ML17332A686
| ML17332A686 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 03/17/1995 |
| From: | Fitzpatrick E Indiana Michigan Power Co, (Formerly Indiana & Michigan Power Co) |
| To: | NRC/IRM |
| Shared Package | |
| ML17332A687 | List: |
| References | |
| AEP:NRC:1204D, NUDOCS 9503230136 | |
| Download: ML17332A686 (31) | |
Text
PR.IC3R.IMY 1 (ACCELERATED RIDS PROCESSING)
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS) l ACCESSION NBR: 9503230136 DOC. DATE: 95/03/17 NOTARIZED: YES DOCKET FACIL:50-315 Donald C.
Cook Nuclear Power Plant, Unit 1, Indiana M
05000315 AUTH.NAME AUTHOR AFFILIATION FITZPATRICK,E.
Indiana Michigan Power Co. (formerly Indiana
& Michigan Ele p
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
R
SUBJECT:
Application for amend to license DPR-58,proposing one-time mod to TS 4.6.1.2.a to defer performance of Type A overall ILRT for facility until next refueling outage, scheduled to begin approx May 1997.
DISTRIBUTION CODE:
A017D COPIES RECEIVED:LTR (
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TITLE: OR Submittal:
Append J Containment Leak Rate Testing NOTES:
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E'OTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACTTHE DOCUMENTCONTROL DESK, ROOM Pl-37 (EXT. 504-2083 ) TO ELIMINATEYOUR NAMEFROM DISTRIBUTIONLISTS I OR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
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S indiana Michigan Power Company P.O. Box 16631 Columbus, OH 43216 Narch 17, 1995 Docket No.: 50-315 AEP:NRC'1204D U.
S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.
C.
20555 Gentlemen:
Donald C.
Cook Nuclear Plant Unit 1 UNIT 1 CYCLE 14 TECHNICAL SPECIFICATION SURVEILLANCE INTERVAL EXTENSION FOR TYPE A LEAK RATE TESTING, AND ONE-TIME EXEMPTION FROM 10 CFR 50, APPENDIX J This letter constitutes an application for amendment to the Technical Specifications (T/Ss) for Donald C.
Cook Nuclear Plant Unit 1.
Pursuant to 10 CFR 50.12, this letter also requests a one-time exemption from 10 CFR 50, Appendix J, Section III.D.l(a).
Specifically, the request is to defer performance of the Type A containment integrated leakage rate test.
This test is currently scheduled to be performed prior to startup following the refueling outage in Unit 1, which is scheduled to begin in September 1995.
A description of the proposed T/S change, our analysis concerning significant hazards considerations, and our justification for the 10 CFR 50, Appendix J exemption are contained in Attachment 1.
The existing T/S
- page, marked to reflect the proposed
- change, is contained in Attachment 2.
The
- proposed, revised T/S page is contained in Attachment 3.
In accordance with 10 CFR 50.12, the exemption is justifiable since (1) it will not present an undue risk to the public health and
- safety, (2) the underlying purpose of the rule will be served, and (3) it is temporary, and the surveillance will be performed during the next refueling outage.
The Nuclear Regulatory Commission is considering similar requests from Union Electric and Baltimore Gas and Electric.
In accordance with 10 CFR 50.92(c),
our evaluation of the change indicates no significant hazards because the change does not (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously 950323013b 950317'DR
'ADOCK 05000315 P
" U. S. Nuclear Regulatory Commission Page 2
AEP'NRC'1204D evaluated, or (3) involve a significant reduction in the margin of safety.
The second ten-year inservice inspection interval for Unit 1 will end on July 1,
- 1996, and Unit 1 is currently scheduled for a Type A test to be performed during the upcoming refueling outage which begins in September 1995.
The use of this deferment is estimated to reduce the critical path time by approximately 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> by eliminating the Type A test.
Deferring the Type A test will save'pproximately
$130,000 in 1995 (Attachment 4),
therefore, this proposed amendment request is being submitted as a Cost Beneficial Licensing Action (CBLA).
Similar deferrals have been granted to other utilities in the recent past.
We request that approval be granted prior to July 1,
- 1995, to make the necessary scheduling changes for the upcoming Unit 1 outage.
