ML20206J400
| ML20206J400 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 11/21/1988 |
| From: | Varga S Office of Nuclear Reactor Regulation |
| To: | VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| Shared Package | |
| ML20206J405 | List: |
| References | |
| NUDOCS 8811280180 | |
| Download: ML20206J400 (5) | |
Text
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7590-01 l
UNITED STATES OF AMERICA f
NUCLEAR REGULATORY COMMISSION i
in the Matter I
' VIRGINIA ELECTRIC AND POWER COMPANY Cocket No. 50 281 j
i (Surry Power Station, l
Unit 2)
(
EXEMPTION l
i 1.
1he Virginia Electric and Power Company (VEPCO, the licensee) is the holder j
of Onerating License No. OPR-37, which authorizes operation of Surry Power I
Station Unit 2.
The operating license provides, among other things, that the t
Surry Power Statioi Unit 2 is subject to all rules, regulations, and Orders of the Coomission now or hereafter in effect.
The facility consists of a pressurized water reactor at the licensee's site in Surry, Virginia.
i The Code of Federal Regulations,10 CFR 50.54(o), specifies that primary reactor containments for water-cooled power reactors shall comply with Appendix J, f
"Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors."
Section !!!.A.6(b) of Appendix J to 10 CFR Part 50 states the following:
l If two consecutive periodic Type A tests fail to meet the a plicable f
acceptance criteria in !!!.A.5'b), notwithstanding the peri dic retest i
a Type A test shall be performed at each plant i
schedule of !!!.D. ling or approxinately every 18 months, whictever shutdown for refue occurs first, until two consecutive Type A tests meet the acceptance criteria in !!!.A.5(b), af ter which time the retest schedule specified in III.D. may be resumed.
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8911280180 GS1121
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PDR ADOCK 05000281 p
PDC i
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p From 1983 through 1986, the licensee conducted three Type A tests at Surry Unit 2.
All of these tests wtre considered to be failures due to leakage penalty additions from Type C (local leakage rate testing of containment isola-tionvalves) testing.
In each case the leakage was associated with penetrations /
valves in systems that are normally filled with water and operating, under post-accident conditions, and/or the containment sump isolation valves. The licensee indicated that the containment sump isolation valves have been replaced and they are no longer a continuir.g source of containment leakage, and that the last three Type A tests have demonstrated that containment integri'y has not significantly degraded over the operating cycle. Therefore, the licensee requested a one-tirne exemption from the schedular rcquirements of paragraph !!!.A.6(b) so that the normal retest schedule can be resumed in accordance with Section !!!.D.
By letter dated August 12, 1968, as supplemented August 15 and August J1, 1988, the licensee requested a cr.e-time exemption fron 10 CFR part 50, I
Appendix J, Section !!!. A.6(b) so that the normal retest schedule of Apr endix J, Section !!!.D. can be resumed. Surry Unit 2 failed the "es found" Typs A tests that were conducted in 1933, 1985, and 1986, due to leakage rate additions from Type C testing.
In each case the leakage was' associated with the normal i
containment surp isolstion valves (TV-DA-100/200 A3B) and/or valves in systems that are normally filled with water and operating under post-accident conditions.
If these leakage additions had not been necessary, the plant would not have requiredanacceleratedtestscheduledelineatedinSection!!!,A.6(b).
In order to avoid addition of a leakage penalty and an accelerated test schedule, the licensee elected to
- N nstrate to the staff's satisfaction uat:
1.
the corrective acti n Len for the normal contaiorent surp 1 solation l
valves for Unit 2 has
,aminated the chronic leakage problem, and
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for the Surry 'Jnits 1 and 2, the design of the "water-filled" penetra-tions is such that it precludes leakage of containment atmosphere through the penetrations during an accident, thus making it unnecessary to edd the associated Type C leakage rates to Type A leakage rates.
The licensee stated that accomplishing these two objectives would justify the requested exemption.
The licensee addressed the first issue in its letter dated August 12, 1988.
