ML20035G513
| ML20035G513 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/23/1993 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20035G512 | List: |
| References | |
| NUDOCS 9304280027 | |
| Download: ML20035G513 (16) | |
Text
{{#Wiki_filter:'. ro ot co 4 UNITED STATES [m '
- j NUCLEAR REGULATORY COMMISSION
- I-f WASHINGTON, D.C. 205 5 0001 o
.....s SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION i RELATED TO THE INSERVICE TESTING PROGRAM AND RE0 VEST FOR RELIEF TOLEDO EDISON COMPANY DAVIS-BESSE NUCLEAR POWER STATION DOCKET NO. 50-346 1
1.0 INTRODUCTION
The Code of Federal Regulations,10 CFR 50.55a, requires that inservice testing (IST) of certain ASME 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(f)(6)(i) where the alternative has been authorized pursuant to 50.55a(a)(3)(i) or o: (a)(3)(ii). In requesting relief, the licensee must demonstrate that: (1) the proposed alternative provides 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 and safety; or (3) conformance i is impractical for its facility. The NRC guidance contained in Generic Letter (GL) 89-04, " Guidance on Developing Acceptable IST Programs," provided alternatives to the Code requirements determined to be acceptable to the NRC staff. Section 50.55a of 10 CFR authorizes the Commission to grant relief from or approve alternatives to ASME Code requirements upon making the necessary findings. The NRC staff's findings with respect to granting or not granting l the relief requested or authorizing the proposed alternatives as part of the licensee's IST Program are contained in this Safety Evaluation (SE). This SE covers new relief request RP-7 and resubmitted relief requests RV-1, RP-5 and RP-6 for the Davis-Besse Nuclear Power Station, Unit 1, as described in Toledo Edison Company's (the licensee) letter dated July 8,1992. The licensee's second 10-year interval IST program is based on the requirements of Section XI of the ASME Code, 1986 Edition. The interval began September 21, 1990. 2.0 RELIEF RE0 VEST RP-7 The licensee has requested relief from the ASME Code, 1986 Edition, Section XI, Subsection IWP, Table IWP-3100-2 requirements to measure displacements for the vibration test quantities. Relief is requested for all IST Program pumps. h P P
2.1 Basis for Relief Vibration is determined by measurement of a specific displacement parameter for each pump in the program as defined per the ASME Code, 1986 E m ion, Section XI. Above 600 rpm, displacement has been determined as a poor i indicator of pump performance. All the IST program pumps are of the l centrifugal type with motor speed greater than 600 rpm. Some pump displacement readings are not repeatable. Therefore, for vibration the velocity quantities shall be evaluated in lieu of displacement quantities. ASME OM-1990 Code, Section ISTB 4.6.4 and ISTB Table 5.2-2a requires more than one vibration point to monitor, hence more test data is required. Therefore, an acceptable level of quality and safety is still present. 2.2 Alternate Test If an engineering evaluation indicates that velocity is a more appropriate i indicator for pump degradation, then velocity shall be used in lieu of displacement. These velocity quantities shall meet the alert levels and required action levels as defined per ASME OH-1990 Code, Sedion ISTB 4.6.4 and Table 5.2-2a, " Ranges for Test Parameters." 