[Federal Register Volume 61, Number 4 (Friday, January 5, 1996)]
[Notices]
[Pages 416-419]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 96-146]
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NUCLEAR REGULATORY COMMISSION
[Docket Nos. 50-295 and 50-304]
Commonwealth Edison Co., (Zion Nuclear Power Station, Unit Nos. 1
and 2); Exemption
I
Commonwealth Edison Company (ComEd or the licensee) is the holder
of Facility Operating License Nos. DPR-39 and DPR-48, which authorize
operation of the Zion Nuclear Power Station, Unit Nos. 1 and 2, at a
steady-state reactor power level not in excess of 3250 megawatts
thermal. The facilities are pressurized water reactors located at the
licensee's site in Lake County, Illinois. The licenses provide, among
other things, that the Zion Nuclear Power Station is subject to all
rules, regulations, and Orders of the U.S. Nuclear Regulatory
Commission (the Commission or NRC) now or hereafter in effect.
II
Sections III.C and III.D.3 of 10 CFR part 50, appendix J, option A,
require that Type C local leakage rate periodic tests shall be
performed during reactor shutdown for refueling, or other convenient
intervals, but in no case at intervals greater than 2 years. These
requirements are reflected in the Zion Technical Specifications (TS) as
requirements to perform Type C containment leakage rate testing in
accordance with 10 CFR part 50, appendix J, and approved exemptions.
III
The licensee has determined that certain containment isolation
pathways have not been locally leakage rate tested (Type C tests) as
required by option A of appendix J to 10 CFR part 50. In a letter dated
August 16, 1995, the licensee requested relief from the requirement to
perform the Type C containment leakage rate tests of certain
penetrations and valves in these pathways in accordance with the
requirements of sections III.C and III.D of 10 CFR part 50, appendix J,
option A. On August 16, 1995, the staff authorized in writing,
continued operation of the Zion units in a notice of enforcement
discretion (NOED) until such time as the
[[Page 417]]
staff acted on the exemption requests. In a letter dated November 20,
1995, the staff granted the schedular exemptions requested in the
licensee's letter of August 16, 1995, and granted schedular exemptions
for the permanent exemption requests to allow time for additional staff
review and until final staff action could be taken. In its letter of
November 28, 1995, and supplemented on December 6, 1995, the licensee
requested, in part, that certain schedular exemption requests be
granted as permanent exemptions. As requested, the staff granted
permanent exemptions for the containment isolation valves in
containment penetrations P-70 and P-99 by letter dated December 11,
1995.
The licensee's letter of November 28, 1995, also requested that the
following permanent exemption requests be changed to schedular
exemption requests.
Units 1 and 2: P-77, 1(2)PP0101, 1(2)PP0102, 1(2)PP0103,
1(2)PP0104, Penetration Pressurization to Containment Valve Stations;
and P-102, 1(2)AOV-RC8029, Primary Water to the Pressurizer Relief
Tank.
For Unit 1, the penetrations would be tested during the refueling
outage in the fall of 1995, and for unit 2, they would be tested during
the next cold shutdown of sufficient duration, and subsequently
thereafter as required. For P-77 and P-102, the staff's letter of
November 20, 1995, granted schedular exemptions until December 31,
1995. The final action for these penetrations is addressed below.
The licensee's letter of November 28, 1995, also requested that the
staff grant a schedular exemption for penetration P-44. In a letter
dated December 6, 1995, the licensee withdrew the request because it
had recently tested the penetration for both units 1 and 2 and intends
to continue to test the penetration in accordance with the requirements
of 10 CFR part 50, appendix J, option A.
The final resolution of the remaining issues is provided below.
