ML20236M014

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Recommends That Hope Creek Modify TS 3/4.5.1 to Conform W/ Sts,Which Specifies Steam Pressure & Flow as Necessary Conditions to Perform Test,To Avoid Further Interpretation Problems
ML20236M014
Person / Time
Site: Hope Creek PSEG icon.png
Issue date: 08/05/1996
From: Varga S
NRC (Affiliation Not Assigned)
To: Cooper R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20236J990 List: ... further results
References
FOIA-98-155 TAC-M95186, NUDOCS 9807130266
Download: ML20236M014 (6)
v • d • e


Text

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a' ha 2500 po *, UNITED STATES g, j, S* j 2

NUCLEAR REGULATORY COMMISSION WASHis#0 TON, D.C. 3000Hm01

% *****/ August 5, 1996 MEMORANDUM TO: Richard W. Cooper, II, Director Division of Reactor Projects Region I FROM: Steven A. Varga, Director Division of Reactor Projects I/IV

/Q-Office of Nuclear Reactor Regulation

SUBJECT:

TECHNICAL ASSISTANCE REQUEST ON HOPE CREEK TESTING OF AUTOMATIC DEPRESSURIZATION SYSTEM VALVES (M95186)

REFERENCES:

1. Memorandum from R. W. Cooper, II, Director Division of Reactor Projects, Region I to S. A. Varga, Director, Division of Reactor Projects, NRR, " Request for Technical Assistance on Hope Creek Testing of Automatic Depressurization System Valves," dated April 17, 1996.
2. LER No. 96-011-00 from M. E. Reddeman, General Manager, Hope Creek Operations to NRC, "High Pressure Coolant Injection System Failed Surveillance and Automatic Depressurization System Inoperability Resulteo in Entry into

, TS 3.0.3", dated April 19, 1996.

The Office of Nuclear Reactor Regulation (NRR) has reviewed the request from l Region I (Ref.1) to determine the adequacy of actions taken by Hope Creek i during a recent plant startup regarding the operability and testing of their i automatic depressurization system (ADS) valves.

Hope Creek Technical Specification (TS) 3.5.1.d requires the ADS valves to be OPERABLE in OPERATIONAL CONDITION 1, 2 & 3, with a footnote stating that the  !

ADS is not required to be OPERABLE when reactor steam dome pressure is less than or equal to 100 psig. ACTION statement d.2 specifies that with two or more ADS valves inoperable, be in at least HOT SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and reduce reactor steam dome pressure to less than or equal to 100 psig within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Finally, TS SURVEILLANCE ".EQUIREMENT 4.5.1.d.2.b states, in part, that the ADS valves be tested every 18 months by manually opening  ;

each valve when reactor steam pressure is greater than or equal to 100 psig.

A footnote to this surveillance requirement states that the provisions of TS i 4.0.4 are not applicable provided that the surveillance is performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam done pressure is adequate to perform the test. l During the restart from refueling outage 6, Hope Creek initially exceeded a reactor dome pressure of 100 psig at about midnight on March 19, 1996.

However, the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> clock to test the ADS was not started until 12:32 p.m. on i March 20, 1996, when reactor dome pressure exceeded approximately 700 psig, CONTACT: R. J. Giardina 415-3152 9007130266 900624 N$hnam rDFO

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2 - August 5,1996 which is the minimum pressure the valve vendor provided as adequate for testing. Due to problems with the High Pressure Coolant Injection (HPCI) pump, PSE&G was unable to test the ADS valves within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of achieving 700 psig. Therefore, at 12:32 a.m. on March 21, 1996, FSE&G declared the ADS system inoperable and, coupled with an inoperable HPCI system, entered a TS l 3.0.3 shutdown. At 4:45 a.m. on March 21, 1996, reactor pressure was reduced l to below 200 psig and HPCI ACTION statement C.1 was entered. The ACTION l statement for an inoperable ADS was exited at about 8:00 a.m. on March 21, l 1996, when reactor steam done pressure was reduced below 100 psig. The plant i remained critical and was r. subsequently allowed to repressurize to greater than 100 psig without demonstrating the ADS operable while repairs to the HPCI pump i were conducted.

