ML092320128
| ML092320128 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 08/10/2009 |
| From: | Bezilla M B FirstEnergy Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| GL-08-001, L-09-158, TAC MD7862 | |
| Download: ML092320128 (12) | |
Text
F.rtEnyN.O FirstEnergy Nucle"ar.Opera~tiil opny" ' : ' i.on~Perry Nuclear Power Station 10 Center Road Perry, Ohio 44081 Mark B. Bezilla Vice President'.
440-280-5382
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'.. -"
August 10, 2009 L-09-1 58f.10 CFR 50.54(f)ATTN: Document Control Desk.U; S.: Nuclear Regulatory Commission Washington, DC 20555-0001 Perry Nuclear Power Plant Docket, No. 507 4 4 0, License NO. NPF-58 , v ..'Ninhety Day Post-'Outage -Supplemental.
Response to Generic Letter 2008-01,."Mana&ing Gas Accumulation in Emrer-gency Core Cooling, Decay Heat Removal, and Containment Spray Systems" (.TAG ,ýNoý. MD7862):..', ;'. -.The Perry Nuclear PowerPlant,(PNPP) niine' rmonth response to Generic Letter "2008-01 was submitted by letter dated October 14, 2008 (Accession No. ML082980365)."The,:,,.
nine month response included a commitment to develop a summary of evaluations of those in-field piping verifications that had not yet been completed, and submit it within 90 days after the next refueling outage. The attachment to this letter provides the summary of those evaluations and any resultant corrective actions, along with updates to corrective actions that were identified in the nine month response.In summary, FirstEnergy Nuclear Operating Company has concluded that the applicable systems at PNPP are cpable, of performing, their intended safety function, and that,;PNPP is currently in compliance with 10 CFR 50 Appendix B, Criteria Ill, V, Xl, XVI and XVII, withi respect to the gais .ma-ng-emre'nt.oncer.ns in Generic Letter 2008-01.Thr'e are .no regulatory commitments -contained inmthis..submittal.
If-there are any qIuestions.or if additional information is required, please contact Mr. Thomas A. Lentz, Manager -Fleet Licen'sing, at (330)761-6071.
I declare'under penalty of perjury that the foregoing is true and correct. Executed on August i ,2009.Sincerely, Mark 7x§b 1/6/
Attachment:
Ninety Day Post-Outage Supplemental Response to Generic Letter 2008-01 cc: Nuclear Regulatory Commission (NRC) Region ll.1 Administrator
'- NRC-Resident'lnspector
- NRC Project Manager Attachment L-09-158 Ninety Day Post-Outage Supplemental Response to Generic Letter 2008-01 Page 1 of 11 This attachment provides the Perry Nuclear Power Plant (PNPP) 90 day post-outage supplemental response to Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," dated January 11, 2008. This supplements information provided in the nine month response dated October 14, 2008 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML082980365), and a subsequent submittal dated December 19, 2008 (ADAMS Accession No. ML090430426).
This submittal provides:* In Section A, a summary of the recently completed evaluations of those in-field piping verifications that had not yet been completed at the time of the nine month response, including information on revised void acceptance criteria, and corrective actions resulting from the new evaluations or from the new acceptance criteria" In Section B, updates to the corrective actions identified in the nine month response, and identification of other gas management-related corrective actions that have recently been generated and therefore have not yet been described in either the nine month response or the letter dated December 19, 2008 A. EVALUATION RESULTS 1) Acceptance Criteria Suction Pipincq At the time of the nine month response, the void acceptance criferia being utilized at PNPP for suction piping was the same regardless of the normal flow rate of the various Emergency Core Cooling System (ECCS) pumps, since each of the PNPP ECCS pumps operate at flow rates less than 140 percent of their best efficiency point (BEP). On June 18, 2009, the industry issued new recommendations for suction side void acceptance criteria, which included revised criteria for pumps that operate outside of specified bands around the BEP (see Nuclear Energy Institute (NEI) letter to the Nuclear Regulatory Commission (NRC) (ADAMS Accession No. ML091800416) and its enclosure (ADAMS Accession No. ML091800418)).
