ML17223B371
| ML17223B371 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 12/05/1991 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17223B370 | List: |
| References | |
| GL-89-04, GL-89-4, NUDOCS 9112130168 | |
| Download: ML17223B371 (4) | |
Text
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t UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE INSERVICE TESTING PROGRAM RELIEF RE UEST FLORIDA POWER 5 LIGHT COMPANY ST.
LUCIE UNIT 2 DOCKET NO.
50-389
- 1. 0 INTRODUCTION By letter dated October 6, 1983, Florida Power 5 Light Company (FPSL) submitted, the first 10-year inservice testing program for St. Lucie, Unit 2.
The program covered the interval from August 8, 1983, to August 8, 1993, in accordance with 10 CFR 50.55a and the 1980 Edition with addenda through the 1981 Winter Addendum of ASME Section XI.
The submittal included a
pump test table which identified a nuIIIber of pumps for which flow measurement was not instrumented, and for which the licensee indicated that the flow systems had fixed hydraulic resistance.
The NRC issued a Safety Evaluation (SE) on January 13, 1986, addressing the October 1983 submittal, indicating that the lack of flow instrumentation was unacceptable for long-term program implementation and granting interim relief until the next refueling outage.
In correspondence between FPEL and NRC, relief associated with flow measurement of certain safety-related pumps was at issue.
The staff position that flow instrumentation was required for certain pumps was presented in the January 1986 SE.
FP8L requested schedular relief in a letter dated March 11,
- 1986, with NRC granting extension of'he interim relief until the fall 1987 outage in an SE dated May 13, 1986.
FPSL submitted additional information supporting the impracticality of installing flow instrumentation and proposing to conduct tests on a shutdown interval in their October 13, 1986, letter.
Relief was denied in NRC's February 10, 1987, letter.
In a March 23, 1987, letter, FPEL indicated their intent to provide additional justification for not installing flow instruments.
Further information was provided in FP8L's March 23, 1988, submittal.
Extension of interim relief was requested in FP8L's November 2, 1988, letter, with NRC approval in a February 9, 1989 letter.
NRC issued Generic Letter (GL) 89-04, "Guidance on Acceptable Inservice Testing Programs,"
on April 3, 1989.
Position 9 of Attachment 1 to GL 89-04 provided NRC's position on pump testing using minimum-flow return lines with or without flow measuring
- devices, and provided an acceptable alternative for cases where flow can only be established through a non-instrumented minimum flow path during quarterly testing.
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To address the St. Lucie, Unit 2, issue, the NRC initiated a review by Oak Ridge National Laboratory (ORNL) of the FPSL pump inservice testing program for pumps without flow instrumentation.
The results of their review are provided in the attached Technical Evaluation Report which provides a feasibility study of flow measurement for the affected pumps.
2.0 DESCRIPTION
AND DISCUSSION FP&L requested relief from the requirement of IWP-4600 to measure flow rate for the following pumps:
- Boric Acid Makeup Pumps 2A/2B
- Containment Spray Pumps 2A/28
- Auxiliary Feedwater Pumps 2A/28/2C
- Low Pressure Safety Injection Pumps 2A/2B
- High Pressure Safety Injection Pumps 2A/2B
- Diesel Fuel Oil Transfer Pumps 2A/28 The licensee alternatively proposed to measure differential pressure across the pumps during quarterly pump testing and compare the values to reference values for each pump.
3.0 LICENSEE'S BASIS FOR RELIEF These pumps use a fixed hydraulic resistance system with an orifice installed in the pump recirculation line.
4.0 EVALUATION The ORNL TER provides an assessment of and recommendations relating to flow measurement for each group of pumps.
The staff endorses the recommendations presented in the TER.
- However, recommended actions may provide an assessment of a particular method ORNL has determined could be feasible.
The licensee should not consider that the method discussed in the TER is the only type of test or indicates the preferred flowpath.
Other possible methods and flowpaths may be acceptable for meeting the requirement to measure flow, including the use of temporary flow instrumentation.
The licensee must make the final determination of the test method and procedure.
The TER includes actions which could be taken for valves associated with the pump tests.
The licensee should review these recommendations, and where it is determined that the actions should be taken, applicable changes to the inservice testing program should be made.
Where the recommended action indicates that disassembly and inspection of a check valve is the best method for verifying reverse flow closure, the NRC's current position is that disassembly and inspection for verifying closure is acceptable only if no positive means from system parameters, such as cessation of flow or pressure indication, is available.
The use of non-intrusive techniques can also be acceptable for verifying the position of a check valve disk.
>>30 Additionally, Recommended Action "b" for the auxiliary feedwater pumps states that the NRC required monthly, versus quarterly, tests for AFW pumps be conducted.
This statement refers to the Technical Specifications and not the inservice testing program requirements which have specified quarterly testing in Code editions issued following the 1977 Edition.
Inservice testing of the AFW pumps could be performed concurrently with Technical Specification required testing.
5.0 CONCLUSION
S Relief is denied for not measuring flow for the subject pumps.
The licensee should review the TER recommendations and the guidelines in GL 89-04, Position 9, and provide a proposed test method and implementation
- schedule, including a schedule for any modifications required.
The information shall be submitted within 90 days of the date of this SE.
Principal Contributor:
P. Campbell Date:
December 5, 1991