ML17202U774
| ML17202U774 | |
| Person / Time | |
|---|---|
| Site: | Dresden |
| Issue date: | 07/25/1990 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17202U773 | List: |
| References | |
| GL-89-04, GL-89-4, NUDOCS 9008070349 | |
| Download: ML17202U774 (8) | |
Text
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 DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 DOCKET NOS. 50-237 AND 50-249
1.0 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 50.55(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 IST program addressed in this Safety Evaluation (SE) covers the second ten year inspection interval from March 1, 1982' to March 1, 1992.
The licensee*'s pump and valve IST program is described in an enclosure to a letter dated July 12, 198~ entitled, "Inservice Testing Programs for ASME Class 1, 2, 3 and Saftey Related Pumps and Valves," Revision 3, July 1, 1989. This *submittal supercedes all previous submittals.
The program is based on the requirements of Section XI of the ASME Code, 1977 Edition through the Summer 1989 Addenda.
2.0 EVALUATION The IST program and the requ~sts for relief from the requirements of Section XI have been reviewed by the staff with the assistance of its contractor, EG&G, Idaho, Irie. {EG&G).
In addition, EG&G and staff members met with licensee representatives on May 23 and 24, 1989, in a working session to discuss ques-tions resulting from the review. The Technical Evaluation Report (TER) provided as Attachment 1 is EG&G'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 summary of the pump and valve relief request determinations is presented in Table 1. 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
- P~R-
-Ar~ ~ 9007~~
.1..ll,J(*L.'
)
-'*-1 P
- r, (. 500023"7
. _ Ptic I
- Two relief requests were denied (TER Sections 4.3.2.3 and 4.3.3.1); eleven relief requests were granted with certain conditions (TER Sections 3.1.1, 3.5.1, 4.1.1.1, 4.1.1.2, 4.1.2.1, 4.2.1.1, 4.2.1.2, 4.4.1.2, 4.4.1.4, 4.9.1.1, and 4.10.1.1) and one relief request was granted on an interim bases {TER Section 3.3.1). The licensee should refer to the specific TER section for a detailed*
discussion of these cases. These conditions are listed in the TER Appendix C, which also lists other IST program anomalies identified during the*review.
The licensee should resolve the anomalies identified in Appendix C in accordance with the staff positions*. Required program changes sho1,1ld be made within six months of receipt of this SER.
3.0 CONCLUSION
Based on the review of the licensee's IST program and relief requests, the staff concludes that the IST program, as evaluated and modified by this SE, will provide reasonable assurance of the operational readiness of the pumps and valves covered by the IST program 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 corrunon 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 compen-sating 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 whith 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 surrunarized in the TER Appendix C.
The IST program for March 1, 1982 to March 1, 1992 contained in a submittal dated July 12, 1989, is acceptable for implementation provided that the items noted above are corrected within six months of receipt of this SE (unless otherwise noted in the 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 meeting the positions in Generic Letter 89-04, Attachment 1.
Principal Reviewer:
H. Shaw Dated:
e e
Page No.
1 96/22/90 DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 SER TABLE 1
SUMMARY
OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE RELIEF REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF REQUEST NUMBER
& SUBJECT TESTING STATUS Puni~
3.1.1 IWP-4500 All pumps ;n Utilize vibration Relief Granted PR-Measure IST program.
testing program in ia){3){i) vibration IST program.
rovided displacement.
compliance with all OM-6
- vibration criteria.
Pump 3.1.2 IWP-3300 All pumps in *Measure vibration in Relief Granted PR-2 Measure IST program.
units of velocity (a){3).(i) bearing quarterly.
temperature.
Pum~
3.1.3 IWP-3400 All pumps in Test pumps Re 1 i ef Granted
- PR-Test IST program.
quarterly.
(a){3)(ii) frequency.
Pump 3.2.1 IWP-4200 Diesel Evaluate using pump Relief Granted PR-4 Measure inlet generator fuel discharge pressure. (a){3){i) pressure.
oil transfer and flow.
pumps: 2-5203, 2/3-5203, &
3-5203 Pum~
3.3.1 IWP-4600 Diesel Monitor monthly to Interim Relief PR-
- Measure fl ow Generator ensure adequa.te Granted*
rate.
cooling water cooling water (g)(6}(i) until pumps:
temperatures.
end of next 2-3903, refueling 2/3-3903, &
outage.
3-3903 Pump 3.4.1
.. IWP-3100 Standb1 1 iquid Determine suction Relief Granted PR-6 Measure inlet contro pum~s: pressu~e prior to (a)(3)(i) pressure.
