ML20006F351
| ML20006F351 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 02/13/1990 |
| From: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Bird R BOSTON EDISON CO. |
| References | |
| NUDOCS 9002270427 | |
| Download: ML20006F351 (3) | |
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.. q FEB 13 W Docket No. 50-293 Boston Edison Company ATTN: Mr. Ralph G. Bird Senior Vice President - Nuclear Pilgrim Nuclear Power Station RFD #1 Rocky Hill Road Plymouth, Massachusetts 02360 Gentlemen:
SUBJECT:
Discretionary Enforcement Relating-to the Technical Specification (TS)
Surveillance Test 4.7. A.2.b.1.d for Instrument Line Excess Flow Check Valves at Pilgrim Nuclear Power Station j
l This letter is in reference to the telephone conversation on February 9,1990 l
between Mr. K. Highfill and others of your staff and Messrs. B. Boger, W. Kane, l
and others of the NRC regarding your request for relief from certain testing requirements.
This also confirms the subsequent conversation between Mr. K. Highfill and Mr. J. Johnson of this office g' anting your request for one time enforcement discretion to allow you to prepare and submit a request for a TS change and subsequent action by the Office of Nuclear Reactor Regulation.
Specifically, this action grants relief from the Pilgrim Nuclear Power Station TS 4.7.A.2.b.1.d, which requires operability verification of the reactor cool-i ont system instrument line flow check valves 2-CK125A and B, once per operating cycle.
This relief will allow you to operate the facility without completing a test-of these flow check valves, as required by TS 4.7.A.2.b.1.d, until your request-l.
for a Technical Specification amendment is acted upon by the Office of Nuclear l
Reactor Regulation or the outage currently scheduled to begin on March 9, 1990.
This discretion is subject to the following interim compensatory measures as l
committed in your letter of February 9, 1990 (attached):
Control access to the vicinity of the lines from the check valves to the instrument racks; Control work and maintenance in the area of lines from check valves to
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instrument racks; 4
Prepare a standing Radiation Work Permit to allow operations personnel to l
isolate root valves if required by a line break downstream of the check valve; and Inspect the affected lines for leakage each watch.
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L OFFICIAL RECORD COPY 18/EAPEN/2/12/90 - 0001.0.0 i
9002270427 900213 g
02/13/90 PDR ADOCK 05000293 P
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.'l Boston Edison Company 2
RB13 W This discretion will remain in effect until the Office of Nuclear Reactor Regulation acts upon your Technical Specification amendment request.
Sincerely, Original Signo5 By WILil.'.X T. IlUSSELL William T. Russell Regional Administrator
Attachment:
As Stated cc w/ attachment:
K. Highfill, Vice President, Nuclear Operations R. Anderson, Plant Manager J. Dietrich, Licensing Division Manager E. Robinson, Nuclear Information Manager R. Swanson, Regulatory Affairs Manager The Honorable John F. Kerry The Honorable Edward J. Markey The Honorabic Edward P. Kirby The Honcrable Peter V. Forman The Honorable Lawrence R. Alexander The Honorable Nicholas J. Costello B. McIntyre, Chairman, Department of Public Utilities Chairman, Plymouth Board of, Selectmen Chairman, Duxbury Board of Selectmen Plymouth Civil Defense Director R. Hallisey, Department of Public Health, Commonwealth of Massachusetts R. Adams, Department of Labor and Industries, Commonwealth of Massachusetts D. Tibbetts, Acting Massachusetts Secretary of Energy Resources Sarah Woodhouse, legislative Assistant A. Nogee, MASSPIRG Public Document Room (PDR) local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector Commonwealth of Massachusetts, SLO Designee 0FFICIAL RECORD COPY 18/EAPEN/2/12/90 - 0002.0.0 02/12/90
Boston Edison Company 3
FES 13 898 bec w/ attachment:
Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o enc 1)
W. Russell, RA J. Dyer, EDO R.'Wessman, NRR M. Fairtile, NRR J. Johnson, DRP P. K. Espen, DRP J. Macdonald, SRI - Pilgrim _(with concurrences) l W
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Martin Russell Eapen/meo Johnson f#e an le 2/12/90 3 g)
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ATTACHMENT s,,;
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P;1 grim Nuc! tar Power station Rocky Hill Road l
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Plymouth. Messachusetts 02360 L
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Ralph G. Bird senior Vice President - Nuttear
. February 9, 1990 g
BECo Ltr #90-22 j
4 U.S. Nuclear Regulatory Comission F
Attn: Document Control tesk t
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Hashington, D.C. 20555 Docket No. 50-293 t
License No. DPR-35 t
Subject:
REQUEST TOR RELIEF FROH TECHNICAL SPECIFICATION 4.7.A.2.b.l.d LIMITING CONDITION FOR OPERATION i
f
. Dear Strr Boston Edison Company hereby requests a temporary relief from the requirements
' of Pilgrim Huclear Power Station Technical Specification 4.7.A.2.b.l.d until the mid-cycle outage scheduled to begin on March 9.1990.
