ML17227A749
| ML17227A749 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 02/26/1993 |
| From: | Sager D FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| L-93-44, TAC-M74794, NUDOCS 9303040136 | |
| Download: ML17227A749 (30) | |
Text
DOCKET 05000335
SUBJECT:
Forwards addi info
& clarifications in response to NRC 920226 ltr transmitting SE for Rev 2 of inservice testing program, replacing response to Relief Request Anomalies 12 13.
DISTRIBUTION CODE:
R047D COPIES RECEIVED:LTR L ENCL /
SIZE:
TITLE: OR Submittal: Inservice/Testing/Relief from ASME Code NOTES:
ACCEI ERAT DOCVlVlENT-DIST VTION SYSTEM REGULAT INFORMATION DISTRIBUTION STEM (RIDS)
ACCESSION(NBR 9 03040136 DOC'DATE 93 02 26 NOTARIZED'O FACIL:50-335 St. Lucie'lant, Unit 1, Florida Power
& Light Co.
AUTH.NAME AUTHOR AFFILIATION SAGER,D.A.
Florida Power
& Light Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
RECIPIENT ID CODE/NAME PD2-2 LA NORRISiJ INTERNAL: ACRS NUDOCS-ABSTRACT OGC/HDS3 RES MILLMANiG EXTERNAL'G&G BROWN r B NRC PDR COPIES LTTR ENCL 1
0 2
2 6
6 1
1 1
0 1
1 RECIPIENT ID CODE/NAME PD2-2 PD NRR/DE/EMEB 0
B REG FIL 01 SIR/EIB EG&G RANSOME g C NSIC COPIES LTTR ENCL 1
1 1
1 1
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1 1
1 1
1 1
1 NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM PI-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 21 ENCL 18
I
P.O. Box 128, Ft. Pierce, FL 34954-0128 February 26, 1993 L-93-44 10 CFR 50.4 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.
C.
20555 Re:
St. Lucie Unit 1 Docket No. 50-335 NRC TAC NO.
M74794 Additional Information-In-Service-Testin Pro ram Revision 2
On February 26,
- 1992, the NRC transmitted the Safety Evaluation (SE) for Revision 2 of the St.
Lucie Unit 1 In-Service-Testing Program (IST).
The SE identified a
number of anomalies which required additional information from FPL.
FPL letters L-92-133 dated May 11,
- 1992, and L-92-224 dated August 12,
- 1992, provided the 90 day and 6 month responses and a description of the program development process requested by the SE.
This letter provides the additional information on the Relief Request Anomalies due within 1 year of the date of the SE.
Attachment 1
is additional information and clarifications requested.
Attachment 2 replaces the response to Relief Request Anomalies Nos.
12 and 13 which were submitted by FPL letter L 224.
Please contact us if there are any questions about this submittal.
Very truly yours, D. A.
ger Vice r sident St.
L ie Plant DAS/GRM/kw cc:
Stewart D. Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, St. Lucie Plant DAS/PSL 8864-93
'7r303040236 930226 PDR ADOCK 05000335 P
PDR an FPL Group company 030Igo
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St. Lucie Unit 1 Docket No. 50-335 NRC TAC NO. M74794 Additional Information-In-Service-Testin Pro ram Revision 2
ATTACHMENT 1 Revision 2 to the St. Lucie Unit 1 Second Ten-Year IST Program.
Revision 2 incorporated NRC guidance contained in Generic Letter (GL) 89-04, "Guidance on Developing Acceptable In-service Testing Programs."
The NRC, with the technical assistance of EG&G Idaho Inc.(EG&G), reviewed and evaluated the relief requests contained in the revision and issued a Safety Evaluation dated February 26, 1992.
The NRC adopted the evaluations and conclusions contained in the Technical Evaluation Report(TER) prepared by EG&G which was enclosed with the SE.
The NRC granted the reliefs from the testing requirements pursuant to 10 CFR 50.55a(a)(3)(i),
10 CFR 50.55a(a) (3) (ii), or 10 CFR 50.55a(g) (6) (i).
Appendix B of the TER contained an "anomalies" section which identified items FPL was requested to address within 1 year of the date of the SE, or by the schedule requested in the specific anomaly, except for items 6, 9, 12, 13, 14, and 15.
