ML20073P358
| ML20073P358 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood, 05000000 |
| Issue date: | 04/19/1983 |
| From: | Lentine F COMMONWEALTH EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| 6067N, NUDOCS 8304250148 | |
| Download: ML20073P358 (7) | |
Text
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Commonwealth Edison
) one Fast feational Plaza, Chicago, Illinois C
Address Rrply to: Post Office Box 767 Chicago Illinois 60690
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April 19, 1983 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
Byron Station Units 1 and 2 Braidwood Station Units 1 and 2 Containment Leak Rate Testing NRC Docket Nos. 50-454, 50-455, 50-456, and 50-457
Dear Mr. Denton:
This is to provide additional information regarding leak testing of the reactor containments at Byron and Braidwood Generating Stations.
Staff review of this information should close Confirmatory Issue 20 of the Byron Safety Evaluation Report.
Specific exemptions from the requirements of Appendix J are also requested.
In general, fluid systems will be vented and drained during containment integrated leak rate tests in accordance with the requirements of paragraph III.A.1(d) of Appendix J to 10 CFR 50.
Attachment A to this letter contains a list of the fluid systems which will not be vented and drained.
The line numbers identified pertain to Unit 1 at each station.
The Unit 2 list will have different line numbers but will cover function-ally equivalent piping.
Attachment B to this letter provides the basis for not draining and venting each pipe listed in Attachment A.
In some cases Type C leak testing is required by Appendix J but is not necessary at Byron and Braidwood.
For those cases, an exemption is requested and the basis for the request is provided.
We believe that the attachments provide the information necessary to complete NRR's review of our integrated leak rate testing plans..If additional information is required to close the SER Outstanding Item, please contact this office.
One signed original and fifteen copies of this letter and the attachment are provided for your review and approval.
Very truly yours, OO F. G. Lentine Nuclear Licensing Administrator 1m Attachments 8304250148 830419 6067N PDR ADOCK 05000454 E
PDR i
D ATTACHMENT A Portions of Systems that will not be vented and drained during the ILRT and Containment Isolation valves that will not receive a Type C Test.-
SYSTEM PENETRATION, LINE # & CONT. ISOL. VLVS M-PRINT 1)
RHR System IPC-68 (lRH01BA-12"), IPC-75 (1RH01BB-12")
RHR Pump Suctions -MOV-8701A & B, MOV-8702A & B M-62-1 2)
SX System-IPC-7 (ISX06BB-16"), IPC-9 (ISX07FB-16")
IPC-14 (ISX07FA-16"), IPC-15 (ISX06BA-16")
M-42-5 4
SX Inlet and Outlet to RCFC SX water coils
- MOV-SX016A&B, MOV-SX027A&B 3)
MS System IPC-77 (1MS01BD-30"), IPC-78 (IMS01BA-30")
IPC-85 (IMS01BB-30"), IPC-86 (1MS01BC-30")
M-35-1, 2 S/G Mainsteam Lines - H0V-MS001A, B, C & D 4)
FW System IPC-76 (lFWO3DD-16"), IPC-79 (1rWO3DA-16")
IPC-84 (lFWO3DB-16"), IPC-87 (lFWO3DC-16")
M-3 6-1 FW Inlet to S/Gs - HOV-FWC09A, B, C & D 1PC-99 (1FW87CD-6"), IPC-100 (1FW87CA-6")
IPC-101 (1FW87CB-6"), IPC-102 (lFW87CC-6")
Aux FW Inlet to S/Cs - A0V-FWO35A, B, C & D 6-IFWO37A, B, C & D 5)
M-52-1 FP Containment Inlet Line - A0V-FP010 & ADV-FP011 6)
CC System IPC-48 (ICC03E-3"), IPC-22 (ICC05BA-3")
M-66-1 Excess Letdown HX Inlet & Outlet - ADV-CC9437A & B 7)
SI System -
iPC-26 (ISIO8D-3") Cent Chg SI Line M-61-2,3,4,6 MOV-SI8801A & B, SI8815, A0V-SI8843-IPC-66 (ISIO4B-12"), RHR Hot Leg Inj MOV-SI8840 1PC-50 (ISIO5BA-8"), IPC-51 (ISIO5BB-8")
