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| * e e VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 10 CFR 50 W. L. STEWART VICE PRESIDENT NUCLEAR OPERATIONS March 1, 1988 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Gentlemen: | | * e e 10 CFR 50 VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 W. L. STEWART VICE PRESIDENT March 1, 1988 NUCLEAR OPERATIONS U.S. Nuclear Regulatory Commission Serial No .. 88-005 Attn: Document Control Desk NO/ETS:vlh Washington, D. C. 20555 Docket Nos. 50-280 50-281 License Nos. DPR-32 DPR-37 Gentlemen: |
| VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS I AND 2 10 CFR 50, APPENDIX J EXEMPTION REQUEST Serial No .. NO/ETS:vlh Docket Nos. License Nos. 88-005 50-280 50-281 DPR-32 DPR-37 Pursuant to 10 CFR 50.12, Virginia Electric and Power Company requests an exemption from 10 CFR 50, Appendix J, Paragraph III.A.3, which requires that Type A (Containment Integrated Leak Rate) tests be performed in accordance with ANSI N45.4-1972, "Leakage Rate Testing of Containment Structures for Nuclear Reactors." Since the issuance of ANSI N45.4-1972, a more accurate method of determining containment leakage rates, the mass point method, was developed as described in ANSI 56.8-1981, "Containment System Leakage Testing Requirements." Therefore, Virginia Electric and Powet Company is requesting exemption to a 11 ow use of the mass point method for ca lcul at i ng containment leakage rates. Based on the justification provided in Attachment 1, we conclude that the exemption from the requirements of Appendix J, Paragraph III.A.3 is justified pursuant to 10 CFR 50.12(a)(l) and 10 CFR 50.12(a)(2)(ii) in that it is authorized by law; will not present undue risk to public health and safety, and is consistent with the common defense and security. | | VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS I AND 2 10 CFR 50, APPENDIX J EXEMPTION REQUEST Pursuant to 10 CFR 50.12, Virginia Electric and Power Company requests an exemption from 10 CFR 50, Appendix J, Paragraph III.A.3, which requires that Type A (Containment Integrated Leak Rate) tests be performed in accordance with ANSI N45.4-1972, "Leakage Rate Testing of Containment Structures for Nuclear Reactors." Since the issuance of ANSI N45.4-1972, a more accurate method of determining containment leakage rates, the mass point method, was developed as described in ANSI 56.8-1981, "Containment System Leakage Testing Requirements." Therefore, Virginia Electric and Powet Company is requesting exemption to a11 ow use of the mass point method for ca lcul at i ng containment leakage rates. |
| Additionally, special circumstances are present in this case in that application of the regulation is not necessary to achieve the underlying purpose of the rule. The mass point method will satisfy the accuracy requirements of 10 CFR 50, Appendix J, Paragraph III.A.3 for Type A tests. In addition, a change to our Technical Specifications is r~quired in order to maintain consistency between Appendix J, our exemption request and the Technical Specifications. | | Based on the justification provided in Attachment 1, we conclude that the exemption from the requirements of Appendix J, Paragraph III.A.3 is justified pursuant to 10 CFR 50.12(a)(l) and 10 CFR 50.12(a)(2)(ii) in that it is authorized by law; will not present undue risk to public health and safety, and is consistent with the common defense and security. Additionally, special circumstances are present in this case in that application of the regulation is not necessary to achieve the underlying purpose of the rule. The mass point method will satisfy the accuracy requirements of 10 CFR 50, Appendix J, Paragraph III.A.3 for Type A tests. |
| The proposed changes to Technical Specification are contained in Attachment 2 and the discussion of the proposed changes is contained in Attachment | | In addition, a change to our Technical Specifications is r~quired in order to maintain consistency between Appendix J, our exemption request and the Technical Specifications. The proposed changes to Technical Specification are contained in Attachment 2 and the discussion of the proposed changes is contained in Attachment 3. |