These items were to be addressed within 6 months of the date of the SE.
The response to these items was submitted by FPL on August 12,
Item 8 required a response within 90 days of the date of the SE.
The response to this item was submitted on May 11,
The SE also requested FPL to provide a description of the process used in developing the IST program within one year of the date of the SE.
This description was submitted on August 12,
A endix B Item 1 Relief Re est PR-3 TER section 2.1.3.1 PR-3 requests relief from measuring inlet pressure before starting the pump for the test, per Section XI, Table IWP-3100-1 for all pumps in the IST program.
The licensee proposes to measure inlet pressure prior to start only if the pump is idle. If operating, only running inlet pressure will be recorded.
NRC Evaluation:
Although the Code does not specifically exempt the inlet pressure measurement when a
pump is not
- running, the provision of IWP-3400(b) only requires taking those measurements performed at reference conditions, which does not include the inlet pressure measurement required to be taken before pump start-up.
Therefore, when performing a test on a pump that is already in operation, the
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only required inlet, pressure measurement is the one taken with the pump operating at reference conditions and the requested relief is not necessary.
St. Lucie Res onse:
Relief request PR-3 has been deleted in the latest revision of the IST program.
A endix B Item 2
Relief Re uest PR-7 TER section 2.2.1.1 PR-7 requests relief from measuring flow rate per Section XI, Paragraph IWP-4600, for the diesel fuel oil transfer
- pumps, DOT lA and 1B, and proposes to calculate it based on the change in level in the fuel oil day tank over time.
NRC Evaluation:
Based on the determination that compliance with the Code requirements is impractical and burdensome, and considering the proposed alternate testing, relief should be granted provided that the results are at least as accurate as measurements taken from installed instruments meeting the Code accuracy requirements.
St. Lucie Res onse:
The scope of the Section XI, IWP-1100 testing requirements is Class 1,
2, and 3 centrifugal and displacement type pumps that are installed in light-water cooled nuclear power plants, that are required to perform a specific function in shutting down a reactor to the cold shutdown condition or in mitigating the consequences of an accident, and that are provided with an emergency power source.
Those systems not meeting this criteria need not be tested per the Code.
In addition, those systems whose safety criteria permit the system to be non-nuclear safety class and an owner optionally classifies and constructs that system, or a portion thereof, to Class 2 or Class 3 requirements, the application of the rules of IWA-1300.(c) is at the option of the owner and not a requirement of this section.
Those systems which are constructed to Class 2 or 3
at the option of the owner do not fall under the scope of Section XI, IWP-1100 and therefore are not required to be tested to the Code standards.
According to Regulatory Guide 1.26, Quality Group Classifications and Standards for Water-,
Steam-,
and Radioactive-Waste-Containing Components of Nuclear Power Plants, examples of systems that are not included in quality groups 1, 2, or 3 are instrument and service air, diesel engines and their generators and auxiliary support
- systems, including diesel fuel systems.
The St. Lucie Unit 1 diesel fuel oil system was built to Class 3 at the option of FPL.
Therefore, the testing of this system is not required to be performed in accordance with the Code.
- However, since this system is important to safety, it must be tested in accordance with 10 CFR 50 Appendix B, Criterion XI, Test Control.
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Criterion XI of 10 CFR 50 Appendix B, Test Control, requires that testing be performed to demonstrate that structures,
- systems, and components important to safety will be able to perform satisfactorily in service.
The diesel fuel oil system has been included in the Unit 1 IST program administratively in order to fulfillthe requirements of 10 CFR 50 Appendix B, Criterion XI.
The IST program will be updated to reflect the non-class status of these pumps.
Since the initial submission of revision 2 of the IST program, the test flow path has been changed.
The new flow path is from one fuel oil storage tank (FOST) to the other FOST.
The new flow path allows a larger volume of fuel oil.to be transferred, extending the length of the test, and therefore improving its accuracy.
The level of one of the Unit 1 fuel oil storage tanks was measured several times in order to determine the accuracy of the measurement.
Each person performing the level measurement.
reported the exact same level.
