ML20206C248
| ML20206C248 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 11/09/1988 |
| From: | POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | |
| Shared Package | |
| ML20206C035 | List: |
| References | |
| NUDOCS 8811160178 | |
| Download: ML20206C248 (9) | |
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ATTACHMENT I TO JPN-88060 PROPOSED 1TCHNICAL SPECIFICAT10N CHANGFJ REGARDING CONTAINMENT LAAK RATE TL9 TING UPM48412) l
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N:w M Pme Aetherity JAhlES A. FITZPATRICK NUCLEAR POWER FIANT Dodet No.50 333 DPR.59 831116017a estgo9 fDR ADOCH C5000333 PDC
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JAFNPP ,
l 4.7 (cont'd)
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Type A test shaR be performed at each plant .
shutdown for refuehng or approximately every 18 rnonths, whdever occurs first, until two ..
consecutive Type A tests meet the acceptance cniana. - I
- b. Typ6 7 tests (l.ocal leek rase toshng of containment pereabons)
(1.) All preoperabonsi and penodic Type B tests shall be performed by local pneumahc pressunzabon of the containment penetrabons, adher individually or in groups, at a pressure not less than Pa, rnd the gas '
flow to mainten Pa shen be measured.
(2.) Acceptanceentena The combmed leakage rate of all penetrations and valves subject to Type B and C tests shall be less than 0.00 La, with the eucephon of the valves seeied with fluid from a seal system.
- In accordance with an exemphon from 10 CFR 50 Appendix J, a Type A test need not be performed dunng the 1988 refueling outage.
Amendment No.
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O ATTACHMENT II TO JPN-M-060 SAFETY LTAI.UAT10N FOR PROPOSED
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TTCHNiCAL $PECIFICAttoM CHANGES ILEGARDING ~
CONTAINMENT ll.AK RATE TENTING l
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t Nm York Power Astleerity J AMES A. TTTZPATRICK NUCLFAR POWER PLANT Docket No. ,%333 DPR 59 I
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Attachment 11 to JPN 8tW60 SAFJIY EVALUATM)N Page 1 of 5 i t
i I. DF.SCRIPDON OF THE PROPOSFD CHANCES ft The proposed changes to the James A. FdtPMrkk Techakai dpecifications resisc Specification 4.7.A.2.a(10) l on page 170 and Specification 4.7A.2.f on page 174. I Pase 170 !
An asterisk (') is laserted after S iccification 4,7A.2.a(10) and the following note is added to the bottom of I the page- L l In accoraance with an esempkm from 10 CFR $0 Appendit J a Type A !
test need not be performed during the 19M refueling cutage. !
Page 174 I t An asterisk (*)is inserted after ' replacement of a component' and the following note is mided to the bottom !
of the page:
In accordance with an esemp!w from 10 CFR 50 Appendit J, a Type (
A, it, or C test is not required for the replacement of the llPCI turbine j i enhrust line bkxk vaht (23-}lPI 11) during the 19M refueling outage, j f
II. Pt1RPOSE OF TisE PROPOSED CH WGFS f
Fit:Patrkk has failed the last two II.RT tests in the 'as found' condition due to escessht Type C vaht l le kage and the Authority would hast been required to perform an aduitional't)pe A ted this outage. The j NRC addressed this sitv.uion in Refcicace 5, whkh prosided the following guidance. !
if Type B and C leakage rates constitute an identified contributor to this failure of the 'as ,
! found' condition for the C1LRT, the general purgese of maintaining a high degree of l containment lategrity might be better scrwd through an leprosed maintenance, and testing -
program for containment pcactration boundaries and isolatkm vahes. In this utuation, the licensee : y submit a Correcthe Action Plan as an esempion reqont for NRC staff resiew. The licensee may impkment the [ CAP l In lieu of the required lacrease in Type A test frequency.
