ML20107G963
| ML20107G963 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 02/21/1985 |
| From: | Woolever E DUQUESNE LIGHT CO. |
| To: | Knighton G Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8502270006 | |
| Download: ML20107G963 (8) | |
Text
[
'Af Duquesne Lidit 23Cg0f,2
)93 60 Nuclear Construction Division elecon W2) 787-2629 Robinson Plaza, Building 2. Suite 210 Pittsburgh, PA 15205 February 21, 1985 United States Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Mr. George W. Knighton, Chief Licensing Branch 3 Of fice of Nuclear Reactor Regulation
SUBJECT:
Beaver Valley Power Station - Unit No. 2 Do cke t No. 50-412 Meeting on Pressure Isolation Valve Leak Testing
REFERENCE:
2ASR-01654, dated January 25, 1985 Gentlemen:
For your information this le t t e r fo rward s Duquesne Light Company's (DLC) s umma ry of the meeting held on January 17, 1985, in Bethesda, MA, to discuss Reactor Coolant System pressure isolation valve leak testing criteria.
It was indicated at that time that the NRC would res pond on the subject of the Technical Specification Basis for BVPS-2 being similar to BVPS-1 by January 25, 1985.
DLC requests a response on this very important s ubject as soon as possible.
DUQUESNE LIGHT COMPANY I
By.
E. J. Woolever Vice President JJS/wjs Attachments cc:
Mr. B. K. Singh, Project Manager (w/a)
Mr. G. Walton, NRC Resident Inspector (w/a)
SUBSCRIBED AND SWORN TO BEFORE ME THIS 4/cd DAY OF Id/>_ttua
- 1985, 2
D 0
412 A--
4W PDR Notary Public
\\
A AMWATL4HDfEjity,?.NOMMY/PMC
@O ff0dH5NUTbWNtHfp,' All'EGHENVicbMy i
IW @ MhlttidN:SXptRtK 06 Tot V m * -
hnitedStatesNuclesrRegulstoryCommission
~'
Mr. Gsorge W. Knighton, Chief Page 2 COMMONWEALTH OF PENNSYLVANIA
)
)
SS:
COUNTY OF ALLEGHENY
)
On this J/cd day of
/ 9f[ ', befo re me, a Notary Public in and fo r said Commonwealth a[ County, pe rsonally appeared E.
J. Woolever, who being duly sworn, deposed and said that (1) he is Vice President of Duquesne Light, (2) he is duly authorized to execute and file the foregoing Submittal on behalf of said Company, and (3) the statements set forth in the Submittal are true and correct to the best of his knowledge, n
s.d Ab Notary Public
. ANITA ELAINE REITER, NOTARY PUDLIC ROBINSON TOWNSHIP, ALLEGHENY COUNTY MY COMMISSION EXPlRES OCTOBER 20,19H i
i i
Y
ATTACHMENT 1 Meeting on Pressure Isolation Valve Leak Testing The meeting was held between DLC (NCD Engineering, RAD, and SUG) and the NRC (NRR) to discuss the RCS pressure isolation valve le ak tes t ing criteria for BVPS-2.
DLC had previously submitted a response to NRC Mechani-c al Branch Que s t ion 210.40 (draft SER open item 4 3) followed by telecons between NRR (Owen Rothberg) and DLC (F. Lin).
These telecons, although informational interchange s primarily, indicated that a lack of understanding existed between the DLC position and NRC position on RCS pressure isolation valve le ak testing (and categc y of valves for leak testing).
The meeting was at DLC's request.
DLC prepared the " Proposed Agenda" (See Attachment 3) to provide an organized manner for the discussion.
The first part was intended to provide the NRC with an opportunity to convey their position on RCS boundary valve testing, including the basis for their position. The second part was intended as a means for DLC to substantiate their position, where it dif fered with the NRC.
The results are as follows:
1.
NRC POSITION AND BASIS FOR THIS POSITION 1.
Mr. F. Cherny indicated that although leak testing of check valves (high-to-low pressure) at the RCS boundary, was intially the NRC concern (Event V LOCA, similar to BVPS-1 Tech Spec, utilizing Franklin Research Institute Study); af ter TMI any intersystem LOCA was the new NRC basis.
This, therefore, includes any high-to-low pressure regardless of whether it is ins ide or outside containment.
2.
The valves are considered as "Two Barriers", not two check valves.
