ML20244B561
| ML20244B561 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 08/06/1981 |
| From: | Delgaizo T Franklin Research Ctr, Franklin Institute |
| To: | Huang Y Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML15113A045 | List: |
| References | |
| CON-NRC-03-79-118, CON-NRC-3-79-118, TAC 10114, TAC 10115, TAC 10116 TER-C5257-33-34, TER-C5257-33-34-35, NUDOCS 8108130163 | |
| Download: ML20244B561 (28) | |
Text
,
1
- &;h,
uce;
~
i,,, ;,,
~'r 3'. *;,
\\
$.7 l
9 i
TECHNICAL EVALUATION REPORT i
CONTAINMENT LEAKAGE RATE TESTING
~
A.
DUKE POWER COMPANY OCONEE UNITS L 2, AND 3 NRC DOCKET NO. 50-269, 50-270, 50-287 NRC TAC NO. 10114, 10115, 10116 FRC PRO, LECT Cs257 l
1
^
NRC CONTRACT NO. NRC43 ?S 118 FRC TASK 33, 34, 35 i
i I
)
Preparedby Franklin Research Center Author:
T. J. DelGaizo I
i The Parkway at Twentieth Street Philadelphia, PA 19103 FRC Group Leader:
T. J. DalGaizo l
1 i
Prepared for l
Nuclear Regulatory Commission Washington, D.C. 20555 Lead NRC Engineer:
Y. s. Huang l
l l
Auguse 6, 1981 This report was prepared as an account of work sponsored by an l
agency of the United States Government. Neither the United States Government nor any agency thereof, or any of their employees, makes any warranty, expressed or implied, or assumes any legal liability or responsibility for any third party's use, or the results of such use, of any information, apparatus, product or process disclosed in this report or represents that h t uit by such third party wouM not intringe privately owned rights.
sw
- [\\ [/6 P /30/(,3 &
.00. Franklin Research Center A Division of The Franklin Institute y (_
we a.n,.an ne r%. m Pa. inics assi us.ioco j
Q / C 6 1.3 0 M D 6.,,,
..-n.-,...
d
,..'b
-l TER-C5257-33/34/35
~
i f
CourzrrS f Section Title Page f
1 BACKGROtRC.
1 2
NALCATION CRITDt.IA 3
3 TECHNICAL NALCATION 4
(
3.1 I4censee-Proposed Dcemptions from the Type C Testing Requirements of Appendix J 4
3 1.1 Penetrations 4, 43 - OTSG B, A Drain Lines.
4 I
3.1.2 Penetrations 8, 9, 52 - Loop A Nozzle Warming Idne s High Pressure Injection Lines, A, B.
6 l
313 Penetrations 13, 14 - React 3r Building Spray Inlet Lines, A, B.
7 3.1.4 Penetrations 15,16 - Iow Pre'ssure Injection and Decay Heat Removal Inlet Lines, A, B 9
3.1 5 Penetrations 17, 50 - OTSG, B, A Ibergency i
FDW Lines.
11 f
3.1.6 OTSG Feedwater and Steam Penetrations a.
Penetrations 25, 27 b.
Penetrations 26, 28 l?
317 Penetrations 30, 31, 32 LPSW for RB Cooling Chits z
+
Inlet Linet 33, 34, 35 LPSW for RB Coolirvg Units t
Outlet Line 13 j
318 Reactor Building Daergency Smp Penetrations a.
Penetrations 36, 37 14 j
b.
Penetration 40.
14
}
3.1 9 Penetration 47 (Unit 1 Only) - Demineralized l
Water Supply to RC Pump Seal Vents.
16 J
i i
f I
111
. -.,R,.es,e_ arch _ Center nk!!n I
z.
t.
k E
TER-CS257-33/34/35 CONTENTS (CCtc. )
i i
Section
- Title, Page k
3.1.10 Penetration 51 - Leak Rate Test Line.
16 F
f 3.1.11 Penetrations 57 (Unit 1), 62 (Unita 2. 3) 17 Decay Heat P4moval Return Line
[
3.1.12 Penetration 59 - CF Tank Sample Line.
18 t
[
32 Paversa Direction Testing of Isolation valves.
19 k
3.3 Proposed Technical Specification Changes.
21 23 4
CO!CLUSIONS k
25 REFIRDCI:5.
j t
6 1.
.k Or hI
~.c E
I L:
F I
l I
l-l D
iv TJ'ij Frartklin Research C.en.ter J
a w w % em.
t-4 I
TI3t-CS257-33/34/35 3
7 1.
BACEROUND i
on August 4, 1975 (1], the NRC requested that the Duke Power Company (DPC) review the containment leakage testing program at Oconee Units 1, 2, and 3 J (Oconee ) and provide a plan for achieving full compliance with 10CFR50, Appen-f dix J, Containment hakage Testing, including appropriate design modifications, f changes to technical specifications, or requests for exemption from require-4 ments pursuant to 10Cn.50.12, where necessary.
0 on September 5, 1975 (2], DPC responded to the NRC's request stating that
! the Oconee Technical Specifications were in compliance with 10CFR50, Appendix
.fJ,withoneexception. DPC requested an exemption for this deviation pursuant to 10Cnt50.12.
j on November 30, 1976 (3), DPC reported that subsequent review of the f Oconee testing program revealed that certain additional penetrations may be construed to require Type C testing. DPC stated that these penetrations were tested in conjunction with the integrated leet rata test of the reactor j
building and requested exemption for these' penetrations pursuant to 10CFR50.12.
On December 28, 1976 (4], DPC acknowledged that an approved modified method to meet the objective of 10CFR50, Appendix J, for airlock testing was considered to be a suitable alternative for oconee.
i on Fe.bruary 15, 1977 (5), DPC reported that efforts to test airlocks according to the modified method were unsuccessful and requested an exemotion to the provision of 10CFR50, Aependix J, as previously requested in Reference 2.
