ML19345A787

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Submits Sections of 10CFR50,App J,Requiring Exemption & Justification for Exemption Re Proposed Tech Specs Change 112 Per 750520 Request
ML19345A787
Person / Time
Site: Yankee Rowe
Issue date: 06/04/1975
From: French J
YANKEE ATOMIC ELECTRIC CO.
To: Purple R
Office of Nuclear Reactor Regulation
References
WYR-75-60, NUDOCS 8011250151
Download: ML19345A787 (3)


Text

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t' REGULATORY D00KETFILE COPY

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710-390-0739 YANKEE ATOMIC ELECTRIC COMPANY ma 's-so e - - ~.,

AL 20 Turnpike Road Westborough, Massachusetts 01581

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June 4, 1975

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United States Nuclear Regulatory O.nission Washington, D. C.

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Attention: Office of Nuclear Reactor Regulation T,

P.r. Robert A. Purple, Chief D.

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+[<, $ bV Cperating Reactor Branch #1 N'.. - : r \\,s

Reference:

(a) License No. DPR-3 (Docket No. 50-29)

(b)

Proposed Change No. 112, dated 1/3/74.

(c) AEC Letter from D. J. Skovholt to L. H. Heider, dated 1/14/74.

(d) NRC Letter from R. A. Purple, dated 5/20/75.

Dear Sir:

Ycur letter of May 20, 1973 (reference d) requests that we identify the specific sections of 10CFF Part 50, Appendix J from which we desire exemption, and further, provide justification for the exemption relating to each section of Appendix J.

The original exemptions appeared in section 16.5.4 of our proposed new format Technical Specifications submitted as part of reference (b).

The specific exemptions and the justificaticn are as follows:

1.A.l.

Section III.B.2 of Appendix J specifies " local pneumatic pressurization of the containment penetrations...," which fg \\ M/m is not possible without single seal equipment hatch.

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Section III.D.2 of Appendix J specifies:

" Air locks shall

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he tested at six-:nonth intervals. However, air locks j

'_E54 which are opened during such intervals, shall be tested 9

after each opening." An exemption for the personnel hatch l

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f3 was requested because of its frequent use for vapor I

ccntainer inspection during plant operation.

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The above exemption requests were reviewed by D. J. Skovholt

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and exemption was granted in reference (c).

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'm 1.A.2.

Section III.D.2 of Appendix J specifies:

" Type B tests except tests for air locks, shall be performed during each reactor shutdown for refueling, or other convenient intervals, but in no case at intervals greater than 2 years."

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United States Nuc

Regulatory Commission June 4, 1975

, Attn

  • Mr. Robert A. Purple, Chief Page Two The electrical penetrations were not originally designed

,for ease of testing. Two tests must be performed on each individual penetrations one on the double o ring seal and one on the cylinder holding the electrical conductors.

Extreme care must be taken with test equip-ment when working in the vicinity of these energized electrical penetrations and exposed terminal boards.

Testing the 163 penetrations is quite difficult and is

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extremely time consuming for little increase in plant safety. The functional containment continuous leak monitoring system (reference c) is capable of assuring that containment integrity is maintained. The requested exemption from the provision of III.D.2 is for an extension of time interval only and does not relieve _us of the testing requirements.

2.

Section III.A.3 (s) specified " Type A tests shall be conducted in accordance with the provisions of ANSI N45.4-1972."

At the time of our submittal (reference b), it was not clear to us that our method of leakage rate measurement was in full agree-ment with all provisions of ANSI N45.4-1972.

This standard is presently undergoing extensive revision and clarification, and we have been assured that our tests methods are in accordance with the intent of ANSI N45.4-1972.

No exception from its provisions are being requested.

3.

At the time of our submittal (reference b), we had not conducted Type A tests at the calculated peak accident pressure (P ) nor at the reduced test pressure (P ) as specified in III.A.4.

These tests were performed in May, 1974 9nd were the subject of a__

report submitted to the Commission ^. The results of these tests have permitted us to determine the extrapolation factor for future tests in accordance with Appendix J-and no exception is now requested in this area.

In view of the foregoing discussion and under present existing conditions, we request under 16.5.4, Specifications, Items 2 and 3 be deleted, as these exemptions are no longer necessary and.we are in compliance with Appendix J in these areas.

We trust the foregoing information is sufficient to permit the completion of your review of this portion of our proposed new format Technical Specifi-cations for Yankee-Rowe. Feel free to contact us should you desire clarifi-cation or additional information.

Very truly yours, YANKEE ATOMIC ELECTRIC COMPANY

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J. L. French, Jr.

Manager _of Operations-1-Reactor Containment Building. Integrated-Leak Rate. Test,-

M. W. Ebert & T. K. Henderson,'May,~ 1974.

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IJRC DISTRIBUTION FOR PART 50 DOCKET MATERI AL (TEMPORARY FORM)

FILE:

FROM: Yankee Atocic Electric DATE OF DOC ' DATE REC'D LTR TWX RPT OTHER Westberough, Mass J L French Jr TO:

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50-29 DEscalPTION:

ENCLOSURES:

Ltr re our 5-20-75 ler.... furnishing info g 3 0rp %

with regard to Tech Specs Change #112....

concerning Appendix J modifications......

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