ML20127L422

SE Accepting IST Program Requests for Relief for Pumps & Valves

ML20127L422
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	11/19/1992
From:	Office of Nuclear Reactor Regulation
To:
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ML20127L421	List: ML20127L417 ML20127L422
References
NUDOCS 9211240236
Download: ML20127L422 (17)

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- UNITED STATES n

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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20666 SAFETY EVALVATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION j

RELATED TO THE INSERVICE TESTING PROGRAM RE0 VESTS FOR RELIEF PORTLAND GENERAL ELECTRIC COMPANY. ET Al.

l' TROJAN NUCLEAR PLANI DOCKET NUMBER 50-344

1.0 INTRODUCTION

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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 have been authorized by the Commission pursuant to 50.55a 1 5

_(f)(6)(i), (a)(3)(i), or (a)(3)(ii).

In order to obtain authorization or relief, the licensee must demonstrate that: (1) conformance is impractical for its facility; (2) the proposed alternative provides an acceptable level-of quality and safety; or (3) compliance would result in a hardship or unusual difficulty without a compensating increase in the level of' quality and safety.

Section 50.55a 1 (f)(4)(iv) provides that inservice tests of pumps and valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 1 (b) of 6.50.55a, subject to the limitations and modifications listed, and subject to Commission approval. NRC guidance l

contained in Generic Letter (GL) 89-04, " Guidance on Developing Acceptable l

Inservice Testing Programs," provided alternatives to the Code requirements determined to be acceptable to the staff and authorized the use of the alternatives in Positions 1, 2, 6, 7, 9, and 10 provided the licensee follow i

the guidance delineated in the applicable position. Whea an alternative is proposed which is in accordance with Generic Letter (GL) 89-04 guidance and is documented in the IST program, no further evaluation is required; however, i

implementation of the alternative is subject to NRC inspection.

l Section 50.55a authorizes the Commission to grant reliof from ASME Code requirements or to approve proposed alternatives upon making the necessary l

findings. The NRC staff's findings with respect to granting or not granting the relief requested or authorizing the proposed alternative as part of the licensee's IST program are contained in this Safety Evaluation (SE).

This SE concerns relief requests and supporting information that were submitted in Portland General Electric's (FGE) letter dated June 30, 1992, for the Trojan Nuclear Plant IST program. A review of the licensee's response to anomalies identified in NRC SE dated December 5,1991, was performed.

I 9211240236 921119 DR ADOCK 0500 4

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The results of this review are provided in the attached Table of Anomalies / Action Items.

The new or revised relief requests which were included in the submittal are evaluated below.

2.0 GENERAL The Trojan IST Program, second ten-year interval, was developed to the 1983 Edition, with Summer 1983 Addenda, of ASME Section XI. The second inservice testing interval began May 21, 1986. The new relief request evaluations below are to the requirements of the 1983 Edition, Summer 1983 Addenda, of ASME Section XI.

f 3.0 RELIEF RE0 VEST 3.2.12

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The licensee has requested relief from the instrument accuracy requirements of Section XI, Table IWP-4110-1, and from the full-scale range requirements. of IWP-4120.

The relief request is applicable to all Code Class 2, 3, and ASME Section VIII pumps in the IST program which perform a function in shutting down the reactor or in mitigating the consequences of an accident, and are provided with an emergency power source.

l 3.1 Lj_qs! Lt. 's Basis for Relief e

i The licensee states:

"If the cumulative accuracies allowed per Table IWP-4110-1 and Subarticle IWP-4120 are either met or exceeded during pump performance data measurement, it should be acceptable to deviate from the i

requirements of either Table IWP-4110-1 or Subarticle IWP-4120.

It is possible to meet the fundamental technical requirements of ASME Section XI, Subsection IWP, without strictly adhering to the concurrent requirements of l

Table IWP-4110 and Subarticle IWP-4120.

Relief from the specific requirements allows certain permanent plant instruments to be used for data measurement. This precludes the need to routhely install temporary test instrumentation which provides no greater assurance of operational readiness.

l An example demonstrating each of the possibilities is provided for clarity.

l 1.

Where the 3 percent accuracy converts to an absolute accuracy equal to l

or better than the Code required-2 percent accuracy, p

For example, using a pressure reference value of 50 psig and an actual l

full scale range of 100 psig:

(a)

Code Reference Value - 50 psig Code allowable range - 3 x reference value - 150 psig Code instrument accuracy allowed (units of pressure) =

2 percent x 150 psig -

3 psig.

