ML20093C056
| ML20093C056 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 04/12/1982 |
| From: | Delgaizo T Franklin Research Ctr, Franklin Institute |
| To: | Huang Y Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20093B950 | List: |
| References | |
| CON-NRC-03-79-118, CON-NRC-3-79-118, TAC 43804, TASK-A-04, TASK-A-4, TASK-OR TER-C5257-548, NUDOCS 8204150347 | |
| Download: ML20093C056 (17) | |
Text
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- to C5257-548 j
TECHNICAL EVALUATION REPORT CONTAINMENT LEAKAGE RATE TESTING BOSTON EDISON COMPANY (A-00 PILGRIM UNIT 1 NRC DOCKET NO. 50-293 FRC PROJECT CS257 NRC TAC NO. 43804 FRC ASSIGNMENT 1 f NRC CONTRACT NO. NRC-03-79-118 FRC TASK 548 Prepared by Franklin Research Center Author: T. J. DelGaizo 20th and Race Street Philadelphia, PA 19103 FRC Grouc Leader: T. J. DelGai:c f
Prepared for Nuclesr Regulatory Commission Washington, D.C. 20555 Lead NRC Engineerf Y. S. Huang April 12, 1982 This report was prepared as an account of work sponsored by an agency of the United States Government. Neither the United States Government nor any agency thereof, or any of their empicyees, makes any warranty, expressed or implied, or assumes any legal liability or responsibility for any third party's use, or the results of such use, of any information, apparatus, product or process discicsed in this report, or represents that its use by such third party would not infringe privately owned rights.
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TER-C5257-548 CONTENTS
'Section Title Page 1
BACKGROUND.
1 2
EVALLATION CRITERIA.
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-3 TECHNICAL EVALUATION 3
3.1 Requests for Exemption froen the Requirements of Appendix J.
3 3.1.1 Traveling Incore Probe Penetrations.
3 3.1.2 Local Leak Rate Testing.
4 3.1.3 Penetration X-9A 5
3.1.4 Standby Liquid Control Check Valve... -..
8 3.1.5 Core Spray System Check Valves.
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CONCLUSIONS.
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REFFJ.INCES.
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I TER-C5257-542 FOREWORD t
This Technical Evaluation Report was prepared by Franklin Research Center under a contract with the U.S. Nuclear Regulatory Com:nission (Office of Nuclear Reactor Regulation, Division of Operating Reactors) for technical assistance in support of NRC operating reactor licensing actions.
The technical evaluation was conducted in accordance with criteria established by the NRC.
Mr. T. J. DelGaizo contributed to the technical prephration of this report through a subcontract with WESTEC Services, Inc.
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TER-C5257-548 1.
BACKGROUlO On May 5, J.981, FRC published' a Technical Evaluation Report (1)
(TER-C5257-40)- relating to the implementation of 10CFR50, Appendix J, f
Containment M akage Testing, at Pilgrim Unit 1 in accordance with a contract to provide; technical support services to the U.S. Nuclear Regulatory Commission (NRC).
The report provided technical evaluations of outstanding requests for exemption from the requirements of Appendix J covering a period dating back to mid-1975.
It was later used by the NRC as the basis for a Safety Evaluation Report (SER) entitled " Compliance with 10CFR50, Appendix J" [2}.
In a letter response to the SER/TER, dated September 15, 1981 [3], Boston Edison Company (BEC) sub=itted additional information and clarifications in support of previous requests for exemption from the requirements of Appendix J for Pilgrim Unit 1.
The purpose of tnis report is to provide technical cvaluatic:.s of.each of the issues identified in Reference 3 in order to complete the review of implementation of Appendix J at Pilgrim Unit 1.,,
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EVALUATION CRITERIA Tne same criteria were applied to these evaluations as were used in TER-C5257-40 [1].
The evaluation criteria identified in TER-C5257-40 follow:
Code of Federal Regulations, Title 10, Part 50 (10CFR50), Appendix J, containmant Leakage Testing, was specified by the NRC as containing the criteria for the tec4nical evaluations. Where applied to the evaluations in this report, the criteria are either referenced or briefly stated, wnere necessary, in support of the determinations.
