ML20148C959

Safety Evaluation Concluding That Inservice Testing Program Submitted w/860730 Ltr as Modified in Subj Safety Evaluation Will Provide Reasonable Assurance of Operational Readiness of safety-related Pumps & Valves

ML20148C959
Person / Time
Site:	Cooper
Issue date:	01/13/1988
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20148C951	List: ML20148C948 ML20148C959
References
NUDOCS 8801250297
Download: ML20148C959 (9)

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d o g UNITED STATES

[ g NUCLEAR REGULATORY COMMISSION g :j W ASHING ton, o. C. 20555

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ENCLOSURE 1 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE INSERVICE TESTING PROGRAM AND REQUESTS FOR RELIEF NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION DOCKET NO.: 50-298 INTRODUCTION l

l The Code of Federal Regulations, 10 CFR 50.55a(g), requires that inservice inspection of ASME Code Class 1, 2, and 3 components and intervice testing (IST) of ASME Code Class 1, 2, and 3 pumps and valves shall be performed in i accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable addenda, except where specific written relief has been requested by the licensee and granted by the Commission pursuant to 10 CFR 50.55a(g) (6)(i).

In requesting relief, the licensee must demonstrate that conformance with cer-I tain requirements of the applicable Code edition and addenda is impractical for its facility.

Regulation 10 CFR 50.55a(g)(6)(i) authorizes the Commission to grant relief l from these requirements upon making the necessary findings. This Safety Evalua-1 tion (SE) contains the NRC staff findings with respect to granting or not granting the relief requested as part of the licensee's IST program.

The IST program addressed in this report covers the second ten year inspection interval from July 1, 1984. By a letter dated June 15, 1984, Nebraska Public Power District (NPPD) submitted an IST program for Cooper station. A revised program was provided by letter dated July 30, 1986 which superseded the previous submittal.

The program is based on the requirements of the 1980 edition through the Winter of 1981 Adderida of Section XI of the ASME Code and remains in effect until July 1, 1994.

EVALUATION l The IST program, the requests for relief from the requirements of Section XI that have been determined to be impractical to perform and the justification for testing certain valves at cold shutdowns have been reviewed by the staff and its contractor, EG&G Idaho, Inc., (EG&G). In addition to the review of the IST program, cold shutdown justifications, and relief requests, EG&G and staff members met witn licensee representatives on April 15 and 16, 1986 in a working session to discuss questions resulting from the review. The Technical Evaluation 8801250297 880113 PDR P ADOCK 05000298 PDR

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Report (TER) provided in Attachment 1 is EG&G's evaluation of the licensee's  ;

inservice testing program and relief requests. The staff has reviewed the Tr.R ,

and concurs with and adopts as part of this SER the evaluations and conclusions i contained in the TER. A summary of the relief request determinations is presented

' in Table 1. The granting of relief is based upon the fulfillment of any commit-ments made by the licensee in its basis for each relief request and the alter- ,

nate proposed testing.

In the TER EG&G identified several deficiencies and inconsistencies in the Cooper IST program. These items are listed and summarized in Appendix C of the t j TER and in most cases also discussed in the body of the TER. The licensee is i required to address each of these items by either correcting the IST program and testing procedures and/or by providing the NRC with the appropriate relief requests and supporting bases. These items should all be corrected within 3 months of the date of this SE.

l CONCLUSION l

Based on the review of the licensee's IST program and relief requests, the r staff concludes that the IST program as evaluated and modified by this SE will provide reasonable assurance of the operational readiness of safety-related  ;

pumps and valves to perform their safety-related functions. The staff has '

determined that pursuant to 10 CFR 50.55a(g)(6)(i) granting relief where the l Code requirements are impractical is authorized by law and will not endanger life or property, or the common defense and security. The staff has also con-cluded that granting relief is otherwise in the public interest considering the burden that could result if the requirements were imposed on the facility.  !

j During the review of the licensee's inservice testing program the staff identi-fied certain misinterpretations or omissions of Code requirements. These items

are discussed in the TER. The IST program submitted for Cooper, Dated July 30, 1986, is acceptable for implementation provided the items noted above are cor-rected promptly. Relief requests contained in any subsequent revisions may not be implemented without prior approval by NRC. l Staff Reviewer: Y. Li i

Attachment:

