HL-3014, Forwards Response for Table 3 Items from App a of IST Program Safety Evaluation.Response to Section 3.2.3.1 of SE Also Encl
| ML20127N461 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 11/17/1992 |
| From: | Beckham J GEORGIA POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| HL-3014, TAC-M59202, TAC-M59203, NUDOCS 9212010270 | |
| Download: ML20127N461 (28) | |
Text
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Georgis Power Company 40 invemers Center P:skw y Post Offc0 Box 1295 e Birmingham. Alabama 35201 Telephone 205 877-7279 L
J. T. sockham. Jr.
Vce Presdent . Nuclear Georgia Power Hatch Project the soutwn eiectnc 5, stem HL-3014 004251 November 17, 1992 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 SECOND TEN YEAR INSPECTION INTERVAL IST PROGRAM SAFETY EVALUATION RESPONSE NRC TAC NOS. M-59202 AND M-59203 Gentlemen:
By letter dated May 28, 1992, Georgia Power Company (GPC) submitted a proposed schedule for addressing the Appendix A items contained in the Safety Evaluation (SE) issued on GPC's Second 10-Year Inspection Interval IST Program. In the proposed schedule, the Appendix A items were categorized into three tables. Table 1 included items for which GPC is in agreement with the SE. Table 2 included items for which GPC submitted additional justification by letter dated June 5, 1992. Table 3 included items which GPC intended to evaluate and provide a response by November 17, 1992.
In accordance with the submitted schedule, the enclosure provides a response for the items included in Table 3. A response to Section 3.2.3.1 of the SE is also provided in the enclosure. Copies of the revised relief requests reflecting the proposed changes are provided as an attachment to the enclosure.
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Georgia Powerd U.S. Nuclear-Regulatory Commission November 17, 1992 Page Two GPC will implement the appropriate IST program changes, as required, within 6 months of receipt of NRC approval. Should you have any questions in this regard, please contact this office.
Sincerely, h
. T. Beckham, Jr. k JKB/cr Enclosure cc: Georaia Power Company Mr. H. L. Sumner, General Manager - Nuclear Plant NORMS U.S. Nuclear Reaulatory Commission. Washinaton. D.C.
Mr. K. Jabbour, Licensing Project Manager - Hatch U.S. Nuclear Reaulatory Commission. Reaton II Mr. S. D. Ebneter, Regional Administrator Mr. L. D. Wert, Senior Resident Inspector - Hatch 004251 1
ENCLOSURE PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 TABLE 3 ITEMS FROM APPENDIX A
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t ENCLOSURE PLANT HATCH - UNITS 1, 2 NRC 00CKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 TABLE 3 ITEMS FROM APPENDIX A Backaround The enclosure prevides a summary listing and GPC's response to the 11 items from Appendix A of the IST Program Safety Evaluation (SE) categorized by GPC as Table 3 items. A response to Section 3.2.3.1 of the SE is also included.
Appendix A Jtem Number GPC Response A7 Item A7 concerns the leak rate testing performed on valves that provide both a containment isolation function and a pressure isolation function. Per the IST program, containment isolation valves (CIVs) and valves serving a dual CIV and pressure isolation valve (PlV) function are tested per 10 CFR 50, Appendix J, and ASME Section XI, paragraphs IWV-3426 and IWV-3427(a). P!Vs are leak tested per ASME Section XI, IWV-3420 except for IWV-3427(b). Valves performing a dual CIV/PlV function are tested only to ClV acceptance criteria as it is more stringent than the PlV acceptance criteria.
Item A7 requested the IST program be revised to include documentation for each valve performing a dual CIV/PIV function demonstrating that the Appendix J 1eak test bounds the ASME Section XI leak test or otherwise verifies the valve's ability to perform its pressure isolation function. GPC has performed the necessary studies and calculations to justify that the Appendix J leak test bounds the Section XI leak test. The study shows that the CIV leak test- provides reasonable assurance of the valve's leak tight integrity. This information will be retained in plant records and is %
available for NRC review.
A10 Relief Request RR-V-39 proposed to measure the stroke time of the scram discharge volume vent and drain valves as a group rather than individually. Item A10 stated that the proposed method does not allow for detection of individual valve degradation and some method should be developed to monitor individual valve condition.
