ML20211B569
| ML20211B569 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 02/13/1987 |
| From: | Brey H PUBLIC SERVICE CO. OF COLORADO |
| To: | Berkow H NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| References | |
| P-87018, NUDOCS 8702190445 | |
| Download: ML20211B569 (18) | |
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OPublic Service-om,*.
Company of Colorado February 13, 1987 Fort St. Vrain Unit No. 1 P-87018 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C.
20555 Attention:
Mr. H. N. Berkow, Director Standardization and Special Projects Directorate Docket No. 50-267
SUBJECT:
Inservice Inspection and Testing
REFERENCES:
- 1) Telecon (C-86-0186)
Heitner/Hinson/ Williams to Holmes, 10/20/86
- 2) NRC letter, Wagner to Lee, dated 3/8/83 (G-83104)
- 3) PSC Letter, Walker to Berkow, dated 9/4/86 (P-86498)
Dear Mr. Berkow:
This letter is in response to a request by the NRC Staff (Ref.1) to submit a letter describing both the overall status of the Fort St. Vrain (FSV) Inservice Inspection and Testing (ISIT) Program and the FSV ISIT Program Plan.
The present ISIT Program is based on certain surveillance requirements (ISIT Phase I, Ref. 2) incorporated in the FSV Technical Specifications, Section 5.0.
Additional ISIT requirements have been submitted (Ref. 3) to the Nuclear Regulatory Commission (NRC) which when approved will constitu'a Public Service Company's (PSC) ISIT Program, Phase II. Major PSC ISIT Program developmental erphasis in the past few months has focused on this Phase II submittal and resolution of NRC comments associated with Phase II.
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P-87018 February 13, 1987 PSC is currently developing a ISIT Program Plan which will consolidate FSV's ISIT requirements and identify the structures, systems and components which are encompassed by the ISIT Program.
The ISIT Program Plan being prepared by PSC will emphasize the overall aspects of the ISIT Program and will be based on the applicable portions of ASME Boiler and Pressure Vessel Code Section XI, Divisions 1 or 2 as appropriate, for inspection and testing requirements, methodology, and acceptance criteria. A draf t of the Program Plan will be submitted to the NRC for review and comment by April 4, 1988. contains draft portions of the FSV ISIT Program Plan for your information at this time. The Table of Contents and the first four sections of the Program Plan have been included to indicate the organization, philosophy and direction that have been developed. Attachment 2 is the program development schedule.
Please note that the schedule is subject to change based on PSC's available resources and on the demands that may arise during the forthcoming restart effort.
In addition, PSC is currently reviewing the resource allocation for all long term projects and the ISIT Program may be affected.
If you have any questions or comments concerning the enclosed information, please contact Mr. M. H. Holmes at (303) 480-6960.
Very truly yours, h
H. L. Brey, Manager Nuclear Licensing and Fuels Division HLB /DLF/sem Attachments cc: Regional Administrator, Region IV ATTN: Mr. J. E. Gagliardo, Chief Reactor Projects Branch Robert Farrell Senior Resident Inspector Fort St. Vrain
ATTACHMENT 1 INSERVICE INSPECTION AND TESTING PROGRAM PLAN TABLE OF CONTENTS Section Title Page 1.0 Introduction
2.0 Background
3.0 Program Description 4.0 Administrative Controls 5.0 Reactor Internals 6.0 Elevated Temperature Structural Material 7.0 Graphite 8.0 PCRV 9.0 Class 2 Systems 10.0 Class 3 Systems 11.0 Component Support Program 12.0 ISIT Report Submittal Appendix A Pump Testing Program Appendix B Valve Testing Program
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I SECTION
1.0 INTRODUCTION
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- 1.0 Introduction The Fort St.
Vrain Inservice Inspection and Testing (ISIT) Program Plan defines the commitment to the United States Nuclear Regulatory Commission (NRC) made by the Public Service Company of Colorado (PSC) for fulfilling the intent of the requirements set forth by the American Society of Mechanical Engineers (ASME), Boiler and Pressure Vessel Code,Section XI, " Rules for Inservice Inspection of Nuclear Power Plant Components", at the Fort St.
Vrain (FSV) Nuclear Generating Station.
