ML20155C356
| ML20155C356 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 11/10/1982 |
| From: | WISCONSIN PUBLIC SERVICE CORP. |
| To: | |
| Shared Package | |
| ML111750746 | List: |
| References | |
| TAC-49131, NUDOCS 8810100009 | |
| Download: ML20155C356 (24) | |
Text
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l ATTACHMENT 1 l
l TO LETTER FROM C. W. GIESLER TO S. A. VARGA b
(_
l PROPOSED AMENDMENT No. 52 TO THE KNPP i
TECHNICAL SPECIFICATIONS, SECTION 4.4 i
j CONTAINMEET TESTS t
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4.4 Containasnt Tests Applicability Applies to integrity testing of the steel containment, sheild building, auxi-liary building special ventilation zone, and the associated systems including isolation valves.
Obj ective To verify that leakage from the containment system is maintained within allowable limits in accordance with 10CFR50, Appendix J.
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Specification l
a.
Integrated Leak Rate Tests (Type A) i j
1.
The minimum test temperature will be 50*F.
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2.
Integrated leak rate tests shall be performed et intervals specified in 4.4.a.7 at reduced pressure (Pe) of 23 psig or at a peak pressure J
(Pa) of 46 poig.
52 3.
Af ter test condition stabilisation, the test duration shall be a mini-aus of eight hours and shall have a total of not less than 20 sets of 2
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data points at approximately equal time intervals.
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4.
All fluid systems which, under post accident conditions, become an l
l extension of the containment presssure boundary shall be opened to the containment atmosphere prior to the test.
Systems that are required for i
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proper conduct of the test or to maintain the plant in a safe oondition during the test shall be operable in their normal mode and need not be vented or draine,1. Additionally, systems that are normally filled with I
water and operable under post-accident conditions need not be vented or i
TS 4.4-1 Proposed Amendment No. 52
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11/10/82 i
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is21stien valves shs11 be cccomplish:d C1cauro of contcinment drain:d.
by the normal mode of operation.
ive leakage may be iso-Once the Type A test has begun, paths of excessUpon completi 5
laced in order to complete the Type A test. leakage, shall be Type 's o A test, all paths isolated due to excessive l iso-Necessary repairs shall be made and the previous y C leak tested.
The test results shall be reported lated paths retested (Type B or C).
l leakage rates, (corrected to with both the pre-and post-repair loca had been conducted.
t test pressure), as if two Type A tes s Acceptance Criteria 0.5 weight percent of the 6.
The maximum allowable leakage rate, La, is ressure, Pa, of 46 psig.
l a.
contained air per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at the peak test p 07025, weight percent The maximum allowable leakage rat,e, Le, is 0.
d ced test pressure, Pg, b.
of the contained air per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at the re u I.52.','
of 23 psig.
red leak rate At a peak test pressure (Pa) of 46 peig, the measu i
c.
52 (L..) shall be less than 0.75 L..
asured leak rate h
At a reduced test pressure of (Pe) 23 psig, t e me d.
(Lg ) shall b3 less that 0.75 L,
t tests subsequent to The frequency of periodic integrated leak rate be perforacd at approxi-7.
preoperational tests shall be three tests to ervice period. The third test f
mately equal intervals during each 10 year s ling outage that occurs f
of each set shall coincide with a major re ue j
id within 6 months of the end of the 10-year per o.
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Proposed Amendment No. 52 i
TS 4.4-2 11/10/82
7-3.
If the leak race ca;4ca.ned by eny test exce ds ths caximus allowable leak race. the tes: ;ch+dule applicablo to subsequsnt integrated leak rate tests shall be Subj e c t to review and approval by the Commission.
If the leik rate determined by two consecutive periodic tests exceeds the maximus allowable lesk rate, subsequent tests shall be performed at each major refueling outsgo until two consecutive tests have been per-formed for which the leak rate does not exceed the maximum allowable.
b.
Local Leak Rate Tests (Type B and C) 1.
Type B & C tests as defined in 10CTR50 shall be periodically conducted at a pressure not less chan 46 psig (Pa). The leak tests may be con-ducted utilizing pressure decay, soap bubble, halogen detection, or equivalent metnods.
2.
Leak teste shall be performed during, or within one month of, each major refueling outage, but are not to exceed two years between tests.
3.
Local leak rate tests may be performed prior to the integrated leak 52 rate test.
4.
Personnel Air Lock Testing a.
Each personnel air lock shall be tested at six month intervals uti-lizing a Type B test at Pa*
b.
Air locks opened during periods when containment integrity is not required shall be tested at the end of such periods at not less than (Pa) 46 psig.
Air locks opened during periods when containment integrity is c.
required shall be tested within 3 days of being opened. Air locks opened more frequently than once every 3 days shall be tested at least once every 3 days during the period of frequent openings.
TS 4.4-3 f roposed Amendment No. 52 11/10/82
r' Tcsting th3 cir lack door dtuble s:als fulfills the 3 dcy test rcquirement. DAir lock door s:cl testing shall n2t be substituted for the six-month test.
d.
The overall air lock leakage rate shall be in accordance with speci-fication 4.4.b.8.
5.
Safety Injection System (High Head)-
Those portions of the Safety' Injection System in service post-s.
accident shall be hydrostatically tested by closure of the motor operated valves nearest the reactor coolant system and operation of a
the pumps on the minimum flow test line to the refueling water storage tank.
