ML20039F681
| ML20039F681 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 12/22/1981 |
| From: | AFFILIATION NOT ASSIGNED, ASTA, INC. |
| To: | |
| Shared Package | |
| ML20039F672 | List: |
| References | |
| NUDOCS 8201130215 | |
| Download: ML20039F681 (175) | |
Text
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'O REVIEW 0F THE O PUBLIC SERVICE COMPANY OF COLORADO PROPOSED INSERVICE INSPECTION PROGRAM O
O O
Submitted to:
LOS ALN40S NATIONAL LABORATORY O by:
ASTA, Inc.
22 December 1981 O Under LANL P.O. 9-L32-9055X-1 0
8201130215 820105 ^
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D CONTENTS PAGE 3
INTRODUCTION i TASK OUTLINE 11 PROCEDURE iii 3 PROPOSED ISI PROGRAM - SECTIONS iv CODE DEVELOPMENT, ISSUANCE, AND EFFECTIVITY vi g TERMIN0 LOGY vii EXECUTIVE
SUMMARY
E-1 D SECTION 1 -
Responses to Proposed Technical 1-1 Surveillance Requirements for PCRV Auxiliary System Tables 1-10 D
SECTION 2 - Responses to Proposed Technical 2-1 Surveillance Requirements for Prestressed Concrete Reactor l Vessel (PCRV)
D Tables 2-12 SECTION 3 - Responses to Proposed Technical 3-1 Surveillance Requirements for PCRV Internals D
Tables 3-9 D
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O CONTENTS, Continued PAGE O
SECTION 4 - Responses to Proposed Technical 4-1 --
Surveillance Requirements for Primary Coolant System Helium O Circulators Tables 4-9 SECTION 5 - Responses to Proposed Technical 5-1 O Surveillance Requirements for Secondary Coolant System Tables 5-11 O APPENDIX A - Additional Surveillance Requirements A-1 REFERENCES A-36 l Tables A-37
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. . TASK 1 - INSERVICE INSPECTION s M '.
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'cINTRODUCi10N -
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- Following a period of operation at. the Fort St. Vraln (FSV) .
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Nuclear Generating Station the inservice inspection (ISI) program is
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2.< > lbeing evaluated and uodated to' reflect plant ope'r.ating experience to
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.t ~1 30NRC. Consequently, the inservice ipspection procram to be followed
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" P' b at_FSV is being; revised and submitted"by' publicf5er' lice of Colorado (PSC)
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.- y 1 .y . to NRC for approval. Thre'e submittals of modified FSV'TeEtinicale. s-x 3 g- 3 w
_ m Speci fication Surveillance Requirements have'been. tran:,mitted(to NRC..
on February 8, March 3, ands March 31, 1980. A list of systemsfcomponents O7. . - s , ,
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covered}y,these~submittalsisgivenonpage,iy.x,-
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O. ~ Reslefof the p~r 6 posed modifications' tr 'SV Techn'ical Spe'cification
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, Surveillance Pequiremehts and completeness y the FSV ISI program N y. s
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. . . xs relative to ap$licable . inservice and, testing requirements is'the-subject c .
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, ,s TASK OUTLINE -
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The: principal,' activities of this task include:
O e Review df original FSV ' inservice inspection program >
(current program).
O e Review of PSC submittals to NRC outlining the revised inservice inspection program.
O e Comparison of the revised inservice inspection program to available regulations, requirements and guides including proposed ASME Boiler and Pressure Vessel Code,Section XI,
- O Division 2," Rules for Inservice Inspection and Testing of Components for Gas-Cooled Plants," and previous PSC operating license comitments to NRC.
g i
e Recommendation of approval of the revised inservice program i in whole or in part and recomendation of changes required O to meet the applicable requirements necessary to obtain final NRC approval of the program.
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O f 1 PROCEDURE lO i
The procedure for review of each Technical Specification Surveillance
- Requirerent (SR) of the proposed ISI program was generally as follows:
- O-l a. Sununarization of original requirements.
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- O b. Identification of proposed changes to requirements.
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- c. Identificat on of applicable related requirements of. code, i
j O regulatory agencies, etc.
- d. Review, comparison, and discussion of requirements. -
P l Additional requirements beyond the scope of the current group of SRs are contained in Appendix A. The review procedure in Appendix
- O A generally follows the above fonnat, except that (a) and (b) are replaced l .by a single introductory section.
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lO l The. review of each SR and its comparison with Section XI, Division i
2 Code requirements is sununarized in a Table at the end of each section.
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q PROPOSED ISI PROGRAM - SECTIONS
-O Surveillance Requirements for Fort St. Vrain Category I systems are covered in three PSC submittals to NRC dated February 8, March 3 and 31 j 1980. These include:
O
- 1. PCRV Auxiliary System (P-80014 of 2/8/80).
SR 5.1.2 -
Reserve Shutdown System Surveillance lO SR 5.2.1 -
PCRV Overpressure Safety System Surveillance SR 5.2.15 - PCRV Penetration Interspace Pressure Surveillance SR 5.2.16 - PCRV Closure Leakage Surveillance O 2. Prestressed Concrete Reactor Vessel (PCRV) (P-80034 of 3/3/80)
SR 5.2.2 -
Tendon Corrosion and Anchor Assemblies Surveillance SR 5.2.3 -
Tendon Load Cell Surveillance SR 5.2.4 -
PCRV Concrete Structure Surveillance SR 5.2.5 -
Liner Specimen Surveillance SR 5.2.13 - PCRV Concrete Helium Permeability Surveillance SR 5.2.14 - PCRV Liner Corrosion Surveillance g SR 5.2.24 - Refueling Penetration Holddown Plates Surveillance
- 3. PCRV Internals (P-80034of3/3/80)
SR 5.2.22 - PGX Graphite Surveillance O SR 5.2.25 - Core Support Block Surveillance SR 5.2.26 - Region Constraint Devices Surveillance
- 4. Primary Coolant System Helium Circulators (P-80064 of'3/31/80)
O SR 5.2.17 - Helium Circulator Pelton Wheels, Surveillance SR 5.2.18 - Helium Circulators, Surveillance SR 5.2.19 -- IACM Diesel-Driven Pumps, Surveillance (deletion)
SR 5.2.27 - Helium Shutoff Valves, Surveillance O
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- 5. Secondary Coolant System (P-80064 of 3/31/80)
SR 5.3.1 - Steam / Water Dump System, Surveillance O SR 5.3.2 - Main and Hot Reheat Steam Stop Check Valves, Surveillance SR 5 3.3 - Bypass and Pressure Relief Valves, Surveillance SR 5.3.4 - Safe Shutdown Cooling Valves, Surveillance SR 5.3.9 - Safety Valves, Surveillance O
SR 5.3.10 - Secondary Coolant System Instrumentation, Surveillance O
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CODE DEVELOPMENT, ISSUANCE, AND EFFECTIVITY O
Proposed Section XI, Division 2. ASME Boiler and Pressure Vessel Code," Rules for Inservice Inspection and Testing of Components of Gas-Cooled Systems"was issued in September 1977 for a one year review and O
comment period. This trial period was extended in September 1978 for an indefinite period. In the meantime, development of the proposed code continued and in June 1979 a new subsection was published as addenda to the O
proposed code - Subsection IGl!, Inservice Inspection of Elevated Temperature Structural Material. In January 1980 the ASME Main comittee adopted another new subsection to be added to the proposed code - Subsection IGI, O
Inservice Inspection of Graphite and Thennal Insulation Materials.
ASME plans to officially issue ASME Section XI, Division 2 by the end O
of 1981, including the initial proposed 1977 issue together with subsequently adopted subsections IGI and IGH. Continued work by rules committees will include future additions to the Gas-Cooled Plant Code of Subsections IGE O
on Containments (Class MC Vessels) and IGF on Component Supports. These will be based on generic requirements currently contained in similar subsections for LWRs, and requirements appropriate to unique structures of large HTGRs.
O (Note: LWR code development includes rules for component supports in the current issue of Section XI Division 1. Rules of inspection for containments have been adopted by ASME technical committees and issuance
.O as addenda is expected shortly - Code Case 81-401).
For purposes of this review, the effective revisions of Code and O
Addenda appropriate to the FSV inservice inspection program update arecon-sidered to be the 1977 proposed code draft and summer 1979 draft issue of Subsection IGH for elevated temperature materials requirements.
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TERMIN0 LOGY - -
3 A. The " Code" or " proposed Code" refers to Proposed Section XI, Division 2, ASME Boiler and Pressure Code," Rules for O Inservice Inspection and Testing of Components of Gas-Cooled Systems," draft issue of 1977.
O B. Surveillance - The current definition if surveillance as contained in the proposed Code states: "
. . . . the continued periodic examination perfonned on material speci-O mens or components to insure the adequacy of the physical properties of the material ."
h By code definition, surveillance constitutes e specific inspection method. Other methods are identified as l examination (NDE), monitoring and testing. . The use of
- O the tenn in the PSC inservice inspection program covers a much broader interpretation encompassing such methods
- as visual examination, operational testing, performance O monitoring, dimensional check, material examination,and testing.
i C. The terms AREA, HETHOD, EXTENT and FRE0VENCY in the Tables 3 are used as defined by the Code.
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- O EXECUTIVE Suff1ARY
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SUMMARY
General In general, the ISI proaram proposed by PSC is well thought O
out, practical, and meets the intent of the various applicable codes and regulations as they would apply to the unique Fort St. Vrain HTGR desian.
.g Suninary PSC Submittal The enclosed tables briefly summarize reconinendations con-g cerning the proposed ISI program. Immediate NRC approval is recommended in the case of 19 of the 24 items submitted by PSC.
One (1) item is f r inf rmati n nly, and requires no further NRC O
action. Three (3) items are reconinended for approval following changes recommended herein. One (1) item is suggested for further investigati n by PSC.
O Additional Items Appendix A discusses six (6) additional items that do not pre-O sently appear in the ISI program, but are recommended herein for inclusion.
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O O O O O O O O O O O REVIEW OF PROPOSED PSC INSERVICE INSPECTION PROGRAM SUM ARY OF RECO MENDATIONS ON ACCEPTABILITY OF SURVEILLANCE REQUIREMENTS (SRs) Sheet 1 SURVEILLANCE REQUIREMENT RECOMENDATION TO NRC AREA NO. TITLE APPROVE. APPROVE, SUBJECT TO:
AS IS MODIFICATION FURTHER STUDY 1.PCRV SR 5.1.2 Reserve Shutdown System Surveillance X AUXILIARY SYSTEMS SR 5.2.1 PCRV Overpressure Safety System Surveillance X SR 5.2.15 PCRV Penetration Interspace Pressure Surveillance X
,7 SR 5.2.16 PCRV Closure Leakage Surveillance X .
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.o 2.PCRV SR 5.2.2 Tendon Corrosion and Anchor Assemblies Surveillance X
$* STRUCTURES SR 5.2.3 Tendon Load Cell Surveillance X SR 5.2.4 PCRV Concrete Structure Surveillance X SR 5.2.5 Liner Specimen Surveillance X SR 5.2.13 PCRV Concrete Helium Permeability Surveillance X SR 5.2.14 PCRV Liner Corrosion Surveillance X SR 5.2.24 Refueling Penetration Holddown Plates Surveillance X
- 3. PCRV. SR 5.2.22 PGX Graphite Surveillance X i INTERNALS SR 5.2.25 Core Support Block Surveillance X SR 5.2.26 Region Constraint Devices Surveillance X
O O O O O O O O O O O REVIEW 0F PROPOSED PSC INSERVICE INSPECTION PROGRAM SUP9(ARY OF REC 0t91ENDATIONS ON ACCEPTABILITY OF SURVEILLANCE REQUIREMENTS (SRs) Sheet 2 SURVEILLANCE REQUIREMENT RECOMMENDATION TO NRC APPROVE, APPROVE, SUBJECT TO:
AREA NO. TITLE AS IS MODIFICATION FURTHER STUDY
, CIRCULATOR SR 5.2.18 Helium Circulators, Surveillance X SR 5.2.19. IACM Diesel-Driven Pumps, Surveillance No act ion required lm SR 5.2.27 Helium Shutoff Valves, Surveillance X ,
h@5. SECONDARY N
SR 5.3.1 Steam / Water Dump System, Surveillance X C0OLANT SYSTEMS SR 5.3.2 Main and Hot Reheat Steam Stop Check Valves, Surveillance X SR 5.3.3 Bypass and Pressure Relief Valves, Surveillance X SR 5.3.4 Safe Shutdown Cooling Valves, Surveillance X SR.S.3.9 Safety Valves, Surveillance X SR 5.3.10 Secondary Coolant System Instrumentation, Surveillance X Note: (1) Approve PSC action to delete from program.
a.
O O O O O O O O- 0 0 0 REVIEW 0F PROPOSED PSC INSERVICE INSPECTION PROGRAM Sum ARY OF RECOM1ENDATIONS ON ADDITIONAL SURVEILLANCE REQUIREMENTS (From APPENDIX A) l AREA STRUCTURE / SYSTEM / C0f1PONENT RECOMMENDATION TO NRC I
- 1. PCRV Structures A-1: PCRV Penetrations and Closures PSC incorporate prescribed requirements 4 l
- 2. PCRV Internals A- 2 : Thermal Barriers Subject to prior U investigation, PSC y develop new SR T
l A- 3 : Core Lateral Restraints Subject to prior i investigation, PSC l develop new SR j
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- 3. Helium A- 4: Helium Purification System Subject to prior Purification investigation, PSC develop ned SR l
- 4. Steam Generators A-5: Steam Generator Tubing PSC submit bi-metallic weld test data.
- 5. Piping Systems A-6: High Energy Piping PSC develop new SR.
3 SECTION 1 RESPONSES TO PROPOSED TECHNICAL SURVEILLANCE REQUIREMENTS FOR PCRV AUXILIARY SYSTEM O
This section responds to the content of PSC-ISI Program submittal to NRC dated February 8,1980, and includes the following subjects:
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- 1. SR 5.1.2 Reserve Shutdown System Surveillance O
- 2. SR 5.2.1 PCRV and PCRV Penetration Overpressure Protection Surveillance O 3. SR 5.2.15 PCRV Penetration Interspace Pressure Surveillance
- 4. SR 5.2.16 PCRV Closure Leakage Surveillance O
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- 1. SR 5.1.2 Reserve Shutdown System Surveillance i
- a. The original Technical Specification dealt with surveillance of system functional capability and structural integrity
- 3 of components. Periodic functional testing of a reserve shutdown assembly in the hot cell facility was also a feature of this surveillance area.
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- b. The basic requirements of the current SR are being augmented by the proposed modification. Operability of valves used 3 as an alternate means of actuating the hopper pressuriza-tion valves, visual examinations of piping located within the refueling penetrations when disturbed for other reasons, gp and pressurizing valves operability testing together with associated position indicating and fail safe features are now included in the scope of the SR.
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- c. The proposed code does not include components of this reactor control system within the current scope of the gp pressure-retaining examinations or functional testing cate-gories, planned maintenance on the principal components l of the system being normally that of scheduled replacement.
gp There are no indications at this time of ASME plans to add requirements for canponents of this system to future code versions.
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- d. The proposed surveillance exceeds Code requirements.
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- O t j e. It is recommended that.NRC approve the SR and proposed
, changes thereto for implementation by the Plant
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- O For detai1s of requirements see Table 1 1 .
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- 2. SR 5.2.1 PCRV and PCRV___ Penetration Overpressure Protection Surveillance J
- a. The original Technical Specification identified requirements for the periodic testing of PCRV rupture disc and safety a
valve assemblies, and safety valves protecting steam genera-tor and circulator penetrations. Instrumentation calibration and testing requirements associated with the above overpressure O
protection components made up the remainder of the sur-veillance coverage for this area.
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- b. The proposed PSC program modifies the current program in several areas; intervals between tests for the principal overpressure protection components identified in (a) have been J
modified slightly, requirements for surveillance of the PCRV safety valve containment tank and associated systems have been added, instrumentation calibration and testing J
requirements have been expanded for the principal over-pressure protection components and added for features of the containment tank.
