ML20138L796

SER Related to Inservice Testing Program Relief Request Detroit Edison Co,Fermi Unit 2

ML20138L796
Person / Time
Site:	Fermi
Issue date:	02/19/1997
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20138L791	List: ML20138L788 ML20138L796
References
GL-89-04, GL-89-4, NUDOCS 9702250082
Download: ML20138L796 (7)

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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 30886-e001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO INSERVICE TESTING PROGRAM RELIEF REQUESTS DETROIT EDISON COMPANY

! FERMI UNIT 2 1

DOCKET NO. 50-341

1.0 INTRODUCTION

The Code of Federal Regulations,10 CFR 50.55a, 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 requested and granted or proposed alternatives have been authorized by the Commission pursuant to 10 CFR 50.55a(f)(6)(1),.(a)(3)(i), or (a)(3)(ii). 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 10 CFR 50.55a(b), subject to the limitations and modifications listed, and subject to Commission 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 follows 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.

Section 50.55a authorizes the Commission 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).

The first ten-year interval for Fermi Unit 2 began January 23, 1988, and ends January 22,_1998. The current IST program is based on the requirements of the 1980 Edition through the winter 1980 addenda of the ASME Code.

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! During an IST inspection conducted at Fermi on January 23-27, 1995, the .

l inspectors identified a number of relief requests which had not been l previously reviewed by the NRC. The relief requests had been provided to the l staff in a letter submitted by the licensee dated September 20, 1985. The i relief requests in the letter include PR-6, PR-7, PR-8, VR-45, VR-46, VR-47, ,

VR-48, VR-49,.VR-50 and VR-51. The inspectors informed the licensee that the  !

staff planned to evaluate the relief requests using the licensee's IST program '

submittal dated December 24, 1994. This information is documented in Fermi Safety Issues Inspection Report Number 50-341/95002(DRS) dated February 10, 1995.

l t 4 Subsequent to the inspection, the licensee revised Relief Requests PR-6, PR-7  !

and PR-8 in a letter dated July 14, 1995. In addition, the licensee submitted .

Revision 3, Change 9 of its IST program in a letter date:1 hly 19, 1995, which !

included the following changes to the.unreviewed relief requests: (1) VR-46, l VR-47 and VR-49 had been revised; (2) VR-45 and VR-48 were revised to meet the provisions of GL 89-04, and (3) VR-50 was deleted from the licensee's IST program. Evaluations of relief requests PR-6-R1, PR-8-R1, 'VR-46-RS, VR-47-R2, '

VR-49-R3 and VR-51 were included in Sections 3 and 4 of the NRC safety evaluation (SE) dated May 2, 1996.

Inspection followup item (IFI) 341/95002-01(DRS) was generated to address the  ;

licensee's use of pump reference curves for code compliance on all Fermi safety-related pumps without relief being either requested or approved. The '

licensee responded to this IFI in a letter dated April 7, 1995, committing to submit relief requests for the residual heat removal (RHR), high pressure ,

coolant injection (HPCI),. emergency equipment cooling water (EECW), diesel '

generator service water and the control center heating, ventilating and air conditioning (CCHVAC) chill water pumps. In addition, the licensee committed ,

, to submit revised relief requuts for the core spray and RHR service water i pumps for review and ap)roval by July 14, 1995. New Relief Request PR-Il l which was included in t1e July 14, 1995, submittal proposed using pump  :

reference curves for the EECW pumps. An evaluation of Relief Request PR-Il is included in Section 3.4.3 of the May 2, 1996, safety evaluation.  :

The July 14, 1995, submittal from the licensee-requested interim relief to  :

continue to test all safety-related pumps using reference curves with the l Exception of the standby liquid control pumps (which already use fixed reference values) and the core spray, RHR service water and EECW pumps until  ;

l refueling outage 5. No formal relief request was included in the licensee's l submittal. The staff conducted a conference call with the licensee on l August 10, 1995, and the licensee committed to establ' h fixed reference i values for these safety-related pumps at Fermi during their regular IST l schedule. This is documented in a' letter from the licensee dated August 31, '

1995. The establishment of fixed reference values would obviate the interim relief request. The licensee indicaed that fixed reference values for pumps l in the Fermi IST program had been incorporated, with the exception of the i standby liquid control, core spray, EECW and RHR service water pumps, in a l

phone conversation with the licensee on March 13, 1996. I i

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j On May 2,1996, the staff issued an SE evaluating relief requests PR-6-R1,

' PR-8-RI, PR-11, VR-46-R5, VR-47-R2, VR-49-R3, and VR-51. On November 1, 1996,

' the licensee submitted Revision 3, Change 11 to its IST program to the NRC to confirm actions taken by Detroit Edison in response to the May 2, 1996, safety evaluation.

