ML20147D628
| ML20147D628 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 01/14/1988 |
| From: | Corbin McNeil Public Service Enterprise Group |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NLR-N88003, NUDOCS 8801200238 | |
| Download: ML20147D628 (13) | |
Text
.
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Pudhc Service Electric and Gas i
Comp any j
Corbin A. McNeill, Jr.
Public Service Electnc and Gas Company P.O. Box 236,Hancocks Bridge, NJ 08038 609 339-4800 sena vce nnant -
January 14, 1988 l
l NLR-N88003 United States Nuclear Regulatory Commission Document Control Desk 1
i Washinoton, DC 20555 l
l Gentlemen:
ADDITIONAL INFORMATION INSERVICE TESTING PROGRAM, REVISION 1 HOPE CREEK GENERATING STATION l
DOCKET NO. 50-354 Public Service Electric and Gas Company (PSE&G) hereby transmits l
l additional information in support of the Inservice Testing (IST)
+
1 Procram, Revision 1, previously submitted in a letter from i
C. A. McNeill, Jr. dated September 21, 1987.
The attached j
information responds to the NRC Staff Evaluation of the t
referenced letter as detailed in the transmittal from l
W.
R. Butler (NRC) to C. A.
McNeill, Jr. dated December 7, 1987.
l 2
In summary, after further review, FSE&G agrees with the NRC l
evaluation for Relief Request Nos. V-08, V-12 and V-19 and will l
accordingly either comply with the requirements of Section XI of the 1983 Edition of the ASME Code through Summer 1983 Addenda, as
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applicable, or remove the subject valves from the IST Program in accordance with the review comments.
However, PSE&G requests the NRC to review for approval revised Relief Recuest Nos. V-02 and i
V-05 as well as Relief Request No. V-07 in licht of the additional information provided in the attached documentation.
The attached information also addresses the NRC comments contained in Paragraphs 3.1.1 and 3.2.1 of the referenced evaluation letter.
1 PSE&G requests a meetino with the NRC to discuss the additional i
information provided in this transmittal.
Should you have any cuestions or comments, do not hesitate to contact us.
i l
Sincerely, k5 y
s A_,,
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l Attachment'(11 paces) i j
8901200238 8B0114 l
i PDR ADOCK 05000354 t
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Document Control Desk 2
1/14/88 C
Mr.
G.
W. Rivenbark USNRC Licensing Project Manager Mr. R. W.
Borchardt USNRC Senior Resident Inspector Mr.
W. T.
Russell. Administrator USNRC Region I Mr.
D.
M. Scott, Chief Bureau of Nuclear Engineering Department of Environmental Protection 380 Scotch Road Trenton, NJ 08628
)
i
RELIEF REQUEST V FAST ACTING VALVES TEST REQUIREHENTS:
I WV-3 417( a) requires that if an increase in stroke time of 50% or more is observed for valves with full-stroke times of ten ( 10) seconds or less, the test frequency be increased to once each month until corrective action is taken.
BASIS FOR RELIEF REQUEST:
The valves listed below are equipped with fast-acting actuators which are typically designed to provide the valves with full-stroke operating times of 5 seconds or less.
Since instrumentation is not installed to provide the level of accuracy required, attempts to measure percentage changes in the stroke time of these valves would be subjective and prone to error.
In addition, this requirement exceeds the requirement of I WV-3 413( b) that the stroke time of all power operated valves for stroke times of 10 seconds or less be measured to the nearest second.
ALTERN ATE TESTING:
None.
Testing of these valves shall meet the requirement of I WV-3 413( b) that the full stroke operating time for valves with operating times of 5 seconds or less be measured to the nearest second.
Any observed abnormality of erratic action shall be investigated, i
STAFF EV A LU ATI ON:
The NRC staff has taken a position on fast acting valves which assigns a li mi t i ng stroke time of 2 seconds, requires corrective action if such a value is exceeded under test and applies the full Section XI requirements for valves with a full stroke time of greater than 2 seconds.
