ML17308A485
| ML17308A485 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 01/03/1990 |
| From: | Sager D FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML17223A451 | List: |
| References | |
| GL-89-04, GL-89-4, L-90-03, L-90-3, NUDOCS 9001120166 | |
| Download: ML17308A485 (20) | |
Text
ACCELERATED DIS UNCTION DEMON ON SYSTEM DOCKET 05000335 NOTES REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9001120166 DOC.DATE: 90/01/03 NOTARIZED: NO FACIL:50-335 St. Lucie Plant, Unit 1, Florida Power ight Co.
AUTH.NAME AUTHOR AFFILIATION SAGER,D.A.
Florida Power
& Light Co.
RECIP.NAME RECIPIENT AFFILIATION 4
Document Control Branch (Documen Contro Desk)
SUBJECT:
Forwards Rev 2 to-,JNS-PSL-203, "Second 10-Yr Inservice Insp Interval Inservice Testing Program...," per GL 89-04.
DISTRIBUTION CODE:
AO47D COPIES RECEIVED:LTR Q ENCL Q SIZE:
TITLE: OR Submittal: Inservice Inspection/Testing/Relief from ASME Code RECIPIENT ID CODE/NAME PD2-2 LA NORRIS,J INTERNAL ACRS NRR/DET/ECMB 9H NUDOCS-ABSTRACT OGC/HDS2 RES/DSIR/EIB EXTERNAL EG&G BROWN F B LPDR NSIC COPIES LTTR ENCL 1
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1 IO 1
1 1
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1 RECIPIENT ID CODE/NAME PD2-2 PD AEOD/DSP/TPAB NRR/DET/EMEB 9H Ge/-BPMB REG FILE '1 EG&G RANSOM,C NRC PDR COPIES L TR ENCL 1
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1 NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACI'HE.DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAMEFROM DISTRIBUTION LISIS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 26 ENCL
P.O. Box 14000, Juno Bouch, Fl 33408-0420
>AHOY,RX o >>>-'-
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~ Nuclear Regulatory Commission Attn:
Document Control Desk Washington, D ~
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2 0555 Gentlemen:
Re:
St. Lucie Unit No.
1 Docket No. 50-335 Generic Letter 89-04, Guidance on Develo in Acce table Inservice Testin Pro rams Generic Letter (GL) 89-04, "Guidance on Developing Acceptable Inservice Testing Programs, " issued by the NRC on April 3,
- 1989, requested that certain licensees
( 1 ) review their most recently submitted Inserv ice Testing Programs (IST) and implementation procedures against the positions delineated in Attachment 1 of the GL, and (2) within six months of the date of the GL confirm in writing their conformance to the stated positions.
By letter dated October 3,
1989 (L-89-3 59 ), Florida Power
& Light Company
( FPL) notified the Staff that a revised Inservice Testing Program would be submitted for St. Lucie Unit 1 by January 3,
199 0.
FPL has completed its evaluation of the St.
Lucie Unit 1
IST Program with respect to compliance with the positions delineated in the GL.
Attachment 1 to this letter is FPL '
response to the positions of GL 89-04.
FPL has revised the St.
Lucie Unit 1 IST Program which is hereby submitted (Attachment 2 ).
Revised testing procedures reflecting the requirements of the positions out 1ined in the GL and the revised IST Program will be implemented such that testing performed after May 15, 199 0 will conform to the specified requirements PDR 201 66 5 001 03 ADOCk OS000335 PDC an fpL Group companY
f I
U. S. Nuclear Regulatory Commission L-90-03 Page two In several instances, FPL has evaluated the NRC positions of the GL and determined that some deviations are required.
For those
- cases, alternative proposals are provided.
Accordingly, pursuant to 10 CFR 50.55a(g)(5)(iii),
FPL requests relief from these requirements and certain other ASME Code Requirements.
Attachment 3 is provided as a summary of all relief requests related to the Program.
These relief requests are included in the revised IST Program.
As indicated in the
- summary, in accordance with Section B of the GL, FPL considers those relief requests not specifically addressing the positions of the GL and submitted prior to April 3, 1989 to be approved.