2.3 Evaluation The licensee has requested relief from the requirements of Section XI, Subsection IWP, pertaining to measurement of pump vibration amplitude and proposes an alternate test to allow for measurement of pump vibration velocity. The purpose of pump vibration assessment is to assure operability, detect degradation, and effect repairs prior to the onset of conditions leading to pump inoperability. The proposed alternative to measure, monitor and evaluate vibration velocity is an industry-accepted method that provides a comprehensive and sensitive technique of assessing pump condition and early f indications of degradation. l The advantages of measuring and monitoring vibration velocity for assessing the condition of pumps operating above 600 rpm are widely acknowledged in the industry, including the Codes and standards community. The ASME/ ANSI OM-6 Standard, " Inservice Testing of Pumps in Light-Water Reactor Power Plants," allows for this method of vibrational monitoring for inservice testing. Thi's standard has been incorporated into the ASME OM-1990 Code for Operation and Maintenance of Nuclear Power Plants. Further, Regulatory Guide 1.147, " Inservice Inspection Code Case Acceptability ASME Section XI Division I," approved the use of Code Case N-465 which states ASME/ ANSI OM-6 may be used for pump testing in lieu of Subsection IWP. The ASME OH-1990 Code has yet to be accepted by the NRC. Furthermore, in rulemaking to 10 CFR 50.55a effective September 8, 1992, (See 57 Federal Reaister 34666), the 1989 edition of ASME Section XI was incor-porated in paragraph (b) of f 50.55a. The 1989 edition provides that the l
1 l i rules for IST of pumps and valves may meet the requirements set forth in ASME Operations and Maintenance Standards Part 6 (OM-6), " Inservice Testing of Pumps in Light-Water Reactor Power Plants," and Part 10 (OM-10), " Inservice Testing of Valves in Light-Water Reactor Power Plants." Pursuant to (f)(4)(iv), portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met, and therefore, relief is not required for those inservice tests that are conducted in accordance with OM-6 and OM-10, or portions thereof. 1 2.4 Findina Relief is no longer required pursuant to 10 CFR 50.55a(f)(4)(iv). The licensee's proposed alternate is covered by the rulemaking effective i September 8, 1992, and no further action would be required provided the testing of the pumps meets the requirements for vibration monitoring per OM-6 l as noted above. Whether all related requirements are met is subject to NRC inspection. i 3.0 RELIEF RE0 VESTS PR-5 AND PR-6 The licensee requested relief from ASME, 1986 Edition, Section XI, Subsection IWP, paragraphs IWP-3100 and IWP-3500 requirements to measure pump inlet pressure, differential pressure, flow rate, vibration, ar,d test duration. 1 i The relief is requested for pumps, P195-1 and P195-22, that transfer diesel fuel oil from the emergency diesel generator (EDG) fuel oil storage tanks to the EDG day tanks. i 3.1 Basis for Relief The diesel fuel oil transfer pump discharge plenum is bolted to the manhole cover on the top of the EDG Fuel Storage Tank, being submerged inside the tank. The transfer pumps are submersible motor driven, canned, centrifugal pumps. The pump and motor are submersed in an underground tank and are not accessible for vibration measurements. These pumps are low flow, rated at 10 gpm. They automatically start on low EDG Day Tank level of 7 feet, approxi-mately 5050 gallons, then automatically shut off at 71/2 feet. This corres-ponds to about 250 gallons pumped. This safety feature maintains a minimum level as required by Technical Specification (TS) paragraph 3.8.1. An EDG fuel oil storage tank has a capacity of apprcximately 40,000 gallons. The EDG day tanks have a capacity of 6000 gallons. The EDG tanks can be cross-connected to each other allowing one EDG transfer pump to serve both tanks. Each EDG day tank has the capability of emergency fill from the 100,000 gallon fuel storage tank. EDG fuel design flow is 4.5 gpm, therefore each day tank can last approxi-mately 22 hours. This time period is sufficient to allow off-site fuel oil delivery service directly to the day tanks.