This test shall be performed during each major
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refueling outage.
b.
Leakage shall be determined by visual observation. Visible leakage that cannot be stopped 4t' test conditions shall be suitably measured to demonstrate compliance with Spec'ification 4.4.b.8.d.
52 J
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c.
Any repairs necessary to meet the specified leak rate shall be I
accomplished within seven days of resumption of power operation.
6.
Internal Containment Spray System l
4 a.
Those portions of the Internal Containment Spray System in service N
post-accident shall be hydrostatically tested by closure of the J
nanual isolation valves nearest the spray ring assembly and opera-tion of the pumpe on the 2" test line to the refueling water storage tank. This test shall be performed during each major refueling i
outago.
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TS 4.4-4 Proposed Amendment No. 52 11/10/82 l
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r b.
Leekcgo chall be determinsd by visual obsorvction. Visible leckcge th t cannot be stoppsd at test conditions chall be suitebly usasural to demonstrate compliance with Specification 4.4.b.8.d.
c.
Any repairs necessary to meet the specified leak rate shall be accomplished within seven days of resumption of power operation.
7.
Residual Hest Removal System a.
Those portions of the Residual Heat Removal Systen external to the isolation valves at the reactor coolant system shall be hydrostati-cally tested in excess of 350 peig at each major refueling outage, or they shall be tested during their use in normal operation at least once between successive major refueling outages.
b.
14akage shall be determined by visual observation. Visible leakage that cannot be stopped at' test conditions shall be suitably measured 52 to demonstrate compliance with Specification 4.4.b.8.d.
c.
Any repairs necessary to meet the specified leak rate shall be accoep.11shed within seven days of resumption of power operation.
8.
Acceptance Criteria l
If the combined leak rate from all Type 3 & C tests as determined by a.
the sua of the most recent results for each penetration test, i
exceeds 0.60 L., repairs and retest shall be performed to dbnetratereductionofthecombinedleakratetothisvalue.
b.
The tests described in this section, 4.4.b. shall include the penetrations which extend from the containment vessel to the TS 4.4-5 Proposed Amendment No. 52 e
11/10/82
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j Spocial Ventilction Zons of the. Auxiliary Building.
If the con-bined leak race from tests of these psnotretions. as determined by the sum of the most recent results for each penetration, exceeds 0.10 L, repairs and retest shall be performed to demonstrate a
reduction of the combined leak rate to this value.
1 c.
The tests described in this section, 4.4.b. shall include tha penetrations which extend from the containment vsesel beyond the boundary of the Special Ventilation Zone of the Auxiliary Building.
If the combined leak rate from tests of these penetrations, as determined by the sua of the met recent results for each penetra-tion, exceeds 0.01 L. repairs and retest shall be performed to e
demonstrate reduction of the combined leak rate to this value.
d.
The combined leakage from all trains of the RMR, Safety injection, and Internal Containment Spray systema shall be less than six (6) 52 gallons per hour.
c.
Shield Building Ventilation System r
1' 1.
At least once per operating cycle or once every 18 monthe whichever occurs first, the following conditic,as shall be dwoonstrated j
I a.
Pressure drop across the combined HEPA filters and charcoal absorber.
j banks is less than 10 inches of water and the pressure drop across
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any NEPA filter bank is less than 4 inches of water at the systes
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design flow rate (+101).
52 b.
Automatic initiation of each train of the systes c.
Operability of heaters at rating and the absence of defects by 52 l
visual observation.
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TS 4.4-6 Proposed Amendment No. 52 11/10/s2
2.
c.
Tho in-plcco DOP tost for HEPA filtors shall bo performed (1) at I
least once per 18 months and (2) following painting, fire or chesi-cal release in any ventilation zone communicating with the system.
b.
The laboratory tests for act!,vated carbon in the charcoal filters 1
shall be performed (1) at least once per 18 months for filters in a standby status or after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of filter operation, and following l
l painting, fire or chemical release in any ventilation zone com-l l
eunicating with the system.
c.
Cold DOP tasting shall be performed af ter each complete or partial replacement of a HEPA filter bank or af ter any maintenance on the system that could affect the HEPA bank bypass leakage.
d.
Ralogenated hydrocarbon testing shall be performed af ter each complete or partial replacement of a charcoal adsorber bank or af ter any maintenance on the sys(en that could affect the charcoal absorber bank bypass leakage.
e.
Each train shall be operated with the heaters on at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> every month.
3.
An air distribution test on these HEPA filter banks will be performed after any maintenance or testing that could affect the air distribution within the systems.
The test shall be performed at design flow rate (t 10%). The results of the test shall show the air distribution is uniform within 120%.*
4.
Each train shall be determined to be operable at the time of its periodic test if it produces measurable - dicated vacuum in the annulue within two minutes af ter initiation of a simulated safety injection See Note TS 4.12.b.4 TS 4.4'-7 Proposed Amendment No. 52 11/10/82
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signal cnd obtains cquilibrium dischargs co ditic s th;t demonstr:to the l
Shield Building icektgo is within acceptablo licits.
d.
Auxiliary Building Special Ventilation System 1.
Periodic tests of the Auxiliary Building Special Ventilation System, l
including the door interlocks, shall be performed in accordance with Specifications 4.4.c.1 through 4.4.c.3 except for Specification 4.4.c.2.e.
2.