These proposed changes have been reviewed and approved by the Plant Nuclear Safety Review Committee and by the Nuclear Safety and Design Review Committee.
In compliance with the requirements of 10 CFR 50.91(b)(1),
copies of this letter and its attachments have been transmitted to the Michigan Public Service Commission and to the Michigan Department of Public Health.
Sincerely,
,Y
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~(v E, E. Fitzpatrick Vice President SWORN TO AND SUBSCRIBED BEFORE ME THIS ~1~8 DAY OF
~
1995 otary Pub ic My Commission Expires:
eh Attachments
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U.
S. Nuclear Regulatory Commission Page 3
AEP:NRC:1204D CC:
A. A. Blind G. Charnoff J.
B. Martin NFEM Section Chief NRC Resident Inspector
- Bridgman J.
R. Padgett
ATTACHMENT 1 TO AEP:NRC:1204D 10 CFR 50.92 ANALYSIS FOR CHANGES TO THE DONALD C.
COOK NUCLEAR PLANT UNIT 1 TECHNICAL SPECIFICATIONS 10 CFR 50.12 JUSTIFICATION FOR EXEMPTION FROM THE REQUIREMENTS OF 10 CFR 50, APPENDIX J, SECTION III.D.1(a)
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ATTACHMENT 1 TO AEP:NRC:1204D Page 1
I.
DESCRIPTION OF THE CHANGES We propose a one-time modification to T/S 4.6.1.2.a to defer the performance of the Type A Overall Integrated Leakage Rate Test for Cook Nuclear Plant Unit 1.
We believe
- that, even with such a
- deferral, we willcontinue to meet the underlying purpose of 10 CFR 50, Appendix J by performing only the Type B and C tests at the end of Cycle 14.
In addition, valuable outage time and radiation exposure will be saved by deferring the Type A test.
The Type A surveillance will be completed during the next refueling outage, which is scheduled to begin approximately May 1997.
T/S 4.6.1.2.a currently states the following:
Types A,
B, and C
(Overall Integrated and Local Combined Leakage Rate) testing shall be conducted in accordance with the requirements specified in Appendix J to 10 CFR 50, as modified by approved exemptions.
We are proposing to modify this surveillance requirement with a footnote that reads as follows:
A one-time extension of the test interval is allowed for the third Type A test of the second 10-year service period originally scheduled to be performed at the end of Cycle 14.
The test will be performed prior to unit restart following the refueling outage that willfollow the end of Cycle 15
'ince the test interval of T/S 4.6.1.2.a pertaining to the Type A test is based on the requirements of 10 CFR 50, Appendix J, Section III.D.1(a),
a schedular exemption from this requirement is also being sought.
This exemption'equest is to provide temporary (one-time) relief of the performance of a Type A test which is typically required to be performed at approximately equal intervals during each 10-year service
- period, with the third test of each set conducted when the plant is shutdown for the 10-year plant inservice inspections.
II.
JUSTIFICATION FOR THE PROPOSED T
S CH GE AND AP ENDIX J EXEMPTION RE UEST T/S 4.6.1.2.a surveillance for the Type A test is due prior to restart from refueling after Cycle 14.
We are requesting a one-time extension to avoid unnecessary outage time and cost for performing the Type A test.
We believe that performance of the test can be deferred to the next refueling outage and that performance of the Type B and C test program is sufficient to ensure the leak tightness of the containment.
There have been six Type A tests successfully completed to date on Unit 1 without an adverse trend or indication of failure.
The data in Table 1 provides the results from the last three Type A tests.
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ATTACHMENT 1 TO AEP:NRC:1204D Page 2
The last three tests provide the most recent data and are representative of all the previous test results.
The first ten-year inservice inspection period Type A test was performed in August 1985.
The first and second Type A tests of the set of three tests for the second ten-year service period were conducted in June 1989 and September
- 1992, respectively.
This represents testing intervals of 46 and 39 months.
The third Type A test is currently scheduled to be performed prior to restart following the refueling outage after Cycle 14.
Deferring the third Type A test one cycle would result in an interval of approximately 57 months.
As illustrated in Table 1 and 'as indicated in the evaluation below, there have been no Type A test failures to date.
III.
EVALUATION The Cook Nuclear Plant containment system is designed to control the release of airborne radioactivity and direct mass and energy through the ice condensers following postulated design basis accidents.
