ML18152B104

Requests Exemption from 10CFR50,App J,Paragraph III.A.6(b) Requirement to Perform Type a Test Every Outage Until Two Consecutive Tests Meet Acceptance Criteria & Resume Normal Test Schedule in Accordance,Per Paragraph Iii.D.Fee Paid

ML18152B104
Person / Time
Site:	Surry
Issue date:	08/12/1988
From:	Cruden D VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
88-278, NUDOCS 8808290267
Download: ML18152B104 (7)

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VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 August 12, 1988 D.S.CRUDEN VICE PRESIDENT-NUCLEAR United States Nuclear Regulatory Commission Serial No.88-278 Attention: Document Control Desk NO/ETS: vl h Washington, D.C. 20555 Docket No. 50-281 License No. DPR-37 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNIT 2 10 CFR 50 APPENDIX J EXEMPTION REQUEST Pursuant to 10 CFR 50.12, Virginia Electric and Power Company requests an exemption from 10 CFR 50, Appendix J, Paragraph III.A.6(b), which requires, in part, that "if two consecutive periodic Type A tests fail to meet the appli-cable acceptance criteria in III.A.5.b ... a Type A test shall be performed at each plant shutdown for refueling or approximately 18 months, whichever occurs first until two consecutive Type A tests meet the acceptance criteria in III.A.5. (b), after which time the retest schedule specified in III.D may be resumed." We believe that the purpose of Type A testing is to measure and ensure that the leakage through the primary reactor containment does not exceed the maximum allowable leakage rate. It also provides assurance that periodic surveillance, maintenance and repairs are made to systems or com-ponents penetrating the containment. Our last three Type A tests have demon-strated that containment integrity has not significantly degraded over the operating cycle. Therefore, Virginia Electric and Power Company requests an exemption from the schedular requirements of paragraph III.A.6(b) to perform a Type A test every outage until two consecutive tests meet the acceptance criteria and resume our normal test schedule in accordance with III.D.

The containment sump isolation valves (TV-DA-100/200 A&B) have been the major contributor to our containment leakage problems for several outages. These valves have been replaced and are no longer a continuing source of containment leakage. Also, technical justifications have been submitted to your office to resolve the containment Type A testing issues i dent i fi ed in NRC inspection report 50-281/86-36. With the successful resolution of the two technical issues and our corrective action program for the containment sump i sol at ion valves (see Attachment 1), we feel we have met the intent of the regulation in establishing containment integrity (leakage rate less than 0.75 La), and maintaining that integrity over the operating cycle.

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Therefore, Virginia Electric and Power Company believes that this exemption should be granted pursuant to 10 CFR 50.12(a)(2)(ii) and (v), in that:

application of the regulation in this particular instance is not necessary to achieve the underlying purpose of the rule which is to measure and ensure that leakage through the primary containment does not exceed the allowable leakage rate at any time during the operating cycle; and, the exemption would provide only temporary relief from the applicable requirement and we have made a good faith effort to comply with the regulation. This one-time exemption will enable Surry Unit 2 to resume the retest schedule specified in Section III.D of 10 CFR 50, Appendix J and therefore, prevent unnecessary pressurization of the containment to design basis pressure. Pursuant to 10CFR170.12 an application fee of $150 is enclosed.

If you have any questions or need additional information to process this request, please contact us.

Very truly yours,

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Attachments cc: U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N. W.

Suite 2900 Atlanta, Georgia 30323 Mr. W. E. Holland NRC Senior Resident Inspector Surry Power Station Mr. Chandu P. Pat~l NRC Surry Project Manager Project Directorate II-2 Division of Reactor Projects - I/II

ATTACHMENT I Corrective Action Program Leak Rate Testing Program

Corrective Action Program I. Problem Surry Unit 2 was unable to satisfy the "as-found" condition for the 1983, 1985 and 1986 Type A tests due to leakage penalty additions from Type C testing. In each case the leakage was associated with penetrations/

valves in systems that are normally filled with water and operating under post accident conditions and/or the containment sump i sol at ion valves (TV-DA-100/200 A & B).

The fo 11 owing are the test results of the previous three Type A tests.

In each case, the test results indicate that containment integrity has been maintained.

