ML20149M590

Forwards Technical Evaluation Rept of Program Changes for Pump & Valve Inservice Testing Program Based on Addl Info Re Relief Request V-07.Interm Approval Granted

ML20149M590
Person / Time
Site:	Hope Creek
Issue date:	02/23/1988
From:	Butler W Office of Nuclear Reactor Regulation
To:	Corbin McNeil Public Service Enterprise Group
References
TAC-65730, NUDOCS 8802260144
Download: ML20149M590 (7)

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February 23, 1988 Docket No. 50-354 Mr. Corbin A. McNeill, Jr.

Senior Vice President - Nuclear Public Service Electric & Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038

SUBJECT:

INSERVICE TESTING PROGRAM (TAC NO. 65730)

RE: Hope Creek Generating Station By letter dated December 7,1987, we granted interim approval of reliefs requested for certain ASME Code Section XI pump and valve test requirements.

These reliefs were requested for the Hope Creek Generating Station in your letter of July 12, 1987. We also denied six of the requests for relief. In subsequent letters dated January 14, January 25, and February 11, 1988, you submitted additional information supporting three of the relief requests that had been denied, and subsequently withdrew two of these three requests.

The staff and its consultant, EG&G, Idaho have completed a review of the additional information concerning the remaining relief request (V-07) and has concluded that the granting of interim approval for the sole remaining requested relief which concerns leak testing of the main steam isolation valve sealing system and the long-term feedwater sealing system is authorized by law and will not endanger life or property or the common defense and security. The staff has also concluded that granting the approval is otherwise in the public interest considering the burden that would result if the requirements were imposed on the facility. Accordingly, interim approval is hereby granted for relief request No. V-07.

The enclosed report which was prepared by our contractor provides the basis for our granting this requested relief.

Sincerely,

/s/

Walter R. Butler, Director Project Directorate '-2 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation

Enclosure:

As stated

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/ rebcuary 23, 1988 Docket No. 50-354 ,

i Mr. Corbin A. McNeill, Jr.

Senior Vice President - Nuclear Public Service Electric & Gas Company  ;

P.O. Box 236  !

Hancocks Bridge, New Jersey 08038 i

Dear Mr. McNeill:

SilBJECT: INSERVICE TESTING PROGRAM (TAC NO. 65730)

RE: Hope Creek Generating Station l i

By letter dated December 7,1987, we granted interim approval of reliefs reouested for certain ASME Code Section XI pumo and valve test requirements. ,

These reliefs were requested for the Hcpe Creek Generating Station in your letter of July 12, 1987. We also denied six of the requests for relief. In subsequent letters dated January 14, January 25, and February 11, 1988, you submitted additional information supporting th)ee of the relief reouests that ,

had been denied, and subsequently withdrew two of these three requests. I The staff and its consultat t . EG&G, Idaho have completed a review of the additional information con cning the remaining relief request (V-07) and has i concluded that the granting of interim approval for the sole remaining i requested relief which concerns leak testing of the main steam isolation valve sealing system and the long-term feedwater sealing system is authorized by law 1 and will not endanger life or property or the comon defense and securitv. The l staff has also concluded that grantino the approval is otherwise in the public i interest considering the burden that would result if the requirements were imposed on the facility. Accordingly, interim approval is hereby granted  !

for relief request No. V-07. l The enclosed report which was prepared by our contractor provides the basis I for our granting this requested relief.

Sincerely, Halter R. Butler, Director I Project Directorate I-2 Division of Reactor Projects I/II i Office of Nuclear Reactor Regulation Enclosure-As stated l

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7 Mr. C. A. McNeill Hope Creek Generating Station 1 Public Service Electric & Gas Co.  !

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S. E. Miltenberger Mr. B. A.- Preston, Manager.  !

Vice President'- Nuclear Operations Licensing and Regulation Nuclear Department Nuclear Department P.O. Box 236 P.O. Box 236 ,

Hancocks Bridge, NJ 08038 Hancocks Bridge, New Jersey 08038  ;

Gregory Minor Susan C. Remis Richard Hubbard Division of Public Interest Advocacy .

Dale Bridenbaugh New Jersey State Department of MHB Technical Associates the Public Advocate 1723 Hamilton Avenue, Suite K Richard J. Hughes Justice Complex Sar Jose, California 95125 CN-850 Trenton, New Jersey 08625 M. J. Wetterhahn, Esquire Conner & Wette*hahn Office of Legal Counsal Suite 1050 Department of Natural Resources 1747 Pennsylvania Avenue and Environmental Control Washington, D.C. 20006 89 Kings Highway P.O. Box 1401 R. Fryling, Jr., Esquire Dover, Delaware 19903 Law Department - Tower SE 80 Park Place Ms. Rebecca Green Newark, New Jersey 07101 New Jersey Bureau of Radiation Protection 380 Scotch Road Resident Inspector Trenton, New Jersey 08628 U.S. Nuclear Regulatory Commission P.O. Box 241 Mr. Anthony J. Pietrofitta Hancocks Bridge, New Jersey 08038 General Manager Power Production Engineering Richard F. Engel Atlantic Electric Deputy Attorney General 1199 Black Horse Pike Division of Law Pleasantville, New Jersey 08232 Environmental Protection Section Richard J. Hughes Justice Complex Regional Administrator, Region !

