ML20081K780

Proposed Tech Specs Re Overall Integrated Containment Leakage Rate Tests

ML20081K780
Person / Time
Site:	Grand Gulf
Issue date:	06/25/1991
From:	ENTERGY OPERATIONS, INC.
To:
Shared Package
ML20081K778	List: ML20081K776 ML20081K780
References
NUDOCS 9107020017
Download: ML20081K780 (6)

Text

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PS- Wo.2

• CONTAINMENT SYS?ECS LIMITING CONDITION FOR OPERATION (Continued)

ACTION (Continued) b.

The combined leakage rate for all penetrations and all valves #

subject to Type B and C tests to less than or equal to 0.60

c. L,, and The leakage rate to less than 100 scf per hour for all four main steam Ifnes through the isolation valves, and d.

The combined leakage rate for all cor,tainment isolation valves in hydrostatically tested lines which penetrate the primary containment to less than or equal to 1 gpa times the total number of such valves, prior to increasing reactor coolant system temperature above 200*F.

SURVEILLANCE REQUIREMENTS

4. 6.1. 2 test schedule and shall be determined in confurmance with fled in Appendix 1972: J of 10 CFR 50 using the methods and provisions of ANSI N45.4 -

a.

Three Type A Overall Integrated Containment Leakage Rate tests shall psig, during each 15 year serviced period.be conducted 4he-ttrird-t;;t 11.5 at 40 of eseh-set- 1 + 1 enduct:d derifi the shutd;.;n fcr the 10 yeer p1;nt incervice q

b. If any periodic Type A test fails to meet 0.75 L the test schedule I forsubsequentTypeAtestsshallbereviewedan8,approvedbythe Commission. If two consecutive Type A tests fail to meet 0.75 L I Type A test shall be perfonned at least every 18 months until tw8, a consecutive schedule may Type A tests meet 0.75 L,, at which time the above test be resumed, c.

The accuracy of each Type A test shall be verified by a supplemental test which:

1.

Confirms the accuracy of the test by verifying that the '

cont.ainment leakage rate, L'y, calculated in accordance with ANSI N-45.4-1972, Appendix C, is within 25 percent of the containment leakage rate, Ly , measured prior to the introduc-tion of the superimposed leak.

2.

Has duration sufficient to establish accurately the change in leakage rate between the Type A test and the supplemental test.

I 3. Requires the quantity of gas injected into the containment or bled from the containment during the supplemental test to be between 0.75 L, and 1.25 L,.

1. I ncludes all valves listed in Table 3.6.4-1, except for those that are

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I S- 41/o 2 3/4.6 CONfAINMENT SYSTEMS BASES 3/4.6.1 PRIMARY CONTAINMENf 3/4.6.1.1 PRIMARY CONTAINMENT INTEGRITY PRIMARY CONTAINMENT INTEGRITY ensures that the release of radioactive materials from the containment atmosphere will be restricted to those leakage paths and associated leak rates assumed in the accident analyses. This restric-tion, in conjunction with the leakage rate limitation, will limit the site boundary radiation doses to within the limits of 10 CFR Part 100 during accident conditions.

3/4.6.1.2 CONTAINMENT LEAKAGE The limitations on containment leakage rates ensure that the total containment leakage volume will not exceed the value assumed in the accident analyses at the peak accident pressure of 11.5 psig, P . As an added conser-vatism, the measured overall integrated leakage rate il further limited to less than or equal to 0.75 L during performance of the periodic tests to account for possible degradation of,the containment leakage barriers between leakage tests.

Operating experience with the main steam line isolation valves has indicated that degradation has occasionally occurred in the leak tightness of the valves; therefore the special requirement for testing these valves.

The surveillance testing for measuring leakage rates is consistent with exemthe ion requirements of Appendix

( ranted for testing the aMocksJ af toter 10each CFRop~enin 50 with nthe exception W on co. > _o p "$ny C i

(Hn .6. "}{'GJ~ Me resc e p ,,cT'}H5 F e fu, cu tay ep 3~C MENT ~ AIR"LiR D thMjd mWW l The limitations on closure and leak rate for'tlie containment air locks are required to meet the restrictions on PRIMARY CONTAINMENT INTEGRITY and the containment leakage rate given in Specifications 3.6.1.1 and 3.6.1.2. The specification makes allowances for the fact that there may be long periods of time when the air locks will be in a closed and secured position during reactor operation. Only one closed door in each air lock is requi ed to maintain the integrity of the containment. Verification that each air lock door inflatable seal system is OPERABLE by the performance of a local leak-detection test for a period of less than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is permissible if it can be demonstrated that the leakage rate can be accurately determined for this shorter period. (This is in accordance with Sections 6.4 and 7.6 of ANSI N45.4-1972.)

3/4.6.1.4 MSIV LEAKAGE CONTROL SYSTEM Calculated doses resulting from the maximum leakage allowance for the main steamline isolation valves in the postulated LOCA situations would be a small fraction of the 10 CFR 100 guidelines, provided the main steam line system from the isolation valves up to and including the turbine condenser remains intact.

Operating experience has indicated that degradation has occasionally occurred in the leak tightness of the MSIV's such that the specified leakage requirements have not always been maintained continuously. The requirement for the leakage control system will reduce the untreated leakage from the MSIVs when isolation of the primary system and containment is required.