On August 15, 1977 (6), the NRC notified CPC that (1) reverse direction testing of the five penetrations identified by DPC in Reference 3 was i
5 acceptable and no exemption was required, (2) more information was required to evaluate the acceptability of not testing seven penetrations so identified in Reference 3, (3) DPC must supply evidence to justify not including 23 n
1 l'
specified containment penetrations in the Technical Specifications listing of penetrations requiring local leak rate testing, and (4) an exemption with respect to airlock testing was declined.
t DV MU Franidin Research C. enter a c==
w n. r=
I l
.4_._-
l TER-C5257-33/34/35 1
On september 14, 1977 [7], CPC provided justification for not testing 31 penetrations (the 30 identified in Reference 6 and penetration number 57) and, following c substantial restatement of the problem associated with compliance with the NRC's position concerning airlock testing, reiterated CPC's position requesting that an exemption in this mattar be granted to allow continuation I
of the existing airlock testing program. Further, on October 24, 1980 (8),
DPC submitted to the NRC a proposed revision to its Technical Specifications w
?
which supplemented the original submittal of Reference 3.
I G
(
On December 29, 1980 (9), DPC submitted a supplement to Reference 8, revising part of its Technical Specifications, and stated that the review of
(
i containment airlock test procedures is continuing.
The purpose of this report is to provide technical evaluations of all l
outstanding submittals regarding the containment leakage testing program at Oconee. Since DPC has indicated in Reference 9 that it is reviewing its airlock test program in view of the October 22, 1980 rule change regarding airlock testing, TRC has not included an evaluation of any airlock submittals.
hI w-l e
t i
4 e.
d Frank!!n Research Center -
A Diammen gg N pm m I
u l
TER-C5257-33/34/35 2.
EFAIUATION CRITERIA l
Code of Federal Regulations, Title 10 Part 50 (10CFRSO), Appendix J, j
containment 14akage Testing, contains the basic criteria used for the j
following evaluation. Recognition that plant-specific conditions can lead to variations not explicitly covered by existing regulations has dictated that this review emphasize the basic intent of Appendix J, that potential 6
l containment atmosphere. leakage paths be identified, monitored, and ma.intained 1
i below established limits. Where applied in the following evaluation, criteria
(
used have been referenced or briefly stated, as necessary, to support the conclusions.
I 1
I
)
I i
l l
\\
i l
l I
1
$0 Frank!!n Research Center A Cheesque el The fnywan Wisches
m
)
i j
TER-C5257-33/34/35 I
3.
TECHNICAL 257ALCATICN In Reference 9, DPC revised its latest proposals regarding con +=4 a==at leakage testing. To facilitate the NRC's review, Beference 9 contained all of l
s DPC's outstanding requests regarding the implementation of Appendix J.
I i
Consequently, FRC has reviewed and evaluated only the Befarence 9 ' submittal.
l 2ese evaluations have been conducted in three categories:
C f
1.
Deemptions from the requirements of Appendix J for testing of j
containment isolation valves (Type C testing) as provided in Table l
[
4.4-1 of Paference 9.
I 2.
Justification for reverse direction valve tasting as provided in j
1 Table 4.4-1 of Reference 9.
l l
l l
1 3.
Proposed technical specification changes as included in Reference 9.
l i
f 31 LICDSEE-PROPOSID IXD(PTIONS FROM THE TYPE C TISTING R2QUIRIMMTS OF APP DiDIX J i
I Deemptions from the Type C testing requirements of Appenddx J, which are I
listed under " Test Paquirement Bases" in Ref erence 9, are evaluated by FRC in j
r.
the fellowing sections.
r t.
3.1.1 Penetrations 4, 43 - OTSG B, A Drain I.ines f
{
Licensee Position "This system can be isolated from the OTSG's and is drained and vented during a Type A test.
A Type C test is required for F
containment isolation valves by Appendix J, III.A.l(d).
E g
"2e inside containment isolation valves are normally closed manual l
gate valves. Outside containment isolation valve is a normally closed u
I motor-operated gate valve which receives an IS signal to close. Se manual isolation valves provide the containment isolation function but
[
are not required to be tested based on the definition of containment f
it.tlation valves in Appendix J, II.H.
The IS closure signal to outside
]
isolation valve is provided as a backup method to assure containment i
isolation. During normal operation, the primary means te assure
)
containment isolation is by having the system valves closed as this system is normally used only when the unit is shutdown and for a a
l limited period of time.during the unit heat-up and prior to l
criticality. hirthermore, the drain lines are connected to a
{
seismically designed system, which does not communicate with the containment, and which operates at conditions well above postulated b MJ Frankhn Research C. enter h w w r,num GD.
l I
l' i
i TER-C5257-33/34/35 l
i l
accident pressure and temperature conditions. Any containment leakage l
associated with this system would be included in the Type A test.
It is considered that a Type C test is neither necessary nor required for this system."
j l
r FRC IVAIDATION 2e Licensee has correctly stated that Section III.A.l. (d) of Appendix J requires Type C testing of the containment isolation valves in the OTSG drain j
lines.Section II of Appendix J, however, defines containment isolation j
valves as those valves relied upon to prevent the escape of containment air to j
(
the surrounding environment.
l provided these drain lines do not rupture as a result of a IDCA, there is no possibility of leakage of containment atmosphere through these penetrations because the steam generators will be operating at pressures in excess of post-accident containment pressure.
If, however, they may rupture as a result of the IDCA (e.g., LOCA missiles or pipe whip), then the isolation valves are relied upon to prevent the escape of containment atmosphere and must be Type C tested. In this case, the fact that the valves are normally shut or are Type A tested is immaterial.
l l
l In Ref erence 8, the Licensee indicated that these drain lines were postulated to rupture after an accident s however, in Reference 9, indication that the lines rupture was omitted without comment.