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1 (b)

Tro_ian Reference value - 50 psig i

Actual full scale range - 100 psig i

An allowable instrument accuracy of 3 percent x 100 psig -

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psig could be used and would be comparable to the Code allowable instrumentation.

I As demonstrated in the example, if (b) is less than or equal to (a) then the existing instrumentation is considered to be sufficiently accurate.

2.

Where three times the reference value is exceeded but actual accuracy converts to an absolute accuracy equal to or better than the-allowable Code requirements.

i For example, using a pressure reference value of 30 psig and an actual full scale range of 100 psig:

(a)

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Reference - 30 psig l

Code allowable range - 3 x reference value - 90 psig Code instrument accuracy allowed (units of pressure) -

2 percent l

x 90 psig -

1.8 psig (b)

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Reference value - 30 psig Actual full scale range - 100 psig An actual instrument accuracy of 1.5 percent x'100 psig -

1.5 j

psig could be used and would be comparable to the Code allowable instrumentation.

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As demonstrated in the example, if (b) is.less_ than or equal to (a),

l then the existing instrumentation is considered to be sufficiently accurate."

3.- 2 Pronosed Alternative The licensee' proposes:

" Instruments.t.ich deviate from the requirements of i

Table IWP-3110-1 or Subarticle IWP-4120 are acceptable provided the cumulative-accuracy meets or exceeds the Code requirements. NRC approval is requested in accordance with 10 CFR 50.55a (a)(3)(i)."

3.3 - Evaluation 4

j The Code requirements for range and accuracy of instrumentation for measuring i

pump flow and pressure were established such that the readings obtained would be within a range of variance small enough to make degradation monitoring i

i meaningful. The original inservice testing requirements specified an j

instrument range of four times the reference value or less. As a result,-many 0

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i early licensed plants have permanent instrumentation that does not meet' the requirements of later Code editions which require an instrument range of three times the reference value or less. The NRC does not consider installation or replacement of instruments an undue burden. However, if available instrumentation meets th:..ntent of the Code requirements for the actual reading, the use of such instrumentation provides an equivalent >"el of quality and safety for inservice testing.

Because the licensee has requested approval on a general basis without i

specifying the specific instruments and the associated pumps, relief can be granted provided an instrumentation section be included in the inservice testing program which documents, for each permanently installed instrument i

used for pump testing, (1) the full-scale range, (2) the accuracy, (3) the reference value, and (4) a calculation demonstrating that the reading obtained is within J e variance that would be allowed if the instrument met the Code requirements. When using temporary instrumentation that does not meet the Code requirements, but similarly meets the intent of the Code, the instrument number (for traceability), instrument full-scale range, and instrument accuracy must be included in the test record to ensure that the readings obtained are within an equivalent variance.

For temporary instruments, the range is generally greater than three times the reference value, but the accuracy is generally 0.5% rather than 2%, providing a reading within the allowable variance of the Code.

In all cases, the licensee's instrument calibration program should be such that all instruments used for inservice testing are within current calibration.

3.4 Conclusion The alternative is authorized pursuant to 10 CFR 50.55a 1 (a)(3)(i) based on-the use of the currently available instrumer. ration providing an equivalent level of quality and safety to the Code requirements for the range and accuracy. This authorization contains the provision that the licensee include adequate documentation in the i-service testing program, or test procedures as appropriate, which demonstrates that the specific instruments meet the intent of the Code.

l 4.0 REllEF RE0 VEST 3.2.13 Relief from the inservice testing requirements of IWP for the Code Class 3 and ANSI B31.1 chilled water recircula* ion pumps was requested. The control room

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supplemental cooling system, CB-16, is a self-contained (no service water as an emergency cooling water source) air conditioning unit with refrigerant, chilled water, and forced air recirculation loops. The chilled water. pumps provide the driving head to recirculate chilled water through a cooling coil.

This loop removes heat from the control room atmosphere as a fan-driven recirculation loop forces-air over the cooling coils. A third refrigerant loop subsequently removes heat from the chilled water loop. The system was i

not designed to enable inservice testing of the chilled water recirculation pumps.

