ML20128C365
| ML20128C365 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 11/24/1992 |
| From: | Alexion T, Bevan R Office of Nuclear Reactor Regulation |
| To: | Yelverton J ENTERGY OPERATIONS, INC. |
| 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, TAC-M77326, TAC-M77327, NUDOCS 9212040367 | |
| Download: ML20128C365 (5) | |
Text
_ - - _ _ _ _ _ _ _.-.
vu *eog%
9 UNIT E D S1 ATES
/'
NUCLE AR REGULATORY COMMISSION 3g
{
j w AsmNGTON, D. C. 70m
\\
s November 24, 1992 Dv kot. Nos. 50-313 and W-366 Mr. Jerry W. Yelverton Vice dresident, Operations Entergy Operations, Inc.
Route
'4, Box 137G Russe aille, Arkansas 72801
Dear Mr. Yelverton:
SUBJECT:
staff REVIEW OF GENERIC LETTER 90-06, " RESOLUTION Of GENERIC ISSUE 70, ' POWER-0PERATED RELIEF VALVE AND BLOCK VALVE RELIABILITY,' AND GENERIC ISSU: 94, 'ADDil10NAL LOW-TEMPERATURE OVERPRESSURE PRGTECTION FOR LIGHT-WATER REACTORS,' PURSUANT TO 10 CFR 50.54(f),"
ARKANSAS NUCLEAR ONE, UNITS 1 AND 2 (AN9-l&2) (TAC N05. F'7326 AND M77327)
By letters dated December 21, 1990 (separate responses for ANO-1 and ANO-2),
and June 18, 1991 (response for ANO-2), Entergy Operations, Inc. (the licensee) responded to Generic Letter (GL) 90-06 for ANO-l&2.
The GL represented toe technical resolution of two generic issues (Gis) and included plant backfits which were cost-justified ufety enhancements.
GI-70 included upgrades in quality requirements, inservice testing (IST) requirements, and modified technical specifications for all pressurized water reactor facilities that incorporate power-operated relief valves (PORVs) and block valves in their design.
The intended purpose was to enhance the overall reliability of the PORVs and block valves so that they could better perform the safety unctions identified in the GL. GI-94 included modified technical specificaticns for all Westinghouse and Combustion Engineering facilities to reduce the allowed outage time for an inoperable low-temperature overpressure protection (LTOP) channel and thus reduce the probability of over-pressurization events during shutdown conditions.
The staff has reviewed your submittals related to GI-70 and finds that you have not adequately responded to selected portions of the GL.
It is the staff's positicn that a regulatory analysis has been performed in accordance with 10 CFR 50.109(a)(3) and 50.109(c) which justifies the backfit.
Therefore, absent any information that d?monstrates that your facility is not bounded by the regulatory analysis that accompanied the GL, you are requested to resubmit a response that is in keeping with the intent of the GL.
The staff position for the resolution of GI-70 required technical specification upgrades as presented in the GL.
Our review of your submittal indicates that you have declined the staff position.
Tne staff will not accept, without suf ficient justification, the position that the technical specification upgrades are unnecessary because the PORVs are not the primary h'
50006a b
9212040367 921124
?
- % p,[fd}f PDR ADOCK 05000313
- 3 g n P
PDH
. a Li t
Mr. Jerry W. Yelverton means of dealing with the three safety functions or other functions (i.e.,
feed and biced cooling) identified in the GL.
Some specific areas of concern in your submittals are as follows.
1he intent of GL 90-06 in regards to GI-70 was to improve the performance of power-operated relief valves (PORVs) and block valves when used for any safety f u nc t i or., including feed and bleed cooling, in your June 18, 1991, submittal for Unit 2, it was implied that valve 2CV4698-1 is used in conjunction with valve 2CV-4740-2 to provide an emergency core cooling systcm (ECCS) vent path for depressurization in the event of a small-break loss-of-coolant accident (LOCA) or a total loss of feedwater.
The staff concludes that these valves should be considered in your response to GL 90-06.
In the Unit I submittal, the basis for not relying upon the electromatic relief varve (ERV) to perform in a steam gencrator tube accident (SGTA) assumes the availability of offsite power.
