ML20138F813
| ML20138F813 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 12/12/1985 |
| From: | Corbin McNeil Public Service Enterprise Group |
| To: | Adensam E Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8512160175 | |
| Download: ML20138F813 (13) | |
Text
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Public Service Electric and Gas Company
. Corbin A. McNeill, Jr.
Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge.NJ 08038 609339-4800 Vice President -
Nuclear December 12, 1985 9
Director of Nuclear Reactor Regulation United States Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20814 Attention:
Ms. Elinor Adensam, Director Project Directorate 3 Division of BWR Licensing
Dear Ms. Adensam:
10CFR50 APPENDIX J EXEMPTION REQUESTS HOPE. CREEK GENERATING STATION DOCKET NO. 50-354 Public Service Electric and Gas Company (PSE&G) requests, pursuant to 10CFR50.12(a), exemptions.t'o six specific re-quirements of 10CFR50 Appendix J.
The attachment to this letter provides the necessary background, detail, justifi-cation and concluding discussions for each exemption request.
Various supportive revisions and additions to the Hope Creek Generating Station (HCGS) Final Safety Analysis Report (FSAR) and Technical Specifications will be submitted separately.
These requests are provided for your review and authorization.
Should you have any questions on the subject filing, do not hesitate to contact us.
Sincerely, 9512160175 85121 PDR ADOCM 05000 4
A P
ADDI RWR = t/RC's T,CH %UPPORT
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I l Affidavit g'f;ggga&,
A Attachment na t Acmm) rOS (VASSALLO)
M. G. MINA3 (LLP ely)
o Director of Nuclear 2
12/12/85 Reactor Regulation C
D.H. Wagner USNRC Licensing Project Manager R.W.
Borchardt USNRC Senior Resident Inspector
A UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION DOCKET NO. 50-354 PUBLIC SERVICE ELECTRIC AND GAS COMPANY 10CFR50 APPENDIX J EXEMPTION REQUESTS Public Service Electric and Gas Company (PSE&G) hereby requests, pursuant to 10CFR50.12(a), exemptions to six specific requirements of 10CFR50 Appendix J.
The requests provided contain the necessary background, detail, justifi-cation and concluding discussions for your review and author-ization.
l
-The matters' set forth in these requests are true to the best of my knowledge, information, and belief.
i Respectively submitted, Public Service Electric.
and Gas Company By:
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Corbin A. McNeill, M Vice President - Nuclear.
Sworn to and subscribed
.before me, a Notary Public of New Jersey, this /A
- l day of December 1985.
N hP1w DONNA G. HITCHNER NOTAflY PUBLIC OF NEW JERSEY My Comm!ssion Expires March 24,1987
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION DOCKET NO. 50-354 PUBLIC SERVICE ELECTRIC AND GAS COMPANY 10CFR50 APPENDIX.J EXEMPTION REQUESTS Public Service Electric and Gas Company (PSE&G) hereby requests, pursuant to 10CFR50.12(a), exemptions to six specific requirements of 10CFR50 Appendix J.
The requests provided contain the necessary background, detail, justifi-cation and concluding discussions for your review and author-ization.
The matters set forth in these requests are true to the
.best of my knowledge, information, and belief.
Respectively submitted, Public Service Electric and Gas Company By:
RN Corbin A. McNeill, Jrh Vice President - Nuclear i
Sworn to and subscribed before me,.a Notary Public of New Jersey, this /JI
- day of December 1985.
N DONflA G. HITCifNER NOTARY PUBUC OF NEW JERSEY hly Comm!ssion Eq:res March 24,1987
f UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION DOCKET NO. 50-354.
PUBLIC SERVICE ELECTRIC AND GAS COMPANY 10CFR50 APPENDIX J EXEMPTION REQUESTS Public Service Electric and Gas Company (PSE&G) hereby i
requests, pursuant to 10CFR50.12(a), exemptions to six specific requirements of 10CFR50 Appendix J.
The requests provided'contain the necessary background, detail, justifi-cation and concluding discussions for your review and author-ization'.
The matters set forth in these requests are true-to the i
best of my knowledge, information, and belief.
Respectively submitted, Public Service Electric and Gas Company By:
%N Corbin A. McNeill, Jr}
Vice President - Nuclear Sworn to and subscribed before me, a Notary Public of New Jersey, this /a
- day of December 1985.
bM D0?l!!A G. lilTCilNEll NOTARY FUBLIC OF FCV JERSEY I4 Commissica Expires Abrch 24,1037
Paga 1 of 8 ATTACHMENT
' EXEMPTION REQUEST 51 A..
