ML20128L486
| ML20128L486 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 10/09/1996 |
| From: | Bajwa S NRC (Affiliation Not Assigned) |
| To: | William Cahill POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| References | |
| NUDOCS 9610150094 | |
| Download: ML20128L486 (4) | |
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UNITED STATES j
j NUCLEAR REGULATORY COMMISSION t
WASHINGTON, D.C. 2066M001 October 9, 1996 Mr. William Cahill, Jr.
Chief Nuclear Officer Power Authority of the State of New York 123 Main Street White Plains, NY 1601
SUBJECT:
RELIEF REQUEST V61 FOR THE SECOND TEN YEAR INTERVAL (JULY 28, 1995 TO JUNE 28, 1997) 0F THE INSERVICE TESTING PROGRAM
Dear Mr. Cahill:
By letter dated October 2,1996, the Power Authority of the State of New York (PASNY) requested relief for the Second Ten Year Interval (July 28, 1995 to June 28, 1997) Inservice Testing Program to allow James A. FitzPatrick (JAF) to take full advantage of the provisions of 10 CFR Fart 50, Appendix J, Option B during RF0-12.
By letter dated March 27, 1996, as supplemented by April 24, 1996 and August 15, 1996, JAF submitted an amendment request to permit implementation of 10 CFR Part 50, Appendix J, Option B, with an exception to the guidelines of Regulatory Guide 1.163 for Type C testing of primary containment isolation valves in the reverse (non-accident) direction.
Amendment No. 234 was issued on October 4,1996.
PASNY requests relief from the testing requirements contained in ASME Section XI, 1983 Edition through Winter 1981 Addendum, Subsection IWV-3420. This specifies that Category A and AC leakage rate testing is performed every 2 years. As an alternative, PASNY requests that containment isolation valve testing shall be performed in accordance with ASME/ ANSI OMa-1988, Part 10,
" Inservice Testing of Valves in Light-Water Reactor Water Power Plants,"
Paragraph 4.2.2.2, " Containment Isolation Valves." This paragraph states that Category A valves, which are containment isolation valves shall be tested in accordance with 10 CFR Part 50, Appendix J.
As a consequence of this change, Category A containment isolation valves that do not provide a reactor coolant system pressure isolation function will be analyzed in accordance with paragraph 4.2.2.3(e) of Part 10, and corrective actions will be made in accordance with paragraph 4.2.2.3(f) of Part 10.
These additional actions are required in order to comply with 10 CFR 50.55a(b)(2)(vii). This request is consistent with the provisions of 10 CFR 50.55a(f)(4)(iv).
The alternative to the ASME Code is necessary to fully implement Appendix J, Option B, because the 1980 Edition of the Code does not differentiate between containment isolation valves and other valves that have a leak-tight safety function.
DFcQ 9610150094 961009 8 "
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Sn NRC FR.E CENTER COPY L
l The NRC staff has reviewed PASNY's October 2, 1996, proposal and has determined that it is acceptable to use a portion of the most recent edition 1
of the ASME Code incorporated by reference in 10 CFR 50.55a (i.e., 1989 Edition) which references Part 10 of the ASME/ ANSI 1987 Operations and j
- aintenance Standards (Part 10) for inservice testing of valves. The approval j
is pursuant to 10 CFR 50.55a(f)(4)(iv) subject to the requirements of 10 CFR 50.55a(b)(2)(vii).
In its application, PASNY stated that, in accordance with 10 CFR 50.55a(b)(2)(vii), it would analyze valves that do not provide a reactor coolant pressure boundary function in accordance with paragraph 4.2.2.3(e) and that it would make any corrective actions in accordance with paragraph 4.2.2.3(f) of Part 10.
Option B of 10 CFR Part 50, Appendix J, provides that a licensee may, if it so chooses, implement a performance-based containment isolation valve leak-rate testing program.
The provisions of Option B allow that, for certain valves, the local leakage rate testing (referred to as Type C testing in Appendix J) need not be performed every refueling outage. Use of the later edition ASME l
Code (the 1989 Edition instead of the 1980 Edition) is necessary because containment isolation valves are specifically addressed in Part 10, referring the user to Appendix J for the leakage rate testing requirements for the containment isolation function.
Part 10 does not specify a frequency of leakage testing the containment isolation valves.
