ML20148J735

SER of First 10-yr Inservice Testing Program Plan & Requests for Relief from Requirements Concluding That Program as Modified by SER Provides Reasonable Assurance of Operational Readiness of safety-related Pumps & Valves

ML20148J735
Person / Time
Site:	Wolf Creek
Issue date:	01/15/1988
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20148J705	List: ML20148J702 ML20148J735 ML20148J809
References
NUDOCS 8801270470
Download: ML20148J735 (12)

Text

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ENCLOSURE 1

', SAFETY EVALUATION REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATIONS RELATED TO THE IN5ERVICE TESTING PROGRAM AND REQUEST 5 FOR RELIEF UNION ELECTRIC COMPANY WOLF CREEK GENERATING STATION DOCKET NO.: 50-482 INTRODUCTION Technical' Specification 4.0.5 for the Wolf Creek Generating Station (WCGS) states that inservice inspection of ASME Code Class 1, 2 and 3 componenta and inservice testing (IST) of ASME Code Class 1, 2, and 3 pumps and valves shall be perfomed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable addenda as required by 10 CFR Part 50, Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR Part 50, Section 50.55(g)(6)(1). Certain requirements of the applicable Code edition and addenda of Section XI are impractical to perform becease of certain plant system and component designs.

Regulation 10 CFR 50.55(g)(6)(i) authorizes the Connission to grant relief from these requirements upon making the necessary findings. This Safety Evaluation Report (SER) contains NRC staff's findings with respect to granting or not granting reiiefs submitted as part of the licensee's IST program.

By letters dated September 5 and 18, 1981, Kansas Gas and Electric Company (KG&E) submitted its first ten year IST program and additional information related to requests for relief from certain code requirements detemined to be impractical to perfom on the Wolf Creek Generating Station. Subsequent revisions were provided by letters dated July 31, 1984 February 25,1985 July 29,1985, June 10, 1986, and March 2, 1987. Additional infomation was submitted by letters dated April 24, 1987 and September 11, 1987, 2

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r The original program was based on the requirements of the 1977 Edition through the Summer of 1978 Addenda of Section XI of the ASME Code. However, revisions were made to the program such that the IST program now meets the requirements of the 1980 Edition through Winter of 1981 Addenda to Section XI of the ASME Code and remains in effect until September 3,1995.

EVALUATION

! The IST program and 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 shutdown have been reviewed by the staff's con-tractor,EG&G, Idaho,Inc.(EG&G). In addition to the review of the IST program, justifications for cold shutdown as opposed to quarterly testing, and relief requests, EG&G and staff members met with KG&E representatives on September 8 and 9,1986, at the SNUPPS office in Gaithersburg, Maryland, to discuss questions resulting from the review. The Technical Evaluation Report (TER) provided in Attachment 1 is EG&G's evaluation of the licensee's IST program and relief requests.

- The staff has reviewed the TER and with one exception noted below concurs with the evaluations and conclusions 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 6ny commitments made by the licensee in its basis for each relief request and the alternate proposed testing.

In request PR 8 evaluated in TER Section 3.3.2, KG&E requested relief from the flow measurement requirements in Section XI, paragraph IWP-4600, for the boric acid transfer pumps PBG02A and PBG02B and the emergency fuel oil transfer pumps PJE01A and PJE01B. The licensee indicated in the relief request that there is no flow

instrumentation it. stalled in the flow paths of these pumps and that the pump j tests are perfomed with the system lined up in a recirculation flow path or fixed resistance flow path.

The licensee has not provided sufficient infonnation to demonstrate that installation of flow measurements devices is impractical. In order for I the licenseee to assemble the information necessary to support their request relief, interim relief on request PR 8 is granted until November 30, 1988.

This relief is based upon the testing of these pumps which, except for flow I measurement, is in accordance with the Code, the fact that the flow devices are not presently installed, and a reasonable length of time to assemble the necessary data. The licensee should include, as appropriate, proposed alter-native testing that permits measurement of Code required parameters at a decrested frequency such as cold shutdown or refueling. The licensee should justify the present or proposed alternative testing in terms of all the

- potential pump failure mechanisms for these pumps and the means by which the IST ,

i program will detect degradation. The licensee should include in their discussion, l as necessary, the pump vibration monitoring techniques to be used, failure rates for similar pumps in use at nuclear power plants, and scheduled maintenance per-fomed on these purps.

