ML20202J116

SER Accepting Relief Requests Associated with Second 10-year Interval Inservice Testing Program

ML20202J116
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Site:	Harris
Issue date:	02/01/1999
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• UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 200 SHOO 1

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE INSERVICE TESTING PROGRAM. SECOND TEN-YEAR INTERVAL CAROLINA POWER AND LIGHT COMPANY SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NUMBER 50-400

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 Boller and Pressure Vessel Code (the Code) and applicable addenda, except where altematives 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 alternatives 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 qvality 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 to be acceptable to the staff.

Alternatives that conform with the guidance in GL 89-04 may be implemented prior to receiving NRC approval, but should be included as relief requests for review by the staff. When alternatives are implemented in accordance with the relevant position in the GL, the staff has determined that relief should be granted pursuant to 10 CFR 50.55a(f)(6)(i) on the grounds that it is authorized by law, 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 considers the burden on the licensee that would result if the requirements were imposed.

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 respect to authorizing alternatives and granting or not granting the relief requested as part of the licensee's IST program are contained in this Safety Evaluation (SE).

Carolina Power and Light Company (the licensee) based the Shearon Harris Nuclear Power Plant IST program on the requirements of the 1989 Edition of ASME Section XI, Subsections lWP and IWV, which is incorporated by reference in 10 CFR 50.55a. ASME Operations and Maintenance (OM) Standard Pa:t 6, for IST of pumps is referenced by Subsection lWP and OM Standard, Part 10, for IST of valves is referenced by Subsection IWV. The relief requests were reviewed against the requirements of the 1989 Edition of ASME Section XI for pumps and valves. The second 10-year interval began on February 2,1998, and ends on May 1,2007. A summary of the NRC's action on each relief request is provided in Attachment 1. The test deferrals for valves which are in accordance with Part 10 have been reviewed and are summarized in Appendix C of the Technical Evaluation Report (TER), which is included as Attachment 2 to this SE.

ENCLOSURE 9902090040 990201 PDR ADOCK 05000400 P PDR _

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i 2.0 EVALUATION 2.1 Relief Reauests l

The Mechanical Engineering Branch, with technical assistan::e from INEEL, has reviewed the information concoming IST program requests for relief submitted for the third 10-year interval for the Shearon Harris Nuclear Power Plant in a letter dated January 27,1998. The staff adopts the evaluations and recommendations for granting relief or authorizing alternatives :

contained in the TER prepared by INEEL.

For the Shearon Harris IST Program, as summarized in Attachment 1 to the SE, relief is granted from, or attematives are authorized in lieu of, the testing requirements which have been determined to be impractical to perform, where an attemative 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.

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. Program changes that add or delete components from the IST program should also be periodically provided to the NRC.

2.2 Deferred Test Justifications The test deferrais of valves, as allowed by OM-10, were reviewed as part of INEEL's evaluation.

Results of the review are provided in Appendix C of the TER with recommendations for further review by the licensee for specific deferrals. Results of the review of deferred test justifications do not necessarily constitute final approval and are subject to NRC inspection.

2.3 System Review INEEL, using the Shearon Harris Updated Final Safety Analysis Report, conducted a scope review of the chemical volume control and component cooling water systems against the requirements of Section XI and the regulations. The review revealed severalitems that did not appear to be in compliance with the Code requirements (see Appendix B of the TER). In addition, editorial comments discovered during the system review are also noted in this Appendix. The licensee should review these items, as well as other systems that might contain similar issues, and revise their program and take any necessary actions as appropriate.

2.4 Relief Reauests in Accordance with NRC GL 89-04 For any relief granted based on following the positions stated in GL 89-04, the staff (with technical assistance from INEEL) has reviewed the information submitted by the licensee to determine whether the proposed attemative testing follows the relevant position in the GL. New or revised relief requests that meet the positions stated in GL 89-04, Attachment 1, should be submitted to NRC but may be implemented prior to staff approval provided the guidance in GL 89-04, Section D, is followed.

