ML17223A972
| ML17223A972 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 10/17/1990 |
| From: | Berkow H Office of Nuclear Reactor Regulation |
| To: | Goldberg J FLORIDA POWER & LIGHT CO. |
| References | |
| GL-89-04, GL-89-4, TAC-74794, NUDOCS 9010240325 | |
| Download: ML17223A972 (12) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, O. C. 20555 October 17, 1990 Docket No. 50-335 Mr. J.
H. Goldberg Executive Vice President Florida Power and Light Company P.O.
Box 14000 Juno Beach, Florida 33408-0420
Dear Mr. Goldberg:
SUBJECT:
ST.
LUCIE UNIT 1 - INTERIM RELIEF FROM THE INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES (TAC NO. 74794)
On January 3, 1990, you submitted your response to Generic Letter 89-04.
Your submittal consisted of a review of your Inservice Testing
( IST) Program for the second 10-year interval, along with several requests for relief from various sections of the ASME Pressure Vessel Code.
The staff has not yet completed a
detailed review of your submittal.
- However, we have, with the help of our contractor, EG&G Idaho, completed a preliminary review.
As a result of our preliminary review, we have determined that an interim period of relief is appropriate.
The staff has determined that, for the interim period, an acceptable level of safety wi 11 be provided by your proposed alternative testing.
Therefore, the relief requests of your January 3, 1990, letter are granted with the exception of those identified in the the enclosure to this letter.
You are authorized to implement your proposed program as modified by the provisions in the enclosure, recognizing that additional restrictions could result from the staff's final review.
For the relief requests identified in the enclosure, the interim relief expires at the end of the next refueling outage or when the staff issues its Safety Evaluation (SE), whichever comes first.
for the remainder of the relief
- requests, interim relief expires when the staff issues its SE.
Since the interim approval does not represent the results of the final program review, the final SE could contain relief request denials or identify components that should be added to the St. Lucie Unit 1 Inservice Testing Program.
Until we complete our detailed review of the IST program, you should comply with both the existing Technical Specifications (TS) and the proposed IST Program as modified by the provisions of the enclosure.
In the event that conflicting requirements arise for any component, you must comply with the more restrictive requirements.
The granting of this relief from the ASME Code does not.relieve you from any of the requirements in existing TS.
90i0240325 90iOi7 PDR ADOCK 05000335 P
PDC QFo II(I
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Mr. J.
H. Goldberg October'7, 1990 The staff has determined that pursuant to 10 CFR 50.55a(g)(6)( i) and (a)(3)(i) granting the interim reliefs, as described
- above, is authorized by law and will not endanger life or property or the common defense and security.
The staff has also concluded that granting the interim reliefs is otherwise in the public interest considering the burden that could result if the requirements were imposed on the facility.
The interim reliefs will terminate upon issuance of the detailed review or the next refueling outage, whichever comes first.
S incere ly, Original signed by
Enclosure:
As stated cc w/enclosure:
See next page DISTRI BUT-ION-)
NRC
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- LA:PDI Herbert N. Berkow, Director Project Directorate II-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation AKeller 7/E/23 MSinkule RII HBerkow
- SEE PREVIOUS CONCURRENCE
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DATE
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INTERIM RELIEF ST.
LUCIE
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Mr. J.
H. Goldberg Florida Power
& Light Company St. Lucie Plant CC:
Mr. Jack Shreve Office of the Public Counsel Room 4, Holland Building Tallahassee, Florida 32304 Senior Resident Inspector St. Lucie Plant U.S. Nuclear Regulatory Commission 7585 S.
Hwy A1A Jensen
- Beach, Florida 33457 State Planning
& Development Clearinghouse Office of Planning
& Budget Executive Office of the Governor The Capitol Building Tallahassee, Florida 32301 Harold F. Reis, Esq.
Newman
& Holtzinger 1615 L Street, N.W.
Washington, DC 20036 John T. Butler, Esq.
- Steel, Hector and Davis 4000 Southeast Financial Center Miami, Florida 33131-2398 Administrator Department of Environmental Regulation Power Plant Siting Section State of Florida 2600 Blair Stone Road Tallahassee, Florida 32301 Mr. Weldon B. Lewis, County Administrator St. Lucie County 2300 Virginia Avenue.
Room 104 Fort Pierce, Florida 33450 Mr. Charles B. Brinkman, Manager Washington Nuclear Operations Combustion Engineering, Inc.
12300 Twinbrook Parkway, Suite 330 Rockville, Maryland 20852 Mr. Jacob Daniel Nash Office of Radiation Control Department of Health and Rehabilitative Services 1317 Winewood Blvd.
