ML20198P131

Informs NRC of Util Conclusions After Further Evaluating Denial of Relief Request VR-09

ML20198P131
Person / Time
Site:	Calvert Cliffs
Issue date:	12/30/1998
From:	Cruse C BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9901060331
Download: ML20198P131 (3)

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. CHCLES H. CRUSE Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant Vice President Nuclear Energy 1650 Calven Cliffs Parkway j

Lusby, Maryland 20657 r

l 410 495 4455 l

i December 30,1998 l

l' U. S. Nuclear Regulatory Commission 3

I Washington,DC 20555 i

NTTENTION:

Document Con'rol Desk g

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SUBJECT:

Calvert Cliffs Nuclear Power Plant I

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Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 l

Results of Evaluation of Relief Reauest VR-09 i

REFERENCES:

(a)

Letter from Mr. C. H. Cruse (BGE) to NRC Document Control Desk, j

dated April 30,1997, " Third Ten-Year Inservice Test Program for i

Safety-Related Pumps and Valves"

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(b)

Letter from Mr. C. H. Cruse (BGE) to NRC Document Control Desk, i

dated October 1,1997, " Response to Questions on the Third Ten-Year l

Inservice Test Program for Safety-Related Pumps and Valves" f'

(c)

Letter from Mr. S. S. Bajwa (NRC) to Mr. C. H. Cruse (BGE), dated February, 11,1998," Safety Evaluation of the Inservice Testing Program f-Third Ten-Year Interval for Pumps and Valves - Calvert Cliffs Nuclear l

Power Plant, Units Nos. I and 2" l

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(d)

" General inservice Testing Issues,"

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Colaccino et al.,

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NUREG/CP-0152 Vol. 2, " Proceedings of the Fifth NRC/ASME l

Symposium on Valve and Pump Testing," July,1998

.(e).

NUREG-1463, " Regulatory Analysis for the Resolution of Generic l

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Safety Issue 105: Interfacing System Loss-of-Coolant Accident in Light Water Reactors," July,1993

[j' i-I The purpose of this' letter is to inform the Nuclear Regulatory Commission (NRC) of our conclusions after further evaluating the denial of Relief Request VR-09. Reference (a) submitted Revision 0 of our 5

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. Third Ten-Year Inservice Test (IST) Program for Safety-Related Pumps and Valves. Included in the IST Program Plan was Relief Request VR-09. In response to several questions, Reference (b) submitted b

Revision 1 of our Third Ten-Year. Inservice Test Program for Safety-Related Pumps and Valves.

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Revision 1 contained some minor changes, but Relief Request VR-09 was unchanged. Relief Request -

' VR-09 was denied in Section 3.2.3 of Reference (c).

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l For the Third Ten-Year IST interval, we updated our program to American Society of Mechanical Engineers (ASME) Operations and Maintenance Code Part 10 (OM-10). Paragraph 4.2.2.2 of OM 10

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" Containment Isolation Valves," requires leak testing containment isolation valves per 10 CFR Part 50, Appendix J requirements. This paragraph further requires that containment isolation valves also having a reactor coolant pressure isolation function to be additionally leak tested per OM-10, paragraph 4.2.2.3,

" Valve Leak Rate Test - Leakage Rate for Other Than Containment Isolation Valves."

During our Second Ten-Ye_ar IST Interval, leak testing of the Shutdown Cooling Return Isolation Motor-l

- Operated Valves was limited to that required by 10 CFR Part 50, Appendix 3. No other leak testing was required by Subsection IWV, nor were any commitments made in response to Generic Letters 80-14,

" LWR Primary Coolant System Pressure Isolation Valves" and 87-06, " Periodic Verification of Leak

' Tight. Integrity of Pressure Isolation Valves."

Therefore, the second requirement of OM-10,

. paragraph 4.2.2.2 establishes new leak testing requirements for these valves.

.Our experience shows Appendix J testing remains adequate to verify the leak-tight integrity of these valves. Additionally, the system configuration and normal operational observations are adequate to ensure.theLleak-tight integrity of the valves is monitored and maintained on a continuing basis.

l Therefore, we' submitted Relief Request VR-09 to continue this testing regime for these valves since i

implementing the new requirement would be difficult, expensive, and yield no greater assurance of the l

valves' leak-tight integrity.

While we are confident that these normal operational observations ensure the pressure isolation function of these valves'is maintained in a manner that satisfies OM-10, paragraph 4.2.2.1, we have also F

concluded that the pressure isolation function for these valves does not fall within the scope of the IST I

' Program. This conclusion is based on the evaluation written by the same NRC staff and contractors that co-authored Reference (c). It was presented during the 1998 NRC/ASME Symposium on Pump and Valve Testing in Reference (d) pages 4A-21 through 4A-36. Specifically, pressure isolation valves are L

discussed on pages 4A-22 through 4A 23. 'Ihe paper states, in part "... For plants licensed before 1979,

- licensees:are encouraged to perform leak testing...The [NRC) staff determined that there was

. insufficient basis to backfit generic requirements for PlV testing..." This statement is followed by a note referring the reader to Reference (e).

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Our review 'of Reference'(e) supports our conclusion that the statements in the paper are applicable to LCalvert Cliffs Nuclear Power Plant. It concludes that a majority of the interfacing system loss-of-coolant i

accident (ISLOCA) risk was due to operator error which could be corrected by training and improved a

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procedures.. It identified only one specific configuration where equipment failure contributed to L

'ISLOCA risk. ;The configuration is not applicable to us. The ISLOCA issue was resolved and no new 4

l requirements were established, as documented in NUREG-0933,."A Prioritization of Generic Safety

. Issues."

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December 30,1998 -

Page 3 Therefore, we have concluded

' Leak tight integrity of these valves is ensured by operational observations acr! A ppndix J testing; e

and Testing the pressure isolation function is outside the scope of the IST Program.

As recommended by Generic Letter 89-04, " Guidance on Developing Acceptable Inservice Testing Programs" and NUREG 1482, " Guidelines for Inservice Testing at Nuclear Power Plants," a revision to our IST Program Plan will be provided separately when an appropriate number of changes have been made to the plan.

This letter is provided for your information only. Should you have additional questions regarding this matter, we will be pleased to discuss them with you.

Very truly yours,

/ MJ V CllC/JMO/bjd 4

cc:

R. S. Fleishman, Esquire H. J. Miller, NRC l'

-J. E. Silberg, Esquire Resident inspector, NRC l

S. S. Bajwa, NRC R. I. McLean, DNR A. W. Dromerick, NRC J. It Walter, PSC l

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