PSE&G RESPONSE:
PSE&G has reviewed the valves identified under both Relier Requests Hos. V-02 and V-05 and has concluded that for the majority of the identified valves, compliance with the above regulatory position can be achieved.
As discussed in r e vi s e d Relief Request No.
V-05 below, valves with maximum stroke times of 2 seconds or less can be exempted from the j
requirements of I WV-3 417( a).
Page i of 11
l With regard to the Containment Atmosphere Control System
( C ACS) valves which typically close in 2-1/ 2 to 5 seconds, adherrence to the full requirements of ASME Section XI, including the frequency criteria of I WV-3 417( a), can be l
achieved.
This conclusion is based upon the over-riding requirements of Technical Specification Table 3.6.3-1 which require the subject valves to be declared inoperable prior to exceeding the ASME 50% degradation requirement.
This rationale is based upon the pending issuance of the License Amendment associated with the qualification of the drywell and suppression chamber containment isolation valves.
Finally, compliance with the requirements of the referenced ASME code for the Primary Containment Instrument Gas System l
( PCIGS) valve is considered achievable since the baseline stroke time is on the order of 5 seconds and further stroke time degradation is not expected nor difficult to correct should such degradation occur.
However, a review of Title 10 of the Code of Federal i
Regulations, HUREG-0800 ( the Standard Review Plan) Section
- 3. 9. 6, NUREG-1048 (the HCGS Safety Evaluation Report)
Section 3.9.6 and the applicable sections of the ASME code has not identified the basis behind the 2 second limiting stroke time for fast acting valves.
Therefore, without a definitive regulatory criteria for applying such a requirement when testing the set of valves remaining from the original list, and in light of the difficulty encountered in complying with the criteria for a portion of the original list of valves. PSE&G requests the Staff to re-evaluate this revised relier request (i.e.
exemption from I WV-3 417( a) for the below listed valves with 5 second stroke t i me s ) in light of the additional information provided below.
j ADDITIONAL J USTIFICATION:
From the original list of valves contained in Relief Request No.
V-02, the valves listed below require multi-area, verbal interactions (i.e.
the use of personnel, locally at valves and in either the control room or other remote locations, communicating via radios, pages, etc...)
in order to stroke i
test the valves.
This requirement increases the potential for t i mi ng error due to coordination considerations when measuring stroke time.
Additionally, t i mi ng requires the use of a hand-held stopwatch and since the plant design does not support the use of in-line instrumentation, the level of accuracy needed to obtain stroke times which would support the adherence to the 50% degradation requirement is not possible.
Without the ability or capability to obtain highly accurate strike times and e li mi na t e human error factors, the Page 2 of 11
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t requirement to satisfy the afore-referenced ASME code for the revised listing of valves identified below becomes impractical and if imposed represents an undue burden.
In the case of manual t i mi ng, to require additional testing which may indeed not be necessary, as a result of measurement error rather than any actual valve strake time degradation, would burden station operation by rerdering valves needlessly inoperable ( either when perform.ng the test or as a result of the test) on a frequency r,reater than the norm.
For the case of in-line instrumentation, the efforts associated with design, installation and maintenance would result in hardship and unusual difficulties without a compensating increase in the level of safety or quality.
a Therefore, it can be concluded that the imposition of the requirements identified within this relief request represent an undue burden and granting of the above referenced relief request is in the public interest since the relier will not endanger life or property or the common defense and security of the public.
