ML20236C204
| ML20236C204 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/13/1989 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-89110, NUDOCS 8903220023 | |
| Download: ML20236C204 (3) | |
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Ref 10CFR50.12(a) 7UELECTRIC March 13, 1989 l
W.J.Cahm becutive Ykr PresMent U. S. Nuclear Regulatory Commission Attn: Document Control Desk l
Washington, D. C.
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SUBJECT:
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COMANCHE PEAK' STEAM ELECTRIC STATION (CPSES)
I DOCKET NOS. 50-445 and<50-446 APPLICATION FOR EXEMPTION FROM APPENDIX J STYPE C LEAKRATE TESTING REQUIREMENTS:
i Gentlemen:
Pursuant to 10CFR50.12(a), TV Electric requests an exemption from the requirement of 10CFR50.54(o) to perform Type C containment leakage rate tests as specified in 10CFR50, Appendix J, for CPSES FSAR Table 6.2.4-2 penetrations MS-1 through 4 (containment recirculation sump supply to the Residual Heat Removal (RHR) pumps and the Containment Spray pumps). The exemption is necessary because of the difficulty in performing Type C-leakrate testing on the containment isolation valves for the containment recirculation sump supply to the RHR pumps and to the containment Spray pumps in the current configuration.
Disabling one train of RHR (or Containment Spray) would be required to enable air pressurization of the-portions of sump supply line required for testing.
In the case of RHR, although the technical specifications permit disabling one train ofiRHR (in Mode 6 only and provided certain other conditions are met) TV Electric considers it unwise to place the 4
plant in this configuration to perform leakrate testing.
More importantly, as l
detailed below, Type C testing of the containment isolation valves for the containment recirculation sump supply to the RHR pumps and Containment-Spray pumps is not necessary to achieve the underlying purpose of the regulation.-
l The basic provisions for containment isolation relating to each of these lines consists of a single, motor operated gate valve outside of containment.
The-1 associated ESF systems are required to;be available post-accident, and the single isolation valve in each line ensures system availability.
Double-valving to. permit Appendix J. Type C-testing could compromise system reliability.
The system outside containment is a closed, seismically
. qualified ASME Code Class 2 system. The, associated process piping-is performance tested and inspected to verify its integrity in accordance with.
NUREG 0737, position III.D.1. Additionally, the associated pumps and containment isolation valves are included in the ASME Section XI Inservice Test (IST) program.
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March 13, 1989 Page 2 of 3 The above-mentioned gate valve ~is enclosed'in a valve isolation tank and.the piping from the sump to the valve. is' enclosed in a concentric. guard pipe.--
Although the isolation tank is not a pressure. boundary, it does. allow forf detection and control of any water leakage by drainage to a safety grade leak collection - system.
During normal plant operations and'upon initial ESF actuation,.these valves are normally closed with a water seal provided from the refueling water :
storage. tank.
During the ESF recirculation phases, these valves-are open and supplying water from the containment, sump to their respective ESF pumps. -The water in the. containment sump provides a seal.between the containment-atmosphere (post-accident) and these valves in the event of a singleLfailure (i.e., the loss of an ESF train).
l NRC Regulations provide' for specific exemption in 10CFR50.12(a).if:
o The activities to be conducted are authorized by law; o - The exemption will not endanger life and property; The exemption will not endanger the common defense and security of the o
United States; and o There are special circumstances present that demonstrate good cause for the exemption, i
TV Electric's /' termination to request this exemption is' based upon the l
following spec,al circumstances:
The combination of water seals during normal and accident conditions, and a.
seismically qualified closed system which is inspected and tested to. verify its integrity, provide assurance that no single active failure could result in a release of containment atmosphere to the environment..
These circumstances establish that application of.the regulation in this particular case is not necessary to achieve the underlying purpose of Appendix J, Type C testing requirements, which is to assure that~the containment isolation valves would not be a source of. leakage of. containment atmosphere.
into the environment in the event of an accident.
The above-noted circumstances constitute good cause for'the exemption.and' demonstrate that TV Electric's exemption request is in the public interest.
Accordingly, TU Electric respectfully submits that. the special circumstances.
as provided in 10CFR50.12(a)(2)(ii) justify the requested exemption. The activities sought to be conducted under this exemption request are clearly-authorized by law and the common defense and security of the United States are l
not implicated... In addition, a qualified closed system is provided for L
l containing any unexpected leakage'of containment atmosphere.
Thus,.it is submitted _that'the granting of the requested exemption will not adversely impact the environment.
TXX-89110 March 13, 1989 Page 3 of 3 In conclusion, the standards of Section 50.12(a) are met and the requested exemption is appropriate.
Pursuant to 10CFR170.21, a check for the application fee of $150 is enclosed.
Please advise us if any additional information is necessary.
I Sincerely, j
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William J. Cahill, Jr.
BSD/bsd Enclosure c - Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3) 1 i
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