ML20128P473
| ML20128P473 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 10/09/1996 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20128P456 | List: |
| References | |
| NUDOCS 9610170271 | |
| Download: ML20128P473 (5) | |
Text
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UNITED STATES p
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,j NUCLEAR REGULATORY COMMISSION
'4 WASHINGTON, D.C. 20665 4001
(,.....f SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION j
RELATED TO AMENDMENT NOS.169 AND 173 TO FACILITY OPERATING LICENSE NOS. DPR-24 AND DPR-27 WISCONSIN ELECTRIC POWER COMPANY E. DINT BEACH NUCLEAR PLANT. UNIT NOS. 1 AND 2 DOCKET NOS. 50-266 AND 50-301
1.0 INTRODUCTION
On September 12, 1995, the U.S. Nuclear Regulatory Commission (NRC) approved issuance of a revision to 10 CFR Part 50, Appendix J, " Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors" which was subsequently published in the Federal Reaister on September 26, 1995, and became effective on October 26, 1995. The NRC added Option B, " Performance-Based Requirements," to allow licensees to voluntarily replace the prescriptive testing requirements of 10 CFR Part 50, Appendix J, with testing requirements based on both overall leakage rate performance and the performance of individual components.
By application dated May 29, 1996, and supplemented by letter dated August 20, 1996, Wisconsin Electric Power Company (WEPCo, the licensee) requested changes to the Technical Specifications (TS) for the Point Beach Nuclear Plant (PBNP),
Units 1 and 2.
The supplemental information did not change the staff's initial no significant hazards consideration determination. The proposed changes would permit implementation of 10 CFR Part 50, Appendix J - Option B.
We licensee has established a " Containment Leakage Rate Testing Program" and proposed adding this program to the TS. The program references Regulatory Guide (RG) 1.163, " Performance-Based Containment Leak Test Program," dated September 1995, which specifies a method acceptable to the NRC for complying with Option B.
2.0 BACKGROUND
Compliance with 10 CFR Part 50, Appendix J, provides assurance that the primary containment, including those systems and components which penetrate the primary containment, do not exceed the allowable leakage rate specified in the TS and Bases.
The allowable leakage rate is determined so that the leakage assumed in the safety analyses is not exceeded.
On February 4,1992, the NRC published a notice in the Federal Reaister (57 FR 4166) discussing a planned initiative to begin eliminating requirements marginal to safety which impose a significant regulatory burden. Appendix J 9610170271 961009 PDR ADOCK 05000266 P
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of 10 CFR Part 50 was considered for this initiative and the staff undertook a study of possible changes to this regulation. The study examined the previous l
performance history of domestic containments and examined the effect on risk of a revision to the requirements of Appendix J.
The results of this study
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are reported in NUREG-1493, " Performance-Based Leak-Test Program."
Based on the results of this study, the staff developed a performance-based approach to containment leakage rate testing. On September 12, 1995, the NRC 4'
approved issuance of this revision to 10 CFR Part 50, Appendix J, which became effective on October 26, 1995. The revision added Option B, " Performance-1 Based Requirements," to Appendix J to allow licensees to voluntarily replace the prescriptive testing requirements of Appendix J with testing requirements j
based on both overall and individual component leakage rate performance.
Regulatory Guide 1.163, was developed as a method acceptable to the NRC staff for implementing Option B.
This regulatory guide states that the Nuclear Energy Institute (NEI) guidance document NEI 94-01, " Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J" provides l
methods acceptable to the NRC staff for complying with Option B with four i
i exceptions which are described therein.
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Option B requires that the RG or other implementation document used by a licensee to develop a performance-based leakage rate testing program must be included, by general reference, in the plant TS. The licensee has referenced j
RG 1.163 in the Point Beach TS.
l Regulatory Guide 1.163 specifies an extension in Type A test frequency to at least one test in 10 years based upon two consecutive successful tests. Type j
B tests may be extended up to a maximum interval of 10 years based upon completion of two consecutive successful tests and Type C tests may be extended up to 5 years based on two consecutive successful tests.
By letter dated October 20, 1995, NEI proposed TS to implement Option B.
After some discussion, the staff and NEI agreed on final TS which were attached to a letter from C. Grimes (NRC) to D. Modeen (NEI) dated November 2, 1995. These TS are to serve as a model for licensees to develop plant specific TS in preparing amendment requests to implement Option B.
For a licensee to determine the performance of each component, factors that are indicative of or affect performance, such as an administrative leakage limit, must be established.
The administrative limit is selected-to be indicative of the potential onset of component degradation. Although these limits are subject to NRC inspection to assure that they are selected in a reasonable manner, they are not TS requirements. Failure to meet an administrative limit requires the licensee to return to the minimum value of the test interval.
Option B requires that the licensee maintain records to show that the criteria for Type A, B and C tests have been met.
In addition, the licensee must maintain performance comparisons of the overall containment system and individual components to show that the test intervals are adequate. These records are subject to NRC inspection.
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3.0 EVALUATION In its May 29, 1996, letter, the licensee proposed establishing a " Containment
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Leakage Rate Testing Program" and proposed adding this program to the TS. The l
program references RG 1.163, which specifies a method acceptable to the NRC 1
for complying with Option B.
The proposal requires a change to existing TS 4
Sections 15.4.4, "Contr.inment Tests," 15.1, " Definitions," 15.3.6, l
" Containment System," and 15.6, " Administrative Castrols."
Option B permits a licensee to choose Type A; or Type B and C; or Type A, B and C; testing to be done on a performance basis. The licensee has elected to l
perform Type A, B and C testing on a performance basis.
