ML20058N802

Safety Evaluation Approving Third 10-yr IST Program Requests for Pumps & Valves,Per 10CFR50.55a(f)(6)(i) & 10CFR50.55a(a)(3)(i)

ML20058N802
Person / Time
Site:	Prairie Island
Issue date:	12/08/1993
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20058N786	List: ML20058N783 ML20058N802 ML20058N809
References
GL-89-04, GL-89-4, NUDOCS 9312220266
Download: ML20058N802 (5)

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- UNITED STATES j

,j NUCLEAR REGULATORY COMMISSION E

t "VASHINGToN, D.C. 205EH001

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SAFETY EVALVATIOL BY THE OFFICE OF NUCLEAR REACTOR REGULATION l

RELATED TO THE INSESVICE TESTING PROGRAM REOUESTS FOR RELIEF _

NORTHERN STATES POWER COMPANY l

PRAIRIE ISLAND NUCLEAR GENERATING PLANT. UNITS 1 AND 2 1

DOCKET NUMBERS 50-282 AND 50-306

1.0 INTRODUCTION

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-t The Code of Federal Regulations,10 CFR 50.55a, requires that inservice testing (IST) of certain ASME Code Class 1, 2, and 3 pumps and valves be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable addenda, except where alternatives have been authorized or l

relief has been requested by the licensee and granted by the Commission j

pursuant to Sections (a)(3)(1), (a)(3)(ii), or (f)(6)(1) of 10 CFR 50.55a.

In' proposing alternatives or requesting relief, the licensee must demonstrate that:

(1) the proposed alternatives provide an acceptable level: of. quality and safety; (2) compliance would result in hardship or unusual difficulty l

without a compensating increase in the level of quality and safety; or.(3).

conformance is impractical for its facility. NRC guidance contained in Generic Letter (GL) 89-04, Guidance on Developing Acceptable Inservice Testing Programs, provides alternatives to the Code requirements determined acceptable to the staff.

Section 10 CFR 50.55a authorizes the Commission to approve alternatives and to

~i grant relief from ASME Code requirements upon making the necessary findings.

The NRC staff's findings with respect to authorizing alternatives and granting or not granting the relief requested as part of the licensee's IST program are contained in this Safety Evaluation (SE).

_j 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 10 CFR 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 i

Maintenance Standards Part 6 (OM-6), " Inservice Testing of Pumps in Light-Water Reactor Power Plants," and Part 10~(OM-10), " Inservice Testing of Valves in Light-Water Reactor Power Plants." The staff has determined that it is acceptable for a licensee to use OM-6 and OM-10 in developing the IST program.

Because the program was developed using the 1989 Edition of the ASME Code, the relief requests in the Prairie Island Nuclear Generating Plant IST program j

have been reviewed against the requirements of OM-6 and OM-10.

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. 2.0 INSERVICE TEST PROGRAM INTERVAL The IST program evaluated in this SE covers the third 10-year IST interval for the Prairie Island Nuclear Generating Plant, Units 1 and 2.

The interval for Unit I begins December 16, 1993, and for Unit 2 begins December 21, 1994.

Based on the licensee's intent to maintain the two units on the same editior.

of the Code, implementation of the revised program may begin for Unit 2 at the same time as Unit 1.

The staff has determined that 10 CFR 50.55a(f)(4)(iv) allows a licensee to update its IST program prior to the beginning of a 10-year interval, provided another edition of the Code would not be required per 10 CFR 50.55a(f)(4)(ii). For an interval start date of December 21, 1994 (Unit 2), the 1989 Edition of the Code would be the edition incorporated in 10 CFR 50.55a(b) 12 months prior to the interval start date. Therefore, it is acceptable for Northern States Power to use the 1989 Edition of the ASME Code for the third 10-year intervals of the Prairie Island Nuclear Generating Plant.

3.0 EVALUATION The NRC staff, with technical assistance from Brookhaven National Laboratory (BNL), has reviewed the information concerning IST program requests for relief submitted for Prairie Island Nuclear Generating Plant, Units 1 and 2, in Northern States Power Company's letters dated June 16, 1993, and August 25, 1993. The staff adopts the evaluations and recommendations for granting relief or authorizing alternatives contained in the attached Technical Evaluation Report (TER), prepared by BNL. Table I lists each relief request and the status of approval.

The test deferrals of valves, as allowed by OM-10, were reviewed. Results of the review are provided in Table 4.1 of the TER with recommendations for further review by the licensee for certain of the deferrals. Actions taken on these recommendations are subject to NRC inspection.

For the Prairie Island Nuclear Generating Plant IST Program, relief is granted from, or alternatives are authorized to, the testing requirements which have been determined to be impractical to perform or where compliance would result in a hardship without a compensating increase in safety.

Interim approval is authorized for Relief Requests 1 and 2 for a period of 1 year or until the next refueling outage of each unit, whichever is later. The portion of Relief Request 5 related to use of alternate acceptance criteria is denied.

Authorization of Relief Request 10 ie acceptable until the next refueling outage for each unit when the licen",ee has committed to install flow instrumentation.

