ML20203E974
| ML20203E974 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 02/11/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20203E948 | List: |
| References | |
| NUDOCS 9802270170 | |
| Download: ML20203E974 (9) | |
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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20%Hxiot g
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BAFETY EVALUATION BY THE OFFICE OF NUCL_ EAR REACTOR REGULATION BELATED TO THE INSERVICE TESTING PROGRAM. THIRD TEN YEAR INTERVAL BALTIMOR[LGAS AND ELECTRIC COMPANY CALVERT CLIFFS NUCLEAR POWER PLANT. UNIT NOS.1 AND 2 QOCKET NOS 50 317 AND 50 318
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 are performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code (the Code) and applicable addenda, except where attematives have been authorized or relief has been requested by the licensee and granted by the Commission pursuant to Sections (a)(3)(l), (a)(3)(ii), or (f)(6)(1) of 10 CFR 50.55a. In proposing attematives or r6 questing relief, the licensee must demonstrate that: (1) the proposed alternatives provide an acceptable level of quality and safety; (2) compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety, or (3) conformance is impractical for its facility. NRC guidance contained in Generic Letter (GL) 89-04,
- Guidance on Developing Acceptable Inservice Testing Programs," provides alternatives
,o the Code requirements determined acceptable to the staff. Altematives that conform with the guidance in GL 89-04 may be implemented without additional NRC approval. When atteinatives are implemented in accordance with the relevant position in the GL, the staff has determined that relief should be granted pursuant to 10 CFR 50.55a(f)(6)(i) on the grounds that it 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, the staff considers the burden on the licensee that would result if the requirements were imposed.
10 CFR 50.55a authorizes the Commission to approve attematives and to grant relief from ASME Code requ,rements upon making the necessary findings. The NRC staff's findings with respect to authonzing attematives and granting or not granting the relief requested as part of the licensee's IST program are contained in this Safety Evaluation (SE).
The Calvert Cliffs IST Program is based on the requirements in the 1989 Edition of the Code,Section XI, Subsections lWP and IWV, which provide that the rules for IST of pumps and valves will meet the requirements set forth in ASME Operations and Maintenance Standards Part 6 (OM-6)," Inservice Testing of Pumps in Light Water Reactor Power Plants," and Part 10 (OM-10),
" Inservice Testing of Valves in Light Water Reactor Power Plants " The Calvert Cliffs IST program c3 vers the third ten year IST interval. The third ten year interval for Units 1 and 2 begins on January 15,1998, and ends on January 14,2008.
2.0 EVALUATION The NRC staff, with technical assistance from Brookhaven National Laboratory (BNL), has reviewed the information concerning IST program requests for relief submitted for the third 9002270170 980211 7 l DR ADOCK 0S00 Enclosure
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2 te'.yur nntervals for Calvert Cliu Nuclear Power Plant, Units 1 and 2, in Baltimore Gas and ElecW. Company (the licensee) letters dated April 30,1997, and October 1,1997. The staff adopts the evaluations and recommendations for granting relief or authorizing alternatives contained in the Technical Evaluation Report (TER), included as an Attachment to this SE, prepared by BNL. Attachment 1 to this SE lists each relief request ana 'he status of approval.
The test deferrals of valves, as allowed by OM 10, were also reviewed. Results of the review are provided in Section 4.0 of the TER with recommendations for further review by the licensee for specific deferrals.
For the Calvert Cliffs Units 1 and 2 IST Program, relief is granted from, or alternatives are authorized to, the testing requirements which have been determined to be impractical to perform, where an allemative provides an acceptable level of quality and safety, or where compliance would result > a hardship or unusual difficulty without a compensating increase in quality or safety. Two relief requests were denied: (1) Relief Request VR 03 was denied to use attemate test media in the testing of relief valves because the licensee proposed alternate testing was to request generic relief from all valves instead of requesting specific relief for each valve or group of valves; and (2) Relief Request VR-09 was denied because the licensee did not describe any hardship or unusual difficulty in performing the Code testing. Relief Request PR 05 was granted on an interim basis for a period of 1 year to allow the licensee to either procure new vibration instrumentation that meets the Code requirements or revise and resubmit the relief request. If the licensee intends to revise Relief Request PR 05, this should be performed within 6 months of the date of this SE in order to provide the staff time to review the request and retum it to the licensee we,I before the end of the interim period.