FRC assumes that the omission was based upon a determination by the Licensee that the lines are not liable to rupture as a result of a IDCA.
i 0
FRC concludes that the CTSG drain line isolation valves (both the manual I
valve inside containment and the actor-operated valve outside containment) do l
not require Type C testing because they are not relied upon to perform a l
l containment isolation function. No exemption from Appendix J is required.
4 bis conclusion is valid, provided that the Licensee has determined that the drain lines inside containment are not liable to rupture as a result of a, IDCA.
nkiln Research Center A Opponen of The Franse anseouse A
i TER-C5257-33/34/35
)
3.1 2 Penetrations 8, 9, 52 - Loop A Nozzle Warming Lines High Pressure Injection Iines, A, B Licensee Position "This systma is normally filled with water and l
operating under post-accident conditions. Sus, it need not be drained i
and vented during the Type A test. A Type C test is required for j
containment isolation valves by Appendix J, III.A.1(d).
"For the Ioop A nozzle warming line, the insicie containment isolation l
valve is a normally open stop-check valve. The outside containment' l
isolation valves are normally open stop-check valve in series with a j
normally throttled needle valve.
I "For the EP injection lines, the inside containment valves are a single
[
swing check in series with two parallel stop-check valves. The outside
(
containment valve is a motor-operated globe valve (A loop - normally closed, B loop - normally open) which receives an IS signal to open.
2ese valves do not perform a containment isolation function as defined in Appendix J, II.4 and thus a Type C test need not be performed."
l 1
l TRC IVALUATION i
te Licensee's position implies that valves which do not perform a l
containment isolation function as defined in Section II.H do not require Type j
l C testing. TRC does not agree with this interpretation of the Type C testing l
requirements of Appendix J.
l Section II.E defines Type c testing as the measurement of containment isolation valve leakage rates. This section further describes four types of valves which are included as containment isolation valves.Section III.A.1.(d) also identifies systems for which the containment isolation valves must be Type C tested.
Section II.B defines containment isolation valves as those valves relied upon to perform a containment isolation function. Combined with the definition of leakage in Section II.D, containment isolation valves may.be further described as those valves relied upon to prevent the escape of containment air to the outside atmosphere. Consequently, the valves of Section II.H or Section III. A.l. (d) that are relied upon to prevent escape of containment air to the outside require Type C tasting.
One of the obvious diff erences between TRC's interpretation of these requirements and the Licensee's interpretation is that TRC would cor,clude that 1
ranklin Research Center
~ ~ - -.
C_________
1 l
TIR-C5257-33/34/35 a normally shut isolation valve in a Section III. A.l.(d) system which is relied upon to prevent leakage of containment air to the outside must be Type C tested, whereas the Licensee would conclude that testing is not required.
me Icop A nozzle warming lines (penetration 8) and the high head safety injection lines (penetrations 9 and 52) will normally be pressurized with water at a pressure significantly in excess of containment accident pressure (Pa) at the beginning of an accident. However, the high head safety injection j
does not operate continuously throughout the postaccident period since it may
/~
be secured when pressure has beca lowered sufficiently to permit low pressure
(
injection. In addition, failure of pump HP-plC to start would prevent the i
pressurization of penetration 52.
Should the system be secured before containment pressure is returned to ambient or should pump HP-Plc fall to operate, however, containment atmospheric leakage would be contained within the system outside containment.
The escape of containment air from a closed loop outside containment can further be prevented by the opening of remotely controlled valves in the emergency core cooling system (B:CS), which would continuously apply water j
pressure from the operating low pressure safety injection system to the isolated portion of the high pressure injection system. This, in addition to the fact that a portion of the system is constantly pressurized by the head of the containment recirculation sump, would preclude leakage of containment air
(
through this system.
g Consequently, FRC finds that the isolation valves of the high pressure safety injection system (penetrations 8, 9, and 52) do not require Type C testing, not because testing is excluded by Section II.H but because these valves are not relied upon to prevent the escape of contaimnent air in accordance with Sections II.D, II.0, and II.H.
3.1.3 Penetrations 13,14 - Peactor Building Spray Inlet I.ines, A, B Licensee Position
" Reactor Building spray system is normally filled
' with water and operating under post-accident conditions and thus, need not be drained and vented during the Type A tsst.
A Type C test as required for containment isolation valves by Appendix J, III. A.1. (d).
nklin Research Center A Dhessem of The Fw rustwee
v e
TIR-C5257,-33/34/35 4
"The inside containment valve is a tilting disc check valve. Outside containtant valve is a normally closed motor-operated globe valve which receives an IS signal to open. These valves do not perform a containment isolation function as defined in Appendix J, II.H and thus a Type C test need not be performed."
TRC IVALUATICH me Licensee's position implies that valves which do not perform a containment isolation function as defined in Section II.E do not require Type 1
C testing. TRC does not agree with this interpretation of the Type C testing requirements of Appendh J.
Section II.H defines Type C testing as the measurement of containment isolation valve leakage rates. 'Ihis section further deceribes four types of valves which are, included as containment isolation valves.Section III. A.l. Id) also identifies systems for which the containment isolation valves must be Type C tested.
Section II.B defines containment isolation valves as those valves relied upon to perf orm a containment isolation function. Combined with the definition of leakage in Section II.D, containment isolation valves may be further described as those valves relied upon to prevent the escape of containment air to the outside atmosphere. Consequently, the valves of Section II.E or Section III. A.l. (d) that are relied upon to prevent escape of containment air to the outside require Type C testing.
One of the obvious diff erences between FRC's interpretation of these requirements and the Licensee's interpretation is that FRC would conclude that a normally shut isolation valve in a Section III. A.l. (d) system which is relied upon to prevent leakage of containment air to the outside must be Type C tested, whereas the Licensee would. conclude that testing is not required.