Tal 1 ahassee, Fl orida 32399-0700 Regional Administrator, Region II U,S. Nuclear Regulatory Commission 101 Marietta Street N.W., Suite 2900 Atlanta, Georgia 30323
ENCLOSURE REVIEM OF RELIEF REQUESTS ST.
LUCIE NUCLEAR POMER PLANT, UNIT I PUMP AND VALVE INSERVICE TESTING PROGRAM This report documents problem areas encountered during EGEG Idaho's review of the pump and valve inservice testing program relief requests submitted by Florida Power and Light Company for their St. Lucie Nuclear Power Plant, Unit 1.
The licensee's proposed alternate testing for the affected relief requests may not provide an acceptable alternative to the Code requirements, therefore, the licensee should comply with the provisions identified in this report.
Relief Re uest No.
VR-4 In Relief Request No. VR-4 the licensee has requested relief from the testing requirements of the Code for components in redundant trains when the other train is inoperable and proposed to delay testing of these components until the inoperable train has been returned to service.
When one train of a safety system is inoperable, it is important to test components in the redundant train to verify that they are operable
- and, thereby give assurance of operability of the safety system.
In fact, some plant Technical Specifications require testing of the operable train when a redundant train is inoperable.
The licensee's proposal may be non-conservative, therefore, relief shou1d not be granted.
Relief Re uest No. VR-5 In Relief Request No.
VR-5 the licensee has requested relief from the individual leak rate testing requirements of the Code for the listed valves and proposed to leak rate test these valves in groups and to apply a maximum permissible leakage rate to each combination of valves.
The licensee's proposed alternate testing may be non-conservative since it may permit excessive leakage through certain individual valves without requiring corrective actions.
Although leakage limits will be assigned for each listed containment isolation valve combination, the licensee has not indicated how these leakage limits will be determined or if they will be set so corrective action will be required when any valve in the group is
- degraded, even the smallest valve.
Each containment isolation valve should be individually leak rate tested if practicable.
Mhen valves can only practically be tested in groups, the group limit should be set such that excessive leakage through any individual valve, even the smallest, is detected and appropriate corrective actions taken.
The licensee should revise their procedures, if necessary, to ensure that leak rates for valve groups are consistent with the above approach.
R li f Re N
In Relief Request No. VR-24 the licensee has requested relief from the exercising requirements of the Code for the check valves in the nitrogen zero gas supply to the hydrogen analyzer, V-29305 and V-29306, and proposed
to verify the reverse f1ow closure of these valves simultaneously as a
pair.
These simple check valves are installed in series with no test taps between them or Other means to verify that both valves seat when flow is reversed.
The licensee proposed to test this check valve combination as a
pair to verify that at least one of the valves closes on cessation or reversa1 of flow.
This testing does not provide indication of the condition of each valve, however, it does provide positive indication that at least one va1ve in the pair is capable of performing the closed safety function.
The licensee's proposed testing gives reasonable assurance of the operational readiness of the check valve pair and may provide an acceptable alternative to the Code requirements,
- however, no mention has been made of how corrective action will be applied to these valves.
Since excessive back flow through the pair can only occur when both valves are degraded and fail to seat, if there is an indication that the closure capability of the pair of valves is questionable, both valves must be declared inoperable and be repaired or replaced before being returned to service.
Relief Re vest No.
VR-26 In Relief Request No. VR-26 the licensee has requested relief from the stroke time measurement requirements of the Code for the listed diesel fuel oil supply solenoid valves, and proposed to verify the. operability of these valves by local observation while stroking the valves and monitoring for any unusual audible noise or vibration.
These valves perform active safety functions in the open position to provide diesel fuel oil flow paths, therefore, they should be full-stroke exercised and have their stroke times measured in accordance with Section XI unless specific relief is requested and approved.
The licensee's proposed alternative for these valves provides limited information on the functioning of the valves and, therefore is acceptable on interim basis until the end of the next refueling outage.
This method provides no obgective means of determining valve degradation and is, therefore, unacceptable for the long term.
By the end oF the next refueling outage the licensee should develop a means of measuring the full-stroke times of these valves at the Code required frequency unless a
reduced test frequency is justified. It is possible that this testing could be performed during valve fail-safe testing.
The licensee should develop an alternate testing method as described above and notify the staff regarding the disposition of this relief request.
Re ief In Relief Request No. VR-33 the licensee has requested relief from the stroke time measurement requirements of the Code for the safety in)ection (SI) test line isolation valves, HCV-3618, HCV-3628, HCV-3638, and HCV-3648, and proposed to verify the operability of these valves by locally observing them as they are exercised open and closed.
