ML20101H674
| ML20101H674 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 03/27/1996 |
| From: | POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | |
| Shared Package | |
| ML20101H660 | List: |
| References | |
| NUDOCS 9604010068 | |
| Download: ML20101H674 (62) | |
Text
_
Attachment I to JPN-96-011 PROPOSED TECHNICAL SPECIFICATION CHANGES (JPTS-96-003)
New York Power Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 DPR-59 9604010068 960327 PDR ADOCK 05000333 p PDR
l JAFNPP TABLE OF CONTENTS (Cont'd) 6.16 Process Control Program (PCP) 258b 6.17 Offsite Dose Calculation Manual (ODCM) 258b l
6.18 Major Modifications to Radioactive Liquid, Gaseous, and 258c i Solid Waste Treatment Systems 6.19 Postaccident Sampling Program 258e 6.20 Primary Containment Leakage Rate Testing Program 258e 1 7.0 References 285 l
l l
1 1
Amendment No. 7,22,93,130, iv
t JAFNPP L!ST OF TABLES Table lit!g Eage 4.2-8 Minimum Test and Calibration Frequency for Accident Monitoring 86 Instrumentation 4.6-1 Snubber Visual Inspection Interval 161 4.6-2 Minimum Test and Calibration Frequency for Drywell Continuous 162a Atmosphere Radioactivity Monitoring System 4.7-1 (DELETED) 210 4.7-2 (DELETED) 211 1 3.12-1 (DELETED) 244a 3.12-2 (DELETED) 244a 3.12-3 (DELETED) 244a 4.12-1 (DELETED) 244a 4.12-2 (DELETED) 244a 4.12-3 (DELETED) 244a 6.2-1 Minimum Shift Manning Requirements 260a 6.10-1 Component Cyclic or Transient Limits 261 l
l l
l A ..endment No. 20,22,92,111,130,134,150,173,180,181,210,218, vi
JAFNPP ,
i 4.0 JLASES l
A. This specification provides that surveillance activities requirement will be identified as an exception. An example necessary to insure the Limiting Conditions for Operation are of an exception when the test interval is not specified in the met and will be performed during the OPERATIONAL regulations is the Note it' Specification 6.20, " Primary !
CONDITIONS (modes) for which the Limiting Conditions for Containment Leakage Rate Testing Program," which states
! Operation are applicable. Provisions for additional "The provisions of Specification 4.0.B do not apply to the surveillance activities to be performed without regard to the test frequencies specified in the Primary Containment .,
applicable OPERATIONAL CONDITIONS (modes) are provided Leakage Rate Testing Program." This exception is provided ;
in the individual Surveillance Requirements. because the program already includes provisions for extension of intervals. . l B. Specification 4.0.B establishes the limit for which the specified time interval for Surveillance Requirements may be C. This specification establishes the failure to perform a extended. It permits an allowable extension of the normal Surveillance Requirement within the allowed surveillance '
surveillance interval to facilitate surveillance scheduling and interval, defined by the provisions of Specification 4.0.B, as consideration of plant operating conditions that may not be a condition that constitutes a failure to meet the suitable for conducting the surveillance (e.g., transient OPERABILITY requirements for a Limiting Condition for conditions or other ongoing surveillance or maintenance Operation. Under the provisions of this specification, '
activities). It also provides flexibility to accommodate the systems and components are assumed to be OPERABLE length of a fuel cycle for surveillances that are performed at when Surveillance Requirements have been satisfactorily each refueling outage and are specified with a 24 month performed within the specified time interval. However, -
surveillance interval, it is not intended that this provision be nothing in this provision is to be construed as implying that ,
used repeatedly as a convenience to extend surveillance systems or components are OPERABLE when they are found intervals beyond that specified for surveillances that are not or known to be inoperable although still meeting the performed during refueling outages. The limitation of this Surveillance Requirements. This specification also clarifies specification is based on engineering judgement and the that the ACTION requirements are applicable when recognition that the most probable result of any particular . Surveillance Requirements have not been completed within i surveillance being performed is the verification of the allowed surveillance interval and that the time limits of conformance with the Surveillance Requirements. The limit the ACTION requirements apply from the point in time it is '
on extension of the normal surveillance interval ensures that identified that a surveillance has not been performed and not the reliability confirmed by surveillance activities is not at the time that the allowed surveillance was exceeded.
significantly reduced below that obtained from the specified Completion of the Surveillance Requirement within the a surveillance interval. The exceptions to Specification 4.0.B allowable outage time limits of the ACTION requirements ;
are those surveillances for which the 25% extension of the restores compliance with the requirements of Specification interval specified does not apply. These exceptions are 4.0.C. However, this does not negate the fact that the stated in the individual Technical Specifications. The failure to have performed the surveillance within the allowed requirements of regulations take precedence over the surveillance interval, defined by the provisions of Technical Specifications. Therefore, when a test interval is Specification 4.0.B, was a violation of the OPERABILITY.
specified in the regulations, the test interval cannot be requirements of a Limiting Condition for Operation that is extended under the provisions of 4.0.B, and the surveillance subject to enforcement action. Further, the failure to Amendment No. 83,1 SS,198, 227, 30e
JAFNPP 4.0 BASES - Continued C. Continued C. Continued d.
, perform a surveillance within the provisions of Specification Surveillance Requirements do not have to be performed on 4.0.B is a violation of a Technical Specification requirement inoperable equipment because the ACTION requirements and is, therefore, a reportable event under the requirements - define the remedial measures that apply. However, the of 10 CFR 50.73(a)(2)(i)(B) because it is a condition Surveillance Requirements have to be met to demonstrate .
prohibited by the plant Technical Specifications. that inoperable equipment has been restored to OPERABLE status.
If the allowable outage time limits of the ACTION .
requirements are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or a shutdown is required to comply with ACTION requirements, a 24-hour D. This specification establishes the requirement that a!!
allowance is provided to permit a delay in implementing the applicable surveillances must be met before entry into an ACTION requirements. This provides an adequate time limit OPERATIONAL CONDITION or other condition of operation to complete Surveillance Requirements that have not been specified in the Applicability statement. The purpose of this performed. The purpose of this allowance is to permit the specification is to ensure that system and component completion of a surveillance before a shutdown is required to OPERABILITY requirements or parameter limits are met comply with ACTION requirements or before other remedial before entry into an OPERATIONAL CONDITION or other measures would be required that may preclude completion of specified condition associated with plant shutdown as well a surveillance. The basis for this allowance includes as startup.
consideration for plant conditions, adequate planning, availability of personnel, the time required to perform the Under the provisions of this specification, the applicable surveillance and the safety significance of the delay in Surveillance Requirements must be performed within the completing the required surveillance. This provision also specified surveillance interval to ensure that the Limiting provides a time limit for the completion of Surveillance Conditions for Operation are met during initial plant startup Requirements that become applicable as a consequence of or following a plant outage.
OPERATIONAL CONDITION (mode) changes imposed by ACTION requirements and for completing Surveillance When a shutdown is required to comply with ACTION Requirements that are applicable when an exception to the requirements, the provisions of this specification do not requirements of Specification 4.0.C is allowed. If a apply because this would delay placing the facility in a lower surveillance is not completed within the 24-hour allowance, CONDITION of operation.
the time limits of the ACTION requirements are applicable at that time. When a surveillance is performed within the 24-hour allowance and the Surveillance Requirements are not met, the time limits of the ACTION requirements are applicable at the time the surveillance is terminated.
Amendment No. iS, Si, SS, 100,152,182,227, 30f
JAFNPP 4.7 (cont'd) 3.7 (cont'd)
(2) During testing which adds heat to the suppression -
pool, the water temperature shall not exceed 10*F above the normal power operation limit specified in (1) above. In connection with such testing, the pool temperature must be reduced to below the normal power operation limit specified in (1) above within 24 ~
hours.
(3) The reactor shall be scrammed from any operating ,
condition if the pool temperature reaches 110*F.
Power operation shall not be resumed until the pool temperature is reduced below the normal power operation limit specified in (1) above.
(4) During reactor isolation conditions, the reactor pressure vessel shall be depressurized to less than 200 psig at normal cooldown rates if the pool temperature reaches 120'F.
- 2. Primary containment integrity shall be maintained at all times 2. a. Perform required visual examination and leakage rate when the reactor is critical or when the reactor water testing of the Primary Containment in accordance temperature is above 212*F, and fuel is in the reactor with the Primary Containment Leakage Rate Testing vessel, except while performing low power physics tests at Program.
atmospheric pressure at power levels not to exceed 5 MWt.
- b. Demonstrate leakage rate through each MSIV is s 11.5 scfh when tested at = 25 psig. The testing frequency is in accordance with the Primary Containment Leakage Rate Testing Program.
- c. Once per 24 months, demonstrate the leakage rate of 10AOV-68A,B for the Low Pressure Coolant injection system and 14AOV-13A,B for the Core Spray system to be less than 11 scfm per valve when pneumatically tested at a 45 psig at ambient temperature, or less than 10 gpm per valve if hydrostatically tested at =
1000 psig at ambient temperature.
Amendment No. 44, 166
s a
d e
t e
le D
n e _
e _
B )
e 6 v 7 a 1 P H is P 5 7 N e F 7 6 g 1 1 a _
A h p _
J g t u x o e r N
(
h t
7 _
6 1
s .
e g
a P
o N
t n
e m
d n
e m
A
JAFNPP 4.7 BASES (cont'd)
-assumption of no holdup in the secondary containment, resulting in a direct release of fission products from the primary containment through the filters and stack to the environs. Therefore, the specified primary containment leak rate and filter efficiency are conservative and provide additional margin between expected offsite doses and 10CFR100 guidelines.
The leakage rate testing program was originally based on NRC guidelines for development of leak rate testing and surveillance schedules for reactor containment vessels.
Containment structural integrity is currently verified with visual inspections and containment leak tightness is verified by the leakage rate surveillance testing described in the JAFNPP Primary Containment Leakage Rate Testing Program. This Program as implemented meets the -
requirements of Option B of 10 CFR 50, Appendix J (16),
and Regulatory Guide 1.163 (13), with the following approved exemptions that are described in more detail within the Program:
- 1. The Type C exceptions listed on Table 4.7-2,
" Exception to Type C Test", as of the date of issuance of Amendment 194 (F o 1993). B. Standby Gas Trs-in,ent System and C. Secondary Containment
- 2. Valves which are sealed with fluid trom a seal system, such as the liquid in the suppression Initiating reactor building isolation and operation of chamber are not required to be Type C tested. This the Standby Gas Treatment System to maintain at exemption was approved by the NRC in the original least a 1/4 in. of water vacuum within the Technical Specifications (SR 4.7.A.2.c(3)). secondary containment provides an adequate test of the operation of the reactor '
- 3. The MSIVs are tested at a pressure less than P, and 2: 25 psig, with a leakage rate acceptance criteria of s 11.5 scfh per valve. This exemption was approved by the NRC in the original Technical i Specifications (Table 4.7-2).
