ML17219A459
| ML17219A459 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 03/17/1987 |
| From: | Tourigny E Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8703250576 | |
| Download: ML17219A459 (39) | |
Text
March 17, 1987
~M+ +lb Docket No. 50-389 Licensee:
Facility:
Subject:
Introduction
'Florida Power and Light Company (FPItL)
St. Lucie Plant, Unit No.
2
SUMMARY
OF MARCH 4, 1987 APPEAL MEETING WITH FPSL AND NRC STAFF REGARDING THE INSTALLATION OF FLOW MEASUREMENT DEVICES FOR CERTAIN SAFETY RELATED PUMPS By letter dated February 10, 1987, the staff issued its supplemental safety evaluation on the above subject.
The staff concluded that flow measurement devices for certain safety-related pumps would needs to be installed per the the ASME Boiler and Pressure Vessel Code,Section XI.
The staff also advised the licensee that if FPIlAL disagreed with this staff position, FPIEL could appeal to upper NRC management.
FPSL subsequently requested an appeal meeting.
NRC staff met with FPEL personnel on March 4, 1987 in Bethesda, Maryland.
The purpose of the meeting was for FPSL to appeal the staff position on flow measure devices.
The meeting was chained by A.C. Thadani, Director, PWR Project Directorate
$8.
The agenda for the meeting is contained in Enclosure 1.
Enclosure 2 identifies the meeting attendees.
A summary of the meeting follows.
~Summar A brief history of the issue was presented.
The staff position for requiring the installation of flow measurement devices for certain safety-related pumps was first raised in the staff's safety evaluation on inservice testing of pumps and valves dated January 13, 1986.
FPSL subsequently asked for scheduler relief by letter dated March 11, 1986 which was granted by the staff by letter dated May 13, 1986.
FPSL provided additional information by letter dated October 13, 1986.
The staff's supplemental safety evaluation was issued by letter dated February 19, 1987.
The staff maintained its previous position.
The licensee's main argument was that if FPSL had to change the design of an existing system to meet a new requirement of the Code, they would not have to do so.
In this case, installing flow measurement devices for certain safety-related pumps would change the design for the related systems.
Thus, flow measurement devices do not have to be installed.
The staff did not agree with this argument but acknowledged it.
The licensee then presented a conceptual overview on how they would install the flow measurement device if they were required to.
For example, a flow measurement devise could be installed at the boric acid makeup station or adjacent to the boric acid pumps.
The licensee estimated that all changes would cost approximately
$225,000.
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"2-The licensee also outlined the proposed testing that they would perform in lieu of installing the flow measurement devices.
This outline.was basically the same proposed testing that was contained in their October 13,'986 letter, which was found unacceptable by the staff in the supplement safety evaluation dated February 10, 1987.
The staff'et independently after the licensee presented the appeal and discussed the details of the licensee's appeal.
The staff then reconvened with the licensee and presented
.the 'licensee two options.
Option. 1 was to continue to deny the licensee's relief request, and the licensee would need to go to the next appeal stage (higher NRC management-Division Director level).
Option 2 would be to go back to the original code requirements for the near term (for example measure pump delta pressure on a monthly basis versus measuring pump delta pressure and flow on a quarterly basis) and provide a submittal in a few months that would technically justify on a specific pump basis that flow measurement would not be meaningful in the licensee's case.
The licensee expressed the opinion that they are leaning toward option 2 and would like to scope it out before fully committing to it.
The licensee planned to get back to the staff shortly.
The meeting was then adjourned with the nest step to be taken by the licensee.
Enclosure 3 contains a copy of the licensee's vu-graphs.
E.
G. Tourigny, Project Manager Project Directorate ¹8 Division of PMR Licensing-B
Enclosures:
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Docket No. 50-389 UNITEDSTATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 March 17, 1987 Licensee:
Facility:
Subject:
Florida Power and Light Company (FP8L)
St. Lucie Plant, Unit No.
2
SUMMARY
OF MARCH 4, 1987 APPEAL MEETING WITH FPSL AND NRC STAFF REGARDING THE INSTALLATION OF FLOW MEASUREMENT DEVICES FOR CERTAIN SAFETY RELATED PUMPS Introduction By letter dated February 10, 1987, the staff issued its supplemental safety evaluation on the above subject.
The staff concluded that flow measurement devices for certain safety-related pumps would need to be installed per the ASME Boiler and Pressure Vessel Code,Section XI.
The staff also advised the licensee that if FP&L disagreed with this staff position, FPSL could appeal to upper NRC management, FP8L subsequently requested an appeal meeting.
