BECO-92-131, Forwards Rev 4 to Pilgrim Nuclear Power Station Procedure 8.I.1.1, Inservice Pump & Valve Testing Program. Program Addresses Anomalies Indentified in Pump & Valve Inservice Testing Program TER
| ML20127N262 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 11/25/1992 |
| From: | Richard Anderson BOSTON EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20127N264 | List: |
| References | |
| BECO-92-131, NUDOCS 9212010134 | |
| Download: ML20127N262 (7) | |
Text
..__r.--
h BOSTON EDISON Pagnm NuJear Power Station Rocky Hill Road Phmouth, Massachusetts 02360
_~
Roy A. Anderson Senior Vice Piesdent - Nscleat November 25, 1992 BECo 92-131 U. S. Nuclear Regulatory Commission 4
Document Control Desk Washington, DC 2rT55 License DPR-35 Docket 50-293 Pilgrim Nuclear Power Station Inservice Test P g. gram t
Boston Edison Company has revised the Pilgrim Nuclear Power Station Inservice Test (IST) Program as required by 10CFR50.55(a)(f)(4)(ii) for the third 10 year interval starting December 10, 1992.
Our revised IST Program is enclosed and complies with the 1986 Edition of the ASME Boiler and Pressure Vessel
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Code,Section XI requirements with the following exception: The 1987 Edition of the ASME Code for Operation and Maintenance of Nuclear Power Plants (0M-1) will be used in lieu of the 1981 Edition presently specified in the 1986
};
Edition of the ASME B&PV Code Section XI.
The 1987 version corrects and clarifies numbering nomenclature anomalies found in the 1981 Edition.
Use of portions of later approved editions of the ASME B&PV Code is allowed by f
10CFR50.55(a)(f)(4)(1v).
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Where we have determined that conformance to certain code requirements is
(
impractical for our facility we have included Relief Requests and Cold Shutdown Justifications in the IST Program. A summary of IST Program Relief Requests and Cold Shutdown Justifications is enclosed as Attachment A to this letter. For the relief requests and cold shutdown justifications previously i.
reviewed in the NRC Safety Evaluation Report (SER) dated April 22,1991,(TAC No. 74785) for the current PNPS IST program, the summary identifies if the al relief / justification has been revised, retractea or left unchanged.
For new reliefs / justifications, a description is provided detailing the reason.
The revised IST Program addresses anomalies identified in the Pump and Valve U
Inser' rice Testing Program Technical Evaluation Report and meets tne above L
refe m ced Safety Evaluation Report requirements.
To ?'.;able full implementation of the revised program, we are requesting a
" priority" review for Cold Shutdown Justification CS-17 and Relief Requests RV-25, RV-37, RV-38, RV-39, RV-40 and RV-41.
Relief Request RV-25 was reviewed, evaluated, and approved by the NRC for interim use through our i
second ten year interval IST program. During this interim use period, we were to oavelop a method to comply with the code requirements. We have chosen to I
repla:e these valves with a testable type of valve in Refueling Outage 9
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(April 1993) and, therefore, require an extension of the approval until this v
9212010134 921125 Mh DR ADOCK 0500 3'
)
1 BOSTON EDIS0N COMPANY U.-S. Nuclear Regulatory Commission Page 2 time.
Relief Requests RV-37 and RV-38 were required by the Technical Evaluation-Report to resolve ancmaly 19.
Relief / Justification Requests CS-17, RV-39, RV-40 and RV-41 are new and have not been evaluated in the Safety Evaluation Report.
Relief Requests RV-18, RV'26, and RV-31, were approved by the SER for interim use through the second ten year interval while we resolved identified concerns. We have resolved the SER concerns, conformed to the requirements of the SER and consider use of these relief requests acceptable for interim use during the third ten year interval; however, formal review and concurrence is required.
In conclusion, the PNPS IST Program addresses the program anomalies identified in the Technical Evaluation Report and meets the Safety Evaluation Report requirements. Where we determined compliance with the Section XI requirements was impractical-for our facility, we have requested relief in our program and proposed alternate tests. A priority: review of CS-17, RV-25, RV-37, RV-38, RV-39, RV-40 and RV-41 is needed for program implementation.
In a separate submittal,(BEC0 letter 2.92.126' dated,10/30/92) we have revised our Technical Specifications to resolve conflicts between ASME Section XI Code requirements and Technical Specification Surveillance Requirements.
If there are any questions regarding this submittal, please contact the Licensing Staff.
