ML19332C719
| ML19332C719 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 11/15/1989 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19332C717 | List: |
| References | |
| GL-89-04, GL-89-4, NUDOCS 8911280466 | |
| Download: ML19332C719 (6) | |
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SUpPLEMENTALSAFETYEVAj.UAT,10N BY THE OFFICE.0F NUCLEAR REACTOR REGULATION RELATED TO THE INSERVICE TESTING PROGRAM ARKANSAS POWER AND LIGHT COMPANY ARKANSASNUCLEARONE,,,UNITNh,2 D_0CKET NO. 50-368 The Code of Federal Regulations, 10 CFR 50.55a(g), requires that inservice testing (IST) of ASME Code Class 1, 2, and 3 purps 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 The Regulations, 10 CFR 50.55a by)the licensee and granted by(the Commission.(a(3)(1),(a)(3)(ii),and(g)6)(i),authorizet
'from these requirements.
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 difficulties without a corrpensating increase in the level of quality and safety, or (3) conformance with certain requirements of the applicable Code edition and addenda is imprac-
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tical.for its facility.
'The staff issued the Safety (Evaluation (SE) of the Arkansas Nuclear One, Unit 2 (ANO-2),inservicetestin IST)programonJune 20, 1985.
Subsequently, Arkansas Power and Light Company (gthe licensee) submitted a letter dated September 30, 1985, which contained additional relief requests and comments concerning "certain difficulties / discrepancies noted during [its] review of the SER." The staff, with-assistance from its contractor EG&G, Idaho, reviewed the licensee's September 30, 1985 submittel against the requirements of 10 CFR 50.55a, Generic Letter No. 89-04, and the ASME Code,Section XI.
Since this submittal is not the IST program, the relief request it contains should be incorporated in a revision to the IST program.
Future relief requests presented for staff review should be in the form of a revision to the IST program.
Item (1).
The licensee stated that none of the diesel generator subsystems are ASME Code Class 1, 2, or 3 and are, therefore, not subject to Section XI. The safety related diesel generator subsystem components are not in the IST program. The utility stated, however, that the diesel generator support systems are tested when the diesel generators are routinely tested in accordance with the Technical Specifications. The staff agrees with the licensees position on the diesel generator. subsystems.
8911280466 891115 PDR-ADOCK 05000368 P-PNU
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,u 2-Item (2).
The licensee provided additional clarification for the relief request from the Code requirement to stroke and measure the full-stroke time of the emergency l
feedwater pump turbine governor valve. The-licensee provided the following:
"The governor valve is actuated closed by control oil pressure which is produced by the spinning turbine.
It is spring opened. When the EFW pump turbine is not spinning, the governor valve is open and it closes to a regulating position as the turbine comes up to speed increasing the control oil pressure. The operation of the governor valve is tested monthly _ per Technical Specification 3/4.7.1.2.
Should the valve move too slowly (i.e., fail to control the steam flow), the turbine would overspeed. The trip / throttle valve, acting independently, would trip tc prevent excessive overspeed.
In effect then, the timely operation of l
the governor valve is tested monthly with each turbine start."
"Since the governor valve is actuated closed with control oil, which in turn is produced by spinning the turbine, there is no p*actical way to full-stroke the valve.
Depending on the inlet steam pressure, pump load, oil temperature, etc., the valve may stroke tc different positions with each start. Consequently, stroke times could vary over a fairly wide rar.ge."
With the additior.el information provided in the submittal dated September 30, 1985, the licer.see has shown the impracticelity of performing-the Code testing of the emergency feedwater punp turbine governor valve and has demonstrated-the adequacy of propestd alternate testing.
Since the staff finds that the alternate monthly testine as required by the Technical Specifications, provides 50.55a(ptable level of quality and safety, relief is granted pursuant to 10 CFP.
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Item (3).1'.
i The licensee indicated that the SE had not addressed the relief request from the Code requirement of IWV-3410(c)(3) to correlate the measured stroke times of power operated valves to the previous stroke time measurement.
In the relief request the licensee provided the following basis and alternate testing:
" Maintenance of a running file on previous test stroke times and the inclusion of such as revised criteria, amounts to an undue clerical burden for dubious benefits. Also, the chance for clerical error is greatly increased by such a cumbersome system."
" Valve stroke times will be compared against a set (reference) value arrived at from initial testing and tevring following any maintenance pursuant to IWV-3200."
Although comparing the measured stroke times to reference stroke times can be l
an acceptable alternate test method for power operated valves, the licensee has L
not provided an appropriate besis fcr het conplyire with Code requirements.
