ML20045D929
| ML20045D929 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 06/23/1993 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20044E740 | List: |
| References | |
| NUDOCS 9306300237 | |
| Download: ML20045D929 (9) | |
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wassincron, o.c. 20sss-cooi MFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE INSERVICE TESTING PROGRAM RE0 VESTS FOR RELIEF BOSTON EDISON COMPANY PILGRIM NUCLEAR POWER STATION DOCKET NUMBER 50-293
1.0 INTRODUCTION
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 Code and applicable addenda, except where alternatives are authorized or relief is granted by the Commission pursuant to 10 CFR 50.55a(a)(3)(1),
(a)(3)(ii), or (f)(6)(1).
In order to obtain authorization or relief, the licensee must demonstrate that:
(1) the proposed alternatives provide 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 is impractical for its facility.
NRC guidance contained in Generic Letter (GL) 89-04, " Guidance on Developing Acceptable Inservice Testing Programs," provided alternatives to the Code requirements determined to be acceptable to the staff. When an alternative is proposed which is in accordance with GL 89-04 guidance and is documented in the IST program, no further evaluation is required; however, implementation of the alternative is subject to NRC inspection.
In rulemaking to 10 CFR 50.55a, effective September 8,1992 (See 57 Federal Reaister 34666), the 1989 Edition of ASME Section XI was incorporated in paragraph (b) of 50.55a. The 1989 Edition provides that the rules for IST of pumps and valves shall 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 (0M-10), " Inservice Testing of Valves in Light-Water Reactor Power Plants." Pursuant to 50.55a(f)(4)(iv), portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met; therefore, relief is not required for those inservice tests that are conducted in accordance with OH-6 and OM-10, or portions thereof.
Whether all related requirements are met is subject to NRC inspection.
The Code of Federal Re,qulations of 10 CFR 50.55a authorizes the Commission to approve alternatives or grant relief from ASME Code requirements upon making the necessary findings.
The NRC staff's findings with respect to relief requested and alternatives proposed as part of the licensee's IST program are contained in this safety evaluation (SE).
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. The IST program addressed herein covers the third ten-year interval which began December 10, 1992, and ends December 9, 2002. This SE concerns' relief requests in Revision 4 of the Pilgrim Nuclear Power Station IST program that was submitted by Boston Edison Company (the licensee) in a letter dated November 25, 1992.
The licensee's program is based on the requirements of Section XI of the ASME Code, 1986 Edition.
2.0 EVALUATION The licensee's IST program 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).
The technical evaluation report (TER) provided as Attachment 1 is EG&G's evaluation of the licensee's IST program relief requests in the submittal dated November 25, 1992.
The staff has reviewed the TER and cc, curs with the evaluations and conclusions contained therein. A summary of the relief request determinations is presented in Table 1.
The granting of relief or authorization of proposed alternatives is based upon the fulfillment of any commitments made by the licensee in its basis for each relief request and the alternatives proposed. The implementation of the licensee's IST program is subject to inspection by the NRC.
The licensee's IST program contained several relief requests for non-Code components.
These components are not required by 10 CFR 50.55a to be included in the IST program, though it is acceptable to include the components to meet testing requirements of 10 CFR Part 50, Appendix A and Appendix B.
Relief requests related to these components, however, are not evaluated by the staff pursuant to 50.55a. The relief requests for these components are listed in Table 1 of the SE.
The licensee should refer to the TER, Appendix A, for a discussion of IST program anomalies identified during the review.
The licensee should resolve all items in accordance with the guidance therein.
For check valves which are included in a dissssembly and inspection program, the guidance delineated in GL 89-04, Atischn.act 1, Position 2, must be followed for approval per GL 89-04.
Position J includes guidance for extension of the disassembly / inspection interval to longer than once every 6 years and the documentation for supporting the extension.
The information is to be available on-site for NRC inspection.
If the guidance is not followed, the licensee may follow the requirements of OM-10, pursuant to 50.55a (f)(4)(iv), and perform disassembly and inspection of each valve each refueling outage.
