ML20107F218
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Jersey Central Power & Light Company %jb' i
MADISON AVENUE AT PUNCH BOWL ROAD e MORRISTOWN, N. J.07%0
- 201539 6111 es
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General P,e PubleC Utelsties Corporation U
,,,,,e December 24, 1975 GD-75-020' Mr. Karl R. Coller Assistant Director for Operating Reactors Division of Reactor Licensing Office of Nuclear Reactor Regulation
. United States Nuclear Regulatory Commission Washington, DC 20555
Dear Mr. Go11er:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 Primary Containment Leakage Testing Program
'lhis report is in respo'nse to your letter of August 7, 1975 which requested that a study be made to determine if the containment Icakage test-ing program at the Oyster Creek Nuclear Generating Station is being conducted in full compliance with 10 CFR Part 50, Appendix J, and also, if not in full compliance, to identify planned actions and schedules to attain full conformance with the Regulation.
The requested study has been completed. The results indicate that an extensive effort has been made to bring the procedures for primary containment overall integrated and local Icakage rate tests into conformance with the criteria specified in Appendix J using the methods and provisions of ANSI N45.4-1972. The study further revealed that the Oyster Creek containment leakage test program, in so far as the design and construc-
. tion features of the plant will permit, comparcs favorably with the requirements forth in Appendix J for Type A and Type B tests, but differs ' considerably set with the requirements for Type C tests. The specific deviations of the Oyster Creek containment 1cakage testing program in regard to Appendix J requirements are identified in Tabics 1 through VI, attached to this report.
The Oyster Creek Nuclear Generating Station is an early vintage boiling water reactor plant (General Electric BWR-2), and, as such, has fluid systems and a primary containment system with physical and functional designs that predate 10 CFR Part 50, Appendixes A and J, by several years.
An evaluation of the Oyster Creek primary containment design features against the Commission's containment design criteria, Group V of Appendix A - General Design Criteria for Nuclear Power Plants, is given in Amendment 68 to the Oyster Creek Facility Description and Safety Analysis Report.
g lu2n 9604220265 960213 PDR FOIA PDR
- DE.KOK95-258
' December 24, 1975 Mr. Goller
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The program for primary containment leakage testing at Oyster Creek consists of periodic overall integrated Icak rate tests plus local Icakage rate tests of the closures with double gasketed seals, the testabic penetrations, and the testable isolation valves.
The procedures which are used in the conduct of the containment Icakage testing program were reviewed for nonconfonalty with the requirements set forth in. Appendix J.
The disparities found are identified in the attached tables.
In Tabics I and II are listed the Oyster Creek testing program differences with regard to the requirements for Type A and Type 11 tests. 1hc tables with numbers Ill, IV and V were compiled from a listing of all of the valves in piping which penetrates primary containment.
The containment isolation valves shown in Table III are those which are tested by a local Icakage rate test in addition to the overall integrated test. -In Table IV are listed the containment isolation valves which are not tested in a local leakagc* rate, Type C, test.
The penetration valves listed in Tabic V are in systems that will or may be called on to operate under accident conditions.
In regard to testing requirements, the valves listed in Taole V are placed in a category with system operating valves and are considered not to require a local Icak rate test.
The most recent containment overall integrated Icak rate test was conducted at Oyster Creek in June 1974.
Local Icakage rate tests were conducted as recently as May 1976. The program has been proven very effective in determining the primary containment system Icak rate and providing Icakage surveillance of testable penetrations and testable valves. The system modifications required to provide the design features.necessary to attain full compliance with the test requirements of Appendix J entail high costs, both monetary and in personnel exposure, and could possibly result in a reduction in integrity of systems which have been proven structurally sound over the past several years of service.
1here are no plans at the present time for making system modifications designed specifically to increase Icakage surveil-lance capability. Jersey Central Power f Light Company will, however, continue to give Appendix J criteria consideration in the design of future repairs and modifications that involve the integrity of the primary containment system.
It is our. belief that the items of nonconformance that presently exist between the Oyster Creek containment Icakage testing program and Appendix J
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criteria, because of the aforementioned design limitations, cause no undue risk to the health and safety of the public.
We plan, therefore, pursuant to 10 CFR Part 50, Section 50.12a, to request of the Commission that Oyster Creek be exempted from full compliance with Appendix J.
Specifically, the request will seck exemptions for all items shown in Table I and in Table II, all valves listed in Table IV, and those valves in Table III for which the test method is in variance with the requirements of a Type C test. The submittal of the exemption request is planned for June 1976.
A comparison of the Appendix J criteria with the Oyster Creek Technical Specifications which apply to the primary containment system leakage rate is given in Tabic VI of this report.
There are no me.ior deviations i
indicated; however, the Technical Specification is much less extensive than Appendix J.