These valves perfori an active safety function in the closed position to isolate the SI check valve test line, therefore, they should be full-stroke exercised and have their stroke times measured in accordance with Section XI unless specific relief is requested and approved.
The licensee's proposed alternative for these valves provides limited information on the functioning of the valves
- and,
therefore, is acceptable on an interim basis until the end of the next refueling outage.
This method provides no objective means of determining va1ve degradation and is, therefore, unacceptable for the long-term.
By the end of the next refueling outage the licensee should develop a means of measuring the full-stroke times of these valves at the Code required frequency unless a reduced test frequency is justified.
It is possible that this testing could be performed during valve fail-safe testing.
The licensee should deve1op an alternate testing method as described above and notify the staff regarding the disposition of this relief request.
Relief Re uest No. VR-35 In Relief Request No. VR-35 the licensee has requested relief from the stroke time measurement requirements of the Code for the intake cooling water isolation valves from the component cooling heat exchangers, TCV-14-4A and TCV-14-4B, and proposed to verify the operability of these valves by locally observing them as they are exercised open and closed.
These valves perform an active safety function in the open position to provide a flow path for intake cooling water from the component cooling heat exchangers, therefore, they should be full-stroke exercised and have their stroke times measured in accordance with Section XI unless specific relief is requested and approved.
The licensee's proposed alternative for these valves provides limited information on the functioning of the valves and, therefore is acceptable on interim basis until the end of the next refueling outage.
This method provides no objective means of determining valve degradation and
's, therefore, unacceptable fot the long term.
By the end of the next refueling outage the licensee should develop a means of measuring the full-stroke times of these valves at the Code required frequency unless a
reduced test frequency is justified.
It is possible that this testing could be performed during valve fail-safe testing.
The licensee should develop an alternate testing method as described above and notify the staff regarding the disposition of this relief request.
Relic Re N
n In Relief Requests Nos. VR-12, 13, and 19 the licensee has requested relief from the exercising requirements of the Code for the listed check
- valves, and proposed to disassemble and inspect these valves on a sampling basis each refueling outage.
Disassembly, together with inspection, to verify the full-stroke capability of check valves is an option only where full-stroke exercising cannot practically be performed by flow or by other positive means.
The NRC staff considers valve disassembly and inspection to be a maintenance procedure that is not a test and not equivalent to the exercising produced by fluid flow.
This procedure has some risk which may make its routine use as a substitute for testing undesirable when some method of testing is possible.
Check valve disassembly is a valuable maintenance tool that can provide a great deal of information about a valve's internal condition and as such should be performed under the maintenance program at a frequency commensurate with the valve type and service.
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The use of valve diagnostics to determine that a check valve opens fully or sufficiently to pass maximum required accident flow during a
partial flow test"is considered an acceptable means to satisfy the Code requirements.
The licensee should investigate the use of alternate testing methods to full-stroke exercise these valves, such as using non-intrusive diagnostic techniques to demonstrate whether they swing fully open during partial f1ow testing.
If the licensee's investigation reveals that full-stroke testing with flow is not feasible, then valve disassembly may be used as an alternative to Code testing provided that the licensee performs this procedure in accordance with Generic Letter 89-04 and provides an assurance of proper reassembly by performing a partial flow test or leak rate test of each valve prior to returning it to service following the disassembly and inspection procedure.
Based on the past disassembly and inspections of these valves, the licensee's proposed alternative is considered acceptable on an interim basis.
however, prior to restart from the next refueling outage, the licensee must resubmit this relief request addressing the concerns raised in the above evaluation regarding the use of non-intrusive methods, if practical, and, if not practical, the partial flow testing after reassembly.
R lief Re u t N
VR-In Relief Request No. VR-14 the licensee has requested relief from the exercising requirements of the Code for the main steamline check valves, V-08117 and V-08148, and proposed to verify valve closure by disassembly and inspection of these valves on a sampling basis each refueling outage.
The use of disassembly and inspection to verify reverse flow closure capability of check valves may be found to be acceptable depending on whether verification by flow or pressure measurements is practical.
The use of valve diagnostics to determine check valve closure upon cessation or reversal of flow is considered an acceptable means to satisfy the Code requirements.
The licensee should investigate the use of alternative testing methods, such as non-intrusive diagnostic techniques, to demonstrate that these valves swing closed upon cessation or reversal of flow.
The NRC staff considers valve disassembly and inspection to be a
maintenance procedure that is not a test and not equivalent to the exercising produced by fluid flow.
This procedure has some risk which may make its routine use as a substitute for testing undesirable when some method of testing is possible.
Check valve disassembly is a valuable maintenance tool that can provide a great deal of information about a
valve's internal condition and as such should be performed under the maintenance progratw at a frequency commensurate with the valve type and
.service.