e l t None of the pumps have installed instrumentation to measure either ficw or i discharge pressure. Discharge pressure cannot be varied since there are no isolation valves. The only possible flow measurement is by measuring tank volume change over time. Error in measuring this volume is dependent on fuel oil temperature and a limited change in level indication because the EDG day tank has a large upper circular section. Flow rate is dependent upon EDG fuel oil storage tank level and fuel oil viscosity, which varies with environmental temperature conditions. There are no recirculation pathways nor j designed drainage pathways. To date, no maintenance has been required for these canned rotor pumps. The pumps have successfully started and delivered fuel oil upon demand. The l latest flow test indicates that the pump design flow rates are being met. To perform Section XI testing would require extensive plant modifications. Performance of ASME Section XI testing requirements without major modification to plant structure is impractical. 3.2 Alternate Test Pump test flow functional testing is performed each month per TS paragraph 4.8.1.1.2. Pumps are observed to start with a corresponding increase level in the EDG day tank. Pump flow rate tests are performed each refueling. A predetermined oil level above the transfer pump will be set. Flow rate is obtained by measuring a change in EDG day tank level over time. A EDG day tank level change of 150 gallons or more shall be timed to determine flow rate. j There are no means of obtaining differential pressure, nor the ability to throttle flow. Flow rate will be calculated from a known increase in EDG day tank level. Pump suction will be preset by adjusting fuel oil level. Pump l discharge is consistent since there are no throttle valvet Based upon these conditions, pump flow rates should be repeatable and capable of predicting } pump degradation. i A low required action range of less than 6 gpm will be used in lieu of Table 3100-2. Based upon engineering judgment, the developed range in lieu of Table 3100-2 is required because of errors from fuel oil temperature and viscosities, EDG fuel oil storage tank level measurements, and EDG day tank measurements. This range will ensure EDG transfer pumps do not 1egrade below required design system flow requirements. Pump flow rates will be trended for degradation. No alert levels shall be specified since this is a refueling test, hence required action will be performed if the pump flow rate is determined to be outside the acceptable range.
^ F o l i Periodically, the EDG fuel oil storage tanks are drained, cleaned, and inspected. At these times, a long term pump duration test is possible. The i transfer pump will be required to consecutively pump 1000 gallons of fuel from [ the EDG fuel oil storage tank to the EDG day tank. Flow rate will be measured t and evaluated for degradation. 3.3 Evaluation L It is impractical to take vibration measurements on these pumps. The pumps i and motors are located inside the EDG fuel oil storage tank, are not acces-sible during operation, and are submersed in the fuel oil being pumped. L Further, there are no installed flow or pressure instrumentation or recircu-lation lines available to perform the Code-required testing. The existing fuel transfer system has significant redundancy, including several independent methods for replenishing the day tanks during diesel generator operation. Some methods do not require the use of transfer pumps. Significant system and [ plant modifications would be required to perform the Code-specified testing, creating a burden on the licensee. l The alternate testing proposed by the licensee includes monthly functional p;;p tests per TS requirements, pump flow rate tests (based on a flow of 150 l gallons or more) at each refueling, and periodic maintenance pump flow rate tests (based on a flow of 1000 gallons or more). The flow rate tests will be performed under preset and repeatable system conditions. The pump flow rates will be analyzed and trended for indications of degradation. A required l action range for a pump flow rate of less than 6 gpm will be established for i corrective action by the licensee. The required action range provides sufficient margin over the required fuel flow rate. The alternate test provides an adequate means of monitoring these pumps for degrading conditions. 3.4 Findino Based on the proposed test providing adequate assurance of operational readi-ness, and considering the impracticality of performing testing in accordance with the Code and the burden on the licensee if the Code requirements were imposed, relief for testing of these pumps is granted pursuant to 10 CFR 50.55a(f)(6)(i). 4.0 REllEF REOUEST RV-1 The licensee has requested relief from the ASME Code, Section XI, Subsection IWV, Paragraph IWV-3412, requirements for exercising valves quarterly during l plant operations or during cold shutdown conditions. Relief is requested for decay heat removal valves DH-9A and DH-9B. These valves are the emergency sump isolation valves providing suction to the low-pressure decay heat removal pumps and containment spray pumps. l l l 1 i
