ML20216J586

Safety Evaluation Re Third 10-year IST Program.Approves Valve Relief Requests 1,3 & 4.Valve Relief Request 2 Not Required.Authorizes Pump Relief Requests 1,2,3 & 4

ML20216J586
Person / Time
Site:	Beaver Valley
Issue date:	09/04/1997
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20216J575	List: ML20216J572 ML20216J586
References
NUDOCS 9709170364
Download: ML20216J586 (16)

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UNITED STATES

• : NUCLEAR HEGULATORY COMMISSION -

WASHINGTON, D.C. asse6 eeM l '

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION

[ RELATED TO THE THIRD 10-YEAR INSERVICE TESTING PROGRAM DUQUESNE LIGHT COMPANY BEAVER VALLEY POWER STATION. UNIT N0. 1 DOCKET NUMBER 50-334

1.0 INTRODUCTION

The Code of federal Regulatfons, 10 CFR 50.55a, requires that inservice testing (IST) of certain American Society of Mechanical Engineers Class 1, 2, and 3 pumps and valves be performed in accordanceSection with(ASME)

XI Code of the ASME Sof fer and Pressure Vessel Code (the Code) and applicable addenda, except where alternatives-have been authorized or relief has been requested by the licensee and granted by the Commission pursuant to Sections (a)(3)(1),

~ (a)(3)(ii), or_ (f)(6)(1) of 10 CFR 50.55a. In proposing alternatives or

. requesting 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. Section 50.55a authorizes the Commission to approve alternatives '

and to grant relief from ASME Code requirements upon making the necessary findings. Guidance related to the development and implementation of IST programs is given in Generic Letter (GL) 89-04, " Guidance on Developing Acceptable Inservice Testing Programs," issued April 3, 1989, and its

-Supplement 1~ issued April 4, 1995. Also see NUREG-1482, " Guidelines for Inservice Testing at Nuclear Power Plants," and NUREG/CR-6396, " Examples, Clarifications, and Guidance on Preparing Requests for Relief from Pump and Valve Inservice Testing Requirements."

The 1989 Edition of the ASME Code is the latest edition incorporated by reference in paragraph (b) of Section 50.55a. Subsection IWV of the 1989-

Edition, which gives the requirements for IST of valves, references Part 10 of the American National Standards Institute /ASME Operations and #aintenance Standants (OM-10) as the rules for IST of valves. OM-10 replaces specific requirements in previous editions of Section XI, subsection IWV, of the ASME

- Code. Subsection IWP of the 1989 Edition, which gives the requirements for IST of pumps, references Part 6 of the American National Standards Institute /ASME Operations and #afntenance Standants (OM-6) as the rules for IST of pumps. OM-6 replaces specific-requirements in previous editions of Section XI.- Subsection IWP, of the ASME Code.

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By letter dated April 30, 1997, the Duquesne Light Company (the licensee) submitted eight relief requests, deferred test justifications, and other i sections-of the third 10-year-interval IST program for the Beaver Valley Power ,

-Station Unit No. 1 (BVPS-1). The licensee.also requested to implement the 4

third 10-year interval IST program 15 days earlier on_ September 5,1997, to coincide with the start date of the twelfh refueling outage.

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2.0 EQDE I

The BVPS-1 IST Program was developed to the 1989 Edition of ASME Section XI for the third 10-year interval that would begin on September 20, 1997. In a t

letter dated April 30, 1997, the licensee requested to implement the third 10-year interval IST program on September 5, 1997, to coincide with the start date of the twelfth refueling outage. The earlier, September 5,1997,

! implementation of the third interval IST program is consistent with IWA-

, - 2400(c) of the Code, which allows intervals to be extended or decreased by as much as one year cumulative, and is in compliance with regulatory requirements (also,seeNUREG1482,Section3.3.1). The expiration date would remain as

September 20, 2007.

, The IST program and deferred test justification were developed to comply with the provisions of 10 CFR 50.55a and are based on OM-6 and OM-10.

