ML20117M825
| ML20117M825 | |
| Person / Time | |
|---|---|
| Site: | 05000000, LaSalle |
| Issue date: | 11/29/1983 |
| From: | Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20114G054 | List:
|
| References | |
| FOIA-84-616 NUDOCS 8505170227 | |
| Download: ML20117M825 (4) | |
Text
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o NOV 2 01983.
MEMORANDUM FOR:
D. G.~Eisenhut, Director, Division of Licensing, NRR FROM:
R. L. Spessard, Director, Division of Engineering
SUBJECT:
-REACTOR FEEDWATER CHECK VALVE SEAT SEALS - LASALLE COUNTY STATION Telephone discussions were conducted between members _of our staffs on November 22 and 23, 1983, regarding recent reactor feedwater check valve seal failures for reasons other than material qualification at LaSalle County Unit 1
- and Unit 2 and the November 17, 1983 request by Commonwealth Edison Company to NRR for a Technical. Specification change relating to the inboard feedwater l check valves at LaSalle County Unit 1.
The request was submitted by the flicensee. due to the. licensee's inability to provide in the near-term full documentation demonstrating qualification of the soft seals for the seats of these valves. We believe that either the requested Technical Specification change is necessary for the seals in question to be exempted from the require-ments of 10 CFR 50 Appendix J or justification for interim operation with the
- seals be provided.._The basis -for our view is that we can not conclude that the: valves will continue to meet the operability requirements of the Technical Specifications in the absence of fully qualified seals unless the seals have been' demonstrated to be acceptable for interim operation. We believe-that the inherent assumption in barrier testing prescribed by the Technical
-Specifications to determine component operability is that the barrier is
. capable by design of surviving the environment associated with the design basis accident for which the barrier is required.
-We understand that NRR intends to deny the licensee's request on the grounds
~
that the request is not necessary provided that (1) the valves can meet the leakage limits of Appendix J to 10 CFR Part 50 as reflected in the Technical Specifications and (2) sufficient justification can be provided by the licensee for interim operation.
. e support your views and recommend that the Justification for Interim W~
~
Operation (JIO) be applied to composition seal material used in valve seats, packing, etc., where such seal material provides the containment or primary system boundary. Further, we suggest that such a JIO be conditioned with a specific requirement that Commonwealth Edison Company conduct a review of all safety-related applications of seals and establish a program to qualify any seal-material presently in use in safety-related applications. Also, we believe that the: lack of documentation of the qualification on the valve seal material is not unique to Commonwealth Edison Company's Quality Assurance
-Program. Therefore, similar actions should be considered for all licensees.
g51g7840914 BARFIEL84-616 PDR i
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D. G. Eisenhut 2
NOV 2 9 G83 In view of the generic aspects of this seal material qualification concern and the minimal safety consequences associated with failure of the inboard feedwater check valve seals, we believe that interim operation of both Units 1 and 2 at LaSalle County _can be supported on the basis of actions specified in the attached Confirmatory Action. Letter. With your concurrence this Confirmatory Action Letter.was issued immediately, while your office pursues
'the requested exemptions from regulatory requirements.
We intend to address the generic aspects of the seal material qualification
~
concern in.a separate memorandum to the staff.
If you have any questions regarding this' matter, please contact J. F. Streeter (FTS 388-5541) or D. R. Hunter (FTS 388-5555) of my staff.