BACKGROUND 10CFR50 Appendix J Paragraph III.C.2(a) requires valves, unless pressurized with fluid from a seal system, to be pressurized with air or nitrogen at a pressure of Pa, where Pa is defined as the calculated peak containment internal pressure, in psig, resulting from a design basis accident.
B.-
EXENPTION REQUEST 10CFR50 Appendix J Section III.C describes the leakage testing requirements for.those containment isolation valves subject to Type C tests, as defined in Section II.H; while Technical Specification Table 3.6.3-1, as contained in the Proof and Review copy dated October 4,
1985, herein after referred to as the Technical Specifications, implements these requirements with the following exception.
Thermal relief valves that discharge into the primary containment and also serve as containment isolation valves, i.e. in the Residual Heat Removal (RHR) System and Core Spray (CS) System, will have their integrity verified during the Type A test, at defined in Section II.F.
C.
JUSTIFICATION In support of the above requested exemption it should be noted that relief valves which serve as containment isolation valves are designed such that their discharge piping will withstand temperature and pressure at least equal to the containment design temperature and pressure.
In fact, the Loss of Coolant Accident (LOCA) pressure seats the valve's disk.
As stated
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in Safety Evaluation Report (SER) Section 6.2.4, the addition of another valve to form a test boundary would not only defeat the purpose for which the relief valves were installed but may also decrease the probability that the relief valves would function properly when required.
{Paga 2 of 8 D.
CONCLUSION The exemption request detailed above is justified as described in Final Safety. Analysis Report (FSAR)
Section 6.2.4.4 '(and summarized above) and has been deemed an acceptable alternative to General Design Criteria (GDC) 56 (SER Section 6.2.4) and to'10CFR50 Appendix J (Technical Specification Table 3.5.3-1).
It can therefore be concluded that the granting of this exemption does not endanger life or property or the common defense and security, and is in the public interest.
EXEMPTION REQUEST 82 A.
. BACKGROUND 10CFR Appendix J Paragraph III.C.2(a) requires valves, unless pressurized with fluid from a seal system, to be pressurized with air or nitrogen at a pressure of Pa.
B.
EXEMPTION REQUEST 10CFR50 Appendix J Section III.C describes the leakage testing requirements for those containment isolation valves subject to the Type C tests while Technical Specification Table 3.6.3-1 implements these requirements with the following exception.
Instrument lines that are not included in the Type C test. program, i.e.
suppression pool level and pressure instrumentation, drywell pressure instrumentation, and those lines containing excess flow check valves, will have their leak tightness verified during the Type A test.
C.
JUSTIFICATION In support of the above requested exemption, these instrument lines were designed on an "other defined basis" of GDC 56 and hence are not capable of being Type C tested.
Instrument lines are provided with a manual isolation valve outside containment for greater reliability.
The systems they serve are closed systems outside containment thereby providing reliable boundaries against containment leakage.
The Type A test which will be conducted on these instrument lines serves to adequately assure integrity.
D.
CONCLUSION The exemption request detailed above is justified as described in FSAR Sections 6.2.4.3.2.21 and 6.2.4.3.5
7 Paga 3 of 8 (and summarized above) and.has been deemed an acceptable alternative to GDC 56.(SER Section 6.2.4) and to 10CFR50
- Appendix;J (Technical-Specification. Table 3.6.3-1).
It-can therefore be concluded that the granting of this exemption does not endanger life or property or the common defense and security and is in the public interest.
EXEMPTION REQUEST 83 A.
BACKGROUND 10CFR50 Appendix J Paragraph III.C.2(b) requires valves which are sealed with fluid from a seal system to be pressurized with that fluid to a test pressure not less than 1.10 Pa.
B.
EXEMPTION REQUEST 10CFR50 Appendix J Section III.C describes the leakage testing requirements for those containment isolation valves subject to Type C tests, while Technical Speci-fications 3.6.1.2.b and d implement these requirements with the exception for feedwater valves detailed in Table 3.6.3-1.
The feedwater isolation valves, consisting of three check valves of which two are outside contain-ment, will be sealed with water from the High Pressure Coolant Injection (HPCI) and Reactor Core Isolation Cooling (RCIC) systems for at least 30 days following a LOCA.
Leakage on the inboard and first outboard check valves will be determined from a Type C gas test conducted at Pa but will not be added to the 0.60La allowable leakage total.
C.
JUSTIFICATION In support of the above requested exemption, the design of the feedwater system should be detailed.
Specifically, the design includes two check valves serving as isolation valves, one inside containment and one outside contain-ment with an air-operator, followed by another check valve outside containment with a motor-operator (see FSAR Figure 6.2-28, Sheet 2 of 48).
