ML18347A340

Conduct of Containment Leak Testing

ML18347A340
Person / Time
Site:	Palisades
Issue date:	09/11/1975
From:	Sewell R Consumers Power Co
To:	Goller K Office of Nuclear Reactor Regulation
References
Download: ML18347A340 (6)

Text

__,.,

September 11, Mr Karl L. Goller Division of Reactor Licensing US Nuclear Regulatory Commissi Washington, DC 20555 DOCKET 50-255, LICENSE DPR PALISADES PLANT consumers Power company By letter dated August 4, 1975 you noted that 10 CFR 50, Appendix J, was published February 14, 1973 and that some plants may not now be in full com-pliance with the requirements of this regulation as they were constructed prior to the issuance of this regulation.

You requested that we determine if we are conducting containment leakage testing at the Palisades Plant in full compliance with Appendix J and if we were not in full compliance that we identify planned actions and our schedule to obtain conformance to the Regulation.

You noted that possible courses of action included design modi-fications, amendments to the Technical Specifications, and request for ex-emption pursuant to 10 CFR 50.12.

We have reviewed the requirements of Appendix J and the procedures utilized in containment leakage testing.

• We note that on April 10, 1973 we proposed Technical Specifications changes to update the containment leak rate testing requirements so that they would be in accordance with the provisions of the then recently issued Appendix J, insofar as practical.

The results of the review are summarized in the attachment to this letter. It was noted that several minor procedural revisions are required to insure that some of the detail of Appendix J is not overlooked during leakage testing.

These procedure changes will be completed within about 30 days.

In addition, one exemption from Appendix J is required.

Pursuant to 10 CFR 50.12, Consumers Power Company hereby requests a specific exemption from the requirement that the personnel air lock be tested after each opening.

This requirement is contained in 10 CFR 50, Appendix J, Section III.D.2.

The Palisades Plant was designed, constructed, and licensed prior to the issuance of Appendix J.

During design and construction, it was anticipated that access to portions of the containment would be routinely available during operation and equipment was located and installed based on this philosophy.

Thus, during

2 routine operations, access to the containment via the personnel lock is required two to three times a week.

During start-up access to the containment through the personnel lock is required many times per day.

In order to perform a local leak test o*n the personnel lock, a "strongback" or test clamps must be utilized on the inner door of the lock.

The test clamp, fully installed, requires installing and torquing 48 bolts in place through the strongback clamps.

The lock must then be pressurized, allowed to stabilize, tested, blown down and the strongback test clamps removed before entry can be made again.

This test process takes a minimum of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to perform.

Thus, we have concluded that it is not feasible to test the personnel lock after each opening.

Early in plant life, minor deficiencies were detected during local leak testing of the personnel lock.

These deficiencies have been corrected.

For the past several years, the results of local leak test performed on the personnel lock at six-month intervals have been satisfactory with no corrective action required.

We believe that this demonstrates that there is no requirement to perform local leak testing of the personnel lock at.intervals more frequent than six months and, therefore, have concluded that issuance of this specific exemption will not endanger life or property and is in the public interest.

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SUMMARY

OF PALISADES PLANT Status of Conformance to 10 CFR 50, Appendix J III. *Leakage Testing Requirements All preoperational tests have been completed by Bechtel as reported in their Job Number 5935 "Containment Building Integrated Leak Rate Test,"

of May 20, 1970.

A.

Type A Test

1. Pretest Requirements

a.

The specified containment inspection is presently not specified in our procedures.

This, prior to the Type A test inspection, will be included in our procedures, along with any require-ments or restrictions associated with the inspection.

The requirement for identifying potential excessive leakage paths is included in our "Containment Integrated Leak Rate Test Procedure" (M-CLP-1, Rev 0), but the procedure does not specifically state that the local leak testing required when excessive leaks are folind be carried out at the pressure Pt.

This appropriate pressure designation will be included in our procedures.

Also, it is not, at this time, mentioned in our procedures that during the supplemental testing for leak rate accuracy poten~

tially excessive leakage paths might* be identified. This fact will be included in our procedures along with the proper re-porting requirements.

b. Presently, our procedures do not specify that the repair in-formation on valve closure maintenance, if any, be included in the report on the test to the commission.

The fact will be specified in our procedures.

c.

We are in full compliance.

d.

We are in full compliance.

2.

Conduct of Tests We are in full compliance.

3.

Test Methods

a.

We are in full compliance,

• Outline corresponds to 10 CFR 50, Appendix J.

1

b.

We are in full compliance.

c.

We are in full compliance.

4.

Preoperational Leakage Rate Tests All preoperational testing has been completed.

5.

Periodic Leakage Rate Tests

a.

Test Pressure (1)

We are in compliance.

(2)

Not applicable.

b.

Acceptance Criteria (1)

The Palisades Technical Specifications limit the leakage rate Ltm to less than 0.75 Lt.

Our procedures will be modified to specify that local leakage testing shall be taken at a test pressure Pt.

(2)

Not applicable.

6.

Additional Requirements

a.

We are in full compliance.

b.

Not applicable.

B.

Type B Tests

1.

Test Methods

a.

Not applicable.

b.

Our procedures use this type of test.

c.

Not applicable.

2.

Test Pressure We are in full compliance.

3.

Acceptance Criteria We are in full compliance, 2

c.

D.

Type C Tests

1.

Test Method We are in full compliance.

2.

Test Pressure We are in full compliance.

3.

Acceptance Criterion We are in compliance.

Periodic Retest Schedule

1.

2.

3.

a.

We are in compliance.

b.

We are in compliance.

Type B Tests We cannot test our air locks after each opening because of fre-quent access requirements and the physical technique required to run the test.

We will test our air locks every six months.

Type C Tests We are in compliance.

IV.

Special Testing Requirements A.

Containment Modification We will include this inspection in our procedures.

B.

Multiple Leakage Barrier or Subatmospheric Containments We are in full compliance.

V.

Inspection and Reporting of Tests A.

Containment Inspection We will include.this inspection in our procedures.

B.

Report of Test Results

1.

We will include an appendix to our procedures describing all necessary reporting requirements.

3

2.

All preoperational tests have been completed.

3.

See 1 above.

4