ML20235G737

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Safety Evaluation Supporting Rev 2 to Inservice Testing Program,Providing Cold Shutdown Valve Testing Justifications & Addl Relief Requests
ML20235G737
Person / Time
Site: Vogtle Southern Nuclear icon.png
Issue date: 09/22/1987
From:
NRC
To:
Shared Package
ML20235G734 List:
References
NUDOCS 8709300193
Download: ML20235G737 (10)


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ENCLOSURE 1 SAFETY EVALUATION IST PROGRAM CHANGES AND REQUESTS FOR RELIEF'

, V0GTLE UNIT 1 7 ,

INTRODUCTION In accordance with the requirements of 10 CFR 50.55a, Georgia- Power Company (GPC) submitted the Inservice Testing (IST) Program for Vogtle Electric Gener-ating Plant, Unit 1 by letter dated July 30, 1986. As a result of NRC review and comments, GPC revised its IST program for Vogtle Unit I and by letter dated October 30, 1986, submitted Revision 1 of the Vogtle Unit 1 IST program for final staff review and approval. The NRC staff found Revision 1 of the Vogtle Unit 1 IST program acceptable as discussed in Supplement 6 of the Vogtle Safety Evaluation Report (NUREG-1137) dated March 1987.

By letters dated June 25, 1987 and August 27, 1987, . GPC submitted Revision 2 of the Vogtle Unit I program for staff review and approval. Revision 2 contains mostly program changes resulting from operating experiences, and additional re-quests for relief from American Society of Mechanical Engineers-(ASME) Boiler and Pressure Vessel Code Section XI, Subsections IWP, " Inservice Testing of Pumps in fuclear Power Plants," and IWV, " Inservice Testing of Valves in Nuclear Power Plants," requirements. The staff's evaluation and conclusions regarding _ Revision 2 of the Vogtle Unit 1 IST program are provided below.

EVALUATION i

The staff's contractor, EG&G Idaho, Inc., has reviewed the licensee's submittals pertaining to Revision 2 and has prepared an evaluation of the proposed revision to the Vogtle Unit 1 IST program (see Enclosure 2). The staff has reviewed the contractor's evaluation and concurs in its findings. IA summary of the staff's evaluation and conclusions is presented in Table 1. Where appropriate, a re-mark is provided to clarify the conclusions. j CONCLUSION Based on its review of the licensee's revised IST program and relief requests, the staff concludes that the IST program will provide reasonable assurance of the operational readiness of the pumps and valves covered by the IST program to perform their safety-related functions. The staff has determined that

' pursuant to10 CFR 50.55a(g)(6)(1) granting relief where-the ASME Code require-ments are impractical is authorized by law and will not endanger life or property, or the common defense and security. The staff has also concluded that granting relief is otherwise-in the public interest considering the burden that could-result -if- the requirements were imposed on the-facility. During' the review of the licensee's inservice testing program the staff has not identified any significant misinterpretation or omissions of Code requirements. Thus, the

.IST program, Revision 2, dated June 25, 1987, as supplemented by letter dated

' August 27,1987, is acceptable for implementation.

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TABLE 1

SUMMARY

OF V0GTLE UNIT 1 INSERVICE TESTING PROGRAM, REVISION 2, CHANGES AND' RELIEF RE0 VESTS Description of Changes NPr Evaluation Remarks and/or Relief Requests and Conclusions Relief Recuest PR-4 was added to the Relief Granted Alternative Program. The PR-4 requests relief method is to measure pump vibration at found acceptable different locations than those required by the Code.

A note was added to Relief Request PR-2 Acceptable Change was to indicate that instruments to measure made to comply the Code-required flow rate will be with the Code installed before restart following requirement the first refueling outage.

The range on the pressure gauges was Acceptable changed from "O psi to 15 psi" to "-15 psi to 15 psi" to indicate the ranges on the installed instruments.

