ML20056H265

SE Re Inservice Testing Program Requests for Relief

ML20056H265
Person / Time
Site:	Oyster Creek
Issue date:	08/24/1993
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20056H257	List: ML20056H256 ML20056H265
References
NUDOCS 9309090062
Download: ML20056H265 (31)

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g ea "8 c ii* E UNITED STATES ig  ! NUCLEAR REGULATORY COMMISSION g _ ,/ WA5WNGTON, D.C. 2554m SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE INSERVICE TESTING PROGRAM RE00ESTS FOR RELIfF GPU NUCLEAR CORPORATION OYSTER CREEK NUCLEAR GENERATING STATION DOCKET NO. 50-219

1.0 INTRODUCTION

The Code of Federal Regulations,10 CFR 50.55a(f), 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 relief has been requested by the licensee and granted by the Commission pursuant to 50.55a(f)(6)(i), or where the alternative has been authorized pursuant to 50.55a(a)(3)(i) or (a)(3)(ii).

In requesting relief, the licensee must demonstrate that: (1) the proposed alterr.atives 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 with certain requirements of the applicable Code Editic and addenda is impractical for its facility. Section 50.55a(f)(4)(iv) provio, that inservice tests of pumps and valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 50.55a(b), subject to the limitations i and modifications listed, and subject to Commission approval. 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 and authorized the use of the alternatives in Positions 1, 2, 6, 7, 9, and 10 provided the licensee follow the guidance delineated in the applicable position. When an alternative is propose.d 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.

Furthermore, in rulemaking to 10 CFR 50.55a effective September 8, 1992, (57 FR 34666), the 1989 edition of ASME Section XI was incorporated in 50.55a(b). 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), Intervice Testing of Valves in Light-Vater 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 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.

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These regulations authorize 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 the relief requested or authorizing the proposed alternative as part of the licensee's IST Program are contained in this Safety Evaluation (SE).

GPU Nuclear Corporation, the licensee, submitted their third 10-year pump and  ;

valve IST program in a letter dated October 11, 1991. The third 10-year <

program was developed according to the requirements of the 1986 Edition of l ASME Code,Section XI, which was incorporated by reference in 10 CFR 50.55a May 5, 1988, (53 FR 16051). The staff transmitted a Safety Evaluation (SE) to the licensee addressing the third 10-year IST program in a letter dated September 24, 1992. The SE contained 17 action items which the licensee was requested to address. The licensee submitted their action item responses in a letter dated December 23, 1992. An evaluation of new and revised relief )

requests that were submitted in the December 23, 1992, letter is included '

below. The status of each action item is summarized in Table 1. ,

l The licensee should address issues associated with relief requests that have been granted on a provisional or interim basis in this SE within 1 year or by ,

the next refueling outage, whichever is later, unless otherwise specified in i the SE. Testing associated with Relief Request VR-29 that has been denied is ,

to be in compliance with applicable requirements prior to the initial testing required per IWV-3620 and OM-1-1981.

2.0 EVALUATION OF REVISED RELIEF REOUESTS 2.1 RELIEF REQUEST PR-3 l The licensee has requested relief from the vibration amplitude measurement raquirements of Section XI, Paragraph IWP-4500 for all pumps in the IST program. The licensee is proposing to measure pump vibration in accordance with ANSI /ASME OMa-1988, Part 6 (OM-6).

2.1.1 LICENSEE'S BASIS FOR REQUESTING RELIEF The licensee states: " Velocity gives a better overall measure of machinery condition in the frequencies of interest. Between 600 and 60,000 counts per minute, vibration velocity is independent of frequency yielding a simple measure of vibration severity. The alert and action ranges are chosen based on industry experience for these types of rotating equipment."

2.1.2 ALTERNATE TESTING 1

The licensee proposes to use vibration velocity in lieu of displacement. i l

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2.1.3 ADDITIONAL INFORMATION PROVIDED BY THE LICENSEE The licensee states: " Pump vibration acceptance criteria were previously .

developed based on industry experience for these types of rotating equipment. l Any pump baselined since 1991 complies with OM-6 acceptance criteria. Other l pumps retain their previously developed acceptance criteria. In all cases,  !

the high action acceptance criteria is less than the 0.7 in/sec maximum allowd by OM-6. Since existing acceptance criteria are conservative compared to UM-6, it is acceptable to continue using these values until the pumps are rebaselined, at which time acceptance criteria will be developed in accordance with OM-6."

2.1.3.1 Method of Testing: Centrifugal pumps 1 1

The licensee states: "0M-6 section 4.6.4 requires that vibration measurements '

shall be taken in two orthogonal directions on each accessible pump bearing  !

housing. Measurements must also be taken in the axial direction on each i accessible pump thrust bearing housing. Vibration readings are currently l taken in only one direction at each bearing (the direction of the largest vibration, based on an annual full spectrum vibration analysis). Procedures must be revised to comply with OM-6 requirements. The procedures will be ,

revised within one year of the date of the NRC approval of this request. In i the interim, monitoring vibration in one direction at each pump bearing with acceptance criteria at least as restrictive as OM-6 ensures adequate vibration monitoring to detect pump degradation."

2.1.3.2 Method of Testing: Vertical line shaft pumps The licensee states: "0M-6 section 4.6.4 requires vibration measurements to be taken on the upper motor bearing housing in three orthogonal directions, one of which must be the axial direction. Existing vibration procedures record vibration readings in two orthogonal directions at the base of the pump on the intake deck. Procedures must be revised to comply with the OM-6 requirement. The procedures will be revised within one year of the date of the NRC approval of this request. In the interim, monitoring vibration at the base of the pump on the intake deck with acceptance criteria at least as restrictive as OM-6 ensures adequate vibration monitoring to detect pump degradation."

l 2.1.3.3 Method of Testing: Reciprocating pumps The licensee states: "0M-6 section 4.6.4 requires that vibration measurements shall be laken on the bearing housing of the crankshaft, approximately perpendicalar to both the crankshaft and the line of plunger travel. The only set of reciprocating pumps is in the Standby Liquid Control System. Provision exists for taking readings in the direction specified by OM-6, but readings are currently only taken in a direction perpendicular to the crankshaft and parallel to the line of plunger travel. The procedure must be revised to meet  ;

the OM-6 requirement."  !

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i 2.1.3.4 Vibration Measurement: Reference Points  !

The licensee states: "0M-6 section 4 6 4 requires that if a portable vibration analyzer is used, the reference points must be clearly identified on.

the pump to permit subsequent duplication in both location and plane. Each test procedure contains a pump sketch with vibration data points marked. l' These labeled sketches permit duplication of vibration measurement location in subsequent tests. Vibration test points are not marked on the pumps at the present time. Each point will be marked to comply with this OM-6 requirement." ,

2.1.4 Evaluation j In rulemaking to 10 CFR 50.55a effective September 8,'1992, (57 FR 34666), the

1989 edition of ASME Section XI was incorporated in 50.55a(b). The 1989 i edition provides that the rules for IST of pumps'shall meet the requirements .

set forth in OM-6. Pursuant to 50.55(f)(4)(iv), portions of editions or i addenda may be used provided that all related requirements of the respective '

1 editions or addenda are met, and subject to Commission approval. Therefore, relief is not required for those inservice tests that are conducted in i

, accordance with OH-6, or portions thereof. Whether all related requirements  !

are met is subject to NRC inspection.

The licensee has proposed to use the vibration monitoring requirements of OM-6  !'

1 for vibration monitoring of all pumps in their IST program. The licensee ,

stated that all vibration testing of pumps will comply with the requirements 1 of OM-6 within one year of NRC acceptance of their proposal. Based on the proposal meeting the requirements of a -later edition of the Code incorporated l in 10 CFR 50.55a(b), relief is not required; however, approval by the

Commission is required for implementing the later edition. I a

2.1.5 Conclusion The staff finds the licensee's proposal acceptable and approves the use of OM-

. 6, Paragraphs 4.6.1 and 4.6.4, for vibration monitoring these pumps pursuant to 10 CFR 50.55a(f)(4)(iv) provided the licensee meet the related requirements

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of OM-6 which include Section 5 and Paragraph 6.1. The implementation of these requirements is subject to NRC inspection.

2.2 Relief Request PR-4 The licensee has requested relief from the full-scale range requirements of Section XI, Paragraph IWP-4120, for the suction pressure gauges on the core spray, containment spray, emergency service water, service water, and condensate transfer pumps and the discharge pressure gauges for the service water pumps. The licensee is proposing to use the currently installed gauges. ,

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2.2.1 Licensee's Basis For Requesting Relief  !

i The following information is provided for groups of pumps performing redundant safety functions. '

2.2.1.1 Containment Spray Pump Suction Pressure (PI-21-349, 350, 351, 352):

Range: -15 psig to +15 psig  !

