ML20101S471
| ML20101S471 | |
| Person / Time | |
|---|---|
| Site: | Fermi |
| Issue date: | 01/26/1985 |
| From: | Jens W DETROIT EDISON CO. |
| To: | Youngblood B Office of Nuclear Reactor Regulation |
| References | |
| NE-85-0233, NE-85-233, NUDOCS 8502050421 | |
| Download: ML20101S471 (3) | |
Text
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Wayne H. Jens Vee Prestant N0 bear Operations Edison== orth Dixie Highway 6
January 26, 1985 NE-85-0233 Director of Nuclear Reactor Regulation Attention:
Mr.
B. J. Youngblood, Chief Licensing Branch No. 1 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Youngblood:
Reference:
(1)
Fermi 2 NRC Docket No. 50-341 (2)
Letter dated January 19, 1985, Request for Exemption to Appendix J
Subject:
Request for Exemption to Appendix J This letter is intended to provide more complete justi-fication for the request for exemption to 10CFR50, Appendix J originally submitted in Reference 2.
Reference 2 requested exemption from Paragraph III.D.2(b)(li), which i
states:
" Air locks opened during periods when containment integrity is not required by the plant's Technical Specifications shall be tested at the end of such periods at not less than P a-Whenever the plant is in Operational condition 4 or 5, containment integrity is not required.
Therefore, if an air lock is opened during either of these conditions the subject paragraph requires that an overall air lock leakage test be i
conducted prior to entry into Operational condition 3.
Such a test involves the following activities:
o Installing 14 tie downs to the interior air lock door (4-6 hours) o Pressurizing the air lock to P (1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />) a Waiting for the air lock volume to stabilize,and o
recording the leakage (3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />) o Depressurizing the air lock, removing and storing the tie downs below the air lock floor k
(3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />).
8502050421 850126 PDR ADOCK 05000341 1
A N
Mr. B. J. Youngblood January 26, 1985 NE-85-0233 Page 2 This test would require an average of 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />.
Often there are minor problems that require containment entry just prior s
to entering Operational Condition 3.
This would require an additional 14 hour1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> test or personnel would be required to l
remain inside containment to perform such activities until
)
entry is made into Operational Condition 3.
Paragraph III.D.2(b)(iii) of Appendix J allows the interior and exterior air lock door seals to be pressurized to P as a
a satisfactory method of assuring air lock integrity after being opened while in Cperational Conditions requiring containment integrity.
This test is much less time consuming (2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />).
Therefore, Detroit Edison requests an exemption from paragraph III.D.2(b)(ii) and instead intends to demonstrate air lock leak tight integrity prior to entering Operational Condition 3 by verifying acceptable leakage after pressur-izing the interior and exterior air lock door seals to not less than P If, however, maintenance has been performed a.
on the air lock since the last successful test performed pursuant to III.D.2(b)(i), an air lock leakage test will be performed.
Detroit Edison also requests that the draft Fermi 2 Technical Specifications be changed as indicated in to conform to the requested exemption.
I hereby certify that this proposed change to the Fermi 2 Technical Specifications as well as the changes requested in letters dated January 10 and January 22, 1985 respectively, accurately reflects the plant, the Final Safety Analysis Report and the staff's Safety Evaluation Reports in all material respects, except as necessitated by the above discussed change.
Should you have any further questions, please contact Mr. O. Keener Earle (313) 586-4211.
Sincerely, f
f cc:
Mr..P. M. Byron Mr. M. D. Lynch Mr. L. N. Olshan Document Control Desk, USNRC Washington, D. C.
20555
CONTAINMENT SYST. EMS SURVEILLANCE REQUIREMENTS 4
j Each primary containment air lock shall be[ifemonstrated OPERAB_Ll j 4.6.1.3 a.
Within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following each closing, except when the air lock is being used for multiple entries, then at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, by verifying seal leakage rate less than or equal to 5 scf per hour when the gap between the door seals is pressurized to Po, 56.5 psig.
--.) b.
Pa By conducting an overall air lock leakage test at P,, 56.5 psig, and by verifying that the overall air lock leakage rate is within its limit:
1.
Prior to initial fuel loading and at 6-month
- intervals thereafter, establishing PRIMARY CONTAINMENT INTEGRITY when the air Prior to,hi'o'p'e3ed during periods when containment integrity was.
2.
b lockx a"s sYch$guiredri9 rneinhene-L w hie.h eco t A aff ter The ka K Tic not re At least once per [esY 'o5y verYy[ng that only,Y."
3'*
s'slui Na dlME months one door in each c.
d.
air lock can be opened at a time.**
Pr.o r te estaLlishind PRIMhRY 60t4 tat KMENT s'
INTEGRtTy iG ehef am loc.k has barn opened d u ring PEMods wh6 n 8 0ntam mE nT LnEEGRITY uj 8 S McT RE utREd, ThL d e m e n sTonTio n S h e ll U Er l fg a S E d. t _ t e n]K ast v nn less het o r e.ct u f+l t o E-s e v PLR h o c R-W b tn thE top b ETu) E E.N. C h E. d o u-S6dJS
_iS _ PEES 5 0 r 2 E A to Pa s 5(o.5' es;c O n lE.s s.t hE a t s
_\\oc.k,s tested PoR.5o n nT to 4 6 t.3. C..A < e sTe a a.
l l
l l
l l
- The provisions of Specification 4.0.2 are not applicable.
- Except that the inner door need not be opened to verify interlock OPERABILITY when the primary containment is inerted, provided that the inner door inter-lock is tested within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after the primary containment has been deinerted.
l l
FERMI - UNIT 2 3/4 6-9
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