NRC staff met with FPSL personnel on March 4, 1987 in Bethesda, Maryland.
The purpose of the meeting was for FP8L to appeal the staff position on flow measure devices.
The meeting was chaired by A.C. Thadani, Director, PWR Project Directorate P8.
The agenda for the meeting is contained in Enclosure l.
Enclosure 2 identifies the meeting attendees.
A summary of the meeting follows.
~Sum ar A brief history of the issue was presented.
The staff position for requiring the installation of flow measurement devices for certain safety-related pumps was first raised in the staff's safety evaluation on inservi'ce testing of pumps and valves dated January 13, 1986.
FPSL subsequently, asked for schedular relief by letter dated March 11, 1986 which was granted by the staff by letter dated May 13, 1986.
FPSL provided additional information by letter dated October 13, 1986.
The staff's supplemental safety evaluation was issued by letter dated February 10, 1987.
The staff maintained its previous position.
The licensee's main argument was that, if FP8L had to change the design of an existing system to meet a
new requirement of the Code, they would not have to do so.
In this case, installing flow measurement devices for cer tain safety-related pumps to meet a new code requirement (flow) would change the design for the related systems.
Thus, flow measurement devices do not have to be installed.
The staff did not agree with this argument but acknowledged it.
The licensee then presented a conceptual overview on how they would install the flow measurement devices if they were required to.
For example, a flow measurement device could be installed at the boric acid makeup station or adjacent to the boric acid pumps.
The licensee estimated that all changes would cost approximately
$225,000.
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The licensee also outlined the proposed testing that they would perform in lieu of installing the flow measurement devices.
This outline was basically the same proposed testing that was contained in their October 13, 1986 letter,'hich was found unacceptable by the staff in the supplemental safety'evaluation dated February 10, 1987.
The staff met independently after the licensee presented the appeal and discussed the details of the licensee's appeal.
The staff then reconvened with the licensee and presented the licensee two options.
Option 1 was to continue to deny the licensee's relief request, and the licensee would need to go to the next appeal stage (higher NRC management-Division Director level).
Option 2 would be to go back to the original code requirements for the near term (for example, measure pump delta pressure on a monthly basis versus measuring pump delta pressure and flow on a quarterly basis) and provide a submittal in a few months that would technically justify, on a specific pump basis, that flow measurement would not be meaningful in the licensee's case.
The licensee expressed the opinion that they are leaning toward Option 2 and would like to scope it out before fully committing to it.
The licensee planned to get back to the staff shortly.
The meeting was then adjourned with the next step to be taken by the licensee.
Enclosure 3 contains a copy of the licensee's vu-graphs.
Enclosures:
As stated E.
G. Tourig y, roject Manager Project Directorate 88 Division of PWR Licensing-B
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Encl'osut e 1
AGENDA March 4, l987 I:00 p.m.
OBJECTIVE: Demonstrate that design changes due to later editions of ASME Section XI are not required per 50.55a(g)(4) and based on FPL letter dated October 13, 1986, show that FPL will be in compliance, to the extent practical within the limitations of design, with ASME Section XI, I 980 Code.
I.
Introduction II.
Meaning and Intent of 50.55a(g)(3) and (g)(4)
III.
Scope of Design Changes IV.
Outline of Proposed Testing V.
Summary
Enclosure 2
NRC MEETING " IST PUMP FLOW RELIEF MARCH 4 1987 ATTENDEE Ashok Thadani Steve Frantz Dave Stewart Vernon T. Chilson Owen Rothberg Frank Cherny P.T.
Kuo Dennis Crutchfield L.B. Marsh Gary Hammer Dave Arpepper Mark Dryden C.A. Pell P.W.
Heycock Ronald J.
Stevens Renee M. Perfetti Joe Scinto J.A.
DeMastry D.G.
McDonald C. Brinkman Ed Tourigny ORGANIZATION NRC Newman 8 Holtzinger (Council for FPKL)
FP8(L FP6L NRC/NRR/DSRO/EIB NRC/NRR/DSRO/EIB NRC/NRR/PWR"B/EB NRC/NRR/PWR-B NRC/NRR/PWR-B/EB NCR/NRR/PWR"B/EB FPL/Power Plant ENgineers FPL/Nuc.
Licensing FPL/St.
Lucie FP8L/St.
Lucie FPL Nuclear Licensing NRC/NRR/DPL"B/PD-8 NRC FPAL NRC/NRR/PWR"A C-E/Bethesda
, NRC/PM for St.
