ML14191A659

Forwards SE Granting Relief from IST Requirements.Review Supersedes Interim Relief Granted in

ML14191A659
Person / Time
Site:	Robinson
Issue date:	09/16/1992
From:	Mozafari B Office of Nuclear Reactor Regulation
To:	Watson R CAROLINA POWER & LIGHT CO.
Shared Package
ML14188B145	List: ML14191A659 ML14191A661
References
TAC-M81309, NUDOCS 9209240285
Download: ML14191A659 (22)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 September 16, 1992 Docket No. 50-261 Mr. R. A. Watson Senior Vice President Nuclear Generation Carolina Power & Light Company P. 0. Box 1551 Raleigh, NC 27602

SUBJECT:

SAFETY EVALUATION OF THE INSERVICE TESTING (IST) PROGRAM RELIEF REQUESTS, H. B. ROBINSON, UNIT NO. 2 (TAC NO. M81309)

By letter dated August 1, 1991, Carolina Power & Light Company (CP&L or the licensee) submitted the Inservice Testing (1ST) Program for the third ten-year interval at the H. B. Robinson Steam Electric Plant, Unit No. 2 (HBR2).

The licensee's submittal superseded all previous IST program submittals. The third interval commenced February 19, 1992, and is scheduled to end February 18, 2002.

(The licensee's August 1, 1991, transmittal letter contained a typographical error indicating February 21, 2002, as the end of the third interval.)

The NRC staff has reviewed and evaluated the relief requests contained in the submittal.

This review supersedes the interim relief granted by the NRC in a letter dated June 1, 1992.

Title 10 of the Code of Federal Regulations, paragraph 50.55a(g) requires that certain American Society of Mechanical Engineers (ASME) Code Class 1, 2, and 3 pumps and valves in light water-cooled nuclear power facilities meet the IST requirements stated in the ASME Boiler and Pressure Vessel Code,Section XI; specifically, Subsection IWP, IST of Pumps in Nuclear Power Plants, and Subsection IWV, IST of Valves in Nuclear Power Plants.

Each facility is required to establish a program for the IST of pumps and valves which is updated every ten years to meet the requirements in the latest approved Edition and Addenda to Section XI of the ASME Code. The program is submitted to the NRC for review and approval of the relief requests. The review entails verifying that the program is based on the applicable Code Edition and Addenda, and verifying the acceptability of the requests for relief from the requirements of Subsections IWP and IWV.

The NRC with technical assistance from Idaho National Engineering Laboratory, EG&G Idaho Inc. (EG&G), has reviewed and evaluated the requests for relief submitted for HBR2. As explained in the enclosed Safety Evaluation (SE), the NRC adopts the evaluations and conclusions contained in the Technical Evaluation Report (TER) prepared by EG&G (EGG-NTA-10099, dated March 1992),

except as noted in SE Sections 2.1, 2.2, and 2.3.

9L 0

-2 Certain relief requests have been denied where proposed alternative testing is unacceptable or where an adequate basis for the relief request has not been provided. These denials were reported to you in a letter from the NRC dated June 1, 1992.

We have reviewed and evaluated the remaining IST program relief requests and have determined that the remaining 1ST program relief requests are acceptable for implementation provided the items identified in Appendix B of the TER are addressed. The licensee should refer to the TER, Appendix B, for a discussion of 1ST program action items identified during the review. All the items in Appendix B should be resolved in accordance with the guidance therein.

Actions taken to resolve the Appendix B items must be completed within one year of the date of this letter, or by the end of the next refueling outage, whichever is later.

For those relief requests that have been denied, the testing is to be in compliance with Code requirements or GL 89-04 by the end of the first quarter following the date of this letter. Any revised relief requests addressing relief denials should be submitted within the first quarter after the date of this letter.

The NRC is granting relief from the testing requirements which we determined to be impractical to perform, where compliance would result in a hardship without a compensating increase in safety, or where the proposed alternative testing provides an acceptable level of quality and safety. The NRC staff has determined that granting relief, pursuant to 10 CFR 50.55a(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 giving due consideration to the burden upon CP&L that could result if the ASME Code requirements were imposed on the facility.

Compliance is required with the IST program defined in your letter of August 1, 1991, in cases where relief is being granted in the enclosed SE.

