ML20059L921

Safety Evaluation Re Inservice Testing Program & Requests for Relief from Requirements Deemed Impractical to Perform at Facilities

ML20059L921
Person / Time
Site:	Calvert Cliffs
Issue date:	09/20/1990
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20059L920	List: ML20059L917 ML20059L921
References
GL-89-04, GL-89-4, NUDOCS 9010020171
Download: ML20059L921 (9)

Text

.

.. _. ~ _

,.i.

t V

L a

I,,, esa t

7 o

UNITED STATES I

[

S-q ^,I

. NUCLEAR REGULATORY COMMISSION

-J-WASHf fv0 TON, Dl C. 205%

' \\ *1 [

+

...+

ENCLOSURE 1 4

SAFETY EVA'LUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE INSERVICE TESTING PROGRAM AND REQUESTS FOR RELIEF BALTIMORE GAS AND ELECTRIC COMPANY CALVERT CLIFFS NUCLEAR POWER PLANT. UNITS 1 AND 2-

[

DOCKET NOS. 50-317 AND 50-318 x

INTRODUCTION The Code of Federal Regulations, 10 CFR 50.55a(g) requires that inservice l

testing (IST) of American Society of Mechanical Engineers (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 specific written relief has been req)uested by the licensee and granted by the Connission pursuant to 10 CFR 50.55(a (3)(1), (a)(3)(ii), or (g)(6)(1).

In 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 without a compensating increase in the level of quality or safety; or (3) the conformance with certain requirements of the applicable Code edition and addenda is impractical for its facility.

TheRegulations,10CFR50.55a(a)(3)(1),(a)(3)(ii),and(g)(6)(1), authorize the Commission to grant relief from these requirements upon making the necessary findings. The NRC staff's findings with respect to granting or not granting' the relief, requested as part of'the Baltimore Gas and Electric Company's (licensee) IST Program are contained in this Safety Evaluation (SE).

The IST program addressed in this SE covers the second ten-year inspection

-interval from April 1, 1987 to April 1, 1997. The licensee's program includes:

pump and valve IST program, Revision 1, and is described in a letter dated.

October 18, 1988. Additional information for several relief requests for both; units was-submitted by letters dated October 14, 1988, November 13; 1989, February. 15, 1990, and February 16, 1990. The program is based on the requirements of Section XI of the ASME Code,1983 Edition through the Sunner 1983 Addenda.

L EVALUATION l

The IST program and the requests for relief from the requirements of Section XI have been reviewed by the staff ~with the assistance of its contractor, Idaho

. National Engineering Laboratory, EG8G, Idaho, Inc. (EG8G).

In addition, EG&G and staff members raet with licensee representatives on February 18 and 19, 1988, in a working session to discuss questiens resulting from the review. The 1

901oo20171 900920

{DR ADOCK0500gf7

L

.. Technical Evaluation Report (TER) is EG&G's evaluetion of the licensee's inservice testing program and relief requests.

The staff has reviewed the TER and concurs with, and adopts, the evaluations and conclusions: contained in the TER. A summary.of the pump and valve relief request detern.inations is presented i

in Table 1 of this SE. The granting of relief is based upoi the fulfillment of any comitments made by the licensee in its basis for each *elief request and the alternative proposed testing, i

No relief requests were denied; however, ten relief requests were granted with certain conditions in TER Sections 3.3.1, 3.1.1, 3.4.2, 3.2.2, 4.3.1.1, 4.5.1.1, 4.4.2.2, 4.4.1.1, 4.4.1.3, and 4.4.2.1.

These conditions are alto listed in the TER Appendix C.

Further, one relief request was granted an interim relief in TER Section 3.2.1.

The licensee should refer to the specific TER section

' for a detailed discussion of these cases.

Paragraph 2.2 of the Calvert Cliffs IST program states that the licensee will revise the upper boundary for Alert and Action ranges of differential pressure

~a and flow for selected pumps.

In order to be consistent with IWP-3210, the:

licensee should document the bases for revising the specified ranges.

Paragraph IWP-3210 states that, if ranges in Table IWP-3100-2 cannot be met, the owner shall specify the " reduced range limits" to allow the pumps to fulfill their function.

Thus, the documentation should specify the " reduced

.(2)ge limits" and show why: (1) ranges in Table IWP-3100-2 cannot be met and; ran how, with the revised ranges, assurance will be provided that the pumps can continue to fulfill their function.

These documented bases should be in a form-that is readily available onsite for review.

The licensee should resolve the anomalies identified in the TER Appendix C and-this SE in accordance with the staff positions.

Required program changes identified in the TER Appendix C should be made within six months of receipt of this SE.