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- c. Requirements of the proposed Code applicable to the areas
. identified by the SR include examinations and testing of J
pressure-retaining vessel and piping boundaries and examina-tions of bolting and supports as contained in subsections IGB and IGC. Operational testing of valves and their associated position indication features are identified by Subsection IGV.
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- d. Unique to the FSV design is the housing of PCRV safety O
valve assemblies (2) within a pressure vessel (safety valve tank) acting as secondary containment. The primary and secondary boundaries are extended between the PCRV safety O pipe penetration and the tank by a double wall pipe. The interspaces between primary and secondary boundaries are continuously monitored for leakage. The piping interspace O is pressurized, while the safety tank is not pressurized.
Noted in the PSC rationale in support of the proposed surveillance requirements for this area is the position taken that the primary and secondary boundaries are excluded i
from the volumetric and surface weld examinations by the exempted conditions described by the proposed code, Subsections IGB & IGC-1220. Alsd noted is the discussion on primary boundary O
isolation relative to pressure testing, and the subsequent 1
testing method adopted as being that of leak detection during full power operation following each refueling.
I i Delineated in Table 1-2 are the proposed surveillance requirements of the SR compared with those of the proposed Code. The valve testing area of the proposed SR shows no I
significant differences in requirements over the proposed l code, the methods, extent and frequencies being relatively v0 compatible. However,in the area of pressure-retaining boundary integrity examinations the proposed PSC program does not comply with the intent of the proposed code. Assuming O '
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.O the validity of the PSC position with respect to exempted category status for volumetric and surface examination of pressure-retaining welds, and consistent with planned rules development for secondary containments, the following should be included in the proposed modification to the SR:
o PCRV safety piping primary boundary visual examinations of all accessible welds, including integrally welded
.O support attachments. Examinations of bolting and support components.
,0 e Safety tank pressure boundary visual examinations of all accessible welds, integral attachments and support components. Tank boundary pressure testing. Torque or tension testing of bolting not normally disturbed ,
for access to tank internals.
.O e PCRV penetration over pressure protection pipe and valve visual examinations including welded attachments and support components.
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- e. It is recommended that NRC seek PSC modification of the proposed SR by incorporating the above additional surveillance O requirements prior to approving implementation of the SR by the Plant Technical Specifications.
O For details of requirements comparison see Tables 1-2 and 1-2a.
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- 3. SR 5.2.15 PCRV Penetration Interspace Pressure Surveillance 1
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- a. The original Technical Specification was developed to monitor the performance of instrumentation required to ensure that PCRV 33 -
penetration interspace pressure is maintained at acceptable limits.
() b. The proposed PSC program does not modify the current requirement for this surveillance.
-() c. The proposed Code does not address the subject. Further, there are no indications that ASME plans to include the subject of 4
instrumentation operability in future code rules development.
3 d.
The above requires'no further disEussion.on_ the subject.
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l e. It is recommended that NRC approve the proposed SR for DC) implementation by the Plant Technical Specifications.
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! For details of requirements comparison see Table 1-3.
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- 4. SR 5.2.16 PCRV Closure Leakage Surveillance
- a. The original Technical Specification requirements were established
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O and quantification of PCRV primary and secondary boundary leakage.
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- b. The proposed change by PSC adds to the 3R: (1) testing and calibration of instrumentation for the detection of unacceptable pressure and moisture levels in the core support floor and core support floor columns; (2) control, position indication, and failsafe operation of remote manual isolation valves for the pressurizing, purging and vent ng f PCRV penetration closures; and O
(3) testing of check valves in purge lines to refueling and high temperature filter absorber (HTFA) penetrations. .
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- c. The Code position on areas of the SR dealing with instrumentation is as previously stated for companion SR 5.2.15. In the case of pressure-retaining boundary inspection and valve operability O
testing, requirements are clearly applicable to components of PCRV auxiliary piping systems performing the penetration c1 sure functi ns as identified by para raph (b) above.
O Applicable proposed Code requirements are consequently to be found under Subsections IGC and IGV.
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- d. Portions of the auxiliary piping systems covered by this O SR serve as appendages to containment provided by secondary penetration shells and closures. Normal pressures for these systems exceed reactor coolant pressures. Portions of the O systems subject to Class 2 pressure retaining boundary requirements of the proposed Code can be considered as those connecting lines extending beyond the penetration out to and including the O first isolation valves. However, the functions of the systems exempt them from the pipe weld joint non-destructive examination requirements of the proposed Code, with periodic pressure testing O being performed in lieu of this surveillance method. This is consistent with the intent of the proposed Code.
O' Planned performance testing of valves, their remote indication and failsafe features are consistent with the intent of the proposed Code. Minor requirements comparison differences O (Table 1-3) are noted in the scheduled frequencies for sur-veillance testing. In light of the various discussions by PSC supporting the proposed surveillance program and in particular O those describing plant operating experience to date relating to valve operability surveillance findings, it is concluded that this SR and subsequent proposed changes essentially meet the O scope of the proposed Code.
- e. It is reconnended that the NRC approve the proposed SR for O implementation by the Plant Technical Specifications.
For details of requirements comparison see Table 1-3.
Q 1-9
g g SURVEILLANCE REQUIREMENTS (SR): 5.1.2 RESERVE SHUTDOWN SYSTEM SURVEILLANCE TABLE l-1 Sheet 1 i STRUCTURE / SYSTEM / COMPONENT : VAP.IOUS INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N SCOPE OF SURVEILLANCE PSC - PROPOSED PROGRf.M REQUIREMENTS APPLICABLE CODE, OTHER(1)
REQUIREMENTS COPMENTS AREA / a. Hopper - pressurizing test a, through g.: No requirements METHOD b ACM quick disconnect valves-operability test
- c. Reserve shutdown assembly-functional test h d. Piping sections in refueling penetration-visua'l examination
- e. Pressurizing valve-operability test l f. Pressurizing valve-position indicating and failsafe operation test
- g. System instrumentation and control circuit test NOTES:
(1) Source may include 10 CFR 50 Reg. Guides or operating license comitments as identified.
O O O O-O O O O O O O SURVEILLANCE REQUIREMENTS (SR):
5.1.2 RESERVE SHUTDOWN SYSTEM SURVEILLANCE TABLE l-1 Sheet 2 STRUCTURE / SYSTEM / COMPONENT : VARIOUS INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N VI ANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS COPMENTS EXTENT / a. Each hopper every 3 months a. through g.: No requirements FREQUENCY
- b. Every 3 months
- c. One assembly every alternate refueling 7 d. Quantities and intervals in consonance with refueling penetration disassembly sequence
- e. Each subsystem at each refueling
- f. Each subsystem at each refueling
- g. Functional test monthly and calibrate annually NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license connitments as identified.
O O O CL O O O O O O O SURVEILLANCE REQUIREMENTS (SR):
5.2.1 PCRV AND PCRV PENETRATION OVERPRESSURE PROTECTION SURVEILLANCE TABLE l-2 Sheet 1 STRUCTURE / SYSTEM / COMP 0NENT : pcRV
.I INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N (COPE OF SURVEILLANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER(1)EQUIREMENTS R CO M NTS AREA Code Subsection IGV:
- a. Valve testing: a. Valve testing:
e Isolation Valve o Isolation Valve e Rupture disc e Rupture disc e Safety valve e Safety valve o Position indication circuit e Remote position indication for safety / relief train isolation valve
- b. System instrumentation and b. No requirements control circuits testing NOTES:
(1) Source may include 10 CFR 50, Reg. Guides or operating license comitments as idemtified.
SURVEILLANCE REQUIREMENTS (SR): 5.2.1PCRV AND PCRV PENETRATION OVERPRESSURE PROTECTION SURVEILLANCE 12 Sheet 2 TABLE STRUCTURE / SYSTEM / COMPONENT : PCRV INSERVICE SURVEILLANCE - REQUIREMENTS COMPARISON SCOPE OF SURVEILLANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER(1)EQUIREMENTS R COMENTS AREA, Con'd. Code Subsection IGB & IGC:
- c. Pressure-retaining boundaries - c. Pressure-retaining boundaries vessels (penetrations), piping vessels (penetrations), piping and and valves: valves:
, e No requirements-exempt category e Welds PSC postion as per i
status invoked Code paragraphs C IGB and IGC-1220.
e No requirements-exempt category e Supports status invoked See review text on this SR for e Bolting e Bolting recommendations.
e Vessel pressure testing o Vessel pressure testing e Piping pressure testing a Piping pressure testing i
NOTES:
(1) Source may include 10 CFR 50 Reg. Guides or operating license comitments as identified.
7 u u trnm C u u 1) e e SURVEILLANCE REQUIREMENTS (SR): 5.2.1 PCRV PENETRATION OVERPRESSURE PROTECTION SURVEILLANCE TABLE l-2 Sheet 3 PCRV STRUCTURE / SYSTEM / COMPONENT :
INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N V I LANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS COMiENTS METHOD a. Valve testing: a. Valve testing:
o Operational readiness test e Operational readiness test
- Locking verification - Locking verification e Bench test e Test, where designed for this y
capability e Set point test e Set point test e Operation verification test e Operation verification test
- b. Operational readiness test b. No requirements NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license comitments as identified.
O O O O_ O O O O- 0 0 0 SURVEILLANCE REQUIREMENTS (SR): 5.2.1 PCRV AND PCRV PENETRATION OVERPRESSURE PROTECTION SURVEILLANCE TABLE l-2 Sheet 4 STRUCTURE / SYSTEM / COMPONENT : PCRV INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N SCOPE OF SURVEILLANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER(1)EQUIREMENTS R COP 94ENTS METHOD,Contd ,
- c. c.
e No requirements - exempt category status invoked e Volumetric examination e No requirements - exempt category o Volumetric, visual or surface,'
status invoked visual examination
{
e Visual examination e Volumetric, surface, visual examina-tion (Above methods where not exempted ffom examination by the conditions ,
of IGB and IGC-1220) e Leak detection test e Examination during pressure test e Leak detection test e Leak detection test NOTES:
(1) Source may include 10 CFR 50, Reg. Guides or operating license comitments as identified.
! SURVEILLANCEREQUIREMENTS(SR): 5.2.1 PCRV AND PCRV PENETRATION OVERPRESSURE PROTECTION SURVEILLANCE TA8LE l-2 Sheet 5 STRUCTURE / SYSTEM / COMP 0NENT : PCRV
~
INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N V I LANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS COPMENTS EXTENT a. a.
e Isolation valves (two) e Isolation valves e Rupture discs (two) e Quantity at discretion of Owner
, o Safety valves (two) e Safety valves b e Applicable isolation valves e Isolation valves remote indicators remote indicators
- b. Associated with applicable b. No requiremente components of safety train
.g NOTES:
(1) Source may include 10 CFR 50, Reg. Guides or operating license comitments as identified.
e e e e-e G O' 4 ~G U LJ 5.2.1 PCRV AND PCRV PENETRATI0il OVERPRESSURE ,
SURVEILLANCE REQUIREMENTS (SR):
PROTECTION SURVEILLANCE ,,
TABLE l-2 ' Sheet 6 PCRV -; ,
,l STRUCTURE / SYSTEM / COMPONENT : ,
, 4 _
INSERVICE SURVEILLAt:CE - REOUIREMENTS COMPARIS0N ,
'i SCOPE OF -APPLICABLE CODE, OTHER(1)EQUIREMENTS i 'I l
SURVEILLANCE PSC - PROPOSED PROGRAM REQUIREMENTS , R C(M4fMTS -l l
EXTENT, Cent. c. PCRV safety valve penetration, c. Per the components, parts, .
tank and piping trains (2) portions and quantities identified ',
by Code Tables IGB.and-IGC-25G0-1,. '
where not exempted troca examinacipn 4 by the conditier.s of IGB and-IGC-1220.
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1 .
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/ g
, 1 l
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j NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license comitments as identified.
l
g g g g g 5.2.1 PCRV AND PCRV PENETRATION OVERPRESSURE SURVEILLANCE REQUIREMENTS (SR):
PROTECTION SURVEILLANCE l-2 Sheet 7 TABLE STRUCTURE / SYSTEM / COMPONENT : PCRV -.
INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N SCOPE OF SURVEILLANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER(1)EQUIREMENTS R COMENTS FREQUENCY a. a.
o Exercise at interval not to exceed e Full stroke exercise during five years (each with associated each refueling safety valve test) e Examine at interval not to exceed e If testable, frequency at discretion 7 five years (each with associated of Owner 5 safety valve test) e Tested at interval not to exceed e Tested at interval not to exceed five years. On alternating basis, five years one valve at every other refueling.
e Remote position indication e Valve remote position indication test in consonance with isolation observed at least once every valve exercising. two years
- b. Functional test monthly and b. No requirements calibrate annually NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license comitments as identified.
1
U U U U__ U U U U U U v SURVEILLANCE REQUIREMENTS (SR): 5.2.1 PCRV AND PCRV PENETRATION OVERPRESSURE PROTECTION SURVEILLANCE
- TABLE STRUCTURE / SYSTEM / COMPONENT : PCRV INSERVICE SURVEILLANCE - REQUIREMENTS COMPARISON I ANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS COPMENTS FREQUENCY c. c.
Cont.
e No requirements-exempt category e Per the intervals of inspection status invoked program A or B of IGA-2400 m o Bolting, containment tank closure e Per the intervals of inspection L when opened for valve testing program A or 8 of IGA-2400 m
a At each refueling e Per the intervals of inspection program A or B of IGA-2400 e Following each refueling e Following each refueling NOTES:
(1) Source may include 10 CFR 50, Reg. Guides or o rating license connitments as identified.
,, g g g g g ,
5.2.1 PCRV AND PCRV PENETRATION OVERPRESSURE SURVEILLANCE REQUIREMENTS (SR): -
PROTECTI0Y3URVEILLANCE l-2a Sheet 1
^
STRUCTURE / SYSTEM / COMPONENT : PCRV PENETRATION INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N SCOPE OF SURVE!LLANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER(1)EQUIREMENTS R COMENTS Code Subsection IGV:
AREA a. Valve testing: a. Valve testing:
e Isolation valve e Isolation valve e Rupture disc e Rupture disc
. e Safety valve e Safety valve e Remote position indication for e Remote position indication safety train isolation valve
- b. System instrumentation and control b. No requirements circuits testing NOTES:
(1) Source may include 10 CFR 50, Reg. Guides or operating license comitments as identified.
5.2.1 PCRV AND PCRV PENETRATION OVERPRESSURE SURVEILLANCE REQUIREMENTS (SR):
PROTECTION SURVEILLANCE
- TABLE STRUCTURE / SYSTEM / COMPONENT : PCRV PENETRATION INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N I ANCE PSC - PROPOSED PROGRAM REQUIREMENTS PPLICABLE CODE, OTHER EQUIREMENTS COMENTS 1 _._y_ Code Subsection IGC:
AREA, Cont. c. Pressure-retaining boundaries- c. Pressure-retaining boundaries-piping and valves: piping and valves:
e No requirements-exempt category e Welds status invoked PSC position as o No reyairements-exempt category e Bolting per Code para.
status invoked IGC-1220.
- 4 e No requirements-exempt category e Supports status invoked e Piping pressure testing e Piping pressure testing NOTES
(1) Source may include 10 CFR 50, Reg. Guides or operating license connitments as identified.
