ML20058N480
| ML20058N480 | |
| Person / Time | |
|---|---|
| Issue date: | 12/08/1993 |
| From: | David Nelson Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9312220055 | |
| Download: ML20058N480 (26) | |
Text
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UNITED STATES
',0 ' ' E 7i NUCLEAR REGULATORY COMMISSION (y
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WASHINGTON, D.C. 2055H001 December 8, 1993 ORGANIZATION:
Nuclear Management And Resources Council (NUMARC)
SUBJECT:
SUMMARY
OF MEETING WITH NUMARC CONCERNING NUMARC PROPOSALS FOR CHANGING THE LICENSE RENEWAL RULE On Thursday, October 28, 1993, representatives of NUMARC met with the NRC staff in Bethesda, Maryland, to present further information on NUMARC proposals to amend the license renewal rule (10 CFR Part 54). A similar meeting was held on October 15, 1993. is the meeting attendance list. is a copy of the information provided by NUMARC for discussion during the meeting.
The presentation centered on NUMARC's recommended definition of age-related degradation unique to license renewal (ARDUTLR) with examples of its use considering various plant systems, structures, and components (SSCs).
NUMARC refined their definition of ARDUTLR from that included in their submittal dated October 12, 1993, considering staff comments at the October 15 meeting. NUMARC stated that the changes are primarily for legal construction considerations and considers the fundamental concepts of the definition to be consistent with those in their submittal.
Part (a) of the definition that considers long-lived passive structures and components was not materially changed.
Part (b) underwent several changes.
The " refurbishment" exclusion in (b)(ii) was deleted based on recognition that refurbishment is subsumed within maintenance processes, but does not necessarily share equal safety status with " replacement." A 40-year qualifier was added to the " replacement" exclusion instead of replacement " based on time or condition." This recognizes that routine replacement, like refurbishment, is within the broader scope of maintenance options, but retains the 40-year ARDUTLR exclusion consistent with the exclusion afforded passive structures and components in part (a). The " replacement or refurbishment on time or condition" exclusion reappears in the proposed integrated plant assessment (IPA) section 54.21(a)(3).
In (b)(iii), the " existing program or activity" subject was elevated to "CLB program" to clarify the ARDUTLR exclusion by definition, but the former wording also reappears in section 54.21(a)(3), granting the
" existing programs" ARDUTLR exclusion.
NUMARC illustrated the use of the proposed definition of ARDUTLR using examples of various plant SSCs of Babcock and Wilcox (B&W) and General Electric (GE) designs. The examples covered a broad range of SSCs demonstrating each aspect of the definitica of ARDUTLR.
A topic of considerable discussion was NUMARC's application of important to license renewal (ITLR) function :.t the system versus redundant train level.
The NUMARC position is based on the assumption in the current licensing bases (CLB) that, with a single failure that disables one redundant train, the other d54 7 (MMWe
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. fully capable train is available for accident mitigation.
In NUMARC's definition of ARDUTLR, this non-redundant screening test excludes dual train i
systems from being subject to ARDUTLR since system function is preserved by redundancy.
NUMARC explained this rationale by examples, illustrating that non-redundant passive, long-lived, common train components are dispositioned as possibly subject to ARDUTLR subject to a review of their monitoring program. The example of the B&W design decay heat removal system refueling water storage tank (RWST) and single discharge piping represented long-lived, passive components, whose failure results in the loss of system ITLR function, since the tank and piping are common to the downstream redundant trains. The tank and piping are considered subject to ARDUTLR because programs typically do not exist to fully manage aging of these components. On the other hand, the example of the Class I reactor coolant pressure boundary, which is non-i redundant, would be considered as not subject to ARDUTLR, based on an evaluation of existing performance and condition-monitoring programs that are determined to be adequate.
In a subsequent example, the non-redundant exclusion was elevated further to safety function versus system function using the GE design high pressure coolant injection (HPCI) and automatic depressurization (ADS) systems. These single train emergency core cooling system (ECCS) sub-systems represent diverse rather than redundant trains. ADS is used to depressurize the reactor to permit ECCS injection by the low pressure sub-systems in the event of HPCI failure (and other reasons).
Based on this reasoning, NUMARC considers the HPCI passive, long-lived components to be not subject to ARDUTLR. The staff noted that NUMARC's definition of ARDUTLR referred to system function, not safety function, thus disposition of the HPCI passive, long-lived components as not subject to ARDUTLR for this reason may be inappropriate.
