ML20237L334

Requests Review of Plant Specific & STS with Respect to Allowable Number of Safety Relief Valves Out of Svc at Bwrs. Related Matl Encl

ML20237L334
Person / Time
Site:	Hatch, Nine Mile Point, Perry, Fermi, Hope Creek, Grand Gulf, Susquehanna, Brunswick, Limerick, River Bend, Clinton, LaSalle, 05000000, Shoreham, Skagit
Issue date:	08/26/1987
From:	Gibson A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Lainas G Office of Nuclear Reactor Regulation
References
REF-PT21-87-190-000 PT21-87-190, PT21-87-190-000, NUDOCS 8709080356
Download: ML20237L334 (7)

Text

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UNIT E D S1 ATES

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' ' ' ' .,,,. / AUG 2 61987 J PEriORAWUM F0P: Gus C. Lainas, Assistant Director for Region'IJ Peactors 1

Division of Reactor Projects 7/11 i FROM: Albert ~F. Gibson, Director Division of Reactor Safety

SUBJECT:

ALLOWABLE fDMCER OF SAFETY EELIEF VALVES OUT OF SERVICE AT

. BOILING WATER REACTORS (BWRS)

The Grand Gulf Resident Inspector has notified the Region of An issue dealing with requirements for the number of. operable Safety Relief Valves (SRVs) at

. BWRs. i s

' The' enclosed letters' from the General Electric (GE) Grand Gulf Construction Project Manager indicate that if the current Tech Specs concerning the number of' operable SRVs were -followed literally, the plant could oe operating in an unanalyzed region. The letters state that some plant analysis performed by GE

' assume all SRVs operable or only one inoperable. Until further analysis is

. performed, operation with more than one SRV inoperable could place the plant outside the licensed basis. The letter of February 3,1986, lists other BWRs-T that may be affected.

Les Kintner was contacted August 12, 1987. After discussions with others'at NRR, he concurred that a TIA is an appropriate means to address this matter.

Solutions to the problem may involve changes to the Standard Tech Specs for BWRs.- The Grand Gulf facility has issued a Tech Spec position statement that would forbid operation'with more than one SRV out of service. The other BWR i owners within Region II currently have restrictions in their Tech Specs limiting operation with SRVs out of service. The restrictions for operating with hoursg(reater Brownsthan olie Ferry) to SRV out seven fix within of servicedaysvary from hot (Brunswick).

or shutdown shut down within 12

' The anticipated transient without scram (ATWS) implications have not yet been detemined. ATWS may have stricter operating restrictions. 4 Region II requests NRR to review the plant specific and Standar'd Tech Specs with respect to this issue to determine if changes should be made.

If you have questions concernin or Rudy Bernhard (FTS 242-0339)g this matter, contact Frank Jape (FTS 242-4182) h Albert F. Gibson 1b

Enclosure:

GE letters dated 02/03/86 and 02/14/86 L

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AUG 2 61967 PEtiORANDUM FOR: Gus C. Lainas, Assistant. Director for Region'Il Reactors Division of Reactor Projects 7/11 FROM: Albert F. Gibson, Director Division of Reactor Safety SUNECT: ALLOWABLE fMCEP. OF SAFETY PELIEF VALVES OUT OF SERVICE AT B0ILING WATER REACTORS (BWRS)

The Grand Gulf Resident.!nspector has notified the Region of an issue dealing with requirements for the number of operable Safety Relief Valves (SRVs) at BWRs.

The enclosed letters from the General Electric (GE) Grand Gulf Construction Project Manager indicate that if the current Tech Snecs concerning the number of operable SRVs were followed literally, the plant could be operating in an unanalyzed region. The letters state that some plant analysis performed by GE assume all SRVs operable or only one inoperable. Until further analysis is performed, operation with more than one SRV inoperable could place the plant outside the licensed basis. The letter of February 3,1986, lists other BWRs that may be affected.

Les- Kintner was contacted August 12, 1987. After discussions with others at NRR, he concurred that a TIA is an appropriate means to address this matter.

Solutions to the problem may involve changes to the Standard Tech Specs for BWRs. The Grand Gulf facility has issued a Tech Spec position statement that would forbid operation with more than one SRV out of service. The other BWR owners within Region 11 currently have restrictions in their Tech Specs

, limiting operation with SRVs out of service. The restrictions for operating with greater than one SRV out of service vary from hot shut down within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (Browns Ferry) to fix within sevt.n days or shutdown (Brunswick).

