ML20154J247

SER Accepting Inservice Testing Program,Third ten-year Interval for License DPR-51,Arkansas Nuclear One,Unit 1

ML20154J247
Person / Time
Site:	Arkansas Nuclear
Issue date:	10/09/1998
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20154J225	List: ML20154J221 ML20154J247 ML20154K301
References
NUDOCS 9810150199
Download: ML20154J247 (5)

Text

_ _

. Uruq y t UNITED STATES j

3

1. NUCLEAR REGULATORY COMMISSION 2 WASHINGTON, D.C. 2006H001

\...../

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO INSERVICE TESTING PROGRAM. THIRD TEN-YEAR INTERVAL FACILITY OPERATING LICENSE NO. DPR-51 ENTERGY OPERATIONS. INC.

ARKANSAS NUCLEAR ONE. UNIT NO.1 DOCKET NO. 50-313

1.0 INTRODUCTION

The Code of Federal Regulations,10 CFR 50.55a, requires that inservice testing (IST) of certain ASME Code Class 1,2, and 3 pumps and valves are performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code (the Code) and applicable addenda, except where alternatives have been authorized or relief has been requested by the licensee and granted by the Commission pursuant to Sections (a)(3)(i), (a)(3)(ii), or (f)(6)(i) of 10 CFR 50.55a. In proposing alternatives or requesting relief, the licensee must demonstrate that: (1) the proposed attematives provide an acceptable level of quality and safety; (2) compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety; or (3) conformance is impractical for its facility. NRC guidance contained in Generic Letter (GL) 89-04, Guidance on Developing Acceptable Inservice Testing Programs, provides alternatives to the Code requirements determined acceptable to the staff.

Section 10 CFR 50.55a authorizes the Commission to approve alternatives and to grant relief from ASME Code requirements upon making the necessary findings. The NRC staff's findings with resper.t to authonzing alternatives and granting or not granting the relief requested as part of the licensee's IST program are contained in this Safety Evaluation (SE).

The Arkansas Nuclear One, Unit 1 (ANO-1) IST Program is based on the requirements in the 1989 Edition of the Code,Section XI, Subsections IWP and IWV, which provide that the rules for IST of pumps and valves will meet the requirements set forth in the 1988 Addenda to the ASME Operations and Maintenance Standards, Part 6 (OM-6), " Inservice Testing of Pumps in Light-Water Reactor Power Plants," and Part 10 (OM-10), " inservice Testing of Valves in Light-Water Reactor Power Plants." The ANO-1 IST program covers the third ten-year IST interval.

ENCLOSURE 9810150199 981009 PDR ADOCK 05000313 P PDR

d 2.0 EVALUATION The NRC staff, with technical assistance from Brookhaven National Laboratory (BNL), has reviewed the information concerning IST program requests for relief submitted for the third ten-year intervals for ANO-1, in a Entergy Operations, Inc. (the licensee) letter dated December 1, 1997. The staff adopts the evaluations and recommendations for granting relief or authorizing alternatives contained in the Technical Evaluation Report (TER), included as Attachment 2 to this SE, prepared by BNL. Attachment 1 to this SE lists each relief request and the status of approval. The test deferrals of valves, as allowed by OM-10, were also reviewed. Results of this review are provided in Section 4.0 of the TER with recommendations for further review by the licensee for specific deferrals.

For the ANO-1 IST Program, relief is granted from, or alternatives are authorized to, the testing requirements which have been determined to be impractical to perform, where an alternative provides an acceptable level of quality and safety, or where compliance would result in a hardship or unusual difficulty without a compensating increase in quality or safety. Relief Request Number 12 was denied because the licensee's request for generic relief from the Code requirements related to certification of relief valve correlations was determined to be ineppropriate. Three relief requests were granted with provisions: Relief Request Numbers 2 and 5 were granted provided that the licensee evaluate partial stroke exercising the check valves as specified in GL 89-04, Position 2; and Relief Request Number 8 was authorized provided that there are no owner-established acceptance criteria for these relief valves, based on system and valve design basis or technical specifications, more stringent than i2% of the nameplate set pressure.

