ML20059F169
| ML20059F169 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| 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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August 30, 1990 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)'
-Operating License No. DPR e 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 CFR Part:50 Appendix J, SectionIII.D.1(a) for-TMI-1.
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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
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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 scheduled _to-begin on-October 4, 1991.
Therefore, granting of-m 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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-PDR ADocK 05000289 *
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.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.
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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..
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(\\d Sincerely,
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