SURVEILLANCE REQUIREMENTS (SR): 5.2.1 PCRV AND PCRV PENETRATION OVERPRESSURE PROTECTION SURVEILLANCE TABLE l-2a Sheet 3 STRUCTURE / SYSTEM / COMPONENT : PCRV PENETRATION INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N SCOPE OF SUP.VEILLANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER(1 EQUIREMENTS COPMENTS METHOD a. a.
e Operational readiness test o Operational readiness test
- L'ocking verification - Locking verification
, o Visual examination e Test, where designed for this g (non-testabledesign) capability e Set point test e Set point test e Operation verification test e Operation verification test
- b. Operational readiness test b. No requirements NOTES:
(1) Source may include 10 CFR 50, Reg. Guides or operating license comitments as identified.
v v v v v v V v N v C SURVEILLANCE REQUIREMENTS (SR): 5.2.1 PCRV AND PCRV PENETRATION OVERPRESSURE PROTECTION SURVEILLANCE TABLE 1-2a Sheet 4 STRUCTURE / SYSTEM / COMP 0NENT : PCRV PENETRATION INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N VI ANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS COMENTS METHOD, Cont. c. c.
s No requirements-exempt category e Volumetric examination status invoked e Volumetric, surface, visual e Volumetric, surface, visual examination examination e Surface, visual examination e Surface, visual examination (Above methods where not exempted from examination by the conditions of IGC-1220) e Leak detection test e Leak detection test NOTES:
(1) Source may include 10 CFR 50, Reg. Guides or operating license comitments as identified.
SURVEILLANCE REQUIREMENTS (SR): 5.2.1 PCRV AND PCRV PENETRATION OVERPRESSURE PROTECTION SURVEILLANCE TABLE l-2a Sheet 5 STRUCTURE / SYSTEM / COMP 0NENT : PCRV PENETRATION
- INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N SCOPE OF SURVEILLANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER(1)EQUIREMENTS R COMENTS EXTENT a. a.
e Isolation valves (two) for each e Isolation valves penetration (or penetration group) interspace .
- 7 e Selected number of discs and knives e Quantity at discretion of Owner
.W e Safety valves (two) for each e Safety valves penetration (or penetration group) interspace e Applicable isolation valves e Isolation valves remote indicators remote indicators
- b. Associated with applicable components b. No requirements of safety train NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license comitments as identified.
SURVEILLANCE REQUIREMENTS (SR): 5.2.1 PCRV AND PCRV PENETRATION OVERPRESSURE
- PROTECTION SURVEILLANCE TABLE l-2a Sheet 6 PCRV PENETRATION STRUCTURE / SYSTEM / COMPONENT :
i INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N I ANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS C0999ENTS EXTENT, Cont. c. All penetration safety valve c. Per the components, parts, portions piping trains and quantities identified by Code Table IGC-2500-1 where not
, exempted from examination by the conditions of IGC-1220.
b NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license comitments as identified.
O O O O- 0 0 0 0 0 0 0 SURVEILLANCE REQUIREMENTS (SR): 5.2.1 PCRV AND PCRV PENETRATION OVERPRESSURE PROTECTION SURVEILLANCE TABLE l-2a Sheet 7 STRUCTURE / SYSTEM / COMPONENT : PCRV PENETRATION INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N VI ANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS COMMENTS FREQUENCY a. a.
e Exercise at interval of approxi- e Full stroke exercise during each mately two and one half years refueling e Examine at interval not to exceed e If testable, frequency at discretion
{ five years of Owner cn e Tested at interval not to exceed e Tested at interval not to exceed five years, with approximately five years two and one half years between >
tests e Remote position indication test e Valve remote position indication in consonance with isolation observed at least once every valve exercising two years
- b. Functional test monthly and calibrate b. No requirements annually NOTES: (1) Source may include 10 CFR 50, Reg.. Guides or operating license comitments as identified.
o o o a.. O o o^ ~o ~o o ^6 SURVEILLANCE REQUIREMENTS (SR): 5.2.1 PCRV AND PCRV PENETRATION OVERPRESSURE PROTECTION SURVEILLANCE TABLE l-2a Sheet 8 PCRV PENETRATION STRUCTURE / SYSTEM / COMPONENT :
i INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N UVI ANCE. PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS COMMENTS T,
FREQUENCY, & c. c.
Cont.
o No requirements-exempt category e Per the intervals of inspection status invoked Program A or B of IGA-2400 e Quarterly (per SR 5.2.16) e Fo?'owing each refueling bi NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license commitments as identified.
O O O O O O O O O O O 5.2.15 PCRV PENETRATION INTERSPACE PRESSURE SURVEILLANCE SURVEILLANCE REQUIREMENTS (SR): 5.2.16 PCRV CLOSURE LEAKAGE SURVEILLANCE TABLE 1-3 Sheet 1 STRUCTURE / SYSTEM / COMPONENT : PCRV AUXILIARY SYSTEM INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS COMENTS V I LANCE
}
Code Subsection IGV: .
AREA ld.Systeminstrumentationandcontrol a. No requirements circuits testing.
- b. Valve testing, b. Valve testing.
T' c. Valve remote position indication c. Valve remote position indication M testing. testing.
- d. Valve failsafe actuator testing. d. Valve failsafe actuator testing.
Code Subsection IGC:
- e. e Piping pressure-retaining e. e Piping pressure-retaining boundaries: boundaries:
no requirements - exempt cateaory welds & bolting - exempted from status invoked. examination by the conditions of Subarticle IGC-1220 o Piping pressure testing e Piping pressure testing.
NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license comitments as identified.
I
5.2.15 PCRV PENETRATION INTERSPACE PRESSUPsE SURVEILLANCE SURVEILLANCE REQUIREMENTS (SR):
. 16 OSURE NGE SUWEMANE
~
TABLE STRUCTURE / SYSTEM / COMPONENT : PCRV AUXILIARY SYSTEM INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N LVI ANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS COMMENTS METHOD a. Operational readiness test a. No requirements
- b. Operational readiness test b. Operational readiness test
- c. Operation verification test c. Operation verification test
- d. Operation verification test d. Operation verification test
- e. e No requirements - exempt category e. e No requirements - exempted from status invoked examination by the conditions of IGC-1220 e Leak detection test e Leak detection test NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license comitments as identified.
~
5.2.15 PCRV PENETRATION INTERSPACE PRESSURE SURVEILLANCE SURVEILLANCEREQUIREMENTS(SR):
TABLE 1-3 Sheet 3 STRUCTURE / SYSTEM / COMP 0NENT : PCRV AUXILIARY SYSTEM INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS COPMENTS UVI ANCE l
EXTENT Isolation valves and penetration Isolation valves and penetration I pressurization, pu,ge and vent pressurization, purge and vent piping pressure-rataining boundaries. piping pressure-retaining boundaries.
d> FREQUENCY a. Functionally test monthly and a. No requirements calibrate annually.
- b. e Automatic isolation valve test b. e Valve full stroke exercise during each year. each refueling.
e Check valve and remote manual e Check valve exercise once every isolation valve test once every three months (or each refueling).
fifth year. Valve full stroke exercise during l
each refueling.
- c. Valve remote position indication c. Valve remote position indication test once every fifth year. observed at least once every two years. ,
F 1
NOTE 5: (1) Source may include 10 CFR 50, Reg. Guides er operating license comitments as identified.
1
IM
~
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O 1 0 ,[ O' O O' 'O 'O O 5.2.15 PCRV PENETRATION INTERSPACE PRESSURE SURVEILLANCE SURVEILLANCE REQUIREMENTS (SR): 5.2.16 PCRV CLOSURE LEAKAGE SURVEILLANCE TABLE 1 - 3 Sheet 4 PCRV AUXILIARY SYSTEM STRUCTURE / SYSTEM / COMPONENT :
INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER VI ANCE EQUIREMENTS COP 94ENTS FREQUENCY, d. Valve failsafe actuator test once d. Valve failsafe actuator test during Cont'd every fifth year. each refueling.
- e. e No requirements - exempt cateoory e. e No requirements - exempted category status invoked.
O e Quarterly e Following each refueling NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license comitments as identified.
C)
SECTION 2 RESPONSES TO
'C)
PROPOSED TECHNICAL SURVEILLANCE REQUIREMENTS FOR PRESTRESSED CONCRETE REACTOR VESSEL (PCRV)
.O This section responds in part to the content of PSC-ISI Program submittal to NRC dated March 3,1980, and includes the following subjects:
'C)
- 1. SR 5.2.2 Tendon Corrosion and Anchor Assemblies Surveillance
- C) 2. SR 5.2.3 Tendon Load Cell Surveillance
- 4. SR 5.2.5 PCRV Liner Specimen Surveillance i
j() 5. SR 5.2.13 PCRV Concrete Hehum Permeability Surveillance [
- 6. SR 5.2.14 PCRV Liner Corrosion Surveillance
- C)
- 7. SR 5.2.24 Refueling Penetration Holddown Plate Surveillance s r
C) 8. PCRV Penetrations and Closures i
C) 2-1
O
- 1. SR 5.2.2 Tendon Corrosion and Anchor Assemblies Surveillance
- a. The basis for the original Technical Specification was the O continued assurance of the adequacy of the corrosion pro-tection measures applied to PCRV prestressing system components.
O .b. The proposed requirements modify the current position by clarifying tendon wire specimen requirements and intervals between surveillance, and by adding visual examination require-
- O ments for verification of the structural integrity of pre-stressing anchor assemblies.
- O c. Requirements for prestressing system inspections are contained in Subsection IGK of the proposed Code Section XI, Division
- 2. They include visual and material surveillance inspections O conducted to assure the ontinued integrity of structures and effectiveness of corrosion protection methods.
lO Regulatory Guide 1.35 identifies inservice inspection require-t i ments for ungrouted tendons in prestressed concrete con-l tainments. Several of the requirements are applicable to O PCRV structures located inside containment and thus protected fra.: deleterious environmental effects to which the regulatory guide is principally directed. The inservice inspection areas O of the regulatory guide appropriate to the PCRV are considered to include wire specimen material tests, visual examinations of prestressing anchor assemblies and adjacent concrete O structures, load cell monitoring and measures as will assure tendon corrosion protection.
lO 2-2
.O
- d. The proposed FSV program for surveillance of the PCRV prestressing system complies with current proposed Code Subsection IGK requirements and those portions of Regulatory Guide 1.35 analogous to the FSV configuration and prestressing system design. Minor differences exist in the surveillance schedule but these are of
.O little consequence in the application of effective surveillance measures which this program provides.
.O
- e. It is recommended that NRC apprcve the proposed SR for imple-mentation by the Plant Technical Specifications.
lO
- O l
- O O
l O
O For details of requirements comparison see Table 2-1, l
0 2-3
. . . _ _ _ . _ . . - _ - _ _ _ _ . _ _ _ _ . . . _ . _ . . . - . - _ - _ . . . . . . _ _ _ _ _ . _ . - ~ _ - .
.O
- 2. SR 5.2.3 Tendon Load Cell Surveillance
.O
- a. Prestressing tendon assemblies include a number fitted with load cells as a means of monitoring the capacity of the PCRV to g withstand internal pressure. Periodic checks (liftoff tests) on the load cell reference points constitute the planned surveil-lance activity for these structural components.
O
- b. The proposed modification to the current requirement calls for the periodic testing of the load cell alann circuit used to
.O indicate a significant shift in the tendon load setting (s).
- c. Prestressing system instrumentation (load cell) checks are not O addressed by proposed Code Section XI, Division 2. However, the necessity to monitor prestress forces is recognized by the content of Subarticle IGK-3400 which addresses monitoring
!O interval and what constitutes an acceptable rate for the acqui-sition of data.
O d. The above paragraphs require no further discussion.
- O e. It is recommended that NRC approve the proposed SR for imple-o mentation by the Plant Technical Specifications.
I O
For details of requirements comparison see Table 2-2.
O 2-4
O
- 3. SR 5.2.4' PCRV Concrete Structure Surveillance r
s O
- a. The original surveillance requirements were devised to record and track developing crack patterns by visual examination of PCRV surfaces,at and following the structural integrity test and "O
at predetennined intervals thereafter.
- b. The proposed modification to the current requirement compliments
~O the visual examination by the addition of surveillance checks for significant dimensional changes at key structural areas of the PCRV profile, including deformations, during vessel pressurization
!O from atmospheric pressure to operating pressure prior to initial power operation and at predetermined intervals thereafter. Periodic 4 visual examinations of PCRV support structures are further additions
'O to the proposed program.
- c. - Requirements for inviection of CRV surfaces and surveillance of concrete
!O
! structures are contained in Subsection IGK of proposed Section XI, Division 2. Included in the requirements are visual examination of all concrete surfaces not covered by embedded oranchored items.
O These examinations cover top and bottom CRV heads,and CRV sidewall.
Still to be developed in this inspection area .are requirements for CRV support structures.
O
- d. The surveillance requirements being proposed by PSC and those of the proposed Code are generally in agreement. The Code refers to-areas of expected high tensile strain, such as the penetration array on the tophead, and ligaments between major components such as steam generators and circulators. No such distinction is drawn
'O-l 2 1 .
O in the PSC Technical Specification. The frequencies of inspection are compatable. The proposed extent of inspection planned by PSC O following start-up for visual examination of concrete surfaces covers a greater area than the corresponding code requirements; 100% all areas by PSC as against 100% controlled areas plus 25%
O uncontrolled areas by code.
The PSC proposed program of visual examination and material O surveillance as delineated by SR 5.2.4 meets the intent and scope of proposed Code Subsection IGK for inspection of concrete structures.
O e. It is recommended that NRC approve the proposed SR for imple-l mentation by the Plant Technical Specifications.
O O
O O ~
O For details of requirements comparison see Table 2-3.
O 2-6
9
- 4. SR 5.2.5 Liner Specimen Surveillance O a. The basis for the original Technical Specification was the assurance that the structural characteristics of material used for the PCRV liner are not degraded following exposure to the effects
- of irradiation, by the performance of mechanical tests prescribed for specimens removed from the reactor at scheduled intervals.
] b. The proposed change to this SR deals with the inspection interval.
The interval schedule for specimen removal now relates to the
" refueling cycle" rather than to " years of power operation".
D
- c. General requirements for liner material surveillance are included in Subsection IGK of the proposed code. Specific requirements on 3 specimen quantities and surveillance intervals have yet to be determined by ASME.
3 d. The PSC inservice inspection program and subsequent proposed changes for surveillance of liner material meet the intent of the proposed code and provide a suitable scope of inspection.
3 Further, the PSC program appears to comply with the analogous liner material requirements of 10 CFR 50 Criterion 36 and the applicable specimen tests of ASTM-E-185-70 which constitute the bases for liner material surveillance rules being developed by ASME Section XI, Division 2.
- e. It is recommended that NRC approve the proposed SR for implementation
,) by the plant Technical Specifications.
For details of requirements comparison see Table 2-4.
2-7
O
O
- a. The original Technical Specification was developed of necessity to obtain additional supportive data on PCRV integrity.
O ,
- b. The proposed PSC program does not modify the current requirements for this surveillance subject.
O
- c. The proposed code does not address the subject. Further, there are nc indications that ASME plans to include the subject in
,0 future code rules development,
- d. The above requires no further discussion on-the subject.
O
- e. It is recommended that the NRC approve the proposed SR for implementation by the Plant Technical Specifications.
O O-0 0
For details of requirements comparison see Table 2-5.
O 2-8
2 0
- 6. SR 5.2.14 PCRV Liner Corrosion Surveillance O a. The original Technical Specification requirements were established for the detection of liner material degradation from undefined causes.
O b. The proposed PSC program does not modify the current requirements for this surveillance subject.
O c. The proposed code does not address the subject. Further, there are no indications that ASME plans to include the subject in future code rules development.
O
- d. The above requires no further discussion on the subject.
O e. It is recommended that NRC approve the proposed SR for imple-mentation by the Plant Technical Specifications.
'O O
O O
For details of requirements see Table 2-4. ,
l g 2-9
l l
b
- 7. SR 5.2.24 Refueling Penetration Holddown Plate Surveillance D
- a. The proposed program for this SR is a new addition to the Technical Specifications, developed due to the high fre-quency of removal and reinstallation of the components and subsequent potential for damage to bolting.
- b. As described, this is a new SR.
- c. The component of concern may be characterized as being analogous to limit stop components located external to PCRV penetration closures for which periodic visual examinations are required by the proposed Code, Subsection IGG, examination category I-B-1. For comparison purposes however, it has been elected not to categorize the component as such.