R. A. Anderson BRS/c1c/pnpsist cc:
Mr. R. Eaton, Project Manager-Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Mail Stop:
1401 U. S. Nuclear Regulatory Commission
-1 White Flint North 11555 Rockville Pike Rockville, MD 20852 U. S. Nuc, :- Regulatory Commission Region I 475 Allendale Road King of Prussia, PA.19406 Senior NRC Resident Inspector Pilgrim Nuclear Power Station
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i ATTACHMENT-A Page 1 of 5 t
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SUMMARY
OF I J PUMP AND VALVE PROGRAM COLD SHUTDOWN i
JUSTIFICATION AND RELIEF REQUESTS STATUS RP-1 Revised, changed the Basis for Relief and Alternate Testing to conform with SER provisional requirements making this relief request j
Acceptable.
RP-2 Revised, changed Pump Listing (deleted P141A/B and separated P205 l
Main and Booster) which should not affect the Preapproved status, i
RP-3 Revised, changed the Basis for Relief to conform with SER l
provisional requirements making this relief request Acceptable.
1 RP-4 Not changed, Preapproved by GL89-04, reference SER.
RP-5 Revised, changed the Basis for Relief and Alternate Testing to-conform with SER provisional requirements making this relief request l
Acceptable,
}
RP-6 Not changed, Preapproved by GL89-04, reference SER.
RP-7 Retracted, placed the-Non-Class D0T pumps within Section 5.1[9] of l
the IST Program and deleted this relief request.
This is consistent with potitions in: NRC Letter to Mr. Rhodes,. Chairman, ASME OM Committee, dated September 9,1991, cnd Memorandom from Mr. Norberg, Chief EMEB
Subject:
Inservice Testing (IST) Relief Requests for 4
Components Outside the Scope of Section XI.
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RP-8 Revised, changed Pump Listing (deleted P141A/B and separated P205 i
Main and Booster) which should not affect the Approved status.
[
RP-9 Revised, changed Pump Listing (deleted I'141A/B and separated P205 l
Main and Booster) which should not affect the Approved status.
{
RP-10 Not changed, previous revision retracted relief request.
CS-1 Retracted, converted to relief request (RV-32) in accordance with SER to allow closeout of Anomaly No.17.
CS-2 Not changed, reviewed within SER - Acceptable.
1 CS-3 Retracted.
CS-4 Revised, changes made in Basis for Justification and Alternate Testing to allow closecut of-SER Anomaly No.19 (AP Test).
Previously-reviewed within SER - Acceptable.
3 CS-5 Retracted, converted to relief request.(RV_-33) in accordance with-SER to allow closeout of Anomaly _No.17, CS-6.
-Not changed, reviewed within SER - Acceptable.
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l ATTACHMENT A I
Page 2 of 5 1
CS-7 Revised, changes made in Basis for Justification and Alternate Testing to allow closeout of SER Anomaly No.19 (AP Test).
Previously reviewed within SER - Acceptable.
CS-8 Retracted, converted to relief request (RV-34) in accordance with SER to allow closeout of Anomaly No.17.
CS-9 Not changed, reviewed within SER - Acceptable.
CS-10 Retracted, removed va've from program per Plant Design Change (PDC 86-052).
CS-ll Not changed, reviewed within SER - Acceptable.
1 CS-12 Retracted, converted to relief request (RV-35) in accordance with SER to allow closeout of Anomaly No.17.
CS-13 Retracted, converted to relief request (RV-36) in accordance with SER to allow closeout of Anomaly No.17.
CS-14 Not changed, reviewed within SER - Acceptable.
CS-15 Not changed, reviewed within SER - Acceptable.
CS-16 Not changed, reviewed within SER - Acceptable.
CS-17 New, unreviewed Cold Shutdown Justification.
This justification is commonly used within the industry and has been approved at many plant sites.
CS-18 New, unreviewed Basis for Justification and Alternate Testing which is required to closecut SER Anomaly No. 19 (AP Test).
RV-1 Not changed, Preapproved by GL89-04, reference SER.
RV-2 Revised, changes made in Basis for Relief and Alternate Testing to allow closecut of SER Anomaly No.19 (AP Test ) - Preapproved.
RV-3 Revised, substituted refueling interval for refueling outage within basis for Relief which should not affect the Preapproved status.
RV-4 Not changed, Preapproved by GL89-04, reference SER.
RV-5 Revised, changes made in Basis for Relief and Alternate Testing to allow closecut of SER Anomaly No.19 (AP Test) - Preapproved.
RV-6 Revised, substituted refueling interval for refueling outage within Alternate Testing, which should not affect the Preapproved status.
RV-7 Not changed, Preapproved by GL89-04, reference SER.
RV-8 Revised, changed valve Category to AC and substituted refueling interval for refueling outage within Alternate Testing which should not affect the Preapproved status.