4 COMPONENTS:
The valves for which relief is requested are identified below by valve number and system:
l Safety and Turbine Auxiliaries Cooli no Syst em ( ST ACS) 1 l
)
1-EG-HV-2290 A ( V065) 1 -EG-HV-2395 A ( V231) i 1-EG-HV-2290B ( V068) 1 -EG-HV-2395B ( V235) 1 -EG-HV-2290C ( V064) 1 -EG-HV-2395C ( V233) 1-EG-HV-2290D ( V069) 1 -EG-HV-2395D ( V237) 1-EG-HV-2290E ( V071) 1 -EG-HV-2398 A ( V238)
)
1 -EG-HV-2290F ( V074) 1 -EG-HV-23988 ( V250) l 1 -EG-HV-2290G ( V070) 1 -EG-HV-2398C ( V24 4) j 1 -EG-HV-2290H ( V075) 1-EG-HV-2398D ( V256) j 1-EG-HV-2292A ( V072) 1 -EG-HV-239 8 E ( V2 41) 1 -EG-HV-2292 B ( V073) 1 -EG-HV-2398F ( V253) 3 1 -EG-HV-2302 A ( V104) 1 -EG-HV-2398G ( V2 47) 1 -EG-HV-2302B ( V106) 1 -EG-HV-2398 H ( V259) 1-EG-HV-2302C ( V107) 1 -EG-HV-2325C ( V14 2) 1 -EG-HV-2 302 D ( V108) 1 -EG-HV-232 5D ( V14 8) 1-EG-HV-2302E ( V109) 1 -EG-HV-232 5E ( V14 5) l 1 -EG-HV-2 302 F ( V10 5) 1 -EG-HV-2325F ( V147) 1 -EG-HV-2325 A ( Vi 44) 1 -EG-HV-2325G ( V14 3) j 1 -EG-HV-2 3 2 5 B ( V14 6) 1 -EG-HV-2325H ( V14 9) e l
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RELIEF REQUEST V-05 FAST ACTING SOLENOIDS / VALVES TEST REQUIREMENT:
I WV-3 417( a) requires that if an increase in stroke time of 50% or more is observed for valves with full-stroke times of ten ( 10) seconds or less, the test frequency be increased to once each month until corrective action is taken.
B ASIS FOR RELIEF REQUEST:
The valves listed below are equipped with f ast-acting actuators which are typically designed to provide the valves with full-stroke operating times of 2 Ipreviously 51 seconds or less.
Si nc e instrumentation is not installed to provide the level of accuracy required, attempts to measure percentage changes in the stroke time of these valves would be subjective and prone to error.
In addition, this requirement exceeds the requirement of I WV-3 413( b) that the stroke time of all power operated valves for stroke times of r
10 seconds or less be measured to the nearest second.
ALTERN ATE TESTING:
None.
Testing of these valves shall meet the requirement of I WV-3 413( b) that the full stroke operating time for valves with operating times of 2 I previously 51 seconds or less be measured to the nearest second.
Any observed abnormality of erratic action shall be investigated.
STAFF EV ALU ATION:
The NRC staff has taken a position on fast acting valves which assigns a limiting stroke time of 2 seconds, requi res corrective action if such a value is exceeded under test and applies the full Section XI requirements for valves with a 1
full stroke time of greater than 2 seconds.
1 PSE&G RESPONSE:
Upon further review and evaluation, PSE&G has decided
.a modify this relier request to apply to only those valves which have full stroke operating times of 2 seconds or less, rather than the previously requested 5 seconds.
This change in philosophy is based upon a review of the valves baseline data in light of Staff Evaluation comments.
The new grouping of valves includes all the valves previously identified under this relief request as well as the Containment Atmosphere Control System ( C ACS) valve Page 4 of 11
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1-GS-HV-4980 ( V020) originally listed under Relief Request No.
V-02.
These valves typically close in less than l
approximately 1 secondt therefore, adherence to the Staf f's I
criteria is acceptable and within operational capabilities.
Accordingly, the Relief Request reiterated above will be revised as shown in the highlighted areas above and the listing of valves.below when the Program is formally i
submitted for approval.