O
- d. The above requires no further discussion on the subject.
- e. It is recommended that NRC approve the proposed SR for implementation by the Plant Technical Specifications.
S S
For details of requirements see Table 2-6.
, 2-10
O
- 8. PCRV Penetrations and Closures O
As a structural element of the PCRV this subject can be characterized as an area of inservice inspection interest and 53 consequently subject to some form of examination. Leak rate 1
- testing of penetrations is the subject of SR 5.2.16; otherwise pene-tration pressure retaining boundary integrity examinations are f
- 3) not addressed by the current surveillance program. The PSC
- position on surveillance of these structures is sunnarized i
- in Appendix A, Item A-1 together with proposed Code applicable 53 requirements and subsequent recommendations for surveillance.
1
()
!C) l jC) i 2
- O
- O j
I f 2-11
O O O O O O O O O ~O 'O SURVEILLANCEREQUIREMENTS(SR): 5.2.2 TENDON CORROSION & ANCHOR ASSEMBLIES SURVEILLANCE TABLE 2-1 PCRV STRUCTURES STRUCTURE / SYSTEM / COMPONENT :
INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N SCOPE OF SURVEILLANCE PSC . PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER(1) REQUIREMENTS COP 94ENTS Code Subsection IGK:
AREA a. Prestressing anchor assemblies a. Prestressing anchor assemblies See Note (2) .
- b. Prestressing tendon wire samples b. Prestressing tendon wire samples i
(unstressed) (unstressed) 4
'?
N METHOD a. Visual examination a. Visual examination
- b. Surveillance (of material) b. Surveillance (of material) l l
EXTENT a. 5% assemblies examined at end of a. 25% assemblies examined during each a. Code inspection AND first and third year following inspection interval, interval based FREQUENCY initial prestressing and at five on large HTGR-40 years intervals thereafter, years life with optional intervals 1 b. Samples from 1% prestressing members b. Two prestressing members at end of programs permitted examined at end of first .and third first year and one at end of third (IGK-2400) year following prestressing and and fifth year following CRV
- at five years intervals thereafter, structural acceptance test, with minimum 1% at five year intervals following comnercial service.
NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license comitments as identified.
(2) See text outlining applicable requirements of Reg. Guide 1-35.
t
O O 5.2.3 TENDON LOAD CELL SURVEILLANCE SURVEILLANCE REQUIREMENTS (SR):
i TABLE 2-2 PCRV STRUCTURES STRUCTURE / SYSTEM / COMPONENT :
INSERVICE SURVEILLANCE - REQUIREMENTS COMPARISON PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS COPMENTS I ANCE i
- AREA a. Tendon load cells and No requirements indentified.
I
- b. Load cell alarm circuitry
.i METHOD a. Calibration test m No requirements identified.
,L b. Functional test w
i
- EXTENT a. 10% load cells, i.e., 3 of 27, at No requirements identified.
- AND end of first and third years FREQUENCY following initial prestressing
- and at five year intervals i thereafter.
- b. Annually 4
1 i
i
- NOTES
- (1) Source may include 10 CFR 50, Reg. Guides or operating license comitments as identified. ,
4
)
SURVEILLANCE REQUIREMENTS (SR): PCRV CONCRETE STRbCTURE SURVEILLANCE TABLE 2-3 Sheet 1 STRUCTURE / SYSTEM / COMPONENT : PCRV STRUCTURES INSERVICE SURVEILLANCE - REQUIREMENTS COMPARISON I ANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS COMENTS Code Subsection IGK:
AREA a. PCRV concrete structure
- a. CRV tophead and bottomhead -
Areas shsil include conirol areas which shall be established thus:
- At structural integrity test, 100% of m concrete surface shall be examined
.' (CRV areas A, B, and C),(2) u
- 25% of surface of expected high surface tensile strain during vessel pressurization shai; be included in contral areas (CRV area A).
- 50% of surface of ligaments (3) between steam generator penetrations included in control areas (CRV area B).
All cracks, any portion of which is
> 0.015 in wide, shall be included Tn control areas (CRV areas A and B).
NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license c:msnitments as identified.
(2) Areas of CRV: A - Tophead, B - Bottomhead, C - Sidewall.
l (3) Ligament is defined as area contained by tangents connecting two sides of two penetrations, i.e., main l- steam penetration and FM, HRH, and CRH penetrations.
l r
. ~ .. - .. .. .
SURVEILLANCE REQUIREMENTS (SR): PCRV CONCRETE STRUCTURE SURVEILLANCE ___
TABLE 2-3 Sheet 2 PCRV STRUCTURES STRUCTURE / SYSTEM / CQiPONENT :
INSERVICE SURVEILLANCE - REQUIREMENTS COMPARISDN U El ANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS COMMENTS I
AREA -
2S% of total concrete surface area shall be included in control area (CRV areas A and B).
- Cracks:>.0.01S in, wide founo during examinat' ion of uncontrolled areas n, shall be included in control areas
- 2. for future inspections (CRV areas u'
A and B).
Sidewall -
Areas shall include entire concrete surface. Concrete surface being all areas not covered by embedded or anchored items (CRV area C).
- b. PCRV concrete support strutture. b. Area requirements in course of i
preparation.
i l
l l NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license commitments as identified.
PCRV CONCRETE STRUCTURE SURVEILLANCE SURVEILLANCE REQUIREMENTS (SR):
TABLE 2-3 Sheet 3 PCRV STRUCTURES STRUCTURE / SYSTEM / COMPONENT :
INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS C0tWENTS El ANCE METHOD Visual Examination Visual Examination Y
a
?
NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license commitments as identified.
v v v v v u- v v v v v PCRV CONCRETE STRUCTURE SURVEILLANCE SURVEILLANCE REQUIREMENTS (SR):
TABLE 2-3 Sheet 4 PCRV STRUCTURES STRUCTURE / SYSTEM / COMPONENT :
INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER COMENTS VI ANCE EQUIREMENTS EXTENT a. PCRV concrete structure - a. CRV Tophead and Bottomhead -
- 100% of visible concrete surfaces - 100% of controlled area shall during each inspection interval. be examined during each inspection interval.
- Concrete cracks ? 0.015 in, wide m shall be recorded. - During each inspection interval, 1 25% of uncontrolled areas shall be N - Recorded cracks shall be assessed visually examined. During for changes in length and new successive intervals a different cracks recorded in subsequent exam- 25% of uncontrolled areas shall inations. be examined.
Cracks found within control areas shall be documented.
For cracks > 0.015 in. wide, location, length and width shall be recorded.
NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license comitments as identified.
O O O v O O U U V U 4 PCRV CONCRETE STRUCTURE SURVEILLANCL SURVEILLANCE REQUIREMENTS (SR):
TABLE 2-3 Sheet 5 PCRV STRUCTURES STRUCTURE / SYSTEM / COMP 0NENT :
INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N VI ANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS COMMENTS EXTENT -
If demonstrated during structural integrity test that crack width is insensitive to CRV internal pressure, crack mapping can be performed in either pressurized or unpressurized state.
co Sidewall -
- 25% of sidewall concrete surfaces shall be examined during each inspection interval to detect gross degradation.
- b. 100% of visible concrete for b. Extent of examination in course evidence of structural deterioration. of preparation.
NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license comitments as identified.
o o'~~'~ o o o o o o o~ o o SURVEILLANCE REQUIREMENTS (SR): PCRV CONCRETE STRUCTURE SURVEILLANCE TABLE 2-3 Sheet 6 STRUCTURES STRUCTURE / SYSTEM / COMPONENT :
INSERVICE SURVEILLANCE - REQUIREMENTS COMPARISON PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER COMENTS VI ANCE EQUIREMENTS FREQUENCY a. At structural integrity test and a. At structural integrity test and
- after first and third year subsequent intervals of inspection following initial power operation. at ten year intervals.
Subsequent inspections at ten
- year intervals thereafter.
- b. At ten year intervals when perfonning b. In course of preparation.
]'e PCRV crack mapping surveillance.
- i 4
i NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license comitments as identified.
O O O O D O O O O O O PCRV CONCRETE STRUCTURE SURVEILLANCE SURVEILLANCE REQUIREMENTS (SR):
TABLE 2-3 Sheet 7 PCRV STRUCTURES STRUCTURE / SYSTEM / COMP 0NENT :
i i
INSERVICE SURVEILLANCE - REQUIREMENTS COMPARISON PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS COPMENTS I LANCE L
AREA Code Subsection IGK:
Vessel mid-height and center of tophead. Vessel mid-height and center of tophead.
METHOD Dimensional surveillance of overall Dimensional surveillance of overall l defomations,and deflections, deformations,and deflections, m
b '
EXTENT Above areas during a vessel pressuriza- Above areas during a vessel pressuriza-AND tion from atmospheric to operating tion from atmospheric to operating FREQUENCY pressure prior to initial power pressure just prior to commercial operation and during first depressuriza- service then following at first, third tion after first, third and fifth year. and fifth years. Thereafter, at five Subsequent surveillance perfomed at year intervals.
five year intervals.
NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license commitments as identified.
5.2.5 PCRV LINER SPECIMEN SURVEILLANCE SURVEILLANCE REQUIREMENTS (SR): 5.2.14 PCRV LINER CORROSION SURVEILLANCE ,
TABLE 2-4 STRUCTURE / SYSTEM / COMPONENT : PCRV STRUCTURES INSERVICE SURVEILLANCE - REQUIREMENTS COMPARISON SCOPE OF PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER(1)
REQUIREMENTS COMENTS SURVEILLANCE Code Subsection IGK:
AREA a. Liner material a. Liner material .
- b. Liner representative areas. b. No requirements.
METHOD a. Charpy impact tests a. Charpy impact tests
~
- b. Ultrasonic examination b. No requirements.
EX1dNT a. Af ter fifth refueling cycle, three a. In course of preparation, a Per PSC program AND sets of twelve liner and weld impact tests will FREQUENCY material specimens removed and follow practices of tested to obtain Charpy impact data. ASTil 185-70.
Subsequent removal and testing of Specimen removal similar specimen quantities con- and. testing ducted at each ten year refueling frequency adjust-cycle thereafter. able based on prior' results following
- b. During first schedule pressurization b. No requirements. fifth refueling after end of the third and fifth cycle, year following initial power
~
operation. Subsequent examinations at first scheduled depressurization following each ten year interval.
NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license connitments as identified.
U 0 0 0 0 0 0 0 5.2.13 PCRV CONCRETE HELIUM PERMEABILITY SURVEILLANCE SURVEILLANCE REQUIREMENTS (SR):
TABLE 2-5 PCRV STRUCTURES STRUCTURE / SYSTEM / COMP 0NENT :
INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER COMMENTS VI ANCE EQUIREMENTS AREA PCRV concrete structure No requirements METHOD Penneation test No requirements m
b EXTENT Prior to initial startup and following No requirements Surveillance test AND end of third year of initial power intervals subject FREQUENCY operation. Subsequent tests at to adjustment based five year intervals, on analysis of prior results, following fifth year of initial power operation.
NOTES: (1) Source may include 10 CFR 50, Reg. Guides or, operating license comitments as identified.
e
O O O O O O O O O O O-5.2.24 REFUELING PENETRATION HOLDDOWN PLATE SURVEILLANCE SURVEILLANCE REQUIREMENTS (SR):
TABLE 2-6
^ '
STRUCTURE / SYSTEM / COMPONENT : PCRV STRUCTURES INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N V I LANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS COPetENTS AREA Bolting No requirements'. ,
e METHOD Visual examination No requirements.
EXTENT For holddown plates removed at No requirements.
AND each refueling shutdown.
FREQUENCY NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license conmiitments as identified.
O.
SECTION 3 RESPONSES TO O
PROPOSED TECHNICAL SURVEILLANCE REQUIREMENTS FOR o PCRV INTERNALS
, This section responds in part to the content of PSC - ISI Program
- g sutxnit+ ' to NRC dated March 3,1980, and includes the following subjects
!O 1. SR 5.2.22 PGX Graphite Surveillance
- 2. SR 5.2.25 Core Support Block Surveillance O
- 3. SR 5.2.26 Region Constraint Devices Surveillance l
O 4. PCRV Thennal Barriers
- 5. Core Lateral Restraints O
O O
O
[ 3-1
O
- 1. SR 5.2.22 PGX Graphite Surveillance
.O
- a. The original Technical Specification did not contain require-ments for graphite. Surveillance requirements were sub-sequently added by kaendment #20 dated May 25, 1979, with O
quantities, removal frequencies and examination methods being identified for removable material specimens located in selected regions of the core, O
- b. The proposed requirements modify the current requirements
.O by the deletion of "non-destructive" examination from the range of tests to be perfonned on material specimens removed from the core.
t
- O
- c. Requirements for core support graphite materials are contained in proposed Code Subsection IGG, exa.mination O category I-C-l . These consist of visual examination of core support structures and surveillance of core support post graphite materials. Additional material surveillance
- O requirements for core support graphites are identified in new proposed Subsection IGI. It is the intention of ASME that the material surveillance requirements of this new g draft subsection ultimately replace the requirements of Subsection IGG.
!O Reference is made in the notes to examination Table IGG-2600-1 to emerging new techniques for material properties examination appropriate to core support structures and their consequent
~
3-2
O applications. The reference concerns methods of volumetric O examination of graphite support structures currently being evaluated by laboratories.
O d. The PCRV internal arrangements for large HTGRs can readily accomodate proposed Code Section XI Division 2 requirements, w:lereas the FSV design was developed with less emphasis on O accessibility to conduct inspections of core support structures.
There is a current program to evaluate PGX graphite behavior material performance in selected regions of the core at FSV.
O In identifying the core support posts as the principal component for material surveillance attention, it is not inferred by the proposed Code that other components of graphite core support struc-O tures are of any lesser concern. Graphite support structures as a whole warrant surveillance attention and it is with this expressed intent that the proposed Code addresses O all principal structural graphite support elements. This position is conveyed in the thrust of proposed Code Subsection IGI recently adopted by ASME. This new subsection addresses O the potential for variations in structural graphite properties and the consequent necessity for surveillance testing over l
LO l
e t
l 3-3 0
4 O
a wide range of candidate materials representative of the O same general type of graphite. In the case of FSV, this would include the use of ATJ graphite as a structural material.
, It is concluded that while the current graphite surveillance O program being implemented at FSV responds meaningfully to a particular problem, the necessity exists for the application
, of a' wider scope of surveillance. PGX and ATJ material representative
- O of each type of support component should therefore be included in an expanded scope for core graphite surveillance specimen placement and testing.
O
- e. It is recommended that NRC seek PSC modification of the proposed SR by incorporating the above additional surveillance f
O requirements prior to approving implementation of the SR by the Plant Technical Specifications.
lo O
I
!O J
For details of requirements comparison see Table 3-1.
O
!O 324
O
- 2. SR 5.2.25 Core Support Block Surveillance O
- a. The original Technical Specification and subsequent amendnents did not contain requirements for core support graphite O blocks.
- b. .
The new proposed requirements call for remote visual examination O of core support block top surface regions fitted with PGX graphite specimens, at frequencies consistent with the graphite specimen removal schedule of Technical Specification 0- SR 5.2.22.
- c. Core support block visual examinations are covered by proposed O Code Section XI Division 2 Subsection IGG, examination ,
category I-C-1.
- d. The proposed surveillance for visual examination of top surface areas of core support blocks expected to exhibit high tensile stresses addresses an issue unique to the burn
'O off phenomenon experienced with PGX graphite. No provision is made for selected viewing by the proposed Code. General viewing of representative core support O
structures is intended.
- O i
f
- O 3-5
O.
On large HTGR this is achieved by general viewing of com-O ponents of the core outlet plenum by a remote viewing device inserted into the region of interest from above by means of the Fuel Handling Machine via a suitable channel in O a fuel region core support block, or from below via one of several special inspection penetrations.
