ML20094A057

Requests Partial Exemption from 10CFR50,App J,To Allow Reduced Pressure Leakage Testing of Containment Air Locks Following Periods When Air Locks Open & Containment Integrity Not Required by Tech Specs

ML20094A057
Person / Time
Site:	Callaway
Issue date:	07/31/1984
From:	Schnell D UNION ELECTRIC CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
ULNRC-892, NUDOCS 8408030098
Download: ML20094A057 (12)

Text

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UNION ELECTRIC COM PANY 1901 GRATIOT STREET ST. LOuls, MISSOURI July 31, 1984 - iunO ooa ...

DO*d ALD P. .CHN=LL P. O. .OX 949 4.c . ... .. . m .r. LOui.. mi.souai .u ..

.Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Denton:

ULNRC- 892 DOCKET NUMBER 50-083 CALLAWAY PLANT, UNIT 1 APPLICATION FOR PARTIAL EXEMPTION FROM APPENDIX J e

The purpose of this letter is to request a partial exemption, pursuant to the provisions of 10CFR50.12, from the testing requirements of 10CFR50, Appendix J.

The exemption requested would allow reduced pressure leakage testing of containment air locks following periods when the air locks-are open and containment integrity is not required by the Technical Specifications.

The reduced pressure test uses a testable seals feature which verifies that the seal leakage is less than 0.0054 as determined by precision flow measurements when measured for at least 30 seconds at a constant pressure of greater than or equal to 10 psig. The air locks will be tested at Pa (as defined in

-Technical Specification 3.6.1.2) at least once every 6 months and prior to' establishing containment integrity when maintenance has been performed on an air lock that could affect the lock's sealing capability.

The current requirement contained in 10CFR50, Appendix J, III.D. 2. (b) (ii) poses a significant burden. Air locks will usually be opened during outages to facilitate equipment and personnel transport into and out of containment. Prior to entry into Mode 4, the air lock leakage-tests are required to be performed. Installing strongbacks, performing the tests and removing strongbacks requires at least six hours during which access through the air locks is prohibited. The proposed changes would provide for reduced pressure tests, if the test at-Pa had been performed within 6 months and air lock sealing maintenance had not been performed. This will-allow better scheduling of the normal air lock leakage test during periods when the need for access to containment is minimal.

i e40803OO98 840731 PDR ADOCK 05000483 1 p PDR l (g gc. keerc# Y/6D 09

Mr. Hnrold R. D;nton

.*- July 31, 1984 Page 2 This exemption will not pose any undue-risk'to the health and safety of the'public. Testing of the air locks at reduced pressure by the use of the testable seals feature in conjunction-with tests at Pa every 6 months'and following seal maintenance  ;

provides adequate assurance of proper seal performance. The air locks are designed to maintain. containment integrity with a pressure applied.from inside containment. Testing of the overall air lock at Pa from within the air lock does'present some possibility of damage or degradation to the containment side air lock door and seal.

The Standard. Technical Specifications for Westinghouse PWR's (NUREG-0452, Revision 4) generically recognize-this as an area for possible exemption to Appendix J. The Callaway Technical Specifications do not require an amendment to be consistent.with this exemption request.

This request for exemption is for the_ duration of the license for Callaway Plant, Unit 1. If any questions arise during your review of this-request, please contact us.

Very truly yours, e

c Dona F. 'Schnell JS/sz cc: J. Holonich

-STATE OF MISSOURI )

)- SS CITY OF ST. LOUIS )

Robert J. Schukai,-of lawful age, being first duly sworn upon oath says that he is General Manager-Engineering (Nuclear) for Union Electric Company; that he has read the foregoing document and knows the content thereof; that he has executed the same for and on behalf of said company 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.

By Rbbe . ukai Gener ager-Engineering Nuclear SUBSCRIBED and sworn to before me this 8/a5 day of , 198 d 77tm e d / A 0MARGARET S. HEIDA NOTARY PUBUO-STATE CF 'AiSSOURI ST. LOUIS COUNTY MY COMMISSION DPIRES JANUARY 2,1986 i

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cc: Gerald Charnoff, Esq.

Shaw, Pittman, Potts & Trowbridge 1800 M. Street, N.W.

