ML17056B079

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Safety Evaluation Re Inservice Testing Program & Requests for Relief
ML17056B079
Person / Time
Site: Nine Mile Point Constellation icon.png
Issue date: 10/29/1990
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML17056B078 List:
References
NUDOCS 9011060238
Download: ML17056B079 (12)


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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, O. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE INSERVICE TESTING PROGRAM AND RE UESTS FOR RELIEF NIAGARA MOHAWK POWER CORPORATION NINE MILE POINT NUCLEAR POWER STATION UNIT NO.

2 DOCKET NO. 50-410 INTRODUCTION The Code of 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 difficultywithout a compensating increase in the level of quality or safety; or (3) the Code requirement is impractical for its facility.

The regulations, 10 CFR 50.55a(a)(3)(i), (a)(3)(ii), and (g)(6)(i), authorize 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 from October 31, 1986, to October 31, 1996.

The licensee's program includes the pump IST program, Revision 1, and the valve IST program, Revision 1, and is described in a letter dated March 31, 1988, which superseded all previous submittals.

Additional information was submitted by letters dated September 30, 1988 and February 8, 1989.

The program is based on the requirements of Section XI of the ASME Code, 1983 Edition through the Summer 1983 Addenda.

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, EGSG Idaho, Inc.

(EGKG).

In addition, EG8G staff members met with licensee representatives on December 3 and 4, 1987, in a working session to discuss questions resulting from the review.

The Technical Evaluation Report (TER) provided as Attachment 1 is EGAG's evaluation of the licensee's inservice testing program and relief requests.

The staff has reviewed the TER and concurs with the evaluations and conclusions contained in the TER.

A sumary of the pump and valve relief request determinations is presented in Table 1.

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The granting of relief is based upon the fulfillment of any commitments made by the licensee in its basis for each relief request and the alternative proposed testing.

No relief requests were denied;

however, two relief requests were granted with cer tain conditions (TER Sections 3.1. 1 and 4.1.4.1) and two relief requests were granted on an interim basis (TER Sections 3.3.1 and 4.10.2.1).

The licensee should refer to the specific TER sections for a detailed discussion of these cases.

These conditions are listed in the TER Appendix B, which also lists other IST program anomalies identified during the review.

The licensee should resolve all the items listed in Appendix B in accordance with the staff guidance therein.

Program/procedural changes covered by Items I, 3, and 4, in Appendix B should be made within 6 months of receipt of this SE.

Item 2 in Appendix B should be resolved within one year of receipt of this SE or the next refueling outage, whichever is longer.

The staff has not specified a fixed schedule for Item 5.

The program change covered by Item 6 in Appendix B should be made within the next refueling outage.

CONCLUSION Based on the review of the licensee's IST relief requests, the staff 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 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.

In making this determination the staff has considered the alternative 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, on the facilities.

The last column of Table I identifies the regulation under which the requested relief was granted.

During the review of the licensee's inservice testing program, the staff has identified certain items concerning Code requirements.

These items are suomarized in the TER Appendix B.

The IST program relief requests for Nine Mile Point Unit 2 provided by a submittal dated March 31, 1988, as supplemented by letters dated September 30, 1988 and February 7, 1989, are acceptable for implementation provided that the items noted above are corrected in accordance with the guidance in this SE and the TER.

New or revised relief requests may not be implemented without prior approval by NRC, unless they are relief requests meeting the positions in Generic Letter 89-04, Enclosure l.

Dated:

Princi al Contributor:

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Page No.

07/30/90 NINE MILE POINT, UNIT 2 SER TABLE 1

SUMMARY

OF RELIEF REQUESTS RELIEF TER REQUEST SECTION NUMBER SECTION XI EQUIPMENT REQUIREMENT IDENTIFICATION 5 SUBJECT ALTERNATE METHOD OF TESTING ACTION BY USNRC GPRR-1 3.1.1 IWP-4500 Measure pump bearing vibration displacement.