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CONPONENTS:
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3 The valves for which relief is requested are identified below by valve number and system:
1 Reactor Recirculation System 1
1-BB-SV-4310 1-BB-SV-4311 l
I j
Residual Heat Removal ( RHR) System i
1-BC-SV-F079A 1-BC-SV-F080A i
1-BC-SV-F079B i-BC-SV-F080B l
Reactor Core Isolation Coolino ( RCIC) System l
?
l 1-BD-SV-F019 I
l S e r vi c e Water System ( SWS) i 1-EA-SV-2367A 1-EA-SV-2367C
]
1-EA-SV-2367B 1-EA-SV-2367D
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S i
j Process Samplino Svatem i
i 0-RC-SV-0643A 0-RC-SV-0729A 3
0-RC-SV-0643B 0-RC-SV-0729B l
0-RC-SV-0707A 0-RC-SV-0730A i
0-RC-SV-0707B 0-RC-SV-07308 0-RC-SV-0728A 0-RC-SV-0731A
}
0-RC-SV-0728B 0-RC-SV-07318 0-RC-SV-8903A 0-RC-SV-8903B i
a j
Neutron Monitorino System
.i 1-SE-SV-J004A-1 I
1-SE-SV-J004A-2 l
l 1-SE-SV-J004A-3 l
i-SE-SV-J004A-4 1-SE-SV-J004A-5 2
Co nt ai n me nt Atmosphere Control System ( C ACS).
t
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1 HV-4978 ( YO23) i I
Page 5 of it i
1.
RELIEF REQUEST V-07 SPECIAL LEAK TEST TEST REQUIRENENTS:
IWV-3420 provides requirements for seat leakage testing of Category A valves.
Specifically, IWV-3426 requires that the maximum permissible leakage rates for each individual valve be specified by the Owner, or meet the criteria identified therein.
IWV-3427 stipulates the necessary corrective action to be taken based on the requirements provided in IWV-3426.
BASIS FOR RELIEF REQUEST:
The valves listed below are tested in accordance with HCGS Technical Specifications 4.6.1.2.f and 4.6.1.2.g.
respectively.
These tests meet all of the requirements of IWV-3420, except those identified above (i.e i ndi vi d ual valve leak rates).
Since it is the function of these valves to establish seal boundaries in order to isolate the primary containment in the event of an emergency, the collective acceptance criteria is more appropriate.
In addition, a d mi ni s t ra t i ve li mi t s have been established for the individual valves listed in the request for relief.
Exceeding the a d mi ni s t r a t i ve limits requires evaluation for corrective action, as appropriate.
ALTERNATE TESTING:
These valves will be tested in accordance with the requirements of HCGS Technical Specifications 4.6.1.2.f and
- 4. 6.1, 2. g, as applicable.
1 STAFF E V A LU ATI ON:
The NRC staff has concluded that additional information is necessary in order to demonstrate that Section XI requirements are impractical and that the Technical l
Specification testing provides equivalent data for 1
evaluation of the subject valves.
PSE&G RESPONSE:
Information regarding the impracticality of Section XI testing is p r o vi d e d in the following section.
However, as discussed below, additional information which establishes the basis for testing the Main Steam Isolation Valve Sealing System ( MSIVSS) and Feedwater ( FW) sealing system is Page 6 of 11 i
1 i
provided in docketed PSE&G correspondence and the PSAR and SER.
Specifically, as stated in the NRC Safety Evaluation Report
( SER) Section 6.2.4'1),
the design of the FW sealing system, i
as described in FSAk Sections 5.4.9, 6.2.3.2.3, 6.2.4.3.1.2 and 6.2.6.3, provides an acceptable alternative to the explicit requirements of GDC 55.
However, discussions with the NRC during the final licensing phase of HCGS required additional information to support the actual testing arrangement generally alluded to in the FSAR.
PSE&G provided this detail in the letter from C.A.
McNeill, J r.
( PSE&G) to E.
Adensam ( NRC) dated February 18, 1986 in which agreement was reached regarding leakage past valves BD-V005, BJ-V059 and AE-V021 into the RCIC, HPCI and RWCU systems, respectively.
Since these referenced systems are 1
seismically qualified, water-filled, closed systems outside containment there is no requirement to specify their leakage in the Technical Specifications other than the 10 gpm limit applied to the valves which form the long-term boundary of the feedwater system.
