ML20248D851
| ML20248D851 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 09/28/1989 |
| From: | Brons J POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | |
| Shared Package | |
| ML20248D843 | List: |
| References | |
| NUDOCS 8910040420 | |
| Download: ML20248D851 (4) | |
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u BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION
- In the Matter of -
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NEW YORK POWER AUTHORITY
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Docket No. 50-333 James A. FitzPatrick Nuclear Power Plant
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APPLICATION FOR AMENDMENT TO OPERATING IJCENSE Pursuant to Section 50.90 of the regulations of the Nuclear Regulatory Commission, the New York Power Authority, as holder of Facility Operating Ucense No. DPR-59, hereby applies for an Amendment to the Technical Specifications contained in Appendix A of this license.
The purpose of the proposed change eliminates the requirement for the Authority to perform a Type A primary containment integrated leak rate test (ILRT) during the 1989 maintenance outage due to the provision of Technical Specification 4.7.A.2.f. The proposed change allows the repair of weld 10-14-884A on the Core Spray system test return line (10"-W23-152-98), without having to perform a Type A ILRT as required by Technical Specifications. This weld cannot be isolated to allow performance of either a Type B or C localleak rate test.
The proposed change revises the note associated with Technical Specification 4.7.A.2.f on page 174.
Attachment I to this application contains a corresponding request for exemption from 10 CFR 50 Appendix J,Section IV.A. The proposed changes to the Technical Specifications j
are Attachment 11 to this application for amendment to the Operating Ucense. The Safety Evaluation for the proposed changes and exemption request is included as Attachment 111.
New York Power Authority hJohn C. Brons g'k Executive Vice President Nuclear Generation STATE OF NEW YORK COUNTY OF WESTCHESTER Subscribed d sworn to before me this A7 day of September 1989.
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ATTACHMENT I TO JPN EXEMPTION REQUEST CONTAINMENT LEAK RATE TESTING New York Power Authority l
JAMES A. FITZPATRICK NUCLEAR POWER PLANT l
Docket No. 50-333 l
DPR-59 J
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JAMES A. FITZPATRICK NUCLEAR POWER PL. ANT EXEMPTION REQUEST CONTAINMENT LEAK RATE TESTING In accordance with 10 CFR 50.12(a)(2)(ii), the New York Power Authority requests an exemption from 10 CFR 50 Appendix J,Section IV.A which states:
Containment modification. Any major modification,. replacement of a component which is part of the primary reactor containment boundary, or resealing a seal-welded door, performed after the preoperational leakage rate test shall be followed by either a Type A, Type B, or Type C test, as applicable for the area affected by the modification.
Minor modifications, replacements, or resealing of seal-welded' doors, performed directly prior to the conduct of a scheduled Type A test do not require a separate test.
In-service inspections conducted during the current mid-cycle maintenance outage has revealed the presence of a slag inclusion within weld 10-14-884A on the Core Spray system test return line (10"-W23-152-9B). In accordance with the requirements of ASME Section XI and ANSI B-31.1-1967 (the construction code for FitzPatrick) the weld is being repaired and reinspected prior to plant startup. The weld is located on a section of piping between the Core Spray test return valve (14MOV-26B) and the primary containment pressure suppression chamber (torus) shell and is part of the primary containment pressure boundary.
Although this type of repair to the containment pressure boundary is not specifically discussed in the regulation quoted above, the Authority considers that the intent of this regulation would require that the repair be Type A, B, or C tested as applicable. Because of the location of the weld repair, pressure testing can only be accomplished by performing a Type A primary containment integrated leakage rate test (ILRT).
This exemption would allow the repair of weld 10-14-884A on the Core Spray test line without '
having to perform an ILRT. The next Type A ILRT is scheduled to be conducted during the 1990 refueling outage.
10 CFR 50.12(a) indicates that the Commission may grant exemptions if special circumstances are present. Three of the special circumstances presented in 50.12(a)(2) apply to this situation.
Circumstance (ii) states:
Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the l
underlying purpose of the rule; The underlying purpose of 10 CFR 50 Appendix J,Section IV.A is to ensure that modifications to the containment do not result in unacceptable leakage. The Authority plans to conduct 100%
radiography, surface examination, and in-service functional tests of the weld repair to compensate for the lack of an ILRT. These examinations assure the structural integrity of the repair and the l'L
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lack of any surface' flaw through which a leakage path could develop. In combination, these examinations ensure zero leakage through the weld repair. Application of Appendix J requirements in these particular circumstances would not serve the purpose of the rule and are i
not necessary to achieve the underlying purpose of the rule.
Circumstance (iii) states:
Compliance would result on undue hardship or other. costs that are significantly in excess of those contemplated when the regulation was adopted, or that are significantly in excess of those incurred by others similarly situated.
The exemption from Appendix J is required to allow FitzPatrick to resume power operation following the current maintenance outage. If the exemption is not issued, operation of FitzPatrick would be delayed until such time that it is issued. If the Authority was required to perform'an ILRT prior to startup, this would effectively delay startup even further. Substantial lead time is required to rent the necessary equipment, perform Type B and C local leakage. rate tests on all containment penetrations, contract for, consultant personnel, and send instrumentation to an outside laboratory for calibration. Remaining shutdown for this extended time would result in a significant financial hardship to the Authority. The regulations originally considered that Type A ILRT tests would only be conducted as a planned evolution, typically during refueling or other long duration outages, and not as a result of a plant conditions discovered during the conduct of short (3 week) maintenance outages.
Circumstance (v) states:
The exemption would provide only temporary relief from the applicable regulation and the licensee or applicant has made good faith efforts to comply with the regulation.
The exemption is to be applied to a one time occurrence and constitutes only temporary relief. As evident by the ongoing containment isolation valve upgrade and extensive corrective action programs, the Authority not only complies with the requirements of Appendix J, it aggressively implements actions beyond the requirements to more completely meet the underlying purpose of the regulation. A corrective action plan to replace selected containment isolation valves was described in an April 12,1988 letter to the NRC (JPN-88-012).
Conclusion As stated above, the exemption would prevent an undue hardship to the Authority, avoid costs in excess of those contemplated in the regulation, and constitute only temporary relief from the regulations. The circumstances could not have been forseen or avoided. Therefore, the special circumstances defined 10 CFR 50.12(a)(2)(ii), (iii) and (v) for an exemption have been satisfied.
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