l l 1 l - 4.1 Basis for Relief Valves DH-9A/B are the emergency sump isolation valves providing suction to the low pressure injection (LPI) decay heat (DH) pumps and containment spray (CS) pumps during the recirculation phase following a postulated loss of coolant accident. The LPI/DH pumps and the CS pumps suction are also connected to the borated water storage tank (BWST) via the normally open BWST isolation valves DH-7A and DH-78. I During normal operation, valves DH-9A/B are deenergized in the closed position to address 10 CFR Part 50, Appendix R, fire protection concerns. Valves DH-9A/B are also interlocked with valves DH-7A/B and BWST level. On low-low BSWT level, the interlocks permit the operator to open valves DH-9A/B. Once these valves begin to open, the interlock signals valves DH-7A/B to close. Cycling of valves DH-9A/B to accomplish the required Code testing during normal plant operation would require isolation of the BWST, the source of emergency cooling system water, defeating the interlocks to permit opening of valves DH-9A/B, and reenergize power to valves DH-9A/B contrary to fire protection commitments. Closure of valves DH-7A/B to isolate the BWST would also place additional reliance on these valves to open on an actuation signal should a LOCA occur during this evolution. This is not a normal plant i configuration assumed as an initial condition in the safety analysis. Cycling of valves DH-9A/B introduces water into the containment emergency sump since the downstream DH system piping is full of water even if the BWST is isolated. Consequently, valves DH-9A/B can be tested only when blank flanges can be installed in the containment sump upstream of valves DH-9A/B to prevent water from the DH piping from flowing into the sump when the valves are open. Even at that, the water trapped between the valves and flanges will drain into the sump when the flanges are removed. Blank flanges cannot be installed during normal operation because the containment emergency sump is inaccessible and installation of a flange would render the affected emergency core cooling train inoperable. I Even during cold shutdown, installation of the flanges and restoring the sump to operational readiness and filling and venting drained sections of piping presents a significant burden to accomplish during a non-refueling outage. The emergency sump debris screens must be removed. The sump is a contami-nated area. Removal of the flanges and draining of the water trapped between flanges and valves provides additional opportunity for personnel contami-nation. These factors, in combination with the need to defeat the interlocks, the pressure of time associated with a non-refueling outage cold shutdown, and risk associated with potential errors as identified in NRC Information Notice 91-22, are significant liabilities when compared with the minimal benefits of-performing testing during cold shutdown. The ASME Code Section XI requirements for testing valves DH-9A/B have not changed from the 1977 Edition with addenda through Summer of 1978, the basis for the first 10-year IST program; nor has the burden associated with testing valves DH-9A/B at cold shutdown changed. In the evaluation of the first c
w f a 10-year interval IST program, the NRC staff concluded that the benefit to be gained by testing valves DH-9A/B at cold shutdown does not warrant the burden; this same relief reauest for testing during refueling was approved for the first 10-year interval by NRC letter to Toledo Edison dated May 18, 1984. 4.2 Alternate Test Exercise and time valves during each refueling. 4.3 Evaluation This relief request was revised and resubmitted for NRC staff review and approval. The previous submittal was denied on the basis of inadequate justification for not performing the Code-required testing during cold shutdowns. The Code requires valves that cannot be exercised during plant operation shall be specifically identified and shall be full-stroke exercised during cold shutdowns. It is impractical to test these valves during power operation since the testing would defeat valve safety interlocks and isolate the BWST from one train of safety system components and render the HPI, LPI, and Containment Spray system associated with that train inoperable. This would place the plant in an unanalyzed safety condition. It is also impractical to test these valves during cold shutdowns since the testing would involve defeating interlocks, entering the sump to remove debris screens, installing and removing blind flanges, draining water trapped between the valves and flanges, filling and venting drained sections of sump piping, performing the tests, and returning the system to operational condition after testing. It is impractical to complete this testing within the usual cold shutdown time frame. i Furthermore, in rulemaking to 10 CFR 50.55a effective September 8, 1992, (See i 57 Federal Reaister 34666), the 1989 edition of the ASME Code Section XI was incorporated in paragraph (b) of f 50.55a. The 1989 edition provides that the rules for IST of pump: and valves may meet the requirements set forth in ASME Operations and Maintenance Standards Part 6 (OM-6), " Inservice Testing of Pumps in Light-Water Reactor Power Plants," and Part 10 (OM-10), " Inservice Testing of Valves in Light-Water Reactor Power Plants." Pursuant to ~ (f)(4)(iv), portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met, and there-fore, relief is not required for those inservice tests that are conducted in accordance with OM-6 and OM-10, or portions thereof. OM-10, paragraph 4.2.1.2 (e), allows that "if exercising is not practical during plant operation or cold shutdown, it may be limited to full-stroke during refueling outages." I i t i w.