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| 3080179 980301 .. ,,, .~**J r. . 880 *A*nocu . 05000280 * :: .: :. \ | | : r. . 880 3080179 980301 . . ,,, |
| * PDR * * *"' * -* P-DR ' . p e The exemption request and proposed Technical Specification change has been reviewed and approved by the Station Nuclear Safety and Operating Committee and the Safety Evaluation and Control Staff. It has been determined that the exemption request and Technical Specification change do not pose an unreviewed safety question as defined by 10 CFR 50.59 nor does it pose a significant safety hazards consideration as defined by 10 CFR 50.92. In accordance with 10 CFR 170 an application fee of $150 is enclosed. | | *A*nocu . 05000280 * :: .: :. |
| If you have any questions or need additional information to process this request please contact us. Very truly yours, DL~~:& W. L. Stewart Attachments | | .~* J |
| | * PDR * * *"' * - |
| | * P-DR |
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| | e The exemption request and proposed Technical Specification change has been reviewed and approved by the Station Nuclear Safety and Operating Committee and the Safety Evaluation and Control Staff. It has been determined that the exemption request and Technical Specification change do not pose an unreviewed safety question as defined by 10 CFR 50.59 nor does it pose a significant safety hazards consideration as defined by 10 CFR 50.92. |
| | In accordance with 10 CFR 170 an application fee of $150 is enclosed. If you have any questions or need additional information to process this request please contact us. |
| | Very truly yours, DL~~:& |
| | W. L. Stewart Attachments |
| : 1) Justification of Exemption | | : 1) Justification of Exemption |
| : 2) Proposed Technical Specification Change 3) Discussion of Proposed Changes 4) Application Fee cc: U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N. W. Suite 2900 Atlanta, Georgia 30323 Mr. W. E. Holland NRC Senior Resident Inspector Surry Power Station Mr. Charles Price Department of Health 109 Governor Street | | : 2) Proposed Technical Specification Change |
| * Richmond, Virginia 23219 Mr. Chandu P. Patel NRC Surry Project Manager Project Directorate 11-2 Division of Reactor Projects -1/11 e COMMONWEALTH OF VIRGINIA) ) CITY OF RICHMOND ) | | : 3) Discussion of Proposed Changes |
| * The foregoing document was acknowledged before me, in and for the City and Commonwealth aforesaid, today by W. L. Stewart who is Vice President
| | : 4) Application Fee cc: U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N. W. |
| -Nuclear Operations, of Virginia Electric and Power Company. He is duly authorized to execute and file the aforegoing document in behalf of that Company, and the statements in the document are true to the best of his knowledge and belief. Acknowledged before me this / 9::_T day of cll1,{llLC/tJ , 19 Q.S_. My Commission expires: ~Ir~ Z5, 19'7l>, &h* X.i!ML Notary Public --(SEAL) *-,. / -.:::-"' | | Suite 2900 Atlanta, Georgia 30323 Mr. W. E. Holland NRC Senior Resident Inspector Surry Power Station Mr. Charles Price Department of Health 109 Governor Street |
| e ATIACHMENT 1 JUSTIFICATION OF EXEMPTION BACKGROUND e e In 1973, 10 CFR 50 Appendix J was issued to establish requirements for Primary Reactor Containment Leakage Testing. Appendix J incorporated by reference ANSI N45.4-1972, "Leakage Rate Testing of Containment Structures for Nuclear Reactors." The Standard requires that containment leakage calculations be performed using either the point-to-point method or the total time method. The total time method was used most by the nuclear industry until about 1976. As noted in ANSI N45.4, the point-to-point method is suited to uninsulated containments where atmospheric stability is affected by outside diurnal change, while the total time method is appropriate for insulated containments that are relatively unaffected by diurnal changes. In 1976, an article (reference: "Containment Leak Rate Testing: Why the Mass-Point Analysis Method is Preferred," Power Engineering, February 1976) was written which compared the results of test analyses that were performed using point-to-point, total time, and mass-point techniques. | | * Richmond, Virginia 23219 Mr. Chandu P. Patel NRC Surry Project Manager Project Directorate 11-2 Division of Reactor Projects - 1/11 |