In addition, relief requests needing approval for the timely implementation of the revised Program are so indicated.
Should there be any questions, please contact us.
Very truly yours, O(AS D. A.
ger Vice r sident St L 'l nt DAS/MSD/gp Attachments cc:
Stewart D. Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, St. Lucie Plant
e ATTACHMENT 1
RESPONSE
TO POSITIONS OF NRC GENERIC LETTER 89-04 Position 1
Full Flow Testin of Check Valves A check valve's full-stroke to the open position may be verified by passing the maximum required accident condition flow through the valve.
Any flowrate less than this will be considered a partial-stroke exercise.
A valid full-stroke exercise by flow requires that the flow through the valve be known.
Knowledge of only the total flow through multiple parallel lines does not provide verification of flowrates through the individual valves and is not a valid full-stroke exercise.
Response
For those cases where FPL is performing a full-stroke exercise of check valves using system flow, the flowrate through the subject valve will be measured or derived by physical measurement with an acceptance criteria that is equivalent to the maximum required accident flowrate through the valve.
Position la Alternative to Full Flow Testin of Check Valves Where full flow testing of a check valve, as described
- above, is impractical, it may be possible to qualify other techniques to confirm that a valve is exercised to the position required to perform its safety function.
To substantiate the acceptability of any alternative technique for meeting the Code requirements, licensees
- must, as a minimum, address and document the following in the IST Program:
1 ~
The impracticality of performing a full flow test; 2 ~
3.
A description of the alternate technique and a
summary of the respective implementing procedures; A
description of the method and results of the qualification program for the alternative technique; 4
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5.
A description of the instrumentation used and the maintenance and calibration of the instrumentation; A description"of the basis used to verify that baseline data has been generated when the valve is known to be in good working order;
6.
A description of the basis for the acceptance criteria for the alternative testing and a
description of corrective actions to be taken when the acceptance criteria are not met.
Response
There are several instances where FPL has determined that full flow testing of check valves as described in Position 1 is not practical and valve disassembly and inspection (Position 2) may also prove to be impractical.
In the cases of several safety injection system check
- valves, disassembly and inspection of valves would be considerable hardship (eg. excessive plant downtime and personnal radiation exposures) without any obvious gain in plant safety or reliability.
In these
- cases, FPL is planning to investigate alternate testing or inspection techniques that can effectively detect significant component degradation and provide the documentation and analysis of the position outlined above.
Such methods may include state-of-the-art electronic non-obtrusive
- sensors, radiography, or remote visual inspection.
If such methods prove valid, specific testing and inspection documentation willbe provided in future revisions to the IST Program Plan.
Position 2
Disassembl Alternative to Full Flow Testin of
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Check Valves As an acceptable alternate to full flow testing as described in Position 1,
- above, the NRC staff position is that valve disassembly and inspection can be used as a positive means of determining that a valve's disk willfull stroke exercise open or of verifying closure capability, as permitted by IWV-3522.
If possible, partial valve stroking quarterly or during cold shutdowns, or after reassembly must be performed.
Response
Where FPL has determined that full flow testing of check valves as described in Position 1 is not practical, valve disassembly and inspection will be performed in lieu of flow testing along with partial valve stroking periodically and following reassembly, when practical.
The specific testing and inspection plan is provided in the revised IST Program Plan.
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Position 2a.
Ins ection Procedure During valve testing by disassembly, valve internals should be visually inspected for worn or corroded
- parts, and the valve disk should be manually exercised.
Response
During valve testing by disassembly, valve internals will be inspected and exercised per the above guidelines.
Appropriate acceptance criteria willbe applied to assess valve operability.
Position 2b.
Fre uenc of Disassembl Valve disassembly and inspection may be performed during reactor refueling outages.
Since this frequency differs from the Code-required frequency, this deviation must be specifically noted in the IST Program.'esponse:
Where specified in the revised IST Program Plan, valve disassembly and inspection will be performed during reactor refueling outages or other convenient times based on the fuel cycle duration.
