ML17258A433
| ML17258A433 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 12/15/1981 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | Maier J ROCHESTER GAS & ELECTRIC CORP. |
| References | |
| TASK-2.E.4.2, TASK-B-24, TASK-B-24-.2, TASK-OR, TASK-TM LSO5-81-12-041, LSO5-81-12-41, NUDOCS 8201150221 | |
| Download: ML17258A433 (19) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 C
PDR LPDR TERA NSIC ORB ~6 RF GLainas TWambach RSnaider JLyons
Dear Mr. Maier:
December 15, 1981 Docket Ho. 50-244 ON:
HSmith (2)
LS05-81-12-041 Docket ACRS (10)
BScharf GDeegan tir. John E. Maier, Vice President OIaE (3
Electric and Steam Production OELD Rochester Gas and Electric Corporation AWang
'9 East Avenue Xtra Cy Rochester, New York 14649 WButl'er EReeves DShum WPasedag
SUBJECT:
CONTAINtIENT PURGIH3/VENTING DURING NORttAL PLANT OPERATION (TMI II.E.4.2)
R. E. GIHNA Recpg,.
OEggam
. 3, 4'ig In our letter of November 29, 1978, we identified the generic concerns
. of purging and venting of containments to all operating reactor licensees and requested your response to these concerns.
Our review of your response was interrupted by the TMI accident and its'demands on staff resources.
Conse'quently, as you know, an Interim Position on containment purging and venting was transmitted to you on October 23, 1979.
You were requested to implement short-term corrective actions to remain in effect pending completion of our longer-term review of your response to our November 29, 1978 letter.
We are aware that you had installed mechanical travel stops to limit travel of the, purge valves to 50'pen, thus meeting our Interim Position.
In
- June, 1981 you determined that the valves will remain closed unless purging
's necessary for con'tainment entry for safety-related reasons.
Although your letter dated October 31, 1981 concluded, based on recent analysis,
~ that limiting opening to 40'ould assure integrity, th'is 'restriction (valves remaining closed) should remain in effect until valve qualifica-tion analyses are reviewed by us.
Over the past several months we and our contractors have been reviewing the responses to our November 1978 letter to complete our long-term review of this rather complex.issue.
The components of this review are as follows:
t 1.
Conformance With Standard Review Plan Section 6.2.4 Revision 1 and rane ec n>ca osltson evssson These documents were provided as enclosures to our November 1978 1 etter.
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Mr. John E. Maier December 15, 1981 2.
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Valve Operability Although the Interim Position allowed blocking of the valves at partial-open positions, this is indeed an interim position.
Ear-lier we requested a program demonstrating operability of the valves in accordance with our "Guidelines for Demonstrative Operability of Purge and Vent Valves".
These Guidelines were sent to you in our letter of September 27, 1979.
There is an acceptable alternative which you may wish to consider in lieu of completing the valve qualification program for the large butterfly-type valves.
This would be the installation of a fully-qualified (operability and environmental qualification) mini -purge system with valves 8-inches or smaller to bypass the larger valves.
Such a system change might prove more timely and more cost-effective.
The system would meet BTP CSB 6-4 Item B.l.c.
Safety Actuation Si nal Override This involves the review of safety actuation signal circuits to ensure that overriding of one safety actuation signal does not also cause the bypass of any other safety actuation signal.
Containment Leaka e Due to Seal Deterioration Position B.4 of the BTP CSB 6-4 requires that provisions be made to test the availability of the isolation function and the leakage rate of the isolation valves in the vent and purge lines, individually, during reactor operations.
But CSB 6-4 does not explain when or how these tests are to be performed.
Enclosure 1 is an amplification of Position B.4 concerning these tests.
The status of our long-term review of the above items for the Ginna facility is as follows:
Conformance With Standard Review Plan Section 6.2.4 Revision 1 and rane ec naca osition B
evss on This item is still under review.
Since it appears that there may be some misunderstanding regarding the use of containment purge/
vent valves, a restatement of salient features of the position as interpreted by the staff is provided in Enclosure 2 to assist you in understanding subsequent correspondence on this item from the staff.
Additional information which we need to complete our review is requested in the Draft Safety Evaluation Report, which is Enclosure 3.
Please respond within 45 days of receipt of this letter.
Mr. John E. Maier w 3 2.
Valve 0 erability This item is still under review.
Your letter dated June 16, 1981, stated that completion of the analyses is scheduled to allo>]
delivery of a final report to the NRC by December 31, 1981 Safety Actuation Signal Override This item is still under review.