The containment system consists of a
reinforced concrete cylindrical structure with a hemispherical dome.
The interior of the containment also has a welded steel liner, with a minimum thickness of 3/8" at the dome and wall and 1/4" at the bottom, which is attached to the inside face of the concrete shell to ensure a high degree of leak tightness.
The integrity and capability of the containment to perform its intended function is demonstrated by the performance of periodic testing.
Type A tests are defined in 10 CFR 50, Appendix J, Section II.F as those tests intended to measure the primary reactor containment overall integrated leakage rate at periodic intervals.
The time required to perform the Type A test necessitates that they be performed during refueling outages.
The major safety benefit achieved by performance of the Type A test is the detection of leakage not identified by the Type B and C test program such as a
leakage through the containment liner and reinforced concrete walls.
Prior to performance of the Type A test, a
general visual inspection of all accessible interior surfaces of the steel liner plate and exterior surfaces of the containment concrete wall is conducted.
This inspection is performed in accordance with T/S Surveillance Requirement 4.6.1.6 and approved plant procedures.
The purpose of the inspection is to detect any evidence of structural deterioration (corrosion or deformation of the steel liner and spalling and cracking of the concrete) which may affect the containment structural integrity or its leak tightness.
The previous inspections conducted in support of each of the periodic Type A
tests have identified no evidence of structural deterioration that would impact structural or leak tightness of containment.
In addition, absent actual accident conditions, structural deterioration is a gradual phenomenon requiring periods of time well in excess of the proposed interval extension.
Based on
- this, the visual inspection will still be performed in
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ATTACHMENT 1 TO AEP:NRC:1204D Page 3
accordance with approved plant procedures during the 1995 refueling outage.
Type B and C tests are used to determine leak rates through systems and components that penetrate containment.
The Cook Nuclear Plant Type B
and C test program provides reasonable assurance that containment integrity can be maintained.
Each penetration is assigned an administrative limit used for testing purposes.
The limit is used to identify any potential concern for a
given penetration and ensures that the containment does not come close to the allowable leak rate limit for the'ype B-'and C test program.
These tests are currently performed at least every two years, consistent with the requirements of 10 CFR 50, Appendix J.
Since the Type B
and C test program is unchanged, assurance that containment integrity is maintained can be verified by performance of the Type B and C test program at the end of Cycle 14, and by continued reliance on the results from previous Type A tests.
Data from the last three Type A tests (Table 1) illustrate that the as-found leakage rates were well below the acceptance limits established in 10 CFR 50, Appendix J and the T/S.
Appendix J and T/S require that the as-found leak rate be less than La (0'5 wtX/day) and that the as-left leak'ate be less than 75X of La (0.1875 wtX/day).
As illustrated in Table 1,
the as-found leak rates for the last three Type A tests were 0.10567, 0.05550, and 0.08716 wtX/day, respectively.
The results from the past three Type A tests support two different arguments for deferring the Type A test one cycle.
It can be seen from the August 1985 test that 81X (0.0857 wtX/day) of the as-found leak rate is contributed by Type B and C test penalties.
In addition, the as-left result was less than 12%
(0.02247 wtX/day) of the allowable 0.1875 wt%/day.
For the June 1989 Type A test, 49X (0.0272 wtX/day) of the as-found leak rate is contributed by Type B and C test penalties.
The as-left result, including Type B
and C penalties, was less than 18X (0.0333 wtX/day) of the allowable leak rate of 0.1875, wtX/day.
The September 1992 test only had 9X (0.0080 wtX/day) of the as-found leak rate contributed by Type B
and C test penalties.
This strongly illustrates that the Type B and C test program has made tremendous strides in limiting containment penetration leak rates over the past ten years by reducing the Type B and C leak rate penalties that apply to the as-found Type A test results.
The September 1992 as-left results were less than 45X (0.0830 wtX/day) of the allowable leak rate of 0.1875 wtX/day.
This seems high compared to the other two tests but is still significantly lower than the allowable limit.
One reason for the larger calculated leak rate is the fact that the two earlier tests were 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> tests and the September 1992 test was performed in eight hours.
Therefore, the September 1992 test had a significant statistical penalty applied to provide the 95X upper confidence level leak rate that was calculated.
