ML17159A243
| ML17159A243 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 04/07/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML17159A242 | List: |
| References | |
| NUDOCS 9804100180 | |
| Download: ML17159A243 (9) | |
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SAF VA U UNITED STATES NUCLEAR REGULATORY COMIVIISSION WASHINGTON, D.C. 205554001 CO GU 0
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SUS 0 50-38 I"
The Code o Federal ula', 10 CFR 50.55a, requires that inservice testing (IST) of certain American Society of Mechanical Engineers (ASME) Code Class 1, 2 and 3 pumps and valves be
'erformed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and
'applicable addenda, except where relief has been requested and granted or proposed alternatives have been authorized by the Commission pursuant to 10 CFR 50.55a (f)(6)(l),
(a)(P)(l), or (a)(3)(ii). In proposing alternatives or requesting relief, the licensee must demonstrate that: (1) conformance is impractical for its facility; (2) the proposed alternative provides an acceptable level of quality and safety; or (3) compliance would result in a hardship or unusual difficultywithout a compensating increase in the level of quality and safety.
By letter dated October 17, 1997, Pennsylvania Power and Light Company (the licensee),
submitted a request for relief from certain ASME Code IST requirements pertaining to tests of the Susquehanna Steam Electric Station, Unit 1 (Susquehanna 1),'main steam safety/relief valves (S/RVs). The plant IST program requires that the testing meet the requirements of ASME Code OM-1987, Part 1 (herein referred to as the Code)
~ Specifically, this request seeks relief from performing as-found set pressure tests on all S/RVs within a 5-year period. There are 16 S/RVs installed on the Susquehanna 1 main steam piping and are identified as valves PSV-141F013A, B, C, D, E, F, G, H, J, K, L, M, N, P, R, and S. For these 16 valves, the licensee is requesting relief from the following testing requirement:
OM-1987, Part 1, paragraph 1.3.3.1(b), "Subsequent 5 Year Periods." Allvalves of each type and manufacture shall be tested within each subsequent 5 year period with a minimum of 20% of the valves tested within any 24 months.
This 20% shall be previously untested valves, ifthey exist.
3.0 The licensee states that Susquehanna 1 is scheduled to implement a 24-month fuel cycle after the completion of the upcoming refueling outage in spring 1998, and that continuing to meet the above Code testing requirement, as has been done for previous 18-month fuel cycles, would cause a hardship without a compensating increase in the level of quality and safety. The licensee. states that the plant history for the S/RVs indicates that several leaking valves are required to be replaced, in addition to those selected for testing, and that a total of 8 of the 9804i00i80 980407 PDR ADOCK 05000387 P
PDR ENCLOSURE 16 valves are typically removed and tested (i.e., 5 or 6 valves for the test sample plus approximately 2 or 3 additional leakers) during each outage.
Because the Code requires that the test valve sample be previously untested valves, the licensee projects that more than 8 valves would be required to be removed and tested following a 24-month cycle since all 16 valves (plus any leakers) would be required to be tested within two cycles.
When the facilitywas operating under an 18-month cycle, all valves were required to be tested within three cycles. The licensee states that this creates the possibility of increasing the length of an outage and additional personnel radiation exposure to perform the additional testing during the outage.
The licensee also states that the purchase of additional spare valves would be required since a larger number of valves'would potentially need'to'e removed each'outage.
'Furthermore, the licensee states that the setpoint history of the S/RVs has been good such that there has been infrequent need for testing additional valves when test valve setpoints are found greater than 3% above the nominal values.
4.0 ROPOS A IV SI G
As an alternative to the above Code test requirement, the licensee proposes that the S/RVs be tested such that all valves would be tested within three 24-month fuel cycles (or 6 years) with a minimum of 20% of previously untested valves tested within any one outage.
With the projected number of additional leaking valves which would also require refurbishing, the licensee could then continue to remove and test approximately 8 valves per outage.
Ykulh1DA The staff cannot conclude that meeting the above Code requirement for the 24-month fuel cycle would cause a hardship without a compensating increase in the level of quality and safety.
Meeting this Code requirement would result in approximately the same rate of testing (i.e., the number of valves tested per year) for the 24-month cycle as for the previous 18-month cycle.