Each reactor building (RB) spray system at Oconee consists of two independent loops, each of which delivers water fran the berated water storage tank (BWST) or RB emergency sump to the containment spray nozzles. Normally, both locps will be in operation following an accident in which containment l
pressure exceeds atmospheric pressure. When the loops are in operation, water 1
d a on a w w arch C. enter rankjin Rese
.en.
i TIR-C5257-33/34 /35 at pressures greater than Pa will be delivered to the containment, which will prevent any possible out-leakage of containment air through this piping system. Should this system be intermittently operated after an accident or if one loop were to fail (e.g., failure of a pump motor), then there is a ques-tion of potential leakage of containment air to the surrounding environment.
Should the system be secure before containment pressure is returned to ambient or should one of the two loops fail to operate, however, containment atmospheric leakage would be contained within the system outside containment.
The escape of containment air from the closed loop outside containment can be l
(
further prevented by the opening of remotely controlled valves in the ICCS, l
which would continuously apply water pressure from the operating low pressure safety injection system to the isolated portion of the spray system. Ihis, in addition to the f act that a portion of the spray system is. constantly pres,surized by the head of the containment recirculation sump, would preclude leakage of containment air through this system.
i consequently, TRC finds that the isolation valves of the RB spray system do not require Type C testing, not because testing is excluded by Section II.H, but because these valves are not relied upon to prevent the escape of containment air in accordance with Sections II.B, II.D, and II.H.
3.1.4 Penetrations 15,16 - Iow Pressure Injection and Decay Heat Pemoval Inlet I.ines, A, B i
k I.icensee Position
"':his system is required to be filled with water to maintain the plant in a safe condition during the Type A test.
Additionally, this system is normally filled with water and operating under post-accident conditions. Thus, it need not be drained and vented during the Type A tent. A Type C test is required for containment isolation valves by Appendix J, III.A.l.(d).
"':he inside containment valve is a swing check valve. The outside containment valve is a normally closed motor-operated gate valve which receives an IS signal to open. Stese valves do not perform a containment isolation function as defined in Appendix J, II.H and thus a Type C test need not be perfomed."
TRC IVAIDATION The I.icensee's position implies that valves which do net perf orm a containment isolation function as defined in Section II.H do not require Type M,JU'JU Franklin Research Center 9
-b A Dsamen af The Fween einemas e
v 4
TIR-C5257-33/34/35 4
C' testing. FRC does not agree with this interpretation of the Type C testing requirements of Appendix J.
Section II.E defines Type C testing as the measurement of containment isolation valve leakage rates. This section further describes four types of valves which are included as containment isolation valves.Section III.A.l.(d) also identifies systems for which the containment isolation valves must be Type C tested.
I Section II.B defines containment isolation valves as those valves relied upon to perform a containment isolation function. Combined with the l
definition of leakage in Section II.D, containment isolation valves may be j
further described as those valves relied upon to prevent the escape of containment air to the outside atmosphere. Consequently, the valves of Section II.H or Section III.A.l(d) that are relied upon to prevent escape of j
i containment air to the outside require Type C Testing.
One of the obvious differences between FRC's interpretation of these requirements and the Licensee's interpretation is that FRC would conclude that a normally shut isolation valve in a Section III. A.1(d) system which is relied upon to prevent leakage of containment air to the outside must be Type C tested, whereas the Licensee would conclude that testing is not required.
The low pressure coolant injeccion syste.n consists of two injection headers being supplied by three pumps. Once initiated following an accident,
/
this system will remain operational throughout both the injection phase and the long-term postaccident cooling recirculation phase. Furthermore, there is no single active failure which can prevent the operation of the system. In the worst-ease scenario, with e i of the two motor-operated injection valves failing to open (LP-V4A or LP-V4D), the piping will still be water pressurized by the operating pump or pumps. In any event, there is no potential for leakage of containment air to atmosphere through penetrations 15 or 16 because of the presence in the lines of water at a pressure greater than Pa.
Consequently, FRC finds that these isolation valves do not require Type C testing, not because testing is excluded by Section II.H, but because the valves are not relied upon to prevent the escape of containment air in accordance with Sections II.3,.II.D, and II.H.
_anklin Res.earch. Center
l TDL-C5257-33/34/35 3.1.5 Venstrations 17, 50 - OTSG, B, A Bnergency FDW Lines Licensee Position
- his system is normally filled with water and operating under post-accident conditions, and thus, need not be drained and vented during the Type A test. A Type C test is required for contmimnant isolation valves by Appendix J, III.A.1(d).
"2e inside containment valve is a tilting disc check valve. Se outside containment valves are a tilting disc check valve in series with a normally closed pneumatically opened gate valve. These valves do not perform a containment isolation function as defined in Appendix J,
II.H and thus a Type C test need not be performed. "
I (I
FRC EVALt:ATION j
\\
i 2e Licensee's position implies that valves chich do not perform a containment isolation function as defined in Section II.H do not require Type C testing. FPC does not agree with this interpretation of the Type C testing requirements of Appendix J.
I l
Section II.H defines Type C testing as the measurement of containment isolation valve leakage rates. This section further describes f our types of valves which are included as containment isolation valves.Section III.A.l(d) also identifies systems for which the containment isolation valves must be Type C tested.
Section II.B defines containment isolation valves as those valves relied upon to perform a containment isolation function. Canbined with the definition of leakage in Section II.D, containment isolation valves may be further described as those valves relied upon to prevent the escape of containment air to the outside atmosphere. Consequently, the valves of Section II.H or Section III. A.l(d) that are relied upon to prevent escape or containment air to the outside require Type C testing.
