ML17321A306

Discusses Review of Info in 831104 Memo Re Adequacy of Testing for Containment Spray Additive Sys (Task Interface Agreement 83-106).Containment Sys Branch SER Addressing Items 1 & 2 of Memo Encl.W/O Encl

ML17321A306
Person / Time
Site:	Cook
Issue date:	11/21/1984
From:	Eisenhut D Office of Nuclear Reactor Regulation
To:	Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 8412030077
Download: ML17321A306 (6)

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MEMORANDUM FOR:

FROM:

SUBJECT:

November 21, 1984 UNITED STATES NUCLEAR REGULATORY COMMISSION

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WASHINGTON, D. C. 20555 Local PDR ORBII1 Rdg.

Gray file DEisenhut CParrish DWlgg1nton OELD ACRS (10)

EJordan PMcKee JPartlow ADEQUACY OF TESTING FOR CONTAINMENT SPRAY ADDITIVE SYSTEMS FOR D.

C.

COOK, UNIT 2 (TIA 83-106)

We have completed our review of the information provided by your November 4, 1983 memo in accordance with the Task Interface Agreement 83-106 dated November 30, 1983.

Attached is the Containment Systems Branch SER which addresses Items 1 and 2 of your memorandum.

We have determined that the current Technical Specification surveillance requirements are inappropriate, that the licensee should establish a basis for a new surveillance requirement and propose a revised Technical Specification, that the licensee should demonstrate that the actual system performance under accident conditions may be adjusted in accordance with proportionality principles, and because the system cannot be periodically tested to actual accident conditions and the sensitivity of the system is not determined, the licensee should provide emergency procedures for operation of the spray additive system in the case of system malfunction during an accident.

The details of these conclusions are contained in the SER.

We have also reviewed the question on periodic testing of the check valves in this system in accordance with ASME Section XI.

As you know, the IST program at D.

C.

Cook is under review and our staff met with D.

C.

Cook at the plant site on March 27 and 28, 1984.

Jim Heller, the resident inspector, attended the meeting.

Section XI of the ASME Code has maintained the requirement to establish a

"reference" DP across swing or tilting disk check valves during preoperational testing if those valves are to be forward flow inservice tested using fluid flow.

Therefore, (a) unless the licensee had requested and received relief from this code requirement, he should have complied.

Additionally, (b) this requirement does imply that the fluid force required to open a swing or tilting disk check valve is not expected to be greater during an event than during test conditions.

However, the current standard (OM-10) which is being developed by the ASME OEM Working Group for Inservice Testing of Valves omits this requirement.

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November 21, 1984 Historical evidence has indicated that the instrumentation required to obtain DP across check valves is rarely available.

This and other matters were discussed with the licensee at the March 27/28 meeting on IST.

We are currently reviewing the licensee's IST program and will include consideration of this in that review.

As for the spray additive system deficiencies in the Technical Specifications surveillance requirements, we will send a copy of the enclosed Safety Evaluation to the licensee and request a response.

This was discussed with your staff as the best means for correcting the Technical Specifications.

If there are further questions on this matter, please let us know.

Attachment:

Containment Systems

Branch, SER cc w/enclosure:

R.

Wessman, NRR R. Spessard, Reg. III R. Mattson, D/DSI R. Vollmer, DE

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Historical evidence has indicated that the instrumentation requir d to obtain DP across check valves is rarely available.

This and other ma ers were discussed with the licensee at the March 27/28 meeting on IS If there are further questions on th>s matter, please let s

know.

Darrell G. Eis nhut, Director Division of

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Attachment:

Containment Systems

Branch, SER

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