ML19289C061
| ML19289C061 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/20/1978 |
| From: | Reid R Office of Nuclear Reactor Regulation |
| To: | Herbein J METROPOLITAN EDISON CO. |
| References | |
| NUDOCS 7812010005 | |
| Download: ML19289C061 (12) | |
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UNITED STATES j..( D ),' '.j 3'
NUCLEAR REGULATORY COMMISSION WASHINGTON, 0. C. 20555 a
\\'.,gs November 20, 1978 Docket No. T,0-289 Q Mr. J. G. Herbein Vice President Metropolitan Edison Company P. O. Box 542 Reading, Pennsylvania 19603
Dear Mr. Herbein:
By letters dated August 17 and September 30, 1977, you submitted for Three Mile Island Nuclear Station,. Unit No.1 (TMI-1), a proposed inservice inspection and testing program description and requests for relief from selected ASME Code requirements pursuant to 10 CFR 50.55a(g). By letter dated December 20, 1977, we advised you that on the basis of our preliminary review, we were granting on an interim basis (pending completion of our detailed review) relief from those inservice inspection and testing requirements that you had requested. We also advised you, however, that until our review had been completed you should be guided in perfonning the TMI-1 inservice inspection and testing program by both your proposed program and the present TMI-l Technical Specifications - using whichever guidance was more conservative.
Since granting this interim relief, we have made substantial progress in conducting our detailed review of your submittals. This review has included a meeting between our respective staffs on October 18 and 19, 1978. Our minutes of that meeting are enclosed. As you will note in reviewing the enclosed minutes, several areas of staff concern were identified at the meeting. We expect to advise you further in the near future with regard to these concerns.
In the matter of documentation of our review, the questions in were previously transmitted to you in draft form on September 11, 1978, and your responses to these questions were discussed at the meeting of October 18/19, 1978.
In order to provide a complete record in this matter, you are requested to submit your 20/5 133
_7812010005
Mr. J. G. Herbein written responses to the questions contained in Enclosure 2, within 14 days of receipt of this letter.
Sincerely,
,, j 4. f I-s Robert W. Reid, Chief Operating Reactors Branch #4 Division of Operating Reactors
Enclosures:
1.
Meeting Minutes 2.
Questions cc w/ enclosures:
See next page 20/5 134
Metropolitan Edison Company cc:
G. F. Trowbridge, Esquire Shaw, Pittman, Potts & Trowbridge 1800 f1 Street, N.W.
Washington, D.C.
20036 GPU Service Corporation Richard W. Heward, Project Manager Mr. E. G. Wallace, Licensing Manager 260 Cherry Hill Road Parsippany, New Jersey 07054 Pennsylvania Electric Company Mr. R. W. Conrad Vice President, Generation 1001 Broad Street Johnstown, Pennsylvania 1590i fliss Mary V. Southard, Chairman Citizens for a Safe Environment P. O. Box 405 Harrisburg, Pennsylvcnia 17108 Government Publications Section State Library of Pennsylvania Box 1601 (Education Building)
Harrisburg, Pennsylvania 17126 2075 135
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UNITED STATES y
NUCLEAR REGULATORY COMMiss.ON
-Enclosure I
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WASHINGTON, D. C. 20555
$ 7).
M November 20, 1978 Docket No. 50-289 LICENSEE: Metropolitan Edison Company, et al FACILITY: Three Mile Island Nuclear Station, Unit No.1 (TMI-1)
SUBJECT:
SUmARY OF MEETING HELD ON OCTOBER 18 AND 19,1978 TO DISCUSS LICENSEE'S SUBMITTAL ON INSERVICE INSPECTION AND TESTING PURSUANT T0 10 CFR 50.55a(g)
The meeting was held at the Conirission's offices in Bethesda, Maryland.
A list of attendees is given ir. attachment 1.
INTRODUCTION The purpose of the meeting was to obtain clarification of the proposed inservice inspection and testing program for TMI-l as contained in the licensee's submittals of August 17 and September 30, 1977.
SUMMARY
1.
