ML18153C282

Requests Exemption from 10CFR50,App J,Paragraph III.A.6(b), Which Requires That When Two Consecutive Periodic Type a Tests Fail to Meet Applicable Acceptance Criteria Type a Test Shall Be Performed at Plant

ML18153C282
Person / Time
Site:	Surry
Issue date:	07/03/1990
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
90-122A, NUDOCS 9007100340
Download: ML18153C282 (2)

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U . e VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 July 3, 1990 United States Nuclear Regulatory Commission Serial No. 90-122A Attention: Document Control Desk NL/ETS Washington, D. C. 20555 Docket No. 50-280 License No.DPR-32 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNIT 1 ADDITIONAL INFORMATION FOR THE 10 CFR 50 APPENDIX J EXEMPTION REQUEST Pursuant to 10 CFR 50.12, on April 5, 1990, Virginia Electric and Power Company requested an exemption from 10 CFR 50, Appendix J, Paragraph 111.A.6 (b), which requires, in part, that "if two consecutive periodic Type A tests fail to meet the applicable acceptance criteria in 111.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 111.A.5 (b), after which time the retest schedule specified in 111.D may be resumed."

Type A tests were performed in June 1981, April 1983, July 1986, and June 1988 for Unit 1. The 1981, 1983, and 1986 tests were performed in accordance with the Appendix J schedular requirements of conducting three tests within a ten year service interval. During a September, 1983, NRC inspection of the Unit 2 Type A test program (NRC IR 50-281/83-27) an open item was identified regarding the proper application of the requirement for evaluating the "as-found" as well as the "as-left" leakage.

Following resolution of the open item, proper application of the "as-found" leakage was used in the then next scheduled Type A test. During the next Type A test, in 1986, an "as-found" evaluation was performed which failed to meet the acceptance criterion.

At this point the results of the 1983 Type A test were reevaluated against the "as-tound" acceptance criterion and it was determined that the 1983 test failed to meet the recently applied acceptance criterion. Therefore, we have conservatively considered these two tests (1983 & 1986) to be failures and performed the 1988 Type A test in accordance with paragraph 111.A.6 (b). The Type A test performed in 1988 passed the "as-found" acceptance criterion. This successful test and the information provided in our letter dated April 5, 1990 (Serial No.90-122) form the basis of our exemption request.

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As stated in our previous submittal, 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 ensure that the leakage through the containment structure 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 regulation for which we have made a good faith effort to comply. This one-time exemption will enable Surry Unit 1 to resume the retest schedule specified in Section 111.D of 10 CFR 50, Appendix J and therefore, prevent unnecessary pressurization of the containment to design basis pressure.

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

W. L. Ste art Senior Vice President - Nuclear 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