ML17349A353
| ML17349A353 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 08/20/1992 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17349A352 | List: |
| References | |
| NUDOCS 9208280414 | |
| Download: ML17349A353 (8) | |
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- +~ i UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON. O.C. 20666 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION R LATED TO THE INSERVICE TESTING PROGRAM AND RE VEST FOR RELIEF FLORIDA POWER AND LIGHT COMPANY TURKEY POINT UNITS 3 AND 4 DOCKET NOS.
50-250 AND 50-251
- 1. 0 INTRODUCTION The Code of Federal Regulations, 10 CFR 50.55a(g),
requires that inservice testing (IST) of certain ASME 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 Subsections (a)(3)(i),
(a)(3)(ii), or (g)(6)(i) of 10 CFR 50.55a.
In requesting relief, the licensee must demonstrate that:
(1) the proposed alternative provides an acceptable level of quality and safety; (2) compliance would result in hardship or unusual difficulty 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.
Generic Letter (GL) 89-04, "Guidance on Developing Acceptable Inservice Testing Programs" provides alternatives to Code requirements which have been determined by the staff to be acceptable, provided that the alternatives are implemented in accordance with the guidance delineated in the applicable positions.
These regulations authorize the Commission to grant relief from ASME Code requirements upon making the necessary findings.
The NRC staff's findings with respect to granting or not granting the reliefs requested as part of the licensee's IST Program are contained in this Safety Evaluation (SE).
This SE covers revised relief requests VR-2, VR-6, VR-9, VR-ll, VR-12, VR-13, VR-14, VR-29 and VR-30 and new relief requests PR-12, VR-28, and VR-33 as described in Florida Power and Light Company's letter dated May 14,
- 1992, which superseded all previous submittals.
The remaining relief requests were evaluated in NRC's SE dated September 21, 1991.
The licensee's program is based on the requirements of Section XI of the ASME Code, 1980 Edition through the Winter of 1981 Addenda.
2.0
~EVA UATIO The licensee's
!ST Program requests for relief from the requirements of Section XI have been reviewed by the staff with assistance of its contractor, EGKG Idaho, Inc.
(EGSG).
The Technical Evaluation Report (TER) provided as Enclosure 2 is EG8G's evaluation of the licensee's IST Program relief requests.
The staff has reviewed the TER and concurs with the evaluations and 0
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conclusions contained in the TER.
A summary of the pump and valve relief request determinations 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.
3.0 CONCLUSION
Based on the review of the licensee's IST Program, the staff concludes that the relief requests as evaluated and modified by this SE will provide reasonable assurance of the operational readiness of the pumps and valves to perform their safety-related functions.
The staff has determined that granting relief, pursuant to 10 CFR 50.55(a)(3)(i), (a)(3)(ii) and (g)(6)(i),
is authorized by law and will not endanger life or property, or the common defense and security and is otherwise in the public interest.
In making this determination the staff has considered the alternative testing being imple-
- mented, compliance resulting in a hardship without a compensating increase in
- safety, and the impracticality of performing the required testing considering the burden if the requirements were imposed.
The last column of Table 1
identifies the regulation under which each requested relief is granted.
During the review of the licensee's IST Program, the staff has identified certain misinterpretations or omissions of Code requirements.
These items are summarized in the TER.
The IST Program relief requests evaluated in the TER for Turkey Point Units 3 and 4 provided by the licensee's submittal dated May 14,
- 1992, are acceptable for implementation provided that the changes and actions described in the TER are completed as set forth in this SE.
Principal Contributor:
F. Grubelich Date:
August 20, 1992
.page No.