The current plant procedures for containment Icakage testing and Icakage surveillance were prepared in accordance with the requirements of Appendix J, insofar as system design features permit. Test results must i
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t 's Mr. Go11Gr December 24,'1975
. satisfy Appendix J acceptance.critorien.. It is recognized that the Technical Specification in regard to containment Icakage testing is in need of a change 1
.that will incorporate the language and intent of Appendix J criteria..A:
revision to the Technica1' Specification has.been drafted and is being processed through the required review stages. A change request for Commission review
.and approval will be submitted with the request for specific exemptions.from-full compliance with Appendix J which was discussed above.
Should you have any questions regarding the information that.has been presented in this report, we would be pleased to meet with you and discuss the matter.
Very truly yours,
'l W.IM'll.) I ti Ivan R. Finfrock/ Jr.
Vice President cs Attachments i
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Table I q
OYSTER CREEK CONTAINMENT LEAKAGE TESTING PROGRASI CONTAINMENT OVERALL INTEGRATED LEAK RATE TEST ITLMS OF NON-COMPLIANCE WITH 10 CFR PART 50 APPENDIX J TYPE A TEST REQUIREMENTS Item' Trpe A Test Requirement Oyster Creek Program 1
Those portions of the fluid systems that are
.The Reactor Building' Closed Cooling Water.
part of the reactor coolant pressure boundary (RBCCW) System is not presently opened or vented and are open directly to the containment to the containment for the Type A test. The.
atmosphere under post accident conditions and instrument and service air systems are not become an extension of the boundary of the.
presently opened or vented and drained for the containment shall be opened or vented to the Type A test.
i containment atmosphere prior to and during the test.
Portions of closed system inside contain-The entire Emergency Condenser System is opened but ment that penetrate containment and rupture as a the condensate return leg cannot be drained.
result of a' loss-of-coolant accident shall be Since this system is closed outside the containment i
vented to the containment atmosphere.
All vented as an extension of the reactor coolant system, j
systems shall be drained of water or other fluids its isolation valves have no effect on the Type A
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to the extent necessary to assure exposure of the test other than packing leaks which are detected -
system containment isolation valves to containment and repaired during normal plant operation.
L air test pressure and to assure they will be sub-jected to the post accident differential pressure.
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Systems that are required to maintain the plant in a safe condition during the test shall be oper-abic in their normal mode, and need not be vented.
1 Systems that are normally filled with water and operating under post accident conditions, such' as the containnent heat removal system, need not be. vented.
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4 Table 1 (Continued)
' Item _
Type A Test Requirement Oyster Creek Program -
2 Test Methods
-(a) All Type A tests shall be conducted in (a) H is requirement is.not included in.the accordance with the provision of the.
Technical Specifications or procedures; American National Standard N45.4-1972, however, the test is done in accordance
-g Leakage Rate Testing of Containment with ANSI N45.4-1972 with the following.
1-Stnictures for Nuclear Reactors, March 16, exceptions:
1972. The method chosen for the initial test shall normally be used for the periodic (1) " Cool Night Air" is not always used tests.
to pressurize the containment.
(2) The reference volume is not currently.
being checked after the Type A test.
f (b) Test Icakage rates shall be calculated using (b) The leakage rate values are not' currently-
-1
- absolute values corrected for instrument corrected for instrument error.
error.
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m Table-II
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OYSTER CREEK CONTAINMENT LEAKAGE TESTING PROGRAll I
CONTAINMENT PENETRATIONS, DOUBLE-GASKETED' SEALS'AND PERSONNEL AIRLOCK DOOR SEALS ITDIS OF NON-COMPLIANCE WITH 10 CFR PART. SO ' APPENDIX J TYPE B TEST REQUIRDIENTS L
-Item.
Type B Test Requirement Oyster Creek Program 1-
- Piping penetrations fitted with expansion bellows Steam line penetrations (two lines) are not are subject to test each refueling outage.
tested by local leak rate test.
2 All-preoperational and periodic Type B tests shall The drywell air lock doors are tested at a
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be performed by local pneumatic pressurization of pressure of 10 psig. Design does not permit the containment, either individually or in groups, testing at a higher pressure. (Note 1)'
at a pressure not less than Pa.
Note 1: ' The personnel air lock _ door seals are tested by pressurizing the air lock to 16 psig and taking Icak
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.J rate data.
Since the inner door is being tested in the opposite direction to the intended' isolation, a pressure of greater than 10 psig could daaage the door.
Because pressure.in this direction tends to open the door while pressure in the same direction of the intended isolation would tend to close the door, the test results are at least equivalent to or more conservative than a test in the same direction.
of the intended isolation.
