ML20059L917

Forwards Safety Evaluation Granting Relief from Testing Requirements for Second 10-yr Interval Inservice Testing. Inservice Testing Program Acceptable Provided Omissions & Inconsistencies Noted in App C Addressed within 6 Months

ML20059L917
Person / Time
Site:	Calvert Cliffs
Issue date:	09/20/1990
From:	Capra R Office of Nuclear Reactor Regulation
To:	Creel G BALTIMORE GAS & ELECTRIC CO.
Shared Package
ML20059L920	List: ML20059L917 ML20059L921
References
GL-89-04, GL-89-4, NUDOCS 9010020169
Download: ML20059L917 (3)

Text

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' y[,y UNITED STATES l

NUCLEAR REGULATORY COMMISSION Le WA SHINGTON, D. C, 20666

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September 20, 1990 Docket Nos. 50-317 I

and 150-318 l

Mr. G.-C. Creel Vice President - Nuclear Energy Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant 1

MD Rts 2 & 4 l

l P. 0. Box 1535 Lusby, Maryland 20657 1

SUBJECT:

SECOND TEN-YEAR INTERVAL INSERVICE TESTING PROGRAM - CALVERT CLIFFS.

NUCLEARPOWERPLANT, UNITS 1AND2,TACNOS.64976(UNIT 1)

AND 64977 (UNIT 2)-

By letter dated October 18, 1988, BaltimoreGasandElectricCompany(BG&E) l submitted its proposed Inservice Testing (IST) Program for the second ten-year l

, cycle ~ of operation for the Calvert Cliffs Nuclear Power Plant, Units 1 and 2.

Additional information for several relief requests for both units was submitted by letters dated October 14, 1988, November 13, 1989, February 15, 1990,Jand February 16,-1990. The second ten-year interval covers the period from April 1,1987 to April 1,1997.

The:Calvert Cliffs, Units 1 and 2, second ten-year IST program submittal, as L

amended, was evaluated for compliance with the Code of Federal Regulations, paragraph 10CFR50.55a(g),whichrequirescertainClass1,2,and3pumpsand I'

-valves-in' water-cooled nuclear reactor facilities to meet the inservice L-testin (ASME)g requirements stated in the American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI. Specifically, compliance o

with the requirements.of Subsection IWP, Inservice Testing of Pumps in Nuclear.

l Power Plants' and Subsection IWV,-Inservice Testing of Valves in Nuclear Power Plants were evaluated.. Each facility is required to establish a program _for theiinservice testing of pumps and valves which is updated every ten years to i

meet'the requirements in the latest approved edition and addenda to Section XI of the.ASME Code.

l The ' staff, with technical assistance from Idaho National Engineering Laboratory, EG&G ' Idaho, Inc. (EG8G) has reviewed and evaluated the revised IST program and additional changes-provided by BG8E letters, including the requests for relief from those requirements-that BG8E determined to be impractical to perform at the Calvert Cliffs Power Plant, Units 1 and 2.

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r h;4 Mr. G. C. Creel I The staff adopts the evaluations and conclusions contained in the Technical-EvaluationReport(TER)preparedby(EG8G. The enclosed Safety Evaluation (SE)

(Enclosure 1)-incorporates the TER Enclosure 2) and its findings. We are granting relief from the testing requirements which we have determined would be impractical to perform or would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety and where the proposed alternative testing provides an acceptable level of quality and

-safety.

A summary of.the ser and valve relief request determinations is presented in Table 1 of the: encMed SE. A suninary of these requirements and the basis for granting the relief requests are also contained in the SE. The staff has i

detemined, pursuant to 10 CFR 50.55(a)(3)(1), (a)(3)(ii), and (g)(6)(1), that the granting of these reliefs 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 given due consideration to the alternative testing being implemented; whether compliance with the j

specified requirement would result in a hardship or unusual difficulty without a compensating increase in safety, and the impracticality of performing the required testing considering the burden if the requirements were imposed on this facility. Accordingly, the staff concludes that the IST program is.

-acceptable for implementation provided the omissions and inconsistencies 1

identified in the SE and the Appendix C of the TER are addressed within six months of the receipt of this letter.

BG&E is required to comply with the IST program, as defined in the above references including BG&E submittals and in accordance with the reliefs i

granted in the enclosed SE.

Program changes, such as additional relief requests or changes to relief requests, should be submitted for staff review but should not be implemented prior to review and approval by the NRC.

However, new or revised relief requests meeting the positions in Generic Letter 89-04, Attachment 1, can be implemented provided the guidance.in Generic Letter 89-04, Section~D, is followed.

Program changes that involve additions or deletions of components from the IST program should be provided to the staff for review and should not be implemented prior to review and approval by the NRC.

This completes our action relative to the referenced TAC numbers.

Sincerely, ORIGINAL $1GNED BY

~

Robert A. Capra, Director Project Directorate I-I Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation

Enclosures:

Distribution:

1.

Safety Evaluation 4 Docket 111ew NRC/ Local PDRs OGC 2.

Technical Evaluation Report PDI-1 Rdg SVarga EJordan RWessman RACapra ACRS(10) cc w/ enclosures:

CVogan DMcDonald JLinville

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RACapra Ec ona rsc

%'L o CQ R 9/7/9 91uho DOCUMENT.NAME: Ltr to. Creel..Taci6.4976/64977

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h Mr.

G'. C. Creel The staff adopts the evaluations and conclusions contained in the Techr.t al p'

-Evaluation Report (TER) prepared by(Enclosure 2) and its finding,.Thee EG&G.

(Enclosure 1) incorporates the TER We are granting relief from the testing requirements which we have determined would be impractical' to. perform or would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety and where the. proposed alternative testing provides an acceptable level of quality-and safety.

A summary of the pump and valve relief request determinations is presented in Table 1 of the enclosed SE. A sumary of these requirements and the basis-for-

-granting the relief requests are also-contained in the SE.

The staff has detemined, pursuant to 10 CFR 50.55(a)(3)(i), (a)(3)(ii), and (g)(6)(i), that the granting of these reliefs 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 detemination the staff has given due consideration j

to the alternative testing being implemented; whether compliance with the

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specified requirement would result in a hardship or unusual difficulty without a compensating increase in safety, and the impracticality of perfoming the required testing considering the burden if the requirements were imposed on -

this facility. Accordingly, the staff concludes that the IST program is acceptable for implementation provided the omissions and inconsistencies identified in the SE and the Appendix C of the TER are addressed within six months of the receipt of this letter.

BG&E,is required to comply with the IST program, as defined in the above references including BG&E submittals and in accordance with the reliefs

. granted in the enclosed SE.

Program changes, such as additional relief requests or changes to relief requests, should be submitted for staff review but should not be implemented prior to review and approval by the NRC.

However, new or revised relief requests meeting the positions in Generic Letter 89-04, Attachment 1, can be implemented provided the guidance in Generic ij letter 89-04, Section D, is followed.

a, Program changes-that involve additions 1

or deletions of components from the IST program should be provided to the staff for review and should not be implemented prior to review and approval by the NRC.

i This completes our action relative to the referenced TAC numbers.

Sincerely, i

7 h a_..C w Robert A. Capra. Director Project Directorate I Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation

Enclosures:

1.

Safety Evaluation 2.

Technical Evaluation Report ec w/ enclosures:

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