ML13303B242
| ML13303B242 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 09/24/1990 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML13303B241 | List: |
| References | |
| NUDOCS 9010150226 | |
| Download: ML13303B242 (8) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 ENCLOSURE 1 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE INSERVICE TESTING PROGRAM AND REQUESTS FOR RELIEF SAN ONOFRE NUCLEAR GENERATING STATION, UNIT NOS. 2 AND 3 DOCKET NOS. 50-361 AND 50-362
1.0 INTRODUCTION
The Code~qf Federal Regulations, 10 CFR 50.55a(g), requires that inservice testing (IST) of ASME Code Class 1, 2, and 3 pumps and valves be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable addenda, except where specific written relief has been requested by the licensee and granted by the Commission pursuant to 10 CFR 50.55a(a)(3)(i),
(a)(3)(ii), or (g)(6)(i). In 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 or safety; or (3) the conformance with certain requirements of the applicable Code edition and addenda is impractical for its facility.
The Regulation, 10 CFR 50.55a(a)(3)(i), (a)(3)(ii), and (g)(6)(i), authorizes the Commission to grant relief from these requirements upon making the necessary findings. The NRC staff's findings with respect to granting or not granting the relief requested as part of the licensee's IST Program are contained in the Safety Evaluation (SE) issued on the licensee's program.
The IST program addressed in this report covers the first ten-year inspection interval for both Units 2 and 3 from August 18, 1983 to August 18, 1993. The licensee's program through Revision 14 for Unit 2 and Revision 9 for Unit 3, submitted in a letter dated May 18, 1990, was reviewed for this report.
The program is based on the requirements of Section XI of the ASME Code, 1977 Edition through the Summer 1979 Addenda.
2.0 EVALUATION The IST program and the requests for relief from the requirements of Section XI have been reviewed by the staff with the assistance of its contractor, EG&G Idaho, Inc. (EG&G). In addition, EG&G and staff members met with licensee representatives on January 6 and 7, 1988, in a working session to discuss questions resulting from the review. The Technical Evaluation Report (TER) (enclosed) is EG&G's evaluation of the licensee's inservice testing program and relief requests. The staff has reviewed the TER and concurs with its evaluations and conclusions. A summary of the pump and valve relief request determinations is presented in Table 1. The granting of relief is based upon the fulfillment of commitments made by the licensee in its basis for each relief request and the alternative proposed testing.
DR ADOCK 05000361 P
-2 Two relief requests were denied (TER Sections 3.1.3.1 and 3.3.1.1); two relief requests were partially denied (TER Sections 4.2.2.2 and 4.2.2.3); five relief requests were granted with certain conditions (TER Sections 4.1.2.1, 4.1.3.1, 4.2.1.1, 4.5.1.1, and 4.6.1.1); and three relief requests were approved on an interim basis (TER Sections 3.2.3.1, 4.2.2.4, and 4.3.1.1). The licensee should refer to the specific TER section for a detailed discussion of these cases. Denials and conditions are listed in the TER Appendix C, which also lists other IST program anomalies identified during the review.
The Commission anticipates that the licensee will resolve all items listed in Appendix C within the cited time limits in accordance with staff guidance, specifically: (a) program/procedural changes covered by items 1, 2, 3, 5, and 8 -
16, within six months of receipt of this SER; (b) item 4, by the next refueling outage; and (c) item 6, within one year of receipt of this SER or the next refueling outage, whichever is longer. Item 7 should be actively pursued, and if an alternate testing method is developed, the affected relief requests should be revised or withdrawn.
3.0 CONCLUSION
Based on the review of the licensee's IST program relief requests, the staff concludes that the relief requests as evaluated and modified by this SER will provide reasonable assurance of the operational readiness of the pumps and valves to perform their safety related functions. The staff has determined that granting relief, pursuant to 10 CFR 50.55(a)(3)(i), (a)(3)(ii) and (g)(6)(i), is authorized by law and will not endanger life or property, or the common defense and security and is otherwise in the public interest. In making this determination, the staff has considered the alternate testing being implemented, compliance resulting in a hardship without a compensating increase in safety, and the impracticality of performing the required testing, considering the burden if the requirements were imposed. The last column of Table 1 identifies the regulation under which the requested relief is granted.
