ML20059F169

Requests Exemption from Requirements of 10CFR50,App J,Section III.D.1(a) for Facility Re Schedule Requirements for Connecting Type a Testing w/10-yr Inservice Insp Interval, Per 10CFR50.12(a)(2)

ML20059F169
Person / Time
Site:	Three Mile Island
Issue date:	08/30/1990
From:	Hukill H GENERAL PUBLIC UTILITIES CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
C311-90-2113, NUDOCS 9009110117
Download: ML20059F169 (3)

Text

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GPU Nuclear Corporation ,

Jx 0 Nuclear: o m',erar Middletown, Pennsylvania _170$7 0191 717 944 7621 August 30, 1990 TELEX 84 2386 . . .

Writer's Direct Dial Number:

C311-90-2113 4

U. S. Nuclear Regulatory Commission 4 Attnt, Document Control Desk Washington, DC -20555

Dear Sir:

Three Mile' Island Nuclear _ Station, Unit 1 (TMI-1)'

e -Operating License No. DPR Docket No. 50-289

_ Request for Exemption from'10 CFR 50 Appendix J, Schedule Requirements Connecting Type-A Testing with the: Ten Year Inservice Ins.>ection (ISI) Interval P' GPU. Nuclear. requests exemption from the requirements of 10 g < CFR Part:50 Appendix J, SectionIII.D.1(a) for-TMI-1.

7 Section'III.D.1(a) requires the performance of a set of,three

-Type'A. tests after the preoperational leakage rate tests,.ati approximate 1y'~ equal > intervals during each 10-year' service period,_

such that:the third test of each set is conducted when the plant; is shutdown;for the 10-year plant' inservice / inspections required!

A by;Section 50.55a. Thisiexemption would allow the third Type.A,--

Containment Integrated Leak Rate Test-(ILRT) of the current

'10-yeariservice period-(and subsequent periods)~ to:be uncoupled

, =- ' , from the-ISI schedule.

Thejl0-year inservice inspections required'byL10 CFR Part 50.55a are dueLfor the upcoming' cycle: 9 refueling outage (9R),1which:is m scheduled _to-begin on-October 4, 1991. Therefore, granting of-this exemption _ prior to 9R would obviate-the need to-_ perform an 7 'ILRT=that would not otherwise be required by Appendix J.

In accordance :with 10 CFR 50.12 (a) (2), the requested exemption meets..the ' criteria of Section 50.12 (a) (2) (ii)' and (iii) , . as' ifollows:

Y 1. In a' ccordance with 10 CFR 50.12(a) (2) (ii), compliance with "O 10 CFR 50 Appendix J, SectionLIII.D.1.(a) to perform a.

Type A test and the 10-year inservice inspection pursuant to 10'CFR 50.55a during the same outage does not serve the n> underlying purpose of the rule. The Introduction to 10 CFR-50 Appendix J states "the purposes of the tests are 5 toJassure that (a) leakage through the primary reactor containment and systems and components penetrating primary _

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.1 C311-90-2113 T- .2Lof: 3

. containment shall not exceed allowable leakage rate values l as-specified in,the technical specifications or associated 1 bases "; The performance of three-Type A tests at ,

approximately equal intervals over each 10-year service period provides the necessary assurance.of primary

. containment integrity to meet the intent of Appendix J. '!'

The coupling.of the Type A test schedule to-the 10-year.

inservice inspection schedule does not enhance:the purpose  ;

or assurance of containment integrity above that which will already have been demonstrated.. Such uncoupling of J the ISI and ILRT schedules is recognized by the NRC's L proposed revision to 10 CFR 50 Appendix J (51 FR 39538,.

October :29, 1986).

2. In accordance with 10 CFR 50.12 (a) (2) (iii) , compliance with'10 CFR 50 Appendix J, Section III.D.1(a) would result in undue hardship or'other costs that are significantly in 1 excess of those contemplated when the-regulation was adopted. 'When1the regulation was adopted, it' appears that

.the end'of,the 10-year service perica and.the'10-year  ;

inservice. inspection outage were contemplated as ';

concurrent milestones. However, these milestones are '

unrelated,'in that they were established to fulfill the ,

separate! purposes of Appendix J and the ASME Section-XI '

Code, and are.not' concurrent. Linkage of these milestones ,

for no apparent. safety-related purpose would require.TMI q

-tofperform TypeLA-tests during consecutive outages -

resulting in significant excess costs due to additional

-testing,and potentially increased outage time. Thus, GPUN

concludes that unnecessary Type'A-testing during-consecutive outages would result in additional costs that

'were not, intended by the; regulation when originally adopted.

4 Based ;cn1 the. above,. GPUN requests that exemption be- granted for

~TMI-1:from;the110-CFR 50. Appendix J,Section III.D.1(a) '

requirements to couple thi third ILRT.of the set of three Type A tests:with the 10-year.insereice inspection schedule. This- N exemption 11s consistent with'the proposed revision to 10 CFR 50 Appendix J as cited-above. As a matter of precedent, a similar exemption was granted by'the NRC for Davis-Besse in a letter- O dated January'29, 1990. E By-. separate: submittal,. changes to the TMI-l' Technical "

Specifications are'being requested in order to conform the TMI-1 Technical Specifications to reflect this exemption. 1 1

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To' minimize the' uncertainty associhted'_with-outage schedules, it

'is~necessary-that:we request approval of this exemption-by letter.  ;

i; prior to.Nov'30,- 1990.. I K.

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(\d Sincerely, _,

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-Vice President'and Director, THI .

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