ML17304A748
| ML17304A748 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 11/15/1988 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17304A747 | List: |
| References | |
| NUDOCS 8811220267 | |
| Download: ML17304A748 (12) | |
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UNITEDSTATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 ENCLOSURE 1
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE INSERVICE TESTING PROGRAM AND RE UESTS FOR RELIEF ARIZONA NUCLEAR POWER PROJECT PALO VERDE NUCLEAR GENERATING STATION UNITS 1
2 AND 3 DOCKET NO.:
50-528/529/530 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 50.55a(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 difficulties without a compensating increase in the level of quality and safety, or (3) conformance with certain requirements of the applicable Code edition and addenda is impractical for its facility.
The Regulations, 10 CFR 50. 55a(a) (3) (i), (a) (3)(ii), and (g) (6) (i),
authorize the Commission to grant relief from these requirements upon making the necessary findings.
The NRC staff's findings with respect to granting or not granting the relief requested as part of the Arizona Nuclear Power Project's (the licensee's)
IST Program are contained in the Safety Evaluation (SE) issued on the licensee's program.
The IST program addressed in this report covers the first ten-year inspection intervals beginning with the start of the commercial operation for each unit. The first ten year intervals are January 28, 1986 to January 28, 1996 for Unit 1; September 30, 1986 to September 30, 1996 for Unit 2; and January 8,
1988 to January 8, 1998 for Unit 3.
The licensee's program is described in a letter dated September 10, 1987 which supersedes all previous submittals.
Additional information was submitted in a letter dated August 2, 1988.
The program is based on the requirements of Section XI of the ASME Code, 1980 Edition through the Winter of 1981 Addenda, and remains in effect until the end of the first 10 year intervals.
88ii220267 88iii5 PDR ADOCK 05000528 p
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EVALUATION The Regulation, 10 CFR 50.55a(g)(4)(i),
requires that during the initial 120 month interval, the IST program shall comply with the latest edition and addenda of the Code incorporated by reference in 10 CFR 50.55a(b) on the date 12 months prior to the date of issuance of the operating license.
This corresponds to 1980 Edition through the Winter of 1981 Addenda (80W81) for Units 1 and 2 and 1983 Edition through the Summer of 1983 Addenda (83S83) for Unit 3.
A review of the differences between the 80W81 and the 83S83 Code requirements indicates that there are only minor editorial changes in the area of inservice testing and that the licensee's IST program would not be affected by the use of either edition and addenda.
The IST program and the requests for relief from the requirements of Section XI have been reviewed by the staff with the assistance of its contractor, EG&G, Idaho, Inc.
(EG&G).
In addition, EG&G and staff members met with licensee representatives on May 27 and 28, 1987 in a working session to discuss questions 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 determi-nations 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.
In the TER, EG&G identified a number of deficiencies and inconsistencies in the Palo Verde 1, 2, and 3 IST program.
One relief request is denied (TER section 4.5.1.4) and seven relief requests are granted with cer tain conditions (TER sections 3.2.2, 3.2.3, 4.3.1.1, 4.5.1.2, 4.5.2.3, 4.5.1.3, and 4.5.1.4).
The licensee should refer to the specific TER sections for a detailed discussion of these cases.
These items are also included in TER Appendix C which lists the IST program anomalies identified during the review.
The licensee should resolve all the items listed in Appendix C in accord-ance with the staff positions.
Required program changes should be made within 90 days of receipt of this SE.
INSPECTION An inspection of the Palo Verde 1, 2, and 3 IST programs should be conducted by Region V.
The inspection should focus on the adequacy of procedures for implementing the IST program and on the adequacy of licensee's actions to resolve the items addressed in Appendix C of the TER.
CONCLUSION Based on the review of the licensee's program and relief requests, the staff concludes that the IST program as evaluated and modified by this SER 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 50.55a(a)
(3)(i) or (9)(6)(i), is authorized by law and will not endanger life or property, or the common defense and security and is othe'rwise in the public interest.
In making this determination the staff has considered the alternate testing being implemented and the impracticality of performing the required testing considering the burden if the requirements were imposed.
The last column of Table I identifies the regulation under which 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 summarized in the TER Appendix C.
The IST program for Palo Verde 1, 2, and 3, as documented through the submittal dated August 2, 1988, is acceptable for implementation provided that the items noted above are corrected promptly.
Relief requests contained in any subsequent revisions may not be implemented without prior approval by NRC.
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Page No.
08/29/88 1
PALO VERD CLEAR GENERATING STATION, UNI 1, 2, AND 3 SER TABLE 1
SUMMARY
OF RELIEF REQUESTS RELIEF
- TER, SECTION XI EQUIPMENT REQUEST SECTION REQUIREMENT IDENTIFICATION NUMBER
& SUBJECT ALTERNATE METHOD OF TESTING ACTION BY USNRC Pump 3.2.2 RR 1
IWP-3100 Flow AFN-P01, rate AFA-P01, and measurement.
AFB-P01.
Measure all parameters during cold shutdown full flow test.
Rel ief
- Granted, provided measurements taken as discussed in Pump 3.2. 1 RR 2 IWP-3100 Inlet and differential pressure measurements.