In addition, a feedwater line fill network outside containment is used to maintain a water seal in the feedwater lines following a LOCA.
The fill network consists of the HPCI and the RCIC jockey pump loops and utilizes the HPCI and RCIC injection lines to the feedwater piping to provide makeup water to the piping between the outboard check valves.
This design has been accepted-by the NRC Staff in SER Gupplement 3, Section 6.2.3.
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p Pags 4 of 8 A Type C' gas test will be performed at Pa on the two check valves ^ classified as containment isolation valves with leakage through the' valves limited to 15 SCF per hour, this will be. included as an addition to Technical Specification 3.6.1.2.
The leakage values obtained will not be included in the 0.60La allowable leakage _because during the initial portion of a LOCA, water in the feedwater system piping downstream of the No. 3 feedwater heater will flash to steam.
This steam will continue to flow toward the reactor pressure vessel until pressure in the feedwater line decreases to the containment pressure, at which time the isolation valves will be manually closed.
In addition, a water seal will be maintained upstream of the third feedwater heater since the maximum water temperature is 211.9 F and'the feedwater is in a no flow condition.
These conditions prevent the outward leakage of radioactive contaminants through the isolation valves during approximately a'one-hour period after the accident, i.e. until the water seal is re-established; thus, no bypass leakage of the feedwater system is expected to occur.
A Type C water test will be performed at 1.10Pa on the outermost check valve and its leakage included with all other hydrostatically tested valves (Technical Specification 3.6.1.2.d).
Once the water seal system is activated, any external leakage would be through this boundary valve via the seal _ fluid.
The Type C water test will be sufficient to assure proper leakage verification.
D..
CONCLUSION The exemption request deta'iled above is justified as described in FSAR Sectigns 5.4.9/'6.2.3.2.3 and 6.2.4.3.1.2 (and summarized above) and has/been deemed an acceptable alttirn'ative flo the requirements of l'0CFR50 Appendix J by the NRC Staff in Technical Specification Table 3.6.3-1.
It can therefore be concluded that the granting of.this exemption does'not endangerflife or property or the common defense and security, and, is in the public interest.
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RXENPTION RBQUEST 84
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A.
BACKGROUND
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10CFR50 Appendix J Paragraph III.C.2(b) requires valves which are scaled w'ith flUtd'Irom a system to be pressurized withthatfluidtoatestpres(arenot1esothan1.10Pa.
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Pags 5 of 8 B.
EXEMPTION REQUEST 10CFR50 Appendix J Section III.C describes the leakage testing requirements for those containment isolation valves subject to Type C tests, while Technical Specifications 3.6.1.2.b and c implement these requirements with the following exception.
The Main Steam Isolation Valves (MSIVs) will be leakrate tested by pressurizing between the inboard and outboard MSIVs and between the outboard MSIV and the Main Steam Stop Valve (MSSV) at a reduced pressure of 5 psig which is less than the 1.10Pa required by Appendix J.
C.
JUSTIFICATION In support of the above requested exemption, it is necessary to briefly describe the operation of the Main Steam Isolation Valve Sealing System (MSIVSS).
The MSIVSS is manually initiated approximately 20 minutes after the onset of a LOCA and only after main steam line pressure is below 20 psig.
This latter restriction is necessary since the MSIVSS maintains the pressure between the valves at reactor vessel pressure plus 5 psig and because a back pressure dif-forential of 25 psi will lift the MSIV disk, unseating the valve.
Therefore, testing of the two MSIVs simultaneously, between the valves, at 1.10Pa would lift the disk at the inboard valve and result in a meaningless test.
A test will be conducted at 5 psig (the seal system differential pressure) with the total observed leakage through both the outboard MSIV and the MSSV conservatively assigned to that penetration and limited to 11.5 SCF per hour for any one main steam line.
This commitment is reitera'.ed in Technical Specification 3.6.1.:.c and has been deemed an acceptable alternative to the requirements of Appendix J for the aforementioned reasons by the NRC Staff in SER Section 6.2.6(1).
D.
CONCLUSION The exemption request detailed above is justified as described in FSAR Sections 6.2.6 and 6.7 (and sum-marized above) and has been deemed an acceptable alter-native to the requirements of Appendix J by the NRC staff in the afore-referenced sections of the SER and Technical Specifications.
It can therefore be concluded that the granting of this exemption does not endanger life or property or the common defense and security, and is in the public interest.
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Paga 6 of 8 i
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' EXEMPTION REQUEST #5 3,
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A.
BACKGROUND s
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1.
