ML20128P737
| ML20128P737 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 02/18/1993 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20128P729 | List: |
| References | |
| NUDOCS 9302250089 | |
| Download: ML20128P737 (41) | |
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NUCLEAR REGULATORY COMMISSION WA SHING TON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE INSERVICE TESTING PROGRAM RE0 VESTS FOR RtLIEE NORTHEAST NUCLEAR ENERGY COMPANY MILLSTONE NUCLEAR POWER STATION. UNIT 1 DOCKET NUMBER 50-245 1.0 INTRODUCTIQB The Code of Federal P.egulations,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 Pressere Vessel Code and applicable addenda, except where relief has been granted or proposed alternatives have been authorized by the Commission pursuant to 10 CFR 50.55a (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(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 10 CFR 50.55a(b), subject to the limitations and modifications listed, and subject to Commission approval.
NRC guidance contained in Generic Letter (GL) 89-04, Guidance on Developing Acceptable 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 the guidance delineated in the applicable position. When an alternative is proposed which is in accordance with GL 89-04 guidance and is documented in the IST program, no further evaluation is required; however, implementation of the alternative is subject to NRC inspection.
The Code of Federal Regulations, 10 CFR 50.55a, authorizes the Commission to grant relief from ASME Code requirements or to approve proposed alternatives upon making the necessary 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 Northeast Nuclear Energy Company's (NNEC0/ licensee) letter dated October 30, 1992, for the Millstone Nuclear Power Station, Unit 1, IST Program, Revision 5.
A review of the licensce's response to certain items identified in NRC SE dated January 8, 1992, was performed.
The results of this review are provided in Table 1, Table of Anomalies and Action Items in NRC Safety Evaluation Dated January 8, 1992.
The new or revised relief requests which were included in the submittals are evaluated below.
9302250009 930218 PDR ADOCK 05000245 P
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,. The Millstone Unit 1 IST Program was developed to the requirements of OM-6, Inservice Te2 ting of Pumps in Light-Water Nuclear Power Plants, and OH-10, inservice Testing of Valves in Light-Water Nuclear Power Plants, which were incorporated into 10 CFR 50.55a(b), through the_1989 Edition of Section XI, by-rulemaking effective September 8, 1992.
The staff approves the use of_0M-6 and OM-10, with modifications to 0M-10 rc'ated to containment isolation valve leakage testing.
The IST Program is for the third ten-year interval which began August 15, 1991, following the extension of the second ten-year interval program from December 7.8. 1990, to startup from the 1991 refueling outage.
Several relief requests include discussion of schedules for future modifications.
Refueling Outage 14 is scheduled for January 1994, and Refueling Outage 15 is scheduled for 1996.
In relief requests which discuss modifications to be completed in these refueling outages, where relief is granted for implementation of testing ir, accordanco with the modifications, the relief becomes effective upon completion, or at startup from the refueling outage.
In the interim, the licensee's inservice testing.is to be performed in accordance with current testing procedures-for these specific relief.
requests.
The licensee has indicated in their submittal that the implementing procedures for Revision 5 of the inservice testing program are being revised over the next year, with final completion scheduled for the 1994 refueling outage.
The staff recognizes that procedural development involves an extensive effort that requires a period of time to complete and that several tests are based on a refueling outage schedule; however, it is expected that this effort will be accompiished in a timely manner over the period of development, and that the tests performed on a refueling outage schedule will be conducted during the 1994 refueling outage.
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2.0 PUMP REUEF RE00ESTS A total of eight relief requests for pumps are included.in the revised inservice testing program.
Each of these are evaluated separately-below-in accordance with the requirements of OM-b.
The requirements for inservice testing were not in effect when Millstone Unit I was constructed (Construction Permit date May 19,1966), and therefore, design features-to enable testing were not provided as later required by 10 CFR 50.55a.
Because the NRC has determined that flow measurement is required for inservice testing of pumps-and that long-term relief is not appropriate (reference GL 89-04, Position 9),
the previous SE discussed the lack of flow instrumentation 'for the pumps subject to inservice testing. The licensee has made an attempt to address the concerns through testing during refueling outages when individual pump flows-can be measured, using temporary flow instrumentation, and using' instrumentation which does not meet the accuracy and/or full-scale range-requirements due to limitations in design features. The relief requests related to flow instrumentation have been evaluated with consideration of these design limitations and the limitations associated with modifications to existing systems.
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2.1-fLt. lief Reauest R-1 l
Relief from the requirements of OM-6, Section 5.1., to_ perfotm inservice -
testing of the-service water pumps (M4-7C and M4-70) and-feedwater coolant injection.(FWCI) condensate pumps (M2-6A, M2-68, M2-7AL M2-78) nominally every-3 months is requested.
Based 'on the status of.available flow instrumentation, the. pumps will be monitored quarterly without-~ individual flow measurement, and-r:
tested during refueling outages with flow measurements' recorded.
2.1.1 Licensee's Basis for Relief The licensee states:
N Individual pump flow -instrumentation is not installed. _ The; required length of straight pipe without obstructions (approximately-10 diametersL
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upstream and 5 diameters downstream) to obtain an accurate flow =
measurement and comply with OH-6, Paragraph 4.6.1.1, is not. available'on individual lines on the-suction or discharge' side of each pump.
There-is a flow element on the condensate =line which'is a commonLline=
for all 3 pumps downstream of:the steam packing exhauster. _- All;3 condensate pumps and 'at' least 2 of 3 conden. sate booster pumps are.
required for operation at 100% power.
The condensate pumps are also operated as necessary during_ cold shutdown to maintain reactor vessel
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water level.
The condensate booster pumps' fuses are pulled to prevent-a feedwater pump start-for reactor vessel overpressurization protection.
in case of a FWCI initiation signal during cold shutdown.-Therefore, individual. flow measurement is-not' possible during power operation or cold shutdown.
During normal operation-at:least'2 service water pumps are-required to operate to maintain heat. load. This means -that measurement:of single pump flowrato -is not possible during plant operation using the strainer 1 bypass line.
Flow instrumentation is installed cn-the strainer bypass.
line (common to all 4 service water pumps). This: path was determined to-be the-only path practical for flow measurement; however, it can only be--
used at refuel-when heat load can be minimized-to allow single-pump-operation..:
2.1.2 Alternative Testino L
The licensee proposes:
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Pump differential pressure and vibration will'be recorded on a quarterly-basis.
These quarterly. measurements will be analyzed and compared.to reference values _per OM-6.
Due to_the varying Service Water system conditions, an expanded allowable range will:be-used for evaluating differential pressure dering'~ quarterly testing.
Past experience.has proven _ these owner specified ranges still allow for early'detectioniof-1 pump degradation.
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, Each pump will be individually tested during every reactor refueling outage.
Individual pump flow, differential pressure, and vibration will be recorded.
Either pump flow or pump discharge pressure will be throttled to a reference value as' close as practical to the value that -
each pump is expected to achieve during operation.
For the condensate pumps (M?-6 A/B), the flow element on the 16-inch minimum flow line downstream of the Steam Jet Air Ejectors will be used to throttle to a-known reference value to measure flow.
For the condensate booster pumps (M2-7 A/B), the flow will be throttled to a known reference value and the suction flow will be measured using the flow element downstream of the steam packing exhauster.
This testing will be performed when the pumps are known to be operating acceptably.
The allowable percentage changes in measured values identified in OH-6, Table 38,- will be used to evaluate the condition of each pump tested.
2.1.3 Evaluation The basis for relief addresses the quarterly versus refueling outage testing and tne alternative testing addresses using an expanded allowable range for differential pressure during quarterly testing. The intent of inservice testing per 0M-6 is to assess the operational readiness of pumps and to monitor for degrading conditions. The NRC indicated the importance of monitoring buh differential pressure and flow rate to determine pump hydraulic performance in GL 89-04, Position 9, " Pump Testing Using Minimum-Flow Return Line With or Without Flow Measuring Devices." Based on the early construction of Millstone 1, design features for measuring individual pump flow to enable quarterly inservice testing were not provided for the service water pumps and the feedwater coolant injection (condensate) pumps.
Service Water Pumos: The only available instrumented flow path for testing the service water pumps is the strainer bypass line.- Testing with flowrate measurement must be conducted during refueling outages when the plant heat loads are low enough to allow single pump operation. Therefore, based on design limitations, it is impractical' to measure flow during testing performed quarterly.
Individual pump testing.is impractical during cold shutdown due to plant heat load considerations.
The testing performed quarterly will evaluate the condition of the pumps based on differential pressure and vibration.
Vibration data fill provide information on the mechanical condition of the.
pumps, which may be indicative of degradating conditions prior to indications in the hydraulic parameters. The licensee indicates that the expanded range for. differential pressure will "still allow for early detection of pump degradation." Expansion of the range during quarterly testing is necessary -
because the service water system conditions vary depending on plant heat load conditions. Additionally, the four service water pumps discharge into a common supply header, possibly having an impact on the discharge pressure of a single pump, depending on the number of pumps running when the measurement is taken.
Degradation in the hydraulic conditions could be masked in this manner; however, by performing testing that conforms to the requirements of OM-6, other than the frequency, during refueling outages, the hydraulic conditions of the pumps can be monitored.
Imposition of the requirements to i
. measure flowrate quarterly in accordt.nce with OM-6 would be a burden on the licensee in that installation of flow instrumentation in the individual ~
service water lines from the pumps to the common supply header could not be effected without major modifications to the piping system. The proposed testing quarterly monitors the mechanical condition of the. pumps,- and the hydraulic conditions to a more limited extent.
The proposed testing dur' g refueling outages provides an assessment of the overall condition of.the pumps. Therefore, granting relief is appropriate.
f_qedwater Coolant in.iection (Condensate) Pumos: The condensate pumps and condensate booster pumps operate in a normal mode during-power operation to provide condensate to the suction of the reactor feedwater pumps. The 'A' and
'B' condensate pumps and condensate booster pumps also perform a -safety-related function to inject coolant into the reactor vessel in the event of a design basis loss of coolant accident.
Individual ~ pump flowrate measurement is impractical during power operations because the flow element in the condensate line measures total condensate flow. During cold shutdown conditions, the condensate pumps operate to maintain reactor vessel level and the condensate booster pumps are electrically prohibited from operating-for overpressurization protection of the reactor vessel; therefore, testing with flow measurement is impractical during cold shutdown. The inservice testing for these pumps will consist of quarterly testing which' monitors differential pressure and vibration, and testing conducted during refueling outages which conforms to OM-6 requirements, other than frequency and flowrate instrument accuracy (see R-2 below). Vibration data will provide information on the-mechanical condition of the pumps, which may be indicative of degradation conditions prior to indications in the hydraulic parameters.
By performing testing that conforms to the requirements of OM-6, other than-the frequency, during refueling outages, the hydraulic conditions of the pumps can be monitored.