Additionally, ~ GL 89-04 and its Supplement 1 (NUREG-1482) were followed in the

, program development. The licensee states that pumps and valves included in

the program are ASME Code Class 1, 2, and 3 and are required to perform a i specific function in shutting down a reactor to the cold shutdown condition, in maintaining the cold shutdown condition, or in mitigating the consequences of an accident. However, BVPS-1 is licensed for a safe shutdown condition of hot shutdown; therefore, the IST program scope includes pumps and valves required to achieve and maintain a hot shutdown (see Section 2.2 of NUREG-1482),

j 3.0 PUMP RELIEF REQUEST 1 Relief is requested from OH-6, Paragraph 6, with regard to doubling the frequency of testing for pumps when deviations fall within the alert range for vibration measurements. This relief request pertains to all pumps in the IST program. .

3.1 Licensee's Basis for Reauest

The licensee provided the following basis for the relief request

i The ASME OMc Code-1994, Subsection ISTB, Paragraph 4.6, "New Reference

Values," states in cases where a pump's test parameters are within the-

> alert or required action ranges and the pump's continued use at the changed values-is supported by an analysis, a new set of reference 4 . values may be' established. Paragraph-4.6 goes on [to say that this 1 analysis:shall include verification of the pump's oper)aticaal readiness.

Thc-analysis = shall also include both a pump level and system level b

l evaluation of operational readiness, the cause of the change in pump

performance, and an evaluation of all trends indicated by available-data. The results of this analysis shall be documented in the record of ,

the test.

Spectral analysis may be used to determine the mechanical condition of a pump. The reason for testing a pump on double frequency is to obtain additional information so that the condition of the pump may be i determined. Spectral data can provide infomation to determine if i misalignment, unbalance, resonance, looseness or a bearing problem is 4

present. Through a review of the spectral data over a period of time,

any change in condition of-the pump may also be determined.

3.2 Pronosed Alternate Testina i

4 The licensee proposed the following:

BVPS-1 proposes to implement ASME OMc Code-1994, Subsection ISTB, Paragraph 4.6 for vibration measurements for all the pumps in the-IST Program. Spectral vibration data is currently being obtained for each vibration measurement on all of the pumps. Each time a pump enters the alert range for vibration, an analysis of the spectral vibration data will be performed to determine the cause of the higher vibrations. If l the analysis supports continued operation, the pump will be removed from double frequency testing and a new set of reference [ values) may be obtained. However, to avoid stair-stepping to failure, a new set of

! reference values may only be obtained once prior to performing corrective maintenance. If the cause of the higher vibrations cannot be

! determined, or if the data shows a continuing trend such that the condition of the pump may continue to degrade until it can no longer fulfill its function, the pump will remain on double frequency testing e until the condition 1s corrected.

l 3.3 Evaluation f OH-6, Paragraph 6.1, " Acceptance Criteria," specifies actions required to be taken if any of the measured pump parameters fall within the alert or required action ranges. For the alert range, the test frequency is required to be doubled until the cause of the deviation is determined and the condition is

~ corrected. - Instead of doubling the test frequency, the licensee proposes for

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pump vibration that falls into the alert range to perform an analysis that i demonstrates that the current mechanical or hydraulic performance levels of l- the pump do not impair the pump operability and that the pump would still perfom its safety function. To >rovide reasonable assurance of pump operational readiness, the staff >elieves this analysis should include a comparison of the current vibration spectrum with the baseline vibration spectrum, an evaluation of the trend of available overall vibration amplitudes and spectra, and a determinatien of the need for corrective action.

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( It appears that the licensee has included these elements in its proposed 1

. .alterantive described in Section 3.2, above. Also, OM-6, Paragraph 4.5, allows the licensee to establish new reference values after such an analysis

- is perfonned.

- The 1994 Edition of the ASME OM Code, Subsection IST8 4.6, "New Reference Values,' which is not currently referenced in 10 CFR 50.55a, allows that "[i]n cases where the pump's test parameters are either within the alert or the required action ranges of ISTB 5.2.1.1. Table ISTB 5.2.1-2 Table ISTB 5.2.2-1, or Table ISTB 5.2.3-1, and the pump's continued use at the changed values is supported by an analysis, a new set of reference value may be established." This paragraph also states that the analysis shall include both a pump level and-a system level verification of pump operational readiness, the cause of the change in pump performance, and an evaluation'of -

l all trends indicated by available data. BVPS-1 proposes to implement ASME OMc Code-1994, Subsection ISTB, Paragraph 4.6 for vibration measurements.