i e 4.4 Findina Relief is no longer required related to full-stroke exercising during refueling outages, based on rulemaking effective September 8, 1992, pursuant to 10 CFR 50.55a paragraph (f)(4)(iv), provided the licensee implements all related requirements of OM-10, paragraph 4.2.1.2 (e). Whether all related requirements are met is subject to NRC inspection. 5.0 Conclusion The NRC staff has completed its review of the revised and new relief requests. Based on its review of the IST program requests, the NRC staff concludes that the relief requests will provide reasonable assurance of the operational readiness of the pumps and valves to perform their safety-related functions. The NRC staff has determined that grar. ting relief pursuant to 10 CFR 50.55a(f)(6)(1) 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 NRC staff has considered the acceptability of proposed alternate testing, the impracticality of performing the required-testing considering the burden if the requirements were imposed, and whether the proposed alternative testing meets the requirements set forth in subse-quent editions and addenda that are incorporated by reference in 10 CFR 50.55a(b). Attached is a summary of the staff's findings.
Attachment:
Summary Principal Contributor: F. Grubelich Date: I f ) l t
? l 5 SLMMRY
SUMMARY
OF STAFF'S COMMENTS ON TOLEDO EDISON'S RESPONSE TO NRC SE OF DAV]S-BESSE NUCLEAR POWER STATION'S SECOND 10-YEAR IST PROGRAM ANOMALIES ANOMALIES
SUMMARY
TOLEDO EDIS0N RESPONSE REMAINING ITEM NO., NRC SE DATED DATED JULY 8,1992 ACTION TER DECEMBER 2, 1991 SECTION NO. 1, LICENSEE REQUESTED RATHER THAN JUSTIFY THE STAFF APPROVED TER EXPANDED FLOW THE ACCEPTABILITY OF OM-6 IN RULEMAKING SECTION RANGES IN NEW EXPANDED RANGES T0 10 CFR 50.55a 2.2.1.1 ACCEPTABLE, ALERT THE LICENSEE PROPOSES EFFECTIVE HIGH, AND REQUIRED TO USE THE ACCEPTABLE, SEPTEMBER 8, RANGE FOR SERVICE ALERT AND REQUIRED 1992.* NO FURTHER WATER PUMPS, P3-1, ACTION RANGES IN ACTION WOULD BE 2, AND 3. RELIEF ACCORDANCE WITH ASME REQUIRED PROVIDED WAS GRANTED OM-1990 CODE. THE LICENSEE MEETS PROVIDED THE THE ACCEPTABLE, TECHNICAL BASIS OF ALERT AND REQUIRED l THE ACCEPTABILITY RANGES IN ( OF THE EXPANDED ACCORDANCE WITH RANGES IS ASME OM-6 AS DOCUMENTED. APPROVED IN RULEMAKING AS NOTED AB0VE. (SEE SE PR-7 RELIEF REQUEST EVALUATION) i U__________-_______________________________--__.___________-___---_____---_----__-__--_-_------