RHR Cold Lcg Inj. MOV-SI8809A & B 1PC-59 (1SIO3BA-4") MOV-S18802A, SI Hot Leg Inj IPC-73 (1SIO3BB-4") MOV-ST8802B, SI Hot Leg Inj IPC-60 (ISI18C-4") MOV-SI8835, SI Cold Leg Inj 8)
-(N. Sys t em IPC-37 (ICV 43A-2") ICV 8348, ICV 8346 Loop Fill Hdr M-6 4-1,2,3 1PC-71 (ICV 09D-3") MOV-CV8105, MOV-CV8106 Chg Hdr IPC-33, 53 '(lCV14EA, B, C, D-2") MOV-CV8355A, B, C & D, CV8368A, B, C & D RCP Seal Inj
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l ATTACHMENT B Bssis For Not.0 raining and Venting Portions of
, Systems and For Not. Performing Type C Valve Tests Reference ('1):
D. G. Eisenhut letter to L. 0. DelGeorge dated September 30, 198.l'~
1)
The Residual Heat Removal (RHR) system's pump suction lines, penetrations 1PC-68 and 1PC-75.
The RHR; pumps take suction from the RCS through these lines to remove core decay heat.
s This system falls under the' proilsion of Appendix J Section III A.l.d: - " Systems that are required to maintain the plant in a safe condition dur'ing the test shall die operable in their normal mode, and need not be vented".
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The RHR Pump suction line isolation valves are MOV-RH8701A and B and c
MOV-RH8702A'and'B..
The valves do not fall under any of the three capplicablevdefin'itions in Appendix J,Section II.H, for containment isolation valves requiring Type C tests.
The valves remain closed s
thrugh the entire Leakage Design Basis Accident scenario.
In a post-accident condition, the suction side of the RHR pumps is continuously water covered by the pressure head of the containment sump.
Consequently, these valves are not relied upon to perform a containment isolation function, and therefore, Appendix J does not require that they be tested.
(This determination was confirmed by the NRC for Zion in refeyence6(1)^.
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.The SX syste s's Inlet andr6utlet lines to the Reactor Containment Fan Cooler (RCFC) Tssenti~al-Service Water Cdils.
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3 During norma 2<and accident operation, pssential service wat.er flow is provided to the RCFC coils)
This'systemf' alls under.the provision of Appendix J,Section III.A.l.d: '! Systems that are normally filled with water and operating under post-acc'ident canditions, such as the containment;hett removal system, need not be vented."
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- The RCFC isolation valves MOV-SX016A and B and-MOV-SX027A and B do not
- f fall under any -of.the three applicable definitions in Appendix J,
- W Section~'II.H,:fo~r containment? isolation valves requiring Type C tests.
Jhe valves receive a confirmatdry,~open signal.on SI actuation and I'emain open through the accident.
The coils 'and piping: inside contain-I 9
ment. meet-theorequirements' of-ASME Code Section III,. Class 3 and are
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Theynare qualified analytically to withstand.the tested to~ Class 2.
i dynamic effect of the-Loss of Coolant. Accident concurrent with the
...l Design-Basis seismic event.y The SX system inside containment can M therefore be. considered a closed system with respect-to the RCS and containment atmosphere under post-accident conditions.
Consequently, the valvescare not relied upon to perform a containment isolation function,sa'd therefore, Appendix J does not require that they be 4
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Th.e MS.' system's: Steam Generator to Turbine main steam lines 1PC-77, f 'flPC-78,,lPC-85, and 1PC-86.
The; Main Steah Lines ~ transfer the steam from the steam generators to
- W thelturbine?
