ML20140B614

Requests Temporary Exemption from Section III.D.3 of 10CFR50,App J,Deferring 24-month Testing Interval for Containment Penetrations & Associated Isolation Valves Until Startup Following Refueling Outage

ML20140B614
Person / Time
Site:	Wolf Creek
Issue date:	01/20/1986
From:	Koester G KANSAS GAS & ELECTRIC CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
KMLNRC-86-008, KMLNRC-86-8, NUDOCS 8601270057
Download: ML20140B614 (15)

Text

'

KANSAS GAS AND ELECTRIC COMPANY THE ELECTAC COMPANY GLENN L MOESTER m . m .uu.. January 20, 1986 Mr. Harold R. Denton, Director Office of Nuclear R3 actor Regulation U.S. Nuclear Regulatory Contnission Washington, D.C. 20555 KMLNRC 86-008 Re: Docket No. STN 50-482 Ref: KMLNRC 86-007 fran G.L.Koester, KG&E, to H.R.Denton, NRC, Dated 1/20/86 Subj: Tenporary Exeuption to 10 CFR 50, Appendix J, Section III.D.3

Dear Mr. Denton:

The purpose of this letter is to request a tenporary exenption to 10 CFR 50, Appendix J, Section III.D.3 pursuant to the requirenents of 10 CFR 50.12.

Kansas Gas and Electric Conpany requests that the contairment penetrations and associated isolation values delineated in Attachment I receive a one time only deferment of the twenty four month testing interval specified for Type C penetrations until startup following Refuel 1. The reference provides a request for revision to the associated portions of Wolf Creek Generating Station, Unit No. 1 Technical Specifications.

In granting a similar request to Carolina Power & Light Company for Brunswick Steam Electric Plant, Unit No. 1, the Staff stated that, " The 24 month interval requirement for Type B and C penetrations is to be often enough to prevent significant deterioration from occurring and long enough to permit the LLRTs to be performed during plant outages. Leak testing of the penetrations during plant shutdown is preferable because of the lower radiation exposures to plant personnel. Moreover, some penetrations, because of their intended functions, cannot be tested at power operation.

For penetrations that cannot be tested during power operation or those that, if tested during plant operation would cause a degredation in the plants overall safety (e.g., the closing of a redundant line in a safety systen) , the increase in confidence of containment integrity following a successful test is not significant enough to justify a plant shutdown specifically to perform the LLRTs within the 24 month time period...".

12 h b h $h@o 82 AD - J. KNIGifT (ltr only)

P PDR EB (BALLAHD)

Ol'/ Ij p jgog EICSB (HOSA)

PSB (GAMMILL) j F

ggd HSB (BERLINGER)

F00 (BENAH0YA) 201 N. Market - Wictuta, Kansas - Mail Address: RO. Boar 208 [ WicMa, Kansas 67201 - TeMphone: Area Code (316) 2616451

Mr. H. R. Denton KMLNRC 86-008 Page 2 January 20, 1986 Refuel 1 is the next scheduled shutdown and is currently scheduled to begin in October, 1986. In the event of any unanticipe;ed delays in the refueling schedule a unit shutdown to perform these surveillances will be initiated by October 31, 1986. Therefore this request entails an approximate seven month extension in the most limiting case. If an unscheduled shutdown of sufficient duration and resulting in appropriate plant conditions occurs prior to Refuel 1, Kansas Gas and Electric Ccxnpany intends to perform any surveillances that can be completed. Since refueling outages normally occur approximately every twelve to eighteen months, extensions beyond the 24 month maximum interval required by the Technical Specifications and 10 CFR 50 Appendix J, Section III.D.3 are not usually necessary. However, due to the extended plant startup program c.nd plant performance during Cycle 1, Kansa Gas and Electric Company is requesting the aforementioned temporary exemption to 10 CFR 50, Appendix J, Section III.D.3. Without the requested temporary exemption Wolf Creek Generating Station would be forced into an outage for the purpose of surveillance testing.

Empimentation of this temporary exemption will not present an undue risk to the public health and safety as specifically evaluated in the Attachnents.

The Ccximission has provided that special circumstances must be present for an exemption request to be considered. They have further provided that special circumstances exist when, "The exemption would provide only tmporary relief from the applicable regulation ard the Licensee or Applicant have made good faith efforts to comply with the regulation;".

This temporary exertption request fully complies as previously discussed, with this example of "special circumstances".

Enclosed is a check (No. 67590) for the $150.00 application fee required by 10 CFR 170.21. If you have any questions concerning this matter, please contact me or Mr. O.L. Maynard of my staff.

