ML20236X631

Discusses Preliminary Review of Util 870712 Submittal of Rev 0 to Inservice Testing Program Based on Pump & Valve Test Requirements of 1980 Edition of ASME Code,Section Xi.Program Complete Except Six Relief Requests.Comments Encl

ML20236X631
Person / Time
Site:	Hope Creek
Issue date:	12/07/1987
From:	Butler W Office of Nuclear Reactor Regulation
To:	Corbin McNeil Public Service Enterprise Group
References
TAC-65730, NUDOCS 8712090347
Download: ML20236X631 (8)

Text

- - - - - _ _ _ - _ _ - . _ _ _ _ _ - _ - _ _ _ _ . . _ _ _ _ _ .

'o UNITED STATES

+f g 8 o NUCLEAR REGULATORY COMMISSION

• ;; ~E WASHINGTON, D. C. 20555

% December 7, 1987

,/

....+

Docket Nn. 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:

(TAC NO. 65730) INSERVICE TESTING PROGRAM Re: HOPE CREEK GENERATING STATION By letter dated July 12, 1985, Public Service Electric and Gas Company (PSE&G), in sunport of its application for an operating license for the Hope Creek Generating Station, submitted Revision 0 of the Hope Creek Inservice l Testing (IST) Program. This IST program was based on the pump and valve test requirements of the 1980 Edition of ASME Code,Section XI, through Winter 1981 l Addenda. Based on a preliminary review of this July 12, 1985 submittal, the staff concluded, as documented in NUREG 1048, Supplement Number 4, Safety Evaluation Report Related to the Operation of Hope Creek Generating Station, dated December, 1985, that the relief requested in the July 12, 1985 submittal should be granted for a period no longer than two years from the date of issuance of the operating license or until the detailed review has been completed, whichever comes first. The requested relief was granted via Condition C(3) to the operating license which states:

. .a the relief ~ identified in the PSE8G submittal dated .

July 12, 1985, requesting relief from certain pump and valve testing requirements of 10 CFR 50.55a(g) is granted, until April 11, 1988, or un~til a detailed review of the inservice testing .

. program for pumps and valves has been completed, whichever enmes .

first."

Prior to the staff's detailed review of the July I?, 1985, Revision 0 Hope Creek IST Program, PSE8G by letter dated September 21, 1987 submitted Revision 1 to this IST Program. It stated that this revision supercedes the July 12, 1985 Revision 0 IST Program. It requested that the NRC conduct a review and provide interim approval of this revised program until a complete review can be accomplished or until April 11, 1988. This revised program incorporates the requirements of the 1983 Edition of ASME Code Section XI through sumer 1983 addenda. It deletes some of the previous relief requests and adds some new relief requests. It also deletes some components from the program and incorporates some additional components not previously identified within the program.

The staff and its consultant, EG&G, Idaho, has performed a preliminary review of this revision, with emphasis on requests for relief from the Code 0712090347 PDR ADOCK 87Mb PDR-P

! - ..___ m _ _______ _ _ _ _ _ _ _

requirements. The review concluded that the program is reasonably complete with respect to all but six relief requests. For four of these six requests, Hope Creek has not provided sufficient technical information for the staff to conclude that the Section XI inservice testing requirements would be met, or are impractical. These four requests are therefore denied. The four denied relief requests are: Valve Relief Requests Nos. V-02, V-05, V-07, and V-08.

The fifth and six requests, V-12 and V-19, were deemed to be unnecessary by the staff. The enclosed report, which was prepared by our contractor provides the basis for our position on each of these six relief requests.

This preliminary review is not intended to replace a complete component-by-component review to ensure that all proposed tests in the program are in accordance with the Code requirements. A more thorough review will be conducted later and could result in further denials of relief requests or the need for additional components to be added to the program. The purpose of present review is to provide an assessment of the acceptability of the Hope Creek ist program for the period of time until the complete review of the program is finished.

Except for the above mentioned six relief requests, PSE&G should follow Revision 1 of the Hope Creek IST program to establish pump and valve operability for its plant operation until the final SER is issued. Any additional relief requests may not be implemented without prior approval by NRC.