Knowing that no method of measuring a
physical quantity is absolutely exact, the method of measuring the FOST level was assumed to be accurate to 1/16 of an inch (1/2 of the smallest division on the measuring tape).
At 110.5 gallons per inch, the 1/16 inch equals 6.9 gallons of error per measurement.
At two measurements per test, the total measurement error is 9.8'allons per test or +4.9 gallons.
The test procedure states that the preferred amount of fuel to transfer is u>3 inches".
The length of the test used to transfer 3
inches would last approximately 9.5 minutes.
The 9.8 gallon error over a 9.5 minute test equates to a calculated flow rate error of 1.0 gpm. or +0.5 gpm.
This is well within the accuracy range specified by the Code.
If a flow instrument that met the Code requirements were to be used to measure the pump flow rate of 35 gpm (1A fuel oil transfer (FOT) pump average measured flow), the instrument could have a range of up to 105 gpm (IWP-4120) with an accuracy of +24 of full scale (IWP-4600 and Table 4110-1).
This would require the measurements taken during the test to be within +2.1 gpm.
A endix B Item 3
Relief Re uest PR-8 and PR-11 TER section 2 '.2.1 PR-8 and PR-11 requests relief from measuring inlet and differential pressure per Section XI, Table IWP-3100-1, for boric acid make up (BAM) pumps,lA and 1B, intake cooling water (ICW)
- pumps, 1A, 1B, and 1C, and diesel fuel oil transfer (FOT) pumps,1A and 1B.
The licensee proposes to measure the height of fluid above the pump suction and calculate inlet and differential pressure.
NRC Evaluation:
Since direct measurement of inlet and differential pressure is impractical and burdensome, relief should be granted provided that The Total Error is determined using the Sum of the Squareg of the fndjvfdual volume measurement errors.
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the calculated inlet and differential pressures are determined at least as accurately as would be indicated by installed instruments meeting the Code accuracy requirements.
St. Lucie Res onse:
The BAM storage tank levels are measured using level instruments that. are accurate to +0.54.
The level reading is used to calculate the height of boric acid in the suction line to the pump (Height =
(%Level x 0.2)
+
7 ft.).
The expected range of suction pressure for the BAM pumps is from 7 feet
(
04 level) to 27 feet (1004 level).
The minimum increment on the level instruments is 2%.
Assuming an error of +1/2 gage increment or +14 combined with the 0.5% accuracy of the gage, the total error would be +1.5
~ for the level measurement.
This is within the limits of+ 24 for pressure measurement specified in IWP-4600 and Table 4110-1 of the Code.
The FOT pump suction pressure is calculated based upon the level of the tank.
As stated in the PR-7 response, the assumed accuracy in measuring the tank level is 1/16 of an inch or 0.0052 feet.
The normal range in the FOST level is from 12.8 feet to over 15 feet.
The error in measuring the tanks level is (0.0052 ft./15 ft) x 1004 or
.035%.
This is within the limits of
+24 for pressure measurement specified in IWP-4600 and Table 4110-1 of the Code.
The ICW pump suction pressure is calculated by measuring the sea water level at the intake structure.
The level marker has 5
divisions per foot and is numbered such that 0.0 feet on the marker is 18 feet above the suction of the pump.
Assuming an error of +
1/2 division or O.l ft., and an average intake level of 0.0 feet, results in an error of (0.1 ft./18 ft.) x 100%
or 0.67 percent.
This is within the limits of +24 for pressure measurement specified in IWP-4600 and Table 4110-1 of the Code.
A endix B Item 4 Relief Re uest VR-1 TER section 3.1.1.1 VR-1 requests relief from the test frequency requirement for all valves that cannot be exercised at power per Code paragraphs IWV-3412, -3415, and -3522.
The licensee proposed to test them during cold shutdowns on a deferred basis, if required.
NRC Evaluation:
Based on the determination that the proposal provides a reasonable alternative to the
- Code, and considering the hardship on the licensee without a compensating increase in safety if the Code test frequency requirements were imposed, relief should be granted as requested.
However, it is limited to those valves that can be tested during any cold shutdown.