FSV is a single unit High Temperature Gas Cooled Reactor (HTGR) located 35 miles north of Denver, Colorado.
The plant employs a uranium-thorium fuel cycle; graphite is used for the moderator, fuel cladding, core structure and reflector; and helium is the prima ry coolant.
A prestressed concrete reactor vessel (PCRV) contains all the major components of the nuclear steam supply system.
The plant's net ra ed electrical output is 330 MWe.
The plant received it's operatir g license on December 21, 1973.
Inservice inspection and testing of nuclear power plant components provides confidence in the continued integrity of pressure retaining components, including piping and component supports, for those systems required for safe operation and shutdown of the pl a rit.
The inspection rules and FSV components included in the program are based on the safety functions required for safe operation and shutdown of the plant. The proper operating characteristics of components, such as pumps and valves, are also verified during ISIT and are included in the scope of the FSV ISIT Program.
The ISIT Program shall be based on the applicable portions of the ASME Boiler and Pressure Vessel Code,Section XI, Divisions 1 or 2 as appropriate, for inspection and testing requirements, methodology, and acceptance criteria.
This program uses the 1983 Edition of ASME Section XI up to and including the Winter 1983 Adde,nda for guidance.*
ASME Section XI, Division 2, has not been formally adopted by the NRC.
Essentially, all of the plant's pressure-retaining equipment have been designed and fabricated in accordance with the ASME Boiler and 1
Pressure Vessel Code (1965, with Addenda from Winter 1966),Section III Class C or Section VIII, as applicable.
All piping F?s been designed in accordance with the USAS Power Piping Code B31.1, 1967, or the USAS Nuclear Power Piping Code B31.7, including applicable nuclear interpretations.
There are certain components, e.g., Steam Generators and PCRV closures, that have been designed to ASME Section III, Classes A and B.
Structures, systems and components at FSV are divided into two groups according to their importance in terms of safety during environmental disturbance accidents. The two groups are the Class I and the Class II items.
Some of the Class I items are required for Safe Shutdown of the plant.
All Class I items are designed to withstand the
" Design Basis Earthquake" without unsafe damage or failure to function.
General descriptions of these items are contained in FSAR Table 1.4-1.
Class I structures, systems and components include items whose l
failure or damage could result in (1) release of abnormal quantities of radioactivity, (2) interference with safe reactor shutdown, or (3) interference with adequate removal of decay heat.
All structures, systems and components which are not Class I are Class II.
The minimum seismic and wind speed design requirements, as specified in FSAR Section 1.4.5, apply to the Class II items.
Those Class I structures, systems and components which are also Safe Shutdown, are required to be operational following a Maximum Tornado (300 MPH winds).
These items are listed in FSAR Table 1.4-2.
Further classifications of structures, systems and components have 1
been performed to better define, for the purposes of FSV ISIT only, an orderly gradation of safety importance to this equipment.
These ISIT classifications, considering guidance from ANS-23, Regulatory Guide 1.26 and 10CFR50.55a, are shown for FSV systems in Table 4-1.
This ISIT Program Plan has beer: prepared to govern the inservice inspection and testing activities at FSV during the first 10 year inspection interval commencing with the fourth refueling cycle.
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SECTION
2.0 BACKGROUND
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2.0 Background
As part of the orignal operating license, FSV inservice inspections and tests were specified by the FSV Technical Specification Surveillance Requirements, Section 5.0 (Reference 1).
The original 1972 NRC Safety Evaluation Report (SER) for the FSV Operating License (Reference 2) included a commitment to review the ISIT Program for the primary coolant system after five years of reactor operations.
In response to this commitment Public Service Comoany of Colorado (PSC) has reviewed the ISIT Program for FSV considering the acquired operating experience with the plant and updating the program in light of more recent rules and regulations.
The review effort was originally described by PSC together with the planned approach for conforming with the 1972 SER commitment in Reference 3.
A review of ISC plans was performed by the NRC which also identified priority items to be addressed as part of the original SER commitment (Ref. 4). The general ISIT review plan and the priority items were further discussed in letters and meetings between the NRC and PSC until a basic agreement was reached between both parties (Ref. 5 through Ref.10). A schedule was established for the review of surveillance requirements for all major. plant systems and equipment by subdividing them into priority categories as requested by the NRC (Ref. 11).
