ML18005A451

Provides Revised Relief Requests for Inservice Testing Program.Revised Requests Identify Proposed Alternative Method of Testing Per 880519 Discussion W/Nrc.Disagrees W/ NRC Safety Evaluation Re Submittal of Program Mods

ML18005A451
Person / Time
Site:	Harris
Issue date:	06/06/1988
From:	Loflin L CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NLS-88-134, NUDOCS 8806140269
Download: ML18005A451 (6)

Text

ACCELERATED DIORIBUTION DEMONSTliQIION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:8806140269 DOC.DATE: 88/06/06 NOTARIZED: NO -DOCKET '8 FACIL:50-400 Shearon-Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH. NAME AUTHOR AFFILIATION LOFLIN,L.I'arolina RECIP.NAME Power" & Light Co.

RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Provides revised relief requests for inservice testing program.

DISTRIBUTION CODE: A047D COPIES RECEIVED:LTR J ENCL / SIZE:

TITLE: OR Submittal: Inservice Inspection/Testing/Relief from ASME Code 9

NOTES:Application for permit renewal filed. 05000400 S

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-1 LA 1 0 PD2-1 PD 5 5 A BUCKLEY,B 1 1 D

INTERNAL: ACRS 10 10 AEOD/DOA 1 1 ,

AEOD/DSP/TPAB 1 1 ARM/DAF/LFMB 1 0 NRR/DEST/MEB 9H 1 1 NRR/DEST/MTB 9H 1 1 NUDOCS-ABSTRACT 1 1 OGC 15-B-18 1 0

.EG $ 'TlrE 01 1 1 RES/DE/EIB 1 1 EXTERNAL EG&G ROCKHOLD g H 1 1 LPDR 1 1 NL 007 HEMMING 1 1 NRC PDR 1 1 NSIC 1 1 l

D S

A TOTAL NUMBER OF COPIES REQUIRED: LTTR 31 ENCL 28

~ v Py SlNK Carolina Power 8 Light Cornpttny JUM 6 lg88 SERIAL: NLS-88-130 10CFR50.55a United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-000/LICENSE NO. NPF-63 IN-SERVICE PUMP AND VALVE TESTING PROGRAM Gentlemen:

Carolina Power R Light Company (CPRL) hereby submits for your review revised relief requests for the Shearon Harris Nuclear Power Plant In-service Testing (IST) Program.

The original "relief;request submitted for Auxiliary:Feedwater discharge check valves was denied by NRC safety evaluation (SE) dated April;27, 1988 on the basis that the proposed testing did not provide reasonable assurance of individual valve closure.

The revised relief requests identify the proposed alternative method of testing as discussed with the NRC staff and its contractor on May 19, 1988. Your review and approval of the revised requests is requested by September 1, 1988 to support Cycle 2 operations.

CPttt:L has reviewed the SE and agrees with the evaluations and conclusions contained in the Technical Evaluation Report (TER) with one exception. Appendix C, item 1, last sentence suggests that the licensee make modifications to the program and submit them to the NRC for review. We agree with program modifications where compliance to requirements is impractical, but disagree that they need to be submitted to the NRC unless they involve denied relief. Resolution of the outstanding relief requests will complete the initial licensing process for the first ten-year interval of the IST program.

The conclusion of the SE and Table 1 support this position.

If you have any questions on this subject, please contact Mr. D. B. Bates at (919) 836-6150.

Yours very truly, L.. Lof in Manag r DBB/dml (50213DK) Nuclear Licensing Section cc: Mr. B. C. Buckley Dr. 3. Nelson Grace Mr. G. F. Maxwell 411 Fayettevilte Street ~ P. O. Box 1551 o Raleigh. N. C. 27602 8S06140269 880606 PDR ADOCK 05000400 DCD

VALVE RELIEF RE UEST RV-2 System: Auxiliary Feedwater Valve: 1AF-117 Category:

Class:

Function: 1C-SAB Discharge Check Valve Test Requirements: Verify reverse flow closure.

Basis for Relief: The system has no design provision for verification of

, reverseflow closure. The only possible test method

.involves pressurizing the downstream section of pipe and monitoring an upstream tap for evidence of gross leakage. This method involves filling and draining large segments of the system. Because of the time involved, ALARAconsideration, and large amounts of wastes, it is not practical to perform testing except at refueling.

The only other alternative testing is to disassemble and visually inspect the valve.

Alternate Testing: 1AF-117 will be disassembled and visually inspected at each refueling to assure full closed position.

(5421JDK/dNI)

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VALVE RELIEF RE UEST RV-3 System: Auxiliary Feedwater Valve: lAF-20I, 202, 203 200, 205, 206 Category:

Class:

Function: Auxiliary Feedwater Pump Discharge Line to Feedwater Line Check Valves.

Test Requirement: Verify reverse flow closure.

Basis for Relief: The system has no design'provision for verification of reverse. flow closure. The only possible test method involves pressurizing the. downstream section of pipe and monitoring on upstream tap for evidence of gross leakage. This method involves filling and draining large segments of the system. Because of the time involved, ALARAconsideration, and large amounts of wastes, it is not practical to perform testing except at refueling.

The only other alternative testing is to disassemble and visually inspect each valve.

Alternate Testing: During normal plant operation, the Valves lAF-201, 202, 203, 200, 205, and 206 will be verified to be in the closed position through the continual monitoring of installed temperature elements. Unacceptable conditions require action in accordance with Plant Operating Procedures. In addition, one valve off of the Motor-Driven Train and one valve off I'urbine-Driven Train will be disassembled and inspected at each refueling, and alternate valves will be done during subsequent refuelings. Failure to pass inspection will initiate disassembly and inspection of the other valves on the same train.

(542 / JDK/dml )

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