Following this discussion NUMARC indicated that they will reconsider their position regarding redundancy and diversity of function.
In a general discussion regarding the definition of ARDUTLR, NUMARC indicated that the regulatory usefulness of retaining the concept of unique aging, as opposed to eliminating it as suggested by others, is a desire to explicitly limit renewal reviews to the period beyond the original operating license term.
Regarding the IPA process, NUMARC stated that changes to IPA steps 54.21(a)(1) and (2), initial screening of SSCs as ITLR and identification of required functions, were not being recommended based on industry's perception that the NRC wanted to preserve these steps.
In addition, NUMARC stated that this process would be somewhat useful for some licensees, although direct screening for passive, long-lived structures and components would be generally more efficient.
Several other issues were discussed. NUMARC envisions the renewal application as containing separate IPA and final safety analysis report (FSAR) documents.
With regard to descriptions of effective programs in the application, NUMARC 3
considers that program acceptance criteria are not specifically needed.
Considering aging effects versus aging mechanisms, NUMARC indicated that the industry wants to retain the option of managing aging mechanisms. NUMARC i
December 8, 1993
-. stated that recommendations for other rule changes, regarding aging effects versus mechanisms and the IPA process, would be included in an additional submittal to be sent in November 1993.
On the topic of equating ITLR function to maintaining the CLB, the staff indicated preliminary receptiveness to this concept. With recognition that performance-based evaluations are inappropriate for passive, long-lived structures and components, the staff and NUMARC agreed that some direct aging evaluation may be necessary. NUMARC stated that further information on this topic would be provided.
The form, timing, and relationship with the license renewal process of any time-limited analysis issues were discussed. NUMARC stated that no firm position had been adopted on this topic.
The staff indicated that approaches for addressing time-limited analysis issues were being considered.
/s/
David J. Nelson, Project Manager License Renewal and Environmental Review Project Directorate Associate Directorate for Advanced Reactors and License Renewal Office of Nuclear Reactor Regulation
Enclosures:
1.
Attendees List 2.
NUMARC Handout DISTRIBUTION:w/ Encl. 1 TMurley/FMiraglia, 12G18 JCallan, 12G18 DCrutchfield, llH21 WTravers, 11H21 SNewberry, 11F23 OGC EJordan, MNBB3701 ACRS (10)
MKarman, OCH ENcKenna, OCH DISTRIBUTION: w/ Encl. 1 & 2 Central File PDR PDLR R/F DNelson, llF23 SReynolds, 11F23 LLuther, llF23 DISTRIBUION: VIA E-Mail:
DJackson, llF23 JMoulton, 11F23 RAnand, llF23 RParkhill, llF23 THiltz, I?F23 HPolk, llF23 SHoffman, llF23 Stee, llF23 SFlanders 11F23 PDLR:L W PDLR:PM PD 5
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'12/ /93 DOC ENT NAME: NELSON 10/28 MEETING
SUMMARY
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ENCLOSURE 1 MEETING ATTENDANCE NUMARC PROPOSALS FOR LICENSE RENEWAL OCTOBER 28, 1993 NAME ORGANIZATION David Nelson NRR/PDLR Ron Parkhill NRR/PDLR Steve Reynolds NRR/PDLR William Travers NRR/PDLR Scott Newberry NRR/PDLR Sam Lee NRR/PDLR Tom Hiltz NRR/PDLR Debbie Jackson NRR/PDLR Scott Flanders NRR/PDLR Raj Anand NRR/PDLR John Moulton NRR/PDLR Harold Polk NRR/PDLR Steve Hoffman NRR/PDLR Myron Karman OCM/KR Eileen McKenna OCM/GD Fred Burke BWNT/BWOG Bob Borsum BWNT Charles Petrone NRR/DRIL Jeff Sharkey NRR/PDLR Ellen Ginsberg NRR/AGC Barry Tilden BG&E Chuck Pierce Southern Nuclear /BWROG Ray Ng NUMARC Doug Walters NUMARC Debbie Staudinger BWOG Joseph Gallo Gallo & Ross Charles Meyer Westinghouse Peter Stancavage GE Larry Gifford GE Tony McConnell BWOG Tricia Heroux EPRI Kathryn Kalowsky Winston & Strawn Dennis Harrison DOE Charles Thompson DOE
ENCLOSURE 2, gs4.21 (a)(1)a(2)
INDUSTRY INTEGRATED PLANT ASSESSMENT PROCESS
- IS SSC IMPORTANT TO LICENSE RENEWAL?