Imposition of the requirements to measure-flowrate quarterly.in accordance with OM-6 would be a burden on the licensee -in that installation of flow instrumentation in the individual condensate lines from the pumps to the common line could not be effected without major modifications to the piping system. The proposed testing quarterly monitors the mechanical condition of the pumps, and the hydraulic conditions to a more limited extent. The proposed testing during refueling outages provides an assessment of the overall condition of the pumps. Therefore, granting relief is appropriate.
2.1.4 Concl0sion Relief is granted pursuant to 10 CFR 50.55a(f)(6)(i) based on the impracticality of performing testing in accordance with Code requirements, and in consideration of the burden on the licensee if the Code requirements were j
imposed on the facility.
2.2 Relief Recuest R-2 l
Relief from the requirements of OM-6, Section 4.6.1.1, for instrument accuracy I
of 2% for the flow measurement instrumentation for use in inservice testing l
the feedwater coolant injection pumps M2-6/7/10A and M2-6/7/108, is requested.
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I 2.2.1 Licensee's Basis for Relief The licensee states:
The flow measurement equipment configuration currently installed has 1
analog indicators and does not allow for a loop accuracy of 2%. The current loop accuracy is between 3
'5%.
However, during the cycle 14 RF0 (refueling outage), MP1 [ Millstone Plant, Unit 1) is performing control room design reconstruction which will replace the feedwater instrumentation (FIS-2-1, FIS-2-2, FIS-2-3) with digital flow-indicators =
with 0.25% accuracy which will increase the loop accuracy to less than 3%. This accuracy is not significantly outside the code limit of 2% and will provide repeatable test results to facilitate detection of pump degradation, MP1 is proposing to install similar flow instrumentation for the condensate and condensate booster pumps (FI-2-4A and 4B).
2.2.2 Alternative Testino The licensee proposes:
Use existing instrumentation with an accuracy of 3 - 5% until the digital equipment installation is completed during the cycle 15 RFO.
Use upgraded flow measurement equipment with an accuracy of = 2.9% once installed.
2.2.3 [ valuation The intent of the Code requirements on instrument accuracy is to ensure that, accurate test data is obtained that is representative of actual pump operating conditions so that a meaningful evaluation of pump performance can_ be made.
The instrument accuracies specified in OM-6 are based on a percentage of full-scale for individual analog instruments and over the calibrated range for digital instruments.
In cases where an instrumentation loop consisting of a combination of analog instruments is used, the accuracy should be interpreted to be the loop accuracy, which represents the accuracy of the final measured
-As clarified in OM Code Interpretation (IN) 91-value obtained from the loop.
3, issued May 14, 1991, the accuracy requirements apply-only to the calibration of the instruments, and that attributes such as orifice plate tolerances, tap locations, and process temperatures are not to be included in-the determination of loop accuracy. The licensee should review the loop accuracy, or the calibrated range for the digital -instruments, in consideration of this guidance and determine if relief is required, An interim period of time is necessary for the licensee to: determine if the t
j loop accuracy is correctly stated, or if the accuracy stated in the relief request includes attributes associated with the instrument loop that are not subject to' calibration (0M IN 91-3). Once this determination is performed,-
the relief request should be deleted, if appropriate, or revised to-indicate the correct loop accuracy.
If the accuracy remains 2.9%, the licensee-should determine if meaningful results can be obtained, and if necessary, adjust the l-
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- e. acceptance criteria to account for the inaccuracies.
This information should be included in the revised relief request, if necessary.
2.2.4 Conclusion Relief cannot be granted based on the information provided.
The licensee should continue testing in accordance with the inservice testing currently-established for these pumps and address the instrumentation loop accuracy as discussed. The results of the determination should be provided to the NRC.
within 6 months of the date of this SE, either in a letter or in. a revised relief request, depetiding on the results. This remains an open item.
2.3 Relief Reouest R-3 Relief from the instrument accuracy requirements (2%) of OM-6, Section 4.6.1.1, for the service water flow measurement, is requested.
2.3.1 Licensee's Basis for Relief The licensee states:
The required length of straight pipe without obstructions (approximately 10 diameters upstream and 5 diameters downstream) to obtain an accurate flow measurement and comply with OH-6, paragraph 4.6.1.1, is not available on individual lines on the suction or discharge side of cach pump. Millstone is installing flow instrumentation on a commor, downstream header in the strainer bypass line.
The accuracy of the flow measurement equipment cannoi.-be verified to be within 2% using the annubar being installed.
Expected accuracy is between 3 - 5%.
?.3.2 Alternative Testino-The licensee proposes no alternative testing.
Instrumentation with an installed accuracy of 3 - 5% will be used for flow measurement.
2.3.3 Evaluation The description of the modification appears to indicate that the accuracy of the annubar is included in the accuracy determination for the. entire loop.
The intent of the Code requirements on instrument. accuracy is to ensure that accurate test data is obtained that is representative of actual pump operating conditions so that a meaningful evaluation of pump performance can be made.
The instrument accuracles specified in OM-6 are based on a percentage of full-scale for individual analog instruments and over.the calibrated range for digital instruments.
In cases where an instrumentation loop consisting of a combination of analog instruments is used, the accuracy should be interpreted to be the loop accuracy, which represents the accuracy of the final measured value obtained from the loop. As clarified in OM Code Interpretation (IN) 91-3, issued May 14, 1991, the accuracy requirements apply only to the I
calibration of the instruments, and that attributes such as orifice plate
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tolerances, tap locations, and process temperatures are not to be included in l
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. the determination of loop accuracy.
The licensee-should review the loop accuracy, or the c'alibrated range for the digital instruments, in consideration of this guidance and determine if relief is required.
Currently, the service water pumps, M4-7C/D, are covered under Relief Request R-1 (see Section 2.1 above) to test with flowrate measurement' during refueling outages using the strainer bypass line flow instrumentation.
It appears that R-3 applies to both the current testing and to the testing following modifications scheduled for 1994 (the modification' schedule was ~ provided in the licensee's submittal). Therefore, an interim period of time is necessary for the licensee to determine if the loop accuracy is correctly stated, or if the accuracy stated in the relief request includes attributes associated-with the instrument loop that are not subject to calibration (OM IN 91-3). Once this determination is performed, the relief request should be deleted, if appropriate, or revised to indicate the correct loop accuracy.
If the accuracy remains between 3% and 5%, the licensee should determine if meaningful results can be obtained, and if necessary, adjust the acceptance criteria tc account for the inaccuracies. This information should be included in the revised relief request, if necessary, 2.3.4 Conclusion Relief cannot be granted based on the information provided.
The-licensee should continue testing in accordance with the inservice testing currently established for 'these pumps and address the instrumentation loop accuracy as discussed.
The results of.the determination should-be provided to the NRC within 6 months of the date of this SE, either in a letter or in a revised relief request, depending on the results.
This remains an open item.
2.4 Relief Reouest R-4 Relief from the instrument accuracy requirements (2%).of OM-6, Section 4.6.1.1, for the gas turbine fuel forwarding pumps and turbine building secondary closed cooling water pumps is requested.
2.4.1 Licensee's Basis for Relief The licensee states:
HPl was not designed with the allowance to perform accurate aump flow measurement in many cases.
This means that frequent-piping
- sends, component interferences, etc., exist which reduce the effectiveness of installed flow instrumentation' to -an accuracy of as much as 5% of full scale. Until permanent flow instrumentation is installed, HP1 will use -
portable flow measurement equipment. The repeatability and. accuracy of this equipment may not be within 2% accuracy.
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l 2.4.2 Alternative Testino The licensee-proposes:
Portable measurement instrumentation will be calibrated using a mockup; to reflect the material and configuration to the extent practicable.
Accuracy is expected to be within i 5X..
2.4.3 Evaluation
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Currently, no installed flow instrumentation is available for the subjects pumps.
The use of portable instrumentation is'neeessary to achieve. flowrate-measurement data during inservice testing until such time that the: permanent flow instrumentation installation is completed during the 1996 refueling-outage (the schedule for modifications was provided in the licensee's submittal).
Temporary flow measurement devices can, provide-accurate Land ?
repeatable results; however, these results can:be-affected by the-piping configuration. When an appropriate length of straight pipe is not available, as is the case-at Millstone 1, the accuracy and. repeatability will not_be-within the Code requirements. Therefore, it is. impractical to conform withi.
the requirements due to limitations of'the design of these. systems,;and may be impractical following installation of_ permanent instrumentation-unless the-modification includes piping changes as well.
Immediate~ imposition of the Code requirements 'would be a burden on the licensee in that a plant shutdown may. result until flow instrumentation could be installed which conforms with the Code, or as described in:a.later relief request ~ submittal. Additionally, with the current-piping configuration, major modifications may be' required to meet the requirements.for accuracy.
Based on the impracticality of meeting the Code requirements'without permanent =
flow instrumentation, interim relief is appropriate until the instal _lation is-complete.
In the interim, the licensee should ensure that the temporary flow _
instrumentation is used in a manner that achieves.the minimum inaccuracy:
(i.e.,-ensuring placement in the same location each test, locating'the best run of piping for stable flow, etc.) in accordance with 0M-6, Section ~4',6.1.3,
" Instrument. Location."
2.4.4 Conclusion Interim relief is granted pursuant to 10 CFR 50.55a(f)('6)(1) based on the impracticality of performing testing is accordance with Code requirements, and:
in consideration of the burden on the licensee -if-the Code requirements were imposed on.the_ facility. The. interim period expires upon installation of:the
- permanent flow. instrumentation during the 1996 refueling. outage.
2.5 Relief Reouest R-5 Relief from the requirements of _0M-6, Section 4.6.5, to measure _ flow using a rate or quantity meter. installed in the pump test circuit, is recuested for-the diesel generator fuel forwarding pumps and the standby liquic control (SBLC) pumps.
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- ;. 2.5.1 Licensee's Basis for Relief The licensee states
Diesel Generator Fuel Forwarding and the Standby Liquid Control systems have no installed flow instrumentation. A test tank (M8-57) is installed in the SBLC system which allows for the injection of-demineralized water into the storage tank.. During the operability test,-
the selected pump takes a suction from the test tank and discharges into the storage tank. The fuel forwarding pumps pump diesel = fuel from the storage tank (M8-19) directly to the day tank (M8-30). Tank. level is monitored over time to determine flowrate. The test results are compared to a previously established reference value in accordance with OM-6, Section 6.1.
2.5.2 Alternative Testina The licensee proposes:
Perform calculation using tank level change to determine flowrate during~
system quarterly operability surveillance test.
2.5.3 fyaluation OM-6, Section 4.6.5, " Flow Rate Measurement," states the following:-'When measuring flow rate, use a rate or quantity meter installed in the pump. test ci rct.i t.
If a meter does not indicate the flow rate directly, the record shall include the mtthod used to reduce the data.
If the licensee: determines that the measurement of tank level over the period of test performance _ meets' the requirements for "a rate or quantity meter. installed in the pump test circuit," and the test procedure includes the method-used to reduce the data.
for calculation of flowrate, relief is not required.