The licensee's proposed alternative does not conflict with the NRC's

- interpretation of OM-6, Paragraphs 6 and 4.5. The proposal provides an acceptable level of quality and safety since (1) the licensee's proposed

, analysis provides reasonable assurance of the operational readiness of the pumps and (2) establishing new reference values are allowed by Paragraph _4.5 i

of OM-6 after an analysis is performed. The analysis is subject to NRC ins >ection and must provide reasonable assurance that the degradation

mecianism will not cause further degradation such that, before the next pump

. test or before repairs can be performed, the pump would fail.

3.4 Summary l

F The licensee's proposed alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(1) based on the acceptable level of quality and shfety that will

be provided by the alternative, i

4.0 PUMP RELIEF REQUEST 2 Relief is requested from OM-6, Paragraph 4.6.1.2(a), which states that the

full-scale range of each analog instrument shall be not greater than three times the reference value. This request pertains to discharge pressure for the river water pumps IP-117A to D. The licensee has proposed to follow an alternative specified in NUREG-1482, Section 5.5.1, which states that the staff will grant relief when the combination of the range and accuracy yields a reading at least equivalent to the reading achieved from instruments that meet the Code requirements (i.e., up to i 6 percent).

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' Licensee's Basis for Reauest

-The _ licensee provided the following basis for the relief request:

i- In accordance with 10 CFR 50.55a(a)(3)(1), relief is requested on the

basis that the proposed alternattves would provide an acceptable level of quality and safety. .

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The pumps listed on the attached table [see page 14] use instruments which do not meet the requirements of OM-6, Paragraph 4.6.1.2(a),  !

however, the accuracy of the instruments used is more conservative than the requirements of OM-6, Paragraph 4.6.1.1, " Quality,' and Table 1,

" Acceptable Instrument Accuracy." Per the attached table, the

combination of higher range and better accuracy for each instrument j yields a reading at least equivalent to the reading achieved from ,

instruments that meet OM-6, Paragraph 4.6.1.1 and Table 1 requirements.

Therefore, relief is requested in accordance with NUREG-1482, Section 5.5.1, " Range and Accuracy of Analog Instruments."

4.2 Proonsed Alternate Testina The licensee proposed the following:

i Use the installed instruments listed on the attached table as long as the combination of the higher range and better accuracy for each

! instrument yields a reading at least equivalent to the reading achieved

from instruments-that meet OM-6 requirements.

l 4.3 Evaluation

_ The licensee has proposed to use permanently installed analog pump discharge pressure instruments identified in the referenced table that do not meet the i range requirements of the Code. The instrument accuracy and range requirements of OM-6, Paragraph 4.6, are to ensure that test measurements are

! sufficiently-sensitive to changes in pump condition to allow detection of degradation. OM-6, Paragraph 4.6, states that (1)-accuracy for instruments used in the measurement of pressure shall be i 2 percent and (2) full-scale L range of analog instruments shall be three times the reference value or less.

A range of greater than three times the reference value can be acceptable if 3 the instrument is proportionately more accurate than required. As indicated in Section 5.5.1 of NUREG-1482, an alternative can be approved if the

combination of range and accuracy yields a reading that meets i 6 percent of reference value, i

~ The licensee has proposed to follow the guidelines in NUREG-1482, Section

'5.5.1, which states that the staff will grant relief when the combination of the. range and accuracy yields a reading at least equivalent to the reading

-achieved from instruments that meet the Code requirements. For each of the instruments identified in the table, the combination of range and accuracy

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yields a reading that meets t 6 percent of_ reference value. -The licensee's

- proposed alterative therefore provides an acceptable level of quality and

safety for testing.

4.4 lugary The proposed alternative is authnrized pursuant to 10 CFR 50.55a(a)(3)(1) 4 based on a detemination that ti.o propeal provides an acceptable level of

. quality.and safety.