Inservice Testing of Pumps The staff indicated that except for measuring pump flow rates, there appeared to be adequate basis for granting most of the relief requested by Metropolitan Edison Company (Meted) with respect to inservice testing of pumps. The staff noted that the primary basis for granting relief is that a measurement or inspection is impractical. The staff also expressed its view that the fact that a pump circuit did not presently include instrumentation for measuring flow did not make flow measurements impracticable within the meaning of 10 CFR 50.55a(g)(4) unless the installation of such flow instrumentation was impractical.
The staff did, however, express its opinion that relief probably could be granted in the case of the Screen Wash pumps (SW-PlA/B) in that visual confirmation of the effectiveness of the screen wash spray was a valid and functional alternative to quantitative flow measurement.
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. 2.
Inservice Testing of Valves On the basis of information previously supplied by Meted and infonnation provided at the meeting, the staff requested that Meted review a number of matters dealing with inservice testing of valves and revise their submittal accordingly. These matters are identified in detail in Attachment 2, 3.
Inservice Inspection of Class 1, 2 and 3 Component Pressure Boundaries Meted described the " focused" approach used in the preparation of their proposed ISI program for Class I components. Using the focused approach, inspections are concentrated in those areas having the highest calculated stresses and, as proposed by Meted, the number of areas inspected is greatly reduced. This offers the benefit of reduced radi& tion exposure of ISI personnel.
Meted stated that this approach had been discussed previously with certain technical members of the staff and based on the generally positive reaction, Meted based its submittal on this approach.
The staff responded that while its technical members favoreo the general concept of the focused approach, it had not yet been endorsed by Section XI of the ASME Code and therefore could not be approved at this time. Meted was also advised that because we cannot presently approve the focused approach, if they needed any relief from the present Code requirements for Class I components, they should revise their submittal accordingly and provide full justification for the relief requested.
With regard to Class 2 and 3 components, the staff stated that Meted's submittal covering Class 2 ccmponents appeared acceptable, but that the staff was still reviewing the relief requested for the Class 3 Decay Heat River Water pipes.
4.
Conflicts Between Code Requirements and Safety Requirements At the conclusion of the meeting, V. Nerses suggested that Meted should once again review their progr m to assure themselves that they have included requests for relie.. from valve testing in all cases where the Code requirement might create an unsafe condition as outlined in Enclosure 2 to the letter of November 17, 1976 from R. W. Reid to R. C. Arnold.
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. 5.
Valves That Perform a Pressure Isolation Function V. Nerses noted that there are several safety systems connected to the reactor coolant pressure boundary that have design pressures that are below the reactor coolant system operating pressure.
Nerses indicated we have required that there be redundant isolation valves forming the interface between these high and low pressure systems to prevent the low pressure systems from being subjected to pressures which exceed their design limits.
In this role the valves are per-forming a pressure isolation function.
It was noted that valves DH-V1, DH-V2, DH-V22 A/B, CF-V4 A/B, CF-V5 A/B, two of the following four: RC-V23, RC-V4, DH-V62, DH-V63; and two in each of the follow-ing groups of three: MU-V16A/ftU-V107A/MU-V95; MU-V16C/MU-V107C/ftU-V86B; and MU-V160/MU-V107D/MU-V86A, appear to perform a pressure isolation function.* It was noted that we consider it necessary to provide assurance that the condition of each of these valves is adequate to maintain the integrity of the pressure isolation function in order to prevent the several lower pressure systems connected to the reactor coolant pressure boundary from being subjected to pressures which exceed the design limits of these lower pressure systems.
For this reason, we believe that some method, such as leak testing, should be used to assure their pressure isolation function.
Nerses pointed out that recommendations for resolution of this item will be discussed in our safety evaluation report (SER) of the TMI-l inservice inspection and testing program. The licensee agreed to respond to the NRC concern relative to leak testing of these valves after they receive the SER.
QMdb h
-Gerald B.
etzig, Project Manager Operating Reactors Branch #4 Division of Operating Reactors
Enclosures:
1.
Attendance List 2.
Review Items
- The groups of valves associated with MU-V16A/C/D were added subsequent to the meeting.
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y REQUEST FOR ADDITIONAL INFORMATION THREE MILE ISLAND NUCLEAR STATION ENGINEERING BRANCH DIVISION OF OPERATING REACTORS 1.
Class I components 1.
