ML20079S215
| ML20079S215 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 10/21/1994 |
| From: | Stratman R CENTERIOR ENERGY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20079S216 | List: |
| References | |
| NUDOCS 9410270016 | |
| Download: ML20079S215 (13) | |
Text
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CENTEMOR ENERGY PERRY NUCLEAR POWER PLANT Mail Address:
Robert A.Stratman 10 CENTER ROAD RR, O 10 44081 PERRY, OHIO 44081 (216) 259-3737 October 21, 1994 PY-CEI/NRR-1651L U. S. Nuclear Regulatory Commission Document Control Desk Vashington, D. C. 20555 Perry Nuclear Power Plant Docket No. 50-440 Request for Exemptions From Type A and C Testing Requirements of 10 CFR 50 Appendix J Gentlemen:
Pursuant to the requirements of 10 CFR 50.12, several exemptions to portions of the Type A containment integrated leakage rate testing criteria and Type C local leak rate testing criteria within 10 CFR 50 Appendix J, " Primary Reactor Containment Leakage Testing for Vater-Cooled Power Reactors" are requested for the Perry Nuclear Power Plant (PNPP), Unit 1. contains a discussion of the basis for the proposed Type A and C testing exemptions. Attachment 2 provides proposed Technical Specification Bases changes to incorporate the exemptions following their approval.
In conjunction with this letter, a Technical Specification change request is also being submitted (see letter PY-CEI/NRR-1650L, dated October 21, 1994).
If you have questions or require additional information, please contact Mr. James D. Kloosterman, Manager - Regulatory Affairs at (216) 280-5833.
Very truly yours,
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SUMMARY
This exemption request proposes several exemptions from the Type A and C testing requirements of 10 CFR 50 Appendix J, " Primary Reactor Containment Leakage Testing for Vater-Cooled Power Reactors." Each of the proposed l
exemptions are independent of each other and may be implemented separately.
The following exemptions are proposed:
A)
An exemption is requested to formalize the approval (included in Technical Specification (TS) Limiting Condition for Operation (LCO) 3.6.1.2) to allow the main steam line isolation valve leakage to be accounted for separately from other pathways. The exemption is from the acceptance criteria of Paragraphs III.A.5(b)(2), III.B.3, III.C.3, and III.A.1(d)) of 10 CFR 50 Appendix J to indicate that 1) the main steam line leak rates are exempted from inclusion in the overall integrated i
primary containment leak rate (or Type A test total); ii) the main steam line leak rates are exempted from inclusion in the combined local leak rate summation (0.6 L for Type B and C testing); and clarify that the main steam lines are n,ot required to be vented and drained for Type A testing.
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B)
An exemption is requested to the 10 CFR 50 Appendix J. Paragraph III.D.1(a) requirement (included in the TS as Surveillance Requirement (SR) 4.6.1.2.a), that the third containment Integrated Leak Rate Test (the ILRT or Type A test) in each 10-year service period be conducted in conjunction with the 10-year inservice inspection. This change is also included in the proposed Appendix J rule changes currently under consideration.
C)
An exemption is requested to the 10 CFR 50 Appendix J, Paragraph III.D.3 requirement (this requirement is not included in the TS), that implies that Type C testing is only allowed to be performed during a reactor shutdown for refueling. This exemption vould allow Type C local leak rate tests to be performed at "other convenient intervals" in addition to during a reactor shutdown for refueling. This is consistent with the l
current Type B testing requirements of Appendix J, and is also included j
in the proposed Appendix J rule changes (for Type C tests) currently I
under consideration. Note that this does not affect the Appendix J requirement that local leak rate testing be performed at intervals no greater than 2 years.
In conjunction with the proposed exemptions to 10 CFR 50 Appendix J cited above, TS changes are being requested for items A and B (see letter PY-CEI/NRR-1650L).
- s PY-CEI/NRR-1651L Page 2 of 12 JUSTIFICATION FOR GRANTING THE EXEMPTION REQUESTS The specific requirements for granting exemptions from Part 50 regulations are set forth in 10 CFR 50.12, " Specific Exemptions".
Under Section 50.12 the Commission is authorized to grant an exe.nption upon a demonstration that the exemption: (a) is authorized by lav, (b) vill not present an undue risk to the public health and safety, (c) is consistent with the common defense and security, and (d) special circumstraces exist.