Accuracy: i0 6 psig (12% of 30) '

Reference Values (psig):

l Containment Spray Pumps  !

A _B_ C D  !

Suction

! Pressure (P,) 5 5 5 5.5 3

] Discharge

) Pressure (Po ) 71 71 71 71.5

) Licensee's justification: " Suction pressure is only a fraction of pump discharge pressure (7.7%, at most). A small change in suction pressure will have minimal affects on the calculation of pump differential pressure. Since Containment Spray is a fixed resistance system, pump flow is used to track ,

pump performance. Therefore, small changes in pump suction pressure will not -

impair analysis of pump performance." i 2.2.1.2 Condensate Transfer Pump Suction Pressure (PI-18, PI-20):

Range: -20 in Hg to +30 psig Accuracy: f.5 psig ( 1.67%)

Reference values (psig):

i Condensate Transfer Pumps ,

A B  ;

Suction Pressure (P,) 12.5 8.5 Discharge Pressure (P,) 152.5 163

Licensee's justification: " Condensate Transfer Pump suction pressure varies directly with Condensate Storage Tank level. Only PI-20, for Condensate Transfer Pump B, does not meet the Code requirement for range. Pump B's suction pressure is only 5.2% of discharge pressure. A small change in the ,

suction pressure reading will have a minimal effect on pump differential pressure values used for trending pump performance. Maintenance requirements and failure predictions are based on long-term performance trends, in which any errors in suction pressure reading will tend to average out over time, so ability to analyze pump performance is not impaired."

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2.2.1.3 Emergency Service Water Suction Pressure (PI-533-1173, 1172):  !

l Range: 0-10 psig i Accuracy: 10.2 psig (12%) i Reference Values (psig): l Emergency Service Water Pumps A B C D i Suction 1 Pressure (P,) 2.4 2.5 2.5 2.5 1 Discharge l

Pressure (Po ) 157.0 165.8 148.5 149.5  ;

i Licensee's justification: "P is a small fraction of P 1.7% at most). A  !

small change in P, will have,a mininal effect on calcula(ted differential j pressure. These gauges essentially read intake water level and are used for '

purposes of other than reading ESW suction pressure. The gauges must be able to indicate at least 5.81 psig (corresponding to 8 ft. above mean sea level) in order to take appropriate procedural actions in the event of intake structure flooding. A change in range to a maximum of 7.2 psig to meet Code  !

requirements would provide minhal benefit in increased accuracy and could

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possibly interfere with use of there gauges for purposes other than In-Service Testing. Also, a change from a 0-10 psig range would necessitate use of a non-standard gauge."

2.2.1.4 Service Water Pump Suction Pressure (PI-533-1173, 1172): l Range: 0-10 psig Accuracy: 10.2 psig (i2%)

Reference values (psig):

Service Water Pumps A B Suction Pressure (P,) 2.4 2.8 j Discharge Pressure (Po ) 63/60/49 72/65/60 (see Note)

Licensee's Note: "In order to test these pumps at the i code required frequency each pump is baselined at three l flow rates 4000, 5000 and 6000 gpm, respectively.  ;

Seasonal temperatures and varying heat loads require that certain flow rates be maintained to prevent plant transients and interfacing system trips."

Licensee's justification: "P is a small fraction of P 4.9% at most). A small change in P, will have,a minimal effect on calcula(ted differential pressure. These gauges essentially read intake water level and are used for purposes other than reading Service Water suction pressure. The gauges must be able to indicate at least 5.81 psig (corresponding to 8 ft. above mean sea level) in order to take appropriate procedural actions in the event of intake structure flooding. A change in range to a maximum of 7.2 psig to meet Code requirements would provide minimal benefit in increased accuracy and could

! t possibly interfere with use of these gauges for purposes other than Inservice i*

Testing. Also, a change from a 0-10 psig range would necessitate use of a non-standard gauge."

2.2.1.5 Service Water Pump Discharge Pressure (PI-29,30):  ;

s Range: 0-160 psig l Accuracy: 12 psig ( l.25%)  ;

Reference values (psig): l Service Water Flow Rate (gpm)

Pumo 4000 5000 6000 Discharge ,

A Pressure (Po ) 63 60 49 j H Discharge Pressure (Po ) 72 65 60 i a

Licensee's justification: "The Service Water pumps require more than one '

reference value because required system flow rates are dependent upon the heat loads to be dissipated. These heat loads are based upon operating mode and environmental / seasonal changes. Any significant change in system flow rate will cause undesirable operational transients in those systems cooled by the Reactor Building Closed Cooling Water System, which is cooled by. Service Water. The expanded range of the discharge pressure gauges has provided the t necessary flexibility to accommodate testing on a quarterly basis and still  !

provide the level of accuracy required to analyze pump performance. Only one  !

reference value, Pump A at 6000 gpm, does not meet the requirement for full- i scale range of gauge (PI-29) less than or equal to three times the reference ,

value. Service Water pumps are not usually operated at 6000 gpm. They are operated in this range usually when intake water temperature rises to above r 75'F, and then the two pumps are run in parallel. The only time a single pump is run at 6000 gpm (and thus discharge pressure gauge range is too wide) is for in-service ysting. For all other reference values, the gauge range meets code requirements. It is not desirable to change one of the two gauges to ,

meet Code requirements, and changing both would be a burden for the minimal gain in accuracy."

2.2.1.6 Core Spray Main Pump Suction Pressure (PI-25, A, B, C, 0):

Range: 0-10 psig Accuracy: 10.2 psig (12%)

Reference values (psig):

Core Spray Pumps A B C D Suction Pressure (P,) 2.3 3 1.4 4.5 Discharge Pressure (Po ) 182 172 180 172 Licensee's justification: "P is a small fraction of Po (2.6% at most). A small change in P, will have a, minimal effect on calculated differential pressure. Changing the range to meet Code requirements for the lowest reference value of 1.4 psig would make the high end a maximum of 4.2 psig.

This maximum value would not accommodate the normal variation in pressure

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reading (torus water level plus any applied reference pressure) experienced for this pump from April 1987 to September 1992. Suction pressure readings have varied from 0.6 to 6.2 psig. All pumps experience similar variations in suction pressure:

Core Spray Pumps NZ01A NZ01B NZO)C NZO10 P, range 1.4- 2.5- 0.6- 1.7-4.2 4.8 6.2 5.9 P, average 2.6 3.4 2.7 3.4 A 0-10 psig gauge is most suited to accommodate this variation in readings.

Changing the range of three of these four gauges to meet Code requirements would be detrimental in one case (NZO1C), and would result in minimal gain in the other two cases."

, 2.2.2 Alternate Testing The licensee proposes to use the installed pressure gauges for all pumps in this relief request.

2.2.3 Evaluations and Conclusions '

l The licensee has requested relief from the Code full-scale range requirements i for several suction pressure gauges and one group of discharge pressure gauges used for inservice testing of pumps. ASME Secti'an XI, Paragraph IWP-4120, I

requires that the full-scale range of each instrument be three times the  !

reference value or less.

2.2.3.1 Containment Spray (CS) Pump Suction Pressure Gauges The four CS pump suction gauges exceed the full-scale range requirements of the Code. The maximum ange of the installed gauges is six times the reference value. The maximum variation in the pressure measurement with the current instrumentation is 10.6 psig (12% X 30 psig). Compared with the Code allowable maximum accuracy variance of 10.3 psig (12% X 3 X 5 psig), there is a 10.3 psig variance above the Code accuracy requirement. Since pump i differential pressure (discharge pressure minus suction pressure) is used to '

assess pump degradation, the maximum deviation between the differential pressure measured with the installed instrumentation and instrumentation meeting the Code accuracy requirements would be less than 1%.

Requiring the licensee to install instrumentation that meets the Code requirements is not justified by the difference in the information obtained.

Compliance with the Code requirements would result 1i a hardship without a compensating increase in safety because the information gained from a more accurate pressure indicator would not greatly affect the licensee's ability to assess the condition of a CS pump if it were operating in the alert or required action range. The installed CS pump suction pressure gauges provide

-g-an acceptable level of assurance of their operational readiness; therefore, based on the hardship without a compensating increase in the level of quality and safety, the alternative is authorized, pursuant to 50.55a(a)(3)(ii), as requested.  ;

2.2.3.2 Condensate Transfer (CT) Pump Suction Pressure Gauges The two CT pump suction pressure gauges have a range of -20 inches Mercury (Hg) to +30 psig. Converting inches of Hg to psi, the full-scale range of the j gauge is approximately 39.8 psi. Therefore, both pumps exceed the full-scale i range requirements of the Code. The maximum range of the installed gauges is '

4.7 times the reference value. The maximum variation in the pressure ,

measurement with the current instrumentation is 0.7 psi (fl.67% X 39.8 psi). '

Compared with the Code allowable maximum accuracy variance of 10.5 psi (i2% X  ;

3 X 8.5 psi), there is a 10.2 psi variance above the Code accuracy requirements. Since pump differential pressure is used to assess pump ,

degradation, the maximum deviation between the differential pressure measured l with the installed instrumentation and instrumentation meeting the Code accuracy requirements would be approximately 1%.