Original Signed by R. L. spcsscrd" R. L. Spessard, Director Division of Engineering
Attachment:
Confirmatory Action Letter to Commonwealth Edison
' Company cc:
R. Wessman, NRR A. Bournia, LPM, LaSalle W. Guldemond, SRI, LaSalle J. Partlow, IE E. Jordan, IE RIIJ RIII RIL R
MSG QSteeter def Spes sard iY Walker /1d nter 11/25/83 lihq/t3 lI!
p l_
^ /) WQ. f, (( f.- '*^ ": pe arcq UNITED STATES _ V ' y* 5 NUCLEAR REGULATORY COMMISSION 5, j ( REGloN lli - I, E 799 ROOSEVELT RO AD e CLEN ELLYN. ILLINOIS 60137 %..a f NOV 2 9 E63 m MEMORANDUM FOR: D. G. Eisenhut, Director, Division of Licensing, NRR FROM: .R. L. Spessard, Director, Division of Engineering
SUBJECT:
REACTOR FEEDWATER CHECK VALVE SEAT SEALS - LASALLE COUh"IT STATION Telephone discussions were conducted between members of our staffs on November 22 and 23, 1983, regarding recent reactor feedwater check valve seal failures for reasons other than material qualification at LaSalle County Unit I and Unit:2 and.the November 17 1983 request by Commonwealth Edison Company to NRR for a Technical Specification change relating to the inboard feedwater check valves at LaSalle County Unit 1. The request was submitted by the licensee;due to the licensee's inability to-provide in the near-term full -documentation demonstrating. qualification of the soft seals for the seats of these valves. We believe that either the requested Technical Specification change is necessary for the seals. in question' to be exempted from the require-ments 'of 10 CIT 50 Appendix J 'or justification for interim operation with the seals be provided. The basis for our view is that we can not conclude that the valves will' continue to meet the operability requirements of the Technidal Specifications in the absence 1of fully qualified seals unless the. seals have 'been demonstrated to be acceptable for interim operation. We believe that the. inherent-assumption in barrier testing. prescribed by the Technical ~}'g _;[ Specifications to determine. component operability is that the barrier is capable by design of surviving the environment associated with the design
- s p; c;.
basis accident for which the barrier is required. kge.- r} ' We understand that NRR intends to deny the licensee's request on the grounds yygg, ) that the request is not necessary provided that (1) the valves can meet the leakage limits of Appendix J to 10 CFR Part 50 as reflected in the Technicall o i.... r-Specifications and (2) sufficient justification can be provided by the licensee for interim operation. We support your views.and recommend that the Justification for Interim -Operation (J10) be applied to composition seal material used in' valve seats, packing, etc., where such seal material provides the containment or primary system boundary. Further, we suggest that such a JIO be conditioned with a specific. requirement.that Commonwealth Edison Company conduct a review of all safety-related applications of seals and establish a program to qualify any
- seal = material presently in use in safety-related applications. Also, we
-believe that the lack of documentation of the qualification on the valve seal material is not unique to Commonwealth Edison Company's Quality Assurance ~- Program. Therefore, similar actions should be considered for all licensees. l 1 4 e k L e r -.... - -.. - - - -...., -,.., -,.s-- r----,.----.------,y----.w --,,er- --~we-'.-- ---e-
a . s-.., ,d' .e 1 D. G. Eisenhut 2 NOV 2 9 G33 In view of the generic aspects of this seal material qualification concern and the minimal safety consequences associated with failure of the inboard feedwater check valve seals, we believe that interim operation of both Units 1 and 2 at LaSalle County can be supported on the basis of actions specified in the attached Confirmatory Action Letter. With your concurrence this Confirmatory Action Letter was issued immediately, while your office pursues the requested exemptions from regulatory requirements. We intend to address the generic aspects of the seal material qualification concern in a separate memorandum to the staff. If you have any questions regarding this matter, please contact J. F. Streeter (FTS 388-5541) or D. R. Hunter (FTS 388-5555) of my staff. s. R. L. Spessa d, Director Division of Engineering i
Attachment:
Confirmatory Action Letter to Commonwealth Edison Company cc: R.Wessman, NRR A. Bournia, LPM, LaSalle W. Guldemond, SRI, LaSalle J. Partlow, IE
- n. /1,.
E. Jordan, IE 7 tE % n:s u Wk t pu -h b e tw deal. h a g i E.: 7 b l,l d d hn w g ps.r &rwN.\\lA -n k$ 2e.4.,p i. b l -,}}