A detailed technical justification is presented for eruh of the proposed exemptions and then the specific requirements of 10 CFP 50.12 for each exemption are addressed. These justifications demonstrate tb4t the Commission should grant the requested exemptions.
Part A - Formalize the Aprroval for Excluding the Main Steam Line Isolation Valve Leakages from Inclusion in 1) the Overall Integrated Primary Containment Leak Rate and 11) the Combined Local Leak Rate, and Clarify that the Main Steam Lines are Not Required to be Vented and Drained for Type A Testing The primary objective of 10 CFR 50 Appendix J is to specify an acceptable methodology for testing the primary containment and, through this testing, determine the leakage rate is within the acceptance criteria cited in the licensing basis in order to verify that it is capable of maintaining its I
leak-tight integrity during normal and post-accident conditions.
Leakage rate acceptance criteria are based on leakage rate assumptions used in calculation of total radiological consequences for 10 CFR 100.
Since Appendix J vas originally envisioned, alternative means of meeting the objective of these requirements have been developed. These alternatives provide an equivalent level of protection of the public health and safety.
Since some of these alternatives deviate from the specific wording of Appendix J, an exemption is appropriate to recognize these alternatives.
Specifically, implicit in the Final Safety Analysis Report (FSAR) treatment of the main steam line leakage, as well as in the TS requirements for main steam line leakage, are deviations from several requirements of 10 CFR 50 Appendix J associated with Type A and C leakage rate testing. Although PNPP's methods and practices for Appendix J testing have been previously described in correspondence to the NRC dated July 26, 1985 (letter PY-CEI/NRR-0292L, M. R. Edelman (CEI) to B. J.
Youngblood (NRC)), formal approval of exemptions to Appendix J vere not requested. Recently, however, it was recognized that due to the NRC Staff legal interpretation described in the NRC Inspection and Enforcement Manual, Part 9900: "CFR Discussions, Containment Integrated Leak Rate Testing", and due to the specific wording of Appendix J, a formal exemption is appropriate to document the approvals previously received.
An exemption, therefore, is being formally requested to Paragraphs III.A.5(b)(2), III.B.3 and III.C.3, and III.A.l(d) of 10 CFR 50 Appendix J.
Detailed justifications for the exemption to these paragraphs of Appendix J is provided in the following.
10 CFR 50 Appendix J implies that the overall integrated primary containment leak rate consists of the leakage through all the primary containment penetrations. No allovance is currently provided within Appendix J for alternative means to address leakage pathways having different leakage treatment provisions (and resulting radiological effects) than those considered at the time Appendix J vas envisioned.
However, with respect to leakage from the main steam lines, the PNPP utilizes the criteria described in the Standard Review Plan, Section 15.6.5, Appendix D, " Radiological
PY-CEI/NRR-1651L Page 3 of 12 Consequences of a Design Basis Loss-of-Coolant Accident:
Leakage from Main Steam Isolation Valve Leakage Control System", (Rev. 1 - July 1981). The assumptions used in the PNPP FSAR in computing the total radiological consequences from a hypothetical LOCA include separate contributions for the containment leak rate and the main steam line isolation valve leak rate. The value for the maximum allowable containment leak rate, L of 0.2%/ day, was established based on this separate accounting for the main steam line isolation valve leak rate. The allowable value for the main steam line isolation valve leak rate of 25 standard cubic feet per hour /steamline is a separate and distinct requirement which was incorporated in the PNPP TS during initial PNPP licensing. The contributions for each leak rate are explicitly described in the PNPP FSAR as well as the NRC's Safety Evaluation Report (SER) l (NUREG-0887). This alternative NRC approved method for assessing the mnin steam line isolation valve leakage contribution and determining the radiological consequences was developed after issuance of 10 CFR 50 Appendix J, and consequently Appendix J does not explicitly recogni:
the j
approach presented therein. Therefore, based on the separate treatx of the main steam line isolation valve leakage from the rest of the containment l
leakage, an exemption to various Paragraphs of 10 CFR 50 Appendix J is necessary.