Lucie
40
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Enc1osure 3
'RC MEETING PUNP FLOW RELIEF REQUEST NRCH 4,
1987 JULY 1981
'ST PROGRAM PROVIDED TO NRC OCTOBER 1981 ST, LUCIE UNIT 2 SER ilUREG 0843 SEC 3 9e6 INSERVICE TESTING OF PUMPS AND'VALVES
, BASED ON OUR PRELIMINARY REVIEW)
WE FIND THAT IT IS IMPRACTICAL WITHIN THE LIMITATIONS OF DESIGN GEOMETRY AND ACCESSIBILITY FOR THE APPLICANT TO MEET CERTAIN OF THE AMERICAN SOCIETY OF I lECHANICAL ENGINEERS CODE REQUIREMENTS IMPOSITION OF THOSE REQUIREMENTS WOULD'N OUR VIEWi RESULT IN HARDSHIPS OR UNUSUAL DIFFICULTIES WITHOUT A
COMPENSATING INCREASE IN THE LEVEL OF QUALITY OF SAF ETY i
a OCTOBER 1983 FPL LETTFR L-83-510, DATED OCTOBER 6,
1983 SUBMITTED ISI AND INCLUDED ISl PROGRAM AS AN ATTACHMENT AUGUST 1985 ONSITE REVIEW OF ISI PROGRAM NRC RI I
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JANUARY 1986 NRC SE DATED JANUARY 13)
.1986 DENIED RELIEF REQUESTS AND IHPOSED PLANT MOD IF I CAT IONS PRIOR TO STARTUP'F NEXT REFUELING OUTAGE (SPRING 1986)
NARCH 1986 '-PL LETTER L-86-101, DATED NARCH 1 l, REQUESTED RELIEF UNTIL FALL 1987
- OUTAGE, 1986 81ARCH 1986 TELECON
DATED APRIL 14'986 PROVIDED INFORMATION TO SUPPORT RELIEF UNTIL FAL'L 1987 OUTAGE'AY 1986 NRC LETTER DATED 'NAY 13'986 GRANTED EXTENSION OF INTERIM RELIEF, JULY 1986 TELECON WITH NRC STAFF DISCUSSING LEGAL INTERPRETATION NRC RESTATED STAFF POSITION 1
OCTOBER 1986 FPL LETTER
- L86404, DATED OCTOBER 13) 19861 ADDITIONAL I NFORHAT I ON FOR DETERH I NATION OF IMPRACTICALITY AND OFFERED FULL.
PUMP FLOH MEASUREMENT ON A SHUTDOHN INTERVAL DECEMBER 1986 FPL LETTER L-86-495, DATED DECEMBER 12'986'EQUESTED NRC POSITION BY JANUARY 31J 1987 I
FEBRUARY 1987 NRC LETTER DATED FEBRUARY 10,
- 1987, DENYING RELIFF REQUESTS' NARCH 1987 NEET ING WITH NRC,
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PWH 3/2/87 1
10CFR50.55a Governs design Requirements for Inservice Inspection/Test
PWH 3/2/87 2
10CFR50. 55R
~
(g)(3)(i) - ASME Class 1
~
(g)(3)(ii) - ASME Class 2 & 3
~
(g)(3)(iii) - ASME Class 1
~
(g)(3)(iv) - ASME Class 2 & 3 Class 1 Components Class 2 & 3 Components Class 1 Pumps &Valves Class 2 & 3 Pumps &Valves
... shall be designed and be provided with access to enable the performance of inservice testing of pumps and valves for assessing operational readiness set forth in Section XI of editions of the ASME Boiler and Pressure Vessel Code and Addenda applied to the construction of the particular pump or valve or the Summer 1973 Addenda, whichever is later.
Visual Examinations Monthly Test Measure S/G Stroke TemP.
Eddy Current Time Measure Seat hP Surface Examination Quarterly Test Measure Vibration Inservice Pressure Testing Well Volumetric Examination
~tr
PWH 3/2/87 3
10CFR50. 55a
~
(g)(3)(i) - ASME Class 1
~
(g)(3)(ii) - ASME Class 2 & 3
~
(g)(3)(iii) - ASME Class 1
~
(g)(3)(iv) - ASME Class 2 & 3 Class 1 Components Class 2 & 3 Components Class 1 Pumps &Valves Class 2 & 3 Pumps &Valves A Design B - Access Considerations B
isual Ex minations
- Measure Temp.