Very truly yours, Glenn L. Koester Vice President - Nuclear GLK:see Enclosure

Attachment:

I-Safety Evaluation II-Type C LLRT Test Date III-Significant Hazards Consideration cc: PO'Connor (2) w/a JCurmins w/a FJohnson w/a

STATE OF KANSAS )

) SS CITY OF WICHITA )

Glenn L. Koester, of lawful age, being first duly sworn upon oath says that he is Vice President - Nuclear and an Officer of Kansas Gas and Electric Company; that he has read the foregoing document and knows the content thereof; that he has executed the same for and on behalf of said Company with full Power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.'

., By  %) >

f dienn L. Koester j Vice President - Nuclear SUBSCRIBED and sworn to before me this 20th day of January , 1986 . ,

t t

1 InA (%uadau Notary Public ,

C* m m ion E4'A'* f- N u.s ..

t.:

! !. o3 OI  ! > n*i

\,% . % .

. bl

' fhy $% ,,'

t,d t

4 i

i

E 3

A rra c e G N P I I

(

l l

l l

Mr. H. R. Denton Attachment I to KMLNRC 86-008 Page 1 of 2 SAFE 1T WALUATION This application requests a revision to the Wolf Creek Generating Station, Unit No. 1, Technical Specifications Section 4.6.1.2.d to allow a one-time only deferment of the specified 24 month m ximum surveillance interval on the below listed containment penetrations for the first operating cycle only (Cycle 1); provided these surveillances are performed prior to startup following the first refueling outage (Refuel 1) . These surveillances cannot be safely performed et POWER OPERATION. The proposed changes to the Wehnical Specifications are provided as Attachment IV.

Refuel 1 is the next scheduled shutdown and is currently scheduled to begin in October, 1986. In the event of any unanticipated delays in the refueling schedule a unit shutdown to perform these surveillances will be initiated by October 31, 1986. Therefore this request entails an approxiste seven month extension in the most limiting case. If an unscheduled shutdown of sufficient duration and resulting in appropriate plant conditions occurs prior to Refuel 1, Kansas Gas and Electric Conpany intends to perform any surveillances that can reasonably be completed. Since refueling outages normily occur approximately every twelve to eighteen months, extensions beyond the twenty four nonth eximtra interval allowed by the Technical Specifications are not usually necessary. However, due to the extended plant startup program and plant performnce during Cycle 1, Kansas Gas and Electric Conpany is requesting the aforenentioned Technical Specification Revisions. Without the requested revisions Wolf Creek Generating Station would be forced into an outage for the purpose of surveillance testing.

Penetration Valve Surveillance Due Date P-41 . . . . . . . . . . . . . BB-Vll8 .... 12/12/86 BB-HV8351A .... 07/12/86 P-22 . . . . . . . . . . . . . BB-V148 .... 07/06/86 BB-W8351B .... 07/07/86 P-39 . . . . . . . . . . . . . BB-V178 .... 07/09/86 BB-HV8351C .... 07/11/86 P-40 . . . . . . . . . . . . . BB-V208 .... 07/09/86 NW8351D .... 07/09/86 P-24 . . . . . . . . . . . . . BG-V135 .... 03/01/86 BG-HV8100 .... 03/01/86 BG-W8112 .... 08/25/86 P-74 . . . . . . . . . . . . . EG-V204 .... 07/19/86 y EG-W58 .... 12/04/86 y ec-W127 .... 12/04/86 P-80 . . . . . . . . . . . . . BG-8381 .... 04/13/86 BG-W8105 .... 07/18/86 P-23 . . . . . . . . . . . . . BG-W8160 .... 04/19/86 BG-HV8152 .... 04/22/86 P-71 . . . . . . . . . . . . . EF-HV31 .... 07/12/86 P-73 . . . . . . . . . . . . . EF-HV45 .... 06/09/86 EF-HV47 .... 06/09/86 P-2 8 . . . . . . . . . . . . . EF-HV32 .... 09/25/86 P-29 . . . . . . . . . . . . . EF-HV46 .... 09/25/86 1* Note these valves included only for completeness

Mr. H. R. Denton Attachment I to KWERC 86-008 Page 2 of 2 For each of the penetrations considered in the request for extension of the surveillance interval, it can be shown that one or both of the following design parameters apply:

1. A closed ASMS piping system (inside and/or outside containment) precludes the release of containment atmosphere to the environs.

2. Should an isolation valve leak slightly when closed, the pressurized fluid seal within the pipe irecludes release of containnent atmosphere to the environs.

Specific details for each contairment penetration are included as Attachnent II and III. In each case, possible degradation of a containnent leakage barrier does not result in a release of radioactive materials from the containment atmosphere.