Furthermore, in recognition of plant-specific conditions that could lead to requests f or exemption not explicitly covered by the regulation, tne NRC directed that the technical review constantly.3mphasize the intent of Appendix J, that potential containment atmospheric leakage paths be identified, monitored, and maintained below established litrits.
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TECmiICAL EVALUATION 3.1 REQUESTS FOR EXEMPTION FROM TdE REQUIREMENTS OF APPENDIX J In Reference 3, BEC submitted additional information and clarifications in support of previously submitted requests for exemption from the requirements cf Appendix J which were technically evaluated in TER-C5257-40.
Technical cvaluations of each of the issues identified in Refsrence 3 are provided in the following paragraphs.
3.1.1 Traveling Incore Proce Penetrations
's In TER-CS257-40, it was concluded that traveling incore probe (TIP) isolation valves should be tested in accordance with Appendix J.
In response to he TER, BEC stated in Reference 3:
Since tne NRC/FRC SER denying our request fo. exemption on this subject was cased on a misunderstanding of the number of lines involved, clarification was provided as follows:,_
PNPS has only 4 lines and each line equals 3/8" diameter.
We believe this information will alleviate your concerns of the potential for leakago of containment because of the number of lines involved' In addition we will test the TIP Ball Valves in accordance with Appendix J and add these four ball valves to the hchnical Specification List cf Containment Isolation Valves.
Evaluation TIP tubes penetrate the reactor vessel but, since they are sealed, the TIP system does not communicate with either the reactor coolant or the containment atmosphere.
Consequently, only one isolation valve is required for containrent isolation of TIP penetrations.
The automatically actuated
. ball valves are installed for this' purpose.
BEC nas stated that these ball valves at Pilgrim Unit 1 will be tested in accordance with Appendix J and that they will be added to the list of containment isolation valves in the Technical Specifications.
This testing satisfies the Appendix J requirement for testing of TIP penetrations.
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T TEE-05:57-545 Conclusion BEC's testing of TIP ball valves satisfies the requirements of Appendix J wita regard to the TIP penetrations.
No exemption from Type C testing is necessary.
3.1.2 Local Leak Rate Testitig In TER-C5257-40, it was concluded that BEC's proposal to conduct local leak rate tests before the integrated leakage tests was acceptacle provided th at the total measured local leak rate is conservatively assumed to be out of the containment when integrated leakage rate results are corrected to estaolisn tne "as is" condition.
In Reference 3, BEC provided tne following statement:
Per cur discussion ve understand the following to be acceptable:
Local Leak Rate Testing will be conductec prior to Integrated Leak Rate Testing and the "as found" Local Leak Rate testing results that cannot be proven and documented as inside containment leakage will be added to the Integrated Leak Rate test results to determine "as is" containment leakage.
Evaluation BEC's understanding of the application of the conservative casamption that local leakage be assumea to be out of the containment is correct.
Local
'loakage need not be assumed to be in a direction out of the containment if it can be proven and documented that the leakage is actually internal to the containment.
For the purpose of determining the "as is" condition, leakage which cannot be,shown to be inside containment should be conservatively
&Osumed to be leakage out of the containment.
Crnclusion BEC's interpretation of the discussion of TER-C5257-40 regarding the conservative assumption to be applied when correcting integrated leakage rates fe: the "as is" condition is correct.
The conservative assumption need rot be cpplied when it can be proven and documented that leakage is internal to the containment. BON Franklin Research Center
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TER-C3257-546 3.1.3 Penetration X _9A,A Throughout the correspondence between the NRC and BEC regarding the implementation of 10CFR50, Appendix J, several requests for exemption have been related to penetration X-9A, a feedwater containment penetration.
These cxemption requests have involved both the feedwater line and the connecting lines of the rea'ctor core isolation cooling (RCIC) system, the control rod
' drive (CRD) hydraalic system, and the reactor water clean-up (RWCU) system.