Program changes such as additional relief requests or changes to relief requests should be submitted for review and should not be implemented prior to review and approval by the NRC.

New or revised relief requests meeting the positions in Generic Letter (GL) 89-04, Enclosure 1, should be submitted to the NRC for information, but can be implemented provided the guidance in GL 89-04, Section D, is followed. Program changes that involve additions or deletions of components from the IST program should be provided to the NRC.

The NRC performs audits/inspections of licensees' IST programs. Therefore, the review performed for the TER does not include verification that all pumps and valves within the scope of 10 CFR 50.55a and ASME Code Section XI are contained in the IST program. Additionally, for the components included in the IST program, no determination is made to ensure all applicable testing requirements are identified. Therefore, the licensee is requested to provide the NRC with a description of how you have assured yourselves that you have identified and correctly categorized all pumps and valves. This can be accomplished by briefly summarizing the process used in developing the IST program. The submittal should include, as a minimum, details of the documents used, the method of determining if a component requires inservice testing, the

September 16, 1992

-3 basis for the testing required, the basis for categorizing valves, and the method or process used for maintaining the program current with design modifications or other activities performed under 10 CFR 50.59. If a description of this process is not already available from existing documentation, the staff envisions that this request could be answered in two to four pages. It could be incorporated into the IST program in appropriate sections. The information should be included with the licensee's response to the anomalies presented in Appendix B of the TER. The schedule for the response is outlined in the evaluation section of the SE.

This completes our review of the IST Program relief requests under TAC No. 81309.

The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OMB clearance is not required under P. L.96-511.

Sincerely, ORIGINAL SIGNED BY:

Brenda Mozafari, Project Manager Project Directorate II-1 Division of Reactor Projects -

I/II Office of Nuclear Reactor Regulation cc: See next page DISTRIBUTION:

See next page

• See previous concurrence LA:PD21: E"

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PAnderson a a:JNorberg JHull

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///92 07/15/92 08/14/92 nPD:PD21:w EAdensam Document Name:

ROB81309.LTR

-4 During the review of the licensee's inservice testing program, the NRC has identified certain misinterpretations or omissions of Code requirements.

These items are summarized in the TER Appendix B. Except for those relief requests that were denied, the IST program relief requests for HBR2 provided by the submittal dated August 1, 1991, are acceptable for implementation provided that the changes and actions described in Appendix B are completed in accordance with the schedule set forth in the cover letter.

Principal Contributor: K. Dempsey Date:

Mr. R. A. Watson H. B. Robinson Steam Electric Carolina Power & Light Company Plant, Unit No.2 cc:

Mr. H. Ray Starling Mr. Dayne H. Brown, Director Manager -

Legal Department Department of Environmental, Carolina Power & Light Company Health and Natural Resources P. 0. Box 1551 Division of Radiation Protection Raleigh, North Carolina 21602 P. 0. Box 21687 Raleigh, North Carolina 27611-7687 Mr. H. A. Cole Special Deputy Attorney General Mr. Robert P. Gruber State of North Carolina Executive Director P. 0. Box 629 Public Staff -

NCUC Raleigh, North Carolina 27602 P. 0. Box 29520 Raleigh, North Carolina 27626-0520 U.S. Nuclear Regulatory Commission Mr. C. R. Dietz Resident Inspector's Office Vice President H. B. Robinson Steam Electric Plant Robinson Nuclear Department Route 5, Box 413 H. B. Robinson Steam Electric Plant Hartsville, South Carolina 29550 P. 0. Box 790 Reginal dminstrtorRegin ~Hartsville, South Carolina 29550 Regional Administrator, Region II U.S. Nuclear Regulatory Commission Mr. Heyward G. Shealy, Chief 101 Marietta Street Bureau of Radiological Health Suite 2900 South Carolina Department of Health Atlanta, Georgia 30323 and Environmental Control 2600 Bull Street Mr. Ray H. Chambers, Jr.

