ML20198P994

SE Authorizing Relief Requests for Third Interval Pump & Valve Inservice Testing Program

ML20198P994
Person / Time
Site:	Vermont Yankee
Issue date:	01/15/1998
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20198P978	List: ML20198P974 ML20198P994
References
NUDOCS 9801220309
Download: ML20198P994 (12)

Text

_ . . - --

,, pmwe p- A umisD stairs NUCLEAR REGULATORY COMMISSION

• WASHINGTON, D.C. seethe 01 SAFETY EVAlt1ATION BY THE OFFICE OF NtrlEAR REACTOR REQJLATION

,*ee,*

RELATED TO INSERVICE TESTING PROGRAM RELIEF REQUEST FOR VERMONT YANKEE NtfLEAR POWER CORPORATIOl VERMONT YANKEE NUCLEAR POWER STATION DOCKET NLNBER $0 271

1.0 INTRODUCTION

The Code of federal Regulations.10 CFR 50.55a, requires that inservice testing (IST) of certain American Society of Mechanical Engineers (ASME) Code Class 1, 2, and 3 pums and valves are performed in accordance with Section XI of the ASME Boffer and Pressure Vesse? Code (the Code) and applicable addenda, except where alternatives have been authorized or relief has been requested by the licensre and granted by the Comission pursuant to Sections (a)(3)(i). (a)(3)(11), or (f)(6)(i) of 10 CFR 50.55a. In proposing alternatives or requesting relief, the licensee must demonstrate that: (1) the proposed alternatives provide an acceptable level of quality and safety; (2) cogliance would result in hardship ur umsual dif ficulty without a compensating increase in the level of quality and safety; or (3) conformance is impractical for its facility. Section 50 55a authorizes the Comission to approve alternatives and to grant relief it0,n ASME Code requiremnts upon making the necessary findings. Guidance reloted to the developuent and implementation of IST programs is given in Generic letter (Ct ) 89-04. "Q idance on Developing Acceptable Inservice Testing Programs,* issued April 3. 1989, a d its Supplement 1 issued April 4, 1995. Also see NUREG-1482.

• Guidelines for Inservice Testing at Nuclear Power Plants.* and NUREG/CR 6396. "Eengles. Clarifications, and Guidance on Preparing Requests for Relief from Pug and Valve Inservice Testing Requirements,"

The 1989 Edition of the ASME Code is the latest edition incorporated b)r reference in Paragraph (b) of Section 50.55a. Subsection IWV of the 1989 Editico. which gives the requirements for IST of valves, references Part 10 of the Amrican National Standards Institute /ASME @erations and NJvntenance standards (on 10) as the rules for IST of valves. OH 10 replaces specific requirements in previous editions of Section XI. Subsection IWV, of the ASME Code. Subsection IWP of the 1989 Edition, which gives the requirements for IST of pums, references Part 6 of the American National Standards Institute /ASME Operatfons and Hafntenance Standards (OM 6) as the rules for IST of pumps. OH 6 replaces specific requirements in previous editions of Secticn XI. Subsection IWP of the ASME Code.

08#'

9001220309 990115 PDR ADOCK 03000271 P PM ,

.: u 2

By letters dated Deceeer 19,1996. August 13, 1997, and Septeeer 10, 1997.-

Vermont Yankee Nuclear Power Corporation (VYNPC) submitted Revision 18 of its third l

20 year interval for IST cf pues and valves. In Revision 18. VYNPC submitted three f.ew relief requests (RR V13. RR V14. and RR V15), and four revised relief requests (Revision 1 for RR V12. RR P03. RR P05. and RR P06).

l The staff has evaluated these relief requests and has provided the following safety  !

evaluation.

1he licensee's IST program covers the third 10 year IST interval from Septeter 1.

1993 to August 31, 2003. The VYNPC IST program is based on the requirements of the 1989 Edition.Section XI. of the ASME Boiler and Pressure Vessel Code. -The 1989 Edition provides that the rules for IST of pu@s and valves shall meet the requirements set forth in ASME Operations and Maintenance Standards Part 6 (OM 6).

" Inservice Testing of Pumps in Light Water Reactor Power Plants.* and OH 10.

3

• Inservice Testing of Valves in L,ight Nater Reactor Power Plants.*

2.0 f(LLIEF REDUESI RR-V12. Revision 1 HR VIP requests relief from the test method and frequency requirements of OH 10.