CONCLUSION l

Based on the review of the. licensee's IST program and relief requests, the staff concludes that the IST program, as evaluated and modified by this SE will provide reasonable assurance of the operational readiness of the pumps and i

valves covered by the IST program to perform their safety related functions.

The-staff has determined that granting relief, pursuant to 10.CFR 50.55(a)(3)(i),

(a)(3)(ii)', and (g)(6)(1), is authorized by law and will not endanger life or i

i property, or the common defense and security and is otherwise in the public interest.

In making this determination the staff has given due considerations the alternative testing being implemented; compliance with the specific to 1

requirements resulting 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. The last column of Table 1 identifies the regulation under which the requested relief is granted.

During the review of the licensee's inservice testing program, the staff has identified certain misinterpretations or omissions of Code requirements. These items are sunnarized in the TER Appendix C.

The IST program for Calvert

o; o

i i

3-L Cliffs, Units I and 2, through-a submittal dated February 16 -1990, is acceptable

~

l' for implementation provided that the items noted above are corrected promptly.

New or revised relief requests contained in any subsequent revisions-may not be

' implemented without prior approval by NRC unless they are relief requests meeting-the positions in Generic Letter 89-04, Attachment 1.

Dated:

l-PRINCIPAL CONTRIBUTOR:

l K. Dempsey l

L-l

(.

s

l y..

4 Page No. i 08/,22/90 CALVERT CLIFFS NUCLEAR POWER PLANT UNITS 1 AND 2 SER TABLE 1

-SUN 4ARY OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE

-ACTION REQUEST-SECTION REQUIREMENT IDENTIFICATION METHOD OF BY

-NUMBER.

& SUBJECT TESTING USNRC Pump 3.3.1 IWP 3100 Salt water Calculate suction Relief RR 1 -

Inlet-cooling pumps pressure from height granted pressure 11(21),

of water.

provided)the (a)(3)(i measurement.

12(22),13(23) calculations meet the accuracy requirements of IWP 4110.

Pump 3.2.3 IWP 3100 Salt water Grease bearin Relief RR-2 Observation cooling pumps manufacturer'gs per granted s

schedule.

(a)(3)(i) 11(21),13(23) of lubricant level or 12(22),

pressure.

Component cooling water 4

13(23).

Pump 3.1.1 IWP-3100 All safety Expand quarterly Relief RR Annual pump related pumps.. pump vibration ranted bearing testing from one a)(3)(ii) temperature reading to multiple or pumps measurement.

readings in two without orthogonal installed directions, bearing temperature measurement instruments..

.1 Pump 3.4.1 IWP-3100 Rx. coolant Maintain volume Relief RR 4 Measurement char ing pumps control tank level granted 12(2 J, 13(23) net positive suction (a)(3)(i).

11(2 J, to ensure adequate of pump suction pressure.

head to pumps.

1

Pa e No.

2 CALVERT ' IFFS NUCLEAR POWER PLANT

' NITS 1 AND 2 SER TABLE 1

SUMMARY

OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION.

METH00 0F BY NUMBER-

& SUBJECT

. TESTING USNRC-Pumo 3.4.2 IWP-3100 Rx. coolant Waive differential-Relief RR-l Measurement char ng pumps pressure measurement granted provid)ed)

(a)(3 (i of pump 11(2 requirement.

differential 12(2

,13(23) pressure.

testing methods conform to requirements outlined in evaluation.

Pump 3.2.1 IWP 4110 Numerous Meet flow loop Interim accuracy of +

relief of full scale /- 4% granted RR 6 Instrument

pumps, accuracy requirements.

(a)(3)(ii)

All AFW,dHPIS, Measure all required Relief Pump 3.2.2 IWP 3100 flow rate quarterly, granted parameters except LPIS, an RR-7 Measurement (g)(6) i) excest(that of pump containment flowrate.

spray pumps.

all required parameters at the

.PIS refueling outages.

pumps should be tested during cold shutdowns.

Ltr.

3.4.3 IWP-4520(b)

Rx. coolant Measure pump Relief vibration with granted charging (21)}:instrumentationthat(a)(3 Relief Vibration umps},1113(23 reads accurately instrument 2(22

.requiremants.

from 3 to 10,000 Hz.

Valve 4.1.2.1 IWV 3413(bl Power operated Assign maximum Relief A-1 and IWV-34h7 valves with limiting stroke time granted Stroke timing nominal streke of 2 seconds to (a)(3)(i) and times less rapid acting valves corrective than two with no trending of-action seconds.

valve stroke times, requirements.

cPage No..

