View source for B12709, Comments on NRC 870902 Approval of Util 860930 & 870401 Requests for One Cycle Extension to Exemption from Single Failure Criterion That Had Been Granted on 860428.NRC Should Incorporate Comments in Future SER on Open Items Re HPSI

{{Adams
| number = ML20236C923
| issue date = 10/22/1987
| title = Comments on NRC 870902 Approval of Util 860930 & 870401 Requests for One Cycle Extension to Exemption from Single Failure Criterion That Had Been Granted on 860428.NRC Should Incorporate Comments in Future SER on Open Items Re HPSI
| author name = Mroczka E, Sears C
| author affiliation = CONNECTICUT YANKEE ATOMIC POWER CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF ADMINISTRATION &amp; RESOURCES MANAGEMENT (ARM)
| docket = 05000213
| license number = 
| contact person = 
| document report number = B12709, TAC-62974, NUDOCS 8710270401
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 4
| project = TAC:62974
| stage = Other
}}

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l CONNECTICUT YA KEE ATOMIC POWER COMPANY                                                         !
USNRC'DS                          B E R L I N, CONNECTICUT k                     P.O. BOX 270 HARTFORD. CONNECTICUT 06141-0270 mu>mne                                     _ October 22,1987 203-665-5000 Docket No. 50-213 B12709 Re: 10CFR50, Appendix A                                     i U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555

==Reference:==
(1)       D. M. Crutchfield letter to E. 3. Mroczka, " Extension of the Temporary Exemption from the Single Failure Criterion (GDC No. 35)," dated September 2,1987.                                                  ;
Gentlemen:
Haddam Neck Plant Comments on Extension of the                                                i Temporary Exemption from the Single Failure Criterion (TAC 62974)                              !
By letters dated September 30,1986(I) and April 1, 1987,(2) Connecticut Yankee Atomic Power Company (CYAPCO) requested a one cycie extension to the exempt,lon from the single failure criterion that had been granted on April 28, 1986.131 Reference (1) granted CYAPCO this extension to the exemption.
CYAPCO has reviewed this exemption and its associated safety evaluation report (SER) and has the following comments. CYAPCO requests that the NRC Staff incorporate these comments in a future SER on the open items pertaining to' the high pressure safety injection (HPSI) pump mini-flow modifications and gate valve flow throttling ability.
Exemption, Page 1, Paragraph 4 The last paragraph states: "The cross-tie connection between the RHR pump discharge and the HPSI pump suction will be accomplished by the addition of two eight inch lines, each with a separate motor-operated valve." CYAPCO has installed one eight inch cross-tie with a branch to each of the two HPSI pump (1)     3. F. Opeka letter to C. I. Grimes, "Small Break LOCA Permanent Resolution - Request for Extension of Single Failure Exemption," dated September 30,1986.
(2)     E. 3. Mroczka letter to NRC Document Control Desk, "ECCS Modifications Additional Information - Request for Extension of Single Failure Exemption," dated April 1,1987.
I (3)     F. 3. Miraglia letter to 3. F. Opeka, " Exemption from Single Failure                    AOO' Criterion (GDC 35) - Haddam Neck Plant," dated April 28,1986.                            El i O B710270401 071022 PDR       ADOCK 05000213

