ML20205Q088

Application to Amend CPPR-135 & CPPR-136,providing Partial Exemption from 10CFR50,App J Requirements Re Retesting Open Containment Airlocks When Containment Integrity Not Required by Tech Specs.Fee Paid

ML20205Q088
Person / Time
Site:	Seabrook
Issue date:	05/21/1986
From:	George Thomas PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:	Noonan V Office of Nuclear Reactor Regulation
References
SBN-1065, NUDOCS 8605280158
Download: ML20205Q088 (2)

Text

I Georga S. Thornos

, Veo Presiden: Nuctoct F7oduction Put2C Service of New Hampshire New Hampshiro Yankoo Division May 21, 1986 SBN-1065 T.F. B6.1.10 United States Nuclear Regulatory Commission Washington, DC 20555 Attention: Mr. Vincent S. Noonan, Project Director PWR Project Directorate No. 5 Attention: (a) Coastruction Permits CPPR-135 and CPPR-136, Docket Nos. 50-443 and 50-444

Subject:

Application for Amendment to Construction Permits, Exemption from 10CFR50, Appendix J III.D.2.(b)(ii)

Dear Sir:

Pursuant to the Atomic Energy Act of 1954, as amended, 10CFR50.12; 10CFR50.90 and otherwise according to law, Public Service Company of New Hampshire (PSNil), on behalf of itself and the other permittees named in the above referenced construction permits, as amended, hereby apply for an amendment to these Construction Permits.

The amendment, if granted would afford the Applicants partial exemotion from 10CFR50, Appendix J as it applies to the retesting of containment airlocks which had been opened during periods when contain-ment integrity is not required by Technical Specifications [10CFR50, Appendix J, Paragraph III.D.2.(b)(ii)]. Granting of the amendment would climinate the need to perform said test unless maintenance performed on the airlock hatch could have affected its sealing capability.

The Applicants submit that good cause exists for granting this amendment and exemption. The justification in support of this request is provided herewith in Attachment 1. Furthermore, this exemption is consistent with current regulatory practice and policy and is included as part of the Standard Technical Specifications. Accordingly, the Appitcants would anticipate that this exemption would be granted and incorporated into the Technient Specifications issued with our operating licenne (Low-Power).

8605 50 CW Ih PDRO PDR P.O. Box 300

• Seabrook,NH03874

• Telephone (603)474 9521 g., f/9 O

United States Nuclear Regulatory Commission Attention: Mr. Vincent S. Noonan Page 2 Pursuant to 10CFR50.30(e) and 10CFR170.12, a check for a filing fee of $150.00 is enclosed herewith.

Very truly yours,

~

r a Attachment cc Atomic Safety and Licensing Board Service List STATE OF NEW HAMPSHIRE Rockingham, as. May 21, 1986 Then personally appeared before me, the above-named Ceorge S. Thomas who, being duly sworn, did state that he his a Vice President of Public Service Company of New Hampshire, that he is duly authorized to execute and file the foregoing information in the name and on the behalf of Public Service Company of New Hampshire, and that the statements therein are true to the best of his knowledge and belief.

u bS$Mtuu Beverly c);. Silloway, %ary Public Hy Commission Expires: March 6, 1990 9

SBN-1065 ATTACHMENT 1 REQUEST FOR EXEMPTION TO 10CFR50. APPENDIX J The Applicants raquest a permanent exemption from the requirements specified in 10CFR50. Appendix J, Paragraph III.D.2.(b)(ii). The Applicants also request that the Staff specifically approve the applicable Technical Specification provision (see " BACKGROUND" below) as the requirement governing testing of air locks at Seabrok Station when " containment integrity is not req ui red" .

The exemption requested is authorized by 10CFR50.12 and there are no laws or regulations which would preclude the granting of the exemption.

The exemption will not present undue risk to the public health and safety, is consistent with the common defense and security, and is in the public interest. Furthermore, this exemption is consistent with current regulatory practice and policy and is included as part of the Standard Technical Specifications.

BACKGROUND Section III.D.2.(b) of 10CFR50, Appendix J, describes in detail three explicit air lock testing requirements for air locks penetrating primary reactor containment. In addition, the acceptance criteria for these air lock tests are required to be included in plant Technical Specifications.