Requiring the licensee to install instrumentation that meets the Code j requirements is not justified by the difference in the information obtained. i Compliance with the Code requirements would result in a hardship without a compensating increase in safety because the information gained from a more accurate pressure indicator would not greatly affect the licensee's ability to i assess the condition of a CT pump if it were operating in the alert or required action range. The installed CT pump suction pressure gauges provide an acceptable level of assurance of their operational readiness; therefore, i based on the hardship without a compensating increase in the level of quality i and safety, the alternative is authorized, pursuant to 50.55a(a)(3)(ii), as requested.

2.2.3.3 Emergency Service Water (ESW) Suction Pressure Gauges The four ESW pump suction pressure gauges exceed the full-scale range requirements of the Code. The maximum range of the installed gauges is 4.2 times the reference value. The maximum variation in the pressure measurement with the current instrumentation is 0.2 psig (i2% X 10 psig). Compared with the Code allowable maximum accuracy variance of i0.1 psig (12% X 3 X 2.4 psi),

there is a 10.1 psig variance above the Code accuracy requirements. Since pump differential pressure is used to assess pump degradation, the maximum deviation between the differential pressure measured with the installed instrumentation and instrumentation meeting the Code accuracy requirements would be less than 1%.

Requiring the licensee to install instrumentation that meets the Code requirements is not justified by the difference in the information obtained.

Compliance with the Code requirements would result in a hardship without a compensating increase in safety because the information gained from a more accurate pressure indicator would not greatly affect the licensee's ability to

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i assess the condition of a ESW pump if it were operating in the alert or ,

required action range. The installed ESW pump suction pressure gauges provide  !

an acceptable level of assurance of their operational readiness; therefore, f based on the hardship without a compensating increase in the level of quality  !

and safety, the alternative is authorized, pursuant to 50.55a(a)(3)(ii), as requested.

2.2.3.4 Service Water (SW) Pump Suction Pressure Gauges  !

The two SW pump suction pressure gauges exceed the full-scale range (

requirements of the Code. The maximum range of the installed gauges is l

! approximately 4.2 times the reference value. The maximum variation in the l 4

pressure measurement with the current instrumentation is 0.2 psig (i2% X 10  !

psig). Compared with the Code allowable maximum accuracy variance of 10.1 i psig (i2% X 3 X 2.4 psi), there is a 0.1 psig variance above the Code accuracy l requirements. Since pump differential pressure is used to assess pump  ;

degradation, the maximum deviation between the differential pressure measured  :

with the installed instrumentation and instrumentation meeting the Code '

accuracy requirements would be less than 1%. '

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Requiring the licensee to install instrumentation that meets the Code i requirements is not justified by the difference in the information obtained.  !

Compliance with the Code requirements would result in a hardship without a i compensating increase in safety because the information gained from a more i accurate pressure indicator would not greatly affect the licensee's ability to  ;

assess the condition of a SW pump if it were operating in the alert or  !

required action range. The installed SW pump suction pressure gauges provide an acceptable level of assurance of their operational readiness; tharefore, ,

based on the hardship without = compensating increase in the level of quality and safety, the alternative is authorized, pursuant to 50.55a(a)(3)(ii), as 4

. requested. i 2.2.1.5 Service Water (SW) Pump Discharge Pressure Gauges The "A" SW pump discharge pressure gauge exceeds the full-scale range requirements of the Code when the pump is tested at a reference flow rate of i 6000 gpm. The maximum range of the installed gauge is approximately 3.3 times j the reference value. This gauge is calibrated to an accuracy of 11.25% of  ;

full scale. This results in the actual variance having a value less than the i maximum variance that would be allowed by the Code. The installed I i instrumentation provides an acceptable level of quality and safety because the I variance in the actual test results is at least as conservative as the maximum that would be allowed by the Code. Therefore, the alternative is authorized, pursuant to 50.55a(a)(3)(1), as requested.

. 2.2.1.6 Core Spray Main Pump Suction Pressure Gauges Three of the four core spray main pump suction pressure gauges exceed de full-scale range requirements of the Code. The maximum range of the N.Mlled gauges is approximately 7.1 times the reference value. Based on the accuracy of the instruments, the maximum variation in the pressure measurement with the current instrumentation is 10.2 psig (12% X 10 psig). Compared with the Code

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allowable maximum accuracy variance of 10.1 psig (12% X 3 X 1.4 psi), there is  !

a 10.1 psig variance above the Code accuracy requirement. Since pump  ;

differential pressure is used to assess pump degradation, the maximum  !

deviation between the differential pressure measured with the installed- l j instrumentation and instrumentation meeting the Code accuracy requirements t would be less than 1%.

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Requiring the licensee to install instrumentation that meets the Code  ;

requirements is not justified by the difference in the information obtained. .

l Compliance with tne Code requirements would result in a hardship without a  !

compensating increase in safety because the information gained from a more i accurate pressure indicator would not greatly affect the licensee's ability to I assess the condition of a core spray pump if it were operating in the alert or l required action range. The installed core spray pump suction pressure gauges  !

provide an acceptable level of assurance of their operational readiness; t therefore, based on the hardship without a compensating increase in the level of quality and safety, the alternative is authorized, pursuant to 50.55a (a)(3)(ii), as requested.  !

2.3 Generic Valve Relief Request 4.1 l 1

The licensee has requested relief from the increased test frequency l 3

requirements of Section XI, Paragraph IWV-3417(a), for all power operated l 4

valves in the IST program. The licensee is proposing to declare a power  !

operated valve inoperable if the limiting value of full-stroke time is  !

4 exceeded. In addition, the licensee is proposing.to use criteria almost  !

identical to the stroke time acceptance criteria contained within OM-10,  !

Paragraph 4.2.1.8, to determine the limiting value of stroke time for power  !

operated valves.

2.3.1 Licensee's basis for requesting relief

The licensee states: " Relief is requested from the increased test frequency requirements of IWV 3417(a) of Section XI. As permitted by position 5 of GL i

! 89-04, limiting value of full stroke time has been based on a valve average '

stroke time when the valve was known to be operating properly. The limiting value was then set based on a reasonable deviation from this reference time or i the requirements of the Tech. Specs or Safety Analysis, whichever is nore

restrictive. The increased test frequency requirements in the present code conflict with the method of selecting the limiting value of stroke. If a valve exceeds the limiting value it is declared inoperable. The following methodology is used when determining limiting values for stroke times

A. Electric motor-operated valves with reference stroke times greater than 15 sec. shall exhibit no more than il5% change in stroke time when compared to the reference value.

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B. Other power-operated valves with reference stroke times ,

greater than 15 sec. shall exhibit no more 125% change in  :

stroke time when compared to the reference value.

C. Electric motor-operated valves with reference stroke times less than or equal to 15 sec. shall exhibit no more than a 125% or il sec. change in stroke time, whichever is greater, when compared to the reference value.

D. Other power-operated valves with reference stroke times less than or equal to 15 sec. shall exhibit no more than 150% change in stroke time when compared to the reference value.

E. Valves that stroke in less than 2 sec. may be exempted from C and D above. In such cases, the maximum limiting stroke time shall be 2 sec. when rounded off to the nearest whole second.

Exceptions to the above methodology may be required on a case by case basis.

For some valves, process variables, such as system pressure, and/or DC bus voltage can cause normal stroke time variations that may exceed the conservative limiting values established as indicated above. Another exception to the above methodology could be when no direct position indication exists and stroke time is based upon an observed parameter change such as pressure or flow. Timing valves in this manner can result in wider variations in stroke time measurements due to the subjective nature of testing. Any exceptions to the above method of establishing limiting values of stroke time will be documented with an Engineering Evaluation to justify the methodology and limiting values used. Using the above methodology satisfies the intent of GL 89-04 and is comparable to the acceptance criteria specified in IWV-3417(a)."

2.3.3 Alternate Testing lhe licensee proposes that if a valve stroke time exceeds the limiting value it is declared inoperable.

