ML20082E933
| ML20082E933 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 11/15/1983 |
| From: | William Jones OMAHA PUBLIC POWER DISTRICT |
| To: | John Miller Office of Nuclear Reactor Regulation |
| References | |
| LIC-83-285, NUDOCS 8311280374 | |
| Download: ML20082E933 (8) | |
Text
.
Omaha Public Power District 1623 Harney Omaha. Nebraska 68102 402/536 4000 November 15, 1983 LIC-83-285 Mr. James R.
Miller, Chief U.
S.
Nuclear Regulatory Commission Of fice of Nuclear Reactor Regulation Division of Licensing Operating Reactors Branch No. 3 Washington, D.C.
20555
Reference:
Docket No. 50-285
Dear Mr. Miller:
Inservice Inspection and Testing Program Relief from ASME Boiler and Pressure Vessel Code,Section XI The Commission's letter to the Omaha Public Power District da ted September 30, 1983 transmitted the safety evaluation j
for the relief requests from ASME Boiler and Pressure Vessel Code,Section XI.
The safety evaluation contained several requests for additional information.
This information is provided in Attachment 1 to this letter.
The District wishes to note that this safety evaluation is based upon the July 7, 1983 letter which only provided a "best estimate" of exemptions required from the 1983-1993 ISI Program Plan.
The District, on September 26, 1983, sub-mitted the 1983-1993 ISI Program Plan.
That submittal con-tained the complete list of all known exemptions required l
from Section XI.
G311280374 831115 PDR ADOCK 05000285 P
PDR 455:24 Employment with Equal Opportunity Male / F emale
)
I l1
Mr. James R.
Miller LIC-83-285 Page Two to this letter contains a list which summarizes the dif ferences be tween the "best estimate" exemption re-
~
quest letter of July 7, 1983 and the exemption requests con-tained in the September 26, 1983 letter.
should be used for the review of the District's updated list oof exemption requests contained in the September 26, 1983 letter.
Sincerely, T
/
I W. C. Dones Divisl. n Manager Production Operations WCJ/DJM:jmm Attachments cc:
LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.
Washington, D.C.
20036 Mr.
E. G.-Tourigny, Project Manager Mr.
L.
A. Yandell, Senior Resident Inspector i
RESPONSE TO NRC SAFETY EVALUATION CONCERNS ATTACHED TO THEIR LETTER TO W. C. JONES DATED SEPTEMBER 30, 1983 The NRC's review of the District's July 7, 1983 submittal noted the following deficiencies in the ISI program:
1.
Systems or_ portions of systems omitted from the ISI program:
auxiliary feedwater, emergency diesel gener-ator cooling water, and diesel generator fuel oil transfer and storage systems.
2.
Components omitted from the ISI/IST program:
reactor coolant system power operated relief valves (PORV's) and their associated PORV block valves.
3.
Valves omitted from the leak testing requirements of Technical Specification Table 2-9:
HCV-347 SI-205 HCV-348 SI-207 SI-196 SI-211 SI-199 SI-215 SI-202 SI-219 The. District's response to these deficiencies noted by the NRC are:
1.a The District's-submittal of September 26, 1983 in-cluded the auxiliary feedwater system in the ISI/IST Program Plan.
1.b The emergency diesel generator cooling water system does not need to be included in the ISI/IST program under provisions of Section XI.
This system is a closed-loop, self-contained engine radiator system with no components amenable to testing.
Functionality is assured by the District's monthly diesel generator operational test, ST-ESF-6, F.2.
1.c To put the District in full compliance with the cur-rent code with regard to testing of the fuel oil (FO) transfer system would require the addition of dif-ferential pressure measurement for the FO transfer pumps, installation of thermocouples on the FO trans-fer pumps, and addition of monthly vibration testing for the FO pumps.
This effort is deemed unnecessary and superfluous in view of the monthly testing which has provisions to monitor and assure operation of the four FO transfer pumps.
[Just prior to shutting down the diesel generator during a monthly test, operation of the FO transfer pumps is checked per ST-ESF-6, F.2(16).]
' Ten years of monthly testing of the diesel-generator systems has never yielded a failure in the FO transfer pumps..'Thus, in view of the monthly testing of the diesel generator systems and the existing testing re-quirements which assure functionality of-the FO trans-fer pumps and in view of ten years of successful oper-ation without a failure, the District does not believe
-that modifications to existing procedures and systems will result in'a greater level f
9 sa f e ty <n assured system operation.
The District, therefore, requests exemption from the testing requirements of Section XI, Articles'IWD-2400 and IWP-3100.
The basis for this is that existing surveillance testing.is used to fulfill
. Technical Specification 3.7 (Emergency Power System Periodic Tests) and Table 3-2 (Minimum Frequencies for Checks, Calibrations, and Testing of Emergency Safety Features, Instrumentation and Controls), Items 11 and 12.
This is deemed adequate to assure system reli-ability.
With regard to the other requirements of the Section XI code,. such as supports testing and hydro-testing, the District will take the built-in pipe support exemptions of IWD-1220.1 and 2 with regard to Class 3 components 4"-in diameter or less.
The District also requests to exempt the system from a 1.1 times hydro on the basis of its existing yearly FO system leak in-spection, ST-ESF-6, F.5(B), which follows industry standards for testing FO systems for leakage using black-light as an aid.
2.
With regard to testing of the PORV's and the PORV block' valves, the District should point out that the PORV's were not qualified under IE Bulletin 79-OlB due
[
to analysis which has shown that the procedure for l
handling a small break LOCA would also adequately handle a blocked open PORV/PORV block valve system.
Operation of the PORV's is an operational convenience and not required for mitigating the consequences of an accident, nor to achieve safe shutdown of the plant.