At PNPP, the Residual Heat Removal (RHR) and High Pressure Core Spray (HPCS) pumps rated flow rates are above the 120 percent BEP value that is included in the new recommendation, so the evaluations summarized in this letter utilized a modified void acceptance criterion.
Potential void pockets that were identified during the review of laser scans of the previously unevaluated piping segments were compared against a revised transient acceptance criterion of a 5 percent void fraction for five seconds (the nine month response discussed a transient criterion of a 10 percent void fraction for five seconds).
AY , ,I Attachment L-09-158 Page 2 of 11 However, as already noted. in the nine month response, if a void would not transport to the pump suction, the void fraction that could result from such a void does not need to be calculated.
The transportability of a void can be determined by calculations using Froude number analysis.
This methodology can be applied to determine if a void in the suction piping could be transported through the piping and down more than 20 feet in elevation to the pump suction, especially in low flow situations such as initial pump startup and operation in the minimum flow configuration.
The results of the current evaluations are summarized in Section A.2, below.The revision of the suction side acceptance criterion for pump flow rates above 120 percent BEP resulted in the need to review the potential suction side void locations that were previously evaluated and summarized in the letter dated December 19, 2008. That review was performed, and did not identify any previously evaluated potential gas accumulation locations where the transient void fraction transported to the pump suction could exceed 5 percent averaged over a five second interval.The revision of the suction side transient acceptance criterion also results in the need to update the safety-related calculation that documents the gas management criterion.
A corrective action has been created to revise the suction side transient criterion in the calculation.
Discharge Piping For discharge piping,.the nine month response and the letter dated.December 19, 2008, both noted that the interim acceptance criterion fot a void was 1.0 cubic foot, based on use of an industry-developed pressure pulsation methodology.
A corrective action had been created to formalize the criteria into appropriate design documentation.
Subsequent approval of the safety-related calculation using the described pressure pulsation methodology determined that the acceptable void for the Low Pressure Core Spray (LPCS) system was reduced to 0.9 cubic feet, while the acceptable void for RHR and HPCS was larger than previously assumed, at 4.7 cubic feet. Voids less than or equal to these values have been determined to be small enough to ensure that relief valves on the system will not be opened due to a pressure pulse. The results of the current evaluations are summarized in Section A.2, below.The revision of the discharge side acceptance criterion for LPCS from 1.0 to 0.9 cubic feet resulted in the need to review the potential discharge side void locations that were previously evaluated and summarized in the letter dated December 19, 2008. That review identified that the largest potential gas void previously identified in the LPCS discharge piping was 0.8 cubic feet, which is less than the new acceptance criterion.
The previous conclusion that this potential void would not represent an operability concern is still valid.
Attachment L-09-158 Page 3 of 11 2) Confirmatory In-Field Piping Verifications A laser scanning method was utilized to obtain information on previously unverified ECCS piping inside containment and the steam tunnel, using the same technique described in Section A, "Evaluation Results," of the letter dated December 19, 2008.The vendor who processed the data from the laser scans provided a Slope Report documenting the results. The Slope Report provides a nodal layout of the piping. The elevation of each node and the slope between nodes is tabulated.
As described in the December letter, potential voids with a volume greater than 0.1 cubic feet received specific evaluation.
Two potential areas where a void might accumulate were larger than the 0.1 cubic foot size. Both were in the RHR system, one on the suction side, and one on the discharge side of the pump.The suction side potential void location is in the RHR Shutdown Cooling suction header. The volume of a potential void upstream of the suction line outboard isolation valve 1 E12-F008 is 0.794 cubic feet, and the volume of a potential void downstream of valve 1 E12-F008 is 0.121 cubic feet. Gas that may accumulate in these locations is expected to be purged upon RHR Shutdown Cooling startup based on RHR system fluid velocities.