Rcference 3 contains a request for an esempion from the rclest requirement of 10 C- 0 Appendis J, Section IIIAA(b). This cac spion wouki climinate the requirement for the Authority to perform a Type A primary containment lategrated kahage rate test (ILRT) during the 19M refueling outage. Reference 3 described a containment isolation vahr replacemcat pentram whkb the Authority is implementias in order to imprmt the kakage characteristics of the Farrattkk containment. This prqtrara is the key ekment of a proposed Correcthe Action Plan (CAP) whkh is the basis for the esempion request.
In Reference 3, the Authority informed the NRC thrt the llPC1 turbine tshaust linsa nanual bkxk vaht (25 11P111) would be replacc4 during the 194 refacting outage. The Authority subsequentis Ficatified the fxt that replacetnent of this vahr would create two new wckis la the prkwary containment pressure twndary whkh ceuLt not be kvalical rate tested. The Authority then amended its esempion request on July 14,19M (Reference 4), to allow installation of this nhe without basing to perform a T)pe A ILRT as otherwise required by 10 CFR $0 Argtndit J. Sution IVA.
At that time, the Authority did not reafire that a license amendment would aho be required in addition to the esempiens from Appendia J.
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- Attachment !! to JPN M4W l .
MAFEW EVALUATION l
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j The purpose of the proposed changes is to e'iminate the requirement for the Authority to perform a T)pe A i primary containment integrated kak rate test (ILRT) during the 19M refueling outage due to the prosision of i i Technical Specifwation 4.7A.2.1(10).
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j The proposed changes also allow the replacement of the HPCI turbine exhaust line manual block vahe,23- i 1 IIPi 11, without hasing to perform an ILRT as otherwise required by Technical Specificatkw 4.7.A.2.f. An l
! alternate inspectkm program, conshting of 100% radiography and surface czami. ation, ensures the str* al i
< integrity and leak tightness of the wclds, 1
l %c proposed ch agea to the Techalcal Specificatkms ere required pekw to.tatt up from the curicat rcfueling
! outage, ne Aut x>rity plans to end the current refueling outage on Nmtmber 18,19M whkh is leu than 30 l i
! days from the date of this application, ne Authority request that this application for amendment be !
J proccued on an emergency bans under the prmisions of 10 CFR 50.91(a)(5) since insulti ime eshts to l I
pro ide for a 30 day public comment pcri d without prntnting the resumptkw of powtr og ,
L 1%lPACT OF THE PitOPOSEI) TH WGES The Authority is implementing an aggreuht program to improve the leak tight grforrr ance of the lhPatrick primary containment. Prcsious 'a.s founal' failures of the Type A ILRT have dencatrated that >
j the mou significant source of containment leakage is through isolttkm vabes For this reason,in e Authority i h replacing 33 containment isolation vahrs which have cshibited a hhtor, of execuht leakage. This vaha replacement program is the key clement of a CAP that the Authority has propmed in lieu of performing an ,
i ILRT this outage, (Refe.coces 3 and 5) The rerlacement of one wht (23.IIPt 11) as part of this CAP, j j
requires an ILRT to ten the welds shkh attache the uht to the containment penet.'ation. ;
! E 4 la Reference 4, the Authority pro ided technical justincation for not grforming r.n ILRT merely to test these j !
welds, ne justificathm for that caemption from 10 CFR 50 Appendit J is aho applicable to the propmed i q change to the Technical Specifs ations as follows 1
i The constructkw cale applied in the replacement of the vahe, AN51 B 31.11%7 with Addenda A, prescribei.
l the testing requirements for the lastallation of the new vahe. Specifically, Table 136.11 prescribes the t
) Mandatory Minimum Nondestructhe Teus for Wckh. For the wwds in qusstion, the code does not r* quire l radiography, liquid pcactrant, not magnetic particle testing. Sec km 137.1 does, howtwr, r: quire that leak tightneu be demonstrateJ. This sectim erates:
It shall tw mandatory that the design, fabricatkm, and crection of power piping, constru icd under this Code demonstrate leak tightacu. This requirement shall be met by a hydrostatic leak test prioe to initial operatkm. Men a hydrweatic 6est k not practicabar, an laitial scrsice leak test, a vacuus.: ten, or les per not red 6 graphy of all weld: A jalett in an all i
welded system usay be nh.46teted. [rmphasis eJJed) 1 The Autlwity performed im radiography of the final utkh in iicu of the hydro-ted as stated atwe. la addition to the requirements of the code, surface esaminations (dye penetrant or magnec partkle tcM) were also perforreed on the final wtlJs, His auures that no surface flaw cshts which coukt lead to a katage path.