Tne pl ping configuration is shown in Figure 1.
Technical evaluations of the cutstanding requests relative to penetration X-9A are provided below along with the status of each line in order to present a co=prehensive summary of tne testing required for this penetration.
Feedwater Svstem In Reference 4, BEC withdrew a previous request to test the feedwater check valves with water in lieu of air as required by Appendix J.
BEC stated that the feedwater check valves had been modified to ecntain sof t ' seats ~and '- ~
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that they were being tested with air as required by Appendix J.
RCIC Svstem In Reference 4, BEC also withdrew a previous request to exempt RCIC check valve AO-1301-50 from the Type C testing requirements of Appendix J.
BEC stated that this valve also had oeen modified and that it will be tested in
-cccordance with Appendix J.
CRD Hydraulic System In Reference 3, BEC clarified previous requests that had been submitted prior to a modification of this piping.
BEC stated that valve 301-95 is now the primary centainment isolation valve and that it is Type C tested in cccordance with Appendix J.
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TER-25257-54S J
RXC*J Svste In Reference 4, EEC requested an exemption from Type C testing of check valve 1201-81, stating that this valve was installed to limit reverse flow until downstream motor-operated isolation valves were shut.
In TER-C5257-40, it was concluded that an exemption for check valve 1201-81 was. inappropriate and that the valve should be Type C tested in accordance with Appendix J.
In Reference 3, BEC clarified its request, stating that the motor-operated contain=ent isolatica valve previously referenced was valve MD-1201-80.
BEC further stated:
Valve MO-1201-80 receives automatic isolation signals in the event such isolation is recuired.
No operator action would be required to acco=plish this isolation.
In addition, this piping run is seis=ically qualified through to the 1201-80 valve and the 1201-80 valve is tested in accordance with Appendix J.
Evaluation As can be seen in Figure 1, penetration ~X-SA contain's sevefal brahch- ~~ ~ ~ ~' - -
lines outside containment.
Feedwater check valve 6-58A is the isolation valve inside containment for all branch lines.
This valve mutt be tested in cccordance with Appendix J, and BEC has stated that this testing is new Deing performed.
One containment isolatica valves outside containment are 6-62A (feedwater line), AO-1301-50 (RCIC line), 301-95 (CRD line), and 1201-81 (RWCU line).
BIC has stated that these valves are being Type C tested in accordance with Appendix J with the exception of 1201-81.
BEC has p ;cposed to Type C test MO-1201-60 in lieu of 1201-81.
REC has stated that valve 1201-81 is not currently air-testacle.
MD-12 01-80, however, is a globe valve, automatically shut on a containment isolation signal, and the piping run through valve MD-1201-80 is seismically qualified.
Consequently, the intent of Appendix.T is satisfied if valve MO-1201-80 is Type C tested in accordance with Appendix J provided that the poundaries of this test include valves 1201-81 and 1201-82.
By exposing valves
'1201-81'and 1201-82 to the air test pressure, any leakage to the outside atmospnere through tnese valves (e.g., steam pacxing loans or oody-to-connet
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f TER-05257-545 ceci leaks) will be accounted for in the total Type C leakage which must eatisfy tne acceptance criteria of Appendix J.
Similarly, the Type C test of valve 301-95 should encompass valve 301-99.so that any external leakage from this valve is also accounted for.
Conclusion In view of the foregoing discussion, it is concluded that the intent of Appendix J is satisfied and no exemption is required if the following valves are Type C *ested in accordant.;e with Appendix J, provided that valver 301-99, 1201-81, and 1201-d2 are exposed to the Type C test pressure:
o Feedwater valves 6-58A and 6-62A o
RCIC valve AO-1301-50 o
CRD valve 301-95 o
RWC*J valve MO-1201-80.
3.1.4 Standby Licuid Control Check Valve In TER-C5257-40, it was concluded that check valve 1101-15 should be Type C tested, rejecting the, position that an exemption should be granted because tne valve was inside containment and could not be tested.