1983 Type A Test Weight Percent Per Day As-found Type A results 0.060643 Type C penalty without "water-fi 11 ed" 0.00504 and containment sump penetrations TOTAL 0.065683 As-found Type A results 0.060643 Type C penalty with "water-filled" and a) 0.0446 containment sump penetrations TOTAL 0.105243 a) specific contributors were penetrations #46 RCS loop fill, #69 recirculation spray and #38 containment sump valves; each with leakage greater than 40 SCFH 1

1985 Type A Test Weight Percent Per Day As-found Type A 0.061023 Type C penalty without "water-fi 11 ed" 0 .011049 and containment sump penetrations TOTAL 0.072072 As-found Type A 0.061023 Type C penalty with "water-filled" b) 0.03481 and containment sump penetrations TOTAL 0.095833 b) specific contributors were penetrations #7 safety injection, #38 containment sump valve; each with leakage greater than 20 SCFH 1986 Type A Test Weight Percent Per Day As-found Type A 0.063838 Type C penalty without "water-filled" 0. 00898106 and containment sump penetrations TOTAL 0.07281906 As-found Type A 0.063838 Type C penalty with "water-filled" c) > 0.208364 and containment sump penetrations TOTAL > 0. 272202 c) specific contributors were penetrations #46 RCS loop fill and #38 containment sump valves; both with leakage greater than 300 SCFH "as-found

Both in 1983, 1985, and 1986, the problem penetration(s) was either a penetration that is normally filled with water and operating under post-accident conditions or the containment sump isolation valves. For each test, the as-found leakage on these valves caused the results of the "as-found" integrated leak rate to exceed 0.075 weight percent per day.

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II.

Corrective Actions A. Safety System Valves Engineering eva 1uat ions have been performed in accordance with the standard review plan to demonstrate that specific penetrations in safety systems are normally operating and filled with water under post-accident conditions. See Virginia Electric and Power Company submittal dated February 29, 1988, Serial Number 88-707A.

Therefore, these penetrations/valves are not a credible leakage path from containment during design basis accidents.

8. TV-DA-100/200 A & B (penetration #38)

After we discovered the deficiencies with the original containment isolation valves, Type C testing was performed on these valves every unit cold shutdown and repairs were made as necessary until valve replacement.

The containment sump isolation valves were redesigned and replaced in 1986. In order to improve the reliability of this penetration/

valves, the system design was also modified to include a process control check valve. This valve cycles with the containment sump pump leaving TV-DA-100/200 A & B open, which prevents excessive wear on the sump isolation valves. The following are the results of Type C testing for TV-DA-100/200 A &B.

Unit 1 TV-DA-lOOA TV-DA-1008 05-22 Replaced Valve 05-22 Replaced Valve 06-21 0.0 SCFH (Initial test) 06-21 0.0 SCFH (Initial test) 07-09 0.90 SCFH (As-left) 09-11 255.0 SCFH (As-found) 09-11 0.0 SCFH (As-found/left)

Valve Packing Problem Penetration at 255 SCFH 09-22 0.0 SCFH (As-left) see 09-11-86 (lOOA) 12-12 0.32 SCFH (As-found) 12-12 31.43 SCFH (As-found) 01-13 0.0 SCFH (As-left) 01-13 0.0 SCFH (As-left) 05-19 305 SCFH (As-found) 05-26 0.0 SCFH (As-found/left)

Valve Actuation Problem Replaced gasket Air Operator Froze 05-21 0.0 SCFH (As-left) 04-16 0.109 SCFH (As-found) 04-16 4.99 SCFH (As-found) 04-27 0.0 SCFH (As-left) 05-24 0.0 SCFH (As-left) 3

Unit 2 TV-DA-200A TV-DA-200B 10-08 Replaced Valve 10-08 Replaced Valve 11-14 0.0 SCFH (Initial test) 11-14 0.0 SCFH (Initial test) 12-10 0.0 SCFH (As-found/left) 12-10 0.269 SCFH (As-found/left)

III. Integrated Leak Rate Test - 1988 Refueling Guidance given in IE Information Notice 85-71 indicates that an improved maintenance and test program (Corrective Action Program) for containment penetration boundaries and isolation valves could be an acceptable alternative to increasing the frequency of Type A tests.

Therefore, our Corrective Action Program, as described, has assured that containment integrity is being maintained in that, the last three Unit 2 Type A tests have been successful, only the Type C leakage penalty has caused us to exceed the Type A "as-found" criteria. The penetrations/

valves with the high Type C leakage are associated with systems that are normally water filled and operating under post accident conditions and are not considered credible leakage sources or have been replaced with a more reliable design. Thus, the overall plan will ensure in the event of an accident that the dose levels wi 11 not exceed 10 CFR 100 limits.

Therefore, these corrective actions for the overall containment leak rate test program have ful fi 11 ed the requirements of increased frequency for Type A tests.

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