ML20041E480
| ML20041E480 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 02/25/1982 |
| From: | Miraglia F Office of Nuclear Reactor Regulation |
| To: | Oprea G HOUSTON LIGHTING & POWER CO. |
| References | |
| NUDOCS 8203100603 | |
| Download: ML20041E480 (17) | |
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50-498/499 LB#3 Files DEisenhut RTedesco y RPurple FMiragl o
Mr. George W. Oprea, Jr.
SHanauer DSel f b" Executive Vice President RVollmer a
N Houston Lighting f. Power Comp lany RMattson s
Post Office Box 1700 E?m HThompson 6
D Houston, Texas 77001 M491 MPA
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Dear Mr. Oprea:
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Subject:
Request for Additional Information - South Texas Proje
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s The Mechanical Engineering Branch has identified a question dealing w inservice testing requirements for pumps and valves that must be addressed prior to completion of their review of your operating license applications.
The specific question is contained in Enclosure 1.
Your response to this question should be provided using the attached fonnat.
In view of your current activities with regard to changing contractors, you are requested to provide us with a schedule within 60 days of receipt of this letter by which you plan to respond to this request for additional information.
If you cannot supply a schedule within60 days,pleaseadviseluswhenitcanbeprovided.
If you have any questions, co'ntact D. Sells (301) 492-7100, the Project Manager.
Sincerely,
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Original signed by, Frank J. Miraglia '
l Frank J. Miraglia, Chief
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Licensing Branch No. 3 Division of Licensing
Enclosure:
Request for Additional Information cc w/ enclosure:
See next page.
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o SOUTH TEXAS Mr. G. W. Oprea, Jr.
Mrs. Peggy Buchorn Executive Vice President Executive Director Houston Lighting and Power Company P. O. Box 1700 Citizens for Equitable Utilities, Inc.
Route 1, Box 1684 Houston, Texas 77001 Brazoria, Texas 77422 Mr. J. H. Goldberg William S. Jordan, III Esq.
Vice President - Nuclear Engineering Harmon & Weiss
& Construction 1725 1 Street, N.W.
Houston Lighting and Power Company Suite 506 P. O. Box 1700 Washington, D.C.
20006 Houston, Texas 77001 Mr. O. G. Barker Brian Berwick, Esq.
Manager, South Texas Project Assistant Attorney General Houston lighting and Pomr Company Environmental Protection Division P. O. Box 1700 P. O. Box 12548 Houston, Texas 77001 Capitol Station Austin, Texas 78711 Mr. M. L. Borchelt Central Power and Light Company William M. Hill P. O. Box 2121 Resident Inspector / South Texas Project Corpus Christi, Texas 78403 c/o U. S. NRC P. O. Box 910 Mr. R. L. Hancock Bay City, Texas 77414 City of Austin Electric Utility Department e
?. C. Sox 1088 Austin, Texas 78767 Mr. J. B. Poston Mr. Lanny Sinkin Assistant General Manager for Operations Pat Coy City Public Service Board P. O. Box 1771 Citizens Concerned About Nuclear Powr 5106 Case Oro San Antonic, Texas 78296 San Antonio, Texas 78233 Jack R. Newman, Esq.
Mr. Cloin Robertson Lowenstein, Newman, Axelrad & Toll 1025 Connecticut Avenuel N.W.
Manager, Nuclear Licensing Houston Lighting and Power Company Washington, D. C.
20036 P. O. Box 1700 Houston, Texas 77001 Melbert Schwarz, Jr., Esq.
Baker & Botts Charles Halligan One Shell Plaza Bechtel Power Corporation Houston, Texas 77002 P. O. Box 2166 Mr. E. A. Saltarelli Brown & Root, Inc.
P. O. Box 3 Houston, Texas 77001
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t MECHANICAL ENGIt!EERIfiG BRANCH 210.1 10 CFR 50.55a has recently been revised with respect to pump and valve inserv fce testing requirements (See October 9,1979 Federal Register, pp. 57912-4)
Provide a program for initial 120 month inservice testing of pumps and valves, as required by 10 CFR 50.55a(g)(4)(i). The applicable code for this inspection interval which would be required by 10 CFR 50.55a(g)(4)(1) is the Code endorsed by 10 CFR 50.55a(b)(2) 12 months prior to the date of issuance of your OL. Effective fiovember 1,1979.10 CFR 50.55a(b)(2) endorsed the 1977 Edition with all age,nda through Summer 1978. L'e therefore reccamend that your progra'm be based on the 1977 Edition with all agenda through Sumrier 1978.
Your program.should ir.dicate which code requirements are. impractical to meet together with documentation for justification why relief is necessary.
The attached format should be used when submitting IST program.
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NRC STAFF COPPINTS ON INSERVICE PUMP AND VALVE TESTING PROGRAMS AND RELIEF REQUESTS The NRC staff, after reviewing a number of pump and valve testing programs, has determined that further guidance might be helpful to illustrate the type and extent of information we feel is necessary to expedite the review of these programs. Ve feel that the Licensee can, by incorporating these guidelines into each program submittal, reduce considerably the staff's review time and time spent by the Licensee in responding to NRC staff requests for additional information.