4 4.1 Licensee's Basis for Relief The licensee states:

" Verifying chilled water pump performance alone per ASME Section XI, Subsection IWP, will not assure system operability. Other components such as control valves, compressors, condensers, coolers, and evaporators are critical to the system performance. A more realistic measure of performance has been developed which verifies overall system cooling capabilities through monitoring and evaluation of control room and outside air temperatures during a 10-hour surveillance test while CB-16 is running.

This test is performed every 30 days, which is more frequent than Code requirements.'

4.2 Drocosed Alternative The licensee proposes:

"The CB-16 system performance will be measured by verifying that its cooling capabilities meet certain Vedetermined standards.

The data from the test will be compared against established performance curves for CB-16. Any significant reduction in the cooling capabilities of the system, including the chilled water pump, will be readily apparent from this testing.

NRC approval is requested in accordance with 10 CFR 50.55a (a)(3)(i) and 10 CFR 50.55a (g)(6)(i)."

4.3 Evaluation For a number of plants, the systems that support control room habitability are considered safety-related, engineered safeguards systems.

The cooling water to the coolers is generally Code Class 3 in accordance with Regulatory Guide 1.26, " Quality Group Classifications and Standards for Water, Steam, and Radioactive-Waste-Containing Components of Nuclear Power Plants," paragraph C.2.b.

Trojan performs a system functional test once every thirty days and essesses the performance of the entire system rather than individual components. To assess degradation of the system, test results are compared to performance curves for system cooling capability.

The control valves in the system regulate flow and differential pressure according to system parameters that may change due, for example, to temperature differences in outside air throughout the year.

Reductions in the cooling capabilities of the system would indicate that degradation could be occurring in the pumps, though the reductions could also be due to other conditions.

In general, if a design basis test is performed periodically, assurance of the operational readiness of the components is verified by the test.

The 10-hour surveillance of the CB-16 system is essentially a design basis test.

Monitoring these parameters in accordance with the Code requirements is impractical based on the design of the system.

However, vibration monitoring of pump bearings could provide information on the condition of the pumps from test to test.

This shculd be included in the testing at the same point in time (from the start of the test each time the test is performed).

Additionally, the test procedure should have acceptance criteria for taking actions to correct any potential degrading conditions of the pumps.

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i Imposition of the Code requirements to monitor pump parameters would be a burden in that (1) modifications would be required, (2) operating the system in an off-normal condition for testing may result in damage to some of the components or reduce the overall reliability and efficiency of the system when operating in a normal condition, and (3) additional testing requires additional staff resources.

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4.4 Conclusion Relief is granted pursuant to 10 CFR 50.55a 1 (t)(6)(1) to monitor the condition of the chilled water recirculation pumps indirectly by monitoring the condition of the system during a 10-hour maillance performed once each 4

30 days based on (1) the impracticality of the system design to enable i

inservice testing of the pump in accordance with the Code requirements, (2) consideration of the burden if the requirements were imposed, and (3) the testing performed providing assurance of the operational readiness of the l

pump. The licensee is to incorporate vibration monitoring of the pump into the testing unl.:s an assessment determines that-the data would not provide meaningful information. The inclusion of vibration monitoring in the testing is subject to NRC inspection; therefore, if the vibration monitoring is not i

included in the test performance, the determination is to be included in the inservice testing program document or a document referenced in a revision to the relief request. Additionally, the test procedure is to include acceptance criteria that requires analysis and/or corrective action when poter,:ial pump degradation is identified.

5.0 RELIEF RE0 VEST TABLE 4.1-4 ITEM C.

The licensee has requested to implement a cold shutdown te.cing schedule that does not prohibit startup when all inservice testing of valves scheduled for l

cold shutdown testing has not been completed. ASME Section XI, IWV-3412(a) and IWV-3522 requi:

that testing which cannot be performed during plant operation be performed during cold shutdown conditions. The relief request is l

applicable to all valves in the inservice testing program tested at a cold l

shutdown frequency.

5.1 Licensee's Basis for Relief The licensee states:

" Title 10 to the Code of Federal Regulations, Section l

50.55a (a)(3)(ii) provides for relief from the requirements of this section l

(10 CFR 50.55a) when compliance would result in undue hardship without a j

compensating increase in safety.

The extension of an outage solely for the L

purpose of completing testing required to be performed at each cold shutdown i

creates an economic hardship due to lost power. generation.

No decrease occurs 1

in the-quality or lew, of safety as the interval between cold shutdowns could 4

be from one refueling outage to the next refueling outage.