Including the number of expected leakers, it would be expected that the number of valves to be removed and tested would increase from approximately 8-per-outage to approximately 11-per-outage.
This would result in 24 valves tested over 4.5 years (for three 18-month cycles) which equates to 5.33 valves per year, compared to 22 valves tested over 4.0 years (for two 24-month cycles) which equates to 5.5 valves per year. Therefore, meeting the above Code 5-year testing requirement does not represent a significant increase in effort beyond that which has been previously performed.
In addition, the purchase of additional spare S/RVs to be used for replacements when installed S/RVs are removed is not an ASME Code requirement.
It is acceptable to reinstall tlie same valves after they are tested or refurbished.
The use of spare valves allows the outage time to be minimized. Therefore, the licensee's purchase of additional spares for inventory does not represent a significant burden, considering the offsetting economies associated with increasing the fuel cycle length from 18 to 24 months.
Lastly, the decision to change from an 18-month to a 24-month fuel cycle is a voluntary decision by the licensee.
However, as discussed below, even though no hardship due to meeting the Code requirement has been found, the staff has also reviewed the licensee's S/RV test results to determine ifthe licensee's proposed alternative testing provides an acceptable level of safety.
The staff reviewed the licensee's as-found S/RV setpoint test results for the time period from initial operation to the present, which comprises 199 data points.
The average of the setpoint drift percentages is -0.721%, which indicates that, in general, the S/RVs tend to drift slightly downward, not upward. The staff also calculated the standard deviation from the average for the data set and determined it to be 1.44%. The data indicates that a significant number of the as-found setpoints were outside the+/-1% tolerance allowed by the plant Technical Specifications (TS). However, most of the points outside the TS tolerance were below-1%, not above+1%,
which results in a slightly downward setpoint drift trend over time. This indicates that for the longer test interval proposed, there is not expected to be a reduced capability of the S/RVs to provide adequate system overpressure protection. Also, there were only 2 data points above the
+3% tolerance allowed by the Code. Another consideration is that with the licensee's proposed alternative testing, ifsetpoints are found above the Code+3% tolerance, at least two additional valves are required to be tested for each valve found above+3%, which would significantly "in'crease th'e rate'of testing'as a corrective rrieasure.
It should also be noted that the Susquehanna 1 TS S/RV (3.4.2) setpoint tolerance is+/-1% and is a more stringent criterion than a TS tolerance of+/-3%, as provided in licensing topical report NEDC-31753P.
(The NEDC-31753P topical report was approved by the NRC in a letter to the BWR Owners Group dated March 8, 1993.)
However, this topical report provides that for an increase in the S/RV TS tolerance to+/-3%, all S/RVs must be tested within 40 months.
Therefore, the staff finds that given that the TS S/RV tolerance is+/-1%, allowing the testing to be extended to three 24-month cycles with a minimum of 20% of previously untested valves tested during any one outage provides an acceptable level of quality and safety.
The staff notes that the acceptance is based on the safety/relief valve setpoint tolerance being +/-1%, and if in the future, this tolerance is revised, the licensee willneed to resubmit the request for relief because the basis for the staff acceptance willhave been changed.
Based on the above evaluation, the staff has determined that, pursuant to 10 CFR 50.55a (a)(3)(i), the proposed alternative may be authorized on the basis that the alternative testing provides an acceptable level of quality and safety.
Principal Contributor:
G. Hammer Date: April 7, 1998
Mr. Robert G. Byram Senior Vice President-Gel%btion and Chief Nuclear Officer
'ennsylvania Power and Ught Company 2 North Ninth Street Allentown, PA 18101 Apri1 1998
SUBJECT:
REQUEST FOR ADDITIONALINFORMATION(RAI) REGARDING QUALITY ASSURANCE PROGRAM CHANGES, SUSQUEHANNA STEAM ELECTRIC STATION (SSES), UNITS 1 AND2 (TAC NOS. M96327 ANDM96328)
Dear Mr. Byram:
By letter dated March 19, 1998, Pennsylvania Power and Ught Company (PP&L) submitted its proposed changes to the Susquehanna Steam Electric Station, Units 1 and 2 (SSES), Quality Assurance (QA) Program.
The QA Program is contained in Chapter 17.2 of the SSES Final Safety Analysis Report (FSAR).