V yes g54.21(a)(3)
DEF. ARDUTLR Y
(b) IS ITLR SSC NO ARDUTLR (a) IS ITLR SSC LONG-LIVED (i) MAINTENANCE RULE
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yes y
y no AGE-RELATED ARE SSCs SUBJECT TO EXISTING yes DEGRADATION PROGRAMS THAT MONITOR ASSESSMENT CONDITION OR PERFORMANCE...
DOES SSC ITLR HAVE ARDUTLR PER no m
THE " AFFIRMATIVE" DEFINITION OF ARDUTLR?
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$54.21(a)(d) DETF%4INE NEED FOR AN EFFECTIVE PROGRAM V
$54.21(a)(6) EFFECTIVE PROGRAM EVALUATION 10/28/93
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PROPOSED CHANGES TO 10 CFR PART 54
@ 54.3 Definitions i
As used in this part.
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i Age-related degradation unique to license renewal (ARDUTLR) is ace-related i
degradation to SSCs ITLR the effects of which. notwithstanding the application of existing programs during the period of extended operation. result in loss ofITLR function such that plant operation is not in accordance with the CLB during the period of extended operation.
i For purposes of this definition, i
(a) An SSC ITLR could be subject to ARDUTLR and must be evaluated under 54.23(a)(4)-(a)(6), as appropriate. if:
(i) its service life exceeds 40 years; and (ii) it is passive (ir, cannot or should not change state under normal operation or in response to accident conditions); and l
(iii) its failure would directly result in loss ofITLR system or structure function in a manner not permitted by the CLB.
l (b) Other than those SSCs ITLR identified in paragraph (a) of this definition, an i
SSC ITLR shall be deemed not to have ARDUTLR ifit is subject to-
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(i) the provisions of 10 CFR. 50.65; or
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a (ii) replacement or refurbishment based upon time or condition; or 5
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-(iii) an existing program or activity that monitors condition or pe,rformance and l
reasonably assures that the SSC will be capable of performing its ITLR function in j
accordance with the CLB during the period of extended operation.
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I PROPOSED CHANGES TO 10 CFR PART 54 54.3 Definitions As used in this part, 1
Age-related degradation means a change in a system's, structure's, or component's performance or physical or chemical properties resulting in whole or part from aging.
Examples of this type of change include changes in dimension, ductility, fatigue resistance, fracture toughness, mechanical strength, polymerization, viscosity, and dielectric strench.
Age-related degradation unique to license renewal (ARDUTLR) is -- age-related degradation to SSCs ITLR the effects of which. notwithstanding the soplication of eristine oroernms durine the neriod of extended oneration. results in loss ofITLR
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function such that pInnt oneration is not in accordance with the CLR durine the period of extended operation.
For purposes of this definition.
l (a) An SSC ITLR could be subject to ARDUTLR and must be evaluated under the sopronrinte provisions of 54.21 if:
1 (i) its service life exceeds 40 years:
(ii) it is passive (i.e. cannot or should not chance state under normni oneratine conditions or in resnonse to accident conditions): nnd
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1 (iii) its failure would directiv result in loss ofITLR system or structure function in a manner not nermitted by the CLB.
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(b) Ercent for those SSCs ITLR that meet the criteria identified in naracraph (a) of this definition. an SSC ITLR shall be deemed not to have ARDUTLR ifit is j
subject to:
i (i) the nrovisions of10 CFR 50.65:
1 10/27/93 j
(ii) replacement such that service life is less than 40 years: or (iii) a CI B procram that monitors condition or performance to maintain
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compliance with the CLB.
Excerpted from { 54.21(a)(3)
(3) For those SCs identified in paragraph (a)(2) of this section, identify the SCs that are subject to age-related degradation unique to license renewal. For the purpose of this determination. SCs will not have ARDUTLR if they are subject to existing programs that monitor condition or performance. or orovide for replacement or refurbishment on time or condition. and reasonably assure that the SSC will be canable of performine is ITLR function in accordance with the CLB during the period of extended operation.