The revised Program Plan includes several requests for relief where this option is used.
Position 2c.
Sam lin Ins ection Plans
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Where it is determined that it is burdensome to disassemble and inspect all applicable valves each refueling outage, a
sample disassembly and inspection plan for groups of identical valves in similar applications may be employed.
Guidelines for such plans are as follows:
The sample disassembly and inspection program groups similar valves and tests one (1) valve in each group during each refueling outage.
Every valve in a group shall be the same design (manufacturer, size, model, and materials of construction) and have the same orientation.
During valve disassembly, it must be verified that the valve is capable of full stroking by manually exercising and that the internals of the valve are structurally sound (no loose or corroded parts).
I
A different valve of each group is required to be disassembled, inspected, and manually full-stroke exercised at each successive refueling outage until the entire group has been tested.
If.a disassembled valve is not capable of being full stroke exercised or there is binding or failure of valve internals, the remaining valves in that group must.
also be disassembled, inspected, and manually full-stroke exercised during the same outage.
Following this, the original sequence of inspection must be repeated unless extension of the inspection interval can be justified.
When disassembly/inspection data for a valve group show a greater than 25 percent failure rate, a determination should be made as to whether the group size should be decreased or more valves from the group disassembled during each refueling outage.
Extension of the disassembly/inspection interval to one valve every other interval, expansion of the group size above four valves, or other changes that would reduce the inspection interval for a valve to greater than 6
years should only be considered in cases of extreme hardship where the extension is supported by actual in-plant data from previous testing.
In order to support a
frequency extension to longer than 6
years the following information should be developed:
a ~
A documented report detailing the disassembly and inspection of each valve in the valve grouping, the condition of each valve, and the valve's capability to be full-stroked.
b.
A review of industry experience regarding the same type of valve used in similar service.
c ~
A review of the installation of each valve addressing the "EPRI Applications Guidelines for Check Valves in Nuclear Power Plants" for problematic locations.
Response: It is FPL's position
- that, in all
- cases, valve disassembly is burdensome as well as undesirable from the viewpoint of post-inspection reliability, and, as such, sampling plans will be utilized and applied where practical.
There are several instances where like valves in similar applications at St.
Lucie are grouped as described above.
In those instances the guidelines set forth in this position will be followed.
Position 3 - Backflow Testin of Check Valves Check valves that perform a safety function in the closed position to prevent reverse flow should be tested in a manner that proves that the disc travels to the seat promptly on cessation or reversal of flow.
Verification that a Category C valve is in the closed position can be done by visual observation, by an electrical signal initiated by a position-indicating
- device, by observation of appropriate pressure indication in the
- system, by leak testing, or by other positive means.
Response
The revised IST Program Plan will identify testing that is required (open or closed) for each check valve in the Program.
Test procedures for backflow testing check valves will be revised or developed to demonstrate that the valve is properly performing its safety function in the closed direction or that the valve is in the closed position.
Position 4
Pressure Isolation Valves PIV's All PIV's listed in the plant Technical Specifications should be listed in the IST Program as Category A or A/C valves and the Technical Specification requirements referenced in the IST Program.
All Event V valves shall be individually leak tested and evaluated against the leakage limits specified in the Technical Specifications.
Response
All PIV's listed in the plant Technical Specifications are listed in the IST Program as Category A or A/C valves.
The Technical Specification requirements are referenced in the revised Program Plan (See Relief Request VR-2).
Position 5
Limitin Values of Full-Stroke Times for Power-0 crated Valves The following guidelines are established regarding limiting values of full-stroke time for power-operated valves:
a.
The limiting value of full-stroke time should be based on the valve reference or average stroke time when it is known to be in good condition and operating properly.
b.
The limiting value should be a reasonable deviation from the reference stroke time based on valve size, valve
- type, and actuator type.
C ~
The allowable deviation in stroke time should not be so restrictive that it results in a valve being declared inoperable due to reasonable stroke time variations.
d.
The allowable deviation used to establish the limit should be such that corrective action would be taken for a valve that may not perform its intended function.
e.
