ML18113A669
| ML18113A669 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 11/29/1978 |
| From: | Stello V Office of Nuclear Reactor Regulation |
| To: | Proffitt W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| References | |
| NUDOCS 7812110063 | |
| Download: ML18113A669 (5) | |
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November 29, 197~
DISTRIBUTIOfL Docket Fi15Q-28V and 50-281 Docket Nos. 50-280 and 50-281 Virginia Electric and Power Company ATTN:
Mr. W. L. P,roffitt
- Senior Vice President - Power Post Office Box 26666 Richmond,, Virginia 23261 Gentlemen:*
ORBl Rdg NRC PDR Local PDR V. Stello B. Grimes A. Schwencer D. Neighbors C. Parrish OELD I&E(3)
D. Eisenhut TERA J. Buchanan ACRS ( 16)
By letter dated Septernber 229, 1978, you requested amendments which would change the Surry Power Station Units 1 and 2 Technical Speci-fications, Section 4.49 "Containment Tests 11
- This c*hanqe would reference 10* CFR 50 Appendix J except for the containment personnel air lock, which would be an exemption to Appendix J.
You proposed_that-the containment personnel air lock be leak tested at four month intervals with no intermediate tests should the air locks be opened during such i nterva 1 s.
Based on our re 1:1iew of your propo$ed testing program for the contain-ment person-nel air lock, we have concluded tb_at it is not acceptable because it does not provide alternate testing methods which meet the intent of Appendix J.
We have enclosed our position on containment air.locks whi.ch provides
'acceptable methods for testing.
We* request that, since we cannot accept your proposal as stated~ you pro vi de an alternat:ive using the guida,_nce enclosed.
Until such time that a specifjc exemption from the air lock testing requirements of Appendix J is granted, you must meet the air lock testing requirements at six month intervals and after each opening.
Your response is requested within JO.days of the date of this so that we may continue our review.
Sincerely, Original Signed By~
1'ic'5or Stello, Director Ot.i'il..Jl.
- SEE PREVIOUS YELLOW 'FOR-- *coNCURRErCE Division of Operating Reactors -t: <;4~F
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e Docket Nos. 50..-280 and 50-281 ia El e_ctric and Power Company 1r. W. L. Proffitt nior Vice President - Power
- 'Post Offi e Box 26666
- Richmond, 23261 Gentlemen:
DISTRIBUTION Docket Files 50-280 ORB1 Rdg NRC PDR Local PDR V. Stello B. Grimes and 50-281 A. Schw~ncer D. Neighbors
- C. Parrish OELD I&E (3)
D. Eisenhut TERA J. Buchana ACRS (16)
By letter date September 22, 1978; you re.* ested amendments which would change the Surry Power Station Unit* land 2 Technical Speci-fications, Sectim 4.4, 11Containment,]e *s 11 This change would ref eren*ce l O CFR 5 Appendix J except or the containment personne 1 air lock, wh-rch wou be an exemptiop to Appendix J.
You proposed that the ontainment ~rsonnel air lock be leak tested*
at four month intervals 1ith no * "termediate tests should the air locks be opened during s hint rvals.
Based on our review.of your posed testing program for the contain-:-*
ment personnel air lock, w Ii ve concluded that it is not acceptable*
because it does not provi al ernate testing methods.which meet the intent of Appendix J We have enclosed our sition on c ntainment air locks which provfdes acceptable methods fr testing.
We equest that, since we cannot accept your propos as stated~ you ovide an alternative using the guidance enclosed Your response is r quested within 30 days of the date of this let er so that*we may cont*nue our review.
cc:
w/encl osure Victor Stello, Director Division of Ope. ting Reactors Office of Nuclea Reactor Regulatdion
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Virginia Electric & Perr Company Cc cc:
Mr. Michael W. Maupin Hunton & Williams Post Office Box 1535 Richmond, Virginia 23213 Swem Library College of William & Mary Williamsburg, Virginia 23185 Donald J. Burke USNRC, Region II 2 -
Office of Inspection and Enforcement 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 November 29, 1978
C r:.
e CONTAINMENT AIRLOCKS Appendix J to 10 CFR 50 requires that reactor containment airlocks be leak tested at the peak calculated accident pressure (Pa) at six month intervals.
Further, should the air locks be opened during such intervals, the airlocks will be leak tested after each opening.
Appendix J calls out these specific requirements for airlocks because they represent a potentially large leakage path that is more subject to human error than other isolation barriers.
The staff's interpretation of the objectives of the airlocks leak testing requirements are (1) that the six month test will provide an integrated leakage rate for the entire airlock assembly, including electrical and mechanical penetrations, the airlock cyclinder, hinge assemblies, welded connections, and other potential leakage paths; and (2) that the 11after.each opening 11 test would provide a means of assuring that the door seals had not been damaged or seated improperly during airlock use.
For those operating facilities that were designed and constructed prior to the issuance of Appendix J, consideration has been given to alternatives to the specific testing requirements which will meet the intent of Appendix J. Listed below are a numbe~ of guidelines which may be useful.
- 1. At six month intervals, the entire airlock assembly must be
. leak tested at the peak pressure. Pa.
If the test pressure will 1 ift the inner ai.rlock door off its seat, strongbacks or other mechanical devices should be used so that meaningful test results can be obtained at Pa.
~.. 2.
Should the airlock be opened during the interval between the six month tests, the airlock door seals shall be leak tested within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of the first of a series of openings. This relaxation in the 11after each opening 11 test requirement of Appendix J recognizes that a significant amount of time is requir~d to conduct these intermediate tests in relation to the frequ.ency of use of the airlock. These tests would be conducted whenever containment integrity is required.
- 3.
For those plants which require the use of strong back or clamps to leak test the door seals at a pressure Pa, a lower pressure (e.g.,
manufacturer's recommended pressure which would not require the use of such clamping devices) should be used to conduct the intermediate tests.
The results of leakage tests at the lower pressure shall be conservatively ex~rapolated to a leakage rate at the accident pressure Pa to determine acceptability.
- 4.
In lieu of the intermediate tests an acceptable alternative would be the use of a continuous leakage monitoring system.
As in the case of reduced pressure intennediate tests it must be demonstrated that the leakage rate using a continuous pressurized monitoring system is sufficiently sensitive, and can and will be conservatively extrapolated to the leakage rate that would be experienced under accident conditions (e.g., at a pressure of Pa).