ML18153C352
| ML18153C352 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 08/27/1990 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML18153C351 | List: |
| References | |
| NUDOCS 9009110096 | |
| Download: ML18153C352 (8) | |
Text
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e UNITED STATES 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-REQUESTS-FOR RELIEF SURRY POWER STATION UNITS 1 AND 2 DOCKET NOS. 50-280 AND 50-281 INTRODUCTION The Code of Federal Regulations, 10 CFR 50.55a{g), requires that inservice testing (!ST) 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 difficulty without a compensating increase in the level of quality or safety; or (3) the 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 licensee's IST Program are contained in this Safety Evaluation (SE).
The !ST Program addressed in this report covers the second 10-year inspection interval from December 22, 1982, until December 22, 1992, for Unit 1 and from May 1, 1983, until May 1, 1993, for Unit.2. The staff reviewed IST Program Revision 4 for Unit 1 and Revision 2 for Unit 2, and which are described in a licensee letter dated September 30, 1988, which supersedes all previous submit-tals. Additional information on the IST Program was provided in letters dated February 22, 1989, and January 17, 1990.
The program is based on the requirements of Section XI of the ASME Code, 1983 Edition through the Summer 1983 Addenda.
EVALUATION 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 March 29 and 30, 1988, in a working session to discuss questions resulting from the review.* The Technical Evaluation Report (TER) is EG&G's evaluation of the licensee's IST Program and relief requests (Enclosure 2). 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 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.
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,.,, Eight reliefs were granted, including one interim relief, one relief request was partially denied (TER Section 4.5.1.1) and 16 relief requests were granted with certain conditions (TER Sections 3.2.1, 3.4.1, 3.5.1, 3.6.1, 3.3.1, 3.8.1, 3.9.1, 4.2.1.1, 4.4.2.2, 4.8.1.1, 4.9.1.1, 4.8.2.1, 4.1.4.1, 4.3.1.2, 4.2.1.2, and 4.7.1.1). Relief request V-26 (TER Section 4.4.1.1) is still under review.
Additional information will be required to complete the review, and any discrep-ancies will have to be resolved by the start of the next refueling outage.
Relief request V-30 (TER Section 4.1.1.1) is under study pending resolution of NRC Generic Issue 105, Interfacing System LOCA in LWRs.
The licensee may continue following their proposed alternative pending the staff's resolution of this generic issue. Leak testing of some valves in relief request V-27 is still under study (TER Section 4.4.1.2). Cold shutdown justification included in relief request V-21 was not evaluated. Cold shutdown justification was unacceptable (see Appendix C, Item 15). The licensee should refer to the specific TER section for a detailed discussion of these cases. These denials and conditions are listed in the TER Appendix C and in addition, Appendix C lists other IST program anomalies which were identified during the review.
- The licensee should resolve all the items listed in Appendix C in accordance with the staff positions. Required program changes should be made within 90 days of receipt of this SE.
CONCLUSION-Based on the review of the licensee's IST Program and relief requests, the staff concludes that the IST Program as evaluated and modified by this SE 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),
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 alternate testing being implemented, and the impracticality of performing the required testing, consider-ing the burden upon the licensee if the requirements were imposed.
The last column of Table 1 identifies the regulation under which the requested relief is granted.
During the review of the licensee's IST Program, the staff has identified certain inconsistencies and omissions of Code requirements. These items are summarized in Appendix C of the TER #EGG-NTA-8419 dated March 1990.
By submittal dated January 17, 1990, the IST Program for the Surry Power Station is acceptable for implementation provided omissions and inconsistencies identified in Appendix C of the TER are addressed within 3 months of receipt of this SE, unless otherwise allowed in the TER.
Relief requests contained in any subsequent revisions may not be implemented without prior approval by NRC.
Dated: August 27, 1990 Principal Contributor:
T. Sullivan
i~
RELIEF REQUEST NUMBER P-1 P-2 P-3 P-4 P-5 P-6
~
~CLOSURE 2 SURRY POWER STATION, UNITS I AND 2 SER TABLE I
SUMMARY
OF RELIEF REQUESTS TER SECTION XI EQUIPMENT SECTION REQUIREMENT IDENTIFICATION
& SUBJECT
- 3. I. I IWP-4300 and 4500 All pumps.
