ML20066G339

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Proposed Tech Specs,Revising Surveillance Requirement 4.6.1.6.1 Re Containment Structural Integrity
ML20066G339
Person / Time
Site: Beaver Valley
Issue date: 02/08/1991
From:
DUQUESNE LIGHT CO.
To:
Shared Package
ML20066G314 List:
References
NUDOCS 9102190084
Download: ML20066G339 (13)
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Text

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i ATTACHMENT A

! Beaver Valley Power Station, Unit No. 1 ,

' Proposed Technical Specification Change No. 187 l

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Revise the Technical Specifications as follows: l P#moX_C._Pmn _ Insert Pagg

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I 9102190084 9102og

{DR ADOCK 05000334 PDR

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  • 1' t, I L CONTAINMENT ' SYSTEMS

' CONTAINMENT STRUCTURAL-INTEGRITY LIMITING CONDITIONS FOR OPERATION .t 3.6.1.6 The structural integrity of the containment shall be maintained r at a level consistent with the acceptance criteria in Specification 4.6.1.6.1.

  • _APPLIC lBILITY: MODES 1, 2, 3 and 4.

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With the structural integrity of the containment not conforming to the above requirements, restore the structural integrity to within the limits prior to increasing the Reactor Coolant System temperature above 200'F.

RE h.Ac.9 wrrH SURVEILLANCE REOUIREMENTS 6.1.6.1 containmen,L,,iner Plateandandconcrete The structural integrity of the.

Concreteshall '

, t liner plate be determined during the  ;

shutdown for each Type A containment leakage rate test (reference-

  • Specification 4.6.1.2) by:
a. . a visual inspection of the accessible curfaces and verifying no -

apparent changes in appearance or'other abnormal degradation.

b. .a visual inspection of accessible' containment liner test channels-prior to each Type A containment leakage rate test. Any contain-ment liner test channel which is: found to be; damaged to the extant that channel integrity-is impaired or which is discovered with a - )

vent plug removed. shall: be removed and a protective coating shall be applied to. the liner in that area,

c. a1 visual tinspection"of the- dome area prior toLeach Type A contain- t ment leakage rate test to insure. the: integrity of. the protective- J coating. If a loss of integrity of the protective coating-is observed, any vent plug to a test channel which may be in the area where the protective coating.has failed shall be seal welded and then the= protective coating shall be repaired.

4.6.1.6.2 Reports An initial report of any-abnonnal degradation of the +

containment- structure detected during -the above required tests and inspec-tions shall be made within 10 days after completion of the surveillance requirements of this: specification, and the detailed report shallsbe' submitted pursuant to Specification.6.9.2 within 90 days after ccmpletion.. This report shall _ include a description of the condition-of the liner plate and 4 concrete, the inspection procedure, the tolerances on cracking and the cor-g- ,

1 rective actions taken.

@S iEbER #LLEY "MT 1 3/4 5-10 1

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b.ttachment to " Containment structurgl_Intearity" Insert "A" l

-4.6.1.6.1 Containment structural integrity shall be determined by performing one of the following surveillances:

a. Liner Plate and Concrete The structural integrity of the containment liner plate and concrete shall be deterniined during the shutdown for each Type A containment leakage rate test (reference Specification 4.6.1.2) by:
1. A visual inspection of the accessible surfaces and verifying no apparent changes in appearance or other abnormal degradation.
2. a visual inspection of accessible containment liner test channels prior to each Type A containment leakage rate test. Any containment liner test channel which is found to be damaged .to the extent that channel integrity.is impaired or- which is- discovered with a vent plug removed, shall be removed and a protective coating shall be applied to the liner in that area.
3. a' visual inspection of the dome area prior to each Type A containment- leakage rate test to insure the integrity of the protective coating. If a loss of integrity of the protective coating is observed, any vont plug to a test channel which may be in the area where the protective l coating has failed shall be seal welded and then the protective coating shall be repaired.
b.
  • Containment -Vessel Surfaces The structural integrity of the exposed- accessible interior and_ exterior surfaces- of the containment -vessel, including the liner plate, shall be determined _ during the shutdown for each Type A containment-leakage rate test (reference Specification 4.6.1.2) by a visual inspection of these surfaces. This_ inspection _shall be performed prior to the Type A containmentileakage rate test to verify no apparent changes in appearance or other abnormal 1 degradation.