5 2 NO. 2, LICENSEE PROPOSED THE LICENSEE PROPOSES THE STAFF APPROVED TER TO MEASURE TO MEASURE VIBRATION OM-6 IN RULEMAKING SECTION VIBRATIGN GF IN THREE ORTH 0 GONAL TO 10 CFR 50.55a 2.2.2.1 SERVICE WATER DIRECTIONS AND MEASURE EFFECTIVE PUMPS P3-1, 2 AND VIBRATION VELOCITY SEPTEMBER 8, 3 IN TWO RATHER THAN 1992.* NO FURTHER DIRECTIONS. THE DISPLACEMENT. THE ACTION WOULD BE REQUEST WAS MEASUREMENTS AND REQUIRED PROVIDED APPROVED PROVIDED ACCEPTANCE CRITERIA THE LICENSEE MEETS AXIAL MEASUREMENTS WILL BE IN ACCORDANCE THE VELOCITY l WERE INCLUDED AND WITH ASME OM-1990 MEASUREMENT ACCEPTANCE CODE. REQUIREMENTS AND CRITERIA ASSIGNED. ACCEPTANCE CRITERIA IN ACCORDANCE WITH ASME OM-6 AS APPROVED IN RULEMAKING AS NOTED ABOVE. (SEE SE PR-7 RELIEF REQUEST EVALUATION) NO. 3, LICENSEE REQUESTED THE LICENSEE HAS THE STAFF APPROVED TER RELIEF TO TEST DEVELOPED PUMP OM-6 IN RULEMAKING SECTION SERVICE WATER PERFORMANCE CURVES TO TO 10 CFR 50.55a l 2.2.3.1 PUMPS, P3-1,2 AND COVER THE RANGES OF EFFECTIVE 3 IN THE AS FOUND NORMAL AND ACCIDENT SEPTEMBER 8, CONDITION. THE FLOW CONDITIONS. THE 1992.* NO FURTHER REQUEST WAS LICENSEE PROPOSES TO ACTION WOULD BE 1 APPROVED PROVIDED USE THE ACCEPTABLE, REQUIRED PROVIDED THE LICENSEE ALERT AND REQUIRED THE LICENSEE USES DEVELOPS PUMP ACTION RANGES IN ACCEPTABLE, ALERT CURVES AND ACCORDANCE WITH ASME AND REQUIRED ACCEPTANCE OM-1990 CODE FOR ACTION RANGES ]N CRITERIA FOR ACCEPTANCE CRITERIA ACCORDANCE WITH VIBRATION FOR VIBRATION ASME OM-6 FOR MEASUREMENTS. MEASUREMENTS. ACCEPTANCE CRITERIA FOR VIBRATION MEASUREMENTS AS APPROVED IN RULEMAKING AS NOTED AB0VE. (SEE SE PR-7 RELIEF REQUEST l EVALUATION) i [
I 3 NO. 6, THE LICENSEE THE LICENSEE REVISED NO FURTHER ACTION TER REQUESTED REllEF THE RELIEF REQUEST TO REQUIRED. SECTION FROM CORRECTIVE ENSURE THE FAILURE 3.1.1.1 ACTION ANALYSIS INCLUDES AN REQUIREMENTS. OPERABILITY ASSESSMENT RELIEF WAS GRANTED OF THE CAPABILITY OF PROVIDED THE THE COMPONENT TO LICENSEE ENSURES PERFORM ITS SPECIFIED THAT THE TEST FUNCTION IN ACCORDANCE FAILURE ANALYSIS WITH THE TECHNICAL L INCLUDES A SPECIFICATIONS DETERMINATION ON OPERABILITY THE SYSTEM'S DEFINITION. CAPABILITY TO PERFORM ITS SAFETY FUNCTION (S). NO. 7, THE LICENSEE THE LICENSEE REVISED NO FURTHER ACTION TER REQUESTED RELIEF THE RELIEF REQUEST TO IS REQUIRED. SECTION FROM CORRECTIVE INCLUDE A STATEMENT 3.1.2.1 ACTIONS THAT IF A PlV FAILS TO REQUIREMENTS OF MEET THE TECHNICAL THE CODE, SPECIFICATIONS LEAKAGE PARAGRAPH IWV-ACCEPTANCE CRITERIA IT 3427(b) FOR Wil' BE REPAIRED OR VARIOUS CATEGORY A REPLACED TO RESTORE AND A/C PlVs. THE THE VALVE TO AN REQUEST WAS ACCEPTABLE CONDITION. GRANTED PROVIDED THAT CORRECTIVE ACTIONS ARE REQUIRED IF THESE VALVES Fall TO MEET THElR LEAKAGE H LIMITS. i ) 4
