ML20247R047

Environ Assessment Supporting Exemption from Requirements of 10CFR50,App J,Section III.A.6.(b) to the Extent That Type a Primary Containment Integrated Leak Rate Test Would Not Have to Be Performed During Surveillance Outage

ML20247R047
Person / Time
Site:	Pilgrim
Issue date:	09/19/1989
From:	Wessman R Office of Nuclear Reactor Regulation
To:
Shared Package
ML20247R049	List: ML20247R047
References
NUDOCS 8909290157
Download: ML20247R047 (6)

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UNITED STATES NUCLEAR REGULATORY COMMISSION BOSTON EDISON COMPANY DOCKET NO. 50-293 ENVIRONMENTAL ASSESSMENT AND FINCING OF NO SIGNIFICANT IMPACT The U.S. Nuclear Regulatory Comission (the Commission) is considering issuance of exemptions from certain requirements of 10 CFR Part 50, Appendix J.

SectionIII.A.6(b),III.D.2(a),andIII.D.3,totheBostonEdisonCompany (BEC0/ licensee) for the Pilgrim Nuclear Power Station located at the licensee's site in Plymouth County, Massachusetts.

ENVIRONMENTAL ASSESSMENT Identification of Proposed Action:

The licensee would te exempted from the requirements of 10 CFR Part 50, Appendix J, Section III.A.6(b) to the extent that a Type A Primary Containment Integrated Leak Rate Test (PCILRT) would not have to be performed during the Pilgrim Nuclear Power Station's (PNPS) upcoming surveillance outage scheduled for October 1989. Also, the normal PCILRT retest schedule specified in Section III.D.1(a)ofAppendixJNouldberestored.

In addition, the licensee would be exempted from the requirements cf Sections III.D.2(a) and III.D.3 to the extent that Type B and C Local Leak Rate Tests (LLRTs) would not be performed during the upcoming October 1989 outage, but would be allowed a one-time schedule extension of approximately six months for the following components:

1.

Shutdown Cooling Isolation Valves MO-1001-47 and M0-1001-50 (Type C LLRTs) 2.

Reactor Building Closed Cooling Water Isolation Valve M0-4002 on the line from the drywell and Check Valve 30-CK-432 on the line to the drywell (Type C LLRTs) 8909290157 890919 PDR ADOCK 05000293 (p

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Drywell Head and Drywell Head Access Hatch (Typt 8 LLETs)

The Need for the Proposed Action:

The PCILRTs performed during the 1982, 1983, and 1987 refueling outages at the PNPS were deemed failures in the "as-found" condition due to leakage from the pathways of the Type B and C LLRTs.Section III.A.6(b) of Appendin J states that, should two consecutive PCILRTs fail to meet the applicable acceptance criteria, a retest must be performed during each subsequent refueling outage until two consecutive tests are deemed acceptable, cfter which time the retest schedule specified in Section III.D.1(a) may be resumed. Accordingly, the licensee would be required to perform a PCILRT during the surveillance outage scheduled for October 1989. As an alternative to performing the required test, the licensee has submitted a Corrective Action Plan in accordance with the guidance provided in NRC Information Notice 85-71, " Containment Integrated Leak Rate Tests",

dated August 22, 1985.

The Corrective Action Plan includes a LLRT failure analysis team to investigate LLRT failures, determination of root causes, and recommend corrective actions. The plan also includes a trending program, test method improvements and augmented testing.

It should be noted, that the major leakage (about 83%)

of the LLRTs performed in December 1987, was due to the feedwater check valves. The short term replacement of problem components in the valves and the long term inspection and testing of the valves had been unsuccessful. However, in recent years, the licensee initiated a Valve Betterment Program which has resulted in the replacement of 17 valves and modifications to 12 other valves which were identified as having excessive leakage. These actions appear to have resolved the feedwater check valve leakage problem and leakage from other Type 8 and C components. The implementation of the Corrective Action Plan including augmented LLRTs and continued close trending of the Type 8 and C

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1 tests performed on all required penetrations, including the replaced and refurbished valves, should ensure the intent.of 10 CFR 50, Appendix J Section III.A.6(b) is met in that unacceptable containment leakage is identified and corrected.

