ML030650255

Relief Request Review, Third 10-Year Pump and Valve Inservice Testing Program, Revision of Relief Request VRR-04

ML030650255
Person / Time
Site:	FitzPatrick
Issue date:	04/01/2003
From:	Richard Laufer NRC/NRR/DLPM/LPD1
To:	Kansler M Entergy Nuclear Operations
Vissing G, NRR/DLPM, 415-1441
References
TAC MB6901
Download: ML030650255 (8)

Text

April 1, 2003 Mr. Michael Kansler Senior Vice President and Chief Operating Officer Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

SUBJECT:

JAMES A. FITZPATRICK NUCLEAR POWER PLANT - THIRD 10-YEAR PUMP AND VALVE INSERVICE TESTING PROGRAM - REVISION OF RELIEF REQUEST VRR-04 (TAC NO. MB6901)

Dear Mr. Kansler:

By letter dated November 12, 2002, Entergy Nuclear Operations, Inc. (ENO) submitted a proposed revision to Relief Request VRR-04, under the third ten-year pump and valve inservice testing (IST) program for the James A. FitzPatrick Nuclear Power Plant (JAFNPP). VRR-04 was previously approved for the Third Interval IST Program and requires that check valves 23HPI-402 and 23HPI-403 will be exercised open and the pair (at least one valve) will be verified to close during cold shutdown and each refueling outage. The proposed revision (VRR-04R1) would delete the words during cold shutdown from the Alternate Testing identified in the relief request making this a refueling outage test only. The Alternate Testing cited in VRR-04 requires the installation of special test equipment such that, in practice, the tests are normally only performed during the extended duration of a refueling outage.

The Nuclear Regulatory Commission (NRC) staff has completed its review of the proposed relief request. The results are provided in the enclosed Safety Evaluation. Based on its review, the NRC staff concludes that ENOs compliance with the exercising tests required by Relief Request VRR-04 for check valves 23HPI-402 and 23HPI-403 would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. On this basis, the proposed alternative, described in VRR-04R1, is authorized for the James A.

FitzPatrick Plant pursuant to 10 CFR 50.55a(a)(3)(ii) for the third 10-year IST interval.

If you have any questions, please do not hesitate to call Mr. Guy S. Vissing, Senior Project Manager, at 301-415-1441.

Sincerely,

/RA/

Richard J. Laufer, Chief, Section 1 Project Directorate I Division of Licensing Project Managment Office of Nuclear Reactor Regulation Docket No. 50-333

Enclosure:

Safety Evaluation cc w/encl: See next page

April 1, 2003 Mr. Michael Kansler Senior Vice President and Chief Operating Officer Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

SUBJECT:

JAMES A. FITZPATRICK NUCLEAR POWER PLANT - THIRD 10-YEAR PUMP AND VALVE INSERVICE TESTING PROGRAM - REVISION OF RELIEF REQUEST VRR-04 (TAC NO. MB6901)

Dear Mr. Kansler:

By letter dated November 12, 2002, Entergy Nuclear Operations, Inc. (ENO) submitted a proposed revision to Relief Request VRR-04, under the third ten-year pump and valve inservice testing (IST) program for the James A. FitzPatrick Nuclear Power Plant (JAFNPP). VRR-04 was previously approved for the Third Interval IST Program and requires that check valves 23HPI-402 and 23HPI-403 will be exercised open and the pair (at least one valve) will be verified to close during cold shutdown and each refueling outage. The proposed revision (VRR-04R1) would delete the words during cold shutdown from the Alternate Testing identified in the relief request making this a refueling outage test only. The Alternate Testing cited in VRR-04 requires the installation of special test equipment such that, in practice, the tests are normally only performed during the extended duration of a refueling outage.

The Nuclear Regulatory Commission (NRC) staff has completed its review of the proposed relief request. The results are provided in the enclosed Safety Evaluation. Based on its review, the NRC staff concludes that ENOs compliance with the exercising tests required by Relief Request VRR-04 for check valves 23HPI-402 and 23HPI-403 would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. On this basis, the proposed alternative, described in VRR-04R1, is authorized for the James A.

FitzPatrick Plant pursuant to 10 CFR 50.55a(a)(3)(ii) for the third 10-year IST interval.

If you have any questions, please do not hesitate to call Mr. Guy S. Vissing, Senior Project Manager, at 301-415-1441.