BNL, using the Calvert Cliffs Updated Final Safety Analysis Report, conducted a scope review for the following systems against the requirements of Section XI and the regulations: auxiliary feedwater; main steam; reactor vessel head venting; containment spray; and service water. The review revealed three items that did not appear to be in compliance with the Code requirements (see Section 5.0 of the TER). The licensee should review these items, as well as other systems that might contain similar problems, and revise their program as appropriate.
The IST program relief requests which are granted or authorized are acceptable for implementation and the action items identified in Section 6.0 of the TER should be addressed within 1 year of the date of the SE or by the end of the next refueling outage, whichever is later.
Additionally, the granting of relief is based upon the fulfillment of any commitments made by the licensee in its basis for each relief request and the attematives proposed. Program changes involving new or revised relief requests must be submitted to NRC for review. New or revised relief req asts that meet the positions stated in GL 89-04, should be submitted to the NRC but may be implemented provided the guidance in GL 89 04, Section D, is followed. Program changes that add or delete components from the IST program should also be periodically provided to the NRC.
3.0 CONCLUSION
The Calvert Cliffs IST orogram requests for relief from the Code requirements have been reviewed by the staff with the assistance of its contractor, BNL. The TER provides BNL's evaluation of these relief requests. The staff has reviewed the TER and concurs with the evaluations and recommendations for granting relief or authorizing alternatives. A summary of the relief request determinations is also presented. The authorizing of attematives or granting of relief is based upon the fulfillment of any commitments made by the licensee in its basis for each
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l 3-re'"f request and the allematives proposed. The implement 9 tion of IST program and relief requests is subject to inspection by the NRC.
For any relief granted pursuant to GL 89 04 the staff (with technical assistJnce from BNL) has reviewed the information submitted by the licensee to determine whether the proposed alternative follows the relevant posit %n in the GL. Relief requests that conform with GL 89 04 are not evaluated in the TER, though any concems identified by such reviews are discussed in Section 6.0,"lST Program i.ecommended Action items." Relief Requests VR 05, VR 07, VR 10, and VR 11 are approved pursuant to GL 89 04 as they conform to the guidance for Position 2 of Attachment 1.
The licensee should refer to the TER, Section 6.0, for a discussion of recommendations identified during the review. The licensee should address each recommendation in accordance with the guidance therein. The IST program relief requests are acceptable for implementation and the action items identified in Section 6.0 of the TER should be addressed within 1 year of the date of this SE or by the end of the next refueling outage, whichever is later, unless otherwise specified in the TER.
The staff concludes that the relief requests as evaluated and modified by this SE will provide reasonable assurance of the operational readitiess of the pumps and valves to perform their safety related functions. The staff has determined that granting relief pursuant to 10 CFR 50.55a (f)(6)(i) and authorizing altematives pursuant to 10 CFR 50.55a (a)(3)(l) or (a)(3)(ii) is authorized by law and will not endanger life or property, or the common defense and security and is otherwise in the public interest.
Attachments: 1. Relief Request Summary
- 2. Technical Evaluation Report Principal Contributor: Joseph Colaccino Date: February 11, 1998
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Attachment 1-Summary of Pump and Valve Relief Requests Calveit Ckffs Nuclear Pcmer Plant 5
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Equipment Proposed Alternate Method ofTesting NRC Action b !