1 l .
Amendment No. 97,134, 194
JAFNPP Pages 198 through 213 Have Been Deleted Amendment No. ' 9, 9? , ' ? S, ? 50, ' 72, 198 (Next page is 214)
_____--. _ _ _ _ , . . - ~ _ _ _ - _ ~ _ _ _ . _ _ . - . _ . . - . _ _ . _ _ , . _ _ . . _ _ _ . . _ _ _ _ _ . . _ . _
. I e .
JAFNPP 6.19 POSTACCIDENT SAMPLING PROGRAM A program shall be established, implemented, and maintained which will ensure the 4 capability to obtain and analyze reactor coolant, radioactive iodines and particulates 1 I
in plant gaseous effluents, and containment atmosphere samples under accident conditions. The program shallinclude the following:
A) Training of personnel, )
B) Procedures for sampling and analysis, C) Provisions for maintenance of sampling and analysis 6.20 PRIMARY CONTAINMENT LEAKAGE RATE TESTING PROGRAM A program shall be established to implement the leakage rate testing of the Primary Containment as r3 quired by 10 CFR 50.54 (o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, " Performance-Based ,
Containment Leak-Test Program", dated September 1995. j A. The peak Primary Containment internal pressure for the design basis loss of coolant accident (P,), is 45 psig.
B. The maximum allowable Primary Containment leakage rate (L.), at P., shall be 1.5% of primary containment air weight per day.
C. The leakage rate acceptance criteria are:
- 1. Primary containment leakage rate acceptance criteria is s 1.0 L,. ,
During unit startup following testing in accordance with this program, the leakage rate acceptance criteria are s 0.60 L, for the Type B and Type C tests and s 0.75 L, for the Type A tests;
- 2. Airlock testing acceptance criteria are: j i
- a. Overall airlock leakage rate is s 0.05 L, when tested at a P,,
- b. For each door seal, leakage rate is s 120 scfd when tested at a P,.
D. The provisions of Specification 4.0.B do not apply to the test frequencies specified in the Primary Containment Leakage Rate Testing Program.
E. The provisions of Specification 4.0.C are applicable to the Primary Containment Leakage Rate Testing Program.
l Amendment No. 430, 258e
7.0 REFERENCES
(1) E. Janssen, " Multi-Rod Burnout at Low Pressure," ASME Paper (9) C.H. Robbins, " Tests of a Full Scale 1/48 Segment of the-62-HT-26, August 1962. Humbolt Bay Pressure Suppression Containment,"
GEAP-3596, November 17,1960.
(2) K.M. Backer, " Burnout Conditions for Flow of Boiling Water in ~
Vertical Rod Clusters," AE-74 (Stockholm, Sweden), May (10) " Nuclear Safety Program Annual Progress Report for Period 1962. Ending December 31,1966, Progress Report for Period Ending December 31,1966, ORNL-4071." .
(3) FSAR Section 11.2.2.
(11) Section 5.2 of the FSAR.
(4) FSAR Section 4.4.3.
(12) TID 20583, " Leakage Characteristics of Steel Containment (5) 1.M. Jacobs, " Reliability of Engineered Safety Features as a _ Vessel and the Analysis of Leakage Rate Determinations."
Function of Testing Frequency," Nuclear Safety, Vol. 9, No. 4, July-August 1968, pp 310-312. (13) Regulatory Guide 1.163, " Performance-Based Containment Leak-Test Program", dated September 1995.
(6) Deleted (14) Section 14.6 of the FSAR.
(7) 1.M. Jacobs and P.W. Mariott, APED Guidelines for Determining Safe Test intervals and Repair Times for (15) ASME Boiler and Pressure Vessel Code, Nuclear Vessels, Engineered Safeguards - April 1969. Section Ill. Maximum allowable internal pressure is 62 psig.
(8) Bodega Bay Preliminary Hazards Report, Appendix 1, Docket (16) 10 CFR Part 50, Appendix J, " Primary Reactor Containment 50-205, December 28,1962. Leakage Testing for Water-Cooled Power Reactors, Option B -
Performance Based Requirements", Effective Date October 26, 1995 (17) Deleted Amendment No. 190,227, 285
t l
Attachment 11 to JPN 96-011 SAFETY EVALUATION FOR PROPOSED TECHNICAL SPEClElCAIlON CHANGES (JPTS-96-003) l l
1 I
i I
New York Power Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 DPR-59
l Attachment il to JPN-96-011 SAFETY EVALUATION f
Page 1 of 12 l 1. DESCRIPTION OF THE PROPOSED CHANGES i
! -1 j These proposed Technical Specification (TS) changes support adoption of the primary )
l containment leakage rate testing requirements of Option B to 10 CFR 50, Appendix J l (Option B), and clarify the numerical value of the allowable containment leakage rate (L ) as 1.5 percent per day. The specific changes are 9 follows:
l 1. Page iv, Table of Contents, add 6.20, " Primary Containment Leakage Rate Testing '
l Program" and "page 258e" to the Table of Contents.
- 2. Page vi, Ust of Tables, denote that Table 4.7-2, " Exception to Type C Tests," is l deleted. The revised text reads:
"4.7-2 (DELETED) 211"
- 3. Bases 4.0.B page 30e, insert the following after the current discussion:
"The exceptions to Specification 4.0.B are those surveillances for which the 25%
extension of the interval specified does not apply. These exceptions are stated in the l Individual Technical Specifications. The requirements of regulations take precedence l over the Technical Specifications. Therefore, when a test interval is specified in the ,
- regulations, the test interval cannot be extended under the provisions of 4.0.B, and the l surveillance requirement will be identified as an exception. An example of an l exception when the test interval is not specified in the regulations is the Note in l Specification 6.20, " Primary Containment Leakage Rate Testing Program," which I states "The provisions of Specification 4.0.B do not apply to the test frequencies l specified in the Primary Containment Leakage Rate Testing Program." This exception is provided because the program already includes provisions for extension of intervals."
Note: This change results in the last five unes of the second column being moved to Page 30f.
- 4. Pages 166 through 174, delete the following SRs:
l l 4.7.A.2.a (1) through (10),
l- 4.7.A.2.b (1), (2) i 4.7.A.2.c (1) through (5),
l 4.7.A.2.e (1) through (6), '
l 4.7.A.2.f.
i ,
I l
l
7._. _
Attachment 11 to JPN-96-011 SAFETY EVALUATION Page 2 of 12
- 5. Page 166, insert the folbwing new SRs:
"4.7.A.2.a Perform required visual examination and leakage rate testing of the Primary Containment in accordance with the Primary Containment Leakage Rate Testing Program."
4.7.A.2.b Demonstrate leakage rate through each MSIV is s 11.5 scfh when tested at a 25 psig. The testing frequency is in accordance with the Primary Containment Leakage Rate Testing Program.
6.- Page 167, add note stating that pages 167 through 175 have been deleted. Add note under the page number stating "(Next Page is 176)." !
- 7. Page 172, relocate SR 4.7.A.2.d (1) to page 166 and renumber as SR 4.7.A.2.c. Make editorial changes to improve readability. The revised SR reads:
"4.7.A.2.c Once per 24 months, demonstrate the leakage rate of valves 10AOV- ,
68A,8 for the Low Pressure Coolant injection system and 14AOV-13A,B for the Core Spray system to be less than 11 scfm per valve when pneumatically tested at 2 45 psig at ambient temperature, or less than 10 gpm per valve if hydrostatically tested at 21000 psig at ambient temperature."
- 8. Page 174, delete asterisked notes for one-time exemptions from the Type A,B and C testing reqJirements of 10 CFR 50 Appendix J.
- 9. Page 175, delete the intentionally blank page.
- 10. Bases 4.7.A, Page 194, delete the primary containment leakage rate testing discussion !
which starts on the first column, second paragraph. Replace with:
"The leakage rate testing program was originally based on NRC guidelines for development of leak rate testing and surveillance schedules for reactor containment vessels. Containment structural integrity is currently verified with visual inspections and containment leak tightness is verified by the leakage rate surveillance testing described in the JAFNPP. Primary Containment Leakage Rate Testing Program. This Program as implemented meets the requirements of Option B of 10 CFR 50 Appendix J (16) and Regulatory Guide 1.163 (13), with the following approved exemptions that are described in more detail within the Program:
- 1. The Type C exceptions listed on Table 4.7-2, " Exception to Type C Tests," as of the date of issuance of Amendment 194 (July 29,1993).
l l ;
- i. . !
Attachment 11 to JPN-96-011 SAFETY EVALUATION I Page 3 of 12 l
- 2. Valves which are sealed with fluid from a seal system, such as the liquid in the suppression chamber are not required to be Type C tested.
This exemption was approved by the NRC in the original Technical l Specifications (SR 4.7.A.2.c(3)).
- 3. The MSIVs are tested at a pressure less than P, and ;t 25 psig, with a leakage rate acceptance criteria of s 11.5 scfh per valve. This exemption was approved by the NRC in the original Technical Specifications (Table 4.7-2)."
- 11. Page 198, Change page "209" to page "213," and change next page from "210" to "214" to reflect the deletion of page 211 through 213b discussed in item 13.
- 12. Page 210, Delete the intentionally blank page.
- 13. Page 211 through 213b, Table 4.7-2 " Exception to Type C Tests," delete pages and relocate Table in its entirety to the Containment Leakage Rate Testing Program.
- 14. Page 258e, Administrative Controls, add new section 6.20 entitled " Primary Containment Leakage Rate Testing Program." The new section reads:
"6.20 Primary Containment Leakage Rate Testing Proaram )
A program shall be established to implement the leakage rate testing of the Primary Containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B, i as modified by approved exemptions. This program shall be in accordance with the l guidelines contained in Regulatory Guide 1.163, " Performance-Based Containment Leak-Test Program," dated September 1995.
A. The peak Primary Containment intemal pressure for the design basis loss of coolant accident (P ), is 45 psig.
1 B. The maximum allowable Primary Containment leakage rate (L,), at P , shall be l 1.5% of primary containment air weight per day.
]
C. The leakage rate acceptance criteria are:
- 1. Primary containment leakage rate acceptance criteria is s 1.0 L,.
During unit startup following testing in accordance with this program, the leakage rate acceptance criteria are s 0.60 L, for the Type B and Type C tests and s 0.75 L, for the Type A test; 1
Attachment 11 to JPN-96-011 SAFETY EVALUATION Page 4 of 12
- 2. Airlock testing acceptance criteria are:
- a. Overall airlock leakage rate is s 0.05 L, when tested at a P.,
l
- b. For each door seal, leakage rate is s 120 SCFD when pressurized to 2 P,.
l 3. MSIV leakage rate acceptance criteria is s 11.5 sclh for each MSIV when tested at 2 25 psig D. The provisions of Specification 4.0.B do not apply to the test frequencies specified in the Primary Containment Leakage Rate Testing Program.