A conservative estimate of the size of this potential gas void results in a maximum void fraction of less than 4 percent at any point along the pipe. This void would result in an average void fraction at the pump inlet for any five second period of less than 2 percent, which is less than the transie'nt acceptance criterion for the RHR pumps of 5 percent in any five second period.The discharge side potential void location is in the RHR B system in a branch line off of the main flow stream. The potential void location is in a short section of 12 inch pipe, which could result in a volume of 2.12 cubic feet if the pipe is not properly vented. This potential void is smaller than the 4.7 cubic foot acceptance criteria for the discharge side of the RHR subsystems, and therefore is also not a GL 2008-01 gas management concern.3) Vents, Procedure Changes, or Other Corrective Actions Due to Evaluations No new vent valves, procedure changes, or other corrective actions were necessary as a result of the above-described evaluations of the previously uncompleted laser scans, since each of the evaluated potential void locations was determined to be within the revised void fraction acceptance criteria.One new corrective action resulted from the revision of the acceptance criteria.As discussed above, the corrective action is to revise the official void fraction Attachment L-09-158 Page 4 of 11 acceptance criteria calculation to incorporate the revised suction side transient void limits discussed in the NEI letter dated June 18, 2009.B. UPDATES TO PREVIOUS CORRECTIVE ACTIONS, AND NEW ACTIONS 1) Updates to Previously Described Actions A number of corrective actions listed in the nine month response were already complete at the time the response was submitted.
Those completed items are not repeated herein.A 2004 Condition Report investigation had identified the need to install additional vent valves. The vent valve modifications that were not yet complete at the time of the nine month response were completed during the spring 2009 refueling outage. The following list identifies the vent valve installations completed during the 2009 refueling outage that are within the scope of the GL 2008-01 review (three other vent valves were installed in a system outside the scope of the GL):* Feedwater Leakage Control System Division 2 upstream of the high/low pressure isolation valve.* HPCS suction piping (Quantity 2)* RHR 16-Inch cross-tie piping to LPCS* RHR 18-Inch piping downstream of the Shutdown Cooling suction (Quantity 2)* HPCS waterleg discharge piping.Necessary Actions to Achieve Full Compliance Necessary actions to achieve full compliance with the regulations were listed in Table 1 of the nine month response.
The Table is updated below. The sections identified in the Table are from the nine month response.TABLE I Findings Identified During the Section 2a Design Basis Document Review.Summary of Finding #1: The 24" RHR C suction header is -horizontal before reaching suppression pool isolation valve 1E12-F0105.
The piping in this segment is nearly completely vented by vent holes in the suppression pool side piping from the ECCS suction strainer.
Gas in the bonnet of this gate valve will likely stay in the bonnet. The small quantity of gas transported to the pump would be over an extended period of time. Downstream of this valve the line drops approximately 7 feet where it enters a 24 inch tee and follows horizontal pipe sections prior to entering the RHR C pump suction flange. The piping at the opposite end of the 24 inch tee is cross connected to the RHR Shutdown Cooling suction path through the normally closed isolation gate valve Attachment L-09-158 Page 5 of 11 1E12-F0067.
Significant air accumulation in the short 24" x 18" riser (approximately 6 feet) at the outlet of this isolation valve as well as the isolation valve bonnet can be readily vented by opening this valve during fill and vent operations in the RHR System Operating Instruction SOI-E12.Revise Surveillance Instruction SVI-E12-T1 182C, "RHR C LPCI Valve Lineup Verification And System Venting" to perform quarterly ultrasonic test (UT) inspections on 18 inch piping immediately below valve 1E12-F0067 to confirm piping is sufficiently water filled.Current Status: Implemented.
No air has been detected during this quarterly UT inspection.
Findings Identified During the Section 2b Acceptance Criteria Review 2. Summary of Finding #2: Instrument Maintenance Instruction IMI-E2-42, "Filling And Venting Suppression Pool Level Instrument Lines," provides instructions for filling and venting the suppression pool level instrument lines and instruments.