~3-

'08/22/90

-CALVERT CLIFFS NUCLEAR POWER PLANT UNITS 1 AND 2 SER TA8LE 1 Supe 4ARY.OF RELIEF REQUESTS RELIEF-TER' SECTION XI-EQUIPMENT-ALTERNATE ACTION

. REQUEST -

SECTION REQUIREMENT IDENTIFICATION METHOD OF BY NUMBER

& SUBJECT-TESTING USNRC

~ Valve 4.1.3.1 IWV-3512 Safety related Test supervisor will Relief A-3 Relief valve relief and meet all

- granted 1

testing safety valves. requirements except (a)(3)(ii),

supervisor two years practical qualifica-experience in fluid

tion, flow measurement. -

1 Valve 4.1.1.1 IWV 3421 All

-Test containment Relief A4 through containment iso ~1ation valves:

granted according to10CFR50, Appendix J. (a)(3)(1)

IWV-3425 and isolation IWV-3427(b) valves.

Leak rate Type C, IWV 3426 and testing IWV-3427(a) requirements.

requirements.

Valve 4.2.1.1 IWV 3411 Containment Full-stroke exercise Relief VS-1:

Full-stroke ventilation during refueling Granted exercise salves outages.

(g)(6)(1) valves 1(2?-CV-1410 quarterly.

1*1a, 1412, 1413 Valve Appen. C in/-3521 Passive.

Appendix J leak rate Relief not NG-1 Full-stroke containment test during requirsd.

exercise isolation refueling outages.

check valves valves quarterly.

0 N2-344, 345, 346, 347, 348, 349, 389, 392, 395, 398

' Valve 4.3.1.1 IWV-3510 Pressurizer Channel. calibration Relief i

RC-1 Relief valve electro test at refueling, granted provid)ed)

(a)(3 (i testing magnetic functional test requirements. relief valves prior to placing and)4041(2 ERV-402 valves in service valves are and every 31' days oxercised thereafter.

and stroke timed as~

outlined in evaluation.

u l

=

j 1

Page No.-

4 08/22/90 CALVERT CLIFFS NUCLEAR PC'4ER PLANT UNITS 1 AND 2-SER TA8LE 1

SUMMARY

OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METH00 0F BY TESTING USNRC

& SUBJECT

-NUMBER Valve 4.5.1.1.

IWV-3521 Containment Sample disastSchly Relief Full-stroke spray header during refust 9.g granted provid)ed)

(g)(6 (i S1 1 exercise check valves outages.

1(2 316, disassembled 326),330,340 check valves valves are quarterly.

part-stroke exercised after reassembly.

~ Valve 4.4.2.2 IWV-3521 Containment Sample disassembly Relief F 11-stroke sump outlet during refueling granted provid)(d)

(g)(6 i

SI-2 exercise check valves outages.

e check valves 1(2)-SI-4148, disassembled quarterly.

4149 valves are part-stroke exercised after reassembly.

Relief Sample disassembly granted' Safety infection tank during refueling I

Valve 4.4.1.1 IWV-3521.

SI-3 exercise d. charge outages.:

(g)(6)(d).

i Full-stroke provide check valves

c. eck valves disassembled -

1(2)-51-215,5-valves are quarterly.

225, 235, 24 part-stroke exercised after reassembly.

Continuously monitor Relief upstream pressure, granted Valve 4.4.1.2 IWV-3421 Combined with alare functions (g)(6)(1).

Leak rate safety SI-4 testing injection on high pressure in requirements. system the control-room.

discharge check valves 1(?)51-217, 227, 237, 247 I

l l

L l

~-

CALVERT CLIFFS NUCLEAR POWER PLANT UNITS 1 AND 2 i

SER TABLE 1

SUMMARY

OF RELIEF REQUiSTS RELIEF TER SECTION XI EQUIPMENT.

ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY NUMBER

& SUBJECT TESTING USNRC r

Valve 4.4.1.3 IWV-3521 Combined Part-stroke exercise Relief 51-5 Full-stroke safety quarterly. sample granted exercise injection disassemblyduring provided)

(g)(6)(i check valves system refueling outages, quarterly.

oischarge disassembled check valves valves are l

1(2)-51-217, part-stroke 227, 237, 247 exercised after reassembly.

Valve 4.4.2.1 IWV-3521 Refueling Part-stroke exercise Relief.

SI-6 Full-stroke water storage quarterly sample

. granted exercise tank outlet disassemblyduring provid)e(d)

(g)(6 1

check valves check valves refueling outages.

quarterly, 1(2)-S1-4146, disassembled-4147 valves are part-stroke exercised after reassembly.

Valve 4.5.2.1 IWV-3521 Containment Part-stroke.during Relief SI-7.

Full-stroke spray pump-cold shutdowns, Granted exercise discharge full-stroke exercise-(g)(6)(i) check valves check valves with flow during quarterly.

g)-SI-313, refueling outages..

e i

I

,e-m

.*.e