ML20086H923
| ML20086H923 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 12/03/1991 |
| From: | Woodard J ALABAMA POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9112100175 | |
| Download: ML20086H923 (5) | |
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Docket Nos. 50-348 10 CfR 50.55a 50-364 U. S. Nuclear Regulatory Commission ATIN: Document Control Desk i
Washington, DC 20555 Joseph M. Farley Nuclear Plant Inservice Testing of ASME Code Classes 1, 2 and 3 Eumos and Valves - Deferral of lenle.m1Lation Gentlemen:
On June 3, 1991. Alabama Power Company received the E 's Safety Evaluation and Technical Evaluation Report (SE/TER) on the subject Inservice Testing (IST) Programs which were transmitted by letter dated May 23, 1991 (TAC Nas. 65489 and 71579)., Section 2.0 of the SE requested that certain actions identified in Appendix A of the TER be completed within six months of receipt of the SE (December 3,1991).
In addition to the granting of relief requests, Appendix A of fb9 1ER and the accompanying SE denied certain relief requests, provisionally granted certain relief requests, and granted some relief requests on an interim basis for twelve months or until the next refueling outage, whichever is longer.
Alabama Power Company has reviewed the SE/TER and has determined that in several instances where the NRC denied, or inte-imly granted relief requests, the technical and/or schedular requirements of the SE/TER are impractical.
Specifically, technical and/or schedular requirements imposed
.by the SE/TER for two of the partially denied and several of the interimly granted relief requests are impractical to implement. Of these issues, one involves individual versus parallel testing of service water pumps on a quarterly basis and the others relate to testing to be performed during a cold shutdown of sufficient duration or refueling outage. These issues must be resolved prior to the start of the Unit 2 eighth refueling outage, tentatively scheduled to begi e March 6,1992. Alabama Power Company requests a meeting with the NRC during December 1991 to discuss these issues.
Pending decisions reached in that meeting, Alabama Power Company will provide by December 31, 1991, a detailed submittal addressing each item from the TER, Appendix A for which full compliance cannot be met.
These issues are summarized herein and further described in Attachments 1 and 2.
For the partially denied and interimly granted relief requests, Alabama Power Campany is continuing to evaluate various alternatives for addressing the additional requiraments imposed in the SE/TER.
These determinations directly impact the development of revised programs'and procedures.
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Therefore, the completion date proposed by the NRC for implementation of the Appendix A items specified in the SE must be extended from six months f\\
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U. S. nuclear Regulatory Commission Page two to nine months from the receipt of the SE/TER, except where interim i
granting has t.1 ready been extended t1 the first refueling outage or twelve j
months, whichever is longer.
For the TER, Appendix A items discussed above and in Attachments 1 and 2, completion of the actions requested, includin;;
the revisions of programs and procedures, is dependent upon satisfactory resolution of these issues at the requested Decembar 1991 meeting.
All remaining TER, Appendix A Items not addressed in the above mentioned submittal will be completed within the three month extension.
The SE/TER partially denied portions of three relief requests.
For each partial denial, the SE/TER also granted or provisionally granted portions of these same relief requests.
The SE provided a specific, six month schedule for implementation of the granted or provisionally granted portions, but did not provide such a schedule for the denied portions.
In the absence of such a. schedule, Alabama Power Company interpreted the schedular requirements for the granted and provisionally granted portions of these reliefs (lief request requirements.i.e., completion six months from receipt o to apply to all re Based on a conference call held on December 2, 1991, with Messrs. Steve Hoffman and Ken Dempsey of the NRC, Alabama Power Company was informed that absence of an implementation schedule for denied portions of reliefs meant that reliefs previously grante(' in an interim basis were immediately denied upon receipt of the SE/TER and that the SE made no provisions for a reasonable implementation period.- These same relief requests had been interimly granted by the NRC for Units 1 and 2 for over two and three years, respectively.
In the interim, Alabama Power Company has continued to perform inservice testing in accordance with the IST Program relief requests previously submitted for Units 1 and 2, which were interimly granted by NRC letters dated March 30, 1988, and March 31, 1989, respectively.
To clarify its position, Alabama Power Company proposed in the referenced conference call to provide specific information on the denied portion of each relief request.
4 provides a summary of the denied relief request portions, whether the requested actions are impractical, proposed alternate testing and interim actions to be taken pending resolution of the issues.
The SE/TER interimly granted one Unit 2 relief request in the Containment Spray system where the provisional requirements cannot be complied with
-until completion of a Unit 2 plant modification.
This modification is required to permit full forward flow testing of these check valves at refueling outages. The modification involves procurement and insta11atien of safety related piping and valves necessary to temporarily divert the Containment Spray Pump discharge flow into the refueling cavity.
Due to the extent and complexity of this modification, it cannot be completed until the Unit 2 tenth refueling outage, tentatively scheduled to be completed in April 1995.
For this reason, an extension is needed to the interim granting of _ relief to permit valve disassembly and visual inspection without partial flow verification following reassembly until the necessary modifications can be completed.
The SE/TER interimly granted several other. relief requests where the technical provisions cf the interim granting cannot be complied with. Attachment 2 summarizes the requirements imposed by the interimly grantsd reliefs and their impracticality.
