Text

Proposed Tech Specs Re Implementation of Option B to 10CFR50,App J
	ML20128L837
Person / Time
Site:	Zion File:ZionSolutions icon.png
Issue date:	10/04/1996
From:	; COMMONWEALTH EDISON CO.
To:	;
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ML20128L830	List: ML20128L823; ML20128L837;
References
	NUDOCS 9610150206
	Download: ML20128L837 (21)
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ATTACHMENT B Part 1 - Annotated Copy of Revised Technical Specifications 9610150206 961004 PDR ADOCK 05000295 P

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LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT

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3.10 CONTAINMENT STRUCTURAL INTEGRITY (per unit) 4.10 CONTAINMENT STRUCTUP.AL INTEGRITY (per unit)

OBJECTIVE:

To insure that the containment structure meets To establish the testing requirements to assure r

i its design requirements throughout plant life.

containment structural integrity.

r SPECIFICATION:

1.

Containment Leakage Rate Testing j

1.

Containment Leakage Rate Testing A.

Surveillance and testing of the A.

Containment Leakage Rate shall be containment shall be performed as limited to:

follows:

1.

An overall inte rated leakage 1.

The containment Type A leakage rate ef+ less t an or equal to rate shall be determined in i

thatispecified by the accordance'with:the Containment senfermancewith'10gFR50 Leakage Rate Tes Containment Leakage Rate Testing Program.

Appendix J :nd appreved 2.

Less than er equal to exemptions.

b,, 0.10 percent by acight cf the contair.m:nt air per 2.

Th0 leakage rate test shall 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months at P, (47 psig), er be performed at er above the design basis accident b.

Less than or equal to pressure P. (1' psig), er at b,, where L,-is--as cr abcvc the reduced i

computed in 10CFP 50 pressure P (25 psi 9)-

[

r Appendix J and 2 proved i

exemptiens, istEcmaximum b.

Deleted i

allowable leakage rate at pressure P, (25 psig) l l

2.1 A combined leakage rate of less

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than or equal to that specified by the Containment Leakage Rate Testing Program 0.50 L,v-for all l

penet~ rations and valves subject to Type B and C tests, when t

pressurized to P,.

APPLICABILITY: Modes 1, 2, 3, 4 and 7

Refer to note en page 214.

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212 Amendments Nos. 165 and 153 I

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LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT 3.10.1.A (Continued)

' 10.1.A.I.

c.

The maximum 21?ceable leakage ACTION:

rate L -or--l,, as applicable, l

7 Shal! _c computed i" accordance With either (a) the measured overall integrated with the appropriate paragraphs containment leakage rate exceeding 0.75 L,-er of 10CFR50 Appendix J and 0.75 L,, as applicable, or (b) w+th-the measured approved exemptions.

combined leakage rate for all penetrations and valves subject to Type B and C tests, exceeding that 4.10.1. A.2.* Type B and C tests (except air _ lock s

specified by the Containment Leakage Rate Testing tests) shall be performed in accordance Program, exceeding 0.50 ', restore the applicable with-that specified by the Containment cverall integrated leakage rate to less than or Leakage Rate Testing Program.-at-#,-er equal to that'specified by'the Containment--Leakage above accordance eith the"previsions Rate Testing Program 0.75 L, or less than er equal of the appropriate Section of 10CFR50 to 0.75

!.,, as ~ hpplichble, and the combined leakage Appendix J and approved exemptions.

j rate for al' penetrations subject to Type B and C i

tests te less than or equal to 0.5 L*- prior to 3.

Air locks shall be tested and i

entering MODE 4.

demonstrated OPERABLE per Surveillance j

Requirement 4.10.2.

l 4.1 Type A, B, and C leakage rate tests I

shall be considered to be satisfactory

(

if the. acceptance criteria delineated by Program are met. 40CFge Rate Testing the' Containment Leaka 50 Appendi" J and l

approved exemptions are met.

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5.

Leakage from containment isolation valves sealed by the Isolation Valve Eeal Water system may be excluded from the combined Type B and C leakage rate.

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m. m. +. m -. m.,mm o i,o.

