ML17219A301

Forwards Justification for 861010 Request for Exemption to 10CFR50,App J,Paragraph III.D.2(b)(ii) & Addl Documentation Re NSHC in Support of Application for Amend to License DPR-67 Re Requirements for Testing of Containment Air Locks

ML17219A301
Person / Time
Site:	Saint Lucie
Issue date:	01/09/1987
From:	WOODY C O FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
L-86-9, NUDOCS 8701130269
Download: ML17219A301 (11)

Text

REGULATORY FORNATION DISTRIBUTION SY-N (R IDS).ACCESSlON NBR: 8701130269 DOC.DATE: 87/Oi/OV NOTARIZED:

NO FACIL: 50-335 St.Lucie Planti Unit 1>Florida Power Zc Light Co.AUTH.NANE AUTHOR AFFILIATION MOODY'.Q.Florida Power 8c Light Co.REC IP.NAI'lE RECIPIENT AFFILIATION Record Services Branch (Document Control Desk)DOCKET 05000335

SUBJECT:

Forwards justification for 861010 request for exemption to 10CFR50>App J~Paragraph I I I.D.2(b)(i i)8c addi documentati on re NSHC in support of application for amend to License DPR-67 re requirements for testing of containment air locks.DISTRIBUTION CODE: A017D COPIES RECEIVED: LTR+ENCL SIZE: TITLE: QR Submittal:

Append J Containment Leak Rate Testing NOTES: RECIPIENT ID CODE/NAI'lE PNR-8 ADTS PNR-8 PEICSB PNR-8 PDB LA TQURIQNY>E PNR-8 RSB INTERNAL: ADN/LFNB NRR BAR ADTS NRR PNR-8 ADTS NRR/DSRO/RSIB COPIES LTTR ENCL 1 2 2 1 0 1 1 1 0 1 1 1 1 RECIPIENT ID CODE/NAI'1E PNR-8 EB PMR-8 FOB PMR-8 PDS PD 01 PWR-8 PEICSB ELD/HDS2 08 NRR PAR-A ADTS EIB 04 COPIES LTTR ENCL 1 1 1 5 5 1 1 1 1 1 EXTERNAL: LPDR NSIC 03 05 1 1 1 NRC PDR 02 TOTAL NU})BER OF COPIES REQUIRED: LTTR 25 ENCL 23

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h'"'}'I h., 4 I" 4$<<v P.O.B 4000, JUNO BEACH, FL 33408-0420"gNUwY 09lSA L-87-9 U.S.Nuclear Regulatory Commission Document Control Desk Washington, D.C.20555 Gentlemen:

Re: St.Lucie Unit 1 Docket No.50-335 Containment Air Locks By letter L-86-412, dated October 10, 1986, Florida Power&Light Company (FPL)applied for an amendment to Facility Operating License DPR-67 regarding surveillance requirements for testing of containment air locks.The intent of this proposed amendment is to bring the St.Lucie Unit I Technical Specifications to the same form as those of Unit 2 for air lock testing.By letter dated November 25, 1986 (E.G.Tourigny to C.O.Woody), the NRC stated that the specific exemption included in the amendment should be made in accordance with 10 CFR 50.12.The staff also requested additional information to address each factor under 10 CFR 50.92(c), the No Significant Hazards Consideration.

Attachment I is the justification for the requested exemption to 10 CFR 50, Appendix J, Paragraph 111.D.2(b)(ii).Attachment ll is additional documentation regarding the No Significant Hazards Consideration.

Please contact us if you have any questions about this submittal.

Very truly yours,.Woody roup Vice President Nuclear Energy COW/E JW/gp At tachments (2)cc: Dr.J.Nelson Grace, Region ll, USNRC Mr.Alan Schubert, Florida Dept.of Health and Rehabilitative Services Harold F.Reis, Esquire t 8701130269 870109 PDR ADOCK 05000335I P PDR I~j PEOPLE...SERVING PEOPLE

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JUSTIFICATION FOR THE RE UESTED EXEMPTIONS TO 10CFR50 APPENDIX J 10CFR50.12(a)

(1)In accordance with 10CFR50.12(a)

(1), the Commission may grant exemptions under the following circumstances: (I)the activities to be conducted are authorized by law, (IZ)operation with the exemption will not present undue risk to the health and safety of the public, and (ZIZ)the common defense and security are not endangered.

The evaluations to these standards, contained herein, are in accordance with 10CFR50.12 as revised by final rule dated January 13, 1986.I.The Re uested Exem tions and the Activities Which Would Be Allowed Thereunder Are Authorized b Law There are no other prohibitions of law to preclude the activities which would be authorized by the requested exemption.

Therefore, the Commission is authorized by law to grant this exemption request.IZ.The Re uested Exem tions Will Not Present Undue Risk to the Health and Safet of the Public The evaluation of"no undue risk" considers such factors as the type of plant operation contemplated, the length of time the exemption would be in effect, the existence of alternative means of compliance or compensatory measures, and other safety factors.The results of the evaluations considering these factors are discussed below.Containment Air Lock Testin Exem tion Re uest 10CFR50, Appendix J, Paragraph III.D.2(b) details three explicit air lock testing requirements.