The Region requested clarification on three points with regard to Hope Creek TS interpretation and adequacy of operator actions. NRR's response is as follows:

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1. Was it appropriate to start the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> clock for testing ADS after a pressure of 700 psig ,is reached versus a pressure equal to or greater than 100 psig? Note that starting at any pressure greater than 100 psig

, allows unlimited operation in the resulting pressure band without demonstrating the ADS operable. Also note that the current standard TS would permit this type of operation, although worded slightly different than the Hope Creek TS in that the standard identifies the adequate test pressure within the surveillance requirement. However, the standard l does not prohibit or limit the time of operation above [100 psig], when ADS is required to be operable; and below [700 psig), when ADS operability demonstration occurs. While this question is specific to the Hope Creek TS, the intent of the testing requirement may also be applicable to the current standard.

Response

I l

Based on the wording of the Hope Creek TS and the description of the purpose of this type of surveillance provided in the BASES for NUREG-1433 (BWR/4 STS) and NUREG-1434 (BWR/6 STS), the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> clod for l testing the ADS valves starts when adequate . steam pressure trg perform l the test is achieved. In Hope Creek's case this is 700 psig, the manufacturer's recommended test pressure. Operation between 100 and 700 psig is permissible, as described in the STS BASES which states that

... valve OPERABILITY and the setpoints for overpressure protection are verified, per ASME requirements, prior to valve installation."

, Reference 2 confirms that these surveillance were performed prior to startup, and, thus, the ADS valves were considered operable and capable of performing the safety functions. The STS does not otherwise limit plant operation above the applicability condition of 100 psig, but below the test condition of 700 psig.

" August 5,19%

2. Once the ADS valves were not tested within the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> grace period allowed by TS 4.5.1.d.2.b footnote, was the waiver from TS 4.0.4 still valid? Does this situation then constitute an unauthorized MODE changes, since the plant was then in Operational Condition Z without a tested ADS 7

Response

ADS OPERABILITY is applicable in OPERATIONAL CONDITION 2 and 3, when the steam done pressure is greater than or equal to 100 psig. The waiver from TS 4.0.4 applies to entry into these specified conditions.

The footnote to TS 4.5.1.d.2.b specifies that ADS testing be conducted "after reactor steam pressure is adequate to perform the test."

Adequate steam pressure includes both a specified pressure setting (700 psig) and a specified steam flow with 3 turbine bypass valves open (Ref.

2). If adequate steam pressure is maintained for the full 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and the surveillance has not been performed, this would be considered a failure to perform a surveillance and the appropriate ACTION should be taken to bring the plant to a condition in which the LCO does not apply (LCO 3.5.1.2.2 with two or more ADS valves inoperable, or LCO 3.0.3 with ADS and HPCI inoperable); in this case, the whlver of TS.4.0.4 would be moot. However, if after adequate steam pressere has been achieved, but cannot be maintained due to plant conditions; i.e., steam pressure drops because of operating conditions or is reduced by operator action, then i the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> clock is stopped, reset to zero (0) and not restarted until  !

adequate steam pressure is achieved; continued operation above 100 psig in OPERATIONAL CONDITION 2 or 3 would be allowed, because the ADS valves are still considered operable based on the response to question 1 above.

Thus, the waiver from TS 4.0.4 is still valid. In either case, operation in OPERATIONAL CONDITION 2 or 3 would not constitute an unauthorized MODE change.

. 3. Was it acceptable to remain critical with pressure reduced below 100 psig, instead of going to hot shutdown and reduced pressure as required by the inoperable ADS ACTION statement 3.5.1.d? If it was acceptable, what then is the purpose of the ACTION statement for more than one ADS valve being inoperable, which states: "be in at least HOT SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and reduce reactor steam dome pressure to less than or equal to 100 psig within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />?"