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Table III OYSTER CREEK CONTAIhWENT LEAKAGE TESTING PROGRA>l I
CONTAINS!ENT ISOLATION VALVES TliAT ARE INDIVIDUALLY TESTED (Local Leakage Rate Test)
Valve Test Piping System Identification Number Location Type Size Direction 13itrogen Makeup to Drywell V-23-17 Outside Drywell Control 2"
Right (1)
Nitrogen Makeup to Drywell V-23-18 Outside Drywell Control 2"
Opposite (2),(4)
Drywell Nitrogen Purge V-23-13 Outside Drywell A. O. Butterfly 8"
Right.
o Drywell Nitrogen Purge V-23-14 Outside Drywell A. O. Butterfly 8"
Opposite (3)
Drywell Vent Bypass V-23-21 Outside Drywell Control 2"
Opposite Drywell Vent Bypass V-23-22 Outside Drywell Control 2"
Right Nitrogen Makeup to Torus V-23-19 Outside Torus Control 2"
Right Nitrogen Makeup to Torus V 20 Outside Torus Control 2"
Opposite (4)
Torus Nitrogen Purge V-23-15 Outside Torus A. O. Butterfly 8"
Right
. Torus Nitrogen Purge V-23-16 Outside Torus A. O. Butterfly 8"
Opposite
. rywell Vent Line V-27-1 Outside Drywell A. O. Butterfly 18" Opposite (3)-
Drywell Vent Line V-27-2 Outside Drywell A. O. Butterfly 18" Right Drywell Purge Inlet V-27-3 Outside Drywell A. O. Butterfly 18" Right Drywell Purge Inlet V-27-4 Outside Drywell A. O. Butterfly 18" Opposite (3)
Torus Vent Line V-28-17 Outside Torus A. O. Butterfly 12"
' Opposite (3)
Torus Vent Line V-28-18 Outside Torus A. O. Butterfly 12" Right Torus Vent Line V-2 8-47 Outside Torus Control 2"
Opposite (4)
Torus to Rx Bldg Vac Bkr Line V-26-IS Outside Torus A. O. Butterfly 20" Right Torus to Rx Bldg Vac Bkr Line V-26-16 Outside Torus A. O. Butterfly 20" Opposite (3)
Page 1 of 2
Table III (Continued)
Valve Test Piping System Identification Number Location Type
. Size Direction Torus to Rx Bldg Vac 11kr Line V-26-17 Outside Torus A. O. Butterfly 20" Right Torus to Rx Bldg Vac Bkr Line V-26-18 Outside Torus A. O. Butterfly 20" Opposite (3)
Drywell Sump Discharge V-22-28 Outside Drywell Control 2"
Opposite (4)
Orywell Sump Discharge V-22-29 Outside Drywell Control 2"
Right Drywell Equipment Drain Tank V-22-1 Outside Drywell Control 2"
Opposite (4)
Drywell Equipment Drain Tank V-22-2 Outside Drywell Control 2"
R3ght Drywell 02 Analyzer Outside Drywell S. O. Globe 1/4" Right Drywell 02 Analyzer Outside Drywell S. O. Globe 1/4" Right o
Torus 02 Analyzer Outside Drywell S. O. Globe 1/4" Right 2 Analyzer Outside Drywell S. O. Globe 1/4" Right Torus 0 Main Steam Line NS03A Inside Drywell A. O. Globe 24" Right Main Steam Line NSO4A Outside Drywell A. O. Globe 24" Right Main Steam Line NS03B Inside Drywell A. O. Globe 24" Right Main Steam Line NSO4B Outside Drywell A. O. Globe 24" Right
^ STV Bypass Line V-1-106 Inside Drywell M. O. Gate 2"
Right 1
itSIV Bypass Line V-1-107 Inside Drywell M. O. Gate 2"
Right MSIV Bypass Line V-1-110 Outside Drywell M. O. Gate 2"
Right MSIV Bypass Line V-1-111 Outside Drywell M. O. Cate 2"
Right Notes (1)
"Right" - Tested in same direction as valves intended iso 1'ation.
(2)
" Opposite" - Test direction is opposite to direction of intended isolation.
(3) Tested in wrong direction for Type C test but considered satisfactory.
(Butterfly valves can be tested in j
either. direction.
(4) Tested in wrong direction for Type C test.
