ML17352A851

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SER Granting Relief Requests & Authorizing Alternatives Per 10CFR50.55(a)(f)(6)(i) & 10CFR50.55a(a)(3)(i) or (a)(3)(ii),for Pumps & Valves
ML17352A851
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 10/27/1994
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML17352A850 List:
References
NUDOCS 9411020113
Download: ML17352A851 (5)


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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION ELATED TO THE INSERVICE TESTING PROGRAM RE UESTS FOR RELIEF FLORIDA POWER AND LIGHT COMPANY TURKEY POINT UNITS 3 AND 4 DOCKET NUMBERS 50-250 AND 50-251

1.0 INTRODUCTION

The Code of Federal Regulations, 10 CFR 50.55a, requires that inservice testing (IST) of certain 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 alternatives have been authorized or relief has been requested by the licensee and granted by the Commission pursuant to Sections (a)(3)(i), (a)(3)(ii), or (f)(6)(i) of 10 CFR 50.55a.

In proposing alternatives or 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 difficulty without a compensating increase in the level of quality and safety; or (3) conformance is impractical for its facility.

NRC guidance contained in Generic Letter (GL) 89-04, "Guidance on Developing Acceptable Inservice Testing Programs,"

provides alternatives to the

, Code requirements determined acceptable to the staff.

Alternatives that conform with the guidance in GL 89-04 may be implemented without additional NRC approval.

Relief requests that conform with GL 89-04 are not evaluated in the TER, though they have been reviewed to determine conformance and any concerns identified by such reviews are discussed in Section 5,

" IST Program Recommended Action Items."

Section 10 CFR 50.55a authorizes the Commission to approve alternatives and to grant relief from ASME Code requirements upon making the necessary findings.

The NRC staff's findings with respect to authorizing alternatives and granting or not granting the relief requested as part of the licensee's IST program are contained in this Safety Evaluation (SE).

The IST program-evaluated in this SE covers the third 10-year IST interval for the Turkey Point Plant, Units 3 and 4.

The interval for Unit 3 began February 22,

1994, and ends February 21, 2004.

The interval for Unit 4 began April 15,

1994, and ends April 14, 2004.

The third 10-year interval IST programs are based on the requirements of the 1989 Edition of the ASME Section XI Boiler and Pressure Vessel Code (the Code).

2.0 EVALUATION The Office of Nuclear Reactor Regulation, with technical assistance from Brookhaven National Laboratory (BNL), has reviewed the information concerning IST program requests for relief submitted for the updated IST program for the Turkey Point Plant, Units 3 and 4, in Florida Power and Light Company's letter dated January 12, 1994.

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The staff adopts the evaluations and recommendations for granting relief or authorizing alternatives contained in the attached Technical Evaluation Report (TER) prepared by BNL.

Relief is granted from, or alternatives are authorized to, the testing requirements which have been determined to be impractical to perform, where compliance would result in a hardship without a compensating increase in

safety, or where the proposed alternative testing provides an acceptable level of quality and safety.

A summary of the relief requests and NRC actions is provided in Table l.

The NRC has identified a number of generic deficiencies that affect plant safety and have frequently appeared as IST programmatic weaknesses.

These are addressed by GL 89-04.

In that letter, the staff delineated positions that describe deficiencies and explained alternatives to the ASHE Code that the staff considers acceptable.

If alternatives are implemented in accordance with the relevant position in the generic letter, the staff has determined that relief should be granted pursuant to 10 CFR 50.55a(g)(6)(i)

[now (f)(6)(i)] on the grounds that it is authorized by law, 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 burden on the licensee that would result if the requirements were imposed.

For any relief granted pursuant to GL 89-04 the staff (with technical assistance from BNL) has reviewed the information submitted by the licensee to determine whether the proposed alternative follows the relevant position in the generic letter.

If an alternative conforms to a position of the generic letter, it is listed as having been approved pursuant to GL 89-04 in Table 1 of the safety evaluation.

Any action items in the relief request are addressed in the TER.

A sampling of systems was selected for a review of the scope of the IST program.

The review identified a few weaknesses or errors in the scope or in the program document that are listed in Action Item 5. 1 of Section 5 of the TER.