Relief is denied for valves that cannot be tested during any cold shutdown of sufficient duration to complete testing.
St. Lucie Res onse:
St. Lucie agrees.
The purpose of this relief request is to avoid any delays in starting up due to IST testing following a brief cold shutdown period.
Any pumps or valves which cannot be tested during any cold shutdown period of sufficient duration to complete testing will have their own individual relief request submitted.
A endix B Item 5 Relief Re uest VR-4 VR-4 requests relief from the test frequency requirement for safety-related pumps or valves that must be removed from service for testing.
The licensee proposes to defer testing when the redundant subsystem is out of service for maintenance for repairs, and to perform the testing after the out of service subsystem is returned to service.
NRC Evaluation:
This issue is addressed and the requirements are stated in plant Technical Specifications.
Therefore, this relief request is not evaluated in this TER.
St. Lucie Res onse:
VR-4 has been withdrawn from the IST program in revision 3.
A endix B Item No.
7 Relief Re uest VR-9 TER section 3.2.1.2 VR-9 requests relief from the test frequency requirements of.
Section XI, paragraph IWV-3521, for the HPSI pump discharge check valves V-3405, -3414, and -3427.
The licensee proposed to manually exercise them closed quarterly and full-stroke exercise them open each refueling outage.
NRC Evaluation:
Based on the determination that compliance with the Code is impractical and burdensome, and considering the proposal, relief should be granted provided that the licensee develops a method to partial-stroke exercise these valves open on the approach to cold shutdown, if practicable, and verifies that they fully close when they are manually stroked closed.
St. Lucie Res onse:
The 1C HPSI Pump has been permanently removed form service by PC/M 028-190.
The 1C HPSI pump and its associated
- valves, V-3102~ and V-3405, have been removed by revision 3 to the IST Program.
The Unit 1 procedures will be modified to record the partial stroke open tests of the lA and 1B HPSI pump discharge stop check valves during the start-up following a cold shutdown.
These tests will be performed following. a cold shutdown as specified in VR-1.
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Ipartial-stroke exercise of these valves is performed while filling the SITs in preparation for start-up.
The test procedures presently perform a back flow test on the 1A and 1B HPSI pump discharge stop check valves during the normal quarterly valve testing.
A endix B Item 10 Relief Re uest VR-6 VR-6 requests relief from the test frequency requirements of Section XI, Paragraph IWV-3521, for check valves in the charging pump suction lines from the boric acid makeup
- system, V-2177,
- 2190, and -2191.
The licensee proposes to full-stroke exercise these valves each refueling outage.
NRC Evaluation:
Based on the determination that compliance with the Code frequency requirements is impractical and burdensome, and considering the proposal, relief should be granted provided the licensee develops a method to partial-stroke exercise these valves when approaching cold shutdown or documents the reason this testing is impractical.
St. Lucie Res onse:
St.
Lucie Unit 1 test procedures have been modified to include partial-stroke exercising of these valves when approaching cold shutdown.
A endix B Item No.11 Relief Re uest VR-27 TER section 3.5.1.1 VR-27 requests relief from the stroke time measurement requirements of Section XI, paragraph IWV-3413(b), for the diesel air start
- valves, FCV-59-1A1 through 4A1, 1B1 through
- 1B4, SE-59-3A through
-6A and
-3B through
-6B.
The licensee proposed to measure the emergency diesel generator start times in lieu of stroke timing the above valves.
NRC Evaluation:
Based on the impracticality of measuring valve full-stroke times, the burden on the licensee if the Code requirements are
- imposed, and considering the proposed alternate
- testing, interim relief should be granted for one year or until the end'f the next refueling outage, whichever is longer, During this interim period the licensee should develop a
method of monitoring for valve degradation or demonstrate the adequacy of the proposed testing.
St. Lucie Res onse:
The scope of the Section XI, IWV-1100 testing requirements is Class 1,
2, and 3 valves (and their actuating and position indicating systems) in light-water cooled nuclear power plants, which are required to perform a specific function in shutting down a reactor
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to the cold shutdown condition or in mitigating the consequences of an accident.
Those systems not meeting this criteria need not be tested per the Code.