In addition, the 1989 Edition of the ASME Code and ASME Code Case N-473 (approved by ASME on March 8,1989) invoke ASME/ ANSI OM, Part 10, " Inservice Testing of Valves in Light-Water Reactor Power Plants." 0M Part 10, Sections 4.2.1.2 and 4.3.2.2 require that cold shutdown frequency testing be performed until testing is completed or the plant is ready to return to power.

It also requires that

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7-valve testing be performed during a refueling outage. The NRC published,.in i

the Federal Reaister, its intent to adopt the 1989 Edition of the ASME Code.

The notification did not identify that the NRC Staff had concerns with the use i

of OM Part 10, Sections 4.2.1.2 and 4.3.2.2."

5.2 Proposed Alternative The licensee proposes:

To perform cold shutdown testing in accordance with the schedule requirements of ASME/ ANSI OM Part 10, Sections 4.2.1.2(g),

4.2.1.2(h), 4.3.2.2(g), and 4.3.2.2(h). NRC approval is requested in accordance with 10 CFR 50.55a (a)(3)(ii)."

i 5.3 Evaluation 4

In rulemaking to 10 CFR 50.55a cffective September 8,1992 (See 57 Federal l

Reaister 34666), the 1989 Edition of ASME Section XI was incorporated in 1 (b) of 5 50.55a.

The 1989 Edition provides that the rules for inservice testing of valves are as specified in OH-10. The staff imposed no limitations to 0M-i 10 associated with testing valves during cold shutdown.

Section 50.55a 1 (f)(4)(iv) provides that inservice tests of valves may seet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 1 (b) of f 50.55a, subject to the limitations and modifications listed, and subject to Commission approval.

Portions of editions or addenda may be used provided that all related requirements of tb respective editions or addenda are met.

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OM-10, Paragraphs 4.2.1.2(g) and 4.3.2.2(g) specify the following:

l Valve exercising during cold shutdown shall commence within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of achieving cold shutdown, and continue until a~ll testing is complete or the plant is ready to return to power.

For extended outages, testing need not be commenced in 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> provided all valves required to be tested during cold shutdown will be tested prior to plant startup.

i However, it is not the intent of this Part to keep the plant in cold shutdown in order to complete cold rhutdown testing.

Accordingly, the relief requested by the licensee is covered by the rulemaking effective September 8, 1992, as described above, and no further action is required.

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Attachment:

Table of Anomalies / Action Items Principal Contributor:

Patricia L. Campbell Date: November 19, 1992 4

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t TABLE OF ANOMALIES / ACTION ITEMS IDENTIFIED IN NRC SAFETY EVALJATION DATED DECEMBER 5, 1991 PORTLAND GENERAL ELECTRIC COMPANY, ET AL.

TROJAN NUCLEAR PLANT DOCKET NO. 50-344 TER SECTION/ ANOMALY NLSWER DESG IPTION ON Am0 MALT / ACTION ITDI P(kitAaB EMERAL ELECTRIC'S fPE) ACTION CJNWEET STAftF 5.1 In serv'ce water ptmp relief request The retI2f request was modified to Including the deteretnetton 3.2.1, the licensee included t w icent in delete the referenc? to tubricant. A ef differentist pressure in the " Test Requirement" section. No discussion of how the measurement of the relief reent es discussion of this test requirement in differentiet pressure is determined was rw_,.M in the encmely the "Besis for Variance" was provided.

added to the relief request.

does not impact the bas h The reviewer assuwd that no relief free for the staff granting this test requirement we4 requested.

relief in the Dece d er 5, Additionally, the licensee indicated that 1991, SE. The calcuteted intet pressure is calculated from the Inlet pressure is stbtracted frees the measured disef:arge intake structure water tevel in lieu of l

pressure to obtain direct pressure measurement, but the relief request did not address differentist prwsure, es differer.tiet pressure, which should have discussed in the 12/91 SE been included if this test parameter is

• Evetuation" sec' ion for J -ot directly measured.

this relief request. No iiurther action is requird.

5.2 In diesel fuet oil punp relief rec vest The rette? request has baen mod". fled to no further action is 3.2.2, flow rate was inctwied in the delete the reference to flow rate.

reesired.