2~3lA-1102 start, set pump 2 3 B-1102 dischar~e pressure for tes
- Pum~
3.5.1 IWP-4500/0M-6 High pressure* Utilize limits in Relief Granted PR-Vibration coolant relief request based ig)(6)(i) velocity injection on reference values. rovided acceptance pum~s:
appropriate criteria.
2(3 -2302 limiting values of vibration velocity assigned.
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Page*No.
2 06/22/90 DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 SER TABLE 1
SUMMARY
OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE RELIEF REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF.
REQUEST NUMBER
& SUBJECT TESTING STATUS Valve 4.1.1.1 IWV-3413 Power-operated Stroke time in.
Relief Granted VR-5 Stroke valves with accordance with ig)(6)(i) timing.
maximum str9ke newer edition of the rovided stroke times less CQde.
timing to at than 10s.
least nearest second.
Valve 4.1.1.2 IWV-3413(c)
All power Assi~n alert range Relief Granted DAIM-Vl Stroke tlme operated limi s based on (g)(6)(i) measurements. valves with reference stroke Provided stroke times time values.
compliance with
~reater than GL 89-04,
- s.
Position 5.
Valve 4.1.2.1 IWV-3420 Primary Test to criteria of Relief Granted VR-6 Category A containment Appendix J.and ia)(3)(i) leak testing isolation Technical rovided requirements. valves.
Specifications.
compliance with GL 89-04, Position 10.
Valve
.4.1.3.1 IWV-3521 All excess Test to Technical Relief Granted VR-24 Test flow* check Specification (g)(6)( i) frequ.ency.
valves.
requirements.
Valve 4.2.1.1 IWV-3413 CRD ARl/ATWS Exercise each cold Relief Granted VR-8 Test method. air header shutdown without ig)(6)(i) bleed valves: stroke timing.
rovided valve 2p}-0339-524A operation is
- 24B, -548A,.
verified within
-548B, -549A, acceptance
& -549B criteria.
Valve.
4.2.1.2 IWV-3413 CRD backup Exercise without Relief Granted VR-9 Test scram and stroke timing each (g)(6)(i) frequency and scram dump co 1 d *shutdown..
Provided valve method.
valves:
operation is 2(3~-0302-19A, verified within
-19, -20A, &
acceptance
-20B criteria.
Page No.
96li2/90 3
RELIEF TER REQUEST SECTION NUMBER Valve 4.2.2.1 VR-1 Valve 4.3.1.1 VR-16 Valve 4.3.2.1 VR-3.
Valve
. 4.3.2.2 VR-4
. Valve 4.3.2.3 VR-10 Valve.
4.4.l.l VR-15 *
- DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 SER TABLE 1
SUMMARY
OF RELIEF REQUESTS SECTION XI EQUIPMENT REQUIREMENT IDENTIFICATION
& SUBJECT ALTERNATE METHOD OF TESTING RELIEF REQUEST STATUS IWV-3413 &
CRD scram and Verify oferation via Relief Granted
-3521 Test scram pilot
- Technica (g)(6)(i) frequency and valves:
Specification method.
2f 3~-0305-114, testing.
- 1 ' -118,
-126, & -127 IWV-3522 Main steam Manually full-stroke Relief Granted Test method. relief valve* disk and visually (g)(6)(i)
. discharge inspect valve vacuum reaker internals during check valves: cold shutdowns when 2(3l*0220-105A de-inerted and
- B,
, D, & E refueling *.
I
.IWV-3413 ADS Target Verify proper Relief Granted Sfroke time Rock and operation each (g)(6)(i) measurements. electromatic refueling outage.
relief valves:
2(3l*0203-3A, B,
, D & E IWV-3512 ADS Target Calibrate pressure Relief Granted Setpoint
- Rock and switches and verify (a)(3)(i) check.
electromatic pro~er operation relief valves: eac refueling 2(3l*0203-3A, outige.
B,
, D, & E IWV-3512 Main steam Replace valve pilot Relief Denied Relief valve Target Rock assembly section seti:ioint safety relief each refueling as-fol.ind valves:
outage and replace test.
2(3)-0203-3A valve body every
- other refueling outage.
IWV-3521 High pressure Part-stroke
'Re 1 i ef Granted Test coolant
~uarterl~ and sample (g)(6)(i) frequency and injection isassem ly and method.
torus suction inspection as check valves: described in IST 2(3)-2301-39 program
- I e
e Page No.