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EVALUATION MATRIX SYSTEM COMPONENT ITLR ARDUTLR DEFINITION EFFECTIVE COMMENTS ARDUTLR PitomtAM LLP MR R
CLB DISPOSITION REQUlltED (a)
(b.i)
(b.ii)
(b.iii)
Plant systent NO not to be included iii Circulating disposition itettial applicatloit Water Main system YES Feedwater disposition Reactor Class I piping YES YES NO NO Coolant and interfaces RWST and YES YES YES YES See attached Decay lleat djseliarge description Ref:
piping BWNT 12-1228335-00 U80/600 systeni YES NO YES NO NO VAC SR disposition Power Auxiliary Pressure YES NO NO YES NO NO Stenin Transinitter in Aux Huilding I;iie Spiinkles s YES NO NO NO Y ES.
NO NO Protection
CLASS I PIPING Descrio': ion
- The RCS provides a primary boundary preventing loss of fission products to the environment, it also provides coolant circulation through the core to the steam generators with the reactor coolant pumps. The reactor coolant system and interconnecting systems piping out to either the first or second isolation valve (depending on the Piping Code of Record for the specific plant) is class I.
Sys :em Screening - ITLR (54.2' (a)(1))
- Safety Related
- Fire Protection, Station Blackout
- Technical Specification Limiting Condition for Operation (leakage limits)
Comoonent Screening - ITLR (54.21(a)(2))
- Maintain structural integrity and pressure boundary NUMARC
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REACTOR COOLANT SYSTEM (RCSD CLASS I PIPING
- ARDUTLR Definition (54.21(a)(3))
- Under Section (a) (i), (ii), and (iii) of the proposed definition, this component is:
(i) long-lived (i.e. service life greater than 40 years);
(ii) passive; and (iii) its failure results in the loss of system ITLR function Class I piping could be subject to ARDUTLR NUMARC
REACTOR COOLANT SYSTEM (RCS's CLASS I PIPING Program Evaluation anc Ef ects Assessment (5L.21(aV. 3D.
- Volumetric and surface examinations as part of ASME Section XI inservice inspection programs
- Technical Specification surveillance programs
- ASME Section til fatigue analysis Conclusions
- The existing plant programs and the evaluation of fatigue on the Class I piping assure that the effects of aging will be managed to assure ITLR function in accordance with the CLB through the license renewal period
- Class I piping is not subject to ARDUTLR per 54.21(a)(3)
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4 DECAY HEAT SYSTEM.
RWST AND SINGLE DISCHARGE PIPING i
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- The Decay Heat System removes fission product decay heat from the RCS during.the later stages of cooldown. It can be used to inject borated water into the reactor-vessel for long term emergency core cooling, and also provides auxiliary spray to the pressurizer. The refueling water storage tank (RWST) and single discharge piping provides and delivers a reservoir of borated water for these system functions.
System Screening - ITLR (54.21(a)(1))
- Safety.Related
- Fire Proteciton, Station Blackout-
- Technical Specification Liminting Condition for Operation Component Screening - ITLR (54.21(a)(2))
- Maintain pressure boundary
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DECAY HEAT SYSTEM RWST AND SINGLE DISCHARGE PIPING ARDUTLR De"inition (54.2'(a)(3))
Under Section (a) (i), (ii), and (iii) of the proposed definition, these components are:
(i) long-lived (i.e. service life greater than 40 years);
(ii) passive; and-(iii) their failure results in the loss of system ITLP, function-The RWST and single discharge piping could be subject to ARDUTLR 4
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DECAY HEAT SYSTEM RWST AND SINGLE DISCHARGE PIPING 3rogram Evaluation anc Effects Assessment (14.21(a)(3))
-- Programs typically do not exist to fully manage aging of these components Conclusions
- The RWST and single discharge piping are subject to ARDUTLR
- No existing programs that adequately manage aging
- Effective program required NUMARC
480/600 VAC SAFETY RELATED POWER SYSTEM Description l
- the 480/600 VAC Safety Related Power System provides a 1E source of electrical power to safety related and certain non
-safety related loads. This power supply is required to provide motive power to numerous plant components which must function to safely shut down the plant after a variety of design i
basis events and other transients. This system is a dual train l
system connected to the plant emergency diesel generators.
System Screenina - ITLR (5L.21(aV3D..