In the proposed amendment to St.Lucie Unit 1, Technical Specification 4.6.1.3, items a, b, and c comply with Appendix J requirements with one exception.

Appendix J, Paragraph III.D.2(b)(ii)requires that"Air locks opened during periods when containment integrity is not required by the plant's Technical Specifications shall be tested at the end of such periods at not less than Pa.".Whenever the plant is in Mode 5 or 6 CONTAINMENT>

VESSEL INTEGRITY is not required.Therefore, if an air lock is opened during either of these conditions, paragraph 1ZZ.D.2(b)(ii)requires that an overall air lock leakage test at not less than Pa be conducted prior to entry into Mode 4.This requirement is excessively restrictive since.it requires a termination of containment entries while preparing to leave Mode 5 until the air lock that was opened and operated in Mode 5 or 6 is tested pursuant to paragraph IIZ.D.2(b)(ii).Primary Containment entries during Mode 5 are important to ensure that surveillance requirements and minor maintenance activities are completed.

The requirements of paragraph IIZ.DE 2(b)(ii.)would apply even if the six month testing requirement of paragraph ZII.D.2(b)(i)had been satisfied.

Subsequent containment entries while in Mode 5 would require retesting of the air lock uti.lized.

Access to containment during Periods when CONTAINMENT

.VESSEL INTEGRITY is required by plant Technical Specifications is governed by paragraph ZIZ.D.2(b)(iii).The existing air lock doors are so designed that a full pressure test at Pa of an entire air lock can only be performed after strongbacks (structural bracing)have been installed on the inner door.This is because the pressure exerted on the inner door during the test is in a direction opposite to that of force experienced during a postulated accident and the locking mechanisms are not designed to wi.thstand such reverse forces..Installing strongbacks, performing the test, and removing the strongbacks, is a cumbersome process requiring at least 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> during which access through the air lock is prohibited.

The Appendix J periodic 6-month test requirement of paragraph ZII.D.2(b)(i)and the 3-day test requirement of paragraph ZZI.D.2(b)(iii)provide assurance that the air lock will not leak excessively if no maintenance which could affect the ability of the air lock to seal has been performed on the air lock and if the air lock is properly engaged and sealed.An exempti.on from paragraph ZZI.D.2(b)(ii)of Appendix J is requested since the proposed amendment to Techni,cal Specification (FPL letter L-86-4 12, dated October 10, 1986)is substantially as safe as the requirement itself.This exemption is included as a part of the NRC's CE Standard Technical Specifications approved December 31, 1981, and is consistent with current regulatory practice and poli.cy.Because of the proposed Techni.cal Specification surveillance requirements, the requested exemption involves a de facto requirement for an air lock seal test in lieu of the ZIZ.D.2(b)(ii)test.Appendix J, Paragraph III.D.2(b)(ii.i)already allows an air lock seal test in lieu of a simi.lar required air lock test at a pressure of not less than, Pa.Thus the functional equivalence of these tests under similar.circumstances has been recognized.

PPL proposes an alternative'est to be conducted during those periods when CONTAIN-MENT VESSEL INTEGRITY is not required by the Plant Technical Specifications and pri.or to entering Mode 4.The alternative test consists of testing the seals of the inner and outer doors by pressurizing the area between the seals and verifying an acceptable leakage rate.Zf, however, maintenance has been performed on the air lock since the last successful test performed pursuant to paragraph IZZ.D.2(b)(i), an overall air lock test will be performed.

It is concluded that there is reasonable assurance against undue air lock leakage provided under the exemption and no material increase in the probability or extent of air lock leakage is to be expected.Therefore, there is no signi'ficant increase in the probability of higher post-accident offsite or onsite doses related to the exemption and no significant increase in environmental impact beyond that experienced without an exemption.

As a result, this exemption will not present undue risk to the health and safety of the public.The Re uested Exem tion Will Not Endan er the Common Defense and Securit The requested exemption will have no impact on the common defense and security.In conclusion, the standards of 10CFR50.12(a)

(1)are met for the specific exemption.

10CFR50.12(a)

(2)In accordance with 10CFR50.12(a)

(2), the Commission will not consider granting an exemption unless special circumstances are present.Special circumstances in which the Commission believes it would be reasonable to grant an exemption are identified in Sections 50.12(a)(2)(i)through (vi)of the revised final rule.The following evaluations pertain to each of these criteria.50.12(a)(2)(i)-"Application of the regulation in the particular circumstances would be in conflict with other rules or requirements of the Commission." The specific exemption request discussed herein is not applicable to the special circumstance of Section 50.12(a)(2)(i).50;12(a)(2)(ii)-"Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule." 4 Application of this special circumstance shows that application of the regulation is not necessary to serve the specific purpose.of the regulation.

~i~'The Containment Air Lock leakage rate testing is performed to ensure CONTAINMENT VESSEL INTEGRITY.

