ML20248D859
| ML20248D859 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 09/28/1989 |
| From: | POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | |
| Shared Package | |
| ML20248D843 | List: |
| References | |
| JPTS-89-025, JPTS-89-25, NUDOCS 8910040422 | |
| Download: ML20248D859 (7) | |
Text
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ATTACHMENT 11 TO JPN PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING CONTAINMENT LEAK RATE TESTING (JPTS-89-025)
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New York Power Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT o
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ATTACHMENT 111 TO JPN -
SAFETY EVALUATION FOR PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING CONTAINMENT LEAK RATE TESTING
' (JPTS-8S025) l 1
New York Power Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 DPR-59
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4 Attachment til to JPN -
SAFETY EVALUATION Page 1 of 4 1.
DESCRIPTION OF THE PROPOSED CHANGES The proposed changes to the James' A. FitzPatrick Technical Specifications revise the note associated with Specification 4.7.A.2.f on page 174.
. The note is ch'anged to read as follows:
- In accordance with an exemption from 10 CFR 50 Appendix J, a Type A, B, or C test is not required for: 1. The repair of the HPCI turbine exhaust line block valve (23-HPI 11) during the 1988 refueling outage; or 2. The repair of the Core Spray test return line weld 1014-884A during the 1989 maintenance outage.
In addition, the associated asterisk has been relocated to the section heading for Specification 4.7.A.2.f.
II.
PURPOSE OF THE PROPOSED CHANGES The purpose of the proposed change is to eliminate 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 an Type A ILRT as otherwise required. This weld cannot be isolated to allow performance of either a Type B or C local leak rate test. Compensatory measures include an alternate inspection program, consisting of 100% radiography, surface examination, and an in-service functional test to ensure the structural integrity and leak tightness of the weld.
The proposed changes to the Technical Specifications are required prior to start-up from the current maintenance outage. The Authority plans to end the current outage on October 3,1989 which is less than 30 days from the date of this application. The Authority requests that this application for emendment be processed on an emergency basis under the provisions of 10 CFR 50.91(a)(5) since insufficient time exists to provide for a 30 day public comment period without preventing the resumption of power operation.
l 111.
IMPACT OF THE PROPOSED CHANGES The most significant impact of the proposed change would be to allow the FitzPatrick plant to restart following the completion of the current mid-cycle maintenance outage. Performance of compensatory NDE (non-destructive examination) testing of the we!d recair in lieu of a leakage test as required by the Technical Specifications on the repaired weld has no impact on the safety of the plant and is technically justifiable as discussed below.
The construction code applied to the original installation and repair of the weld, ANSI B-31.1-1967 with Addenda A, prescribes the post-repair testing requirements. Section 127.4.7 states that "the types, extent and method of examination and limits of imperfections of repair welds shall be the same as for the original weld." The original testing requirements are contained in Table 136.5.1, " Mandatory Minimum Nondestructive Tests for Welds." For this weld repair, the
Attachment ill to JPN
- SAFETY EVALUATION Page 2 of 4
]
code does not require radiography or surface examination. Section 137.1 does, however, require that leak tightness be demonstrated. This section states.
i 11 shall be mandatory that the design, fabrication, and erection of power piping, l
constructed under this Code demonstrate leak tightness. This requirement shall be met by a hydrostatic leak test prior to initial operation. Where a hydrostatic i
test is not practicable, an initial service leak test, a vacuum test, or 100 per cent i
radiography of all welded joints in an all welded system may be substituted.
[ emphasis added]
The Authority will perform 100% radiography of the repaired weld in lieu of the hydro-test as stated above. In addition to the requirements of the code, a surface examination and an in-service functional test will be perforrned. This assures that no surface flaw exists which could lead to a leakage path. These non-destructive examinations meet the intent of the existing Technical Specification 4.7,A.2.f which is to assure that modifications to the containment pressure boundary are leak-tight.
This situation is very similar to one the Authority experienced in 1988 concerning the replacement of the HPCI turbine exhaust line manual block valve (23-HPI-11). The Authority identified the fact that replacement of this valve would create a new weld in the primary containment pressure boundary which could not be local leak rate tested. The Authority amended an existing exemption request on July 14,1988 (Reference 3) and requested an amendment to the Technicai Specifications on November 9,1988 (Reference 4) to allow installation of this valve without having to perform a Type A ILRT. These requests were granted by the NRC in References 5 and 6 respectively.
The Authority performed a comprehensive review of alternate methods of performing a local leak rate test for the 1988 replacement of the HPCI valve which is provided in Attachment I to Reference 3. In that report, it was concluded that no valid method was found to be practicable.
This discussion is applicable to the current weld repair since the piping configuration is similar.
IV.