The first Appendix J requirement (from item A(i) cited above) for which an l
exemption is sought to reinforce the methodology and approval cited in the PNPP licensing basis is Paragraph III.A.5(b)(2). Therein is stated that "The leakage rate L shall be less than 0.75 L." The inference of these words is that this limii*vould apply to all leakage" paths including the ma'n steam l
lines. At PNPP however, the separate treatment of main steam line leakage is l
considered within the PNPP licensing basis, since within Section l
15.6.5.5.1.2.a of the FSAR (and carried forward into the Updated Safety Analysis Report (USAR)) the following is stated, "The design basis leak rate of the primary containment and its penetrations (excluding the main steam lines) is 0.2 percent per day [ emphasis added] for the duration of the l
accident", and within TS LCO 3.6.1.2.a, "an overall integrated leakage rate of less than or equal to 0.75 L, 0.20 percent by veight of the primary containment air per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />"at P [ emphasis addedj" is specified. Thus, the same leakage limit for L was spe"ified in both of these licensing basis documents, although the iS do not explicitly state that the overall integrated leakage rate of 0.20 percent per day does not include the main steam line I
isolation valve leakage fraction. The PNPP Unit 1 TS do however recognize the separate dose calculations for the main steam line leakage contribution by providing a distinct leakage limit just for these lines (see LCO 3.6.1.2.c).
The NRC SER approving the PNPP design basis LOCA analysis alst recognized the main steam line isolation valve leakage as a contribution separate from the 0.20 percent per day containment leakage contribution (see SSEP b. Table 15.2).
In order to make the TS more clear on this point, within letter PY-CEI/NRR-1650L it is proposed to add "except for the main steam line isolation valves" and a superscript "#" to LCO 3.6.1.2.a and Action 3.6.1.2.a to refer to a footnote which clarifies that an Appendix J exemption is associated with these requirements. The concept of using such a footnote to identify exemptions to Appendix J is consisten* vith the current BVR Standard Technical Specifications. The Bases are also p.sposed to be revised to explain that the main steam line isolation valve leak rates are exempted from
'e PY-CEI/NRR-1651L Page 4 of 12 inclusion in the overall integrated primary containment leak rate (see ).
A detailed description of these (and all of the following) proposed TS and Bases changes is provided in the " Description of the Proposed Changes" section of letter PY-CEI/NRR-1650L.
The second portion of the exemption (from item A(ii) cited above) being sought to reinforce the methodology and approvals cited in the PNPP licensing basis is to Paragraphs III.B.3 and III.C.3 of the regulation, which require that the combined local leak rate for all penetrations and all isolation valves, as measured during local leak rate tests (the LLRTs or Type B and Type C tests),
meet the acceptance criterion of less than or equal to 0.60 of the maximum allowable containment leak rate (or L ).
The inference of these vords is that this limit would apply to all penetrations including the main steam line penetrations. The separate treatment of main steam line isolation valve leakage is recognized within the PNPP licensing basis since within FSAR Table 6.2-40, Note 4 (and carried forward in the USAR), it was specified that "MSIV leakage is not included in the 0.60 L Type B and C test totals" (the combined local leak rate totals'). Also, the P$PP Unit 1 TS issued by the NRC are clear on this separation; in addition to the separate leakage limit provided for the main steam lines in LCO 3.6.1.2.c, TS LC0 3.6.1.2.b states that the combined leakage rate limit shall be "less than or equal to 0.60 L for all penetrations and all valves, except for main steam line 1"olation valves...[ emphasis added]".
Therefore, it is proposed within letter PY-CEI/NRR-1650L to add a superscript
"#" to LC0 3.6.1.2.b and to Action 3.6.1.2.b to refer to a footnote which clarifies that an Appendix J exemption is involved. The use of this footnote to identify this exemption is consistent with the current BVR Standard Technical Specifications.
It is also proposed to revise the Bases (see ) to cite that the main steam line isolation valve leak rates are exempted from inclusion in the combined leakage rate.
The third portion of the exemption being sought to reinforce the methodology and approvals cited in the PNPP licensing basis is to Paragraph III.A.1(d) of Appendix J, which (in part) requires that, "Those portions of the fluid systems that are part of the reactor coolant pressure boundary and are open directly to the containment atmosphere under post-accident conditions and become an extension of the boundary of the containment shall be open or vented to the containment atmosphere prior to and during the test....All vented systems shall be drained of water or other fluids to the extent necessary to assure exposure of the system containment isolation valves to containment air test pressure...."