HL-3014 004251 E-1 1
rWLO$URE (Continued)
JMLL311 EMS FROM APPENDIX A 4
Appendix A Item Number Ec_Retrns.e A10 (Continued) GPC has -investigated the possibility of measuring individual stroke times and concluded this method would eepresent an unnecessary hardship, giver the design of he scram discharge volume vent and drein valves. The sabject valves are not equipped with individual valve
,antrol switttos and are controlled be a single test switch, and the test circJit uses an alternate vent path which d rectly affects the valves' operating time.
Consequently, the opening time during normal operation testing is not representative of the actual opening time. Also, full stroke time testing during normal operation would require disabling the Reactor Protection System scram signal to the subject valves. The installation of electrical jumpers and opening links in ar energized control circuit results in the potential of a reactor scram.
All Relief Requests RR-V-32 and RR-V-40 requested relief from measuring the stroke time of the TIP purge supply valves. The valves are not equipped with remote position indicating lights and the valve stem is not observable for position indication. GPC proposed to verify valve movement quarterly by observing a change in the system purge flow rate. Jtem All stated that GPC's proposed -testing provides no means of detecting valve degradation and some means should be developed to monitor valve condition.
l The relief requests have been revised to provide additional justification and to provide for trending-of l the local leak rate testing data in an attempt to monitor valve degradation.
A13 Relief Requests RR-V-14 and RR-V-17 requested relief from exercising the RHR injection check valves on a L quarterly basis to verify forward flow operability.
l Plant design does not provide any method for a full flow i
exercise during normal operation ,or during normal RHR I
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ENCLOSURE (Continued)
TABLE 3 ITEMS FRGM APPENDlX A Appendix A Item. Numb.er GPC Response A13 (Continued) operation during shutdown. Item A13 stated that the-relief requests provided no justification for not partial-stroke exercising both valves during each cold shutdown and requested GPC to investigate and implement, if practicable, a method to demonstrate that these valves fully open when subjected to shutdown cooling fl ow.
The relief requests have been revised to provide justification for not partial-stroke exercising both valves during each cold shutdown. The revision also provides for a partial exercise of at least one of these valves each cold shutdown with testing to alternate between valves for each cold shutdown. GPC has also investigated whether the valves can be demonstrated to be fully open when subjected to shutdown cooling flow.
For Unit 1, the valves are not full open during RHR operation in the shutdown cooling mode. To full open in this mode, two RHR pumas would be' required; however, the net positive suction aead requirements are not met with this alignment. Consequently, both valves will be ,
partial-stroke exercised each refueling outage and each check valve will be mechanically exercised in accordance with IWV-3522(b), at each refueling outage, to. verify full stroke capability. For Unit 2, the valves have a-smaller cross-sectional area and are fully exercised when subjected-to shutdown cooling flow. The relief requests have been revised ~accordingly and copies are attached to the enclosure.
A14 Relief Request RR-V-22 requested relief from exercising L and stroke -timing the RHRSW heat exchanger outlet valves. Item A14 stated that the proposed testing does not provide for detection of valve degradation and some method should be developeo to detect and monitor valve
. condition. The relief requess has been revis.!d to provide additional justification for the preposed testing and to implement comparison time testing per t
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h ENCLOSURE (Continued)
TABLE 3 ITEMS TROM APPENDIX A Appendix A Jtem Number GEC.Belponse A14 (Continued) IWV-3417(a) to detect valve degradation. A copy of the revised relief request is attached to tne enclosure.
A15 Relief kequests RR-V 13 and RR-V-16 requested relief ,
from exercising the core spray injection check valves on a quarterly basis to verify forward flow opernbility, i Plant design does not provide a method for full flow exercisin9 of these valves during normal system operation. Itui. A15 stated that GPC should full stroke exercise these valves using a mechanical exerciser per 7 IWV-3522(b) or verify a full stroke exercise when the valves are subjected to system tivai a" at least a refueling outage frequency if practical.
- Full flow testing of these valves during shutdown .
conditions is not practical due to the resulting-degradation of reactor coolant quality. Consequently, each check valve will be mechanically exercised in accordance with IWV-3522('.,, at each refueling outage, to verify full stroke capibility. The relief requests have been revised accordingly and copiet are attached to the enclosure.
A20 Item A20 concerned the IST program scope for the reactor core isolation corling system (RCIC) valves.