" Test Req;irement" section. No Relief fross this test parameter was not discussion of this test requirements was consic.ared part of the request.

provided in the "Besis for variance" section. The reviewer assuned retief frcus this test requirement was not regtested. -

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i TER SECTION/AAMBuhLY ORBSER DrSGIPTION GE AMORhlV/ ACTION ITDI PORTUuS KamtAL ELECitlC'S (PE) ACTION O kefp STATUE 5.3 Section 4.5 of the Trojan IST Program PGE is evaluating c*.sck vehes which PGE should complete the

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stated that check valves which are

. sere classified as " Passive" to evaluation and make the i

normally open during power operation ard determine if any a* these salve need to

- v iste changes to the j

remain open during an accident are change positior to futfitt a safeti -

ajan IST Program. The N?C

" Passive

• valves and exenpt by Section related ?metion. This evatuntion is setsiders that check valves, XI, Paragraph IW-1200(a). Generetty, schedateo to be conoteted tn 12/31/92.

ar other automatic valves check valves cannot be exenpted from designed to close (or inservice testing requirements on the reopen) eithout operator basis provided in Section 4.5.

The action tottowing an l

ticansee was requested to evaluate if accident, are active devices j

there is any mode of operation including and should be classified as cold shutdown, where the cheik valve is

" Active" valves in the IST reqi red to close or is closv4 'md is progrge tmtess the flow is l

required to open to fulfiti a safety-block d.

related ftmetion (e.g., the reactor i.

coolant ptsup seat stgpty check valves, 1

836 & D, may be required to close to l

1 provide containment isolation).

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SA The Trojan IST Program valve stasaary PGE has revised the suminary listing The valve list still does

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• ! sting table, Table 4.1-1, did not table to include the normal position for not clarify tle exercise fruficate which direction check valves are each valve. The exercise direction is direction specificatty. The exe cised. Irttuding the exercise asusned to be the opposite of the normal NEC is preparing a doctmumt direction of check valves in the IST direction.

to provide guloetines on l

Program was reconenended.

Information that should be included in IST programs.

The licensee shw!d review the valve list against these guidelines when issued.

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5.5 Containment M r cooler automatic valves, PGE changed the system operation as No further action is i

AV-021 throu3h -C36, on pipirv3 and described in the FSAR for-these vatwes.

required.

j instrtsment diagram M-215, Sheet 3, were ermetty open manust valves testream of not included in the IST program valve vdves AV-021 through -036 are now strenary tisting. These valves open to

.* ntained as normatty closed valves.

4.

prevent air binding in the contairunent Therefore, valves AV-021 through -036 air water colts per the FSAR. The are not required to be in the IST ticensee was requested to evaluate program because they have no safety q

including these valves in the IST ftmetien to change positiers Program.

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i TER SECTIGI/AIItBELY M5GER DESmiPTim GN AfstBIALY/ACT10il ITEM PWTLAIB EEaERAL ELECTgIC'S (FM) ACTim ORAEST STAME

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5.6 The tsi program included exercising Normat ty closed manual watwes wstream No further action is l

1 valves CC-2001 through -2032 in the of valves CC-2001 through -2032 allowed regaired.

j closed direction only. These valves removal cf these valves from the IST j

j a m ear to perform a safety-related program. By maintaining tre manuet l

i ftaMtion to open to attow venting the valves closed, valves CC-2001 through -

e containment cooter colts. The licensee 2032 no longer have a safety-related was reques%f to consider exercising ftriction, and are no longer stbject to 4

these valves in the open direction. The inservice testing requirements.

j closure function was the subject of Relief Request M215f to utilize a teskage i

test to verify the closure capability.

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5.7 Tabte 4.1-1 of the IST Program includes a The reference has been corrected in No further action is tegend for the abbreviations. The test Tabte 4.1-1.

required.

o frequency "T" inc>rrectly referenced j

Section XI, Paragrardi IW-3311. The correct reference f 7 the test freg;ency for safety and retb f valves is Paragraph 1

IW-3511.

t 5.8 For Relief ReqJest M201f, interim relief PCE determined that these valves should The tfc nsee has taken I

was granted for one year or until the end be Category A/C. Ar: evaluation is acti'n to address the of the next refueling outage, whichever e derwa* to determine if a single valve provisions of the interim j

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is longer, following issuance of the SE.

can % used as the isolation botsidery retlef for declaring both r

Relief was for testing the PORV air for the seismic category Il portion of valves in @ erable and taking I

supply check valves in series. The the instrtsient air systee, or if corrective actions if leakage testing of a pair of valves to individual testing of the valves is excessive teakoge is verify closure was indicated to be required to meet safety analysis identified. The evaluation acceptable provided both valves be asstantions. The evaluation will be to address the safety i

i declared inoperable if the acceptance completed prior to starttp from the 1993 analysis laplications for a criteria was not met and corrective refueling cutage. The results of this single valve versus two i

vtions taken for both valvee. The evaluation may require revision of the series watves functioning as relief was not granted for the long-teria relief request.

the seismic bnedary wilt cased on the categorization of the valves determine the long-ters

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as Category C.