Pathways Listed in Licensee's Letter Dated August 16, 1995
Attachment 2 of the licensee's letter of August 16, 1995, requested
permanent exemptions for components in the following containment
penetrations:
Units 1 and 2: P-14, Valve 1(2) FCV-SA01A, Service Air Supply to
Containment; P-19, Valve 1(2) MOV-CC9413A, Component Cooling Water
Supply to the Reactor Coolant Pumps; P-34, Valve 1(2) DW0030,
Demineralized Flushing Water to Containment; P-43, Valve 1(2) LCV-
DT1003, Reactor Coolant Drain Tank Pump Discharge; P-75, Valves 1(2)
VC8402A, 1920HCV-VC182, 1(2) VC8402B, 1(2) VC8403, Chemical and Volume
Control to Regenerative Heat Exchanger; P-76, Valve 1(2) VC8480A,
Reactor Coolant Loop Fill Header; P-77, Valves 1(2) PP0101, 1(2)
PP0102, 1(2) PP0103, 1(2) PP0104, Penetration Pressurization to
Containment Valve Stations; P-88, Valve 1(2) FCV-RV112, Containment Hot
Water Supply; and P-102, Valve 1(2) AOV-RC8029, Primary Water to the
Pressurizer Relief Tank.
Unit 1 only: P-16, Compression Fittings on Five Reactor Vessel Leak
Detection System Lines.
As stated above, the requests for P-77 and P-102 were changed from
permanent to schedular exemptions.
Also, in attachment 3 of the licensee's letter of August 16, 1995,
the licensee requested staff concurrence concerning certain
clarifications for the testing of P-23, P-44, and P-66.
Schedular Exemptions
As requested, penetrations P-77 and P-102 will receive extensions
of the schedular exemptions granted on November 20, 1995, rather than
permanent exemptions. For Unit 1, the penetrations were tested during
the refueling outage which concluded on December 17, 1995, and will be
tested hereafter as required by Appendix J, Option A, so no further
exemption is needed. For Unit 2, they will be tested during the next
cold shutdown of sufficient duration (no later than the next refueling
outage), and subsequently thereafter as required. The staff's review
and justification for the schedular exemptions granted for these
penetrations on November 20, 1995, remains valid and will not be
repeated here. The staff finds that, on the basis stated in the
November 20, 1995, exemption, it is acceptable to delay the testing of
P-77 and P-102 until the next cold shutdown of sufficient duration, but
no later than the next refueling outage, for Unit 2. The next Unit 2
refueling outage is currently scheduled for September 1996. Further,
the staff finds that the special circumstances required by 10 CFR
50.12(a)(2)(v) are present as described in the November 20, 1995
exemption, namely, that the requested exemptions provide only temporary
relief and the licensee made good faith efforts to comply.
Permanent Exemptions
The licensee has requested permanent exemptions for several
penetrations because it is not possible to perform the required testing
with the current hardware configurations, such as the absence of test
taps or block valves that would be needed to perform the tests. In each
case, the relief is not from testing through-valve leakage paths, but
rather leakage paths out of containment isolation valves through valve
packing, diaphragms, or compression fittings. The permanent exemption
requests may be divided into three groups, as follows:
1. P-14: The licensee proposes to test the valve packing by
pressurizing it with air to a pressure greater than or equal to Pa
and performing a soap bubble test on the packing, with an acceptance
criterion of zero observed bubbles. This will be done at the normal
Type B and C testing frequency; further, the test was performed and
passed during the recent Unit 1 refueling outage and during January
1995 for Unit 2. Generally, a soap bubble test cannot be used to
quantify a leakage rate, which is required by the regulation, but when
the observed leakage is zero (no bubbles being produced), then the
leakage rate is also zero. Therefore, the proposed testing method in
fact complies with the requirements of Appendix J, Option A, and no
exemption is required.