The U.S. Nuclear Regulatory Commission staff is reviewing the March 19, 1998, submittal along with the changes proposed in Revision B of the SSES Improved Standard Technical Specification (ISTS) submitted on March 2, 1998. The staff has determined that additional information is required to complete its reviews. The information that is requested relates to the
'elocation of the administrative controls currently in the Technical Specifications to the FSAR.
The specific information requested is addressed in the enclosure.
The staff requests that the additional information be provided within 30 days of receipt of this letter in order to maintain the current schedule for reviewing the SSES ISTS.
On the basis of this RAI, the staff requests that PP8L refrain from implementing the QA Program changes until the staff provides formal notification of approval.
Ifyou have any questions, please contact me on (301) 415-1484.
Sincerely,
/s/
Victor Nerses, Senior Project Manager Project Directorate 1-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket Nos. 50-387/50-388
Enclosure:
RAI ccw/encl: See next page DISTRIBUTION MO'Brien OGC ACRS S Black LCampbell RGramm CAnderson, RGN-I
'pY OFFICE PDI-2/PM NAME VNe esr'b PDI-
/
MO'en HQMB/C M PDI-2/D SBlack "ST'3 RCa ra DATE
'f /
/98 If398 16 I98 t /~ /98 OFFICIALRECORD COPY DOCUMENT NAME: SU96327.RAI
Mr. Robert G. Byram 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 C'orporate Counsel-"- ----
Pennsylvania Power & Light Company 2'North Ninth Street Allentown, Pennsylvania 18101
,Licensing Group Supervisor Pennsylvania Power & Light Company 2 North Ninth Street Allentown, Pennsylvania I8I01 Regional Administrator, Region I
U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, Pennsylvania 19406 General Manager-Susquehanna Steam Electric Station Pennsylvania Power and Light Company Box 467 Berwick, Pennsylvania 18603 Mr. Herbert D. Wo'odeshick Special Office of the President Pennsylvania Power and Light Company Rural Route 1, Box 1797 Berwick, Pennsylvania 18603 Senior Resident Inspector U. S. Nuclear Regulatory Commission P.O. Box 35 Berwick, Pennsylvania 18603-0035 Director-Bureau of Radiation Protection Pennsylvania Department of Environmental Resources P. O. Box 8469 Harrisburg, Pennsylvania 17105-8469 Mr. Jesse C. Tilton, III Allegheny Elec. Cooperative, Inc.
212 Locust Street P.O. Box 1266 Harrisburg, Pennsylvania 17108-1266 George T.'ones Vice President-Nuclear Operations Pennsylvania Power and Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Dr. Judith Johnsrud National Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803 Chairman Board of Supervisors
?38 East Third Street Berwick, PA 18603
RE UEST FOR ADDITIONALINFORMATION CHANGES TO THE UALITYASSURANCE PROGRAM SUS UEHANNASTEAM ELECTRIC STATION SSES UNITS 1 AND 2 General Comments:
Pennsylvania Power and Light Company (PP&L) has proposed to relocate most of the current Technical Specifications (TSs) administrative controls to Chapter 13 of the Final Safety Analysis Report (FSAR). Future changes to the information in Chapter 13 are controlled under the provisions of 10 CFR 50.59. Nuclear Regulatory Commission (NRC) Administrative Letter 95-06, "Relocation of Technical Specification Administrative Controls Related to Quality Assurance,"
dated December 12, 1996, identified the need to relocate the TS administrative controls to a document controlled in accordance with 10 CFR 50.54(a). -Thus, subsequent changes to these..
relocated TS provisions would be controlled in accordance with 10 CFR 50.54(a).
By relocating several of the TS administrative controls to FSAR Chapter 13, PP&L willnot be controlling future changes to the relocated administrative controls in accordance with 10 CFR 50.54(a) as addressed in NRC Administrative Letter 95-06.
Although several sections of the Quality Assurance (QA) Program contained in FSAR Chapter 17.2 have been revised to reference proposed TS administrative controls relocated to Section 13 of the FSAR, the NRC staff believes that the TS administrative controls proposed by PP8L to be relocated to FSAR Chapter 13 need to be relocated to FSAR Chapter 17,2.
guestions:
1.
In its March 2, 1998, submittal, PP&L proposed relocating the following current TS Sections to the QA Program.