The anticipated transient without scram ( ATWS) implications have not yet been determined. ATWS may have stricter operating restrictions.

Region 11 requests NRR to review the plant specific and Standard Tech Specs with respect to this issue to determine if changes should be made.

, If you have questions concernin 242-4182) l or Rudy Bernhard (FTS 242-0339)g this matter, contact Frank Jape (FTS hk H F /'

Albert F. Gibson

Enclosure:

GE letters dated 02/03/86 and 02/14/86

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wuewa s< icy wswtss octues gA) sentm eaene coa,a . m em, nu . w su ewcw nm MC 396 (408) 925-1937 February 14,1986 ,

Mr. L. F. Dale Director, Nuclear Licensing and Safety Mississippi power & Light Corpany

p. O. Box 1840

. Jackson, M5 39215 1640 Middle South Energy. Inc.

Grand Gulf Nuclear Station

$AFETY RELIEF VALVES CUT OF $ERVICE KPGE.86/023 OssrLarry:

Reference:

MPGE.86/014 Upen review of the referenced letter we have concluded that it was unclear and perhaps misleading and consequently this letter rescinds and supersedes the referenced letter.

The present status as we understand it is as follows:

Current Grand Gulf Tech $pec allows operation with only 13 of the to 3RV's in service.

Actual operation at Grand Gulf has had all valves in service.

The $[ referenced letter states that no safety hazard would have existed even if operation had taken place with up to 7 valves out of service (for a reasonable period).

Gt has concluded that there is no significant safety hazard (or no compromise of 14fety) for the follow.ng reasons:

I plant overpressure protection has been analyzed and documented in FSAR Chapter 3 showing that only 13 valves need to function to t temply with the A$ME criteria even for the bounding event. All 1

Chapter 15 transients are bounded by this analysis. Therefore the overpressure protection area is covered for the design and licensing basis.

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y y *ss DE:1E PF'4. IU:LcAD. $Fil;ci JA . I'! ,

/ , pean F . c'I 3.la. tsp 6 23:3e P. 3 CENIRAL $ ELECTRIC Mr. L. R. Dale

• February 14,1986- '

page !

Fuel protection is provided in Cha analysis was done with 41120 $RV'pter 15 in terms of MCPR. This s in service. GE evaluated the pctential impact of up to seven valves out-of-service and concluded that no MCPR degradation would occur. A key fact in this evaluation is that the minimum value of MCPR occurs before any $R flow has begun in alt 1 biting cases.

specifically for.the Grand Gu f F1AR cases of. lead reThis fact ha bypass failure and the feedwater controller failure jection with max demand, begins.both of which lead to MCPR valuss which occur just before $RV wtaid exist even though the situation is not fully calc documented in Chapter 15.

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of service untti analytical work is completed suppor operation with more than one SRV 005.

following: Our recommendation considers the The fuel margin evaluation is clearly obvious for one less valve, but of out should probably be further documented if a larger number is service.

It is highly likely that plant availability will be degraded if valves are lif ted in the spring eiode (with the most likel out-Df servict situation that the air actuator has malfwry It is not currently considered cosrnercially prudent ct(oned). to operate with more than one valve in this condition, but this is strictly an Operational consideration and has no safety irp1(c.ations.

Plant equipment thermal and load cycle evaluations have conserva-tively bounded transient events with 411 $AV's in service. Margin 4

be needed for larger numbers of valves and the such operation.

af plar.t lifetime cyclic design is expected to be nep however the constraints and documentation y 'nisplace.

not ful l One other question was . raised concerninst Ans. This is special because implementation of the new rule is still e performanc n process, and it has no clear pressure. Historically e criteria . GE specifically in this situation related to peak emergency limit to be soprop(and the WRC) have considered the A5ME boundary evaluations. riate . certainly for all passfve pressure below the tessel upset limitcomponents and shown ac maintained if no more than one(1375  ? psi ).ce if peak pressure is ke valve is fully out of servfee. Further evaluation valves may be needed if required to support operation with few in service,

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CENER AL $ ELECTRIC 1 Mr. L. F. Osle February 14,'.986 fage 3 -

In conciviion:

No Tech spec violation is involved since it allows 7 valves out of '-

. service.

Plant startup sad operation is clearly acceptable with co. or onc

$RY out-of service.

