ML20134L753

Forwards Safety Evaluation Re Inservice Testing Program Requests for Listed Reliefs

ML20134L753
Person / Time
Site:	Byron
Issue date:	11/18/1996
From:	Capra R NRC (Affiliation Not Assigned)
To:	Johnson I COMMONWEALTH EDISON CO.
Shared Package
ML20134L755	List: ML20134L753 ML20134L781
References
TAC-M94432, NUDOCS 9611210204
Download: ML20134L753 (3)

Text

. - _ - - - . - . --.-- ----__- - --------- -

j_ *1 49% SD-W4/46S 1 j O k UNITED STATES i g NUCLEAR REGULATORY COMMISSION g WASHINGTON, D.C. was annt i  %,*****/g November 18, 1996 e

i j Ms. Irene M. Johnson, Acting Manager Nuclear Regulatory Services Commonwealth Edison Company Executive Towers West III 1400 Opus Place, Suite 500

Downers Grove, IL 60515

}

SUBJECT:

INSERVICE TESTING PROGRAM RELIEF REQUESTS FOR PUMPS AND VALVES,

BYRON STATION, UNITS 1 AND 2 (TAC N05. M94432 AND M94433) i

Dear Ms. Johnson:

j In a letter dated December 22, 1995, Commonwealth Edison Company (Comed, the 3 licensee), submitted the second ten-year interval inservice testing program l- for pumps and valves for the Byron Station, Units 1 and 2. The submittal

, included Pump Relief Request PR-1 and Valve Relief Requests VR-1, VR-2, VR-3, .

i VR-4, VR-5, VR-6, VR-7, and VR-8.

I j The C.gde of Federal Reaulations,10 CFR 50.55a, requires that inservice <

testing (IST).of certain American Society of Mechanical Engineers (ASME) l Boiler and Pressure Vessel Code (Code) Class 1, 2, and 3 pumps and valves l be performed in accordance with Section XI of the ASME Code and applicable

addenda, except where relief has been requested and granted or proposed

alternatives have been authorized by the Commission pursuant to 10 CFR 50.55a(f)(6)(1), (a)(3)(1), or (a)(3)(ii). In order to obtain authorization for relief, the licensee must demonstrate that: (1) conformance is

impractical for its facility; (2) the proposed alternative provides an i acceptable level of quality and safety; or (3) compliance would result in a

hardship or unusual difficulty without a compensating increase in the level j of quality and safety.

1 l We have completed our review of th~ e Comed requests for relief from the ASME i Code. The request for an allowed variance of i I psig for the diesel oil

' transfer pumps (Pump Relief Request PR-1) is granted pursuant to 10 CFR

{ 50.55a(f)(6)(1).

i' With regard to Relief Request VR-2, relief is granted pursuant to 10 CFR

! 50.55a(f)(6)(1) to verify the capability of the valves to stroke by i disassembly and inspection. Additionally, for four of the valves included in L the relief request (valves 1/2CS011A/B and 1/2CS020A/B), considering that it i would be a hardship without a compensating increase in the level of quality l and safety to require disassembly and inspection at the same time as the full

, flow testing, the proposed alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(ii). For performing disassembly and inspection during any i plant mode, the alternative schedule is authorized pursuant to 10 CFR i 50.55a(a)(3)(1) based on the activity ensuring an adequate level of quality I and safety, provided that Comed considers all of the appropriate guidance i referenced in our evaluation - including a determination that the activity can j be performed in a manner that does not increase the risk to the plant.

bD 5 54

• I I. M. Johnson i 4

! Relief Request VR-3 is granted pursuant to 10 CFR 50.55a(f)(6)(i) based on the F _ impracticalities in the design of the valves that limit inservice testing in

the traditional manner using position indicating lights. In implementing this relief request, Comed must include acceptance criteria in the test procedure

which is related to the method of verifying that the valves stroke during the l quarterly pump test.

Relief Requests VR-4 and VR-5 are granted pursuant to 10 CFR 50.55a(a)(3)(i) based on the acceptable level of quality and safety that the alternatives

, provide. Relief Request VR-6 is granted pursuant to 10 CFR 50.55a(f)(6)(1)

based on the impracticalities of the design for verifying closure of the

valves.