By implementing the sampling program per the guidance in Position 2, it is expected that all of the guidance will be addressed.
Implementation is subject to NRC inspection.
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3.0 CONCLUSION
In evaluating the. licensee's requests for relief from the. requirements of Section XI, the staff considered:
(1) the acceptability of proposed
' alternative testing; (2) whether the hardship of-compliance is without a compensating increase in safety;- (3) the impracticality of performing the required testing considering the. burden if the requirements were imposed;.and (4) whether the proposed alternative testing meets thel requirements; set-forth-t in subsequent editions and addenda that are incorporated by reference.in paragraph (b) of 50.55a. The last column of Table 1 identifies the regulation or GL 89-04 guidance under which the requested relief is approved..The NRC staff has determined that granting relief or approving-alternatives ~ pursuant
.to 10 CFR 50.55a is authorized by law and will not endanger life or property,
- or the common defense and security and is otherwise in the public. interest.
The granting of relief or authorization of proposed alternatives is based upon the fulfillment of any commitments made by the licensee in-its basis for each relief request and the proposed alternate testing.
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Principle Contributor: Joseph Colaccino i
Date: June 23, 1993.
- Attachment-1: -TER i
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4 PILGRIM NUCLEAR POWER STATION SAFETY EVALUATION TABLE 1
SUMMARY
OF RELIEF REQUESTS Relief TER Section XI Eouipment Alternate Method of Testing Action by Request Section Requirement and
- dentification USNRC Section Subject l
Pump 2.2.1 IWP-3f 00:
Reactor building closed Measure shutoff head Rein.f Granted R P. I Measure flow rate cooling water quarterly, me.sure individual wah pavision quarter ly (RBCCW) pumps:
pump flow rate and pressure (f)(6)(6 P-202A through -202F each refueling outage.
Pump
2.1.1 IWP-3100
All Code Class pumps Measure vibration velocity at Approved p.:rsuant RP-2 5.ieasure bearing in the IST program.
the same locations as required to 10 CFR 50.55a l temperature by Section XI. Perform a (f)(v-)(iv) spectrum analysis if vibration exceeds 0.314 in./sec.
Pump 2.3.1 IWP-3300, -3500, Standby liquid control Evaluate discharge pressure, Approveo oursuant RP-3 and -4600:
pumps:
verify test tank level to ensure to (0(4)(iv) for test Test duration, P-207A and -207B adequate suction pressure, run duration and inlet measure flow rate, test for three minutes and and differential and measure inlet calculate flow rate based on pressures, and differential change in test tank level over Relief Granted with ll pressures time.
provision (0(6)(i) for flow rate calculation i
Pump
2.4.1 IWP-3100
Salt service water Calculate inlet pressure from Approved pursuant R P-4 Measure inlet pumps:
the tide level.
to (0(4)(iv), with pressure P-208A through -208E provision Pump
2.4.2 IWP-3100
Salt service water Measure shutoff head Relief Granted R P-5 Measure flow rate pumps:
quarterly and measure pump with provision quarterly P-208A through -208E flow rate each refueling (0(6)(i) outage.
Pump
2.4.3 IWP-4510
Salt service water Measure vibration at upper Approved pursuant RP-6 Vibration pumps:
motor bearing housing, to (0(4)(iv), with measurement P-208A through -208E provision location Pump N/A Request retracted N/A N/A N/A R P-7 Pump
2.1.2 IWP-3220
All Code Class pumps Compare results to acceptance Alternate R P-8 Analyze test results in the IST program criteria immediately and Authorized within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> analyze within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />, (a)(3)(i) excluding weekends and holidays.
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2.1.3 IWP-4120
All Code Class pumps Measure vibration with analog Approved pursuant RP-9 Instrument range in the IST program meter with selectable scales, to (0(4)(iv), with requirement take readings within upper provision 70% of meter's full-scale.
