ML19323F209

Forwards Addl Info Re Containment Leakage Testing,Per NRC 800404 Request.Info Supports Application to Amend Tech Specs to Authorize Exemption from App J Requirements

ML19323F209
Person / Time
Site:	Fort Calhoun
Issue date:	05/15/1980
From:	William Jones OMAHA PUBLIC POWER DISTRICT
To:	Clark R Office of Nuclear Reactor Regulation
References
TAC-8910, NUDOCS 8005280652
Download: ML19323F209 (11)

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Omaha Public Power District .

1623 HARNEY a OMAHA. NE5RASKA 68102 e TELEPHONE 536 4000 AREA CODE 402 May 15, 1980 Mr. Robert A. Clark, Chief U. S. Nuclear Regulatory Commission Operating Reactors Branch No. 3 Division of Licensing Washington, D. C. 20555

Reference:

Docket No. 50-285

Dear Mr. Clark:

The Omaha Public Power District received the Commission's letter dated April 4, 1980, requesting additional information in support of the District's Application for Amendment to Technical Specifications, Appendix A to Facility Operating License DPR-40 for the Fort Calhoun Station Unit No.1, for exemption from Appendix J requirements. The attached docu-ment is submitted in response to the Commission's letter.

Sincerely, f '

W. C. Jones Division Manager -

Production Operations WCJ/KJM/BJH/TLP:jmm Attach.

cc: LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N. W.

Washington, D. C. 20036 i

Y%'

8005280652

REQUEST FOR ADDITIONAL INFORMATION FORT CALHOUN STATION UNIT NO. 1 ' -

IMPLEMENTATION OF 10 CFR 50 APPENDIX J CONTAINMENT LEAKAGE TESTING Information Required

1. Containment Air Lock Testing Article 3.5(3)d states that the results of personnel access lock door seal tests at 5 psig shall be conservatively extrapolated to a leakage rate at 60 psig. Describe the extrapolation method to be used.

Response

The extrapolation method to be used shall be ASME Section 11. IVW-3420, #5. Assuming a " square edged orifice", one can use the following formula to determine the leakage rate at 60 psig:

L60 = Leakage rate at 60 psig LTEST = Leakage rate during test PD = Desired pressure of 60 psig PTEST = Test pressure normally 5 psig L60 " LTEST PTEST

=

74.7 . LTEST = 1.95 . LTEST 19.7 ,

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2. Type B Testing , ,

Article 3.5(3)e lists penetrations to be subjected to Type B testing. Identify all containment penetrations, and provide a justi-fication for each omission from the Type B testing requirements of Appendix J.

Response

Attached is the list of all containment penetrations and other containment boundary seals. These penetrations and boundary seals are to be tested under Type B testing. Table 2 provides a complete list of mechanical penetrations with associated isolation valves.

Two items, steam generator manways and steam generator handholes, are considered part of the containment boundary seals. However, these items are tested under Type C testing and not by Type B testing, the reason being seals on steam generator manholes and manways are more suitable for Type C testing.

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TABLE 1 CONTAINMENT PENETRATIONS AND BOUNDARY SEALS

1. Equipment Hatch

2. Personnel Access Lock

3. Fuel Transfer Tube ,

4. Mechanical Penetrations M-1 througn M-99 and M-HCV-383-3 and M-HCV-383-4

5. Steam Generator Manways

6. Steam Generator Handholes

7. Electrical Penetrations A-1 B-9 D-6 F-2 E-HCV-383-3A A-2 B-10 0-7 F-4 E-HCV-383-3B A-4 B-11 D-8 F-5 E-HCV-383-4A A-5 C-1 D-9 F-6 E-HCV-383-4B A-6 C-2 D-10 F-7 A-7 C-4 D-11 F-8 A-8 C-5 E-i F-9 A-9 C-6 E-2 F-10 A-10 C-7 E-4 F-11 A-11 C-8 E-5 G-1 B-1 C-9 E-6 G-2 B-2 C-10 E-7 G-3 ~

B-4 C-11 E-8 G-4 B-5 D-1 E-9 H-1

! B-6 D-2 E-10 H-2 B-7 D-4 E-11 H-3 B-8 D-5 F-1 H-4 9

TABLE 2 MECHANICAL PENETRATIONS Containment Penetration System Isolation Valve M-1 M-2 Letdown TCV-202, HCV-204 M-3* Charging Pump M-4 M-5* HPSI M-6* HPSI