Table 1 l Dated: January 13, 1988 r

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o Cooper Nuclear Station Table 1 Summary of Relief Requests Relief Proposed Relief Request TER Section XI Requirement / Alternate Test Action by Number Section Subject / Pump or Valve Number Method USNRC RP-01 3.1.1 IWP-3300, Annual bearing None Granted temperature measurement All pumps in program RP-02 3.2.1 IWP-3100, Inlet and Discharge Granted differential pressure pressure and measurement flow rate Standby Liquid Control measurement pumps SLC-1A and -1B RP-03 3.4.1 IWP-3100, Vibration Vibration Granted measurement measurement Service Water pumps at the motor SW-1A, -18, -1C and -10 RP-04 3.1.2 IWP-3100 and -4510 Vibration Denied Vibration measurement velocity All pumps in program measurements except SLC-1A and -1B REC-1A, -1B, -10, and -10, DG-FOT-1A and -1B RP-05 3.3.1 IWP-3100, Establish a Duplicate pump Denied reference pump speed flow rate and Hi h Pressure coolant discharge pressure in ection pump HP-1 RP-06 3.5.1 IWP-3400, All pume Utilize station Denied test Reactor Equipment surveillance pro-Cooling pumps REC-1A, -1B, cedure 6.3.16.1

-1C and -10 RP-06 3.6.1 IWP-3100, All pump tests Utilize station Denied Diesel generator fuel oil surveillance pro-transfer pump DC-f0T-1A cedures 0.3.12.1 and -1B & 6.3.12.8

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j Relief Proposed Relief l

Request TER Section XI Requirement / Alternate Test Action by

Number Section Subject / Pump or Valve Number Method USNRC l 1  :

RV-01 4.1.1.1 IW-3420 through -3425 Utilize 10 CFR 50 Granted, l

' Containment isolation Appendix J provided valves Type C Leak Rate licensee Testing also  :

' Implements ,

Section XI, IW-3426 &

-3427 re-quirements  ;

RV-04 4. 8.1.1 IW-3417(a) Stroke Stroke time Granted <

) in accordance 4 time measurement Main steam isolation with Tech.

valves MS- A0-80A, Specs.  !

-80B, -800, and -800 i

MS-AO-86A, -868, -86C,

and -860 RV-05 4.7.1.1 IW-3400 and -3520 Verify closure Granted Quarterly exercise during refueling  !

Reactor feedwater line outage leak test

. checks RF-CV-13, -14, i

-15, and -16 RV-06 4.11.2.1 IW-3400, Quarterly Exercise Granted i exercising : cram inlet during scram and outlet CRD-CV-126 testing i J and -127 i

! t j RV-06 4.11.3.1 IW-3520, Quarterly Full stroke Granted  !

exercising Control rod during control l

l. scram discharge header rod scram testing l check CRD-CV-114 l l

I RV-07 4.11.3.2 IW-3420, Quarterly leak testing Granted  ;

exercising during refueling t Accumulator charging outage ,

I header checks CRO-CV-115 I

RV-08 Appendix C This request is unnecessary because the licensee meets 1 I

I the code requirement.

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Relief Proposed Relief Request TER Section XI Requirement / Alternate Test Action by N_ umber Section Section/ Pump or Velve Number Method USNRC RV-09 4.12.1.1 IW-3520, Quarterly Verify proper Granted exercising operation of Diesel generator service diesel generator water supply checks monthly and dis-SW-CV-35CV, -26CV assemble every

-37CV, and -38CV third refueling RV-10 Appendix C This request is unnecessary because the licensee meets the Code requirement.

RV-11 4.1.2.1 IW-3400, -3420, and -3520 Modified leak Granted All excess flow check test during valves refueli:.g in accorda-ce with Tech. Specs.

4.7.D.1.d RF 12 4.14.2.1 IW-3522, Quarterly Verify valve Relief is exercising open during daily unnes-Reactor equipment operation and sary for cooling pump discharge monthly testing for all checks REC-CV-10, -11, -12, per surveillance listed

-13, Containment cooling procedure 6.3.16.1' valves supply check REC-CV-15, except Noncritical cooling return REC-CV-16 header check REC-CV-16 Denied for REC-CV-16 RV-13 4.14.1.1 IW-3400, Quarterly Utilize station Denied testing surveillance Reactor equipment cooling procedure 6.3.16.2 system power operated valves REC-H0-694, -695, -697

-698, -700, -702, -709

-711, -714, -712, -713,

-721, -722, and -1329 l

RV-14 4.2.1.1 IW-3520, Quarterly Verify closure Granted exercising of at least one  !

Core spray pres:ure of the two in maintenance checks, series check ,

CS-CV-12, -13 valves quarterly  !

-14, and -15

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Relief Proposed Relief Request TER Section XI Requirement / Alternate Test Action by Number Sec'.l on Subject / Pump or Valve Number Method USNRC RV-15 4.3.1.1 IW-3520, Quarterly Verify closure Granted exercising of at least one Residual heat removci of the two in pressure maintenance series check checks, RHR-CV-18, -19 valves quarterly

-24, and -25 RV-16 4.5.2.1 IW-3250, Quarterly Verify closure Granted exercising of at least one High pressure coolant of the two in injection pressure series check maintenance checks valves quarterly HPCI-CV-18 and -19 RV-17 4.3.1.2 IW-3520, Quarterly Disassemble and Grcnted exercising manually full- Provided Service Water emergency stroke exercise disassembly /

core flooding sLpply every third inspection RHR-CV-20 refueling is performed each refuelin!

outage RV-18 4.4.1.1 IW-3520, Quarterly Full-stroke Granted exercising during refueling Standby liquid control outages injection checks SLC-CV-12 and -13 RV-19 Appendix C This request is unnecessary because the licensee meets the code rect' ement.