The HPCS level transmitters addressed by this procedure are associated with the functionality of HPCS.The procedure requires the venting of air from the suppression pool E22 transmitters, instrument lines, or the system but does not specify any acceptance criteria for quantities of air vented or water drained from the system or vent/drain time requirements.
This corrective action was created to formally establish acceptance criteria for IMI-E2-42 in terms of venting times or quantities-of water drained.Current Status: Addressed in a manner determined to be more appropriate than establishing an acceptance criterion in a procedure that only applies to one type of instrument line. Instead, Maintenance Administrative Instruction MAI-0504, "Plant -Instrument Calibration and Maintenance," was revised to include an acceptance criterion that addresses venting from instrument linis regardless of which system is*being vented. The specified acceptance criterion associated with the venting of instruments was intended to reflect a low tolerance for gas -if gas is released for more than one second, a Condition Report is required to be generated to document, trend, and evaluate the discovery of gas in instrumentation lines (a Condition Report was written on July 27, 2009, to re-evaluate the adequacy of this acceptance criterion for instrument lines). A separate change has also been made to MAI-0504 to include a two minute vent duration after a solid stream of water has been achieved.3. Summary of Finding1 #3: ECCS injection lines inboard of the closed isolation valve are normally only vented during a system fill and vent. Since the systems are filled under ambient conditions, degassing may occur following startup and heatup associated with normal operation.
This Action was created to obtain an ultrasonic (UT) examination of the ECCS injection lines to confirm that several months (6 or greater) after a fill and vent of the system that the lines remain sufficiently filled during normal plant operation.
Notifications were created to perform the requested UT examinations.
Document results of UT inspections on ECCS injection line high points between injection isolation valves and the reactor vessel, for RHR A, B and C, LPCS, and HPCS.Current Status: These UT inspections were performed on October 23, 2008. No voiding was identified.
This was a one-time check for information, since the Scope section of the nine month response noted that voiding in these lines between the Attachment L-09-158 Page 6 of 11 injection valve and the reactor vessel is not a concern.Findings Identified During the Section 2d Fill and Vent Review 4. Summary of Finding #4: Instrument Maintenance Instruction IMI-E6-3, "Fill And Vent For 'E' Systems," currently does not specify any acceptance criteria for quantities of air vented from the system or venting time requirements.
The acceptance criteria shall be established and incorporated into IMI-E6-3.Current Status: Similar to the discussion for Finding #2 above, changes were made to MAI-0504, "Plant Instrument Calibration and Maintenance." The MAI was determined to be the appropriate location for instrument venting guidance.5. Summary of.Finding
- 5: Incorporate post-maintenance verification techniques to validate that systems are sufficiently full of water following fill and vent, based on quantification of a remaining gas void. Unvented gas that'remains after an initial system fill and vent is quantified and justified.
Current Status: This was implemented in an alternative manner. Design and procedure changes were implemented to provide assurance that following an initial system fill and vent, there will not be a remaining gas Void significant enough to need quantification and justification.
New vents have been added in susceptible locations, and procedures now require 1) a minimum vent duration of two minutes after achieving a solid stream of water during venting of plant systems and instrumentation, and 2) additional venting after keep-fill systems are switched from the high pressure (approximately 120 psig) alternate keep-fill system to the normal (approximately 35, psig) keep-fill pumps due to the drop in system pressure that occurs from the switch.Findings !d6ntified During the Section 2e Gas Intrusion Review 6. Summary of Finding #6: Engineering Change Packages (ECPs) 05-0123-001 and 05-0123-002 will install vent valves on high points downstream of isolation valves 1E12-FO06A and B. Limited head from the suppression pool is available at these locations; therefore venting sequences at these new locations will need to ensure that any air that may be trapped at the vent high point is adequately vented. To accomplish this, a minimum volume of water to be drained through the vent shall be specified.
