ML17157C096
| ML17157C096 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 11/25/1992 |
| From: | Calvo J Office of Nuclear Reactor Regulation |
| To: | Kaiser H PENNSYLVANIA POWER & LIGHT CO. |
| References | |
| NUDOCS 9212070105 | |
| Download: ML17157C096 (6) | |
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Docket No. 50-388 UNITED STATES NUCLEAR REGULATORY COIVIIVIISSION WASHINGTON, D.C. 20555 November 25, 1992 Mr. Harold W. Kaiser Senior Vice President-Nuclear Pennsylvania Power and Light Company 2 North Ninth Street Allentown, Pennsylvania 18101
Dear Mr. Kaiser:
SUBJECT:
REQUEST FOR EXTENSION OF TEMPORARY WAIVER OF COMPLIANCE FROM TECHNICAL SPECIFICATION 3.3.2, ACTION B, FOR SUSQUEHANNA STEAM ELECTRIC STATION, UNIT NO.
2 This letter describes actions taken by the NRC staff in considering two requests to extend a waiver of compliance from Technical Specification (TS)
Action Requirement 23 of Table 3.3.2-1 which is referenced in TS 3.3.2, Action b, footnote (*) (TS 3.3.2, Action b) that had been previously granted by the; staff on November 17, 1992.
Approval for the previous waiver is documented in a letter from the NRC to Pennsylvania Power and Light (PP8L) dated November 18, 1992.
The waiver was requested to allow restoration of the Reactor Water Cleanup (RWCU) system to operation with the "B" RWCU Flow-High isolation channel inoperable while trouble shooting activities were performed.
By letter dated November 20,
- 1992, PP8L requested an extension of the waiver to allow continued operation of the RWCU system with the "B" RWCU channel inoperable while the licensee prepared a TS change request that would permanently delete operability requirements for the RWCU Flow-High isolation channels and while the NRC considered such a request.
In the waiver extension
- request, the licensee addressed the safety significance of operating with an inoperable "B" RWCU Flow High channel and described the compensatory actions that would be implemented for the duration of the waiver.
The licensee stated that the remaining RWCU isolation functions, including the "A" RWCU Flow-High
- channel, were believed to provide diverse and redundant methods for detecting and isolating= the appropriate range of pipe leaks and pipe breaks.
During discussions with PP8L on November 20, 1992, prior to submission of the written waiver extension
- request, the staff. requested that the licensee confirm that diverse and redundant leak detection and isolation capability was available for all sections of the RWCU system.
The staff requested that PPRL include such confirmation in the TS change request.
Based on discussions between the staff and PP8L on November 20,
- 1992, concerning overall leak detection and isolation capability and your proposed compensatory
- actions, the NRC verbally granted the licensee's request to extend the waiver of the requirements of TS 3.3.2, Action b, for the "B" RWCU Flow-High.isolation 04ooss 92i2070i05 92ii25 PDR ADQCK 05000388 P
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Mr. Harold W. Kaiser November 25, 1992 channel until the staff received and reviewed the permanent TS change request.
In granting the extension, the staff noted that if at any time, while the waiver was in effect, additional RWCU isolation instrumentation became inoperable or staff review of the TS submittal failed to support issuance of a TS amendment, the waiver would expire and the licensee would be subject to the full requirements of the license.
During a more detailed evaluation of the adequacy of leak detection for the entire length of RWCU piping PP8L determined that without the RWCU Flow-High isolation, certain portions of the RWCU system in the Filter Demineralizer Room and Main Steam Tunnel did not have the same fully diverse and redundant leak detection and isolation capability as originally believed.
Specifically, portions of system piping downstream of the RWCU return High Differential Flow instrument taps were not covered by Area Temperature, Area Differential Temperature, or High Differential Flow RWCU isolation features.
The licensee relayed this information to the staff on November 23, 1992.
After consideration of this additional information, the staff determined that the basis for extending the waiver on November 20,
- 1992, was diminished and retracted the waiver extension.
This subjected the licensee to the full requirements of TS 3.3.2, Action. b, for the "B" RWCU Flow-High isolation channel.
'P Subsequent to the notification by the NRC that the November 20, 1992, waiver:.
extension had been retracted, the licensee informed the staff that they were" making preparations to perform the TS required isolation of the RWCU system.
The licensee indicated they had additional justification for reinstating the waiver extension and proposed a teleconference that same afternoon to present it.
In recognition that isolation of the RWCU system would induce an undesired transient on the plant, the staff orally waived the requirements of TS 3.3.2, Action b, for an additional hour pending presentation of the additional justification.
During the subsequent teleconference on November 23,
- 1992, the licensee again requested extension of the November 17, 1992, waiver and provided additional technical justification.
This verbal request was followed by a written request on November 24, 1992.
PP8L noted that the portions of system piping not covered by specific RWCU safety related isolation functions were afforded some level of leak detection and isolation function by other detection systems.
High Area Temperature and High Differential Temperature instrumentation is provided for the Main Steam Pipe Tunnel and provides additional indication of an RWCU break in this area.
In the justifying arguments, the licensee indicated that these area temperature indications provide a basis for operators detecting, investigating and manually isolating the RWCU system in the event of an RWCU pipe break in this area.
The licensee also noted that a break of the RWCU system piping in the Main Steam Tunnel or Filter Demineralizer room would eventually cause an isolation of the RWCU system on a low reactor water level signal.