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2.5 Action items  :

For several IST program relief requests, the staff identified certain action items for the keensee to complete. These action items are identified in Appendix A of the TER and should be  ;

addressed within one year from the date of this SE or by the end of the next refueling outage, l whichever is later. In addition, the licensee should address program scope issues identified in ,

Appendix B of the TER within one year from the date of this SE or by the end of the next I refueling outage, whichever is later. Licensee actions to address the action items in this SE are subject to NRC inspection. The licensee is requested to respond to the NRC within one year of the date of this SE describing actions taken, actions in progress, or actions to be taken, to address each of these items.

3.0 CONCLUSION

The Shearon Harris IST program requests for relief from the Code requirements have been reviewed by the staff with the assistance of its contractor, INEEL. The TER provides INEEL's evaluation of these relief requests. The staff has reviewed the TER and adopts the evaluations and recommendations for granting relief or authorizing alternatives for implementation for the second 10-year interval with the exception of CE-VR1, which is authorized for one year or until the next refueling outage. 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. The implementation of IST program and relief requests is subject to inspection by the NRC.

The licensee should refer to Appendices A and B of the TER for a discussion of recommendations identified during the review. The licensee should address each l recommendation in accordance with the guidance therein. The action items identified in Appendix A of the TER should be 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.

The staff concludes that the relief requests as evaluated and modified by this SE provide  !

reasonable assurance of the operational readiness of the pumps and valves to perform their safety-related functions. With respect to reliefs CB-VR1 and IA-VR1, the staff has determined that the requirements of the code are impractical and relief is granted pursuant to 10 CFR 50.55a (f)(6)(i). The relief granted 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 on the licensee if the requirements were imposed. The alternatives in relief requests AF-PR1, CC-VR1, CC-VR2, CE-VR1, CT-VR1, MS-VR1, and SI-VR1 are authorized pursuant to 10 CFR 50.55a (a)(3)(ii) in that compliance with the code would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Principal Contributor: Joseph Colaccino, DE/EMEB Date: February 1, 1999

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Attachnient I  !

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SE Table 1 i 4 .

I t Shearon Harris NuclearPowerPlant i 4 '

Summary ofReliefRequests -

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Rqn st TER Test Equipneent No. Secnen Requirennents identryibution ProposedAltera ;:n '

NRCAcnon t AF PR1 3.1.1 Oh84, Pere. i AFIA-SA and-S8 The existing pennenently insteRed pump hatrument is maamys=han m.-- gas Anemouse 4.6.1.2(a) Ir=8v'=amm8 acrasrecy is lose Wien or aquel to +6% es calculated at see soference Audhortrod welue. No atomets toshng or instrumentation mE be nest-d.

, acconsng to 10 CFR 50.55e(eX3MS C8NR1 4.3.1.1 0 04-1, 1C8-3 and -7 t The subled wolves sheE be tested te versy goir open and ciese espebssy and RemetGranted Pers.1.3.4.3(e) set poseure h acconfonce weh the sequhemente of Obs-1 ende sofmesng i

accontng to 10 CFR outage  !

50.55e(fM6MD l CCNR1 4.2.1.1 Cas.10, Pers. 1 CC-308 and-307

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s 4.3.2.

A fulk4roke ctosure exedse of the eutijod vehes we be vorsled by a eengte Anemesmo disassernbty and inspedian pmgrarn as cumned in NRC Stef '

- Augeortred Posihon 2 in USNRC Gener6c Leser 89 04 *riame=nce On Developing '

occonNng to 10 CFR

1. ---.-" inservice Testing Pmgrams? The subled velves are of the some 50.56e(eM3XS t

design (snenuleduser, sire, model nurstier and metensis of constuction) and j have the some service candimens hesudmg vuevo orientemon and lagesher consist of one group. One of the subied veeves shes be seessemband each secuenne outage. During vehe ^  :

^ ,, the valve insemets wis be visusey Inspected for wom or conoded ports, and the vehe disk shes be menuesy t

enerdned. N the ====mband vesve is not cepetse of heme fiseeresse

• i enadeed or a them is bindng or fatwo of se valve biomets, em olher vehe  !

h this group shag also be * - _ _ ^

_ . Insparead, and snenuesy fuSgtelse eer-ised during the esmo sofustng outage {'

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cC-vR2 4.2.1.2 004-10, Pere.

