ML20087G291

Forwards Summary of Status of Requests for Relief from Requirements of Section XI of ASME Boiler & Pressure Vessel Code for Inservice Insp Program & Clarification of Items That Require Addl Review

ML20087G291
Person / Time
Site:	Prairie Island
Issue date:	03/09/1984
From:	Musolf D NORTHERN STATES POWER CO.
To:	Office of Nuclear Reactor Regulation
References
TAC-53456, TAC-53457, NUDOCS 8403190388
Download: ML20087G291 (9)

Text

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Northern States Power Company 414 Ncollet Mel P.*:nneapoks. Minnesota 55401 Telephone t612) 330 5500 March 9, 1984 Director Office of Nuclear Reactor Regulation U S Nuclear Regulatory Commission Washington, DC 20555 PRAIRIE ISLAND NUCLEAR GENERATING PLA!E Docket Nos. 50-282 License Nos. DPR-42 50-306 DPR-60 Status of Request for Relief from the Requirements of Section XI of the ASME Boiler and Pressure Vessel Code With our letter dated December 22, 1983 we submitted the Inservice 1:.spection and Testing Program for the second +.en-year interval at the Prairie Island Nuclear Generating Plant. 10 CFR Part 50, Section 55.55a(g) requires this program to conform to the latest NRC approved edition and addenda of Section XI of the ASME Code unless relief has been granted by the Commission.

The program submitted on December 22, 1983 contained a number of requests for relief fro.n the requirements of Section XI of the Code. Many of these requests for relief had been previously reviewed and approved by the Commission when the Inservice Inspection and Testing Program for the first ten-year interval was reviewed. The program for the first ten-yea r interval was originally submitted'on February 1, 1978 and was revised several times to incorporate NRC Staff comments, reflect newly discovered conflicts with the Code, and include new plant equipment.

The purpose of this letter is to summarize the status of our requests for relief from the requirements of the Code and clarify for the Staff which items require additional review and Staf f action. It should be noted that much of the material submitted on December 22, 1983 does not require Staff action. This material was provided only for the information of our Licensing Project Manager and other interested members of the l Staff. We believe that the program manual we have assembled, which very l clearly shows which components are inspected and tested as well as all j identified departures from the requirements of the Code, is a valuable l resource document. Regulations require only the submittal of new or l revised requests for relief.

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>Ey 8403190388 840309 l PDR ADOCK 05000282 )

G PDR

• NORTHERN CTATE] POWER COMPANY

!c. Dir:ctor cf NRR March 9, 1984 Page 2-As noted in our letter of December 22, 1983, three completely new requests for relief were identified when the new program document was assembled.

i These new requests for relief were numbered 66, 67 and 68. As a result

! of NRC review of our previous program or Code changes, a number of requests for relief were withdrawn. The status of all requests for relief is summarized on the attached table.

As noted on the Table, all requests for relief included in our current

, progran have been approved by the NRC Staff with the following exceptions:

Request for Relief Number Actions Remaining 4 NRC Staff review of this item was completed on 1/31/84. Our program will be revised to include additional NRC requirements described in the supple-mental SER.

5 The required valve internals inspections have been completed with no degradation detected. Our current program specifies a five-year re-inspection interval based on the results of this initial inspection. This interval was lef t unresolved in the 1/4/83 NRC Staff SER.

See the attached table showing' inspection results.

8 Reactor Coolant System vent valves (a TMI Action Plan modification completed on both units) were added to this request for relief subsequent to NRC Staff approval on 1/4/83. The proposed alternative testing meets NRC requirements as noted on the attached summary.

9 NRC Staf f review of this item was completed on 1/31/84. Our program will be revised to include additional NRC requirements described in the supplemental SER.

10 This request will be withdrawn in accordance with the NRC Staf f SER dated 1/4/83.

22 This request for relief will be withdrawn in accordance with the NRC Staff SER dated 1/31/84. l 24 This request for relief will be modified to include only the diesel-drived cooling water pumps in accordance with the NRC Staff SER dated 1/31/84.

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NORTHERN CTATE'3 POWER COMPANY

, Dir:ctor of NRR March 9, 1984 Page 3 45 The NRC Staf f SER dated 1/14/80 did not address the RHR heat exchangers (Class 2 components). This is believed to be an oversight. The basis on which other NRC Staf f approval was granted also applies to this component.

59 The change in order of testing pressure

. isolation valves cannot be made as specified in NRC Staf f SER dated 1/4/83 for one group of valves. We believe the alternative testing described in the attached figure is acceptable to the Staff.

66, 67, 68 New requests for relief Also, as stated in Note (1) to the attached table, we do not believe that revisions to the Code which af fect only the numbering of paragraphs cited in previously approved requests for relief require NRC Staff review and approval. We believe that in these cases the previous approval remains valid.