At PNPP, the containment ILRT is performed with the main steam lines filled with water between the inboard and outboard MSIVs to minimize leakage through this pathway during the Type A test.
Filling these lines meets the objective of the regulation in that the filling removes the leakage pathway from the test, which is consistent with the PNPP design and accident analysis.
Venting and draining the main steam lines to the containment atmosphere during a Type A test is not necessary to achieve the underlying purpose of the rule since: each main steam line penetration (the area between the inboard and outboard MSIVs, including the outboard MSIVs before seat drain lines) is Type C tested as required by this paragraph (Paragraph III.A.1(d)); this leakage is required to be less than the limit specified in TS LCO 3.6.1.2.c; and, this i
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PY-CEI/NRR-1651L Page 5 of 12 leakage contribution is separately addressed in the design basis LOCA radiological analyses.
During the initial licensing period, conversations were held with the NRC Staff to ensure it was understood that we did not intend to vent and drain the main steam lines to the containment atmosphere during the ILRTs, but instead intended to treat the main steam line penetration leakage separately.
Following these conversations, CEI submitted a letter (PY-CEI/NRR-0292L dated July 26, 1985) from M. R. Edelman (CEI) to B. J. Youngblood (NRC) clarifying the main steam line leak testing to be performed at the Perry Nuclear Power Plant in accordance with 10 CFR 50 Appendix J.
This letter stated:
"The Perry Nuclear Power Plant Technical Specifications (Proof and Review Copy dated April 8, 1985) establish a separate leakage i
limit for main steam line isolation valves (MSIV's) in Section 3/4.6.1.2.
To establish consistent leak testing in accordance vith Appendix J, we are planning to conduct primary reactor containment leak rate testing (Type A) separately from MSIV testing (Type C).
To accomplish this separation, the main steam lines vill be water-filled between inboard and outboard MSIV's to prevent air leakage during the Type A test; MSIV's vill be separately Type C tested in accordance with 10 CFR 50 Appendix J Paragraph III.A.l(d) and III.C.1 and 2.
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The basis upon which CEI concludes this is acceptable primarily l
rests on the consistent separation of leakage terms in technical specifications, test performance, and offsite dose assessment."
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This letter served two purposes related to the exemption being discussed I
herein; first, it clarified that the Type A overall containment leak rate test results and the Type C local leak rate test results for the main steam lines would be treated separately (see discussion above for the first and second portions of the exemption), and second, it clarified that CEI intended to vater fill the main steam lines between the inboard and outboard MSIVs during the ILRT (relates to the third portion of the exemption being discussed here).
In order to better clarify the third portion of the exemption within the PNPP licensing basis, it is proposed to revise the TS Bases to state that the main steam line penetrations do not require venting and draining during the ILRT (see Attachment 2).
Therefore, as previously described in the discussions for each of the affected Appendix J paragraphs, the concept that main steam line isolation valve leakage was to be treated separately f rom the other Type A and B/C leakages was recognized by and accepted by the NRC Staff at the time of licensing of the PNPP. However, due to the NRC Staff legal interpretation previously discussed, and the specific wording of Appendix J, it was subsequently recognized that a formal exemption for these issues would be more appropriate to document the approvals received in the initial licensing of PNPP, and to reflect the PNPP design basis. The formal exemption request submitted herein for these paragraphs of 10 CFR 50 Appendix J should be issued prior to or concurrent with the proposed TS changes discussed in letter PY-CEI/NRR-1650L.
Also, issuance of this exemption is requested prior to issuance of the Improved Technical Specifications for PNPP, Unit 1, due to the reformatting of the primary containment leakage requirements.
i PY-CEI/NRR-1651L Page 6 of 12 Part B - Decouple Performance of the Third Type A Test from the Shutdown for the 10-Year Plant Inservice Inspection Paragraph III.D.1(a) of 10 CFR 50 Appendix J requires in part,
... a set of three Type A tests shall be performed, at approximately equal intervals during each 10-year service period. The third test of each set shall be conducted when the plant is shutdown for the 10-year plant inservice inspections." Type A tests are defined in Paragraph II.F of Appendix J as those "... tests intended to measure the primary reactor containment overall integrated leakage rate... at periodic intervals..." The 10-year plant inservice inspection (ISI) is that series of inspections performed every 10 years in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and Addenda as required by 10 CFR 50.55a. The PNPP proposes to perform the three Type A tests at approximately equal intervals within each 10-year service period, with the third test of each set conducted as close as practical to the end of the 10-year service period.