The TS changes proposed by the licensee are in compliance with the requirements of Option B and consistent with the guidance of RG 1.163, and the generic TS of the November 2,1995, letter, with one exception. The licensee's proposed TS change includes a one-time exception to RG 1.163 in that the next Type A test for Unit 2 will be performed t+ n interval of 60,
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rather than 48, months since the last Type A test.
j RG 1.163 endorses NEI 94-01 which states that periodic Type A tests shall be i
performed at intervals of 48 months until acceptable performance is established to extend the test intervals. Acceptable performance history is defined as completion of two consecutive periodic Type A tests where the calculated performance leakage rate was less than 1.0 L,.
At least one of these tests must be performed at peak accident pressure. Since the periodic i
Type A tests at PBNP are conducted at reduced pressure, the licensee must perform a full pressure test in order to adopt the extended Type A test interval provisions of Option B.
Under the provision of Option A, the next Type A test for PBNP Unit 2 must be performed during the Fall 1996 outage.
The licensee's proposal would delay the next Unit 2 Type A test until the Fall l
1997 outage.
i' The licensee is planning to replace the Unit 2 steam generators during the Fall 1996 outage. The licensee feels it is more prudent to focus its l
resources on the safe replacement of the steam generators rather than on i
obtaining the equipment and changing the implementing procedures necessary to i
account for performing a full pressure Type A test. Deferral of the Type A test will reduce the Fall 1996 outage scope and duration and will allow time to adequately prepare for a full pressure test.
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In order to justify their proposal, the licensee reviewed the PBNP Type A test i
performance history.
The Unit 2 containment has sever failed a Type A test.
The five Type A tests conducted since plant start-up have all been less than 63% of the allowable test leakage rate at the 95% confidence level.
The licensee also reviewed its activities and concluded that there have not 2
i been any alterations or challenges to the Unit 2 containment since the last 2
Type A test. There are also no major modifications to the containment i
structure itself planned for the Fall 1996 outage. Transportation of the existing and replacement steam generators out of and into containment will be i
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a done via the existing equipment hatch. No cutting of the containment structure or liner plate is required. Welding of the main steam and feedwater i
lines after installation of the rep 1'acement steam generators will be followed by appropriate inspections and testing in accordance with approved codes and standards to ensure the integrity of these containment penetrations is i
maintained. No other work that could affect the containment structure is scheduled for the Fall 1996 outage.
I Based on Unit 2 Type A test performance history, as discussed above, the staff finds the licensee's proposal to delay the next Unit 2 Type A test until the i
Fall 1997 outage acceptable. Since the proposed TS changes are otherwise in compliance with the requirements of Option B and consistent with the guidance of RG 1.163, and the generic TS of the November 2,1995, letter, the staff i
i finds the proposed TS changes acceptable.
Option B states that specific existing exemptions to Option A are still applicable to Option B, if necessary, unless specifically revoked by the NRC.
1 The current PBNP TS contain three exemptions to Appendix J, Option A.
These i
exemptions are:
(1) an exemption from Section III. A.I.(d) related to the i
service air supply line used in conjunction with the Type A test; (2) an
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exemption from Section III.A.1.(d) related to leakage testing of the residual heat removal system; and (3) and exemption from Section III.A.1.(a) related to the termination of a Type A test if excessive leakage paths are identified.
j The licensee evaluated these existing exemptions from Option A against the new i
requirements of Option B and determined that the exemptions are no longer j
applicable.
1 The present Point Beach TSs require that the containment purge supply and exhaust valves be tested every six months. The licensee's May 29, 1996, letter also requested a revision to the TSs which would delete this
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requirement. These valves would then be tested in accordance with Regulatory Guide 1.163 which specifies a test interval of 30 months. The requirement to leak test these valves at a frequency of every 6 months is not an Appendix J requirement. The current 6 month test interval is based on the findings of Generic Issue B-20, " Containment Leakage Due to Seal Degradation," that valves with resilient seals should be tested more frequently than required by Appendix J.
The background for this conclusion is discussed in IE Circular 77-11, " Leakage of Containment Isolation Valves With Resilient Seats," issued on September 6, 1977. However, by letter dated August 20, 1996, the licensee reported the results of a review of purge supply and exhaust valve leakage test results and maintenance history from 1992 to the present. The licensee stated that 36 leakage tests were performed, nine per penetration, and "there have been no failures when compared to Technical Specifications and Appendix J limits."
In addition, the licensee stated that no valve has exceeded the licensee's administrative limit of 2000 scen (standard cubic centimeter per minute). Based on inase results, the staff finds it acceptable to perform leakage rate tests on these valves at the 30 month interval specified in Regulatory Guide 1.163, rather than the previous 6 month interval.
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1 The staff has reviewed the licensee's proposed disposition of its existing l
(Option A) Appendix J exemptions as they relate to the Option B requirements.
Pursuant to the provisions of 10 CFR Part 50, Appendix J - Option B, paragraph III.V.B.1, the staff finds it acceptable.
4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Wisconsin state Official was notified of the proposed issuance of the amendment. The state official had no comments.
5.0 ENVIR0letENTAL CONSIDERATION 4
l The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR i
Part 20 and changes surveillance requirements. This also changes surveillance i
requirements. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no i
significant increase in individual or cumulative occupational radiation j
exposure.
The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (61 FR 34901). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
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6.0 CONCLUSION
i The Commission has concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, l
and (3) the issuance of the amendment will not be inimical to the common i
defense and security or to the health and safety of the public.
Principal Contributors:
R. Lobel R. Laufer Date:
October 9, 1996 I
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