In addition, those systems whose safety criteria permit the system to be non-nuclear safety class and an owner optionally classifies'nd constructs that
- system, or a
portion
- thereof, to Class 2
or Class 3
requirements, the application of the rules of IWA-1300.(c) is at the option of the owner and not. a requirement of this section.
Those systems which were constructed to Class 2 or 3 at. the option of the owner do not fall under the scope of Section XI, IWV-1100 and therefore are not required to be tested to the Code standards.
According to Regulatory Guide 1.26, Quality Group Classifications and Standards for Water-, Steam-,
and Radioactive-Waste-Containing Components of Nuclear Power Plants, examples of systems that are not included in quality groups 1,
2, or 3
are instrument and service
- air, diesel
- engines, their generators, and auxiliary support systems, including diesel fuel systems.
The St. Lucie Unit 1 diesel air start system valves were built to Class 3 at the option of FPL.
Therefore, the testing of this system and these valves is not required to be performed in accordance with the Code.
- However, since this system is important to safety, it must be tested in accordance with 10 CFR 50 Appendix B, Criterion XI.
Criterion XI of 10 CFR 50 Appendix B, Test Control, requires that testing be performed to demonstrate that structures,
- systems, and components important to safety will be able to perform satisfactorily in service.
These valves in the diesel air start system have been included in the Unit 1
IST program administratively in order to fulfillthe requirements of 10 CFR 50 Appendix B.
The IST program will be updated to reflect the non-class status of these valves.
The alternate testing listed in the latest revision (rev. 4) to VR-27 incorporates modifications to include additional information and new alternate testing to comply with the requirements of 10 CFR 50 Appendix B, Criterion XI.
A endix B item 16 Relief Re uests VR-13 and VR-14 TER section 3.2.1.4
& 3.6.1.1 In valve relief requests VR-13 and VR-14 the licensee stated that their alternative testing satisfies the requirement of Generic Letter(GL) 98-04, Position 2
and as
- such, is considered to be approved upon submittal.
The Minutes of the Public Meetings on Generic Letter 89-04, state that the use of disassembly and inspection to verify closure capability may be found to be acceptable depending on whether verification by flow or pressure measurements is practical.
- However, the minutes further state, that for this use, the submission and approval'f a relief request before implementation is required.
NRC Evaluation:
The licensee's statement that these relief requests are approved upon submittal is in error and should be corrected.
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St. Lucie Res onse:
Position 2 of Attachment 1 to the Generic Letter states as follows:
"The most common method to full-stroke exercise a check valve open (where disk position is not observable) is to pass the maximum required accident flow through the valve.
- However, for some check valves, licensees cannot practically establish or verify sufficient, flow to full-stroke exercise the valves open.
Some examples of such valves
- are, in
- PWRs, the containment spray header check valves, and combined LPSI and safety injection accumulator header check valves Position 2 of Attachment 1 to the Generic Letter continues to state as follows:
"The NRC staff position is that valve disassembly and inspection can be used as a positive means of determining that a valve's disk will full-stroke exercise open or of verifying closure capability, as permitted by IWV-3522."
Finally, Generic Letter itself states that:
"Provided the provisions of this letter are followed, the staff has determined that relief is granted to follow the alternative testing delineated in positions 1, 2, 6 7, 9, 10, II VR-13 proposed check valve disassembly
-and inspection for the combined LPSI and safety injection accumulator header check valve.
The expected full accident flow through these valves cannot be achieved under test conditions.
These are the same valves that were addressed in Position 2 of Attachment 1 of the Generic Letter 89-04.
The Generic Letter and Position 2 of Attachment 1 continue to state that if the provisions of the letter are followed that the relief request can be assumed to be pre-approved.
Therefore, the statement in VR-13 was not in error.
VR-14 proposed check valve disassembly and inspection for the steam generator non-return check valves.
Although not specifically mentioned in Position 2 of Attachment 1,
like in VR-13, the alternate -testing of disassembly and inspection as stated in Position 2 of Attachment 1 should also apply to these valves.
The back flow test for these valves would require the entire main steam piping system to be pressurized to back seat the valves.