5.0 PUMP REllEF REQUEST 3 i Relief is requested from the requirement of OM-6, Paragraph 5.2(b), which

- states the resistance of the system shall be varied until the flow rate equals 9 the reference value. The pressure shall then be determined and compared to

its reference value. Alternatively, the flow rate can be varied until the pressure equals the reference value and the flow rate shall be determined and compared to the reference flow rate value.

This relief request pertains to component cooling water pumps ICC-P-1A,.8, and C.

5.1 Licensee's Basis for Reauest The licensee provide. the following basis for the relief request:

The amount of Reactor Plant Component Cooling Water System flow is dependent on the plant's seasonal heat load requirements and on River Water System and seasonal Ohio River water temperatures. The overall amount of flow may vary by several hundred gallons per minute between cold winter months and hot summer months.

Varying Component Cooling header flows by adding or removing-heat loads from service in order to increase or decrease flowrate to a specific reference value is not practical. An exact flowrate cannot be duplicated because flow to some heat exchangers cannot be throttled and those that-can be throttled are not always capable of being throttled due to system heat load requirements. The test is typically performed by either isolating or placing into service non-essential heat exchangers which results in a gross flow change. For this reason, a wider range of flow values, as on a pump curve, is needed as a.

reference.

In addition, to throttle flow to a reference value during hot summer months when flow demand is greatest requires the use of a manual butterfly valve at the discharge of the pumps. A butterfly valve is not designed to be used as a throttle valve so throttling may result in excessive wear and premature failure of the valve. No other valves are available to throttle header flow. Also, operating experience has shown that any throttling of the pump discharge butterfly valves results in a

large reduction in cooling water flow to the Reactor Coolant Pump thermal barrier heat exchangers, bearing lube oil coolers, and motor stator air coolers. Reduced header flows result in low flow alarms and heatup of the Reactor Coolant Pumps to near required manual pump trip setpoints which could ultimately result in a plant trip. Finally, the added thermal cycling of these coolers for pump testing could cause premature degradation of these heat exchangers.

OM-6, Paragraph 4.5, "To Establish an Additional Set of Reference Values," provides for multiple sets of reference values. A pum) ct:rve is merely a graphical representation of the fixed response of tie pump to an infinite number of flow conditions which are based on some finite number of reference values verified by measurement. Relief is, therefore, required to use a pump curve, which should provide an equivalent level of quality and safety in trending pump performance and degradation. Flow will be permitted to vary as system conditions reouire. Delta-P will be calculated and converted to a developed head for which OH-6 ranges will be applied.

5.2 Proposed Alternate Testina The licensee proposed the following:

A pump curve (developed per the guidelines in NUREG-1482, Section 5.2, "Use of Variable Reference Values for Flow Rate and Differential Pressure During Pump Testing") will be used to compare flowrate with developed pump head at the flow conditions dictated by plant seasonal heat load requirements per Reactor Plant Component Cooling Water Pump Tests, 10ST-15.1, 10ST-15.2 and 10ST-15.3 each quarter. Since normal flow varies, the most limiting vibration acceptance criteria will be used over this range of flows based on baseline vibration data obtained at various flow points on the pump curve.

5.3 Evaluation OM-6 requires that pump flow rate and differential pressure be evaluated against reference values to monitor pump condition and to allow detection of l hydraulic degradation. The component cooling water pumps ICC-P-1A, B, and C o)erate under varying flow and differential pressure conditions, depending on tie load requirements. It would not be practical to establish a fixed reference point for testing the component cooling pumps because of system constraints that could result in plant trip and damage to equipment.

l When it is impractical to test a pump at a reference value of flow and differential pressure, testing in the "as-found" condition and comparing values to an established reference curve may be an acceptable alternative.

j Pump curves represent a set of infinite reference points of flow rate and differential pressure. Establishing a reference curve for the pump when it is known to be operating acceptably, and basing the acceptance criteria on this curve, can permit evaluation of pump condition and detection of degradation.

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The licensee proposes to follow the NRC guidelines specified in NUREG-1482, Section 5.2, for the use of pump curve. The proposal in Pum) Relief Request 3 therefore, provides a reasonable alternative to t1e Code requirements.

