View source for ST-HL-AE-3659, Forwards Response to Generic Ltr 90-06, Resolution of Generic Issue 70, 'Porv & Block Valve Reliability' & Generic Issue 94, 'Addl Low Temp Overpressure Protection for Lwrs.' License Amend Submitted on 901222 Re Generic Ltr

{{Adams
| number = ML20065T527
| issue date = 12/21/1990
| title = Forwards Response to Generic Ltr 90-06, Resolution of Generic Issue 70, 'Porv & Block Valve Reliability' & Generic Issue 94, 'Addl Low Temp Overpressure Protection for Lwrs.' License Amend Submitted on 901222 Re Generic Ltr
| author name = Rosen S
| author affiliation = HOUSTON LIGHTING &amp; POWER CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000498, 05000499
| license number = 
| contact person = 
| case reference number = REF-GTECI-070, REF-GTECI-094, REF-GTECI-NI, TASK-070, TASK-094, TASK-70, TASK-94, TASK-OR
| document report number = GL-90-06, GL-90-6, ST-HL-AE-3659, NUDOCS 9012280174
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 7
}}

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The Light company                                      PO llox 1700 llouston, he 77001 (715) :' m M it ilouston 1.ightingk Power December 21, 1990 ST llL AE 3659 File No.: 09.06, C20.01 10CTR$0.90 10CFR50.92 10CTR$0.54(f) l i
U. S. Nuclear Regulatory Conunission                                                            l Attention:      Document Control Desk                                                           l Washington, DC 20555                                                                            )
South Texas Project Elcetric Generating Station Units 1 6 2 Docket Nos. STN $0 498, STN $0 499 Response to Generic Latter 90 06

==Reference:==
(1) Letter ST llL AE 3642, dated December 22, 1990 from S. L.
Rosen (STPECS) to the USNRC Document Control Desk Attached is the response to Generic Letter 90 06, Resolution of Generic Issue 70, " Power Operated Relief Valve and Block Valve Reliability,"
and Generic Issue 94, " Additional Low Temperature Overpressure Protection for Light Water Reactors."
Pursuant to 10Cril50.54(f) the staf f requested that actions identified in Generic Letter GL 90 06 be taken by liccusees in order to increase plant safety and reliability. Implementation of the 10CPR50.54(f) request. requires lilAP to modify Technical Specifications 3/4.4.4 and 3/4.4.9.3.      Reference 1 proposes an Amendment to Operating Licenses NPF 76 and NPF 80 to change the Technical Specifications for the South Texas Project Electric Generating Station (STPEGS) Units 1 and 2.                  The proposed changes to the STPECS Technical Specifications incorporate the recommendations provided in Enclosure A and Enclosure B of Generic Letter 90 06.                    Implementation of these actions resolves Generic Issues 70 and 94 for STPEGS.
If you should have any questions concerning this matter, please contact Mr. A. W. liarrison at (512) 972 7298 or myself at ($12) 972 7138 S. L.'Rosen Vice President, Nuclear Engineering SDP/sgs Attachments:        1. Response to Generic Letter 90 06                              k(j
: 2. Proposed Technical Specification Changes (h \
A1/039.N19                  A Subsidiary of llouston Indmtries In00tpotated                k 9012280174 901221 PDR    ADOCK 05000498 p                       PDR

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  !                                                                                ST.HL AE.3659 Ilouston Lighting & Power Company                          File No.: 0 9. 06, C 2 0. 01            .
                    , South Teams Project Electric Generating Statiot.             Page 2-cc:
Regional Administrator, Region IV                   Rufus S. Scott Hucicar Regulatory Commission                       Associate General Counsel 611 Ryan Plaza Drive, Suite 1000                    llouston Lighting & Power Company Arlington, TX 76011                                 P. O. Box 61867 llouston, TX 77208 Ceorge Dick, Project Manager U.S. Nuclear Regulatory Commission                  INPO Washington, DC 20!55                                Records Center                                   .
1100 circle 75 Parkway J. I. Tapia                                         Atlanta, CA 30339 3064 Senior Resident inspector                                                                           "
c/o U. S. Nuclear Regulatory                        Dr. Joseph M. llendrie Commission                                         $0 Be11 port Lane P.-     O. Box 910                                  Be11 port, NY 11713 Bay City, TX 77414 D. R. Lacker J. R. Newman, Esquire                               Bureau of Radiation Control Newman & lloitzinger, P.C.                          Texas Department of llealth 1615 L Street,. N.W.                                1100 West 49th Street Washington, DC 20036                                Austin, TX 78756 3189 R. P. Verret/D. E. Ward Central Power & Light Company P. O. Box 2121 r                     Corpus Christi, TX 78403 l
J. C. Lanier/M. B. Lee City of Austin Elcetric Utility Department P.O. Box 1088 Austin, TX 78767 R. J. Costello/M. T. liardt City Public Service Board P. O. Box 1771 San Antonio, TX 78296 i
Revised 10/08/90 L4/NRC/