These non-destructhe examia aws mect the latent of the esisting Tcchnical Specifwatim 4.7 A.2.f which h to auure that malitications to the containment preuvre boundary are leak tight, i The Authority performed a compechensht rniew of alternate methods of performing a localleak rate test uhich is prmided la Attachment I to Reference 4. In that report,it was concluded that no salid method was found io be pcacticable and is, theetfore, not discussed la this safety esatuation. ;
Atiachment 11 to JPN-88-060 SAFETY EVALUATION 1 Page 3 of 5 l
!!. EVALUATION OF EMERGENCY SITUATION As stated in Section 11 above, the Authority requests that this application for amendment be processed on an emergency basis under the prosisions of 10 CFR 50.91(a)(5), since insufficient time exists to allow for a 30 day public comment period without preventing the resumption of power operation.
10 CFR 50.91(a)(5) defines en emergency situation as:
' failure to act in a ti nely way would result in derating or shutdow a, or in prevention of either resumptica of operation or of increase in power output up to the plant's licensed power level.' \emphasLr added}
The proposed Technical Specification change is required to allow FitzPatrick to resume power operation following the current refueling outage. If the amendment is not issued on an emergency basis, operation of FitzPatrici. would be delayed until such tirae that it is issued. If the Authority was required to perform an ILRT prior to startup, this would effectively delay startup even further. Substantial lead time is required to rent the necessary equipment, contract for consultant personnel, and send instrumentation to an outside laboratory for calibration. In addition, the Authority has spent significant resources in lieu of performing an ILRT this outage, as evident by the containment isolation nlve replacement program described in licensing correspondence.
10 CFR 50.91(a)(5) requires the Authority to address (be following concern before the NRC can make a determination that an emergency condition exists:
- Whenew.r an emergency situation exists, a licensee requesting an amendment must explain why this emergency situadon occurred and why it could not avoid this situation
- The CAP invohes the replacement of 33 containment iso;ation valves during twu refueling outages at a cost of (
over $3 million. This substantial program has required a great deal of coordination between various Authority ,
4 departments, the plant, and the NRC since its original submission to the NRC in April 1988. It was identified I by the Authority this past summer that 23-ilPI.11 would require an exemption from 10 CFR 50 Appendix J to allow its installation. This information was discussed with the NRC's project manager for FitzPatrick. The exemption was formally requested as Reference 4 and was available as a public record in the Public i D~;ument Room (PDR) in a timely manner. The Authority inadvertently failed to identify that a license amendment would be required in addition to the exemptions from the requirements of Appendix .f. The Authority first recognized the need for this license amendment on November 4,1988. The Authority did not s
delay submittal of this application in order to let the emergency situation develop and obtain NRC approval on an emergency basis.
l Reference 3 was transmitted to the NRC over seven months prior to the anticipated startup date and Reference 4 was transmitted over foui months prior to the anticipated startup date. The proposed Technical 4
Specification changes are sittually ideotical to the exemptions discussed in References 3 and 4. The late date of this application for amendment does not impact the technical review of the material, but merely makes the 30 day public comment period impractical. Since the subject matter of the proposed change has been available to the public .ia correspondence contained in the PDR, an inadvertent failure to submit this application in time to 4.llow a 30 day public comment period should not be a basis to delay approval of this application, thereby preventing plant startup.
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Attachment 11 to JPN-88-060 SAFETY EVALUATION Page 4 of 5 111. EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION Operation of the FitzPatrick Plant in accordance with the proposed Amendment would not invoht a si,;nificant hazards consideration as stated in 10 CFR 50.92 since it would not:
- 1. invohn a significant increase in the probability or consequences of an accident presiously evaluated.
