ML20127D099

Forwards SE of IST Program Relief Request Re high-pressure Safety Injection Pump Discharge Check Valves at Plant.Util 910903 Proposal Acceptable for Implementation Per 10CFR50.55a(f)(iv) & Relief Not Required

ML20127D099
Person / Time
Site:	Waterford
Issue date:	01/11/1993
From:	Wigginton D Office of Nuclear Reactor Regulation
To:	Barkhurst R ENTERGY OPERATIONS, INC.
Shared Package
ML20127D103	List: ML20127D099 ML20127D136
References
TAC-M85059, NUDOCS 9301150095
Download: ML20127D099 (5)

Text

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'+g , , , , #j January 11, 1993 Docket No. 50-382 Mr. Ross P. Barkhurst Vice President Operations Entergy Operations, Inc.

Post Office Box B Killona, Lo'uisiana 70066

SUBJECT:

SAFETY EVALUATION OF THE INSERVICE TESTING PROGRAM RELIEF REQUEST RELAlED TO THE HIGH-PRESSURE SAFETY INJECTION PUMP DISCHARGE CHECK VALVES AT WATERFORD STEAM ELECTRIC STATION, UNIT 3 (TAC N0. M85059)

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 relief has been granted or proposed alternatives authorized by the Commission pursuant to 10 CFR 50.55a(f)(6)(1),

(a)(3)(i), or (a)(3)(ii). Guidance on acceptable alternatives to Section XI requirements was provided in Generic Letter 89-04, " Guidance on Developing Acceptable Inservice Testing Programs," for certain aspects of IST.

The Waterford 3 Inservice Testing Plan (i.e., Revision 7, Change 1) was submitted to the Commission via a letter from Entergy Operations, Inc. dated September 3, 1991. In this submittal, Entergy requested relief from the quarterly requirements to cycle open and closed the high-pressure safety injection (HPSI) pump discharge check valves. The basis for this request was "these valves are only exercised open during refueling outages. Closure verification can only be performed after open exercising." Entergy proposed that these valves be cycled each refueling outage, as opposed to quarterly (i.e., they proposed to verify closure only every refueling outage following full-stroke testing of the check valves to the open position).

In the NRC staff's safety evaluation dated August 19, 1992, we indicated that:

The licensee has not discussed why it is impractical to exercise the valves at the Code-required frequency. Additionally, in some cases, it is possible to verify that a check valve remains closed even though it has not opened or has only partially opened. There may be a practical means to verify more frequently than at refueling outages that the discharge check valves close or remain closed. The licensee has not addressed the impracticality of closure verification quarterly or during cold shutdown conditions.

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Mr. Ross P. Barkhurst Relief was therefore denied due to inadequate information to justify a basis for granting relief. The August 19, 1992, letter indicated that:

If the licensee has additional justification which supports granting relief and which has not been presented in the relief request, a submittal with the revised relief request should be made within 90 days ,

of the date of this SE [ safety evaluation]. Otherwise, testing is to be performed in accordance with the Code requirements within 90 days of the date of this SE.

By letter dated November 17, 1992, Entergy submitted a revised relief request, indicating that the next quarterly surveillance is due to be performed in mid-January, and requested that the revised request be given an expeditious review.

The enclosed safety evaluation (SE) provides the result of the staff review of information provided by Entergy Operations, Inc., in the Entergy letter dated November 17, 1992. We ha . determined that the licensee's proposal is acceptable for implementation pursuant to 10 CFR 50.55a(f)(4)(iv) and that relief is, therefore, not required.

Sincerely, Original signed by:

David L. Wigginton, Senior Project Manager Project Directorate IV-1 Division of Reactor Projects - Ill/IV/V Office of Nuclear Reactor Regulation

Enclosure:

Safety Evaluation cc w/ enclosure:

See next page DISTRIBUTION Docket File NRC & Local PDRs PD4-1 Reading J. Partlow B. Grimes T. Murley/F. Miraglia J. Lieberman OGC E. Jordan

G. Hill (4) OC/LFDCB J. Mitchell D. Wigginton M. Virgilio J. Larkins P. Nooran ACRS (10) (P-315) OGC (15B18)

J. Roe PD4-1 Plant File A. B. Beach, RIV D. Fischer OPA 0FC LA:PD4-l l i PMtitQ4-\1 D:PD4-1 l NAME PNoonan '

DW h on:pk JLarkins b l DATE / / 7 /93 \[l/92 I /// 92

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l OfflLIAL RECORD COPY Document Name: WA185059.rel

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Mr. Ross P. Barkhurst .