3.0 ACTION ITEMS 5.1 THROUGH 5.7 FROM THE MAY 2. 1996. SAFETY EVALUATION 3.1 Action Item 5.1. Relief Reauest PR-6-RI. Core Sorav System Pumos 3.1.1 Action Item From Safety Evaluation 1

In Relief Request PR-6-RI, provisional relief is granted to perform parallel pump testing of each core spray pump train and to use reference 2 curves to assess the performare of each parallel pump combination. The licensee must incorporate the following provisions in its IST program or the applicable test procedures.

! 1) If the hydraulic performance of one train enters the alert or required action range, then both pump in that train must either be individually verified to hue acceptable performance (through testing or inspection) or repaired i

prior to the train being returned to service.

2) All elements listed in NUREG-1482, Section 5.2, concerning development of pump reference curves must be addressed and documented in the licensee's IST program.

3) The licensee is not allowed to use the provisions of Paragraphs IWP-3112 and IWP-3230(c) that permit an analysis to be performed when the hydraulic performance of a pump train enters the alert or required action range and establish additional reference values.

4) This relief request must be revised to include the reference curves for each train of core spray that are currently included in the applicable surveillance procedures (such as Table 1 in Fermi Suiveillance Procedure 24.203.03, Revision 25, Page 10, core spray loop B, reference test date 12-20-84). The relief request need not be resubmitted for approval if it is revised only to include a new reference curve; however, the new reference curve should be retained in facility files for inspection.

5) New reference curves for each core spray train can be established only after both pumps in the train have been verified individually to be in good operating condition.

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3.1.2 Evaluation of Revision 3. Chanae 11 l

4 The licensee has revised the relief request to include reference curves for each train of core spray (in tabular form) and to document how the

elrnents of WREG-1482, Section 5.2, have been addressed. In addition, L the limitations described in actions 1), 3), and 5) have been i i incorporated into the relief request. These changes satisfy the actions requested by the staff. ,

! 3.2 Action Item 5.2. Relief Raouest PR-8-RI. Residual Heat R-val System

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, 3.2.1 Action Item From Safety Evaluation i

l In Relief Request PR-8-R1 the licensee appears to identify the four RHR pumps at Fermi as vertical line. shaft pumps. RHR pumps at boiling water -

reactors are typically vertical centrifugal pumps. The two types of i pumps are classified differently in OM-6 with more stringent acceptance criteria assigned to the vertical line shaft pumps. The licensee should resolve this discrepancy within its IST program and current and future program submittals as appropriate.

! 3.2.2 Evaluation of Revision 3. Chanae 11 l Yhe licensee has revised the relief request to clearly indicate that the i

residual heat removal system pumps are vertical centrifugal pumps. This change satisfies the action requested by the staff.

I 3.3 Action Item 5.3. Relief Reauest PR-8-RI. Residual Heat Removal System IMEI i

3.3.1 Action Item From Safety Evaluation The licensee should apply all vibration requirements of OM-6 to vibration j testing of the RHR pumps.

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3.3.2 Evaluation of Revision 3. Chanae 11 1

i The licensee has revised the relief request to clearly indicate that the f OM-6 requirements for vibration testing (ISTB 4.6.1, 4.6.4, 5.2, and 6.1) will be applied to the residual heat removal system pumps. This change satisfies the action requested by the staff.

3.4 Action Item 5.4. Relief Reauest PR-11. Emeraency Eouionent Coolina Water System Pumps 3.4.1 Action Item From Safety Evaluation Relief Request PR-11 is granted for the EECW pumps with the provision that the elements listed in W REG-1482, Section 5.2, are addressed and documented in the licensee's IST program.

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l3 b i n 3.4.2 Evaluation of Revision 3. Chance 11 s

Tne licensee has revise:I the relief request to document how the elements of NUREG-1482, Section 5.2, have been addressed. These changes satisfy the actions requested by the staff.

3.5 Action Item 5.5. Relief Reauests VR-46-R5 and VR-47-R2. Leak Rate Testina  !

of Containment Isolation Valves j 3.5.1 Action Item From Safety Evaluation  !