| A revision to the Standard (ref.: ANSI/ANS 56.8-1981, "Containment System Leakage Testing") . specifies the use of mass-point. | | |
| The draft revision to Appendix J incorporates the new standard ANSI/ANS 56.8-1981. | | e |
| JUSTIFICATION Virginia Electric and Power Company believes that this exemption should be granted pursuant to 10 CFR 50.12(a)(2)(ii); | | * COMMONWEALTH OF VIRGINIA) |
| i.e., application of the regulation in the particular circumstances is not necessary to achieve the underlying purpose of the rule, ~hich is to provide an accurate and conservative test of containment integrity. | | ) |
| Mass-point is a newer and more accurate method of ca lcul at i ng containment leakage. The total time method cal cul ates a series of leakage rates based upon air mass differences between an initial data point and each individu~l data point thereafter. | | CITY OF RICHMOND ) |
| The adequacy of the method is extremely sensitive to the accuracy of that initial data point. If, due to any reason (su*ch as instrument error, lack of temperature equilibrium, ingassing or outgassing) the initial data point is not accurate, the results of the test will be affected. | | The foregoing document was acknowledged before me, in and for the City and Commonwealth aforesaid, today by W. L. Stewart who is Vice President - Nuclear Operations, of Virginia Electric and Power Company. He is duly authorized to execute and file the aforegoing document in behalf of that Company, and the statements in the document are true to the best of his knowledge and belief. |
| Even if the data point is accurate, during the early stages of the test the leakage varies with time; as a result the initial value and therefore the calculated leak rate become time dependent. | | Acknowledged before me this / 9::_T day of cll1,{llLC/tJ , 19Q.S_. |
| In the mass-point method, the mass of air in containment is calculated and plotted as a function of time. The slope of the linear least squares fit to the data is the leakage. Using the total time method, the calculation of leakage rates as a function of time required creates the situation where increasing the amount of data . ava i 1 ab 1 e causes the results to become more erratic and the 95% Confidence Interval to become wider. Using the total time method, the 95% confidence interval may range from one-half to twice the measured leak rate. In the case of mass-point method, the 95% confidence interval is between 5% and 20% of the measured leak rate. | | My Commission expires: ~ I r ~ Z5, 19'7l>, |
| | &h* X.i!ML Notary Public |
| | -- |
| | (SEAL) |
| | *-,. / - .:::- |
| | "' |
| | |
| | e ATIACHMENT 1 JUSTIFICATION OF EXEMPTION |
| | |
| | BACKGROUND e e In 1973, 10 CFR 50 Appendix J was issued to establish requirements for Primary Reactor Containment Leakage Testing. Appendix J incorporated by reference ANSI N45.4-1972, "Leakage Rate Testing of Containment Structures for Nuclear Reactors." The Standard requires that containment leakage calculations be performed using either the point-to-point method or the total time method. |
| | The total time method was used most by the nuclear industry until about 1976. |
| | As noted in ANSI N45.4, the point-to-point method is suited to uninsulated containments where atmospheric stability is affected by outside diurnal change, while the total time method is appropriate for insulated containments that are relatively unaffected by diurnal changes. In 1976, an article (reference: "Containment Leak Rate Testing: Why the Mass-Point Analysis Method is Preferred," Power Engineering, February 1976) was written which compared the results of test analyses that were performed using point-to-point, total time, and mass-point techniques. A revision to the Standard (ref.: ANSI/ANS 56.8-1981, "Containment System Leakage Testing") |
