ML20073H982
| ML20073H982 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 09/30/1994 |
| From: | Varga S Office of Nuclear Reactor Regulation |
| To: | PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| Shared Package | |
| ML20073H986 | List: |
| References | |
| NUDOCS 9410060169 | |
| Download: ML20073H982 (8) | |
Text
.-
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
)
Philadelphia Electric Company
)
Docket No. 50-277 Public Service Electric and Gas
)
Company
)
Delmarva Power and Light Company
)
Atlantic City Electric Company
)
(Peach Bottom Atomic Power Station,
)
Unit 2)
)
EXEMPTION I.
Philadelphia Electric Company, et. al (PEco, the licensees), is the holder of Facility Operating License No. DPR-44, which authorizes operation of the Peach Bottom Atomic Power Station (PBAPS), Unit 2.
The license provides, among other things, that the licensee is subject to all rules, regulations, I
and orders of the Nuclear Regulatory Commission (the Commission) now and hereafter in effect.
The PBAPS, Unit 2, facility consists of a boiling water reactor located in York County, Pennsylvania.
II.
In its letter dated May 13, 1994, the licensee requested an exemption from the Commission's regulations. The subject exemption is from a requic9 ment in Appendix J to 10 CFR Part 50 that a set of three Type A tests (Containment Integrated Leak Rate Tests (CILRTs)) be performed, at approximately equal intervals, during each 10-year service period. The exemption applies to the second 10-year service period; subsequent service periods are not changed.
9410060169 940930 PDR ADOCK 05000277 P
PDR i.
I
l
\\
. l The type A test is defined in 10 CFR Part 50, Appendix J, Section II.F, as " tests intended to measure the primary reactor containment overall integrated leakage rate (1) after the containment has been completed and is ready for operation, and (2) at periodic intervals thereafter." The 10-year j
service period begins with the inservice date. The request for a one-time exemption would allow an extension of the second 10-year Type A service period and would allow the performance of the three Type A tests in the second 10-year service period at intervals that are not approximately equal.
It does not affect the third 10-year service period.
Current TS and 10 CFR Part 50, Appendix J, would require performing a Type A test during Unit 2's refueling outage 10 scheduled for September 1994 in order to comply with the requirement to perform three Type A tests within the current 10-year service period.
Furthermore, 10 CFR Part 50, Appendix J, would also require a Type A test to be performed during the next refueling outage (Unit 2 refueling outage 11 scheduled for September 1996) in order to coincide with the end of the current 10-year plant inservice inspection (ISI) interval.
The current 10-year ISI period ends in November 1997 and current ISI inspections are scheduled for September 1996.
Therefore, to fully comply with Appendix J, the licensee would have to perform CILRTs during the tenth and eleventh refueling outages for Unit 2.
The licensee stated that the first and second CILRTs of the set of three tests for the second 10-year service period for PBAPS were conducted in February 1989 and April 1991. Thus, the first CILLT testing interval of the second 10-year service period was approximately 44 months, and the second CILRT testing interval was approximately 27 months. The time interval between
. CILRTs should be about 40 months based on performing three such tests at approximately equal intervals during each 10-year service period. The third of the second set of three CILRTs will be scheduled for Refueling Outage 11, projected to start in September 1996, pending approval of the exemption request.
Issuance of this exemption would allow the extension of the second 10-year service period such that the next CILRT would be performed during Refueling Outage 11, approximately 66 months after the April 1991 CILRT.
The licensee performed a review of the history of the PBAPS Unit 2 CILRT results to evaluate the risk of activity-based and time-based degradation. This review identified only one activity-based component failure detected during past CILRTs. The measured mass point and total time leakage rates measured for the June 1985 CILRT stabilized at approximately 0.70%
wt/ day, which failed to meet the TS and 10 CFR Part 50, Appendix J criterion of less than 0.375% wt/ day (0.75 La). Following the completion of repairs, the CILRT was repeated with an as-left leakage of 0.0155% wt/ day. After this failure, the licensee modified the plant so that a similar failure, in the future, would be detected by a local leak rate test (LLRT).
The Type B and C test (i.e., LLRT) program provides assurance that j
containment integrity has been maintained.
LLRTs demonstrate operability of components and penetrations by measuring penetration and valve leakage.
Additionally, there have been no modifications made to the plant, since the last Type A test, that could adversely affect the test results.
The licensee further notes that the performance of consecutive Type A tests in refueling outages 2R010 and 2R0ll to meet the requirements of the TS
e
. and Appendix J, would result in additional radiation exposure to personnel.
