3F1286-04, Requests Exemption from Requirements of 10CFR50,App J, Paragraph III D.2(b)(ii) for Conducting Full Pressure Airlock Leakage Test.Exemption Would Allow Substitution of Airlock Seal Test for Airlock Full Pressure Test.Fee Paid
| ML20214R025 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 12/01/1986 |
| From: | Widell R FLORIDA POWER CORP. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| 3F1286-04, 3F1286-4, NUDOCS 8612050347 | |
| Download: ML20214R025 (3) | |
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Power CO R POR ATION December 1, 1986 3F1286-04 Mr. H. R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 10 CFR 50 Appendix J Exemption Request
Dear Sir:
Florida Power Corporation (FPC) hereby requests exemption from the requirements of 10 CFR 50, paragraph III D.2(b)(ii) of Appendix J, in accordance with the provisions of 10 CFR 50.12.
EXEMPTION REQUEST This exemption will revise the requirements for conducting a full pressure airlock leakage test. FPC proposes to rely on seal leakage testing as described in paragraph III.D.2(b)(iii) when the reactor is in COLD SHUTDOWN (Mode 5) or REFUELING (Mode 6) and when no maintenance has been perfonned that affects airlock sealing capabilities.
A full pressure airlock leakage test will be performed at least once per six months and following any maintenance that could affect airlock sealing capabili ty.
This testing will verify the sealing capability of the airlock has not degraded as a result of routine use or maintenance since the previous test.
It will also verify the overall airlock leakage rate is within the Technical Specification limits.
This change conforms to the latest revision of the Standard Technical Specifications (NUREG 0452), and to the proposed revision to 10 CFR 50 Appendix J, published on October 29, 1986, in Federal Register Volume 51, Number 209, Page 39543.
It is our conclusion the requested 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.
8612050347 861201
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P PDR GENERAL OFFICE: 3201 Thirty-fourth street south.
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,N December 1, 1986 3F1286-04 Page 2 50.12(a)(2)(ii)
Application of the regulation in this circumstance is not necessary to achieve the underlying purpose of 10 CFR 50, Appendix J,
III.D.2(b)(ii).
The six month test requirement of paragraph III.D.2(b)(i) of Appendix J, the three day test requirement of paragraph III.D.2(b)(iii) of Appendix J, and the testing require-ments when maintenance is performed on the airlock that affects sealing capacity will provide assurance the airlock will not leak excessively.
50.12(a)(2)(iii) Compliance would result in undue hardship and cost through reduced operational flexibility and unwarranted delays in power ascension over the life of Crystal River Unit 3 in excess of those incurred by other similar facilities that have received exemption from the subject Appendix J paragraph.
Performance of the leakage rate tests required by paragraph III.D.2(b)(ii) takes approximately 28 man-hours per airlock and requires installation of a strong back device on the inside airlock door (test pressure applied inside the airlock tends to unseat this door because it is designed to seat with accident pressure from inside containment).
This evolution could presently occur several times during an outage and ultimately delay mode change on startup. Additionally, the extra testing is a drain on manpower resources with little or no resulting increase in assurance the airlock will not experience excessive leakage.
EVALUATION The following information is provided to assist the Commission in their evaluation of the safety impact of this exemption request.
The full pressure airlock leakage test will be performed every six months, however, during Modes 5 and 6, the test will only be conducted if maintenance activities were performed which could have affected airlock sealing capability.
FPC will also perform an airlock seal test by pressur-izing the airlock door gasket interspaces to 8 psig if the doors have been opened.
If the doors have not been opened, the six month full pressure (49.6 psig) test will demonstrate the overall sealing capabilities.
Opening of the airlock has the potential of altering the sealing capability of the airlock because of possible damage to the seals.
The door operator (hand wheel) e shaf t seals experience very little alteration as the shafts rotate within packing.
History indicates the shaft seals are effective in maintaining the sealing capabil-ity, even with door operation.
Additionally, a full pressure test every six months and af ter maintenance is sufficient to assure operability.
In contrast to the shaft seals, the door seals could experience alteration when the doors cycle. The alterations occur as the knife edges impact the seals.
Pressuriza-
.N December 1, 1986 3F1286-04 Page 3 tion of the volume between the seals to 8 psig after each opening, and prior to establishing containment integrity, provides the necessary surveillance to ensure the sealing capability of the door seals.
Additionally, the sealing capability of the doors is ensured by the performance of a full pressure test af ter maintenance which could affect airlock door gasket sealing capability.
CONCLUSION The granting of the requested exemption would allow the substitution of an airlock seal test for an airlock full pressure test while the reactor is in a shutdown or refueling mode.
This substitution has no significant impact upon plant operation or safety. The six month test requirement of paragraph III.D.2(b)(i) of Appendix J, the three day test requirement of paragraph III.D.2(b)(iii) of Appendix J, and the requirement for testing af ter maintenance has been performed on the airlock will continue to demonstrate containment integrity. Therefore, post accident radiological releases which were previously described in the CR-3 Final Safety Analysis Report will not be affected by the exemption.
Furthermore, this exemption has no impact on plant radiological or non-radiological effluents and involves no significant occupational exposure.
FPC respectfully requests approval of this exemption request by December 11,1986, in order to facilitate startup from the present forced outage.
An application fee, check number 874578, of one hundred fif ty dollars ($150) as required by 10 CFR 170 has been attached.
Sincerely, 0
R.C)Widell Manager, Nuclear Operations Licensing and Fuel Management JLB/nl Attachment cc: Dr. J. Nelson Grace Regional Administrator, Region II U.S. Nuclear Regulatory Commission 101 Marietta Street, N.W., Suite 2900 Atlanta, GA 30323
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