2.3.4 Evaluation ASME Section XI, Paragraph IWV-3417(a), requires that corrective action be taken when the stroke time of a valve increases by 25% from the previous test for valves which usually stroke in greater than 10 seconds. For valves that stroke in less than 10 seconds, corrective action is required for valves which an increase in their stroke time by 50% from the previous test is observed.

If the stroke times exceed the limits given in this paragraph, the licensee is required to increase the testing to a monthly frequency until corrective action is taken. The licensee is proposing to use the criteria they have l

provided to determine the valve limiting stroke time and declare the valve '

inoperable if this stroke time is exceeded.  ;

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4 GL 89-04, Position 6, indicated that the NRC accepts measuring changes in stroke times from a reference value as opposed to measuring changes from the (

previous test value as required by IWV-3413. GL 89-04, Position 5, provided l guidance on establishing limiting values, but did not provide specific i percentages of the reference value. j In rulemaking to 10 CFR 50.55a effective September 8, 1992, the 1989 edition of ASME Section XI was incorporated in Paragraph (b) of Section 50.55a. The  !

1989 edition provides that the rules for IST of valves shall meet tha requirements set forth in OM-10. 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 and subject to Commission approval.

The methodology described by the licensee for determining limiting values for power operated valve stroke time is almost identical to OM-10, Paragraphs 4.2.1.8(a) through 4.2.1.8(e), which addresses stroke time acceptance criteria. The sole difference is the licensee's value of differentiating

! valve stroke time which is 15 seconds as opposed to 10 seconds as stated in i Paragraphs 4.2.1.8(a) through (d). Increasing this differentiating value is  ;

less conservative because power operated valves with stroke times less that or '

equal to the differentiating value have a larger tolerance before corrective 4 action must be taken. The licensee has not provided any technical  ;

justification to make this change. Therefore, the licensee should use the '

4 differentiating value specified in OH-10.

As stated above, rulemaking to 50.55a allows the use of portions of OM-10, )

provided that all related requirements are met and subject to Commission '

approval. For stroke time testing using reference values, the related I requirements of OM-10 include Paragraphs 1.3, 3.1, 3.2, 3.3, 3.4, 3.5, 3.6,  ;

4.2.1.1, 4.2.1.2, 4.2.1.3, 4.2.1.4, 4.2.1.5, 4.2.1.6, 4.2.1.7, 4.2.1.8,  !

4 4.2.1.9, 5, and 6.~ The regulations impose no limitations to OH-10 associated i 1 with the requirements for stroke time testing using reference values.

2.3.5 Conclusion The licensee's proposal to use OM-10 for stroke-time testing is approved pursuant to 50.55a(f)(4)(iv). Relief is no longer required, related to stroke-time testing using reference values, based on the rulemaking effective September 8,1992, provided the licensee implement all the stroke-time requirements in OM-10. Implementation of these requirements is subject to NRC inspection. Consequently, the value of differentiating valve stroke time should be 10 seconds as specified in OM-10, rather than 15 seconds as in the proposed alternative.

2.4 Generic Valve Relief Request 4.2 The licensee has requested relief from the testing requirements of Section XI, Paragraph IWV-3416, for valves in systems that are out of service. The 4 licensee proposes that the Oyster Creek Technical Specifications (TS) and I procedures govern operation with out-of-service valves.

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I 2.4.1 Licensee's basis for requesting relief The licensee states: " Paragraph IWV-3416 of Section XI requires that for any i systems out of service, all valves in that system shall be tested before the '

i system is returned to service."  !

The Limiting Conditions for Operation presently contained in the Oyster Creek l Technical Specifications along with the Oyster Creek Plant Procedures

adequately cover the situation of out of service valves and plant operations.  ;

2.4.2 Additional information provided by the licensee  !

J The licensee states: "0yster Creek Technical Specifications do allow for l reduced system availability to accomplish maintenance or modifications to l j safety related systems during shutdown periods. To require testing of all '

valves in that system before returning the system to a reduced system availability would conflict with the allowable provisions of the Technical Specifications. When reduced system availability is permitted by Technical  !

Specifications, testing will consist of those valves necessary to satisfy the reduced system availability as required by Technical Specifications. Prior to  ;

returning the entire system back to service, all valves in that system shall  !

be tested. Compliance with the plant Technical Specifications will provide an ,

acceptable level of quality and safety." i 2.4.3 Alternate testing The licensee proposes that the requirements contained in the Oyster Creek

Technical Specifications and Plant Procedures will govern operation regarding out of service valves.

I i 2.4.4 Evaluation

! The Code requires that all valves in systems out-of-service be tested within j 30 days prior to returning a system to operable status. The licensee is proposing that the TS requirements and plant procedures will govern the i operation of valves in systems (or portions of systems) which are out-of-service. The NRC has reviewed and approved the Oyster Creek TS as part of

, their operating license. The station TS specify the components and systems necessary to allow continued safe operation or to change plant operational modes. All systems referenced in TS have limiting conditions for operation (LCOs) which specify the length of time a system can be inoperable during a specific plant mode. If a system exceeds its LCO, then the licensee would be directed by the TS to perform additional actions.

, Requiring the licensee to test valves in a portion of a system which is not in service, where reduced availability of that system is allowed by plant TS, would be a hardship without a compensating increase in the level of quality and safety. The proposed testing provides reasonable assurance of operational  ;

readiness when the valves are required to be operational because the licensee i states that valves will be tested in the portion of the system not in service 2

prior to placing the system back into service. However, because the TS do not l l

I i

include requirements specific to returning valves to service following maintenance, the licensee must incorporate controls in their procedures to ensure that inservice testing .s performed prior to returning a valve to operable status following maintenance as required per IWV-3200.

2.4.5 Conclusion 1

The proposed alternative for TS requirements to govern the operation of valves specifically referenced in plant TS is authorized pursuant to 50.55a (a)(3)(ii) based on the determination that compliance with the specified requirements results in a hardship without a compensating increase in tie level of quality and safety, provided that for any valve which has been subjected to repair or replacement, inservice testing is performed prior to declaring the valve operable, as required per IWV-3200.

2.5 Generic Valve Relief Raquest 4.3 The licenses has requested relief from the requirement of Section XI, Paragraph IWV-3417(b), that corrective action required as a result of cold shutdown testing be performed before startup. The licensee is proposing that plant operation be governed by the requirements of the Oyster Creek Technical Specifications (TS) and Plant Procedures.

2.5.1 Licensee's basis for requesting relief  ;

The licensee states: " Paragraph IWV-3417 of Section XI requires that when corrective action is required as a result of tests made during cold shutdown, the condition shall be corrected before startup."

The Limiting Conditions for Operation presently contained in the Oyster Creek Technical Specifications, along with the Oyster Creek Plant Procedures, adequately cover all such situations.

2.5.2 Additional information provided by the licensee i

• licensee states: " Relief is requested from IWV-3417 for valves s, ecifically addressed in Technical Specifications with respect to operability and startup requirements. Compliance with the plant Technical Specifications will provide an acceptable level of quality and safety.

Relief is also requested from IWV-3417 for those cases where evaluation and analysis can demonstrate that the specific safety functions of the valve involved are either no longer required or compensatory actions have been taken to assure the safety function is preserved. This evaluation and analysis will be documented and maintained as a record of corrective action."

2.5.3 Alternate testing The licensee proposes that the requirements contained in the Oyster Creek Technical Specifications and Plant Procedures will govern plant operation in such situations.

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2.5.4 Evaluation i

OM-10 does not require inoperable cold shutdown frequency valves to be i repaired or replaced prior to plant startup. The plant TS establish the  !

m:nimum system, subsystem, and component operability requirements for safe  ;

operation, and they have been reviewed and approved by the staff. 0M-10, as well asSection XI, however, requires a test demonstrating satisfactory operation prior to returning a repaired or replaced valve to service.

Valves which are tested during cold shutdowns or refueling outages are tested at that frequency because of specific concerns which make quarterly testing during power operation impractical, as demonstrated through the submittal of relief requests or cold shutdown justifications. Should the plant restart with cold shutdown frequency valves out-of-service, the valves must be repaired or replaced and retested in accordance with the requirements of Section XI, Paragraphs IWV-3523 and IWV-3417, or the requirements of OM-10, Paragraphs 4.2.1.9(e) and 4.3.2.6, prior to entering any operational mode which requires the valves to be in service. Since testing during power operation is impractical for these valves, it may be necessary to shutdown the  :

plant in order to retest the valves. Optionally, the inoperable valve (s) may !

remain out-of-service if TS allows the plant to operate with the affected system out-of-service.