5.4 Summary Based on the determination that compliance with the Code requirements is impractical, and considering the burden on the licensee if the Code requirements are imposed, relief is granted from the Code requirements pursuant to 10 CFR 50.55a(f)(6)(1).

6.0 PUMP RELIEF RE00EST 4 Relief from the requirements of OH-6, Paragraph 4.6.5, on the measurement of flow using a rate or quantity meter installed in the pump test circuit, is requested for the diesel fuel oil pumps IEE-P-1A, IB, IC, and 10.

6.1 Licensee's Basis for Reauest The licensee provided the following basis for the relief request:

There is no installed instrumentation provided to measure flow rate for these Emergency Diesel Generator Fuel Oil Transfer Pumps. However, a level sight glass does exist on the side of the Diesel Generator Fuel Oil Day Tank, which can be used to measure a change in level over time as the aumps transfer fuel oil from the underground Storage Tank to the Day Tanc. The reading scale for measuring the level change over time, and the calculation method yield an accuracy within i2% as required by OM-6, Paragraph 4.6.1.1, " Quality" and Table 1, " Acceptable Instrument Accuracy."

6.2 Proposed Alternate Testina The licensee proposed the following:

Flow rate will be calculated by measuring the level change over time in the Diesel Generator Fuel Oil Day Tank, and converting this data into Fuel Oil Transfer Pump flow rate at least quarterly per 10ST-36.1 and 10ST-36.2 (Emergency Diesel Generator and Fuel Oil Transfer Pump Tests).

6.3 Evaluation OM-6, Paragraph 4.6.5, " Flow Rate Measurement," states when measuring flow rates, use a rate or a quantity meter installed in the pump test circuit. If a meter does not indicate the flow rate directly, the record shall include the method used to reduce the data.

If the licenace determines that the measurement of tank level over the period of test performance meets the requirements for "a rate or quantity meter installed in the pump test circuit," and the test procedure includes the method used to reduce the data for calculation of flowrate, relief is not required, if these requirements cannot be met, the staff has determined that the use of a tank level to calculate flowrate is an acceptable alternative to the Code, provided the calculated results meet the accuracy requirements of OH-6, ensuring an acceptable level of quality and safety.

6.4 S = ary The proposed alternative to the Code requirements is authorized pursuant to 10 CFR 50.55a(a)(3)(1) based on the alternative providing an acceptable level of quality and safety. If the licensee determines that the alternative meets the requirements of OM-6 Paragraph 4.6.5, this relief request may be deleted, provided the method of reducing the data obtained from the level instrument (s) is included in the test procedure.

7.0 VALVE RELIEF RE0 VEST 1 For check valves 151-1 and -2 in the safety injection system, relief is recuested from OH-10, Paragraph 4.3.2.1, which requires check valves to be innvidually exercised nominally every 3 months, except as provided by Paragraphs 4.3.2.2, 4.3.2.3, 4.3.2.4, and 4.3.2.5. The licensee proposes to follow the sample disassembly and inspection program in accordance with GL 89-04, Position 2. Valve Relief Request 1 is therefore approved per GL 89-04, Position 2.

8.0 VALVE RELIEF RF0 VEST 2 Relief is requested from OH-10, Paragraphs 4.3.2.1 and 4.3.2.4(a), for check valves 1S1-48, 49, 50, 51, 52, and 53 in the safety injection system.

Paragraph 4.3.2.1 requires check valves to be individually exercised nominally every 3 months, except as provided by Paragraphs 4.3.2.2, 4.3.2.3, 4.3.2.4, and 4.3.2.5. Paragraph 4.3.2.4(a) states that the necessary valve obturator movement shall be demonstrated by exercising the valve and observing that the obturator opens to the position required to fulfill its function.