Refer to note en page 21d.

f m cm.

c o. m. m.+m e 3s..

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213 Amendment Nos. 165 and 153 t

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i LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENT 3.10.1.A (Continued) 4.10.1.A.

6.*

The retest schedules for Type A, B, and f

C. tests.shall be in accordance.with the-ContainmentiLeakageJRate? Testing Programfcp-r p?icti Sectic ~5f 10CFR50

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7.

Inspection and reporting of. tests shall be in accoraance with the Containment l'eakage Rate. Testing:ProgCFR50 Appendix !

ram.

appropr'icte'Section of I.

J nd approved exemptions.

1 A!he fellowing exceptica applic :

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Drior te entering Mcdc 5 fer refueling cutage ZlRld, the Type C leak rate testing requirements of this

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t 214 Amendment Nos. 165 and 153

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LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT I

3.10.2 Containment Air Locks 4.10.2.

Containment Air Locks o

t A.

Each containment air lock shall be OPERABLE A.

Each air lock shall be demonstrated l

with:

OPERABLE:

I 1.

Both doors closed except when the air i

lock is being used for normal entry Veri fy7 thatithe1 overall ? ai E l ock Lleakage rate,'

and exit through the containment, then andithe leakage ratecfor ea~ h' door, are less '

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at least one air lock door shall be thanforLequalzto that: specified by the I

l closed, and Containment.:LeakagefRate-Testing Program.

2.*

The air lock leakage rate shall belless Verifications 'shall; be conductediat the.

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than'or equalf toithat specified:byf the ^

frequencyispecifiedLby?the: Containment L~eakage Containment 1 Leakage;RateuTesting Program.

Rate >TestingfProgram. "

, when combined ^w:th other Ty e S'and'C i

testresults,shallbelesstEnerequal 1.

Within 72 Scurs followin cach cpening i

tc 0.50 L, at '7 psig (P,tr

{cxceptwhentheairlec!isScingused

.cr multi-le entries, ther at least APPLICABILITY: Modes 1, 2, 3, 4 and 7 enceper72heur;);

1 Verif;' thet the leake^!

retc frc c.

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the air lock decr sca is less l

ACTION:

a.)

With one containment air lcck door than er equal to 1.0 SCFH at a j

inoperable:

test pressure (P ) cf greater i

y l.

Maintain at least the OPERABLE air than er equal to 2.5 psig; or verify that the leaka^

the air lock decr sca!c rate from lock door closed and either restore is les:

1 the inoperable air lock door to i

OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or than er equal to 1.75 SCFM at a lock the OPERABLE air lock door closed.

test pressure (P,) of greater than er i

2.

Operation may continue until e ual tc 10.0 sig.

j performance of the next required b.

I?theairlecEdccrsealtest

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overall air lock leakage test provided identific: a leakage rate greater i

that the OPERABLE air lock door is than 1.0 SCFM at a test prescurc vcrified locked closed at least once fR ) cf greater than er equal to y

per 31 days, 2.5 p;ig er i 75 SCFP at test 3.

Otherwise be in at least MODE 3 within pressure (P,) cf greater than er i

the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within the n~.,i

+n in n

--en

+ tan i

,n following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

3?3"$1i"alf'icEE'T$aE3g3t3st I

shal' be performed at a prescurc l

Refer te note en p "aO 214 9,,%

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acceptance criteria shall be as

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l 214a Amendment Nos. 121 and 110 1

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LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT

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3.10.2 (Continued)

' 10.2.A (Continued) 4.

The provisions of Technical 2.

By conducting everall air !cck leakage te t:

Specification 3.0.4 are not at prc Surc (P.) Of '7 psig Or greater and within t!c 'e Overall air lcck leakage i applicable.

veri fyin" th imit:

b.)

With the containment air lock 2.

At 5 month intervals inoperable, except as a result of an b.

o-icr to entering *!cdc A; if in Mede 5 inoperable air lock door, maintain at greater than cr equal 10 7 day: and

'least one air lock door closed; restore containmentinte!rityhasbeenbrcken the inoperable air lock to OPERABLE (both d0cr: Open.

status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be in at least MODE 3 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 3.