Previously, RCIC syst un valves, other than those which perform a containment isolation function, could be deleted from the IST program if the accident analysis did not take credit .for the RCIC system. GPC's positior-continues to be that'the system should not be included in the IST program as it is not included in any accident-analysis.
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l ENCLOSURE (Continued) 1 JABLE 3 ITDi5 FROM APPENDIX A Appendix A Item Number GPC Response '
A22 Relief Request RR-V-20 requested relief from exercising and stroke timing seventeen plant service water power operated valves and proposed to verify proper operation by assigning a maximum stroke time and measuring stroke times by direct observation during quarterly test.
These valves are air operated and do not have indicating lights or control switches, item A22 stated that the proposed tests do not provide for detection of valve degradation and that some method should be developed to detect and monitor valve conditions. Relief Request RR-V-20 has been revised such that the subject valves will be stroke timed by observing actual stem movement when the associated room coolers are placed in service.
The requirements of IWV-3413, except as described above, and IWV-3417 will be applied to provide a method to detect and monitor valve condition. A copy of the revised relief request is attached to the enclosure.
1 A23 Relief Request RR-V-19 vequested relief from exercising the high pressure coolant injection (HPCI) system pump room cooler outlet check valves and proposed to samplo disassemble, inspect, and manually exercise these valves during refueling outages. The design of the system does not provide a means for positive verification of the flow rate through each valve. Item A23 stated that GPC should partial stroke exercise these valves wtth flow following disassembly and that GPC should investigate the use of non-intrusive diagnostic techniques to verify these valves full stroke exercise open when subjected to '
partial flow.
The relief request has been revised and no longer proposes -to sample disassemble,- inspect, and manually exercise the valves. The relief -request references.
GPC's Plant Service Water System performance monitoring program which performs periodic flow : measurements throughout the system to detect potential flow and/or component degradation. The subject pump room coolers are included in the monitoring program. These measurements are typically performed corresponding _to- ,
each scheduled refueling outage. Temporary ultrasonic HL-3014 004251 E-5
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ENCLOSURE (Continued)
TABLE 3 ITEM 5 FROM APPENDIX A !
Appendix A !
ltem Number GPC Response A22 (Continued) flow measuring instruments are used to obtain the system flow rates and these rates are compared to-the design basis acceptance criteria for each location. -The monitoring program will confirm that the check valves are capable or performing their safety function.
Trending of the flow measurements will provide data which is potentially indicative of check valve degradation.
A24 Relief Request RR-V-41 requested relief from exercising the diesel generator service water outlet check valves and proposed to perform a partial-stroke exercise quarterly and a full-stroke exercise at refueling !
outages during the diesel generator tests by observing that the diesels are properly cooled. Item A24 stated that GPC had not identified the power levels at which the diesels are operated during the quarterly and refueling outage test and requested GPC to -perform a study verifying that the refueling outage diesel test produces a sufficient loci on the cooling system to qualify these as a full stroke exercise. Also, GPC was requested to determine if direct flow meesurements can be used to verify the flow through these valves.
Relief Request RR-V-41 has been revised to provide the approximate power levels at which the- diesels- arc tested. The diesel testing performed during refueling outages is of sufficient-magnitude to confirm that the valves will open sufficiently to perform their design safety function. Additionally, GPC proposes to.
disassemble, manually exercise, and visually inspect one
. valve every third refueling outage on a rotating _ basis.
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l I- The flow elements indicated on the- P& ids (P41-N526 and N528) were installed and utilized during construction only. Present Instrument and Controls Department records do not contain flow versus differential pressure curves for these elements; thus,.their use for direct flow measurement for IST of the discharge check valves is impractical.
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Ei4 CLOSURE (Continued)
TABLE 3 ITIMS FROM APPEt4 DIX 6 Appendix A Item Numigr GPC Response A24 (Continued) A copy of the revised relief request is attached to the enclosure.
A26 Relief Request RR-V-31 requested relief from measering the stroke times of the torus to drywell vacuum breaker test valves, item A26 stated that GPC's proposal provided no means of detecting valve degradation.
A subsequent review has shown that the subject test valves provide no active safety function. .The valves are located in the torus to drywell vacuum breaker test circuit. Therefore, these valves have been recategorized as "A passive" in the IST program and are not required to be exercised and stroke timed per ASME Section XI. Consequently, the relief request is not required and is being withdrawn.