Insert "B" Surveillance requirement 4.6.1.6.1.b is only applicable for the interval, including .the Type A testing conducted during seventh refueling outage, up _to the refueling outage for the next scheduled Type A test as per Surveillance requirement 4.6.1.2.a .

L BEAVER VALLEY - UNIT 1 (Proposed Wording)

ATTACHMENT B Beaver Valley Power Station, Unit No. 1 Proposed Technical Specification Change No. 187 REVISION OF TECHNICAL SPECIFICATION 4.6.1.6.1 A. DESCRIPTION OF AMENDMENT REQUEST The proposed amendment would revise surveillance requirement 4.6.1.6.1 to include an altcrnative to the present surveillance requirement. The alternate surveillance requirement is consistent with the Standard Technical Specifications (STS), and does not contain specific details on the required actions pertaining to test channels. In addition, a footnote was added which limits the duration for which the alternate surveillance is applicable.

B. BACKGROUND The Beaver Valley Power Station (BVPS) Unit No. 3 containment building has a continuously welded carbon steel membrane, supported by and anchored to the inside of the containment structure. Its function is to act as a leak tight membrane in the event of an accident. The cylindrical portion of the liner is 3/8" thick, the hemispherical dome liner is 1/2" thick, the flat floor liner covering the mat is 1/4" thick, with the exception of areas where the transfer of loads requires either bridging bars or bridging plates. The floor liner plate is covered with approximately 2 ft of reinforced concrete that insulates it from transient temperature effects. At the intersection of the containment liner and the concrete floor, a 1/2" joint is provided. This joint is filled with a 1/2 inch premolded joint filler. The top of the joint is sealed with two component polysulfide sealant. All welded seams are covered with continuously welded test channels which are zoned into test areas by dams welded to the ends of the sections of the channels.

Channels in the- hemispherical dome and containment mat are covered with concrete while those on the cylindrical liner wall are exposed. These test channels were installed to facilitate leak testing of welds during the containment liner erection.

Test ports were provided for each zone of the leak chase channels and, after completion of weld testing, 1/8 inch-NPT pipe plugs (vent plugs) were installed in the test ports. These plugs remain in place during subsequent Type A leak-rate testing. The design, analyses, and construction of the BVPS Unit No. l' containment building is similar to DVPS Unit No. 2, and VEPCO's Surry and North Anna containment buildings. The test channels in BVPS Unit No. 1 are constructed utilizing a smaller channel but installed in a manner similar to BVPS Unit No. 2.

Surveillance requirement 4.6.1.6.1 is normally performed in support of conducting Type A containment leakage rate tests.

When preparing to perform this test on Unit No. 2 during the second refueling outage, it was determined that the inspections conducted in support of the surveillance reqairement did not include .the vent plugs associated with test channels located on the containment basement floor. This resulted in requesting an emergency Technical Specification change on October 9, 1990.

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' ATTACHMENT.B,fcontinued-- -

y,  ; Proposed Technical Specification Change No. 187  :

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- Unit? RNo . L1- was;~ operating at the time the Unit No. 2 inspection-

- was! performed. It was unclear as to whether the floor test channel vent plugs had been . verified to exist in Unit No. 1 during . previous inspections in _ . suppsrt of- Type A tests. -There was no- recollection of this verifichtion and procedures do-not ,

specifically: call Lout verifying vent plugs' associated with the j test channels located in -the floor. Technical Specification [

Surveillance 4.6.1.6.1.b . infers inspections. of the containment

  • liner cylindrical walls because if a. vent plug is found missing, J tho' test channel is to be removed. The test channels are visible 4 on the liner walls'and their existence'is obvious. Surveillance requirement 4.6.1.6.1.0 addresses inspections of the containment

-dome. .As a ' result, we were concerned that we had not' verified.

the existence of the vent plugs on the floor' test channel vents q and _were _ preparing to inspect _this area-during the'next Unit No.  ;

l1 refueling outage, scheduled to'begin.in April'1991.

