ML20247N535

SER Accepting Third 10-year Interval Inservice Program for Pump & Valves for Plant,Units 2 & 3

ML20247N535
Person / Time
Site:	Peach Bottom
Issue date:	05/11/1998
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20247N523	List: ML20247N518 ML20247N535 ML20247N542
References
NUDOCS 9805270173
Download: ML20247N535 (14)

Text

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ne UNITED STATES S

NUCLEAR REGULATORY COMMISSION

%, n p WASHINGTON, D.C. 30006 4001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE INSERVICE TESTING PROGRAM. THIRD 10 YEAR INTERVAL PECO ENERGY COMPANY PEACH BOTTOM ATOMIC POWER STATION. UNITS 2 AND 3 DOCKET NOS. 50-277 AND 50-278

1.0 INTRODUCTION

The Code of Federal Regulations.10 CFR 50.55a, requires that inservice testing (IST of certain

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American Society of Mechanical Engineers (ASME) Code Class 1,2, and 3 pumps an)d valves are performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code (the Code) and applicable addenda, except where a!!ematives have been authorized or relief has been requested by the licensee and granted by the Commission pursuant to Sections (s)(3)(i),

(a)(3)(li), or (f)(6)(i) of 10 CFR 50.55a. In proposing altamatives 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.

Nuclear Regulatory Commission (NRC) guidance contained in Generic Letter (GL) 89-04,

" Guidance on Developing Acceptable Inservice Testing Programs," provides altomatives to the Code requirements determined acceptable to the staff. Altematives that conform with the guidance in GL 89-04 may be implemented without additional NRC approval. When attematives 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 maldng this determination, the staff considers the burden on the licensee that would result if the requirements were imposed.

Section 50.55a authorizes the Commission to approve attematives and to grant relief from ASME Code requirements upon making the necessary findings. The NRC staffa findings with respect to authorizing altamatives and granting or not granting the relief requested as part of the licensee's IST program are contained in this safety evaluation (SE).

The licensee was authorized in Relief Request GVRR-3 to base the Peach Bottom IST program on the requirements of the Code 1990 in lieu of the 1989 Edition of ASME Section XI, Subsections IWP and IWV, which is referenced in 10 CFR 50.55a. ASME Operations and Maintenance (OM) Code 1990 is a reformat of the ASME OM Standard and includes Part 6, for IST of pumps (rpferenced by Subsection IWP), and OM Standard, Part 10, for IST of valves (referenced by Subsection IWV). The Peach Bottom IST program covers the third 10 year IST interval. The third 10 year interval for Units 2 and 3 began on November 5,1997, and ends on November 4,2007.

9805270173 980511 ENCLOSURE DR ADOCK 0500 7

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, 2.0 EVAL _UATION 2.1 Relief Requests The NRC staff, with technical assistance from idaho National Engineering and Environmental

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Laboratory (INEEL), has reviewed the information concoming IST program requests for relief submitted for the third 10 year intervtl for Peach Bottom Atomic Power Station, Units 2 and 3, in PECO Energy Company's (the licensee) letters dated May 8,1997, and February 13,1998. The staff adopts the evaluations and recommendations for granting relief or authorizing altamatives contained in the Technical Evaluation Report (TER), included as Attachment 2 to this SE, prepared by INEEL with the exception of the evaluation of Relief Request GVRR-2 which is discussed in Section 2.1.1 of this SE. Attachment 1 to this SE lists each relief request and the status of approval.

For the Peach Bottom Units 2 and 3 IST Program, reliefis 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 leve' of quality and safety, or where compliance would result in a hardship or unusual difficulty without a compensating increase in quality or safety. The following four relief requests were denied:

Relief Request GVRR-1 to use an altamative test frequency for the exercising of manual valves was denied because the licensee did not describe any hardship or unusual difficulty in performing the Code testing, and generic relief was requested for all manual valves instead of requesting specific relief for each valve or group of valves; Relief Request GVRR-4 to use attemative test frequency requirements for certain containment isolation check valves was denied because the licensee did not describe any hardship or unusual difficulty in performing the Code testing; Relief Request GVRR 5 to delete the requirements for position indication verification of Category B passive manual isolation valves because position verification may be used in maintaining the plant in a cold shutdown condition; and Relief Request GVRR 6 to establish a maximum limiting stroke time for rapid acting valves of 5 seconds was denied because the proposed acceptance criterion was not shown to be justified for Category A & B rapid acting valves.