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i UNITED STATES OF AMERICA NUCLEAR REGUIATORY COMMISSION I           In the matter                             )                                        '
                                                      )
ilouston Lighting 6 Power                 )            Dock Nos. 50 498 Company,'et al.,-                         )                      50 499              ;
                                                      )
South Texas Project                       )
Units 1 and 2                             )
l; l
AFFIDAVIT S. L. Rosen being duly sworn, hereby deposes and says that he is
,          .Vice President, Nuclear Engineering of Houston Lighting 6 Power Cotopany; that
;.          he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached response to PRC Ceneric Letter 90 06; is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge and belief.
1 r
                                                                  .c -
S. L. Rosen Vice-President, Nuclear Engineering GTATE OF TEXAS )
                              )
                              )
Subscribedapdsworntobeforeme,aNotaryPublicinandfor-
           -The State of Texas thiad day of 2/cemkW/ , 1990.
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                          ,digey,,,, "' :                     Notary Puutio in and for tue
               " . gs,,,,/
                 <       -Mewnentanian.,f                     State f Texas                    ,
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1 A1/039.N19 i
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 ;             -                                                                                     Attachment 1 i
ST HL AE 3659 Page 1 of 4 RP.SPONSE TO GENERIC Lb"PTER 90-06 Generic Letter 90 06 provided resolution of Generic Issue 70,
* POWER OPERATED RELIEP VALVE AND BLOCK VALVE RELIABILITY," and Generic Issue 94, " ADDITIONAL LOW TEMPERATURE OVERPRESSURE PROTECTION POR LIGHT WATER REACTOR $".                              This Generic Letter requested that Licensees complete the actions identified in Section 3 of Enclosures A and B to enhance safety. Implementation of the requested actions resolves Generic Issues 70 and 94 for STPEGS.                                                !
,                                                                                                                                  1 Section 3 of Enclosure A to Generic Letter 90 06 provides actions which should be taken to improve tLe reliability of Power Operated Relief Valves (PORVs) and block valves. Tho specific actions and the HL&P response are provided below:
Action 1.
Include PORVs and blotk valves within the scope of an operational quality                               )
assurance program that is in compliance with 10 CIR 50. Appendix B. This program should include the following elements:
: a.       The addition of PORV.1 and block valves to the plant operational Quality Assurance Lint.

===Response===
The PORVs and block valves.are specified as safety class 1 valves and are included in the STPEGS Project Q List,
: b. ' Implementation of a maintenance / refurbishment program for PORVs and block valves that is based on the manufacturer's recommendations or guidelines and is implemented by trained plant maintenance personnel.
Response:                                                 ,
These valvea are included in the STPEGi meiutenance program which incorporates the manufactuier's guidelines and reconnendations. Required maintenance is specified in thu Grecial Equipment Qualification Maintenance Book (SEQHB) and is performed by trained maintenance personnel.
: c.       When repinecoent parts and spares, as well as complete components, are required for existing non safoty grado PORVs and block valves (and associated control systems), it is the intent of this generic letter that these items may be procured in accordance with the original construction codes and standards.

===Response===
The STPEGS PORVs and block valves are safety grade valves.                             Repincement parts, spares and components are procured in accordance with the original construction codes and standards.
A1/039,N10
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Attachment 1               l ST ill AE 36$9             j
]                                                                    Page 2 of 4                l 1                                                                                               i
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!                Action 2.                                                                      ;
Include PORVs, valves in PORV control air systems, and block valves            i within the scope of a program covered by subrection IWV,
* Inservice Testing of Valves in Nuclear Power Plants," of Section XI of the ASME          4 2
Boiler and Pressure Vessel code. Stroke testing of PORVs should only bc          ,
performed during Mode 3 (HOT STANDBY) or Mode 4 (110T SHUTDOWN) and in all     j cases prior to establishing conditions where the PORVs are used for            l low temperature overpressure protection. Stroke testing of the PORVs           l should not be performed during power operation. Additionally, the PORV         l block valves should be included in the licensees' expanded MOV test 4
program discussed in NRC Generic Letter 89 10, " Safety Related Motor Operated Valve Testing and Surveillance," dated June 28, 1989.