Page 2 of 2
Table IV CONTAINMENT ISOLATION VALVES TilAT ARE NOT INDIVIDUALLY TESTED (No Local Leakage Rate Test)
L Valve Reasons for Piping System Identi fication - Number Location Type Size Not Testing aanup System Line from Reactor V-16-1 Inside Drywell M. O. Gate 6"
2,3,4 I
Cleanup System Line from Reactor V-16-2 Outside Drywell M. O. Gate 6"
2,3,4 1
Cleanup System Line from Reactor V-16-14 Outside Drywell M. O. Gate 6"
2,3,4 Cleanup System Line to Reactor V-16-62 Inside'Drywell Check 6"
3, 4
, Cleanup System Line to Reactor V-16-61 Outside Drywell M. O. Gate 6"
3, 4
' Shutdown Cooling from Reactor V-17-19 Inside Drywell M. O. Gate 14" 1, 2, S Shutdown Cooling frem Reactor V-17-1 Outside Drywell M. O. Gate 10" 1, 2 Shutdown Cooling from Reactor V-17-2 Outside Drywell M. O. Gate 10" 1, ' 2 Shutdown Cooling from Reactor V-17-3 Outside Drywell M. O. Gate 10" 1, 2
-Shutdown Cooling to Reactor V-17-54 Inside Drywell M. O. Gate 14" 1, 2, S
. Shutdown Cooling to Reactor V-17-55 Outsid6 Drywell M. O. Globe 8"
1 Shutdown Cooling to. Reactor V 56 Outside Drywell M. O. Globe
' 8
1 Shutdown CooliAg to Reactor V-17-57 Outside Drywell M. O. Globe 8"
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Winincralized Water to Drywell V-12-13 Inside Drywell Check 2"
3 Demineralized Water to Drywell V-12-60 Outside Drywell Diaphragm (N. C.)
2" 3, 7 Instrument Air to Drywell V-6-166 Outside Drywell Globe
_2" 6
l Instrument Air to Drywell V-6-167 Outside Drywell Check 2"-
6
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Instrument Nitrogen to Drywell Outside Drywell Gate 2"
6 Sample Line from Reactor V-24-29 Inside Drywell Control 3/4" 3, 9
- Sample Line from Reactor V-24-30 Outside Drywell Control 3/4" 3, 9 l
c l. Emergency Condenser - Steam Line Vent V-14-S Outside Drywell A. O. Control 3/4" 3, 8 Emergency Condenser - Steam Line Vent V-14-20 Outside Drywell A. O. Control 3/4" 3, 8 Page 1 of 2
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Table IV (Continued)
Valve Reasons for Piping System Identification Number.
Location Type Size Not Testing Emergency Condenser - Steam Line Vent V-15-1 Outside.Drywell A. O. Control 3/4" 3, 8 Emergency Condenser - Steam Line Vent V-14-19 Outside Drywell A. O. Control 3/4" 3, 8 Traversing In-Core Probe System -
(Two Valves each Outside Drywell Ball Valve Eines Mechanism)
Shear Valve 3, 8 a
Reasons for not Testing (1) This valve is needed to maintain the reactor coolant below 212*F.
(2)
It would be necessary to drain the reactor vessel in order to test this valve.
(3) There are no testing provisions for this valve.
(4) This valve is in a seismic qualified line forming a closed loop outside containment.
(4 This valve is normally closed against reactor system operating pressure (constant leak. test).
w' This valve is not an automatic isolation valve (normally open).
(7) This valve is not an automatic isolation valve (normally closed).
(8) 'Ihis valve is a containment isolation valve and is exposed to Type A test pressure and any, leakage is included in the Type A test results.
(9) Tested for isolation function but not for leak rate.
Page 2 of 2 e
Table V
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OYSTER CREEK CONTAINMENT LEAKAGE TESTING PROGRAM CONTAINMENT PENETRATION VALVES TIL\\T ARE NOT INDIVIDUALLY TESTED (No Local Leakage Rate Test)
Valve x-Piping System Identification Number Location Type Size Notes
'Feedwater Line V-2-73 Inside Drywell Check 18" I
i Feedwater Line V-2-71 Outside Dr well Check 18" 1
/
f Feedwater Line
-V-2-74 Inside Drywell Check 18" 1
3 Feedwater Line V-2-72
- Outside Drywell Check 18" 1
RBCCW System to Drywell V-5-147 Outside Drywell M. O. Gnte 6"
2,7,9 RBCCW System to Drywell V-S-165 Inside Drywell Check 6"
2, 9 l
RBCCW System from Drywell V-S-166 Inside Drywell M. O. Gate 6"
2,:7, 9 RBCCW System from Drywell V-S'167 Outside Drywell M. O. Gate 6"
2,7,9 Emergency Condenser - Steam Line V-14-30 Outside Drywell M. O. Gate 10"_
3, 4,-6, 9-Emergency Condenser - Steam Line V-14-31 Outside Drywell M. O. Cate 10" 3,4,6,9 rgency Condenser - Steam Line V-14-32 Outside Drywell M. O. Gate 10" 3,4,6,9' Emergency Condenser - Steam Line V-14-33 Outside Drywell M. O. Gate 10" 3,4,6,9-Emergency Condenser - Condensate Line V-14-34 Outside Drywell M. O. Gate (N. C.)
