ML20206A159
| ML20206A159 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 04/03/1987 |
| From: | Corbin McNeil Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLR-N87055, NUDOCS 8704070434 | |
| Download: ML20206A159 (9) | |
Text
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4 Public Service Electric and Gas Company Cerbin A. McNeill, Jr.
Public Service Electric and Gas Cort pany P.O. Box 236, Hancocks Bndge, NJ 08038 609 339-4800 Vice President -
Nuclear April 3, 1987 NLR-N87055
-United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 REQUEST FOR 10 CFR 50, APPENDIX J EXEMPTION HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 In accordance with the provisions of 10 CFR 50.12a, we hereby request exemption from the requirements of 10 CFR 50, Appendix J, Section III.D.3.
EXEMPTION REQUEST The exemption will provide a one-time relief from the requirement to perform a local leak rate test within a two year interval for 27 containment isolation valves.
In order to meet the requirements of 10 CFR 50, Appendix J, Section III.D.3 and Technical Specification 4.6.1.2.d, it would be necessary to shutdown the plant prior to the first refueling outage for Hope Creek Generating Station, tentatively scheduled for February 1988.
A shutdown is necessitated because containment entry is required and testing of these valves at power would expose test personnel to substantial safety hazards and would involve significant radiation exposures.
In addition, testing of some of the valves at power would require draining of the "A" and "B" RHR loops as well as the "A"
core spray loop.
For specific description by valve, refer to Attachment 1.
For that portion of the list of valves in Attachment I which are classified as Pressure Isolation Valves (PIVs), the overdue date is referred to in terms of their 18 month testing interval.
Since Section 3.9.6, Inservice Testing of Pumps and Valves, of Supplement No. 5 of the Hope Creek Safety Evaluation Report (SER) has indicated that Type "C" (gas) testing of the PIVs (in lieu of water testing) will satisfy the Technical Specification 4.4.3.2.2.a testing requirement, this testing is also used to meet the containment isolation valve (Type "C")
testing requirements of g\\ }
/
Technical Specification 4.6.1.2.d for these valves.
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Document Control Desk 2
4/3/87 The extension of the surveillance intervals for the containment isolation valves in question is requested to allow the station to be shutdown for testing at a time consistent with system need for power rather than undergoing a forced shutdown at a time when the distribution system's need for power is high (June - July 1987).
An extension of the required testing to the first refueling outage will not be contrary to the basic intent of the 10 CFR 50, j.
Appendix J requirement, i.e. to leak test the valves after a nominal two years of operation.
Since the low power operating license was issued for Hope Creek was issued on April 11, 1986, j
none of the valves in question will have been exposed to an opera. ting environment for more than 24 months with an approved exemption.
We conclude therefore, that the increased probability of containment leakage is not significant and that no measurable i
impact would result from the proposed extension of time.
I Since the basic intent of the regulation is not violated, there
- )
is no undue risk to public health and safety involved with plant I
operation with the requested exemption in place.
Nothing is contained in the exemption requect that inconsistent with the a
j common defense and security.
Finally, the temporary exemption, as requested, has been reviewed and has been found to be authorized by law.
SPECIFIC JUSTIFYING CIRCUMSTANCES The special circumstances present which justify the Commission's i
consideration of this exemption request to conform to the following paragraphs of 10 CFR 50.12a:
i 1
50.12(a)(2)(ii) - Application of the Appendix J requirement in this situation for testing within two years would not serve the underlying purpose of the regulation, which is to assure testing after two years in an operating environment.
Since Hope Creek, in the most conservative interpretation, can only be considered to have provided an operating environment for the containment isolation valves in question since April 1986, the requested extension of time does not conflict with the intent of the rule and defers the testing requirement intended by 10 CFR 50, Appendix J to the first refueling outage.
50.12(a)(2)(iii) - A requirement for shutdown to comply with the l
two year testing requirement in Appendix J would impose a hardship and costs not contemplated by the rule when written since Appendix J clearly indicates an intent that required testing be performed during normal refueling outages except in unusual situations when the two year limit would apply.
