FVY-84-139, Forwards Info Supporting 790130 Application to Amend License DPR-28,consisting of Proposed Change 77 to Tech Specs to Allow Exemption from Inservice Insp Program Code (ASME Section Xi).Revised Inservice Insp Program Encl.Fee Paid
| ML20100E780 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 11/27/1984 |
| From: | Murphy W VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20100E784 | List: |
| References | |
| FVY-84-139, NUDOCS 8412060369 | |
| Download: ML20100E780 (523) | |
Text
s.
VERMONT YANKEE NUCLEAR POWER CORPORATION FVY 84-13]
. RD 5, Box 169 Ferry Road, Brattleboro, VT 05301 ,,,Ly 7,,
p- ENGINEERING OFFICE 1671 WORCESTER ROAD
+ FRAMINGHAM, MASSACHUSETTS 01701
- - TELEPHONE 617-872-8100 November 27, 1984 U.S. Nuclear Regulato.'y Commissior.
Washington, D.C. 20555 Attention: Office of Nuclear Reactor Regulation Operating Reactors Branch #2 Division of Licensing
References:
a) License No. DPR-28 (Docket No. 50-271) b) Code of Federal Regulations, Title 10 Chapter 1, Part 50, Section 50.55a c) ASME Section XI, 1980 Edition through the Winter 1980 Addenda d) ASME Sectior. XI, 1974 Edition through the Summer 1975 Addenda e) letter, VYNPC to USNRC, WVY 79-9, Proposed Change No. 77 to Technical Specifications, dated 1/30/79
Dear Sir:
Subject:
Vermont Yankee Inservice Inspection Program Code Exemptions As required by 10CFR50.55a(g)(5)(iii), we are submitting herewith infor-mation which supports our determination that certain of the requirements of Reference c) are impractical for our facility. This information is applicable to the Vermont Yankee Inservice Inspection Program for the second 120-month inspection interval. To facilitate your review of these exemptions, we are also enclosing six (6) copies of the complete program for information only. This program has been developed in accordance with Reference b) to meet the require-ments of Reference c) and, where applicable, Reference d). Changes to the program will be submitted for NRC approval prior to implementation only in the event that such changes constitute further exemptions under 10CFR50.55a(g)(5)(iii).
In preparing this program, we have interpreted the statements in 10CFR50.55a(b)(2)(ii) regarding the extent of examination for Category B-J piping welds'to mean that the degree to which these components must be examined shall be as defined in Table IWB-2500 and IWB-2600 of Reference d). It is our understanding that " extent of examination" encompasses the degree of interroga-tion afforded by the nondestructive examination techniques stipulated in Table IWB-2600, and that the examinations listed therein and in Table IWB-2500 of Reference ponents. d) are the only examinations required by 10CFR50.55a for these c pwain s+ ed PDR 1
U.S. Nuclear R:gulatery Connission Novemb:r 27, 1984 Page 2-VERMONT YANKEE NUCLEAR POWER CORPORATION Category C-F an'd C-G piping welds shall be examined in accordance with 10CFR50.55a(b)(2)(iv), and -all other components shall be examined as required by
' Reference c) unless specific relief is requested in the enclosed Program sec-tions.-
In accordance with the provisions of 10CFR170.12, an application fee of -
$150 is enclosed. It is important to note that this updated program is being instituted despite the fact that we have not yet received a Technical Specification amendment under 10CFR50.55a(g)(5)(ii) permitting the use of any edition of ASME Section XI later than the 1974 Edition, Summer 1975 Addenda [see Reference e)].
We trust that the information contained in this submittal will be satisfactory; however, should you have any questions or require additional information, please contact us.
Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION d4a Warren P. urphy h
Vice President an Manager of Operatic l WPM /dm
RELIEF REQUEST BASIS Number: B_1 Component: -Circumferential and longitudinal shell welds in reactor vessel Category: 8-A Items: B1.11 and 81.12 Class: 1.
i- Test Requirement Volumetric j Basis for Relief: With the exception of portions of the two longitudinal seam welds adjoining the vessel shell to flange weld, vessel shell welds are inaccessible due to mirror. insulation / bio-shield configuration. Insulation is not designed to be easily re-movable and only 8-1/2 inches of clearance exists between the outside of the insulation and the inside of the shield wall.
Nozzle inspection ports do not provide sufficient access to reach shell welds.
Alternate Testing: Accessible length of B1.12 Igitudinal welds will be exa-mined 100% during each inspection interval. In addition, the-reactor vessel is subjected to a system leakage test before startup after each refueling outage, and to a hydrostatic pressure test at least once each inspection interval.
I a
- I-127
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RELIEF REQUEST BASIS
- Number: B Components Repair welds in reactor vessel beltline region L ' Category. - B-A-Item. 81.51 Class, 1
, Test Requirement. Volumetric Basis for Relief: Beltline region repair welds are inaccessible for the reasons stated in Relief Request Basis No. B-1.
Alternate Testing: One weld repair area (if any such areas exist) in the region between the top of the bio-shield wall and the vessel flange will be examined during each inspection interval. In addi-tion, the reactor vessel is subjected to a system leakage test before startup after each refueling outage, and to a
- - hydrostatic ~ pressure test at least once each inspection-interval.
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I-128
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RELIEF REQUEST BASIS Number s 3 Component: Integral attachments for vessels ,
Category: B-H
- Item 88.10
+
Class 1
- Test
- Requirement. Volumetric or Surface, as applicable l Basis for Relief
- 1. the reactor vessel support skirt to vessel weld is only partially accessible from outside the skirt enclosure at two locations, approximately four feet long and 183 apart. The balance of the weld is covered by non-removable mirror insu-lation.
- 2. The reactor vessel stabilizer brackets are attached to the vessel with vee-prep fillet-type welds. A volumetric inspection of these welds would not be meaningful. The bot-tom side of the stabilizer weld is inaccessible due to its location behind the top of the bio-shield wall.
- Alternate Testings 1. The accessible portions of the vessel support skirt weld will be inspected by volumetric and surface methods from out-side the skirt enclosure during the second inspection inter-1 val, and the total weld length required for the second -
interval will be examined by surface methods from inside the enclosure.
- 2. The upper portion of each stabilizer bracket attachment l weld will be examined by surface ~ methods during the second L
inspection interval.
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s-RELIEF REQUEST BASIS Number B-4 Component Primary containment penetration process pipe to flued head welds Category: B-I Class, 1 Test Requirement. Volumetric Basis for Relief Each of the following lines enters the primary containment via a penetration assembly similar in design to those shown in Figure 1. In each case, the Class 1 process pipe has one circumferential pressure retaining weld which is inaccessible s for ultrasonic examination. In addition, the complex design of the penetration makes double-wall radiography extremely difficult and unreliable. Meaningful volumetric examination of these welds is not possible.
- 1. Main Steam A, 8, C and D - 18 in.
- 2. Feedwater A and 8 - 16 in.
- 3. RHR A Supply - 20 in.
- 4. RHR B and C Return - 24 in.
- 5. HPCI Steam Supply - 10 in.
- 6. RCIC Steam Supply - 3 in.
- 7. Core Spray A and 8 - 8 in.
Alternate Testing: The first accessible process pipe weld outside of each listed penetration will be volumetrically examined once each inspec-tion interval. In addition, during the primary coolant bound-ary hydrostatic pressure test at or near the end of each interval, visual inspection from within the primary contain-ment will be performed to detect leakage from internal welds.
During operation, routine surveillance of process monitoring l
instrumentation will detect significant leakage.
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1 RELIEF REQUEST BASIS Number B-5 Component: Main steam line circumferential weld joints A4 and 04 Category. B-J
- Class e- 1 Test-Requirement Volumetric
. Basis for Relief. Welds A4 and D4 are pipe to valve welds which are inspectable
! from the pipe side only, as discussed in Relief Request Basis
- B-4. HowcVer, most of the weld crown and several inches of base metal on the pipe side are covered by a support ring
, (see attachment). These rigid supports cannot be removed because '.le only other restraints on each line are the penetration at one end, several spring hangers and a snubber along the run, and the vessel nozzle at the other end.
Removal would introduce unnecessary stress into the piping and remaining support components. Consequently, volumetric examination of these welds is not practical.
Alternate Testing These welds will be visually examined for leakage during the primary coolant system hydrostatic pressure test. In addi-tion, they will be volumetrically examined, to'the extend practical, if the support components are removed for any reason.
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I-132
WELDED SUPPORT RING WELDED SHEAR BLOCK
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RELIEF REQUEST 8 ASIS-
' Number: B-6
- Components : Welded and non-welded component supports and restraints on liquid-filled piping and components. smaller than 2* schedule 80 and on steam-filled piping and components smaller than 4* schedule 80. .
Category: F-A, F-8 and F-C Test Requirement VT-3, VT-4 Visual Basis for Relief In the interest of keeping personnel radiation exposure ALARA,'and to maintain consistency with the allowance of Sub-sub Article IWB-1220, paragraph IWB 1220(a), VT-3 and VT-4 visual examination of non-welded sopport components and restraints under Section IWF should be limited to those sup-ports and restraints on piping and components which are 2*
schedule 80 (liquid service) and larger, and 4* schedule 80 (steam service) and larger.