SER ltem Section 3.2.3.1 Although this item is not contained in Appendix A, Section 3.2.3.1 of the SE discusses GPC's proposed testing of the main steam safety relief valves. Section 3.2.3.1 stated that GPC has not formally requested relief from measuring the stroke times of these valves and that GPC's proposal does not provide adequate information to monitor valve degradation.
Relief Request RR-V-29 has been revised to provide additional information relative to the valve degradation concern. All pilot operating assemblies and at least one valve body are removed and sent to an independer.t testing laboratory each refueling outage. Because of the maintenance, testing, and adjustments performed each refueling outage, additional testing methods to detect valve degradation are unwarranted. A copy of the revised relief request is attached to the enclosure.
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ATTACHMENT TO ENCLOSURE PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES OPR-57 NPF-5 REVISED RELIEF RE0 VESTS 9
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RELIEF REQUEST RR V 32 SYSTEH: TIP System VALVE: 2C51-F3012 CATEGORY: A CLASS: 2 FUNCTION: Containment Isolation TEST REQUIREMENT: IWV-3413 requires that power operated valves be stroke timed quarterly and IWV-3417(b) requires comparison testing.
BASIS FOR REllEF: This valve is not provided with indicating lights and the valve stem is not observable for position indication.
There are no other system provisions other than indirect means (i.e., flow measurement) to determine valve position. Therefore stroke timimg is impractical._
This is a rapid acting solenoid valve which if stroke timing was possible, comparison time testing would not be required per the guidance of GL 89-04 Position 6. Per Position 6 of CL 89 04, valves with stroke times of less than or equal to 2 seconds are considered rapid acting valves which do not require comparison time testing.
The nitrogen purge line is relatively small (3/8") and the FSAR evaluation indicates that even in the event of a neutron monitoring instrumentation dry tube failure, the radioactive release would remain within the required limits.
This valve is local leak rate tested (LLRT) at each' refueling outage in accordance with 10 CFR 50, Appendix J.
LLRT should indicate any problem with the valve seating characteristics which could be indicative of improper valve operation.
ALTERNATE TESTING: Valve will be exercised quarterly and N, flow will- be observed as an indirect means of determining the required change in position. Observation of N, flow confirms valve-position only and does not provide data relative to valve stroke time, i
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RR-V-32 (cont.)
Additionally, the valve is exercised closed each refueling outage and closure is verified by means of 10 CFR 50 Appendix J local leak rate testing (LLRT).
LLRT data will be trended in an attempt to monitor and detect any valve degradation.
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REllEF REQUEST RR V-40 SYSTEM: TIP VALVE: C51-f3012 CATEGORY: A CLASS: 2 FUNC110N: Containment Isolation TEST REQUIREMENT: IWV 3413 requires that power operated valves be stroke timed quarterly and IWV-3417(b) requires comparison tes .19 BASIS FOR REllEF: The valve is not equipped with remote position indicating lights and the valve stem is not observable for position indication. There are no other system provisions that could be used to determine the actual position of the valve.
This is a rapid acting solenoid valve which if provided with indicating lights or if valve stem movement were observable, would not require comparison time testing if the guidance of GL 89 04 Position 6 were applied. Per Position 6 of GL 89 04, valves with stroke times of less than or equal to 2 seconds do not require comparison time testing.
The nitrogen purge line is relatively small (3/8*) and the FSAR evaluation indicates that even in the event of a neutron monitoring instrumentation dry tube failure, the radioactive release would remain within the required limits.
This valve is local leak rate tested (LLRT) at each refueling outage in accordance with 10 CFR 50, Aspendix J.
LLRT should indicate any problem with the valga seating characteristics which could be indicative of improper valve operation.
ALTERNATE 1ES11NG: The valve will be exercised closed each refueling outage and closure verified by means of 10 CFR 50, Appendix J local leak rate testing (LLRT).
LLRT data will be trended in an attempt to monitor /
determine valve degradation.
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RELIEF REQUEST RR-V-14 SYSTEH: RHR VALVE (S): lEll-F050A,B CATEGORY: AC CLASS: 1 FUNCTION: LPCI and Pressure Isolation TEST REQUIREMENT: Verify forward flow operability quarterly or at cold shutdown per IWV 3520.
BASIS FOR RELIEF: The plant and system configuration does not provide for full or partial flow exercising during normal operation.