CONTAINMENT VESSEL INTEGRITY ensures that the release of radioactive materials from the containment atmosphere will be restricted to those leakage paths and associated leak rates assumed in the accident analyses.The restriction, in conjunction with the leakage rate limitation, will limit the site boundary radiation doses to within the limits of 10CFR Part 100 during accident conditions.

3 The limitations on containment leakage rates ensure that the total containment leakage volume will not exceed the value assumed in the accident analyses at the peak accident pressure.As noted above, and in the previous discussion of"no undue risk", the application of the requirements of 10CFR50, Appendix J, Paragraphs ZII.D.2(b)(ii)is not necessary to serve the underlying purpose of these regulations.

This is true since the alternatives presented limit the postulated accident doses to within the 10CFR100 guidelines.

Therefore, the special circumstances of Section 50.12(a)(2)(ii)apply to these specific exemption requests.50.12(a)(2)(iii)-"Compliance would result in undue hardship or other costs that are significantly in excess of those incurred by others similarly situated." This special circumstance is intended to provide equitable treatment to all applicants and licensees.

As noted in the discussion of the Containment Air Lock test exemption request, undue hardships or unnecessary difficulties, in the form of excessive restrictions to Containment access and the cumbersome process of installing/removing strongbacks on the inner door, would result from literal compliance to 10CFR50, Appendix J, Paragraph ZZZ.D.2(b)(ii).Such literal compliance to this Appendix J requirement would not result in any measurable difference in protection to the public health and safety relative to the protection afforded if this exemption is granted.In addition, similar exemptions to these requirements have been granted by the NRC for the Grand Gulf Nuclear Station, Fermi Unit 2, and Salem Nuclear Generating Station.Exemption requests from this requirement have been filed by Perry Nuclear Power Plant, Nine Mile Point Unit 2, Seabrook and the Clinton Power Station.Therefore, with respect to the Containment Air Lock test exemption, the special circumstance of Section 50.12(a)(2)(iii)applies.Furthermore, compliance to this requirement would result in undue hardship and cost through reduced operational flexibility and unwarranted.

delays in power ascension over the life of the plant in excess of those incurred by other similar facilities that have received exemption from the subject Appendix J paragraph.

Performance of the leakage rate tests required by paragraph ZZI.D.2(b)(ii)takes approximately 14'ours per air lock and requires installation of a strong.back device on the insid'e air lock door (Test pressuie applied inside the air lock tends to unseat this door because it is de'signed to seal with accident pressure from inside containment).

This evolution can potentially occur several times during a refueling outage and ultimately can delay mode change on start up.

50.12(a)(2)(iv)-"The exemption would result in benefit to the public health and safety that compensates for any decrease in safety that may result from the grant of the exemption." The above discussions

'on the Containment Air Lock leak rate test exemption support the basis for this special circumstance.

In the exemption request, the design and/or alternative testing is substantially as safe as the requirements themselves.

Therefore, the special circumstance of Section 50.12(a)(2)(iv)applies to this specific exemption.

50.12(a)(2)(v)"The exemption would provide only temporary relief from the applicable regulation and the licensee or applicant has made good faith efforts to comply with the regulation." This special circumstance does not apply to these exemption requests since it is for the operating lifetime of St.Lucie Unit l.50.12(a)(2)(vi)-"There is present any other material circumstance not considered when the regulation was adopted for which it would be in the public interest to grant an exemption." There is not present any other material circumstance not considered when the regulation was adopted for which it would be in the public interest to grant an exemption.

REATTACHMENT II)'ETERMINATION OP NO SIGNIFICANT HAZARDS CONSIDERATION The standards used to arrive at a determination that a request for amendment involves no signif icant hazards consideration are included in the Commission

'regulations, 10 CFR 50.92.These regulations state that no significant hazards consideration are involved if the operation of the facility in accordance with the proposed amendment would not: (1)involve a significant increase in the probability or consequences of an accident previously evaluated, or (2)create the possibility of a new or different kind of accident from any accident previously evaluated, or (3)involve a significant reduction in a margin of safety.Each standard is discussed as follows: (1)Operation of the facility in accordance with the proposed amendment would not involve a significant increase in the, probability or consequences of an accident previously evaluated.

The air lock configuration

'or current method of testing is not being changed.Therefore, the PSAR analysis for accident probability, malfunction type, accident type, and consequence of failure has not been affected.(2)Use of the modified specification would not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed amendment will result in no changes to the plant's procedures, structures, systems, mode of operation or components.

No additional tests or experiments not described in the FSAR are necessary to implement the proposed change.(3)Use of the modified specification would not involve a significant reduction in a margin of safety.The margin of safety for Technical Specifications has not been reduced since acceptance criteria will remain unchanged.

Based on the above, PPL has determined that the amendment request does not (1)involve a significant increase in the probability or consequences of a accident previously evaluated, (2)create the probability of a new or different kind of accident from any accident previously evaluated, or (3)involve a significant reduction in a margin of safety;and therefore does not involve a significant hazards consideration.

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