10CFR50 Appendix J Paragraph III.D,12(b)(ii) requi$es air locks which have been used during periods when.
-containment integrity is not r' quired by the plant's' e
Technical Specifications to be tested at the e'nd of such-periods at not less than Pa.
B..
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10CFR50 Appendix J Section III.D.2(b) describes the periodic retest schedule for containment air locks which are specifically implemented in Technical Specification 4.6.1.3 with-the following exception.
In addition to the six month intervals, air locks will be subjected
.to an'overall air lock leakage integrity test only
-when maintenance has been performed on the air lock that could affect the. air lock sealing capability.
This is an exemption to Paragraph III.D.2(b)(ii) because Appendix J requires testing of. air locks at the end of periods when primary containment integrity is not required regardless of whetheir or not maintenance is performed.on the air lock.
i C.
JUSTIFICATION
'9
. y The exemption request de, tailed above is justified t
for the following reasons.
First, an air lock leakage f
test at-Pa will be performed'at leastj once per six i
s months (Technical Specification 4.6.1.3.b.1) to verify that the overall air lock lda.kage rate is within its limit.
This periodic test-will verify that the sealing-capability of'the air lock has not degraded as a result of routine use since the last time the test was conducted.
Secondly, tests conducted on the air lock at the end 4
of periods when primary containment integrity is not required, during which no maintenance has been performed on the air lock that could affect its sealing capability, serve only to confirm the periodic six month surveillance requirement and in effect establish an unnecessarily restrictive surveillance interval.
Finally, to assure air lock leakage is within specified limits, an air
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lock leakage test at Pa will be performed prior to S
establishing primary containment integrity when maintenance has been performed on the air lock that could affect its sealing capability (Technical Specification 4.6.1.3.b.2),)
and an air lock seal test will be performed within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following each closure, except uhen the air lock is being used for multiple entries and then at
'least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> ( echnical Specification 4.6.1.3.a).
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.Page 7 of 8 g.
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This commitment assures that when replacements, modifications or other alterations to the air lock are made which 9
affect scaling capability, surveillances will'be conducted to verify that.the air lock ~ satisfies acceptance criterion.
g Therefore, testing of the air locks prior to establishing b
primary containment integrity if no maintenance has been performed on the air lock's seal capability would result in an unnecessary, repetitive test.
In conclusion, the test which will be performed, i.e.
after maintenance affecting the sealing capability, represents sufficient surveillance (in addition to the six month and 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> requirements) to assure.
proper leakage verification.
D.
CONCLUSION 4
The exemption request detailed above is justified as itemized above and' reiterated in Technical Specifi-cation 4.6.1.3.
It can therefore be concluded that the granting of this exemption does not endanger life y
or property or the common defense and security, and 7\\.g is in'the public interest.
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EXEMPTION REQUEST #6 A.
. BACKGROUND 10CFR50 Appendix J Paragraph III.D.3 requires valves which are classified as Type C valves to be leak tested by local pressurization during each reactor shutdown h
for refueling but in no case at intervals greater than two years.
o di B.
EXEMPTION REQUEST 10CFR50 Appendix J Section III.D.3 describes the periodic leakage requirements for those primary containment isolation valves subject to Type C tests; while Techni-cal Specification 3/4.6.3 implements these requirements with the following exception.
The Traversing Incore e
Probe (TIP) system's shear valves will not be Type C tested.
4C.
JUSTIFICATION In support of the above requested exemption and because o
the shear valves require-testing to destruction, the following actions will be implemented as an alternative to Type C testing in order to ensure the shear valves will perform their intended functions.
First, the continuity of the explosive charge will be verified 3>
at least once per 31 days.
Second, the explosive
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e Paga 8 of 8 squib from at least one explosive valve will be removed at least once per 18 months (such that'each explosive squib in each explosive valve is removed at least L
once per 90 months) and t'ested by initiating the explo-sive squib.- Third, the replacement charge for the exploded squib will be from the same manufactured batch as the one fired or from another batch which has been certified by having at least one of that batch successfully fired.
Finally, all charges will be replaced according to the manufacturer's recommended
-life time.
These four commitments are reiterated in Technical Specification 4.6.3.5.
Therefore; since testing of the TIP system's shear valves result in their destruct' ion, such a test would be meaningless and will not be conducted.
In lieu of such a test; the above described alternate testing program will he implemented and represents an acceptable alternative to the requirements of Appendix J to the NRC Staff as detailed in SER Section 6.2.6(5) and in the Technical Specifications as referenced above.
D.
CONCLUSION Based on the justification detailed above, it can be concluded that the granting of this exemption does not endanger life or property or the common defense and security, and is in the public interest.
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