One of the obvious differences between FRC's interpretation of these requirements and the Licensee's ir$erpretation is that FRC would conclude that a normally shut isolation valve in a Section III. A.l(d) system which is relied upon to prevent leakage of containment air to the outside must be Type C tested, whereas the Licensee would conclude that testing is not required.
nkb Researth Center A Common el The hunnan insemas a w
TTR-C5257-33/34/35 2e emergency feedwater ( 22W) system is a safety-related system designed to provide steam generator feedwater following an accident. S e design of this system is such that it is capable of providing feedwater, at pressure higher than Pa, to the steam generators despite a possible single active failure. In addition, in the unlikely event that the plant is cooled down and I2M is secured before containment pressure is reduced to ambient, the system represcnts a closed loop inside containment which does not communicate with the containment atmosphere.
Consequently, FRC finds that the isolation valves in penetrations 17 and 50 are not relied upon to prevent the escape of containment air after an
/
accident, and therefore Appendix J does not require testing. No Appendix J exemption is necessary.
l 3.1. 6 OTSG Teedwater and Stear. Penetrations a.
Penet:ations 25, 27 - OTSG B, A Feedwater Lines Licensee Position "2e OTSG is req'uired to be filled with water to maintain it in a safe condition during the Type A test and thus, the feedwater lines cannot be drained and vented. A Type C test is required for containment isolation valves by Appendix J, III. A.l(d).
"No inside containment isolation valves exist. The outside containment valve is a tilting disc check valve. De feedvater lines are connected to a seismically designed system which dcca not communicate with the containment atmosphere. S e feedwater lines are seismically qualified through the outside centalment valve.
3 It is not postulated that this system will rupture during a i
postulated IDCA condition. However, even if it were to rupture, the operating pressure and temperature are well above that expected in the containment. mus, it is considered that a Type C test is neither necessary aor required f or this system."
l b.
Penetrations 26, 28 - OTSG B, A Main Steam Lines Licensee Position "We OTSG is required to be filled with water to maintain it in a sr.fe condition during the Type A test and thus, the main steam line is not vented. A Type C test is required for i
containment isolation valves by Appendix J, III. A.l(d).
"No inside containment isolation valves exist. 2e outside containment valves are two elec.ro-hydraulic turbine stop valves in parallel per main rteam line. Se steam lines are connected to the seismically designed system which does not communicate with the
~
nklin Research Center A Ohemen ad The Fnuedue huunane e
/
TIR-C5257-33/34/35 containment atmosphere. Se steam lines are seismically qualified through the stop valves. It is not postulated that this system will rupture during the postulated IDCA condition. However, even it were to rupture, the operating pressure and temperature are well above that expected in the containment.
'Ihus, it is considered that a Type C test is neither necessary nor required for this system."
TBC IVAIDATION TRC concurs with the Licensee's analysis that Appendix J does not require testing of these lines becausa they are part of a closed system which does not
('
communicate with the reactor coolant pressure boundary or the containment atmosphere and which is not liable to rupture as result cf a IDCA.
j 3.1.7 Penetrations 30, 31, 32 IPSW for RB Cooling Units Inlet Line
}
33, 34, 35 IPSW for RB Cooling Units Outlet Line l
Licensen Position - "his system is normally filled with water and operating under post-accident conditions and, thus, need net be drained and vented during the Type A test.
A Type C test is required for l
containment isolation valves by Appendix J, III.A.1(d).
"No inside containment isolation valves axist. D e outside containment valve is normally open motor-operated gate valve which also receives an IS signal to open. Ihese valves do not perform a containment isolation function as defined in Appendix J, II.H and, thus, a Type C test need l
not be performed. "
TRC EVALUATION 1
3, The Licensee's position implies that valves which do not perform a containment isolation function as defined in Section II.H do not require Type C testing. TRC dass not agree with this interpretation of the Type C testing requirements of Appendix J.
Section II.H defines Type C testing as the measurement of containment isolation valve leakage rates. mis section further describes four types of valves which are included as containment isolation valves.Section III. A.1(d) also identifies systems for which the containment isolation valves must be Type C tested.
I l
1 l
,n i idu Franklin Research Center a c w w reme.
=u.
I m
^
b*W e
~
a T23t-C5257-33/34/35 Section II.B defines containment isolation valves as those valves relied upon to perform a containment isolation function. Centined with the definition of leakage in Section II.D, containment isolation valves may be further described as those valves relied upon to prevent the escape of containment air -
to the outside atmosphere. Consequently, the valves of Section II.H or Section III. A.l. (d) tht are relied upon to prevent escape of containment air to the outside require Type C testing.
One of the obvious differences between 11C's interpretation of these requirements and the Licensee's interpretation is that TRC would conclude that a normally shut isolation valve in a Section III.A.1.(d) system which is relied upon to prevent leakage of containment air to the outside must be Type C tested, whereas the Licensee would conclude that testing is not required.
2e reactor building closed cooling water system' forms a closed system inside containment which is designed to operate throughout the postaccident period. Consequently, the isolation valves of this system are not relied upon to perform a postaccident containment isolation function cs defined by Appendix J and thecefore do not require testing. No exemption frem Appendix J requirements is necessary.
3.1.8 Reactor Building 2nergency Sump Penetrations Penetrations 36, 37 - Reactor Building 2nergency Cump Recirculation
)
a.
Line
(
Licensee Position "his system is normally filled with water and operating under post-accident conditions and, thus, need not be drained and vented during the Type A test. A Type C test is required for containment isolation valves by Appendix J, III.A.l(d).
"No inside containment isolation valves exist. We outside containment valve fer each penetration is normally closed motor-operated gate valve. This valve does not perform a containment isolation function as defined in Appendix J, II.H and, thus, a Type C test need not be performed."
b.
Penetration 40 - RB Bnergency Sump Drain Line Licensee Position "21s system is. drained and vented during a Type A test.
