ML20138R871
| ML20138R871 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 10/31/1985 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20138R872 | List: |
| References | |
| TAC-60876, NUDOCS 8511190169 | |
| Download: ML20138R871 (6) | |
Text
f UNITED STATES y
g NUCLEAR REGULATORY COMMISSION Iw
'j WASHINGTON, D. C. 20555
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SUPPLEMENTAL SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR' REGULATION i-RELATED TO REQUESTS FOR RELIEF FROM INSERVICE TESTING REQUIREMENTS NORTHEAST NUCLEAR ENERGY COMPANY, ET AL.
MILLSTONE NUCLEAR POWER STATION, UNIT N0. 2 DOCKET NO. 50-336 Introduction Technical Specification 4.0.5 for the Millstone Nuclear Power Station, Unit No. 2 (Millstone 2) states that inservice testing (ISI) of ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code (the Code)(and applicable Addenda, as required by 10 CFR 50.55a(g). 10 CFR 50.55a(g) 6)(1) authorizes the Commission to grant relief from Code requirements and to impose such alternative requirements as it determines is authorized by law upon making the necessary findings.
By letter dated June 25, 1979, Northeast Nuclear Energy Company, et al. (NNECo)
(the licensee), submitted its pump and valve inservice testing program. The program was revised by letter dated May 1,1981. The staff issued on May 4,1983, a safety evaluation of its review of the licensee's proposed inservice testing program. The staff's safety evaluation delineated cases in which requested relief can be granted as requested, cases where relief cannot be granted and others where testing or alternate testing would be necessary.
The staff found that the licensee had included all appropriate safety-related pumps and valves in the IST program except those in the fire protection system, emergency diesel generator auxiliary system and certain containment isolation valves. The staff recognized the potential for certain code test requirements to be impractical for some components and the existence of adequate alternate surveillance testing. However, the staff stated its position that all safety-related pumps and valves be included in the IST program.
By letter dated March 12, 1984 and May 4, 1984, the licensee provided responses to the staff's safety evaluation of May 4, 1983. This supplemental safety evaluation addresses the licensee's responses to the staff's safety evaluation.
Evaluation and Discussion The staff's review of the licensee's March 12, 1984 and May 4, 1984 responses to the staff's May 4,1983 safety evaluation of NNECo's inservice testing program identified the need for additional information.
In a "A04477, Provides Addl Info Re Design of Reactor Coolant Pump P-1 Snubber Support Per DG Eisenhut .Error in Calculator Not Considered Reportable Per [[CFR" contains a listed "[" character as part of the property label and has therefore been classified as invalid..55|letter dated December 7,1984]], the staff addressed licensee positions taken that were counter to certain positions taken in the staff's May 4,1983 safety evaluation, 8511190169 851031 PDR ADOCK O y6 0
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The licensee responded by letter dated January 31, 1985 with additional j
i information regarding positions countering the placing of the emergency diesel i
generator (EDG) auxiliary systems into the IST program and testing in accordance with ASME Section XI. The letter also included a revised relief request for safety injection valves 2SI-215, 225, 235, 245. The licensee did not submit an EDG inservice testing program description as requested by the staff but instead maintained a position that the EDG auxiliary systems were not required to meet ASME Section XI because the auxiliary systems were "not required to be constructed in accordance with the ASME Section III" Code requirements.
The staff held a meeting with the licensee at Millstone 2 on March 28 and 29,1985 to review the EDG auxiliary system testing being done and to pennit further i
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assessment of the Itcensee's testing for which they stated assured EDG reliability.
The following evaluation addresses the licensee's responses, relief requests and testing being done.
Fire Protection System 4
Based upon the evolution of other requirements for fire protection and the focus of the IST program to include only safety related and safe shutdown components, the staff now concludes that the Millstone 2 fire protection system's pumps and valves are not required to be under ASME Section XI and incorporated in the inservice testing program. The staff hereby rescinds its May 4, 1983 request that the subject fire protection system be included as part of the inservice testing program.
Relief Request Concerning Testing of Safety Injection Tank Outlet Check Valves
.l The licensee's January 31, 1985 response submitted a revised relief request to their inservice test program for the Category C safety injection valves 251-215, 225, 235 and 245. The licensee proposed an alternate testing method stating that the valves will be full-stroke exercised during refueling shutdowns and that the valves cannot be effectively part-stroke tested during reactor operation or cold shutdown.
Considering the existing system design, the staff finds that the alternate testing proposed by the licensee to full-stroke exercise the valves using a flow method during refueling shutdowns to be an acceptable alternate. Therefore, j
the relief requested for safety injection valves 2SI-215, 225, 235 and 245 is granted for full stroke exercising at refueling shutdown frequency (not to exceed 2 years).
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I 3-Inservice Testing for Emergency Diesel Generator (EDG) Auxiliary Systems The staff's onsite review examined the licensee's "EDG perfomance' testing program" to ascertain if individual safety related components weres.being tested i
in each EDG auxiliary system commensurate with the component testing required by Section XI on a quarterly and/or refueling outage testing frequency. The i
review included the licensee's weekly, technical specification, and refueling outage EDG testing.
