ML20247Q421

Provides Results of Review of Amend to Rev 5 of Inservice Testing Program for Pumps & Valves.Amend to Rev 5 Acceptable for Implementation & That Testing Requirements Impractical for Item for Which Relief Being Granted

ML20247Q421
Person / Time
Site:	Waterford
Issue date:	09/22/1989
From:	Hebdon F Office of Nuclear Reactor Regulation
To:	Dewease J LOUISIANA POWER & LIGHT CO.
References
TAC-73417, NUDOCS 8909280191
Download: ML20247Q421 (4)

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-g. UNITED STATES

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, g NUCLEAR REGULATORY COMMISSION p

j .- WASHINGTON, D. C. 20555

%.,,,.* September 22, 1989 f

b 'Dicket No. 50-382 ..

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Mr. J. G.'Dewease v' Senior Vice Fresident'- Nuclear Operations Louisiana Power and Light Company D1 Post Office Box 60340

' New Orleans, Louisiana 70160 IJ

SUBJECT:

INSERVICE TESTING (IST) PROGRAM FOR PUMPS AND VALVES.

WATERFORD STEAM ELECTRIC STATION, UNIT 3, LOUISIANA POWER AND LIGHT COMPANY - AMENDMENT TO REVISION 5 (TAC N0. 73417)

This letter provides the results of the staff review of the Waterford 3 inservice testing program for pumps and valves, specifically, amendment to Revision 5 which was approved by letter to Louisiana Power and Light Company (LP&L) dated February 7,1989.

p By. letter dated June 19, 1989, LP&L submitted an amendment to the IST program through Revision 5. The proposed changes address ccncerns from the staff's Safety Evaluation dated February 7,1989 as transmitted to the licensee by letter dated February 7,1989. The changes were also discussed at a meeting on May 9,1989 with the licensee. The changes and one new relief are as 7 follows:

L 1. Change 2.1.3 - For pumps tested using mini-recirculation flow paths, flow L is added to the parameters when determining operability consistent with the February 7,1989 Safety Evaluation.

2. Change 3.1.1 - Rapid acting valves which exceed their two second stroke time limit will be declared inoperable consistent with the February 7, 1989 Safety Evaluation.

3. Change 3.1.4 - Relief request was deleted and a clarification statement proposed that cold shutdown valves exceeding the increased frequency testing criteria will be repaired prior to startup or the plant conditions established to perform the monthly required testing. This also is consistent with the February 7,1989 Safety Evaluation.

4. Change 3.1.34 - Relief request was determined to be unnecessary and deleted.Section XI has no exercising requirements for passive valves.

5. Change 3.1.54 - Relief request was determined to be unnecessary and deleted. Pressure-regulating valves are exempt from Section XI requirements.

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s909280191 890922 PDR ADOCK 05000382 p FDC

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'Mr. J. G. Dewease 6. . Relief 3.1;55 (new) - It is requested that relief from trending in accordance withIWV-3427(b)begrantedfromSectionXIforcontainmentisolation valves tested in accordance with 10 CFR Part 50, Appendix J. The leak test procedures and requirements are equivalent for Appendix J and IWV-3421 through IWV-3425 and the use of' Appendix J tests to fulfill these ASME requirements is appropriate. The analysis of leakage rates and corrective action requirements of IWV-3426 and IWY-3427(a) which are not performed by Appendix J testing will be followed. The licensee requests relief from IWV-3427(b), trending,onthebasisthatcurrentcoderequirementsfor trending within the reference values with current instrumentation is not practical or informative, i.e., data at these points may mislead and may not give an accurate trend. We agree with the licensee and find no basis for continuing this requirement as currently defined under IWV-3427(b);

the trending is impracticable. We also find that continuing to trend data in accordance with IWV-3427(b) for these valves is burdensome with no resultant value or purpose.

" We have determined that the amendment to Revision 5 is acceptable for implement-

< .ation. We have also determined that testing requirements are impractical for theitemforwhichreliefisbeinggranted,andpursuantto10CFR55.55a(g)(6)(i),

that the granting of relief 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, we have given due consideration to the burden that could result if this requirement is imposed on your facility.

This letter grants the relief identified above.

Program changes such as revisions or additional relief request or deletion of any components from the IST program should be submitted for our review but should not be implemented prior to review and approval.

