ML20116N909
| ML20116N909 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 05/02/1985 |
| From: | POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | |
| Shared Package | |
| ML20116N908 | List: |
| References | |
| NUDOCS 8505070395 | |
| Download: ML20116N909 (10) | |
Text
p-ATTACHMENT I TO JPN-85-39 Proposed Technical Specification Chances Related To Primary Containment Airlock-Test Requirements PTS-80-20 New York Power Authority James A. FitzPatrick Nuclear >>ower Plant Docket No. 50-333 50 395 50
JAFNPP 4,7 (cont'd)
L The third test of each setoshall.be-conducted when:the plant is shutdown-for the 10-year 1 plant inservice inspections.
i.
Permissible periods.for testing.
The performance of Type A tests shall be limited to periods-when'the plant facility-is nonoperational-and l
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' l
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.
173 i
A
^
JAFNPP 4.7 (cont'd) c) Within three days of opening.
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.
Amendrent No.
173a
- Exemption to 10 CFR 50, Appendix J l
JAFNPP 4.7
.(cont'd) 4
?
~
(5) ~ Type C test.
Type C tests shall.be performed during each-reactor shutdown for refueling but in no case at intervals:
greater than two years.
(6) Other-leak rate' tests specified in l
Section 4.7d 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 resealing 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 applicable, for the area affected by the modification.
The measured leakage from this test shall be included in the test report.
The acceptance criteria as appropriate, shall be met.
Minor modifications, replacements, or re-2 sealing on seal-welded doors, performed directly prior to the conduct of a scheduled Type A test do not require a separate test.
s-Amendment No. g i
~
174
JAFNPP 4.7 BASES - (cont'd) assumption-of no holdup in the As most leakage and deterioration of secondary containment, resulting in integrity is expected to occur a direct release of. fission products through penetrations, especially from the primary containment through those with resilient seals, a the filters and stack to the periodic leak rate test program of environs.
Therefore, the specified such penetrations is conducted at primary containment leak rate and the peak pressure of 45 psig to filter efficiency are conservative insure not only that the leakage and provide additional margin remains acceptably low but also that between expected offsite. doses and the sealing materials can withstand 13CFR100 guidelines.
the accident pressure.
For airlock leak test, a seal test at the peak The maximun allowable test leak rate pressure could be substituted for the at the peak pressure of 45 psig (pa) complete airlock test, if no mainte-is 0.5 weight percent per day (Lam).
nance work is done which could affect The maximum allowable test leak rate the sealing capability of the airlock.
at the reduced pressure of 23 psig (P ) will be verified to be The leak rate testing program was t
conservative by actual primary originally based on AEC guidelines -
containment leak rate measurements for development of leak rate testing at both 45 psig and 23 psig upon and surveillance schedules for completion of the containment reactor containment vessels, (16) structure.
and discussed in Question 5.4 of the FSAR.
With the exceptions listed in To allow a margin for possible Table 4.7-2, the system conforms Icakage deterioration between to the latest AEC guidelines (17).
intervals, the maximum allowable The exceptions stated in leak rate (Ltml, which will be met Table 4.7-2 are necessary since to remain on the normal test additional requirements were added schedule, is 0.75 Lt.
In addition, after the systen was designed.
it is intended to operate.the primary containment structure at a B.
Standby Gas Treatment System and slicht positive pressure to C.
Secondary containment continuous 1v monitor primary containment leakage.
Initiating reactor building isolation and operation of the Standby Gas Treatment System to maintain at least a 1/4 in. of water vacuum within the secondary containment provides an adequate test of the operation of the reactor Ar.cndnent I:o.
194
r p.
4 ATTACilMENT II TO JPN-85-39 Safety Evaluation Related To Primary Containment Airlock Test Reouirements PTS-80-20 l
i l
l l
l l
l New York Power Authority James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Nay 2, 1985 l
p-
~
~7 Section I Doucription of the Chancos The proposed changes to the Technical Specifications are shown in Attachment I to the Application for Amendment.
Those changes occur in Section 4.7.A pages 173, 173a and 174 and Section 4.7.A BASES page 194.
The proposed changes reflect the NRC's amendment to 10 CFR 50 Appendix J, dated October 22, 1980, regarding containment airlock testing requirements.
In the proposed amendment, the following changes are incorporated:
a) The timo specified for testing the airlocks, which are opened during periods when containment integrity is required, has boon increased from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
b) Test pressure and leakage critoria for the airlocks have been specified.
)
c) A seal test has boon specified in lieu of the entire airlock test when: containment integrity is to be established following a period during which it was not required; and, no m4intenance has boon performed on the airlock that could affect its scaling capability.
As por Appendix J to 10 CPR 50, paragraph III.D.2.b(ii), a complete airlock tost is required at the end of the period wher. containment intagrity is not required.
The Authority hereby requests an exemption from this requirement in accordance with 10 CFR 50.12.