E. The provisions of Specification 4.0.C are applicable to the Primary Containment j Leakage Rate Testing Prograrn."
- 15. Page 285, delete Reference 13 as it no longer applies under Option B, and replace with reference to Regulatory Guide 1.163. The revised Reference 13 reads:
l
"(13) Regulatory Guide 1.163, " Performance-Based Containment Leak-Test Program," dated September 1995."
I'
- 16. Page 285, revise Reference 16 to reflect new revisions to 10 CFR 50 Appendix J. The revised reference reads:
"(16) 10 CFR Part 50 Appendix J, " Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors, Option B-Performance Based Requirements," Effective date October 26,1995.
- 17. Page 285, delete Reference 17 as it no longer applies under Option B, and replace with " Deleted."
- 11. PURPOSE OF THE PROPOSED CHANGES i The proposed changes to the TS support adoption of the primary containment leakage rate testing requirements of Option B at the FitzPatrick plant, and clarify the numerical value of the allowable containment leakage rate (L.) as 1.5% per day.
The original FitzPatrick TS were written prior to the effective date of the 10 CFR 50 l Appendix J regulation. Therefore, to ensure adequate primary containment leak rate j testing, many of the requirements of the draft Appendix J requirements were incorporated directly into the Specifications. Exceptions were included as part of the l
l
l' Attachment ll to JPN-96-011 SAFETY EVALUATION !
Page 5 of 12 l
'~ initial issuance of the TS. Consequently, primary containment leck rate testing i requirements duplicate those contained in the draft Appendix J (Option A), with approved exemptions.
[ To simplify implementation of Option B, and prevent conflicts with the TS currently .
i based on Option A, the Authority proposes to delete the following SRs: i 4.7.A.2.a(1) through (10) Type A testing requirements - Option A Section Ill.A. I
- 4.7.A.2.b(1) and (2) Type B testing requirements - Option A Section Ill.B. ,
4.7.A.2.c(1), (2) Type C testing requirements - Option A Section Ill.C i 4.7.A.2.c(3) Approved exemption that eliminates Type C testing for l valves that are sealed from a seal system, such as the l water in the suppression chamber. This exemption is i l retained and relocated to the Program. ;
4.7.A.2.c.4 Reference to Table 4.7-2, " Exception to Type C tests."
The Table is relocated to the Program.-
4.7.A.2.e(1), (2) Periodic retest schedule requirements - Option A Section l Ill.D l 4.7.A.2.e(3) through (4) Requirements for Type B tests of airlocks and testing of lt airlock seals. These SRs were exemptions from Option A testing requirements that are no longer required for :
implementation of Option B. Acceptance criteria is relocated to proposed Specification 6.20.
, 4.7.A.2.e(5) Type C retest schedule - Option A Section Ill.D.
l 4.7.A.2.f Containment modification requirements - Option A Section ,
IV.A i The Authority proposes to relocate Table 4.7-2, " Exception to Type C Tests," from the :
TS to the Program. This table lists the approved exemptions to Appendix J for Type C tests at the FitzPatrick Plant, and is still applicable to Option B.
l The above SRs and Table are replaced by: (1) New SR 4.7.A.2 (a) which requires . ,
visual examination and leak rate testing of the Primary Containment in accordance with the Program; and (2) New SR 4.7.A.2 (b) which incorporates an existing exemption for Type C testing of Main Steam Isolation Valves (MSIV) directly into the TS for consistency with References 2 and 3. A description of the Program, including plant specific leakage limits, is contained in new Specification 6.20. Regulatory Guide 1.163 (Reference 1) is incorporated, by reference, into new Specification 6.20 as required by Option B, Paragraph V.B.1.
Implementation of Option B requirements will be controlled under the Primary l Containment Leakage Rate Testing Program (the Program), in accordance with the j requitaments of Option B, Regulatory Guide 1.163 (Reference 1), and exemptions
Attachment il to JPN-96-011 SAFETY EVALUATION Page 6 of 12 from Option A currently approved by the NRC for the FitzPatrick plant. The proposed TS changes are consistent with guidelines provided in NUREG-1433 (Reference 2) and NRC letter dated November 2,1995 (Reference 3), to the extent practicable.
There are differences between the FitzPatrick TS and Reference 2 relating to Containment Systems that will be resolved in our upcoming Improved Standard Technical Specifications conversion effort. These differences do not adversely affect the TS changes required to support implementation of Option B at the FitzPatrick plant.
Ill. SAFETY IMPLICAllONS OF THE PROPOSED CHANfaES This section discusses the safety implications of the TS changes relating to implementation of Option B at the FitzPatrick Plant and the clarification of the L, numerical definition.
l 1. Option B Imolementation The testing requirements of 10 CFR 50, Appendix J, ensure that leakage through the primary containment, including systems and components that penetrate the primary containment, does not exceed the allowable leakage rate values specified in the TS and bases. This ensures that an adequate primary containment boundary is maintained during and after an accident, thereby assuring that the primary containment function assumed in the safety analyses is maintained. !
A revision to 10 CFR 50, Appendix J, to allow a performance-based approach to l containment leakage rate testing became effective on October 26,1995. The revision added Option B " Performance Based Requirements" to Appendix J to allow licensees to voluntarily replace the prescriptive testing requirements of Appendix J with testing ;
requirements based on both overall and individual component leakage rate i performance. Option B allows plants with satisfactory Integrated Leak Rate Testing (ILRT) performance history to reduce the Type A testing frequency from three tests in ten years to one test in ten years. For Type B and Type C tests, the testing frequency can be reduced based on the leak rate test history of each component. The Authority has elected to perform Type A, Type B and Type C containment leak rate testing on a performance basis.
Regulatory Guide 1.163 (Reference 1) was issued by the NRC Staff as an acceptable method for implementing Option B. It states that NEl 94-01 (Reference 4) provides ;
! methods acceptable to the NRC staff for complying with Option B, with the four !
l exceptions listed in Section C of the Regulatory Guide. The Authority will comply with !
l the methods outlined in the Regulatory Guide, and no attemate methods are proposed for implementing Option B at the FitzPatrick plant. 4 r
Attachment ll to JPN-96-011 SAFETY EVALUATION Page 7 of 12 The adoption of a performance-based primary containment leakage rate testing program does not change the method by which leakage rate testing is performed. The tests will continue to be performed at full pressure (P.) or greater, with the exception of existing NRC approved exemptions. Plant specific limits for allowable leakage rates (L ) and required test pressure (P,) are retained in the proposed TS and are not changed as a result of adopting Option B testing requirements. Testing methods will continue to be in accordance with existing leak rate testing requirements, as modified by exemptions previously approved by the NRC. !
These changes do not alter the plant design, only the frequency of measuring primary containment leakage. Therefore, the proposed changes do not directly result in an increase in containment leakage. However, decreasing the test frequency can increase the probability that a large increase in containment leakage could go ,
undetected for an extended period of time. NUREG-1493, " Performance- Based '
Containment Leak-Test Program, Final Report," (Reference 7) made the following observations with regard to the decreased test frequency: ;
= Reducing the Type A (ILRT) testing frequency from the current three per ten years to one per 20 years was found to lead to an imperceptible increase in risk. The estimated increase in risk is small because ILRTs identify only a few potential leakage paths that can not be identified by Type B and Type C testing, and the leaks that have been found by Type A tests have only been marginally !
above existing requirements. Given the insensitivity of risk to containment leakage rate, and the small fraction of leakage detected solely by Type A :
testing, increasing the interval between ILRT testing has minimal impact on l public risk. t a While Type B and C tests identify the vast majority (greater than 95 percent) of all potential leakage paths, performance-based attematives to current local !
leakage testing requirements are feasible without significant risk impacts. The risk model used in NUREG-1493 suggests that the number of components ,
tested would be reduced by about 60 percent with less than a three-fold !
increase in the incremental risk due to containment leakage. Since under existing requirements leakage contributes less than 0.1 percent of overall accident risk, the overall impact is very small.
t Option B states that specific exemptions to Option A of Appendix J, that have been formally approved by the NRC or AEC, are still applicable to Option B if necessary, unless specifically revoked by the NRC. The following exemptions to Option A will be retained in the Option B Program:
- 1. The Type C exceptions listed on Table 4.7-2, " Exception to Type C Tests," as of the date of issuance of Amendment 194 (July 29,1993). .
w- ._ _ ,, -- -,.m r . - - - - ,. w-
l Attachment 11 to JPN-96-011 SAFETY EVALUATION Page 8 of 12
- 2. Valves which are sealed with fluid from a seal system, such as the liquid in the suppression chamber are not required to be Type C tested. This exemption f was approved by the NRC in the original Technical Specifications (SR l 4.7.A.2.c(3)).
l
- 3. The MSIVs are tested at a pressure less than P, and a 25 psig, with a leakage rate acceptance criteria of s 11.5 scfh. This exemption was approved by the
! NRC in the original Technical Specifications (Table 4.7-2).
l l These exemptions focus on the testing methodology aspects of Append 'and are i unaffected by the adoption of Option B testing frequency requirements. A list of l approved exemptions will be contained in the Bases of the FitzPatrick TS, Section l 4.7.A. The details of these exemptions will be contained in the Program.
l l Changes to the Program will be controlled in accordance with the requirements of 10 l CFR 50.59, " Changes, tests and experiments." Thus, a determination of whether Program changes require prior NRC approval will be performed. In addition,10 CFR 50 Appendix J Option B requires Licensee compliance with containment leakage rate testing requirements as stated in the regulation, and included by reference in the proposed TS. Changes to the Program that conflict with the requirements of Option B, or documents referenced in Specification 6.20, require an exemption per 10 CFR -
50.12. The combination of the 10 CFR 50.59 change process and the 10 CFR 50.12 exemption process assure proper control of changes to the Primary Containment Leakage Rate Testing Program.
l Current SR 4.7.A.2.d (1) requires pneumatic or hydrostatic leakage rate testing of the l LPCI and Core Spray injection testable check valves. These valves are pressure isolation valves that separate the high pressure reactor coolant system from the low pressure LPCI and Core Spray systems. The leakage test required by SR 4.7.A.2.d (1) is not a requirement of 10 CFR 50 Appendix J, therefore, it is not relocated from the TS. Editorial changes to improved readability are made to the SR, and it is moved to page 166 and renumbered as SR 4.7.A.2.c.