The staff's analysis assumes loss of offsite power.
As discussed in NUREG-1316, most of the safety enhancement for the proposed backfit is derived from the increase in feed aad bleed capabilitj.
Therefore, for those facilities with two PORVs that can accomplish the three safety functions and the feed and bleed cooling without relying on the PORVs or their equivalents, the allowed outage time (A01) for an inoperable PORV (for reasons other than excrssive leakage) may be increased from the recommended 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days.
The staff position also required the 18-month PORV stroke test to be perlormed daring Mode 3 (HOT STANDBY) or Mode 4 (HOT 3HUTDOWN) and in all cases prior to establishing conditions where the PORVs are used for L10P.
Your submittal did not adequately meet this staff position.
The staff is net accepting Mode 5 (COLD SHUTDOWN) testing simply because it is allowed by the ASME Code or that the NRC-approved IST program includes Mode 5 for this particular test.
The requirement to perform stroke tests of the PORVs during Modes 3 or 4 is a new position for some licensees.
The basis for this position lies in the uncertainty introduced by stroke testing the PORVs at lesser system temperature conditions and then expecting them to perform adequately at operating system conditions, including feed and bleed situations.
If this recommendation is not adopted, a sound technical basis should be provided (e.g., that such testing cannot be performed without significant system modifications or that the intent of such testing is accomplished by some other means).
We note that one licensee has proposed the option to bench test the PORVs.
This would be acceptable, provided the tests are pe, formed at conditions simulating Mode 3 or 4 conditions or greater and provided the proper reinstallation of the PORVs and controls is verified.
In another case, the staff accepted an argument from a licensee that the physical distance between the PCRV and the pressurizer maintained the same temperature at tre P0kV in Modes 3, 4, or 5 such that there is no difference from the valve's
R 0-e Mr. Jerry d. Yelverten.
perspective of testing in differp9t modes, in this case the facility had an air-operated PORV and was able to perform the PORV stroke test with the block -
valve closed such that the PORV would be primarily influenced by the ambient room conditions.
Additionally, the GL required that PORVs be stroke tested in all cases prior to establishing conditions where the PORVs are used for LTOP.
This could be interpreted to mean that PORVs should be stroke tested during every shutdown and again during every startup. However, the inclusion of the PORVs in the IST program requires the valves oc tested no more frequently than every three months (unless valve maintenance is performed) to demonstrate operability, in summary, the staff maintains its position that the PORVs should be stroke tested during Modes 3 or 4 in order to verify the capability to function in an environment more representative of operating conditions.
In your revised response, discuss how PORV stroke tqsting provides assurance that the PORVs will perform all necessary safety functions adequately at the required system operating conditions, including feed and blead cooling.
You are requested to respond within 60 days following receipt of this letter.
If you would like to further discuss these issues prior to your resubmittal, please feel free to contact me.
The information requested by this letter is within the scope of the overall burden estimated in GL 90405 for the resolution of GI-70 and GI-94, which was a maximum of 320 person-hours pei licensee response.
This request is covered by Office of Management and Budget clearance Number 3150-0011, which expires May 31, 1994.
Sincerely, ORIGINAL SIGliED BY:
Thomas W. Alexion, Project Manager Project Directorate IV-1 Division of Reactor Projects - lil/IV/V Office of Nuclear Reactor Regulation-
-ORIGINAL SIGNED BY:
Roby B. Bevan, Project Director Project Directorate !V-1 Yvisio., of Reactor Projects - Il!/IV/V 0:fice of Nucleac Reactor Regula'. ion cc:
See next page DISTRIQy1103:
Docket = File NRC & Local PDRs PD4-1 Reading R. Twigg OGC J. Roe M. Virgilio J. Larkins R. Young P. Noonan PD4-1 Plant File T. Alexion R. Jones R. Bevan ACRS (10) (P-315)
A. B. Beach J. Norberg
- See previous concurrence
@ 81 thi OfC LA:l/h PE:PO4-l*
PM:PD4--I BC:SRXB*
BC:EMEB*
MDpi I
NAME PNooNn RTwigg:pk TAlexfobRJones JNorberg ILIrYins DATE \\\\/b92 10/28/92 ll $9/92 11/16/92
'11/19/92
// 2f/92 i
/
OfflCIAL RECORD COPY Document Name: AR77326.Itr
Mr. Jerry W. Yelverton perspective of testing in differen' modes.