In addition to the relief requests discussed above, the TER states that Relief Request GVRR 2 was denied because the licensee did not provide a list of excess flow check valves which would be tested during system outages. A submittal by the licensee da' ted February 13,1998, contains a revised version of GVRR 2 and is evaluated in Section 2.1.1 of this SE.

The licensee's February 13,1998, submittal also included Relief Request GVRR-7 which was not included in the initial third 10-year program submittal. This relief request is evaluated in Section 2.1.2 of this SE. In addition, the licensee made a change to Relief Request 10-VRR-1 which is discussed in Section 2.1.3 of this SE.

4 3-The granting of relief is based upon the information provided by the licensee in its basis for each relief request and the attematives proposed. Program changes involving new or revised relief requests must be submitted to the NRC for review. Program changes that add or delete components from the IST program should also be periodically provided to the NRC.

2.1.1 Relief Request GVRR-2 The licensee has requested reflef from the exercise procedure requirements of ASME OM Code-1990, Subsection ISTC 4.5, for several excess flow check valves (EFCVs) installed on instrument lines penetrating the containment of each unit. The licensee has proposed to test these EFCVs during system outages when the associated unit is at power. The EFCVs tested during system outages would be tested at a frequency which would be equivalent to a refuelin cycle interval.

XFC-2(3)-02-007A(B)

XFC-2(3)-02-023A(8,C,D)

XFC-2(3)-02-025 XFC-2(3)-02-062A(B,C,D)

XFC-2(3) 02-064A(B,C,D)

XFC 2(3)-02-305A(B)

XFC-2(3)-02-021 A C XFC-2(3)-02-011 XFC-2(3)-12-066A(B)

XFC-2-12-80457L(H)

XFC-2(3)-13-055A(B)

XFC-2(3)-14-031A(B)

XFC-2(3)-23-037A(B)

XF C-2 (3)-02-031 B (C, D, E,G, H,J, K, M, N, P, R,T, U,V,W) 2.1.1.1 Licensee's Basis for Requesting Relief The licenses states:

Excess flow check valves (EFCVs) are installed on instrument lines penetrating containment to minimize leakage in the event of an instrument line failure outside the containment in accordance with Regulatory Guide 1.11. The EFCVis a spring loaded ball check valve.

Since the system is normally in a static condition, the valve ball is held open by the spring.

Any sudden increase in flow through the valve (i.e. line break) will result in a differential pressure across the valve which will overcome the spring and close the valve. Functional testing of valve closure is accomplished by venting the instrument side of the valve while the process side is under pressure and verifying the absence ofleakage through the vent.

The testing described above would require the removal of the associated instrument or instruments from service on a quarterly basis. Removal of any of these instruments from service outside of a scheduled refueling outage or a controlled system outage may cause a spurious signal which could result in a plant trip, an inadvertent initiation of a safety system, loss of decay heat removal and/or the defeating of safety interiocks.

i Testing of EFCVs can be performed during a scheduled system outage when appropriate plant administrative procedures and controls are utilized to ensure plant safety. System outsges are performed in order to enhance system performance and maximize system i

i availability. They sie scheduled on a less than quarterfy frequency (typically once an operating cycle). Taking system outages quarterly solely for the purpose of EFCV testing would result in reduced system availability and increased risk to the plant. NUREG 1482,

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! Section 3.1.2, recommends minimizing equipment out of service time. The additional assurance of operational readiness afforded through surveillance testing must outweigh the impact en plant safetyincuned when removing equipment from service.

I in Section 4.1.4 of NUREG 1482, the U.S. NRC approves the deferral of backflow testing of I

check valves to refueling outages when the testing requires the installation of test equipment. The intent of this request is the same in that EFCVtesting requires a plant evolution which should be avoided unless appropriate plant administrative controls are in l

place.

As discussed in NUREG 1482, the staff recommends that the basis for relief address whether.

(1) the proposed altamative gives an acceptable level of quality and safety, (2) compliance would l

result in a hardship without a compensating increase in the level of safety, or (3) complying with Code requirements is impractical. Two of these criteria, and the basis for meeting the criteria are provided below:

1 The Proposed attemative gives an acceptable level of quality and safety i

A review of NPRDS industry failure data for the Dragon excess flow check valves, which is the manufacturer of the valves used at PBAPS, reveals only 7 failures. The 7 failures break down as follows; 2 were a result of an IST surveillance which failed to meet the acceptance criteria for leakage,1 was an indication (limit switch) problem, and 4 were leakage caused by a bad gasket. Both IST failures occurred at Peach Bottom. A thorough review of Peach Bottom excess flow check valve test history has shown that the 2 NPRDS failures above are the only 2 since 1980. One of the failures,1.1 gpm measured leakage, was due to dirt on the seating surface of the valve; the other,4.0 gpm measured leakage, was due to a defective seating surface in the manual bypass portion of the EFCV. These are 2 independent failures which have not been repeated. Further, this review of surveillance test history shows evidence of no time based failure mechanisms or chronic failures associated with the excess flow check valves. Although the testing of the EFCVs was performed on the previous refueling cycle frequency (approximately 18 months), testing of the EFCVs has been performed since 1993 on a 24 month refueling outage frequency. Therefore, performing the testing of the EFCVs on a 24 month frequencyis appropriate.

Comollance would result in a hardshio without a compensating increase in sefew Personnel safety would decrease if EFCV testing would be performed on a quarterly basis during plant operation without an appropriate system outage. During power operation, the process side of the EFCVs is normally high pressure (>500 psig) and/or high temperature

(>200'F) and highly contaminated reactor coolant. Testing EFCVs during system outage windows with the appropriate administrative procedures and controls applied will ensure personnel safety.

Additionally, testing at a frequency greater than once per operating cycle would also result in i

increased radiation dosage and reduced system availability without any compensating

' increase in saf sty.

5-Improvements in work planning and scheduling have resulted in a significant reduction in outage duration at Peach Bottom. As a result of these improvements, EFCV testing has become an outage critical path activity. Due to the large number of EFCVs and the plant conditions required to perform the testing (reactor pressure > 500 psig), testing all the valves during refueling results in an outage duration increase of approximately 2 days.

Based on current replacement power costs, this equates to an expenditure of

$900,000 per year for the life of the plant.

In order to reduce this level of burden, extensive programmatic and procedural controls are used during system outages to ensure that the impact on plant safety is understood prior to removing equipment from service. This process is consistent with industry practice and NRC guidance, and has been recognized as an effective method of controlling the impac plant activities on safety. During a refueling outage, the constraints on resources are at a premium, and the elimination of work which can be safely performed independent of these constraints is both practical and prudent.

In summary, considering the extremely low failure rate, personnel and plant safety concem and the high monetary cost of testing during refueling outaces, EFCV testing at a frequency greater than once per operating cycle and exclusively during refueling outages is impracticable and results in a hardship without a compensating increase in the level of safety.

2.1.1.1.1 Additional Basis for Testing Certain Valves During System Outages The licensee provided the following information in their letter dated August 9.1995, to support their claim of hardship if all the EFCVs were tested during refueling outages and is repeated here because it clearly describes their unique burden.

The Peach Bottom Atomic Power Station, Units 2 and 3 system design does not include test taps upstream of the EFCVs. For this reason, the EFCVs cannot be isolated and tested using another pressure source; reactor pressure is required to perform the testing. During refueling outages, the duration of time in which adequate reactor pressure is available is much shorter than the time it takes to test all of the EFCVs.

This is based on past experience which has shown that the approximate duration for EFCV testing is 2 days.

A small number of tests (4 valves scheduled for 3R10) can be performed at the beginning of the outage Just after shutdown during depressurization. This depressurization time is approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The remainder of the tests must be performed at the end of the refueling outage when the reactoris again pressurized.

This corresponds to the time when the vessel hydrostatic test is being performed. The scheduled hydrostatic test duration is driven by EFCV testing; EFCV testing is the critical path activity during the hydrostatic test. Based on past history and including contingencies for the complexity of test coordination activities, limit switch adjustnwnts, and vessel depressurizations (see next paragraph), testing the remaining EFCVs during the hydrostatic test would aCd approximately 2 de)s to the ' refueling outage. This represents a significant financial hardship. Additionally, minimizing the hydrostatic test l

6-duration reduces the challenges to the reactor operator caused by ' manually controlling reactor pressure at near solid conditions for extended periods of time.

As a result of more efficient outage planning (i.e., shorter outages), decay heat levels during the hydrostatic test are higher than in the past. If the hydrostatic test was extended to test all remaining EFCVs, the vessel could require depressurization as l

many as 4 times to avoid exceeding the refuel mode built coolant temperature limit of 212 degrees F. This is an evolution which challenges, the reactor operators and thermally cycles the reactor vessel and should be avoided if possible.