Based on the above discussion, removal of the containment leakage rate testing details, except for plant specific limits, from the TS is acceptable. The proposed TS i and the Program comply with Regulatory Guide 1.163 (Reference 1) requirements and l contain sufficient controls to ensure that the primary containment structural integrity is inspected and maintained, and that leakage is limited to values assumed in the plant safety analyses. Required surveillances will continue to be performed in accordance with TS, written procedures, and instructions auditable by the NRC Primary containment leakage rate requirements continue to remain an integral part of .i i FitzPatrick plant operation. The changes to current SR 4.7.A.2.d.(1) are editorial in i nature and do not change any TS requirement.
I I
i Attachment il to JPN-96-011 SAFETY EVALUATION Page 9 of 12 ;
1 l
l 2. Clarification of the Numerical Definition of La l l
I Proposed Specification 6.20 defines the value of the allowable containment leakage rate (L,) as 1.5 percent of primary contcinment air weight per day. This is a clarification of the numerical value of L, for the FitzPatrick plant. This clarification was previously submitted as part of a proposed TS amendment (Reference 5), and subsequently withdrawn (Reference 6) because additional evaluation was required to l quantify the effects of a 1.5 percent per day leakage rate on safety-related equipment '
located in the reactor building. The Authority has reviewed the environmental qualification of safety-related equipment in the reactor building and has identified two .
I component types that require further evaluation as a result of this clarification.
Appropriate action will be taken to qualify these component types prior to implementation of a 1.5 percent per day allowable leakage rate.
Current SR 4.7.A.2.a (8) defines the Type A acceptance criteria as less than 0.75 L, and not greater than the design leakage rate, Le (0.5%/ day). This SR was contained in I the original TS and was written to support the pre-operational test. The SR is l consistent with the pre-operational leakage rate test requirements of Option A, l paragraph Ill.A.4(b)(2), and conservative with respect to the retest leakage rate i requirement of Option A, paragraph ill.A.5(b)(2), which defines the acceptance critena i as less than 0.75L,. For purposes of establishing Type A, B and C leakage test '
acceptance criteria, the allowable containment leakage rate has been limited to 0.5 weight percent of the contained air volume per day so as not to conflict with SR 4.7.A.2.a (8). This interpretation is conservative with respect to the TS Bases, and the current licensing basis.
This clarification potentially affects the off-site dose consequences of postulated accidents which are directly related to containment leakage rate. The FitzPatrick accident analyses assumed an allowable leakage rate (L ) of 1.5 weight percent per day. The limitation on containment leakage rate ensures that total leakage will not exceed the value assumed in the accident analyses at the peak accident pressure (P,)
of 45 psig. The margin of safety for the off-site dose consequences of postulated accidents directly related to the containment leakage rate is maintained by meeting the 1.0L, acceptance criteria stated in proposed Specification 6.20.
The effects of this clarification are: 1) The value of the As-Left Type A test leakage criteria of 0.75 L, is 1.125 percent per day; 2) The value of the combined Type B and C test leakage acceptance criteria of 0.6 L, is 0.9 percent per day; and 3) The value of the "As-found" Type A test acceptance criteria is 1.5 percent per day (L.). The value of 1.5 percent per day is consistent with the accident analyses, and Option B, and does not constitute an increase in the allowable leakage rates as analyzed in the UFSAR. Therefore, this change does not adversely impact plant safety.
l l
Attachment il to JPN-96-011 SAFETY EVALUATION Page 10 of 12 IV. EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION The Authority has evaluated the proposed TS Amendment and determined that it does ]
not represent a significant hazards consideration. Based on the criteria for defining a significant hazards consideration established in 10 CFR 50.92, operation of the James !
A. FitzPatrick Nuclear Power Plant in accordance with the proposed amendment will j not:
- 1) Involve a significant increase in the probability or consequences of an accident l previously evaluated because: j The proposed changes do not involve a change to the design or operation of the plant.
The systems affected by this proposed TS change are not assumed in any safety analyses to initiate any accident sequence. Therefore, the probability of any accident ;
previously evaluated is not increased by this proposed TS change. The clarification of the allowable containment leakage rate (L ) is consistent with the accident analyses.
There is no change to the consequences of an accident previously evaluated because maintaining leakage within limits assumed in the accident analyses ensures that the dose consequences resulting from an accident are not increased. The proposed TS changes maintain an equivalent level of reliability and availability for all affected :'
systems. The ability of the affected systems associated with maintaining leak rate integrity to perform their intended function is unaffected by the proposed TS changes.
Implementation of these changes will provide continued assurance that specified parameters associated with containment integrity will remain within acceptance limits, and as such, will not significantly increase the consequences of a previously evaluated accident.
1
- 2) Create the possibility of a new or different kind of accident from any accident j previously evaluated because:
The proposed changes allow adoption of those requirements specified in Option B to ;
10 CFR 50, Appendix J, and do not involve a change to the plant design and I operation. As a result, the proposed changes do not affect the parameters or l conditions that could contribute to the initiation of any accidents. The methods of I performing primary containment leakage rate testing are not changed. No new accident modes are created by allowing extended intervals for Type A, B and C testing, or by clarifying the numerical value of the allowable containment leakage rate (L,). No safety-related equipment or safety functions are altered, or adversely affected, as a result of these changes. The proposed changes will not introduce failure mechanisms beyond those already considered in the current plant safety analyses.
Extension of the test intervals, and clarification of the allowable leakage rate, does not contribute to the possibility of a new or different kind of accident or malfunction from those previously analyzed.
4 f Attachment il to JPN-96-011 SAFETY EVALUATION Page 11 of 12
- 3) Involve a significant reduction in the margin of safety because:
The proposed changes affect the frequency of primary containment leakage rate testing, and the numerical definition of the allowable containment leakage rate (L,).
The design of the FitzPatrick plant is not changed. The methodology for test performance is unchanged and Type A, B and C tests will continue to be performed at a P,. The proposed changes provide sufficient controls to ensure that proper maintenance and repairs are performed on the primary containment, and systems and components penetrating the primary containment. The reliability of containment systems assumed to operate in the plant safety analyses is not reduced. The numerical value of L, specified in Specification 6.20 is consistent with the accident analyses, therefore, the dose consequences of any analyzed accidents are not increased. Therefore, the proposed changes provide continued assurance of the leak tightness of the containment without adversely affecting the public health and safety and, as such, will not involve a significant reduction in the margin of safety.
This proposed amendment does not involve a significant relaxation of the criteria used to establish safety limits, a significant relaxation of the bases for the limiting safety system settings or a significant relaxation of the bases for the limiting conditions for operations.
Therefore, based on the criteria established in 10 CFR 50.92(c), the proposed change does not constitute a significant hazards consideration.
V. IMPLEMENTATION OF THE PROPOSED CHANDES implementation of the proposed changes will not adversely affect the ALARA or Fire Protection Programs at the FitzPatrick plant, nor will the changes affect the environment.
The Authority requests NRC approval of this proposed amendment prior to July 1,1996 in order to adopt these changes prior to the upcoming Refuel 11/ Cycle 12 Refueling Outage.
VI. CONCLUSION Based on the discussions above, the adoption of Option B to 10 CFR 50, Appendix J, requirements into the TS will not decrease the effectiveness of containment leakage rate testing. Operating limitations will continue to be imposed, and required surveillances will continue to be performed in accordance with Technical Specifications, written procedures and instructions auditable by the NRC. The assumptions in the FitzPatrick licensing bases are not invalidated by the proposed Technical Specification changes.
The Plant Operating Review Committee (PORC) and the Safety Review Committee (SRC) have reviewed these proposed changes to the Technical Specifications and have concluded that they do not involve an unreviewed safety question, or a significant
i Attachment 11 to JPN-96-011 SAFETY EVALUATION Page 12 of 12 l
hazards consideration, and will not endanger the health and safety of the public.
i Vll. REFERENCES
- 1. Regulatory Guide 1.163, Performance-Based Containment Leak-Test Program, dated September 1995
- 2. NUREG-1433, Standard Technical Specifications, Revision 1, dated April 1995
- 3. NRC Letter to Mr. David J. Modeen (NEI), Regarding the Industry's Proposed Technical Specifications for implementing Opt'on B of Appendix J, dated November 2,1995
- 4. NEl 94-01, Industry Guideline for Implementing Performance-Based Option of 10 CFR 50 Appendix J, Rev. O, dated July 26,1995
- 5. NYPA letter, J.C. Brons to the NRC, dated January 16,1990 (JPN-90-008),
" Proposed Change to the Technical Specifications Regarding Containment Leak Rate Testing Requirements (JPTS-84-012)."
- 6. NYPA letter, R.E. Beedle to the NRC, dated March 31,1992 (JPN-92-016),
" Withdrawal of Amendment Application (JPTS-84-012)."
l 7. NUREG-1493, Performance-Based Containment Leak-Test Program, Final Report, dated September 1995 l
l I
i 4
4
4 Attachment lli to JPN-96-011 MARKUP OF TECHNICAL SPECIFICATION PAGES l
(JPTS-96-003) l l
l f
New York Power Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 DPR-59 l
i I.
I
JAFNPP 1
TAatt OF CONTENTS (cont'd) I E.ASA 6.16 Process Control Program (PCF) 258b 6.17 Offsite Dose Calculation Manual (CDCM) 258b 6.18 Major Modifications to Radioactive Liquid, l Gaseous, and Solid Waste Treatment Systems 258c 6.19 Postaccident Sampling Program 258e f .07 References 285 \
l- Q , p 9 f,.imi. Cod b ! noJ N* N fL 'f I
k JAFNPP LIST OF TABLES ,
Iable Iitle Eage 4.2-8 Minimum Test and Calibration Frequency for Accident Monitoring 86 Instrumentation 4.6 1 Sn~ubber Visual inspection interval 161 4.62 Minimum Test and Calibration Frequency for Drywell Continuous 162a Atmosphere Radioactivity Monitoring System 4.7-1 (DELETED) 210 4.7 2 [ Exception to Type C T (De LE TED) 211 nl 3.12-1 (DELETED) 244a l 3.12 2 (DELETED) 244a '
3.12-3 (DELETED) 244a 4.12 1 (DELETED) 244a l 4.12 2 (DELETED) - 244a l 4.12-3 (DELETED) 244a \,
6.2 1 Minimum Shift Manning Requirements 260a 6.10-1 Component Cyclic or Transient Umits 261 )
Amendment No. .. . , . . . , _, . , _, . . ., . , . . . . . . .,4t&-
vi
. . . J
. _ - . _- _ . - _ _ _ _ _ _ _. _ _ _ _ _._ _ .._ _ m _. - -
~
JAFNPP 4.0 BASES A. This specification provides that swveillance activities C. Continued necessary to inswe the Limiting Conditions for Operation are met and wiu be performed during the OPERATIONAL interval, defined by the provisions of Specification 4.0.B, as a 4
CONDITIONS (moses) for vMah the Limiting Conditions for condition that constitutes a failure to meet the OPERABILITY '
2 Operation are appbcable.'ivovisions for additional survestance requirements for a Limiting Condition for Operation. Under the activities to be performed without regard to the applicable provisions of this specification, systems and components are OPERATIONAL CONDITIONS (modes) are provided in the assumed to be OPERABLE when Surveillance Requirements endsvidual Surveitance Requirements. have been satisfactorily performed within the specified time interval. However, notheng in this provision is to be construed Specification 4.0.B estabhshes the limit for which the specified as implying that systems or components are OPERABLE when D.