Except for the items we have noted, we believe the previous review remains valid for, the new program. There have been no changes in the Code or in the installed plant systems which impact our requests for relief.except as noted.

In summary, we believe that NRC Staf f review is required only for the new requests for relief submitted with our December 22, 1983 letter (number 66, 67 and'68). In addition, to provide documentation of closcout of issues previously reviewed, the Staff may wish to address resolution i of requests for relief 5, 8, 45, and 59.

Please contact us if you have any questions related to the information we have provided. We apologize for any inconvenience caused by the lack i of clarity of our December 22, 1983 submittal.

DJ W.

David Musolf Manager - Muclear Support Services DMM/bd Attachment c: J G Keppler NRR Project Manager, NRC Resident Inspector, NRC G Charnoff Attachments

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' Prairie Island

'R:qu:=t.for . Applicability . Data R311sf Evaluatsd in NRC Req; mat. . ,

Relief Number -(Unit 1,2 or 1/2) Requested by NSP 'SER Dated Approved ~ Remarks (notes 1,2,3,4) 1 .1/2 9/15/78 -1/4/83 YES -

2 1/2 9/15/78 1/31/84 YES -

3 1/2 9/15/78 1/31/84 YES -

4 1/2 9/15/78 1/31/84 YES Additional NRC. Requirements Specified 5 '1/2 6/8/79 1/4/83 YES Valve Intervals Inspection Interval Unresolved 6 Withdrawn - - -- -

7 1/2 9/15/78 1/4/83- YES -

8 1/2 6/8/79 1/4/83 YES RCS Vent Valves Added-9 1/2 9/15/78 .1/31/84 YES Additional NRC Requirements Specified 10 1 9/15/78 1/4/83 NO Will be withdrawn 11 1/2 2/1/78 1/4/83 YES -

12 1/2 9/15/78 1/4/83 YES -

13 1/2 2/1/78 1/4/83 YES -

14 1/2 9/15/78 1/4/83 YES -

15 Withd rawn - -

16 1/2 2/1/78 1/4/83 .YES -

17 Withdrawn - - - -

18 1/2 2/1/78 1/4/83 YES -

19 Withdrawn - - - -

20 Withdrawn - - - -

21 1/2 2/1/78 1/4/83 YES -

22 1/2 4/19/83 1/31/84 NO Will be withdrawn 23 1 2/1/78 1/4/83 YES -

24 1 4/19/83 1/31/84 YES Approved only for diesel CL pumps 25 1 9/15/78 1/4/83 YES -

26 1 9/15/78 1/14/83 YES -

27 1/2 9/15/78 1/14/83 YES -

N!f 3 28 1/2 2/1/78 11/14/80 YES -

E2 N 29 1/2 2/1/78 11/14/80 YES -

S#S 30 1 2/1/78 11/14/80 YES -

$2 0 31 1 2/1/78 11/14/80 YES -

N-o 32 Withd rawn - - - -

?o

• 33 1/2 9/15/78 1/4/83 YES -

34 Withd rawn - - - - 2 35 1/2 6/8/79 1/4/83 YES -

c 36 Withdrawn - - - -

37 Withdrawn - - - -

o 38 Withdrawn - - - -

39 1/2 2/1/78 1/4/83 YES -

40 1 2/1/78 1/4/83 YES -

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Request for- . Appl'icability . . Date Relief.' ' Evaluated in NRC- Request . , .

. Relief Number (Unit 1,2 or 1/2) . Requested:by NSP SER Dated Approved Recarks (notes 1,2,3,4)1 41- Withdrawn -

42' I 812o/83 12/28/83 YES - -

43. - Withdrawn - - - -

44 ~ -Withdrawn - --- -- -

45 1/2 2/1/78 1/14/80 YES Note 5 46 Withdrawn -

47 Withdrawn - - - -

48- 1/2 9/15/78 1/14/80 YES -

49 Withd rawn - - ' - -

50 1/2 9/19/79 ~1/14/S0 YES -

51 Withd rawn - - - ' -

1/2 2/1/78 11/14/80 52 YES -

53 Witiid rawn . .- - - -

54 1/2 2/1/78 11/14/80 YES -

55 Withd rawn - - - -

56 1/2 2/1/78 11/14/80 YES- -

57- 1/2 9/15/78 1/4/83 YES Note 6 58 Withdrawn - - - -

59 1/2 4/i7/80 1/4/83 YES Note 7 50 1/2 9/15/78 11/14/80 YES. -

61 1 6/8/79 11/14/80 YES -

62 Withd rawn -

63- 1/2 6/24/83 10/12/83 YES -

64 Withdrawn - - - -

65 Withdrawn - - - -

66 1/2 10/14/83 - -

Note 8 67 1/2 10/14/83 - -

Note 8 68 1/2 10/14/83 - -

Note 8 L

Notes:

1) Reviced code section numbers have been incorporated in the Relief Requests contained in the program manual for the second ten-year interval. No additional NRC review is believed to be necessary in these cases.

