ML20245J008

Exemption Permitting one-time Extension of Test Period for Type a Test from 870927,or Later,Until Next Refueling Outage & for Type B & C Tests from 870718,or Later,Until Next Refueling Outage

ML20245J008
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	08/14/1989
From:	Varga S Office of Nuclear Reactor Regulation
To:	CONNECTICUT YANKEE ATOMIC POWER CO.
Shared Package
ML20245H969	List: ML20245H965 ML20245J008 ML20245J012
References
NUDOCS 8908170423
Download: ML20245J008 (6)

Text

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7590-01 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 1

l-l In the Matter of )

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L CONNECTICUT YANKEE ATOMIC POWER COMPANY ) Docket No. 50-213

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.Haddam Neck Plant )

EXEMPTION 1.

The Connecticut Yankee Atomic Power Company (CYAPCO, the Licensee) is the holder of Operating License No. DPR-61 which authorizes operation of the

'Haddam Neck Plant. The license provides, among other things, that the Haddam -

Neck Plant is subiect to all rules, regulations, and Orders of the Comission now or hereafter in effect.

The plant is a single-unit pressurized water reactor at the licensee's site located in Middlesex County, Connecticut.

II.

One of the conditions of all operating licenses for water-cooled power reactors, as specified in 10 CFR 50.54(o), is that primary reactor containments shall meet the containment leakage test requirements set forth in 10 CFR Part 50, Appendix J. More specifically the following sections require that:

a Section III.A.6.(b), " Additional Requirements - Type A Test" "If two consecutive periodic Type A tests fail to meet the applicable acceptance criteria in III. A.S.(b), notwithstanding the periodic retest schedule of III.D. a Type A test shall be performed at each plant shutdown for refueling or approximately every 18 months, whichever occurs first, ggBQ$kh P

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. until two consecutive Type A tests meet the acceptance criteria in III. A.5.(b),

after which time the retest schedule specified in III.D. may be resumed."

Section III.D.2.(a), " Type B Test"

" Type B tests, except tests for air locks, shall be performed during reactor shutdown for refueling or other convenient intervals but in no case at intervals greater than 2 years."

Section III.D.3, " Type C Test"

" Type C tests shall be performed during each reactor shutdown for refueling but in no case at intervals greater than 2 years."

By letter dated April 26, 1989, CYAPC0 requested a schedular exemption from the above requirements. Haddam Neck was last shutdown for refueling in July 1987 and the leak rate tests were performed over a period of the next 3 months. Haddam Neck was restarted in March 1988, after a 9 month outage and has operated essentially continuously since then, a total of 15 months. By September 5,1989 Haddam Neck will have operated 18 months and will be ready for refueling. However, the 18 month Type A test and the two year Type B and C test periods end before the next refueling on various dates beginning April 27, 1989.

III.

By letter dated April 26,1989 CYAPC0 requested a scheduler exemption from the regulatory requirements cited in Section II above. In this Section, the staff has evaluated the Type A and Type B and C test separately. The accepta-bility of the exemption requests for each item is addressed below. More details are contained in the NRC staff's related Safety Evaluation issued concurrent with this exemption.

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The Safety Evaluation and the above referenced submittal by the licensee are aveilable fcr public inspcction at the Comission's Public Document Room the Gelrt.an Building, 2120 L Street, N.W., kashington, D.C. 20555, and at the Russell Library,123 Broad Street, Middictown, Connecticut 06457.

SectionIII.A.6.(b)

As indicated above the intent of Appendix J was that after two consecutive f ailures of the integrated leat rate test (ILP.T) the plant should perform the ILET during eact refuelir5 cutage nct to exceed 18 ruenths. Hadcam Feck is prtsently schtduled tc cos. duct a refueling outage on or beforc September 5, 1989. Thc cremption would allow the ILRT to be pcstponed urtil that refueling cotage. Such an extensier cf approxir3ately 6 months is desirable in order tc 1

l prevent a mic' cycle shutdown. The *as found" failure of the ILRT has been due to 1

c> cessive Tyrt C lea kagts. CYAPCO bas taken aggressive actier.s to improve the Type C leatages. These efforts have included:

1) Impreving test precedures and methods,

?) l'aking modifications to penetration.s of poor performers,

3) Making modifications tc thc Service Water System to limit silt,

4) Conc'octing suppiecental Tyre C test, and

5) Tursuing an enhancec testing and maintenance program to identify, test, repair and reduce containment leakage.

Thc staff has reviewed these actions and agrees thest actions should reduce l

ientegt from historically peor penetrations and provide CYAPC0 a method to detect and focus its attentior. en future bad performers.