Sincerely,

/RA/

Richard J. Laufer, Chief, Section 1 Project Directorate I Division of Licensing Project Managment Office of Nuclear Reactor Regulation Docket No. 50-333

Enclosure:

Safety Evaluation cc w/encl: See next page DISTRIBUTION:

PUBLIC RLaufer OGC SLittle PDI-1 Reading SRichards GHill (2 copies) GLmbro GVissing JStrnisha ACRS/ACNW BPlatchek, RGI ADAMS Accession Number: ML030650255

• SE transmitted by letter dated 01/29/03, no changes made

• • See previous concurrence OFFICE PDI-1/PM PDI-1/LA EMEB/SC* OGC** PDI-1/SC NAME GVissing SLittle DTerao RHoefling RLaufer DATE 4/1/03 3/31/03 01/29/2003 3/24/03 4/1/03 OFFICIAL RECORD COPY

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE INSERVICE TESTING PROGRAM, THIRD 10-YEAR INTERVAL ENTERGY NUCLEAR OPERATIONS, INC JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NUMBER 50-333

1.0 INTRODUCTION

By letter dated November 12, 2002, Entergy Nuclear Operations, Inc. (the licensee) requested Relief Request VRR-04R1 to test check valves 23HPI-402 and 23HPI-403 during each refueling outage only. The proposed relief request would be a revision to previously approved Relief Request VRR-04 (Reference 1) which required the testing of these valves in series during cold shutdown and each refueling outage.

2.0 REGULATORY EVALUATION

Title 10 of the Code of Federal Regulations (10 CFR), Section 50.55a, requires that inservice testing (IST) of certain American Society of Mechanical Engineers Boiler Pressure and Vessel Code (ASME Code) Class 1, 2, and 3 pumps and valves be performed at 120-month (10-year)

IST program intervals in accordance with a specified ASME Code and applicable addenda, except where alternatives have been authorized or relief has been requested by the licensee and granted by the NRC pursuant to paragraphs (a)(3)(i), (a)(3)(ii), or (f)(6)(i) of 10 CFR 50.55a. In accordance with 10 CFR 50.55a(f)(4)(ii), licensees are required to comply with the requirements of the latest edition and addenda of the ASME Code incorporated by reference in the regulations 12 months prior to the start of the 120-month IST program. James A. FitzPatricks third 10-year IST interval is based on the 1989 Edition of the ASME Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code). In proposing alternatives or requesting relief, the licensee must demonstrate that (1) the proposed alternatives provide an acceptable level of quality and safety, (2) compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety, or (3) conformance is impractical for the facility. Section 50.55a authorizes the NRC to approve alternatives and grant relief from ASME Code requirements upon making the necessary findings. NRC guidance in Generic Letter (GL) 89-04, Guidance on Developing Acceptable Inservice Testing Program, provides acceptable alternatives to the Code requirements.

Further guidance is given in GL 89-04, Supplement 1, and NUREG-1482, Guidelines for Inservice Testing at Nuclear Power Plants.

Enclosure

3.0 TECHNICAL EVALUATION

3.1 Code Requirements Relief Request VRR-04, approved for the third 10-year interval James A. Fitzpatrick Nuclear Power Plant (JAFNPP) IST Program (Reference 1), states that check valves 23HPI-402 and 23HPI-403 will be exercised open and the pair (at least one valve) will be verified to close during cold shutdown and each refueling outage.

3.2 Licensees Basis for Requesting Relief: As stated VRR-04, approved for the Third Interval JAFNPP IST Program, currently states that [the subject valves] will be exercised open and the pair (at least one valve) will be verified to close during cold shutdown and each refueling outage.... The Alternate Test cited in VRR-04 requires the installation of special test equipment such that in practice, the tests are normally only performed during the extended duration of a refueling outage, as permitted by applicable codes.

The proposed revision to VRR-04 deletes the words during cold shutdown from the Alternate Testing identified by the relief request, making this a refueling outage test. This change is consistent with the provisions of NUREG-1482, Guidelines for Inservice Tests at Nuclear Power Plants, Section 4.1.4, which identifies the need to set up test equipment as adequate justification for deferring testing of this type until a refueling outage.

3.3 Licensees Proposed Alternative to Code Testing Requirement: As stated Check valves 23HPI-402 and 23HPI-403 would be tested during each refueling outage.

3.4 Staff Evaluation Valves 23HPI-402 and 23HPI-403 are ASME Code Class 2, Category C, high-pressure coolant injection (HPCI) turbine exhaust line check valves. These valves open to eliminate any differential pressure that could force water from the suppression chamber into the HPCI exhaust piping when the suppression chamber pressure is greater than atmospheric. They close to prevent HPCI exhaust steam from entering the suppression chamber air space, thus bypassing the quenching action of the suppression pool. Approved Relief Request VRR-04 (Reference 1) stated that check valves 23HPI-402 and 23HPI-403 will be exercised open and the pair (at least one valve) will be verified to close during cold shutdown and each refueling outage. Testing of these check valves requires the installation and removal of test equipment that could delay plant startup. The ASME OM Code recognizes the limitations of performing testing during power operations and cold shutdown and allows testing to be performed during refueling outages for those valves which cannot be practically exercised otherwise. The position to allow deferral of testing to refueling outages when installation and removal of test equipment is needed is consistent with NRC staff guidelines in NUREG-1482, Section 4.1.4.

