ML20210A600

Safety Evaluation Supporting Amend 8 to License DPR-3

ML20210A600
Person / Time
Site:	Yankee Rowe
Issue date:	11/08/1985
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20210A535	List: ML20210A529 ML20210A564 ML20210A600
References
NUDOCS 8511150070
Download: ML20210A600 (10)

Text

• , =r UNITED STATES

[ g NUCLEAR REGULATORY COMMISSION r,,

J WASHINGTON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION

-SUPPORTING AMENDMENT NO. 86 TO FACILITY 0PERATING LICENSE NO. OPR-3 YANKEE ATOMIC ELECTRIC COMPANY YANKEE NUCLEAR POWER STATION DOCKET NO. 50-29

1.0 INTRODUCTION

By letters date'd' July 19, 1983, April 17, 1984, August 16, 1984 and April 5, 1985, the Yankee Atomic Electric Company (YAEC) submitted a

_ request for changes to the Yankee Nuclear Power Station Technical Specifications (TS) related to containment systems.

The proposed amendment would modify the TS to (1) clarify plant conditions that require establishing containment integrity, (2) address use of threaded caps or plugs as containment boundaries, (3) make the containment leak testing criteria consistent, (4) modify the surveillance testing of the personnel airlock to comply with Appendix J to 10 CFR Part 50, (5) add

~. TS for the upgraded continuous containment leak monitoring system, (6) make editorial changes and add clarifications to the TS, (7) revise and reorganize the containment isolation barrier listing, and (8) modify the TS to reflect modification of the containment boundary.

A Notice of Consideration of Issuance of Amendment to License and Proposed No Significant Hazards Consideration Determination and Opportunity for Hearing related to the requested action was published in the Federal Reafster on February 24, 1984 (49 FR 7051) and September 11, 1985 (50 FR 37091). No comments or requests for hearing were received.

2.0 EVALUATION (1) TS Page 3/4 6-1, Section 3.6.1.1:

The licensee proposes to delete Mode 5, and the accompanying footnote

" Main coolant pressure > 300 psig," from the APPLICABILITY statement, I- and delete the phrase, "with main coolant pressure < 300 psig," from the ACTION statement. These changes make the TS consistent with the Westinghcuse Standard Technical Specifications (STS) which have been

' reviewed and approved by the staff. Therefore, the proposed changes are acceptable.

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(2) TS Page 3/4 6-1, Section 4.6.1.1:

The licensee proposes to delete 4.6.1.1.b and d.6.1.1.c, since they are redundant with TS 3.6.1.3 and TS 3.6.1.7, respectively; change 4.6.1.1.d at least onceto 4.6.1.1.b and add per 3 merths thataallnew 4.6.1.1.ctest, penetration to read, vent"By andverifying drain (TVD) connections and instrumentation ports providing a direct path to the containment are isolated with a minimum of one cap, plug, closed valve, instrument or appropriate seal," and add a new 4.6.1.1.d to read, "Any threaded pipe cap, or threaded plug to provide containment integrity will be torque tested on installation." The licensee explains that the new 4.6.1.1.c emphasizes the importance of treating TVD connections and instrumentation ports as containment penetrations, and periodically monitoring their isolation status; the new 4.6.1.1.d will ensure the threaded pipe caps and threaded plugs used for containment isolation are J properly installed. We note that threaded devices, such as pipe caps and plugs, are not preferred types of isolation barriers for TVD connections.

However, where threaded devices are used, a requirement for torque testing the threaded devices on installation is proposed. Therefore, we find the proposed TS 4.6.1.1 acceptable.

(3) TS Page 3/4 6-2 and 6-3, Sections 3.6.1.2 and 4.6.1.2:

The licensee proposes to revise these sections, which address containment leakage testing, as follows:

a) Delete Mode 5 and the accompanying footnote from the APPLICABILITY statement. (See item 1 for acceptance rationale.)

b) Change the maximum allowable leakage rate for the reduced pressure test froin 0.1123 w/o per day to 0.10 w/o per day, to make the Limiting

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Condition for Operation (LCO) action and surveillance acceptance criteria consistent.

c) Change the ILRT acceptance criterion from 0.7 L (or L ) to 0.75 L (or L ), to comply with the requirements of Appendix 3 to 10 Crn part s0.

t d) Chence the wording to appropriately reflect deviations from the surveillance intervals prescribed for Types B and C, i.e., local leak rate, testing of com In this regard, a new specification (4.6.1.2.h)ponents., the substance of which was previously approved by letter, USNRC to YAEC, dated September 2, 1982, is added to read as follows:

"Every four years 100% of all electrical penetrations (approximately 25% per year) shall be locally leak tested, subject to the following conditions:

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1. During testing of the electrical penetrations, any penetration

t. which fails the leak test shall be included in the subsequent annual tests until two acceptable consecutive leak tests have been demonstrated; and

2. Those penetrations in Item 1 above shall be additional to those selected for testing during the subsequent annual test periods."

e) Change the second sentence to 4.6.1.2 9 to more appropriately express the intent of ILPT error analyses.