In the TER EG&G also identified several deficiencies and inconsistencies in the Wolf Creek 15T program. These items are listed and sumarized in Appendix C of

4 the TER and in most cases also discussed in the body of the TER. The licensee is 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 SER.

INSPECTION An inspection of the Wolf Creek Station IST program should be conducted by Region IV. The inspection should focus on the adequacy of implementing procedures for the IST program, satisfactory actions to resolve the items addressed in Appendix C of the TER, and programmatic aspects of the Wolf Creek IST program / procedures and changes to the same.

CONCLUSION Based on the review of the licensee's IST program and relief requests, the staff

- concludes that the IST program as evaluated and modified by this SER will provide reasonable assurance of the operatioral readiness of safety-related pumps and valves to perfom their safety-related functions. The staff has detemined that pursuant to 10 CFR 50.55a(g)(6)(1) granting relief where the Code requirements are impractical is authorized by law and will not endanger life or property, or the ]

conron defense and security. The staff has also concluded that granting relief I l

is otherwise in the public interest considering the burden that could result if the requirements were imposeri on the facility. During the review of the licensee's )

inservice testing program the staff identified certain misinterpretations or l

I omissions of Code requirements. These items are discussed in the TER. The IST l 1

program for Wolf Creek through the submittal dated March 2, 1987, is acceptable l for implementation provided that the items noted above are corrected promptly.

Relief requests contained in any subsequent revisions may not be implemented without prior approval by NRC.

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SUMMARY

OF RELIEF RE0 VESTS 1

Relief TER Section XI Requirement / Alternate Relief Action Request Section Subject / Pump or Valve Method of by USNRC Number Number Testing PR 1 3.1.1 IWP 3100-1 None Granted only for Bearing temperature pumps without per- l

, measurement manently installed All pumps in program temperature moni-tors or are inac- l cessible for port- l able temperature l measuring device

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PR 12 3.2.1 IWP 4120 Detector Granted l Full scale range re- with multi- l quirement ple over lap-All pumps in program ping scales PR 6 3.2.2 IWP 4110-1 Level indi- Granted Instrument accuracy cator of plus requirement or minus 2.5%

PJE01A & B l

PR 3 3.3.1 IWP 3100-1 Measure pump Granted Inlet pressure suction fluid measurement height PEF 01A & B PJE01A & B l i

PR 8 3.3.2 IWP 4600 None Interim Flow rate meter Relief Granted PBG02A & B until Nov. 30, PJE01A & B 1988 i

l Relief- TER Section XI Requirement / Alternate Relief Action J

, Request Section Subject / Pump or Valve Method of by USNRC l Number Number Testing PR 4 3.4.1 IWP 3100-1 None Granted Vibration measurement PJE01A & B PR 9 3.4.2 IWP 4510 Motor bear- Granted, provid-

. Vibration measurement ings housing ed licensee mea-

location sures vibration PEF 01A & B on bearing hou-sing with motor thrust bearing PR 10 3.5.1 IWP3500(a) 1 minute Granted I l

Test duration pump run af- 1 PJE01A & B ter discharge pressure sta-bilizes Ph 11 3.5.2 IWP 3100-2 & 3230(b) Increase Denied Required action (high) Alert range j

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& Alert range (high) (high)to limits & corrective 105%; delete action for flowrate Required ac-

& differential pres- tion (high) sure measurements range limit &

PALO1A & B, PALO2, corrective pc-PBG05A & B, PEF 01B, tion for flow-PEG 01A, B, & C, rate & differ-PEJ01A & B, PEM01A, ential pressure PJE01A & B, PEC01A & B measurements

Relief TER Section XI Requirement / . Alternate Relief Action Request Section Subject / Pump or Valve Method of by USNRC Number Number Testing VR 22 4.1.1.1 IWV 3417(a). Test degra- Denied Corrective action ded valves Cold shutdown exer- during cold cised power operated shutdowns &

valves refueling

- outages VR 5 4.1.2.1 IWV 3421 through 3425 10 CFR 50 Granted, provid-Leak rate testing Appendix J ed licensee also Containment isolation testing implements Sect-valves ion XI, IWV 3426 &

3427 requirements VR 21 4.1.3.1 IWV 3421 through 3427 Leak rate Granted Leak rate testing testing in RCS pressure isola- accordance tion valves with Techni-cal Specific-ations 3.4.6.2.f

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& 4.4.6.2.2 VR 4 4.1.3.2 IWV 3522 RCS pres- Granted Verify valve sure iso-closure lation leak RCS pressure isola- rate testing tion valves e e a ,e m e

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l Relief TER Section XI Requirement / Alternate Relief Action  !