0 1 4 NO. 9, THE LICENSEE THE LICENSEE REVISED N0 FURTHER ACTION TER REQUESTED RELIEF THE RELIEF REQUEST TO IS REQUIRED. SECTION FROM THE TEST INCLUDE PARTIAL FLOW 3.2.2.1 FREQUENCY TESTING 0F THESE REQUIREMENTS OF VALVES AT COLD THE CODE, SHUTDOWN. PARAGRAPH IWV-3410 FOR THE M010R DRIVEN AUXILIARY FEEDWATER PUMP DISCHARGE TO STEAM GENERATOR LINE CHECK VALVES, AF-39, 43, 72, 73, 74, AND 75. RELIEF WAS GRANTED PROVIDED THE LICENSEE INVESTIGATE A METHOD TO PART-i STROKE EXERCISE THESE VALVES AT F COLD SHUTDOWN AND DOCUMENT THE FINDINGS IN A REVISED RELIEF REQUEST. NO. 10, THE LICENSEE THE LICENSEE WITHDREW NO FURTHER ACTION TER REQUESTED RELIEF THE RELIEF REQUEST. IS REQUIRED. SECTION FROM VERIFYING 3.4.1.2 REVERSE FLOW CLOSURE QUARTERLY FOR COMPONENT COOLING WATER CHECK VALVES, CC-17, 18 AND 19. RELIEF WAS DENIED SINCE INADEQUATE TECHNICAL INFORMATION OR JUSTIFICATION WAS PROVIDED. t e
e i I 5 NO.ll, THE LICENSEE THE LICENSEE HAS NO FURTHER ACTION TER REQUESTED RELIEF REVISED THE RELIEF REQUIRED. SECTION FROM THE TEST REQUEST TO INCLUDE 3.7.1.2 FREQUENCY COLD SHUTDOWN PART-REQUIREMENTS OF STROKE EXERCISING OF THE CODE, THESE VALVES. PARAGRAPH IWV-3522 FOR THE CORE FLOOD TANK DISCHARGE VALVES,CF-28 AND
- 29. THE LICENSEE PROPOSED TO VERIFY FORWARD FLOW CAPABILITY AT REFUELING OUTAGES.
RELIEF WAS GRANTED PROVIDED THE LICENSEE i INVESTIGATE A METHOD TO PART-STR0KE THESE VALVES IN THE PROCESS OF COLD SHUTDOWN. NO. 13, THE LICENSEE THE LICENSEE REVISED NO FURTHER ACTION TER REQUESTED REllEF THE RELIEF REQUEST TO REQUIRED. SECTION FROM THE METHOD OF REQUIRE FULL FORWARD 3.12.1.1 PERFORMING REVERSE FLOW TESTING AFTER FLOW CLOSURE INSPECTION AND VERIFICATION FOR REASSEMBLY. MAIN STEAM CHECK i VALVES, MS-726 AND 727. SAMPLE DISASSEMBLY AND INSPECTION WAS PROPOSED. RELIEF WAS GRANTED PROVIDED EXERCISING WAS PERFORMED UPON COMPLETION OF INSPECTION AND PRIOR 10 RETURN TO SERVICE. p
s 6 1 NO. 14, THE LICENSEE THE LICENSEE WITHDREW ND FURTHER ACTION TER REQUESTED RELIEF THE RELIEF REQUEST. IS REQUIRED. SECTION FROM EXERCISING l 3.13.2.3 FREQUENCY REQUIREMENTS OF THE CODE, PARAGRAPH IWV-3521, FOR MAKEUP PUMP MINIMUM FLOW LINE CHECK VALVES, l MU-204 AND 207. EXERCISING DURING l REFUELING OUTAGES l WAS PROPOSED. THE JUSTIFICATION FOR NOT PERFORMING COLD SHUTDOWN TESTING WAS INADEQUATE. RELIEF WAS DENIED. NO. 15, THE LICENSEE THE LICENSEE REVISED NO FURTHER f.CTION TER REQUESTED RELIEF THE RELIEF REQUEST TO REQUIRED. i SECTION FROM EXERCISING INCLUDE AN ALTERNATE 3.15.2.1 FREQUENCY AND TEST. THE ALTERNATE STROKE TIME TEST WILL MEASURE FLOW MEASUREMENTS FOR THROUGH THE VALVE AND i PORV RC-2A. RELIEF PRESSURE DECAY TIME WAS GRANTED BASED ON ESTABLISHED PROVIDED THE REPEATABLE CONDITIONS. LICENSEE DEVELOPED A REFERENCE PRESSURE ACCEPTANCE DECAY TIME AND CRITERIA ACCEPTANCE CRITERIA SUFFICIENTLY WILL BE ESTABLISHED. RESTRICTIVE TO TEST DATA WILL BE PERMIT. MONITORING TRENDED TO IDENTIFY VALVE DEGRADATION., VALVE DEGRADATION. l 1 i