The schedule exemption for the Shutdown Cooling Suction Isolation valves is needed to defer the leak rate testing until the next scheduled refueling outage. The shutdown cooling system is the normal means of removing decay heat from the reactor vessel during short outages, such as the upcoming October 1989 surveillance outage.

The schedule exemption for the Reactor Building Closed Cooling Water (RBCCW) system isolation valves is needed because the testing would impact components cooled by the RBCCW system during the upcoming short outage.

In addition, staging to provide access must be built and removed resulting in considerable exposure of workers to radiation. The water in the system is also required to be drained and treated resulting in an increase in the produc-tion of radwaste.

The schedule exerno-fon for the drywell head and the drywell head access hatch is needed due to tie extent of the work needed to be performed and the resulting worker exposure to radiation. Nine shield blocks above the drywell must be removed. These are normally removed only during refueling outages to allow removal of the reactor head for fuel loading.

Environmental Impacts of the Proposed Action:

The proposed action of performing the Type A PCILRT during the next refueling outage (RFO-8) and then following a schedule in accordance with 10 CFR50,AppendixJ.SectionIII.D.1(a),isbasedontheimplementationof I

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, 1 the Corrective Action Plan and continued trending of LLRTs. These actions would ensure that excessive leakage from containment isolation valves is identified and corrected. The proposed action would provide a level of safety at least equivalent to that attained by being in compliance with 10 CFR 50, Appendix J, Section III.A.6(b).

The proposed actiore, in relation to the granting of a one-time schedule extent'on of approximately six months for performing the Type B or C LLRTs on the components previously discussed, is based on augmented LLRTs and the impact which would result if the tests were performed during the upcoming October 1989

' outage. The length of the requested extension and the previous history of the components provides reasonable assurance that excessive leakage will not occur prior to the next tests which will be performed durihg RFO-8; and that there will be no significant changes in the types or amounts of effluents that may be released offsite.

The Commission has concluded, based on the above, that there are no significant radiological environmental impacts associated with the proposed exemptions, and in fact would reduce the amount of radwaste generated and reduce exposure of workers to radiation.

With regard to potential nonradiological impacts, the proposed exemptions involve features located entirely within the restricted areas as defined in 10 CFR Part 20.

It does not affect nonradiological plant effluents and has no other environmental impact. Therefore, the Commission concludes that there are no significant nonradiological environmental impacts associated with the proposed exemptions.

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Alternative.to the Proposed Action:

Since the Commission has concluded there are no measurable environmental impacts associated with the proposed exemptions, any alternatives with equal or greater environmental impact need not be evaluated. The principal alternative to the exemptions would be to require rigid compliance with the applicable portions of Sections III.A.6(b), III.D.2(a) and III.D.3 of the Appendix J requirements. Such action would not enhance the protection of the environment and would result as unjustified worker exposure and cost for the licensee.

' Alternative Use of Resources:

This action does not involve the use of any resources not considered previously in the Final Environmental Statement related to the operation of Pilgrim Nuclear Power Station.

Acencies and-Persons Consulted:

The NRC staff reviewed the licensee's request and did not consult other agencies or persons.

FINDING OF NO SIGNIFICANT IMPACT -

The Commission has determined not to prepare an environmental impact statement for the proposed exemptions. Based upon the foregoing environmental assessment, the NRC staff concludes that the proposed action will not have a significant effect on the quality of the human environment.

For further details with respect to this proposed action, see the licensee's letters dated July 7 and September 1,1989. The letters are available for public inspection at the Commission's Public Document Room, l

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Gelman Building, Lower Level

'20 L Street, N.W., Washington, D.C. and at the Plymo'uth Public Library,11 North Street, Plymouth, Massachusetts.

D :ted at Rockville, Maryland this 19th day of September 1989.

FOR THE MUCLEAR REGULATORY COP 9 FISSION WN Richard H. Wes %sman, Director Project Directorate I-3 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation 6

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