Alternate Testing Significant degradation of these support components would be readily observable during visual examinations performed while pressure testing those systems in accordance with IWB-5220.
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I-134 1
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n RELIEF REQUEST BASIS Number: C-1 . .
. Component: RHR Heat Exchangers' Nozzle Welds -
Cate' gory: C-8 .
Class: 2 Test Requirement: Volumetric Basis for. Relief: Nozzle design configuration prohibits meaningful volumetric
covered by a reinforcement saddle. - Refer to detail *A" of drawing I-20.
Alternate Testing: Surface and VT-1 visual examinations shall be performed on the reinforcement saddle-to-nozzle and reinforcement saddle-to-vessel welds.
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RELIEF REQUEST BASIS Number: C-2 -
Component: Attachment welds for pipe covering protection saddles
- Category: C-E-1 Tcat Requiremes.w. Surface Basis for Relief: Saddles are provided to prevent damage to piping caused by excessive lateral deflection. They mainly perform a posi-tional rather than a load-bearing function. The saddles are designed to transmit those loads that do exist in a predomi-nantly compressional mode. Therefore, the intermittent or continuous fillet welds (see attachment) used to join the saddles to the pipe serve to hold them in place but do not contribute significantly to their load-bearing capability.
The saddle-configuration is such that access to these welds is severely limited, and surface examination is, con-sequently, impractical or impossible. The "best effort" examinations which result require considerable work and pro-vide negligible benefit in terms of improved plant safety, reliability and quality.
Alternate Testing: Visual examination will be performed on all fillet-welded saddles.
P 5
II-103 I
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SUPPORT SADDLE CONFIGURATION
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FILLET WELDS
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i RELIEF REQUEST BASIS NUMBER C-2 ATTACHMENT .
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RELIEF REQUEST BASIS Number: C-3 Components- Welded and non-welded component supports and restraints s 4 in. nominal pipe size Category: -F-A, F-B and F-C Class: 2 Test Requirement: VT-3, VT-4 Visual Basis for Relief: To maintain consistency with the allowance of Sub-sub Article IWC-1220, paragraph IWC-1220(c), VT-3 and VT-4 visual exami-nation of welded and non-welded support components and restraints under Section IWF should be limited to those-sup-ports exceeding 4 in. nominal pipe size.
Alternate Testing: Significant degradation of support components s 4 in. tFS would be readily observable during visual examinations per-formed while pressure testing these systems in accordance with IWC-5220.
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RELIEF REQUEST BASIS Number. 0-1 Component. Welded and non-welded com 4-in. nominal pipe size. ponent supports and restraints s Category. F-A, F-8 and F-C Class: 3 Test Requirement VT-3, VT-4 Visual Basis for Relief To maintain consistency with the allowance of Sub-sub Article IWD-1220, paragraph IWD-1220.1, VT-3 and VT-4 visual examina-tion of welded and non-welded support components and restraints under Section IWF should be limited to those sup-ports exceeding 4-in nominal pipe size.
Alternate Testing Significant degradation of support components s 4-in. NPS would be readily observable during visual examinations per-
' formed while pressure testing these systems in accordance with IWD-5220.
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III-23
RELIEF REQUEST 8 ASIS Number H '
Systems:- Resihjal Heat Removal Lines Core Spray Suction and discharge pipifrom Torus to first s High Pressure Coolant Injection valve.
-Reactor Core Isolation Cooling c-Safety Class: 2 Basis for Relief: Piping is non-isolable from primary containment, which has a design pressure of 56 psia.
Alternate, Testing: Piping experiences a static head pressure of 5-6 psig with the torus filled to its normal operating level. Visual exa-
, , minations are made during monthly surveillance testing to i
verify absence of leakage.
RELIEF REQUEST BAblS Number: H-2 System: Standby Liqujd Control Line: SLC - 2, 3, 4 and 5 Downstream of valves V11-11 and V11-41 to SLC pumps.
Safety Class: 2 Function s ::cdium pentaborate suction from SLC tarks.
t Basis for Relief: This piping has no test connection between the valves and
- the positive-displacement SLC pumps. The suction piping
- d. upstream of the valves is open to atmosphere through the SLC tanks, and provides no boundary.
}, -.
Alternate Testing: , Piping experiences a static head of 3-5 psig from the SLC tank, since V11-11 is normally open. Evidence of leakage 0
. would be detectable during surveillance testing and operator
.rsnds.
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RELIEF REQUEST BASIS Number: H-3 System: Standby Liquid Control Line(s): SLC-11 between valves V11-15 and V11-16.
Test connection downstream of V11-16 to V11-36.
Safety Class: 2 Function: Sodium pentaborate injection to reactor vessel. -
Basis for Relief: Pressurization of this piping to 1.10 x Psv (1595 psig) would also pressurize the Class 1 portion of SLC-11 to valve V11-18. The latter piping forms part of the reactor coolant pressure boundary, and as such is only required to be tested' at 1.02 x P0 (1018 psig).
Alternate Testing: This piping will be hydrostatically tested during the Safety
, Class 1 primary coolant pressure boundary hydro.
RELIEF REQUEST BASIS
' Number: H-4 System: Radwaste Line(s): Piping to RHR Sys. from RX Bldg floor drains downstreain of valves 319A-D.
Safety Class: 2 Function: Forms part of Primary Containment Isolation System Basis for Relief Safety function of the piping is to contain primary contain-ment atmosphere. Piping integrity in this service is ade-quately demonstrated by periodic pneumatic leak rate testing.
. Alternate Testing: Containment Isolation portions of this system are tested to 44 psig during the Type **C* Leak Rate Test each refueling and are tested during the Type **A* Leak Rate Test every 3-1/3 years.
H-52 L
RELIEF REQUEST BASIS' Number: -H-5 System: Radwaste Lines: Drywell Sump Pump Discharge from Penetrations X-18 and X-19 to Valves j A0-83 and A0-95.
- Function: Forms part of Primary Containment Isolation System.
Basis for Relief: Safety function of the piping is to contain primary contain-ment atmosphere. Piping integrity in this service is ade-
, quately demonstrated by periodic pneumatic leak rate J
testing.
Alternate Testing: Containment Isolation portions of this system are tested to 44 psig during the Type "C" Leak Rate Test each refueling ,
and are tested during the Type "A" Leak Rate Test every 3-1/3 years.
E R_ELIEF REQUEST BASIS Number: H-6 .
System: Reactor Water Cleanup Line: Discharge (CUW-55)
Safety Class: 2 Function: Return demineralized water to reactor coolant.
, Bases for Relief: The portion of CUW-55 between V12-63 and V12-62 cannot be isolated from the Safety Class 3 line CUW-54. Extending the 1.25 x Pd (2375 psig) test boundary beyond V12-63 would over pressurize CUW-54, which require testing at 1.25 x Psv (1813 .
psig). ' -
Alternate Testing:- The portion of CUW-55 between V12-63 and V12-62 will be included in the 1.25 Psv test of CUW-54.
H-53
~-
RELIEF REQUEST BASIS Number: H-7 System: _ WCI, RCIC Line(s): FPCI 15A RCIC 8A Safety Class: 2 Function: FPCI~and RCIC Pump Discharge to Feedwater System i
!~
. Basis For Relief: Portions dowastream of HPCI MOV 23-19 and RCIC K)V 13-21 are ncn-isolable from feedwater piping.
4 Alternate Testing: These lines will be tested during the feedwater system test.
RELIEF REQUEST BASIS Number: H-8 System: Service + Instrument Air Line(s): Full System r Safety Class: 2 -
i j Function: Forms part of Primary Contain.nent Isolation System.
l Basis for Relief:
- Safety function of the piping is to contain primary containment
, atmosphere. Piping integrity in this service is adequately
(
demonstrated by periodic pneumatic leak rate testing.
Alternate Testing: Containment Isolation portions of this system are tested to 44 psig during the Type "A Leak Rate Test every 3-1/3 years.
H-54 IWlas _. __ . _ _ _ _ . _ _ , _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ . _ _ _ @
RELIEF REQUEST BASIS Number H.9 Syste"la Atmospheric Control Line(s). Full System Safety Class: 2 Function: Forms part of Primary Containment Isolation System.
Basis for Relief Safety Function of the piping is to contain primary contain-ment atmosphere. Piping integrity in this service is ade-quately demonstrated by periodic pneumatic leak rate testing.
Alternate Testing, Containment Isolation Portions of this system are tested to 44 psig during the Type ~A~ Leak Rate Test every 3-1/3 years.
RELIEF REQUEST BASIS Number: H-10 System s Sampling Line(s): Containment Air Safety Class: 2+3 Function Forms part of Primary Containment Isolation System.
Basis for Relief: Safety Function of the piping is to contain primary contain-ment atmosphere. Piping integrity in this service is ade-quately demonstrated by periodic pneumatic leak rate testing.
