ML17056B361

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Safety Evaluation Approving Relief Request from ASME Code Requirements
ML17056B361
Person / Time
Site: Nine Mile Point Constellation icon.png
Issue date: 03/07/1991
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML17056B360 List:
References
NUDOCS 9103140148
Download: ML17056B361 (18)


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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555 Enelesuve-1 SAFETY EVALUATION-BY-THE -OFFICE -OF-NUCLEAR -REACTOR - REGULATION RELATED-TO THE-INSERVICE. TESTING-PROGRAM-AND-RE UESTS-FOR -RELIEF NIAGARA-MOHAWK-ROWER - CORPORATION NINE-NICE. POINT-NUCLEAR-STATION -UNIT-NQr - I DOCKET-NQi 220 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 difficulty without a compensating increase in the level of quality and safety; or (3) the conformance with certain requirements of the applicable Code edition and addenda is impractical for its 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 IST Program are contained in this Safety Evaluation (SE).

The IST program addressed in this SE covers the second ten-year inspection interval from June 1,

1986 to June 1, 1996.

The licensee's program includes pump and valve IST program, Revision 2, and is described in a letter dated March 28, 1989, which supersedes all previous submittals.

The licensee's program is based on the requirements of Section XI of the ASME

Code, 1983 Edition through the Summer of 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, EG&G, Idaho, Inc.

(EG&h).

In addition, EG&G and staff members met with licensee representatives on February 22 and 23, 1989, in a working session to 9i03i40i48 9i0307 PDR ADDCK 05000220 P

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discuss questions resulting from the review.

The Technical Evaluation Report (TER) No.

EGG-NTA-8515 is EGKG's evaluation of the licensee's IST program and relief requests.

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

A summary of the pump and valve relief request determinations is presented in Table I of this SE.

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

testing, One relief request was partially denied (TER Section 3.9. 1. 1), ll relief requests were granted with certain conditions (TER Sections 2.1.1. 1, 2.1.2. 1, 2.1.2.2, 2.3.1.1, 2.5.1.1, 3.1.4.1, 3.4.1.1, 3.4.2.1, 3.4.2.2, 3.5.1.1, and 3.6.2. 1), and four relief requests were granted on an interim basis (TER Sections 3.2. 1. 1, 3.6. 1. 1, 3.7.2. 1, and 3. 10. 1.1).

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

These denials and 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 of the TER in accordance with the staff guidance therein.

Actions described in paragraphs 1, 2, 3, 5, 6, and 9 in TER Appendix B should be completed within six months of receipt of this safety evaluation.

Actions described in paragraph 4 of TER Appendix B should be completed within one year of receipt of this safety evaluation or the next refueling outage, whichever is longer.

Actions described in paragraphs 7 and 10 of TER Appendix B should be completed by the end of the 1992 refueling outage.

The alternate testing methods discussed in paragraphs 4, 5, and 8 in TER Appendix B should also be actively pursued and as new information is acquired and t'esting methods are developed the affected relief requests should be revised or withdrawn.

CONCL;US ION 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 safety evaluation will provide reasonable assurance of the operational readiness of the pumps and valves to perform their safety related functions.

The staff has

'etermined 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 alternate testing being implemented, compliance resulting in a harcship without a compensating increase in safety, and the impractically 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 B.

The IST program relief requests for Nine Mile Point, Unit 1, provtded by a submittal dated March 28,

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1989, are acceptable for implementation provided that the actions described in TER Appendix 8 are completed in accordance with the schedule set forth above in the evaluation section of this SE.

New or revised relief requests contained in any subsequent revisions may not be implemented without prior approval by NRC, unless they are relief requests complying with the guidance in Generic Letter 89-04, Section D, Enclosure 1.

Principal Contributor:

A. Keller Dated:

March 7, 1991

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Page' NINE HILE POINT, UNIT 1

SUETY EVALUATIONTABLE 1

SUMMARY

OF RELIEF REQUESTS RELIEF REQUEST NUMBER TER.