The containment leakage rates assumed in the FSAR require that containment isolation valves (CIV) exhibit superior leak rate characteristics. Because of degradation of vahrs over time, the leakage rates could not be maintained over the length of an operating cycle. This has ici to 'as found' failures of the Type A ILRT which then requires increased ILRT test frequency. The Authority considers that replacing CIVs better serves the purpose of maintaining a leak tight containment than does an increased Type A ILRT test frequency.
The replacement of the IIPCI exhaust inboard manual block vahr (23-11PI 11) is intended to improve the testing of the two CIVs on this line. Leakage past this vahr during tiie conduct of localleak rate tests is attributed to the CIV under test and is therefore unnecessarily included in the ostfall containment leakage tof al.
The valve body forms part of the containment pressure boundary under accident conditions. All of the post accident piessure boundary components except the inboard welds are leak tested as part of the localleakage rate tests of the penetration. The proposed change allows installation of the vahr without performing a leakage test on the inboard welds connecting the valve to the containment penetration.
Alternate testing, including 100% radiography of the welds as:ures the structural integrity of the wolds and surface examination will detect any surface flaws which could lead to leakage paths. Since the vahc is normally open, remains open under accident conditiens, and the structural integrity of the containment pressure boundary through the valve is assured, no change is made to the probability of occurrence or consequences of any accident previously evaluated.
- 2. create the possibility of a new or different kind of accident from any accident presiously evaluated. Not performing an ILRT this outage cannot initiate any type of accident.
23 IIPI 11 has no active safety function and remains open during all normal plant operational and transient or accident conditiora, its only purpose is to isolate CIVt. on the line for routine localleak rate testing. The one for one replacement of this vahc can not introduce a new type of accident from any cecident previously evaluated.
- 3. imolve a significant reduction in a margin of safety. As stated above,23-HPl.11 has no operational or
, accident mitigation functions. Performance of 100% radiography in lieu of a pneumatic leak rate test on :he inboard welds is conservative. The construction code (ANSI B 31.1-1%7) allows for 100%
radiography as an alternaths to leakage testing when such testing is not practicable.
The NRC considers a Correcthc Action Plan (CAP) superior to performing additional Type A ILRT l tests. (Reference 5) The Authority is implementing its CAP to improve the long term leakage characteristic of the Fitrhtrick containment. This CAP is impicmented in lieu of performing an ILRT I this outage and results in no reduction of any margin of safety.
IV. IMPLEMENTATION OF Tile PROPOSED CilANGE implementation of the proposed changes will not irnpact the A1 ARA or Fire Protection Programs at FitiPatrick, nor will the changes impact the emironmr.nt, l
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Attachment 11 to JPN.88-060 SAFE'IY EVALUATION PageSof5 V. CONCLUSION The change, as proposed, does not constitute an unreviewed safety question as defined in 10 CFR 50.59. That is, it:
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- a. will not change the probability nor the consequences of an accident or malfunction of equipment l important to safety as previously evaluated in the Safety Analysis Report;
- b. will not increase the possibility of an accident or malfunction of a different type from any presiously evaluated in the Safety Analysis Report; i
- c. will not reduce the ma: gin of safety as defined in the basis for any technical specification; .
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- d. does not constitute an unreviewed safety question; and
- e, invohes no significant hazards consideration, as defined ic 10 CFR 50.92. !
VI. REFERENCES
- 1. James A. Fitt itrick Nuc! car Powt Plant Updated Final Safety Analpis Report.
- 2. James A. FitzPatrick Nuclear Power Plant Safety Evaluation Report (SER), dated November 20,1972, and Supplements. !
- 3. NYPA letter, J. C. Brons to the NRC, dated April 8,1988 (JPN-88-012), regarding a Request for Exemp?: i from Containment integrated Leak Rate Test - Ret st Schedule.
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- 4. NYPA letter, J. C. Brons to the NRC, dated July 14,1988 (JPN-88-033), regarding a Request for Exemption from Containment Integrated Leak Rate Test Retest Schedule. ;
- 5. NRC IE Information Notice 85 71: Containment Integrated Leak Rate Tests, dated August 22,1985.
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