Alternate Testing: Containment isolation portions of this system are tested to 44 psig during the Type "A" Leak Rate Test every 31/,3 years.
H-55 s 5 __ _ . . .
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. U RELIEF REQUEST BASIS Number: H-11 System: Containment Air Dilution Line(s): Portions of system from Primary Containment penetration to the second outboard isolation valve.
Safety Class: 2 Function: Forms part of Primary Containment Isolation System.
p Basis for Relief: Safety function of the piping is to contain primary contain-ment atmosphere. Piping integrity in this service is ade-quately demonstrated by periodic pneumatic leak rate testing.
. Alternate Testing: Containment Isolation portions of this system are tested to-44 psig during the Type **A" Leak Rate Test every 3-1/3 years.
RELIEF REQUEST BASIS Number: H-12 System CR0 Hydraulic Line(s): Drive Water, Charging Water and Cooling Water,-
Piping and Hydraulic Contrcl Units Safety Class: 2 Basis for Relief Isolation of this piping for hydrostatic testing would involve repositioning and independent verification of approximately 450 valves before and after the test. The slight increase in reliability assurance provided by a once-
_ per-interval 1.1 x Pd hydro test vice that provided by the much more frequent on-line inspections and surveillance at operating pressures in excess of .1000 psig does. not justify
/ the ' effort required t~o place the' system in the test con-figuration.
Alternate Testing: Primary coolant boundary portions of this piping will experience a hydrostatic test pressure of 1018 psig during the reactor vessel hydro. The balance of the system func-tions at a normal operating pressure of between 1040 and 1500 psig and any evidence of leakage would be detected by routine operator surveillance.
H-56
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-RELIEF REQUEST BASIS' Number: H i. ; System - Standby-Gas Treatment Line(s): Containment purge-lines-to !BGT Units.
QI
. Safety. Class: 2'-
Function:' ' Forms part of. Primary Containment Isolation System.
- Basis-for Relief -Safety' function of the piping is to limit airborne fission
,- product release to environment. Piping integrity in this service is adequately demonstrated by periodic pneumatic g leak rate testing..
Alternate Testing: Containment isolation portions of this system are tested to 44.psig during the Type "A Leak Rate Test every 3-1/3 years.
Duct work portions of system. are outside the scope of the code.
RELIEF REQUEST BASIS
' Number: H-14 -
. Systems . Service Water Line(s): Supply piping between valves V70-5A and 58. ,
Common return piping for redundant trains of plant -
safety systems.
Safety Class: 3
, Function: Supply piping between valves V70-5A + 58 provides pressuri-zation for Fire Protection System. Return piping provides removal of plant waste heat.
> Basis for Relief: Isolation of this supply piping for testing would simulta-l~ . neously exclude the Fire Protection System from pressuriza-tion by the Service Water pumps and the' station Lfire water pumps, effectively disabling the Fire Protection System for
+
. the duration of the test. Isolation of the common return piping.would disable both trains of several plant safety systems for the duration of the test. At least one train of these systems must be operable, or available to operate,
- during all mcdes of plant operation, and Service Water is required to remove waste heat resulting from their opera-
- tion.
- Alternate Testing: Since the Service Water System runs approximately 100% of
- the time, routine operator surveillance would detect evi-dence of leakage from visible portions of the system.
H-57
. a_ + . .
RELIEF REQUEST BASIS Number: H-15 -
System: A0G Line(s): Guard Beds and Absorbers
[ ' Safety Class: 3 Basis ' for ' Relief: Gaseous Radwaste System must continuously operate during all modes of station operation and cannot be isolated for testing.
' Alternate Testing: System operates under vacuum. In-leakage would result in increased flow which would be detected by flow elements located downstream of vacuum pumps.
A h
RELIEF REQUEST BASIS Number: H-16 System: Recirc Pump Seal Purge System Line(s): All Safety Class: 2 Function: Forms parts of Primary Containment Isolation System.
Basis for Relief: Safety function of the piping is to contain primary contain-ment atmosphere. Piping integrity in this service is ade-quately demonstrated by periodic pneumatic leak rate 1 testing.
k Alternate Testing: Containment Isolation portions of this system are tested to 44 psig during the Type "A" Leak Rate Test every 3-1/3 l years, and type "C" Leak Rate tested every year.
4 l
H-58
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RELIEF REQUEST BASIS Number, H_17 System. WCI Line. Condensate suction, from MOV RCIC- WCl-17 and RCIC-18 to check valves immediately downstream.
Safety Class 2 and 3 f Basis for Relief. Piping cannot be effectively pressurized from HPCI/RCIC side h
due to blockage by check valves, and cannot be pressurized from CST side due to check valves opening on flow from CST.
Alternate Testing, Since MOV WCI-17 and RCIC-18 and associated CST manual shut
-off valves are normally open, this piping experiences a constant static head of 6-25 psig from the Condensate Storage Tank. Piping is not insulated and leakage would be visible during routine surveillance and operator rounds.
RELIEF REQUEST 8 ASIS -
Number: H-18 System: High Pressure Coolant Injection Reactor Core Isolation Cooling Linels): 125 Pd WCI Steam Supply Line MS-48 from turbine stop valve to tur-bine casing.
1250 Pd WCI Steam Drain Lines 1250 Pd RCIC Steam Supply Line MS-58 from Muvl3-131 to Turbine Casing.
n Safety Class: 2 and 3
[
t Requirement Pressure test at 1.25 x Pd per IWC-5222(aj or IwD-5223(a)
, Basis for Relief Piping cannot be effectively isolated from 150 Pd turbine
. < , casing and.exha'ust lines. _ .
Alternate Testing. Piping will be included in the 188 psig pressure test of the turbine casing and exhaust lines.
H-59
RELIEF REQUEST BASIS Number: H-19 System s RHR Linese RHR-13A and 138 between valves V10-69A and 69B and V10-16A and 168.
Safety Class 2 Function: Minimum flow bypass for.RHR pumps Basis.for Relief, . Piping contains no test connection for pressurization.
} Opening of V10-69A and 698 places this piping in com-a munication with lower-pressure RHR suction piping through
( the centrifugal RHR pumps, while piping downstream of V10-16A and 166 is open-ended to the torus.
t Alternate Testing: This piping will be included in the lower-pressure pump suc-tion hydro.
RELIEF REQlEST BASIS -
Number e H-20 System. CRD Scram Discharge Line(s)e Entire System Headers, Instrument Volumes and Associated Piping Function: Receive .CRD discharge water during reactor scram.
Basis for Relief: Table IWC - 2500 - 1 requires a functional test per IWC-5221 once each inspection period. This system would receive a functional test only during reactor scrams. Since the Ver-mont Yankee FSAR limits the number of scrams permitted dur-
- ing the life of the plant, Vermont Yankee has discontinued l the practice of initiating manual scrams at each refueling outage. Consequently, although it is unlikely, a reactor scram may not be experienced once each inspection period.
Alternate Testing. Visual inspections conducted by operators following reactor scram events would detect any evidence .of leakage from this. .
piping.
H-60
RELIEF REQUEST BASIS Number H-21
. System. CR0 Scram Discharge Line(s). Eighty-nine (89) 3/4**
Headers, Instrument scram discharge lines, Volumes and Associated between scram outlet Piping. valves ar.d V13-ll2 manual valves.
Function. Transport CR0 discharge water to discharge headers during reactor scram.
Basis for Relief: General Electric Company recommends not pressurizing against the scram outlet valves to a pressure of 1563 psig, to avoid possible damage. Since there is only one check valve bet--
ween the scram outlet valves and the manual valves, it is prudent to close the eighty-nine (89) manual valves prior to pressurizing the Scram Discharge Headers, Instrument Volumes and associated 3/4 discharge piping to 1563 psig.
Alternate Testing: Hydro test is required only once every ten years. Reactor scrams occur more frequently, and this piping is subjected to reactor pressure during scram events. Evidence of -
leakage would be visible during post-scram visual inspec-tions by operators.
4 9
6 en 4
H-61 f
Relief Request Basis NUMBER: ' ~ P1
. SYSTEM: Service Water
- PUMP: P7-1A-D CLASS: 3'
_ TEST REQUIREMENT: Bearing temperature per IWP-3300 BASIS FOR RELIEF: - Service water pump bearings are physically submerged under a minimum of 30 feet of river water. Contact pyrometer raadings would be impractical.
ALTERNATIVE TESTING: None k
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k P - 3 Rev. 8
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Relief Request Basis NUMBER: P2 SYSTEM: Service Water PUMP: P7-1A-D CLASS: 3 TEST REQUIREMENT: Quarterly testing per IWP-3100 BASIS FOR REQUEST: Flow is calculated using a computer program which fits a head / capacity curve from the data inputs. Since flow can not be throttled or differential pressure cannot be fixed, (dependent on river water levels and temperatures) the data
- received from the computer may not be a true indication of the pump's performance. Vibration levels are also subject to change since the reference parameter of differential pressure cannot always be achieved.