Columbia, South Carolina 29201 General Manager H. B. Robinson Steam Electric Plant Mr. R. B. Starkey P.O. Box 790 Vice President Hartsville, South Carolina 29550 Nuclear Services Department Carolina Power & Light Company P.O. Box 1551 Raleigh, North Carolina 27602

44 DISTRIBUTION:

Docket File NRC and local PDRs Robinson Reading File S. Varga G. Lainas E. Adensam B. Mozafari P. Anderson J. Norberg K. Dempsey OGC ACRS (10)

L. Reyes, RII

t ptREQ0,4 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE INSERVICE TESTING PROGRAM AND REQUESTS FOR RELIEF CAROLINA POWER & LIGHT COMPANY H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261

1.0 INTRODUCTION

The Code of Federal Regulations, 10 CFR 50.55a(g), requires that inservice testing (IST) of certain American Society of Mechanical Engineers (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 Subsections (a)(3)(i), (a)(3)(ii), or (g)(6)(i) of 10 CFR 50.55a. 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 and safety; or (3) compliance with applicable provisions of the ASME Code is impractical for the facility.

These regulations authorize the Commission to grant relief from ASME Code 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 Inservice Testing (IST) Program are contained in this Safety Evaluation (SE).

The IST program addressed in the SE covers the third ten-year inspection interval from February 19, 1992, to February 18, 2002. The licensee's program, which is described in a letter dated August 1, 1991, supersedes all previous submittals. The licensee's program is based on the requirements of Section XI of the ASME Code, 1986 Edition.

2.0 EVALUATION The licensee's requests for relief from the requirements of Section XI of the ASME Code have been reviewed by the NRC staff with the assistance of contractors, EG&G Idaho, Inc. (EG&G).

The Technical Evaluation Report (TER) provided as an attachment to this SE, EGG-NTA-10099, is EG&G's evaluation of the licensee's relief requests. The staff has reviewed the TER and concurs with the evaluations and conclusions therein except as noted below in sections 2.1, 2.2, and 2.3. A summary of the pump and valve relief request determinations is presented in Table 1 of this SE. The granting of relief is based upon fulfillment of any commitments made by the licensee in its basis for each relief request and the proposed alternative testing.

-2 2.1 Relief Request GVRR-1 The licensee requested relief (TER Section 3.1.1.1) from the leak testing requirements of Section XI of the ASME Code, Paragraph IWV-3420, for the containment isolation valves served by the isolation valve seal water system (IVSW). As an alternative, the licensee proposed to test the valves in accordance with 10 CFR 50, Appendix J and HBR2 Technical Specifications. The NRC SE, dated April 23, 1979, concluded that it is acceptable to use the IVSW to conduct Appendix J, Type C tests on the valves served by that system. The IVSW is designed to pressurize containment penetrations higher than containment design pressure, so that leakage would be from the penetrations into the containment. With this type of design, the testing of these valves as part of IVSW in accordance with the SE, dated April 23, 1979, provides an acceptable level of safety. The alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(i), provided these valves are tested according to the Type C requirements applicable to valves served by a seal water system.

2.2 Relief Request SI-VRR-3 In NRC's July 9, 1991, Safety Evaluation for the inservice testing program relief requests, Relief Request 5.3.14 was evaluated for safety injection check valves SI-875A/B/C which are the subject valves for SI-VRR-3 in the revised inservice testing program. In the 1991 SE, interim relief was granted for a period of one year from the date of the SE or until the end of the next refueling outage following receipt of the SE, whichever was later. The interim relief expired July 9, 1992, based on completion of the spring 1992 refueling outage. Actions which were to be taken in the interim period were described in Appendix B of the TER attached to the 1991 SE, Anomaly 12.

These check valves are located in parallel branches of safety injection to the reactor coolant system. The licensee had proposed to stroke test the valves at a flow less than maximum design accident flow rate. The 1991 SE in Anomaly 12 requested the licensee pursue the use of nonintrusive techniques to verify full stroke exercising of these valves.

Relief Request SI-VRR-3 is evaluated in Section 3.4.1.1 of the attached TER.

Additionally, Anomaly 13 of the attached TER, provides further discussion of the relief request, indicating that application of nonintrusive techniques would be required to ensure full stroke exercising of these valves at a flow rate less than accident flow.

As confirmed by teleconference June 17, 1992, the licensee performed full stroke exercising of check valves SI-875A/B/C using ultrasonic nonintrusive techniques to verify disc movement during the flow test. This addresses the concerns of the July 9, 1991, SE, and should be documented in the licensee's response to Anomaly 13 of Appendix B of the attached TER.