Compute the required venting time to ensure that any trapped air in the vent high point will be purged during the venting operation, and implement the venting requirement into the applicable procedures.
Current Status: Minimum volume of water and vent time were determined to be 0.75 gallons in one minute. The two minute minimum venting time that has been added to procedures is more than adequate to ensure that the valve 1 E1 2-F623 A and B vent lines are sufficiently filled with water.Findings Identified During the Section 3 Testing Evaluation
- 7. Summary of Finding #7: Acceptance Criteria in the ECCS venting surveillance instructions (SVIs) use general nomenclature such as, "If excessive air was vented, generate a Condition Report to evaluate past operability and surveillance frequency." A definition of "excessive air" is not provided and it is left to the test performer to
-, I' 4 Attachment L-09-158 Page 7 of 11 determine whether excessive air is vented. The procedures also do not provide a method to record the quantity of air vented from the system. Quantitative acceptance criteria need to be specified.
Develop the acceptance criteria and implement the acceptance criteria and method for recording and trending results into the respective ECCS SVIs.Current Status: Acceptance criteria for the ECCS venting surveillance procedures has been developed and incorporated into these procedures, including venting durations (a minimum of two minutes after a clear stream has been obtained) and quantities of gas (no more than one second before a solid stream is obtained).
- 8. Summary of Finding #8: As part of the evaluations associated with Generic Letter 2008-01, a review of the PNPP SVIs associated with venting ECCS flow lines was performed.
It was determined that adequate measures are not in place to quantify and track any air accumulation released during the venting process.Current Status: This finding was determined to be redundant to the other identified corrective actions, and was closed in the Corrective Action Program by referring to the other corrective actions, such as Finding #7 above.9. Summary of Finding #9: The minimum flow requirement through the recirculation line for the LPCS water leg pump is about 10 gpm. This flow rate creates a fluid velocity of approximately one foot per second, which is marginal for sweeping air out of the horizontal suction piping near the flow element. Since the flow rate in the line is less than desired to ensure removal of air, an alternate means of verifying that the line is sufficiently filled with water is required.
Revise SVI-E21-T1 181 to add a quarterly UT inspection on horizontal piping between flow element 1E21-N0656 and the elbow to confirm piping is sufficiently water filled.Current Status: Implemented.
No air has been detected during thisquarterly UT inspection.
- 10. Summary of Finding #10: Section 5.3.4.4 of ANSI N18.7 states that procedures for monitoring performance of plant systems shall be required to ensure that engineered safety features and emergency equipment are in a state of readiness to maintain the plant in a safe condition if needed. This Action was created to revise each of the ECCS SVI venting procedures (El 2-Ti 182A/B/C, E21 -T1 181 and E22-Tl 183) to document and trend (monitor) results from the venting operations obtained during the performance of the venting surveillances.
Current Status: The listed procedures have been revised to require trending and resolution of air observed during periodic venting evolutions through use of the Corrective Action Program by removing the phrase "excessive air" and replacing it with a requirement to write a Condition Report if more than one second of air is observed during a vent.
Attachment L-09-158 Page 8 of 11 Enhancement Actions Enhancement actions were listed in Table 2 of the nine month response.
The Table is updated below. These items were recommended to improve management of gas accumulation.
Because current practices have been determined to be effective at maintaining system operability with respect to voids, and none of these actions are required for compliance with existing regulatory requirements, these actions are considered enhancements.
TABLE 2 Findings Identified During the Section 1 Licensing Basis Evaluation 1 Summary of Findingq # 1: The PNPP Updated Safety -Analysis Report (USAR)discussions are considered to be acceptable, but some additional information should be added. The concept of performance-based periodic verifications on the suction side piping should be acknowledged in the USAR. The description of these performance-based periodic checks should note that if voiding is identified, potentially damaging air/gas is removed, similar to the existing USAR discussion for the discharge side fill and vent process. Because new licensing basis information is established upon completion of the NRC's review of GL 2008-01, the schedule for completion of this action will be 120 days following NRC closure of the GL 2008-01 review.Current Status: As noted in the Finding, the schedule for completion of this action is 120 days following NRC closure of the GL 2008-01 review.Findings Identified During the Section 2a Design Basis Document Review 2. Summary of Finding #2: When an ECCS is operating with return flow to the suppression pool, the system is vulnerable to drain back of system inventory into the suppression pool should pump operation be interrupted.
