L-91-236, Forwards Rev 3 to JNS-PSL-203, Second 10-Yr Inservice Insp Interval Inservice Testing Program for Pumps & Valves,St Lucie Nuclear Power Plant Unit 1, Per Generic Ltr 89-04
| ML17309A662 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 10/23/1991 |
| From: | Sager D FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML17223B294 | List: |
| References | |
| GL-89-04, GL-89-4, L-91-236, NUDOCS 9111010080 | |
| Download: ML17309A662 (18) | |
Text
ACCELERATED DIS UTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9111010080 DOC.DATE: 91/10/23 NOTARIZED: NO DOCKET FACIL:50-335 St. Lucie Plant, Unit 1, Florida Power
& Light Co.
05000335 AUTH.NAME AUTHOR AFFILIATION SAGER,D.A.
Florida Power
& Light Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Forwards Rev 1 to JNS-PSL-203, "Second 10-Yr Inservice Insp Interval Inservice Testing Program for Pumps
& Valves,St Lucie Nuclear Power Plant Unit 1," per Generic Ltr 89-04.
DISTRIBUTION CODE:
A047D COPIES RECEIVED:LTR f ENCL g SIZE:
+ /W TITLE: OR Submittal: Inservice Inspection/Testing/Relief from ASME Code NOTES:
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P.O. Box 128, rt. Pierce, FL 34954-0128
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October 23, 1991 L-91-236 10 CFR 50.4 U.
S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.
C.
20555 Gentlemen:
RE:
St. Lucie Unit 1 Docket No. 50-335 Generic Letter 89-04 Second Ten-Year Inservice Inspection Interval Inservice Testin Pro ram Revision 3
Generic Letter (GL) 89-04 "Guidance on Developing Acceptable Inservice Testing Programs,"
issued by the NRC on April 3,
- 1989, requested that certain licensees (1) review their most recently submitted Inservice Testing (IST)
Programs and implementation procedures against the positions delineated in Attachment 1 of the GL, and (2) confirm in writing their conformance to the stated positions.
By Letter dated January 3,
1990 (L-90-03), Florida Power and Light Company (FPL) submitted a
response to the GL positions and submitted the revised ST. Lucie Unit 1 IST Program.
On October 17
- 1990, the NRC issued an interim Safety Evaluation Report (SER).
The SER provided interim approval for the IST program and relief requests, however, it denied certain relief requests related to valve testing.
FPL has reviewed the interim SER and has modified the St. Lucie IST Program or provided additional information to support the relief requests that were denied.
Some of the relief requests contain issues that are industry wide and concern check valve full flow testing and/or inspections.
FPL requests a meeting at the staff's earliest convenience to discuss the open relief requests.
FPL requests an extension of the interim relief granted by NRC letter dated October 17, 1990 until the NRC completes its detailed review.
In addition, FPL requests that interim relief be granted on the new relief requests identified in Attachment 1 until the NRC completes its review of the requests.
9iii0i0080'9i'i023 PDR ADoclc 0500033S l
I I
St. Lucie Unit 1 Docket No. 50-335 Generic Letter 89-04 Inservice Testin Pro ram Revision Attachment 1 provides a summary of the changes to the IST Program.
Attachment 2 provides the revised St. Lucie Unit 1 IST Program.
Please contact us if there are any questions about this submittal.
Very truly yours, D. A.
ager Vice P esident St.
ie Plant DAS/GRM/kw cc:
Stewart D. Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, St. Lucie Plant DAS/PSL 75510-91
4
St. Lucie Unit 1 Docket No. 50-335 Generic Letter 89-04 Second Ten-Year Inservice Inspection Interval Inservice Testin Pro ram Revision 3
99111010080 ATTACHMENT 1
SUMMARY
OF RELIEF RE UEST CHANGES Ref.:
NRC Letter (Herbert N.
Berkow to J.H.
Goldberg) dated October 17, 1990 In the referenced letter dated October 17,
- 1990, the Staff evaluated the requests for relief included with the St Lucie, Unit 1 Inservice Testing Program Plan submittal of December 12, 1989.
In response to this evaluation FPL has amended the Program or provided additional information in support of the relief requests.
The changes are summarized below:
r Relief Re uest No. VR-4 In many instances testing of pumps and valves places a system in a configuration such that it cannot adequately respond to an emergency situation and, thus, it can be considered to be unavailable or in an inoperable status for the duration of the test.
This request for relief was intended to eliminat;e the need for intentionally causing both trains of a safety system to,be placed in inoperable status as a result of testing.
FPL considers such action to be imprudent and inconsistent with good plant operating practice.
Although we disagree with the NRC position, FPL has withdrawn this relief request in order to close this item.
Relief Re uest No. VR-5 This relief request is revised to provide additional information requested by the Staff.
Relief Re uest No. VR-12 This relief request is revised to provide additional information requested by the Staff.
Relief Re uest Nos.
VR-12 13 and 19 FPL shares the concerns of the NRC with respect to the risks associated with routine and unnecessary disassembly of check valves as a substitute for testing.