Response

l l As discussed in the response to question 2, it was acceptable to remain critical with pressure below 100 psig because the ADS valves were not considered inoperable. Action 3.5.1.d directs the plant to a hot l shutdown condition and reduced pressure condition, when ADS valves are inoperable and cannot be restored to an operable condition within the '

l allowed outage time. This LCO is relatively unique because of the combination of a pressure limit and applicable plant modes (OPERATIONAL i CONDITIONS). While it is probably sufficient to maintain the plant below the 100 psig limit with inoperable ADS valves, the typical l

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August 5, 1996 i

construction of TS requirements in accordance with 10 CFR 50.36 includes l' a " default" shutdown requirement when the LCO cannot be restored within the allowed outage time, i

Based on our review of References 1 and 2, the staff concludes that the Hope Creek actions taken during this event were appropriate. Reference 2 indicates that pressure reduction began approximately 40 minutes prior to the expiration  ;

of the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> clock. Thus, it is possible that the steam pressure was below the 700 psig limit prior to the expiration of 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> limit in which case the {

1 i

latter scenario of question 2 above would apply and the actions taken by the l plant would not have to have been performed. However, there may be some (

confusion in the footnote with regards to adequate steam pressure; as to whether it refers to pressure only (a specific point 700 psig) or pressure and flow. Reference 2 indicates that steam flow, as well as pressure, is a i i necessary condition for performing this ADS valve surveillance and that this )

clarification is specified in the associated plant procedures. Since Hope {

Creek has not decided whether they will pursue a conversion to the improved j STS, we recommend that Hope Creek modify TS 3/4.5.1 to conform with the STS, which specifies steam pressure and flow as necessary conditions to perform this test, to avoid further interpretation problems.

cc: E. Merschoff, R II W. Axelson, R III '

J. Dyer, R IV e

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4 i i

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August 5, 1996 construction of TS requirements in accordance with 10 CFR 50.36 includes J a " default" shutdown requirement when the LC0 cannot be restored within the allowed outage time.

Based on our review of References I and 2, the staff concludes that the Hope i Creek actions taken during this event were appropriate. Reference 2 indicates  !

, that pressure reduction began approximately 40 minutes prior to the expiration l l of the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> clock. Thus, it is possible that the steam pressure was below  ;

the 700 psig limit prior to the expiration of 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> limit in which case the l

, latter scenario of question 2 above would apply and the actions taken by the '

l plant would not have to have been performed. However, there may be some l confusion in the footnote with regards to adequate steam pressure; as to I whether it refers to pressure only (a specific point 700 psig) or pressure and l flow. Reference 2 indicates that steam flow, as well as pressure, is a necessary condition for performing this ADS valve surveillance and that this clarification is specified in the associated plant procedures. Since Hope Creek has not decided whether they will pursue a conversion to the improved STS, we recommend that Hope Creek modify TS 3/4.5.1 to conform with the STS, which specifies steam pressure and flow as necessary conditions to perform this test, to avoid further interpretation problems, i

cc: E. Herschoff, R II W. Axelson, R III J. Dyer, R IV

i, 6

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August 5, 1996 construction of TS requirements in accordance with 10 CFR 50.36 includes a " default" shutdown requirement when the LCO cannot be restored within the allowed outage time.

Based on our review of References 1 and 2, the staff concludes that the Hope Creek actions taken during this event were appropriate. Reference 2 indicates that pressure reduction began approximately 40 minutes prior to the expiration of the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> clock. Thus, it is possible that the steam pressure was below the 700 psig limit prior to the expiration of 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> limit in which case the latter scenario of question 2 above would apply and the actions taken by the plant would not have te have been performed. However, there may be some confusion in the footnote with regards to adequate steam pressure; as to whether it refers to pressure only (a specific point 700 psig) or pressure and fl ow. Reference 2 indicates that steam flow, as well as pressure, is a necessary condition for performing this ADS valve surveillance and that this clarification is specified in the associated plant procedures. Since Hope Creek has not decided whether they will pursue a conversion to the improved STS, we recomend that Hope Creek modify TS 3/4.5.1 to conform with the STS, which specifies steam pressure and flow as necessary conditions to perform this test, to avoid further interpretation problems.

cc: E. Merschoff, R II i W. Axelson, R III J. Dyer, R IV DISTRIBUTION: \

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