ML17310B153
| ML17310B153 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 03/24/1994 |
| From: | Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 102-02877-WFC-R, 102-2877-WFC-R, NUDOCS 9404040202 | |
| Download: ML17310B153 (11) | |
Text
ACCELERATED DISTRIBUTION DEMONSTPATION SYSTEM l,~
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DOCKET 05000528
SUBJECT:
Requests temporary exemption for PVNGS Unit 1 from one requirement of 10CFR50,App J,Section 3.D.l.a re integrated containment leakage rate tests.
DISTRIBUTION CODE:
A017D COPIES RECEIVED:LTR 4 ENCL SIZE TITLE: OR Submittal:
Append J Containment Leak Rate Testing ACCESSION NBR:9404040202 DOC.DATE: 94/03/24 NOTARIZED: NO FACIL:STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi AUTH.NAME AUTHOR AFFILIATION CONWAY,W.F.
Arizona Public Service Co.
(formerly Arizona Nuclear Power RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
D NOTES:STANDARDIZED PLANT RECIPIENT ID CODE/NAME PDV PD TRAN,L INTERNAL: ACRS OGC/HDS 1 RES/DE/SEB EXTERNAL: NRC PDR COPIES LTTR ENCL 1
1 2
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1 RECIPIENT ID CODE/NAME HOLIAN, B OC G IL 01 R/SAIB NSIC COPIES LTTR ENCL 2
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NOTE TO ALL"RIDS" RECIPIENTS:
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PLEASE HELP US TO REDUCE KVASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 18 ENCL 17
Arizona Public Service Company P.O. BOX 53999
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PHOENIX. ARIZONA85072-3999 WILLIAMF. CONWAY EXECUTIVEVICEPRESIDENT NUCLEAR U. S. Nuclear Regulatory Commission ATIN: Document Control Desk Mail Station P1-37 Washington, D.C. 20555
Dear Sirs:
102-02877-WFC/RAB/2 J E March 24, 1994 94p+Q40202 05000528 9+032 pgOCK
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Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Unit 1 Docket No. STN 50-528 Request forTemporary Exemption from One Requirement of 10CFR50, Appendix J, Section III.D.1.a File: 94-056-026 Pursuant to 10 CFR 50.12, Arizona Public Service Company (APS) is requesting a
temporary exemption for PVNGS Unit 1 from one requirement of 10 CFR 50, Appendix J, Section III.D.1.a. That section of Appendix J requires PVNGS Unit 1 to perform three overall Integrated Containment Leakage Rate (ILRT) tests (also known as Type A tests) during each 10-year service period, at a roximatel e
ual intervals, with the third test of each set to be conducted during the Unit 1 shutdown for the 10-year plant inservice inspection (ISI).
The PVNGS Unit 1 Technical Specification Section 4.6.1.2 requires that APS meet the Appendix J requirements using methods and provisions of ANSI N45.4-1972.
The three Type A ILRTtests at PVNGS Unit 1 are required to be conducted in each 10-year period at intervals ranging between 30 and 50 months during plant shutdowns.
APS has submitted a request to the NRC to delete the reference to the length of intervals between Type A tests from Section 4.6.1.2 in the Technical Specification.
This exemption request proposes that the Unit 1 third Type A ILRT test be conducted during the Unit 1 fifth refueling outage (1R5) which is planned for the Spring Quarter of 1995.
The resulting time interval between the second and the third Type A tests would then be about 61 months.
This time interval exceeds the "a roximatel e
ual intervals in each 10- ear eriod" set in 10 CFR 50 Appendix J. The Unit 1 fourth Type A test will coincide with the 10-year plant ISI in 1998.
The enclosure to this letter provides justification for this exemption and the special circumstances as required by 10 CFR 50.12.
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U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Request for Temporary Exemption from One Requirement of 10 CFR 50 Page 2 If you have any questions, please contact Richard A. Bernier at (602) 393-5882.
Sincerely, WFC/RAB/ZJE/did Enclosure 1.