A final Safety Evaluation Report incorporating Systematic Evaluation Program review of this issue will be sent to you shortly.
4.
Containment Leaka e Due to Seal Deterioration We request that you propose a Technical Specification change incorporating the test requirements together with the details of your proposed test program within 60 days of receipt of this letter.
In closing, you may have noted the similarity of this long-term generic issue with Item II.E.4.2 of NUREG-0737, TMI Action Plan.
Except for Positions 5, 6
8 7 of Item II.E.4.2, the review of the remaining out-standing positions of Item II.E.4.2 will be completed by this purge and vent review.
Our schedule of the purge and vent review agrees with the schedule for Item II.E.4.2.
Thus, your assistance in completing the outstanding purge and vent items, noted above, is necessary to complete Item II.E.4.2.
Although the Technical Specifications necessary to complete the purge and vent part of Item II.E.4.2 are not finalized, a recently-developed sample Technical Specifi-cation is provided for your consideration as Enclosure 4.
We request that you review existing Technical Specifications (TS) against the sample provided herein.
For any areas in which your existing TS needs expansion, you are requested to provide a TS change request within 90 days of receipt of this letter.
Please contact your NRC Project Manager should you have any questions.
Sincerely,
Enclosures:
As s Dennis M. Crutchfield, Chief Operating Reactors Branch ¹5 Division of Licensing OFFICE IP SURNAME/
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Mr. John E. Maier December 15, 1981 2.
Valve Operability This item is still under review.
Your letter dated June 16,
- 1981, stated that completion of the analyses is scheduled to allow delivery of a final report to the NRC by December 31, 1981.
3.
Safety Actuation Si nal Override This item is still under review.
A final Safety Evaluation Report incorporating Systematic Evaluation Program review of this issue will be sent to you shortly.
4.
Containment Leakage Due to Seal Deterioration We request that you propose Technical Specification changes incor-porating the test requirements set forth in Enclosure 1 together with the details of your proposed test program.
If the results of current and past surveillance and operating experience are believed to demonstrate leak tightness of those valves, provide this infor-mation as justification for not modifying the surveillance require-ments.
In closing, you may have noted the similarity of this long-term generic issue with Item II.E.4.2 of NUREG-0737, TMI Action Plan.
Except for Positions 5,
6 8
7 of Item II.E.4.2, the review of the remaining out-standing positions of Item II.E.4.2 will be completed by this purge and vent review.
Our schedule of the purge and vent review agrees with the schedule for Item II.E.4.2.
Thus, your assistance in completing the outstanding purge and vent items, noted above, is necessary to complete Item II.E.4.2.
Although the Technical Specifications necessary to complete the purge and vent part of Item II.E.4.2 are not finalized, a recently-developed sample Technical Specifi-cation is provided for your consideration as Enclosure 4.
We request that you review existing Technical Specifications (TS) against the sample provided herein.
For any areas in which your existing TS needs expansion, you are requested to provide a TS change request within 90 days of receipt 'of this letter.
Please contact your NRC Project Manager should you have any questions.
Sincerely, Dennis M. Crutchfield, Chief Operating Reactors Branch ¹5 Division of Licensing
Enclosures:
As stated
Mr. John E. Maier 4
December 15, 1981 cc w/enclosures:
Harry H. Voigt, Esquire LeBoeuf Lamb Leiby and MacRae 1333 New Hampshire Avenue, N.
W.
Suite 1100 Washington, D. C.
20036 Mr. Michael Slade 12 Trailwood Circle Rochester, New York 14618 Ezra Bialik Assistant Attorney General Environmental Protection Bureau New York State Department of Law 2 World Trade Center New York, New York 10047 Resident Inspector R. E. Ginna Plant c/o U. S.
NRC 1503 Lake Road
- Ontario, New York 14519 Director, Bureau of Nuclear Operations State of New York Energy Office Agency Building 2 Empire State Plaza
- Albany, New York 12223 Rochester Public Library 115 South Avenue Rochester, New York 14604 Supervisor of the Town of Ontario 107 Ridge Road West
- Ontario, New York 14519 U. S. Environmental Protection Agency Region II Office ATTN:
Regional Radiation Representative 26 Federal Plaza New York New York 10007 Herbert Grossman, Esq.,
Chairman Atomic Safety and Licensing Board U. S. Nuclear Regulatory Cormission Washington D. C.
20555 Dr.
Emmeth A. Luebke Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Dr. Richard F. Cole Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C.
