ML20217L720
| ML20217L720 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 03/23/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20217L011 | List: |
| References | |
| NUDOCS 9804070366 | |
| Download: ML20217L720 (5) | |
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,, j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 30006 0001 o\ .....+ q SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 185 TO FACILITY OPERATING LICENSE NO. DPR-40 OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION. UNIT NO.1 DOCKET NO. 50-285 1.0' INTRODUCTION On September 12,1995, the U.S. Nuclear Regulatory Commission (NRC) approved issuance of a revision to 10 CFR Part 50, Appendix J," Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors" which was subsequently published in the Federal Register on September 26,1995, and became effective on October 26,1995. The NRC added Option B,
" Performance-Based Requirements," to allow licensees to voluntarily replace the prescriptive testing requirements of 10 CFR Part 50, Appendix J, with testing requirements based on both -
overall performance and the performance of individual components.
By application dated July 25,1997, Omaha Public Power District (OPPD) requested changes to the Technical Specifications (Appendix A to Facility Operating License No. DPR-40) for the Fort Calhoun Station, Unit No.1. The requested changes would permit implementation of 10 CFR Part 50, Appendix J, Option B. The licensee has established a "10 CFR 50 Appendix J Testing Program Plan" and proposed adding this program plan to the TS. The program plan references Regulatory Guide 1.163, " Performance-Based Containment Leak Test Program," dated -
September 1995, which specifies a method acceptable to the NRC for complying with Option B.
The November 21,1997, and March 3,1998, supplemental letters provided additional clarifying information that did not change the initial no significant hazards consideration determination published in the Federal Register on November 5,1997 (62 FR 59919).-
2.0 BACKGROUND
Compliance with 10 CFR Part 50, Appendix J, provides ast,urance that the primary ,
containment, including those systems and components whl:h penetrate the primary containment, do not exceed the allowable leakage rate specified in the TS and Bases. The i allowable leakage rate is determined so that the leakage rate assumed in the safety analyses !
is not exceeded. l 1
On February 4,1992, the NRC published a notice in the Federal Register (57 FR 4166) discussing a planned initiative to begin eliminating requirements marginal to safety which l
1 9904070366 900323 l PDR ADOCK 05000285 P PDR
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Impose a significant regulatory burden. ' Appendix J to 10 CFR Part 50, " Primary Containment
. Leakage Testing for Water-Cooled Power Reactors," was considered for this initiative and the staff undertook a study of possible changes to this regulation. The study examined the previous performance history of domestic containments and examined the effect on risk of a revision to the requirements of Appendix J. The results of this study are reported in NUREG-1493," Performance-Based Leak-Test Program."
Based on the results of this study, the staff developed a performance-based approach to
' containment leakage rate testing. On September 12,1995, the NRC approved issuance of this revision to 10 CFR Part 50,~ Appendix J, which was subsequently published in the Federal l Register on September 26,1995, and became effective on October 26,1995. The revision 1 added Option B, " Performance-Based Requirements," to Appendix J to allow licensees to voluntarily replace the prescriptive testing requirements of Appendix J with testing requirements based on both overall and individual component leakage rate performance.
Regulatory Guide 1.163, " Performance-Based Containment Leak Test Program," dated September 1995, was developed as a method acceptable to the NRC staff for implementing Option B. This regulatory guide states that the Nuclear Energy Institute (NEl) guidance document NEl 94-01, Rev. O, " Industry Guideline for implementing Performance-Based Option of 10 CFR Part 50, Appendix J," provides methods acceptable to the NRC staff for complying with Option B with four exceptions which are described therein.
I Option B requires that Regulatory Guide 1.163 or another implementation document used by a licensee to develop a performance-based leakage testing program must be included, by general reference, in the plant TS. The licensee has referenced Regulatory Guide 1,163 in the
. proposed Fort Calhoun Station TS.
Regulatory Guide 1.163 specifies an extension in Type A test frequency to at least one test in 10 years based upon two consecutive successful tests. Type B tests may be extended up to a rnaximum interval of 10 years based upon completion of two consecutive successful tests and Type C tests may be extended up to 5 yeus based on two consecutive successful tests.
By letter dated October 20,1995, NEl proposed TS to implement Option B. After some discussion, the staff and NEl agreed on final TS which were transmitted to NEl in a letter dated November 2,1995. These TS are to serve as a model for licensees to develop plant-specific TS in preparing amendment requests to implement Option B.
l In order for a licensee to determine the performance of each component, factors that are r indicative of or affect performance, such as an administrative leakage limit, must be - )
. established. The administrative limit is selected to be indicative of the potential onset of 1 component degradation. Although these limits are subject to NRC inspection to assure that they are selected in a reasonable manner, they are not TS requirements. Failure to meet an administrative limit requires the licensee to retum to the minimum value of the test interval. 1 Option B requires that the licensee maintain records to show that the criteria for Type A, B and C tests have been met, in addition, the licensee must maintain comparisons of the
3-performance of the overall containment system and the individual components to show that the test intervals are adequate. These records are subject to NRC inspection.
3.0 EVALUATION
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The licensee's July 25,'1997, letter to the NRC proposes to establish a " Containment Leakage _
Rate Testing Program" and proposes to add this program to the TS. The program is consistent with Regulatory Guide 1.163, " Performance-Based Containment Leak Test Program," dated September 1995, which specifies methods acceptable to the NRC for complying with Option B.