Paragroph 4.3.2. for verifying the closure capability of check valves. V70 43A and 433. In the service water system discharge header. The licensee proposes to full-sicMn cercise these valves open at least quarterly and verify their closure copability by non-intrusive testing (radiography) or disassembly and inspection on each check valve once each operating cycle in lieu of refueling outage frequency.

2.1 Licenste'.s_Jasis for The Relief Remast These val u s are the service water system header discharge check valves. These valves have a safety function to close to prevent the backflow of service water puno discharge to the suction of the pugs when operating in the alternate cooling mie of operation. it is igracti'I to full- or part-stroke exercise these valves in the clnsed direction on a quartt , .y, cold shutdown or refueling outage freqwncy. Closure of these valves would require Shutdown of the service water punps'in their individual trains when the service water system is required to supply tooling water to core standby cooling equipment and the emergency diesel generators.

However.t 'he closure test can be practically performed whenever the service water system is operated in the alternate cooling mode or service water flow is isolated to the emergency diesel generator heat exchanger and ECCS area coolers.

As.such. the licensee proposes to verify the closure capability by non intrusive testing (radiography) or disasseely and inspection on each check valve once each operating cycle, but not necessWily at the refueling outage, l

s.

u

{

3 2.2 Alternate Testina The licensee proposes to full stroke exercise these valves open at least quarterly and verify their closure capability by non intrusive testing (radiography) or disassembly and inspection on each check valve once each operating cycle but not necessarily at refueling outage.

For those valves which are disasseeled and inspected in accordance with a plant planned maintenance program, that disasseely and inspection will be performed in lieu of non intrusive testing for that valve for that operating cycle. During the disasseely, the internals of the valve will be verified to be structurally sound (no loose or corroded parts.) If the disassembled valve is not capable of being full stroke exercised or there is binding or failure of the valve internals, the other valve will also be disasseeled inspected and manually exercised during the same operating cycle.

2.3 Evaluation Paragraph 4.3.2.2(e) of OH 10 requires that if valve exercising is not practicable during plant operation or cold shutdowns, full stroke exercising is to be performed during .efueling outages. Paragraph 4.3.2.4(c) allows disassembly every refueling outage to verify operability of check valves.

The licensee states that full or part stroke exercising these valves closed is not practicable because closure of these valves would require shutdown of the service water pumps in their individual trains when the service water system is required to supply cooling water to core standby cooling equipment and the emergency diesel generators. In Relief Request RR V12. Revision 0, the licensee proposed to disasseele. inspect, and manually exercise the valves on a sagling basis (one per refueling outage) when the service water system flow to the required loads can be isolated. The licensee stated that the disasseely and inspection would be done in accordance with GL 89 04. Position 2. In the safety evaluation report (SER) dated December 19, 1996. the staff approved the use of the disassembly and inspection for velve closure test at each refueling outat;e. However, the staff requested additional documentation and justification for testing the valve (one valve per refueling outage) on a sa mling basis. In addition, the staff requested that the licensee address use of non intrusive enethods.

In response to the above staff conrnents the licensee revised the relief request.

Relief Request RR V12. Revision 1. proposes to verify the closure capability by non intrusive testing (radiography) or, where applicable, disassembly and inspection of each check valve once each operating cycle, when the system in which the valves are located is not in operation.

