ML17227A549

Reviews Util Submittals Per 901220,911206 & s Responding to Generic Ltr 90-06 & Requests Resubmittal of Util Response Keeping W/Intent of GL Due to Listed Areas of Concern

ML17227A549
Person / Time
Site:	Saint Lucie
Issue date:	08/06/1992
From:	Norris J Office of Nuclear Reactor Regulation
To:	Goldberg J FLORIDA POWER & LIGHT CO.
References
REF-GTECI-070, REF-GTECI-094, REF-GTECI-NI, TASK-070, TASK-094, TASK-70, TASK-94, TASK-OR GL-90-06, GL-90-6, TAC-M77382, TAC-M77383, TAC-M77457, TAC-M77458, NUDOCS 9208140030
Download: ML17227A549 (7)

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555 August 6, 1992 Docket Nos.

50-335 and 50-389 Mr. J.

H. Goldberg President Nuclear Division Florida Power and Light Company P.O.

Box 14000 Juno

Beach, Florida 33408-0420

SUBJECT:

ST.

LUCIE UNITS 1

AND 2 GENERIC LETTER 90-06, "RESOLUTION OF GENERIC ISSUE 70,

'POWER-OPERATED RELIEF VALVE AND BLOCK VALVE RELIABILITY,'NDGENERIC ISSUE 94,

'ADDITIONAL LOW TEMPERATURE OVERPRESSURE PROTECTION FOR LIGHT-WATER REACTORS,'URSUANT TO 10 CFR 50.54(f)"

(TAC NOS.

M77382, M77383, M77457 AND M77458)

By letters dated December 20,

1990, December 6,

1991 and May ll, 1992, you responded to Generic Letter (GL) 90-06.

The GL represented the technical resolution of two generic issues and included plant backfits which were cost-justified safety enhancements.

Generic Issue 70 included upgrades in quality requirements, inservice testing requirements, and modified Technical Specifications (TS) for all pressurized water reactor facilities that incorporate power-operated relief valves (PORVs) and block valves in their design.

The intended purpose was to enhance the overall reliability of the PORVs and block valves so that they could better perform the safety functions identified in the GL.

Generic Issue 94 included modified TS for all Westinghouse and Combustion Engineering facilities to reduce the allowed outage time for an inoperable low temperature overpressure protection (LTOP)

channel, and thus reduce the probability of overpressurization events during shutdown conditions.

We have reviewed your submittals and find that you have modified selected portions of the GL.

It is our position that a regulatory analysis has been performed in accordance with 10 CFR 50. 109(a)(3) and 50. 109(c) which justifies the backfit.

Therefore, absent any information that demonstrates that your facility is not bounded by the regulatory analysis that accompanied the GL, you are requested to resubmit a response that is in keeping with the intent of the GL.

The specific areas of concern are as follows.

1.

Staff Guidance on Mode for 18-Month PORV Stroke Test Our position requires the 18-month PORV stroke test to be performed during Mode 3

(HOT STANDBY) or Mode 4

(HOT SHUTDOWN) and in all cases prior to establishing conditions where the PORVs are used for LTOP.

Your submittal did not adequately meet this staff position.

We are nest accepting Mode 5

(COLD SHUTDOWN) testing simply because it is allowed by the ASME Code or that the NRC-approved Inservice Testing

( IST) program includes Mode 5 for this particular test.

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Hr. J.

H. Goldberg August 6, 1992 The requirement to perform stroke tests of the PORVs during Hodes 3 or 4 is a

new position for some licensees.

The basis for this position lies in the uncertainty introduced by stroke testing the PORVs at lesser system temperature conditions and then expecting them to perform adequately at operating system conditions.

If this recommendation is not adopted, a sound technical basis should be provided (e.g., that such testing cannot be performed without significant system modifications or that the intent of such testing is accomplished by some other means).

We note that one licensee has proposed the option to bench test the PORVs.

This would be acceptable, provided the tests are performed at conditions simulating Hode 3 or 4 conditions or greater and provided the proper reinstallation of the PORVs and controls is verified.

In another

case, we accepted an argument from a licensee that the physical distance

"=etween the PORV and the pressurizer maintained the same temperature at the PORV in Hodes 3, 4, or 5 such that there is no difference from the valve's perspective of testing in different modes.

In this case the facility had an air-operated PORV and was able to perform the PORV stroke test with the block valve closed such that the PORV would be primarily influenced by the ambient room conditions.

Additionally, the GL required that PORVs be stroke tested in all cases prior to establishing conditions where the PORVs are used for LTOP.

This could be interpreted to mean that PORVs should be stroke tested during every shutdown and again during every startup.

However, the inclusion of the PORVs in the IST program requires the valves be tested no more frequently than every 3 months (unless valve maintenance is performed) to demonstrate operability.

In summary, we maintain our position that the PORVs should be stroke tested during Hodes 3 or 4 in order to verify the capability to function in an environment more representative of operating conditions.

