ML14190A628
| ML14190A628 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 12/28/1981 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML14190A627 | List: |
| References | |
| NUDOCS 8201210371 | |
| Download: ML14190A628 (3) | |
Text
SAFETY EVALUATION REPORT APPENDIX J REVIEW H. B. ROBINSON, UNIT 2
1.0 INTRODUCTION
By letter dated August 7,-1975(1), the NRC requested Carolina Power and Light Company (CP&L) to review its containment leakage testing program for H. B. Robinson, Unit.2, and the associated Technical Specifications, for compliance with the requirements of Appendix J to 10 CFR Part 50.
Appendix J to 10 CFR Part 50 was published on February 14, 1973. Since there already were many operating nuclear power plants and a number of others in advanced stages of design or construction, the NRC decided to have these plants re-evaluated against the requirements of this new regu lation. Therefore, beginning in August 1975, requests for review of the extent of compliance with the requirements of Appendix J were made of each licensee. Following the initial responses to these requests, NRC staff positions were developed which would assure that the objectives of the testing requirements of the above cited regulation were satisfied. These staff positions have since been applied in our review of the submittals filed by the H. B. Robinson, Unit 2 licensee. The results of our evalua tion are provided below.
2.0 EVALUATION Our consultant, the Franklin Research Center, has reviewed the licensee's submittals [2, 4] and prepared the attached Technical Evaluation Report (TER) of containment leak rate tests for H. B. Robinson, Unit 2. We have reviewed this evaluation and concur in its bases and findings.
In the TER, the staff's consultant agreed with'the licensee's proposed change to Technical Specification (T.S.) 4.4.1.1-f.3 as stated in ENCLOSURE 83201210371 811228 PDR ADOCK 05000261 P-PDR
-2' reference (2) which requires that the allowable test leakage shall not ex ceed 0.75 L.
The acceptance criteria of Appendix J require that the allow t
able test leakage shall be less than 0.75 L.
Since the licensee's modifi t
cation meets the requirements of Appendix J, both we and our consultant con clude that this modification to the T.S. is acceptable.
The licensee requested an exemption from the frequency of testing the air locks, and indicated that the airlock door seals are tested at pressure Pa on a continuous basis by the plant penetration pressurization system. Spe fically, the licensee proposed to substitute a Type B test at P during re a
fueling outages for the six-month Type B test at Pa, and substitute a contin uous pressure test at Pa using the plant penetration pressurization system for the seal test after each opening of the airlock.
Appendix 3, at Sections III.B.2 and III.D.2, requires that reactor contain ment airlocks be leak tested at the peak calculated accident pressure, P,
a at six month intervals. Further, should the airlocks be opened between such intervals, the airlocks must be leak tested after each opening.
Although continuous pressurization at P demonstrates the adequacy of the a
the door seals, it does not satisfy the objective that the six month test provide an integrated leakage rate for the entire airlock assembly, includ ing electrical and mechanical penetrations, the airlock cylinder, hinge as semblies, welded connections, and other potential leakage paths.
In view of the above, our consultant finds that CP&L's proposal to perform a verification of airlock door seals at P on a continuous basis by pres a
surizing between the double-gasketed seals is an acceptable alternative to performing a Type B test of the airlock after each use and that an exemp tion from this requirement of Appendix J is acceptable. Our consultant
-3 also finds that CP&L's request for an exemption from the requirement for testing the airlocks every six months is not acceptable and that a Type B test in accordance with with Appendix J must be performed every six months.
We concur with our consultant's conclusion that the exemption from the re quirement for a seal test after each opening of the airlock is acceptable and the exemption from the Type B test every six months is unacceptable.
3.0 CONCLUSION
Based on our review of the attached technical evaluation report as prepared by our consultant, and the above discussion, we conclude that:
- 1) CP&L's request for an exemption from the requirement for testing air locks every six months is not acceptable.
- 2) CP&L's request for an exemption from the requirement for testing air locks after each opening is acceptable, provided that the double seals are pressurized on a continuous basis at pressure P a
- 3) CP&L's proposed modification to Technical Specification 4.4.1.1.f.3 to change "shall not exceed 0.75...
" to read "shall be less than 0.75... "
is acceptable.
4.0 REFERENCES
[1]
NRC generic letter from Mr. Karl Goller, Assistant Director for Oper ating Reactors, to CP&L dated August 7, 1975.
[2] CP&L letter from Mr. E. E. Utley, Vice President, to Mr. Karl Goller, Assistant Director for Operating Reactors, dated September 16, 1975.
[3)
NRC letter from Mr. R. W. Reid, Chief, Operating Reactors Branch #4, to Mr. J. A. Jones, Senior Vice President, dated July 5, 1977.
[4]
CP&L letter from Mr. E. E. Utley, Senior Vice President, to Mr. R. W. Reid, Chief, Operating Reactors Branch #4, dated September 21, 1977.