SECTION SECTION XI EQUIPMENT REQUIREMENT IDENTIFICATION

& SUBJECT ALTERNATE METHOD OF TESTING ACTION BY USNRC Pump PG-1 2.1.1.1 IWP-3100-2,

-4120, and

-4500 Vibration measurement method.

All pumps in IST Heasure vibration in program units of velocity and use the acceptance criteria of Table 1 as provided.

Provisional Relief Granted (a)(3){i)

Pump PG-2 Pump PG-3 2.1.2.1 2.1.2.2 Table IWP-3100-1 Measure pump inlet pressure.

Table IWP-3100-1 Measure inlet pressure before startup.

ESW, RBCLCW,
LPCS, EDGCW, CS, and CSRW pumps
ESW, RBCLCW,
LPCS, LPCST,
EDGCW, SFPC, CS,
CSRW, CT, and EDGFOT pumps Calculate inlet pressure from the level of the suction supply.

Inlet pressure will be measured or calculated during pump tests.

Provisional Relief Granted (a)(3)(ii)

Provisional Relief Granted (a)(3)(ii)

Pump PG-4 2.1.3.1 IWP-4310 Measure bearing temperature.

All pumps in IST Measure vibration in Relief Granted program velocity units (a)(3)(ii) quarterly.

Pump PR-4 2.1.4.1 IWP-4510 Measure vibration on pump bearing housing.

Various submerged pumps Vibration Relief Granted measur ements will be (g) (6) (i )

taken on the pump motors quarterly.

Pump PR-5 Pump PR-1 2.1.5.1 2.2.1.1 Tabl e IWP-4110-1 Flow rate instrument accuracy.

IWP-3400(a)

Test frequency.

LPCS, LPCST,
SFPC, CS, and CSRW pumps RBCLCW pumps Use installed instrumentation whose accuracy is better than 3%.

Heasure pump vibr ation quarter ly and all parameters during cold shutdowns.

Relief Granted (a)(3)(ii)

Relief Granted (g)(6)(i)

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C NINE MILE POINT, UNIT 1 SAFETY EVALUATIONTABLE 1

SUMMARY

OF RELIEF REQUESTS RELIEF REQUEST NUMBER TER SECTION SECTION XI EQUIPMENT REQUIREMENT IDENTIFICATION 5 SUBJECT ALTERNATE METHOD OF TESTING ACTION BY USNRC Pump PR-2 2.3.1.1 Table IWP-3100-1 Measure flow rate, inlet, and differential pressures.

Liquid poison pumps Measure discharge

pressure, vibration, and calculate flow rate.

Provisional Relief Granted (g)(6)(i)

Pump PR-3, 2.4.1.1 IWP-3400(a)

Emergency Measure flow service water rate pumps quarterly.

Measure parameters except flow rate quarterly, measure parameters including flow rate during refueling outages.

Relief Granted (g)(6)(i)

Pump PR-6 2.5.1.1 IWP-3100 Measure flow rate, inlet, and differential pressures.

DG fuel. oil transfer pumps Calculate flow rate.

Provisional. Relief Granted (g)(6)(i)

Pump PR-7 2.6.1.1 Table IWP-4110-1 Inlet pressure instrument accuracy.

Containment and Use installed level core spray pumps instruments whose accuracy is better than 2.5L'.

Relief Granted (a)(3)(ii)

Pump PR-8 NRC SER Table 06/22/90 IWV-3100-1 Vary system resistance.

DG cooling water Evaluate test

pumps, quantities at pump operating point.

Interim Relief Granted (a)(3)(i) till end of next refueling outage.

Valve VG-1 3.1.1.1 IWV-3417(a)

Stroke time corrective action requirements.

Rapid acting power operated valves Assign limiting stroke time of two seconds take corrective action if exceeded.

Relief Granted (g)(6)(i)

GL 89-04, Position 6.

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NINE MILE POINT, UNIT I SAFEZY EVALUATION'ABLEl.

SUMMARY

OF RELIEF REQUESTS RELIEF REQUEST NUMBER TER SECTION SECTION XI EQUIPMENT REQUIREMENT IDENTIFICATION 5 SUBJECT ALTERNATE METHOD OF TESTING ACTION BY USNRC Valve VG-2 3.1.2.1 IWV-3421 thru

-3425 and

-3427(b)

Leak rate test method.

