ML20031E398
| ML20031E398 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 10/08/1981 |
| From: | Clayton F ALABAMA POWER CO. |
| To: | Varga S Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20031E399 | List: |
| References | |
| NUDOCS 8110150464 | |
| Download: ML20031E398 (4) | |
Text
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Mailing Addrrss Y
O A!abama Power Company 1
600 North 18th Street 7
Post Office Box 2641 P
Bumingham, Alabama 35291 Telephone 205 783-6081 b
F. L. Clayton, Jr.
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Alabama Power ow.xwm axire serem October 8,1981 Docket No. 50-364 s
g Di ector Of Nuclear Reactor Regulation ff 9) d-O U. S. Nuclear Regulatory Commission
%l v.s.CQ 4 IS8/amg, Washington, D. C.
20555 L:
NuR%nn; Attention: Mr. S. A. Varga 4
Gentlemen:
k Joseph M. Farley Nuclear Plant - Unit 2 Reactor Containment Leakage Testing In response to our letter of July 29, 1981, Alabama Power Company has'been informed that NRC Staff's interpretation of the Unit 2 Technical Specification and 10CFR50, Appendix J related to Containment System Leakage Testing requires Type B and C tests to be performed prior to initial criticality and periodically thereafter during shutdown periods or normal plant operations, but in no case shall any individual test be conducted at intervals greater than two years.
The Farley Unit 2 preoperational Type B and C Local Leak Rate Testing (LLRT) was completed in June,1980. This testing was conducted over a six-month period which began in November,1979. The scheduled start of the preoperation?.1 LLRT was based on a fuel load date of May, 1980. The Type A test was actually performed in June of 1980; however, fuel load did not occur until March,1981.
To comply with the above interpretation of Farley Unit 2 Technical Specification 4.6.1.2.d and 10CFR50, Appendix J, Type B and C tests will be required between November,1981 and June,1982 on Unit 2 containment pene-trations. There are one hundred (100) containment penetrations that fall into this category.
Fifty-three (53) of these penetrations can be tested with the unit at power. Twenty-five (25) of the penetrations require at least HOT SHUTDOWN and twenty-two (22) penetrations require COLD SHUTDOWN as a prerequisite plant condition for performing the leak rate testing.
Since the results of the Unit 2 preservice Type B and C test demonstrated extremely low leakage rates and since no incidents have occurred at Farley Unit 2 which could have caused abnormal degradation to the integrity of the penetrations, Alabama Power Company proposes 8110250464 811008 Y
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l Director of Nucitar R: actor R:gulation Octobsr 8, 1981 U. S. Nuclear Regulatory Comission page 2 Attention:
Mr. S. A. Varga p
the following plan for performing the Type B and C' tests that will become due between November, 1981 and June, 1982:
(1) For the fifty-three penetrations that can be tested at power, the Type B or C tests will be conducted such that no individual penetration exceeds a 24-month test interval.
(2) The twenty-five penetrations that require HOT SHUTDOWN will be tested when plant conditions of sufficient duration will support the testing, but in no case later than the first refueling outage.
~(3) The twenty-two penetrations that require COLI) SHUTDOWN will be: tested when plant conditions of. sufficient ' duration sill support the testing, but in no case later than the first ret ling outage.
In order to accomplish the Type B and C test without requiring a four-week plant shutdown for the express purpose of performing these tests, Alabama Power Company requests a one-time expemption, pursuant to 10CFR50.12, to the requirements of 10CFR50, Appendix J and from the 24-month requirement of Farley Unit 2 Technical Specification 4.6.1.2.d (Attachment 1). The basis for.this exemption is provided in Attachment 2.
This exemption would apply to those forty-seven penetrations which require the plant to be in a shutdown condition to perfonn the leak rate test and will be tested as plant conditions permit.
In any event, all penetrations subject to a Type B or C test will be. tested during the first refueling outage of Unit 2.
Current burnup rate indicates that this outage will begin in late 1982.
The containment buildings at Farley Units 1 and 2 have historically exhibited mi " mal leakage.
In addition, the vast conservative margin demonstrated ay the preoperational. test results provides adequate confidence in the integrity of the Unit 2 containment system during this first fuel cycle. The total leakage of the forty-seven penetrations for which special test; scheduling is being requested only represents 2.3% of the maximum allowable leakage (6.La) based on previous test results.
Penetrations whose leakage path could provide a direct path to the environment (personnel access hatches, containment purge, equipment hatch, and fuel transfer tube) have been or will be tested (due to configurations which allow testing at power) on a schedule consistent with Technical Specification time frame requirements.
All other penetrations are not a direct path to the atmosphere and would require a pipe failure O
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r Director of Nuclear R: actor R gulation October 8,1981 U. S. Nuclear Regulatory Conunission Page 3 Attention: Mr. S. A. Varga inside containment plus a penetration failure for ariy nast accident releases outsiJe of containment.
In this event the penetration fiitration system will recirculate and filter any such releases I
from these penetrations prior to exhausting to the environment.
l This multipass filtration system for processing any long term l
containment leakage maintains the auxiliary building rooms adjacent l
to the containment at a sightly negative pressure during accident conditions.
The negative pressure ensures inleakage into the penetration rooms and filtration of any containment atmospheric releases to the auxiliary building. The integrity of this filtration system is verified as required by the surveillance requirements of Techr.ical Specification Section 4.7.8.
By performing the tests as proposed herein, it is the judgment of Alabama Power Company that no undue risk to the health and safety of the public will be encountered because:
(1) The penetrations, which are potential ~ direct release paths are being tested in accordance'with Technical Specification requirements (2) Other penetrations require two failures (i.e. both isolation valves and a piping failure) for post accident containment releases to enter the auxiliary building (3) Releases through these penetrations due to failures would ba processed by the penetration filtration system (4) The forty-seven penetrations that cannot be tested at power represent a minimal fraction of the total allowable leakage (5) There is not expected to be any appreciable degradation of the forty-seven penetrations during the first fuel cycle.
Currently with Farley Unit 1 shutdown for major repairs to the turbine generator, Alabama Power Company, as a member of the Southern Company Power Pool, is a net purchaser of both capacity and energy during the fourth quarter of 1981.
Major maintenance on other generating units is being conducted during this period. The shutdown of Unit 2 to complete this testing would further exacerbate this cond# tion of purchasing power and/or delaying necessary maintenance on other units in preparation for winter load requirements.
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Director of Nuclear Reactor Regulation October 8, 1981 U. S. Nuclear Regulatory Commission Page 4 Attention: Mr. S. A. Varga This proposed exemption to the Technical Specifications and 10CFR50, Appendix J has been reviewed by the Plant Operation's Review Committee and the Nuclear Operations Review Board and has been determined not to involve an unreviewed safety question or represent any potential for endangering the health and welfare of the public.
This item is designated Class III according to 10CFR170.22 requirements. A check for $4,000 is enclosed to cover the fees required.
In accordance with 10CFR50.30 (c)(1)(i), three signed originals and thirty-seven (37) copies of this proposed exemption are enclosed.
If you have any questions, please advise.
Yours very tru CnRM/
, M. L. Clayton, Jr.
FLCJr/RLG:jc SWORN TO AND SUBSCRIBED BEFORE PE Enclosure THIS Mr'd DAY OF hr[Nv,,1981.
cc: Mr. R. A. Thomas Mr. G. F. Trowbridge M [ [^ ^ O Mr. E. A. Reeves Mr. W. H. Bradford Notary Public My Commission Expires:
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