Deleted reference to RR-3 on valves PV-0455A Acceptable and PV-456A. On Relief Request RR-3, the reference to valves 1201-PV-0455A and 1201-PV-0456 was deleted in order to make RR-3 generic.

Cold Shutdown Justification CS-35 was Acceptable Necessitated by written to allow testing of valves IE Information 1205-HV-8716A and 1205-HV-8716B to be Notice No. 87-01 performed on a co'id shutdown frequency.

Cold Shutdown Justification CS-36 was Acceptable Necessitated by written to allow testing of valves IE Information 1205-U6-001 and 1205-U6-002 to be Notice No. 87-01 performed on a cold shutdown frequency.

Cold Shutdown Justification CS-37 was Acceptable Necessitated oy written to allow quarterly partial- IE Information stroke testing and full-stroke Notice No. 87-01 testing during cold shutdown of valves 1205-U6-009 and 1205-06-010.

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i Description of Changes NRC Evaluation Remarks and/or Relief Recuests and Conclusions i

The- program was changed to delete the Acceptable closed safety position for valves 1205-U6-009 and 1205-06-010. These valves are '

not required to close to perform a safety function.

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Relief Request RR-26 was written to request Relief Request l relief from using mechanical exercisers to withdrawal is j test the spray additive tank vacuum breaker acceptable valves and w&s subsequently withdrawn by letter dated August 27, 1987.

Cold Shutdown Justification CS-38 was written Acceptable to allow testing of valves HV-8508A and HV-8508B during cold shutdown.

The program.was changed to indicate quarterly Acceptable forward-flow-operability testing for valve 1208-U6-032.

Cold Shutdown Justification CS-34 was Acceptable written to allow full-stroke testing of valves 1208-U4-284 and'1208-U4-299 during cold shutdown and partial-stroke testing during the quarterly pump tests.

The program was changed to indicate the Acceptable quarterly reverse-flow-closure testing of valves 1302-U4-113, 1302-U4-114, 1302-04-115, and 1302-U4-116.

Cold Shutdown Justification CS-33 was Acceptable l

written to allow testing of valves 1302-04-125, 1302-04-126, 1302-04-127, and 1302-U4-128 to be performed on a cold ",

i shutdown frequency.

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l Description'ofLChanges NRC Evaluation Remarks and/or Relief Requests 'and Conclusions l

L The program was changed to' indicate that Acceptable

! cvalves' 1592-04-186 and 1592-U4-187 are l' normally closed and that their safety position'is open.

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' An.editoria1Lchange indicating a P&ID Acceptable Editorial change revision which relocated valves HV-9378 and 2420-U4-049 to P&ID 1X4DB186-4.

The program was. changed to indicate that Acceptable valves HV-8208, HV-8209, HV-8211, and .]

HV-8212 are normally closed instead of normally open. Valves HV-8211 and

. HV-8212 have been. replaced with 1.00 in. valves.

Relief Request RR-1 was withdrawn. Acceptable Changes were References to RR-1 were deleted from made to comply the valve tables where appropriate. with SSER 6-t 4

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, . ENCLOSURE 2 l

-LETTER REPORT, TECHNICAL EVALUATION OF REVISION 2 CHANGES FOR PUMP AND VALVE INSERVICE TESTING PROGRAM, V0GTLE~ ELECTRIC GENERATING PLANT,_ UNIT 1 1 pumo Relief Raouest -

The licensee has requested relief from the Section XI-(1983 Edition through Summer 1983 Addenda), IWP-4510 requirement that the direction of vibration measurements be in .the ' horizontal or vertical direction for

' component cooling water pumps P4-001, P4-002, P4-003, P4-004, P4-005, and  ;

P4-006; safety injection pumps P6-003 and P6-004; centrifugal charging ,

pumps P6-002 and P6-003; and auxiliary feedwater pumps P4-001, P4-002, and  !

w P4-003 and has proposed that two permanently mounted vibration transducers {

on each pump installed 45 degrees from the vertical and 90 degrees from l each other be utilized for vibration measurements.

i Licensee's Basis for Recuestino Relief. Each of these pumps has two permanently-mounted vibration transducers (or pickups) installed 45 J D degrees from the vertical and 90 degrees from each other. Both-transducers are used in the quarterly pump testing. Any increase in pump vibration in either the horizontal or vertical direction is detected by both transducers.