If these. requirements cannot be met, the staff has determined that the use of a tank level to-calculate flowrate is an acceptable alternative to the Code, provided the calculated results meet the accuracy requirements of OM-6, ensuring.an acceptable level of quality and safety 2.5.4 Conclusion The proposed alternative to the Code requirements is authorized pursuant to.10 CFR 50.55a(a)(3)(1) based on the alternative providing an acceptable level. of quality and safety, if the licensee determines that the alternative meets the requirements of OM-6 Section 4.6.5, this relief request may be deleted, provided the method of reducing the data obtained from the level instrument (s)-
is included in the test procedure.
2.6 Relief Reouest R-6 Relief from the requirements of OM-6, Section 6.1, to evaluate deviations in test parameters using the limits given in Table 3 of OM-6, is requested _for-the diesel generator fuel forwarding pumps and the gas turbine fuel forwarding
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- ;' pumps As an alternative for these low flow, low head pumps, the licensee proposes to'use whole units rather than fractional units based _ on percentages of the reference values.
2.6.1 Licensee's Basis for Relief The licensee states:
Both systems are fixed resistance system; therefore, flow and pressure ~
are measured and compared to their respective reference values.
Due to the small absolute value of these numbers, the code allowed ranges for determining a component as being either in alert or' required action are a fractional value of l psi or 1 gpm. Deviations of less that I unit of measure are not necessarily indicative 'of pump degradation and could result in unnecessarily declaring safety systems inoperables Millstone proposes to use the following more appropriate. ranges:.
Low Alert: -2 units (psi or gpm) from reference value Low Required Action: -3 units (psi or gpm) from reference value The upper required action range will remain the same.
For example, a pump with a reference flow of 30 gpm would have an alert range of 2 27 gpm to < 28 gpm rather than a Code range of 1 27.9 gpm to
< 28.5 gpm.
Past experience has proven these owner specified ranges still allow for early detection of pump degradation.
2.6.2 Alternative Testino The licensee proposes:
Use the following owner specified ranges for determining pump operability:
Low Alert Range:
reference value (Q, or Ap) -2 units _(psi or gpm)
Low Required Action: reference value (Q, or AP) -3 units (psi or
.gpm)-
2.6.3 Evaluation The Code requirements for establishing alert and required action rangestare to ensure that increased testing or required corrective _ actions are taken when pump test results indicate degrading performance.
Generally, a pump will not indicate improved performance unless modified; therefore, the upper limits are established to indicate that a problem in the test method or test instrumentation exists, rather than a degrading condition in the pump itself.
For pumps which have a narrow margin of acceptable values, such as the subject pumps, a change of less than 1 unit of flow or differential pressure may not be indicative of an actual problem.
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- . The licensee has )rovidsd no actual values, but rather used 30 gpm as an example.. While tie rounding of values to the nearest whole number would provide _ ease in calculations and in reading instruments, if the Code " alert range" requirement is within -l gpm or psi, a value'of -2 gpm or psi may not, necessarily, be adequate for monitoring these_ pumps for degradation.- More details wi'1 be required for the staff to make a determination as to the acceptability of the proposed alternative.
2.6.4 Conclusion Relief cannot be granted based on the information provided. The-licensee should. review the basis for Relief Request R-6 and resubmit a revised relief l
request within 6 months from the date of this SE, if it is determined that relief is necessary. The basis for relief should include the actual values of the most recent refer ence values for each pump. Justification that past experience indicates that the alternative values for the alert and required-action limits allows for monitoring degrading conditions must also be included. This remains an open item.
2.7 Rglief Reouest R-7 For the turbine building secondary closed cooling water (TBSCCW) pumps, relief-from the requirements of OM-6, Section 5.2, to vary the' system resistance-until either the flowrate or differential pressure equals-the reference value and compare the other, is requested. Alternatively, the licensee proposes-to utilize a reference curve to be developed during RF0 14, 2.7.1 Licensee's Basis for Relief The licensee states:
This system is a variable resistance system that cannot be' throttled '
during normal operations to a specific reference value. One pump is normally operating with the flowrate varying according to the heat load demand of the components being supplied cooling water.
Individual flow instrumentation does not exist for this system. MP1 will install -a flow.
element in the common line at the outlet of the TBSCCW heat exchanger-during the cycle 15 RF0.
2.7.2 Alternative Testino The licensee proposes:
Perform quarterly vibration and differential pressure measurements.
Develop a reference curve from at least 5 points using portable flow l
instrumentation during the cycle 14 RFO.
Perform quarterly flow measurements in the as-found condition, evaluated against the reference curve, starting with cycle 15.
Use portable instrumentation until permanent instrumentation is installed during the cycle 15 RFO.
Evaluate all measured parameters using OM-6, Table 3b ranges.
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. 2.7.3 Evaluation The staff has daterminw that wnen the flowrate varies according to heat load.
demand, making the requirements of OM-6 Section 5.2(b) impractical for the subject pumps, the use of a pump curve can be an acceptable, though not equivalent, method of monitoring for degradation. The acceptability of using; pump curves is with the following i revisions:
1)
Curves are developed, or manufacturer's pump curves are validated, when the pumps are known to be operating acceptably.
2)
The reference points used to develop or validate the curve are measured using instruments at least as accurate as required by the Code (unless specific relief is approved).
3)
Curves are based on an adequate number of poi ts, with a minimum of five.
4)
Points are beyond the " flat" portion (low flow rates) of-the curvas in a range which includes or is as close as practicable to design basis flow rates.
5)
Acceptance criteria based on the curves does not conflict with Technical Specifications or Facility Safety Analysis Report operability criteria, for flow rate and differential pressure, for the affected pumps.
6)
If vibration levels vary significantly over the range of pump conditions, a method for assigning. appropriate vibration acceptance criteria should be developed for regions of the pump curve.
7)
When the reference curve may have been affected by repair, replacement, or routine service, a new reference curve shall be determined or the previous curve revalidated by an inservice test.
Imposition of the Code requirements would be a burden on the licensee in that.
the system, as operating during normal operations, would have to be realigned to perform testing in-accordance with the Code. This realignment would affect the heat load and potentially impact the operability of various components which are cooled by the TBSCCW system. Though the use of pump curves is not considered " equivalent" to the Code required testing, it does provide an-adequate level of assurance of operational readiness of the pumps.
Additionally, if more accurate instrumentation is installed or becomes available, the applicable curve (s) must be reverified.
2.7.4 Conclusion Relief is granted pursuant to 10 CFR-50.55a(f)(6)(1) based on the impracticality of performing testing in accordance with Code requirements, and in consideration of the burden on the licensee if the Code requirements were imposed on the facility. This relief is granted with the provision that the
m 1:
licensee ensure the pump curve testing is implemented in accordance with the seven elements described above.
2.8 Relief Recuest R-8 Relief from the full-scale range requirements (not greater than 3 ' times the reference value) of OM-6, Section 4.6.1.2(a), for the pressure gauges installed for the low pressure coolant injection pumps,_ is requested.-
2.8.1 Licensge's Basis for Reliqf The licensee states:
The different system operating requirements (higher pressures under accident conditions, pump pressure when running at or near shutoff) preclude installing and using gauges that meet the OM-6 range requirement of not greater than 3 times *he reference value. The existing pressure gauges (0-400, 0-30) are the lowest-range practical for the system while avoiding the potential damage from overranging the gauge.
Gauges that exceed the range requirement but are calibrated to a tighter-tolerance (i.e.,
1% accuracy) can provide as accurate and repeatable test data as those that strictly comply to code requirements _(1.'e., 3 times ' reference value, 2% accuracy). For example, a 0-300 psig gauge with 2% accuracy has a potential error of 6.psig, whereas a 0-400 psig gauge with 1% accuracy has a potential error of only 4 psig.
2.8.2 Alternative Testina The licensee proposes:
Use gauges with the current full scale ranges.(0-400 psig, 0-30 psig) which are the lowest ranges practical for-the system while avoiding the potential for damage from overranging. The gauges will be calibrated-to a minimum accuracy of 1% of full' scale.
2.8.3 Evaluation The intent off the OM-6 requirements for full ' scale range and accuracy are to ensure repeatable results for inservice tests of-pumps.
The licensee's alternative proposal meets the intent of OM-6 by narrowing the. instrument.
accuracy to offset the increased full-scale range. Therefore, the alternative is acceptable for implementation.
2.8.4 fonclusion The proposed alternative to the Code requirements is authorized pursuant to CFR 50.55a(a)(3)(i) based on the alternative providing an acceptable level o_f quality and safety.
-C 3.0 VALVE RELIEF RE0 VESTS 3.1 Relief Reouest V-1 For emergency service water (ESW) valve 1-LPC-4A/B, the licensee requests relief from the requirements of OM-10 to measure stroke time and to verify valve remote position indicators.
3.1.2 Licensee's Basis for Relief The licensee states:
Full stroke timing and position indicator check cannot be performed because of the following:
1.
The valve will only open if an ESW pump is running.-
2.
Full opening of the valve will cause pump runout, even with 2 pumps operating.
3.
If the circuitry is defeated to permit opening the valve without a pump running, keep-fill pressure will be lost and the system-partially drained.
3,1,3 Alternative Testina The licensee proposes:
In lieu of full stroke testing, the valve will be cycled from closed to a throttled position to obtain a flow of 2,500 gpm,_ then throttled open to obtain a flow of 5,000 gpm, and-then closed.
By this manipulation of the valve from the Control Room, the inability to establish and adequately maintain the above flow rates would indicate the need for corrective action.
Position indication is verified each surveillance by observing the change in flow as the valve is positioned-from closed-(green light) to.
mid-position (red and green light) and back to closed (green light, no-flow).
Additionally, these valves are part of the MOV [ motor-operated valve]
testing program to comply with Generic letter 89-10-and will be-V0TES tested on-a schedule determined by that program.
3.1.4 Evaluation The controlling function of these valves is excluded from the inservice testing requirements of OM-10 by Section 1.2(a)(2). The safety function to close, however, requires these valves to be tested to verify the capability of the valves to close and to monitor for degradation. Though the valves'-full-open indication cannot be verified, the mid-position verification based on flow ensures that the closed indication is accurate and, at a minimum, that the open indicating-light becomes lit when flow is established. This does e
t 4
i L
116-provide assurance that the valve has opened.. Based on the-safety function of?
the valves,.the verification provides assurance of the operational readiness-of the position: indication for these valves.- Imposition en the: licensee of)
-verifying-full-open position indication would be a~ burden..in that modifications to the piping system (insta11ationLof a test isolation valve);
and to the valve circuitry would be required, with only a minor _ benefit 1 achieved from the mudification.
The current design configuration makes'the
- verification of the open indication impractical.: However,.- the additional information gained by fully opening the. valves does -_not. appear to provide a o
benefit to safety. Therefore, relief is appropriate for implementing the:
position indication as proposed.