time interval for Survestance Requirements may be extended. they are found or known to be inoperable although stiN lt permets an allowable extension of the normal survedlence meeting the Survesitance Requirements. This specification also interval to facilitate survedlance schedadeng and consideration clarifies that the ACTION requirements are appiscable when of plant operating condstions that may not be suitable for Survedlance Requirements have not been completed within the conducting the survetence (e.g., transiiont conditions or other allowed survesuance interval and that the time limits of the ongoing surveitance or maentenance actevities). It also
- ACTION requirements apply from the poent in time it is provides flexibility to accommodate the length of a fuel cycle identified that a survedlance has not been performed and not fi for aurvasances that are performed at each refunding outage at the time that the allowed surveillance was exceeded.
and are especified with a 24 month survedlance interval. It is Completion of the Survedience Requirement within the not intended that this provision be used repeatedly as a allowable outage time limits of the ACTION requirements convenience to extend surveillance intervels beyond that restores compliance with the requirements of Specification specified for swvedlances that are not performed during 4.0.C. However, this does not negate the fact that the failure (
refueling outages. The hmitation of this specification is based to have perforrned the survedlance within the aNowed on engensonne y-t m and the recognition that the most surveillance interval, defined by the provisions of Specification probable restdt of any particular survedience being performed 4.0.B. was a violation of the OPERABILITY requirements of a is the verification of conformance with the Surveitance Limiting Condition for Operation that is subject to enforcement Requirements. The limit on extension of the normal action. Further, the failure _tqJperform a surveillance within the survestance interval ensures that the reliability confirmed by provisions of Specification 4.0.8 is a violation of a Technical i I
surveillance activities is not significantly reduced below that Specification requirement and is, therefore, a reportable event obtamed from the specified survessence interval. < under the requirements of 10 CFR 50.73(a)(2)(iHB) because it I
1 is a condition prohibited by the plant Technical Specifications. q j
C. This specification establishes the failure to perform a j Survedlance Requerement within the allowed surveillance s i g 4 3 mow d b # 5 I- M L Amendment No. 23,1SS, iSS,227 -
- 30e j
I 5 INSERT A:
"The exceptions to Specification 4.0.B are those surveillances for which the 25% extension of the interval specified does not apply. These exceptions are stated in the individual Technical Specifications. The requirements of regulations take precedence over the Technical Specifications. Therefore, when a test interval is specified in the regulations, the test interval cannot be extended under the provisions of 4.0.B, and the surveillance requirement will be identified as an exception. An example of an exception when the test interval is not specified in the regulations is the Note in Specification 6.20, " Primary containment Leakage Rate Testing Program", which states "The provisions of Specification 4.0.B do not apply to the test frequencies specified in the Primary Containment Leakage Rate Testing Program." This exception is provided because the program already includes provisions for extension of intervals."
1 b
A QMEOQ 3 l
l 4.0 BASES - Continued l
Continued C. Continued
( C. ;
if the aNowable outage time Emits of the ACTION requirements Survedlance Requirements do not have to be performed on !
are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> er a shutdown is required to comply inoperable equipment because the ACTION requirements *i with ACTION requwements, a 244 tour aNowance is provided to define the remedial measures that apply. However, the j permit a delay in implementing the ACTION requwements. Surveillance Requirements have to be met to demonstrate that j
This provides an adequate time Emit to complete Surveellence snoperable equipment has been restored to OPERABLE status.
Requirements that have not been performed. The purpose of .
this allowance is to pennit the completion of a survedlance before a shutdown is required to comply with ACTION D. This specification establishes the requirement that all i requirements or before other remedial measures would be applicable survesilences must be met before entry into an required that may preclude completion of a survedlance. The OPERATIONAL CONDITION or other condition of operation i
' basis for this aNowance irwhta= consideration for plant specified in the Applicability. statement. The purpose of this !
t conditions, adequate planning, avadsbetty of personnel, the specification is to ensure that system and component time required to perform the surveillance and the safety. OPERABILITY requirements or parameter limits are met before sognefecance of the delay in completing the required entry into an OPERATIONAL CONDITION or other specified
- survestance. This provision also provides a time limit for the condition associated with plant shutdown as well as startup.
completion of Survedlance Requwements that become applicable as a consequence of OPERATIONAL CONDITION Under the provisions of this specification, the applicable !
(model cheness imposed by ACTION requirements and for Survedlance Requirements must be performed within the !
completing Surveillance Requirements that are appiscable when specified surveillance interval to ensure that the Limiting an exception to the requwements of Specification 4.0.C is Conditions for Operation are met during initial plant startup or ,
allowed. If a survedlance is not completed within the 24-hour following a plant outage. ;
i allowance, the time limits of the ACTION requwements are appbcable at that time. When a surveellence is performed When a shutdown is required to comply with ACTION within the 24-hour allowance and the Surveillance requirements, the provmons of this specification do not apply l Requwements are not met, ths time limits of the ACTION because this would delay placing the facility in a lower requirements are applicable at the time the survestance is CONDITION of operation. :
termensted. j
{
Amendment No. iS, Si, 2",1C^.1S2, t SO, 22L 30f ,
J.7 (contrd) JAFNPP 4 7 (cont'd) d (2) During testing which adds heat to the suppression pool, the wcter temperature shall not exceed ~
IGF Obove the nornal power orcration linit specified in (1) above. In coancetion with such testing, the pcol terperature must be reduced to below the noreal power operation linit specified in (1) above within "" b !
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
(3) The reactor shall be scrammed froin any -
operating condition if the pool tenperature reaches 110F. Power 2 The pri:a:1ry contcinment cperatica shall not be resuned until integrity chall be- de.. T castrated the pcol ter.perature is reduced below DS f 01105'S : I the nor. mal powcr operation lisait specified in (1) ahuve. a. Type A Test (primary Containment Iriteg rct ed (4) Daringreactorisolationconditkons, Leaka9e Itate Test) the reactcr' pressure vessel sha,'ll ha depressuri:cd-to less than 200 psig (1.) Containment inspection et nor..a1 couldosta rates if the' pool chall. he performe.1 an a torperature reaches 120F. prerequisite to the performance of Type A
- 2. Primary containment integrity shall be maintained tests. During the at all tines when the reactor is critical or when period betteceu Ihe l
the reactor water tenperature is above 212cF, and initiation of the feel is in the reactor vessel, except while containuent inspect ion f perfor. ing lowpower physics tests at atuospheric arul the perfen :.ince O L' l
l press :re at pcuer levels not to c::cced 5 Intt. the Type'A t e .:t , .ia repair:: Or ailjuntam nt s shall 1:e made.
Amendment No.16" 166 .
l
1 1
l I
INSERT B:
"4.7.A.2.a Perform required visual examination and leakage rate testing of the Primary Containment in 1 accordance with the Primary Containment Leakage Rate Testing Program. ,
4.7.A.2.b Demonstrate leakage rate through each MSIV is 5 11.5 ccfh when tested at 2 25 psig. The testing j frequency is in accordance with the Primary ,
Containment Leakage Rate Testing Program. l 4.7.A.2.c Once per 24 months, demonstrate the leakage rate of 10AOV-68A,B for the Low Pressure Coolant <
Injection system and 14AOV-13A,B for the Core )
Spray system to be less than 11 scfm per valve j when pneumatically tested at 245 psig at ambient temperature, or less than 10 gpm per valve if hydrostatically tested at 21000 psig at ambient temperature."
'l
JAFNPP 4.7 (cont 8d)
(2.) Closure of containment -
isolation valves for the Type A test shall be accomplished by normal operation and without -
any preliminary exercising.
hq3 c5 I (3. ) The containment test hW g4M conditions stabilize for a period shall of about 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> prior to the start of a leakage rate test.
(4.) Components to be tested as part of the containment shall be vented to the containment atmosphere.
i (5. ) Test methods are to comply with ANSI N4 5.4--1972 paragraph 5 and leak rate calculations will comply with the intent of ANSI N45.4-1972 paragraph 5.
The mass of air in the containment will be calculated hourly and ,
the leak rate determined by a linear least sq uares fit to the mass of air as a function of time.
167 (Nur Pc p 6 l~7
JAFNPP 4.7 (cont'd)
(6.) The accuracy of the Type A test shall be kI verified by a supplemental test as described in Appendix C
}
of ANSI N45.4-1972, or '
the metered addition of air into the containment after the end of the e- Type A test.
(7.) Test Pressure (a . ) An initial test {
shall be performed I, at a 23 psig (Pt, reduced pressure)
- which is greater than 0.50 Pa to measure a leakage rate Ltm.
4 (b.) A second test shall be performed at 4% psig (Pa peak r ?ssure) to measure i leakage rate Lam.
(c.) The leakage characteristics yielded by measurements Ltm and Lam shall establish the maximum allowable test leakage rate Lt of
-ot more than La (Ltm/ Lam) . In the event Ltm/ Lam is greater than 0.7, Lt shall be specified as equal to La 168 VPt/Pa).
JAFNPP 4.7 (cont'd)
(8.) Acceptance Criteria
, Reduced pressure tests. .
(Pt) The leakage rate Cc.JM Ltm shall be less than 0.75 Lt.
f Peak pressure test.
(Pa) The leakage rate Lam shall be less than 0.75 (La) and not greater than IA, which is 0.5 weight percent of the contained air per 24 hr at the test pressure Po.
(9.) Periodic leakage rate test shall be performed at reduced pressure (Pt) or at peak pressure (Pa).
(10.) Additional requirements If any periodic Type A test fails to meet the applicable acceptance criteria the test schedule applicable to subsequent Type A tests will be reviewed and
- approved by the s
Conomission.
If two consecutive periodic Type A tests fail to meet the acceptance criteria, a 169
l l
~
~
JAFNPP l
4.7 tcont'd) l Type A test shen be performed at each plant shutdown for refuelmg or approximately every 18 months, whichever occurs first, until two consecutive Type A tests meet the acceptance criteria.
- b. Type B tests ILocalleak rate testing of contamment ;
penetrations)
D s k I} q (1.) All preoperational and periodic Type B tests shall be performed by local pneumatic pressurization of the contaenment penetrations, either individually or in groups, l at a pressure not less than Pa, and the gas flow to h meentain Pa shall be measured.
