ML20044A226

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Exemption from Leak Test Requirements of 10CFR50,App J,Section III.D.3,extending Schedule for Performing Type C Tests to Cycle 10 Refueling Outage
ML20044A226
Person / Time
Site: Surry Dominion icon.png
Issue date: 06/22/1990
From: Varga S
Office of Nuclear Reactor Regulation
To:
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
Shared Package
ML20044A208 List:
References
NUDOCS 9006280237
Download: ML20044A226 (5)


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x 7590 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of VIPGINIA ELECTRIC AND POWER COMPANY Docket No. 50-280 (Surry Power Station,=

Unit 1)

= EXEMPTION 1

1.

TheVirginiaElectricandPowerCompany(VEPCO,thelicensee)isthe holder. of Operating License No. DPR-32, which authorizes operation of Surry Power. Station (SPS), Unit 1.

The operating license provides,'among other things, that.the SPS, Unit 1 is subject to'all rules, regulations,-and orders of the Comission now or hereafter in effeht.

The facility' consists of a presturized water reactor at the licensee's v

site in Sorry County, Virginia.

II.

One of the conditio'is of all operating licenses for water-cooled power

- reactors, as specified in 10 CFR 50.54(o), is that the-primary containments shall meet the leakage test regi:irements set forth in 10 CFR Part 50,-

h-Appendix J.

More specifically, Section.III.D.3 of Appendix J, " Type C tests,"

requires that:

' Type C tests shall be performed during each reactor shutdown for refueling but in no case at intervals greater than 2 years.

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. By letter dated January 8,1990, as clarified March 20 and April 20, 1990, VEPC0 requested a schedular exemption from the regulatory requirements of 10 CFR'Part 50, Appendix J.Section III.D.3.

In these submittals, VEPC0 evaluated the acceptability of the exemption request. More details are contained in the NRC's Safety Evaluation issued concurrent with this exemption.

III.

SPS, Unit I was shut down for refueling April 9 through July 18,1988 when local leak rate testing and the 18-month and refueling surveillance tests were last completed. In September 1988 the-unit was shut down again for an extended maintenance outage which lasted 299 days (approximately 10 months).

ThetocalLeakRateTestit.] Program (TypeCtesting)wasperformedduring the refueling outage and completed on June 23, 1988. Due to the subsequent extended maintenance outage, the next refueling outage is currently scheduled for the fourth quarter of 1990. The interval between the refueling outages will exceed the 2-year limit of Appendix J. - Therefore, an exemption to this Appendix 0 requirement in the fo m of a one-time extension of the interval is being requested. In addition to this exemption request, a request for a one-time Technical Specificat'lon change to provide the same relief is being requested. A footnote will be added to TS 4.4.B.2 and 4.4.D denoting the

. Appendix J exemption.

As indicated above, the intent of Appendix J was that isolation valves and associated penetrations be' tested during each refueling outage not to exceed 2 years. SPS, Unit 1 is presently scheduled to conduct a refueling outage in October 1990. The exemption would allow local leak rate Type C tests for the

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70 TS valves to be postponed until the next refueling outage. Such an extension is desirable in order to prevent premature shutdown. However, in the event the refueling outage is delayed by more than 2 months beyond the current projection of October 1990, approval of deferral would become invalid and the licensee would have to seek new approval. This provision has been discussed with'and-found acceptable by the licensee's staff and has been incorporated into the associated amendment to the Technical Specifications.

During an extended maintenance outage which lasted approximately 10 months, modifications and testing were performed on the emergency diesel generators, the Circulating and Service Water Systems cnd the Electric.a1 Distribution System.

In addition, during this time plant components were not exposed to.the normal operating temperatures, pressure and radiation conditions. The time-interval of 2 years, specified in Appendix J, was based, in part, on the expected degradation of components exposed to the environment resulting from a full 24 months of normal plant operation. The total exposure time for the containment penetration to normal plant operating environment will be only 1

about 15 months and is exposed to a less hostile environment during shutdown conditions.

The 2-year interval requirement for the Type C. penetrations is intended to be often enough to prevent significant deterioration from occurring and long enough to permit the local leak rate tests (LLRTs) to be performed dnring plant outages.

In addition, leak testing of the penetrations during plant-shutdown is preferable because of the lower radiation exposures to plant personnel. tioreover, some penetrations, because of their intended functions, cannot be tested.at power operation. For penetrations that cannot be tested during' power operation or those that if tested during p' ant operation would

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a-4 cause a degradation in the plant's overall safety (e.g., the closing of a redundant line in a safety system), the increase in confidence of containment i nter" - following a successful test is not significant enough to justify a plant.hutdown specifically to perform the LLRTs within the 2-year time period, especially in light of the above discussions.

IV.

Pursuant to 10 CFR 50.12(a)(2)(v), the Comission will not consider granting a schedular exemption unless the 1 kensee has made good faith efforts to comply with the regulation., The NRC staff believes that VEPC0 has taken prudent steps to improve the containment integrity and if not for the extended refueling outage would have complied with Appendix J.

Based on our evaluation, the NRC staff has concluded VEPC0 has made good faith efforts to comply with the requirements of Appendix J and that the L

specialcircumstancesasdescribedin10CFR50.12(a)(2)(v) exist,inthatthe exemption would provide only temporary relief from the applicable regulation.

Therefore, the staff has determined that the schedular exemption for 10 CFR Part 50, Appendix J should be granted.

V.

Accordingly, the Comission has determined that pursuant to 10 CFR 50.12, the exemption is authorized by law, will not endanger life or property or the comon defense and security, and is otherwise in the'public interest. Therefore, the Comission hereby approves the following exemption request.

A temporary exemption is granted from the requirements of Section III.D.3, which requires a local leak rate test be conducted within a 2 year interval.

For good cause shown, this exemption extends that period by approximately 6 months from June 23, 1990 until December 31, 1990.

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. ' 'However, in the event the refueling outage is delayed by more than 2 months beyond the current projection of October 1990, approval of the deferral would become ' invalid and the licensee would have to seek new approval.

l Pursuant to 10 CFR 51.32, the Commission has determined that the granting of this exemption will have no significant impact on the environment-(65FR25754),

i A copy of the licensee's request for exemption dated January 9,1990, as

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E clarified March 20 and April 20, 1990, is available for public inspection j

at the Commission's Public Document Room, 2120 L Street, N.W., Wasnington, I

D.C., and at the Swem Library, College of William and Mary, Williamsburg, Virginia, 23185.-

o This: exemption is effective upon issuance.

FOR THE~ NUCLEAR REGULATORY COMMISSION da Dir c or ve Division of Reactor cts - I/II

' Office of Nuclear Reactor Regulation i

Dated at Rockville, Maryland this 22nd day of June 1990 i

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