If the licensee's investigation reveals that valve closure verification with flow is not feasible, then valve disassembly may be used as an alternative to Code testing provided that the licensee performs this procedure in accordance with Generic Letter 89-04 and provides an assurance
, of proper reassembly by performing a partial flow test of each valve prior to returning it to service following the disassembly and inspection procedure.
Based on the past disassemb1y and inspections of these
- valves, the b
1icensee's proposed alternative is considered acceptable on an interi asis.
However, prior to restart from the next refueling outage, the in crim 1icensee must resubmit this re1ief request addressing the concerns raised in the above eva1vation regarding the use of non-intrusive methods, 'f practical, and, if not practical, the partia1 flow testing after reassembly.
Relief Re uests Nos.
VR-17 2
9 30 and 3
In Relief Requests Nos.
VR-17, 22, 29, 30, and 31 the licensee has requested relief from the exercising requirements of the Code for the listed check valves, and proposed to part-stroke exercise these valves during quarterly pump testing and to disassemble and inspect them on a
sam lin basis each refueling outage.
Oisassembly, together with inspection, to verify the full-stroke capability of check valves is an option only where full-stroke exercising cannot practically be performed by flow or by other positive means.
The NRC staff considers valve disassembly and inspection to be a maintenance procedure that is not a test and not equivalent to the exercising produced by fluid flow.
This procedure has some risk which may make its routine use as a substitute for testing undesirable when some method of testing is possible.
Check valve disassembly is a valuable maintenance tool that can provide a great deal of information about a valve's internal condition and as such should be performed under the maintenance program at a frequency commensurate with the valve type and service.
The use of valve diagnostics to determine that a check valve opens fully or sufficiently to pass maximum required accident flow during a
partial flow test is considered an acceptable means to satisfy the Code requirements.
The licensee should investigate the use of alternate t ti thods to full-stroke exercise these valves, such as using non-intrusive na e
es ng diagnostic techniques to demonstrate whether they swing fully open durin partial flow testing.
pen ur ng If the licensee's investigation reveals that full-stroke testing with flow is not feasible, then valve disassembly may be used as an alternative to Code testing provided that the licensee performs this procedure in accordance with Generic Letter 89-04 and performs a partial flow test of each valve prior to returning it to service following the disassembly and inspection procedure.
Sased on the past part-stroke exercising of these valves, and past disassembly and inspections of these valves, the licensee's proposed alternative is considered acceptable on an. interim basis.
However, prior to restart from the next refueling outage, the licensee must resubmit these relief requests addressing the concerns raised in the above evaluation regarding the use of non-intrusive methods, if practical, and, if not practical, the partial flow testing after reassembly.
Relief Re uest No.
VR-20 In Relief RKjuest No. VR-20 the licensee has requested relief from the exercising requirements of the Code for the containment spray header check
- valves, V-07192 and V-07193, and proposed to disassemble and inspect them once every other refueling outage.
Disassemb1y, together with inspection, to verify the full-stroke capability of check valves is an option only where full-stroke exercising cannot practically be performed by flow or by other positive means.
The NRC staff considers valve disassembly and inspection to be a maintenance procedure that is not a test and not equivalent to the exercising produced by fluid flow.
This procedure has some risk which may make its routine use as a substitute for testing undesirable when some method of testing is possible.
Check valve disassembly is a valuable maintenance tool that can provide a great deal of information about a valve's internal condition and as such should be performed under the maintenance program at a frequency commensurate with the valve type and service.
The use of valve diagnostics to determine that a check valve opens fully or sufficiently to pass maximum required accident flow during a
partial flow test is considered an acceptable means to satisfy the Code requirements.
The licensee should investigate the use of alternate testing methods to full-stroke exercise these valves, such as using non-intrusive diagnostic techniques to demonstrate whether they swing fully open during partial flow testing.
If the licensee's investigation reveals that full-stroke testing with flow is not feasible, then valve disassembly may be used as an alternative to Code testing provided that the licensee performs this procedure in accordance with Generic Letter 89-04 and provides an assurance of proper reassembly by performing a partial flow test or leak rate test of each val,ve prior to returning it to service following the disassembly and inspection procedure.
Further it is not clear that the licensee has met the criteria of Generic Letter 89-04, Attachment I, Position 2, for extending the inspection interval for these valves.
Based on the and past disassembly and inspections of these valves, the licensee's proposed alternative is considered acceptable on an interim basis.
However, prior to restart from the next refueling outage, the licensee must resubmit this relief request addressing the concerns raised in the above evaluation regarding the use of non-intrusive methods, if practical, and, if not practical, the partial flow testing after reassembly as well as the proposed interval of disassembly.