The proposed changes to Section 3.6.1.2 and 4.6.1.2 are acceptable since they bring the specifications into compliance with the requirements of Appendix J to 10 CFR Part 50 or are editorial in nature to clarify their intent.

(4) TS Page 3/4 6-4, Section 3.6.1.3 and 4.6.1.3:

The licensee proposes to revise these sections which address the containment airlock as follows:

a) Delete Mode 5 and the accompa..ying footnote from the APPLICABILITY statement. (See item 1 for acceptance rationale.)

'b) ' Upgrade the containment airlock surveillance requirements in 4.6.1.3 to better reflect the current requirements of Appendix J to 10 CFP Part 50. In the August 16, 1984 letter, the licensee proposed the

, following wording for the revised TS 4.6.1.3:

"The containment airlock shall be demonstrated OPERABLE:

a. Within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following each opening, except when the airleck is being used for multiple entries, then at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />' prior to entering a mode where containment integrity is required, by verifying a pressu" >

drop of less than 0.2 psi when the airlock is pressurizsd to greater than or equal to Pa (31.6 psig) for at least 15 minutes.

b. At least once per 6 months or prior to establishing CONTAIPMENT INTEGRITY when maintenance has been performed on the airlock that could affect the airlock sealing capability, by conducting en overall airlock leakage test at not less than Pa (31.6 psig) and verifying the overall airlock leakage rate is within its limit.

c. At least once per 6 months by verifying that only one door in  ;

the airlock can be opened at a time." - i

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, c The proposed change is consistent with the STS, which have been reviewed and approved by the staff. The acceptance criteria of 0.2 psi pressure drop in 15 minutes for the containment airlock surveillance allows for pressure changes due to tenperature variations, while remaining within the TS limit for the every 6 month test. The staff therefore finds these-changes acceptable.

3 (5) TS Page 3/4 6-6,- Section 4.6.1.5; .TS Page 3/4 6-8, Sections 3.6.1.7

.and 4.6.1.7:

Additional temperature sensors and dew probes were installed as part of .

the continuous -containment leak monitoring system upgrade. To reflect this, the licensee proposed appropriate changes to the subject specifications. Also, the licensee proposes to delete Mode 5 and the accompanying footnote <from the APPLICABILITY statement of 3.6.1.7 (see '

Item 1 for acceptance rationale) We find the upgrading of the continuous

-leak monitoring system and hence the proposed changes acceptable.

__- (6) TS Page 3/4 6-9, Section 3.6.2:

The licensee proposes to delete Mode 5 and the accompanying footnote _from the APPLICABILITY statement. (See item l'for acceptance rationale.)

(7) TS Pape B3/4 6-1, Basis 3/a 6.1.2 and 3/4 6.1.3:

The licensee proposes editorial changes to the subject bases to reflect

_,, .the changes made to. Sections 3/4 6.1.2 (see Item 3) and Sections 3/4 6.1.3.

He find the changes acceptable.

. (8) TS Pace B3/4 6-2, Basis 3/4 6.1.5 and 3/4 6.1.7:

5' The licensee proposes to revise Basis 3/4 6.1.5 by deleting the equation for calculating the average air temperature since the equation _is no longer valid for-the upgraded containment temperature monitoring system.

We find the change acceptable.

The licensee proposes to revise Basis 3/4 6.1.7, concerning the continuous leak monitoring system, by listing those containment components for which the continuous leak monitoring system will provide an indication of continuing integrity. This is the basis for maintaining the continuous leak monitoring system operable, and for deviations from the surveillance interval prescribed for Type B and C testing. We find the revised Basis acceptable.

