ML18092B458

Requests That Existing Exemption from Requirements of 10CFR50,App J,Section III.D.2(b)(ii) Be Amended to Include Replacement of Seal Leakage Testing for Overall Airlock Leakage Testing After Maint on Airlock Door Seals

ML18092B458
Person / Time
Site:	Salem
Issue date:	03/13/1987
From:	Corbin McNeil Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLR-N87037, NUDOCS 8703180467
Download: ML18092B458 (6)

Text

"*

Public Service Electric and Gas Company Corbin A. McNeil!, Jr. Public Service Electric and Gas Company P.O. Box236, Han cocks Bridge, NJ 08038 609 339-4800 Vice President -

Nuclear MAR 1 3 1987 NLR-N87037 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

AMENDED REQUEST FOR 10CFR50, APPENDIX J EXEMPTION SALEM GENERATING STATION FACILITY OPERATING LICENSES DPR-70 AND DPR-75 UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 On June 19, 1986, Public Service Electric and Gas Company (PSE&G) was granted an exemption from the 10CFR50, Appendix J, Section III.D.2(b)(ii) requirement to conduct a full pressure airlock leakage test whenever air locks are opened during periods when containment integrity is not required. The exemption did not, however, reflect our request to substitute the seal leakage testing described in 10CFR50, Appendix J, Section III.D.2(b)(iii) for overall airlock leakage testing after maintenance has been performed specifically on the airlock door seals. As such, we hereby request, in accordance with the provisions of 10CFR50.12a, that the existing exemption from the requirements of 10CFR50, Appendix J, Section III.D.2(b)(ii) be amended to include the aforementioned door seal testing requirement when maintenance is only performed on the door seals.

EXEMPTION REQUEST This exemption will relieve the requirement to conduct a full pressure airlock leakage test whenever airlocks are opened if either no maintenance has been performed that affects airlock sealing capabilities or if maintenance is performed only on the door seals. A full pressure test of airlock leakage will continue to be performed at least once per six months and following maintenance that could affect airlock sealing capability other than specific maintenance on the door seals.

This frequency of full pressure airlock testing will verify that the sealing capability of the airlock has not degraded as a

. 8703180467 870313

~DR ADOCK 05000272 PDR

MAR 13 1987 Document Control Desk 2 result of routine use or maintenance since the last time the full pressure test was conducted and that the overall airlock leakage rate is within its Technical Specification limit. Performance of a seal test after specific maintenance on the door seals will be sufficient to verify the integrity and sealing capability of the seals.

There is no undue risk to public health and safety involved with plant operation with the requested exemption in place. Nothing is contained in the exemption request that is inconsistent with the common defense and security. Finally, the exemption, as requested, has been reviewed and has been found to be authorized by law.

SPECIAL JUSTIFYING CIRCUMSTANCES The special circumstances present which justify the Commission's consideration of this exemption request conform to the following paragraphs in 10CFR50.12a:

50.12(a)(2)(ii) Application of the regulation in this circumstance is not necessary to achieve the underlying purpose of 10CFR50, 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 full pressure testing when maintenance is performed on the airlock that affects sealing capacity other than the door seals will provide assurance that 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 the Salem plants. Performance of the leakage rate tests required by paragraph III.D.2(b)(ii) takes approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 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 can presently occur several times during a refueling outage and ultimately can delay mode change on start up. Additionally, the extra testing is a drain on manpower resources with little or no resulting increase in assurance that the airlock will not experience excessive leakage.

MAR 13 1987 Document Control Desk 3 TECHNICAL CONSIDERATIONS The following considerations have been taken into account in our evaluation of the safety and environmental impact attendant to this exemption request:

0 To assure airlock leakage is within specified limits, an airlock leakage test at design pressure will be performed prior to establishing primary containment integrity when maintenance has been performed on the airlock that could affect its sealing capability other than on the door seals. An airlock seal test will be performed within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following each closure, except when the airlock is being used for multiple entries and then at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

0 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) shaft seals experience very little alteration as the shafts rotate within packing. History indicates the shaft seals are very effective in maintaining the sealing capability, even with door operation, and a complete test every six months and after maintenance is sufficient to assure operability.

0 In contrast to the shaft seals,_ the door seals could experience significant alteration when the doors are cycled. The alterations occur as the knife edges impact the seals. Pressurization of the volume between the door seals after each opening, after maintenance which could affect airlock door gaskets, and prior to establishing containment integrity, provides the necessary surveillance to ensure the sealing capability of the door seals.

It should also be noted that NRC has indicated the acceptability of the testing ref erred to in this exemption request by way of the proposed rule change for 10CFR50, Appendix J published in the October 29, 1986 issue of the Federal Register (pages 39538-39544). The proposed rule specifically excludes the requirement for full pressure airlock testing whenever maintenance is performed on the airlock which is specifically related to the door seals. The background information provided in the proposed rule states that the revision "is limited to corrections and clarifications, and excludes new criteria" (51FR39538). The proposed rule also affirmed that, if adopted, it "would not be a major Federal Action significantly affecting the quality of the human environment and therefore an environmental impact statement is not required" (51FR39540) and also that no offsite radiological environmental impacts are

llftR 1 3 1987 Document Control Desk 4 involved. The availability of the environmental assessment and finding of no significant impact was also noted in the proposed rule.

CONCLUSION The granting of the requested exemption would allow the substitution of an airlock seal test for an overall airlock pressure test after maintenance has been performed solely on the door seals. With respect to this exemption from Appendix J, the increment of increased risk to public health and safety is related solely to the potential increased probability for, and magnitude of, containment leakage during an accident which could lead to potentially greater offsite radiological consequences.

The potential increase due to this exemption is small and should result only from the potential leakage path through *the door operator shaft seals which will not be measured by this modified test. However, 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)(ii) of Appendix J, and the testing requirements when maintenance other than on the door seals is performed on the airlock, will measure the leakage through the door operator shaft seals and, if current, provide assurance that the airlock will not leak excessively and will not affect containment integrity or increase the risk of any facility accidents. Therefore, post accident radiological releases will not exceed previously determined values. The exemption has no impact on plant radiological or non-radiological effluents and involves no significant occupational exposure. This conclusion has been substantiated by the NRC through statements in 51FR39538-39544 regarding a proposed rule change for 10CFR50, Appendix J.

In accordance with the application fee requirements of 10CFR170.21, a check in the amount of $150.00 was submitted with initial exemption request dated April 11, 1986.

This submittal includes three (3) signed originals and forty (40) copies.

Sincerely,

Document Control Desk 5 MAR 1 *3 J987 C Mr. D. C. Fischer Licensing Project Manager Mr. T. J. Kenny Senior Resident Inspector Dr. Thomas E. Murley Regional Administrator NRC Region I

Ref: EXEMPTION REQUEST 10CFRSO, App. J STATE OF NEW JERSEY )

) SS.

COUNTY OF SALEM )

Corbin A. McNeill, Jr., being duly sworn according to law deposes and says:

I am Vice President of Public Service Electric and Gas Company, and as such, I find the matters set forth in our letter dated March 13, 198~ concerning our amended request for exemption from the requirements of 10CFR50, Appendix J, III.D.2(b)(ii) for Facility Operating Licenses DPR-70 and DPR-75, are true to the best of my knowledge, information and belief.

/.._B/"/>1 day of Subscrib~9 and Sworn to before me this ~M./J , 198 7

~,,~fv/~

NOtary Public of New Jersey onoms D. HADDEN ANotary Public of New Jersey My Commission fxpires March 14, 1990 My Commission expires on