ML20137K888

Proposed Tech Specs Permitting Utilization of Exemptions to 10CFR50,App J Re Type Band C Tests

ML20137K888
Person / Time
Site:	McGuire, Mcguire
Issue date:	01/21/1986
From:	DUKE POWER CO.
To:
Shared Package
ML20137K881	List: ML20137K879 ML20137K888
References
TAC-59796, TAC-59797, TAC-60601, TAC-60602, NUDOCS 8601240264
Download: ML20137K888 (7)

Text

ATTAClutENT 1 PROPOSED TECHNICAL SPECIFICATION CHANCES l

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8601240264 G60121 1

PDR ADCCK 05000369 l

P PDR

CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

Three Type A tests (Overall Integrated Containment Leakage Rate) a.

shall be conducted at 40

• 10 month intervals during shutdown at eitherPle,riod.

14.8 psig, or at P, 7.4 psig, during each 10 year service The third tekt of each set shall be conducted during the shutdown for the 10 year plant inservice inspection; b.

If any periodic Type A test fails to meet either 0.75 L or 0.75 L the test schedule for subsequent Type A tests shall be $eviewed anb, approved by the Commission.

If two consecutive Type A tests fail to meet either 0.75 L or 0. 75 L a Type A test shall be performed at least every 18 monfhs until tb, consecutive Type A tests meet either 0.75 L resume 8;or0.75Lg at which time the above test schedule may be The accuracy of each Type A test shall be verifled by a supplemental c.

test which:

1)

Confirms the accuracy of the Type A test by verifying that the, difference between supplemental and Type A test data is within 0.25 L,, or 0.25 Lt 2)

Has a duration sufficient to establish accurately the change in leakage rate between the Type A test and the supplemental test; and 3)

Requires the quantity of gas injected into the containment or bled from the containment during the supplemental test to be equivalent to at least 25% of the total measured leakage at P,

14.8 psig, or P, 7.4 psig.

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Type 8 and C tests shall be conducted with gas at P, 14.8 psig, at d.

intervals no greater than 24 months except for testl involving:

1)

Air locks, 2)

Oual-ply bellows assemblies on containment penetrations between the containment building and the annulus, and 3)

Purge supply and exhaust isolation valves with resilient material seals Purge supply"an*d hh[s N oiaN onN al M w e.

r silient material seals shall be tested and demonstrated OPERA 8LE by the requirements of Specification 4.6.1.9.3 or 4.6.1.9.4, as applicable; i

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The combined bypass leakage rate shall be determined to be less than 0.07 L,for penetrations which are not individually testable; pene e-by applicable Type 8 and C tests at least once per 24 months 4

except tions not individually testable shall be determined to have no detect-

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able leakage when tested with soap bubbles while the containment is pressurized to P,, 14.8 psig, or P. 7.4 psig, during each Type A test; t

Amendment No. V'(Unit 2)

McGUIRE - UNITS 1 and 2 3/4 6-3 Amendment No. 29 (Unit 1)

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ATTACRMENT 2 JUSTIFICATION AND SAFETY ANALYSES i

JUSTIFICATION AND SAFETY ANALYSIS i

The proposed change to the McGuire Technical Specifications is an administrative change to allow the NRC to approve exemptions from 10CFR50 Appendix J (relative to Type B and C leakage tests).

In some cases, it may be appropriate to pres-surize with a different medium instead of gas.

These cases would be submitted and justified to the NRC Staff on an individual basis. This change would allow such an exemption to be granted and utilized, i

Specifically. Attachment 4 contains an exemption request submitted September 24 1985 to allow initial leak testing of two containment penetrations using glycol as discussed in the request; in this case, the acceptance criteria is zero lenk-age.

If this is not met, the penetration would be drained and tested according to Appendix J.

Such exemptions would be justified individually to assure that containment integrity is not compromised.

4 ATTACHMENT 3 ANALYSES OF SIGNIFICANT HAZARDS CONSIDERATION k

ANALYSES OF SIGNIFICANT HAZARDS CONSIDERATIONS Pursuant to the requirements of 10CFR50.91, this analysis provides a determina-tion that the proposed amendment of the Technical Specification does not involve any significant hazards consideration, as defined by 10CFR50.92.

The proposed amendment would not:

1)

Involve a significant increase in the probability or consequences of an accident previously evaluated.

The change is administrative to allow exemptions to Containment penetration testing requirements and would assure, through the NRC approval process, that Containment Integrity is not compromised thus r.ot affecting the pro-bability or consequences of an accident previously evaluated, i.e., con-tainment failure.

2) Create the possibility of a new or dif ferent kind of accident f rom any accident previously evaluated.

No hardware changes would be made as a result of this change so no accident mechanisms are affected or created.

3)

Involve a significant reduction in a margin of safety.