. 10" 3,4,S,9 Emergency Condenser - Condensate Line V-14-36 Inside Drywell M. O. Gate (N. O.)
10" 3,4,9 Emergency Condenser - Condensate Line V-14-35 Outside Drywell-M. O. Gate'(N. C.)
10" -
3, 4, 3, 9 Emergency Condenser - Condensate Line V-14-37 Inside Drywell M. O. Gate (N. O.)
10" 3,4,9 Core Spray to Reactor NZ-02D Inside Drywell A. O. Check 8"-
3, 4, l
. Core Spray to Reactor NZ-02B Inside Drywell A. O. Check 8"
' 3. 4, Core Spray to Reactor
.V-20-21 Outside Drywell M. O. Gate 8"
3, 4 Core Spray to Reactor V-20-41 Outside Drywell M. O. Gate 8"'
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Table V (Continued)
Valve Riping System Identification Number Location Type Size Notes Coro Spray to Reactor NZ-02C Inside Drywell A. O. Check 8"
'3, 4
Care Spray to Reactor NZ-02A Inside Drywell A. O. Check 8"
3, 4 Core Spray to Reactor V-20-15 Outside Drywell M. 0. Gate 8"
-3, 4
Core Spray to Reactor V-20-40 Outside Drywell M. O. Gate 8"
3, 4.
Core Spray from Torus-V-20-3 Outside Torus M. O. Gate 12" 2,-3, 4, 7 Iors Spray from Torus.
V-20-4 Outside Torus M. O. Gate 12" 2,3,4,7 sre Spray from Torus V-20-32 Outside Torus M. O. Gate 12" 2,3,4,7 Core Spray from Torus V-20-33 Outside Torus M. O. Gate 12" 2,3,4,7 Containment Spray to Drywell V-21-11 Outside Drywell M. O. Gate 14"
. 3, 4, 7 3 ' Containment Spray to Torus V-21-18 Outside Torus M. O. Gate.
4" 4, 8 Containment Spray to Torus V-21-17 Outside Torus M. O. Gate 6"
4, 8 Centainment Spray from Torus V-21-9 Outside Torus M. 0. Gate 12" 3;4,7 Containment Spray from Torus V-21-7 Outside Torus M. O. Gate.
IP 3,4,7 Containment Spray to Drywell V-21-5 Outside Drywell M. O. Gate 14"-
3,4,7 Containment Spray to Torus V-21-15 Outside Torus M. O. Gate
~ 4" -
'4, 8
Containment Spray to Torus V-21-13 Outside Torus M. O. Gate 6"
4, 8
^)ntainment Spray from Torus V-21-3 Outside Torus M. O. Gate 12" 3,4,7
'.'t:dntainment Spray from Torus V-21-1 Outside Torus M. 6. Gate 12" 3,4,7
. Liquid Poison to Reactor V-19-20 Inside Drywell Check 1-1/2" 5, 8 Liquid Poison to Reactor V-19-16 Outside Drywell Check 1-1/2" 5, 8 Liquid Poison to Reactor NP05A Outside Drywell Explosive Diaphragm 1-1/2" Liquid Poison to Reactor NP05B Outside Drywell Explosive Diaphragm 1-1/2" CRD Hydraulic System to Reactor V-15-28 Inside Drywell Check 3"
2, 3 CRD Hydraulic System to Reactor V-15-27 Outside Drywell Check 3"
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, s t-Table V (Continued)
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Valve
. Piping System' Identification Number
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Location'
. Type
' Size LNotes~
.CRD' Hydraulic System - 137 Lines (Several Valves Outside Drywell 1"
3' 4
to Drives.(Insert) each Unit)
- ' CRD !!ydraulic System - 137 Lines (Several Valves Outside Drywell 3/4" 3~
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p to Drives - (Withdrawal) each Unit)
+
R;1ctor Head Cooling V-31-5 Inside Drywell Check-
'2"'
2, 3
-Reactor. Head Cooling V-31-2 Outside Drywell A. O. Gate.
2" 2
.Racetor Head Cooling V-31-1 Outside Drywell A. 0. Control' 2"
2 fe1R32ctor Coolant Instruments -
(One Valve Outside Drywell Excess Flow Check 1"
- 3, 8, 9
-59 Lines ~
each Line)
Notes
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-(1). It would un necessary to ' drain the reactor vessel in order to test this valve.
()'
There are no testing provisions for this valve.
cl$ ' This valve is requi red to open and remain -open - for duration of accident.
(4)- This valve is in a seismic qualified line forming a closed -loop outside containment.
(5) ' This valve is normally closed against reactor system operating pressure (constant leak test).
- (6) This valve is open for Type. A Test and'any downstream leakage is included in test results.
