ML20127M724

SE Concluding That Relief Requests Submitted on 920507 Are Covered by Rulemaking on 920908,which Was Incorporated Into 10CFR50.55a(b)

ML20127M724
Person / Time
Site:	South Texas
Issue date:	01/19/1993
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20127M718	List: ML20127M714 ML20127M724
References
NUDOCS 9301280287
Download: ML20127M724 (5)

Text

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I !a ucy'e UNITED $TATEs P' Tgn NUCLE AR REGULATORY COMMISSION y s j' wassiwaiON, D. C. 20555

\....j SAFETY EVALVATION BY THE OFFICE,0F NUCLEAR REACTOR REGULATION EfLATED TO THE INSERY1CE TESTIN0 PROGRAM RELiffFEQVJJi]ji 110VSTON LIGHTING & POWER COMPANY CITY PUBLIC SERVICE BOARD OF SAN ANTONIO CENTRAL POWER AND LIGHT COMPANY (ITY OF AUSTIN. TEXAS

.500TH TEXAS PROJECT. UNITS 1 AND 2 EOCKET NOS. !!Q-490 AND 50-499

1.0 INTRODUCTION

The Code of Federal Regulations, 10 CFR So.55a, requires that inservice testing (IST) of certain ASME Code Class 1, 2, and 3 pumps and valves be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable addenda, except where relief has been granted or proposed alternatives have been authorized by the Commission pursuant to 10 CFR 50.55a (a)(3)(i), (a)(3)(ii) or (f)(6)(i). In order to obtain authorization or relief, the licensee must demonstrate that: (1) conformance is impractical for its facility; (2) the proposed alternative provides an acceptable level of quality and safety; or (3) compliance would result in a hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Section 50.55a(f)(4)(iv) provides that inservice tests of pumps and valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in (b) of 5 50.55a, subject to the limitations and modifications listed, and subject to Comission approval. NRC guidance contained in Generic Letter (GL) 89-04, ' Guidance on Developing Acceptable Inservice Testing Programs," provided alternatives to the Code requirements determined to be acceptable to the staff and authorized the use of the alternatives in Positions 1, 2, 6, 7, 9, and 10 provided the licensee follow the guidance delineated in the applicable position. When an alternative is proposed which is in accordance with GL 89-04 guidance and is documented in the IST program, no further evaluation is required; however, implementation of the alternative is subject to NRC inspection.

9301200287 930119 0 DR ADOCK 0500

Section 50.55a authorizes the Comission to grant relief from ASME Code requirements or to approve proposed alternatives upon making the necessary findings. The NRC staff's findings with respect to granting or not granting the relief requested or authorizing the proposed alternative as part of the licensee's IST program are contained in this safety Evaluation (SE).

This SE concerns relief requests and supporting information that were submitted in Houston Lighting & Power's (HL&P) letter dated May 7, 1992, for I the South Texas Project, Units 1 and 2, IST program. A review of the licensee's response to an item identified in NRC's letter dated March 19, l 1992, related to testing valves on a cold shutdown frequency now included in Relief Requests RR-51 and RR-46 (by unit) was performed. The results of this review are provided balow. The remaining new or revised relief requests which were also included in the submittal are evaluated below. The South Texas IST Program was developed to the 1983 Edition, Sumer 1993 Addenda, of ASME '

Section XI, for the first ten-year interval of both units.

2.0 QENERAL ITEM Accumulator Discharce Isolation Valves and Accumulator Vent Valves in the staff's letter of March 19, 1992, it was noted that cold shutdown justifications were not included in the IST program for the accumulator discharge isolation valves and accumulator vent valves. The licensee has determined that the accumulator discharge isolation valves may be tested in

t. odes other than cold shutdown using appropriate precautions. Test arocedures are to be revised to provide instruction on the method for testing tie accumulator discharge isolation valves during plant operations on a quarterly basis. The sccumulator vent valves are being reviewed and a relief request or a cold shutdown justification will be prepared and submitted at a later date, as necessary, if the valves continue to be tested on a cold shutdown frequency, NRC approval of the cold shutdown justification is not required, and it may be submitted with the next periodic update of the IST program.

3.0 REllEF RE0 VESTS 50 (UNIT 1) AND 45 (UNIT 2)

The licensee has requested relief from the requirements of IWV-3417 for comparison of stroke times of power-operated valves to previous values and taking corrective action based on a percentage increase over the latest value measured. Alternatively, the licensee proposes to establish baseline values for stroke times.

3.1 Licensee's basis for Relief The licensee stated "Heasuring changes in full-stroke times from a reference value as opposed to measuring changes from the previous test provides a better indication of valve operability. Trenjing from a reference talue based on stroke times obtained while [a] valve is operating properly will reduce the number of times a valve may go into increased frequency due to fluctuating data. Generic Letter 89-04 also suggests that this method of trending is acceptable."

f 3.2 Alternative Testing The licensee proposed "The performance of all power operated valves will be evaluated using reference values for comparing stroke times, as discussed in GL 89-04, " Guidance on Developing Acceptable Inservice Testing Programs,"

rather than previous test values. Reference values will be established from data measured when each valve was known to be operating acceptably."

