ML20005F076

Forwards Revised Inservice Test Program in Response to Generic Ltr 89-04.List of Inservice Test Program Relief Requests Previously Submitted & Acceptable,Per Generic Ltr 89-04,encl

ML20005F076
Person / Time
Site:	Pilgrim
Issue date:	01/04/1990
From:	Bird R BOSTON EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20005F077	List: ML20005F076 ML20005F079
References
BECO-90-001, BECO-90-1, GL-89-04, GL-89-4, NUDOCS 9001120261
Download: ML20005F076 (9)

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l ' ~ Pilgrim Nuclear Power Station Rocky Hill Road Plymouth, Massachusetts 02360 Ralph G. Bird BECo 90-001 senior Vice President - Nuclear January 4 1990 U.S; Nuclear Regulatory Commission Document Control Desk-Hashington, DC 20555

' License DPR-35 Docket 50-293 RESPONSE TO GENERIC LETTER 89-04 GUIDANCE ON DEVELOPING ACCEPTABLE INSERVICE TESTING PROGRAMS This letter transmits our revised Inservice Test Program (PNPS Procedure 8.I.1.1) and contains our statement of conformance with the positions stated in Generic Letter 89-04.

Boston Edison confirms the enclosed Pilgrim Nuclear Power Station Inservice Test Program, including the relief requests identified in Attachments 1 and 2, conform with the positions stated within Generic Letter 89-04. Accordingly, BECo understands that the relief requests identified in Attachments 1 and 2 are approved by the Generic Letter.

-The relief requests identified in Attachment 3 are submitted for NRC review and approval under the provisions of 10CFR50.55a(g)(5). These relief requests _

address issues not specified within the scope of Generic Letter 89-04. He request NRC review and approval prior to May 30, 1990 to allow us adequate time to develop the Pilgrim test procedures and perform the associated tests prior to the end-of Refueling Outage #8.

Th'e enclosed Inservice-Test Program updates our existing program to meet the recommendations in the Generic Letter while maintaining compliance with 10CFR50.55a(g) and the ASME B&PV Code, Section XI (1980 Edition through Hinter 1980 Addenda).

Our present schedule for preparing the associated test procedures was contained in.BECO Letter 89.158, dated October 27, 1989. This schedule will be included in our next Long Term Program (LTP) submittal and updated as necessary via the LTP process (LTP item #460). Testing will be performed within the test interval following station approval of the associated procedure.

RAH /amm/3924 Attachments cc: See Next Page 9001120261 900104 (Ah PDR ADOCK 05000293 ii P PNU m

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't  : BOSTON EDISON COMPANY

-January 4, 1990 i

.'U. S. Nuclear Regulatory Commission- '

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-Page Two ,

cc: Mr. D.' Mcdonald, Project Manager Division of Reactor. Projects - I/II 0ffice of Nuclear Reactor Regulation Mail Stop: 14D1 U. S. Nuclear Regulatory Commission 1:Hhite Flint North 11555 Rockville Pike Rockville, MD 02852

c. U. S. Nuclear Regulatory Commission Region I . .

475 Allendale Road.

King of Prussia, PA' 19406 Senior NRC Resident Inspector

• Pilgrim Nuclear Power Station L

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. , ATTACHMENT 1 Pilgrim IST Program Relief Request Previously Submitted H ~ and Acceptable Under the Provisions of Generic Letter 89-04 The following list correlates the current to past relief requests for pumps -

and valves. Minor revisions which have not'affected the intent are summarized below. Intent changes to past relief requests are identified in Attachment 2 and.3. Cold Shutdown Justifications which conform to Subsection IHV Requirements and Relief Requests which were previously in full compliance with the. Generic Letter Requirements are also identified in this: attachment.

Relief Request changes from the past IST Program Revision (1B) have been highlighted by boldface.

CURRENT PASI STATUS RP RP-1 Added requirement- to measure individual pump flow ,

rate and pressures each Pefueling Outage.