Approval was given in Relief Requests VR-46-R5 and VR-47-R2 to use later editions of the OM-10 Code to test grou>s of containment isolation valves  !

associated with specific penetrations w)ere it is impractical to individually leak test each valve in the group and assign permissible leakage rates for each valve group provided that the licensee meets all related requirements of Sections 4.2.2.1 and 4.2.2.3. Implementation of these requirements is subject to NRC inspection.

l 3.5.2 Evaluation of Revision 3. Chanae 11 j The licensee has revised relief request VR-46 to clearly indicate that the related requirements in OM-10 (specifically Sections 4.2.2.1 and 4.2.2.3) shall be applied for the testing of the containment penetrations associated with the relief request. Relief request VR-47 has been deleted. These changes satisfy the actions requested by the staff. .

i 3.6 Action item 5.6.. Relief Reauest VR-51. Qiesel Generator Air Start System Valves  !

i 3.6.1 Action Item From Safety Evaluation i Interim relief is granted for Relief Request VR-51 for a period of 1 year to provide the. licensee ample time to develop acceptance criteria which l

verify that the diesel air-start solenoid valves stroke during the '

monthly diesel test to satisfy the Code quarterly test frequency requirements.

3.6.2 Evaluation of Revision 3. Chanae 11 The licensee has revised the relief request to document the interim relief and the consiitment to propose and implement additional alternate testing within one year of the May 2, 1996, NRC Safety Evaluation. These changes satisfy the interim actions requested by the staff.

3.7 Action Item 5.7. Relief Reauest VR-45-RI. Core Sorav System Valves 3.7.1 &c. tion Item From Safety Evaluation In the licensee's IST program submittal of July 19, 1995, the licensee states in Relief Request VR-45-R1 that these check valves cannot be partial-stroke exercised because the core spray pumps in each division

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are tested in parallel. Credit for a full-stroke test of a check valve requires that the flow through the check valve be known. Knowledge of

- only.the total flow through multiple parallel lines is not a full-stroke o

test. However, since both pumps are running during the quarterly test, and.if the division meets its tydraulic performance criteria, then the

! quarterly core spray test is a partial-stroke test of the core spray pump j discharge check valves. The licensee should remove this reference from

! its IST program. In addition, the licensee should partial-stroke test i the core spray dischar guidance in GL 89-04, Position ge pump2.check valves after reassembly to meet the

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3.7.2 Evaluation of Revision 3. Chance 11 In the November 1,1996, cover letter submitting Revision 3, Change 11, i to the IST program, the licensee explained that the NRC evaluation had

! erroneously referred tc the core spray pump discharge check valves while l' Relief Request VR-45 refers to the check valves in the core spray pump minimum f?ow lines. This issue was also discussed in a phone call between the licensee and the NRC staff on September 12, 1996.

The licensee states:

As described in Relief Request PR-6, both core spray pumps in each

' division must be operating during surveillance testing. Therefore, detection of flow through the minimum flow line will only show that one out of two valves is open. Also, the ability to verify that the check valves close upon reversal of flow is lost during two-pump testing.

The licensee proposes:

In lieu of the Code-required exercise test, one valve of each type will be demonstrated operable by disassembling the valve and verifying that the valve disk swings freely from and to the seat each refueling outage. All of the above valves are 3-inch, swing check type valves manufactured by Powell Since Core Spray Pumps are tested together in each Division, a partial stroke test is not possible and will not be specified for these valves. This complies with Position 2 of GL 89-04. Valve disassembly and inspection will occur at every refueling outage.

NRC evaluation:

The Code require's that the core spray pump minimum flow line check valves be stroke tested every three months. These valves have safety functions in both the open and close directions. The configuration of the system is such that it is not practical to stroke test the valves with flow. It would be an undue burden for the licensee to meet the Code requirements because these components would have to;be either modified or replaced.

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l The licensee has proposed to demonstrate valve operability by disassembling one valve and verifying free disk movement from and to the seat each refueling outage. Generic Letter 89-04, Position 2, allows relief for licensees to disassemble and inspect check valves  ;

for which it is impractical to test with flow. Up to four like  !

valves may be grouped based on size, model, manufacturer, and i service conditions. Based on appropriate justification, the l licensee may disassemble one valve out of the group during each refueling outage. The configuration at Fermi justifies the use of the guidance in Position 2.

3.7.3 Conclusion j The licensee's proposal to demonstrate valve operability by disassembling and inspecting the core spray pump minimum flow check valves is in accordance with the auidance of GL 89-04, Position 2.

Therefore, relief is not required.  !

4.0 CONCLUSION

The staff concludes that the relief requests as evaluated and modified by

. this safety evaluation will not compromise the reasonable assurance of operational readiness of the pumps and valves in question to perform their safety-related functions. Licensee incorporation of Action Items l from the May 2,1996, NRC safety evaluation was reviewed for relief requests PR-6-R1, PR-8-R1, PR-11, VR-46-R5, VR-47-R2, and VR-51. Relief i Request VR-45-R1 was in accordance with the guidance of GL 89-04,  ;

Position 2. Therefore, relief is not required. i Principal Contributors: Andrew Kugler i' Joseph Colaccino Dated: February 19, 1997 l

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