1CC.216,-227 and-238 A tut.elroke cdoeure enerdee of the subjod volves wW be vergled by e semple AtomeNuo 4.3.2. ^--

., and kispedson program as ousned in EC Stef Austertred  ;

Possion 2 in USNRC Generic Letter 8944 'Giedence On Developing acconNng to 10 CFR Acaptable Inservice Testing Programs? The sutigoct valves are of sie some 80.56e(eM3M4 i desagn (rnenutedurer, sire, model number and metertels of construdien) and have the some sonnte andsons indudng vahe orienteNon and together consist of one group. One of Nie subged valves shes be es=====mbled eeds nefueling outage. Durbig vehe "

"A .the valve intemels we be viouser inspeded ser wom er conoded parts, and the vehe dek sheA be menueSy exercseed. Nthe son ==antled volve is not capable of being fuS-strate eumdeed orif there is turukng or feRum of the velve intemels, the oIher lee .

volves in this group shes eles be son =me-gtied,irnaparemm8 and manusBy its-strone esordeed during the some refueAng outage.

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i Mender,Nmmeeris 299s .

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Request TER Test Equipneent -

No. Section Requirennents Mentificntion Prrr;'eseofAlternatier NRCAction ~

M-VR1 4.1.1.1 l 004-10. Pers. 1CG38. -48 and -56 i 4.3.2. A fus-stroke closure of the sutded valves wW be vermed by a serrgde Anomatka esassembly and Inspedian program os outilned h NRC StsN Posalon 2 in Aulhortred on en i USNRC Genenc Lener 89-04 ' Guidance On C, .~., Acceptable Inservice interern beste Teshmj Programs

• The sutsed valves are of simRor design (Wienusedurer,

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according to 10 CRt model number and malenols of construdion) and have Wie some service 50.55e(s)(3)(W). for condshons induding ve8ve orientation. The only Postion 2 cetorton not enetle one yearor unIE Wie

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i the common size for at valves in the sempRng yo gs.1CG36 and 1G-46 ese nemt sofustng 6 inch valves and 1CE56 la en 8 inch valve. As eutape.

j idenhfied in the NRC safety evaluellonPledmical evoluelson tiege 38 deled Apr# 27,1968) of sie HNP ist Ten-Year IntervalIST Program," Sines eE oIher factors arc identical for these velves, the feviewer feele that even wWe ete site 1

esperey, these sehes should be snowed to be sneeed togeWier because any tenwe mechanism should be ammen ser as Swee veswee

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Sina the tanne mechanism enound be common for as Wuse veeves, ene i

of Bie autved vehes shes be omessensed endi meneang sidege ig o r one g r veeve esassemedy the veeve ineemmen was be visume inspeded for nom er corroded parte, and Be veeve esk we be monumer essee- athe esassentised veeve w not c=p-se fobeing the-eecem enesdeed or 9them to bandag or faame of the vehe insommie, the asher two weeves m ihte i

group we also be disassembled inspeded, and snonuesy fuSetrole seerdned

}  ! during De same resueens cidsge.

CT-vR1 4.4.1.1 One-10, Poe. 4.3.2 1C-53 and -91 l i A fue-seeke open>g esercise of 9m sutded wolves we te vermed by a sanges AAomethe disassemtdy and inspection program as outEned in NRC Stew PosNIon 2 tre Autheetted USNRC Generic Lener 8944 Tsuidance On Developing Armte.see Innervice accoedhg to 10 CFR i