While VOTES testing (motor-operated valve diagnostic testing system)-of the valve assemblies provides significant information about the condition of th valve and operator, including stroke-timing, the frequency of testing isinott in accordance with the inservice testing requirements of OM-10. = Stroke-_ timing of power-operated valves is intended to. monitor for degradation;1 however, the periodic verification performed under the motor-operated valve programs established as a result of HRC Generic Letter 89-10, Safety-Related Motor--
Operated Valve Testing and Surveillance, providesian adequate' alternative,_.
- method for monitoring these valves for degrading conditions, including. stroke-timing.
Because the testing is more extensive than-simply stroke-timing,'the' frequency of the diagnostic testing is offset by the additional _information-obtained on the condition-of the valves. Therefore, the proposed-alternative -
provides an acceptable leve1L of quality 1and safety.
3.1.4 Conclusion The alternative testing is authorized pursuant to 10 CFR.50.55a(a)(3)(i) based on the acceptable level of quality and safety for monitoring these valves:for, degrading conditions.-
3.2 Relief Reouest V-2 The licensee.has requested relief from the requirements of OM-10-Section-.
4.2.1.4 to measure the stroke time of-the standby gas treatment ~ power operated -
valves, 1-SG-1A/B, 1-SG-2A/B, 1-SG-4A/B. These valves'open to allow flow.
through the system.
3.2.1 Licensee's Basis for Relief The licensee states:
These valves do not have individual control switches. The valves open:
simultaneously upon _ receipt of an auto open signal.from fan start circuitry.
The valves and operators are of the same design, size, and x
manufacturer.
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3.2.2 Alternative Testino The licensee proposes:
In lieu of establishing a reference value and acceptance ranges for each-valve, a maximum stroke time for the group-(i.e., lA, 2A, 4A) to open will be assigned.
Therefore, any valve whose cycle time is outside this
-i limiting value can be identified and corrective action taken.
3.2.3 Evaluation The relief request indicates that testing the valves and measuring inriividual stroke times is impractical with the current design and testing methods.
Though the relief request does not include the estimated stroke time
- 1 differences between the valves, it implies that the valves should stroke in approximately the same length ~ of time, thereby, making it pssible to identify any valve individually which does not stroke in the assigned limiting time.
The proposed alternative can provide a means to monitor the valves as a_ group, provided that all other requirements of OM-10 associated with stroke time-measurement, including testing following repair or re)lacement, are met. To impose the Code requirements in order to measure stro(e time of the valves individually, the licensee would be required to modify the control circuitry of the system and/or develop a measurement method employing valve diagnostic equipment, resulting in a burden.
If, at a later. time, the licensee implements a diagnostic methed of monitoring these valves for degradation, including stroke time measurement, this relief request should be reviewed for continued reliance.
The licensee must ensure that-the implementing procedures for measurement of the stroke time of the group of valves includes a limiting value, a means of identification of individual valves which exceed this value, and requirements for corrective actions for those valves that exceed the limiting value.
3.2.4 Conclusion Relief is granted pursuant to 10 CFR 50.55a(f)(6)(1) based on the impracticality of performing testing in accordance with Code requirements, and in consideration of the burden on the licensee if the Code requirements were imposed on the facility. The granting of this relief is with the _following provisions:- (1) all other applicable requirements for stroke time measurement are incorporated in the inservice testing program for the groups of valves;-
(2) implementing procedures include the limiting value, a means of identifying individual valves which exceed this value, and requirements for appropriate corrective actions for these valves; and (3) if the licensee implements a diagnostic method that allows for individual valve stroke time, this relief-request is to be reviewed for continued reliance.
3.3 Relief Reauest V-3 The licensee has requested relief from the requirements of.0M-10, Section 4.3.2.1, for exercise frequency, and Section 4.3.2.4, for obturator movement verification, for the main steam automatic depressurization system (ADS) check
y
- valves (1-AC-l'64A _through F and 1-AC-165A through_ F) and atmospheric control
~
(AC) check valves (1-AC-48 and 1-AC-49).
Both groups of valves function' in the closed position to (1) ADS - maintain ADS accumulator pressurized, and (2).
AC - prevent loss of N inventory on a loss of-drywell N 2
2 compressor.
3.3.1 Licensee's Basis for Relief The licensee states:
The main steam safety / relief valves are provided with an-air operator to provide remote valve operation. The check valves are installed in the air supply line to each safety / relief valve. -These valves provide a path to supply a backup supply of air (nitroge'n) through 'an accumulator during a loss of normal air supply.
Valves 1-AC-164 and 1-AC-165 are 1-inch and installed in series. There are no test.onnections to allow individually testing thcse valves.
These valves are located in containment and are not accessible during operation or cold shutdown when the drywell atmosphere is inerted.
The atmosphere control check valves prevent reverse flow from the safety-related drywell nitrogen backup supply system to the non-safety-drywell compressor. There are no test connections to allow individual valve testing.
Exercising these valves requires securing both.drywell N compressors and bleeding down the header. The N compressors are 2
2 required during operation to maintain a 1 p:1 differential between the torus and the drywell. Also, the potential drop in header pressure from check valve and system leakage may result in an inadvertent MSIV [ main steam isolation valve) closure and subsequent reactor scram.
3.3.2 Alternative Testina The licensee proposes:
Test these valves in pairs.
Reverse flow exercise cnecK valve 1-AC-48 and 1-AC-49 at cold shutdown.
rerform a leak test'on all valves during each refueling outage. When a component fails to meet its acceptance criteria, both check valves will be declared inoperable and repaired.
3.3.3 Evaluation The proposed test frequency is in accordance with the requirements of OM-10, Section 4.3.2.2, where exercising of check valves ~ is not practical during.
power operations or cold shutdown. When the design of check valves is. limited such that individual verification of closure anti /or leak tightness is impractical, for series valves which are not bgh required to meet safety analysis assumptions, verification of closure and/or leak tightness of. the pair is acceptable to ensure the safety function is maintained.
Controls must ensure that if excessive leakage is identified for a pair of valves, and/or-reverse flow closure cannot be verified for the pair, both valves are to be repaired or replaced.
Imposition of the Code requirements would be a burden
l
. on the licensee in that modifications would be required to either add test instrumentation or remove the internals of one of the two series valves.
Provided both valves are not required by the safety analysis, the proposed testing provides an adequate level of assurance of the operational readiness -
of the series valves.
3.3.4 Conclusion Relief is granted pursuant to 10 CFR 50,55a(f)(6)(i) based on the impracticality of perfnrming testing in accordance with Code requirements, and in consideration of the burden on the licensee if the Code requirements were imposed on the facility. The granting of this relief is with the following provisions:
(1) if acceptance criteria for the testing is not met, both valves in the affected pair will be repaired or replaced, and (2) both valves in each pair are not required for safety analysis assumptions.
?.4 Relief Reauest V-4 The requested relief applies to the control rod drive hydraulic scram valves.
The licensee proposes to test these valves in accordance with GL 89-04, Position 7, " Testing Individual Control Rod Scram Valves in Boiling Water Reactors (BWRs)." The staff has determined that Position 7 is an acceptable alternative to the Code requirements provided the testing is performed in accordance with the guidance delineated in the position (reference GL 89-04, page 5).
Therefore, this relief request is approved by GL 89-04 and no further evaluation is required.
The implementation of the guidance is subject to NRC inspection.
3.5 Relief Reauest V-5 The licensee has rcquested relief from the requirements of OM-10, Section 4.2.1.4, for measuring stroke time of the gas turbine starting air and gas turbine fuel forwarding power operated valves. These valves have no individual stroke time indication and stroke in less than 1 second.
Proper operation will be verified by proper operation of the gas turbine during the normal monthly operability surveillance test required by Technical Specifications. These valves are non-Code Class components, and are not within the required scope of 10 CFR 50.55a. Therefore, NRC approval of the alternative testing method is not required.
3.6 Relief Reouest V-6 The licensee has requested relief from the requirements of OM-10, Section 4.2.1.4, for measuring stroke time of the diesel air start power operated valves.
These valves have no individual stroke time indication.
Proper operation will be verified by normal starting of the diesel during the normal operability surveillance test required by Technical Specifications.
These valves are non-Code Class components, and are not within the required scope of 10 CFR 50.55a. Therefore, NRC approval of the alternative testing method is not required.
...t I
i 3.7 Relief Reauest V-7 The licensee has requested relief from the requirements of OM-10, Section 4.3.2.1, to exercise check valves nominally every 3 months. Diesel generator fuel forwarding check valve 1-FFDG-14 opens to allow diesel fuel oil to the injection pump and 1-FFDG-15 closes to prevent diversion of fuel oil flow.
There is no means of verifying full stroke of the check valves.
Proper operation will be verified by the starting and acceptable operation of _ the diesel generator during the normal monthly operability surveillance test required by Technical Specifications. These valves are non-Code Class components, and are not within the required scope of 10 CFR 50.55a.
Therefore, NRC approval of the alternative testing method is not required.
3.8 Relief Reauest V-8 Relief from the exercising requirements of OH
'0, Section 4.3.2.1, for the Class 1, Category A/C, feedwater coolant inje,cion (FWCI) check valves 1-FW-9A/B and 1-FW-10A/B is requested. These valves open to allow flow to the reactor and close to provide containment isolation.
3.8.1 Licensee's Basis for Relief The licensee states:
These valves are simple checks with no position indication or assist devices.
They remain open during normal power operation supplying feedwater to the reactor vessel. These valves are also open during cold shutdown because the condensate /feedwater system (using one condensate pump) is used to maintain reactor vessel level.
Exercising these valves requires isolation of all feedwater flow to the reactor vessel, which cannot be done during power operation or cold shutdown.
3.8.2 Alternative Testina The licensee proposes:
Verify that the check valves are open by observation of reactor vessel level changes and fee &ater flow instrumentation.
Verify that the valves are closed at refuel outages during performance of Appendix J type C Local Leakrate Testing.
Additionally, these valves are disassembled, inspection, and manually exercised under the Check Valve Inspection Program at a frequency determined per the recommendations of INP0 SOER 86-03.
3.8.3 Eyaluation OM-10, Section 4.2.1.5, " Valves in Regular Use," stipulates that valves which operate in the course of plant operation need not be further exercised, with certain requirements for recording data. OM-10, Section 4.3.2.2, " Exercising Requirements," allows testing to be deferred to refueling outage's when it is
not practical to perform during normal operations or cold shi idown conditions.
The licensee's-proposed alternative indicates that the ' requirements of OH-10 can be met without relief. Therefore, the licensee should ensure that the requitaments of Sections 4.2.1.5 and 4.3.2.2 are incorporated into the testing.
and delete this relief request. A cold shutdown / refueling outage justification-for closure verification is required.
