ML20044C107
| ML20044C107 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 03/12/1993 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20044C106 | List: |
| References | |
| NUDOCS 9303170251 | |
| Download: ML20044C107 (3) | |
Text
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1 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION 2
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RELATED TO THE INSERVICE TESTING PROGRAM RELIEF REOUEST VR-24 l
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WOLF CREEK NUCLEAR OPERATING CORPORATION WOLF CREEK GENERATING STATION 0
DOCKET NO. 50-482
1.0 INTRODUCTION
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l The Code of Federal Regulations,10 CFR 50.55a, requires that inservice testing (IST) of certain ASME Code Class 1, 2, and 3 pumps and valves be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel i
Code and applicable addenda, except where relief has been granted or proposed alternatives have been authorized by the Commission pursuant to 10 CFR 50.55a (a)(3)(i), (a)(3)(ii) or (f)(6)(1).
In order to obtain authorization or l
relief, the licensee must demonstrate that:
(1) conformance is impractical for its facility; (2) the proposed alternative provides an acceptable level of quality and safety; or (3) compliance would result in a hardship or unusual i
i difficulty without a compensating increase in the level of quality and safety.
Section 50.55a(f)(4)(iv) provides that inservice tests of pumps and valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in (b) of 5 50.55a, subject to the limitations and modifications listed, and subject to Commission approval. That section further provides that portions or editions of addenda may be used provided all related requirements of the respective editions or addenda are met.
Section 50.55a authorizes the Commission to grant relief from ASME Code requirements or to approve proposed alternatives upon making the necessary findings. The NRC staff's findings with respect to granting relief requested or authorizing the proposed alternative as part of the licensee's inservice testing (IST) program are contained in this safety evaluation (SE).
2.0 BASIS FOR RELIEF WCNOC has committed to perform a technical review of and incorporate required changes to all valve test procedures by February 28, 1993. To improve the IST program during these changes, WCNOC desires to adopt ASME/ ANSI OMa-1988, Part 10.
Part 10 incorporates later industry provisions for valve testing and is considered by WCNOC to be a better method of testing than Section XI IWV.
However, adoption of Part I requirements referenced in Part 10 would place an undue burden on WCNOC to incorporate Part I and Part 10 by February 28, 1993.
Therefore, WCNOC will continue to use the existing requirements of IWV-3100,
-3200, -3510, -3700, and -6000 of the 1980 Edition through Winter 1981 addenda of Section XI for pressure relief device testing in lieu of the reference to 9303170251 930512 DR ADOCK 0500 2
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. Part 1 contained in Part 10. The requirements of later editions of the Code can be implemented during an interval pursuant to 10 CFR 50.55a(f)(4)(iv) subject to Commission approval. The first 10-year interval for Wolf Creek began September 3, 1985 and ends September 2, 1995.
3.0 ALTERNATE TESTING By February 28, 1993, WCNOC will adopt all of ASME/ ANSI OMa-1988, Part 10, except references to Part 1.
In addition to Part 10, leakage rates for category A containment isolation valves that do not provide a reactor coolant system pressure isolation function will be analyzed in accordance with paragraph 4.2.2.3(e) of Part 10, and corrective action for these valves will be made in accordance with paragraph 4.2.2.3(f) of Part 10, as required by 10 CFR 50.55a approved in the Federal Register dated August 6, 1992.
WCNOC will continue using IWV-3100, -3200, -3510, -3700, and -6000 and will continue using the alternate testing approved through WCNOC's relief requests.
4.0 EVALUATION WCNOC committed to perform a technical review of and incorporate required changes to all valve test procedures by February 28, 1993. To improve their IST program during these changes, WCNOC desires to adopt ASME/ ANSI OMa-1988, Part 10.
Part 10 incorporates later industry provisions for valve testing.
The WCNOC IST program was developed to be consistent with the ASME Boiler and Pressure Vessel Code Section XI, 1980 Edition, Winter 1981 Addenda.
By letter of December 1,1992, WCNOC requested relief from the Part 1 IST I
requirements referenced in OMa-1988, Part 10 (i.e., Part I requirements for pressure relief device testing shall not be included in the revised IST program to be implemented by February 28,1993). WCNOC intends to include Part I requirements in the IST program plan for the second inspection interval which starts in September 1995.
Until then, WCNOC will continue to use the existing requirements of IWV-3100, -3200, -3510, -3700, and -6000 for pressure relief device testing.
In rulemaking effective September 8, 1992 (57 FR 34666), the 1989 Edition of ASME Section XI was incorporated into 10 CFR 50.55a(b).
The 1989 Edition provides that the rules for IST of valves are as specified in OMa-1988, Part 10 " Inservice Testing of Valves in Light-Water Reactor Power Plants" (OM-10).
The staff modified the requirements of OM-10 related to containment isolation valve leakage testing in the rulemaking.
The licensee plans to incorporate all related requirements of OMa-1988, Part 10, for valves other than safety-relief valves, by February 28, 1993.
Therefore, the request is covered by the rulemaking effective September 8, 1992, as described above, and may be approved pursuant to 10 CFR 50.55a (f)(4)(iv).
Implementation of all related requirements of OH-10 is subject to NRC inspection.
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5.0 CONCLUSION
Pursuant to 10 CFR 50.55a(f)(4)(iv), WCNOC's use of OM-10 is acceptable, provided that all related requirements are met, with the noted modification on containment isolation valves. If the licensee determines that relief from OH-10 requirements is necessary, the relief requests are to be written against the requirements of OM-10 and to provide information concerning the basis for the requested relief as required by 10 CFR 50.55(f)(5)(iii).
4 Therefore, the licensee should submit its revised IST Program to the NRC.
This submittal should include:
a Relief requests written against the requirements of OM-10 where requirements cannot be met (to include relief requests previously i'
granted but written to a different version of the Code).
Justification for deferral of stroke testing in accordance with paragraphs 4.2.1.2 and 4.3.2.2 of OM-10 (see OM-10 paragraph 6.2(d)).
The schedule for implementation of the test plans.
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Principal Contributor: David C. Fischer i
Dated:
March 12, 1993 i