Containment Leak test per isolation valves 10 CFR 50, Appendix J, and comply with IWV-3426 and -3427(a)

Relief Granted (a)(3)(i)

GI 89-04, Position 10.

Valve VG-3 3.1.3.1 IWV-3521 and Excess flow

-3522 Test check valves method and frequency.

Verify closure by Relief Granted reduction of leakage (g)(6)(i) and by sound.

Val ve VG-4 3.1.4.1 IWV-3417(a)

Stroke time test method.

Power operated Compare stroke times valves except to baseline stroke for rapid-acting times for acceptance, Provisional Relief Granted (a)(3)(i)

Valve MS-RR-1 Valve MS-RR-2 3.2.1.1 3.2.2.1 IWV-3412,

-3413, and

-3522 Test method and frequency.

IWV-3521 and

-3522(b)

Exercise check valves quarterly or during cold shutdowns.

ADS valves ADS vacuum relief check valves Exercise during refueling outages, do not stroke time.

Exercise by hand and inspect valves during refueling outages.

Interim Relief Granted (g)(6)(i) for one year or until the next refueling outage.

Relief Granted (g)(6)(i)

Valve CRD-RR-3 Valve CRD-RR-1 3.3.1.1 3.3.2.1 IWV-3521 and 301-112 and

-3522 Test 301-113 frequency.

IWV-3412, CRC scram valves

-3413,

-3415, 126 and 127 and

-3300 Test method and frequency.

Perform Section XI leak rate test during refueling outages.

Exercise valves during Technical Specification control rod scram testing.

Relief Granted (g)(6)(i)

Relief Granted (a)(3)(i)

GL 89-04, Position 7.

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NINE NILE POINT, UNIT 1 SAFEZY EVALUATIONTABLE 1

SUMMARY

OF RELIEF REQUESTS RELIEF REQUEST NUMBER TER SECTION XI EQUIPMENT SECTION REQUIREMENT IDENTIFICATION

& SUBJECT ALTERNATE METHOD OF-TESTING ACTION BY USNRC Valve CRD-RR-1 3.3.3.1 IWV-3521 and CRD scram

-3522 Test discharge check method and valves 108 frequency.

Exercise valves during Technical Specification control rod scram testing.

Relief Granted (a)(3)(i)

GL 89-04, Position 7.

Valve CRO-RR-2 3.3.3.2 IWV-3521 and CRD charging

-3522 Test water check frequency.

valves 106 Perform a scram accumulator pressure decay test during refueling outages.

Relief Granted (g)(6)(i)

Valve CS-RR-3 Valve CS-RR-4 3.4.1.1 3.4.1.2 IWV-3521 and 93-58 and 93-64

-3522 Test method and frequency, IWV-3521 and 40-20 and 40-23

-3522 Test method and frequency.

Perform sample disassembly and inspection and verify closure via Appendix J leak test during refueling outages.

Reverse..flow closure is verified by the pressure isolation valve leakage testing during cold shutdowns.

Provisional Relief Granted (g)(6)(i),

GL 89-04, Position 2.

Relief Granted (g)(6)(i)

Valve CS-RR-1 3.4. 1.3 IWY-3521 and 40-03 and

-3522 Test 40-13 frequency.

Part-stroke exercise quarterly and full-stroke exercise during refueling outages.

Relief Granted (g)(6)(i)

Valve CS-RR-1 3.4.2.1 IWV-3521 and 81-07, 81-08,

-3522 Test 81-27, and 81-28 method and frequency.

Perform part-stroke exercise and sample disassembly and inspection as described in IST program.

Provisional Relief Granted (g)(6)(i),

GL 89-04, Position 2, for 81-07 5 -27 Relief Granted (g)(6)(i) <<r 81-08 5 -28.

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NINE MILE POINT, UNIT 1 SAFETY EVALUATIONTABLE l

SUMMARY

OF RELIEF REQUESTS RELIEF REQUEST NUMBER TER SECTION XI EQUIPMENT SECTION

'EQUIREMENT IDENTIFICATION 5 SUBJECT ALTERNATE METHOD OF TESTING ACTION BY USNRC Valve CS-RR-2 3.4.2.2 IWV-3521 and CS-C-3 and

-3522 Test CS-C-3 method and (2 valves) frequency.