The main / steam system is neither a part of the' Reactor containment atmosphere 1lunder 'postCoolant System.pressupe boundary nor is it.
~doesnotneed-to'.beve'ntedandVdha-LOCAconditions;therefore,theline
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ined during the ILRT.
c The MainJteam is'olation valves' HOV-MS001A, B, C and D do not fall 1
under any of the three applicable defintions in Appendix J, Section II2H, for containment isslation. valves. requiring' Type C tests.- They receive an isolationWsignal on Safety Injection actuation which is termed Main Steam Isolation.) The intent of: Main Steam Isolation is to minimize primary system!cooldo'wn and maintain secondary system water inventory.- These valves are not relied upon to perform a containment y [% -
isolation function, and therefere, Appendix J does'not require that
-they.be: tested.
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ThefFWisystems'smainfeedwaterlinesandAuxiliaryfeedwatbrlines, t
. penetrations 1PC-76'; 1PC-79, 1PC-84, 1PC-87, 1PC-99, IPC-100, 1PC-101, A ',p
'and 1PC-102.
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- These Fe$dwater lines normally transfer feedwater to the steam N
- generators on'the secondary side of the steam generator tubes.
On a Safety Injection'the main feedwater system is isolated and the auxi-f liarydfeedwate,r valvesLopin to provide flow to the steam generators.
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The Main Feedwater and Auxiliary Feedwater systems are neither part of l
the: Reactor Coolant System Pressure Boundary nor are they open directly iO to the Containment atmosphere under post-LOCA conditions.
They do not
{+o need.to be vent'ed?and drained during the ILRT.
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.. The Main Feedwater Isolation valves HOV-FWOO9A, B, C and D do not fall
.under-the three applicable definitions in1 Appendix J for. containment
. isolation. valves requiring' Type C tests.
They close upon receipt of a Feedwater Isolation signal.
The intent of.Feedwater Isolation is to 1minimizeLprimary cooldown and to avoid overfilling the steam genera-
. tors.- Auxiliary Feedwater isolation valves-A0V-FWO35A, 8, C and D and.
'FWO37A,-B,fC and D open to provide Auxiliary Feedwater flow to.the.
steam generators under most post-accident conditions.
Consequently, these valves are not relied upon to perform a containment isolation function, and therefore, Appendix J~does not require that s
they be tested.
- 15) -Thel Fire Protection (FP) system's containment inlet line, penetration 1PC-34.
This pipeline supplies water to numerous fire hose stations inside containment.
This system falls under the provision of Appendix J,
-Section III.A.l.: " Systems that are required to maintain the plant-in
.a safe condition-during,the test shall be operable in their normal mode, and need not be vented."
Isolation of the FP header.to the containment for venting.and. draining has the potential of increasing the severity.of' damage due to a fire in containment.
For this reason.
the FP.line will not be vented and drained.
However, the containment isolation-valves A0V-FP010 and A0V-FP0ll.will be closed during an ILRT tocminimize theLpossibility of inleakage-of water.
The. Fire Protection System in the Auxiliary Building and Containment
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has been built-to-ASME Code Section III, Class 3.
The minimum static pressure maintained outtlde the FP containment isolation valves A0V-FP010 and A0V-FP011 is 100 psig.
While the Fire Protection system components are not safety-related, the system is designed to high
. reliability standards.
Also, the safety-related Essential Service Water system can'be cross-ti'ed to'the FP system to provide a back-up water source.
Therefore, the fire protection system effectively
.. serves as a-seal water system to the FP isolation valves, in i
accordance with Section III.C.3 of Appendix J.
Because the fire protection system is a. closed system inside U
containment-which is unlikely toJrupture, and because the penetration L
is water sealed, Type C testing ise not required.
(This determination was confirmed by the NRC fo'r Zion in reference (1).)
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The'Comparent: Cooling (CC) System's Excess Letdown HX Inlet and Outlet L11nes,-penetrations 1PC-48 and 1PC-22.
