ML20057F127
| ML20057F127 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 10/05/1993 |
| From: | Kugler A Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9310140162 | |
| Download: ML20057F127 (8) | |
Text
i October 5, 1993 Docket No. 50-440 LICENSEE: Centerior Service Company FACILITY: Perry Nuclear Power Plant
SUBJECT:
MEETING
SUMMARY
OF SEPTEMBER 2, 1993 On September 2, 1993, the staff met with representatives of the licensee at One White Flint North. is a list of the meeting participants.
The licensee's questions regarding the staff's April 5,1993, safety evaluation (SE) of Revision 3 to the inservice testing (IST) program were discussed. contains the subjects the licensee wanted to discuss regarding the SE.
Each of the licensee's questions were examined and the staff provided clarifications for each issue.
The licensee agreed to modify the affected portions of the submittal, incorporating the changes discussed in the meeting, and providing the changes to the staff.
ORIGINAL SIGNED BY:
Andrew J. Kugler, Assistant Project Manager Project Directorate III-3 Division of Reactor Projects III/IV/V Office of Nuclear Reactor Regulation
Enclosures:
i As stated cc w/ enclosures:
See next page DISTRIBUTION Docket File Local & NRC PDRs T. Murley/F. Miraglia PDIII-3 r/f PDIII-3 Gray File J. Partlow J. Roe J. Zwolinski E. Jordan J. Hannon R. Stransky A. Gody, Jr., EDO A. Kugler K. Dempsey E. Sullivan P. Campbell M. Rushbrook OGC ACRS(10) 1 E. Greenman, RIII
- See Previous Concurrence OFFICE LAQD3,3 PM:PDI3-3
- EMEB:NRR DhPb3h MRushbok AKuglerkj KDempsey HEnno$
q
)
NAME
(\\ / /93 lb /f/93 9/28/93
/D /E/93 Y
DATE 0FFICIAL RECORD COPY FILENAME: G:\\ PERRY \\lST74784.MTS QOl
\\
30 nm CH6TER COPY 9310140162 931005 PDR ADOCK 05000440 i
P PDR l
I Perry Nuclear Power Plant Cleveland Electric Illuminating Company Unit Nos. I cnd 2 cc:
Mr. Robert A. Stratman, Vice President Nuclear - Perry The Cleveland Electric Illuminating Company 10 Center Road Perry, Ohio 44081 Jay E. Silberg, Esq.
Mr. James W. Harris, Director Shaw, Pittman, Potts & Trowbridge Division of Power Generation 2300 N Street, N.W.
Ohio Department of Industrial Relations Washington, D.C.
20037 P. O. Box 825 Columbus, Ohio 43216 Mary E. O'Reilly Centerior Energy Corporation The Honorable Lawrence Logan 300 Madison Avenue Mayor, Village of Perry Toledo, Ohio 43652 4203 Harper Street Perry, Ohio 44081 s
Resident Inspector's Office The Honorable Robert V. Orosz U.S. Nuclear Regulatory Commission Mayor, Village of North Perry Parmly at Center Road North Perry Village Hall Perry, Ohio 44081 4778 Lockwood Road North Perry Village, Ohio 44081 Regional Administrator, Region III U.S. Nuclear Regulatory Commission Attorney General 799 Roosevelt Road Department of Attorney General Glen Ellyn, Illinois 60137 30 East Broad Street Columbus, Ohio 43216 Lake County Prosecutor Lake County Administration Bldg.
Radiological Health Program 105 Main Street Ohio Department of Health Painesville, Ohio 44077 Post Office Box 118 Columbus, Ohio 43266-0118 Ms. Sue Hiatt OCRE Interim Representative Ohio Environmental Protection Agency i