Measure pump bearing temperature and vibration amplitude.
3.2.1 IWP-3100 Centrifugal Measure pump charging inlet
- pum)s,
- pressure, 1~2 -CH-P-IA, differential I, and IC.
pressure, and fl ow rate.
3.4.1 IWP-3100 Safety Measure pump Injection inlet and Pum)s, differential 1(2 -SI-P-IA pressure.
and IB.
3.5.1 IWP-3100 Outside Measure pump recirculation inlet spray pumps, pressure and 1(2)-RS-P-2A differential and 28.
pressure.
3.5.2 IWP-3400 Inside Perform recirculation inservice spray pumps, testing every 1(2)-RS-P-IA
- three months. and 18.
3.6.1 IWP-3100 Auxiliary Measure pump. feedwater flow rate.
pum)s, 1A2 -FW-P-2, 3, and 38.
ALTERNATE METHOD OF TESTING Measure pump vibration velocity in accordance with ANSI/ASME OM-6 except assign minimum reference value of 0.05 in/sec.
Observe volume control tank pressure, install necessary instrumentation durinT next refue ing outage.
Monitor RWST level, install necessary instrumentation.
durinT next refue ing outage.
Install necessary instrumentation durinT next refue ing outage.
Run pumps drb to verify opera ility ever1
- quarter, compete flow test every refueling.
Install necessary instrumentation durinT next refue ing outage.
ACTION BY USNRC Interim relief granted for a*
period of three years.
Relief aranted provide instrumentation i s inst a 11 ed at next refueling.
(g)(6)(i)
Relief granted provided instrumentation is installed at next refueling.
(g)(6)(i)
Relief aranted provide instrumentation is installed at next refueling.
(g)(6)(i)
Relief ~ranted.
(9)(6)(1)
Relief granted provided instrumentation is installed at next refueling.
(g){6)( i)
I I
Page No.
06/15/90 RELIEF REQUEST NUMBER P-7 P-9 P-11 Unit 1 P-11 Unit 2 P-12 Unit I V-I 2
SURRY POWER STATION, UNITS 1 AND 2 SER TABLE l
SUMMARY
OF RELIEF REQUESTS r*
TER SECTION XI EQUIPMENT ALTERNATE METHOD OF TESTING ACTION BY USNRC SECTION REQUIREMENT IDENTIFICATION
& SUBJECT 3.7.1 IWP-3400 Residual heat Test pumps each cold Relief ~ranted.
Perform removal pumps, shutdown, but not
{9)(6)(1) inservice 1{2)-RH-P-lA more frequently than testing every and 18.
every three months.
three months.
3.3.l IWP-3100 Boric acid Observe boric acid Relief aranted Measure pump transfer stora1e tank level, provide inlet and
- pumps, insta l necessary instrumentation differential 1-CH-P-2A, 28, instrumentation is installed at
- pressure, 2C, and 2D.
durinv next next refueling.
flow rate, refue ing outage.
(g){6){i) and vibration.
3.8.1 IWP-3100 Service water Calculate inlet Relief granted Measure pump pum~s,
~ressure from river provided inlet 1-S -P-lA, 18, evel, flowrate from instrumentation
- pressure, IC.
impact reference is installed at differential point, install next refueling.
pressure, and instrumentation next (g){6){i) flow rate.
refueling.
3.9.1 IWP-3100 Diesel fuel Ensure fuel oil Relief aranted Measure pump oil pumps,
.flows when pum~s are provide inlet I-EE-P-lA, 18, running, insta 1 instrumentation
instrumentation next refueling.
pressure, and durinT next (g)(6)(i) flow rate.
refue ing outage.
4.1. 2 IWV-35I2 Various safety Main steam safety Relief not Test and relief valves tested to required.
procedure valves.
Section 4;90I,a)(2) requirements.
of PTC-25.3-I 76, other safety and jelief valves to 4.90l(c)(l).