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. Inconvenience cannot be used as a justification to obtair relief from a Code requirement. Also, the licensee did not describe the proposed alternate testing ard acceptance criteria in sufficient detail.
For example, establishing an increased testing frequency for possibly degraded valves has not been addressed. Therefore, this relief cannot be granted.
Item (3).2.
The licensee requested clarification from the staff regarding valves that are tested on a cold shutdown testing frequency as discussed in Section 3.2 of the SE. The licensee felt that certain valves that fall in this category were not addressed in the SE and that one valve that was addressed should not be included. Valve 2CV-4823-2 in Section 3.2 of the SE is a typocraphical error and should be ?CV-4873-1.
Valve 2CV-4823-2 is exercised quarterly ard a cold shutdown justification need not be provided.
Valve 2CV-4873-1 is exercised during cold shutdowns and a cold shutdown justification must be provided in the.
IST progran.
Valves 2CV-4916-2 and 2CVC-49 were inadvertently omitted from the SE and should have been included in the discussion with valves 2CV-4920, 2CV-4921, and 2CVC-58 in Section 3.2 of the SE (page 8 under Chemical and Volume Control).
These valves are exercised during cold shutdewns and a cold shutdown justifica-tion must be provided in the IST program.
Valves 2CV-1480-2 and 2CV-1481-1 were discussed in the March 11, 1980 IST working meeting and were left as an open item for the licensee to provide a justification why they cannot be exercised quarterly.
In the correspendence dated October 29, 1980, the licensee stated that "2CV-1480 and 2CV-1481 carrot be tested during power operations because of the possibility of unit shutdown due to a loss of service water flow." The licensee must provide a ccid shutdown justification in the IST program for thest valves and provide a rcre detailed technical bcsis than that submitted on October 29, 1980. The basis should address specific equipment that would lose cooling water flow and the conse-quence of losing cooling water flor.
Item (3).3 The utility requested clarification for the omission of valve 2CV-4873-1 from the discussions of valves that are tested on a cold shutdown testing frequency in Section 3.2 of the SE. AsdiscussedinItem(3).2.,thisomissionisatypo-graphical error.
Item (3).4.
In the September 30, 1985, submittal, the utility requested relief from the quarterly exercising requirements of the Code for valve 2CV-5038-1 and proposed to exercise this valve during cold shutdowns.
In the submittal, the licensee stated that there is a control room pressure indication for the low pressure side, between valves 2CV-5038-1 and 2CV-5085-2.
Exercising 2CV-5038-1 quarterly should not result in an overpressurization of the low pressure injection system if the two valves (2CV-5084-1 and 2CV-5086-2), between 2CV-5038-1 and the RCS, can be verified closed by the pressure indicator. Therefore, the relief request from the Code requirement to quarterly exercise 2CV-5038-1 is denied.
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. 1 Further,-the alternate leak testing described in the September 30, 1985 letter would not detect degradation of individual valves and therefore is not equivalent to the Code requirement. For example, under the alternate leak testing proposed by the licensee, the failure of 2CV-5086-2 could go undetected
-as long as 2CV-5084-1 is leak tight. Also, the licensee has not addressed the impracticality of meeting the Code requirements. Therefore, the relief from r
the Code leak testing requirements cannot be granted for valves 2CV-5084-1 and 2CV-5086-1.
The valve 2CV-5038-1 does not appear to perform a pressure boundary isnlation function because two upstream valves, 2CV-5084-1 and 2CV-5086-1, are identified as pressure boundary isolation valves and only two valves are required to protect a low pressure system from being overpressurized by a high pressure systen. Also, it is on Class 2 piping, outside the Class 1-to-Class 2 interface. The leak tight integrity of this valve appears to bt not safety related. Thus, a relief request is not necessary.
Item (3).5.
The utility requested clarification concerning certain category A/E valves in the IST program.
Sectier. 3.14.1-of the SE addresses a relief request for valve 2SA-69. This is a typographical errer and the proper valve number is 2SA-68. There is-no valve 2SA-69 in the-IST program.
The licensee requested relici f rom the Code requirement of checking the position of vtives 2FP-35 and 2FP-36 quarterly and each time the valves are cycled and proposed to check the positions of these valves during refueling outages and af ter the velves are cycled. The justification for not complying with the Code requirements is that the valves are located insice containment
. cod ALARA reasons make checking the positions quarterly undesirable.
Valves 2FP-35 and EFP-36 are Category A/E and as such are required to be tested to the requirements of both IWV-3400 and 3700.
IWV-3400 requires Category A valves to be exercised quarterly and leak rate tested once i
every two years and IWV-3700 requires the valve position to be checked each time the valves are cycled. The licensee requested relief from the quarterly exercising requirements because the valves are normally locked closed and are not required to change position for accident mitication.