3.8.4 Conclusion No further NRC action is required.
3.9 Relief Reauest V-9 Relief from the stroke time measure requirements of OM-10, Section 4.2.1.4_is requested for the main steam relief valves,1-MS-3A through F, which are Category B/C valves that function as power operated relief valves to rapidly depressurize the primary system.
3.9.1 Licensee's Basis for Relief The licensee states:
These power operated relief valves are rapid acting valves and they do.
not have stem or disk position indicators. The open l!ght-indication is actuated by pressure sensors located in the relief valve discharge piping and does not reflect valve full stroke open position.
3.9.2 Alternative Testino The licensee proposes:
These valves are exercise tested at reactor refueling outages during plant startup (reference CSJ-16).
Light indication is-. verified to actuate during this testing. These valves are also tested in accordance -
with ASME/ ANSI OM-1-1987 and Technical Specification 4.6.E.1.
3.9.3 Evaluation The relief request does not clarify whether the testing performed at reactor refueling outages is in accordance with the requirements of-Section 4.2.1.4.
As Category B/C valves, the licensee has determined that stroke time testing-of the power operation function of these valves is recuired. Additionally, the relieving function requires snat testing in accorcance with OH-1, Section 3.3.1.1, " Main Steam Pressure Relief Valves With Auxiliary Actuating Devices,"
be pet-formed.- The stroke time measurement for power operated valves is intended to provide a method of monitoring the valves for degradation.
The alternative testing does not describe' a method to meet this intent if stroke-time measurement is not performed. However,_ testing performed in accordance with OM-1, Section 3.3.1.1 may provide, or may be enhanced to provide, a means of monitoring the valves for degradation. The licensee should review the i
purpose of this relief request and clarify what relief is required, provide 4
adequate justification of the impracticality of performing testing in accordance with the Code, and describe the alternative testing in detail, including the method to menitor these valves for degrading conditions.
t
- 3.9.4 Conclusion Relief cannot be granted based on the information provided.
The revised relief request is to be submitted within 6 months of the date of this SE.
This remains an open item.
3.10 Relief Reauest V-12 for reactor water cleanup (RWCU) check valve 1-CU-29 and station air check valves 1-SA-344 and 345 which close to provide containment isolation, relief from the testing requirements of OH-10, Section 4.2.2.2, " Containment Isolation Valves," and Section 4.3.2.1, " Exercising Requirements," is requested.
3.10.1 Licensee's Basis for Relief The licensee states:
Check valve 1-CV-29 is the inboard containment isolation valve on the return of the RWCU flow to the reactor vessel. MOV l-SA-344 is the outboard containment isolation valve on the station air supply header to the drywell. Check valve 1-SA-345 is the inboard containment isolation valve. Currently, there are no test connections available to implement an Appendix J test and verify leak tightness and valve closure.
Interim relief is. requested until the cycle 15 RF0 when necessary modifications can be made.
3.10.2 Alternative Testina The licensee proposes:
In the interim, as required, the station air headers inside (downstream of 1-SA-345) and outside (upstream of 1-SA-344) containment and the RWCU system upstream of valves 1-CU-28 and CU-29 will be vented during the Appendix J Type "A" test.
3.10.3 EyJ1uation The licensee performed a review of the categorization of all containment isolation valves in response to Anomaly Item 4.3.6 from the January 8,.1992, SE. -This review resulted in the three subject valves being categorized as "A/C" and tubject-to Appendix J local leak rate testing. While interim relief from the Code requirements is appropriate due to the impracticality of performing the testing until. modifications can be completed, the-licensee should determine if an exemption from 10 CFR.50, Appendix J, is required. The granting of this relief relates cnly to the requirements of 10 CFR 50.55a.
Imposition of the Code requirements in-the short-term would be a burden in that an accelerated schedule for the modifications would result, potentially delaying startup from the next refueling outage,14 RF0. The proposed alternative is acceptable if an integrated leak rate test (Appendix J Type "A" Test) is scheduled for RF014, as implied in the alternative testing description.
If an integrated leak rate test is not scheduled for RF0 14, the
1 i licensee should propose an alternative that challenges the leak tiaht integrity of these valves for performance during RF014, or otherwise revise-the modification schedule for completion during RF014, 3.10.4 Conclusion Relief is granted for an interim period until RF015 (1996) pursuant to 10 CFR 50.55a(f)(6)(i) based on the impracticclity of performing testing in accordance with Code requirements, and in consideration of the burden on the licensee if the Code requirements were imposed on the facility.
The granting of this relief is subject to the performance of an intyrated leak test during RF0 14, 3.11 Relief Reauest V-11 This relief request identifies the check valves for which testing is impractical due to the lack of positive means to ensure full stroke exercising in the open or closed direction. The licensee indicates that a disassembly and inspectior. program will be implemented for these valves-in accordance with OM-10, Section 4.3,2.4(c), based on a sampling frequency as-discuss 9d in GL-89-04, Position 2.
Because the implementation of a sampling program has been determined to be acceptable per GL 89-04, provided the guidance delineated in Position 2 is followed, no further evaluation is required.
If a nonintrusive testing method is determined to provide a practical method of testing any or all of the listed check valves, the relief request no longer applies to these valves.
For the keep fill check valves in series with no intermediate-test connections, if the licensee can perform a reverse flow test of the series valves, and the safety analysis does not require both valves to meet design basis assumptions, disassembly and inspection mcy not be required-for-verification of the closure capability of-the f acividual valves;.however, a separate relief request would be required and a method to verify opening of these valves would need to be developed. Verification that the keep-fill system is maintaining the piping filled may be acceptable for the valve opening function.
3.12 Relief Reouest V-12 For reactor recirculation check valves 1-RR-lllA/B which close to provide containment isolation, relief from the testing requirements of OM-10, Section 4.2.2.2, " Containment Isolation Valves," and Section 4.3.2.1, " Exercising Requirements," is requested.
3.12.1 Licensee's Basis for Relief
'he licensee states:
Check valves 1-RR-lllA/B are the inboard containment isolation valves on the reactor recirculation pump seal flush line.
Currently, there are no test connections available to implement an Appendix J test and verify leak tightness and valve closure.
Interim relief is requested until the l
cycle 15 RF0 when necessary modifications can be made.
n 3.12.2 Alternative Testina The licensee proposes no alternative testing.
3.12.3 Evaluation The licensee performed a review of the categorization of all containment isolation valves in response to Anomaly item 4.3.6 from the January 8,1992, SE. This review resulted in the two subject valves being categorized as "A/C" and subject to Appendix J local leak rate testing.. While interim relief from the Code requirements is appropriate due to the impracticality of performing the testing until modifications can be completed, the licensee should determine if an exemption from 10 CFR 50, Appendix J, is required. The granting of this relief relates only to the requirements of 10 CFR 50.55a.
Imposition of the Code requirements in the short-term would be a burden in that an accelerated schedule for the modifications would result, potentially delaying startup from the next refueling outage,14 RF0.
However, before relief can be determined acceptable, the licensee must determine a test to conduct during RF0 14 (1994) which provides a means of assessing the leak tight integrity of these valves in the interim, or modify the valves during RF0 14.
3.12.4 Conclusion Interim relief is granted pursuant to 10 CFR 50.55a(f)(6)(1).- However, the licensee must submit a revised relief request-within 6 months of the date of this SE, which describes an alternative means of assessing the condition of these valves for accomplishing their function to provide leak tight closure for containment isolation.
Otherwise, the licensee must evaluate completing the modifications during RF014 rather than RF015.
3.13 Relief Reauest V-Il The relief applies to non-Code Class gas' turbine fuel forwarding check valves and Code Class 3 turbine building secondary.:losed cooling water check valves which perform a safety function in the open direction. The valves will be subject to a disassembly and inspection program as an interim alternative to testing until RF014 (1994) when testing will be accomplished using portable flow instrumentation, with permanent flow instrumentation modifications scheduled for*RFO 15 (1996). The disassembly and inspection activities are approved per GL'89-04, Position 2, provided the guidance delineated _in Position 2 is followed, and no further NRC evaluation is required.
Implementation is subject to NRC inspection.
If non-intrusive techniques are available for RF014, testing should be performed in lieu of disassembly and inspection.
3.14 Relief Reauest V-14 The licensee requests relief from the exercise requirements for Category A/C check valves 1-LP-11A/B in the low pressure coolant injection (LPCI) system which open to allow flow and close to provide reactor coolant pressure boundary integrity.
The relief is applicable only to the opening function of
3
- the valves. The licensee intends to implement a disassembly and inspection program, along with part-stroke exercising,- to verify the capability of the valves to open. Nonintrusive testing techniques are currently being evaluated which could be utilized during part-stroke testing to meet the requirements for full-stroke testing. Additionally, modifications to the valves' air operator mechanisms,.which are no longer in use, are being' considered..If_
such methods are implemented, this relief request will be deleted. The current alternative is approved per GL 89-04, Position 2,-provided the-guidance delineated in Position 2 is followed, and no further NRC evaluation is required. -Implementation is subject to NRC inspection.
4.0 SAFE SHUTDOWN The licensee has identified that Millstone I was licensed with hot shutdown being the safe shutdown condition of the plant, and as a result of the inservice testing bases document review, has removed components from the program which are required for achieving and maintaining cold shutdown.
In discussions between NRC and ASME Code committee members, the NRC had identified to the committee members that a number of early plants were licensed to operate with a " safe" shutdown condition of hot standby or hot-shutdown, and were not required to achieve cold shutdown following design bases accidents.
For such plants, components and systems necessary to achieve cold shutdown may not, therefore, be safety-related and/or subject to quality assurance requirements. These components are not credited to achieve " safe" shutdown.
The ASME Code committee members have agreed to revise the scope of the OM Codes and Standards to " safe" shutdown rather than " cold" shutdown-in recognition of this apparent conflict for plants such as Millstone 1.
The licensee should ensure that the scope of the inservice testing program includes all safety-related ASME Code Class components which are credited in the safety analysis.
5.0 CONGLUSION The staff concludes that the relief requests as evaluated and modified by this SE will provide reasonable assurance of the operational readiness of the pumps -
and valves to perform their safety-related functions, provided the. licensee makes the applicable modifications described in the relief requests during refueling outages RF0 14 (1994) and RF0 15 (1996). The staff has determined that granting' relief pursuant to 10 CFR 50.55a(f)(6)(1) is authorized by law.
and will not-endanger life or property, or the common defense and security and is otherwise in the public interest, giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
For certain items, the staff has requested the licensee to perform additional review and to address the related issues within 6l months from the date of this SE. These items-are as follows:
Item 4.2.10 of Table 1, and Sections -2.2,
-(
a
.q
.; 2.3, 2.6, 3.9,~and-3.12, of this'SE. Other sections may! include actions the.
licensee is.to take to address provisions in the granting of relief.
These provisions should be incorporated into the inservice testing program'within 6 months from the date of this SE unless otherwise noted in the SE.