However, the operability of the PORV's and block valves is verified each refueling o.utage through l
execution of surveillance test ST-ESF-6, F.3 and F.4.
I 3.
HCV-347 and 348 are both in " Containment Leak Testing" and included in the new ISI Program Plan.
SI-196, 199, 202, and 205 are check valves in 2500 psi design lines.
For this reason the Franklin Research Institute did not mention them in their October 20, 1980 Technical Evaluation Report (NRC-03-79-118) which j
was included with the April 20, 1981 order letter on l
l
m
. the-leak testing of certain check valves.
Similarly, SI-207, 211, 215, and 219, if. leaking, would gradually fill the SI tanks, which are alarmed with LO/LO and HIGH/HIGH alarms.
This, plus the fact that the SI tanks relieve in containment, assures sufficient pro-tection against accidental releases due to leakage through.these valves.
Summary The District agrees with the NRC with regard to the addition of the auxiliary feedwater system to the ISI/IST program.
With' regard to the diesel generator coolant and fuel oil transfer system, the District believes that adequate testing has been done (during the first ten year interval) and will be continued under the existing non-ISI Fort Calhoun surveil-lance tests.
Concerning the PORV/PORV block valves, the Dis-trict has done analysis which shows these valves are not re-quired for ".
the safe shutdown of the plant, nor in mitigating the consequences of an accident.", as required by Section XI IWA as a determining factor for inclusion in the ISI/IST program..The District believes that the NRC's order letter of April 20, 1981 and the Technical Evaluation Report prepared for the Commission by the Franklin Research Insti-tute adequately justify the exclusion of the 8 SI valves listed in the current review letter as needing inclusion in Table 2-9 of the District's Technical Specifications from both the ISI program and the Technical Specifications.
l
CHANGES TO THE OMAHA PUBLIC POWER DISTRICT EXEMPTION REQUESTS OF JULY 7, 1983 (LIC-83-161)
Valve Exceptions:
HCV-746A This valve cannot be leak tested in the (not in July direction of its design function in ac-submittal) cordance with IWV-3420 due to system con-figuration.
The intent of Subsection IWV to verify the leak rate is met, since test-ing in the direction opposite to the de-sign function will result in a greater leakage than would be experienced in the preferred direction.
LCV-lCl-1, 2 Removed from new program plan, but on July list.
AC-101, 4 & 7 The check valves shall be tested to ensure (not in July they open during normal component cooling submittal) water pump cycling.
RW-115, 17, These check valves shall be tested to en-121, 25-sure they open during normal raw water. pump (not in July cycling.
submittal)
FW-161, 162 These check valves are normally open during (not in July operation and to cycle these valves closed submittal) would result in a loss of normal feedwater to the steam generators.
This would re-sult in a steam generator water level drop and a possible reactor trip.
These valves shall be exercise tested each cold shut-down or refueling outage.
In the case where more than one cold shutdown occurs during a three-month period of time, the valves shall only be exercise tested once-during that three-month period.
Since failure of these valves to function in the back flow direction would not interfere with the plant's ability to shutdown or mitigate the consequences of an accident, these valves shall only be tested in a for-ward flow direction.
FW-163, 1 o4 These check valves open for auxiliary feed-(not in July water flow to the steam generators.
Cycling submittal) these valves during operation would result in cold water injection to a portion of the steam generators normally at operating
=
, temperatures.
This would cause abnormal stresses on the steam generators.
These valves shall be exercise tested each cold shutdown or. refueling outage.
In the case where more than one cold shutdown or combi-nation RO and CS cccurs within a three-month period, the. valves need only be. exer-cised once during the three-month period.
Since failure of these valves to function in a back flow direction would not inter-fere with the-plant's ability to shutdown or mitigate the consequences of an ac-cident, these valves shall only be tested in the forward flow direction.
Under Class 1 Weld Exams:
T B9.10-B9.40:
The primary piping is fabricated using (not in July centrifugally cast stainless steel pipe submittal) and cast stainless steel elbows.
Ex-perience has shown that these materials and welds are not always amendable to UT examination.
Radiographic techniques have been developed to substantially overcome this problem.
Volumetric examination will be performed to the extent practicall and according to the schedule designated in the examination plan.
Should other specialized ultrasonic examination techni-ques which are more effective become practical, they will be incorporated into the examination plan.
B12.10:
(There was a B12.10 exception submitted, but the exception written by our program plan vendor is worded differently and more specifically addresses the issue than the preliminary exemption list does.)
There is currently only one technique available to volumetrically examine pump casing welds-i.e.,
the Miniature Linear i
Accelerator (MINAC).
Because of results i
obtained to date during MINAC examinations E
at other PWR's, economic considerations of L
pump disassembly and the high radiation exposures involved, the District's posi-tion is that a volumetric examination of the pump casing welds will be considered L
only when the pump is disassembled for i
maintenance.
J. -
4
.... Under Pump Testing:
There is only one exemption not included in the July sub-mittal.
It applies to pumps SI-1A and B (Low Pressure Safety Injection' Pumps), SI-2A, B,
and C (High Pressure Safety Injection Pumps), SI-3A, B,
and C (Containment Spray Pumps), and pumps'CH-4A and B (Boric Acid Pumps).
The exemption reads:
Exceptions:
IWP-3100 Flow Measuremont Basis:
Original plant design did not include flow measurement for these pumps.
These pumps are in fixed resistance systems.
The inservice testing of differential pressure across the pumps under a minimum recirculation flow condi-tion (and thus near shutoff head) is deemed ade-quate to allow determination of pump function-ality and/or degradation.
i i
l I
l l
l l
l 1
f l