ML20024H941
| ML20024H941 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 08/12/1993 |
| From: | Roe J Office of Nuclear Reactor Regulation |
| To: | ENTERGY OPERATIONS, INC. |
| Shared Package | |
| ML20024H942 | List: |
| References | |
| NUDOCS 9308300283 | |
| Download: ML20024H941 (5) | |
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7590-01 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
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ENTERGY OPERATIONS, INC.
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Docket No. 50-382
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(Waterford Steam Electric
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Station, Unit No. 3)
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EXEMPTION I.
Entergy Operations, Inc. (the licensee), is the holder of Facility Operating License No. NPF-38, which authorizes operation of the Waterford Steam Electric Station, Unit No. 3 (Waterford). The license provides, among other things, that Waterf-J is subject to all rules, regulations, and orders of the Nuclear Regulatory Commission (the Commission) now and hereafter in effect.
The Waterford facility consists of a pressurized water reactor located in St. Charles Parish, Louisiana.
II.
In its letter dated May 7, 1993, the licensee requested an exemption from the Commission's regulations. The subject exemption is from a requirement in Appendix J to 10 CFR Part 50 that a set of three Type A tests (Containment Integrated Leakage Rate Tests, or CILRTs) be performed, at approximately equal intervals, during each 10-year service period. The exemption applies to the first 10-year service period; subsequent service periods are not changed.
In another letter, also dated May 7,1993, the 93083002e3 930s12 DR ADOCK 0500 2
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licensee applied for an amendment to Operating License No. NPF-38 to change l
certain provisions of the Waterford Technical Specifications (TSs).
The Type A test is defined in 10 CFR Part 50, Appendix J, Section II.F, as a " test intended to measure the primary reactor containment overall integrated leakage rate (1) after the containment has been completed and is ready for operation, and (2) at periodic intervals thereafter." The 10-year service period begins with the inservice date.
TS 4.6.1.2.a requires that the Type A tests be conducted during shutdown at 40110 month intervals in each 10-year service period. This TS incorporates the requirements of Section III.D.I.(a) of Appendix J with regard to performing three Type A tests at approximately equal intervals during each 10-year service period. The first CILRT testing interval was
- 37. months, and the second was 36 months.
The time interval between ClLRTs I
I should be about 40 months based on performing three such tests at approximately equal intervals during each 10-year service period.
Since refueling outages do not necessarily occur at 40-month intervals, a permissible variation of 10 months (25 percent variation) is typically authorized in the technical specifications issued with an operating license to permit flexibility in scheduling the CILRTs.
The proposed revision to the Waterford TSs associated with the licensee's May 7, 1993, request for a one-time exemption would change the TSs by extending the surveillance requirements of TS 4.6.1.2.a and its associated Bases. The extension would allow the third Type A CILRT within the first 10-year service period to be conducted during the Cycle 7 refueling outage.
This TS change is a one-time schedular extension of the I
1
. third maximum interval from 50 months to 54 months.
It does not affect the second 10-year service period.
4 With respect to the subject exemption request, the NRC staff notes that the first and second CILRTs of the set of three tests for the first 10-year service period for Waterford were conducted in May 1988 and May I
1991. This represents testing intervals of 32 and 36 months from the inservice date of September 1985. The third of the first set of three CILRTs will be scheduled for Refueling Outage 7, projected to start in October 1995, pending approval of the exemption request.
The current third test period in the first 10-year service period will actually be exceeded t
by approximately 4 months.
a Data from the first (May 1988) and second (May 1991) CILRT at Waterford 3 indicates that most of the measured leakage is from the J
containment penetrations and not from the containment barrier. The "as-left" leakage rate was well below the 10 CFR Part 50 Appendix J limit.
Both Appendix J and TS requires that the leakage rate be less that 75% of L, to allow for deterioration in leakage paths between tests.
The s
allowable leakage rate, L, is 0.5 wt.%/ day. Therefore, the established s
acce' le limit is <0.375 wt.%/ day.
The "as-left" leakage rates for the first two CILRTs were 0.116 and 0.0731 wt.%/ day, which is well below the acceptance limit. The Type B and C test (Local Leakage Rate Test or LLRT) l program also provides assurance that containment integrity has been t
maintained.
LLRTs demonstrate operability of components and penetrations by measuring penetration and valve leakage. Additionally, there have been no modifications made to the plant that could adversely affect the test results.
. The licensee further notes that the performance of a fourth test in the first 10-year service period to meet the requirements of the TSs and Appendix J would result in additional radiation exposure to personnel.
Omitting the test will result in additional dose savings by eliminating contamination and by reducing exposure from venting and draining and from setups and restorations of instrumentation required to perform the test.
These factors and the costs associated with a fourth test for a 4-month difference in interval time are not offset by the benefits of the fourth j
test.
For the reasons set forth above, the NRC staff concludes that this deviation from the 10-year service period ending September 1995 is not significant in terms of complying with the safety or scheduling requirements of Section III.D.I.(a) of Appendix J.
Accordingly, the staff j
finds that the additional test would not provide substantially different information and that the intent of Appendix J is met.
Therefore, the i
subject exemption request meets the special circumstances of 10 CFR 50.12(a)(2)(ii), in that the fourth test is not necessary to achieve the underlying purpose of the rule.
On this basis, the NRC staff finds that the licensee has d
demonstrated that special circumstances are present as required by 10 CFR 50.12(a)(2).
Further, the staff also finds that extending the service period will not present an undue risk to the public health and safety; since the licensee has justified the leaktight integrity of the containment i
based on previous leakage test results, the staff concludes that a one-time extension of approximately 4 months beyond the maximum permitted third test interval within the first 10-year service period will-not have a significant safety impact.
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III.
Accordingly, the Commission has determined that, pursuant to 10 CFR 50.12, an exemption is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest and hereby grants the following exemption with respect to a requirement of 10 CFR Part 50, Appendix J, Section III.D.l(a):
For the Waterford Steam Electric Station, Unit 3, the current third test period within the first 10-year service period may be extended by approximately 4 months, so that the third periodic Type A test may be i
performed during the Cycle 7 refueling outage.
Pursuant to 10 CFR 51.32, the Commission has determined that the granting of the subject exemption will not have a significant effect on the quality of the human environment (58 FR 34829).
This Exemption is effective upon issuance.
i FOR THE NUCLEAR REGULATORY COMMISSION
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ck W. Roe, Director Division of Reactor Projects - III/IV/V Office of Nuclear Reactor Regulation t
Dated at Rockville, Maryland this 12th day of August 1993 i.
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