At least once per 6 mo1ths by i

and in MODE 5 within the following 30 verifying that only one door in each i

hours.

air lock can be opened at a time.

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214b Amendment Nos. 90 and 80 l'

6;10GContainsknt0Lesksde' Rats 5Testind*Pr6eram li J' A? program 3 hull;beTestahlisheditolimpl'emenMthMisakagdTrateIthstihgTofTthelcontai.nsientias?rsquiredfbyllo t

CFR 50 54(o) sand LIO CFR150h Appendix;J T Opt w*(3 has i modi fied : by% approvedtexemptions $:Thi s). programish'all? be i

7 in!accordance witht theTguidelines:;containedTinlRegslatory: Guidef11163U" Performance-Ba's'edjContainmentiLeak"s TestiProgram y dated.;Septemaer): 1995 ;; wi thl: thef f61.l owi ng [excepti on :1 ~'^

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Sseti6nM012;lidflNE1794LO1MRsvisioniOMiffnotTapplicableit6 UnitilipehetpationTPI16GThis'excep" tis 6

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for]penetrationf P-16j shallf expirejatLtheicampleti.onlofj unitl1[ outage)ZlR15b " '

LThe^peakicalculatedl containment;}internaly reslsurejforithe design / s~sisllossfoffdoolantfaccidentij PMis

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2.

46;79;psig.1xTheccontainment.Nasign;;pressuresis(47dpsig.,

3;

$The 'maximunfallowable'dontainmentileaf jjs. rate 3G;htlP,*,"sh'allf be f-l:J021%Toffcontiinment? air] weight [per day]

4.1 lL'eaksgeLrateLacceptanceiriterlatare

a. -

Centhinmenti.leakagiratsi acc'eptancef critsrioniis?f jl.0;L,i. "During f the[firstludit?stsrtuf following testing in j accordancejwith: this program.jthe :1eakagei rate' acceptance:criteriaTare;;<: 0;60]L3 for: the Type B.'and ~ C tests l and:!< 0' 75~. L,' forf TypeJ A; tests; i

b.-

fair lock-testing acceptance ~ criteria;are:

1):

Coverall.Lai r:'.1,0ck - l eakage :; i s ;f } 0 ; 6 g whenicombi ned : wi th al.10Typs] Blind ! C ltestf resul t'sl atial test l

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pressure!of 1 F,.

i "2)?

~For.each door.f.1eakage ratetisff;1'.0?SCFH.when; tested':at l2j5[ psi'gjand % 10lpiig yo Q 4:7.5 SCFH when-testediat;:-1 10fpsig.

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' Th'e~provi.sions of Surveillance 1Requir.enent-4.0;2idolnottapply to the test < frequencies!specified Jin;':ths

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Containment Leakage Rate TestingfProgram.

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6.-

LThe provisions' of ' Surveill'anc'el RsquirementL4.0.3 fare capplicableito the?Containmentileakage;:.RatelTesting Program-

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326a I

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ATTACHMENT B Part 2 - Clean Copy of Revised Technical Specifications

LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT 3.10 CONTAINMENT STRUCTURAL INTEGRITY (per unit) 4.10 CONTAINMENT STRUCTURAL INTEGRITY (per unit)

OBJECTIVE:

t To insure that the containment structure meets To establish the testing requirements to assure its design requirements throughout plant life.

containment structural integrity.

i SPECIFICATION:

1.

Containment Leaktge Rate Testing j

1.

Containment Leakage Rate Testing A.

Surveillance and testing of the A.

Containment Leakage Rate shall be containment shall be performed as limited to:

follows:

t 1.

An overall integrated leakage 1.

The containment Type A leakage rate less than or equal to that rate shall be determined in l

specified by the Containment accordance with the Containment Leakage Rate Testing Program.

Leakage Rate Testing Program.

r 2.

A combined leakage rate less than or equal to that specified by the Containment Leakage Rate Testing Program for all penetrations and valves subject to Type B and C tests, when piessurized to P,.

APPLICABILITY: Modes 1,.