Pressurizing this 34 inch piping through 1 inch drain lines would take considerable effort and time.
Due to the size and weight. of these check valves, the slow pressure increase inside the 34 inch piping probably would not be sufficient to force the valve's disk firmly against its seat.
- Finally, any data collected from this type would be ambiguous and of little value when compared to the effort to perform the test.
For the reasons stated above and in the basis for relief section of VR-14 St.
Lucie considers the relief to be pre-approved.
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A endix B Item No.
17 Relief Re uest VR-14 TER section 3.6.1.1 VR-14 requests relief from the exercising method and frequency requirements of Section XI, Paragraph IWV-3520, for V-08117 and
-08148, the main steam non-return valves, and proposed to verify valve closure by disassembly, inspection, and manual exercise of these valves on a sampling basis during refueling outages.
NRC Evaluation:
Based on the determination that compliance with the Code is impractical and burdensome, and considering the adequacy of the proposed
- testing, relief may be granted provided that when disassembly and inspection is utilized in lieu of testing, the reassembled valve is part-stroke exercised prior to entering a
plant condition where it might be required to perform its safety function in the closed position. If another method is developed to verify the reverse flow closure capability of these valves, this relief request should be revised or withdrawn as appropriate.
If the licensee's investigation indicates that both standard and non-intrusive techniques are impractical for demonstrating the reverse flow closure of these valves, the technical bases for this determination should be documented.
St. Lucie Res onse:
The Unit 1
test procedures will be changed to include a
partial-stroke exercise test for the main steam non-return valves to be performed following a refueling outage prior to Mode 3.
A endix B
Item No.
18 Relief Re uest VR-20 The licensee indicated that Relief Request VR-20 is preapproved per GL 89-04.
Testing and other requirements for preapproval are explicitly stated in the generic letter and must be followed to be in compliance.
The relief request indicates that the two affected valves will be disassembled and inspected during the same period every other refueling outage.
The generic letter states that a
different valve of each group is required to be disassembled, inspected, and manually full stroke exercised at each successive refueling outage.
Therefore, the proposed interval is,an extension from the GL specified interval.
The information provided in the alternate testing section of VR-20 is not adequate to justify extension of the inspection interval for the affected valves per GL 89-04, Position 2.
The details of the analysis performed to justify the extended interval, as required by the generic letter, are assumed to be available for inspection at the plant site.
VR-20 requested relief from testing one of the two containment spray ring header check valves each outage.
It alternately proposed to test both valves every other outage.
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St. Lucie Res onse:
Both of these valves are located high in the containment building and are relatively close to each other.
The scaffolding erected for the inspection would extend above the polar crane
- track, requiring the polar crane to be placed out of service causing a
delay of work inside the containment building.
The initial intent was to request relief to inspect both valves once every other refueling outage, thereby only having to erect the scaffolding once every other outage.
However, while planning the next outage work, after GL 89-04 was issued, it was determined that the amount of additional scaffolding required to do both valves at once would cause more of a delay than doing one valve each outage.
Therefore, this relief has never been used.
One of these two valves have been disassembled and inspected during each refueling since GL 89-04.
The alternate testing section of relief request VR-20 was modified in revision 3 of the IST program.
The revised relief request now states that at least one of these valves will be disassembled, inspected, and manually stroked to verify operability during each refueling outage.
This conforms to Position 2 of the GL 89-04, and was considered approved when revision 3 was submitted.
A endix B Item 19 Relief Re uest No. VR-3 and VR-23 Relief Requests VR-3 and VR-23 are nearly identical and both request relief from the requirements of IWV-3417(a) for fast-acting valves.
NRC Evaluation:
One of these relief requests is unnecessary and should be deleted from the IST program.
St. Lucie Res onse:
VR-23 was deleted in revision 3 of the Unit 1 IST program.
A endix B Item 20 Relief Re uest VR-34 VR-34 requests relief from the leakage rate trending requirements of IWV-3427(b) for containment isolation valves (CIVs).
This request is in accordance with GL 89-04, Position 10, and is approved by the GL.
This request is not evaluated in Section 3 of the TER.