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PILGRIM NUCLEAR POWER STATION SAFETY EVALUATION TABLE 1
SUMMARY
OF RELIEF REQUESTS Relief TER Section XI Equipment Alternate Method of Testing Action by Request Section Requirement and Identification USNRC Section Subject Pump N/A Request retracted N/A N/A N/A RP-10 Valve 3.2.2.1 IWV-3521:
RBCCW drywell Exercise every two years.
Approved pursuam R V-01 Test frequency isolation check valve:
to (f)(4)(iv), v Pb 432 provision Valve 3.12.1.1 IWV-3521:
. Pneumatic supply to Exercise open and closed Approved put RV-02 Test frequency drywell isolation check during each refueling interval.
to (f)(4)(iv), wc.a valve: 167 provision V.ilve 3.13.1.1 IWV-3420:
Suppression chamber to Perform a pressure decay test Relief Granted RY-03 Leak rate test drywell vacuum quarterly and combined leak (t)(6)(i) -
I breaker valves:
rate test per plant Technical X-201 A through H, Specifications (TS) during
-201J, and -20lK each refueling interval.
Valve N/A IWV-3417(a):
Various rapid-acting Assign 2 second stroke time Approved by GL R V-04 Corrective action power operated valves limit.
8944, Position 6, request not evaluated in SE/TER.-
Valve 3.14.t.1 IWV-3521:
Transverse incore Exercise open and closed at Approved pursuant R V-05 Test frequency probe (TIP) nitrogen least once every two years.
to (t)(4)(iv), with purge line check valve provision Valve 3.3.1.1 IWV-3521:
Core spray injection Exercise during refueling Approved pursuant RV-06 Test frequency isolation check valves:
outages.
to (f)(4)(iv), with 9A and 9B provision Valve 3.4.2.1 IWV-3413:
High pressure coolant Observe proper system Relief Granted RV-07 Stroke time injection (HPCI) operability.
(f)(6)(i) measurement turbine trip throttle valve: 24 l
Vah.e 3.7.1.1 IWV-3521:
Standby liquid control Exercise valves open each Approved pursuant RV-08 Test frequency injection check valves:
refueling outage.
to (f)(4)(iv), with 15 and 16 provision Valve N/A IWV-34 t l, -2413.
un inlet and outlet Perform scram functional Approved by GL R V-09
-3415. -3521:
v a s: 126 and 127; timing per plant TS. Exercise 89-04, Position 7, Test method and hynrMc control unit valves 114 and 115 open request not frequency (HCU) c mharge during scram functiemal evaluated in header ano ecumulator testing, verify closure of SE/TER.
supply check valves:
valve 115 each reldeling i14 and 115 outage.
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. PILGRIM NUCLEAR POWER STATION SAFETY EVALUATION TABLE 1
SUMMARY
OF RELIEF REQUESTS Relief TER Section XI Equipment Alternate Method of Testing Action by Request Section Requirement and.
Identification.
USNRC Section Subject Valve N/A IWV-3521:
Control rod drive Exercise per TS surveillance Approved by GL RV-10 Test frequency (CRD) cooling water requirements.
89-04, Position 7, check valveu 138 request not -
evaluated in SEffER.
6 Valve 3.8.1.1 IWV-3411, and Main steam automatic Exercise during refueling.
Altemate RV-11
-3413:
depressurization system outages, do not measure Authorized for Test frequency and (ADS) and safety relief stroke times, verify timely Interim Period stroke time valves: 3A through 3D system response.
(a)(3)(i), for 1 year -
measurement or until the next refueling outage Valve 3.8.1.3 IWV-3521:
Feedwater header check Exercise at least once every Approved pursuant RV-12 Test frequency valves: 58A,58B,62A, two years, to (f)(4)(iv), with -
and 62B provision Valve 3.11.1.1 IWV-3521:
Recirculation pump seal Exercise at least once every
. Approved pursuant -
RV-13 Test frequency water system isolation two years, to (f)(4)(iv), with valves: 13A,13B,17A provision l
and 17B Valve N/A Request retracted N/A N/A N/A I
RV-14 Valve N/A Request retracted N/A N/A N/A-RV-15 i
Valve 3.5.1.1 IWV-3413:
Reactor core isolation Observe proper system Relief Granted RV-16 Stroke time cooling (RCIC) turbine operability.