| | . specifies the use of mass-point. The draft revision to Appendix J incorporates the new standard ANSI/ANS 56.8-1981. |
| | JUSTIFICATION Virginia Electric and Power Company believes that this exemption should be granted pursuant to 10 CFR 50.12(a)(2)(ii); i.e., application of the regulation in the particular circumstances is not necessary to achieve the underlying purpose of the rule, ~hich is to provide an accurate and conservative test of containment integrity. |
| | Mass-point is a newer and more accurate method of ca lcul at i ng containment leakage. The total time method cal cul ates a series of leakage rates based upon air mass differences between an initial data point and each individu~l data point thereafter. The adequacy of the method is extremely sensitive to the accuracy of that initial data point. If, due to any reason (su*ch as instrument error, lack of temperature equilibrium, ingassing or outgassing) the initial data point is not accurate, the results of the test will be affected. Even if the data point is accurate, during the early stages of the test the leakage varies with time; as a result the initial value and therefore the calculated leak rate become time dependent. In the mass-point method, the mass of air in containment is calculated and plotted as a function of time. |
| | The slope of the linear least squares fit to the data is the leakage. |
| | Using the total time method, the calculation of leakage rates as a function of time required creates the situation where increasing the amount of data |
| | . ava i 1ab 1e causes the results to become more erratic and the 95% Confidence Interval to become wider. Using the total time method, the 95% confidence interval may range from one-half to twice the measured leak rate. In the case of mass-point method, the 95% confidence interval is between 5% and 20% of the measured leak rate. |
| * Additionally, Virginia Electric and Power Company believes that this exemption request will not result in undue risk to the health or safety of the public, in that; the proposed exemptions do not change, modify, or restrict existing plant safety limits, safety settings, systems or operation; or impact the design basis of the containment or modify its response during a DBA .. | | * Additionally, Virginia Electric and Power Company believes that this exemption request will not result in undue risk to the health or safety of the public, in that; the proposed exemptions do not change, modify, or restrict existing plant safety limits, safety settings, systems or operation; or impact the design basis of the containment or modify its response during a DBA .. |
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| e ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATION CHANGE}} | | e ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATION CHANGE}} |
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MONTHYEARML18152B6571999-04-28028 April 1999 Application for Amends to Licenses DPR-32 & DPR-37,revising TSs Re Refueling Water Chemical Addition Tank Min Vol ML18152B5431999-02-16016 February 1999 Application for Amends to Licenses DPR-32 & DPR-37,revising TS Re Augmented Insp Requirements for Reactor Coolant Pump Flywheels ML18152B5501999-02-16016 February 1999 Application for Amends to Licenses DPR-32 & DPR-37,proposing Administrative Change That Will Consolidate AFW cross-connect Requirements by Relocation of Electrical Power Requirements from TS 3.16 to TS 3.6 ML18152B6131998-11-0404 November 1998 Application for Amends to Licenses DPR-32 & DPR-37,revising EDG Start & Load Time Testing Requirements in TS 4.6.A.1.b ML18153A3291998-09-24024 September 1998 Application for Amends to Licenses DPR-32 & DPR-37,modifying Testing Requirements for Reactor Trip Bypass Breaker ML18151A6801998-06-19019 June 1998 Application for Amends to Licenses DPR-32 & DPR-37, Establishing Requirements for Use of Temporary Supply Line (Jumper) to Provide Svc Water to Component Cooling Heat Exchangers.Application Revised 971105 Submittal ML18153A2891998-03-25025 March 1998 Application