ML20005F209
| ML20005F209 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 01/04/1990 |
| From: | Hebdon F Office of Nuclear Reactor Regulation |
| To: | Dewease J LOUISIANA POWER & LIGHT CO. |
| References | |
| GL-89-04, TAC-69819, NUDOCS 9001160054 | |
| Download: ML20005F209 (4) | |
Text
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UNITED STATES p
g )..g 'g NUCLEAR REGULATORY COMMISSION 5/
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t WASHINGTON D. C. 20555 S.
January 4,1990 FccLet Lt. U-3P.2 Mr. J. G. Dewease Senior Vict Fresident - Nuclear Operctions totisiana Power and Light-Company Post Office. box 60340 New Orleans, Louisiana 70160 Decr Mr. Dewease:
SUBJECT:
INSERVICE TESTINC (IST) PRCGRAM FOR FUMPS AHD VALVES, WATERFORD STEAM ELECTRIC STATION, Utili H0. 3, LOUISIANA POWER AND LIGHT C0t< pal'Y - CHANGE 2 TO REVISIGH 6 (TAC NO. 69819)
This Ictter Frovides the results of the staff's review of the Waterfctd.3 inservice testing program for purps and valves, specifically, amendment to Pevision 5 which was approved by letter to Louisiana Power and Light Correny (LPll) dated February 7, 1989.
By letter dated October 31, 1985, LP&L submitted a Change-2 to Revisien 6.
We are still in the process of reviewing the Revision 6 and Change 1.
Nothing in this letter should be construed to irply approval of Revisien 6 or Change 1 to Revision 6.
However, the relief requested by the October 31, 1989 letter is needed in the near future as discussed in the~ request. The'new reliefs are as follows.
1.
Relief 3.1.57 -
It is requested that relief from. full or partial stroke testing of gate ~
valves, ACC-116A and ACC-116B, be granted from the. requirements of-ASME Cooe Section XI. These valves are being added to theLIST program. They prevent the water from the auxiliary component cooling water (ACCW) system from entering the emergency feedwater system or condensate storage pool.
They ellow the ACCW to be used as a backup water supply;to the steam generators upon the complete loss of the condensate system. The water:in the ACCW is not suitable for use as the normal water source for the steam generators or steam supply system and any attemptsto full or partial strcke the valves during normal operation (once every three months pcr Section'XI) would unduly contaminate interconnecting systems with a decreasing benefit to safety. The contaminate wculd attack the high quality material integrity of the steara generators which serve as a principal boundary to reactor'.
coolant and could necessitate the early replacement of vital secondary side; components such as the steam generators and. turbine. The proposed alternative
-is to full stroke the valves during refueling and can be accomplished by isolating the valves, stroke testing, drainingland flushing to prevent:
cross-contamination. This alternative provides s'n acceptable level-of-confidence of valve cperability without the potential fer a decreasing-benefit to safety.
0For 9001160034 900104 DR ADOCK 050003G2 l i PDC I
e
Mr. J. G. Dewease
-?-
s 2.
Relief 3.1.56 -
It is requested that relief fren, exercising check valves. ACC-114A and ACC-1148, be granted from the requirements of IWV-3520 of ASME Code Section XI. The code requires the check valves be operated at least once every three renths.
These check valves are in the same lines as the gate -
valves discussed in the first change above.
l Operation of the check valve during normal operation would result in injecting ACCW contaminated water into the steam generators via the energency feedwater. system or into the condensate system.
As above, this' operation veuld have a decreasing benefit to safety and with possible early replacement of components.
The proposed alternatives is to disassemble and ranually exercise the valves by hand to thcir fully open position at each refueling outage. This alternative provides an acceptable level of confidence of valve operability without the potential for a decreasing benefit to safety.
The staff has reviewed your analysis and agrees that a potential for degrading.
the cuality of the water in the EFW system woulc exist if the required tests-l were conducted.
The staff has also reviewed your alternatives, and we' conclude that they provide an acceptable level of confidence of valve
~
operability without the inherent risk of degrading-the water quality in the~
EFW system. Thus, we have determined that the Change 2 proposed revision is acceptable for implementation provided the guidance on grouping and sampling in Generic Letter 89-04, Position 2, is followed.. We have also determined that testing requirements are impractical for the-items for which relief is being granted, and pursuant to 10 CFR 55.55a(g)(6)(1), that the granting'of relief is authorized by law, will not endanger life or property or the cormon defense and l
security, and is otherwise in the public interest.
In making this determination, I
we have given due consideration to the burden that could result if-this requirement is imposed on your f acility. This letter grants the relief-identified above.