Request Section Subject / Pump or Valve Method of by USNRC Number Number Testing  !

VR 11 4.2.1.1 IWV 3300 Disconnect Granted Remote valve position position in-indication verifica- dication tion switch a sim- l 8010A, B, & C ulate valve movement l

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VR 3 4.2.2.1 IWV 3522 Closure verifi- Granted Verify valve closure cation during Vll8, 148, 178, & 208 refueling outage leak rate testing I

VR 12 4.2.2.2 IWY 3522 Full-stroke ex- Granted Full-stroke exercise ercise during re-V001, 022, 040, & 059 fueling outages VR 10 4.2.2.3 IWV 3522 Full-stroke ex- Granted l Full-stroke exercise ercise during re-8949A, B, C, & D fueling outages VR 9 4.2.2.4 IWV 3522 Partial-stroke ex- Denied Full-stroke exercise ercise during re-8948A, B, C, & D fueling outages l VR 2 4.3.1.1 IWV 3522 Full-stroke ex- Granted Full-stroke exercise ercise during re- l 8481A & B fueling outages l VR 19 4.3.1.2 IWV 3522 Full-stroke ex- Granted Full-stroke exercise ercise during re-8546A & B fueling outtges i

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o 3 Relief TER Section XI Requirement / Alternate Relief Action l f Request Section Subject / Pump or Valve Method of by USNRC Number Number Testing l

VR 3 4.3.2.1 IWV 3522 Closure verifi- Granted ,

Verify valve closure cation during l V8381 refueling outage leak rate testing l

. VR 3 4.4.1.1 IWV 3522 Closure verifi- Granted

Verify valve closure cation during l

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V204 refueling outage 1 leak rate testing l l

VR 20 4.5.1.1 IWV 3522 Full-stroke ex- Granted l Full-stroke exercise ercise during re-  ;

8958A & B fueling outages l l

VR 18 4.5.1.2 IWV 3522 Full-stroke ex- Granted Full-stroke exercise ercise during re-8969A & B fueling outages l l

VR 7 & 4.6.1.1 IWV 3522 Full-stroke ex- Granted

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VR 8 Full-stroke exercise ercise during re-8922A & B, 8926A & B fueling outages VR 13 4.6.2.1 IWV 3522 Full-stroke ex- Granted Full stroke exercise ercise during re-V001, 002, 003, & 004 fueling outages i VR 12 4.6.2.2 IWV 3522 Full-stroke ex- Granted Full-stroke exercise ercise during re-V240, 241, & 8815 fueling outages

l Relief TER Section XI Requirement / Alternate Relief Action Request Section Subject / Pump or Valve Method of by USNRC Number Number Testing VR 15 4.7.1.1 IWV 3522 Disassembly /in- Granted Full-stroke exercise spection/ manual V002, 008, 013, & 017 full-stroke exer- )

cising during cold  !

shutdowns l

VR 17 4.7.1.2 IWV 3522 Partial-stroke ex- Denied Full-stroke exercise ercise every 3 V003, 004, 009, & 010 months i VR 14 4.8.1.1 IWV 3522 Partial-stroke ex- Denied i Full-stroke exercise ercise during re-8956A, B, C, & D fueling outages VR 13 4.8.1.2 IWV 3522 Full-stroke ex- Granted Full-stroke exercise ercise during re-V010, 020, 030, & 040 fueling outages VR 16 4.9.1.1 IWV 3522 Test series Denied i

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Full-stroke exercise check valves as V001, 002, 024, & 025 single check valve VR 3 4.10.1.1 IWV 3522 Closure verifi- Granted Verify valve closure cation during V204 refueling outage leak rate testing

Relief TER Section XI Requirement / Alternate Relief Action Request Section Subject / Pump or Valve Method of by USNRC Number Number Testing.

VR 6 4.11.1.1 IWY 3413 Measure Granted Stroke time measure- time die-ment sel requi-  !

PVIA & B, 101A & B res to reach I rated speed &

. observe start-

- ing air tank pressure chan-ges

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