for Amends to Licenses DPR-32,DPR-37,NPF-4 & NPF-7,revising Station Mgt Titles to Reflect New Positions Approved by Vepc Power Board of Directors on 980220 ML18153A3451997-12-18018 December 1997 Application for Amends to Licenses DPR-32 & DPR-37, Clarifying Terminology Used for Describing Equipment Surveillances Conducted in Refueling Interval Frequency. Amend Consistent W/Info Provided in Rev 1 of NUREG-1431 ML18151A9791997-11-0505 November 1997 Application for Amends to Licenses DPR-32 & DPR-37, Respectively.Amends Will Revise TS to Increase Maximum Allowable Fuel Enrichment from 4.1 to 4.3 Weight Percent U-235.Description of Change Encl ML18152A0761997-11-0505 November 1997 Application for Amends to Licenses DPR-32 & DPR-37, Establishing Requirements for Use of Temporary Supply Line (Jumper) to Provide Svc Water to Component Cooling Heat Exchangers ML18153A6331996-11-26026 November 1996 Application for Amends to Licenses DPR-32,DPR-37,NPF-4 & NPF-7,respectively,eliminating Records Retention Requirements Section of Ts,Per GL 95-06 & Adminstrative Ltr 95-06 ML18153A6881996-04-15015 April 1996 Application for Amends to Licenses DPR-32 & DPR-37, Clarifying Applicability of Quadrant Power Tilt Ratio Requirements ML18153A5371996-03-21021 March 1996 Application for Amends to Licenses DPR-32 & DPR-37, Clarifying Requirements for Testing Charcoal Adsorbent in Auxiliary Ventilation & Control Room Air Filtration Sys as Outlined in Tech Specs 4.12 & 4.20,respectively ML18153A5781996-01-30030 January 1996 Application for Amends to Licenses DPR-32 & DPR-37, Eliminating Surveillance Requirement for Certain Reactor Coolant Liquid Samples ML18153A6741995-11-20020 November 1995 Application for Amends to Licenses DPR-32 & DPR-37,permiting Use of 10CFR50 App J,Option B Performance-Based Containment Leakage Rate Testing. ML18153A7121995-07-20020 July 1995 Application for Amends to Licenses DPR-32 & DPR-37,proposing Changes to Ts,By Establishing New Setpoint Limit for Steam Generator high-high Level & Provides More Restrictive Setting Limits for Certain Rps/Esfas Setpoints ML18153A6971995-07-14014 July 1995 Application for Amends to Licenses DPR-32 & DPR-37,providing Two H Allowed Outage Time for One RHR Pump to Accommodate Plant Safety,Emergency Power Sys Surveillance Testing & Permit Depressurizing Su Accumulators in Lieu of Isolation ML18152A1841995-02-14014 February 1995 Application for Amends to Licenses DPR-32 & DPR-37,revising TS 4.4.D to Permit Approved Exemptions to ILRT Frequency Requirements,Including one-time Exemption Request from Section III.D.1(a) of 10CFR50,App J for Surry Unit 2 ML18153B2111995-01-24024 January 1995 Application for Amends to Licenses DPR-32 & DPR-37,modifying as-found Test Acceptance Criterion for Pressurizer Safety Valves ML18153B1601994-11-29029 November 1994 Application for Amends to Licenses DPR-32 & DPR-37,revising TSs to Implement Zirlo Fuel Cladding ML18153B1561994-11-22022 November 1994 Application for Amends to Licenses DPR-32 & DPR-37,deleting Unnecessary Descriptive Phrases Re Number of Cells in Station & EDG Batteries ML18153B1481994-11-10010 November 1994 Application for Amends to Licenses DPR-32 & DPR-37 to TS Re Changes to TS to Clarify SR for Reactor Protection & Engineered Safeguard Sys Instrumentation & Actuation Logic ML18153B0921994-10-11011 October 1994 Application for Amends to Licenses DPR-32 & DPR-37,modifying Surveillance Frequencies of Hydrogen Analyzers in Accordance W/Generic Ltr 93-05 ML18153B0491994-08-30030 August 1994 Application for Amends to Licenses DPR-32 & DPR-37,revising TS to Accomodate Core Uprating,In Accordance w/WCAP-10263, Review Plan for Uprating Licensed Power of PWR Power Plant. ML18153B0041994-07-14014 July 1994 Application for Amends to Licenses DPR-32 & DPR-37, Requesting Amendments in Form of Changes to TS to Eliminate Remaining References to cycle-specific Parameters in Surry TS ML18153A9651994-06-0909 June 1994 Application for Amends to Licenses DPR-32 & DPR-37,modifying in Part,Chemical & Vol Control Sys Specs & Safety Injection Sys Specs in Accordance w/NUREG-0452,Rev 4,NUREG-1431 & Generic Ltr 93-05 ML18153A8801994-02-25025 February 1994 Application for Amends to Licenses DPR-32,DPR-37,NPF-4 & NPF-7,modifying Surveillance Frequency of Nozzles in Containment & Recirculation Spray Sys in Accordance W/Gl 93-05, Line-Item TS Improvements to Reduced Srs.... ML18153B4301993-12-27027 December 1993 Application for Amends to Licenses DPR-32,DPR-37,NPF-4 & NPF-7,changing TS to Revise Review Responsibilities of Station Nuclear Safety & Operating Committee & Mgt Safety Review Committee ML18153B3481993-10-19019 October 1993 Application for Amends to Licenses DPR-32 & DPR-37,adding Operability & Action Statements for RSHX Service Water Outlet Radiation Monitors to TS Table 3.7-6 & SRs for Monitors to TS Table 4.1-2 ML18153B3301993-09-29029 September 1993 Application for Amends to Licenses DPR-32 & DPR-37,modifying TS to Require Insp Frequency of Low Pressure Turbine Blades to Permit Blade Insp to Perform Concurrent W/Disk & Hub Insp ML18153D3951993-07-20020 July 1993 Application for Amends to Licenses DPR-32,DPR-37,NPF-4 & NPF-7 Proposing Changes of Deletion of Requirement for Station Nuclear Safety & Operating Committee & Audit Frequencies ML18153D3901993-07-16016 July 1993 Application for Amends to Licenses DPR-32 & DPR-37,proposing Changes to TS to Permit Operation W/Three Degree Increase in Svc Water Temp Limit for Containment Air Partial Pressures of 9.1,9.2 & 9.35 Psia ML18153D3931993-07-16016 July 1993 Application for Amends to Licenses DPR-32,DPR-37,NPF-4 & NPF-7 to Implement Revised 10CFR20,revise Frequency of Radiological Effluent Release Repts from Semiannual to Annual & Clarify Site Maps ML18153D3791993-07-0202 July 1993 Application for Amends to Licenses DPR-32 & DPR-37,updating Augmented Insp Program for Sensitized Stainless Steel to Incorporate Newer Code Requirements While Maintaining Increased Insp Philosophy of ASLB ML18153D3781993-07-0202 July 1993 Application for Amends to Licenses DPR-32 & DPR-37 Modifying TS to Include COLR Which Presents reload-specific Limits for Key Core Operating Parameters ML18152A4471993-05-0606 May 1993 Application for Amend to License DPR-37,modifying TS to Support Operation of Unit 2 w/100 Psi Reduction in RCS Nominal Operating Pressure Through End of Operating Cycle 12,per Enforcement Discretion Granted by NRC on 930504 ML18153D3141993-04-21021 April 1993 Application for Amends to Licenses DPR-32 & DPR-37,providing Clarification of Design Response Time of Containment Hydrogen Analyzers & Deleting Unnecessary Channel Check for Analyzers ML18153D3111993-04-21021 April 1993 Suppl to 930315 Application for Amends to Licenses DPR-32 & DPR-37,modifying LCO & Action Statements for Main Control Room & Emergency Switchgear Room Air Conditioning Sys ML18153D2771993-03-19019 March 1993 Application for Amends to Licenses DPR-32 & DPR-37,revising TS to Address Operation W/Control Rod Urgent Failure Condition ML18153D2691993-03-15015 March 1993 Application for Amends to Licenses DPR-32 & DPR-37,changing TS to Permit Use of Two New Main Control Room & Emergency Switchgear Room Air Conditioning Sys Chillers,When Fully Operational,To Meet LCO ML18153D2281993-01-26026 January 1993 Application for Amends to Licenses DPR-32 & DPR-37,adding NRC Std Fire Protection License Condition to Each OL & Relocating Fire Protection Requirements from TS to Updated Fsar,Per GL 86-10 & GL 88-12 ML20128A5221993-01-22022 January 1993 Amends 173 & 172 to Licenses DPR-32 & DPR-37,respectively, Revising TS to Modify Acceptance Criteria for Functional Testing of Anchor Darling Mechanical Snubbers ML18153D1971992-12-11011 December 1992 Application for Amends to Licenses DPR-32 & DPR-37, Eliminating Operability Requirements for RCS Loop Stop Interlocks & Establishing Requirements for Operation of Loop Stop Valves ML18153D1681992-11-10010 November 1992 Application for Amends to Licenses DPR-32 & DPR-37, Specifying Action Statement for Operable Svc Water Flow Paths to Main Control & Emergency Switchgear Room Air Conditioning Condensers Governed by TS 3.14.C ML18153D1611992-10-26026 October 1992 Application for Amends to Licenses DPR-32 & DPR-37 