8.1 Licensee's Basis for Reauest The licensee provided the following basis for the relief request:

These check valves are closed during power operation preventing the higher RCS pressure from entering the low pressure accumulators, but are required to open to fulfill their safety function of allowing the accumulators to discharge for core flooding. Due to the high pressure differential between the RCS and the accumulators, full and part-stroke exercising of these check valves is not possible during power operations. Full-stroke exercising of all 6 valves and part-stroke exercising of 4 of the six during cold shutdowns is also impractical due

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j - 10 to lack of installed instrumentation and an uncontrolled test volume change if the MOV isolation valve is opened at low RCS pressure. This s could also delay startup from a cold shutdown while the SI accumulators

- are refilled and-pressurized. The other 2 valves (151-52, 53) are part-stroke exercised in the open direction during RHR system operation during cold shutdowns.

, Relief is requested to fu11' stroke exercise the check valves open during

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refueling outages using a method similar to the test used at the Ft.

Calhoun Nuclear Station. The test method will measure a flow coefficient value (Cv) during a blowdown,at reduced accumulator pressure. The SER for the Ft. Calhoun test method will' be followed and l the recommendations incorporated.

8.2 Pronosed Alternate Testina The licensee proposed the following: ,

Full-stroke exercised open during refueling outages per IBVT 1.11.3, 'SI Accumulator Discharge Check Valves Full Stroke Test." As a special test after maintenance, 10ST-11.15 may be performed to part-stroke open exercise the applicable valves.

8.3 Evaluation -

Full-stroke exercising these valves during power operation is not practicable

-because the RCS is at a higher pressure than the safety injection tank.

4 During cold shutdowns, the RCS lacks adequate expansion volume to accommodate

- the required flow and a low temperature overpressure condition could result.

l These valves could only be full-stroke exercised quarterly or during cold shutdowns if extensive system modifications were performed, such as installing full-flow test loops. Making such modifications would be burdensome to the licensee.

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The licensee proposed to full-stroke open these valves during refueling outages and partial-stroke'open valves ISI-52 and-53 during cold shutdowns as part of the RHR system operation. The alternative testing frequencies are consistent with the requirements of OM-10, Paragraph 4.3.2.2, which allows j deferral of stroke testing to every refueling outage if testing quarterly or

during cold shutdowns is not practicable.

The licensee's method of exercising these valves open, by measuring a flow coefficient. valun {Cv)' curinta blowdown at reduced accumulator pressure, had proviously ban tppmysd- for ft. Calhoun with the-provision that the recommendatinnt.specified in the ORNL report, .0RNL/NRC/LTR-93-16, be followed.

This method of earcising those valves is consistent with the OM-10,

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. -Paragraph 4.3 P.. 2 regulroments; relief is, therefore, not required. The

, licensee states that the Ft. Calhoun test method will be followed for-BVPS-1 and the recommendation incorporated.

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Based on the determination that the alternative testing is consistent with

!- ~ OM-10, Paragraph 4.3.2.2 requirements, no relief is required. The  :

implementation of IST program commitments is subject to NRC inspection.

g0 VALVE RELIEF REQUEST 3 t For check valves IRS-158 and 160 in the containment spray system, relief is

!- requested from OM-10, Paragraph 4.3.2.1, which requires check valves to be 4 individually exercised nominally every 3 months, except as provided by

[ Paragraphs 4.3.2.2, 4.3.2.3, 4.3.2.4, and 4.3.2.5. The licensee proposes to ,

follow the sample disassembly and inspection program in accordance with ,

- GL 89-04, Position 2. Valve Relief Request 3 is therefore approved per

GL 89-04, Position 2.

i 10.0 . VALVE RELIEF REQUEST 4 i

Relief is requested from OM-10. Paragraph 4.2.1.4(b), which states that the stroke time of all power-operated valves shall be measured to at least the nearest second. This request pertains to diesel generator air start solenoid

operated valves SOV-LEE-101,102,103, and 104. The licensee proposes to

! verify the operational readiness of these solenoid valves on an alternating basis during the monthly EDG testing, i

10.1 Licensee's Basis for Reauest t

-The licensee provided the following basis for the relief request:

1 These valves are quick acting and do not have position indication. The operation of these valves will be monitored by each' individual diesel generator's start failure alarm circuit. Malfunctions which will cause

the annunciator panel START FAILURE light to come on and the alarm bell ,

to ring are:

1. Engine fails to crank above 40 RPM within 3 seconds after a start signal is received or 4 2. Engine cranks above 40 RPM within 3 seconds, but fails to exceed j 2000 RPM within 4 seconds after a start signal is received.

