ML20236S956
| ML20236S956 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 11/20/1987 |
| From: | Shelton D TOLEDO EDISON CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 1443, NUDOCS 8711300204 | |
| Download: ML20236S956 (2) | |
Text
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TOLEDO
%mmEDISON
-l DONALO C. SHELTON 4
Vce Presdent-Nudear W91249-2399 Docket No. 50-346 License No. NPF-3 Serial No. 1443 November 20, 1987 1
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l United States Nuclear Regulatory Commission l
Document Control Desk Washington, D. C.
20555
Subject:
Request for. Exemption from 10CFR50, Appendix J, Section III.D.1(a) Regarding Type A Testing and 10-year Inservice Inspection Gentlemen:
1 Toledo Ediscn herewith' submits the attached request for exemption from the= requirements of 10CFR50, Appendix J, Section III.D.1(a) for the Davis-Besse Nuclear Power Station (DBNPS), Unit No. 1.
This exemption would allow'the third Type A (Containment Integrated Leak Rate Test) and the 10-year inservice inspections (required by 10CFR50.55a) to be uncoupled and performed'in separate, but consecutive, refueling outages.
Consistent with this exemption request, a License Amendment Request to revise Technical Specification 4.6.1.2a is being prepared for submittal to the Nuclear Regulatory Commission. Toledo Edison requests that this exemption be granted prior to power ascension to Mode 4 from the 1988 refueling outage in order that DBNPS, Unit No. 1 will not be in violation i
with the letter of 10CFR50, Appendix J.
Mode 4 entry from this outage is l
presently scheduled for August, 1988.
Very t u y yours.,
I QT DCS:bam i
Attachment j
cc:
A. B. Davis i
DB-1 NRC Resident Inspector I vl7 6
1 0
THE TOLEOO EOISON COMPANY EOISON PLAZA 300 MAOlGON AVENUE TOLEOO. OHIO 43652 J
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' ; Docket No. 50-346:
^ License'No. NPF-3' Serial 1No.' 1443'-
JAttachment Page 2
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-In accordance with 10CFR50.12(a)(2), the~ requested. exemption-meets the
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. criteria. of 10CFR50.12(a)(2)(ii) and 10 CFR-50.12(a)(2)(111), as i
. described in~the following:
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1)
In accordance.with:10CFR50'.12(a)(2)(ii), compliance with 10CFR50, Appendix.J.Section III.D.1(a) to perform a Type A test and the 10-year: inservice inspection (per 10CFR50.55(a) requirements) during the same outage does not serve the underlying purpose of the rule.
The Introduction.to 10CFR50, Appendix'J states "The purposes of the
- tests are to. assure that (a) leakage through the primary reactor containment and systems and; components < penetrating primary containment shall not exceed allowable leakage rate values as specified in the. technical specifications or associated bases...."
s The performance of the Type:A test during-the 1988 refueling outage.provides the necessary assurance of primary containment
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integrity at an interval which is consistent with the previous interval: performance of.the first two Type A. tests conducted during the first-10-year service period of DBNPS, Unit No. 1. The coupling
'of'the Type A test'to the 10-year inservice inspection does not enhance the purpose or: assurance of containment integrity above that which will'already have been demonstrated.
It is important to note this uncoupl1ng is recognized by the proposed revision to 10CFR50, Appendix'J.(51FR39538, October 29, 1986).
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-2)
In accordance with 10CFR50.12(a)(2)(iii), compliance with 10CFR50, Appendix J, Section III.D.1(2) would result in undue hardship or other costs that are significantly in excess of those contemplated when the regulation was adopted.
It appears that when the regulation was adopted, the end of the 10-year service period and
'the 10-year inservice inspection outage were contemplated as concurrent milestones. However, the unrelated' nature of these milestones within the meaning of Appendix J and-ASME Section XI would require DBNPS, Unit No. I'to perform Type A tests during
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consecutive outages (i.e., the 1988 and 1989 refueling outages) and would result in significant excess costs due to additional testing and potentially increased outage time. Unnecessary Type A testing during consecutive outages with its associated costs was not intended by the regulation when originally adopted. >
Based on the above, Toledo Edison requests the exemption from 10CFR50, Appendix J, Section III.D.1(a) requirements to perform a Type A test when the plant is shutdown for the 10-year inservice inspections be granted.
This exemption 10 consistent with the proposed revision to 10CFR50, Appendix J as cited above and is requested to be granted prior to
' plant ascension to Mode 4 following the 1988 refueling outage in order that DENPS, Unit No. I will not be in violation with the letter of 10CFR50, Appendix J.
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