ML20248J194
| ML20248J194 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 10/04/1989 |
| From: | Whittier G Maine Yankee |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GDW-89-323, GL-89-04, GL-89-4, MN-89-123, NUDOCS 8910130123 | |
| Download: ML20248J194 (3) | |
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MaineYankee j:
REUABLE ELECTRICITY FOR MAINE SINCE 1972 i
EDyON DRIVE
- AUGUSTA, MAINE 04336 * (207) 622-4868 October 4, 1989 i-MN-89-123
-GDH-89-323-UNITED STATES NUCLEAR REGULATORY COMMISSION
' Attention: ~ Document Control Desk
'Hashington, D. C.
20555
References:
(a) License No. DPR-36 (Docket No. 50-309)
(b) NRC Letter to Maine Yankee dated April 3,1989, Guidance on Developing Acceptable Inservice Testing Programs (Generic Letter No. 89-04)
(c) Maine' Yankee Letter to USNRC dated August 8, 1983 (MN-83-165)
Subject:
Maine Yankee Inservice Testing Program Gentlemen:
HRC Generic-Letter No. 89-04 (Reference b) provides' guidance on developing acceptable Inservice Testing (IST) Programs. The Generic Letter constitutes app _roval of currently submitted IST program relief requests provided that licensees "(1) review their most recently submitted IST programs and
' implementing procedures against the positions delineated in Attachment 1 (of the letter) and (2) within six months of the date of (the) letter confirm in writing their conformance with the stated positions." The Generic Letter recognizes' that equipment modifications and/or IST program changes may be necessary as a result of the letter.
In these cases, the Generic Letter states that any changes to the IST program and a schedule for completing required modifications should be submitted to the NRC.
. Maine Yankee's Inservice Testing Program was submitted to the NRC with Reference (c). Maine Yankee has also submitted several relief requests, in accordance with 10 CFR 50.55a(g). He have conducted a comprehensive review of our IST program as required by the Generic Letter.
This review has shown that changes to the program are needed.
Paragraph 50.55a(g)(1) of 10 CFR Part 50 requires that certain pumps and valves "shall meet the requirements, except design and access provisions...
set forth in Section XI" of the ASME Boiler and Pressure Vessel Code.
The scope of Section XI of the Code addresses components "which are required to perform a specific function in shutting down a reactor to the cold 8910130123 891004 l-PDR ADOCK 05000309 h4[
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- United States Nuclear Regulatory Commission HN-89-123 1
Attention: Document Control Desk Page two shutdown condition or in mitigating the consequences of an accident." Maine Yankee's existing IST program was focused on testing the components and j
functions that are necessary to mitigate a design basis accident. The i
guidance provided in the Generic Letter places more emphasis on component reliability, multiple functions, and measurement and analysis details.
l Maine Yankee has identified changes to the IST program and procedures, and physical plant backfits necessary to conform with the positions stated in the Generic Letter.
The following actions are planned to conform our IST program with the Generic Letter:
1.
Procedures for quarterly testing are currently scheduled to be revised by October 31, 1989. Most of these changes involve the addition of acceptance criteria and test documentation for check valve functions.
The previous tests provided assurance that components would support our safety analysis, but they did not address all the interpretation in the Generic Letter.
2.
Test procedures implemented during shutdowns are being revised to add or improve testing that may be performed without additional equipment. These revisions are currently scheduled to be completed by December 31, 1989. Our next scheduled cold shutdown is for Cycle 11/12 refueling in the spring of 1990. He therefore believe that this schedule is adequate.
3.
The IST program is being revised as a result of our review for conformance with the positions in the Generic Letter. After the appropriate internal reviews and approvals, we will submit the revised IST program to the NRC. With this submittal, we will submit a letter confirming conformance to the guidance in the Generic Letter (with exceptions, scheduled to be resolved - see below).
The IST program revision and conformance letter are currently scheduled to be submitted by December 31, 1989.
4.
Maine Yankee was not designed nor constructed in a manner to permit some of the testing required to conform witn the Generic Letter.
l Additional flow measuring devices and plant modifications would be necessary to allow back flow and full flow testing of certain check valves, leak testing of certain Category A valves and/or testing of certain pumps in accordance with the Generic Letter. Maine Yankee is evaluating these modifications in accordance with the NRC's rules governing backfits. The outcome of that evaluation notwithstanding, l
backfitting the plant requires detailed engineering evaluations, procurement of materials and preparation of installation instructions. Should Maine Yankee determine that backfits are appropriate, they would be accomplished by the end of our refueling shutdown scheduled for the winter of 1991.
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'United States Nuclear Regulatory Commission MN-89-123 Attention:. Document Control Desk Page three 3
-i 5.
Position 8 of Attachment 1 of the Generic Letter addresses a potential conflict between the ASME Code data analysis interval j
versus Maine Yankee Technical Specification action statement time periods.
The NRC position is that'"(w) hen the data is determined to -
be within the required action range of (the Code) the (pump or valve) is inoperable and the TS ACTION statement time starts." Maine Yankee agrees with the intent of this position, but would like to clarify our position.
In measuring and recording data for pump tests, there have been and will continue to be instances when an instrument and/or its readings are not accurate. Readings from a single instrument should not, in and of itself, be considered sufficient to warrant declaring a pump inoperable. Therefore, in a case where.an instrument appears to be giving faulty, inaccurate, or unreliable indications, and all other parameters are normal, the single instrument or reading need not be recognized as cause for declaring the pump inoperable provided the reading (s) are verified. Procedures require this verification to be performed within eight (8) hours.
This interpretation is acceptable under ASME Section XI, and we believe that it assures the level of quality and safety that is required.
In summary, Maine Yankee has actively and aggressively pursued the review and improvement of its Inservice Testing Program, as required by NRC Generic Letter No. 89-04. Additional work.is required to assure full compliance with this letter, as discussed in the foregoing. He believe that the proposed schedule provides reasonable goals for enhancing our IST program. Upon completion of the foregoing actions, we expect that our IST program will conform to the Generic Letter.
Should you have any questions regarding this letter, our plans or our program, please contact us.
Very truly yours, MAINE YANKEE t
hW G. D. Whittier, Manager Nuclear Engineering and Licensing GDH:CLB h
c: Mr. Richard H. Nessman Mr. Hilliam T. Russell Mr. Eric J. Leeds Mr. Cornelius F. Holden 05571/RCC
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