The previous two tests had significantly more data in establishing the 95X upper confidence level leak rate.
The
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ATTACHMENT 1 TO AEP:NRC:1204D Page 4
points to be made are that both the as-found and as-left results from the Type A tests were less than 50X of the allowable leak
- rate, including penalties associated with the Type B and C testing program.
This information demonstrates that the containment is essentially leak tight, with ample margin for increased leakage conditions between periodic tests.
Based on this, we believe that the performance of the Type B and C testing program is a reasonable representation of the containment leak rate and that performance of this program in the 1995 Refueling Outage will provide reasonable verification of the leak tightness of the containment without performance of a Type A test.
Modifications that would alter the passive containment structure are infrequent and would receive extensive review to ensure containment capabilities are not diminished.
The Cook Nuclear Plant modification process and the 10 CFR 50.59 programs have been demonstrated to be effective in providing high quality oversight of safety significant modifications.
In addition, 10 CFR 50, Appendix J,
Section IV.A requires that containment integrated leak rate testing be performed following any major modification to t'e primary containment boundary.
This requirement willbe maintained.
There are no plans to make any such modifications to the containment in 1995 or 1996 that would require a Type A test to be performed.
The cost benefits associated with this one-time exemption are discussed in Attachment 2.
IV.
10 CFR 50 92 CRITERI Per 10 CFR 50.92, a
proposed change does not involve a
significant hazards consideration if the change does not:
involve a significant increase in the probability or consequences of an accident previously evaluated, 2.
create the possibility of a new or different kind of accident from any accident previously evaluated, or 3.
involve a significant reduction in a margin of safety.
Crite ion 1 The Cook Nuclear Plant Type A test history provides substantial justification for the proposed test schedule.
Three Type A tests were performed over a seven year period with successful results.
The tests indicate that the Cook Nuclear Plant has a low leakage containment.
In addition, there are no adverse trends in the results from the previous Types A, B, and C tests or visual inspections that indicate a gradual degradation of the containment boundary.
- Further, there are no structural modifications planned which would adversely affect the structural capability of the containment
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ATTACHMENT 1 TO AEP:NRC:1204D Page 5
and that would be a factor in deferring the Type A test one refueling outage.
Containment leak rate testing is not an initiator of any accident.
The proposed interval extension does not affect reactor operations or the accident analysis and has no radiological consequences, except for the dose savings associated with not performing the test.
There will be no changes to 10 CFR 100 dose limits or the control room dose limits.
Extending the test interval will not increase the probability of a malfunction of equipment important to safety.
Based on these considerations, it is concluded that the change does not involve a significaiit increase in the probability or consequences of an accident previously evaluated.
Criterion 2
The proposed change does not involve physical changes to the plant or changes in plant operating configuration.
The proposed change only relaxes the schedular requirements for conducting one Type A test from the T/Ss and defers performance of the test one cycle.
The purpose of the test is to provide periodic verific'ation of the leak-tight integrity of the primary reactor containment, and systems and components which penetrate containment.
The tests assure that leakage through containment and systems and components penetrating containment will not exceed the allowable leak rate values established in 10 CFR 50, Appendix J.
Thus, it is concluded that the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
ion 3 The proposed change to the schedule for performing the Type A test does not reduce the margin of safety assumed in the accident analysis for any release of radioactive materials or reduce any margin of safety preserved by the technical specifications.
The methodology, acceptance
- criteria, and the technical specification leak rate limits for the performance of the Type A test willnot change.
Type A tests will continue to be performed in accordance with 10 CFR 50, Appendix J and the applicable Cook Nuclear Plant Technical Specifications beginning in 1997.
In addition, there are no adverse trends in the results from the previous Type A, B, and C tests or visual inspections that indicate a gradual degradation of the containment boundary.
Based on these considerations, it is concluded that the change does not involve a significant reduction in a margin of safety.
0 CFR 50 12 CRITE Exemption from the requirements of 10 CFR 50, Appendix J, Section III.D.1(a) is justified in accordance with 10 CFR 50.12, "Specific
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ATTACHMENT 1 TO AEP:NRC:1204D Page 6
exemptions," Sections (a)(1), (a)(2)(ii), and (a)(2)(v) as follows.