-(7)-- This valve is..not an automatic isolation valve-(normally open).
(8) This valve is not an automatic isolation valve (normally closed).
(9) Tested for proper operation but not for leak rate.
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Table VI OYSTER CREEK CONTAINMENT LEAKAGE TESTING PROGRN1 PRESENT OYSTER CREEK TECIINICAL SPECIFICATIONS COMPARED WITil APPENDIX J CRITERIA Appendix J Tech Spec Item Reference Appendix J Criteria Re ference Present Oyster Creek Technical Specification III.A.1 Containment inspection. A general Not addressed in present Technical Specifi-inspection of the accessible interior cations but is included in test procedure, and exterior surfaces of the contain-ment structures and components shall be performed prior to any Type A test to uncover any evidence of structural deterioration which may affect either the containment structural integrity or leak-tightness.
If there is evidence of structural deterioration, Type A tests shall not be performed until corrective action is taken in accordance with repair procedures, nondestructive examinations, and tests as specified in the applicable code specified in paragraph 50.55A
~ 1 at the commencement of repair work.
d Such structural deterioration and corrective actions taken shall be reported as part of the test report, submitted in accordance with V. B.
2 III.A.I.a If during a Type A test including the 4.5.C If Icak repairs are necessary to meet the supplemental test specified in III.A.3.(b),
allowable operational leak rate, the potentially excessive Icakage paths are integrated Icak rate test need not be identified which will interfere with repeated provided local leakage measurements satisfactory completion of the test, or are conducted, and the leak rate differences l
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Table VI (Continued)
Appendix J Tech Spec Item Reference Appendix J Criteria Reference Present Oyster Creek Technical Specification which result in the Type A test not meet-prior to and after repairs when corrected to Pt ing the acceptance criteria III. A.4. (b) and deducted from the integrated leak rate or III.A.5.(b),
The Type A test shall be measurement, yield a leakage rate value not terminated and the leakage.through such in excess of the allowable operational paths shall be measured using local leakage leak rate Lto (20).
testing methods.
Repairs and/or adjustments to equipment, shall be made and a Type A (The provisions of Appendix 'J are incorporated test performed.
in the test procedure.)
3 III.A.I.C The containment test conditions shall Not a Technical Specification requirement stabilize for a period of about 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> but test procedure calls for allowing the prior to the start of a leakage rate test.
primary containment to reach an equilibrium o
temperature and also specifies a 4-hour stabilizing period.
4 III.A.I.D Those portions of the fluid systens that Not addressed in Technical Specifications.
are part of the reactor coolant pressure boundary and are open directly to the containment atmosphere under post accident conditions and become an extension of the boundary of the containment shall be opened or vented to the containment atmosphere prior to and during the test.
Portions of closed
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system inside containment that penetrate containment and rupture as a result of a loss-of-coolant accident shall be vented to the containment atmosphere. All vented systems shall be drained of water or other fluids to the extent necessary to assure exposure of the system containment isolation valves to con-tainment air test pressure and to assure they will be subjected to the post-accident differential pressure.
Systecs that are required to maintain the plant in a safe con-dition during the test shall be operable Page 2 of 9
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Table VI (Continued)
Appendix J Tech Spec Item Reference Appendix J Criteria Re ference Present Oyster Creek Technical Specification J
in their noraml mode, and need not be vented.
Systems that are normally filled with water and operating under post-accident conditions, such as the contain-ment heat removal system, need not be vented.
However, the containment isolation valves Specific isolation valves to be tested in the systems defined in III. A.1. (d) are not identified in the Technical shall be tested in accordance with III.C.
Specification.
The measured leakage rate from these tests shall be reported to the Commission.
5 III.A.3 Test Methods (a) All Type A tests shall be con-(a) This requirement is not included in ducted in accordance with the the Technical Specifications but -
provision of the American National test is done in accordance with Standard N45.4-1972, Leakage Rate ANSI N.45.4-1972 with minor exceptions.
Testing of Containment Structures for Nuclear Reactors, March 16, 1972.
The method chosen for the initial
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test shall normally be used for the periodic tests.
(h) The accuracy of any Type A test (b) Limitations on the supplementary test shall be verified by a supplemental are not included in the Technical test.
An acceptable method is Specifications, but are a part of described in Appendix C of the test procedure.
The supplemental test method selected shall be conducted for sufficient duration to establish accurately the change in leakage rate between the Type A and supplemental test.
Results Page 3 of 9
Table VI (Continued)
Appendix J Tech Spec Item Re ference Appendix J Criteria Reference Present Oyster Creek Technical Specification J
from this supplemental tests are acceptable provided the difference between.the supplemental test data and the Type A test data is within 0.25 La (or 0.25 Lt).