However, there would be no connection as currently required by the regulation between the third Appendix J Type A test and the plant 10-year inservice inspection outage.
Vithin letter PY-CCI/NRR-1650L a change is proposed, which requires the exemption proposed here, to remove the second sentence in TS SR 4.6.1.2.a which requires that the third Type A test of each set be conducted during the shutdown for the 10-year plant inservice inspection.
(Note that this proposed l
exemption does not alter the existing requirement that three ILRTs be l
performed during each 10-year service period.)
l The following discussion addresses the Appendix J requirement (as reflected in TS SR 4.6.1.2.a) that links the third Type A test of each set to the shutdown period for the 10-year plant inservice inspection. The Type A containment integrated leak rate tests and the 10-year inservice inspection program are independent of each other and provide assurance of different plant characteristics. The Type A test assures the required leak-tightness of the containment to demonstrate compliance with the guidelines of 10 CFR Part 100.
The 10-year inservice inspection program provides assurance of the structural integrity of the structures, systems, and components as directed by Section XI of the ASME Boiler and Pressure Vessel Code and Addenda in compliance with 10 CFR 50.55a.
At PNPP, the inservice inspection volumetric, surface and visual examinations of components and system pressure tests are performed in accordance with 10 CFR 50.55a(g)(4) throughout the 10-year inspection interval. The major portion of this effort is presently being performed periodically during refueling outages.
The regulation, by linking these two requirements, forces the third Type A test (in the 10-year service period) and the 10-year ISI to be performed during the same outage.
If three Type A tests have already been performed in the 10-year service period, this regulation would require that another Type A test be performed during the 10-year ISI outage, since by the precise wording of the regulation the test and examination have to be performed together.
An Appendix J exemption and a TS change would be necessary to prevent having to i
l perform an otherwise unnecessary Type A test.
There is no benefit to be l
gained by coupling the third Type A test and the 10-year plant inservice I
inspections to the same refueling outage since elements of the PNPP ISI program are conducted throughout each 10-year cycle rather than just during a refueling outage at the end of the 10-year cycle. Consequently, the subject
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PY-CEI/NRR-1651L Page 7 of 12 coupling requirement offers no benefit either with regard to safety or to economical operation of the facility. There are no requirements other than this one (for which an exemption is requested) that links performance of the ILRT and the inservice inspection.
Note that the proposed revision to 10 CFR 50 Appendix J, published in the Federal Register on October 29, 1986 proposes the same exact change, to decouple the performance of the third Type A test (in each 10-year service period) from being required to occur during the same outage as the 10-year plant inservice inspections. Additionally, several plants have previously received similar exemptions and corresponding amendments to their TS to implement this proposed change.
The TS and Bases changes are proposed by letter PY-CEI/NRR-1650L to remove the tie between the performance of the third Type A test (in each 10-year service period) and the 10-year plant inservice inspection. Attachment 2 to this letter provides the Bases change, as proposed by PY-CEI/NRR-1650L, which explains that an exemption to 10 CFR 50 Appendix J has been granted to eliminate the tie between the ILRT and the ISI program.
Part C - Allov Type C Testing to be Performed at Times Other Than During Shutdown for Refueling l
Paragraph II.D.3 of 10 CFR 50 Appendix J requires that " Type C tests shall be performed during each reactor shutdown for refueling but in no case at intervals greater than 2 years."
Paragraph III.D.2 discusses the scheduling of Type B tests and contains the same wording but also includes an additional provision that allows Type B tests to be performed at "other convenient intervals" in lieu of during reactor shutdown for refueling.
It is requested that this same provision also be applied to Type C local leak rate testing. This vould allov local leak rate testing to be performed on those systems which could be taken out-of-service while the reactor was operating consistent with other considerations such as TS Operability, ALARA and other considerations.
This change is consistent with the current Type B testing requirements of Appendix J, and is also included in the proposed Appendix J rule changes currently under consideration.