(a)(1)
The exemption ".
. will not present an undue risk to the public health and safety The significant hazards consideration, per 10 CFR 50.92(c),
performed above provides justification that there will not be undue risk to the public health and safety.
As stated
- above, our significant improvement in Type B and C test results, and excellent Type A test
"'-results provide assurance that serious deterioration of containment integrity will not occur during the extension period.
(a)(2)(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."
The underlying purpose of Appendix J is to ensure that serious deterioration of containment integrity willnot occur.
Our examination of past Type A, B, and C leak rate
- tests, as discussed in the above evaluation, indicates that the anticipated 1995 total integrated leak rate of the containment, would be much less than the Appendix J
acceptance criteria.
Since the extension of the interval is only for one cycle, the time frame between Type A tests would change from approximately 37 to 57 months.
We believe that performing the surveillance in 1995 is not necessary to achieve the underlying purpose of the rule, which is to ensure the primary reactor containment overall integrated leak tightness at periodic intervals.
Our history indicates no Type A test failures (as-found or as-left) have occurred in the past and that our overall calculated leak rates are well within the established values of 10 CFR 50, Appendix J and Cook Nuclear Plant Technical Specifications.
Based on this, it is not anticipated that the requested deferral would lead to failure of the Type A test in 1997.
(a)(2)(v)
"The exemption would provide only temporary relief from the applicable regulation and the licensee has made good faith efforts to comply with the regulation."
The exemption is only being requested to delay the Type A leak rate test until the next scheduled refueling outage.
The exemption request is necessary to save outage time and expense in 1995 associated with the ten year inservice inspections.
As stated
- above, we feel that the previous Type A test data support a position that the Cook Nuclear Plant containment is free of any serious deterioration of the containment boundary and is essentially leak tight.
P I
ATTACHMENT 1 TO AEP:NRC:1204D Page 7
Table 1
Unit 1 Historical T e A Test Data for Cook Nuclear Plant CNP Technical Specification As-Left Limit for CNP is 0.1875 wtX/day DATE AS-FOUND AS-LEFT September,1992 (wtX/day)
Least Squares Fit Leak Rate(Lam) 95'.
UCL Leak Rate 0.0010 0 '7921 0.0010 0.07921 Type B and C Adjustments Repaired Valve Adjustments Total (Lines 2,3, and 4) 0.00379 0.00416 0.08716 0.00379 0.08300 June,1989 Least Squares Fit Leak Rate(Lan) 95%UCL Leak Rate (wt./day) 0.02083 0.02830 0.02083 0.'02830 Type B and C Adjustments Repaired Valve Adjustments Total (Lines 2,3, and 4) 0.00500 0.02220 0.05550 0.00500
- 0. 03330 August,1985 **
(wt%/day)
Least Squares Fit Leak Rate(La+)
95.UCL Leak Rate Type B and C Adjustments Repaired Valve Adjustments Sump level change in La Total (Lines 2,3,4, and 5) 0.00905 0.01677 0.00320 0.08320 0.00250 0.10567 0.00905 0.01677 0.00320 0.00250 0.02247 8 Hour Test 24 Hour Test
ATTACHMENT 2 TO AEP:NRC:1204D EXISTING TECHNICAL SPECIFICATION PAGE MARKED TO REFLECT PROPOSED CHANGES
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OR OP 3.6.1.2 Containment leakage rates shall be limited to.'.
An overall integrated leakage rate of sL, 0.25 percent by weight of the 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 12.0 psig, and b.
A combined leakage race of s0.60 L, for all penetracions and valves subject to Type B and C tests when pressurized co P,.
p cAB Nodes 1, 2, 3 and 4.
~CQ:ON:
Pith either (a) the measured overall integrated containment leakage rate exceeding 0.75 L,'r (b) with the measured combined leakage rate for all penetrations and valves subject to Types B and C tests exceeding 0.60 L, restore the leakage race (s) to within the limit(s) prior to increasing the Reactor Coolant System temperature above 200 P.
SUR TLLANCE RE UTREMENTS 4.6.1.2 b.
The containment leakage rates shall be demonstrated at the follo~ing'est schedule and shall be determined in conformance with the criteria specified in Appendix J of 10 CFR 50 using the methods and provisions of ANSI N45.4-1972:
- .lJ a.