RP-2 RP-2 Minor, Basis and Alternate Testing Hording

, Clarification.

RP-3 RP-3 Added Flow Instrumentation Deviatic". From IHP-4600, flowrate Measurement. Basis and Alternate Testing-Nording Clarification.

RP-4 PP-4 No Change.

! RP-5 RP-5 Added requirement to measure individual pump flow rate and pressures each Refueling Outage. Basis and Alternate Testing Wording Clarification.

RP-6 RP-6 No Change.

RP-7 RP-8 Reduced (made more conservative) Allowable Corrective Action ranges.

RV-01 RV-03 Minor; Basis and Alternate Testing Hording j Clarification.

1 RV-02 RV-06 Minor; Basis and Alternate Testing Nording l Clarification-.

RV-04 RV-08 Minor; Basis and Alternate Testing Hording Clarification.

RV-05 RV-11 Minor; Basis and Alternate Testing Hording Clarification RV-06 RV-14 No Change.

RV-07 RV-16 Minor, Basis Hording Clarification.

'RV-08 RV-19 Minor, Basis Wording Clarification.

RV-09 RV-21 Minor, changed Basis due to Technical Spec amendment i

which effects Control Rod Scram Testing frequency. I l

RV-10 RV-22 Minor, Basis Wording Clarification. '

1 RV-11 RV-24 Minor; Basis and Alternate Testing Hording  !

Clarification. 1

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' 1 CURRENT- EASI STATUS 1 RV-12 RV-26 Minor; Basis and Alternate Testing Wording i Clarification.

RV-13 RV-28 Minor; Function, Basis ~and Alternate Testing Nording.

Clarification.

RV-14 RV 140 Changes. '

RV-15 RV-33 Changed Class Designation to NC.

RV-16 RV-39 Minor, Basis Hording Clarification.  ;

RV-18 RV-44 Changed Class Designation to NC.  !

RV-19 RV-45 Changed Class Designation to NC.

RV-20 RV-47 Minor, changed Valve to Normal Closed position.

Modified wording in Basis and Alternate Testing, accordingly.

CS-01 RV-02 No Change. ,

CS-02 RV-12. No Change.

CS-03 RV-13 Change to Partial Exercise Justification.

'CS-04 RV-15 Minor Basis Clarification.

CS-05 RV-23 No Change.

CS-06 RV-25 No Change CS- 07 RS-41 No Change.

CS-08 RV-43 Minor, Basis Nording Clarification.

CS-09 RV-46 Minor, Basis Wording Clarification. i

'CS-10 NEH Not Applicable.

CS-11 RV-48 Minor, Basis Wording Clarification.

CS-12 NEH Not Applicable.

CS-13 RV Changed Class Desiccation to NC.

CS-14 RV-36 No Change.

CS-15 NEW Not Applicable.

.CS-16 NEW Not Applicable.

GL.

ATTACHMENT 2

.. . Relief Request For Generic Letter 89-04 and Accepted

.o Under the Provisions' of Generic Letter 89-04 The following list identifies new relief requests specially created (NEH) to satisfy Generic Letter 89-04. The Generic Letter 89-04 position for '

compliance is identified within each relief request.

CURRENT ITEM # GENERIC LETTER 89-04 POSITION RP-08 NEH 8 -Identifies that shift personnel shall declare the pump-inoperable and the Technical Specification action time. must be started.

RV-17 NEW 7 and -Identifies valves which were not 11a uniquely specified within the Generic Letter but considered active valves in positioning control rods.

'RV-27. NEH 2 -Established a position regarding testing of check valves by disassembly to verify full-exercise. Outlines sample

-disassembly and inspection program.

RV-28 NEW 10 -Identifies non-conformance to; l- IHV-3427(b) for containment itolation valve Corrective Action.

.RV-29 NEH 6 -Identifies use of- a reference stroke time and corrective action f,or increased . L testing requirements.

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. j ATTACHMENT 3' g,  : .

