ML17174A805

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Informs That NRC Does Not Consider Use of Nominal Reactor Pressure in design-basis Reviews for HELB MOVs to Be Consistent W/Util Commitments Re Generic Ltr 89-10,per Open Item Noted in Insp Repts 50-237/91-11 & 50-249/91-10
ML17174A805
Person / Time
Site: Dresden, Quad Cities, LaSalle  Constellation icon.png
Issue date: 07/19/1991
From: Miller H
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Reed C
COMMONWEALTH EDISON CO.
Shared Package
ML17174A806 List:
References
GL-89-10, NUDOCS 9107240137
Download: ML17174A805 (3)


See also: IR 05000237/1991011

Text

Docket No. 50-237

Docket No. 50-249

JUL l 9 1991

Commonwealth Edison Company

ATTN:

Mr. Cordell Reed

Senior Vice President

Licensing Department-Suite 300

Opus West III

1400 Opus Place

Downers Grove, IL

60515

Dear Mr. Reed: *

SUBJECT:

DETERMINATION IF BRANCH TECHNICAL POSITION (BTP)

SPLB* (ASB) 3-1 IS APPLICABLE FOR SIZING MOTOR-OPE~TED

VALVES FOR GENERIC LETTER 89~10

During a recent inspection of the program implemented by

Commonwealth Edison Company's (CECo) Dresden Station to address

Generic Letter (GL) 89-10, "Safety Related Motor-operated Valve

(MOV) Testing and Surveillance," Region III *inspectors identi.fied

a concern with respect to the worst-case differential pressure

(dp) for which a MOV is to operate against (Open Item

50-237/91011-01; 50-249/91010-01).

In GL 89-10, the NRC staff requested licensees to review and

document the design basis for the operation of each MOV within

the scope o( the generic letter program .. The .purpose of the

design basis review is to determine the worst case dp and pther

conditions for both normal operations and abnormal conditions

where MOVs are required to operate.

Following the determination

  • of the maximum (or worst case) dp, a review is conducted to

select and set the MOV switches and to ensure that the MOV is

capable of operating under worst-case conditions.

Since GL 89-10 requests licensees to review the design basis to

determine the worst case dp and then size MOVs to ensure their

operability, this process should be completed for MOVs used to

isolate a high energy line break (HELB).

These MOVs normally

consist of valves in High Pressure Coolant Injection (HPCI),

Reactor Core Isolation Cooling (RCIC), Isolation.condenser steam

supply lines, and Reactor Water Cleanup (RWCU) lines, whose

function is to isolate during a pipe break.

Performing a design basis review for HELB MOVs as requested by GL 89-10 would lead a licensee to determine the pressure at which a

pipe break would occur and to subsequently size the MOV to ensure

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its capability to operate against the assumed pressure.

The

pressure for which a HELB is assumed to occur then becomes

critical for ensuring an MOV is sized properly.* If a lower

pressure is assumed than the point at which a pipe break actually

occurred, an MOV may not have been adequately sized for closure.

During the inspection at Dresden Station, Region III inspectors

noted that CECo used BTP SPLB (ASB) 3-1 to obtain guidance for

determining the pressure that could be assumed for calculating

the worst case dp that would be seen by an MOV during a high

energy line break.

The NRC staff has reviewed CECo's reliance on BTP SPLB (ASB) 3-1

in assuming nominal reactor pressure for design-basis reviews of

MOVs in the GL 89-10 program.

BTP ASB 3~1 was intended to

address the protection of plant equipment from the dynamic

effects of pipe breaks and harsh environments resulting from pipe

breaks.

This BTP was not.written for developing MOV design

bases, and the assumptions used for the development of this BTP

are not applicable for GL 89-10.* Through GL 89-10, the NRC staff

is requesting licensees to verify tnat .MOVs within the scope of

the generic letter are capable of performing their intended

functions under worst case dp and other conditions.

Assuming

nominal reactor pressure will not demonstrate that the MOVs in

question are capable of isolating a break initiated at maximum

reactor pressure.

Qualifying MOVs to operate under nominal

rather than maximum dp and flow conditions will limit the

scenarios for which the MOVs are required to operate to only

certain events and reduces the options available to plant

operators during abnormal plant conditions.

Therefore, NRC does not consider the use of nominal reactor

pressure* in design-basis reviews for HELB MOVs to be consistent

with the CECo commitments regarding GL 89-10.

CECo should assume

maximum reactor pressure in its determination of the worst case

dp for an MOV in a pipe directly connected with the reactor

vessei.

With the maximum reactor pressure (i.e., lowe~t relief

valve setpoint pressure) as a starting point, the dp across the

valve should be calculated by considering factors such as losses

in the piping.

Commonwealth Edison Company

3

Should you have any questions concerning this letter, please*

contact Mr. Marc Huber of my staff at FTS 388-5789.

Sincerely,

ORt.GINAL SIGNED BY HUBERT J. MILLER

H. J. Miller, Director

Division of Reactor Safety

cc:

D. Galle, Vice President,

BWR Operations

T. Kovach, Nuc.lear Licensing

Mariager

E. D. Eenigenburg, station

Manager

DCD/DCB (RIDS)

OC/LFDCB

J. Zwolinski, NRR

B. Siegel, NRR

~. *

T. Scarbrough, NRR

v.6

Resident Inspectors-Dresden,

LaSalle, Quad Cities

Richard Hubbard

J. w. Mccaffrey, Chief

Public Utilities Division

Robert Newmann, Office o.f Public

Counsel, State of Illinois

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