===Response===
The STPECS solenoid operated PORVs and block valves are included in the        ,
inservice Inspection (ISI) program which is covered by Subsection IWV of       j Section XI of the ASME code. Stroke testing of the PORVs will not be           !
[                performed during power operations. The conditions under which PORV             j stroke testing is performed are provided in Technleni Specification            '
Requirements 4.4.4.1.b 3.4.9.3.b, and 3.4.9.3.c (see Reference 1). The PORV block valves are included-in the STPECS expanded MOV test program.
Action 3.                                                                       '
For operating PWR plants, modify the limiting conditionts for operation of PORVs and block valves in the technical specifications for Modes 1. 2, and 3 to incorporate the position adopted by the str.ff in recent Ilcensing actions. Attachments A 1 through A 3 are provided for guidance. The staff recognizes that some recently licensed PWR plants already have technical specifications in accordance with the staff po-sition. Such plants are already in compliance with this position and need merely state that in their response. These recent technical speci*ications require that plants that run with the block valves closed (e.g., due to leaking PORVs) maintain electrical power to the block valves so they can be readily opened from the control room upon demand.
Additionally, plant operation in Modes 1, 2, and 3 with PORVs and block valves inoperable for reasons other than seat leakage is not permitted for periods of more than 72 hours.

===Response===
The guidance provided in Attachment A-1 through A 3 of the Generic Letter is incorporated in-the proposed revision to the STPECS Technical Specifications. The proposed Technical Specification changes which incorporate this guidance are given in Reference.1.
Section 3 of Enclosure B to Generic Letter 90 06 provides additional administrative restrictions on the Low Temperature Overpressure Protection (LTOP) system which improve the protection system availability. As stated in the Staff position, revision of the current Technical Specification for i        Overprotection Protection to reduce the A0T for a single channel in modes 5 1.
j        A1/039.N19

Attachment 1 ST.}lL. AE. 3659 Page 3 of 4 and 6 from 7 days to 24 hours provides additional assurance that plant operation is consistent with the design basis transient analysis.           In addition, the Staff has requested that administrative controls and procedures which are identified in Section 1 of Enclosure B to the Generic Letter and which are incorporated into the plant design basis should be implemented now 1R the teatrictions were not implemented as part of USI A 26.          These administrative controls and procedures shich were identified as part of Multi-Plant Action Item B 04 include the following items:
: 1. Minimize the time the reactor coolant system (RCS) is maintained in a water solid condition.
: 2. Restrict the number of high pressure pumps operable to no more than one when the RCS is in the LTOP condition.
: 3. Ensure that-the steam generator to RCS temperature difference is less than 50 Deg F when a reactor coolant pump (RCP) is bein6 started in a water solid RCS.
4    Set the PORV setpoint (if the particular plant relies on this 1                  component for LTOP) to a plant + specific analysis supported value, and have surveillance that checks the PORV actuation electronics and setpoint.

===Response===
The revised Technical Specification for the STPECS Cold Overpressure Mitigation System (COMS) is provided in Reference 1. This revised Technical Specification 3.4.9.3 reduces the A0T from 7 days to 24 hours as requested. The administrative controls and procedures discussed in Section 1 of Enclosure B of the Generic Letter are incorporated into the STPECS procedures as follows:
: 1. The time that the RCS is water solid is minimized by the STPECS plant operating procedures and administrative controls. The RCS is placed in a water solid condition only during cooldown and filling and venting operatiens. The need to minimize the time that the plant is maintained in a water solid condition will be included in operator training.
: 2. The current STPECS Technical Specifications allow only one liigh llead Safety Injection (511151) pump to be OPERABLE and a second lillS1 pump OPERABhE with its dreaker racked out in MODE 4 (ref. Technical specification LCO 3.u.3 1). All 111151 pumps are to be inoperabic in HODES 5 & 6 with the reactor vessel head on (ref. Technical Specification LCO 3.5.3.2). The current STPEGS Technical Specification requirements comply with the intent of item 2 of Multi-Plant Action item.
A1/039,N19 Y

At t achinent 1 i
ST l!L AE 3659 Page 4 of 4
: 3. The restriction on starting a RCP during water solid operations with the steam generator secondary side water temperature greater than 50*F above the RCS temperature is provided in the current STPECS Technical Specifications (ref. Technical Specification LCO 3.4.1.3).
: 4. The PORV setpoints are based on plant specific analysis which ensures compliance with the 10 CFR 50 Appendix G liroits. The surveillance requirements for the PORV actuation electronics and setpoints are provided in current Technical Specification Requirements 4.4.4.1.a.
4.4.9.3.1.a and 4.4.9.3.1.b.
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