O Viewing within the core outlet' plenum is not expected to discern degradation other than gross surface deformation and displaced components, such as tilted O support posts. Although limited, these examinations can be expected to provide adequate assurance of the overall condition of graphite structural members when combined with O the material surveillance requirements of SR 5.2.22. It is therefore considered appropriate that PSC investigate the application of visual examination techniques to components O located within the core outlet plenum and include this examination area and method in the SR where determined to be practicable.
O
- e. It is recommended that NRC defer approval of the proposed SR pending the outcome of further study by PSC of the above O proposed increase to the scope of examination.
For other aspects of viewing in this core region and sub-O sequent review conclusions see the previous discussion under SR 5.2.22.and item A-2 of Appendix A.
For details of requirements comparison see Table 3-1.
O 3-6
O
- 3. SR 5.2.26 Region Constraint Devices Surveillance O
- a. This is a new Technical Specification. Region Constraint Devices restrain fuel region movements during power O operation. Pennanency of this new installation will depend on the ability of the design to perfonn its function.
O b. As described, this is a new requirement.
- c. The installation of fuel region constraint devices is unique O to the FSV plant. There are no proposed Code requirements which cover ' inservice inspection of similar devices on large HTGR.
O
- d. The proposed Technical Specification describing the devices and the planned method for periodic visual examination and O dimensional checks, at the frequencies and of the scope prescribed, should assure the integrity of these devices and mating fuel column components.
O
- e. It is reconnended that NRC approve the proposed SR for O implementation by the Plant Technical Specifications.
O For detail requirements see Table 3-2.
O 327
O
- 4. PCRV Themal Barriers O
This area of inscryice inspection interest is discussed and subsequent reconnendations forsurveillance provided in Appendix A, Item A-2.
O
'O Core Lateral Restraints 5.
This area of inservice inspection interest is discussed and j subsequent recommendations for surveillance provided in Appendix O
! A, Item A-3.
lO 4
I l
!O i
l0 w
O 4
!O 3-8 1_._...._.__ _...- _ _ _ - -
5.2.22 PGX GRAPHITE SURVEILLANCE 5.2.25 CORE SUPPORT BLOCK SURVEILLANCE SURVEILLANCE REQUIREMENTS (SR):
3-1 TABLE PCRV INTERNALS STRUCTURE / SYSTEM / COMP 0NENT : 3 )
INSERVICE SURVEILLANCE - REQUIREMEN15 COMPARIS0N SCOPE OF PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER(1)
REQUIREMENTS COPMENTS SURVEILLANCE Code Subsection IGG:
AREA Core Support Structures - Core Support Structures - See review texts on these SRs e Core support blocks e Representative surfaces of components for recomendations.
serving as vertical supports Y
e PGX graphite surveillance specimens e Material surveillance coupons fabri- See review texts installed in selected core cated from core support floor remove- on these SRs support blocks. able plug of same material as core for recomendations.
support posts.
Code Subsection IGI:
e Materials of core support structures:
support posts and blocks, including side reflector blocks and support blocks.
NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license comitments as identified.
~
D O 6~ O O O O O O O O 1
5.2.22 PGX GRAPHITE SURVEILLANCE 5.2.2S CORE SUPPORT BLOCK SURVEILLANCE SURVEILLANCE REQUIREMENTS (SR):
i 3-1 TABLE PCRV INTERNALS STRUCTURE / SYSTEM / COMPONENT : , Sheet 2 INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N I ANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS COMMENTS i
METHOD e Visual examination e Visual examination, where not exempted Code: Newly develop-from examination by the conditions ed material sur-of Subarticle IGG-1220, veillance tet.,.! ques as they become available, to augment visual
% examination.
e PGX graphite material surveillance e Material surveillance coupons examina-specimeas examinations including tions (undefined), where not exempted oxidation rates / profile evaluations from examinations by the conditions and dimensional checks of Subarticle IGG-1220.
e Materials specimen tests (mechanical and other properties), where not exempted from examination by the conditions of IGI-1220.
NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license comitments as identified.
5.2.22 PGX GRAPHITE SURVEILLANCE 5.2.25 CORE SUPPORT BLOCK SURVEILLANCE SURVEILLANCE REQUIREMENTS (SR):
TABLE 3-1 PCRV INTERNALS STRUCTURE / SYSTEM / COMPONENT : Sheet 3
- INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N I ANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS COPMENTS EXTENT e Top surfaces of core support blocks e Examination shall include representa-j for fuel regions fitted with PGX tive portion of exposed and accessible graphite specimens. areas. At least 25% of support blocks and posts inspected during j each inspection interval, i
, w e PGX graphite specimens installed in e Examinations during each inspection ^
.L five bottom transition reflector interval of material surveillance elements, sixteen specimens per coupons from three separate core reflector element. support block plugs, e Material specimens of each type of graphite for support structures 4 exposed to most severe service conditions for the type. Specimen types and quantities to be determined by Owner.
! NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license commitments as identified.
4
O O O O O O O O O O O 5.2.'22 PGX GRAPHITE SURVEILLANCE j 5,2.25 CORE SUPPORT BLOCK SURVEILLANCE SURVEILLANCE REQUIREMENTS (SR):
- TABLE 3-1 j PCRV INTERNALS STRUCTURE / SYSTEM / COMPONENT
- Sheet 4
, INSERVICE SURVEILLANCE - REQU?REMENTS COMPARISON VI ANCE PSC - PROPOSED PROGP.AM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS COMENTS i
! FREQUENCY e In consonance with PGX graphite e Per the intervals of inspection 1 specimen withdrawal schedule. Program A or B of Subarticle i IGA-2400.
! e Transition element assembly con- e Per the intervals of inspection
,a taining PGX graphite specimens with- Program A or B of Subarticle
- .L drawn' during
- IGA-2400.
i~
2 Second, fourth, sixth, ninth and i seventeenth refuelings.
e Surveillance specimen removal inter-i vals:
{ - First to second refueling (incl.)
] - Second to fourth (incl.) refueling
- Eighth to ninth refueling (incl.) ,
- Twenty-second to twenty-third
. refueling (incl.)
- l. .
NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license connitments as identified.
Cf O O O O -O O O O O O
- " ^ ^
SURVEILLANCE REQUIREMENTS (SR): _
TABLE 3-2 PCRV INTERNALS Sheet 1 STRUCTURE / SYSTEM / COMPONENT :
INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS COMENTS I ANCE l
These devices, I AREA Fuel Region Constraint Devices Not applicable located on top of fuel columns of j three adjacent fuel !
METHOD Visual examination Not applicable regions, were temporarily install-ed to eliminate ,
core temperature g Location verification and engagement / Not applicable fluctuations experi-4, enced following p disengagement checks plant startup. De- ,
. pending upon thier i c
~
performance,the continued nec-l essity for the SR ;
will be detennined following each inspection.
l l
NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license comitments as identified.
^
O O .O O O O O D" D O O SURVEILLANCEREQUIREMENTS(SR):
TABLE 3-2 PCRV INTERNALS STRUCTURE / SYSTEM / COMPONENT : Sheet 2 INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER COPMENTS VI ANCE EQUIREMENTS EXTENT e Devices within visible range (remote Not applicable TV) from core region being refueled.
e Devices disturbed during refueling Not applicable Y
FREQUENCY At each refueling Not applicable a
NOTES: (1) Source may include 10 CFR S0, Reg. Guides or operating license commitments as identified.
C)
SECTION 4 C) RESPONSES TO PROPOSED TECHNICAL SURVEILLANCE REQUIREMENTS FOR PRIMARY COOLANT SYSTEM HELIUM CIRCULATORS O
This section responds in part to the content of PSC-ISI Program submittal to NRC dated March 31, 1980, and includes the following
() subjects:
1.' SR 5.2.17 Helium Circulator Pelton Wheels Surveillance O
- 2. SR 5.2.18 Helium Circulators Surveillance JC) 3. SR 5.2.19 IACM Diesel-Driven Pumps Surveillance i 4. SR 5.2.27 Helium Shutoff Valves Surveillance lO O
O O
O 4_1
O
- a. The original Technical Specification was developed as a response to the discovery of evidence of cavitation and O erosive effects on Pelton Wheel buckets, resulting in the eventual replacement of these components by a modified design. A program of surveillance was inititted for the O replacement components that required the examination of a Pelton Wheel during the first turbine generator removal.
This one-time examination did not produce further evidence
!O 'of the original problem, or uncover other potential structural problems associated with the area of interest.
O b. Fur.ther periodic surveillance of these components will be retained under SR 5.2.18 and the subject SR deleted from the Technical Specification.
- O
- c. There are no Code requirements for examination of these components. Further, there are no indications that ASME O plans to include the subject in future Code rules develop-ment.
1 I'
i C d. No further discussion is required.
- e. It is recommended that NRC approve PSC action to delete the i
lO SR from the Plant Technical Specification.
l O 4-2
O
- a. The cricinal Technical Specification established the frequency for circulators replacement and the scope of surveillance,
- O including methods to be used and areas to be covered for these components, the functions of which include that of emergency core cooling.
- O
- b. The proposed modifications to the current-requirements clarify, but do not modify, the serveillance intervals (ten years) 20 to be followed. Additional requirements have been added in the form of visual examinations for other helium circulator components made accessible in the course of replacement
- O operations for compressor rotor and turbine drive components.
l
- c. Code requirements for circulators fall into three categories of inspection: as pressure-retaining boundaries, as reactor internals;and, as components subject to operational readiness testing. Pressure-retaining boundary requirements are appropriate to circulator casings which form part of primary and secondary boundaries. Reactor internals and performance readiness testing requirements apply to those compressors a
of the core auxiliary cooling system which are provided with an emergency power source. The requirements are contained in the proposed Code Section XI Division 2; subsections IGB, IGC, IGG and IGQ.
.O 4-3
E
)
As the bases for code rules development, large HTGR conceptual designs locate the emergency core cooling circulator within the primary boundary. Part of the circulator casing may form a portion of the primary boundary or may function as a support g"
component for the unit. Another feature of design which may warrant inservice inspection attention is the loop service regime with respect to temperature. Code subsection IGH y' identifies components subject to inspection requirements for materials exposed to elevated temperature service. Areas of large HTGR conceptual designs associated with emergency O core cooling are potential candidates for surveillance of materials under the provisions of IGH.
- d. Operating modes and features of design for the helium circulator which may influence the applicability of ASME Code requirements to the FSV plant include:
O e Unit function includes that of emergency core cooling.
e Configuration conducive to ease of unit and parts replacement.
O e Cnmponent materials not exposed to long tenn effects of elevated temperature service.
e Continuous monitoring capability to verify performance characteristics.
e Normal operation expected to provide adequate exercising frequency for some active components to demonstrate
- O performance. For other active components, limitations on exercising during plant operat',on identified.
l
.3 44 i
O Figure 1 depicts the principal areas of inspection for g components of primary loop circulation pertinent to the discussion: the penetration, helium circulator, helium shut-off valve and coolant-loop ducting. The schematic is repre-O sentative of the FSV concept. It identifies and categorizes areas of inspection interest relative to the proposed require-4 ments of the Code and to those of the PSC program. As a
- O further aid for reviewing the comparative differences in the proposed requirements, attention is directed to Table 2-1 on this SR. .
O FSV operating experience to date (specifically circulator change-outs and subsequent materials investigative testing and analyses f f nns and causes of degradation to drive
'O components) has provided the bases for a meaningful program of surveillance for circulator components. Pressure-retaining
.g boundary examinations should also be an important facet of the planned surveillance program. The position that the double closure concept exempts primary and secondary boundaries from volumetric and surface examinations of weids and bolting
.O neglects the safe shutdown cooling function of this component.
For further discussion of this point see Appendix A, item A-1. -
The occasions for circulator change out provide the cpportunity O
for extensive inspection of penetration interspace boundaries and structures. It is recommended that these inspectfons include the following:
O n"
4-5
O e Penetration primary boundaries forming part of circulator l[) casings, or performing support functions or other functions vital to circulator structural integrity to be examined to the maximum extent practicable. This to
-(C) include surface examination of accessible welds at structural discontinuities in representative areas of pressure-retaining boundaries, including support attachnEnt JC) welds, and visual examinations of bolting.
e Penetration secondary boundaries (shells and closures) iC) to be examined in accordance with Apperidix A, item A-1 recommendations. This as a surveillance requirement for PCRV Structures.
O
- e. It is recommended that NRC seek PSC modification of the proposed SR by incorporating the above additional surveillance requirements (D) prior to approving implementation of the SR by the Plant Techni-cal Specifications.
1
.o i
l O
r' O
For details of requirements comparison see Table 2-1.
() 4-6
O
- 3. SR 5.2.19 IACM Diesel-Driven Pumps Surveillance 3
Under a previous ammendment to the Technical Specifications this SR was deleted.
3 O
O O
O O
O g
O 4-7
O
'O
- a. This is a new Technical Specification requiring the surveillance of helium shutoff valve operation by monitoring annually
'O cr at the next scheduled plant shutdown if such monitoring has not been performed during the previous year.
- O b. As described, this is a new requirement,
- c. Proposed Code requirements for this component are identified O under the check valve category of Subsection IGV.
- d. The " failure to seat" consequences af helium circulator valve oper-
- O r tion are noted in the PSC rationale in support of the proposed surveillance requirements. The ability to detect malfunction of the valve by installed instrumentation is O also noted. The proposed surveillance is considered to be consistent with the intent of the Code.
,0 e. It is recommended that NRC approve the propased SR for implementation by the Plant Technical Specifications.
O i
1 O For details of requirements comparison see Table 2-2. I l
l 4-8 O
1
O O O O- O O O '~O O O U SR 5.2.17 HELIUM CIRCULATORS SURVEILLANCE SURVEILLANCE REQUIREMENTS (SR):
TABLE 2-1 STRUCTURE / SYSTEM / COMPONENT : PRIMARY COOLANT SYSTEM Sheet 1 of 9 4
INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS COMENTS VI ANCE Code Subsections IGB AREA
- a. Pressure-retaining boundaries - a. Pressure-retaining boundaries - Applicable categor-Circulator, casing: les of Code Tables e No requirements - exempt category e Circulator casing fonning portions of IGB-2500-1.
status invoked for non-removable primary pressure-retaining bound- fohePa $
portions. aries, welds and bolting ra'tion IG 2500-1.
a e Removable portions.
- b. Circulator supports: b. Circulator support members integrally Applicable categor-e Attachments integrally welded to welded to pressure-retaining ies of Code Tables pressure-retaining casings casings, and support components. IGB (non-removable),
e Support components, bolted attachments (non-removable).
Code Subsection IGG e Not applicable. e Circulator supports (reactor Code Table IGG-2500-internals category) 1, Category I-E-1.
NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license conunitments as identified.
X
O O O O O. O O O O O O SURVEILLANCE REQUIREMENTS (SR): SR 5.2.17 HELIUM CIRCULATORS SURVEILLANCE TABLE 2-1 STRUCTURE / SYSTEM / COMPONENT : PRIMARY COOLANT SYSTEM Sheet 2 of 9 INSERVICE SURVEILLANCE - REQUIREMENTS COMPARISON VI ANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS COP 99ENTS AREA c. e Circulator wheel rotor, c. e No requirements.
drive turbine wheel and -
Pelton wheel e All other components of removed e No requirements.
circulator
'?
Codd Subsection IGQ:
- d. Circulator ope i%n d. Compressor (circulator) testing.
Code Subsection IGV:
- e. Valve testing L.iaft brake & e. Valve testing (automatic isolation shutdown seal) valve)
NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license comunitments as identifth
b SR 5.2.17 HELIUM CIRCULATORS SURVEILLANCE SURVEILLANCE REQUIREMENTS (SR):
TABLE PRIMARY COOLANT SYSTEM STRUCTURE / SYSTEM / COMPONENT : Sheet 3 of 9 INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N I ANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS COPMENTS
~
- a. e No requirements-exempt category METHOD a. e Volumetric, surface and visual See review text on status invoked for non-removable examinations, as appropriate. this SR for portions. recommendations.
e Visual examination of removed items j .
