JAFP-02-0212, Proposed Revision of Relief Request No. VRR-04 to JAFNPP In-Service Testing Program
| ML023300131 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 11/12/2002 |
| From: | Ted Sullivan Entergy Nuclear Northeast |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| JAFP-02-0212 | |
| Download: ML023300131 (3) | |
Text
En tergy Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.
James A Fitzpatrick NPP PO Box 110 Lycoming, NY 13093 Tel 315 349 6024 Fax 315 349 6480 T.A. Sullivan Vice President, Operations-JAF November 12,2002 JAFP-02-0212 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop O-PI-17 Washington, DC 20555
Subject:
James A FitzPatrick Nuclear Power Plant Docket No. 5 0-333 Proposed Revision of Relief Request No. VRR-04 to the JAFNPP In-Service Testing Program
Dear Sir:
This submittal forwards a proposed revision to JAFNPP In-Service Testing (IST) Program Valve Relief Request VRR-04 for your review and approval. The revision clarifies the conditions under which the identified Alternate Testing is performed.
VRR-04, approved for the Third Interval JAFNPP IST Program, currently states that [the subject valves]
"will be exercised open and the pair (at least one valve) will be verified to close during cold shutdown and each refueling outage...." The Altemate Testing cited in VRR-04 requires the installation of special test equipment such that in practice, the tests are normally only performed during the extended duration of a refueling outage, as permitted by applicable codes.
The proposed revision to VRR-04 deletes the words "during cold shutdown" from the Altemate Testing identified by the relief request, making this a refueling outage test. This change is consistent with the provisions ofNUREG-1482, "Guidelines for Inservice Tests at Nuclear Power Plants", section 4.1.4, which identifies the need to set up test equipment as adequate justification for deferring testing of this type until a refueling outage.
Attachment I provides a markup of existing VRR-04. Attachment 2 contains the revised relief request. If you have any questions, please contact Mr. John Hoddy at (315) 349-6538.
Ve truly yours,,
T.A. Sullivan Vice President Operations to JAFP-02-0212 VRR-04 markup VRR-04 SYSTEM:
VALVES:
CATEGORY:
CLASS:
HIGH PRESSURE COOLANT INJECTION (HPCI) 23HPI-402, 23HPI-403 C
2 Augmented FUNCTION:
TEST REQUIREMENT:
BASIS FOR RELIEF:
ALTERNATE TESTING:
These valves open to eliminate any differential pressure that could force water from the suppression chamber into the HPCI exhaust piping when the suppression chamber pressure is greater than atmospheric. They close to prevent HPCI exhaust steam from entering the suppression chamber air space, thus bypassing the quenching action of the suppression pool.
OM-10, Section 4.3.2.2 - each check valve shall be exercised or examined in a manner which verifies obturator travel to the closed, full-open or partially open position required to fulfill its function.
There are no position indicators on these valves or other means for verifying valve closure, thus the only practical means of verifying closure is to perform a back-leakage test.
Since the valves are installed in series with no intermediate test tap, verifying the each individual valve closes is not practical.
To perform the specified safety function in the closed direction, only one valve of the pair needs to close. Thus in accordance with NUREG-1482 Section 4.1.1, verifying that either valve closes is adequate to demonstrate reliable operation of the pair.
These valves will be exercised open and the pair (at least one valve) will be verified to close during cold shutdown and each refueling outage in accordance with OM-10 Section 4.3.2.2(f) and (g). In accordance with NUREG 1482, if the closure test of the pair of valves fails, then corrective action will be applied to both valves prior to returning the system to operability.
to JAFP-02-0212 Proposed VRR-04R1 VRR-04R1 SYSTEM:
VALVES:
CATEGORY:
CLASS:
HIGH PRESSURE COOLANT INJECTION (HPCI) 23HPI-402, 23HPI-403 C
2 Augmented FUNCTION:
TEST REQUIREMENT:
BASIS FOR RELIEF:
ALTERNATE TESTING:
These valves open to eliminate any differential pressure that could force water from the suppression chamber into the HPCI exhaust piping when the suppression chamber pressure is greater than atmospheric. They close to prevent HPCI exhaust steam from entering the suppression chamber air space, thus bypassing the quenching action of the suppression pool.
OM-10, Section 4.3.2.2 - each check valve shall be exercised or examined in a manner which verifies obturator travel to the closed, full-open or partially open position required to fulfill its function.
There are no position indicators on these valves or other means for verifying valve closure, thus the only practical means of verifying closure is to perform a back-leakage test.
Since the valves are installed in series with no intermediate test tap, verifying the each individual valve closes is not practical.
To perform the specified safety function in the closed direction, only one valve of the pair needs to close. Thus in accordance with NUREG-1482 Section 4.1.1, verifying that either valve closes is adequate to demonstrate reliable operation of the pair.
These valves will be exercised open and the pair (at least one valve) will be verified to close during each refueling outage in accordance with OM-10 Section 4.3.2.2(f) and (g). In accordance with NUREG-1482, if the closure test of the pair of valves fails, then corrective action will be applied to both valves prior to returning the system to operability.