8275 Munson DERR--Compliance Unit Memtor, Ohio 44060 ATTN: Zack A. Clayton 1
P. O. Box 1049 Terry J. Lodge, Esq.
Columbus, Ohio 43266-014!-
618 N. Michigan Street, Suite 105 Toledo, Ohio 43624 Mr. Thomas Haas, Chairman Perry Township Board of Trustees Ashtabula County Prosecutor 3750 Center Rd., Box 65 25 West Jefferson Street Perry, Ohio 44081 Jefferson, Ohio 44047 State of Ohio Mr. Kevin P. Donovan Public Utilities Commission Cleveland Electric Illuminating Company East Broad Street 1
Perry Nuclear Power Plant Columbus, Ohio 43266-0573 P. O. Box 97, E-210 Perry, Ohio 44081 David P. Igyarto, General Manager Cleveland Electric Illuminating Company James R. Williams, Chief of Staff Perry Nuclear Power Plant Ohio Emergency Management Agency P. O. Box 97, SB306 2825 West Granville Road Perry, Ohio 44081 Worthington, Ohio 43085
a-September 2. 1993 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES List of Attendees
- P. Campbell NRC K. Dempsey NRC A. Kugler NRC R. Stransky NRC
- E. Sullivan NRC B. Andrie Centerior Service Company B. Ferrell Centerior Service Company S. Hutton (ETS)
Centerior Service Company S. Seman Centerior Service Company
- L. Grove Emergency Management Agency, State of Ohio I
I I
I i
k Denotes part-time attendance
Ebclosure 2
~
Clarification of Items in 04/05/93 IST Package l.
VR-26, pgs. 16 4 20 (Denied Relief Request)
PNPP suggested approach for valve groupings (ira place of disassembly):
E12-F054A/B - drop from the Relief Request once valves are declared inoperable (because steam condensing mode of PER vill not be used) 4 no testing needs to be perf rmed on inoperable equipment. Add note in ISTP that valves aren't tested.
E22-F016, E51-F030, and P45-F575 - these valves are not full-open tested while installed in the plant due to the system line-ups which vould be necessary, and the testing performed for both open/close testing really isn't a " disassembly" (just unflange the entire unit), so break these out into a new separate Relief which provides more justification than the old one.
E12-F084A,B,C; E12-F085A,B,C; E22-F006, E22-F007, E51-F061, E51-F062, E51-F079, and E31-F081 - perform single-unit test as suggested by the NRC and resubmit as a new separate Relief containing information requested on page 20.
E21-F033 - vill attempt to develop a test to check this valve during the time that the main E21 pump is operating for its quarterly SVI (this allows securing of the vaterleg pump, if necessary).
~
E21-F501, E22-F002 - create a new VR vhich notes that the full exercise test 4
l is done quarterly, it's just the closure check that must be done at a refuel Trequency.
Similar to the F016, F030, and F575 valves discussed above, the closure check is not really a " disassembly" (just unflange the entire unit).
Add detail to the VR to explain that a full-exercise test vill be performed following reinstallation of these valves in the plant.
P45-F501A,B and P45-F522 - drop from the Relief Request and attempt to test closure when the E5V/HPCS main pump is secured by using the pump discharge pressure gauge and verifying no reverse rotation on the pump.
~
2.
VR;.7, VR-9, VR-15, VR-18, VR-19, VR-23, VR-27, VR-37, VR-40, VR-42, Part 1 of PR-3 (No Relief necessary)
VR-7 (pg. 45) uses fairly clear language to explain the NRC position on vhy
~
these 10 VR's and 1 PR can be eliminated, however, the rest of them use greatly shortened discussions which are misleading.
Perhaps this vas because the writer expected that VR-7 vould be the first of these eleven discussions that a reader vould get to, hovever, it ended up buried on page
- 45. Therefore, the reader instead first runs into vords such as " relief is not required provided the licensee implements all related requirements of OH-10, or portions thereof. Vhether all related requirements are met is subject to NRC inspection." (see example VR-9 pg. 30). Is our assumption correct that the items other than VR-7 are just shortened versions of the VR-7 discussion [and therefore of 10CFR50.55a(f)(4)(iv)], or is there some
hidden intent in the vords "all related requirements of OM-10, or portions thereof"? Ve vould like reassurance that we do not have to change our Code commitment to OH-10 prior to the end of our current 10 year interval.
Also, having the vords "all related requirements" and the words" or portions thereof" in the same sentence is confusing. Ve vould assume that both of these phrases were meant to say exactly the same thing, rather than assuming that the vords "or portions thereof" vere meant to modify the words "all related requirements" (i.e., ve aren't alloved to decide what the "related requirements" are, and then pick out a portion of those to implement).
t For the valves /pucp subject to these VR's/PR, ve intend to add a reference in the " Relief Request" column of the " Valve Test Table" in the ISTP, which I
vill refer a reader to a note explaining that Commission approval was i
received to use a portion of OH-10 for testing, and then ve vill delete the Relief Requests from our program. Is this what the NRC expected?