=These lines supply CC water to and return CC water from the Excess
' Letdown Heat Exchangers.
The Excess Letdown Heat:Exchangers and all the' associated CC piping inside containment has been built to ASME LCode Section III, Class 2.
In addition, the piping is protected from LOCA missiles.
This piping is neither a part of the RCS pressure boundary nor is it open directly to the containment atmosphere under-post-LOCA conditions.
This system is therefore considered a closed
' system, and venting and draining is not necessary during an ILRT.
,The safety-related component' cooling system maintains a static pressure.of 100 psig outside the CC containment isolation valves CC9437A and CC94378.
.Therefore, the component cooling system effectively serves-as a seal water: system in'accordance with Section III.C.3 of Appendix J.
Because the' component cooling system is a closed system inside containment which is unlikely to rupture, and because the penetration is water sealed, Type C testing is not required.- (This determination was confirmed by the NRC-for Zion in reference (1).)
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The Safety Injection (SI) System injection lines:
a)
_ Centrifugal Charging Pu.'o SI'line to RCS Cold Legs'lPC-26 b).
RHR Pump SI line to RCS Hot Legs 1PC-66 c)
RHR Pump SI line to RCS Cold' Legs IPC-50 and 51 d)
SI Pump SI line~to RCS Hot Legs 1PC-59 and '73 e)
SI Pump.SI'line to RCS Cold Legs 1PC-60 These lines are normally filled with water and are required to be operated.during post-accident conditions.
In addition, they may be considered lines that are required to maintain the plant in a safe condition during-the test.
Therefore, they need not be vented according to Appendix ~J,~Section III.A.l.(d) during an ILRT.
These injection line isolation valves do not fall'under any of the three' applicable definitions in Appendix J,Section II.H, for containment isolation valves requiring Type C tests.
During the various modes of ECCS operation (cold leg injection, cold leg recirculation, simultaneous hot and cold leg recirculation), the configuration of the lines will be as follows:
Either 1)- The lines will be passing injection water to the RCS Cold Legs at'a minimum pressure of 200 psig.
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The lines ~to the_ Hot Leg injection path will be isolated by the outboard isolation valve which is sealed with a minimum
-injection pressure of 200 psig.
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The lines will be passing injection water to both the Hot
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Legs and the Cold. Legs at a minimum pressure of 200 psig.
Consequently, the valves are not relied upon-to perform a containment isolation function, and therefore, Appendix J does not require that they be tested.
8)
The Chemical and Volume Control (CV) system's charging, loop fill header-and seal injection lines, penetrations 1PC-71, 1PC-37, 1PC-33, and 1PC-53, respectively.
.The charging and-loop fill headers fall under the provision of Appendix J,Section III.A.l.d:
Systems that are required to maintain the plant in afsafe condition during that. test shall be operable in their normal mode, and need not be vented."
These systems must remain
. operable to provide make-up capability for maintaining reactor-coolant inventory.
.In addition, draining'and venting of these lines would.
i require draining of the reactor _ coolant loops.
The seal injection lines' fall under the' provision of Appendix J,Section III.A.1.d:
'" Systems'that are normally' filled with water and operating under post-
. accident condition...need not be vented."
Since.these lines are part of the reactor coolant pressure boundary and may be open to the containment atmosphere under post-accident condition, Type C testing of"their isolation valves (listed in Appendix A) is required by' Appendix J.
Commonwealth Edison hereby requests an exemption from Type C testing of~these valves, on the-following basis:
The charging and loop fill header lines are isolated during a LOCA and are sealed with the discharge pressure of the
-Centrifugal Charging pumps (approximately 2400 psig) external to the containment.
For the duration of the accident a pressure greater than that of the peak containment pressure can be maintained.
Similarly, the seal ~ injection flow is supplied by the centrifugal charging pumps at.acpressure greater than the-peak containment accident pressure.
- Therefore, there is no possibility of containment leakage through lthese
- penetrations.
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