ML20034C582
| ML20034C582 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 05/01/1990 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20034C581 | List: |
| References | |
| NUDOCS 9005040165 | |
| Download: ML20034C582 (4) | |
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f"p ho4.g UNITED STATES Vi
'i NUCLEAR REGULATORY COMMISSION
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i WASHINGTON, D. C. 20555
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ENCLOSURE
?i SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION PUMP AND VALVE TESTING PROGRAM-RELIEF REQUESTS 2
k FLORIDA-POWER CORPORATION CRYSTAL RIVER UNIT 3.
00CKET NO. 50-302 a
INTRODUCTION By letters dated November 7, 1989,fand March 7, 1990, Florida Power.
-Corporation (FPC) submitted three: relief requests-concerning the inservice -.
pump and valve-testing program-(IST)Lfor Facility Operating: License No.-DPR-72 for Crystal River Unit 3 (CR-3). --Relief request V-115 proposed use of. 0M-1 instead of Performance Test Code (PTC) 25.3 for safety / relief. valve testing.
I Relief request V-366-requested relief from the requirements of valve. remote, position indication verification.. - Relief request V-371' requested relief from-the requirements governing fluctuations.in hydraulic pump; readings.
DESCRIPTION AND DISCUSSION 1
ReliefRequestNumberl-115 The licensee: requested reliefLto. utilize the' reference in the ASME Code, i
Section XI, IWV-3510, 1986 Edition to ANSI /ASME OM-1, 1981, for all the requirements for inservice testing-of safety 'and' relief valves, with the-.
exception of the main steam ' safety valves which will remain on a 5 year test frequency.
Relief is being requested,from the requirements'of_the ASME Code,=
Section XI,1983 Edition through Summer 1983 Addenda which contains testing S
frequency-requirements and references the ANSI PTC 25.3, 1976.
i Basis for Relief The alternative code is a more recent standard and more appropriate for all safety / relief valve testing requirements'in:the-field.
Evaluation The licensee requested relief from the safety / relief valve testing requirements 1
of their code of record,-the ASME Code,Section XI, 1983 Edition through Summer 1983 Addenda.
As an alternative, the licensee proposes to utilize the 1
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T applicable requirements of the 1986 Edition of the ASME Code,Section XI.
i of the 1986 Edition has been approved by the NRC in that this edition of Use Section XI has been incorporated by reference in 10 CFR 50.55a(b)(2).
The licensee has indicated that they will follow all the OM-1, 1981 requirements for inservice testing of safety and relief valves, with the exception of the main steam safety valves which will remain on a 5 year test frequency.
OM-1, 1981 requires that PWR main steam safety valves be tested in accordance with the frequency requirements for ASME Code Class 1 safety valves which are en a 5 year test frequency.
Therefore, this exception is not necessary.
Based on the acceptability of the licensee's proposal, as explained above, relief is granted pursuant to 10 CFR 50.55a(a)(3)(1).
Relief Request Number V-366 Relief Requested The licensee requested relief from the ASME Code,Section XI, IWV-3300 requirements for observation of valve position to verify accurate remote position indication.
LRV-72, and LRV-73 which perform post-accident hydrogen purge iso Verification that valve position is accurately indicated by remote indicators will be accomplished indirectly by observation of affected system parameters which can include items such as establishment and cessation of flow or change in indicated system pressure or level.
Basis for Relief 1
These are solenoid operated valves.
The solenoid operators are enclosed in a "can" that is seal welded closed.
valve stem position without cutting the closure weld.There is no method to visually ver I
Evaluation The licensee has indicated that it is not possible to verify valve stem position directly and correlate valve stem position with the remote indicators since the valves are totally encapsulated.
As an alternative the licensee has proposed relying on system parameters to verify valve position.
This method will provide the same infcrmation and may in some cases provide more reliable verification of valve position than simple observation of valve stem position.
Therefore, the proposed alternative is acceptable and relief is granted pursuant to 10 CFR 50.55a(a)(3)(i).
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, Relief' Request V-371 i
Relief Requested s
The licensee requested relief for'the chilled water pumps from the requirements of.the~ASME Code,Section XI, IWP-4150 which requires that-instrument' fluctuations be reduced to within 2% of the observed reading.
1 The j
licensee proposed to assure that " steady-state" conditions are met and then.
average the flow-readings.
Upon achieving the desired average flow reading, which will be within'2% of the required reading, the remaining pump data will-
'be gathered in accordance with Section XI requirements.
Basisifor Relief
-The chilled water pumps in the.CR-3 Pump and ValveLInservice Testing Program-3 have not had flow measurement requirementszimposed-on them as' allowed by
. request for_ relief V-370.- In V-370, flow measurements were not required.to be taken due'to a damaged flow element.
Request V-370 was withdrawn, as'a result l of a new element being installed,' and flow measurements were subsequently'
- imposed, 7
The design and operation of the chilled water system results'in low flow conditions.
The element used to measure flow ~ is_ an annubar type that under, '
lower flow conditions, typically will: indicate hydraulic-fluctuations in.
This, coupled with the physical location of-the element downstream measurement.
of an elbow, produces an indication of hydraulic fluctuation that cannot be-reduced to be within 2% of the required reading..
Evaluation u
The_ licensee had indicated that manual averaging. techniques will be used to 3
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reduce pump hydraulic, instrument fluctuations.
Based upon NRC, understanding.of-the Code, this type of averaging is, permitted to meet-the requirements of-a IWP-4150.
Therefore, relief from the Code-requirements is not necessary, i
In Crystal River' 3 LER 90-003, the licensee has indicated that-engin'eering'is pursuing enhancing the existing instrumentation which will provideia digitalL averaging technique.
lde would encourage the licensee to pursue _this' i
enhancement.
l CONCLUSION l.
3 The staff has, determined that relief requests V-115 and V-366 can be granted -
pursuant to 10 CFR 50.55a(a)(3)(i), and that the alternatives' proposed by'the:
L licensee are authorized by law and will not endanger life or: property or the L.
L common defense and security and are otherwise in the public. interest, giving'due l
consideration to the burden upon the licensee that-would. result if the requirements were imposed on the facility.
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e For relief request'V-371 the staff has determined that the manual averaging i
techniques,-proposed as an alternative by.the licensee, are permitted in order to-meet the requirements of IWP-4150, and therefore' relief froft the Code requirements is not necessary.
Dated:.May 1, 1990 Principal Contributors:
H. Shaw E. Sullivan i
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