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(9) The licensee proposes to reorganize Table 3.6-1 of the TS to more clearly identify containment barriers. The revised listing would include the following categories:

A.1 Automatic isolation valves (subject to Type C testing)

A.2 Automatic isolation valves (not subject to Type C testing)

B.1 Manual valves (subject to Type C testing)

B.2 Manual valves (not subject to Type C testing)

C. Check valves (not' subject to Type C testing)

D.1 Remote manual valves (subject to Type C testing)

D.2 Remote manual valves (not subject to Type C testing)

E.1 Barriers (subject to type B testing)

E.2 Barriers (not subject to Type B testing)

F. Safety valves (subject to Type C testing)

G.1 Secondary Automatic Isolation (not subject to Appendix J)

G.2 Secondary Manual Isolation (not subject to Appendix J)

G.3 Secondary Remote Manual Isolation (not subject to Appendix J)

G.4 Secondary Safety Valves (not subject to Appendix J)

__ The staff's evaluation of the licensee's changes to Table 3.6-1 is presented below:

a) The licensee proposes to remove valves HV-SOV-1 and 2 (the hydrogen vent system) from the Table. Since the licensee has identified the normally closed valves (HV-V-5, 6, 34, CA-V-688, 834) as the containment boundary isolation valves for the system, eliminating valves HV-SOV-1 and 2 from the Table is acceptable.

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b) The licensee proposes to remove valves TV-205 and TV-208 from the list of automatic isolation valves and include them in Category D.1 Remote Manual Valves (subject to Type C testing). The licensee also

-- proposes to add a notation to allow operation under administrative controls. These valves are used isolate the component cooling water return from the Vapor Containment (V.C.) and the inlet to the V.C.,

respectively. These valves are~in an essential system having a post-accident function, and remote manual actuation under administrative controls is acceptable. Therefore, the proposed change is acceptable.

c) The licensee proposes to remove valves CA-TV-211, and CA-TV-212 from the list of automatic isolation valves. These valves isolate the containment instrument lines (penetrations 40 and 41) used to provide pressure signals for safety injection and containment isolation actuation. The lines are normally closed outside containment and are classified Safety Class 2. The licensee plans to remove these valves from the lines. Since these lines provide an important safety function and are required post-accident, and are designed as extensions of the containment boundary, removal of the isolation valves is acceptable.

The subject penetrations would be added to Category E.2.

l d). _The licensee proposes to remove valves SC-MOV-551, SC-MOV-552, ,

4 SC-MOV-553, and SC-MOV-554 (shutdown cooling), CH-MOV-522 (MC feed to loop fill header), SI-MOV-516, and SI-MOV-517 (emergency core i- cooling) from the-list of manual valves and place them in Category D.2 Remote Manual Valves. These valves are remote manually operated from the control room, and, therefore, their listing in Category D.? is appropriate.

The licensee also proposes to add two notations to the Table for shutdown cooling valves SC-MOV-551, 552, 553, and 554. The first would exempt these valves from the monthly surveillance requirement l~ of TS 4.6.1.1 (Position Status Check) while in Modes 1 and 2.

1 This is due to ALARA considerations. The second notation would allow these valves to be open in Mode 4 for plant cooldown. Since written procedures are in effect which govern the use of these valves, the proposed notations are acceptable.

e) The licensee proposes to add va' '

CA-V-746 (containment air j.. charge), and VD-V-752, and VD A (neutron shield tank leakage

__ surveillance) to the list o;* .egory B.1 Manual Valves. Test

, ~ connections and valves have been added to allow Type C testing of these valves. Therefore, the change in listing is acceptable.

, f) The licensee proposes to place valves HV-V-5, and HV-V-6, HV-V-34, CA-V-834 (hydrogen vent system) in Category B.1 Manual Valves

, (subject to Type C testing). Test connections and valves have also been added to facilitate leak testing.

. Valves HV-V-34 and CA-V-834 are series valves in a path that parallels j the line containing HV-V-5 and HV-V-6, to provide single failure protection, in accordance with item 2.1.5a of NUREG-0578. Notations

! - have also been added which allow for monthly surveillance of the post-accident hydrogen vent system. The upgrading of'the isolation provisions as proposed is acceptable.

g) The licensee proposes to remove valves CS-CV-215, and CS-MOV-500 (fuel chute) from the Table; the blank flange in the fuel chute (Category E.1) is the isolation barrier for the penetrations. The isolation provision for the fuel chute is acceptable since it is more appropriately viewed as an equipment hatch; Category E.1 isolation barriers are subject to Type B testing.

h) The licensee proposes to remove valves BF-V-4-1 and BF-V-4-2 from the Table. The licensee installed blank flanges on the inlet and outlet of the air purge lines during the 1982 refueling outage; they are listed in Category E.1 as the isolation barriers. Blank flanges that are leak testable are acceptable isolation barriers in lieu of valves. The removal of these valves from the Table is therefore acceptable. .