2, 3, 4 and 7 r

i 212 Amendments Nos.

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LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT

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3.10.1.A (Continued) f ACTION:

4.10.1.A.2.

Type 8-and C tests (except air lock i

tests) shall be performed in accordance With either (a) the measured overall integrated with that specified by the Containment j

containment leakage rate, or (b) the measured Leakage Rate Testing Program.

{

combined leakage rate for all penetrations and valves subject to Type B and C tests, exceeding that 3.

Air locks shall be tested and

[

specified by the Containment Leakage Rate Testing demonstrated OPERABLE per Surveillance l

Program, restore the applicable leakage rate to less Requirement 4.10.2.

than or equal to that specified by the Containment t

Leakage Rate Testing Program prior to entering MODE 4.

Type A, B, and C leakage rate tests shall be considered to be satisfactory

[

4.

if the acceptance criteria delineated by the Containment Leakage Rate Testing Program are met.

5.

Leakage from containment isolation

[

valves sealed by the Isolation Valve j

Seal Water system may be excluded from the combined Type 3 and C leakage rate.

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213 Amendment Nos.

LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENT 3.lC.I.A (Continued) 4.10.1.A.

6.

The retest schedules for Type A, B, and C tests shall be in accordance with the Containment Leakage Rate Testing Program.

7.

Inspection and reporting of tests shall be in accordance with the Containment Leakage Rate Testing Program.

214 Amendment Nos.

N.

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1 LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT

~

3.10.2 Containment Air Locks 4.10.2.

Containment Air Locks A.

Each containment air lock shall be OPERABLE A.

Each air lock shall be demonstrated OPERABLE:

with:

1.

Both doors closed except when the air Verify that the overall air lock leakage rate, lock is being used for normal entry and the leakage rate for each door, are less and exit through the containment, then than or equal to that specified by the at least one air lock door shall be Containment Leakage Rate Testing Program.

closed, and Verifications shall be conducted at the.

2.

The air lock leakage rate shall be less frequency specified by the Containment Leakage than or equal to that specified by the Rate Testing Program.

Containment Leakage Rate Testing Program.

At least once per 6 months by verifying that

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APPLICABILITY: Modes 1, 2, 3, 4 and 7 only one door in each air lock can be opened

.at a time.

ACTION:

a.)

With one containment air lock door inoperable:

1.

Maintain at least the OPERABLE air i

lock door closed and either restore I

the inoperable air lock door to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or lock the OPERABLE air lock door closed.

2.

Operation may continue until performance of the next required overall air lock leakage test provided that the OPERABLE air lock door is i

verified locked closed at least once per 31 days.

3.

Otherwise be in at least MODE 3 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

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214a Amendment Nos.

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LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT 3.10.2 (Continued) 4.

The provisions of Technical Specification 3.0.4 are not applicable.

b.)

With the containment air lock inoperable, except as a result of an

.. operable air lock door, maintain at least one air lock door closed; restore the inoperable air lock to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be in at least MODE 3 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 5 within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

214b Amendment Nos.

~._.-

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6.10 Containment Leakage Rate Testing Program 1.

A program shall be established to implement the leakage rate testing of the containment as required by 10 l

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-t Test Program," dated September 1995, with the following exception i

Section 10.2.1 of NEI 94-01, Revision 0, is not applicable to Unit 1 penetration P-16.

This exception for penetration P-16 shall expire at the completion of Unit 1 outage Z1R15.

2.

The peak calculated containment internal pressure for the design basis loss of coolant accident, P, is

[

46.79 psig. The containernt design pressure is 47 psig.

l 3.

The maximum allowable containment leakage rate, L, at P,, shall be f 0.1% of containment air weight per j

t day.

4.

Leakage rate acceptance criteria are:

I a.

Containment leakage rate acceptance criterion is f 1.0 L,.

During tha first unit startup following i

testing in accordance with this program, the leakage rate acceptance criteria are_ < 0.60 L, for the j

Type B and C tests and < 0.75 L,' for Type A tests; i

b.

Air lock testing acceptance criteria are:

t 1)

Overall air lock leakage is f 0.6 L, when combined with all Type B and C test results at a test pressure of 1 P,.