No safety h: 2srd exists even with more valves out-of service, but this is not fully documented at this time.

Very truly yours. L Q.re. c%:tA '

- A. R. Smith

' ConstructionProjectManager Grand Gulf Project cc: J. 6. Cesare T. H. Cloninger J. E. Cross

5. M. Faith J. 5. Ct11s -

5. H. Hobbs

' D. J. Kemppainen O. D. Kingsisy, Jr.

J. E. Nichols G. D. Pierce F. W. Titus Central File .

File: 22.15 0

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February 3.1M6 M.tC R / _ u p f 7 u sw L ,,,3__ ,

Mr. F. W. Titus Director Nuclear Plant Engineering .

t Mississippi Power & Light Company i

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'P. Sulf4tp O. Box Nuclear Station to Port Sfbson. M5 39160 F. Miedle South Energy Inc. I b- trend ~tulf Nuclear Station EtttRAL ELECTRIC PRC 64 28

- SAFETY RELIEF VALVES OUT.

0F 5ERVICE \

Deer Mr. Yftus: - MPGE-M/014 c'

t Program for eve 194 tion of potentially lleporta satisfaction of 10CFR Part 21.

1. information should be conveyed to the40tentis11y affected es 3

even though technical infomation.a Reportable Condition does not exist within the s Owners Group 5WROG This information was presented in the last SWR notification w(as general meeting and a by req)uested foreal transmittal the primeof representativ 1 MP&L should evaluate this infomation~as it tviates to existing future plant equipment, conditions, procedures or plans.

SE it' currently following information.notifying other potentially affe,cted BWR own b

, _ . Jnfermation to be Conveyed '

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The current interpreted standard as allowing MRC a plant to DWRoperateTechnica1'3pectfications indefinitely ' (

relattvely This large possio'le ' number of safety reitef valves'(5RV) ylwith a out of service.

, interpretation is based upon thewiefmus' number of SRV's required Vessel C6de.to function in order to satisfy the ASMf loiler & Pressure reflected in theItNRC is this minimum standard number Tech Spees.of SAYr t Dich sppears to be

( .. sechanical design of the fuel and various otherJsafetThe GeheYal Electric

,,,, components is based on the evallability SRV's. puder of installedof the Dtal ,

of insteiled 34V's in order to mitipste posign hin.pecidents and transients. ..

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Februtry 3, 1986

- , itted, or are in To GE's knowledge, the utilities that writtenhave to the either Manford subm the process of submitting Technical 2 C11stonjSpecifications 1$susquehanna1&22, Fermi Hope current NRC standard format are Grand GulfF Creek, Limerick, Shoreham, LaSalIt 3 ith & more than one $RV After reviewing the potential forft olantRCoperation standard Techwcriteria Spec have put of-service, SE has concluded that no sa e y violated with utility application of the current d hich shows WThis that conclus

$RV allowance and that no' safety hassed exists.

based on results of a therms). hydraulic' i (MCPR t $he transient transient stu y there is no impact'en Minieum Critical Powerf the $RV's, Rat e C'- number of $4V's assumed ..:

-  : ..- to operate wil g .

t to is not aware of any piant ever operating f

$AV s4t i.f snerice c A of service. Operation.Yith sore then one of design

- place the plant in an unanalyzed region of requirements to assume that all SRV's: in excess o

• the ASME code Itait may be inoperable.SWR teth Spect C, . of ^the SWR 00 Tech e

GE recommended modifications ,,

their to the s Spec coseittee for their action. i r

All operating plants since Hatch 2/8runswick 1 sh6

, $RV out of service" T technical specifications to confim the "enly one

c. allowance for operabt11ty. checked for One representative plant of the bases SWR 4/$/6 met by produ can be coepliance to the-recent ATWS Requirement. l one valve out of the presently-2 installed SRV's, the 'ATW$

Serv,1ce. 5 i) -

Very truly yours. -

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M ". 1;:

A. n. seith

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ConstructionProjectManager , .o..y Q:,,'

. E. Michols Grand Gulf project  ;- -.

J. 5. 1111s ,J . D, Pierce w/att.

cc: T. H. Cloninger 5. H. Hobbs w/stt. Central File w/att.

( J. E. Cross 'w/att. D. J. Kemppainen .w/stt",J File 12.15 J. G. Cesare w/att. 0, 0. Kingsley, Jr,-

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