ML20005E996
| ML20005E996 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 01/04/1990 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20005E995 | List: |
| References | |
| NUDOCS 9001120153 | |
| Download: ML20005E996 (9) | |
Text
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ENCLOSURE 2 9V
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UNITE 3 STATES NUCLEAR REGULATORY COMMISSION n
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WASHINGTON. D. C. 20b$5
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE INSERVICE TEST'NG PROGRAM AND RE0 VESTS FOR RELIEF l
CAROLINA POWER & LIGHT COMPANY BRUf:SWICK STEAM ELECTRIC PLANT. UNITS 1 AND 2 DOCKET NOS.:
50-325/50-324 INTRODUCTION The Code of Federal Regulations,10 CFR 50.55a(g), requires that inservice testing (!$T) of AStiE 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 Connission pursuant to 10 CFR 50.55a(a)(3)(1),
(a)(3)(ii), or (g)(6)(1).
In requesting relief, the licensee nust 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 compensating increase in the level of quality and safety, or (3) conformance with certain requirenants of the applicable Code edition and addenda is impractical for its facility.
The Regulation,10 CFR 50.55a(a)(3)(i), and 50.55a(g)(6)(1), authorizes NRC to grant relief from these requirements upon making the necessary finding s.
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 the Safety Evaluation (SE) issued on the licensee's program.
The IST pmgram addressed in this report is b6 sed on the requirements of Section XI of the ASf1E Code,1980 Edition through the Winter 1981 Ade-ada. It covers the second ten-year inspection interval from July 10, 1986 to July 10, 1996. ' The licensee's original program is described in a letter dated October 23, 1986. A revised program was provided by letter dated Novent>er 24, 1987, and additional changes were submitted in letters dated March 28, 1988, November 2,1988, and Septenber 8,1989.
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, EG8G and staff menbers met with licensee representatives on July 21 and 22,1987 in a working session to discuss questions resulting from the review. The attached Technical Evaluation Report (TER) is the EG&G's evaluation of the licensee's inservice testing program and relief requests.
The staff has reviewed the TER, concurs with and adopts the evaluations and conclusions contained in the TER.
A summary of the pump and valve relief request determinations is presented in Table 1, 900112o153 9001o4
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DR ADOCK 0500o324 PDC
f.
2 i
The granting of relief is based upon the fulfillnent of any commitnents made by the ifcensee in its basis for each relief request and the alternative preposed testing.
During the 1988 plant modification. Brunswick installed instrunentation on several systems.
Operators will be cble to perform pump tests properly.
Cecause of this, certain relief requests were deened to be no longer necessary by the reviewers.
One interim relief request was grented interimly (TER section 3.1.1), because the plants are prepared to modify the pumps on a permanant basis.
The licensee should refer to the specific TER section for a detailed discussion of this case.
In addition, /ppendix C lists other IST program anomalies which were identified during our review.
The licensee should resolve all the items listed in Appendix C in accordance with the staff positions.
As required by Generic Letter 89-04, the licensee should review its implenenting procedures and amend them to address any deficiencies related to the implenentation of the positions in this generic letter.
Required program and procedure changes should be made within 180 days l
of receipt of this SER.
CONCLUSION Based on the review of the licensee's IST program and relief requests, the staff concludes that the IST program as evaluated and n.odified by this SER will provide reasonable assurance of the operational readiness of the pumps and valves covered by the IST progr6m to perform their safety related functions.
The staff has determined that granting relief, pursuant to 10 CFR 50.55a(a)(3)(i) and 50.55a(g)(6)(1), is authorized by law and will not endanger life or property, or the cummon defense and security and is othemise in the public interest.
In making this determination the staff has considered the alternate testing being implenented, resulting hardships without a compensating increase in safety, or the innpracticality of performing the required testing considering the burden if the.equirenents 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 inservice testing program, the staff has identified certain misinterpretations or omissions of Code requirecents.