[

2)

For each door, leakage rate is f 1.0 SCFH when tested at 1 2.5 psig and < 10 psig, or f 4.75 i

SCFH when tested at 1 10 psig.

5.

The provisions of Surveillance Requirement 4.0.2 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program.

l 6.

The provisions of Surveillance Requirement 4.0.3 are applicable to the Containment Leakage Rate Testing Program.

326a Amendment Nos.

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ATTACHNENT C EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATIONS in accordance with 10 CFR 50.92(c), Commonwealth Edison (CrmEd) has determined that the proposed amendment involves no significant hazards considerations in that operation of the facility in accordance with the proposed amendment would not:

l

1. Involve a sianificant increase in the probability or conseauences of an accident previously evaluated The proposed amendment cannot affect the probability of an accident since it involves only changes in the containment leakage rate testing program. There is no credible accident which can be initiated by containment leakage rate testing.

The proposed amendment will not affect the consequences of a accident since the allowable containment leakage rates, which determine the offsite consequences of a accident, are unchanged. Only the frequency of measuring the leakage rates may be changed.

2. Create the possibility of a new or different kind of accident from any accident previously evaluated The proposed amendment will not create the possibility of a new or different kind of accident since there are no changes to any systems, structures, or components, and no changes in the method of operation of any system, structure, or component.

3. Involve a sianificant reduction in a marain of safety The proposed amendment will not involve a significant reduction in the margin of safety. As documented in the 10 CFR 50, Appendix J, Option 8 Proposed Rule and Final Rule published in the Federal Register, the additional industry wide risk resulting from the proposed change is marginal and within acceptable limits.

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ATTACHMENT D ENVIRONMENTAL ASSESSMENT EXCLUSION Commonwealth Edison Company (Comed) has evaluated this license amendment request using the criteria for licensing and regulatory actions requiring environmental assessment in accordance with 10 CFR 51.21.

Comed has determined that this license amendment request meets the criteria for a categorical exclusion set forth in 10 CFR 51.22(c)(9), in that:

This change is proposed as an amendment to a license issued pursuant to 10 CFR 50, which changes a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, and which changes an inspection or a surveillance requirement, and the amendment meets the following specific criteria:

(1)

The amendment involves no significant hazards considerations.

The determination that the proposed amendment will not create a significant hazard is documented in Attachment C to this LAR.

(ii) There is no significant change in the types or significant increase in j

the amounts of any effluent that may be released offsite.

There will be no change in the level of controls or methodology used for processing of radioactive effluents or handling of solid radioactive waste.

(iii) There is no significant increase in individual or cumulative occupational radiation exposure.

The proposed amendment will not result in changes in the operation or l

configuration of the facility.

There will be no change in the level of controls or methodology used for processing of radioactive effluents or handling of solid radioactive waste, nor will the proposal result in any change in the normal radiation levels within the plant.

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ATTACHMENT E CONTAINMENT LEAKAGE RATE TESTING PROGRAM IMPLEMENTATION PLAN Comed has formed an Appendix J implementation task force to implement and interpret the new rule in a consistent manner throughout Comed.

Each Comed Nuclear Station (including Zion Station) is represented in the group.

The task force will provide generic guidelines for all Comed Nuclear Stations for the implementation of 10 CFR Part 50, Appendix J, Option B.

Requirement Source Documents Zion Station will irrorporate 10 CFR Part 50, Appendix J, Option B into the station containment leakage' rate testing program.

Zion Station will comply with the performance oriented and risk-based approaches including all performance based requirements and the following supporting documents:

U. S. Nuclear Regulatory Commission Regulatory Guide 1.163, 1

" Performance-Based Containment Leak-Test Program," September 1995 NEI 94-01 Revision 0, " Nuclear Energy Institute Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J,"

l Rev. 0 ANSI /ANS-56.8-1994, "American National Standard for Containment System Leakage Testing Requirements" Component Leakage Limits Zion Station will use the administrative limits set by the Comed Appendix J Implementation Task Force for components requiring Type B and C leakage rate testing. To determine whether an as-found local leak rate test (LLRT) passed or failed, a component's measured leakage will be compared against its administrative limit.