It appears that these Relief Request M201F was revised to testing requirements. This valves have a function to close and reflect the prov:.' ions to declare both evaluation is to be i

l remain teek-tight to prevent teakage valves ino grabic,i excessive leakage completed prict to startte j

which cou'd compromise the operation of i*. Identisied and u pair ce reptete both from the 1993 refueling the PORVs. The licensee was requested to series valves.

outage. TN Interim relief assess the c C egorization of the these will also expire et that valves.

time.

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TER SECTIm/alet4LY N KSCRIPTim ou AllonALY/ACTim ITEM PWTLAIB gDERAL ELECTRIC'S (PE) ACTim GMAEST STAftB i

l 5.9 valve 8958 is required to close to The categorization of Velve 8958 was The actions teAten to l

prevent beckflow from the residual hea*

revCewed and has been changed to recategorize vatve 8958 and l

removat suction header to the refueling Category A/C. Relief Regsest M205G, to initiate closure water storage tank (RWST). gecause back which addresses relief from futt-stroke verification during col.d i

teeks i into the RWST could effect the opening the valves quarterly (granted in

' ehutdowns e4 dresses the offsite does anstysis as the RWST is a 12/5/91 SE to exercise at refueling concerns of this snomety.

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vented tank, the Licensee was requasted outage fregaency) has been revised te

{Nofurthe?actlAtis to essess whether the categoritation of specify that the vol w is ene%ised required. The relief this valve is correct (Category C in the clossi on a cold s b t 6 n frequency le=

previously granted for the i.

IST Program). Additionally, the valve accordance with the Code required opening test ff w was should be backflow tested quarterly in frequency.

(unaffectedbytheaddition I

accordance with GL 89-04, Position 3.

j of the closure test 1 frequency and, therefore, cemains approved.

t 3.10 For Relief Request M208A, interim relief Leekage testing of each pair of check the licensee has taken was granted for one year or until the end valves has been implemmted to action to address the of the next refueling outage, whichever incorporate the provisi vi of the interim provisions of the interim is longer, fotLowing issuance of the SE.

retlef approved in the SE. The valves retlef. The evetuation to The licensee proposed verifying the have been determined to be Category A/C.

address the safety onetysis closure capability of the turbine-driven PGE is evetusting if a single valve con implications for a single euxitlery feedwater pw p steam supply be used as the isolation bourtiery for vetve versus two series l

valve's air sigply check volves during the seismic category il portion of the velves functioning es the 3

the pw p operability test. White this instrument air system, v if individuet seismic boisidery wilt i

testing verifies puup operability, it testing of the valves is required. This determine the long-ters does not adequately assess the capability evaluation will be completed prior to testing regJire==nts. This i

of the volves to perform their closed startte f rom the 1993 refueling outage.

evetuation is to be safety ftsiction. The interim relief was completed prior to startup i

i granted provided the licensee perform from tSe 1993 refueling I

leekoge tests of each pair of check outage. The interim relief i

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vetves. Additionetty, the valves are will also expire at that J

i categorized as Category C.

Leekage past time.

these check valves cog d compromise the 1

i operation of TSe steam-driven auxitlary

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feedwater pw p.

The licensee was j

requested to review the categorization of these valves and to provide information on indiwIduetty Ieek testing requirements i

for meeting the safety analysis.

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TER SECTIOC/ANOMRLY NL9BER DESGIFTION ON A800MALY/ACTIGI ITDI PORTLAaB EMERAL ELECTRIC'S (PE) ACTION ORWEWT STAft:5 5.11 For Retief Reque*t 3.2.1, relief was The calculation for determining intet The licensee should use the I

granted to calculate the intet pressure pressure was proceduralized and verified requirements of OM-6 in the of the service water prps based on the to meet the Code acetr acy requirements.