2.1.1.2 Altemate Testing:

The licensee proposes:

Functional testing will be performed once per operating cycle during system outages when appropdate plant administrative controls are in place.

2.1.1.3 Evaluation These EFCVs have a safety function in the closed direction to isolate the associated instrument line in the event of a line failure outside of containment. As stated previously in Section 3.3.1 of this SE, it is impractical to exercise the EFCVs quarterfy and during cold shutdowns because of the loss of reactor protection and control signals and the potential for inadvertent reactor scrams.

The licensee has identified above the valves that can be tested at power when their associated system is nut of service for a scheduled maintenance outage.

The licensee stated that current methods employed for testing these valves would increase the length of their refueling outage by approximately 2 days. This is because the instrument lines at Peach Bottom do not have test taps upstream of the EFCVs which would allow the attachment of an attemate pressure source to conduct closure testing throughout the entire refueling outage.

Without this configuration, the EFCVs can only be tested during refueling outages when the reactor vessel is adequately pressurized. This occurs immediately after shutdown when the i

reactor is being depressurized and during the reactor vessel hydrostatic test. The licensee stated that testing conducted during the hydrostatic test is on the critical path to the refueling outage schedule. Therefore, testing all EFCVs during the refueling outage at Peach Bottom directly effects the length of the refueling outage.

The licensee has proposed to test the valves listed above during scheduled system outages while the reactor is at power. The frequency of testing for these valves would be similar to the refueling cycle length of 24 months currently at Peach Bottom. Both the Technical Specification

. (TS) and the IST program allow one-time 25 percent extensions of testing intervals. However, if a particular testing interval had the potential to exceed the extended frequency, the licenses would be ra,1 red to request an extension to the TS and IST frequencies and provide adequate basis for the exionsion.

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Testing these valves during refueling outages is not impractical, however, Peach Bottom appears to have a unique burden because the capability does not exist to test these valves throughout the refueling outage. It is a hardship for the licenses to test the EFCVs listed above during reactor

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vessel hydrostatic testing, because it would extend the refueling outage, and there exists other means to test these valves. The licensee's proposed testing provides a reasonable assurance of operational readiness because the EFCVs will be tested at a frequency similar to the refueling outage frequency.

2.1.1.4 Conclusion The proposed altamative to the Code exercise procedure requirements is authorized for the EFCVs listed in Section 2.1.2 of inis SE that can be tested at power in systems that are out of service pursuant to 10 CFR 50.55a(a)(3)(ii) based on the determination that the proposed testing provides reasonable assurance of operational readiness *M compliance with the specified i

requirements results in a hardship without a compensating mcrease in the level of quality and safety.

2.1.2 Relief Request GVRR-7 The licensee has requested relief from the check valve exercise test requirements of the ASME OM Code-1gg0, Subsection ISTC 4.5, for the high Pressure coolant injection (HPCI) and the reactor core isolation cooling (RCIC) vacuum relief check valves listed below. The licensee has proposed to test these valves as a group in accordance with NUREG 1482, Section 4.1.1.

VRV 2-13C-13gA,B,C,D VRV 2-23C-140A,B,C,D VRV 313C-13gA,B,C,D VRV-3 230-140A,B,C,D 2.1.2.1 Licensee's Basis for Requesting Relief:

i The Licenses states:

These check valves, which function as vacuum relief valves, perform a safety function in the i

open direction to prevent siphoning of suppression pool water into the turt ine exhaust line when the HPCI and RCIC systems are shutdown. These valves also perform a safety function in the closed direction to prevent back flow of HPCI and RCIC turbine exhaust steam through the vacuum breakerlines.

l The valves are installed in series-parallel and were not provided with air operators to facilitate testing (exercising). The piping configurations in the HPCI and RCIC systems do not allow for individual testing of these valves. All valves shall be included in the IST Program as discussed in NUREG 1482, Section 4.1.1.

2.1.1.2 Altomate Testing:

The licensee proposes:

The above valves will be tested quarterfy in the forward and reverse directions as a unit.

Forward exercise testing will be performed by verifying the turbine exhaust lines are drained.

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3 Valve closure will be vertfled by monitoring the HPCI and RCIC turbine exhaust vent high temperature alarms located upstream of the valve assemblies. High temperature alarms will l

Indicate steam leakage past the valves.