On. January 21, '1991, Unit No. 1 prepared to shutdown due to an unrelated problem, . During this shutdown, containment entries Lwere made -aince" the plant was being cooled to Mode 5 conditions -

and containment was being' returned to atmospheric' conditions. -on January- 22, 1991, .a test engineer _ was performing- specific' containment integrity checks and determined that-a number of vent plugs were missing.

The test channels which-were found txt have missing. vent plugs are 1

' located- under approximately 'two -feet of ~ reinforced concrete.

This factor makes complying withithe: surveillance requirement of

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= removing-'the: test channels, coating the liner _ welds and returning .

the- floor __to: its normal ' arrangement- an extreme hardship.

Therefore, Temporary. ' Waiver,-fwe -requested which. and.weresupportedgranted, on: Januaryl25, the planti L

restart 1991, without~ :a

-meeting -the ~ current surveillance ~ requirementL4L6.1.6.1-.until a j LTechnical- Specification change can'be approvedLby theTNRC. This amendment) request"fis the' f ollow -up .to; the Labove- mentioned DTomporaryDWaiver.:

I C.- JUSTIFICATION 1

The- proposed: -alternate surveillance . requirement is consistent 'I with the Standard: Technical Specifications'and 10 CFRj50' Appendix. L LJ. This: proposed . change adds a surveillance requirement?that does 'not contain specific details on 'the . required actions necessary if a test- channel is -f ound - to _be damaged or is discovered with a vent plug- removed. _The-test channels, as stated' in ~ a Stone 1 & ~ Webster (S&W)~ Report titled " Containment Liner Test Channels at BVPS Unit No. 1" (submitted under Change Request 181/45 'on 10ctober 1, 1990), are-capable of withstanding all loads that might be imposed on them during normal, test, and W-v-- , -- y*wwy y

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ATTACHMENTEB,4 continued

, :P'roposednTechnical Specification Change No. 187

Page.3' upset _ condition .

without ar.y loss of function. The' presence of the- test channels do not in.any way impair the performance;of the -;

containment. liner. itself. This report was prepared for Unit No. i l' and is- an' equivalent report when compared to the Unit No. 2 report' submitted with- Change Request 2A-46. 'The NRC recently  ;

(1989). determined the acceptability of these test channels as the containment pressure boundary at VEPCOs' Surry and North Anna Power Plants. ~

i The containment liner welds associated with~those test channels- )

with~ missing vent:-plugs are considered acceptable for continued

-operation based on the following activities:-

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1. -Sampling at affected floor locations
2. Installation of new' stainless.steelEvent plugs 3.- Seventh refueling outage Type A test The inspection of the containment floor test channel; vent plugs l q resulted in identifying _ 27; missing and-111 degraded carbon ~ steel '

vent plugs.-- These are. categorized'as follows:

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  • 15 missing plugs located on the containment floor ,

-C 12 . missing plugs- located- on vent- linen- attached to-  !

containment colunns at a :2 foot. distance above the l containment floor. 1'

  • ?l11 vent. plugs: . located.on the containment floor' failed when disturbed-for inspection purposes.-

Forf each ' floor location,-an~ effort was ma'de to;collectLa sample

-of"-the: contents .(if .any) of.the: test. channel. -In allDbut two-

cases;1 samples of dirt,; sand, and otherimaterials1were collected -i

-by 1 forcing aJcapillary tubecinto the vent:line. In some' cases it 1

is:Lbelieved: the capillary-tube =wasiextended' fully into the test -

i channel: and no moisture was collected'(it is believed these!were 3 dry). . The1 samples will be sent outLfor analysisLand the results '

l fwillibe:available-in approximately two weeks.

.TheJ sampling- of the romain'ing two-vent' lines resultedLin several-drops- of . moisture being . collected. Those two vent lines were

, parti of the sample of 11-which had vent-plugs disturbedLduring

.the_ inspection. ._An; offort' was made to analyze these' samples.

The quantity-wasLinsufficient-to provide-conclusive results. The pH of Lthe samplesL was neutral;.however, dilution may have made-

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-the.results inconclusive. .