1 Evaluation. Utilizing two permanently mounted-vibration transducers installed 45 degrees from the vertical and 90 degrees-from each other-to measure vibration for these pumps-will give information equivalent to or better than the information obtained from the utilization of one measurement point in the horizontal or vertical direction as required by the Code. Based on the determination that it would be burdensome to the licensee if the Code requirement were imposed and that the licensee's proposed alternative testing will detect vibration changes in a manner equal to or better than the Code requirement, relief may-be granted as  ;

requested.  !

i l (pages 2-4, 2-5, 2-8, 2-10, and 3-4 in the Vogtle IST Program Manual)

{ NOTE: The parenthesi:ed page numoers are those of the Vogtle IST Program Manual that have been changed.

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. Additional Cold Shutdown Justifications for Valves l Charging pump alternate miniflow isoldion valves HV-8508A and l HV-8508B (category B) cannot be exercised during power operation since the valves are interlocked with the volume control tank discharge valves LV-0112B and LV-0112C and these valves cannot be exercised during power operation due to interruption of pressurizer level control and possible subsequent plant shutdown. These valves will be full-stroke exercised during cold shutdowns and refueling outages (pages 4-27 and 6-38).

Boric acid transfer pump discharge check valves U4-284 and U4-299 k (category C) cannot be full-stroke exercised during power operation as full flow would adversely affect RCS baron concentration which could result in plant shutdown. These valves will be partial-stroke exercised quarterly and full-stroke exercised during cold shutdowns and refue?ing outages (pages 4-29 and 6-34).

Residual heat removal (RHR) pump discharge check valves U6-009 and U6-010 (category C) cannot be exercised during power operation as the RHR pumps cannot overcome RCS opert. ting pressure. These valves cannot be.

. exercised with full flow to the refueling water storage tank as the required valve lineup would place the plant in an unanalyzed condition outside its established design basis. These valves will be partial-stroke exercised quarterly and full-stroke exercised during cold shutdowns and refueling outages (pages 4-23 and 6-37).

RHR pump suction from the refueling water storage tank (RWST) check valves U6-001 and U6-002 (category C) cannot be exercised during power operation as the required valve lineup would place the plant in an unanalyzed condition outside its established design basis (see IE Information Notice No. 87-01). Thesevalveswillbefull-strogexercised during cold shutdowns and refueling outages (pages 4-23 and 6- M).

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-RHR pump discharge cross-connect isolation valves HV-8716A and HV-8716B (category B)'cannot be exercised during power. operation as l failure in the closed position would place the plant in an unanalyzed-condition outside its established design basis'(see IE Information Notice No. 87-01). These valves will be full-strok'e exercised during cold shutdowns and. refueling outages (pages 4-22 and 6-35).

Auxiliary feedwater system feedwater bypass check valves U4-125, U4-126, U4-127, and U4-128 (category C) cannot be exercised during power operation as flow verification can only be verified during injection of auxiliary feedwater into the steam generators during cold shutdown. These

-p valves will be full-stroke exercised during cold shutdowns and refueling

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- outages (pages 4-44 and 6-33). J l

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OtheriProgram Revisions Not Addressed in TER 4

Concerning-pump relief request =3, the boric acid pump suction pressure gages were identified in revision 1 to have a range of 0 to 15 psig. The actual range of.these gages is -15 to-15 psig and the pump relief request was changed ~ to reflect this. This change has no programmatic effect upon pump' relief request 3 and this relief request will not have to be re-evaluated (page 3-3).

A note was added to pump relief request 2 to indicate that Supplement No. 6 of the Safety Evaluation Report requires that instruments to measure g the Code required flow rate be installed before restart following the first refueling outage. This change has no programmatic effect upon pump relief request 2 and this relief request will not have to be re-evaluated (page 3-2).

