ML20065T313
| ML20065T313 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/21/1990 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| REF-GTECI-070, REF-GTECI-094, REF-GTECI-NI, TASK-070, TASK-094, TASK-OR GL-90-06, TXX-901053, NUDOCS 9012280035 | |
| Download: ML20065T313 (6) | |
Text
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Log # TXX-901053 I7 File # 10035 916 (3/4.4.4) clo 916 (3/4.4.8.3) clo 7UELEC7RlC 905.2 clo 905.4 clo 907.6 clo 903.9 clo w mi.in J. c.hm Jr.
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Ref.
- Generic letter 90-06 Generic Letter 89-10 December 21, 1990 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Wasilington, DC 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50 445 AND S0 446 RESPONSE TO GENERIC LETTER 90-06 RESOLUTION OF GENERIC ISSUE 70, " POWER 0PERATED REllEF VALVE AND BLOCK VALVE RELIABILITY," AND GENERIC ISSUE 94, ' ADDITIONAL LOW-TEMPERATURE OVERPRESSURE PROTECTION FOR LIGHT-WATER REACTORS," PURSUANT TO 10CFR50.54(f)
Gentlemen:
Generic Letter 90-06, dated June 25, 1990, requested that PWR licensee and construction permit holders advise t'ie NDf. staff of the current plans relating to PORVs, PORV block valves and low temperature overpressure protection and, in particular, whether TV Electric intinus to follow the staff positions included in Enclosures A and B as applicablr.. or propose alternative measures.
The recommendations of Generic letter 90-06, respective responses, and schedule for completion are listed in the attachment.
Sincerely,
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William J. Cahill, Jr.
JLR/grp Attachment c
Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3)
Mr. J. W. Clifford, NRR 0M L M hh hh b b 445 400 North ouve street L B. $i nati.3, Texa3 73:01 P
1.
t UNITED STATES 0: AMERICA NUCLEAR REGULATO'Y COMMISSION A
- In the Matter of
)
)
Texas. Utilities Electric Company
)
Docket Nos. 50 445
)
50-446 (Comanche Peak Steam Electric
)
Station, Units 1 & 2)
)
AFFIDAVIT William J. Cahill, Jr. being duly sworn, hereby deposes and says that he is Executive Vice President, Nuclear of TV Electric, that he is duly-authorized to sign and file with the Nuclear Regulatory Commission this response to Generic Letter 90-06; that he is familiar with-the content thereof; and that L
the matters set forth therein are true and correct to the best of his
' knowledge, information and belief.
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William J. CahilT, Jr.
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Executive Vice President, Nucle /
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STATE OF TEXAS COUNTY OF sour.nvr.u. L).
Subscribed and sworn to before me, a Notary Public, on this 21st day of necember
, 1990.
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Attachment to TXX-901053 Page 1 of 4.
1.
IMPROVEMENTS TO ALL PORVs AND BLOCK VALVES Section 3.1 of Enclosure A to Generic letter 90 Actions to be taken l
based on analysis and findinas for GI-70:
l' Position 1.
Include PORVs and block valves within the scope of an
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operational quality assurance program that is in compliance with 10 CFR_Part 50, Appendix B.
This program should include the following elements:
i a)
The addition of PORVs and block valves to the plant operational Quality Assurance List.
-b)
Implementation of a maintenance / refurbishment program for PORVs and block valves that is based on the manufacturer's o
recommendations or guidelines and is implemented by trained l
plant maintenance personnel.
c)
- When replacement parts and spares, as.well as complete components, are required for existing non-safety-grade PORVs and block = valves -(and associated. control systems), these items may be procured in accordance with the original construction codes and standards.
Response
a)-
The pressurizer PORVs and block valves for CPSES are included in the Quality Assurance List as delineated on FSAR Table 17A-1, " List of
'i Quality Assured Structures, Systems and Components." This classification subjects these valves to the most stringent requirements of our Quality Assurance program.
t b)
.The maintenance procedures'for the PORVs and block valves for CPSES.
are all. based on the respective manufacturer's guidelines and are implemented by trained plant personnel.
c)
Replacement parts' and spares; as well as complete components, are procured in accordance-with;CPSES procedures for safety related items.
No change to the existing program is: required.
Position 2a.
Include PORVs, valves in PORV control air systems, and block valves within the scope of a program covered by subsection IWV,
. Inservice Testing of Valves in Nuclear Power Plants," of.
Section XI of the ASME Boiler and Pressure Ve:4e1 Code.
Responsg:
The:PORVs, air accumulator check-valves, and block valves for CPSES are included in-the IST program. While not specifically addressed in the IST proom, the-air solenoids are an integral part of the PORV control
~ circuit and proper functioning is assured by the successful completion of L
.the PORV surveillance.
