ML20136F548
| ML20136F548 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 08/23/1993 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20136C539 | List:
|
| References | |
| FOIA-96-485 NUDOCS 9703140193 | |
| Download: ML20136F548 (6) | |
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}j NUCLEAR REGULATORY COMMISSION l
UNITED STATES g....,/,e waswiworow, o.c. sonas. coos l
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION l
i RELATED TO THE INSERVICE TESTING PROGRAM REQUESTS FOR RELIEF i
FLORIDA POWER AND LIGHT COMPANY i
ST. LUCIE PLANT. UNIT 2
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DOCKET NO. 50-389
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1.0 INTRODUCTION
i 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 i
Code and applicable addenda, except where alternatives have been authorized or-
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relief has been requested by the licensee and granted by the Commission i
pursuant to Sections (a)(3)(i), (a)(3)(ii), or (f)(6)(1) of 10 CFR 50.55a.
In i
proposing alternatives or requesting relief, the licensee must demonstrate i
that: (1) the proposed alternatives provide an acceptable level of quality and safety;-(2) compliance would result in hardship or unusual difficulty without j
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 to the Code requirements determined acceptable to the
-NRC staff.
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The Commission is authorized pursuant to 10 CFR { 50.55a to approve
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alternatives and to grant relief from ASME Code requirements upon making the i
necessary findings. The NRC staff's findings with respect to authorizing j
alternatives and granting or not granting the relief requested as part of the
. licensee's inservice testing (IST) program are contained in this Safety 4
i Evaluation (SE).
Furthermore, in a rulemaking.to 10 CFR i 50.55a effective September 8,1992, (see 57 FR 34666), the 1989 edition of ASME Section XI was incorporated in 1
e j
50.55a(b). The 1989 edition provides that the rules for IST of pumps and valves shall meet the requirements. set forth in ASME Operations and I
Maintenance Standards Part 6 (OM-6), Inservice Testing of Pumps in Light-Water Reactor Power Plants, and Part-10 (0N-10), inservice Testing of Valves in 1
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. Light-Water Reactor Power Plants. Pursuant to 10 CFR i 50.55a(f)(4)(iv),
portions of editions or addenda may be used provided that all related 1
requirements of the respective editions or addenda are met, and subject to Commission approval.
Because the alternatives meet later editions of the
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Code, relief is not required for those inservice tests that are conducted in accordance with OM-6 and OM-10, or portions thereof, provided all related requirements are met. Whether all related requirements are met is subject to j
NRC inspection.
I 9703140193 970301 f
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The IST program evaluated in this SE covers the first 10-year IST interval for St. Lucie Plant, Unit 2.
The interval began August 8, 1983, and ends August 8, 1993. The first 10-year interval IST program is based on the requirements of the 1980 Edition, included addenda through the Winter 1980 Addenda, of the ASME Section XI Code which were incorporated by reference in 50.55a(b) by 46 FR 63208 effective February 1, 1982.
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The second 20-year interval begins August 9,1993. The relief requests which are approved for an interim period of one year, or until the next refueling l
outage, whichever is later, may continue into the next interval, if applicable. This will allow the licensee time to evaluate the concerns identified in the attached Technical Evaluation Report (TER) associated with these relief requests.,0therwise, the licensee should implement the updated-IST program developed for the second 10-year interval, which has not yet been submitted to the NRC, at the second interval start date in accordance with the requirements of 10 CFR 50.55a(f)(4)(ii).
2.0 EVALUATION j
The NRC, with technical assistance from Brookhaven National Laboratory (BNL),
has reviewed the information concerning IST program requests for relief submitted for the St. Lucie Plant, Unit 2, in Florida Power and Light Company's letters dated September 15, 1992, and January 13, 1993. A previous i
Safety Evaluation for the St. Lucie Plant, Unit 2, IST Program was issued for i
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_the first 10-year interval in NRC's letter dated January 13, 1986. The September 1992 revised program renumbered the relief requests.
The licensee
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identified several relief _ requests in At.tachment 1 of their September 15, 1992, submittal which they indicated required review and approval by the NRC.
The remaining relief requests which were not listed in Attachment I were not reviewed. The relief requests submitted for the second 10-year program will be reviewed in total.