Individual valves will- be tested monthly on an alternating frequency by

=using a different set of air starting motors each month to crank the r engine. This will ensure each bank is casable of starting the diesel

-generator in the required-time and that tie air start SOVs are not i

degrading. Per NUREG-1482,'Section 3.4, " Skid-Mounted Components and Component Subassemblies," "The staff has determined that the testing of i the major component is an acceptable means.for verifying the o>erational readiness of the skid-mounted and com>onent subassemblies if tie licensee documents this approach in tie IST Program."

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. i 10.2 Proonsed Alternate Testina The licensee proposed the following;

[These valves willibe) stroked and indirectly timed by the START FAILURE

. annunciator on an alternating frequency in conjunction with 10ST-36.1

and 2, "The Diesel Generator Monthly Test."

l 10.3 Evaluation The Code requires that the diesel air start solenoid valves be stroke timed j every 3 months. These valves have a safety function to open in conjunction

, - with the operation of their associated diesel generators. 'The air start

solenoid valves are small, rapid acting valves that are completely enclosed.

They operate from an engine start control signal rather than a control switch and do not have remote position indication or any external mecns to determine ,

valve position. Therefore, it is impractical to stroke time test these valves 4

as required by the Code. Failure or significant degradation of these valves would be evidenced ~by failure to meet the start time limit.specified in the l

technical specific 6tiont It would be an undue borden for the licensee to meet the Code requirements because components associated with EDG would have to be either modified or

, replaced. The licensee proposes to verify quarterly the operational readiness of these valves by observing a pressure drop in the associated starting air reservoir during diesel testing and by confirmation of proper diesel start

- times. This proposed alternative is consistent with the NRC guidelines in Section 3.4 of NUREG-1482 and provides a reasonable alternative to the Code requirements.

T 10.4 Summary Based on the determination that compliance with the Code requirements is impractical and the licensee's proposal provides a reasonable alternative to the Code requirements, relief as requested is granted pursuant to

10CFR150.55a(f)(6)(1).

' 11,0 CONCLUSION

, Valve Relief Requests 1 and 3 are approved per GL 89-04, Position 2. Valve Relief-Request 2 is not required. Valve Relief Request 4 is granted pursuant to 10 CFR 50.55a(f)(6)(1). The proposed alternatives in Pump Relief Requests 1, 2, and 4 are authorized pursuant to 10 CFR 50.55a(a)(3)(1). Pump Relief Request 3 is granted from the Code requirements pursuant to 10 CFR 50.55a(f)(6)(1). The staff has determined that approval of relief requests peruant to 10 CFR 50.55a(a)(3)(1) or (f)(6)(1) is authorized by law and will

not endanger life or property, or tha common defense and security and is otherwise in the public interest.

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The 15 days earlier than required (on September 5,1997) implementation of the third interval IST program is consd stent with IWA;2400(c) of the Code, which allows intervals to be extended or decreased by as much as one year cumulative, and is in compliance with regulatory requirements (see NUREG 1482, Section3.3.1).

Principal Contributor: K. Dempsey Date: September 4, 1997 J

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PUMP RELIEF REQUEST 2 IST PUMP INSTRUMENTATION Pump.ID# Instrument Condition Requiring Basis for Relief / Alternate Test IDS- Relief 1RH-P-1A PI-1RH-600 The range of the gauges These gauges are the discharge pressure gauges for the RHR 1RH-P-1B PI-1RH-601 is greater than thrw pumps. They are sized for all modes of pump operation with a-times the reference range of 0-700 psig. The RHR pumps take suction on the RCS.

pressure at some and the discharge pressure is dependent on the RCS pressure, operating conditions. varying between 96-485 psig (ty)1cally 420 psig). The calibration accuracy is 0.5%. witch would yield a reading more accurate than Code requirements for any operating pressure.