ALTERNATE TESTING: Each refueling outage one pump will be taken out of service and overhauled for preventive maintenance. Quarterly readings will continue to be taken, recorded, and analyzed for trends to the degree possible.
P - 4 Rev. 8
s
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. J Relief Request Basis t
.I NUMBER: P3 SYSTEM: . Residual Heat Removal Service Water li.
PUMP: P8-1A-D.
CLASS: 3 -
TEFT REQUIREMENT: . Bearings temperature per IWP-3300
- BASIS FOR RELIEF: ' Bearings are internal to the pump casing and are inaccessible for. temperature measurements'. Contact.
pyrometer would not be feasible since the casing is large and *
-would quickly dissipai.2 the heat.
- ALTERNATIVE TESTING: .None.
i 4
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- P - 5 Rev. 8 .
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.I Relief Request Basis NUMBER: P4 i
SYSTEM: Residual Heat Removal
~
PUMP: P10-IA-D
~ CLASS: 2 f- ,
TEST REQUIREMENT: Bearing temperature per IWP-3300 BASIS FOR RELIEF: Bearings are internal to the pump casing and are inaccessible for temperature measurements. Contact pyrometer would.
not be feasible since the casing is large and would quickly -
dissipate the' heat.
ALTERNATIVE' TESTING: None.
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P - 6 Rev. 8 e b 4. e .N
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Relief Request Basis tGMBER: PS; SYSTEM: High Pressure Coolant Injection PUMP: ~ P44-1A'
- CLASS: 2
-TEST REQUIREMENT: Bearing temperature per IWP-3300 BASIS FOR RELIEF: Bearings are internal to the pump casing and.are inaccessible for temperature measurements. Contact pyrometer would not be feasible since the casing is large and would quickly
-dissipate.the heat.
ALTERNATIVE TESTING: None.
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P - 7 Rev. 8
._ - : p _. . a _.._; _:_. ~ .- . . _ - -
r ,s2 Relief Request Basis s .
NUMBER: P6 SYSTEM: Standby Liquid Control PUNP: -P45-IA/B CLASS: 2~
TEST REQUIREMENT: Bearing temperature per IWP-3300 BASIS FOR RELIEF: Bearings are internal to the pump casing and are in' accessible for temperature measurements. Contact pyrometer would not be feasible since the casing is large and would quickly .
dissipate the heat.
ALTERNATIVE TESTING: None.
1 1,
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/- P - 8 Rev. 8
b Relief Request Basis NUMBER: P7 l SYSTEM: -Standby Liquid Control PUMP: P45-1A/B CLASS: 2 TEST REQUIREMENT: Reference values per IWP-3100, fable 3100-1 BASIS FOR RELIEF: In accordance with Table IWP-3100-1, flow will be-measured from flow element FI-11-1.
This parameter will be estab-lished as the reference value and trends analyzed per IWP-3100.
Differential pressure will not be measured as-it is variable-since suction is from a vented tank. Inlet pressure will only be measured to assure that there is liquid in TK-21-1A, as not to damage the pumps.
ALTERNATIVE TESTING: Continue testing and analysis of flow and e vibration results per IWP-3200.
i
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P - 9 Rev. 8 A .
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. Relief Request Basis NUMBER: P8 SYSTEM: , Core Spray l-PUMP: P46-1A/B CLASS: 2 J: . TEST REQUIREMENT: Bearing temperature per IWP-3300 n
BASIS FOR RELIEF: Bearings are internal to the pump casing and are inaccessible for temperature measurements. Contact pyrometer would not be feasible since the casing is large and would quickly dissipate the heat.
ALTERNATIVE TESTING: None.
4 1
j:-
P - 10 Rev. 8
. - .- -_n . . . . _ - . _ _ _ _. . _ . . . . _ . _ -. . , _ - , _ . _ _ _ _ . . - ~ _ . _ _ _
Relief Request Basis
' NUMBER: P9 SYSTEM: Reactor Core Isolation Cooling
- PUNT: P47-1A
' CLASS: 2
' TEST REQUIREMENT: Bearing temperature per IWP-3300 BASIS FOR' RELIEF: Bearings are internal to the pump casing and are
. inaccessible for temperature measurements. Contact pyrometer-would not be feasible since the casing is large and would ,
quickly dissipate the heat.
ALTERNATIVE TESTING: None.
s:
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i -
P P - 11 Rev. 8 li
i Relief Request' Basis NUMBER: P10 SYSTEM: Reactor Building Closed Cooling Water i
PUMP: P59-1A/B j . CLASS: 3 b TEST REQUIREMENT: Proper lubrication level and or pressure per IWP-3110 Table IWP-3100-1.
BASIS FOR RELIEF: Pump has grease packed bearings and therefore.
cannot be checked.
ALTERNATIVE TESTING: None.
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P - 12 Rev. 8 y y- m,- + r w 4- eJmW,-- .gy 9-=y s
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q-Relief Request Basis ,
NUMBER: - Pil
- SYSTEM: Reactor Building Closed Cooling Water
' PUMP: P59-1A/B i CLASS: 3-TEST REQUIREMENT: Inservice' test quantities per IWP-3100, Table IWP-3100-1 BASIS FOR RELIEF: Table IWP-3100-1 specifies the In' service' Test Quantities
'to be measured or observed. 'For these pumps, there is no method available.
'for measuring flow. Differential pressure varies due to the distribution
- of' cooling water to'the various loads as regulated by temperature and pressure control valves in the system. ' Inlet pressure also cannot be measured before the pump test since the pumps are normally running. The-vibration lev'els are also subject tio change .since the reference para-
. ineters cannot always be achieved .
ALTERNATE TESTING: Monthly readings will continue to be taken, recorded .
~
and analyzed for trends to the degree possible.
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J l P - 13 Rev. 8 i.
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- m. -
A Relief Request Basis NUMBER: ~ P12 SYSTEM: Fuel Oil Transfer ,
' PUMP:
~ P92-1A/B CLASS: -3 TEST ~ REQUIREMENT: Bearing temperature per IWP-3300 BASIS FOR RELIEF: Per IWP-3500, bearing temperature measurements ,
require that each pump be run until the bearing temperatures stabilize... A bearing temperature is considered stable when three -
successive readings taken-at ten minute intervals do not vary by
- more than 3%. The fuel oil transfer pump operability test can only.
be performed when the diesel is undergoing testing. ' When low level is sensed in the day tank, the fuel oil transfer pumps provide the
. make-up. This normally-takes less than 15 minutes. This is not-sufficient time'to record a meaningful bearing temperature.
~
ALTERNATIVE TESTING: None.
- ; 6 p
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P - 14 Rev. 8 t ,
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Relief Request Basis NUMBER: P13 i: SYSTEM: Fuel Oil Transfer. .
PUMP: P92-1A/B 1:
CLASS: 3 TEST REQUIREMENT: Proper lubrication and or pressure per IWP 3110 Table IWP-3100-1 BASIS FOR RELIEF: Pump has grease-packed bearings and therefore. ,
cannot be checked.
ALTERNATIVE TESTING: None.
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P - 15 Rev. 8
R P
Relief Request Basis
- 4
. NUMBER: P14 SYSTEM: Fuel Oil Transfer-CLASS: 3 TEST REQUIREMENTS: Differential pressure and flow measurements per IWP-3100, Table IWP-3100-1.
BASIS FOR RELIEF: Fuel oil pumps are positive displacement pumps which are in a fixed resistance system. Per Table IWP-3100-1, Note'1, it is required to measure differential pressure or flow rate. There is -
no method available for measuring flow. Differential pressure varies with the amount ofcfuel in the diesel fuel storage tank, TK-40-1A.-
The differential pressure is also subject to viscosity changes of the fuel oil due to seasonal temperature variations. These variations are not indicative of positive displacement pump performance.
ALTERNATIVE TESTING: Measure discharge pressure in lieu of differential pressure and take corrective action if the discharge pressure-falls below a calculated reference value, which is the amount of ' discharge pressure _necessary to supply fuel oil to the day tanks.
P - 16 Rev. 8
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Relief Request Basis Number: -
"[ Code Paragraph: Table IWP-3100-2 Basis For Relief:
A thorough review of 'past operating surveillance data and continuing difficulty in obtaining consistent data indicates a need to re-evaluate the ranges specified in the code paragraph listed above. There are many causes for the difference oin readings which have no relation to pump degradation.
Differences in the manner by which gauges or meters are read, accuracies associated with each instrument, the affect on the instrument system due to the inaccuracies of each component all contribute to readings that are out of specification by more than than 2% allowed by the code.
The nature of the test method required by ASME XI also contributes to.the inconsistent data. When establishing the fixed parameter, there can be no tolerance since errors here will compound the error in reading the variable
- parameter. Because of the instrument inaccuracies and the test method, the -
data of ten unjustifiably falls into the required action level of ASME XI.
These test method induced discrepancies are not syptomatic of a pump failure.