-3 The use of nonintrusive testing methods is considered as an "other positive means in accordance with IWV-3522, and relief for the test method is not required. Performance of this testing during refueling outages requires relief from the requirements of IWV-3521 for the test frequency. Due to the impracticality in the design limitations of injecting substantial flow of low pressure water into the reactor coolant system during normal operations and during cold shutdown conditions, the testing must be performed during refueling outages. The part-stroke exercising and reverse flow closure verification performed each cold shutdown and the full stroke exercising during refueling outages provide adequate assurance of the operational readiness of these valves. Therefore, rather than interim relief as stated in Section 3.4.1.1.2, relief is granted per 10 CFR 50.55a(g)(6)(i).

2.3 Relief Request SI-VRR-6 In NRC's July 9, 1991, Safety Evaluation for the inservice testing program relief requests, Relief Request 5.3.4 was evaluated for safety injection check valves SI-874A/B which are the subject valves for SI-VRR-6 in the revised inservice testing program. In the 1991 SE, provisional relief was granted provided the licensee performs testing in accordance with guidance delineated in GL 89-04, Position 1. In Section 3.4.2.4 of the attached TER, the evaluation indicates that testing these valves in parallel does not conform to the guidance of GL 89-04, Position 1, and the corresponding anomaly (number

14) refers to the 1991 SE.

The licensee had proposed testing these valves in parallel which will not verify full flow through each valve. Per teleconference June 17, 1992, the licensee indicated that the valves were tested during the spring 1992 refueling outage, and that full flow was monitored for both valves individually. Therefore, the relief request is approved per GL 89-04, provided the testing conforms with the guidance delineated in Position 1 for full flow testing. This addresses the concerns of the July 9, 1991, SE, and should be documented in the licensee's response to Anomaly 14 of Appendix B of the attached TER.

3.0 CONCLUSION

Based on the review of the licensee's IST program relief requests, the NRC concludes that the relief requests as evaluated and modified by this SE will provide reasonable assurance of the operational readiness of the pumps and valves to perform their safety related functions. The NRC has determined that the proposed alternatives are authorized, pursuant to 10 CFR 50.55a(a)(3)(i) and (a)(3)(ii), and relief is granted pursuant to (g)(6)(i),

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 NRC 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 each requested relief is granted.

Page No.

TABLE 1 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT 2

SUMMARY

OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY NUMBER

& SUBJECT TESTING USNRC Pump 2.1.1.1 IWP-4500:

All pumps in Measure pump Relief Granted GPRR-1 Measure program vibration velocity with provision vibration and use acceptance (a)(3)(i) amplitude criteria of ASME/ANSI OMa-1988.

Pump 2.1.2.1 IWP-3100:

All pumps in Measure vibration Relief Granted GPRR-2 Measure program velocity quarterly. (a)(3)(ii)

-bearing temperature Pump 2.1.3.1 IWP-4110:

All pumps in Use ultrasonic flow Interim Relief GPRR-3 Instrument program instruments accurate Granted accuracy to 3% of reading.

(a)(3)(ii),

for one year or until the next refueling outage.

Pump 2.1.4.1 IWP-4110 and All pumps in Use digital Relief Granted GPRR -4

-4120:

program instruments accurate with provision Instrument to 3% of reading at for inst. range accuracy and owner's discretion. (a)(3)().

range General Relief Denied.

Pump 2.1.5.1 IWP-3100:

Safety Calculate inlet Relief Granted GPRR-5 Measure inlet injection, pressure based on (g)(6)(i) pressure containment head of water above during tests spray, boric pump suction.

acid, RHR, and service water pumps Pump 2.1.6.1 IWP-3230(b): All pumps in Allow 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Relief Denied GPRR -6 Corrective program evaluation prior to actions declaring pumps inoperable.

Pump 2.2.1.1 IWP-3100:

Containment Evaluate "as found" Relief Granted CS-PRR-1 Establish spray pumps flow rates and (g)(6)(i) reference A and B differential flow or dP pressures.

TABLE 1 S

Page No.