In your revised

response, discuss how PORV stroke testing provides assurance that the PORVs will perform all necessary safety functions adequately at the required system operating conditions.

2.

Staff Guidance on PORV and Block Valve TS U

rades Our position for the resolution of Generic Issue 70 required TS upgrades as presented in the GL.

Our review of your submittal indicates that you have declined our position.

We will not accept, without sufficient justification, the position that the TS upgrades are unnecessary because the PORVs are not the primary means of dealing with the three safety functions identified in the GL.

As discussed in NUREG-1316, most of the safety enhancement for the proposed backfit is derived from the increase in feed-and-bleed capability.

Therefore, for those facilities that can accomplish the three safety functions identified in the GL without relying on PORVs for the feed-and-bleed function, the

C Hr. J.

H. Goldberg August 6, 1992 allowed outage time (AOT) for an inoperable PORV (for reasons other than excessive leakage) may be increased from the recommended 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days.

In addition, for those facilities that have three safety-related PORVs and can accomplish the three safety functions and feed-and-bleed with only two, the AOT for one inoperable PORV may be increased to 7 days while the AOT for two inoperable PORVs remains at 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

Therefore, based on the additional guidance provided above, we request that you resubmit your response to the GL.

3.

Staff Guidance on LTOP TS L'ades Our position for the resolution of G-"neric Issue 94 included the TS upgrades as presented in the GL.

Our review determined that you have declined the staff position.

We will not accept, without significant technical justification, statements that the maximum AOT will not support flexible plant operations.

In addition, we will not accept PRA-based arguments to expand AOTs.

Only differences in. plant hardware relative to that assumed in our cost/benefit analysis will be considered.

It is our position that in view of the recently completed regulatory analysis supporting the proposed outage

times, and the uncertainties inherent in PRA analyses, that consideration of PRA-based arguments (which is tantamount to re-opening the issue) is not warranted.

The intent of the resolution of Generic Issue 94 was to decrease the probability of cold overpressurization while in a water-solid condition by increasing the availability of the LTOP system.

Generic Issue 94 did not apply to Babcock

& Wilcox (B&W) facilities because they maintain a nitrogen bubble in the pressurizer and do not operate in a water-solid condition.

Similarly, we would be receptive to extending the recommended 24-hour AOT with an inoperable LTOP channel to 7 days provided the plant is not water-solid.

For such cases, the licensee must identify a pressurizer level which provides a level of protection against cold overpressurization comparable to that provided by the nitrogen bubble in B&W facilities.

Therefore, based on the additional guidance provided above, we request that you resubmit your response to the GL.

We request that you respond within 60 days following receipt of this letter.

If you would like to further discuss these issues prior to your resubmittal, please feel free to contact me.

Nr. J.

H. Goldberg August 6, 1992 The information requested by this letter is within the scope of the overall burden estimated in Generic Letter 90-06 for the resolution of Generic Issue 70 and Generic Issue 94, which was a maximum of 320 person-hours per licensee response.

This request is covered by Office of Management and Budget Clearance Number 3150-0011, which expires Hay 31, 1994.

Sincerely, (Original Signed By) cc:

See next page DISTRIBUTION

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H. Goldberg Florida-Power and Light Company CC:

Jack Shreve, Public Counsel Office of the Public Counsel c/o The Florida Legislature 111 West Madison Avenue, Room 812 Tallahassee, Florida 32399-1400 Senior Resident Inspector St. Lucie Plant U.S. Nuclear Regulatory Commission 7585 S.

Hwy A1A Jensen

Beach, Florida 33457 Hr. Robert G. Nave, Director Emergency Management Department of Community Affairs 2740 Centerview Drive Tallahassee, Florida 32399-2100 Harold F. Reis, Esq.

Newman 3 Holtzinger 1615 L Street, N.W.

Washington, DC 20036 John T. Butler, Esq.

Steel, Hector and Davis 4000 Southeast Financial Center Miami, Florida 33131-2398 Administrator Department of Environmental Regulation Power Plant Siting Section State of Florida 2600 Blair Stone Road Tallahassee, Florida 34982 Hr. James V. Chisolm, County Administrator St. Lucie County 2300 Virginia Avenue Fort Pierce, Florida 34982 Hr. Charles B. Brinkman, Manager Washington Nuclear Operations ABB Combustion Engineering, Nuclear Power 12300 Twinbrook Parkway, Suite 330 Rockville, Maryland 20852 St.

Lucie Plant Mr. Jacob Daniel Nash Office of Radiation Control Department of Health and Rehabilitative Services 1317 Winewood Blvd.

Tallahassee, Florida 32399-0700 Regional Administrator, RII U.S. Nuclear Regulatory Commission 101 Marietta Street N.W., Suite 2900 Atlanta, Georgia 30323 Hr.

R.

E. Grazio Director, Nuclear Licensing Florida Power and Light Company P.O.

Box 14000 Juno

Beach, Florida 33408-0420