Based on our experience in surveillance testing since commercial operation in 1972, the ranges proposed in the following section represent reasonable and expected deviations of the pump parameters. The proposed changes only expand the range in the more conservative direction, i.e.,
allowing more flow or a higher differential pressure. 'These ranges are consistent with our Safety Analysis in that they do not lower the minimum flow or discharge pressure required.
Alternative:
The high end of the various ranges will be adjusted upward as indicated in the following table:
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Parameter Acceptable Alert Action
-Q .94 - 1.08 . 90 - <.94 <.90
>1.08 - 1.12 >1.12
- AP' .93 - 1.08' ' 90'- <.93~
. <.90
>1.08 - 1.12 >1.12 .
P - 17 Rev. 8 4
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RELIEF REQUEST BASIS IU EER. y1 SYSTEM: Service Water VALVE: V70-1A-D CATEGORY: C t
CLASS: 3
!, FUNCTION: Service Water Pump Discharge Check Valves
' TEST REQUIREMENT: CV BASIS FOR RELIEF: During sumer operation, all four (4) service water pumps are required for plant operation. The shutting down of a pump for check valve testing is not practical. Also, during the remainder of the year, three (3) of the four (4) pumps are used in plant operation. The pumps are routinely rotated .
. when possible.
ALTERNATE TESTING: Valves will be exercised as pumps are rotated in' service upon startup. Proper pump operation will indicate proper opening of the check valves. Absence of pump runback or system pressure loss as noted by operations personnel will indicate proper closure of the check valves.
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. Rev. 8
{. V-30
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V s-_ RELIEF REQUEST BASIS NUMBER: V2 SYSTEM: Reactor Building Closed Cooling Water VALVE V70-113 CATEGORY C CLASS: 2 FUNCTION: RBCCW to containment check valve TEST REQUIREENT: CV i-BASIS FOR RELIEF: Valve is required to be open during power operation.
Shutting the valve would stop cooling water flow to vital
, containment equipment.
ALTERNATE TESTING: Valve will be verified shut during cold shutdowns and .
refueling outages.
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i n-
1 RELIEF REQUEST BASIS NLAGER V3 SYSTEMS. Reactor Building Closed Cooling Water VALVE V70-117 CATEGORY: B CLASS, .2 FUNCTION: RBCCW return isolation valve TEST REQUIREENT: Q BASIS FOR RELIEF: Valve cannot.be exercised during power operation since closing the valve would stop cooling water flow to vital con-tainment equipment.
ALTERNATE TESTING: Valve will be full stroke exercised during cold shutdowns and .
refueling outages.
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Rev. 8 V-32
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RELIEF REQUEST BASIS NUMBER: V4 SYSTEM: Recirculation pump VALVE: 2-2-7AA,2-2-8AA CATEGORY: C CLASS: 2 FUNCTION: Excess flow check valves for instrument isolation TEST REQUIREENT: CV BASIS FOR RELIEF: Valves can only be verified to shut by leak testin performed during the refueling outage hydrostatic gtest. which is Valves cannot be exercised shut during power operation since shutting these would isolate instrumentation required for power operation.
ALTERNATE TESTING: Valves will be functionally tested each refueling outage.
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Rev. 8 V-33
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RELIEF REQUEST BASIS NUMBER: V5
' SYSTEM: Service and Instrument Air VALVE: V72-38A/B, V72-898/t, V72-103 CATEGORY: A i
cum, 2 FUNCTION: Primary Containment Isolation TEST REQUIREMENT:- LT BASIS FOR RELIEF: Primary containment isolation valves are covered by 10 CFR 50, Appendix J, via Technical Specification Section 4.7.2 ALTERNATE TESTINGr Leak testing in accordance with Appendix J.
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t Rev.' 8 V-34
.. .. . , . . _ , , _ . , . _ . . , - . . . , _ , . , . . . , . _ - - _ . , . . . . , ~ , ,-..,.......,,,-.-..m ,. , . -
RELIEF REQUEST BASIS NUMBER: V6 SYSTEM: Service and Instrument Air VALVE: V72-898/t CATEGORY: C -
CLASS:- 2 -
) FUNCTION: Primary Containment Isolation 3
i TEST REQUIREENT: CV BASIS FOR RELIEF: Valve cannot be exercised during power operation since ?
closing the valve could cause the air operated main steam isolation valves to close, resulting in a reactor scram.
ALTERNATE TESTING: Valve is verified open during normal system operation. Valve is verified closed during leak testing in accordance with Appendix J.
4 a
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Rev. 8 l V-35 i
l a . - . . _ -_ , . _ _ . ~ , - , . - - . . _ . . _ _ . __,-,,_ . _ - - . . . - . , . _ , - - , , - _ - - - _ , . - - , , - , - - - . , , , , -
RELIEF REQUEST BASIS NUMBER, y7 SYSTEM: Nuclear Boiler )
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VALVE: SR 2-14E-L CATEGORY: C CLASS 3 i
j FUNCTION: Relief Valve Discharge Line Vacuum Breaker l
TEST REQUIREENT: 'CV l BASIS FOR RELIEF: Valves cannot be exercised during power operation since .
valves are inside the drywell and are inaccessible when at power.
ALTERNATE TESTING: Valves will be manually exercised during cold shutdown. -
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d-e Rev. 8 V-36 n ,, , , . - g, e .- - -t-.-_,, ,.mn, .,, -, -,e , -a,.-- , , ,, r,-----w,, ,-n.-- - , , , - -n
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RELIEF REQlEST BASIS NLMIER: V8 SYSTEM: Nuclear Boiler VALVE: V2-27A, V2-39, V2-40, V2-74, V2-77, V2-80A-D, V2-86A-D, V2-96A CATEGORY: A CLASS: 1 FUNCTION: Primary Containment Isolation TEST REQUIREMENT: LT BASIS FOR RELIEF: Primary containment isolation valves are covered by 10 CFR 50, Appendix J, via Technical Specification Section 4.7.2 ALTERNATE TESTING: Leak testing in accordance with Appendix J.
9 i
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- Rev.'8 V-37 -
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RELIEF REQUEST BASIS NUMBER.- .V9 SYSTEM. Nuclear Boiler VALVE. V2-28A/B CATEGORY. A
- CLASS. 1
! FUNCTION: Primary Containment Isolation TEST REQUIREMENT: LT BASIS FOR RELIEF: Valves presently exempted, per Technical Specification Sec-tion 4.7.2, from leak testin'g.
. ALTERNATE TESTING. None 4
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Rev. 8
- V-38
%w. * * <6 e w,n+--,, y- , , -,,y-i..-. ,,y mg_ n --e -,-pyg ,-,-
RELIEF REQUEST BASIS NU6eER: V10 SYSTEM: Nuclear Boiler.
VALVE: . V2-53AA,V2-54A4 CATEGORY: B
, COM: 1
- FUNCTION: Recirculation pump discharge and bypass valve - required for
- j. LPCI operation.
TEST REQUIREENT: Q i
BASIS FOR RELIEF: Valve exercising during power operation would require a reac-tor trip.
ALTERNATE TESTING: Valves will be full stroke exercised during cold shutdowns of duration greater than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> and during refueling outages.
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.Rev. 8 V-39 l
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RELIEF REQUEST BASIS NUMBER: yll SYSTEM: Nuclear Boiler VALVE: RV2-71A-D, SV2-70A/B CATEGORY: C CLASS: 1 FUNCTION: Automatic Depressurization/t)verpressure Protection TEST REQUIREENT: SRV (IW-3511)
BASIS FOR RELIEF: The present program for testing main steam relief and safety valves as described in the Vermont Yankee Inservice Inspec-tion Program is more conservative than the test frequency described in IW-3511. Per the ISI Program, all che main steam relief and safety valves are tested every two refuel outages. The valves that are removed each refuel outage for testing are either tested and replaced or replaced with a previously tested spare valve. In the case where the valves are replaced with a previously tested spare, the removed valves are not tested for as-found conditions until a con-venient time after the refuel outage is over. This would make the additional testing as described in IW-3513 un-reasonable, since the plant would be operating before it could be determined whether the removed valve fails to func-tion properly or not.
. ALTERNATE TESTING: Continue to test the main steam relief and safety valves per the requirements of the Inservice Inspection Program.
s 5
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Rev. 8 V-40
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RELIEF REQUEST BASIS l
l I
NUEER: V12 SYSTEM: Nuclear Boiler VALVE: RV2-71A-D CATEGORY: B CLASS: 1 FUNCTION: Automatic Depressurization
}
TEST REQUIREMENT: Q BASIS FOR RELIEF: Valves cannot be exercised during power operation since failure in the open position would require tripping the reac-tor. Also, live steam would be discharged to the suppression pool which would heat the water and pressurize the contain '
ment. Valves cannot be exercised during cold shutdowns since .
steam is required to stroke the main piston in the valve.