Performing the Type A test during two consecutive refueling outages in order to comply with the TS and 10 CFR Part 50, Appendix J, would result in an unnecessary increase in personnel radiation exposure and increased cost by increasing the length of one of the affected refueling outages. Omitting the test will result in additional dose savings by eliminating contamination and by reducing exposure from venting and draining and from setups and restorations of instrumentation required to perform the test. These factors and the costs associated with an additional test for a 24-month difference in interval are not offset by the benefits of the additional test.
4 For the reasons set forth above, the NRC staff concludes that this deviation from the 10-year service period ending August 1994 is not significant in terms of complying with the safety or scheduling requirements of Section III.D.I.(a) of Appendix J.
Accordingly, the staff finds that the additional test would not provide substantially different information and that the intent of Appendix J is met.
Therefore, the subject exemption request meets the special circumstances of 10 CFR 50.12(a)(2)(ii), in that the fourth Type A test is not necessary to achieve the underlying purpose of the rule.
On this basis, the NRC staff finds that the licensee has demonstrated that special circumstances are present as required by 10 CFR 50.12(a)(2).
Further, the staff also finds that extending the service period will not present an undue risk to the public health and safety; since the licensee has justified the leaktight integrity of the containment based on previous leakage test results, the staff concludes that a one-time extension of the second
- 10-year service period and a one-time implementation of an extended test interval will not have a significant safety impact.
)
III.
Pursuant to 10 CFR 50.12, the Commission may, upon application by any interested person or upon its own initiative, grant exemptions from the requirements of 10 CFR Part 50 when (1) the exemptions are authorized by law, will not present an undue risk to public health and safety, and are consistent with the common defense and security; and (2) when special circumstances are present.
Special circumstances are present whenever, according to 10 CFR 50.12(a)(2)(ii), " Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule...."
The underlying purpose of the requirement to perform Type A containment leak rate tests is to provide for periodic verification of the leak-tight i
integrity of the primary reactor containment. The licensee has demonstrated that the leak tight integrity of the primary containment can be assured the latest test results and by controlling the maintenance activities which affect a primary containment penetration. The Type B and C testing will provide additional assurance of the overall integrity of the primary containment.
1 On this basis, the NRC staff finds that the licensee has demonstrated that special circumstances are present as required by 10 CFR 50.12(a)(2)(ii).
Since the licensee has justified the leaktight integrity of the containment based on previous leakage test results, the staff concludes that a one-time extension of the second 10-year service period will not have a significant
4
- safety impact. The staff also finds that extending the interval between tests will not present an undue risk to the public health and safety.
i IV.
Accordingly, the Commission has determined that, pursuant to 10 CFR 50.12, an exemption is authorized by law and will not present an undue risk to the public health and safety and that there are special circumstances present, as specified in 10 CFR 50.12(a)(2), such that application of 10 CFR Part 50, Appendix J, Section III.D.I.(a) is not necessary in order to achieve the underlying purpose of this regulation; and hereby grants the following exemption with respect to the requirements of 10 CFR Part 50, Appendix J, Section III.D.I.(a).
For the Peach Bottom Atomic Power Station, Unit 2, the second 10-year Type A service period is extended such that the third periodic Type A test may be performed during the Unit 2 Refueling Outage 11 currently scheduled for September 1996 and such that the three Type A tests in the second 10-year service period are r
performed at intervals that are not approximately equal.
i i
l 3
Pursuant to 10 CFR 51.32, the Commission has determined that the granting of this exemption will have no significant effect on the quality of the human environment (59 FR 50018).
This exemption is effective upon issuance.
FOR THE NUCLEAR REGULATORY COMMISSION
/S/
Steven A. Varga, Director Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Dated at Rockville, Maryland this 30th day of September 1994 i-i V
l I
- Previously Concurred
/
OFFICE:
F)D$$M/7DI--[)(PE hDI-J/PM PDI-2/Ihk/
OGC*
DRPE/AD*
DRPE/D*
i NAME:
kOT[J'e[4khM N rb MThada[
RWeisman CMiller SVarga DATE:
h />h ( h /94 kg94 9/h/94 09/23/94 09/26/94 09/27/94 i '
i
~~-,
Pursuant to 10 CFR 51.32, the Commission has determined that the granting of this exemption will have no significant effect on the quality of the human environment (59 FR 50018
).
This exemption is effective upon issuance.
FOR THE NUCLEAR REGULATORY COMMISSION f?
'4 even A.
- rga, e
Division of Reactor Pr icts - I/II Office of Nuclear Reactor Regulation Dated at Rockville, Maryland this 30th day of September 1994 i
l e