ML19256G417
| ML19256G417 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 12/12/1979 |
| From: | Stolz J Office of Nuclear Reactor Regulation |
| To: | Borgmann E CINCINNATI GAS & ELECTRIC CO. |
| References | |
| NUDOCS 7912310262 | |
| Download: ML19256G417 (18) | |
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UNITED STATES g
g y y,e(, g NUCLEAR REGULATORY COMMISSION
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WASHINGTO N, D. C. 20555 g; % ",/
DEC 121979 Docket No:
50-358 Mr. Earl A. Borgmann Vice President - Engineering Cincinnati Gas & Electric Company P. O. Box 960 Cincinnati, Ohio 45201
Dear Mr. Borgmann:
SUBJECT:
REQUEST FOP. ADDITIONAL INFORMATION (WM. H. ZIMMER, UNIT NO.1)
In order that we may continue our review of your application for a license to operate the Zimer Nuclear Power Station, Unit No.1, your response to the enclosed request for additional infomation is needed.
The request is based upon information contained in your application as amended through Revision 62 and your responses to our previous requests. We will need your response to this request prior to February 28, 1980.
Please contact us if you desire infomation or clarification regarding the enclosure.
Sincerely, f
T!
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John F. Stolz, Chief Lji ht Water Reactors Branch No.1 U1 vision of Project v.anagement
Enclosure:
Requests for Additional Information Se next page 1664 057 7912310 g
DEC 12 199 cc: Troy B. Conner, Jr., Esq.
David 3. Fankhauser, Pn3 Conner, Mot.r,e & Corber 3569 *:ine Mile Road 1747 Pennsylvania Avenue, N. W.
Cincinnati, Chio 45230 Washington, D. C.
20006 Dr. Frank F. Hooner Mr. William J. Moran School of Natural Rescurces General Counsel University of 'tichigan The Cincinnati Gas and Electric Ann.;roor, Michigan JS109 Company P. O. Box 960 Mr. S epnen Schumacher Cincinnati, Ohio 45201 Miami Valley Power Pro.iect P. O. Box 252 fir. William G. Porter, Jr.
Dayton, Ohio 45401 Porter, Stanley, Arthur and Platt its. Augusta Prince, Chairperson 37 West Broad Street 601 Stanley Avenue Columbus, Ohio 43215 Cincinnati, Ohio 45226 fir. Steven G. Smith, Manaaer Charles Secnnoefer, Esc., Chairman Engineering & Project Control Atcaic Safety & Licensing Board The Dayton Power and Light Panel Company V. S. Nuclear Regulato'y Comission P. O. Box 1247 Washington, D. C.
20555 Dayton, Ohio 45401 Mr. G'enn 0. Briqnt J. Robert Newlin, Counsel Atomic Safety and The Dayton Power and Light Board Panel Company V. S. Nuclear Regulatory Commission P. O. Box 1247 Washington, D. C.
20555 Dayton, Ohio 45401 Lee.h S. Kosik, Esc.
Mr. James D. Flynn 3454 Cornell Place Manager, Licensing Cincinnati, Ohio 45220 Environmental Affairs The Cincinnati Gas and N. Pe er Heile, Esq.
Electric Company Assis ant City Solicitor P. O. Box 960 Room 214, City Hall Cincinnati, Ohio 45201 Cincinnati, Ohio 45220 Mr. J. P. Fenstermaker Atomic Safety and Licer. sing Board Senior Vice President-Operations Panel Columbus and Southern Ohio V. S. Nuclear Regulatory Comission Electric Company Washington, D. C.
20555 215 North Front Street Columbus, Ohio 43215 Atcmic Safety and Licensing Acceal Boart U. 5. Nuclear Regulato 7 Commission Wasnington, D. C.
205;5 M
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1664 058
ENCLOSURE REQUEST FOR ADDITIONAL INFORMATION WM. H. ZIMMER ROUND-TWO QUESTIONS Introduction This enclosure censists of the thirtieth in a series of position; (and r requests for additional information). We will need your response in order to complete our safety evaluation of your Zimmer OL application. The request is in the area of:
110.0 Mechanical Engineering It will be helpful to us if your responses are in a " Position and Response" format using the same number designation as the position.
The first number designated the review area and the second (in parentheses) designated the associated section of the FSAR. Of course, your responses should include revision to the FSAR wherever. appropriate.