4 Paragraphs 4.3.2.4(a) and 4.3.2.4(c) of OH 10 allow both non intrusive testing (radiography), and disasse21y and inpection of check valves as ecceptable means of verifying valve closure, and Code relief is not required. With appropriate justification. Paragraphs 4.3.2.2(e) and 4.3.2.4(c) of OH 10 also allow refueling outage testing or disassembly every refueling outage to verify op6rability of chea valves. The staff found in NUREG 1482 that extensive effort to set up the test and the adverse imact on sy.'em operation provide sufficient justification,to defer the test to refueling outage. The licensee has adequate justification to perform the required test at a refueling outage frequency. However in lieu of performing the test at each refueling outage. the licensee proposes to perform the test once for each operating cycle when the service water system is operated in the alternate cooling mode or when the service water flow is isolated to the emergency diesel generator heat exchanger and ECCS' area coolers. Because the system may be in use during refueling outage testing the valves. V70 43A and 438 would rec,uire shutting down the system switching to alternate cooling o de, and extensive effort to set up the test; all of which not only are hardship but also would adversely imact the system operation and might cause unnecessary interruption of ce,rtain cooling functions provided by the system. Nonetheless, the licensee's proposal will require the test to be performed on each valve at least once for that operating cycle. This proposal may extend the interval between two tests longer than 18 months, but no longer than two refueling outages. Position 2 of GL 89 04 allows extention of the test interval of a check valve beyond Code requirements if the licensee determines that it is burdensome to test certain valves at each refueling outage. In its relief request, the licensee has demonstrated that not only 1 is a hardship to perform the test at a specified outage when the system is in use, but a'so the test can adversely i mact the required system function, in addition, the proposal to perform the test once each operating cycle is consistent with the intent of the Code requirement of once each refueling outage, and, therefore, providas reasonable assurance of valve operability. Thus, compliance with the Code requirements would result in hardship or unsual difficulty without a co@ensating increase in the level of quality or safety, 2.4 Conclusion Paragraphs 4.3.2.4(a) and 4.3.2.4(c) of OH 10 allow both non intrusive testing (radiography) and disasseely and inspection of check valve as acceptable mPans of verifying check valve closure, and Code relief is not required. The propose' to perform the required test on each check valve once each operating cycle is consistent with the intent of once each refueling outage allowed by the Paragraph 4.3.2.4(c) of OH 10 and, therefore, provides reasonable assurance of valve operability. Given that Code comliance would result in hardship or unsual difficulty without a cogensating increase in the level of quality and safety, the staff authorizes the licensee's proposed alternative frequency of testing as described in relief request RR V12. Revision 1 pursuant to 10 CFR 50.55a(a)(3)(ii).

5 3.0 RELIEF RE00EST RR-V13 RR V13 requests relief from the test method and frequency requirements of OH 10.

Paragraph 4.3.2. for verifying the closure capability of check valves. V10 36A and 368. V14 33A and -33B, V23 208, and V13 208. These valves are the Residual Heat Retroval (RhR), Core Spray (CS). High Pressure Coolant Injection (HPCI) and Reactor Core Isolation Cooling (RCIC) system keep fill check valves. These valves have a safety function to close to isolate safety class piping from the le pressure non safety grade piping in the event of a system actuation. In lieu of performing the test at the refueling outage, the licensee proposes to perform non intrusive testing (radiography) on each check valve once each operating cycle within two months of the scheduled start of the next refueling outage.

3.1 Licensee's Basis for The Re14ef Recuest These valves are Safety Class 2 one inch lift check valves located in the keep fill pressurization lines for the RHR. CS, HPCI and RCIC systems. These valves are arranged in parallel . wnstream of a comon non nuclear safety Condensate Transfer supply check valve. There ar-e no test connections between the check valves or in any of the keep fill pressurization lines. Individual check valve closure capability verification is presently acco@lished by performing quarterly non-intrusive (radiography) testing. Indication of valve closure has been conclusive.

However, this quarterly non intrusive testing of the subject valves during power operation has proven to be burdensome. The burden irrposed by these test methods and more frequent testing during power operation includes increased personnel radiation exposure large manpower requirements, extensive test equipment setup, and increased potential for unexpected challenges to plant safety systems, it is expected that the performance of radiography during cold shutdowns would present the additional burden of obtaining contract services on short notice. It is also expected that performing radiography during refueling outages will present added risk of increased radiation exposure to personnel. Testing once each operating cycle but not during refueling outage will reduce the risk of increased radiation exposure to personnel as fewer people will be subject to exposure.

3.2 Alternate Testino In lieu of the alternative "disassertly and inspection" methods described in Generic Letter 89 04. Position 2. the licensee proposes to perform non intrusive testing (radiography) on each check valve once each operating cycle within two months of the scheduled start of the next refueling outage.

3.3 Evaluation Paragraph 4.3.2.2(e) of OH 10 requires that if valve exercising is not practicable during plant operation or cold shutdowns, full-stroke exercising is to be performed during refueling outages. Paragraph 4.3.2.4(c) allows disassertly and inspection each refueling outage to verify operability of check valves.

6 Relief Request RR V13. proposes to perform non intrusive testing (radiography) on each check valve once each operating cycle within two months of the scheduled start of the next refueli19 outage.

Paragraph 4.3.2.4(a) allows the non intrusive testing (radiography) of check valve as an acceptable neans of verifying valve closure I d Code relief is not required.

