ML20206G053
| ML20206G053 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 11/16/1988 |
| From: | Varga S Office of Nuclear Reactor Regulation |
| To: | POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| Shared Package | |
| ML20206G058 | List: |
| References | |
| NUDOCS 8811220021 | |
| Download: ML20206G053 (5) | |
Text
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i 759 UNITED STATES NUCLEAR REGillATORY COMMISSION in Matter of
)i POWER AUTHORITY OF THE
)
Docket No. 50-333 STATE OF NEW YORK
)
1 (James A. FitzPatrick
)
Nuclear Power Plant)
)
EXEMPTION I.
The Power Authority of the State of New York (the licensee) is the holder of Facility Operating License No. OPR-59, which authorizes operation of the James A, FitzPatrick Nuclear Power Plant (the facility). The license 4
provides, among other things, that the facility is sub,iect to all rules, regulations and Orders of the Fuclear Regulatory Comission (the Comissioni now or hereafter in effect.
The facility is a boiling water reactor located at the licensee's site in Oswego County, New York.
II.
I Section III.D.(a) of Appendix J to 10 CFR Part 50 requires that a Type A Drimary Containment Integrated leak Rate Test (PCILRT) be performed at approximately equal intervals durina each 10-year service period. Section 4
!!!.A.6(a) of f.npendix J to 10 CFR Part 50 requires that if any periodic Type A test fails to meet the apolicable acceptance criteria, a review of the test schedule be performed and approved by the Comission. Section !!I.A.6(b) of Appendix J requires that if two consecutive periodic Type A tests fail to meet the applicable acceptance criteria, a Type A test shall he perfomed at each
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subsequent refueling outage or approximately every 18 months, whichever comes first, until two consecutive Type A tests meet the acceptance criteria giren in Section III.A.5(b).
Section iV. A of Appendix J to 10 CFR Part 50 requires that a Type A, B or C leak test, as applicable, must be perfomed following any major modification or replacement of a component which is part of the primary containment boundary.
The licensee has determined that the Type A tests perfomed during the last three refueling outages (1982,1985, and 1987) for the "as found" condition, failed to meet the acceptance criteria as a result of excessive leakage observed from the pathways of the Type B and C Local Leak Rate Tests (LLRT). The study showed that, historically, certain containment isolation valves (CIVs) have repeatedly failed their LLRT. As a result, the licensee concluded that the most effective approach to eliminate the excessive leakage was to develop a Corrective Action Plan (CAP) using the guidance given in the NRC Infomation Notice 85-71, dated August 22, 1985, in lieu of the increased test frequency required by Section III. A.6(b) of Appendix J to 10 CFR Part
- 50. Tht:refore, an exemption from this requirement is required.
The CAP developed by the licensee recomended replacement of 33 CIVs, 21 during the current outage and I? during the 1990 outage. The valves are being replaced with valves that have better leakage characteristics, are easier to maintain, are expected to eliminate the previous failures and correct the bulk of the problem, and will be tested per the LLRT program when replaced. The 12 valves scheduled to be replaced during the 1990 outage have acceptable leakage rates based on the tests performed during the present refueling outage. The r
CAP has shown that they are likely to perfom their intet.ded function.
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'r As part of the CAP, the licensee has purchased a main steem isolation valve seat maintenance tool from the valve manufacturer, plant mechanics have received trainina in conducting leak repairs from the valve vendors, and an apprenticeship program certified by INPO has been implemented.
Also, as prt of the CAP, a manual valve in the High Pressure Coolant Injection (HPCI) System turbine exhaust to the suppression chamber was replaced. Because of the piping configuration and since a LLRT boundary cannot be created, the weld attachino the inboard side of the valve to the containment penetration cannot be pressure tested as required by Section IV.A of Appendix J to 10 CFR Part 50. Therefore, an exemption from this regulation is required.
The licensee has submitted an alternate testing program consisting of 100 percent radiography and dye penetrant or magnetic particle tests to ensure the leak tightness of the welds and the structural integrity and leak tightness of the piping.
Our Safety Evalua; ion supporting these Exemptions is dated November 16, 1088 III.
In this case, the licensee's CAP to eliminate the root cause of the successive Type A PCILRT test failures, and the improved valve maintenance program, will provide the equivalent level of protection as that provided by the Type A test. Therefore, the Comission staff finds that there are special circumstances in this case which satisfy the standards of 10 CFR Part 50.12(a)(2)(ii).
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s 1 Also, in this case, the licensee's non-destructive examination s '" welds for the HPCI turbine exhaust isolation valve will provide the equivalent level of protection as that provided by the Type R or C LLRT. Therefore, the Commission's staff finds that there are special circumstances in this case which satisfy the standards of 10 CFR part 50.12(a)(2)(ii).
IV.
As discussed above, the underlying purpose of the requirements of Section III.A.6(b) of Appendix J to 10 CFR Part 50 is to ensure the integrity of the primary containment and its penetrations. The underlying purpose is achieved and served by the replacement and testing program developed by tb2 licensee.
Also, the underlying purpose of the requirements of Section IV.A of Appendix.1 to 10 CFR Part 50 is to ensure that the primary containment integrity is not compromised when replacing components which form part of the boundary.
In the case of the HPCI exhaust valve, this is achieved and served by the non-destructive tests which were performed.
V.
Accordingly, the Commmission has determined that pursuant to 10 CFP Part 50.1?(a), the exemptions, as described in Section III, are authorized by law and will not present an undue risk to the public health and safety and are consistent with conmon defense and security, and special circumstances are present for the exemptions, in that application of the regulation in these
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9 i particular circumstances is not necessary to achieve the underlying purposes of Section III.A.6(b) and Section IV. A of Appendix J to 10 CFR Part 50.
Therefore, the Commission hereby grants the exemption from Section III.A.6(b) and Section IV.A to allow satisfactory implementation of the FitzPatrick Corrective Action Plan associated with containment isolation valves to fulfill the requirement of increased Type A tests and the satisfactory results from the non. destructive tests conducted on the welds for the HPCI turbine exhaust valve to fulfill the requirements of a Type B or C Test.
t Pursuant to 10 CFR Part 5: 32, the Commission has determined that the grantir9 of this Exemption will have no significant impact on the environment (53 FR 46135 ).
This Exemption is effective upon issuance and is applicable for the operating cycle following startup from the 1988 refuel outage.
Dated at Rockville, Maryland, this 16 D day of November 1988.
t FOR THE NUCLEAR REGULATORY COMMISSION i
1 Steven A. Varga, Director Division of Reactor Profects, I/II
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Office of Nuclear Reactor Regulat
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DATE :11/1/88 ti : 11/ 7 /88
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