New ISTP Relief. Requests Most;of th'e.following relief' requests were created because of the increased l

. scope of components _(Pumps and Valves) being tested. Some of these reliefs H

were informally identified _to the NRC as part of BECo's planned IST Program  !

Upgrade'to increase Scope.

1 QHLPINI POSITION ,

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.RP-09 For the absolute strict compliance to IHP-4120 Requirements, j industry-wide acceptable test equipment would be considered  !

unacceptable. Because of the non-compliance, this Relief is required, but the minor deviation has no affect on satisfying l

-the intent of IHP for monitoring pump performance. (This issn* 1 was previously identified). ~

4 RP-10 Created due to incorporation of the HPCI Gland Seal Condenser Condensate Pump into the ISTP as safety significant. "

RV-03 Basis wording clarification. Added request for relief (frequently) from 2-year Position Indication verification _ to be once per refuel. (Past Relief # RV-07).

RV-21 Created due to increased Scope of the ISTP. (This issue was previously identifled).

i RV-22 Revised to incorporate Leak Test Frequency Relief since testing can only be performed safely while conducting the Class 1, System Leakage / Hydrostatic Pressure Test duting Refueling Outages. (Past Relief # RV-C ).

RV-23 Created due to the incorporation of. Diesel Oil Transfer Syster into IST Program as safety significant. (This issue was previously identified).

RV-24 Created due to increased Scope of the ISTP. (This issue was previously. identified. Ref. BECo Lettei 2.89.144 to NRC dated September 22, 1989). It should be noted that these valves are currently inoperative until completion of an ongoing Plant Design Change.

RV-25 Created due to increased Scope of the ISTP. (This issue was previously identified).

RV-26 Created due to increased Scope of the ISTP.

RV-30 Created due to increased leakage testing requirements that necessitate the use of a Pressure Drop (Decay) Test technique in lieu of IHV-3420 Valve Leak Rate Testing.

RV-31 Created due to the incorporation of the H /02 Analyzer System 2

into the IST Program as safety significant.

1-Executive Summary l

Issue Summary Generic Letter 89-04 was issued on April 3,1989 and required a statement of conformance by October 3, 1989. BECo requested an extension to ths response date on October 27, 1989 (Reference 2.89.158). The extension was requested to allow 8ECo sufficient time to finalized the revision of the IST Program and prepare a Statement of Conformance with the positions delineated in the Generic Letter.

He prdpared a major revision to our IST Program which incorporates the positions contained in the Generic Letter. This letter transmits our revised program and the Statement of Conformance to the positions delineated in the Generic Letter.

Status The IST Program has been prepared in conformance with the requirements of the Generic Letter. Three (3) attachments have-been prepared to facilitate the NRC review of our relief requests. Attachment 1 identifies previously submitted relief requests which we believe are acceptable and approved under the provisions of Generic Letter 89-04. Attachment 2 identifies new relief requests whicn we believe are acceptable and approved under the provisions of Generic Letter 89-04. Attachment 3 identifies new Relief Rsquests which wa believe are consistent with the routine upgrade provisions of 10CFR50.55a(g),

but which ri. quire NRC approval before they can be implemented.

Pump and valve test procedures have to be. developed. The schedule for preparation of the procedures was transmitted to.the NRC on October 27, 1989 (Reference 2.89.158).

A number of plant modifications to allow testing have been identified and they will have to be implemented during RF0 #8 (for compliance to Generic Letter 89-04). The estimated cost for-the modifications are discussed in the Cost /LTP.Section of the Executive Summary.

Schedule A schedule supporting the completion of the conformance to the Generic Letter was transmitted in our previous letter, 2.89.158. The following internal milestenes have been developed:

Complete Cold Shutdown and Quarterly Pump and Valve procedures by 6/30/90.

Complete Valve Leakage and Refueling Outage procedures by 11/30/90, tinta: The internal Valve Leakage and Refueling Outage milestones have 2 months of slack.