To require a plant shutdown to comply with the two year limit for 1
J 1
Document Control Desk 3
4/3/87 testing even though the plant has not accumulated two full years of power operation would result in an unnecessary loss of power to the grid at a time when the distribution system's need for power is high as well as the extra costs attendant to having two successive outages.
50.12 (a)(2)(v) - The requested exemption is temporary and became necessary as a result of the delays in attaining full power operation common to initial startup activities.
If an unplanned outage of greater than 30 days is encountered prior to the first refueling outage at Hope Creek, PSE&G agrees to perform the testing which is the subject of this exemption request with the exception of Head Spray Valves BC-V020 and BC-V021 which require removal of the drywell head for testing.
Testing of these valves can only performed during a refueling outage.
TECHNICAL CONSIDERATIONS The following considerations have been taken into account in our evaluation of the safety and environmental impact attendant to the exemption request:
To assure the leak tightness of the containment isolation valves listed in Attachment 1, testing with the proposed temporary extension will have been performed prior to the accumulation of two years of exposure to power operation, using the most conservative interpretation of a power operation environment, i.e. the commencement of the low power testing program.
1 The requested exemption is for containment isolation valves which to date have exhibited favorable operating experience.
Since the initial testing of these valves, a limited number have required maintenance, repairs or adjustments that would mandate performance of additional Type C tests.
Additionally, these valves are normally maintained in either the open or closed position and are not used in a modulating mode to control flow rates.
The containment isolation valves listed on Attachment 1
+
were all tested successfully in late 1985.
The total of the measured Type C leakage rates for these valves is not a significant portion (4.9%) of the allowable leakage limit (0.6 La).
It is unrealistic to assume that valve leakage will increase significantly from June - September 1987 until the first Hope Creek refueling outage in early 1988, when the duration of the actual exposure to a power operation environment is considered.
~.__
Document Control Desk 4
4/3/87 CONCLUSION The granting of the requested exemption would provide a one-time extension, for specified containment isolation valves of the 10 CFR 50, Appendix J requirement to perform local leak rate testing within a two year interval.
With respect to this exemption from Appendix J, the increment of increased risk to public health and safety is related solely to the potential increased probability for the magnitude of containment leakage during an accident which could lead to potentially greater offsite radiological consequence.
The potential increase due to this exemption is not significant and will impart no measurable impact on the health and safety of the public since the valves will have been tested with less than two years of accumulated exposure to a power operation environment.
The successful testing of the valves listed in Attachment 1 in late 1985 provides assurance that the leakage from the valves will not significantly increase from the June - September 1987 time frame until the first Hope Creek refueling outage when the period of exposure to a power operation environment is considered.
Containment integrity will not be measurably affected and the risk of any facility accident will not be increased.
Therefore, post accident radiological releases will not exceed previously determined values.
The exemption has no impact on plant radiological or non-radiological effluents and involves no significant occupational exposure.
In accordance with the application fee requirements of 10CFR 170.21, a check in the amount of $150.00 is submitted with this request for exemption.
This submittal includes three (3) signed originals and forty (40) copies.
Sincerely, Attachments C
Mr. D. Wagner Licensing Project Manager Mr. R.
Borchardt Senior Resident Inspector Dr. Thomas E. Murley Regional Administrator NRC Region I l
EXEMPTION REQUEST 10CFR50, App. J.
STATE OF NEW JERSEY
)
)
SS.
COUNTY OF SALEM
)
Corbin A. McNeill, Jr.,
being duly sworn according to law deposes and says:
I am Vice President of Public Service Electric and Gas Company, and as such, I find the matters set forth in our letter dated April 3, 1987, concerning our request for exemption from the requirments of 10CFR50, Appendix J, III.D.3 for Facility Operating License NPF-57, are true to the best of my knowledge, information and belief.