i) The licensee proposes to remove valve PP-V-610 (Pressurizer Feise Gage Line) listed in Category E.7 from the Table. This instrument line is a closed system, and is protected by two excess flow check valves. Since Regulatory Guide 1.11 is satisfied, the isolation provisions and the Category E.2 listing are acceptable.

j) The licensee proposes to add valve CA-V-755 to Category B.1, Manual Valves (subject to Type C testing). This containment isolation valve serves as the pressure relief valve for the containment personnel hatch; a notation has been added which allows the valve (which is normally locked closed) to be opened while in Modes 1, 2, 3 and 4 for depressurization of the hatch during containment access, or testing. The adminn.trative control to be exercised over the valve and its Category B.1 listing are acceptable.

k) The licensee proposes to add HV-SOV-39 and HV-S0V-42 to Category D.1, Remote Manual Valves (sub,iect to Type C testing). These valves are the containment isolation valves of the hydrogen monitoring system (installed to comply with the TMI Action Plan). They are remote manually operated from the control room. Since the system has a post-accident safety function, remote manual actuation is acceptable. Also, the Category D.1 listing of the valves is appropriate.

1) The licensee proposes to add the containment top manhole cover and the containment bottom manhole cover to Category E.2, since they

~. constitute containment boundary isolation barriers. The barriers in this category are not subject to Type B testing. The listing is accepteble, since the continuous leak monitoring system will detect any degradation of containment boundary leakage integrity.

m) The licensee proposes to add a notation to the fuel chute blank flange (Category E.1) and expansion joint (Category E.2) to exempt them from the monthly surveillance requirement of 4.6.1.1.g.1, i.e.,

from the 31-day check that isolation barriers are secured in their positions. This is due to ALARA censiderations. Because these barriers are under administrative control and because of the low likelihood of their being tampered with during rermal operation, the proposed notation is acceptable, n) the TS to reflect a design modification Thelicenseeproposestomodify(LPST).

to the Low Pressure Surge Tank The design change removed the LPST as a contairment boundary, and simplified the valve configuration required to provide containment isolation. The followirg specific changes were proposed by the licensee:

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1. The licensee proposes to delete valve TV-213 from TS Table 3.6-1.

The addition of CH-LCV-222 as a containment isolation valve provides isolation for the line containing TV-213. TV-213 is no longer necessary for containment isolation, and its administrative deletion from the TS ir acceptable.

2. The licensee proposes to add valves PR-TV-214, Safety Valve Discharge Header Isolation, and CH-LCV-222 Main Coolant Bleed Isolation, to Catecory A.1, Automatic Isolation Valves. These are new automatic isolation valves added to piping between the containment and the LPST to allow for isolating the containment before the LPST, and are therefore acceptable.

3. The licensee proposes to add VD-V-917 (LPST pressure control) to Category B.1, Manual Valves. The valve has been modified to make it Type C testable for 10 CFR Part 50 Appendix J, and this change is therefore acceptable.

_, 4. The licensee proposes to add valves SV-215 (LPST Safety Valve) and SV-223, Valve Steam Leakoff Safety Valve to Category F, Safety Valves. SV-215 provides isolation for the LPST safety valve discharge back into containment. SV-223 provides isolation for a valve stem leakoff branch line. Use of these safety valves as containment isolation valves is allowed as long as the safety valve setpoints are at least 1.5 times the containment design pressure, as provided for in Standard Review Plan (SRP) Section s 6.2.4. Both valves meet this criteria, and their use as containment isolation valves is acceptable.

5. The LPST has been removed as a containment boundary. Due to the

_ reconfiguration of the containment isolation, five of the LPST safety valves were removed and replaced by blank flanges, which became the containment boundaries. Use of blank flanges as containment boundaries is acceptable, and these flanges are appropriately added to TS Table 3.6-1.

o) The licensee proposes to add valves CA-V-1275 and 1276 (H.,Recombiner Tap),

and CA-V-1277 (Conteinment Air Charge) to category B.1, ahd to add a notation ~to TS Table 3.6-1 to allow for surveillance testing of valves CA-V-1275 and CA-V-1276, Hydrogen Recombiner Inlet Valves. These valves are being added to allow connection of a post-accident hydrogen recombiner, as required by 10 CFR 50.44(3)(c)(ii). In addition this change allows for surveillance testing of the recombiner taps under administrative controls.

This change is acceptable, p) The licensee proposes the following administrative changes to TS Table 3.6-1:

1. Table 3.6-1, title for valve TV-207, change "Neutren" to " Neutron".

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2. Removal of previous footnotes from Table 3.6-1 that specified which valves were "NOT SUBJECT TO TYPE C TESTS," and all related asterisks (*). The reclassification of categories clearly specifies which valves are subject to testing, and which are oct.