All pumps in IST program Perform vibration measurements per IST program description.

Relief Granted 10 CFR 50.55a (a)(3)(i) provided, compliance with all OH-6 vibration measurement requirements.

GPRR-3 3.1.2 IWP-4310 All pumps in Heasure pump IST program bearing temperature.

Monitor pump vibration velocity quarterly.

Relief Granted (a)(3)(ii)

SLS-PRR-1 3.2. 1 SWP-PRR-1 3.3.1 Table IWP-4110-1 Instrument accuracy.

IWP-3100 Measure pump inlet and differential pressure and flowrate.

Standby liquid control

pumps, 2SLS*P1A and P18 Control building chilled water
pumps, 2SWP*P2A and P2B Measure flow with ultrasonic flowmeter with full-scale repeatable accuracy of + or - 3%.

Monitor system temperature response and pump vibration velocity quarterly.

Relief Granted (a)(3)(ii)

Interim Relief Granted (g)(6)(i) for 1 year or until the next RO provided method developed to evaluate pump hydraulic condition.

GVRR-1 GVRR-2 4.1.1.1 4.1.2.1 IWV-3421 thru

-3425 Leak rate testing Category A

valves.

IWV-3522 Test method and frequency.

Containment isolation valves with exception of excess flow check valves Excess flow check valves.

Leak rate test in accordance

with, Appendix J, Type C,

requirements and comply with IWV-3426 and -3427.

Functionally test each refueling outage to verify valves limit leakage.

Relief Granted (a) (3) (i) per GL,89-04, Position 10 Relief Granted (g)(6)(i)

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Page No.

07/30/90 NINE MILE POINT, UNIT 2 SER TABLE 1

SUMMARY

OF RELIEF REQUESTS e

RELIEF TER REQUEST SECTION NUMBER SECTION XI REQUIREMENT 8r. SUBJECT EQUIPMENT IDENTIFICATION ALTERNATE METHOD OF TESTING ACTION BY USNRC GVRR-3 4.1.3.1 IWV-3413 and

-3417 Valve stroke timing and trending.

Rapid-acting power-operated valves with normal stroke times less than 2 sec.

Assign 2 sec stroke Relief Granted time limit, perform (g)(6)(i) corrective action if per GL 89-04, exceeded.

Position 6

GVRR-4 4.1.4.1 IWV-3522 Test method.

Keep fill system check

valves, 2CSH*V17, V55, 2CSL*V14, and V21 Verify operability as a unit quarterly.

Relief Granted (g)(6)(i) provided corrective action taken upon evidence of leakage through the pair.

EGA-VRR-1 4 ~ 2.1.1 IWV-3413, Valve stroke timing.

Auto diesel air start

valves, 2EGA*PCV25A,
25B, 26A, 26B, AOV323A and 323B Functionally test during monthly diesel testing by evaluation of diesel start time.

Relief Granted (g)(6)(i)

EGA-VRR-2 4.2.2.1 IWV-3522 Test method and frequency.

Auto diesel generator start check

.valves, 2EGA*V12A, V12B, V14A, and V14B Verify closure each Relief Granted refueling outage.

(g)(6)(i)

FWS-VRR-1 4.3.1.1 GSN-VRR-1 4.4.1.1 IWV-3522 Test frequency.

IWV-3522 Test frequency.

Feedwater system inside containment isolation check valves, 2FWS*V12A and V12B TIP mechanism nitrogen purge containment isolation

valve, 2GSN*V170 Verify closure each cold shutdown when the containment is de-inerted and each refueling outage.

Verify closure each refueling outage during Appendix J, Type C, leak rate testing.

Relief Granted (g)(6)(i)

Relief Granted (g)(6)(i)

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Page No.