2 03/24/92 H. B. ROBINSON STFAM ELECTRIC PLANT, UNIT 2

SUMMARY

OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY NUMBER

& SUBJECT TESTING USNRC Pump 2.3.1.1 IWP-4120:

RHR pumps A Use installed 1%

Relief Granted RHR-PRR-1 Instrument and accuracy pressure (g)(6)(i) full-scale gauge that exceeds range range requirement.

Valve 3.1.1.1 IWV-3420:

Containment Test CIVs by testing Provisional GVRR-1 Leak rate isolation IVSW per Appendix J. Relief Granted testing valves (CIVs)

(a)(3)(1) served by the isolation valve seal water (IVSW) system Valve 3.1.1.2 IWV-3420:

All CIVs Assign leakage rate Relief Granted GVRR-1 Leak rate except those limits to with provision testing served by the penetrations, take (a)(3)(ii)

IVSW system corrective action if limits are exceeeded.

Valve 3.1.2.1 IWV-3520:

All nitrogen Functionally test Interim Relief GVRR-2 Exercising and air supply valves by testing Granted method check valves associated (g)(6)(i),

except those components or or one year or in GVRR-4 systems.

until the next refueling outage.

Valve 3.1.3.1 IWV-3417(b):

All power Allow 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Relief Denied GVRR-3 Corrective operated evaluation period actions valves prior to declaring valves inoperable.

Valve 3.1.4.1 IWV-3520:

IVSW system Functionally test Interim Relief GVRR-4 Exercising

valves, valves by testing Granted method SA-80, IA-525, associated (g)(6)(i),

IVSW-68A, components or for one year or

-68B, -68C, system.

until the next and -68D refueling outage.

TABLE 1 Page No. 3 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT 2

SUMMARY

OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY NUMBER

& SUBJECT TESTING USNRC Valve 3.2.1.1 IWV-3411 and All IVSW Exercise valves Relief Granted IVSW-VRR-1

-3521:

system valves during refueling for check Test in program outages.

valves frequency (g)(6)(i).

Relief Denied for power operated valves.

Valve 3.3.1.1 IWV-3413:

Diesel air Test alternate air Relief Granted DA-VRR-1 Measure start valves, start trains during (g)(6)(i) stroke times DA-19A, -19B, monthly diesel

-23A, and -23B testing.

Valve 3.3.2.1 IWV-3520:

Diesel air Verify closure of Relief Granted DA-VRR-2 Test method reciever check each set of series (g)(6)(i)

valves, check valves DA-9A, -9B, quarterly.

-33A, and -33B Valve 3.3.1.2 IWV-3413:

Diesel day Verify that valves Interim Relief DA-VRR-3 Measure tank supply operate to fill day Granted stroke times valves, tank during monthly (g)(6)(i),

EV-1963A-1, diesel testing.

for one year or

-1963A-2, until the next

-19638-1, and refueling

-19638-2 outage.

Valve 3.4.2.1 IWV-3521:

Safety Full-stroke exercise Relief Granted SI-VRR-1 Test injection (SI) with flow at (g)(6)(i) frequency check valves, refueling outages.

SI-873A thru

-873F, -874A, and -8748 Valve 3.4.2.2 IWV-3521:

SI charging Full-stroke exercise Relief Denied SI-VRR-1 Test return line with flow at frequency check valve, refueling outages.

SI-849 Valve 3.4.2.3 IWV-3521:

SI pump Part-stroke open and Relief Granted SI-VRR-2 Test discharge verify closure (g)(6)(i) frequency check valves, quarterly.

SI-879A, Full-stroke during

-8798, and refueling outages.

-879C

TABLE 1 Page No.

4 03/24/92 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT 2

SUMMARY

OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY NUMBER

& SUBJECT TESTING USNRC Valve 3.4.1.1 IWV-3520:

SI combined Exercise open with Relief Granted SI-VRR-3 Test method injection less than full flow (g)(6)(i) and frequency check valves, at refueling Reference 2.2 of SI-875A, outages. Exercise Safety Evaluation

-875B, and closed and leak test

-875C at cold shutdowns.

Valve 3.4.1.2 IWV-3521:

SI high head Part-stroke and leak Relief Granted SI-VRR-4 Test injection test at cold (g)(6)(i) frequency check valves, shutdowns.

SI-876A, Full-stroke with

-876B, and flow at refueling

-876C outages.