Justification for this exemption is provided below.
d) The numbering of Sections 4.7.A.2.o(3) and 4.7.A.2.e(4) was changed to 4.7.A.2.o(5) and 4.7.A.2.o(6), respectively, as a result of the changes mado above.
_Soction II Purpose of the Chances The purpose of the changes is to provido greator flexibility with respect to airlock testing when the airlocks are in frequent uso.
The changes would also facilitato visual inspections during plant heat-up and pressurization.
Section III Impact of the Chancos The following is a justification to substitute a seal test in lieu of the entire airlock test for the conditions stated above.
Testing of the airlock (s) at Pa (45 pcig) following primary containment ontry, and prior to establishing primary containment intogrity, requires installation of the airlock innor door strong backs, as the applied test pressure exerts a forco on the door in the direction opposite to that of the accident pressure direction and could move the door off the sealing surface.
11-1 c
a e
Installation of the strong backs must commence approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to the nood to establish primary containment integrity.
During this 24-hour period, approximately one (1) hour is required to inspect the door seals and door seat surfaces, throo (3) hours is required to install the strong backs, and 12 to 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> is required to pressurize the airlock to 45 psig, stabilize the test pressure and measure the leak rate.
Adding four (4) hours to this sequence for resolution of unanticipated problems, results in 20 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to complete air lock leak testing.
During the period of 20 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> required to complete the airlock leak testing, the primary containment is inaccessible.
As a result, all work inside the primary containment must be completed approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to establishing primary containment integrity or plant start-up must be delayed to allow completion of the airlock test.
In either caso, plant start-up in effectively delayed by approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Airlock testing would also cause additional delayc for re-entry into the primary containment in order to conduct a visual inspection of systems and components.
This re-entry can only be conducted after the airlock is depressurized requiring 4 to 0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />, and the strong backs are removed requiring approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
As an alternative, testing of the airlock door seals at Pa (45 psig) with a leakage limit of 120 SCFD provides a positivo demonstration of seal tightness and requires approximately 30 minutos to conduct.
Following completion of door seal testing, the airlock door can be opened to permit access within five (5) minutes.
As a result, little or no delay in conducting plant start-up is encountered and the ease of access to primary containment enables an active and thorough inspection of the systems and components insido primary containment during plant heat-up and pressurization.
The entire airlock test, and the installation and removal of the strong backs results in an estimated expenditure of approximately 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> and 0.15 man-com compared with 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> and 0.025 man-tem for seal testing only.
Furthermoro, the periodic 6 month test of the entico airlock and the specified coal tonts assure that the airlock is properly sealed, and would perform its design function.
This oxomption is also included in the Standard Technical Specifications.
Ilaced on the above stated reasons, the Authority considors that a seal test can be substituted in lieu of a complete airlock test for the abovo mentioned conditions without affecting the nato operation of the plant.
11-2
/
r 2
I o
The proposed changes do not change any system or subsystem and will not alter the conclusions of either the FSAR or SER accident analysos.
Operation of the Fitzpatrick plant in accordance with the proposed amendment would not:
1) involve a significant increase in the probability or consequences of an accident previously evaluated because:
a) the changes are intended to provide greater flexibility for airlock testing and facilitate visual inspections during plant heat-up and pressurization, b) A seal test is substituted in lieu of an entico airlock test, when: containment integrity is to be established following a period during which it was not required; and, no maintenance has boon performed on the airlock that could affect its l
sealing capability.
This providos adoquato assurance that the airlock and airlock seals will perform their design l
function.
It should be noted that substituting a soal test l
in lieu of an airlock test has boon incorporated into the Standard Technical Specifications.
l 2) create the possibility of a now or diffotont kind of accident from any accident previously evaluated, because the changes l
provide greater flexibility for surveillance testing of airlocks.
I 3) involve a significant reduction in margin of safety because:
a) the periodic 6 month tests of the entico airlock and the specified seal tests assure that the airlock is properly sealed, and will torform its design function.
Section IV Implementation of the Chancea Implementation of the changes, as proposed, will not impact the ALARA or firo protection programs at Fitzpatrick, nor will the changes impact the environment.
Section V Conclunion The incorporation of those changos:
a) Will not change the probability or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the Safety Analysis Hoport; b) Will not increase the possibility of an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report; II-3
o c) Will not reduce the margin of safety as defined in the basis for any Technical Speelfications;.
d) Does not constituto an unreviewod safety question as defined j
in 10 CFR 50.59; and l
e) Involves no significant hazards consideration, as defined in t
(~
10 CPR 50.92.
l Section VI References i
1)
Amendment to the Code of Federal Regulations 10 CFR 50 Appendix J. dated October 22, 1980.
l 2)
NYPA letter, J.P.
Bayno to D.B. Vassallo (NRC), dated October 1, 1984 (JPN-84-60) regarding same subject.
3)
James A. FitzPatrick Nuclear Power Plant Final Safety Analysis Report (FSAR), Rev 0, July 1982, Section 5.2.
4)
James A. FitzPatrick Nuclear Power Plant Safety Evaluation l
Report (SER).
i I
l l
I II-4
-