O 3 I t 7 NO. 16, THE LICENSEE THE LICENSEE WITHDREW NO FURTHER ACTION F TER REQUESTED RELIEF THE REQUEST. REQUIRED. SECTION FROM QUARTERLY 3.15.2.2 EXERLISING, TIMING AND FAIL-SAFE i TESTING CODE i REQUIREMENTS FOR RCS LOOP VENT VALVES, RC 4608A/B AND 4610A/B. THE LICENSEE PROVIDED INADEQUATE JUSTIFICATION FOR i NOT MEETING CODE REQUIREMENTS. THE REQUEST WAS DENIED NO. 17, THE LICENSEE THE LICENSEE WITHDREW NO FURTHER ACTION TER REQUESTED RELIEF THE REllEF REQUEST. REQUIRED. SECTION FROM QUARTERLY 3.16.1.1 VERIFICATION OF REVERSE FLOW CLOSURE CODE REQUIREMENTS FOR SERVICE WATER VALVES SW-17, 18 AND 19. THE LICENSEE PROVIDED INADEQUATE JUSTIFICATION FOR NOT MEETING CODE REQUIREMENTS. THE REQUEST WAS DENIED. In rulemsking to 10 CFR 50.55a effective September 8,1992, (See 57 Federal Reaister 152, 34666), the 1989 Edition of the ASME Section XI was incorporated in paragraph (b) of section 50.55a. The 1989 edition of ASME Section XI i provided that the rules for IST of pumps and valves are specified in OM-6 and OM-10. Section 50.55a paragraph (f)(4)(iv) provides that ISTs of pumps and valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in paragraph (b) of this section, and subject to Commission approval. Pursuant to (f)(4)(iv), portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met, and therefore, relief is not required for those inservice tests that are conducted in accordance with OM-6 and OM-10, or portions thereof. Whether all related requirements are met is subject to NRC inspection.
l Mr. Donald C. Shelton April 23,1993 defense and security and is otherwise in the public interest. v. <*39 this determination, the NRC staff has considered the acceptability of p.s sed o c alternate testing, the impracticality of performing the required testing considering the burden if the requirements were imposed, and whether the proposed alternative testing meets the requirements set forth in subsequent editions and addenda that are incorporated by reference in 10 CFR 50.55a(b). Sincerely, Allen G. liensen/f or John N. Hannon, Director Project Directorate III-3 Division of Reactor Projects - III/IV/V Office of Nuclear Reactor Regulation
Enclosure:
Safety Evaluation cc w/ enclosure: See next page DISTRIBUTION: Docket File NRC & Local PDRs PDIII-3 Reading JRoe JZwolinski JHannon MRushbrook JHopkins OGC ACRS (10) Region III, DRP
- See Previous Concurrence OFFICE PDIII-3:LA:DRPW PDIII-3:PM:DRPW
- 0GC PDIII-3:PD:DRPW NAME M b ook JHepkins/jbh/bj JHull JHannon b b b DATE i /4793
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