These new administrative limits will be used to determine whether future or previous tests passed or failed.

Thus, the limits chosen will affect each component's Type B or C testing frequency.

Two limits will be specified for each component, a warning limit and an alarm limit. When the component's leakage rate is above the warning limit and below the alarm limit, then the component should be evaluated for repair.

This will not be counted as a performance failure.

When the component's leakage rate is above the alarm limit, then the component will be repaired, except as noted below. This will be counted as a performance failure.

Although administrative limits will be used to maintain the containment in good condition, it 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 L, where L, is defined as the maximum allowable primary containment leakage rate.

In the past, there have been instances where the leakage from one or more components has exceeded the alarm limits. To bring the leakage rate below the limit prior to start-up would have been very difficult and/or costly.

For those special cases, a safety evaluation was performed.

If this evaluation concluded that there was no significant safety impact, then the component (s) 1

ATTACHMENT E was(were) allowed to continue to leak in excess of the individual valve leakage limit until repairs could be conducted, provided that the limit of 0.6 L, was not exceeded. However, the test was still considered to be a failure.

Zion Station will continue to use this provision if necessitated by special circumstances.

Building Performance Baselines, Establishing Test Frequencies Type A Tests Per the new requirements associated with Appendix J, Option B, Type A testing shall be performed during a period of reactor shutdown at a frequency of at least once per 10 years based on acceptable performance history. Acceptable performance history will be as defined in NEl 94-01.

The new rule allows for reviewing past performar.ce history with several options to determine if past Type A tests were satisfactory.

In accordance with N[' 94-01, Sec. 9.2.3, as-Found Type A test results can be compared to 1.0 L, rather than the previous 0.75 L, criteria.

Leakage savings (repairs / adjustments) from Type B and C testable j

pathways which were added as penalties to the As-Found Type A test can be subtracted when reviewing previous Type A test results.

j The Type A test upper confidence limit from previous Type A tests may be i

recalculated using the Mass Point Methodology described in ANS-56.8-1994.

Zion Station has reviewed Type A test results as compared to the current requirements and criteria to establish a test frequency for the primary containment integrated leak rate test (ILRT).

In reviewing Type A history, it has been determined that the two most recent Type A tests for Units 1 and 2 have been below the 1.0 L, criteria.

Zion Station will therefore implement the 10 year Type A test frequency based on the criteria set forth in the new rule during the next refueling outage, Z2R14.

The corresponding due dates for the next required Type A test, based upon Option B, are March 2002 for Unit 1 and November 2002 for Unit 2.

Type B and C Tests Zion Station will formulate administrative procedures for documenting Type B and C testing performance.

A performance evaluation will be used to ensure that consistent criteria were applied to establish component baseline performance and their subsequent testing frequencies.

Zion Station has developed a computer and hard copy database to compile all the required leak rate historical data to be used in the evaluation process.

This database will continue to be updated with the most current as-found leak rate data acquired during the most recent refueling outages.

The performance history of each component will be evaluated against the administrative limit 2

_~

ATTACHMENT F DISPOSITION OF PREVIOUSLY APPROVED EXEMPTIONS 10 CFR Part Part 50, Appendix J, Option B, Paragraph V.B.1 states that specific exemptions to Option A that have been ap~ proved by the NRC are still applicable to Option B, if necessary, unless specifically revoked by the NRC.

The exemptions to Option A previously approved for Zion Station will be dispositioned as follows:

The one-time schedular exemption allowing a delay in performance of a Type A test on Unit 1, which was approved by the NRC in a letter dated July 12, 1995, will no longer be necessary.

The decreased frequency of testing allowed by Option B will eliminate the need for this exemption.

The one time schedular exemption allowing a delay in testing of Unit 2 penetrations P-60 and P-80 until Z2R14, which was approved by the NRC staff in a November 20, 1995 letter, will remain applicable until testing is completed during the outage.