to Increase Limit for Intermediate Range High Flux Reactor Trip Setpoint & to Eliminate Redundant Stipulation That Predicted Critical Rod Position Be Above Zero Power Insertion Limit ML18153D1171992-09-0404 September 1992 Suppl to 911230 Amend Applications 165 & 164 to Licenses DPR-32 & DPR-37,respectively,reinstating Allowed Outage Time for Surveillance Testing of Nonessential Svc Water Isolation Actuation Logic & Reformatting Logic ML18153D1141992-09-0404 September 1992 Application for Amends to Licenses DPR-32 & DPR-37,changing TS to Modify Acceptance Criteria for Functional Testing of Anchor/Darling Mechanical Snubbers to Reflect Replacement of Pacific Scientific Snubbers W/Anchor/Darling Snubbers ML18153D0871992-08-0707 August 1992 Application for Amends to Licenses DPR-32 & DPR-37, Establishing Operating Requirements for Recirculation Mode Transfer (Rmt) Function,Including LCO Action Statement & SR for Rmt & Deleting RWST Max Vol Requirements ML18153D0861992-08-0404 August 1992 Suppl to 911008 Application for Amends to Licenses DPR-32 & DPR-37,upgrading Portions of Section 3.0 & 4.0,per Generic Ltr 87-09 to Restrict Changes of Operational Conditions While in LCO & Delaying Entry Into Action Statement ML18153D0701992-07-28028 July 1992 Application for Amends to Licenses DPR-32 & DPR-37,deleting Operability & SRs of Hydrogen Monitor from Explosive Gas Monitoring Instrumentation Requirements for Waste Gas Holdup Sys & Including Requirements to Submit Special Rept to NRC 1999-04-28
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- e e 10 CFR 50 VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 W. L. STEWART VICE PRESIDENT March 1, 1988 NUCLEAR OPERATIONS U.S. Nuclear Regulatory Commission Serial No ..88-005 Attn: Document Control Desk NO/ETS:vlh Washington, D. C. 20555 Docket Nos. 50-280 50-281 License Nos. DPR-32 DPR-37 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS I AND 2 10 CFR 50, APPENDIX J EXEMPTION REQUEST Pursuant to 10 CFR 50.12, Virginia Electric and Power Company requests an exemption from 10 CFR 50, Appendix J, Paragraph III.A.3, which requires that Type A (Containment Integrated Leak Rate) tests be performed in accordance with ANSI N45.4-1972, "Leakage Rate Testing of Containment Structures for Nuclear Reactors." Since the issuance of ANSI N45.4-1972, a more accurate method of determining containment leakage rates, the mass point method, was developed as described in ANSI 56.8-1981, "Containment System Leakage Testing Requirements." Therefore, Virginia Electric and Powet Company is requesting exemption to a11 ow use of the mass point method for ca lcul at i ng containment leakage rates.
Based on the justification provided in Attachment 1, we conclude that the exemption from the requirements of Appendix J, Paragraph III.A.3 is justified pursuant to 10 CFR 50.12(a)(l) and 10 CFR 50.12(a)(2)(ii) in that it is authorized by law; will not present undue risk to public health and safety, and is consistent with the common defense and security. Additionally, special circumstances are present in this case in that application of the regulation is not necessary to achieve the underlying purpose of the rule. The mass point method will satisfy the accuracy requirements of 10 CFR 50, Appendix J, Paragraph III.A.3 for Type A tests.
In addition, a change to our Technical Specifications is r~quired in order to maintain consistency between Appendix J, our exemption request and the Technical Specifications. The proposed changes to Technical Specification are contained in Attachment 2 and the discussion of the proposed changes is contained in Attachment 3.
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e The exemption request and proposed Technical Specification change has been reviewed and approved by the Station Nuclear Safety and Operating Committee and the Safety Evaluation and Control Staff. It has been determined that the exemption request and Technical Specification change do not pose an unreviewed safety question as defined by 10 CFR 50.59 nor does it pose a significant safety hazards consideration as defined by 10 CFR 50.92.