3.3 Evaluation The staff provided guidance for the use of 'r eference values for stroke timing of power operated valves in Position 5. " Limiting Values of full-Stroke Times for Power Operated Valves," and Position 6, " Stroke Time Heasurements for Rapid-Acting Valves," of AttacNent I to Generic Letter 89-04. With the approval of OH-10, inservice Testing of Valves in Light-Water Reactor Power Plants, j 4,2.1.8, " Stroke Time Acceptance Criteria," the criteria for implementatton of reference values for stroke times in now included in the Code requirements. Pursuant to 10 CFR 50.55a 1 (f)(4)(iv), the staff incorporated the 1989 Edition of Section XI into i 50.55a 5 (b), by rulemaking effective September 8, 1992. The 1989 Edition references the requirements of OH-10 for inservice testing of valves in lieu of IWV requirements. Therefore, the licensee's utilization of reference values for valve stroke time measurement and comparison is acceptable to the staff if the implementation is in accordance with the requirements of OM-10, including all related requirements of Section 4.2.1 for stroke time measurement such as acceptance criteria and corrective action. If the licensee develops the inservice testing of valves using all related requirements of OH-10 for stroke-time measurement of power-operated valves, relief is no longer required based on the September 8, 1992, rulemaking. The guidance in GL 89-04, Position 5, should be utilized to establish the limiting value of stroke times to ensure that the value is not greater than the technical specif' cation or safety analysis limit, if applicable, for each specific valve.

4.0 REllEF RE0 VESTS 51 D) NIT 1) AND 46 (UNIT 2)

The licensee has requested relief from the requirements of IWV-3412 and IWV-3522 to exercise valves tested during cold shutdown conditions and proposes to implement the requirements for scheduling these tests in accordance with the requirements provided in OM-10, 4.1 Licensee's Basis for Relief The licensee stated " Requiring the testing of all cold shutdown valves during a short cold shutdown would limit the unit's capability to startup."

4.2 Alternative Testing The licensee proposed Valve testing will commence no later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after a cold shutdown condition is achieved and continue until complete or until the plant is ready to return to power. Completion of all valve testing will not be a prerequisite to return to power. Any testing not completed

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. during one cold shutdown will be performed during the subsequent cold shutdowns starting from the last test performed at the previous cold shutdown.

For planned cold shutdowns where ample time is available and testing all valves identified for cold shutdown test frequency in the IST program will be accomplished, exception to the 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> will be taken.'

4.3 Evaluation In rulemaking to 10 CFR 50.55a effective September 8, 1992 (57 FR 34666), the 1989 Edition of ASME Section XI was incorporated in (b) of i 50.55a. The 1989 Edition provides that the rules for inservice testing of valves are as specified in OH-10. The staff imposed no limitations to OH-10 associated with testing valves during cold shutdown. Section 50.55a (f)(4)(iv) provides that inservice tests of valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in (b) of i 50.55a, subject to the limitations and modifications listed, and subject to Commission approval. Portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met.

OM-10, Paragraphs 4.2.1.2(g) and 4.3.2.2(g) specify the following:

Valve exercising during cold shutdown shall commence within 48 hr. of achieving cold shutdown, and continue until all testing is complete or the plant is ready to return to power. For extended outages, testing need not be commenced in 48 hr. provided all valves required to be tested during cold shutdown will be tested prior to plant startup. However, it is not the intent of this Part to keep the plant in cold shutdown in order to complete cold shutdown testing.

Accordingly, the relief requested by the licensee is covered by the rulemaking effective September 8,1992, as described above, and relief is no longer required.

5.0 REllEF RE0 VESTS 7 (UNIT li AND 6 (UNIT 2)

The licensee has requested to utilize a velocity standard for monitoring pump vibration rather than the displacement requirements of the 1983 Edition of Section XI, IWP-4500.

5.1 Licensee's Basis for Relief The licensc; stated "The use of a velocity standard, rather than a displacement standard, is more indicative of pump condition and is industry accepted."

5.2 Alternative Testino-The licensee stated " Velocity vibration measurements (in/sec unfiltered peak) shall bc read during each inservice test . Centrifugal pump measurements will be taken in a plane perpendicular to the shaft in two orthogonal directions on all accessible pump bearing housings and in the axial direction on all

,' accessible thrust bearing housings. On vertical pumps, measurements will be taken on the upper motor bearing housing in three orthogonal directions. The frequency response range of the vibration measuring transducers and the readout system shall be from one-third minimum pump shaft rotational speed to at least 1000 Hertz with an accuracy of at least i 5 percent. Allowable ranges of vibration velocity for pump testing shall be as follows:

Acceptable Range 1 2. 5 V, Alert Range: to 6 V

> 2.5 V,in/sec., or

> 0.325 Required Action:

> 6 V[)in/sec.

> 0.7 or Reference OM Code - 1990, Subsection ISTB."

5.3 Evaluation In rulemaking to 10 CFR 50.55a effective September 8, 1992 (57 FR 34666), the 1989 Edition of ASME Section XI was incorporated in (b) of 6 50.55a. The 1989 Edition provides that the rules for inservice testing of pumps are as specified in OM-6, inservice Testing of Pumps in Light-Water Reactor Power Plants. The licensee's proposed alternative testing is in accordance with the vibration monitoring including instrumentation, requirements, of OH-6.

Accordingly, the rel,ef i requested by the licensee is covered by the rulemaking ef fective September 8,1992, as described above, and relief is no longer required.

6.0 Conclusion The staff has determined that the relief requests submitted by the licensee on May 7, 1992 are covered by the rulemaking on September 8, 1992, in which the 1989 Edition of the ASME Section XI was incorporated into 10 CFR 50.55a(b).

Therefore, the relief sought by the licensee is no longer required provided the licensee implements all related requirements of the 1989 Edition of Section XI into the inservice testing program for stroke timing of power-operated valve, scheduling of tests during cold shutdowns, and utilizing velocity for vibration monitoring.

Principal Contributor: Patricia L. Campbell Dated: January 19, 1993

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