.The 12--vent lines located-on columns could not be sampled due to

' configuration. A 90' fitting is. located at the1 vent opening  ;

=which does ruit permit insertion of a sampling-tool. However, since these ' lines are elevated above the floor it is unlikely corrosive' materials could get-into the test channels.  !

ATTACHMENT B, continued P'roposed Technical Specification Change No. 187 Page 4 The 11 vent plugs which failed when disturbed for inspection purposes, were located in the general vicinity of the containment sump. In this general area, the floor slopes toward the sump.

In the event the sump is overfilled, these vent plugs would be among the first to be wetted by sump water. The containment sump water frequently is comprised of a boric acid solution. This factor would make these 11 vent plugs more susceptible to corrosion.

Visual inspection into the test channels associated with vent connections found with missing plugs using a fiber-optic boroscope was not attempted due to the poor results obtained while inspecting the test channels at Unit No. 2. The boroscope provided very good resolution, but had a limited area of view (approximately 1/4" -

3/8" dia.). The boroscope results were inconclusive because of the limited area of view.

From the above sampling, there is no indication that a corrosive environment exists within the test channels beyond that

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originally assumed. Additionally, since each floor vent line is either- totally or partially plugged with dirt, there is no opportunity for reoxygenation of the test channel in a sufficient manner to promote accelerated corrosion. The-Unit No. 2 vent line inspection also resulted in identifying dirt and debris left over from the construction of the containment. It is believed the same can be said for the Unit No. 1 test channel vent lines terminating at floor level.

l The _ test channels are believed to be in good condition on the basis- of a lack of conclusive information to prove otherwise.

Preliminary assessmunts have resulted in the conclusion that the liner welds are still capable of performing their intended function.

The replacement of the 27 missing and 11 degraded carbon steel vent plugs with stainless steel plugs will.further enhance the ability of liner to properly function. The combination of the carbon steel test channel, stainless steel vont tube and new l stainless steel vent plugs forms a redundant barrier to preclude

.a fission product release. The new stainless steel plugs-will also eliminate the source of possible reoxygenation to the test channels and prevent the introduction of fluids to the test L channel environment, which could enhance corrosion of the liner.

1 Additionally, we successfully completed a Type A test in the fall of 1989 during the Unit No. 1 seventh refueling outage. This test provides added assurance that the liner is capable of performing its intended function. The affected vent plugs will be removed during the next scheduled Type A test (late 1992) and reinstalled following completion of that test. This will provide further assurance that the liner welds are capable of performing their intended function.

The completion of the above activities provides assurance of the integrity of the containment liner for the duration of this request for a Technical Specification change.

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n ~. I TTACHMENTLB,fcontinued

. Froposed Technical' Specification' Change No. 187 '

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The' proposed' word'ing -for the alternate surveillance requirement 4.6=.1.6.1.b- contains specific requirements to inspect the' exposed accessible- interior and exterior surfaces of the containment l -vessel. This inspection will_ verify that no apparent changes in ,

appearance or other-abnormal degradation have occurred, t LThe -visual 1 inspection will' continue to include the accessible exposed ~ . test _ channels and associated vent plugs. This. proposed change toe the Technical _ Specifications does not relax the '

requirement to assure the containment-liner remains capable of g performing its intendedffunction. Repairs, if.any, to the liner, _1

.will: 1xa - made- in- accordance with the-ASME Boiler and Pressure Vessel Code.- .

Therefore, this proposed change to, _ include an alternate L surveillance requirement- 4.6.1.6.1.b does not affect 'the structural. integrity or? leak tightness of the containment Evessel. The structural integrity of the' containment vessel will

still be verified by inspections.and tests as required
by 10 CFR-

,L50,- 1 Appendix J, to ensure the containment structure'will remain.

