ML20056H134

Safety Evaluation Accepting Licensee 921217 Response to NRC 920917 SE Re Inservice Testing Program Relief Request

ML20056H134
Person / Time
Site:	Farley
Issue date:	08/23/1993
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20056H127	List: ML20056H126 ML20056H134
References
GL-89-04, GL-89-4, NUDOCS 9309080269
Download: ML20056H134 (5)

Text

j e arc 8 A i *I E UNITED STATES l  ! NUCLEAR REGULATORY COMMISSION yv..... / WASHINGTON, D.C. 205550001 r

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SOUTHERN NUCLEAR OPERATING COMPANY. INC.

1 JOSEPH M. FARLEY NUCLEAR PLANT. UNITS 1 AND 2 DOCKET NOS. 50-348 AND 50-364

1.0 INTRODUCTION

The Nuclear Regulatory Commission requires that inservice testing (IST) of certain American Society of Mechanical Engineers Boilers and Pressure Vessel Code (ASME Code) Class 1. 2, and 3 pumps and valves be performed in accordance with Section XI of the ASME Code and applicable addenda, except where alternatives have been authorized or relief has been requested by the licensee and granted by the Commission pursuant to Sections (a)(3)(i), (a)(3)(ii), or (f)(6)(i) of 10 CFR 50.55a. In proposing alternatives or requesting relief, the licensee must demonstrate that: (1) the proposed alternatives would provide an acceptable level of quality and safety; (2) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. NRC guidance contained in Generic Letter (GL) 89-04, " Guidance on Developing Acceptable Inservice Testing Programs," provided alternatives to the ASME Code ,

requirements determined acceptable to the staff.

, Section 10 CFR 50.55a authorizes the Commission to approve alternatives and to grant relief from ASME Code requirements upon making the necessary findings.

The NRC staff's findings with respect to authorizing alternatives and granting j or not granting the relief requested as part of the licensee's IST program are +

contained in this Safety Evaluation (SE).

Furthermore, in rulemaking to 10 CFR 50.55a, effective September 8, 1992 (see 57 FR 34666), the 1989 Edition of the ASME Code,Section XI, was incorporated i in paragraph (b) of Section 50.55a. The 1989 Edition provides that the rules for IST of pumps and valves shall meet the requirements set forth in the ASME -

Code Operations and Maintenance Standards Part 6 (OM-6), Inservice Testing of i Pumps in Light-Water Reactor Power Plants, and Part 10 (OM-10), inservice Testing of Valves in Light-Water Reactor Power Plants. Pursuant to 10 CFR 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, and subject to Commission approval. Because the alternatives meet later editions of the ASME Code, relief is not required for those inservice tests that are conducted in accordance with OM-6 and OM-10, or portions thereof, provided all related requirements are met. Whether all related requirements are met is subject to NRC inspection.

L 93090B0269 DR 930823 ADOCK 05000348 PDR _

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i The IST program evaluated in this SE covers the second ten-year IST interval for Joseph M. Farley Nuclear Plant, Units 1 and 2 (Farley). The interval ends December 1, 1997. The second ten-year interval IST program is based on the i requirements of the 1983 Edition of the ASME Code Section XI, including the i Summer 1983 Addenda, which were incorporated by reference in 10 CFR 50.55a(b) {

effective October 28, 1985. i The staff has completed review of information relating to the Farley inservice Testing (IST) Program for pumps and valves provided by Southern Nuclear  ;

Operating Ccmpany (the licensee) in a letter dated December 17, 1992. The  ;

letter was submitted in response to NRC Safety Evaluation (SE) dated September j 17, 1992. The SE provided the results of the NRC review of the Farley IST- i Program submittals dated July 26, 1991, July 29, 1991, December 3, 1991, December 30, 1991, and April 10, 1992, concerning relief requests. .These  ;

submittals contained information related to actions taken by the licensee to address items identified in the NRC's previous SE dated May 23, 1991, and l i NRC's request for additional information dated February 14, 1992.. The results -

of the review are provided below.  ;

2.0 EVALUATION  !

y The September 17, 1992, SE denied three relief requests and stated that >

testing was to comply with applicable ASME Code,Section XI, requirements i and/or Generic Letter (GL) 89-04, " Guidance on Developing Acceptable Inservice  !

Testing Programs," within 3 months of the date of the SE. Two of the denied  !

relief requests were withdrawn and replaced with cold shutdown justification j (per the licensee's December 17, 1992 submittal), in accordance with the ASME ,

1 r Code requirements.

2.1 Relief Reauest Ol/2-N23-RV-1 i

The third denied relief request (Ql/2-N23-RV-1) for the condensate storage i tank to auxiliary feedwater pump suction check valve was resubmitted as a t relief request; however, the alternative testing of verifying closure by a i pressure decay test during cold shutdowns and refueling outages meets the  ;

! frequency requirements of IWV-3521 and IWV-3522, and provides a method that is  :

in accordance with IWV-3522 and GL 89-04, Attachment 1, Position 3, guidance  ;

for closure verificatict f check valves. Therefore, Relief Request j Ql/2-N23-RV-1 is in accordance with the ASME Code and should be changed to a i cold shutdown justification to document the basis for extending the testing I from once every 3 months. Because this is allowed by the ASME Code, NRC +

evaluation is not required by 10 CFR 50.55a. For additional quidance, refer to Question 102 in the " Minutes of the Public Meetings on Generic Letter

• 89-04," dated October 25, 1989.

