ML20141H356

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Exemption from App J to 10CFR50 Re Primary Reactor Containment Leakage Testing for Airlock Doors
ML20141H356
Person / Time
Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 01/08/1986
From: Bernero R
Office of Nuclear Reactor Regulation
To:
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
Shared Package
ML20141H346 List:
References
NUDOCS 8601130570
Download: ML20141H356 (4)


Text

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r 7590-01 UNITED STATES'0F AMERICA NUCLEAR' REGULATORY COMISSION In the Matter of CONSUMERS POWER COMPANY Docket No. 50-155 (BigRockPoint-Plant)

)

EXEMPTION I.

.The Consumers Power Company (the licensee) is the holder of Facility Operating License No. DPR-6 which authorizes the operation of the Big Rock Point Plant, located in Charlevoix County, Michigan. This license provides, among other things, that it is subject to all rules, regulations.

and Orders of the Commission now or hereafter in effect.

II.

10 CFR 50.54(o) requires that all licensees meet the requirements of

. Appendix J - Priinary Reactor Containment' Leakage Testing for Water-Cooled Power Reactors.Section III.D.2(b)(iii) of Appendix J requires that-airlocks opened during periods when containment integrity is required shall be tested for leakage within 3 days after each opening, or shall be tested L

every 3 days during periods of frequent openings. SectionIII.O.2(b)(1)of Appendix J requires that full pressure airlock leak tests be done every 6 months.

In lieu of these requirements, the licensee has proposed, by l

submittal dated September. 15, 1975, as supplemented by subnittals dated

' October 10, 1980'and February 2, 1984, to-(1) perform full pressure leakage 8601130570 86010e

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$ tests of airlocks every 6 months, and (2) replace airlock door seals periodically in accordance with manufacturer's recommendations.

Currently, the containment airlocks (equipment, personnel, and i

emergency) are leak tested every 6 months. Appendix J to 10 CFR Part 50 l

i requires that airlocks be leak tested within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after each use or every l

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> if the airlocks are used daily. Therefore, the explicit requirements of Appendix J to 10 CFR Part 50 are not met. The staff's November 23, 1982 Appendix J safety evaluation proposed reduced pressure leak tests within 72 hear 3 ufter each use or every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> during frequent use in addition to the 6-month tests as an acceptable airlock leak test schedule.

The licensee has concluded that frequent use of the personnel airlock is necessary for the safe operation of the plant; the personnel airlock is.used many times a day. Airlock testing is time consuming (requiring at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to obtain statistically significant data), even for a reduced pressure test, because the entire airlock must be pressurized. The airlocks are all of the single seal design, not the i

double seal design which allows testing by presst ; zing between the seals.

During testing of the personnel airlock, entry to containment is curtailed because the only available entrance is the emergency airlock. The emergency airlock is opened daily as a personnel safety measure to ensure operability. The equipment airlock is used infrequently.

Each of the airlocks is tested every 6 months, and each airlock is covered by a preventive maintenance program, including seal inspection and

-cleaning. Moreover, the as-found leakage observed during the 6-month tests has been quite low. The leak rates have averaged 3% to 5% (closer to 3%

r 7590-01

since 1974) of the maximum Technical Specifications leakage liriit. The requirement of additional tests, even reduced pressure tests, would (1) place a burden on plant operations and ( d provide no increase in safety based on the record of the 6-month leakage tests.

The NRC staff performed an evaluation of the Big Rock Point Plant containment airlock leak testing during the Integrated Assessment portion of the Systematic Evaluation Program. The staff's conclusion, which is documented in Section 4.20 of NUREG-0828 issued in May 1984, was that the licensee's proposed leakage testing program, including more frequent i

full pressure testing and periodic replacement of airlock door seals in accordance with the manufacturer's recommendations, would provide an acceptable alternative to strict compliance with the applicable Appendix J requirements. This conclusion is further supported by the past excellent performance of the airlock door seals at the facility. The alternative actions proposed by the licensee provides reasonable assurance that airlock leakage will not exceed acceptable levels. Therefore, granting tLe exemption does not affect the risk of facility accidents.

Thus, the staff concludes that an exemption from the requirements of Section III.D.2(b)(iii) of Appendix J to 10 CFR Part 50 should be granted.

III.

Accordingly, the Comission has determined that, pursuant to 10 CFR 50.12, an exemption is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public

. interest. Therefore, the Comission hereby grants an exemption from the requirements of Section III.O.2(b)(iii) of Appendix J to 10 CFR Part 50 i

that airlocks opened during periods when containment integrity is required

~ by :the facility's Technical Specifications shall be tested within 3 days

e 7590-01

>^ after being opened and for airlock doors opened more frequently than once every 3 days, the airlocks shall be tested at least once every 3 days during

-the period of frequent openings.

Pursuant to 10 CFR 51.32,.the Commission has determined that the issuance of this exemption will have no significant impact on the environment (November 5, 1985, 50 FR 45954).

This exemption is effective upon issuance.

Dated at Bethesda, Maryland, this 8th day of January 1986.

FOR THE NUCLEAR REGULATORY COMMISSION

=- -r Robert M. Bernero, Director Division of BWR Licensing Office of Nuclear Reactor Regulation s,-

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