(f)(6)(i) measurement governor valve: 2 Valve 3.9.1.1 IWV-3411 and Rod insertion and Verify operation weekly by Relief Granted '
RV-17
-3413: Test withdrawal valves:
notching control rods.
(f)(6)(i)'
frequency and 120,121,122, and 123 stroke time measurement Valve N/A IWV-3522(b):
Main steam isolation Verify full-stroke open Non-Code Clast RV-18 Test method valve (MSIV) capability _by MSIV full-stroke components,'
accumulator air supply valve cycle testing.
request not check valves:
evaluated in 84 A, B, C, D.
SETTER BSA, B, C, and D i
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i PILGRIM NUCLEAR POWER STATION SAFETY EVALUATION TABLE 1
SUMMARY
OF RELIEF REQUESTS Relief TER Section XI Equipment Alternate Method of Testing Action by Request Section Requirement and Identification USNRC Set tion Subject Valve N/A IWV-3422:
Diesel generator air Verify operation during Non-Code Class R V-19 Test frequency start valves listed in the monthly diesel start tests, components, IST program trend diesel start times.
request not evaluated in SE/TER Valve 3.6.2.1 IWV-3521:
Residual heat removal Part-stroke exercise open Approved pursuant RV-20 Test frequency (RHR) and core spray quarterly and verify a full-to (f)(4)(iv), with keeptill pressurization stroke exercise open during provision check valves:
each refueling interval.
1001-362B, -363 A, 1400-212A, and -212B Valve 3.10.1.1 IWV-3521:
RWCU return flow Exercise closed during leak Approved pursuant RV-21 Test frequency path to reactor vessel testing each refueling outage.
to (f)(4)(iv), with check valve: 81 provision Valve 3.1,1.1 IWV-3422 and All primary Exercise and leak rate test Approved pursuant RV-22
-3521:
containment isolation each refueling outage.
to (f)(4)(iv), with Test frequency excess flow check provision valves Valve N/A IWV-3521:
Emergency diesel Verify full-stroke open during Non-Code Class R V-23 Test frequency generator fuel oil emergency diesel generator components, supply check valves:
testing.
request not i16A and i16B evaluated in SE/TER Wlve N/A Request retracted N/A N/A N/A RV-24 Valve 3.4.1.1 IWV-3413:
HPCI system turbine Verify closure by system Interim Relief R V-25 Test method exhaust drain pot operation and by performing Granted isolation valves:
(f)(6)(i), until 9068A and 9068B refueling outage No.9 Valve 3.9.1.2 IWV-3411 and Rod scram discharge Measure the closed stroke Relief Granted RV-26
-3413: Test volume drain valves:
times and trend this data each (f)(6)(i) frequency and 21 A, 21 B, 22A, 22B, refueling outage.
stroke time 23A 23B,24A and measurement 24B Valve N/A IWV-3522:
Various check valves Disassemble and inspect Approved by GL RV-27 Test method and identified in the IST valves per GL 89-04, 89-04, Position 2, frequency program Position 2.
request not evaluated in SE/TER 4
i PILGRIM NUCLEAR POWER STATION SAFETY EVALUATION TABLE I
SUMMARY
OF RELIEF REQUESTS -
Relief TER Section XI Equipment Alternate Method of Testing Action by Request Section Requirement and Identification USNRC Section Subject Valve N/A IWV-3427(b):
All containment Repair or replace valves as Approved by GL RV-28 Leak testing isolation. <alves determined by licensee or '
89-04, Position 10, corrective action when leakage rate exceeds request not requirements plant TS limit or evaluated in IWV-3427(a).