Relief was therefore denied due to inadequate information to justify a basis for granting relief. The August 19, 1992, letter indicated that:

If the licensee has additional justification which supports granting relief and which has not been presented in the relief request, a submittal with the revised relief request should be made within 90 days of the date of this SE [ safety evaluation). Otherwise, testing is to be performed in accordance with the Code requirements within 90 days of the date of this SE.

By letter dated November 17, 1992, Entergy submitted a revised relief request, indicating that the next quarterly surveillance is due to be performed in mid-January, and requested that the revised request be given an expeditious review.

The enclosed safety evaluation (SE) provides the result of the staff review of information provided by Entergy Operations, Inc., in the Entergy letter dated November 17, 1992. We have determined that the licensee's proposal is acceptable for implementation pursuant to 10 CFR-50.55a(f)(4)(iv) and that relief is, therefore, not required.

Sincerely, Original signed by:

David L. Wigginton, Senior Project Manager Project Directorate IV-1 Division of Reactor Projects - Ill/IV/V Office of Nuclear Reactor Regulation

Enclosure:

Safety Evaluation cc w/ enclosure:

See next page DISTRIBUTION Docket File NRC & Local PDRs PD4-1 Reading J. Partlow B. Grimes T. Murley/F. Miraglia J. Lieberman 0GC E. Jordan G. Hill (4) OC/LFDCB J. Mitchell D. Wigginton M. Virgilio J. Larkins P. Noonan ACRS (10) (P-315) OGC (15B18)

J. Roe PD4-1 Plant File A. B. Beach, RIV D. Fischer OPA 0FC LA: PD44~h) f PMMQ4hl D:PD4-1 NAME PNoona'n)' DW h on:pk JLarkins b DATE / /7/93 \ O /92 I /// 92

/

0FFICIAL RECORD COPY Document Name: WA185059.rel

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. Mr. Ross P. Barkhurst Relief was therefore denied due to inadequate information to justify a basis for granting relief. The August 19, 1992, letter indicated that:

If the licensee has additional justification which supports granting relief and which has not been presented in the relief request, a submittal with the revised relief request should be made within 90 days of the date of this SE [ safety evaluation). Otherwise, testing is to be performed in accordance with the Code requirements within 90 days of the date of this SE.

By letter dated November 17, 1992, Entergy submitted a revised relief request, indicating that the next quarterly surveillance is due to be performed in mid-January, and requested that the revised request be given an expeditious review.

The enclosed safety evaluation (SE) provides the result of the staff review of information provided by Entergy Operations, Inc., in the Entergy letter dated November 17, 1992. We have determined that the licensee's proposal is acceptable for implementation pursuant to 10 CFR 50.55a(f)(4)(iv) and that relief is, therefore, not required.

Sincerely, i

li dnton,SeniorProjectManager David L.

Project Directorate IV-1 Division of Reactor Projects - III/IV/V Office of Nuclear Reactor Regulation

Enclosure:

Safety Evaluation cc w/ enclosure:

See next page l

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Mr. Ross P. Barkhurst Entergy Operations, Inc. Waterford 3 cc:

Mr. Hall Bohlinger, Administrator Regional Administrator, Region IV Radiation Protection Division U.S. Nuclear Regulatory Commission Office of Air Quality and Nuclear Energy 611 Ryan Plaza Drive, Suite 1000 Post Office Box 82135 Arlington, Texas 76011 Baton Rouge, Louisiana 70884-2135 Resident Inspector /Waterford NPS Mr. John R. McGaha Post Office Box 822 Vice President, Operations Killona, Louisiana 70066 Support Entergy Operations, Inc. Parish President Council P. O. Box 31995 St. Charles Parish Jackson, Mississippi 39286 P. O. Box 302 Hahnville, Louisiana 70057 William A. Cross Bethesda Licensing Office Mr. Donald C. Hintz, President 3 Metro Center and Chief Executive Officer Suite 610 Entergy Operations, Inc.

Bethesda, Maryland 20814 P. O. Box 31995 Jackson, Mississippi 39286 Mr. Robert B. McGehee Wise, Carter, Child & Caraway Chairman P.O. Box 651 Louisiana Public Service Commission Jackson, Mississippi 39205 One American Place, Suite 1630 Baton Rouge, Louisiana 70825-1697 Mr. D. F. Packer General Manager Plant Operations Mr. R. F. Burski, Director Entergy Operations, Inc. Nuclear Safety P. O. Box B Entergy Operations, Inc.

Killona, Louisiana 70066 P. O. Box B Killona, Louisiana 70066 Mr. L. W. Laughlin, Licensing Manager Entergy Operations, Inc.

P. O. Box B Killona, Louisiana 70066 Winston & Strawn Attn: N. S. Reynolds 1400 1 Street, N.W.

Washington, DC 20005-3502