Disassembly of many these valves requires configuring the plant for mid-loop cooling operation which is not a desirable plant condition.
We are also concerned with the significant'.
personnel exposure associated with these inspections.
In this regard we have reviewed the operating and maintenance history of these valves and similar valves used throughout the industry under like conditions.
Based on these reviews, there is no evidence of any generic problem of valve degradation with respect to the, ability of these valves to open and satisfactorily pass the required flow. It is apparent from the failure data that the primary mode of failure is related to valve leakage both past the seat and external through the body-bonnet joint.
Indeed several of the later failures are attributable to poor maintenance practices during reassembly following inspection or maintenance activities.
Furthermore, we agree with the NRC statement that "check valve disassembly is a valuable maintenance tool that can provide a great deal of information about a valve's internal condition and as such should be performed under the maintenance program at a frequency commensurate with the valve type and service."
In this light, FPL considers the frequency of once each refueling outage (4 valves from each group every 6 years) as set forth in the generic letter to be excessive for these valves and, by this letter, resubmits revised relief requests to extend this inspection interval to once every 10 years for all check valves with no minimum refueling outages quota requirement.
With respect to the issue of non-intrusive diagnostic techniques to demonstrate valve operability, FPL actively participates in the efforts of the Nuclear Industry Check Valve Group and their efforts to evaluate and develop appropriate methods and technology.
- However, we feel at the present time these methods are not yet proven nor ready for routine implementation in the field.
As they become available, we will evaluate them for timely implementation at St. Lucie.
Relief Re uest Nos.
VR-14 With respect to the issue of non-intrusive diagnostic techniques to demonstrate valve operability, FPL actively participates in the efforts of the Nuclear Industry Check Valve Group and their efforts to evaluate and develop appropriate methods and technology.
- However, we feel at the present time these methods are not yet proven nor ready for routine implementation in the field particularly in this case where the temperatures are high and valve closure verification is required..
As methods may become available to apply to this
- case, we will evaluate them for timely implementation at St. Lucie.
Partial-flow testing of these valves is not necessarily applicable since there is no safety significance of these valves to open.
Upon plant startup these valves necessarily open to allow the passage of steam to the main turbine generator and its auxiliaries.
I
Relief Re uest Nos.
VR-17 With respect to the issue of non-intrusive diagnostic techniques to demonstrate valve operability, FPL actively participates in the efforts of the Nuclear Industry Check Valve Group and their efforts to evaluate and develop appropriate methods and technology.
- However, we feel at the present time these methods are not yet proven nor ready for routine implementation in the field.
As they become available, we will evaluate them for timely implementation at St. Lucie.
This relief request has been amended to include a requirement for post-reassembly exercising.
Relief Re uest No. VR-20 This relief'equest has been amended to provide additional information related to the impracticality of flow exercising and non-obtrusive testing.
Relief Re uest Nos.
VR-22 29 30 and 31 The valves associated with these relief requests are.full-stroke exercised
- however, due to the absence of appropriate instrumentation flow measurements are not available.
FPL is evaluating non-intrusive techniques for measuring flow and, if these methods prove to be practical, these relief requests will be withdrawn or revised, as appropriate.
Relief Re uest No. VR-24 This relief request is revised-as requested by the Staff and resubmitted for consideration.
Relief Re uest No. VR-26 FPL has reviewed the installation of these valves and it has been determined that there is no practical means of accurately determining the stroke time as required by IWV-3413A for these valves.
We note again that these are "totally" enclosed solenoid valves with no remote or local position indicating capability.
Compliance with the NRC request to stroke time these valves would require replacement of these valves with a suitable replacement having position indicating capability.
Since these valves have been installed since plant startup with a satisfactory operating record we feel system backfit to satisfy this requirement is unwarranted at this time. It is therefore requested that your office reconsider this relief request (amended) for approval.
Relief Re uest No. VR-33 This relief request is withdrawn.
Relief Re uest No. VR-35 FPL maintains the position that measuring the stroke time of these valves is impractical each quarter due to the transient placed on the Turbine Cooling Water System.
This relief request has been amended to provide additional information and is submitted for further consideration.
In addition to the relief requests addressed by the referenced letter dated October 17, 1990, St. Lucie has modified or added to Appendix B, the Pump Program Relief Requests as follows:
Relief Re uest No. PR-1 NEW This request addressed the yearly requirement for measuring bearing temperatures on centrifugal pumps in the program.
The request was included in the original submittal (3 Jan 1990) and was approved.
In its original form, the relief request inadvertently omitted reciprocating pumps.
The relief request is modified to add reciprocating pumps to the exemption from the yearly bearing temperature measurement requirement (IWP-3300
& 4310).
The Code requirements for bearing temperatures on pumps make little differential between centrifugal and reciprocation pumps.
The only distinction made in the Code is the temperature measurement locations on each type of pump; thus the exemption is equally valid for reciprocating as well as centrifugal pumps.
Relief Re uest No.
PR-7 NEW There are three paths available for flow from the Diesel Oil Transfer Pumps.