Relief TER Code Requirement Request No. Section Identification i LPSI Pumps Verify flowrate above a minimum value Alternate approved in PR-01 2.1.1 Part 6,15.1,5.2(c);
quarterly,no evaluation against accordance with Measurement and evaluation of reference values or ae ia'~i corrective 10CFR50.55a(aX3Xi).
flowrate quarterly actions will be mx*- Measurement and evaluation of flowrate willbe made during test performed at cold shutdowns or refueling oatages.
Verify flowrate above a minimum value A;temate aproved in PR-02 ??1 Part 6,15.1,5.2(c); Steam-driven AFW Pumps quarterly,no evaluation against accordance with Measurement and reference values or associated corrective 10CFR50.55a(aX3Xi).
evalusion of flowrate quarterly actions will be made. Meatwement and evaluation of flowrate will be made during test performed at cold shutdowns or refueling outages.
Verify flowrate above a minimum value Altemate approved in PR-03 2.2.2 Part 6,15.1,5.2(c); Motor-driven AFW Pumps quarterly,no evaluation against accordance with Measurement and reference values or avsiatui corrective 10CFR50.55a(aX3Xi).
enluation of f;owTate quarterly actions will be made. Measurement and evaluation of flowrat.: will be made during test performed at cold shutdowns or refueling outages. .
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Attachment 1-Summary of Pump and Valve Relief Requests Calvert Chffs Nuclear Power Plant NRC Action Equipsicat Proposed A!: arete Method ofTesting Relief TER Code Requirement ,
Section Identification Request No. Alternate approvedin HPSI Pur-p Verify flowrate above a minimum value PR-04 2.1.2 Part 6,15.1,5.2(c); accordance with quarterly,no evaluation against Mm-ur cat and 10CFR50.55a(aX3Xi). ,
reference values or associated corrective l evaluation of flowrate quarterly actions will be made. Measurement ana .
evsluation of flowrate willbe made during test performed at cold shutdowns or refueling ondges.
Altorate ppwved for Part 6,14.6.1.6, Charging Use currentinstrumentation with a aninterim period ofone PR-05 23.1 frequency response range from 4 Hz.
Vibration Pumps year naccordancewith instruments' 10CFR50.55a(aX3Xii).
frequency response W l Verify flowrate r.bove a minimum value Altarete wovedin 2.1.3 Part 6,15.1,5.2w; Containnient accordance with PR-06 quarterly, no evaluation against Measuremera and Spray Pumps 10CFR50.55a(aX3Xi).
reference vaiues or associated corrective evaluation of flowratequarterly actions will be madr.. Measurement and evaluation of flowrate will be made during test performed at cold shutdowns or refueling o=dves.
Reqw withdrawn per PR.07 Oct.1,1997 letter from C. Cruse, BGE.
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Attachment 1-Summary of Pump and Valve Relief Requests Calvert Ckffs Nuclear Power Plant NRC Action Equipment Pruposed Alternate Method ofTesting Relief TER Code Requirement ,
l' Identification Reqe No. > Smion Altemate approved in Measure vibration at location specified 2.4.1 Part 6,15.2,4.6.4; Saltwater accordance with PR-08 for centrifugal pumps and use Location for Pumps 10CFR50.55a(aX3Xii).
centrifugal pumps' hydraulic acceptance incasurement of criteria. l vibration on vertical line shaft pumps l and hydraulic x xp".ance criteria Alternate sproved in Part 6,14.o.l.6, Saltwater Use current 'mstrumentation with a PR-09 2.4.2 acconfance with Cooling frequency response range from 4 IIz. )
Vibration 10CFR50.55a(aX3Xii).
instruments' Pumps frequency response range Reliefis not required to Generic Use Figure 1 in Part 6, OMb-1989,that Part 6, Table 3, use erratato the 1989 PR-10 -
was published as errata.
