ML20207E863

Safety Evaluation Accepting Licensee 990114 Submittal of one-time Request for Relief from ASME B&PV Code IST Requirements for Pressure Safety Valves at Plant,Unit 3

ML20207E863
Person / Time
Site:	Waterford
Issue date:	06/03/1999
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20207E858	List: ML20207E854 ML20207E863
References
NUDOCS 9906070188
Download: ML20207E863 (3)

Text

-,. ..

p pa**2uq\ UNITED STATES g NUCLEAR REGULATORY COMMISSION g WASHINGTON, D.C. 20se6 0001 k*****

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AN INSERVICE TESTING REQUEST FOR RELIEF ENTERGY OPERATIONS. INC.

WATERFORD STEAM ELECTRIC STATION UNIT 3 DOCKET NO. 50-382

1.0 INTRODUCTION

Title 10 of the Code of Federal Reaulations (10 CFR), Section 50.55a, requires that inservice testing (IST) of certain American Society of mechanical Engineers (ASME) Code Class 1,2, and 3 pumps and valves be performed in accordance with Section XI of the ASME Boller and Pressure. Vessel Code (Code, or the Code) and applicable addenda, except where relief has been requested and granted or proposed attematives have been authorized by the Commission pursuant to 10 CFR 50.55a (f)(6)(i), (a)(3)(i), or (a)(3)(ii). In order to obtain authorization or relief, the applicant 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. .

2.0 BACKGROUND

By letter dated January 14,1999, Entergy Operations, Inc. (the licensee), submitted a one-time request for relief from certain ASME Code IST requirements pertaining to the frequency of testing of the pressurizer safety valves (PSVs) at Waterford Steam Electric Station, Unit 3

. (Waterford 3). The Waterford 3 IST program requires that the testing meet the requirements of the Operations and Maintenance Code-1987, Part 1 (herein referred to as Part 1). Specifically, this request seeks a one-time relief from performing the next periodic tests before the date that would be required by Part 1. The following is a list of the PSVs for which the licensee is seeking this one-time relief:

VALVEID DESCRIPTION RC MVAAA317 A Pressurizer Safety Valve RC MVAAA317 B Pressurizer Safety Valve For the referenced valves, the licensee is requesting a one-time relief from the following testing requirements for Class 1 pressure relief valves:

Part 1, paragraph 1.3.3 All valves of each type and manufacture shall be tested within each subsequent 5-year period with a minimum of 20 percent of the valves tested within any 24 months.

Enclosure 9906070180 990603 DR ADOCK O g2

i

. - +

l 2

- Both of the Waterford 3 PSVs were tested on September 21,1998. Therefore, the preceding Part 1 paragraph would require testing of at least one PSV prior to September 21,2000.

3.0 PROPOSED ALTERNATIVE TESTING As an attemative to the above required testing, the licensee proposes to test or replace the '

PSVs in accordance with Part 1 during Refueling Outage 10, currently scheduled to begin September 29,2000, with the following exceptions.

1. If a Mode 5 outage of sufficient duration occurs anytime during Cycle 10 and the start of

- Refueling Outage 10 is (or has previously been) delayed by 6 months or more beyond September 21,2000 (the current testing due date), valve testing and/or replacement will be

' performed.

2. If Refueling Outage 10 occurs after September 21,2000, valve testing and/or replacement

~

will be performed during the first Mode 5 outage of sufficient duration occurring after -

September 21,2000. In any event, valve testing and/or replacement will occur prior to .,

March 21,2001,  !

4.0 BASIS FOR RELIEF The licensee replaced the two PSVs at Waterford 3 during an outage on September 21,1998, I due to leakage from one of the PSVs. This occurred approximately 5 months prior to the scheduled beginning of Refueling Outage 9 in February 1999. The licensee stated that Refueling Outage 10 is officially scheduled to begin on September 15,2000, but that, due to

. mid-cycle outages during Cycle 9, it is likely that the start of Refueling Outage 10 will be revised l to September 29,2000. . As a result of this expected revision to the outage schedule, the )

24-month maximum period required by Part 1 between tests of the PSVs would expire prior to 1 the beginning of Refueling Outage 10. The licensee stated that the proposed addition of a maximum of 6 months beyond the Code-required 24-month period could be necessary to accommodate mid-cycle forced outages that may cause the beginning of Refueling Outage 10  ;

to be further delayed. j

, As justification for the proposed relief, the licensee reviewed test results for the past three tests

' of the two currently installed PSVs and determined that in three of the six cases, the PSVs met _

the Technical Specification setpoint acceptance criteria. The licensee also stated that the three failures to meet this criteria were determined to be the result of maintenance or test practices, not due to significant setpoint drift.

The licensee also stated that if the PSVs were required to be tested during Refueling Outage 9, it would result in significant additional cost and personnel exposure.

5.0 ~ EVALUATION The staff finds that performing PSV testing to meet the schedular requirements of Part 1 would result in unusual hardship without a compensating increase in quality and safety. The staff reviewed the test data referenced by the licensee, as documented in submitted Licensee Event Reports. Based on this review of the licensee's operating experience with the Waterford 3 l

valves and general industry experience with similar valves, significant additional degradation of

3 these components would not be expected during the proposed additional 6-month period.

Therefore, the staff finds that it is acceptable to perform the testing of the installed PSVs at Waterford 3, with a maximum extension of 6 months to the 24-month testing period required by ,

Part 1, as proposed by the licensee. That is, the staff finds it acceptable to pedorm the testing no later than March 21,2001. Further, the staff finds that the provisions outlined by the licensee's proposed altamative testing in the exceptions numbered 1 and 2 herein, are reasonable regarding the use of an opportunity that may be afforded during a Mode 5 outage to perform the PSV testing. However, the stated provisions of exception number 1 do not place an appropriate upper limit on the maximum period of time prior to testing, since it refers to a postulated delay of Refueling Outage 10 by 6 months or more. Based on the review of the information provided by the licensee, the staff does not find that it is acceptable to delay the PSV testing beyond March 21,2001; therefore, if the licensee desires to extend the testing beyond March 21,2001, additional relief from the Part 1 requirements, with appropriate justification, would be necessary. 4

6.0 CONCLUSION

On the basis of its evaluation, the staff has determined that the licensee's request for a

, one-time relief from the ASME Code testing requirements for the pressurizer safety valves at Waterford 3 is authorized pursuant to10 CFR 50.55a(a)(3)(ii). Compliance with these requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

PrincipalContributor: G. Hammer Date: June 3, 1999 i

l i

i l