The pump testing program should include all safety related* Class 1, 2, and 3 punps which are installed in water cooled nuclear pcwer plants and which are provided with an erargency power source.
The valve testing program should include all the safety related valves in the following systems excluding valves used for operating convenience only, such as manual vent, drain, instrument, and test valves, and valves used for maintenance only.
M a.
High Pressure Injection System b.
Low Pressure Infection System l
c.
Accumulator Systems d.
Containment Spray System
- Safety related - necessary to safely shut down the plant and mitigate the consequences of an accident.
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Primary and Secondary System Safety and Relief Valves f.
Auxiliary Feedwater Systems g.
Reactor Building Cooling System h.
Active Components in Service Water and Instrument Air Systems which are required to support safety system functions,
- i. Containment Isolation Valves required to change position to isolate containment.
- j. Chemical & Volume Control System k.
Other key components in Auxiliary Systems which are required to directly support plant shutdown or safety system function.
1.
Residual Heat Removal System m.
High Pressure Core Injection System b.
Lcw Pressure Core Injection System c.
Residual Heat Removal System (Shutdown Cooling System) d.
Emergency Condenser System (Isolation Condenser System) e.
Low Pressure Core Spray System f.
Containment Spray System g.
Safety, Relief, and Safety / Relief Yalves h.
RCIC (Reactor Core Isolat' ion Cooling) System
- i. Containment Cooling System J.
Containment isolation valves required to change position to isolate containment.
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Standby liquid control system (Boron System) 1.
Autom'atic Depressurization System (any pilot or control valves, associated hydraulic or pneumatic systems, etc.)
Control Rod Drive Hydraulic System (" Scram" function) n.
other key components in Auxiliary Systems which are required to directly n.
support plant shutdown or safety system function,
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Reactor Coolant System Inservice Puro and Valve Testino Program I.
Information required for NRC Staff Review of the Pump and Valve Testing Program A.
Three sets of P&ID's, which include all of the systems listed above, with the code class and system boundaries clearly marked.
The drawings should include all of the components present at the time of submittal and a legend of the P&ID symbols.
B.
Identification of the applicable ASME Code Edition and Addenda C.
The period for which the program is applicable.
D.
Identify the component code class.
E.
For Pump testing:
Identify 1.
Each pump required to be tested (name and number) 2.
The test parameters to be measured 3.
The test frequency e
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4-F.
For valve testing: Identify 1.
Each valve in ASME Section XI Categories A & B that will be exercised every three months during normal plant operation (indicate whether partial or full stroke exercise, and for power operated valves list the limiting value for stroke time.)
2.
Each valve in ASME Section XI Category A that will be leak tested during refueling outages (Indicate the leak test procedure you intend to use) 3.
Each valve in ASME Section XI Categories C, 0, and E that will be tested, the type of test and the test frequency.
For check valves, identify those that will be exercised every 3 months and these that will only be exercised during cold shutdown or refueling outages.
Additional Information that will be Helpful in Speeding Up the Review II.
Process A.
Include the valve location coordinates or other appropriate location information which will expedite our locating the valves on the P& ids.
B.
Provide P&ID drawings that are large and clear enough to be read easily.
a.
Identify valves tg are provided with an interlock to other C.
' components and a brief description of that function.
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, Relief Reouests from Section XI Recuirements The largest area of concern for the NRC staff, in the review of an inservice valve and pump testing program, is in evaluating the basis for justifying relief from Section XI Requirements. It has been our experience that many requests for relief, submitted in these programs, do not provide adequate descriptive and detailed technical infomation. This explicit information is necessary to provide reasonable assurance that the burden irposed on the licensee in complying with the code requirements is not justified by the increased level of safety obtained.
Relief requests which are submitted with a justification such as
" Impractical", " Inaccessible", or any other categorical basis, will require additional information, as illustrated in the enclosed examples, to allow our staff to make an evaluation of that relief request. The intention of this guidance is to illustrate the content and extent of information required by the NRC staff, in the request for relief, to make a proper evaluation and adequately document the basis for that relief in our safety evaluation report. The NRC staff feels that by receiving this infomation in the program submittal, subsequent requests for additional infomation and delays in completing our review can be considerably reduced or eliminated.
I.
Infomation Recuired for NRC Review of Relief Recuests A.
Identify component for which relief is requested:
1.
Name and number as given in FSAR 2.
Function 3.
ASME Section III Code Class 4.
For valve testing, also specify the ASME Section XI valve category as defined in IW-2000
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Specifically identify the ASME Code requirement that has been determined to be impractical for each component.
C.
Provid,e information to support the determination that the requirement in (B) is impractical; i.e., state and explain the basis for requesting relief.
D.
Specify the inservice testing that will be performed in lieu of the ASME Code Section XI requirements.
E.
Provide the schedule for implementation of the procedure (s) in (D).
II. Examples to Illustrate Several Possible Areas k'here Relief !!ay Se Granted and the Extent and Content of Information flecessary to Make An Evaluation A.