During postulated accident conditions, the RB Bnergency Sump contains water but this line would not be in operation. A Type C test is required for containment isolation valves by Appendix J, III.A.l(d).
_nkin Resea_rch._ Center b
h
_a TIR-CS257-33/34/35 "No inside containment isolation valves exist. All inside containment piping is imbedded in concrete. me outside containment valves are two normally closed manual gate valves in series. Any contmimnent leakage associated with this system would be included in the Type A test.
merefore, it is considered that the additional Type C test is not necessary."
rRC LVAIDATION 1he Licensee's position implies that valves which do not perform a l
\\
f containment isolation function as defined in Section II.H do not require Type j
g C testing. FRC does not agree with this interpretation of the Type C testing I
requirements of Appendix J.
I Section II.H defines Type C testing as the measurement of containment
{
isolation valve leakage rates. mis section further describes four types of i
(
valves which are included as containment isolation valves.Section III.A.l.(d) also identifies systems for which the containment isolation valves must be Type C tested.
I Section II.B defines containment isolation valves as those valves relied upon to perform a containment isolation function. Cmbined with the definition of leakage in Section II.D, containment isolation valves may be further l
described as t!.ose valves relied upon to prevent the escape of containment air to the outside atmosphere. Consequently, the valves of Section II.H or Section III.A. l. ( d) that are relied upon to prevent escape of containment air to the outside require Type C testing.
One of the obvious differences between FRC's interpretation of these requirements and the Licensee's interpretation is that ThC would conclude that a normally shut isolation valve in a Section III.A.l. (d) system which is relied upon to prevent leakage of containment air to the outside must be Type C tested, whereas the Licensee would et.nclude that testing is not required.
Following any accident in which the containment is pressurized with radio-active air, the ~ RB emergency sump will be filled with water by the ECCS system. Pacirculation lines and drain lines,will therefore r =m 4 water
~
covered throughout the postaccident period. This water seal precludes the
. e_nkhn_Rese_ arch _Cen. tar ra dA
J r
l, f
e s
.s
- s r.
l i
.T21-C5357-33/34/35 d
escape of contahumant air to the outside atmosphere, and therefore the isolation valves are not' containment isolation valves as. defined by Appendix '
.j J.
Consequently, 'these valves. do not require Type C testing and no exasption is required.
)
3.1 9 Penetration 47 (Unit 1 only) - Demineralized Water Supply to RC Pump-
']
. Seal vents Licensee Position "21s system is drained 'and. vented during "a Type I
A test.
A Type C test is required for containment isolation valves k
J by Appendix J, III.A.1(d).
)
J
~
"Both the inside and outside containment valves are tilting dise check valves. Any containment leakage associated with this systen
-f would be included in the Type A test. m ersfore, it is considered j
that the additional Type C test is not necessary. "
i i
FRC I. AIJJATION V
Generally, Type A testing is not an adequate substitute for Type C f
testing for two reasons:
I 1.
Type C testing is parformed twice as of ten as Type A testing.
l 2.
Type C testing tests valves individually, whereas Type A testing -
tests penetrations (i.e., two shut valves = in series).. mis is necessary to ensure that, when one isolation valve fails to shut following an accident, the penetration is adequately isolated.' Type i'
A testing is insufficient for this purpose since the leaktightness of l
the penetration is established by the more leaktight of the two shut valves.
In view of the foregoing, FRC finds that' Type C testing of these valves:
is required.
J.1.10 Penetration 51 - Isak Rate Teat Line Licensee Position
" mis air system is vented during the Type A i
test. Draining of fluids is not required.- A Type B test is also' required by Appendix J, III.S.-
'*:he inside containment' device is a gasketed blind ' flange which _is removed only to perform the Type A test. ' ne.outside containment valve is a normally closed air-operated Saunders diaphragm valve.
During the performance of the Typs A test, th's valve is closed and
]
l
)
..._m.-
_......_._.,_..__...,.__..__._....,._.....__..,..._.._._m..
m-u-
. f:
Li TER-C5257-33/34/35 the connecting line vented. Any containment leakage associated with this system would be included in the Type A test.
2erefore, it is j
considered that the additional Type B test is not necessary. "
I
)
rnC tvA wATIon l
In view of the comparison of integrated leakage testing (Type A) and local leakage testing (Type B or c) given in the FPC evaluation in Section 3.1.9, and since this penetration includes a blind flange and single valve (tested by Type A test) which is used only during Type A testing, FPC concurs with the
[
I.icensee's conclusion that Type A testing of this penetration is sufficient i
for the purposes of Appendix J.
3 1.11 Penetrations 57 (Unit 1), 62 (Unit 2, 3) - Decay Heat Removal Return I.ine Licensee Position "his system is regulred to be filled with water to maintain thw plant in a safe condition during the Type A test.
Additional 2y this system is normally filled with water and operating under post-accident condicions. m us, it need not be drained and vented during the Type A test. A Type test is required for containment isolation valves by Appendix J, III.A.1(d).
"to inside containment valves are two normally closed motor-operated gate valves in serias. Se etttside containment valve is a normally closed motor-operated gate valve. tese valves do not perform a containment isolation function as defined in Appendix J, II.H and, thus, a Type C test need not be perfomed. "
b FRC E7AIUATION l
me Licensee's position implies that valves which do not perform a containment isolation function as defined in'Section II.H do not require Type C testing. FRC does not agree with this interpretation of the Type C testing requirements of Appendix J.
