1CAN129013, Responds to Generic Ltr 90-06 Re Resolution of Generic Issue 70, Power-Operated Relief Valve & Block Valve Reliability, & Generic Issue 94, Addl Low-Temp Overpressure Protection for Lwrs

Responds to Generic Ltr 90-06 Re Resolution of Generic Issue 70, Power-Operated Relief Valve & Block Valve Reliability, & Generic Issue 94, Addl Low-Temp Overpressure Protection for Lwrs

ML20065U421
Person / Time
Site:	Arkansas Nuclear
Issue date:	12/21/1990
From:	James Fisicaro ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
REF-GTECI-070, REF-GTECI-094, REF-GTECI-NI, TASK-070, TASK-094, TASK-70, TASK-94, TASK-OR 1CAN129013, GL-90-06, GL-90-6, NUDOCS 9101020316
Download: ML20065U421 (9)

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Operations December 21, 1990 1CAN129013 U. S. Nuclear Regulatory Commission Document Control Desk Hall Station Pl-137 Washington, D. C. 20555

Subject:

Arkn'inas Nuclear One-Unit 1 Docket No. 50-313 Licenso No. DPR-51 Response to Generic hetter 90-06 Gentlemen:

Generic Letter 90-06, Resolution of Generic Issun 70, " Power-Operated Relief Valve and Block Valve Reliability," and Generic issuo 94, " Additional Low-Temperature Overpressuro Protnction for Light-Water Reactors" was issued on Junn 25, 1990 (0CNA069027), to advise licensees of the NRC Staff positions with respnct to resolution of these Generic Issues. The Staff positions are dolineated in Enclosures A and B to the Generic Letter.

With respect to the Staff positions delicinated in Enclosure A, the Arkansas Nuclear Onn-Unit 1 Electromatic Relief Valvo (or PORV) is not rolled upon to perform any of the safety-related functions identiflod in Section 2 of Enclosure A. Therefore, Entergy Operations, Inc. does not commit to incorporcte those improvements identified in Section 3 of Enclosuro A for Arkantas Nuclear One-Unit 1. The detailed basis for this position is provided in ths onclosed Attachment to this letter. Iloweve r , ' majority of the Jmprovement actions identified it, the Staff positiont tave been implomonted at Arkansas Nuclear One-Unit I as described in the enclosed Attachment.

As indicated in the Generic Lotte. , the Staff positions delineated in Enclosure B to t.he Generic 1.ntter are not applicable to Arkansas Nuclear One-Unit 1 since this plant is a Babcock & Wilcox designed plant which maintains a steam or gas volume in the pressurizer, l

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O. S. NRC December 21, 1999 Page 2 l l

l This informatien is being provided under af firmation pursuant to 10 CFR 50.54(f). Picase adviso if you require any additional information, j

0 Very truly yourw.

l pppe. '.)bue James . Fisicato Hannger, 1.(censing JJF/SAB/agw Attachments ,

cci Hr. Robert Hartin U. S. Nucicar Regulatory Commission Region IV-611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 Thomas W. Alexion NRR Project Manager, Region IV/ANO-1 U. S. Nuclear Regulatory Commission NRR Hall Stop ll-B-19 One White Flint North 11535 Rockville Pike Rockville Maryland 20852 NRC Senior Residei.t Inspector Arkansas Nuclear One - ANO-1 & 2 Number 1, Nucicar Plant Road Russellville, AR 72801 Hs. Sheri Peterson NRR Project Manager, Region IV/ANO-2

, U.- S. Nuclear Regulatory Commission L

NRR Hall Stop 11-B-19' One White Flint North 11555 Rockville Plke l

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1, J. J. Fisicaro, bcIng duly sworn, subscribe to and say that I am Manager, I,leensing, ANO for Entergy Operations, Inc.; that. I have full authorft) to executo this onth; that I have rend the document numbered 1CAN129013 eind know the contouts thorcof; and that to the bent of my ,

knowledgn, information and bolinf, the statements in it are true, n ... !). } .:. % ,,

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. 'J. idficaro SUBSCRIBED AND SWORN TO bnfore me, a Notary Public in and for the CountyandStatoabovonamed,this.2/Jf,dayof. /MW/ D ,

1990.