Valve 3.4.1.3 IWV-3420:

Boron Leak test series Relief Granted SI-VRR-5 Leak rate injection tank check valves as a (g)(6)(i) testing discharge pair at cold check valves, shutdowns.

SI-873A, and

-873D Valve 3.4.2.4 IWV-3520:

SI hot leg Pass full flow Provisional Relief SI-VRR-6 Test method injection through parallel Granted per GL 89-04 and frequency check valves, valve pair each Reference 2.3 of SI-874A and refueling outage.

Safety Evaluation

-874B Valve 3.5.2.1 IWV-3521:

Emergency Part-stroke exercise Relief Granted CVC-VRR-1 Test boration check quarterly.

(g)(6)(i) frequency

valves, Full-stroke exercise CVC-351, and each refueling

-357 outage.

Valve 3.5.2.2 IWV-3520:

RCP seal water Verify valve closure Relief Granted CVC-VRR-2 Test supply check each refueling (g)(6)(i) frequency va ves, outage.

CVC-298A thru

-298F

TABLE 1 Page No.

5 03/24/92

- H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT 2

SUMMARY

OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY NUMBER

& SUBJECT TESTING USNRC Valve 3.5.1.1 IWV-3520:

Charging Exercise closed and Relief Granted CVC-VRR-3 Test header check leak test each (g)(6)(i) frequency

valve, refueling outage.

CVC-312C Valve 3.6.1.1 IWV-3412 and Penetration Verify pro per valve Interim Relief PPS-VRR-1

-3413:

pressurization operation b Granted Exercise system Appendix J leak rate (g)(6)(i),

valves and solenoid testing associated for one year or measure valves CIVs.

until the next stroke times refueling outage.

Valve 3.7.1.1 IWV-3520:

Main feedwater Verify valve closure Relief Granted FW-VRR-1 Test header check each refueling (g)(6)(i) frequency

valves, outage.

FW-8A, -8B, and -8C Valve 3.8.1.1 IWV-3300:

RCS vent No alternate testing Interim Relief RCS-VRR-1 Verify valve valves, is proposed.

Granted position RC-567, -568, (g)(6)(i),

indication

-569, -570, for one year or

-571, -572 until the next refueling outage.

vRE0 0 >

UNITED STATES NUCLEAR REGULATORY COMMISSION o

WASHINGTON, D. C. 20555 00 September 16, 1992 Docket No. 50-261 Mr. R. A. Watson Senior Vice President Nuclear Generation Carolina Power & Light Company P. 0. Box 1551 Raleigh, NC 27602

SUBJECT:

SAFETY EVALUATION OF THE INSERVICE TESTING (IST) PROGRAM RELIEF REQUESTS, H. B. ROBINSON, UNIT NO. 2 (TAC NO. M81309)

By letter dated August 1, 1991, Carolina Power & Light Company (CP&L or the licensee) submitted the Inservice Testing (IST) Program for the third ten-year interval at the H. B. Robinson Steam Electric Plant, Unit No. 2 (HBR2).

The licensee's submittal superseded all previous IST program submittals. The third interval commenced February 19, 1992, and is scheduled to end February 18, 2002.

(The licensee's August 1, 1991, transmittal letter contained a typographical error indicating February 21, 2002, as the end of the third interval.)

The NRC staff has reviewed and evaluated the relief requests contained in the submittal.

This review supersedes the interim relief granted by the NRC in a letter dated June 1, 1992.

Title 10 of the Code of Federal Regulations, paragraph 50.55a(g) requires that certain American Society of Mechanical Engineers (ASME) Code Class 1, 2, and 3 pumps and valves in light water-cooled nuclear power facilities meet the IST requirements stated in the ASME Boiler and Pressure Vessel Code,Section XI; specifically, Subsection IWP, IST of Pumps in Nuclear Power Plants, and Subsection IWV, IST of Valves in Nuclear Power Plants. Each facility is required to establish a program for the IST of pumps and valves which is updated every ten years to meet the requirements in the latest approved Edition and Addenda to Section XI of the ASME Code. The program is submitted to the NRC for review and approval of the relief request-s.

The review entails verifying that the program is based on the applicable Code Edition and Addenda, and verifying the acceptability of the requests for relief from the requirements of Subsections IWP and IWV.

