ML20118B747

Forwards Revised Response to GL 90-06, Resolution of Generic Issue 70, 'Power-Operated Relief Valve & Block Valve Realiability,' & Generic Issue 94, 'Addl Low-Temp Overpressure Protection for Light-Water Reactors.'

ML20118B747
Person / Time
Site:	Wolf Creek
Issue date:	10/02/1992
From:	Withers B WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
REF-GTECI-070, REF-GTECI-094, REF-GTECI-NI, TASK-070, TASK-094, TASK-70, TASK-94, TASK-OR GL-90-06, GL-90-6, WM-92-0158, WM-92-158, NUDOCS 9210070117
Download: ML20118B747 (6)

Text

._ _- _ _ _ _ _ . _ _ . _ _ _ _ . _ _

i

- s W8LF CREEK ' NUCLEAR OPERATING CORPORATION l

1 nart o w.ms e, ..seni .no October 2, 1?92 cn ci i mute o% c, i WM 92-0158 U. S. Nuclear Regulatory Cour.nission  ;

ATTH: Document Control Desk

• Mail Station F1-137 ,

~

Washington, D. C. 20$$5 References 1) Letter dated June 25, 1990 irom J. C. Partlow, NRC to all Pressurized Water Reactor Licensees and '

construction Permit iloiders (Ceneric Letter 90-06) *

2) Letter ET 90-0190 dated December 21, 1990 from F. T. Rhodes WCNOC to NRC

3) Letter ET 91-0175 dated May 14, 1991 from F. T. Rhodes WCNOC to NRC

4) Letter dated July 30, 1992 from W. D. Reckley, NRC ,

to B. D. Withers, WCHOC

Subject:

Docket No. 50-482: Revised Response to Generic Letter '

90-06, Resolution of Generic Issue 70, ' Power-Operated '

Relief Valve and Block Valve Reliability,' and Generic Issue 94, ' Additional Low-Temperature Overpressure Protection for Light-Water Reactors' Gentlemen:

This letter provides a revised response to Generic Letter 90-06 Resolution of Generic Issue 70, " Power-Operated Relief Valve and Block Valve Reliability,' and Generic Issue 94, ' Additional Low-Temperature Overpressure ,

Protection for Light-Water Reactors,' This revision _is being made to address .

specific concerns that the staf f - had with Wolf ~ Creek - Nuclear Operating Corporation's (WCNOC) response to requested action 2 which requires the stroke testing of PORVs during Mode 3 (Hot Standby) or Mode 4 (Hot Shutdown) and in all cases prior to establishing conditions where the PORVs are used for low-temperature overpressure protection.

The attachment provides WCNOC's plans relating to the NRC requested actions; i

-concerning PORVs and block valves and to low-temperature overpressure protection. This response is id ntical to the original _ submittal with the exception of the response to requested action 2 which was revised to comply with the-staff's position.

l h({} I i

' B x 411/ Burhngt n. KS 66839 / Phone:(316) 364-6831' 9210070117 921002 PDR ADOCK 05000482 - An Equa ouxxtun o Ems *, u r scytr p P, ppa _

/  :

l

.l

. . . -.. ...._ . . - - . . - . . . .-. . . .---- . . - _ - - - - . . - - .. -. - - . ~ - . ~ - _ . . - - . - - .

WM 92 0158  !

Page 2 of 2 If you have any questions concerning this matter, please contact me or Mr . Kevin J. Moles of tny staf f .

Very truly yours, f

N Bart D. Withers President nd Chief Executive officer BDW/jta Attachment cci A. T. Howell (NRC), w/a J. l.. Milhoan (11RC), w/a G. A. Pick (11RC), w/a V. D. Reckley (NRC), w/a t

v~w Ne ' N 'P"" * ' ""

i l

STATE OF KANSAS }

) SS COUNTY OF C0FFKY )

l I

Bart D. Withers, of lawful age, being first duly sworn upon oath says that he is President and Ohlef Executive Officer of Wolf Creek th clear Operating Corporations that he has read the foregoing document and knows the content thereof that he has executed that same for and on behalf of said Corporation with full power and authority to do sol and that the facts therein stated are true and correct to the best of his knowledge, information and belfef.

By /J ^W Bart'D. Withers President and Chief Executive Officer SUBSCRIBED and sworn to before me this 2 day of /dI , 1992.

e

/

g *. -

_,l]? d b' ~ '

t / EL L lhe ~

}q ' l 4

^ .v725}oj Notary rudlic y

Expiration Date '!

3

,,,...e'

Attachment to VM 92-0158 Page 1 of 3 RrVISED RESPONSE TO GENERIC LETTER 90-06 REQUESTED ACTION:

1. Include PORVs and block valves within the scope of an operational quality assurance program that is in compliance with 10 CFR Part 50. Appendix B.

This Program should include the fallowing elements:

a. The addit ion 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 recommendations or guidelines and is implemented by trained 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), it is the intent of this generic letter that these items may be procured in accordance with the original construction codes and standards.

RESPONSE

1.a. The PORVs and block valves are safety-related as described in Sections 3.11(B) and 5.4 of the Updated Safety Analysis Report and are included on the Wolf Creek Generating Station (WCGS) Q-list. The WCGS Q-list provides a listing of safety-related components.

