ML18136A188

Forwards Status Rept Re Containment Leak Rate Test & Request for Addl Info to Complete Review

ML18136A188
Person / Time
Site:	Surry
Issue date:	10/12/1979
From:	Carfagno S FRANKLIN INSTITUTE
To:	Zech G Office of Nuclear Reactor Regulation
References
CON-NRC-03-79-118, CON-NRC-3-79-118 NUDOCS 7911160478
Download: ML18136A188 (4)

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LJLJLJmanklin Research Center

. ~ Division of The Franklin Institute

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November 17, .. 1979 United States Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Mr. Gary Zech Project Monitor

Reference:

FRC Project C5257 NRC Contract NRC~03-79-118

-NRC TAC No. 08638 FRC Task Nos. 50/51

Title:

Surry Units 1 & 2; Containment Leak Rate Testing (App*endix J)

Dear Mr. Zech:

• A status .of the subject review package is_ provided in enclosure (1).

It is forwarded to provide both the NRC and VEPCO with an opportunity to concur with or comment on the status as determined by the FRC.

Enclosure (2) provides a listing of additional information required

_by the FRC* to complete the*review.

For your information, the milestone dates for review of this package are .as follows: * *

. Receipt of Additional Information:. 1/15/80 Start Final Review: 2/4/80 Submit Draft Report*to NRG: 3/31/80 Very truly yours,

,4'r7dcfr S. P. Carfagno Project Manager Enc.

SPC/cal xool s

f 11!

The Benjamin Franklin Parkway, Philadelphia, Pa. 19103 (215) 448-1000 TWX-710 670 1889

Enclosure (1) ..

STATUS OF IMPLEMENTATION 10 CFR 50, APPENDIX J SURRY 1 & 2 1.0 GENERIC ISSUE BACKGROUND Appendix J to 10 CFR 50 was published on February 14, 1973. Since several plants were either operating or in advanced stages of construc-tion at the time, it was frequently not possible to implement the re~

quirements of Appencµ..x Jin these plants without exceptions.

During mid-1975, the USNRC requested all licensees concerned to review their status of compliance with Appendix J and to identify planned actions (design modifications, amendment to technical specifi-cations, requests for exemption pursuant to 10 CFR 50.12, etc.) where not in full compliance. Subsequently, the NRC developed positions regarding the extent. to which leak testing practices generally satisfy the intent of the regulation. These positions have been utilized to resolve certain exemption or technical specification change requests for specific plants. The generic issue, however, has remained open primarily owing to proposed changes to both Appendix J and the associat-ed concensus standards related to containment leak rate testing.

The NRC presently intends to resolve all outstanding questions in

• this area prior to October, 1980. The proposed regulatory or standards changes have developed sufficiently to preclude the precipitation by such action of further generic issues. Accordingly, a concerted effort has been scheduled to provide*a final review.of all outstanding requests.

This effort may require licencees to submit additional information necessary to resolve the specific issues for their plants.

2.0 SPECIFIC BACKGROUND According to the file of correspondence relating to implementation of Appendix J requirements for Surry, Units No. 1 and No. 2, the history of the issue is as follows:

Virginia Electric and Power Company (VEPCO) replied to the NRC's generic letter (dated 8/4/75) on October 20, 1975. In that reply, VEPCO listed seven differerices between the then existing technical specifications and the approved version of Appendix J. VEPCO further stated that it would modify its program to.accommodate the technical differences with exception of the requirement to test the containment personnel air lock after each opening. Subsequently, VEPCO submitted Proposed Technical Specification Change No. 69 on September 22, 1978 which specified that Containment Leakage Testing would be performed in accordance with Appendix J except for the personnel hatch which would be tested at least quarterly instead of after each entry.

e e On January 9, 1979, in response to an NRC letter dated No~ember 29, 1978, VEPCO stated that it would conform to the NRC Staff's interpreta-tion of the "after each opening" requirement of Appendix J for contain-ment air locks. VEPCO further stated that air lock seals would be tested within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of each use to verify proper sealing and that the entire air lock would be tested at peak calculated accident pressure at intervals of no more then six months.

Finally, on September 24, 1979, VEPCO amended its Proposed Technical Specification Change No. 69 to replace the reference volume method of leakage rate testing with the absolute method of leakage rate testing of ANSI N45 .4-1972. I 3.0 OUTSTANDING ISSUES

..The outstanding requests, questions or issues as enumerated in the correspondence listed above relating to implementation of Appendix J criteria for SURRY .Units 1 and 2 which require review, comment or approval are:

ITEM DESCRIPTION OF ISSUE 1 Acceptance of T.-S. Change No. 69 with amendment of 9/24/79 (contingent upon further amendment to include VEPCO's commitment of 1/9/79).

4.0 INFORMATION REQUIRED In order to *conduct a final review in this matter, additional infor-mation, docmnentation or drawings is needed as listed in enclosure (2).

Additionally, should the licensee have a substantial disagreement with either the.background or listing of outstanding issues described above, or have other information pertinent to a final review and disposition of this matter, this should be made known at this time.

It is desired that all information indicated herein be provided within approximately thirty days.

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Enclosure (2) **

Additional Information Required Item Description_

1 Further description of the method to be used to verify proper seating of air lock seals with 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of opening, including system diagram, !test

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pressures and system discription.

2 Manufacturer's drawings or other drawings of the personnel air lock showing sealing devices and door operating/locking mechanisms, as well as the manufacturer's recommended test pressure.

3 A description of how L will be determined (para 4.(a)(iii) of Ap~. J.) in view of the fact the method of performing the Type A test was changed from the reference volume method to the absolute pressure method.

4 A further description of the "make up air method" to be used to verify the Type A test discussed in VEPCO's 9/24/79 letter.