Based on the following references, the testing of each relief valve at a frecniency of once per operating cycle is assessed to be adequate by Vermont Yankee and the industry. In a letter from Brian K. Grimes of the NRC to All Boiling Water Reactor Licensees dated July 16, 1979 regarding relief and safety-relief valves, it states that *we have concluded that
, implementation of a requirement for increased surveillance testing would not be the most effective way of assuring safety-relief valve reliability.' Also referenced is a -
letter from Darrel G. Eisenhut of the EC to All Operating Reactor Licensees dated May 7, 1980 regarding the Five Addi-tional TMI-2 Related Requirements to Operating Reactors.
Item II.K.3.16 entitled Reduction of Challenges and Failures of Relief Valves - Feasibility Study and System Modification states that, 'Those changes which are shown to reduce relief 5
valve challenges without compromising the performance of the relief valves or other systems should be~ implemented." Ver-mont Yankee's response to an K C suggested Tech. Spec. change
- dated February 2,1978 states that "Both Gener&1 Electric
- ,- ' Company and Target Rock strongly recommend that these valves
, be manually operated only when absolutely necessary. .The. .
only time we consider to be absolutely necessary, other than if plant conditions warrant, is once a cycle."
ALTERNATE TESTING: During power ascension after a refueling outage, each relief valve will be manually opened to full stroke with the reactor at low pressure until the thermocouple downsteam of the valve indicates fluid is flowing from the valve.
Rev. 8 i
V-41 g.w4 4 -
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= _ _ . . . . .- - - . - . . . .
RELIEF REQlEST BASIS
, NUMBER: V13 SYSTEM: Nuclear Boiler
~ VALVE: V2-278,.V2-968 CATEGORY: .C CLASS: 2 FUNCTION: Feedwater Checks for IPCI/RCIC Operation TEST REQUIREENT: CV BASIS FOR RELIEF: Valves are rea'Jired to be open during power operation.
' Shutting these valves will cause a reactor trip. Testing via the PCI/MCIC systems would cause thermal shocking of the feedwater nozzles and could result in damage to reactor internals. Testing the valves during cold shutdown would .
require removing the only mechanism of vessel level control (via reactor cleanup system).
4 ALTERNATE TESTING: Valves will be verified shut during the refueling outages.
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O Rev. 8 V-42 4
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RELIEF REQUEST BASIS NUMBER: V14 SYSTEM: Nuclear Boiler VALVE: 2-62-A-D, 2-64-A-D, 2-73-A-H, 2-301 C/b, 2-305 AA3 CATEGORY: C CLASS: 2 FUNCTION: Excess Flow Check Valves for Instrument Isolation TEST REQUIREMENT: CV BASIS FOR RELIEF: Valves can only be verified to shut by leak testing which is performed during the refueling outage hydrostatic test.
Valves cannot be exercised shut during power operation since shutting these would isolate instrumentation required for power operation.
ALTERNATE TESTING: Valves will be functionally tested each refueling outage.
t-4 Rev. 8 V-43 i
1
RELIEF REQLEST BASIS NJMBER V15-SYSTEM: Core Spray VALVE: V14-13A/B.
CATEGORY: C CLASS: 2
} FUNCTION: Injection Check Valve 3 TEST REQUIREENT: CV BASIS FOR RELIEF: Valves cannot be exercised manually since valves are located c
inside the primary containment. Valves cannot be exercised with flow since pump discharge pressure cannot overcome reac-tor pressure.
~ ALTERNATE TESTIKi These valves will be manually full stroke exercised during cold shutdowns when the drywell is accessible and during refueling outages.
i ..
h 9 4 Rev. 8 V-44 4
- t
- - - + , .r %.,wi .,m,-m-_y,. .-_,..m_.-..e,_-r.... -_,.--~-~e.,- -.,, ,.,,,-r--,,, , , - - - ,.m_.., _ . -,.,-, _ , . - _ . - - - _ - -
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( l RELIEF REQUEST BASIS <
NUMBER: V16 '
j SYSTEM: Core Spray ,
VALVE: 14-31A/B
. CATEGORY: .C .
4 2' ' '
CLASS:- '
FUNCTION: Excess flow check valves for instrument isolation TEST REQUIREENT: CV BASIS FOR RELIEF: Valves can only be verified to shut by leak testing ich is performed during the refueling outage hydrostatic test.
Valves cannot be exercised shut during power operation since' shutting these would isolate' instrumentation required for power operation. .
ALTERNATE TESTING: Valves will be. functionally tested each refueling outage.
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Rev.-8 V-45 l
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RELIEF REQUEST BASIS
.e,. NUMiER e V17 s
SYSTEM: High Pressure Coolant Injection VALVE: . V23-15, V23-16
' CATEGORY:. A
, CLASS: 1 FUNCTION: IPCI Steam Line Isolation 4
TEST REQUIREMENT: LT F
BASIS FOR RELIEF: Primary containment-isolation valves are covered by 10 CFR 50, Appendix J, via Technical. Specification Section 4.7.2.
ALTERNATE TESTING: Leak testing in accordance with Appendix J.
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Rev. 8 V-46
RELIEF REQUEST BASIS NUM3ER: Vl8 SYSTEM: High Pressure Coolant Injection VALVE: V23-18 CATEGORY: C
- CLASS
- 2 i
FUNCTION: Injection check valve TEST REQUIREMENT: CV f BASIS FOR RELIEF: Valve cannot be exercised during power operation since flow through this valve must be injected into the reactor coolant system. This would thermally shock'the reactor nozzles. The cold water injection would also cause a reactivity excursion.
Manual valve operation is not possible during power operation .
since the valve is located in the steam tunnel which is unac-
. cessible.
ALTERNATE TESTING: Valve will be manually fully stroke exercised duri.% cold shutdowns and refueling outages.
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Rev. 8 V-47
f RELIEF REQUEST BASIS NUMBER . . V19 L SYSTEM: High Pressure Coolant Injection .
VALVE: SL23-37A-0 CATEGORY: C CLASS: 2 j
FUNCTION: . Excess flow check valves for instrument isolation TEST REQUIREENT: CV -
BASIS FOR RELIEF: Valves can only be verified to shut by leak testing which is performed during the refueling outage hydrostatic test.
Valves cannot be exercised shut during power operation since shutting these would isolate instrumentation required for.
power operation.
ALTERNATE TESTING: Valves will be functionally tested each refueling outage.
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.h e Rev. 8 V-48
- ,- . ...c.,,____,,,__..., _ _ _ __ ,:_ ,:_ .,_. _ __.._ _ _ ., _ __ _ ,._... .,_._ _ ,._. _ ,
RELIEF REQ E ST BASIS NUMBER: V20 SYSTEM: High Pressure Coolant Injection VALVE: V23-61 CATEGORY: C CLASS: 2 FUNbTION: Torus suction check valve TEST REQUIREENT:- CV
- BASIS FOR RELIEF: Valve cannot be full stroke exercised during power operation since there is no full ficw test loop available to recir-culate the water back to the torus. There are no means to manually stroke the valve. Yalve cannot be stroked via a system injection into the reactor since that would result in .
a reactivity excursion and potentially thermally shocking the
, reactor nozzles.
ALTERNATE TESTING: Valve will be verified to open freely each cold shutdown and refuel outages.
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- A Rev. 8 V-49
. - _ _ - . - . . _ - - - - . - . . . - . - . . . - - _ . . _ - . . - _ - _ . - . ~ - - -
RELIEF'REQESTBASIS lO GER: V21 SYSTEM - Control Rod Drive Hydraulic
- VALVEe V3-13-114, V3-13-126, V3-13-127 CATEGORY: B or C
- CLASS . 2
{ FUNCTION: Control rod drive scram TEST REQUIREMENT: Q or CV 1
{ ~ BASIS FOR RELIEF: Exercising these valves during power operation would require scramming the plant or an undesirable reactor transient.
ALTERNATE TESTING: Since scram insertion times are representative of valve operability and stroke times, alternate testing will be per-formed in accordance with Tech. Spec. Section 4.3.C.1 and 2.
This section requires that all control rods be subjected to scram-time measurements on a refueling outage basis. Also, this section requires that 50% of the control rods be measured for scram times every 16 to 32 weeks. An evaluation is required that provides reasonable assurance that proper control rod drive performance is being maintained. These test adequately verify valve operability and stroke times.
a 5
i l-l Rev. 8 l V-50
RELIEF REQUEST BASIS NUMBER: V22 SYSTEM: Control Rod Drive Hydraulic VALVE: V3-181 CATEGORY: C CLASS: 3 FUNCTION: CR0 Return to RWCU System TEST REQUIREMENT: CV BASIS FOR RELIEF: Valve cannot be exercised during power operation since this would require isolating and venting a portion of the CRD system. This would cause hydraulic instability throughout the system. This situation is potentially unsafe until the system can be rebalanced and the rod strokes retimed. This ,
cannot be done during power operation.
ALTERNATE TESTING: Valve will be verified to close during cold shutdown.
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9 Rev. 8 V-51
RELIEF REQUEST BASIS NUMBER: V23 SYSTEM: Control Rod Drive Hydraulic VALVE: V13-162A/B CATEGORY: C CLASS 3 FUNCTION: Scram Discharge Volume Vent Check Valves TEST REQUIREENT: CV BASIS FOR RELIEF: Valves cannot be exercised during power operation since this would require taking the CRD system out of service. Operabi-lity of these valves is demonstrated by decreasing scram discharge volume water level upon reset from SCRAM.
