U-601117, Requests one-time Exemption from Requirements of 10CFR50, App J,Paragraph III.D.3 Re Surveillance Interval Requirement for Type C Local Leak Rate Tests for Containment Isolation Valves.Fee Paid

Requests one-time Exemption from Requirements of 10CFR50, App J,Paragraph III.D.3 Re Surveillance Interval Requirement for Type C Local Leak Rate Tests for Containment Isolation Valves.Fee Paid

ML20195H383
Person / Time
Site:	Clinton
Issue date:	01/13/1988
From:	Hall D ILLINOIS POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
DPH-0129-88, DPH-129-88, U-601117, NUDOCS 8801190289
Download: ML20195H383 (8)

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- U-601117 L30-88(01 -13 )-LP 1A.120 ILLIN0/8 POWER 00MPANY CLINTON POwtR STAtlON P.O. BOX 678, CLINTON, ILLINOl$ 61727 DPli-0129-88 January 13, 1988 10CFR50.12 Docket No. 50-461 Document Control Desk Nuclear Regulatory Commission Washington, D.C. 20555 Subj ect : Clinton Power Station Request for Exemption from 10CFR56, Appendix J, Leak Testing Requirements

Dear Sir:

Pursuant to 10CFR50.12, Illinois Power Company (IP) hereby requests exemption from the requirements of 10CFR50, Appendix J, paragraph III.D.3.

. IP requests one-time exemption from the two year surveillance interval requirement for Type C Local Leak Rate Tests for Containment Isolation Valves (CIVs) 1E12-F023, 1E51-F034, 1E51-F035, 1E51-F390, 1E51-F391, 1E12-F061, IE12-F062 and lE51-F013. Attachment 2 to this letter provides a description of the requested change, and response to regulatory requirements including the special circumstances required for commission consideration. An affidavit supporting certification accompanies this letter. The related Technical Specification change request was submitted in IP Letter

! U-601084 dated December 10, 1987.

In accordance with the provisions of 10CFR170.12 and 170.21, IP is enclosing a check made out to the Nuclear Regulatory Commission in the amount of $150.00 as payment of the application fee.

! Si ly ours, i

D. P. Hall Vice President l

GSL/krm Attachments l1

'}D 8801190289 880113 [8N d /

II I DR hDOCN 0500 1 g j o cj'/ 3 f i

- U-601117 L30-88 ( 01-13 )-LP 1A.120 cci NRC Resident Office NRC Region III, Regional Administrator NRC Clinton Licensing Project Manager Illinois Departinent of Nuclear Safety

. Attcchm:nt 1 to U,601117 STATE OF ILLIN0IS COUNTY OF DEWITT DONALD P. HALL, Being first duly sworn, deposes and says: That he is Vice President of Illinois Power Company:

that the provided information to certify that this request for exemption from the 10CFR50, Appendix J, paragraph III.D 3 leak testing requirements has been prepared under his supervision and directions that he knows the contents thereof and that to the best of his knowledge and belief said request and the facts contained therein are true and Correct.

DATED: This /CI day of anuar Signed:

D66ald'P. Hall Subscribedandsworntobeforemethis/Yo[dayofJanuary 1988.

Qx v P!

Notary Public 4G My commission expires:

"O F F I C l o '. S E A L" ttND A S Cuswa!st4IN NOTARY Pum.m. statt cr ttttweis NY COMMt:5.09 IxPIRES 21190

' Attachm2nt 2 to U-601117 Page 1 of 5 Description and Justification:

IP is requesting a one-time exemption to 10CFR50, Appendix J, paragraph III.D.3 for leak-rate testing of Containment Isolation Valves (CIVs), 1E12-F023, 1E51-F034, 1E51-F035, 1E51-F390, 1E51-F391, lE12-F061, 1E12-F062, and IE51-F013.

These CIVs were last tested on October 21, 1986, and would require testing by October 21, 1988. The first refueling outage at Clinton Power Station is scheduled for the spring of 1989. IP is requesting exemption from these testing requirements until the first refueling outage.

Requirements 10CFR50.12 (a) states:

"The Commission may, upon application by any interested person or upon its own initiative, grant exemptions from the requirements of the regulations of this part, which are -

(1) Authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security."

IP satisfies these requirements as follows:

(1) Authorized by Law:

If the criteria established in 10CFR50.12(a) are satisfied, as they are in this case, and if no other prohibition of law exists to preclude the activities which would be authorized by the requested exemption, and there is not such prohibition, then the Commission is authorized by law to grant this exemption request.

Will not present an undue risk to the public health and safety:

The effects of deferral of the requested Type C tests upon the potential for aost-accident leakage from the primary l

containment, and thus risk to the public health and safety, have been evaluated and are shown to be negligible. The following forms the basis for this conclusion:

The most recent test of the valves was performed satisfactorily. No significant increase in the probability of equipment failures is mostulated for a short, extended time-period effected by the deferred testing,

r -

Attcchm2nt 2 to U-601117 Page 2 of 5 The Local Leak Rate Testing provides verification of valve seating integrity and does not provide assurance that the valve actuates (either automatically or manually) to its isolation position.