This rationale and conclusion was approved by the NRC with the issuance of the HCGS Technical i
Specifications on April 11, 1986 ( NUREG-1202 Appendix A to Facility Operating License NPF-50.)
Consequently, PSELG concludes that the basis of the FW sealing system dictates the testing method for the subject valves and hence the o
requested relief is necessary in order tr implement the IST Program.
1 t
With regard to the Main Steam Isolation Valve Sealing System
( HSI VSS), the NRC concluded in SER Section 6. 7 that the l
system, as described in FSAR Sections
- 5. 4. 9, 6.2.4.3.1.1, 6.2.4.4.4 and 6.7, meet all applicable guidance of the d
Standard Re vi e w Plan, Section 6.7, and therefore was in conformance with regulatory requirements.
However, similar to the FW sealing system, additional information was necessary regarding the testing of the HSIVSS and hence PSE&G docketed the required details on March 17, 1986 (C.A l
McNeill, J r.
to E.
Adens am. )
The inf crmation provided in this referenced transmittal clearly identifies the testing method which when reviewed in light of the system design as d
detailed in the PSAR, support the IST relief request.
In fact, the Technical Specifications provide confirmation of the testing method employed in that testing of the entire main steam sealing system, rather than individually specific valves or penetrations, requires the leakage of the entire l
system to be maintained less than or equal to 46 s c f h.
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ADDITION AL JUSTIFIC ATION:
The design of both the FW sealing system and HSIVSS does not currently permit the testing of less than two, and in some cases less than three valves, at one time in that each valve i
i Page 7 of 11 i
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cannot be isolated from the others associated with the subject penetration.
This design has dictated the current test method of testing the entire penetration and including leakage from the test boundaries into the entire s ys t e m' s Technical Specification leakage li mi t.
A plant redesign to facilitate a test method which would permit individual valve testing in order to satisfy the ASME code is impractical and if imposed represents an undue burden.
Furthermore, without the approval of the abnve referenced relief request, a plant shutdown would be required in order to perform surveillances required more frequently than every 18 months.
Since the current Technical Specifications clearly stipulate corrective actions should test failures be encountered, the additional requirement which would be imposed from the IST Program should the relier not be granted would result in hardship and unusual difficulties without a compensating increase in the level of quality and safety.
Therefore granting of the above referenced relier request is in the public interest since the relief will not endanger life or property or the common defense and security of the public.
COMPONENTS:
The valves for which relief is requested are identified below by valve number and s ys t e m:
Main Steam System 1-AB-HV-3631A ( V003) 1 - AB-HV-3631 B ( V004) 1 - A B-HV-36 31 C ( V005) 1 - AB-HV-3631 D ( V006) 1-AB-HV-F022 A ( V028) 1 - AB-HV-F022B ( V029) 1-AB-HV-F022C ( V030) 1 - AB-HV-F022 D ( V0 31) 1 - AB-HV-F028 A ( V032) 1 - AB-HV-F028B ( V033) 1 - AB-HV-F028C ( V034) 1-AB-HV-F028D ( V035) 1-AB-HV-F067A ( V059) 1 - AB-HV-F067 B ( V060) 1 - AB-HV-F067C ( YO61) 1 - AB-HV-F067D ( V062) 1-AB-HV-F071
( V027)
Feedwater System 1
1-AE-HV-F032 A ( V005) 1 - A E - H'f - F 0 3 2 B ( V001 )
1-AE-HV-F039
( V0 21 )
Reactor Core Isolation Coolino j RCIC) System 1-BD-HV-F013
( V005) j Hioh Pressure Coolant Injection ( HPCI) System
]
1-BJ-HV-6278
( V059) t 1
j Page 8 of 11 j
Main Steam Isolation Valve Sealina System ( MSIVSS) 1 -KP-HV-58 34 A ( V010) 1 -KP-HV-5 8 3 4 B ( V016) 1-KP-HV-5835A ( V009) 1 -KP-HV-5 8 3 5 B ( V015) 1-KP-HV-5836 A ( V008) 1 -KP-HV-5 8 3 6B ( V014) 1-KP-HV-5837 A ( V007) 1 -KP-HV-5 8 3 7 B ( V013)
RESPONSE TO PARAGRAPH 3.1.1 OF THE STAFF EVALUATION STAFF COHHUNT:
In several relief requests the licensee has used an alternete testing interval of 18 months.