1 L
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Attachment to TXX-901053 Page 2 of 4 r.
l.-
IMPROVEMENTS TO ALL PORVs AND BLOCK VALVES (Continued)
Section 3.1 of Enclosure A to Generic letter 90 Actions to be taken based on analysis and findinas for GI-70:
Position 2b.
Stroke testing of PORVs should only be performed dc;ing Mode 3 (HOT STANDBY) or Mode 4 (HOT SHUTDOWN) cnd in al', cases prior to establishing conditions where the PORVs are used for low-l temperature' overpressure protection.
Stroke testing of the PORVs should not be performed during power operation.
Response:'
i CPSES PORVs are included in the Section XI Program and at stroke tested during cold shutdown as required by the Code.
PORVs are not stroke tested during power operation.
1 Position 2c.
Additionally, the PORY block valves should be included in the licensee's expanded MOV test program discussed in NRC Generic i
Letter 89-10, " Safety Related Motor Operated Valve Testing and Surveillance," dated June 28, 1989.
Response
The PORV block valves have been added to the Generic Letter 8910 MOV test program.
Position 3.
For operating PWR plants, modify the limiting conditions of operation of PORVs and block valves in technical specifications for Modes 1, 2, and 3 to incorporate the position adopted by the staff -in recent licensing actions, (Attachments A-1, A-2 andA-3of__theGenericletter),
i
Response
l
. TU Electric will submit an amendment request to modify the current Technical Specification Limiting Conditions of Operation to fully comply with those proposed by the Generic letter for PORV and islock valve reliability (Attachment A 1 for Westinghouse Plants with two PORVs).
II.
IMPROVEMENTS IN PROTECTION SYSTEM AVAILABILITY Section 3 of Enclosure B to Generic letter 90 Action to be taken for 01-94:
Position 3.
Revise current Technical Specifications for Overpressure Protection to reduce allowable outage time (A0T) for a single channel from 7 days to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the plant is in Modes 5 or i
6, (see Attachment B-1 to the Generic Letter).
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Attachment to TXX-901053 Page 3 of 4 11.
IM MOVEMENTS IN PROTECTION SYSTEM AVAllABillTY (Continued)
Section 3 of Enclosure B to Generic letter 90 Action to be taken for fiL-24:
Response
The CPSES cold overpressure technical specification currently allows the use of either PORVs or RHR suction relief valves for relief protection.
Although this configuration is acknowledged by the Generic Letter, a sam)1e specification for this configuration was not provided.
A revised i
Tec1nical Specification which reflects this configuration will be proposed, and will adopt a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed outage time when only one Cold Overpressure Protection device is available in Modes 5 or 6.
This revised technical specification will also include the option of having at least 1 PORV and 1 RHR suction relief valve operable during Modes 4, 5 and 6 when the reactor vessel head is on and t,1e RCS is not vented through a 2.98 square inch or larger vent. We beheve these i
approaches fully meet the intent of the Generic Letter.
TU Electric cooperated with six other utilities in developing a common approach to this action item of Generic Letter 90-06.
A joint effort was possible due to the similarity of plant types and technical specifications. These plants are all Westinghouse PWRs which utilize the PORVs and RHR suction relief valves for low-temperature overpressure protection.
Also, CPSES has in place administrative controls that provide restrictions for: 1) the restart of an idle reactor coolant pump (Technical Specification 3.4.1.3 and 3.4.1.4.1) and 2) the number of high pressure safety injection pumps and charging pumps allowed to be operable when LTOP is required (Technical Specifications 3.1.2.2, 3.1.2.3 and 3.5.3.2).
These administrative contrals provide additional assurance of proper pressure control during low temperature conditions.
111. SCHEDULE Generic Letter 90-06 Action:
for PWR plants with an operating license, staff positions 1, 2 and 3 in Section 3.1 of Enclosure A and staff position 3 in Section 3 of Enclosure B should be implemented by the end of the first refueling outage that starts 6 months or later from the date of the Generic Letter, for PWR CP holders, staff positions 1 and 2 in section 3.1 of Enclosure A
~should be implemented before initial criticality or within 6 months of the date of the Generic Letter, whichever is later.
The technical specification modifications in staff position 3 in Section 3.1 of Enclosure A and in Section 3 of Enclosure B should be submitted by the end of the first refueling outage that starts 6 months or later from the date of the Generic Letter.
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Attachment to TXX-901053 Page 4 of 4 111. SCHEDULE (Continued.).
Generic letter 90-06 Action:
If the licensees and the CP holders commit to implement these recommended technical specifications, it is requested that they submit modifications to their current technical specifications in a license amendment in accordance with the schedule noted above.
Response
Froposed Technical Specification changes for Unit I will be submitted by the end of the first refueling outage, which is currently scheduled for September 1991.
Because refueling outage start dates are fluid, this date is approximate.
All changes required for Unit 2 will be implemented before fuel load.