Washington, D.C. 20036 Nicholas A. Petrick Executive Director SNUPPS S Choke Cherry Road Rockville, Maryland 20850 John H. Neisler Callaway Resident Office U.S. Nuclear Regulatory Commission RR$1 Steedman, Missouri 65077 William Forney Divisi7n of Projects and Resident Programs, Chief, Section lA -

U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Bruce Little Callaway Resident Office U.S. Nuclear Regulatory Commission RRil Steedman, Missouri 65077

,- s, UNION ELECTRIC COM PANY 19c1 GRATIOT STREET ST. Louis, MISSOURI July 3L 1984 =*iu-O.DoMSSS DONALD F. SCHNSLL P. O. SOM 949 voce eatselDENT ST. LOUIS. MIS SOURI SS I SS Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Denton:

ULNRC- 892 DOCKET NUMBER 50-483 CALLAWAY PLANT, UNIT 1 APPLICATION FOR PARTIAL EXEMPTION FROM APPENDIX J The exemption,pursuant ,

purposetoof the thisprovisions letter is to of request a partial 10CFR50.12, from the testing requirements of 10CFR50, Appendix J.

The exemption requested would allow reduced pressure leakage testing of containment air locks following periods wher the air locks are open and containment integrity is not required by the Technical Specifications.

The reduced pressure test uses a testable seals feature which verifies that the seal leakage is less than 0.005La as determined by precision flow measurements when measured for at least 30 seconds at a constant pressure of greater than or equal to 10 psig. The air locks will be tested at Pa (as defined in Technical Specification 3.6.1.2) at least once every 6 months and prior to establishing containment integrity when maintenance has been performed on an air lock that could affect the lock's sealing capability.

The current requirement contained in 10CFR50, Appendix J, III.D.2. (b) (ii) poses a significant burden. Air locks will usually be opened during outages to facilitate equipment and personnel transport into and out of containment. Prior to entry into Mode 4, the air lock leakage tests are required to be performed. Installing strongbacks, performing the tests and removing strongbacks requires at least six hours during which access through the air locks is prohibited. The proposed changes would provide for reduced pressure tests, if the test at Pa had been performed within 6 months and air lock sealing maintenance had not been performed. This will allow better scheduling of the normal air lock leakage test during periods when the need for access to containment is minimal.

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.Mr. Htrold R. Denton

. July 34'1984 Page 2 This exemption will not pose any undue risk to the health and safety of the.public. Testing of the air locks.at reduced pressure by the use of the testable seals feature in conjunction with tests at P a every 6 months and following seal maintenance provides adequate assurance of proper seal performance. The air

~

locks are designed to maintain containment integrity with a pressure applied from inside containment. Testing of the overall air lock at P from within the air lock does present some possibility o$ damage or degradation'to the containment side air lock door and seal.

Une, Standard Technical Specifications for Westinghouse PWR's (NUREG-0452, Revision 4) generically recognize this as an area for pcssible exemption to Appendix J. The Callaway Technical Specifications do not require an amendment to be consistent with this exemption request.

This request for exemption is for the duration of'the  :

licence for Callaway Plant, Unit 1. If any questions arise  ;

during your review of this request, please contact us. l Very truly yours, e) l 3 5% Donal Schr.all -

j DS/sz

! cc: J. Holonic.

STATE OF MISSOURI )'

) SS CITY OF ST. LOUIS )

Robert J. Schukai, of lawful age, being first duly sworn upon oath says that he is General Manager-Engineering (Nuclear) for Union Electric Company; that he has read the foregoing document and knows the content thereof; that he has executed the same for and on behalf of said company 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.

^

By Rober(J. S)hukai General Manager-Engineering Nuclear SUBSCRIBED and sworn to before me this J/cd day of , 198M 2hwuAjJIAu

/ MARGARET S. HEIDA NOTARY PUBLtC-STATE OF !AISSOURI ST. LOUIS COUNTY MY COMMISSION DPIRES JANUARY 2,1986

cc: Gerald Charnoff, Esq.

Shaw, Pittman, Potts & Trowbridge 1800 M. Street, N.W.

Washington, D.C. 20036 Nicholas A. Petrick Executive Director

'SNUPPS 5 Choke Cherry Road Rockville, Maryland 20850 John H. Neisler Callaway Resident Office U.S. Nuclear Regulatory Commission RRil Steedman, Missouri 65077 William Forney Division of Projects and Resident Programs, Chief, Section lA U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137

. Bruce Little i

Callaway Resident Office U.S. Nuclear Regulatory Commission RRil Steedman, Missouri 65077

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UNION ELECTRIC COM PANY lect GRATIOT STREET ST. Louis, Missoumi e July 31, 1984 , , , , , , , , , , , , , ,

OONALD P. SCHNELL P. O. SON i49 v.e........,- sr. Louis, mis.Ou . esi .