Valves that have a dual function (i.e., an additional leak-tight function other than containment i
isolation, such as pressure isolation valves) are to be tested in accordance with the requirements of the edition of the ASME Code to which JAF is licensed (currently the 1530 Edition through Winter 1981 Addendum). Therefore, this approval would not supersede any leak-tight safety function test requirements j
applicable to the subject valves.
If you have any questions.on this matter, contact the JAF Project Manager,
{
Karen Cotton at (301) 415-1438.
j Sincerely, A4/w S. Singh Bajwa, Acting Director Project Directorate I-l Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket No. 50-333 cc:
See next page j
i i
William Cahill October 9, 1996 The NRC staff has reviewed PASNY's October 2, 1996, proposal and has determined that it is acc ptable to use a portion of the most recent edition of the ASME Code incorporated by reference in 10 CFR 50.55a (i.e., 1989 Edition) which references Part 10 of the ASME/ ANSI 1987 Operatfons and
- aintenance Standanfs (Part 10) for inservice testing of valves. The approval is pursuant to 10 CFR 50.55a(f)(4)(iv) subject to the requirements of 10 CFR 50.55a(b)(2)(vii).
In its application, PASNY stated that, in accordance with 10 CFR 50.55a(b)(2)(vii), it would analyze valves that do not provide a reactor coolant pressure boundary function in accordance with paragraph 4.2.2.3(e) and that it would make any corrective actions in accordance with paragraph 4.2.2.3(f) of Part 10.
Option B of 10 CFR Part 50, Appendix J, provides that a licensee may, if it so chooses, implement a performance-based containment isolation valve leak-rate testing program. The provisions of'0ption B allow that, for certain valves, the local leakage rate testing (referred to as Type C testing in Appendix J) need not be performed every refueling outage.
Use of the later edition ASME Code (the 1989 Edition instead of the 1980 Edition) is necessary because containment isolation valves are specifically addressed in Part 10, referring the user to Appendix J for the leakage rate testing requirements for the containment isolation function.
Part 10 does not specify a fregrency of leakage testing the containment isolation valves. Valves that ha e a dual function (i.e., an additional leak-tight function other tnan contanament isolation, such as pressure isolation valves) are to be tested in accordance with the requirements of the edition of the ASME Code to which JAF is licensed (currently the 1980 Edition through Winter 1981 Addendum). Therefore, this approval would not supersede any leak-tight safety function test requirements applicable to the subject valves.
If you have any questions on this matter, contact the JAF Project Manager, Karen Cotton at (301) 415-1438.
Sincerely original s,igned by D. Hood for S. Singh Bajwa, Acting Director Project Directorate I-1 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket No. 50-333 Distribution SVarga SLittle GHill(2)
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l William J. Cahill, Jr.
James A. FitzPatrick Nuclear 5
I Power Authority of the State Power Plant of New York cc:
Mr. Gerald C. Goldstein Regional Administrator, Region I Assistant General Counsel U.S. Nuclear Regulatory Commission Power Authority of the State 475 Allendale Road of New York King of Prussia, PA 19406 1633 Broadway New York, NY 10019 Mr. F. William Valentino, President New York State Energy, Research, Resident Inspector's Office and Development Authority U. S. Nuclear P.egulatory Commission 2 Rockefeller Plaza P.O. Box 136 Albany, NY 12223-1253 Lycoming, NY 13093 Mr. Richard L. Patch, Director Mr. Harry P. Salmon, Jr.
Quality Assurance Resident Manager Power Authority of the State James A. FitzPatrick Nuclear of New York Power Plant 123 Main Street P.O. Box 41 White Plains, NY 10601 Lycoming, NY 13093 Mr. Gerard Goering Ms. Charlene D. Faison 28112 Bayview Drive Director Nuclear Licensing Red Wing, MN 55066 Power Authority of the State of New York Mr. James Gagliardo 123 Main Street Safety Review Committee White Plains, NY 10601 708 Castlewood Avenue Arlington, TX 76012 Supervisor Town of Scriba Mr. Arthur Zaremba, Licensing Route 8, Box 382 Manager Oswego, NY 13126 James A. FitzPatrick Nuclear Power Plant Mr. Robert G. Schoenberger, P.O. Box 41 Vice President Lycoming, NY 13093 and Chief Operating Officer Power Authority of the State of New York 123 Main Street White Plains, NY 10601 Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271 l
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