ML20147A841

Forwards Application for Amend to License DPR-16,including Rev 1 to Tech Spec Change Request 126 Re Exemption from 10CFR50,App J,Section III.A.3 to Allow Utilization of mass-plot Calculational Method in Lieu of point-to-point

ML20147A841
Person / Time
Site:	Oyster Creek
Issue date:	02/19/1988
From:	Fiedler P GENERAL PUBLIC UTILITIES CORP.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20147A845	List: ML20147A841 ML20147A848 ML20147A864
References
NUDOCS 8803010366
Download: ML20147A841 (5)

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l GPU Nuclear Corporation

" Nuclear  : = = = 388 Forked River, New Jersey 08731-o388 609 971-4000 Writer's Direct Dial Number:

February 19, 1988 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555

Subject:

Oyster Creek Nuclear Generating Station Docket No. 50-219 Appendix J Leak Testing During an NRC inspection of the Containment Leak Rate Testing Program at the Oyster Creek Nuclear Generating Station (OCNGS), it was stated that Appendix J of 10CFR50 does not recognize the mass plot calculational method currently being utilized for this testing at the OCNGS. Enclosure 1 requests exemption from 10CFR50, Appendix J, Section III. A.3 to the extent that conformance to ANSI N45.4-1972 is required. Exemption is requested to allow utilizing the mass-plot calculational method as specified in ANSI /ANS 56.8-1981 in lieu of the point-to-point or total time method specified in ANSI N45.4-1972.

General Public Utilities Nuclear (GPUN) is also requesting changes to Appendix A of the OCNGS Operating License DPR-16. Enclosure 2 presents a revision of Technical Specification Change Request No.126 which was originally submitted by letter dated July 25, 1986. This revision includes additional information requested by the NRC staff by letter dated October 22, 1986 and during a telephone conference on March 19, 1987.

As discussed with the NRC staff, references to ANSI /ANS 56.8-1981 have been removed from the Technical Specification Change Request and Section 4.5.F has been clarified. Section 4.5.D.2 meets the requirements of 10CFR50, Appendix J which requires that failure of two (2) consecutive Type A tests requires performing the test at the next scheduled shutdown for refueling. As pertaining to drywell airlock testing, it was detennined by the NRC staff that pursuant to Technical Evaluation Report #TER-C5257-36 "Containment Leakage Rate Testing" dated May 21, 1981, an exemption is not required to allow reduced pressure testing of the drywell airlock at six month intervals.

As requested by letter dated October 22, 1986, GIUN has investigated the potential use of resilent "T" type seals in containment vent and purge valves at Oyster Creek. The subject valves at Oyster Creek do not contain seals of this type; as the seal surfaces are located in the valve body. It should be noted these four (4) valves passed the "as found" leakage test during the llR outage at the Oyster Creek station.

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Q During the above-referenced telecon on March 19, 1987, the NRC staff made further comments on the draft changes to Technical Specification Change Request No. 126. As a result, the Technical Specification Change Request has been revised to retain a test duration of at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the test frequency has been revised to conform to the Appendix J requirements.

Should you have any questions, please contact Mr. George W. Busch of the Licensing Department at (600)971-4909.

Very truly yours, P' e' Vice President and Director Oyster Creek PBF/GB/dmd (0102A) cc: Mr. William T. Russell, Administrator Region I U.S. Nuclear Regulatory Commission 475 Allendale Road l King of Prussia, PA 19406 Mr. Alexander W. Dromerick, Project Manager U.S. Nuclear Regulatory Commission Washington, DC

! Dr. Thomas E. Murley, Director l Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 l NRC Resident Inspector Oyster Creek Nuclear Generating Station Forked River, NJ 08731 l

4 ENCLOSURE 1 REQUEST FOR EXEMPTION In accordance with 10CFR 50.12, GPUN requests exemption from the requirements of 10CFR50, Appendix J.Section III. A.3. Currently, the calculational method utilized in conducting the Integrated Primary Containment Leak Rate Test (IPCLRT) is the mass plot approach as described in ANSI /ANS 56.8-1981. Since Section III.A.3 of 10CFR50, Appendix J references ANSI ' N45.4-1972, exemption is requested to allow utilization of the more accurate mass plot technique.

Special circumstances exist which support consideration-of the requested exemption. As delineated in 10CFR50.12, Section (a)(2)(ii), application of the regulation in this instance is not necessary to achieve the underlying purpose of the rule. Furthermore, pursuant to Section (a)(2)(vi) present circumstances pertaining to the IPCLRT calculational method were not considered when the regulation was adopted and it is in the public interest to grant the requested exemption.

The purpose of the rule is to assure containment integrity throughout the operating life of the nuclear power plant. At the time Appendix J to 10CFR50 was adopted, ANSI N45.4-1972 provided test calculational methods (point-to-point and total time) which were adequate and suitable for the sensitivity levels of the instrumentation in use at the time. Since then, i developments in the technology have resulted in superior methods for conducting leak rate testing. The mass plot method provides greater accuracy in determining leak rates and better serves the underlying purpose of the rule, t Furthermore, in recognizing the superiority of the mass plot method, the NRC staff has recommended that utilities in general and specifically the Oyster Creek Station develop and utilize the mass plot calculational method.

This circumstance was not considered when the regulation was adopted. The t IPCLRT at the Oyster Creek station has been conducted utilizing the mass plot calculational method with the knowledge and the recommendation of the Commission's staff since the promulgation of ANSI /ANS 56.8-1981.

During the period October 26-29, 1986, NRC Region I inspection personnel reviewed tne Oyster Creek IPCLRT program including the mass plot calculation i methodolegy. As a result of this review, the test procedure was revised to include an additional acceptance criterion. This criterion states that calculated leakage rate for the last 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> test be less than

.75 Lt (disregarding the 95% UCL). This criterion assures that a change in leak rate trend toward the end of the test will be identified.

The l additional acceptance criterion meets the intent of the extended ANSI method described in Draf t Regulatory Guide (Task MS-021-5) "Containment System Leakage Testing".

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ENCLOSURE 2 TECHNICAL SPECIFICATION CHANGE REQUEST 4

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF )

) DOCKET NO. 50-219 GPU NUCLEAR CORPORATION )

CERTIFICATE OF SERVICE This is to certify that a copy of Technical Specification Change Request No.126, Rev.1 for the Oyster Creek Nuclear Generating Station Technical Spec;fications, filed with the United States Nuclear Regulatory Commission on February 19 , 1988, has this day of February 19 , 1988, been served on the Mayor of Lacey Township, Ocean County, New Jersey by deposit in the United States mail, addressed as follows:

The Honorable Christopher Connors Mayor of Lacey Township 818 West Lacey Road Forked River, NJ 08731 l

By: h wN O Pet'er B. Fiedler Vice President and Director Oyster Creek i

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