4.0 CONCLUSION

Based on its review of information provided by the licensee, the staff concludes that the licensees compliance with the Alternate Test cited in relief request VRR-04 for check valves 23HPI-402 and 23HPI-403 during cold shutdown would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. On this basis, the licensees proposed alternative, described in VRR-04R1, is authorized pursuant to 10 CFR 50.55a(a)(3)(ii) for the third 10-year IST interval for the JAFPNPP.

5.0 REFERENCE Letter from S. Bajwa, NRC to J. Knubel, James A. FitzPatrick Nuclear Power Plant -

Third Interval Inservice Testing Program and Relief Results, dated November 17, 1998.

Principal Contributor: J. Strnisha Date: April 1, 2003

FitzPatrick Nuclear Power Plant cc:

Mr. Jerry Yelverton Ms. Charlene D. Faison Chief Executive Officer Licensing Entergy Operations Entergy Nuclear Operations, Inc.

1340 Echelon Parkway 440 Hamilton Avenue Jackson, MS 39213 White Plains, NY 10601 Mr. Theodore H. Sullivan Supervisor Vice President Operations Town of Scriba Entergy Nuclear Operations, Inc. Route 8, Box 382 James A. FitzPatrick Nuclear Power Plant Oswego, NY 13126 P.O. Box 110 Lycoming, NY 13093 Charles Donaldson, Esquire Assistant Attorney General Mr. Dan Pace New York Department of Law Vice President, Engineering 120 Broadway Entergy Nuclear Operations, Inc. New York, NY 10271 440 Hamilton Avenue White Plains, NY 10601 Regional Administrator, Region I U.S. Nuclear Regulatory Commission Mr. John Kelly 475 Allendale Road Director - Licensing King of Prussia, PA 19406 Entergy Nuclear Operations, Inc.

440 Hamilton Avenue Oswego County Administrator White Plains, NY 10601 Jack Tierney 46 East Bridge Street Mr. George Tasick Oswego, New York 13126 Licensing Manager Entergy Nuclear Operations, Inc. Mr. William M. Flynn, President James A. FitzPatrick Nuclear Power Plant New York State Energy, Research, P.O. Box 110 and Development Authority Lycoming, NY 13093 17 Columbia Circle Albany, NY 12203-6399 Resident Inspectors Office U. S. Nuclear Regulatory Commission Mr. Arthur Zaremba, Licensing Manager P.O. Box 136 Director, Safety Assurance Lycoming, NY 13093 Entergy Nuclear Operations, Inc.

James A. FitzPatrick Nuclear Power Plant Mr. Harry P. Salmon, Jr. P.O. Box 110 Director of Oversight Lycoming, NY 13093 Entergy Nuclear Operations, Inc.

440 Hamilton Avenue Mr. Paul Eddy White Plains, NY 10601 Electric Division New York State Dept. of Public Service 3 Empire State Plaza, 10th Floor Albany, NY 12223

FitzPatrick Nuclear Power Plant cc:

Michael J. Colomb Mr. Tim Judson General Manager Organizer Entergy Nuclear Operations, Inc. Citizens Awareness Network James A. FitzPatrick Nuclear Power Plant 140 Bassett St.

P.O. Box 110 Syracuse, NY 13210 Lycoming, NY 13093 Deborah Katz Mr. James Knubel Executive Director Vice President, Operations Support Citizens Awareness Network Entergy Nuclear Operations, Inc. P.O. Box 83 440 Hamilton Avenue Shelburne Falls, MA 01370 White Plains, NY 10601 Shawn McConnell Mr. John M. Fulton NYPIRG Project Coordinator Assistant General Counsel 13 Hewitt Union Entergy Nuclear Generation Co. SUNY Oswego Pilgrim Station Oswego, NY 13126 600 Rocky Hill Road Plymouth, MA 02360 Tom Dellwo Oswego NYPIRG Environmental Mr. J. Spath, Program Director Project Leader New York State Energy, Research, and 13 Hewitt Union Development Authority SUNY Owego 17 Columbia Circle Oswego, NY 13126 Albany, NY 12203-6399 Mr. Ronald Schwartz SRC Consultant 64 Walnut Drive Spring Lake Heights, NJ 07762 Mr. Ronald J. Toole SRC Consultant Toole Insight 605 West Horner Street Ebensburg, PA 15931 Mr. Charles W. Hehl SRC Consultant Charles Hehl, Inc.

1486 Matthew Lane Pottstown, PA 19465