RV-20 4.5.2.2 IW-3520, Quarterly Disassemble and Granted exercising manually full- Provided High pressure coolant stroke exercise disassembly /

injection suppression every third inspection pool suction HPCI-CV-11 refueling is performed each refuelir outage RV-21 4.5.1.1 IW-3400 and -3520 Exercise open Granted Quarterly exercising quarterly and ,

High pressure coolant verify closure l injection turbine during refueling exhaust check and turbine drain check HPCI-LVSC-44 and -50 l

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9 Relief Propused Relief Request TER Section XI Requirement / Alternate Test Action by N_tanber Section Subject / Pump or Valve Number Method USNRC RV-22 4.5.2.3 IW-3520, Quarterly Manually Granted exercising full-stroke High pressure coolant exercise each injection turbine exhaust refueling line vacuum breakers HPCI-CV-24, -25, -26 and -27 RV-P_3 4.6.2.2 IW-3520, Quarterly Disassemble and Granted exercising manually full- provided Reactar core isolation stroke exercise disassembly /

cooling suppression pool every third inspection suction RCIC-CV-11 refueling is performed each refueling outage RV-24 4.6.2.1 IW-3520, Quarterly Verify closure Granted exercising of at least one Reactor core isolation of,the two in cooling pressure series check maintenance checks valves quarterly RCIC-CV-18 and -19 RV-25 4.6.1.1 IW-3400 and -3520 Exercise open Grar,ted Quarterly exercising quarterly and Reactor core isolation verify closure l cooling turbine exhaust during refueling check and barometric condenser vacuum pump discharge RCIC-LVSC-37 and -42 RV-26 4.6.2.3 IW-3520, Quarterly Manually Granted exercising full-stroke each Reactor core isolation refueling I cooling turbine exhaust vacuum breakers RCIC-CV-22, -23, -24, and -25 RV-27 4.8.2.1 IW-3400, Quarterly Full-stroke Granted exercise and stroke timing exercise without Main steam safety / reliefs, stroke timing MS-RV-71A, -71B, -710, -710, each refueling

-71E, -71F , -71G , and -71H

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Relief Proposed Relief Request TER Section XI Requirement / Alternate Test Action by Number Section Subject / Pump or Valve Number Method USNRC RV-28 4.8.3.1 IW-3520, Quarterly Manually Granted exercising full-stroke Main steam relief valve exercise each tail pipe vacuum breakers refueling outage MS-CV-21, -22, -23, -24

-25, -26, -27, -P.8, -29

-30, -31, -32, -33, -34, and -35 RV-29 4.15.1.1 IW-3522, Full-stroke Verify full- Granted exercising stroke each Relief valve accumulator refueling outage air supply checks IA-CV-17, -18, -19, -20,

-21, -22, -36, and -37 RV-30 4. 9.1.1 IW-3520, Quarterly Verify closure Granted >

exercising during refueling Reactor water cleanup outage leak rate return check test RWCU-CV-15 RV-31 4.11.1.1 IW-3520, Quarterly Verify closure Granted exercising during refueling Reactor recirculation outage leak rate pump seal water injection test checks CRD-CV-13, -14, -15.

and -16 RV-32 4.13.1.1 IW-3400, Quarterly Utilize station Denied exercising and stroke surveillance timing procedure 6.3.18.1 Service water system valves SW-M0-37, -117,

-886, -887, -888, -889,

-650, and -651 RV-33 Appendix C This request is unnecessary because the licensee meets ,

the Code requirements. l RV-34 4.13.1.2 IW-3413(b). Valve stroke Full-stroke Granted l timing exercise  !

Residual heat removal quarterly heat exchanger service without stroke  :

water outlets timing I SW-M0-89A and -89B l

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Relief Proposed Relief Request TER Section XI Requirement / Alternate Test Action by Number Section Subject / Pump or Valve Number Method USNRC RV-35 Appendix C This request is unnecessary because the licensee meets the Code requirements.

RV-36 4.10.1.1 IWV-3520, Quarterly Manually Granted exercising full-stroke '

Primary containment exercise each vacuum breakers refueling outage PC-CV-13 and -14 RV-37 4.16.1.1 IWV-3400, Quarterly Utilize station Denied exercising surveillance Standby gas treatment procedure 6.3.19.1 system SGT-249AV, -250AV, -251AV,

-252AV, -255AV, and -256AV l

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