BECO-LTR-97-107, Application for Emergency Amend to License DPR-35,changing TS 3.7.A.5 as Pertains to Periodic Surveillance Testing of Check Valve 30-CK-432.Exemption from LCO Footnote Provides Would Expire When Testing Is Performed

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Application for Emergency Amend to License DPR-35,changing TS 3.7.A.5 as Pertains to Periodic Surveillance Testing of Check Valve 30-CK-432.Exemption from LCO Footnote Provides Would Expire When Testing Is Performed
ML20217K558
Person / Time
Site: Pilgrim
Issue date: 10/24/1997
From: Boulette E
BOSTON EDISON CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20217K562 List:
References
BECO-LTR-97-107, NUDOCS 9710280312
Download: ML20217K558 (5)
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E. T. Boulette, PhD Senior vice President - Nuclear U.S. Nuclear Regulatory Commission j Attention: Document Control Desk Washington, DC 20555 Docket No. 50-293 License No. DPR-35 Emeroency Amendment Reauest for Technical Specification 3.7.A.5 Concernino Check Valve 30-CK-432 Boston Edison hereby requests an eniergency change to the requirements of Pilgrim Nuclear '

Power Station (PNPS) Technical Specification 3.7.A.5 as it pertains to the periodic surveillance testing of check valve 30-CK-432. This is a temporary request made under the purview of 10CFR 50.91(5). This temporary change will expire when the surveillance testing is performed no later than the 1998 maintenance outage. Plant operation with the approval of this relief request will not create a significant hazard to the public health and safety or the environment.

Description of Chance Technical Specification section 3.7.A.5 requires all containment isolation check valves to be operable or to have at least one containment isolation valve in a line with an inoperable valve to

- be secured in the isolation position.

This amendment request proposes the addition of a footnote declaring one containment isolation valve, 30-CK-432, operable for a limited period despite not being within its in service testing interval for reverse flow testing. The exemption from the LCO this footnote provides will expire when testing is performed.

The footnote states:

Check valve 30-CK-432 will be considered operaLN until reverse flow testing is performed no later than the 1998 mcintenance outege. j .gl I

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Purpose of Chanao Failure to perform the test or amend sectiori 3.7.5.A will result in 30-CK-432 being declared i.noperable, forcing Pilgrim to shutdown. This Technica! Specification Amendment is requested to preclude subjecting Pilgrim to transients associated with a forced shutdown caused by testing check valve 20-CK-432 per the requirements of Pilgrim's in-service testing (IST) program.

Reason for Emeraency Status Under the provisions of 10CFR50.91(5) Technical Specification amendments may be processed under emergency conditions if failure to do so derates the plant and the necessary amendment could not have been reque.sted by the licensee in a timely manner. Failure to grant this amendment will derate Pilgrim by forcing entry into 3.7.A.(5), which will result in a shutdown.

Pilgrim could not make timely application for an amendment request. This problem was identified September 18,1997, by Problem Report 97.2806. Our immediate response to PR97.2806 was to (1) identify other valves that may have been inadvertently not tested, and (2) investigate methods to test without subjecting Pilgrim to unnecessary challenges.

Our investigation indicates 30-CK-432 is the only valve that experienced this testing problem.

However, our investigation also indicated no safe means to test the valve at power.

Once the inability to test at power was determ'. led, Pilgrim submitted a ceouest for enforcement discretion (NOED) by letter to the NRC dated October 10,1997. We believed a NOED was the appropriate mechanism to resolve this issue.

On October 21,1997, the NRC informed us by telephone that our NOED request was not the appropriate mechanism, that this issue required an amendment request. Since the LCO requiring shutdown becomes operant November 2,1997, there is insufficient time to request this amendment under any condition but as an emergency amendment request. Therefore, despite our efforts, we cannot avoid submitting an emergency amendment request because the option to make tim <. sly application was denied us by the circumstancer prior to October 21,1997.

Backaround During a review of Pilgrim's Master Surveillance Tracking Program (MSTP) following an in-Service Testing (IST) program revision, we discovered that the reverse flow exercise (surveillance) for check valve 30-CK-432 was not performed during RFO #11, which ended April 1997. The surveillance was due May 2,1997, and its grace period expires November 2,1997; hence, the valve will become administratively inoperable November 2,1997, due to the missed surveillance unless Techr...:al Specification Amendment is granted by the NRC. Previously, reverse flow testing of 30-CK-432 (IST) had been performed concomitant with 10CFR50, Appendix J local i leak-rate testing. Appendix J testing for this valve was deferred to RFO #12 following adoption of Appenoix J, Option B granted by the NRC in Amendment # 167, dated October 4,1996, resulting in the IST portion of the test being inadvertently missed during RFO #11. A subsequent review of the IST records confirmed this was the only valve affected by the Technical Specification Amendment that was not tested in RFO #11.

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Slanificant Hazards Ana',vsis Check valve 30 CK-432 provides isolation to nonsafety-related drywell equipment cooled by the reactor' building closed cooling water (RBCCW) system. This check valve is the primary containment isolation valve outside containment for a system required to be in-service during plant operation. The valve is located in a closed system (Class C) that does net communicate with the reactor coolant system, the containment atmosphere, or environs. The system piping is seismic Class 1. The forward flow exercise of this valve is verified quarterly in accordance with IST program requirements.

The Code of Federal Regulations (10 CFR 50.91) requires licensees requesting an amendment to provide an analysis, using the standards in 10CFR 50.92, that determines whether a significant hazards censideration exists. The following analysis is provided in acoordance with 10 CFR 50.91 and 10 CFR 50.92 for the proposed amendment.