The staff has determined that pursuant to 10 CFR 50.55a(g)(6)i granting this interim approval for the reliefs requested in Revision 1, except for the 6 relief requests identified above, 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 could result if the requirements were imposed on the facility.

Since License Condition C(3) refers to the July 12, 1985 Pevision 0 1st Program which has now been superceded by the September 21, 1987 Revision 1st Program, it is no longer applicable. We suggest that you submit an amendment request to have this license condition deleted.

Sincerely,

/s/

Walter R. Butler, Director Project Directorate 1-2 Division of Reactor Projects I/II l

Enclosure:

DISTRIBUTION As stated above Docket File M0'Brien NRC PDR/LPDR GRivenbark/RLo cc w/ enclosure: . PD #I-2 Reading OGC-Bethesda See next page , o SYarga BBoger EJordan JRartlow

/

I' ACRS (10)

PDI- PDI-2/D C, GRiv bar :cps WButler l2/Lf87 ' s 1 / ] /87 3'l

I e

requirements. The review concluded that the program is reasonably complete with respect to all but six relief requests. For four of these six requests, Hope Creek has not provided sufficient technical information for the staff to conclude that the Section XI inservice testing requirements would be met, or i

are impractical. These four requests are therefore denied. The four denied I relief requests are: Valve Relief Requests Nos. V-02, V-05, V-07, and V-08.

The fifth and six requests, V-12 and V-19, were deemed to be unnecessary by the staff. The enclosed report, which was prepared by our-contractor provides the basis for our position on each of these six relief requests.

This preliminary review is not intended to replace a complete component-by-component review to ensure that all proposed tests in the program are in accordance with the Code requirements. A more thorough review will be conducted later and could result in further denials of relief requests or the need for additional components to be added to the program. The purpose of present review is to provide an assessment of the acceptability of the Hope Creek ist program for the period of time until the complete review of the program is finished.

! Except for the above mentioned six relief requests, PSE&G should follow l Revision 1 of the Hope Creek IST program to establish pump and valve 1

operability for its plant operation until the final SER is issued. Any additional relief requests may not be implemented without prior approval by NRC.

l l The staff has determined that pursuant to 10 CFR 50.55a(g)(6)i granting this interim approval for the reliefs requested in Revision 1, except for the 6 relief requests identified above, 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 could result if the requirements were imposed on .

the facility.

Since License Condition C(3) refers to the July 12, 1985 pevision 0 1st

- Program which has now been superceded by the September 21, 1987 Revision 1st Program, it is no longer applicable. We suggest that you submit an amendment request to have this license condition deleted.

Sincerely,

/s/

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

Enclosure:

DISTRIBUTION As stated above Docket File M0'Brien NRC PDR/LPDR GRivenbark/RLo cc w/ enclosure: e. PD #1-2 Reading OGC-Bethesda See next page ,

SVarga EJordan BBoger JBartlow i ACRS (10)

PDI PDI-2/D C, GRiv bar :cp WButler j

/2/ t/87 4/}/87 / F7

.p.

requirements. The review concluded that the program is reasonably complete with respect to all but six relief requests. For four of these six. requests, Hope Creek has not provided sufficient technical information for the staff to conclude that the Section XI inservice testing requirements would be met, or are impractical. These four requests are therefore denied. The four denied relief requests are: Valve Relief Requests Nos. V-02, V-05, Y-07, and V-08.

The fifth and six requests, V-12 and V-19, were deemed to be unnecessary by the staff. The enclnsed report, which was prepared by our contractor provides the basis for our position on each of these six relief requests.

This preliminary review is not intended to replace a complete component-by-component review to ensure that all proposed tests in the program are in accordance with the Code requirements. A more thorough review will be conducted later and could result in further denials of relief requests or the need for additional components to be added to the program. The purpose of the present review is to provide an assessment of the acceptability of the Hope Creek IST program for the period of time until the staff's review of the program is completed.