2) Additional' NRC requirements or NSP commitments noted in NRC SER dated 11/14/80 were implemented with Revision 6 to the program manual for the first ten-year interval dated 7/31/81.

3) Additional NRC requirements or NSP commitments noted _ in NRC SER dated 1/4/83 were implemented with Revision 8 to the program manual for the first ten ' year interval dated 4/19/83.

4) Relief requests will be modified in a future revision to the current program manual to' include additional NRC requirements or NSP commitments noted in NRC Supplemental SER dated 1/31/84. See remarks column.

5) NRC Staff SER did not address RHR heat exchangers (Class 2). This is believed to_ be an accidental omission.

6) Required changes specified in NRC SER made in Revision 0 of program manual for the second ten-year in te rva l.

7) NSP commitment to reverse order of testing for accumulator check valves has been revised. For SI-6-2, MV-32066, and SI-6-1 (and Unit 2 equivalents) this cannot be done. See the attached sketch and explanation.

8) Undergoing NRC review.

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Request for Relief No. 5 - Check Valve Internals Inspections

.The following inspections were performed as required by Request for Relief No. 5:

Check Valve Inspection -

Numbers Description Date Results CW-18-1 D2 Diesel Gen Cooling 2/28/84 Good Condition Water Supply Check CW-18-4 D1 Diesel Gen Cooling 8/2/83 Good Condition Water Supply Check Tighten 1 bolt k turn CA-11-1 Caustic Add to 11x12CS 12/16/83 Good Condition Pumps CS-18 11 Cntat Spray Disch 12/11/83 Good Condition Check CS-19 12 Cntat Spray Disch 12/18/83 Good Condition Check 2CA-11-1 Caustic Add to 21 and 9/24/83 Good Condition 22 CS Pumps CS-48 21 Catmt Spray Disch 9/20/83 Good Condition Check CS-49 22 Cntat Spray Disch 9/26/83 Good Cosdition Check Based aon the results of these inspections (made following approximately ten years of operating service), we believe a 5-year re-inspection interval is appropriate' as proposed in Request for Relief No. 5.

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. ~ Request for Relief No. 8 _ Reactor Coolant System Vent Valves.

Unit 1 - SV-37035, 37036, 37037, 37038, 37039, 37049 Unit =2 - SV-37091, 37092, 37093, 37094, 37095, 37096 We believe cold shutdown exercising of these valves is not practical and that refueling exercising is appropriate.

As stated in our letter dated July 6, 1981:

ASME operability testing of the vent system can be accomplished as required'. However according to sub-section IWV, valves shall be exercised once every 3 months unless it is not practical during plant operation.

We do not believe it is practical to test these valves

-during plant operation, therefore the valve operability testing should be accomplished during refueling.

- The Technical Evaluation Report (TER) accompanying the safety evaluation report issued by the NRC Staf f on September 19, 1983 noted that a refueling .

interval surveillance was specified by NSP and found this acceptable.

During many cold shutdown conditions, the reactor coolant system will remain pressurized and the potential exists for some leakage through the

. system during this testing. Refueling interval testing will be done with the reactor coolant systeta depressurized.

These values are used during routine fill and venting procedures following refueling and other cold shutdowns involving depressurization. This use of these valves helps assure their operability.

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I Request for Relief No. 59 - Revised Precedure q'e Page 3-4, 5 of NRC SER dated January 4,1983 states that NSP has

-agreed to reverse the order of testing certain isolation valves.

We have revised the wording of the relief request to incorporate the

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desired order of testing (i.e., inboard or valves close to reactor coolant system should be tested last to minimize valve op'eration after leak testing). This cannot be accomplished for accumulator isolation valves, however, since Technical Specification Limiting Conditions for Operation (LCOs) require the accumulators to be

-operable under the plant conditions required for the valve tests.

This valve arrangement is tested in the following manner:

A SI-6-2 SI-6-1

+- 4-N N RCS__._jumpey,,,,,,f MV-32066 SI-6-2 is leak tested before placing accumulator in service MV-32066 & SI-6-1 are leak tested by connecting a jumper between RCS & drain valve & monitoring change in ACC level & RIIR pressure The NRC Staff has requested us to test SI-6-1 and 32066 first, then SI-6-2. The back leakage of S1-6-2 can only be done by isolating the accumulator. We cannot* isolate an accumulator when LCOs requires it to be-in service.

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