Each train of Auxiliary Building Special Ventilation Systen shall be operated with the heaters on at least 15 minutes every month.
3.
Each systen shall be determined to be operable at the time of periodic test if it starts with coincident isolation of the normal ventilation ducts and produces a measurable vacuum throughout the Special Ventilation Zone with respect to the outside atmosphere.
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e.
Containment Vacuun Breaker Systes The power operated valve in each vent line shall be tested during each t
refueling outage to demonstrate that a staulated containment vacuus of 0.5 psig will open the valve and a simulated accident signal will close the valve. The check and butterfly valves will be leak tested in accordance with specification 4.4.b during each refueling, except that the pressure
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will be applied in a direction opposite to that which would occur post-LOCA.
Basis I
Background
r Containment leak testing and leak testing extensions of the containment atmosphere must be done to verify that operation is bounded by the safety I
analysis.(2) The testing process will includes (1) an overall containment leak
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rate evaluation (Type A), (2) a determination of the leakage through pressure TS 4.4-8 Proposed Amendment No. 52 11/10/82 l
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centcining er leak:gs liciting boundari*ds (Type B). and (3) In ovaluation of the ! *. -
lock reto through contcinment isolation valves (Typo C).(3)
These tests are n
intended to check all possible paths for containment atmosphere to reach the j
i outside atmosphere.
If measured leak rates are at an unacceptablo lovci, the above mentioned tests will provide a means for locating paths of excessive 1
leakage.
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Minimus Test Temperature (TS 4.4.a.1) i l
During containment pressurisation the containment atmosphere temperature shall F
t not reach a level that challenges the ductility of any steel component located I
L within the shield building. A minimum test temperature of 50' F (containment f
staosphere) provides for steel component safety (!)*
L Definition of Pe and P. (TS 4.4.a.2)_
If the Design Basis Accident (2) occurred during normal steady state power opera-tion the maxinua pressure during the transient would not exceed 46 psig. The I
primary containment shell has been successfully strength tested at $1.8 psig. A j
L conservative value of 46 psig was chosen as the pressure at which overall l
1 integrated leak tests will be conducted. Tests conducted at 46 psig or 23 psig I
will demonstrate the ability of the containment vessel to act as a barrier bet-52 ween containment atmosphere and outside atmosphere as would be needed in a post accident situation.
I Stabilization & Duration (TS 4.4.a.3)
Conditions shall stabilise prior to an ILRT such that an accurate inventory of containment atmosphere is maintained throughout the test. Conditions will be stabilised when temperature variations over cias are negligible. The contain-I ment vessel and atmosphere together form a thermodynamic systen to which there are two degrees of freedom. The assumption of constant containment volume
^t 4.4-9 Proposed Amendment No. 52 11/10/82
f 1 caves one degreo of freedon.
Choosing ec psraturo or prossuro es tho second degree of freedom fixes either the pressure or temperature, respectively. Once the containment has been pressurized the only changes in pressure will be caused by variations in temperature or leakage. Therefore, the condition of pressure stabilization shall be considered achieved upon temperature stabilization.
The duration of the test period must be sufficient to enable adequate data to be accumulated so that a leakage rate and upper confidence limit can be accurately determined. The test duration and number of data points required are in accor-dance with ANSI / ANS 56.8-1981. Containment System Leakage Testing Requirements.
Fluid Systems Vented (TS 4.4.a.4)
Venting of fluid systems which during post-accident conditions become an exten-sion of the containment atmosphere is necessary to insure that possible leak paths of containment air in a post-accident situation vill be verified as being leak tight or as needing repair. Those extensions of the contairusent atmosphere that are not vented prior to an ILRT include the following: RHR, SIS, ICS, CC, and SW.
ILRT's shall be conducted in a manner as would occur had a containment.
isolation signal been initiated.
52 Isolating Leaks During the Test (TS 4.4.a.5)
Isolating excessive leak paths during a W pe A test for later repair c. d completing the test ensures that the containment will be pressurized only once in conducting a Type A test. Type B or C leak testinig paths that were isolated during a Type A test provides the "as found" leakage.
Rapairing and retesting the once isolated leak paths provides the "as left" leakage. Adding the pre-repairleakagetotheILRTresultsyieldsthe"asfou)"totalintegratedleak rate while adding the post-repair leakage provides the "as lef t" total i
integrated leak rate.
TS 4.4-10 Proposed Amendment No. 52 11/10/82 i
Type A Test Acceptrncq Crit"ri+n (TS 6.4.n.6)
It h:s be:n recognized that tho quality of tho Contcina:nt Vascol cnd Penetration Seals used in the construction of the containment can permit meeting a 0.5 wt% per day leakage rate, (La).
This is conservative as the FSAR section 14.3-5, 0f fsite Dose Consequences, assumes a Containment Vessel leakage rate of 2.5 wtt per day for the first day tnd 1.25 ve% per day for the remaining 29 days.(2) The, acceptance criteria from Appendix J to 10CFR50, 0.75 La or 0.375 wt%, is still more conservative.
The assumptions used in the FSAR conform to NRC Safety Guide 4 and result in offsite doses within the criteria set forth in 10CFR100 following the Design Basis Accident.
Type A Test Frcquency (TS 4.4.a.7)
Integrated leak rate tests are done periodically to detect any deteriorating conditions that may adversely affect the ability of the primary reactor contain-ment to perform its intended function. The Commission has determined that three tests at approximately equal intervals within ten years is a suitable frequency.