A set of general rules governing the FSV ISIT Program review was established by PSC in agreement with the NRC, as discussed above.
Specific important features of these rules were that Section XI Division 2 of the ASME Code, then in draft form, could not be applied directly to FSV, but was to be used as a guide; PSC would provide the NRC with a comparison of recommended surveillance requirements and justify the differences.
It was also agreed that PSC would rank the equipment items by their importance to plant safety and specify surveillance requirements commensurate with that importance to safety. Detailed definitions and criteria for examinations and tests were developed accordingly and transmitted to the NRC (Enclosure 3 to Ref. 12).
The results of all priority Category I reviews were transmitted to the NRC (Ref.12,13 and 14).
These reviews covered the major systems and components that are important to safety, including the
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prestressed concrete reactor vessel (PCRV),
the reactor internals, the reactor primary coolant system, the reactor secondary coolant system and the PCRV auxiliary system.
Each of the above packages contained draft modifications to the FSV Technical Specification Surveillance Requirements along with an evaluation of the existing and proposed inspections and tests, an identification of ASME Code Section XI requirements, and a discussion of the differences.
At the request of the NRC, the PSC preliminary submittals were independently reviewed under the direction of the Los Alamos National Laboratory (LANL) (Ref. 15, 16 and 17). A first meeting was held at FSV on November 20, 1982, between LANL, PSC and their consultants (Ref.
18).
The results of the independent review were subsequently included in a report, which was transmitted to both the NRC and PSC (Ref.
19). Most of PSC's recommended modiffcations to the Technical Specification Surveillance Requirements were determined to be adequate and acceptable, and a few additional investigations were recommended. The recommendations resulting from the independent review were subsequently analyzed by PSC who prepared a response to agree with or clarify these recommendations, or further support PSC's positions (Ref.
20).
The responses were also reviewed at a final meeting held on July 29, 1982, at FSV between the NRC, LANL, PSC and their consultants (Ref. 21 and 22). At this meeting, it was agreed that PSC would submit final proposed changes to the Technical Specification Surveillance Requirements, together with an implementation schedule.
These reviews culminated in the issuance of Amendment 33 to the FSV Technical Specifications (March 8,
1983), which included the Surveillance Requirements that embodied Phase I of FSV's ISIT Program.
Based on a subsequent review of FSV systems, PSC submitted a proposed Technical Specification Amendment (Ref. 23) in December of 1983 to address Phase II of the FSV ISIT Program. The proposed amendment was revised'(Ref. 24) in November of 1985.
In May of 1986, the NRC responded to the proposed amendment (Ref. 25).
PSC submitted a supplemental change (Reference 26) to the November,
- 1985, amendment request which addressed the NRC comments (Reference 25) as well as agreements reached with the NRC during telephone conversations in mid
- July, 1986.
PSC is currently awaiting NRC approval of this latest Phase II submittal of the FSV ISIT Program.
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REFERENCES 1
- 1. Fort St. Vrain Technical Specifications
- 2. Safety Evaluation Report (1-20-72), Section 3.3 l'
- 3. PSC letter (10-9-78, P-78169)
- 4. NRC letter (1-15-79, G-79009)
- 5. PSC letter (3-15-79, P-79058)
- 6. NRC letter (10-5-79, G-79176)
- 7. PSC Progress Report Meeting /NRC (8-20-79)
- 8. PSC letter (8-8-79, P-79176)
- 9. NRC letter (11-20-79, G-79189)
- 10. PSC Progress Report Meeting /NRC (11-1-79)
- 11. PSC letter (11-30-79, P-79289)
- 12. PSC letter (2-8-80, P-80014)
- 13. PSC letter (3-3-80, P-80034)
- 14. PSC letter (3-31-80, P-80064)
- 15. LANL letter (11-2-81, Q-13:81:365)
- 16. LANL letter (11-2-81, Q-12:81:369)
- 17. PSC letter (11-9-81, P-81285)
- 18. LANL letter (12-10-81, Q-13:81:420)
- 19. LANL letter (1-5-82, 0-13:82:5)
- 20. PSC letter (3-29-82, P-82061)
- 21. LANL letter (6-30-82, 0-13:82:228)
- 22. Meeting NRC/PSC/LANL (7-29-82)
- 23. PSC letter (12-30-83, P-83416)
- 24. PSC letter (11-27-85, P-85444)
- 25. NRC letter (5-30-86, G-86286)
- 26. PSC letter (9-4-86, P-86498) s
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e SECTION 3.0 PROGRAM DESCRIPTION 1
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3.1 Program Philosophy The overall intent of the FSV ISIT Program is to balance the following objectives and constrain 6s:
a.