With appropriate justification. Paragraphs 4.3.2.2te) W 10 also allows refueling outage testing. However, the licensee needs relief von Code requirements to perform the required test at a time other than refue'.ing outages. The licensee proposes to perform the test within two months of the scheduled start of the next refueling outage. The licensee requests the relief on the basis that the burden 1 @osed by the non-intrusive test methods and more frequent testing (i.e..

Quarterly) during power operation does not provide a comensating increase in safety. The burden of performing nore frequent tests during power operation includes increased personnel radiation erposure, large manpower requirements, extensive test equipment setup, and increased potential for unexpected challenges to plant safety systems. The performance of radiogr phy during cold shutdowns would present the additional burden of obtaining contract services on short notice, and performing radiography during refueling outages will present added risk of increased radiation exposure because more workers are on site during refueling

, outages.

With regard to extended test frequency, the staff has determined (see Section 4.1.4 of NUREG 1482) that the need to set up test equipment is adequate justification to defer backflow (closure) testing of a check valve until refueling outage. The licensee has provided sufficient refueling outage testing justification such as the hardship caused by extensive equipment setup. large manpower requirements, and increased personnel exposure from more frequent testing. Testing the valve at refueling outage with sufficient justification meets the Code requirements of Paragraph 4.2.1.2(e) of OH 10 and relief is no' required. However, the licensee proposes to perform the test not at the refueling outage but within two months of the scheduled start of the next refueling outage, on the basis that, during the refueling outage, there will be more on site personnel and it would require more time to move and setup the test equipment. The staff finds that the proposed alternative to move the test to within two months before the refueling outage would reduce the risk of increased radiation to more workers but still maintain a test interval of approximately 18 months. Testing the valve every 18 months is consistent with the Code allowed period for assuring valve operability and is acceptable.

3.4 conclusion Non intrusive testing (radiography) of check valves is a mi.thod allowed by the Code for verifying valve closure, and Code relief is not required. The proposal to perform the required test on a check valve once each operating cycle within two months of the scheduled start of the next refueling outage is consistent with the

y '

'4

{

1 i 71 test interval- allowed by the Paragraph'4.3.2.4(c) of OM 10.- and, therefore. ; I

'provides adequate assurance of valve operability. _Given that Code coup 11ance would

~

.. 1esultLini hardship or unsual difficulity without a meensating increase in _the; level of quality lor_ safety. the staff authorizes the11censee's proposed  ;

alternative frequency of testing as described in relief request RR V13 pursuant to 10 CFR 50.55a(a)(3)(11).-  ;

4.0 RELIEF REQUEST RR-V14

=RR V14 requests _ relief from tne test method and frequency requirements of OM 10..

Paragt aph 4.3.2. for verifying the closure capability of check valves. V14 22A, 228. ,22C and 220. .These valves are the Condensate Transfer (CT) system to CS 3 1 flushing line check valves.. There valves have a safety function to close to~_

1solate safety class _ piping from the lower pressure non safety grade piping in'the

<--event of a CS system actuation. In lieu of performing the test at the refueling outage, the licensee proposes to perform non intrusive testing (radiography) on -

each check valve once each operating cycle within two months of the scheduled start

- of the next refueling outage.

4.1 Licensee's Basit For The Relief Rennett These valves are Safety Class 2 one inch lift check valves located in the flushing

lines between the CS system and the CT system. These valves are arranged in series pairs in each flushing line. During normal power operation. these flushing E

lines are isolated. There are no test connections between the check valves or in either flushing lines. Individual check valve closure capability verification is ,

'L presently acconp11thed by performing quarterly non intrusive (radiography) testing.

Indication of, valve closure has been conclusive. However, this quarterly non-intrusive testing of the subject valves during power operation has proven to be '

^ burdensome. The burden inposed by this test method and more frequent testing

[

during power operation includes increated personnel radiation exposure large manpower requirements, extensive test equipment setup, and increased potential for -

. unexpected challenges to plant safety systems. It is expected that the performance

- of radiography during cold shutdowns would present the additional burder, of obtaining contract 1,ervices on short notice. It is also expected that performing

- radiography during refueling outages will present added risk of increased radiation '

g exposure to personnel during refuelig outages. Testing once each operating cycle but not during refbeling outage will reduce the risk of increased radiation:

, exposure:to personnel as fewer people will be subject to possible exposure.