Except for the above mentioned six relief requests, PSE&G should follow Revision I of the Hope Creek IST program to establish pump and valve operability for its plant operation until the final SER is issued. Any additional relief requests may not be implemented without prior approval by NRC.

The staff has determined, pursuant to 10 CFR 50.55a(g)(6)i, that granting this interim approval for the reliefs requested in Revision 1, except for the six relief requests identified above, is authorized by law and will not endanger life or property or the common defense and security. The staff has also con-cluded that. granting the approval is otherwise in the public interest con-sidering the burden that could result if the requirements were imposed on '

the facility.

Since License Condit' ion C(3) refers to the July 12, 1985 Revision 0 IST

_ Program which has now been superceded by the September 21, 1987 Revision IST Program, it is no longer applicable. We suggest that you submit a request for an amendment to have this license condition deleted.

Sincerely, UaADVM Walter R. Butler, Director Project Directorate I-2 Division of Reactor Projects I/II

Enclosure:

As stated above l

cc w/ enclosure: l See next page I

l

l

. HOPE CREEK GENERATING STATION )

INSERVICE TESTING PROGRAM l PRELIMINARY REVIEW j

\

l l

1.

• INTRODUCTION AND SCOPE f

The EG&G Idaho Inservice Testing Program Evaluation Group has performed a preliminary review of the Hope Creek Generating Station Pump and Valve Inservice Testing Program (IST), Revision 1, September 1987. The review, which primarily targeted the relief requests submitted by the licensee, was performed utilizing the acceptance criteria and guidance contained in the ASME Code Section XI; 1983 Edition with summer 1983 addenda, Code interpretations when applicable, the Code of Federal Regulations 10CFR50 and the Standard Review Plan, Section 3.9.6.

The relief requests were evaluated to determine if testing the components in accordance with the code requirements would place an unreasonable burden on the licensee and whether the licensee's proposed testing provided a reasonable alternative to the code requirements.

2. VALVE TESTING PROGRAM 2.1. Relief Requests V-02 and V-05.

2.1.1. RELIEF REOUEST. The licensee has requested relief for valves that normally full stroke in 5 seconds or less, from Section XI, paragraph 3417(a) which requires monthly testing to be performed (until corrective. action is taken) on valves with stroke times of 10 seconds or less, whose stroke time has increased 50% or more.

2.1.2. LICENSEE'S BASIS. These valves are equipped with fast acting actuators which are typically designed to provide the valves with full stroke times of 5 seconds or less. Since instrumentation is not

-installed to provide the level of accuracy required, attempts to measure percentage changes in the stroke time on these valves would be subjective and prone to error. In addition, this requirement exceeds the requirement of IWV 3413(b) that the stroke time for all power operated valves with stroke times of less than 10 seconds be measured to the nearest second.

2.1.3. EVALUATION. The Staff position on fast acting valves requires them to be assigned a limiting value stroke time of 2 seconds.

If a valve under test exceeds the 2 second value, corrective action is required. If a valve is assigned a limiting value full stroke time of I greater than 2 seconds, then the full Section XI requirements must apply.

Relief from the Code requirements as sought for in V-02 and V-05 cannot be granted.

2.2. Relief Request V-07. l 2.2.1. RELIEF REOUEST. The licensee has requested relief for the Main Steam Isolation Valve Seal and Feedwater longterm water seal boundary systems from Section XI, paragraphs IWV 3426 and 3427. These paragraphs require that the maximum permissible leakage rate for each individual valve be specified by the owner or meet the criteria therein, and also l stipulate the corrective action to be taken. l

i 2.2.2. LICENSEE'S BASIS. These valves are tested in accordance with HCGS Technical Specifications 4.6.1.2.f and .g respec.tively. These tests meet all of the requirements of IWV-3420, except those identified in the relief request above. 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, administrative limits have been established for the individual valves in this relief. Exceeding the administrative limits l requires evaluation for corrective action, as appropriate.