Comply with commit'ments to the NRC governing the inservice inspection and testing of FSV systems, components. and structures during the subsequent 10 year inspection interval;
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b.
Minimize the cost and schedule impact of the required examination activities during plant operation and refueling outages; c.
Develop a program which includes, to the extent practical for FSV, the philosophy of the 1983 Edition ofiASME Section XI up to and including the Winter 1983 Addenda; and d.
Develop a program which is based on the applicable portions of ASME Boiler and Pressure Vessel Code'Section XI, Divisions 1 or 2 as appropriate, for inspection and testing requirements, methodology, and acceptance criteria.
3.2 Program Scope This program will govern applicable nondestructive examinations, test, evaluations and reporting activities based on ASME Section XI, Division 1
- or 2,
and any augmented or self initiated inspection programs as deemed necessary by PSC Management.
3.3 Schedule Inspection Program B, as defined in ASME Section XI, paragraph IGA-2420, will be used.
This program contains 10-year inspection '
intervals.
These intervals represent calendar years after the reactor has been placed in commercial service.*
The inspection interval is divided into 3 inspection periods. A g
certain minimum / maximum percentage defined by Section XI of the 4
examinations is required to be completed each inspection period.
For purposes of the FSV ISIT Program, the inservice examination activities will be the subsequent 10-year inspection interval commencing with the fifth fuel cycle.
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2 The cutages in which ISIT will be performed will be determined by the Station Manager. They will usually correspond to major plant outages for maintenance or refueling.
Major ISIT activities will be incorporated into the planned plant outage schedule.
3.4 Changes to the Program Plan Proposed changes to the Inservice Inspection and Testing Program Plan shall be evaluated per the criteria of 10 CFR 50.59.
Proposed changes involving an unreviewed safety question shall be submitted to the Commission for approval prior to implementation.
Proposed changes not involving an unreviewed safety question may be implemented without prior Commission approval, but all such changes shall be reported to the Commission in the annual 10 CFR 50,59 summary report.
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SECTION 4.0 ADMINISTRATIVE CONTROLS 4
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-g-4.0 Administrative Controls The inservice inspection and testing of structures, systems and components at FSV is presently required by the FSV Technical Specifications, Section 5.0, to Facility Operating License DPR-34.
Additional inspection and testing requirements have been submitted to the NRC (Reference 26) in the form of a Technical Specification amendment request.
The Inservice Inspection and Testing Program Plan shall be approved by the Commission prior to implementation.
Proposed changes to the Inservice Inspection and Testing Program shall be evaluated per the criteria of 10 CFR 50.59.
Proposed changes involving an unreviewed safety question shall be submitted to the Commission for approval prior to implementation.
Proposed changes not involving an unreviewed safety question may be implemented without prior Commission approval, but all such changes shall be reported to the Commission in the annual 10 CFR 50.59 summary report.
The Inservice Inspection and Testing Program shall be based on the applicable portions of ASME Boiler and Pressure Vessel Code Section XI, Division 1 or 2 as appropriate, for inspection and testing requirements, methodology, and acceptance criteria.
Implementation of the program described in this plan will be accomplished in accordance with the Quality Assurance (QA) Policies 4
and Procedures as described in'the FSAR Appendix B.
All items to be examined during a given 40-month period are to be scheduled for completion by the end of the applicable period in accordance with ASME Section XI.
A summary ISIT report for the examined components shall be filed within 90 days after completion of the inspection with the appropriate state agencies and the NRC.
4.1 System Boundaries ISIT classification of structures, systems and components for the Fort St. Vrain Nuclear Generating Station for the ISIT Program is summarized in Table 4-1.