O Mr.. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Denton:

ULNRC- 892 DOCKET NUMBER 50-483 CALLAWAY PLANT, UNIT 1 APPLICATION FOR PARTIAL EXEMPTION FROM APPENDIX J The purpose of-this letter is to request,a partial exemption, pursuant to the provisions of 10CFR50.12, from the testing requirements of 10CFR50, Appendix J.

The exemption requested would allow reduced pressure leakage testing of containment air locks following periods when the air '

locks are open and containment integrity is not required by the Technical Specifications.

The reduced pressure test uses a testable seals feature which verifies that the seal leakage is less than 0.005La as determined by precision flow measurements when measured for at least 30 seconds at a constant pressure of greater than or equal to 10-paig. The air locks will be tested at P a (as defined in Technical Specification 3.6.1.2) at least once every 6 months and prior to establishing containment integrity when maintenance has been performed on an air lock that could affect the lock's sealing capability.

The current requirement contained in 10CFR50, Appendix J, III.D. 2. (b) (ii) poses a significant burden. Air locks will usually be opened during outages to facilitate equipment and ,

personnel transport into and out of containment. Prior to entry into Mode 4, the air lock leakage tests are required to be performed. Installing strongbacks, performing the tests and removing strongbacks requires at least six hours during which access through the air locks is prohibited. The proposed changes would provide for reduced pressure tests, if the test at P a had been performed within 6 months and air lock sealing maintenance had not been. performed. This will allow better ccheduling of the normal air lock leakage test during periods when the need for access to containment is minimal.

m

.Mr. Harold R.-Denton

., July 31,.1984 Page 2 This exemption will not pose'any undue risk to the health and safety of the public. . Testing of the air locks at reduced pressure by the use of the testable seals feature in conjunction with tests at P every 6 months and following seal maintenance provides adequase assurance of proper seal performance. The air

- locks are designed to maintain containment integrity with a pressure applied from inside. containment. Testing.of the overall air lock at Pa from within the air lock does present some possibility of damage or degradation to the containment side air lock door and seal.

The Standard Technical' Specifications for Westinghouse PWR's (NUREG-0452, Revision 4) generically recognize this as an area for possible exemption to Appendix J. 'The Callaway Technical

. Specifications do not require an amendment to be consistent with this exemption request.

s This request for exemption is for the duration of the license for Callaway Plant, Unit 1. If any questions arise during your review of this request, please contact us.

Very truly yours,

\

dk Dona F. Schnell DS/sz cc: J. Holonich l

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o STATE OF MISSOURI )

) SS CITY OF ST. LOUIS )

Robert J. Schukai, of lawful age, being first duly sworn upon oath says that he is General Manager-Engineering (Nuclear) for

, Union Electric Company; that he has read the foregoing document and knows the content thereof; that he has executed the same for and on behalf of said company 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.

By \

Ro t J. chukai Gene nager-Engineering Nuclear SUBSCRIBED and sworn to before me this d/aI day of 7 , 198d

$d$rMJt *-

r MARGARET S. HEIDA NOTARY PUBUC-STATE OF msgoung ST. LOUIS COUNTY NV N gapigES JANU4gy g, gg 1

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___.__.__m..-

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cci Gerald Charnoff, Esq.

Shaw, Pittman, Potts & Trowbridge

! 1800 M. Street, N.W.

Washington, D.C. 20036 Nicholas A. Petrick.

Executive Director ,

SNUPPS 5 Choke Cherry Road Rockville, Maryland 20850 John H. Neisler Callaway Resident Office

! U.S. Nuclear Regulatcry Commission RR$1 Steedman, Missouri 65077 l William Forney l Division of Projects and l Resident Programs, Chief, Section lA

U.S. Nuclear Regulatory Commission l Region III

( 799 Roosevelt Road l Glen Ellyn, Illinois 60137 Bruce Little Callaway Resident Office

, U.S. Nuclear Regulatory Commission i

RRil Steedman, Missouri 65077 l

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