Principal Contributor:- P. Campbell Date:
February 18, 1993 1
e
,.r 3
M
1 3
Table 1 Table of Anomalies and Action Items in NRC Safety Evaluation Dated January 8,1992-Millstone Nuclear Power Station, Unit 1 Northeast Utilities Response Dated October 30, 1992 Descriptian of Actions Tekm to Addreas statam of Itea Beacription of Item in NRC SE It a s as Described in October 30,1992/
'and Anomaty/ Action Item
'Deted January 84 1992-sempense
. nemminig Action, 4.1.1
- The licensee had submitted the previous program The licensee has revised the inservice No further action is' Generat for inservice testing of' valves in accordance testing program to incorporate the recent required.
with the requirements of OM-10, inservice Testina rutemaking ef f ective September 8,1992.- The of valves in Liant-water acactor Power Plants relief requests and cold shutdowVrefueling which had not yet been approved for outage justifications have been revised to implementation by the NRC, ' This item indicated include the appropriate references to the OM-that the NRC review and evaluation of relief 6 and OM-10 requirements in the " TEST requests had been performed in accordance with REQUIREMENT
- section.
the requirements of the 1986 Edition of ASME Section N1,. Subsection !W. [By rulemak.ing ef fective September 8.1992, the staf f incorporated the 1989 Edition of ASME Section NI, which references OM-10 for the requirements of inservice testing of. valves, with a modification -
related to containment' isolation valves.] The pump testing had been developed using 04-6, Lnservice Testino of Pues in Liaht-Water Reactor Power Plants. [0M 6 had been a @ roved by NRC in Revision 8 (November 1990) of Regulatory Guide i
1.147, inservice Inspection' Code Case Accectability AsmE Section XI Division 1.]
It was recommerded that the licensee review the 4 -
references te "ection' XI, IW, and OM-6, incitded in the evaluation sections of the SE, to ensure -
the refererces were in accordance with the Millstone IST Program, and further, to include
~
the applicable references in the relief' requests when revised.'
' ~ "
- 1 1-
.f'
+
e, w
.n n,
7 e
IIe f [,8; Description of Actions Takest to Achdreas
- Status of Item T
- Description of Itan in NRC SE -
Items me Described in october Anamaty/ Action Item'.
. Dated January 8,'1992 30,.1992,-
'and-
~
teemining Artten =
4.1.2 The Isf program included a ruiber of relief the licensee provided a schedute for review Relief secpaests R-1.
General requests for teck of instatted flow and/or instattation of flow instrumentation thro d R-5 are instemmentation. ' These relief requests related in a stbnittat dated May 19, 1992. Relief evaluated in the 6
.to hoe pump and valve testing. The WRC's Requests R-1 through R-5 summarize the review' current SE. Refer :
.'E positten is that the hydraulic performance of of flow instrumentation requirements.
to Sections 2.1'and
- plays can be adequately monitored by measuring 2.5.
flow and differential pressure, or discharge-prsesure for positive chsptacoment pumps and, that an acceptable test for futt-stroke exercising check valves is to ress accident flow rate through the valves, requiring a known flow rate (reference GL 89-04, Positions 1 and 9).
The tack of flow measurement was a concern. The
. ticensee was recpested to review the issue and provide a schedule for completion of reviews in the Integrated Safety Assessment Program related to flow instrumentation.-
4.1.3 -
This anoniely identified that the inservice The Mittstone-1 IST Program, Revision 5, was No further action'is General testing program indicated that valve exercising developed using OM-10 for valves testing.
required.
charing cold shutdown would comumence within 48 Based on the rutemaking ef fective Septaneer hours of' achieving cold shutdown and cantinue 8,1992, and the use of 01-10 to revise the until att cold shutdom tested valves have been vetve inservice testing program, relief to tested or mtil the plant is ready to startup.
implement the cold shutdom scheduling The anomaly indicated that this position was requirements is no longer required.
consistent with OM-10 which had not,'at the time the SE was issued, been endorsed by the WRC in.'
~ 10 cfR 50.55a. ' Relief was required to laptement this position.
l-2-
L r
l l'
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Description of Actieres Taken to Address Status of Item Description of Itaa in WRC SE Itens as Described in October.%r, 1992, and Anamnly/ Action Ites Dated January 8, 1992 Reep mse Remaining Action 4.1.4 This anomaly noted that a rusber of passive The licensee responded that passive valves, The administrative Generat valves were ilsted in the Mittstone-1 IST valve by definition, are not reqJIred to Change Controt$ need not be List,. The licensee was requested to include a position to perform their safety fmetion, included (* the IST description in the IST program describing the and that administrative controls are in place Program. These are, method (s) utilized to verif y these passive valves to control system valve alignment. The however, sibject to are maintained in the correct position.
details of how these administrative controls
>RC inspectlan. no are accorplished were determined not to be further action is acceptable for inclusion in the IST progree required.
doctment. However, the Licensee ir.:licates that position indication of these valves is verified in accordance with the requirements of OM-10, Section 4.1, " Valve Position verification," ard section 6.1.5, " Position Indication (PI) Verification Testing,* of the IST Program, as approorfite.
4.2.1 This encoaty addressed pep Relied Requests R-6, These relief requests have been replaced.
The revised relief Relief Requests R-6, R-12, R-14, and R-17.
These relief requests adrere applicable, by revised Relief Requests reg;ests are R - 12, R - 14, ard R -17 discussed the impracticality of varying the R-1 and R-7.
evaluated in the system resistance until the flow rate equals the current SE. Refer reference value ind rieasuring pressure, or to Sections 2.1 and varying the f tcw rate mtil the pressure equats 2.7.
the reference value and measuring flow rate. The SE conetuded that because fIou instrumentation was not provided for the af fected peps, as discussed in separate relief requesta, these additional relief requests were not necessary.
Interim relief was granted for the separate relief requests in order to provide a period of time for the licensee to evaluate the instat tation of flow instrunentation. For R-6, R-12, R-14, and R-17, the SE andicated that these relief requests were not applicable at the current time based on the flow instrumentation relief requests.
3 a
'm. -u _, e Description of Actions Taken to Addrw star a of item Beacriptiset of items in ERC SE Items am Described in Octsber M, 1992, ased Anmmety/ Action items Deted Jarasury 8,1992 W
Semmisedeg Action 4.2.2 Relief from the ren.eirements of on-6, section This relief repnst has t:een withdraun.
me Asrther action is Relief Request R-1 4.6.4, for measuring pump vibration, for various Performance of vibration w asurement will be ressired.
- D gasps, in tira orthogonal directions was denied in accordance with the requirements of 04-6.
beoed en insufficient justification that the i'
regairements were either impractical cr presented a taarden without a casupensating g.setity ce safety benefit. The licensee was regsested to review the need for this relief in relation to specific pimpr*, and If cases were idontified tesich i
necessitate relief, individant retlef requests were to be stenitted.
I
.4.2.3 Interim relief was granted for the tack of flow Quarterly meesurement of indivi & st Relief Request R-1 1j:
Retief Reesest R-2 instrumentetion fer quarterly testing of the corusensate pump flow has been invest *:;sted.
is evaketed in the condensate pumps. The licensee was reauested tw The results are docssmented in Revision 5, current st. sef er -
investigate and evaluate methods to individustly Relief ReeJest R-1.
Differential pressure to section 2.1.
seesure flow & ring quarterly testing of each cf and slbration will be monitored quarterly and these three pumps.
casuplete testing in accordance witti EM-4, including individust smsup flow rates, will be performed daring each refueling outage. This Is similar to CL 89-04, Positier: 9, **umo Testing Using Minimum 4tou Return Line With or Without Flow measuring Devices.* The use I
]
of portable flow instrumentatirn or insta1(atIan of perumnent f1om instriseentation that would sticu for l2 indivi&ot game flons measurunent gaerterly was investigated, as requested, and l,
determined not to be possible for the j?
esisti*up srstem configuraticri.
<1.
4.2.6 Relief from the requirements to vary the This relief regsest has bewn withdrawn.
Retief Request 4-1 4,
8etief Request R-3 resistance of the systeme to a reference vsdue of systein resistance witt be varied daring is evatunted in the flow or differentist pressure when perfor,,4 individaat condensate gamp testing performed current SE. Refer testing of the condensate w was denied..
' daring refueling outases. Relief Request R--
so Sectiori 2.1.~
Relief was not applicable to the genrterly 1, discussed in Itase 4.2.3 above, has been testing based on the tacit of flow lshittedrelatedtothisissue.
instrsementation. For additionet testing 2
performed during cold shutdoeris and refuetins outages, individaat puso flow seasurement provides a means for tt.e or+. hod of testing to meet the remirennents of CM-6, vu$ therefore, relief was not considered appn p-iate for the testing performed at tf 4s f regmy.
4 1
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,o Descriptist of Actions Taken to Ack$ress Status of Itma Descriptim of Itesa in WRC SE Items as Described in October 30, 1992, aruf Anomaty/ Action Itna Dated Jarusary 8,1992 tempanse Remmoining Action 4.2.5 Relief to not measure or calculate differential This relief reg;est has been witharann. Pump ao further action is Relief Reg;est R-4 pressure for the condensate pw ps was denied due differential pressure witt be determined regaired.
to inadegante justification of the impracticality charing condensate purp testing. Suction of meeting the regairements of 04-6.
for both pressure will be determined frza hetweit the gaarterly and cold shutdown /refueting outage tevet and corusenser vacusa and dif ferentist testire, the dif ferentist pressure should be pressure calculated for the cordensate pumps calculated using the tevet of the corher in accordance with On-6 rersairements.
hotwett to determine suction pressure. The licensee was to ensure that the calculation method awets accuracy regairements of OM-6, Tabte 1.
4.2.6 For these relief requests covering various pupps the requirement to serasure pwp flow The reruseered Relief Requests R-5, for.Aich no flow instrsamentation is instatted, identified in these relief requests has been relief requests are R-11, R-16, R-18, R-interim relief was granted. The interim relief reviewed. Specific inform 6-lon is contained evaluated in the
- 22. R 23, and R-24 was intended to provide the licensee with e in revised relief rensests (renumbered) current St. Refer i
l period of time to investigate and evatuate the asplicable to the dif ferent ptsps as follows:
to Sections 2.1, instat tation of flow instrumentation or the use R-1: Condensate booster smmpa and service 2.5, and 2.7.
l i
of tesaporarity instatted flow unessuring devices.
water pumps see item 4.1.2 atsove.
R-5: Dieset fuel oit transfer ptsps R-7: Secondary closed cooting water gasps (Previous ret ief requests R-5, R-11, a-16, and R-22.)
The following previous relief regJests have been deletec:
R-15, R-18, and R the reactor building closed cooling unter purps, shutdown cooking I
pumps, and reactor feechater seat injection punps have been removed from the t$T program as the functions these gasps perfone are not within the scope of the program (identified during devetessment of bases doctammt).
R for the ses turbine fuet forwarding pisps, smrtable flow instrtsmentation will be l
used (R-4 addresses the accuracy of this Instrisier-tation).