The NRC with technical assistance from Idaho National Engineering Laboratory, EG&G Idaho Inc. (EG&G), has reviewed and evaluated the requests for relief submitted for HBR2. As explained in the enclosed Safety Evaluation (SE), the NRC adopts the evaluations and conclusions contained in the Technical Evaluation Report (TER) prepared by EG&G (EGG-NTA-10099, dated March 1992),

except as noted in SE Sections 2.1, 2.2, and 2.3.

9209240285 920916 PDR ADOCK 05000261 P

PDR

-2 Certain relief requests have been denied where proposed alternative testing is unacceptable or where an adequate basis for the relief request has not been provided. These denials were reported to you in a letter from the NRC dated June 1, 1992.

We have reviewed and evaluated the remaining IST program relief requests and have determined that the remaining IST program relief requests are acceptable for implementation provided the items identified in Appendix B of the TER are addressed. The licensee should refer to the TER, Appendix B, for a discussion of IST program action items identified during the review. All the items in Appendix B should be resolved in accordance with the guidance therein.

Actions taken to resolve the Appendix B items must be completed within one year of the date of this letter, or by the end of the next refueling outage, whichever is later. For those relief requests that have been denied, the testing is to be in compliance with Code requirements or GL 89-04 by the end of the first quarter following the date of this letter. Any revised relief requests addressing relief denials should be submitted within the first quarter after the date of this letter.

The NRC is granting relief from the testing requirements which we determined to be impractical to perform, where compliance would result in a hardship without a compensating increase in safety, or where the proposed alternative testing provides an acceptable level of quality and safety. The NRC staff has determined that granting relief, pursuant to 10 CFR 50.55a(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 giving due consideration to the burden upon CP&L that could result if the ASME Code requirements were imposed on the facility.

Compliance is required with the IST program defined in your letter of August 1, 1991, in cases where relief is being granted in the enclosed SE.

Program changes such as additional relief requests or changes to relief requests should be submitted for review and should not be implemented prior to review and approval by the NRC. New or revised relief requests meeting the positions in Generic Letter (GL) 89-04, Enclosure 1, should be submitted to the NRC for information, but can be implemented provided the guidance in GL 89-04, Section D, is followed. Program changes that involve additions or deletions of components from the IST program should be provided to the NRC.

The NRC performs audits/inspections of licensees' IST programs. Therefore, the review performed for the TER does not include verification that all pumps and valves within the scope of 10 CFR 50.55a and ASME Code Section XI are contained in the IST program. Additionally, for the components included in the IST program, no determination is made to ensure all applicable testing requirements are identified. Therefore, the licensee is requested to provide the NRC with a description of how you have assured yourselves that you have identified and correctly categorized all pumps and valves. This can be accomplished by briefly summarizing the process used in developing the IST program. The submittal should include, as a minimum, details of the documents used, the method of determining if a component requires inservice testing, the

September 16, 1992

-3 basis for the testing required, the basis for categorizing valves, and the method or process used for maintaining the program current with design modifications or other activities performed under 10 CFR 50.59. If a description of this process is not already available from existing documentation, the staff envisions that this request could be answered in two to four pages. It could be incorporated into the IST program in appropriate sections. The information should be included with the licensee's response to the anomalies presented in Appendix B of the TER. The schedule for the response is outlined in the evaluation section of the SE.

This completes our review of the IST Program relief requests under TAC No. 81309.

The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OMB clearance is not required under P. L.96-511.

Sincerely, ORIGINAL SIGNED BY:

Brenda Mozafari, Project Manager Project Directorate II-1 Division of Reactor Projects -

I/II Office of Nuclear Reactor Regulation cc: See next page DISTRIBUTION:

See next page See previous concurrence LA: PD2 1:

P M-PD2,1:DRPE EMEB*

OGC*

PAnderson Rza ar:1n JNorberg JHull

//116/92

//14/92 07/15/92 08/14/92 PD:PD21:

EAdensam Document Name:

ROB81309.LTR bR NL ET CP

-3 requirements are identified. Therefore, the licensee is requested to provide the NRC with a description of how you have assured yourselves that have identified and correctly categorized all pumps and valves. This can be accomplished by briefly summarizing the process used in developing the IST program. The submittal should include, as a minimum, details of the documents used, the method of determining if a component requires inservice testing, the basis for the testing required, the basis for categorizing valves, and the method or process used for maintaining the program current with design modifications or other activities performed under 10 CFR 50.59. If a description of this process is not already available from existing documentation, the staff envisions that this request could be answered in 2 to 4 pages. It could be incorporated into the IST program in appropriate sections. The information should be included with the licensee's response to the anomalies presented in Appendix B of the TER. The schedule for the response is outlined in the evaluation section of the SE.