A water hammer will not occur following a loss of offsite power (LOOP) event for either the RHR A or B pumps when operating in the suppression pool cooling mode because the operating pump will trip on loss of AC power and will not automatically re-start without manual actions. The venting sequences in the post-trip procedures do not currently include the 1E12-F400A/B vent valves located at the Containment Spray/upper pool cooling riser high points. An action was generated to implement mitigating actions in System Operating Instruction SOI-E12 and Off-Normal Instructions ONI-SPI-A3 and ONI-SPI-B3 to ensure that an RHR pump is not manually re-started if the pump stops while in the suppression pool cooling mode, prior to performing a high point fill and vent through valves 1E12-F400A and B.Current Status: SOI-E12 contains a Precaution and Limitation (P&L) that the RHR system must be filled and vented prior to starting a pump. The P&L specifically identifies a loss of pumping power when in the suppression pool cooling line-up as an event that could cause voiding, and requires a fill and vent of the RHR system. SOI-E12 includes requirements to vent through valves 1 E12-F400A and B.Off-Normal Instructions ONI-SPI A-3 and ONIkSPI B-3 were updated to add the requirement to vent from valves 1 El 2-F400A and B.
1 11 Y~3;~-: ~......................
Attachment L-09-158 Page 9 of 11 Findings Identified During the Section 2b Acceptance Criteria Review 3. Summary.of Finding #3: Add a P&L or a step into section 7.13.3 in SOI-E12 to warn against opening the injection line high point vent in Modes 1, 2 and 3. Opening these vent valves in Mode 1, 2 and 3 may void the piping., Current Status: A Caution was added to Section 7.13.3 stating that the potential exists to drain the injection piping if pressure is allowed to drop to 0 psig while depressurizing the injection header.4. Summary of Finding #4: Develop a calculation to formally document the void acceptance criteria for the ECCS systems. The discharge piping calculation will focus on the Fauske pulsation methodology, and will discuss the GE Hitachi Nuclear Energy criteria for delay time due to voids. The suction side will address the continuous, long-term void fraction of 2 percent or less, and a transient, short-term void fraction of no greater than a 10 percent void fraction during-any 5 second period.Current Status: A calculation was approved in February 2009 based on industry guidance available at the time, including the pulsation methodology and the 10 percent transient void fraction.
As described in Section A of this letter, a Condition Report has been written noting that this calculation needs to be revised to reflect current industry guidance in the June 18, 2009 NEI letter on the transient void acceptance criteria for the suction side of the applicable systems.2) Recently Identified Corrective Actions Due to the corrective actions listed above to generate a Condition Report if air is observed for longer than one. second, and to vent for at least two minutes after a solid stream is observed, several Condition Reports have been written and several corrective actions have been generated that were not already discussed in either the nine month response or the supplemental response dated December 19, 2008. The corrective actions that resulted from these Condition Reports are summarized in Table 3 below.TABLE 3 1. Summary of Finding #1: To align with the NEI proposed best venting practice, a minimum venting duration shall be implemented into the ECCS venting SVIs and SOIs.The ECCS SOIs and venting SVIs shall be revised to require a minimum vent duration of two minutes after a solid stream of fluid has been achieved.
As an alternate, Operations Administrative Instruction OAI-0502, "Preparation Of Operating Instructions" may be modified to include the recommended generic instructions for venting operations.
Current Status: Procedure OAI-0502 has been revised to incorporate the two minute minimum vent duration for Operations Section venting activities.