3 07/30/90 NINE MILE POINT, UNIT 2 SER TABLE 1

SUMMARY

OF RELIEF REQUESTS RELIEF TER SECTION XI REQUEST SECTION REQUIREMENT NUMBER

& SUBJECT EQUIPMENT IDENTIFICATION ALTERNATE METHOD OF TESTING ACTION BY USNRC IAS-VRR-1 4.5.1.1 IAS-VRR-2 4.5.1.2 ICS-VRR-2 4.6.1.1 MSS-VRR-1 4.7.1.1 RCS-VRR-1 4.8.1.1 IWV-3522 Test frequency.

IWV-3522 Test frequency.

IWV-3522 Test method and frequency.

IWV-3412 and

-3522

Exercise, stroke time, and fail-safe test.

IWV-3522 Test frequency.

Instrument air containment isolation

valves, 2IAS*V448 and V449 ADS and MS IV accumulator inlet air check valves listed in the IST program RCIC suction check valve from suppression
pool, 2ICS*V28 ADS valves, 2MSS*PSV121,
PSV126, PCV129,
PCV130, PCV134, and PCV137 Reactor coolant recirculation pump seal water CIVs, 2RCS*V59A,
59B, 60A, 60B,
90A, and 90B Verify closure each refueling outage during Appendix J, Type C, leak rate testing.

Verify reverse flow closure during cold shutdowns when containment is de-inerted and each refueling outage.

t Part-stroke exercise quarterly and disassemble and inspect each refueling outage.

Exercise and fail-safe test each refueling out'age and stroke time 50% each 18 months.

Verify closure each refueling outage during Appendix J, Type C, leak rate testing.

Relief Granted (g)(6)(i)

Relief Granted (g)(6)(i)

Relief Granted (g)(6)(i)

Rel i ef Granted (g)(6)(i)

Relief Granted (g)(6)(i)

RDS-VRR-1 4.9.1.1 IWV-3412 Test frequency.

Control rod Test in accordance Relief Granted scram valves, with plant Technical (g)(6)(i) 2RDS*AOV126 Specifications.

per GL 89-04, and AOV127 Position 7

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Pa'ge No.

4 07/30/90 NINE MILE POINT, UNIT 2 SER TABLE 1

SUMMARY

OF RELIEF REQUESTS RELIEF TER REQUEST SECTION NUMBER SECTION XI REQUIREMENT L SUBJECT EQUIPHENT IDENTIFICATION ALTERNATE METHOD OF TESTING ACTION BY USNRC RDS-VRR-1 4.9.2. 1 IWV-3522 Test frequency.

Control rod scram discharge check valve, 2ROS*V114 Test in accordance Relief Granted with plant Technical (g)(6)(i)

Specifications per GL 89-04, Position 7

SLS-VRR-1 4.10.1.1 IWV-3412 and

-3522 Test frequency.

SLS-VRR-2 4.10.2.1 IWV-3522 Test method and frequency.

SLS-VRR-3 4.10.1.2 IWV-3522 Test frequency.

Standby liquid control system injection check valves, 2SLS*MOV5A, MOVSB, and V10 Standby liquid control system pump discharge check valves, 2SLS*V12 and V14 Standby liquid control system injection check valve, 2SLS*V10 Verify forward flow capability during system test each refueling outage.

Verify closure at refueling outages and modify system to allow performance of this testing quarterly.

Verify reverse flow closure capability each cold shu'tdown when containment is de-inerted and each refueling outage.

Relief Granted (g) (6) (')

Interim Relief Granted (g)(6)(i) until end of next scheduled refueling outage.

Relief Granted (g)(6)(i)

SWP-VRR-1 4.11.1.1 IWV-3412 Test frequency.

Traveling water screen bypass

valves, 2SWP*MOV77A and MOV778 Exercise and stroke Relief Granted time each refueling (g)(6)(i) outage.

CPS-VRR-1 4.12.1.1 IWV-3522 Test frequency.

Containment purge-supply containment isolation

valves, 2CPS*V50 and V51 Verify closure capability each refueling outage.

Relief Granted (g) (6) (i)

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