troke:
ime Measure Monthly Test S/G Eddy Current Measur Vibratio Quarterly Test Weld Volumetric Examination Seat hP Leakage Weld Surface E
mination Inservi Pressu Testi g'
PWH 3/2/87 4
~
(g)(3)(i) - ASME Class 1
~
(g)(3)(ii) - ASME Class 2 & 3 (g)(3)(iii) ASME Class 1
~
(g)(3)(iv) - ASME Class 2 & 3 Class 1 Components Class 2 & 3 Components Class 1 Pumps &Valves Class 2 & 3 Pumps &Valves A-Design B
Access Considerations 10CFR50.55a m(g)(3)
Bounda
~~:,,:. Monthly "'.,:-.'<<~>>" -:w.>',
rY4'~'=':
Test Measure S/G
+ Stroke
- , 'ddy Current:
, 'easure Vibration g. Volumetric
.~,g~rrr., Ar, Leakage
.ri"'.o"r', r..--."~.;rpc@w. Pl eSSule
~&~j~$j<~~v'j4~+rr~~~+
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PWH 3/2/87 5
Throughout the service life of a boiling or pressurized mater-cooled nuclear power facility, components (including supports) which are classified as ASME Code Class 1, Class 2 and Class 3 shall meet the requirements, except design and access provisions and preservice ezaxriination requirements set forth in Section XI of the ASME B&PV Code and Addenda... incorporated by reference in paragraph
@) of this section, to the extent practical withinthe limitations of design, geometry and materials of construction ofthe components.
l.OCmSO.55a
'l((g)(3)
B~d
'" ',;."':::--" Monthly ~>'+w R"'-'"i z-~
Test O~'
, Stroke
- . Eddy Current::
'-,::,:;,;:;::.,.',. Measure
$eat sir:iris':"'4 Weld Surface Vibration ';
Weld Volumetric
<,:,M,,-.,:. ~:, Examination
PWH 3/2/87 6
Throughout the service life of a boiling or pressurized water-cooled nuclear power facility, components (including supports) which are classified as ASME Code Class 1, Class 2 and Class 3 shall meet the requirements, except design and access provisions and preservice examination requirements set forth in Section XI of the ASME B&PV Code and Addenda... incorporated by reference in paragraph (b) of this section, to the extent practical withinthe limitations of design, geometry and materials ofconstruction ofthe components.
New Code lOCFB50.55a
%g)(3)
Bounda q
Measure Flow
- rww
- 4~@~
Test
';!Pg, ~g:,: Measure Vibration "',
Weld Voluinetric
<~
',~~y"-':: Exazninatio E'service Weld urf (Outside Limitations)
Address Practicality (WithinLimitations)
E
PWH
.3/2/87 7
Logic Flow Chart New Code Requirement 10CFR50.55a(g) (4) 10CFR50. 55a(g) (3)
YES ESIGN or CESS preclude us from meeting the equirement NO CQ Q
- (END)
Implement Program
'?
Is The Requirement Practical Prepare Relief Request Submit Program YES
'?
Proposed Alternatives Adequate 10CFR50.55a (g) (6) (i)
(g) (6) (ii)
Issue S.E.R.
Impose Augmented Requirements
10CFR50. 55a (e)(4)
Throughout the service life of a boiling or pressurized water-cooled nuclear power facility, components (including supports) which are. classified as ASME Code Class l, Class 2 and Class 3 shall meet the r'equirements, except design and access provisions and preservice examination requirements set forth in Section XI of the ASME BBiPV Code and Addenda... incorporated by refere'nce in paragraph (b) of this section, to the extent practical wi hin the limitations of design, geometry and materials of construction ofthe components.
Excerpt from:
"PART 50 STATEMENTS OF CONSIDERATION" 41 FR6256 Published 2/12/76 Effective 3/15/76 (b.
To eliminate the misconception that the design of
. components needs to be continually modified and to provide a
consistency between the design requirements for inspectability and the design requirements for construction, the provision on design requirements for inspectability of components has been changed to refer to the same code edition which is a
lied to the construction of such com onents.
4
In Order for FPL to meet the 1980 ASME Section XI Code requirement to measure flowrate on a uarterly basis, one of the following is required:
u stantia esi n an es OI'arter ant estin ut own or urvei ance
1
Flow Test Considerations strument ccU1 ac eia iit ocate esta e
in a ow at
4
~CTED SYSTEMS ECCS Purn s
~ HPSI
~ Lpsr.
~ Containment Spray Auxilia Feedwater Boric Acid Makeu Diesel Oil Transfer