The IST program relief requests dich are granted or authorized are acceptable for implementation provideo Lie action items identified in Section 5 of the TER are addressed within 1 year of the date of the SE or by the end of the next refueling outage. whichever is later. Additionally, the granting of relief is based upon the fulfillment of any commitments made by the licensee in its basis for each relief request and the alternatives proposed.

SE Table 1 - Summary of Relief Requests Prairie Island Nuclear Generating Plant, Units 1 and 2 Relief TER Section XI Requirement Equipenent Proposed Attemete NRC Action Request No.

Sectkm Identification Method of Testing 1

2.1.1 OM Part 6, Table 3, Vibration etert Unit 1 and 2 Safety Use Code sfert limitr. un!ees e Alternets authorized in limits.

Injection. Conteinment vabe becomes > 0.325 in/sec, in accordance with 10 CFR Sprey, Component vrbich case, use Vr + 0.2 in/sec.

60.E6e (e)(3)(ii), for en interim Cooling. Diesel Driven period.

Cooling Water Pun ps 2

2.2.3 OM Part 6 Peregraph 4.6.1.1 and Unit I and 2 Component Ues presently installed Attemete authorized in Table 1 flow instrumentation Cooling Water Pumps instrumentation that in occurate eccordance with 10 CFR eccur acy.

within,1,3 %.

60.66e (e)(3)(li), for en interim period.

3 3.1 OM Part 10, Peregraph 4.1, local Unit 1 and 2 Use system cherectoristice, leek Authorized in accordance with verification of remote position Containment Sump testing et refuefing, and visual 10 CFR 60.66e (e)(3)(li).

Indiention.

Isolation Velves, MV-observation, when velve 32076,32178.end enclosures are removed, to verify 32179.

position indication.

4 2.1.2 OM Part 6, Peregraph 4.6.4(b),

Unit 1 and 2 Diesel Use attemative locatione.

Relief granted in accordance vibration measurement location.

Driven Coolino Water, with 10 CFR 60.66e (f)(6)(i).

Motor Driven Coorm0 Water, RHR Pumps 1

Resef TER

- Section XI R

,2_..;-a -

Equipment Pmposed Altamete

_NRC Action Request No.

Section identification Method of Testing 6

' 2.2.1 '

OM Part 6. Peteroph 5.2(b) and Unit 1 Diesel Driven Use pump curve end etternate-Relief to use pump curves Table 3b, Use of singh reference Cooling Water, Motor differential pressure acceptance granted in occordence with to point and differential preseure Driven Cooling Water criterie.

CTR 50.56e (f)tBiti). Relief to acceptance criterie.

Pumps use efternete acceptence criterie denied.

10 2.2.2 OM Port 6, Perspeph 5.2, Unit 1 Containment Test quarterly, until the next

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i Afternative authorized in Mesourement of flowrote quarterly.

Spray Pumps refueling outage, without the accordance with 10 CFR measurement of flowrote.

50.66e (e)(3)(W). until next refuelmg outage when flow instrumentation will be instelled.

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NOTE: Relief Requeste 6 - 9 not used.

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- Program changes involving new or revised relief requests should not be implemented prior to approval by the NRC except as authorized by GL 89-04.

New or revised relief requests that meet the positions in GL 89-04,, should be submitted to the NRC but may be implemented provided the guidance in GL 89-04, Section D, is followed.

Program changes that add or delete components from the IST program should also be periodically provided to the NRC.

4.0 CONCLUSION

The licensee's IST program requests for relief from the requirements of Section XI have been reviewed by the staff with the assistance of its contractor, BNL. The TER is BNL's evaluation of the licensee's IST program relief requests. The staff has reviewed the TER and concurs with the evaluations and recommendations for granting relief or authorizing alternatives. A summary of the relief request determinations is presented in Table 1.

The authorizing of alternatives or granting of relief is based upon the fulfillment of any commitments made by the licensee in its basis for each relief request and the alternatives proposed. The implementation of IST program is subject to inspection by NRC.

The licensee should refer to the TER, Section 5, for a discussion of IST program anomalies identified during the review. The licensee should resolve all items in accordance with the guidance therein. The IST program relief requests are acceptable for implementation provided the action items identified in Section 5 of the TER are addressed within I year of the date of this SE or by the end of the next refueling outage, whichever is later. The licensee should respond to the NRC within 1 year of the date of this SE describing actions taken, actions in progress, or actions to be taken, to address each of these items.

The staff concludes that the relief requests as evaluated and inodified by this SE will provide reasonable assurance of the operational readiness of the pumps and valves to perform their safety-related functions. The staff has determined that granting relief pursuant to 10 CFR 50.55a(f)(6)(i) and authorizing alternatives pursuant to 10 CFR 50.55a(a)(3)(1) is authorized by law and will not endanger life or property, or the common defense and security and is otherwise in the public interest.

In making this determination, the staff has considered the impracticality of performing the required testing and the burden on the licensee if the requirements were imposed.

Principal Contributor:

P. Campbell, EMEB Date:

Dece ter 8,1993