For Items Bl.2 and B2.1, Examination Category B-8, the ASME Code requires 10% of the longitudinal and 5% of the circumferential welds to be inspected near the end of each inspection interval.
Please supply additional justification to support your request for eliminating examinations. Low calculated stress alone is not sufficient to warrent exception.
2.
For Items Bl.4 and B2.2, Examination Category B-D, the ASME Code requires all nozzles to be examined 100% during the inspection interval. Please supply additional justification to support your request for the proposed selection of nozzles for examination.
3.
For Items Bl.6 and B4.1, Examination Category B-F, the ASME Code requires volumetric and surface examinations of 100% of all safe end welds during the inspection interval. Please provide additional justification for not complying with the Code requirements and provide an estimate of the following:
(a) the normal range of expected radiation dose rates in the area of the safe ends, (b) the total number of man-hours involved in completing the examinations, and (c) the total number of man-rems involved in completing the examinations.
4.
For Items Bl.13, Bl.14, B2.9 and B3.8, Examination Categories B-I-l and B-I-2, please provide more information to justify your request for eliminat' ion for cladding inspection.
5.
Are three housings equal to 10% of the peripheral control rod housings required to be examined under Item B1-18, Examination Category B-0?
6.
For Item B3.1, Examination Category B-B, do the examinations intended meet the 5% requirement for the circumferential welds and the 10% requirement for the longitudinal welds?
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i.
For Item B3.2, Category B-0, volumetric examination is required 7.
by the Code. Please provide a more detailed technical justifica-tion for not meeting the Code requirements.
i 8.
Will the welds chosen to be examined under Items B4.5, B4.7 and B4.
- 8. Examination Category B-J, meet the 25% requirement of the Code?
II. Class 2 Components i
1.
Will the examinations intended for Items C1.1 and C1.2, Examination Categories C-A and C-B, satisfy the requirements for examination over the service life of the plant?
2.
Previde a technical justification for examining the bolting of only three decay heat system flanges over the service life of the unit when the Code requires examination of 100% of the bolting during each inspection interval, a period of ten (10) years.
(Items 3.2 and 4.2, Examination Category C-D).
3.
Provide a technical justification for examining only one pumps support component of one decay heat system pump when the Code requires that all support components shall be examined during each inspection interval, a period of ten (10) years.
(Item 3.4, Examir.ation Category C-E-2).
4.
The Code requires that at least part of the required examinations be performed by the expiration of one-third, two-thirds, and the end of each inspection interval, ten (10) years, where the number of required examinations are distributed unformly among the number of inspection intervals.
It is not apparent that the following examinations to be performed during this inspection period, as given in Table B-1 of your submittal, are in compliance with this requirement:
Item Cl.1 Examination Category C-A Item C1.2 Examination Category C-B Item C1.4 Examination Category C-D Item C2.1 Examination Category C-F, C-G Item C2.2 Examination Category C-F, C-G Item C2.4 Examination Category C-D Item C2.5 Examination Category C-E-1 Item C2.6 Examinatior. Category C-E-2 III Class 3 Component For the buried piping systems listed on Table C-2, give their operating pressures and consequences that may result from piping failure.
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I I
IV. Pump Testing Program These questions apply to the justification notes for Table 0-2.
- 1) Applies to Note 2:
In most cases where pump bearings are submerged and cooled i
by the workjng fluid, ti.ce exists a thrust bearing at theCan bearing te motor or driven end which is accessible.
measurements be made at this bearing?
t
- 2) Applies to Note 3:
Where flow meters are not installed, it ma be assible to estimate flow rate from other pressure drop components a read in the system such as While the absolute accuracy of such a device may elbnws.
be questionable, its repeatability would satisfy the intent of the code. Please re-examine the pump systems affected and comment on these,ossibilities.
In cases where this is not practical, n
power maasurements may be useful in estimating flow.
- 3) Applies to Note 4:
Calculatalinlet static pressure based on height measurements Some method for the measure-of wili meet the intent of the code.
system pressure, allowing AP to be calculated, should be proposed.
- 4) Applies to Note 5:
In cases where bearings are immersed in oil, can oil tertperature i
prior to cooling be obtained?
- 5) Applies to Table 3-1:
f The Table implies Pleaseindicate which pumps are constant speed.
that all except turbine drive emergency feedwater.