This requires changes to existing TS 3.5(2) and 5.9.3, deletion of TS 3.5(3) through 3.5(7),
addition of a new TS 5.19 " Containment Leakage Rate Testing Program." The corresponding bases were also modified.
Option B permits a licensee to choose Type A; or Type B and C; or Type A, B and C; testing to be done on a performa_nce basis. The licensee has elected to perform Type A, B, and C testing on a performance basis.
The TS changes proposed by the licensee are in compliance with the requirements of Option B and consistent with the guidance of Regulatory Guide 1.163, with three' exceptions noted by the licensee; these are discussed in Sections 3.1 through 3.3, below. Further, despite the different format of the licensee's current TS, all of the important elements of the model TS guidance provided in the NRC letter to NEl dated November 2,1995, are included in the proposed TS, with a few exceptions as discussed in Section 3.4, below.
3.1 Personnel Air Lock The licensee's proposed TS changes include an exception to the requirement for testing the personnel air lock (PAL) prior to establishing containment integrity, in a letter dated January 10,1986, the NRC granted an exemption to OPPD from certain 10 CFR Part 50, Appendix J requirements including personnel air lock leakage testing. The licensee's technical specifications were amended on February 3,1986, (Amendment No. 95) to reflect the personnel air lock exemption. Regulatory Guide 1.163 endorses NEl 94-01 which states that attemate performance-based testing requirements contained in Option B of Appendix J will not invalidate previously granted exemptions. Also,Section V.B.1 of Option B of Appendix J states:
B. Implementation
- 1. Specific exemptions to Option A of this appendix that have been formally approved by the AEC or NRC, according to 10 CFR 50.12, are still applicable to Option B of this appendix if necessary, unless specifically revoked by the NRC.
Since the air lock exemption validity is based on guidance stated in NEl 94-01 and endorsed by Regulatory Guide 1.163, and is in accordance with the cited section of Option B of Appendix J, the staff finds the proposed method of testing the personnel air locks to be acceptable.
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~<* ,4, 3.2 Tvoe A Tests for One-Inch Na.seGens NEl 94-01, Section 9.2.4, " Containment Repairs and Modifications," states that Type A testing may be deferred to the next regularly scheduled Type A test for "... welds attaching to steel pressure-retaining boundary penetrations, where the nominal diameter of the welds or
. penetrations does not exceed one inch." The licensee's proposed TS change incorporates an exception that Type A tests be deferred for penetrations of the steel pressure retaining boundary where the nominal diameter does not exceed one inch. The industry guidance (NEl-94-01) on containment repairs and modifications allows deferral of Type A testing for welds and penetrations that do not exceed one inch in nominal diameter. Therefore, the licensee's proposed change is found to be acceptable by the staff, although it is not considered an exception.
3.3 ' Consecutive Tvoe A Tests Current TS 3.5(3) requires containment integrated leak rate tests (Type A tests) to be conducted in accordance with Appendix J to 10 CFR Part 50. The proposed TS 5.19 establishes a containment leakage rate testing program to implement Option B of Appendix J to 10 CFR Part 50, and in accordance with Regulatory Guide 1.163, dated September 1995.
. Additionally, Regulatory Guide 1.163 references NEl 94-01, " Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J," Rev. O.
Section 9.2.3, " Extended Test Intervals," of NEl 94-01 states, in part, that the test interval for Type A tests (containment integrated leakage rate tests) may be increased to 10 years if the plant has passed the last two consecutive Type A tests. Further, it states that the elapsed time between the first and last tests in a series of consecutive satisfactory tests shall be at least 24 months. Proposed TS 5.19(3) would take an exception to the 24-month requirement and reduce it to 18 months.
The purpose of specifying a minimum time interval between consecutive satisfactory tests is to ensure that the containment is exposed to a significant amount _of plant operating time, sufficient to allow containment leakage to deteriorate, and to demonstrate sustained good performance of the containment over time. The proposed 18 months provides a reasonable time interval and is the nominal refueling cycle for this plant. Therefore, the staff finds that this exception to NEl 94-01 will not have a significant adverse effect on safety and that the proposed TS is acceptable.
3.4 Exceptions to Model TS !
Proposed TS 5.19, " Containment Leakage Rate Testing Program," contains two items, leakage rate acceptance criteria c. and d., which are not in the model TS. Item c. is the acceptance i criterion for containment purge valve leakage rate testing. Item d. specifies the acceptance l criterion for the Type B and C test total during plant operation, and requires a shutdown if the acceptance criterion is not satisified for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or more. Both items c. and d. are contained in the current plant TS and are merely being moved to proposed TS 5.19. As this is a simple relocation of existing TS requirements, the staff finds it to be acceptable.
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4.0 STATE CONSULTATION
in accordance with the Commission's regulations, the Nebraska State official was notified of the proposed issuance of the amendment. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes surveillance requirements. The NRC 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 the amendment involves no significant hazards consideration, and there has been no public comment on such finding (62 FR 59919). Accordingly, tho' amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). This amendment also involves changes in recordkeeping, reporting or administrative procedured or requirements. Accordingly, with respect to these items, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10). Pursuant to 10 CFR 51.22(b) no environmentalimpact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
6.0 CONCLUSION
- The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) ruch activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: Raynard Wharton Date: March 23, 1998 l
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