Ii b. e No requirements-exempt category b. Volumetric, surface and visual exam % See review text on
]O status invoked for non-removable tions, as appropriate. this SR for
- portions, recommendations.
e No requirements e Visual examination.
e Not applicable e Visual examination Code: When made accessible for
- other reasons.
l c. e Volumetric and surface examina- c. e No requirements.
tions.
e Visual examination. e No requirements.
NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license comitments as identified.
O O O O O O O O O O O SURVEILLANCE REQUIREMENTS (SR): SR 5.2.17 HELIUM CIRCULATORS SURVEILLANCE TABLE 2-1 STHUCTURE / SYSTEM / COMPONENT : PRIMARY COOLANT SYSTEM Sheet 4 of 9 INSERVICE SURVEILLANCE - REQU.Y.REMENTS COMPARISON V I LANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS COMENTS METHOD d. Performance verification during d. Operational readiness test.
nonnal operation.
- e. Performance verification during e. Operational readiness test, normal operation.
?
2 NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license comitments as identified.
.. H U A ORS SURVE M AN E SURVEILLANCE REQUIREMENTS (SR):
TABLE 2-1 PRIMARY C0OLANT SYSTEM STRUCTURE / SYSTEM / COMPONENT : Sheet 5 of 9 INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIRE"ENTS COMENTS V I LANCE EXTENT a. Casing of replaced circulator. a. Per the components, parts, portions '
9: Generally one and quantities identified by above LC .Jnent in each references. group of similar ,
components serving I same function.
l Code: Generally one
> b. e All support members and components made accessible during circulator
- b. e Per the components, parts, portions
& quantities identified by above component in each l
replacement. references, group of similar components serving same function.
j e 100% of all support components in one circulator, NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license commitments as identified.
SURVEILLANCE REQUIREMENTS (SR): SR 5.2.17 HELIUM CIRCULATORS SURVEILLANCE TABLE 2-1 STRUCTURE / SYSTEM / COMPONENT : PRIMARY COOLANT SYSTEM Sheet 6 of 9 INSERVICE SURVEILLANCE - REQUIREMENTS COMPARISON SCOPE OF SURVEILLANCE PSC PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER(1)
REQUIREMENTS COP 91ENTS EXTENT c. e Components of replaced circulator, c. e No requirements.
identified in (a) above.
- d. All circulators (primary coolant d. All auxiliary circulators Circulators with loop). (primary coolant loop). emergency core
? cooling function.
^
- e. All circulators, shaft break and e. All isolation valves.
shutdown seals.
1 t
l NOTES: (1) Source may include 10 CFR 50 Reg. Guides or operating license comitments as identified.
t
I SURVEILLANCE REQUIREMENTS (SR): SR 5.2.17 HELIUM CIRCULATORS SURVEILLANCE
, TABLE 2-1 STRUCTURE / SYSTEM / COMPONENT : PRIMARY COOLANT SYSTEM t Sheet 7 of 9 n
INSERVICE SURVEILLANCE - REQUIREMENTS COMPARISON PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS COMMENTS URV I LANCE FREQUENCY a. One circulator during first main a. Per the intervals of inspection 4 turbine-generator overhaul and one Program A or B of Subarticle "
uninspected circulator at each ten IGA-2400.
year interval thereafter.
, b. One circulator during first main b. Per the< intervals of inspection l a. turoine-generator overhaul and one Program A or B of Subarticle
- 1. uninspected circulator at each ten IGA-2400.
- "' year interval thereafter.
i i
i f
1 4
NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license commitments as identified.
i SR 5.2.17 HELIUM CIRCULATORS SURVEILLANCE SURVEILLANCE REQUIREMENTS (SR):
TABLE 2-1 PRIMARY COOLANT SYSTEM STRUCTURE / SYSTEM / COMP 0NENT : Sheet 8 of 9 INSERVICE SURVEILLANCE - REQUIREMENTS COMPARISON VI ANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS C0fmENTS
! FREQUENCY c. e Components of one circulator c. e No requirements. ,
during first main turbine-generator overhaul and one uninspected cir-i culator at each ten year interval thereafter.
? e As above for initial inspection e No requirements, ig and thereafter of components made accessible by disassembly to inspect circulator wheels.
i 1 ,
NOTES: (1) Source may include 10 CFR 50, Reg, Guides or operating license comitments as identified.
O O O O O O O. O O O- O SR 5.2.17 HELIUM CIRCULATORS SURVEILLANCE SURVEILLANCE REQUIREMENTS (SR):
TABLE 2-1 PRIMARY COOLANT SYSTEM STRUCTURE / SYSTEM / COMPONENT : Sheet 9 of 9 INSERVICE SVRVEILLANCE - REQUIREMENTS COMPARISON V I LANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS COP 9 TENTS s-FREQUENCY d. Quarterly test when not operated more d. e Monthly readiness test. -
frequently during normal operation, e Annual full flow test.
- e. Yearly test when not gperated more e. Valve full stroke exercise.'
t' frequently during normal during each refueling.
O operation.
NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license comitments as identified.
O O O O O O ~O O O. O .O SURVEILLANCF.. REQUIREMENTS (SR): SR 5.2.27 HELIUM SHUT 0FF VALVES SURVEILLANCE TABLE 2-2
^ ^
STRUCTURE / SYSTEM / COMPONENT :
INSERVICE SURVEILLANCE - REQUIREMENTS COMPARISON V I LANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS COPMENTS Code Subsection IGV:
AREA a. Valve testing. a. Valve testing.
METHOD b. Opsrattonal readiness test. b. Operational readiness test.
EXTENT c. All helium circulator shutoff valves. c. Isolation check valves.
FREQUENCY d. Monitored annually. d. Check valve exercise once every three months (or each refueling, when impracticable during operation).
NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license connitments as identified.
O L l
I PCRV Interior Helium Shutoff o Valve (A) (B) d I Compression Wheel O Fairing and C.C (A)
Diffuser a w Surveilla,nce requirements j Gas Inlet Plenum
- O identified for the area by
(A) - PSC Program
/ N (B) - Proposed Code Shaft Brake and Boundaries f Primary (B) Shutdown Seal (A)(B) ,
O L ' l. ' el
~
. r
.; c
~-
- .~
l i
Circulator i Component i ;
, Suocort(B)
I Attachments O and Support Circulator Members (B) H I Drive 3
', PCRV Bottomhead j Structure
~
f 0 -i, l
..p.l;.
Q .x
.i Steam / Water Turbine Steam / Water Turbine r rna 41 - r Discharge (A)(B) Supply (A)(B)
/ $
Circulator '4 Auxiliary Systems Secondary Boundaries (B)
O FIGURE 1 CIRCULATOR PENETRATION & IHLET GAS PLENUM,
.O SCHEMATIC SHOWING PRINCIPAL COMP 0NENTS & AREAS OF INSPECTION 4-19
__ _ _ _ . _~. _ _ _ . - -
.O SECTION 5 RESPONSES TO y
PROPOSED TECHNICAL SURVEILLANCE REQUIREMENTS FOR SECONDARY COOLANT SYSTEM O
This section responds in part to the content of PSC - ISI Program submittal to NRC dated March 31, 1980, and includes the following O ,
subjects:
- 1. SR 5.3.1 Steam $ater Dep Systs SuneiHance O
L
- 2. SR 5.3.2 Main and Hot Reheat Steam Stop Check Valves Surveillance jO .
- 3. SR 5.3.3 Bypass and Pressure Relief Valves Surveillance lO 4. SR 5.3.4 Safe Shutdown Cooling Valves Surveillance
- 5. SR 5.3.9 Safety Valves Surveillance O ,
- 6. SR 5.3.10 Secondary Coolant System Instrumentation Surveillance O
O lO 5-1 l
I
)
- 1. SR 5.3.1 Steam / Water Dump System Surveillance
)
- a. The original Technical Specification was developed for the periodic operational testing of valves used to dump steam
) generator inventory to the dump tank in the event of a steam generator tubing failure. Included in the surveillance were requirements for functional checks and calibration of
) tank level, pressure, temperature indicators and other associated instrumentation.
) b. The proposed PSC program does not modify the current requirements for this surveillance subject.
) c. Proposed Code requirements applicable to operational testing of the dump valves are identified under Category B valves of Subsection IGV,
)
- d. The proposed surveillance for dump systcm valve testing is consistent with the intent and scope of the Code.
)
Component structural integrity requirements beyond those of nonnal monitoring for leakage of pressure retaining
) boundaries is not considered to be necessary, as described by the PSC rationale provided in support of the proposed scope for surveillance of secondary coolant systems.
) This position is addressed in-the discussions of A.ppendix A ,
as c separate topic. Meantime, the review of this SR is limited to that on valve operability testing.
5-2 . - . . _ . . _ _ . - - -
i
- e. It is recommended that NRC approve the proposed SR for imple-
) mentation by the Plant Technical Specifications.
)
n D
D D
D D
D l
For details of requirements comparison see Table 5-1 0 5-3
4
- 2. SR 5.3.2 Main and Hot Reheat Steam Stop Check Valves Surveillance O
- a. The original Technical Specification was developed to verify operability of the main and reheat steam stop check valves by O periodic stroking.
- b. The proposed PSC program does not modify the current require-
- O ments for this surveillance subject.
- c. Proposed Code requirements for exercising the stop check
- O valves are identified in Subsection IGV, Subarticle IGV-3400,
- d. The proposed surveillance for periodic exercising of main and
.O hot reheat steam stop check valves is consistent with the intent and scope of the Code.
O Component structural integrity requirements beyond those of nomal monitoring for leakage of pressure retaining boundaries is not considered to be necessary, as described by the PSC
- O rationale provided in support of the proposed scope for sur-veillance of secondary coolant systems. This position is addressed in the discussions of Appendix A as a separate topic.
=O Meantime, the review of this SR is limited to that on valve operability testing.
- O c. It is recomended that NRC approve the proposed SR for imple-mentation by the Plant Technical Specifications.
10 5-4
O
- 3. SR 5.3.3 Bypass and Pressure Relief Valves Surveillance O
- a. The original Technical Specification was developed for the periodic operational testing of valves used for (a) bypassing f main steam f r safe shutdown cooling components, including
- O circulator drive, following turbine trip or loop isolation, (b) main steam relief during these events and (c) assurance g of continuous steam flow from circulators during decay heat removal. Valves include main steam and hot reheat steam bypasses and power operated pressure reliefs.
10'
- b. The proposed PSC program does not modify the current requirements for this surveillance subject.
- O
- c. Operability testing of valves covered by the proposed SR are identified in proposed Code Subsection IGV, under
- O Category B valves.
- d. The proposed surveillance for the performance of operability
- O testing f the valves identified above is consistent with the intent and scope of the Code.
O Component structural integrity requirements beyond those of nomal monitoring for leakage of pressure retaining boundaries is not considered to be necessary, as described by the PSC O rationale provided in support of the proposed scope for sur-veillance of secondary coolant systems. This position is addressed in the discussions of Appendix A as a separate topic.
_O 5-5
i 1
.;O 1
i i
l Meantime, the review of this SR is limited to that on valve ,
'O l operability testing.
i ;
1
)
! e. It is recommended that NRC approve the proposed SR for imple-
,'O
. mentation by the Plant Technical Specifications. ;
4 4
i i iO
- i. '
i :
i
!O~
!O i
.I i
f lO-(
O O
1 l-O P
'O 5-6 :
.u.-_.___ . . _ _ _ _ _ _ _ _ . _ - _ _ _ . _ _ _ - , _ -..-.;
O
- 4. SR 5.3.4 Safe Shutdown Cooling Valves Surveillance O
- a. The original Technical Specification was developed for periodic operability testing of valves vital to the safe O
shutdown cooling mode, and activated remotely by pneumatic, hydraulic or electrical means.
O b. The proposed program modifies the current program by extending the valve testing interval by approximately 6 months and by including check valves vital to initiation of the safe shutdown cooling mode.
- c. Valve testing requirements appropriate to this area are
- O identified in proposed Code Subsection IGV. These include valve exercising, including confimation of check valve' opera-tion, verification of remote position indication and stroke time measurements for power operated valves.
- d. The proposed surveillance for the valves identified by the pro-posed SR and subsequent modification thereto, Paragraph b, is considered to be consistent with the intent and scope of the proposed Code.
!O Component structural integrity requirements beyond those of nonnal monitoring for leakage of pressure retaining boundaries O
is not considered to be necessary, as described by the PSC rationale provided in support of the proposed scope for sur-veillance of secondary coolant systcms. This position is
- O-5-7
)
addressed in the discussions of Appendix A as a separate topic.
Meantime, the review of this SR is limited to that on valve operability testing.
)
- e. It is reconnent,ed that NRC approve the proposed SR and proposed changes thereto for implementation by the Plant Technical Specifications.
)
)
)
)
)
) 5-8
O
- 5. SR 5.3.9 Safety Valves Surveillance 1
O
- a. This is a new Technical Specification developed for the periodic testing of safety valves installed in main steam, reheat steam and generator steam / water dump systems.
- b. As described, this is a new requirement.
!O
- c. Operability testing of valves covered by the proposed SR are identified in proposed Code Subsection IGV, under Category n C valves.
o
- d. The proposed surveillance for the valves identified by the proposed SR is consistent with the intent and scope of the O
proposed Code.
I Component structural integrity requirements beyond those of
- O j nonnal monitoring for leakage of pressure retaining boundaries is not considered to be necessary, as described by the PSC rati nale pr Vided in support of the proposed scope for sur- '
- O veillance of secondary coolant systems. This position is addressed in the discussions of Appendix A as a separate t pic, meantime, the review of this SR is limited to that on
~O valve operability testing.
- e. It is rec mended that NRC approve the proposed SR for imple--
IO mentation by the Plant Technical Specifications.
g 5-9
O
- 6. SR 5.3.10 Secondary Coolant System Instrumentation Surveillance
~
.O
- a. This is a new Technical Specification developed to verify the performance of instrumentation used to detect conditions
.O in portions of the secondary coolant system vital to the safe shutdown cooling mode.
'O
- b. As described, this is a new requirement.
- c. The proposed Code does not acdress the subject of instrumentation
'O performance.
- d. The proposed Code position requires no further discussion 10 on the subject.
- e. It is recomended that NRC approve the prooosed SR for imple-
- O mentation by the Plant Technical Specifications.
- O IO'
.O
'O 5-10
O--
O O O O O O O O O O 5.3.1, 5.3.2, 5.3.3, 5.3.4 and 5.3.9 SURVEILLANCEREQUIREMENTS(SR):
- TABLE 5-1 Sheet 1 SECONDARY COOLANT SYSTEM, VALVES SURVEILLANCE STRUCTURE / SYSTEM / COMPONENT
INSERVICE SURVEILLANCE - REQUIREMENTS COMPARISON V I LANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS COP 9 TENTS Code Subsection IGV-AREA Valve testing Valve testing e Power operated isolation valves, e As for valve.Cateoories B, C, and E.
including check valves.
1 e Safety valves m
S e Locked valves NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license connitments as identified.
O O O O.. O O O O O O O SURVEILLANCE REQUIREMENTS (SR): 5.3.1, 5.3.2, 5.3.3, 5.3.4 and 5.3.9 TABLE 5-1 Sheet 2 STRUCTURE / SYSTEM / COMPONENT : SECONDARYCOOLA[lTSYSTEM,VALVESSURVEILLANCE INSERVICE SURVEILLANCE - REQUIREMENTS COMPARISON V I LANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS COMENTS j METHOD e Operational readiness tests, e By the applicable methods identified including: for category B valves, including:
)
Exercising Exercising Stroke time measurement Stroke time measurement C Disc position verification Disc position verification Remote position indication Remote oosition indication verification verification l e Setooint test e Setpoint test ,
e Locking verification e Locking verification d
e b
NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license commitments as identified.
