ML19098B298
| ML19098B298 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 10/20/1975 |
| From: | Stallings C Virginia Electric & Power Co (VEPCO) |
| To: | Reid R Office of Nuclear Reactor Regulation |
| References | |
| Download: ML19098B298 (6) | |
Text
'.
Attn:
Mr. Robert W. Reid, Chief Operating Reactors Branch
Dear Sir:
. This letter is in response to your.letter of August 4, 1975 requesting that'we review our containment leakage testing program for the Surry Power Station, Unit Nos. 1 and 2, to determine if we are presently conducting the tests. in full compliance with Appendix J, 10 CFR 50 *
. -;_-.~,,,., Technical Specification 4.4 defines our current requirements for con-tainment leakage rate testing.
The specification basically states that leak-age rate tests will be performed in accordance with the requirements of pro-posed 10 CFR 50, Appendix J, "Reactor Containment Leakage Testing for.Water Cooled Power Reactors," as published in the.Federal Register, Volume 36, No.
167/~~ugust 27, 1971.
Type A tests are conducted in accordance with the provisions of ANS 7.60.
The currently approved Appendix J, 10 CFR 50, was published in the Federal Register, Volume 36, No. 30 on February 14, 1973.
This "approved" version is a revision of the "proposed" version currently specified in the Technical Specifications for Surry Power Station, Unit Nos. 1 and 2.
Significant differences between the "proposed" and "approved" versions are:
- 1.
Modification of procedures governing containment inspection and leak detection surveys as a prerequisite to conducting formal leakage tests, and clarification of the basis for reporting pretest leakage values to the Commission,
- 2.
Establishment of criteria for deferring certain safety related systems from regularly scheduled Type A con-tainment leakage tests.
e VIRGINIA ELECTRIC AND POWER COMPANY TO e
Mr. Robert.W. Reid, Chief Operating Reactors Branch 4
.3.
Incorporation by reference*of ANSI *N45.4-1972 instead of ANS 7.60.
, 4.
Inclusion of nitrogen gas as a suitable testing.medium for testing the leaktightness of valves..
. 5.
Inclusion of water.leakage test and.acceptance criteria for containment isolation valves which are sealed against the containment atmosphere outleakage during a design basis accident condition by means of a seal *water system.
- 6.
Revision of the schedule for testing air locks every four (4) months to after each opening.
- 7.
Editorial and format changes.
Page 2 We have reviewed our existing containment leakage rate.testing program in light of the. differences* listed above.
We will modify our pro.gram to.
accommodate the technical changes noted in Items 1, 2, 3, 4 and 5 above.
However, we do.not feel that we can comply with,the revised requirements for leak test~ng the containment personnel air lock for the reasons outlined below.
The containment.personnel air lock provides the only access to thecon-tainment.
Containment entries are made on a daily basis during normal operation.
On occasions, multiple consecutive entries are required daily to complete operational and maintenance activities.
Testing of the air lock after each entry would extend critical maintenance, as well as place an unnecessary burden on tp,e station staff without any significant. benefit.. The air lock is presently leak tested every four, (4) months and past' experience has shown the integrity of the seals to be verified satisfactorily with this testing interval.
The testing of the personnel hatch is done by manual means; there-fore, additional manpower is required to perform the test.
Of cours~, during testing, access through the hatch is not permitted, which makes the containment inaccessible for about two (2) hours for each*test.
We do not believe the Appendix J provisions for testing the hatch after each entry is required or justified.
In r.egard to Type C tests used to measure containment isolation valve leakage rates, the same valves required.to be tested by* the "proposed".version of Appendix J are also.required by the "approved" version; therefore, we would plan to continue to test the same valves included in the present program.
A list of the valves which would be subjected to Type C tests is attached here-with~
Only Unit No. 1 valves are listed; however, corresponding valves for Unit No. 2 would.be tested.
We would propose to list the valves for both units as part of the Technical Specification change to be submitted.
e VIRGINIA ELECTRIC AND POWER COMPANY TO e
Mr. Robert W. Reid, Chief Operating Reactors Branch 4 Page 3 We have periodic test procedures which provide the details for con-ducting our current program which are available for your inspection at the station.
These procedures would be revised to reflect the updated require-ments of Appendix J, if required.
With the exception noted concerning the testing of the personnel access lock we are able to conform with the requirements of the current version of Appendix J, 10 CFR 50, without major modifications.
We trust the above information adequately responds to your request.
Upon receiving concurrence with the exception noted.we will propose an amend-ment to the Technical Specifications based on the current version of Appendix J, 10 CFR 50, published February 14, 1973.
Attachments cc:
Mr. Norman.C. Moseley Very truly yours,
- 70. JY;. J;att~
C. M. Stallings Vice President-Power Supply and Production Operations
,i VALVE DESIGNATION l-CH-323 l-'-CH-333 l-CH-349 MOV-1890A MOV-1890B MOV-1890C MOV-1842 l-SI-174 &
MOV-1869A MOV-1869B l-SI-150 &
MQV-1867C & D l-RL-3 l-RL-5 1-RL-13 1-RL-15 e
VALVES SUBJECT TO TYPE C LEAKAGE RATE TESTING SURRY POWER STATION UNIT NO. 1 VALVE DESIGNATION 1-CH-309 MOV-1289A MOV-1381 TV-1204 HCV-1200A,B & C FCV-1160 1-SI-32 l-SI-73 TV-SS-104A TV-SS-104B TV-SS-lOOA TV-SS-lOOB TV-SS-102A TV-SS-102B TV-SS-106A TV-SS-106B TV-SS-lOlA TV-SS-lOlB r r*
e VALVE~SIGNATION VALVE DESIGNATION TV-SS-103 TV-VG-109A 1:.cs-34 TV-VG-109B TV-DG-108A.
1-VA-l TV-DG-108B l-VA-6 l-RC-160 TV-SI-101A TV-1519A TV-SI-101B
.1-cs-24 2-IA-446 MOV-CS-101C & D l~IA-938 l-CS-13 l-IA-446 MOV-CS-lOlA & B l-IA-939 l-RS-11 l-SA-60
~!
MOV-RS-156A l-SA-62
'I l-RS-17 TV~SI-100 MOV-RS-156B l-RM-3 f
i MOV-RS-155A & B TV-RM-lOOA I'
MOV-1860A & B TV-RM-lOOB i ' !
TV-DA-lOOA TV-RM-lOOC r ! j
.TV-DA-lOOB MOV-VS-lOOA l
MOV-VS-lOOB MOV-VS-102 MOV-VS-lOOC MOV-VS-lOOD MOV-VS-101 TV-CV-150A TV-CV-150B r
e e
VALVE DESIGNATION VALVE DESIGNATION TY-CV-150C TV-CV-150D HCV-CV-100 l-CV-2 TV-SV-102 l-VP-12 l-GW-166 l-GW-175 TV-LM-lOOB & D TV-LM-lOOF & H TV-LM-lOOA & C TV-LM-lOOE & G TV-LM-101A TV-LM-101B