None of the flow paths have flow instrumentation; therefore, St. Lucie is unable to comply with IWP-4600 and requests relief.
In order to comply with IWP-3100 of the
- Code, flowrate is measured by calculating the transfer rate between the Diesel Oil Storage Tanks.
Tank levels are measured at the beginning and at the end of the test and are then equated into tank volumes.
A difference in volume is calculated and then divided by the time interval to end up with the pump flowrate.
Relief Re uest PR-9 and HPSI Pum 1C NEW The 1C HPSI Pump has been permanently removed from service by PC/M 028-190.
The 1C HPSI Pump has been removed from this relief request.
Relief Re uests PR-12 and PR-13 NEW The frequency response range of the readout system (for instruments used to measure vibration amplitude) shall be from one-half minimum speed to at least maximum pump shaft rotational speed (IWP-4520(b)).
In two cases slow speed pumps are installed at St Lucie and the resulting required lower
frequency response limit is 'verly restrictive or unattainable.
Specifically, the Reactor Coolant Charging Pumps operate at approximately 210-215 rpm which equates to a rotational frequency of 1.75 Hz.
Following an extensive investigation of available and potentially suitable instrumentation, it has been determined that instruments satisfying this requirement for the charging pumps are commercially unavailable.
The second case is the Intake Cooling Water pumps which operate at 885 rpm (7.38 Hz).
In this case there are commercially available instruments for these measurements however they are significantly more complex and cumbersome than those currently used at the plant site.
The vibration instruments in use at St. Lucie have a low frequency response (3dB) of approximately 10 Hz and are reliable and easy to use.
The impact of procuring instruments along with the accompanying re-training that would be required is clearly unwarranted at this time simply to gain a slightly better frequency response.
The final updates to the program are in Appendix C, Valve Program Tables.
Several of the changes are related to the relief requests addressed in the referenced letter dated October 17, 1990.
In response to those
- changes, the Valve Program Tables are amended accordingly.
V-2426 and V-2436 8770-G-078 SH 121 NEW These valves have been removed from the Chemical and Volume Control System and has therefore been removed from the program.
V-3101" 8770-G-078 SH 130 NEW Test frequency listed in original submittal was a
typographical error.
The correct test frequency should be
>tQRn not tt 2A>t ~
V-3102 and V-3405 NEW These valves have been removed from the program due to the 1C HPSI Pump being removed from service by PC/M 028-190.
Valve reliefs VR-29 and VR-9 have been updated to reflect the removal of the valves from the program.
H J
MV-08-1A and MV-08-1B 8770-G-079 SH 1
NEW The original test frequency of cold shutdown for exam "EC" was incorrectly listed.
The test frequency is and has been quarterly for these valves.
V-08117 and V-08148 8770-G-079 SH 1
NEW The exam listed for these, check valves has been changed from a back flow test to disassembly and inspection each refueling outage.
Refer to relief request VR-14.
V-08448 and V-08492 8770-G-079 SH 1
NEW The exam listed for these check valves has been changed from a back flow test to disassembly and inspection each refueling outage.
Refer to relief request VR-36.
Pl V-09248 and V-09280 8770-G-079 SH 1
NEW The exam listed for these check valves has been changed from a back flow test to disassembly and inspection each refueling outage.
Refer to relief request VR-38.
SB-21165 and SB-21211 8770-G-082 SH 1
NEW These manual valves have no active safety function and are deleted.
FCV-21-3A and FCV-21-3B 8770-G-082 SH 2
NEW Remote valve position checks every 2 years have been added to the valve exams.
i V-21005 and V-21010 8770-G-082 SH 2
NEW The quarterly back flow test for these valves has been deleted.
The safety function to prevent back flow would be better served by the individual check valves in the lube water lines feeding each pump.
The back flow test will be added to these valves'xam lists.
V-21044 V-21046 V-21058 and V-21060 8770-G-082 SH 2
NEW The back flow tests that have been deleted above from V-21005 and V-21010 have been added to these valves'ist of exams and will be performed quarterly.
V-21030 and V-21032 8770-G-082 SH 2
NEW The 1A Intake Cooling Water Pump has recently been modified to have self lubricating bearings.
These valves and the associated piping have been disconnected from the pump and blank flagged.
These valves no longer are required to fulfill any safety requirement, therefore they can be dropped from the program.
The other Intake Cooling Water Pumps will also undergo a similar modification in the future.
As these modifications are completed, the Program will be revised accordingly.
0
SB-14156 SB-14160 SB-14166 SB-14167 SB-14169 SB-14177 SB-14178 and SB-14439 8770-G-083 SH 1
NEW These manual valves have no active safety function and are deleted.'V-18-1 8770-G-085 SH 2
NEW The testing frequency is being increased from cold shutdown to quarterly.
V-18279 and V-18283 8770-G-085 SH 2
NEW The testing frequency is being decreased from every cold shutdown to one every, refueling outage.
See relief request VR-37.
MV-07-2A and MV-07-2B 8770-G-088 SH 1
NEW The testing frequency is being increased from cold shutdown to quarterly.