- Safety Related
- Fire Protection, Station Blackout, EQ l
- Technical Specification Limiting Condition for Operation The 480/600 VAC system will be addressed as an entire system rather than on a component basis NUMARC
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480/600 VAC SAFETY RELATED POWER SYSTEM ARDUTLR Defini': ion (54.21(a)(3))
- The 480/600 VAC system does not meet Section (a) of the proposed definition since the system is active. The system does meet Section (b)(i) of the proposed definition, "the provisions of 10 CFR 50.65"
- The 480/600 VAC Safety Related Power System is_ ant subject to ARDUTLR Conclusion
- Performance goals will be set for this system under the provisions of the Maintenance Rule. No further evaluation of the system is required for license renewal.
- The 480/600 VAC Safety Related Power System is not subject to ARDUTLR per 54.21(a)(3)
AUXILIARY STEAM SYSTEM PRESSURE TRANSMITTER IN AUXILIARY BUILDING Descriotion
- The Auxiliary Steam System supplies reduced pressure steam to a number of auxiliary systems, components and heat exchangers throughout the plant. The pressure tansmitter of interest outside containment is one connected to a high energy line in the auxiliary building. The purpose of this transmitter is to provide a low pressure signal to an interlock device that will automaticily isolate the high energy line on decreasing pressure, isolating the break and terminating the HELB.
System Screening - ITLR (54.21(a)(1))
- Non-Safety Related
- Environmental Qualification Program Comoonent Screening - F LR {5L.21(a)(2))
- Transmit a pressure signal NUMARC w-
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AUXILIARY STEAM SYSTEM PRESSURE TRANSMITTER IN AUXILIARY BUILDING ARDU~ LR Definition (54.21(a)(3))
- The pressure transmitter does not meet the criteria established in Part (a)(i), (ii), and (iii) of the proposed definition of ARDUTLR
- The pressure transmitter is subject to regular replacement under the provisions of the EQ program and is therefore dispositioned under Part (b)(ii) of the proposed definition of ARDUTLR.
Conclusion
- This component is not subject to ARDUTLR per 54.21(a)(3)
I FIRE PROTECT lON SYSTEM SPRINKLER HEADS Description
- The Fire Protection System will provide a deluge of water to protect safety realted equipment in the event of a fire. The sprinklers employ either a wet or dry setup. In a wet setup the piping to the sprinklers is filled with water. In a dry setup, an isolation valve must open to fill the lines. In each setup, the sprinkler plug must melt to open the sprinkler valve.
System Screening - ITLR (54.21(a)(1))
- Fire Protection Component Screening - ITLR (54.21(a)(2))
- Provide flow NUMARC
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SPRINKLER HEADS 4
ARDUTLR Definition (54.21(a)(3))
- The sprinkler heads doe not meet Part (a) of the proposed i
definition since theyare active. The components are taken through Part-(b) of the proposed definition.
- These components are not in the scope of the Maintenance Rule nor are they routinely replaced. There are however, CLB programs to assure that these sprinkler heads perform their ITLR functions. Fire suppression systems are subject to maintenance, tests, surveillance requirements under Appendix R and implementing fire protection plans.
- Sprinkler heads are 'not subject to ARDUTLR per 54.21(a)(3) i
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i MAIN FEEDWATER SYSTEM l
Description The Main Feedwater System is the system responsible for delivering condensate grade water to the steam generators to produce steam System Screening - ITLR (54.21(a)(' ))
Safety Related
- ATWS To meet the ITLR requirements, the system is only required to provide isolation functions and pump status inputs to protection systems. Only a small portion of the Main Feedwater System is used to accomplish these functions.
The Main Feedwater System figure illustrates that portion.
Conclusion The Main Feedwater System was used as an example of a system that is ITLR but only a small number of components are used to accomplish the ITLR functions.
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PLANT CIRCULATING WATER SYSTEM Description
- The plant circulating water provides heat removal from the plant during normal operation. using a plant with cooling towers as an example, the CW System water flows through the main condenser tubes and is pumped out to the cooling towers where it is cooled and recirculated back to the main condensers. The plant circulating water performs no safety functions and is not required to support any of the ITLR Screening critiera.
Sys":em/ Component Screening (54.2' (a)(' ))
- System and system components not required to function to meet any of the ITLR requirements identified in 10 CFR 50.54. Therefore, the system is not ITLR.