10CTR50, Appendix J explains Type A test schedule modifications applicable if an Integrated Leak Rate Test does not meet the acceptanca criteria.
Local Leak Rate Tests (TS 4.4.b)
The Commission has determined that local leak rate tests will be performed at 52 Pa, which at KNPP is (46 psig). Conducting Type B & C tests at Pa vill determine
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whether these barriers to containment atmosphere will perform during the Design Basis Accident.
Periodically conducting Type C testa determines the degradstion 1
rate on the sealing capability of the isolation valves.
Present experience indicates that two years is the maximum tima interval that should be allowed before ratesting the sealing capability of individual valves.(5) The above l
reasoning also applies to Type 3 tests (pressure contai,ning and leak limiting
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bounda rie s ). Various methods have been developed for measuring local leak rates, all of which are equivalent.
TS 4.4-11 Proposed Amendment No. 52 11/10/82
T Porforcing Tvon B & C Tects Prior to Tvon A Test (TS 4.4.b.3) l Typa B and C toets ate condacted indspendsntly of Typs A toets.
Locci Icak rate tests are conducted during aach refueling outage whereas ILRT's are performed three times within a ten-year period. When an ILRT snd a Type B & C test are to be performed during the sane outage, it is preferable to conduct the Type B & C test prior to the ILRT.
Personneal Air Locks (TS 4.4.b.4) personnel Air Locks are a leak limiting boundary of the primary containment syntes and accordingly shall be Type B tested.
The frequency of testing air locks is greated than that for other Type B tests due to the nature of the penetration. Every six months the entire air lock shall be pressurized to Pa in order to determine its leak tightness. Air locks opened when containment integrity is not required shall be leak tested by pressurising the entire air lock before placing the plant in a condition requiring containment integrity.
Air locks opened when containment integrity is required shall be leak tested within three days of that opaning.
Air locks opened frequently (more than once 52 every three days) when containment integrity is required shall be leak tested once every three days. Testing the air lock door seals fulfills the three day testing requirement.
Hydrostatic Testing of SI, ICS and RNR (TS 4.4.b.4, 4.4.b.6 and 4.4.b.7)
The Safeguard Systems which operate post accident to cool the containment and maintain the reactor core in a safe condition become part of the containment system during the post-accident period. These safeguard systesa are designed to remain intact during and post-accident at which time they will be flooded and in operation. These safeguard systess are designed for pressures well in excess of the peak containment pressure. The protection of the health and safety of the public is assured by limiting the leakage from these systems rather than limiting the leakage through their isolation valves since these isolation valves TS 4.4-12 Proposed Asendment No. 52 11/10/82
will not be shut post-accidone. Tha refueling interval inspection spweified for ths piping of these systect will encuro tho Icek tightness of thoso systeca at pressures comparable to those pressures which would exist post-accident.
Technical SpecifAcations 4.4.6.5, 4.4.6.6. 4.4.6.7 incorporate the exemptions to 10CFR50 Appendix J requirements as allowed by 10CFR50.12 and granted by the Commission for the Kewaunee Nuclear Power Plant.(5)
Acceptance Criteria for Type B & C Tests (TS 4.4.b.8)
Appendix J to 10CTR50 defines the acceptable leak rate through Type 1 and C penetrations.
There are penetrations which extend the containment steosphere past the boundary l
b of the Special Ventilation Zone of the auxiliary building. Containment f
l atmosphere escaping through these paths will not be filtered through charcoal and j
t HEPA filters. Due to the special nature of these penetrations. the allowble leak rate is less than those penetratidas which would leak to the special ven-i tilation zone.
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f The Safety Injection System. Internal Containment Spray System, and Residual 52
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Heat Removal (RNR) systes are subject to containment sump water during their r
post-accident use. A radiological analysis was performed using the RMR system f
i to demonstrate that the liquid leakage limit would not result in doses greater j
than the 10CFR Part 100 guidelines.(2) As a result of that analysis the I
t allowable leakage for the RHR system was determined to be two gallons per hour f
per train. The SIS and ICS systems are subject to containment sump water and each systes is allowed a one gallon per hour leak rate. The total leakage of containement sump water would then be sin (6) gallons per hour to the auxiliary f
building special ventilation some. ( A15VZ). The resultant offsite dose from a leak of 6 sph of containment sump water to the ABSVZ will not exceed 10CFR100
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guidelines.
l TS 0.4-13 Proposed Amendment No. 52 l
11/10/82-l
Shiold Buildine Veneilation Syste (T9 4.4.e5 Pressure top across the combined hEPA i11cors and enare m aosorbers of less than 10 inches of water and an individual HEPA bank pressure drop of less than 4 inches of water at the system design flow rate (;10%) will indicate that the I
i filters and adsorbers are not clogged by excessive amounts of foreign ::atter.
A test frequency of once per operating cycle establishes systes performance capability. This pressure drop is approximately 6 inches of water when the filters are clean.
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l Shield Building Ventilation Systen Filter Testing (TS 4.4.e.2)
I The frequency of tests and sample analysis are necessary to show that the HEPA l
filters and charcoal adsorbers can perform as evaluated. Replacement adiorbent I
should be qualified according to the guidelines of Regulatory Guide 1.52 (Rev 1) dated June 1976. The charcoal adsorber efficiency test procedures should allow t
for the renoval of one adsorber tray, e9ptying of one bed from the tray, mixing
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t the adsorbent thoroughly, and obtaining at least two samples.