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- Page No.
06/15/90 RELIEF REQUEST NUMBER V-5 V-14 V-20 V-21 V-26 3
e e
SURRY POWER STATION, UNITS 1 AND 2 SER TABLE 1
SUMMARY
OF RELIEF REQUESTS TER SECTION XI SECTION REQUIREMENT
& SUBJECT
- 4. 2.1.1 IWV-3521 Exercise quarterly.
4.3.1.1 IWV-3521 Exercise quarterly.
4.4:2.2 IWV-3521 Exercise quarterly.
4.4.2.3 IWV-3521 Exercise quarterly.
4.4.1.1 IWV-3521 Exercise quarterly.
EQUIPMENT ALTERNATE IDENTIFICATION METHOD OF TESTING Main feedwater Disassemble on a containment sampling basis at a isolation refueling outage check valves, frequency.
1(2)-FW-10, 41, and 72.
ACTION BY USNRC Relief granted p~ovided licensee follows guidance on disassembly and inspection in GL 89-04.
(g)(6)(i)
Charging pump discharge check valves, 1(2)-CH-258, 267, and 276.
Part-stroke exercise Relief ~ranted.
quarterly, (9)(6)(1)
LPSI pump suction check valves from the containment
- sump, 1( 2)-Sl-56 and
- 41.
full-stroke exercise each refueling.
Disassemble on a sampling basis at a refueling outage frequency.
Relief granted provided compliance with NRC staff positions on disassembly and inspection.
(g)(6)( i)
LPSI suction Part-stroke exercise Relief ~ranted.
from RWST and quarterly,
( g )( 6 )( 1) NOTE:
pump discharge full-stroke exercise cold shutdown justi-check valves, at*refueling outage fication included in 1(2)-SI-46A, frequency. Inc~~~ed __ relief request was 4gs, 50, cold shutdown
- not evaluated. Cold 1-Sl-58, and reverse fl ow closure shutdown justi fi ca-2-Sl-327
- testing.
tion unacceptable.
Safety,
- injection,.
. accumu-1 ator:
- -:dischar'.ge...,.-
1(2)-SI-107, 109, 128, 130, 145, and 147.
Full. flow test on a sampling basis at a refueling outage frequency.
. See Item 1 5,
- App. C
- Relief request
~under study, additional information required.
Page No.
06/15/90 RELIEF REQUEST NUMBER V-27 V-27 V-28 V-30 V-31 4
SURRY POWER STATION, UNITS I AND 2 SER TABLE 1
SUMMARY
OF RELIEF REQUESTS TER SECTION XI EQUIPMENT ALTERNATE METHOD OF TESTING ACTION BY USNRC SECTION REQUIREMENT IDENTIFICATION
& SUBJECT
- 4. 4.1. 2 IWV-3521 High and low Full-stroke exericse Relief ~ranted Exercise head safety open at a refueling (g}(6){1) quarterly.
injection outafe frequencb, except the leak isolation veri y closure y testing of some check valves leak testing valves is still to the RCS hot according to Tech.
under study.
and cold legs. Specs..
4.. 4.2.1 IWV-3521 Safety Full-stroke exercise Relief granted.
Exercise injection line during refueling (g)(6)(i) quarterly.
check valves, outages when reactor 1~2)-Sl-224, vessel head is 2 5, 226, 227, removed.
228, and 229.
4. 5. 1. 1 I WV -3 5 21 Char~ing ~um~
Part-stroke exercise Relief granted Exercise suet 10n c ec during cold for exercising quarterly.
valves from shutdowns, to open refueling full-stroke during position water cross refuelina outa~es,
~g{(6)(i)
- tie, no close test1ng e 1ef denied 1(21-sI-2s, for 1(2)-SI-25.
for not testing 1-S -410, SI-25 closed.
2-SI-400.
4.1.1.1 IWV-3426 and Numerous Test in accordance Relief request 3427 reactor with Technical is under study.
Analysis of coolant system Specifications 3.1.C Licensee may leakage rates boundary and 4.3.
continue to and isolation test according corrective valves.
to TS.
action requirements.