Conclusion
- No further evaluation of system / components is required NUMARC
DRYWELL FLOOR DRAIN AND EQUIPMENT DRAIN SUMP SYSTEM This example demonstrates the application of Part (b)(iii) of the proposed definition of ARDUTLR
System Description
- Two steel lined sumps
- Four motor driven sump pumps
- One heat exchanger
- Sump level measurement systems
- Sump pump discharge flow measurement systems
- Associated piping, instrument and electrical components NUMARC
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DRYWELL FLOOR DRAIN SUMP DRYWELL EQUIPMENT DRAIN SUMP DRYWELL FLOOR DRAIN AND EQUIPMENT DRAIN SUMP SYSTEM SIMPLIFIED DIAGRAM
DRYWELL FLOOR DRAIN AND EQUIPMENT DRAIN SUMP SYSTEM Importance to license renewal - 54.21(a)(1)
- Safety-related (containment isolation portions)
- Subject to operability requirements contained in the facility technical specification limiting conditins for operation ITLR system function - 54.21(a)(2)
- Provide primary containment isolation of pump discharge lines
- Measure drywell leakage and demonstrate that it does not exceed the limits specified in the technical specifications NUMARC
DRYWELL FLOOR DRAIN AND EQUIPMENT DRAIN SUMP SYSTEM ARDUTLR evaluation - 54.21(a)(3)
- Applying Part (a) of the proposed ARDUTLR definition:
(i) with the exception of I & C DEVICES, all of the system components are expected to have service lives greater than 40 years n (ii) The following system components are considered passive:
sump liners heat exchanger piping (including instrument tubing, flow elements and small manual valves )
(iii) Failure of the following passive components could result in i
loss of the ITLR system function in a manner not permitted by the CLB sump liners - failure could prevent collection of drywell leakage, giving erroneously low leakage rate readings heat exchanger - pressure boundary failure coulc result in transferring liquid from the equipment drain sump to the floor drain i
sump piping - pressure boundary failure could prevent transfer of the l
collected liquids from the sumps to the radwaste system NUMARC
l DRYWELL FLOOR DRAIN AND EQUIPMENT DRAIN SUMP SYSTEM
- Therefore, these passive components would require furter evaluation, since they coud be subject to ARDUTLR
- The remaining components will be assessed pursuant to Part (b) of the definition ARDUTLR evaluation - 54.21 (a)(3)
- Applying Part (b) of the proposed ARDUTLR definition to the remaining system (active components):
(i) the four air operated containment isolation valves are safety-related and are within the scope of the maintenance rule.
Therefore, these components do not require further evaluation (iii) the remaining system components are covered by CLB programs which adequately ensuer the ITLR functions as documented in the following table.
Therefore, these components do not require furthe evaluation NUMARC C
DRYWELL FLOOR DRAIN AND EQUIPMENT DRAIN SUMP SYSTEM PROGRAMS COMPONENT CLB PROGRAM PROGRAM FEATURES SUMP PUMPS SURVEILLANCE TESTING OPERABILITY OF TIIE STANDBY PUMP IS VERIFIED QUARTERLY BY SWITCillNG STANDBY PUMP TO LEAD PUMP FOR AT LEAST TWO ON-OFF CYCLES WillLE OP-ERATOR MONITORS PUMP STATUS.
PUMP DISCilARGE FLOW SUR'<EILLANCE TESTING TIIE FLOW INSTRUMENTS ARE CALI-INSTRUMENTS BRATED ONCE PER CYCLE. CHANNEL CllECKS ARE PERFORMED EVERY FOUR HOURS.
SUMP LEVEL SURVEILLANCE TESTING TIIE LEVEL INSTRUMENTS ARE CALI--
INSTRUMENTS BRATED ONCE PER CYCLE. CHANNEL CHECKS ARE PERFORMED EVERY FOUR HOURS.
PUMP DISCHARGE CHECK CHECK VALVE REVIEW REPRESENTATIVE CHECK VALVES ARE VALVES PROGRAM DISASSEMBLED AND INSPECTED. EN-GINEERING, OPERATING, AND i
MANUFACTURER DATA IS COLLECTED AND l
CENTRALIZED. HISTORIC MAINTENANCE AND TESTING DATA IS COLLECTED AND CENTRALIZED. THE INSPECTIONS AND l
DATA ARE USED TO TREND VALVE PER-FORMANCE AND EVALUATE THE NEED FOR PREVENTIVE MAINTENANCE OR ADDITIONAL TESTING ON INDIVIDUAL OR SELECT GROUPS OF ClIECK VALVES.