For example, the BVR/6 Mark III containment / suppression pool design is such that Type C local leak rate testing can be performed during power operation on l
certain systems (primarily ECCS) that are specifically designed to remain l
intact following a LOCA and thus provide a water seal for the containment l
isolation valves or ensure that only liquid leakage from the containment vill occur through these penetrations.
Also, the Dryvell and Containment Purge System (TS 3.6.1.8) containment isolation valves have Surveillance Requirements imposed on them to demonstrate leak tightness during power operation. These surveillance tests (for the Dryvell and Containment Purge System) are the same exact leak rate tests as the Type C local leak rate tests. Therefore, credit for performance of these tests at the much more frequent intervals required by TS 3.6.1.8 rather then the two year interval of Appendix J should be allowed.
However, a literal reading of Paragraph III.D.3 of Appendix J vould prohibit taking credit for these Type C local leak rate tests.
Type C testing of containment isolation valves at test frequencies other than refueling outages vill provide at least equivalent assurance of containment
U PY-CEI/NRR-1651L Page 8 of 12 leak tightness as required by 10 CFR 50 Appendix J, Paragraph III.C in that the test interval vill not exceed the 2 year maximum duration specified in Paragraph III.D.3.
Permitting the containment isolation valve leak rate tests to be conducted in this manner is consistent with the proposed revision to 10 CFR 50 Appendix J published in the Federal Register on October 29, 1986.
A.
The Exemptions Are Authorized By Law The Commission's authority to grant exemptions from its regulations as described in 10 CFR 50 is defined within 10 CFR Section 50.12.
Therefore, exemptions are consistent with the regulatory scheme established by the NRC and are not prohibited by any statutory authority.
Hence, exemptions are authorized under NRC regulations.
B.
The Exemptions Will Not Present An Undue Risk To The Public Health And Safety An exemption vill not present an undue risk to the public health and safety if it can be shown that the exemption meets the statutory standard of adequate protection to the health and safety of the public.
The evaluation of "no undue risk" considers such factors as the type of plant operation contemplated, the existence of alternative means of compliance or compensatory measures which meet the objective of the regulation (or requirement) but in a different way from that originally envisioned, and other safety factors. The results of evaluations for each of the exemptions considering these factors are discussed below.
Part A - Formalize the Approval for Excluding the Main Steam Line i
Isolation Valve Leakages from Inclusion 1) in the Overall Integrated Primary Containment Leak Rate and 11) the Combined Local Leak Rate, and Clarify that the Main Steam Lines are Not Required to be Vented and Drained for Type A Testing During the initial licensing of PNPP, the main steam line leakage rate was treated as a separate input from the containment design leak rate in the radiological analysis of a postulated design basis LOCA. The analysis demonstrated that the calculated LOCA dose exposures are well within the guidelines of 10 CFR 100 for offsite doses and within 10 CFR 50, Appendix A, (General Design Criteria 19) for the control room i
doses. TS 3.6.1.2, separate and apart from the Type A test, has provided for periodic verification and control of the allovable main steam lina isolation valve leak rates.
Since the TS limit for main steam line isolation valve leakage is treated separately, as supported in the radiological analysis in accordance with the Standard Review Plan provisions, it is not necessary to "doublecount" the main steam line isolation valve leakage contribution by also adding it into the overall primary containment leak rate or combined local leak rate summations.
The main steam line isolation valves are separately Type C tested in accordance with 10 CFR 50 Appendix J, Paragraph III.C.
In that establishing the main steam lines as water-filled between the inboard and outboard MSIVs during the Type A testing and measuring main steam line isolation valve leakage rate separately from the overall and combined
PY-CEI/NRR-1651L
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Page 9 of 12 totals is consistent with the PNPP design assumptions and analyses, the proposed exemption presents no undue risk to the public health and safety.
Part B - Decouple Performance of the Third Type A Test from the Shutdown for the 10-Year Plant Inservice Inspection No need exists to link the third Type A ILRT vith the inspections performed during each 10-year ISI outage. The two programs evaluate different plant characteristics, and the methods of complying with each program are considerably different. The purpose of the containment leak rate testing program, as described in the introduction to Appendix J to 10 CFR 50 is to ensure that leakage through the primary containment and components penetrating the primary containment do not exceed the allovable leak rate limits. These limits help to ensure compliance with the radiological dose guidelines of 10 CFR Part 100. The 10-year ISI or ASME Section XI inspection program is intended to separately ensure that the structural integrity of Class 1, 2, and 3 components is maintained in accordance with the requirements of the ASME code or 10 CFR 50.55a.