Containment integrity is maintained with no reduction in margin.

Based upon the preceding analysis, Duke Power Company concludes that the proposed amendments do not involve a significant hazards consideration.

1 ATTACHMENT 4 EXEMPTION REQUEST OF SEPTEMBER 24 1985 I

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DmCE POWER COMPANY p.o. mox 30:se H.U., 5. M'CKER enAntorrz w.c. ass 4a nem enemme=

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TW u r.co g September 24, 1985 t

Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention:

Ms. E. G. Adensaa. Chief Licensing Branch No. 4

Subject:

McGuire Nuclear Station Docket Nos. 50-369 and 50-370 Request for Exemption from 10 CFR 50 Appendix J Requirement i

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Dear Mr. Denton:

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Attached is a Request for Exemption from the 10 CFR 50 Appendix J Requ to leak rate test mechanical penet:ations using air or nitrogen as th ent medium across the valve sealing surface.

e test to two penetrations for the Ice Condenser Refrigeration System wherThis Re 1

of the procedure is included in the request.otherwise necessary e it is j

An outline be used as the pressurization medium.The proposal would allow an altern th~e penetration will be fully drained and tested in accord i

is not met, I

I Appendix J.

4 Review and approval is requested by February 1. 1966 to support the current j

test cycle.

Pursuant to 10 CFR 170.21. a check for $150.00 is enclosed.

Please feel free to contact us At you require any additional information Very truly yours.

y Hal B. Tucker JBD/hrp 4

Attachment Dr. J. Nelson Grace. Regional Administrator ec:

U. S. Nuclear Regulatory Commission Mr. W. T. Orders Region II NRC Resident Inspector 101 Marietta Street. NW. Suits 2900 McGuire Nuclear Station Atlanta, Georgia 30323 i

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t Raouest for Eveantion from 10CFRLu Annandir J Raouirement 10CFR50 Appendix J III C 2(a) requires mechanical penetrations to i

be leak rate tested using air or nitrogen as the test mediua across the valve sealing surface.

An exemption is requested froa j

this requirement for penetration numbers M-372 and M-373.

The i

local leakage test will be performed without draining the glycol 4

from the seats of the diaphram valves in these penetrations.

Attachment A depicts the arrangement of these penetrations.

McGuire utilizes an ice condenser to surpress the peak accident pressure in the reactor containment building.

The ice condenser is refrigerated by recirculating a 505 - 505 mixture of ethylene i

glycol and water through a series of air handling unita located inside the containment building and chillers units located in the auxiliary building.

Typically,

draining, testing and refilling the system requires 24 to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> of downtime for the ice condenser refrigeration system.

This extended downtime potentially diminishes the amount of ice in the baskets.

Draining the glycol consumes a significant number of manhours and 3

j creates toxic waste which has to be disposed.

As an alternative to draining the 200 gallons of glycol i

necessary to perform this test in accordance with Appendix J, the i

following procedure for testing these penetrations is

proposed, i

Penetration M-373 would be drained through NF-1173 and NF-960.

i NF-229 (a duo check valve) would be local leak tested with air on j

both sides.

NF-228A would then be tested with air as the pressurization medium and glycol on its seats.

The systen high point vent, NF-1150, would serve as the vent valve for NF-228A.

Similarly, M-372 would be tested without completely draining the i

glycol.

NF-233B would be tested by pressurizing through NF-957 utilizing NF-236 as the test vent.

NF-234A would be pressurized j

through NF-957 utilizing NF-1150 as the test vent.

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NF-228A, NF-233B and NF-234A are diaphraga valves which have an excellent history of leak tightness.

This characteristic is primarily due to the resiliency of the rubber diaphragm.

If a rupture of the diaphrage were to occur, it would be evident via leakage around the valve stem due to the static pressure maintained on the glycol system.

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A bench test was performed at McGuire to corrolate the leakage rate of air and the Glycol / Water mixture.

A test stand was fabricated using a

metering valve to achieve a

repeatable leakage area.

The upstream side was pressurized to 15 pais, the downstream side discharged to atmosphere and temperature was held i

constant at 75 degrees F.

The following results were obtained:

i AIR LEAK WATER / GLYCOL RATE (SCCM)

LEAK RATE (SCCM) 500 15 1000 28 1500 47 These results infer a 1 to 31 glycol to air leakage ratio with a.994 corrolation coefficient.

This ratio will be different at different temperatures due to changes in kinematic viscosity.

The leakage rate acceptance criteria that would be imposed on these diaphragm valves would be zero indicated leakage (not including instrument error).

If the leak rate is greater than zero, the. penetration will be fully drained and the valves leak tested in accordance with Appendix J.

Performing the local leakage rate test on these penetrations without fully draining them will not compromlse containment integrity.

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