These items are summariIed in the TER Appendix C.
The IST program for Brunswick described in their revised program dated !!ovember 24, 1987, t hrough submittals dated l'. arch 28, 1988, Noventer 2,1988 and September 8,1989, is dCCeptable for implenentation provided that the items noted above are corrected promptly.
Relief requests contained in any subsequent revisions may not be impleriented without prior approval by NRC.
Principal Contributor:
H. Shaw Dated:
January 4. 1990 t
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Page Noa 1
L 1
BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 SER TABLE 1
SUMMARY
OF RELIEF REQUESTS i
RELIEF TER SECTION XI EQUIPMENT ALTERNATE REllEF REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF REQUEST NUMBER.
& SUBJECT TESTING STATUS Pump 3.1.1 IWP 3100 All pumps in Vibration testing in Relief Granted PR-01 Measure pump the IST accordance with 10 CFR 50.55a-bearing program.
OM 6.
(a)(3)(1)'
temperature.
Pump 3.2.1 IWP 31001 Standby liquid Utilize discharge Relief Granted PR 02 and 3400(a Measure pum)p control pumps, pressure to evaluate (g)(6)(1) 1-SLC-P-1A, pump performance and suction and 18, verify suction differential 2 SLC-P-2A,
- pressure, pressure.
and 28 Pump 3.2.2 IWP 3500 and Standby liquid None.
Relief Not PR 03 4600 Pump control pumps, Instrumentation to Necessary Due flow rate and 2 SLC P-2A and be installed May To Recent Plant run time.
2B 1988.
Modifications.
Pump 3.3.1 IWP-3100 Diesel fuel Monthly functional Relief Not 9
PR 04 Measure pump oil-transfer testing per Tech.
Necessary Due inlet and pumps.
Specs.
To Recent Plant differential 2 DG Oll-P-1A, Instrumentation to Modifications.
pressure and IB, 2A, 28, be installed by end flowrate.
3A, 3B, 4A, of 1988.
and 4B Pump 3.4.1 Table Service water None. Modify service Interim Relief PR-05 IWP-3100-1 lube water water pumps for self Granted Measure pump pumps, lubrication.
(g)(61(,1) inlet and 1 SW-LW-P 1A, provided pump i
differential 18, hydraulic i
pressure and 2 SW LW P 2A, condition flowrate.
and 2B evaluated.
Valve N/A IWV 3415 Test All valves Normal motion to Not Evaluated VR-01 fail-safe with fail safe fall position.
Relief Not actuators.
operators.
Necessary Valve 4.1.1.1 IWV-3417(a)
Various power Compare stroke times Relief Granted VR-02 Trending of operated to reference and (g)(6)(1) valve stroie valves, assign maximum times.
limiting stroke time of 2 seconds to rapid acting valves.
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Page No.
2 l
BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 SER TABLE 1
SUMMARY
OF RELIEF REQUESTS i
REllEF TER SECTION XI EQUIPMENT ALTERNATE RELIEF REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF REQUEST l
NUMBER,
& SUBJECT TESTING STATUS Valve 4.1.2.1 IWV-3300 Various Verify open position Relief Granted VR 03 Verify valve solenoid using plant (a)(3)(i) position operated parameters during indication,
- valves, operations and closure by positive means during refueling outages.
Valve 4.2.1.1 IWV 3412 and CRD valves, Verify operability Relief Granted VR-04 3522 Exercise C11/C12 114
-via control rod (g)(6)(i) ~
and stroke Cll/Cl2 SVll8, scram testing per time.
Cll/Cl2 CV127, Technical Cll/Cl2-SVll7, Specifications.
Cll/Cl2 CV126, C11/012 138 Valve 4.1.4.1 IWV-3411, All excess Functionally test in Relief Granted VR 05 3420, and flow check accordance with (g)(6)(1) 3521 Exercise valves.
Technical check valves Specifications, and leak test Category A valves.