Program changes such as revisions or additional relief requests or deletion of any components from the IST program should be submitted for our review but should not be implemented prior to review or approval.
Please contact your Project Manager, David L. Wigginton at (301) 492-3027, if you need any clarification.
Sincerely, A
l
~
Frederick J. He don, Director -
Project. Directorate IV Division of Reactor Projects - III, IV,'V and Special Projects Office of Nuclear Reactor Regulation cc: See next page 4
J
}
a Mr. Jerrold G. Oewease Waterford 3 j
Louisiana Power & Light Company.
t cc:
W. Malcolm Stevenson, Esq.
Regional Administrator, Region IV Monroe & Leman U.S. Nuclear Regulatory Commission 201 St. Charles Avenue,~ Suite 3300 Office of Executive Director f or
.New Orleans, Louisiana 70170-3300 Operations 611 Psyen Plaza Drive, Suite 1000 Mr. E. Blake Arlington,' Texas 76011 Shaw, Pittman, Potts & Trowbridge 2300 N Street, NW Mr. William H. Spell, Administrator Washington, D.C.
20037-Nuclear Energy Division Department of Environmental Quality--
Resident-Inspector /Waterford NPS Post Office Box 14690 3
Post Office Box 822 Baton Rouge, Louisiana-70898f K111ona, Louisiana 70066
?
Mr. Ralph T. Lally President, Police Jury Manager of Quality Assurance ~
St.- Charles Parish Middle South Services, Inc.
Hahnv111e, Louisiana 70057 i
Post Office Box 61000 i
New Orleans,' Louisiana 70161
)
Chairman William A. Cross Louisiana Public Service Commission Bethesda Licensing' Office One American Place, Suite 1630 3' Metro Center Baton Rouge, Louisiana 70825-1697 Suite 610-l Mr.'R.-F. Burski Nuclear Safety and Regulatory Aff airs Mar.ager Louisiana Power & Light Company 317 Baronne Street' New Orleans, Louisiana 70112 9
Y I
h 1
a
, tdr. J. G. Dewease,
- 12..
Relief 3.1.58 -
It is requested that relief from exercising check valves, ACC-114A and ACC-1148, be granted from the requirements of IWV-3520 of ASME code Section XI. The code requires the check valves be operated at least once every three months.
These check valves are in the same lines as the gate valves discussed in the first change above.-
Operation of the check valve during normal operation would result in injecting ACCW contaminated water into the steam generators via the emergency feedwater system or into the condensate system. As above, this operation would have a decreasing benefit to sefety and with possible early replacement of components. The-proposed alternatives is to disassemble and manually exercise the valves by hand to-their fully open position at each refueling outage. This alternative provides an acceptable level of confidence of valve operability without the potential.for a decreasing benefit to safety.
The staff has reviewed your analysis and agrees that a potential for degrading the quality of the water in the EFW system would exist if the required tests were conducted. The staff has also reviewed your alternatives, and we conclude that they provide an acceptable level of confidence of valve operability without the inherent risk of degrading the water quality in the EFW system. Thus, we have determined that the Change 2 proposed revision is acceptable for implementation provided the guidance on grouping and sampling in-Generic Letter 89-04, Position 2, is followed. We have also determined that testing requirements are impractical for the items for which relief.is being granted,andpursuantto10CFR55.55a(g)(6)(1),thatthegrantingofreliefis 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,-
we have given due consideration to the burden that could result-if this requirement-is imposed on your facility.. This letter grants the relief identified above.
Program changes such as revisions or additional relief requests or deletion of any components from the IST program should be submitted for our review but should not be implemented prior to review or approval.
Please contact your Project Manager, David L. Wigginton at (301) 492-3027, if l
you need any clarification.
4 Sincerely, 1
Odginal Signtd By.
Frederid J. Hebdon 1
Frederick J..Hebdon, Director Project Directorate IV Division of Reactor Projects - III.
IV, V and Special Projects Office of Nuclear Reactor Regulation cc:.See next page STRIBUTION.
r
- ..
- ad NRC PDR Local PDR PD4 Reading-l G. Holahan F. Hebdon P. Noonan D. Wigginton OGC-Rockville E. Jordan ACRS (10)
PD4 Plant File T. Marsh
- See previous concurence 0FC :*PD4/LA :*PD4/PM
- MEB
- 0G
- PD4/Dd.:
NAME :PNoonan :DWigginton
- bj:TMarsh
- FHebd6n :
'DATE :12/11/89 :12/11/89
- 12/20/89
- 1$
90!)(/4/.8f:
Document Name: W3 LTR/69819 0FFICIAL RECORD COPY '70