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Table 4-1 i
FSV ISIT Principal Component Classification FSAR Figure P&ID
- 1. REACTOR CORE ASSEMBLY
- a. Core Support Structure 1
3.3-2 N/A
- b. Core Restraints 1
3.3-4 N/A I
- 2. REACTIVITY CONTROL SYSTEMS
- a. Reserve Shutdown System 2
3.8-4 Piping and Valves 3.8-5
- 3. PRIMARY COOLANT SYSTEM
- a. PCRV Structural Concrete, 1
5.6-4 N/A Tendons, etc.
- b. PCRV Support Ring 1
5.1-5 N/A
- c. Steam Generator (tubes, 1
4.2-13 N/A tube supports, tubesheets)
- d. Penetration Closures 1
5.8.2.1 N/A
- e. Large Penetration 1
5.8.5-14 N/A
- f. PCRV Liner 1
5.7-1 N/A
- g. PCRV Pressure Relief Devices, 2
6.8-2 PI-11-5 Block Valves, and Piping PI-11-4
- h. Primary Coolant Circulator 2
4.2-12 PI-21 Shaft Sealing Components up to the 1st isolation valve (Bearing Water & Buffer Helium)
- 1. Helium / Shutoff Valves 2
4.2-4 N/A
- j. PCRV Penetration 2
14.11-3 N/A Flow Restrictors
- k. Portions of Thermal Barrier 2
5.9-1,2 N/A
- 1. PCRV Liner Cooling Tubes 3
5.7-2 PI-46
- 4. HELIUM PURIFICATION SYSTEM
- a. Piping and Valves up to and 3
9.4-2 PI-23 including the second isolation valve
- b. High Temperature Filter 3
9.4-2 PI-23 Adsorber Internal Coolers I
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l-FSV ISIT Principal Component Classification FSAR Figure P&ID
- 4. HELIUM PURIFICATION SYSTEM (cont.)
- c. Equipment in Regeneration 3
9.4-2 PI-23 Section
- d. Piping and Valves in 3
9.4-2 PI-23 Regeneration Section
- 5. REACTOR PLANT COOLING WATER SYSTEM
- a. Components serving safety 3
9.7-2 PI-46 related equipment
- 6. SERVICE WATER SYSTEM
- a. Components serving safety 3
9.8-1 PI-42 related equipment
- 7. SECONDARY COOLANT SYSTEM
- a. Piping from Steam Generator 2
6.4-1 PI-22 up to and including dump valves and isolation valve outside containment
- b. Main Steam Piping 2*
10.1-1,2 PI-22
- c. Feedwater Piping 2*
10.1-1,2 PI-31
- d. Hot Reheat Piping 2*
10.1-1,2 PI-22
- e. Cold Reheat Piping 2*
10.1-1,2 PI-22
- g. Emergency Cond. Header 2
- 8. CIRCULATING WATER MAKEUP SYSTEM
- a. Components serving safety 3
9.8-1 PI-41 related equipment
- 9. FIRE PROTECTION SYSTEM
- a. Components serving safety 3
9.12-2 PI-45 related equipment These piping systems are part of the FSV Augmented ISIT Program for high energy piping as defined under EQ Program Confirmatory Action 6.
,e ATTACHMENT 2 FSV ISIT Program Development Schedule February 13, 1987 Submit information letter on status of the FSV ISIT Program and Program Plan.
July 1,1987
- Begin identification of FSV ISIT Class 1, 2 and 3 systems including markups of piping and instrumentation diagrams.
February 1, 1988
- Complete identification of FSV ISIT Class 1, 2 and 3 systems including markups of piping and instrumentation diagrams.
March 3, 1988
- Begin Plant / Management review of draft ISIT Program Plan.
April 4, 1988
- Submit a draft ISIT Program Plan to l
NRC staff for review and comment.
90 days after
- Submit comment resolutions for receipt of NRC review and acceptance.
comments.
60 days after NRC - Formal submittal of the FSV ISIT Program comment resolution Plan to the NRC.
acceptance.
Beginning of 5th
- ISIT Program Plan implementation.
Fuel Cycle g
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