~
O O O O .- O ~'O' 'O O O ~O O 5.3.1, 5.3.2, 5.3.3, 5.3.4 and 5.3.9 SURVEILLANCE REQUIREMENTS (SR): _
5-1 Sheet 3
. TABLE STRUCTURE / SYSTEM / COMPONENT : SE0CNDARY C00LANT SYSTEM, VALVES SURVEILLANCE INSERVICE SURVEILLANCE - REQUIREMENTS COMPARISON VI ANCE PSC - PP' POSED PROGRAM REQUIREMENTS APPLICABLE CODE. OTHER EQUIREMENTS COPMENTS EXTENT All essential vaives associated with Valves, including their activating and initiation of the safe shutdown cooling oosition indicatino systems, required mode. in shutting down the reactor.
FREQUENCY e For valves not exercised durino normal e Full stroke exercised during each Y' operation, tested annually or at refueling.
C next scheduled shutdown where not tested during previous year. (Incl. Valve remote position indication remote position indication.) observed at least once every two years.
Tested every three months (steam / water dump valves) e Tested at interval not to exceed e Tested at interval not to exceed five years five years e Eyanined with associated upstream o Examined at frequency for other isolation valve associated rystem isolation valves l
I NOTES: (1) Source may include 10 CFR S0, Reg. Guides or operating license comitments as identified.
.O 1
1 4 APPENDIX A O ADDITIONAL SURVEILLANCE REQUIREMENTS Identified by this Appendix are areas of inservice inspection interest considered to warrant greater attention-in order to meet the O- intent and scope of the proposed Code. These include areas addressed f by PSC in rationale supporting the scope of surveillance proposed by the SRs, as well as related areas not identified by proposed SRs. .
O Recomendations for additional surveillance are, in most cases, predicated on the outcome of prior investigation by PSC to determine applicability; consequently they are not expected to result in automatic adoption.
- O Included in these additional areas of inservice inspection interest are the following structures, systems and components:
- O A-1 PCRV Penetrations and Clcsures A-2 PCRV Thermal Barriers iO A-3 Core Lateral Restraints A-4 Helium Purification System 4
A-5 Steam Generator Tubing
- O' A-6 Migh Energy Piping b -
'O O-A-1
O APPENDIX A O
A-1 PCRV Penetrations and Closures O. a. FCRV penetration configurations for the FSV design consist of two independent closures arranged in series and which provide primary and secondary containment. The interspace O between closuret is normally pressurized to a level slightly over primary coolant pressure. Secondary closure stiuctures shells and closures, consequently, see interspace pressure.
O Pressure retaining boundary surveillance requirements proposed by PSC for these Class I structures are confined to periodic O pressure testing to detect loss of penetration structural integrity (SR 5.2.16). The rationale behind this surveillance position is that with this penetration assembly design O (double closures) simultaneous failure of both primary ano secondary closures is considered to be an incredible event.
Consequently, periodic monitoring for leakage constitutes O the only form of inservice inspection required. The PSC rationale further supports this scope of surveillance by citing the exempted categories of the proposed Code as
- O being applicable exclusions
- "both primary and secondary closures are exemoted from volumetric and surface examinations since they are not utilized for shutdown heat removal, or
- O chemical ingress detection or control, and failure of the component would not result in a primary coolant system depressurization which exceeds the rate established for the
.O A-2
O design basis depressurization accident."
O
- b. Proposed Code Section XI, Division 2 provides rules for inspection and testing of PCRV penetration assemblies
() based on a single (primary) penetration closure design, representative of the current large HTGR concept. The requirements for penetration structures include volumetric
() or surface examination of pressure-retaining welds and bolting, visual examinaticn of flow restrictors and limit stops, examinations for leakage and pressure testing.
() The applicable areas of the Code are Subsections 1GB and IGC for Class 1 and Class 2 penetrations respectively, and Subsection IGG for limit stops and flow restrictors.
O .
- c. The FSV penetration double closure design concept places this component in a unique inspection category not directly
() addressed by the proposed code. The PSC rationale wculd invoke exempted status from volumetric and surface examinations based on component function and design. However, the basic precepts of C) the proposed Code governing the scope of examination for PCRV penetrations are generally applicable to the FSV desigre. The following FSV penetrations fall within non-exempted categories:
O
,() e Steam Generator and Helium Circulator penetrations utilized for shutdowr, heat removal operations.
C) A-3
7 e Refueling penetrations utilized for nuclear reactivity lC control.
e High Temperature Filter Absorber and Helium Purification O
Piping penetrations utilized for chemical ingress control.
O All other FSV penetrations, failure of which will not result in a DBDA, may be considered as being exempted from volumetric and surface examinations for pressure-retaining boundaries.
- O These include
e Top and Bottom Access penetrations iO e Safety Valve penetrations t
e Instrumentation penetrations O
With due consideration of the FSV penetration design config-uration and consistent with the intent of the proposed Code the following proposed surveillance requirements are O
recommended:
For non-exempted components -
10 l Surveillance of a representative number of penetration assembly areas designed as secondary containment (shells and closures) to be performed to the maximum extent practicable O
over the life of the plant, as noted below.
l 0 A-4
- - , . - _ . ~. _. -
O e Surface examination of accessible pressure-retaining
. circumferential welds (I) in penetration O
shells and closures; integral attachment welds not backed by concrete; and circumferen'tial welds II) in penetration shells backed by concrete but outboard
.O of any shear anchor. Examinations may be performed from the outside of the penetration or from the inter-
'\
j space region where removal of the penetration closure
,' is a regularly scheduled event (refueling, circulator change-out,etc.).
- O e Visual examination of bolting. Additionally, tension testing of bolting not normally disassembled for maintenance or any other scheduled event.
- O e Visual examination of accessible limit stops and structures identified as flow restrictors.
- O e Leak testing.
- O For exempted components -
Surveillance of penetration assemblies designed as secondary containment (shells and closures) to be nerformed
.O to the maximum extent practicable over the life of the plant, as noted below.
'O O A5 1
- o e Visual examination of pressure retaining welds (I}
- O .in accessible areas of penetration shells and closures outboard of concrete.
O e Visual examination of bolting, torque and tension testing.
e Visual examination of accessible limit stops and structures
-O identified as flow restrictors.
Leak testing.
e lO
- d. It is recommended that NRC seek modi,fication of the -
proposed PSC-inservice inspection program to include the O prescribed additional surveillance requirements in the PCRV structures section of the Plant Technical Specifications.
- O I
l IO l
t l
'O l
(1) Prinrily, welds at structural discontinuities.
.'O - For details of requirements comparison see Table A-1.
lO A-6
. . . - - . - . . . - - . . _ - - - - _ .. . - . -._.- . ,.- ~ . .
~~
SURVEILLANCE REQUIREMENTS (SR): _
TABLE A-1 Sheet 1 STRUCTURE / SYSTEM / COMPONENT : PCR'l PENETRATIONS & CLOSURES INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N El ANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICADLE CODE, OTHER EQUIREMENTS COWENTS AREA Code Subsections IGB & IGC:
Primary and secondary penetrations and Primary and secondary penetrations and Applicable categories closures: clesures: of Code Tables IGB
& IGC-2500-1.
e No requirements - exempt category e Pressure retaining welds and bolting, status invoked, e System pressure testing . System pressure testing Code Subsection IGG:
Code Table IGG-2500-e No requirements . Flow restrictors and limit stops f'y ,f METHOD e No requirements-exempt category e Volumetric, surface and visual status invoked. examinations, as appropriate.
(Above methods where not exempted from examination by che conditions of IGB'& IGC-1220) e Leak detection test.
. Leak detection test When made accessibla
= No requirements e Visual examination for other reasons.
NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license commitments as identified.
SURVEILLANCE REQUIREMENTS (SR): __
TABLE A-1 Sheet 2 STRUCTURE / SYSTEM / COMPONENT : PCRV PENETRATIONS & CLOSUP,ES INSERVICE SURVEILLANCE - REQUIREMENTS COMPARISON PSC PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER S' V I LANCE EQUIREMENTS COMENTS EXTENT All penetrations and penetration Per the components, parts, portior.; and closure interspace pressure retaining quantities indentified by Code Tables boundaries. IGB, IGC and IGG-2500-1, where not exempted from examination by the condi-tions of IGB, IGC and IGG-1220.
FREQUENCY Quarterly (Per SR 5.2.16 for piping) Per the intervals of inspection Program A or B of IGA-2400.
NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license commitments as identified.
a APPENDIX A A-2 Themal Barriers L
}
- a. The PSC surveillance requirements position for themal barriers can be sumarized as follows:
3 s Monitoring of thermal barrier perfomance, as indicative 3 of the structural integrity of thermal barrier assemblies and materials, by means of liner cooling water system instrumentation.
e Remote visual examination of upper core plenum areas as an investigative means only to verify degraded thermal g barrier perfomance detected by liner water cooling system instrumentation,and not as a scheduled surveil-lance requirement.
9 The proposed PSC Program does not contain :equirements specific to themal barriers, but rather,by imposing sur-G veillance requirements on the instrumentation for the liner cooling water system, the continued monitoring of themal barrier performance can be assured.
O
- b. Proposed Code Subsection IGG, examination category I-D-1 identifies visual examination requirements for thermal 4 barriers including specific a:eas, quantities and frequencies.
Additionally, requirements for metallic portions of thermal barriers exposed to elevated temperatura service are O
A-0
'O contained in Subsection IGH, examination category I-C-1, and
() requirements for insulation materials are covered by draft Subsection IGI, examination category I-B-1. It s 1ould be noted that with the current material surveillance specimen requirements of the
() above code subsections the selections, quantities and in-core locations for sample coupons are at the discretion of the Owners.
O
- c. The PSC rationale for thermal barrier inservice inspection emphasizes the capability for detecting
() thermal barrier component degradation by the performance of the liner cooling water system.
Exempted category status under the conditions identified in oC) proposed Code Subarticles IGG and IGI-1220 is sought. Periodic removal of certain PCRV appendages ard their use as possible sources for thermal barrier surveillance specimens is also i() discussed. However, since thermal barrier specimens on the removable components identified would not represent the general design they were not used for naterial surveillance
!() purposes.
I O
It is the intent of the Code that visual examination combined with material surveillance of-thermal barrier components
- 1) be conducted in cavity areas where failures could affect <
safety tl unctions. Lower plenum areas, including duct entrances to emergency cooldown equipment.are af particular ,
- O A-10 l.
! . - - _ . . . , . . _ . . _ _ . . _ . - - . _ - _ . ~ . - . . . , - - - -
.O interest.
'O Exempted category status for surveillance of metallic and insulation materials of themal barriers is validly based on
.O the capability of the liner cooling water system configuration and instrumentation to detect impaired themal barrier per-formance. However, the necessity for visual examination of lO representative thermal barrier structures still exists, especially in the core outlet plenum area and in the steem generator inlet ducting. Consequently, it is concluded that this should
'O be a feature of the proposed surveillance program. It is considered appropriate that PSC inves tigate the application of visual examination techniques to d.hermal barriers 10 i located within the core outlet plenun and steam generator inlets end develop this examination is the topic of a new SR.
O
- d. It is recommended that NRC seek PSC development of a new SR based on the outcome of the proposed investigation.
O O
O For details of requirements comparison see Table A-2.
O A-ll
~
~O ' O' 'O^ ^O- O D D' 'O ^ O' O O 1
~~
SURVEILLANCE REQUIREMENTS (SR):
A-2 TABLE PCRV INTERNALS - THERMAL BARRIERS STRUCTURE / SYSTEM / COMPONENT : Sheet 1 INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N PSC - PROPOSED PROGRAM REQUIREMENTS APPLIEABLE CODE, OTHER EQUIREMENTS COPMENTS V I LANCE Code Subsection IGG:
AREA e No requirements e Representative surfaces in upper See review text on and lower core pienems and core this subject for l
cavity end of auxiliary loop recomendation.
cross ducts.
Ih Code Subsection IGH:
, e Not applicable e Plate, bar, forging, bimetallic welds PSC: Exempted exposed to elevated temperature category status service invoked.
C3de Subsection IGI:
e Nat applicable e Thermal insulation fibrous and PSC: Exempted cate-
, ceramic gory status invoked.
4 NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license connitments as identified.
~~
1 SURVEILLANCE REQUIREMENTS (SR):
A-2 TABLE PCRV INTERNALS - THERMAL BARRIERS STRUCTURE / SYSTEM / COMPONENT : _ Sheet 2 INSERVICE SURVEILLANCE - REQUIREMENTS COMPARISON PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS COMENTS I LANCE METHOD e No requirements e Visual examinatiog where not exempted from examination by the conditions of Subarticle IGG-1220.
e Not applicable e Metallic materials specimen tests (mechanical properties), where not
> exempted from examination by the cor.di-1 tions of Subarticle IGH-1220.
e Not applicable e Insulation materials specimen tests (mechanical and other properties),
where not exempted from examination by the conditions of Subarticle IGI-1220.
i NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license comitments as identified.
SUP,VEILLANCE REQUIREMENTS (SR):
TABLE A-2 STRUCTURE / SYSTEM / COMP 0NENT : PCRV INTERNALS - THERMAL BARRIERS Sheet 3 j INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N i VI ANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICA8LE CODE, OTHER EQUIREMENTS COMENTS EXTENT e No requirements e Examination during each refueling shall cover representative portion of exposed and accessible areas.
At least 25% of surface examined during each inspection interval.
e Not; applicable e Material specimens of each type of
}- metallic structural material exposed g to temperatures and environment representative of service conditions.
Specimen types and quantities to be determined by Owner, e Not applicable e Material. specimens of each type of insulation material exposed to most severe service conditions for 1
the type. Specimen types and quantities to be determined by Owner.
, NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license comitments as identified.
SURVEILLANCE REQUIREMENTS 1(SR):
TABLE A-2 STRUCTURE / SYSTEM / COMPONENT : PCRV INTERNALS - THERMALS BARRIERS Sheet 4 INSERVICE SURVEILLANCE - REQUIREMENTS COMPARISON I ANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS COPMENTS FREQUENCY e No requirements e Per the intervals of inspection
., Program A or B of Subarticle IGA-2400.
e Not applicable e Surveillance specimen removal intervals:
- First to second refueling (incl.)
- Second to fourth (incl.) refueling
- Eighth to ninth refueling (incl.)
- Twenty-second to twenty-third re-fueling (incl.)
= Not applicable e Surveillance specimen removal intervals as above.
1 NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license comitments as identified.
O APPENDIX A A-3 Core Lateral Restraints
'O
- a. There are no Technical Specification surveillance requirements for core lateral restraints. For reasons provided by the O Psc rationale, surveillance requirements are not prescribed for this component. These are given as: lack of indications for concern.and, component inaccessibility.
'O
- b. Proposed Code Section XI Division 2 contains requirements O for inspection of these components under Subsection IGG, examination categnry I-G-l . The form of inspection is sur-veillance of specimens fabricated from materials for springs O used in core lateral restraint designs for large HTGR.
Radiation environment and temperature are the basic con-cerns behind the surveillance requirements. Code Subsection D' IGH, examina : ion category I-E-1 also contains requirements i for these components in the form of sarveillance tests for metallic structural material specimens following exposure
-O to elevated temperature service.
Future plans for rules development by ASME include the arrang-ing of all material surveillance requirements for these 3
components under a single applicable subsection .and not spread over two areas of the proposed Code as in the current O
edition.
O A-16
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O
- c. - As previcusly mentioned, core lateral restraint designs O f r large tiTGR include springs, both coil and leaf types.
Safety function demands on these active parts necessitate material integrity verification by the periodic testing of
'g material specimens following expos' ire. The FSV design for core lateral restraints does not include spring packs; however, other structural members of this component may
- 0 be subjected to elevated temperatures and other conditions of service which could result in the occurance of significant material degradation. The position of no planned surveillance g for these components should therefore be supported by design analysis demonstrating that unacceptable degradation will not occur under the service conditions to which the components are
.g exposed. Where this cannot be ascertained it is important that surveillance be performed to verify component functiunal integrity as a feature of the preposed inservice inspection O program.