CHA-P01, CHB-P01, CHE-P01,"
SIA-P05, and SIB-P05.
TER section 3.2.2.2.
(g)(6)(i)
Set discharge Rel ief pressure and measure Granted.
and trend pump flow (a)(3)(i) rate.
Pump 3.3. 1 IWP-3100 RR 3 Measure pump vibration.
DFA-P01 and DFB-P01.
None.
Rel ief Granted.
(g)(6)(i)
F Pump 3.1.1 RR 5
IWP-4120 Full SIA-P01 and scale range SI B-P01.
of instruments.
Utilize installed instrumentation.
Rel ief Granted.
(a)(3)(i)
Pump 3.2.3 IWP-3100 Flow RR 6 rate measurement.
SIA-P01, SIB"P01, SIA-P02, SIB-P02, SIA-P03, and SIB-P03.
Measure all parameters during refueling outage full flow test.
Relief
- Granted, provided measurements taken as discussed in TER section 3.2.3.2.
(9)(6)(i)
Valve 4.2.1.1 IWV-3521 Test CHB-V305 and RR 6 frequency.
CHA-V306.
Full-stroke exercise Relief during refueling Granted.
outages.
(g)(6)(i)
Valve 4.3.1.1 IWV-3413
'RR 16 Stroke time measurement.
DGA-UV-3, 5, 7, 9, ll, 15, DGB-UV-4, 6, 8, 10, 12, and 16.
Measure diesel generator start time.
Rel ief
- Granted, provided valves tested as discussed in TER section 4.3.1.1.2.
(g)(6)(i)
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Page No.
- 08/29/88 O
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2 PALO VERDE LEAR GENERATING STATION, UNI, 2, AND 3 SER TABLE '1
SUMMARY
OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT REQUEST SECTION REQUIREMENT IDENTIFICATION NUMBER 8 SUBJECT ALTERNATE METHOD OF TESTING ACTION BY USNRC Valve RR 23 4.4.1.1 IWV-3522 SGE-V642, Verify valve V652, V653, closure.
and V693.
Verify in-series valves'losure during refueling outages.
Rel ief Granted.
(g)(6)(
)
Valve RR 28 4.5.2.1
.IWV-3521 Test frequency.
SI E"V113, V123, V133,
- V143, SIA-V404, and SIB"V405.
'ull-stroke exercise Relief during refuel ing Granted.
outages.
(g)(6)(i)
Valve RR 30 4.5.2.2 IWV-3521 Test SIA-V157, frequency.
SIB-V158, SIA-V201, and SIB-V200.
Full -stroke exercise Relief during refueling Granted.
outages.
(g)(6)(i)
Valve RR 31 Valve RR 32 4.5.1.2 4.5.2.3 IWV-3522 Full-stroke exercise.
IWV"3522 Full-stroke exercise.
SIA-V164 and S IB"V165.
SIA-V205 and SI B-V206.
Disassembly/inspec-tion once per 5
years.
Sample disassembly/inspec-
, tion every fourth refueling outage.
Rel ief
- Granted, provided valves tested as discussed in TER section 4.5.1.2.2.
(g)(6)(i)
Rel ief
- Granted, provided valves tested as discussed in TER section 4.5.1.2.2.
(g)(6)(i)
Valve RR 33 4.5.1.3 IWV-3521 Test SIE-V215, frequency.
V225, V235, and V245.
Partial-stroke exercise during refueling outages and sample disassembly/inspec-tion every second refueling outage.
Rel ief
- Granted, provided valves tested as discussed in TER section 4.5.1.2.2.
(g)(6)(i)
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Page No.
08/29/88 3
PALO VERD CLEAR GENERATING STATION, UNI, 2, AND 3 SER TABLE 1
SUMMARY
OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT REQUEST SECTION REQUIREMENT IDENTIFICATION NUMBER 5 SUBJECT
. ALTERNATE METHOD OF TESTING ACTION BY USNRC Valve RR 34 Valve RR 34 4.5.1.4 4.5.1.4 IWV-3522 Full-stroke exercise.
IWV-3522 Full-stroke exercise.
SIE"V217, V227, V237, and V247.
S IE-V217, V227, V237, and V247.
Sample disassembly/inspec-tion during refueling outages.
Utilize ul trasonic methods to verify full-stroke capability.
Rel ief
- Granted, provided valves tested as discussed in TER section 4.5.1.2.2.
(g)(6)(i)
Relief Denied.
Valve RR 35 4.5.1.1 IWV-3521 Test SIA-V522, frequency.
- V523, SIB-V532, and V533.
Full-stroke exercise Relief during refueling Granted.
outages.
(g)(6)(i)
Valve
- 4. 1.1.1 IWV-3420 Leak Containment RR 41 rate testing.
isolation valves.
10 CFR 50, Appendix Relief J testing and Granted.
compliance with (a)(3)(i)
IWV-3426 and 3427.
Valve 4.1.2.1 RR 44 IWV-3417(a)
Al 1 power Corrective operated action valves.
requirements.
Take corrective action if stroke time exceeds fixed reference value.
Rel ief Granted.
(a)(3)(i)
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