Each sample
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should be at least two inches in diameter and a length equal to the thickness of i
52 the bed. The use of multi-sample assemblies for test samples is an acceptable alternate to atxing one bed for a sample.
If the iodine removal efficiency test results are unacceptable, all adsorbent in the systen should be replaced. Any HEPA filters found defective should be replaced with filters qualified pursuant l
l to Regulatory Position C.3.4 of Regulatory Guide 1.52 (Rev.1) dated June 1976.
k If painting, fire or chemical release occurs such that the HgPA filter or char-i t
coal adsorber should become contaminated from the funes, chesteals, or foreign materials, the same tests and sample analysis should be performed as required f
for operational use.
TS 4.4-14 Proposed Amendment No. 52 11/10/82
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SBV Test Frequency (TS 4.4.c.3 & 6,4.c.4) k' Oporction of tha systema overy conth will demonstrate operability of the filters and adsorber system.
Operation of the Shield Building Ventilation System will result in a discharge to the environment.
This discharge is made af tet at least 3 samples of the building atmosphere have been analyzed to determine the con-l centration of activity in the atmosphere.
Auxiliary Building Special Ventilation System (TS 4.4.b.d) l Demonstration of the automatic initiation capability is necessary to assure l
system performance capability.(4)
Periodic checking of the inlet heaters and associated controls for each train will prov*de assurance that the system has the capability of reducing inlet air humidity so that charcoal adsorber efficiency is enhanced.
In-place testing procedures will be established utilizing applicable sections of 52 ANSI N510 - 1975 standard as a procedural guideline.
Vacuun Breaker Valves (TS 4.4.e)
The vacuum breaker valves are 18" butterfly valves with air to close, spring to open operators.
The valve discs are center pivot and rotate when closing to an EPT base material seat.
When closed, the disc is positioned fully on the seat regardless of flow or pressure direction.
Testing these valves in a direction opposite to that which would occur POST-LOCA verifies leakage rates of both the l
l vacuum breaker valves and the check valves downstream.
Referencest l
l (1) Updated FSAR Section 5.2 (2) Updated FSAR Section 14.3 (3) 10cFR Part 50. Appendix J (4) Updated FSAR Section 9.6 (5) Latter from Darrell C. Eisenhut to Carl W. Giesler dated September 30, 1982 TS 4.4-15 Proposed Amendment No. 52 11/10/82
f s
t 4.
Halogenated hydrocarbon testing shall be performed af ter each complete 33
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or partial replacement of a charcoal adsorber bank or af ter any maintenance on the system that could af fect the charcoal adsorber I
l bank bypass leakage.
c.
Perfom an air distribution test en the HEPA filter bank af ter any f
I i
saintenance or testing that could affect the air distribution within
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the sy st em.
We test shall be perfor:ed at design flow rate (110%).
33 The results of the test shall show the air distribution is unifem within 120%.*
i
- This note applies here and also to 4.4.c.3.
52 t
In WPS letter of August 25, 1976 to Mr. Al Schwencer (NRC) from Mr. E. W. James, we relayed test results for flow distribution for tests performed in accordance with ANSI N510-1975.
This standard i
refers to flow distribution tests performed upstream of filter e
assemblies.
$1nce the test resulta upstream of filters were in-conclusive due to high degree of turbulence, tests for flow distribu-r I
tion were perfor-ed domstream of filter assemblies with acceptable results (within 20%).
The safety evaluation, attached to Amendment 12 references our letter of August 25, 1976 and acknowledges acceptance i
of the test results.
I l
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TS 4.12-2 Proposed Amendment No. 52 5 *'
I 11/10/82
ATTACHMENT 2 TO LETTER FROM C. W. GIESLER TO S. A. VARGA FSAR TABLE 5.2-2 & INFORMATION TO BE INCLUDED UPOR FSAR UPDATE
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N j
ff Mr. S. A. Varga November 10, 1982 The information from Proposed Amendment 23c Table TS 4.4-1 will be included in Table 5.2-2 of the FSAR. Proposed Amendment No. 23, issued on September 5, 1975, and revised on January 4. 1977, and August 17, 1981, was withdrawn on August 23, 1982; however, the information from Proposed
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Table TS 4.4-1 will not be lost as it will be included with the annual FSAR update.
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~ Proposed Amendment 23c, August'17, 1931 Withdrawn on August 23, 1982 Proposed Table TS 4.4-1 (Page 1 of 5)
Penetration Designation and Test Method for Leakage Tests Type of Penetratiun Penetration Test Test No.
Penetration Category Required Method 1
Pressurizer Relief P-ABSVZ C
Pneumatic Tank Sample to Gas Analyzer 2
Pressurizer Relief Exterior C
Pneumatic Tank Nitrogen Supply 3
Instrumentation Exterior B
Pneumatic Sensors Exterior B
Pneumatic Isolation Valves Exterior C
' Pneumatic 4
Primary System P-ABSVZ C
Pneumatic Vent Heater 5
Reactor Coolant Drain P-ABSVZ C
Pneumatic Tank Pump Discharge 6E & 6W Main Steam Expansion Annulus B
Pneumatic Bellows 7E & 7W Feedwater Expansion Annulus B
Pneumatic Bellows 8S & 8N Steam Generator Annulus B
Pneumatic Blowdown Expansion L
Bellows 9
Pneumatic Expansion Bellows 10 RHR Loop Inlet Annulus B
Pneumatic Expansion Bellows 11 Letdown Line Isolation P-ABSVZ C
Pneumatic Valve Expansion Bellows Annulus B
Pneumatic 12 Charging Line SCOPA C
Pneumatic
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Propossd Amsndm:nt 23c, August 17, 1981 Withdrawn on August 23, 1982 Propos:d Table TS 4.4-1 (Page 2 of 5)
Type of Penetration Penetration Test Test No.