Valve 4.1.5.1 IWV 3522 Test Containment Appendix J. Type C, Relief Granted VR 06 frequency, isolation leak test at (g)(6)(i)
- checks, refueling outages.
832 V24,V32, B21 F010A,
- F010B, E41 F040,F049 E51-F028,F040, V88,TIPNC Valve 4.3.1.1 IWV 3412 ADS valves, Exercise valves once Relief Granted VR 07 Exercise and B21-F013A, B, every 18 months.
(g)(6)(1) stroke time C, D, E, F, G, Verify that valves quarterly.
H.J,K,L stroke in less than five seconds.
. Page No.
3 BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 SER TABLE 1
SUMMARY
OF RELIEF REQUESTS REllEF TER SECTION XI EQUIPMENT ALTERNATE RELIEF REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF REQUEST NUMBER.
& SUBJECT TESTING STATUS Valve Deleted VR-08 Valve 4.4.1.1 IWV 3412 and Core spray Full stroke exercise Relief Granted VR 09 3522 Test injection open during (g)(6)(1) frequency.
isolation refueling outages.
- valves, E21 F006A and B Valve 4.7.1.1 IWV-3522 Test Standby liquid Fire a squib valve Relief Granted VR-10 frequency, control and inject into the (g)(6)(i) injection RCS at least once-check valves, each 18 months.
C41 F006 and Verify closure via F007 Appendix J 1eak test.
Valve Deleted VR-11 Valve 4.5.1.1 IWV 3522 Test RHR injection Exercise during Relief Granted VR-12 frequency, isolation pressure isolation (g)(6)(1)
- valves, valve testing during Ell F050A, refueling outages.
F050B Valve 4.4.1.2 IWV 3522 Test Core spray Exercise closed Relief Granted VR-12 frequency, injection during pressure (g)(o)(i) isolation isolation valve check valves, testing during E21-F006A and refueling outages.
F006B l
Valve 4.6.1.1 IWV 3412 DG valves.
Utilize starting air Relief Granted VR-13 Exercise and 2 DSA SV6552 1 header pressure to (g)(6)(i) stroke time, thru 4, verify operability 2-DSA SV6553-1 quarterly.
l thru 4, 2 DSA-SV6554 1 thru 4 L
2 DSA SV6555-1 thru 4 I
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i Page No.
4 0
BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 1
SER TABLE 1
SUMMARY
OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE REllEF REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF REQUEST NUMBER.
& SUBJECT TESTING STATUS Valve 4.8.1.1 IWV-3412 RHR service Exercise quarterly Relief: Granted VR 14 Exercise and water booster do not measure (g)(6)(i) stroke time, pump motor stroke times, provided the cooler inlet licensee
- valves, implements SW V136, V137, acceptance V138, and criteria.
V139.
Valve 4.8.2.1 IWV 3522 Test SW lubricating Disassemble and Relief Granted VR 15 frequency and pumps suction inspect as described (g)(6)(i) -
- method, valves, in IST program, provided SW V201, V204, compliance with and V205 NRC staff position and grouping.
Valve 4.8.2.2 IWV 3522 lest Service water Disassemble and Relief Granted VR 16 frequency and isolation inspect as described (g)(6)(1)
- method, check valve to in IST program, provided nuclear compliance with
Valve 4.8.2.3 IWV-3522 Test Lubricating Disassemble and Relief Granted VR-17 frequency and water to SW inspect as described (g)(6)(i)
- method, pumps check in IST program, provided
- valves, compliance with SW V202 and NRC staff V203 position and
- grouping, Valve 4.8.2.4 IWV-3522 Test SW nuclear Disassemble and Relief Granted VR-18 frequency and header inspect as described (g)(6)(1) method.
isolation in IST program.
provided check valves, compliance with l'
SW-V272, V273, NRC staff V274, V275 position.
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- Page' No.