ALTERNATE TESTING: None 6
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RELIEF REQUEST BASIS NUDEERe V24
- SYSTEM. Standby Liquid Control
-VALVE: Vll-16, Vll CATEGORY: A-CLASS: 1' FUNCTION Primary Containment Isolation TEST REQUIREMENT: LT i
BASIS FOR RELIEF: Yalves presently exempted, per Tech. Spec. Section 4.7.2 from leak testing.
ALTERNATE TESTING: None E
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1 Rev. 8 V-53 L- ._. . . _
RELIEF REQUEST BASIS NUMBER: V25 SYSTEM: Standby Liquid Control VALVE: V11-16, V11-17
- CATEGORY
- C CLASS: 1 i
- i FUNCTION: SLC Injection into Reactor TEST REQUIREMENT: CV BASIS FOR RELIEF: Exercising these valves during power operation would require injecting borated water into the reactor coolant system.
This would create a reactivity excursion and potential for reactor trip. Injection of demineralized water would require removing the system from service to clean the barated solu- '
tion from the piping and replacing the explosive actuated valves. This system is required for power operation.
ALTERNATE
" TESTING: Valve operability will be demonstrated each refuel outage by the system flow test directly into the reactor vessel.
4 4
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RELIEF REQUEST BASIS NLA6CR V26 SYSTEM: Residual Heat Removal
. VALVE: V10-17, V10-18, V10-26AA, V10-31AA, Y10-32, V10-33,
( V10-34AA, V10-38AA, V10-39AA 1
CATEGORY: A ,
CLASS: 1 or 2 FUNCTION: Primary Containment Isolation
- TEST REQUIREENT: LT
[ BASIS FOR RELIEF: Valves presently exempted, per Tech. Spec. Section 4.7.2 from leak testing.
ALTERNATE TESTING: None l
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Rev. 8 V-55
t RELIEF REQUEST BASIS NUDGER: V27 SYSTEM: Residual Heat Removal t
VALVE: V10-17, V10-18 CATEGORY: A CLASS: -- 1 FUNCTION: Primary Containment Isolation j TEST REQUIREMENT: MT BASIS FOR RELIEF: Valves cannot be exercised during power operation since there is a 100 psig interlock that prevents opening these valves during power operation.
ALTERNATE TESTING: Valves will be exerc1E?d during cold shutdowns and refuel outages.
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Rev. 8 V-56
RELIEF REQUEST BASIS NUPEER: V28 SYSTEM: Residual Heat Removal VALVE: V10-46A/d CATEGORY: C CLASS: 1 l
FUNCTION: LPCI Injection Check TEST REQUIREMENT: CV BASIS FOR RELIEF: Valves cannot be exercised during power operation since the valves are located inside the primary containment. Exer-cising the valves by system flow is not possible during power operation since pung discharge is unable to overcome reactor '
coolant system pressure.
- ALTERNATE TESTING
- Valves will be manually full stroke exercised during cold shutdowns when the drywell is accessible and during refueling outages.
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b Rev. 8 V-57
RELIEF REQlEST BASIS NUMBER: V29 SYSTEM: Residual Heat Removal VALVE: V10-89A/B CATEGORY: 8 CLASS: 3 FUNCTION: Flow Control TEST REQUIREENT: MT BASIS FOR RELIEF: Valve is a modulating type valve. Stroke time is not an appropriate reference parameter.
ALTERNATE TESTING: Proper valve operation is verified through normal system ,
operation during the pump tests.
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Rev. 8 V-58 i
7 RELIEF REQUEST BASIS NUMBER: V30 SYSTEM: Reactor Core Isolation Cooling VALVE: V13-15, V13-16 CATEGORY: A CLASS: 1 FUNCTION: RCIC Steam Line Isolation
-TEST REQUIREENT: LT BASIS FOR RELIEF: Primary containment isolation valves are covered by 10 CFR 50, Appendix J, Tech. Spec. Section 4.7.2 ALTERNATE TESTING: Leak testing in accordance with Appendix J. ,
Rev. 8 V-59 m
RELIEF REQLEST BASIS lu eER: V31 SYSTEM: Reactor Core Isolation Cooling VALVE: V13-22 CATEGORY: C CLASS: 2 FUNCTION: Injection Check Valve TEST REQUIREENT: CV BASIS FOR RELIEF: Valve cannot be exercised during power operation since flow through this valve must be injected into the reactor coolant system. This would thermally shock the reactor nozzles. The cold water injection would also cause a reactivity excursion. ,
Manual valve operation is not possible dJring power operation since the valve is located in the steam tunnel which is inaccessible.
ALTERNATE TESTING: Valve will be manually fully stroke exercised during cold shutdowns.
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i Rev. 8 V-60 r
RELIEF REQUEST BASIS NUneER: V32 SYSTEM: Reactor Core Isolation Cooling VALVE: SL 13-55A-D CATEGORY: C i
CLASS:- 2 FUNCTION: Excess flow check valves for instrument isolation TEST REQUIREMENT: CV
- BASIS FOR RELIEF: Valves can only be verified to shut by leak testing which is performed during the refueling outage hydrostatic test.
Valves cannot be exercised shut during power operation since shutting these would isolate instrumentation reouired for power operation.
ALTERNATE TESTING: Valves will be functionally tested each refueling outage.
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b Rev. 8 V-61
t RELIEF REQUEST BASIS NUMER: V33 SYSTEM: Reactor Core Isolation Cooling
. VALVE: V13-40 CATEGORY:- C CLASS: 2 FUNCTION: Torus suction check valve TEST REQUIREENT: VC BASIS FOR RELIEF: Valve cannot be full stroke exercised during power operation since there is no full ficw test loop available to recir-culate the water back to the torus. There are no means to manually stroke the valve. Valve cannot be stroked via a system injection into the reactor since that would result in a reactivity excursion and potentially thermally shocking the reactor nozzles.
ALTERNATE TESTING: Valve will be verified to open freely each cold shutdown and refuel outages.
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Rev. 8 V-62
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RELIEF REQUEST BASIS r.
NUMBER: V34 e
SYSTEM: Reactor Core Isolation Cooling VALVE: Turb. Gov. '
4 CATEGORY: B
' CLASS: 2 FUNCTION: Modulating Valve TEST REQUIREMENT: MT i
BASIS FOR RELIEF: Valve is a modulating type valve. Stroke time is not an appropriate reference parameters.
ALTERNATE TESTING: Proper valve operation is verified through normal system ,
operation during the purrp tests.
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Rev. 8 V-63
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RELIEF REQUEST BASIS MJMBER: V35
-SYSTEM: - Primary Containment and Atmosphere Control VALVE: V16-19-5 A to J
- CATEGORY: A CLASS: -2 FUNCTION: Torus-drywell vacuum breakers TEST REQUIREMENT: LT BASIS FOR RELIEF: Valves cannot be leak tested individually ALTERNATE TESTING: Leak test will be done which will demonstrate that with an initial differential pressure of not less than 1.0 psi, the differential pressure decay rate shall not exceed the equiva
- lent of the leakage rate through a 1-inch orifice.
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- 1 Rev. 8 V-64 4
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RELIEF REQUEST BASIS NUMBER: V36 SYSTEM: Primary Containment and Atmosphere Control VALVE: S316-19-6, SB16-19-6AA, S816-19-7, SB16-19-7AA, SB16-19-8, S816-19-9, S816-19-10, SB16-19-11AA, V16-19-12AA, V16-20-20, V16-20-22AA, V16-19-23 CATEGORY: A
]
CLASS: 2 p FUNCTION: Primary Containment Isolation TEST REQUIREMENT: LT BASIS FOR RELIEF: Primary containment isolation valves are covered by 10 CFR 50, Appenu!* J, via Tech. Spec. Section 4.7.2.
ALTERNATE TESTING: Leak testing in accordance with Appendix J.
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Rev. 8 l V-65 l
. - . .. . - - . - - _ _ . _ = - _- - . -_ - ---_-.-_:
RELIEF REQUEST BASIS NUMBER: V37 SYSTEM: Primary Containment and Atmosphere Control VALVE: 216-19-6, S816-19-8, V16-19-23 CATEGORY: A CLASS: 2 FUNCTION: Primary Containment Isolation TEST REQUIREENT: Q BASIS FOR RELIEF: Valves cannot be exercised during power operation since this would cause the loss of the differential pressure between the drywell and the suppression chamber. This DP is a required condition of plant operation.
ALTERNATE TESTING: Valves will be full stroke exercised during cold shutdowns and refueling outages.