BNL, using the ANO-1 Updated Final Safety Analysis Report, conducted a scope review for the following systems against the requirements of Section XI and the regulations: emergency feedwater; intermediate cooling; service water; and makeup and purification systems. The review revealed five items that did not appear to be in compliance with the Code requirements (see Section 5.0 of the TER). The licensee should review these items, as well as other systems that might contain similar problems, and revise their program as appropriate.

The IST program relief requests which are granted or authorized are acceptable for implementation provided the action items identified in Section 6.0 of the TER are addressed within one year of the date of the SE or by the end of the next refueling outage, whichever is later. Additionally, the granting of relief is based upon the fulfillment of any commitments made by the licensee in its basis for each relief request and the alternatives proposed. Program changes involving new or revised relief requests must be submitted to NRC for review. New or revised relief requests that meet the positions stated in GL 89-04, Attachment 1, should be submitted to the NRC but may be implemented provided the guidance in GL 89-04, Section D, is followed. Program changes that add or delete components from the IST program should also be periodically provided to the NRC.

A discussion of the start date and length of the third ten-year interval for Unit 1 is included in Sections 1.0 and 6.1 of BNL's TER. The NRC staff authorized, in its letter and safety evaluation dated August 2,1994, an extension to the second ten-year interval and stated that the licensee had the flexibility to choose which subsequent interval to shorten. The licensee

-- - . . .- ~ - - -_ -- . _ .

i requested that the third ten-year interval begin December 2,1997 and end on December 2, 1997, and end on December 2,2007. Contrary to the finding in the TER, the staff finds this interval to be acceptable and consistent with the previous authorization which would allow the licensee to shorten the fourth interval or a subsequent interval if the plant lifetime is extended.

3.0 CONCLUSION

The ANO-1 IST program requests for relief from the Code requirements have been reviewed by the staff with the assistance ofits contractor, BNL. The TER provides BNL's evaluation of these relief requests. The staff has reviewed the TER and concurs with the evaluations and recommendations for granting relief or authorizing alternatives. A summary of the relief request determinations is presented in Attachment 1. The authorizing of alternatives or granting of relief is based upon the fulfillment of any commitments made by the licensee in its basis for each relief request and the alternatives proposed. For any relief granted pursuant to GL 89-04 the staff has reviewed the information submitted by the licensee to determine whether the proposed alternative follows the relevant position in the generic letter. The implementation of IST program and relief requests is subject to inspection by the NRC.

The licensee should refer to the TER, Section 6.0, for a discussion of recommendations identified during the review. The licensee should address each recommendation in accordance with the guidance therein. The IST program relief requests are acceptable for implementation provided the action items identified in Section 6.0 of the TER are addressed within one year of the date of this SE or by the end of the next refueling outage, whichever is later, unless otherwise specified in the TER. Contrary to the TER, the staff finds that the proposed beginning of the third ten-year interval on December 2,1997, and ending of the interval on December 2,2007, is acceptable.

The staff concludes that the relief requests approved herein will provide reasonable assurance of the operational readiness of the pumps and valves to perform their safety-related functions.

The staff has determined that granting relief pursuant to 10 CFR 50.55a (f)(6)(i) and authorizing alternatives pursuant to 10 CFR 50.55a (a)(3)(i) or (a)(3)(ii) are authorized by law and will not endanger life or property, or the common defense and security, and is otherwise in the public interest. In making this determination, the staff has considered the impracticality of performing the required testing and the burden on the licensee if the requirements were imposed. The reliefs which have been granted and alternatives which have been authorized in this SE are valid for the remainder of the ANO-1 third ten-year IST program interval.