Alternate Testirg-

-4.2 _

In lieu of.the alternative " disassembly and inspectien" methods described in GL 89-04. Position-2.' the licensee pluposes to perform non intrusive testing .

(radiography) on each check valve once each operatig cycle within te months of the .ycheduled start of the rext refueling outage, s

e -'

2-- -.

w vb 5%Je s,, v ,r--,xy,-,-...,+.Jr-c.- ,-,.._..,r - . - - - , . * ' - - . , .mu .- , m.- , , . .

( .

i .'

I 8

4.3 Evaluation Paragraph 4.3.2.2(e) of OH 10 requires that'if valve exercising is not practicable during plant operation or cold shutdowns, full stroke exercising is to be performed during refueling outages. Pangraph 4.3.2.4(c) allows disassembly and inspection each refueling outage to veriij operability of check valves.

Relief Request RR V14 proposes to perform non intrusiv* testing (radiography) on each check valve once each operating cycle within two months of the scheduled start of the next refueling outage.

Paragraph 4.3.2.4(a) M10ws the non intrusive testing (radiography) of check valve as an acceptable means of verifying valve closure and Code relief is not required.

With appropriate justification. Paragraphs 4.3.2.2(e) OM 10 also allows refueling cutage testing. However, the licensee needs relief from Code requirements to perform the required test at a time other than refueling outages. The licensee proposes to perform the test within two months of the scheduled start of the next refueling outage. The licensee requests the relief on the basis that the burden 1 @ osed by the non intrusive test methods and more frequent testing (i.e..

quarterly) during power operation does not provide a comensating increase in safety. The burden of performing more frequent tests during power operation includes increased personnel radiation exposure, large manpower requirements.

extensive test equignent setup, and increased potential for unexpected challenges to plant safety systems. The performance of radiography during cold shutdowns

( would present the additional burden of obtaining contract services on short notice.

F and performing radiography during refueling outages will present added risk of increased radiation exposure because more Wrkers are on site during refueling outages.

With regard to extended test frecuency. the staff has determined (see Section 4.1.4 of NOREG 1482) that the naed to set up test equipment is adequate justification to defer backflow (closure) testing of a check valve until refueling outage. The licensee has provided sufficient refueling outage testing justification such as the hardship caused by extensive equipment setup, large manpower requirements and increased personnel exposure from more frequent testing. Testing the valve at refueling outage with sufficient justifice' ton meets the Code requirements of Paragraph 4.2.1.2O) of OH 10 and relief is not required. However, the licensee proposes to perform the test not at the refueling outage but within two months of

^ the scheduled start of the next refueling outage, on the basis that, during the refueling outage, there will be more on site personnel and it would require more time to move and setup the test equipment. The staff finds that the proposed alternative to move the test to within two months before the refueling outage would reduce the risk of increased radiation to more workers but still maintain a test interval of approximately 18 months. Testing the valve every 18 months is consistent with the Code allowed period for assuring valve operability and is acceptable.

.(*

T 9

4.4- conclusion Non intrusive testing (radiography) of check valves is a method allowed by the Code for verifying valve closure, and Code relief is not required. The proposal to-perform the required test on a check valve once each operating cycle within two months of the scheduled start of the next refueling outage is consistent with the test interval allowed by the Paragraph 4.3.2.4(c) of OM 10, and, therefore, provides adequate assurance of valve operability. Given that Code compliance would result in hardship or unsual difficulty without a co@ensating increase in the ,

level of quality and safety, the staff authorizes that the licensee's proposed ,

alternative frequency of testing as described in relief request RR V14 pursuant to 10 CFR 50,55a(a)(3)(ii).

5.0 RELIEF RFOUF%T RR-VM RR V15 requests relief from the test method and frequency requirements of OM 10, Paragraph 4.3.2, for verifying the closure capability of check valves, V13-19 and V23 32. Valve V1319 is the Condensate Storage Tank (CST) supply to RCIC pump is tion check valve. This valve has a safety function to close and isolate the RCIC pu m suction from the CST. V23 32 is the CST supply to HPCI pump suction check valve. This valve has a safety function to open and supply water from CST to the HPCI pum suction. This valve also has e safety function to close and isolate the HPC] pu@ suction from the CST. In lieu of performing the test at the refueling outage, the licensee proposes to perform non ;,trusive testing (radiography) on each check valve once each operating cycle w nhin two months of f5e scheduled start of the next refueling outage.