        . U. S. Nuclear Regulatory Commission                                                     i
           'Bi2709/Page 2 October 22,1987
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suctions.(4)' This design is' consistent with the Haddam Neck design philosophy of common piping connecting redundant components.
CYAPCO notes that the words " injection and" in the first sentence of the last       ''
i paragraph should be deleted. Only high pressure recirculation, not high pressure injection, will be accomplished by aligning the residual heat removal (RHR) injection pump discharge to the.HPSI pump suction piping. The injection path remains unchanged.
CYAPCO notes that the word " injection" should be replaced with " recirculation" in the second sentence of the last parag,raph. Although, the same wording is used in the' September 30, 1986 submittal,P) CYAPCO notes this change will avoid confusion with the injection phase.
          ' Exemption, Page 2, Paragraphs 1 and 2 The last sentence of the first paragraph states: " Consequently, CYAPCO should be able to . complete all piping and valve modifications during the Cycle 14        .
outage." CYAPCO suggests that the phase "with the exception of the mini-flow modifications" be inserted af ter the word " modification" in the above sentence.
Although the SER states that the mini-flow modifications will be completed in 1989, it is not clearly stated in the exemption.
The first sentence of the fourth paragraph states: "The staff has also concluded that;the only item preventing completion of this activity during the current
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outage .is the ability to provide a safety-related power supply to the new motor-operated vrives from existing power sources." For clarification, CYAPCO                 4 suggests that the phrase "(satisfying the single failure criterion)" be inserted          I af ter the word " activity." It is also suggested-that the following sentence be inserted af ter this first sentence: "In addition, the mini-flow modifications will be performed in conjunction with the electrical modifications."
SER, Page 3, Paragraph 3 Motor-operated valve (MOV) 845A in paragraph 3, item #1 should be MOV 854A.              )
CYAPCO suggests that the word " blocked" in paragraph 3, item #3 be deleted              j since the valve cannot be physically blocked by remote operator action.                  ]
SER, Page 4, Paragraph 4 CYAPCO suggests that the word " blocked" be deleted from the seventh sentence             l in paragraph four for the same reason as stated above.                                    ;
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(4)   E. 3. Mroczka letter to NRC Document Control Desk, dated April 1,1987, Attachment 1, page 1.
(5)   3. F. Opeka letter to       C. I. Grimes, dated September 30, 1987, Attachment 1, page 4.                                                               j i
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U. S. Nuclear Regulatory Commission B12709/Page 3
          . October 22,1987
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SER, Page 5, Paragraph 1                                                            ,
i CYAPCO suggests that the following sentence in the first paragraph,"CYAPCO,         l by {{letter dated|date=July 20, 1987|text=letter dated July 20, 1987}}, stated that prior to HPSI operation during           l recirculation, the LPSI pumps are to be breakered out," be replaced with            3 "CYAPCO, by' {{letter dated|date=July 20, 1987|text=letter dated July 20, 1987}}, stated that prior to HPSI operation
           .during recirculation, the LPSI pump control room switches will be placed in the trip / pull-out position." This more accurately describes how the pumps will be prevented from starting.
SER, Page 7, Paragraph 1 The first sentence states: "The newly installed MOVs, with the exception of         !
SI-MOV-873, will not be electrically connected following the Cycle 14 outage."      I This implies that SI-MOV-873 will be eng,rgized during Cycle 15 when it in fact will not be energized. On April 1,1987,W1 CYAPCO stated that this valve was         i not required for operation until the new modification is fully implemented. This    l valve is not required for use during Cycle 15 because th9 pethod presently in use   j for mitigating medium break loss of coolant accidentsW will remain in use for       l Cycle 15 operation. Specifically, FCV-796 will remain throttled to provide          !
adequate flow via the. core deluge and charging systems. Since this valve was       l not required for operation and electrically connecting it would have required       l removing an electrical load from the safety-related motor control center            {
(MCC5) in order to power this valve, it was decided not to electrically' connect this valve. However, it was necessary to install this valve this refueling outage since installation required a full core off-load.
SER, Page 8, Paragraph 3 Due to the flow rates referenced in this paragraph, it appears that the Staff is    )
concerned with the throttling ability of FCV-796. These flow rates are used to      : '
perform the flow testing for the present valve alignment.(8) CYAPCO believes that the NRC's concern is with the throttling ability of the gate valves and not    i FCV-796.       In order to clarify this paragraph, CYAPCO suggests that the         I following sentence, "This test is to assure that with a single pump running, the    ,
RHR pump flow is equal to 1500+ or -280 gpm," be replaced with "This test is to     j assure that with a single pump running, a gate valve (SI-V-871 A or B) could be used to throttle RHR pump flow such that flow to the core deluge provides adequate delivery (a minimum of 200 gpm with the RCS fully depressurized) without exceeding flows that could cause cavitation."
1 (6)    E. J. Mroczka letter to NRC Document Control Desk, dated April 1,1987,        :
Attachment 1, page 2.                                                       l (7)    Previously described to the NRC Staff by the following letters:
l                  E. 7. Mroczka letter to C. I. Grimes, dated December 17,1986.
E. 3. Mroczka letter to C. I. Grimes, dated December 19,1986.               J (S)     E. J. Mroczka letter to NRC Document Control Desk, dated June 1,1987, Attachment 1, page 4-4a.                                                    )
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* U. S. Nucl:ar Regulatory Commission
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             -B12709/Page 4
             . October 22,1987                                                                   .
Aside' from providing the above comments, CYAPCO would like to inform the            3 NRC Staff of its intention to submit a proposed revision to the Haddam Neck          l Technical Specifications.- This change would renumber the four manual throttle       i valves (SI-V-905, 906, 907, 908) installed in the HPSI injection line 3 and revise Technical Specification 3.6.B.2 to state . that the valves are positioned and        l verified whenever the core cooling system is required to be operable rather than     !
prior to start-up from cold shutdown (Mode 5).                                       !
We hope you find . this information ' satisfactory, and we remain available to answer any questions you may have.                                                   j i
Very truly'yours,                               j t
CONNECTICUT YANKEE ATOMIC POWER COMPANY         j J
E S, M E. 3. Mroczka         M Senior Vice President                           t 1
By: C. F. Sears                                 ,
Vice President                                  !
cc:    W. T. Russell, Region I Administrator F. M. Akstulewicz, NRC Project Manager, Haddam Neck Plant
: 3. T. Shedlosky, Resident inspector, Haddam Neck Plant                        t i
l I                                                                                                  )
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