CN-112P U.S. Nuclear Regulatory Commission Trenton, New Jersey 08625 475 Allendale Road ,

King of Prussia, Pennsylvania 19406 Mr. S. LaBruna i General Manager-Hope Creek Operations l Hope Creek Generating Station  :

P.O. Box 118 Hancocks Aridge, New Jersey 08038 i

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LETTER REPORT. TECHNICAL EVALUATION OF PROGRAM CHANGES FOR PUNP AND VALVE INSERVICE TESTING PROGRAM.

HOPE CREEK GENERATING STATION In December 1987, an Interim Safety Evaluation Report (SER) was issued for the Hope Creek Generating Station (HCGS). In response, by letter dated January 14, 1988, the licensee submitted additional information and proposed program changes concerning three of the relief requests that were denied in the interim SER. By letter dated February 11, 1988, the licensee withdrew two of the relief requests addressed in the January letter, leaving only one relief request to be addressed in this report.

The change to the licensee's Insevice Testing (IST) program was reviewed utilizing the acceptance criteria and guidance contained in the ~

following documents: ASME Code,Section XI; Code interpretations when applicable; the Code of Federal Regulations 10CFR50; the Standard Review Plan, Section 3.9.6; and the Draft Regulatory Guide and Value/ Impact Statement titled, "Identification of Valves for Inclusion in Inservice Testing Programs."

Relief request V-07 was evaluated to determine if testing the affected components in accordance with the Code requirements would be impractical, whether the licensee's proposed testing would provide a reasonable alternative to the Code requirements, and whether it would place an unreasonable burden on the licensee if the Code requirements were imposed.

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r y 1. GENERAL COMENTS In the January 14, 1988 letter, the licensee responded to the two general comments presented in the December 1987 SER. The two issues dealt with an alternate testing frequency of 18 months and relief requests that concern de-inerting containment.

The licensee's addressing of these issues in the letter does not fully conform to the current Staff positions. Because these are complex issues and are related to each other and other issues, they will be discussed at the IST working meeting to be held in the near future.

Deferring of these two issues will not adversely affect the IST program as the frequecy of testing involved is very long compared to the anticipated resolution at the working meeting. ,

2. VALVE TESTING PROGRAM The Public Service Electric and Gas Company basis for requesting relief from the valve testing requirements and the reviewer's evaluation of that request is summarized below.

2.1 Soecial Leak Test 2.1.1 Valve Relief Recyest V 07 2.1.1.1 Relief Reouest The licensee has requested relief from Section XI, Paragraphs IWV-3426 and -3427, which stipulate how each Category A valve will be leak-rate tested, the leakage measured, and the corrective action taken if that leak-rate is exceeded for the listed valves. The licensee has proposed to leak test these valves according to Technical Specifications with administrative limits and corrective actions assigned.

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Valves Included In V-07 I Main Steam System 1-AB-HV-3631A-D- 1-AB-HV F022A D l-AB-HV-F028A D l-AB-HV F067A-D l-AB-HV-F071 i Feedwater System 1-AE-HV-F032A/B l-AE-HV F039 Reactor Core Isolation Coolina System 1-BD-HV-F013 Hiah Pressure Coolant In.iection System 1-BJ-HV-8278 Main Steam Isolation Valve Sealina System 1-KP-HV-5834A/B 1-KP-HV-5835A/B 1-KP-HV-5836A/B 1-KP-HV-5837A/B

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2.1.1.1.1 Licensee's Basis For Reauestina Relief The valves listed 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 for individual 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, I administrative limits have been established for the individual valves listed in the request for relief. Exceeding the administrative limits l requires evaluation for corrective action, as appropriate. The design of both the FW sealing system and the MSIVSS does not currently permit the testing of less than two, and, in some cases, less than three valves, at j one time in that each valve 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 boundries into the entire system's Technical Specification leakage  !

limit. A plant redesign to facilitate a test method which would permit l individual valve testing in order to satisfy the ASME code is impractical and, if imposed, represents an undue burden.

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- . o ALTERNATE TEST 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.

2.1.1.1.2 Evaluation Due to the design constraints of these systems and the valves concerned, individual leak testing in accordance with the requirements of the Code is not feasible. Leak rate testing of valves in groups essentially meets the Section XI Code requirements, since this type of testing incoporates all of the major elements contained in paragraphs IWV-3421-3425. The licensee has developed Technical Specification controlled leak rate limits and corrective actions for each group of valves listed. The leak rate limits assigned for each group of valves provides a reasonable alternative to the requirements of IWV-3426, and the corrective actions provide a reasonable alternative to IWV-3427. '

If the limits established by Technical Specifications are exceeded, corrective action will be taken on one or more valves to reduce the leakage to within the limits. This Technical Specification leakage monitoring requirement adequately monitors valve sealing degradation The licensee's proposal to leak rate test these groups of valves in accordance with the HCGS Technical Specifications and the application of these limits and corrective actions provides a reasonable demonstration of valve leak tight integrity. Based on the impracticality of meeting the Code requirements for measuring valve-specific leakage for these valves, and considering the burden placed on the licensee if the Code requirements were imposed, relief may be granted from the individual valve leak rate testing requirements of Gection XI as requested.

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