Decoupling has no safety consequences because the requirements of containment integrity in Appendix J and the TS, and of the structural integrity of Class 1, 2, and 3 components in the ASME Code, are not being changed. The three Type A tests vill continue to be performed at i
approximately equal intervals during each 10-year service period.
l Therefore, granting of the exemption from the requirement of 10 CFR 50 l
Appendix J,Section III.D.1(a) which links the Type A test to the 10-year l
ISI outage vill not present any undue risk to the public health and safety.
l Part C - Allow Type C Testing to be Performed at Times Other Than During l
Shutdown for Refueling l
Type C testing of containment isolation valves at test frequencies other than refueling outages vill provide at least equivalent assurance of containment leak-tightness as required by 10 CFR 50 Appendix J, Paragraph l
III.C in that the test interval vill not exceed the 2 year maximum duration specified in Paragraph III.D.3.
Permitting the containment isolation valve leak rate tests to be conducted in this manner vill provide enhancements in ALARA considerations and is consistent with the proposed revision to 10 CFR 50 Appendix J published in the Federal Register on October 29, 1986. Based on these considerations, the proposed exemption does not present an undue risk to the public health and safety.
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C.
The Exemptions Are Consistent Vith Common Defense And Security Vith regard to the " common defense and security" standard, granting the requested exemptions is consistent with the common defense and security of the United States. The Commission's Statement of Considerations in support of the exemption rule note with approval the explanation of this standard as set forth in Long Island Lighting Company (Shoreham Nuclear l
Power Station, Unit 1) LBP-84-45, 20 NRC 1343, 1400 (October 29, 1984).
There, the term " common defense and security" refers principally to the
1 PY-CEI/NRR-1651L Page 10 of 12 safeguarding of special nuclear material, the absence of foreign control over the applicant, the protection of Restricted Data, and the availability of special nuclear material for defense needs. The granting of the requested exemptions vill not affect any of these matters and, thus, the requested exemptions are consistent with the common defense and security.
D.
Special Circumstances Are Present The spec 191 circumstances applicable to each of the proposed exemptions as prescribed by 10 CFR 50.12(a)(2), are discussed within each Part below:
Part A - Formalize the Approval for Excluding the Main Steam Line Isolation Valve Leakages from Inclusion in 1) the Overall Integrated Primary Containment Leak Rate and 11) the Combined Local Leak Rate, and Clarify that the Main Steam Lines are Not Required to be Vented and Drained for Type A Testing The following special circumstance as identified in Section 50.12(a)(2),
is relevant to this exemption request:
(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 rule; Explicit compliance with 10 CFR 50 Appendix J for Type A tests is not necessary to achieve the underlying purpose of the rule.
As discussed earlier, the basis for the containment leak tests is to determine that the measured leak rate is within the acceptance criteria cited in the licensing basis safety analysis. The safety analysic for a design basis LOCA includes the maximum main steam line isolation valve leak rate separately from the maximum containment leak rate. Main steam line isolation valve leakages are tested as part of the local leak rate testing in accordance with the requirements of TS 3.6.1.2.
This testing provides the leakage measurement for the separate main steam line isolation valve component as has been assumed in the safety analysis and, therefore, the assumed radiological releases due to the measured leakage rate can be determined consistent with the methods of the safety analysis.
Since Type A tests are intended to measure the primary containment overall integrated leak rate consistent with the accident analysis, the main steam line isolation valve leak rate should not be included in the measurement of the ILRT.
Inclusion of the main steam line isolation valves Type C leakage in the combined local leak rate limit is not necessary since a specific main steam line isolation valve leak rate (corresponding to the safety analysis value) is specified in TS 3.6.1.2 and leakage through this path has been included as a separate leakage component in the safety analysis.
Also, venting and draining of the main steam lines during Type A tests is not necessary. The main steam line isolation valve leakage
i
.s PY-CEI/NRR-1651L Page 11 of 12 l
rate component of the overall containment leakage has been accounted for separately in the safety analysis.