Penetration category Required Method 13N & 13E RC Pump Seal P-ABSVE C
Pneumatic Water Supply 14 RC Pump Seal P-ABSVR C
Pneumatic Water Return 15-SS Pressurizer Steam P-ABSVE C
Pneumatic Sample 15-LS Pressurizer Liquid P-ABSV3 C
Pneumatic Sample 15-HLS toop B llot Leg P ABSVB C
Pn'eumatic Sample 18 Fuel Transfer Tube Expansion Bellows Annulue B
Pneumatic "O" Ring Seal Exterior B
Pneumatic 19 Service Air Exterior C
Pneumatic 20 Instrument Air Exterior C
Pneumatic 21 Reactor Coolant P-ABSVE C
Pneumatic Drain Tank Cas Analyzer 22 Containment Air P-ABSVR C
Pneumatic Sample In l
23 Contaiment Air P-ABSVR C
Pneumatic Sample out 24 Service Water Exterior C
Pneumatsc Non Safeguard 25N Containment Purge P-ABSVM C
Pneumatic Exhaust Duct 255 Containment Vent P-ABSV3 C
Pneumatic and Purge Supply Duct 26 Containment Sump "A" P-ABSVE C
Pneumatic Discharge 27N-XI in.it rumenta tion Transmitter P-ABSVB B
Pneumatic Isolation Valves P-ABSVE C
Pneumatic
f Proposed Amend:ent 23c, August 17, 1981 Withdrawn on August 23, 1982 Proposed Table TS 4.4-1 (Page 3 of 5)
Type of Penetration Penetration Test Test No.
Penetration Category Required Method 27N-X2 a
27N-SW Instrumentation 27NE-XI Transmitters Exterior B
Pneumatic 27NE-X2 Isolation Valves Exterior C
E'eumatic 27NE-X3 27EN Test Line Plug P-ABSVZ B
Pneumatic 27EN-X Instrumentation Transmitter Exterior B
Pneumatic
-Isolation Valves Exterior C
Pneuwstic 31 Nitrogen to Exterior C
Pneumatic Accumulator 36N-X2 Instrumentation Transmitter Exterior B
Pneumatic Isolation Valves Exterior C
Pneumatic 36S Hydrogen P-ABSVZ C
Pneumatic 36N Control 36SE System 36NW r
41E Containment Vacuum Breaker t
Valve Annulus C
Pneumatic (4)
"0" Ring Seal Annulus B
Pneumatic (4)
L 41S/S Containment Vacuum Breaker Valve Annulus C
Pneumatic (4)
"O" Ring Seal Annulus B
Pneumatic (4) 42N Containment Vessel Annulus B
Pneumatic Test Pressurization Flange 45 Reactor Makeup P-ABSVZ C
Pneumatic Water to PRT
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Propossd'Amandment23c,Augus$?l7.1981 Withdrawn on August 23, 1982 Proposed Table TS 4.4-1 (Page 4 of 5)
Type of Penetration Penetration Test Test No.
Penetration Ca t eco rv Repuired Method A
Electrical Penetration Annulus B
Pneumatic Manifold "A" B
Electrical Penetration Annulus B
Pneumatic lknifold "B" C
Electrical Pet.etration Annult.s B
Pneumatic Manifold "C" D
Elect'rical Penetration Annulus B
Pneumatic Mar.ifold "D" E
Electrical Penetratica Annulus B
Pneumatic Manifold "E" F
Electrical Penetration Annulus B
Pneumatic Manifold "P" Equipment Door Annulus B
Pneumatic Personnel Airlock Annulus B
Pneumatic Personnel Airlock Annulus B
Pneumatic Inner Door Personnel Airlock Annulus B
Pneustaic Outer Door Emergency Airlock Annulus B
Pneumatic Emergency Personnel Annulus B
Pneumatic Airlock Inner Door EmergencyPerso$nel Annulus B
Pneumatic Airlock Outer Door All Personnel Airlock Annulus B
Pneumatic Electrical Penetration-AL2 Personnel Airlock Annulus B
Pneumatic Electrical Penetration Personne) Airlock Annulus B
Pneumatic Emergency Air Opening Seal
F Proposed Amendment 23c, August 17, 1981
'41thdrawn on August 23, 1982 Proposed Table TS 4.4-1 (Page 5 of 5)
Note _2 Penetration Category P-ABSVE Piping penetration to syst' ems located within the auxiliary building special ventilation Wone.
E-ABSVE Electrical penetration to wivnin the auxiliary building special ventilation zone.
Exterior - Penetrations which are exces'ior to the shield building oc th auxiliary building special ventilation zone.
Annulus Penetration to within the shield building annulus.
SGOPA Safeguard system operating post LOCA and is designed for pressures in excess of peak containment pressure for DBA.