- However, some CIVs also perform a pressure isolation function and are identified to be tested as pressure isolation valves (PIVs) per the St. Lucie Technical Specifications (TS).
The response to question 51 in the Minutes of the Public Meeting on GL 89-04, indicates that PIV leakage testing should be trended per IWV-3427(b).
Therefore, VR-34 does not apply to the PIV leakage rate testing of dual function CIVs/PIVs.
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St. Lucie Res onse:
St. Lucie does not have any dual function CIVs/PIVs and does not plan to apply thi's relief to PIVs.
A endix B Item 21 Section 3.2 of IST Pro ram Section 3.2 of the licensee's IST program states that in some cases the performance of a pump may be adequate to fulfillits safety function even though there may be a value of an operating parameter that falls outside the allowable ranges as set forth in Table IWP-3200-2. It further states that should such a situation arise, an expanded allowable
[range]
may be determined, on a case-by-case basis, in accordance with IWP-3210 and ASME Code Interpretation XI-1-79-19.
NRC Evaluation:
If the limits of Table IWP-3100-2 are relaxed using, the above guidelines, the licensee should have documentation of their evaluation supporting the relaxation available for inspection.
St. Lucie Res onse:
St. Lucie uses expanded limits for the diesel generator fuel oil transfer pumps.
Due to the testing method, data scatter does not fall within the limits of Table IWP-3100-2.
Full detailed documentation is available for inspection at St. Lucie.
A endix B Item No. 22 Relief Re uest VR-11 TER section 3.2.1.1 VR-11 requests relief from the test frequency requirements of Section XI, Paragraph IWV-3521, for the LPSI header to RCS injection line check valves, V-3114, -3124, -3134, and
-3134.
The licensee proposes to full-stroke exercise them open during cold shutdowns.
Reverse flow closure will be verified in conjunction with PIV leak testing at least once every 2 years.
NRC Evaluation:
The licensee's proposal to full-stroke exercise these valves open during cold shutdowns should be acceptable.
- However, unless an adequate technical justification is provided and approved, relief should not be granted to defer verifying their reverse flow closure until once every two years in conjunction with PIV leak rate testing.
St. Lucie Res onse:
The LPSI header to RCS check valves are listed as Pressure Isolation Valves (PIV) in Technical Specification 4.4.6.2.f, Table
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3.4.6-1, Primary Coolant System Pressure Isolation Valves.
These valves are required to be leak tested at the following frequency:
1.
Prior to entering Mode 2 after refueling.
2.
Prior to entering Mode 2, whenever the plant has been in COLD SHUTDOWN for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or more and if leakage testing has not been performed in the previous 9 months.
3.
Prior to returning the valve to service following maintenance, repair or replacement work on the valve.
Data Sheet g
25 of AP 1-0010125A is the present test procedure used to measure the leakage rate (reverse flow) of these check valves.
The test utilizes the Safety Injection Tank (SIT) volume of pressurized water (200 250 psig) to pressurize the down stream side of the check valves.
The upstream Motor Operated Valves (MOV) are closed and the drain lines located between each MOV and check valve pair are opened sequentially.
Once the initial trapped volume of water is drained
- out, the check valve leakage is collected using tygon tubing and poly bottles.
The leakage volumes and collection times are used to calculate the check valve leakage rates.
The drain valves for these tests are located along the north and south walls of the west end of the pipe tunnel in the Unit 1
Reactor Auxiliary Building (RAB).
This area of the RAB is designated as a high radiation area.
The general area radiation levels vary from 20 to 30 mRem/hr in the center of the hallway.
Along the walls of the pipe tunnel where the drain valves are
- located, the contact radiation levels range from 200 mRem/hr to 1,600 mRem/hr (radiation survey HPS-38 dated 3/31/92).
The test requires at least 3 test personnel for 1 to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to properly perform the procedure.
In addition, the test personnel must handle up to several gallons of contaminated water per test, some of which could be under pressure when first vented.
Due the potential for contaminations, the personnel performing the test usually wear a
rain suit in addition to full PCs.
The plastic rain suit and the heat in the area cause the heat stress levels to be high.
Revision 4
of VR-11 has been revised to include the above information.