Section II.H defines Type C testing as the measurement of containment isolation valve leakage rates. 21s section further describes f our types of valves which are included as containment isolation valves.Section III.A.l.(d) also identifies systems for which the containment isolation valves must be Type C tested.
rarMn Rescerth Center A Chaman af The hensen pusewes
v-g T U-C525b 13/34/35 j
.Section II.B defines containment isolation valves as those valves relied upon to perform a containment isolation function. Combined with the definition of leakage in Section II.D, containment isolation valves may be further described as those valves relied upon te prevent t.he escape of containment air to the outside atmosphere. Consequently, the valva.s of Section II.H or Section III.A.1.(d) that are relied upon to prevent uscape of containment air to the outside require Type C testing.
one of the obvious differences between FRC's interpretation of -these
(-
['
requirements and the Licensee's interpretation is that FRC would conclude 'that a normally shut isolation valve in a section III. A.1. (d) system that is relied upon to prevent leakage of containment air to the outside must be Type I
C tested, whereas the Licensee would conclude that testing is not required..
l We decay heat removal return line is directly connected to the low pressure coolant injection (LPCI) system which will be in operation throughout i
the entire postaccident period as discussed in the FRC evaluation in Section 3.1 4.
Leakage of containment air through this penetration is prevented by the water seal created by the operating LPCI system. Consequently,-Type C testing is not required by Appendix J because the isolation valves are not relied upon to perform a containment isolation function.
~
3.1.12 Penetration 59 - CF Tank Sample Line Licensae Position "This system is vented and drained during the Type A test. A Type C test is also required for containment isolation valves by Appendix J, III.A.1(d).
"L5e inside containment valves are two normally closed actor-operated gate valves in parallel, one to each core flood tank.
Se outside containment valves are two normally closed manual globe valves in parallel. Any containment leakage associated with this system would be included in the Type A test.
Furthermore, these valves do not perform a containment isolation function as defined in Appendix J, II.H, and thus, it is considered that a Type C test need not be performed.*
FRC IV,ALUATION Se Licensee's position implies that valves which do not perform a containment isolation function as defined in Section II.H do not require Type
_rankun Resear_ch _Cen.ter i
i
g[
.F
,r 1
TER-C5257-33/34/35 C testing. FRC does not agree with this interpretation of the Type C testing requirements of Appendix J.
Section II.H defines Type C testing as the measurement of containment isolation valve leakage rates. This section further describes four types of valves which are included as containment isolation valves.Section III.A.1.(d) also identifies systems for which the containment isolation valves must be Iype C tested.
Section II.B defines containment isolation valves as those valves relied
(
upon to perfom a containment isolation function. Combined with the definition of leakage in Section II.D, containment isolation valves may be further described as those valves relied upon to prevent the escape of containment air to the outside atmosphere. Consequently, the valves of Section II.E or Section III. A.1. (d) that are relied upon to prevent escape of containment air to the outside require Type C testing.
l One of the obvious differences between TRC's interpretation of these requirements and the Licensee's interpretation is that FRC would conclude that a normally shut isolation valve in a section III. A.1. (d) system that is relied upon to prevent leakage of containment air to the outside must be Type C tested, whereas the Licensee would conclude that testing is not required.
Core flood tank (CPI) sample isolation valves can become a barrier to the escape of containment air when the location of the IDCA break causes the contents of a tank to be discharged into the containment. In this case, a leaking sample line will allow the CFT nitrogen to be vented such that containment atmosphere can then enter the CFT by leaking through check valve CF-11 or CF-13.
Since the isolation valves may be relied upon to prevent the escape of containment air in this situation, Type C testing is required.
3.2 RIVIRSE DIRICTION TISTING OF ISOLATION VALVIS In Table 4.4-1 of Reference 9, CPC lints.14 penetrations for which reverse direction testing is planned. A justification for this testing is Provided for each penetration.
bP.
Frankun Research C. enter acm = w N r en
_ _ _ _ _ _ _ _ - _ - - -. _ - - - - - - - - - - ~
9 d
TDL-C5257-33/34/35 i
In each case, test connections for inboard and outboard penetration l
isolation valves exist between the valves so that the inboard valve is tested I.
1 in the reverse direction. Also, Type A test requirements for each penetration i
are fully met.
DPC apparantly believes that, because the measured leakage when pressurizing between the two valves results in a leakage rate for both valves, the test is conservative.
TIC LVAIDATION
/"
I l
Type A procedures test connimat penetrations, i.e., penetrations with l
two shut isolation valves in series. Compared to Type A testing, DPC's procedure is a conservative measurement of penetration leakage. Type C procedures, however, test individual isolation valves.' In this case, DPC's i
procedure is not necessarily conservative.
Appendix J permits reverse direction testing of an isolation valve when it can be determined that leakage rates measured in the reverse direction are equivalent to or more conservative than leakage rates measured in the direction of accident pressure for that particular valve. 21s determination, there-fore, is contingent upon the type of valve and possibly the design of the l
particular valve as well. Once the Licensee has made a determination that l
reverse direction testing is equivalent to or more conservative than testing a
in the direction of accident pressure for a particular valve, reverse i
l direction testing is authorized by Appendix J.
No report to the NRC is I
~
necessary nor is a request for exemption necessary. However, the Licensee must be prepared to justify the determination, if so requested.
J In view of the foregoing, TRC does not conmar with the justification
)
I presented by the Licensee in Paference 9 for reverse direction testing of these valvas. to acceptability of reverse direction testing, however, rema.ns a matter for Licensee determination.
l To assist the Licensee in these determinations, the following obser-vations relative to conmunly encountered valves are provided based upon TRC's experience in reviewing containment leakage testing submittals from various operating reactors :
1 i
\\
nkun Research Center A 0 human of he husuen wouhme s %
.m_
_,7 7
'TIR-C5257-33/34/35 1.
Cate valves - generally not capable of reverse direction testing because the seating surfaces relied upon to prevent accident leakage i
are not tested
- by reverse direction pressure.
2.
Globe valves - where reverse direction testing tends to unseat the l
valve, testing may be considered conservative.