This completes our review of the IST Program relief requests under TAC No. 81309.

The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OMB clearance is not required under P. L.96-511.

Sincerely, Brenda Mozafari, Project Manager Project Directorate II-1 Division of Reactor Projects -

I/II Office of Nuclear Reactor Regulation cc: See next page DISTRIBUTION:

See next page

• See previous concurrence LA: PD2 1: D J'

PMyPW SPE EMEB*

0GC*

PAnerson B

afari:ln JNorberg JHull 9/)0/92/

/92 07/15/92 08/14/92 PD:PD21:DRPE EAdensam

/

/92 Document Name:

ROB81309.LTR

September 16, 1992

-3 basis for the testing required, the basis for categorizing valves, and the method or process used for maintaining the program current with design modifications or other activities performed under 10 CFR 50.59. If a description of this process is not already available from existing documentation, the staff envisions that this request could be answered in two to four pages. It could be incorporated into the IST program in appropriate sections. The information should be included with the licensee's response to the anomalies presented in Appendix B of the TER. The schedule for the response is outlined in the evaluation section of the SE.

This completes our review of the IST Program relief requests under TAC No. 81309.

The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OMB clearance is not required under P. L.96-511.

Sincerely, Brenda Mozafari, Projec Manager Project Directorate II-1 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation cc:

See next page

-4 During the review of the licensee's inservice testing program, the NRC has identified certain misinterpretations or omissions of Code requirements.

These items are summarized in the TER Appendix B. Except for those relief requests that were denied, the IST program relief requests for HBR2 provided by the submittal dated August 1, 1991, are acceptable for implementation provided that the changes and actions described in Appendix B are completed in accordance with the schedule set forth in the cover letter.

Principal Contributor: K. Dempsey Date:

S0 Mr. R. A. Watson H. B. Robinson Steam Electric Carolina Power & Light Company Plant, Unit No. 2 cc:

Mr. H. Ray Starling Mr. Dayne H. Brown, Director Manager - Legal Department Department of Environmental, Carolina Power & Light Company Health and Natural Resources P. 0. Box 1551

• Division of Radiation Protection Raleigh, North Carolina 27602 P. 0. Box 27687 Raleigh, North Carolina 27611-7687 Mr. H. A. Cole Special Deputy Attorney General Mr. Robert P. Gruber State of North Carolina Executive Director P. 0. Box 629 Public Staff - NCUC Raleigh, North Carolina 27602 P. 0. Box 29520 Raleigh, North Carolina 27626-0520 U.S. Nuclear Regulatory Commission Mr. C. R. Dietz Resident Inspector's Office Vice President H. B. Robinson Steam Electric Plant Robinson Nuclear Department Route 5, Box 413 H. B. Robinson Steam Electric Plant Hartsville, South Carolina 29550 P. 0. Box 790 Hartsville, South Carolina 29550 Regional Administrator, Region II U.S. Nuclear Regulatory Commission Mr. Heyward G. Shealy, Chief 101 Marietta Street Bureau of Radiological Health Suite 2900 South Carolina Department of Health Atlanta, Georgia 30323 and Environmental Control 2600 Bull Street Mr. Ray H. Chambers, Jr.

Columbia, South Carolina 29201 General Manager H. B. Robinson Steam Electric Plant Mr. R. B. Starkey P.O. Box 790 Vice President Hartsville, South Carolina 29550 Nuclear Services Department Carolina Power & Light Company P.O. Box 1551 Raleigh, North Carolina 27602

DISTRIBUTION:

Docket File NRC and local PDRs Robinson Reading File S. Varga G. Lainas E. Adensam B. Mozafari P. Anderson J. Norberg K. Dempsey OGC ACRS (10)

E. Merschoff, RII 210018