5 g
BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 1
SER TABLE 1 j
SUMMARY
OF RELIEF REQUESTS 1
RELIEF TER SECTION XI EQUIPMENT ALTERNATE RELIEF REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF REQUEST ME-NUMBER -
& SUBJECT TESTING STATUS EC j
Valve 4.9.1.1 IWV-3522 Test Minimum flow Disassemble and Relief Granted i
VR 19 frequency and check valves, inspect as described (g)(6)(i)
V' method.
E41-F046, in IST program, provided E11 F046A, compliance with F0468, F0460, NRC staff and F046D position and grouping.
Valve 4.9.1.2 IWV-3522 Test HPCI suction Disassemble and Relief Denied VR 20 frequency and check from inspect as described method.
E41 F019 Valve 4.1.6.1 IWV-3522 Test Keep fill Disassemble and Relief Granted VR 21 frequency and check valves, inspect as described (g)(6)(1)
+
method.
Ell-F089 Uniti in IST program.
provided F090-Unit 2, compliance with
- Vl93, NRC staff E21-F030A,B, position and and E41-V93 grouping.
Valve 4.9.1.3 IWV-3522 Test Suction check Disassemble and Relief Granted VR 22 frequency and from inspect as described (g)(6)(1)
- method, suppression to in IST program, provided
- HPCI, compliance with E41-F045 NRC staff position and grouping.
Valve 4.10.1.1 IWV-3412 Test RHRSW to loop Exercise at Relief Granted VR 23 frequency.
injection refueling.
(g)(6)(1) isolation, Ell-F073, and F075 Valve 4.10.2.1 IWV-3522 Test RHRSW to loop Exercise at Relief Granted VR-23 frequency, injection refueling.
(g)(6)(i) isolation check valve, Ell-F078
- Page No.
6 l
BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 i
SER TABLE 1
SUMMARY
OF RELIEF REQUESTS RELIEF
-TER SECTION XI EQUIPMENT ALTERNATE REllEF REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF REQUEST NUMBER -
1 SUBJECT TESTING STATUS Valve 4.8.1.2 IWV 3412 Test RHR heat System modifications Relief Not VR-24 frequency.
exchanger flow at refueling will Necessary Due control permit testing to To Recent Plant
- valves, Code.
Modifications.
Ell-F068A and F068B(Unit 2)
Valve 4.7.2.1 IWV 3522 Test Standby liquid System modifications Relief Not VR 25 frequency and control pump at refueling will Necessary Due method.
discharge permit testing to To Recent. Plant
- checks, Code.
Modifications.
C41 F033A and F033B(Unit 2)
Valve 4.6.2.1 IWV 3522 Test Diesel Disassemble and Relief Granted VR-26 frequency and starting air inspect every 18 (g)(6)(i) method.
header months.
isolation
- checks, DSA V141.
V142, V145 V146, V149, VISO, V153, and V154 Valve 4.1.3.1 IWV 3420 Leak Appendix J Appendix J leak Relief Granted VR 27 testing of leak tested testing.
(a)(3)(1)
Category A
- valves, provided
- valves, compliance with IWV 3426 and 3427(a).
Valve 4.11.1.1 IWV-3423 Torus Pressurize from the Relief Granted VR 28 Direction of isolation reverse direction.
(g)(6)(i) pressure
- valves, differential. Ell F011A,B, F007A,B, E41-F075, and 551-F031
- Page' No.
7 BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 SER TABLE 1 l
SUMMARY
OF REllEF REQUESTS l
RELIEF TER SECTION XI EQUIPMENT ALTERNATE RELIEF REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF REQUEST l
NUMBER *
& SUBJECT TESTING STATUS j
valve 4.6.2.2 IWV 3522 Test Diesel Otsassemble and Relief Granted l
VR 31 frequency and starting air inspect every 18 (g)(6)(1)
- method, compressor
- months, discharge checks.
DSA V21 V33 V51, V63, V81, V93, Vill, and V123 9
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