ML20059D738
| ML20059D738 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 10/27/1993 |
| From: | Hagan R WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NA-93-0186, NA-93-186, NUDOCS 9311020386 | |
| Download: ML20059D738 (5) | |
Text
9-i WFLF CREEK
' NUCLEAR OPERATING CORPORATION Robert C. Hagan Vice President Nuclear Assurance October 27, 1993 NA 93-0186.
l U. S. Nuclear Regulatory Commission i
ATTN: Document Control Desk D
Mail Station P1-137 Washington, D. C.
20555
Reference:
Letter NA 43-0195 from R.
C.
Hagan, WCNOC, to j
Document Control Desk, NRC
Subject:
Exemption From 10 CFR 50, Appendix J,
Section III.D.1(a)
Gentlemen:
The purpose of this letter is to transmit an exemption request, pursuant to the provisions of 10 CFR 50.12, from the testing requirements of.10 CFR 50, Appendix J,
Section III.D.1(a).
. This ' request is a one-time exemption that would allow the third test of the first 10rjear service period to be performed approximately six months beyond the 10-year service period.
The attachment contains the exemption request with evaluation and 10 CFR 50.12 Special Circumstances in support of this request.
If you have any questions concerning this matter, please contact me at (316) 364-8831, extension 4553, or Mr. Kevin J. Moles at extension 4565.
Very truly yours, h%
RepertC. Hagan Vice President Nuclear Assurance RCH/jra 020059 Attachment cc:
J.
L. Milhoan (NRC), w/a-G. A.
Pick. (NRC), w/a W.
D.
Reckley (NRC), w/a L.
A. Yandell (NRC), w/a l
DI PO Dox 411/ Budington, KS 66839 / Phone: (316) 364-8831 9311020386 931027 PDR ADDCK 05000482 L,
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e STATE OF KANSAS
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Robert C. Hagan, of-lawful age,;being first duly sworn upon oath.says that he is Vice President Nuclear Assurance of Wolf.-Creek Nuclear Operating Corporation; that he has read the foregoing document and knows the content thereci; that he has executed that same for and on behalf of said Corporation-with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.
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SUBSCRIBED and sworn to before me this 87 dr.y of O;/h)[w, 1993.
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L Attachment to NA 93-0186 j
i Page 1 of 3 EXEMPTION REQUEST Prooosed Exemotion This proposed exemption request is to 10 CFR 50, Appendix J,
Section III.D 1(a) which requires a set of three Type A tests (Overall Integrated Containment Leakage Rate Test (ILRT)) -be performed at approximately equal intervals during each 10-year service period with the third test of each set being conducted when tne plant is shutdown for the 10-year plant inservice inepections. This request is a one-time exemption that would allow the third test of the first 10-year service period to be performed approximately six months beyond the 10-year service period. This exemption is needed in conjunction with Wolf Creek Nuclear Operating Corporation's (WCNOC) license amendment request to Technical Specification 4.6.1.2.a (Reference) that would allow the third test to be performed at approximately a 54-month interval in lieu of the cuttent maximum interval of 50 months.
Technical Specification 4.6.1.2.a requires, in part, that three Type A tests be conducted at 40 10 month intervals while shutdown, during each 10-year service period.
The 54-month interval coupled with the first and second test intervals of 45 and 35 months, respectively, would exceed the 10-year time frame for the first service period.
Backaround Type A tests are defined in Section II.F of 10 CFR 50, Appendix J, as those tests intended to measure the primary reactor containment overall integrated leakage rate at periodic intervals.
The t2me required to perform the ILRTs necessitates that they be performed during refueling outages with the time interval between ILRTs being roughly 40 months based on the performance of three such tests at approximately equal intervals during each 10-year service period.
Since refueling outages do not necessarily occur coincident with this 40-month interval, Technical Specification 4.6.1.2.a specifies that a variation of 3.10 months (i.e.,
a 25 percent variation) is permissible to permit flexibility in scheduling the ILRTs.
The first and second ILRTs, of the set of three tests for the first 10-year service period for Wolf Creek Generating Station (WCGS), were conducted in October 1988 and September 1991, respectively.