During the review of the licensee's inservice testing program, the staff has identified certain misinterpretations or omissions of Code requirements. These items are summarized in the TER, Appendix C. The IST program relief requests for San Onofre Nuclear Generating Station, Unit Nos. 2 and 3, through a submittal dated May 18, 1990, is acceptable for implementation provided that the items above are corrected promptly. New or revised relief requests contained in any subsequent revisions may not be implemented without prior approval by NRC, unless they are relief requests meeting the positions in Generic Letter 89-04,.
Page No.
1 09/02/90 SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 SER TABLE 1
SUMMARY
OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY NUMBER
& SUBJECT TESTING USNRC P-04 3.1.1.1 IWP-3400 All pumps.
Perform pump testiong Relief granted.
Test pumps quarterly.
(a)(3)(ii) monthly.
P-07 3.1.2.1 IWP-4320 All pumps.
None.
Relief granted.
Measure (a)(3)(ii) temperature of fluid being pumped.
P-01 3.1.3.1 IWP-3230(b)
All pumps.
Perform analysis to Relief denied.
Declare pump determine if pump inoperable if should be declared test quantity inoperable.
is in the required action range of Table IWP-3100-2.
P-06 3.2.1.1 IWP-4120 Various flow Use currently Relief granted.
Instrument and pressure installed (a)(3)(i) full scale instruments instrumentation for range for auxiliary pump testing.
requirements. feedwater, component cooling water, salt water cooling, and charging pumps.
P-03 3.2.2.1 IWP-3100 Diesel fuel Waive bearing Relief granted.
Measure oil transfer temperature (a)(3)(ii) bearing pumps: P093, measurement temperatures. P094, P095, requirements since P096 these pumps are Saltwater submerged and the cooling pumps: bearings are P112, P113, inaccessible.
P114, P307.
'iage No.
2 09/02/90 SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 SER TABLE 1
SUMMARY
OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY NUMBER
& SUBJECT TESTING USNRC P-05 3.2.3.1 IWP-3100 Containment Test pumps in fixed Relief granted Measure spray pumps:
resistance flowpath for LPIS and flowrate P012, P013 with no flow rated containment during pump Diesel fuel measurement.
spray pumps testing.
oil pumps:
provided P093, P094, compliance with P095, P096 GL 89-04, Auxiliary Item 9.
feedwater Interim relief pumps: P140, granted for P141 auxiliary Low pressure feedwater and safety diesel fuel oil injection pumps.
pumps: P015, (g)(6)(i)
P016.
-08 3.3.1.1 IWP-4500 Centrifugal Measure vibration Relief denied.
Measure charging velocity vibration pumps: P190, instrumentation amplitude.
P191, and currently in use and P192.
apply the acceptance criteria of OM-6.
V-24 4.1.1.1 IWV-3412(a)
All valves.
Terminate cold Relief granted.
Full-stroke shutdown testing (a)(3)(ii) exercise when plant is ready valves during to return to power, cold defer remaining shutdowns testing to next cold when testing shutdown.
cannnot be done quarterly.
Page No.
3 09/02/90 SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 SER TABLE 1
SUMMARY
OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY NUMBER
& SUBJECT TESTING USNRC V-16 4.1.2.1 IWV-3417(a)
All Declare valves Relief granted Stroke time rapid-acting inoperable when provided the trending and valves.
stroke time excedds licensee's corrective maximum value of testing action five seconds.
conforms to requirements staff approved for power alternative operated outlined in GL valves.
89-04, Item 6.
(g)(6)(i)
V-23 4.1.3.1 IWV-3417(a)
All power Compare stroke times Relief granted Stroke time operated to average value provided trending and valves.
since last reference corrective maintenance or last values of action three stroke times, stroke time are requirements whichever is established for power greater.
when the valves operated are known to be valves.
in good operating condition.
