ML20128N071

Forwards Request for Exemption from Requirements of 10CFR50.54(o) Re Containment Leak Rate Testing.Approval Requested by 930410 to Avoid Unnecessary Performance of Local Leak Rate Tests

ML20128N071
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	02/16/1993
From:	Cross J, Machon R PORTLAND GENERAL ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9302220477
Download: ML20128N071 (3)

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( ps y . Portland General Electric Company p%r,;J ni k James E. Cross Vice President and Chief Nuclear Officer February 16, 1993 Trojan Nuclear Plant Docket 50-344 License NPF-1 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washingt.on DC 20555

Dear Sirs:

Request for Exemption from Title 10 of the Code of Fedtral Regulations, Part 50.54(o) 110_ffiLL5MalLConne ntin g_Canlainmentle a Ulatele s tin g Portland General Electric Compa.4y (PGE) is requesting an exemption from the requirements of 10 CFR 50.54(o), requiring primary reactor containments for water-cooled power reactors to be subject to the requirements set forth in Appendix J for tests of the leak-tight integrity of the primary reactor containment, and systems and components which penetrate containment. On February 2, 1993, PGE certified to the Nuclear Regulatory Commission (NRC) '

that the reactor fuel had been permanently removed from the reactor vessel at Trojan and placed in the spent fuel pool. The basis for the requested exemption is submitted in the attachment to this letter.

PGE requests approval of the requested exemption by April 10, 1993 to avoid the unnecessary performance of local leak rate tests which are currently required to be performed by this date.

Sincerely,

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R. D..N chon for J. E. Cross At tactwent c: Mr. John B. Martin Regi nal Administrator, Region V U.S. Nuclear Regulatory Commission Mr. David Stewart-Smith State of Oregon Department of Energy Mr. Kenneth Johnsto-NRC Senior Resident Inspector Trojan Nuclear Plant 9302220477 930216 i ADOCK 05000344- 121 SW Salmon Street, Portland, OR 97204 PDR P PDR 503/464-8897

Trojan Nuclear Plant Document Control Desk Docket 50-344 February 16, 1993 e

License NPF-1 Attachment Page 1 of 2 REQUEST FOR EXEMPTION FROM TITLE 10 0F Tile CODE OF FEDERAL REGULATIONS, PART 50.54(o) 110_ CEIL 10.dMa)1 CONCEBRIR0_CDHIAIMiEHIlEAKJMIA.luiIIRQ Deacrip11on .nLExemplicalequeal 10 CFR 50.54(o) states, " Primary reactor containments for water cooled power reactors shall be subject to the requirements set forth in Appendix J to this part". The requirements of Appendix-J provide for preoperational and periodic verification by tests of the leak-tight integrity of the primary reactor containment, and systems and components which penetrate containment of water-cooled power reactors, and establish the acceptance criteria for such te_ats. As a result of the permanent cessation of the operation of the Trojan facility, compliance with this regulation would not serve the underlying purpose of the rule requiring contairment leak rate testing.

Enain_farlxemplisnJ1caucat The provisions of 10 CFR 50.12 allow specific exemptions from the requirements of 10 CFR 50 provided the exemptions are authorized by law, are consistent with the common defense and security, are accompaaled by special circumstances, and do not present an undue risk to the public health and safety. Portland General Electric Company (PGE) concludes that the activities sought to be conducted under this exemption request are clearly authorized by law, are consiste . with the common defense and security, and do not present an undue rien to the public health and safety. PGE believes that spacial circumstances exist with regard to the performance of containment leak rate testing. 10 CFR 50.12(a)(2)(ii) states, " Application of the regulation in the particular circumstaaces would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule . . ."

By letter d_ted January 27, 1993, PGE informed the Nuclear Pegulatory Commission (NRC) of PGE's decision permanently ceasing operations at the Trojan Nucleac Plant. Further, by letter dated February 2,1993. PGE informed the Commission that the Trojan teactor had l'een permanently shutdown and defueled, with the fuel placed in the spent fuel pool. <

The testing specified by Appendix J to 10 CFR 50 serves to assure that:

1. Leakage through the primary reactor containment and systems and components penetrating primary containment shall not exceed allowable lea)

• rate values as specified in the Technical Specifications 1 associated bases, and

2. Periodic surveillance of reactor containment penetratione and isolation valves is perforr:d so that proper maintenance and repairs are made during the service life of the containment, and systems and components penetrating primary containment.

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. Trojan Nuclear Plant Document Control Desk p bocket 50-344- february 16, 1993 License NPF-1 Attachment Page 2 of 2 Trojan Technical Specifications require periodic surveillance testing of the primary teactor containment and systems and components penetrating primary containment to ensure that the total containment leakage volume will not exceed the value assumed in the accident analyses at the peak accident pressure.

The reactor containment and associated systems are provided to catablish an essentially leak-tight barrier against the uncontrolled release of radioactivity to the environment aa a result of design basis accidents associated with reactor operations. Removal of the fuel from the containment eliminated the significant source of radioactivity potentially available for release ftov the containment and the primary source of energy f or creating a dif f erential preosure to cause leakage-across the containment barrier. PGE has concluded that there are no longer any credible design basis conditions that require the containment to perform as an essentially leak-tight barrier. Therefore, further

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periodic verification by tests of the leak-tight integrity of the primary reactor containment and systems anu components which penetrate containment would not serve the underlying purpose of the rule.

Concluelon Due to the cessation of operations of Trojan, ft:rther periodic verification by tests of the leak-tight integrfty of the primary reactor containment and systems and components which penetrate containment does not serve the underlying purpose of 10 CFR 50.54(o),

htential_EnYlennmentaL_ Impact Pursuant to the requirements of 10 CFR 50.12, PGE is requesting an exemption from the requirements of 10 CFR 50.54(o) for the Trojnn Nuclear Plant, The requested exemption is from periodic verificetion by tests of the leak-tight integrity of the primary reactor containment and systems and components which penetrate containment. As such, the exemption will not result in an increase in the licenscd power level or a change in Plant configuration. Furthermore, since the source of rrdionuclides which the containment was designed to retain was removed permanently, there is not an adverse change in the type or quantity of radioactive or non-radioactive effluents. Therefore, the proposed exemption does n.

involve a significant environmental impact.

LGD/bsh 7422W.0293