20555
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~
Enclosure 1
PURGE/VENT VALVE LEAKAGE TESTS The long term resolution of Generic Issue B-24, "Containment Purging During Normal Plant Operation," includes, in part, the implementation of Item B.4 of Branch Technical Position (BTP)
CSB 6-4.
Item 8.4 specifies that provisions should be made for leakage rate testing of the (purge/vent system) isolation valves, individually, during reactor operation.
Although Item B.4 does not address the testing frequency, Appendix J to 10 CFR Part 50 specifies a maximum test interval of 2 years.
As a result of the numerous reports on unsatisfactory performance of the resilient seats for the isolation valves in containment purge and vent lines (addressed in OIE Circular 77-11, dated September 6, 1977), Generic Issue B-20, "Containment Leakage Due to Seal Deterioration,"
was established to evaluate the matter and establish an appropriate testing frequency for the isolation valves.
Excessive leakage past the resilient seats of isolation valves in purge/vent lines is typically caused by severe environmental con-ditions and/or. wear due to frequent use.
Consequently, the leakage test frequency for these valves should be keyed to the occurrence of severe environ-mental conditions and the use of the valves, rather than the current require-ments of 10 CFR 50, Appendix J.
It is recommended that the following provision be added to the Technical Specifications for the le+ testing of purge/vent line isolation valves:
".Leakage integrity tests shall. be performed on the containment isolation valves with resilient material seals in (a) active purge/vent systems (i.e., those which may be. operated during plant operating Modes 1 through 4) at least once every three months and (b) passive purge systems (i.e.', those which must be administratively controlled closed during reactor operating Modes 1 through 4) at least once every six months."
C By way of clarification, the above proposed surveillance specification is predicated on our expectation that a plant would have a need to go to cold shutdown several times a year.
To cover the possibility that this may not occur, a maximum test interval of 6 months is specified.
However, it is not our intent to require a plant to shut. down just to conduct the valve leakage integrity tests.
- If licensees anticipate 1'ong duration power oper-ations with infrequent shutdown, then insgallation of a leak test connection that:i's accessible from 'outside containment may be appr'opriate.
This will permit simultaneous testing of the redundant valves. It will not be possible to satisfy. explicitly the guidance of Item B.4 of BTP CSB 6-4 (which states that valves should be tested individually), but at least some testing of the valves during reactor operation will be possible.
~
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It is intended that the above proposed surveillance specification be applied to the active purge/vent lines, as well as passive purge lines:
i.e., the purge lines that are, administratively controlled closed during reactor oper-ating modes 1-4.
The reason for including the passive purge lines is that 8-20 is concerned with the potential adverse effect of seasonal weather con-ditions on the integrity of the isolation valves.
Consequently, passive pur urge lines must also be included in the surveillance program.
The purpose of the leakage integrity tests of the isolation valves in the containment purge and vent lines is to identify excessive degradation of the resilient seats for these valves.
Therefore, they need not be conducted with the precision required for the Type C isolation valve tests in 10 CFR Part 50, Appendix J.
These tests would be performed in addition to the quantitative Type C tests required by Appendix J and would not relieve the licensee of the responsibility to conform with the requirements of Appendix J.
In view of the wide variety of valve types and seating materials, the acceptance criteria for such tests should be developed on a plant-specific.
basis.
Mr. John E. Mafer 0 3 W
December 15, 1981 2.
Valve Operability This item is still under revfev.
Your letter dated June 16, 1981, stated that completion of the analyses fs scheduled to allover delivery of a final report to the NRC by December 31, 1981.
3.
Safety Actuation Sf nal Override This item fs still under review.
A final Safety Evaluation Report incorporating Systematic Evaluation Program review of this issue will be sent to you shortly.
4.
Containment Leakaqe Due to Seal Deterioration We request that you propose Technical Specification changes incor-porating the test requirements set forth in Enclosure 1 together with the details of your proposed test program.
If the results of current and past surveillance and operating experience are believed to demonstrate leak tightness of those valves, provide this infor-matfon as justification for not modifying the surveillance require-ments.
In closing, you may have noted the similarity of this long-term generic issue with Item II.E.4.2 of NUREG-0737, TMI Action Plan.
Except for Positions 5, 6 8 7 of Item II.E.4.2, the review of the remaining out-standing positions of Item II.E.4.2 will be completed by this purge and vent review.
Our schedule of the purge and vent review agrees with the schedule for Item II.E.4.2.
Thus, your assistance in completing the outstanding purge and vent items, noted above, fs necessary to complete Item II.E.4.2.