If results are not within 0.25 La (or 0.25 Lt),
the reason shall be determined, corrective action taken, and a successful supplemental test performed.
(c) Test leakage rates shall be (c) Not included in the Technical calculated using absolute values Specifications.
corrected for instrument error.
6 III. A.4. A(iii) The Icakage characteristics yielded by 4.5.B.2 The allowable test leak rate Lt (20) measurements Ltm and Lam shall shall not exceed the lesser value establish the maximum allownble test established as follows:
leakage rate Lt of not more than La
( Lt m/ Lam).
In the event Ltm/ Lam is Lt (20) = 1.0 Lm (20)/Lm (33) nceater than 0.7, Lt shall be specified or as equal to La (Pt/Pa).
Lt (20) = 1.0 'Pt (20)'
1/2
- Pt (35)~'
. ~s)
This is interpreted to mean the ratio of absolute pressures and not gage pressures as indicated in Appendix J' since absolute pressures are normally used in fluid mechanics calculations.
Page 4 of 9
Table VI (Continued)
Appendix J Tech Spec
-Item Reference
- Appendix J Criteria Reference Present Oyster Creek Technical Specification 4
7.
III.A.5.b.1 Acceptance criteria for reduced pressure 4.5.B.3 The allowable operational leak rate tests.
The leakage rate Ltm shall be Lto (20) which shall be met prior to less than 0.75 Lt.
If local leakage resumption of power folicwing a test gi:
measurements are taken to effect re-(either as measured or following re-pairs in order to meet the acceptance pairs and retest) shall not exceed criteria, these me,asurements shall be 0.75 Lt-(20).
taken at a test pressure Pt.
(Local leak rates are taken at 35 psig and corrected to 20 psig.)
c 8
III.D.I.'s Periodic retest schedule. Type A test.
4.5.D Integrated leak rate tests shall be After the preoperational leakage rate performed within plus or minus 8 months tests, a set of three Type A tests shall as follows:
be performed, at approximately equal intervals during each 10 year service (1) During the first refueling outage -
period.
The third test of each set after -initial criticality or shall be conducted when the plant is 12 months, whichever~is sooner.
shut down for the 10-year plant in-service inspections.
(2) Within 24 months from the date of the test in (1) above.
(3)l Within every 48 months from the J
date of the test in (2)-and every 48 months thereafter.
9 III.A.6.a If any periodic Type A test fails to 4.5.D In the event the leak rate of any test meet the applicable acceptance criteria exceeds the allowable test leak rate in III. A.5(b)', the test schedule applicable Lt (20), the condition shall be corrected, to subsequent Type A tests will be reviewed the testing ~ frequency shall revert _to and approved by the Commission, the following schedule, within plus or-minus 8 months, as follows:
Page 5 of 9 L
Table VI (Continued)
Appendix J Tech Spec Iten Reference Appendix J Criteria Reference Present Oyster Creek Technical Specification d
(1) Within 12 months following the retest made (local or integrated) to correct excess leak rate.
(2) Within 24 months of Test 1.
-s (3) Within 48 months of Test 2.
10 III.A.6.b if two consecutive periodic Type A tests fail to meet the applicable acceptance criteria in III. A. 5. (b),
e notwithstanding the periodic retest 4
schedule of III.D, a Type A test shall Y
be performed at each plant shutdown for refueling or approximately every 18 months, whichever occurs first, until two consecutive Type A tests meet the accept-ance criteria in III.A.5.(b), after which time the retest schedule specified in III.D may be resumed.
-11 IV.B.3 For each periodic test, leakage test re-4. 5. 11 Each integrated leakage rate test shall
%I suits from Type A, B, and C tests shall be the subject of a summary technical be reported. The report shall contain an report, including results of the local analysis and interpretation of the Type A leakage rate tests. The report shall test results and a summary analysis of include analysis and interpretation of periodic Type B and Type C tests that the results which demonstrate con.pliance were performed since the last Type A test.
in meeting the specified leakage rate 1.calage test results from Type A, B, and limits.
C tests that failed to meet the acceptance criteria of III. A.S. (b), III.B.3, and Ill.C.3, respectively, shall be reported in a separate accompanying summary report that includes an analysis and interpretation Page 6 of 9
t s
b' Table VI (Continued)
Append c J Tech Spec
.r ci al Specification Item Reference Appendix J Criteria Reference Present Oyster Creek Tm e
of the test data, the least-squares fit analysis of the test data, the instrumentation error analysis, and the structural ' conditions of the containment or components, if any, which contributed to the failure in meering the acceptance' criteria. Results of analyses
- of the supplemental verification test employed to demonstrate the validity of the leakage rate test measurements shall also be included.
o 12 III.D.2 Type B tests. Type B tests except tests 4.5.E.1 Primary containment testable penetrations for air locks, shall be performed during and isolation valves shall be tested each reactor shutdown for refueling, or at a pressure of 35 psig each refueling other convenient intervals, but in no case outage except bolted double-gasketed at intervals greater than-2 years. Air seals shall be tested whenever the. seal locks shall be tested at 6-month intervals.
is closed after being opened, and at flowever, air locks which are opened during least at each refueling outage, such intervals, shall be tested after each opening.