1664 059
110.0 MECHANICAL ENGINEERING BRANCH 110.30 10CFR50.55a has recently been revised with respect to pump and (3.9.6) valve inservice testing requirements.
(See the Octo,ber 9,1979, Federal Register, pp. 57912-4.)
Provide a program for the preservice testing and initial 120 month inservice testing of pumps and valves, as requiredby 10CFR50.55a(g)(2) for preservice testing and (g)
(4)(1) for the initial 120 month period.
Since inservice testing requirements were not included in the Code until the Summer 1973 Addenda of the 1971 edition, which is later than the CP date for Zimmer 1, you have the option of meeting that edition and addenda or later ones to the extent practical for your preservice program.
The applicable Code for your initial 120 month inspection interval which would be required by 10CFR50.55a(g)(4)(i) is the Code endorsed by 10CFR50.55a(b)(2) 12 months prior to the date of issuance of your OL. Until November 1,1979, the latest endorsed version of Section XI was the 1974 Edition through the Summer 1975 Addenda.
However, effective November 1,1979,10CFR50.55a(b)(2) endorsed the 1977 Edition with all addenda through Summer 1978. With the current uncertainty in estimating whether your OL date will be before or after November 1,1980, it is difficult to determine which Code addenda would be required by 10CFR50.55a(g)(4)(i). We therefore recommend that you base your initial 120 month inservice testing program on the 1977 Edition with all addenda through Summer 1978 as permitted by 10CFR50.55a(g)(4)(iv).
Your preservice and initial 120 month interval programs should indicate which Code requirements are impractical to meet together with documentation for justification why relief is necessary.
The attached format should be used when submitting your IST program.
1664 060
NRC STAFF COMMENTS ON INSERVICE PUP AND V!1VE TESTING PROGRAMS AND RELIEF REQUESTS The NRC staff, after reviewing a nurber of pump and valve testing zz, -
programs, has determined that further guidance might be helpful to illustrate the type and extent of information we feel is necessary to expedite the review of these programs. We feel that the Licensee can, by incorporating o.:
these guidelines into each program subr.ittal, reduce considerably the staff's review time and time spent by the Licensee in responding to NRC
.m staff requests for additional information.
The pump testing program should include all safety related* Class 1, 2, and 3 pumps which are installed in water cc;1ed nuclear power plants and which are provided with an emergency power source.
The valve testing program should include all the safety related valves
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in the following systems excluding valves used for operating convenience only, such as manual vent, drain, instrunent, and test valves, and valves used for maintenance only.
PWR a.
High Pressure Injection System
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b.
Low Pressure Injection System c.
Accumulator Systems d.
Containment Spray System
- Safety related - necessary to safely shut down the plant and mitigate the consequences of an accident.
1664 061
-2 e.
Primary and Secondary System Safety and Relief Valves f.
Auxiliary Feedwater Systems g.
Reactor Building Cooling System h.
Active Components in Service W6ter and Instrument Air Systems which are required to support safety system functions.
- i. Containment Isolation Valves required to change position to isolate containment.
J.
Chemical & Volume Control System k.
Other key components in Auxiliary Systems which are required to directly support plant shutdown or safety system function.
1.
Residual Heat Removal System m.
High Pressure Core Injection System b.
Low Pressure Core Injection System c.
Residual Heat Removal System (Shutdown Cooling System) d.
Emergency Condenser System (Isolation Condenser System) e.
Low Pressure Core Spray System f.
Containment Spray System g.
Safety, Relief, and Safety / Relief Valves h.
RCIC (Reactor Core Isolation Cooling) System
- i. Containment Cooling System j.
Containment isolation valves required to change position to isolate containment.
I664 062
, 1 k.
Standby liquid control system (Boron Systen) 1.
Automatic Depressurization System (any pilot or control valves, associated
.3.
hydraulic or pneumatic systems, etc.)
Control Rod Drive Hydraulic System (" Scram" function) m.
other key components in Auxiliary Systems which are required to directly n.
support plant shutdown or safety system function.
o.
Reactor Coolant System Inservice Pumo and Valve Testing Program I.
Information required for NRC Staff Review of the Pump and Valve Testing Program A.
Three sets of P&ID's, which include all of the systems listed above, with the code class and system boundaries clearly marked.
The drawings should include all of the components present at the time of submittal and a legend of the P&ID symbols.
B.
Identification of the applicable ASME Code Edition and Addenda C.
The period for which the program is ap?licable.
..g._.