The staff adopts the evaluations and recommendations for granting relief or authorizing alternatives contained in the attached Technical Evaluation Report prepared by BNL. Relief is granted from, or alternatives are authorized to, the testing requirements which have been determined to be impractical to perform, where compliance would result in a hardship without a compensating increase in safety, or where the proposed alternative testing provides an acceptable level of quality and safety. Certain relief requests have been approved pursuant to 10 CFR 50.55a(f)(4)(iv) where it has been determined that the proposed alternative is in accordance with the requirements of the 1989 Edition of ASME Section XI, and therefore, relief from Code requirements is not required. When an alternative is approved pursuant to (f)(4)(iv), any applicable related requirements, as listed in the TER, must be implemented, '
and such implementation is subject to NRC inspection. A summary of the NRC actions is provided in Table 1.
The IST program relief requests which are granted, authorized, or approved are acceptable for implementation provided the action items identified in Section 4 of the TER are addressed within one year of the date of the SE or by the end of the next refueling outage, whichever is later. As noted above, the
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St. Lucie Plant, Unit 2,10-year interval updated program will be implemented i
August 9, 1993. Any interim relief continues for the next interval, if j
applicable, in order that the licensee have a period of time to address the concerns identified in the TER.
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. 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 l
alternatives proposed.
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Program changes involving new or revised relief requests should not be
' implemented prior to approval by the NRC except as authorized by GL 89-04.
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. New or revised relief requests that meet the positions in GL 89-04, Attachment i
1, should be submitted to the NRC but may be implemented provided the guidance lu in GL 89-04, Section D, is followed.- Program changas that add or delete components from the IST program should also be periodically provided to the
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NRC.
4 3.0 RELIEF REQUEST VR-13. SAFETY INJECTION TANK TO REACTOR COOLANT SYSTEM i
CHECK VALVES V-3215. V-3225. V-3235. AND V-3245. AND RELIEF REQUEST i
VR-14. SAFETY INJECTION HEADERS TO REACTOR COOLANT SYSTEM CHECK VALVES
~j V-3217. V-3227. V-3237. AND V-3247 1
i In addition to the evaluations in Section 3.2.2 and 3.2.3, and discussion in l;
Action Items 4.9 and 4.10, of the TER, the staff provides the following information for the licensee to consider in evaluating the extension.of the 4
j disassembly and inspection (D+I) for the safety injection tank discharge check j
valves and the safety injection headers check valves.
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Disassembly and inspection of a check valve is not considered a true substitute for an operability test conducted under operating flow conditions, i
but is allowed when no other means for testing is available. Under operating i
conditions the valve internal parts are subjected to dynamic flow loads, pressure gradients, differential temperature and gradients, and flow-induced and system-generated mechanical vibration.- Pipe loading on the valve body can affect the alignment of valve internal parts. Any of these conditions, or a j
i combination of these conditions, can alter the valve performance and the effects could be diagnosed during operational testing. However, these operating conditions are not duplicated, and the results may not be apparent, in a disassembly and inspection effort. There have been instances where operational problems were discovered after disassembly / inspections. There are also examples of latent problems caused by the disassembly and inspection i
efforts, such as installing a bonnet-hung check valve in an incorrect l
orientation. Certain of these problems could be identified during a partial-i i
flow test or a leakage test following disassembly / inspection, if performed.
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In the past, conditions limiting testing of certain check valves justified the i
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use of disassembly and inspection since no other practical test method was l
available. With the acceptance of nonintrusive methods and the development of i
other test methods, this justification requires a re-examination (reference i
i NUREG/CP-0123, " Proceedings of the Second NRC/ASME Symposium on Pump and Valve 1
j Testing"). GL 89-04,. Position 2, was developed prior to wide-spread use of e'
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l nonintrusive techniques.
It allowed disassembly and inspection conditionally 1
when other methods were impractical; however, in the public meetings, in l
response to questions on use of D&I, the staff indicated the use of other alternate techniques, including nonintrusives, were under investigation and i
were being encouraged by NRC. Allowing D&I.on a sampling basis was an extension of the Code required time interval for valve testing. The D&I sample i
was small and valves in the group were identical in type, size, service conditions, exposure to operating environments, and age. The GL 89-04 sampling interval extension was justified on the basis that one valve in the group would be examined during each refueling outage and the performance of each.
valve in the group was representative of all the others.