U. S. Nuclear RegJlatory CommiMion Page three All items listed in Attachments 1 and 2, except for quarterly testing of Service Water and Dies,el Generator fuel 011 Transfer Pumps, are related to cold shutdown and/or refueling outage testing and are not scheduled to be performed until the Unit 2 eighth refueling outage.
The attached information is provided to facilitate the proposed December 1991 meeting.
At this meeting, Alabama Power Company also wishes to discuss one relief request not addressed in the SE/TER and two additional relief requests submitted for Units 1 and 2 by letters dated July 26 and 29, 1991, respectively.
If there are any questions, please advise.-
Respectfully submitted, ALABAMA POWLR COMPANY k [> 3rw o
sJ J Woodard JDW/ STB: map 1466 Attachments cc: Mr. S. D. Ebneter Mr. S.- T. Hoffman Mr. G. f. Maxwell 1
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' 1 ATTACHMENT 1
%J PARTIALLY DfNIED RELIEF REQUESTS ey]
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ttlymos - Felief Reouest P.ELQ m.
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is requested.e*
'isequently denied to test two pmps in parallel.
. :e Water syr > 4 ign does not permit measuring pump discharge l'
6"1 the irdividud e s discharge lires, as neither flow mentat h nor s ui.able location for flow instrumentation is
%bl e. Thus, the only viable means for testing a pump individually is r
ne ihe nther operating pump from service.
This configuration m.o
_:s with normal plant op ration as specified in the FSAR, which vqub s two operating. sps. Removing the other pump from service could lead to isolation of the turbine building Service Water supply lines requirir.q a plant shutdown. As an alternative. testing Service Water Pumps in parallel will be continued on a quarterly basis with performance of individual pump tests during refueling, when plant conditions permit opera
,r, of a single pump.
If quarterly testing results exceed the Acceptme Range, analytical evaluations are performed to determine individual pimp performanca and to determine corrective act5cns. Until this issue is resolved, Alabsea Power Company will continue testing the Service Water Pumps in accoroance with the existing IST Program requirements.
E.
Diesel Generator fuel Oil Transfer Pumps - Relief Reaugst PR-16 Relief was requested and subsequently denied for meuuring diesel generator fuel oil transfer pump suction and discharge pressures nad calculuing differential pressure due te the lack of avWable instrumentation.
Subsequently, it has been determined that mporary pressure gauge can be installed on the discharge side of each pump and can be used to calculate differential pressure, Prrc.edures have been revised to include this provision. Tests performed in the tuture will include measurement of differential pressure as requee..
Sl{qtv Inierlion Check Val- _
Relief fle_ quest 01/2E21-RV-4 1
Relief was requested and subsequently denied for disassembling the Saf ety m
Injection system discharge check velves to the hot and cold leg RCS. The E
basis of the denial was the fact that the P&lD drawing indicates the presence of flow orifices which the NRC believed could be utilized for measuring individual branch line flow during forward flow testing. While these flow orifices do exist, the associated instruments were removed following the start-up flow balance.
The instrumentction connections have been capped.nd seal welded, rendering them inoperable.
Therefore, measurement of individual branch line flow during full forward flow testing would require a pl int modification. Until this issue is resolved Alabama Power Company will cca+ aue to test these valves in accorJ nce with the interimly granted relief request, which requires disassenibly and visual inspection of one valve from each of the four three-valve groups during each refueling outage.
If any degradation is detected, the remaining valves in that group will he disassembled and inspected.
In addition, where valve internals are removed, a partial flow test following reassembly
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will be performed to verify operability.
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m ATTACHMENT 2 INTERIMLY GRANTED RELIEF REQUESTS Rgattgr Vessel Head Vent Valves - Religf Reauest 01/2B13-RV-1 The relief was interimly granted to allow development and implementation of a method to monitor valve stem position movement during stroke time testing. These solenoid-operated valves have no means of verifying valve stem position.
Furthermore, Westinghouse has no approved alternative design to replace or modify these valves to accommodate valve stem movement verification.
Containment Soray Dischar.ge Check Valves - Relief Reauest 02E13-RV-1 Relief was interimly grhr.:
provided the valves are partial flow tested following disassembly and visual inspection.
The valves are disassembled and inspected in lieu of fill or partial forward flow testing.
Plant design does not permit full or partial forward flow testing without initiating flow to the containment spray header.
RHB Heat Exchanapr Flow Contrpl Valves - Relief Reauest Ol/2 Ell-RV-Q Relief was interimly granted pending development of a methed to stroke time these modulating valves.
Alabama Power Company has determined that these valves are not subject to testing under the ASME Code,Section XI, and they will be deleted from the program.
Charaina Pumo Suction Check Valvt from the RWST - Relief Reauest 01/2E21-nV-1 Relief was ir.terimly granted pending development of a quarterly partial stroke testing method.
Full or partial forward ' low testing this check valve requires aligning the Pefueling Water Siy age Tank to the Charging Pump suction and injecting flow into the RCS.
During normal operation, this test configuration would introduce heevily borated water into the RCS, resulting in reactivity excursions.
Auxiliary Feedwater Pumo Suction Chtck Valves - Relief Reauest 01/2N23-RV-1 Relief was interimly granted pending development of a method of reverse flow closure verification.
These valves can be tested at refueling using a leak test similar to an LLRT type pressure decay test.
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