This includes "normally closed" motor operated valves or "normally closed" solenoid valves if they are included in the "two barriers".
NOTE:
In detailed discussion it was es t abli shed by the
'C that the "Two Barriers" did not have to be:
a.
Adjacent (intervening valve can exist) b.
Both or either on the SC-1 side of the class break (one or both may be SC-2).
The valves will require a leak test at IGPM and are to be included in technical specifications.
NOTE: Other details applicable to 1GPM vs. 5GPM with trending was included in NRC discussion as follows:
a.
It is possible the RHS Barrier Valves (at RHS pump suc-tion, two interlocked per train) may be relaxed to SGPM maximum.
. b.
Recent in process NRC internal discussion could result in an approach based on valve size with le ss than 1GPM for smaller valves (leak rate based on 1/2 GPM allowable per inch of diameter) to a maximum of SGPM allowable leakage. Again, this has not been approved.
c.
The 1GPM criteria was stated as "in the Standard Tech Specs" and a change to criteria would be a Standard Tech Spec change.
d.
NUREG 0677 was also referenced as guidance.
e.
Containment isolation valves (which are included as "Two Barriers") are also to be cons ide red as IST Program c ategory A or A/C valves, requiring Leak Rate Testing
( A ppe ndix "J ", Type "C"
Leak Testing alone is not cons ide red adequate).
A copy of "The Safety Evaluation of Sequoyah 1 and 2 In s e rv ice Test (IST) Program for Pumps and Valves", with direct reference to paragraph 3.1.4 and 3.1.5 was provided by the NRC to DLC as speci-fic clarification of this point.
4.
DLC (R. Fedin and J. Syz Slow Ski) indicated that BVPS-2 had been informed by the NRC (G. W. Knighton) that the Tech Spec Basis for EVPS-2 is to be similar to BVPS-1.
This is directly applicable to the RCS Boundary Valves, as the Event V (high-to-low, outside con-tainment) with the Franklin Research Institute Report Guidelines were accepted for BVPS-1 Tech Specs and, therefore, should be acceptable for BVPS-2 Tech Spe c ap plica t ion.
No other basis /
criteria had been established, although Question 210.40 identifies this leak rate conce rn (a call was placed by Mr. Cherny to Mr.
Knighton during the discussion, with indication that this Tech Spec Basis subject would be resolved by NRC by January 25, 1985).
5.
The NRC indicat ed that ASME Section XI testing without Te ch Spe c Requirements is inadequate, even when the Leak Rate Criteria is the This position was based on the following:
same.
A.
No assurance that "un ac cep t able" le ak rate would result in repair prior to returning plant to service.
B.
Leak Rate Testing could (and may) be performed during decrease in RCS pressure, rather than increase in RCS pressure (ramp up) as intended by NRC.
C.
No assurance that valve position was established positively (by Leak Rate Means) after its last change of position.
NOTE:
1.)
The NRC (Mr. Cherny) indicated that there is no assurance that a valve will not be faulty (fully open) by " Position Test" alone.
A leakage test is
. the only ac ceptab le method to assure that inter-active sys tem LOCA (high-to-low pressure) will not occur between the RCS Boundary and lower pres sure system.
2.)
DLC questioned the basis for this pos it ion.
The NRC cited valve failures / faulty valves resulting in high-to-low pressure occurrences.
They also indicated the NRC (Mr. Tedesco) had initiated this basis for the pos i t ion following TMI and "others" (in NRC management) had maintained this position.
3.)
DLC again questioned the basis of this position, as it had not been identified in Licensing Require-ments by the NRC.
6.
DLC asked the NRC to cite the regulations fo r all of the above discussed " requirement s".
The NRC answer as that it (the regula-t ions) are covered, in part, by internal NRC memos and (guidance)
NUREC0677.
DLC pointed out that they do not have any of these
" internal" NRC documents.
Mr. Cherny indicated that the NRC is presently working on a revision to the S RP, but it has not been completed.
(However the NRC basis is essentially the St andard Technical Specifications.)
II.
DLC directed its specific agenda items to the NRC latest telecopy (B. K. Singh to Jim Syz Slow Ski), in which questions were asked by the NRC MEB Eng,ineer and pressure isolation valves (PIV's) were identified (From DLC System information furnished to the NRC earlier via 2NRC 184, 11/07/84.)-
1.
DLC indicated that RHS Valves
- MOV701A&B and *MOV720A&B are shown "normally open" as the A/E (SWEC) s t andard when valves have two modes of operation.