This represents testing intervals of 45 and 35 months, respectively, from the initial preoperational ILRT performed in January 1985.
This would indicate that the third of the first set of three ILRTs should be performed during the seventh refueling outage, scheduled for September 1994 which would be 36 months after the preceding test and within the first 10-year service period.
However, the result of this testing sequence would cause an additional ILRT to be performed during eighth 8
F
Attachment to NA 93-0186 Page 2 of 3 j
refueling outage in order to comply with the requirements of 10 CFR 50, Appendix J, Section III.D.1(a), which requires the ~ third test of each.
l set be conducted when the plant is shutdown for the 10-year plant inservice inspections.
In order to prevent perfctming this fourth ILRT.
in the first 10-year service period, WCNOC is proposing that the third ILRT for the first 10-year service period be performed in conjunction with the 10-year plant inservice inspections during the eight refueling outage, scheduled for Spring 1996.
Therefore, this one time scheduler exemption is needed to allow the third test of the first 10-year service
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period to be performed approximately six months beyond the 10-year j
service period.
Data from previous ILRTs conducted at WCGS indicates that the majority of the leakage that is measured during an ILRT is from the containment penetrations and not from the containment barrier itself.
Since'this exemption request does not alter the Type B and C tests (Local Leakage Rate Test (LLRT) program), which measures penetration and valve-leakage, assurance that containment integrity is maintained can also be verified by the performance of the LLRTs.
In addition to the LLRT's indication f
of containment integrity, the data from the first-and second ILRT l
illustrates that the "as-1.ft" leakage rates were well below the limit i
established for acceptance in 10 CFR 50, Appendix J,
and Technical l
Specifications.
The allowable leakage rate, L,
is 0.2 wt.%/ day; a
however, 10 CFR 50, Appendix J,
and technical specifications requires 1
that the leakage rate be less than 75 percent of this value (0.15 wt.t/ day) to allow for deterioration in the leakage paths between tests.
The "as-left" leakage rates for the first two ILRTs were 0.112 and 0.070 wt.%/ day, respectively, which is well below the acceptance limit.
Evaluation i
The purpose of the ILRT, which is to provide periodic verification of J
the leak-tight integrity of the primary reactor containment, and systems and components which penctrate containment,. will not be adversely impacted by this one time exemption.
The LLRT program is not affected and past data has indicated that the majority of the leakage measured during the ILRT is from containment penetrations and valves and not from-the containment barrier itself.
Therefore, assurance that containment integrity is maintained can also be verified by the performance of the LLRTs.
Given the above discussions, and the fact that a revision to Appendix J is pending that would delete the 10-year interval for performing three ILRTs and replace it with a requirement that any three consecutive test intervals be <3.25 times 48 months, this exemption will not pose any undue risk to the health and safety of the public or involve a significant safety hazard. Special circumstances, as provided in 10 CFR 50.12 (a) (2) (ii), are present justifying the exemption from Appendix J.
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.l Attachment to NA 93-0186 Page 3.of 3 4
d Namely, application of the regulation in the.particular circumstances is not necessary to achieve its underlying purpose, which.is to ensure that accurate and conservative methods are used in performing. periodic containment leak rate tests at approximately equal intervals throughout t
'i the life of the plant to assure that cont ainment ' ' int egrity is being maintained.
.j Additional Information Letter NO 92-0001 submitted Licensee Event. Report 91-020-01 concerning
~l 1eakage past Containment Isolation Valves EFHV32 and EFHV34 that
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resulted in the "as-found" ILRT conducted in September 1991 exceeding
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the allowable leakage value.
In accordance with Technical Specification I
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4.6,1.2(b) and 10 CFR 50, Appendix J,
Section III. A.6. (a), a test schedule applicable to subsequent Type A tests was submitted with the licensee event report for review and approval by the Commission.
This:
test schedule proposed to continue performing ILRTs every other refueling outage, as per the original test schedule, which would indicate that the next ILRT is required to be performed during the seventh refueling outage scheduled for September'1994, This schedule was approved by the Commission in a letter-dated May 4,
1992, from~
Suzanne C. Black, NRC, to Bart D. Withers, WCNOC.