ML20140C933

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Forwards Draft Ack Ltr & Draft Notice of Receipt of Petition to Assist NRR in Responding to Citizens Against Nuclear Power 840605 Petition for Emergency Action Re Integrated Leak Rate Testing
ML20140C933
Person / Time
Site: Zion File:ZionSolutions icon.png
Issue date: 06/20/1984
From: Stephen Burns
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To: Harold Denton
Office of Nuclear Reactor Regulation
Shared Package
ML20140C940 List:
References
FOIA-85-136 NUDOCS 8407020233
Download: ML20140C933 (2)
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DRM lFILEl Vg MEMORANDUM FOR: Harold R. Denton, Director Office of Nuclear Reactor Regulation .

FROM: Stephen G. Burns, Acting Director Regional Operations and Enforcement Division Office of the Executive Legal Director

SUBJECT:

PETITION OF CITIZENS AGAINST NUCLEAR POWER FOR EMERGENCY RELIEF RE INTEGRATED LEAK RATE TESTING AT ZION NUCLEAR UNIT 10F THE C0tiMONWEALTH EDISON C0t1PANY By a Petition For Emergency Relief dated June 5,1984. Edward H. Gogol, on behalf of Citizens Against Nuclear Power (Petitioner), requested that emergency action be taken.with respect to integrated leak rate testing -

of the Zion Nuclear Unit No.1 of the Commonwealth Edison Company (Ceco). '-

The Petition alleges that the containment leak rate test perfonned on Zion i

Nuclear Unit No. I during March 1981 was scientifically invalid, and was

  • not performed in accordance with ANSI N.45.4-1972, a standard of the American Nuclear Society specified in the Comission's regulations governing the area of containment leak rate testing, specifically 10 CFR Part 50, Appendix J. Support for these allegations is allegedly contained in the Affidavit of Dr. Zinovy Reytblatt attached to the Petition.

Relief requested by the Petitioner includes immediate action by the NRC to remove the threat posed by the alleged noncompliance at the Zion Nuclear Unit Nn.1, including e satisfactory containment leak rate test performed

under NRC supervision. Petitioner also requests that all information 7

associated with such a test be provided to the Petitioner on a timely basis.

In the alternative, Petitioner requests that the Zion Nuclear Unit No.1 operating license be suspended.

A response by your office appears to be appropriate as the Petition addresses licensing issues within the province of NRR. It should be noted that 11r. Gogol has previously petitioned the Cormiission to remedy alleged inadequacies in the area of containment leak rate testing associated with all U.S. nuclear power reactors with special emphasis on certain units of CECO.

However, the Zion Unit was not specifically identified in.the earlier petitions.

You issued a decision with respect to these petitions on March 16,1984,1/ and the Comission declined to review that decision.

1/ Comonwealth Edison Co. (LaSalle County Station, Units 1 and 2) and All Light-Water Reactors, DD-84-6,19 NRC (llarch 16,1984).

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t As the riresent Petition seeks . emergency relief, a description of -the imediate ac.tions taken by the agency or an articulation of why such actions need not be taken should be set out in the letter acknowledging receip~t of the Petition. liy staff will work with your staff to develop an appropriate re'sponse. Enclosed for your use are: ,

1. A draft acknowledgment letter which will require substantive input from your staff '
2. A draft notice of receipt of the Petition under 10 CFR 2.206 for publication in the Federal Register and
3. The original Petition submitted by Citizens Against fluclear Power Should you determine, following review of this Petition, that additional information from the licensee regarding the subject of the request would be useful to you in the preparation of a Director's Decision, such additional information may be solicited from the licensee by utilizing 10 CFR 50.54(f) and Section 182 of the Atomic Energy Act. .

Please provide us with copies of all documents related to the Petition.

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Also, please place our office on concurrence for all correspondence initiated by the staff and related to this Petition, bR Stephe G. Burns Acting Director Regional Operations and Enforcement -

Division Office of the Executive Legal Director

Enclosures:

as stated cc: (w/ encl.)

R. DeYoung, IE E. Christenbury, OELD JfJ. Keppler, Reg. III D. Berson, Reg. III S. Varga,tiRR J. Norris, NRR .

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Comm:nwe:lth Edison -

- One first National Plaza. Chicago, Illinois f Address Reply to Post Othee Box 767 sg Chicago. Ilknois 60690 -

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. July 27, 1984 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Zion Station Unit 1 Conduct of Proposed Integrated Leak Rate Test NRC Docket No. 50-295

Dear Mr. Keppler:

In accordance with the July 24, 1984 teleconference between i' Messrs. Guldemand and Maura (NRC Region III), Messrs. Norris, Huang and Shapaker (NRC Bethesda) and Commonwealth Edison Company, this summarizes the conduct of the Zion Unit 1 leak test, if that test is necessary. The teleconference was supplemented by a . telephone call between Commonwealth Edison and Mr. Guldemand on July 25.

The Unit 1 integrated leak rate test will be a 25 psig test in accordance with Zion technical specifications. Test duration will be a minimum of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and conducted in accordance with the mass point method. At the conclusion of the Type A test an imposed leakage test shall be performed to verify accuracy of instrumentation to measure leakage. The imposed test will be acceptable if measured leakage is within 0.25 Lt.

Zion Station will supplement its normal instrument checkout with an integrated system check. This check is to be performed after instruments are hung but prior to commencing containment pressurization for a sufficient period of time to ensure proper instrumentation and data collection system operation.

The NRC leak rate inspector, Mr. Maura, will make a containment inspection to verify adequacy of instrument locations placed in accordance with engineered containment modeling.

l The test will be performed in a manner which will permit

, characterizing the as found and as lef t containment conditions. If l { the Type A test is within criteria, no adjustments will be made l

until af ter the test at which time any adjustments would be made based on an assessment of Type B or C local leak test results. If

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.. a-while the test is being conducted leakage in excess of icceptance criteria is discovered, an attempt will be made to quan.tify the leakage before isolation. If the leakage is unisolables an estimate oC leak rate contribution will be made, repairs will be performed, add the Type A test restarted without having to depressurize.

Repairs on isolable leaks will be performed after the Type A test.

The signficant events log will clearly state the start and termination times of both the Type A and imposed tests. If there is a need to reinitialize either test, the reason will be clearly stated at the time of reinitialization. Zion will verify stable conditions are reestablished before starting the test.

The test lineup for the penetration pressurization (PP) and isolation valves seal water system (IVSW) will be as follows. The PP system will be depressurized and vented. The IVSW system will be depressurized at the start of the test, but may be utilized if .

I required. If IVSW is used, the amount of water will be quantified and evaluated with regard to the results of the test. While the NRC representatives and Commonwealth Edison recognize the preference for not using IVSW, it was agreed by both parties that its use would not invalidate the test. -

Zion Station explained the status 4 f 'the air locks during the test. At the start of test the inner' door on both air locks

.will be closed and outer doortopen. If excessive leakage exists, the outer door will be Closed and the air lock volime will be equalized in pressute with the containment. Maintenance of the doors as described abhve is conservative with regard to containment leak testing and as doch is acceptable as agreed to tiy the NRC.

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