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A t t a chmerit to 1CAN129013 r,nge 1 SAFETY FUNCTIONS OF PORVs AND BLOCK VALVES _(GL 90 06. Enclosuro A uSection 2)t Generic Letter 90-06 Enclosure A, Section 2 states that over n period of time the role of PORVN has chnnged such that PORVs are .aow relied upon by many plants to perform one, or more, of the following safety-related funct ions:

1. Hitigation of a design-basis steam generator tube rupture accidou .

2. Low-temperaturn overnressure protection of the reactor vessel during startup and shutdown, or

3. Plant cooldown in compliance with Branch TechC sil Position R511 5-1 to SRP 5.4.7, "Resid%1 llent Removal (RllR) System."

Sectlon 2 further states that where PORVs are used or could be used to perform one, or more, of these saf ety-related functions or to perform any other safety-rointed function in the future, it is approprinto to reconsider the safety classifiention of PORVs and the associnted block valves.

Arkans.as Nucicar_One-Unit 1_Rosponsoi Although Arkansas Nuclear One Unit 1 (ANO-1) is n Babcock 6 Wilcox designed pinnt with a single elect romat ic (power-opernted) roller valve and associnted block valvo, the design of the plant does not rely upon the Electromatic Relief Vnivo (ERV) to perform any of the safety-relnted functions identified in Section 2 of Enclosure A. The following discussion provides justification for not depending upon thn ERV for each safety-related function:

1. Mit inntion of a design-basis steam generator tube r upture accident.

Section 14.2.2.2 of the ANO-1 Safety Analysis Report (SAR) describes the analysis, the assumed sequence of events, and the results for the design-basis Stenm Generator Tube Rupture accident. As doncribed in the SAR, the initial primary-to-secondary lenk rato f rom the tube rupture exceeds the normal makeup to the Reactor Coolant System (RCS).

Consequently, primary system pressuro decreases and a low RCS pressure t rip will occur assuming no initial operator action. The analysis nasumes that no operator action is taken until 20 minutes af ter the tubo rupture.

Following renctor t rip, the RCS pressure cont.inues to decrease until liigh Pressure injection (HPI) is actuated. The capacity of IIP 1 is suf ficient to compensate for the leaknge and maintains both pressure and volume control of the RCS. The turbine stop valves will also closo following reactor trip; and since a primary-to-secondary leak has occurred, steam lino pressure will incronso and the steam bypass valvos will open to the condenser. The steum bypass system and the condensor are both assumed to be availablo due to the availability of of f-site power during the design-basis steam generator t ube accident.

Thereafter, the reactor is cooled down and depressurized at. 100'F por hour in accordance with normal cooldown procedures.

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At t tithmer i to IC AN 12901'l Page 2 Aftet the RCS t empeiat ure has decronsed to the vnlue corresporiding ta the saturation pressure of the lowest set main stenm safety vnive, the nffected stenm generator i s a t: s s med to be isolated. Cooldown via t he unnffected steam generntor contjoues until the KCS temperature is reduced to 280*F where cooldown is cont (tiued using the Decny llent Removal System.

The I.RV is ut ilized in the ANO 1 f.mergency Opernt itig Procedures for a tube rupture accident ns n mentin to depressur ize the RCS. However, as irid iented above, the f.RV (or PORV) is not utilized iti the assumed sequence of events and is therefore not. rolled upon to mitigate n design-bnsis steam generator tube rupture accident.

2. Low-temperature overpressure protection of tha reactor vessel duririg stnttup and shutdown.

Low-Temperature Overpressure Protection (1. TOP) concertis with respect to PORVs do not apply to ANO-1 sinte IGW designed pinnts maintain a steam or gas volume in the pressurizer (ns (tdicated in Generic hetter 40-06). Annlynes hnvc shown that during low-t emperatut e overpressure prot ect ion cond i t lons , the operator hns at l en s t. t en (10) mitiutes to respond to nu overpressure event prior to exceeding the LTOP pressure 1 i m i t. .

The ANO-1 analyses supporting the ten minute operntor response time was provided in f.nt ergy Operat ions letter dated March 24, 1977 (ICANO37716). Subnequent reviews by the NRC nnd F.ntergy Operations resulted in the current Technical Specificat ions with respect to LTOP cond i t ions . These speci f icnLions ( = , e ANO-1 responsa to NRC Staff Position 3.1, item 3 below) were provided in f.ntergy Operations letter dated August 15, 1984 (IC/.N088401), which was issued as Amendment No.

95 to the facility Opernting License.

3. Plant cooldown in complinnce with Branch Technical Posit ion RSD 5-1 to SRP 5.4.7, "Residunt Hent Removal (RilR) System."