Where reverse direction testing tends to seat the valve, testing may still be considered equivalent if the seating force exerted by the valve stem (with normal torque applied) is substantially larger than the seating force exerted by the test pressure.
3.
Butterfly valves - generally, measured leakage is independent of the
('
direction of test pressure both frou a force-exerted standpoint and a seating-surface standpoint.
I 4.
Stop-check valves generally, reverse direction testing is conservative although an evaluation of differential forces may be appropriate for certain valves.
5.
Ball / plug valves - generally not capable of reverse direction testing for reasons similar to those in the gate valve discussion above.
6.
Diaphragm valves = often similar to globe valves but require evaluation on a case-by-case basis.
33 PROPOSZD TICHNICAL SPECIFICATION CHANG 2:S In Reference 9, DPC provided proposed revisions to Sections 3 6.6 and 4.4.1 of.he Technical Specifications for the Oconee plants. ':hese sections
(
provide for the pressure, frequency, and acceptance criteria, and the accuracy and repor.ing requirements of the integrated leak rate test; the scope of testing, : frequency, and acceptance criteria of the local leak rate tests; reactor bailding modification requirements and isolation valve functional test requirements.
FRC LVAIDATION Subparagraph 4.4.1.2.1 (Scope of Testing) requires that local leak rate tests be performed in accordance with Appendix J with the exception of the exemptions f rom-Appendix J noted in Table 4.4-1.
FRC's evaluations of these proposed exemptions are provided in Section 3'1 of this report.
i "U~
'n d U Franklin Resestrh Center A Chassen af the Pm sumane
___.___--__m
~
go i
c TIR-C5257-33/34/35 i
I d
subject to the evaluations of section 3.1 of this report regarding DPC's proposed exemptions of Table 4.4-1, ITC finds that the proposed Technical i
Specifications are in conformance with the requiren.nts of Appendix J and us therefore acceptable.
Gupp i
i A
- q..
G.
S Sl t
i 1
j i
u00Gr.nuin n
,cn c.n, A Cheen ad The Ponen timumme
l e
W C
J
?
TER-C5257-33/34/35 l
4 4.
CO!CLUSIONS
.m Technical wealuations of Licensee-proposed exemptions from the require-e eents of Appendix J, justifications for continued reverse direction testing, and proposed Technical Specification changes for Oconee as summitted in Reference 9 have resulted in the following conclusions:
l l
1 I
o Proposed exemptions for the following isolation valves identified in l
[;
Table 4.4-1 have been found unacceptable. These valves should be i
tested in accordance with Appendix J:
1
(. W i
y Penetration 47 (Unit 1 only) - Demineralized water supply to RC pump seal vents 1
Penetration 59 - CF tank sample lines.
l' o Proposed exemptions for the following isolation valves are not necessary because Type C testing is not required by Appendix J Penetrations 4, 43 - OTSG B, A drain lines N
Penetrations 8, 9, 52 - Loop A nozzle warming linei high pressure injection lines, A, B j
~}
i
[
Penetrations 13, 14 - Reactor building spray inlet lines, A, B l
1 J
J Penetrations 15,16 - Iow pressure injection and decay heat i
removal inlet lines, A, 3 j
Penetrations 17, 50 - OTSG B, A emergency FDW lines j
Penetrations 25, 27 - OTSG B, A feedwater lines l
Penetrations 26, 28 - OTSG B, A main steam lines Penetrations 30, 31, 32 - LPSW for RB cooling units inlet lines Penetrations 33, 34, 35 - LPSW for RB cooling units outlet lines Penetrations 36, 37 - Reactor building emergency sump recirculation line Penetration 40 - RB emergency sump drain line Penetration 51 - Leak rate test line Penetration 57 (Unit 1), 62 (Units 2, 3) - Decay heat removal line Justification for reverse direction testing of certain isolation o
valves provided in Ref erence 9 was found to be insufficient. The acceptability of reverse direction testing in accordance with Appendix J remains a matter for Licensee datarmination.
N M Frank!!n Research Center Mb
-_________----__-__m
v i
i M
-3 Sb l
<i M
T R-C5257-33/34/35 rv; Proposed Technical Specification changee subutitted in Raference 9 o
!J were found to be acceptable subject to modification of Table 4.4-1 in accordance with the findinge of this report regarding l
exemption of isolation valves for penetrations 47 (Unit 1 only) and 59.
l l, ~
,t '-
y,:t 4
y-g P:
/8 4
q 4
i 1
w N
l l
1 b
~
. - ~
fi; z
5; 5-t
, q, ?
T2R-C5257-33/34/35 5.
R2FIRINCIE 1.
K. Go11er lNRC)
Letter to W. O. Parker, Jr. (DPC)
August 4, 1975 2.
W. O. Parker, Jr. (DPC) l Letter to R. Boyd (NRC) l September 5, 1975 g
3.
W. O. Parker, Jr. (DPC)
!atter to B. Rusche (NRC) f.. '
November 30, 1976 4.
W. O. Parker, Jr. (DPC)
, letter to B. Rusche (NRC)
{
December 28, 1976 5.
W.
O. Parker, Jr. (DPC)
Istter to B. Rusche (NRC)
February 15, 1977 6.
A. Schwencer (NRC)
Iatter to W. O. Parker, Jr. (DPC)
August 15, 1977 7.
W. O. Parker, Jr. (DPC)
[-
14tter to E. Case (NRC, NRR)
September 14, 1977 8.
W. O. Parker, Jr. (DPC) k Iatter to R. W. Reid (NRC, ORB)
October 24, 1980
.e f
9.
W. O. Parker, Jr. (DPC)
?
Iatter to R. W. Reid (NRC, ORB)
December 29, 1980 i
1 nkun Reseerth Comer A Dhuman af The Femamen tumum
. _ _ _ _ _ _ _