ISI-P-1A PI-ISI-943 The range of the gauges These gauges are the discharge pressure gauges.for the LHSI ISI-P-1B PI-1SI-944 is greater than three pumps. They are sized for all modes of pump operation with a times the reference range of 0-400 psig. They meet the criteria for the quarterly pressure at full flow test: however, at higher flow rates the pressure is ap)rox.

conditions. 25% of the range. The calibration accuracy is 0.5%. w11th' would yield a reading mo'er accurate than Code requirements.

ICC-P-1A PI-1CC-100A The range of the gauges These gauges are the discharge pressure gauges for the CCR ICC-P-1B PI-ICC-1008 is slightly greater than pumps. The range of the gauges is 0-400 psig. The use of a ICC-P-IC PI-1CC-100C three times the pump curve is allowed for these pumos per PRR3. and the reference pressure. typical pressure readings are slightly lower than 1/3 the range. varying between 110-132 psig. The calibration accuracy is 1.0%. which would yield a reading more accurate than Code requirements.

PUMP RELIEF REQUEST 2 IST PUMP INSTRUENTATION Pump IDI Instrument Condition Requiring Basis for Relief / Alternate Test IDI Relief ICC-P-1A FI-1CC-117 The range of the gauges These flow indicators are in the branch lines of the component ICC-P-1B F1-1CC-118 is greater than three cooling water system. They are only used if the installed ICC-P-1C FI-1CC-119 times the reference PDIs are over-ranged. In that case. the typical flow expected flow. would be enough to meet Code ren arements. except'for

[FI-1CC-117]. which could be placed in service with a flow of .  ;

4000 gpm. [FI-1CC-117] is sized for all flow conditions with a range of 0-14.000 gpm and an accuracy of 1.5%. It is in the 24" CCR header supplying the cooling loads inside the containment. When the RHR system is in operation. the flow through this line is significantly higher. The calibration accuracy of this gauge would yield a reading more accurate than Code requirements.

PDI-1CC-119 The range of the flow This flow indicator in the CCR header supplying the cooling meter is greater than loads in the Auxiliary Building. has a range of 0-150 inches three times the of water column. Since the use of a pump curve is appraved reference flow for per relief, the reference flow may not be at a specific flow normal operations. point. Ty)ical test flow dP is approx.19 inches of water column. T1e accuracy of the gauge is 0.5%. which would yield a reading more accurate than Code requirements.

IFW-P-2 FI-1FW-100A The range of the gauges These flow indicators are in the three lines to the S/Gs from 1FW-P-3A F1-1FW-100B is greater than three the AFW Pumps. The flow indicators are sized to reasure 1FW-P-38 FI-1FW-100C times the reference flow accident flow from the Turbine-Driven AFW Punp as well as the for the Motor-Driven AFW Motor-Driven Pumps with a range of 0-400 gpm. The reference Pumps. value for the full-flow test is approx.110 gpm. 27.5% of the range. The calibration accuracy of the flow meters is 1.0%.

which would yield a reading more accurate than Code requirements.

Pt M RELIEF REQUEST 2 IST PUMP INSTRUENTATION Pump IDF Instrument Condition Requiring Basis for Relief / Alternate Test IDI Relief 1FW-P-2 PI-1FW-156 The range of the gauges These gauges are the suction pressure gauges for the Auxiliary IFW-P-3A PI-1FW-156A is greater than three Feedwater Pumps. In 1991. DCP 1557 changed the existing 1FW-P-38 PI-1FW-156B times the reference 0-160 psig gauges to the present 0-60 asig gauges. This range pressure. was selected as a conpromise between t~.e IST Program requirements and yassible accident pressures (i.e . River Water supplying tie AFW Punps). The 0-60 psig range will acccmodate the accident pressure and typical test pressure of 10 psig. With a calibration accuracy of 0.5%. this results in a reading more accurate than Code requirements.

IEE-P-1A PI-1EE-101A The range of the gauges These gauges are the discharge pressure gauges for the D/G 1EE-P-1B PI-1EE-102A is greater than three Fuel Oil Transfer Pumps. The reference value is approx.

1EE-P-1C times the reference 9 psig. slightly below 1/3 of the range of the gauges IEE-P-10 pressure. (0-30 psig). Their calibration accuracy is 0.5%. which would yield a reading more accurate than Code requirements.

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