6 + ,
1 Rev. 8 V-66
. _ - . . . - . _ . m. .-_.._m, _ . _ . , ..m... _ . _ , . , _-._ . --. m. _.~ _ . - . , . _ . m.- ., _. ,, . . _ . ~ -..,. ,~,--.. , . - _ , , , _,
. RELIEF REQLEST BASIS ,
NUMBER: V38 SYSTEM: Primary Containment and Atmosphere Control VALVE: V16-19-12A/B CATEGORY: . A, C
' CLASS: 2 j FUNCTION: Primary Containment Isolation
. TEST REQUIREMENT: CV BASIS FOR RELIEF: Vacuum breaker cannot be exercised during power operation since there is no test loop available. There are no means to manually stroke the vacuum breaker.
ALTERNATE TESTING: Each refueling outage, each vacuum breaker will be tested to
- determine that the force required to open the vacuum breaker -
does not exceed the force specified by Tech. Spec. Section 3.7.A.5.a and each vacuum breaker will be inspected and verified to meet the design requirements.
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s Rev. 8 j
V-67
r RELIEF REQUEST BASIS NUMBER: V39 SYSTEM: Radwaste VALVE: V20-82, V20-83, V20-94, V20-95 CATEGORY: A CLASS: 2 FUNCTION: Primary Containment Isolation TEST REQUIREENT: LT BASIS FOR RELIEF: Primary containment isolation valves are covered by 10 CFR 50, Appendix J, via Tech. Spec. Section 4.7.2
.; ALTERNATE TESTING: Leak testing in accordance with Appendix J.
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, , e Rev. 8 V-68
RELIEF REQUEST BASIS NUMBER: V40 SYSTEM: Nuclear Boiler Vessel Instrumentation VALVE: 2-3-11, 2-3-13AA, 2-3-15AA, 2-3-17AA, 2-3-19AA, 2-3-21A-0, 2-3-23A-D, 2-3-25, 2-3-27, 2-3-29AA, 2-3-31A-H, 2-3-31I-Q, 2-3-33, 2-3-35 i
. CATEGORY: C CLASS: 2 FUNCTION: Excess flow check valves for instrument isolation TEST REQUIREENT: CV BASIS FOR RELIEF: Valves can only be verified to shut by leak testing which is performed during the refueling outage hydrostatic test.
Valves cannot be exercised shut during power operation since shutting these would isolate instrumentation required for power operation.
ALTERNATE TESTING: Valves will be functionally tested each refueling outage.
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Rev. 8 V-69 5
- - . - .. . - . . , , , . , - . ~ . . ..,.__,...--r--.--- ,.--,-.,e_m,--. .--- ,-w-., ,,- - ., , - , .w,._.- .,. --_. - , - . - ...--._,,.i..,,~~._,u.
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NUNBER: V41 SYSTEN: Containment Atmosphere 011ution VALVE: FS0-109-75A1,2, FSO-109-7581,2, FSO-109-75C1,2, FS0-109-7501,2,- VG-75A-3,4, VG-24, VG-25, VG-33, VG-34 CATEGORY: A
[ CLASS: .2 FUNCTION: Primary Containnent Isolation i TEST REQUIREENT: LT
. BASIS FOR RELIEF: Valves presently exempted from leak testing per Tech. Spec.
Section 4.7.2 ALTERNATE TESTIPG: None l-t
,l , , . .
Rev. 8 V-70
r- .
RELIEF REQUEST BASIS NUMBER: V42 SYSTEM: . Containment Atmosphere Dilution VALVE:* FSO-109-76AA, VG-23, VG-26 CATEGORY: A CLASS: 2 P FUNCTION: Primary Containment Isolation TEST REQUIREENT: LT
- BASIS FOR RELIEF: Primary containment isolation valves are covered by-10 & R 50, Appendix J, via Tech. Spec. Section 4.7.2
- ALTERNATETEST1k: Leak testing in.accordance with Appendix J. .
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RELIEF REQUEST BASIS NUMBER: V43 SYSTEM: Containment Atmosphere Dilution VALVE: VG-9AA, VG-22AA, PC-11AA, E-12AA, E-13AA CATEGORY: A CLASS: 2 FUNCTION: Primary Containment Isolation TEST REQUIRE >ENT: LT BASIS FOR RELIEF: Primary containment isolation valves are covered by 10 CFR 50, Appendix J, via Tech. Spec. Section 4.7.2.
ALTERNATE TESTING: Leak testing in accordance with Appendix J. .
4 Rev. 8 V-72
^
RELIEF REQtEST BASIS NUMER: V44 SYSTEM: TIP VALVE: Ball A-C, Solenoid CATEGORY: A CLASS: 2 FUNCTION: Primary Containment Isolation
_ TEST REQUIREMENT: LT
. BASIS FOR RELIEF:' Valves are normally closed and passive during an accident.
ALTERNATE TESTING: Valves will be evaluated for leak tightness during the per-formance of each type "A" leak test, and by Appendix J leak testing.
t s - t*
9 Rev. 8' V-73
_. . ._. . , _ ._. .._... ~ - ,. _ ._._ . _ __ . -._ .___ _ _ . , . , , _ . _ . _ _ - . - _ _ ,
o RELIEF REQUEST BASIS NUMER: V45 SYSTEM: TIP VALVE: . Solenoid CATEGORY: A CLASS: 2 FUNCTION: Primary Containment Isolation 4
TEST REQUIREMENT: MT BASIS FOR RELIEF: The solenoid valve permits the guide tube, indexers and. drive
{# mechanisms to be purged with nitrogen in order to prevent rusting of the drive cables and deterioration of the guide tube lubricant. The stroke time on the' solenoid valve is so '
small that it cannot be measured accurately and therefore cannot be evaluated for trends.
. ALTERNATE TESTING: None c
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Rev. 8 V-74 i
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RELIEF REQUEST BASIS NUMBER: GV-1 CODE PARAGRAPHS: IWV-3417 concerning an increase in test frequency BASIS FOR RELIEF: As defined in the Inservice Test Program, there is sufficient justification to test certain valves on either a cold shut-
. down or a refueling outage basis. The test frequency of these valves cannot be increased without jeopardizing plant operations.
b ALTERNATIVE: If any of the valves that are tested quarterly fail, the test frequency will be increased in accordance with the provisions
- 'of the referenced paragraph. If any of the valves that are tested on a cold shutdown basis fail, the valves will be tested each cold shutdown, not to exceed once every month until corrective action is taken.
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I Rev. 8 L - V-75 l
_ - - . - - - - . . - - - - _ - . - _ . , - - -_-_.___- , - . . . .. . .. :.?
5 RELIEF REQlEST BASIS
, NUMBER: GV-2 CODE PARAGRAPHS: IW-3417(b) and IW-3523 concerning corrective action prior to startup.
BASIS FOR RELIEF: The Vermont Yankee Technical Specifications describe various limiting conditions for operation. These are more appropriately used as a basis for plant startup than are the above-referenced requirements.
ALTERNATIVE: The Technical Specifications limiting conditions for opera-i tion will be used as the basis to determine if the plant can startup.
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Rev. 8 i' .V-76 l
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- RELIEF REQUEST BASIS q=x NLM3ER
- GV-3 ,
CODE PARAGRAPHS: IW-3410"and IW-3520 concerning the definition of " cold shutdown" BASIS FOR RELIEF: Since operations personnel are faced with many activities associated with and maintaining the plant in cold shutdown conditions, the operators require some amount of flexibility in scheduling certain surveillance testing. Surveillance testing alone should not be a cause for the plant to remain in shutdown conditions.
ALTERNATIVE: " Cold Shutdown Testing" will be defined as commencing the required testing not later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after cold shutdown is achieved. Testing must continue until complete or the plant is ready to return to power. Completion of all valve testing is not a prerequisite to return to power. Any testing not completed at one cold shutdown should be per-formed during subsequent cold shutdowns to meet the code specified testing frequency.
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! Rev. 8 l- V-77 l
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RELIEF REQUEST BASIS NUMBER: GV-4 CODE PARAGRAPHS: IW8-3417(a) concerning an increase in test frequency.
BASIS FOR RELIEF: Certain power operated valves have very short stroke times.
The ability to accurately measure these short stroke times with a hand-held stopwatch is difficult and not repeatable.
An increase in observed stroke time of 50% or more does not necessarily indicate valve degradation.
ALTERNATIVE: All power operated valves with a reference stroke time of less than or equal to 5 seconds, shall have its test fre-quency increased to once each month until corrective action is taken, if its stroke time increases to 8 seconds or more.
This 8 second maximum stroke time is not applicable if the maxinum operating time for the valve is less than 8 seconds.
, ,
- 1
- A Rev. 8 V-78
r INSERVICE INSPECTION PROGRAM Record of Changes -
INITIALS INITIALS Change Date Change Date Number Entered PORC P1 Supt it00 Number Entered PORC P1 Supt M00 q gpt 12.%
1 6/25/75 d?2 y /" # (dshe 2 LO/18/79
-" *b
n hd,n 3-5/13/8 [
4 6/27/8C 5 10/1/86 w'e se g c o g 6 12/21/81 /
7 1/7/P3
, +d#t iP(80 i N/s3 8 10/26/8 & 5i 5 L
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,