SE/TER Valve 3.1.5.1 IWV-3417(a):
Various power-operated Compare stroke times against Approved pursuant RV-29 Corrective action valves listed in the IST reference stroke times, to (f)(4)(iv), with program provision Valve 3.1.2.1 IWV-3424, -3426, All leakage important Perform pressure decay tests Relief Granted-R V-30 and -3427:
valves listed in the IST utilizing a pressure boundary (f)(6)(i)
Leak rate testing program specified leakage limit.
requirements Valve 3.15.1.1 IWV-3413:
liydrogen/ oxygen Measure stroke times by Relief Granted RV-31 Stroke time analyzer reagent gas positioning the function with provision measurement valves: 5117A,5117B, selector switch and observing (f)(6)(i) 5137A, and 51378 flow meter indication.
Valve 3.2.1.)
IWV-3411:
RBCCW to drywell Exercise during cold Approved pursuant R V-32 Test frequency isolation valves:
shutdowns when reactor to (t)(4)(iv), with 4009A, 4009B, and recirculation pumps are provision 4002 stopped and drywell coolers are not required and during refueling outrages.
Valve 3.8.2.1 IWV-3411:
Reactor recirculation Exercise during cold Approved pursuant RV-33 Test frequency pump discharge valves:
shutdowns when recirculation to (f)(4)(iv), with 5A and SB pump is stopped but not to provision exceed a refueling interval.
Valve 3.2.3.1 IWV-3411:
RBCCW loop A -
Exercise during cold Approved pursuant RV-34 Test frequency isolation valves:
shutdowns when recirculation to (f)(4)(iv), with 4085A and 4085B pumps are stopped and during provision refueling outages, Valve N/A
!WV-3521:
Main steam Exercise valves open during Non-Code Class RV-35 Test frequency safety / relief discharge cold shutdowns when components, line vacuum relief -
containment is deinerted.
request not check valves:
evaluated in 96A through C, SE/TER -
97A through D, and 98A through D 5
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PILGRIM NUCLEAR POWER STATION SAFETY EVALUATION TABLE 1
SUMMARY
OF RELIEF REQUESTS Relier TER Section XI Equipment Alternate Method of Testing Action by Requot Section Requirement and Identification USNRC Section Subject Valve N/A IWV-3521:
Air accumulator supply Exercise during cold Non-Code Class RV-36 Test frequency valves for ADS valves:
shutdowns when the drywell components, 372A through D is deinerted at least each request not refueling outage.
evaluated in SE/TER Valve 3.1.3.1 IWV-3521:
Various check valves Valve seat leakage test Approved pursuant RV-37 Test frequency listed in the relief performed at least once every to (f)(4)(iv), with request two years.
provision Valve 3.2.4.1 IWV-3521:
RBCCW pump Perform open position Approved pursuant RV-38 Test frequency discharge check valves:
verification in conjunction to (f)(4)(iv), with 30-CK-419 through 424 with the respective pump flow provision rate measurement.
Valve 3.16.1.1 IWV-3521:
Salt service water pump Perform open position Approved pursuant RV-38 Test frequency discharge check valves:
verification in conjunction to (f)(4)(iv), with 29-CK-3880A through with the respective pump flow
. provision 1880E rate measurement.
Valve 3.1.4.1 IWV-3417(b) and All valves in the IST Plant entry into operational Attemate R V-39
-3523:
program modes shall be goverved by Authorized Corrective action plant TS.
(a)(3)(i) with provisions Valve 3.1.4.1 IWV-3417(b):
All power operated Plant startup shall be Approved pursuant RV-39 Corrective action -
valves in the IST governed by plant TS.
to (f)(4)(iv), with program provision Valve 3.8.1.2 ANSI /ASME Main steam ADS and Remove the pilot assemblies Alternate RV-40 OM-1-1987, safety relief valves:
and test them using a slave Authorized Section 3.3, Test 3A, 3B, 3C, and 3D main valve body.
(a)(3)(i) method 9
Vahe 3.6.1.1 IWV-3521:
RHR to recirculation Part-stroke exercise Approved pursuant R V-41 Test frequency loop injection check alternately during cold to (f)(4)(iv), with valves: 68A and 68B shutdowns and verify a full-provision stroke using diagnostics once each refueling interval.
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