The one time schedular exemption allowing a delay in testing of Unit 2 penetrations P-77 and P-102 until Z2R14, which was approved by the NRC staff in a December 28, 1995 letter, will remain applicable until testing is completed during the outage.

The permanent exemption allowing alternate methods for testing Unit 1 and Unit 2 penetrations P-70 and P-99, which was approved by the NRC staff in a December 11, 1995 letter, will remain applicable.

The basis for the exemption, and the alternate testing methods and acceptance criteria remain unchanged.

The permanent exemption allowing alternate methods for testing Unit 1 and 2 penetrations P-19, P-34, P-43, P-75, P-76 and P-88, which was approved by the NRC staff in a December 28, 1995 letter, will remain applicable. The basis for the exemption, and the alternate testing methods and acceptance criteria remain unchanged.

The permanent exemption decreasinn the test frequency for Unit 1 j

penetration P-16 will be revoked.

However, the proposed Containment Leakage Rate Testing Program contains a limited duration exemption from testing requirements for penetration P-16.

This exemption will provide ConiEd an opportunity to complete a modification that will permanently i

eliminate.he need to test the penetration.

In a December 28, 1995 letter, the NRC approved Comed's request to test the penetration only during Type A tests, which are conducted three times in a ten year service period under Option A to Appendix J.

Since Option B would allow reducing the frequency of Type A tests, the NRC further stated in the letter that "if the licensee adopts Option 8 of Appendix J for containment leakage rate testing at Zion Unit 1, the exemption for P-16 is hereby revoked and the matter will have to be reexamined under the requirements of Option B."

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ATTACHMENT F Comed plans to perform a plant modification during the next Unit I refueling outage, ZlR15, such that Type B testing will not be required for P-16.

The five tubing lines which pass through P-16 are part of the Reactor Vessel Leak Detection system.

Comed plans to decommission this system, and to close and deactivate the containment isolation valves for P-16.

During ZlR15, the five tubing lines which pass through P-16 will be cut, capped, and leak tested in accordance with the applicable standards.

Comed has included an exemption for penetration P-16 in the i

proposed Containment Leakage Rate Testing Program administrative j

specification 6.10.

This exemption will encompass the period from l

implementation of Appendix J Option B, until the completion of ZlR15.

Although the schedule for ZlR15 is currently under review, Comed expects l

the outage to end in late May or early June,1997.

l Comed considers that a limited duration (seven to eight months) i exemption for penetration P-16 will not present any significant risk to the public health and safety since there has never been a Type A leak 1

rate test failure at Zion attributable to a compression fitting leak on these lines. Therefore, a limited duration exemption for penetration P-16 is consistent with the underlying principles of a performance based program.

In addition, Containment Penetration P-16 is not required to be leakage rate tested until the next Type A Containment Leakage Rate Test.

Under Option A, Containment Leakage Rate Testing will not be required for Unit I until ZlR15. As such, the duration of the requested i

exemptio. will be consistent with the frequency of testing previously l

granted to the December 28, 1995 letter, C.Y. Shiraki - U.S. Nuclear

[

Regulatory Commission to D.L. Farrar - Comed, issuing exemptions from

-the requirements of 10 CFR 50 Appendix J, Containment Leakage Rate Testing (Reference 3).

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J ATTACHMENT E to rate component performance over the last three refuel outages.

In addition to a performance history evaluation, considerations such as service life, environment, design, system application, special service conditions, and safety impact / risk from failure will be reviewed and evaluated, and will be used to determine test frequency.

Additionally, v+ 3n maintenance is performed on valves that have been assigned an extended surveillance frequency, as-found leak. testing will be conducted to provide additional assurance that the extended surveillance frequency is warranted.

Technical Criteria & Testing Methodology Interpretation The administrative procedure (s) for the Containment Leakage Rate Testing Program will follow the requirements in the above listed source documents, and will contain performance criteria for Type A, B, and C testing.

The administrative procedure (s) will also contain a description of the record keeping and methodology for establishing test intervals for equipment and components within the scope of Containment Leakage Rate Testing Program.

The equipment and component test procedures will contain information on the proper techniques and methods for performing Type A, 8, and C tests, f

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ML20128L837

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