Operating Pilgrim in accordance with this proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Pilgrim inadvertently f ailed to perform the required reverse flow testing on 30-CK-432 as required by the IST program. The valve is located in a closed system (Cla.: C) (

Reference:

Updated Final Safety Analysis Report] that does not communicate with the reactor ccLant system, the containment atmosphere, or enviroris. The system piping is seismic Class 1, Performing the reverse flow test during power operation was considered, but that option was rejected because a potential resulting rise in containment temperature could lead to a plant transient, accelerated equipment wenr, or a reactor trip on high drywell pressure. It wou!d compel entry into Emergency Operating Procedure (EOP-3) due to high cont 7inment temperature. Elevated containment temperature also has the potential to violate Pilgrim Technical Specification section 3/2.H, "Drywell Temperature",

Performance of a check valve closure test during plant operation would result in the isolation of cooling water for the drywe'l to all area coolers and both recirculation pump motor lubrication oil coolers. Isolation of those coolers associated with the recirculation pumps could potentially lead to accelerated degradation of the recirculation pump motors due to overheating. Additionally, isolation of the cooling water to the drywel! area coolers during plant operatio.1 could impact the environmental qualification life of electrical equipment due to drywell heatup. Drywell heating also increases the probability of a reactor scram due to high drywell pressure.

Hence, testing during power operation subjects the plant to possible degradation and transients without a significant increase in safety. Likewise, the additional confidence in the valve's ability to perform its designed safety function provided by the subje1 test is outweighed by the risk and stress placed on plant and equipment by a forced shutdown to implement the test.

Permanent plant-installed, non-intrusive test equipment does not exist for 30-CK-432. Other surveillance methods using portable equipment (e.g., acoustic, ultrasonic, magnetic, and radiographic) that can be used to verify a reverse ficw exercise on this valve require valve closure for periods that could result in plant transients and are, therefore, not practical during power operation.

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Stat luk tasting (normally performed during a refuel cutage) in accordance with 10CFR50, Appendix J also confimis successful reverse flow operability in the closed direction.. A review of LLRT data from 1984 until 1995 shows this valve has a history of good leakage test results (with all tests equal to or below 0.1 SLM), and no signs of a declining performance trend. This performance record provided the basis under option 'B' of Appendix J to extend the LLRT test frequency of 30-CK-432 from 2 years to 60 months. Similarly, records of past in service testing of 30-CK-432 indicate the valve is reliable.

In addition to in service und Appendix J testing, the 30-CK-432 was disassembled April 24,1993, hand exercised, and its accessible areas were inspected for abnormal wear ano signs of degradation as part of the Pilgrim check valve program. During the exercise, this valve functioned smoothly with no signs of excessive force or binding. The examination showed no internal abnormalities (structural deformation, crack-like flaws, loose or detached items) or signs of excessive erosion / corrosion.

Since past test data indicate this temporary ralief from adherence to the license as it relates to this schedule for 30-CK-432 does not result in a significant reduction in confidence that the valve will perform its designed safety function, operating Pilgrim Station in accordance with the requested Technical Specification Amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Operating Pilgrim in -accordance with this proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

- As stated in the narrative of 1 above, testing the valve on line is not feasible, and shutting down places unnecessary stresses on the plant when compared to the value of performing the test.

There is high confidence the valve will function as designed; therefore, operating Pilgrim in accordance witn the proposed Technical Specification Amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Operating- Pilgrim in accordance with this proposed amendment does not involve a significant reduction in a margin of safety.

In addition, for the reasons given above, the margin of safety is not affected by operating Pilgrim in compliance with this request. There are also no environmental consequences as a result of this request because confidence in the valve's actual operability remains high (in_ contrast to administrative operability), and the design of the plant is not affected. Therefore, operating Pilgrim in accordance with this amendment does not involve a reduction in a margin of safety.

This request has been reviewed and concurred with by Pilgrim's Operations Review Committee and Nuclear Safety Review and Audit Committee.

CONCLUSION This request for a Technical Speification Amendment is a temporary change that will terminate when reverse flow testing is penurmed no later than the 1998 maintenance outage. The reason we make this request is because a surveillance within tne purview of our IST program was inadvertently missed during our last refueling outage, which will result in valve 30-CK-432 becoming administratively inoperable November 2,1997. Performing the surveillance during power operation has the potential to degrade essential equipment and could subject the plant to 4

transients (such es a roactor trip on high-drywell prsssuro) without a significant increase in safety.

Shutting the plant down to perform the surveillance also subjects the plant to potential transients without a significant increase in plant safety. Therefore, we submit this emergency amendment request because operating Pilgrim in accordance with the proposed amendment does not result in a significant hazard to plant safety.

Schedule of implementation This Technical Specification Amendment will be implemented upon receipt of NRC approval.

Thank you for your attention to this issue. Should you require further information on this request, please contact P.M. Kahler at (508) 830-7939.

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E. T. Boulette PMK/dmc/noed Commonwealth of Massachusetts)

County of Plymouth )

Then personally appeared before me, E. T. Boulette, who being duly swom, did state that he is Senior Vice President - Nuclear, Boston Edison Company and that he is duly authorized to execute and file the submittal contained herein in the name and on behalf of Boston Edison Company and that the statements in said submitta! are true to the best of his knowledge and belief.

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cc: Mr. Alan B. Wang, Project Manager ca \ V.* O - - /;

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Mail Stop: OWF 14B2 . .

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- Region i 475 Allendale Road King of Prussia, PA 19406 -

Senior Resident inspector Pilgrim Nuclear Power Station 5

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