3.
VR-41, pgs 22 4 23 (Partial granting, partial denial)
For the 2 valves which were denied, we vill create a nev Cold Shutdown justification for these two valves. Therefore, VR-41 vill be revised to delete the tvo valves. Do ve need to resubmit the revised VR-41 for NRC approval due to the deletion of the two valves? Or do ve just go ahead and make the change since it vill make the VR consistent with your approval vords?
4.
VR-5, pgs. 24 4 25 (Interim Relief granted)
It is our intention to resubmit this Relief Request for approval.
The evaluation seems to indicate that the writer understood the overall function of the Main Steam Safety / Relief Valves, yet they are referred to as check valves and the position is taken that ve must use a check valve non-intrusive diagnostic technique within one year to " evaluate their operational readiness" and monitor "the condition of these valves for the long term".
This seems illogical. These are relief valves, not check valves, and currently, every one of these valves are freshly installed each l
outage after being tested at Vyle Labs, and receiving any necessary refurbishment.
In the future, ve may replace only half the valves each outage, but no valves vill go longer than 2 fuel cycles without Vyle tests / refurbishment.
Once a valve is reinstalled in the plant, verification of valve opening and closing is provided during plant startup testing by a variety of plant responses to the movement of these valves (turbine bypass valves stroke closed upon SRV opening, then reopen upon SRV closure; pressure switches dovnstream in the SRV tailpipe indicate pressure increase / decrease; and temperature elements in the SRV tailpipe monitor temperature
' increase / decrease). The Vyle tests and the in-plant verification of opening and closing provides sufficient proof of operational readiness and long-term condition of the valves. These valves are not accessible during their stroking (located within the dryvell), so any non-intrusive diagnostic equipment vould have to be permanently installed (vith permanent cabling run
to outside dryvell and containment). This equipment vould not be qualified for the dryvell environment, and would need replseement every refuel outage.
The costs involved are enormous and completely prohibitive. CEI is not currently aware of any techniques that can be used on an SRV installed in the plant to adequately check its stroke while the plant is shutdovn for refuel (vhen dryvell access is possible). If NRC is aware of any such techniques being used, ve vould be very interested in discussing them, provided it vould permit elimination of the cycling of SRV's at pover.
Leakage of several SRV's during each of our fuel cycles has been experienced, which may have been caused by the cycling of the valves at Unless such a non-steam driven functional test is already approved power.
by URC for use in the industry, the one year deadline on this interim relief is insufficient to develop and implement a new method capable of providing an adequate functional test.
From an administrative standpoint, vhat do the words " interim relief is granted for one year or until the next refueling outage" mean?
Does "until the next refueling outage" mean "until the beginning of the n' ext refueling outage" or "until after the next refueling outage"? The previous NRC Interim Relief letter dated 1/2/90 utilized the phrase " relief is granted until the end of the next refueling outage". That phrase was clearly stating that any vork performed during the outage vould continue to be considered valif. since it vas performed under a valid Relief Request.
5.
VR-17, pgs. 34 + 35 (Granted Relief Request)
This RR vas granted, but a "non-Appendix A" request is made for a " study" on the use of non-intrusive techniques on a frequency more often than refuel outages. What is the time frame for cortpletion of this study? (Our personnel resources are already going to be severely strained performing program / procedure revisions to implement the nev guidance, without doing extra " studies" not listed as " anomalies" in the program).
6.
VR-35, pgs. 35 + 36 (Interim Relief Granted)
A revised Relief Request vill be submitted to request use of
" limit-to-limit" stroke times instead of " control switch to opposing light" times, since the limit-to-limit times can be obtained from our Emergency Response Information System (ERIS) computer, which vill provide more accurate data, as requested by the TER evaluation.
7.
VR-14, pgs. 41 4 42 (Granted Relief Request)
This Evaluation notes that "the licensee should determine if a method for verifying closure at the Code frequency is practical..., as the relief request does not specifically address the verification of closure".
See VR-34 for our justification for a refuel outage closure test, which was granted with no caveats.