08(04/92 TURKEY POINT, UNITS 3 AND 4 SER TABLE 1 SUNNRY OF RELIEF REQUESTS RELIEF TER SECTION XI REQUEST SECTION REQUIREMENT NUMBER 5 SUBJECT EQUIPMENT IDENTIFICATION ALTERNATE METHOD OF TESTING ACTION BY USNRC Valve VR-2 Valve VR-6 Val ve VR-9 Valve VR-11 Valve VR-12 2.1.1.1 2.2.1.1 2.3.1.1 2.4.1.1 2.4.1.2 IWV-3413(b) and -3417:
Stroke time measurement and corrective actions IWV-3413(b) and -3417:
Stroke time measurement and corrective actions IWV-3520:
Test method and frequency IWV-3521:
Test frequency IWV-3521:
Test frequency AFW to steam generator supply valves:
CV-3(4)-2816 thru -2818 and CV-3(4)-2831 thru -2833 Charging pump to boron injection valve:
HCV-3(4)-0121 Containment spray header check valves:
3(4)-0890A and
-08908 SI hot leg injection check valves.:
3(4)-0874A and
-0874B SI cold leg injection check valves:
3 4 -0875A,
-0875C Local observer to measure stroke times as valves are cycled by manually adjusting the controller, times are not trended.
Local observer to measure stroke time as valve fs cycled by manually adjusting the controller, tfmes are not trended.
Verify open capability by sample disassembly per GL 89-04, verify closure capabilfty.
by a leak rate test every 2 years.
Full-stroke exercise open during refueling outages and verify closure at Technical Specifications frequency.
Part-stroke at cold shutdowns full-stroke at refueling outages, and verify closure by leak rate testing at TS schedule.
Interim Relief Granted (g)(6)(f) until the end of the current 10-year IST interval.
Interim Relief Granted
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until the end of the current 10-year IST interval.
Relief Granted (g)(6)(f)
Relief Granted (g)(6)(f)
Relief Granted (g)(6)(f)
Valve 2.4.1.3 VR-13 IWV-3521:
Test frequency SI accumulator discharge check valves:
3 4 -0875D,
-0875F Full-stroke exercise open with flow and verify closure by leak rate testing at refueling outages.
Relief Granted (g)(6)(f)
'Pag.e Ho.
08/04/92 TURKFY POINT, UNITS 3 AND 4 SER TABLE 1
SUMMARY
OF RELIEF REQUESTS RELIEF REQUEST NUMBER TER SECTION XI EQUIPMENT SECTION REQUIREMENT IDENTIFICATION 5 SUBJECT ALTERNATE METHOD OF TESTING ACTION BY USNRC Valve VR-14 2.4.1.4 IWV-3520:
Test method and frequency RHR cold leg injection check valves:
3(4)-08768 and
-0876C Part-stroke exercise at cold shutdowns, sample disassemble per GL 89-04 at refuelings, and leak test at TS frequency.
Relief Granted (g)(6)(i)
Valve VR-28 2.4.1.5 IWV-3521:
Test frequency PRT nitrogen supply check valves:
3(4)-0519 Full-stroke exercise Relief Granted each refueling (g)(6)(i) outage.
Val ve VR-29 Valve VR-30 2.2.2.1 IWV-3521:
Test frequency IN-3521:
Test frequency AFW pump bearing cooler check valves:
AFWU-3-0017 and 0016 Boric acid transfer pump discharge check bivalves:
3(4)-0351, 3-0397A.,
3-0397B, 4-0397C, and 4-0397D Part-stroke exercise open quarterly and disassemble and inspect during refueling outages.
Part-stroke valves 3-0397AAB and 4-0397CLD quarterly and full-stroke all valves each refueling outage.
Approved per GL 89-04, Position 2, Relief request not evaluated in TER.
Relief Granted (g)(6)(i)
Valve VR-33 PR-l2 2.5.1.1 3.1.1.1 IN-3427(b):
Leak rate test corrective action IWP-4210:
All pumps in the Pressure gage IST program liquid level Determine if liquid is in gage lines only if 1t affects differential pressure by more than 0.25%.
Various CIVs Leak rate test identified in valves in accordance the IST program with GL 89-04, Position 10.
Relief Granted per GL 89-04, Position lO, for CIVs that do not have other limited leakage functions.
Relief Granted (a)(3)(ii)