ML20206G063
| ML20206G063 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 11/16/1988 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20206G058 | List: |
| References | |
| NUDOCS 8811220024 | |
| Download: ML20206G063 (4) | |
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RE0 VEST FOR EXEMPTION FROM CONTAINMENT 1h1EGRATED LEAX RATE
_ TEST PETEST SCHEDULE JAMES A. FIT 7 PATRICK NUCLEAR POWER PLANT DOCKET NO. 50-333
1.0 INTRODUCTION
By [[letter::05000333/LER-1988-002, :on 880310,RCIC Made Inoperable for Approx 1 Minute Due to Automatic Closure of Steam Supply Valve While HPCI Inoperable.Caused by Failure to Follow Procedures.Rcic Restored to Svc|letter dated April 8,1988]], Power Authority of the State of New York, the licensee for James A. FitzPatrick Nuclear Power Plant, requested a one-time exemption so that the normal retest schedule of 10 CFR Part 50. Appendix J,Section III.D(a) can be resumed by) exempting the FitzPatrick plant from the requirements of Section III.A.6.(b.
Section III.A.6(b) requires that a Type A Primary Containment Integrated leak Rate Test (PCILRT) be conducted three times during each 10-year service period.
If two consecutive Type A tests fail to meet the applicable acceptance criteria, a retest must be performed during the subsequent refueling outages or approximately every 18 months, whichever comes first, until two consecutive tests meet the acceptance criteria given in Section III.A.F(b). Type A tests perfcrmed at the FitzPatrick plant in 1982, 1985, and 1937 in the "as-found" condition did not meet the acceptance criteria because of the excessive leakage incurred from the several isolation valves which were identified during the Type B and Type C Local 1.eak Rate Tests (LLRTs). The licensee reviewtd the root cause of the failure and determined that a relatively small number of valves were the cause of past Type A test fr.i l u res.
On the basis of this infomation, the licensee proposed a Corrective Acticn Plan (CAP) and requested a one-time exemption from the requirement to 9
perform a Type A test during the 1983 refueling outage.
The licensee will perform a Type A test during the next refueling outage scheduled in 1990 to i
confirm the adequacy of the CAP.
Additionally, in a letter dated July 14, 1988 the licensee requested an exemption from Section IV.A of Appendix J to 10 CFR Part 50 to allow instaliation of two residual heat removal (RHR) containment spray valves and one aigh-pressure coolant injection (HPCI) turbine exhaust isolation valve as
- a. part of the CAP without performing Type B or Type C LLRT or the hydrostatic test during the currant refueling outage.
The licensee stated that because of i
the piping configuration the welds attaching the inboard side of these valves to their respective containment penetrations cannot be pressure tested.
However, in lieu of the Type e or the Type C test, the licensee proposed an alternate testing program of 100 percent radiography of the welds and dye penetrant or magnetic particle tests for the inboard welds to ensure the leak tight integrity of the weld.
Subsequently, in a letter dated October 28, 1988, the exemption request for the two RHR containment spray values was withdrawn.
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, 2.0 EVALUATION I
Appendix J to 10 CFR Part 50 establishes two types of tests with separate acceptance criteria. The local leak rate tests (Types B and C) are performed durino each refueling outage while the primary containment integrated leak rate test (PCILPT) (Type A) is performed three times in each 10. year inservice inspection (ISI) interval (approximately every 3 to 4 yearsl.
The LlRTs provide periodic surveillance of components such as isolation valves and air lock seals. The PCILRT is a rneasurement of the overall integrated leakage rate of the containment.
It includes testing of passive and structural components and verifies the adequacy of the LLRT program.
Exceeding the allowable leakags rate during the PCILRT indicates that either a passive or structural component is leaking or that there may be an inadequacy in the LLRT program.
For passive or structural components, the only test that could determine that the leak exists would be the PCILRT.
In the case of the LLRT program, the PCILRT would serve as a means of verification of the LLRT program results.
The failures of the FitzPatrick 1982, 1985, and 1987 "as-found" PCILRTs were a result of excessive leakage observed from the pathways of the Types B and C tests.
The licensee's review of LLRT data from all refueling outages conducted from 1977 through 1987 revealed that FitzPatrick LLRT leakage consistently exceeded 0.6 La before repair. The review further indicated that the root cause of the problem was containment isolation valve (CIV) leakage. Certain CIVs historically had failed repeatedly during LLRTs. The liccnsee concluded that the most effective approach to eliminate the excessive leakage was through a CAP using the guidance given in the NRC Information Notice 85-71 dated August 22, 1985 The CAP recommended replacement of CIVs identified as being historically poor perfomers (excessive leakage). Thirtv-three CIVs are scheduled for replacement as part of the CAP. The licensee plans to replace 21 of the valves during the 199.8 refueling outage, and 12 during the 1990 refueling outage.