The Staff does not recognize an interval of 18 months.
If the interval is intended to refer to refueling outages, then the program should reflect the interval with reference to refueling rather than 18 months.
PSE&G RESPONSE:
The statement that the Staff does not recognize an interval of 18 months is inconsistent with the current standard, as well as the HCGS, Technical Specifications.
In fact a review of the HCGS Technical Specifications confirms that the surveillance intervals identified are based upon a definitive time frame, such as every 18 months.
Furthermore, since the Technical Specifications already address the required testing interval, the relief requested simply reflects an already approved Staff testing interval.
Therefore, granting of the relief requests which utilize this alternate testing interval is in the public interest since the relief request will not endanger life or property or the common defense and security of the public.
RESPONSE TO PARAGRAPH 3.2.1 0F THE STAFF EVALUATION ST AFF COMMENT:
In several relier reauests the licensee used de-inerting containment as the ju.tification for a given relief.
The i
Staff acknowledges de-inerting of the containment as a valid justification for granting relief, but will not grant relief unless the alternative testing interval is "each cold shutdown if the containment is de-inerted AND each refueling outage."
1 Page 9 of 11
PSE&G RESPONSE:
Two relier requests reference de-inerting the containment in the justification for relief.
Specifically, Relier Request No.
V-9, Exercise Closed Every 18 Honths, specifies that the alternate testing is based upon the requirements contained in SER Supplement 4 Section 3.10.3 which only requires that the subject valves be tested at least once per 18 months.
This request was not taken to test each cold shutdown or refueling, but rather to test every 18 months.
Additionally, Relier Request No.
V-17, Power Operated Testable Check Valves, indicates that the alternate testing will be completed during cold shutdown only.
This request was not provided to permit testing at cold shutdown ( ASHE Code,Section XI already permats this), rather the relief was to exercise the valves by their air-operators and not measure torque as required by code.
Furthermore, for valves that can not be exercised during plant operations, PSE&G will comply with Sect.4on XI, I WV-3 412( a) which states in part:
"Valves that can not be exercised during plant operations shall be identified by the owner and exercised during cold shutdown "
The code also states that:
"Valves not exercised during plant operations shall be on a frequency determined by the intervals between shutdowns as follows:
For intervals of 3 months or longer - exercise during cold shutdown, For intervals of less than 3 months - full stroke exercise is not required unless 3 months have passed since last shutdown exercise."
All valves that are exercised only during cold shutdowns are identified in the IST Program Valve Table under the Remarks column.
For f urther inf ormation regarding the PSE&G position on cold shutdown testing, Generic Valve Relief Request No, 1 was developed and should be referred to for details.
If the requirement to perform testing is at "each cold shutdown if the containment is de-inerted AND each refueling outage" as specified by the staff, then not only is the possibility introduced of testing the valves more than their identified interval, but also testing at "each cold shutdown if the containment is de-inerted" does not specify what time interval between tests is acceptable, In otherwords, back-to-back testing could occur every time the containment Page 10 of 11
is de-inerted, which is not scheduled or anticipated to occur more than six times per year but could possibly occur on a greater frequency.
This requirement if imposed then represents an undue burden, and owing to the fact that such testing is not necessary nor beneficial when compared to the requirements of ASHE Section XI Code or the Technical Specifications, the granting of this relief request is in the public interest since the relief request will not endanger life or property or the common defense and security of the public.
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Page 11 of it
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