The Alternate Testing section has been changed to include the test frequency listed above for verifying their reverse flow closure (as per VR-2).
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St. Lucie Unit 1 Docket No. 50-335 NRC TAC NO. M74794 Additional Information-In-Service-Testin Pro ram Revision 2
ATTACHMENT 2 A
endix B Item 12 Relief Re uest VR-26 TER section 3.5.1.2 VR-26 requests relief from measuring stroke times for SE-59-1A and
-1B, the solenoid operated isolation valves in the diesel fuel oil transfer
- lines, per Section XI, Paragraph IWV-3413(b).
The licensee proposes to observe them locally during quarterly pump testing and monitor for audible noise or vibration.
Individual valve stroke times will not be measured.
NRC Evaluation:
Based on the determination that the proposal provides a reasonable short, but not a long term alternative to the Code and considering the proposal, interim relief should be granted for one year or until the next refueling outage, whichever is longer.
During this
- period, the licensee should develop a
method of accurately measuring stroke time or some other means to adequately monitor valve condition.
Revised St. Lucie Res onse:
The scope of the Section XI, IWV-1100 testing requirements is Class 1,
2, and 3 valves (and their actuating and position indicating systems) in light-water cooled nuclear power plants, which are required to perform a specific function in shutting down a reactor to the cold shutdown condition or in mitigating the consequences of an accident.
Those systems not meeting this scope criteria need not be tested per the Code.
In addition, those systems whose safety criteria permit the system to be non-nuclear safety class and an owner optionally classifies and constructs that system, or a
portion
- thereof, to Class 2
or Class 3
requirements, the application of the rules of IWA-1300.(c) is at the option of the owner and not a requirement of this section.
Those systems which were constructed to Class 2 or 3 at the option of the owner do not fall under the scope of Section XI, IWV-1100 and therefore are not required to be tested to the Code standards.
According to Regulatory Guide 1.26, Quality Group Classifications and Standards for Water-, Steam-,
and Radioactive-Waste-Containing Components of Nuclear Power Plants, examples of systems that are not included in quality groups 1,
2, or 3 are instrument and service air, diesel engines, their generators, and auxiliary support systems, including diesel fuel systems.
The St. Lucie Unit 1 diesel fuel oil system including the solenoid operated isolation valves in the diesel fuel oil transfer lines, SE-59-1A and SE-59-1B, were built to Class 3 at
the option of FPL.. Therefore, the testing of this system and these valves is not required to be performed in accordance with the Code.
- However, since this system is important to safety, it must be tested in accordance with 10 CFR 50 Appendix B, Criterion XI.
Criterion XI of 10 CFR 50 Appendix B, Test Control, requires that testing be performed to demonstrate that structures,
- systems, and components important to safety will be able to perform satisfactorily in service.
The solenoid operated isolation valves in the diesel fuel oil transfer lines, SE-59-1A and SE-59-1B, have been included in the Unit 1 IST program administratively in order to fulfillthe requirements of 10 CFR 50 Appendix B Criterion XI.
The IST program will be updated to reflect the non-class status of these valves.
The alternate testing listed in VR-26 will continue to be performed to comply with the requirements of 10 CFR 50 Appendix B.
A endix B Item 13 Relief Re uest VR-24 TER section 3.7.1.1 VR-24 requests relief from verifying individual closure for hydrogen analyzer nitrogen supply check valves, V-29305 and -29306, per Section XI, Paragraph IWV-3522(a).
The licensee proposes to test them simultaneously in the closed direction to verify at least one valve of the pair closes.
NRC Evaluation:
Based on the determination
- that, compliance with the Code requirements is impractical and burdensome, and considering the proposal, relief should be granted provided that if excessive back flow through the pair is
- observed, both valves are declared inoperable and repaired or replaced before being return to service.
The licensee might consider the use of non-intrusive techniques to individually verify the closure of these valves.
Revised St. Lucie Res onse:
The function of these two check valves has been reviewed and found not to be a safety function.
The v'alves have been deleted from the IST program and VR-24 has been withdrawn from revision 4 of the IST program.
Since these valves have no importance to safety, they need not be included in the 10 CFR 50 Appendix B testing.
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