5.1 Licensee's Basis For The Relief Rennest Individual check valve closure capability verification is presently accoglished by performing quarterly non-intrusive (re'"ography) testing. Indication.of valve closure has been conclusive. However

• nis quarterly non intrusive testing of the subject valves during power operation has proven to be burdensome. The burden i mosed by this test method and more frequent testing during power operation includes increased personnel radiation exposure, large manpower requirements, entensive test equipment setup, and increased potential for unexpected challenges

.to plant safety systems. It is expected that the performance of radiography during cold shutdowns would present the additional burden of obtaining contract services on short notice. It is also expected that performing radiography during refueling outages will present added risk of increased radiation exposure to more personnel during refueling outages. Testing once each operating cycle but during refueling outage will reduce the risk of increased radiation exposure to personnel: as fewer people'will be subject to possible exposure.

A w+r

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

1-j 10  :

'5.2 Alternata Tastinn

In lieu of the alternative *disassesbly and inspection" methods described in GL 89- l L 04. Position 2.: the licensee proposes to perform non intrusive testing: _

L(radiography) on each check valve once each operating cycle within two months of .!

. the~ scheduled start of the next refueling out(,ge.  !

5.3 Evaluation j Paragraph 4.3.2.2(e) of OH 10 requires _that if valve exercising is not practicable during plant operation or cold shutdown:, full-stroke exercising-is to be performed-

' during refueling outages.- Paragraph 4.3.2.4(c) allows disassenbly every refueling outage to verify operability of c, heck valves. -

.  : Relief Request RR V15. proposes to perform non intrusive testing (radiography) on ',

Leach check valve once each operating cycle within two months of the scheduled start I of the next refueling outage.

Paragraph 4.3.2.4(a) allows the non intrusive testing (radiography) of check valve as an acceptable means of verifying valve closure and Code relief is not required.-

With appropriate justification. Paragraphs 4.3.2.2(e) OH 10 also allows refueling outage testing. However the licensee needs relief from Code re,, :.'ements to

perform the required test at a time other than refuelir,g outages. The licensee proposes to perform the test within two months of the scheduled start of the next refueling outage. The licensee requests the relief on the basis that the burden

. imposed by the non intrusive test methods and more frequent testing (i.e..

Quarterly) during power operation does not provide a conpensating increase in safety. The burden of performing more frequent tests during power operation

[ includes in'reased personnel radiation exposure. large manpower requirements. )

extensive test equipment setup, and increased potential for unexpected challenges i- to plant safety systems. The performance of radiography during cold shutdowns would present the additional-burden of obtaining contract services on short notice.

and performing radiography during refueling outages will present added risk of L increased radiation exposure because more workers are on site during refueling outages, i

With regard to extended test frequency, the staff has determined (see Section 4.1.4 F of NURE(i 1482) that the need to set up test equipment is adequate justification to defer backflow (closure) testing of a check valve until refueling outage.. The clicensee has' provided sufficient refueling outage testing justification such as the

hardship caused by extensive equipment setup..large manpower requirements, and

increased personnel exposure from more frequent testing. Testing the valve at

' refueling outage with sufficient justification meets the Code requirements of

, Paragraph 4.2.1.2(e) of OM-10._and relief is not required. -However. the licensee .

Loroposestoperformthetestnotattherefuelingoutagebutwithintwomonthsof De scheduled start of the next refueling outage, on_the basis that, during the Lrefueling outage. there will be more on site per:onnel and it would require more

. . __.m. .-_. a __u_ _ u __ __ _ _

i i

4

. 11 time to move and setup the test equipment. The staff finds that the proposed siternative to move the test to within two months before tne refueling outage would reduce the risk of increased radiation to more workers but still maintain a test

' interval of approximately 18 months. Testing the valve every 18 months is consistent with the Code allowed period for assuring valve operability and is acceptable.

5.4 conclusion Non intrusive testing (radiography) of check valves is a method allowed by the Code for verifying valve closure. and Code _ relief is not required. The proposal to perform the required test on a check valve once each operating cycle within two months of the scheduled start of the next refueling outage is consistent with the test interval allowed by the Paragraph 4.3.2.4(c) of OH-10, and, therefore.

provides adequate assurance of valve operability. Given that Code cogliance would result in hardship or unsual difficulty without a cogensating increase in the level of quality and safety, the staff authorizes the licensee's proposed alternative frequency of testing as described in relief request RR V15. pursuant to 10 CFR 50.55a(a)(3)(11).

