ML20140E099

Submits Objections to Proposed Change 200 & Suppl 1 to Proposed Change 200,revising Plant Cl Testing Requirements to Those Permitting Use of 10CFR50,App J,Option B

ML20140E099
Person / Time
Site:	Maine Yankee
Issue date:	04/15/1997
From:	Dostie P MAINE, STATE OF
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9704250065
Download: ML20140E099 (3)

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Angus S. King. Jr. Kevin W. Concannon j STATE OF MAINE j DEPARTMENT OF liUMAN SERVICES AUGUSTA. MAINE G4333 Y ,

April 15,1997 1

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United States Nuclear Regulatory Commission ,

. Attention

Document Control Desk l

[ Washington, D.C. 20555 '

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! Suoject: Maine Yankee Atomic Power Company - Proposed Change No. 200 and Supplement 1 to Proposed Change No. 200 - Implementation of 10CFR50, Appendix J, Option B Gentlemen:

In accordance with 10 CFR 50.91-(b) the State of Maine has reviewed the proposed amendment and supplement revising Maine Yankee's Containment Leakage Testing requirements to those permitting use of 10CFR50, Appendix J,~-

Option B, Performance-Based Containment Leakage Rate Testing, for Type A I integrated containment leak rate tests and for Types B and C localized leakage rate tests. J Although the State- comprehends the intent of the Technical Specification change, there are several inconsistencies, which disturb us. Because of these concerns, the State objects to the proposed change for the following reasons:

- 1) In section 4.4.1.3 (a) of the proposed change, Maine Yankee appears to be establishing, by default, a calculated peak accident pressure, P., of 50 psig. Since December of 1995 Maine Yankee has been reanalyzing its calculated peak accident pressure as part of an allegation inquiry.

Although the final value has not been published yet, current estimates place it very near to its design pressure of 55 psig. We believe ihat as written the Tech Specs would automatically default in the future to 50 psig instead of any newly calculated peak accident pressure. This could lead to an interpretation that Type A, B, and C tests performed at 50 psig, instead of the reanalyzed peak accident pressure, would be appropriate, f, even though they would be in direct conflict with the intent and requirements of Appendix'J, Option B. [g 9704250065 970415  %

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2)_In sections 4.4.1.1,4.4.11.1,4.4.ll.2, and 4.4.11.3 of the proposed change the phrase, "as modified by approved exemptions", appears

' irrelevant as any exemptions from the rules would require NRC approval

, prior to implementation. Besides , if Maine Yankee were to endorse another methodology, other than the one cited in Regulatory Guide 1.163, that methodology would also require NRC approval under Appendix J (B)

, (V-B) prior to implementation. Likewise, if there were any future revisions of Reg. Guide 1.163, Maine Yankee would still be committed to the September 1995 version, unless it wished to adopt the updated revision, ,

l in which case NRC approval would probably be required. Moreover, this  !

phrase further implies that exemptions for testing requirements already

[ exist in the FSAR or Tech Specs. We have been unable to uncover any ,

[ exemptions that are mentioned in either document. )

i j 3) In 10CFR50, Appendix J (B) (Ill-A) it stipulates that for a Type A test 1 l the allowable leakage rate (L.) with margin must be specified in the Tech  !

l' Specs.' Furthermore, it also states that the sum of the leakage rates at P. l

" for Type B and C tests must be less than L. with margin and also be  !

specified in the Tech Specs Yet,' except for the Type B air lock test, no I i margins are designated in the Tech Specs. It would seem appropriate that the margins be at least cited in the basis section of the Tech Specs.

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4) The State is willing to accept Maine Yankee's position that the last full l pressure test conducted in 1988 meets the industry guidance as set

j. forth in Reg. Guide 1.163. However, the State is very concerned that the j NRC considers extrapolations of reduced pressure tests to full pressure tests as unsuccessful and that Maine Yankee has performed only one full pressure test in the last 25 years. To ensure greater confidence in the integrity of the containment building, the State proposes that Maine Yankee commit to the NRC that the next Type A test will be performed at the reanalyzed peak accident pressure and within the 10 year testing interval since Maine Yankee's last full pressure test in October of 1988.

1 Furthermore, the State has additional comments and concerns that it wishes to i express. First, we are very concerned that, if a Type A test fails, the industry l guidance cited in Reg. Guide 1.163 allows up to four years before another retest  ;

is administered to ensure acceptable performance. We consider this an unreasonable amount of time after a failed test to ensure containment integrity.

. We believe a timely retest, such as prior to a plant startup, would be more appropriate. Secondly, Reg. Guide 1.163 recommends that containment purge valves should be limited to a 30 month testing interval. We assume Maine

. Yankee will abide by this recommendation as the historical performance of their purge valves has been less than exemplary. Finally, although we have not seen any documented evidence that Maine Yankee has committed to ANSl/ANS 56.8-1994, we presume they will as both the industry guidance and Reg. Guide 1.163

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refer to this standard as a means of demonstrating compliance with Appendix J, l Option B. l i

Should you have further questions on these comments, please contact me. My l telephone number at the Maine Yankee facility is 207-882-5349.

l Respectfully yours, Patrick J. Dostie State Nuclear Safety Inspector Office of Nuclear Safety '

Division of Health Engineering i

1 cc:

Dr. Dora Anne Mills, State of Maine i Mr. Clough Toppan, State of Maine Mr. Robert Schell, State of Maine Mr. Uldis Vanags, State of Maine Mr. Jimi Yerokun, NRC Mr. James Hebert, Maine Yankee ,

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