In accordance with 10 CFR 170 an application fee of $150 is enclosed. If you have any questions or need additional information to process this request please contact us.
Very truly yours, DL~~:&
W. L. Stewart Attachments
- 1) Justification of Exemption
- 2) Proposed Technical Specification Change
- 3) Discussion of Proposed Changes
- 4) Application Fee cc: U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N. W.
Suite 2900 Atlanta, Georgia 30323 Mr. W. E. Holland NRC Senior Resident Inspector Surry Power Station Mr. Charles Price Department of Health 109 Governor Street
- Richmond, Virginia 23219 Mr. Chandu P. Patel NRC Surry Project Manager Project Directorate 11-2 Division of Reactor Projects - 1/11
e
)
CITY OF RICHMOND )
The foregoing document was acknowledged before me, in and for the City and Commonwealth aforesaid, today by W. L. Stewart who is Vice President - Nuclear Operations, of Virginia Electric and Power Company. He is duly authorized to execute and file the aforegoing document in behalf of that Company, and the statements in the document are true to the best of his knowledge and belief.
Acknowledged before me this / 9::_T day of cll1,{llLC/tJ , 19Q.S_.
My Commission expires: ~ I r ~ Z5, 19'7l>,
&h* X.i!ML Notary Public
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(SEAL)
"'
e ATIACHMENT 1 JUSTIFICATION OF EXEMPTION
BACKGROUND e e In 1973, 10 CFR 50 Appendix J was issued to establish requirements for Primary Reactor Containment Leakage Testing. Appendix J incorporated by reference ANSI N45.4-1972, "Leakage Rate Testing of Containment Structures for Nuclear Reactors." The Standard requires that containment leakage calculations be performed using either the point-to-point method or the total time method.
The total time method was used most by the nuclear industry until about 1976.
As noted in ANSI N45.4, the point-to-point method is suited to uninsulated containments where atmospheric stability is affected by outside diurnal change, while the total time method is appropriate for insulated containments that are relatively unaffected by diurnal changes. In 1976, an article (reference: "Containment Leak Rate Testing: Why the Mass-Point Analysis Method is Preferred," Power Engineering, February 1976) was written which compared the results of test analyses that were performed using point-to-point, total time, and mass-point techniques. A revision to the Standard (ref.: ANSI/ANS 56.8-1981, "Containment System Leakage Testing")
. specifies the use of mass-point. The draft revision to Appendix J incorporates the new standard ANSI/ANS 56.8-1981.
JUSTIFICATION Virginia Electric and Power Company believes that this exemption should be granted pursuant to 10 CFR 50.12(a)(2)(ii); i.e., application of the regulation in the particular circumstances is not necessary to achieve the underlying purpose of the rule, ~hich is to provide an accurate and conservative test of containment integrity.
Mass-point is a newer and more accurate method of ca lcul at i ng containment leakage. The total time method cal cul ates a series of leakage rates based upon air mass differences between an initial data point and each individu~l data point thereafter. The adequacy of the method is extremely sensitive to the accuracy of that initial data point. If, due to any reason (su*ch as instrument error, lack of temperature equilibrium, ingassing or outgassing) the initial data point is not accurate, the results of the test will be affected. Even if the data point is accurate, during the early stages of the test the leakage varies with time; as a result the initial value and therefore the calculated leak rate become time dependent. In the mass-point method, the mass of air in containment is calculated and plotted as a function of time.
The slope of the linear least squares fit to the data is the leakage.
Using the total time method, the calculation of leakage rates as a function of time required creates the situation where increasing the amount of data
. ava i 1ab 1e causes the results to become more erratic and the 95% Confidence Interval to become wider. Using the total time method, the 95% confidence interval may range from one-half to twice the measured leak rate. In the case of mass-point method, the 95% confidence interval is between 5% and 20% of the measured leak rate.
- Additionally, Virginia Electric and Power Company believes that this exemption request will not result in undue risk to the health or safety of the public, in that; the proposed exemptions do not change, modify, or restrict existing plant safety limits, safety settings, systems or operation; or impact the design basis of the containment or modify its response during a DBA ..
e ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATION CHANGE