2.1.1.3 Evaluation The Code requires that check valves be exercised quarterty to the positions required to fulfill their safety function. These valves have a function to open to equa!!ze pressure between the torus air space and the HPCI and RCIC turbine exhaust lines thus preventing siphoning of suppression pool water in'o the exhaust lines. These valves also have a safety function to close to ensure that there is no diversion of HPCI and RCIC tuttine exhaust into the torus air space.

Each vacuum relief configuration in the HPCI and RClO systems of both units consists of four valves, two branches with two valves each in series with a cross-tie line connecting both branches between the upstream and downstream valves. There are no means to test any of the valves individually. It would be a hardship for the licenses to test these valves in accordance with the Code requirements. However, there are other means to ensure that the valves could perform their safety functions.

The licenses references the guidance in NUREG-1482, Section 4.1.1, which discusses closure verification of series check valves without intermediate test connections. NUREG-1482 states that testing pairs of valves is acceptable if the configuration does not require two valves. In addition, it states that when the closure capability of the valves is questionable, both valves must be declared inoperable and corrective actions must be taken for both valves as necessary before they are retumed to service. Relief is required to implement this guidance because testing valves to their safety function as a unit is not in accordance with the Code. While the guidance in NUREG-1482 refers only to the closure function, the open function would also be applicable in this instance because each unit of four check valves has a common inlet and discharge and both branches are interconnected. This eliminates any concems about verification of flows in multiple parallellines as discussed in GL 8g-04, Position 1.

Each vacuum relief configuration consists of two pairs of valves in series. At least two of the four valves in a system would have to fallin order for the system to be incapable of performing its safety function. Since it would be unlikely to determine which valves had failed, all four valves in the system should be declared inoperable in the event of a failure of the system to perform its safety function and corrective actions should be applied to these valves, as necessary, prior to retuming the valves to service. The licenses has not specifically committed in its relief request to declare all four valves in a system inoperable and perform corrective ac%ns prior to retumJng the valves to service. The proposed altamate testing provides reasonable assurance of operational readiness provided that the licensee commits to declaring all four valves in the system inoperable in the event of a failure of the system to perform Itr, safety function and apply corrective actions, as necessary, prior to retuming the valves to service.

The licenses has also discussed the open and closed test acceptance criteria for the check velves in its relief request. The Code requires that the valves be exercised or examined in a manner that verifie s obturator travel to the closed, full-open, or partla!!y open position required to fulfillits safety function. The test acceptance criteria of monitoring the HPCI and RCIC turbine high temperature vent alarms located upstream of the valve assemblies to verify closure of the

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valves is defirittive and sufficiently quantifiable. However, the "open" acceptance criterion, as described in the relief request of verifying that the tutt>ine exhaust lines are not drained, does not appear to meet the same standard. The licenses should evaluate this acceptance criterion further to ensure that it is adequate. This may be subject to future evaluation by an NRC inspector.

L 2.1.2.4 Conclusion l

The proposed attemative to the check valm exercise test requirements of the ASME OM Code-1990, Subsection ISTC 4.5, for the HPCI RCIC vacuunt relief check valves listed in Section 2.1.1 l

of this SE is authorized pursuant to 10 CFR 50.55s(s)(3)(ii) based on the determination that i

compliance with the specified requirements results in a hardship without a compensating l

increase in the level of quality and safety. The attemative is authorized with the provision that all l

four valves in th9 system are declared inoperable in the event of a failure of the system to perform its function and corrective actions are taken, as necessary, prior to retuming the valves to service. The licensee should provide a commitment to this provision within one year from the date of thB SE.

The check valve "open' acceptance criterion for these valves, as described in the relief request doe.s not appear to be definitive aid sufficiently quantifiable. The licensee should evaluate this acceptance criterion further to ensare that it is adequate. This may be subject to future evaluation by an NRC inspector.

2.1.3 Ralief Request 10 VRR-1 i

The licensee has modified this relief request in its February 13,1998, submittal to delete the l

following sentince:

l Although, only one valve is required by design to provide isolation capability, testing these valves as a pair is preferable to valve disassembly and inspection.

The deletion of this sentence does not affect the determination in the TER on the basis that only l

one valve is required to perform the closure safety function which is typical of check valves of l

this configuration in stay-fill systems. However, as stated in NUREG-1482, Section 4.1.1,if the series valves are specifically required by the plant safety analysis assumptions, the Code requires verification of the capability of each of the pair of valves to function. Therefore, the l

approved relief request does not apply if both valves are required to perform the closure safety l

function. The licenses should revww the scope requirements of these valves and the NRC i

guidance in NUREG-1482 and maka any changes to its IST program as necessary.