2. P-19, P-34, P-43, P-75, P-76, P-88: In each case, the licensee
proposes to test the valve packing (or, in the case of P-43, the valve
diaphragm) by pressurizing it with water to a pressure greater than or
equal to 1.1 Pa and then visually examining the packing or
diaphragm for water leakage, with an acceptance criterion of zero
observed leakage. This will be done at the normal Type B and C testing
frequency. The significant difference between these penetrations and P-
14 is the use of water instead of air as the test medium. The proposed
test, with water as the test medium and with a zero leakage acceptance
criterion, is conservative enough to provide reasonable assurance of no
significant increase in risk to health and safety of the public when
compared to testing with air, especially when considering the nature of
the potential leakage paths. The leakage pathways do not consist of
through-valve leakage paths, but rather leakage paths out of
containment isolation valves through valve packing or diaphragms. The
potential leakage paths are small or restrictive, through packing
openings or through cracks or tears in valve diaphragms. The leakage
path for a significant leak to occur also requires a sequence of events
for which the probability of occurrence is low, as detailed in the
licensee's letter of August 16, 1995. In addition, for some of the
systems, seismic support and the isolation valve seal water system
provide additional assurance that the risk of a significant leak is
minimal.
[[Page 418]]
Therefore, the proposed testing provides an acceptable alternative to
the requirements of Appendix J, Option A.
3. P-16 (Unit 1 only): The licensee proposes to test the
compression fittings on five small lines by pressurizing them with air
to a pressure greater than or equal to Pa and performing a soap
bubble test on the fittings, with an acceptance criterion of zero
observed bubbles. However, these lines cannot be locally pressurized to
the test pressure, so this will be done only during Type A tests, which
are required at a frequency of 3 times in 10 years, instead of the Type
B and C testing interval (every refueling outage, but not to exceed 2
years). The staff will accept the proposed testing frequency because
Type A test history at Zion Station has shown that this type of fitting
has not been problematic. Further, these particular fittings have never
caused a Type A test failure by leaking excessively. As such, the staff
does not expect the lesser testing frequency to significantly impact
the leak-tightness of the containment boundary. However, this exemption
is applicable only to Option A of Appendix J. If the licensee adopts
Option B of Appendix J for containment leakage rate testing at Zion
Unit 1, the exemption for P-16 is hereby revoked and the matter will
have to be reexamined under the requirements of Option B.
Clarifications for P-23, P-44, and P-66
P-23: 1(2) MOV-CC9414, CC Return from the RPC Lube Oil Coolers.
The licensee requested staff concurrence that this valve is a
single barrier and that the Type C test performed on the outboard disk
is adequate. As stated in the staff's Request for Additional
Information letter of December 11, 1995, the staff concurs with the
licensee.
P-44: 1(2) PR0029, Containment Sping Return Line to the
Containment.
As stated above, the licensee withdrew its request and will test
the penetration in accordance with Appendix J, Option A.
P-66: Reactor Coolant Pump Seal Injection System.
The licensee requested staff concurrence that the subject system
may be considered a qualified water seal system for penetration P-66.
In its letter of November 28, 1995, the licensee provided additional
details as to the procedural requirements and the time frames involved
in the switch over from the injection phase to cold leg recirculation
using the containment sump as a water supply. The additional
information indicates that, although there may be a brief interruption
in sealing water pressure during switch over, the water-sealing action
of the system would be essentially continuous throughout the 30-day
post-accident period. Therefore, the staff concurs that the subject
system may be considered a qualified water seal system for penetration
P-66.
To justify granting an exemption to the requirements of 10 CFR Part
50, Appendix J, Option A, a licensee must show that the requirements of
10 CFR 50.12(a)(1) are met. The licensee stated that all its exemption
requests meet the requirements of 10 CFR 50.12(a)(1), for the following
reasons:
Criteria for Granting Exemptions are Met Per 10 CFR 50.12(a)(1)
1. The requested exemptions and the activities which would be
allowed thereunder are authorized by law.
If the criteria established in 10 CFR 50.12(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 no such prohibition, the Commission is
authorized by law to grant this exemption request.
2. The requested exemption will not present undue risk to the
public.
As stated in 10 CFR 50, Appendix J, Option A, the purpose of
primary containment leak rate testing is to assure that leakage
through primary containment and systems and components penetrating
primary containment shall not exceed the allowable leakage rate
values as specified by the Technical Specifications or associated
bases and to ensure that the proper maintenance and repairs are made
during the service life of the containment and systems and
components penetrating primary containment. The requested exemption
is consistent with this intent for those penetrations in that
alternate means of ensuring leakage remains acceptably low will be
performed as proposed herein.