The second issue was addressed in submitta
- lated February 29, 1988, and August 15, 1988. Section 6.2.2.2 of the Surry Updated Final Safety Analysis Re}. ort also contains pertinent information. The sta'f reviewed these submittals and concluded that the subject "water-filled" containment penetrations are sealed 4
with water to tha extent that they need not be vented or drained during Type A tests, and the associated Type C leakage rates need not be added to Type A leakage rate. The staff further concluded that the original leakage path of concern that caused the recent Type A "ac found" failures (the normal containment sump isola-tion valves) has been corrected since these valves no longer exhibit excessive leakage. The staff's detailed evaluation is provided in a Safety Evaluation dated November 21, 1988.
Therefore, on the basis of the licensee's corrective actions to reduce the "as found" containment leakage, the staff concludes that a return to the normal Type A test schedule of Section 111.0. of Appendix J to 10 CFR Part 50 is justified.
By letter dated August 12, 1988, the licensee also submitted information to identify the special circumstances for granting this exemption for Surry Unit 2 pursuant to 10 CFR 50.12. The licensee stated that the purpose of Type A testing is to measure and ensure that the leakage through the primary reactor containment l
e 4
does not exceed the maximum allowable leakage.
It also provides assurance that periodic surveillance, maintenance and repairs are n:ade to systems or components penetrating the containment. The licensee has replac.ed the valves which were a continuing source of containraent leakage. The licen56e also stated that it has met the intent of the regulations in establishing containment integrity, and maintaining that integrity over the operating cycle. Therefore, the licensee believes that this exemption should be granted pursuant to 10 CFR 50.12(a)(2)(ii) and (v), in that application of the regulation in this particular instance is not necessary to achieve the underlying purpose of the rule, which is to measure and ensure that leakage through the primary containment does not exceed the allowable leakage rate at any time during the operating cycle; and, that the exemption would provide only temporary relief from the applicable requirement and the licensee has made a good faith effort to comply with the regulation. This one-time exemption will enable Surry Unit 2 to resume the retest schedule specified in Section III.D. of 10 CFR Part 50, Appendix J and therefore, prevent unnecessary pressurization of the containment to design basis pressure. The staff agrees that the source of leakage which caused the prior failures has been carrected and an additional Type A test at this time is not required to achieve the undcrlying purpose of the rule.
IV.
Accordingly, the Connission has determined that, pursuant to 10 CFR 50.12(a)(1), this exemption is authorized by law, will not oresent an undue risk to the public health and safety, and is consistent with tim common defense and security. The Commission has further determined that special H rcumstances, as set forth m 10 CFR 50.12(a)(2)(ii) are present, justifyi:q the exe::'pt ien; namely that applicatior of the regulation in this particuDr circumstance is not
necessary to achieve the underlying purpose of the rule and the exemption is for e one-time relief only. Accordingly, the Commission h+veby creata e" ave =atiaa ta Section III.A.6(b) cf Appendix J to 10 CFR Part 50 to allow the licensee to resume the Type A retest schedule of Section III.D. of Appendix J for Surry Unit 2.
This exemption docs not apply if the next test is deemed a failure by the NRC acceptance criteria.
Such s failure would constitute two consecutive failure; and Section III.A.6(b) would again apply.
Pursuant to 10 CFR 51.32, the Commission has determined that the granting of this exemption will not have a significant effect on the quality of the human environment (53 FR 46724).
A copy of the licensee's request for exemption dated August 12, 1988, as supplemented August 15 and August 31, 1988, and previous information submitted by letter dated February 29, 1988, are 411able for public inspection at the Commission's Public Document Room, 2LO L Street, N.W., Washington, D.C., and at the Swem Library, College of William and Mary, Williamsburg, Virginia 23185.
Copies may be obtained upon written request to the U. S. Nuclear Regulatory Commission Washington, D.C., 20555, Attention:
Director, Division of Reactor Projects I/II.
This exemption is effective upon issuance.
FOR THE NUCLEAR REGULATORY COM!ilSSION
{
%/venA.Vaiga, Direct Division of Reactor Projects-1/II Office of Nuclear Reactor Regulation Dated at Rockville, Maryland this 21st day of November, 1988
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