V.
Valve Testing Program These questions apply to the notes 1 to 6, to Table E-1, and the request for relief paragraphs A to E in the Licensee's submittal, and to drawings and table discrepancies.
- 1) Applies to Note 1 & Paragraph A:
In the case of normally closed chack valves such as BSV30A/B, there exists an upstream vent or drain connection between the valve in question and a block valve. This arrangement s'iould 20/5 141
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i allow testing, or as a minimum, demonstration of valve opening or j
unsesting, using a substitute fluid during cold shutdowns or refueling.
Please review all valves in this category and propose such alternatives where possible.
- 2) Applies to Note 2:
l The drawing does not show valve function. The note implies con-tainment isolation, but the table does not indicate a leak test for these valves.
Please clarify.
- 3) Applies to Note 3:
Only one valve (SF-V23) is tagged with this note. What is the safety-related function of this valve?
- 4) Applies to Note 5, Paragraph F:
This note applies to one valve (WDL-V362), but Paragraph F is missing. What is Paragraph F and what is the safety-related function of this valve?
- 5) For Category A valves, where leak check "L" is listed in table, type of leak test should be noted. The following NRC position on Category A valves may be used as a guide:
a.
Those valves that ~ rform both a pressure isolation and containment isolacion function shall be leak tested to meet both Section XI of the applicable edition of the ASME Code and Appendix J of 10 CFR 50 requirements.
j b.
Those valves that perform a pressure isolation function only shall be required to meet Section XI of the applicable edition of the ASME Code.
c.
Those valves that perform a containment isolation function only shall be required to meet Appendix J of 10 CFR 50.
The inservice testing program should clearly identify which valves are applicable to each of the categories listed above.
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6)
Describe the operations or tests intended under the submittal i
type "F -- Functional check of valve operation".
In some cases, this may fall under the code as a " partial stroke" test.
Explain why full stroke is impractical or unwarranted.
i 7)
Category E Valves:
There are no Category E valves listed, but examination of the drawings shows many locked position valves in the flow paths of safety-related systems.
Please review and correct.
8)
All relief valves in safety-related systems should be listed.
Particular i
t 9)
Reactor Building Spray System:
Please review for containment isolation function.
Valves selected should be Category A and leak checked.
(FSAR she'.ss Type 1 arrangement, indicating BSV1A/B & BSV30A/B are containment isolation valves, CIV.)
10)
Decay Heat Removal System:
Please review for containment isolation function.
(FSAR shows Type 1 arranoement, indicating for penetration 310 & 503 that valves DH-4A/B and DH-22A/B are CIV, and Type 4 arrangement for penetration 320, indicating valves DH54 and CH59 are CIV.)
Also review for pressure isola-tion, and using guide outlined in Question 5) above, specify leak check required.
i 11)
Decay Heat River Wa'ter System: Where are valves DR-V21A/B and DR-V22A/B located and what is their safety-related function?
12)
Core Flooding System: Valves CF-V4A/B and CF-VSA/B serve a pressure isolation function and should.be reclassified AC and leak checked as outlined in Question 5 above.
Valves CF-VIA/B should be classified and listed, and other valves in this system should be reviewed for their safety-related function.
13)
Reactor Building Emergency Cooling System: What is the safety-related function of valves RR-V3A/B/C and RR-V4A-D? Also, please re /iew function of RR-V9A/B/C and NS-VII to determine whether these valves should also be listed and categorized.
14)
Nuclear Service River Water System:
Drawing missing.
- 15) Screen Wash and Sluice System: What is safety-related functior.
of these valves?
16)
Make-Up System:
Please review function of valves MU-V16A-D' and l'.U-V107A-D to determine correct classi fica tion. Also review all valves on drawing C-300-017 to determine if they should be cate-gorized and listed.
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.6 17)
In'termediate Cooling System:
Please review function of valves IC-V16 and IC-V18 to determine if they should be listed and categorized.
18)
Reactor Coolant System: What is safety-related function of RC-V2 and RC-RV2?
19)
Emergency Feedsater System:
Please review all valves shown on drawing C-300-009 Gill to determine safety-related function and whether or not they should be listed and categorized.
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