Therefore, the proposed amendnent does not increase the probability or consequences of an accident previously evaluated.

The proposed change does not involve hardware changes nor a change in the manner in which the isolation systens at each penetration functions.

Therefore, the possibility of creating a new or different kirx1 of accident fran any accident previously evaluated does not exist.

The proposed change does not alter the leakage rate limitations established in the Technical Specifications. Therefore, the margin for possible deterioration of the contairment integrity during the service intervals between tests has not been reduced. Additionally, the integrity of the closed systens has been verified by the Containment Integrated Leak Rate Test (ILRT). The inpact of extending the testing interval of penetrations bounded by these closed systems is reduced by satisfactory ILRT results.

The requested revisions would not have a significant inpact on safe operation of the plant when conpared to the transient associated with a shutdown for the purpose of performing the m surveillances. Based on the above and the considerations presentM in Attachment III, the aforeneutioned proposed revisions to the Wolf Cteek Generating Station, Unit No. 1, Technical Specifications do rut adversely affect or endanger the health or safety of the general public or involve a significant safety hazard.

4 4

ATrM2eemer II

Mr. H. R. Denton  !

Attachment II to 101LNRC 86-008 Page 1 of 2 TAIK.E lh' TYPE C ILRT TENF DhTA (AIR TEST)

I  % of Current Measured Total Test Leak Rate Measured Valve Penetration Valve (1) Date secm(air) Leakage (2) Type (3) i P-41 BB-V118 12/12/84 8.59 00.0142 1 BB-W8351A 07/12/84 4.32 00.0071 3 P-22 BB-V148 07/06/84 211. 00.3485 1 I

BB-W8351B 07/07/84 10.37 00.0171 3

03/24/85 6.25 00.0103 3

)

f P-39 BB-V178 07/09/84 0.30 00.0005 1 BB-W8351C 07/11/84 4.40 00.0073 3 P-40 BB-V208 07/09/84 89.5 00.,1478 1 BB-W8351C 07/09/84 165.5 00.2734 3 P-24 BG-V135 02/29/84 14.43 00.0238 1 1 BG-W8100 02/29/84 5.64 00.0093 2 BG-W8112 08/25/84 2.93 00.0048 2 l

P-74 W V204 07/19/84 1383. 02.2843 1

! GW58 12/04/84 1276. 02.1075 2 G W127 12/04/84 - - 2 P-80 BG-8381 04/13/84 2.35 00.0039 1 BG-W8105 07/18/84 28.8 00.0476 2 I P-23 BG-W8160 04/19/84 30.7 00.0507 4 BG-W8152 04/22/84 66.1 00.1092 4 Total 3310.18 05.4673 i

l Notes: (1) Valves GW58 and WW127 tested simultaneously I

j (2) % of current total measured leakage value = (current i

measured valve leak rate / current combined leakage rate (60,545 scan)) x 100 l

(3) Valve Types: 1. Check Valve

2. Motor-Operated Gate Valve

3. Motor-Operated Globe Valve

4. Air-Operated Globe Valve i

i l

}

.e,.

Mr. H. R. Denton Attachment II to KMLNRC 86-008 Page 2 of 2 f ff? .l TAIK.E IB TYPE C I4RT TIBF DhTA (MTER TIBr) -

c, .

i , I t

Measured Acceptance Test Leak Rate Criteria (2)

Penetration Valve (l) Date ml/hr ml/hr ,

! P-71 EF-W31 07/12/84 0 420 EF-W33 07/12/84 0 420

.a l P-73 EF-W45 06/09/84 0 420 EF-W47 06/09/84 0 300

}

EF-W49 06/09/84 0 420 P-28 EF-W32 09/25/84 0 420 i

EF-W34 09/25/84 0 420

, p-29 EF-W46 09/25/84 0 420 EF-W48 09/25/84 0 300

, EF-W50 09/25/84 0 420 i

neotes: (1)All valves are motor operated butterfly valves 4

(2)'Ite acceptance criteria is based on the criteria j contained in ASME Section XI, Section IW-3426 which is 30(d) ml/hr where d= valve diameter 4

e k

f t

l I

l l

• l t

W ATFiC MEKr III

Mr. H. R. Denton Attachment III to KMLNRC 86-008 Page 1 of 5 SIGNIFICANT HAZARDS CONSIDERATION This application requests a revision to the Wolf Creek Generating Station, Unit' No. 1, Technical Specifications Section 4.6.1.2.d to allow a one-time only deferment of the specified 24 month maximum surveillance interval for the first operating cycle only (Cycle 1); provided these surveillances are performed prior to startup following the first refueling outage (Refuel 1) .