However, the staff's review of the March 19, 1998, letter and attachments indicated that the TS Sections would be relocated to FSAR Chapter 13. Provide PP8L's basis for relocating the following items to Chapter 13 and how future changes will be controlled per 10 CFR 50.54(a):
a.
Current TS 6.5.1, "Plant Operations Review Committee," has been relocated to FSAR Section 13.4.1.
b.
Current TS 6.5.2, "Susquehanna Review Committee (SRC)," has been relocated to FSAR Section 13.4.2.
Additionally, current TS 6.2.5.10.b does not appear to have been located to either Chapter 13 or Chapter 17.2. FSAR Section 13.4.2.3 also contains a provision for the use of Susquehanna Review Committee (SRC) Sub-Committees but no guidance is provided for the qualifications of subcommittee members (e.g., ANSI N3.1-1981, Section 4.7) or the subcommittee chairman (e.g., must be an SRC committee member).
The use of SRC subcommittees is not contained in current TS 6.5.2.
Provide a discussion regarding the need to incorporate this information.
c.
Current TS 6.5.3, "Technical Review and Control Activities," has been relocated to FSAR Section 13.4.1.4.1
~
Further, in the proposed relocation, the scope of the technical review activities in Section'3.4.1.4.1 failed to address all of the current TS review requirements for all of the procedures and programs required by existing TS Section 6.8. Specifically, the proposed Insert B to FSAR Section 13.4.1.4.1 makes reference to the procedures and programs ENCLOSURE Identified in FSAR Subsection 13.4.1,3.
However, PP&L failed to address in FSAR Section 13.4.1.3 the fact that certain types of procedures and programs should be subject to the technical review process (as presently required by current TS 6.5.3 by reference to existing TS Section 6.8): Current TS Section 6.8.1, Items b, c, d, e, g, and h, have not been relocated to FSAR Section 13.4 nor any other section In FSAR Chapter 13 or Chapter 17.2.
Provide a discussion regarding where these requirements willbe relocated and addressed.
Also, in proposed Insert B for FSAR Section 13.4.1.4.1, reference is made to Section 4.4
.of ANSI/ANS 3.1-.1 993. Current TS Section.6.5.3 requires.,that these, individuals. be....
qualified to ANSI N18.1-1971
~ Provide the basis forthis change.
d.
Although current TS Section 6.8.2 has been relocated to the QA Program, portions are being relocated to FSAR Section 13.4.1.4.
Further, some portions of the existing Section 6.8.2 have not been addressed in FSAR Section 13. Provide the basis for deleting these requirements.
e.
Current TS Section 6.8.3 has been relocated to FSAR Section 13.4.1.4.
2.
Current TS Section 6.13, "Process Control Program (PCP)," is being deleted.
The staff believes that this should not be deleted but rather relocated to the QA Program.
Discuss any basis for not relocating this section.
3.
PP&L proposed to revise current TS Section 6.8.1 to conform with the provisions of NUREG-1433, Revision 1. In complying with the NUREG, PP&L proposed to delete existing items 6.8.1b, c, d, e, g, and h. Although this deletion does not affect the TSs, it does affect other FSAR sections where review activities of certain programs and procedures are required.
Provide a description of how these other review activities willbe maintained.
4.
On page 2 of the March-19, 1998, letter. PP&L states the following:
\\
Finally, be advised that other licensing actions are expected to impact these sections of the FSAR. Examples are described in the following correspondence:
l Reference 2 describes FSAR/QA changes related to NSAG, in response to a Notice of Violation.
Reference 3 describes FSAR/QA changes related to the quality assurance organization and the qualifications of the quality assurance manager.
Provide additional information which identifies any impact that resolution of the violations in Reference 2 may have on the relocated TS administrative controls.
NRC Comment Not Re uirin a PP&L Res onse:
The staff feels that the changes in Reference 3, when processed, should reflect an exception to ANSI 18.1 by indicating that for the qualiTications of the QA Manager, the provisions of Section 4.4.5 ofANSI 3.1-1978 may be used In lieu ofANSI N18.1-1971.
Ifthe QA manager is considered part of the Unit Staff, it appears that PPSL needs to also reflect this exception in new TS Section 5.3.1.