3. The requested exemption will not endanger the common defense
and security.
The common defense and security are not in any way compromised
by this exemption request.
In addition, the licensee must show that at least one of the
special circumstances, as defined in 10 CFR 50.12(a)(2) is present. One
of the special circumstances that a licensee may show to exist is that
the application of the regulation in the particular circumstance is not
necessary to achieve the underlying purposes of the rule. The purposes
of the rule, as stated in Section I of 10 CFR 50, Appendix J, Option A,
are to ensure that: (1) Leakage through the primary reactor containment
and systems and components penetrating containment shall not exceed
allowable values, and (2) periodic surveillance of reactor containment
penetrations and isolation valves is performed so that proper
maintenance and repairs are made. The staff has reviewed the licensee's
proposal and has concluded for the reasons discussed above that the
proposed alternative tests will confirm the integrity of the subject
pathways. Therefore, application of the regulation in this particular
circumstance is not necessary to achieve the underlying purpose of the
rule.
IV
Sections III.C and III.D.3 of 10 CFR Part 50, Appendix J, Option A,
require that Type C local leak rate periodic tests shall be performed
during reactor shutdown for refueling, or other convenient intervals,
but in no case at intervals greater than 2 years.
The licensee proposes exemptions to these sections which would
provide relief from the requirement to perform the Type C containment
leak rate tests of certain valves in accordance with the requirements
of Sections III.C and III.D of 10 CFR Part 50, Appendix J, Option A.
The Commission has determined that, pursuant to 10 CFR 50.12(a)(1),
this exemption is authorized by law, will not present an undue risk to
the public health and safety, and is consistent with the common defense
and security. The Commission further determined that special
circumstances, as provided in 10 CFR 50.12(a)(2) (ii), or (v) are
present justifying the exemption; namely, that the application of the
regulation is not necessary to achieve the underlying purpose of the
rule; or the exemptions provide only temporary relief and the licensee
made good faith efforts to comply.
Therefore the Commission hereby grants the following exemptions:
The requirement of 10 CFR Part 50, Appendix J, Option A, to
perform Type C local leakage rate periodic tests of penetrations P-
77 and P-102 at intervals no greater than 2 years is not required.
For P-77 and P-102, for Unit 1, the penetrations were tested during
the Unit 1 refueling outage in the fall of 1995, and for Unit 2,
they will be tested during the next cold shutdown of sufficient
duration, but no later than the next refueling outage and
subsequently thereafter as required.
The requirement of 10 CFR Part 50, Appendix J, Option A, to test
penetrations P-19, P-34, P-43, P-75, P-76, and P-88 for Units 1 and
2 with air is not required. Instead, the test pressure medium may be
water. These tests will be performed at the normal Type B and C
testing frequency.
The requirement of 10 CFR Part 50, Appendix J, Option A, to test
penetration P-16 for Unit 1 at intervals no greater than 2 years is
not required. Instead, this penetration may be tested during Type A
tests, which are required 3 times at approximately equal intervals
each 10 year
[[Page 419]]
service period. However, if the licensee adopts 10 CFR Part 50,
Appendix J, Option B, for containment leakage rate testing at Zion,
Unit 1, with the potential for Type A test intervals of 10 years,
the exemption for P-16 is hereby revoked.
Pursuant to 10 CFR 51.32, the Commission has determined that
granting these exemptions will not have a significant impact on the
human environment (60 FR 45499).
Dated at Rockville, Maryland, this 28th day of December 1995.
For the Nuclear Regulatory Commission.
Gail Marcus,
Acting Director, Division of Reactor Projects--III/IV, Office of
Nuclear Reactor Regulation.
[FR Doc. 96-146 Filed 1-4-96; 8:45 am]
BILLING CODE 7590-01-P