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The requirement to check the position of valves 2FP-35 and 2FP-36 quarterly is considered to be burdensome because the valves are inside the containment and a containment entry would be required to either reposition the valves or to check their position. Also, a quarterly position check is not a require-ment of the Code for Category E valves. The staff's position is that quarterly
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position checks need not be perforraed; however, the valve position must be verified each time the valves are cycleo.
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, Eased on the deterniination that compliance with the Code ree,uirement would result in hardship without a compensating increase in the level of quality and safety, relief from the cuarterly position checks for valves 2FP-35 and 2FP-36 is granted pursuant to 10 CFP, 50.55a(a)(3)(ii).
Item (3).6.
The licensee provided additional clarification with regard to the relief request fron the Code requirement to mtesure the flow rate for the service water pumps.
The licensee stated that it had not proposed to test the pumps at shutoff head, but instead measure pump differential pressure with the normal service water loads on line for the monthly test and measure individual cooler flow rates with portable flew instrunents durirp each refueling outage.
The 1974 Edition of the Code permits 6easuring only differential pressure in a fixed retistance flow path since the Jifferential pressure measurement in fixtd resistance flow path would be indicativt cf sump hydraulic conditier.
- However, in the variabic flow path that the licensec ist proposed tc use, measurcr..ent of differential pressure without measuring purp flow rate would not provide adequate inforraation aDost pump hydraulic tondition or degradation. The relicf cannut be granted as requested for the service water pump flow rate measurements since the prcposed alternate testing will not providt an acceptable means of determining pur:p bydraulic condition cr detecting pump degradt. tion.
Flow would have to be measured in accordance with Code requirements.
Item (3).7.
Tne Arkansas Power and Light Company provided connents about differences in valve categorics between the IST program and the SE. These valvo categories were reviewed and it was determinct that the categories idertified in the AP&L consents column are the proper categories for these valves. The categories of sinple check valves 2EFW-2A, 2EFW-20, 2SI-7A, 251-7B. 2MS-39A, end 2MS-39B should be changed to "C" in the SE.
Item (3).8.
The licensee requested relief from the leak rate testing requirements of Section XI for valves 2SI-16A, 251-16B, 2S1-160, and 251-16D and proposed monitoring thc i
lukage through these valves by observing the SIT pressure and level as well es l
l RCS leak rate. This alternate testing is not acceptable since the licensee's l
proposal does not provide an indication cf individual valve leakage as required i
by IWV-3420.
One of the valves in the series could fail in the open position and not be detected by the proposed testing. The relief from the Code leak testing requirement is, therefore, denied.
Itcr (3).9.
The licensee requested rclief from the leak rate testing requirements of Section j
XI for valves 2SI-27A, 251-278, 2SI-28A, and 251-28B and proposed monitoring the l
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e 6-leakage through these vains by observing header presture upstret.ni of both series valves. This alternate testing is not acceptable since the licensee's propesal does not provide an indication of individual valve leakage as required by IWV-3420.
One of the series valves could it.11 in the open position and not be detected by the L
proposed testing. The relief frorn the Code leak testing requirement is, there-fore, denied.
Item (3).),03 The Arkansas Fower and Light Cortpany requested that the staff evaluate a relief request frota the Code requireraent to rneesure the purnp differential f
pressure for the charging purr.ps and proposed to rneasure pump flow rate as a rceans of deterrdning purp hydreclic perforrnance. The utility stattd that ttt chargirig purps are positiu displacement pur,ps whuse different'al pressure l
is dependt rit on the RC$ pre ssure.
The distharge pressure of a positivt dhplacer..ent purp 15 determdned by the P.CS pressure ar,d has no bearirig on the purp hydraulic ccredition. Tu require censuring the differential pr(ssure of the charging purrps would be burdensorte because this pert.riettr prevides no useful inferrnation for evaluating a positive displacerrert purp. Ikasuring punt flow rate during testing should provide er, iridication of purp hydreolic cer ditien and degr adation. Therefore,pursuentto50.55a(a)(3)(1),
the rec 4ested relitf is granted.
The elternative test rethod provides ecceptable level of gelity ar d safety.
This grar. ting of relief fror.. the Code testing (quirer.ent pursuarit to 10 CFR 50.55a(a)(3)(i) erd (ii) is authorized by law art will not endanger life or property or the cor..nion defense cri secur ity ar.d is etherwise it, the public interest givir9 due consideration tc the burden upcn the lictnsee that (culd result if the requirer..ents were it: posed on the facility.
Dated:
November 15, 1989 Principal Contributor:
K. Dempsey i