ML20101E931
| ML20101E931 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 06/16/1992 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| ULNRC-2648, NUDOCS 9206240176 | |
| Download: ML20101E931 (7) | |
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2 mn. u w. Erss 3 N 554266/1 Donald F. SchneII ELECTRIC June 16, 1992
$ U.S. Nuclear Regulatory Commission Attn:
Document Mntrol Desk Mail Station P1-137 Washington, D.C.
20555 Gentlemen:
ULNRC-2648 DOCKET NUMBER 50-483 CALLAWAY PLANT EXEMPTION FROM 10CFR50. APPENDIX J.
SECTION III.D.1 (a)
References:
1)
ULNRC-2650, dated June 16, 1992 2)
NRC letter from M. D.
Lynch to t
l D.
F.
Schnell, dated October 22, 1991 Union Electric Company herewith transmits an exemption request, pursuant tc the provisions of 0CFR50.12, from the testing requirements of 10CFR50, Appendix J, Section III.D 1(a).
This request is a one-time exemption that would allow the third test of the first 10-year service period to be performed approximately 14 months beyond the 10-year service period.
The attachment contains the Exemption Request with evaluation and 10CFR50.12 Special Circumstances in support of this request.
The Callaway Onsite Review Committee and the Nuclear Safety Review Board-have approved the exemption request.
We are requestirg that the NRC Staff please expedite their review of this submittal so that the requested exemption will be issued by October 1992 to facilitate our planning for future CI RTs.
Very truly yours, I
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Donald F.
Schnell I
JMC/kea l
Attachment 1
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9206240176 920616 g.
I ADOCK0500g3 DR.
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. STATE OF MISSOURI-)
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Donald F.
Schnell, of lawful age, being first duly sworn upon oath says that he is Senior Vice President-Nuclear and an officer of Union Electric Company; that he has read the foregoing document and knows the content therenf; 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, informat. ion and belief.
By 6
Donald F. 'Schnell Senior Vice President Nuclear SUBSQRIBED and sworn to Defore me this /d b day of
(/Eng-1992.
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o' o g Ba si6MA J. PF U F NOia9Y FUEUC STME CT MbS00Ri MY COMyu:;iC4 EXFIRES APRtl 22,10%
ST. LOUIS COUNTY S
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T. A.
Baxter, Esq.
Shaw, Pittman,_Fotts & Trowbridge
~2300 N. Street, N.W.
-Washington,- D.C. 20037 Dr. J. O. Cermak CFA, Inc.
18225-A Flower Hill Way Gaithersburg, MD-20879-5334 R. C.
Knop Chief, Rcactor Project Branch 1
-U.S.
Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen-Ellyn, Illinois 60137
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Bruce Bartlett Callaway Resident-Office
-U.S.. Nuclear Regulatory Commission j
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Steedman, Missouri 65077 L.
R. Wharton (2)
Office'of Nuclear Reactor Regulation U.S.
Nucleer Regulatory Commission 1 White Flint,. North, Mail Stop 13E21 11555 Rockville Pike-l Rockville, MD-20852
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Manager, Electric Department Missouri Public Service Commission P.O.
Box 360 EJefferson City, MO 65102 g
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'/QA Record (CA-758) e Nuclear.Date E210.01 DFS/ Chrono D.
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Schnell J.
E. Birk J. V.:Laux M. A.
Stiller G._L.
Randolph R. J.
Irwin P.
Barrett C.
D. Naslund
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Passwater D. E. Shafer W.
E, Kahl S. Wideman (WCNOC)
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C. Slovic (Bechtel)
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P. Pharkey NSRB (Sandra Dale)
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- e Attachment Page 1 of 3 s
ULNRC-2648 EXEM* TION REOUEST-
' Proposed Exemotion This proposed exemption request is to.10CFR50, Appendix J, Section -III.D.1 (a) which requires a set.of three Type A tests (Containment Integrated Leakage Rate Test or CILRT) be periormed, at apptcrimately' equal intervals during each 10-year service period. -This request is a one-time exemption that would allow the third test of the first 10-year service period to be performed'approximately 14 months beyond the 10-year service period. _This exemption is needed in conjunction withfour amendment. request (Reference 1) to Technical Specification (T/S) 4.6.1.2.a that would allow the third test to be performed at approximately a 53-month interval in lieu of the current maximum interval of 50 months.
This 53-month interval coupled with the first and second-test intervals of 40 and 41 months respectively would exceed the 10-year time frame for-the first-service period.