In no cases shall the limiting value of full-stroke time exceed that required by the Technical Specifications or Plant Safety Analysis.
Response
FPL has reviewed the acceptance criteria for the limiting values of full-stroke times for all power-operated valves in the Program that require stroke time measurements with regards to the guidelines presented above.
Limiting values of full-stroke times and the implementing test procedures will be revised accordingly.
Position 6
Stroke Time Measurements for Ra id-Actin Valves Power-operated valves with normal stroke times of 2
seconds or less are referred to by the staff as "rapid-acting valves."
Relief may be granted from the requirements of Section XI, Paragraph IWV-3417(a) for these valves provided the licensee assigns a
maximum limiting value of full-stroke time of 2 seconds to these valves and, upon exceeding this limit, declares the valve inoperable and takes corrective action in accordance with IWV-3417(b).
Since this is a
deviation from Code requirements, it should be specifically documented in the IST Program.
Response
In conjunction with the review of all power-operated valve stroke times to be performed in response to Position 5, above, if FPL should elect to identify some valves as "rapid-acting" the requirements as set forth above will be instituted (See Request for Relief VR-3).
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Position 7
Testin Individual Control Rod Scram Valves in Boilin Water Reactors BWR's This position is not applicable to St. Lucie Plant.
Position 8
Startin Point for Time Period in TS ACTION Statements When test data is recognized as being within the Required Action Range for pumps or exceeding the limiting value of full-stroke time for valves, the associated component must be declared inoperable and the Technical Specification ACTION time clock must be started.
Response
FPL complies with this position.
Position 9
Pum Testin Usin Minimum-Flow Return Line With or Without Flow Measurin Devices In cases where flow can only be established through a non-instrumented minimum flow path during quarterly pump testing and a path exists at cold shutdowns or refueling outages allowing test performance under full or substantial flow conditions, the increased interval is acceptable provided that pump differential pressure,
- flowrate, and bearing vibration measurements are taken during this testing.
During quarterly minimum flow testing measurements of differential pressure and vibration must also be taken.
Data from both of these testing methods should be evaluated per the Code.
Since this is a
deviation from Code requirements, it should be specifically documented in the IST Program.
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In cases where only the minimum flow return line is available for pump testing and no mechanism exists for testing at full or substantial flow where flowrates can be measured, then flow instrumentation which meets the requirements of IWP-4110 and 4120 must be installed in the mini-flow test, circuit.
Licensees should ensure that if pumps are tested in a low-flow condition, the flow is sufficient to prevent damage to the pump.
Response
FPL will revise the existing plant procedures or institute new test procedures to comply with this position.
The corresponding testing requirements are identified in the revised IST Program Plan.
Position 10 Containment Isolation Valve Testin All containment isolation valves (CIV's) included in the Appendix J Program should be included in the IST Program as Category A or A/C valves.
The licensee must comply with the Analysis of Leakage Rates and Corrective Action requirements of Paragraphs IWV-3426 and 3427(a),
however, the requirements of IWV-3427(b) need not be applied.
Since this is a deviation from Code requirements, it should be specifically documented in the IST Program.
Response
All valves designated as containment isolation valves at, St.
Lucie Unit 1 are included in the IST Program as Category A or A/C valves.
FPL has evaluated the existing leakrate test acceptance criteria and will revise test procedures as required to comply with the requirements of IWV-3426 and 3427(a) except as noted in Relief Request VR-5.
Relief Request VR-34 is included in the revised program plan requesting relief from the requirements of IWV-3427(b).
Position ll IST Pro ram Sco e
Licensees should review their IST Programs to ensure that the scope of the test program is adequate and accurately reflects the requirements of Subsections IWP-1100 and IWV-1100.
Response
FPL has conducted an extensive review of plant systems and the IST Program with respect to compliance with the requirements of IWP-1100 and IWV-1100.
As a result of this and other aspects of this generic
- letter, the Program Plan has been revised to ensure that the scope is adequate and consistent with respect to the components subject to testing and the individual test requirements and the documentation requirements are properly addressed.
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