- 2. Summary of Finding #2: As an NEI best practice, the requirement to vent for two minutes after a solid stream has been achieved shall be included for all instrumentation venting operations.
This can be achieved as a general requirement in MAI-0504.
Attachment L-09-158 Page 10 of 11 Current Status: Procedure MAI-0504 has been revised to incorporate the two minute minimum vent duration for instrumentation venting activities.
- 3. Summary of Finding #3: Venting instructions shall be implemented into SVI-E22-T1 183,"HPCS Valve Lineup Verification And System Venting," that require a minimum vent duration of two minutes after achieving a solid stream of fluid.Current Status: Surveillance Instruction SVI-E22-T1 183 has been revised to incorporate the two minute minimum vent duration.4. Summary of Finding #4: Revise RHR System Operating Instruction SOI-E12 to: 1. Vent the water leg keep fill line (vent valve 1 El 2-F0571) as part of the initial system fill and vent.2. Initiate an RHR system run following startup of the keep fill system.3. Vent system high points that are not impacted by the system run in step 2 above.Current Status: System Operating Instruction SOI-E12 has been revised to include the additional specified venting and a 10 minute run of the RHR subsystem to ensure gas is fully removed from the system.5. Summary of Finding #5: Add a note into SOI-E12 Section 7.1.2 step 11 to state that the suppression pool level must be greater than 18 feet to successfully complete the venting.Current Status: The evolution that led to this finding occurred during a refueling outage when a vent was being performed per post-maintenance testing guidance rather than per the System Operating Instruction (SOl). The SO did not require revision because it already contains appropriate information for filling and venting the RHR system using a method that does not depend on suppression pool level to successfully complete the vent.Therefore, this action was not necessary and was closed.6. Summary of Finding #6: As an interim action until RHR heat exchanger B vent valve 1 E12-F0074B can be repaired, revise SOI-E12 to include a high point vent of the RHR B heat exchanger following a fill and vent of the shutdown cooling header.Current Status: Implemented.
- 7. Summary of Finding #7: Complete repair and post-maintenance test on valve 1 El 2-F0074B.Current Status: Scheduled due date is Refueling Outage 13 in the spring of 2011.
Attachment L-09-158 Page 11 of 11 8. Summary of Finding #8: Evaluate the results of the next performance (June 2009) of surveillance instruction SVI-E21"-T1181, and if air is observed during venting activities, initiate a plan of action. This plan, based on the significance of any air observed, could range from do nothing to increased venting frequency and establishment of a rigorous problem solving team in accordance with the "Problem Solving and Decision Making" procedure.
Current Status: During the June 2009 surveillance instruction (SVI) performance, no significant air (greater than one second) was observed.
An air free stream of water was achieved from each vent line indicating that the system is sufficiently filled with water to fulfill the LPCS design functions.
This observation supports the previous conclusion that the air observed during the May, 2009 performance of SVI-E21-T1 181 was due to maintenance activities during the recent refueling outage.9. Summary of Finding #9: Complete a revision or alteration to Calculation GEN-019 to incorporate the revised pump suction acceptance criteria per the recent NEI guidance.Current Status: Due date is October 21, 2009.10. Summary of Finding #10: Implement a revision to SOI-E22A that will add another vent of the HPCS high points following the HPCS pump run in Section 7.4. The pump run in SOI-E22A is performed as part of step 7.4.24. The additional high point vents should be added after the HPCS pump is stopped and the minimum flow valve (1 E22F0012) has been verified to be closed.Current Status: Implemented.
CONCLUSION
- In summary, the applicable systems, including the- previously unevaluated portions, have been evaluated and determined to be capable of performing their intended safety function, and for PNPP, FirstEnergy Nuclear Operating Company (FENOC) is currently in compliance with 10 CFR 50 Appendix B, Criteria Ill, V, XI, XVI and XVII, with respect to the gas management concerns outlined in GL 2008-01.