-A detailed (working) schedule will be developed to control the preparation of the procedures.

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i Cost /LTP '

C I. Nuclear Engineering' Department Cost' Impact Plant modifications are estimated to cost $255,000. W cost components are estimated to be (order of magnitude)

BECo Labor $65,000 (1990)

BECo Capital $190,000- (1991)

A conceptual SJA will be prepared requesting the additional funds be added

'to LTP 460-for these modifications.-

II. The Plant Department. cost impacts are as.follows: i A. One time cost associated with Generic _ Letter 89-04. 3 l

1. Procedure Revisions Contractor Support - $75,000 (included in RS&P Division 1990 ,

Budget)_

u' BECo Personnel - $40,000.

The Reactor Safety and Performance Division has established a 1990 Budget Line Item for this activity of $75,000. This will cover revision of all test procedures or creation of new procedures for <

On-line and' Cold Shutdown testing. Procedures required for RF0 #8 i will'be completed by Division personnel as.part of normal work activities if not completed as part of the previously discussed contractor support effort.

2. System Relief Valve Renlacemerit Although not.specifically required by Generic. Letter 89-04, in  :

lieu of testing the valves, Reactor Safety and Performance Division recommends that some of the 41 relief valves identified for-testing every 5_ years be replaced by RF0 #9.

a. The majority of the valves are original plant equipment and have not been tested since e installation. 'The cost to test and then investigate and correct any failures would be more in both expense dollars and critical path time during an outage than straight replacement.

b. Vendor test data is acceptable for new valves, i.e.,

no BECo testing would be required.

Estimated cost is $71,400 over two (2) refueling outages. (This is in addition to the $255,000 cited in paragraph I above).

B. Recurrina Colt

1. It is estimated that 951. of the increased recurring costs associated with this program upgrade will be associated with refue' ling outages, i.e., check valve disassembly, relief valve testing.

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_ a .' -As_a ninhnum, 11 check valves are required to be - . j

- disassembled.per RFO. The-cost associated with this {

$' activity is $36,850/RFO.-

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b. If system relief valves are not replaced (see one time 1 4 costs paragraph.II.A.2), then 22 valves (one-half of the i .

valves) are required to be tested per RF0 (i.e RF0 #8.and RF0 #9.- end of this IST 10-year interval). The cost

"' , associated with this (only testing, assuming no failures)  ;

is $53,200/RF0 or $106,400 total (RF0 #8 and RF0 #9).  !

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2. 100 valves are being added to the IST program.

The majority of.  !

the valves are currently _being tested with existing plant -

4 procedures or will take credit for existing component testing.

, Therefore, no incremntal cost-is ' associated with this activity.

3 pumps are being added to the IST program. One is current 1y' 1 being tested to existing station procedures (HPCI Gland Seal Condensate). Two (D.G. Fuel Oil Transfer Pumps). require revision to the test method (i.e, new test procedures). These can be tested on-line - there will be minimal impact - no $0 assigned.

C. . r$8ential Cost Benefits .

i The Reactor Safety and Performance Division has submitted proposed Technical Specification changes based on the PNPS IST Program that will have the following benefits (reduce costs): ,

1. Change the frequency of testing Technical Specification pumps and valves from monthly to quarterly and. for some' valves to Cold. <

Shutdown. The above will simplify test procedures, minimize

!- equipment'run time and reduce operations man power requirements p to perform testing.

l 2. Change the frequency of Excess Flow Check Valve testing from )

L once-(1)/ cycle (18 months) to Refueling Outage.

l 3. Reduce the probabilities of certain equipment failures.

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The proposed change to the Technical Specification will reduce the overall expense _of performing Technical Specification Testing and implementing the INPS revised IST Program. The amount has not been 1

estimated at this time.

Reauired Action A detailed schedule identifying specific milestones will be developed to control the preparation of the test procedures. The plant modifications will be processed in accor::ance with N0P83E1 (Control of Modifications to Pilgrim Station). The schedule will also track the plant modifications.

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