These valves will be replaced with valves that have better ? %qe characteris-tics and are easier to maintain.
The licensee believes this wiii we re t the leakage problem that has been observed during the past 10 years.
As a part of the CAP to replace the CIVs the licensee also has implemented improved valve maintenance practices. The licensee has purchased a main steam isolation valve seat maintenance tool from the valve manufacturer.
In addition, plant mechanics have received training in conducting leak repairs from the valve vendors and an apprenticeship program (certified by the Institute of Nuclear Power Operations) for mechanics has been implemented.
The NPC staff has reviewed the licensee's LLRT data from the outages conducted during 1977 through 19f7 with regard to CIVs. The data indicates that frequent valve repairs were necessary to minimize leakages, thus prompting the licensee to consider the proposed CAP.
The staff has reviewed the licensee's CAP and finds it acceptable for granting a one-time exemption from performino the required Type A leak test during the
. 1988 refueling outage. The new valves are expected to eliminate the previous failures and correct the bulk of the problem.
The 12 valves scheduled to be replaced during the 1990 refueling outage have acceptable leakage rates based on the latest test information and are likely to perform their intended function with marginal leakage until the 1990 refueling outage. At that time, these valves also will be replaced with the new valves and all CIVs will be subjected to the Typc A test.
As part of the CAP, one of the valves scheduled for replacement during valve (93.,PI-11)g outage is the HPCI turbine exhaust manual isolation the 1988 refuelin The licensee stated that because of the piping configuration the welds attaching the inboard side of this valve to its containment penetration cannot be pressure tested and therefore requested an exemption from the requirement of Section IV.A of Appendix J to 10 CFR Part 50 for the 1988 refueling outage.
Section IV. A reouircs that the leak rate testing (Type A, B, or C test as appropriate) must be performed on all modifications to the containment that could affect the leak tight integrity of the containment system. Therefore, in lieu of the above tests, the licensee proposed an alternate testing program of 100 percent radiography of the weld and dye penetrant or magnetic particle tests for the inboard weld to erisure leak tight integrity of the weld.
Since there are no 'lange connections on the upCI turbine exhaust line valve, isolation of the weld from the containment atnosphere to create an LLRT test volume is impossible. There are no valves between the subiect weld and the containment atmosphere that can isolate the weid. The staff has reviewed the licensee's alternate testing program of 100 percent radiography of the weld and dye penetrant or magnetic particle tests for the inboard weld to ensure the leak tight integrity of the weld.
It has been concluded that these tests are sufficient to assure that structural and leak tight integrity exists in the HPCI turbine exhaust piping. Therefore, the staff concludes that these non-destructive examinations of the weld meets the intent of Section IV. A of Apoendir J to 10 CFR Part 50, which is to assure that modifications to the containment pressure boundary are leak tight.
It is recommended that the licensee's one-time exemption request from Section IV.A of Appendix J to 10 CFR Part 50 be approved. The licensee has further comitted to perform a Type A test durino the refueling outage in 1990.
3.0 SU WARY On the basis of the licensee's CAP to eliminate the root cause of the successive Type A test failures, and the improved valve maintenance program, the staff concludes that the licensee's prooosed request for a one-time exemption from the schedular requirements of Section II..A.6(b) of Appendix J to 10 CFR Part 50 with regard to a Type A PCILRT durino the 1988 refueling outage is acceptable.
This arrangement will permit resumption of the normal retest schedule during the 1900 refueling outage.
Also, the licensee's request concerning an exemption frem Type B or C LLP.T for thi welds attaching the RHR containment spray valves was withdrawn by letter dated October ?A, 198P.
The licensee's reauest concerning non-destructive examination of walds for the HPCI turbine exhaust isolation valve in lieu of Type R or C local leakage rate test is approved.
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4.0 ENVIRONMENTAL CONSIDERATION
This amendment involves a change in the installation or use of a facility component located within the restricted area 6s defined in 10 CFR Part 20.
The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that this anendment involves no significaht hazards consideration and there has been no public comment on such finding. Accordingly, this acendment meets the eligibility criteria for categorical exclusion set forth in 10 tFR Sec 51.22(c)(9).
Pursuant to 10 CFR 51.22(b) no environmental impact settement or environmental assessment need be prepared in connection with the issusnce of this amendment.
5.0 CONCLUSION
We have concluded. based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the public will f
not be endangered by operation in the proposed manner, and (2) such activities i
will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.
4 Dated:
Dated: November 16, 1988 PRINCIPAL CONTRTRUTION:
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