Jetermination of the intake structu-e water levet in lieu of Vibration measurements will be in tocation of the vibration measuring the pressure. The relief velocity units rather than in applitta3e pointa for these psps. T!.e approval was provisional on the licensee tsiits as described in Relief Regtsest concerna of this anomaty procedaratizing the calculation and 3.2.8 which was previously granted.

have otherwise been verifying that Code accuracy requirements Investigation of the location of the ackfressed.

for pressure are met. Additionstly, the a.rast:rements (motor bearing versus psp relief requet included monitorir 3 pump bearing) is being investigated and will Ator bearing vibra' ion in lieu of ;msp be conplete by 12/31/92.

bearing v;bration. The licensee was requested to review meas Mrag vibration veloc8ty in lieu of aeptitude.

5.12 For the diesel fuel ot t pep ret te; The intet pressure calculatterr. have The concerns of this anomaly request, RR 3.2.1, the titensee proposed been proceduraliz W and verified to meet have been addressed. No calculating punp intet pressure based on tode accuracy requirements. A further action is required.

storage tank levet. These peps are maintenance and spare parts progrars has.

sihmerged in the dieset fuel oit storage been established for the prps, tank. Relief was also requested from requiring prp l' earing inspen: tion and measuring the p m bearing vibration and maintenance whenever the bearings are tewperature and observing tubricant tevet accessible (te dt drained).

or pressure. Relief was granted provided the intet pressure calculation be proceduralized and the Code accuracy requirements met, and that the licensee institute a minte.iance and spare parts prograre that includes provisions to inspection the purp bearings and perfona maintenance at a minirun every time the dieset fuel oit storage tank is drained and the bearings are accessible.

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TER SECTION/ANWut!LY WINEER DE30tIPfl0B ON ANDRALY/ ACTION ITEM PORTUMS GENERAI ELECTRIC'S (ME) ACT9eN (NMENT 574145 5.13 Interim relief was granted for one year Ptsp specific curves utit be developed The relief request enast be J

or natit the next refueling outage, prior to starttp from the 1993 refueling revised and stdsnitted prior i

whichever is longer, from the date of the outage.

00 startup from the 1973 i

SE, for the component cooling water refueling outage when the ptmps. The ticensee had proposed to interim relief expires. The i

establish reference vetues with respect revised relief regsest to the manufacturer's ptmp curve. The should emplain the interim relief provided a period of time impracticality of performing

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for the licensee to develop pimp specific testing in accordance with j_

curves.

the Code end describe the j

method of utilizing pump

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curves as reference values for inservice testing.

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5.14 The relief request for the component PCE determined that the pimps are not to further action is t

cooling water makeup purps contained close-cotpled at the motor-driver required.

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conflicting information on the motor-interfec:r and that there are no bearings drive arrangement. Relief wms denied, essociated with these ptamps. Therefore,

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end it was reconenended that t>e licensee there is no requirequent to monitor the i

review the motor-driver interface and condition of the pump bearings and this i

revise the relief request, if necesse 7 relief reatsest is not neces-ery.

f 5.15 Interim relief was granted for-the A ectrection curve for the clamp-ort flow No further action es instrtament occurecy requirements for instrtsments was developed ottowirg the required to ecMress the Code l

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measuring flow for the charging pimps.

Instrtaments to meet the Code accuracy requirements. The licensee 4

The occuracy of the clany-on digitet requirements. The relief request has should, however, ensure that instrtsments was 13% rather then 13 as been deleted from the IST Program f.nd, controls are in place to required by the Code. The Licensee was because the Code requirements are set, install the etenp-on

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to review their previous comunitment to no permanent instrassentation is to be instrtaments in the samme instat1 pernament instrtamentation (2/6/91 instalted.

tocetion (for each specifIe i

letter to NRC).

pamp) each time they are used to assure that results l

I are repeatable.

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TER SECTION/AN0pthtY IneER DESCRIPTl0m tw ANCMALY/ ACTION ITDI PORTLAa0 GENERAL ELECTRIC'S (PE) ACTION (IRRENT STATUS 5.?6 The licencee had requested relief for the The alternative test methods, acoustic The actions taken to address alternative testina method of verifying monitoring, have been verified to meet this ananaty are adequate.

full-stroke of the safety injection and the criteria of GL 89-04, Position 1.