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ATTACHMENT A Page 3 of 5 RV-9 Revised, changes made in Basis for Relief and Alternate Testing that; 1) substitutes refueling interval for refueling outage,
- 2) provides additional basis information for the Scram Inlet and Outlet Valve Stroking and 3) identifies accumulator supply check valve closure testing to show compliance with SER Anomaly No.19 (AP Test) - Preapproved by GL89-04, reference SER.
RV-10 Not changed, Preapproved by GL89-04, reference SER.
RV-11 Not changed, Preapproved by GL89-04, reference SER.
RV-12 Not changed, Preapproved by GL89-04, reference SER.
RV-13 Not changed, Preapproved by GL89-04, reference SER.
RV-14 Retracted, perform local timing of valves.
RV-15 Retracted, perform local timing of valves.
RV-16 Not changed, Preapproved by GL89-04, reference SER.
RV-17 Not changed, Approved by SER.
RV-18 Revised, changes made in Basis for Relief and Alternate Testing to
- 1) identify forward flow exercising by +iming each MSIV's open stroke (not to exceed refueling interval) to conform with SER Anomaly No.13, and 2) to allow closeout of SER Anomaly No.19 (AP Test).
RV-19 Not changed, Preapproved by GL89-04, reference SER.
RV-20 Revised, substituted refueling interval for refueling outage within Basis for Helief and Alternate Testing which should not affect the Approved status.
RV-21 Revised, substituted refueling interval for refueling outage within Basis for Relief and Alternate Testing which should not affect the Approved status.
RV-22 Revised, changes made in Basis for Relief and Alternate Testing to
- 1) substitute refueling interval for refueling outage, and 2) allow closecut of SER Anomaly No.19 (AP Test).
RV-23 Not changed, Approved by SER.
RV-24 Retracted, removed valves from program per Plant Design Change (PDC 86-052).
RV-25 Revised, changed the Basis for Relief to request interim relief until Plant Design Change (PDC 91-075) can be completed (planned for RF0 #9), reference Anomaly No.14.
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4 ATTACHMENT A Page 4 of 5 RV-26 Revised, changes made in Basis for Relief and Alternate Testing to
- 1) substitute refueling interval for refueling outage, and 2) provide additional basis information to conform with SER Anomaly No.
i 10.
RV-27 Revised changes made in Basis for Relief and Alternate Testing to
- 1) substitute refueling interval for refuel outage, 2) provide additional information about valve disassembly to show compliance with SER Anomaly No. 6, and 3) allow closecut of SER Anomaly No.19 (AP Test) - Preapproved.
RV-28 Revised, clarified Alternate Testing to show compliance with SER Anomaly No. 7 - Preapproved.
RV-29 Previously Revised (Nov. 1991), deleted portions of Basis for Relief and Alternate Testing sections that were d:nied within SER Anomaly No. 8, thus Approved by SER.
RV-30 Revised,1) identified the specific applicable subparagraphs within 4
Test Requirements and Alternate Testing sections, and 2) clarified Basis for Relief to show compliance with SER Anomaly No. 9 -
1 Approved.
RV-31 Revised, changed Basis for Relief and Alternate Testing to identify stroke timing these valves using meter deflection for conformance with SER Anomaly No. 15.
RV-32 New, converted CS-01 per SER Anomaly No. 17.
Substituted refueling interval for refueling outage, and provided additional justification within the Basis for Relief which should not affect Approved status.
RV-33 New, converted CS-05 per SER Anomaly No.17.
Substituted refueling interval for refueling outage within Alternate Testing which should not affect Approved status.
RV-34 New, converted CS-08 per SER Anomaly No. 17.
Substituted refueling interval for refueling outage within Alternate Testing which should not affect Approved status.
RV-35 New, converted CS-12 per SER Anomaly No. 17. Substituted rcfueling interval for refueling outage within Alternate Testing and revised Basis for Relief and Alternate Testing to allow closeout of SER Anomaly No.19 (AP Test) - Approved.
RV-36 New, converted CS-13 per SER Anomaly No. 19.
Substituted refueling interval for refueling outage within Alternate Testing which should not cffect Approved status.
RV-37 New, unreviewed relief which implements recommendations for closure of SER Anomaly No.19 (AP Test).
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ATTACHMENT A Page 5 of 5 RV-38 New, unreviewed relief which implements closure requirements for SER Anomaly No, 19 (AP Test).
RV-39 New, unreviewed relief which allows consistency between PNPS IST Program and Technical Specification operability practices.
RV-40 New, unreviewed relief which outlines PNPS (Safety / Relief Valve Testing) policy for implementing ANSI /ASME OM 1-1987 requirements.
RV-41 New, unreviewed relief which incorporates recent industry recommendations for exercising the RHR injection check valves. Also reference SER Anomaly No. 16.
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BRS/cic/pnpsist l
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