Although the Technical Specifications necessary to complete the purge and vent part of Item II.E.4.2 are not finalized, a recently-developed sample Technical Specifi-cation is provided for your consideration as Enclosure 4.
'We request that you review existing Technical Specifications (TS) against the sample provided herein.
For any areas in which your existing TS needs expansion, you are requested to provide a TS change request within 90 days of receipt of this letter.
Please contact your NRC Project Manager should you have any questions.
Sincerely,
- SEE AT, ORIGINAL SIGNED BY THOMAS V.
WAMBACH FOR Dennis M. Crutchfield, Chief Operating Reactors Branch ¹5 Division of Licensing ffED YELLOW FOR PREVIOUS CONCURRENCE OFFICE/
SURNAME/
DATEI nc osures:
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1.
Purging/venting should be minimized during reactor operation because the plant is inherently safer with closed purge/vent valves (containment) than with open lines which require valve action to provide containment.
(Serious consideration is being given to ultimately requiring that future plants be designed such that purging/venting is not required during operation).
2.
Some purging/venting on current plants will be permitted provided that:
a) purging is needed and justified for safety purposes, and b) valves are judged by the staff to be both operable and
- reliable, and c) the estimated amount of radioactivity released during the time'required to cloM '+he valve(s) following a LOCA either does not. cause the total dose to exceed the 10 CFR Part.
100 Guidelines; then a goal should be established which represents a limit on the annual hours of purging expected through each particular valve, or ii. causes the total dose to exceed the guideline values; then purging/venting shall be limited to 90 hour0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br />s/year.',
Purging/venting should not be permitted when valves are being
(
used that are known to be not operable or reliable under transient or accident conditions.
gPR RE0I, (4
o UNITED STATES Enclosure 3
NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 DRAFT SAFETY EVALUATION REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION CONTAINMENT PURGING AND VENTING DURING NORMAL OPERATION ROCHESTER GAS AND ELECTRIC CORPORATION R. E.
GINNA NUCLEAR POWER PLANT DOCKET NO. 50-244 INTRODUCTION A nunber of events have occurred over the past several gears which directly relate.to.the practice of containment purging and venting during normal plant operation.
These events have raised concerns re'lative to potential failures affecting the purge penetrations which could lead to degradation in containm nt integrity, and, for PNRS, a degradation in ECCS performance.
By letter
. dated NoveIIIber 28,
- 1978, the CoIImiission (NRC) requested all licensees of operating reactors to respond to certain generic concerns about containment purging or'enting during normal plant opera-tion.
The generic.concerns were twofold:
{1)
Events had occurred where licensees overrode or by-passed the safety actuation isolation signals to the containment isolation valves.
These events were determined to be abnormal occurrences and were so characterized in our report to Congress in January 1979.
(2)
Recent.licensing reviews have required tests or analyses to show that containment purge or vent valves would shut without degrading containment integrity during the dynamic loads of a
design basis loss of coolant accident (DBA-LOCA).
The NRC position of the November 1978 letter requested licensees to ceaSe purging (or venting)
Of cOntainInent or liIIi.t purging (or Venting) to an absolute minimum.
Licensees who elected to purge (or vent) the con-taiIment were requested to demonstrate that the cont,ainment purge (or vent) system design met the criteria outlined in the NRC Standard Review Plan.
(SRP) 6.2.4, Revision 1, and the associated Branch Technical Position (BTP)
CSB 6-4, Revision 1.
OISCUSS ION ND EVALUATION The Containment Purge System ot the R.E.
Ginna Nuc1ear Power P1ant utilizes two 48-inch butterfly-type isolation valves in series in the purge supply line and two 48-inch butter fly-typ isolation valves in series in the purge exhaust line.
Two 6-inch butterfly-type isolation valves, in
'eries, are used to accomplish containment depressurization.
The licensee responded to the NRC position letter of November 1978 by indicating that they will limit purging to 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> per year while the reactor is critical or operating as defined in the Ginna Te'thnical Specifications.
The licensee has not provided a discussion of the acceptability of the provisions made to protect structures and related equipment (e.g.,
fans, filters, ductwork, etc.) located beyond the purge system isolation valves against loss of function from the environment created by escaping air and steam.
The licensee also has not performed information concerning provisions made to ensure that isolation valve closure will not be prevented by debris which could potenti ally become'ntrained in the escaping air and steam.
III.
CONCLUSIONS AND RECOMMENDATIONS We have reviewed the submittals regarding the Ginna Nuclear Power Plant Purge/Ventilation System against the guidelines of BTP CSB 6-4, Revision 1.
"Containment Purging During Normal Plant Operations."