Note 3 Blind Flange Penetration
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Note 4 Test pressure is applied in the opposite direction to the pressure which would exist when the valve is required to perform its safety function.
_ Note 5 Test required is specified in Specification 4.4.c for all penetrations identified by I in the Type of Test Required column.
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WISCONSIN P U 3 LI C S ERVICE CORPORATION gy P.O. Box 1200, Green Bay, Wisconsin 5J305 November 10, 1982 Division of Operating Reactors U.S. Nuclear Regulatory Commission Washington D.C.
20555 Attention:
Mr. S. A. Varga, Chief Operating Reactors Branch #1 Gar,tlemen:
Docket 50-305 Operating License DPR-43 Proposed Technical Specification Amendment NJ. 52 Appendix J to 10CFR50 Containment Leakage Testing
References:
- 1) Letter from Darrell G. Eisenhut to Carl W. Giesler dated September 30, 1982
- 2) IAtter from Carl W. Giesler to Mr. S. A. Varga dated August 23, 1982 j
- 3) Letter from E. R. Mathews to Mr. A. Schwencer dated May 1,1981 a
Enclosed please find forty (40) copies of Proposed Amendment No. 52 to the Kewaunee Nuclear Power Plant Technical Specifications. This Proposed Amendment deals with Section 4.4, Containment Tests, es required by 10CyR50 Appendix J, Primary Reactor Containment Leakage Testing For Water-cooled Power Reactors.
This proposed amendment revises and supercedes pages TS 4.4-3 TS 4.4-8 and TS 4.4-9 previsouly submitted with Proposed Aatndment No. 25C transmitted May 1, 1981 (Reference 3).
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We have received the Safety Evaluation Report (SER) prepared by the NRC staff based on the' Technical Evaluation Report prepared by the Franklin Research Center as a consultant to NRR.
The SER addresses requests for exemptions to certain requirements of Appendix J in response to Proposed Amendment No. 23 dated September 5,1975, as supple-mented on January 4,1977 and August 17, 1981. Wisconsin Public Service Corporation requested the Commission to disregard Proposed Amendment No. 23 (Reference 2) and committed to subsitting a new amendment request concerning Appendix J by November 1,1982.
Following is a discussion of how WPSC intends to incorporate the conclusions of the Safety Evaluation Report into the Technical Specifications while maintaining consistency with 10CFR50, Appendix J.
The discussion is organized such that each conclusion from the SER is followed by WPSC's intended compliance.
SER Conclusion 1: The proposal to continue hydraulic testing in lieu of pneuma-tic testing of certain isolation valves is acceptable only where the liquid leakage measurements are used to demonstrate a water seal at the valves throughout the post-accident period.
WPSC Responset Hydraulic testing will be done in lieu of pneumatic testing for isolation valves in the RHR system, safety injection system and the containment spray system as discussed under SER Conclusions 3, 4, and 5.
l SER Conclusion 21 The Technical Specifications should be revised to conform to 4
F ths "no greater than two year" requirenent of Appendix J vith respect to Type B and Type C testing.
WPSC Response:
Page TS 4.4-3, Specification 4.4.b.2 is explicit in that the period between Type B and C leak tests tha11 not exceed two years.
SER Conclusion 3: The combination of the design features of the RHR system and the proposed periodic hydrostatic testing is sufficient to ensure that the isolation valves of penetration Nos. 9, 10, and 48 are not relied upon to prevent the escape of contain-ment air to the atmosphere where the hydraulic test is used to demonstrate syst,em leak-tightness. In this case, substi-i tution of a hydrostatic test for the required pneuzatic test is an acceptable exemption from the requirements of Appendix J.
In the case of penetration Nos. 30E and 30W, no exemption is required since the liquid level of Containment Sump B provides a continous water seal at these penetrations throughout the post-accident period.
WPSC Response Hydrostatic testing of the RHR system will be performed as
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stated on page TS 4.4-5 Specification 4.4.b.7.
We acknowledge that Appendix J does not require Type C leak testing of i
penetrations 30E and 30W. Therefore, they are not included in the surveillance requirements of TS Section 4.4.
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SER Conclusion 41 The combination of the design features of the safety injec-wn
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tion and RER systems and the proposed periodic hydrostatic testing is sufficient to ensure that the isolation valves of penetration Nos. 28N, 28E, and 35 are not relied upon to pre-vent the escape of containment air to atmosphere where the hydrostatic test is used to demonstrate system leak-tightness. In this case, substitution of a hydrostatic test for the required pneumatic test is an acceptable exemption from the requirements of Appendix J.
WPSC Rasponset Hydrostatic testing of the safety injection system will be performed as stated on page TS 4.4-4, Specification 4.4.b.5.
SER Conclusion 5: The combination of the design features of the containment spray system and the proposed hydrostatic testing is suf-ficient to ensure that the isolation valves for penetration 4
Nos. 29N and 29E are not relied upon to prevent the escape of containment air to the atmosphere. Substitution of the hydrostatic test for the required pneumatfc test is an accep-table exemption from the requirements of Appendix J.
WPSC Response Hydrostatic testing of the containment spray syeten will be performed per Technical Specification 4.4.b.6, page TS 4.4-4.
i SER Conclusions The proposed operational inspection of the charging portion
.I of the CVCS system is not an acceptable substitute for the pneumatic leakage test of the isolation valves of penetration No. 12 required by Apoendix J.