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Subscribe and Sworn o before me thistf day of
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1987
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' Notary-Public of New Jersey DELORIS D.HADOOf A Nota PutscofNurW My Commission expires on "4E
ATTACHMENT 1 18-Month 24-Month 4.4.3.2.2.a 4.6.1.2.d TECH. SPEC.REF.
Overdue Overdue Valve No.
Date Date Table 3.6.1-1 1)
BC-V014 HV-F050B 6/23/87 Part C, Group 39-F 2)
BC-V013 HV-F015B 6/23/87 A,
3-E l
3)
BC-Vil8 HV-F122B 6/23/87 B,
26-F 4)
BC-V015 HV-F027B 8/12/87 A,
3-B 5)
BC-V113 HV-F017A 7/16/87 B,
26-A 6)
BC-Vll4 HV-F041A 7/16/87 C,
39-E 7)
BC-V119 HV-F146A 7/16/87 8)
BC-V110 HV-F015A 7/25/87 A,
3-E 9)
BC-Vlll HV-F050A 7/25/87 C,
39-F i
10)
BC-Vil7 HV-F122A 7/25/87 B,
26-F 11)
BC-Vll6 HV-F021A 6/11/87 B,
26-B 12)
BE-V003 HV-F005B 8/6/87 B,
25-A 13)
BE-V002 HV-F006B 8/6/87 A,
10-B j
14)
BE-V072 HV-F039B 8/6/87 B,
25-D 15)
BE-V007 HV-F005A 8/5/87 B,
25-A 16)
BE-V006 HV-F006A 8/5/87 A,
10-B 17)
BE-V071 HV-F039A 8/5/87 B,
25-D
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18)
BE-V001 HV-F006 8/5/87 B,
22-A 19)
KL-V026 HV-F5152B 8/7/87 A,
15-A 20)
BC-V021 HV-F023 9/3/87 A,
3-D 21)
BC-V020 HV-F022 9/3/87 A,
3-D 22)
FD-V001 HV-F002 9/6/87 A,
5-A 23)
FD-V051 HV-F100 9/6/87 A,
5-A j
24)
FD-V002 HV-F003 9/6/87 A,
5.
j 25)
FC-V001 HV-F007 9/18/87 A,
6-A
) ' 26)
FC-V048 HV-F076 9/18/87 A,
6-A i
27)
FC-V002 HV-F008 9/18/87 A,
6-A l
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ATTACHMENT 1 (Cont.)
SPECIFIC DESCRIPTIONS "B" Shutdown Cooling Return to'"B"'Recirc.. Loop, PEN 4A.
Valve BC-V014, Stop Check 12" (HV-F050B)
Valve BC-V013, Globe 12" (HV-F015B) i Valve BC-Vll8, Globe 2" (HV-F122B)
Original tests were performed on 8/8/85.
Maximum leakage was 18 i.
SCCM(1).
These valves would require-an extension of 34 weeks
- beyond.the 18-month (+25 percent) - P.I.V.
test interval.
2 l
Technical Specification Air Tests would require containment entry, RHR B Loop isolation and drainage.
j Torus Spray Supply, PEN 214A Valve BC-V015, Gate 6" (HV-F027B) i Original test date was 8/7/85 with leakage of 296 SCCM(1).
This.
valve would require an extension of 26 weeks
- beyond the 24-month Type "C" test interval.
This test would be performed with the j
test for Items 1 through 3, and would require isolation and drainage of the "B" RHR Loop.
i j
Valve BC-V113, Gate 12" (HV-F017A) j Valve BC-V114, Stop Check 12" (HV-F041A)
Valve BC-Vll7, Globe 2" (HV-F146A) l Original tests were performed on 7/9/85 and 7/29/85.
Maximum leakage was 305 SCCM(1).
These valves would require a 28-week
- extension beyond the 18 month (+25 percent)
P.I.V.
test i
interval.
Test specification Air Tests would require containment entry, isolation and drainage of the RHR "A" Loop.
"A" Shutdown Cooling Return to "A" Recirc Loop, PEN P4B Valve BC-V110, Globe 12" (HV-F015A)
Valve BC-Vlll, Stop Check 12" (HV-F050A)
Valve BC-Vll7, Globe 2" (HV-F122A)
Original tests were performed on 8/14/85 and 9/3/85.