Since the quoted item above vas not included in Appendix A, and the answer to the NRC question is contained within the SER, hov do ve document the resolution of this item?
E.
VR-8, pgs. 43 4 44 (Interia Relief Granted)
This VR deserves another verbal discussion between the revievers and our staff on the variability of the RCIC system response, and the inability to obtain consistent data because the valve responds to system flov.
9.
VR-1, pgs. 13 + 14 (Alternative for startup o.k; operability determination alternative is not authorized)
The TER Evaluation provided us with the Relief we intended even though there are vords in the TER evaluation that state that part of our Relief Request was not granted. Our Relief Request must not have been clear because ve veren't asking for Relief from the Code operational readiness requirement to declare a component " inoperative" if it fails a code test (for example, if it eu eeds the " required action" limits). Ve vere only asking for what was
- granted, i.e., that the failure of that " inoperative" component be examined to determine its impact on any Tech Spec system, snd that if.a Tech Spec system is made " inoperable" that the Tech Specs provide the controls over whether plant startup is permissible with that component inoperative.
NOTE: " Inoperative" components are only " inoperable" if they impact a Tech Spec system, since " inoperable" is defined only within the bounds of Tech Specs.
Should we revise this Relief Request to make it more clear?
- 10. VR-11, pgs. 25 + 26 and VR-20, pgs. 26 + 28 (Granted Relief Requests) i If we agree to do vhat the Evaluation says for each of these Reliefs, then ve should revise the Reliefs to state that ve vill take those specified actions upon failure of any valves. Under the new rules of Generic Letter
+
89-04, do the revised Reliefs need to be resubmitted for reapproval even i
though the valve population hasn't changed and ve are just incorporating what the TER said ve should do?
- 11. PR-9, pgs. 7 + 8 (Granted Relief Request) j The Evaluation requests that we evaluate measuring pump discharge pressure and pump bearing vibration quarterly. Ve vill attempt to perform vibration tests quarterly during a period when the waterleg pump is running, but discharge pressure vould not be a valid trending item because of the system design / varying flov demand. This is an area that raises the question: This Relief vas granted provided ve evaluate additional on-line tests that could supplement the cold shutdovn tests, and either implement the on-line tests or document why ve don't do them within the ISTP. If we start doing vibration testing and later determine it isn't giving us useful data, can we assupp that the Relief remains valid during the time period during which ve i
process a change to the ISTP to document the reasons behind suspension of these tests (using normal administrative schedules which vould include cross-discipline reviews (etc.))?
. ]
12.'PR-3 "Part 2", pgs. 9 + 10 (Granted Relief Request) c There are two statements in this Evaluation which need clarification.
First, the TER ruggests a " study" to demonstrate these pumps are not susceptible to vibrations at frequencies below the pump rotational speed
. frequency, even though the next sentence acknowledges that it should not be a problem, and the Q & A at the March 1991 meetings (as documented in the meeting minutes) notes the same lack of a problem in this area. Where did this study requirement come from, and since its not an " anomaly" documented r
in Appendix A, do we really have to spend the manhours to perform such a
" study"? If so, in what time frame? Secondly, what importance does the sentence hear which comes immediately after the granting.of the Relief
-Request and states, "hovever, when new or replacement vibration instruments are obtained in the future, these instruments should meet all applicable-code requirements"? How are ve to address open-ended statements like this?
(See also PR-5, pg. 11). These statements are also not contained as provisions in Appendix A.
j 1,
- 13. Appendix A Anomaly (12 i
)
Anomaly #12 was not discussed anywhere else in the TER, the SER or the cover l
letter. It also was not previously discussed with us at the March 1991 meetings.
Ve do intend to create such a " basis document", however, the effort required to update the ISTP program / procedures to Rev. 3 vill be significant (since it vill be performed in addition to our normal workload),
and the extra vork to document the background information requerted in Anomaly (12 should be able to be divorced from the next years effort.
However, it appears that since Anomaly $12 is in Appendix A, that ve are being forced to put this documentation into our program within the next year. This documentation is general information that doesn't relate to any specific component. If ve do not get this extensive amount of background information into our program by April 5, 1994, what happens?
BSF/3272 9
I I
1 j
- , i
~
Mere
- n v + -+ ~
-