LPCI injection during normal operation is impossible because reactor pressure is significantly greater than LPCI injection pressure. Therefore full or partial exercising with flow is impossible quarterly.
During operation in the cold shutdown mode, it has been determined that the subject valve for the loop in operation is only partially stroked to the open porition.
To fully open the valve in this mode would require the use of two RHR pumps in combination; however, net positive suction head requirements would not be met in this alignment.
The only way to full flow exercise these valves would be to align the RHR pump suctions to the suppression pool and inject to the RPV at cold shutdown or refueling outage.
This would result in a significant degradation of reactor coolant quality which would require an extensive amount of time to restore the Technical Specification required coolant quality. Therefore full flow exercising at cold shutdown or refueling is impractical.
It is normal plant practice to utilize only one loop of RHR in shutdown cooling for any unscheduled shutdown due to the efforts involved in system alignment, flushing, pipe warm up and swapping of loops. Requiring both loops
- of RHR shutdown cooling to be placed in operation during l an unplanned shutdown for the sole purpose of exercising l each check valve places undue hardship on operation's l
personnel involved with-other shutdown activities and could extend shutdown duration. Therefore partial exercising each valve with RHR shutdown cooling flow during each cold shutdown is impractical.
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4 RR-V-14 (cont.)
These valves are located inside the primary containment and are therefore inaccessible during normal operation or at cold shutdown unless the containment is de-inerted.
The containment is never de-inerted during an unplanned shutdown unless containment entry is absolutely necessary.
Therefore mechanical exercising quarterly or at cold shutdown is impractical.
ALTERNATE TESTING: The loop of RHR utilized for shutdown cooling will be alternated each shutdown. Therefore one of these valves will be partial exercised each cold shutdown and valves (
will be alternated for each shutdown.
During each refueling outage, both loops of RHR shutdown cooling are utilized in support of normal shutdown and fuel handling activities. Therefore each check valve will be partially exercised at each refueling outage.
Additionally, each valve will be mechanically exercised in accordance with IWV 3522(b) at each refueling outage.
Partial exercising with flow at the described frequency along with mechanical exercising and leak rate testing during each refueling outage provides sufficient confirmation of valve operability.
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RELIEF REQUEST RR-V-17 SYSTEM: RHR VALVE (S): 2E11-f050A,B CATEGORY: AC CLASS: 1 FUNCTION: LPCI and Pressure Isolation TEST REQUIREMENT: Verify forward flow operability quarterly or at cold shutdown per IWV-3520.
BASIS FOR RELIEF: The plant and system configuration does not provide for full or partial flow exercising during normal operation. LPCI injection during normal operation is impossible because reactor pressure is significantly greater than LPCI injection pressure. Therefore, full or partial exercising with flow is impossible quarterly.
Engineering review indicates that normal shutdown cooling flow (7700-8200 gpm) results in a flow velocity of >14 fps. Vendor information indicates that the valve is fully open at flow rates >10 fps.
Therefore, these valves are fully exercised by normal RHR shutdown cooling flow, it is normal plant practice to utilize only one loop of RHR shutdown cooling for any unscheduled shutdown due to the extra efforts involved in system alignment, flushing, pipe warm up and swapping of loops.
Requiring both loops of RHR shutdown cooling-to be placed in operation during an unplanned shutdown for the solo purpose of exercising each check valve, places undue hardship on operations personnel involved with other shutdown activities and could extend shutdown duration. Therefore, full flow exercising l each valve at each shutdown is impractical.
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ALTERNATE TESTING: At least one of these check valves receives shutdown cooling flow and is fully exercised at each cold shutdown. The loop of RHR shutdown cooling placed :
into service will be alternated for each unplanned shutdown. Therefore, a different valve will be fully exercised each time shutdown cooling is utilized.
During each refueling outage, both loops of RHR shutdown cooling are utilized in support of normal shutdown and fuel handling activities. Therefore, each check valve will be full stroke exercised at each refueling outage.
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REllEF REQUEST RR V 22 SYSTEM: RHR Service Water VALVE (S): IEll-F068A&B 2 Ell-f068A&B CATEGORY: B CLASS: 3 FUNCTION: RHR Service Water Flow / Pressure Regulation TEST REQUIREMENT: Exercise and stroke time quarterly per IWV-3413.