In this case the facility had an air-operated PORV and was able to perform the PORV stroke test with the block i
valve closed such that the PORV would be primarily influenced by the ambient room conditions.
Additionally, the GL required that PORVs be stroke tested in all cases prior to establishing conditions where the PORVs are used for LTOP. This could be interpreted to mean that PORVs should be stroke tested during every shu'.down and again during every startup.
However, the inclusion cf the PORVs in the IST 3rogram requires the valves be tested no more frequently than every three montas (unless valve maintenance is performed) to demonstrate operability, in summary, the staff maintains its position that the PORVs should be stroke tested during Modes 3 or 4 in order to verify the capability to function in an environment more representative of operating conditions.
In your revised response, discu' how PORV stroke testing provides assurance that the PORVs will perform ali necessary safety functions adequately at the required system operating conditions, including feed and bleed cooling.
You are requested to respond within 60 days following receipt of this letter.
If you would like to further discuss these issues prior to your resubmittal, please feel free to contact me.
The information requested by this letter is within the scope of the overall burden estimated in GL 90-06-for the resolution of GI-70 and GI-94, which was a maximum of 120 person-hours per licensee response.
This request is covered by Office of Managerr.ent and Budget Clearance Number 3150-0011, which expires May 34, 1994.
Sincerely, M
'l rh
}Mdd)
AJ A
Thomas W. Alexion, Project Ma' nager Project Directorate IV-1 Division of Reactor Projects - III/IV/V-Office of Nuclear Reactor Regulation UW N
y l
Roby_P. Bev
, Project Director j
Project Directorate IV-1 Division of Reactor Projects - III/IV/V j
Office of Nuclear Reactor Regulation cc:
See next page L
o I
Hr. Jerry W. Yelverton Entergy Operations, Inc.
Arkansas Nuclear One, Unit 2 cc:
Mr. Donald C. Hintz, President Mr. John R. McGaha and Chief Operating Officer Vice President, Operations Support Entergy Operations, Inc.
Entergy Doerations, Inc.
P
- 0. Box 31995 P. O Box 31995 Jackson, Mississippi 39286 Jackson, Mississippi 39286 Mr. Robe-t B. McGehee Mr. R. A. Fenech Wise, Carter, Child & Caraway General Manager, Plant Operations P. O. Box 651 Entergy Operations, Inc.
Jat.kson, Mississippi 39205 Route 3 Gox 137G Russellville, Arkansas 72801 Mr. Charles B. Brinkman, Manager Washington Nuclear Operations He. Nicholas S. Reynolds ABB Combustion Engineering Nuclear Power Winston & Strawn 12300 Twinbronk Parkway, Suite 330 1400 L Street, N.W.
Rockville, Maryland 20852 Washington, D.C.
20005-3502 Mr. James J. Fisicaro Mr. Robert B. Borsum Director, Licensing Licensing Representativ9 Entergy Operations, Inc.
B&W Nuclear Technologies Route 3, Box 137G 1700 Rockville Pike, Suite 525 Russellville, Arkansas 72801 Rockville, Maryland 20852 Admiral Kinnaird R. McKee, USN (Ret)
Senior Resident inspector 214 South Morris Street U.S. Nuclear Regulatory Commission Oxford, Maryland 21654 1 Nuclear Plant Road Russellville, Arkansas 72801 Regional Administrator, Region IV U.S. Nuclear Regulatnry Commission 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76011 Honorable Joe W. Phillips County Judge of Pope County Pope County Courthouse Russellville, Arkansas 72801 lis. Greta Dieus, Director Division of Radiation Control and Emergency Management Arkansas Department of Health 4815 West Markt am Street Little Rock, Arkansas 72205-3867
_