In pertinent part, Technical Specification 4.6.1.3 provides that each containment air lock shall be demonstrated OPERABLE:

a. Within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following each closing, except when the air lock is being used for multiple entries, then at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, by verifying that the seal leakage is less than 0.01 La as determined by precision flow measure-ments when measured for at least 30 seconds within the volume between the seal at a constant pressure of 49.6 psig;

b. By conducting overall air lock leakage tests at not less than Pa , 49.6 psig, and verifying the overall air lock rate is within its limit!

1) At least once per 6 months, and

2) Prior to establishing CONTAINMENT INTEGRITY when mainte-ance has been performed on the air lock that could affect the air lock sealing capability.

The Technical Specification also requires, for items a and b.! above, that operability shall be demonstrated for periods when containment integrity is required (i.e., Hodes 1, 2, 3 and 4).

A comparison of Section III.D.2.(b) of 10CFR50, Appendix J with the above excerpted portion of Technical Specification 4.61.3 concludes that items a and b.! comply with the requirements of 10CFR50 appondix J Paragraph III.D.2.(b)(iii) and !!I.D.2.(b)(i) respectively. Ilowever, there is a difference between the requirements of item b.2 above and Appendix J, Paragraph 111.D.2.(h)(ii).

i

. SBN-1065 ATTACilMENT 1

. REQUEST FOR EXEMPTION TO 10CFR53, APPENDIX J Paragraph III.D.2.(b)(li) requires that "Airlocks opened during periods i when containment integrity f.s not required by the plant's Technical l Specifications shall be tested at the end of such periods at not less than Pa". Item b.2, however, only requires this test to be conducted when maintenance on the air lock could affect its sealing capability which, in essence, is the exemption requested.

PUBLIC HEALTH. ENVIRONMENTAL AND SAFETY JUSTIFICATION The exemption, if granted, will not adversely affect the environment or cause any undue risk to the public health and safety (45FR 2330).

During periods when containment integrity is required, the periodic 6 month and 3 day air lock Icakage tests mandated by Appendix J and reflected in plant Technical Specifications adequately assure that the air locks will satisfy leak rate requiremetus. These same tests provide adequate assurance that the air locks will satisfy leak rate requirements following the period when containment integrity has not been required, provided that no maintenance has been performed on an air lock which could affect its sealing capability. If such maintenance has been performed, the air lock will be leak tested prior to establishing containment integrity to satisfy leak rate requirements. l l

The above described containment air lock testing in conjuction with the other surveillance provisions of Technical Specification 4.6.1.3 provides l reasonabic assurance that no undue air lock Icakage will be caused by the granting of this exemption (i.e., no significant increase in the probability or quantity of air lock leakage). It follows therefore that there is no significant increase in the probability of higher ,

post-accident radiological doses or a significant increase in environ- J mental impact beyond that concluded without the exemption.

It can be concluded, therefore, that Technical Specification 4.6.1.3, which currently includes the requested exemption, provides equivalent protection to the exempted requirements and does not endanger life or property. Furthermore, the application of the regulation in the particular circumstances is not necessary to achieve the underlying purpose of the rule.

OTilER CONSIDERATIONS In addition to what has been stated above, we believe there are other considerations which warrant this exemption.

If strict compliance with the subject provision was required, then, a

cumbersome and lengthy test must be performed. The additional plant shutdown time required to conduct this test, over the life of the plant, in substantial since Appendix J requires the test be performed at the end of each period during which the air lock has been opened and the plant must remain shutdown while performing this test. Given j

! that existing Technical Specification requirements are adequate to -

j protect the public health and safety, the substantial finlancial impact on the Applicants, its shareholders and customers, which would '

result from increased outage time, is not warranted.

i 2-

SBN-1065 ATTACHMENT 1 REQUEST FOR EXEMPTION TO 10CFR50, APPENDIX J In addition to increasing outage time, the test would prohibit access into the containment during and following the test. Following the test, entry would be denied as a practical matter unless necessitated other-wise by circumstances until plant entry into Mode 4 where the " multiple entry" Technical Specification provision would govern. In Mode 4, access to containment would be allowed without requiring a plant shutdown to test the airlock. Therefore, given that there is adequate protection to the public health and safety (e.g., existing Techneial Specification) we do not believe the lack of flexibility in gaining access to the containment and the indirect financial impact associated with this access restriction is warranted.

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