Attachments:

1. Summary of Pump and Valve Relief Requests - ANO Unit 1

2. Technical Evaluation Report (TER), Brookhaven National Laboratory, June 30,1998

3. TER Agendix A, Evaluation of ANO-1's Valve Testing Deferral Justifications Principal Contributor: Joseph Colaccino, DE/EMEB

Attachinent 1-Sunensary of' Pump and Valve Relief Requests-ANO Unit 1 4

Relief TER Code Requirement Equipmeent Identification 7. , 24 Alternate Method of NRC Action Request Section Testing

=*

No.

I 3.2.1 Part 10,14.2.23(c), Dil-13A,13B,17,18; Decay heat Leak test valve group. No reliefis required _

Valve seat leakage removal system pressure isolation requirements valves 2 33.1 Part 10,143.2, HS-4A and B. Reactor building spray Sample disassembly andm' spection Relief granted in accordance ExerciseI;eq, .cy pump's discharge to headers check program. with 10CFR50.55a(fX6)(i),

valves with provisens.

3 33.2 Part 10,143.2, MS-271,272; Main steam to EFW Verify closure each refueling cycle A ; . e.m appmved in Exercise ficqwe y pump tubine check valves using non-intrusives. Full stroke accordance with exercise quarterly. 10CFR50.55a(aK3Xi).

4 333 Part 10,143.2, CS-293 and 294, CST to EFW pump Full-stmke exercise at least once each Alternative appmved in Exercise f. . y suction check valves refueling cycle using non-intrusives. accordance with Partial stroke exercise quarterly. 10CFR50.55a(aX3Xi).

, 5 33.4 Part 10,143.2, CA-61 and 62, Sodium flydroxide Sample disassembly and inspection Relief granted in accordance Exercise frequency Storage tank to reactor building program Partialstrokeexercise with 10CFR50.55a(fX6Xi),

spray pump stop check valves quarterly. with provisions.

6 2.1 Part 6,15.2, test P-4A, B, and C, Service Water Use reference pump curve. Relief granted in accordance reference values Pumps with 10CFR50.55a(fX6Xi).

• 7 2.2 Part 6,15.2, P-36A, B, and C,Iligh Pressure Test quarterly without measurement Relief granted in accordance Measurement of Injection Pumps of a portion of the flow through the' with 10CFR50.55a(fX6Xi).

flowrate mini-flow path. During cold shutdowns, isolate mini-flow path and measure total flow thmugh pumps.

> 8 3.1.1 Part 1,11.4.1.2, Set PSV-1412,1617. Reliefvalves on Establish accuracy to limit actual set Alternative appmved in h pressme the BWST and Sodium Ilydroxide pressure to 2% above the stamped set accordance with g measurement Storage Tank pressure 10CFR50.55a(aX3Xi),with g accuracy provisions.

4 e

, i

Attachnient 1-Sunimary of Pump and Valve Relief Requests-ANO Unit 1 Relief TER Code R; ,_ % t Equipment Identification Proposed Alternate Metimd of NRC Action Request Section Testing -

N.

9 3.1.2 Part 1,18.2, seat PSV-1412,1617, Relief valveson None. Alternative approved in

tightness testing the BWST and Sodium flydroxide . accordance with  ;

. Storage Tank 10CFR50.55a(s)(3)(ii).

10 3.1J Part 1,18.1.2.2, Test Various SRVs Use accumulator requirements in Alternative approved in

accumulator volume 1994 Addenda of OM Code. accordance with requirements 10CFR50.55a(a)(3)(i).

l 11 3.1.4 Part 1,18.1.2.4 and Vanous SRVs For valves tested under ambient No approval required to use 8.1J.4, Hermal conditions using a medium at ambient the clarification in the 1994

, equih%rnnn conditions, test ternperature will be Addenda of the OM Code.

recorded, however, no verification of Delicensee's basis for thermalequilibnum will be derming arabient as under performed. 150 deg. F is subject to NRC in8Pection.

12 3.1.5 Part 1,18.1.2.5 and Vanous SRVs Test at ambient temperatures using Relierdenied.

8.1J.5; Use of the cold differentialtest pressure alternate media provided by manufacturer or

(;.r.;-) cognizant eng'meer, without a conclation.

_ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _