ML20195D634
| ML20195D634 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/25/1988 |
| From: | Wilson R GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 5000-88-1657, C311-88-2148, GL-88-07, GL-88-7, NUDOCS 8811070087 | |
| Download: ML20195D634 (3) | |
Text
GPU Nuclear Corporation
- NEEnI Mu my One Upper Pond Road ww Parsippany, New Jersey 07054 201 316-7000 TELEX 13. -482 6
Writer's Direct Dial Number:
October 25, 1988 5000-88-1657 C311 2113 U.S. fluclear Regulator / Commission Attention: Document Control Desk Washington, D.C.
20555 Gentlemen:
Subject:
Response to flRC Inspection Report 88-05 Operability of Pressurizer Vent Valve RC-V-28 The purpose of this letter is to clarify the evolution of GPUN's assessment of RC-V-28 operability, which is discussed in Inspection Report 88-05 dated July 14, 1988.
T!)1-1 Technical Specification 3.1.13 reauires that at least one of three system vent paths be operable. One of these system vent paths is the pressurizer steam space (RC-V-28 and RC-V-44).
The associated action statement specifies that with one of the reactor coolant system vent paths inoperable, the inoperable vent path shall Le maintained Closed, with power The inoperable removed from the valve actuators in the inoperable vent path.
The Bases for vent path shall be restored to operable status within 30 days.
Technical Specification 3.1.13 identify that for events beyond the present design basis, the venting capability will substantially increase the plant's Tha Bases ability to deal with large quantities of non-condensible gases.
further state that the vent systems are seismically designed, environmentally qualified, and the power operated velves which are powered from emergency buses fail closed on loss of power.
On Wednesday,fiay 4, 1938, a auestion was raised internally as to the environmental cualification of the motor operator for RC-V-28, and a ity Concern (PSC) was filed.
During a meeting held in Preliminary Sar Parsippany on llay 4, GPUN person.iel agreed to evaluate the condition and prepare backup documentation within teri days demonstrating valve operability and justifying continued operation, or take other action as appropriate in accordance with Technical Spec 1f1 cation raautrements.
RC-V-28 is a pressurizer vent valve located inside containment with a Limitoraue motorized valve operator.
The Limitoraue motor operator was not on the Tt11-1 Environmental Qualif teation flaster List, nor did an EQ file exist.
Since documentation was not readily available to demonstrate aualification, a G811070097 G81025 PDR ADOCK 05000239 30(
PDC o
GPU Nuclear Corporat on is a subsd ry of General Pubbc Utit es Corporat>on
I
. s review was deemed necessa'*y to substantiate the component's capaDility to perform. Machine history documentation was reviewed to verify component parts, and telephone communications with Limitorque confirmed information from the THI-l machine history records. An EQ engineer with other plant personnel made an entry into the Containment Building on Wednesday, May 11 while the plant was operating at 1007, power. The purpose of the entry was to confirm as much of the vendor information as possible.
A subseauent meeting was held in Parsippany on Friday, liay 13, 1988. At that time, GPUN identified that the high point vent is provided to increase the plant's ability to deal with large quantities,of non-condensible gas which could interfere with natural circulation for events beyond the design basis.
The high point vents, therefore, do not fall within the scope of 10 CFR 50.49.
However, as previously noted, the Bases for T.S. 3.1.13 specify that the valve is environmentally qualified.
This' statement evolved from NUREG 0737 Item II.B.1, which required the installation of the RC vent system and specified that the system should be Qualified per the May 23, 1980 Commission Order and Memorandum. GPUN determined that the unavailability of documentation demonstrating Qualification of RC-V-28 did not represent a safety issue, since the valve does not perform a design basis safety function.
However, an effort was underway to document Technical Specification compliance, i.e. valve operability.
Documentation of valve operability was completed on Monday, !!ay 16, 1988, i
GPUN identified the status of the RC-V-28 evaluation to D. Johnson of NRC by telephone on May 13.
In recognition of tne fact that components or systems exist with environmental cualification requirements separate from 10 CFn 50.49, GPUN identif;ed our intent to treat the concern with RC-V-28 in accordance with NRC Generic Letter 88-07 in that a Determination of Operability and a Justification for Continued Operation would be documented.
We considered that our actions to establish and document RC-V-28 operability i
i within eight working days were in accordance with the intent of GL-88-07, which specifies that "the icensee is expected to make a prompt determination of operability."
t GPJN would like to clarify that GL 88-07 does not call for "an immediate determination of operability", but rather calls for "immediate steps to j
establish a plan with a reasonable schedule to correct the deficiency."
In the case of RC-V-28, a deficiency was not identified in that an adequate basis
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existed to establish operability.
IR-88-05 identified that the "the inspector concluded that engineering support personnal did not communicate the operability determination results to plant operations personnel in a timely manner." A normal working level of r
communication was maintained during this evaluation; had engineering support j
personnel uncovered an abnormal condition (i.e., that the valve was inoperable), plant operations personnel would have been notified immediately i
so that remedial actions could be taken in accordance with Technical Specif* cation requirements. The need for open lines of communication between plant
.erations personnel and engineering support personnel has been reinforctd by the IR-88-05 discussion.
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t 7225f/0190f
As discussed with R. Conte and O. Johnson of NRC on Octnber 21, 1988, when a PSC is raised internally, GPUN attempts to complete an evaluation as quickiy as possible.
Since a PSC often begins simply as a question, time is required to understand the question anJ determine if it has technical merit. Once researched and understood, then an evaluation addresses whether a valid safety concern or noncompliance exists.
The time required to reach this determination varies with the scope and complexity of the PSC. When a PSC is determined to represent a Technical Specification Limiting Condition for Operation, the plant is notified immediately and appropriate actions taken.
IR-88-05 specifies that "Three weeks was excessive in order to start the time clock for the appropriate TS action statement".
The determination of operability was documented within twelve days (eight working days) of the initial question.
THI-1 never was in a condition which reauired entering an action statement time clock. Although the valve qualification is beyond the scope of 10 CFR 50.49, immediate steps were taken to schedule a modification to upgrade the motor operator and related components with Qualified equipment during the upcoming refueling outage, which was completed in the 7R nutage.
In summary, we believe that our assessment of RC-V-28 operability was expedient and thorough, and exceeded the letter and spirit of the environmental qualification requirements.
- Incergly, ja w
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. F. Ili'Ison RFW/SK/it Vice President Technical Functions cc:
J. Stolz, USNRC R. Hernan. USNRC R. Conte, USNRC, THI-I 7225t,,190f
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