Other surveillances are ,erformed to verify the isolation function for the applicable valves (1E51-F013 and 1E12-F023). The test intervals associated with these surveillances will not be affected by the proposed change.

The proposed change introduces no new modes of operation, failure modes or other changes to any equipment.

The requested extension does not significantly increase the specified surveillance frequency.

The requested amendment concerns schedule relief for surveillance 'esting of a very limited number of containment isolation valves associated with only one containment penetration.

Leak test acceptance criteria are not affected by the proposed change.

Consistent with the common defense and security:

The common defense and security are not implicated in this exemption request. Only the potential impact on public health and safety is at issue.

Special Circumstances 10CFR50.12.(a).(2) requires:

"The Commission will not consider granting an exemption unless special circumstances are present. Special circumstances are present whenever -

(i) Application of the regulation in the particular circumstances conflicts with other rules or requirements of the Commissions or (ii) Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rules or (iii) Compliance would result in 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: or (iv) The exemption would result in benefit to the public health and safety that compensates for any decrease in safety that may result from the grant of the exemptions or

- Attcchm:nt 2 to U-601117 Page 3 of 5 (v) The exemption r,uld provide only temporary relief from the aaplicable regulation and the licensee or applicant Tas made good faith efforts to comply with the regulations or (vi) There is present any other material circumstance not considered when the regulation was adopted for which it would be in the public interest to grant an exemption. If such condition is relied on exclusively for satisfying paragraph (a)(2) of this section, the exemption may not be granted until the Executive Director for Operations has consulted with the Commission."

IP meets the following special circumstances:

50.12.(a).(2) (i) Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule:

The purpose of 10CFR50 Appendix J testing is to assure that (a) leakage through the primary reactor containment and systems and components penetrating primary containment shall not exceed allowable leakage rate values as specified in the Technicel Specifications or associated bases and (b) periodic surveillance of reactor containment penetrations and isolation valves is performed so that proper maintenance and repairs are made during the service life of the containment, and systems and components penetrating primary containment.

The containment leakage rate is primarily affected by equipment wear and maintenance. Isolation valves typically see little usage (especially test connections, vents and drain valves) except for periodic operability testing. This leads to little degradation of equipment or increase in the leakage rate. From October 21, 1988 to the spring 1989 refueling outage, these valves will be subjected to minimal wear.

Redundancy regarding primary containment isolation is provided by two isolation valves in series or one isolation valve bounded by a closed loop outside containment. Consequently, a reduction in the effectiveness of one valve to provide a seal would not itself compromise containment integrity.

Deterioration of the overall integrity of the containment penetrations is normally a gradual arocess. Considering the redundancy of the isolation 3arriers, the short duration of the requested extension of the testing interval and the limited number of valves affected, any reduction in the containment integrity during the extension period would be negligible.

Attcchm:nt 2 to U-601117 Page 4 of 5 These valves have not required maintenance since last tested on October 21, 1986. These valves are tested during cold shutdown, and to date, data from past testing shows leakage to be well within acceptable limits. Similar valves will be tested during the spring 1988 maintenance outage, and any excessive leakage or other degraded valve conditions indicative of a generic condition will be evaluated at that time. An internal commitment has been initiated to ensure this task is completed.

50.12.(a),(2) (iii) Compliance would result in 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:

Performing the leak testing on these valves will require the removal of the drywell head and the disassembly of the reactor head spray piping to allow installation of a blind flange as an inboard test boundary. Reassembly of the reactor head spray

?i ping will require that a reactor coolant system soundary leakage test be performed in accordance with the ASME code. IP estinates that these tasks would extend the spring 1988 maintenance outage by about one week, and cause additional personnel exposure of approximately one to two Man-Rem.

The first refueling outage is scheduled for the spring of 1989. Drywell head removal and a reactor coolant boundary leakage test will be required during this outage. Leak testing of these Containment Isolation Valves will also be performed during this outage in order to bring the test schedule for these valves into alignment with the fuel cycle.

Therefore, the time to perform the required testing has been accounted for in planning the first refueling outage.

Several other nuclear utilities have been granted temporary relief from 10CFR50 Appendix J paragraph III.D.3 for reasons very similar to those outlined in this request.

Attachment 2 to U-601117 Page 5 of 5 50.12.(a),(2) (v) The exemption would provide only temporary relief from the applicable regulation and the licensee or aaplicant has made good faith efforts to comply with t'Te regulation:

IP is requesting a temporary exemption to the requirements of 10CFR50 Alpendix J paragraph III.D.3 <

for a limited number (eigLit) of Containment Isolation Valves. All other Containment Isolation Valves at CPS are in compliance with these requirements. IP will be in complete compliance with 10CFR50 Appendix J paragraph III.D.3 after startup from the first refueling outage.

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