D.
Identify the component code class.
E.
For Pump testing:
Identify 1.
Each pump required to be tested (name and number) 2.
The test parameters to be measurec 1664 063 3.
The test frequency
. F.
For valve testing:
Identify 1.
Each valve in ASME Section XI Categories A & B that will be exercised every three months during normal plant operation (indicate whether partial or full stroke exercise, and for power operated valves list the limiting value for stroke time.)
2.
Each valve in ASME Section XI Category A that will be leak tested during refueling outages (Indicate the leak test procedure you intend to use) 3.
Each valve in ASME Section XI Categories C, D, and E that will be tested, the type of test and the test frequency.
For check valves, identify those that will be exercised
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every 3 months and those that will only be exercised during cold shutdown or refueling outages.
II. Additional Information that will be Helpful in Speeding Up the Review Process A.
Include the valve location coordinates or other appropriate location information which will expedite our locating the valves on the P& ids.
B.
Provide P&ID drawings that are large and clear enough to be read easily.
C.
Identify valves tht are provided with an interlock to other consonents and a brief description of that function.
1664 064
. Relief Reouests from Section XI Reouirements The largest area of concern for the NRC staff, in the review of an inservice valve and pump testing program, is in evaluating tne basis for justifying relief from Section XI Requirements.
It has been our experience that many requests for relief, submitted in these programs, do not provide adequate descriptive and detailed technical information.
This explicit information is necessary to ' provide reasonable assurance that the burden imposed on the licensee in complying with the code requirements is not
.1 justified by the increased level of safety obtained.
((.
Relief requests which are submitted with a justification such as
" Impractical", " Inaccessible", or any other categorical basis, will require additional information, as illustrated in the enclosed examples, to allow our staff to make an evaluation of that relief request.
The intention of this guidance is to illustrate the content and extent of information required by the NRC staff, in the request for relief, to make a proper evaluation and adequately document the basis for that relief in our safety evaluation report. The NRC staff feels that by receiving this information in the program submittal, subsequent requests for additional information and delays in completing our review can be considerably reduced or eliminated.
I.
Information Reouired for NRC Review of Relief Recuests A.
Identify component for which relief is recuested:
1.
Name and number as given in FSAR 2.
Function 3.
ASME Section III Code Class 4.
For valve testing, also scecify tne ASME Section XI valve category as defined in IWV-2000 1664 063
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B.
Specifically identify the ASME Code requirement that has been determined to be impractical for each component.
C.
Provide information to support the determination that the requirement in (B) is impractical; i.e., state and explain the basis-for requesting relief.
D.
Specify the inserv:ce testing that will be performed in lieu of the ASME Code Section XI requirements.
E.
Provide the schedule for implementation of the procedure (s) in (D).
II.
Examples to Illustrate Several Possible Areas Where Relief May Be Granted and the Extent and Content of Information Necessary to Make An Evaluation
[
A.
Accessibility: The regulation specifically grants relief from the code requirement because of insufficient access pro-visions. However, a detailed discussion of actual physical arrangement of the component in question to illustrate the insufficiency of space for conducting the required test is necessary.
Discuss in detail the physical arrangement of the component in question to demonstrate that there is not sufficient space to perform the code required inservice testing.
1664 066
. What alternative surveillance means which will provide an acceptable level of safety have you. considered and why are these means not feasible?
B.
Environmental Conditions (e.g., High radiation level, High temperature, High humidity, etc.)
Although it is prudent to maintain occupation radiation exposure for inspection personnel as low as practicable, the request for relief from the code requirements cannot be granted solely on the basis of high radiation levels alone. A balanced judgment between the hardships and compensating increase in the level of safety should be carefully established.
If the health and safety of the public dictates the necessity of inservice testing, alternative means.or even decontamination of the plant if necessary should be provided or developed.
Provide additional information regarding the radiation levels at the required test location. What alternative testing techniques which will provide an acceptable level of assurance of the integrity of the component in question have you considered and why are these techniques determined to be impractical?
1664 067
. C.
Instrumentation is not originally provided Provide information to justify that compliance with the code requircments would result in undue burden or hardships without a compensating increase in the level of plant safety. What alternative testing methods which will provide an acceptable level of safety have ycu considered and why are these methods determined to be impractica.l?
D.
Valve Cycling During Plant Operation Could Put the Plant in an Unsafe Condition The licensee should explain in detail why exercising tests during plant operation could jeopardize the plant safety.
