ML20114B718
| ML20114B718 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 01/22/1985 |
| From: | Rybak B COMMONWEALTH EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| 9650N, NUDOCS 8501290447 | |
| Download: ML20114B718 (2) | |
Text
3 j,.
/^\\ Commonwealth Edison
[C') One First National Plaza Chicago, Ilknois O
(
Address Reply to: Post Office Box 767 x
_ Chicago. lilinois 60690 January 22, 1985
-Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
Quad Cities Station Unit 2 Request for Exemption to Appendix'J Integrated Leak Rate Test (Type A)
NRC Docket No. 50-254 References (a):
C. E. Norelius letter to Cordell Reed dated August 3, 1984.
(b):
D. L. Farrar letter to J. G. Keppler dated September 6, 1984.
Dear Mr. Denton:
Commonwealth Edison has been notified by Reference (a) that NRC Region III has reviewed Quad Cities Station Unit 2's Integrated Rate Test (Test A) of February 1984 and has found that Unit 2 has failed to meet the Type A test requirement per 10 CFR 50, Appendix J, Section III.A.6.(b).
Accordingly, we have been notified to conduct a Type A test during each refueling outage until two consecutive tests satisfy the Appendix J acceptance criteria.
Commonwealth Edison requests an exemption from this require-ment..The failure identified during the February 1984 test was due to a leaking flange on a 1/2 inch torus level instrument line.
The leak was found during the pressurization phrase of the Type A test.
The flange bolts were tightened without a Type B test to quantify the leakage, in violation of Appendix J,Section III. A.l.a.
The
' failure.to properly quantify the leakage is the sole reason the test was deemed a failure.
The violation of Section III.A.1.a was admitted to in Reference (b) and corrective action taken to prevent recurrence.
Procedure changes were made identifying the requirement that leaks must be measured prior to any repair.' Personnel training was also done and adherence to the revised procedure verified by Region III personnel on a subsequent Unit 1 Type A test.
Additionally, these torus instrument lines will be Type B tested at each subsequent refueling outage.
The instrument line on Unit 1 was tested with no detectable leakage in August, 1984.
p e
qa
e 4
H. R.
Denton January 22, 1985 Given the corrective. action taken to prevent recurrence, Commonwealth Edison believes that the additional penalty of more Type A tests is inappropriate.
The corrective actions taken specifically address the leakage problem that was the sole cause of the-Type A test to be judged a failure.
Those corrective actions provide an equivalent or better level of safety when compared to the alternative of more Type A-tests.
Commonwealth Edison believes that addressing the source of the leakage to be a more effective remedy than an increased frequency of Type A testing.
In our view, the Type A testing serves a different purpose than the Type B'and C tests; to provide periodic testing of the passive and structural elements of the containment boundary.
The inclusion of the instrument lines in the Type B test progam, the procedure revisions and retraining should prevent recurrence of this type of failure.
Therefore, we request an exemption from Appendix J on the requirement to perform successive Type A tests on Quad Cities Unit 2.
'Since the upcoming refueling outage on Unit 2 is scheduled to begin March 18, 1985, a prompt review of our exemption' request is requested.
Due to the extensive calibration and testing necessary prior to any Type A test, your response is requested by the start of the outage.
If there is anything you need to assist you in your review, please contact this office.
One signed original and forty (40) copies of the letter are enclosed for NRC review.
Very truly yours, lb-(_ -
B. Ryb Nuclear Lice ng Administrator 1m cc:
R. Bevan (NRR)
Region III Inspector - Quad Cities L. Reyes (Region III 9650N
_