In addition Note 5 of the design flow diagram (RM-76A) indicates these valves as interlocked closed unt il decrease in RCS pressure below 425 psig.
It was also indicated that DLC operations (SUC) may show these valve closed if clarifica-tion is considered necessary by the operators. This was acceptable to the NRC.
2.
'Ihe valves identified as "PIV's we re not the Final PIV's", as the criteria is "Two Barriers" in high-to-low pressure.
It was mutually agr eed (See I.2., above) that this criteria take s precedence.
3.
The DLC position that MOV's are category "B" vs. NRC position that all PIV's are ASME XI c at ego ry A or A/C was not resolved (see I.S.C, Note 1 above).
l
r
~
. 4.
The Boundary between Class 1 and 2 piping in OM Figure 6-3, indi-cated as unclear by the NRC, was not resolved during the meeting.
5.
The 3/4" MOV's indicated on OM Figure 6-3 (Quantity 3) were not resolved as exempt from PIV s tatus.
DLC agreed with the NRC that RCS inventory was the basis for concern, not "Two Barriers".
The NRC (O. Rot hb erg) stated that 3/8" sizing was the NRC criteria related to him by NRC staf f (Mr. Lacharda).
However, he indicated that he would recheck this and implied that these 3/4" MOV's were not significant (no other utility submitted had included the 3/4" valves as P1V's).
6.
The NRC implied that Multiple Valve Testing (more than
'*rwo specif ic case Barriers") may be an ac ce pt ab le alternative on a basis.
tMweve r, the speci fic case and Leak Rate Testing wi11 require NRC review and approval.
III.
SUMMARY
1.
The NRC position on '%'o Barriers" applicable to Tech Specs is not consistent with previous NRC direction to make BVPS-2 tech spe cs similar to BVPS-1.
This !ssue will be addressed by the NRC by January 25, 1985 for BVPS-2.
2.
The vasis of Leak Rate Testing "Normally Closed" MOV's in lieu of acceptance through valve position (ASME XI, Category "B") does not appear to have a clear licensing basis.
3.
The definition of "Two Barriers" includes high-to-low pr es sure interactive systems for both inside containment and those penetrat-ing containment, thus exceeding basis (Event V) for BVPS-1 Tech Specs.
However, the '*rwo Barrier" Valves do not have to be ad j a-c e nt, nor must thev be SC-1.
One valve may be an MOV if no other "Two Barriers" are present.
4.
The Leak Rate Testing (Limiting Cond i t ion of Operation) is pre-sently considered by the NRC as 1GPM, although standard Tech Spec change is in process to provide some nodification applicable to valve size and SGPM maximum leakage.
5.
The NRC Basis for the " Req ui reme nt s" is the latest st andard tech-nical spe ci ficat ions (rev. 4).
This is inconsistent with an NRC letter which states that BVPS-2 Technical Specifications should be similar to BVPS-1.
In addi t ion, the NRC " Requirements" are not covered in the Federal Regulations or in the SRP.
o ATTACHMENT 2 Meeting on Pressure Isolation Valve Leak Testing Attendance List Name Location Title B. K. Singh NRC/NRR/DL/LB#3 Project Manager F..C. Cherny NRC/NRR/DE/MEB Section Leader 0.-Rothberg-NRC/NRR/DE/MEB Engineer E. Lantz-NRC/NRR/RSB Nuclear Engineer J. R. Houghton DLC/NCD/Eng.
Technical Consultant F. C. Lin DLC/NCD/Eng.
Project Engineer R. W. Fedin DLC/ RAD Sr. Project Engineer
-J. J. Szy Slow Ski DLC/ RAD Sr. Project Engineer V. Ruppert DLC/ Ops /SUG F. D. Schuster DLC/ Ops /SUG
<~
y ATTACHMENT 3 Meeting on Pressure Isolation Valve Leak Testing (MEB Question 210.40)
Proposed Agenda DATE:
January 17, 1985 TIME:
1:00 p.m.
LOCATION:
Air Rights Building, Room 5033, Bethesda, MD I.
Objective of Review Pertinent to SC-1/SC-2 Interface Valves II.
Discussion of Valve Testing for SC-1/SC-2 Interf ace including:
A.
Other Adjacent Valves B.
Applicability of ASME XI/10CFR50 Appendix "J" Testing C.
Limiting Conditions of Operation (Technical Specifications)