BASIS FOR RELIEF: These valves operate as pressure control valves modulating to ensure that RHRSW pressure is always maintained greater than RHR pressure across the RHR heat exchangers. Valves are required to close in the unlikely event that accident conditions require injecting RHRSW into the reactor vessel via the RHRSW/RHR inner tie. Valve logic and operating controls prevent the valves from being fully exercised independent of valve controller response time without defeating the logic circuitry. The valves cannot be opened unless the associated RHRSW pump is running.
However, if the valve is fully opened with the pump operating, the pump would then run out and cause potential damage to the pump.
RHRSW is required Gring plant shutdown for cooldown of the reactor coolant system. Attempting to defeat valve operating logic to perform an exercise test at cold shutdown could extend the shutdown. Performing such testing at cold shutdown impotes undue requirements on operations personnel involved with other shutdown activities.
ALTERNATE TESTING: Quarterly RHRSW pump testing demonstrates that the valve is operating properly to control RHRSW pressure and also ensures that the valve is capable of closure. Thus partial exercising of the valve occurs quarterly.
Each refueling outage the valve operating logw will be defeated and the valve will be exercised and stroke timed in both the open and closed directions. Comparison time testing per IWV-3417(a) will be applied to detect valve degradation. ,
4 RELIEF REQUEST RR-V-13 SYSTEM: Core Spray VALVE (S): lE21-f006A,B CATEGORY: AC CLAS$: 1 FUNCTION: Core Spray Injection and Pressure Isolation TEST REQUIREMENT: Verify forward flow operability quarterly or at cold shutdown per IWV-3520.
BASIS FOR RELIEF: The piant and system configuration does not provide for full or partial flow exercising during normal operation.
Core spray injection during normal operation is impossible because reactor pressure is significantly greater than core spray injection pressure. Therefore full or partial exercising with flow is impossible quarterly.
The only possible way to flow test these valves is by injecting suppression pool water into the RPV or alternately aligning the core spray pump suction to the condensate storage tank (CST) and injection to the RPV.
Utilizing either suction source results in significant degradation of the reactor coolant quality due to the poor quality of the-suppression pool water or the poor quality of stagnant water in the piping associated with aligning the core spray pumps to tie CST. A significant amount of time would be required to restore reactor coolant to the Technical Specification required quality. Therefore exercising with flow at cold shutdown or refueling is impractical.
These valves are located inside the primary containment and are therefore inaccessible during normal operation or at cold shutdown unless the containment is de-inerted.
The containment is not de-inerted during an unplanned shutdown unless containment entry.is necessary. Therefore mechanical exercising quarterly or at cold shutdown is impractical.
ALTERNATE TESTING: Each check valve will be mechanically exercised per IWV-3522(b) during each refueling outage. This mechanical exercising in conjunction with leak rate testing each refueling outage will provide sufficient confirmation of valve operability.
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RELIEF REQUEST RR-V-16 SYSTEM: Core Spray VALVE (S): 2E21-f006A,B CATEGORY: AC CLASS: 1 FUNC110N: Core Spray Injection and Pressure Isolation TEST REQUIREMENT: Verify forward flow operability quarterly or at cold -
shutdown per IWV-3520.
BASIS FOR RELIEF: The plant and system configuration does not provide for full or partial flow exercising during normal operation.
Core spray injection during normal operation is impossible because reactor pressure is significantly greater than core spray injection pressure. Therefore full or partial exercising with flow is impossible quarterly.
The only possible way to flow test these valves is by injecting suppression sool water into the RPV or alternately aligning tie core spray pump suction to the condensate storage tank (CST) and injection to the RPV.
Utilizing either suction source results in significant degradation of the reactor coolant quality due to the poor quality of the suppression pool water or the poor quality of stagnant water in the oiping associated with aligning the core spray pumps to tie CST. A significant amount of time would be required to restore reactor coolant to the Technical Specification required quality. Therefore exercising with flow at cold shutdown or refueling is impractical.
These valves are located inside the primary containment and are therefore inaccessible during normal operation or at cold shutdown unless the containment is de-inerted.
The containment is not de-inerted during an unplanned shutdown unless containment entry is necessary. Therefore mechanical exercising quarterly or at cold shutdown is impractical.