Generic Letter 89-04, Position 2, allowed the use of a limited sampling plan to reduce the burden on the licensee to D&I all valves in the group during each refueling. The sampling plan allowed that only one valve in each group be D&I at each refueling rather than disassembling and inspecting all valves in the group. The sampling plan further allowed a different valve in the group be D&I at each refueling and the process be repeated until all valves were inspected. With an 18-month operating fuel cycle, this would ensure that no valve D&I interval would be greater than 6 years. Position 2 also suggested conditions of extreme hardship for consideration in extending the inspection interval beyond once every 6 years.
In Pos' tion 2 the staff, in part, stated
"[i]n order to support extension of the valve disassembly and inspection interval to longer than once every 6 years, the licensee should develop the following information:
a.
Disassemble and inspect each valve in the grouping and document in detail and the condition of each valve and the valves's capability to be full stroked...."
Although GL 89-04 suggested information to be considered by the licensee in developing justification for an interval extension it was not all inclusive.
The staff expected the licensee would conduct an in-depth review of all the safety effects as discussed during the public meetings. The staff expectations for justification of an interval extension were amplifici in the responses to questions during the GL 89-04 public meetings.
Included in the staff justification expectations was a licensee's detailed evaluation of the effects on public safety, the maintenance history, service history, and other information relative to valve reliability, and that the review and evaluation would rely on known and recorded valve condition of each valve from previous inspection data rather than subjective qualitative judgment. The licensee's justification for extending the inspection interval appears to be based on concerns of mid-loop operation. The evaluation presented in the relief request is considered inadequate for justifying extending the inspection interval per the guidance delineated in GL 89-04, Position 2.
Further, the concerns regarding personnel exposure and potential loss of decay heat removal are the result of performing disassembly and inspection.
In addition to attempting to provide additional justification to comply with GL 89-04, Position 2, for the extreme hardship of performing D&I each refueling outage, the licensee should consider the advantages of other test methods available, including nonintrusive techniques, to reduce exposure and avoid the potential loss of decay heat removal. A discussion of the results of the efforts to
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l 4 apply other testing techniques should be included in the licensee's response to Action Items 4.9 and 4.10.
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4.0 CONCLUSION
The licensee's IST program requests for relief from the requirements of Section XI have been reviewed by the staff with the assistance of its contractor, Brookhaven National Laboratory. The Technical Evaluation Report provided as Attachment 1 is BNL's evaluation of-the licensee's IST program 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 presented in Table 1.
The authorizing of alternatives or granting of relief is based upon the fulfillment of any commitments made by the licensee in its basis for each relief request and the alternatives proposed. The implementation of the IST program is subject to inspection by NRC.
Relief requests which are in accordance with the 1989 Edition of ASME Section XI (which incorporated OM-6 and OM-10) have been approved pursuant to 10 CFR 50.55a 1 (f)(4)(iv) as listed in Table 1; however, because these meet the Code requirements, these are listed as " relief is not required." Certain other relief requests are authorized for an interim period to provide the licensee a period of time to review the testing.
The licensee should refer to the TER, Appendix A, for a discussion of IST program anomalies identified during the review. The licensee should resolve i
all items in accordance with the guidance therein. The IST program relicf requests which-are granted, authorized, or approved are acceptable for i
implenientation provided the action items identified in Section 4 of the TER e
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are addressed within one year of the date of this SE or by the end of the next refueling outage, whichever is later. The action, where applicable, should-address the licensee's updated second 10-year program as well. The licensee should respond to the NRC within one year of the date of this SE describing actions taken, actions in progress, or' actions to be taken, to address each of these. Items, noting which issues have been resolved by the updated second 10-year interval program.
The staff concludes that the relief requests as evaluated and modified by this SE will provide reasonable assurance of the operational readiness 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),
authorizing alternatives pursuant to 10 CFR 50.55a (a)(3)(i) and (a)(3)(ii),
and approving alternatives pursuant to 10 CFR 50.55a (f)(4)(iv) is authorized by law and will not endanger life or property, or the comon defense and security and is otherwise in the public interest.
In making this
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. i determination, the staff has considered the impracticality of performing the i
required testing and the burden on the licensee if the requirements were imposed.
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Principal Contributor: Patricia Campbell, DE/EMEB Date: August 23, 1993
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Attachment:
Technical Evaluation Report 4
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