Water filling the main steam lines between the inboard and outboard MSIVs, as cited previously, ensures the leakage rate for the overall containment is measured consistent with the accident analysis assumptions.
Part B - Decouple Performance of the Third Type A Test from the Shutdown for the 10-Year Plant Inservice Inspection The following special circumstance as identified in Section 50.12(a)(2),
is relevant to this exemption request:
(ii) Application of the regulation in the particular circumstances vould not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule; Coupling the third periodic ILRT to the 10-year Inservica Inspection does not enhance the purpose of Type A testing nor does it provide further assurance of containment integrity above that which is already being demonstrated. The requirement of 10 CFR 50 Appendix J that three Type A tests be performed at approximately equal l
intervals during a 10 year service period is not impacted by l
decoupling the third Type A test from the 10-year Inservice Inspection. This decoupling has been recognized and incorporated by the NRC in the proposed revision to 10 CFR 50 Appendix J, published in the Federal Register on October 29, 1986.
Based on the fact that the underlying purpose of the rule (to ensure containment leak-tightness) vill be met, granting of the proposed exemption is justified.
Part C - Allow Type C Testing to be Performed at Times Other Than During l
Shutdown for Refueling l
The following special circumstance as identified in Section 50.12(a)(2),
is relevant to this exemption request:
(ii) Application of the regulation in the particular circumstances vould not serve the underlying purpose-of the rule or is not necessary to achieve the underlying purpose of the rule; The requirement of 10 CFR 50 Appendix J to perform Type C local leak rate testing of containment isolation valves at least once every two years vill not be affected by granting the exemption from l
the additional requirement that Appendix J leakage rate testing only be performed during shutdown for refueling.
In that it is more prudent, for several considerations including ALARA, that selected containment isolation valve leakage rate testing be performed during power operations, the underlying purpose of the rule to verify l
containment leak-tightness vill be met.
In addition, the exemption from the requirement that Type C local leak rate testing may only be i
performed for Appendix J credit during shutdown for refueling is consistent with the proposed revision to 10 CFR 50 Appendix J, l
published in the Federal Register October 29, 1986.
Based on the i
l above reasons, the proposed exemption is justified.
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In summary, these exemptions vill not pose any undue risk to the health and safety of the public and are consistent with the common defense and security.
Special circumstances, as provided in 10 CFR 50.12(a)(2)(ii),
are present justirying these exemptions from 10 CFR 50 Appendix J.
The purpose of 10 CFR 50 Appendix J is to " assure that... leakage through the primary reactor containment and systems and components penetrating primary containment shall not exceed the allovable leakage rate values as specified in the Technical Specification or associated Bases..." As previously described, this purpose can be fully achieved under the actions proposed by the requested exemptions.
Also, application of the regulation in these particular circumstances in the exact way it is presented is not necessary to achieve the underlying l
purpose of the rule. These exemption requests are similar to exemptions l
vhich have been previously approved for other nuclear power plants and/or have been incorporated into the proposed revision of 10 CFR 50 Appendix J, published in the Federal Register October 29, 1986.
i Based on these findings, special circumstances exist which justify the granting of the requested exemptions.
Consequently, the requested j
exemptions meet the special circumstances test and should be granted pursuant to Section 50.12(a).
CONCLUSION Because these exemptions from the requirements of 10 CFR 50 Appendix J for PNPP Unit 1 are authorized by lav, vill not present an undue risk to the public health and safety, are consistent with the common defense and security, and special circumstances exist, ve respectfully submit that, in accordance with the requirements of 10 CFR 50.12, the NRC should grant the requested exemptions.
PROPOSED TECHNICAL SPECIFICATION BASES CHANGES The Bases for the Containment Leakage specification (TS 3/4.6.1.2) currently l
only describe an exemption to Appendix J for air lock testing in as was granted in the PNPP Safety Evaluation Report, Supplement 7.
Letter PY-CEI/NRR-1650L, dated October 21, 1994, and the markup of the Bases in provides a rewritten version of the existing Bases to clarify the wording of the air lock exemption and to set the framework for a listing in the Bases of other Appendix J exemptions, such as the ones requested herein.
It is proposed that the wording in Attachment 2 be added to the Bases of Specification 3.6.1.2 following approval of these exemption requests.
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