1.b. Pre"entative maintenance on the PORVs and block valves is based on the ma.afacturer's recommendations and scheduled by the VCGS preventative -

maintenance program.

1.c. Since the PORVs and block valves are safety-related, replacement parts and spares are procured to the aplropriate technical and quality requirements for the procurement to safety-related items in accordance with procedure EGP-1250, ' Requisition & Procurement Process."

REQUESTED ACTION:

2. Include PORVs, valves in PORV control air systems, and block valves within the scope of a program covered by Subsection IVV, ' Inservice Testing of Valves in Nuclear Power Plants ," of Section XI of the ASME Boiler and Pressure Vessel Code. Stroke testing of PORVs should only be performed during Mode 3 (HOT STMDBY) or Mode 4 (110T SilUTDOWN) and in all cases prior to establishing i onditions where the PORVs are used for lou-temperature overpressure protection. Stroke testing of the PORVs should not be performed during pow n operation. Additionally, the PORV block valves should be included in the licensee's expanded MOV test program discussed in NRC Generic Letter 89-10, ' Safety-Related Motor Operated Valve Testing and Surveillance.' dated June 28, 1989.

At tachment t o WM 92-0158 Page 2 of 3 RESP 0NSE:

i The PORVs and block valves are included in the NRC approved WCGS Inservice Testing (IST) program, procedure GEN 00-006, " Hot Standby to Cold Shutdown' requires that the PORVs are full stroke tested in accordance with

]

surveillance test STS BB-204, 'RCS loservice Valve Test' prior to couldown below 368*F. This Surveillance Test would, for VCNOC, be conducted during Mode 3 operation, consistent with the staff's position to ensure PORV operability for purposes of low-temperature overpressure protection. Once in cold shutdown, the :,e valves will be retested in accordance with inservice 2

testing requirements which will ensure that they are retested prior to being needed after a prolonged outage or following maintenance conducted on the PORVs. The PORV block valves are stroke tested quarterly in accordance with Technical Specification Surveillance Requirement 4.4.4.2. Adu tionally, the PORV block valves are contained in the Generic Letter 89-10 Motor operated Valve Test Program. The test pr ogram for these valves is administered by procedure ADM 08-227, 'Limitorque Valve Program.'

REQUESTED ACTION:

3. For operatin6 PWR plants, modify the limiting conditions of operation of PORVs and block valves in the technical specifications for Modes 1, 2, and 3 to incorporate the position adopted by the staff in recent licensing actions.

Attachment A-1 through A-3 are provided f or guidance. The staff recognizes that some recently licensed PWR plant s already have technical specifications in accordance with the staff position. Such plants are already in compliance with this position and need merely state that in their response. These recent technical specifications require that plants that run with the block valves closed (e.g., due to leaking PORVs) maintain electrical power to the demand. Additionally, plant. operation in Modes 1, 2, and 3 with PORVs and block valves inoperable for reasons other than seat leakage is n e permitted for periods of more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

Revise current technical specifications for overpressure ptotection to reduce the allowable outage time for a single channel from 7 days t. 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the plant is operating in Modes 5 or 6 (see attachment B-1 to the Generic Letter).

RESPONSE

WCNOC paracipated with six other utilities to develop a connon approach to Generic Letter 90-06. The plants involved in this effort. are: Callaway, Vogtle, Cammanche Peak, Millstone 3 , Seabrook, Byron, Braidwood, and Wolf Creek. This group was formed due to the lack of specific ?,uidance and .- a-sample- technical specification for the . use of - either - the PORVs or the residual heat removal (RHR) suction relief valves. . A joint effort is possible due to the similarity or plant type' tv.d technical specifications.

All the plants are Westinghouse pressurized w.c er reactors which utilize the PORVs and RHR suction relief valves for low-temperature overpressure protection.

J l~

__ e . , _ _ , - -_..._ ---_- - -. . , , - , . _ - - - . - - , _ . _ . ,

. Attachment. to WM 92-0158 Page 3 of 3 At t a clunent A-1 to the generic letter proposes modified standard technical specifications for Combustion Engineering and Westinghouse plants with two PORVs. Wolf Creek tiuclear Operating Corporation (WCtJOC) intends t o submit. a license amendment request to Technical Specif1 cation 3/4.4.4 which follows-the staff positions with plant specific alternatives.

Enclosure E of the r,eneric letter was reviewed by the group and a proposed technical specification was developed that reflects the use of either the PORVs or the RilR suction relief valves. The proposed technical specification will require that at least two overpressure protection devices must be operable. This is . 2 PORVs or 2 R11R suction relief valves or 1 PORV and 1 Rl!R suction relief valve must be operabic when cold overpressure protection is required. Additionally, the revised specification 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 overpressure protection device is available in Mode 5 or 6.

WClioC intends to submit a supplement to the license amendment request to Technical Specification 3/4.4.4, Relief Valver and 3.4.9.3, Overpressure Protection System, to reflect the changes made by this reviaed response to Question 2. This supplement will be submitted by April 30, 1993.

i 4

l 5

p