Backaround Type A tests are defined it.Section II.F of 10 CFR 50, Appendix J as those tests intended to measure the primary reactor containment overall-integrated leakage rate at periodic intervals.
The-time required to perform the CILRTs necessitates that they be performed during refueling-outages.
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.
Since refueling outages do not necessarily occur coincident with a 40-month interva:, a permissible variation of.10 months (i.e.,
a 25 percent variation) is authorized in the-T/S to permit flexibility in scheduling the CILRTs.
The first and second CILRTs, of the set of three tests for the
-first 10-year service period for Callaway Plant, were conducted in April 1987 and October 1990, respectively.
This represents testing intervals of 40 and 41 months from the initial preoperational CILRT perfor;med in January 1984.
This would indicate that the third of the first set of thred CILRTs be performed at Refuel 6 scheduled for-September 1993 which will be 35 months after the preceding test and within the first 10-year L
service _ period.
The result of this testing sequence would cause an extra CILRT to be performed over the course of_the next c
10-year service period based on the 40 i 10-month testing interval-coincident with the 18-month fuel cycle utilized at Callaway Plant.
In order to prevent performing this fourth CILRT p-in theLsecond 10-year service period, we are proposing that the L
third CILRT for the first 10-year service period be performed during Refuel 7 scheduled for March 1995.
Therefore, the one time schedular exemption is needed to allow this test interval to exceed the 40 - 1 10 month requirement and the three tests within the first 10-year service period requirement.
Attachment Page 2 of 3 ULNRC 2648 Data from past tests at'Callaway Plant and from NUliARC indicates that the majority of the leakage that is ;easured during tne CILRT is from the containment penetrations and not from the containment barrier itself.
Since the Type B and C tests (Local Leakage Rate Test or LLRT). program, which measures penetration and valve leakage, is not altered, assurance that containment integrity is maintained can also be verified by the performance of the LLRTs.
In addition to the LLRTs indication of containment
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integrity the data from the first and second CILRT illustrates
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that the "as-left" leakage rate.was well below the limit established for acceptance in 10 C FR 50, Appendix J and Technical Specifications.
The allowable leakage rate, L is 0.2 a
wt %/ day, however Appendix J and T/S requires that the leakage rate be less than 75% of this value to allow for deterioration in leakage paths between tests.
Therefore, the acceptance limit is 0.15 wt.%/ day and the "as-left" leakage rates for the first two CILRTs were 0.083 and 0.0505 wt.t/ day which is well below the acceptance limit.
It is our belief that the Appendix J requirement to perform a set of three CILRTs in a 10-year service period with the third one performed when the plant is shutdown for the 10-year plant inservice inspections, is based on the requirements of 10CFR50. 55a (g) (4).
This section of the regulations requires that inservice examinations of components and system pressure tests be conducted-in 10-year intervals.
At Callaway Plant the inservice volumetric, surface and visual examinations of components and system pressure tests are performed during refueling outages on an ongoing basis.
There is no plant shutdown for these 10-year j
plant inservice inspections.
Therefore, the requirements of 10CFR50. 55a (g) (4 ) and Section III.D.1.(a) for performing the third CILRT during plant shutdown at the end of a 10-year service period are unrelated as has been previously determined by the "RC for Callaway Plant (Reference 2).
Evaluation The purpose of the CILRT, to provide periodic verification by tests of the leak-tight integrity of the primary reactor containment, and systems and components which penetrate
. containment, will not be adversely impacted by this one-time exemption. 'The Local Leak Rate Test or LLRT program is not affected and past data has indicated the majority of the leakage measured during the CILRT is from containment penetrations and valves and'not from the containment barrier itself.
Therefore,
-assurance that containment integrity is maintained can also be verified by the performance of the LLRTs.
Given-the above discussions, and the fact that a revision to Appendix J is pending that would delete the 10-year interval.for performing three CILRTs and replace it with a requirement that any three consecutive test intervals ba 5 3.25 times 48 months, this exemption will not pose any undue risk to the health and satety of the public or involve a significant safety hazard.
Special circumstances, as provided in 10CFR50.12 (a) (2) (ii), are
Attachment i
Page 3 of 3 ULNRC-2648 present-justifying the Exemption from Appendix J.
- Namely, application of the regulation in'the particular circumstances is not necessary to achieve its underlying purpose, which is to ensure that accurate and conservative methods are used in
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-performing periodic containment leak rate tests at approximately-i equal intervals t.hroughout the lif e of the plant to assure that containment ~ integrity is being maintained.
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