These changes are purely administrative in nature, do not affect the technical content of the table, and are therefore acceptable, q) The licensee proposes to revise TS Table 3.6-1 to include secondary systen isolation valves as follows:

1. ), TV-406 (Main Steam Place Drain tovalves TV-411TV-401 Condenser), (Atmospheric Steam A, B, C and D Dump (SG Blowdown), and NRV-405 A, B, C and D (Main Steam Non-Peturn Valves) in category G.I. (Secondary Automatic Isolation).

2. Place valves MS-V-627, 628, 629 and 630 (Main Steam Bypass),

SI-V-701 (SI to Alternate SG Feed), VD-V-1157 (HSS to Alternate SG Feed), AS-V-719 (Emergency Feedwater Pump Supply, AS-V-720

- (steam drain) in category G.2. (Second:ry Manual Isolation). The licensee also proposes to add valves BF-V-815, 816, 817, and 818 (Manual Flow Control Bypass), and CF-V-606, 607, 608, and 609 (Chemical Feed) to this category.

3. Place velves MS-MOV-659, 670, 681 and 692 (Atmospheric Steam Dump),

EBF-MOV-557 ( Alternate SG Feed), and BF-CV-1000,1100,1200, and 1300 (SG Feedwater Regulator) in category G.3, (Secondary Remote

~ Manual Isolation). The licensee also proposes to add BF-CV-1000A, 1100A,1200A, and 1300A (Regulating Flow Control Bypass) to this category.

4 Add valves SV-409 A, B, C, 0, E, F, G, H, I, J, K and L (Main Steam Safety Valves) to category G.4. (Secondary Safety Valves).

5. Notations are included to allow operation of category G.2 and G.3 valves under administrative controls.

These secondary isolation valves are included to meet the requirements of General Design Criteria 57, and are, therefore, acceptable, r) The licensee proposes to add SV-227 (CCST Safety Valve) to category F (safety valves) of Table 3.6-1. The discharge line of the component cooling surge tank (CCST) safety valve discharges to containment, since this is the only location capable of receiving the design relief capacity of the CCST safety valve. SV-227 is being designated as the containment isolation valve to replace check valve V0-V-756, as part of the Systematic Evaluation Program (SEP) topic VI-4 (Containment Isolation System). The setpoint of SV-227 is greater than 1.5 times higher than containment design pressure. Its use as containment isolation is, therefore, acceptable.

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- s) The licensee proposes to remove check valve PU-V-649 from TS Table 3.6-1, and to add PU-V-651 (Containment Sump to Charging Isolation valve). The purification to low pressure safety injection header was cut and capped,

. eliminating PU-V-649 as' a containment isolation valve, as part of SEP topic VI-4. PU-V-651 provides the containment isolation bo~undary between the vapor containment sump and the charoing pump suction header. These modifications to the TS to reflect the containment boundary are acceptable.

't) The licensee proposes to remove VD-SOV-301 and 302 from TS Table 3.6-1, and to add VD-V-1107 and 1108 (Containment Sample) to category B.1

.(Manual Valves). A notation is also proposed to allow operation of these containment sample velves under adninistrative controls. The outside air particulate monitor (OAPM), has been replaced by a new monitor inside-containment. The former isolation valves for the 0APM have been replaced by manually operated, locked closed valves to provide containment isolation.

Use of these manual valves for containment isolation, and their operation under administrative control, is acceptable.

(10) Page 3/4 6-1, Basis 3/4 6.1.2, the licensee proposes to update the reference for NRC acceptance of Appendix J exemption requests to reference the USNRC to YAECo letter dated September 2, 1982. This~

adninistrative change is acceptable.

3.0 ENVIRONMENTAL CONSIDERATION

This amendment involves changes to requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 and changes to the surveillance requirements. The staff has determined that the amendment involvo no significant increase in the amounts, and no significant change l' 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 Comission has previously issued a proposed finding that this amendment involves no significant hazards consideration and there has been no public coment on such finding. Accordingly, this amendment meets the eligibility criteria.for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this~ amendment.

4.0 CONCLUSION

The staff has concluded, based on the considerations discussed above, that:

(1) there is reasonable assurance that the health and safety of the will not be endangered by operation in the proposed manner, and such (2) public activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the corinon defense and security or to the health and-safety of the public.

5.0 ACKNOWLEDGEMENT This Safety Evaluation has been prepared by J. S. Guo and J. W. Clifford.

Dated: November 8,.1985