reactor coolant system is pressurized (> 75 psig) substantially minimizes the possibility of gross leakage through these valves. A high reactor pressure interiock, as well as plant operat:ng procedures, assures that these isolation vaives are closed whenever the reactor pressure is above 75 psig. This protects the low pressure RHR system from overpressurization. The RHR system suction piping is designed for 450 psig. G?,ss leakage while the reactor is pressurized would be detected by leigh pressure on the RHR suction piping or an increase in suppression pool inventory.
Consequently, the maintenance of normal operating status of the RHR system assures the absence of gross leakage through these valves.
These valves also receive an isolation signal in the event of a plant accident (reacter vessel low water level or high drywell pressure). This assures isolation of a potentiJ leakage path from the reactor coolant system to the reactor building. For this path to exist, leakage through both isolation valves, and a breach of the RHR system piping would need to occur simultaneously. Since the isolation valves are maintained closed with the reactor pressurized, it is highly improbable that leakage through the valves will increase while the plant is operating. The redundant isolation valves provide two leakage baniers which limit the pathway leakage rate to that experienced by the valve with the smallest leakage rate. Further, the shutdown cooling system utilizes the RHR system whose entire pressure boundary is designed as a safety-related system. For these reasons, the potential for significant leakage to the reactor building by way of the j
shutdown cooling line is extremely remote.
4 The replacement of both isolation valves with valves of improved design provides adM confidence that excessive leakage will not be experienced. The inbocM valve (10MOV-
- 18) was replaced during the 1985 refuel outage. This valve has expot inced unacccptable leakage during only one of the four Type C tests performed during the refueling outages since its replacement. The outboard isolation valve (10MOV-17) was replaced with a new valve during the last refueling outage (1992). Considering the similarity in design of this valve to 10MOV-18, there is a high level of confidence in the overall integrity of the shutdown cooling sj tem penetration over the duration of the 1
current operating cycle. The limited numt' > of valve strokes these valves are subject to over any one operating cycle minimizes valve degradation due to wear.
i Based on the demonstrated reliability of the current shutdown cooling isolation valve design, and the very low probability that the shutdown cooling system penetration would provide a pathway for significant leakage to the reactor buildin;; for reasons described j
, to JPN-94-001 EXEMPTION REQUEST Page 3 of 5 above, a deferral in the Type C tests for the shutdown cooling isolation valves does not present an undue risk to the public health and safety.
Ill.
The requested exemption is consistent with the common defense and security.
The common defense and security are not affected by this request for exemption.
IV. Special circumstances are present which necessitate the request for an exemption.
Three of the special circumstances presented in 10 CFR 50.12(a)(2) apply to this exemption:
- 1. Circumst:nce (ii) states: " Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessny to achieve the underiying purpose of the rule."
The intent of Type C local leak rate tests is to ensure that the containment leak-tight integrity is maintained within the requirements specified in plant Technical Specifications during operating cycles, and that the appropriate plant conditions exist to accommodate this test as specified in the regulations; i.e., "during reactor shutdawn for refueling." This regulation recognizes that testing the valves during shutdown minimizes the risk to plant safety associated with the removal of systems from service to accommodate testing. Considering the unique nature of the shutdown cooling system (i.e., the shutdown cooling system performs no safety function with the reactor at elevated pressures, and the system performs an essential safety function when the reactor is at low pressure and the plant is in the non-refueling configuration), it is appropriate to tests these valves only during refueling outages.
The two year limitation in the regulation is based on two years of normal plant operation. Considering the seven to eight months that the plant was shutdown following the last Type C test during the previous refueling outage, and the severti surveillance / maintenance outages expected during the current operating cycle, these valves will not be expor d to service conditions in excess of those contemplated by the regulation.
For these reasons, the application of the regulation in this particular circumstance is not necessary to achieve the underiying purpose of the rule.
- 2. Circumstance (iii) states: " Compliance would result in undue hardship or other costs that are significan7 in excess of those contemplated when the regulation was f
adopted,...."
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. to JPN-94-001 j
EXEMPBON REQUEST Page 4 of 5 The shutdown cooling isolation valves are used to isolate the single suction line from the reactor coolant system to the Residual Heat Removal (RHR) purnps. The only effective means of removing reactor core decay heat is with the shutdown cooling mode of the RHR system. This requires both isolation valves to be in the open position. The shutdown cooling mode of the RHR system must be removed from service for approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to perform a local leak rate test (Type C) of its isolation valves. This is the time required to tag-out the system, drain the line, perform the test, refill the line, and retum the system to service. To avoid overheating the reactor coolant system with the shutdown cooling mode inoperable, one of the following two conditions must exist:
a.
The reactor needs to be shutdown for several months to permit sufficient reduction in decay heat levels for use of an altemate shutdown cooling method without placing the plant in the refueling configuration. The attemate cooling method w% the highest heat removal capacity, as identified in a plant proceduto (Shutdown Procedure ODSO-32), is the Reactor Water Cleanup system in the blowdown mode. However, the reactor must be shutdown for more than three months before this method can handle the decay heat load.
b.
The plant needs to be in the refueling configuration; i.e., reactor head removed, reactor cavity flooded up and connected to the roent fuel pool. This permits the removal of the normal shutdown cooling sy&1 from operation and testing of these valves.
Only one additional non-refueling outage is scheduled during th9 current operating cycle. This is a three week surveillance / maintenance outage planned for spring, 1994. The decay heat levels present during any outage less than several months precludes the use of the attemate cooling method without placing the plant in the refueling configuration.
The proposed change will preclude the need to place the plant in the refueling configuration prior to the next scheduled refueling outage. The level of Authority resources necessary for the removal of the drywell and reactor heads, and the connection of the reactor cavity to th3 spent fuel pool, is not practical solely for the 1
purpose of testing the shutdown cooling isolation valves. Additionally, placing the plant in the refueling configuration will extend the length of the spring 1994 outage.
Further, placing the plant in the refueling configuration to accommodate testing of the isolation valves will increase occupational radiation exposures. For these reasons, compliance with the regulation would result in undue hardship and costs that are significantly in excess of those contemplated when the regulation was adopted.
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. to JPN-94-001 EXEMPRON REQUEST Page 5 of 5
- 3. Circumstance (v) states: "The exemption would provide only temporary relief from the applicable regulation and the licensee or applicant has made good faith efforts to comply with the regulation."
The requested exemption is temporary since it provides relief from the two-year maximum surveillance interval of 10 CFR 50, Appendix J, Section Ill.D.3 for the subject valves only during the current operating cycle. A Type C test of the valves would be performed during the next refueling outage, currently planned for six to seven months after the two year test interval limit. The Authority has made a good faith effort to comply with the regulations considering its decision to implement two mid-cycle outages to accommodate Type B and C tests of the other containment penetrations.
CONCLUSION The Authority concludes that this one-time schedular exemption is warranted under the provisions of 10 CFR 50.12, in that it does not present an undue risk to the public health and safety, and several "special circumstances" are present. There is a high degree of confidence that the affected components will not significantly degrade during the extended operating interval. Moreover, any potential incremental benefit of performing the tests within the two year requirement would not be sufficient to offset the increased occupational radiation exposure associated with testing, the risk to plant safety associated with the removal from service of the primary method of decay heat removal, and the undue financial burden of placing the plant in the refueling configuration and extending the length of the spring 1994 surveillance / maintenance outage.
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