5 a
6
+
,e 1
Description of Actions Taken to Adaress Statm of Itsun Description of Iteam in met SE Items as Described in October 30, 1992, and Arussaly/ Action Item Dated Jarusory 8,1992 Eesponse temmining Action 4.2.7 Retief fram the requirements of OM-6, secti m This relief regnst has been withdraert. The so further action is actlef Recpest R-7 5.2(b) to very the resistance of the system etit testing is performed at repeatabte corditions regef red.
the differentist pressure or flow rate equals the ard reference values have been established in corroepending reference value for inservice accordance with tys-6.
testfrie the reactor feedhsater pupps was evaluated. Based on the licensee's description of the testirg, it was d=termined that relief was not regJired, as the test conditions are reedity d@ticated daring normat operation. It was recaemended that if the licensee determines that flow or dif ferential pressure vary daring normat operatim to en eatent that a reference watue, or euttiple values, is not readily d@licated, individual pump curves be developed and relief stistitted for use of the curves.
4.2.8 pelief was denied for these relief requests These relief regmsts have been withdrairi.
No further action is Relief Requests concerning the feedseter pungs (R-2) and control The 'C' reactor feedmater pusqp was removed required.
R-8 and R-20 rod drive g:tsps (R-20). The licensee had from the Ist Progran per the review performed
)
proposed to perform quarterly testing on only the for the IST bases document. Inservice i
pimp in operation, and not perform inservice testing will be performed on the 'A' and *8*
testing on the ptsups not in service.
reactor feeenster pupps quarterly. the 'C' Justification was not adegante to (Micnte that paso does ret fmction as part of the testing at the required frequency was irpractical feedwater coolant injection systeveaAich is or creates a burden without a conpensating the safety mode of operation for the increase in cpatity and safety.
feedsater ptsps; Aw, it will be tested in a s e temental test program.
The CR3 punos' function was deterrined to be outside the scope of the IST Progree dJring develegrent of the bases document; however, these psps will be tested in a stoptementet j
test progree.
6
o.
= '
a Description of Actiers Takers to Ad&ess Status of item Desedption of item in meC SE tiens as Described in October 30,19g2, and 3
.Anamety/ Action item Deted Jaresery 8, 1992 '
Sempanse Rennining Actione-i 4.2.9 Relief was granted for utilizing e pung curves to The suction pressure for the emergency No further action is Relief Request R-9 ottow testing of the emergency condensate condensate transfer pJup is measured; re4 aired.
transfer pasps in the es-found condition provided therefore, a curve for the condensate storage i.
the licensee establish the pump curves with a tank levet is not necessary. This relief miniaan of three points considering the expected request has been withdrawn. Testing as range ef levels in the condensate storage tank described in the retlef regaest is addressed
~
& ring testing, d ich determines the suction in on-6. specificatty, 04-6 1 5.2(c) states, I
1 pressure.
- tulhere system resistance cannot be varied, flow rate and pressure shall be determined and coopered to their respective reference i
values." Therefore, the testing performed j
meets the regstrements of ON-6.
i
~
4.2.10 interim retief was granted to attow a period ef The retlef regaest has been withdraun.
The licensee ham j
Retief Regaest R-10 time (six months) for the licensee to investigate suction pressure for the service water pwys adfressed the j
methods for determining differentist pressure for and emergency service water pumps will be concerns of this i
the verticet ilne shaft service water pumps and determined based on the Eisntic Say levet at anomaly..
4 j
emergency service water ptsups. The licensee had the time of the tests and pump dif ferentist proposed to meesure enty discherge pressure, ta't pressure will be calcutered.
had not discussed the impracticality of determining suction pressure based on the level of Niantic gay.
4.2.11 The licensee had proposed to increase the test This relief regaest haw been withdrann. The No further action is Relief Request R-19 intervet of the shutdoin cooling pigs ard shutdoe.n cooling system uns reviewed during regaired.
testing the pumps enty during cold shutdouns and development of the IST basis document eruf the i,
refueling outages if the shutdoim cooling system systema samps* fsnction was determined to be was pieced in service. It was noted in the SE outside the scope of the ist program. Tnis that a test path was discussed in SAR Secti e -
determination ues based on the plant being 5.1.8 eich coutd be utitired for gaarteriy 1icensed for hot shutdann es the safe
];
inservice testing. The relief request did not shutdonc condition (see section 4.0 of the ~
j discuss the attemative flow path. The relief current SE). Therefore, these pumps have rensest was denied.
been removed from the program. nowever,. the shutdonc cooling pays will centinue to be '
tested as part of a styptemental test program.
i s-4 J 1 4
A 5-4
. + - - _.
3 3
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3
. Descriptian of Actiers Tabet to Ahmereas Statuas of Item
- Seacriptian of Itean in suic SE Items as Described in October 30,1992,
' and Anamaty/ Action item -
Deted Jarusary 8,1992 -
Rempanse esaminime Actless "-
4 4.2.9 tetief was granted for utilizing a pts, curves to The suction pressure for the w me further actlen is Relief Request R-f attons testing of the w;br condensate.
cendensate transfer pimp is seesured; re gired.
trarufer gnaps in the as-found condition provided therefore, a curve for the condensate storage the ticanaos establish the gxmp curves with a tank tevel is not necessary. This relief minleam of three points considering the expected request has been withdrawi. Testing es range of levels in the conderisate stor arye tank described in the relief request is addressed
& ring testing, which determines the suction in 04-6.
specifically, Ot-6 section 5.2tc) pressure.
states, "Iulhere system resistance cannot be varied, flow rate and pressure shall be determined and compared to their respective reference values." Therefore, the testing performed meets the requirements of 04-6.
4.2.10 Interie relief was granted to attow a period of The retlef request has been withdra m.
The licensee has Relief Request R 10 time (six acnths) fer the licensee to investigate Suction pressure for the service esoter ptsps addre= sed the methods for determining differential pressure for and m;sy service water ptmps witi be concerns of this the vertical line shaft service water ptasm and determined based on the mientic say levet at anamaty.
-;N..f service water pumps. The licensee had the time of the tests and pump differential proposed to measure only discharge pressure, but pressure will be calculated.
had not discussed the impracticality of determining suction pressure based on the tevet of slantic Bay.
This relief re m est has been withdraun. The to further action is shutdown cooling system was reviewed darirs recasired..
devetcssment of the Isf basis document and the system ptmps' fisiction was determined to be outside the scope of the IST program. this determination was based on the plant being licersed for hot shutdown as the safe shutdonc condition (see Section 4.0 of the current SE). Therefore, these ptmps have been removed from the program.. sowever, the shutdoen coottre pumps witt contirsae to be tested as part of a sapptemental test program.
7 i
i al
~
~
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v Descriptian of Actions Takers to Addries Statum of Item Demeription of item in autC SE Itemus as teocribed in actedner med Anamenty/ Action its a toted Jarmary 8,1992 30, 1992, -
.., Actlese This re't'ef request has been withdrawn. The eso further action is l
4.2.12 Interie retlef wra granted fer a period of sia Retief Request R-21 months to endow a period of time for the licensee licensee has determined that the requirements regstred.
to devotep and impleaent a method to determine of out-6 section 4.6.5 can be amet. The the differentist pressure for the vertical line suction pressure for the diesel fuet oit sheft diese1 fwet oil transfer pumps and gas transfer pumps and gas turbine fuet turbisw fust alt forwarding pops.
forwarding pays will be determined based on the storage tank levet at the time of the test and pump dif ferential pressure will be calculated.
4.3.1 for Relief Requests V-1, v-2, v-4, v-5, v-6, V-T, The listed vetve relief requests have been me further action is Cold shutdown V-10, v-11, v-14, v-16, v-10, v-22, V-27, v-33, changed to cold shutdewn/ refuel required. Retlef Justifications V-31, v '18, and V-37, the licensee had requested justifications except for V-31 aruf v-38 Request v-3 is extension of the test interval from gaarterly to iAlch have been withdreest and V-39 whieft has evetusted in the each cold shutdown ard refueling cutage. These been incorporated into a rww V-3 relief current SE. Refer relief regaests were not evatusted in the SE.
It regaest.
to Section 3.3.
was recomumended that the ticensee change these retief requests ta cold shutdown justifications aditch include a basis for the impracticality of performing the inservice testing during power operations. If the test intervat is discussed in CL 89-04 positions, the basis for extending the intervat should reference the applicable position such as Position T relating to control rod drive scram valves in gems.
4.3.2 For the feedseter coolant frijection check volves.
This relief regeest has oeen revised to Revised Relief Relief Request v-8 relief esos denied to extend testing to refueling provide additionet justification for not Roguest v-8 is outeges. The relief reg;est did not previde testing feedwater coolant injection evolunted in the sufficient justification for not performing contairement isolation check watwes 1-FW-9A/S current SE'.
Refer testing during cold shutdows conditions. The and 1-FW-1GA/S during cold shutdoen to Section 3.8.
Licensee was requested to address this concern conditions.
l within sin months.
-8
_............e...
,_..m_.__.--,.
Description of Actions Yakers to Addreas Statua of Item
- Description of Itas in NRC SE tream as Described in October 30, 1992, eruf Annasty/ Action items Dated Jarusary 8,1992 seaponse semainig Action 4.3.3 This retlef regJest mseise,; the controt rod This relief regaest has been withdraws. As no further action is Relief Request V-13 withdrawn!/ineert check vatwes. The proposed the test frequency esceeds the exercise rega6 ed.
altamative testing stated that the valves freg>ency requirements of the Code, relief is operate in the course of normal plant operation not retwired.
at a freguancy that exceeds the esercise reqJirements of the Code. Retief is not required if the test freg;ency for inservice testing meets or exceeds the Code regJirements. The Licensee wea to ensure that testing in the course of operating the vatwes is proceduralized with the acceptance criteria included in the procedare, and performed in accordance with Code regairements and/or guidance in r.L 39-04 positions. If Code regJirements other than those related to fregaency carwict be met by this testing, specific relief is reouired.
4.3.4 This relief regJest concerned the -.,ssi Relief Regaest V-23 has been revised to Relief sequest V-1 Relief Request V-23 service water (ESu), tou pressure coolant provide additional details and justification is evaluated in the injection heat exchanger outlet thrcttle vatwes.
for the proposed atternative testing of current SE. Refer The reg >est indicated that strole time testing emergency service water valves 1-LPC-4A/5.
to Section 3.1.
could not be performed due to the type of V-23 has been renuntered as V-1 controtter for these valves and that futty opening the vatwes could dassge the ESW ptsp.
The Licensee proposed to operate the valves to a position greater than 25% trawet. The relief request was insuf ficient to allow for adegante review and this was an open itee of the SE.
4.3.5 For the stantasy gas treatment sequence vatwes, actief Regaest V-23 has been revised to Relief Request V-2 Relief RegJest V-28 thIch operate automatically during the start provide adfitional details and justification is evaluateo in the sequence of the system, individual stroking is for the proposed alternative testing of current SF.