In rulemaking to 10 CFR 50.55a effective September 8, 1992,,the 1989 edition of ASME Section XI was incorporated in Paragraph (b) of Secfion 50.55a. The 1989 edition provides that the rules for IST of valves shall meet the requirements set forth in OM-10. The NRC staff impose no limitations to 0M-10 associated with requiring corrective action prior to plant startup. 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 subject to Commission approval.

, The licensee has also requested relief from the requirements of IWV-3417 for 2

valves for which it can be demonstrated that the safety function of the valve is no longer required or can be preserved with the use of " compensatory actions." Valves which no longer provide a safety function because of (1) a system modification, or (2) as a result of an engineering analysis, may be removed from the licensee's IST program in accordance with the requirements of IWV-Il00 or IWV-1200. In these cases, the licensee would be required to prepare a safety evaluation in accordance with 10 CFR 50.59.

The relief request states that the licensee will attempt to justify that the safety function of the valve is no longer required or can be preserved with the use of compensatory actions when a valve fails an inservice test. These actions represent a non-conservative approach to IST. The corrective action of IWV-3417 should be followed for valves that remain in the IST program.

However, these requirements are implemented by the licensee in accordance with the Code and relief from these requirements is inappropriate. The regulations and the Code allow the licensee to make modifications to their IST program as a result of changes in hardware or additional analysis. These changes

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typically are performed in accordance with 10 CFR 50.59, " Changes, Tests, and l Experiments." Changes that do not involve relief from, or alternatives to,  !

the Code requirements do not require NRC review and approval per 10 CFR j

l 50.55a, except as required by 10 CFR 50.55a(f)(4)(iv) for implementing later j

editions. Changes to the IST program may be submitted to the NRC on a

! periodic basis, and need not be submitted each time a change is made unless  !

) NRC review is required. However, actions to remove the function of a valve, ,

i or to take measures to isolate a non-functioning valve, require that the  !

safety significance be reviewed and ensure that measures are taken to maintain  ;

j the off-normal operation of the valves and affected systems in a safe  ;

j condition. Because the responsiblity for ensuring safety is with the  !

licensee, the NRC cannot grant generic relief to maintain valves out-of-service due to inservice test results.

' f 2.5.5 Conclusion l The relief for using the Technical Specifications to determine the operational i requirements for valves to allow plant mode changes is covered by the  ;

rulemaking, effective September 8,1992, as described above, and relief is not  :

required based on the later Code requirement; however, the implementation is ,

subject to NRC approval. The request is approved pursuant to 50.55a(f)(4)(iv), i provided that if corrective action is deferred in order to allow the plant to

startup, a retest of that valve demonstrating acceptable operation shall be l i made before the valve is returned to service, in accordance with the Code. l

) This testing should be performed prior to entering any mode of operation which .

j requires the valve to be in service, even if the plant must be shutdown in order to perform the testing. For declarations of operability based on an analysis of the stroke-time, GL 89-04, Position 5, and OM-10, Paragraph 4.2.1.9(c) allow the use of analysis as well as repair or replacement. ,

Implementation of these related requirements is subject to NRC inspection.

• i The portion of the relief request related to not using the corrective action .

requirements of IWV-3417 for valves for which it can be demonstrated that the '

i safety function is no longer required, or can be preserved with the use of 2

compensatory actions, is inappropriate for relief. The licensee is cautioned i to ensure that if valves are removed from the IST program, the regulatory  :

! requirements of 10 CFR 50.59 apply, as well as Code Sections IWV-1100 and IWV-  ;

1200. t i

2.6 Relief Request VR-ll The licensee is requesting relief from the exercise frequency requirements of Section XI, Paragraph IWV-3520, for core spray valves V-20-60, V-20-61, V ,

88, and V-20-89. These valves have a safety function in the open position to provide a secondary source of water to the reactor from the fire protection i system. In addition, these valves have a safety function to close to provide '

isolation between the core spray system and the fire protection system. The  ;

licensee is proposina to disassemble and inspect these valves in accordance  !

with GL 89-04, Position'2.

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i 2.6.1 Licensee's basis for requesting relief l The licensee states: " Initiating flow through these valves will cause ,

unacceptable water chemistry transients in the suppression pool and/or reactor vessel." i 2.6.2 Alternate testing f

The licensee proposes: "The closed position of each pair of these valves is verified quarterly by means of a leak test. These valves will be disassembled  :

and inspected to verify open ard close stroke as permitted by NRC GL 89-04, (

Position 2. Before reinstalling the valve cap, the disc is manually lifted and allowed to swing closed. Due to unacceptable water chemistry it is not  !

poss1ble to test open these valves by means of flow, After reassembly the ,

closed position is verified by a leak test. Non-intrusive techniques  ;

presently available would not be feasible since they require flow through the  :

valve. These valves form a group in that they are the same size, manufacturer j model and materials of construction and required to pass the same flow rate. 1 Two of the subject check valves are mounted vertically, flow up, while the l other two are in the horizontal. Since vertical is the more restrictive i orientation a vertical valve was the first to be opened. No adverse [

conditions were observed. Therefore, these valves will be grouped with the  ;

horizontal valves. One valve of the group will be disassembled during each  ;

refueling outg such that over four refueling outages all of the valves will  !

have been insp ned. While this is somewhat different than the GL 89-04 ,

position, it is GPUN opinion that since these valves do not see any active ,

service, and are of the same size and type, any wearing or degradation would  !

be the same for all four valves. GPUN believes there is negligible benefit to  !

safety by the disassembly of two valves each refueling outage as compared to  !

the disassembly of one valve each refueling outage." i 2.6.3 Evaluation i i

The Code requires that the valves be exercised every three months to verify I that they move to their safety position. It is impractical to exercise these valves open with flow at any plant condition because this would initiate flow of poor quality water into the reactor vessel which would adversely effect~ the ,

water chemistry of the reactor coolant. Requiring the licensee to perform '

flow testing of these check valves would be a burden because plant startup may be dM ayed in order to achieve water chemistry parameters within specified operational limits.

The licensee stated that the closure position of each pair of these core spray check valves is verified quarterly. Drawings from the FSAR of the core spray system do not show any test taps between each pair of valves that would allow the upstream valve of each pair to be closure tested individually. The licensee does not have a relief request in their IST program to test these valves in pairs. However, per GL 89-04, Position 2, the licensee's proposal to disassemble and inspect these valves, in conjunction with the. current leak testing, will satisfy the closure safety function of the check valves.

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i "he licensee has proposed to verify that these valves perform their safety i l iunctions by placing them in a single group and disassembling and inspecting l

! the valves in accordance with the guidance provided in Generic Letter 89-04, l Position 2. These valves are 6 inch swing type check valves which are '

j designed to be placed in a horizontal run of pipe. The licensee's relief  ;

j request states that two of these valves are mounted in a vertical run of pipe. J

] The inspection group proposed by the licensee does not meet the' valve I i orientation criteria of GL 89-04, Position 2, which states that valves in the l i same group must be in the same orientation. The licensee stated that one of )

j the check valves, which was oriented in a vertical pipe run, was inspected and  :

] no adverse conditions were observed. j

? l 4

Electric Power Research Institute (EPRI) Report NP-5479, " Application  ;

j Guidelines for Check Valves at Nuclear Power Plants" dated January 1988, )

Application Guideline 2.3.2 in the report discusses effects of check valve ,

{ orientation on check valve performance. Recommendations from this report i include the identification of valves in unusual orientations and a review of the operational history of these valves to identify any check valves which i

4 have poor leak tightness or require frequent maintenance. Since the vertical

valve has been inspected satisfactorily, the proposed testing provides a 4

reasonable assurance of operational readiness. The licensee should inspect a j vertically mounted check valve in this group every other refueling outage to l insure that the inspections are balanced between the four check valves. In i addition, if problems develop with the vertically mounted check valves, the j licensee should follow the recommendations given in the EPRI report. .

j 2.6.4 Conclusion

! Based on the impracticality of complying with the Code test frequency and 4

method requirements, and considering the proposed disassembly and ' inspection

! program for these check valves, relief is granted, pursuant to 50.55a(f)(6)(i)

! provided the licensee inspect a vertically mounted check valve in this group l every other refueling outage.

l 2.7 Relief Request VR-13 (Part 2)

The licensee is requesting relief from the full-stroke exercise and stroke j time measurement requirements of Section XI, Paragraph IWV-3410, for the main

, steam automatic depressurization system (ADS) valves V-01 (NR-108A), V-01 (NR-l 1088), V-01 (NR-108C), V-01 (NR-1080), and V-01 (NR-108E). These yalves

! function to provide overpressure protection to the reactor vessel and provide

a means of depressurizing the vessel. The licensee is proposing to full-d stroke exercise and stroke-time these valves at startup following a refueling i outage. 1

n i 2.7.1 Licensee's basis for requesting relief i

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The licensee states: " Exercising these valves during power operation simulates

a small-break transient, subjecting the RCS and related piping to unnecessary

transients. These valves cannot be exercised at cold shutdown because reactor j pressure is necessary to stroke the valves. No direct position indication J

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exists for these valves. However, acoustic monitors do provide an indirect means to determine position and can be used to time the stroke of these valves."