ALTERNATE TESTING: Each check valve will be mechanically exercised per IWV-3522(b) during each refueling outage. This mechanical exercising in conjunction with leak rate testing each refueling outage will provide sufficient confirmation of valve operability.
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RELIEF REQUEST RR-V 20 SYSTEM: Plant Service Water VALVE (S): IP41-F035A&B, IP41-F036A&B, IP41-F037A 0, IP41-F039A&B, IP41-F340,
, 2P41-f035A&B, 2P41-F036A&B, 2P41-F037A D, 2P41-F039A&B, 2P41-F339A&B CATEGORY: B CLASS: 3 FUNCTION: Cooling Water TEST REQUIREMENT: IWV-3412(b) requires stroke timing by observation of an appropriate indicator which signals the required change of disk position, or observation of indirect evidence, such as changes in system pressure, flow rate, level, or temperature, which reflects stem or disk position.
BASIS FOR RELIEF: These valves are air operated valves without indicating lights or control switches. Heasurement of stroke times can be performed only by observation of the stem movement when the associated room cooler is placed into operation.
ALTERNATE TEST!NG: Valves will be stroke timed by observing actual stem movement when the associated room coolers are placed in service. Stroke time will be considered to be the time frame from start to stop of valve stem movement. The requirements of IWV-3413, except as described above, and IWV-3417 will be applied.
REllEF REQUEST RR-V-19 SYSTEM: Plant Service Water VALVE (S): 2P41-F024A&B CATEGORY: C CLASS: 3 FUNCTION: Provide cooling water flow to RHR, HPCI, and CS pump / pump room coolers TEST REQUIREHENT: Verify forward flow operability quarterly or at cold shutdown per IWV-3520.
BASIS FOR RELIEF: During quarterly testing of the HPCI, RHR, and Core Spray Pumps, the associated room coolers are placed in operation, thereby exercising these valves. However, system design does not provide for positive verification (flow instrumentation) of the flow rate through each valve. Therefore confirmation of full flow exercising quarterly or at cold shutdown is impossible.
ALTERNATE TESTING: GPC has implemented a Plant Service Water System Performance Monitoring Program which performs periodic flow measurements at various locations throughout the system to detect putential flow or component degradation.
These measurements are performed prior to each scheduled refueling outage in order that any required corrective measures can be implemented during the subsequent outage.
Temporary ultrasonic flow measuring instruments are utilized to obtain the required system flow rates and the architect engineer has provided the design basis acceptance criteria-for each location included in the program.
The ECCS room coolers are considered important pieces of equipment and thus service water flow to and from each cooler is included in the service water performance monitoring program.
The GPC Service Water Performance Monitoring Program will be utilized prior to each refueling outage to confirm that these check valves are capable of opening sufficiently to perform their safety related function. Trending of the associated flow measurements will provide data which is potentially indicative of check valve degradation.
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Partial exercising of each check valve is confirmed during-quarterly testing of the associated ECCS room coolers.
Temperature indicators are provided in the system piping which will provide some assurance that the check valves are not stuck in the closed position.
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REll[F REQUEST RR-V 41 SYSTEM: Plant Service Water VALVE (S): P41 f552A&C CATEGORY: C CLASS: 3 FUNCTION: Diesel Generator Discharge Line Check Valves TEST REQUIREMENT: Verify forward flow operability quarterly per IWV-3522(b).
BASIS FOR REllEf: These normally closed check valves are located in the cooling water discharge lines from diesel generators lA and IC. There are no system design provisions to verify forward flow operability by flow rate measurement.
Each diesel generator is operated for a minimum of one hour at 1710 - 2000 kW (approx. 60 percent of continuous rated load) during testing once each month. Partial forward flow operability is verified during this test by monitoring diesel generator oil and jacket cooling water temperatures.
Additionally, each diesel generator is operated for a minimum of one hour at 2250 - 2400 kW (approx. 80 percent of continuous rated load) semi-annually. Partial flow operability is verified during this test by monitoring diesel generator oil and jacket cooling water temperatures.
Additionally, at each refueling outage (at least once per 18 months) each diesel generator is operated for a minimum of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. During the first two hours of this test, the diesel is loaded to a 3000 kW (approx. 105 percent of continuous rated load) and during the remaining 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> of this test, the diesel is loaded to 2775 - 2825 kW (approx. 90 percent of continuous rated load).