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COOLANT INJECTION SYSTEM l
l This example demonstrates the application of i
Parts (a)(iii) and (b)(i) of the proposed definfition of ARDUTLR with regard to diversity System description
- The BWR high pressure coolant injection system (HPCI) is a high pressure emergency core cooling system. It is a single loop system with automatic depressurization system for back-up Importance to license renewal - 54.21(a)(1)
- Safety-related NUMARC
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1 HIGH PRESSURE COOLANT INJECTION SYSTEM ITLR system functions - 54.21 (a)(2)
- Perssure retaining capability of reactor coolant boundary
- High pressure emergency core cooling depressurization to allow low pressure coolant injection and core spray
- Primary containment integrity
- Isolation of steam side on pipe rupture l
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HIGH PRESSURE COOLANT INJECTION SYSTEM ARDUTLR evaluation - 54.21 (a)(3)
Applying Part (a) of the definition to the pressure retaining boundary components except the reactor coolant boundary (which will be discussed under other Class I piping examples),
these components:
(i) have service lives greater than 40 years, l
(ii) are passive i
(iii) after the second containment isolation valve, system function is maintained in spite of individual component i
failures; with the HPCI system inoperable, adequate ocre l
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COOLANT INJECTION SYSTEM 54.21(a)(3)- applying the ARDUTLR definition, Part (b)(i):
- all elements after the second isolation valve in the HPCI system are within the scope of the maintenance rule
- therefore, high pressure emergency cooling function components can be dispositioned as not having ARDUTLR NUMARC
' t REACTOR RECIRCULATION SYSTEM This example demonstrates the application of Part (b)(iii) of the propsed definition of ARDUTLR System description Two 50% capacity recirculation system loops, each with a:
l vanable speed motore driven pump i
piping n motor operated pump suction and discharge valves flow control system instrumentation and controls NUMARC s
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REACTOR RECIRCULATION SYSTEM l
i Important to license renewal - 54.21(a)(1) l
- Safety related reactor coolant pressure boundary integrity valve isolation for LPCI
- Operability requirements in technical specification limiting conditions for operation (LCO) for the recirculation pump and motors only l
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REACTOR RECIRCULATION SYSTEM System functional review - 54.21 (a)(2)
- The functions of each reactor recirculation system loop are:
n provide primary coolant flow through the reactor core and control reactor power by varying recirculation flow rate pressure retaining capabiity of reactor coolant boundary provide a flow path for LPCI downstream from the pump outlet isolation valve 1
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REACTOR RECIRCULATION SYSTEM Applying Part (a) of the definition (54.21 (a)(3)) to the pressure retaining capability of the reactor coolant boundary (i.e. pump suction and discharge piping, valve, bodies, and recirculation pump casing), the pressure retaining boundary components:
- (i) have service lives greater than 40 yea.,o
- (ii) are passive
- (iii) failure of the passive elements will cause loss ofsystem function
- Therefore, all of these passive elements could have ARDULTR and would require further evaluation. These passive elements could be evaluated using information in NUMARC Report 90-09 "BWR Primary Coolant Pressure Boundary License Renewal Industry Report" NUMARC
REACTOR RECIRCULATION SYSTEM Applying Part (a)(i) and (ii) of the definition to the operating capability of the reactor recirculation pumps / motors and the safety related valves, these components:
- have service lives greater than 40 years
- are att passive Applying Part (b)(iii) of the definition to the operating capability of the pumps / motors:
- the pump / motor is subject to CLB programs to maintain this equipment within the current licensing basis (CLB) l Therefore, the reactor recirculation system pumps / motors can be dispositioned as Dat having ARDUTLR because l
CLB programs outlined in the technical specifications to l
maintain this equipment in compliance with the CLB.
Apply Part (b) of the definfition to safety-related valves
- the valves are covered by the maintenance rule NUMARC
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4 FEEDWATER SYSTEM This example demonstrates the application of the definition of SSCs important to license renewal System description t
- BWR feedwater system provides a regulated supply of feedwater to the reactor vessel during normal operation NUMARC
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RCIC FEEDWATER SYSTEM SIMPLIFIED DIAGRAM
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FEEDWATER SYSTEM Importance to license renewal 54.21 (a)(1)
- Safety-related portions - ITLR (covered under reactor coolant pressure boundary)
- Non-Safety related portions - not ITLR NUMARC
FEEDWATER SYSTEM
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i Level of application detail: no detail regarding the non-safety related portions of the feedwater system FSAR supplement detail: no detail regarding the non-safety related portions of the feedwater system The methodology for making this determination is
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subject to review under 54.21(a)(4) 1 4
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