Jcapable of performing its. intended function. -

- D.tSAFETY ANALYSIS .,

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The;rstructural int'egrity and leak tightness.of the. containment' ^

vessel will- continue to lua maintained to the original design l

< standards -for theclife of_the facility. The proposed change will =)

l nots ' :a f f ect .the capabilityfof the? containment */essel to withstand -

Lthe,3 maximum pressure-- ' expected for any-postulated _ accident.. :The-1 proposed 1: wording _for the alternatecsurveillance requirement is W Lconsistent with; STS -and the inspection criteria'as stated in 10' q mCFRif50igAppendix- J. . The1non-existance of.the r specific details Jpertaining . to_ test- channels _andL vent plugs;'in the alternate f , surveillance will not affect -the ' ability of the containment)  ;

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vessel--Lto~ meet .its; design function._ =Any' apparent'changesLin '

p cc -appearance or abnormal degradation discovered duringLthe required inspection other_~

1 of the' accessible- interior ~ and ' exterior

-surfaces of the containment . vessel -will be- corrected- in-

'accordance with,theJASME Boiler.and Pressure 1 Vessel Code prior to

-plant . ' start-up. This inspection w ~ill ' continue .to include

accessible test' channels, vent" plugs'and-protective coatings.
Therefore, Lthis change is- considered safe based on the factithati
the l proposed' amendment- will continue to verify the structural' 1 l

integrity andL leak,' tightness- of_ the containment vessel. .This verification . will~ ensure. that the original design standards, including the ability to withstand the maximum pressure _ expected-

-in the event of a design basis accident, are being maintained for.

the-containment vessel.

i ATTACHMENT B,' continued ,

Proposed Technical Specification Change No. 187 1 "Page 6 E. NO SIGNIFICANT HAZARDS EVALUATION The no significant hazards considerations involved with the proposed amendment have been evaluated, focusing on the three standards set forth in 10 CFR 50.92(c) as quoted below:

The commission may make a final determination, pursuant to the procedures -in paragraph 50.91, that a proposed amendment to an operating license for a facility licensed under paragraph 50.kl(b) or paragraph 50.22 or- for a testing facility involves no significant hazards consideration, if operation of the facility in accordance with the proposed amendment would not:

1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or
2) Create the' possibility of a new or different kind of accident from any accident previously evaluated; or
3) Involve a significant reduction in a margin of safety.

The .following evaluation is provided for the no significant hazards consideration. standards:

1. - Does the change involve a significant increase in the probability or consequences of- an accident previously

. evaluated?

The structural integrity and leak-tightness of the containment vessel will ' continue to be maintained. The ability to provide a leak-tight barrier against the uncontrolled release of- radioactive material to the environment remains unchanged.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

L :2. Does the change create the possibility of a new or different-

kind of accident from any accident previously evaluated?

L There would be no change. to system configurations, plant equipment or analysis. as a result of this proposed amendment. The containment structural integrity and leak-tightness will not be affected by this proposed change.

Therefore, the proposed' changes do not create the possibility L of. a- new or different kind from any accident previously evaluated.

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+ ATTACHMENT-B, continued y, , Proposed; Technical Specification 1 Change No.1187 page 7:

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3. Does the1 change Jinvolve a significant reduction inta margin '

of safety?-

-The containment steel liner and external concrete surfaces -

will.s continue. to' provide the same structuraliintegrity.and- -

leak-tightness assumed in the original design.- Although not .

< ~ required, .the existence of the plugged test channels provide additional--protection in- the form of a. redundant' barrier to

.the steel liner welds. -The proposedLamendment will continue to' require- that an inspection is conducted on_the exposed accessible- - surfaces to_ verify no apparent . changes in .

appearance or other abnormal degradation'has occurred. '

Therefore, ythe proposed changeLdoes not involve a significant- l reduction.in a: margin of safety. 4 F. NO-SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION t

BasedL on fthe considerations, expressed =above, . it is concludedothat- l

.theifactivities> associated with this license- amendment request =

satisfles the nojsigni'ficant hazards consideration standards'of-lo--

g CFR_ 5.0 '. 9 2 ( c ) _ jand, . accordir; gly, a- -no- significant hazards; -!

consideration 1 finding?isijustified..