Test deferrals are addressed in Section 4 and in Action Items 5.5 and 5.6 of the TER.

The licensee should refer to the TER, Section 5, for a discussion of recommendations identified during the review.

The licensee should address each recommendation in accordance with the guidance therein.

The IST program relief requests are acceptable for implementation provided the action items identified in Section 5 of the TER are addressed within one year of the date of this SE or by the end of the next refueling outage, whichever is later.

The licensee should respond to the NRC within one year of the date of this SE describing actions

taken, actions in progress, or actions to be taken, to address each of these items.

The staff concludes that the r'elief 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 50.55a (f)(6)(i) and authorizing alternatives pursuant to 10 CFR 50.55a (a)(3)(i) or (a)(3)(ii) 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 granting relief pursuant to 10 CFR 50.55a(f)(6)(i),

the staff has considered the impracticality of performing the required testing and the burden on the licensee if the requirements were imposed.

Principal Contributor:

Patricia Campbell, DE/EHEB

Turkey Point Units 3 and 4 SE Table 1 - Summary of Pump and Valve Relief Requests

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PR-1 PR-2 2.1 2.2

$5.2(d), inservice test conducted at specified test reference conditions, measuring hP, flow rate and vibration.

$5.2(b), system hP varied until fiow rate equals ref.

value or flow rate varied until hP equals reference value.

Boric Acid Transfer Pumps *-P203A&B Residual Heat Removal (RHR) Pumps

  • -P210AScB.

Quarterly testing - hP and vibration measured using fixed resistance flow path.

Refueling - hP, flow rate and vibration measured using variable resistance per

.$5.2(b).

Quarterly testing-Pump hP and fiow rate varied and compared to reference values using fixed resistance test circuit per $5.2(c).

Relief granted pursuant to 50.55a(f)(6)(i).

Relief granted pursuant to 50.55a(f)(6)(i).

Cold Shutdown and Refueling - Pump hP, flow rate, and vibration recorded per

$5.2(b).

SE Table 1 (Cont'd)

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jg~pJdentification"gl:~;-'; ',"::;-,'~Method':of.'.Testing!.."'-.::..g~~'~$ '-NRC."Action'",.'~;".-'."';"";.

PR-3 PR-4 PR-5 2.3 2.4

$4.6.1.2(a), full-scale range of each analog instrument shall be not greater than 3 times the reference value.

$4.6.2.1, static correction of indicated pressure measurement for liquid in gage line producing more than 0.25% difference in reading.

$4.6.1.6, frequency response range of vibration measurement system shall be 1/3 min. pump shaft rotational speed to at least 1000 Hz.

Residual Heat Removal (RHR) Pumps

  • -P210A&B.

Allpumps in IST program Intake Cooling Water Pumps *-P9A, B, C.

Use alternate instrument accuracy acceptance criteria.

Static correction of gage line reading for pump suction pressure producing more than 0.25% difference in calculated value of pump differential pressure.

Vibration measurement system frequency response range lower limit does not meet required lower limit.

Authorized pursuant to 50.55a(a)(3)(i).

Authorized pursuant to 50.55a(a)(3)(i), with provisions.

Authorized separately pursuant to 50.55a(a)(3)(ii) by NRC letter to licensee dated May 19, 1994 (Ref.

11).

SE Table 1 (Cont'd)

C A'"j?yQ'Request;Tw Q i~,;:c~$c ',""Acr'...x"'>> Pclkloll~~g'.':g';,;";.":p VR-1

$4.3.2.1, check valve testing frequency, and $4.3.2.4(d),

valve obturator movement by disassembly and inspection at refueling outages Containment Spray System check valves 3-0890 A&B(4-0890 A&B)

Disassembly/

inspection at refueling outages, manual full-stroke operation, part-stroke open test with fiow and seat leakage test following reassembly.

Authorized per Generic Letter 89-04, Position 2.

VR-2 3.1

$4.3.2.1, check valve testing frequency Safety Injection System check valves 5-0873 A&B(4-0873 A&B), 3-0874 A&B (44874 A&B)

Seat leakage test per Tech Spec 4.4.6.2.2 and Table 3.4-1 for Pressure Isolation Valves.

Relief not required.

Accepted as a deferral, with provlslolls.