ML20094A954

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Safety Evaluation Supporting 840702 Exemption from Certain Requirements of 10CFR50.54(o) & App J Permitting MSIV Leakage Rate Testing at 23 Psig
ML20094A954
Person / Time
Site: Pilgrim
Issue date: 07/02/1984
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20093B950 List:
References
NUDOCS 8408060172
Download: ML20094A954 (4)


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)o UNITED STATES NUCLEAR REGULATORY COMMISSION O,.f-y

.Ie WASHINGTON, D. C. 20555 gv [

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION APPENDIX J REVIEW PILGRIM NUCLEAR POWER STATION DOCKET NO. 50-293

1.0 INTRODUCTION

Appendix'J to 10 CFR Part 50, relative to primary reactor containment leakage testing for water-cooled power reactors, was published on February 14, 1973.

By a generic letter dated August 7, 1975 (1), the NRC requested the Boston Edison Company (BECo/ licensee) to review its

. containment leakage testing program at Pilgrim for compliance with the requirements of Appendix J.

BECo responded to that reouest on October 10, 1975 (2). Subsequently, NRC staff positions were developed relative to Appendix J and those positions were applied during our reviews of the October 10, 1975 submittal and BEco's subsequent submittals (3,4,7) in response to our requests for additional information (5,6).

?.0 EVALUATION The licensee's submittals (2,3,4,7) were reviewed by the Franklin Pesearch Center (FRC), our consultant, which reported its findings and the bases for e

them in Technical Evaluation Report (TER) No. C5257-40 dated May 5, 1981 (8).

A draft copy of that-TER was provided to BECo en April 28, 1981 (9), and the licensee responded with clarifying information en September 15, 1981 (10).

This infonnation was also reviewed by FRC and the results of its evaluation are provided in TER C-5257-548 dated April 12, 1982 (11).

The NRC staff has reviewed the FRC evaluations and concurs in the findings in TER C5257-40, as modified and supplemented in TER C5257-548.

Based on our review of the attached technical evaluation reports, we conclude that:

(1) The licensee's testing of TIP ball valves satisfies the requirements of Appendix J with reoard to the TIP penetrations. An exemption from the requirements is therefore unnecessary.

(2) The licensee's interpretation of the discussion in TER C5257-40 regarding the conservative assumption to be applied when correcting integrated leakage rates for the "as is" condition is correct.

The conservative assumption need not be applied when it can be proven and documented that leakage is internal to the containment. An exemption from the Appendix J requirements is unnecessary.

8408060172 840702 DR ADOCK 05000

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4 (3) Testing of the main steam isolation valves at 23 psig by pressurizing between the inboard and outboard valves i Wacceptable.

Anexemption for Appendix J requirements is necessary a d should be authorized; j

(() "alves in lines terminating below the level of'the suppression pool do

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nct require Type.C testing; therefore, an< exemption from Appendix J reaufrements.is unnecessary.

(5) The intent %f Appendix J is satisfied and no exemptfon'is required where the following valves of penetration X-9A are Type C tested, j

'provided that valves 301-99, 1201-81, and 1201-82 are exposed to test pressure:

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Feedwater valves 6-58A and 6-62A

.1 RCIC valve A0-1301-50 J

CRD valve 301-95 RWC0 valve M0-1201-80

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(6) Testing of standby liquid control squib valves 1106A and B 1n lieu of checL(valve 1101-5 is acceptable because the intent of Appendix J is achieved and because this testing more closely approximates potential accident leakage. An exemption from the requirements ofl Appendix J is unnecessary.

(7) Type C testing of the motor-operated isolation valves of the core spray system (M0-1400-24A and B and -25A and B) is an acceptable

' substitute for testing the core spray check valves, provided that' emergency procedures require shutting the isolation valves upon deterMnation of the absence of flow in either portion of the system and that the system is periodically tested for integrity. An execption from the requirements is urnecessary.

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(8) Re' verse direction Type C testing of conteinment isolatfor.; gate valves is acceptable where these valves'are TyperA tested in the' direction of accident p'ressure and the other isola ion Malves in each line are Type Ctestedinthedirectionofaccidert} pressure./Thissituationapplies s

to appro'ximately 11 gate valves.. M exemptQ'n from requirements of Appendix J is unnecessary.

(9)

Containment airlocks should be tested in accordance with the October 22, 4

1980 revision of Section III'.D.2'of Appe.ridix J.

The licensee initially requested an exemption from testing the airlocks every six months at a pressure not, less than Pa (45 psig). However, the licensee subsequently int.brmed the staff that the plant procedures now include such testing. An exemption is unnecessary.

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.,. 3.0 Conclusions o

Leakage rate testing of the main steam isolation valves at 23 psig is

- acceptable and an appropriate exemption from Appendix J requirements should be issued.. All of the other BEco exemption requests have either been withdrawn or they have been found unnecessary.

Principal Contributors:

Peter Hearn and Paul Leech Dated:

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References 1.

NRC generic letter to licensees regarding implementation of Appendix J to 10 CFR Part 50, August 5, 1975.

2.

Letter responding to NRC from Boston Edison Company (J.E. Howard),

October 10, 1975.

3.

Letter from Boston Edison Company (J.E. Howard) providing additional information to NRC (D.L. Ziemann), January 27, 1976.

4.

Letter from Boston Edison Company (J.E. Howard) providing additional information to NRC (D.L. Ziemann), June 4, 1976.

5.

Letter from NRC (D.L. Ziemann) to 3oston Edison Company (J.E. Larson),

July 23, 1976.

6.

Letter from NRC (T.M. Novak) to Boston Edison Company (G.C.

Andognini), August 12, 1980.

Letter from Boston Edison Company)(A.V. Morisi) providing additional 7.

information to NRC (T.A. Ippolito, October 27, 1980.

8.

Franklin Research Center Technical Evaluation Report, TER-C5257 40, May 5, 1981.

9.

Letter from NRC (T.A. Ippolito) to Boston Edison Company (A.t. Morisi),

enclosing Safety Evaluation Report and draft Technical Evaluation Report, April 28, 1981.

10.

Letter from Boston Edison Company)(A.V. Morisi) providing further information to NRC (T.A. Ippolito, September 15, 1981.

11. Franklin Research Center Technical Evaluation Report, TER-C5257-548, April 12,1982, p-

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