Accessibility: The regulation specifically grants relief from the code requirement because of insufficient access pro-visions. However, a detailed discussion of actual physical arrangement of the component in question to illustrate the insufficiency of space for conducting the required test is necessary.
Discuss in detail the physical arrangement of the component in question to demonstrate that there is not sufficient space to perform he code required inservice testing.
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. What alternative surveillance means which will provide an
-acceptable level of safety have you considered and why are these means not feasible?
B.
Environmental Conditions (e.g., High radiation level, High temperature, High humidity, etc.)
Although it is prudent to maintain occupation radiation exposure for inspection personnel as low as practicable, the request for relief from the code requirements cannot be granted solely on the basis of high radiation levels alone. A balanced judgment between the hardships and compensating increase in the level of safety should be carefully established.
If the health and safety of the public dictates the necessity of inservice testing, alternative means or even decontamination of the plant if necessary should be provided or developed.
Provide additional information regarding the radiation levels at the required test location. What alternative testing techniques which will provide an acceptable level of assurance of the integrity of the component in question have you considered and why are these techniques determined to be impractical?
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C.
Instrumentation is not originally provided Provide information to justify that compliance with the code requirements wculd result in undue burden or hardships without a compensating increase in the level of plant safety. What alternative testing methods which will provide an acceptable level of safety have you considered and why are these methods determined to be impractical?
D.
Yalve CyclinC During Plant Operation Could Put the Plant in an Unsafe Cone.ition The licensee should explain in detail why exercising tests during plant operation could jeopardize the piant safety.
E.
Valve Testing at Cold Shutdown or Refueling Intervals in Lieu of the 3 Honth Required Interval The licensee should explain in detail why each valve cannot be exercised during normal operation. Also, for the valves v:here a refueling interval is indicated, explain in detail why each valve cannot be exercised during cold shutdown intervals.
III. Acceptance Criteria for Relief Recuest The Licensee must sucessfully demonstrate that:
1.
Compliance with the code requiremants would result in hardships or unusual difficulties without a compensating increase in the level of safety and noncompliance will provide an acceptable level of quality and safety, or l
9-2.
Proposed alternatives to the code requirements or portions thereof wi'l provide an acceptable level of quali,ty and
, safety.
Standard format A standard format, for the valve portion of the pump and valve testing program and relief requests, is included as an attachment to this Guidance.
The NRC staff believes that this standard format will reduce the time spent by both the staff in our review sad by'the licensee in their preparation of the pump and valve testing program and submittals. The standard format includes exacples of relief requests which are intended to illustrate the application of the standard format and are not necessarily a specific plant relief request.-
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ATTACHMENT STANDARD FORMAT VALVE IfiSERVICE TESTING PP03 RAM SUBMITTAL.
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1 Lecend for Valve Testing Exanole Format Q - Exercise valve (full stroke) for operability every (3) months LT - Valves are leak tested per Section XI Article IWV-3420 MT - Stroke time measurements are taken and compared to the stroke time limiting value per Section XI Article IWV 3410 CV - Exercise check valves to the position required to fulfill their function every (3) months SRV - Safety and relief valves are test'ed per Section XI Article IWY-3510 DT - Test category D valves per Section XI Article IIlV-3600 ET - Verify and record valve position before operations are performed and after operations are completed, and verify that valve is locked or s e al ed.
CS - Exercise valve for operability every col'd shutdown RR - Exercise valve for operability every reactor refueling l
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Relief Recuest Basis System: Auxiliary Coolant System, Component Cooling 1.
Valve:
71 7 Category:
C Class:
3 Function:
Prevent backflow from the reactor coolant pump cooling coils Impractical test requirement: Exercise valve for operability every three months Basis for relief: To test this valve would require interruption of cooling water to the reactor coolant pumps motor cooling coils. This action could result in damage to the reactor coolant pumps and thus place the plant in an unsafe mode of operation.
Al ternative Testing:
This valve will be exercised for operability during cold shutdowns.
1 2.
Valve:
834 Category:
8-E i
Class:
3 Function:
Isolate the primary water from the component cooling surge tank during plant opertion.
It is normally in the closed position, but routine operation of this valve will occur during refueling and cold shutdowns.
Practical Test Requirement:
Exercise valve (full stroke) for operability every three (3) months.
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. Basis for Relief: This valve is not required to change position during plant operation to accomplish its safety function. Exercising this valve will increase the possibility of surge tank line contamination.
Testing:
Verify and record valve position before and after each valve operation.
3.
Val ve:
744B Category:
A Class:
2 Function:
Isolate the residual heat exchangers from the cold leg R.C.S. backflow and accumulator backficw.
Test Requirements: Seat leakage test Basis for Relief:
This valve is located in a high radiation field (2000 mr/hr) which would make the required seat leakage test hazardous to test personnel. We intend to seat leak test two other valves (8758 and 876B) which are in series with this valve and will also prevent backflow. We feel that l
by complying with the seat leakage requirements l
we will not achieve a enmpensatory increase in l
the level of safety.
Alternative
' Testing:
ilo citernative seat leak testing is proposed.
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