The alternative means of measuring flow through the check valve of train B of

{ the deep well pumps (Relief Request VR-7) is authorized pursuant to 10 CFR 50.55a(a)(3)(i). The proposal to test with measured flow once per 18 months is granted pursuant to the provisions of 10 CFR 50.55a(f)(6)(1) based on the

! impracticalities of the design not including permanently installed flow 3 instrumentation and the burden of using strap-on instrumentation quarterly.

1 i Relief Request VR-8 relates to components outside of the scope of 10-CFR 50.55a; therefore, Comed may implement the alternative without specific NRC approval.

1 l Relief Request VR-1 is denied because there is insufficient justification j provided for the establishment of a performance-based testing program for

certain check valves in lieu of quarterly exercising. C.nsequently, comed

must continue to perform leakage testing during each refueling outage.

3 The results of our review are included in the enclosed Safety Evaluation.

l Sincerely, i l }

Robert A. Capra, Director Project Directorate III-2 Division of Reactor Projects - III/IV Office of Nuclear Reactor Regulation Docket Nos. STN 50-454, STN 50-455 DISTRIBUTION: Docket'Fi1[

PUBLIC PDIII-2 R/F

Enclosure:

Safety Evaluation J. Roe, JWR E. Adensam EGAl R. Capra C. Moore cc w/ encl: see next page G. Dick OGC, 015B18 ACRS, T2E26 R. Lanksbury, RIII T.Scarbrough,;07E23- R. Campbell, 07E23 DOCUMENT NAME: BYRON \BY94432.SE *CONCURRENCEPROVIDEDBYMEM0DTDVl. Uhs; NO MAJOR CHANGES Ta receive e copy of this document, Indicety1Nhe goa: "C" = Copy without ejstjiMres *E* = Copy with enclosures "N" = No copy 0FFICE PM:PDIII-(2 ; f l _A:$AI-2 l D OGC -17D l d EMEP l PD:PDIII-2 l C.

NAME GDICK /M CMOSRiklm BNoLK4 *PCAMPBELL RCAPRA W DATE 10/;7/96' IV/c21/96 19/f/96 10/ /96 14/lff/96 0FFICIAL RECORD COPY 210069

l i

l I. Johnson Byron Station Commonwealth Edison Company- Unit Nos. 1 and 2

cc

Michael I. Miller, Esquire Chairman, Ogle County Board 2 Sidley and Austin Post Office Box 357

One First National Plaza Oregon, Illinois 61061 Chicago, Illinois 60603

. Mrs. Phillip B. Johnson i Regional Administrator, Region III 1907 Stratford Lane i U.S. Nuclear Regulatory Commission Rockford, Illinois 61107 801 Warrenville Road

, Lisle, Illinois 60532-4351 Attorney General

500 South Second Street i Illinois Department of Springfield, Illinois 62701

Nuclear Safety Office of Nuclear Facility Safety EIS Review Coordinator j 1035 Outer Park Drive U.S. Environmental Protection Agency 4

Springfield, Illinois 62704 77 W. Jackson Blvd.

. Chicago, Illinois 60604-3590 l Document Control Desk-Licensing  !

Commonwealth Edison Company Commonwealth Edison Company j i 1400 Opus Place, suite 400 Byron Station Manager ,

1- Downers Grove, Illinois 60515 4450 North German Church Road .

i Byron, Illinois 61010

Mr. William P. Poirier,. Director ,

Westinghouse Electric Corporation Kenneth Graesser, Site Vice President  ;

j Energy Systems Business Unit Byron Station i Post Office Box 355, Bay 236 West Commonwealth Edison Station Pittsburgh, Pennsylvania 15230 4450 N. German Church Road 4 Byron,. Illinois 61010

' Joseph Galle

! Gallo & Rcss

1250 Eye St., N.W.

l Suite 302 i Washington, DC 20005 I

Howard A. Learner Environmental law and Policy

Center of the Midwest 203 North LaSalle Street 1 Suite 1390 j Chicago, Illinois 60601

{ U.S. Nuclear Regulatory Commission

Byron Resident Inspectors Office

. 4448 North German Church Road i Byron, Illinois 61010-9750 Ms. Lorraine Creek Rt. 1, Box 182 Manteno, Illinois 60950