For primary reactor containment (Test procedures require that air locks penetrations employing a continuous be tested following each opening.)
n leakage monitoring system, Type B tests, 4/
except for tests of air locks, may, notwith-standing the test schedule specified under 111.D.1, be performed every other reactor shutdown for refueling but in no case at intervals greater than 3 years.
13 III.B.2 Test' Pressure. All preoperational and periodic 4.5.E.2 Personnel air lock door seals shall be Type B tests shall be performed by local tested at a pressure of 10 psig each pneumatic pressurization of the containment re fueling. outage, penetrations, either individually or in groups, at a pressure not less than Pa.
(Design does not permit testing at a higher pressure.)
Page 7 of 9 n:e o
e s-m e
e m
e or
~
Tabic VI (Continued)
Appendix J Tech Spec Item Reference Appendix J Criteria Reference Present Oyster Creek Technical Specification J
14 III.B.3 Acceptance criterion.
The combined 4.5.F.1 If the total leakage rates listed and leakage rate for all penetrations and valves below as adjusted to test pressure of III.C.3 subject to Type B and C tests shall be 20 psig are exceeded, repairs and less than 0.60 La.
Leakage from containment retests shall be performed to correct isolation valves that are sealed with fluid the condition.
from a seal system may be excluded when determining the combined leakage rate (a) Doubic gasketed seals 10'. Lto (20) provided that:
(b) Testable penetrations and isolation (a)
Such valves have been demonstrated valves 30% Lto (20) 3 to have fluid leakage rates that do not exceed those specified in the (c)
Primary containment air purge Technical Specifications or associated penetrations and reactor building bases and, to torus vacuum relief valves 50% Lto (20)
(b) the installed isolation valve seal-water system fluid inventory is sufficient (d) Any one penetration or isolation to assure the sealing function for at valve 5% Lto (20)
Icast 30 days at a pressure of 1.10 Pa.
15 III.C.1 Type C tests shall be performed by local Not addressed in present Technical
'y pressurization. The pressure shall be applied Specifications.
~/
in the same direction as that when the valve would be required to perform its safety function, unless it can be determined that the results from the tests for a pressure applied in a different direction will provide equivalent or more conservative results.
The test methods in III.B.1 may be substituted where appropriate.
Each valve to be tested shall be closed by normal operation and without any preliminary exercising or adjustments (e.g., no tightening of valve after closure by valve motor).
Page 8 of 9
Table VI (Continued)
' Appendix J Tech Spec A
Item Reference Appendix J Criteria Reference Prcsent Oyster Creek Technical Specification 16
.III.C.2.a Valves unless pressurized with fluid 4.5.E.1 Primary containment testable penetrations (e.g., water, nitrogen) from a seal system, and isolation valves shall be-tested at shall be pressurized with air or nitrogen at a pressure of 35 psig each refueling out-a pressure of Pa.
age except bolted double-gasketed seals -
shall be tested whenever the seal is closed after being opened, and at least at each refueling outage.
4.5.E.2' The main steam line isolation valves are to be tested at a pressure of 20 psig during each refueling outage.
(MSIV's are presently tested at 20 psig and 35 psig.)
17 V.B.3 For each periodic test, leakage test results 4. 5. 11 Each integrated leakage rate test shall
.from Type A, B, and C tests shall be re-be the subject of a summary technical ported. The report shall contain an analysis report including results of the local and interpretation of the Type A test leakage rate tests. The' report shall results and a summary analysis of periodic include analysis and interpretation of Type B and Type C tests that were performed the results which demonstrate compliance since the last Type A test.
Leakage test in meeting the specified leakage rate results f rom Type A, B, and C tests that limits.
failed to meet the acceptance criteria of III. A. S. (b), III. B. 3 and III.C. 3, respectively, (Although no specific reporting require-shall be reported in a separate accompanying ments are given for other than those local summary report that includes an analysis and leakage rate tests performed at the interpretation of the test data, the Icast-time of a Type A test, the annual tests squares fit analysis of the test data, the are a topic of the summary technical instrumentation error analysis, and the report.)
structural conditions of the containment or components, if any, which contributed to the failure in meeting the acceptance criteria.
Results and analyses of the supplemental
(
verification test employed to demonstrate the validity of the leakage rate test measurements shall also be included.
e Page 9 of 9 t
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