4 6.0 Rrt1EF RE00FST RR P03. Revision 1 The revised relief request RR P03 contains minor changes to the previously approved request that was authorized by NRC in an SER dated September 3.1993.

Specifically. the instrument accuracy values have been revised to reflect the closer tolerances now in use at the Vermont Yankee Nuclear Power Station (VYNPS).

The calibrated accuracy is revised from 11.58% to 11.17%. The measured inaccuracy is revised from *1.34 psi to *0.99 psi. The aP error is revised from 0.12% to 0.081.

6.1 Evaluation and Conclusion Relief Request RR P03 was authorized by NRC in an SER dated September 3. 1993, pursuant to 10 CFR 50.55a(a)(3)(ii) on tne basis that the proposed alternative provides adequate accuracy of the instrumer.t and cogliance with the Code requirements would result in hardship without cogensating increase in the led of quality and safety. Revision I for RR P03 proposes to use improved instrumeia accuracy and tolerances from those previously approved. These changes would not alter the evaluation and conclusion of the September 1993 SER: and accordingly. RR-P03 (Revision 1):is authorized pursuant to 10 CFR 50.55a(a)(3)(11).

~

.7.0 RElfEF RE00rST RR P05. Revision 1 The revised relief request RR-P05 contains minor changes to the previously approved request that was authorized by NRC in an SER dated Septent>er 3.1993.

' Specifically. the instrument' accuracy values have been revised to reflect the closer tolerances now in use at the VYNPS. The calibrated accuracy is revised from 12.01 to *1.68. The measured inaccuracy is revised from *1.2 psi to *0.96 psi.

The AP error is revised from 0.5% to 0.411.

l j .

12 7.1 Evaluation and Conclusion Relief Request RR POS was authorized by NRC in an SER dated Septenber 3,1993, pursuant to 10 CFR 50.55a(a)(3)(11) on the basis that the proposed alternative provides adequate accuracy of the instrument and cogliance with the Code requirements would result in hardship without cogensating increase in the level of quality and safety. Revision 1 for RR POS proposes to use igroved instrument accuracy and tolerances form those previously approved. These changes would not alter the evaluation and conclusion of the Septenber 1993 SER: and accordingly RR-PDS (Revision 1) is authorized pursuant to 10 CFR 50.55a(a)(3)(11).

8.0 RELIEF REOUEST RR-P06. Revision 1 The revised relief request RR P0fr contains minor changes to the previously approved request that was authorized by NRC in an SER dated Septenber 3,1993.

Specifically, the instrument accuracy values have been revised to reflect the closer tolerances now in use at the VYNPS. The calibrated accuracy is revised from 11.588 to il.178. The measured inaccuracy is revised from t1.34 psi to 10.99 psi.

The aP error is revised from 0.125 to 0.09%.

8.1 Evaluation and Conclusion Relief Request RR P06 was authorized by NRC in an SER dated Septenber 3,1993, pursuant to 10 CFR 50.55a(a)(3)(ii) on the basis that the proposed alternative provides adequate accuracy of the instrument and cogliance with the Codt requirements would result in hardship without cogensating increase in the level of quality and safety. Revision 1 for RR P06 proposes to use igroved instrument accuracy and tolerances from those prcviously approved. These changes would not alter the evaluation and conclusion of the Septenber 1993 SER: and accordingly RR-P06 (Revision 1) is authorized pursuant to 10 CFR 50.55a(a)(3)(ii).

9.0 CONctus10N Based on the above evaluation, the staff concludes that the alternatives proposed in valve relief requests RR V12 (Revision 1) RR V13. RR-V14 and RR-V15 are authorized pursuant to 10 CFR 50.55a(a)(3)(11) on the basis that the proposed testing provides reasonable assurance of valve operability and igosition of Code requirements would result in hardship without a cogensating increase in the level of quality or safety. The alternatives proposed in pu g relief requests (Revision 1 for RR-P03. RR P05, and RR-P06) are authorized pursuant to 10 CFR 50.55a(a)(3)(11) on the basis that the revised relief requests provide igroved instrument accuracy from those previously approved and that igosition of Code requirements would result in hardship without a cogensating increase in the level of quality or safety.

Principle Contributor: Y. S. Huang Date: January 15, 1998

._ _ _ _ _ _ _