GRAND GULF-UNIf 1 B 3/4 6-1

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Attachment 3 to GNRO-91/00086 t

10CFR50 Appendix J Exemption Request-G9105161/SNLICFLR - 13

Attachment 3 to GNRO-91/00086 Page 1 Request For Exemption From 10CFR50, Appendix J Section III.D.I.(a) Regarding Periodic Type A Testing A. DESCRIPTION OF REQUESTED EXEMPTION Entergy Operations, Inc. hereby applies for exemption from the requirements of 10CFR Part 50, Appendix J, Section III.D.1.(a) for Grand Gulf Nuclear Station (GGNS). Section III.D.1.(a) requires the performance of a set of three Type A tests after the preoperational leakage rate test, at approximately 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 (ISI) required by Section 50.55a. The NRC has determined that "approximately equal intervals" refers to a duration of 40 + 10 months.' This exemption would allow the third Type A Containment Integrated Leak Rate Test (ILRT) of the current 10-year service period (and subsequent periods) to be uncoupled from the ISI schedule. -Additionally, this exemption would permit a one-time extension of the allowed test interval for the third ILRT only, so that the Type A test may be conducted during the sixth refueling outage.

This Appendix J exemption request is being made in conjunction with the appropriate request for an amendment to the GGNS Operating Licnnse in the form of changes to the Technica) Specifications (TS)

(Attachment 2 to this submittal). The proposed changes will allow the TS to conform to this exemption. A detailed discussion of the reasons for requesting both the TS changes and this Appendix J exemption is provided in Sections B and C of Attachment 2.

B. JUSTIFICATION FOR REQUESTED EXEMPTION 10CFR50.12(a) allows the Commission to grant specific exemptions from the requirements of its regulations provided certain standards are met. These are: (1) the exemptions are authorized by law, will not present undue risk to the public health and safety, and are consistent with the common defense and security; and, (2) special circumstances are present as defined by any of the situations described in Section 50.12(a)2, paragraphs (1) through (iv).

3 54 Federal Register 41,702 (1989)

G9105161/SNLICFLR - 14

Attachment 3 to GNRO-91/00086 Page 2

.... . 4 Entergy Operations, Inc. has evaluated the requested exemption in

accordance with the above criteria. The request moots the requirements of 10CFR50.12 and should thnrefore be granted. Entergy Operations presents the following analyses in support of this application for exerption from Appendix J -

r

1. 50.12(a)(11 - Exemption Critoria

a. The exemption is_ authorized by law. Entergy Operations is currently authorized to operate GGNS Unit 1 pursuant to Licenso No. NpF-29 f asued in accordance with the Atomic Energy Act as amended. The NRC is empownred to grant an exemption to a regulation it has promulgated,8 and sinco no other prohibition of law exists to preclude the activities ,

which would be permitted by this exemption, the exemption is authorized by law,

b. Tho _ exemption will not prosent _unduo risk _to the public health _and safety. Entergy Operations, Inc. has analyzed the

• potential consequences of the proposed exemption and the results are detailed in Section C of Attachmont 2 of this submittal. In addition, Entergy Operations, Inc. has determit.ed that it involvos no significant hazards ,

considerations as defined in 10CFR50.92, as presented in Section D of-Attachmont 2 to this submittal. Accordingly, Entorgy Operations, Inc. concludes that granting of this exemption does not pose an undue risk to public hoolth and safety,

c. The exemption is consistent with the common defonso and security. As described in Attachment 2, this exemption allows for continued safe and cost offectivo power generation.

by GGNS. Thus, Entergy Operations concludes that the ,

exemption is consistent with the common defense and security.

t

2. 50.12Ja)12) - Existence of Special Circumstances Entorgy Operations, Inc. submits the following special circumstances which exist surrounding this application for exemption:

para _.11)-Appl.i_ cat ion of the regulation conflicts with other rules or re3uirements. As described in Sections B.3 and C.1 of Attachment 2, it is not possible for GGNS to comply verbatim with

_ the provisions of Appendix J, Section Ill.D.1.(a) which

! simultaneously. require conduct of the third ILRT during tho l

10-year ISI outage and within 40 + 10 months of the previous

, test. Thus, in this particular situation, the regulation bncomes internally confl.icting so that relist must be granted or GCNS will bo in-do-facto violation of the regulations regardless of the actions taken.

2 S00: United States v. Allegl.Lony-Ludlum Stent Corp. , 406 U.S. 742 (1972)

G9105161/SNhlCFLR - 15

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Attachment 3 to GNRO-91/00086 page 3 Para.(if)-Application of the regulation...is not necessary to achieve the underlying purpose of the rule. The purpose of 10CFR50 Appendix J as described in its. introduction is to " assure that... leakage through the primary reactor containment and systems and components penetrating primary containment shall not exceed allowable Icakage rate values as specified in the TS or associated bases..." As described in Sections C.2 through C.7 of Attachment 2, this purpose can be fully achieved ender the actions proposed by the requested exemption.

Para.(fil)-Compliance would result in undue hardship or other I costs that_are significantly in excess of those contemplated when the regu)_ation was adopted. As stated in the discussion of para, (1) above, verbatim compliance with the regulation in this particular case is not possible. Ilowever, actions other than l those proposed in this request may be considered as a means of meeting the intent of the regulations. Such an alternative la described in Section C.2 of Attachment 2. Not only would this action not meet the letter of the regulation, but it would also place an undue burden on Entergy Operations, Inc. In terms of cost, personnel exposure, and other penalties well in excess of those intended by the regulation. Thus, the exemption as proposed is most suited to meeting the intent of the regulation without imposing undue hardship.

1 Based on the above, Entergy Operations Inc. requests that an- {

exemption from 10CFR50 Appendix J, Section III.D.1.(a) be granted for j GGNS.

i C. ADDITIONAL CONSIDERATIONS As a matter of precedent, similar exemptions have been granted by the i NRC for numerous other facilities as discussed in Section B.7 of '

Attachment 2.

G9105161/SNLICFLR - 16

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