These surveillances cannot be safely performed at POWER OPERATION. 'Ihe proposed changes to the Technical Specifications are provided as Attachment IV.

Refuel 1 is the next scheduled shutdown and is currently reheduled to begin in October, 1986. In the event of any unanticipated delays in the refueling schedule a unit shutdown to perform these surveillances,will be initiated by October 31, 1986. Therefore this request entails an approxinute seven month extension in the most limiting case. If an unscheduled shutdown of sufficient duration and resulting in appropriate plant conditions occurs prior. to Refuel 1, Kansas Gas and Electric Company intends to perform any surveillances that can reasonably be completed. Since refueling outages normally occur approxinntely every twelve to eighteen months, extensions beyond the twenty four month nnximum interval allcwed by the Technical Specifications are not usually necessary. However, due to the extended plant startup program and plant performance during Cycle 1, Kansas Gas and Electric Cmpany is requesting the aforementioned Technical Specification Revisions. Without the requested revisions, Wolf Creek Generating Station would be forced into an outage for the purpose of surveillance testing.

Penetration P-24 Reactor Coolant Pump Seal Water Return This penetrati.m provides a return path for Reactor Coolant Pmp No.1 leak-offs and a flow path for excess letdown when excess letdown is directed to the suction side of the centrifugal charging pump. (See FSAR Figure 6.2.4.1, Page 20)

The piping from penetration P-24 is quality group B (ASME III, Class 2) ,

Seismic Catagory I and forms a closed loop outside containnent by way of the seal water heat exchanger to the suction side 'of the charging pumps in the emrgency core systen (ECCS) cooling recirculation loop. Isolation valves T,-HV-8100 and BG-HV-8112 close on receipt of a CIS-A signal.

Any back leakage from the containment through .the penetration would be returned to containnent by way of the emrgency core cooling systen recirculation loop.

I h

t e

Mr. H. R. Denton Attachment III to KMLNRC 86-008 Page 2 of 5 Penetration P-80 Normal Charging This penetration provides the normal charging flow path to the reactor coolant systen by way of the regenerative heat exchanger. (See FSAR Figure 6.2.4-1, Page 57)

The piping both inside and outside of containment is Quality Groups A and B (ASME III, Class 1 and 2), Seismic Category I.

The outside contaiment isolation valve BG-W-8105 closes on receipt of a Safety Injection Signal (SIS). In addition, valve BG-W-8106 located outside containment closes on a SIS, providing ' additional isolation.

Following a postulated accident, the Auxiliary Building side of Penetration P-80 will be pressurized by the centrifugal charging pump while operating in the ECCS nxxle which precludes back-leakage from containment through this penetration.

In addition, there are two (2) check valves inside contaiment located in the Quality Group A portion of the piping systen, between the reactor coolant systen (RCS) and the regenerative heat exchanger which provides an additional boundary against leakage from contalment.

Penetration P-23 CVCS Normal Letdown This penetration provides a flow path for reactor coolant letdown from the RCS to the chenical and volume control systen (CVCS) outside contairunent.

(See FSAR Figure 6.2.4-1, Page 19)

The piping inside the contaiment from the RCS is Quality Group A (ASME III, Class 1) , Seismic Category I, through two air-operated RCS isolation valves BG-IfV-459 and BG-ILV-460. These valves irolate on low pressurizer level and are designed to fail close. The piping between these isolation valves and the containnent penetration is Quality Group B (ASME III, Class 2),

Seismic Categroy I. In addition, letdown orifice isolation valves BG-HV-8149 A, B, and C, located inside containnent, isolate on low pressurizer level and are designed to fail close. The containment isolation valves BG-HV-8160 and BG-W-8152 close on receipt of a CIS-A signal.

The automatic isolation valves BG-LCV-459, BG-LCV-460 and BG-HV-8149 A, B, C combined with the design of the piping systen between these valves and penetration, provide an additional boundary against leakage from containment.

~

Mr. H. R. Denton Attachment III to KMLNRC 86-008 Page 3 of 5 Penetrations P-28, P-29, P-71, P-73 Essential Service Water (ESW) to and from contalment air coolers.

These penetrations provide an ESW flow path to and from the contalment air coolers. The piping system inside containent is Quality Group C (ASME III, Class 3), Seismic Category I, and closed loop. (See FSAR Fig. 6.2.4-1 Pages 24, 25, 50 & 51)

The ESW piping and the contaiment air cooler inside contalment serve an essential safety-related function. These penetrations are classified as essential penetrations with their associated isolation valves opening on receipt of a SIS.