Footnote (2), Edition ofSection XI Foahlishment of (OMa-1988, Part 6).
displacementlimits for pumps with Speeds 2600 rpm,or velocity limits for pmnps <600 syn O
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Attachment 1-Sumtrary of Pump and Valve Relief Requests Calvert CL4fs Nuclear Power Plant Proposed Alternate Method of Testing NRC Action Relief TER Code Requirement Equipment Request No. Section Identification Alternate apgoved in 3.1.1 Part 1,18.1.2.2, All Class 2 Use 1994 Addenda of OM Code.
VR-01 accordance with Test accumulator and 3 SRVs 10CFR50.55a(aX3Xi).
volume requirements No approval required to
- Part 1,18.13.4, All Class 2 Use 1995 Edition ofOM Code.
VR-02 3.1.2 use this Code Thermal and 3 SRVs clarification.
equilibrium Test at ambient temperatures without a Reliefdenied.
VR-03 3.13 Part 1,18.1.1.1, All SRVs 8.1.2 !, and 8.13.1; - correlation.
Use ofattemate media (fluid or temru.ture)
Request w!:hdrawn per ,
l VR-04 Oct.1,1997 letter from C. Cruse, BGE.
Relief Requestin Part 10,1432, SI and CS Sample disassembly and inspection VR-05 -
accordance with Generic ,
Exercise frequency pump suction program.
Letter 89-04, Position 2, from RWT guidance and is check valves, l therefore approved 1(2)-St-4146 pursuant to 10 CFR l
and 4147 50.55a(fX6Xi) t
Attachment 1-Summary of Pump and Valve Relief Requests Calved Cliffs Nuclear Power Plant Equipment Proposed Alternate Method ofTesting NRC Action ,
Relief TER Code Requirement Request No. Section Idatification '
Exercise valves during cold shutdown Approval not required.
VR-06 - Part 10,14.2.1, Si and CS Valves are not required Exercise frequency shutdown conditions.
cooling path to achieve or maintain a manual safe shutdown.
valves,1(2)-
SI-314,319, 324,329, 432,440, 441,444, 452,453, 456, and 457 SIT discharge NIT valves each refueling. Ifcheck Relief Request in VR-07 3.2.1 Part 10,143.2, j check valves, valve maintenance is already planned or accordance with Generic Exercise frequency to limit personnel exposure, valves will Letter 89-04, Position 2, ,
1(2)-SI-215, 225,235,245 be sample disassembled and inspected. guidance and is therefore approved pursuant to 10 CFR 50.55a(f)(6)(i)
NIT valves each refueling. If check Approved in accordance VR-08 3.2.2 Part 10,143.2, SITand St valve maintenance is already planned or with Generic Letter 89-Exercise frequency Pumps to limit personnel exposure, valves will 04, Position 2, with discharge check valves, be srmple disassembled and inspected. provisions.
1(2)-SI-217, 227,237,247 e
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Attachment 1-Summary of Pump and Valve Relief Requests Calvert Cliffs Nuclear Power Plant Equipment Proposed Altemate Method ofTesting NRC Action Relief TER Code Requimment Request No. Section Identification Reliefdenied. l VR-09 3.2.3 Part 10,14.2.2.3(a), SI shutdown Leak test the valves in accordance with Category Avalves, cooling PlVs, Appendix J, Option B.
which perform a 1(2)-SI-651 l
function other than and 652-containment MOV isolation, leak test frequency Sample disassembly and inspection Relief Request in VR-10 - Par
- 10,14.3.2, CS pump discharge to program. accordance with Generic Exercise frequency Letter 89-04, Position 2, spray header check valves, guidance and is therefore approved
!(2)-SI-316, 326,330,340 pursuant to 10 CFR 50.55a (f)(6)(i)
Sample disassembly and inspection Relief Request in VR-11 - Part 10,14.3.2, Containment sump to SI program. accordance with Generic Exercise frequency Letter 89-04, Position 2, and CS pump guidance and is suction check therefore approved valves,1(2)-
pursuant to 10 CFR SI-4148 and 4149 50.55a(f)(6)(i) i.
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