Please contact your Project Manager, David L. Wigginton at (301) 492-3027, if you need any clarification.

Sincerely, Original Signed By Frederick i Hebdon Frederick J. Hebdon, Director Project Directorate - IV Division of Reactor Projects III, IV, V and Special Projects Office of Nuclear Reactor Projects cc: See next page DISTRIBUTION Docket File NRC PDR Local PDR PD4 Reading G. Holahan ADR4 F. Hebdon P. Noonan D. Wigginton OGC-Rockville E. Jordan B. Grimes ACRS(10) PD4 Plant File DOCUMENT NAME: W3 LTR/73417

• SEE PREVIOUS CONCURRENCES PD4/LA* PD4/PM* MEB* OGCkjI ~ PD4/D1)

PNoonan DWigginton:bj TMarsh M1p FHebd6d 07/31/89 08/08/89 08/I4/89 09/f/89 f 09/J2/89 L

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Mr. J. G. Dewease 6. Relief 3.1.55 (new) - It is requested that relief from trending in accordance with IWV-3427(b) be granted from Section XI for containment isolation valves tested in accordance with 10 CFR Part 50, Appendix J. The leak test procedures and requirements are equivalent for Appendix J and IWV-3421 through IWV-3425 and the use of Appendix J . tests to fulfill these ASME '

requirements is appropriate. The analysis of leakage rates and corrective action requirements of IWV-3426 and IWV-3427(a) which are not performed by Appendix J testing will be followed. The licensee requests relief from'- -

IWV-3427(b), trending, on the basis that current code requirements for trending within the reference values with current instrumentation is not practical or informative, i.e., data at these points may mislead and may not give.an accurate trend. We agree with the licensee and find no basis for continuing this requirement as currently defined under IWV-3427(b);

the trending is impracticable. We also find that continuing to trend data in accordance with IWV-3427(b) for. these valves is burdensone with no resultant value or purpose.

We have determined that the amendment to Revision 5 is acceptable for implement-ation. We have also determined that testing requirements are impractical for the item for which relief is being granted, and pursuant to 10 CFR 55.55a(g)(6)(i),

that the granting of relief is authorized by law, will not endanger life er property or the common defense and security, and is otherwise in the public interest. In making this determination, we have given due consideration to the burden that could result if this requirement is imposed on your facility.

This letter grants the relief identified above.

Program changes such as revisions or additional relief request or deletion of any components from the IST program should be submitted for our review but should not be implemented prior to review and approval.

Please contact your Project Manager, David L. Wigginton at (301) 492-3027, if you need any clarification.

Sincerely, l

0>< t-Frederick J. Hebd6n, Director

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Project Directorate - IV l

Division of Reactor Projects III, IV, Y and Special Projects j

Office of Nuclear Reactor Projects 1

cc: See next page E---_---_ - _ _ _

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Mr. Jerrold G. Dewease Waterford 3 Louisiana Power & Light Company q 1

cc:

W. Malcolm Stevenson, Esq. Regional Administrator, Region IV Monroe & Leman U.S. Nuclear Regulatory Commission 201 St. Charles Avenue, Suite 3300 Office of Executive Director for New Orleans, Louisiana 70170-3300 Operations 611 Ryan Plaza Drive, Suite 1000 Mr. E. Blake Arlington, Texas 76011 Shaw, Pittman, Potts & Trowbridge 2300 N Street, NW Mr'.~ William H. Spell, Administrator Washington, D.C. 20037 Nuclear Energy Division Office of Environmental Affairs Resident Inspector /Waterford NPS

• Post Office Box 14690 Post Office Box 822 Baton Rouge, Louisiana 70898 K111ona, Louisiana 70066 Mr. Ralph T. Lally President, Police Jury Manager of Quality Assurance St. Charles Parish Middle South Services, Inc. Hahnville, Louisiana 70057 Post Office Box 61000 New Orleans, Louisiana 70161 Chairman William A. Cross Louisiana Public Service Commission Bethesda Licensing Office One American Place, Suite 1630 3 Metro Center l Baton Rouge, Louisiana 70825-1697 Suite 610 L Bethesda, Maryland 20814 l Mr. R. F. Burski Nuclear Safety and Regulatory Affairs Manager Louisiana Power & Light Company 317 Baronne Street l

New Orleans, Louisiana 70112

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