With the ESW Systen operating under postulated accident conditions, the pressure at the penetrations will be greater than containment pressure.

Considering the conservative single failure assumption i.e. only one train in operation, no flow would exist to the two penetrations in the non-operating train.

The ESW piping inside contairment, by the nature of it being a closed loop, provides an additional boundary to prevent containment leakage. In addition, outside contaiment, the water filled system provides a water seal to preclude leakage.

Penetrations P-22, P-39, P-40, P-41 RCP Seal Water Supply These penetrations provide a flow path from the CVCS charging pmps to the reactor coolant pump seals. (See FSAR Fig. 6.2.4-1 Pages 18, 29, 30 & 31)

These penetrations are classified as essential penetrations which are open following a postulated accident. These penetrations direct water from the centrifugal charging pumps to the Reactor Coolant Systen (RCS) .

Outside containment, the systen is Quality Group B (ASME III, Class 2),

Seismic Category I. These penetrations are pressurized by a centrifugal charging pump. These penetrations perform an ECCS function and therefore do not require automatic isolation.

In addition, there are two (2) check valves located inside contalment between the RCS and its associated penetration which provide an additional boundary against leakage from contairment.

1 I

1 I

3

Mr. H. R. Denton Attachment III to KMLNRC 86-008 Page 4 of 5 Penetration P-74 Component Cooling Water to the Reactor Coolant Pmps

'Ihis penetration provides a flow path for component cooling water to the reactor coolant pump auxiliaries and other safety-related components. (See FSAR Fig. 6.2.4-1 Page 52)

The Conponent Cooling Water System (CCWS) is Quality Group B and C (ASME III, Class 2 and 3), Seismic Category I, and a closed loop both inside and outside containnent.

Penetration P-74 is classified as an essential . penetration with isolation not required until receipt of a CIS-B signal. Also the component cooling water surge tank, located in the Auxiliary Building, is provided with a radiation manitor located on the vent line which isolates the vent valve on high radiation. Therefore, a closed system outside of containment is assured.

The CCWS piping inside containment, by the nature of it being a closed loop, provides an additional boundary against leakage from containment. Wen the OCWS is in operation following a postulated accident, the pressure at the penetration will be greater than containment pressure. Considering the conservative single failure assumption, i.e. only one train in operation and flow to the penetration isolated, leakage would be contained by the closed loop outside containnent.

Strumary Generically, each of the subject penetrations is from the Containnent into the Auxiliary Building. Leakage through the respective isolation valves would be to a fluid filled system. Penetrations P-22, P-39, P-40, P-41 and

. P-80 are at a pressure higher than the maximum containment postulated peak accident pressure. Except for penetrations P-23 (normal letdown) and P-71, 73, 28, 29 (ESW supply and return), the system associated with the remaining penetrations are totally contained within the Auxiliary Building.

Leakage from these systems into the Auxiliary Building would be filtered by the automatically actuated, safety-related Dnergency Exhaust Systen. It should be noted that the dose calculations for accidents presented in Chapter 15 of the FSAR are based on 100 percent unfiltered leakage from containment, i.e. no specific credit has been taken for filtered leakage from containment through the Auxiliary Building.

Mr. H. R. Denton Attachment III to KMLNRC 86-008 Page 5 of 5 W e containment leakage rate specified by 10 CFR Part 50, Appendix J and the WCI3S Technical Specifications is a combined leakage rate of less than 0.60 La for all penetrations and valves subject to Type B and C tests, when pressurized to Pa. For WCX3S 0.60 La is 252,028 sccm at a Pa of 48 psig.

The present combined total measured leakage rate (Dn) is 60,545 sccm, which is less than 25 percent of the allowable. Attachment II provides a sumnary of the LLRT Type C test Data for the subject penetrations. The total leakage rate associated with these penetrations is small when compared to the total measured leakage rate Lm for WCGS and therefore, if higher leak rates were to exist the effect would be insignificant.

The requested surveillance interval extension applies only to Type C LLRT requirements. All surveillances associated with demonstrating the.

operability of the containment isolation valves are current and will continue to be performed as required. Therefore, the above assessment conbined with the assured operability of the valves denonstrates that the safety-related function of these penetrations is maintained.

Based on of the above discussions and those presented in Attachment I, it has been determined that the requested Technical Specification revision does not involve a significant increase in the probability or consequences of an accident or other adverse condition over previous evaluations; or create the possibility of a new or different kind of accident or condition over previous evaluations; or involve a significant reduction in a margin of-safety. merefore the requested license amendment does not present a significant hazard.

J i

i 1

I

- . . _ . .