In Reference 3, BEC suc=itted tne following additional information regarding this request:
We propose that in lieu of testing the 1101-15 valve, the 1106-A and 110 6-B (Squib) ' valves be tested.
These valves are explosive-actuated injection valves which provide high assurance of opening when needed and ensure that boron will not leak into the reactor even when the pu=ps are being tested.
Conversely, the design assures that reactor coolant will not leak past these valves into the SBLC system.
Evaluation The standny liquid control system is a reactivity addition system which is designed to operate only in the event that the control rod system is not offective in shutting down the reactor.
This system was not installed to combat the consequences of a loss-of-coolant-accident (LOCA), nor is it cxpected to function under LOCA conditions.
Consequently, BEC has proposed to test the containment isolation capability of the system in its normal post-LOCA O 30 Franklin Research Center A Dhanson of The FWR NNe m._
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TER-C5257-548 configuration with the explosive squib valves in their unfired and shut posi-tion.
FRC believes that tnis proposal is in keeping with the Appendix J requirement that penetrations be tested in as close as possible to their normal post-accident condition.
Checx valve 1101-15 is located inside the containment.
A second check valve (1101-16) is located directly outside containment.
The next barrier to leakage beyona the second check valve (discounting normally locked-open manual valve 1101-23) are the explosive squib valves (1106A and B).
Consequently, total penetration leakage can be accounted for by pressurizing the piping between ci.eck valves 1101-15 and 1101-16 and venting the piping upstrea= of the squio valves.
In this way, any leakage past the seat of check valve 1101-16 will be either terminated by the squib valves or accounted for as test leakage.
Furthermore, testing in this manner will provide leakage results wnich more closely approximate actual penetration leakage under accident conditions.
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Conclusion Testing of squib valves 1106A and B in lieu of check valve 1101-15 is ac eptable because the intent of Appendix J is achieved and because this testing wi:.1 more closely approximate potential accident leakage.
No exe=ptica from tne requirements of Appendix J is necessary.
3.1.5 Co.e Spray System Check Valves In CER-CS257-40, it was concluded that check valves AO-1400-9A and B should be tested in accordance with Appendix J, rejecting the position that replacing these valves with air-testable valves was not justified because the check valves function only to limit reverse flow until downstream motor-cperated isolation valves are shut.
In Reference 3, BEC clarified its position, stating:
The air operator on the 1400-9A&B valves was not used for active isolation purposes but merely for stroke testing the valve.
The air
. operator has since been disabled and is no longer operable.
In lieu of
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TEE-C5257-54I testing the 1400-9A&B valves, the MO-1400-24A&B and the MO-1400-25A&B valves are tested in accordance with Appendix J and are listed as Primary Containment Isolation Valves.
Since the Core Spray System is an ECCS System it is required to funct-idn post accident (valves are open during an accident).
For that reason, normal valve lineup for this system is with the MD-1400-25A&B valves closed during normal operation.
Evaluation in TER-C5257-40, it was recognized that the core spray system will be normally operating under post-accident conditions and, in this mode, leakage of containment air to the outside atmosphere is precluded oy tne pressurized system liquid.
The concern was tnat a single active f ailure in the core spray system (e.g., f ailure of one pump to start) could result in the core spray eneen valves being relied upon to prevent the escape of containment air.
However, tne additional information tnat vals es MO-1400-24A and B and -25A and B are being Type C tested in accordance with Appendix J requires further analysis.
Cheer. valves 1400-9A and B are located inside containment.
The motor-operated isolation valves MO-1400-24A and B and -25A and B are located outside containment.
In this came, any leakage past the eneck valves will cause recirculatien leakage into the containment (body-to-bonnet seal leakage) or will be accounred for by tne Type C test of the =ctor-operated valves (in the case of eneck valve seat leakage).
Consequently, assuming that a core spray pump f ails to start, hype C testing of the two motor-operated isolation valves in tne line will oe effective in achieving the cbjectives of Appendix J, provided that the motor-operated valves in that line are shut.