Arkansas Nuclear One-Unit I was licensed prior to issuance of the Standhrd Review Pinn and Branch Technical Position RSD 5-1. Therefore, the licensing basis for ANO-1 does not require compliance with Bianch Technical Ponition RSH 5-1 to SRP 5.4.7, " Design Requirements of the kos idua l llen t. Removnl (RilR) Sys t em."

Attachment to ICAN129013 Page 3 IMPROVEMENTS 70_A!.L_PORVn AND BLOCK _VAI.VES (GL 90-06, Encionure A, Sectlon 3)t Generic Letter 90-06 Enclosure A Section 3 provides the NRC Stnif position with respect to actions which should be taken by licensees to improve the tellnbility of PORVs and block valves. Even though the ANO-1 LRV and associated block valve nre not relied r,vn to per f orm any of t he sn f et y- relat ed f unct ions identified in Section 2 of Enclosure A, t he information provided below nddresses the current status of ANO-1 with respect to the three separate netions which are presented in Sectton 3.

NR_C S_t_nff_ Position 3.1 _ Item.1:

Include PORVs and block valves within the scope of an operational qunlity nasurance program thnt ir in complinnen with 10 CPR Part 50, Appendix B. This program should include the foilewing elements:

n. The addition of PORVs and block valves to the pinnt operationni Quality Assurance List,

b. Implementation of a maintennoce/ refurbishment program for PORVn and block vnives that In based on the manufact urer's recommendations or guidelines and is implemented by trained pinnt maintenance pornonnel.

c. When replacement. parts and spares, as well as complete components, are required for ex ist ing non-saf ety-grade PORVs and block valves (and associnted control systems), it is the intent of this generic letter that-these itoms may be procured in accotdance wIth the orlginnI construction codes and MLandards.

Arkannnn Nuclear __One-Unit _1 Responnet The ERV and associnted block valve are within the scope of the Arkansns Nucient One Qunlity Assurance Mannni Operations (QAMO). The QAMO meets the requirements of 10 CI'R Part 50, Appendix B.

n. The ERV (PSV-1000) is included in the ANO-1 Component Level Q-List which is maintained current in the Station int rmation Manngement System (SIMS)

Component Data Base. This valve is classified as a QA Category Q. Safety Class SR component wit h a Q-Punct ion of C4 (RCS Pressut e Boundary Integrity; Passive). The valve mnnufacturer (Drenser Industries, Inc.) is on the ANO Qunlified Vendors 1.ist (QVL) and has nn NRC approved 10 CFR Part. 50, Appendix B program.

The block valve (CV-1000) is also included in the ANO-1 Component Level Q-List in the SIMS Component Datn Base. This valve is classified as a QA Category Q, Safety Class .1 component with a Q-Funct ion of D4 (RCS Inventory'; Passive). The valve manufacturer (Velnn Engineering) .is on the ANO QVI. and hns an NRC approved 10 CPR Part 50, Appendix D program, i

Attnchment to ICAN129013 Page 4

b. Mnintenance and repnir activities which af fect qunlity and safety at Arkansas Nuclear Doc at e implernented through cont rolled procedures by ttnined plant personnel as described in the QAMO. Ench procedure is suf ficiently detailed such that a conlified individun t any perform the r equired functions wit hout direct opervis ion. Mnintennnce or refurbishment of the ERV is controlled through Hechanical Mnintenance Procedure No. 1402.026. Maintennnte or refutbinhment of the nssociated block valve is controlled through the issuance of specific Work Plans in accordnnce with Administrative Procedure No. 1000.006. Work Plans incet the review and approval requirements of existing procedures. Maintennnce activities for the block valve nre also controlled through the Motor Operated Valve (MOV) Maintenance Program (Maint.mance Administrative Procedure No. 1025.011),

c. Replacement part.s and spo res, as well as cornpletn components for the ERY and block valve (and assocint ed cont rol syst ernn) are procured in accordance with the applicabic codes and standards os required by the QAMO.

NRC_ Staff Position 3.inItem_2:

Include PORYs, valves in PORV control air syst erns, and block vnives within the scope of a program covered by Subsection IWV, " Inservice Testing of Valves in Nucient Power Plants," of Section XI of the ASME Boiler and Pressure Vessel Code. Stroke testing of PORVs should only be pntformed during Mode 3 (ll0T STANDBY) or Mode 4 (ll0T SHUTDOWN) and in all cases prior to establishing conditions where the PORVs are used for low-temperature overpressure protection. Stroke testing of the PORVs should not be performed during power operation. Additionally, the PORV block valves should be included in the licensecs' expanded MOV test program discussed in NRC Generic het ter 89-10

" Safety-Reinted Motor Operated Valve Testing and Surveillance," dated June 28, 19P9.