(2.) Acceptance criteria The combened leakage rate of all penetrations and valves subject to Type B and C tests shall be less than O.60 La, with the exception of the valves sealed with fluid from a seal system.
\
~
N O _
Amendment No. 1 5,190 i 170
JAFNPP 4.7 (cont'd)
- c. Type C tests C
(1.) Type C tests shall be performed by f #'# 41 ~ local pressurisation. The pressure shall be applied in the same direction -
as that when the valve would be required to perform its safety function, except as listed in Table 4.7-2 unless it can be determined that l the results from the tests for a pressure applied in a different direction will provide equivalent or more conservative results. Each valve to be tested shall be closed by normal operation and without any preliminary exercising or adjustments. ,
(2.) Valves, unless pressurized with fluid from a seal system, shall be pressurised with air or nitrogen at a i pressure of Pa, and the gas flow to maintain Pa shall be measured.
(3.) Valves, which are sealed with fluid from a seal system, such as the liquid in the suppression chamber shall not be tested.
l Amendment No. df , 134 J I I
N '
JAFNPP 4.7 (cont'd)
(4.) See table 4.7-2 for exceptions.
[
(S.) Acceptance criterion - The combined leakage rate for all penetrations and b valves subject to type B and C tests shall be less than 0.60 La. Leakage from containment isolation valves that are sealed with fluid from a seal system may be excluded when determining the combined leakage rate provided that the lastalled isolation valve seal-water system fluid inventory is sufficient to assure the sealing function for at least 30 days. ,
bd.
Other leak rate tests (1) The leakage rate for containment isola- s tion valves 10-AOV-68A, B (penetration X-13A, B) for Low Pressure Coolant '
b* Injection system and 14-A0V-13A, B (penetration X-16A, B) for Core Spray j pga- lbb &
System shall be less than 11 cubic feet J g g per minute per valve (pneumatically G5 9.'?, A .J . c tested at 45 psig with ambaent temper-ature) or 10 gallons per minute per valve (hydrostatically) tested at 1000 i
psig with ambient temperature.
w i f6 134 Amendment No. 7 a ,
- 5 laAetlh .
a baacd e
. o,e n
isy p
uao qei e r l ttT e -
u as gp d re n e etel i h p el re c o ra uc s eehh ydi
. rtts l v t t pa e r s s r ,t e e e e f dass '
t t h eml e teo miar r A ra g rxva soore i
c e ek tf rey p t a t s r pt -
)
d d y f e e e e pn0 t
o T Al s t p ai1 i )
n r .
o e 1 c P (
(
7 .
4 e
r A ,
J 7
7
.f 0
4 -
t n
O e m _
/.< d n
e m
A I
_ _ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ~ - - - - - - - ~ ~ ~ ~
JAFNP 4.7 (cont'd)
])ppbc[c-The third test of each set shall be o< 4L- conductel when the plant is shutdown for the 10-year plant inservice
-Q inspections.
l j Permissible periods for testing. The performance of Type A tests shall be
- limited to periods when the plant -
l facility is nonoperational and
! secured in the shutdown condition under the administrative control and in accordance with the plant safety procedures.
(2) Type B tests, (except tests for air-locks), shall be performed during each reactor shutdown for refueling, or other convenient intervals, but in no case at intervals greater than 2 years.
(3) Type B tests of airlocks shall be conducted at an internal pressure of not less than 45 psig (Pa). The overall leakage rate for the airlock shall be less than or equal to 268 SCFD (0.05 La). Airlock tests shall be conducted:
a) Every six months.
b) Prior to restoration of contain-ment integrity, when maintenance has been performed on the airlock which could affect its sealing capability.
Amendment No. 97 -
173 N
JAFNP.
,~
~
/
h
?
{]1gf4gt_ 4.7 (cont'd) 9~ c) Within three days of opening lf> **(a the airlock, when containment integrity is required and maintenance has been performed on the airlock which could affect its sealing capability. *
(4) Airlock seals shall be tested at a pressure not less than 45 psig.
The seal leakage rate shall be less than or equal to 120 SCFD.
Airlock seal tests shall be con-ducted:
a) Prior to restoration of contain-ment integrity *. If maintenance which could affect sealing capa-bility was performed the entire airlock shall be tested as required by 4.7. A.2.e (3).
b) Within three days after opening the airlock, when containment integrity is required.
c) Once every three days, during periods of frequent openings when containment integrity is re-quired.
Anendrent no. 97 173a
- Exemption to 10 CFR 50, Appendix J
j .
JAFNPP 4.7 (cont'd)
(5) Type C test. ~
c Type C tests shall be performed during each I reactor shutdown for refuehng but in no case at intervals greater than two years.*
- l (6) Other leak rate tests specified in Section 4.7.d shall be performed during each reactor shutdown for refueling but in no case at intervals greater than two years. ,
- f. Containment modification" Any major modification, replacement of a component which is part of the primary reactor containment boundary, or ressaling a seal-welded door, performed after the preoperational leakage
- rate test shall be followed by either a Type A, Type B, or Type C test, as apphcable, for the area affacted by the modification. The measured leakage from this test shall be included in the test report.
The acceptance critoria as appropriate, shall be met.
Mmor modifications, replacements, or ressaling of seal-welded doors, performed directly prior to the conduct of a scheduled Type A test do not require a separate test.
- In accordance with an exemption from 10 CFR 50 Appendix J, a "
in accordance with an exemption from 10 CFR 50 Appendix J, -
Type A, B, or C test is not required for the replacement of piping the Type C test of the shutdown coolmg isolation valves
) and welds which constitute the Core Spray System mwwnum flow (10MOV-17 and 10MOV-181 may be deferred until refueling lines (3*-W23-152-7A, B) dunng the 1993 maintenance outage. outage Reload 11/ Cycle 12.
Amendment No. g,g, g5,1/4,1jf6,1[,1p, 208 -
f I
Id I
k 1
P X Osw i
$C
JArnet*
- 4.7 BASES (coat'd) 7 assumption of no holdup la the secondary contain- T As most leakage and deteriorutlos of integrity is j meat, resulting la a direct release of fission espected to occur through penetrations, especially products from the primary costalement through the those with resilient seals, a periodic leak rate filters and stack to the environs. Therefore, test program of such penetrations is conducted at the specified primary costalement leak rate and the peak pressure of 45 psig to lasure not only filter efficiency are conservative and provide that the leakage remains acceptably low but also
~
additional margia between espected offsite doses that the seallag materials can withstand the and 10CFR100 guidelines. accident pressure. For airlock leak test, a seal f-test at the peak pressure could be substituted
[ The maalmum allowable test leak rate at the peak for the complete airlock test, if no maintenance pressure of 45 psig (Fe) is 8.5 weight percent work is done which could affect the sealing per day (Lam). The maalmum allowable test leak capability of the airlock.
rate at the reduced pressure of 23 psig (P t) will be verified to be commervative by actual The leak rate testing program was originally primary containment leak rate measurements at based on Commisalom guidelines for development of l both 45 psig and 23 poig upos completion of the leak rate testing and surveillance schedules for contalaamat structure. reactor contalement vessels (16), med discussed l In Ouestion 5.4 of the FSAR. With the exceptions i To allow a margia for possible leakage deterior- listed in Table 4.7-2 the system comforms to the atlos between latervals, the maximum allowable let'st e Commissica guidelines (17). The exceptions l leak rate (Ltm), which will be met to renais on stated la Table 4.7-2 are necessary since the normal test schedule, is 0.75 Lt . In .
addittomal requirements were added after the addition, it is latended to operate the primary system was designed, containment structure at a slight positive pressure to contianously monitor primary contain- B. Et w hy Gas Treat ===t System and.
I most leakage. j C. Secondary Contalsmaat t _
Initiating reactor building isolation and opera-4 l tion of the Standby Gas Treatment System to malatala at least a 1/4 la. of water vacuwa MMM C. within the secondary contalement provides an adequate test of the operation of the reactor Aneadmeat No. .W 194 O ?i
__ . _ _ _ _ __ . - - - _- _ . ._._- . . _ - . _ . -- .- _ - - _ - . . = = - . - _ . .
I
! INSERT C:
"The leakage rate testing program was originally based on NRC guidelines for development of leak rate testing and surveillance schedules for reactor containment vessels. Containment i structural integrity is currently verified with visual l inspections and containment leak tightness is verified by the i
leakage rate surveillance testing described in the JAFNPP Primary Containment Leakage Rate Testing Program. This Program as implemented meets the requirements of Option B of 10 CFR 50 Appendix J (16) and Regulatory Guide 1.163 (13), with the l following approved exemptions that are described in more detail
! within the Program:
- 1. The Type C exceptions listed on Table 4.7-2, " Exception to Type C Tests," as of the date of issuance of Amendment 194 (July 29,1993).
- 2. Valves which are sealed with fluid from a seal system, such as the liquid in the suppression chamber are not required to be Type C tested. This exemption was approved by the NRC in l the original Technical Specifications (SR 4.7.A.2.c(3)).
l
- 3. The MSIVs are tested at a pressure less than P and 2 25 psig, with a leakage ra',e acceptance criteria of $ 11.5 scfh per valve. This exemption was approved by the NRC in the original Technical Spec.ifications (Table 4.7-2)."
l l
l l
l i
i
y t
I L
-l t
l P
PAGES 198 THROUGH Jl3 Y
- t
[
b t
i
+
Amendment No.M./,1/ tyd,173 198 W pageis 1 i
A
~ j i,
.i '
E \
- kwiV Y
g I P
,I , ;il , b i l t
el e be es wrd ea r d
etao r e uwb s t u
t s
e sAo e C t
r .e Pdet r h e p
t ue y osn t
iai T
e c em t .
r d b ieme r
dee t n o
n S
i u t o
o n e agdo) sk i
t c
i t
c s
s n a
r e e e e v aeeig c t .
r r c D e l l
ve i
d W o r
h c
E rdep e e p i S e nv5 s s y h G r r w R had2 t sr t e
v ev b
e O neaa vobH e r e d e v F i r l l
e R
E dla s
eviC nF h e
h e a e
s v
r P
t t e eohaneS i n n e r
e T t i t 5 d i
a h S etan1 d s bl e e s E
T o o1 t s s a e s v
l esdi t e e n i s
E wie esm t e
t i
l s o T shuS i b
e a l
p A et h x S R l av nebs e 'e. e e d e e T
S K
A ve era dw wk w
s e
w s
e s
s a
e n
a s
E E a r t e ge v v e i L obie l e
T L el e v
l e b v bdps v C A ne 5 'e e e t
o n
l e
v E C il e
I p2 h s
e s e s 2-P O h pf e h h W i h
L Taov T T W
- 7. Y T m L 4T 1
a EO 1
BT A
2 TN O
I t s
- n T e P m AB E e R 0D00s8e 21 t 3 22 A C
X i
u r
E ASC0A8cW 4a44a44 VVVVVVV 1 33 1 1 1 1
1 1 4
0 E
q VVV VV s u
1 e Vm OOO OO o V
/
r L AAAAAAA e a
AAA E i
s g AgWp n
a ODOOOOOM 9999999 2222222 777 222 Ah 77 22 i
W r
7 0 _
e t .