Valves MO-1400-25A and B are normally shut.
Valves MO-1400-24A and B are normally open.
At the start of an accident, all four valves will be signaled to open 'in order to initiate core spray.
Consequently, should a core spray pump fail to start, both the motor-operated isolation valves in that line will be open and will remain open until shut by an operator.
Since a sir.gle active failure has already been imposed in this situation, it can be assumed that the appropriate flow transmitter (PT-1461A or B) will MN Franklin Research Center A Dumason of The Frwuen ensymee
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TER-C5257-54E function and tnat an operator will be able to determine that core spray flow nas not oeen initiated in one of the lines. Whether or not the operator will isolate the affected line prior to 'the escape of containment air is contingent upon (1) tne ability of the system to retain its liquid inventory during the period when the motor-operated valves are open and (2) a procedural requirement tnat the operator shut the valves once it has been determined that there is no flow.
Since the core spray system is an engineered-safety-f eature system, it is periodically tested for both operability and integrity.
The periodic operability checks are intended to ensure that the system can be relied on to function on signal.
At the same time, however, in the unlikely event that the system or a portion of the system fails to function, the integrity check helps to guarantee sufficient time for the operator to recognize the problem and to isolate. the affected portion by shutting the appropriate motor-operated isclation valves.
Conclusion In view of the above discussion, it is concluded that Type C testing of tne motor-operated isolation valves of the core spray system (MO-1400-24A and B and -25A and B) is an acceptacle substitute for testing the check valves, provided tnat (1) energency procedures require shutting the isolation valves 1pon determination of the absence of flow in either portion of tne system and
.(2) the system is periodically tested for integrity, thus ensuring that the operator has sufficient _ time in which to shut the isolation valves before containment air begins to leak out.
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TEA-CE257-546 4.
CONCLUSIONS Technical evaluations of each of the issues identified by BEC in Ref erence 3 for Pilgrim Unit 1 have been performed.
The following conclusions cre provided:
JEC's testing of TIP ball valves satisfies the requirements of o
Appendix J with regard to the TIP penetrations.
No exemption from the requirements of Appendix J is necessary, BEC's interpretation of the discussion of TER-C5257-40 regarding the o
conservative assumption to be applied when cor ting integrated leakage rates for the "as is" condition is co.ect.
The conservative acsu=ption need not be applied when it can be proven and docu=erted tha t leakage is internal to the containment.
The intent of Appendix J is satisfied and no exe=ption is required o
wnere the following valves of penetration X-9A are Type C tested, provided that valveh 301-99, 1201-81, and 1201-82 are exposed to tes_
pressure:
Feedwater valves 6-58A and 6-62A RCIC valve AO-1301-50 CRD valve 301-95 RWCU valve MO-1203-80.
Testing of standby liquid control squib valves 1106A and B in lieu of o
eneck valve 1101-5 is acceptacle cecaure the intent cf Appendix ; is acnieved and cecause this testing more closely approximates potential accident leakage.
No exemption from the requirements of Appendix J is necessary.
Type C testing of the motor-operated isolation valves of the core o
spray system (MO-1400-24A and B and -25A and B) is an acceptable suostitute for testing the core spray check valves, provided that emergency precedures require shutting the isolation valves upon determin'ation of the absence of flow in either portion of the system and that the system is periodically tested for integrity. -7(}931s e-U.J Franklin Research Center A tw n es Tw. Fr.n
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REFERENCES l.. Franklin Research Center Technical Evaluation Report TER-C5257-40, Containment Leakage Rate Testing, Boston Edison Company, Pilgrim Unit 1 May 5, 1981 2.
Nuclear Regulatory Co:rsission Safety Evaluation Report
" Compliance with 10CFR50, Appendix J" April 28, 1981 3.
A. V. Morisi (BEC)
Le tter to T. A.
Ippolito (NRC)
September 15, 1981 4.
A. V. Morisi (BEC)
Letter to T. A.
Ippolito (NRC)
Octo:er 27, 1980 1.
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