E.
Valve Testing at Cold Shutdown.or Refueling Intervals in Lieu of the 3 Month Required Interval The licensee should explain in detail why each val've cannot be exercised during normal operation.
Also, for the valves where a refueling interval is indicated, explain in detail why each valve cannot be exercised during cold shutdown intervals.
III. Acceptance Criteria for Relief Recuest The Licensee must sucessfully demonstrate that:
1.
Compliance with the code requirements would result in hardships or unusual difficulties without a compensating increase in the level of safety and noncompliance will provide an acceptable level of cuality and safety, or 1664 068
9_
2.
Proposed alternatives to the code requirements or portions thereof will provide an acceptable level of quality and safety.
Standard Format A standard format, for the valve portion of the pump and valve testing C.r..
program and relief requests, is included as an attachment to this Guida ce.
The NRC staff believes that this standard format will reduce the time spent by both the staff in-our review and by the licensee in their preparation of the pump and valve testing program and submittals.
The standard format includes examples of relief requests which are intended to illustrate the application of the standard format and are not necessarily a specific plant relief request.
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1664 069 es..
ATTACHMENT STANDARD FORMAT VALVE INSERVICE TESTING PROGRAM SUBMITTAL 1664 070 i
m 5
I
B r
8 5
4 a
l' 3
's B
E 2
o>
.h a
3 M
9; 2
a e
- 2 u
5 n
3 y
REMARKS H
3 3
(Not to be used for relief basis)
Valve Ca ry flumber n
u c
U L
710 3
0-14 X
4 GA M
0-15 X
6 DE NA C
DT 717 3
C-15 X'
16 CK SA CV X
CS 702C 3
C-15 X
16 CK SA CV 707 3
E-14 X
3 REL SA CV 834 3
0-11 X
X 4
GL M
C Q
722B 3
B-11 X
B-11 X
A-10 X
B-10 X
D-14 X
10 GA M0 C
Q LT X
MT 30 sec.
1 w
Ch A
CD N
I e
a ei 4
l'j; nj::
- i
Legend for Valve Testing Example Format Q - Exercise valve (full stroke) for operability every (3) months LT - Valves are leak tested per Section XI Article IW-3420 MT - Stroke time measurements are taken and compared to the stroke time limiting value per Section XI Article IW 3410 CV.- Exercise check valves to the position required to fulfill their function every (3) months SRV - Safety and relief valves are tested per Section XI Article IW-3510 DT - Test category D valves per Section XI Article IW-3600 ET - Verify and record valve position before operations are performed and after operations are completed, and verify that valve is locked or sealed.
CS - Exercise valve for operability every cold shutdown RR - Exercise valve for operability every reactor refueling 1664 072
Relief Reouest Basis System: Auxiliary Coolant System, Component Cooling 1.
Valve:
71 7 Category:
C Class:
3 Function:
Prevent backflow from the reactor coolant pump cooling coils Impractic:1 test requirement: Exercise valve for operability every three months Basis for relief: To test this valve would require interruption of cooling water to the reactor coolant pumps motor cooling coils.
This action could result in damage to the reactor coolant pumps and thus place the plant in an unsafe mode of operation.
Alternative This valve will be exercised for operability Testing:
during cold shutdowns.
2.
Valve:
834 Category:
B-E Class:
3 Function:
Isolate the primary water from the component cooling surge tank during plant opertion.
It is
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normally in the closed position, but routine operation of this valve will occur during refueling and cold shutdowns.
Impractical Test Exercise va've (full stroke) for operability Requirement:
every three (3) months.
1664 073
_ Basis for Relief: This valve is not required to change position during plant operation to accomplish its safety function. Exercising this valve will increase the possibility of surge tank line contamination.
Alternate Verify and record valve position before and Testing:
after each valve operation.
3.
Valve:
744B Category:
A Class:
2 Function:
Isolate the residual heat exchangers from the cold leg R.C.S. backflow and accumulator backflow.
Test Requirements:
Seat leakage test Basis for This valve is located in a high radiation field Relief:
(2000 mr/hr) which would make the required seat leakage test hazardous to test personnel. We intend to seat leak test two other valves (875B and 876B) which are in series with this valve and will also prevent backflow.
We feel that by complying with the seat leakage requirements we will not achieve a compensatory increase in the level of safety.
Alternative No alternative seat leak testing is proposed.
Testing:
1664 074