C _
e p
y T
m o
r s *A 1 _
r r
- f sr Gs e o o n o e 6
1 a e/ o/ i m gd gd s b Dt o iN r n r n e . .
Pu rn k
iOe a u a e n ')
e a) nP /
W iI vT t
S i P r )n e i ee 1 .
8 sie _
C eA g m r r n e g u ec e
r a AU I
B i a w (A o yert a rda w
yek (t o t r
s v
a4 fI s l- F M DleN rde dip r I
n r tin d n y m
o a
r l
t e ,
n e T f _
p N N 8 o g
n EO G I e
2 N i RT &
t n
6e t f
h w
o o
e NR I
AT T
N08E OE A
A8CD 7777 5
2 A
s 2
A 0
3 8
5 3 d e
m n
e m
7 T CP A n
i
j j
} i
. . r e r _
d e d e p e p
t t s s s ey sy e e eb t t i
nb n d _
C C i
l 8e d l e
e e 8l a .
p p 3la 3e t s
T y
T y < o es os -
e
.t t e t e e 1 er 1 r A b b 3a 3 )a e p
t o
n t
o h )s t
e hs t e y n i n
a n
a wv i v wl,o n T
a n
,lo n c c sv e s w i o o s o g hc hc nde ed t e s n
i ne c e c t c i r
i h
i h
l t
i t l
a r o r e u 7a 7c i i ir d D w w 3c i 3d d d d d e e 1d 1 ni e s e e E v v n o e s t R
R l
a l
o ei r
a ru e r e ae r
e w
r e
r e s e
O w v r o w v t F r r eo eh r o e e R e e e e
rf e r t e e r
e r
e r
a E hs hs he t h he th ht ht ht s P ( t ( t e T e e ss ss n n n v S v v ea ea i d
i d
i l a
E i
s m inh i nh e e d e v T o l a
ssh l
h t s t t t S E l
p a p aa sc e o o s o T T x de aa t t t e o r
S A e de e e e ed t
_. E T
R K
A i n
e s
n e
e t
t s a e n..d ed t
o oa ,d t
- n. b W
w b
W w
b W
n e
n s
_( 2 C l
e niu eniu w n E
L e
v e v beS boS e e e e s
d
_ v v i
- E l l t v n 7 P L e v a toress torass l
o l a l o i
_ r A v nee nee v v v s r 4 Y C s s Wn sc sc s e ero
_ n T i i Wn o s s e e E O h h Wpp i i i L O L T T Werpp h T
h T
h T
h T
- m. B T
. A N T A
_ O I 1 T
C 8 038 8 127 A 3 0 P 4 4 222 31 222 1 1 1 E R 0 0 111 11 1 3 3 V-C E E 1 1 VVVD VVV V- V- O s X VM V- V- OOOR OOC O O A u E LI E SSAC o AU 7 E
7 3333 SSA 333 M
0 M 1 6
i r
a VN 0 0 0 0000 000 1 1 1 V 4
C" "B 9 N " " 1 e g O b e e n n h
[1 I
T o e i s
i C
N P r
e P
t e
n e S m
e . -
U S P
N C r
e C
e r
i e
v r l e
e v y a
r y
e r
e r
u i
r e
[1 ,
O n > Dt n Dt n p p s
[1 l
I I l de s det S S e l ers T g g es es . . e t u A n n Ri p Ri p t n
t n
t P no ec R i e
i s l l e e 5 ne T r r C C e E e w
e v t r om r
t st nP N n ne I t w o e oh y ,
E P T r
T r
C e eh Ct e H I
M f D r
I eW s
nD _
T o
NN N
EIO t _
hT n e
I C 5
0 A8CD A8C0 A 5 C m A 5 7777 S808 0 8 5 0 d T 3 3333 3333 3 3 4 5 n N e 4
NN3 O
C s m
A e -
iI J
I 1 1 I i 1 .
. 1 1 I \
l l .,1 1
i, I i l 1 1 1 j 'l l 11 i j j >
- 1 1 1 - >
j
~Il i 11 II o jjll
~
- .. == un s _ .. = i il ll il ll!!!!ll! !!lillll! !
j fj 1j i 1 l
1 t
i 1 I 111111 1g l 4 ig!'l l I 1:!'1 11 i
1 g v
,!'g i i! ! -
l
- ~
9 I
h l
lx # I l #
l# >
it
,l ' j 1 1 1 i l I j , i 1- 1
& E '
i s l l l 1 1 1 $ $ I } }
i l 5g I 1 , a a a a i i ' 1 1 1 1 1 1 n , , ,
,4, i 1 i i i i
p l. :i #
- 1. s s. sl il.
i si 2
l 2 *$I ~ - AW RR$
=
11 ! l ill i i ll !!li ll!
j 2 .
i I I n 1
' l I}l !! !! !! !
s . l !o! i n n!u il n il 1 4
! E ! E E I !
u <
e '
o f
s JAFN TABLE 4.71 EXCEPTION TO TYPE C TESTS CONTAINMENT PENETRATION VALVE LOCAL LEAK RATE TEST PERFORMED PENETRAT, TON _ , FUNCTION NUMBER 22G HPCI- Pump Suction 23MOV-57 Will not be tested as lines are water scated by suppression chamber water. -
(Torus) 23MOV-58 227A Core Spray - Pump 14MOV-7A Will not be tested as line is water sealed by suppression chamber water.
Suction (Torus) f 227B Core Spray - Pump 14MOV-7B Will not be tested as line is water sealed by suppression chamber water.
Surtion (Torus)
\
228 Condensate to Torus 33CND-102 Wdi not be tested as line is water sealed by suppression chamber water.
i Deu,E ,
pad I
- 1ii Nei 143 ? t:sl>
N 6.19 POSTkCCIDENTSAMPLINGPROCEAM ~
t A program shall be established, impissented, and maintained which will ensure the capability to obtain and analyse reactor coolant, radioactive iodines and particulates in plant gaseous e*fluents, and containment atmosphere samples under accident conditions.
the following: The program shall include f;'
A) Training of personnel, B)
C) procedures for sampling and analysis, Provisions for maintenance of sampling and analysis L l
l'#
rose <tr D '
l O
G l
Amendment No. 1 '
258e
I I
INSERT D:
"6.20 Primary Containment Leakace Rate Testina Procram A program shall be established to implement the leakage rate testing of the Primary Containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B, as modified by approved l exemptions. This program shall be in accordance with the j guidelines contained in Regulatory Guide 1.163, " Performance-l Based Containment Leak-Test Program," dated September 1995.
A. The peak Primary Containment internal pressure for the design basis loss of coolant accident (P,) , is 45 psig.
B. The maximum allowable Primary Containment leakage rate ( L,) ,
at P, shall be 1.5% of primary containment air weight per day.
- C. The leakage rate acceptance criteria are
- 1. Primary containment leakage rate acceptance criteria is 5 1. 0 L,. During unit startup following testing in accordance with this program, the leakage rate acceptance criteria are 5 0.60 L, for the Type B and Type C tests and s 0.75 L, for the Type A tests;
- 2. Airlock testing acceptance criteria are:
- a. Overall airlock leakage rate is s 0.05 L, when tested at 2 P ,
- b. For each door seal, leakage rate is 5 120 scfd when pressurized to 2 P,.
- 3. MSIV leakage rate acceptance criteria is 5 11.5 scfh for each MSIV when tested at 2 25 psig D. The provisions of Specification 4.0.B do not apply to the test frequencies specified in the Primary Containment Leakage Rate Testing Program.
E. The provisions of Specification 4.0.C are applicable to the Primary Containment Leakage Rate Testing Program."
JAFNPP ,,
,o,La l \ G3, Pak.m. -
Rey lac 3 C rhaLa,a wa-mr .
Pr ,3,-# l JJeg g Ll e 1995 l
7.0 REFERENCES
t C.H. Robbins, " Tests of a Fun Scale 1/48 Segment of the L j E. Janssen, " Multi-Rod Bumout at Low Paseure," ASME Paper (9) j (1) Humbolt Bay Pressure Suppression Containment," GEAP-3596, 62-HT-26, August 1962. November 17,1960. l K.W Bacter, " Burnout CondNons for Flow of Boung Water in ;
(2) (10) "Nudeer Safety Program Annual Progress Report for Period Vertical Rod Clustom," AE-74 (Stostholm, Sweden), May 1982. i Endng December 31,1986, Progress Report lor Period Ending Dooember 31,1966, ORNL-4071."
(3) FSAR Section 11.2.2.
(11) Section 5.2 of the FSAR.
(4) FSAR Section 4.4.3.
(12) TID 20583,"Leekage Charactortstics of Steel Containment ,
1.M. Jacaha, "ReliebWty of Ei (pr::-d Safety Feelures as a Vessel and the Analysis of Leekage Rate Determinations."
(5)
Func6on of Testing Frequency," Nucteer Safety, Vol. 9, No. 4 M July-August 19es, pp 310-312.
(13) Technical Safety Guide, " Reactor Conseinment Leeka0s Testing '
and Surveulence Requirements," USAEC, DMsion of Safety Deleted l(6) Standants, Revised Draft. December 15,1966.
\
1.M. Jacobs and P.W. Merlott, APED Guidognes for Determining (7) (14) Section 14.6 of the FSAR.
Safe Test intervais and Repair Times for Enginoemd Safeguents
- Apet 1969. (15) ASME Boiler and Pressure Vessel Code, Nucosar Vessels, Secelon Ill. Maximum M Intemel pressure is 62 psig.
(8) Bodega Bay Preliminary Hazards Report, Appendx 1, Docket 50-205, December 28,1962.
(16) k CFR 50.54, Appendx J, " Reactor Containment Testing C
(17)h50, Appendx J, February 13,1973. gg L _ "I O qrR Pn4 So App.a l eix { . "A""j 'A*b" C~ L.an+ L a A y e. Teshap & urkc- Gole0 fo x Rach-s or M B- Ark-e LuD Rey w <w k, * (LM JA OcJeLee -x , /9 95w Amendment No. 1)l6, 285 me
Attachment IV to JPN-96-011 APPENDIX J OPTION B IMPLEMENTATION PLAN (JPTS-96-003) i l
l l
New York Power Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 DPR-59
i .
