ML20198D323

Exemption from Requirements of 10CFR50,Appendix J,Section III.d.2.(b)(ii) Re Containment Air Lock Pressure Test

ML20198D323
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	05/07/1992
From:	Boger B Office of Nuclear Reactor Regulation
To:	PORTLAND GENERAL ELECTRIC CO.
Shared Package
ML20198D321	List: ML20198D319 ML20198D323
References
NUDOCS 9205200122
Download: ML20198D323 (5)

Text

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O.

UNITED STATES OF AMERl[A NUCLEAR REGULA7 AY COMMIS$10N in the matter of PORTLAND GENERAL ELECTRIC COMPANY, Docket Nos. 50-344 ET AL.

(Trojan Nuclear Plant) )

fXEMPTION 1.

Portland General Electric Company, et al. (PGE or the licensee) is the holder of Facility Operating License No. NPF-1, which authorizes operation of the Trojan Nuclear Plant. The license provides, among other things, < hat the licensee is subject to all rules, regulations and orders of the Commission now or hereafter in effect.

The facility consists of a pressurized water reactor at the licensee's site located in Columbia County, Oregon, on the Columbia River.

1.1 Title 10 of the Code of Federal Regulations, Part 50 (10 CFR Part 50),

" Domestic Licensing of Production and Utilization Facilities," provides specific leakage testing requirements in Appendix J, " Primary Reactor Containment Leakage Testing for Water-Coq 1ed Power Reactors." One requirement of 10 CFR Ptrt 50, Appendix J, is found in paragraph Ill.D.2.(b)(ii) which specifically states, " Air la-ks opened during periods when containment integrity is not rer.

• x !9 .ie plant's Technical Specifications shall be i

L tested at the end of such periods at not less than P,."

L l 9205200122 920507 DR ADDCKOSOOg4l

• all.

By letter dated April 1, 1992, Portland General Electric company, et al., requested a permanent, partial exemption from Title 10 of the Code af Federal Regulations, Part 50, Appendix J, paragraph III.D.2.(b)(ii). The requested exemption would allow the performance of a reduced pressure test at not less than 10 psig (rather than at P, of 60 psig) as is done for periods when containment integrity is required, provided no maintenance or modifiestions that could affect sealing capability was performed on the air lock during the period.

Whenever the plant is in cold shutdown (mode 5) or refueling (mode 6),

containment integrity is not required. However, if an air lock is opened during modes 5 and 6, paragraph Ill.D.2(b)(ii) of 10 CFR Part 50, Appendix J requires that an overall air lock leakage test at r .t less than P, be conducted before plant heatup and startup (i.e., entering mode 4). The existing air lock doors are so designed that a full-pressure (i.e., P, of 60 psig) test of an entire air lock can only be performed after " strong backs" (structural bracing) have been installed on the inner door. Stro.:9 backs are needed because the pressure exerted on the inner door during the test is in a -

direction opposite to that of the accident pressure direction. Installing strong backs, performing the test, and removing the strong backs requires several hours, during which access through the air lock is prohibited.

When no maintenance has been performed on the air lock that could affect its senling capability, and the air lock doors have been close. in accordance l with the licensee's procedure, and the periodic 6-month test e+ P, required by paragraph !!!.D.2(b)(i) of 10 CFR Part 50, Appendix J has be e erformed on-

-a

schedule, there is no reason to expect the air lock to leak excessively just because it has been opened in a shutdown or refueling mode. Performing the door sea'. leak test of paragraph Ill.D.2(b)(iii) of 10 CFR Part 50, Appendix J is sufficient, in this case, to demonstrate the continuing integrity of the air lock.

The staff concludes that the licensee's proposed approach of substituting the seal leakage test of paragraph Ill.D.2(b)(iii) for the full pressure test of paragraph Ill.D.2(b)(ii) of 10 CFR Part 50, Appendix J is acceptable when no maintenance that could affect sealing capability has been t

performed on an air lock. Whenevar maintenance that could affect sealing capability has been performed on an air lock, the requirements of paragraph Ill.D.2(b)(ii) of 10 CFR Part 50, Appendix J must still be met by the licensee.

Pursuant to 10 CFR Section 50.12(a), "The Commission may, upon application by any interested person or upon its own initiative, grant exemptions from the requirements of the regulations of this part, which are -

(1) Authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security. (2) The Commission will not consider granting an exemption unless special c.ircumstances are present. Special circumstances are present whenever ....

(ii) Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the

. underlying purpo:,e of the rule; or (iii) Compliance would result in undue hardship or other costs that are significar.tly in excess of those contemplated when the regulation was adopted, or that are significantly in excess of those

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incurred by others similarly situated...."

4 The special circumstances for granting this exemption pursuant to 10 CFR Part 50.12 have also been identified. The purpose of Appendix J to 10 CFR .

1 Part 50 is to ensure that containment leaktight integrity can be verifie6 periodically throughuut service lifetime so as to maintain containment leakage within the limits specified in the f acility Technical Specifications. The l i

proposed alternative test method is sufficient to achieve this underlying purpose in that it provides adequate assurance of continued leaktight integrity of the air lock. In addition, at the time this section of Appendix J was revised in 1980, the staff did not contemplate the undue hardship and cost that would result from the requirement to perform a time-consuming full-prersure test before starting up from even the shortest cold shutdown during which the air lock had been used for containment entry. Because of this, the staff has already granted this same exemption to numerous plants and intends to revise Appendix J to alleviate the need for further similar exemptions.

Consequently, the special circumstances described by 10 CFR Section 50.12(a)(2)(ii) and (iii) exist in that application of the regulation in these particular circumstances is not necessary to achieve the underlying purpose of the rule because the licensee has proposed an acceptable alternative test method that accomplishes the intent of the regulation. Compliance would result _in undue hardship that would be significantly in excess of that incurred by others similarly situated (plant startup would be delayed and unnecessary personnel radiation exposures would be incurred while an overall air lock leakage test was performed at full pressure).

o' Therefore, a permanent, partial exemption from 10 CFR Part 50, Appendix J, paragraph !!!.D.2(b)(ii) is justified and acceptable.

IV.

Accordingly, the Commission has determined, pursuant to 10 CFR

-50.12(a)(1),-that an exemption as described in Section 111 above is authorized by law, will not piesent an undue risk to the public health and safety, and is consistent with the common defense and security. The Commission has determined, pursuant to 10 CFR 50.12(a)(2) that special circumstances exist, as noted in Section 111 above. Therefore, the Commission hereby grants

-Portland General Electric Company, et al., a permanent, partial exemption from the requirements of 10 CFR Part 50, Appendic J, paragraph Ill.D.2(b)(ii).

Pursuant to 10 CFR 51.32, the Commission has determined that the granting of this exemption will not have a significant impact on the quality of the human environment (57 FR 19445).

This exemption is effective upon issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/M Bruce A. Boger, Director Division of Reactor Projects Ill/IV/V Office of Nuclear Reactor Regulation l' Dated at Rockville, Maryland this 7th day of May 1992. '

l

FY May 7, 19P2 DE TR10VT10]i:

Docket File NRC & Local PDRs PDV Reading file T. Murley/F. Miraglia, 12G18 J. Partlow, 12G18 C. Rossi, llE4 J. Lieberman, 7H5 B. Boger M. Virgilio T. Quay D. foster R. Assa L. Kokajko C. McCracken, 8023 OGC, 15B18 E. Jordan, MNBB3701 G. Hill, (4) PI-37 ACRS (10), P315 OPA, 2G5 0C/LFMB, MNBB4503 PDV Plant file S. Shankman, EDO 17G21 RZinnerman, RV