Plant operation,
d subsequent' to the granting of this request would not create a significant hazard to the public~ health and safety and is justified on technical merit.
- l l-He have also concluded that a request for an emergency change'to the Pilgrim p
Technical Specifications would not be appropriate in this case since the J
nature of the requested relief is temporary and non-recurring.
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b Backaround
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Technical Specification 3/4.7.A.2.b.l.d requires that the operability of the E
_ reactor coolant system instrument line flow check valves be' verified once per
'operati ng: cyc1_ e.
During the October,1989 outape, excess-flow check valves 2-CK125 ALB had their test aborted because sufficient actuation' flow was-unattainable due to the instrument line configuration.
e The inability to ver'fy operability conflicts with. Technical Specification 3/4.7.A.2.b.l.d' because the surveillance interval and its 25% " grace period" j
expired for these two valves, r-Justification i
S
-The excess flow check valves-serve two purposes:
that of a passive component je of the pressure boundary, similar to a spool piece; and that of an active 1
. component in reducing coolant flow in the event an instrument line sustains a catastrophic break i.e, a " double guillotine" break.
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Boston Edison Company
-Docket No. 50-293 Pilgrim Nuclear Power Station License No. OPR-35 y
b Jts passive " spool piece" role is not s secifically a part of Technical
>$pecifications because the failure of tie check valve internals in the open I,
position does not affect the process instrument associated with it.
Failure L
of the valve internals in the closed position will be detected by.a response y
time differential between process instruments downstream of the failed valve and similar redundant process instruments associated with open valves.
h The excess flow check valve's active function is to reduce flow into secondary p
containment if there is a line break downstream of the valve.
The FSAR safety v,
analysis of a potential instrument line break is-previded in Section 0
5.2.3.5.3.
This section describes the instrument line-containment boundary as g
an upstream orifice located inside primary containment and a downstream E
instrument flow check valve located outside primary containment. As-stated in the FSAR:
l "The combination of orifice and excess flowcheck (sic) valve will reduce L
Icakage to as low a value as practicable in the unlikely event of line 4
failure."
w The subsequent analysis of instrument line failure is based on.a guillotine line failure of the instrument line URLt.r_CM of the excess -flow check valve.
fJ This failurt results in a leak of 20 gpm to the secondary containment; thi
'i-flow limitation being strictly due to the upstream flow orifice. This leak rate is "well witbin the capability of the Reactor Coolant Makeup System" and, therefore, does not present a safety hazard to the reactor-core.' This flow does not endanger the integrity of the Reactor Building-as there "would not be any significant pressure rise due to the relatively high Reactor Building N
ventilation exhaust rates" and "the operation of one standby gas treatment i
filter train will prevent Reactor Building pressure from exceeding its design value." finally a leak rate of 20 gpm results in a site boundary exposure "which is substantially below the guidelines of 10CFR100."
The flow reduction contribution of the excess flow check valve is not a contributor to the instrument line break analysis.
In addition, the active.
s function of the-excess flow check valves, to reduce flow in the event of a line break downstream of the check valve, is not required to protect the core or.the health and safety of the public.
In effect, the safety function of the excess flow. check valves is reduced to maintaining a pressure boundary and an-open flow path to the associated instruments.
The surveillance requirement given in Technical Specification 3/4.7.A.2.b.1,d addresses only the active function of the check valves to reduce leakage "to T
as low a value as practicable" and this function is not required to meet the design of the plant.
This is the only function that has not been " verified" i
T for valves 2-CK125 A&B within the prescribed surveillance interval.
Noting that the flow orifices and valves are new and not subjected to a fluid flow L
environment other than that required for surveillance testing it is reasonable i
to assume that these orifices and valves have not eroded or degraded in any way which -could result in an increase of their critical / limiting flows. Also, all'other-excess flow check valves which were tested during the October min.i-outage passed ~their test.
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E Page'3 Boston Edison Company Docket No. 50-293 1
Pilgrim Nuclear Power Station License No. DPR-35 I
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Compensatory Measur.g1 f
'i1 Until the excess flow theck valves (2-CK125 ALB) are-replaced during the March E
9, 1990 mid-cycle outage, the following additional compensatory actions are f.
being taken:
Control access to the vicinity of the lines from the theck valves to -
i the instrument racks.
j Control work and maintenance in the area of lines from check valves
-l to instrument racks.
i A standing Radiation Work Permit will be prepared to allow operations personnel to isolate root valves if required by a line break downstream of the check valve.
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Operations personnel will conduct tours each vatch to inspect the E
affected lines for leakage.
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}b Given the evidence of the ability of the orifice and check valve combination to meet-the safety requirements described in the FSAR, and_the compensatory pln measures discussed above, we believe there is no adverse impact-to the public-
).
health and safety by continued operation until the scheduled outage.
l
' Continued operation is the better course of action than subjecting the plant j'
-to-an unnecessary shutdown.
f Please do not hesitate to contact me if you have questions or coments regarding'this. request.
-I
_f K. L. Highfil, Acting i
Senior Vice President - Nuclear j
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