We are unable to complete our review of 'the Purge/Uenti lation System design aspects because the licensee has not provided:
(1)
Information concerning the provisions to protect structures and safety-related equipment located downstream of the purge isolation valves against loss of function from the environment created by the escaping air and Steam following a LOCA.
(2)
A discussion to the provisions to insure that isolation valve closure will not be prevented by debris which could potentially become entrained in the escaping air and steam.
Installation of debris screens is one acceptable method of accomplishing this function. If no provisions are considered necessary provide information to justify this conclusion.
Finally, it is our recommendation that the licensee commit to limiting the use of the Purge/Vent System to a specified annual time commensurate with plant operational safety needs.
The licensee should provide such a commitment or justify why such a limitation is considered unnecessary.
ENCL E 4 CONTAINMENT SYSTEMS LIMITING CONDITION FOR OPERATION 3.6.1.7 The containment purge suppl'y and exhaust iso'lation valves may be open for safety-related reasons [or shall be locked closed].
The containment vent line isolation valves may be open for safety-related reasons [or shall be locked closedl.
'APPLICABILITY:
MODES 1, 2, 3, and 4.
ACTION:
~or p ants with vaives cIosed by technical specification)
With one containment purge supply and/or one exhaust isolation valve
- open, close the open valve(s) within one hour or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
(For plants with valves that may be opened by technical specifications) 1.
With one containment purge supply and/or one exhaust isolation or vent valve inoperable, close the associated OPVSBLE valve and either restore the inoperable valve to OPERABLE status within.72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or lock the OPERABLE valve closed.
2.
3.
Operation may then continue until performance of the next required-valve test provided that the OPERABLE valve is verified to be locked closed at least once per 31 days.
I Otherwise, be in at least HOT STAt.DBY within the next six hours and in COLO SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
- 4. 'he provisions of Specification 3.0.4 are not applicable.
SURVEILLANCE REQUI REMENTS 4.6.1.7.1 The
-inch containment purge supply and exhaust isolation valves and the
-incWvent line isolation valves shall be determined locked closed at least once per 31 days.
4.6.1.7.2 The valve seals of the purge supply and exhaust isolation valves
, and the vent line isolation valves shall be replaced at least one per years.
3/4 6-10
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I" CONTAINMENT SYSTEMS 3/4 4.6.3 CONTAINMENT ISOLATION VALVES LIMITING CONDITION FOR OPERATION 3.6.3 The containment isolation valves specified fn Table 3.6-1 shall be OPERABLE with isolation times as shown in Table 3.6-1.
APPLICABILITY:
MODES 1, 2, 3 and 4.
ACTION:
With one or more of the isolation valves(s) specified fn Table 3.6-1 inoperable, maintain at least one isolation valve OPERABLE fn each affected penetration that fs open and either:
a.
Restore the fnoperable valve(s) to OPERABLE status within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or b.
Isolate each affected penetration within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use of at least one deactivated automatic valve secured fn the fsolation position, or c.
Isolate each affected penetration
~
thin 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use.of at least one closed manual valve or blind fiange; or d.
.Be fo at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
SURVEILLANCE REQUIREMENTS 4.6.3.1 The isolation valves specified in Table 3.6-1 shall be demonstated OPERABLE prior to returning the valve to service after maintenance, repair or replacement work fs performed on the valve or its associated actuator, control or power circuit by performance of a cycling test, and verification of isola-tion time.
3/4 6-14
CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) 4.6.3.2 Each isolation valve specified in Table 3.6-1 shall be demonstrated OPERABLE during the COLD SHUTDOWN or REFUELING MODE at least once per 18 months by:
a.
Verifying that on a Phase A containment isolation test signal, each Phase A isolation valve actuates to its isolation position.
b.
Verifying that on a Phase B containment isolation'test signal, each Phase B isolation valve actuates to its isolation position.
4.6.3.3 The isolation time of each power operated or automatic valve of Table 3.6-1 shall be determined to be within its limit when tested pursuant to Specification 4.0.5.
4.6.3.4 The containment purge and vent isolation valves shall be demonstated OPERABLE at intervals not to exceed months.
Valve OPERABILITY shall be determined by verifying that when the measuued leakage rate is added to the leakage
'ates determined pursuant to Specification 4.6.1.2.d for all other Type B and C penetration, the combined leakage rate is less than or equal to 0.60La.
However, the leakage rate 'for'he containment purge and vent isolation valves sh'all be compared'o the preiiously measured leakage rate 'to detect excessive valve degradation.
3/4 6-15