4 06/22/90 DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 SER TABLE 1
SUMMARY
OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE RELIEF REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF
. REQUEST NUMBER
& SUBJECT TESTING STATUS
. Valve 4~4.1.2 IWV-3521 High pressure Verify closure bf Relief Granted VR-18 Test coolant.
sample disassemb y ig)(6)(i) frequency and in~ection keep and inspection as rovided the method.
fi 1 check described in IST valve series is valves:
program.
leak tested 2(3)-2354-500 each refueling outage.
Valve 4.4.1.3 IWV-3521 High pressure Verify full-stroke Relief Granted VR-19 Test coolant capabilitf by sample (g)(6)(i) as frequency and injection _
disassemb y and requested or to method.
turbine inspection as functionally exhaust vacuum described in IST test the set breakers:
program.
each refueling 2p~-2399-76A,
- . outage.
- 6, -77A, &
-778 Valve 4.4.1.4 IWV-3521
- Hi~h pressure 'Part-stroke exercise Relief Granted VR-22 Test inJection o~en each cold ig)(6)(i) frequency.
check valves: s utdown and rovided valves 2(3)-2301-7 full-stroke exercise are exercised open and closed each o~en at cold refueling outage.
s utdown with torque measured and exercised to both positions at refueling.
- Valve 4.5.1.1 IWV-3521 Inboard Full-stroke exercise Relief Granted
- . VR-17*
Test isolation and leak test each (g)(6)(i) frequency.
reactor head refueling outage.
spray line isolation check valves:
2(3)-205-27 Valve 4.6.1.1 IWV-3521 Inboard and Full-stroke Relief Granted VR-21 Test outboard exercised closed (g)(6)(0 frequency.
feedwater each refueling header
- -outage.
isolation check valves:
2p~-0220-58A,
- 8, -62A, &
~628
I Page ~o.
06122/90 5
RELIEF TER REQUEST SECTION NUMBER Valve 4.6.2.1 VR-20 Valve 4.7.1.1 VR-11 Valve 4.8.1.l VR-12 Valve 4.9.1.l VR-13 Valve 4.10.1.1 VR-14 DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 SER TABLE 1
SUMMARY
OF RELIEF REQUESTS SECTION XI EQUIPMENT REQUIREMENT IDENTIFICATION
& SUBJECT IWV-3521 Hi!1h pressure Test inJection frequency backflow prevention check valves:
2(3)-0220-59 IWV-3521 Isolation Test condenser frequency.
makeup check valves:
2~3)-1301-11,
- 6 &
2(3)-4107-501 ALTERNATE METHOD OF
- TESTING Ful 1-stroke exercised closed each refueling outage.
RELIEF REQUEST STATUS Relief Granted
- (g)(6)( i)
Verify full-stroke Relief Granted capabilit{ by sample (g)(6)(i) disassemb y and inspection as described in IST program.
IWV-3521 Standb{ liquid Exercise open and Relief Granted Test contro system leak test each (g)(6)(i) frequency.
injection refeuling outage.
& - 6 IWV-3521 Core spray Verify closure
, Relief Granted Test system keep capabilitl by sample ~g)(6)(i) frequency and fill check disassemb y and rovided the method.
valves:
inspection as valve series is 2(31-1402-34A described in IST leak tested
& - 4B program.
each refueling outage.
IWV-3521 Low pressure Verify closure Relief Granted Test coolant capabilitl by sample ig)(6)(i) frequency and injection disassemb y and rovided the method.
system keep inspection as valve series is fill check described in IST leak tested valves:
program.
each refueling 2(3~~1501-67A outage.
& - 78.
e e
.Page No.
6 06/22/90 DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 SER TABLE 1
SUMMARY
OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE RELIEF REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF REQUEST NUMBER
& SUBJECT TESTING STATUS Valve Deleted VR-7 Valve 4.3.3.1 IWV-3513 Main steam Replace or test half Relief Denied VR-2 Test sample safety valves: of these valves each expansion.
2{3)-0203-4A refueling outage.
through -4H Valve 4.3.3.2 IWV-3521 MSIV air Full-stroke exercise Relief Granted VR-23 Test accumulator each refueling
{g)(6)(i) frequency.
check valves outage.
listed in IST program.
Valve 4.11.1.1 IWV-3521 TIP system Full-stroke exercise Relief Granted DAIM-V21 Test purge check each cold shutdown
{g)(6)(i) frequency.
valves:
when the containment 2(3)-4799-514 is de-inerted and each refueling outage.