Types A,
B, and C (Overall Integrated and Local Combined Leakage Rate) testing shall be conducted in accordance with the requirements specified in Appendix J to 10 CPR 50, as modified by approved exemptions. +
Each concainmenc air lock.shall ba, verified to be in compliance with the requiremencs of Specification 3.6.1.3.
c.
The provisions of Specification 4.0.2 are noc appucable.
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Cooew COOK NUCLEAR PLANT - UNIT 1 3/4 6-2 AMENDMENT NO. 48, 5N
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ATTACHMENT 3 TO AEP:NRC:1204D PROPOSED REVISED TECHNICAL SPECIFICATION PAGE
CONTAINMENT SYSTEMS CONTAINMENT LEAKAGE LIMITING CONDITION FOR OPERATION 3.6.1.2 Containment leakage rates shall be limited to:
a.
An overall integrated leakage rate of sL 0.25 percent by weight of the 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 12.0 psig, and b.
A combined leakage rate of s0.60 L, for all penetrations and valves subject to Types B and C tests when pressurized to P,.
APPLICABILITY: Modes.1, 2,
3 and 4.
ACTION:
With either (a) the measured overall integrated containment leakage rate exceeding 0.75 L, or (b) with the measured combined leakage rate for all penetrations and valves subject to Types B and C tests exceeding 0.60 L, restore the leakage rate(s) to within the limit(s) prior to increasing the Reactor Coolant System temperature above 2004F.
SURVEILLANCE RE UIREMENTS 4.6.1.2 The containment leakage rates shall be demonstrated at the following test schedule and shall be determined in conformance with the criteria specified in Appendix J of 10 CFR 50 using the methods and provisions of ANSI" N45.4-1972:
a
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Types A, B, and C (Overall Integrated and Local Combined Leakage Rate) testing shall be conducted in accordance with the requirements specified in Appendix J to 10 CFR 50, as modified by approved exemptions.t b.
Each containment air lock shall be verified to be in compliance with the requirements of Specification 3.6.1.3.
c.
The provisions of Specification 4.0.2 are not applicable.
A one-time extension of the test interval is allowed for the third Type A test of the second 10-year service period originally scheduled to be performed at the end of Cycle 14.
The test will be performed prior to unit restart following the refueling outage that will follow the end of Cycle 15.
COOK NUCLEAR PLANT - UNIT 1 3/4 6-2 AMENDMENT NO. 4$,460,ktP
ATTACHMENT 4 TO AEP'NRC:1204D DONALD C.
COOK NUCLEAR PLANT COST BENEFICIAL LICENSING ACTION FOR DEFERMENT OF A TYPE A TEST FROM 1995 TO 1997
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ATTACHMENT 4 TO AEP:NRC:1204D Page 1
Regulatory Requirement:
10 CFR 50, Appendix J provides the requirements for primary containment leakage testing for the Cook Nuclear Plant.
Appendix J requires that a
Type A test be performed in conjunction with the shutdown for the 10-year plant inservice inspection.
Effect of Requirement:
The effect of the requirement is to ensure that the primary reactor containment and systems and components penetrating containment shall not exceed allowable leak rate values as specified in the technical specifications.
Rationale for Regulatory Change:
The performance of a Type A test willnot provide assurance of the containment integrity commensurate with the cost of performing the test.
The data history from previous tests and the performance of the Type B and C testing program will provide reasonable assurance that the containment leakage rates are well within the allowable limits of Appendix J and the Cook Nuclear Plant Technical Specifications.
As a result, the deferment of the Type A test by one cycle will not affect the ability to assess the leak tight capability of the containment structure.
Approximate Cost of Requirement:
Historically, the critical path time associated with performing a Type A test is between 36 and 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br />.
The labor time savings for performance of the Type A test, including set-up and breakdown is estimated to be approximately
$54,000.
Equipment rental and calibration services are estimated to be approximately
$56,000.
It is also estimated that approximately 2 manrem of dose can be saved by not performing the Type A test.
At an associated cost of
$10,000 per
- manrem, this represents a savings of
$20,000.
Therefore, the total savings in 1995 associated with not performing the Type A test is
$130,000, not including 'the costs of replacement power.