Maximum leakage was 165 SCCM(1).
These valves would require a 27 week
- extension beyond the 18-month (+25 percent) P.I.V.
test 4
interval.
Technical Specification Air Tests would require i
containment entry, and isolation and drainage of the "A" RHR Loop.
I 1
i I
ATTACHMENT 1 (Cont.)
RHR "A" Loop Containment Spray Supply, PEN P24B Valve BC-Vll6, 16" Gate (HV-F021A)
Original test date was 6/7/85 with maximum leakage of 880 SCCM(1).
This valve would require a 34-week
- extension to the 24-month Type "C"
test interval.
Technical Specification Air Tests would require isclation and drainage of the "A" RHR Loop.
It is intended that this test be performed along with the testing of valves BC-V110, BC-Vlll and BC-Vll7.
"B" Core Spray Injection, PEN PSA Valve BE-V003, Gate 12" (HV-F005B)
Valve BE-V002, Stop Check 12" (HV-F006B)
Valve BE-V072, 2" Globe (HV-F0398)
Original test date was 9/10/85 with maximum leakage 920 SCCM(1).
These valves would require a 20-week
- extension to the 18-month
(+25 percent)
P.I.V.
test interval.
Technical Specification Air Tests would require containment entry, drainage and isolation or Core Spray Loop "B".
"A" Core Spray Injection, PEN PSB Valve BE-V007, Gate 12" (HV-F005A)
Valve BE-V006, Stop Check 12" (HV-F006A)
Valve BE-V071, Globe 2" (HV-F039A)
Valve BE-V001, Gate 14" (HV-F006)
Original test date was 9/17/85 with maximum leakage of 902.4 SCCM(1).
These valves would require a 20-week
- extension to the 18-month (+25 percent)
P.I.V.
test interval.
Technical Specification Air Tests would require containment entry, drainage and isolation of Core Spray Loop "A".
"B" Instrument Gas Header, PEN P28A Valve KL-V026, 2" Globe (HV-S1S2B)
Original test date was 8/2/85 with maximum leakage of 24 SCCM(1).
This valve would require a 25-week
- extension to the 24-month Type "C" test interval.
Technical Specification Air Tests would require containment entry and loop isolation.
Head Spray Valve BC-V021, 6" Gate (HV-F023)
Valve BC-V020, 6" Globe (HV-F022)
=
ATTACHMENT 1 (Cont.)
Original test date was 10/12/87 with maximum leakage of 27 SCCM(1).
These valves would require a 15-week
- extension to the 18-month (+25 percent)
P.I.V.
test interval.
Technical Specification Air Tests would require plant shutdown to remove the head spray piping spool above the seal plate so that a blind flange could be installed to permit testing.
The reactor well plugs and the drywell head would also have to be removed.
This test can only be performed during a refueling outage.
HPCI Steam Supply Valve FD-V001, 12" Gate (HV-F002)
Valve FD-V051, 2" Globe (HV-F100)
Valve FD-V002, 12" Globe (HV-F003)
Original tests were performed on 9/1/85 with maximum leakage of 192.1 SCCM(1).
These valves would require a 20-week
- extension to the Type "C" test interval.
Testing would require containment entry.
RCIC Steam Supply Valve FC-V001, 4" Gate (HV-F007)
Valve FC-V048, 2" Globe (HV-F076)
Valve FC-V002, 4" Gate (HV-F008)
Original tests were performed on 9/13/85 with maximum leakage of 8.6 SCCM(1).
These valves would require a 20-week
- extension to the Type "C" test interval.
Testing would require containment entry.
Reference (1)
Public Service Electric & Gas Company, Primary Reactor Containment Integrated Leakage Rate Test for the Hope Creek Generating Station (Final Report March 1986).
Based on a tentative date of February 1, 1988 for the commencement of the first Hope Creek refueling outage.
l