M-7 RC Pump Bleedoff HCV-206, HCV-241 M-8 Containment Sump HCV-506A, HCV-506B M-9* SG 2B Blowdown M-10* SG 2B Blowdown M-11 CC Water to Nuclear Detector Well HCV-467A/B M-12* SG 2A Blowdown M-13* SG 2A Blowdown M-14 Vent Header (Waste Gas) HCV-507A, HCV-207B M-15 CC Water to Nuclear Detector Well HCV-467C/D M-16* Shutdown Cooling M-17* SI and Shutdown Cooling M-18 CC Water from RC Pump Coolers HCV-438A/B M-19 CC Water from RC Pump Coolers HCV-438C/D 4

M-20 RC Drain Tank Discharge HCV-500A/B M-21 M-22 SI to and from Leakage Coolers SI-185, HCV-2983, PCV-2909, HCV-2916, .

PCV-2929, HCV-2936, PCV-2969 M-23 M-24 P*essurizer Quench Tank Sample HCV-509A/B M-25 RC Drain Tank Sample HCV-508A/B M-26 M-27 M-28 M-29 M-30 Hydrogen Purge Line HCV-882, VA-289 M-31

• M-32 M-33 M-34 M-35 M-36 M-37 M-38 Containment Pressure M-39 SI Cooler Line HCV-425A/B M-40 M-41 M-42 Nitrogen Supply HCV-2603A/B

-5 TABLE 2 '

MECHANICAL PENETRATIONS (Continued)

Containment Penetration System Isolation Valve M-43 Nitrogen Supply HCV-2604A/B M-44* Pressurizer Pressure Dead Weight Tester M-45 RC Sample Line HCV-2504A/B M-46 Containment Air Sample PCV-742E/F M-47 Containment Air Sample PCV-742G/H M-48 Containment Pressure Relief HCV-746A/B M-49* SG Blowdown Sample M-50 Containment Pressure Relief M-51 Containment Pressure Relief M-52 Containment Pressure Relief M-53 SI Cooler HCV-425C/D M-54 M-55 M-56 M-57 Hydrogen Detection Line M-58 Hydrogen Detection Line M-59 M-60 M-61 M-62 M-63* Blowdown from RC-2A Sampling M-64 M-65 ,

M-66 M-67 M-68 M-69 . Hydrogen Purge HCV-881, VA-280 M-70 M-71 M-72 M-73 Instrument Air PCV-1849 M-74 Service Air HCV-1749 i M-75* Fan Coolers l M-76* Fan Coolers M-77* Fan Coolers '

M-78* Fan Coolers l M-79 DI Water Supply HCV-1560A/B

! M-80 DI Water Supply HCV-1559A/B M-81 M-82* Fan Coolers M-83* Fan Coolers M-84* Fan Coolers

M-85* Fan Coolers l M-86 SI Spray M-87 Containment Air Purge PCV-742A/B M-88 Containment Air Purge PCV-742C/D

TABLE 2 MECHANICAL PENETRATIONS (Continued)

Containment Penetration System Isolation Valve M-89 Safety Injection Spray M-90 M-91* Auxiliary Feedwater to SG-2B M-92 M-93* Feedwater M-94* Main Steam M-95* Main Steam M-96* Feedwater M-97* Auxiliary Feedwater to SG-2A M-98 M-99 M-100* Fuel Transfer Tube M-HCV-383-3 SI Sump HCV-383-3 M-HCV-383-4 SI Sump HCV-383-4 O

3. Type C Testing Article 3.5(4)f lists valves to be subjected to Type C testing.

Provide a complete list of containment isolation valves. Identify those valves not subjected to normal Type C testing, and provide justification for:

1. Valves not being tested.

2. Valves being tested in the reverse direction.

3. Valves being tested with water in lieu of air or nitrogen.

Response

Table 2 provides a complete list of mechanical penetrations and associated isolation valves.

The penetrations not associated with any system are blanked off.

Hence, these penetrations do not require any Type C testing.

1. The penetrations marked with an asterisk (*) are not tested under Type C testing. The valves associated with these penetrations are normally required for safe shutdown of the plant and/or are not activated by the containment isolation actuation signal. These valves are normally part of a closed loop system and do not meet the testing requirements set forth in Apper, dix J of 10 CFR 50.

Valves associated with penetrations M-16 (shutdown cooling),

M-86 (containment spray), and M-89 (containment spray) are part of the core cooling / safety injection system. In the .

event of a DBA (LOCA) these systems will operate. In addi-tion, the pressure seen by the isolation valves in the direc-tion of flow toward the containment building will always be greater than the maximum containment pressure Pa (60 psig).

Valves associated with penetrations M-91 and M-97 are emer-gency feedwater systems. These valves open on containment isolation and are not required to be tested in 10 CFR 50 Appendix J.