I 2.2 Deferred Test Justifications The test deferrals of valves, as allowed by OM 10, were myiewed as part of INEEL's evaluation.

Results of the review are provided in Appendix C of the 1ER with recommendations for further review by the licenses for specific de errsis. Results of the review of deferred test justifications r

do not necessarily constitute firm! approval and are subject to NRC inspection.

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. 2.3 System Review INEEL, using the Peach Bottom Updated Final Safety Analysis Report (FSAR), conducted a scope review for the following systems against the requirements of Section XI and the regulations: auxiliary feedwater, main steam; reactor vessel head venting; containment spray; and service water. 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 almilar issues, and revise their program and take any necessary actions as appropriate.

In a phone conversation on January 13, igg 8, the staff discussed questions raised by the contractor conceming the scope of certain components in the emergency service water system.

Section 10.24.4 of the FSAR was recently revised to state that the emergency service water booster pump had flow measurement capability to perform ASME Code testing. It appears tha certain components referenced in the licensee's IST program under Technical Position 1 (T might be within the scope of the IST program. The contractor treated this Technical Position as a relief request, and it is evaluated in Section 4.4.2.1 of the TER. The licenses should evaluate the applicability of components referenced in TP-1 to the IST program and make any chang necessary within one year or the next refueling outage, whichever is longer.

2.4 Relief Requests in Accordance with NRC GL 8g-04 For any relief granted pursuant to GL 8g-04 the staff (with technical assistance from INEE reviewed the information submitted by the licensee to determine whether the proposed attemative testing follows the relevant position in the GL Relief Request 03A VRR-1, which is evaluated in Sections 4.2.1 and 4.2.2 of the TER, is granted pursuant to 10 CFR 50.55a(f) because it conforms to the guidance for Position 7 of Attachment 1 of GL 8g-04.

New or revised relief requests that meet the positions stated in GL Sg-04, Attachment 1, should be submitted to the NRC but may be implemented prior to staff approval provided the guidan GL Sg-04, Section D, is followed.

2.5 Actionitems The IST program relief requests which are granted or authorized are acceptable for implementation provided the action items identified in Appendix A of the TER, the progra issues identified in Appendix B of the TER, and the additional SE action items listed below, are addressed within one year from the date of this SE or by the end of the next 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, ac* ions in progress, or actions to be taken, to address each of these items.

1. In Relief Request CVRR-7, the licensee should commit to declaring all four valves in the system inoperable in the event of a failure of the system to perform its function and apply corrective actions, as necessary, prior to retuming the valves to service (See Section 2.1.2 of this SE).

2. The licensee should evaluate the check valve "open" acceptance criterlon for the valves in Relief Request GVRR-7 because the current acceptance criterion does not appear to be definitive and sufficiently quantifiable (See Section 2.1.2 of this SE).

3. The licensee should review the scope requirements of the valves referenced in Relief Request 10-VRR-1 and the NRC guidance in NUREG 1482 to ensure that only one valve is required to fulfill the closure safety function and make any changes to their IST program as necessary (See Section 2.1.3 of this SE).

4. The licensee should evaluate the applicability of components referenced in TP-1 tEths IST program and make any changes as necessary (See Section 2.3 of this SE).

3.0 CONCLUSION

I The Peach Bottom 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 concurs with the evaluations and recommendations for granting relief or authorizing altomatives with the exception of the evaluation of Relief Request GVRR-2 which is discussed in Section 2.1.1 of this SE and is based on a letter from the licenses that was obtained after the INEEL TER was submit staff. A summary of the relief request determinations is presented in Attachment 1. The authorizing of altamatives or granting of relief is based upon the information provided by the licensee in its basis for each relief request and the altamatives proposed. The implementation of the IST program and relief requests is subject to inspection by the NRC.

The licensee should refer to Appendices A and B of the TER and Section 2.5 of this SE 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 Appendices A and B of the TER and Section 2.5 of this SE 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.

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. The staff has determined that granting relief pursuant to 10 CFR 50.55a (f)(6)(i) and authorizing altomatives pursuant to 10 CFR 50.55a (a)(3)(i) or (a)(3)(ii) may be 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.

Attachments: 1. SummaryTable

2. Technical Evalution Report.

Principal Contributor: J. Collaccino Date: May 11, 1998 4

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