The retlef request does not residual heat removat pressure isolation The relief request has bem modified to require further review, as check valves. Part-stroke exercising reflect this information.

the testing is in accordance during cold shutdown and the use of the with GL 89-04, Position 1, nonintrusive techniques to verify futL-arW meets the Code a

stroke during refueling outages is in requirements of I W -3522 as accordance with GL 89-04, Position 1, "other positive means" cf provided the techniques are qualified per verifying the disk full-the guidance delineated in Position 1.

stroke. Relief for the proposed test frequency remains as approved in the 12/5/91 SE. No further action is required.

In Relief Requests M201G, M, and I, the the provisiens of the SE have been to further action is 5.17 ticensee proposed verifying closure of incorporated into the relief request to required.

the pressurizer relief tank (PRT) primary specify that conteinment isolation maketp supply check valves, the PRT valves are test d i. accordance witr 10 nitrogen sipply check valve, and the CFR 50, Appendix J, and Section XI, emergency core cooling system pressure Paragraphs IW-3426 and IW-3427(a).

safety valves discharge header to the PRT check valve by a leak test each refueling outage. Relief was granted provided the requirements of 10 CFR 50, Amerrfin J and section xt,11 IW-3426 and IW-3427(a) are met.

5.18 The licensee had proposed to utilfre a A nonintrusive technique, acoustic Relief *o utilire the disassernbty and irspection pregrara for monitoring, has been i m temented for nonintrusive techniques at verifying full-stroke of the safety these valves on a refueling outage the frequency approved in injection accwutator discharge check f requency when the acctmJtators can be the previous SE is granted valve *, Relief was granted v ovided the partially discharged. The testing meets per GL 89-04.

The technique program was performed in accordance with the guidance delineated in CL 89-04, is considered an "other guidance delineated in GL 89-04, Position Position 1.

positive means" for 2.

verifying disk futt-stroke per IW-3522.

5.19 Relief was denied for not testing air-The test frequency for CV-4471 has been Testing on a cold shutdown operated control valve CV-4471 quarterly modified to perform testing on a cold frequency is attowed by the due to insufficient justification for shutdown frequency and is documented in Code. No further action is performing the testing at refueling a cold shutdown justification in Section required.

outages only.

M2238 of the IST Program.

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. TER SECTIW/AINEWILY EDGER KSC*lPflW W AIN3 WILY /ACTIM ITEM PORTtM MWEAL ELECTtlC'S (PE) ACT3m nessef STARE 5.20 Relief Request J781A proposed teak The test frequency of these valves has Testing on a cold shutdown f

testing the electrical penetration been changed to cold shutdown. Sections frequency is ettowed by the nitrogen manifold contairunent isolation M232A and M2328 of the IST Program Code. No further actim is 4

valves each refueling outage.

reflect this frequency in cold shutdown required.

j Justification was insufficient to not justifications.

l exercise these valves qterterly or during cold shutdowns. Relief was denied.

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5.21 The licensee indicated that a disassenbty The disassenoty and inspectiem program No further action is l

and inspection program would be meets the requirements. of Position 2 of required.

f established for contairunent spray ring of GL 89-04. The relief header check valves as desc-ibed in request has been revised to specify that t

Relief Request M207A. Relief was granted the program is in accordance with the

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provided the program be performed in guidance of Position 2.

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accordance with the guidance of GL 89-04, l

Position 2.

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Mr. James E. Cross staff's review of your responses to the twenty-one anomolies is p vided in the table attached to the enclosed SE.

This completes the staff's technical review performed under T C No. M84031.

Sincerely, Theodore R, Quay, Director Project Qirectorate V Division'of Reactor Projects III/IV/V Office 'of Nuclear Reactor Regulation

Enclosure:

Safety Evaluation w/ Table of Anomalies /

Action Items attachment cc w/ enclose e:

See next page QlSlftlBUTION:

Docket File NRC & Local PDRs PDV r/f JRoo MVirgilio TQuay DFoster LKokajko OGC (15818)

ACRS (10)(P3151 PDV p/f PCampball, 7E23 KPerkins, RV 45

///d<

PD[/LA.

//

PDV/[M OGC kh PDV/D OFC:

NAME:

[ Foster b

' hkajko:mc 7 /h/

TQuay DATE:

/l/k/92

'N /10/92

// // 3/92

/ /92 0FFlCIAL ECORD COPY DOCUMENT hAME:

TJ84031.SE

.