ML20238C116

Safety Evaluation Supporting Schedular Exemption from GDC 54 & 55 Re MSIV Operability to Permit Fuel Load.Salp Input Also Encl

ML20238C116
Person / Time
Site:	Nine Mile Point
Issue date:	10/22/1986
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20238A944	List: IA-87-438, Forwards SER & SALP Input Re Util Request for Permission to Operate W/Wye Pattern Globe MSIVs W/O Leakage Control Sys Being Required.Wye Pattern Globe MSIVs Replaced ball-type Msivs.Request Granted ML20238A940 ML20238B200 ML20238C116 ML20238C133 ML20238C168 ML20238C198 ML20238C580 ML20238C643 ML20238C650 ML20238C693 ML20238C712 ML20238C720 ML20244D225 ML20244D227 ML20244D230 ML20244D463 ML20244D466 ML20244E235 ML20244E388 ML20244E403 ML20244E456 ML20245A561
References
FOIA-87-438 NUDOCS 8709090662
Download: ML20238C116 (3)

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ENCLOSURE 1 SAFETY EVALUATION BY THE OFFICE NUCLEAR REACTOR REGULATION NINE MILE POINT UNIT 2 MSIV OPERABILITY EXEMPTION REQUEST

1.0 INTRODUCTION

In a letter dated October 10, 1986 from C. V. Mangan to E. G. Adensam, the applicant requested a scheduler exemption to the requirements of GDC 54 and 55 with regard to main steam isolation valve (MSIV) operability. The requested exemption is to permit fuel loading and performance of those startup tests which can be conducted in Operational Conditions 4 and 5 (Cold Shutdown and

. Refueling). The applicant has reported that recent testing of the MSIV's has shown an inability of the valves to consistently close within the required time frame, and in some cases the valves have failed to close at all. In addition leak testing of the valves has indicated unacceptably high leakage rates. The proposeo exemption would permit fuel loading and some limited pre-criticality testing to be performed in parallel with efforts to resolve the MSIV problems.

2.0 EVALUATION The exemption requested by the applicant would permit only those operations which do not involve reactor criticality because it is restricted to Cold Shutdown and Refueling Mode testing. Since the fuel has never been irradiated and criticality will be prohibited, there will be virtually no fission products present. As a result. primary containment isolation for the i protection of the public is not required. However, secondary containment l' integrity is required by Technical Specifications for core alterations. This isolation will be provided by one refurbished leak tight MSIV in each main steam line (deactivated and in the closed position). Likewise because of l  !

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I the lack of fission products the risk of undue _ personnel exposure to those workers involved in MSIV repair or modification is negligible. Since the radiological risk to both' workers and the public is negligible for the i requested exemption, the scheduler exemption is acceptable, j f

3.0 CONCLUSION

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The applicant's request for scheduler exemption from GDC 54 and 55 with regard to MSIV operability to permit fuel loading and testing which can be perfonned in Operational Conditions 4 and 5 is acceptable because the fit,sion product

! inventory in the fuel is negligible and criticality is prohibited during this  ;

period and, therefore, there is negligible radiological risk to the public and to workers. Secondary containment integrity will be provided by a closed and deactivated MSIV in each main steam line.

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1 ENCLOSURE 2 Systematic Assessment of Licensee Performance

• Nine Mile Point Nuclear Station - Unit 2 i

Fur.ctional Areas

1. Nanagement involvement in assuring quality. ]

N/A i

2. Approach to resolution of technical issues from'a safety standpoint.

The licensee showed a general understanding of the technical issue and used acceptable approaches.

Rating: Category 2

3. Responsiveness to NRC Initiatives The licensee responded favorably to NRC initiatives.

Rating: Category 2

'4. Staffing (includingmanagement)

N/A

5. Reporting and analyses of reportable events N/A

6. Training and effectiveness and qualification N/A

7. Overall rating for functional area: 2

Reference:

NRC Manual Appendix 0516 - Systematic Assessment of Licensee Performance l l

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