Acceptable operation of the diesel generators during the monthly and semi-annual tests verifies that the valves are not stuck in the closed position. Acceptable operation of the diesel generators during each refueling outage test verifies that the check valves have opened sufficiently to perform their design function. The diesel generator oil and jacket cooling water temperatures are trended to ensure no significant changes occur from test to test.
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4 RR V 41 (cont)
ALTERNATE TESTING: Existing monthly and semi-annual diesel surveillance testing will be utilized to prove at least partial check valve exercising and the existing refueling outage-frequency test confirms that the valves will open i sufficiently to perform their design safety function.- i in addition, one valve will be disassembled, manually exercised and visually inspected every third refueling .
outage on a rotating frequency. Based on available maintenance history and NPRDS data, this frequency is warranted. These are stainless steel check valves subjected to relatively stable service water flow which does not pose any severe service conditions.
The valves are flanged into the system piping and are '
completely removed when disassembled and inspected. The valve is manually full stroke exercised prior to being reinstalled in the pipe line.- The valve disassembly is performed prior to the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> diesel surveillance tests, thus the safety function of the valve is-confirmed after reassembly.
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1 RR V-31 )
SYSTEM: Containment Purge and Inerting VALVE (S): T48-F342A L 2T48-F342A-L CATEGORY: A CLASS: 2 FUNCTION: Torus to Drywell Vacuum Breaker Test Valve and Air Line Containment Isolation TEST REQUIREMENT: Exercise and stroke time quarterly per IWV 3413.
BASIS FOR RELIEF: Actuation of this normally closed solenoid valve by the test switch allows air flow to the test cylinder, which then moves the disc of the vacuum breaker check valve to the open position. When the test switch is released, the solenoid valve closes the air supply, the air cylinder depressurizes through the exhaust port, and the check valve disc closes. The open/ closure of the check valve is verified by indicating lights; however, there are no positive means of verifying the closure of the solenoid valve or of performing stroke time measurement.
ALTERNATE TESTING: Closure of the air supply by the solenoid valve is verified by closure of the check valve. If the solenoid did not block the air supply when de energized the vacuum breaker check valve would remain open. However, the closure time of the solenoid valve is independent of the closure time of the check valve and therefore cannot be measured, in addition, closure of the solenoid valve is verified each refueling outage during Local Leak Rate Testing.
Additional review indicates that these valves provide no active safety function. They are located in the torus to drywell vacuum breaker test circuit and testing is not considered a safety function (Per IWV-1200(a) ' test' valves are exempt). Therefore, these valves-have been re-categorized as "A Passive' in the IST Program. Category 'A Passive" valves are not required to be exercised and stroke timed per ASME XI. Therefore, this relief request is not required and is being withdrawn.
Operability of the associated vacuum breakers is proven not only by quarterly exercising using the test circuit, but also by performing a visual inspection and a manual exercise test which measures the force required to operate the vacuum breaker during each refueling outage.
RELIEF REQUEST RR V 29 SYSTEM: Nuclear Boiler System VALVE (S): IB21-F013A H, J, K, and L 2B21 F013A H, K, L, and H CATEGORY: BC CLASS: 1 FUNCTION: Nuclear Boiler System over pressure protection TEST REQUIREHENT: Exercise and stroke time quarterly per IWV 3410.
BASIS FOR RELIEF: Failure of these valves to close while being stroke tested during power operation would cause a loss of the primary reactor coolant. These valves cannot tre exercised at pressure below 100 psig and the position of the main stage of this 2 stage relief valve can only be determined by indirect means.
ALTERNATE TESTING: For Unit 1, once during the operating cycle, at a reactor pressure greater than 100 psig, each relief valve shall be manually opened until thermocouples downstream of the valve indicate steam flow.
For Unit 2, at least once per 18 months, when the reactor steam dome pressure is greater than 100 psig, these valves shall be manually opened and observed to ensure that either;
- 1. The control valve or bypass position responds accordingly, or
- 2. There is a corresponding change in measured steam flow.
Additionally for both units, all pilot operating assemblies and at least one valve body are removed and sent to an independent testing laboratory each refueling outage. These components are inspected and tested to determine their operating condition. Each pilot assembly is repaired / adjusted to ensure its operability prior to re installation. Therefore, due to the maintenance, testing and adjustments performed-each refueling outage, additional testing methods which might detect valve degradation are unwarranted.
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