Disassemble,

inspect, and manually exercise valves during refueling outages a sampling basis.

Provisional Relief Granted (g)(6)(i),

GL 89-04, Position 2.

on Valve EC-RR-1 3.5.1.1 IWV-3521 and

-3522 Test method and frequency, 39-03 and 39-04 Disassemble, Provisional Relief

inspect, and Granted (g)(6)(i),

manually exercise GL 89-04, valves on a sa~pling'osition 2.

basis or exercise with flow during refueling outages.

Valve CTS-RR-3 3.6.1.1 IWV-3521 and 93-60 and 93-62

-3522 Test method and frequency.

Perform sample disassembly and inspdction as described in IST program and leak test to verify closure.

Interim Relief Granted (g)(6)(i) for six months GL 89-04, Position 2.

Val ve CTS-RR-1 3.6.2.1 IWV-3521 and

-3522 Test method and frequency.

80-17,

-18, -19,

-37, -38,'39,

-65, -66,

-67, and -68 Perform sample disassembly and inspection as described in IST program.

Provisional Relief Granted (g)(6)(i),

GL 89-04, Position 2.

Valve CTS-RR-2 3.6.2.2 IWV-3520 Test frequency.

80-05,

-06, -25, Perform substantial Relief Granted and -26 part-stroke exercise (a) (3) (ii) with flow.

Valve

'P-RR-1 3.7.1.1 IWV-3521 and 42.1-02 and

-3522 Test

42. 1-03 frequency.

Full-stroke exercise Relief Granted with flow each (g)(6)(i) refueling outage.

Valve LP-RR-2 3.7.1.2 IWV-3521 and 42.1-02 and

-3522 Test

42. 1-03 frequency.

Verify closure each refueling outage by leak testing per Appendix J.

Relief Granted (9)(6)(')

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NINE MILE POINT, UNIT 1 SAFE1Y EVALUATIONTABLE 1

SUMMARY

OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT REQUEST SECTION REQUIREMENT IDENTIFICATION NUMBER 5 SUBJECT ALTERNATE METHOD OF TESTING ACTION BY USNRC Valve LP-RR-3 3.7.2. 1 IWV-3521 and 42-19 and

-3522 Test 42-20 frequency.

Verify closure each refueling outage and perform system modifications during 1991 outage to allow testing.

Interim Relief Granted (g)(6)(i) till end of 1992 refueling outage.

Valve 3.8.1.1 IWV-3520 Test FP-308 and SFSPFC-RR-1 method.

FP-310 Full-stroke exercise Relief Granted by hand and inspect (g)(6)(i) valve quarterly.

Valve 3.9.1.1 RBCLCW-RR-1 IWV-3521 and 70-MU-7 and

-3522 Test 70-257 method and frequency.

Perform sample disassembly and inspection as described in IST program.

Relief Denied for 70-257 Provisional Relief Granted (g)(6)(i) for 70-MU-7 Valve 3.9.1.2 IWV-3521 and 70-93 and RBCLCW-RR-2

-3522 Test 70-95 frequency.

Verify closure during refueling outages.

Relief Granted (g)(6)(i)

Valve ESW-RR-1 3.10. 1. 1 IWV-3521 and 72-11 and 72-12

-3522 Test frequency.

Full-stroke exercise with flow during refueling outages and modify system during 1991 refueling outage.

Interim Relief Granted (g)(6)(i) till end of 1992 refueling outage.

Valve 3.11.1.1 IWV-3413 and EDGAS-RR-1

-3415 Test method.

DGA-SOV-1 (2 valves),

DGA-SOV-2 (2 valves),

and 4 relay valves Assess operational readiness during diesel testing.

Relief Granted (a)(3)(ii)

Valve

3. 11.2. 1 IWV-3522 Test 82-03 and EDGFO-RR-1 method.

82-04 Assess operational Relief Granted readiness during (a)(3)(i) diesel testing.

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