2.7.2 Alternate testing The licensee proposes: " Valves will be full-stroke exercised and stroke time j measured during startup following a refueling outage; i.e., on a refueling outage frequency."

2.7.3 Evaluation The Code requires that the ADS valves be stroke-timed every 3 months to monitor the valves for degraded conditions. These valves can only be exercised when there is sufficient reactor pressure. Exercising these valves at power is impractical because it could result in a small break loss-of-coolant accident if an ADS valve fails in the open position. .

NUREG-0626, " Generic Evaluation of Feedwater Transients and Small Break Loss-of-Coolant Accidents in GE-Designed Operating Plants and Near Term Operating License Applications," recommends reducing the number of challenges to the dual function ADS valves. Therefore, consistent with the NRC position in NUREG-0626, it is also impractical to stroke time the ADS valves at a cold shutdown frequency because this would not minimize the testing. Therefore, refueling outages, as compared to cold shutdowns, are considered a reasonable alternate frequency to exercise and stroke-time the ADS valves.

The licensee has proposed to exercise and stroke-time these valves every refueling outage using the acoustic monitors. These monitors are accelerometers which are capable of detecting flow noise. An approximate ADS  ;

valve position can be determined from the flow noise. The test would be  !

performed when the plant was in startup following a refueling outage. Direct position indication for the ADS valves, such as indication of valve disk  ;

movement, is not available at this plant. Therefore, stroke time measurements '

cannot be directly taken. To utilize the acoustic monitors downstream of these valves as an indirect method of measuring the stroke time is an acceptable alternative if a limiting value for stroke time is assigned using .

the guidance provided in GL 89-04. Position 6 provides guidance for rapid- l acting valves which have stroke times less than 2 seconds. Position 5 i provides guidance for all other power operated valves. l 1

2.7.4 Conclusion l Based on the impracticality of stroke-timing the ADS valves during power operations and cold shutdowns, and given the licensee's alternative to stroke-time these valve at refueling outages using acoustic monitors, relief is i granted, pursuant to 50.55a(f)(6)(i), provided the licensee assigns a limiting l valve for stroke time using the guidance provided in GL 89-04.

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2.8 Relief Request VR-29 i

The licensee is requesting relief from the test requirements of Section XI, j Paragraph IWV-3620, for the rupture discs in the control rod drive system.

The rupture disks provide overpressure protection to the nitrogen side of the t individual hydraulic control units. The licensee is proposing to continually 1 monitor the passive integrity of the rupture disks.  !

4 j 2.8.1 Licensee's basis for requesting relief- j The licensee states: "These rupture discs are provided to ensure the nitrogen '

side vi Use hydraulic control unit is not overpressurized during periodic charging activities. Each accumulator is charged one at a time by using a j 4

temporary conneci. ion to a charging station. The charging station is provided  :

with a regulator and a relief valve which is set at 1500 psig. Multiple I failures would be required before a rupture disc would be challenged during a charging operation. The failure of a rupture disc can only affect one control rod and will not affect overall system performance. The passive integrity of these rupture discs fulfill the safety-related function of these components.

The passive integrity is continually monitored by means of pressure switches.

Any degradation in integrity will cause an alarm condition and investigation by operators."

j 2.8.2 Alternate testing The licensee has proposed to continuously monitor the passive integrity of the rupture disks as described in their basis for requesting relief.

2.8.3 Evaluation The 1986 Edition of ASME Section XI, Paragraph IWV-3620,. requires that rupture disks shall be tested in accordance with the testing requirements of ANSI /ASME OM-1-1981 (0M-1). Paragraph 1.3.3.2 of OM-1 states that Class 1 nonreclosing pressure relief devices (which include rupture disks) shall be replaced every 5 years unless historical data indicates a requirement _ for a more frequent repl acement. The licensee's proposal suggests that rupture discs would only be replaced after a failure in the disc was detected. This represents a non-1 conservative approach to IST. The licensee has not provided adequate technical justification for relief from the Code requirements. - The licensee .

should review the Code classification of the nitrogen system per the guidance in Regulatory Guide 1.26, " Quality Group Classifications and Standards for-Water , Steam , and Radioactive-Waste-Containing Components of Nuclear Power Plants," to evaluate if these rupture discs are within the scope of 10 CFR j 50.55a. '

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2.8.4 Conclusion The relief request is denied and the licensee should continue to adhere to the requirements of OM-1 for nonreclosing pressure relief devices unless an 4 evaluation determines that these valves are not within the scope of 10 CFR 50.55a.

2 '? Relief Request VR-40 The licensee is requesting relief from the exercise frequency, stroke timing, and fail-safe testing frequency requirements of Section XI, Paragraphs IWV-3411, -3413, and -3415, for the hydrogen and oxygen monitoring system valves listed below. These valves function as containment isolation valves. The licensee has proposed exercising and fail-safe testing these valves during refueling outages. In addition, the licensee stated that these valves will not be stroke timed.

V-38-9 V-38-10 V-38-16 V-38-17 V-38-22 V-38-23 2.9.1 Licensee's Basis for requesting relief The licensee states: " Valves V-38-9,10,16,17, 22 and 23 are not configured with direct position indication nor are they configured with individual control switches for operation. Because of this configuration, it is not possible to utilize an indirect means such as flow or pressure to monitor the

position and status of the individual valves. Exercising these valves with this configuration does not allow operators to confirm that the valves have changed position. Therefore, testing in the present configuration would not provide any significant data for valve operability determination. These are original, as-built limitations, and have existed throughout the last ten-year interval. As the installed configuration does not allow testing in accordance with ASME XI, continuing relief is requested for the next ten-year interval.

l Separate from the IST limitations, modifications have been scheduled to be made to the control circuitry for four of these valves (V-38-9,10,16, and

17) during the current refueling outage. These modifications will allow individual operation of the modified valves. After modifications, a new test procedure will be implemented which has been written to confirm valve exercising, fail-safe testing, and stroke time measurement sufficiently 9

accurate to monitor valve condition and detect degradation. However, the testing methods to be used will require time to collect and evaluate data to determine effectiveness. No modifications are presently scheduled for valves V-38-22 and 23."

i 2.9.2 Alternate testing i The licensee proposes: "These valves will be exercised and the fail-safe feature tested during refueling, but, the cycle cannot be timed."

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i 2.9.3 Evaluation The Code requires that these valves be stroke timed to monitor for degrading j conditions of the valves every three months. The licensee did not provide l justification for not testing these valves on a quarterly frequency. Simply i exercising these valves as a group, while ensuring that at the time of testing l 1

the valve is able to function, does not provide information on individual valve degradation.

The licensee stated that the control circuitry for only four of the six valves will be modified in order to operate these valves individually; therefore, the requiresients of Section XI will not be meet for valves V-38-22 and 23. The current control scheme does not allow for individual operation of these valves i and does not provide position indication information. However, the proposed l alternative does not provide a method to monitor for degrading conditions, and long-term relief cannot be granted. Immediate imposition of the Code requirements would be a burden and could result in the licensee declaring all valves inoperable until Code testing could be performed. Considering that the current testing verifies the capability of the valves to function, an interim i period can be allowed for the licensee to perform the modification and develop J

procedures to test these valves in a manner that will allow for monitoring of 1 degrading conditions. In addition, if valves V-38-22 and V-38-23 are not i

j modified to stroke individually, the licensee should develop a method to monitor these two valves for degradation at least as a pair. The testing in j the interim period, while not acceptable for long-term relief, will provide ,

reasonable assurance of operational readiness.

The licensee should determine whether it is practical to exercise these valves i quarterly or during cold shutdowns. If exercising is practical either quarterly or during cold shutdowns, the testing must be performed at the appropriate frequency. If testing cannot be performed at the Code frequency, the licensee should revise this relief request to provide technical s justification for testing at refueling outages. Additionally, the licensee should review the Code classification of the hydrogen and oxygen system per the guidance in Regulatory Guide 1.26, " Quality Group Classifications and Standards for Water , Steam , and Radioactive-Waste-Containing Components of Nuclear Power Plants," to evaluate if these valves are within the scope of 10 CFR 50.55a.

