ML20246F528
| ML20246F528 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 07/05/1989 |
| From: | Shelton D TOLEDO EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 1680, TAC-M75392, NUDOCS 8907130292 | |
| Download: ML20246F528 (2) | |
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TOLEDO ~
EDISON A Centerer linergy Company
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DONALD C. SHELTON -
Vee Presdert-Nurker h
Docket Number 50-346 l'*dS 35
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-License' Number NPF '
~ Serial Number 1680 July 5,~1989
' United States Nuclear Regulatory Commission Document Contro1~ Desk-Washington, D.'C.
20555
' Subj ec t : Request for Exemption to 10CFR50 Appendix J to Allow Application of the Technical Specification Extension Allowance to Containment Air Lock Testing Gentlemen:
.10CFR50, Appendix J, Paragraph III.D.2(b)(i), requires that the containment air locks be tested at six month intervals.
Davis-Besse Nuclear Power Station
.(DBNPS) Technical' Specification (TS) Surveillance Requirement 4.6.1.3b also requires the' air locks to be tested every six months. Technical Specification 4.0.2 allows.the TS required testing interval for the air locks-to be extended by up to 25 percent of the inspection interval while limiting the total cumulative extension to 25 percent for three consecutive tests. The two test requirements can be met by the same surveillance test.
Since 10CFR50 Appendix J'does not provide'for extension of its six month interval, the TS extension allowance cannot be utilized in meeting the Paragraph III.D.2(b)(i) requirement.
The Basis for TS 4.0.2 states, "The tolerance values, taken either individually or consecutively over three test intervals, are sufficiently restrictive to ensure that the reliability associated with the surveillance activity is not significantly degraded beyond that obtained from the nominal specified interval." Therefore, Toledo Edison considers that there is no safety significance of the 1.5 month maximum extension for the six month 0
interval. The TS 4.0.2 extension provision of 25 percent is an important gn8 scheduling tool and is allowed for many other TS surveillance intervals of 080-both shorter and longer frequencies.
too A review of past Davis-Besse test records indicates that the personnel and w
emergency air locks have failed two surveillance tests due to leakage during 40 the period from plant startup in 1977 to the present. One failure occurred in
$8 January 1978 and the other in May 1988 and both failures involved leakage past 7
the hand wheel shaft seal of the personnel air lock inner door. No major failures of the airlocks have occurred.
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'$80 00li
. THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO, OHIO 43652 I
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W Dockot Numbir 50-346 l
~,
y esnsa Numbar NPF-3 N
Serial Number 1680 i
Page 2 Pursuant to 10CFR50.12, Toledo Edison requests an exemption fru.a 10CFR50 Appendix J.to allow the extension provisions of TS 4.0.2 to be utilized, when j
necessary, for scheduling of the air lock tests. Toledo Edison considers this
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request meets.the requirement of 10CFR50.12 in that the request would be allowed by law, vill not present an undue risk to the public health and safety, is consistent with the common defer.se and security, and is a special l
circumstance under 10CFR50.12(a)(2)(i) (application of the regulation
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conflicts with other requirements) and 10CFR50.12(a)(2)(ii) (application of i
the. regulation is not necessary to achieve the underlying purpose of the I
rule). Toledo Edison requests NRC approval of this exemption by December 31, 1989.
Should further information be. required, please contact Mr. R. V. Schrauder, Nuclear Licensing Manager, at (419) 249-2366.
Very truly yours, GBK/dlm cct P. M. Byron, DB-1 NRC Senior Resident Inspector A. B. Davis, Regional Administrator, NRC Region III T. V. Wambach, NRC/NRR DB-1 Senior Project Manager l
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