EVALUATION OF EMERGENCY SITUATION As stated in Section ll above, the Authority requests that this application for amendment be processed on an emergency basis under the provisions of 10 CFR 50.91(a)(5), since insufficient time exists to allow for a 30 day public comment petxi without delaying the resumption of power operation.
10 CFR 50.91(a)(5) defines an emergency situation as:
" failure to act in a timely way would result in derating or shutdown, or in prevention of either resumption of operation or of increase in power output up to the plant's licensed power level." [ emphasis added]
l The proposed Technical Specification change is required to allow FitzPatrick to resume power i
operation following the current maintenance outage. If the amendment is not issued, operation of FitzPatrick would be delayed. If the Authority was required to perform an ILRT prior to startup, i
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 l
}
! 11 to JPN
- SAFETY EVALUATION Page 3 of 4
(
laboratory for calibration. Conducting an ILRT would delay startup several weeks and several million dollars in revenues would be lost.
10 CFR 50.91(a)(5) requires the Authority to address the following concern before the NRC can make a determination that an emergency condition exists:
"Whenever an emergency situation exists, a licensee requesting an amendment must explain why this emergency situation occurred and why it could not avoid this situation..."
This emergency situation developed as a result of in-service inspections carried out during the current mid-cycle maintenance outage. UT and RT testing as part of an augmented ISI program has revealed the presence of a slag inclusion w thin weld 10-14-884A on the Core Spray system i
test return line (10"-W23-152-98). This weld was created as part of the plant's initial construction.
At that time,100% volumetric examination was not required for this particular weld location and the defect went undetected. It was not anticipated that a weld which previously passed all required examinations, and which is not suseptible to IGSCC, would be found with a defect such that immediate repair would be necessary.
V.
EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION Operation of the FitzPatrick Plant in accordance with the proposed Amendment would not involve a significant hazards consideration as stated in 10 CFR 50.92 since it would not:
1.
Involve a significant increase in the probability or consequences of an accident previously evaluated. The repair of the Core Spray weld will improve the structural capability of the existing weld. It is required that weld flaws, such as the one identified, be repaired prior to plant operation. The proposed change allows repair of the weld without performing a leakage test as currently required by the Technical Specifications. Compensatory measures include 100% radiography of the repaired weld to assure the structural integrity of the weld and surface examination to detect any surface flaws which could lead to leakage paths. This weld forms part of the containment pressure boundary. Since the structural integrity of the containment pressure boundary through the weld is assured, no change is made to the probability of occurrence or consequences of any accident previously evaluated.
2.
create the possibility of a new or different kind of accident from any accident previously evaluated. Not performing an ILRT this outage cannot initiate any type of accident. The repair of the weld restores the Core Spray piping to its original design and structural capability. The weld repair and associated testing cannot initiate any type of accident.
3.
involve a significant reduction in a margin of safety. Performance of 100% radiography in lieu of a pneumatic leak rate test on the weld repair is consentative. The construction code (ANSI B-31.1-1967) allows for 100% radiography as an alternative to leakage testing when such testing is not practicable. There is no reduction of any margin of safety.
VI.
IMPLEMENTATION OF THE PROPOSED CHANGE k
y -
f
- Attachment lil' to JPN a
'~
SAFETY EVALUATION q
Page 4 of 4 i
implementation of the proposed changes will not impact the ALARA or Fire Protection Programs at FitzPatrick, nor will the changes impact the environment.
L Vil.
CONCLUSION The change, as proposed, does not constitute an unreviewed safety question as defined in 10 CFR 50.59. That is, it:
a.
will not change the probability nor the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the Safety Analysis Report; b.
will not increase the possibility of an accident or malfunction of a different type from any previously evaluated in the Safety Analysis Report; c.
will not reduce the margin of safety as defined in the basis for any technical specification; d.
does not constitute an unreviewed safety question; and e.
involves no significant hazards consideration, as defined in 10 CFR 50.92.
Vill.
REFERENCES 1.
James A. FitzPatrick Nuclear Power Plant Updated Final Safety Analysis Report.
2.
James A. FitzPatrick Nuclear Power Plant Safety Evaluation Report (SER), dated November 20,1972, and Supplements.
3.
NYPA letter, J.C. Brons to the NRC, dated July 14,1988 (JPN-88-033), regarding a Request for Exemption from Containment Integrated Leak Rate Test - Retest Schedule.
4.
NYPA letter, J.C. Brons to the NRC, dated November 9,1988 (JPN-88-060), regarding a Proposed Change to the Technical Specifications Regarding Containment Leak Rate Testing.
5.
NRC letter, D.E. LaBarge to J.C. Brons, dated November 16,1988, granting an exemption from Appendix J.
6.
NRC letter, D.E. LaBarge to J.C. Brons, dated February 17,1989, issuing Amendment 125 to the FitzPatrick Technical Specifications.
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