Testing Programs

• The set $ect volves are of the same design (manufactuer, 50.55e(s)(3)(4 stre, nedet number and meterials of construdion) and hwwe Sie amme sendoe condillons hduding volve orientation and together consist of one geign. One of the set $ett volves sher be esessemtded eedt NeueEng oudege. Dwing veeve m .-,. the wake insemens we im visuosy inspeceed ser som er I conoded parts, and she volve disk sheE be manuspy esordeed. N 9ts esessemaned voeve is not c=p=sde of being sue-emote eessdeed er r these is j

binding or foeuse of the volve MIemale, Die other vetse in Wies peup sheE sted l l be disassemided, inspeded, and menueBy fuBetmhe emudsed dushg Wie same neueime autoge,

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~  ! AHer the iAmeseembly of Wie tutted welvos, Wiese velves wE be lotsileskoge l I rate tested be acconlance utgi Wie requimments of 10 CFR 90, Appemmt J.

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No. Section Requiremenar identafication , i ProposedAlternative

• NRCAction IA-VR1 4.5.1.1 One.10, Pere. 4.3.2 70s 1M-786 -787,-788 and - These vehes shes be lessed as a pairs se klonteed h sedian 4.t.1 of

' Rosef Granted USNRC NUREG-1482 each miustng outage since only one of the two wolves seconfing to 10 CFR is required by the system design. Pair 8 I wiR consist of valves 1 IA-786 & 1 50.55e(fM6MI) lA-787. Paar 82 we consset of vahes 1 IA-788 and 11A-70s. These valves and the air accumulators are presently tested as a pair try a pressum decoy test et the sutged vehes and assoanted accumulator i \

i I Since as of the sutgect vaeves are ASME Sedian III Class 2 wefres, they wE I hows equ6veient quatty assurance regubements. I ass-VR1 4.8.1.1 004-10, Pers.4.3.2 198S-71 and -73 Fun-stnAe closure of the sutged valves wiR be vertEed by a sample h i Aanmeeve disassently and inspection program as outhned h NRC Sten Postion 2 In

• Aulhortred USNRC Genenc Letter 8944 *Guadance On Developing Are=r s=han sneerwtoe acconens to 10 CFR Testing Programs."The sutgect valves are of the some design (manuladuer, 50.55e(aM3)(E) size. model number and motorials of construdion) and have Die same servios condibons kidudung vehe orientaloon and together coneset of one group. One

• of the sutged valves sheE be disassembled eedi refusEng outage. Dudng valve disassembly, sie valve intemeis wiu be visueny kispected for worn or i corroded ports, and the valve disk shes be menuesy enerdood N 9to -

disassernbied valve is not capable of being fuS-strate soordood or N Wiese in I bendung or fature of the valve intemois, the osser volve Iri Weis group she8 atee +

be desassembled inspeded, and '

manually fur-stroke enerdeed during Wie some refueAng outage. 3 St-VR1 4.7.1.1 004-10 Pere.4.3.2 158-249.-250 -251,-

A fus-stroke opening eneedse of the sedged valves we be vermed by a semple Atomenwe 252.-253 and-254 .W and inspection program as ousned in NRC Sten Position 2 in Authertred USNRC Genorte Leser 8944

• Guidance On En , . .,, Araf =ha= 8 Inservice acconNng to 10 CFR Testing Programs

• The sutgect valves are of the same design (enanuladuser, 80.55e(eM3M4 stre, model riumber and moserials of construction) and have lhe some service condelons kidueng valve onentation and together consist of tuo q Group 81 consists of no check vaeves dosest to sw safety hvedian accumulators (1SI-249,158-251 and 1S l-253). Groep #2 canalets of the check valves domest to the reador coolant system (IS8-250, IS8-252, and 1S4-254). One of the sutged vahes in eads group shas be disassentled each refuehng outage Dunng vehe " - _,, the volve kitemets wsR be visus #y inspeded for wom or corroded parts, '

and the valve disk shas be snenuesy emeedoed K the sh=====mbled wolve is not capable of being fur-stroke exercised or N them is bindweg

' or faaure of the valve intemels, the other two valves in the apar* greeg sheE also be disassembled, inspeded, and menuesy fus-etrate exerdsed during the same refusens outage vofves we he part strose open ,

enerdsed stor - . _ , .

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