2.9.4 Conclusion Interim relief for a period of one year or until the next refueling outage, which ever is longer, is granted pursuant to 50.55a(f)(6)(i) based on the impracticality of performing stroke time and fail-safe testing with the current control circuit configuration in accordance with the Code requirements, and in consideration of the burden on the licensee if the Code reauirements were imposed on the facility.  ;

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3.0 EVALUATION OF NEW RELIEF RE0 VEST 3.1 Relief Request VR-43 The licensee has requested relief from the exercise procedure requirements of l Section XI, Paragraph IWV-3412, for the liquid poison system pump discharge check valves V-19-37 and V-19-38. These valves have a safety function to open in order to allow injection of liquid poison through the check valves to the i primary system and to close to prevent diversion of flow from the operating pump to the idle pump. The licensee is proposing to verify the full-open position quarterly and to verify closure of the valves by monitoring the opposite pump's relief valve during quarterly pump testing. i 3.1.1 Licensee:s basis for requesting relief The licensee states: "The means for testing these valves in the closed direction would involve mechanical operations that could involve personal hazard due to the high pressure output of the liquid poison pumps. Reverse flow through a positive displacement pump is not a probable mode of failure and relief valve discharge and leakage is checked on a quarterly basis. These are the two possible paths should the pump discharge check valve fail in the open position. Quarterly pump testing and relief valve leakage testing would detect any excessive backflow and cause the operating pump to fail its acceptance criteria. If this condition were to occur, the involved components would be repaired or replaced."

3.1.2 Alternate testing The licensee proposes to monitor relief valve leakage of the opposite pump during pump testing quarterly to verify that the closure function of the check valves is satisfied.

3.1.3 Evaluation l The Code requires that the valves be exercised to their safety position in l order to verify the functiod ng of the valve. The safety function of these )

valves in the closed direction is to prevent diversion of flow into the idle j train of the system from the running pump. These pumps are arranged in parallel and, therefore, running one pump and monitoring the relief valve for leakage through the pump discharge check valve on the opposite pump may demonstrate the closure of the discharge check valve, depending on the setpoint of the relief valve. Leakage past the check valve will not cause the positive displacement pumps to rotate backwards (due to the design), as could  ;

occur in a centrifugal pump. Therefore, there is not a means to identify I leakage into the pump by observing rotation of an impeller. On the other hand, the design of the positive displacement pumps is such that when a pump is not running, it acts much like a closed valve and prohibits any backflow.

Because the pumps are designed such that they will not be damaged by backflow, the main reason the discharge check valves need to close is to prevent gross i

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i i j leakage that could cause lifting of the relief valves. Therefore, i i ve-ification of closure by ensuring there is no gross leakage provides a 2

measure of safety that the check valves are not leaking.

Imposition of the Code requirements would be an undue hardship in that the verification of closure of the discharge check valves creates a personnel  ;

safety hazard concern. As discussed above, the proposed alternative provides i a a measure of safety and the imposition of the Code requirements would not l i provide a significant increase in the level of quality and safety that is  !

sufficient to offset the hardship. l i I.1.4 Cenclusion l i lhe prepcced alternative to monitor relief valve leakage testing quarterly to i 3

verify that the closure function of the check valves is authorized pursuant to i 50.55a(a)(3)(ii) based on the hardship that results from the imposition of the l Code requirements without an increase in the level of. quality and safety. The  !

alternative provides a measure of safety adequate to verify closure on a j periodic basis without creating a personnel hazard concern.

4.0 CONCLUSION

1 t l In evaluating the licensee's requests for relief from the requirements of i Section XI, the staff considered (1) the acceptability of proposed alternative testing, (2) whether the hardship of compliance is without a compensating i increase in safety, (3) the impracticality of performing the required testing i considering the burden if the requirements were imposed, and (4) whether the l proposed alternative testing meets the requirements set forth in subsequent

~

i editions and addenda that are incorporated by reference in 50.55a(b). The

, last column of Table 1 identifies the regulation or GL 89-04 guidance under which the requested relief is approved.

The staff has determined that granting relief or appro..ag alternatives

. pursuant to 50.55a(a)(3)(1), 50.55a(a)(3), 50.55a(f)(4)(iv), and 50.55a(f)(6)(i), provides an acceptable level of quality and safety. The relief is authorized by law and will not endanger life, property, or the

common defense and security, and is otherwise in the public interest. The i relief has been granted giving due consideration to the burden on GPUN that could result if the requirements were imposed.on the facility. The granting  ;

I 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. L Principal Contributor

Joseph Colaccino i

Date:

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Table 1 l GPU Nuclear Corporation l Oyster Creek N!iclear Generating Station NRC 5e %ty Evaluation Docket Number 50-219 Item  ! Description of Action Item in NRC SE Deted GPU Nucteer Actions as Described in the Action item wwber " September 24, 1992 Deccaber 23, 1992, IST Program Stemittet. Status-l (Relief Request)

Item 1 The Licensee requested relief from the vibration The licensee provi&d additionet information Approved (PR-3) emptitude measurement requirements of Section XI for ett addressing their current vibration testing and (f)(4)(Iv) with ptmps in their IST program. Relief was granted to justification for not meeting the requirements of provision measure vibration velocity in lieu of displacement OM-6.

provided this testing is performed in accordance with See section 2.1 ANSI /ASME OMe-1988. Part 6 (OM 6), or a toter version of of SE the ASME OM Code. No justification was provided by the Licensee to use vibration testing or acceptance criteria other then the requirements specified in OM-6.

1 Item 2 The Licensee requested retlef from the instrument range The licensee revised Relief Request FR 4 including Atternate (PR 4) requirements of Section XI for severet suction and specific information on the instrumentation for authorized for discharge pressure geges used with ptsps in their IST which relief was req;ested by grotps of effected containment program. The licensee did not provide specific ptmps, sprey, condensate

. Information on each instrument in which relief was transfer, regsested. Interim relief was granted for the licensee emergency service to either instalt instrumentation that meets the Code water, service requirements or provide justification for using the water, and core instelled instrumentation. sprey ptsp

, suction pressure 1

gauges (e)(3)(li)

Alternate i euthorized for 1 service water ptsp discharge pressure gauges (e)(3)(1)

See section 2.2 of SE I l i

Itess . Description of Action item in NRC SE Dated GPU Nuclear Actions s1 Det cribed in the Action Item Ntsuber September 24, 1992 Decenber 23, 1992, IST Program Stkmittet Status '

. (Retlef Request)

Item 3 The Licensee requested relief from the increased test the licecsee has provided a*fitional information Approved (GYR-4.1) frequency requirements of Section XI, Paragraph IW- detailing their proposed in:reased test requirements (f)(4)(iv) with 3417(e), for ett power operated vetves (POV) in their for POVs. provisions IST program. The licensee proposed to declare e POV inoperable when the volve exceeded a limiting value of See section 2.3 futt stroke time. The licensee based their request for of SE relief by stating that the Code requirement conflicts with the method of selecting the limiting value of futt stroke time specified in Generic Letter (GL) 89-04.

However, the licensee did not demonstrate that the Code increased test frequency requirements interfered with the GL 89-04 method for selecting the limiting value of full-stroke time. Therefore, the relief request was denied.

Item 4 The licensee requested relief from the testing The licensee has provided etk11 tion 21 information in Alternate (GVR-4.2) requirements of Section XI for valves in systems that en effort to support their basis for requesting authorized are out of service. The licensee proposed that testing retlef. (e)(3)(li), with for these valves be performed in accordence with Oyster provisions Creek Technical Specifications (TS) and procedures.

However, the licensee did not demonstrate the burden or See Section 2.4 impracticality of complying with this Code requirement. of SE Therefore, the relief request was denied.

j Item 5 The licensee requested relief from the Section x1 The licensee provided additionet information which Approved (GVR-4.3) requirement that corrective action required as a result modified Relief Request GVR 4.3 to request retlef (f)(4)(iv) of cold shutdown testing be performed before startup, from the requirements of IW-3417 for valves that The licensee stated that plant TS should govern plant were specificatty addressed in TS. See Section 2.5 ,

operation. Relief was granted provided the plant TS of SE specificelty eddress the vrtve or its associated system e The licensee proposed en additional clause in Relief and permit plant starttp when the valve is inoperable. Request GVR-4.3 to include cases where eyetuation and analysis can demonstrate that the specific safety functions of the valve involved are either no longer required or compensatory actions have been i

taken to assure the safety function is preserved.

t I

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-Item . Description of Action item in NRC SE Dated GPU Nucteer Actions as Described in the ' Action item-ptember , September 24,;1992 December 23, 1992,' Ist Proprom submittot . status 9

(Retief' Request)

Item 6 The Licensee requested relief from the Leak rate testing The licensee withdrew Retie 8 Requests VR-3A and VR- No further NRC (VR-34 and differentist test pressure requirements of Section XI 15A and will conduct tenkest testing of these valves action is E

VR 15A) for check valves V-16 62, V-2 71, and V 2-72. The using a tower differential pressure. required.

ticensee is proposing to perform teskoge testing with a differential pressure less then the functional differentist pressure. IW-3423(e) permits teskoge testing of vetves at a lower differential pressure then  ;

the functionet differentist pressure for volves in which i higher differentlet pressures tends to diminish the y'

teekoge rete by pressing the disk on the seat with greater force. Therefore, relief was not required to perform the proposed testing.