2.2.3. EVALUATION. The licensee has not demonstrated that the Section XI Code requirements are impractical or that the Technical Specification testing provides equivalent data for the evaluation of valve condition, therefore relief from the Code requirements as sought for in V-07 cannot be granted.

2.3. Relief Request V-08.

2.3.1. RELIEF REOUEST. The licensee has requested relief for multiple Emergency Diesel Generator valves from Section XI, paragraph IWV-3400 and 3520. This requires the exercising of power operated and check valves on a three month interval and for power operated valves, observing the appropriate indicators and fail safe testing.of the valves.

2.3.2. LICENSEE'S BASIS. The proper operation of these valves are tested on a monthly basis during the surveillance operability testing of the Emergency Diesel Generators per HCGS Technical Specification 4.8.1.1.2. These systems were not specifically designed to facilitate testing of these valves on an individual basis to the code requirements.

Relief is requested from these requirements because they are adequately ~

challenged at the more frequent interval.

2.3.3. EVALUATION. In this relief request, only the diesel air start system is applicable, all other systems are skid mounted and are not required to be included in the program. Surveillance testing of the diesel may not test each individual valve of the air start system to it's safety position as required. Therefore, because all safety related valves in the air start system, including the air start valves, must be tested individually to the Section XI requirements, Relief Request V-08 cannot be granted.

2.4. Relief Requests V-12 and V-19.

2.4.1. RELIEF REOUEST. The licensee has requested relief from Section XI, paragraphs IWV-3413 for the HPIS turbine stop and mechanical overspeed trip valve requiring stroke timing the valve and IWV-3411 for the RCIC turbine overspeed trip /stop valve requiring exercising the valve on a three month frequency.

2.4.2. LICENSEE'S BASIS. Stroke timing of the HPIS turbine stop and overspeed valve is not feasible due to the nature of it's design. The valve trips closed instantaneously. The RCIC turbine overspeed trip and ctop valve is exercis:1 by overspending the RCIC turbine. The risk of detrimental effects to the turbine by overspending it on a 3 month L______________ _ _ _ _ _--

frequency is unnecessary for this non-ECCS system. This valve is overspeed tested on an 18 month frequency in accordance with the preventative maintenance program.

2.4.3. EVALUATION. The Staff considers these valves to be part of the turbine assembly. Therefore, the Staff position in the case of these valves is that they must either be tested to the full requirements of Section XI or removed from the program. If removed from the program, the Staff acknowledges the valves as being adequately tested during the associated pump tests. Either option is acceptable and no relief is needed.

3.

GENERAL COMMENT

S.

l 3.1. 18 Month Alternatt Testing Interval.

3.1.1. COMMENT. 2n several relief requests the licensee has used an alternate testing interval of 18 months. The Staff does not recognize an interval of 18 months. If the interval is intended to refer to refueling outages, then the program should reflect the interval with reference to refueling rather than 18 months.

l 3.2. De-inerting Containment.

3.2.1. COMMENT. In several relief requests the licensee used de-inerting containment as the justification for a given relief. The Staff ,

acknowledges de-inerting of containment as a valid justification for i granting relief, but will not grant relief unless the alternative testing interval is "each cold shutdown if the containment is de-inerted AND each refueling outage".

W I

I i

Mr. C. A. McNeill Public Service Electric & Gas Co. Hope Creek Generating Station CC*

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 l

Hancocks Bridge, NJ 08038 Hancocks Bridge, New Jerrey 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 Harailton Avenue, Suite K Richard J. Hughes Justice Complex San Jose, California 95125 CN-850 Trenton, New Jersey 08625 M. J. Wetterhahn, Esquire Conner & Wetterhahn Office of Legal Counsel 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 Comission 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 I CN-112P U.S. Nuclear Regulatory Commission Trenton, New Jersey 08625 631 Park Avenue King of Prussia, Pennsylvania 19406 Mr. S. LaBruna General Manager-Hope Creek Operations j Hope Creek Generating Station P.O. Box 118 Hancocks Bridge, New Jersey 08038

_ _ _ - _ _ _ _ _ _ _ _ _