ML20098F519

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Informs That Util Cannot Comply W/Requirement to Perform Testing of Containment Personnel Airlock Every 6 Months & Testing at Ambient Pressure.Draft Proposed Tech Spec & Summary of Type B Testing History Encl
ML20098F519
Person / Time
Site: Quad Cities  Constellation icon.png
Issue date: 09/26/1984
From: Rybak B
COMMONWEALTH EDISON CO.
To: Harold Denton
Office of Nuclear Reactor Regulation
References
9232N, NUDOCS 8410030081
Download: ML20098F519 (6)


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/ Chicago Illinois 60690 September 26, 1984 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 Sub ject:

Quad Cities Station Units 1 and 2 Draft Technical Specification Amendment Appendix J Testing -

Containment Personnel Airlock NRC Docket Nos. 50-254 and 50-265 References (a):

D. B. Vassallo letter from D. L. Farrar dated June 12, 1984.

Dear Mr. Denton:

The referenced letter denied our request for specific exemptions-from 10 CFR 50.54(o) and Appendix J on the testing of the containment personnel airlock.

Instead, the Staff amended our request but still requires to perform testing every six months and requires some testing at Pa (48 psig).

Specifically, testing at Pa may be extended to the next refueling outage, but in no case shall exceed 24 months from the last test at Pa, provided that there have been no airlock openings since the last successful test at Pa and a Pa test is performed following the next airlock opening.

A reduced pressure test or testing between seals shall be performed every six months.

Our review of this exemption finds, in short, that we cannot comply.

The containment personnel airlock is designed to withstand pressure from one side, the containment, with minimal leakage.

We question the structural integrity of the airlock, specifically the inner door, when testing between the two doors at Pa.

To resolve that question we are performing an engineering design review of the inner, airlock door's pressure retaining capability with or without the hold-down beams installed.

In recognition of the design characteristics of these doors, we have enclosed for your review DRAFT proposed Technical Specifica-tion changes which we still believe may meet the intent of Appendix J to 10 CFR 50.

Following your review we will formally submit these proposed amendments with appropriate fees pursuant to 10 CFR 170.

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l H. R. Denton September 26, 1984 Finally, we are attaching a table which summarizes-the Type B testing history on the containment personnel airlock at both units at Quad Cities.

As can be seen from this' record, Quad Cities' airlocks have shown acceptably low or zero leakage since the-first.

tests done in 1970.

Please direct any questions that you ma'y have regarding this. matter to this office.

.One signed original and forty (40) copies of this transmittal are provided for your use.

Very truly yours, B. Ryb W Nuclear Licensing Adminstrator

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R. Bevan - NRR NRC Resident Inspector - Quad Cities Attachments A:

DRAFT Technical Specification Amendment to OPR-29 and DPR-30.

B: -Quad Cities Containment Personnel Airlock Test History 9232N L

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s ATTACHMENT-A

' QUAD. CITIES' STATION UNITS 1 and 2

" DRAFT TECHNICAL-SPECIFICATION AMENDMENT FOR 1

. PERSONNEL AIRLOCK TESTING (APPENDIX-J).

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%,ID/0163A/

o' QUAD-CITIES DPR-29/30

< L, 1 0' percent. by-b.

If ' any periodic Type A test b) t weight of the fails to meet either 0.75 L a containment air per 24 or 0.75 L the test schedule t,

hours at a reduced for subsequent Type A tests pressure of P,

shall~be reviewed and approved t

25 psig.

by the commission.

If two consecutive Type A tests fail 2)

A combined leakage rate.

to. meet.either 0.75 La.or of < 0.60 L for all 0.75 L a

t, a Type-A test shall penetrations and valves, be performed at least every 18 except for main steam.

months until two consecutive isolation valves, subject Type A tests meet.either 0.75 to Type B and C tests when L or 0.75 Lt, at which a

pressurized to P time the above test schedule-a.

may be resumed.

3) 11.3 scf per hour for any one main steam isolation c

The accuracy of each Type A valve when tested at 25 test shall be verified by a psig.

g supplemental test which:

b.

With the measured overall 1)

Confirms the accuracy of integrated containment leakage the test by verifying that rate exceeding 0.75 L or the difference between the a

0.75 L, as applicable, supplemental data and the t

restore the overall integrated Type A tests data is within leakage rate (s) to 5,0.75 L 0.25 L or 0.25 L a

a t'

or 5,0.75 L, as applicable.

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Has a duration sufficient c.- With the measured combined to establish accuratley the leakage rate for all change in leakage rate penetrations and valves,'except between the Type A test and for main steam isolation the supplemental test.

valves, subject'to Type B'and C tests exceeding 0.60 L,

3)

Requires the quantity of a

restore the combined leakage gas injected into the rate for'all penetrations and containment or bled from valves, except for main steam the containment during the isolation valves, subject to supplemental test to be Type B and C tests to < 0.60 equivalent to at least 25 L.

percent of the total a

l measured leakage at P a' d.

Leakage shall be limited to a 48 psig, or Pt, 25 psig.

s leakage rate of less than or equal to 3.75 percent of L d.

Type-B and C test shall be a

for any one' air lock.

_ conducted at Pa, 48' psig, at intervals no greater than 24 months except for tests involving:

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.,.ID/0163A/

QUAD-CITIES

'DPR-29/30 e.

With the measured leakage rate ^

1)

Main steam isolation l

exceeding 11.5 scf per hour for valves, which shall be leak any one main steam isolation tested at least once per 18 valve, restore the leakage rate months at a pressure of 25 to < 11.5 scf per hour for any psig, and j

one main steam isolation valve prior to increasing the reactor 2)

Bolted double-gasketed l

coolant. temperature abovet212

seals which shall.be tested F.

at a pressure of 48 psig whenever the seal is closed after being opened and each operating cycle.

e.

All test-leakage rates shall be calculated using observed data converted to absolute values.

Error analyses shall be performed to select a' balanced integrated leakage measurments system.

f.

The drywell personnel air lock shall be tested:

1)

When primary containment is r.

not required and within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following closure by verifying that the leakage rate is less than or equal to its limit when tested at 1.0 psig.

2) When primary containment is required and an entry made, the 1.0 psig test will be performed at the nesxt time primary containment is not required..

3)

Each operating cycle at 10 psig when a Type A test is not scheduled.

7, 4

4)

At P, 48 psig, when a

conducting a Type A test, and verifying that the overall air lock leakage rate is less than or equal to its limit.

3.

Pressure Suppression Chamber-Reactor Building Vacuum 3.

Pressure Suppression Breakers.

Chamber-Reactor Building-Vacuum Breakers.

a.

Except as specified in Specficiation 3.7.A.3.b below, a.

The pressure suppression two pressure sup chamber-reactor building vacuum 3.7/4.7-4

m.

ATTACHMENT B QUAD CITIES STATION CONTAINMENT PERSONNEL AIRLOCK TEST HISTORY UNIT 1 UNIT 2 Date Leakage Date Leakage December 2, 1970 0.07 SCFH August 27, 1971 0.0 SCFH May'18, 1974 0.00 SCFH January 25, 1975 0.0 SCFH January 9,- 1976 0.00 SCFH October 5, 1976 7.0 SCFH May.7, 1977 6.97 SCFH March 3, 1978 9.5 SCFH February 4, 1979 10.10 SCFH January 16, 1980 1.'.74 SCFH zDecember 19,-1980 0.00 SCFH December 18, 1981 1.0.30 SCFH November 26, 1982-0.00 SCFH January 14, 1984 24.73 SCFH April 2, 1984.

3.43 SCFH January 20, 1984 1.37 SCFH 9232N