Item 7 The licensee requested relief from the pressure relief The licensee revised Relief Request vt-29 and Relief denied (VR-29) . device testing requirements of Section XI for the MCU submitted it for evaluatim.

serem occtmulator nitrogen charging line rupture disks. See Section 2.8 '

The licensee stated that these rteture disks are outside of SE the scope of the Code. Relief is not regstred if the rteture disks do not serve a safety function as defined by OM-1-1981.

Item 8 The licensee requested relief from the check vetve The licensee revised Relief Request VR-11 to include Relief granted (VR-11) exercise frequency and test method requirements of additionet justification for not partiet-stroke (f)(6)(1) with Section XI for check valves V-20 60, v-20-61, V-20-88, exercising the check velves after reassenbty and for provision and V-20-89. . The licensee proposed to verify the futt- grotping ett four volves into one group.

stroke capability of these vetves to the open and closed See section 2.6

> position by placing these volves in a group and of SE disassembling and inspecting one volve from the group

- each refueling outage. The licensee's vetve group did not conforie with the guldence provided in GL 89-04,

{

Position 2. Interim relief was granted to attow the Licensee to develop a method to pert-stroke exercise

- these volves efter reassembly. In addition, the vetves j should be grotged in accordance with the guidance given 1 in GL 89-04, Position 2.

l 4

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Item Description of Action Item in NRC &S Dated GPU Nuclear Actions as Descrited in the Action Item Ntsuber . September 24, 1992 December 23, 1992, IST Program Se mittal Status (Retief Reg >est)

Item 9 The licensee regsested relief from the exercising The licensee revised Relief Requests VR-37, VR-42, The licensee has (VR-37, frequency and method requirements of Section XI for and VR-45 to state that the velves would be partial addressed the VR-42, and check valves V-20-52, V-20-53, V-20-54, v-20-M, V 20-8, flow tested af ter reassenbly during refueling concerne of the VR-45) v-20-9, V-20-16, V-20-22, v 20-50, and V-20 51. the outage. In addition, the relief requests stated action item. No licensee proposed to part-stroke exercise these check that the use of non-intrusive diagnostic techniques further NRC valves quarterly and semple disassenble and inspect will actively be pursued. ection is these volves each refueling outage. Relief was granted required.

provided the Licensee perform a partial flow test of the reassenbled wolves prior to their return to service. In addition, the licensee was advised to actively pursue the use of non-intrusive test methods to demonstrate that the volves swing fully open during partial flow testing.

Item 10 The licensee requested relief from the leak rate testing The licensee withdrew relief reo;est VR-12A. The No further NRC (VR-12A) requirements of Section XI for check velves V-31-2 and Licensee stated that relief was granted by GL 89-04, action is V-31-5. It was smeteer from this relief request why the Position 10. required. The licensee was requesting relief from the teak rete licensee should testing recpJirements for these valves. For the indicate in their containment isolation function, relief is already IST program that granted by GL 89-04 to use Appendix J, Type C, with IW- relief is granted 3426 and I W -3427(a), which is a low pressure teek test, to perform teak Insufficient information was provided to justify not rate testing by verifying a pressure isolation function if this testing GL 89-04 for is required. Therefore, the retlef request was denied. these valves.

It.m 11 The licensee regaested retlef from the exercise The licensee provided additionet information for Relief granted (VR 13 frequency and stroke time measure requirements of Relief Request VR-40. (f)(6)(1) with Port 2) Section Mi for the main steen safety /retief valves. The provfslon Licensee proposed to full stroke exercise these valves from startup frce refueling outages without conducting e See Section 2.7 stroke time test. The licensee proposed no method to of SE monitor these valves for degradation which is (necceptable. Relief was granted provided the licensee develop some method to monitor these valves for degradetlon.

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Item Description of Action Item in WRC SE Dated GPU Nuclear Actions as Described in the Action Item Ntaber September 24, 1992 Decenber 23, 1992, IST Program Submittet Status (Relief Request)

Item 12 The Licensee requested relief from the check valve The licensee revised Relief Request VR 14 to The licensee has (VR-14) exercising frequency requirements of Section x1 for the describe the exercise test method and the extent of addressed the vacuum breaker check valves V-1 190, v 1-191, V-1-192, disassenbly. concerns of the and V-1-193, on the electromatic relief valve discharge action item. No lines. The Licensee proposed to partially disassenble further NRC ard mechanicetty exercise these valves during refueling action is outages when the drywett is deinerted. The Licensee did required.

not indicate the degree of disassembly that would be performed and if their would be any post essembly testing. Relief was granted provided the licensee more clearly describe the extent of disassenbty to be performed.

Item 13 The licensee requested retlef from the exercise The Licensee provided additional information to Interim relief (VR-40) frequency, stroke timing, and fall-safe testing justify the current testing. granted for requirements of Section for the contelrunent isolation testing method valves V-38-9, V-38-1, V 38-16, V-38-17, V-38-22, and (f)(6)(1)

V 38-23. The licensee proposed to exercise end fall safe these velves every refueling outage without See Section 2.9 conducting a stroke time test. The licensee's proposed , of SE etternative provides no measure of valve degradation.  !

Therefore, this relief request was denied.

Item 14 The licensee requested relief from the exercicing The Licensee withdrew Relief Request VR-41. The Licensee has (VR-41) frequency, stroke timing, and fall-safe testing Modifications are presently scheduled for the addressed the frequency regJirements osSection XI for containment current refueling outage which will remove these concerns of the isolation vetves V-38-93 and V-38-94. These velves are valves. ection item. No solenoid vetves d ich currently are not connected to any further NRC power source and the Licensee proposed not to test these action is valves. With the power supply disconnected, these required.

valves are Category A passive valves and Tebte IW-3700-

, 1 indicates there are not exercising, stroke timing, and

! fail-safe testing requirements for these vetves. Relief 2

is not required provided these valves do not become active.

d

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Item Description of Action Item in NRC SE Dated GPU Nuclear Actions as Described in the Action item utster Septeater 24, 1992 Decenber 23, 1992, IST Program StAnittal Status (Retief Request)

Item 15 The licensee requested relief from the valve stroke The licensee withdrew Relief Request VR 46. The The licensee's (VR-46 timing requirements of Section XI for the contairment licensee stated that test procedures were developed actions address Parts 1 isolation valves V-24-29, V-24-30, and V-23-70. The to obtain stroke times based upon observed changes the concern. The and 2) Licensee proposed to exercise these valves quarterly in system pressure and flow. According to the testing of these without measuring the valve stroke time. Relief was licensee, stroke timing han been performed with velves is sthject granted to allow the Licensee to develop a testing successful results. The Licensee claims that this to NRC inspection method that would adequately monitor valve degr d tion. method of stroke tiring is sufficiently accurate to monitor valve condition and detect degradation.

Item 16 The licensee requested relief from the exercise The licensee is withdrawing retlef request VR-48. No further NRC (VR-48) frequency requirements of check valves V-11-3 and V-11-7 The licensee stated that a note will be added to the action is to the closed position. The Licensee proposes not to Apoendin B, Table 1, Valve Test Requirements, of required.

test these valves in the closed position because they their IST program. The note will indicate that have no safety function to close. If these valves have normal pu m operation confirms the open position of no safety function in the closed position, then they are these valves on a daily basis during ptmp operation.

not required to be in the licensee's IST program.

Item 17 The IST program does not include a description of how The licensee did not respord to this action item. The Licensee the components were selected and how testing should include a requirements were identified for each conponent. The response to this review performed for the SE of Septenter 24, 1992, did action item in not include verification that att ptmps and valves their next IST within the scope of 10 CFR 50.55a and Section XI are program contained in the licensee's IST program, and did not sthmi t t et .

ensure that all applicable testing requirements have been identified. Therefore, the Licensee was requested to include this information in the IST program. The program should describe the development process, such as a listing of the documents used, the method of determining the selection of conponents, the basis for the testing required, the basis for categorizing valves, and the method or process used for maintaining the program current with design modifications of other activities performed under 10 CFR 50.59.

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