Attachment IV to JPN-96-011 APPENDIX J OPTION B IMPLEMENTATION PLAN Page 1 of 5 INTRODUCTION i Option B of 10 CFR 50, Appendix J (Option B) provides a performance based approach for leakage rate testing of primary containment. This action improves the focus of the regulation l by eliminating prescriptive requirements that have been determined to be marginal in safety.
l Option B allows for test intervals to be established based on system and component performance and provides for greater flexibility for cost effective implementation methods of regulatory safety objectives.
l This plan outlines how the Authority will incorporate Option B into the Primary Containment l Leakage Rate Testing Program (the Program) for Type A, B and C testing at the FitzPatrick l plant. The Authority will comply with the requirements contained within References 1 through 4.
COMPONENT LEAKAGE LIMITS Fitzpatrick will set administrative limits for each Appendix J component and develop the l procedures for changing them. The existing plant administrative limits will be reviewed and l compared against consistent limits set by the FitzPatrick Maintenance Rule Expert Panel.
A component's measured leakage is compared against its administrative limit to determine whether the As-Found LLRT passed or failed on a performance basis. The expert panel will review and approve administrative leakage rate limits since the proper setting of these limits is extremely important under the performance-based rule. Comparison of a components As-Found leakage against the administrative limits will determine if a test passed or failed , thus, the values chosen will affect each component's Type B or C testing frequency.
Two limits, a warning limit and an alarm limit, will be specified for each component. A
, component should be repaired if the As-Found leakage rate is above the warning limit, but l below the alarm limit. If repaired, an As-Left test will be conducted. The As-Found test is l not counted as a performance failure. If a component's leakage rate is above the alarm limit, i then the component shall be repaired. The component will be retested after the repair. The
! As-found test is counted as a performance failure. This scheme allows for a low leakage l
setpoint to trigger component repairs.so as to maintain containment in good condition. It also allows for the alarm limits to be set high enough that a Type B or C As-Found test need l not be counted as a failure unless the component is found in a seriously degraded condition.
Although administrative limits are used to maintain the containment in good condition, it l should be noted that the sum of the As-Left Maximum Pathway Leakage Rates for all Appendix J barriers must be less than 0.6 La per plant Technical Specifications (TS) prior to entering a mode requiring primary containment integrity. In past instances where leakage from one or more components have exceeded administrative limits, and correcting this condition would have either been very difficult or costly, a total containment leakage evaluation was performed and der,cmented. If the evaluation concluded that the additional l
l i
l i
o >
1 l
Attachment IV to JPN-96-011 APPENDIX J OPTION B IMPLEMENTATION PLAN Page 2 of 5 I leakage posed no significant safety impact, and the TS limit of 0.6La was not exceeded, the ;
component (s) was(were) allowed to continue to leak in excess of the individual valve leakage l administrative limit until repairs could be made. The test is still considered to be a failure because the administrative alarm limit was exceeded. The Authority reserves the option to continue use of this criteria when the alarm limit is exceeded, only on a critical as needed basis.
BUILDING PERFORMANCE BASELINES / ESTABLISHING TEST FREQUENCIES j l
Tvoe A Test l
Type A testing procedures will be revised per the new Option B requirements, and shall be l performed during a period of reactor shutdown at a frequency of at least once per 10 years i based on acceptable performance history. Acceptable performance history is defined as l completion of two consecutive periodic Type A tests where calculated performance leakage '
rate was less than 1.0 La. Elapsed time between the first and last tests in a series of consecutive satisfactory tests used to determine performance shall be at least 24 rnonths.
Option B allows for reviewing performance history with several options to determine if past Type A tests were satisfactory.
- a. As-Found Type A test results can be compared to 1.0 La rather than the previous 0.75 La criteria.
- b. Leakage savings (repairs / adjustments) from type B and C testable pathways which were added as penalties to the As-Found Type A test can be subtracted when reviewing previous Type A test results.
- c. The Type A test UCL from previous Type A tests may be recalculated using the Mass Point Methodology described in ANSl/ANS 56.8-1994.
The Authority has reviewed Type A test results for the FitzPatrick plant as compaad to the new requirements / criteria to establish a test frequency for the Primary Containment Integrated Leak Rate Test (ILRT). It has been determined that the two most recent As-Found Type A tests (1990 and 1995) are below the 1.0 La criteria. Leakage savings (repairs / adjustments) from Type B and C testable pathways which were added as additions to the As-Found Type A test were not subtracted. Based on this, Fitzpatrick willimplement the 10 year Type A test frequency based on the criteria set forth in the new rule. The Type A test interval may be extended by up to 15 months, however, this option will only be used in cases where refueling schedules have been changed to accommodate other factors.
Attachment IV to JPN-96-011 APPENDIX J OPTION B IMPLEMENTATION PLAN Page 3 of 5 Appropriate administrative controls have been developed such that prior to initiating a Type A test, a visual examination shall be conducted of accessible interior and exterior surfaces of the containment system for structural problems which may affect either the containment structure integrity or the performance of the Type A test. These containment inspections will also be conducted during two other refueling outages before the next Type A test.
Therefore, FitzPatrick will perform these examinations at least three times every ten years, regardless of the Type A test schedule.
Tvoe B and C Test The Authority will develop a procedure for building and documenting Type B and C testing performance baselines for the FitzPatrick plant. This procedure will be used to ensure that a consistent criteria is applied to establish component baseline performance and their subsequent testing frequencies. The Authority will develop bases for test frequencies based
)
upon performance of leakage tests that meet the requirements of Option B and approved ;
exemptions. In addition historical performance, considerations such as service life, '
environment, design, system application, special service conditions, and safety impact / risk I from failure will be reviewed / evaluated in determining test frequency. The component's I performance history will determine its test interval. j l
The Authority will compile the required leak rate historical data and continue to update this ;
data with the most current As-Found leak rate data. The performance history of each component will be evaluated against the alarm limit to rate component performance over the last two refuel outages.
I Type B components which are determined to have a performance rating of unknown, poor, or ;
improving, will require a 30 month test frequency. A rating of good or excellent allows for up l to a 120 month test interval. The component will be evaluated to determine if it is a member of a group of components subject to the same common mode failure mechanisms. If so, then the test intervals of all members of that group will be staggered, such that some percentage of those components are tested periodically. The date of the next test may be earlier than required by the baseline interval for this reason. The Authority intends to place good or excellent performing Type B components on a 120 month test interval. The test frequencies of similar/ grouped components will be staggered to ensure that a percentage of components are tested periodically.
Type C components which are determined to have a performance rating of unknown, poor, or improving, will require a 30 month test frequency. A rating of good or excellent allows for up to a 60 month interval.
Per NRC Regulatory Guide 1.163, the NRC does not endorse extended test intervals of greater than 60 months for Type C tests. Further, the Regulatory Guide states that Type C tests for Main Steam and Feedwater isolation valves and containment purge and vent valves, should be limited to 30 months with consideration given to operating experience and safety significance. The Authority intends to fully comply with this guidance by performing Type C tests on Main Steam, Feedwater, and Containment Vent and Purge isolation valves at a 30
l Attachment IV to JPN-96-011 APPENDIX J OPTION B IMPLEMENTATION PLAN Page 4 of 5 month interval with consideration given to operating experience and safety significance.
Type B and C testing intervals may be extended by 25 percent of the interval, not to exceed I 15 months, however, this option will only be used in cases where refueling schedules have been changed to accommodate other factors.
The Authority will place the primary containment airlock on a test frequency of at least once per 30 months. Airlock door seals will be tested within seven days after each containment i access when primary containment integrity is required. For periods of multiple containment l entries where the airlock doors are routinely used for access more frequently than once every seven days, door seals may be tested once per 30 days during this time period.
FAILURES, REPAIRS / ADJUSTMENTS, CORRECTIVE ACTIONS
- Failures, repairs / adjustments, and corrective actions for Type A, B, and C testing results will be evaluated through the Deviation Event Report process.
If Type A performance leak rate test results are not acceptable, then a determination will be performed to identify the cause of unacceptable performance and determine appropriate corrective actions. Once the cause has been determined, and corrective actions have been completed, acceptable performance should be reestablished by performing a Type A test within 48 months following the unsuccessful Type A test. Following a successful Type A test, the surveillance frequency may be returned to once per 10 years.
l Type B or C component failures discovered during performance of the Type A test will be l considered as failure of a Type B or C test for purposes of cause determination and corrective action. This includes failures of type B and/or C components that were not previously identified by a Type B or C test.
Type B and C component failures will require that testing frequency be set at the baseline test interval of 30 months. A cause determination will be performed and corrective actions identified that focus on those activities that can eliminate the identified cause of failure and prevent recurrence. Once the cause determination and corrective actions have been completed, acceptable performance should be reestablished and the testing frequency returned to the extended interval in accordance with the NEl 94-01 guidance.
! In addition to the periodic As-Found Type B and C test, an As-Found test shall be performed l prior to maintenance, repair, modification. or adjustment activity if the activity could adversely affect the penetration leak tightness. An As-Left Type B or C test shall be performed following those activities, unless engineering analysis shows reasonable assurance that such work does not affect the leak tightness of the penetration and that it can still perform its intended function. Specifically for Type C tests, an alternative method or analysis can be used to provide reasonable assurance that such work does not affect a valve's leak tightness and a valve will stiil perform its intended function. If As-Found and As-Left Type B
- and/or C results are both less than the allowable administrative limit, a change in testing l frequency is not required. If the results are unacceptable, testing shall continue at initial test intervals until adequate performance history is reestablished.
.e 1
l Attachment IV to JPN-96-011 APPENDIX J OPTION B IMPLEMENTATION PLAN Page 5 of 5 l
l TECHNICAL CRITERIA AND TESTING METHODOLOGY INTERPRETATION 1
l Changes to the leak rate testing program will be required regarding testing methodology and procedural requirements under Option B. The technical details / criteria and testing methodology as described in ANSI /ANS 56.8-1994 will be used in updating the FitzPatrick Type A, B, and C leak rate testing program.
REFERENCES
- 1. Regulatory Guide 1.163, Performance-Based Containment Leak-Test Program, dated September 1995
- 2. Option B of 10 CFR 50 Appendix J, Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors (60 FR 49495)
- 3. NEl 94-01, Industry Guideline for implementing Performance-Based Option of 10 CFR 50 Appendix J, Rev. O, dated July 2G,1995
- 4. ANSl/ANS-56.8-1994, Containment System Leakage Testing Requirements I
l 1
l
n e. o Attachment V to JPN-96-011 List of Commitments Commitment Commitment Due Date
! Number JPN-96-011-01 Perform the appropriate actions to July 1,1996 or prior qualify the Standby Gas Treatment fan to implementation motors and the GE Motor Control of a 1.5 percent per Centers for a 1.5 percent per day day allowable primary containment leakage rate. leakage rate.
l l
)
i i
i