T.3ese valves should be Type C
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tested in accordance with Appendix J.
Test connections are installed for this purpose.
WPSC Response:
The isolation valves associated with penetration No.12 are penumatically Type C leak tested in accordance with Appendix J as delineated in the updated FSAR.
SER Conclusion 7: Type C testing of component cooling system isolation valves (penetration Nos. 32N, 32E, 33N, 33E, 39, and 40) is not i
required. No exemption is necessary because Appendix J does not require them to be tested.
WPSC Response The isolation valvgs for the component cooling system are presently hydrostatically Type C leak tested. We acknowledge t
that Appendix J does not require Type C leak testing of the component cooling isolation valves. Therefore, they are not i
included in the surveillance requirements of TS Section 4.4 i
SER Conclusion 8: Type C testing of service water isolation valves to the fan coil units (penetration Nos. 37NW, 37NE, 37ES, 37EN, 38NW, 38NE, 38ES, and 38EN) is not required. No exemption is f
necessary because Appendix J does not require them to be i
j tested.
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WPSC Response The isolation valves for the service water system are pre-sently hydrostatically Type C leak tested. We acknowledge that Appendix J does not require Type C leak testing of the l
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5 service water isolation valves. Therefore, they are not included in the survet11ance requirements of TS Section 4.4.
SER Conclusion 9: Testing of vacuum breaker 0-ring seals in the direction oppo-site that in which the saf ety function is performed is accep-table and no exemption is required because the test results will be equivalent to or more conservative than testing in the direction of accident pressure.
WPSC Response The vacuum breaker 0-ring seals are currently tested as described above. (KNPP Technical Specification 4.4.e page TS 4.4-8.)
SER Conclusion 10: The proposal to perYorm Type C tests prior to the Type A cast is an acceptable exemption provided a conservative measure of pre-and post-repair differential leakage is added to the Type A results and other similar conservative procedures are followed.
WPSC Responses No exemption is required and the pre-and post-repair dif-ferential leakage need not be added to the Type A test.
Appendix J to 10CyR30 treats Type A testing and Type B & C testing as two independent events performed oa independent schedules. Noraally three sets of type B & C tests vill l
be performed during the interval between Type A tests. There is no technical justification to add the leakage determined 1
by one Type B & C test to the Type A test results, while i
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ignoring the other two Type 3 & C test results.
WPSC understands that it is cos=on practice in the nuclear industry to report the results of Type A and Type B & C tests independently. If the NRC intends to have Type A tests per-formed prior to Type B & C tests when the two tests fall l
coincident upon an outaae then the rule should state this.
l Type B & C tests perfor u on leak paths isolated during Type A tests will be included with the Type A results as if two (2)
Type A tests had been conducted. That is, one of the Type A test results will include the pre-repair leakage and the other will include the post-repair leakage.
SER Conclusion 11: Section 4.4.b.1.C of Technical Specification 4.4 is not suf-l ficient to ensure that all the requirements of the revised i
j Section III.D.2 of Appendix J are achieved. The airlock l
testing program should be revised to conform to the require-ments of Appendix J.
i WPS Responset The personnel air lock testing program has been revised to i
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conform to Appendix J.
The new specifiestion is on page TS 4.4-3, Specification 4.4.b.4.
l SER Conclusion 12: Subject to the technical evaluations of Section 3.1 of the attached TER, revised Technical Specification Sections 4.4.a and 4.4.b and Table TS 4.4-1 are acceptable.
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, WPS Responses As noted in Reference 2 we have requested the Commission to disregard Proposed Amendment No. 23 upon which the Safety Evaluation Report was based. In preparing the new amendment we have chosen not to include oroposed Table TS 4.4-1 which was submitted with Proposed Amendment No. 23. We will revise FSAR Table 5.2-2, Attachment 2, to include the infor-c :' a from proposed Table TS 4.4-1.
Maintaining Table TS 4.4-1 would require a Technical Specification Amendment I
each time a new penetration is added. By maintaining
)
this information in the Updated FSAR the t2ble will be revised annually with the FSAR update and the cost of Technical Specifica' tion Amendments will be avoided.
Revisions Not Adressed in the SER Page TS 4.4-1. Specification 4.4.a.3 The minimum ILRT duration has been changed from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, ANSI /ANS-568-1981, containment system leakage testing requirements, pro-o vides technical justification for this change.
Page TS 4.12-2 The note that is referenced on page TS 4.4-7 and located on page TS 4.12-2 was revised to maintain consistency.
The enclosed proposed Technical Specification Amendment No. 52 addresses the same technical issue as previously schmitted Proposed Amendment No. 23 dated
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.7 h Proposed Amendment No. 23 was submitted prior to the Marc S:ptember 5, 1975.
lity License enactment of 10CFR170.22, "Schedule of Fees for Faci 23, 1978 issue, it Amendments," and since Proposed Amendment No. 52 addresses the sam f Technical Specification is exempt from the fee associated with the processing o changes.
Very truly yours, (h
W C. W. Giesler Vice President - Nuclear Power sav Enc.
Mr. Robert Nelson, US NRC cc Subscribed and Sworn to
)his /d//
_ Day Before Me)/mu L, )
1982 of v/
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Notary Public, S' tate of Wisconsin 1
My Commission Expires:
March 24, 1985 I
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