The licensee's weekly testing program delineated within station procedures is to start each EDG and run it under a 2100 KW load for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. This testing also alternates (every 2 weeks) the redundant air start tanks for each EDG to i ~
check air start redundancy. The refueling outage EDG testing runs the EDGs j
under full load.
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The staff's review of the licensee's positions and actual testing being i
performed on the safety related EDG auxiliary systems identified specific i
components in the EDG auxiliary systems that require additional or alternate inservice testing to verify operational readiness of the components. Although the licensee did not submit their EDG inservice testing program to the staff l
for review, the staff's onsite review of the actual testing determined that the
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4 licensee's EDG testing, if continued, was acceptable with exceptions as i
discussed in the following paragraphs.
The licensee has detemined and the staff agrees that conformance with certain code requirements under 10 CFR 50.55a is impractical for their facility, namely, the EDG auxiliary systems were not designed and constructed to ASME Section III Code Class 1, 2 and 3.
However, the staff noted that the licensee has not established that testing of safety-related components to the IST criteria of ASME Section XI, subsections IWP and IWV is impractical.
The staff's review found that the licensee was not testing certain of the safety-related EDG components to the maximum extent practical to assure operational readiness. As promulgated in 10 CFR 50.55a, the staff bases safety-related pump and valve component testing to assure operational readiness upon acceptance criteria delineated in ASME Section XI. The staff's onsite review identified that the following safety related components were not being tested i
to the extent practical to assure operational readiness.
i Service Water Cooling for EDG Heat Exchangers The system testing being done by the licensee did not measure valve stroke times. The following valves should be exercised / timed to the requirements of IWV-3410.
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FV 6341 FV 6342 FY 6389 FV 6397 l
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Diesel Fuel Oil System
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The following relief valves were not being tested. The valves s'hould be tested to meet IWV-3510.
I PSV 7016 PSV 7017 The following check valves were not being tested for seat leakage. The valves should be tested to meet IWV-3420.
FO-14 F0-85C F0-85D F0-67A FO-67B F0-29 FO-67C F0-67D FO-85A F0-85B The following thermally fusable valves were not being exercised. The valves should be exercised tested per IWV 3410.
F0-79 F0-80 Valve FO-70 should be position verified per IWV-3300.
Starting Air System The following relief valves were not being tested. These valves should be tested per IWV-3510.
PSV 8952 PSV 8953 The following check valves were not being tested for seat leakage. These valves should be tested to meet IWV-3420.
DG-29A DG-35A DG-29B DG-35B DG-29C DG-35C DG-29D DG-350 Lube Oil System The following relief valves were not being tested. These valves should be tested per IWV-3510.
PSV-8797 PSV-8798 l
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Jacket Cooling System The following relief valves were not being tested. Thesevalvesshouldbe tested per IWV-3510.
F PSV-8743 PSV-8744 The staff's review of the EDG testing also found that the controls associated with the component inservice testing program under ASME Section XI were missing from the licensee's program. The IST program under Section XI includes a sumary listing of components in the program, portrayal of current testing status, limiting values of observed parameters, mandated corrective action for component failures, detail records of testing and records of corrective action The controls under 50.55a also require relief be obtained from NRC for changr-in the testing program and conformance of the technical specifications to the inservice testing program when revised.
The staff finds that the licensee has not provided specific technical bases as to why the safety-related EDG auxiliary system components cannot be tested under the IST program and incorporated into the IST program. The staff concludes that meeting the testing requirements of Section XI Subsections IWP and IWV, is important to achieve testing control and added assurance of the operational readiness for all safety-related components.
The staff hereby denies the licensee's argument / request 1) to omit the safety-related EDG auxiliary system components from the inservice testing program and 2) to not meet the testing requirements of ASME Section XI, Subsections IWP and IWY. Therefore, the testing currently being done to the extent necessary to reflect compliance with the EDG pump and valve component testing requirements of Section XI should be incorporated into the IST program.
In addition, the EDG components not being tested and other items discussed should be included into the IST program to meet Section XI to the extent practical.
i Relief may be requested and/or alternate testing proposed where it is demonstrated that the testing requirements of the code or addenda for individual components is determined to be impractical.
The staff further concludes that the following EDG auxiliary systems should be included in the IST program.
EDG Service Water Starting Air Systems Lube Oil System Jacket Cooling System Air Cooling System Diesel Fuel Oil System Air Supply to EDG Service Water Valves t
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6-The licensee should submit a schedule within 60 days for submittal'of their EDG IST program and for completing conformance of the safety related EDG auxiliary systemstotheinservicetestingprogramandthetestingrequirem(ntsofASME Section XI, Subsections IWP and IWV. The testing currently beingidone should be continued until the Code required testing can be done. Relief is granted from Section XI, Subsections IWP and IWV for an additional 6 months from the date of this evaluation to permit the licensee time to conform their testing to the code.
Based on the review sunnarized herein, the staff concludes that the relief granted and alternate testing imposed through this document for Code requirements that are considered impractical, give reasonable assurance that the pump and valve operational readiness intended by the Code will be satisfied.
i Additionally, there is reasonable assurance that the health and safety of the
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Therefore, in accordance with 10 CFR 50.55a(g)(6)(proposed manner.1), we find the re public will not be endangered by operation in the i
requested may be granted. The relief 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.
Date: October 31, 1985 Principal Contributor:
Donald Caphton, Region I e
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