, L G. - ENVIRONMENTAIs EVALUATION The proposed _-_ changes nave- been; evaluated- and -it;.has been g _ determined -that- the' changes- do not , involve - (i);ansignificant l" ihazards' consideration,- (ii) a significant:changefin=the types;or Jsignificantofincrease inL the amounts _of;any effluents-that may be ,

Tr~eleasediioffaite,JorJ(iii)La_significant increase' in-individual orL ecumulative< occupational ~ radiation exposure. _ Accordingly, .the-proposed..~ changes meet thes eligibility criterion for:fcategorical;  ;

exclusion - set: forth in 1101 CFR 151. 22 (c) (9)f. cTherefore,-pursuant:sto?

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C F R l 5 1 . 2 2 c(b) , L 'an ' environmental- assessment 1ofcthe proposedi i (changes 11sDnot(required. j li I

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ATTACHMENT C Beaver Valley Power Station, Unit No. 1 Proposed Technical Specification Change No. 187 gg -

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, , s Typed Pages: 3/4 6-10 3/4 6-10a I

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_ gQNTAINMENT SYSTEMS-SQFTAINMENT STRUCTURAL IUTEGR11TY d

LIMITING CONDITIONS FOR OPERATION

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3.6.1.6 _ The structural Integrity of the containment shall be maintained at a level consistent with the acceptance criteria in Specification 4.6.1.6.1.

AEP_LICABIliLTX: MODES 1, 2, 3 and 4 AQ.T ION:

With the structural integrity of the containment not conf or.aing to the above requirements, restore the structural Jntegrity to within the . limits prior to increasing the Poactor coolant System temperature above 200*F.

SURVEILLANCE REQUIREMENTS 4.6.1.6.1 Containment structural integrity shall be determined by performing one of the following aurveillances:

a. Einer' Plate and Congrete The structura. integrity of the l containment liner plate and concrete shall be detcrmined during the shutdown for nach Type A containnont leakage rate test (reference Specification 4.6.1.2) by:
1. A visual inspection of the accessib.te surfaces and verifying l no - : apparent changes in appearance or other abnor.nal degradation.

- 2 =. a visual- inspection of- accessible containment liner test .l  ;

channels - prior to each Typo A containment leakage rate '

test._ Any containment liner tent-channel which is found to

-be damaged to the extent that channel integrity is impaired or which in- discovered with a vent plug removed, sha.'1 be -

removed and a protective coating- shall be applied to the I liner in that area.

3. a visual inspection of the dome area prior to each Type A i containment . leakage rate test to insure the integrity of the protective coating. If a loss of. integrity- of the

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protective coating is observed, any vent plug to a Oest  ;

channel which may be in the area where the protective I coating has failed shall be seal welded and then the '

protective coating shall be repaired.

l i H BEAVER VALLEY - UNIT 1 3/4 6-10 (Proposed Wording) 1

Containment Systems-Sl"RVERLWOf REQUIREMENTS , To'ttir acd w aar m . - - - a w .: n U.. *D EAlnn b -. Vessel su rf,nteg! The structural integrity of the exp weil ewmasible interior and exterior surfaces of the contCarent vessel, including the liner plate, shall be determinad Wring the shutdown for each Type A containment leakage cute test (reference Specification 4.6.1.2) by a visual inspection of these surfaces. This intpection shall be performed prior to the Type A containment lea} age rate test to verify no apparent changes in appearance or other abnormal degradation.

4 4.6.1.6.') Reports An inititl report of any abnormal degradatior: oi IF the containment structure detected during the above 1equired tet.s y an1 iny ections shall be ande within 10 days after completion of tne ^

surveillance requirements of this upecification, and the detailed . ,

report shall be su'umitted pursuant to specification 6.9.2 witt'n 90 #

days after compktion. This report shali include a descript'.o'. of the condition of the liner plate and concrete, 17. ' inspection 'd procedure, the tolerances on cracking al.d the corre,"r. 've actions h

a taket. )

D FD A

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Surveillhnce requireNent 4.6.1.6.1.b is only applicable for the

' interval, including the type A testing conducted during seventh

're fueliing outage, up to the rc.f ueling outage for the next scheduled Type A tes.t as per Surveillance requirement 4.6.1.2.a .

I, BEAVER VALLEY - UNIT 1 3/4 6-10a (Proponed Wording)

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