2.2 Completed items The licensee has completed actions necessary to address Items 5.2, 5.4, 5.5, l 5.6, 5.7, 5.8, and 5.9.  ;

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.' 2.3 Relief Recuest PR-10 j i

for Item 5.1, Relief Request PR-10, the licensee proposed to measure flow in r two pump combinations during quarterly testing of service water pumps. The .

ASME Code requires the pumps to be tested individually. Provisional relief  !

from quarterly, individual pump testing was granted for the service water  !

pumps provided the licensee tests each of the five pumps in at least one {

combination quarterly and monitors individual pump operation each refueling outage and cold shutdowns when conditions permit single pump operation. The ,

licensee was also requested to address corrective action to be taken in the i event of a degraded flow from combined operation, and the third pump is e unavailable to support additional testing necessary to analytically determine individual pump flow rates. The licensee revised Relief Request PR-10 to  :

include the following requirements for corrective action to address this  !

action item:

Whenever combir.ed flow measurements are not in the acceptable .!

range, individual pump evaluations, which consist of performing  !

three dual pump combination tests at a reference differential '

pressure and solving analytical equations for individual flows, will be performed. If three pumps are not immediately available l to support this testing, tests will be performed as soon as three pumps are available. For the case in which three pumps are not immediately available to support testing and flow is in the ALERT  ;

Range, dual pump testing of the two pumps in the ALERT Range will be performed at double the required frequency until three pumps are available. Correc.tive action will be taken on the individual  ;

pumps as a result of the evaluation in accordance with IWP-3230.

Individual service water pumps testing will be performed at each  !

refueling outage and any cold shutdown of sufficient duration to I support such testing. Individual pump testing will consist of I monitoring pump flow, differential pressure, and vibration and comparison of test data to reference values for each parameter.

The licensee's revised relief request satisfactorily addressed the provisions in the staff's SE of September 17, 1992. The testing and implementing procedures are subject to NRC inspection.

2.4 Relief Recuests 02E13-RV-1 and 02E13-RV-4 For Item 5.3, the revised relief requests (marked " Version 1") indicate that a disassembly and inspection program for the applicable check valves i (containment spray header check valves QV-222A/B and refueling water storage l tank suction check valve QV-014) will be conducted in accordance with l GL 89-04, Attachment 1, Position 2, until modifications allow full-flow l testing. Generic Letter 89-04 approved this alternative method pursuant to 10 CFR 50.55a(g){6)(i) (now (f){6)(i)), provided the guidance de;ineated in Position 2 is followed. Therefore, no further action is required at this time for continuation of the relief request until modifications are compete; i however, the licensee included " Version 2" of Q2E13-RV-1 indicating that it is "not applicable until the Unit 2 modification which supports full flow testing of the containment spray pumps is completed." Version 2 of Q2E13-RV-1 for valves QV-002A/B and QV-014 is evaluated below.

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, 2.4.1 Licensee's Basis for Relief The licensee states: "The only way to verify full forward-flow operability during normal operation or cold shutdown would be by using the pumps and injecting a large quantity (sic) of water into the containment. Spraying the containment would result in extensive damage to safety-related equipment located inside the containment.

Partial exercision using air as a test medium is not possible during normal operation because Technical Specifications required primary containment integrity in operating modes 1 - 4 and attachment of test connections would violate containment integrity."

2.4.2 Alternative Testina The licensee proposes: "The system has been modified such that spool pieces can be installed downstream of these check valves. During refueling, these spool pieces will be installed and a full-forward-flow test performed by pumping water through these full-flow test lines to the containment refueling cavity. Because of the time involved in installing the spool pieces and the large quantity of water necessary, this test can only be performed at refueling.

Additionally, QV014 will be partial-forward-flow verified during quarterly pump testing, and valves QV002A(B) will be partially exercised using air as a test medium during cold shutdown. If multiple shutdowns occur, testing frequency for valves QV002A(B) is not to exceed quarterly.

This relief request is not applicable until the Unit 2 modification which supports full-flow testing of the containment spray pumps is completed.

2.4.3 Evaluation The 1989 Edition of ASME Code,Section XI, references OM-10 for inservice i testing of valves. OM-10 recognizes that there may be impracticalities for testing valves quarterly or during cold shutdowns and allows testing to be extended to refueling outages. For check valves, the applicable paragranh of OM-10 is 4.3.2. Provided all related requirements are met, a licensee may us portions of the ASME Code edition approved in 10 CFR 50.55a(b), subject to Commission approval, pursuant to 10 CFR 50.55a(f)(4)(iv). The revised relief request includes adequate justification to defer testing to refueling outages, considering the impracticali.ty of the design to enable testing, the extent of the temporary modifications required to perform the testing, and the partial flow test quarterly. Therefore, the testing may be performed in accordance with the requirements of OM-10, paragraph 4.3.2, with related requirements specified in paragraph 6.2 to document the basis for the extension which is  !

provided by the relief request.  !

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.' The testing of the containment spray check valves by partial-stroke exercising ,

during pump testing quarterly, or air testing during cold shutdown, with full-stroke exercising during refueling outages, is approved pursuant to 10 CFR 50.55a(f)(4)(iv) provided the licensee implements the requirements of OM-10, Paragraphs 4.3.2 and 6.2, for extension of the test interval. Whether all related requirements are met is subject to NRC inspection. l 3.0 Conclusion  ;

The staff has determined that approving the requested alternative pursuant to '

10 CFR 50.55a(f)(4)(iv) is authorized by law and will not endanger life or property, or the common cafense and security and is otherwise in the public interest. In making this determination, the staff has considered the  !

impracticality of performing the required testing and the bu: den on the '

licensee if the requirements were imposed.

Principal Contributors: Patricia Campbell, DE/EMEB Ken Dempsey, DE/EMEB t

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