Mr. Harold W., Kaiser November 25, 1992 In addition; the -licensee described the Non-Regenerative Heat Exchanger (NRHX) outlet high temperature function as providing further isolation capability for RWCU breaks in the Main Steam Tunnel and the Filter Demineralizer Room.
The NRHX outlet high temperature isolation is a nonsafety related feature designed to protect the filter demineralizer resins from the effects of high process fluid temperature.
PPRL indicated that a
NRHX outlet high temperature isolation would be initiated if RWCU system flow increased due to a leak rate that is bounded by the RWCU Flow-High setpoint as would be the case for RWCU system ruptures downstream of the NRHX outlet temperature element.
The NRHX outlet high temperature isolates the outboard RWCU isolation valve.
It was confirmed during the telecon that the operable "A" RWCU Flow-High channel isolates the inboard isolation valve.
Finally, the licensee indicated that the RWCU piping in the Filter Demineralizer room and Main Steam Tunnel is 4" ASME Section III Class 2 SA-106 Grade B Seamless Carbon piping and was, therefore, resistant to Intergranular Stress Corrosion Cracking (IGSCC).
The staff considered PP8L's additional justifications and determined that they provided adequate compensatory leak detection and isolation protection, provided that the NRHX outlet high temperature feature was controlled in a
manner consistent with the TS requirements for the RWCU Flow-High isolation function.
Specifically, the NRHX outlet high temperature function should have the same operability, action, action time and surveillance requirements as the RWCU Flow-High function.
By letter dated November 24,
- 1992, PPKL committed to controlling the NRHX outlet High Temperature isolation as described above while the "B" RWCU Flow-High channel remained inoperable.
In addition, the licensee committed to requesting a temporary TS change incorporating the additional requirements on the NRHX outlet High Temperature isolation function and allowing operation of the RWCU system with the "B" RWCU Flow-High isolation channel inoperable by November 30, 1992.
In that letter, PPKL also documented the revised request for a waiver extension presented orally on November 23, 1992.
Based on the technical and safety discussion described
- above, I verbally granted your waiver extension request on November 23, 1992, at 5:00 p.m.
The waiver extension allows continued operation of the RWCU system with the "B" RWCU Flow-High isolation function inoperable provided PPKL applies the TS controls on. the NRHX Outlet High Temperature isolation function and provides the additional guidance to operators committed to in the November 24,
- 1992, letter.
The. waiver is to remain in effect while the staff reviews PP8L's application for a temporary TS change to incorporate the additional
Hr. Harold W. Kaiser November 25, 1992 requirements on the NRHX Outlet High Temperature isolation, which the licensee committed to submit by November 30, 1992.
If at any time during the review of the TS change request, the staff determines that the proposed change is not supportable, the waiver will be terminated and PPRL will be subject to the full requirements of the license as it pertains to the RWCU Flow-High isolation function.
Sincerely,
/S/
Jose A. Calvo, Assistant Director for Region I Reactors Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation cc:
See next page, Distribution
~Docket Fil.eg NRC/Local PDR PDI-2 R/F T. Hurley F. Hiraglia J. Partlow S.
Varga J.
Calvo C. Hiller P. O'rien R. Clark OGC D. Hagan G. Hill (4)
W. Jones C. Grimes ACRS (10)
OPA OC/LFDCB B. Norris J.
Lieberman, OE H. Boyle C. Hehl, RI J.
Shea C. HcCracken E. Wenzinger
. J. White LA:PDI-2 POBrien ~
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Hr. Harold W. Kaiser November 25, 1992 requirements on the NRHX Outlet High Temperature isolation, which the licensee committed to submit by November 30, 1992.
If at any time during the review of the TS change request, the staff determines that the proposed change is not supportable, the waiver will be terminated and PP8L will be subject to the full requirements of the license as it pertains to the RWCU Flow-High isolation function.
cc:
See next page Sincerely,'. c.:&-
Jose A. Calvo, Assistant Director for Region I Reactors Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation
Mr. Harold W. Keiser Pennsylvania Power
& Light Company Susquehanna Steam Electric Station, Units 1
& 2 CC:
Jay Silberg, Esq.
- Shaw, Pittman, Potts
& Trowbridge 2300 N Street N.W.
Washington, D.C.
20037 Bryan A. Snapp, Esq.
Assistant Corporate Counsel Pennsylvania Power
& Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Mr. J.
M. Kenny Licensing Group Supervisor Pennsylvania Power
& Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Mr. Scott Barber Senior Resident Inspector U. S. Nuclear Regulatory Commission P.O.
Box 35 Berwick, Pennsylvania 18603-0035 Mr. Thomas M. Gerusky, Director Bureau of Radiation Protection Resources Commonwealth of Pennsylvania P. 0.
Box 2063 Harrisburg, Pennsylvania 17120 Mr. Jesse C. Tilton, III Allegheny Elec. Cooperative, Inc.
212 Locust Street P.O.
Box 1266 Harrisburg, Pennsylvania 17108-1266 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, Pennsylvania 19406 Mr. Harold G. Stanley Superintendent of Plant Susquehanna Steam Electric Station Pennsylvania Power and Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Mr. Herbert D. Woodeshick Special Office of the President Pennsylvania Power and Light Company Rural Route 1,
Box 1797 Berwick, Pennsylvania 18603 Mr. Robert G.
Byram Vice President-Nuclear Operations Pennsylvania Power and Light Company 2 North Ninth Street Allentown, Pennsylvania 18101