Atkannas_Nucien t one.-U. nit _1_Rosponset The ERV and associated block valve are within the scope of the Inservice Test ing Program of pumps and valves for ANO-1 (Engineering Programs Procedure No. 1092.032). This program is in compliance with Subbect ion IWV. "]nservice Testing of Valves in Nuclear Power Plant s ," of Sect ion XI of t he ASME Boiler and Pressure Vessnl Code with NRC npproved exceptions.

The ERV is a pilot-operated rolinf valve and, ns such, does not incorporate control air system valves for valvo control. ERV PSV-1000 is clansified as a Category B valvo per Subsection IWV in the SIMS Component Data Ense, pSV-1000 in exercist J and stroke time tested in both open and close directions por Reactot Coolant System Operating Procedure No. 1103.005, Supplement I during plant startup after establishing a pressurizer bubble. This test is pe r formed during cold shutdown conditions in accordance with IWV-3412(n) for Cat.cgory B valves.

Attachment to ICAN129013 Pago 5 The method of strokn time testing of the ERV uses an acoustic monitor which rnquires that the an80cInted block valve be in the open position. This test is not performed in hot standby or hot shutdown conditions. Exercising t.he ERV in hot standby or hot shutdown " prior to establishing condit tons where the 4 PORVs are used for low-temperature overpressure protection" is not considtred

] necessary. Stroke testing of the ERY during cold shaldown conditions in

conaldered to be suf ficient since I. TOP concerns with respect to PORVs do not j opply to ANO 1 (see thn above response to Item 2 of Section 2 of Enclosure A

] to the Concric I,nt ter).

i Illock valve CV-1000 is classified as a Category A valvo per Subsection lWV in a the SlHS Component 1)nta finne. CV-1000 is stroke time tested in the open and 4 closo direct ions once por quarter por Operations Periodic Tests Proceduro No.

j 1305.007, Supplement 1. This valvo 18 lenk tested per Reactor Coolant System Operating Procedure No. 1103.005 Supplomont 2 during hot shutdown conditions, filock valvo CV-1000 is included in the AND Motor Operated Valvo Testing and j- Surveillnnce (H0 VATS) program (Maintenanco Administrative Procedure No.

1025.011) in response to the expanded HOV test program discussed in NRC Concric 1,etter 89-10.

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Attachment to ICAN 1291113 page 6 NRC S t_ a f f_ Pos it ion _3. l et t e m _3 !

For operat ing PWR plants, modi fy the limit ing conditions of opernt: ton of PORVs and block valves in the technical specificntions for Modes 1, 2, and 3 to incorporate the position adopted by the sinff in recent licensing actions.

Attachments A-1 through A-3 are provided for guidance. The stafI recognizes that some recently licensed PWR pinnts already e t echnieni specificnLions in necordance with the staff position. Such ts nre already in complinnce with this position and need merely state the i their response. These recent.

technical specifications require that plants (not run with the block vnives closed (e.g., due to leaking PORVs) maintain electrical power to the block valves so they can be rendily opened from the control room upon demnnd.

Additionally, plant operntion in Modes 1, 2, anci 3 with PORVs and block valves (noperabic for reasons other thnn sent lenkege is not permitted for periods of more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

Arkar sas Nucionr_One-UnitlRosponsol The current ANO 1 Technical Specifications (TS) contnin requirements for low-temperature overpressure protection (LTOP) ns well as requirements for the ERV and associated block valve. TS 3.1.2.9 nnd 3.1.2.10 include requirements to ensure that the core flood tanks and high pressure injection oro not potential sources for pressurir.ing the RCS during bTOP conditions; and TS 3.1.2.11 requires that the plant not be operated in n water solid condition when the RCS pressure boundary is intact to ensure that the RCS is not operated in a manner which would nilow overpressurization due to a tempernture transient.

TS Surveillance Requirements for the ERV flow monitor, block valve posit ion 2ndicator and an LTop nlarm logic (to ensure that the block valve is open when RCS tempernture is reduced to LTOP conditions) nre provided in TS 4.1, Tabic 4.1- 1, i tems 48, 49 nnd 60, respect ively . A Surveillance Requirement to exercise the ERY nt the end of ench refueling outage is provided in TS 4.1 Tnble 4.1-2, item 17.

Since the design of ANO 1 does not rely upon the ERY and associated block vnivo to perform any of the snfety-related functions identified in Section 2 (see the above response to Section 2 of Enclosure A), additionni Technical Speciftent.lons are not. considered necessary.

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