Refer not possible. The licensee proposed to exercise stanct y gas treatment system vatwes. V-28 to Section 3.2.
and stroke time the valves as a groto. The has been rerubered as V-2.
relief request was insufficient to attow for acequate review and this was an open item of the SE.
9
.. =,. -
Descriptian of Actions Taken to addreas States of Ite Descriptien of Ituar in NRC SE Iteas as Descrlined ift Octatuar send Anaesty/ Action stem Seted Jasmanry 8,1992 30, 1992,
" _ Artien 4.3.6 The licensee regsested retlef for not teak netief acauest V-32 has been withdraen. As Relief Septs V-10 Relief RegJest V-32 testists contalrument isolation valves d ica are part of the IST Program design bases review, and V-12 are not sehject to Appendia J tocal teak rate att valves were anatyred for deterairation of ewetuated in time teethg. mowever, the valves were categorized in Category A status. Appropriate watve current SE. Sofer the innafvice testing program as "A" or "Asc.*
specific relief regsests have written to to sections 3.10 and It ses rW that the ticensee determine address cases d ere testing is not possible 3.12.
the correct categorization of these valves, and due to system configuration (see Relief if it is deteruined that the valves are Category Regaests v-10 and V-12).
A or A/C, the vatwes are stbject to leak rate' testing per 10 F R 50.55a, section II, and/or on-10.
If not, the leak rate testing rsgetrements of the Code do not apply. Valves dich functiers as containment isolation vetras may have a separate leak-tight safety fmction.
4.3.7 The licensee proposed to extend the verification Relief Regaest V-33 has been revised and actief acneest V-10 actief Request V of the 1-C18-29 reactor water clean e check rerumbered as V-10.
Interie retlef has been is evatusted in the vetve's capability to close to a refueling outage requested untit the cycle T5 refueline current sE. Refer intervat, and to utilire a water teekage test, cutage. modifications are to be performed to section 3.10.
d ich is performed in lieu of the A m endia J d ich will attow reverse flow emercise local teak rate test (Appendia J exception), as testing and A m endia J tocal teek rate the verification. Interie relief was granted to testing of check vatwe 1-CU-29.
attow for a period of time for the licensee to determine if closure verification could be performed on a cold shutdown fregsency. The vatwe was presumed to be emercised gaerterly during the cycling of the penetration *s second contairusent isolation valve,1-CU-28, but this test carriot be credited as no position iruficating devices are instatted.
4.3.8 For emptosively actuated shear valves in the This relief request has been withdrawn.
lie further action is actief Request V-35 transversing incore probe (TIP sgaib votwes 1, 2 Testing of emptosively actuated watwes will required.
3 and 4), the Licensee proposed to remove and be performed in accordance with one-to, I e,st att four valves every four years rather than t
Section 4.4.1, requirements.
test one of each batch every two years in accordance with tne Code requirements. Relief was denied es the basis for the alternative-proposet provided no justification that the Code requirements could twt be met, or that the Code requirements were a hardship with no compensating incresse in quality and safety.
10 w.
e.
Description of Actioru Taken to Adkens Status of item Description of Iteas in mRC SE trees as Descritad in October 30, 1992, and Anomaty/ Action Item Dated January 8, 1992
Response
Semaintry Action 4.3.9 Relief was granted for implementing a check valve Relief RegJest V-41 has two incorporated Relief Request V-11 Relief Reg.wst V-41 diseassaidy and inspection program for the low into new Relief Request V-11 which provides is evaluated in the pressure coolant injection pisip minise.se flow the details of the disasseatdy and inspection current SE. Refee recirculation check valves. The licensee was program for these and ether check valves.
to Section 3.11 Instructed that the program should be isolemented in w-he with the guidelines in CL 59-04, Positicn 2, including a partiat-stroke of the valves, if possible, following reassent:ty.
4.3.10 Ratief sea geanted for teak testire the tow Relief Rennsts v-42 and V-43 have been Retief Request v-11 Relief Requests pressurv coolant injection check valves and the incorporated into new Relief Res;est v-11 la evaluated in the V-42 and V-43 core spray keep-fitt check valves in pairs rather which provides the details of the disassent>ty current SE. Refer
~
than individually with the provision that if and inspection program for these ord other to Section 3.11.
escessive leakage is identified, both valves of check valves.
the applicable pair be repaired or rec
- laced.
4.3.11 for both sets of the core spray ptsp ard low This retlef requests has been withdra n.
The ao further action is setief Request v-44 pressure coolant injection pupps actor bearing enre spray puno and icw pressure coolant required.
oit cooler solenoid watwes, no resote position injection pump motc s have been replaced with indication was installed and stroke times were a design that does not reesire cooling water f.et measured. Alternatively, the operation of for the actor bearings. Therefore, the the valves was verified by observation of cooling a d ject watwes, 1-CS-25A/s and 1-LP-52 A/s, water pressure to the cooters during gaarterly are re longer regaired.
ptmo surveillance. Interim relief was granted to J
attow a period of time for the licensee to determine a method of acnitoring these valves for degradation.
4.3.12 For the it/ nitrogen purge contairunent isolation Relief Reg;est V-46 has been changed to cold so further action is Relief Request v-46 check valve, retlef was denied to not emercise shutdomeVrefueling outage justification CSJ-required.
l the valve quarterly or daring cold shutdown
- 23. Additional inforestion is inciscsed in l
conditions. The licensee proposed to exercise CSJ-23 to justify extending the test l
the valve daring open daring the operation of the freaaency to every refueling cutage in erder TI? machines and closed ty Appendia J tocal Leak to verify closure daring the Apperdia J tocat rate testing perf ormed during refueling outages.
teak rate testing.
Retief was denied based on insufficient l
Information in the relief reoaest justifying not l
performing the testing at the Code required l
f reoumey.
l l
I 11 I
aA
- 3*
Descriptian of Actions Taken to Adfress Status of item Description ef Itees in ERC SE Itses as Described in October 30, 1992, and
-Annesty/ Action Items Dated January 8, 1992 temponse Romeining Action 4.3.13 The ticaneae regaested relief from performing The s4 ject relief rerpests have been no further action is Relief Requests pressure isolation valve leakage testing for the withdrawn. Pressure isolation valves will be req > ired.
V-48 and V-49 tow pressure coolant injecticn pressure isolation tested in accordance with CRe-10, secticn vetwee and core spray pressure isolation volves.
4.2.2.3, regairements.
and to alternettvely perform the Appendia J tocal leek rate testing to verify the leak-tight integrity of these valves. The SE identified that the testing must be correlated to account for the different test medium (air versaa. water) and pressure dif f erentists between the two types of teek tests. Interim relief was granted to provide the licensee a period of time to evaluate the testing. It was further recaernended that the licensee review the regairements of all of the pressure isolction valves to ensure teskage testing is h te.
4.3.14 The anomsty related to the reactor water cleanto the f actions of selve 1-CD-69 have been so further action is Relief Request V-45 system relief valve vent line to tonas check reviewed and a determinetton made that the regaired.
valve 1-CU-69, unich was identified as e volve does not provide a conteirnent containment isolation volve. The retlef request isolation fmction. Valve 1-CU-69 has been indicates the etess and category as "Aus!
removed f rom the 157 Progras; therefore, E31.1/C,= and tists no other safety function than Relief Request v-45 has been withdrawn.
contairveent isolation. It was recomunerded that the Code classification ard c.ategory of this valve be reviewed against the regairemects of ASME section 11,Section XI - IWA-1320, 13 CFR 50.55sts)(1), and Generic Len er 89 Position
- 10. The relief request was to be revised according1y.
4.3.15 It was noted that the valve relief regaests (as The relief requests ard cold so adfitionel General - Vatwes well as the volve table) did not specify the shutdown / refueling outage justifications now response is safety-related fmetion(s) of the volves to open include the information identifying the regaired; however, or close. It was recomraended that the relief safety-related fmetion of each velve to open the licensee should requests be revised to inctufe this information.
or close. The vatve table indicates the consider e:kfing a Certain assurptions were made by the mRC reviewer normal position of each valve, but does not coturei to the valve en valve safety functim based en the information list the position or positions regaired for table indicating the in the licensee's basis for relief and in the fulfittment of t w safety fection(s) of the regaired safety Mit tstone 1 Updated Final Safety Anotysis Report.
valves.
positim(s) for future revisions.
12 a
k.-
____m
Ah o.
Deecriptigen of Actions Tatten to Adgrees status of item Dumeriptian of Item in met SE Items as sencribed in octahme 3g, 1992, soud Anamety/ Action Item toted Jarosary 8,19g2 '
tempanse
. Acties -
1 4.3.16 The licensee had requested relief from the Relief Regaest v-24 has been changed to cold No further action is Relief RegJest v-24 tpsarterly tes*ing of certain shutdown cooling shutdoun/ refueling outage justification CSJ-regaired.
system volves and proposed to esercise the valves 24 metich indicates that the applicable valves 1
far operability at reactor refueling outages and will be tested during cold shutdom et cold shutdown if the shutdown cooting system conditions.
Is ptoced in operation. As discussed in Iten j
4.2.11 above, the shutdoin cooling system can be j
operated at each cold shutdown. Therefore, it was recomumended that the ticonsee change Retlef 4 I sequest V-24 to a cold shutdoeri justification and perform the testing at each cold shutdoers and refueling outage if the testing has not been performed within the previous 3 months, in
'j accordance with t w-3412 and I w-3522.
4.3.17' This relief regaest covered a raasber of pump Retlef Reg.aest V-50 has been deletmf and the setlef segaest v-13 Retlef Request v-50 discharge check valves'. The licensee had rewired informaticri is included in two cold is evaluated in the j
requested relief from futt-stroke esercising the shutdown / refueling outage justifications current E sefer applicable check valves. Flow instrumentation (C5J-1 for feegheter coolant injection and to Section 3.13.
was not evaitabte for verifying futt-stroke CsJ-29 for service water) and one relief opening, though samp flow measurement may regsest tv-13 for ses turbine fuel ferwerding currently be'available at some frequency, or mitt and secondary closed cooling water). It mes be available at a later date.. Monitoring system determined that relief is not regsired for parameters for verifying reverse flow closure cari dieset fuet oil formercing check valves.
be acceptable if the parameters provide positive assurance of valve closure, such as monitoring idle pump rotation daring quarterly testing of another puup. - Novever, for tong-term relief, the licensee had not discussed the use of CL 89-04, Positions 1 or 2,-w alternatives to testing with-flow measurement.' It was recommended that testing methods be developed to meet the Code requirements and/or GL 89-04 guldetines.
4.3.18 It was noted that the'ticensee's stheittat did the comment has no relevance to the revised no further actiori is not include e Retief Regaest v-12 and that actief IST Program.
- reesired, tegaest v-40 was notest as deleted-13 t
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