(a)(3)(i)
V-11 4.2.1.1 IWV-3522 Safety Disassembly and Relief granted Exercise injection tank inspection on a provided quarterly.
discharge sampling basis at a licensee check valves:
refueling outage performs a 12-040-A-551, frequency.
partial flow 12-041-A-551, test of the 12-042-A-551, disassembled 12-043-A-551.
valves before they are returned to service and part-stroke exercises all valves during cold shutdowns.
(g)(6)(i)
Page No.
4 o09/02/90 SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 SER TABLE 1
SUMMARY
OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION
.REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY NUMBER
& SUBJECT TESTING USNRC V-08 4.2.2.1 IWV-3522 High pressure Part-stroke exercise Relief granted.
Exercise safety quarterly, (g)(6)(i) quarterly.
injection full-stroke exerdise pumps suction at a refueling check valves: outage frequency.
10-006-C-675, 10-008-C-675.
V-12 4.2.2.2 IWV-3522 Low pressure Part-stroke exercise Relief granted Exercise safety quarterly, to part-stroke quarterly.
injection disassembly and exercise pumps suction inspection on a quarterly check valves:
sampling basis at a provided the 16-077-C-645, refueling outage valves are 16-084-C-645, frequency.
full-stroke 16-199-C-645, exercised with 16-201-C-645.
flow during refueling outages.
(g)(6)(i)
Relief denied for disassembly and inspection.
V-02 4.2.2.3 IWV-3522 Safety Disassembly and Relief granted Exercise injection and inspection on a to part-stroke quarterly.
containment sampling basis at a exercise spray pumps refueling outage quarterly combined frequency.
provided the suction checks valves are from the full-stroke refueling exercised with water tank:
flow during 24-001-C-724, refueling 24-002-C-724.
outages.
(g)(6)(i)
Relief denied for disassembly and inspection.
Page No.
5 09/02/90 SAN ON0FRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 SER TABLE 1
SUMMARY
OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY NUMBER
& SUBJECT TESTING USNRC V-03 4.2.2.4 IWV-3522 Containment Disassembly and Interim relief Exercise sump outlet inspection on a granted.
quarterly.
check valves: sampling basis ata (g)(6)(i) 24-003-C-724, refueling outage 24-004-C-724. frequency.
V-13 4.3.1.1 IWV-3522 Inside Disassembly and Interim relief Exercise containment inspection on a granted.
quarterly.
spray header sampling basis at a (g)(6)(i) check valves: refueling outage 8-004-C-406, frequency.
8-006-C-406.
V-14 4.4.1.1 IWV-3522 Charging Verify valve closure Relief granted.
Exercise header inside capability at a (a)(3)(ii) quarterly.
containment refueling outage isolation frequency.
check valve:
2-122-C-554.
V-18 4.5.1.1 IWV-3522 Turbine driven Disassembly and Relief granted Exercise auxiliary inspection to verify provided the quarterly.
feedwater pump closure capability licensee steam supply on a sampling basis part-stroke check valves: at a refueling exercises the 4-003-D-620, outage frequency.
valves to the 4-005-D-620.
open position with flow after reassembly.
(g)(6)(i)
V-20 4.6.1.1 IWV-3522 Main feedwater Disassembly and Relief granted Exercise supply check inspection to verify provided the quarterly.
- valves, closure capability licensee 20-036-C-609, on a sampling basis part-stroke 20-129-C-609. at a refueling exercises the outage frequency.
valves to the open position with flow after reassembly.
(g)(6)(i)
.Page No.
6 09/02/90 SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 SER TABLE 1
SUMMARY
OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY NUMBER
& SUBJECT TESTING USNRC V-19 4.7.1.1 IWV-3412 Containment Full-stroke exercise Relief not Exercise normal purge when system is required.
quarterly.
supply and placed in servid.,
exhaust (refueling outages &
valves:
cold shutdowns when HV-9948, 9949, containment 9950, 9951.
integrity is required).