During the last refueling cutage unexpected core barrel and thermal shield repairt crtended ttc outage several months. During this time of approximately l 0 conths plant cuponents were not expcsed to the hermal operating temperature,

4 pressure and rediation conditions. The time interval of 18 months specified in

' Appencix J was based, in part, on the expected degradation of components exposed to the environment resulting from a full 18 months of normal plant-operations. The total exposure time for the containment to normal plant operation. environment at Haddam Neck Plant will be about 15 months.

Therefore the staff would not expect the containment condition to degrade significantly curing the extension of the test period.

Sectitn 111.D.2. (a) and III.D.3 As indicated above the intent of Appendix J was that isolation valves and the associated penetrations be tested durins, each refueling outage not to cxceed 24 mor.ths. Haddam I;eck is preser.tly scheduled to conduct a refueling outagc on or beforc September 5,1989. The exemption would allow the local leat rate tests (Type B and C) to be postponed until that refueling outage.

Such an extension of apprc>.imately 2 months is desirable in order to prevent a midcycle shutdown.

As noted in the 1. pe A test evaluation, CYAPCO has taken aggressive action

.to improve the chances of the of Type C leakage test of passing the ILRT.

Historically, Haddam tieck has not had a problem with Type B leakage. The t:RC staff has concluded that the actions taken by CYAPC0 should reduce leakage thrcugh historically poor penetrations and provide CYAPC0 a method to detect and focus attentien on future bad performers.

During the last refueling outage an unexpected core barrel and thermal shield repairs extended the outage several months. During this time of approximately 6 montns, plant components were not exposed to the normal cperating temperatures, pressure and radiation conditions. The time interval cf 24 months, specified in Appendix J, was based, in part, on the expected

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4 degradation of cor:ponents exposed to the environment resulting from a full 2a months of normal plant operation. The total exposure time for the containment penetration to r.ormal plant operating environment will be only about 15 months.

The 24 month interval requirement for Type B and C penetrations is intended to be often enough to prevent significant deterioration from occurring and long encugh to permit the local leak rate tests (LLRTs) to be performed during plcnt outages. In addition leak testing of the penetrations during pknt- shutcown is preferable because of the lower radiation exposures to plant personnel. F.creover, some penetrations, beccuse of their intended functions, cannct be tested at power operation. For penetrations that cannot be tested during_ power operatier. or those that if testcd during plant operation would cause a ct. gradation in the plant's overall safety (e.g., the closiO5 of E recurdant lir.e in a safety system), the increase in confidence of containment integrity following e successful test is not significant enough tc justify a plant shutdowr specifically to perform the LLRTs within the 24 reonth time period, especially in light of the above discussions.

IV.

Pursuant to 10 CFR E0.12(a)(2)(v), the Commission will not consider granting a schedular exenption unless the licensee has made good f aith efforts to comp 13 with the regulation. The NRC staff believes that CYAPC0 has taken prudent steps to irnprove the containment integrity and if not for the extended refueling outage would have corrplied with Appendix J.

Eased on our evaluation, the NRC staff has concluded CYAPC0 has made good faitt cffort to comply with the requirements of Appendix J and that the special circurr. stances es described in 10 CFR 50.1?(a)(2)(v) exist and the scheduler exemptions ' rom 10 CFF, 50, Appendix J should be 5 ranted.

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b' V.

Accordingly, the Commission has determined that pursuant to 10 CFR 50.12, the exemption is authorized by law, will not endanger life or property or the ccmren defense and security, and is otherwise in the public interest. Therefore, the Commission hereby approves the following exemption request.

A temporary exemption is hereby granted from the requirement of 10 CFR 50, Appendix J, Section III.A.6.(b), which requires that an ILRT be conducted within 18 months of the last refueling outage for good cause shown, this exemption extenas that period by approximately 6 months from April 27, 1909.

A temporary exemption also is granted from the requirements of Sections III.D.2 (a) and III.D.3, which require a local leak rate test be conducted within 24 months of the previous refueling outage. For good cause shown, this exemption extends that period by approximately 2 months from July 18, 1989.

Pursuant to 10 CFR E1.32, the Commission has determined that the granting of this exempticn will have no significant impact on the environment (54 FR 27440).

This exemption is effective upon issuance.

FOR THE NUCLEAR REGULATORY C0tiMISSION w

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@ACL irectg ivision of Reactor Prd e ts 1/II Office of Nuclear Reacto egulation Dated at Rockville, Maryland this 14th day of August, 1989 l

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