The specific reference to the PORVs for valve relief request 3 has been deleted in order to make this relief request for rapid acting valves generic. This changg has no programmatic effect upon valve relief request 3 and this relief request will not have to be re-evaluated (pages 4-7 and 5-3). j I

The closed safety position was deleted for RHR pump discharge check valves U6-009 and U6-010 as these valves are not required to close to perform a safety function. RHR pump miniflow valves FV-0610 and FV-0611 are normally open and allow flow to the suction side of the pumps regardless of the position of valves U6-009 and U6-010 (page 4-23).

The quarterly reverse flow closure testing of auxiliary feedwater to 1 steam generator check valves U4-113, U4-114, U4-115, and U4-116 has been added (page 4-43).

l The quarterly forward flow operability testing for chemical and volume control to regenerative heat exchanger check valve U6-032 has been added (pages 4-28 and 5-16).

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e The program was changed to indicate that safety-related chillers chilled water cooler pump check valves U4-186 and U4-187 are normally closed and that their safety position is open (page 4-54).

A P&ID revision which relocated valves HV-9378 and V4-049 to P&ID 1X408186-4' necessitated an editorial change (page 4-60). -

The program was changed to indicate that sample valves HV-8208,

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HV-8209, HV-8211, and HV-8212 are normally closed instead of normally open. Sample valves HV-8211 and HV-8212 have been replaced with one inch valves (page 4-61). _.

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Valve relief request I was withdrawn as per Supplement No. 6 of the Safety Evaluation Report. References to this relief request were deleted ,

from the valve tables and valve relief request section where appropriate (pages 4-5, 4-6, 4-7, 4-11, 4-12, 4-13, 4-24, 4-26, 4-27, 4-28, 4-33, 4-34, 4-35, 4-36, 4-41, 4-45, 4-49, 4-50, 4-57, 4-60, and 5-1).

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-Pr. J. P. O'Reilly Georgia Power Company Vogtle Electric Generating Plant cc:

Mr. L. T. Gucwa Resident Inspector Chief Nuclear Engineer Nuclear Regulatory Comission Georgia Power Company P. O. Box 572 l P.O. Box 4545 Waynesboro, Georgia 30830 Atlanta, Georgia 30302

( Mr. Ruble A. Thomas Deppish Kirkland, III, Counsel Vice President - Licensing Office of the Consumers' Utility Vogtle Project Council Georgia Power Company / Suite 225 Southern Company Services, Inc. 32 Peachtree Street, N.W.

P.O. Box 2625 Atlanta, Georgia 30303 Birmingham, Alabama 35202 James E. Joiner Mr. Paul D. Rice Troutman, Sanders, Lockerman, Vice President & Project General Manager & Ashmore Georgia Power Company Candler Building Post Office Box 299A, Route 2 127 Peachtree Street, N.E.

Waynesboro, Georgia 30830 Atlanta, Georgia 30303 Danny Feig Mr. J. A. Bailey 1130 Alta Avenue Project Licensing Manager Atlanta, Georgia 30307 Southern Company Services, Inc.

P.O. Box 2625 Carol Stangler Bimingham, Alabama 35202 Georgians Against Nuclear Energy 425 Euclid Terrace Ernest L. Blake, Jr. Atlanta, Georgia 30307 Bruce W. Churchill, Esq.

Shaw, Pittman, Potts and Trowbridge 2300 N Street, N. W.

Washington, D. C. 20037 Mr. G. Bockhold, Jr.

Vogtle Plant Manager Georgia Power Company Route 2, Box 299-A Waynesboro, Georgia 30830 Regional Administrator, Region II U.S. Nuclear Regulatory Comission 101 Marietta Street, N.W., Suite 2900 Atlanta, Georgia 30323 Mr. R. E. Conway Senior Vice President and Project Director Georgia Power Company Rt. 2, P. O. Box 299A Waynesboro, Georgia 30830 s