Valves associated with penetrations M-94 and M-95 are on the main steam line. These receive a close signal from low steam '

generator pressure or containment pressure high and not con-tainment isolation signal. Their function is to prevent an uncontrolled heat extraction. They are not required to be tested under 10 CFR 50 Appendix J.

Penetration M-100 is the fuel transfer tube. This penetration is tested in accordance with Type B test procedures.

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The remaining valves associated with penetrations M-9, M-10, M-12, M-13, M-49, M-63, M-93, and M-96 are associated with the -

secondary side of the steam generators. Although the penetra-tion isolation valver are closed on a containment isolation signal as an added precaution (with the exception of M-9 and M-12 whose valves are manually operated, locked closed) the steam generator shell is a containment boundary and no testing is required for such closed systems. Due to the method of operation of the emergency feedwater and main steam penetra-tion, the valves associated with the secondary side of the steam generators were not designed for external leak tight-ness, rather the steam generator shell is the containment boundary.

2. Valves being tested in the reverse direction. The valves listed below are valves that will be tested in a direction opposite to that which pressure would be applied during an ac-cident. A justification for testing of each of these valves is also provided.

Associated Refer to Valve No. Penetration Justification No.

TCV-202 M-2 1 HCV-241 M-7 1 HCV-506A M-8 2 HCV-467A M-15 4 HCV-467C M-11 '

'l HCV-507A M-14 2 HCV-438A M-19 4 HCV-438C M-18 1 HCV-5008 M-20 2 ~

HCV-545 M-22 4 HCV-2916/2936/2956/2976 M-22 1 PCV-2909/2929/2949/2969 M-22 1 HCV-509A .. M-24 2 HCV-508A M-25 2 HCV-882 M-30 3 HCV-425A M-39 4 HCV-425C M-53 1 HCV-2603B M-42 4 HCV-2604A M-43 4 HCV-2504A M-45 1 HCV-883A M-57 2 HCV-1560A M-79 4 HCV-1559A M-60 4 PCV-742A M-87 3 PCV-742C M-88 3 NOTE: Determination of valves tested in a direction opposite to that which pressure would be applied during an accident was made using the valve line-ups of Surveillance Test CONT-3/ Revision 8.

l Justification l

1) All valves referenced to this justification are globe valves. The 60 psig test pressure applied to these valves during Type C leak rate tests is applied above the seat / plug of these valves and tends to help close the valve. However, due to the large pre-set spring compression force of all of these valves (except HCV-438C), in comparison to the force created by the application of the 60 psig test pressure against the seat / plug, it is justifiable to say that the force difference which results from testing above the seat as opposed to below the seat is negligible when compared to the closing force / spring compression force of these valves. NOTE: All valves referenced to this justification, with the exception of HCV-438C, are " fail-closed" valves and, as such, rely on the pre-set spring force for closure during accident conditions. In the case of HCV-438C, the air applied to the diaphrams will supply the plug with a closing force much larger than the 60 psig test pressure resultant force. Therefore, it is again justifiable to test above or below the seat since the closing force of this valve is large.

2) All valves referenced to this justification are Hills McCanna diaphram valves. Testing of Hills McCanna diaphram valves in the reverse direction is considered to be an equivalent method of leak testing due to ~che structural symmetry of the valve and its internal diaphram design. Manufacturers have stipulated that leakage through these valves will be the same regardless of the direction of flow through the valve.

3) All valves referenced to this justification are butterfly valves.

Information obtained from the valve manufacturers (Fisher Controls for HCV-881/882 and Allis Chalmers for PCV-742A/C) has revealed that leakage testing of these valves will be equivalent regardless -

of the direction of flow through the valve. Leakage from these valves is independent of flow direction due to the valve and seating surface symmetry. In addition,Section XI of the ASME Code " Inservice Inspection of Nuclear Power Plant Components",

Section IWV-3420 " Valve Leak Rate Test" is for leak testing of butterfly valves in either direction, provided tha seat construction is designed for sealing against pressure on either side.

4) All valves referenced to this justification are tested in a manner which tends to lift the valve. However, in all cases the accident pressure applied to these valves will tend to help seat the valves.

Testing the valve this way is considered " conservative". ,

3. Valves being tested with water in lieu of air or nitrogen.

Listed below are the valves to be hydrostatically tested. -

Justification for these tests are:

a. Normal operation is with water filling the valves.

b. The valves would be filled with water during any accident.

Penetration Valve No.

M-16 HCV-347 M-12 FW-686 M-9 FW-687 o

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