K. E. Perkins, Jr.
K. E. Johnston B. E. Holian
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ENCLOSVRE 10 CFR 50 Appendix J Exemption Request Associated with the Schedule for the Third Type A Tests i
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In order to ensure that offsite doses remain below those previously evaluated in the event of a design basis accident, leakage from the primary containment must be limited. Periodic testing of leakage rates are per'formed to verify that the leakage rate remains within these established limits. Specifically, 10 CFR 50.54(o) requires primary'eactor containments for PWRs to be tested for leakage as set forth in Appendix J to 10 CFR 50.
Palo Verde Nuclear Generating Station (PVNGS) Unit 1 Technical Specification Section 3/4.6.1.2 "Containment Leakage Surveillance Requirements" provides explicit requirements for test conditions, time intervals, and acceptance criteria.
Descri tion of the Pro osed Exem tion Re uest:"
The Unit 1 pre-operational Integrated Leakage Rate Tests, (ILRT)Type Awere performed in December 1982. The first of the required set of three Type A tests per 10-year period was performed in May 1986, which corresponded to a time interval of 41 months.
The second type Atest in Unit 1 was performed in February 1990, which corresponded to a time interval of 45 months.
The third Type A test in Unit 1 has not been performed yet. This required third Type A test is currently planned for Spring 1995 to coincide with Unit 1 refueling outage 5 (1R5). Allthree Type Atests are required to be performed during plant outages:
Consequently, the resulting time interval for the third Type A test would be 61 months.
Unit 1 Technical Specification Section 4.6.1.2 and 10 CFR 50 Appendix J require that the set of three Type A tests in each 10-year time period be. distributed in approximately equal lengths.
Thus, the schedule for the third Unit 1 Type A test is not strictly in accordance with 10 CFR 50 Appendix J. The Unit 1 Technical Specification Section 4.6.1.2 interprets the "approximately equal intervals" requirement as intervals ranging between 30 and 50 months.
Arizona Public Service (APS) has submitted a request to the NRC to delete that reference to Type A test intervals from Technical Specification Section 4.6.1.2.
APS proposes a one-time, temporary exemption from this one requirement of 10 CFR 50 Appendix J, Section III.D.1 (a) regarding "approximately equal time intervals".
This proposed amendment would allow APS to delay the'required Unit 1 third Type A test until the Spring 1995 Unit 1 refueling outage.
Another Type A test in Unit 1 willbe scheduled in 1998 concurrent with the 10-year ISI. The 10-year Unit 1 ISI has been extended to 1998 due to a Unit extended outage in 1989/1990.
ustifications for the Pro osed Exem tion Re uest:
The schedule to perform the third Type Aleakage rate test in Unit 1 during the Spring 1995 refueling outage preserves the main Appendix J requirement of three tests in each 10-year period of plant service.
Furthermore, the fourth Unit 1 Type A leakage rate test would be planned to coincide with the 1998 plant 10-year ISI. Since the second Type A ILRTtest in
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Unit 1, APS has. performed Types B and C local leakage rate tests during each refueling outage, as well as during non-outage plant condition. These tests are conducted to maintain the total combined Types B and C maximum pathway leakage at less than 0.06 percent per day.
Nuclear industry experience gathered for the preparation of draft NUREG-1493 indicated that Type A ILRTtests are credited for the detection of no more than 3 percent of failure mechanisms that caused leakages which otherwise would not have been detected by, local tests Types B and C.
The Type A leakage rate test results obtained in the first and second Type A tests were significantly below the test a'cceptance criteria set in 10 CFR 50 Appendix J, as well as in Unit 1 Technical Specification Section 3/4.6.1.2.,Those results were 0.0664 percent and 0.067 percent respectively.
The acceptance criteria is set at 0.075 percent by volume.
Therefore, there exists special circumstances as'sociated with the Unit 1 ISI 10-year schedule and the third Type A leakage rate test requirement.
APS concluded that the best approach under these circumstances is to allow for an approximately 61 month time interval for the third required Unit 1 Type A test while preserving the main requirements of 10 CFR 50 Appendix J. APS also concluded that this request for temporary exemption to allow for the conduct of the third Type A test during the Spring 1995 Unit 1 refueling outage will not present an undue risk to the public's health and safety'.
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