- d. It is recomended that NRC seek PSC development of a new SR O r d cumentation of analysis data which demonstrates that plant safety will not be compromised by lack of a core lateral support surveillance procram.
O O
For details of requirements comparison see Table A-3, O A-17
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O O O O- O O O O O O O 1
SURVEILLANCE REQUIREMENTS (SR):
i TABLE A-3 i
STRUCTURE / SYSTEM / COMPONENT : PCRV INTERNALS - CORE LATERAL RESTRAINTS Sheet 1 i
INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N VI ANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS C0091ENTS
? Code Subsection IGG:
AREA e Not applicable e Core lateral restraint spring material
, coupons housed in regions representa-tive of most severe core lateral restraint environment.
?" Code Subsection IGFl:
4 cn e No requirements e Plate, bar, forging exposed to PSC - Potential elevated temperature service applicability de-pending on design ana?yses. (see review text.)
METiiOD e Not applicable e Material specimen tests (mechanical properties), where not exempted from examination by the conditions of Subarticle IGG-1220.
NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license connitments as identified.
1 SURVEILLANCEREQUIREMENTS(SR):
TABLE A-3 STRUCTURE / SYSTEM / COMPONENT :
PCRV INTERNALS - CORE LATERAL RESTRAINTS Sheet 2 INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQU:REMENTS COMENTS I ANCE METHOD, CONT, e No reouirements e Materials specimen tests (mechanical
. properties), where not exempted from examination by the conditions of Subarticle IGH-1220.
EXTENT e Not applicable e Nine coupons of each type of spring
- > material during each inspection
.' interval.
e No requirements e Material specimens of each type of a structural material exposed. to temperatures and environment repre-
] sentative of service conditions.
Specimen types and quantities to be i determined by Owner, j
i NOTES: (1) ' Source may include 10 CFR 50, Reg. Guides or operating license commitments as identified.
1
SURVEILLANCE REQUIREMENTS (SR):
TABLE' A-3 STRUCTURE / SYSTEM / COMFONENT :
PCRV INTERNALS - CORE LATERAL RESTRAINTS Sheet 3 INSERVICE SURVEILLANCE - REQUIREMENTS COMPARISCN PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER COMENTS VI ANCE EQUIREMENTS FREQUENCY e Not applicable o Per the intervals of inspection Program A or B of Subarticle IGA-2400.
e No requirement e Surveillance specimen removal intervals.:
- First to second refueling (incl.)
h - Second to fourth (incl.) refueling
- Eighth to ninth refueling (incl.)
- Twenty-second to twenty-third refueling (incl.)
NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license comitments as identified.
O APPENDIX A O
A-4 Helium Purification System O a. The subject system is directly connected to the PCRV, with portions serving as primary and secondary boundaries.
Included in the functions of the system is that of chemical O control of reactor coolant.
No SR covering this Cr_tegory I item can be identified nor has the subject been discussed by PSC in the proposed program submittals of Category I items to NRC.
'm b. The function of the system places it in the non-exempt category by the conditions of proposed Code Subarticles IWB and IWC 1220 and therefore subject to appropriate
'O non-destructive examination requirements for pressure-retaining components delineated in Tables IGB and IGC-2600-1.
Also applicable is Suharticle IGV for testing of valves.
O
- c. It is proposed that this subject be included in the PSC surveillance program for those features of inservice inspection
'O interest vital to the continued availability and safe operation of the system, incluoing areas of structural integrity and component operability. The proposed n
requirements to be developed on the following bases:
.O -
A-21 _ . __ _ ._ __ .- .
O e For primary boundary components, ine.luding vessels and piping, when not contained within a monitored secondary boundary designed to withstand primary pressure:
0-Surface examination of accessible pressure retaining g welds at structural discontinuities and integral attachments.
Visual examination of bolting and 6dditionally, tension testing f bolting where not disassembled for maintenance lO or other reasons.
Visual examination of support members.
Leak testing.
O e For piping boundaries acting as secondary containment:
O Visual examination of accessible pressure retaining welds and support members.
Leak testing.
- O e For system isolation valves:
.O
- Verificaticn of valve operability.
- Leak testing.
- Other tests detennined appropriate to valve type and O
function.
- O
-O A-22
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g- d. It is reconnended that NRC seek the inclusion of the
- . subject system in the proposed .PSC inservice inspection program
!. on the bases of the above prescribed surveillance requirements.
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I O O O O .. O O O' O O D O
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SURVEILLANCE REQUIREMENTS (SR): _. .
TABLE A-4 Sheet 1 STRUCTURE / SYSTEM / COMPONENT : . HELIUM PURIFICATION SYSTEM INSERVICE SURVEILLANCE - REQUIREMENTS COMPARISON V I LANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS COMENTS Code Subsections IGB & IGC, AREA Pressure-retaining components: Pressure-retaining components:
e No requirements e Felds in vessels, piping & valves and Applicable categor-integral attachment welds. ies of Code Tables IGB & IGC-2500-1
> e Bolting A3 e Supports '
s System pressure testing Code Subsection IGV ;
e No requirements Valve operability testing
\
NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license comitments as identified.
SURVEILLANCE REOUIREMENTS (SR): ____
TABLE A-4 Sheet 2 STRUCTURE / SYSTEM / COMPONENT : HELIU'i PURIFICATION SYSTEM INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N UVI ANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABL'E CODE, OTHER EQUIREMENTS COI9 TENTS METHOD e No requirements e Vols. metric, surface and visual examinations, as appropriate e Leak detection test a No requirements e Operability verification and leakape test (valves) 01 EXTENT No requirements Per components, parts, portions and quantities identified by Code Tables IGB and IGB-2500-1 and Subarticle IGV-3000.
i NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license connitments as identified.
SURVEILLANCE REQUIREMENTS (SR):
TABLE A-4 Sheet 3 STRUCTURE / SYSTEM / COMPONENT : HELIUM PURIFICATION SYSTEtt INSERVICE SURVEILLANCE - REQUIREMENTS COMPARISON VI ANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS COPflENTS FREQUEtlCY No requirement Per the intervals of inspection program A or B of IGA-2400 for pressure retaining boundaries and IGV-3000 for valve testing. .
b 9
NOTES: (1) Source may include 10 CFR 50r Reg. Guides or operating license comitments as identified.
D l
A-5 Steam Generator Tubing H
l ,_)
- a. There is no present program for periodic surveillance i inspection of steam generator tubing at FSV. The primary I
J side of the steam generators is continuously monitored during normal operation for water ingress. Presumably, any tube leakage or tubing failure would be detected by the primary
- 2) side moisture monitoring system.
- b. ASME Section XI, Subsection IGH requires surveillance tests E) of steam generator tubing materials.
NRC Regulatory Guide 1.83, identified in NRC letter to PSC
) dated January 15, 1981, requires periodic eddy current examination of steam generator tubing in LWR's.
E) Reg. Guide 1.121 establis.ies tube plugging limits for LWR steam generators.
[3 Standard Review Plan 5.4.2.2 discusses steam generator sur-veillance requirements for new plants.
3 c. FSV steam generator tubing is generally inaccessible for tubing inspection both due to lack of physical access to the
-)
II A-27
D tubing area and unit configuration. The reheat tube bundle
)
at the top of the steam generators is subject to the most severe operating conditions. Helical tubing in the main section is subheadered and is connected to the superheat 3
section at the top through a series of bi-metallic welds.
The superheat section is located inside the helical bundle.
) Bimetallic welds in the top of the steam generators between the main and superheat sections are subjected to severe thennal conditions. One failure has occurred in this 3 region.
Having two (2) steam generator loops assures adequate safe shutdown cooling in the event of a failure in one loop 7
(each loop containing six steam generator modules). This assumes that location of a steam generator failure is correctly diagnosed and isolated.
}
Operation of the Steam / Water Dump System and Moisture Monitoring System (primary side leak detection) assures water ingress control.
Operation of the Main Steam (tube side) portion of the steam
! generator at a pressure well above the primary side assures l
l that a tubino failure or slight tube leakage does not result in the release of primary system containments to the secondary I side. It should be noted that the reheat bundle is at a
! slightly lower pressure on the secondary side. The reheat system is monitored for primary system leakage.
i .A-28
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Operating history of the steam generators has resulted
'O in only one tube failure.
Heavy wall tubing minimizes the possibility of failures due
- O to erosion or fretting wear.
Primary side helium purity limits chemical corrosion to the secondary tubeside.
1 d. Based on the above, Steam Generator tubing inspection is not
'O considered necessary to assure the long term heat removal and water ingress protection of the primary system.
O It is, however, recommended that data be supplied to the NRC which describes material tests performed to date to assure i
the long term thermal performance of the bi-metallic welds O
at the top of the steam generators.
!O O
O O
~A-29
O O O O .. 'O~ O O O O O O
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SURVEILLANCE REQUIREMENTS (SR): _ _ .
TABLE A-5 Sheet 1 STRUCTURE / SYSTEM / COMPONENT : STENi GENFRATORS (TUBING)
INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N SCOPE OF SURVEILLANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABl.E CODE, OTHER(1)
REQUIREMENTS CO R NTS
=
Code Subsection IGH:
AREA No requirements Tubino, plates, forgings, welds High temperature (including bimetallic welds) materials t
2 b
METHOD No requirements Material surveillance soecimen tests Tests to @tect (mechanical properties), where not degradr'. ion due to exempted from examination by the effect:; of high conditions of Subarticle IGH-1220 temperature opera-tion NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license conuitments as identified.
SURVEILLANCE REQUIREMENTS (SR): _.
TABLE A-5 Sheet 2 STRUCTURE / SYSTEM / COMPONENT : STEAM GENERATORS (TUBING) __
INSERVICE SURVEILLANCE - REQUIREMENTS CCMPARISON VI ANCE PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS COMMENTS EXTENT No requirements Material specimens of each type of structural material exoosed to tempera-ture and environment representative of service conditions. Specimen types and quantities to be detennined by Owner. ,
$! I FREOUENCY No requirements Surveillance specimen removal intervals:
- First to second refueling (incl.)
- Second to fourth (incl.) refueling
- Elohth to ninth refueling (incl.)
- Twenty-second to twenty-third refueling (incl.)
NOTES: (1) Source may include 10 CFR 50, RM. Guides or operating license comitments as identified.
O A-6 High Eneray Pioing
.O
- a. There is presently no surveillance program to assure the long term structural integrity of high energy piping systems.
O
- b. Paragraph 50.55a (g) (6) (iii) of the Code of Federal Regulations, Part 10, requires " augmented inservice inspections" O to be performed in those areas identified by the NRC. High energy piping systems have been identified as areas of concern, (Refs: (1)(2)(3)(4)(5)(6)(7).
O
" Augmented ISI to Protect Against Postulated Piping Failures" is discussed in Section II.8 of Reference (6). The purpose O of this inspection is "to assure that such failures would not cause the loss of needed functions of safety-related systems and to assure that the plant could be safely shut
'O down in the event of such failures." (5)
High energy fluid systems are identified as those in which O 1. Pressure exceeds 275 psig, or
- 2. Temperature exceeds 2000F.
O In the case of FSV, examples of high energy fluid systems include the following:
s Main Steam O e Main Feedwater e Reheat Steam O
A-32
o Helium Purification
) e Buffer Helium
- c. FSV systems and components outside the PCRV which should be
) protected against the effects of high energy piping system failures include at least the following:
e Feedwater and Steam piping
) e Circulator Drive piping e Reactor Monitoring System cabling e Reserve Shutdown equipment
) e PCRV tendon anchorages e PCRV penetrations e Mcisture Monitoring cables e PCRV Liner Cooling System piping and instrument cabling D
As described in Reference (7), the adverse effects of postulated high energy piping failures on systems and equipment important to safety can be citigated by the following design features:
D
- 1. Pipe whip restraints
- 2. Protective guards to minimize the effects of pipe whip, jet impingement, and oiping failures.
D
- 3. Conservative design in critical areas j 4. Augmented ISI in critical areas D
Critical areas may be defined as those which contain both high energy piping and systems important to safety.
D
_ _ _ _ _ _ - _ _ - - _ - - - - - /h2R -
O The intent of this review is to identify augmented ISI as a means to provide a significant deg:ae of assurance that pipe O whip, jet impingement, and structural damage will not result in loss of safety system functions.
O d. It is recommended that PSC be requested to review the above and provide the following:
'O 1. Define systems and components important to safety as follows:
(a) Required to assure the long term integrity of the Q reactor coolant pressure boundary.
p (b) Required to assure safe shutdown and core heat removal following a snutdown.
- O (c) Required to prevent the release of contaminents which would result in offsite doses above acceptable limits.
.O
- 2. Identify high energy piping systems, as defined in (b) above, which are physically located in critical areas, O as described in (c) above.
- 3. Identify systems important to safety that could suffer O loss of function as a result of a high energy piping j failure.
O 4. Describe a program of augmented ISI to mitigate the potential effects of high energy piping failures in critical areas.
Augmented ISI may include the following:
l A-34 l
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(a) Nondestructive examination of welds, j>
(b) Visual inspection during . hydrostatic testing, t
-(c) Examination of pipe supports both durir,g operr. ting ,
i and shutdown conditions.
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O REFERENCES (1) 10 CFR Part 50, Licensing Requirements for Production ano Utilization Facilities O
(2) NRC letter (A.Giambusso - DOL) to applicants and licensees, December 1972, " General Infomation Required for Consideration of Effects of a Piping System Break Outside Containment."
O (3) NRC letter (J.F. O' Leary - 00L) to applicants, July 1972,
" Criteria for Determination of Postulated Break and Leakage Locations in High and Moderate Energy Fluid Piping Systems Outside of Containment Structures."
O (4) ASME Section XI, Division 2, Code for " Inservice Inspection and Testing of Components of Gas Cooled Plants."
(5) Standard Review Plan (NUREG-75/087) Section 3.6.1 " Plant-Design for Protection Against Postulated Piping Failures in O Fluid Systems Outside Containment."
(6) Standard Review Plan Section 6.6, " Inservice Inspection of Class 2 and 3 Components."
'O 4
(7) Branch Technical Position, MEB 3-1, " Protection Against Postulated Piping Failures in Fluid Systems Outside Containment."
O O
'O O ' '
A-36
O O O O- O O O O O O O SURVEILLANCE REQUIREMENTS (SR):
TABLE A-6 Sheet 1 STRUCTURE / SYSTEM / COMPONENT : HIGH ENERGY PIPING / SECONDARY COOLANT SYSTEM INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N (COPE OF APPLICABLE CODE, OTHER(1)EQUIREMENTS 4
PSC . PROPOSED PROGRAM REQUIREMENTS R COMMENTS SURVEILLANCE Code Subsection IGC
~
AREA Pressure-retaining components Pressure-retaining components: Applicable cate-gories of Code Table No requirements e Welds in piping and valves, and IGC-2500-1.
integral attachment welds.
High energy piping e Bolting t)- 2000F,
.lE p)- 275 psia.
!$ e Supports Applicable weld e System pressure testing joints subject to augmented inservice inspection -
4 see text.
METHOD No requirements e Volumetric, surface and visual examinatioqs, as appropriate o Hydrostatic test NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating license commitments as identified.
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SURVEILLANCE REQUIREMENTS (SR):
TABLE A-6 Sheet _2 STRUCTURE / SYSTEM / COMPONENT : HIGH ENERGY PIP.ING/ SECONDARY COOLANT SYSTEtt INSERVICE SURVEILLANCE - REQUIREMENTS COMPARIS0N PSC - PROPOSED PROGRAM REQUIREMENTS APPLICABLE CODE, OTHER EQUIREMENTS C0WiENTS V I LANCE l
l EXTENT tio requirements Per the components, parts, portions and See SRP 3.6.1 l
quantities identified by Code Table l IGC-2500-1 l
?
M FREOUENCY fio requirements Per the intervals of inspection Program A or B of IGA-2400.
NOTES: (1) Source may include 10 CFR 50, Reg. Guides or operating licensa comitments as identified.