4.6.1.1 IWV-3412 and Reactor vessel Exercise and Relief ~ranted.
3415 and fail-safe test (g)(6)( 1)
Exercise and ~ressurizer during cold fail-safe ead vents.
shutdowns when the test RCS is not quarterly.
pressurized.
I II 1
- 1 f..!
~ Page No.
06/15/90 RELIEF REQUEST NUMBER V-34 V-36 V-37 V-38 V-39 e
5 SURRY POWER STATION, UNITS 1 AND 2 SER TABLE 1
SUMMARY
OF RELIEF REQUESTS TER SECTION XI EQUIPMENT SECTION REQUIREMENT IDENTIFICATION
& SUBJECT 4.1.3.1 IWV-3417(a)
All valves Trending identified as requirements ra~id-acting for power**
va ves.
operated**
valves.
4.8.1.1 IWV-3412 Diesel fuel Exercise oil ~ump quarterly.
disc arge
- valves, l-EE-SOV-100, 101, 102, 103, 104, and 105.
4.9.1~1 IWV-3413 Diesel air Stroke time start system quarterly.
solenoid
- valves, 1-EG-lOOA, 1008, 200A, 2008, 300A, and 3008.
4.8.2.1 IWV-3521 Diesel fuel Exercise oil ~ump quarterly.
disc arge check valves, l-EE-13, 15, 19, 28, 31, and 35.
4.1.4.1 IWV-3426 Various Analysis of containment leakage isolation rates.
valves.
ALTERNATE METHOD OF TESTING Corrective action re~uirements of IW -3417(a~ applied whenever t e stroke time of these valves exceeds 2 seconds.
Test monthlh by observin~ tat fuel oil is f owing to the da1 tank after the so enoid valve has opened.
Test monthlh by verifling tat the diese generator starts.
Demonstration of system operability to verify o~erability of the c eek valves, install flow inst.
at next refueling.
Containment isolation valves which cannot be individually leak rate tested will be tested as groups.
ACTION BY USNRC Relief ~ranted.
(9)(6)(1)
Relief aranted provide instrumentation i s i n st a 11 ed at next refueling.
(g)(6)(i)
Relief granted provided acceptance criteria expanded to include maximum*
start time.
(g)(6)(i)
Relief aranted provide instrumentation is installed at next refueling.
(g)(6)(i}
Relief granted
~rovided
,censee reevaluates 1
roup leakage imits.
(g)(6)(i}
Page No.
. 06715/90 RELIEF REQUEST NUMBER V-40 V-41 V-42 J ;"
'o,.l~I 6
SURRY POWER STATION, UNITS 1 AND 2 SER TABLE 1
SUMMARY
OF RELIEF REQUESTS TER SECTION XI*
EQUIPMENT ALTERNATE METHOD OF TESTING ACTION BY USNRC SECTION-REQUIREMENT IDENTIFICATION
& SUBJECT 4. 3. 1. 2 I WV -3 5 21 Exercise quarterly.
4.2.1.2 IWV-3521 Exercise quarterly.
- 4. 7.1.1 IWV-3521 Exercise quarterly.
Charging pump discharge reciculation line check
- valves, 1(2)-CH-256, 265, and 274..
Disassemble on a sampling basis at a refueling outage frequency.
Aux. feedwater Disassemble on a pump recirc.
sampling basis at a line and oil refueling outaq~
cooler check frequency.
- valves, 1(2)-FW-144, 148, 159, 163, 174, 178.
Relief granted provided compliance with NRC staff positions on disassembly and inspection.
(g)(6)(i)
Relief granted provided compliance with NRC staff positions on disassembly and inspect ion.
(g)(6)(i)
Main steam Disassemble on a Relief granted supply check sampling basis at a provided valves to the refueling outage licensee turbine driven frequency, follows
. aux. feedwater part-stroke exercise guidance on
- pump, quarterly.
disassembly and 1(2)-MS-176, inspection in 118, and 182.
(g)(6)(i)